Science Support

IM DRRA 2019-01

No: IM DRRA 2019-01

Issuance Date: 10/02/19

Expiration Date: Retain Until Cancelled  

Subject: 2018 and 2019 Disaster Relief Supplemental Appropriations and Bureau Governance and Reporting Policy

Instruction: This replaces IM DRRA 2018-01 dated July 13, 2018, for the management of the Disaster Relief Requirements Act with no significant revisions to instructions for those funds.

 

1. Purpose. This Instructional Memorandum (IM) updates the policies and procedures U.S. Geological Survey (USGS) Science and Cost Centers (Centers) must follow when using supplemental funding from the Disaster Relief Requirements Act (DRRA of 2018); extends existing requirements to new supplemental funds from the Additional Supplemental Appropriations for Disaster Relief Act (ASADRA of 2019); and describes internal controls for Bureau oversight and reporting, special overhead rates, limitations on expenditures, and special requirements for establishing accounts and awarding grants.

2. Background. Public Law 115-123, Division B, Subdivision 1— Further Additional Supplemental Appropriations for Disaster Relief Requirements Act, 2018 (H.R. 1892 - Bipartisan Budget Act of 2018, signed into law by the President on February 9, 2018), appropriated $42,246,000 to the USGS, for necessary expenses related to the consequences of Hurricanes Harvey, Irma, and Maria, and in those areas impacted by a major disaster declared pursuant to the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5121 et seq.) with respect to wildfires in 2017.

Public Law 116-20, (H.R. 2157, Additional Supplemental Appropriations for Disaster Relief Act, 2019, signed into law by the President on June 6, 2019), appropriated $98,500,000 to the USGS, for necessary expenses related to the consequences of Hurricanes Florence and Michael, and calendar year 2018 wildfires, earthquake damage associated with emergency declaration EM–3410, and in those areas impacted by a major disaster declared pursuant to the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5121 et seq.) with respect to calendar year 2018 wildfires or volcanic eruptions. Of this amount, $72,310,000 is allotted for costs related to the repair and replacement of equipment and facilities damaged by disasters in 2018.

3. Timelines.

A. General. Funds provided to the USGS by the DRRA and ASADRA are no-year. In accordance with Financial Operating Procedures (FOP) Chapter 9, Section 1, subsection 3 Part B, the Period of Availability does not expire. The no-year funds are available for incurring obligations for an indefinite period, usually until the objectives have been accomplished. The Office of Management and Budget (OMB) or Department of the Interior (DOI) may cancel no-year authority under certain circumstances.

OMB and DOI expect the USGS to obligate funds within periods specified by the approved operating plan, which ranges from two to five years. Centers may request additional time by submitting a waiver request via email to the lead Science Coordinator and Senior Program Advisor in the USGS governance group. Extension requests must include clear justifications explaining the reason(s) for delays and identification of new timelines. These officials determine if additional approvals or notifications are required for the DOI, and they will notify the requestor whether approval is granted. Requests will not be automatically granted.

B. Grants. Grantees must fully expend grant funds from the 2018 and 2019 supplementals within the 24-month period following the agency’s obligation of those funds, unless waived by the Director of the OMB or other designated oversight bodies (refer to Section 9 below).

C. Approved Spending Dates. All projects may apply supplemental funds to relevant obligations beginning from the date that Congress approved funding (i.e., Centers may use funds from the ASADRA of 2019 for work beginning on or after June 6, 2019, and funds from the DRRA of 2018 for work beginning on or after February 9, 2018).

In some limited cases, supplemental funds may be applied to obligations made prior to the date of the authorizing bill. These exceptions will be permitted if: 1) they are in the same fiscal year as the authorizing legislation, and either 2) they are included in the Bureau’s supplemental operating plan approved by the DOI, or 3) if written approval has been granted from the Supplemental Oversight Team (SOT) Science Coordinator or Senior Program Advisor, who will coordinate any necessary communication or approvals from the DOI.

4. Responsibilities. The Deputy Secretary of the DOI and the OMB approved spending levels and projects outlined in the USGS supplemental operating plan for various supplemental funded projects, in April 2018 for the DRRA of 2018, and in July 2019 for the ASADRA of 2019. The Acts require agencies to submit an operating plan and monthly reports to the Committees on Appropriations of the House of Representatives and the Senate detailing the allocation and obligation of these funds by account.

The ASADRA of 2019 requires the USGS to submit a report to the Committees on Appropriations that describes the potential options to replace the facility damaged by the 2018 volcano disaster along with cost estimates and a description of how the USGS will provide direct access for monitoring volcanic activity and the potential threat to at-risk communities. The USGS will provide a list of accounts to the DOI Office of Policy, Management and Budget (PMB), which will centrally pull financial updates from DOI’s Financial and Business Management System (FBMS) for this requirement, and coordinate with the DOI on other reporting requirements. In addition, the USGS will develop other requirements for reporting on progress.

Within the USGS, the Hazard Response Executive Committee (HREC), chaired by the USGS Deputy Director and Associate Director for Natural Hazards, is responsible for oversight of projects conducted with supplemental funding. The HREC has established the SOT to maintain strong internal controls, oversee project work, coordinate communications, manage risk, monitor progress, and meet all tracking and reporting requirements established by the USGS, DOI, OMB, or other Executive or Legislative authorities. The SOT will coordinate with the USGS Office of Management Services and the Office of the Regional Director for the Alaska Region, as these offices have the primary responsibility for reporting on the construction of the Hawaiian Volcano Observatory.

Members and Roles for the Supplemental Oversight Team (SOT) are as follows:

A Science Coordinator will serve within the Natural Hazards Mission Area (NHMA) as the SOT lead, to work closely with senior level staff assigned by the Associate Director for the NHMA to provide briefings as necessary for DOI, OMB, other oversight agencies and partners, and Congress. The SOT Science Coordinator has the primary responsibility of organizing and managing the daily operations of the SOT to effectively achieve all its goals and objectives. In addition, this lead will coordinate with: Project leads to obtain science and administrative resources and support; Mission Areas to support Centers receiving supplemental funds; support staff to ensure that reporting is timely and accurate and reaches appropriate stakeholders.

A Senior Program Advisor from NHMA will support the SOT lead by managing project tracking, responding to reporting requirements, establishing operational policies, providing direction and guidance to program leads, and advising on legal, policy, financial, and formulation matters. The Senior Program Advisor will be assisted by a senior financial analyst to track BASIS+ and FBMS entries for the project work, monitor execution, assist with budget formulation and reporting, develop tracking systems for supplemental and related funding augmentations, while providing regular updates, guidance and advice to the Senior Program Advisor and Science Coordinator. These functions will coordinate with the USGS Office of Budget, Planning and Integration (OBPI) and Office of Administration (OA) to meet reporting requirements and establish and implement financial monitoring policies.

Each project will include an individual to serve as the SOT point of contact (SOT POC) for reporting on all activities, updates, and potential issues or concerns regarding projects falling within their boundaries. SOT POCs are responsible for monitoring projects from beginning to end and alerting the SOT lead, and identifying issues relating to project progress, timeliness of contract awards, reporting, communication with stakeholders, or other operational concerns. The POC will identify any technical expertise needed for coordinating efforts between Centers. SOT POCs will coordinate with each other and Regional Liaisons on identifying priority geographic areas for work, joint theme activities, and identifying products that span themes and geographic areas. SOT POCs will work with Centers to identify science implementers, provide staffing suggestions and other resources necessary to complete projects, and ensure that necessary products are delivered in a timely manner.

Projects are expected to meet and report progress on milestones identified in their approved spend plans. Achievements or anticipated delays should be reported through the SOT POC. Changes in timelines or milestones for spending plans must be submitted to the SOT Science Coordinator and SOT POC for notification and approval. The SOT Science Coordinator will determine if a change requires DOI notification. 

The SOT will establish reporting crosswalks, and track funding and costs for each project to meet DOI reporting requirements. Financial reporting transparency and milestone tracking will determine reporting requirements throughout the duration of the projects. In addition, the USGS will provide updates to the DOI and OMB on work progress and accomplishments.

SOT POCs will consult with project leads to ensure that projects are on track, monitor major milestones and report them on various timelines dependent on DOI and external oversight bodies, which may include weekly, monthly, quarterly, annually, or ad hoc deadlines. The SOT POCs will work with the SOT management team and the OA to ensure accountability for internal controls, reporting improper payments, and accounting for grant expenditures. The Office of Communications and Publishing (OCAP) liaisons will ensure Bureau and departmental communication expectations are met. SOT POCs will work with OCAP to ensure a coordinated and consistent message. 

5.  Recording and Tracking Costs in FBMS and BASIS+. Outlined below are details for tracking the supplemental funds in FBMS and in BASIS+. This structure ensures that the USGS will meet the detailed DOI reporting requirements.

A. FBMS Allocation Organization and Cost Centers. The SOT will distribute supplemental funding via initial allocations and then change of allocation when needed. Included in the initial allocation will be the name and project number so that detailed tracking can take place to determine which centers received funds within each project (see the BASIS+ Projects section below). Program Coordinators or those responsible for allocating these funds enter the allocation into BASIS+ using the New Initial Allocation page and Change of Allocation page for changes. 

(1) Treasury Account Symbol (TAS): 14X0804

(2) FBMS Fund Code:18XG0804XH for DRRA of 2018 supplemental funds, 19XG0804XH for ASADRA of 2019 supplemental funds

B. BASIS+ Projects, Tasks and Subtasks. DOI tracks progress using crosswalks to Work Breakdown Structures (WBS). To ensure consistency and completeness, the SOT senior financial analyst will create projects in BASIS+ and provide a list of the WBS accounts for the DOI. Project and task leads will be responsible for entering required data elements into these pre-established projects. 

The SOT senior financial analyst will work with the Administrative Officers (AOs) to create WBS prior to issuing allocations.

As with all no-year funds, supplemental spending is tracked by the source year of the appropriation (i.e., FY 2018 and FY 2019). Due to this requirement, the fiscal year of all WBS accounts tied to supplemental funds must match the respective appropriation year (i.e. all 2019 supplemental funds must be ‘GX19X…’ accounts, and similarly with 2018 WBS). The SOT has coordinated in advance with Centers to create these accounts. If additional accounts or sub accounts are needed for Centers, approval must be obtained from the SOT POC and SOT Senior Program Advisor.

6.  Bureau Management Assessment and Center Burden.

A. Bureau Assessment. The Bureau will assess projects three percent of total funding to support USGS management and oversight of the supplemental funds and administer these funds in accounts held by the Office of the Associate Director for Natural Hazards. These funds will cover SOT and Bureau oversight activities, administrative and communication support, and outreach material. 

B. Center Burden. Administrative and support activities are defined as temporary, discrete, unique, and severable costs associated with management, oversight, and execution of projects. Applicable administrative costs are non-severable in support of the project activity. These would include the following costs:

(1) Administrative support for: (a) contract management; (b) travel arrangements; (c) account management such as account creation, funding transfers, expenditure adjustments, reconciliation and tracking; and (d) human resources related activities.

(2) Center management support for: (a) project and task management; and (b) meeting with cooperators to discuss project activities and products.

C. Burden Rates.  

In general, centers are authorized to assess the lesser figure of either:

a) their regular rate or

b) 20 percent.

Center burden accounts provide for indirect costs for invoice processing and approvals, vendor relations, increased personnel and personnel actions, and project related expense reconciliation. If a center’s normal rate is below this threshold, the standard rate should be utilized.

Exceptions to the above rule include the following:

a) Center rates will not be assessed for lidar acquisition. Non-severable administrative costs and project operational costs must be directly charged to project accounts since a much larger portion of funds will be placed directly on contracts rather than internal labor costs. 

b) For the ASADRA of 2019 funds, center rates will not be assessed for construction of the Hawaiian Volcano Observatory, as support costs are direct costs of the project.

c) For the DRRA of 2018, funds tied to seismic and geomagnetic monitoring assets repairs and replacements, centers are authorized to assess a six percent rate for center common services, and a lower rate of three percent for equipment purchases.

If funded center overhead (COM) accounts are insufficient to cover indirect administrative costs associated with the funding received within a specific center, centers are authorized to direct charge the relevant project accounts. Direct costs are defined as costs that are non-severable from the project activity and include administrative and center management support. Centers must maintain sufficient documentation to justify administrative direct costs to respond to any inquiries from the USGS, DOI, the Office of Inspector General, or others.  

D. Funding Center COM Accounts. To tie supplemental overhead funding to DOI reporting crosswalks, centers will be required to create and maintain separate COM accounts for each project. In some cases, centers will be required to establish separate COM accounts for each task where needed for DOI crosswalks. The SOT senior financial analyst will work with center AOs to establish these accounts.

For these centers, task accounts should be funded with no burden. Separate COM accounts must be set up under each applicable task (i.e., if a center has three tasks, they must have three COM accounts). Each COM account should then be directly funded based on the percentages outlined above. 

To fund the COM, fill in the following fields in the ‘New Fund Source’ screen in BASIS+:

Customer Class: Direct (SIR)

Status: Leave as High

$ Gross Funding: (Calculate manually based on the gross allocation)

Cost Center Burden Rate: 0 (center rate will automatically populate – zero this out)

Reduced Rate: Yes

After you have saved, click on the ‘Update funding in FBMS’ button, click ‘yes,’ and then ‘update.’

7.  Projects – Direct Charging of Expenditures and Obligations.

A. Expenditure Transactions. Centers authorized to receive supplemental funding will record payments (expenditures) against the specific account assigned to that project. If Centers are processing expenditure adjustments into or out of supplemental WBS elements, do not “lump” or consolidate multiple transactions into one transaction. Separate expenditure adjustments must be entered at the 4-digit Budget Object Classification Codes (BOC) to ensure accuracy in reporting with any potential audits related to these funds.

B. Requisition Preparation. Centers involved with supplemental projects will prepare their requisitions for processing. The words “Disaster Recovery Requirements Act Funds” must be included on the header of the requisition and “DRRA” must be included in the line item short text field in FBMS.

C. New and Modified Obligations. New and modified obligations can be direct charged to the assigned project account. If obligations are established using both supplemental and non-supplemental funds, both lines of accounting must be referenced in the purchase request and the award, including modifications to existing contract awards.

D. Documentation. As expenditures and obligations are made against supplemental funds, Centers will need to keep detailed records of all transactions to support potential audits of these funds. Supporting documentation may include details about salary-related costs and what was done to support the project, travel vouchers, details about why certain administrative costs were charged directly to the supplemental project, copies of contracts obligated under these funds, and details about expenditure movements made within the supplemental WBS elements.

E. Authorized Leave Costs. Leave charged to supplemental funds is allowable for: 1) new staff brought on specifically for supplemental project work, and 2) staff funded by and dedicated primarily to supplemental project work. Leave time that is charged to supplemental funds should not exceed leave time earned through supplemental funds (i.e., an employee that accrued five days leave but requests eight days leave may charge up to five days leave to supplemental funds, and the balance of three days leave must be charged to non-supplemental accounts).  

F. Performance Awards. Performance awards or incentives may not be paid using supplemental funds.

8.  Milestone Tracking. The SOT will track progress toward project completion. It is important to enter detailed products, completion status, and outcomes in the BASIS+ project/task structure so that milestone reporting can be facilitated centrally as much as possible. The SOT leadership will issue additional periodic progress data calls when needed for inquiries from the OMB, DOI, or others. SOT POCs work with the Project and Task Leads as necessary to collect the requested information.

9.  Internal Controls and Grant Expenditures. OMB guidance, Implementation of Internal Controls and Grant Expenditures for the Disaster – Related Appropriations, M-18-14, requires agencies to design internal control plans, and report improper payments and accounting for grant expenditures for applicable funding of 2018 supplemental funds. OMB guidance for disaster relief funding stipulates that agencies identify and document incremental risks and mitigating controls, implement improper payments controls, document linkages between risks related to disaster and emergency funding and efforts to address known internal control risks. This IM extends the requirement to 2019 supplemental funds.

For grants, agencies must ensure that grantees expend all awarded disaster relief funds within the 24-month period following the agency’s obligation of those funds, unless waived by the OMB and other required oversight bodies. To meet this statutory requirement, awards must specify criteria for approval of grant applications or proposed plans for the use of grant funds and ensure each proposed grant activity has clear timelines for completion within the period available for grantee expenditure. While some requests for waivers may be approved to extend expenditure periods, requests will be limited to only those activities that are long-term by design or where it is impracticable to expend funds within the 24-month period and still achieve program missions.

Accordingly, the period of performance (POP) for grants funded by the 2018 and 2019 supplementals may not exceed 24 months without the required approvals. Funds must be expended by the end of the POP or must be returned to the awarding agency. Grant term and conditions funded by the supplementals must include the following statement: “Grant funds not expended by the end of the POP must be returned to the awarding agency.” The OMB will grant waivers only on a case-by-case basis, where such requests are justified by compelling legal, policy, or operational challenges and consistent with applicable laws. To ensure sufficient time for approvals, requests to extend obligations beyond the 24-month period should be submitted to the SOT Science Coordinator by email, at least 6 months before the end date of the grant’s period of performance.

 

/s/ Katherine M. McCulloch                                                       10/02/19

___________________________________                          ___________
Katherine M. McCulloch                                                             Date
Associate Director for Administration