FEMA provides PA funding for administrative costs related to managing the PA Program and PA projects. If an applicant tracks, charges, and accounts for these costs directly to a specific eligible project, the costs are eligible as DAC. DAC requested for time spent developing information for a financial audit is not eligible, as that work was not in direct support of the development of this specific project, even if the work may have led to the development of a version request for this project. The full amount of DAC reduced based on excessive rates charged is not eligible; a subject matter expert rate was not reasonable because this project involved contents damage and did not require the work of specialized experts, and time spent organizing files at a rate above the administrative rate was not reasonable. However, time spent developing contents spreadsheets serving as PW 1165’s scope of work was billed at a reasonable rate for the task, and the reduced rate for that work was not warranted. DAC requested for the time spent organizing emails is eligible, though at a lower hourly rate, as this work involved hundreds of emails concerning 13 different sites. DAC requested for a conversation addressing documenting contents procurement is eligible, as the conversation addressed eligibility for this specific project.

The Applicant has not demonstrated its audit work is eligible DAC. However, the Applicant has demonstrated that its procurement conversation work and the email organization work are eligible DAC, as well as a portion of the DAC previously reduced based excessive rates. As such, this appeal is partially granted in the amount of $3,733.75.

Stafford Act § 324. PAPPG, at 37-38.