4 keys to managing multiple disasters
Many states are responding to multiple concurrent disasters—simultaneously battling the ongoing COVID-19 pandemic, responding to new disasters, and trying to recover from legacy disasters, or those that have reached the FEMA closeout stage. One example is Louisiana with 18 open disaster declarations. This includes projects from Hurricane Katrina, which remain open more than 15 years after that storm struck.
But Louisiana is not alone. Nationwide, state and local emergency managers must increasingly cope with multiple disasters rather than discrete events. When a new disaster strikes, immediate response is necessarily all hands on deck. Yet legacy disasters still need time and attention. The issue is that, in most states, disaster management staff are too resource-constrained or overwhelmed to ensure that at least some staff continue to work on these legacy disasters.
The importance of grant closeout
Each recipient of funding from a presidentially declared disaster is responsible for grant closeout. Complete closeout depends on each subrecipient having closed out all of their projects. The consequence of a prolonged delay in closing out a disaster is potential deobligation of federal funding, which leads to a debt for the recipient.
Closeout entails two elements: completeness and compliance. For completeness, all necessary documentation to support the funding must be captured. Compliance requires certification that all funding was disbursed in compliance with federal, state, and local regulations. When these two actions do not occur, recipients bear significant costs because they must then use state funds to complete projects and face the prospect of repayment for disbursed federal funding.
What can federal aid recipients do to prevent this situation from happening? Here are four keys to managing multiple legacy disasters while also responding to an active disaster.
1. Assign those with experience to close out legacy projects.
Take advantage of the expertise of staff who’ve previously managed grants to completion by assigning them to help close legacy projects. A percentage of the total dollars from disaster funds is allocated for management costs and is disbursed during the life of the disaster. Funding should be managed to ensure sufficient funds for closeout implementation are available. Capitalizing on the experience of private sector contractors with grants management expertise can also help ensure sufficient experienced staffing to complete the closeout cycle without straining resources assigned to current disasters.
2. Render decisions based on final deadlines.
When necessary, establish a firm deadline for all subrecipients. Historically, subrecipients have been afforded deadlines to comply with submission of documentation. The decision to terminate the opportunity to submit documentation will no doubt cause some subrecipients to have disbursements deobligated. However, in most cases, failure to produce compliant and adequate documentation during the lifecycle of a disaster indicates the inability to produce this documentation at closeout.
Education and documentation are key to keeping subrecipients on track. Start by helping them understand what's allowed and what's needed (e.g. grantees can provide technical assistance to subrecipients but cannot do the work for them). Detail discrepancies and omissions using checklists and reports, as these documents are particularly useful for recipients providing technical assistance. And finally, conduct ongoing outreach and education to subrecipients—this real-time dialogue is critical to achieving closeout. With final deadlines in place, recipients will be better able to focus their resources and efforts on concluding the closeout process.
3. Pay attention to details to manage grants properly.
Adopt a closeout mentality from the beginning in order to set up maximum funding distribution and minimum likelihood of deobligation. The reality is that during the emergency and recovery period, closeout is often not top of mind. Consequently, as closeout occurs, recipients will make multiple requests to subrecipients for documentation, which in some cases cannot be provided. Providing technical support at the onset of a disaster—by focusing on compliance and completeness of documentation—will expedite the closeout process. At some point, grantees will have to decide to go with what documentation is available and to acknowledge that some portion of the grant may be deobligated. The grantee must inform the subrecipient of this situation.
4. Choose a strategy that matches the event.
Understand that the strategy for implementing a current disaster is different from closing out legacy disasters. For legacy projects, FEMA will negotiate to develop an agreed-upon plan that focuses primarily on validation of funding that was expended. Recipients can collaborate with FEMA on possible concessions for alternative solutions to documentation requirements. For a current or future disaster, there are prescribed requirements for completion and compliance that require verification throughout the implementation process. One successful strategy for arriving at the closeout cycle is to focus on achieving fully-compliant documentation as disaster recovery is implemented.
Planning ahead
If you are facing a looming threat of new disasters on top of your current load, planning and training will be essential to successful implementation. The work must continue on legacy disasters throughout the challenge of managing additional disasters. Approaching future disasters with a closeout mentality—combined with a continuous dedication to legacy closeout—will ensure the maximum amount of federal assistance through disaster recovery.
