After what seemed like an eternity after pressing the submit button, DHS has finally cut through all of the red tape and has begun to send out what we like to call the pre-award notifications. I know it's been a frustrating wait, but we have to remember that not only do we as the grant applicants bound to abide by the laws governing the AFG program, but so does DHS. This year there were some delays, but since things have started to move now, let's not waste time talking about the past.
So what are these pre-award notifications you ask? The one that started appearing on September 5 is the Update 1199A link. The SF-1199A for is a federal direct deposit verification form, used to ensure that any money transfers are going to the appropriate bank accounts. If you see this link appear in this year's AFG application status box, follow the directions and get it sent to DHS as soon as possible. Award winners from prior years might not get one of these, but if they are in line for an award they can find the 2006 AFG application number on the previous 1199A.
If you have been awarded before, you may not get an Update 1199A link, they will make the assumption that nothing has changed, but give you the opportunity to make changes if needed. If this is your first award then you need to make sure all of the information is correct online.
One of the more common mistakes is not ensuring the name listed on the form is the name of someone authorized to handle funds on that account. Normally it will be a treasurer, Chief, or in the case of city based departments perhaps the mayor or city administrator. Once all of the information is correct, use the Save button and a new page will load for printing. Take the printed form to the bank and have the branch manager sign it which will verify that all of the information is correct from their perspective and the organization's representatives listed are truly authorized on the account. Then send it up to Washington DC at the provided address. DO NOT use a 39 cent stamp to mail this form. You want to ship it in a manner that will give you confirmation that they received it. This will save many headaches as well as delays in awarding later.
The next sign that Rudolph the Greenback-Carrying Reindeer might be coming is an e-mail or phone call from DHS asking 10 very important questions. The gist is that they want to know that if they picked you for the award, would you still want it. This may sound like a dumb series of questions; because of course, everyone wants the money. We didn't spend hours refining our application just for posterity, show us the money!
But seriously, departments do turn down awards for various reasons from lack of local support for the funding or just not knowing what to do. If you find yourself about to decline an award, make sure you have a highly valid reasoning for it before saying no. You can't change your mind later. And so everyone is aware, you are not required to have the matching funds available at the time of the award. You have all 12 months of the "Performance Period" to raise them if you do not have anything in savings.
Announcements & Bidding
Once your department name finally appears and you have been officially awarded, now is the time that the work starts. To comply with the competitive bidding regulations of the AFG program award winners must request at least two bids for their project components. Note it says request, not receive. It is a hair splitting, but in our free market society you can't force a business to give you a price on anything.
If they don't want to bid, do yourself a favor and cover your butt with a statement from them to the effect that they are respectfully declining to enter a bid for your business. I would still make an attempt to get other vendors with comparable equipment to give you pricing, but in some cases this may not be possible. They are rare, but the most important thing to remember is make an effort to get yourself the best possible package of equipment, price, and service. I'm a firm believer that anyone can sell you something, but it's the companies that are there after the sale that truly earn business and keep it.
But back to bidding, local and state regulations override the AFG regulations. If you are required to receive three bids based on a local ordinance, then you must request AND receive three bids on your project. The stricter set of regulations is the one that you must follow.
One of the few exceptions to this is purchasing co-operatives, such as state purchasing lists or even an organization such as the Houston-Galveston Area Council (www.hgacbuy.com). In these instances, all listed items were priced based on a bid created by the agency running the list. Member agencies are exempt from normal bidding requirements when buying from these lists because the agencies basically pre-bid the items for everyone else, saving members from having to create their own bid packages and solicit pricing. There are different regulations for purchasing from co-ops in each state. There are also variances on the extent of options that can be included or excluded from the items on these lists so be sure you understand what your requirements and limits are before purchasing in this manner.
The other exception is interoperability. If everyone around you is using Brand X, and Brand Y is not compatible with Brand X then your claim in your application that you needed this equipment to become interoperable doesn't hold much water if you buy Brand Y. Very few projects have this possibility where only one brand will satisfy interoperability requirements, but if yours does then unless there are more than one vendor that serves your area that sell the brand you need you won't be able to receive more than one bid. This is where a statement from a vendor for similar equipment that their products cannot satisfy the bid request is essential to pass a site audit.
Most important of all, if awarded you have to purchase within the spirit of your grant application. In a nutshell you have to buy what you said you want to buy for the reasons you said you want to buy them. You can't extol the virtues of composite bottle 4500psi SCBA because of their lightweight and then go buy 2216psi steel bottle back-breakers because they cost less. You can't take your tanker award and go buy a heavy rescue, or buy nomex PPE after asking for PBI-blended type PPE because of the increased protection. Making such mistakes will cause DHS to carry your purchases away after an audit. They have towed vehicles from stations, and packed up a lot of equipment from departments that attempted to pull a fast one. You will be audited, and you will lose if you break the regulations.
Despite the claims from the computer gurus in the late 1980s, paperwork is not becoming a thing of the past. With nearly every grant award you have to have a paper trail of some kind proving that you did what you were supposed to. As previously mentioned, attempting to obtain more than one bid is classified as an administrative requirement, but let's look at the others:
- Awardees are required to file a six-month performance report. It doesn't have to be highly detailed, but if you have spent any money by now you want to account for it here. Some departments are completely done with their purchasing and payments within six months, it depends on what your project is. Most vehicle awards are not, so it is alright to file the report stating that the vehicle has been ordered and is being built at this time.
- You are expected to keep whatever you purchase with your grant award for the entire service life of that equipment. You can't turn around in two years and try to sell that tanker you needed so badly to buy some new furniture for the meeting room.
- You must not adjust your next budget because of the award, it has to be greater than or equal to the average of that line item in the previous two years worth of budgets. Grants are not meant to be long term fixes to whatever funding problems you are having, they are meant to assist along the way. So if you put $5,000 aside each year for new PPE then you must continue to do so. It wouldn't make sense to stop, with all of the use and abuse PPE takes on calls and in training, why would you not want to have a nest egg ready to buy or repair a set?
- You must keep all paperwork readily available for inspection for 3 years. While the actual Performance Period of the grant award ends 12 months after the announcement date (barring extensions), you can be audited at any time within 3 years of the award to ensure compliance with the longer term rules.
The easiest way to avoid problems that I've found is have one folder with all pertinent paperwork in it. Print out all emails, make sure you have copies of all purchase orders, the actual application and award package from the DHS website, and if there were any phone conversations mark dates, times, and persons you talked to. If you really want to cover your gluteus maximus, send an e-mail to the person you talked to on the phone asking them to confirm the outcome of the conversation, then print that out and add it to the binder. Of course making a copy of everything in the binder and keeping it in a safe place away from the original is probably not a bad idea, but don't forget to mark the binders with their contents. Nothing is worse than being told "it's in the white binder in the back closet" only to find that someone went to Sam's Club for a few boxes of white binders to store everything in.
The normal Performance Period for awards is one year. Sometimes products are backordered, truck delivery dates change, or some other circumstance that will cause you to need an extension beyond then end of that 12th month. This is not a cause for concern, it happens all of the time. If you are getting close to the end of the Performance Period and you think your equipment will not be in before it ends, contact your Fire Programs Specialist to file an extension. Do not wait for them to call you asking why you haven't closed out yet. The same staff is handling all of the grant programs at once, so the more you follow the guidelines the less stress and problems it will cause for everyone, especially you.
Most importantly at this point, don't forget to start on next year's grant project. It is never too early to start. Many departments I work with started on the next application within weeks of submitting this one. While the guidelines obviously haven't been published, if you read back through the older versions the priorities really haven't changed much at all. PPE, SCBA, basic pumpers, and other projects are all still high priorities, and there is no reason to think that they won't be come next March.
In a couple of weeks I'll be back to explain how to handle a denial notification, and some metrics we can go over to make sure we didn't miss anything in our current application. There may be nothing at all wrong, you have to remember most of all that the AFG is a competitive grant program so there are a lot more requests for funding than there is funding. Plenty of solid applications get denied. So stay tuned, and congratulations to those that are on their way to being awarded.