Item 18 - Adopt Resolution for FY 2021 Emergency Management Performance Grant

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Preparedness Grants Manual | February 2021 41 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 • Cancelled 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 cancelled 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. In the event the noncompliance is not able to be corrected by imposing additional conditions or the recipient or subrecipient refuses to correct the matter, FEMA might take other remedies allowed under 2 C.F.R. § 200.339. These remedies include actions to disallow costs, recover funds, wholly or partly suspend or terminate the award, initiate suspension and debarment proceedings, withhold further federal awards, or take other remedies that may be legally available. For further information on termination due to noncompliance, see the section on Termination Provisions in the relevant NOFO. FEMA may discover and take action on noncompliance even after an award has been closed. The closeout of an award does not affect FEMA’s right to disallow costs and recover funds as long as the