Impact of FEMA funds associated with Hurricane Irma

Recently, we have received many inquiries related to the potential impact of FEMA funds associated with Hurricane Irma. Below is information on the April 2017 Compliance Supplement which addresses the recording of expenditures on your Schedule of Expenditures of Federal Awards (SEFA).  Please use this information as you evaluate your SEFA for fiscal year ending September 30, 2017.

Recording Expenditures on the Schedule of Expenditures of Federal Awards (SEFA)

Non-Federal entities must record expenditures on the SEFA when: (1) FEMA has approved the non-Federal entity’s PW, and (2) the non-Federal entity has incurred the eligible expenditures. Federal awards expended in years subsequent to the fiscal year in which the PW is approved are to be recorded on the non-Federal entity’s SEFA in those subsequent years.

For example,

1. If FEMA approves the PW in the non-Federal entity’s fiscal year 2014 and eligible expenditures are incurred in the non-Federal entity’s fiscal year 2015, the non-Federal entity records the eligible expenditures in its fiscal year 2015 SEFA.

2. If the non-Federal entity incurs eligible expenditures in its fiscal year 2014 and FEMA approves the non-Federal entity’s PW in the non-Federal entity’s fiscal year 2015, the non-Federal entity records the eligible expenditures in its fiscal year 2015 SEFA with a footnote that discloses the amount included on the SEFA that was incurred in a prior year.

As always, please reach out to your MSL contact for further information or discussion.