Chapter 9 › III–IV Compliance Reviews; Obligation

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

FEMA term

Compliance reviews; obligation; strategic funds management

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 practitioner 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.

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.