Report 2011-103 Recommendation 8 Responses

Report 2011-103: California's Mutual Aid System: The California Emergency Management Agency Should Administer the Reimbursement Process More Effectively (Release Date: January 2012)

Recommendation #8 To: Emergency Management Agency

If FEMA determines that the calculations and claims identified in the Office of Inspector General's audit report were erroneous, Cal EMA should ensure that the replacement for its current invoicing system can calculate the maximum number of reimbursable personnel hours under both FEMA's policy and the CFAA.

Agency Response*

Cal OES revised the Applicants Briefing materials to reflect FEMA's Public Assistance Program and Policy Guide (April 2017) revisions. Cal OES submits a compact disc (CD) that contains the most recent Major Declaration Applicants Briefing Materials/Handouts and the most recent Fire Management Assistance Grant Program Applicants Briefing Materials/Handouts. These documents are also available on Cal OES's website. Please review the links below.

Links:

Powerpoint for DR 4308: http://www.caloes.ca.gov/RecoverySite/Documents/4308%20CA%20Severe%20Winter%20Storms%20Flooding%20and%20Mudslides%20Presentation.pptm

Federal Disaster Assistance Information/Forms: http://www.caloes.ca.gov/cal-oes-divisions/recovery/public-assistance/federal-disaster-assistance

Public Assistance Forms (cost accounting, FEMA information, etc.): http://www.caloes.ca.gov/cal-oes-divisions/recovery/forms

FMAG Specific Information/Forms (cost accounting, applications, etc.): http://www.caloes.ca.gov/cal-oes-divisions/recovery/public-assistance/fire-management-assistance-grant

Applicants Briefings: http://www.caloes.ca.gov/cal-oes-divisions/recovery/public-assistance/applicants-briefings (note: documents for specific briefings are posted for a limited time)

  • Response Type†: Annual Follow Up
  • Completion Date: April 2017
  • Response Date: November 2017

California State Auditor's Assessment of Status: Resolved

At the time of our audit, FEMA's recovery policy permitted the reimbursement of personnel costs up to 24 hours for each of the first two days, but only up to 16 hours for each of the following days, in the emergency response period. However, CAL FIRE scheduled firefighting resources for a 24-hour response and requested reimbursements for 24-hour periods after the first two days of a response. This was the subject of the Office of Inspector General's audit report. However, FEMA's policy changed to allow reimbursement for 24-hour shifts for up to 14 days from the start of the incident period. CAL OES provided examples of its Applicant Briefing materials for recent emergency responses which reference FEMA's revised policy. Therefore, we believe this recommendation is resolved.


Agency Response*

FEMA issued a Public Assistance Program and Policy Guide in January 2016. This publication combines all Public Assistance policies in the 9500 series, superseding FEMA Policy 9525.7.

Cal OES will comply and revise our applicant briefing materials to reflect changes in the new guide. In addition, we will notify sub-recipients of these changes through the revised applicant briefing materials. Once revisions have been completed, we will forward supporting documentation reflecting these changes.

The current invoicing system can calculate the maximum number of reimbursable personnel hours. The Mutual Aid Reimbursement Program does not apply to forced account labor and should not be included as part of this response.

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: December 31, 2016
  • Response Date: November 2016

California State Auditor's Assessment of Status: Not Fully Implemented


Agency Response*

Cal OES is working to comply and revise our applicant briefing materials to reflect all the changes and updates in the new guide. In addition, we will notify sub-recipients of these changes through the revised applicant briefing materials. These revisions will be completed by December 31, 2016, and we will forward the supporting documentation reflecting these changes.

The current invoicing system can calculate the maximum number of reimbursable personnel hours. The Mutual Aid Reimbursement Program does not apply to force account labor and should not be included as part of this response

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: December 31, 2016
  • Response Date: November 2016

California State Auditor's Assessment of Status: Not Fully Implemented


Agency Response*

FEMA issued the Public Assistance Program and Policy Guide in January 2016. This publication combines all Public Assistance policies in the 9500 series, superseding FEMA Policy 9525.7.

Cal OES is working to comply and revise our applicant briefing materials to reflect all the changes and updates in the new guide. In addition, we will notify sub-recipients of these changes through the revised applicant briefing materials. These revisions will be completed by December 31, 2016, and we will forward the supporting documentation reflecting these changes.

The current invoicing system can calculate the maximum number of reimbursable personnel hours. The Mutual Aid Reimbursement Program does not apply to force account labor and should not be included as part of this response.

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: December 31, 2016
  • Response Date: November 2016

California State Auditor's Assessment of Status: Not Fully Implemented


Agency Response*

To date, the FEMA Policy 9525.7 proposed changes are still under review and a definitive decision has yet to be made. As soon as we receive the final word on the proposed changes we will comply appropriately.

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: Unknown
  • Response Date: October 2015

California State Auditor's Assessment of Status: Not Fully Implemented


Agency Response*

To date, the FEMA Policy 9525.7 proposed changes are still under review and a definitive decision has yet to be made. As soon as we receive the final word on the proposed changes we will comply appropriately.

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: Unknown
  • Response Date: October 2014

California State Auditor's Assessment of Status: Not Fully Implemented


Agency Response*

We have been working with the Federal Emergency Management Agency (FEMA) on making a determination on whether the calculations and claims identified by the Office of Inspector General's (OIG) audit report were erroneous. As of this time, they have not provided us an official decision. In addition, we have been made aware that FEMA and the National Emergency Management Association (NEMA) are reviewing the FEMA Labor Costs - Emergency Work Policy (Recovery Policy 9525.7) and will be revising the policy that addresses the reimbursement cost for employees performing emergency work, as well as the limitations on the 24-hour shift. As soon as a final decision is made or the policy approved we will comply appropriately.

  • Response Type†: Annual Follow Up
  • Estimated Completion Date: Unknown at this time
  • Response Date: November 2013

California State Auditor's Assessment of Status: Not Fully Implemented


Agency Response*

There was no change in the status of this recommendation since the 6-month response.

  • Response Type†: 1-Year
  • Response Date: February 2013

California State Auditor's Assessment of Status: Pending


Agency Response*

Cal EMA did not specifically address whether or not its new Mutual Aid Reimbursement Program will be able to calculate the maximum number of reimbursable personnel hours under both FEMA's policy and the CFAA. (See 2013-406, p. 74)

  • Response Type†: 6-Month
  • Response Date: September 2012

California State Auditor's Assessment of Status: Pending


All Recommendations in 2011-103

†Response Type refers to the interval in which the auditee is providing the State Auditor with their status in implementing recommendations made in an audit report. Auditees must submit a response regarding their progress in implementing recommendations from our reports at three intervals from the release of the report: 60 days, six months, and one year or subsequent to one year.

*Agency responses received after June 2013 are posted verbatim.


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