Appeals & Arbitration

Determinations, RFIs, first and second appeals, CBCA arbitration, and OIG and GAO oversight.

When you disagree with a FEMA decision, the appeal process and deadlines decide whether you can recover the funding. This center covers FEMA determinations and requests for information, first and second appeals, arbitration before the Civilian Board of Contract Appeals, and how audits by the OIG and GAO fit in.

Start here: calendar the appeal deadline as soon as you receive a determination; it is short. Then search past second appeal decisions on the same issue to see how FEMA has ruled.

Start with these guides and tools

The rules

What the PAPPG requires, in plain language.

Insurance, appeals and audits for alternative procedures

Generally no appeals. FEMA only hears appeals of cost adjustments made after you accept the offer, such as for insurance, noncompliance or audits, and not appeals of denied extensions to accept an offer. The obtain-and-maintain insurance requirement still applies, and the DHS Inspector General can audit any alternative procedures project.

Arbitration before the Civilian Board of Contract Appeals

Yes, if more than $500,000 is in dispute ($100,000 in rural areas), you filed a timely first appeal, and FEMA denied it or didn’t decide within 180 days. You choose arbitration or a second appeal, not both, and the Civilian Board of Contract Appeals (CBCA) decision is final.

Appeal deadlines and decisions

You have 60 days from the date FEMA transmits a determination or first appeal decision to file with the recipient. The recipient has 120 days from that same date to forward it to FEMA with its recommendation. Miss either deadline and FEMA denies the appeal as untimely.

Appeal rights and what an appeal must contain

Yes. You can appeal any FEMA determination on your application, including eligibility denials and denied time extensions. The first appeal goes through the recipient to the Regional Administrator; a second appeal goes through the recipient to the Assistant Administrator for Recovery at FEMA Headquarters.

Requests for information (RFIs) and determination letters

FEMA asks for missing information through a request for information (RFI) with a deadline of at least 15 days. Miss it without an approved extension and FEMA denies whatever it couldn’t verify. Any denial comes as a determination memo explaining what was denied, why, and how to appeal.

Key takeaways

Short explainers with the points that matter most.

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

2 CFR 200.403

Part 200 - Uniform Administrative Requirements, Cost Principles, & Audit Requirements

2 CFR 200.403

Appeal Process

44 CFR 206.206

Deep dives and briefings

Longer analysis, practitioner briefings and technical notes.

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Eligibility & Appeal Rights Framework

Master the PA eligibility pyramid, RFI deadlines, two-tiered appeals, and CBCA arbitration thresholds.

Questions people ask

Practitioner answers to common questions.

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FEMA policies and guides

The official FEMA documents behind this subject.

PA Recovery of Improper Payments Standard Operating Procedure

Describes notices, corrective action, deobligation, debt recovery, appeal rights, and collection limits for specified improper-payment audit findings.

Public Assistance Arbitration Fact Sheet

Summarizes CBCA arbitration eligibility, filing deadlines, and the relationship between arbitration and the first-level PA appeal process.

Public Assistance Appeals Fact Sheet

Summarizes the two-level PA appeal process, determination notices, filing deadlines, required appeal content, review steps, and final agency decisions.

Public Assistance Appeals and Arbitration

Defines requirements for appealing PA determinations and requesting Stafford Act Section 423 arbitration, including submission procedures and applicable declaration dates.

Laws and regulations

Stafford Act sections and federal regulations, summarized.

Subpart F: Audit Requirements

Subpart F governs the "Single Audit" process, the final gatekeeper for grant closure. It requires entities expending more than $1,000,000 (updated threshold) in federal funds to undergo an independent audit of their financial statements and compliance. CFOs are responsible for the accuracy of the SEFA and the swift resolution of any findings to prevent "high-risk" status in future disasters.

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Resource hubs and navigators

Curated paths through related material.

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Appeals, RFIs & Funding Defense

Respond to FEMA determinations, Requests for Information, cost denials, eligibility disputes, insurance reductions, procurement findings, closeout issues, and appeal deadlines with a defensible record.

Related subject centers

GovStar is independent and not affiliated with FEMA. Summaries are educational, not legal advice; always confirm against the current PAPPG and your FEMA and state contacts.