Under DAP 9525.9, FEMA will reimburse applicants and grantees for reasonable administrative activities if the costs are properly tracked, documented, and directly chargeable to a Project Worksheet (PW). The Applicant’s generic task descriptions do not allow FEMA to evaluate whether its costs are reasonable and related to eligible direct administrative activities that benefitted only a single PW. DAP 9525.9 requires grantees and applicants to provide detailed information about each activity or task performed so that FEMA may evaluate the following factors to determine whether the costs are reasonable, necessary, and appropriate: (1) methods of contracting for the services, (2) the skill level of persons performing the activities, and (3) the amount of time required to perform an activity. The Applicant’s cost descriptions do not allow FEMA to determine what specific administrative tasks its consultant performed, nor whether the costs charged for those tasks were reasonable, necessary, and appropriate. Travel that benefits more than one project is not an eligible DAC even if an applicant only charges the costs to one PW. The Applicant’s travel cost descriptions do not allow FEMA to determine whether the travel benefitted only a single PW.

The Applicant’s claimed costs are not eligible DAC because the Applicant did not provide documentation demonstrating the costs are reasonable, necessary, appropriate, and chargeable to a single PW.

Disaster Assistance Policy DAP 9525.9, Section 324 Management Costs and Direct Administrative Costs (Nov. 13, 2007); Memorandum from FEMA Assistant Administrator, Disaster Assistance Directorate, to Regional Administrators (Sept. 8, 2009) North Dakota Dep’t of Emergency Servs., PW 4905, FEMA-1981-DR-ND (Jan. 12, 2018);