The Texas Way

Aug 28, 2017 4:00:00 PM |

Viviana Ramirez

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shutterstock_698961514-480206-edited.jpgWith a resilient job market, great Mexican food, and small-town feel, the Texas Gulf Coast is a great place to call home. According to the Texas Relocation Report, “Texas experienced a net gain of 107,689 out-of-state residents in 2015, a 4 percent increase from 2014.” As a good neighbor should, I welcome you to Friday night lights, longhorns and warm Texas weather. As we native Texans know, with triple digit summer days come hurricanes.

In this age of technology and social media, relevant hurricane preparedness information is at your fingertips; from grocery checklists to which gas stations have the shortest lines. There’s something comforting in knowing the insider information—that key piece of advice to make a challenging time a little less trying, especially when you are on the brink of an event with the potential to significantly disrupt your day. Even if you are a storm veteran, hurricanes are both physically and emotionally trying. It’s obvious that our personal lives are disrupted when the weatherman begins to inform us of the tropical storms forming, but no one really speaks about the impact on our professional lives.

As a disaster recovery professional, much of my career has been spent helping entities recover from Hurricane Ike, the third costliest U.S. storm. Here are a few items that can help in this stressful time:

Direct Administrative Costs: For entities that serve the public sector, and are eligible recipients of FEMA funding, FEMA states, "if the Recipient or Subrecipient incurs administrative costs that it tracks, charges, and accounts for directly to a specific eligible project, the costs are eligible as Direct Administrative Costs (DAC).” These are typically challenging to track. Ensuring a process is implemented as early as possible to adequately capture specific disaster related time is crucial for a speedy recovery and reimbursement process. This can be something as simple as an excel spreadsheet or adding disaster specific codes to the entity’s time entry platform. Ensure both the task performed and the skill level and position of individual performing the task are included.  Examples of activities eligible for DAC include:  site inspections, developing the detailed site-specific damage description, evaluating Section 406 hazard mitigation measures, preparing correspondence, administrative duties associated with supporting the claim, requesting disbursement of Public Assistance funds.

Applicant-Owned Equipment and Applicant Labor: Similar to DAC, labor and equipment records may not be front-of-mind during the response period, but are critical to recordkeeping during recovery if a federal declaration is awarded.  Detailed logs should include:

  • For each piece of equipment:
  • Type of equipment, year, make and model and any attachments
  • Size/capacity
  • Location and days and hours used with usage logs
  • Operator name
  • Schedule of equipment rates
  • For each individual:
  • Name, job title, and function
  • Type of employee (i.e. full-time exempt, full-time non-exempt, etc.)
  • Days and hours worked
  • Pay rate and fringe benefits rate
  • Description of work performed
  • Timesheets
  • Pay policy

Procurement: A lot happens in a short amount of time. The key takeaway is that Applicants must comply with Federal procurement standards as a condition of receiving Public Assistance funding. 2 CFR 200 provides details of these requirements.  A few do’s and don'ts to remember:

  • Do follow the more stringent of your procurement policy or the federal requirements.
  • Do provide full and open competition.
  • Do obtain quotes from multiple qualified vendors for any aggregate small purchases that exceed $3,000 but are less than the simplified acquisition threshold (currently $150,000). Document the quotes received.
  • Do utilize sealed bidding or competitive proposals if the simplified acquisition threshold is exceeded.
  • Conduct and document all necessary affirmative steps to ensure the use of minority businesses, women’s business enterprises, and labor surplus area firms when possible.
  • Do not use cost-plus a percentage of cost contracts or a contract with a percentage of construction cost method.
  • Do not have continued use of time and material contracts. It is expected that these are procured under a more acceptable contract type.
  • Document conflicts of interest.
  • Document and maintain records of procurement to include: rationale, selection, and price.
  • I can say I am blessed to work for a Firm where flexibility is available to ensure team member safety. “Turn around don’t drown” is seriously driven into my brain, when the roads get dangerous, our team is encouraged to work from home to avoid hazards.

In Texas, we take being a good neighbor seriously. In this hard time following Hurricane Harvey, I’m here to serve.  

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THIS POST WAS WRITTEN BY Viviana Ramirez

Viviana is a supervisor with HORNE’s government services disaster recovery team. She oversees a team responsible for monitoring state-funded public assistance projects and processes funding requests for multiple applicants. She provides assistance to ensure compliance and transparency for client grants.

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