To be eligible, costs must be, among other requirements, necessary and reasonable to accomplish the work properly and efficiently. The Applicant did not provide information showing how it evaluated the NCS options, nor show how it analyzed the population data presented. The Applicant did not explain how it assessed COVID-19 information at the time the decision was made to continue the lease for all rooms in the EconoLodge in order for FEMA to determine that the number of NCS rooms were reasonable and necessary to shelter the portion of the population identified as potentially requiring NCS.

FEMA finds that the Applicant did not demonstrate that the additional NCS costs were reasonable and necessary to address the public health needs of the COVID-19-declared event. Therefore, this appeal is denied.

Stafford Act § 403. 2 C.F.R. §§ 200.403(g); 200.404; 44 C.F.R. §§ 206.223(a)(1), 206.225(a)(3)(i). PAPPG, at 19, 21, 22, 57, 66, 163. NCS Delegation of Authority Fact Sheet,FEMA FAQ Non-Congregate Sheltering.