FY 2009 SHSP Tribal Guidance

U.S. DEPARTMENT OF HOMELAND SECURITY

FISCAL YEAR 2009
STATE HOMELAND SECURITY PROGRAM TRIBAL
U.S. DEPARTMENT OF HOMELAND SECURITY

GUIDANCE AND APPLICATION KIT

NOVEMBER 2008

U.S. DEPARTMENT OF HOMELAND SECURITY

Title of Opportunity: State Homeland Security Program (SHSP) Tribal
Funding Opportunity Number: DHS-09-GPD-067--1973
Federal Agency Name: FEMA Grant Programs Directorate (GPD)
Announcement Type: Initial
Dates: Completed applications must be submitted no later than 11:59 PM EDT,
March 20, 2009.
Additional overview information: The Fiscal Year (FY) 2009 SHSP Tribal contains
the following key changes:
SHSP Tribal Priorities
Priorities for this year continue to further narrow the focus through the risk-based
funding and the capability-based planning process that DHS began four years ago. FY
2009 SHSP Tribal will focus on the following objectives as its highest priorities. These
priorities are:
1. Addressing Capability Requirements and Measuring Progress in Achieving the
National Preparedness Guidelines
2. National Priority: Strengthen Planning and Citizen Preparedness Capabilities Strengthening Preparedness Planning
3. National Priority: Strengthen Information Sharing and Collaboration Capabilities Maximizing Information Sharing via the National Network of Fusion Centers
4. National Priority: Strengthen Medical Surge and Mass Prophylaxis - Developing
and Enhancing Health and Medical Readiness and Preparedness Capabilities
At least 25 percent of FY 2009 SHSP Tribal funding must be allocated to the
Strengthening Preparedness Planning Priority through planning, training and exercise
activities.
Optional Cost Share
In FY 2009, there is an optional cost share that will provide a bonus in the effectiveness
analysis (see Investment Justification Outline in Part IV.B for additional information).
Personnel Costs
As directed by the Personnel Reimbursement for Intelligence Cooperation and
Enhancement (PRICE) of Homeland Security Act (Public Law 110-412), all personnel
and personnel-related costs, including those for intelligence analysts, are allowed up to
50 percent of SHSP and UASI funding without time limitation placed on the period of
time that such personnel can serve under the grant. These guidelines are not
retroactive to previous fiscal years of SHSP funding (see Part IV.E.4 for additional
information).

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CONTENTS
Contents......................................................................................................................... 1
Part I. FUNDING OPPORTUNITY DESCRIPTION......................................................... 2
Part II. AWARD INFORMATION .................................................................................... 8
Part III. ELIGIBILITY INFORMATION ............................................................................ 9
A.
Eligible Applicants................................................................................... 9
B.
Cost Sharing .......................................................................................... 10
C.
Restrictions ............................................................................................ 10
Part IV. APPLICATION AND SUBMISSION INFORMATION ...................................... 11
A.
Address to Request Application Package ........................................... 11
B.
Content and Form of Application ......................................................... 11
C.
Submission Dates and Times ............................................................... 17
D.
Intergovernmental Review .................................................................... 17
E.
Funding Restrictions ............................................................................. 17
Part V. APPLICATION REVIEW INFORMATION ........................................................ 24
A.
Review Criteria....................................................................................... 24
B.
Review Process ..................................................................................... 24
C.
Anticipated Announcement and Award Dates .................................... 25
Part VI. AWARD ADMINISTRATION INFORMATION ................................................. 26
A.
Notice of Award ..................................................................................... 26
B.
Administrative and National Policy Requirements ............................. 26
C.
Reporting Requirements ....................................................................... 33
Part VII. FEMA CONTACTS......................................................................................... 37
Part VIII. OTHER INFORMATION - SHSP TRIBAL ALLOWABLE EXPENSES ........ 41

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PART I.

FUNDING OPPORTUNITY DESCRIPTION
The State Homeland Security Program (SHSP) is one tool among a comprehensive set
of measures authorized by Congress and implemented by the Administration to help
strengthen the Nation against risks associated with potential terrorist attacks.
The purpose of this package is to provide supplementary guidance for tribal applicants
and includes: (1) an overview of the SHSP Tribal and (2) the formal grant guidance and
application materials needed to apply for funding under the program. The package
outlines FEMA management requirements for implementation of a successful
application. The package also reflects changes called for in the Implementing
Recommendations of the 9/11 Commission Act of 2007 (Public Law.110-53) (hereafter
“9/11 Act”), enacted in August 2007, as well as the Consolidated Security, Disaster
Assistance, and Continuing Appropriations Act of 2009 (Public Law 110-329).
As part of the 9/11 Act, tribes are directly eligible applicants for SHSP Tribal funding1.
This guidance is meant to provide clear direction for those eligible tribes seeking to
apply for SHSP Tribal funding. However, applicants will note that the guidance has
been changed in several places in order to account for different tribal governance
structures, unique tribal homeland security challenges, and 9/11 Act requirements.
Federal Investment Strategy
SHSP is an important part of the Administration’s larger, coordinated effort to strengthen
homeland security preparedness. SHSP implements objectives addressed in a series
of post-9/11 laws, strategy documents, plans and Homeland Security Presidential
Directives (HSPDs).
FEMA expects our State, local, and tribal partners – including recipients of SHSP grants
– to be familiar with this national preparedness architecture and to incorporate elements
of this architecture into their planning, operations and investments.
SHSP Tribal Priorities
Funding priorities for this year continue the focus on risk-based funding and the
capability-based planning process that DHS began four years ago. FY 2009 SHSP
Tribal will focus on the following objectives as its highest priorities.

1

This SHSP Tribal funding is a subset of the State Homeland Security Program (SHSP). Eligible tribes may apply directly to FEMA
for SHSP Tribal funding and are also not precluded from requesting SHSP funding from the respective SAA as long as the projects
contained within each application are not the same.

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1. Addressing Capability Requirements and Measuring Progress in Achieving
the National Preparedness Guidelines. FEMA will continue in FY 2009 to tie
together the performance of preparedness programs (via grants, training,
exercises, technical assistance, planning, etc.) with established priorities and
objectives of the National Preparedness Guidelines, target capabilities, and joint
Federal-Tribal assessments. The preparedness cycle allows for adjustments
based upon evolving risks and capabilities. The Target Capability List (TCL)
Implementation Project is in the process of updating target capabilities into
usable frameworks with performance classes and objectives to guide evaluations
and assessments. The Comprehensive Assessment System (CAS) is under
development to assess compliance with the broad national preparedness system
as described under Subtitle C of the Post-Katrina Emergency Management
Reform Act of 2006 (Public Law 109-295) (PKEMRA), including NIMS, the
National Response Framework, the TCL, and the performance of training,
exercises, and operations.
Measuring Progress: As part of the FY 2009 SHSP Investment Justifications,
applicants are also asked to establish specific capability-based outcomes
associated with all proposed Investments. Proposals should be aligned with the
National Priorities of the National Preparedness Guidelines and must outline
measurable outcomes that will be tracked and accomplished during
implementation. Grantees should reference the TCL, dated September 2007, the
supplemental Target Capability Implementation Frameworks, where appropriate,
and applicable national plans and strategies to develop concrete, measurable
outcomes, and milestones, while preserving the necessary flexibility to meet
unique tribal operational requirements outlined in their homeland security plans.
After funds are awarded, grantees are required to report on progress made
toward achieving the identified outcomes for each Investment as part of the
regular grant reporting process. Performance measure data submitted through
grant reporting will be reviewed and validated through programmatic monitoring
by FEMA staff.
These outcomes should support both capability development and strategic,
operational, and tactical-level planning. For interoperable emergency
communications-related Investments, applicants should align to the objectives of
the National Emergency Communications Plan (NECP).2 The outcomes should
include a minimum number of quantitative and qualitative measures necessary to
demonstrate achievement with regard to developing and enhancing health and
medical readiness and preparedness capabilities. These measures should be
drawn, where applicable, from the TCL and from supplemental Target Capability
Implementation Frameworks. In addition to specific measures, grantees should
outline two to four key enablers for each Investment that are essential to
2

The FY 2007 HSGP required States to develop and submit a Statewide Communication Interoperability Plan (SCIP). All SCIPs
were approved by DHS in April 2008. The National Emergency Communications Plan (NECP), which was informed by the SCIPs, is
available at: www.dhs.gov/xnews/releases/pr_1217529182375.shtm.

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achieving the outcome and require monitoring and management throughout the
period of performance. These enablers are major outputs from the Investment
and can be tangible (e.g., a major equipment item) or logistical (e.g., a critical
process, such as a formal planning process) in nature. Examples should be
drawn from the “Resource Elements” listed as part of each capability in the TCL.
In the Target Capability Implementation Frameworks, outcomes are reflected in
the “Performance Objectives.”
2. National Priority: Strengthen Planning and Citizen Preparedness
Capabilities.
Strengthening Preparedness Planning. This provision also supports the
Planning Annex to HSPD-8, National Preparedness. State, local, and tribal
governments must engage in comprehensive national and regional planning
processes that seek to enhance emergency management capabilities through
strengthened national and regional relationships and the allocation of resources
toward preparedness planning. As indicated in the Planning Annex, coordinated,
comprehensive plans should be developed that cover prevention, protection, and
response activities for specific planning scenarios.
In order to develop these plans, applicants are strongly encouraged to develop
plans in a manner consistent with the principles and doctrine outlined in
Comprehensive Preparedness Guide 101, Producing Emergency Plans: A Guide
for All-Hazard Operations Planning for State, Territorial, Local and Tribal
Governments (Interim).
However, within these plans, specific activities may be implemented in support of
the following areas:
•

Linking operational needs identified in plans to resource allocation.
Applicants should use grant funds to institutionalize a capabilities-based
planning process that defines, documents, analyzes, adjusts, and
approves capability requirements that drive resource allocation.

•

Fixing shortcomings in existing plans. Areas of paramount concern
are: Mass Evacuation and Sheltering, with particular emphasis on
Regional Operations planning, special needs populations3 and citizen
preparedness; Statewide Communication Interoperability Plans and
Tactical Interoperable Communications Plans; Logistics planning,
Resource/Commodity Management, with particular emphasis on National
Incident Management System (NIMS) standardized mechanisms and
processes to describe, inventory, mobilize, dispatch, track, and recover
resources over both the lifecycle and regional or national scope of an
incident, taking into account both at-risk and host jurisdictions/states;

2 See CPG-301: Emergency Management Planning Guide for Special Needs Populations as a reference in addressing this issue.

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CIKR Protection, with particular emphasis on Explosive Device Response
Operations; Hazard Identification and Risk Assessment; Health and
Medical Services for Catastrophic Events; and long term recovery. Once
these shortcomings have been addressed, they should be integrated into
capabilities-based plans that address all hazards and all threats.
Additional shortcomings should be identified by the applicant in addition to
these requirements as warranted.
•

Building regional planning processes and planning communities.
The primary focus is to establish processes for planning, preparedness,
data exchange, and operational resource and asset management among
regional planning partners. Activities should ensure that preparedness
planning networks are fully integrated with other key planning efforts such
as Continuity of Operation Plans (COOP), Area Maritime Security Plans
(AMSPs) for port areas and Buffer Zone Plans (BZPs) for CIKR resources
and community preparedness planning conducted by governmental and
non-governmental entities through the Citizen Corps Council. This should
include drawing clear linkages in an appendix or annex to emergency
operations plans as appropriate. Additionally, applicants should clearly
address the linkages between Fusion Centers and the Tribal Emergency
Operations Centers and develop the necessary protocols and procedures
to ensure connectivity and support, as appropriate.

•

Enhancing continuity of operations planning. Applicants should use
grant funds to establish effective continuity plans and programs in an effort
to enhance tribes’ ongoing delivery of essential functions during all
hazards. Actionable measurable items include developing staffing and
guidance based on continuity priorities from the National Continuity
Programs Directorate and described in the National Continuity Policy
Implementation Plan (NCPIP). Measurable items include: providing State,
territorial, and local government continuity testing, training, and exercises;
offering continuity planning and program guidance; conducting continuity
education and outreach; providing mechanisms and making available
annual meetings for tribal continuity working groups or other forums;
offering and/or provide continuity guidance and outreach through tribal
Continuity Working Groups (CWGs); providing guidance and offering
assistance as required to conduct and/or support train-the-trainer
continuity courses for tribal governments. Examples include the COOP
Managers Train-the-Trainer Course, the COOP Planners Course, the
Exercise Design Course, the Building Design Risk Assessment Course,
and the Determined Accord (pandemic) Exercise.

•

Including the private sector in preparedness planning activities.
Tribes should include private sector entities in their preparedness planning
process, building public-private partnerships where appropriate to more
effectively prevent, protect against, respond to, and recover from major

5

events. In particular, tribes should engage with private sector entities as
provisions for the voluntary private sector preparedness, accreditation,
and certification program called for in the 9/11 Act are finalized in order to
ensure that personnel have a comprehensive understanding of
preparedness capabilities resident in their region.
3. National Priority: Strengthen Information Sharing and Collaboration
Capabilities
Maximizing Information Sharing via the National Network of Fusion
Centers. This priority reflects the policy outlined in the National Strategy for
Information Sharing (NSIS) by supporting the participation of tribes in the national
network of State and Urban Area fusion centers to facilitate effective nationwide
information sharing between local, tribal, State, and Federal partners.
Effective prevention efforts depend on the ability of all levels and sectors of
government to collect, analyze, disseminate, and use homeland security- and
crime-related information and intelligence. In support of these efforts, tribes must
prioritize the allocation of SHSP grant fund resources to participate in designated
State and Urban Area fusion centers, in accordance with the capabilities as
outlined in the Department of Justice’s (DOJ’s) Global Justice Information
Sharing Initiative’s (Global) Baseline Capabilities for State and Major Urban Area
Fusion Centers, a supplement to the Fusion Center Guidelines, available at
http://www.it.ojp.gov/documents/baselinecapabilitiesa.pdf.
4. National Priority: Strengthen Medical Surge and Mass Prophylaxis.
Developing and enhancing health and medical readiness and preparedness
capabilities. State and local grantees should consider preparedness efforts that
emphasize biological attack detection (bio collection), mass casualty incident
response, and counter-measure stockpiling and distribution. The Office of Health
Affairs (OHA) leads the Department’s role in developing and supporting a
scientifically rigorous, intelligence-based biodefense and health preparedness
architecture to ensure the security of our Nation in the face of all hazards.
Grantees are encouraged to work closely with OHA, in addition to their FEMA
Program Analyst and FEMA Region, when developing or enhancing medical
surge and mass prophylaxis programs in response to biological threats and for
public health and medical preparedness. For more information, please visit
http://www.dhs.gov/xabout/structure/editorial_0880.shtm or contact OHA at
oha@dhs.gov.

6

Consolidation of Law Enforcement Terrorism Prevention-oriented Activities
Per the 9/11 Act and the Consolidated Security, Disaster Assistance, and Continuing
Appropriations Act of 2009 (Public Law 110-329), the FY 2009 Homeland Security
Grant Program (HSGP) will not contain a separate line-item Law Enforcement Terrorism
Prevention Program (LETPP). As is clear in this year’s overarching HSGP priorities, a
significant need for law enforcement terrorism prevention exists. As a result, tribes are
also required to ensure that at least 25 percent of their SHSP award funds are
dedicated towards law enforcement terrorism prevention-oriented planning,
organization, training, exercise, and equipment activities.

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PART II.

AWARD INFORMATION
This section summarizes the award period of performance and the total amount of
funding available under the FY 2009 SHSP Tribal, describes the basic distribution
method used to determine final grants awards, and identifies all eligible applicants for
FY 2009 funding.
Award Period of Performance
The period of performance of this grant is 36 months. Extensions to the period of
performance will be considered only through formal requests to FEMA with specific and
compelling justifications why an extension is required.
Available Funding
In FY 2009, the total amount of funds distributed under the FY 2009 SHSP Tribal will be
$1,660,000, which is an amount equal to at least 0.1 percent of the total funds
appropriated for grants under sections 2003 (Urban Areas Security Initiative) and 2004
(State Homeland Security Program) of the Homeland Security Act, as amended by the
9/11 Act. FY 2009 SHSP Tribal funds will be allocated based on risk and anticipated
effectiveness upon completion of the application review process.

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PART III.

ELIGIBILITY INFORMATION

A. Eligible Applicants
Per the 9/11 Act, “a directly eligible tribe applying for a grant under section 2004 [SHSP]
shall designate an individual to serve as a tribal liaison with [DHS] and other Federal,
State, local, and regional government officials concerning preventing, preparing for,
protecting against, and responding to acts of terrorism.”
The term “directly eligible tribe” means –
(A) any Indian tribe –
(i) that is located in the continental United States;
(ii) that operates a law enforcement or emergency response agency with the
capacity to respond to calls for law enforcement or emergency services;
(iii)
(I) that is located on or near an international border or a coastline bordering
an ocean (including the Gulf of Mexico) or international waters;
(II) that is located within 10 miles of a system or asset included on the
prioritized critical infrastructure list established under section 210E(a)(2)
[please refer to section 1001 of the 9/11 Act] or has such a system or
asset within its territory;
(III) that is located within or contiguous to 1 of the 50 most populous
metropolitan statistical areas in the United States; or
(IV) the jurisdiction of which includes not less than 1,000 square miles of
Indian country, as that term is defined in section 1151 of title 18, United
States Code; and
(iv) that certifies to the Secretary that a State has not provided funds under
section 2003 [UASI] or 2004 [SHSP] to the Indian tribe or consortium of
Indian tribes for the purpose for which direct funding is sought; and
(B) a consortium of Indian tribes, if each tribe satisfies the requirements of
subparagraph (A).
In summary, eligible tribes must meet the requirements set forth in (A) (i), (ii), and (iv).
Tribes must also meet one of the requirements set forth in (A) (iii); either (I), (II), (III), or
(IV). Finally, (B) may also be satisfied, if each tribe satisfies the requirements of
subparagraph (A).
To be eligible to receive FY 2009 SHSP Tribal funding, applicants must meet NIMS
compliance requirements. The NIMSCAST will be the required means to report FY 2008

9

NIMS compliance for FY 2009 preparedness award eligibility. All grantees were
required to submit their compliance assessment via the NIMSCAST by September 30,
2008 in order to be eligible for FY 2009 preparedness programs. The grantee reserves
the right to determine compliance reporting requirements of their sub-awardees (locals)
in order to disperse funds at the local level.
For FY 2009 there are no new NIMS compliance objectives. If FY 2008 NIMS
compliance was reported using NIMSCAST and the grantee has met all NIMS
compliance requirements, then NIMSCAST will only require an update in FY 2009.
Additional information on achieving compliance is available through the FEMA National
Integration Center (NIC) at http://www.fema.gov/emergency/nims/.
B. Cost Sharing
In FY 2009, there is an optional cash or in-kind cost share.
C. Restrictions
Please see Part IV.E. for SHSP Tribal Priorities Threshold, Law Enforcement Terrorism
Prevention, Management & Administration (M&A) limits, and allowable/unallowable
costs guidance.

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PART IV.

APPLICATION AND SUBMISSION
INFORMATION
A. Address to Request Application Package
DHS participates in the Administration’s e-government initiative. As part of that
initiative, all applications must be filed using the Administration’s common electronic
“storefront” -- grants.gov. Eligible tribes must apply for funding through this portal,
accessible on the Internet at http://www.grants.gov. To access application forms and
instructions, select “Apply for Grants,” and then select “Download Application Package.”
Enter the CFDA and/or the funding opportunity number located on the cover of this
announcement. Select “Download Application Package,” and then follow the prompts to
download the application package. To download the instructions, go to “Download
Application Package” and select “Instructions.” If you experience difficulties or have any
questions, please call the grants.gov customer support hotline at (800) 518-4726.
B. Content and Form of Application
1. On-line application. The on-line application must be completed and submitted
using grants.gov after Central Contractor Registry (CCR) registration is confirmed.
The on-line application includes required forms and submissions:
•
•
•
•
•
•
•

Tribal Investment Justification Worksheet
Standard Form 424, Application for Federal Assistance
Standard Form 424A, Budget Information
Standard Form 424B Assurances
Standard Form LLL, Disclosure of Lobbying Activities
Standard Form 424C, Budget Information – Construction Programs (if
applicable)
Standard Form 424D, Assurances – Construction Programs (if applicable)

The program title listed in the Catalog of Federal Domestic Assistance (CFDA) is
“Homeland Security Grant Program.” The CFDA number is 97.067.
2. Application via grants.gov. FEMA participates in the Administration’s egovernment initiative. As part of that initiative, all applicants must file their
applications using the Administration’s common electronic “storefront” -- grants.gov.
Eligible tribes must apply for funding through this portal, accessible on the Internet at
http://www.grants.gov. Eligible tribes are required to submit a copy of their
application for SHSP Tribal funds to each State within which any part of the
11

tribe is located for review before the tribe submits it to http://www.grants.gov.
3. DUNS number. The applicant must provide a Dun and Bradstreet Data Universal
Numbering System (DUNS) number with their application. This number is a required
field within grants.gov and for CCR Registration. Organizations should verify that
they have a DUNS number, or take the steps necessary to obtain one, as soon as
possible. Applicants can receive a DUNS number at no cost by calling the dedicated
toll-free DUNS Number request line at (866) 705-5711.
4. Valid Central Contractor Registry (CCR) Registration. The application process
also involves an updated and current registration by the applicant. Eligible
applicants must confirm CCR registration at http://www.ccr.gov, as well as apply for
funding through grants.gov.
5. Investment Justification. As part of the FY 2009 SHSP Tribal application process,
applicants must develop a formal Investment Justification that addresses each
Investment being proposed for funding. These Investment Justifications must
demonstrate how proposed projects address gaps and deficiencies in current
programs and capabilities. The Investment Justification must demonstrate the ability
to provide enhancements consistent with the purpose of the program and guidance
provided by FEMA. Applicants must ensure that the Investment Justification is
consistent with all applicable requirements outlined in the application kit. Applicants
may propose up to three (3) Investments within their Investment Justification.
The following table outlines the Tribal Investment Justification template, and has
been provided by FEMA for directly eligible tribal applicants to apply for SHSP grant
funding, specifically SHSP Tribal funding. The table includes scoring criteria for
each section and the weights that will be applied to reinforce priority areas.

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Question
OVERALL

Investment Justification Outline
Scoring Criteria

Overall Investment Justification
Question: Describe your understanding of
the spectrum of terrorism and natural hazard
risks your tribal area faces. Explain how this
understanding influenced development of
this Investment Justification.

The information provided is not scored
as an individual section; however, it is
considered in the Portfolio Score, and
should demonstrate the relationship
between the individual Investments and
the applicant’s understanding of risk

Management & Administrative Costs:
Tribes must provide a brief overall summary
The information provided is not scored
of planned management and administrative
as an individual section; however, it is
(M&A) expenditures that support the
considered in the Portfolio Score
implementation of the Investments proposed
in this Investment Justification.

Project Management: Describe the
management team’s roles and
responsibilities, governance structures, and
subject matter expertise specifically required
for all of the Investments included in this
Investment Justification.

The information provided is not scored
as an individual section; however, it is
considered in the Portfolio Score and
should demonstrate the team’s ability to
manage the Investments listed in the
application

BASELINE

Investment Heading:
• Tribe name
• Investment name
• Total FY 2009 SHSP Tribal funding
requested
• Investment Phase – Ongoing or New

The information provided is not scored

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Question

Scoring Criteria

I.A. Baseline – Previous SHSP Tribal
Request Name and Funding: If the
Investment was included in a previous
SHSP Tribal request, please provide the
name of the Investment and the total
amount of SHSP Tribal funding that was
dedicated to this Investment, if any.

I.B. Baseline – Purpose Statement:
Describe, at a high-level, what activities will
be implemented and what will be
accomplished by this Investment.

The information provided is not scored
as an individual section; however, it is
considered in the Comprehensive
Investment Score and should establish
the Investment’s background and
progress made to date

I.C. Baseline – Description: Provide a
description of the current state of this
Investment, its objectives, and any
accomplishments that will be completed
prior to the application of FY 2009 SHSP
Tribal funds. Include in this description
whether this is a new or ongoing
Investment. Describe the capability gap(s)
that this Investment is intended to address.

STRATEGY (15%)
•
II.A. Strategy – Homeland Security Plans:
Explain how this Investment supports
homeland security plans, such as the State
Preparedness Report.

14

•

Response provides linkage
between the Investment and
homeland security plans
Response demonstrates how the
Investment will contribute to
reaching any homeland security
plan targets

Question

Scoring Criteria
•

II.B. Strategy – Target Capabilities:
Provide one primary and up to four
secondary Target Capabilities that this
Investment supports. For the primary Target
Capability selected, provide an explanation
of how it is supported by this Investment.

II.C. Strategy – National Priorities: Identify
the National Priority(ies) that this Investment
supports; up to four may be selected.

•

Response provides linkage
between the Investment and
selected primary Target
Capability
Response demonstrates how the
Investment will support the
selected primary Target
Capability

The information provided is not scored
as an individual section; however, it is
considered in the Comprehensive
Investment Score

FUNDING PLAN (15%)
III.A. Funding Plan: Provide the total
estimated cost to implement this Investment
during the three year, FY 2009 SHSP Tribal
period of performance by completing the
following table:
• For each solution area that has an
associated FY 2009 SHSP Tribal
cost, provide a brief summary of the
planned expenditures (including
personnel)
• If this Investment includes an optional
cost share, provide the cash or inkind funding amounts in the
appropriate section of the funding
table and describe how those funds
will be applied
• Other sources of funding should be
identified and described appropriately

15

•
•

•

Response references the
appropriate activities, services,
or products for the solution area
Response describes how the
estimated SHSP Tribal costs will
be used specifically towards this
Investment
The optional cash and in-kind
cost share identified are
considered in the effectiveness
analysis

Question
Scoring Criteria
ACCOMPLISHMENTS, CHALLENGE MITIGATION (35%)
III.B. Accomplishments: Identify two to five
accomplishments that will be achieved
within the three year, FY 2009 SHSP Tribal
period of performance. For each
accomplishment:
• Identify the planned end date for
when the accomplishment will occur
• Identify at least one milestone that
will indicate the Investment is
progressing towards the
accomplishment
• Identify at least one challenge that
may impede the achievement of the
accomplishment within the period of
performance

•

III.C. Challenge Mitigation: Explain how
the management team described in the
Overall section will mitigate challenges and
ensure that the expected accomplishments
and milestones for this Investment will be
achieved within the three year, FY 2009
SHSP Tribal period of performance.

•

Response describes how the
management team will mitigate
challenges to meet milestones in
order to achieve the
accomplishments for the
proposed Investment

•

Response describes how the
accomplishments will reduce
risks outlined in the Overall
Investment Justification question

•

Response describes how the
capabilities developed by this
Investment will be
maintained/sustained beyond the
three year FY 2009 SHSP Tribal
period of performance, or
Response describes why the
Investment will not be
maintained/sustained long-term

•

•

Each response provides a clear
description of the Investment’s
accomplishments
Milestones collectively present a
clear sequence of events that will
lead to the associated
accomplishment
Challenges should describe
potential barriers to both the
successful implementation of the
proposed Investment and the
completion of the associated
accomplishments within the FY
2009 SHSP Tribal period of
performance

IMPACT (35%)
IV.A. Impact on Identified Risk: Describe
how achieving this Investment’s
accomplishments will reduce your identified
risk as described in the Overall Investment
Justification question.

IV.B. Sustainability: Describe the long-term
approach to sustaining the capabilities
created or enhanced by this Investment, or
explain why this Investment will not be
sustained.

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•

C. Submission Dates and Times
Completed applications must be submitted electronically through www.grants.gov no
later than 11:59 PM EDT, March 20, 2009. Late applications will neither be considered
nor reviewed. Upon successful submission, a confirmation e-mail message will be sent
with a grants.gov tracking number, which is needed to track the status of the
application.
D. Intergovernmental Review
Executive Order 12372 requires applicants from State and local units of government or
other organizations providing services within a State to submit a copy of the application
to the State Single Point of Contact (SPOC), if one exists, and if this program has been
selected for review by the State. Applicants must contact their State SPOC to
determine if the program has been selected for State review. Executive Order 12372
can be referenced at http://www.archives.gov/federal-register/codification/executiveorder/12372.html. The names and addresses of the SPOCs are listed on OMB’s home
page available at: http://www.whitehouse.gov/omb/grants/spoc.html.
E. Funding Restrictions
In administering the FY 2009 SHSP Tribal, the tribe must comply with the following
general requirements:
1. SHSP Tribal Priorities Threshold. As noted before, FY 2009 SHSP Tribal will
focus on four objectives as its highest priorities, of which at least 25 percent of
SHSP Tribal funds must be dedicated to Strengthening Preparedness Planning
Priority through planning, training and exercise activities.
2. Law Enforcement Terrorism Prevention. Per the 9/11 Act and the Consolidated
Security, Disaster Assistance, and Continuing Appropriations Act of 2009 (Public
Law 110-329), FY 2009 SHSP will not contain a separate line-item Law Enforcement
Terrorism Prevention Program (LETPP). However, tribal applicants are still required
to ensure that at least 25 percent of their SHSP award funds are dedicated towards
law enforcement terrorism prevention-oriented planning, organization, training,
exercise, and equipment activities.
2. Management and Administration (M&A) limits. A maximum of up to three
percent (3%) of funds awarded may be retained by the direct tribal grantee, and any
funds retained are to be used solely for management and administrative purposes
associated with the SHSP award.
3. Allowable Costs. Allowable Investments made in support of the SHSP Tribal
Priorities discussed above as well as other capability-enhancing projects must fall
into the categories of Planning, Organization, Equipment, Training, or Exercises. Up

17

to 50 percent of FY 2009 SHSP tribal funding may be used to pay for the total of all
personnel or personnel-related costs from these categories.
Additional detail about each of these allowable expense categories, as well as sections
on additional activities including explicitly unallowable costs is provided. In general,
grantees should consult their FEMA Program Analyst prior to making any Investment
that does not clearly meet the allowable expense criteria established by the guidance.
Planning Activities
Tribes are required to use FY 2009 SHSP Tribal funds for planning efforts as noted
above in the “Tribal Priorities Threshold” section. This includes planning that enables
them to prioritize needs, build capabilities, update preparedness strategies, allocate
resources, and deliver preparedness programs across disciplines (e.g., law
enforcement, fire, emergency medical service (EMS), public health, behavioral health,
public works, agriculture, and information technology) and levels of government.
Planning activities should focus on the four homeland security mission areas of
prevention, protection, response, and recovery. All jurisdictions are encouraged to work
through Citizen Corps Councils, nongovernmental entities, and the general public in
planning activities.4
Organization Activities
Sec. 2008 under the 9/11 Act includes allowability for the following activities:
•
•
•

Responding to an increase in the threat level under the Homeland Security
Advisory System, or needs resulting from a National Special Security Event
Establishing, enhancing, and staffing State, local and regional fusion centers
Paying salaries and benefits for personnel to serve as qualified intelligence
analysts

Tribes must justify proposed expenditures of SHSP funds to support organization
activities within their Investment Justification submission by using historical data or
other analysis.5 All tribes are allowed to utilize up to 50 percent of their FY 2009 SHSP
funding for personnel related costs, which include Organizational activities6. At the
request of a recipient of a grant, the Administrator may grant a waiver of the limitation
noted above (50 percent).
• Overtime costs. Overtime costs are allowable for personnel to participate in
information, investigative, and intelligence sharing activities specifically related to
homeland security and specifically requested by a Federal agency. Allowable costs
are limited to overtime associated with Federally requested participation in eligible
fusion activities including anti-terrorism task forces, Joint Terrorism Task Forces
(JTTFs), Area Maritime Security Committees (as required by the Maritime
4

Nongovernmental entities include the private sector and private nonprofit, faith-based, community, volunteer and other
nongovernmental organizations.
5
The effectiveness of a request for the use of funds for allowable organizational costs will be judged on the Investment Justification
to illustrate the need for such resources to effectively achieve a capability that will have a meaningful impact in the reduction of risk.
6
Note: Both organizational costs (e.g., intel analysts, operational overtime) and planning, equipment, training, exercise personnel
costs are applied towards the 50 percent personnel cap.

18

Transportation Security Act of 2002), DHS Border Enforcement Security Task
Forces, and Integrated Border Enforcement Teams. Tribes must submit to DHS a
written letter from a Federal agency which explicitly requests tribal staff participation
in an eligible activity or illustrates how the activities support the roles and
responsibilities of fusion centers as noted in Appendix 1 of the National Strategy for
Information Sharing and provides an estimate of the size of the request in manhours. Grant funding can only be used in proportion to the Federal man-hour
estimate, and only after funding for these activities from other Federal sources (i.e.
FBI JTTF payments to tribal agencies) has been exhausted. Under no
circumstances should DHS grant funding be used to pay for costs already supported
by funding from another Federal source.
•

Intelligence Analysts. Per the Personnel Reimbursement for Intelligence
Cooperation and Enhancement (PRICE) of Homeland Security Act (Public Law 110412), SHSP funds may be used to hire new staff and/or contractor positions to serve
as intelligence analysts to enable information/intelligence sharing capabilities, as
well as support existing intelligence analysts previously covered by SHSP funding.
In order to be hired as an intelligence analyst, staff and/or contractor personnel must
meet at least one of the following criteria:
o Successfully complete training to ensure baseline proficiency in intelligence
analysis and production within six months of being hired; and/or,
o Previously served as an intelligence analyst for a minimum of two years either in
a Federal intelligence agency, the military, or State and/or local law enforcement
intelligence unit.

All intelligence analyst training should be in accordance with Global’s Minimum Criminal
Intelligence Training Standards for Law Enforcement and Other Criminal Justice
Agencies in the United States, which outlines the minimum categories of training
needed for intelligence analysts. These include subject-matter expertise, analytic
methodologies, customer-service ethics, information handling and processing skills,
critical thinking skills, computer literacy, and objectivity and intellectual honesty. A
certificate of completion of such training must be on file with the tribe and the
designated State or Urban Area fusion center, and must be made available to FEMA
Headquarters Program Analysts upon request.
Equipment Activities
The 21 allowable prevention, protection, response, and recovery equipment categories
and equipment standards for FY 2009 SHSP are listed on the web-based version of the
Authorized Equipment List (AEL) on the Responder Knowledge Base (RKB), at
https://www.rkb.us.
The Standardized Equipment List (SEL) is located at this site as well. In some cases,
items on the SEL are not allowable under SHSP or will not be eligible for purchase
unless specific conditions are met. Unless otherwise stated, equipment must meet all
mandatory regulatory and/or DHS-adopted standards to be eligible for purchase using

19

these funds. In addition, agencies will be responsible for obtaining and maintaining all
necessary certifications and licenses for the requested equipment.
Training Activities
Tribes are strongly encouraged to use SHSP funds to develop or enhance a tribal
homeland security training program. Allowable training-related costs under SHSP Tribal
include the establishment, support, conduct, and attendance of training specifically
identified under the SHSP grant program. Allowable training topics include, but are not
limited to, CBRNE terrorism, cyber/agriculture/food security, intelligence gathering and
analysis, NIMS related training, citizen and community preparedness, and training for
volunteers.
Training conducted using SHSP funds should address a performance gap identified
through an After Action Report/Improvement Plan (AAR/IP) or contribute to building a
capability that will be evaluated through an exercise. Exercises should be used to
provide the opportunity to demonstrate and validate skills learned in training, as well as
to identify training gaps. Any training or training gaps should be identified in the AAR/IP
and addressed in the State or Urban Area training cycle. All training and exercises
conducted with SHSP Tribal funds should support the development and testing of the
jurisdiction’s Emergency Operations Plan (EOP) or specific annexes, where applicable
they may also include development of plans tied to the 15 national planning scenarios,
or other tribe-specific planning scenarios.
Exercise Activities
Exercises conducted with FEMA support must be managed and executed in
accordance with the Homeland Security Exercise and Evaluation Program (HSEEP).
HSEEP Volumes One, Two, and Three contain guidance for exercise design,
development, conduct, evaluation, and improvement planning. HSEEP Volume Four
provides sample exercise materials and HSEEP Volume Five: Prevention Exercises
contains guidance and recommendations for designing, developing, conducting, and
evaluating prevention-focused exercises. All volumes can be found at
http://hseep.dhs.gov.
All exercises using SHSP Tribal funding must be NIMS compliant. More information is
available online at the NIMS Integration Center,
http://www.fema.gov/emergency/nims/index.shtm.
Personnel Activities
Personnel hiring, overtime, and backfill expenses are permitted under this grant in order
to perform allowable FY 2009 SHSP planning, training, exercise, and equipment
activities.
•

A personnel cap of up to 50 percent of total program funds may be used for
personnel activities as directed by the Personnel Reimbursement for Intelligence
Cooperation and Enhancement (PRICE) of Homeland Security Act (Public Law
110-412). Grantees who wish to seek a waiver from the personnel cap must

20

provide documentation explaining why the cap is unacceptable; waiver requests
will be considered only under extreme circumstances. In general, the use of
SHSP grant funding to pay for staff and/or contractor regular time or
overtime/backfill is considered a personnel cost. Activities that are considered
“personnel”, and therefore count against the personnel cap of 50 percent include,
but are not limited to:
•
•
•
•
•
•
•

Operational overtime
Overtime/backfill to participate in approved training or exercise deliveries
Salaries and personnel costs of intelligence analysts
Overtime to participate in intelligence sharing activities
Salaries and personnel costs of planners, equipment managers, exercise
coordinators, and/or training coordinators
Salaries and personnel costs under the M&A category
Contractor costs associated with performing the above activities

FY 2009 SHSP funds may not be used to support the hiring of any personnel for the
purposes of fulfilling traditional public safety duties or to supplant traditional public
safety positions and responsibilities.
The following are definitions for the terms as used in this grant guidance:
•

•

•

•

Hiring – Tribal entities may use grant funding to cover the salary of newly hired
personnel who are exclusively undertaking allowable FEMA program activities as
specified in this guidance. This may not include new personnel who are hired to
fulfill any non-FEMA program activities under any circumstances. Hiring will
always result in a net increase of FTEs.
Overtime – These expenses are limited to the additional costs which result from
personnel working over and above 40 hours of weekly work time as a direct
result of their performance of FEMA-approved activities specified in this
guidance. Overtime associated with any other activity is not eligible.
Backfill-related Overtime – Also called “Overtime as Backfill,” these expenses
are limited to overtime costs which result from personnel who are working
overtime (as identified above) to perform the duties of other personnel who are
temporarily assigned to FEMA-approved activities outside their core
responsibilities. Neither overtime nor backfill expenses are the result of an
increase of Full-Time Equivalent (FTE) employees.
Supplanting – Replacing a currently budgeted position with one or more full-time
employees or contracted supported in whole or in part with Federal funds.
Supplanting is prohibited with grant funds.

Construction and Renovation
Use of SHSP funds for construction and renovation is generally prohibited except as
outlined below. Such construction and renovation shall be strictly limited and allowable
only when it is a necessary component of a security system at critical infrastructure
facilities.

21

Project construction and renovation not exceeding $1,000,000 is allowable, as deemed
necessary. The following types of projects are considered to constitute construction or
renovation, and must be submitted to FEMA for compliance review and approval under
Federal environmental planning and historic preservation (EHP) laws and requirements
prior to initiation of the project:
•
•
•
•

Construction of and renovation to guard facilities.
Renovation of and modifications, including the installation of security and
communication equipment, to buildings and structures that are 50 years old or
older.
Any other construction or renovation efforts that change or expand the footprint
of a facility or structure, including security enhancements to improve perimeter
security.
Physical security enhancements, including but not limited to:
o Lighting
o Fencing
o Closed-circuit television (CCTV) systems
o Motion detection systems
o Barriers, doors, gates and related security enhancements

In addition, the erection of communications towers that are included in a
jurisdiction’s interoperable communications plan is allowed, subject to all
applicable laws, regulations, and licensing provisions. Communication tower
projects must be submitted to FEMA for EHP review. Communications towers are
not subject to the $1,000,000 construction and renovation cap.
In order to draw down funds for construction and renovation costs under SHSP
grantees must provide to FEMA:
•
•
•
•
•

A description of the asset or facility, asset location, whether the infrastructure is
publicly or privately owned, and the construction or renovation project
Certification that a facility vulnerability assessment has been conducted
An outline addressing how the construction or renovation project will address the
identified vulnerabilities from the assessment
Consequences of not implementing the construction or renovation project
Any additional information requested by FEMA to ensure compliance with
Federal environmental and historic preservation requirements.

Grantees should refer to FEMA’s Information Bulletin #271, Environmental and Planning
and Historic Preservation Requirements for Grants, available at
http://ojp.usdoj.gov/odp/docs/info271.pdf. Additional information may also be found on
the FEMA’s website located at http://www.fema.gov/plan/ehp/.

22

Law Enforcement Terrorism Prevention Activities Allowable Costs
Sec. 2006 under the 9/11 Act includes allowability for the following activities, while also
subject to the 50 percent personnel cap:
•
•
•
•
•

Overtime expenses consistent with a State homeland security plan, including
enhanced operations in support of federal agencies, including border security
and border crossing enforcement;
Establishing, enhancing and staffing State, local and regional fusion centers;
Paying salaries and benefits for personnel to serve as qualified intelligence
analysts;
Any other terrorism prevention activity authorized by the Administrator
Provisions from Sec. 2008 also apply

Tribes are required to ensure that at least 25 percent of their SHSP award funds are
dedicated towards law enforcement terrorism prevention-oriented planning,
organization, training, exercise, and equipment activities. These include the following
activities:
•
•
•
•
•

•
•

Information sharing and analysis
Target hardening
Threat recognition
Terrorist interdiction
Subject to the limitations on Organization and Personnel Costs outlined above,
overtime expenses consistent with homeland security plans, including for the
provision of enhanced law enforcement operations in support of Federal
agencies, including for increased border security and border crossing
enforcement
Subject to the limitations on Organization and Personnel Costs outlined above,
participating in and staffing fusion centers with appropriately qualified personnel
Subject to the limitations on Organization and Personnel Costs outlined above,
paying salaries and benefits for personnel, including individuals employed by the
grant recipient on the date of the relevant grant application, to serve as qualified
intelligence analysts

23

PART V.

APPLICATION REVIEW INFORMATION
A. Review Criteria
The FY 2009 SHSP will allocate funding based on a combination of the risk and
effectiveness analyses. Applications will be evaluated through a national review
process. The national review process will assess the completeness, adherence to
programmatic guidelines, feasibility, and how well the proposed Investment addresses
the identified need(s) or capability shortfall(s). The Investment Justification requires
narrative on strategic alignment, funding plan, milestones and metrics, project
management, potential challenges, impact, and sustainability for each Investment .
This information will be used to evaluate the anticipated effectiveness of all proposed
Investments. Please refer to Section IV.B. for the Investment Justification questions
and scoring criteria.
B. Review Process
For FY 2009, eligible tribal applications will be reviewed and scored based on the
anticipated effectiveness of proposed Investments. Applications will be evaluated
through the national review process for completeness, adherence to programmatic
guidelines, feasibility, and how well the proposed Investment addresses the identified
need(s) or capability shortfall(s).
Eligible tribes are strongly encouraged to participate as reviewers in the FY 2009
national review process. Participation in the process will provide reviewers the unique
opportunity to gain insight into the evaluation process and to learn innovative ideas
being utilized by their peers.
Tribes have historically been identified as a partner of homeland security and have been
encouraged to embrace nationally-identified guidelines and initiatives. The Department
of Homeland Security (DHS) continues to encourage tribal entities to embrace these
guidelines and initiatives and to collaborate with their local and State homeland security
counterparts.
The Department will ensure that the Investment Justification review process be
conducted in a fair and equitable manner. Tribal applications will be reviewed by
subject matter experts who are familiar with tribal matters. The funding amount for
FY 2009 SHSP Tribal Supplemental awards will be based on combination of the risk
and effectiveness analyses.

24

The following process will be used to make awards under the program:
•

FEMA will verify compliance with all administrative and eligibility criteria identified
in the application kit, to include the required submission of Investment
Justifications and homeland security plans (such as State Preparedness
Reports) by the established due dates.

•

Eligible applications will be reviewed and scored through a national review
process to analyze the anticipated effectiveness of proposed Investments.
Homeland security plans (such as State Preparedness Reports) will be reviewed
during the national review for context, but will not be scored.

•

FEMA will use the results of both the risk analysis and the national review to
make recommendations for funding to the FEMA Administrator and Secretary of
Homeland Security.

Note: Upon award, the recipient may only fund Investments that were included in
the FY 2009 Investment Justification that was submitted to FEMA and evaluated
through the national review process. In addition, release of SHSP funding is
subject to successful completion and approval of Investment Justifications.
C. Anticipated Announcement and Award Dates
FEMA will evaluate and act on applications within 90 days following close of the
application period, consistent with the Consolidated Security, Disaster Assistance, and
Continuing Appropriations Act, 2009 (Public Law 110-329). Awards will be made on or
before September 30, 2009.

25

PART VI.

AWARD ADMINISTRATION INFORMATION
A. Notice of Award
Upon approval of an application, the grant will be awarded to the grant recipient. The
date that this is done is the “award date.” Notification of award approval is made
through the Grants Management System (GMS). Once an award has been approved, a
notice is sent to the authorized grantee official. Follow the directions in the notification
and log into GMS to access the award documents. The authorized grantee official
should carefully read the award and special condition documents. If you do not receive
a notification, please contact your Program Analyst for your award number. Once you
have the award number, contact the GMS Help Desk at (888) 549-9901, option 3, to
obtain the username and password associated with the new award.
The period of performance is 36 months. Any unobligated funds will be deobligated at
the end of the 90 day close-out period. Extensions to the period of performance will be
considered only through formal requests to FEMA with specific and compelling
justifications why an extension is required.
B. Administrative and National Policy Requirements
1. Standard Financial Requirements. The grantee and any subgrantee shall comply
with all applicable laws and regulations. A non-exclusive list of regulations
commonly applicable to DHS grants are listed below:
1.1 -- Administrative Requirements.
• 44 CFR Part 13, Uniform Administrative Requirements for Grants and
Cooperative Agreements to State and Local Governments
• 2 CFR Part 215, Uniform Administrative Requirements for Grants and
Agreements with Institutions of Higher Education, Hospitals, and Other
Non-Profit Organizations (OMB Circular A-110)
1.2 -- Cost Principles.
• 2 CFR Part 225, Cost Principles for State, Local, and Indian Tribal
Governments (OMB Circular A-87)
• 2 CFR Part 220, Cost Principles for Educational Institutions (OMB Circular
A-21)
• 2 CFR Part 230, Cost Principles for Non-Profit Organizations (OMB
Circular A-122)
• Federal Acquisition Regulations (FAR), Part 31.2 Contract Cost Principles
and Procedures, Contracts with Commercial Organizations
26

1.3 -- Audit Requirements.
• OMB Circular A-133, Audits of States, Local Governments, and Non-Profit
Organizations
1.4 -- Duplication of Benefits. There may not be a duplication of any federal
assistance, per A-87, Basic Guidelines Section C.3 (c), which states: Any cost
allocable to a particular Federal award or cost objective under the principles
provided for in this Circular may not be charged to other Federal awards to
overcome fund deficiencies, to avoid restrictions imposed by law or terms of the
Federal awards, or for other reasons. However, this prohibition would not
preclude governmental units from shifting costs that are allowable under two or
more awards in accordance with existing program agreements.
2. Non-supplanting Requirement. Grant funds will be used to supplement existing
funds, and will not replace (supplant) funds that have been appropriated for the
same purpose. Applicants or grantees may be required to supply documentation
certifying that a reduction in non-Federal resources occurred for reasons other than
the receipt or expected receipt of Federal funds.
3. Technology Requirements.
3.1 -- National Information Exchange Model (NIEM). FEMA requires all
grantees to use the latest NIEM specifications and guidelines regarding the use
of Extensible Markup Language (XML) for all grant awards. Further information
about the required use of NIEM specifications and guidelines is available at
http://www.niem.gov.
3.2 -- Geospatial Guidance. Geospatial technologies capture, store, analyze,
transmit, and/or display location-based information (i.e., information that can be
linked to a latitude and longitude). FEMA encourages grantees to align any
geospatial activities with the guidance available on the FEMA website at
http://www.fema.gov/grants.
3.3 -- 28 CFR Part 23 guidance. FEMA requires that any information
technology system funded or supported by these funds comply with 28 CFR Part
23, Criminal Intelligence Systems Operating Policies, if this regulation is
determined to be applicable.
4. Administrative Requirements.
4.1 -- Freedom of Information Act (FOIA). FEMA recognizes that much of the
information submitted in the course of applying for funding under this program or
provided in the course of its grant management activities may be considered law
enforcement sensitive or otherwise important to national security interests. While
this information under Federal control is subject to requests made pursuant to the
Freedom of Information Act (FOIA), 5 U.S.C. §552, all determinations concerning
the release of information of this nature are made on a case-by-case basis by the

27

FEMA FOIA Office, and may likely fall within one or more of the available
exemptions under the Act. The applicant is encouraged to consult its own State
and local laws and regulations regarding the release of information, which should
be considered when reporting sensitive matters in the grant application, needs
assessment and strategic planning process. The applicant may also consult
FEMA regarding concerns or questions about the release of information under
State and local laws. The grantee should be familiar with the regulations
governing Sensitive Security Information (49 CFR Part 1520), as it may provide
additional protection to certain classes of homeland security information.
4.2 -- Protected Critical Infrastructure Information (PCII). The PCII Program,
established pursuant to the Critical Infrastructure Information Act of 2002 (Public
Law 107-296) (CII Act), created a new framework, which enables State and local
jurisdictions and members of the private sector to voluntarily submit sensitive
information regarding critical infrastructure to DHS. The Act also provides
statutory protection for voluntarily shared CII from public disclosure and civil
litigation. If validated as PCII, these documents can only be shared with
authorized users who agree to safeguard the information.
PCII accreditation is a formal recognition that the covered government entity has
the capacity and capability to receive and store PCII. DHS encourages all tribes
to pursue PCII accreditation to cover their State government and attending local
government agencies. Accreditation activities include signing a memorandum of
agreement (MOA) with DHS, appointing a PCII Officer, and implementing a selfinspection program. For additional information about PCII or the accreditation
process, please contact the DHS PCII Program Office at pcii-info@dhs.gov.
4.3 -- Compliance with Federal civil rights laws and regulations. The
grantee is required to comply with Federal civil rights laws and regulations.
Specifically, the grantee is required to provide assurances as a condition for
receipt of Federal funds that its programs and activities comply with the following:
•

Title VI of the Civil Rights Act of 1964, as amended, 42. U.S.C. 2000 et.
seq. – no person on the grounds of race, color, or national origin will be
excluded from participation in, be denied the benefits of, or be otherwise
subjected to discrimination in any program or activity receiving Federal
financial assistance.

•

Section 504 of the Rehabilitation Act of 1973, as amended, 29 U.S.C. 794
– no qualified individual with a disability in the United States, shall, by
reason of his or her disability, be excluded from the participation in, be
denied the benefits of, or otherwise be subjected to discrimination in any
program or activity receiving Federal financial assistance.

28

•

Title IX of the Education Amendments of 1972, as amended, 20 U.S.C.
1681 et. seq. – discrimination on the basis of sex is eliminated in any
education program or activity receiving Federal financial assistance.

•

The Age Discrimination Act of 1975, as amended, 20 U.S.C. 6101 et. seq.
– no person in the United States shall be, on the basis of age, excluded
from participation in, denied the benefits of or subjected to discrimination
under any program or activity receiving Federal financial assistance.

Grantees must comply with all regulations, guidelines, and standards adopted
under the above statutes. The grantee is also required to submit information, as
required, to the DHS Office for Civil Rights and Civil Liberties concerning its
compliance with these laws and their implementing regulations.
4.4 -- Services to limited English proficient (LEP) persons. Recipients of
FEMA financial assistance are required to comply with several Federal civil rights
laws, including Title VI of the Civil Rights Act of 1964, as amended. These laws
prohibit discrimination on the basis of race, color, religion, natural origin, and sex
in the delivery of services. National origin discrimination includes discrimination
on the basis of limited English proficiency. To ensure compliance with Title VI,
recipients are required to take reasonable steps to ensure that LEP persons have
meaningful access to their programs. Meaningful access may entail providing
language assistance services, including oral and written translation, where
necessary. The grantee is encouraged to consider the need for language
services for LEP persons served or encountered both in developing their
proposals and budgets and in conducting their programs and activities.
Reasonable costs associated with providing meaningful access for LEP
individuals are considered allowable program costs. For additional information,
see http://www.lep.gov.
4.5 -- Integrating individuals with disabilities into emergency planning.
Section 504 of the Rehabilitation Act of 1973, as amended, prohibits
discrimination against people with disabilities in all aspects of emergency
mitigation, planning, response, and recovery by entities receiving financial from
FEMA. In addition, Executive Order 13347, Individuals with Disabilities in
Emergency Preparedness signed in July 2004, requires the Federal Government
to support safety and security for individuals with disabilities in situations
involving disasters, including earthquakes, tornadoes, fires, floods, hurricanes,
and acts of terrorism. Executive Order 13347 requires the Federal government
to encourage consideration of the needs of individuals with disabilities served by
State, local, and tribal governments in emergency preparedness planning.
FEMA has several resources available to assist emergency managers in
planning and response efforts related to people with disabilities and to ensure
compliance with Federal civil rights laws:

29

•

Comprehensive Preparedness Guide 301 (CPG-301): Interim
Emergency Management Planning Guide for Special Needs
Populations: CPG-301 is designed to aid tribal, State, territorial, and
local governments in planning for individuals with special needs. CPG301 outlines special needs considerations for: Developing Informed
Plans; Assessments and Registries; Emergency Public
Information/Communication; Sheltering and Mass Care; Evacuation;
Transportation; Human Services/Medical Management; Congregate
Settings; Recovery; and Training and Exercises. CPG-301 is available
at http://www.fema.gov/pdf/media/2008/301.pdf.

•

Guidelines for Accommodating Individuals with Disabilities in
Disaster: The Guidelines synthesize the array of existing accessibility
requirements into a user friendly tool for use by response and recovery
personnel in the field. The Guidelines are available at
http://www.fema.gov/oer/reference/.

•

Disability and Emergency Preparedness Resource Center: A webbased “Resource Center” that includes dozens of technical assistance
materials to assist emergency managers in planning and response efforts
related to people with disabilities. The “Resource Center” is available at
http://www.disabilitypreparedness.gov.

•

Lessons Learned Information Sharing (LLIS) resource page on
Emergency Planning for Persons with Disabilities and Special
Needs: A true one-stop resource shop for planners at all levels of
government, non-governmental organizations, and private sector entities,
the resource page provides more than 250 documents, including lessons
learned, plans, procedures, policies, and guidance, on how to include
citizens with disabilities and other special needs in all phases of the
emergency management cycle.
LLIS.gov is available to emergency response providers and homeland
security officials from the Federal, State, and local levels. To access
the resource page, log onto http://www.LLIS.gov and click on
Emergency Planning for Persons with Disabilities and Special Needs
under Featured Topics. If you meet the eligibility requirements for
accessing Lessons Learned Information Sharing, you can request
membership by registering online.

4.6 -- Compliance with the National Energy Conservation Policy and Energy
Policy Acts. In accordance with the Consolidated Security, Disaster Assistance,
and Continuing Appropriations Act, 2009 (Public Law 110-329), grant funds must
comply with the following two requirements:

30

•

None of the funds made available shall be used in contravention of the
Federal buildings performance and reporting requirements of
Executive Order 13123, part 3 of title V of the National Energy
Conservation Policy Act (42 USC 8251 et. Seq.), or subtitle A of title I
of the Energy Policy Act of 2005 (including the amendments made
thereby).

•

None of the funds made available shall be used in contravention of
section 303 of the Energy Policy Act of 1992 (42 USC13212).

4.7 -- Environmental and Historic Preservation Compliance. FEMA is
required to consider the potential impacts to the human and natural environment
of projects proposed for FEMA funding. FEMA, through its Environmental and
Historic Preservation (EHP) Program, engages in a review process to ensure that
FEMA-funded activities comply with various Federal laws including: National
Environmental Policy Act, National Historic Preservation Act, Endangered
Species Act, and Executive Orders on Floodplains (11988), Wetlands (11990)
and Environmental Justice (12898). The goal of these compliance requirements
is to protect our nation’s water, air, coastal, wildlife, agricultural, historical, and
cultural resources, as well as to minimize potential adverse effects to children
and low-income and minority populations.
The grantee shall provide any information requested by FEMA to ensure
compliance with applicable Federal EHP requirements. Any project with the
potential to impact EHP resources cannot be initiated until FEMA has completed
its review. Grantees may be required to provide detailed information about the
project, including the following: location (street address or map coordinates);
description of the project including any associated ground disturbance work,
extent of modification of existing structures, construction equipment to be used,
staging areas, access roads, etc.; year the existing facility was built; natural,
biological, and/or cultural resources present in the project vicinity; visual
documentation such as site and facility photographs, project plans, maps, etc;
and possible project alternatives.
For certain types of projects, FEMA must consult with other Federal and State
agencies such as the U.S. Fish and Wildlife Service, State Historic Preservation
Offices, and the U.S. Army Corps of Engineers, as well as other agencies and
organizations responsible for protecting natural and cultural resources. For
projects with the potential to have significant adverse effects on the environment
and/or historic properties, FEMA’s EHP review and consultation may result in a
substantive agreement between the involved parties outlining how the grantee
will avoid the effects, minimize the effects, or, if necessary, compensate for the
effects.
Because of the potential for significant adverse effects to EHP resources or
public controversy, some projects may require an additional assessment or

31

report, such as an Environmental Assessment, Biological Assessment,
archaeological survey, cultural resources report, wetlands delineation, or other
document, as well as a public comment period. Grantees are responsible for the
preparation of such documents, as well as for the implementation of any
treatment or mitigation measures identified during the EHP review that are
necessary to address potential adverse impacts. Grantees may use these funds
toward the costs of preparing such documents and/or implementing treatment or
mitigation measures. Failure of the grantee to meet Federal, State, and local
EHP requirements, obtain applicable permits, and comply with any conditions
that may be placed on the project as the result of FEMA’s EHP review may
jeopardize Federal funding.
Recipient shall not undertake any project having the potential to impact EHP
resources without the prior approval of FEMA, including but not limited to
communications towers, physical security enhancements, new construction, and
modifications to buildings, structures and objects that are 50 years old or
greater. Recipient must comply with all conditions placed on the project as the
result of the EHP review. Any change to the approved project scope of work will
require re-evaluation for compliance with these EHP requirements. If ground
disturbing activities occur during project implementation, the recipient must
ensure monitoring of ground disturbance, and if any potential archeological
resources are discovered, the recipient will immediately cease construction in
that area and notify FEMA and the appropriate State Historic Preservation
Office. Any construction activities that have been initiated without the
necessary EHP review and approval will result in a non-compliance finding
and will not eligible for FEMA funding.
For more information on FEMA’s EHP requirements, tribes should refer to
FEMA’s Information Bulletin #271, Environmental Planning and Historic
Preservation Requirements for Grants, available at
http://ojp.usdoj.gov/odp/docs/info271.pdf. Additional information and resources
can also be found at http://www.fema.gov/plan/ehp/ehp-applicant-help.shtm.
4.8 -- Royalty-free License. Applicants are advised that FEMA reserves a
royalty-free, non-exclusive, and irrevocable license to reproduce, publish, or
otherwise use, and authorize others to use, for Federal government purposes: (a)
the copyright in any work developed under an award or sub-award; and (b) any
rights of copyright to which an award recipient or sub-recipient purchases
ownership with Federal support. Award recipients must agree to consult with
FEMA regarding the allocation of any patent rights that arise from, or are
purchased with, this funding.
4.9 -- FEMA GPD Publications Statement. Applicants are advised that all
publications created with funding under any grant award shall prominently
contain the following statement: "This document was prepared under a grant
from FEMA’s Grant Programs Directorate, U.S. Department of Homeland
Security. Points of view or opinions expressed in this document are those of the
32

authors and do not necessarily represent the official position or policies of
FEMA’s Grant Programs Directorate or the U.S. Department of Homeland
Security."
4.10 -- Equipment Marking. Applicants are advised that, when practicable, any
equipment purchased with grant funding shall be prominently marked as follows:
"Purchased with funds provided by the U.S. Department of Homeland Security."
4.11 -- Disadvantaged Business Requirement. Applicants are advised that, to
the extent that recipients of a grant use contractors or subcontractors, such
recipients shall use small, minority, women-owned or disadvantaged business
concerns and contractors or subcontractors to the extent practicable.
4.12 -- National Preparedness Reporting Compliance. The Government
Performance and Results Act (Public Law 103-62) (GPRA) requires that the
Department collect and report performance information on all programs. For
grant programs, the prioritized Investment Justifications and their associated
milestones provide an important tool for assessing grant performance and
complying with these national preparedness reporting requirements. FEMA will
work with grantees to develop tools and processes to support this requirement.
FEMA anticipates using this information to inform future-year grant program
funding decisions. Award recipients must agree to cooperate with any
assessments, national evaluation efforts, or information or data collection
requests, including, but not limited to, the provision of any information required
for the assessment or evaluation of any activities within their grant agreement.
This includes any assessments, audits, or investigations conducted by the
Department of Homeland Security, Office of the Inspector General, or the
Government Accountability Office.
C. Reporting Requirements
Reporting requirements must be met throughout the life of the grant (refer to the
program guidance and the special conditions found in the award package for a full
explanation of these requirements. Please note that FEMA Payment and Reporting
System (PARS) contains edits that will prevent access to funds if reporting requirements
are not met on a timely basis.
1. Financial Status Report (FSR) -- required quarterly. Obligations and
expenditures must be reported on a quarterly basis through the FSR, which is due
within 30 days of the end of each calendar quarter (e.g., for the quarter ending
March 31, FSR is due no later than April 30). A report must be submitted for every
quarter of the period of performance, including partial calendar quarters, as well as
for periods where no grant activity occurs. Future awards and fund draw downs may
be withheld if these reports are delinquent. The final FSR is due 90 days after the
end date of the performance period.

33

FSRs must be filed online through the PARS.
Reporting periods and due dates:
• October 1 – December 31; Due January 30
• January 1 – March 31; Due April 30
• April 1 – June 30; Due July 30
• July 1 – September 30; Due October 30
2. Categorical Assistance Progress Report (CAPR). Following an award, the
awardees will be responsible for providing updated obligation and expenditure
information on a semi-annual basis. The applicable tribes are responsible for
completing and submitting the CAPR reports. Awardees should include a statement
in the narrative field of the CAPR that reads: See BSIR.
The CAPR is due within 30 days after the end of the reporting period (July 30 for the
reporting period of January 1 through June 30; and January 30 for the reporting
period of July 1 though December 31). Future awards and fund drawdowns may be
withheld if these reports are delinquent.
CAPRs must be filed online at https://grants.ojp.usdoj.gov. Guidance and
instructions can be found at https://grants.ojp.usdoj.gov/gmsHelp/index.html.
Required submission: CAPR (due semi-annually).
3. Biannual Strategy Implementation Reports (BSIR). Following an award, the
awardees will be responsible for providing updated obligation and expenditure
information on a semi-annual basis. The applicable SAAs are responsible for
completing and submitting the BSIR reports which is a component of the CAPR.
The BSIR submission will satisfy the narrative requirement of the CAPR. SAAs are
still required to submit the CAPR with a statement in the narrative field that reads:
See BSIR.
The BSIR is due within 30 days after the end of the reporting period (July 30 for the
reporting period of January 1 through June 30; and January 30 for the reporting
period of July 1 though December 31). Updated obligations and expenditure
information must be provided with the BSIR to show progress made toward meeting
strategic goals and objectives. Future awards and fund drawdowns may be withheld
if these reports are delinquent.
Required submission: BSIR (due semi-annually).
4. Exercise Evaluation and Improvement. Exercises, implemented with grant funds,
should be threat and performance-based and should evaluate performance of the
targeted capabilities required to respond to the exercise scenario. Guidance related
to the conduct exercise evaluations and the implementation of improvement is
defined in the Homeland Security Exercise and Evaluation Program (HSEEP)

34

Manual located at http://www.fema.gov/government/grant/administration.shtm.
Grant recipients must report on scheduled exercises and ensure that an After Action
Report (AAR) and Improvement Plan (IP) are prepared for each exercise conducted
with FEMA support (grant funds or direct support) and submitted to the FEMA
secure Portal (https://preparednessportal.dhs.gov/) within 60 days following
completion of the exercise.
The AAR documents the demonstrated performance of targeted capabilities and
identifies recommendations for improvements. The IP outlines an exercising
jurisdiction(s) plan to address the recommendations contained in the AAR. At a
minimum, the IP must identify initial action items and be included in the final AAR.
Guidance for the development of AARs and IPs is provided in the HSEEP manual.
Required submissions: AARs and IPs (as applicable).
5. Financial and Compliance Audit Report. Recipients that expend $500,000 or
more of Federal funds during their fiscal year are required to submit an organizationwide financial and compliance audit report. The audit must be performed in
accordance with the U.S. General Accountability Office, Government Auditing
Standards, located at http://www.gao.gov/govaud/ybk01.htm, and OMB Circular A133, Audits of States, Local Governments, and Non-Profit Organizations, located at
http://www.whitehouse.gov/omb/circulars/a133/a133.html. Audit reports are
currently due to the Federal Audit Clearinghouse no later than nine months after the
end of the recipient’s fiscal year. In addition, the Secretary of Homeland Security
and the Comptroller General of the United States shall have access to any books,
documents, and records of recipients of FY 2009 SHSP Tribal assistance for audit
and examination purposes, provided that, in the opinion of the Secretary or the
Comptroller, these documents are related to the receipt or use of such assistance.
The grantee will also give the sponsoring agency or the Comptroller, through any
authorized representative, access to, and the right to examine all records, books,
papers or documents related to the grant.
The State shall require that sub-grantees comply with the audit requirements set
forth in OMB Circular A-133. Recipients are responsible for ensuring that subrecipient audit reports are received and for resolving any audit findings.
Monitoring
Grant recipients will be monitored periodically by FEMA staff, both programmatically
and financially, to ensure that the project goals, objectives, performance requirements,
timelines, milestone completion, budgets, and other related program criteria are being
met. Programmatic monitoring may also include the Regional Federal Preparedness
Coordinators, when appropriate, to ensure consistency of project investments with
Regional and National goals and policies, as well as to help synchronize similar
investments ongoing at the Federal, State, and local levels.

35

Monitoring will be accomplished through a combination of office-based reviews and onsite monitoring visits. Monitoring will involve the review and analysis of the financial,
programmatic, performance and administrative issues relative to each program and will
identify areas where technical assistance and other support may be needed.
The recipient is responsible for monitoring award activities, to include sub-awards, to
provide reasonable assurance that the Federal award is administered in compliance
with requirements. Responsibilities include the accounting of receipts and
expenditures, cash management, maintaining of adequate financial records, and
refunding expenditures disallowed by audits.
Grant Close-Out Process
Within 90 days after the end of the period of performance, grantees must submit a final
FSR and final CAPR detailing all accomplishments throughout the project. After these
reports have been reviewed and approved by FEMA, a close-out notice will be
completed to close out the grant. The notice will indicate the project as closed, list any
remaining funds that will be deobligated, and address the requirement of maintaining
the grant records for three years from the date of the final FSR. The grantee is
responsible for returning any funds that have been drawndown but remain as
unliquidated on grantee financial records.
Required submissions: (1) final SF-269a, due 90 days from end of grant period;
and (2) final CAPR, due 90 days from the end of the grant period.

36

PART VII.

FEMA CONTACTS
This section describes several resources that may help applicants in completing a
FEMA grant application. During the application period FEMA will identify multiple
opportunities for a cooperative dialogue between the Department and applicants. This
commitment is intended to ensure a common understanding of the funding priorities and
administrative requirements associated with the FY 2009 SHSP Tribal, and to help in
submission of projects that will have the highest impact on reducing risks.
1. Centralized Scheduling & Information Desk (CSID) Help Line. CSID is a nonemergency resource for use by emergency responders across the nation. CSID is a
comprehensive coordination, management, information, and scheduling tool
developed by DHS through FEMA for homeland security terrorism preparedness
activities. CSID provides general information on all FEMA grant programs and
information on the characteristics of CBRNE, agro-terrorism, defensive equipment,
mitigation techniques, and available Federal assets and resources.
CSID maintains a comprehensive database containing key personnel contact
information for homeland security terrorism preparedness programs and events.
These contacts include personnel at the Federal, State and local levels. CSID can
be contacted at (800) 368-6498 or askcsid@dhs.gov. CSID hours of operation are
from 8:00 am–6:00 pm (EST), Monday-Friday.
2. Grant Programs Directorate (GPD). FEMA GPD will provide fiscal support,
including pre- and post-award administration and technical assistance, to the grant
programs included in this solicitation. Additional guidance and information can be
obtained by contacting the FEMA Call Center at (866) 927-5646 or via e-mail to
ASK-GMD@dhs.gov.
3. GSA’s State and Local Purchasing Programs. The U.S. General Services
Administration (GSA) offers two efficient and effective procurement programs for
State and local governments to purchase products and services to fulfill homeland
security and other technology needs. The GSA Schedules (also referred to as the
Multiple Award Schedules and the Federal Supply Schedules) are long-term,
indefinite delivery, indefinite quantity, government-wide contracts with commercial
firms of all sizes.
•

Cooperative Purchasing Program
Cooperative Purchasing, authorized by statute, allows State and local
governments to purchase a variety of supplies (products) and services under

37

specific GSA Schedule contracts to save time, money, and meet their
everyday needs and missions.
The Cooperative Purchasing program allows State and local governments to
purchase alarm and signal systems, facility management systems, firefighting
and rescue equipment, law enforcement and security equipment, marine craft
and related equipment, special purpose clothing, and related services off of
Schedule 84 and Information Technology products and professional services
off of Schedule 70 and the Consolidated Schedule (containing IT Special Item
Numbers) only. Cooperative Purchasing for these categories is authorized
under Federal law by the Local Preparedness Acquisition Act (Public Law
110-248) and Section 211 of the E-Government Act of 2002 (Public Law 107347).
Under this program, State and local governments have access to GSA
Schedule contractors who have voluntarily modified their contracts to
participate in the Cooperative Purchasing program. The U.S. General
Services Administration provides a definition of State and local governments
as well as other vital information under the frequently asked questions section
on its website at http://www.gsa.gov/cooperativepurchasing.
•

Disaster Recovery Purchasing Program
GSA plays a critical role in providing disaster recovery products and services
to Federal agencies. Now State and Local Governments can also benefit
from the speed and savings of the GSA Federal Supply Schedules.
Section 833 of the John Warner National Defense Authorization Act for Fiscal
Year 2007 (Public Law 109-364) amends 40 U.S.C. §502 to authorize GSA to
provide State and Local governments the use of ALL GSA Federal Supply
Schedules for purchase of products and services to be used to facilitate
recovery from a major disaster declared by the President under the Robert T.
Stafford Disaster Relief and Emergency Assistance Act or to facilitate
recovery from terrorism or nuclear, biological, chemical, or radiological
attack.

GSA provides additional information on the Disaster Recovery Purchasing Program
website at http://www.gsa.gov/disasterrecovery.
State and local governments can find a list of contractors on GSA’s website,
http://www.gsaelibrary.gsa.gov, denoted with a
or
symbol.
Assistance is available from GSA on the Cooperative Purchasing and Disaster
Purchasing Program at the local and national levels. For assistance at the local
level, visit http://www.gsa.gov/csd to find a local customer service director in your
area. For assistance at the national level, contact Tricia Reed at
tricia.reed@gsa.gov, (571) 259-9921. More information is available on all GSA
State and local programs at: www.gsa.gov/stateandlocal.

38

4. Exercise Direct Support. FEMA provides support to Regions, States, and local
jurisdictions in accordance with State Homeland Security Strategies and the
Homeland Security Exercise and Evaluation Program (HSEEP). Support is available
to conduct a Training and Exercise Plan (TEP) workshop, to develop a Multi-year
TEP, and to build or enhance the capacity of a jurisdiction to design, develop,
conduct, and evaluate effective exercises.
In FY 2009, support for planning and conduct of exercises has shifted in strategy
from a State-focused approach, organized by National Preparedness Directorate
Headquarters, to a regional (multi-State) approach, organized by the FEMA
Regions, to more effectively integrate national, regional, territorial, tribal, State, and
local preparedness exercises. At this time, the Regional Exercise Support Program
will support discussion-based exercises (i.e., seminar, workshop or tabletop),
operations-based exercises (i.e. drills, functional exercises, full scale exercises), and
TEP workshops within each of the 10 FEMA Regions. The Regional Exercise
Support Program support is not limited to new exercise initiatives and can be applied
to ongoing exercises to maintain continuity of existing planning schedules.
Applicants are encouraged to coordinate requests for exercise support through the
appropriate FEMA Regional Exercise Officer. State requests for support will be
considered, however, priority will be given to exercise initiatives that support
collaboration within a Region.
Additional guidance on the Regional Exercise Support Program to include the
application process and information on the HSEEP is available on the HSEEP
website, https://hseep.dhs.gov.
5. Homeland Security Preparedness Technical Assistance Program. The
Homeland Security Preparedness Technical Assistance Program (HSPTAP)
provides direct support assistance on a first-come, first-served basis (and subject to
the availability of funding) to eligible organizations to enhance their capacity and
preparedness to prevent, protect against, respond to, and recover from terrorist and
all hazard threats. In addition to the risk assessment assistance already being
provided, FEMA also offers a variety of other direct support assistance programs.
More information can be found at http://www.fema.gov/about/divisions/pppa_ta.shtm.
6. Lessons Learned Information Sharing (LLIS) System. LLIS is a national, online,
secure website that houses a collection of peer-validated lessons learned, best
practices, AARs from exercises and actual incidents, and other relevant homeland
security documents. LLIS facilitates improved preparedness nationwide by providing
response professionals with access to a wealth of validated front-line expertise on
effective planning, training, equipping, and operational practices for homeland
security.
The LLIS website also includes a national directory of homeland security officials, as
well as an updated list of homeland security exercises, events, and conferences.

39

Additionally, LLIS includes online collaboration tools, including secure email and
message boards, where users can exchange information. LLIS uses strong
encryption and active site monitoring to protect all information housed on the
system. The LLIS website is https://www.llis.gov.
7. Information Sharing Systems. FEMA encourages all State, regional, local, and
Tribal entities using FY 2009 funding in support of information sharing and
intelligence fusion and analysis centers to leverage available Federal information
sharing systems, including Law Enforcement Online (LEO) and the Homeland
Security Information Network (HSIN). For additional information on LEO, contact the
LEO Program Office at leoprogramoffice@leo.gov or (202) 324-8833. For additional
information on HSIN and available technical assistance, contact the HSIN Help Desk
at (703) 674-3003.

40

PART VIII.

OTHER INFORMATION - SHSP TRIBAL
ALLOWABLE EXPENSES
Overview
The following provides guidance on allowable costs within Planning, Equipment,
Training, and Exercise activities.
Planning Activities Information
The FY 2009 SHSP Tribal Guidance and Application Kit defines five broad categories of
allowable planning costs. Following are examples for each of the categories. The
personnel caps noted earlier will still apply.
•

Developing scenario plans that incorporate the range of prevention, protection,
response, and recovery activities for a scenario

•

Developing and implementing homeland security support programs and adopting
DHS national initiatives including but not limited to the following:
o
o

o
o
o
o
o
o
o

•

Implementing the National Preparedness Guidelines
Costs associated with the adoption, implementation and adherence to
NIMS compliance requirements; including implementing the NIMS
National Credentialing Framework.
Modifying existing incident management and EOPs to ensure proper
alignment with the NRF coordinating structures, processes, and protocols
Establishing or enhancing mutual aid agreements
Developing communications and interoperability protocols and solutions
Conducting tribal program implementation meetings
Developing or updating resource inventory assets in accordance to typed
resource definitions issued by the NIMS Integration Center (NIC)
Designing tribal geospatial data systems
Conducting public education and outreach campaigns, including
promoting individual, family and business emergency preparedness; alerts
and warnings education; and evacuation plans as well as IED or bombing
prevention awareness

Developing related terrorism prevention activities including:
o

Developing law enforcement prevention activities, to include participating
in designated State or Urban Area fusion centers

41

o
o
o

o
o

o
o
o

o
o
o
o
•

Hiring an IT specialist to plan, develop, and implement the IT applications
necessary to share information with a fusion center
Participating in information/intelligence sharing groups
Integrating and coordinating the sharing of tribal public health care and
health security data-gathering (threats to human and animal health) with
State and local fusion centers to achieve early warning and mitigation of
health events
Integrating and coordinating the sharing of information with the private
sector
Acquiring systems allowing connectivity to State, local, and Federal data
networks, such as the National Crime Information Center (NCIC) and
Integrated Automated Fingerprint Identification System (IAFIS), as
appropriate
Planning to enhance security during heightened alerts, during terrorist
incidents, and/or during mitigation and recovery
Multi-discipline preparation across first responder community, including
EMS for response to catastrophic events and acts of terrorism
Conducting public education campaigns, including promoting individual,
family and business emergency preparedness; promoting the Ready
campaign; and/or creating State, regional or local emergency
preparedness efforts that build upon the Ready campaign
Evaluating CIP security equipment and/or personnel requirements to
protect and secure sites
CIP cost assessments, including resources (e.g., financial, personnel)
required for security enhancements/deployments
Multi-Jurisdiction Bombing Prevention Plans (MJBPP)7
Underwater Terrorist Protection Plans

Developing and enhancing plans and protocols, including but not limited to:
o
o
o

o
o

o
o

Developing or enhancing EOPs and operating procedures
Developing or enhancing tribal strategic or tactical interoperable
emergency communications plans
Developing protocols or standard operating procedures for specialized
teams to incorporate the use of equipment acquired through this grant
program
Developing terrorism prevention/deterrence plans
Developing plans, procedures, and requirements for the management of
infrastructure and resources related to SHSP Tribal and implementation of
Homeland Security Strategies
Developing or enhancing border security plans
Developing or enhancing cyber security plans

7

The SAA should examine current bombing prevention and explosive device response capabilities as an import risk reduction
activity. An explosive devise recognition capability analysis can assist in determining their opportunities for increasing the capability
to execute steady state and threat initiated tasks to prevent and respond to a bombing incident.

42

o
o
o
o
o

o
o
o
o

o
o
o

o
o
o

o
o
•

Developing or enhancing secondary health screening protocols at major
points of entry (air, rail, port)
Developing or enhancing cyber risk mitigation plans
Developing or enhancing agriculture/food security risk mitigation,
response, and recovery plans
Developing public/private sector partnership emergency response,
assessment, and resource sharing plans
Developing or enhancing plans to engage and interface with, and to
increase the capacity of, private sector/non-governmental entities working
to meet the human service response and recovery needs of victims
Developing or updating local or regional communications plans
Developing plans to support and assist jurisdictions, such as port
authorities and rail and mass transit agencies
Developing or enhancing continuity of operations and continuity of
government plans
Developing or enhancing existing catastrophic incident response and
recovery plans to include and integrate Federal assets provided under the
NRF
Developing or enhancing evacuation plans
Developing or enhancing citizen surge capacity
Developing or enhancing plans for donations and volunteer management
and the engagement/integration of private sector/non-governmental
entities in preparedness, response, and recovery activities
Developing or enhancing Bombing Prevention Plans
Developing school preparedness plans
Ensuring jurisdiction EOPs adequately address warnings, emergency
public information, evacuation, sheltering, mass care, resource
management from non-governmental sources, unaffiliated volunteer and
donations management, and volunteer resource integration to support
each Emergency Support Function, to include appropriate considerations
for special needs populations
Developing and implementing civil rights, civil liberties and privacy
policies, procedures, and protocols
Designing and developing tribal geospatial data systems

Developing or conducting assessments, including but not limited to:
o
o
o
o
o

Conducting point vulnerability assessments at critical infrastructure
sites/key assets and develop remediation/security plans
Conducting or updating interoperable emergency communications
capabilities assessments at the tribal level
Developing border security operations plans in coordination with CBP
Updating and refining threat matrices
Conducting cyber risk and vulnerability assessments

43

o

o
o

o
o

o

Conducting assessments and exercising existing catastrophic incident
response and recovery plans and capabilities to identify critical gaps that
cannot be met by existing local and State resources
Conducting Bombing Prevention Capability Analysis
Activities that directly support the identification of specific catastrophic
incident priority response and recovery projected needs across disciplines
(e.g. law enforcement, fire, EMS, public health, behavioral health, public
works, agriculture, information technology, and citizen preparedness)
Activities that directly support the identification of pre-designated
temporary housing sites
Conducting community assessments, surveys, and research of
vulnerabilities and resource needs, and determine citizen education and
participation to meet the needs
Soft target security planning (public gatherings)

Training Information and Requirements
1. Training Information Reporting System (“Web-Forms”). Web-Forms is an
electronic form/data management system built to assist the SAA and its
designated State/territory TPOC with the reporting of State and Federal
sponsored training supported by SHSP Tribal funds. Web-Forms can be
accessed through the FEMA Toolkit located at
http://www.firstrespondertraining.gov/admin.
2. Types of training. FEMA facilitates a number of different training sources:
•

•

•
•

FEMA Provided Training: These courses or programs are developed for
and/or delivered by institutions and organizations funded directly by FEMA.
This includes the Center for Domestic Preparedness (CDP), the National
Domestic Preparedness Consortium (NDPC), the Rural Domestic
Preparedness Consortium (RDPC), National Emergency Training Center
(National Fire Academy and the Emergency Management Institute), and
FEMA Training Partners funded through the Continuing and Demonstration
Training grant programs.
Training Not Provided by FEMA: These courses are either State
sponsored or Federal sponsored, coordinated and approved by the SAA or
their designated Training Point of Contact (TPOC), and fall within the FEMA
mission scope to prepare State and local personnel to prevent, protect
against, respond to, and recover from acts of terrorism or catastrophic events.
State Sponsored Courses: These courses are developed for and/or
delivered by institutions or organizations other than Federal entities or FEMA
and are sponsored by the SAA or their designated TPOC.
Approved State Sponsored Course Catalog: This catalog lists
State/territory sponsored courses that fall within the FEMA mission scope and
have been approved through the FEMA course review and approval process.
An updated version of this catalog can be accessed at
http://www.firstrespondertraining.gov/odp_webforms.

44

•
•

Federal Sponsored Courses: This catalog lists courses developed for
and/or delivered by institutions funded by Federal entities other than FEMA.
Approved Federal Sponsored Course Catalog: This catalog lists Federalsponsored courses that fall within the FEMA mission scope, and have been
approved through the FEMA course review and approval process. An
updated version of this catalog can be accessed at
http://www.firstrespondertraining.gov/odp_webforms.

FEMA Provided Training. FEMA funds the direct delivery of a variety of courses that
States can request to meet training needs. These courses are listed in the FEMA
approved course catalog listed at http://www.firstrespondertraining.gov/odp_webforms.
Each FEMA Training Partner should contact the SAA or designated TPOC for locations
within the State that are appropriate for the training. When the direct delivery funds are
exhausted, the Training Partner can continue to offer the classes to the States through
one of two methods—the Voluntary Training Enhancement Program (VTEP) or the
Excess Delivery Acquisition Program (EDAP).
VTEP is a voluntary program designed to increase flexibility for States and territories
while enhancing FEMA’s training delivery capability and complementing the current
training partner pool. Funding from previous fiscal years may be used to support a
State, territory, or Urban Area’s implementation of this program. Through VTEP, the
SAA has the authority to adopt various TEI/TO provided programs for delivery by
institutions within its State and local jurisdictions, and designate institutions as
recognized providers for the identified standardized curriculum.
EDAP allows a FEMA Training Partner to charge for a course delivery when the Federal
grant that developed the program is completed or more deliveries of a requested class
are needed than the grant funds can accommodate. This cost per class is approved by
FEMA so that States pay for the cost of instruction only, not the curriculum development
costs that were paid by FEMA training grant funds. SHSP funds can be used to pay for
the delivery of these classes within a State at the request of the SAA/TPOC.
Attending Training Not Provided by FEMA (State or Federal Sponsored Courses).
States, territories, and Urban Areas are not required to request approval from FEMA for
personnel to attend training not provided by FEMA (State or Federal-sponsored
courses) provided that the training is coordinated with and approved by the SAA or
TPOC and falls within the FEMA mission scope and the jurisdiction’s EOP and Strategy
of preparing State and local personnel or citizens to prevent, protect against, respond
to, and recover from acts of terrorism or catastrophic events.
Tribes are required, within 30 days after attendance, to submit information through the
SAA or TPOC via Web-Forms on all training not provided by FEMA, but supported with
SHSP funds. This information will consist of course title, course description, mission
area, level of training, the training provider, the date of the course, the number and
associated disciplines of the individuals, and the sponsoring jurisdiction. Tribes

45

intending to use FEMA funds to support attendance at training not provided by FEMA
must ensure these courses:
•
•
•
•
•
•

Fall within the FEMA mission scope to prepare State and local personnel to
prevent, protect against, respond to, and recover from acts of terrorism and
catastrophic events
Build additional capabilities that a) support a specific training need identified by
the State, territory, and Urban Area, and b) comport with the State, territory, or
Urban Area Homeland Security Strategy
Address specific tasks and/or competencies articulated in FEMA’s Emergency
Responder Guidelines and the Homeland Security Guidelines for Prevention and
Deterrence
Address specific capabilities and related tasks articulated in the September 2006
version of the TCL, available through LLIS
Support the specific program training activities identified in the SHSP Tribal for
which the funding will be used
Comport with all applicable Federal, State, and local regulations, certifications,
guidelines, and policies deemed appropriate for the type and level of training

In support of the continuing efforts to build common catalogs of approved training not
provided by FEMA, the SAA/TPOC will be allowed three deliveries of the same course
within a State/territory before the course is required to go through the FEMA State
course review and approval process. Additional course deliveries will be authorized
during the review period. However, if the course is disapproved as part of the process,
no additional FEMA funds can be dedicated to attending the course.
State and Federal-Sponsored Course Catalogs. Courses approved by FEMA will be
added to either the approved State Sponsored Course Catalog or the Federal
Sponsored Course Catalog. Courses identified within these catalogs may be attended
on an unlimited basis within any State/territory as long as the training is coordinated and
approved by the SAA/TPOC. A full description of the FEMA Course Development,
Review, and Approval Process, as well as the approved course catalogs, can be found
at http://www.firstrespondertraining.gov/odp_webforms.
FEMA will respond to the initial request for review within 15 days with one of the
following outcomes:
• Course concept is approved as consistent with the State plan and the State
should submit the full course package for subject matter expert review and
comment.
• Course concept is disapproved as inconsistent with State plan, FEMA guidance,
or is exactly the same as another course in the catalog (no need for another
approval, refer to the curriculum already developed and approved).
At any time, the SAA/TPOC (for State-sponsored courses) or the Federal Agency POC
(for Federal sponsored courses) may request the addition of a course to the
corresponding approved catalog by submitting the associated Web-Form (i.e., Request
for Addition to the Approved State-Sponsored Catalog) for review. If a class on the

46

same subject is already in the catalog, the submitting State should provide
documentation as to why the course is unique, after contacting the owner(s) of the other
courses to review the curriculum. This step is required to avoid unnecessary duplication
of similar courses in the catalog, allow States to share course development costs,
permit all States to have access to new or unique courses developed by other
providers, and allow States to direct their training dollars to delivery rather than
development. If it is determined that the proposed course meets the above listed
criteria, the providing entity (SAA/TPOC or Federal Agency POC) will be invited to
submit the Course Review and Approval Request Form along with all supporting
training materials.
For further information on developing courses using the instructional design
methodology and tools that can facilitate the process, SAAs and TPOCs are
encouraged to review the FEMA Strategy for Blended Learning and access the
Responder Training Development Center (RTDC) available at
http://www.firstrespondertraining.gov/admin.
FEMA funds must be used to supplement, not supplant, existing funds that have been
appropriated for the same purpose. FEMA will conduct periodic reviews of all State,
territory, and Urban Area training funded by FEMA. These reviews may include
requests for all course materials and physical observation of, or participation in, the
funded training. If these reviews determine that courses are outside the scope of this
guidance, grantees will be asked to repay grant funds expended in support of those
efforts.
States and territories are required to conduct an annual Training and Exercise Plan
Workshop to identify key priorities and major events over a multi-year time frame and to
align training and exercises in support of those priorities. A Multi-year Training and
Exercise Plan will be produced from the Training and Exercise Plan Workshop to
include the State’s training and exercise priorities, associated training and exercise
capabilities, and a multi-year training and exercise schedule. Further guidance
concerning the Multi-year Training and Exercise Plan can be found in the Exercises
discussion immediately following. Tribes should participate in the State workshop.
Allowable Training Costs
Allowable training-related costs include, but are not limited to, the following:
•
•

Funds used to develop, deliver, and evaluate training, including costs related
to administering the training, planning, scheduling, facilities, materials and
supplies, reproduction of materials, and equipment.
Overtime and Backfill costs, as defined in this guidance, associated with
attending or teaching FEMA-sponsored and/or approved training courses and
programs are allowed. These costs are allowed only to the extent the payment
for such services is in accordance with the policies of the State or unit(s) of local
government and has the approval of the State or the awarding agency,
whichever is applicable. In no case is dual compensation allowable. That is, an

47

•
•

•

employee of a unit of government may not receive compensation from both their
unit or agency of government AND from an award for a single period of time
(e.g., 1:00 pm to 5:00 pm), even though such work may benefit both activities.
Further, overtime costs associated with employees who participate in training in a
teaching role for which they are compensated are not allowed. Fringe benefits
on overtime hours are limited to Federal Insurance Contributions Act (FICA),
Workers’ Compensation and Unemployment Compensation.
Travel costs (e.g., airfare, mileage, per diem, hotel) are allowable as expenses
by employees who are on travel status for official business related to approved
training.
Hiring of Full or Part-Time Staff or Contractors/Consultants to support
training-related activities. Payment of salaries and fringe benefits must be in
accordance with the policies of the State or unit(s) of local government and have
the approval of the State or awarding agency, whichever is applicable. Such
costs must be included within the funding allowed for program management
personnel expenses, which must not exceed 15 percent of the total allocation as
specified in section E.6. In no case is dual compensation allowable (see above).
Certification/Recertification of Instructors is an allowable cost. Tribes are
encouraged to follow the FEMA Instructor Quality Assurance Program to ensure
a minimum level of competency and corresponding levels of evaluation of
student learning. This is particularly important for those courses that involve
training of trainers. This information is contained in an information bulletin issued
in October 2006.

Exercise Requirements
1. Training and Exercise Plan Workshop. States and Urban Areas are required to
conduct an annual Training and Exercise Plan Workshop (T&EPW). A Multi-year
Training and Exercise Plan must be produced from the T&EPW and submitted to
the State’s respective Exercise Manager and Program Analyst. This plan must be
updated annually. Tribes should participate in the State workshop.
The Training and Exercise Plan will include the State’s training and exercise priorities,
associated capabilities, and a multi-year training and exercise schedule. The Plan and
the schedule must both be submitted within 60 days of the workshop and should reflect
all exercises that are being conducted throughout the State. All scheduled exercises
must be entered through the National Exercise Schedule (NEXS) Application, which is
located on the HSEEP website. A template of the Multi-year Training and Exercise Plan
can be found in HSEEP Volume guidance and on the HSEEP website
(https://hseep.gov) under the Sample Exercise Documents section..
Tribes must complete a cycle of exercise activity during the period of this grant. Tribes
are encouraged to use exercises as an opportunity to meet the requirements of multiple
exercise programs. To this end, grantees are encouraged to invite
representatives/planners involved with other Federally-mandated or private exercise
activities. Tribes are encouraged to share, at a minimum, the multi-year training and

48

exercise schedule with those departments, agencies, and organizations included in the
plan.
Further guidance concerning Training and Exercise Plan Workshops can be found in
the HSEEP Volumes.
2. Exercise Scenarios. The scenarios used in SHSP-funded exercises must be
based on the State’s Homeland Security Strategy and plans. Acceptable
scenarios for SHSP Tribal exercises include: chemical, biological, radiological,
nuclear, explosive, cyber, agricultural and natural or technological disasters.
Exercise scenarios must be catastrophic in scope and size, as defined by the
National Response Framework.
The scenarios used in SHSP Tribal-funded exercises must focus on validating existing
capabilities and must be large enough in scope and size to exercise multiple tasks and
warrant involvement from multiple jurisdictions and disciplines and non-governmental
organizations. Exercise scenarios should also be based on the Multi-year Training and
Exercise Plan.
3. Models, Simulations and Games (MS&G). Grantees who wish to expend
funds on models, simulations, or games (MS&G) must consult with “Review of
Models, Simulations, and Games for Domestic Preparedness Training and
Exercising, Volume III,” which provides an overview and analysis of existing
models, simulations, and games. Grantees can also consult with the MS&G
Decision Support System, which automates the aforementioned report into a
searchable database. Both the report and system are available through the
HSEEP website.
4. Special Event Planning. If a State or Urban Area will be hosting an upcoming
special event (e.g., Super Bowl, G-8 Summit); they anticipate participating in a
Tier 2 National-Level Exercise as defined by the National Exercise Program
Implementation Plan (NEP I-Plan); or they anticipate that they will apply to be a
venue for a Tier 1 National-Level Exercise, as defined by the I-Plan, they should
plan to use SHSP Tribal funding to finance training and exercise activities in
preparation for that event. States and Urban Areas should also consider
exercises at major venues (e.g., arenas, convention centers) that focus on
evacuations, communications, and command and control. States should also
anticipate participating in at least one Regional Exercise annually. States must
include all confirmed or planned special events in the Multi-year Training and
Exercise Plan.
5. Exercise Evaluation. All exercises will be performance-based and evaluated.
An After-Action Report/Improvement Plan (AAR/IP) will be prepared and
submitted to FEMA within 60 days, following every exercise, regardless of type or
scope. AAR/IPs must conform to the HSEEP format, should capture objective
data pertaining to exercise conduct, and must be developed based on

49

information gathered through Exercise Evaluation Guides (EEGs) found in
HSEEP Volume IV. All applicants are encouraged to use the Lessons Learned
Information Sharing System (LLIS.gov) as a source for lessons learned and to
exchange best practices.
6. Self-Sustaining Exercise Programs. States are expected to develop a selfsustaining exercise program. A self-sustaining exercise program is one that is
successfully able to implement, maintain, and oversee the Multi-year Training
and Exercise Plan, including the development and delivery of SHSP Tribalfunded exercises. The program must utilize a multi-disciplinary approach to the
development and delivery of exercises, and build upon existing plans, training,
and equipment.
7. Role of Non-Governmental Entities in Exercises. Non-governmental
participation in all levels of exercises is strongly encouraged. Leaders from nongovernmental entities should be included in the planning, conduct, and
evaluation of an exercise. State and local jurisdictions are encouraged to
develop exercises that test the integration and use of non-governmental
resources provided by non-governmental entities, defined as the private sector
and private non-profit, faith-based, community, volunteer and other nongovernmental organizations. Non-governmental participation in exercises should
be coordinated with the local Citizen Corps Council(s).
Allowable Exercise Costs
Allowable exercise-related costs include:
•
•

•

•

Funds Used to Design, Develop, Conduct and Evaluate an Exercise –
Includes costs related to planning, meeting space and other meeting costs,
facilitation costs, materials and supplies, travel, and documentation.
Hiring of Full or Part-Time Staff or Contractors/Consultants – Full or parttime staff may be hired to support exercise-related activities. Such costs must be
included within the funding allowed for program management personnel
expenses. The applicant's formal written procurement policy or the Federal
Acquisition Regulations (FAR) – whichever is more stringent – must be followed.
In no case is dual compensation allowable.
Overtime and Backfill – Overtime and backfill costs associated with the design,
development, and conduct of exercises are allowable expenses. These costs
are allowed only to the extent the payment for such services is in accordance
with the policies of the State or unit(s) of local government and has the approval
of the State or the awarding agency, whichever is applicable. In no case is dual
compensation allowable (see above). Fringe benefits on overtime hours are
limited to FICA, Workers’ Compensation and Unemployment Compensation.
Travel – Travel costs are allowable as expenses by employees who are on travel
status for official business related to the planning and conduct of exercise
project(s).

50

•
•

Supplies – Supplies are items that are expended or consumed during the course
of the planning and conduct of the exercise project(s) (e.g., copying paper,
gloves, tape, non-sterile masks, and disposable protective equipment).
Other Items – These costs include the rental of space/locations for exercise
planning and conduct, rental of equipment (e.g., portable toilets, tents), food,
refreshments, gasoline, exercise signs, badges, etc.

Unauthorized Exercise Costs
Unauthorized exercise-related costs include:
•
•

Reimbursement for the maintenance and/or wear and tear costs of general use
vehicles (e.g., construction vehicles) and emergency response apparatus (e.g.,
fire trucks, ambulances).
Equipment that is purchased for permanent installation and/or use, beyond the
scope of exercise conduct (e.g., electronic messaging signs).

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Allowable Planning, Training, and Exercise
Examples Specific to Law Enforcement
Terrorism Prevention-oriented Activities
Planning Activity Examples
Participation in Fusion Centers
• Participation in or assigning a liaison to designated State or Urban Area fusion
centers
• Hiring an IT specialist to plan, develop, and implement the IT applications
necessary to share information with a fusion center
• Participation in information/intelligence sharing groups
Other Allowable Planning Activity Examples
• Conducting point vulnerability analyses and assessments
• Soft target security planning (public gatherings)
• Developing border security operations plans in coordination with CBP
• Updating and refining threat matrices
• Integrating and coordinating the sharing of information with the private sector
• Developing and implementing civil rights, civil liberties and privacy policies,
procedures, and protocols.
• Acquiring systems allowing connectivity to State, local, and Federal data
networks, such as the National Crime Information Center (NCIC) and Integrated
Automated Fingerprint Identification System (IAFIS), as appropriate
• Designing and developing tribal geospatial data systems
• Costs associated with the adoption, implementation and adherence to NIMS
compliance requirements; including implementing the NIMS National
Credentialing Framework.
Training Activity Examples
Law enforcement terrorism prevention protection-oriented funds may be used for a
range of law enforcement terrorism prevention related training activities to enhance the
capabilities of State and local personnel, including the following:
Participation in Fusion Centers. Grant funds may be used to support intelligence
analyst training in the following manners:
•

Participation in DHS approved intelligence analyst training: States wishing
to develop or sponsor intelligence analyst courses for a national audience should
submit courses to FEMA for review and approval in accordance with the process
outlined in Parts VI and VII of this guidance document. The list of approved

52

courses will be constantly updated and can be accessed in the FEMA catalog at
http://www.firstrespondertraining.gov/odp_webforms.
•

Limited participation in non-FEMA approved intelligence analyst training:
States may send students to attend non-approved intelligence analysis courses
for up to three offerings in accordance with the training process outlined in Parts
VI and VII of this guidance document.

A certificate of completion of all intelligence analyst training must be on file with the SAA
and must be made available to Program Analysts upon request upon the hiring of
personnel.
Additional Allowable Training Activities
Allowable costs include training courses that focus on:
• Building information sharing capacities (especially among law enforcement, nonlaw enforcement, other government agencies, and the private sector)
• Methods of target hardening
• Facility law enforcement security personnel, to include facilities, vessels and
ports
• CBRNE, agriculture, and cyber threats
• History of terrorism and social environments contributing to threats
• Surveillance and counter-surveillance techniques
• Privacy, civil rights, and civil liberties regulations, policies, procedures, and
protocols
• Critical Infrastructure Protection training, to include identifying/assessing critical
infrastructure assets, vulnerabilities, and threats
• Cyber/agriculture/food security threats recognition and protective measures
training
• Cultural awareness training for community engagement activities and undercover
operations related to terrorist organizations
• Languages, such as Arabic, Urdu, or Farsi, which are spoken by known terrorists
and terrorist organizations
• Joint training with other homeland security entities (e.g., U.S. Secret Service,
CBP)
• Use of interoperable communications equipment
• Collection, analysis, mapping, integration, and dissemination of geospatial data
and imagery
• Geospatial database use, design, development, and management training
• Volunteer participation to support law enforcement and community policing
activities related to increased citizen awareness of terrorism activities, to include
the Volunteers in Police Service and Neighborhood Watch programs
Exercise Activity Examples

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Law enforcement terrorism prevention protection-oriented funds may be used to design,
develop, conduct, and evaluate terrorism prevention-related exercises, including the
following:
•
•
•
•
•
•
•
•
•
•
•

Exercises to evaluate the effectiveness of information sharing plans, policies,
procedures, and protocols
Exercises to evaluate NIMS implementation. This includes costs associated with
exercising components of the NIMS National Credentialing Framework.
Exercises to evaluate facility and/or vessel security protection
Exercises to evaluate area maritime security protection
Exercises to evaluate threat recognition capabilities
Exercises to evaluate cyber security capabilities
Exercises to evaluate agricultural/food security capabilities
Exercises to evaluate prevention readiness and techniques
“Red Team” (force on force) exercises
Interoperable communications exercises
Critical infrastructure vulnerability, protection, and/or attack exercises

Where practical, these exercises should involve the public sector, non-governmental
partners, trained citizen volunteers, and the general public. State and local
governments should work with their Citizen Corps Councils to include volunteers from
programs such as Volunteers in Police Service, Neighborhood Watch, and the general
public.

54