U.S. Department of Homeland Security 

 Washington, DC 20472 

1

Grant Programs Directorate Information Bulletin 

No. 427

February 2, 2018 

MEMORANDUM FOR: FY 2017 AFG, FP&S, and SAFER Applicants and Grant 

Recipients 

Volunteer, Combination, and Career Fire Departments 

Municipalities and Fire Districts 

National, State, Local, or Tribal Fire Service Organizations 

FROM: Thomas DiNanno 

Assistant Administrator for Grant Programs 

Federal Emergency Management Agency 

SUBJECT: Economic Hardship Waivers AFG Grant Program, FP&S 

Grant Program, and SAFER Grant Program 

I. Purpose

This Information Bulletin (IB) provides Assistance to Firefighters (AFG), Fire Prevention 

and Safety (FP&S), and Staffing for Adequate Fire and Emergency Response (SAFER) 

applicants and recipients guidance for requesting waivers of specific provisions under the 

AFG, SAFER and FP&S grant programs. 

These include waivers or reductions of the non-Federal funds cost share requirement, waiver 

of the maintenance of effort requirement, waiver of the minimum budget requirement, waiver 

of the non-supplanting requirement, or any combination thereof, based on demonstrated 

economic hardship. Collectively these are known as an Economic Hardship Waiver. This 

guidance provides the minimum requirements for eligibility for an Economic Hardship 

Waiver, conditions which constitute economic hardship and the process and mechanism for 

requesting an Economic Hardship Waiver. 

II. Applicability 

A. This IB is applicable to AFG, FP&S, and SAFER applicants and recipients commencing 

with the Fiscal Year (FY) 2017 grant cycle. 

1. All AFG applicants or recipients may request an Economic Hardship Waiver as 

permitted by the terms of Section III (Guidance). In order to be eligible to receive an 
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Economic Hardship Waiver, AFG recipients must demonstrate economic hardship by 

meeting the minimum requirements detailed in Section III (Guidance). 

2. Under FP&S, only applicants or recipients that are fire departments are eligible to 

request an Economic Hardship Waiver, per 15 U.S.C. § 2229(k)(4)(C), and in order to 

receive an Economic Hardship Waiver, these FP&S recipients must demonstrate 

economic hardship by meeting the minimum requirements in Section III(Guidance). 

Certain FP&S applicants or recipients are not eligible to request or receive an 

Economic Hardship Waiver, in accordance with 15 U.S.C. § 2229(k)(4)(C). Those 

organizations ineligible to request or receive an Economic Hardship Waiver are 1) 

nonprofit organizations that are not fire departments or emergency medical services 

organizations; and 2) nonprofit organizations that are recognized for their experience 

and expertise with respect to fire prevention or fire safety programs and activities and 

firefighter research and development programs. 

3. All SAFER applicants may request an Economic Hardship Waiver. In order to be 

eligible to receive an Economic Hardship Waiver, SAFER applicants must 

demonstrate economic hardship by meeting the minimum requirements detailed in 

Sec. III (Guidance). 

4. Not all AFG, FP&S, and SAFER applicants and recipients will meet the minimum 

requirements to request an Economic Hardship Waiver. 

5. This IB is not retroactive. This IB does not apply to FY 2016 or previous grant years. 

B. This IB does supersede other guidance on this subject starting with the FY 2017 grant 

cycle. Specifically, FP 207-088-01: Economic Hardship Waivers of Cost Share and 

Maintenance of Effort Requirements for the Assistance to Firefighters (AFG) and Fire 

Prevention & Safety (FP&S) Grant Programs, last updated September 13, 2016 and 

Information Bulletin 413: Economic Hardship Waivers of Cost Share, Minimum Budget, 

and Supplanting Requirements for the Staffing for Adequate Fire and Emergency 

Response (SAFER) Grant Program, last updated December 28, 2016, will not apply to 

any FY 2017 applicants or recipients under the AFG, FP&S, or SAFER Programs. 

III. Guidance 

A. Authority 

In cases of demonstrated economic hardship, and upon the request of the recipient, the 

Administrator may waive or reduce requirements of an AFG, FP&S, or SAFER 

recipient’s awards, as outlined below, by program. 

1. AFG: All AFG recipients may request a waiver for the cost share and/or 

maintenance of effort requirements (15 U.S.C. § 2229(k)(4)(A)). 

2. FP&S: Eligible FP&S recipients, as outlined above, may request a waiver for 

the cost share and/or maintenance of effort requirements (15 U.S.C. § 

2229(k)(4)(A)). 

3. SAFER: SAFER Hiring of Firefighters Activity recipients may request a waiver 

for the cost share, minimum budget requirement, and/or non-supplanting 

requirements. Beginning in FY 2018, applicants may also request a waiver for 

the position cost limit. The cost share, position cost limit (applicable in FY 2018 

and beyond), and non-supplanting requirements do not apply to SAFER 
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Recruitment and Retention Activity recipients, so these recipients may only 

request a waiver for the minimum budget requirement (15 U.S.C. § 2229a(d)).

B. Definitions 

1. Administrator refers to the Administrator of the Federal Emergency Management 

Agency (FEMA). 

2. Cost Share Requirement is the requirement applicable to AFG, FP&S, and 

SAFER Hiring of Firefighters Activity recipients that the Federal portion of the 

costs of hiring firefighters may not exceed certain percentages as described in the 

AFG, FP&S, and SAFER Notices of Funding Opportunity (NOFO), 15 U.S.C. § 

2229(k)(1)-(2), and 15 U.S.C. § 2229a(a)(1)(E). 

3. Economic Hardship Waiver a collective term to refer to a waiver or reduction 

available for requirements/rules applicable to AFG, FP&S, and SAFER: 1) cost 

share requirement; 2) maintenance of effort requirement; 3) minimum budget 

requirement; and 3) prohibition on supplanting. A waiver or reduction is only 

granted for cases that demonstrate economic hardship per the terms of this IB. 

4. First Due Response Geographic Area means the geographical area that a fire or 

rescue facility normally serves in the event of a fire or other emergency. 

5. Maintenance of Effort Requirement means the requirement of AFG or FP&S 

recipients to maintain aggregate expenditures of allowable grant activities at a 

certain level during the term of the grant. Specifically, under 15 U.S.C. § 

2229(k)(3), AFG and FP&S recipients must calculate the average of their annual 

expenditures on allowable grant activities for the prior two fiscal years in which 

they received a grant, and for the current grant year, expend at least 80 percent of 

that average on allowable activities. 

6. Minimum Budget Requirement is the requirement that a SAFER recipient’s 

budget for fire-related programs and emergency response must not be below 80 

percent of the recipient’s average funding level during the time period specified in 

the applicable SAFER NOFO. 

7. Peer Review Panel refers to the panel that reviews AFG, FP&S, and SAFER 

applications as enumerated in each program’s respective NOFO.

8. Position Cost Limit is the requirement that the amount of federal funding provided 

to a recipient under the SAFER Hiring of Firefighters Activity for hiring a 

firefighter in any fiscal year may not exceed certain percentages of the usual annual 

cost of a first-year firefighter in that department at the time the grant application 

was submitted. 

9. Recipient, for purposes of this IB, references an AFG, FP&S, or SAFER recipient, 

as well an AFG, FP&S, or SAFER grant applicant. 

10. State refers to any State of the United States, the District of Columbia, the 

Commonwealth of Puerto Rico, the Virgin Islands, Guam, American Samoa, the 

Commonwealth of the Northern Mariana Islands, and any possession of the United 

States. 

11. Non-Supplanting Requirement is the requirement in which funds received under a 

SAFER Hiring of Firefighters Activity grant may not be used to replace funds that 

would be available from State or local sources or from the Bureau of Indian Affairs. 

Instead, SAFER funds shall be used in addition to the funding from State, local, or 
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Bureau of Indian Affairs sources that would be available even in the absence of 

Federal funds. 

C. Abbreviations 

1. AFGP: Assistance to Firefighters Grant Program Branch. 

2. AFG: Assistance to Firefighters Grant Program 

3. DHS: Department of Homeland Security 

4. FEMA: Federal Emergency Management Agency 

5. FP&S: Fire Prevention and Safety Grant Program 

6. NOFO: Notice of Funding Opportunity 

7. SAFER: Staffing for Adequate Fire and Emergency Response Grant Program 

8. SNAP: U.S. Dept. of Agriculture’s Supplemental Nutrition Assistance Program 

(formerly known as the Food Stamp Program) 

D. Eligibility – Demonstrating Economic Hardship 

For a recipient to be eligible for an Economic Hardship Waiver, the recipient must affirm 

that its governing agency or municipality does not have the available financial resources 

to cover all or part of the cost share, maintenance of effort requirement/minimum budget 

requirements, or the restriction on supplanting. Recipients must affirm that they do not 

have access to financial resources from any source that could be used to cover these 

costs, including from: reserve funds, savings accounts, rainy day fund, or other financial 

instruments. 

In addition to this affirmation, to be eligible for an Economic Hardship Waiver, a 

recipient must demonstrate economic hardship in the following two ways: 

1. Demonstrating that the following conditions exist within the community consisting of 

the recipient’s first-due response geographical area: 

a. The rate of unemployment in the recipient’s community has had a net increase of 

no less than ten percent over the last three (3) years preceding the application for 

the waiver. Each recipient submitting an Economic Hardship Waiver shall supply 

statistics indicating their local unemployment rates for the previous three complete 

years; See, for example, national unemployment rate data at: 

http://data.bls.gov/timeseries/LNS14000000; 

b. The rate of unemployment in the recipient’s community has exceeded the annual 

national average rate of unemployment for three (3) of the last five (5) years. 

c. The median household income over the last three (3) years for the recipient’s 

community has been 80 percent or less than that of the median household income 

in the State in which the recipient is located in each of the past three (3) years. See, 

for example, county-level data at: http://www.ers.usda.gov/data-products/countylevel-data-sets.aspx; 
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d. The Social Vulnerability Index in the recipient’s community is greater than or 

equal to the 75th percentile for the nation. See, for example, data on community 

level social vulnerability at: https://svi.cdc.gov/, or 

e. The recipient, or the recipient’s governing agency or municipality, has filed for 

bankruptcy, or has been place under third party financial oversight or receivership 

with the previous three (3) years. 

2. Provide a narrative response to the following three categories to demonstrate the 

economic hardship: 

a. History: Describe the background/history of the economic hardship in the 

recipient’s organization or jurisdiction, including, but not limited to:

i. Why is your organization or jurisdiction in an economic downturn 

(e.g., a particular industry has been impacted)? 

ii. How many jobs have been lost over the past three years? 

iii. What was the annual budget for the past three years? 

iv. How has your tax revenue declined over the past five years? 

v. What is the foreclosure rate in the community or jurisdiction? 

vi. Is your jurisdiction a Labor Surplus Area (see 

https://www.doleta.gov/programs/lsa.cfm)?

vii. Are there any independent reports about the financial outlook for 

the community or jurisdiction? 

viii. Have you ever requested and/or received an Economic Hardship 

Waiver from FMEA under these grant programs before? 

b. Austerity Measures: Describe any measures the organization or jurisdiction has 

taken to address this economic hardship including, but not limited to: 

i. Has the organization or jurisdiction attempted to borrow money? 

ii. Has the organization or jurisdiction attempted to get assistance 

from the state? 

iii. Has the organization or jurisdiction limited expenses (e.g., not 

hiring, not providing promotions, reducing services, restricting 

contracting, limiting overtime, reducing personnel)? 

iv. Are there regular meetings to assess the financial status of the 

organization or jurisdiction? 

v. Are there other means to fund this project or salary? 

vi. Has the organization or jurisdiction considered other revenue 

streams for funding (Homeland Security/Urban Area Security 

Initiative Grants, fundraising, etc.)? 

vii. Has the organization or jurisdiction considered or implemented 

options such as mutual/automatic aid agreements or partnerships 

with neighboring jurisdictions in order to achieve the goals of the 

project or staffing levels? 

viii. Are there any documents or reports prepared by the organization or 

jurisdiction showing attempts to address the economic hardship? 
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c. Operational Impact: Describe how the lack of a waiver will impact the 

jurisdiction’s or organization’s ability to accomplish the mission including, but 

not limited to: 

i. Has the department conducted a needs assessment? If yes, please 

summarize the findings and source of assessment. 

ii. How have changes in national codes and standards impacted the 

organization’s or jurisdiction’s ability to fund this project? Have 

the changes in standards impacted the cost of the equipment? 

iii. How has this economic hardship impacted or delayed response 

times to fires and other emergencies? 

iv. How has firefighter and/or community health and safety been 

impacted? 

v. How has the economic hardship impacted the staffing levels of the 

department or fire prevention division? 

vi. How has the economic hardship impacted the public education, 

community risk reduction efforts, and other prevention activities 

within the departments, and what impact has that had on the 

community’s risk of fire and fire-related injuries and deaths? 

vii. How else has this economic hardship impacted the organization’s 

or jurisdiction’s ability to achieve its mission of saving lives and 

property and responding to fires and other emergencies? 

Note: Recipients or applicants may also supply optional additional information 

supporting their waiver request. Such information may include data which shows an 

increase in the percentage of individuals in the recipient’s community who are eligible to 

receive assistance under the U.S. Dept. of Agriculture’s Supplemental Nutrition 

Assistance Program (SNAP) over the three (3) year period preceding the waiver 

application. See, for example, SNAP data at: 

http://www.fns.usda.gov/pd/SNAPmain.htm. Submitting this information does not 

replace the requirement to provide the information required in Section III.D.1. or III.D.2, 

above, in order to be eligible for an Economic Hardship Waiver. 

All waiver requests must identify the data source(s) and provide attribution in support of 

their claim(s) of economic hardship. All data sources must be verifiable. Failure to supply 

the source(s) of the data supplied will result in the waiver request being denied. 

Narrative responses must conform to the following requirements: 

1. Font: Times New Roman or Arial. 

2. Font Size: 11 points (11 pt) or larger. 

3. Page Dimensions: Page dimensions must be 8.5" x 11" (21.6 cm x 27.9 cm) 

or smaller. 

4. Margins: All margins (top, bottom, left, and right) must be at least 1" 

(2.54cm). 

E. Economic Hardship Waiver Request Process 

1. AFG and FP&S: 
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a. FY 2017 AFG and FP&S Recipients: Only FY 2017 AFG and FP&S 

applicants or recipients whose applications have undergone further 

evaluation through the Peer Review Panel evaluation and have been 

recommended for award will be permitted to submit a request for an 

Economic Hardship Waiver. Final submission of an Economic Hardship 

Waiver will require the recipient to formally accept the award through 

the AFG eGrants or successor system in order to access and submit the 

amendment request. Upon receipt of the waiver request, the applicant 

will be contacted by the AFG/FP&S program office with detailed 

instructions as to how to submit all required supporting documentation. 

The AFG/FP&S program office will confirm receipt of the submitted 

information and subsequently attach the submitted information to the 

applicants file through the AFGP eGrant or successor system. 

b. FY 2018 applicants, and going forward for all subsequent years: 

AFG and FP&S applicants will indicate at the time of application via the 

eGrants or successor system, which of the two waiver they will be 

requesting. The AFG and FP&S Program Office will only contact 

applicants that selected a waiver option in their submitted application. 

Applicants will be asked, during the respective application period for 

AFG and FP&S, about their intent to request an Economic Hardship 

Waiver and which provisions of the statute they are requesting to 

waiver. The AFG and FP&S program office will ask applicants to 

provide information to support their request after the application period 

has ended. Only submitted applications that select a waiver option will 

be contacted by the AFG and FP&S program offices. Upon receipt of the 

waiver request, the applicant will be contacted by the AFG/FP&S 

program office with detailed instructions as to how to submit all required 

supporting documentation. The AFG/FP&S program office will confirm 

receipt of the submitted information and subsequently attach the 

submitted information to the applicants file through the AFGP eGrant or 

successor system. 

2. SAFER applicants: For all years FY 2017 and going forward, SAFER 

applicants who intend to request an Economic Hardship Waiver must indicate 

which of the three waivers they will be applying for online via the eGrants or 

successor system at the time of application. In FY 2018, the waiver options will 

include Position Cost Limit as a waiver option. Applicants will be asked, during 

the SAFER application period, about their intent to request an Economic 

Hardship Waiver and which requirements they are requesting to waive. The 

SAFER program office will ask applicants to provide information to support 

their waiver request after the application period has ended. The SAFER Program 

Office will only contact applicants that selected a waiver option in their 

submitted application. Upon receipt of the waiver request, the applicant will be 

contacted by the SAFER program office with detailed instructions as to how to 

submit all required supporting documentation. The SAFER program office will 

confirm receipt of the submitted information and subsequently attach the 

submitted information to the applicants file through the AFGP eGrant or 

successor system. 
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The Assistant Administrator for Grant Programs, on behalf of the FEMA Administrator, 

with input from the FEMA Grant Programs Directorate, has the discretion and the final 

authority to make determinations as to whether a request for an Economic Hardship 

Waiver will be granted. Meeting the eligibility requirements described in section III does 

not entitle a recipient to an Economic Hardship Waiver. All decisions regarding 

Economic Hardship Waivers by the Administrator are final. Recipients will not be 

permitted to appeal any Economic Hardship Waiver decision made by the Administrator. 

Additionally, FEMA reserves the right to request additional or clarifying information 

from the recipient after any Economic Hardship Waiver request has been submitted 

before making a final decision. 

F. Impacts on Cost Share, Maintenance of Effort, Position Cost Limit (applicable in FY 

2018 and beyond), and Minimum Budget Requirements 

Where a full waiver has been requested, FEMA reserves the right to reduce, but not 

eliminate, the recipient’s cost share, maintenance of effort, position cost limit (applicable 

in FY 2018 and beyond), or minimum budget requirement. 

In FY 2017, should FEMA grant an Economic Hardship Waiver of the cost share 

requirement for AFG or FP&S recipients, this shall only have an effect on the recipient’s 

required cost share. FEMA will not increase the amount of the Federal share awarded for 

FY 2017. Beginning in FY 2018 and in subsequent years, FEMA may consider 

increasing the amount of the Federal share awarded for AFG or FP&S recipients. Should 

FEMA grant an Economic Hardship Waiver of the cost share or position cost limit 

(applicable in FY 2018 and beyond) requirement for SAFER recipients, the amount of the 

Federal share awarded may be increased in order to allow for the hiring of firefighters as 

requested in the application. 

G. Roles & Responsibilities 

1. The FEMA Grant Programs Directorate, Assistance to Firefighters Grant Program 

Branch is responsible for the content of this IB. 

2. FEMA AFGP Program Staff are responsible for implementing this IB, including 

confirming that recipients have properly applied for an Economic Hardship Waiver per 

the terms of this IB and reviewing every Economic Hardship Waiver request. 

3. AFG/FP&S/SAFER Recipients are responsible for requesting an Economic Hardship 

Waiver per the terms of this IB. 

4. The Assistant Administrator of Grant Programs, on behalf of the FEMA 

Administrator, will have the final authority to make determinations as to whether a 

request for an Economic Hardship Waiver will be granted. 

5. The AFGP Help Desk is responsible for addressing recipient’s questions and requests 

for additional information. 

IV. Questions 

Questions regarding this IB may be directed to the AFGP Help Desk at 

firegrants@fema.dhs.gov or by calling (866) 274-0960.
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V. Review Date 

This IB will be reviewed within five years (5) from date of issuance.