Article 60: Disaster Recovery Reform Act of 2018
(Category: emergency-responses)
Article Summary
The DRRA introduced statutory amendments to the Stafford Act to drive national resiliency and streamline grant execution. Key sections include:
- Section 1206 (Code Implementation and Enforcement): Funding for building code and floodplain management ordinance enforcement.
- Section 1207 (Program Improvements): Presumption of reasonableness for engineer-certified cost estimates; bans forced participation in alternative procedures.
- Section 1215 (Management Costs): Expanded definitions and increased reimbursement caps (12% for PA, 15% for HMGP).
- Section 1216 (Statute of Limitations): Recoupment window begins at individual project closeout rather than disaster closeout.
Five Key Takeaways for CTA FEMA Compliance
- Leverage the Certified Engineer Presumption Rule: Mandate that all uncompleted, large project cost estimates are certified by a licensed Professional Engineer to trigger the regulatory presumption of reasonableness.
- Maximize Building Code Enforcement Funding: Track all labor, vehicle, and software expenses incurred by code enforcement officers for post-disaster assessments under Section 1206.
- Observe the 3-Year Project-Specific Recoupment Window: Maintain organized closeout documentation for every project, knowing the 3-year federal clawback statute of limitations starts upon individual project closure.
- Claim the Full 5% Subrecipient Management Cost Allowance: Capture both direct project management tracking and indirect administrative overhead up to the expanded 5% subrecipient cap.
- Reject Mandatory Participation in Alternative Procedures Pilot Programs: Exercise your legal right to opt out of voluntary Section 428 Alternative Procedures caps if standard, flexible cost estimating serves your infrastructure better.
