Chapter 6: Cost Eligibility
Project Management and Design Services
2 CFR 200.403

Article 5: Engineering and Design Services

(Category: costs-eligilbilty)

Article Summary

Engineering and design services required to execute eligible disaster recovery projects qualify for Public Assistance. For grant development, these professional fees are categorized into three areas:

  • Basic Engineering Services: Performed by architectural-engineering (A&E) firms, this covers standard project phases including preliminary engineering analysis, final design, and construction inspection. For large projects, FEMA typically estimates these costs using a set percentage of the total construction cost based on industry curves. For complex facilities, FEMA can issue an initial standalone design grant, allowing the applicant to complete blueprints before building a separate construction grant from the finished design.
  • Special Services: This covers highly technical, site-specific needs not universally required, such as engineering surveys, soil/geotechnical investigations, or retaining a resident engineer. These services must be explicitly detailed and justified to be added to a Project Worksheet.
  • Construction Inspections: Certain projects do not require formal design engineering but demand full-time construction inspection due to unusual project dynamics (verifying complex material qualities, checking technical specifications, and reviewing shop drawings). If a clear need is substantiated upfront, FEMA can authorize an inspection grant capped at 3% of the total estimated construction cost.

As a general rule, engineering and design estimates are excluded from small project worksheets unless the work is uniquely complex or requires specialized technical intervention.

Five Key Takeaways for CTA FEMA Compliance

  1. Utilize Staged Grants for Complex Sites: For heavily compromised infrastructure, request an initial standalone engineering grant to design the facility first, ensuring a precise scope of work is established before seeking a follow-on construction grant.
  2. Separate and Itemize Special Technical Services: Fully isolate and individually document any non-standard "Special Services"—such as soil or geotechnical investigations and site surveys—and list them independently on the project worksheet rather than blending them into basic construction costs.
  3. Adhere to the 3% Cap on Standalone Inspections: When proposing full-time construction inspection services for projects lacking formal engineering designs, ensure the claimed budget does not exceed the strict regulatory cap of 3% of the total construction cost.
  4. Enforce Strict Document Standards for Small Project Exceptions: Since small projects typically exclude engineering fees, you must provide explicit, documented justification (such as proving the absolute necessity of a structural analysis) to secure design cost eligibility.
  5. Reconcile Final Procurement with FEMA Percentages: Ensure that A&E contracts are procured competitively in accordance with federal grant regulations, and map the contracted fees carefully against the percentage-of-construction cost curves used by FEMA to verify cost reasonableness.