The eligibility of premium pay costs is based on the applicant’s predisaster written labor policy, provided the policy meets certain FEMA criteria. The Applicant has not demonstrated it provided premium pay in accordance with a predisaster written labor policy that meets FEMA requirements. Section 705(c) of the Stafford Act provides that a state or local government is not liable for reimbursement or any other penalty for any payment made pursuant to the Stafford Act if the payment was authorized by an approved agreement specifying the costs. Section 705(c) of the Stafford Act does not apply to PNPs.

FEMA finds the FEMA finds the claimed premium pay costs were not provided under a labor policy that meets FEMA policy requirements. In addition, section 705(c) of the Stafford Act does not apply. Therefore, this appeal is denied.

Stafford Act §§ 403(a)(3), 705(c). 2 C.F.R. § 200.403(g); 44 C.F.R. §206.225(a)(1). PAPPG, at 21, 23-24, 133. FP 205-081-2, at 1; FP 104-21-0004, at 4. Ore. Shakespeare Festival Ass’n, FEMA-4499-DR-OR, at 3, Maple Grove Hospital Corp., FEMA-4531-DR-MN, at 4.