Grant Management Basics for AFG Awards

CONGRATULATIONS! Your volunteer or combination fire department has just been awarded a grant through FEMA’s Assistance to Firefighters Grant (AFG) program. You are now ready to purchase the new tools, equipment, and resources requested through the grant. Are you truly ready, though? Accepting a grant award comes with considerable responsibility, which first-time grant recipients or departments without dedicated grant managers may not realize. Here are key principles of grant management that you must understand before accepting a grant award.

Review the Notice of Funding Opportunity (NOFO)

When you were developing and submitting your application, if you were like many applicants, you probably skipped over the administrative requirements for applying and receiving a grant award and went directly to the eligible items lists and equipment priorities. This could prove to be a fatal error if you fail to comply with any of those administrative requirements. Now is the time to make sure that you thoroughly understand each requirement and are prepared to maintain compliance with the requirements. By submitting a grant application, you have attested that you have reviewed and agree to comply with all the terms and conditions of the NOFO and your Notice of Award (NoA).

Review Your NoA Document

Before accepting the award, you should carefully read the award package. The award package includes instructions on administering the grant award and the terms and conditions associated with responsibilities under federal awards. Don’t assume that everything you asked for and all of the associated costs were approved during the award process. During the review process for an AFG Program award, FEMA may modify the application request. These modifications will be identified in the award package.

If the awarded activities, scope of work, or requested dollar amount does not match the application as submitted, the recipient shall only be responsible for completing the activities actually funded by FEMA. The recipient is under no obligation to start, modify, or complete any activities requested but not funded by the award. The award package will identify any such differences under the Approved Scope of Work section.

Contact Your Grant Administrator Regularly

Each FEMA region has one or more grant program specialists who are available to provide technical assistance with managing your grant. They are responsible for monitoring the performance of your grant and reviewing progress reports submitted under the grant. You should establish contact with the grant program specialist assigned to your grant and maintain regular contact to ensure that your actions are fully in compliance with the laws and regulations governing the grant.

Review and Understand Code of Federal Regulations (CFR) Part 200

In addition to the administrative requirements specified in the NOFO and the NoA documents, each grant recipient must also be familiar with and in compliance with the requirements of CFR 200. CFR 200 is managed by the Office of Management and Budget (OMB) to provide uniform federal government guidance on the administrative requirements, cost principles, and audit requirements for ALL federal awards. Although the grant recipient must be familiar with and in compliance with all portions of CFR 200, Subpart D is specific to postaward requirements, with requirements that include the following:

Recipients must establish and maintain a financial management system to identify how federal funds are requested and controlled (CFR 200.302).
Recipients must establish and maintain procurement procedures to avoid conflicts of interest (CFR 200.318) and provide full and open competition (CFR 200.319). Procurement procedures must establish standards for when informal and formal procurement methods are used and how formal proposals are evaluated for larger purchases (CFR 200.320).
Recipients must comply with all reporting requirements established by the awarding agency (CFR 200.328).
Recipients must establish and maintain a record keeping system as well as maintain all records for a grant award for a minimum of three years following closeout of the grant (CFR 200.334).

If your department is not familiar with the requirements of CFR 200, consider additional training in these requirements. FEMA offers training through the “Fundamentals of Grants Management Course” (course code O705) to help grant recipients better understand the requirements of CFR 200 and improve their grant management skills, from pre-award through closeout. This course is offered both virtually and in-person through FEMA’s Emergency Management Institute (EMI).

Competitive Procurement

Before you pick up the phone and call your favorite supplier and issue a purchase order, consider federal requirements for competition. Because you are spending federal dollars, you are required to consider the best value and cost. Your procurement policy should specify thresholds where competition is required. Normally, you can make small purchases without considering competition. For larger purchases, you must follow fair and open competition procedures.

Your procurement policy should specify which actions must be performed and how evaluation of competitive proposals is conducted to ensure the best value. Remember that best value does not always mean lowest price, but you must be able to document why a higher priced proposal was selected. There may also be cases where only a single vendor can provide the goods and services needed. A single source can be considered if you document why it is uniquely qualified to provide the goods and services needed.

Federal regulation also encourages you to consider small and disadvantaged businesses in the selection of vendors to goods and services. These businesses may operate at an economic disadvantage from the larger vendors and offering them the opportunity to provide pricing on smaller purchases may serve the local economy favorably.

Maintain Complete Records for the Grant Award

As noted above, grant recipients are required to maintain and retain sufficient records to detail the history of the grant award cycle from pre-award to closeout. A record keeping system, either maintained electronically or as a paper file system, should include the following documents:

A copy of the NOFO that the grant application was submitted under. This may be important if there is a question about requirements later since the rules may change each grant cycle.
A copy of the NoA document. This is important because it establishes the requirements for what is authorized under the grant.
Copies of all correspondence with the Grants Program Office. If it’s not in writing, it didn’t happen.
Specifications for equipment purchased.
Solicitation documentation, such as requests for quotes, invitations for bids, or requests for proposals.
Responses to solicitations, such as quotes, bids, or proposals.
Basis for selection decisions.
Copies of contract documents and amendments.
Purchase orders.
Contracts.
Canceled checks.
Generally, you must maintain financial records and supporting documents pertinent to a federal award for at least three years from the date of closeout for the grant.

FEMA, through its authorized representatives, has the right, at all reasonable times, to make site visits or conduct desk reviews to check on project accomplishments, management control systems, and award progress and to provide any required technical assistance. During site visits or desk reviews, FEMA will review recipients’ files related to the award. As part of any monitoring and program evaluation activities, recipients must permit FEMA, on reasonable notice, to review grant-related records and to interview the organization’s staff and contractors regarding the program. Recipients must respond promptly and accurately to FEMA requests for information relating to the award.

Complete Reporting Requirements

Recipients are required to submit various financial and programmatic reports as a condition of award acceptance. Future awards and funds drawdown may be withheld if these reports are delinquent. Recipients should keep detailed records of all transactions involving the grant. FEMA may at any time request copies of purchasing documentation along with copies of canceled checks or other proof of payment documentation for verification.

As you near the end of the grant award cycle, you must ensure that you have submitted all reports to FEMA to allow for adequate monitoring and reporting of the grant program performance. As noted above, you must also maintain your records system for at least three years following the grant’s closeout.

Managing your AFG grant (or any grant award) comes with great responsibility. Do not consider the money received a gift, as each grant has program goals established by the awarding organization. To be successful, you must understand and follow the rules.

DAVID LEWIS is the Maryland director for the National Volunteer Fire Council (NVFC) and a member of the NVFC Homeland Security Committee. He is an active member of the Odenton (MD) Volunteer Fire Company, previously serving as assistant chief and as president. Lewis has been responsible for acquiring more than $1M in grants for his own company and assisting others in developing successful grant proposals. He serves as one of the NVFC’s representatives to the AFG Criteria Development Group and as a peer panelist for the FEMA AFG program. He is active as an instructor for the NVFC, the National Fire Academy, and the Maryland Fire and Rescue Institute, delivering training programs and conference presentations across the United States.