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2. Under the rules in place until the 2012 grant cycle no money can be spent from Port Security Grants without the direct involvement of a single point of contact – often one person -- representing the Fiduciary Agent. That person is responsible to channel all communication, modifi cations, applications, requests for extensions, grant modifi cations and Environmental and His- torical Preservation documentation from the subgrantees to the single FEMA Program Analyst (PA) assigned to the security re- gion. 3. The FA can draw up to 5% of the total value of the grants as compensation. But the FA earns that money in part by fi ling at least six reports a year for each grant. 4. FEMA disciplines the FA by refusing to even consider re- quests for extensions or reprogramming, disbursal or other ac- tions critical to the port security needs of the region when the FA fails to fi le timely reports. 5. So if the POC for the FA screws up the paperwork, it doesn’t matter how diligent the subgrantee ports and terminals are in the region. It doesn’t matter how much the safety and security of their facilities require the support of FEMA grants. If the FA has not shuffl ed the papers correctly and on time, sub-grantees don’t get a hearing at FEMA when they want an extension or a modifi - cation of their grant. The Risk of FA Failure The FedReg says: “Upon receipt of the grantee’s request, the FEMA PA verifi es compliance with fi nancial reporting require- ments by confi rming that the grantee has submitted all necessary Federal Financial and Programmatic Reports (SF-425s and CAPRs/ SAPRs).” And, that is mouthful. It means that the Program Administrator at FEMA will not even begin to double check whether the FA/POC has fi led correctly all fi nancial reports until after the request for an extension (beyond Sep. 2012) has been submitted. That deadline for fi ling was April 30, 2012 with FEMA reserving the right to extend the fi ling dead- line. But FEMA warns that the written request for extension “will be granted only due to compelling legal, policy, or operational chal- lenges.” All Photos: Rick Ey erdam MP #2 18-33 NEW STYLES.indd 19 5/4/2012 5:00:44 PM
