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Home / Laws & Policy / PAPPG Explorer / Chapter 9
PAPPG v5.0 · Chapter 9 · pages 227–233

Scoping, Costing, and Final Reviews

How damage turns into a funded project: writing the scope of work, the minimum, small and large project thresholds, expedited funding for emergency work, funding completed and unfinished work, whose cost estimate FEMA uses, and the reviews before FEMA obligates the money. Every section is written as the question applicants actually ask, with FEMA’s requirements, the records you need, and the exact PAPPG pages.

7 topicsSmall vs. large: thresholds set each fiscal yearExpedited: request within 60 days of the scoping meetingEstimates on unit costs, not lump sums
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Chapter 9 › III–IV Compliance Reviews; Obligation

What reviews happen before FEMA obligates the money, and how do we get paid?

Compliance reviews; obligation; strategic funds management
p. 233
Short answer
FEMA reviews each project for quality assurance, insurance, hazard mitigation and environmental and historic compliance, then obligates the federal share to the recipient (your state, tribe or territory), which passes it to you. For permanent work projects over $1 million that won’t need money for more than 180 days, FEMA obligates on your project schedule instead of all at once.
What FEMA requires
  • FEMA conducts compliance reviews for quality assurance, insurance requirements, PA hazard mitigation eligibility and EHP compliance.
  • FEMA obligates the federal share of the eligible cost to the recipient. Once obligated, the project is the official record of the approved scope of work.
  • FEMA’s authority to fund small projects as a lump sum on an estimate does not require recipients to pay them the same way. Recipients spend and account for the award under their own laws and procedures.
  • Strategic funds management: if a permanent work project is over $1 million and you will not need funds for more than 180 days after it is ready for obligation, FEMA obligates based on the project completion schedule.
  • The recipient must notify you that funds are available and distribute them to you.
Documentation

Your project completion schedule (needed for strategic funds management on permanent work projects over $1 million), and the recipient’s notice that funds are available.

Watch out · Govstar advice
Obligation is not payment. The money sits with the recipient, which pays you under its own rules and timelines. Ask early how your recipient handles reimbursement requests and advances.
PAPPG v5.0 p. 233 · 44 CFR 206.200(b)(2), 206.202(e) · 2 CFR 200.302 · FEMA SOP 9570.24
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Chapter 9 › II.E.2–4 Applicant Estimates; FEMA Estimates; Insurance Reductions

Will FEMA accept our own cost estimate, and how does FEMA build its own?

Applicant-submitted estimates; FEMA estimates (Cost Estimating Format); insurance reductions
pp. 232–233
Short answer
Yes, if a licensed engineer, architect or certified cost estimator prepares it on unit costs (not a lump sum), certifies it matches the agreed damage, and it is detailed and reasonable. When FEMA writes the estimate for a large permanent work site less than 90 percent complete, it uses the Cost Estimating Format (CEF). Either way, FEMA reduces the estimate for actual or expected insurance proceeds.
What FEMA requires
  • FEMA accepts an applicant estimate that meets all the criteria in the table. Include foreseeable contingency costs such as security and staging.
  • FEMA evaluates applicant estimates for reasonableness under the reasonable cost criteria in Chapter 6.
  • For permanent work sites less than 90 percent complete with total costs expected to meet the large project threshold, FEMA uses the Cost Estimating Format under the CEF Instructional Guide, which sets factor ranges. Only FEMA Headquarters can approve factors outside those ranges or additional factors.
  • For capped projects (improved and alternate projects), FEMA includes only the CEF contingency factor “Applicant Reserve for Change Orders,” with no other factors or risk premiums.
  • FEMA reduces the estimate for insurance: actual proceeds if known, otherwise anticipated proceeds under your policy.
<table class="pt-table"><thead><tr><th>FEMA accepts your estimate if it…</th><th>Required?</th></tr></thead><tbody><tr><td>Is prepared by a licensed PE, licensed architect or certified professional cost estimator who certifies it meets industry standards</td><td>Yes</td></tr><tr><td>Certifies the cost corresponds directly to repairing the agreed damage</td><td>Yes</td></tr><tr><td>Uses unit costs for each scope component, not a lump sum</td><td>Yes</td></tr><tr><td>Is detailed enough for FEMA to match every component to the scope</td><td>Yes</td></tr><tr><td>Reflects the current design or construction phase and known costs</td><td>Yes</td></tr><tr><td>Includes actual costs for work already completed</td><td>Yes</td></tr><tr><td>Is reasonable</td><td>Yes</td></tr></tbody></table>
Documentation

A unit-cost estimate signed by a licensed professional engineer, licensed architect or certified professional cost estimator, with a certification that it was prepared to industry standards and corresponds directly to repairing the agreed damage; the current design or construction phase and known costs; actual costs for work already done; and your insurance policies and any proceeds.

Watch out · Govstar advice
A lump-sum estimate is the quickest way to have yours rejected. Build in foreseeable contingencies such as security and staging, because FEMA judges reasonableness line by line under the Chapter 6 reasonable cost rules.
PAPPG v5.0 pp. 232–233 · CEF Instructional Guide
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Chapter 9 › II.D–E Estimating Emergency and Permanent Work to Be Completed

How does FEMA estimate work that isn’t finished yet?

Estimating emergency and permanent work projects with work to be completed
pp. 231–232
Short answer
For permanent work, FEMA estimates the cost to restore the facility to its pre-disaster design and function, including eligible codes and standards and a reasonable amount for soft costs, but nothing that is only triggered by changing the design or function. Emergency response work is harder to estimate, and FEMA funds it on an estimate only if you provide enough information.
What FEMA requires
  • Emergency work: except for debris removal and emergency repairs, the detailed scope is often unknown in advance and lacks unit pricing. FEMA may fund it on an estimate if you provide enough information.
  • Permanent work: funding is based on the estimated cost to restore the facility to its pre-disaster design and function, including eligible codes and standards.
  • The estimate may include a reasonable amount of anticipated soft costs. The PAPPG lists engineering and design, EHP compliance, and work required by codes or standards you identify and FEMA verifies.
  • It does not include costs only related to, or only triggered by, changes to the pre-disaster design or function.
  • If FEMA writes the scope, it also writes the cost estimate.
  • If engineering analysis is needed to determine the repair method, FEMA funds engineering and design services when you request them.
Documentation

For emergency work: enough detail on planned activities, durations and resources for FEMA to accept an estimate. For permanent work: the agreed damage description, the method of repair, the codes and standards that apply, and any engineering analysis needed to choose the repair method.

Watch out · Govstar advice
Soft costs such as design and environmental compliance are part of the estimate, so ask for them. If the repair method isn’t clear, request engineering and design funding up front rather than accepting a guessed scope.
PAPPG v5.0 pp. 231–232
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Chapter 9 › II.C Costs for Projects with All Work Completed

How does FEMA fund a project when the work is already finished?

Projects with all work completed
pp. 230–231
Short answer
For a completed large project, FEMA funds actual costs, and denies any cost not supported by documentation. If actual cost records aren’t readily available but the completed scope is well documented, FEMA can fund it on an estimate. For a completed small project, FEMA may accept your certification of costs instead of documentation and fund it on the estimate.
What FEMA requires
  • For projects with all work complete, FEMA works with you to verify programmatic, insurance and hazard mitigation information, confirm EHP grant conditions were met, confirm the work did not harm the community, and verify documentation.
  • Large projects 100 percent complete are funded on actual costs. FEMA decides eligibility on the documentation you submit and denies unsupported costs.
  • If actual cost documentation is not readily available but you have defined the completed scope, FEMA funds the completed work on a cost estimate.
  • If more information is needed, FEMA issues a request for information with a deadline. If you don’t fully support eligibility, FEMA issues a determination memorandum, which you can appeal (see Chapter 2).
  • Small projects may be funded on estimates with your certification instead of documentation. They are not later adjusted to actual costs, except in the situations listed in Chapter 12, but keep your records to support a net small project overrun appeal.
Documentation

For large projects: actual cost documentation for everything claimed (invoices, payroll, equipment logs, contracts and proof of payment). If actual costs are not readily available, documentation that defines the completed scope well enough for an estimate. For small projects: your certification of costs, plus records kept on file in case you later claim a net small project overrun.

Watch out · Govstar advice
On completed work, the record is the project. Missing payroll, equipment logs or proof of payment mean denied costs, and a request for information you don’t answer in time becomes a determination memo you then have to appeal.
PAPPG v5.0 pp. 230–231 · Stafford Act § 422 · 44 CFR 206.205(a)
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Chapter 9 › II.B Expedited Projects for Emergency Work

Can we get emergency work funding before the project is finished?

Expedited projects for emergency work
pp. 229–230
Short answer
Yes, for large debris removal and emergency protective measures projects. Ask within 60 days of your recovery scoping meeting, with enough information for FEMA to validate the work and costs, and FEMA may fund 50 percent of the federal share of the estimate, aiming to obligate within 90 days. The rest follows once you document the full cost.
What FEMA requires
  • Applies to Category A or B projects that meet or exceed the large project threshold.
  • Submit the request within 60 days of the recovery scoping meeting, with enough information for FEMA to validate eligibility, broken down by monthly or bi-weekly operational periods.
  • FEMA funds 50 percent of the federal share of the estimated cost and works to obligate within 90 days of the request.
  • Obligation does not let the recipient advance funds without documentation. Advances are limited to the minimum amounts needed, timed to actual, immediate cash needs.
  • If an increased federal cost share period applies, separate work in that period from work after it.
  • Without enough cost information, FEMA may use average historical pricing. For contract work it may use the contract unit costs if reasonable, but still reviews procurement compliance before or at closeout.
<table class="pt-table"><thead><tr><th>Step</th><th>Rule</th></tr></thead><tbody><tr><td>Which projects</td><td>Category A or B projects at or above the large project threshold</td></tr><tr><td>Request deadline</td><td>Within 60 days of your recovery scoping meeting</td></tr><tr><td>Amount</td><td>50 percent of the federal share of the estimated cost</td></tr><tr><td>FEMA target</td><td>Obligate within 90 days of receiving the request</td></tr><tr><td>Remaining 50 percent</td><td>Once you provide all documentation supporting the estimated cost</td></tr></tbody></table>
Documentation
  • Work: the immediate threat, the work done or planned, locations, and for debris, estimated quantities by type. Break everything down by monthly or bi-weekly operational period.
  • Costs: an itemized estimate with its basis (actual costs, historical or local unit costs, quotes or pre-qualified contracts) and insurance policies.
  • Labor: regular and overtime hours with average rates for budgeted employees, unbudgeted employees, and mutual aid, National Guard or prison labor, plus the mutual aid agreements.
  • Equipment and supplies: type, usage and rate for owned equipment; type and cost for purchased equipment; type and rate for rentals; type, quantity and cost for purchased and stock supplies.
  • Contracts: requests for proposals, bids or contracts supporting the estimate, and debris monitoring information.
  • Other: travel, meals and miscellaneous costs with number of people, purpose, duration and average rate.
Watch out · Govstar advice
Expedited money is not a blank check. The recipient can only release what you need for immediate cash requirements, and FEMA still reviews your procurement at closeout. A noncompliant debris contract funded on an expedited basis can be clawed back later.
PAPPG v5.0 pp. 229–230
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Chapter 9 › II.A Project Thresholds

What makes a project small or large, and is there a minimum?

Minimum project threshold; large and small project threshold
pp. 228–229
Short answer
FEMA sets two dollar amounts each federal fiscal year. A project below the minimum threshold is not eligible at all. A project at or above the large project threshold is a large project, funded on actual costs; anything between is a small project, funded on the estimate. The amounts change every year, so use the ones for the fiscal year of your declaration.
What FEMA requires
  • The minimum threshold applies to each project application, not each line item. The total includes hazard mitigation costs and accounts for insurance and other reductions.
  • FEMA will not combine sites into one project just to reach the minimum, and does not process projects under it unless you intend to appeal scope or costs that would bring it up to the minimum.
  • The minimum does not apply to donated resources or management costs, but these are only eligible when tied to an eligible project that meets it.
  • A large project has costs equal to or above the large project threshold; a small project is below it.
  • For large projects that are not capped, FEMA adjusts estimates to actual incurred costs. For small projects, it does not.
  • FEMA decides large or small on the final approved eligible amount after adjustments, including insurance reductions.
<table class="pt-table"><thead><tr><th>Project total</th><th>Result</th><th>How funding works</th></tr></thead><tbody><tr><td>Below the minimum threshold</td><td>Not eligible</td><td>No funding, unless an appeal would raise it to the minimum</td></tr><tr><td>At or above minimum, below large project threshold</td><td>Small project</td><td>Funded on the estimate; not adjusted to actual costs</td></tr><tr><td>At or above the large project threshold</td><td>Large project</td><td>Estimate adjusted to actual costs at closeout (unless capped)</td></tr></tbody></table>
Documentation

FEMA publishes the minimum project threshold and the large project threshold for each federal fiscal year on its Per Capita Impact Indicator and Project Thresholds page. Use the amounts for the fiscal year your disaster was declared.

Watch out · Govstar advice
The size is set on the final approved amount after insurance and other reductions, so an insurance payment can turn a large project into a small one. Small projects are not trued up to actual costs, which makes an accurate estimate up front essential.
PAPPG v5.0 pp. 228–229 · Stafford Act § 422 · 44 CFR 206.202(d)(2), 206.203(c), 206.205
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Chapter 9 › I. Scope of Work Development

What does a scope of work need to say?

Scope of work (SOW); damage description and dimensions (DDD)
pp. 227–228
Short answer
It describes how each damaged element will be repaired, tied directly to the disaster damage, in measurable terms (length, width, depth, capacity) and specific materials (brick, asphalt, timber deck). FEMA and the applicant should first agree on the damage description and dimensions, because the scope and the eligible cost both follow from that agreement.
What FEMA requires
  • The scope must completely describe the work needed to repair the damage or address the impacts, and correspond directly to the cause of damage.
  • Repair descriptions must be specific to the damaged elements, in quantifiable terms (length, width, depth, capacity) and descriptive terms (brick, wood, asphalt, timber deck bridge).
  • FEMA reviews the information you provide to develop or validate the scope and cost estimate, develop hazard mitigation proposals and check compliance, using the Appendix L checklist for cost estimates.
  • For traditional tribal residences and ceremonial buildings (for example adobe, earth or wood), FEMA accepts the Tribal Nation’s certified damage assessment, scope of work and cost estimate.
Documentation

For each site: the agreed damage description and dimensions, percent of work complete, who did or will do the work (force account, contract, mutual aid), the proposed or completed scope including hazard mitigation and the codes and standards that apply, and any technical studies, reports or assessments.

Watch out · Govstar advice
Agree on the damage description and dimensions before anyone writes a scope. A vague damage description (“road damaged”) leads to a thin scope and a low estimate that is very hard to fix after obligation.
PAPPG v5.0 pp. 227–228 · Appendix L
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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.