

Iowa Department of Homeland Security Iowa Commission on Volunteer ServicesĪnd Emergency Management 1963 Bell Avenue, Suite 200ħ900 Hickman Road, Suite 500 Des Moines, Iowa 50315 Therefore, this appeal is denied.ĭirector National Service Program Officer Regarding the backfill labor costs, FEMA finds that any potentially eligible costs do not meet the minimum project threshold and therefore the total project cost is denied. Therefore, the associated contract costs totaling $46,859.26 are ineligible for PA reimbursement. Additionally, FEMA finds that the Applicant did not demonstrate that the cost related to the deployment of the AmeriCorps personnel was incurred during the performance of eligible emergency work at the food banks.

A project is not eligible if the total dollar value is less than the minimum threshold.

For contracted backfill employees, costs are eligible even if the backfill employee is not performing eligible work if the employee that he or she is replacing is performing eligible emergency work. FEMA establishes a minimum project threshold for each fiscal year. Under the PA program, force account labor incurred in the performance of eligible work may be eligible.The administrative record does not show any agreement or contract between the Applicant and the independent entities that bind the Applicant to reimburse the cost incurred in the AmeriCorps personnel deployment.FEMA provides PA funding for contract costs based on the terms of the contract if an applicant meets federal procurement and contracting requirements.COVID-19 Pandemic: Private Nonprofit Organizations, at 2 COVID-19 Food policy, at 3.The Iowa Department of Homeland Security and Emergency Management (Recipient) transmitted the second appeal explaining that those same agreements allowed FEMA to approve other projects and costs. The Applicant submitted a second appeal stating that the State of Iowa entered into agreements with the food banks for food distribution. Additionally, FEMA stated that the documentation did not support that the employee replaced was performing eligible work. The FEMA Region 7 Regional Administrator denied the appeal stating that the Applicant’s deployment was to Private Nonprofit (PNP) entities not legally responsible for emergency protective measures. Regarding the FAL, it explained that the employee replaced was working on the disaster response. The Applicant appealed explaining that independent entities incurred the contract costs, and it reimbursed the costs.

Finally, FEMA stated that the cost of supplies fell below the minimum project threshold. The backfill labor was considered ineligible for PA because the work performed was not eligible emergency work. FEMA issued a Determination Memorandum denying the expenses because FEMA determined they were not eligible emergency protective measures, but rather increased operating costs. The Iowa Commission on Volunteer Service requested Public Assistance (PA) for expenses related to AmeriCorps personnel deployed to food banks, backfill labor costs, and supplies. The coronavirus (COVID-19) pandemic resulted in a major disaster declaration for the State of Iowa.
