Local Recipient Organization (LRO) Criteria
Criteria for LROs
For a local agency to be eligible for funding it must:
- Be nonprofit or an agency of government;
- Not be debarred or suspended from receiving Federal funding;
- Have a checking account. (Cash payments are not allowed);
- Have an accounting system or fiscal agent approved by the Local Board;
- Have a Federal Employer Identification Number (FEIN), (Note: contact local IRS office for more information on securing FEIN and the necessary form [SS-4] or go to the website: www.irs.gov);
- Have a Data Universal Number System (DUNS) number issued by Dun & Bradstreet (D&B) and provide along with other required associated information (See the EFSP website for information on how to obtain.)
- Conduct an independent annual audit if receiving $100,000 or more in EFSP funds; conduct an annual accountant's review if receiving $50,000 to $99,999 in EFSP funds. See Annex 12, page 103.
- Conduct annual audit, if expending $750,000 or more in Federal funds, in compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards at 2 CFR 200 of the Office of Management and Budget;
- Be providing services and using its other resources in the area in which they are seeking funding;
- Practice nondiscrimination (those agencies with a religious affiliation wishing to participate in the program must not refuse services to an applicant based on religion or require attendance at religious services as a condition of assistance, nor will such groups engage in any religious proselytizing in any program receiving EFSP funds;
- Have a voluntary board if private, not-for-profit; and,
- To the extent practicable, involve homeless individuals and families, through employment, volunteer programs, etc., in providing emergency food and shelter services.
Each award Phase, each LRO must certify to the Local Board by signing the LRO Certification Form for the specific Phase and forwarding it to the Local Board that they have read, understand and agree to abide by the EFSP Responsibilities and Requirements Manual including the LRO Responsibilities section, Financial Terms and Conditions, Program Costs (eligible and ineligible), and Required Documentation. See Annex 3, page 93.
Use of Funds
Provide services within the intent of the program. Funds are to be used on an ongoing basis to supplement and extend food and shelter services, not as a substitute for other program funds or to start new programs. Funds are not to be held or reserved for future use but spent on an as needed basis to supplement and extend existing services. Agencies must have a program in the category for which they are seeking funding. All funds awarded to an LRO must provide for services within the jurisdiction’s spending period. See pages 61-69 for eligible and ineligible program costs.
Bank Accounts/ Interest Income
Maintain a checking account in the LRO's name in a federally insured bank into which EFSP funds are deposited. (Bank accounts must not be set up with FEMA, EFSP or in the name of the LRO’s program.) The National Board does not require funds to be placed in a separate bank account. LROs are required to notify the National Board in writing of any changes in their bank account for EFT purposes. This includes changes such as the closure of bank accounts, opening new bank accounts, and mergers of financial institutions. LROs funded in multiple jurisdictions must provide bank account changes for each jurisdiction individually even if funds are deposited into the same account. The EFT authorization form must be used for initial sign-ups and
Annual Audit Requirements
Comply with audit requirements. For LROs receiving $100,000 or more in EFSP funding, the National Board requires an independent annual audit in accordance with Government Auditing Standards. For LROs receiving from $50,000 to $99,999, the National Board requires an annual accountant’s review. For newly funded LROs or LROs funded above the amount requiring an audit or review for the first time, the LRO will be eligible to receive funds if it arranges for the audit or review of funds to coincide with the next scheduled annual audit or annual review of its financial affairs. See Annexes 12-13, pages 103-104.
The National Board will accept an LRO’s national/regional annual audit if the following conditions are met:
- LRO is truly a subsidiary of the national organization (i.e., shares a single Federal tax exemption).
- The LRO is audited by the national/regional office internal auditors or other person designated by the national/regional office AND the national/regional office is audited by an independent certified public accountant or public accountant or accounting firm, which includes the national/regional organization’s review of the LRO in a larger audit review.
- A copy of the local audit review along with a copy of the independent audit of the national/regional office will be made available to the National Board upon request.
Technical Assistance
Contact should first be directed to the Local Board regarding technical assistance, interpretation of guidelines and resources from other Federal programs as Local Boards are responsible for providing training and technical assistance to LROs.
NOTE: The EFSP website has a training feature for LROs (www.efsp.unitedway.org) to familiarize new staff and board members with EFSP requirements. Another training opportunity has been made available by FEMA’s Emergency Management Agency Institute at the following address: (http://www.training.fema.gov/emiweb/IS/IS420.asp).
Method of Payment
All awards will be paid in two equal installments. Except for the first check to newly funded LROs, the National Board will make all payments by electronic funds transfer (EFT) only. If an LRO has received funds subsequent to October 1998 (Phase 17), they are not considered new for payment purposes; therefore they must have EFT in place to receive payments. This authorization form is made available to each new LRO with their first payment notice and may be printed from the EFSP website or it may be obtained by contacting the National Board staff for the preprinted authorization form.
First Payments
The National Board will issue first payments by EFT to eligible LROs funded in the previous phase. LROs with any known compliance problems from any phase in any jurisdiction in which they received funds are not eligible to be paid until all compliance problems are resolved. The National Board will issue checks to newly funded eligible LROs (those not funded prior to the EFT requirement established in October 1998) for the first payment only.
Technical Assistance
Local Boards must read, understand and be familiar with the EFSP guidelines as found in this manual and provide technical assistance to LROs. Local Boards are responsible for the training of all LROs and should ensure new LROs have thoroughly read this manual and are trained before incurring expenses. The Local Board should be familiar with any personnel changes within an agency to ensure that new staff are trained. Questions that cannot be answered by Local Boards must be referred to the National Board staff. Any matter of interpretation must be referred to the National Board staff at [email protected]. Please reference your Local Board ID number and LRO number when contacting the National Board staff.
NOTE: The EFSP website (www.efsp.unitedway.org) has a training feature for LROs to familiarize new staff and board members with EFSP requirements. FEMA's Emergency Management Institute also provides a training opportunity