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FEMA Policy: Public Assistance Simplified

Procedures

FEMA Policy FP-104-23-001 

BACKGROUND 

Section 422 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 

U.S.C. § 5121 et seq (Stafford Act) authorizes the Federal Emergency Management Agency 

(FEMA) to provide funding on the basis of the federal estimate for projects with an estimated 

cost below a specified and established dollar threshold and implement simplified procedures 

for projects below such threshold. In August 2022, FEMA published a final rule to increase the 

established threshold for Small Project maximum for the agency’s Public Assistance (PA) 

program to $1 million (Small Project). The increased threshold reduces the administrative 

burden on state, local, tribal, or territorial (SLTT) governments and private non-profit (PNP) 

organizations receiving FEMA financial grants following a disaster. A Small Project has costs

below the threshold, while a Large Project has costs equal to or above the $1 million threshold

(Large Project).

1 This policy supersedes guidance pertaining to Small Projects in the Public 

Assistance Program and Policy Guide (PAPPG) and establishes additional requirements 

related to Small Projects. All other requirements in the PAPPG apply. 

PURPOSE 

This policy streamlines application procedure for Small Project funding under the PA program 

to simplify implementation of the PA program and support rapid recovery for Applicants. The 

use of simplified procedures, such as submitting self-certified estimates and summary reports, 

may allow applicants to receive funding early and promotes rapid recovery of the affected 

community. This policy defines FEMA’s simplified procedures and requirements for Small 

Projects funded under the PA program. 

PRINCIPLES 

A. Apply simplified procedures in an appropriate and consistent manner. 

B. Reduce the administrative burden for Small Projects. 

1 Small Projects are those that have a total eligible project cost (federal and non-federal cost share) less than the threshold after 

mitigation is added and all applicable reductions are taken, such as insurance proceeds. FEMA also establishes a minimum 

threshold for which projects must meet or exceed to be considered for Public Assistance (PA) funding. FEMA adjusts these 

thresholds annually based on the consumer price index. See Per Capita Impact Indicator and Project Thresholds | FEMA.gov. 
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C. Support equitable delivery of assistance to underserved communities.

D. Enable communities to recover more quickly after all Presidential emergency and 

major disaster declarations.

REQUIREMENTS

A. APPLICABILITY

This policy applies to all PA Small Projects funded under major disasters and emergencies

declared on or after the date of issuance. It applies to Stafford Act Sections 403, 406, 407, 

and 502. It does not apply to Management Costs funded under Stafford Act Section 324 or 

Donated Resources.

B. DOCUMENTATION REQUIREMENTS

FEMA is streamlining documentation requirements for Small Projects to include acceptance 

of Applicants’ self-certified estimates and summary information for eligible facility, work and 

cost as outlined in Section C and in accordance with all laws, regulations, Executive 

Orders, and policies in lieu of providing more detailed documentation. Additional 

certification requirements are listed below in Section H.

FEMA specifies the information and documentation that Applicants are required to submit 

in Appendix A: Minimum Small Project Information Requirements. Additionally, information 

for detailed documentation requirements is further defined in the PAPPG V.4

FEMA will accept eligible Applicants submitting summary documentation and less 

information for Small Projects. Applicants must continue to retain all source documentation,

including project eligibility records and financial records, for 3 years after the date the 

Recipient submits to FEMA certification of completion of the last Small Project. The 

Recipient must keep all financial and program documentation for 3 years after the date it

submits the final SF-425 in accordance with 2 C.F.R. § 200.334 and access to records will 

be provided upon request in accordance with 2 C.F.R. § 200.337. SLTT government laws 

may require longer retention periods. Real property and equipment disposition, audits, and 

litigation may also require longer retention periods.2 If requested, Applicants must provide 

documentation to FEMA. Recipients may require documentation not otherwise required by 

FEMA (such as actual cost documentation for Small Projects). In such cases, the Applicant 

must provide the documentation to the Recipient.

C. COST ESTIMATES

To streamline the application process for Small Projects, FEMA does not adjust estimated 

costs to the actual incurred amount. Once the estimated amount is obligated, FEMA 

considers it reasonable and eligible and does not re-evaluate the cost if there is no 

evidence of fraud, waste or abuse, and the Applicant complies with federal grant 

conditions.

2 2 C.F.R. § 200.334.
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1. Completed work: FEMA may accept certified cost estimates for projects that have all 

work complete in cases where Applicants are unable to compile actual costs within a 

reasonable timeframe, or when Applicants have not yet received final invoices. FEMA 

does not develop estimates for completed work.

2. Applicant-provided estimates: To streamline the process for Small Projects, FEMA 

will accept the Applicants providing certified cost estimates as outlined in Section B 

above. The Applicant’s itemized cost estimate must include information to support the

estimate and certify that the costs claimed directly correlate to work required to address 

major disaster and emergency related impacts in the Project Application. FEMA may 

use the Cost Estimating Format (CEF)3 on Small Projects as necessary due to project 

complexities.

a. Completed or partially completed work may be estimated based on an 

extrapolation of known actual costs. 

b. Employee labor costs for Applicants’ Force Account Labor estimates may be 

accepted based on summary information instead of providing detailed 

documentation (e.g., time sheets, labor rates) as outlined in the PAPPG V.4

Chapter 9, Scope of work and Cost Development. Estimates may be calculated 

based on actual or estimated total number of staff and total hours with average 

pay rates. Average rates may only be used for employees at similar pay grades

and same category of employee (i.e., permanent full-time vs. part-time vs. 

temporary hire). Applicants should include fringe benefits as part of the labor 

estimate. Fringe benefits may be calculated based on a percentage of the hourly 

pay rate.

c. Equipment and supplies cost estimates for purchased equipment or supplies 

may be accepted based on purchase orders, rental agreements, or the lowest of 

three quotes. Items that meet the PAPPG definition of equipment must include a 

reduction for depreciation or fair market value (estimated or actual) at the time the 

equipment is no longer needed. For Small Projects, fair market value and the 

associated reduction are addressed during project formulation. To calculate 

depreciation or fair market value, the date used to determine when equipment is

no longer needed is based on the work completion deadline. For Force Account 

Equipment the estimate should be based on usage hours and applicable

equipment rate. No reduction is taken for supplies for Small Projects during 

project formulation because the quantity of supplies for which funding is eligible is 

an amount that is necessary and reasonable, and the estimate is based on the 

aggregate unused supplies not exceeding $5,000.4

3 CEF for large Projects has been designed to provide more uniformity in estimating costs for large projects, and to make it user 

friendly and flexible enough to respond to individual project conditions for all types of permanent restorative work. For more complex

Small Projects, CEF may be applicable due to the threshold increase to under $1 million. 4 2 C.F.R. § 200.314.
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d. Contract costs are typically calculated based on a bid or contract amount 

obtained from a competitive procurement process. If a request for proposals has 

not yet been issued, contract work may be estimated based on historical costs or 

another Applicant’s costs for projects that are similar in size and scope of work 

(e.g., similar quantities and types of debris, materials costs, and other factors).

All Small Projects must comply with procurement and contracting laws and 

regulations. In instances where Applicants submit cost claims based on noncompetitive bids or contracts, time and materials contracts, or cost-pluspercentage-of-cost or percentage-of-construction contracts, FEMA will review the 

project for reasonable cost and procurement and contracting compliance.

e. Construction estimates and summaries are permitted based on the below 

criteria. FEMA does not conduct additional cost validation or reasonable cost 

analysis unless there are Scope of Work (SOW) concerns or evidence of 

inaccurate information. When Applicants provide estimates for construction work

in accordance with the following criteria, the construction estimate must be: 

i. Prepared by a licensed professional engineer or other estimating 

professional, such as a licensed architect or certified professional cost 

estimator who certifies the estimate was prepared in accordance with

industry standards; 

ii. Based on a component-level scope of work that is clearly attributable to the 

disaster-related damage with a level of detail sufficient to validate that cost 

elements are neither omitted nor duplicated; 

iii. Accompanied by certification that the estimated cost directly corresponds 

to the repair of damage caused directly by the declared major disaster or 

emergency; and

iv. Based on unit costs for each component of the SOW and not a lump sum 

amount; or a bid or contract amount obtained from a competitive 

procurement process (if bid/contracting process has occurred). 

If Applicant plans to conduct any work with employee labor, the estimate must be 

developed based on the language in Sections C.2 (b) and (c), not (d) or (e) above. 

For additional information on Applicant estimates see PAPPG V.4 Chapter 9.II.2 

f. Hazard Mitigation is encouraged in order to provide protection from future 

incidents. FEMA has the authority to provide PA funding for cost-effective hazard 

mitigation measures that will reduce the potential for damage to a facility from a 

disaster event.5 PA Mitigation is in addition to any code and standard upgrade 

requirements and must reduce potential future damage to the damaged portion(s) 

of the facility, meet cost-effectiveness criteria, and comply with other Federal, 

State, tribal, territorial, or local legal requirements.

6 PA considers a mitigation 

5 Stafford Act § 406(e), 42 U.S.C. § 5172; 44 C.F.R. § 206.226(e). 6 44 C.F.R. § 206.226(e).
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measure cost-effective if it does not exceed 15 percent of the total eligible repair 

cost of the facility (prior to insurance reductions), was pre-determined to be costeffective up to 100 percent of eligible repair cost (prior to insurance reductions)￼7

or is demonstrated to be cost-effective through an acceptable benefit cost 

analysis methodology.

g. Soft Costs are costs necessary to complete the project such as costs for permits, 

studies, designs, surveys, or project management and may be included in the

Applicant provided summary based on quotes or historical costs. If FEMA 

approves a project that only includes funding for Architectural and Engineering 

design, the project size classification will be amended once the scope of work and 

associated costs has been included.

3. FEMA Estimates: For work that has not been completed, where applicable or relevant, 

FEMA may use the CEF to ensure that the estimate includes all costs to complete the 

approved SOW. FEMA offers assistance to the Applicant to develop its SOW or cost 

estimate based on provided information (e.g., soft costs, damage, loss, and addition 

information to build estimate). FEMA may request this additional information when 

needed to prepare the estimate

4. Duplication of Benefits: If the Applicant receives funding from another source for any 

work or costs in the project application, it will notify FEMA, and funding will be 

reconciled to eliminate duplication as required by Stafford Act § 312. Prior to obligation, 

FEMA reduces the project amount to account for:

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i. Actual insurance proceeds, if known; or anticipated insurance proceeds based on 

the applicable insurance policy if the amount of actual proceeds is unknown.; and

ii. Funding from any other sources for the same work that FEMA funded such as 

non-federal grants, third party liability, and other federal awards.

D. REQUESTS FOR ADDITIONAL INFORMATION 

In general, FEMA limits its requests for additional information to scenarios where

Recipients or Subrecipients: 

1. Do not provide all information and documentation required by this policy; or

2. Provide unclear or inaccurate information or documentation. 

E. NON-DISCRIMINATION [AND EQUITY] IN FEDERALLY ASSISTED PROGRAMS 

As a condition of receiving PA funding, Recipients and Subrecipients must comply with all 

federal civil rights laws and authorities prohibiting discrimination, including but not limited 

to, Section 308 of the Stafford Act, 42 U.S.C. § 5151, which requires the impartial and 

7 see Appendix J of the PAPPG for a full list of hazard mitigation measures pre-determined to be cost-effective up to 100 percent of 

eligible repair costs.

8 44 C.F.R. §§ 206.252(c) and 253(a). 
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equitable delivery of disaster services and activities without discrimination.

F. ENVIRONMENTAL AND HISTORIC PRESERVATION COMPLIANCE REQUIREMENTS

Applicants must comply with EHP laws, regulations, and Executive Orders (EO), including 

but not limited to, the Endangered Species Act (ESA), National Environmental Policy Act 

(NEPA), and the National Historic Preservation Act (NHPA).9 Applicants must afford FEMA 

the opportunity to perform EHP reviews prior to starting any work that has potential to 

impact the environment or historic properties, including archaeological resources. FEMA 

reviews each Small Project to ensure that the project complies with appropriate EHP laws, 

regulations, and EOs. If an Applicant starts work prior to FEMA’s completion of the EHP 

review, it jeopardizes PA funding for the entire project.10 Such situations may compel 

FEMA to revoke federal funding for those portions of the project that fail to meet the EHP 

compliance requirements. FEMA will conduct a review of all projects to ensure compliance 

with EHP requirements. FEMA may require additional SOW clarification to determine 

compliance with other requirements such as those needed by regulatory agencies for 

consultation. 

G. INSURANCE COMPLIANCE REQUIREMENTS

When FEMA provides assistance for permanent work to repair or restore a facility, Stafford 

Act § 311 requires the applicant to insure the facility and contents with the types and extent 

of insurance that is reasonably available, adequate, and necessary to protect the facility 

against future loss. FEMA refers to this as the requirement to “obtain and maintain” 

insurance requirement. If the Applicant does not comply with this insurance requirement, 

FEMA will deny or deobligate PA funding for that facility and the facility is ineligible for PA 

funding in any subsequent disaster. Applicants may comply with the insurance requirement 

for both flood and non-flood hazards using commercial property insurance or, with FEMA’s 

approval, a self-insurance plan. 11￼. FEMA Insurance Specialists will conduct an insurance 

review for all projects for compliance with the obtain and maintain insurance requirement 

and a duplication of benefits review. 

H. DAMAGE, WORK, AND COST CERTIFICATIONS

To streamline the process, FEMA will accept the Applicant’s provided certification for 

damage and work, in lieu of providing comprehensive source documentation. The Applicant 

must certify that damage was caused directly by the declared incident. FEMA does not 

provide PA funding for repair of damage caused by deterioration, deferred maintenance, 

failure to take measures to protect a facility from further damage, or negligence.

12 With 

exception of the information and documentation listed in Appendix A, and in lieu of 

9 See the Environmental and Historic Preservation Considerations sections of the PAPPG for additional information.

10 Stafford Act § 316, 41 U.S.C. § 5159, and 2 C.F.R. § 200.300. 11 Stafford Act 311 (c); 44 CFR Part 75; and FP 206-086-1, VII, Part 1. C. 12 PAPPG Chapter 4, I.B.1
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providing comprehensive source documentation to FEMA, Applicants must certify13 that:

1. Damage: All damage claimed was a direct result of the Presidential emergency and 

major disaster declaration. The damage did not result from a lack of maintenance.

2. Work Claimed: All work claimed to retore the facility back to its pre-disaster design 

function and capacity was required as a direct result of the Presidential emergency and 

major disaster declarations, is located within the designated area, and is the applicant’s 

legal responsibility.

3. Impartial and Equitable Delivery of Public Assistance: All work claimed was

delivered in an impartial and equitable manner as required by Title VI of the Civil Rights 

Act, Section 308 of the Stafford Act, 42 U.S.C. § 5151, and applicable provisions of laws 

and authorities prohibiting discrimination.

4. Code and Standard Compliance: All facilities are being restored in accordance with all 

federal and SLTT code and standard requirements.

5. Procurement and Contracting: The Applicant is using the most restrictive of either its 

own documented policies and procedures for procurement or federal procurement and 

contracting laws in accordance with 2 C.F.R. Part 200. The Applicant is following

Environmental Protection Agency guidelines for procurement of recovered materials; 

and including all applicable required contract provisions.

6. Cost Reasonableness: All costs claimed are reasonable and of a type generally 

recognized as ordinary and necessary for the type of facility and work as required by 44 

C.F.R. § 206.228 and 2 C.F.R. § 200.404.

7. Duplication of Benefits: No work or costs are being claimed that are covered by 

another funding source. 

8. Documentation Retention: All documentation is being retained in accordance with 2 

C.F.R. §§ 200.334 and 200.337 and will be provided upon request. 

9. True and Correct Statements: All information provided is true and correct. Upon 

submittal, the certified Project Application becomes a legal document. It is a violation of 

federal law to intentionally make false statements or hide information when applying for 

Public Assistance.

I. POST AWARD MONITORING

1. Quarterly Progress Reports: FEMA does not require Recipients or Subrecipients to 

submit Quarterly Progress Reports for Small Projects. 

13 Final responsibility for ensuring compliance with EHP laws, regulations, and executive orders remains with FEMA. Failure to 

obtain and provide all requested documentation jeopardizes funding. 
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2. Audits: FEMA may adjust funding on Small Projects due to audit findings. Recipients 

and Subrecipients are subject to federal and non-federal audits. A Recipient or 

Subrecipient that expends $750,000 or more in federal awards during its fiscal year 

must have a single or program-specific audit conducted for that year in accordance with 

2 C.F.R. § 200.501. Additionally, Recipients and Subrecipients must have records 

available for review by SLTT auditors, FEMA, the U.S. Department of Homeland 

Security’s Office of Inspector General, or the U.S. Government Accountability Office.

Monitoring and oversight requirements in connection with recipient compliance with 

federal civil rights laws are also authorized pursuant to 44 C.F.R Part 7.

3. Payment Validation: FEMA may request documentation to validate Recipient payment

to the Subrecipient on individual Small Projects under the Payment Integrity Information 

Act of 2019. The SLTT will follow its applicable laws and regulations for payment 

processing.

4. Sampling: FEMA may implement sampling procedures in order to evaluate the 

accuracy of estimates for Small Projects. Such reviews will not change the amount of 

funding awarded for individual projects but will be utilized to assess cost estimating 

processes under simplified procedures. FEMA reserves the right to conduct further 

review should there be audit findings as a result of the sampling procedures. 

J. POST AWARD CHANGE(S) IN SCOPE OR COSTS

Once FEMA awards a Small Project, FEMA does not adjust the estimated cost or approved 

amount of an individual Small Project unless it is for one of the reasons listed below. This 

applies even when FEMA obligates the Project based on an estimate and the actual project 

costs for completing the eligible scope of work differ from the estimated amount.

FEMA only adjusts the approved amount on individual Small Projects for the following 

reasons: 

1. The Subrecipient did not complete the approved scope of work;

2. FEMA approves a change in scope of work, including any additional hazard 

mitigation;

3. The Subrecipient received funding not previously deducted to prevent a duplication 

of benefits (e.g., when actual insurance proceeds exceed the estimated amount 

deducted);

4. When actual insurance proceeds are less than the estimated amount deducted;

5. Errors or omissions;

6. Hidden damage;

7. Non-compliance with applicable laws, regulations, and Executive Orders; or

8. Fraud, waste, or abuse.

In these cases, FEMA only adjusts the cost for the specific item(s) adjusted.

FEMA will adjust the project size classification based on adjusted cost estimates for the 

project. FEMA must provide the required congressional notification under section 507 of the 
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DHS Appropriations Act for any projects that equals to or exceeds $1 million.

FEMA encourages Applicants to use excess funds on activities that reduce future risk or 

improve future disaster operations.

K. NET SMALL PROJECT OVERRUN

The Subrecipient may request additional funding if its combined actual cost of all its Small 

Projects significantly exceeds the total amount obligated for all its Small Projects. FEMA 

refers to this as a Net Small Project Overrun (NSPO) appeal. The Subrecipient must submit 

request in the form of an appeal within 60 days of the latest work completion date of all its 

Small Projects. If all of the Subrecipient’s Small Projects have not been obligated at that 

time, then the Subrecipient has 60 days from the date FEMA obligated its last Small Project

to submit an appeal. The appeal must include actual cost documentation for all Small 

Projects that FEMA funded. 

The work completion date is the date the Subrecipient completes all work associated with 

the approved scope of work, including meeting all compliance requirements. It does not 

include administrative actions after the actual project scope of work has been completed 

such as paying invoices, reconciling insurance, warranty periods, compiling and submitting 

documentation, or other grant management activities. 

L. SIMPLIFIED CLOSEOUT

FEMA reconciles all Small Projects based on accepted certified summaries provided by 

Recipients. To close Small Projects, the Recipient must submit a Small Project Completion 

Certification and certify that:

• The Subrecipient completed the approved SOWs for all of its Small Projects in 

accordance with the FEMA-State/Territory/Tribe Agreement; and

• It made all payments in accordance with the FEMA- State/Territory/Tribal agreement 

(44 C.F.R. § 206.205(a)).

The Applicant must provide documentation to substantiate final actual insurance proceeds 

and any other sources of funding that may duplicate FEMA PA funding. Applicant must 

provide documentation to show that they have obtained insurance and complied with all

EHP conditions. Non-compliance with any applicable federal and SLTT laws, regulations, 

and EOs may result in adjustment, denial or deobligation of funding.

M. TIMELINES AND EXTENSIONS

1. Subrecipient Completion Certification: If the Subrecipient is not requesting an 

NSPO, it must certify completion of all its Small Projects to the Recipient no later than 

90 days from its latest Small Project work completion date, or the latest approved 

completion deadline for all of its Small Projects, whichever is sooner. If work on the 

latest Small Project was completed prior to obligation, the 90-day deadline begins on 

the date of obligation. If a NSPO is requested, then the process in Section J applies.
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2. Recipient Completion Certification: The Recipient must certify that the Subrecipient 

completed the approved scopes of work for all its Small Projects in accordance with the 

FEMA-State/Tribe/Territory Agreement; and that the Recipient made all payments in 

accordance with the FEMA-State/Tribe/Territory agreement.

The Recipient must submit the certification to FEMA within 180 days from the latest 

Small Project work completion date, or the latest approved deadline of the 

Subrecipient’s Small Projects, whichever is sooner. If work on the latest Small Project

was completed prior to obligation, the 180-day deadlines begin on the date of obligation.

The Recipient must submit certification of completion of its own Small Projects within 90 

days of the latest Small Project work completion date, or the approved deadline of its 

last Small Project, whichever is sooner. If work on the latest Small Project was 

completed prior to obligation, the 90-day deadlines begin on the date of obligation.

Once FEMA receives the Recipient’s completion certification and completes the 

necessary review, FEMA closes the respective Small Projects and notifies the Recipient 

electronically. 

3. Completion Certification Time Extensions: Recipients and Subrecipients that are 

unable to meet these deadlines may request a time extension from the FEMA Regional 

Administrator. Examples of extenuating circumstances that may justify a time extension 

include.

i. Projects with open and active correspondence pending that is related to the 

scope or cost of the project;

ii. When the respective Recipient or Subrecipient has insufficient personnel 

available to process project closeout and documentation reviews due to active 

major disaster or emergency response activities; or

iii. When the respective Recipient or Subrecipient have a significant amount of 

project closeouts due simultaneously.

______________________________________

Melissa K. Forbes

Assistant Administrator

Recovery Directorate

January 6, 2023 

___________________________________

Date
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ADDITIONAL INFORMATION

REVIEW CYCLE

This policy will be evaluated and incorporated into version 5 of the PAPPG.

AUTHORITIES 

• Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. § 5121 and 

5207, as amended

• Title 44 of the Code of Federal Regulations, Part 206, Subpart G and H 

• Title 2 of the Code of Federal Regulations, Part 200

MONITORING AND EVALUATION 

FEMA will closely monitor the implementation of this policy through coordination with regional 

and field staff, as appropriate, as well as interagency partners and SLTT stakeholders. 

QUESTIONS

Direct questions to fema-recovery-pa-executive-office@fema.dhs.gov.
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Appendix A: Minimum Small Project Information Requirements

Note: Applicants must continue to retain all source documentation

Applicant Information

Applicant Eligibility • All information required in the PAPPG to substantiate applicant eligibility.

Facility Information

Facility Eligibility • Facility Location (address or GPS);

• Facility type;

• Original date of facility construction; 

• For a natural feature: documentation to substantiate that it is improved 

and maintained.

• Information in the PAPPG for services provided in facilities that are 

owned or operated by private non-profit applicants (Chapter 4, Section 

II.B).

• Information in the PAPPG for facilities that are: 

 Leased (Chapter 4, Section I.3.d);

 Inactive or partially inactive (Chapter 4, Section II.C);

 Scheduled for repair or replacement (Chapter 4, Section II.D);

 Privately owned or operated (Chapter 4, Section II); or 

 Beaches (Chapter 8, Section IX.E.1).

 Mixed use facilities (Chapter 4, Section II.B.1)

• Information for submerged roads (PA Guidance on Inundated and

Submerged Roads FEMA Policy FP 104-009-13)

Work Information

Work on a Facility or 

Equipment

• Type and quantity of equipment, material, and supplies purchased or 

used;

• Work location(s); 

• Description of the work required to restore the facility, including 

dimensions and quantities by material type (with photos and sketches if 

available); 

• Applicable permits and authorizations; 

• If applicable, documentation substantiating coordination with regulatory 

agencies; and

• Information and documentation required by the PAPPG for: 

 Pre-disaster capacity of channels, basins, and reservoirs (Chapter 8, 

Section IX.B).

 Replacement or relocation of a facility (Chapter 8, Section IV.A);

 Improved or Alternate Projects (Chapter 8, Section VIII).

Damage Information • Location (address or GPS)

• A detailed, component-level damage description with dimensions and 

material types (with photos and sketches if available);

• Description of the cause of damage; and

• For insurable equipment, serial or vehicle identification number (VIN).
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Debris Removal

(Category A)

• Detailed description of work activities;

• Type and quantity of labor resources;

• Type and quantity of purchased or used equipment, material, and 

supplies;

• Quantity of each type of debris and method of removal;

• Work locations with physical address or GPS coordinate and ;

• Timeframe of work performed;

• Applicable permits and authorizations;

• If applicable, documentation substantiating coordination with regulatory 

agencies; 

• Information required by the PAPPG and the Simplified PA Program Part 

2 Memo dated September 6, 2022, updated for:

 Removal of hazardous limbs, trees, or stumps if contracted at a per 

price item (Chapter 7, Section 1.B);

 Waterway debris removal (Chapter 7, Section C);

 Removal of privately owned vehicles or vessels (Chapter 7, Section 

I.D);

 Private residential or commercial property debris removal (Chapter 

7, Section I.G.3 and 4); and

 Debris removal from private roads (Chapter 7 Section I.G.2).

• Debris disposal

 Temporary and final disposal site locations;

 Applicable permits and authorizations; 

 Any documentation substantiating coordination with regulatory 

agencies;

 If contracted, name of hauler to the final disposal location;

 Type of disposal site (e.g., municipal, private, commercial); and

 For commercial disposal sites: vendor names.

• Removal of vegetative debris in an invasive species quarantine area: 

 Name of the quarantine area;

 Method of disposal; and

• Whether the debris was disposed of according to quarantine 

requirements.

• Monitoring

Emergency 

Protective Measures 

Category B)

• Detailed description of work activities;

• Type and quantity of labor resources;

• Type and quantity of purchased or used equipment, material, and

supplies;

• Work locations with physical address or GPS coordinate;

• Timeframe of work performed; and

• Information, summary and documentation required by the PAPPG for:

 Any work on private property and work that requires FEMA approval 

including non-congregate sheltering (Chapter 7, Section II.O.2);

residential electrical meter repair (Chapter 7, Section II.R); 

demolition of residential or commercial property (Chapter 7, Section 
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II.U); safe rooms for temporary schools (Chapter &, Section II.V.5); 

and host-state/tribe/territory evacuation or sheltering (Chapter 7, 

Section II.O.4).

 Emergency Access (Chapter 7, Section II.J)

 Mosquito abatement (Chapter 7, Section II.Q and Appendix G);

 Expenses related to operating a facility or providing a service

(Chapter 7, Section II.D);

 Purchase or construction of a temporary facility (Chapter 7, Section 

II.V);

 Mold remediation (Chapter 7, Section II.X.3);

 Emergency berms or dunes on beaches (Chapter 7, Section II.X.4);

or 

 Repair of damage caused during the performance of eligible 

emergency protective measures or debris removal operations

(Chapter 7, Section III).

Hazardous materials • Types of hazardous materials;

• If not disposed, reason for not disposing and what was done, if anything, 

at the location of the materials; or

• If disposed:

 Location of disposal sites;

 Vendor or organization that transported the material;

 Waste manifests;

 Notification of proper storage; 

 Any required facility-specific Emergency Response Plans for spills, 

safety, and proper handling; and

 Whether any oil or hazardous spills occurred and if so, whether it 

was reported to state environmental agencies; if so, the case or site 

number.

Hazard mitigation • Detailed description of the work, including dimensions and quantities by 

material type

Use of fill or borrow 

material

• Type and quantity of fill;

• Source and location of the fill and borrow; and

• Whether the source location is commercial (if so, vendor(s) name), 

municipal, private, or other.

Ground disturbance • Location and dimensions of ground disturbance;

• Whether the site was previously undisturbed or outside of an existing 

footprint or right-of-way; and

• Whether it involves removal of any trees, root-balls, stumps, or other 

vegetation and if so, method of removal.

Work in or adjacent 

to a cemetery

• Cemetery name and age.

Work in or within 200 

feet of a waterway, 

body of water, 

floodway, or wetland

• Whether any equipment is being placed in water or wetlands. If yes, 

location and area dimensions (length, width, and depth).

• Whether discharge or fill materials occurred. If so, type of material.

• If dredging: method, dimensions, and boundaries.

Work on or adjacent 

to a facility 

• Whether there were any previous extensive renovations to the exterior 

or interior of the facility. If so, dates of renovations; and 
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constructed 45 or 

more years ago; 

listed on a national 

register; or that is a 

locally registered 

landmark or in a 

historic district

• Detailed descriptions of mold remediation activities including chemical 

cleansers or pounds per square inch for power washing.

Temporary access 

road or temporary 

staging of equipment 

or materials

• Whether it is in an existing right-of way; and 

• Type of surface.

Cost Information

Hazard mitigation • If applicable, a benefit-cost analysis or information for FEMA to conduct 

a benefit cost analysis.

Costs for completed 

work

• Certified cost estimates may be used in cases where Applicants are not 

able to compile actual costs within a reasonable timeframe, or when 

Applicants have not yet received final invoices.

• Estimates may be calculated based on actual or estimated total number 

of staff and total hours with average pay rates, including fringe benefits. 

Average rates may only be used for employees at similar pay grades 

and same category of employee (i.e., permanent full-time vs. part-time 

vs. temporary hire).

• Summary of the total hours and cost must include each of the following 

separately listed, if applicable: 

 Total number of employee straight-time hours and cost;

 Total number of employee overtime hours and cost;

 List of purchased materials, supplies, and equipment broken out by 

type with total cost for each;

 Rented equipment cost with total number of days and/or hours used; 

 Total number of applicant-owned equipment usage hours and cost 

broken out by equipment type; and

• Total cost for each contractor.

Costs for 

uncompleted work

• Itemized cost estimate; or

• Information for FEMA to prepare a cost estimate, which may be 

estimated based on an extrapolation of known actual costs.

Contracts • Type of contract; and

• Information and documentation required in PAPPG Chapter 6, Section 

VIII for contracts that are: 

 Non-competitively bid; 

 Time and materials;

 Cost-plus-percentage-of-cost; or 

 Cost-plus-percentage-of-construction.

Insurance • Policies as applicable and settlement documents; and

• Documentation to support compliance with Obtain and Maintain 

insurance requirements, if applicable.

Environmental or Historic Preservation Information
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Environmental or 

Historic Preservation 

Information

• Applicable permits and authorizations;

• Applicable documentation substantiating coordination with regulatory 

agencies; Whether work is near threatened or endangered species or 

designated critical habitat; and

• Documentation for FEMA to confirm compliance with EHP laws, 

executive orders, and regulations.