prepare + prevent + respond + recover + mitigate what is the match? 1

Prepare + Prevent + Respond + Recover + Mitigate

What is the match?

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Purpose• To explain the non-Federal cost-share

requirement – the “match” – of the Hazard Mitigation Assistance (HMA) programs.

• To identify strategies a Subgrantee can use to meet the “match.”

• To describe the documentation for the non-Federal cost-share.

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Authorities• Hazard Mitigation Assistance Unified

Guidance July 12, 2013• 44 Code of Federal Regulations (CFR) 13.24

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AcronymsDOB Duplication of Benefits

HMA Hazard Mitigation Assistance

FMA Flood Mitigation Assistance

PDM Pre-Disaster Mitigation

HMGP Hazard Mitigation Grant Program

ICC Increased Cost of Compliance

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Why this is important

• Each Federal grant program requires a non-Federal match.

• Failure to meet the match can jeopardize Federal funding eligibility.

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Definitions

• Cost-Share –

• Non-Federal Funds –

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Portion of the costs of a Federally assisted project not borne by the Federal government.

Financial resources provided by sources other than the Federal government.


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Table 2: Cost-Share Requirements Programs

Mitigation Activity (Percent of Federal/Non-Federal Share)

HMGP 75/25 PDM 75/25

PDM – Subgrantee is small impoverished community 90/10

PDM – Tribal Grantee is small impoverished community 90/10

FMA – Insured properties and planning grants 75/25

FMA – Repetitive loss property 90/10

FMA – Severe repetitive loss property 100/0

75/25 75/25 90/1090/1075/2590/10100/0


Ways to meet the cost-share

• Cash.• In-kind.• Certain Federal funds allowed as

non-Federal match.• ICC.

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Cash match – the EASIEST way• Subgrantee matches the cost-

share using its own funds.• Examples of documentation:– Cancelled checks with invoices.– Proof of electronic funds

transfers with invoices.

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In-kind contributions• In-kind contributions are non-cash donations

provided by non-Federal third parties. • These can be in the form of real property,

equipment, supplies, labor, services and other expendable property.

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In-kind (Continued . . . )

In-kind documentation includes:• Record of donor.• Dates of donation.• Rates + time tracking for staff + equipment.• Deposit slips for cash donations.

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In-kind (Continued . . . )

• Documentation must be kept on file by the Grantee + Subgrantee.

• Records must be maintained for three (3) years from the date of FEMA closeout of your last project associated with the specific disaster.

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Examples of in-kind • A local attorney’s time to review the real property

acquisition contract documents and conduct the settlements for the Subgrantee.

• The normal cost of the attorney’s professional time donated to the project (based on her normal per hour or per

settlement rate) is allowable as local in-kind cost-share.

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Examples of in-kind (Continued . . . )

• A homeowner accepts 75 percent of the value of his home in cash and donates the rest of the appraised value to the project.

• The remaining 25 percent donated value is allowable as a third party in-kind contribution.

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Examples of in-kind (Continued . . . )

• The local hardware store donates construction materials for a hurricane shuttering project.

• The retail value of those materials is an allowable third party in-kind contribution.

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Changes in guidance

• There is no longer a limit on in-kind contributions for the non-Federal cost-share.

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Certain Federal funds allowed as non-Federal match

• Generally, non-Federal cost-share requirements may not be met with funds from other Federal Agencies.

• There are exceptions.

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Examples of “Federal funds”

• Federal funds that can be used as the non-Federal cost-share:– U.S. Department of Housing and Urban

Development (HUD) Community Development Block Grant (CDGB) funds.

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Rule of thumbFederal funds as match

• Federal funds used to meet a non-Federal cost-share requirement must meet – and be used for – eligible approved activities of both the Federal source program and the HMA grant program.

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Increased Cost of Compliance (ICC)

• Are costs associated with bringing the structure into compliance with the local flood plain ordinance.

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ICC (Continued . . . )

• National Flood Insurance Program (NFIP) ICC claim payment from a flood event may be used to contribute to the non-Federal cost-share requirement.

• Claim must be submitted within the NFIP timeframe. (Set by NFIP – 2 years from the date of claim)

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• ICC coverage can be a part of a commercial/residential NFIP policy.

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• If the ICC payment exceeds the required non-Federal share, Federal funding will be reduced to the difference between the cost of the activity and the ICC payment.

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• ICC match can only be used for the following projects:– Elevation– Relocation– Demolition– Floodproofing

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• Example:– If you received $10,000 for ICC then that

$10,000 will be used as part of the non-Federal match, if used for the intended purpose.

– If not used for the intended purpose, it will be counted as Duplication of Benefits (DOB).

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• Policy holder must sign the insurance claim over to the Subgrantee.– Only the part of the ICC benefit that pertains to

the project can be assigned.– The ICC benefit canNOT be assigned to another

individual.

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Cost-share documentation requirements

• The local match must be documented as reasonable + allocable + necessary. – And must comply with all Federal requirements

+ regulations.• The type of cost-share MUST be identified at

the time of application.

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Most important 3 takeaways

• Several options to meeting the cost-share requirement:– Cash.– In-kind.– Certain Federal funds allowed as non-Federal match.– ICC.

• Always document your cost-share.• No longer a limit on in-kind contributions.

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Contact

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Jeffrey [email protected]

Tenesha [email protected]


Questions?

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For more information + to download materials from today’s seminar:

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gohsep.la.gov/outreach.aspx

prepare + prevent + respond + recover + mitigate what is the match? 1

Documents

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certain federal funds

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