Item 35 - FY 2022 Emergency Management Performance Grant

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44 •The record retention period will be extended if the recipient is notified in writing of the extension by FEMA, the cognizant or oversight agency for audit, or the cognizant agency for indirect costs. See 2 C.F.R. § 200.334(b). •Where FEMA requires recipients to report program income after the period of performance ends, the program income record retention period begins at the end of the recipient’s fiscal year in which program income is earned. See 2 C.F.R. § 200.334(e). •For indirect cost rate proposals, cost allocation plans, or other rate computations records, the start of the record retention period depends on whether the indirect cost rate documents were submitted for negotiation. If the indirect cost rate documents were submitted for negotiation, the record retention period begins from the date those documents were submitted for negotiation. If indirect cost rate documents were not submitted for negotiation, the record retention period begins at the end of the recipient’s fiscal year or other accounting period covered by that indirect cost rate. See 2 C.F.R. § 200.334(f). Types of Records to Retain FEMA requires that non-federal entities maintain the following documentation for federally funded purchases: •Specifications; •Solicitations; •Competitive quotes or proposals; •Basis for selection decisions; •Purchase orders; •Contracts; •Invoices; and •Canceled checks. Non-federal entities should keep detailed records of all transactions involving the grant. FEMA may at any time request copies of any relevant documentation and records, including purchasing documentation along with copies of canceled checks for verification. See, e.g., 2 C.F.R. §§ 200.318(i), 200.334, 200.337. In order for any cost to be allowable, it must be adequately documented per 2 C.F.R. § 200.403(g). Non- federal entities who fail to fully document all purchases may find their expenditures questioned and subsequently disallowed. Actions to Address Noncompliance Non-federal entities receiving financial assistance from FEMA are required to comply with requirements in the terms and conditions of their awards or subawards, including the terms set forth in applicable federal statutes, regulations, NOFOs, policies, and this Manual. Throughout the award lifecycle or even after an award has been closed, FEMA or the pass-through entity may discover potential or actual noncompliance on the part of a recipient or subrecipient. This potential or actual noncompliance may be discovered through routine monitoring, audits, closeout, or reporting from various sources. In the case of any potential or actual noncompliance, FEMA may place special conditions on an award per 2 C.F.R. §§ 200.208 and 200.339, FEMA may place a hold on funds until the matter is corrected, or additional information is provided per 2 C.F.R. § 200.339, or it may do both. Similar remedies for noncompliance with certain federal civil rights laws are authorized pursuant to 44 C.F.R Parts 7 and 19.