What steps should a community applying for funding under the FEMA Hazard Mitigation Assistance Programs (HMGP, BRIC, FMA, and PDM) take in preparation for application?

The Federal Emergency Management Agency’s (“FEMA”) Hazard Mitigation Assistance (“HMA”) programs fund eligible mitigation measures to reduce disaster losses. Within FEMA, there are presently at least four mitigation programs that interested jurisdictions can apply to:

• Hazard Mitigation Grant Program (“HMGP”);
• Building Resilient Infrastructure and Communities (“BRIC”);
• Flood Mitigation Assistance (“FMA”); and
• Pre-Disaster Mitigation (“PDM”)

With respect to the nationally competitive programs (BRIC and FMA), jurisdictions are encouraged to review the Notice of Funding Opportunities (“NOFO”) for application requirements specific to each fiscal year.[1] The NOFOs for BRIC and FMA are typically released each year in August. The PDM program was revived in fiscal year 2022 as appropriations to 68 congressionally directed projects. Only these projects were eligible to submit sub-applications for PDM funding.[2] At this time, FEMA has indicated that PDM funding will be available annually.

HMGP is available when authorized under a presidentially declared major disaster. States then issue a NOFO to alert jurisdictions of available funding. States generally have one year after the disaster declaration to submit HMGP subapplications to FEMA. 

For all FEMA HMA programs, eligible jurisdictions apply as subapplicants[3] through a state, territory, or federally recognized tribe. The state, territory, or federally recognized tribe is the applicant and pass-through entity. The applicants review, approve, and prioritize subapplications before they are submitted to FEMA for federal review and approval. Jurisdictions interested in applying are encouraged to reach out to their State or Tribal Hazard Mitigation Officer to learn about mitigation priorities, application processes and deadlines, and upcoming webinars and workshops.[4]

The following list addresses the steps a municipality may consider taking in applying for any of the FEMA HMA programs, among other things:

HMGP

1. Be aware of available HMGP following a major disaster declaration

The amount of HMGP funding available varies by disaster. Applicants (e.g., states, territories, and tribes) mayhost a briefing or a kick-off workshop to let potential subapplicants know of available funds and state priorities. Following a major disaster declaration, jurisdictions are encouraged to sign up for state email notifications, establish a point of contact with their state emergency management office, and review the state issued NOFO, if one is released.

2. Review application process requirements and deadlines

Each individual state, territory, and tribe is responsible for setting up the process to receive and review subapplications for its HMGP funding ceiling. Subapplicants are responsible for adhering to the state deadlines and application process. This process may include, but is not limited to:

• A Notice of Interest (“NOI”), Letter of Intent (“LOI”), or pre-application that provides preliminary information about a subapplicant’s project. States use this document to check for eligibility and alignment with state priorities, and to set the overall budget for the available HMGP funds.
  • This document may require a tight turnaround deadline after the declaration. States will notify those entities whose NOI/LOI/pre-applications were selected when it is time to move forward with a subapplication.
• Each state develops their own HMGP application and the process by which it is submitted to the state. Some states use online grant management systems to receive subapplications and others require PDF or printed versions that are then submitted via email or other electronic means.
  • Some states require physical copies of subapplications be mailed to the state office. Interested subapplicants must pay close attention to their state’s process and allow enough time to meet those requirements.
• Each state, territory, or tribe establishes its own deadlines for HMGP subapplications. Typically, these deadlines are set two to three months before subapplications are due to FEMA to allow the state enough time to review subapplications and issue a Request for Information (“RFI”) if needed.
• The state will issue RFIs if a subapplication is incomplete or does not meet the state or FEMA documentation requirements. Subapplicants must respond to these RFIs as quickly and as completely as possible to minimize future RFIs. 

3. Understand the state mitigation funding priorities for each presidential major disaster declaration and submit projects that align with those priorities

States, territories, and tribes with HMGP funds typically establish specific funding priorities. Many states will prioritize the jurisdictions that were impacted by the disaster. States may also prioritize projects that address the type of hazard that caused the major disaster declaration. For example, if the disaster declaration was the result of wildfires, the state may prioritize projects that address wildfire mitigation, such as soil stabilization in burn scars or vegetation management.

State project priorities can include but are not limited to the following types of projects: 

• Projects that will benefit communities with high social, economic, and/or environmental vulnerability
• Projects that incorporate climate adaptive solutions or nature-based approaches
• Projects that will benefit a whole community rather than only a small portion of the community
• Projects that address critical infrastructure
• Projects that address one of the critical hazards in the state

Please note that these priorities may change for each individual disaster declaration. Jurisdictions must pay attention to the State-issued NOFO for HMGP funds when this funding is available. 

 BRIC and FMA

1. Review the August 2022 Notices of Funding Opportunity (NOFOs)[5]

FEMA released its most recent NOFOs for the BRIC and FMA programs on August 12, 2022. These NOFOs outline important funding information such as:

• The date the application period opens and the FEMA deadlines to submit applications
• Available funding under state allocations, tribal set-aside, and national competition
• The funding priorities and how project applications for competitive funding will be scored and prioritized
• Other administrative information pertaining to the grants

2. Attend FEMA and State sponsored webinars

To supplement the release of the NOFOs, FEMA hosted a series of webinars in the last two years to review key components of the funding programs.[6]

In addition to the FEMA webinars, many states host webinars to review the NOFOs with interested jurisdictions. These webinars provide a chance for potential subapplicants to become acquainted with the state team managing the FEMA mitigation programs and establish points of contact to discuss project ideas. States may also discuss requirements and deadlines specific to their state.

3. Be aware of state subapplication requirements and register in FEMA Grants Outcomes (“FEMA GO”) Management System

As with HMGP, many states set subapplication deadlines well before the FEMA application deadline. The deadline for NOIs for FEMA funding is typically early in the application process — in some cases, within one month from when FEMA releases the NOFO.

As soon as the state approves a subapplicant’s NOI, the subapplicant must register in the FEMA GO grants management system.[7] FEMA GO is a system utilized to receive, review, and approve both BRIC and FMA applications. States will often request that subapplicants start drafting their subapplications in FEMA GO as soon as possible as there may be troubleshooting required when first registering in the system.

The subapplication process for BRIC and FMA is more expedited than the subapplication process for HMGP. Several states set deadlines for submission to the state in late November or early December. This provides states enough time to review the subapplications for eligibility, competitiveness, and completeness before submitting the state application packets (i.e., all subapplications plus the state management cost subapplication) to FEMA. As with HMGP, the state will issue RFIs when necessary to submit eligible and complete subapplications.

4. Obtain a Unique Entity Identifier (UEI) if the municipality does not have a pre-existing UEI 

The federal government transitioned from the Data Universal Numbering System (DUNS)[8] to the UEI as the official entity identifier in April 2022.[9] In order to apply for BRIC and FMA grants, a jurisdiction must obtain a UEI. This process may take several weeks, so starting early is recommended.

Some other key considerations for each program are as follows:

BRIC

• The BRIC program allots technical criteria points to subapplicants with a Building Code Effectiveness Grading Schedule (“BCEGS”) rating between one and five.[10] If a jurisdiction is interested in applying for BRIC, it should obtain its BCEGS rating as soon as possible. Interested parties should reach out to the municipal or county building department to ask if one has been completed for the jurisdiction. If not, the community may contact the BCEGS Program Manager, Dale Thomure, at Dale.Thomure [at] verisk.com (Dale[dot]Thomure[at]verisk[dot]com).
• Jurisdictions interested in applying for the Capability and Capacity Building funds must contact their State Hazard Mitigation Officer to discuss the state’s priorities for the state allocation dollars ($2 million in fiscal year 2022). For example, many states will choose to put all allocation dollars towards a particular activity type (e.g., project scoping) or a single subapplication. The state allocation funding is limited and tend to be very competitive.  
• Jurisdictions must understand and address FEMA’s Technical and Qualitative Evaluation Criteria in their subapplication narratives to be competitive for BRIC funding.[11] Subapplications that fail to meet these criteria will likely not be selected to receive BRIC funding.

FMA

• To be competitive for the FMA funding, subapplicants must protect Repetitive Loss (“RL”) and Severe Repetitive Loss (“SRL”) properties. It is critical for jurisdictions applying for this funding to obtain the RL and SRL data as soon as possible and crosscheck the data with National Flood Insurance Program (“NFIP”) policy claims information. FEMA currently utilizes the NFIP PIVOT system to store NFIP claims information.[12]
• For Individual Mitigation Projects (e.g., property acquisitions, structure elevations, mitigation reconstruction), jurisdictions are encouraged to conduct community outreach early to gauge property owner interest. This outreach can be conducted prior to the release of the FEMA announcement. In some cases, jurisdictions with high rates of RL and SRL properties conduct outreach to property owners throughout the year to ensure they have an up-to-date list of interested property owners ready for a subapplication.
• Similarly, jurisdictions preparing subapplications with large numbers of properties are encouraged to build an in-house team or procure professional services to assist with property owner data collection and management.

General Good Practices  

The following are general good practices when developing a FEMA mitigation subapplication under all HMA programs (HMGP, BRIC, FMA, and PDM)

1. Utilize and Request Pre-Award Costs

Pre-award costs are a mechanism in the FEMA HMA programs that allow subapplicants to incur costs before FEMA has issued an award. These are soft costs needed to prepare a complete subapplication packet and may include costs for activities including: design and engineering, environmental and historic studies and data collection, community outreach, and subapplication and BCA preparation. No groundbreaking may take place before award so pre-award costs are constrained to the technical body of work needed to support the subapplication. A subapplicant requests pre-award costs by including them as a line item within their subapplication cost estimate. The activities listed above may require support from contractors, and subapplicants are encouraged to begin the procurement process early if they anticipate requiring assistance to develop these materials.

To be eligible for reimbursement, should the project be awarded, any procured services for pre-award activities must comply with 2 CFR Part 200.[13] If using in-house staff to complete these activities, subapplicants are encouraged to keep a robust accounting of staff hours and tasks completed. Importantly, because pre-award costs are incurred prior to FEMA award, these costs are incurred at the subapplicant’s risk. If FEMA does not award the project, these costs will not be reimbursed.

2. Frontload Environmental and Historic Preservation (“EHP”)  

It is important in the early stages of project identification and development to identify any EHP concerns or questions that may impact project approval by FEMA or project implementation. These are important considerations during the project development stage, as EHP compliance requirements may:

• impose time and cost implications for the project;
• include additional award conditions imposed by FEMA; or
• require the subapplicant to consider alternatives, identify alternate locations, and other project modifications.[14]

Subapplicants are urged to conduct environmental planning and historic preservation tasks prior to award (utilizing pre-award costs as discussed above). This may include consultations with various local, state, and federal agencies, as well as interested parties, to gauge what, if any, impacts the project may have on environmental, historical, and cultural resources. The consultations and data collection must inform the project scope of work, budget, and schedule and the resulting documentation should be included in the subapplication packet.

This data collection and consultation process is helpful in two ways:

• creates a more thorough project subapplication with increased viability for implementation; and
• assists in expediting FEMA’s EHP review and the award timeline for the project.

3. Phasing Projects

Another mechanism available under the FEMA HMA programs is project phasing. This mechanism is available in situations where a subapplicant does not have the technical or financial resources to provide the complete technical body of work needed for the state and FEMA to perform a complete eligibility, feasibility, and EHP review. Phasing allows a subapplicant to submit a whole project (engineering/design through construction) as one subapplication, but the funding is awarded in two parts. The project is split into two phases as described below.  

• Phase I typically includes:
  • Finalization of feasibility studies
  • Advanced design and engineering studies
  • Reassessment of the benefit-cost analysis (“BCA”)
  • Project site data collection. For example, if the project involves individual property retrofits, data on each structure may be collected during Phase I. 
  • Collection and finalization of EHP data and consultation. The project must meet EHP requirements before Phase II approval.
• Phase II is only awarded if the Phase I studies demonstrate that the project is eligible, technically feasible, cost-effective, and compliant with EHP regulations. Phase II consists of project implementation including:
  • construction;
  • project monitoring and inspections; and
  • project closeout.

Last Updated: March 16, 2023