SSBG Hurricane Sandy FAQs

Publication Date: February 4, 2015
Current as of:

Answer

• Administrative Costs
• Appeals
• Child Care
• Congregate Meals
• Domestic Violence
• Equipment
• Eligibility
• Extensions
• FEMA
• Health Care
• Housing
• Improper Payments
• Insurance
• Lost Wages
• Mental Health
• Notice of Federal Interest
• Reimbursement
• Repair, Renovation, Rebuilding
• Reporting Requirements
• Waiver Requirements

 

Administrative Costs

  1. Human face with question mark illustration on white backgroundQ - What type of administrative activities can be included in the service delivery and what type of activities are solely administrative?
    A - General grant administration, audit oversight, and other statewide financial management count as administrative costs. Non-service costs that support a specific programmatic activity (e.g. facilities and management) are not administrative costs.
  2. Q - What costs should be included on line 31 “Administrative Costs” on the SSBG post-expenditure report form?
    A - Administrative costs include costs related to planning and evaluation, personnel training and retraining directly related to the provision of services, licensing activities, and the overhead costs of providing services as authorized under Section 2002(a)(2)(B) of the Social Security Act [42 U.S.C.1397a(a)(2)(B)].
  3. Q - Is there a percentage limit on the amount of administrative/ indirect costs that can reimbursed by these SSBG funds?
    A - There is currently no administrative cap. The SSBG program has developed strategies, including annual long-term performance measures, to ensure that SSBG funds are spent effectively and efficiently. States have been encouraged to initiate efficient management of the SSBG Program to decrease administrative costs to nine percent or less.

Appeals

  1. Q - What is the Department of Health and Human Services’ (HHS) appeal process if a business or individual wants to dispute a state’s eligibility or programmatic determination?
    A - HHS block grant regulations 45 CFR 96.50 specify that complaints related to the Social Services Block Grant should be submitted to the Administration for Children and Families (ACF) Assistant Secretary.  Any disputes received by a state should be provided to ACF within 60 days of advisement of the complaint.  ACF will provide a written response to the complainant within 180 days of receipt.

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Child Care

  1. Q - Can Sandy SSBG Supplemental funds be used to repair, renovate, or rebuild child care centers?
    A - Yes, States can use funds for the repair, renovation, and rebuilding center-based or family child care facilities that were damaged by Hurricane Sandy. Sandy SSBG Supplemental funds may also be used for the costs of replacing supplies, learning materials, outdoor play equipment, or furniture, such as cribs.
  2. Q - Can 2013 Supplemental SSBG Funds be used for child care vouchers?                                                     
    A - Yes, Sandy SSBG supplemental funds can be used to support child care services.  Eligible states may establish a voucher or subsidy payment approach, but would need to make sure appropriate controls were in place to ensure that vouchers were directed to disaster-affected populations and that funds would be obligated and expended within the allowable time frames.  Alternately, the State may also choose to enter into a contract or grant with child care centers or providers in order to reserve slots for children of impacted families.

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Congregate Meals

  1. Q - Can Sandy SSBG supplemental funds be used to provide food at disaster-specific recovery classes, open to affected residents, with the intention of promoting community resources?
    A - Yes, providing meals at recovery classes is allowable based on the definition of congregate meals. Congregate meals are services or activities designed to prepare and serve one or more meals a day to individuals in central dining areas in order to prevent institutionalization, malnutrition, and feelings of isolation. Component services or activities may include the cost of personnel, equipment, and food; assessment of nutritional and dietary needs; nutritional education and counseling; socialization; and other services such as transportation and information and referral.

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Domestic Violence

  1. Q — Where can I find resources and support for domestic violence or intimate partner violence?
    A — Highly trained expert advocates are available 24/7 to talk confidentially with anyone experiencing domestic violence, seeking resources or information, or questioning unhealthy aspects of their relationship. Call 1-800-799-7233 or 1-800-787-3224 (TTY) or visit thehotline.org for assistance.

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Eligibility

  1. Q - Are repairs for businesses eligible?
    A - Repairs to businesses are not an allowable use of Hurricane Sandy supplemental SSBG funds.
  2. Q - Are "undocumented persons" eligible for services funded by SSBG?
    A - No, "undocumented persons" are not eligible for services funded by SSBG that are considered "Federal public benefits".  States must ensure that Federal provisions related to verification of qualified immigrant status in providing services are in full compliance.
  3. Q - What are the parameters of using SSBG funds to reimburse religious institutions?
    A - There is no federal prohibition on states providing Sandy SSBG supplemental funding to faith-based organizations.  States may set their own guidelines for awarding of sub awards under the statute.  Consistent with federal regulations, funds may not be used for proselytization or activities for which a client may have a religious objection.  The state should take care that sub-awardees make provisions to provide clients with services or activities consistent with the client's desires, and alternatives, as needed. View ACF's policy on grants to faith-based organizations for additional information.
  4. Q — Can states reimburse community agencies for expenditures directly related to Hurricane Sandy?
    A - Yes, states may use Sandy SSBG supplemental funds to reimburse units of local governments, emergency responders, faith-based organizations and consortiums that incurred expenditures providing social services to people directly affected by Hurricane Sandy.
  5. Q - Is the purchase of food cards an allowable use of Sandy SSBG Supplemental funding?
    A - Yes. Eligible grantees and their sub-recipients may use supplemental SSBG funds to pay for food card costs for individuals and families who were affected by Hurricane Sandy and are targeted for services within the state's Intended Use Plan.

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Equipment

  1. Q - Can repair or replacement of vehicles and equipment at nonprofits be funded with 2013 Supplemental SSBG Funds?
    A - Yes. Supplemental funds may be used to repair or replace vehicles and equipment damaged/destroyed by Hurricane Sandy in order to provide access services, medical care, or employment.
  2. Q - Can grantees purchase hardware and/or software to track and coordinate services to Sandy survivors?
    A - Yes.  If the purpose of a database is to track and coordinate services to people and organizations impacted by Hurricane Sandy, hardware and software may be purchased for this purpose.
  3. Q - Can Sandy SSBG supplemental funds be used to purchase supplies and/or equipment which will aid in future disasters?
    A - No, Sandy SSBG Supplemental funds cannot be used to purchase supplies and/or equipment that will aid in future disasters.

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Extensions

  1. Q - Can eligible states request an extension to expend Sandy SSBG supplemental funding beyond the September 30, 2015 deadline?
    A — The Administration for Children and Families (ACF) has advised eligible states to submit any waiver requests for extensions to ACF’s Office of Community Services by January 22, 2015 for review and consideration. It should be noted that the Office of Management and Budget will make the final determination on state’s requests for extensions to expend funds.

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FEMA

  1. Q - Can Sandy SSBG Supplemental funds be used to pay the non-federal share of FEMA Public Assistance grants?
    A - No. Check the FAQs on the FEMA Public Assistance Program for guidance.
  2. Q - Where can I find information on FEMA’s Hurricane Sandy recovery activities?
    A - FEMA provides updates on its Hurricane Sandy disaster recovery activities online.
  3. Q - Is FEMA Individual Assistance registrant data available by county for use by the State?
    A - Yes, please refer to the FEMA website for information on Individual Assistance registrant data.

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Health Care

  1. Q - What is the difference between the ’regular’ Title XX ’Health-Related Services’ and ’Health Care Services’ allowable under the Sandy SSBG supplemental program?
    A - Health-Related Services are in-home or out-of home services or activities designed to assist individuals and families to attain and maintain a favorable condition of health.  Component services and activities may include providing an analysis or assessment of an individual’s health problems and the development of a treatment plan; assisting individuals to identify and understand their health needs; assisting individuals to identify and understand their health needs; assisting individuals to locate, provide, or secure and utilize appropriate medical treatment, preventive medical care, and health maintenance services, including in-home health services and emergency medical services; and providing follow-up services as needed. 

    Health Care Services is the provision of medical care.
  2. Q - Can the cost of medications or durable medical equipment for an individual be covered by Sandy SSBG Supplemental funds?
    A - Yes, these funds are intended to be available to address necessary expenses resulting from Hurricane Sandy, including health and mental health services for individuals.
  3. Q - Can individuals that have health insurance under the Affordable Care Act receive clinical services funded with Sandy SSBG funds after January 1, 2014?
    A - If an individual receiving SSBG-paid clinical services is eligible for health coverage under the Affordable Care Act, then SSBG funding should not be used to provide duplicate services. Two sources of federal funding may not be used to pay for the same service.

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Housing

  1. Q - Is the provision of temporary housing for Hurricane Sandy survivors an allowable cost for Sandy SSBG supplemental funds?
    A - Yes, states may use Sandy SSBG supplemental funding to pay for temporary housing for disaster survivors displaced due to Hurricane Sandy.
  2. Q - Can funds be used to pay off liens or judgments for approved home-rebuild applicants, if those applicants are unable to pay themselves?
    A - No. Sandy SSBG supplemental funds cannot be used to pay off liens or judgments for approved home-repair applicants.

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Improper Payments

  1. Q — What is an improper payment?
    A - The 2010 Improper Payments Elimination and Recovery Act (IPERA) defines an improper payment as a payment that should not have been made or that was made in an incorrect amount, including both over- and under-payments. This definition includes payments that were made to an ineligible recipient, duplicate payments, payments for a good or service not received, and payments that do not account for credit for applicable discounts.
  2. Q — How is “payment” defined under the 2010 Improper Payments Elimination and Recovery Act?
    A - Under IPERA, “payment” is defined as a transfer or commitment to transfer federal funds in the future—including cash, securities, loans, loan guarantees, and insurance subsidies—to a nonfederal entity.
  3. Q — Does the 2010 Improper Payments Elimination and Recovery Act apply to Sandy SSBG supplemental funding?
    A — Yes. Federal programs receiving Hurricane Sandy Disaster Relief funds are considered susceptible to significant improper payment and are required to report an improper payment error rate.

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Insurance

  1. Q - Can Hurricane Sandy funds be used to reimburse insurance deductibles?
    A — Yes. Insurance providers require individuals to pay a deductible before the provider fulfills its payment obligations. Insurance deductibles are not reimbursed by providers.  Subsequently, using Sandy SSBG supplemental funding to reimburse insurance deductibles directly related to Hurricane Sandy recovery needs is an allowable use of funds, if all other requirements for reimbursement are met and there is no duplication of benefits.

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Lost Wages

  1. Q — Can states use Sandy SSBG supplemental funding to cover payroll expenses of employees who were unable to work because their employer’s facilities were closed due to Hurricane Sandy? Some community agencies had to pay their personnel for the days that their facility was closed and services were not being delivered.
    A — No. Even when used in disaster response, reimbursement is only allowed for services actually provided. Moreover, Section 2005 of the Social Services Block Grant Act is clear that SSBG is not available for “the provision of cash payments as a service.”  42 USC 1397d(a)(8).  There are no provisions of the statute addressing payment for lost revenue and none of the language appropriating SSBG funds for Sandy disaster response contradicted or overrode these provisions.  Thus, the provision of SSBG funds for services not provided would clearly contravene the statute. This is a cost for which SSBG Hurricane Sandy funds should not be used for reimbursement.

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Mental Health

  1. Q — Can Sandy SSBG supplemental funds be used to provide mental or behavioral health services to Sandy survivors?
    A - Yes, Sandy SSBG supplemental funds may be used to help meet the mental health needs of people affected by the Hurricane Sandy. States should take reasonable and prudent action to ensure that mental health services funded by Sandy SSBG supplemental funds are limited to Hurricane Sandy survivors.
  2. Q - If someone is experiencing stress or other behavioral health impacts from Hurricane Sandy, where can they get support?
    A - If you or someone you know has been affected by a disaster and needs immediate assistance, please call the toll-free Disaster Distress Helpline at 1-800-985-5990 or Text TalkWithUs to 66746  number for information, support, and counseling. You will be connected to the nearest crisis center.

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Notice of Federal Interest

  1. Q — When does a Notice of Federal Interest apply?
    A - If a state undertakes renovations, repairs, or rebuilding to a property that exceed the lesser of $200,000 or 25 percent of the total allocation for the State, a Notice of Federal Interest (NFI) must be filed in the appropriate property records for the jurisdiction in which the property is located. Renovation, repair, or rebuilding costs that fall below this threshold are not covered by the requirement.

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Reimbursement

  1. Q - Can SSBG funds be used for loan repayment?
    A - States may pay for all or a portion of expenses for which an individual or agency would otherwise qualify only for loan assistance, provided that the expenses are directly related to Hurricane Sandy and are otherwise consistent with a state’s SSBG eligibility criteria and are included in the state’s Intended Use Plan. States must ensure that activities are not reimbursable through FEMA disaster assistance, under a contract for insurance, or by self-insurance.
  2. Q - Can Sandy SSBG supplemental funds be used to repay mortgage loans?
    A — Using Sandy SSBG supplemental funds for repayment of mortgage loan costs requires a waiver.

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Repair, Renovation, and Rebuilding

  1. Q - Is advance federal approval required to use Sandy SSBG Supplemental funds for construction or renovation?
    A - Yes, the Administration for Children and Families must approve of construction and renovation projects in a state’s Intended Use Plan prior to the start of construction. Waiver requests for renovation, repair, or rebuilding must include a description of the services and activities to be supported and the extraordinary circumstances warranting a waiver. States must also certify that the requested costs are not reimbursable through FEMA disaster assistance, under a contract for insurance, or by self-insurance.
  2. Q - Does the Davis-Bacon Act apply to Sandy Supplemental SSBG funds?
    A - Federal grant programs can only require grantees to adhere to provisions of the Davis-Bacon Act if the federal statute authorizing the program requires it. The Department of Health and Human Services has concluded that the Davis-Bacon Act does not apply to construction activities paid for in whole or in part with Sandy SSBG supplemental funds. However, state laws must be followed. ACF recommends that states check with their Attorney General to determine whether state construction projects are subject to prevailing wage rate requirements under applicable state law.
  3. Q - Can states use Sandy SSBG supplemental funds for repairs to school facilities?
    A - No.  SSBG funds may not be used for repairs to school facilities.  However, Sandy SSBG supplemental funds may be utilized for Education and Training Services to help meet the social service needs of affected individuals.

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Reporting Requirements

  1. Q — Are states required to submit reports on their programs that are funded with Sandy SSBG supplemental funds?
    A — Yes. States that received Sandy SSBG supplemental funds are required to submit pre-expenditure reports (intended use plans) detailing proposed uses of their supplemental SSBG grant award. States receiving Sandy SSBG supplemental funds are also required to submit post-expenditure reports. The post-expenditure report for the Hurricane Sandy SSBG Supplemental funds is due after each annual reporting period.  The report is separate from the report that states submit for the traditional SSBG program.
  2. Q - What are the SSBG reporting requirements with regard to immigration status?
    A - There is no reporting requirement for immigration status on the either the pre- or post-expenditure reporting form (OMB NO.: 0970-0234).  Data are collected by service category and recipient ages (children, adults 59 years and younger, adults 60 years and older, adults of unknown age).

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Waiver Requirements

  1. Q - What activities allowed under the Hurricane Sandy supplemental require a federal waiver?
    A - Waiver requests are required for activities that involve:
    (1) The purchase or improvement of land, or the purchase, construction, or permanent improvement (other than minor remodeling) of any building or other facility; or
    (2) The provision of medical care (other than family planning services, rehabilitation services, or initial detoxification of an alcoholic or drug dependent individual) unless it is an integral but subordinate part of a social service for which grants may be used under this title. Grantees must document extraordinary circumstances justifying the waiver and demonstrate that permitting the waiver will contribute to the state’s ability to implement the purposes outlined in Title XX of the Social Security Act.
  2. Q - Are separate waiver requests required for each activity? For example, are separate requests required for each building repair?
    A - No. States may submit consolidated waiver requests. For example, states may submit a table outlining proposed services and/or repair and reconstruction activities.

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