Emergency Mental Health and
Traumatic Stress

Fiscal Guidelines for the Crisis Counseling Assistance and Training Program

Note: This is the sixth in a series of program guidance documents developed to ensure consistency in addressing key program issues in the Crisis Counseling Training and Assistance Program (CCP). The Crisis Counseling Training and Assistance Program is funded by the Federal Emergency Management Agency (FEMA) under the authority of the Robert T. Stafford Disaster Relief and Emergency Assistance Act. On behalf of FEMA, the Center for Mental Health Services (CMHS), Emergency Services and Disaster Relief Branch (ESDRB) provides technical assistance, program guidance and oversight.

Purpose
This program guidance is intended to assist local and State provider agencies in the preparation of budget requests and in the fiscal monitoring of immediate and regular service grant CCP programs. This guidance is intended to be used in conjunction with the more detailed application instructions, FEMA and PHS/DHHS regulations, and grants policy statements. Five key concepts are discussed:

• Terms and Conditions of Support
• Allowable and Non-allowable Costs
• Transfer of Funds
• Post Award Administration of Funds
• Reporting Requirements

I Terms and Conditions of Support
Requested funds must supplement, not supplant, existing local or State resources.

Following a disaster event an assessment of needs must be undertaken by the State and local mental health agencies. State and local resources must be considered first in order to meet the needs assessed. A compelling case must be made that needs are greater than existing resources.

Most programs rely heavily on newly hired staff with some involvement of existing State and local staff. On-going service demands often preclude the extensive use of existing staff. CCP funds may not be used to supplant existing services.

Local and State Contributions are expected. These are often in-kind resources.

Currently there are no State or local government matching funds requirements. However, regulations require the " identification of the resources the State and local governments will commit to both services and training..." Examples of in-kind resources include: personnel; equipment such as computers, printers, telephone lines, mobile telephones and pagers; office and meeting space; overhead or administrative costs; transportation; advertising and public service announcements. Other donated contributions from community groups such as meals, food for program related meetings or refreshments for support groups should be described but dollar amounts are not required. The CCP is a supplemental program; therefore, it is important that the State include in the budget all costs to be absorbed by the State and local provider.

II Allowable and Non-allowable Costs
Budgets must be detailed and justify costs that are appropriate, allowable, and reasonable.

All budget requests should be detailed for each agency or service provider requesting Federal funding for the program. Costs should be consistent with the findings of the needs assessment and objectives described in the program plan.

The budget must be categorized and detailed with itemized dollar amounts. A narrative justification should accompany the budget. Separate budgets must be included for each agency/service provider. The State oversees the development of the application and insures consistency among counties or regional areas. Variables that can significantly impact the cost of a program include: severity of the disaster; number of disaster survivors; availability of local resources; cultural diversity; linguistic needs; salary levels of counselors; and geographic area to be covered.

The following categories will detail appropriate, allowable, and reasonable costs, as well as describe, inappropriate, and typical in-kind contributions. DHHS/FEMA is not required to approve all allowable costs and has the discretion to elect not to fund any allowable cost items if it is determined they are not appropriate, reasonable or beyond State resources. (See Attachment A for the Summary Table outlining fundable and non-fundable expenses)

PERSONNEL/SALARY AND WAGES: Salary and wages are based on current levels paid by State and local providers for similar skill levels. The number of personnel or full time equivalents (FTEs), percentage of time dedicated to the project and hourly or monthly rate for each staff category (e.g., Program Coordinator, Team Leader, Crisis Counselor/ Outreach Worker, Administrative Assistant) should be detailed. Salary, wages, and fringe benefits are generally the largest portion of the budget.

Appropriate expenses include crisis counselors/outreach workers to provide direct services to disaster-impacted residents; managers or supervisors of crisis counseling staff at State and local levels; and, administrative and fiscal support staff. Staffing should be proportional to the size of the disaster and be internally consistent when there are multiple local providers.

Inappropriate expenses include mental health professionals providing long-term, more formal mental health or substance abuse treatment services such as diagnostic testing and therapy; and, reimbursement for uncollected revenue. For example, if mental health workers respond to a disaster, resulting in fewer Medicaid billings, the State should not expect to be reimbursed for lost Medicaid billings from crisis counseling funds. Costs to support mutual aid and overtime rates will be reviewed on a case by case basis.

In-kind contributions include salary and wages of existing State and local staff such as the State disaster mental health coordinator and local area provider agency managers who dedicate a percentage of time to the crisis counseling program in addition to their existing duties.

FRINGE BENEFITS: Established State and local personnel policies and fringe benefits rates should be followed. Temporary and part-time employees may or may not be eligible for all or some fringe benefits.

Appropriate expenses include the existing fringe benefit policies which are the usual and customary costs for personnel at the State and local level.

Inappropriate expenses include costs beyond the usual and customary for personnel at the State or local level.

CONSULTANTS: Consultants are used to provide technical assistance and consultation to State and local project staff on program development and/or management of a project. CMHS Project Officers will identify experienced disaster mental health personnel from other experienced State and local departments of mental health that have implemented Crisis Counseling Projects for previous disasters.

Appropriate expenses include reimbursement for travel and regular salary expenses incurred by the State or local representative. For contracted consultants, the maximum reimbursement rate is $750 per day which includes preparation time, travel time and materials. Reimbursable travel expenses include airfare, hotel and perdiem.

In-kind contributions include costs and time associated with the use of State and local in-house consultants.

TRAVEL/TRANSPORTATION: Program staff are expected to provide outreach services to communities impacted by a disaster. Staff generally use personal vehicles.

Appropriate expenses include mileage based on State or local standard rates for staff to conduct outreach to survivors' homes, to meet with community groups or agency personnel, or to conduct or receive training. When personnel must travel beyond their home area, expenses for transportation, lodging, and meals may be appropriate. Costs for program sanctioned training events beyond the home area would be typical examples. Usual and customary State and local travel policy should be followed.

Inappropriate expenses include travel/transportation costs for disaster survivors and out-of-state travel for staff. The use of State or local agency vehicles is encouraged and the standard motor-pool cost may be covered or considered an in-kind contribution. Rental or leasing of vehicles is permitted only in unusual circumstances where it can be demonstrated that the use of personal vehicles is not a reasonable option. Unusual circumstances include those in which the disaster occurred throughout a very large geographic area or in remote areas.

TRAINING: The March 19, 1995 FEMA training policy memorandum must be followed (Attachment B).

Appropriate expenses include those described in the FEMA training policy memorandum and training materials.

Inappropriate expenses include those that do not comply with the training policy memorandum. Also included: food and beverages, preparedness training, attending conferences or workshops not directly related to the project, out-of-State training, and other training primarily designed to prepare staff for future disasters. Training for Critical Incident Stress Debriefing (CISD), an intervention offered to emergency responders soon after a traumatic incident, is considered preparedness training and is an inappropriate expenditure for this program.

In-kind contributions include costs and time associated with the use of State and local in-house trainers. CMHS has training resources available to assist State and local providers.

EVALUATION: Program evaluation is optional for States. (CMHS is currently developing guidelines on program evaluation for States). Costs related to the data collection/evaluation component include collecting, collating, and reporting data for required project reports. These costs can include on-going data collection, surveys, outcome assessment, etc. Research is prohibited under the CCP.

SUPPLIES: Supplies may include any item with a per item cost of less than $5,000. General supplies should be described but do not need to be itemized. Computers, cell phones and pagers must be itemized and include number needed and cost per unit.

Appropriate expenses include copy and fax paper, printer cartridges, basic office supplies, copy or reproduction costs for outreach materials, cellular phones and pagers. Cellular phones and pagers can help to assure the safety of staff traveling to remote or dangerous areas. Computers and fax and copier machines may be appropriate, but verification should be made that the equipment is not available through in-kind contributions, State or local inventories, or through donations. If a State has had a previous crisis counseling grant program where items of equipment were purchased, that equipment should be used. Requests for computers require a strong justification related to the need, number, cost, and type (i.e. laptops or desktops).

Inappropriate expenses include food and beverages, medications, stuffed animals, toys, disaster kits, materials or playground items for recreational programs, video cameras, video recording equipment, and other types of video production equipment and materials.

In-kind contributions typically include furniture, computers, fax, and copier machines.

RENTAL OFFICE SPACE: Office space may be funded if it is demonstrated in-kind or donated space is not available. Outreach to disaster survivors is a major goal of the program and staff are expected to spend minimal time in an office setting.

Appropriate expenses include a minimal amount of office space for the management and administration functions of the program when donated space is not available.

Inappropriate expenses include facility renovation, repair or construction.

TELEPHONE AND UTILITIES: These costs should be estimated.

MEDIA/PUBLIC INFORMATION: The development and dissemination of brochures, flyers, posters and information about the program is encouraged. In addition, CMHS has videotapes and publications on a variety of topics to assist State and local crisis counseling programs.

Appropriate expenses include advertisements to recruit staff, publicize services available to disaster survivors, or educate the public concerning typical reactions to the disaster; pamphlets, flyers, newspapers, publications, booths exhibits/displays, and duplication of CMHS/FEMA disaster mental health videotapes and materials, if the State requires more copies than CMHS can provide. Television and radio broadcasts are appropriate but attempts should be made to obtain donated space and air time for print ads and broadcasts.

Funds for video development may be included if the following three criteria are met:

• There is no similar resource. No comparable resource is available from another crisis counseling program, any Federal agency, State agency, or the commercial market.
  
  
• The State has provided a comprehensive description of the objectives and format of the videotape and has demonstrated the disaster mental health knowledge and experience necessary to develop a quality product.
  
  
• The video tape can be completed early enough in the program period to allow it to be used as an educational and training tool during the nine-month grant. Preparedness activities will not be funded.

Inappropriate expenses include expensive print ads or broadcast and video development costs that fail to meet the above criteria.

POSTAGE: Postage for mailings may be funded.

INDIRECT COSTS: As a supplemental program, FEMA does not fund a line item category for indirect costs. All charges must be direct. Indirect costs (blanket percentage charges) and administrative overhead costs to manage and monitor the program are not allowed. Costs that are typically included in indirect cost rates may be submitted for consideration as direct costs.

MISCELLANEOUS/OTHER: Funds may not be requested as "miscellaneous." All costs must be itemized.

III Transfer of Funds
The funding processes are separate and distinct for the Immediate Services Program and the Regular Services Grant Program. The State is strongly advised to understand and prepare for the transfer of funds.

Immediate Services Program (ISP)

FEMA may elect to advance all or part of the approved immediate services funds. Disbursement of funds is accomplished through an electronic funds transfer system, SMARTLINK, to the State Emergency Management Agency (SEMA). The State Emergency Management Agency then disburses the funds to the State Department of Mental Health. FEMA can obligate funds as quickly as within 48 hours of the application approval. Prior to FEMA disbursement of funds, the State Department of Mental Health and the State Emergency Management Agency should prepare to transfer funds between their agencies. In addition, the State Department of Mental Health is advised to consult with respective State and local fiscal agency/service provider staff to ensure that there is a mechanism in place to draw down and distribute funds immediately to area service providers funded in the project.

Regular Services Program (RSP)

Unlike the ISP, funds for the RSP are not transferred through the State Emergency Management Agency. Funds for the RSP are transferred by FEMA HQ to SAMHSA/ CMHS, and then awarded by a grant from SAMHSA/CMHS to the State Mental Health Authority. The RSP is essentially a grant that must adhere to DHHS/Public Health Service grant policy, in addition to FEMA regulations.

The State is eligible to withdraw funds upon receipt of a Notice of Grant Award (NOGA) which is issued by the SAMHSA Office of Resource Management. As a discretionary grant, States may not receive all of the total approved grant amount. FEMA initially obligates about one-half of the approved funds to SAMHSA/CMHS. The State's request for the second allotment of funds should be included in the First Quarterly Report with a financial plan projecting the amount of funds required to complete the project. The second allotment of funds will be awarded to the State through another NOGA upon review and receipt of the first quarterly report with expenditures detailed in a fiscal report.

The funding processes are separate and distinct for the Immediate Services Program and the Regular Services Grant Program. Therefore, transition from the ISP to the RSP is important. The start date of the RSP should be coordinated with the CMHS Project Officer to ensure a seamless transition. TIP: States should consider agency payroll time frames when coordinating the end date of the Immediate Services Program and the start date for the Regular Services program. This transition in the middle of pay periods may be problematic for some State accounting systems.

IV Post-award Administration of Funds
With review and concurrence of awarding office, approved budgets may be amended as program requirements change.

Disaster mental health crisis counseling programs are dynamic and proactive. It is not unusual for original needs to change. Often there has been an overestimation or underestimation of resources needed in a specific geographic or target population area.

Contemplated amendments to approved budgets should be discussed with FEMA/CMHS program officials before a formal request for change is requested. Proposed changes should not be beyond the basic general goals of the approved program. In general, States may make minor changes to a project. Shifting funds from the supplies line item to the travel line item to support increased travel expenses for outreach workers is an example of a minor budget modification. However, written prior approval must be obtained from the CMHS Project officer and FEMA for major changes to a project as defined by changes in scope, direction, staffing level, type of service delivery, training, or other areas that constitute a significant departure from the objectives or purposes of the approved project as described in the application. If written approvals are not obtained, costs related to those activities are at significant risk of being disallowed.

When in doubt, contact the CMHS Project Officer for the Regular Services Program; or the FEMA Crisis Counseling Coordinator for the Immediate Services Program.

V Reporting Requirements and Procedures
There are special reporting and closeout requirements for the ISP and RSP. This is a departure from most Federal grants. In addition to the reporting requirements, FEMA and CMHS may, on occasion, request that the State provide information in addition to that contained in the required reports.

Immediate Services Program
Final Program Report: This report is due to the FEMA Disaster Recovery Manager 90 calender days after the last day of the immediate services funding. If a regular program grant is ongoing, the transition from immediate to the regular program activities must be described.

Final Accounting of Funds: This report is due 90 calender days after the last day of immediate services funding. This report should explain how the funds were expended by category and budget line for each agency/service provider as described in the application. The report should be included in the final program report which is submitted to the FEMA Disaster Recovery Manager through the Governor's Authorized Representative. A final voucher must also accompany this report. Most States use the SF 269A Financial Status Report (Short Form) as the final voucher (Attachment C) but States may use the longer version SF 269 if they prefer. There must not be any unliquidated obligations and the exact balance of funds must be indicated. The total expended funds must be consistent with the line item report.
The expenditure report is prepared by the State Department of Mental Health; the voucher is prepared by the State Emergency Management Agency. The State should coordinate closely with the SEMA to ensure that the voucher and expenditure report are consistent and accurate.

Mid Program Report: Should the State determine there may be a need for services beyond 60 days, a Regular Services Grant program application can be submitted. This progress report is submitted to the FEMA Disaster Recovery Manager only when an application for a Regular Services Grant application is being prepared. The application is due no later than the 60th calender day following the Presidential Declaration Date. The Mid Program Report must include an interim fiscal report of expenditures under the ISP.

Regular Services Program

Quarterly Report: Two quarterly progress reports for the nine-month grant must be submitted to the CMHS Project Officer. Quarterly reports are due 30 days after the end of the 3-month reporting period. Documentation on financial expenditures is part of the quarterly reports. The interim accounting of funds should reflect: (1) the approved budget, (2) the costs incurred/obligated expenditures, (3) approved budget modifications, and, (4) the unspent balance for each agency or service provider. These quarterly budget expenditure reports should be consistent with the budget categories and line items as described in the approved application. See Attachment D for a Sample Expenditure Report form.

The request for the second allotment of funds should be included in the first quarterly report. In order to issue an award for additional funds, the State must also include a financial plan projecting the amount of funds required to complete the project. It is advisable to develop monthly service and financial data to document activities and level of efforts to help project additional funds needed.

Final Program Report: The final program report is due to the CMHS Project Officer 90 days following the final day of program services. Disaster survivor data collection records should be destroyed upon completion and submission of the final program report.

Final Accounting of Funds Report: The final accounting of funds report is due 90 days following the final day of program services. This report contains two documents: (1) a final expenditure report showing expenditures of funds by category and budget line for each agency/service provider as described in the application, and (2) a final voucher. Most States use the SF 269A Financial Status Report (Short Form) as the final voucher (Attachment C) but a State may use the longer version, SF 269, if desired. There must not be any unliquidated obligations and the exact balance of funds must be indicated. All interest earned on Federal grant funds must be used as additional income to the grant program. All reports should be submitted to the CMHS Project Officer with copies submitted to the SAMHSA Grants Management Office.

Tip: Lines "d" and "f" of the SF 269A Short Form should show a zero balance. Lines "k" and "m" of the SF 269 Long Form should show a zero balance. Please do not show dollar numbers in these respective lines.

Tip: The total award refers to the total of all NOGAs issued which may not be the same as the original total approved grant.

The expenditure report is prepared by the State Department of Mental Health, while the voucher is prepared and authorized by the State's Financial Accounting Office. The State should coordinate closely with their Financial Accounting office to ensure that the voucher and the expenditure report are consistent.

Program Audit: State and local government agencies must conduct audits in accordance with the Single Audit Act of 1984, PL 98-502, which is implemented by the Office of Management and Budget (OMB) Circular A-133. CCPs are also subject to Federal audits. States should keep CCP fiscal records and documents three years following the last date of the project services period even if a Federal audit is conducted during that timeframe.

Attachments

Attachment A   Summary Table - Fundable and Non-Fundable Expenses
Attachment B   FEMA Training Policy Memorandum, May 1995
Attachment C   Financial Status Report, SF 269A Short Form http://www.whitehouse.gov/omb/grants/sf269a.pdf
You will need Adobe Acrobat Reader to view this file.
Attachment D   Sample Budget Form – Financial Expenditure Report for a Regular Service Program

For More Information
This program guidance was developed to ensure that the context, boundaries and strategies of the Crisis Counseling Program are consistently implemented throughout the United States. If program managers have questions regarding this guidance, they should contact their State disaster mental health program director for clarification. If the State program director needs additional guidance, he or she should contact their CMHS Project Officer.

Center for Mental Health Services
Emergency Services and Disaster Relief Branch
5600 Fishers Lane, Room 17C-20
Rockville, MD 20857
(301) 443-4735
(301) 443-8040 FAX

Attachment A - Summary Table on Fundable and Non-Fundable Expenses

Attachment B - FEMA Training Policy

Federal Emergency Management Agency Washington, D.C. 20472 May 19,1995

BACKGROUND
Training is a critical element of the Crisis Counseling Assistance and Training Program (CCP). State departments of mental health provide mainstream rental health services, such as treatment for substance abuse, mental illnesses, or developmental disabilities. They do not normally provide crisis counseling services and thus, do not have trained crisis counselors or outreach workers readily available.

Training of Crisis counseling and outreach staff is conducted by either State, county or local mental health staff or contractors. For many years, the availability of qualified mental health practitioners to conduct disaster mental health training was limited. Contractors were often the only available training resource. During the time there were few trainers, the rate of pay for contractors became inflated and has remained high ever since. Due to the large number of immediate services and regular programs funded by FEMA since 1992, the pool of qualified trainers has grown significantly.

POLICY
The following policy has been developed in an effort to reduce training costs, assure that the pool of qualified trainers continues to grow, and encourage States to assist each other not only with training, but also with technical advice on program development. The policy is divided into three priorities or steps that should be followed by the State.

Priority 1
It is FEMA's intent to encourage States to develop in-house training capabilities. Priority should be given to using State,disaster mental health county, and local resources with appropriate disaster mental health experience to conduct training. When the State documents that the cost of training is beyond State and local resources, FEMA will reimburse salary and travel costs of the State, county or local mental health trainers. If FEMA has funded an immediate or regular program in the State within the past three years, qualified trainers should be available within the State. The first priority is to assess the availability of in-state resources.

Priority 2
If a State has not administered an immediate services or regular program in the past- three years or due to unusual circumstances does not have in-State resources, the State should be encouraged to contact other State departments of mental health that have 4 mplemented CCP for comparable disasters. The declared State may include in the budget for the immediate services or regular program reimbursement for travel and salary expenses(including overtime)incurred by one or more representatives of another State to provide technical assistance with program and training development. The intent is for the declared State to develop their own resources with assistance from experienced State representatives. The representative sent by the assisting State may be from State, county or local mental health authorities. The Center for Mental Health Services will assist the declared State in identifying training resources in other States.

Priority 3
If a State does not have in-house training capabilities and after consultation with CMHS cannot identify resources from other States, FEM will consider funding contractors. The maximum amount that FEMA will reimburse for a trainer is $750 per day, plus travel expenses (airfare, mileage, hotel, and per diem). The daily rate includes preparation, materials, travel time, and all other expenses. The rate of $750 is a maximum amount. It is anticipated for many disasters well qualified trainers will be available at lower rates. If a State elects to use a trainer that charges more than the cap amount, the State or county must cover the difference as part of their in-kind contribution.

In order to be reimbursed for contractors, the State must include in their immediate or regular services application a description of their effort to locate in-State and other State resources. CMHS will verify the lack of availability of training resources.

CONTACT
The contact on the training policy is Diana Nordboe of the Human
Services Division at (202) 646-4026.

LEAD OFFICE
The lead office for the training policy is the Human Services Division, Response and Recovery Directorate.

Attachment D- Sample Budget Report Format: Quarterly Expenditure Reports

NOTE: Report must capture all obligated costs for the report period.

01/2001