FEMA only provides assistance to eligible applicants. Payment to an ineligible applicant is considered an improper payment of federal funds. To be an eligible PNP applicant, an organization must show that it has a current and effective ruling letter from the U.S. Internal Revenue Service granting tax exempt status or documentation substantiating that it is a nonprofit entity organized or doing business under state law. Although eligible at the time of the application for funding, the applicant’s inability to meet the requirements at the time of the award approval and obligation makes the applicant ineligible for FEMA funding and any funding, if granted, constitutes an improper payment of federal funds.

St. Luke’s is not eligible for PA funding because it is not currently a tax-exempt PNP doing business in the state of Ohio and does not own or operate an eligible PNP facility. Because St. Luke’s is not an eligible applicant, any assistance would be an improper payment of federal funds. Therefore, St. Luke’s consolidated appeals are denied.

Stafford Act §§ 102, 403. 2 C.F.R. § 200.53; 44 C.F.R. §§ 206.221(e), (f), 206.222, 206.223(a), 206.225(a). PAPPG, at 9-11.