NSGP reports, equipment records and closeout

Why the SAA asks for reports

FEMA's reporting duties fall on the SAA, which receives the federal award; each nonprofit is a subrecipient (FY2026 NSGP NOFO). The SAA builds its federal reports from what its subrecipients send, and the subaward sets the forms and due dates the nonprofit must meet. The post-award roadmap shows where reporting and closeout fit with claims, changes, and monitoring.

Those federal deadlines matter to subrecipients, because the SAA pays them from the same award. FEMA "may withhold future federal awards and cash payments if FFRs are not timely, complete, detailed, and accurate" (NOFO, Financial Reporting Requirements). For FY2024 and later awards, the BSIR replaces the former Performance Progress Report, but FEMA still requires a separate final performance report at closeout (Preparedness Grants Manual, section 5.3). The FY2026 NOFO is internally inconsistent: its performance table shows one January 1–December 31 period due January 30, while the preceding text calls for two reports a year. Follow the SAA's calendar.

What the subrecipient owes the SAA

The subaward sets the forms, frequency and due dates. Federal rules set the outer limits. An SAA must collect financial and performance reports at least annually and no more often than quarterly, unless it imposes a specific condition, and a quarterly or semiannual report must be due no later than 30 calendar days after the period ends (2 CFR 200.328(b)–(c); 2 CFR 200.329(c)(1)). A specific condition can add "additional or more detailed financial reports," and the SAA must first tell the subrecipient why and how to have the condition removed (2 CFR 200.208(c)–(d)).

Published state calendars show how much the dates differ. These come from earlier award years and illustrate the range; they don't predict what an FY2026 subaward will say.

What a progress report should show

Report against the approved milestones. Under 2 CFR 200.329(c)(2), performance reports should compare accomplishments with the award's objectives and, where appropriate, explain unmet goals and "cost overruns or higher-than-expected unit costs." The SAA's BSIR needs updated obligations, expenditures, and significant developments for every project (NOFO, Programmatic Performance Reporting Requirements). Report measurable progress, such as equipment installed or guard hours delivered.

When a significant development could affect the award between reporting dates, the subrecipient must notify the SAA. If a problem, delay, or adverse condition will materially impair the award's objectives, the notice must include a corrective-action plan and describe any assistance needed (2 CFR 200.329(e)). A vendor delay that threatens the end date belongs in that notice, along with any request covered in NSGP budget and scope changes.

Quarters with no spending

A quarter with no spending still needs whatever report the subaward requires. FEMA requires the SAA's financial report even "in periods where no grant award activity occurs" (Preparedness Grants Manual, section 5.2). Florida's FY2023–2024 onboarding guide requires a project status each quarter, whether or not funds were spent, until projects are complete and closeout has been requested. File from the first reporting period the subaward names, with a short, accurate status when nothing was spent.

Use the period labels and current form specified by the subaward, and update the status even when spending is zero. A skipped report or wrong reporting period can lead to a correction request or payment hold.

Equipment records

For FY2026, federal property rules define "equipment" as tangible personal property with a useful life of more than one year and a per-unit cost that equals or exceeds "the lesser of the capitalization level established by the recipient or subrecipient for financial statement purposes, or $10,000" (2 CFR 200.1). Older SAA materials may show $5,000, the former federal threshold. An SAA may also require tags or inventory records below the federal equipment threshold, so follow the current rule and any additional subaward requirement.

For each item, the property record must show a description, serial or other identification number, funding source including the Federal Award Identification Number, title holder, acquisition date and cost, federal share, location, use and condition, and any disposition data (2 CFR 200.313(d)(1)). These duties continue while the equipment is in use:

• Reconcile a physical inventory with the records "at least once every two years" (200.313(d)(2)).
• Keep a control system that guards against loss, damage and theft, investigate any loss, and notify the SAA of one that will affect the program (200.313(d)(3)).
• Maintain the equipment in working condition (200.313(d)(4)).
• Insure it at least as well as the organization's own property (2 CFR 200.310).

SAAs may add their own rules. Missouri's FY2024 workshop required that all NSGP-funded equipment "MUST be tagged," required an inventory form, and asked for loss, damage, or theft to be reported within 30 days. Idaho's 2024 guidance requires inventory records to remain in place "for the life of equipment." The FY2026 NOFO and Preparedness Grants Manual set no tagging rule, so check your subaward. The NOFO lists establishing and maintaining equipment inventory as a management and administration (M&A) activity. Any M&A charge for that work must be adequately documented under FEMA Information Bulletin 581 and kept within the 5% cap; follow the subaward before revising the budget. NSGP monitoring explains how a monitor compares the records with what is installed.

When equipment is no longer needed for the original project or other federally supported work, the organization must request disposition instructions if the award requires it. Items with a per-unit fair market value of $10,000 or less may be kept, sold, or otherwise disposed of with no further obligation. For more valuable items, FEMA or the SAA is owed its share of the current value or sale proceeds, and if it sends no instructions within 120 days the organization may keep or sell the item (2 CFR 200.313(e)). Unused supplies worth more than $10,000 in total at the end of the period of performance, if no other federal award needs them, may be kept or sold, but FEMA or the SAA is owed its share of their value (2 CFR 200.314).

Closeout

Closeout runs from the subaward's end date. Within 90 calendar days after the subaward's period of performance ends, "or an earlier date as agreed upon by the pass-through entity and subrecipient," the subrecipient must submit all required financial, performance, and other reports and liquidate all its financial obligations (2 CFR 200.344(b)–(c)). The FY2026 NOFO separately says subrecipient closeout materials are due within 90 days and gives the SAA 120 days after the federal period ends to submit its own closeout reports (NOFO, Closeout Reporting Requirements).

The SAA may approve a justified extension to the 90-day federal default, while the SAA and subrecipient may agree to an earlier deadline. Published SAA deadlines from earlier award years were much shorter:

• Missouri, FY2024: final claims and the final status report due 45 days after the period of performance ends.
• California, FY2024: the final cash request due within 20 calendar days after the subaward period ends, and a final BSIR showing all funds spent.
• Idaho, 2024: the final progress report due 15 days after the end of the performance period.
• Florida's public FY2023–2024 onboarding guide doesn't state a closeout deadline. Read it in the FDEM agreement and on Florida security grants.

File every closeout item the agreement lists, including any final claim, the final financial and performance reports, and any attestations or other documents. California's FY2024 supplement shows what an SAA checks before it closes a subaward: completed work, all funds requested and reimbursed or disencumbered, the accuracy of reported information, a reconciliation of actual costs to the subaward, modifications and payments, and the final BSIR. Keep that reconciliation current through the award; the final claim and the reimbursement rules are covered in NSGP reimbursement claims.

A subrecipient must promptly refund any unobligated funds it was paid and is not authorized to keep (2 CFR 200.344(e)). Administrative closeout costs may be incurred until the final reports are due, but they must be liquidated before that date and charged to the final budget period unless FEMA specifies otherwise (2 CFR 200.403(h)). All other costs must be incurred during the approved budget period. Missing a closeout report or an earlier deadline in the subaward can delay final payment and leave the subaward open.

After closeout

Specified obligations continue after closeout. FEMA or the SAA may still disallow costs and recover funds after a later audit or review, but must make that determination and notify the subrecipient "within the record retention period" (2 CFR 200.345(a)). Refunds and corrections, audit requirements, property rules, and record retention also continue. Audits, including when a single audit is required, are covered in NSGP monitoring.

How long to keep records

2 CFR 200.334 requires recipients and subrecipients to retain records for three years "from the date of submission of their final financial report." The period runs longer in listed cases: records involved in litigation, a claim, or an audit that starts before the three years end must be kept until the matter is resolved and final action is taken; FEMA or the SAA can extend the period by written notice; and equipment records must be kept for three years after final disposition.

The practical start date is unsettled when the subaward is silent. Section 200.334 addresses records of recipients and subrecipients, and 2 CFR 200.328(d) sends a subrecipient's final financial report to the SAA. The NOFO, Record Retention, describes the SAA's final FFR to FEMA and counts retention from "the date the final FFR is submitted." The sources reviewed do not resolve which event an NSGP subrecipient should use. Published SAA guidance sets different start points and periods:

• California, FY2024: three years from the date of the Cal OES Grant Closeout letter.
• Idaho, 2024: at least three years after notice that the grant is programmatically and fiscally closed, or after an audit report with findings is closed.
• Missouri, FY2024: at least five years from the end of the state fiscal year in which the grant closes, or later in the other cases the workshop lists.

Keep the full grant file until the latest date in the applicable written requirements, and ask the SAA which event starts its clock. Electronic copies may replace paper originals under procedures with periodic quality-control reviews (2 CFR 200.336). FEMA's and the SAA's rights of access "last as long as the records are retained" (2 CFR 200.337(c)).