Submitting Costs for Reimbursement

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Small Project Simplified Procedures

FEMA establishes a dollar threshold each Federal fiscal year for the implementation of Simplified Procedures under Section 422 of the Stafford Act. This threshold defines a project as large or small. The threshold applies to incidents declared within that fiscal year.

The effective threshold for each year can be found at: FEMA Per Capita Impact Indicator and Project Thresholds. The applicable threshold will be determined by the disaster declaration date.

In August 2022, FEMA increased the small project threshold to $1M from $139,800 which was a significant increase from previous fiscal years. The increased threshold reduces the administrative burden on State, local, Tribal, and Territorial (SLTT) governments and private non-profit (PNP) organizations.

The guidance listed below outlines basic information applicable to a small project, process steps, and documentation required.

Policy/Guidance

Small Project - PA Simplified Procedures FP-104-23-0001 (01/06/2023)

FEMA Training Video

Documenting Damages and Repairs - Photographs

Take photos and ensure the damage is captured from different angles including close-ups. Take pictures of equipment tags which capture make, model, etc.

  • Damages before any emergency or temporary work is done or as soon as feasible.  
  • After restoration work is completed.

Tips for Organizing and Naming Documents

Do not upload individual invoices, timesheets, etc. into Grants Portal, combine each document type into one document, if feasible, depending on the combined file size (there is no size limit but files over 30mb may take longer to download/open) or number of pages (limit to around 100 pages). Preferably organize the invoices, timesheets, etc. in the same order as listed on the applicable summary spreadsheet to facilitate an easier FEMA review process which gets the project through FEMA reviews more quickly.  

Name required documents where they are easily identifiable. 

  • Example:  
    • (disaster #)_(project #)_(category)_(doc type) 
      • (ex. 3598_72532_Materials_Invoices)
      • (disaster #) applicable disaster number assigned by FEMA
      • (project #) comes from Grants Portal
      • (category) Labor, Contract, Equipment, Materials
      • (doc type) Summary, Invoices, Timesheets, Fringe Calculation, etc.

Due to file size or number of pages, if separating like documents into more than one file, name using (disaster #)_(project #)_(category)_(doc type)_Part 1, 2, 3….

For step-by-step instructions on uploading documents, see “Navigating Grants Portal”.

Force Account Labor (FAL)

FEMA refers to the Applicant’s personnel as “force account” and reimburses force account labor based on actual hourly rates plus the cost of the employee’s actual fringe benefits.  FEMA calculates the fringe benefit cost based on a percentage of the hourly pay rate. Because certain items in a benefit package are not dependent on hours worked (e.g., health insurance), the percentage for overtime is usually different than the percentage for straight-time.

Labor Policies

FEMA determines the eligibility of overtime, premium pay, and compensatory time costs based on the Applicant’s pre-disaster written labor policy, provided the policy:

  • Does not include a contingency clause that payment is subject to Federal funding;
  • Is applied uniformly regardless of a Presidential declaration; and 
  • Has set non-discretionary criteria for when the Applicant activates varies pay types.

All costs must be reasonable for the type of work being performed.  FEMA will determine whether the number of hours claimed are reasonable and necessary by evaluation:

  • The severity of the incident;
  • Whether the work was performed at a time when it was necessary to work extraordinary hours based on the circumstances of the incident;
  • The function of the employee for which the hours are claimed; and
  • The number of consecutive hours the employee worked.

Eligibility Criteria

Emergency Work

  • Budgeted employees - only overtime is eligible
  • Unbudgeted employees - both straight-time and overtime are eligible
  • Note:  Accelerated Debris Removal Alternative Procedure – straight-time for the Applicant’s employees conducting debris removal activities is eligible.

Permanent Work

  • Budgeted/Unbudgeted employees - both straight-time and overtime labor costs are eligible.
Emergency Work Labor Eligibility
Budgeted Employees Overtime Straight-Time
Permanent Employee X  
Seasonal employee working during normal season of employment X  
Unbudgeted Employees Overtime Straight-Time
Essential employee called back from administrative leave X X
Permanent employee funded from external source X X
Temporary employee hired to perform eligible work X X
Seasonal employee working outside normal season of employment X X

Reassigned Employees

The Applicant may assign an employee to perform work that is not part of the employee’s normal job. For example, a police officer may clear debris. FEMA provides Public Assistance (PA) funding based on the reassigned employee’s normal pay rate, not the pay level appropriate to the work, because the Applicant’s incurred cost is the employee’s normal pay rate. 
Straight-time of a permanent employee funded from an external source (such as a grant from a Federal agency or statutorily dedicated funds) is eligible if the employee is reassigned to perform eligible Emergency Work that the external source does not fund. FEMA must confirm that no duplication of funding exists prior to approval.

Backfill Employees

The Applicant may need to temporarily replace an employee who is responding to the incident. Overtime costs for the backfill employee are eligible even if the backfill employee is not performing eligible work as long as the employee that he/she is replacing is performing eligible Emergency Work.

FEMA also provides PA funding for straight-time if the backfill employee is a: 

  • Contracted or temporary employee; or 
  • Permanent employee called in on a normally scheduled day off (weekend or other off day). 

If the backfill employee is called in from scheduled leave, only overtime is eligible.

Supervisors

Second-level supervisors and above (e.g., commissioners, mayors, department directors, police and fire chiefs) are usually exempt employees and are not directly involved in the performance of a specific project. Therefore, they are not eligible for overtime, unless the Applicant: 

  • Demonstrates that the employee was directly involved with a specific project; 
  • Normally charges that individual’s time to specific projects regardless of Federal funding; and 
  • Incurs overtime costs for the employee in accordance with a labor policy that meets the criteria related to the Accelerated Debris Removal Alternative Procedure.

Other

Extraordinary costs (such as call-back pay, night-time and weekend differential pay, and hazardous duty pay) for essential employees who are called back to duty during administrative leave to perform eligible Emergency Work are eligible if costs are paid in accordance with a labor policy that meets the criteria above. 

Administrative leave or similar labor costs incurred for employees sent home or told not to report due to emergency conditions are not eligible. 

Stand-by Time

Subject to the provisions of labor cost eligibility criteria, FEMA also provides Public Assistance (PA) funding for costs related to stand-by time incurred in preparation for and directly related to actions necessary to save lives and protect public health and safety. To be eligible, stand-by time must be reasonable, necessary, and consistent with the Applicant’s practice in non-federally declared incidents. Examples of when FEMA may reimburse costs for stand-by time include, but are not limited to:

  • When bus drivers are prudently deployed to transport evacuees, even if the bus is not ultimately used for evacuations 
  • When first responders are prudently deployed for the purpose of evacuating or providing emergency medical care to survivors in order to save lives or protect health and safety, even if the employee does not ultimately perform eligible Emergency Work 
  • When a contract or union agreement requires payment for stand-by time

FEMA will determine whether any stand-by time claimed is reasonable and necessary based on whether: 

  • There is a contractual obligation to pay for stand-by time based on a labor agreement
  • The stand-by time occurred when it was necessary to have resources available to save lives and protect health and safety 

For instance, the Applicant may be required to pay firefighter costs from portal-to-portal, which may result in paying for 24-hour shifts with periods of rest. FEMA will reimburse costs based on such requirements. However, FEMA limits its reimbursement to that which is reasonable and necessary, not to exceed 14 calendar days from the start of the incident period.

Required Documents

Small Project (based on applicable threshold):

  • Labor Summary 
    • Include straight-time hours even if only overtime is being claimed (FEMA needs to verify employee worked appropriate hours for overtime pay)
  • Fringe Benefit Calculation Worksheet
    • If only claiming overtime, worksheet does not have to include fringe for straight-time
  • Pay Policy (may be requested if not previously provided under Organization Profile)

NOTE:  For small projects funded at $500,000 to the current small project threshold, MEMA requires the same documentation as required by FEMA for a Large Project.  It is recommended the documentation be uploaded to Grants Portal when submitting the project for FEMA approval.

Large Project (based on applicable threshold):

  • Labor Summary
    • Include straight-time hours even if only overtime is being claimed (FEMA needs to verify employee worked appropriate hours for overtime pay)
  • Fringe Benefit Calculation Worksheet
    • If only claiming overtime, worksheet does not have to include fringe for straight-time
  • Pay Policy (may be requested if not previously provided under Organization Profile)
  • Bargaining Agreement, if applicable
  • Substantiate hours claimed, provide the document(s) that are available:
    • Payroll Registers
    • Timesheets
    • Sign-in Sheets
    • Daily logs or activity reports

Cost Summary Template

FEMA Project Worksheet Template (XLS)

Force Account (Applicant Owned) Equipment (FAE)

FEMA provides Public Assistance (PA) funding for the use of Applicant-owned equipment (force account equipment), including permanently mounted generators, based on hourly rates.  FEMA may provide PA funding based on mileage for vehicles, if the mileage is documented and is less costly than hourly rates. 

FEMA only applies equipment rates to the time the Applicant is actually operating equipment. Although costs associated with mobilizing equipment to a project site are eligible, costs for standby time (time spent on hold or in reserve) are not eligible unless the equipment operator uses the equipment intermittently for more than half of the working hours for a given day. In this case the intermittent standby time is eligible.

FEMA provides PA funding for force account equipment usage based on FEMA, State, Territorial, Tribal, or local equipment rates in accordance with the specific criteria noted below. 

FEMA Rates

FEMA publishes equipment rates applicable on a national basis. FEMA’s rate schedule includes any item powered by fuel or attached to any item powered by fuel. FEMA develops equipment rates based on all costs associated with ownership and operation of equipment, with the exception of operator labor. FEMA equipment rate components include depreciation, overhead, equipment overhaul (labor, parts, and supplies), maintenance (labor, parts, and supplies), lubrication, tires, ground engaging component (if applicable), and fuel. Because the rates include maintenance costs, a mechanic’s labor costs to maintain Applicant-owned equipment are not eligible. 

State and Territorial Rates

State and Territorial rates are those established under State or Territorial guidelines for use in normal day-to-day operations. FEMA provides PA funding based on State or Territorial rates up to $75 per hour. FEMA only provides PA funding for a rate above $75 per hour if the Applicant demonstrates that each of the components of the rate is comparable to current market prices.

Tribal Rates

Tribal rates are those developed under Tribal Government guidelines for use in normal day-to¬day operations. FEMA generally provides PA funding for equipment usage based on the lower of either the Tribal rate or the FEMA rate. However, if the Tribal rate is lower, but it does not reflect all of the costs associated with operating the equipment, FEMA may provide PA funding based on the higher FEMA rate. Additionally, if the Tribal rate is higher, the Applicant must document the basis for that rate and obtain approval from FEMA for the higher rate.

If determining the lowest rate for each piece of equipment is overly burdensome because of the number of different types of equipment used, or if the Applicant prefers, FEMA will reimburse all equipment use based on the lower of the two rate schedules, rather than based on a comparison of each individual rate. In these cases, the PA Division at FEMA Headquarters will determine which schedule of rates is lower.

Local Rates

Local rates are those developed under local government guidelines for use in normal day-to-day operations. FEMA generally provides PA funding for equipment usage based on the lower of either the local rate or the FEMA rate. However, if the local rate is lower, but it does not reflect all of the costs associated with operating the equipment, FEMA may provide PA funding based on the higher FEMA rate. Additionally, if the local rate is higher, the Applicant must document the basis for that rate and obtain approval from FEMA for the higher rate.

If determining the lowest rate for each piece of equipment is overly burdensome because of the number of different types of equipment used, or if the Applicant prefers, FEMA will reimburse all equipment use based on the lower of the two rate schedules, rather than based on a comparison of each individual rate. In these cases, the PA Division at FEMA Headquarters will determine which schedule of rates is lower.

Equipment with no Established Rate

If the Applicant uses equipment that has no established State, Territorial, Tribal, or local rate, FEMA reimburses that equipment based on the FEMA rate. If FEMA does not have a rate established for the equipment, the Applicant may either submit a rate for approval or request that FEMA provide a rate. If the Applicant submits a rate, it must include documentation demonstrating that each component of the rate is comparable to current market prices. The rate cannot be based on rental rates as such rates include cost components, such as profit, that are above and beyond what is necessary to operate and maintain force account equipment.

Required Documents

Small and Large Project (based on applicable threshold):

  • Equipment Summary

Cost Summary Template

FEMA Project Worksheet Template (XLS)

Purchased Equipment

There are instances when an Applicant does not have sufficient equipment to effectively respond to an incident. If the Applicant purchases equipment that it justifiably needs to respond effectively to the incident, FEMA provides Public Assistance (PA) funding for both the purchase price and either:

  • The use of the equipment based on equipment rates (without the ownership and depreciation components); or 
  • The actual fuel and maintenance costs.

If equipment has a useful life over a year and a fair market value of $5,000 or more at the end of disaster work activities, disposition requirements will apply.  See “Disposition of Purchased Equipment and Supplies”

Note: The Applicant may want to consider reimbursement using FEMA’s Schedule of Equipment Rates as explained in the previous section instead of claiming the purchase price due to Disposition requirements. An evaluation may be required to determine which method is most beneficial.

Required Documents

Small and Large Project (based on applicable threshold):

  • Invoice Summary
  • Invoices (not required for a small project but recommended)
  • Cost comparison of purchase price vs lease of equipment

Cost Summary Template

FEMA Project Worksheet Template (XLS)

Rental Equipment

When the Applicant leases equipment, FEMA provides Public Assistance (PA) funding based on the terms of the lease. Leasing costs are eligible if: 

  • The Applicant performed an analysis of the cost of leasing versus purchasing the equipment; and 
  • The total leasing costs do not exceed the cost of purchasing and maintaining equipment during the life of the eligible project. 

If the leasing costs exceed the cost of purchasing and maintaining the equipment, FEMA determines the amount of eligible costs based on an evaluation of the reasonableness of the costs claimed, including whether the Applicant acted with prudence under the circumstances at the time it leased the equipment. 

If the Applicant has a lease-purchase agreement and obtains ownership during completion of eligible work, FEMA provides PA funding for the equipment use based on the hourly equipment rate, as described above. 

If the Applicant has a lease-purchase agreement and completes the eligible work prior to obtaining ownership, FEMA provides PA funding based on the cost to lease the equipment.

Required Documents

Small Project (based on applicable threshold):

  • Rental Equipment Summary
  • Invoices (not required but recommended)
  • Cost comparison of leasing equipment vs purchasing

NOTE:  For small projects funded at $500,000 to the current small project threshold, MEMA requires the same documentation as required by FEMA for a Large Project.  It is recommended the documentation be uploaded to Grants Portal when submitting the project for FEMA approval.

Large Project (based on applicable threshold):

  • Rental Equipment Summary
  • Invoices
  • Rental Agreement
  • Cost comparison of leasing equipment vs purchasing

Cost Summary Template

FEMA Project Worksheet Template (XLS)

Contract Work

Refer to Procurement and Contracting Requirements

Required Documents

Small Project (based on applicable threshold):

  • Contract Costs Summary 
  • Invoices (not required but recommended)
  • If Work Completed (damages):
    • Category A – Photos (before and after debris removal)
    • Category B-G – Photos (pre-disaster, if available, damages, and restored)
  • If Work To Be Completed (damages):
    • Category C-G – maintenance records to show facility was properly maintained prior to declared disaster

Note:  For small projects funded at $500,000 to the current small project threshold, MEMA requires the same documentation as required by FEMA for a Large Project.  It is recommended the documentation be uploaded to Grants Portal when submitting the project for FEMA approval.

Large Project (based on applicable threshold):

  • Contract Costs Summary
  • Invoices
  • Contract(s) and Amendments
  • Procurement Policy
  • Proof of proper procurement, if applicable
    • Request for Proposal (RFP)
    • Scoring Sheet
    • Bid Tab
  • If Work Completed (damages):
    • Category A – Photos (before and after debris removal)
    • Category B-G – Photos (pre-disaster, if available, damages, and restored)
    • Category C-G – drawings, permits, engineering reports, etc.
  • If Work To Be Completed (damages):
    • Category C-G – maintenance records to show facility was maintained prior to declared disaster

Cost Summary Template

FEMA Project Worksheet Template (XLS)

Materials / Supplies

The cost of supplies, including materials, is eligible if: 

  • Purchased and justifiably needed to effectively respond to and/or recover from the incident; or 
  • Taken from the Applicant’s stock and used for the incident. 

The Applicant needs to track items taken from stock with inventory withdrawal and usage records. 

FEMA provides Public Assistance (PA) funding for these items based on invoices, if available. If invoices are not available for items used from stock, FEMA provides PA funding based on the Applicant’s established method of pricing inventory. If the Applicant does not have an established method, FEMA provides PA funding based on historical data or prices from area vendors.

Required Documents

Small Project (based on applicable threshold):

  • Materials Summary
    • Note: include in the summary, how each purchased material was used related to the disaster
  • Invoices (not required but recommended)
  • If total purchases from any one contractor exceeds $250,000 across all projects in a given disaster, competitive procurement is required or a cost analysis.

NOTE:  For small projects funded at $500,000 to the current small project threshold, MEMA requires the same documentation as required by FEMA for a Large Project.  It is recommended the documentation be uploaded to Grants Portal when submitting the project for FEMA approval.

Large Project (based on applicable threshold):

  • Materials Summary
    • Note:  include in the summary, how each purchased material was used related to the disaster
  • Invoices
  • Procurement Policy
  • If total purchases from any one contractor exceeds $250,000 across all projects in a given disaster, competitive procurement is required or a cost analysis.

Cost Summary Template

FEMA Project Worksheet Template (XLS)

Management Costs

Applicants may use Force Account Labor or a contracted consultant to formulate and manage Public Assistance (PA) projects.  As well, facilities, equipment or supplies may be required for management of the PA process.  

After all projects have been obligated by FEMA, the Management Costs (Category Z) project can be submitted.  The Applicant is eligible for 5% of the total funds obligated.
Eligible Activities include, but not limited to,:

  • Meetings regarding the PA program or overall PA damage claims:
    • Preliminary Damage Assessments (PDA)
    • Site Inspections
    • Exploratory Call
    • Recovery Scoping Meeting
    • Recovery Transition Meeting
  • Preparing and reviewing PA projects and project applications:
    • Preparing small and large projects
    • Organizing damage sites into logical groups
    • Developing the detailed site-specific damage description
    • Collecting, copying, filing, or submitting documents to support a claim
    • Preparing correspondence
    • Reviewing projects
    • Evaluating Section 406 Hazard Mitigation measures
    • Requesting disbursement of funds
  • Purchasing or renting equipment, software, and supplies used specifically for the PA Program
  • Purchasing or renting facilities or space used specifically for the PA Program
  • Travel expenses relating to documenting damage and developing projects (e.g., site inspections)
  • Training related to PA

Required Documents

Note:  All Management Costs projects are treated as large projects

Force Account Labor

Contracted Services

  • Contract Costs Summary
  • Invoices
  • Contract and Amendment(s)
  • Procurement Policy
  • Proof of proper procurement
    • Request for Proposal (RFP)
    • Bid Tab
    • Scoring Sheet
    • Proposal from selected contractor

FEMA Memo

Simplifying the PA Program Management Costs (PDF)

Training Video

COVID Management Costs
 

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