State of Wisconsin Administrative Plan for the Public Assistance Program

Section 406
PL 100-707
The Robert T. Stafford Disaster Relief and Emergency Assistance Act
WISCONSIN EMERGENCY MANAGEMENT
Department of Military Affairs
2024

Contents

Purpose
Authorities and References
1. State Authorities:
2. Federal Authorities:
State Agency Responsible for Program Administration
Organization and Staffing
Post Declaration Activities
Program Management
1. Request for Public Assistance
2. Role of County Emergency Management Directors
3. Program Compliance, Audits, Reviews, and Closeout
4. Management Costs
5. Administrative Plan
Project Administration
Definitions
Appendices

I. Purpose

This plan establishes the organization, staffing, and administrative procedures for administering the Federal Emergency Management Agency (FEMA) Public Assistance (PA) Program after a Presidential Disaster Declaration. It assumes that pre-disaster declaration activities involving the PA Program, such as Applicant/Subrecipient training and annual updates of specific plans, are covered in Wisconsin Emergency Management (WEM) position descriptions and do not need to be addressed in this plan. This administrative plan to the FEMA PA Program is a supporting document to the Wisconsin Emergency Operations Plan as well as the FEMA-State Agreement made for any Presidential Disaster Declarations.

Federal disaster assistance is made available through FEMA to state, county, and local governmental agencies, tribal organizations, as well as certain eligible private non-profit organizations. FEMA provides a grant to the State/Recipient and authorizes the State/Recipient to pass funding through to eligible Subrecipients. The FEMA-State Agreement establishes the Federal share provided, which will be no less than 75% of the total project costs.

II. Authorities and References

State Authorities:
1. Wisconsin Statutes, Chapter 323, Subchapter III, Disaster Assistance Programs
2. Wisconsin Statutes, Chapter 87.30, Floodplain Zoning
3. Wisconsin Statutes, Chapter 86.34, Disaster Damage Aids Program
4. Wisconsin Code, Chapter 166, Emergency Management
5. Wisconsin Code, Chapter Natural Resources, 116
6. Wisconsin Code, Chapter WEM 7, Disaster Fund Rule
7. Wisconsin Emergency Operations Plan
Federal Authorities:
1. 42 U.S.C. § 5121-5208, Robert T. Stafford Disaster Relief and Emergency Assistance Act, Public Law 93-288, as amended.
2. 44 CFR, Public Assistance Program Regulations:
  1. Part 206 Subpart G, Public Assistance Project Administration
  2. Part 206 Subpart H, Public Assistance Eligibility
  3. Part 206 Subpart I, Public Assistance Insurance Requirements
3. 2 CFR, Office of Management and Budget Guidance
  1. Part 200, Grants and Agreements, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
  2. Part 3002 Subpart F, Adoption of 2 CFR Part 200
4. Executive Order 11988, Floodplain Management
5. Executive Order 11990, Protection of Wetland
6. Executive Order 12612, Federalism
7. Executive Order 12898, Environmental Justice
8. Executive Order 13717, Earthquake Risk Management
9. 16 U.S.C. § 3501 Coastal Barrier Resources Act
10. 54 U.S.C. § 300101 et seq., National Historic Preservation Act
11. 16 U.S.C. § 1531, Endangered Species Act References
12. Public Law 93-234, as amended, Flood Disaster Protection Act of 1973
13. Public Law 103-325, National Flood Insurance Reform Act of 1994
14. Public Assistance Program and Policy Guide (PAPPG)

III. State Agency Responsible for Program Administration

The Governor designated WEM, a division of the Wisconsin Department of Military Affairs (DMA), as the state agency responsible for management and administration of the FEMA PA Program for disasters declared within the State of Wisconsin. Responsible WEM personnel, appointed by the Governor’s Authorized Representative (GAR), shall provide guidance and assistance including, but not limited to, the following:

Submit the Application for Federal Assistance.
Comply with Federal and State program and grant administrative requirements.
Notify potential applicants of the availability of assistance.
Conduct Applicant Briefings.
Request Expedited Funding on behalf of applicants, as applicable.
Assist FEMA in determining work and applicant eligibility.
Process requests for appeals, review cost overruns, submit scope of work change requests, approve time extensions, approve advances and reimbursements.
Make recommendations to FEMA on appeals and other requests.
Monitor awards to ensure compliance through quarterly reports, site inspections, and audits, as required.
Review and certify project completion information.
Determine budget and staffing requirements necessary for proper program management.

IV. Organization and Staffing

The staffing for administration of the FEMA PA Program by WEM must be flexible to match the size and scope of damage caused by any given event. For a Presidential Disaster Declaration, the minimum State positions needed to administer the FEMA PA Program include the following:

Governor’s Authorized Representative (GAR)
State Public Assistance Officer (SPAO)
Deputy State Public Assistance Officer (DSPAO)
State Financial Management Officer (FMO)
State Liaison Officers
State Hazard Mitigation Officer (SHMO)

A. Governor’s Authorized Representative (GAR)

The GAR determines the positions, number of personnel, and the budget required for proper program management, as advised by the SPAO and/or DSPAO. The magnitude and severity of each disaster, and the anticipated number of applicants and projects, will dictate the level of additional WEM staff that will be required to carry out proper program management. The GAR will be the WEM Administrator or the Director of the WEM Bureau of Operations and Planning Support or its equivalent and will:

Act as the intermediary between federal, state, and local parties involving conflicts over PA matters.
Ensure coordination between the PA and Hazard Mitigation Grant Program to ensure actions are taken to identify and implement hazard mitigation activities among applicants.
Determine if the State will implement Expedited Funding for any declared disaster and notify the Federal Coordinating Officer (FCO) of the decision.
Ensure that WEM prepares the FEMA–State Agreement, setting forth the assistance to be rendered and the respective federal and state shares of that assistance.

B. State Public Assistance Officer (SPAO)/Deputy State Public Assistance Officer (DSPAO)

The SPAO/DSPAO accomplishes the necessary program work assigned to the State to administer the FEMA PA Program and Fire Management Assistance Grant Program to eligible Subrecipients. The SPAO/DSPAO is a full-time employee at WEM, who assumes duties related to disaster operations, as outlined in their position description. The SPAO/DSPAO must:

Ensure that all post-disaster meetings, such as applicant briefings, are scheduled and held in a timely fashion.
Prepare and submit a staffing plan for the Joint Field Office (JFO).
Prepare a budget for administration of the FEMA PA Program.
Validate project worksheets and distribute funds upon FEMA review.
Oversee the day-to-day operations of the PA program from disaster request through disaster closeout.

C. State Financial Management Officer (FMO) and Finance Staff

The WEM Fiscal Officer serves as the State FMO, as assisted by WEM finance staff. The State FMO and finance staff will ensure that day-to-day financial operations support completion of work by Subrecipients. The finance staff must:

Work with SPAO/DSPAO to process checks and enter disbursements into the state financial management system.
Maintain financial records of all disbursements to Subrecipients.
Maintain records of salaries, administrative costs, and other eligible expenses for reimbursement.

D. State Liaison Officers

The State Liaison Officers include qualified personnel from applicable state agencies who may assist WEM with technical guidance to applicants, assist with project worksheet formulation, assess damages, and prepare or review project worksheets. WEM draws upon technical experts to serve as Liaison Officers from supporting state agencies such as:

Department of Transportation (DOT)
Department of Natural Resources (DNR)
Department of Administration (DOA)
Public Service Commission (PSC)
Department of Workforce Development (DWD)
Department of Agriculture, Trade, and Consumer Protection (DATCP)

E. State Hazard Mitigation Officer (SHMO) and Mitigation Staff

The SHMO, as supported by WEM mitigation staff, accomplishes the necessary work assigned to the State to administer the Hazard Mitigation Grant Program (HMGP) to eligible applicants. The SHMO performs duties related to disaster operations, as listed in their position description, which include:

Maintains the State Hazard Mitigation Plan. Under the Disaster Mitigation Act of 2000, the State must have at least a standard plan to implement the FEMA PA Program.
Develops the State program for Hazard Mitigation. Has oversight responsibility to ensure state policies are followed in providing funding to subrecipients for mitigation projects eligible under the FEMA PA Program and Section 404 of the Stafford Act. (Ref. Hazard Mitigation Administrative Plan).
Discuss mitigation opportunities through HMGP available to eligible subrecipients and how HMGP differs from mitigation offered through the FEMA PA Program.
Forward applications for PA-related mitigation received from HMGP solicitation.
Work with WEM PA staff to incorporate cost-effective mitigation activities into disaster recovery operations.

F. Other Positions, as directed.

The GAR, FCO, and SPAO/DSPAO will work to fill any additional positions as needs arise and shortfalls are identified.

V. Per Capita Impact Indicator and Project Thresholds

A. Per Capita Impact Indicator and Project Thresholds

Fiscal Year (FFY) 2024

Statewide Indicator: $1.84
Countywide Indicator: $4.60
Small Project Minimum: $3,900
Large Project Threshold: $1,037,000

B. Administrative Requirements

Application for Federal Assistance (SF-424) is submitted in FEMA’s Grants Portal system.
FEMA-State Agreement is updated and signed.
WEM Public Assistance Administrative Plan is updated/amended and submitted to FEMA.

C. Notification of Potential Applicants

The SPAO/DSPAO works with State Public Information Officers as well as Regional and County Emergency Management Directors to conduct outreach efforts to notify potential Subrecipients that assistance is available and the time and date of applicant briefings. Outreach is targeted at identifying eligible applicants for the FEMA PA Program following the presidential declaration of a disaster.

Additionally, the WEM website will be updated following the disaster declaration with instructions outlining:

Eligibility criteria for applicants to the FEMA PA Program.
Eligibility criteria for work categories and costs.
How to apply for the FEMA PA Program.
Deadlines to apply for the FEMA PA Program.
Who to contact at WEM regarding FEMA PA Program questions.

D. Joint Field Office (JFO) Response

Required WEM personnel respond to the JFO, once established by FEMA.

E. State Public Assistance Operations

The SPAO/DSPAO attends the FEMA-State briefing, outlining expectations for PA operations within the state.

F. FEMA Public Assistance Program Delivery Process

FEMA and WEM start working in partnership in administering the FEMA PA Program utilizing the web-based Grants Portal system.

Incident Occurs

Pre-Award Activities

Preliminary Damage Assessment^{A R F}
Declaration Request^R
Declaration Evaluation^F
Administrative Requirements^R

Phase 1: Operational Planning & Application Coordination

Operational Set-up and Coordination^{R F}
Application Briefing^R
Request for Public Assistance^A
Application Eligibility Evaluation^{R F}
Application Impact Survey (+Exploratory Call if PDMG Assigned)^{A R F}
Recovery Scoping Video (Meeting if PDMG assigned)^{A R F}

Phase 2: Impacts & Eligibility

Impact and Damage Identification^A
Initial Eligibility Evaluation^{R F}
Site Inspections for Damage^{A R F}
Impact and Damage Information and Documentation^{A R F}
Develop Detailed Damage Description with Dimensions^{A R F}

Phase 3: Scope & Costing

Scope of Work Development or Validation^{A R F}
Cost Development or Validation^{A R F}
Compliance Reviews^F

Phase 4: Final Reviews

Final Project Reviews^{R F}
Application Signature^A

Phase 5: Obligation & Recovery Transition

Obligate Funds to Recipient^F
Recovery Transition Meetings^{A R F}

Phase 6: Post-Award Monitoring & Amendments

Quarterly Progress Reports^{A R}
Scope Amendments/Time Extensions/Appeals/Audits (as applicable)^{A R F}

Phase 7: Final Reconciliation & Closeout

Project Completion Certification^{A R}
Reconcile and Close Projects^{R F}
Close Applicants^{R F}
Reconcile and Close PA Award^{R F}

Key:

^A = Applicant
^R = Recipient
^F = FEMA

G. Applicant Briefings

Once FEMA approves a designated area for PA, members of the WEM PA Program staff will conduct applicant briefings. The number of potential applicants and the area involved in the disaster will determine the number of briefings held.

The SPAO/DSPAO works with Regional and County Emergency Management Directors to:

Identify eligible applicants for the PA Program.
Schedule briefings for all potential applicants, paying attention to the number and location of briefings, depending on the size and number of potential applicants.
Ensure all potential applicants complete a Request for Public Assistance (RPA) within 30 days of the date of the disaster declaration.

Applicant briefings will outline the FEMA PA Program requirements, eligibility components, rules and regulations, as well as outline hazard mitigation opportunities, environmental and historic preservation conditions, insurance requirements, procurement, and other pertinent information to the disaster event in the declared area.

WEM staff members work with attendees of the applicant briefings to submit a formal Request for Public Assistance (RPA) within 30 days from the date the respective area was designated in the disaster declaration. This deadline will be communicated at the applicant briefing, on the WEM website, and through the Regional and County Emergency Management Directors.

H. Program Delivery Manager (PDMG)

FEMA assigns each eligible applicant a PDMG who will be the primary point of contact during the project formulation and development. The PDMG serves as the primary point of contact for the Applicant, providing customer service and programmatic guidance throughout phases I through V of the FEMA PA Program delivery process.

I. Exploratory Call

The PDMG conducts the Exploratory Call with the Applicant (usually within seven working days of Applicant assignment). The Exploratory Call is an introductory discussion conducted by the PDMG via a conference call. The PDMG reviews the Applicant Profile prior to the Exploratory Call. The objective for the call is to begin developing a relationship with the Applicant and prepare for the Recovery Scoping Meeting as follows:

Understand the Applicant’s incident impacts by gathering information about the type and level of damage and priority needs for assistance;
Ensure the Applicant understands the general requirements for a list of impacts;
Provide key information on documentation, procurement, and EHP requirements; and
Schedule the Recovery Scoping Meeting and define appropriate attendees.

J. Recovery Scoping Meeting (RSM)

The RSM addresses the specific needs of each eligible Applicant. At the RSM, FEMA, the Recipient, and the Applicant review and refine the list of impacts and discuss the following:

PA delivery process;
Details of the Applicant’s impacts from the incident;
Hazard mitigation opportunities;
Eligibility criteria for facilities, work and costs;
Logical grouping of damage;
Procurement requirements;
Insurance reductions and requirements;
EHP compliance requirements;
Documentation requirements;
Interagency Recovery Coordination;
Deadlines; and
Appeal process.

An Applicant should ensure that all local personnel involved in repair or restoration of the damaged facilities and any personnel involved in tracking expenses, project budgets, contracts, and documentation are present at the meetings, not just local elected officials with signatory authority. It is extremely important to have people who will be doing paperwork and overseeing or performing physical work at these meetings, if possible.

In all instances, an Applicant has 60 days from when the RSM is held to report all their damages to the PDMG.

K. Project Worksheet (PW)

Depending on the damages experienced and the resources available to the Applicant, a PW will be created as one of the following types:

Large Projects: FEMA designates any project expected to cost equal to or more than the large project threshold amount as a large project. The large project threshold is an amount of approved project estimated costs adjusted annually to reflect changes in the Consumer Price Index for all Urban Consumers. The large project threshold amount applicable to any project is that amount in effect on the declaration date of the disaster, regardless of when project approval is made or when the work is performed. For large projects that are not capped, FEMA adjusts any estimated costs to the actual incurred amount so that the final approved funding is based on actual costs.
Complex Small Projects: FEMA designates any project expected to cost less than the large project threshold as a small project; however, lower cost does not necessarily mean these projects cannot be complex. Some projects may require an engineering analysis to determine the method of repair. In these cases, FEMA may provide PA funding for engineering and design services.
Standard Small Projects: Many small projects can be completed with minimal assistance. Applicants can provide an estimate to repair the damaged facility and the FEMA Consolidated Resource Center (CRC) will validate and formulate the PW. FEMA accepts an Applicant-submitted cost estimate if the estimate:
- Is prepared by a licensed Professional Engineer or other estimating professional, such as a licensed architect or certified professional cost estimator, who certifies that the estimate was prepared in accordance with industry standards.
- Includes certification that the estimated cost directly corresponds to the repair of the agreed upon damage.
- Is based on unit costs for each component of the scope of work (SOW) and not a lump sum amount.
- Contains a level of detail sufficient for FEMA to validate that all components correspond with the agreed-upon SOW.
- Is based on the current phase of design or construction inclusive of any known costs.
- Includes actual costs for work completed at the time the cost estimate is developed; and
- Is reasonable.
Expedited Projects: FEMA may provide expedited funding for Emergency Work Projects (Category A or B) that meet or exceed the large project threshold. FEMA funds expedited projects at 50 percent of the federal share of the estimated project cost. Requests for expedited projects must be submitted to FEMA within 60 days of the Applicant’s RSM. To support its request, the Applicant must provide enough information for FEMA to validate that the work and costs are eligible. FEMA will work to obligate funding within 90 days of receipt of the request.
Insurance Commitments: Insurance proceeds and/or the requirement to purchase insurance will be documented within PWs by the FEMA Insurance Specialist located at the CRC. Eligible costs shall be reduced by the amount of any insurance proceeds received or anticipated. WEM will review actual insurance proceeds during closeout of a PW. If a Subrecipient has insurance requirements related to a specific PW (e.g. must purchase insurance or provide a statement of loss), they are notified at PW obligation. For insurance purchase requirements, the Subrecipient must submit the Declaration Page of the policy once insurance is purchased, prior to the release of funding for that PW. Once the Declaration Page is received for the PW, it will be recorded in State Porter, for their records and funding will be released. Should a Subrecipient choose not to purchase the required insurance, a letter will be sent to FEMA requesting de-obligation of the PW.

IV. Program Management

A. Request for Public Assistance

In accordance with 44CFR 206.202(e)(1), WEM will complete and submit SF-424 (Application for Federal Assistance) and SF-424D (Assurances for Construction Programs) as soon as possible after the disaster declaration. Once WEM receives approval of the SF-424, FEMA authorizes WEM to draw up sub-award documents and to issue checks to subrecipients.

B. Role of County Emergency Management Directors

County Emergency Management Directors serve as the intermediaries between WEM and Applicants/Subrecipients regarding the FEMA PA Program.

C. Program Compliance, Audits, Reviews, and Closeout

WEM ensures compliance with the “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” (2 CFR Part 200). The State and each Applicant assures that it shall comply with all applicable Federal statutes and regulations, outlined in Appendix C of this document, with respect for which it receives grant funding.

Each Subrecipient expending $750,000 or more in total direct and indirect federal financial assistance per fiscal year, shall have a financial and compliance audit made in accordance with the Single Audit Act of 1996 (P.L. 104-156) and the Federal Office of Management and Budget (OMB) Circular A-133. Audit requirements are the responsibility of the local unit of government (municipal or county). The FMO reviews audits completed for Subrecipients. If adverse findings are reported, the FMO informs the SPAO/DSPAO who ensures that appropriate actions are taken, and these actions are reported to FEMA. The Legislative Audit Bureau (LAB) submits a copy of the audit performed on State operations to the FEMA Inspector General. FEMA may elect to conduct a separate federal audit on the disaster assistance grant, or on any of the subawards, and the State will provide any information necessary for completing such audits.

Prior to closeout of a disaster declaration, WEM PA and/or Fiscal Staff reviews all files internally to ensure that they are complete, correct, and contain all required documentation.

After all grant fund payments have been made, the FMO determines eligible Recipient management costs and administrative allowances and requests reimbursement from FEMA. Upon receipt of these allowances, the SPAO/DSPAO notifies the FEMA Regional Administrator (RA) in writing that WEM has no further claims for the disaster and that WEM closed all FEMA PA Program activities. The FMO will submit a final FEMA Form 20-10 for the total FEMA PA Program disaster grant amount within 90 days following the completion of all required work and administrative actions. FEMA will review the final claim and close the grant.

D. Management Costs

FEMA provides PA funding for administrative costs related to managing the FEMA PA Program and PA projects. Management costs can include any of the following when associated with the PA portion of a major disaster or emergency:

Indirect costs.
Direct administrative costs.
Other administrative expenses associated with a specific project.

Recipient Management Costs
WEM, as the Recipient for the State of Wisconsin, will request management cost funding, in accordance with Stafford Act § 324(a), 42 U.S.C. § 5165b; and 200.412; and DRRA Div. D Sec. 1215.

Recipient Management Cost Funding Request Process:
1. All management costs will be obligated via a Category Z project worksheet and funded at 100% Federal share.
2. FEMA reimburses for management costs based on actual costs incurred up to 7% of the total award amount for the disaster, excluding Subrecipient management costs.
3. If management costs are requested prior to Subrecipient project obligations, FEMA may make an initial Category Z obligation for 7% of the state minimum per capita indicator. Once project obligations exceed the minimum per capita indicator, FEMA may process additional versions to the Category Z project worksheet for 7% of the total project amount obligated on a quarterly basis as needed.
4. After FEMA has received the Recipient’s certification of all projects for a declaration in accordance with 44 CFR § 206.205 and processed all final actual cost project claims, and upon receipt of the Recipient’s final actual management cost claim, FEMA will process the final Category Z obligation or deobligation based on actual reasonable costs up to the maximum 7%.
5. The Recipient may claim management costs incurred up to whichever of the following occurs first:
  1. 180 days after work is completed on the last non-management cost PA project for the declaration; or
  2. 180 days after the latest performance period on a non-management cost PA project for the declaration; or
  3. Two years from the date of an Emergency Declaration; or
  4. Eight years from the date of a Major Disaster Declaration.
6. WEM reports management cost spending in the public assistance and financial quarterly reports.
Subrecipient Administrative Costs
1. FEMA provides contributions for management costs based on actual costs incurred up to 5% of the total award amount.
2. Once a Subrecipient has project obligations, FEMA may provide a Category Z obligation for 5% of the total project amount obligated. FEMA may process additional versions to the Category Z project worksheet for 5% of the Subrecipient’s total project obligations on a quarterly basis as needed. These obligations are subject to Strategic Funds Management. FEMA may require a plan describing how the Subrecipient plans to use the funds.
3. After FEMA has received and processed all a Subrecipient’s final actual cost project claims and upon receipt of the Subrecipient’s final actual management cost claim, FEMA will process the final Category Z obligation or deobligation based on actual reasonable costs up to the maximum 5%.

E. Administrative Plan

The SPAO/DSPAO reviews this administrative plan annually to ensure compliance with applicable laws, implementing regulations, and state policies. This plan will also be updated whenever necessary to reflect new or revised federal regulatory or policy changes; reflect a material change in any state law, organization, policy, or state agency operation; or to improve FEMA PA Program administration. When updated, each will be submitted to FEMA Region V for review and approval. Following a Presidential Disaster Declaration, the SPAO/DSPAO

prepares, publishes, and distributes updates, amendments, or revisions to this administrative plan to meet the then current policy guidance or any program administration changes that have occurred.

VII. Project Administration

A. EM Grants Pro

WEM utilizes emgrants.wi.gov to manage the FEMA Public Assistance Program in Wisconsin. The site is for online management of grants from post-award to closeout.
1. Subrecipients will use it to:
  1. Sign and submit the Assurances, DMA Form 1017, Project Completion Certification Form (P.4 Form)
  2. Submit Time Extension Requests, Scope of Work Change Request, Quarterly Reports
  3. Upload documents and photos
2. The Recipient will use it to:
  1. Track and monitor grant progress
  2. Request payment(s)
  3. Process submitted forms from the Subrecipient

B. Grant Award Documents

Upon award from FEMA, WEM reviews the project and sends the Subrecipient a DMA Form 1017.

DMA Form 1017: State of Wisconsin Disaster Application for Federal Public Assistance for Subrecipients (Appendix B). This form highlights information including:
1. Breakdown of Federal, State, and Local cost shares of each PW. In a typical disaster declaration, the project shares are as follows:
  1. Federal 75%, up to State 12.5%, and Local 12.5%.
  2. If the Federal share is greater than 75%, the State and Subrecipient (Local) will split the remaining non-federal share evenly. For example, if the Federal share is 85%, the State share will be up to 7.5% and Local share will be 7.5%.
2. Total completion percentage, as noted during most recent FEMA site inspection.
3. Approved Period of Performance end date.

C. Additional Damages

The Applicant/Subrecipient has 60 days from the RSM with FEMA to notify WEM and FEMA of any newly discovered damages. FEMA reviews the information and, if justified, requests that inspectors survey the newly discovered damage.

D. Unique Entity Identifier (UEI)

Unique Entity Identifier is a number or other identifier used to identify a specific commercial, nonprofit, or Government entity. UEIs are required in accordance with 2 CFR Part 25. The website to obtain an UEI is www.sam.gov.

E. Payment

Payment will be made in accordance with this administrative plan and the guidelines published in 44 CFR Part 206.205 Payment of claims.

Payment on projects will not occur until project worksheets have been approved by both FEMA and WEM, and the proper forms and supporting documentation have been signed and returned by the Subrecipient.

Project worksheets will be obligated in one of four types depending on the size of the project (small or large) and the percentage complete at the time of FEMA site inspection. This will determine the closeout process and documentation required for closeout. Each project will be obligated separately. Please see below for detailed obligation and closeout information on all four categories:

Small Projects 100% Complete at time of FEMA Site Inspection
1. The Subrecipient will sign the DMA Form 1017 and submit it in the EM Grants Pro system.
2. The Subrecipient will sign the Project Completion Certification Form (P.4. Form) and submit it in the EM Grants Pro system.
3. After both forms have been submitted, the closeout process begins.
Small Projects Not 100% Complete at time of FEMA Site Inspection
1. The Subrecipient will sign the DMA Form 1017 and submit it in the EM Grants Pro system.
2. Quarterly Progress Report (QPR) forms for small projects in this category will be required. FEMA requires that project managers update our office on progress made, problems encountered, and other information every quarter of the Federal Fiscal Year (FFY) for large projects. WEM also requires a QPR for small projects that were not complete at the time of the FEMA site inspection.
  
  Quarterly progress report notification emails will be sent electronically to the Subrecipient e-mail address on file. Notification emails will be sent two weeks prior to the end of the quarter, at the end of the quarter, and one month after the end of the quarter.
  - FFY Quarter 1 (October 1 through December 31)
  - FFY Quarter 2 (January 1 through March 31)
  - FFY Quarter 3 (April 1 through June 30)
  - FFY Quarter 4 (July 1 through September 30)
3. Once the project is 100% complete, the Subrecipient will sign the Project Completion Certification Form (P.4. Form) and submit it in the EM Grants Pro system.
4. If the total actual cost of all a Subrecipient’s small projects combined exceeds the total amount obligated for all the small projects, the Subrecipient may request additional funding. The Subrecipient must request additional funding through the appeal process within 60 days of work completion on its last small project. FEMA refers to this as a Net Small Project Overrun (NSPO) appeal. The appeal must include actual cost documentation for all small projects that FEMA originally funded based on estimated amounts. Small project cost overrun appeals are reviewed by WEM staff and then submitted to FEMA with recommendation. If the overrun appeal is approved, FEMA writes a new project version or project accordingly and obligates it. WEM forwards FEMA’s determination to the Subrecipient with a recommendation for further action, if appropriate.
Small Project Closeout Process
1. Cost Shares
  1. Federal Share – the full federal cost share, not less than 75% of the eligible costs, will be reimbursed upon signature and submission of the DMA Form 1017.
  2. State Share – reimbursement based on actual costs incurred up to 12.5% of the eligible and verified costs.
    - If the Subrecipient spent up to the full federal cost share and not over, they will not get a state share and the project will be closed under the Simplified Closeout Procedure.
2. Closeout Types
  1. Simplified Closeout Procedure:
    - If the Applicant spent up to the federal cost share of the total project amount, the project would be closed, the full federal share would be paid, and no state share would be paid.
    - If the Applicant spent over the federal cost share amount for a project but does not want to go through the Regular Closeout Procedure, they can choose to close their project under the Simplified Closeout Procedure and not claim a state share reimbursement.
  2. Regular Closeout Procedure:
    - If the Applicant spent over the federal cost share for a project and would like to claim a state share reimbursement.
3. Documentation Requirements
  1. Simplified Closeout:
    - Pictures of the completed work for every site that was indicated as Work To Be Completed (WTBC) in the project worksheet scope of work, labeled appropriately or properly identified in the photo.
    - Timesheets, invoices, etc. that show some costs were incurred.
    - Proof of payment to show that employees, invoices, or contractors, etc. were paid.
  2. Regular Closeout
    - Pictures of the completed work for every site that was indicated as Work To Be Completed (WTBC) in the project worksheet scope of work, labeled appropriately or properly identified in the photo.
    - Cost summary for all incurred costs for the project.
    - Force Account Labor – cost summary sheet or timesheets/worklogs/etc.Force Account Equipment:
      1. Worklog, equipment log, etc. showing the equipment type used, location, date, hours, and operator.
      2. WisDOT Equipment Rates will be used unless the Applicant adopted their own rates prior to the disaster event. FEMA Equipment Rates will be used when applicable.
    - Materials – invoices, receipts, and summary showing material type, amount used, location, and cost.
    - Contractors:
      1. Itemized invoice with costs. Lump sum invoices will not be accepted.
      2. We do not need bidding, contracts, change orders, etc. but Applicant is required to retain them.
    - Proof of payment for all WTBC costs.
    - We do not need permits, but the Applicant is required to retain them if they were required for the project.
4. Closeout Procedure
  1. WEM PA Specialists will ensure the following:
    - Simplified Closeout:
      1. All WTBC was completed according to the approved SOW, including any mitigation measures.
      2. Pictures for WTBC have been submitted and labeled.
      3. Supporting documentation showing that costs were incurred along with proof of payment for these costs.
    - Regular Closeout:
      1. All WTBC was completed according to the approved SOW, including any mitigation measures.
      2. Pictures for WTBC have been submitted and labeled.
      3. Cost summary for all WTBC costs.
      4. Supporting documentation for all WTBC costs that have been incurred.
      5. Proof of payment for all WTBC costs.
    - Once all documentation has been reviewed, WEM PA Specialist will advance the project closeout forward in the EM Grants Pro system.
5. Payment
  1. Simplified Closeout
    - Once the proper forms are signed and submitted (DMA Form1017 and P.4 Form), WEM can request reimbursement from the WEM Finance Section for that project.
    - When the WEM PA Specialist receives the check from the WEM Finance Section, the check will be mailed to the Subrecipient.
    - Once the check is mailed and received by the Subrecipient, the project is considered closed by WEM.
  2. Regular Closeout
    - WEM will reimburse the Federal share of the project worksheet eligible amount once the DMA Form 1017 has been signed and submitted.
    - The WEM PA Specialist will require the Subrecipient to provide supporting documentation proving that the work was completed as stated above. WEM is not checking for cost overruns or underruns, rather we are ensuring that the work was properly completed according to the approved project scope of work. If the work was not done in accordance with the approved project scope of work, the Subrecipient will jeopardize the funding of the project. FEMA has the ability to de-obligate all funds. It is important that the Subrecipient review and ensure that they are following the approved project scope of work. If not, the Subrecipient should notify their WEM PA Specialist BEFORE they begin doing work outside of the approved project scope of work.
    - WEM will reimburse the state share (if applicable) of the project worksheet eligible amount once the P.4 Form has been signed and submitted, and the conditions outlined previously are met.
Large Projects 100% Complete at time of FEMA Site Inspection
1. The Subrecipient will sign the DMA Form 1017 and submit it in the EM Grants Pro system.
2. The Subrecipient will sign the Project Completion Certification Form (P.4. Form) and submit it in the EM Grants Pro system.
3. After both forms have been submitted, the closeout process begins.
4. Closeout:
  1. Once the proper forms are signed and submitted (DMA Form1017 and P.4 Form), WEM can request reimbursement from the WEM Finance Section for that project.
  2. When the WEM PA Specialist receives the check from the WEM Finance Section, the check will be mailed to the Subrecipient.
  3. Once the check is mailed and received by the Subrecipient, the project is considered closed by WEM.
Large Projects Not 100% Complete at time of FEMA Site Inspection
1. The Subrecipient will sign the DMA Form 1017 and submit it in the EM Grants Pro system.
2. Quarterly Progress Report form submissions are required by both FEMA and WEM for large projects that were not completed at the time of FEMA site inspection. FEMA requires that project managers update our office on progress made, problems encountered, and other information every quarter of the Federal Fiscal Year (FFY) for large projects.
  
  Quarterly progress report notification emails will be sent electronically to the Subrecipient e-mail address on file. Notification emails will be sent two weeks prior to the end of the quarter, at the end of the quarter, and one month after the end of the quarter.
  - FFY Quarter 1 (October 1 through December 31)
  - FFY Quarter 2 (January 1 through March 31)
  - FFY Quarter 3 (April 1 through June 30)
  - FFY Quarter 4 (July 1 through September 30)
3. Once the project is 100% complete, the Subrecipient will sign the Project Completion Certification Form (P.4. Form) and submit it in the EM Grants Pro system.
4. Closeouts:
  1. Once WEM has received the proper forms, the WEM PA Specialist will request all supporting documentation related to the project. See the Large Project Closeout Documentation section for a detailed list of what documentation will be required.
  2. The WEM PA Specialist will audit the work that was done to ensure it is within the approved project scope of work. Invoices and proof of payments will be audited and tracked in a Large Project Documentation Summary that will be submitted to FEMA with all the backup supporting documentation for each cost.
  3. Once the WEM PA Specialist is satisfied with the audit, the documentation will be sent to FEMA with a letter requesting closeout. FEMA will then audit the files as well to ensure the work done was within the approved project scope of work.
    - If the work was within scope, they will approve the project based on actual costs.
    - If there is documentation missing or clarification needed, FEMA will contact WEM and/or the Subrecipient with a request for information (RFI).
  4. If the project is approved, and a new project version is obligated, the Subrecipient will have to sign and submit updated DMA Form 1017 and P.4 Forms that have the new amounts based on actual costs. Once WEM receives the updated signed forms, the Federal and State shares will be reimbursed and the project closed.
Large Project Documentation Requirements for Payment and Closeout
1. Summary of Expenditures –a spreadsheet or coversheet that summarizes the expenses being claimed for a project.
  1. Force Account Labor
    - Labor Costs and Records
    - Fringe Benefits
    - Personnel Pay Policies
  2. Force Account Equipment/Supplies
    - Salvage Value
    - Equipment Rates
  3. Force Account Materials
  4. Contracts
    - Procurement Procedures
    - Invoices/Canceled Checks
    - Price Analysis to determine reasonableness of cost.
    - Scope of Work
    - Type of Contract:
      - Related Correspondence
      - Bid Documents – Engineering/Architectural and Construction Work must be bid out.
      - Contracts – Copy of any Signed Contracts
      - Change Orders
2. Applicable codes and standards
3. Documentation of any required environmental compliance
4. Other backup documentation as needed:
  1. Invoices, Time Sheets, Work Orders – proof of payment for each
  2. Photos
  3. Issues identified in the Comment Field of the PW
    - Documentation Requirements
    - Insurance Requirements
    - Special Considerations
    - Environmental Concerns
    - Insurance Issues
    - Compliance with Historic Preservation Requirements
  4. Time Extensions – any approved time extensions from WEM or FEMA.
  5. Work Completion Date – day physical work was completed for the project.

F. Improved Project Requests

A Subrecipient requests an improved project if they desire to make improvements to a damaged facility that are not required by eligible codes or standards. A project that restores the pre-disaster function of a facility and incorporates improvements or changes to the pre-disaster design is an improved project. The Subrecipient must fill out and submit a Scope of Work Change Request form to obtain State and FEMA approval prior to the start of construction. If approved, federal funding for improved projects will be limited to the lesser of original federal share of the approved estimate of eligible costs or the federal share of the actual costs of completing the improved project.

G. Alternate Project Requests

A Subrecipient requests an alternate project when they determine that the public welfare would not be best served by restoring a damaged public facility or the function of that facility. The Subrecipient must fill out and submit a Scope of Work Change Request form to obtain State and

FEMA approval prior to the start of construction. The alternate project option may be exercised only on permanent restorative work. If approved, federal funding for alternate projects will be limited to the lesser of original federal share of the approved estimate of eligible costs or the federal share of the actual cost of completing the alternate project. Funds contributed for alternate projects may be used to repair or expand other selected public facilities, to construct new facilities, or to fund hazard mitigation measures. These funds may not be used to pay the non-Federal share of any project, nor for any operating expense.

H. Time Extensions

The approved period of performance for each awarded project should be tracked by the Subrecipient. If work cannot be completed within the approved period of performance, the Subrecipient must request a time extension for each separate project by filling out and submitting a Time Extension Request form. WEM will review the time extension request. Requests for time extensions beyond the State’s approval authority will be submitted to FEMA Region V for consideration. If a time extension is approved, WEM will notify the Subrecipient of the revised period of performance, as well as notify FEMA if approved under State authority by submitting a Change Request in FEMA’s Emergency Management Mission Integrated Environment (EMMIE) system and uploading the necessary documentation.

I. Scope of Work Changes

The Subrecipient may request a change in the scope of work of their project. The Subrecipient must fill out and submit a Scope of Work Change Request form to obtain State and FEMA approval prior to the start of construction. The SPAO/DSPAO evaluates the request and submits a request and recommendation to FEMA Region V for consideration.

J. Recoupment of Funds

If repayment of any portion of Federal and/or State share is necessary for any reason, the repayment to the State must be made within 30 days of notification. A Subrecipient will be notified via letter of the reasoning for the recoupment of funds.

K. Appeals

An Applicant/Subrecipient may appeal any determination previously made by FEMA or the State related to Federal assistance. The Applicant/Subrecipient must submit a written appeal to the Recipient within 60 days of receiving FEMA’s written notification of its determination (FEMA’s eligibility determination or first appeal decision). The Recipient must forward the appeal with its written recommendation to FEMA within 60 days of its receipt of the appeal. If either the Applicant/Subrecipient or Recipient does not meet the respective 60-day deadlines, FEMA will deny the appeal as untimely.

If the total actual cost of all a Subrecipient’s small projects combined exceeds the total amount obligated for all the small projects, the Subrecipient may request additional funding.

The Subrecipient must request additional funding through the appeal process within 60 days of work completion on its last small project. FEMA refers to this as a Net Small Project Overrun (NSPO) appeal. The appeal must include actual cost documentation for all small projects that FEMA originally funded based on estimated amounts.

L. Disaster Period of Performance and Liquidation Extensions

The prime award POP begins on the first day of the incident period and initially extends four years from the declaration date. Project extensions cannot exceed the Recipient’s prime award POP. Therefore, the Recipient must request FEMA approval for an extension to the prime award POP if it anticipates project work to extend beyond the end of the prime award POP.

M. Disaster/PA Grant Program Closeout

The Recipient must submit its final FFR (SF-425) with a written request to close the PA award. FEMA and the Recipient certify that all work was completed, all eligible costs have been reimbursed, and financially reconciled. The PA program is programmatically closed when FEMA ensures that all PA projects awarded for the incident meet statutory and regulatory requirements. The Recipient must liquidate all obligations within 90 days of the end of the prime award period of performance, or request an extension from FEMA.

N. Financial Management

To start the FEMA Public Assistance Program Account, immediately following a major disaster declaration, the GAR provides the FMO with copies of the Governor’s Request for Presidential Declaration, the President’s Declaration of Major Disaster, the FEMA-State Agreement, and the Grant Summaries. The FMO establishes separate accounts for Federal and State disaster funds. WEM accounts for these funds through pay-in and pay-out vouchers prepared and maintained by the FMO and DMA. Damage assessment information determines an estimate of the amount of Public Assistance Program funds needed. After project worksheet formulation and validation, funds are obligated based on approved grants.
The Federal share of a small project is distributed after the Subrecipient has signed the DMA Form 1017 and the State share is distributed after the project is complete and all closeout requirements have been met. Large project funds are distributed on a reimbursement basis only. Exceptions for advance payments will only be made on a case-by-case basis. In these cases, a Subrecipient needs to justify the amount being paid in advance. The Subrecipient must notify WEM within one week of receiving a check that funds were deposited, and work paid for by providing proof of payment.
Disasters will incorporate the Single Obligation drawdown process:
1. Payment Management System receives single obligations in its system, making grant dollars available for drawdown.
2. The SPAO/DSPAO submits written authorization to the FMO to pay the Federal and/or State share(s).
3. The FMO requests a drawdown only if there is an actual documented need for funds.
4. The FMO draws funds electronically in one of three ways:
  1. Option 1: State FMO inputs drawdown amounts into the Payment Management System (PMS) by subaccount per project.
  2. Option 2: State FMO downloads a spreadsheet populated with all subaccounts and inputs specific drawdown information for each subaccount/project.
  3. Option 3: FMO creates their own spreadsheet for specific subaccount/project.
5. The FMO uploads a properly formatted spreadsheet to the PMS.
6. WEM receives the funds and disburses to the Subrecipient by project.
In most cases, checks will be mailed directly to the Subrecipient. If a Subrecipient reports a check as lost, WEM will seek action to recover them after ten working days have elapsed from the mailing date. If the check is not recovered at that time, the FMO requests in writing that the State Treasury stop payment on the check. If the check is not cashed, the Treasury sends the FMO a State Treasury Stop-Payment Affidavit. The FMO forwards the affidavit with the formal letter to the Subrecipient. The affidavit must be signed and returned by the Subrecipient. On receipt of the completed affidavit, the State Treasury will reissue the check.
Every effort will be made to avoid instances where a Subrecipient receives more funds than can be supported by inspection, review, or audit. The requirement that all disbursements be thoroughly documented prior to disbursement of funds is a fiscal control and should limit, if not eliminate, excess advanced funds. If an overpayment is discovered prior to final payment and closeout, the SPAO/DSPAO deducts the overpayment from funds still due to the Subrecipient, and the remaining balance will be paid. If the overpayment exceeds the amount of the final payment, the SPAO/DSPAO will withhold all funds and request the balance from the Subrecipient. The SPAO/DSPAO returns the withheld funds to FEMA by making an offsetting entry on PMS with the FMO. If the Subrecipient refuses to repay the overpayment, or any part of it, the SPAO/DSPAO will refer the case to the DMA Legal Counsel for initiation of collection efforts. The SPAO/DSPAO will keep FEMA informed of the status of such cases.

VIII. Definitions

Alternate Project – A Subrecipient may determine that the public welfare is not best served by restoring the function of a damaged facility. When this occurs, the Subrecipient may apply PA funding toward a different facility (or facilities). The Alternate Project must be a permanent project that benefits the public, serving the same general area that was being served by the original facility.

Applicant – A state, county, local, Indian Tribal government, other legal entity, or certain private non-profit organizations that receive a subgrant award and which is accountable to the Recipient for the use of the funds provided. Also referred to as the Subrecipient.

Consolidated Resources Center (CRC) – Permanent FEMA offices where subject matter experts and specialized resources provide support for all PA operations. CRC responsibilities include project scoping, costing, validation, and compliance reviews.

Designated Area – Any emergency or major disaster-affected portion of a state which has been determined eligible for federal disaster assistance.

Duplication of Benefits – Funding received from multiple sources for the same item of work.

Emergency Protective Measures – Any action taken by a community before, during, or after a disaster to save lives, protect public health and safety, and prevent damage to improved public and private property.

Emergency Work – Work which must be done before, during, and immediately after a disaster event to save lives and to protect improved property and public health and safety or to avert or lessen the threat of a major disaster. Under the Public Assistance Program, Category A (Debris Removal) and Category B (Emergency Protective Measures) are referred to as Emergency Work.

Federal Agency – Any department, independent establishment, government cooperation, or other agency of the executive branch of the Federal government, including FEMA.

Federal Coordinating Officer (FCO) – The person appointed by the FEMA Administrator, or in his absence, the Deputy Administrator, to coordinate Federal assistance in an emergency or a major disaster.

Federal Emergency Management Agency (FEMA) – The Federal agency responsible for coordinating disaster recovery efforts.

Federal Share – The portion of the total project costs paid by Federal funds. Shall be no less than 75% of the total project costs.

FEMA-State Agreement – A formal legal document between FEMA and the affected State stating the understandings, commitments, terms, and conditions for assistance resulting from a Federal disaster or emergency declared by the President. The FEMA Regional Administer and the Governor sign the document.

Fire Management Assistance Grant (FMAG) Program – Program established in 2001 under the Disaster Mitigation Act of 2000, replacing the previous Fire Suppression Grant Program. This new program expands the range of eligible activities from the suppression of forest and grassland fires that threaten to cause major disaster to the “mitigation, management, and control” of such fires. The program also allows FEMA to provide funding for eligible local government activities and for emergency-related services, such as evacuations, sheltering, and search and rescue operations.

Governor’s Authorized Representative (GAR) – The person designated by the Governor to execute on behalf of the State, all necessary documents for disaster assistance. In Wisconsin, the responsibilities of the GAR and the State Coordinating Officer (SCO) are generally assigned to the Administrator of Wisconsin Emergency Management (WEM) or the Director of the WEM Bureau of Operations and Planning Support.

Hazard Mitigation – Any sustained action taken to reduce or eliminate long-term risk to people and property from natural hazards and their effects.

Immediate Needs Funding (INF) – An advance of grant funds by FEMA, not to exceed 50% of the Preliminary Damage Assessment estimate, to assist with payment of emergency work within the first 60 days after a declared disaster occurs.

Improved Project – The use of funding to repair/rebuild a damaged facility beyond the scope of the Project Worksheet (PW) but still restore its pre-disaster function and at least the equivalent capacity.

Joint Field Office (JFO) – A temporary facility established in a Presidentially declared disaster area to serve as the field headquarters for FEMA, other Federal and State recovery personnel, and as the focal point for disaster operation, direction, coordination, and information.

Large Project – Approved projects with total costs equal to or greater than the large project threshold amount. The large project threshold is an amount of approved project estimated costs adjusted annually to reflect changes in the Consumer Price Index for all Urban Consumers. The large project threshold amount applicable to any project is that amount in effect on the declaration date of the disaster, regardless of when project approval is made or when the work is performed.

Permanent Work – Restorative work performed on damaged facilities through repairs or replacement, to pre-disaster design and current applicable standards. Under the FEMA Public Assistance Program, Category C (Roads and Bridges), Category D (Water Control Facilities), Category E (Buildings and Equipment, Category F (Utilities), and Category G (Parks, Recreational Facilities, and Other Items), are referred to as Permanent Work.

Pre-disaster Design – The size or capacity of a facility as originally designed and constructed or subsequently modified by changes or additions to the original design. It does not mean the capacity at which the facility was being used at the time the major disaster occurred if different from the most recent designed capacity.

Pre-disaster Function – The function the facility was performing immediately prior to the disaster.

Private Non-Profit (PNP) Organization – Any nongovernmental agency or entity that currently has an effective ruling letter from the U.S. Internal Revenue Service, granting tax exemption under Sections 501(c), (d), or (e) of the Internal Revenue Code, or satisfactory evidence from the State that the nonrevenue producing organization or entity is a nonprofit one organized or doing business under State law.

Preliminary Damage Assessment (PDA) – A mechanism used to determine the impact and magnitude of damage and the resulting unmet needs of individuals, businesses, the public sector, and the community. Information collected is used by the State as a basis for the Governor’s request, and by FEMA to document the recommendation made to the President in response to the Governor’s request.

Project – A logical grouping of work required as a result of the declared major disaster or emergency.

Project Worksheet (FEMA Form 90-91) – Form used to document the scope of work and cost estimate for a project.

Program Delivery Manager (PDMG) – A FEMA appointed, single point of contact for a Subrecipient for public assistance guidance during a declared disaster during the project development process to award.

Public Facility – Any of the following facilities owned and/or maintained by a state or local government: any flood control, navigation, irrigation, reclamation, public power, sewage treatment and collection, water supply and distribution, watershed development, or airport facility; any non-Federal aid, street, road, or highway; and any other public building, structure, or system, including those used for educational, recreational, or cultural purposes; or any park.

Recipient – The government to which a grant is awarded, and which is accountable for the use of the funds provided. The Recipient is the entire legal entity even if only a particular component of the entity is designated in the grant award document. For the purposes of this plan and its implementation, the State is the Recipient.

Regional Administrator (RA) – An administrator of a FEMA regional office or his/her designated representative.

Small Project – A project for which the final obligated (Federal and non-Federal) amount is less than the annually adjusted cost threshold for small project grants.

Special Considerations – Issues that involve insurance, floodplain management, hazard mitigation, historic preservation, and environmental reviews as they relate to FEMA Public Assistance Program funding.

State Coordinating Officer (SCO) – The person designated by the Governor to act in cooperation with the Federal Coordinating Officer (FCO) to administer disaster recovery efforts. In Wisconsin, the responsibilities of the SCO are generally assigned to the Administrator of Wisconsin Emergency Management or the Director of the WEM Bureau of Operations and Planning Support.

Subrecipient – A non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program. It does not include an individual that is a beneficiary of such program. A Subrecipient may also be a Recipient of other Federal awards directly from a Federal awarding agency. Also referred to as the Applicant.

Volunteer Labor Rate – Volunteer labor is reimbursed at the rate which is set by the Independent Sector which provides a national hourly rate for volunteer time every year.

Work Completion Date – The date the Subrecipient completes all physical work associated with the approved SOW including meeting all compliance requirements. It does not include invoice payments, warranty periods, or grant management activities (e.g., compiling and submitting documentation, financial reconciliation, requesting payment, etc.).

IX. Appendices

APPENDIX A – Applicant Eligibility

Applicant Eligibility: the following entities are eligible to apply for assistance under the FEMA Public Assistance Program:

State, county, and local government agencies.
Indian tribes or authorized tribal organizations.
Private, non-profit organizations or institutions owned or operated by a private, non-profit facility as defined by 44 CFR Part 206.221 (e).
1. Private, non-profit facilities: in determining eligibility, potential private, non-profit applicants will need to complete a PNP Questionnaire (Attachment C) with their Request for Public Assistance (RPA) and submit it to the SPAO for review and determination of status. The applicant is also required to provide an effective ruling letter from the US Internal Revenue Service granting tax exemption under Section 501(c), (d), or (e) of the Internal Revenue Code of 1954 or acceptance from the state for recognition as a tax exempt not for profit organization.
2. Facilities serving a rural community or unincorporated town or village. To be eligible for assistance, a facility not owned by an eligible applicant, as defined in 44 CFR Part 206.222, must be owned by a private, non-profit organization and provide an essential governmental service to the general public. Applications for these facilities must be submitted through the State or a political subdivision of the State.
3. Examples of eligible private non-profit organizations include but are not limited to educational institutions, museums, public libraries, community centers, and emergency response agencies.

Eligible private non-profit organizations that are not providing a critical function and have Permanent Work damages, must first apply to the Small Business Administration (SBA) for low-interest loans when available before being considered for public assistance grants. Eligible private non-profit organizations do not have to apply to the SBA for assistance with Emergency Work costs.

Wisconsin Emergency Management