Failure to complete a project’s approved SOW may result in the deobligation of funds and require that the Federal payment be refunded. The documentation, including the Applicant’s acknowledgement, shows it did not complete the approved SOW, and therefore, FEMA’s deobligation of funding was proper. FEMA is barred from recovering payments made for a project if all three conditions of Stafford Act section 705(c) are met, including the requirement that the purpose of the grant was accomplished. The Applicant did not complete the approved SOW. Therefore, the purpose of the grant was not accomplished, and section 705(c) does not bar the recovery of funding. FEMA must provide notice of its intent to recover payments made to a recipient and/or an applicant within three years from the date that project completion certification is submitted. However, an RFI will pause the 3-year statute of limitations. Because FEMA transmitted an RFI within the three-year time period, Stafford Act section 705(a) does not prohibit the recovery of funding.

The Applicant has not demonstrated it completed the project’s approved SOW. In addition, FEMA properly deobligated funding and is not barred by Stafford Act section 705 from recovering the previously awarded funding. Therefore, this appeal is denied.

Stafford Act § 705(a), (c). 44 C.F.R. §§ 13.43; 206.205(a). FP 205-081-2, at 1, 2, 5; PA Guide 96, 109.