Appendix G › Scope of Work Changes; Closeout Requirements

When do we need FEMA’s approval to change the scope, and how do alternative procedures projects close out?

FEMA term

Alternative procedures scope of work changes; closeout requirements

Short answer

After you accept the offer, notify FEMA before changes involving buildings 45 years or older, ground disturbance, or work in or near water. Routine changes like material substitutions or new floor plans don’t need notice. At closeout, the recipient certifies the work and costs within 180 days, with a final report; you don’t track costs line by line.

What FEMA requires

Notify FEMA before scope changes that involve buildings or structures 45 years or older, ground-disturbing activities, or work in or near waterways.
Except for buildings 45 years or older, changes that substantially conform to the approved scope (material substitutions, interior floor plan reconfigurations) don’t require notice.
Changes affecting hazard mitigation must be approved within the 18-month deadline, and the fixed amount is adjusted.
Work must be complete by the approved deadline. The recipient certifies that incurred costs relate to the approved scope and that work followed FEMA rules.
The recipient submits its certification within 180 days of the subrecipient completing its last alternative procedures project or the latest project deadline, whichever comes first, for the subrecipient to keep excess funds.
Subrecipients don’t track costs to specific line items; they substantiate and certify that claimed costs relate to the overall eligible work.

<table class="pt-table"><thead><tr><th>Change after the offer is accepted</th><th>Notify FEMA first?</th></tr></thead><tbody><tr><td>Work on buildings or structures 45 years or older</td><td>Yes</td></tr><tr><td>Ground-disturbing activities</td><td>Yes</td></tr><tr><td>Work in or near waterways</td><td>Yes</td></tr><tr><td>Changes that substantially conform (material substitutions, interior floor plan changes)</td><td>No (except on buildings 45+ years old)</td></tr><tr><td>Changes affecting the hazard mitigation scope</td><td>Must be approved within the 18-month deadline; fixed amount adjusted</td></tr></tbody></table>

Documentation

The recipient’s closeout certification with a final cost report covering: actual work completed, mitigation achieved, EHP compliance, civil rights compliance, obtain and maintain insurance compliance, total actual costs, procurement compliance, and actual insurance proceeds.

Watch out · Govstar practitioner advice

The recipient’s 180-day certification is what lets you keep excess funds, so make sure your final cost report and compliance records are ready well before then.

Govstar summarizes FEMA’s Public Assistance Program and Policy Guide in plain language and links to the official text. Govstar is independent and not affiliated with FEMA. This is general guidance, not legal advice.