How do we show the damage was caused by the declared disaster?
FEMA term
Minimum work eligibility: result of the declared incident
Short answer
All work must pass three tests: it is required because of the declared incident, it is in the designated area, and it is your legal responsibility. For the first, you must show the damage happened during the incident period and was caused directly by the incident, and separate it from anything else, such as earlier damage, wear and tear, deferred maintenance or another event.
What FEMA requires
Work must meet three minimum criteria: required as a result of the declared incident, located in the designated area, and the legal responsibility of an eligible applicant.
Debris removal: the debris was generated by the incident during the incident period, and removing it addresses an immediate threat caused by the incident.
Emergency protective measures: the work addresses an immediate threat caused by the incident.
Permanent work, temporary repairs and mold remediation: the work addresses damage caused by the incident.
You must separate impacts, damage, work and costs not caused by the incident from those that were.
A facility that was functioning before the disaster and was made non-functional by it may be eligible, provided its pre-disaster condition was not a significant contributing factor in the failure.
For tribal sacred sites closed to non-members, FEMA accepts the Tribal Nation’s certified damage assessment instead of a site inspection, and does not require photos, site maps or GPS locations where tribal artifacts are located.
<table class="pt-table"><thead><tr><th>Not caused by the declared incident</th><th>Eligible?</th></tr></thead><tbody><tr><td>Damage or debris that existed before the incident</td><td>Not eligible</td></tr><tr><td>Damage from a different incident, even during the incident period</td><td>Not eligible</td></tr><tr><td>Damage after the incident period but before repairs</td><td>Not eligible</td></tr><tr><td>Deterioration (wear and tear) or deferred maintenance</td><td>Not eligible</td></tr><tr><td>Damage from failing to protect the facility promptly, or from negligence</td><td>Not eligible</td></tr></tbody></table>
Documentation
Small projects: you certify instead of providing documents: for debris, that it was generated by the incident during the incident period and its removal addresses an immediate threat; for emergency protective measures, that the threat resulted from the incident; for permanent work, that the incident directly caused the damage and it did not result from lack of maintenance.
Large projects: if needed to validate the cause, pre-incident photos or video of the site, and records of its pre-disaster condition such as maintenance records or inspection and safety reports.
Not every large project needs these. When the cause is evident at inspection, for example a bridge washed away or a building destroyed by fire, FEMA does not require them.
Some project types, such as maintained natural features and beaches, always require maintenance records or photos.
Watch out · Govstar practitioner advice
Deferred maintenance is one of the most common ways FEMA cuts permanent work. Pull maintenance logs, inspection reports and pre-disaster photos early, before FEMA asks, especially for roads, culverts and natural features.
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.
