Public Assistance Administrative Plan
Recipients must have a FEMA-approved administrative plan 58 that describes how it intends to administer the PA Program before FEMA provides PA funding for any project. At a minimum, the administrative plan must include: 59
The agencies responsible for program administration;
Identification of staffing functions, the source of staff to fill the functions, the management and oversight responsibilities of each function; and
Procedures for:
o Notifying potential applicants of the availability of the PA Program;
o Conducting applicant briefings;
o Assisting FEMA in determining applicant eligibility;
o Participating with FEMA in conducting preliminary damage assessments;
o Participating with FEMA in establishing PA mitigation and insurance requirements;
o Processing appeals, time extension requests, and other project-related correspondence;
o Complying with administrative requirements of 2 Code of Federal Regulations (C.F.R.) § 200 and 3002 and 44 C.F.R. § 206;
o Complying with audit requirements of 2 C.F.R. § 200 and 3002;
o Processing requests for advances of funds and reimbursement;
o Determining staffing and budgeting requirements; and,
o Determining the pass-through funds for management costs provided under 44 C.F.R. § 207. State and territorial recipients must submit their administrative plan to FEMA annually. Additionally, an amendment is required for each disaster declaration to address the specifics of the new incident. The
recipient must incorporate the approved administrative plan into its emergency plan. Tribal Nations submit
their PA administrative plan for each declared disaster in which they are a recipient. For further guidance see Tribal Declarations Interim Guidance. 60 Subrecipients do not require PA administrative plans.
57 The Payment Management System Access Form and the SF-1199A are available at: Payment Management Services | psc.gov.
58 Templates for administrative plans are available at: Public Assistance Project Templates and Forms.
59 44 C.F.R. § 206.207(b).
60 For more information, refer to: Tribal Declarations Interim Guidance | fema.gov.
M. Recipient-Led Public Assistance
FEMA has found that recovery efforts are most successful when locally executed, state or Tribal Nation managed, and federally supported. Local county or parish officials are best equipped to understand the unique needs of their communities, while Tribal Nations know what is most important to their people and how to effectively guide their recovery. Disaster recovery progresses at different rates for each locality and involving the right mix of local subject matter experts early in the process ensures that environmental, historic, sustainability, and resilience factors are considered from project formulation through implementation.
This approach forms the basis of recipient-led PA operations. While it may not be suitable for widespread disasters that could overwhelm local, state, or Tribal Nation resources, recipient-led PA events offer opportunities to build local capacity and capability while addressing the specific needs of the recovering community.
In recipient-led PA events, recipients can lead any of the following key PA functions in lieu of FEMA:
Customer service;
Site inspections; and,
Scoping and costing.
In addition to any support requested by recipients, FEMA maintains the following responsibilities:
Oversight of the PA operation;
Quality control reviews;
Law, regulation, and EO compliance reviews; and,
Final eligibility determination and obligation authority.
FEMA and the recipient discuss whether a recipient-led PA operation is appropriate given the recipient’s current capacity. These discussions may begin before an incident when the recipient is assessing its capability to lead a future PA operation or after a declaration request. FEMA and the recipient examine the recipient’s capacity at the time of the disaster and incident-specific characteristics to determine the feasibility of recipient-led PA. Typically, the best candidates for recipient-led PA are recipients with the following factors:
61 For more information, refer to: Hazard Mitigation Planning | fema.gov.
62 44 C.F.R. § 201.3(c)(1) and (e)(1).
Recent disaster experience;
Adequate recipient staff or staff augmentation mechanisms;
A fiscal accounting system tracks specific projects, withstands audit, and may be used to evaluate appeals; and,
Established record of meeting deadlines for PA grant management activities.
To opt in to recipient-led PA, the Regional Administrator and the governor or the GAR63, or for Tribal Nation declarations, the tribal chief executive or TAR must enter into an operational agreement, as an addendum to the FEMA-state agreement (FSA) or FEMA-Tribal Nation agreement (FTA), that delineates roles and responsibilities. After signing, recipients have 72 hours to sign the operational agreement. The Regional Administrator may approve requests to participate in recipient-led PA after the 72 hours at its discretion. The “State-Led Public Assistance Guide” 64 provides additional guidance on the processes, resources, and capabilities required.