For the COVID-19 pandemic, FEMA issued the COVID-19 Programmatic Deadlines Policy to establish PA programmatic deadlines across all COVID-19 declarations. This policy requires that applicants and recipients submit all RPAs to FEMA no later than July 1, 2022. However, FEMA may extend the RPA deadline when the request is justified based on extenuating circumstances beyond the applicant’s or the recipient’s control. The Applicant’s letter and Recipient’s RPA submittal occurred more than a year after the Applicant received the Certificate of Incorporation dated November 21, 2021, and approximately 10 months after the Applicant received the IRS letter granting it 501(c)(3) status, on July 7, 2022. Additionally, because the Applicant states it was conducting COVID-19 work as early as January 2020, the example extenuating circumstance listed in the COVID-19 Programmatic Deadlines Policy does not apply.

The Applicant has not demonstrated extenuating circumstances beyond its or the Recipient’s control to justify extending the RPA deadline.

44 C.F.R. §206.202(c), §206.202(f)(2). PAPPG, at 130. Programmatic Deadlines Policy, at 1 and 3.