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Chapter 11: Project Monitoring and Amendments

Post-award project monitoring includes managing projects, ensuring subrecipients use funds in alignment with the approved scope of work (SOW), adhering to set deadlines, and meeting compliance requirements. Recipients are responsible for assessing the risk of non-compliance for each subrecipient and, if necessary, imposing additional conditions or requirements. Monitoring subrecipients is essential to ensure compliance with federal regulations and the achievement of performance goals, which includes reviewing financial and progress reports.

PA staff support recipients, track the overall progress of disaster operations, and manage requests for changes in scope, time extensions, project closeouts, appeals, audits, and arbitration.

I. Post-Award Change in Scope of Work

Subrecipients must ensure PA funding is used exclusively for eligible work specified in the approved project. If a change to the SOW becomes necessary, subrecipients should promptly consult with both the recipient and FEMA to allow sufficient time for FEMA to review the proposed changes for eligibility.

A. SOW Revision Process

To request a change, subrecipients must submit a written request to the recipient, including a detailed justification explaining why the change is necessary and supporting documentation for FEMA to substantiate the eligibility of the proposed revision. If the request involves previously unreported damage, subrecipients must provide documentation linking the work directly to the disaster. The recipient then forwards the request and its formal recommendation to FEMA.

Eligible Scope Modification Triggers

Commonly eligible reasons for SOW changes include:

• An alternate repair method is proven more cost-effective than the original proposed repair method.
• The original repair method is determined to be no longer technically feasible.
• Upgrades are required to comply with eligible building codes and standards.
• An increase in previously approved quantities is required due to documented errors or omissions.
• Hidden incident-related damage is discovered during the active performance of eligible work.
• The subrecipient wishes to formally pursue an improved or alternate project.

B. Change in Scope Documentation Requirements

Mandated Modification Data Fields

To facilitate evaluation, the subrecipient's written request must systematically outline the following information for both small and large projects:

• Detailed changes to the scope of work and a revised cost estimate.
• A cost estimate comparison if the request is based on a more cost-effective repair method.
• Supporting technical reports or surveys if the original scope of work is no longer technically feasible.
• Hidden damage documentation substantiating that the damage is directly related to the declared incident, accompanied by photographic evidence discovered during the performance of eligible work.
• An updated construction timeline or project schedule, including a formal time extension request if the scope of work change will cause work to be conducted outside the approved period of performance.

II. Work Completion Deadlines

FEMA provides PA funding only for work completed and costs incurred within specified regulatory deadlines. FEMA considers these timelines as the approved period of performance (POP) for a project, defining work completion as fulfilling all tasks in the approved SOW and meeting compliance requirements.

Period of Performance Limits

• Emergency Work (Categories A-B): The regulatory completion deadline is 6 months from the disaster declaration date.
• Permanent Work (Categories C-G): The standard regulatory completion deadline is 18 months from the disaster declaration date.
• Category I (Code & Floodplain Administration): Subject to a strict 180-day operational limit.

Performance Boundary Exclusions

Scope Notice: The period of performance window does not include late payments for invoices, contractor warranty periods, or grant management activities such as submitting closeout documentation, reconciling finances, or requesting final payment.

A. Time Extension Request Elements

If additional time is required, subrecipients must submit a written request to the recipient containing:

• The specific dates and justification for all previous time extensions.
• A detailed, technically supportable justification for the project delay.

B. Extension Authorities and Valid Grounds

Recipient Extension Thresholds

Recipients have the initial authority to grant time extensions due to extenuating circumstances on a project-by-project basis:

• Emergency work projects may be extended up to an additional 6 months.
• Permanent work projects may be extended up to an additional 30 months.
• Exceptions: Recipient extension authority excludes temporary relocation projects and Category I projects. Recipients must notify FEMA of all approved extensions via the Grants Portal or official correspondence.

FEMA Direct Extension Triggers

Any time extensions extending beyond a recipient's maximum boundary require formal FEMA approval. FEMA holds the authority to grant further extensions if justified by extenuating circumstances beyond the applicant's control.

Valid Extenuating Delays

• Delays directly caused by complex permitting or Environmental and Historic Preservation (EHP) requirements.
• Atypical site limitations, such as narrow, environmentally mandated construction windows.
• Extreme adverse weather conditions that prevent physical site access.
• Widespread shortages of materials, specialized equipment, or qualified contractors.

Invalid Delay Exceptions

Extension Rejection Notice: FEMA does not recognize the following as valid grounds for an extension: delayed permit submissions by the applicant, general lack of local funding, internal administrative or personnel changes, or delays in compiling final cost documentation.

III. Large Project Quarterly Progress Reports

Funding for PA large projects is based on estimated costs, contracted costs, or a combination of both for an approved scope of work, with grant funds obligated accordingly. Regular reviews and timely identification of any changes in project costs are essential.

Large Project QPR Tracking Controls

The large project Quarterly Progress Report (QPR) is an administrative tool used to track project expenditures relative to completion percentages, compare completed work costs against obligated funding, monitor fund drawdowns, and assess overfunding or underfunding. It tracks open large projects pending final federal payment and highlights issues that could cause noncompliance with grant conditions. Quarterly progress reporting is strictly prohibited from being requested or required for small projects.

Submission Cycles

FEMA requires recipients to report on the status of all open large projects each quarter. QPRs must be submitted to FEMA within 30 days of each fiscal quarter's end.

Quarterly Reporting Deadlines

• Quarter 1 (Oct 1 – Dec 31): Report is due no later than January 30.
• Quarter 2 (Jan 1 – Mar 31): Report is due no later than April 30.
• Quarter 3 (Apr 1 – Jun 30): Report is due no later than July 30.
• Quarter 4 (Jul 1 – Sep 30): Report is due no later than October 30.

Mandatory QPR Data Fields

Subrecipients and recipients must fulfill specific tracking fields based on the physical completion status of the large project:

In-Progress Large Projects (Subrecipient Fields)

• A brief description of known problems or circumstances expected to cause a deviation from the approved SOW, cost, or delay project completion/closeout.
• Active status of the project (construction phase or precise percent complete).
• Clear verification of whether the work is physically complete.
• The official project period of performance end date and the projected completion date.
• Current status of any pending or approved time extensions.

Completed Large Projects (Subrecipient Fields)

• The exact date the scope of work was physically completed.
• Identification of the specific entity responsible for the next action in the closeout process (FEMA, recipient, or subrecipient).

Completed Large Projects (Recipient Fields)

• Total cumulative funding amount disbursed to the subrecipient.
• Formal verification of whether final payment has been executed.
• Documentation showing whether time extensions were approved, alongside the latest approved work completion deadline.

IV. Financial Reporting & Public Policy Mandates

A. Financial Status Reports

Recipients must submit the Federal Financial Report (SF-425) quarterly to their respective FEMA Regional Office. These reports detail the financial status of funds for the prime award, track the recipient's expenditure drawdowns, and verify that the recipient is meeting its statutory cost-share requirements.

B. Federal Funding Accountability and Transparency Act (FFATA)

FFATA mandates that FEMA manage and administer awards to ensure federal funding is expended in full accordance with the U.S. Constitution, federal law, and public policy requirements. This includes regulations protecting free speech, religious liberty, public welfare, the environment, and prohibiting discrimination.

FFATA Tracking Thresholds

Recipients are responsible for complying with all FFATA provisions, including executive compensation disclosures and non-federal entity regulations under 2 C.F.R. Parts 25 and 170. Recipients must register in the FFATA Subaward Reporting System and report on all awards and subawards equal to or greater than $30,000.

V. Audits & Civil Rights Oversight

Recipients and subrecipients are subject to federal and non-federal audits by state or territorial auditors, FEMA, the U.S. Department of Homeland Security Office of Inspector General (OIG), and the U.S. Government Accountability Office (GAO). FEMA reserves the authority to adjust project funding based on audit findings.

A. Single Audit Valuation Threshold

Audit Trigger: A recipient or subrecipient that expends $1 million or more in total federal funds during its fiscal year must perform a formal single audit or program-specific audit in compliance with 2 C.F.R. § 200.501.

B. Investigatory Agencies

• Government Accountability Office (GAO): Operating as the independent, nonpartisan investigatory arm of Congress, the GAO investigates how federal taxpayer dollars are expended and retains the authority to audit any PA project.
• Office of Inspector General (OIG): Conducts independent audits and investigations into FEMA operations, recipient/subrecipient expenditures, and single audit oversight to identify, deter, and address fraud, waste, and abuse. It retains the authority to audit any project. Award entities are highly encouraged to report suspicious activities to the FEMA Fraud and Investigation Division or the DHS OIG Hotline.

C. FEMA Office of Civil Rights (OCR)

The OCR holds the authority to conduct investigations and compliance reviews to ensure that FEMA financial assistance is administered without discrimination. OCR reviews recipient documentation before, during, and after disasters, investigates public complaints alleging civil rights violations, and can render formal decisions or refer complaints to other agencies.

VI. Recovery of Improper Payments & VAYGo

FEMA conducts audit assessments on drawdowns to recover payments identified as improper under the Payment Integrity Information Act.

Validate as You Go (VAYGo) Framework

The VAYGo review process is an expanded grant payment review framework applied to all PA and Fire Management Assistance Grant (FMAG) disasters.

VAYGo Operational Goals

• Consistently assess payment error rates to identify and mitigate potential payment integrity issues.
• Improve internal control processes across both recipient and subrecipient tiers.
• Reduce the volume of mandatory project closeout documentation requirements for recipients that demonstrate proven, effective internal control controls.

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