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PAPPG v5.0 · Appendix L · pages 319–321

Validation of Applicant-Provided Cost Estimates

The checklist FEMA staff must use to review your cost estimate for a large permanent work project. Knowing it lets your engineer or estimator build an estimate that passes the first time: who must prepare and certify it, which cost data sources are acceptable, what each unit cost must include, and the 10 percent reasonableness test.

3 topicsRequired for large permanent workUnit costs, not lump sumsLargest items within 10%
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Appendix L › Step 5 Validate Completeness and Reasonableness

How does FEMA decide whether our estimate’s costs are reasonable?

Validating completeness and reasonableness (10 percent test)
p. 321
Short answer
FEMA samples the estimate. At least six of the ten largest cost items, and at least 25 percent of the rest, must each be within 10 percent of local weighted average unit prices or industry cost data. FEMA also checks that every activity has a unit cost (no lump sums), the right locality factors are applied, and every item is eligible. Failing items send the estimate back for revision.
What FEMA requires
  • FEMA checks a representative sample for reasonable costs. Unreasonable items send the estimate back for revision.
  • All items must be eligible; FEMA removes ineligible items and documents why.
  • All work activities must be quantified with unit costs. Lump sums that need to be converted to unit prices send the estimate back.
  • The correct locality adjustment factor from the cost publication must be applied to each line item. Where historical costs were used, no locality adjustment is applied, but escalation factors are added.
  • Cost items are checked against local weighted average unit prices or industry cost data: at least six of the ten largest items (or all items if fewer than ten), individually, and at least 25 percent of the rest must be within 10 percent. If not, the estimate is returned for revision.
  • The reviewer records the review date, any information requests, and signs the checklist.
<table class="pt-table"><thead><tr><th>Check</th><th>Pass</th></tr></thead><tbody><tr><td>Largest items</td><td>At least six of the ten largest cost items (or all, if fewer than ten), each within 10% of local weighted average unit prices or industry cost data</td></tr><tr><td>Remaining items</td><td>At least 25% of the remaining items within 10%</td></tr><tr><td>Unit pricing</td><td>All work activities quantified with unit costs, no lump sums</td></tr><tr><td>Locality</td><td>Correct locality factor applied to published costs; for historical costs, no locality factor but escalation added</td></tr><tr><td>Eligibility</td><td>Every item of work is eligible</td></tr></tbody></table>
Documentation

Backup for your largest cost items, local weighted average unit prices or cost data references, the locality adjustment factors used, and escalation factors where you used historical costs.

Watch out · Govstar advice
Put your best backup behind the ten largest line items, since that is where FEMA looks hardest. If you used historical costs, add escalation and don’t also apply a locality factor; mixing the two is a common error the checklist catches.
PAPPG v5.0 p. 321 · Appendix L step 5
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Appendix L › Steps 3–4 Cost Sources; Unit Cost Components

Which cost data sources does FEMA accept, and what must each unit cost include?

Approved cost data sources; components of unit costs
pp. 319–321
Short answer
Current editions of industry-standard cost data (RSMeans, Xactimate, BNi, Marshall & Swift, Sweet’s and similar), local cost data, or unit costs from recently completed contracts. Each unit cost must be a complete in-place cost covering labor, equipment, materials, small tools, incidentals and hauling, and overhead, profit, surveying, inspection and permit fees must not be counted twice.
What FEMA requires
  • Step 3: FEMA determines whether unit costs come from an approved industry-standard source and whether current publications were used. If not, the estimate is returned for revision.
  • Step 4: FEMA checks the components of the unit costs. Each unit cost should be a complete, in-place cost including all labor, equipment, materials, small tools, incidentals and hauling for that element of work.
  • FEMA checks whether general contractor and subcontractor overhead and profit are included in the unit costs and not duplicated elsewhere in the estimate or in the Cost Estimating Format, or whether they are duplicated.
  • Surveying, construction inspection and permit compliance fees must not appear both within a unit cost and separately.
  • If there isn’t enough information on unit cost components, FEMA requests more from you.
<table class="pt-table"><thead><tr><th>Acceptable sources</th></tr></thead><tbody><tr><td>RSMeans</td></tr><tr><td>Xactimate</td></tr><tr><td>BNi Costbooks</td></tr><tr><td>Marshall &amp; Swift</td></tr><tr><td>Sweet’s Unit Cost Guide</td></tr><tr><td>Other industry standard construction cost resources</td></tr><tr><td>Local cost data</td></tr><tr><td>Contract unit costs from recently completed projects</td></tr></tbody></table>
Documentation

The name and edition of the cost data source used, local cost data or recent contract unit prices if used, and a breakdown showing what each unit cost includes and where overhead, profit, surveying, inspection and permit fees appear.

Watch out · Govstar advice
Double-counted overhead and profit is a classic reason estimates come back. If O&P is already in the unit prices, say so clearly and don’t add it again as a line item or in the CEF.
PAPPG v5.0 pp. 319–321 · Appendix L steps 3–4
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Appendix L › Steps 1–2 Verify the Estimate; Eligible Items Only

What does FEMA check first when it reviews our cost estimate?

Validation of applicant-provided cost estimates: initial verification
p. 319
Short answer
FEMA staff must use the Appendix L checklist for large permanent work estimates. First they confirm a licensed engineer, architect or certified cost estimator prepared and certified it, that it uses unit costs rather than lump sums, and that it is detailed enough to match the scope. Then they check that every item is required by the agreed damage, removing or returning anything ineligible.
What FEMA requires
  • FEMA PA staff must use this checklist to review applicant cost estimates for large permanent work projects, and may use parts of it for emergency work.
  • Step 1: verify the estimate is prepared by a licensed professional engineer or other estimating professional (licensed architect or certified professional cost estimator) who certifies it follows industry standards; certifies the cost directly corresponds to repairing the agreed damage; is based on unit costs for each scope component, not a lump sum; and is detailed enough to validate every component against the agreed scope.
  • Step 2: verify only eligible items are included, based on the agreed damage description and dimensions. If ineligible items are found, FEMA removes them and documents why, or returns the estimate to you to revise.
<table class="pt-table"><thead><tr><th>Step</th><th>FEMA verifies</th><th>If not met</th></tr></thead><tbody><tr><td>1. Preparer and certification</td><td>Licensed PE, licensed architect or certified cost estimator certifies it meets industry standards and matches the agreed damage</td><td>Estimate not accepted</td></tr><tr><td>1. Format</td><td>Unit costs for each scope component, not lump sums, with enough detail to match the scope</td><td>Returned for revision</td></tr><tr><td>2. Eligible items</td><td>Every scope item is required by the agreed damage description and dimensions</td><td>FEMA removes ineligible items with an explanation, or returns the estimate</td></tr></tbody></table>
Documentation

A signed estimate from a licensed professional engineer, licensed architect or certified professional cost estimator, with a certification that it follows industry standards and corresponds to the agreed damage; unit costs for each scope component; and the agreed damage description and dimensions.

Watch out · Govstar advice
Ask your estimator to build the estimate to the Appendix L checklist from the start. An estimate that fails step 1 never gets to the reasonableness review and simply comes back.
PAPPG v5.0 p. 319 · Appendix L steps 1–2
Read this in the PAPPG
Govstar summarizes FEMA’s Public Assistance Program and Policy Guide, version 5.0 Amended, for disasters declared on or after January 6, 2025. “Watch out” notes are Govstar practitioner advice, not FEMA policy. Govstar is independent and not affiliated with FEMA. This is general guidance, not legal advice.