State-Led Public Assistance 

Guide 

February 2019
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State-Led Public Assistance Guide 

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Table of Contents

Chapter 1: Introduction .................................................................................................................1

Purpose.......................................................................................................................................1

Audience.....................................................................................................................................1

Scope and Applicability..............................................................................................................2

Supersession..............................................................................................................................2

Authorities and Foundational Documents................................................................................2

Document Management and Maintenance .............................................................................3

Chapter 2: Defining State-Led Public Assistance ........................................................................5

Purpose of State-Led Public Assistance...................................................................................6

Recipient Benefits......................................................................................................................7

Chapter 3: Public Assistance Operation Overview.......................................................................9

Public Assistance Grant Life Cycle Overview............................................................................9

Key Functions...........................................................................................................................11

State-Led Public Assistance Roles and Responsibilities.......................................................13

Reimbursement for Management and Administrative Costs................................................15

Chapter 4: State-Led Public Assistance Operating Concept.....................................................17

State-Led Public Assistance Options ......................................................................................17

Operational Agreement............................................................................................................21

Public Assistance Management Plan .....................................................................................21

Chapter 5: Decision-Making Considerations..............................................................................23

Joint Decision-Making Timeline ..............................................................................................23

Considerations for Selecting State-Led Public Assistance....................................................24

Chapter 6: Planning For State-Led Public Assistance ...............................................................27

Pre-Disaster Preparedness......................................................................................................27

Staffing Augmentation Mechanisms ......................................................................................28

Training and Assistance ..........................................................................................................29

Accountability ...........................................................................................................................30

Appendix A: Acronym List ...........................................................................................................A-1

Appendix B: Glossary ..................................................................................................................B-1
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Appendix C: Authorities and Foundational Documents............................................................C-1

Appendix D: Operational Agreement Template........................................................................ D-1

Appendix E: Public Assistance Grant Life Cycle ........................................................................E-1

Appendix F: Resource Toolkit.....................................................................................................F-1

List of Figures 

Figure 1: FEMA Doctrine Hierarchy...............................................................................................3

Figure 2: PA Grant Life Cycle.........................................................................................................9

Figure 3: Timeline for Initial Decision Making............................................................................24

List of Tables 

Table 1: Stages of the PA Grant Life Cycle.................................................................................10

Table 2: Options for State-Led PA...............................................................................................17

Table 3: PA Grant Life Cycle Overview of Responsibilities and Corresponding Options .........19

Table 4: Summary of PA Management Plan ..............................................................................22

Table 5: Current Recipient Post-Disaster Capacity Considerations..........................................24

Table 6: Disaster Characteristic Considerations .......................................................................25

Table 7: Potential Topics for Pre-Disaster Preparedness Discussions ....................................27

Table 8: Pre-Disaster Preparedness Activities ..........................................................................E-1

Table 9: Pre-Declaration Coordination Responsibilities...........................................................E-2

Table 10: Operational Planning for PA Delivery ........................................................................E-3

Table 11: Intake Damage and Eligibility Analysis for PA Grants..............................................E-5

Table 12: Scoping and Costing for PA Delivery.........................................................................E-6

Table 13: Obligation of Funds for PA Delivery...........................................................................E-8

Table 14: Post-Award Grant Administration..............................................................................E-8

Table 15: PA Grant Closeout......................................................................................................E-9

Table 16: Resource Toolkit.........................................................................................................F-1
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CHAPTER 1: INTRODUCTION 

Purpose 

The Federal Emergency Management 

Agency’s (FEMA) State-Led Public Assistance 

Guide provides clear and streamlined 

guidance on the processes, resources, and 

capabilities required for Recipients to lead 

Public Assistance (PA) operations. This 

guidance outlines the process for Recipients 

and FEMA to determine if and under what 

conditions Recipients may elect to perform

certain PA disaster grant functions. While 

FEMA will always retain some functions for 

presidential disaster declarations in 

accordance with federal regulations and 

laws, Recipients may elect to take 

responsibility for executing one or more 

options for state-led PA functions, as defined 

in Chapter 4: State-Led Public Assistance

Operating Concept. Such a division of 

responsibility between Recipients and FEMA 

seeks to optimize the use of resources 

across all levels of government.

Audience 

Recipients, FEMA regions, and field 

leadership are the primary intended

audience of the State-Led Public Assistance 

Guide, which provides Recipients with clear 

direction on the processes, requirements, and capabilities necessary to manage PA

operations within their state, territory, or tribe. The State-Led Public Assistance Guide also 

informs FEMA headquarters (HQ), regional, and incident-level staff about how to coordinate 

and support a state-led PA operation.

Use of Terms 

State-Led Public Assistance (PA): The 

State-Led Public Assistance Guide will use 

the term state-led PA to denote when 

states, territories, or federally recognized 

tribes (“tribes”) lead PA operations.

Recipient: A non-federal entity, typically a 

state, territory, or tribe that receives a 

federal award directly from a federal 

awarding agency to carry out an activity 

under a federal program. 

Subrecipient: A non-federal entity that has 

been awarded funds under the Recipient’s 

federal award. When submitting an 

application to the Recipient for assistance, 

the Subrecipient is known as the Applicant. 

The State-Led Public Assistance Guide will 

use the term Subrecipient to encompass 

both Applicant and Subrecipient.

Level III Incident: A disaster, which because 

of its severity, size, location and actual or 

potential impact on public health, welfare, 

and infrastructure, requires a moderate 

amount of direct federal assistance. A 

Level III disaster requires coordination 

among involved federal, state, tribal, and 

local entities because of minor-to-average

levels and breadth of damage. 
State-Led Public Assistance Guide 

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Scope and Applicability 

The State-Led Public Assistance Guide establishes a common terminology to clarify the roles

and responsibilities Recipients and FEMA may lead or share throughout the PA grant life 

cycle. At this time, FEMA intends state-led PA operations to be undertaken primarily for 

Level III incidents. The State-Led Public Assistance Guide is not intended to prescribe 

Recipient operations during state-led PA but, instead, offers broad guidance that can be 

adapted to fit the needs of each Recipient’s emergency management resources at the time 

of the disaster. While tribal governments retain the decision to lead PA operations, tribes are 

primarily new Recipients at this time. FEMA acknowledges the need to provide additional 

resources to support tribes in developing and sustaining PA Program capability prior to 

leading a PA operation. Tribal governments that wish to pursue a path toward leading PA 

operations should reach out to their respective FEMA regional office.

Supersession

This document is consistent with existing authorities, policy, and doctrine. It does not 

supersede any existing doctrine, policies, or regulations governing the PA Program or the 

presidential disaster declaration process.

Authorities and Foundational Documents 

 Public Law 93-288, as amended, Sections 5121-5207, 42 U.S.C., Robert T. Stafford

Disaster Relief and Emergency Assistance Act (Stafford Act), 2018.

 Title 2 of the Code of Federal Regulations (CFR), Part 200, Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal Awards.

 Title 44 CFR, Emergency Management and Assistance.

 Federal Register Notice (FRN), Volume 66, Number 135, FR Doc No. 01-17533,

Documentation Citation 66 FR 36783, Notice of the State Management of Public 

Assistance Operations in Small Disasters, 2001.

 FP 104-009-2, Public Assistance Program and Policy Guide (PAPPG).

 National Incident Management System (NIMS), Third Edition, October 2017.

 National Response Framework (NRF), Third Edition, June 2016.

 National Disaster Recovery Framework (NDRF), Second Edition, June 2016.

 National Mitigation Framework, Second Edition, June 2016.

 FEMA, Incident Management and Support Keystone (IMSK), January 2011.

 FEMA, Regional Incident Support Manual (RISM), January 2013.

 FEMA, National Incident Management System Guideline for the National 

Qualification System, November 2017.
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 FEMA Directive 108-1, Environmental Planning and Historic Preservation (EHP) 

Responsibilities and Program Requirements and Companion Instruction, August 

2016.

Figure 1 depicts how the State-Led Public Assistance Guide maps to directly related FEMA 

doctrine.

 

Figure 1: FEMA Doctrine Hierarchy 

Document Management and Maintenance 

The FEMA Office of Response and Recovery (ORR), Doctrine and Policy Office is responsible 

for the management and maintenance of this document. Comments and feedback from 

FEMA personnel and stakeholders regarding this document should be directed to the ORR, 

Doctrine and Policy Office at FEMA HQ.

Incident Management 

and Support Keystone

Public Assistance 

Program and Policy 

Guide

State-Led Public 

Assistance Guide

Regional Incident 

Support Manual

Foundational 

Documents

Key

Foundational

Keystone

Manual

Guide
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CHAPTER 2: DEFINING STATE-LED PUBLIC 

ASSISTANCE 

FEMA's PA Program provides federal grant funding to governments and eligible private 

nonprofit (PNP) organizations so that communities can quickly respond to and recover from 

major disasters or emergencies declared by the President.

Through the PA Program, FEMA provides federal disaster grant assistance for debris 

removal, life-saving emergency protective measures, and the repair, replacement, or 

restoration of disaster-damaged, publicly owned infrastructure and the facilities of eligible

PNP organizations. The PA Program also encourages protection of damaged infrastructure

from future events by providing assistance for hazard mitigation measures during the 

recovery process. FEMA currently shares many aspects of the PA grant life cycle with the 

Recipient, such as the Joint Preliminary Damage Assessment (PDA). The Recipient currently 

takes an active leadership role for other responsibilities, including the Applicant Briefing. 

In 2001, FRN 66 FR 36783 authorized 

Recipients to lead PA delivery for Level III, smallsized presidential disaster declarations. Stateled PA refers to the delivery of PA to 

Subrecipients when the Recipient leads some 

responsibilities instead of FEMA. The concept of 

state-led PA provides structured flexibility for 

Recipients to manage PA delivery functions that 

fit their capacity at the time of disaster. The PA

delivery model provides a framework that 

facilitates performance monitoring and 

continuous improvement while also affording a 

consistent and tailored customer service experience for Subrecipients. Recipients leading 

PA operations must adhere to the requirements outlined in the PAPPG and FEMA’s PA 

delivery model. However, Recipients are not required to fill the positions FEMA uses to 

deliver the PA Program, such as Site Inspector or Program Delivery Manager. Recipients may 

choose to staff a PA operation consistent with the National Qualification System (NQS) 

guidelines in ways that meet the Recipient’s resource levels.

Following a Recipient's request for a presidential disaster declaration of a Level III incident, 

FEMA and the Recipient will jointly decide whether a state-led PA operation is appropriate 

given the Recipient's current capacity. If the Recipient chooses to lead the PA operation, 

FEMA and the Recipient will enter into an Operational Agreement, an addendum to the 

FEMA-State Agreement (FSA) that delineates the roles and responsibilities of the Recipient 

State-led PA Program Background 

In 2001, FEMA began allowing states 

to help lead PA operations for small 

disasters. Since then, several states 

have demonstrated the ability to lead 

PA delivery operations with varying 

levels of federal oversight. Experience 

from these participating states helped 

to inform the creation of the State-Led 

Public Assistance Guide. 
State-Led Public Assistance Guide 

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and FEMA. Appendix D: Operational Agreement Template includes the template that 

Recipients and FEMA will sign for each state-led PA operation.

For all PA operations, FEMA will do the following:

 Maintain oversight for state-led PA operations;

 Retain final eligibility determination and obligation authority;

 Participate in quality control reviews with the Recipient;

 Provide support, as requested by the Recipient;

 Ensure compliance with all federal Environmental Planning and Historic Preservation 

(EHP) laws, regulations, and Executive orders (EO);

 Issue final eligibility determinations; and

 Issue ineligibility determination memorandums and letters, as necessary.

Purpose of State-Led Public Assistance 

State-led PA maximizes the cooperative delivery features of the PA delivery model in a way 

that enhances the capacity of Recipients to satisfy their communities’ immediate and longterm recovery goals. This approach enhances the PA delivery model, allowing Recipients to 

lead recovery efforts in their communities with support from FEMA. 

State-led PA operations for Level III incidents will help preserve federal resources to respond

to and recover from large-scale or catastrophic events. Such operations also build national 

recovery capacity and strengthen the emergency management enterprise to one that is 

federally supported, state managed, and locally executed.
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Recipient Benefits 

For Recipients that elect to conduct state-led PA 

operations, the decision offers multiple benefits, 

including tailored customer service and increased

Recipient-level capability for future events and 

operational readiness. State-led PA also allows 

Recipients to play a greater role in focusing 

attention on and achieving their desired recovery 

outcomes.

Capacity and Capability Building 

State-led PA operations build Recipients’ internal 

capacity and capability to respond to and recover 

from disasters of all sizes, thus enhancing the 

readiness of the Recipient and Subrecipient for 

catastrophic events. Through increased training 

and disaster experience, which may be acquired internally or through a mutual aid 

compact(s) with other partners, Recipient personnel may enhance their capacity and 

capability along the continuum of PA grant management responsibilities.

Tailored Customer Service 

The principal advantage to a state-led PA operation, as identified by Recipients with 

experience conducting such operations, is the ability to ensure a tailored customer 

experience for Subrecipients throughout the PA grant life cycle. Recipients can develop and 

maintain stronger relationships with Subrecipients by achieving continuity in points of 

contact and interactions with the Subrecipient over extended periods of time. 

This continuity in contact (during disaster and steady-state periods) and familiarity with 

geographic areas and eligible facilities may lead to more efficient delivery of assistance to 

communities by reducing the time it takes to properly document disaster-specific damages 

and other eligibility requirements. In turn, stronger relationships and prior experiences 

between the Recipient and Subrecipients can lead to improved efficiencies in identifying and 

understanding Subrecipient needs.

With increased capacity and capability and more experience working closely with 

Subrecipients during disaster and steady-state periods, Recipient staff may have a more 

complete understanding of Subrecipient needs. This understanding can reduce the amount 

of appeals or audits, potentially result in fewer funds requiring de-obligation later in the 

process, and provide Recipients with a greater role in identifying requirements to right-size 

the recovery operation, including the federal staff presence in field offices.

Variation in Assessing Incident 

Complexity 

A Level III incident is not defined by a 

dollar threshold. A disaster with a large 

per capita damage amount may be 

relatively simple with a few 

Subrecipients, making it a likely 

candidate for state-led PA. Conversely, a 

disaster with a smaller per capita 

damage amount may be complex with a 

significant number of applicants, 

specialized projects, or other 

complicating factors that may impact 

the viability of a state-led option.

Diversity in the size and population of 

states also means that incident 

complexity can vary from state to state.
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CHAPTER 3: PUBLIC ASSISTANCE OPERATION 

OVERVIEW 

This chapter introduces the PA grant life cycle, key functions required for PA grant 

management, and the associated roles and responsibilities in a state-led PA operation. If a 

Recipient elects to pursue one or more state-led PA options, Recipient personnel may lead 

many of these functions or share responsibility with FEMA personnel. Chapter 4: State-Led 

Public Assistance Operating Concept defines state-led PA options. Appendix E: Public 

Assistance Grant Life Cycle provides more detailed information about the PA grant life cycle.

Recipients can use Appendix E: Public Assistance Grant Life Cycle to customize their own 

implementation of state-led PA operations.

Public Assistance Grant Life Cycle Overview 

Figure 2 shows an overview of the PA grant life cycle. Table 1 describes each stage of the PA 

grant life cycle.

Figure 2: PA Grant Life Cycle 

Pre-Disaster Preparedness

Pre-Declaration 

Coordination

Disaster

PA Program Delivery

Post-Award Grant 

Administration

Grant Closeout

Phase I: Operational 

Planning

Phase II: Damage 

Intake & Eligibility 

Analysis

Phase III: Scoping & 

Costing

Phase IV: Obligation

Repeat

Presidential Disaster 

Declaration
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Table 1: Stages of the PA Grant Life Cycle 

Stage of the PA 

Grant Life Cycle 

Description of Stage 

Pre-Disaster 

Preparedness 

Recipients can self-assess their capability to lead the PA grant program’s 

key functions and train necessary PA personnel.

Pre-Declaration 

Coordination 

After a disaster, the Recipient requests a presidential disaster declaration 

and coordinates with FEMA to conduct a joint Preliminary Damage 

Assessment (PDA).

Presidential Disaster 

Declaration 

The President will issue a disaster declaration that establishes the incident 

period, designated eligible areas, and types of assistance authorized. Once 

a presidential disaster declaration has been issued, the Recipient and 

FEMA engage in a discussion on whether a state-led PA operation is 

feasible and, if so, which key functions the Recipient will lead.

Public Assistance 

Program Delivery 

PA grant funding is delivered through a phased process that includes 

operational planning, intake and evaluation of damage, scoping and 

costing disaster-related damage, and project reviews, including EHP 

compliance, before FEMA obligates funds.

Post-Award Grant 

Administration 

After FEMA obligates the grant award, the Recipient monitors all work 

performed for scoping or cost changes and works with FEMA on audits or 

appeals.

Grant Closeout 

After all work has been completed, the Recipient and FEMA begin project 

closeout and de-obligate remaining funds, eventually resulting in disaster 

closeout. For more information about PA Program delivery, refer to the 

Public Assistance Program and Policy Guide (PAPPG).
State-Led Public Assistance Guide 

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Key Functions 

Throughout the delivery of PA grants, FEMA and 

the Recipient coordinate to each perform one or 

more key functions (customer service, site 

inspections, and scoping and costing) to 

formulate each subgrant or project. While each 

of these functions corresponds to FEMA PA 

position titles, such as the Program Delivery 

Manager (PDMG) or the Site Inspector (SI), 

Recipients have flexibility in deciding how to 

execute these key functions in accordance with 

the PA delivery model. Personnel performing 

these key functions coordinate with one another 

to ensure quality assurance.

Through the NQS, FEMA is developing position 

task books and position descriptions to help 

Recipients build capabilities required to perform 

these key functions. For current tools and 

position titles, see 

https://www.fema.gov/national-qualificationsystem. NQS positions are not meant to be 

prescriptive but, instead, represent effective 

service models that allow Recipients to participate in cross-cutting functional tasks or 

activities at levels commensurate with capabilities. The following sections describe the key 

functions of PA Program delivery as they relate to a state-led PA operation.

Customer Service 

A key aspect of the customer service function is walking assigned Subrecipients through 

subgrant formulation to ensure they understand the eligibility requirements, documentation 

requirements, and conditions of the subgrant. Customer service representatives are 

assigned to serve as the single point of contact for Subrecipients, providing consistent 

customer service and programmatic guidance throughout the PA grant life cycle. Customer 

service responsibilities include the following:

 Facilitating and coordinating communication with assigned Subrecipients to ensure 

continuity and alignment with the Subrecipients’ recovery priorities,

 Understanding the Subrecipients’ capacity and capability to develop projects, and

 Participating in site inspections, as necessary.

Electronic Systems 

The key functions described in this 

section are performed within FEMA’s 

designated electronic systems, the 

Grants Manager and Grants Portal. 

The Recipient must use these systems 

in conducting state-led PA operations.

Grants Manager establishes a 

collaborative workspace for 

management personnel to interact 

with Subrecipients and review, 

adjudicate, and approve PA projects.

Grants Portal streamlines the PA 

process and facilitates collaboration 

among FEMA, the Recipient, and the 

Subrecipient. The Grants Portal affords 

full project transparency for the 

Subrecipient by allowing all parties to 

upload work and documentation. 
State-Led Public Assistance Guide 

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Customer service representatives are responsible for facilitating all activities for assigned 

Subrecipients following the Recovery Scoping Meeting (RSM), including Essential Elements 

of Information (EEI) and Requests for Information (RFI), communication, and documentation 

review. As a result, the customer service function is generally a longer-term commitment 

performed throughout the entire PA grant. Skills important for performing customer service 

activities may include a strong understanding of PA grant eligibility and the PA delivery 

model, communications skills, and project management experience.

Site Inspections 

The site inspection function includes conducting site visits to assess damage and document 

if damage descriptions are accurate and disaster related. Personnel performing these tasks 

also develop the Damage Description and Dimensions (DDD) based on photographs, site 

sketches or drawings, and measurements taken during site visits for inclusion in the project 

files. As compared to customer service, site inspection functions are generally a shorter-term 

commitment and completed earlier in the process.

The nature of the incident and the category of work may determine the type and level of 

expertise, including specialized or technical expertise, required to conduct each site 

inspection. Furthermore, Recipients are encouraged to explore the potential to assign 

employees from other state agencies or departments, such as transportation or public 

works, to perform site inspection responsibilities, if feasible.

Scoping and Costing 

Scoping and costing includes developing the 

Scope of Work (SOW) and cost estimate for 

each subgrant or project under the PA award. 

The SOW is connected to the codified 

damages in the DDD and describes what 

work the Subrecipient will undertake to 

address eligible damages. The cost estimate 

is the anticipated amount of money required 

to complete requirements identified in the 

SOW. Recipients or Subrecipients may elect 

to develop the SOW and cost estimate 

themselves and submit to FEMA for review. 

Recipients with advanced capabilities in this 

key function may develop cost estimates for 

complex or highly technical projects or 

develop and maintain spend plans, with 

FEMA’s final approval.

Special Considerations 

In performing each of these key functions, 

FEMA and the Recipient maintain a 

responsibility to uphold federal regulations 

around special considerations, including 

environmental planning and historic 

preservation (EHP), insurance, and 

mitigation. This may include identifying 

issues as they arise, notifying appropriate 

subject matter experts, and collecting or 

preparing required documentation to 

ensure work performed under the grant 

complies with federal regulations.
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State-Led Public Assistance Roles and Responsibilities 

State-led PA allows for the seamless integration of Recipient personnel into key PA functions

with flexibility that best suits the Recipient’s capacity. Recipients can decide to perform 

responsibilities associated with one or more key functions and have the flexibility to organize 

their resources to focus on what they have the capacity to address and focus FEMA support 

on areas that require supplemental assistance. This flexibility allows for Recipients to 

implement a fully state-led PA operation or perform some of the key functions and orient 

their state-led operations along geographic, sector, or functional lines. FEMA must, by law 

and regulation, retain certain inherently federal responsibilities, such as obligating funds, 

making eligibility determinations, adjudicating appeals, and ensuring compliance with all 

applicable federal regulations and statutes, such as EHP. For more information about stateled PA, see Chapter 4: State-Led Public Assistance Operating Concept.

Governor and Governor’s Authorized Representative (GAR) 

The governor of a state initiates the declaration process by requesting the presidential 

disaster declaration within 30 days of the occurrence of the incident if it exceeds Recipient 

and local government capabilities to respond.1 The governor or the GAR can also request to 

add additional jurisdictional areas or categories of assistance to the presidential disaster 

declaration. The governor or GAR engages in early and ongoing discussions with the FEMA 

Regional Administrator (RA) to determine whether state-led PA is appropriate and, if so, 

signs the Operational Agreement documenting the state’s planned responsibilities for the PA 

operation within 72 hours of signing the FSA. A state’s request to lead a PA operation and its 

subsequent submission of the Operational Agreement beyond the 72-hour timeframe may 

be approved at the RA’s discretion.

State Coordinating Officer (SCO) 

The SCO, as appointed by the governor, represents the Recipient and acts in cooperation 

with the Federal Coordinating Officer (FCO) to administer incident management efforts, 

including the PA Program. If the Recipient or FEMA identifies the need to amend the 

Operational Agreement or the PA Management Plan, the SCO will engage with the FCO on 

the proper course of action to do so. The SCO typically holds the authority to commit state 

resources and make obligations on behalf of the Recipient.

State Emergency Management Agency or Recipient Staff 

Specific roles and responsibilities for state emergency management agency or Recipient 

staff during a state-led PA operation would be determined after the Recipient chooses to 

 

1 The 30-day deadline may be extended upon request per 44 CFR 206.35 and 206.36.
State-Led Public Assistance Guide 

14

pursue a state-led operation and selects a state-led PA option(s) for the specific presidential 

disaster declaration.

To build capability for state-led operations, the Recipient or the state emergency 

management agency staff may also focus on pre-disaster preparedness activities, such as 

training, augmenting its disaster workforce (e.g., developing a disaster reservist or an 

augmentee program and establishing contracts), conducting assessments, and building 

organizational profiles in the Grants Portal electronic system before a disaster strikes. Staff 

may also revise plans, policies, and procedures that would help facilitate state-led PA 

following a presidential disaster declaration.

FEMA HQ 

FEMA HQ is responsible for national monitoring and oversight, data collection, and policy 

and guidance related to the PA Program. FEMA HQ staff will work with regions to standardize 

a method to capture state-led PA data and monitor progress.

The Recovery Analytics Division (RAD) will collect and analyze data on the state-led PA 

Program, and the Office of Policy and Program Analysis (OPPA) will use that data to ensure 

the program meets FEMA strategic objectives. Data requirements need to be clearly 

articulated and agreed upon with the Recipient, preferably in the PA Management Plan.

Regional Administrator (RA) 

The RA of the impacted region serves as the federal decision-making authority for the 

declared disaster until an FCO is appointed. The FEMA RA or his/her designee engages in 

early and ongoing discussions with the governor or GAR to determine whether state-led PA is 

appropriate and what state-led PA option(s) the state would like to undertake. The authority 

to obligate federal funding (i.e., Disaster Recovery Manager [DRM] authority) originates with 

the FEMA Administrator and is typically delegated to the RA. This authority is then usually

further delegated to the FCO.

Federal Coordinating Officer (FCO) 

The FCO, as identified by the presidential disaster declaration, works in conjunction with the 

GAR and SCO to coordinate federal resources and obligate PA Program funds for eligible 

activities. The FCO, in coordination with the RA, will coordinate with Recipients on which 

state-led PA option(s) is most suited for the Recipient’s current capacity.

Regional Public Assistance Leadership 

Regional PA Leadership, including the Regional PA Branch Chief, serve as the Recipients’

main points of contact for PA at FEMA. Depending on the size and extent of FEMA’s field 

presence, the Recipient may also coordinate directly with incident-level PA staff, such as the 

PA Group Supervisor. Recipients can contact Regional PA Leadership with questions related 
State-Led Public Assistance Guide 

15

to eligibility, staff organization, and federal grant compliance requirements. Recipients 

should reach out to the Regional PA Branch Chief for training resources or to request inperson training. Regional PA Leadership should be reaching out to potential Recipients

during pre-disaster preparedness to discuss the Recipients’ capability to participate in stateled PA and which key functions they would be interested in managing. Regional PA 

Leadership will consult with FEMA’s Office of Chief Counsel, as needed, when providing 

management and oversight of state-led PA operations.

Regional Environmental Officer 

The Regional Environmental Officer (REO) serves as the Recipient’s main point of contact for 

EHP compliance at FEMA. In a state-led PA operation, the ultimate responsibility for all EHP 

compliance and Agency decisions remains with FEMA. Recipients can contact the REO with 

questions related to compliance with EHP laws and EOs. If an EHP advisor has deployed to 

support a presidentially declared disaster, Recipients may contact him/her for assistance 

with EHP considerations.

Reimbursement for Management and Administrative Costs 

FEMA provides PA funding to reimburse Recipients for management and administrative 

costs related to managing the PA Program and PA projects. Recipients should contact their 

respective FEMA regional office for relevant resources and information on the latest policies 

and procedures for claiming and documenting eligible management and administrative 

costs.
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CHAPTER 4: STATE-LED PUBLIC ASSISTANCE 

OPERATING CONCEPT 

This chapter introduces the six potential options that FEMA has identified to ensure 

consistent application of the state-led PA Program. These options align with the key 

functions of the PA process: customer service, site inspections, and scoping and costing. 

The chapter later addresses the Operational Agreement and PA Management Plan, which 

document the Recipient’s intent to lead parts of the PA operation and outline details of how 

the state-led PA operation will be implemented, respectively.

State-Led Public Assistance Options 

The six state-led PA options offer Recipients a flexible mechanism to progressively build their 

capability and capacity. Each key function has two levels: shared and plus. For shared 

options, Recipients will lead all responsibilities for some projects, and for plus options, they 

will lead all responsibilities for all projects. In the plus options, Recipients may also take on 

other advanced responsibilities. This approach may be scaled up or down and may vary by 

disaster, depending on the Recipient’s capacity at that time. Table 2 lists the potential 

options of key functions for state-led PA operations.

Table 2: Options for State-Led PA 

Option Description

Customer 

Service Shared

Recipient performs the customer service responsibilities for some

Subrecipients, while FEMA performs these responsibilities for the rest. 

Recipients can distribute the responsibilities for Subrecipients with FEMA 

based on disaster-specific considerations.

Customer 

Service Plus 

Recipient performs all customer service responsibilities for all Subrecipients. 

Recipients capable of performing these responsibilities have demonstrated a 

working knowledge of the process and an ability to accurately assess eligibility.

Site Inspections 

Shared

Recipient performs the site inspection responsibilities for some projects. For 

example, Recipients may choose to conduct site inspections for all projects in 

the “Standard Lane” because they require less specialized or technical 

expertise, assigning the remaining “Specialized Lane” projects to FEMA.

Site Inspections 

Plus 

Recipient performs all site inspection responsibilities, including providing

specialized and technical expertise, for all projects.

Scoping and 

Costing Shared

Recipient performs all scoping and costing functions for some projects. This 

includes advanced responsibilities, such as developing the Scope of Work

(SOW) and cost estimates, and drafting Hazard Mitigation proposals. 

Scoping and 

Costing Plus 

Recipient performs all scoping and costing functions for all projects. This option 

would be reserved for select Recipients that have the necessary internal 

capabilities to perform functions requiring technical expertise and other 

specialized knowledge, including Environmental Planning and Historic 

Preservation (EHP). Recipients may choose to develop and maintain spending

plans with approval by FEMA.
State-Led Public Assistance Guide 

18

All Shared options may include on-the-ground FEMA support and distribution of 

responsibilities between the Recipient and FEMA, based on agreed-upon criteria (e.g., 

geographic boundaries, categories of work, and complexity).

All Plus options may include the Recipient assuming responsibility for all aspects of the key 

function (customer service, site inspections, or scoping and costing) and support from FEMA, 

which may be a physical Joint Field Office (JFO), virtual JFO, or regional support, depending 

on the needs of the disaster and at no additional cost to the Recipient.

For all options, FEMA retains decision-making authority for final eligibility determinations, as 

required by law. FEMA will issue the Determination Memorandum and Letter, but the 

Recipient may draft the Determination Memorandum and Letter for FEMA to review, 

approve, and send to the Applicant if performing customer service functions. If decisions 

over project eligibility cannot be agreed upon, FEMA and the Recipient will engage in the 

standard appeals process.

FEMA has final review and approval authority on the environmental impact of proposed 

federal action or undertaking; however, Recipients may assist FEMA with the preparation for 

environmental review, including providing background information for assessing the 

environmental impact of the federal action on historic properties, endangered and 

threatened species, critical habitats, wetlands, floodplains, and on low-income and minority 

populations. Recipients should work with their Subrecipients to evaluate and document 

environmental and cultural resource information involved with the proposed projects to 

consider alternatives to avoid, minimize, and/or mitigate potential adverse impacts to the 

human environment and to integrate sustainable practices as early as possible in project 

formulation. Finally, Recipients must coordinate with FEMA Regional EHP staff to receive 

EHP clearance.

Table 3 identifies which steps in the PA grant life cycle are always performed by FEMA, the 

Recipient, or shared. Additionally, Table 3 identifies the steps corresponding to each key 

function which the Recipient can choose to perform in a state-led PA operation. FEMA 

written approval will still be required in all instances where FEMA written approval would 

otherwise be required. More detailed information about the key functions can be found in 

Chapter 3: Public Assistance Operation Overview and information on the PA grant life cycle

in Appendix E: Public Assistance Grant Life Cycle.

 
State-Led Public Assistance Guide 

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Table 3: PA Grant Life Cycle Overview of Responsibilities and Corresponding Options 

KEY

Always FEMA, 

Recipient, or Applicant Always Shared Site Inspections Customer Service Scoping and Costing 

Step Owner or Key Function

Pre-Disaster Preparedness

a. Recipient Public Assistance Program Self-Assessment Recipient

b. Hazard Mitigation Plan Recipient

c. Recipient to Obtain System Access to Grants Manager Shared

d. Pre-Load Applicant Profiles into Grants Portal/Manager Shared

e. Training Shared

Pre-Declaration Coordination

a. Payment Management System Account Recipient 

b. Joint Preliminary Damage Assessment (PDA) Shared

c. Request for Presidential Disaster Declaration Recipient

d. Prepare Application for Federal Assistance 

(SF-424,424D) Recipient

Phase I: Operational Planning

a. Presidential Disaster Declaration FEMA

b. FEMA-State Agreement (FSA) Shared

c. Structured Dialogue for State-Led PA Shared

d. State Administrative Plan Amendment Recipient 

e. Submit Application for Federal Assistance 

(SF-424,424D) Recipient

f. Disaster Operating Profile and Overview Briefing Customer Service 

g. State-Led PA Operational Agreement Shared

h. PA Management Plan FEMA or Recipient

i. Applicant Briefing Recipient

j. Assess Applicant Eligibility* Customer Service 

k. Assignment of Program Delivery Managers (PDMG) to 

Applicants Customer Service

l. Exploratory Call Customer Service

m. Initial Damage Inventory Customer Service

n. Recovery Scoping Meeting (RSM) Customer Service

Phase II: Damage Intake and Eligibility Analysis

a. Assess Facility Eligibility (Recommendation) Customer Service 

b. Group Damage into Projects Customer Service

c. Request Documentation Customer Service

d. Submit Site Inspection Work Order Request(s) Customer Service

e. Assign Site Inspector Site Inspections 

f. Conduct Site Inspection Site Inspections

g. Review Site Inspection Report (SIR) and Damage 

Description and Dimensions (DDD) Customer Service
State-Led Public Assistance Guide 

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KEY

Always FEMA, 

Recipient, or Applicant Always Shared Site Inspections Customer Service Scoping and Costing 

Step Owner or Key Function

h. Review Applicant Request for Documentation 

Responses Customer Service 

i. Assess Work Eligibility (Recommendation) Customer Service

j. Applicant Reviews and Signs DDD Customer Service

k. Complete Development Guide Questions Customer Service

l. Submit Project to Consolidated Resource Center (CRC) Customer Service

Phase III: Scoping and Costing

a. Assign CRC Specialists FEMA

b. Develop or Validate Scope of Work (SOW) and Cost Scoping and Costing 

c. Draft 406 Hazard Mitigation Proposal Scoping and Costing 

d. Environmental Planning and Historic Preservation 

(EHP), Insurance, and Mitigation Scoping and Costing

e. Peer Review FEMA

f. Determine Work and Cost for Eligibility FEMA

g. Program Compliance Evaluations FEMA

Phase IV: Obligation

a. PDMG Review Customer Service

b. FEMA Final Review FEMA

c. Recipient Review Recipient

d. Applicant Review Applicant

e. FEMA Obligates Funding to Recipient Shared

f. Pass-through Funds to Subrecipient Recipient

g. Recovery Transition Meeting Customer Service

Post-Award Grant Administration

a. Monitoring Work Performed Under the SOW Recipient

b. Quarterly Progress Reports and Financial Status 

Reports Recipient

c. Appeals Shared

d. Audits Shared

Grant Closeout

a. Initiate Project Closeout Recipient

b. Initiate Subrecipient Closeout Recipient

c. Project and Subrecipient Closeout Shared

d. Disaster Closeout FEMA

*FEMA must assess and review the eligibility of all private nonprofit (PNP) Applicants.
State-Led Public Assistance Guide 

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Operational Agreement 

When FEMA and the Recipient agree that stateled PA is appropriate, the Recipient will then 

choose, in consultation with FEMA, which stateled PA option(s) the Recipient intends to lead, 

as previously described. This decision will be 

based on an assessment of the Recipient's 

current capacity, disaster characteristics, and 

other relevant disaster-specific circumstances, 

as further described in Chapter 5: DecisionMaking Considerations.

The Recipient will submit an Operational 

Agreement that documents its intent to lead PA 

operations, identifies which state-led PA 

option(s) the Recipient and FEMA agreed is 

appropriate, and acknowledges the Recipient’s 

understanding of the requirements they are 

responsible for based on the option(s) selected.

The Recipient should submit this Operational 

Agreement as an addendum to the FSA no later 

than 72 hours after the FSA has been 

executed. A Recipient's request to lead a PA 

operation and its subsequent submission of the Operational Agreement beyond the 72-hour 

timeframe may be approved at the RA's discretion. An Operational Agreement Template is 

available in Appendix D: Operational Agreement Template.

Public Assistance Management Plan 

The PA Management Plan is the primary framework that a Recipient uses to guide its stateled PA operation. Once FEMA and the Recipient have agreed upon which state-led PA 

option(s) the Recipient will lead, the management details of the state-led PA operation will 

be described in the PA Management Plan. The initial version of the plan is due 30 days after 

the Operational Agreement but is intended to be a living document that is updated 

throughout the PA grant life cycle. This plan will encompass the distribution of 

responsibilities, the staffing plan, the reporting requirements, the timeline for completion, 

and the metrics to assess program performance.

Table 4 provides a summary of the sections in the PA Management Plan. The template for 

the plan can be found in the Grants Manager.

State Administrative Plan: A deliberate plan 

that describes how the Recipient intends to 

administer the PA Program. Recipients must 

submit their Administrative Plans to the 

FEMA Regional Office on an annual basis 

and submit an amendment for each 

incident that occurs within the year to 

address specifics of the new incident.

Operational Agreement: A signed agreement 

that denotes the Recipient’s intent to 

pursue a state-led PA operation and the 

division of key functions as a result of 

FEMA-Recipient dialogue. The agreement is 

submitted 72 hours after the FEMA-State 

Agreement (FSA) is signed as an addendum 

to the FSA. 

PA Management Plan: An incident-specific 

plan that provides details of the PA 

operation including points of contact, 

distinct functions the Recipient and FEMA 

are performing based on the state-led PA 

option(s), staffing plan, and progress in 

relation to established milestones. 
State-Led Public Assistance Guide 

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Table 4: Summary of PA Management Plan 

Section Description

Record 

Management 

Provides a change log to help track version history of the PA Management 

Plan for a given disaster.

Situation

Provides basic information of the event and its background information. It 

also provides specific information about the declaration and the results of 

the Preliminary Damage Assessment (PDA).

Program 

Administration

Describes the components and processes of the state-led PA operation.

Staff Management

Discusses organizing resources, training, overtime and holidays, 

management of travel costs, performance evaluations, and personnel 

issues.

Recovery Process

Describes the function of the PA Program from initiation through closeout

and identifies goals that define success for program operation and 

completion.

Special 

Considerations 

Describes special consideration issues applicable to the disaster (e.g., 

insurance, mitigation, Environmental Planning and Historic Preservation 

[EHP]). Special issues may exist depending on the disaster-specific 

damages and the location and conditions of the disaster area.

Key Issues and 

Resolution 

Describes key issues specific to the disaster and identifies procedures for 

reaching resolution. Some of the most common key issues involve disasterspecific eligibility, debris removal, flood control facilities, private nonprofit 

eligibility, and cost estimating.

Transition and 

Closeout 

Provides the procedures for the transition of the state-led PA Operation 

from the field to the Recipient or region office. Coordination of this 

transition should occur with the region.

Remedial Action 

Management 

Program 

Describes requirements for preparing the Remedial Action Management 

Program (RAMP) report. The RAMP Report serves as a tool for the Regional 

Office to evaluate the success of the state-led PA Operation and to improve 

future operations.

Attachments 

Includes attachments to the plan, such as Applicant-required 

documentation, organization charts, PDAs, etc. 

Approval and 

Distribution 

Signatures from FEMA Regional PA Leadership and State Public Assistance 

Officer (PAO).

.
State-Led Public Assistance Guide 

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CHAPTER 5: DECISION-MAKING CONSIDERATIONS 

This chapter highlights some of the key 

decision-making factors for a Recipient and 

FEMA to consider when determining

whether and how to pursue a state-led PA 

operation. This decision is unique for each 

presidential disaster declaration but will 

follow a structured process based on the 

Recipient’s assessment of key 

considerations of disaster complexity and 

Recipient capacity. A Recipient’s decision 

to pursue a state-led PA operation, 

including a specific option(s) selected, will 

affect neither federal funding levels nor the 

decision to issue a presidential disaster 

declaration.

FEMA will provide oversight throughout the

PA grant life cycle as the accountable federal agency for PA grant funding. FEMA or the 

Recipient may adjust the planned distribution of responsibilities, as needed, to account for 

changing requirements.

Joint Decision-Making Timeline 

The FEMA RA or his/her designee and the Recipient will begin a joint decision-making 

dialogue on the state-led PA option(s) after the Recipient requests a presidential disaster 

declaration. FEMA and the Recipient will discuss whether a state-led PA operation is 

appropriate given the Recipient’s current capacity. These discussions can also begin before 

a disaster when the Recipient is assessing its capability to lead a future PA operation.

As described in Chapter 4: State-Led Public Assistance Operating Concept, if FEMA and the 

Recipient agree that a state-led PA operation is appropriate, the Recipient will then decide

which state-led PA option(s) it intends to lead. This decision will be based on the Recipient’s 

assessment of its current capacity, disaster characteristics, and other relevant disasterspecific circumstances. The Recipient should document the selected state-led PA option(s) 

in the Operational Agreement as an addendum to the FSA. Details for how the state-led PA 

operation will be implemented will be expanded upon in the PA Management Plan, which is 

due 30 days after the Operational Agreement.

Successful Recipient Characteristics 

As stated in FRN 66 FR 36783, Recipients 

that display the following characteristics are 

the best candidates for state-led PA 

operations:

 Recent disaster experience;

 Adequate Recipient staff or staff 

augmentation mechanism;

 A fiscal accounting system that can 

track specific projects, withstand audit, 

and be used to evaluate appeals; and

 Established record of meeting 

deadlines for grant management 

activities, including PA grants.
State-Led Public Assistance Guide 

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Figure 3 provides a general guideline of milestones, a timeline, and necessary tasks for the 

Recipient to initiate state-led PA operations.

Figure 3: Timeline for Initial Decision Making 

Considerations for Selecting State-Led Public Assistance 

The Recipient and FEMA will examine key considerations about the feasibility of 

implementing state-led PA. These considerations fall into two categories: the Recipient’s 

capacity at the time of the disaster and disaster-specific characteristics. These 

considerations may help the Recipient and FEMA determine the appropriate option(s) the 

Recipient will select and how that option(s) should be implemented for a specific disaster.

Recipient Capacity 

A Recipient’s ability to lead PA grant administration and management activities at the time 

of a specific disaster is likely the most important decision-making factor. Because of the 

disaster-specific nature of the potential variables that could affect Recipient capacity, FEMA 

and the Recipient should use a common basis of considerations to help structure their

dialogue. A structured approach to these discussions will establish consistency in how FEMA 

and Recipients discuss the potential decision to pursue a state-led PA operation across 

different FEMA regions.

Table 5 identifies common Recipient capacity considerations. These questions provide a 

common structure to the discussion between a Recipient and FEMA on the feasibility of 

state-led PA for a given incident and to assist with selecting the appropriate state-led 

option(s). They are not meant to be prerequisites to state-led PA.

Table 5: Current Recipient Post-Disaster Capacity Considerations 

Key Questions 

Viable Staffing Plan and Current Staffing Level

Are the current levels of staffing adequate?

Is there a staffing plan identified to handle an increased workload?

How will the Recipient train new staff or augmentees while initiating program delivery?

Discuss Capacity for State-Led Public Assistance

Incident Declaration 

Request

Declaration 

Issued

Application 

for Federal 

Assistance 

(SF-424)

Applicant 

Briefing

State-Led PA 

Operational 

Agreement 

Requests for 

Public 

Assistance 

(RPA)

Steady-State 

Discussion 

on Capability

State-Led Management 

Plan

30 days after 

incident

30 days after 

declaration

As soon as 

possible 

following the 

declaration

72 hours 

after FSA is 

signed 

30 days after 

declaration Pre-incident Incident 

30 days after 

Operational 

Agreement

KEY

State-Led PA Milestone Standard Milestone Incident Timeline 
State-Led Public Assistance Guide 

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Key Questions 

Experience with Public Assistance (PA)

Is there a state-funded Public Assistance (PA) program or equivalent?

Has there been previous participation in a state-led PA operation?

Is there experience partnering with FEMA to provide state personnel for roles such as the Program Delivery 

Manager or Site Inspector?

Is there a demonstrated commitment to or history of PA training?

Is there history using alternative procedures for permanent work?

Environmental Planning and Historic Preservation (EHP) Experience 

Does the Recipient have experience integrating EHP into project development?

Has the Recipient appointed an EHP point of contact who will collaborate with the FEMA Regional 

Environmental Officer and/or FEMA EHP staff?

Disaster Characteristics 

Characteristics for the specific disaster will also inform Recipient and FEMA decision

making. Many of these characteristics will have already been identified during the PDA 

process, making PDAs an important resource for Recipients and FEMA to incorporate into 

the broader dialogue and decision-making process to pursue a state-led PA operation. As 

such, accurate PDA information is critical to generating an informed decision between the 

Recipient and FEMA.

Table 6 identifies disaster characteristics and key questions to help guide the dialogue

between a Recipient and FEMA on the potential for state-led PA.

Table 6: Disaster Characteristic Considerations 

Key Questions 

Applicant Characteristics

According to the Preliminary Damage Assessment (PDA), how many Applicants are there? 

What type of Applicant(s)?

Categories of Work 

According to the PDA, which categories of work (e.g., C to G or A and B) will need to be completed?

Size of Disaster

According to the PDA, where is the highest concentration of damage?

How many damaged sites are there?

Geographical Context (State-Specific)

Is the disaster spread over a large area of the state?

Are there remote access issues or long travel requirements that may complicate logistical coordination?

Does the impacted area(s) affect a large percentage of the population?

Considerations for Recipient Staffing Capacity at the Time of a Disaster

Are there other incident operations currently ongoing?

Are there presidentially declared disasters pending closeout?

Can Recipient staff handle an increased workload at this time? If not, is the Recipient able to augment 

staffing?

Are key personnel expected to be unavailable during this disaster?
State-Led Public Assistance Guide 

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Key Questions 

Does the Recipient have additional staffing that will be available post-declaration to perform program 

delivery roles and responsibilities, and, if so, when will they be available?

Disaster Complexity 

What is the nature and type of the disaster?

Do the characteristics of the debris (quantity, type, and location) require specialized assistance or expertise?

Are there rural electric cooperatives that will be involved?

What is the extent of the damage to the power grid, and what special issues may arise in the repair and 

restoration of electricity in the disaster area?

What other federal agencies are involved in disaster operations, and what is their role?

Will projects require a complex Environmental Planning and Historic Preservation (EHP) compliance project 

(e.g., endangered species, essential fish habitat, historic resources, work in water and/or the coastal zone, 

and coastal barrier area)?

Will projects require the specialized lane at the Consolidated Resource Center (CRC)? If so, how many, what 

type, and what are the technical requirements needed to assess or evaluate these projects?

Are damaged facilities of high importance or significance to the community?

What are the political considerations?

Modifying Implementation of State-Led Public Assistance

If a Recipient or FEMA determines there is a need for increased FEMA involvement in an 

ongoing state-led PA operation, both parties will coordinate to determine how to fill identified 

needs. This adjustment can be because of many factors, including subsequent 

events/disasters, unforeseen complexities, or a change in circumstances that hinder the 

Recipient’s capacity. Such modifications will be documented in the FSA as an amendment to 

the Operational Agreement or the PA Management Plan.

The PA Management Plan will clearly state the timeline and metrics for successful 

completion of a state-led PA operation, consistent with the same measures FEMA takes to 

monitor PA operations nationwide. If the FCO or other FEMA official determines that the 

Recipient is no longer able to perform the duties as outlined, FEMA reserves the authority to 

step in and manage some or all aspects of the PA operation. Conversely, the Recipient can 

request to assume responsibility of additional tasks or increase its role in shared tasks or 

request FEMA increase its support if conditions warrant such a change.

The Recipient and FEMA will clearly document modifications in updated Operational 

Agreements and in state-led PA Management Plan amendments (if needed). FEMA’s Office 

of Chief Counsel (OCC) will determine when the modification is significant enough to warrant 

an amendment to the FSA or Operational Agreement. The PA Management Plan is a living 

document and should evolve with the state-led PA operation, documenting all adjustments 

to the planned approach as they arise.
State-Led Public Assistance Guide 

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CHAPTER 6: PLANNING FOR STATE-LED PUBLIC 

ASSISTANCE 

This chapter presents general guidance for Recipients to prepare, train, and plan for leading 

state-led PA operations. Recipients who opt into state-led PA may benefit from resources 

and support from experienced personnel in efforts to build capacity and capability. FEMA 

and mutual aid partners in other states can share resources and training opportunities to 

build and improve Recipient capability to support a state-led PA operation. Guidance in this 

chapter includes the following:

 Pre-disaster preparedness,

 Staffing augmentation mechanisms,

 Training and assistance, and

 Accountability.

Pre-Disaster Preparedness 

When conducting pre-disaster preparedness activities in steady-state, RAs and Regional 

Recovery Directors reach out to their respective potential Recipients to discuss their interest 

in potentially pursuing one or more state-led PA options. This discussion can help the 

Recipient and FEMA regions think through when a state-led PA operation might be 

appropriate and how to operationalize the concepts laid out in this guidance. Table 7

provides a list of potential topics to cover during pre-disaster preparedness discussions.

Table 7: Potential Topics for Pre-Disaster Preparedness Discussions 

Topic Outcome 

Mutual 

Understanding 

General shared understanding between the FEMA region and the Recipient on 

what roles or option(s) the Recipient has the capability and interest to 

potentially perform during a future state-led PA operation. This understanding 

should also include the types of incidents in which the Recipient would be more 

receptive to pursuing a state-led PA operation.

Training 

Recipient understands what training is required for the roles it might perform 

during a state-led PA operation, as well as how to access related training 

resources.

Systems Access 

Recipient has identified staff that would likely require systems access during a 

state-led PA operation. FEMA coordinates internally to initiate the process (i.e.,

background investigation) needed to approve systems access.

Notional 

Staffing Plan 

Recipient and the FEMA region collaboratively identify the resources and 

staffing mechanisms the Recipient would mobilize to support the option(s) it 

has expressed an interest in. Additionally, the Recipient, with support from the 

FEMA region, may begin developing a notional staffing plan.
State-Led Public Assistance Guide 

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Topic Outcome 

Mitigation 

Recipient and FEMA discuss previous experience integrating 404 funding with 

406 funding. Discussions should include potential approaches to combine 

funding from PA and Hazard Mitigation grants to meet Recipient objectives to 

mitigate losses in future disasters. The Recipient should evaluate whether it 

has an enhanced mitigation plan or the feasibility of creating one. 

Staffing Augmentation Mechanisms

Developing and maintaining qualified staff has historically been one of the principal 

challenges in conducting state-led PA operations. This section relies on state-level 

experiences to identify examples of staff augmentation methods and best practices to help 

Recipients conduct a state-led PA operation. Each Recipient has its own disaster 

requirements and state legal authorities; therefore, the following information offers potential 

examples Recipients may adapt to meet their own needs and circumstances.

Reservist Program

Some Recipients have developed disaster reservist programs to support PA grant 

implementation activities. These reservists specialize in PA, are employees of the Recipient, 

and are typically classified as part-time, on-call as needed and do not have a guarantee or 

cap on hours. This allows the Recipient to have a trained workforce at hand with flexibility to 

surge staffing, as needed, scaling support to match the needs of applicable presidential 

disaster declarations while minimizing risks and additional costs of maintaining a larger 

permanent workforce. To keep reservists up to date on current practices, Recipients can

provide them with training courses and other resources offered by FEMA (see Appendix F: 

Resource Toolkit).

Emergency Management Assistance Compact (EMAC) 

EMAC is another avenue for temporarily augmenting staff. Recipients can use EMAC to 

request PA-specific expertise from other states or loan out their own staff to sharpen their 

skills and gain experience in administering PA grants. Through EMAC, state agents can gain 

experience when other states need assistance with site inspections, project development, or 

other aspects of the PA Program. Assisting states benefit from fulfilling EMAC requests by 

providing their staff with more opportunities and experience in state-led PA operations. The 

requesting state benefits from EMAC deployments by conserving resources to support a 

smaller cadre of on-call personnel while relying on mutual aid to surge adequate staffing 

when needed.

Requesting and assisting states will follow the standard EMAC processes for requesting and 

offering assistance; mobilizing, deploying, or demobilizing personnel; and applying for 

reimbursement. The requesting state is generally eligible for FEMA reimbursement, 
State-Led Public Assistance Guide 

29

assuming it has the proper documentation. For more information about EMAC, please refer 

to Public Law 104-321.

Contract Support 

Recipients may choose to hire contractors to assist with various aspects of a state-led PA 

operation. One example of contract support is through pre-bid contracts that may 

supplement or perform similar functions to a Recipient-level reservist program. Recipients 

may procure other contract support to help manage and operate the electronic systems 

used in the PA grant delivery process, such as Grants Manager and Grants Portal.

Training and Assistance 

FEMA is available to offer advice and resources to help Recipients as they lead PA grant 

delivery, including training delivery and mentorship. FEMA may mobilize its resources and 

staff to augment Recipient needs for each disaster or in coordinating pre-disaster 

preparedness activities.

Training Availability

FEMA offers a range of training resources and guidance documents to help Recipients gain 

the knowledge and skills necessary to lead and conduct PA operations, including EHP 

training. Appendix F: Resource Toolkit identifies a more detailed list of resources available to 

support Recipients in implementing or building capacity for a state-led PA operation. Many of 

these resources are also accessible via the Grants Manager or Grants Portal.

Requesting Training and Assistance 

Recipients may request in-person training and assistance to better understand and perform 

their potential roles and responsibilities under state-led PA operations. Recipients may 

request training and assistance during pre-disaster preparedness or once a presidential 

disaster declaration has been issued. Recipients should contact their Regional PA Branch 

Chief or designated PA official with questions related to training or FEMA resources. FEMA is

also available to assist with eligibility, staff organization, and federal grant compliance 

requirements.

Mentorship 

Recipients may consider adopting a formal or informal mentorship program that pairs 

seasoned staff with incoming staff, encouraging veteran employees to train and share their 

experience with those less familiar with the PA Program and processes. The mentor can 

observe mentees in the field and report progress to supervisors to measure and improve job 

performance. Recipients could identify mentors within their emergency management agency

or request mentors from FEMA or other states.
State-Led Public Assistance Guide 

30

Accountability 

Ultimately, FEMA, the Recipient, and the Subrecipient are accountable to uphold federal 

regulations and report to oversight authorities. The Recipient and FEMA should regularly 

share information regarding the implementation of state-led PA throughout the full grant life 

cycle using the Grants Manager electronic system and other required reporting mechanisms.

Transparency 

Electronic systems such as the Grants Portal and Grants Manager provide transparency 

across all levels of government (Subrecipients, Recipients, and FEMA) to help ensure 

Subrecipients have a consistent customer service experience, receive the PA grant funding 

for which they are eligible, and have access to the resources they need to recover from 

disasters. FEMA is working to increase the functionality and access to the Grants Portal and 

Grants Manager to improve the ease of use for these systems to support state-led PA 

operations.

Procurement 

In a state-led PA operation, Recipients must comply with the procurement standards of the 

government-wide Uniform Administrative Requirements, Cost Principles, and Audit 

Requirements for Federal Awards (“Uniform Rules”) of 2 CFR, Part 200, as adopted by the 

Department of Homeland Security at 2 CFR, Part 3002. As the federal awarding agency, 

FEMA is responsible for monitoring financial assistance execution and ensuring proper 

performance under the FEMA award, including compliance with procurement standards. 

FEMA may, in exercising this responsibility, conduct pre- and post-procurement reviews of 

the Recipient’s procurements consistent with the terms of 2 CFR, § 200.317-200.326.
State-Led Public Assistance Guide

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APPENDIX A: ACRONYM LIST 

CFR Code of Federal Regulations

CRC Consolidated Resource Center

DDD Damage Description and Dimensions

DRM Disaster Recovery Manager

EEI Essential Element of Information

EHP Environmental Planning and Historic Preservation

EMAC Emergency Management Assistance Compact 

EO Executive Order

FCO Federal Coordinating Officer

FEMA Federal Emergency Management Agency

FRN Federal Register Notice

FSA FEMA-State Agreement 

GAR Governor's Authorized Representative 

HQ Headquarters

IMSK Incident Management and Support Keystone

JFO Joint Field Office

NDRF National Disaster Recovery Framework

NIMS National Incident Management System

NISM National Incident Support Manual

NQS National Qualification System

NRF National Response Framework

OCC Office of Chief Counsel 

OPPA Office of Policy and Program Analysis
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ORR Office of Response and Recovery

PA Public Assistance

PAGS Public Assistance Group Supervisor 

PAO Public Assistance Officer

PAPPG Public Assistance Program and Policy Guide 

PD TFL Program Delivery Task Force Leader 

PDA Preliminary Damage Assessment

PDMG Program Delivery Manager

PNP Private Nonprofit

RA Regional Administrator

RAD Recovery Analytics Division 

RAMP Remedial Action Management Program

REO Regional Environmental Officer

RFI Request for Information

RISM Regional Incident Support Manual 

RPA Request for Public Assistance

RRCS Regional Response Coordination Staff

RSM Recovery Scoping Meeting

SCO State Coordinating Officer

SF Standard Form

SI Site Inspector

SI TFL Site Inspector Task Force Leader

SIR Site Inspection Report

SOW Scope of Work

TFL Task Force Lead
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UCG Unified Coordination Group

U.S.C. United States Code
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State-Led Public Assistance Guide 

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APPENDIX B: GLOSSARY 

Applicant. A non-federal entity submitting an application for assistance under the Recipient’s 

federal award. 

Environmental Planning and Historic Preservation (EHP) Staff. Provides technical assistance 

to the state, tribe, and local programs to ensure compliance with EHP laws, regulations, 

statutes, and Executive orders and, when necessary, in submitting or preparing 

documentation to demonstrate EHP compliance.

Federal Coordinating Officer (FCO). The FCO is responsible for the overall management of 

the federal response, short-term and intermediate recovery, and mitigation activities for the 

incident. The President signs a letter assigning the FCO. The Regional Administrator (RA) 

then delegates Disaster Recovery Manager (DRM) authority and responsibilities to the FCO. 

When the FCO is the only federal member of the Unified Coordination Group (UCG), the FCO 

has directive authority over all federal resources assigned. In situations when other federal 

UCG members are present, they retain directive authority over their assigned resources.

Grant Closeout. The status of a grant for which FEMA has determined that the Recipient and 

Subrecipient(s) have completed all required grant work and FEMA has completed all 

applicable administrative actions related to the PA Program.

Grants Manager. The Grants Manager is one of the FEMA electronic systems used to 

manage PA grants. The system establishes a collaborative workspace for management 

personnel to interact with Subrecipients and review, adjudicate, and approve Public 

Assistance (PA) projects.

Grants Portal. The Grants Portal is another FEMA electronic system used for grant 

management and delivery. The Grants Portal streamlines the PA process and facilitates 

collaboration among FEMA, the Recipient, and the Subrecipient. The Grants Portal affords 

full project transparency for the Subrecipient by allowing all parties to upload work and 

documentation. 

Joint Field Office (JFO). The primary federal incident management field facility. The JFO is a 

temporary federal facility that provides a central location for the coordination of federal, 

state, tribal, and local governments and private-sector and nongovernmental organizations 

with primary responsibility for response and recovery. When not physically present at the 

disaster site, virtual JFO staff offer guidance and coordination assistance to personnel on 

the ground assisting with the PA operation as recovery efforts.

Mitigation. Activities providing a critical foundation in the effort to reduce the loss of life and 

property from natural and man-made disasters by avoiding or lessening the impact of a 

disaster and providing value to the public by creating safer communities. Mitigation seeks to 
State-Led Public Assistance Guide 

B-2

fix the cycle of disaster damage, reconstruction, and repeated damage. These activities or 

actions, in most cases, will have a long-term, sustained effect.

Operational Agreement. This document denotes the Recipient’s intent to pursue a state-led 

PA operation and the division of key functions as a result of FEMA-Recipient dialogue. The 

document is submitted 72 hours after the FEMA-State Agreement (FSA) is signed as an 

addendum to the FSA.

Preliminary Damage Assessment (PDA). A survey conducted by a team of state and federal

officials with the Applicant to estimate the extent of the disaster and its impact on 

individuals and public facilities. The team’s work begins with reviewing the types of damage 

or emergency costs incurred by the units of government and the impact to critical facilities, 

such as public utilities, individuals, and businesses. This assessment includes the number 

of damaged facilities, the number of people displaced, and the threat to health and safety 

caused by the storm event.

Public Assistance (PA). PA provides federal disaster grants from the President’s Disaster 

Relief Fund to eligible state, tribal, and local governments, as well as certain nonprofit 

organizations, for the repair, replacement, or restoration of publicly owned facilities and 

infrastructure damaged by the disaster.

Public Assistance (PA) Management Plan. The PA Management Plan describes the 

management details of the state-led PA operation and selected options. This plan will 

encompass the distribution of responsibilities, as well as the reporting structure, timeline for 

completion, and metrics the Recipient will be assessed on for program performance. 

Recipient. The Recipient is the state, tribal, or territorial government to which the grant is 

awarded. The Recipient is accountable for the use of funds provided by FEMA and is 

responsible for disbursing those funds to the Subrecipient (Applicant). State and local 

governments are closest to those impacted by incidents and have always had the lead in 

response and recovery. During response, Recipients play a key role coordinating resources 

and capabilities throughout the state, territory, or tribal land and obtaining resources and 

capabilities from other states. States are sovereign entities, and the governor has 

responsibility for public safety and welfare. While U.S. territories, possessions, freely 

associated states, and tribal governments also have sovereign rights, there are unique 

factors involved in working with these entities.

Regional Administrator (RA). Primary FEMA representative to state governors, other federal 

departments and agencies, and local, tribal, and territorial authorities during day-to-day 

operations within the RA’s region. In the event of a Stafford Act declaration, the RA of the 

affected region has control of FEMA resources within the region. The RA delegates authority 

for incident management and control of assigned federal resources to the FCO when the 

FCO has established operational capability.
State-Led Public Assistance Guide 

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Regional Environmental Officer (REO). The REO serves as the Recipient’s main point of 

contact for EHP compliance at FEMA. In a state-led PA operation, the ultimate responsibility 

for all EHP compliance and Agency decisions remains with FEMA. Recipients can contact the 

REO with questions related to compliance with EHP laws and Executive orders.

State Coordinating Officer (SCO). The SCO is appointed by the governor to represent the 

state and act in cooperation with the FCO to administer incident management efforts. The 

SCO brings the governor’s priorities to the UCG and serves as the conduit for addressing the 

needs of the state. The relationship between the SCO and the FCO is always intended to be 

a partnership between federal and state authorities. The SCO and FCO work collaboratively 

to achieve unity of effort and create joint incident priorities, objectives, and strategies in 

accordance with the governor’s priorities.

State-led Public Assistance (PA) Operation. The delivery of PA to Applicants and 

Subrecipients when some responsibilities are led by the Recipient instead of FEMA. A stateled PA operation can occur during Level III incidents. In 2001, FRN 66 FR 36784 authorized 

Recipients to lead PA delivery for Level III, small-sized presidential disaster declarations.

State-led Public Assistance (PA) Options. Recipients choose one of six state-led PA options 

based on three key functions: customer service, site inspections, and scoping and costing. 

There are two levels, shared and plus, for each key function, totaling six options. For shared 

options, Recipients will lead all responsibilities for some projects, and for plus options, they 

will lead all responsibilities for all projects. In the plus options, Recipients may take on other 

advanced responsibilities such as EHP or spend plans. 

Structured Dialogue. FEMA and the Recipient discuss which tasks will be potentially led or 

co-led by the Recipient in the PA delivery operation. This only occurs if a Recipient is 

interested in potentially leading aspects of the PA operation.

Subgrant Closeout. The status of a subgrant for which FEMA has determined that the 

Recipient and the Subrecipient have certified that all projects (large and small) are 

100 percent complete and that the Recipient has performed a final reconciliation on large 

projects.

Subrecipient. A non-federal entity that receives a subaward from a pass-through entity to 

carry out part of a federal program. A Subrecipient does not include an individual who is a 

beneficiary of such program. A Subrecipient may also be a Recipient of other federal awards 

directly from a federal awarding agency.
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APPENDIX C: AUTHORITIES AND FOUNDATIONAL 

DOCUMENTS 

Public Law 93-288, as amended, Sections 5121-5207, 42 U.S.C., Robert T. Stafford 

Disaster Relief and Emergency Assistance Act (Stafford Act), 2018.

The Stafford Act authorizes the programs and processes by which the Federal Government 

provides disaster and emergency assistance to state and local governments, tribal nations, 

eligible private nonprofit organizations, and individuals affected by a declared major disaster 

or emergency. The Stafford Act covers all hazards, including natural disasters and terrorist 

events.

Title 2 of the Code of Federal Regulations (CFR), Part 200, Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal Awards.

This document provides guidance for non-federal entity recipients and Subrecipients of 

federal financial assistance awarded by FEMA when using that assistance to finance 

procurements of property and services. The guidance provided by this document only 

applies to federal financial assistance (e.g., grants and cooperative agreements) subject to 

the procurement standards of the government-wide Uniform Administrative Requirements, 

Cost Principles, and Audit Requirements for federal Awards.

Title 44 CFR, Emergency Management and Assistance. 

The CFR is a codification of the general and permanent rules and regulations published in 

the FEDERAL REGISTER that contain basic policies and procedures. Title 44 is entitled 

“Emergency Management and Assistance,” and Chapter 1 of Title 44 contains the 

regulations issued by FEMA, including those related to implementing the Stafford Act. 

Federal Register Notice (FRN), Volume 66, Number 135, FR Doc No. 01-17533, 

Documentation Citation, 66 FR 36783, Notice of the State Management of Public 

Assistance Operations in Small Disasters, 2001. 

FRN 66 FR 36783 gave notice that FEMA would devolve major management responsibility 

of the PA Program in small disasters to interested states with demonstrated capability. 

Interested tribal governments may also participate.
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FP 104-009-2, Public Assistance Program and Policy Guide (PAPPG).

The PAPPG combines all Public Assistance (PA) policy into a single volume and provides an 

overview of the PA Program implementation process with links to other publications and 

documents that provide additional process details.

National Incident Management System (NIMS), Third Edition, October 2017.

The NIMS is a set of principles that provides a systematic, proactive approach to guiding 

government agencies at all levels, NGOs, and the private sector to work seamlessly to 

prevent, protect against, respond to, recover from, and mitigate the effects of incidents—

regardless of cause, size, location, or complexity—in order to reduce the loss of life or 

property and harm to the environment.

National Response Framework (NRF), Third Edition, June 2016.

The NRF is a guide to how the Nation conducts an all-hazards response. The NRF is built 

upon scalable, flexible, and adaptable coordinating structures to align key roles and 

responsibilities across the Nation, linking all levels of government, NGOs, and the private 

sector. The NRF is intended to capture specific authorities and best practices for managing 

incidents that range from serious but purely local events to large-scale terrorist attacks or 

catastrophic natural disasters.

National Disaster Recovery Framework (NDRF), Second Edition, June 2016.

The NDRF is a guide that enables effective recovery support to disaster-impacted states, 

tribes, territories, and local jurisdictions. The NDRF provides a flexible structure that enables 

disaster recovery managers to operate in a unified and collaborative manner. The NDRF also 

focuses on how best to restore, redevelop, and revitalize the health, social, economic, 

natural, and environmental fabric of the community and build a more resilient nation.

National Mitigation Framework, Second Edition, June 2016.

The document provides context for how the whole community works together and how 

mitigation efforts relate to all other parts of national preparedness. The document is one of 

the five documents in a suite of National Planning Frameworks. Each framework covers one 

preparedness mission area: prevention, protection, mitigation, response, or recovery.

FEMA, Incident Management and Support Keystone (IMSK), January 2011.

This keystone is the primary document from which all other FEMA disaster response 

directives and policies are derived. This keystone describes how the Response Doctrine, 

articulated in the National Response Framework, is implemented in FEMA disaster response 

operations.
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FEMA, Regional Incident Support Manual (RISM), January 2013.

The RISM describes the organization, functions, and underlying doctrine of incident support 

activities at the regional level. The RISM explains how the Regional Response Coordination 

Staff (RRCS) supports incident operations and discusses steady-state activities pertinent to 

incident operations. Like the National Incident Support Manual (NISM), the RISM serves as 

the basis for developing guidance, including procedures, handbooks, incident guides, and 

training materials for FEMA incident support personnel. The RISM is also intended to inform 

FEMA’s partners regarding guidelines and requirements for incident support operations.

FEMA, National Incident Management System Guideline for the National Qualification 

System, November 2017.

This document describes the components of a qualification and certification system, defines 

a process for certifying the qualifications of incident personnel, describes how to stand up 

and implement a peer review process, and provides an introduction to the process of 

credentialing personnel.

FEMA Directive 108-1, Environmental Planning and Historic Preservation (EHP) 

Responsibilities and Program Requirements and Companion Instruction, August 2016.

The purpose of this EHP Directive is to establish FEMA policies, roles, responsibilities, and 

procedures for delegations of authority concerning EHP. Environmental stewardship, 

preservation of historic and cultural resources, and sustainability are complementary goals 

to the emergency management mission and activities of FEMA. FEMA promotes these goals 

to support development of resilient communities in light of disasters, sea level rise, climate 

change, and other impacts that threaten the human environment. Environmental, historic, 

and cultural resources are important considerations when preparing for, responding to, 

recovering from, and mitigating hazards to the United States.
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APPENDIX D: OPERATIONAL AGREEMENT 

TEMPLATE 

PUBLIC ASSISTANCE PROGRAMMATIC ADDENDUM 

SUBPART C: STATE-LED PUBLIC ASSISTANCE 

OPERATIONAL AGREEMENT

I. PURPOSE 

The purpose of this Operational Agreement (Agreement) between the Federal Emergency 

Management Agency (FEMA) and the State is to build a FEMA-State collaborative partnership 

in the implementation of State-Led Public Assistance (PA). This document defines the roles, 

responsibilities, procedures, and processes in effect under this Agreement.

Under this arrangement, the State will lead certain key functions of the Public Assistance 

operation, which are outlined in more detail below. FEMA will retain obligation authority, the 

final approval of environmental and historic preservation reviews, and will assist the State to 

the extent that such assistance is necessary and requested by the State. This arrangement 

should be cost effective, maintain a high level of customer service, and provide consistency 

within the State’s implementation of state-led Public Assistance. Both FEMA and the State 

agree to adhere to the provisions outlined in this Agreement.

II. APPLICABILITY 

A. This Agreement applies to the administration of the PA Program under disaster declaration 

FEMA-xxxx-DR-xx and is effective upon date of signature by both parties.

B. Under this Agreement, all applicable laws, Executive Orders, regulations, OMB Circulars 

and FEMA policies and guidance remain in effect.

C. The State or FEMA may request modifications to the Agreement at any time, which may 

include modifications to the options selected in Section B.2. Any amendments to the 

Agreement will be coordinated with FEMA’s Office of Chief Counsel. Both signatories must 

sign amendments to the Agreement. 

III. ROLES AND RESPONSIBILITIES 

This section outlines which key functions of PA Program delivery (Customer Service, Site 

Inspection, and/or Scoping and Costing) the State will assume, and to what degree. FEMA 

regional staff will provide technical assistance to the State, obligate funding to the State, and 

monitor program implementation after project approvals.
State-Led Public Assistance Guide 

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A. GENERAL 

1. The State will: 

a. Administer the Public Assistance Program consistent with applicable program laws, 

Executive Orders, regulations, OMB Circulars, and FEMA policies and guidance.

b. Ensure the State Administrative Plan is current and approved by the FEMA Regional 

Administrator [or designee]. Document in the Plan the processes to determine eligible 

applicants and projects, develop appropriate scopes of work, and assure sufficient 

documentation exists on the project to allow for program review or audit.

c. Maintain the technical capability necessary to meet its responsibilities under the 

Agreement. If, at any time, the State determines it requires additional technical capability, 

the State will request technical assistance from FEMA.

d. Provide FEMA any information requested to assist FEMA in carrying out its functions.

e. Utilize current electronic systems (e.g., Grants Manager and/or Grants Portal) to share 

information regarding the implementation of State-Led PA throughout the full grant 

lifecycle.

2. FEMA will: 

a. Ensure that the State administers the Public Assistance Program consistent with 

applicable program laws, Executive Orders, regulations, OMB Circulars, and FEMA policies 

and guidance, as well as all applicable environmental and historic preservation laws, 

policies, and guidance, through an on-going quality control review.

b. Provide technical assistance to the State, upon request and as appropriate.

c. Utilize current electronic systems (e.g., Grants Manager and/or Grants Portal) to share 

information regarding the implementation of State-Led PA throughout the full grant 

lifecycle.

B. PROGRAM DELIVERY 

Throughout the delivery of PA grants, FEMA and the State will coordinate to perform one 

or more key functions (customer service, site inspections, and scoping and costing) to 

formulate each subgrant or project. While each of these functions correspond to FEMA PA 

position titles such as the Program Delivery Manager (PDMG) or the Site Inspector (SI), 

the State has flexibility in deciding how to execute these key functions in accordance with 

the PA delivery model, pursuant to the Public Assistance Program and Policy Guide 

(PAPPG). Although separate lines of effort, personnel performing these key functions will 

coordinate with one another to ensure quality assurance.

 

 
State-Led Public Assistance Guide 

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1. For disaster declaration FEMA-xxxx-DR-xx, the State will: 

a. Work with FEMA to develop a PA Management Plan that includes a situation overview and 

the processes and procedures for record management; program administration; staff 

management; PA delivery process; quality assurance; special considerations (e.g., 

insurance, mitigation, environmental and historic preservation); key issues and resolution 

(e.g., disaster-specific eligibility, debris removal, flood control facilities, private nonprofit 

eligibility, and cost estimating); transition and closeout timeline; Remedial Action 

Management Program; and, performance metrics. This Plan will be signed by FEMA 

Regional PA Leadership and the State Public Assistance Officer [or authorized 

representative;

b. Conduct Applicant Briefings to provide high-level information regarding the PA Program;

c. Conduct Recipient reviews of completed projects and awards in Grants Portal;

d. Complete entry of all Version 0 Project Worksheets;

e. Pursue an active partnership with FEMA to coordinate the obligation of funds;

f. Pass-through funds to Subrecipient(s) when received from FEMA;

g. Utilize the current electronic system for PA grants management (e.g., Grants Portal and/or 

Grants Manager) for processing, tracking, and reporting of projects and Subrecipients;

h. Monitor grant funds and subaward-supported activities to ensure the grant activities are 

performed in accordance with the SOW; the activities are compliant with federal 

requirements and current codes, standards, and permitting requirements, in accordance 

with 44 C.F.R. § 206.226(b); and sufficient funds are available for closeout;

i. Afford FEMA the opportunity to perform environmental planning and historic preservation 

(EHP) reviews prior to the start of construction for any Permanent Work project. Proceeding 

with Permanent Work before FEMA completes EHP reviews will jeopardize PA funding;

j. Submit Quarterly Progress Reports and Financial Status Reports to FEMA;

k. Make recommendations on appeals and provide FEMA with any necessary 

documentation;

l. Respond to any requests for information related to audits and submit requested 

documentation to FEMA;

m. Initiate and work with FEMA on timely project closeout by: conducting final financial 

reconciliation; and, ensuring that all appeals have a final determination, all funds have 

been obligated, the project is complete, and the final expenditure report has been 

submitted.
State-Led Public Assistance Guide 

D-4

n. Initiate and work with FEMA on timely Subrecipient closeout by submitting a written 

closeout request for each Subrecipient once all the Subrecipient’s projects have been 

completed and closed for the disaster and submit a Project Completion and Certification 

Report (P.4 Form) to demonstrate that the Applicant is ready to close out its projects. 

2. In addition to the functions above, the State will assume key functions under the following 

option(s) for state-led PA, as outlined in the State-Led Public Assistance Guide [check one

or more]:

 Customer Service Shared or Customer Service Plus; and/or

 Under Customer Service Shared, the State will perform customer service 

functions for some Applicants/Subrecipients, while FEMA performs them for 

the remaining Applicants/Subrecipients. Applicants/Subrecipients will be 

assigned to the State or FEMA in the PA Management Plan.

 Under Customer Service Plus, the State will perform customer service 

functions for all Applicants/Subrecipients.

 Site Inspections Shared or Site Inspections Plus; and/or

 Under Site Inspections Shared, the State will perform the site inspection 

functions for some projects, while FEMA performs them for the remaining 

projects. Projects will be assigned to the State or FEMA in the PA 

Management Plan.

 Under Site Inspections Plus, the State will perform site inspection functions 

for all projects.

 Scoping and Costing Shared or Scoping and Costing Plus.

 Under Scoping and Costing Shared, the State will perform all scoping and 

costing functions for some projects, while FEMA performs them for the 

remaining projects. Projects will be assigned to the State or FEMA in the PA 

Management Plan.

 Under Scoping and Costing Plus, the State will perform all scoping and 

costing functions for all projects.

a. Under Customer Service Shared, for those Applicants/Subrecipients assigned to the State, 

the State will: 

i. Perform eligibility reviews and ensure that only eligible projects, based on Applicant, 

facility, work and cost, are funded per the Agreement. Make eligibility 

recommendations to FEMA;

ii. Assign Program Delivery Managers (or equivalent) to Applicants for PA grant 

development;
State-Led Public Assistance Guide 

D-5

iii. Conduct exploratory calls with Applicant representatives to obtain general information 

about the Applicant and its disaster impacts, explain next steps, including the Damage 

Inventory, discuss potential special considerations and eligibility issues, and schedule 

the Recovery Scoping Meeting (RSM).

iv. Work with Applicants to input an initial damage inventory into Grants Portal;

v. Conduct Recovery Scoping Meetings;

vi. Group damage into projects in Grants Manager;

vii. Send Essential Elements of Information (EEI) requests to Applicants; 

viii. Submit site inspection work order requests; 

ix. Review Site Inspection Report and Damage Description and Dimensions (DDD); 

x. Review Applicant EEI responses; 

xi. Coordinate Applicant review and signature of the DDD; 

xii. Complete Development Guide questions in Grants Manager; 

xiii. Submit Project to Consolidated Resource Center (CRC) via Grants Manager; 

xiv. Conduct Project Reviews before obligation; 

xv. Conduct Recovery Transition Meetings. 

b. Under Customer Service Plus, for all Applicants/Subrecipients, the State will: 

i. Perform eligibility reviews and ensure that only eligible projects, based on Applicant, 

facility, work and cost, are funded per the Agreement. Make eligibility 

recommendations to FEMA;

ii. Assign Program Delivery Managers (or equivalent) to Applicants for PA grant 

development;

iii. Conduct exploratory calls with Applicant representatives to obtain general information 

about the Applicant and its disaster impacts, explain next steps, including the Damage 

Inventory, discuss potential special considerations and eligibility issues, and schedule 

the Recovery Scoping Meeting (RSM).

iv. Work with Applicants to input an initial damage inventory into Grants Portal;

v. Conduct Recovery Scoping Meetings;

vi. Group damage into projects in Grants Manager;
State-Led Public Assistance Guide 

D-6

vii. Send Essential Elements of Information (EEI) requests to Applicants;

viii. Submit site inspection work order requests;

ix. Review Site Inspection Report and Damage Description and Dimensions (DDD);

x. Review Applicant EEI responses;

xi. Coordinate Applicant review and signature of the DDD;

xii. Complete Development Guide questions in Grants Manager;

xiii. Submit Project to Consolidated Resource Center (CRC) via Grants Manager;

xiv. Conduct Project Reviews before obligation;

xv. Conduct Recovery Transition Meetings.

c. Under Site Inspections Shared, for those projects assigned to the State, the State will: 

i. Assess the type of site inspection needed;

ii. Assign Site Inspectors (or equivalent) to projects;

iii. Conduct site inspections to Site Inspection Work Orders in Grants Manager;

iv. Assist Subrecipient in gathering required information and documentation, including for 

special considerations such as environmental planning and historic preservation 

(EHP), insurance, and mitigation, and review projects for completeness.

d. Under Site Inspections Plus, for all projects, the State will: 

i. Assess the type of site inspection needed;

ii. Assign Site Inspectors (or equivalent) to projects;

iii. Conduct site inspections to Site Inspection Work Orders in Grants Manager;

iv. Assist Subrecipients in gathering required information and documentation, including 

for special considerations such as environmental planning and historic preservation 

(EHP), insurance, and mitigation, and review projects for completeness.

e. Under Scoping and Costing Shared, for those projects assigned to the State, the State will: 

i. Develop Scope of Work (SOW) and costs;

ii. Draft or review Stafford Act Section 406 Hazard Mitigation Proposal for eligible 

facilities, if applicable.
State-Led Public Assistance Guide 

D-7

iii. Conduct initial environmental and historic preservation (EHP) compliance review.

f. Under Scoping and Costing Plus, for all projects, the State will: 

i. Develop Scope of Work (SOW) and costs;

ii. Draft or review Stafford Act Section 406 Hazard Mitigation Proposal for eligible 

facilities, if applicable.

iii. Conduct initial environmental and historic preservation (EHP) compliance review.

3. For disaster declaration FEMA-xxxx-DR-xx, FEMA will: 

a. Work with the State to develop a PA Management Plan that includes a situation overview 

and the processes and procedures for record management; program administration; staff 

management; PA delivery process; quality assurance; special considerations (e.g., 

insurance, mitigation, environmental and historic preservation); key issues and resolution 

(e.g., disaster-specific eligibility, debris removal, flood control facilities, private nonprofit 

eligibility, and cost estimating); transition and closeout; Remedial Action Management 

Program. This Plan will be signed by FEMA Regional PA Leadership and the State Public 

Assistance Officer [or authorized representative];

b. Review Project Worksheets for which the State is the Applicant;

c. Make all final facility and work eligibility determinations;

d. Validate Scope of Work (SOW) and costs;

e. Route projects and assign Consolidated Resource Center (CRC) staff;

f. Conduct Program compliance evaluations, including Quality Assurance Evaluation, 

Insurance and Mitigation Evaluations, Minimum Threshold Evaluations, and 

Environmental and Historic Preservation (EHP) Evaluations; 

g. Review all projects to ensure the work complies with applicable Federal environmental 

and historic preservation (EHP) laws and their implementing regulations, and applicable 

Executive Orders (EOs);

h. Conduct final reviews and obligate funding for eligible projects to the State utilizing the 

current electronic system (e.g., Grants Manager);

i. Publish all Public Assistance public notices; 

j. Review appeal documentation and recommendations from the State, and inform the State 

of the determination;
State-Led Public Assistance Guide 

D-8

k. Inform the State of changes to a project or to funding if any are required in a Corrective 

Action Plan following an audit;

l. Complete project closeout, Subrecipient closeout, and disaster closeout in a timely 

manner.

4. In addition to the functions above, FEMA will retain key functions based on the option(s) 

for State-Led PA selected above, as outlined in the State-Led Public Assistance Guide:

a. Under Customer Service Shared, for those Applicants/Subrecipients assigned to FEMA, 

FEMA will: 

i. Perform eligibility reviews and ensure that only eligible projects, based on Applicant, 

facility, work and cost, are funded per the Agreement. Make eligibility 

recommendations to FEMA;

ii. Assign Program Delivery Managers (or equivalent) to Applicants for PA grant 

development;

iii. Conduct exploratory calls with Applicant representatives to obtain general information 

about the Applicant and its disaster impacts, explain next steps, including the Damage 

Inventory, discuss potential special considerations and eligibility issues, and schedule 

the Recovery Scoping Meeting (RSM).

iv. Work with Applicants to input an initial damage inventory into Grants Portal;

v. Conduct Recovery Scoping Meetings;

vi. Group damage into projects in Grants Manager;

vii. Send Essential Elements of Information (EEI) requests to Applicants;

viii. Submit site inspection work order requests;

ix. Review Site Inspection Report and Damage Description and Dimensions (DDD);

x. Review Applicant EEI responses;

xi. Coordinate Applicant review and signature of the DDD;

xii. Complete Development Guide questions in Grants Manager;

xiii. Submit Project to Consolidated Resource Center (CRC) via Grants Manager;

xiv. Conduct Project Reviews before obligation;

xv. Conduct Recovery Transition Meetings.
State-Led Public Assistance Guide 

D-9

b. Under Site Inspections Shared, for those projects assigned to FEMA, FEMA will: 

i. Assess the type of site inspection needed;

ii. Assign Site Inspectors (or equivalent) to projects;

iii. Conduct site inspections to Site Inspection Work Orders in Grants Manager;

iv. Assist Subrecipients in gathering required information and documentation, including 

for special considerations such as environmental and historic preservation (EHP), 

insurance, and mitigation, and review projects for completeness.

c. Under Scoping and Costing Shared, for those projects assigned to FEMA, FEMA will: 

i. Develop and validate Scope of Work (SOW) and costs;

ii. Review Stafford Act Section 406 Hazard Mitigation proposals;

iii. Review all projects to ensure the work complies with applicable Federal environmental 

and historic preservation (EHP) laws and their implementing regulations, and 

applicable Executive Orders (EOs).

C. STATE MANAGEMENT COSTS 

The allowance to cover management costs for the State-Led PA operation will be in 

accordance Section 324 of the Stafford Act and applicable polices and guidance.

1. The State will: 

a. Identify staffing and other resource requirements necessary for budgeting and proper 

program management/implementation for the disaster in the State Administrative 

Plan.

2. FEMA will: 

a. Review and approve the State Administrative Plan during the scoping meeting to 

determine the eligible management costs.

b. Obligate eligible management costs based on the State Management Plan, in 

accordance with 2 C.F.R. §§ 327-328 and 44 C.F.R. §206.204(f).

D. DISPUTE RESOLUTION 

 

The State and FEMA will resolve any disputes in the interpretation of regulations, policy, and 

the implementation of the Public Assistance Program by designating one Public Assistance 

staff member from the State and one from FEMA to research the issue and present the 

findings to the Federal and State PA Group Supervisors who will make a joint determination.

If the dispute cannot be resolved, is highly sensitive or controversial, or if the funding level 

requires the Disaster Recovery Manager’s (DRM's) authority to obligate, the PA Group 
State-Led Public Assistance Guide 

D-10

Supervisors will present a recommendation to the Federal Coordinating Officer (FCO) for a 

final determination. The FCO’s decision does not waive the Applicant’s right to appeal.

IV. CONCURRENCE 

By their signatures below, the State and FEMA agree to abide by the terms of this agreement 

in the implementation of the Public Assistance Program for disaster declaration FEMA-xxxxDR-xx.

________________________________ _____________________________

[NAME] [NAME]

Governor’s Authorized Representative Regional Administrator [or designee]

[or designee]

[STATE] Emergency Management Agency FEMA Region [_]

Attachments

1. State Administration Plan

2. State Management Plan
State-Led Public Assistance Guide 

E-1

APPENDIX E: PUBLIC ASSISTANCE GRANT LIFE 

CYCLE 

This appendix places the unique activities needed to implement state-led PA in the context 

of the wider grant life cycle for an incident. Specifically, Tables 8 to 15 provide more detailed 

information on the PA grant life cycle, including describing processes, staff positions, and 

key steps FEMA currently uses to deliver PA grants for all incidents.

Recipients can refer to the detailed information in this appendix to customize their own 

implementation and staffing approaches when executing one or more of the state-led PA 

options described in Chapter 4: State-Led Public Assistance Operating Concept. Information 

in subsequent sections establishes common expectations of the functions that must be 

performed--either by Recipients or FEMA—to establish consistent implementation of the PA 

Program across all states and FEMA regions. Although Tables 8 to 15 identify FEMA-specific 

positions to provide greater context and consistent terminology, Recipients conducting a 

state-led PA operation have flexibility to align staffing approaches with their specific 

capabilities and resources.

Pre-Disaster Preparedness 

Prior to a disaster, Recipients may undertake several activities to better position themselves 

to conduct a state-led PA operation, including an analysis of their capacity and capability to 

manage aspects of the PA Program. FEMA regions will reach out to Recipients to gauge their 

interest in a state-led PA operation pre-disaster to discuss and plan for potential state-led PA 

operations if they are interested in participating in the program.

Table 8 shows pre-disaster activities Recipients can undertake to better prepare themselves 

to initiate and conduct a state-led PA operation.

Table 8: Pre-Disaster Preparedness Activities 

Step Description 

a. Recipient Public 

Assistance (PA) Program 

Self-Assessment 

Recipient assesses capability to manage aspects of the PA 

operation before a declaration and identifies conditions under 

which Recipient leadership may be interested in potentially 

pursuing a state-led operation.

b. Hazard Mitigation Plan 

Recipient submits a plan showing how it intends to reduce risks

from natural hazards, which must be approved by FEMA before

hazard mitigation funding is provided. Jurisdictions must update

these plans every 5 years to remain eligible for the Hazard

Mitigation Assistance programs.
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Step Description 

c. Recipient to Obtain 

Systems Access to Grants 

Manager 

Recipient ensures it has access to the Grants Manger and Grants 

Portal and its organizational profile is up to date. Recipient 

identifies likely personnel who will need access to the system for 

state-led PA operations. Recipient should request access through 

its respective FEMA region.

d. Pre-Load Applicant 

Organizational Profiles 

into Grants 

Portal/Manager 

Recipient or FEMA works with potential Applicants to create an 

organizational profile in the Grants Portal and Grants Manager.

e. Training 

Recipient conducts (or requests) training to perform the key 

functions of PA delivery: customer service, site inspections, and 

scoping and costing, as well as other supporting functions such 

as EHP compliance and Hazard Mitigation.

Pre-Declaration Coordination 

After a disaster but prior to a presidential disaster declaration being issued, Recipients 

assess the disaster impacts and magnitude of damage by completing initial damage 

assessments and requesting and completing a joint Preliminary Damage Assessment (PDA) 

with FEMA. The objective is to collect and prepare the information and documentation 

required to request a presidential disaster declaration and receive supplemental federal 

assistance.

Recipients may choose to review and update PA-related assessments after a presidential 

disaster declaration because Recipient capacity and capability can shift based on factors 

such as staffing, resources, number of disasters currently being managed, and frequency of 

disaster declarations. For more information about considerations for selecting state-led PA 

and disaster characteristics, see Chapter 5: Decision-Making Considerations.

Table 9 identifies responsibilities that a Recipient can undertake before a presidential 

disaster declaration.

Table 9: Pre-Declaration Coordination Responsibilities 

Step Description 

a. Payment Management 

System Account

Recipient creates a FEMA-specific SmartLink account by

submitting a Payment Management System Access Form and a

Direct Deposit Form (SF-1199A).

b. Joint Preliminary Damage 

Assessment (PDA) 

Recipient, FEMA, and local communities assess the disaster

impacts and magnitude of damage. Recipient and FEMA begin

discussion on potential applicability of state-led PA.

c. Request for Presidential 

Disaster Declaration 

Recipient submits request for a presidential disaster

declaration based on information collected from the PDA.
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Step Description 

d. Prepare Application for 

Federal Assistance 

(SF-424,424D) 

Recipient prepares Application for Federal Assistance (SF-424)

and Assurances for Construction Programs (SF-424D) for

submittal.

Pre-Award Program Delivery 

The purpose of this section is to establish a common terminology and understanding of the 

delivery model FEMA uses to implement the PA grant program. Recipients have flexibility in 

how they decide to staff these steps, depending on their resources and which state-led PA 

option(s) they select. These sections are meant to offer an example of how FEMA staffs each 

step of the PA delivery process.

Phase I: Operational Planning 

The objective of operational planning in PA delivery is to establish a foundation for applicantdriven, outcome-based recovery by identifying disaster impacts and priorities. Developing a 

customized Disaster Operating Profile effectively integrates FEMA and Recipient capabilities 

and necessary support functions to deliver the federal assistance grant program. In addition 

to the responsibilities identified in Table 10, Recipients will need to determine the necessary 

staffing requirements and identify resource needs to manage the PA Program that could be

met by the Recipient or FEMA personnel. During operational planning, Recipients and/or 

FEMA staff identify Subrecipients’ disaster impacts and recovery priorities and begin to 

address mitigation and EHP considerations with the Subrecipients.

Table 10 identifies the steps in operational planning that Recipients may undertake after a 

presidential disaster declaration to prepare for and select one or more state-led PA options.

Table 10: Operational Planning for PA Delivery 

Step Description 

a. Presidential Disaster 

Declaration 

President declares an emergency or major disaster Declaration 

which authorizes Public Assistance (PA).

b. FEMA-State Agreement 

(FSA) 

The governor and the FEMA Regional Administrator or designated 

representatives sign an agreement that states the 

understandings, commitments, and conditions for assistance 

under which FEMA disaster assistance shall be provided.

c. Structured Dialogue for 

State-Led PA 

Following approval of a presidential declaration authorizing PA,

FEMA and Recipient begin discussion on which state-led option(s)

is most appropriate based on disaster characteristics and the

Recipient’s capacity at the time of the disaster.

d. State Administrative Plan

Amendment 

Recipient submits an amendment (or new) State Administrative

Plan for a specific presidential disaster declaration.
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Step Description 

e. Submit Application for 

Federal Assistance 

(SF-424,424D) 

Recipient submits the Application for federal assistance once a

presidential disaster declaration has been issued.

f. Disaster Operating Profile 

and Overview Briefing

FEMA and/or Recipient develop the Disaster Operating Profile

based on the disaster’s PDA and historical known data. FEMA

and/or Recipient conduct(s) the Disaster Overview Briefing for

staff involved with the disaster.

g. State-Led PA Operational 

Agreement 

If state-led PA is agreed upon between FEMA and the Recipient,

the Operational Agreement outlining the roles and responsibilities

for the PA operation will be attached as an addendum within

72 hours of signing the FSA.

h. PA Management Plan 

The PA Management Plan identifies the roles and responsibilities,

processes, and procedures for administering the PA Program.

i. Applicant Briefing Recipient conducts briefing for potential Applicants to provide

high-level information regarding the PA Program.

j. Assess Applicant 

Eligibility 

Applicants submit Requests for Public Assistance (RPA) through 

the Grants Portal. Recipient reviews and makes eligibility 

recommendation to FEMA through the Grants Portal. Internally, 

FEMA’s Office of Chief Counsel reviews RPAs from private 

nonprofits. The PA Group Supervisor (PAGS) reviews the other

RPAs for Applicant eligibility. If an Applicant is not eligible, PAGS 

drafts determination memorandum and letter explaining why the 

Applicant is not eligible.

k. Assignment of Program 

Delivery Manager (PDMG) 

to Applicants 

PAGS or Program Delivery Task Force Lead (PD TFL) assigns 

PDMGs to eligible Applicants for PA grant development.

l. Exploratory Call 

PDMG conducts the Exploratory Call with Applicant

representative(s) to introduce the role of the PDMG and the

Applicant's role in the PA Program delivery process, understand

the Applicant's disaster-related damage and identify Applicant's

needs, explain the Damage Inventory, and schedule the Recovery

Scoping Meeting (RSM).

m. Initial Damage Inventory 

Prior to the RSM, the PDMG works with the Applicant to input an

initial Damage Inventory into the Grants Portal.

n. Recovery Scoping 

Meeting (RSM) 

The RSM represents the first substantive meeting between the

PDMG and the Applicant and starts the 60-day regulatory

timeframe for the Applicant to identify and report damage. The

meeting covers an in-depth discussion about the Applicant’s

damage claims, the supporting documentation needed, and the

plan for site inspections and establishes the Applicant’s

priorities.
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Step Description 

For all options, FEMA will issue the Determination Memorandum and Letter. If the Recipient is performing

customer service functions, the Recipient may draft the Determination Memorandum and Letter for FEMA to

review, approve, and send to the Applicant.

Phase II: Intake Damage and Eligibility Analysis 

After the Operational Planning phase, Recipients and FEMA conduct site inspections and

collect documentation from Applicants. The objective of Phase II is to capture Applicants' 

disaster-related damage and determine eligibility within 60 days of the Recovery Scoping 

Meeting (RSM). Table 11 shows the responsibilities involved with Phase II in PA delivery, 

many of which would be managed by Recipients who choose the site inspections option(s).

Table 11: Intake Damage and Eligibility Analysis for PA Grants 

Step Description 

a. Assess Facility Eligibility 

Program Delivery Manager (PDMG) assesses the eligibility of 

facilities on the Damage Inventory and discusses potential 

eligibility issues with the Public Assistance (PA) Group Supervisor 

(PAGS) to confirm eligibility recommendation. If a facility is found 

to be ineligible for PA, a Determination Memorandum will be 

issued with an explanation.

b. Group Damage 

into Projects 

PDMG groups damages in the Damage Inventory into projects in 

the Grants Manager. Each project will be designated to a lane in 

the Consolidated Resource Center (CRC) for processing: 

Completed/Fully Documented, Standard, or Specialized.

c. Request Documentation 

For each project, PDMG develops a request for documentation 

and information needed to support the Applicant's claims. PDMG 

sends the request to the Applicant through the Grants Manager.

d. Submit Site Inspection 

Work Order Request(s) 

PDMG assesses what type of site inspection is needed—standard 

or specialized—and sends a Site Inspection Work Order Request

to the Site Inspection Task Force Leader (SI TFL) through the 

Grants Manager.

e. Assign Site Inspector (SI)

SI TFL assesses the types of facilities on the Site Inspection Work 

Order request and the skill sets of available SIs. SI TFL assigns 

SIs to the Site Inspection Work Order.

f. Conduct Site Inspection 

SI conducts the site inspection with the Applicant. SI captures 

detailed dimensions of the damage as shown by the Applicant on 

the Site Inspection Report (SIR). SI also takes photographs and 

drafts sketches of the damages shown. SI enters the site 

inspection information into the Grants Manager, which drafts the 

Damage Description and Dimensions (DDD) of the project. The SI

sends the DDD to the PDMG.

g. Review the SIR and DDD 

PDMG reviews the DDD to ensure the information is clear and 

matches the SIR and accompanying photographs.
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Step Description 

h. Review Applicant Request 

for Documentation 

Responses 

Applicant responds to the request for documentation for each 

project. After each request is satisfied, Applicant returns the 

request to the PDMG through the Grants Portal. PDMG reviews to 

ensure the request is complete.

i. Assess Work Eligibility 

(Recommendation)

Before sending the project to the next step, PDMG reviews the 

work claims for eligibility. If a project is deemed ineligible for PA, 

a Determination Memorandum will be issued with an explanation.

j. Applicant Reviews and 

Signs DDD 

Through the Grants Manager, PDMG sends the DDDs associated 

with each project to the Applicant for review and approval. PDMG 

discusses the DDDs with the Applicant and the Applicant's 

desired method of repair.

k. Complete Development 

Guide Questions 

PDMG completes the Development Guide Questions in the Grants 

Manager. These questions determine the following: who will

develop the Scope of Work (SOW) and cost estimate for the 

project, the method of repair, the Applicant's interest in mitigation 

opportunities, and environmental planning and historic 

preservation (EHP) issues with the proposed method of repair.

l. Submit Project to CRC PDMG sends project(s) to the CRC via the Grants Manager.

For all options, FEMA will issue the Determination Memorandum and Letter. If the Recipient is performing 

customer service functions, the Recipient may draft the Determination Memorandum and Letter for FEMA to 

review, approve, and send to the Applicant.

Phase III: Scoping and Costing 

The objective for the Scoping and Costing phase is to validate Applicant-provided documents 

to develop Completed/Fully Documented projects or develop/validate the Scope of Work

(SOW) and cost estimate for standard and specialized projects. Table 12 identifies 

responsibilities that Recipients choosing one or both of the scoping and costing options 

undertake. Many responsibilities in this phase will be managed by FEMA for all operations. 

Table 12: Scoping and Costing for PA Delivery 

Step Description 

a. Assign Consolidated 

Resource Center (CRC) 

Specialists 

CRC Lane Task Force Leads (TFL) assign specialists based on the 

project complexity and skill sets required.

b. Develop or Validate the 

Scope of Work (SOW) 

and Cost 

Completed/Fully Documented: Specialists review/validate 

Applicant-provided documentation to develop the Damage 

Description and Dimensions (DDD), SOW, and cost for each project.

Standard/Specialized: Specialists develop or validate Applicantprovided SOW and cost estimates for each project.
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Step Description 

c. Draft 406 Hazard 

Mitigation Proposal 

Program Delivery Manager (PDMG) drafts Hazard Mitigation 

Proposal for eligible facilities, if applicable.

d. Environmental and 

Historic Preservation 

(EHP), Insurance, and 

Mitigation 

For special considerations, such as EHP, insurance, and mitigation, 

the Recipient may help Subrecipients gather required 

documentation and review projects for completeness. FEMA then 

performs compliance reviews to ensure projects comply with 

federal regulations related to their respective program.

e. Peer Review 

CRC Lane TFLs or designees conduct a peer review of the project, 

as needed.

f. Determine Work and 

Cost for Eligibility 

CRC Specialist assesses the work and costs and makes an 

eligibility recommendation. CRC raises eligibility issues with the 

PAGS to confirm eligibility recommendation.

g. Program Compliance 

Evaluations 

FEMA conducts Quality Assurance, Insurance, Mitigation, and EHP 

evaluations for each project.

For all options, FEMA will issue the Determination Memorandum and Letter. If the Recipient is performing 

customer service functions, the Recipient may draft the Determination Memorandum and Letter for FEMA to 

review, approve, and send to the Applicant.

Phase IV: Obligation 

In the final phase of the PA delivery process, funding is obligated to eligible projects. Once 

approved, FEMA obligates funds to the Recipient, who obligates subawards to Subrecipients.

Table 13 shows the responsibilities of this final phase. Recipients choosing one or both 

customer service options complete the PDMG review and conduct the Recovery Transition 

Meetings.
State-Led Public Assistance Guide 

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Table 13: Obligation of Funds for PA Delivery 

Step Description 

a. Program Delivery 

Manager (PDMG) 

Review 

PDMG reviews the completed project and award in the Grants 

Manager.

b. FEMA Final Review FEMA reviews the completed project and award in the Grants 

Manager.

c. Recipient Review Recipient reviews the completed project and award in the Grants 

Portal.

d. Applicant Review 

Applicant reviews the completed project and award in the Grants 

Portal and concurs with the terms of funding.

e. FEMA Obligates 

Funding to Recipient 

Recipient receives grant funding from FEMA.

f. Pass-through Funds 

to Subrecipient 

Recipient obligates subaward funds to Subrecipient(s).

g. Recovery Transition 

Meeting 

The Recovery Transition Meeting is the formal transition briefing from 

FEMA back to the Recipient. The format of this meeting will depend on 

the organization of responsibilities for a state-led PA operation. 

Post-Award Grant Administration 

Post-award grant administration occurs after FEMA has obligated funds. The objective is to 

monitor project construction and finances and to develop grant versions, as necessary. 

FEMA considers requests for time extensions or appeals in accordance with published 

guidance and may conduct audits during this phase. Table 14 shows the responsibilities in 

post-award grant administration, all of which are the same for a PA operation.

Table 14: Post-Award Grant Administration 

Step Description 

a. Monitoring Work 

Performed Under 

the Scope of Work 

(SOW) 

Recipient monitors grant funds and subaward-supported activities to 

ensure the grant activities are being performed in accordance with the 

SOW, the activities are compliant with federal requirements, 

and sufficient funds are available for closeout.

b. Quarterly Progress 

Reports and 

Financial Status 

Reports 

Recipient submits quarterly progress reports that list all open projects 

where Recipient has not processed the final federal payment to the 

Applicant. Recipient submits financial status reports proving the status 

of funds, expenditure drawdowns, and the status of the Recipient’s costshare requirements.

c. Appeals 

FEMA provides two opportunities for Applicants to appeal a funding

decision. The first is to the Regional Administrator (RA). If the Applicant

disagrees with the first appeal determination, it may submit a second

appeal to the Assistant Administrator of the Recovery Directorate at

FEMA HQ.
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Step Description 

d. Audits 

FEMA responds to audits with a Corrective Action Plan for each

recommendation with which it concurs and provides an explanation for

each recommendation with which it does not concur. FEMA will notify

Recipients of changes to a project or to funding if changes are required

in a Corrective Action Plan.

Closeout 

Closeout is the final step of the PA life cycle and depends on the size of the project. The 

objective in this step is to ensure that the Subrecipient and Recipient have spent all

obligated funds in the manner in which they were described.

Table 15 shows the final responsibilities in the PA grant life cycle required for PA grant 

closeout. Recipients play a role in closeout even when they do not pursue state-led PA. 

Table 15: PA Grant Closeout 

Step Description 

a. Initiate 

Project 

Closeout 

Recipient conducts final financial reconciliation and ensures all appeals have a

final determination, all funds have been obligated, the project is complete, and

the final expenditure report has been submitted.

b. Initiate 

Subrecipient 

Closeout

Recipient submits a written closeout request for each Subrecipient once all the 

Subrecipients’ projects have been completed and closed for the 

disaster. Recipient submits Project Completion and Certification Report (P.4 

Form) to demonstrate that the Applicant is ready for closure.

c. Project and 

Subrecipient 

Closeout 

FEMA reviews the P.4 Form and informs the Recipient of outstanding issues. If 

no issues are found, FEMA concurs that the Subrecipient is ready for closure.

d. Disaster 

Closeout

FEMA closes out the award when it determines that all applicable

administrative actions and all required work authorized by the grant have been

completed.
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State-Led Public Assistance Guide

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APPENDIX F: RESOURCE TOOLKIT 

Table 16 lists various resources that may be helpful to Recipients currently conducting 

Public Assistance (PA) operations or Recipients that may conduct PA operations in the 

future. Recipients can access these resources through the Grants Portal or Grants Manager 

or by contacting their Regional PA Branch Chief or designated PA official.

 

Table 16: Resource Toolkit 

Resource Type Description

Exploratory Call and 

Recovery Scoping 

Meeting Guides

Document or 

Guidance

Guides containing objectives, checklists, and other 

information about Exploratory Calls and Recovery Scoping 

Meetings.

Position Assists Document or 

Guidance

Position Assists provide guidance on the Public Assistance 

(PA) delivery model to FEMA PA Joint Field Office (JFO) and 

Consolidated Resource Center (CRC) staff. They explain 

when and how staff work in the four phases of the PA 

delivery process and provide links to checklists and tools to 

perform the work. The following Position Assists may 

provide helpful information for Recipients leading PA 

operations:

 Site Inspector

 Site Inspector Task Force Leader

 Program Delivery Manager (PDMG)

 Program Delivery Task Force Leader

 Document Validation Specialist

 Costing Specialist

 Technical Specialist

 EHP Advisor

Recipient-Developed 

Guides on PA 

Operations

Document or 

Guidance

Guides on PA operations developed by Recipients with 

experience leading PA operations. For example, the State 

of North Dakota adapted FEMA guidance to create its own

PA Program Basics Guide, Site Inspector Guide, and PDMG

Guide.

Recipient-Developed 

PA Position 

Descriptions

Document or 

Guidance

Position descriptions developed by Recipients that 

describe the essential job functions for positions that 

augment the state’s organic capacity (e.g., reservists)

under state-led PA operations.

Recipient 

Experiences with 

Leading PA 

Operations

Lessons 

Learned

Documents detailing Recipient experiences leading PA 

operations, including challenges, benefits, best practices, 

and lessons learned.

Grants Portal/Grants 

Manager Training 

and Guidance

Training

Online or in-person training and written guidance on the 

use of the Grants Portal/Grants Manager platform, which 

allows FEMA and state, local, tribal, and territorial 

governments to manage PA grant applications and delivery.
State-Led Public Assistance Guide

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Resource Type Description

PA Program Training Training

Online or in-person training provided by FEMA that 

introduces and provides an overview of the PA Program, 

process, and policies. The New PA Model for Recipients 

and Applicants course may be helpful for Recipients 

leading PA operations.

Position-Specific 

Training Training

In-person training provided by FEMA that teaches statelevel emergency management staff about the roles and 

responsibilities of specific positions necessary to conduct 

PA operations (e.g., site inspectors and PDMGs). The 

trainings primarily take place after a presidential disaster 

declaration and may include long-form, 2-week training 

courses and shorter, refresher/micro trainings. Some of 

these courses may only be offered at FEMA training sites. 

The following courses may be helpful for Recipients leading 

PA operations:

 E0865, Public Assistance Site Inspection

 E0866, Scoping and Costing

 E0867, Public Assistance Document Review and 

Validation

 E0869, Public Assistance Program Delivery 

Management

 E0870, Public Assistance Field and CRC Operations 

Management

 L253, Environmental and Historic Preservation

Operational 

Agreement 

Template

Signed amendment to the FSA that codifies the Recipient’s 

commitment to conduct a state-led PA operation according 

to the conditions stated in the agreement. For more 

information, see Appendix D: Operational Agreement

Template.

PA Management 

Plan Template

Modified PA Management Plan template that Recipients 

can use during a state-led PA operation to track progress 

and milestones and consolidate resources to submit to 

Regional staff for management and oversight purposes.

See Chapter 4: State-Led Public Assistance Operating 

Concept for more information.