Public Assistance Alternative Procedures for Direct Administrative Costs Policy Version 1.1 permits excess DAC funds to be used for any costs otherwise eligible, if the applicant identifies the excess funds and submits the request to use the funds to FEMA within 180 days of the latest project POP. Under this policy, FEMA defines the end of the DAC PW POP as equal to the latest Category A-G PW POP. The POP for PW 4 ended on October 8, 2018. This means April 6, 2019, 180 days later, was the deadline for submitting a request to use excess DAC. The Grantee submitted its request to use excess DAC funds on August 20, 2019, after the deadline had passed.

The Grantee submitted its request to use excess DAC more than 180 days after the POP of its latest Category A-G PW; therefore, the request was untimely. The appeal is denied.

Stafford Act § 428(e)(1)(B)(ii). PAAPDAC, Version 1.1, at 6-7.