Nonprofit Security Grant Program Webinar 2019


Welcome to the Nonprofit Security Grant Program EHP training for this afternoon. Thank you for joining us. This is Cembrye Ross, the Grants Program Manager for the Nonprofit Security Grant Program, along with Charles Madden, the Grants Management Bureau Chief, and Tristan Reed, the Grants Management Officer— My supervisors with whom I consult if there are issues that arise regarding your project. Today, we will focus on environmental and historic preservation. Please make sure that you have the following materials for this training, a PowerPoint presentation, EHP screening form, a training screening form, and ACH and W-9 forms. Please mute your phones, and during the course of this training, you will be able to text if you had any question that’s presented. As Cembrye indicated, we are enabling most of the participants to perform chat functionality to the host. So please, if you do have questions you’d like to have answered, just cue them up into chat. And then, as we cover each section, we’ll periodically pause to address any of the questions that come up that are relevant to that content. If you do have your phone’s ability to mute them, please do so. Otherwise, please try to minimize any background noise. We’re trying to mute everybody’s lines, but every now and then, one sneaks through. As you see on the first page of our PowerPoint presentation, today’s agenda is just a brief list of five topics. Subawards; quarterly status reports; reimbursement requests and payment; project file; and as we mentioned earlier, the EHP review and approval process. In reference to subawards, the outstanding matter might be whether you, as the subrecipient, have uploaded signed subaward letters in SAA.SP. Everyone has been given their subaward package, and at this point, the only thing that might be done or needed for completion is you signing the subaward letter and uploading it in SAA.SP. On the second page of our presentation, we’ve given you a brief timeline–the earliest possible timeline that certain materials might be submitted by subrecipients. It is our hope as the SAA to complete all PMP reviews by next Friday. We had provided you with W-9 and ACH enrollment forms to complete, which are necessary to set you up in our financial system. We would like these documents to be returned as soon as possible, but no later than the 31st of December. EHP submissions might begin in the month of December. We think the 31st of December might be the earliest date for complete submissions. Quarterly status reports will be due January 10th, and we are anticipating the beginning of FEMA approvals between January and March 2020. Thereafter, the earliest date that project equipment installations may begin would be April 2020, and the submission of reimbursement requests June 2020. What Cembrye has laid out there is certainly regarding the EHP—anything beyond January is more of a notional timeline and just to kind of set expectations. If any of this material that is submitted—especially the EHP material—if any of that comes in early, and for some reason FEMA is able to approve it very early, and the work is done earlier, that’s fine. Really high performers may be able to get that done. Or if things just take longer, if it takes longer to scope out all the materials, if it takes longer for FEMA to approve, it takes longer for the work to get done, you do have the full period performance to accomplish that. So I think this was more just kind of to set the expectations if folks thought that they were going to complete their entire project before the end of the year, it’s probably very unlikely. I think the key one is we do want to make sure we have both your award letters signed and returned in SharePoint, as soon as possible. Really, no work should be done before them. We do want to get the project management plans all completed and approved, so any lingering questions there should be resolved as soon as possible. And then jumping right into getting your payment materials submitted so you can get set up for payment and getting the EHP materials in. If we can finish the year with everybody approved, signed—approved project plan, signed documents, EHP submissions done and payment materials for setup and payment done—by the end of the year, that is going to be so far ahead of schedule. We’ll be in a great spot. I imagine we’ll just be following up next year with everybody who doesn’t have everything in place so we can narrow down our focus to get those in. And just one note regarding the PMP status. Please remember to check your junk and spam files for SAA.SP notifications. There are many PMPs that are in need of revision. Be sure to read the bottom of your PMP or the SAA notifications for what revisions are necessary and suggestions for language that might need to be removed or other changes that might need to be made for your PMP to be acceptable. On the next page—page three— a definite deadline for all subrecipients is the completion of the quarterly status report. You will have to submit quarterly status reports four times a year. January 10th will be the time for the first submission, and in that quarterly status report, which will be completed online through the SAA.SP system, you’ll report on your activity for what did you engage in, what was accomplish from October 1st to December 31st 2019. The whole purpose of the report is to let us know your progress towards the completion of your project. You’ll also include current spending that is projected for the next quarter and any risks that have been identified, which are hindering your progress— whether you have had problems submitting your EHP screening material, or any other issue that has arisen. We will send an email with instructions on how to submit your quarterly status reports, probably in the latter part of December or the very early part of January. And one note on quarterly status reports, the quarterly status report essentially is drawn from your approved project management plan. That’s why we really want to make sure everybody has an approved project management plan in the system so that when December rolls around, and the quarterly status report forms start being generated, it’ll be pulling all that information from your most recent approved project management plan, and you’re reporting on an accurate project management plan. Many people have asked us about what will be necessary for reimbursement. You have been provided with a W-9 and an ACH enrollment form for completion. The W-9 is an absolute necessity and make sure that it is signed and dated by whoever’s completing it. The ACH payment is an option—automated clearing house payment. You will complete the enrollment form if that is the means of payment that you would prefer. However, you would prefer to be paid by checks, send an email to me directly to let me know that. Make sure when you complete the ACH enrollment form, that the second portion of it is completed by your bank official, and it also must be properly signed. A couple of notes on getting set up to receive payment. First, is that for those individuals who are receiving payments or will be receiving payments for the first time, and have not previously received an award from DC HSEMA, and haven’t previously done business with the District of Columbia government, when your payment account essentially is set up by the CFO and the DC Treasury, you may receive an email from them indicating that your payment information has been completed or updated. That is a new practice the DC Treasury is doing is that they are notifying people when their payment information is either initially created or changed. We’re hoping to get all that done fairly shortly. Everybody will get those notices in a short period of time. You’ll remember that we’ve talked about this. We’ll set that up as soon as you send it to us. And also, even if you have currently a W-9 on file, if it’s a subaward from 2018, there probably might not be a need to be submitted W-9 again. But if your project or W-9 might have been submitted before 2018, there was a new form that was mandated for our use by the Office of the Chief Financial Officer. So the better part of that would be to submit a new W-9 if you have not submitted one within the last year. Same for the ACH enrollment form. The next thing in terms of documentation necessary for reimbursement— your reimbursements will consist of two things that are sent to me: invoices and proof of payment. An invoice should indicate the vendor that performed work for you, that installed equipment, or other labor associated with the installation of equipment, the amount of the work done, the date of purchase; and it should be thorough and itemized so that we can tell what was done by your vendor. Proof of payment should be either a canceled check or an itemized credit card statement showing purchase, or payment of the invoice. The amount should be clear so that we can match up to your project management plan. And this is, I think, a very important point that Cembrye made about clear documentation because we would hope to avoid the situation in which you’re sending several different amounts in for payment, and we can’t figure out how you arrived at the total you’re requesting, or even what total you’re actually asking to be paid for. Especially if you’re submitting multiple invoices with different proofs of payment, or if it’s a split invoice where some items were charged to nonprofit grant, and some items you’re paying for out of other funding sources, the more clearly, you can organize that and make it easy to determine what you’re requesting payment for, and how you derive that total, and how that corresponds to the proofs of payment you’re providing, that will really make our lives a lot easier and make it a much quicker process the payment. Another thing to consider is that we want this, the final product, to be audit-proof. While you might be familiar with your project and what you did, and we might be familiar with what your project was all about and how those costs are allowable, we may have to present this payment material to an external auditor down the road who isn’t familiar with the program, or you, or us. And so the easier it is to explain to a complete stranger how this makes sense, the easier it’ll be to ensure that you have a well-documented package for reimbursement. Again, just a reminder at no juncture do you engage in any kind of expenditure before you have EHP approval—not even deposits to vendors for or based on proposals. As you know, the SAA has a repository for documents—our SAA.SP system— but it is incumbent upon all subrecipients to maintain their own project files, be they electronic, or binders, or some other means of retaining the documents that are set forth. Your project file should consist of your subaward letters, your terms and conditions, any guidance for your grant, adjustment notices, EHP documentation and approval letter, all correspondence that is relevant that you have with our agency, the Subrecipient Handbook, your project management plan, your contracts, purchase orders, invoices, proof of payment, any reimbursement that was sent to me, QSR, and proofs of work completed. And this is a good point that while the SharePoint system is there for our use and for your use and we do hope that it is there to support you, there is an expectation in the way the federal government lays out the responsibilities of the awarding agency and the receiving entity, that the receiving entity—that would be your organization—does maintain its own files relating to the grant. So please do a set up early on, if you haven’t done it already, a file organization structure on your side, where you can keep all the materials that are relevant to this project. Hopefully then, the things that you’re giving us and SharePoint are also reflected on your side. All the documents that are electronically in the SAA.SP system, you can easily PDF and make paper copies for any paper files that you retain, or any electronic files that you have in your organization. The focus of this presentation, as we mentioned, is Environmental and Historic Preservation. Basically, when you receive the terms and conditions and also the notice of funding opportunity, one thing that subrecipients must do to be compliant to receive grant funding, is to make sure that they comply with all the terms of environmental and historic preservation. The concern of EHP is whether projects will have an impact on the integrity of historic buildings or the environment, particularly in this case, ground disturbance. Since the Nonprofit Security Grant Program is primarily at its core a physical facility target- hardening program, the expectation on our side, and on FEMA’s side, is that almost every Nonprofit Security Grant Program will have elements in it that will require this EHP review—be it installation of fences, replacement of cameras, running electrical power cords to a camera, replacing windows, doors, locks—all that kind of stuff is the kind of thing that would require EHP, and it is the most common type of activity under NSGP. There are some narrow areas that are allowable under NSGP that would not require EHP. If you do have any of those activities going on in your project— be it training, or a planning activity, or the newly approved contracted security personnel for the facility— some of those areas would not require EHP, but it would really be important to carve those out and clearly identify them in your project plan to explain how parts A, B, and C of your project are exempt from EHP approval, whereas parts D and f require EHP approval. So the things that tend to require EHP approval are physical security enhancement both internally and externally. So that would be things such as doors, lights, fences, walls, bollards, alarm systems, access control systems, video surveillance systems, anything that must be affixed to a wall, or in any other way attached to an interior portion of your facility or exterior portion. If you have lights and light poles that are going to be installed in the perimeter of your property, because that would involve ground disturbance, it must be receive EHP approval. You’ve been given an EHP screening form to complete. For future reference, please use the EHP screening form that we provided and attached to this invitation, because the keystroke limitations do not exist. You can type to your full desire whatever text is necessary to adequately describe your project. For the purposes of this training, we are going to refer to a training EHP screening form that has been completed. The first thing we’ll touch on, right before we get into the form itself, is the process just to understand what steps it goes through. The first step is that you would complete the EHP screening form describing the work that you’re doing in your project, answering the questions in the form—and we’ll walk through the form in great detail later—and attaching all the necessary documentation and then providing it to us. You would not provide any information directly to FEMA. They want us to collect those forms and the materials, and submit them to FEMA ourselves. So send it to us. The best way to get it to us is, if you complete everything, put it into either a single file or a manageable number of files, and attach it in the attachment section in the SharePoint system. And then, that will give us a notification that something has been attached and we’ll receive it. And then once we’ve reviewed it, determined that it’s complete, we’ll send it to FEMA. When we send it to FEMA Grants Program Directorate, it starts off at their headquarters branch. They do an initial type of review. Some projects are approved at that level, they’re approved at the initial review level, because they have no potential impact on the environment, no potential impact on historic properties, and there’s basically nothing controversial about them, and they get a relatively quick approval, hopefully. If there are any additional questions that come up, for instance, if your property is in a historic district, or your facility itself is over 45 years old, or is on the historic register list, or if the ground disturbance that you’re performing is in a flood plain, or something else that has the potential to impact any of the variety of different federal regulations, then the initial reviewer on FEMA’s side will kick it up to either another federal agency to review, or up to the FEMA Region III office, which is in Philadelphia. FEMA breaks up the country into various regions, and the things that need additional review will be done at the regional level. That FEMA regional officer may then consult with other federal agencies, or may go right back down to the State Historic Preservation Office in DC, Maryland or Virginia, depending on where your facility is located. And then, that review will happen there. You might get more questions back. The questions will come from FEMA to us; from us to you; and then we’ll pass the responses back the same way. The back and forth with an additional review can take as long as it takes for FEMA to get the answers they need, and that is probably the biggest thing that will delay a project is if it has a significant amount of questions on any of these relevant issues. The biggest one being historic properties. As far as timeline goes, FEMA will notify the SAA in no more than 45 days of the review status. That sounds like a lot. We have seen easy EHPs get approved in much less than that, but at a bare minimum, they will tell us where things are at within 45 days. So if you’ve submitted something to us, give us a little bit of time to review it and we will then submit it to FEMA. If you have not heard back anything from us within 45 days or a little bit over 45 days, That might be when you might want to check with Cembrye to see do we have an update from FEMA, and if we’re beyond 45 days of submission, we’ll check with FEMA and they’ll tell us where it’s at. We do want to make sure that you have realistic expectations. We have had FEMA EHP approval in as short as four days, but we have had it take as long as eight months, depending upon how complicated the project may be. After we have been notified by FEMA of the approval of your project, we will send a notification to you and indicate in an email that you’re able to expend now grant funding. In reference to the EHP screening form, there is a current version that was attached as an email— a 2017 PDF fillable document. Please do not use any other form of this document other than the one that we provided. The character stroke limitations are a real issue. With what we provided, there is the ability to type whatever you need to type without any limitation. In reference to the first section of the document— Section A Project Information— the DHS grant award number in this instance will be provided by our office, but for the purposes of this exercise, we have a prior grant year. For this current grant year. The grant award number is EMW-2019-UA-00061. We will provide it, but do not worry about it. The main point here is that the the first couple of lines are not yours to fill out, so you don’t need to worry about that. The award number, the grant program, the grantee, the grantee point of contact, the mailing address and the email—That’s all us. You are the subrecipient. So you would fill out the subgrantee portion, indicating your organization’s name, who the point of contact is, the mailing address, email, and the estimated cost of the project. Normally, you would be indicating the subaward amount. There should not be an inconsistency. The project title will always be Target Hardening. For project location, you will indicate the location of your facility for the project, or you can also provide longitude and latitude. But is is preferable for you to use your actual physical address. In the project description, what we’d want to know from you is, basically, what does your project consist of. We want it to be specific to what is the equipment that will be installed, the quantity of the equipment, where will be installed, and if possible, to include the authorized equipment list code. This is not a place to go through a recitation of what makes you vulnerable necessarily, or what was included in your investment justification. You have gotten a subaward; there’s no need to repeat that information. It can be very, very concise, but we need to be able to follow it. Please do not cut and paste from proposals or cut sheets where the narrative is not clear. It’s worth pointing out that in this entire form, this one section here, under project description, is the only place where you really get to describe what you’re doing. Every place else, it’s some specific questions to specific elements of the project. This is the only place where you get to lay out the project as a whole. So, I think this is the best place to describe this is what we’re doing and summarize it. And then, as you get into the subsequent portions of it, you can then refer back to those portions that you’ve already listed here. In the next section—Section B Project Type—you’ll indicate the type of project this consist of. For most of the subrecipients or subawards, you’re going to be checking the box “purchase of equipment”. If it’s a training or exercise that is classroom-based, there will not be a need to complete a screening form. We want to encourage you also if you’re completing this document to save your materials frequently. Normally you’ll be checking just the first box “purchase of equipment”. There may be on occasion a need to check the box “renovationsupgradesmodifications”, but if you have any questions, you can email me. For the next section— Section C Project Details— “purchase of equipment”. For the first line “a”, you are supposed to specify the type of equipment and the quantity. If you’re going to have five types of a particular type of camera, please indicate the quantity and the camera. For the second line “b”, indicate the corresponding AEL code. I think this is a good place to point out one of the quirks of this particular PDF form that FEMA requires us to use. If you look at the sample answer that’s being displayed in section 1.a. “specify the equipment and the quantity of each”, you see in that blue box, there’s a little plus sign in the bottom corner. That indicates that there’s more text that exceeds the size of the box that is being displayed. If you were to click in that box and just scroll to the right, you’ll see there’s quite a lot of text there, actually. And this is something we can’t really fix, but if you have a lengthy amount of text to type in there, you might want to type it either in a word document or something else, and then copy/paste it in, because it can be kind of awkward to type a lot of material in a box where you can only see a few bits of it at a time. And again, this is just a limitation of FEMA’s template. If you can figure out how to work around its limitations, our best advice is just copy/paste it in. From Section C Project Details, you will then go to Section D Project Details regarding project installation. In this section, in the top box—box a—you will tell us not only what equipment will be installed, but how. Meaning: will the cameras be mounted on walls? Will wall packs be affixed to walls? Will bollards be placed outside of the facility on your driveway, or near your driveway? If a fence should be installed, there is a section for that in the box. Exactly, what will the ground disturbance be to install that particular type of equipment such as a fence? The narrative there shows you what FEMA will be seeking: the depth of holes that must be drilled, the width of holes that must be drilled for posts or fences. I think it’s important to answer some of those questions as accurately as you can and to consider all the possible work that would need to be done to install the equipment that you’re installing. One example would be if you’re putting lights on posts in the parking lot, would you need to dig up the parking lot to run new electrical power or would they be running off of an existing electrical power supply? The more you can think out those things ahead of time, the easier it will be to completely answer all these questions and have accurate answers. If there is no ground disturbance, please remember to check the box indicating no for question “b”. The electrical distribution system question is question “c” indicating yes or no. You must in question 2 indicate the age of your structure. You must also thereafter indicate whether there are any buildings or structures that are over 45 years old. Please include if there are renovations, or rehabilitation, or modifications to your structure, the years of those modifications or renovations. Question “d”: in the proximity of your building, are there any buildings that are 50 years or older adjacent to your project area? If there are not, then check the box “no”. If your site is listed on the National Register of Historic Places, again, yes or no, I think the questions are self-explanatory. Now, one question that has come up that was asked in the chat from one of the meeting participants was whether if the delay in receiving a submission and approval to proceed would push some of your timelines back further than what was originally scoped out in your project plan—if you will be penalized for that. And the answer is no. Clearly we would prefer that once you have an idea of what your adjusted timelines are, to go ahead and just ask for the project plan to be sent back so you can revise it. And if that means pushing back some of your due dates, as long as it accurately reflects what you think is going to happen, that’s fine. And then, as we go through and do our quarterly reports every quarter, if another adjustment is needed some time further on down the line, it’s best for the PMP to be accurate. And that’s the most important thing. The grant is a three-year period of performance grant. We started off issuing two year awards, just because we want people to kind of get through the projects early and have that last year for emergencies, but we have three years, if we really, really need it. I don’t think that any project that was funded under Nonprofit would not be able to be accomplished within three years if everybody’s doing what they can to finish. In this section—Setion 3— the final page of your EHP screening form—”site photographs, maps and drawings”. You’ll be asked to attach photographs of the site, labeled, color, ground-level photographs for the project site. Please indicate and check the box, they are required. Color photographs of each location where equipment will be installed or attached to the building structure. For this instance, if there are fifty cameras being installed in fifty different locations in your building, we should have fifty separate photographs of equipment location. They will be floor-to-ceiling photographs, showing where the camera would be installed. Normally, with some type of asterisk or star to show the specific camera location. We want aerial photographs of your project site. You can easily get these using Google Maps, as well as aerial photographs that show the extent of ground disturbance if applicable. Also labelled, color, ground-level photographs that show the exterior side of the structure, only if the building is more than 45 years old. If you have site plans or any other plans, they might also be attached, but they are not required. We’ll have a couple of examples coming up of some well-done EHP photos and how they’re labeled. I think basically the point here is that FEMA is reading your narrative, but they don’t know what your facility looks like or where you are, and so everything you can give them to understand your location, and what your facility looks like, and what work is being done in and around it, the easier it will be for them to approve it the first time. As Cembrye mentioned, the aerial photography—Google Maps is a great solution for that. Just so FEMA can understand, are you in the middle of an open field or are you in the middle of a highly urbanized area? Is there potentially a 100- or 200-year-old church sitting right next to you—that kind of thing. It helps FEMA to contextualize where you’re at. It’ll also give you the opportunity, if you want to use an edit tool, to show the boundaries of your property, if it’s not clear. Potentially, that would be how you could maybe mark off where a fence is going in, or where the lights in the parking lot are going in. For interior or ground-level photographs, thinking about the context—just taking a photograph of just the corner of your building, where the camera’s going, but if you’re so close to the wall, you can’t see anything else, that might not be all that helpful. But if you step back a little bit just so you can put the big photograph in context, I think that’s really what would help them understand what’s going on. Because FEMA has to assess the impact of the equipment installation on the integrity of historic buildings. When you have a floor-to-ceiling photograph, that does give FEMA the context necessary to be able to see exactly how this the equipment installation impacts the historical nature of the property. If we’re able to go to the PowerPoint presentation on the eleventh, twelfth and thirteenth page are examples of the type of photographs that will be expected by FEMA. Here’s an example. It’s a faked-up example that FEMA provided of a notional camera project at Union Station. Here we have a ground level photo taken for a minute with enough distance that you can actually see what’s around the area, but it’s close enough where you can actually kind of make out where they’re going to put these cameras. They’ve used a marking tool to just edit the picture either in PowerPoint or Word or Publisher. There’s a variety of photo editing tools. Even Microsoft Paint can be used to insert those kinds of marks just showing that there are going to be five cameras. One’s on that post; one’s on that wall; one’s over there and further down. It also indicates in the narrative that they’re facing south. That’s helpful information. That way, when FEMA’s looking at it, they can compare that to the Google Map-type aerial photos so they can kind of figure out—oh, where in the property am I right now? Facing south in the rail yard. The next picture on page 12 gives you a better sense of interior installation. You see that the photographs show you exactly where the cameras will be installed. The label says “proposed camera location” and the stars are present where each camera will be located. We just want to note one thing in reference to EHP, there’s not a specific deadline when these screening forms are due. We want you to do a good and thorough job in getting them to us as soon as possible. But again, this is a two-year project. The timeline that we provided in the beginning was notional. If we start to get EHP screening forms in December of this year, that’s great. But really, actually, there is no deadline for the submission of this material. Here’s another example of the Union Station project. In this case, this is the aerial photo. This was just printed out of Google Maps. You can even see the branding down the lower right-hand corner. And they’ve done a really good job here because what they’ve done is, they’ve taken a red marker tool and just noted the boundaries of what Union Station’s property lines are. So that even though this photo’s from a few hundred feet up in the air, this way, you can see, oh, this is Union Station. It’s not the building next to it. It’s not the building south of it. And then they’ve gone in and marked in the camera locations and labeling them again. So you can cross reference this to the ground-level photo. And then that other marking they have up front, in their project that they’re describing, they were proposing putting bollards out in front of the building, so they just drew a yellow line from the building where they expect those bollards to go. Now, a really good submission would have probably also provided the ground-level photo of the front of Union Station with similar markings showing where the bollards are actually going to go. But this is a kind of an example of how you can put together these kinds of additional documentation to supplement the narrative. There was a question regarding how many camera locations can be shown as one photo. As indicated in slide 12, for instance, the photograph there shows three proposed camera locations If that particular photograph could encompass more camera locations, provided that it’s clearly labeled, that would be fine. But it must be very specific and showing proposed camera locations. One more note on that. If in the photograph, if you’re saying, you are going to install a camera at this location, and in the photograph, there’s already a camera there, it might be helpful either in your narrative or in the labeling of the photo to explain whether you’re adding a new camera, in addition, or if you’re replacing the existing one. We’ve had that come up a couple of times in the past where an item is already there. And the question comes back. Are they replacing it? Or is this something extra? If you address that up front, that’d be helpful. Jumping back into—actually, can we skip back to the form really quickly? It’ll answer one of our questions that we had. At the very end of the form, in Appendix A, there’s a question about— has there been any previously approved environmental documentation? And this is, for instance, if you are a previous NSGP recipient, and you’ve gone through an EHP approval for some other project at your facility, you could answer that question “yes” and identify that, either by name or by the reference number. That might help FEMA speed through this process a little bit. If they’ve already answered a bunch of questions about your facility and your neighborhood and the rest of it, they can just refer back to their prior work and get their answer faster. Or if, for instance, if you are in a historic district, and you’ve done some kind of previous renovation or previous work in your facility, and you’ve already had to go through your state historic preservation office, or your local community board, for some kinds of approvals, that might be something that you might reference in your application here. Because again that might speed up the process of figuring out—have some of these questions already been answered? But even if you’re a prior nonprofit recipient, and you’ve had a previous EHP approval at your facility—let’s say in 2017—you still have to go through this process for 2019, but referring to your prior approval might go a lot faster. Is there any other question? Please feel free to continue with the chat. We wanted to note some of the problems that we have had in the past with the EHP screening forms, which will result in a back and forth between our office and with the subrecipients to try to get the best information possible. Again, using the correct template is of utmost importance. Please do not use an old or outdated EHP template. Please provide the information in the spaces that are designated for the type of information sought. Not describing the project in the space provided at the end of the section. You must also provide building age. By not providing building age, we will have to go back and forth with you to get the information so that your form is complete. If you don’t submit photographs, or if you submit photographs that are not labeled, we will have to continue to request that information from you. And if I’m not mindful of the status of your EHP approval, the review, please feel free to contact me at any point to remind me that your project is outstanding. So we don’t want to lose track of approval status. One thing that we will do to help both us and you remember where things are at with EHP is during our review of your quarterly reports, probably not in the January report, but starting in the March report, we will start indicating if we’re providing you feedback every quarter thereafter, whether you if you have not received EHP approval. It’s not necessarily a black mark against you. It’s more of a reminder that, as every quarter goes by, if we have not received final EHP approval, or if you’ve not submitted your EHP request to us, that there’s miles you have to go before we can actually complete the project. So we’ll just keep on reminding on a quarterly basis starting in the spring, if we have not received the EHP approval from FEMA. Please try to have your information in this form be as clear and concise as possible. If there’s material from cut sheets or from product brochures, please edit it and organize it so that the major equipment being installed is obvious to a reviewer. We have reached the end of our scheduled agenda. We do have a couple of questions queued up in the chat. As we go through answering them, if you have additional questions, please feel free to add more. Or if you’d rather ask a question offline, send an email to myself or Cembrye. And we will try to put together all these questions and answers and also publish a frequently asked questions summary after this is all completed. One question has come up and this isn’t necessarily unique to EHP, but it’s a question about a budgeting. If an estimate was made up front that you would have to install twenty cameras, and it would cost a certain amount of money, and then as you’re getting quotes in and getting closer to implementing, you realize that either the amount is less or more. Either one really would have the same result. If you need to change the budget as it’s laid out in your project plan, just go ahead and notify Cembrye that you have a change in your approved budget and you need to move some things around. Probably best to kind of lay it out in an email so that we know what you’re trying to do. And then at that point, if it looks like it’s not a problem, we’ll go ahead and send the project plan back to you in SharePoint. You can update your project plan and resubmit it so that we’re always looking at an accurate picture of what you’re doing. Moving money between elements that were in your original application is relatively kind of uncontroversial and easily approved. We understood that back last spring, you might not have the best grasp of what a security camera might cost. That’s fine. It’s when you start proposing new expenditures or things that were not in the original application—that is the kind of thing that if it’s a too significant, we might have to go back to FEMA for approval. And we really do want to keep those to a minimum, because again, this was a competitive grant. Your project was approved based on how you described it initially. Adding new items or eliminating items that were in it to begin with may be the kind of thing that might not be approved. But please, let us know upfront as soon as you know these things happening. The reason why the EHP screening form you’ve been provided has eight pages that require your providing answers and information regarding your project. The original online version had twelve pages with four pages being examples of photographs and other information that might be helpful in completing an EHP screening form. But this form is concise and all that you need to complete your EHP screening for your project. Another question came up regarding the difference between the award package and the project management plan. To answer that—the award letter is basically us sending you the award saying, you were agreeing to these terms and conditions that fall under this grant program. Your signature of the award letter is you’re accepting the terms and conditions of the award and agreeing to carry out that project. Part of the terms and conditions is to carry out the project that’s in your approved project management plan. Signing the award letter is not the same as having an approved project management plan. But that should be your probably your first step is getting the award letter signed. Once that’s done, you would then be required, per the terms and conditions of the award, to fill out a project management plan. That should then be approved. And that would be a first step before moving forward with the project. In reference to moving money around. This is not an EHP issue. This is really a project management plan issue. We want you to accomplish the deliverables that were set forth in your investment justification— the basis of your award. We don’t want a lot of variation in the expenditures from your original investment justification. But I think as Charles mentioned, we expect some changes, but they must be the activities described in your investment justification and subsequently in your PMP. In section C of the EHP screening form, there’s a question about project details, purchase of equipment. There really is not a limit on what can be typed there. There should not be any problem with your typing fully. All of the equipment that’s going to be installed for your project. Please do not put things like video surveillance system, or access control system, or alarm system. You must in this section—project type details—indicate the components of these projects. If the video surveillance system consists of two monitors, one DVR, five cameras, each component needs to be listed. The same thing for alarm systems and access control systems. If there are going to be five key fobs, pin card readers, it needs to be specified—each component. I think the confusing part about this one, this section, and also the other narrative sections in the entire form, is that they won’t expand to include all the text visible. But it should all fit. It’s just you won’t be able to see it. You’ll have to scroll across to see all of it. Another reason why, if you have a lengthy bit of text to put in there, you may be best off to write it somewhere else and then copy/paste it in. Otherwise, it can be a little bit awkward to use. There have been some individuals or some subrecipients that have submitted EHP documents that have not yet been reviewed. One reason why they’ve not been reviewed is because we had not had the training, and the PMPs have not been approved. Many PMPs have not been approved. However, if you are comfortable with your submission and feel that is thorough and complete, and it would not involve any changes and meets the guidelines that we provided through this training, then you would not have to revise any EHP material that you have uploaded as an attachment in SAA.SP for the ’19 award. So if you mean EHP forms completed for this award, then it will be reviewed. If you mean for some prior year, you would need to submit a new screening form. We might need more clarity on what you mean by prior EHP material. Because there are some older versions of the EHP form floating around in various forums, if you’ve already begun work, or have already submitted an EHP form for this current award using an old template, probably the best bet is to just copy everything into the new template, because FEMA has started ratcheting down and not accepting the old template anymore. They might just reject it out of hand. I think the best bet is to make sure we’re submitting to FEMA using the new template in all cases. In terms of ACH payment, a lot of the turnaround time for payment really does depend on the completeness of the documents that have been provided. And some things might also depend upon the time of year that they have provided. We will try to make every effort to get payment to you within a month of submission, but also we do possibly face backlogs if there’s a problem with the office of the Chief Financial Officer, or if in some way any information provided is incomplete. I think a good rule of thumb would be a check back if you have not received payment within 45 days. That gives us a two weeks internal to our office to get everything through, and the CFO then would have its 30 days under the DC Quick Payment Act to process the payment. I would hope that things go faster than that, but don’t think that it’s overdue unless you are at 45 days from submission, and haven’t received any questions or any rejection of the request due to incomplete documentation. And of course, the better documented and clear it is on the front end, the faster it goes through our process. In reference to the completion of Section C, if you know that you want an access control system, but you don’t have an idea of what the components should be, I think it would be premature at this time for you to submit an EHP screening form. You should have more specific information available to you to complete an EHP screening form, because it would defeat the purpose to submit one prematurely, and you have no specificity of what equipment will be installed. So don’t feel under a time constraint to submit this to us in December, or January, or February. Submit it to us when you realistically know what the equipment will consist of. We do want the best information you have available. What will your systems consist of? The specificity of the information is very important in terms of things being reviewed by FEMA I would suggest not submitting anything where you have a lack of clarity. I think Cembrye makes a good point there, because it’ll be very difficult to describe, especially in marking up your photos, what’s going where, if you don’t know at this point what’s going where. Will it require a panel installation on the wall next to the door? Will it require a camera over the lintel of the door? Or is it just all going to happen inside the locking mechanism? There are different types of access systems, and if you don’t know what you’re planning on getting, you might not know how it’s being installed, and there are some questions in the EHP form you might not be able to answer. Question—this might be fairly unique to the organization that requested it—is there a required time the equipment has to remain in place? Not really, although if you are aware that you’re going to be be leaving the facility soon, you might want to reconsider whether the project is going to provide you the benefits you’d like to have out of it. That’s one, depending on how pressing your timeline is, you might want to contact us so we can figure out exactly what your situation is. But in general, FEMA is not looking to penalize anybody; they are trying to help. So if the project is completed, and then two years down the road, it turns out you’re going to relocate— well, at least you had two years worth of the benefit of this project, and that’s a benefit. In reference to completing your PMP, you do not submit different PMPs— I’m sorry EHPs—based on the category or type of equipment that you’re dealing with. You will combine your entire project on one screening form. So you wouldn’t have one EHP for cameras, and another one for fence, and another one for wall. It would all be in the same EHP screening form and photographs provided for every type and all types of equipment that your project consists of. And one more question. Again, if you don’t know fully what your project consists of, your EHP screening form can wait until you have that information. I think that if you have that information in a month or two months, it does not in any way harm your project substantially. So, please wait to submit your material when you have the best specificity possible. I think that’s one thing we have seen that said some subrecipients have done is that they’ve built in time in their project management plan for that first portion of the period to be nailing down all the specifics of their project, getting all their documentation together, and then submitting the EHP request. If you’ve built that into your project plan timeline, then that’s fine. If you haven’t, and you realize that you’re running behind schedule, and you need to now revise your project plan to include some kind of planning and preparation phase to actually get it all together before implementing— if it’s enough of a delay that your milestones and timelines are really not accurate anymore, we can work with you to revise your project plan to include some kind of ramp-up time to get all this done. But certainly, I think as Cembrye has said couple of times, there’s no rush to get EHP in if you don’t at this time know exactly what you’re trying to do. I think FEMA’s assumption is that when the application went in, there was a good knowledge of what what was needed and what was going to be done. But we have the period performance to work with. So, again, if you don’t know, let’s maybe focus our efforts on getting the PMP done and figuring out exactly what’s gonna happen. And then you’ll be in a spot where you can actually take that knowledge and information, fill out the EHP request form, get it approved by FEMA, and then implement. And again, nothing goes to FEMA. Everything comes to us through the SAA.SP system so that it can be reviewed. And on behalf of the subrecipients, our agency will be the only entity that has contact with FEMA regarding your project. So nothing goes to FEMA directly. It comes to us instead. We are actually at the hour mark. We might turn you loose a couple minutes early. Thank you for sticking around and asking all the useful questions. We will provide a recording of this webinar on our website. It’ll hopefully be useful to people who weren’t able to make it, or if you need a refresher. And then we’ll also write up the questions and answers that we dealt with on this call, as well as any others. If you have any other questions, feel free to contact myself or Cembrye. We will also be doing—probably our next major communication will be upcoming near the end of the year regarding how to submit the quarterly status report. And that’s pretty straightforward. We’ll probably just send out a written guide on how to do that in the SharePoint system. Happy holidays! Thank you. Goodbye.

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