When Disaster Strikes: Municipal Planning and Time Tracking for FEMA Disaster Reimbursement
After seeing the devastating effects of Hurricanes Harvey, Irma and Maria as well as the catastrophic California wildfires, many municipalities are taking a proactive approach in either reviewing and updating their own disaster-preparedness and emergency-management plans or starting from scratch to put them in place. Whether facing hurricanes, nor’easters, tornadoes, earthquakes or other natural disasters, proper planning and organization are key elements for a municipality to provide a cost-effective, compliant and successful emergency response for its residents and businesses and to receive all reimbursement funding available.
In the case of a Federal Disaster Declaration, tracking and properly categorizing all time and costs associated with the disaster response is vital in ensuring everyone adheres to the FEMA guidelines and to make certain that a real-time, accurate record of all reimbursable labor costs and equipment fees are tracked, continually reviewed against budget and ultimately submitted for reimbursement. In order to be reimbursed for any associated costs by FEMA (generally up to 75% of the entire cost), the following is required:
- Presidential Disaster Declaration
- Damage must be within the defined disaster area
- Municipal applicant must be legally responsible for recovery effort
- All work performed must be in the best interest of the public
Once these four criteria have been met, state and local officials can begin the process of seeking funds to aid in recovery efforts including Immediate Needs Funding (INF – paid within the first 60 days of a federal disaster declaration) and Statutory Administrative Costs (covers the cost of completing all necessary disaster-related paperwork, providing backup documentation and attending field inspections and other meetings) . Project recovery is broken into specified types of work such as Debris Removal; Emergency Protective Measures and Permanent Work on Publicly-Owned Facilities and Infrastructure as well as possible Hazard Mitigation to protect against future incidents, all of which may be performed separately or concurrently in order to complete a certain project. Each of the types of work must be completed within a specified time frame and – unless an extension is granted – typically 6 months is provided for Debris Removal and Emergency Protective Measures and then Permanent/Hazard Work should generally be completed within 18 months.
FEMA Specified Categories for Disaster-Related Expenses
FEMA has outlined cost categories for municipalities to utilize when requesting assistance or reimbursement for costs associated with a Federal Disaster area, including:
Force Account Labor
FEMA will reimburse a municipality for the time its own employees spend cleaning up and making necessary repairs after a disaster as well as defined administrative costs for preparing Project Worksheets, field inspections, project applications, final inspection reports and audits and other required paperwork. In general, if any type of emergency response is part of the typical duties performed by municipal hourly workers regardless of whether or not there is a Federal Disaster Declaration, then FEMA only provides reimbursement for any overtime worked and associated fringe benefits (e.g. vacation and time-off accruals, work comp, retirement, sick leave, health insurance, life and disability insurance) based upon hours worked by permanent staff or current seasonal staff that is considered Emergency Work. Straight-time hours and benefits are not eligible for these employees if the work falls under the Emergency Work classification. Other classifications of workers such as employees called back from administrative leave, temporary workers hired to assist in the recovery, seasonal workers who are hired in the off-season to assist as well as permanent employees funded from external sources who assist in performing Emergency Work are eligible for both straight time and overtime reimbursement. For any Permanent Work, both straight time and overtime work is eligible for reimbursement including fringe benefits. As such, maintaining an accurate record of all hours worked and by which classification of worker in association with disaster response and cleanup is imperative and should be clearly broken into Emergency Work vs Permanent Work categories. In compiling all the paperwork needed to submit for reimbursement as well as attending field meeting, inspections, etc. both straight time and overtime are eligible for reimbursement whether for hourly or salaried employees. With changing variables including the types of work and classifications of employees performing it, maintaining accurate records is essential. Preserving historical data for these types of activities can als aid government organizations in future project and/or budget planning as well as its own accounting and reporting to tax payers, other government authorities/agencies, other towns for mutual aid agreements, insurance claims, grant applications or other funding or reimbursement opportunities, etc.
Contract Labor and Vendor Fees
In recognizing that disaster response can be an extremely time and labor intensive undertaking, FEMA provides reimbursements for contract labor hired to assist with approved recovery efforts. While they no longer maintain a list of approved contractors for debris removal (FEMA Debris Removal Contractor Registry Information), they do provide a checklist to help guide applicants through the process of selecting a contractor and obtaining appropriate reimbursement: (FEMA Public Assistance: Contracting Requirements Checklist). FEMA also has a cost estimating tool and standards for public entities to use in determining reimbursable cost estimates for large projects (FEMA Cost Estimating Format SOP) and for engineering and design services (FEMA Public Assistance Cost Estimating Tool for Engineering and Design Services (12/18/2015)).
Many municipalities either do not own the equipment required for their recovery efforts or they do not have enough pieces of equipment to quickly complete the necessary repairs and cleanup efforts prompted by a disaster event. FEMA has outlined a fee schedule for equipment: (FEMA’s 2017 Schedule of Equipment Rates). For both owned and leased equipment, FEMA will only reimburse government organizations for the time that the equipment is in use and not when it is sitting idle at a site. The cost for equipment operators not included in the equipment rates and should be tracked separately for reimbursement.
Debris Removal Expense
In order to be reimbursed for debris removal, all such work must be part of a defined scope of work performed in order to serve the best interest of the public to achieve the following:
- Eliminate immediate threats to life, public health and safety;
- Eliminate immediate threats of significant damage to improved public or private property;
- Ensure economic recovery of the affected community to the benefit of the community-at large; or
- Mitigate the risk to life and property by removing substantially damaged structures and associated appurtenances as needed to convert property acquired through a FEMA hazard mitigation program to uses compatible with open space, recreation, or wetlands management practices.
Cost associated with debris removal can include both the labor for removing and disposing of the materials in addition to any associated fees for transporting and disposal.
Planning for the Future
As with any emergency type response, the best way to ensure a timely and effective response to any emergency is through careful planning as well as by conducting periodic practice drills using different scenarios. While one can never truly plan for exactly what will happen during a minor or major emergency event, there are some steps that can be taken in advance to help ensure a less costly, more fluid and well-orchestrated response effort:
- Identify Debris Removal Site(s) – Many do not realize that the greatest task after a disaster is removing all the debris. Disaster debris typically falls into four basic categories, so your emergency management team should work to create a plan that includes disposal handling and sites for each type of debris (which in some instances may be the same location). The categories are: (1) Damaged Structures; (2) Limbs, Brush, Leaves and Natural Debris; (3) Building Material; and (4) Hazardous Waste. Municipalities should work with their local FEMA representatives as well as their Department of Environmental Services (DES) to determine proper disposal locations and procedures as part of their emergency management plans.
- Review Employee Handbooks to Ensure Policies are Clearly Written and Documented – FEMA bases reimbursement for pay, benefits and other labor costs based upon pre-disaster policies. Ensure that you have defined expectations for emergency response, rates of pay including call-in and blended pay rates, and ensure there is no language indicating emergency pay is subject to Federal funding.
- Implement a Comprehensive Time-Tracking and HCM Solution – As noted on FEMA’s “Public Assistance: Frequently Asked Questions” page, “Good fiscal management and record keeping are essential to controlling the indirect costs associated with FEMA-reimbursed projects.” Even on a day-to-day basis, manually tracking time with paper sheets is a highly error-prone and time-intensive process which also opens government organizations to time theft and potential liability for wage disputes and other compliance issues. When presented with the chaos of an emergency event, the problem is only magnified and it can have a detrimental effect on your ability to receive full reimbursement, not to mention that paper trails can be lost as part of a disaster. With a system like Checkmate HCM’s time and labor management, you can easily track all your employee and equipment reimbursable hours for a federally declared disaster by creating specific cost centers to record time by project, type of work performed, departments and teams.
Employee Force Labor – Your staff can easily clock into the system under specific projects in accordance with FEMA guidelines for reimbursement (Emergency Work vs. Permanent Work, Statutory Administrative, etc.) and employees can change projects or classifications during a shift to maintain accurate records for all employee time associated with the recovery efforts. The system helps to ensure your workers have clearly defined classifications (permanent, temporary, seasonal, returned from administrative leave, etc.) to keep precise records of hours in each category to ensure your municipal organization receives reimbursement for overtime and potential straight time as well as any benefits as permitted.
Contractor and Subcontractor Hours – In addition to allowing you to log time for your own municipal employees, you can also configure the system to permit contractors and sub-contractors to clock in without having their hours roll into your payroll processing. This will help your management staff and elected officials stay apprised of actual expenditures to date and can aid in the reconciliation process when reviewing contractor draws and invoices in addition to compiling the necessary data to submit for your FEMA reimbursement.
Owned and Rented Equipment Hour Logs – Create accounts for pieces of equipment whether owned or leased to permit workers to clock the equipment in when utilized and clock it out while sitting idle to ensure more precise records of equipment use for reimbursement and to compare against contractor invoices. As with Contractor/Subcontractor hours, these accounts can be set to not roll into payroll processing.
Create a Manageable Project Work Schedule – Responding to emergency events can take both a physical and emotional toll on your workers. By having greater visibility to the hours your people are working and the availability of workers based on skills and capabilities, you can more easily determine when to schedule needed breaks and rest periods or call in additional temporary/contract help to drive productivity and, more importantly, prevent burnout and avoid potential added risks in workplace accidents due to fatigue.
Maintain Employee Policies and Procedures – All of your relevant employee documents including Employee Handbooks and acknowledgement of their receipt can be electronically maintained within Checkmate’s HCM solution. You can also utilize the system to send notifications for periodic reviews of documentation and ensure the most up to date version is readily available.
As a cloud-based solution, all this can be completed right from a cellphone using the Checkmate HCM mobile app, via laptops onsite or computers and time clocks in an office. Ease of access and an intuitive interface, provides management and elected officials with real-time visibility to progress, productivity and projections vs actual budget to date to best manage the disaster recovery process or standard day-to-day operations for your municipality. By having an automated time system and goverment workforce management system, not only are you able to quickly and comprehensively compile information for your final reimbursement requests that can be uploaded to the FEMA Grantee Portal, but also easily capture and analyze accurate data for future budget planning, annual reports and right-to-know requests. The system also provides document storage, which can provide you with a centralized solution to scan and store all disaster-project related documentation including invoices, bids, purchase orders, plans and specifications, weight slips, clearance letters and permits. Checkmate HCM also provides the ability to process payroll; administer benefits (including administration of NHRS contributions); track training, certification and performance records; administer time off accruals and vacation requests; recruit online and track applicants and vast array of other HR tasks creating a single-record for each employee, audit trails and a comprehensive database of relevant and easy-to-access and analyze data.
Learn more about how putting the power of Checkmate HCM to work in helping you better manage your municipal workforce and ensure you are fulfilling your fiduciary responsibilities and protecting the best interest of your community, employees and taxpayers.
FEMA periodically updates its Public Assistance Program and Policy Guide. Click here to access the most current version and to find complete details to ensure adherence to and compliance with all requirements: https://www.fema.gov/media-library/assets/documents/111781