The Hazard Mitigation Assistance Application Process

Change to Eligibility of Subapplicants

When 2 CFR 200 went effective December 26, 2014, several our County governments became apprehensive to be a pass-through entity for local private non-profit rural electric cooperatives due to the additional requirements in 2 CFR § 200.331 - Requirements for Pass-Through Entities and §200.328 Monitoring and Reporting Program Performance. These additional requirements have made the county governments reluctant in being the pass-through entity as these requirements have added additional tasks to an already over-tasked staff. Under the current Hazard Mitigation Assistance Guidance Part IIIB. Eligible Subapplicants, private non-profit organizations are an eligible applicant under the Hazard Mitigation Grant Program (HMGP), but they are not eligible to by an applicant under either Pre-Disaster Mitigation (PDM) or the Flood Mitigation Assistance (FMA). If the goal of the Building Resilient Infrastructure and Communities (BRIC) is to mitigate lifelines, by allowing a PNP to be an eligible applicant this would support the Lifeline of Power and reduce the burden on our counties and communities of being a pass-through entity and continue to build resilience in our electrical infrastructure. Recommendation to simplify who can be an applicant of the any Hazard Mitigation Assistance (HMA) programs would be if an entity is an eligible applicant under one HMA grant program, they are eligible for all HMA programs. The States are already the recipients and have the procedures in place to act as the pass-through entity for all sub-recipients.

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Idea No. 2323