3. Public Assistance Program and Policy Guide (PAPPG) — version 4
In June 2020, FEMA issued the PAPPG version 4. PAPPG superseded the majority of all prior Public Assistance guidance, and PAPPG version 4 is in effect for incidents declared on or after 1 June 2020.
Version 3.1 incorporated revisions to align with the changes made by the Bipartisan Budget Act, including changes regarding “essential social services” and “essential social-type services,” houses of worship and other private nonprofit educational facilities. Version 4 includes revisions and clarifications relating to administrative requirements, applicant eligibility (specifically for private nonprofit entities), emergency and permanent work eligibility, and cost eligibility.
Also included in this version of the guidance is the Public Assistance Alternative Procedures for Permanent Work Pilot Policy (FP 104-009-7), which establishes Alternative Procedures as the first option considered for all large permanent work projects. This not only enables Applicants to drive their own recovery but also standardizes a single process for the development and consideration of fixed cost estimates for all permanent work projects. Benefits of using this approach include enhanced flexibility in meeting post-disaster recovery needs, no requirement to rebuild community to pre-disaster conditions, shared funds across all Alternative Procedures Permanent Work Projects, and the ability to retain and use excess funds to improve future disaster response.
4. Public Assistance Management Costs Interim Policy (Interim Policy)
On 5 October 2018, as part of the DRRA, FEMA issued the Interim Policy, which redefined management costs. The Interim Policy defines management costs as “indirect costs, direct administrative costs and other administrative expenses associated with a specific project.” The policy is in effect for all major disasters and emergencies declared on or after 1 August 2017. For disasters declared on or after 5 October 2018, all management costs will be processed under the interim policy. For disasters declared between 1 August 2017, and 4 October 2018, Recipients and Subrecipients were required by 15 March 2019, to decide if they wanted to receive costs under the Interim Policy or continue to receive under the existing management costs and DAC policy in effect at the time of disaster (Public Assistance Program and Policy Guide and/or Public Assistance Alternative Procedures for Direct Administrative Costs).
Under the Interim Policy, a Recipient is allowed no more than 12% of the total award, where a maximum of 7% can be used by a Recipient and 5% by a Subrecipient. Costs are funded at 100% federal cost share. Recipients and Subrecipients are required to fully document and demonstrate eligibility and reasonableness of all costs and activities claimed. Section C of the Interim Policy details eligibility and several deadlines to claim the costs. Under the Interim Policy, FEMA bases management costs on the total award amount, which is the actual eligible PA project cost, including the non-federal share, after insurance and any other reductions.
5. Public Assistance Alternative Procedures for Direct Administrative Costs
The DAC Pilot formally ended on 5 October 2018. Version 1.1 of the policy was published on 12 June 2018. It was applicable to incidents declared from 25 August 2017 through 4 October 2018. It was archived on 5 October 2018 upon the discontinuation of the pilot.