The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consi...
The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT United States Department of Homeland Security 2025-003 Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Disposition of Audit Finding: The South Carolina Emergency Management Division (SCEMD) of the Office of the Adjutant General concurs with the audit finding. Corrective Action: The Agency will refine its Public Assistance (PA) Reimbursement Review SOP and related Recovery Grants and Finance staff training to specify a requirement to validate that for projects under PA grants declared in 2018 and before, Direct Administrative Costs (DAC) were expended before the end of the project period of performance. In addition, the Recipient has submitted a time extension for the project period of performance but does not yet have approval from FEMA. Notes: • DAC was an eligible category of costs in PA projects under disaster grants through 2017 and optional for those declared August 1, 2017, through October 04, 2018 (opt-in). • Federal PA policy shifted to a management costs approach for projects under incidents declared on or after October 05, 2018. See attached FEMA Recovery Policy FP 104-11-2. Management costs are eligible for reimbursement up to 180 days after the subrecipient completes its last non-management cost project (p. 5). • Guidance regarding Direct Administrative Costs (see FEMA table attached) indicates that project closeout activities are eligible direct costs,which may have led to the Recipient considering DAC during the closeout period as eligible even when the project period of performance had ended. • The Federal Agency involved, FEMA, closed the project without noting an issue with reimbursement of these expenditures. Anticipated Completion Date: June 30, 2026 2 Name of the contact person responsible for corrective action: • Emily Bentley, SCEMD Chief of Mitigation and Recovery, at (803) 737-8774 • Antonio Johnson, SCEMD Grants and Finance Manager, at (803) 737-8606