Procurement & Contracting

Small projects need an itemized summary by contractor. Large projects need the full procurement file plus invoices, and time-and-materials contracts need proof of close oversight.

Pre-positioned (standby) contracts work if they were competed under federal rules and cover the work performed. FEMA advises against cooperative purchasing and piggyback contracts because they often fail federal procurement requirements.

FEMA reimburses fixed-price and cost-reimbursement contracts, and time-and-materials contracts only in limited cases. Cost-plus-percentage-of-cost and percentage-of-construction pricing is prohibited.

Yes, but only under one of four circumstances, only for work tied to that circumstance, and only while it lasts. Start a competitive procurement right away and move to a competed contract as soon as the emergency or exigency ends.

States, territories and tribes follow the same procurement policies they use with their own funds, plus the EPA recovered-materials rule, and must include the required federal contract clauses in every contract.

You must follow your own written procurement procedures, your state and local laws, and the federal rules in 2 CFR 200.318–200.327, using whichever is most restrictive. If you don’t comply, FEMA can deny all contract costs or pay only the portion it finds reasonable.

2 CFR 200.320

2 CFR 200.318

Stafford Act Section 406

Procurement mistakes can turn otherwise eligible FEMA PA work into unreimbursed local costs. This Govstar resource explains how SLTT applicants can protect disaster funding by following 2 CFR Part 200 procurement rules from solicitation through closeout. Topics include state vs. local/PNP standards, full and open competition, socio-economic contracting steps, independent cost estimates, SAT thresholds, sealed bids, competitive proposals, sole-source limits, emergency/exigency justifications, required contract clauses, CPPC prohibitions, T&M/T&E limits, cost or price analysis, procurement histories, OIG audit risk, and FEMA enforcement remedies. **Character count:** ~675 characters.

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When conducting procurement transactions under a Federal award, a State or Indian Tribe must follow the same policies and procedures it uses for procurements with non-Federal funds. If such policies and procedures do not exist, States and Indian Tribes must follow the procurement standards in §§ 200.318 through 200.327. In addition to its own policies and procedures, a State or Indian Tribe must also comply with the following procurement standards: §§ 200.321, 200.322, 200.323, and 200.327. All other recipients and subrecipients, including subrecipients of a State or Indian Tribe, must follow the procurement standards in §§ 200.318 through 200.327.

Procurement mistakes can turn otherwise eligible FEMA PA work into unreimbursed local costs. This GovStar resource, updated for FEMA's FY 2026 Procurement Under Grants Policy Guide, explains which rules apply by declaration date, the $15,000 and $350,000 thresholds, state vs. local and nonprofit standards, full and open competition, socio-economic contracting steps, independent cost estimates, sealed bids, proposals, sole-source limits, emergency and exigency justifications, required contract clauses, CPPC and T&M limits, procurement records and FEMA remedies.

Emergency procurement can protect lives after a disaster—but it can also put FEMA reimbursement at risk if the record is weak. This Govstar resource explains when exigency or emergency circumstances allow noncompetitive “sole-source” contracting and what rules still apply. Topics include state vs. non-state procurement standards, 2 CFR Part 200, FEMA/OIG review, written justifications, cost or price analysis, required contract clauses, responsible contractors, bonding, T&M limits, CPPC prohibitions, piggyback contracts, transition to competition, conflicts of interest, and documentation needed to defend reimbursement.

Federal procurement standards for grant-funded disaster recovery contracts and compliance requirements.

How SLTT applicants protect disaster funding by following 2 CFR Part 200 procurement rules.

Contract types, payment rules, and compliance requirements for states, tribes, local governments, and nonprofits.

Force account labor rules, cost reasonableness analysis, 2 C.F.R. procurement standards, and duplication of benefits.

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Summarizes changes to federal procurement standards and explains how requirements differ among states, territories, Indian Tribes, local governments, and nonprofits.

Guides FEMA grant recipients and subrecipients understand which federal contract provisions are required under 2 C.F.R. § 200.327, Appendix II to Part 200. Includes sample language and FEMA-recommended contract provisions.

Explains federal procurement standards under FEMA awards, with entity-specific requirements, procurement procedures, contract provisions, and compliance checklists.

Summary

Summary

Review FEMA Public Assistance procurement and contracting requirements, including competition, procurement method, contract type, cost reasonableness, change orders, and required federal contract provisions.