FEMA Public Assistance Cost Estimating Format (CEF)

Web-Based Instruction and Education Guide for Parts A-H

Prepared as Webflow-ready source content for GOVSTAR educational publishing

How to Use This Web-Based Guide

This document is structured for direct conversion into a Google Doc, Webflow CMS Rich Text field, or long-form instructional web page. Each CEF part is presented as a Level 1 heading so it can become a major page anchor or section in Webflow. Use the subheadings as Webflow H2/H3 elements and the tables as comparison blocks or card-based learning modules.

The guide explains the purpose, requirements, risks, documentation expectations, and practical review issues for each CEF part. It is written for applicants, subrecipients, public works staff, finance officers, emergency managers, engineers, architects, grant managers, and consultants who must understand how FEMA develops, validates, and reviews large project cost estimates.

CEF Overview: Why Parts A-H Must Work Together

The Cost Estimating Format is a structured method for estimating eligible costs for FEMA Public Assistance large permanent work projects. It starts with an itemized base construction estimate and then applies a series of project factors to account for conditions normally encountered during design, construction, permitting, contractor performance, applicant management, and project delivery. The CEF is not merely a spreadsheet; it is a disciplined project formulation, cost validation, documentation, and audit-readiness method.

The source documents emphasize that the eligible scope of work must be agreed upon before the CEF is prepared, that local technical professionals are often in the best position to develop eligible cost estimates, and that FEMA validates that costs address only eligible disaster-related work and that appropriate factors are applied to base costs. The SOP also states that the CEF should be used only for certain permanent work large projects that are less than 90 percent complete.

Critical Estimating Rule: Part A Comes First

The CEF method is a sequence. Part A must define the eligible disaster-related scope and base construction costs before Parts B through H are selected. The SOP requires each work activity in Part A to include a written scope description, CSI-based cost item reference, cost code reference if FEMA cost codes are used, unit of measure, quantity or measurement, unit cost, and extended quantity cost. It also states not to use lump sum units for Part A work activities.

This is why Part A is the critical control point. It is the place where eligibility, scope, dimensions, quantity takeoff, unit pricing, local cost adjustment, completed versus uncompleted work, permanent versus non-permanent work, insurance deductions, hazard mitigation, code upgrades, and repair-versus-replacement logic must be organized into a defensible estimate. If the base cost estimate cannot be reproduced by another competent estimator using the documentation file, the entire CEF is exposed.

Part A - Base Costs for Construction Work in Trades

Purpose and role of Part A

Part A contains the base costs for eligible permanent and non-permanent trade work needed to directly complete the eligible scope of work. The Instructional Guide describes these costs as complete and in-place components, meaning the labor, equipment, materials, small tools, incidentals, and hauling needed to complete an item of work. The Guide specifically states that preparing a precise base cost estimate in Part A is critical to the accuracy of the total project estimate developed with the CEF.

Part A is not a placeholder for a future design estimate. It is the quantitative foundation for the federal funding decision. It must be organized well enough to support policy determinations, alternatives analysis, repair-versus-replacement decisions, hazard mitigation review, insurance and duplication-of-benefits deductions, and future scope changes without reconstructing the entire estimate.

Eligible scope must be resolved before Part A

Before Part A is completed, the eligible scope of work must be clearly defined. The eligible scope is the work needed to repair or replace the damaged facility based on its pre-disaster design, including eligible code and standard upgrades and approved hazard mitigation measures. It must not include ineligible improvements or alternate project work. The CEF should be the last step in large project formulation after scope eligibility conflicts are resolved.

Required line-item structure

Every Part A work activity should be itemized and quantified. A defensible line item should include the damage/work description, CSI division or cost code reference, unit of measure, measured quantity, unit price, city or local adjustment when applicable, and extended quantity cost. Lump-sum construction cost estimates are not acceptable for the CEF because they do not meet the requirement for quantitative estimating and make future scope revisions difficult.

• Use quantities that are traceable to photographs, sketches, drawings, field measurements, plan sheets, calculations, or other source records.
• Separate completed and uncompleted work so actual costs and estimates are not improperly mixed.
• Separate permanent work from non-permanent, job-specific work such as scaffolding, temporary access, dewatering, crane support, safety systems, or other temporary work required to complete the eligible scope.
• Use one consistent CSI MasterFormat system throughout the estimate rather than mixing formats.
• Identify and avoid costs already captured in Parts B through H, such as general contractor overhead, escalation, contingencies, permit fees, or applicant project management costs.

Cost data hierarchy and pricing judgment

The strongest Part A base costs usually come from recent, relevant, competitively procured local cost history. If appropriate local weighted unit prices are not available, industry-standard cost data such as RSMeans, BNi, Marshall & Swift, Sweet’s Unit Cost Guide, and similar recognized sources may be used. FEMA cost codes may also be used, but the estimator must understand whether the source already includes overhead and profit, location factors, escalation, or other items that could be duplicated by later CEF factors.

Unit costs should represent complete and in-place installation costs. They generally should include subcontractor overhead and profit but not general contractor overhead and profit, because Part D is designed to address general contractor overhead, bond, insurance, and profit. When FEMA cost codes or contractor bids already include general contractor-level costs, the estimator must adjust Parts B through H to prevent duplication.

Repair versus replacement, hazard mitigation, and codes

Part A is also where the estimator must protect the integrity of repair-versus-replacement calculations and hazard mitigation analysis. The Instructional Guide states that repair-versus-replacement analysis begins by preparing separate Part A base cost estimates for the repair and replacement scenarios without applying Parts B through H. This is a powerful example of why Part A must be technically sound: if the repair or replacement base estimate is inaccurate, the eligibility conclusion may be wrong.

Eligible Section 406 hazard mitigation measures and eligible code and standard upgrades must be included when approved and properly tied to the eligible scope. However, ineligible improvements, discretionary betterments, unrelated upgrades, and alternate project features should not be allowed to contaminate Part A.

Documentation requirements

The Part A file should include site maps, location plans, photographs, sketches, calculations, measurements, insurance declarations, anticipated or actual insurance settlement information, Section 406 hazard mitigation proposals, permits and clearances, force account summaries, codes and standards support, drawings, plans, specifications, vouchers, invoices, timesheets, purchase orders, tickets, weight slips, and other records sufficient to support the scope and cost. Major construction activities should include schematic drawings and plan information such as elevations, floor plans, site plans, structural plans, and sections when applicable.

Part A issues to watch

• Lump-sum estimates that cannot be traced to measured quantities.
• Ineligible work embedded inside repair line items.
• Use of outdated or non-local cost data without proper location or time adjustment.
• Duplicate inclusion of contractor overhead, profit, escalation, permits, contingencies, or project management.
• Failure to separate completed work from uncompleted work.
• Failure to reconcile actual costs against prior estimates when partial completion exists.
• Confusion between permanent construction and non-permanent job-specific work.
• Repair-versus-replacement calculations based on total project costs instead of Part A base costs.

Part B - General Requirements and General Conditions

Purpose and role of Part B

Part B accounts for non-permanent job-site work that could not be readily itemized in Part A. It is applied directly to the work-type subtotals from Part A. Part B should be used only when the support cost is necessary for the eligible work and has not already been included in Part A or in the unit prices used to develop Part A.

B.1 General Requirements

B.1 covers costs commonly described in the general requirements section of construction specifications. These include safety and security, temporary services and utilities, quality control, and submittals. The Guide recommends itemizing these costs in Part A when possible. If they are included in Part A, they should not be duplicated in Part B.

B.2 General Conditions

B.2 reflects the prime contractor’s on-site project management costs and field supervision. The Guide identifies a recommended value of 4.25 percent. Before applying B.2, the reviewer should verify that the prime contractor’s on-site management costs are not already included in the unit costs or bid prices used in Part A.

Part B issues to watch

• Using Part B as a generic markup without linking it to actual job-site requirements.
• Duplicating temporary work already included in Part A.2 or in contractor unit prices.
• Applying field supervision costs to force account work or costs that do not require a prime contractor delivery model.
• Failing to document why a particular percentage was selected.

Part C - Construction Cost Contingencies and Uncertainties

Purpose and role of Part C

Part C provides cost allowances for uncertainty in completing the eligible scope of work defined in Parts A and B. It is not a budget cushion for unspecified work. It is intended to address design maturity, constructability, access, storage, staging, and economies of scale. Every Part C selection must be supported by the CEF Notes Sheet and the project file.

C.1 Design Phase / Scope Definition Contingency

C.1 addresses uncertainty based on the level of design completion at the time the estimate is prepared. At the preliminary engineering analysis stage, concepts may exist without detailed quantities or specifications, so risk is higher. At the working drawing stage, details, quantities, and construction methods are more defined, so risk should be lower. As design advances, the appropriate contingency should decrease. A high C.1 factor with nearly complete design drawings is a red flag unless there is exceptional documented uncertainty.

C.2 Facility or Project Constructability

C.2 addresses premiums caused by project complexity, site conditions, or construction process constraints. It applies to repair and retrofit projects, not new construction where design should already account for complexity. Examples include steep embankments, unstable soils, difficult subsurface work, dewatering, rock excavation, winter shutdowns, urban sites, special code requirements, utility or material constraints, reasonable applicant restrictions, and environmental considerations.

C.3 Access, Storage, and Staging

C.3 covers cost impacts caused by site access, storage, or staging limitations that are not already line-itemized in Part A. Examples include remote storage, restricted delivery hours, temporary easements, sidewalk or lot rental, off-site parking, cranes or barges needed because of loading constraints, and phased work in occupied hospitals, city halls, or other operational facilities.

C.4 Economies of Scale

C.4 reduces potential overstatement when CEF factors are applied to large repetitive projects where productivity may be better than normal unit-cost assumptions. The Guide identifies negative cost adjustments as project size increases, including 0 percent under $500,000, -0.5 percent under $2 million, -1 percent under $10 million, and -2 percent over $10 million, with interpolation performed by the spreadsheet.

Part C issues to watch

• Treating contingencies as automatic instead of tying them to design maturity and site-specific risk.
• Applying constructability allowances to new construction without justification.
• Using C.2 or C.3 where the condition can and should be quantified in Part A.
• Failing to reduce contingency as the design matures.
• Ignoring economies of scale on large repetitive projects.

Part D - General Contractor’s Overhead and Profit

Purpose and role of Part D

Part D captures general contractor costs not already included in Parts A, B, or C. It includes general contractor home office overhead, insurance, payment and performance bonds, and profit. Part D does not represent subcontractor overhead and profit, which should already be included in Part A unit prices. Part D should not be applied to force account work.

Part D issues to watch

• Applying general contractor overhead and profit to applicant force account work.
• Duplicating overhead and profit already included in FEMA cost codes, bids, contracts, or unit-cost sources.
• Confusing subcontractor overhead and profit in Part A with general contractor overhead and profit in Part D.
• Applying Part D to costs that are not construction contract costs.

Part E - Cost Escalation Allowance

Purpose and role of Part E

Part E adjusts estimated construction costs for inflation during the design and construction period. It should be used only for uncompleted work. The estimator establishes a design and construction timeline to the midpoint of construction for the eligible portion of the work, then applies the appropriate escalation logic. The timeline must be tied to the eligible scope, not to unrelated improved or alternate project features.

Required escalation logic

The critical Part E inputs are the date of estimate, anticipated design schedule, anticipated construction schedule, expected midpoint of eligible construction, and the inflation index or factor used. The source documents stress that assumptions and basis for selected factors must be recorded in the CEF Notes Sheet. From an audit perspective, Part E should read like a transparent forecast, not an arbitrary percentage.

Part E issues to watch

• Applying escalation to completed work.
• Failing to document the date of estimate and midpoint of construction.
• Using escalation that is inconsistent with the project schedule.
• Duplicating escalation already embedded in a bid, contract, or cost database.
• Using an improved project schedule rather than the eligible scope schedule.

Part F - Plan Review and Construction Permit Costs

Purpose and role of Part F

Part F reflects State and local agency fees for plan review and construction permits. It should include fees paid to others to obtain approvals required before construction can begin. The actual cost of the fees should be entered into the spreadsheet. Part F is not a generic design contingency; it is for identifiable jurisdictional fees and approvals.

Determining applicable fees

At the beginning of a disaster, the PA Group Supervisor or designee should identify plan review and permit fee schedules and distribute them to Project Specialists. The controlling jurisdiction may be a city building department, office of the state architect, or other agency. State-owned facilities such as schools, medical facilities, bridges, and treatment plants may have different review requirements from other facilities.

Part F issues to watch

• Including fees that were waived after the disaster.
• Using the wrong fee schedule or wrong cost basis.
• Duplicating fees already included in contractor prices.
• Failing to distinguish plan review fees from construction permit fees.
• Ignoring special approval processes for schools, hospitals, bridges, treatment plants, historic facilities, or regulated utilities.

Part G - Applicant’s Reserve for Construction

Purpose and role of Part G

Part G reflects the applicant’s reserve for construction. It is controlled by the applicant and is intended to fund approved change orders to eligible work and other incidental eligible costs incurred after the construction contract is awarded. It is not a reserve for discretionary upgrades, betterments, scope expansion, alternate project features, or ineligible work.

The reserve is based on the size of the project, measured by the sum of Parts A through F. The Instructional Guide lists reserve percentages that decrease as project size increases, and the spreadsheet interpolates between percentage points using a natural logarithmic formula.

Part G issues to watch

• Treating the reserve as a discretionary contingency for upgrades.
• Funding change orders that are not tied to eligible work.
• Failing to manage change orders with eligibility documentation.
• Duplicating contingency already funded under Part C.
• Assuming Part G eliminates the need for procurement, eligibility, and cost reasonableness review.

Part H - Applicant’s Project Management and Design Costs

Purpose and role of Part H

Part H represents the applicant’s project development and management costs through design and construction. It includes managing the design process, basic design and inspection services normally performed by an architect-engineer firm, and managing the construction phase. The Guide is clear that Part H does not duplicate the administrative allowance for requesting, obtaining, or administering disaster assistance. Part H covers project management, not grant management.

H.1 Applicant project management - design phase

H.1 covers applicant costs to manage the design phase, including managing A&E contracts, managing permitting and special review, and interfacing with other agencies. The Guide establishes a value of 1 percent for this factor. It is not applicable where design is not required.

H.2 A&E design contract costs

H.2 covers basic design and inspection services normally performed by an A&E firm, including preliminary engineering analysis, preliminary design, final design, and construction inspection. The CEF spreadsheet incorporates engineering service curves from FEMA guidance. Curve A applies to above-average complexity and non-standard design projects, such as hospitals, treatment plants, schools, power plants, large dams, complicated waterfront facilities, and similar projects. Curve B applies to average complexity projects, such as conventional buildings, bridges, roads, levees, storm sewers, sanitary sewers, water distribution lines, irrigation works, and airports except those classified for Curve A.

Special services not normally included in basic engineering fees should be specifically described and justified before being included. Examples include engineering surveys, soil investigations, resident engineer services, and feasibility studies. If only basic construction inspection services are required, the Guide states that a fee not exceeding 3 percent of construction cost should be used to cover inspection-related tasks such as bid review, site visits, material sample checks, shop drawing and change order review, contractor payment request review, and acting as the applicant’s representative.

H.3 Project management - construction phase

H.3 covers applicant management during construction, including quality assurance, management of additional testing, advertising and awarding the construction contract, decisions on construction problems and requests for information, and management of change orders for site conditions, design errors, omissions, hidden damage, and unforeseen problems.

Part H issues to watch

• Confusing applicant project management with grant administration.
• Applying H.1 or H.2 where no design or design management is required.
• Choosing Curve A for projects that are average complexity without justification.
• Omitting special services from Part A or failing to justify them.
• Duplicating construction inspection, quality control, or testing costs already included in Part B, Part A, or contracts.
• Failing to document why applicant management costs are necessary for the eligible scope.

Cross-Cutting Documentation Standards for Parts A-H

A CEF estimate should be defensible, reproducible, and auditable. The CEF Notes Sheet is not a formality. It is the written record of professional judgment. Every factor selection, especially any value outside recommended ranges, should be supported by a clear explanation tied to documented project conditions.

Practical Applicant Readiness Checklist

• Create a disaster-specific cost source file before estimates are prepared.
• Collect local weighted unit prices and verify whether they include overhead, profit, bonds, escalation, or permits.
• Use a consistent CSI MasterFormat structure throughout Part A.
• Resolve scope eligibility before entering costs into the CEF.
• Separate permanent, non-permanent, completed, and uncompleted work.
• Document every selected factor in Parts B through H with project-specific notes.
• Maintain a duplication-control worksheet showing what is included in Part A and what is left for Parts B-H.
• Preserve all measurements, drawings, photos, calculations, unit cost source pages, bids, contracts, and review comments.
• Track insurance proceeds, salvage, depreciation, duplication of benefits, and other deductions separately from base estimating logic.
• Have a qualified estimator or engineer independently review Part A before factor selection begins.

Conclusion: The CEF Is a Funding Model and an Audit File

The Cost Estimating Format is most effective when it is treated as both a cost model and a documentation system. Part A defines what is eligible, measurable, and priced. Parts B through H then apply disciplined factors to that base. The most common failure is to debate factor percentages while the base estimate remains unsupported. The proper sequence is the opposite: first make Part A precise, eligible, quantified, locally grounded, and reproducible; then select Parts B through H based on documented project conditions.

Source Basis

This guide was developed from the uploaded FEMA CEF source documents, including the CEF Standard Operating Procedure for Large Projects, the CEF Instructional Guide Version 2.1, the FEMA online CEF course material, the Federal Register proposed rule on CEF for large projects, and the provided technical reference and summary documents. The text is written as educational synthesis for web publication and should be checked against current FEMA policy before use in active grant administration.