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Navigating FEMA Public Assistance and Cost Share

May 13, 2024

When a disaster strikes, individuals and organizations often donate resources to assist with response activities. These resources can include cash donations, grants, volunteer labor and donated supplies and equipment. Under the Stafford Disaster Relief and Emergency Assistance Act, the assistance FEMA provides through its Public Assistance Program is subject to a cost share. The federal share typically covers 75% of eligible costs and the remaining 25% is the applicant’s responsibility to cost share or “match.” These donations are a key component to meeting the federal match requirement. There are three key considerations for match:  

  1. The first 30 days
  2. What is eligible as match
  3. How to document the match 

      The First 30 Days: Match Considerations 

      In limited circumstances, the federal match may be increased. When the President authorizes an increased federal cost share for a limited timeframe, FEMA applies it to all eligible costs related to work performed through 11:59 p.m. on the date of expiration. However, it is still very important to track all resources utilized or received during this time period to accurately document all match. For emergency work specifically, if there is a time-limited 100% federal cost share period: 

      • If the applicant uses resources donated during this time period, it may use the value of those donated resources to offset the non-federal cost share incurred after the 100% federal cost share period expires. 
      • If the applicant uses resources from its stock that were donated during a previous incident or timeframe, it may use the value of those donated resources to offset its non-federal cost share if the applicant has not claimed the resources as an offset in a previous incident. 

      What is Eligible as Match Under FEMA Public Assistance Program? 

      Grants and cash donations from non-federal sources and donated services, equipment and supplies can be used to meet the match requirements of the program.  

      The match is eligible when:  

      • The donated resource is from a third party; 
      • The donated resource is necessary and reasonable; 
      • The applicant uses the resource to perform eligible work and within period of performance; and  
      • The applicant tracks the resources and work performed to the project, including description, specific locations and hours. 

      The value of a donated resource is not eligible as match if the resource is: 

      • Donated by a federal agency; 
      • Donated by another federally-funded source; 
      • Funded through a federal award; 
      • Used as an offset to any other federal award; or 
      • Used for ineligible work. 

      As mentioned, match requirements generally cannot be paid with other federal funds. However, when specifically allowed in another federal program, federal funds may be used as match. One specifically allowable source of federal match is the HUD Community Development Block Grants for Disaster Recovery (“CDBG-DR”) program. CDBG-DR can be used to pay for eligible expenses on eligible project worksheets. States routinely use this approach to assist local entities, state agencies and other public assistance applicants with their cost share requirement.  

      There are challenges in using CDBG-DR to make the match. Differences in program requirements, including grant amounts and timing, can cause alignment difficulties. However, careful documentation and tracking can help make certain that the match is properly applied and allowable. 

      How Should Match be Documented? 

      The applicant must track and document the following to support donated resources. This documentation is required. Proper documentation will support the requirements that the assistance is essential to meeting immediate threats resulting from the disaster and that the match is verifiable through the applicant’s records. 

      Documentation requirements for donated services, equipment or supplies include, but are not limited to: 

      For individuals providing an eligible service: 

      • Sign-in sheet 
      • Name 
      • Title and function 
      • Date, days and hours worked 
      • Location of work and description of work performed 

      For equipment: 

      • Date and length of time operating equipment 
      • Specific backup documentation if applicant-owned 
      • Who donated each piece of equipment 

       For supplies or materials: 

      • Quantity used 
      • Who donated 
      • Location(s) used 
      • Invoices or other documentation to validate claimed value 

      Disasters pose extreme challenges to the individuals and the communities they impact. To meet cost-sharing requirements, the non-federal contributions must be reasonable, allowable, allocable and necessary under the grant program and must comply with all federal requirements and regulations.  

      EisnerAmper professionals have decades of experience navigating the complexities of federal funding. We closely monitor relief developments at the federal, state, and local levels and we’re committed to helping you understand and leverage the disaster relief options available. Contact us below to discuss your organization’s unique situation. 

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      Jennifer Butler

      Jennifer Butler is a Partner in the firm and has over 20 years of experience in executive leadership roles. 

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