GRANT COMPLIANCE BOOKLET

Last Updated:11/12/2014

INTRODUCTION

This guidebook was created with the intent to provide clarification on the requirements that must be met in order to achieve and/or maintain grant compliance for the Homeland Security Grant Program and other related grants. This guidebook is not an all-inclusive identifier of each component of compliance, but rather a brief overview as to what must be achieved by each agency or jurisdiction, how to achieve the component, and points of contact to obtain additional assistance in obtaining grant compliance. Compliance requirements identified herein are subject to change, as the federal guidance for the Fiscal Year 2015 Homeland Security Grant Program has not yet been released by the Department of Homeland Security. You may feel free to contact the Homeland Security Division of the Heart of Texas Council of Governments’ Homeland Security Division by telephone at (254) 292-1800 or to obtain clarification or additional assistance. Additional compliance resources may also be found online at

Table of Contents

Checklist of Grant Compliance Components

NIMS Compliance

Emergency Management Plans

OMB Circular A-133 Single Audit

Texas Regional Response Network (TRRN)

DUNS, CCR, and FFATA

Criminal History Disposition Reporting

Eligibility Certification Form

Inventory and Tagging

APPENDIX 1: NIMS Implementation Objectives

APPENDIX 2: Sample NIMS Implementation Plan and Policy

APPENDIX 3: 2014 Eligibility Certification Form

APPENDIX 4: Information Bulletin 12-004

APPENDIX 5: Annual Inventory Control Certification

This Page Intentionally Left Blank

Checklist of Grant Compliance Components

The following checklist is designed to assist jurisdictions and agencies in ensuring that all Homeland Security Grant Program compliance metrics have been successfully met and that all appropriate documentation is obtained prior to applying for a grant-funded project under the Homeland Security Grant Program.

NIMS Compliance

NIMS Implementation Objectives (adoption, training, etc.)

Supporting Documentation

NIMS Implementation Survey

Emergency Management Plan (Current, NIMS Compliant, Intermediate Level)

OMB Circular A-133 Single Audit

TRRN

TRRN Account

Data Entry of Grant-Funded Equipment

DUNS, CCR, and FFATA

Criminal History Disposition Reporting

Eligibility Certification Form

Inventory and Tagging


NIMS Compliance

What is NIMS Compliance?

NIMS is the acronym for the National Incident Management System, which is comprised of several components. In order to be NIMS compliant, an agency or jurisdiction must meet several requirements.

  • FY 2010 NIMS Implementation Objectives as illustrated in Appendix 1 must be met. The objectives include components to include, but not limited to:
  • Adoption: The jurisdiction must formally adopt NIMS. This is most often done through a Commissioner’s Court Resolution, City Council Resolution, or other similar document in which the governing council approves.
  • Preparedness:
  • Planning
  • Training (see the recommended training requirements that follows)
  • Exercises
  • Communication and Information Management
  • Resource Management
  • Command and Management

Documentation of the completion of these objectives must be maintained by the jurisdiction or agency. In previous years, the NIMSCAST tool was utilized to record the completion of required NIMS compliance metrics. However, as of 2013, NIMSCAST was discontinued. Currently, the state requires the completion of an annual survey to verify NIMS compliance metric completion.

Who needs to be NIMS Compliant?

All cities and counties mustmeet the NIMS Implementation Objectives to be eligible for Homeland Security Grant Funds. All agencies and departments within the cities and counties must meet the requirements for the city or county to be eligible.

When must I become NIMS Compliant?

NIMS Compliance must be maintained on an ongoing basis. Jurisdictions should incorporate NIMS in all training, exercises, and responses and review such cases in order to improve in their response, command, and coordination of incidents and events.

Why do I need to be NIMS Compliant?

NIMS is not a protocol, procedure, or guideline. NIMS is a standardized incident management system that has been developed through years of experience and lessons learned. The implementation and utilization of NIMS is essential when involving more than one agency or jurisdiction in a response to an incident or event. NIMS is also essential when requesting State or Federal resources for assistance in a response.

How do I become NIMS Compliant?

FY 2010 NIMS Implementation Objectives as illustrated on the chart found in Appendix 1 must be met.

  • Agencies and jurisdictions requiring NIMS adoption must present their governing council with an order or resolution stating that they will fully adopt, implement and utilize NIMS within their agency or jurisdiction.
  • For personnel needing NIMS training, most training is available online. However, there are several classes that require classroom instruction and are available through both the Heart of Texas Council of Governments’ Homeland Security Division and through the Texas Division of Emergency Management.
  • Jurisdictions must maintain a current, NIMS compliant emergency management plan at the Intermediate level. Most cities in the HOTCOG region are under the county plan.
  • Jurisdictions should maintain a NIMS Implementation Policy and Procedure. A template can be found in Appendix 2.

Where can I find resources to assist me in becoming NIMS Compliant?

  • Sample NIMS adoption forms can be found on the Texas Division of Emergency Management website:
  • NIMS Training can be found on the FEMA website:
  • The ICS 300 and 400 courses can be obtained in a classroom setting by contacting the HOTCOG Homeland Security Division at (254) 292-1800 or viewing the website.

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NIMS Training Requirements1
Discipline/Job / IS-1002 / IS-2002 / IS-3002 / IS-4002 / IS-700 / IS-701 / IS-7023 / IS-703 / IS-7044 / IS-800
Responder Level Personnel (All Disciplines) / LP / LP / R / LP / LP / EM
Public Information Officers3 / LP / R / R / LP / EM
Persons with significant resource management role / LP / R / R / LP / EM
Emergency Management Personnel / LP / LP / LP / LP / R / R / LP / R / R
First Line Supervisors (All Disciplines) / LP / LP / R / LP / LP / EM
Mid Managers (All Disciplines) / LP / LP / LP / R / LP / LP / EM
Command Staff (All Disciplines) / LP / LP / LP / LP / R / R / LP / LP / R
General Staff (All Disciplines) / LP / LP / LP / LP / R / R / LP / LP / R
MACC Staff / LP / LP / LP / LP / R / R / R / LP / R
Elected Officials / LP / LP / LP / LP / R / C/G / PIO / R / R
Legend
May not be required (See other disciplines/jobs.)
Required / R
Required as determined by local incident management organizational planning2 / LP
Required if serving as a member of Command or General Staff / C/G
Required if serving as a Public Information Officer / PIO
Required if position has "overall emergency management responsibilities" / EM
1This guidance was compiled from NIMS guidance documents and other FEMA materials. These documents do not clearly delineate which personnel are required to take specific training courses. The recommendations are based upon information contained in the target audience description in the course summaries.
2Course summary within the "Five-Year NIMS Training Plan" states, "It is incumbent upon Federal, State, tribal, and local emergency management/response personnel to determine who within their organizations requires [this] training, based upon local incident management organizational planning." TDEM's NIMS 2010 Compliance Letter, dated 6/30/10, states, "Each jurisdiction that has adopted NIMS is responsible for determining the NIMS training that staff members should complete." Hence, the extension of this category to IS-703 and IS-704.
3Texas Division of Emergency Management guidance, dated 6/30/10, limits this to PIOs "who have successfully completed G-290 - Basic Public Information training provided by the Texas Division of Emergency Management (TDEM)."
4Guidance on the EMI web-site ( clarifies that the primary audience is "Individuals with emergency management responsibilities . . ."This is narrower than the guidance in the Five-Year NIMS Training Plan. This course has been discontinued and will be updated to current standards in the near future.

1

Emergency Management Plans

What are emergency management plans?

Emergency management plans are documents that assist jurisdictions and agencies in preparing for, responding to, and recovering from all-hazards situations. These plans, consisting of a basic plan and supporting annexes, lay the foundation for responding to incidents and disasters of all types. The documents contain pertinent information relating to lines of succession, roles and responsibilities and legal authorization during times of emergency or disaster.

Who needs to have emergency management plans?

In order to be eligible for Homeland Security Grant Funds, all jurisdictions must develop and maintain a current, NIMS compliant emergency management plan. This emergency management plan must be, at a minimum, at the intermediate level of planning. Emergency management plans are most often maintained at the County level; however, jurisdictions should be aware and knowledgeable of their plan and participate in revising the plan accordingly.

When must I submit emergency management plans?

Emergency management plans must be revised, at a minimum, every five years after the last plan date. It is recommended that plans are revised as necessary when changes are made within agencies or jurisdictions to ensure effectiveness of the plan. It is usually much easier to update some annexes each year so that they don’t all become due at the same time.

Why do I need an emergency management plan?

Emergency management plans provide the foundation necessary to respond to all-hazard incidents. These plans assist local emergency responders and managers with the tools necessary to appropriately assess the incident’s impact, respond to outlying issues, and maintain control at the local level.

How do I develop an emergency management plan?

Jurisdictions may obtain plan and annex templates from the Texas Division of Emergency Management website. When developing an emergency management plan, it is essential to incorporate jurisdictional information and capabilities into the plan in order to make it both accurate and effective. For additional assistance in developing a comprehensive emergency management plan, please contact your County Emergency Management Coordinator or the HOTCOG Homeland Security Division.

OMB Circular A-133 Single Audit

Sound financial management practices are a requirement for grant administration and the funding of grant-eligible projects. OMB Circular A-133 requires that any jurisdiction having expended over $500,000 in Federal or State funding, an A-133 audit be obtained. Furthermore, OMB Circular A-133 and the Texas State Administrative Agency requires that the reporting package attained from the audit must be submitted to the Federal Clearinghouse and the Texas Department of Public Safety.

Texas Regional Response Network (TRRN)

The Texas Division of Emergency Management is tasked with administering a program of Comprehensive Emergency Management, designed to reduce the vulnerability of the citizens and communities of this State to damage, to injury, and to loss of life and property by providing a system for the Mitigation of, Preparedness for, Response to and Recovery from natural or man-made disasters. To aid in this task, jurisdictions are encouraged to enter all of their deployable resources in TRRN. The function of the T.R.R.N. web application is to provide a central, web-based system to organize and coordinate resources in response to such incidents.

Jurisdictions and agencies seeking compliance with the requirements of the Homeland Security Grant Program must register as a user of the Texas Regional Response Network (TRRN) and identify all major resources such as vehicles and trailers, equipment costing $5,000 or more and specialized teams/response units equipped and/or trained using grant funds (i.e. hazardous material, decontamination, search and rescue, etc.). This registration is to ensure jurisdictions or organizations are prepared to make grant funded resources available to other jurisdictions through mutual aid.

The registration and log-inpage for TRRN is

Click on the New Provider Application tab in the gray area near the top-left to create a new account. The following point of contact can also assist in account creation and system use:

Dan Walker
Texas Division of Emergency Management
5805 North Lamar Blvd.

Austin, TX 75752
Phone: 512-424-2549
Fax: 512-424-2444

DUNS, CCR, and FFATA

All potential applicants for Homeland Security Grant funds are required to obtain a Dun & Bradstreet number, or a DUNS number. Additionally, jurisdictions are required to create an account on the System for Award Management (SAM) website. Once an account is created, jurisdictions must enter all required information, including FFATA/employee compensation information, into the SAM database. Lastly, jurisdictions must show an active registration status with no “Active Exclusion Records”. The SAM website is found at

Criminal History Disposition Reporting

For the Fiscal Year 2015 Homeland Security Grant Program requirements, all counties must have documented a 90% average disposition completeness rate for adult arrests and a 90% average disposition completeness rate for juvenile arrests for calendar years 2008-2012, as identified in Texas Code of Criminal Procedure, Chapter 60. For cities and agencies within a municipality, your county must show a 90% disposition completeness rate for both adult and juvenile arrests in the 2008-2012 calendar years in order for you to be eligible to receive grants funds under the Homeland Security Grant Program.

Eligibility Certification Form

The Eligibility Certification Form is a document issued by the Texas State Administrative Agency that allows for a jurisdiction or agency that desires to apply for Homeland Security Grant Program funds to document their compliance to the metrics listed throughout the document. Completion of the Eligibility Form is required in order to be identified as compliant with grant compliance metrics. The form itself must be signed by the Chief Elected Official or other Authorized Signatory Agent of the jurisdiction or agency. The 2014 Eligibility Certification Form is depicted in Appendix 3 to this booklet. The 2015 Eligibility Certification Form has not been released by the Texas State Administrative Agency at the time of this book’s completion. Potential applicants for grant-funded projects will be notified of the 2015 form’s release by HOTCOG staff.

Inventory and Tagging

Code of Federal Regulations, Chapter 44, Section 13.32 requires that all Homeland Security Grant Program sub-recipients must follow specific inventory control and asset identification (tagging) procedures. A sub-recipient is any agency or jurisdiction who has received funding for equipment through the Homeland Security Grant Program. The Texas State Administrative Agency has released Information Bulletin 12-004 that clarifies the codified laws surrounding inventory management and asset tagging. Information Bulletin 12-004 is provided in Appendix 4.

44 CFR 13.32 requires that all grant-funded equipment must be documented, in detail, on an inventory control log. This log must contain a description of the asset, the asset’s serial number, the titleholder of the asset, and other such information. This information is detailed in Information Bulletin 12-004 found in Appendix 4. Additionally, all grant-funded capital assets over $5,000 in unit price, as well as all assets having a unique serial number (controlled assets), must be tagged in accordance with Information Bulletin 12-004.

Annually, sub-recipients must complete an Annual Inventory Control Certification form. This form provides the sub-recipient an opportunity to validate existing inventory practices and document compliance with 44 CFR 13.32 and Texas SAA Information Bulletin 12-004. The Annual Inventory Control Certification form is provided in Appendix 5.

APPENDIX 1: NIMS Implementation Objectives

APPENDIX 2: Sample NIMS Implementation Plan and Policy

Section I: General Purpose

The purpose of this policy/procedure is to:

  1. establish and document the minimum National Incident Management System (NIMS) training and documentation requirements for [DEPARTMENT].
  2. establish a single point of contact that will be responsible for implementing all components of the National Incident Management System (NIMS) in a timely manner. This point of contact is responsible for data entry and documentation.
  3. incorporate NIMS into all emergency operations and emergency management plans.

Section II: NIMS Implementation Policy

Departments & Agencies Adhering to this Policy

The [DEPARTMENT] has developed a process to ensure that the NIMS is accurately and effectively implemented. This process identifies the training and exercise requirements, along with the policy for implementing the NIMS.

Training and Exercise

The [DEPARTMENT] has identified the needs of NIMS training and the training levels required for our personnel. Based on the identification of these personnel, the following training and certification procedure is in effect: See attached chart listed as Annex 1.

Training should take place within the following time period based on the date of service, promotion, or change of job duties.

  1. IS 100 -90 days
  2. IS 200 -90 days
  3. IS 300 - one year
  4. IS 400 - one year
  5. IS 700a -90 days
  6. IS 701 -90 days
  7. IS 702 -90 days
  8. IS 703 -90 days
  9. IS 704 - 90 days
  10. IS 705 -90 days
  11. IS 706- 90 days
  12. IS 707 - 90 days
  13. IS 800b - 90 days

When available the [DEPARTMENT] will participate in State, Regional, and local exercises, including Tabletops, Functional and Full-Scale exercises. Exercise participation is contingent upon available resources and funding.

Policy and Planning

The components of NIMS have been implemented into [DEPARTMENT] policies and plans.

  1. COMMON OPERATING PICTURE. A common operating picture is maintained through the use of the Incident Command System, common terminology and plain language.
  2. COMMON TERMINOLOGY. Common terminology is utilized for all incident facilities and positions.
  3. PLAIN LANGUAGE. Plain language shall be utilized in lieu of 10-codes, unless plain language institutes a threat to the safety and well-being of the responder, subjects or bystanders.
  4. PUBLIC INFORMATION SYSTEMS. Public information is coordinated according to NIMS standards. Public Information Officers are utilized to interface with the media. All Public Information Officers are vetted by the [DEPARTMENT] Fire Chief and all press releases authorized by the Incident Commander prior to release.
  5. DOCUMENTATION. Documentation is maintained on all department response activities. Additionally, certificates and training records shall be maintained for all personnel.

Section III: Procedures

The following procedures shall be implemented, effective immediately upon approval of this implementation procedure.

  1. [Department] NIMS Point of Contact (POC)
  2. The [DEPARTMENT] Fire Chief shall appoint, in writing, an agency NIMS Point of Contact (POC) for NIMS implementation.
  3. [DEPARTMENT] NIMS POC identified in this policy is responsible for NIMS implementation and record keeping within the department.
  4. The NIMS Point of Contact’s information shall be kept current and all changes shall be documented immediately upon modification of POC or POC information.
  5. The [DEPARTMENT] NIMS POC will research and inform all necessary personnel of changes in training requirements.
  1. Training Compliance and Documentation of NIMS
  2. Training shall be completed by all personnel in accordance with the requirements defined in Annex 1 of this procedure.
  3. Documentation of NIMS certificates and training required by this policy and procedure shall be maintained by the NIMS POC.

Section IV: Approval