Office for Domestic Preparedness 

U.S. Department of Homeland Security 

Washington, DC 20531

ODP Information Bulletin

No. 145 December 22, 2004

TO: All State Administrative Agency Heads 

All State Administrative Agency Points of Contact 

All Urban Areas Security Initiative Points of Contact 

All ODP Training Partners 

FROM: C. Suzanne Mencer 

 Executive Director 

SUBJECT: Updates to the Department of Homeland Security (DHS) Fiscal Year 2005 

Homeland Security Grant Program (HSGP) Program Guidelines and Application 

Kit 

The Fiscal Year 2005 HSGP Program Guidelines and Application Kit was released on December 

2, 2004. This information bulletin provides several important clarifications and updates to that 

guidance. An updated version of the FY05 HSGP Program Guidance and Application Kit can be 

accessed and downloaded at http://www.ojp.gov/odp/whatsnew/whats_new.htm. Grantees should 

rely upon this attached updated version of the guidance, labeled Version 2.0, 12-22-04 on the 

inside cover of the document and at the top of each page. 

Funding Allocations. Within the Program Guidance and Application Kit, Table 1: FY05 HSGP 

Funding Allocations on page 2 has an apparent discrepancy between each state’s program 

funding allocations and the total allocation. The apparent discrepancy for each state is no greater 

than plus or minus $3. All numbers in the table are rounded to the nearest whole dollar, which 

creates the apparent discrepancy that the sum of the program allocations may not equal the total 

allocation for each state. However, the total allocation per state in Table 1 is the correct

allocation and is the amount that should be entered when applying through the online Grants 

Management System, which does not accept cents in the input field. 

MMRS Jurisdictions. An error was made in identifying FY05 MMRS jurisdictions and 

allocations. The MMRS jurisdiction of Albuquerque, NM was omitted from the list of MMRS 

jurisdictions and Columbia, NC, which is not an MMRS jurisdiction, was incorrectly added to 

the list. The FY05 MMRS program is allocated to the same FY03 and FY04 MMRS 

jurisdictions. Therefore, Table 3: FY05 MMRS Jurisdictions on page 8 has been corrected to 

include Albuquerque, NM, and delete Columbia, NC. The current North Carolina MMRS 

jurisdictions of Charlotte, Greensboro, and Raleigh remain intact for the FY05 MMRS list. In 

addition, Table 1 is corrected to allocate $227,592 (instead of $0) to New Mexico for MMRS and 

$682,776 (instead of $910,368) to North Carolina for MMRS. The total HSGP allocation for 
New Mexico and North Carolina has also been updated to reflect this correction. MMRS

allocations to all other states and MMRS jurisdictions are unaffected by this correction. 

Interest-bearing Accounts. The Drawdown of Funds section on page 22 has been updated with 

additional guidance regarding funds placed in an interest-bearing account. The updated HSGP

states that a grantee or subgrantee may keep interest amounts up to $100 per year for

administrative expenses, and should consult the OJP Financial Guide or the applicable OMB 

Circular for additional guidance. Finally, State grantees are subject to the interest requirements 

of the Cash Management Improvement Act (CMIA) and its implementing regulations at 31 CFR 

Part 205. Interest under CMIA will accrue from the time Federal funds are credited to a State 

account until the time the State pays out the funds to a subgrantee or otherwise for program 

purposes. 

Operational Costs. Both the Urban Areas Security Initiative (UASI) and the Law Enforcement 

Terrorism Prevention Program (LETPP) allow for up to 25% of the gross award amount to be

used in support of select operational activities. Three categories of operational activities are 

allowable under both UASI and LETPP: 

• Operational overtime costs associated with increased security measures at critical 

infrastructure sites during periods of heightened alert 

• Overtime costs for personnel to participate in information, investigative, and intelligence 

sharing activities specifically related to homeland security 

• Hiring of contractors/consultants for participation in information/intelligence sharing

groups or intelligence fusion centers 

Additional information on allowable operational costs is available on page 26. 

Overtime, Backfill, and Hiring Guidance. The overtime, backfill, and hiring section on page 

40 has been clarified to clearly communicate that grantees are permitted to hire or laterally move 

existing public safety officers to new positions that support allowable HSGP program activities. 

In the case of lateral transfers, grant funds may only be used to support those positions that are 

allowable under FY05 HSGP program guidance; all non-supplanting rules apply. In addition, 

positions created and/or funded through ODP grants may continue to be supported with future 

year funding provided that the position is dedicated to the same or similar purposes allowable 

under applicable ODP program guidance. 

Unallowable costs guidance has been clarified to read that funds may not be used to support the 

hiring of sworn public safety officers for the purposes of fulfilling traditional public safety duties 

or to supplant traditional public safety positions and responsibilities. 

Homeland Security Assistance for Nonprofit Organizations. The 60-day pass-through 

requirements for the nonprofit allocations under UASI program outlined on page 21 have been

updated. Current guidance directs the state to issue a solicitation within 60 days of the award 

date through which organizations can apply for funds allocated under the UASI program for

nonprofit organizations. Eligible nonprofit organizations will submit applications to the state 

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which will make subgrant awards to selected individual nonprofit organizations in amounts not

to exceed $100,000. 

Emergency Management Performance Grants (EMPG) and Construction. While the 

primary purpose of the EMPG program is not to support construction activities, DHS recognizes 

that an updated, functioning emergency operations center (EOC) is a core component of an 

effective emergency management system. Therefore, limited construction and renovation 

activities for EOCs are allowable under EMPG in the FY05 HSGP. (See Construction and 

Renovation Guidance on page 38 for additional details.) This provision is consistent with past 

practices under EMPG. 

States wishing to expend EMPG funds on limited construction and renovation projects must

formally request written approval from ODP in advance. The request must be directed to their 

assigned ODP Preparedness Officer and must address the following issues: 

• Description of the EOC facility, location, and the scope of the construction or renovation 

project 

• Certification that an assessment has been conducted to identify EOC needs regarding 

such issues as the facility, communications capability, computer systems and network 

capabilities, survivability, and sustainability 

• How the construction or renovation project will address the needs identified from the 

assessment 

• Consequences of not implementing the construction or renovation project 

The State must match 50% of any money used for construction and must comply with the DavisBacon Act. 

States must also comply with all National Environmental Policy Act (NEPA) requirements. 

Grantees wishing to use ODP funding for construction projects must complete and submit a 

NEPA Compliance Checklist to their respective ODP Preparedness Officer for review. 

Additionally, grantees may be required to provide additional detailed information on the 

activities to be conducted, locations, sites, possible construction activities, possible alternatives, 

and any environmental concerns that may exist. Results of the NEPA Compliance Review could

result in a project not being approved for ODP funding, the need to perform an Environmental 

Assessment (EA) or draft an Environmental Impact Statement (EIS). 

EMPG Equipment. Table 8 on page 89 defines equipment as non-expendable property having 

a useful life of more than one year and an acquisition cost of $5,000 or more per unit. This 

definition stems from OMB Circular A-87 and is a federal classification used in this context for 

definitional purposes only. Equipment items allowed under EMPG is further detailed on page 89 

and in the Authorized Equipment List housed on the Responder Knowledge Base 

(www.rkb.mipt.org). 

Allowable Management and Administrative (M&A) Costs. Updated M&A guidance on page

25 allows states to pass through a portion of the state M&A allocation to local subgrantees in 

order to supplement the 2.5% M&A allocation allowed on subgrants. However, no more than 

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3% of the total subaward may be expended by subgrantees on M&A costs. In addition, overtime 

and backfill costs related to allowable M&A costs are eligible as Allowable M&A Costs in 

Appendix A: Authorized Program Expenditures. 

Allowable Planning Costs. Overtime and backfill costs related to planning activities for the 

development and implementation of programs under HSGP are eligible as Allowable Planning 

Costs in the updated HSGP. Please see Appendix A: Authorized Program Expenditures for 

additional information. 

Biannual Strategy Implementation Reports (BSIR). The BSIR guidance on page 60 and in 

Appendix D: Guidance for Initial Strategy Implementation Plan and Biannual Strategy 

Implementation Report has been updated to reflect that the BSIR will satisfy the narrative 

requirement in Box 12 of the biannual Categorical Assistance Progress Reports (CAPR). 

For additional information, please contact your Preparedness Officer or the ODP Helpline 

at 1-800-368-6498. 

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