The Applicant then opened four new sites (Aug. 26, 2014) and opened a fourteenth site (Aug. 27, 2014). Debris Removal, Procurement | FEMA.gov Here, the Applicant only provided information about its RFQ process, but did not provide the information needed to determine if it complied with its own procurement policies in procuring its debris removal services. Prior to Hurricane Ians landfall in Southwest Florida, FDEM positioned five teams along the projected path of the storm alongside FEMA partners to immediately begin conducting rapid damage assessments after Hurricane Ian in impacted areas. The Department of Homeland Security stated that it concurred with GAO's recommendations. We made 5 recommendations, including that FEMA assess fraud risks to this program and provide antifraud training to grant recipients and program staff. A day after it was announced for the first time FEMA will assist with residential debris removal, the agency explains not everyone will be eligible. Use extreme caution Debris monitoring costs for the first 90 days were properly reimbursed in other PWs. In areas designated with severe damage, FEMA will waive the requirement for approval of applicants for all storm-related residential debris and commercial right-of-way debris. Specifically, this process should include (1) identifying inherent fraud risks to PA grant funds, (2) assessing the likelihood and impact of inherent fraud risks, (3) determining fraud risk tolerance, (4) examining the suitability of existing fraud controls, and (5) documenting the fraud risk profile. Thanks to advanced coordination with federal, state, and local partners, FDEM has conducted the damage assessment process in a more comprehensive and expedited manner to ensure counties can quickly receive the FEMA Public Assistance funding needed to begin the long-term recovery process. Accordingly, this appeal is denied. Trump Ally Mark Meadows Asks Judge to Block Arrest in Georgia FEMA Second Appeal Analysis, City of Fort Lauderdale, FEMA-1609-DR-FL PW 2932 (Nov. 25, 2015). [5] The Applicant also provided documentation to refute the RAs finding regarding the availability of additional insurance proceeds. By utilizing the advanced prestaging and deployment of state recovery teams, and securing 100% Category A assistance for 30 days, Florida has paved the way for municipalities to expedite debris removal. As you move wet and damaged things out of the home, you need to sort them by category and place them at the side of the road in separate piles. [21] Reasonable costs can be established through the use of historical documentation for similar work, average costs for similar work in the area, published unit costs from national cost estimating databases, or FEMA cost codes. The letter with this request can be foundhere. Published: Sep 29, 2020. The contract between the Applicant and NRWS; Any change orders on the NRWS contract to perform specific earthquake debris removal work; Any information regarding the ability of NRWS to hire subcontractors and how the subcontractors were to be governed; and. The record shows monitoring work was completed with each stage of debris removal; any subsequent monitoring work duplicates work already documented and reimbursed in PWs 425 and 442. In January 2023, FEMA officials stated that FEMA plans to issue the newer version of the PAPPG by the end of 2023 and plans to include information on how and where to report suspected fraud in that version of the guide. [4], Applicants are required to monitor debris removal operations to document eligible debris quantities and expenses to ensure that the work is eligible for public assistance funding. ) or https:// means youve safely connected to the .gov website. Here is FEMA Should Take Additional Actions to Strengthen Fraud Risk Management for Public Assistance Emergency Work Grants. We will continue to monitor FEMA's progress in this area. While FEMA policy does not require monitors to be certified professionals it notes that they should have experience working on construction sites and that they should be able to estimate debris quantities, differentiate debris types and follow all safety procedures. In response to the disaster the Applicant began and continued a debris collection and removal program. Therefore, FEMA notes that the issue of the Applicants contract procurement noncompliance is not in dispute on second appeal. [8] Debris Monitoring Guide, at 1; DAP 9580.203, at 1. [9], Debris monitors must be qualified for the task they perform. Cost Estimating Tools | FEMA.gov [16] The Applicant performed interspersed spot checks, but there is insufficient documentation to demonstrate that this would have satisfied FEMAs monitoring requirements. [5] Failure to do so may jeopardize funding. The Applicant initially provided a spreadsheet with debris estimates by the cubic yard for its six facilities. You dont want to touch things twice: Once everything that cant be saved has been readied for pickup, recovery can begin. Debris Removal and Monitoring | FEMA.gov In fact, the Applicant notes that only one drop off was turned awaya clean load of dirt. The Applicant appealed, arguing costs for verification work performed during the 91-180 day time frame and beyond are eligible, the contractors data collection system was acceptable under FEMAs program, and costs were necessary and reasonable. For homeowners, items can include an exterior ramp, grab bars and a paved pathway to the homes entrance from a vehicle. Finally, the Grantee conceded that the debris removal operation had room for improvement as there were procurement issues (mainly the use of a T&M contract beyond the 70-hour time limit), along with issues surrounding the comingling of debris. [11] A cost is considered reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.[12] FEMA determines whether costs are reasonable by considering factors such as the facility type, the market price for similar goods or services, availability of resources, project complexities, exigent circumstances, and compliance with procurement requirements.[13]. (Recommendation 1), The Administrator of FEMA should update key training and guidance documents for the PA grant program to include information on where and how to report suspected fraud, and direct PA recipients to include such information in key training and guidance documents they provide to subrecipients. [6] Monitoring debris removal is the means by which an applicant documents eligible work and costs for reimbursement. of Ga. Bd. [3] Failure to document eligible work and costs may jeopardize PA grants.[4]. Jun 9, 2021 Earthquake | Disaster Clean-up and Debris Removal Learn about disaster clean-up and debris removal after an earthquake. The PW summarized the Applicants debris collection program, monitoring, and associated costs. The Applicant failed to provide documentation which would allow FEMA to determine whether the costs associated with the debris collection, removal, and monitoring were reasonable. Some parts may be able to be recycled. An official website of the United States government. FEMA will not reimburse costs incurred beyond those 90 days resulting from its deficient recordkeeping, as they were not reasonable and necessary for the performance of the federal award. The highest fraud risks may include risks related to procurement and debris removal, and other risks FEMA identifies through fraud risk assessments. After that, FEMA will conduct assessments alongside the county to determine Public Assistance funding. Debris Removal-Reasonable Costs | FEMA.gov When the Applcant elected to participate in the Pilot Program, it agreed that any work done after 180 days would be ineligible. In areas designated with severe damage, FEMA will waive the requirement for approval of applicants for all storm-related residential debris and commercial right-of OFFICE OF THE PRESIDENT, OMB CIRCULAR A-87, COST PRINCIPLES FOR STATE, LOCAL, AND INDIAN TRIBAL GOVERNMENTS (2013) (codified at Title 2 Code of Federal Regulations 225). Boat, Debris Removal Skiff: Debris Removal Skiff: Length 48' to 200: New 2023 rate: hour: $154.85: 8138: Boat, Jet: Boat, Jet (Woolridge Xtra Plus Inboard) Length 20' 4" to 100: Shallow Draft: hour: $30.93: 8140: Boat, Tug: Miscellaneous 100 - Inland On August 17, 2017, the Applicant appealed FEMAs denial of all costs in PWs 508 and 502 with the exception of the costs FEMA deemed as ineligible CPPC fees. The Applicant incurred costs of $2.32 million at an average of $72 per cubic yard of debris removed. [5] Title 2 of the Code of Federal Regulations (2 C.F.R) 200.403(a) (2014). LockA locked padlock Please inform the Applicant of my decision. 200.317, 200.318(j) 200.404, 200.338. FEMA updated several, but not all, key training and guidance documents for the PA grant program to include information on where and how to report suspected fraud. Accordingly, the Applicant now requests $254,711.88 for PW 508 and $90,083.02 for PW 502. These positions are full-time, 120-day appointments that may be extended depending on operational needs. WebCosts to remove incident-related debris (including, but not limited to, vegetative debris, components of structures, sand, mud, silt, gravel, rocks, boulders, vehicles, and vessels) A lock ( [1] Determination Memorandum from FEMA Region IX, to City of Napa, at 1 (Apr. The Applicant appealed by letter dated January 14, 2019 for $2,831,795.97, stating that although the contractors performed the debris removal within the first 90 day period, the costs submitted were for verification work performed during the 91-180 day time frame (and beyond), which are eligible. It also asserted that FEMAs requirement to monitor debris quantities and amounts is an interpretive variable, which varies depending on the project and the personal opinion of the assessor. A .gov website belongs to an official government organization in the United States. The Applicant then responded to the Grantee stating that it could not properly respond to the RFI without a more detailed description of what information FEMA was requesting. Re: Second Appeal South Carolina Department of Transportation, PA ID 000-URFSC-00, FEMA-4166-DR-SC, Project Worksheet (PW) 453 Debris Disposal and Monitoring Allowable Costs and Reasonable Costs. 28, 2015). FEMA stated that, during the initial request, it was noted that the Applicant did not incur any costs for Leaner/Hanger (L/H) (i.e., hazardous trees) removal operations during the 91-180 day time frame and, as such, its contractor could not have been monitoring eligible L/H work during that timeframe. Awards do not count toward your Housing Assistance or Personal Property maximum awards. By Erik Larson. Similarly, the RA determined that the Applicant was unable to demonstrate it properly validated the costs claimed by the contractors. [5] Public Assistance Debris Management Guide, FEMA 325, at 30, 105 (July 2007) [hereinafter Debris Management Guide]. Debris Removal Guidelines Help You and Your The Grantee claimed that the Applicant requested bids from debris monitoring companies but none responded, which led to the Applicant hiring SEA. LockA locked padlock Furthermore, the Applicant stated that the quantities of storm-generated debris collected from two of the six facilities could be ascertained in contractor invoices and load tickets documenting the relocation of the debris that was initially staged in a floodplain. FEMA denied the appeal because the Applicant did not: (1) pursue all available insurance proceeds; (2) monitor its contracted debris removal work; (3) provide documentation substantiating its claimed debris amounts and costs for force account labor and equipment; (4) justify its use of T&M contracts, a verbal contract, its unscheduled rates, or the subcontractors hourly labor rate; or (5) establish that its costs were reasonable. However, the agency has not comprehensively assessed fraud risks to these grants as called for by leading practices in GAO's Fraud Risk Framework. Specifically, DHS noted that different FEMA entities have responsibilities for managing fraud risks and that FEMA believes combining these functions into one office would potentially cause conflicts of interest. The Applicant met with the California Governors Office of Emergency Services (Grantee) and the Federal Emergency Management Agency (FEMA) to prepare Project Worksheet (PW) 250 encompassing the debris collection and removal program. Timely, accurate, and These monitors manned the collection sites 24/7 and maintained a log for individuals dropping off debris to include their names, phone numbers, and addresses, and whether the debris was related to the disaster. Hurricane Ian brought catastrophic damage to Southwest Florida, but we will be with impacted communities every step of the way as they begin to recover and rebuild stronger.. In addition, according to FEMA officials, the Fraud and Internal Investigations Division completed a preliminary assessment of PA emergency protective measures in September 2022, with an estimated completion date for the review of June 2023. Dir., Ga. The RA also determined that the Applicant violated Federal procurement and contracting requirements in its improper use of T&M and CPPC contracts and an informal verbal contract arrangement with the subcontractor. The Applicant submitted a letter to the Grantee, who forwarded it to FEMA on July 15, 2016, asserting FEMA did not provide enough guidance in the final RFI to allow the Applicant to respond with documents that would support any prior deficiencies. Share sensitive information only on official, secure websites.. WASHINGTON --To accelerate the removal of debris from Hurricane Ian in Florida, FEMA is providing limited waivers to the application process for Public Assistance Private Property Debris Removal/Commercial Property Debris Removal. (Recommendation 5), Disaster Assistance: FEMA Should Take Additional Actions to Strengthen Fraud Risk Management for Public Assistance Emergency Work Grants. However, the spreadsheets do not specify the size of the debris loads, nor do they indicate the specific amounts of work that can be attributed to the contractor, subcontractor, and force account labor or equipment. FEMA prepared Project Worksheet (PW) 453 to cover the Applicants costs for work performed to monitor debris removal operations during the 91-180 day time frame from May 11 to August 8, 2014 under the Public Assistance (PA) Alternative Procedures Pilot Program for Debris Removal (Pilot Program), and awarded $295,670.18 in estimated costs. The Applicant filed a second appeal requesting a reduced award based on the disasters median cost for debris removal work of $20.39/CYi.e., reducing its It also contended that it provided a high degree of oversight to ensure cost controls in a reasonable manner, and was able to determine that the costs were reasonable by monitoring the quality of the work completed. As explained in the enclosed analysis, debris monitoring costs for work performed during the first 90 days were properly reimbursed. Currently, Charlotte, Collier, DeSoto, Flagler, Hardee, Hillsborough, Lee, Manatee, Orange, Osceola, Pinellas, Polk, Putnam, Sarasota, Seminole, St. Johns, and Volusia counties are also eligiblefor FEMA Individual Assistance, which may include temporary housing assistance, basic home repairs and certain other uninsured disaster-related needs. According to FEMA officials, the program review branch of FEMA's Fraud and Internal Investigations Division completed its review of PA debris removal in September 2022. The FIRs for PWs 425 and 442 both stated costs were based on actual costs for the disaster and there were no additional items to be claimed. This is in response to a letter from your office dated September 28, 2018, which transmitted the referenced second appeal on behalf of the City of Napa (Applicant). The Applicant responded to the issues in FEMAs Determination Memo by arguing, among other things, that an analysis showed that the vast majority of the debris was consistent with earthquake-related damage; 94 percent of the debris could be validated as residential debris; the debris collection sites were adequately monitored; the city monitored its contractors and the self-hauling residents; and the debris removal was necessary to eliminate an immediate threat to public health and safety. By sorting and moving debris curbside, you will have begun to take control of your own situation; your community benefits from a speedier and less costly recovery. Further, the Grantee asserted that the Applicant used the same contract with NRWS following a previous disaster, and FEMA had no issues with the contract or with reimbursing the Applicant for the debris removal service costs incurred in that prior disaster.
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