To be eligible, costs must be directly tied to the performance of eligible work and adequately documented. For the COVID-19 pandemic, FEMA established December 31, 2022, as the deadline to identify and report all emergency work activities performed through July 1, 2022. The Applicant submitted additional costs associated with eligible work performed after March 30, 2022, which was during the approved timeframe of the project’s scope of work. The remainder of the Applicant’s claimed costs are for work performed before that date, and the Applicant did not report the work until after the reporting deadline.

The Applicant incurred an additional $114,137.48 associated with the project’s approved scope of work. This additional cost is eligible for reimbursement because it is associated with previously approved work and within the project’s approved timeframe. The remainder of the Applicant’s claimed costs are associated with work performed outside of the project’s approved scope of work timeframe. The Applicant did not report the additional work until after the December 31, 2022, work reporting deadline and did not demonstrate that there were extenuating circumstances beyond its control to justify the scope of work amendment and extending the deadline. Therefore, this appeal is partially granted.

Stafford Act § 403(a)(3); 44 C.F.R. § 206.225(a)(1). PAPPG, at 21. Programmatic Deadlines Policy, V.3, at 1-2, 4, 5; Medical Care Policy, at 3-4. Oregon Shakespeare Festival Ass’n, FEMA-4499-DR-OR, at 2.