Federal procurement standards prohibit the use of the CPPC method of contracting. Contractor’s markups in the Belfor contract were determined using a prohibited CPPC method in violation of federal procurement standards. The associated costs are ineligible. Among other criteria, costs must be necessary and reasonable to be considered allowable under the Public Assistance (PA) grant program. Costs for meals invoiced by Belfor are ineligible duplicate costs. On first appeal, FEMA determined allowable costs in accordance with the RA’s enforcement authority. If FEMA determines that the purpose of the grant was not accomplished, or that an applicant did not incur reasonable costs, Stafford Act Section 705(c) does not apply. The use of CPPC provisions in the Belfor contract meant that the purpose of the grant was not accomplished. Additionally, the duplicate costs for employee meals are not reasonable. Therefore, Section 705(c) does not apply.

The Applicant’s contract with Belfor utilized prohibited CPPC provisions to determine contractor’s markups for some items. Associated costs totaling $111,445.61 are ineligible. Additionally, meal expenses totaling $12,561.45 are ineligible because they are duplicate costs and therefore not reasonable. Finally, Stafford Act Section 705(c) does not prevent FEMA from recouping PA funding. Therefore, this appeal is denied.

Stafford Act § 705(c). 2 C.F.R. §§ 200.323(d), 200.338, 200.403(a), 200.404. PAAPG, at 30, 63. FP 205-081-2, at 6. Collier (County), FEMA-4337-DR-FL, at 3-4.