Detailed Discussion
Donated Resources, which include volunteer labor, donated equipment and donated materials, are eligible to offset the State and local portion of the cost share for emergency work (Categories A and B). The amount of credit that can be applied to a project is capped at the non-Federal share of emergency work so that the Federal share will not exceed the applicant’s actual out-of-pocket costs. Any excess credit can be applied to other emergency work projects of the same applicant.
Donated resources must apply to actual eligible emergency work, such as debris removal or the filling and placing of sandbags. The donated services must be documented and must include a record of hours worked, the work site, and a description of work. Volunteer labor will be valued at the same hourly labor rate as someone in the applicant’s organization performing similar work. If the applicant does not have employees performing similar work, then the rate should be consistent with those ordinarily performing the work in the same labor market.
The value for donated equipment should be determined by using the applicable FEMA equipment rate and multiplying it by the number of hours the piece of equipment was used to perform eligible emergency work.
Donated materials are valued at the current commercial rate. If the materials were donated by a Federal agency, such as sandbags donated by the U.S. Army Corps of Engineers, the materials cannot be applied for volunteer credit.
Individuals and organizations often donate resources (equipment, supplies, materials, or labor) to assist with response activities. FEMA does not provide PA funding for donated resources; however, the Applicant may use the value of donated resources to offset the non-Federal share of its eligible Emergency Work projects and DFA.
The Applicant may apply the offset if all of the following conditions are met:
• The donated resource is from a third party (a private entity or individual that is not a paid employee of the Applicant or Federal, State, Territorial, or Tribal government);
• The Applicant uses the resource in the performance of eligible Emergency Work; and
• The Applicant or volunteer organization tracks the resources and work performed, including description, specific locations, and hours.133
FEMA considers unpaid individuals who volunteer their labor to an Applicant to be third party even if they are officially members or employees of the Applicant organization (e.g. volunteer fire fighters at a PNP volunteer fire department).
Resources donated to the Applicant by an organization that would normally provide the same resources under its mission are eligible as an offset provided the organization is not federally funded. Additionally, if a mutual aid agreement provides for assistance at no cost to the Applicant, the Applicant may use the value of that assistance to offset the non-Federal cost share of its Emergency Work.
Resources donated by a Federal agency, funded through a Federal award, or from another federally funded source are not eligible as an offset to the
130 44 CFR § 206.208(a).
131 44 CFR § 206.208(c)(1).
132 44 CFR § 206.208(c)(2).
133 2 CFR § 200.434(d).
non-Federal share.134 Additionally, when an Applicant uses donated resources for ineligible Emergency Work, or for any Permanent Work (eligible or ineligible), the value of those resources are not eligible as an offset to the non-Federal share.
All projects approved under PA are subject to cost sharing135; therefore, FEMA applies the Federal cost share to the total value of donated resources. FEMA does not apply the offset toward other State, Territorial, or Tribal government obligations, toward Permanent Work, or toward another Applicant’s projects.
Offset Amounts
• Volunteer Labor: The offset for volunteer labor is based on the same straight-time hourly labor rate, and fringe benefits, as a similarly qualified person in the Applicant’s organization who normally performs similar work. FEMA does not offset volunteer labor based on overtime or premium rates. If the Applicant does not have employees performing similar work, FEMA credits the non-Federal share based on a rate consistent with those ordinarily performing the work in the same labor market.136
• Donated Equipment: The offset for donated equipment is based on equipment rates. See Chapter 2:V.B for information on equipment rates.
• Donated Supplies or Materials: The offset for donated supplies or materials is based on current commercial rates, which FEMA validates based on invoices from previous purchases or information available from vendors in the area.137
• Logistical Support: Reasonable logistical support for volunteers doing eligible work, such as donations warehousing and management related to eligible Emergency Work, may be eligible either for funding (if the Applicant provides the logistical support) or as a donations credit (if a third party provides the logistical support), subject to approval by FEMA.