Administrative costs related to managing the PA Program and PA projects, if tracked, charged, and accounted for directly to a specific eligible project, are eligible as DAC. PM activities, such as procurement, document review, and construction oversight, are eligible provided the activities are tracked and directly related to a specific, eligible project. Engineering and design services and construction inspection are also eligible provided the services are necessary to complete eligible work. To be eligible, all costs must be adequately documented and reasonable. The Applicant provided inconsistent descriptions of its contractor’s services and did not separately identify or distinguish DAC from engineering and design, PM, or insurance claim support costs referenced throughout the appeal process.

The Applicant has not separately identified or distinguished DAC from engineering and design, PM, or insurance claim support costs. Therefore, the Applicant has not demonstrated the costs are reasonable or otherwise eligible as DAC, and the Applicant’s second appeal is denied.

PAPPG, at 21, 36-37, 39. Cameron Parish Sch. Bd., FEMA-1607-DR-LA, at 3-4.