How not to get denied reimbursement for AFG-purchased communications equipment
Many departments have had to pay back FEMA, or are not getting reimbursed because the purchases are not P25 compliant
If you received an Assistance to Firefighters Grants (AFG) Award for interoperable communications equipment, please make sure that all equipment purchased are APCO Project 25 (P25) compliant.
In recent weeks, we have heard of a number of departments whose AFG awards are now in jeopardy because they failed to comply with the SAFECOM regulations and AFG program requirements.
When this is found to be the case, these purchases are ruled ineligible. If this is discovered when the grantee is requesting to draw down funds, these expenses will be deemed unallowable, and not reimbursed by FEMA. If the non-compliant equipment is discovered during an audit or desk review, or after reimbursement has been made, the grantee will be required to return those funds to FEMA.
The majority of these departments ended up in this predicament unintentionally. Here are some scenarios that explain how they got there, and how it could have been avoided:
Know what you’re buying
The first scenario involves grantees who did not study the P25 guidelines and/or did not examine the communications equipment when they purchased it to ensure compliance. All AFG applicants should conduct market research prior to submitting their application.
Ask prospective vendors if the desired communications equipment is P25 compliant and operates in accordance with SAFECOM regulations and technical standards. If you have questions, or are not sure, manufacturers are required to produce, upon request, supporting documentation that shows the specified equipment is P25 compliant.
Know that “upgradable” doesn’t mean compliant
A second scenario involves departments who purchased communications equipment that they were told was “upgradable,” and happened to be significantly less expensive than the P25 compliant equipment.
Remember, anytime you purchase anything that has a drastically lower price, there is a reason. The interoperable communications equipment you purchase with AFG funds must meet P25 compliance the day you take possession of it.
Don’t do it on purpose
A third scenario involves departments who may have intentionally violated the P25 requirement. If it is found that these grantees willfully misled the government, either in their application or through their request for reimbursement, they may be referred to the Office of the Inspector General for further investigation and possible prosecution.
It is the grantee’s responsibility to obtain and retain documented evidence that the equipment to be acquired has been tested and passed all the applicable P25 requirements. The grantee should be able to produce such documentation to the AFG Program Office upon request.
AFG applicants do not have to identify a specific P25 product in their application narrative, but they must affirm that the interoperable communications equipment requested or acquired is P25 compliant.
As an initial step in researching P25 compliant communications equipment, for either your Assistance to Firefighters Grants (AFG) application or an AFG award; please visit the DHS Lessons Learned Information Sharing website, RKB Certifications & Declarations:
- Type the vendor/manufacturer name of the equipment being researched into the “Title” box and hit “APPLY”
- Products listed will have supporting P25 documentation. Click on the product for specification details and documentation.
The move to P25 compliant communications equipment is another attempt to standardize our response capabilities. APCO Project 25 is a set of standards produced through the joint efforts of the Association of Public Safety Communications Officials International (APCO), the National Association of State Telecommunications Directors (NASTD), selected federal agencies and the National Communications System (NCS). It’sstandardized under the Telecommunications Industry Association (TIA).
P25 communications equipment has numerous beneﬁts in performance, efficiency, capabilities and quality.
It is programmable, scalable, and can communicate in analog mode with legacy radios and in both analog and digital mode with other P25 equipment.
P25 compliant equipment also has encryption capability, and improved audio quality. P-25 radios will allow users from different agencies or areas to communicate directly with each other. This will allow agencies at the federal, state or local level — basically any agency —to communicate more effectively with each other when required. This is critical during large-scale emergency situations.