Public Assistance Program and Policy Guide Version 5.0 Amended, Effective January 6, 2025

(FP 104-009-2)

PAPPG v5

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PAPPG Version 5.0 has been amended to reflect the issuance of Executive Orders on and after January 20, 2025. Amendments are reflected in the following: Chapters 4, 6, 8, 10, Appendices A, B, C, D, G, & the removal of the option for an independent expert panel cost estimate review for projects with a federal cost share greater than $5 million.

Foreword On behalf of the Federal Emergency Management Agency (FEMA), I am pleased to issue the fifth edition (Version 5.0 Amended) of the “Public Assistance Program and Policy Guide” (PAPPG). This version applies to incidents declared on or after January 6, 2025 and supersedes Version 4.1 As with prior versions, FEMA has archived previous editions for reference, and Version 5.0 Amended serves as the comprehensive, consolidated resource for Public Assistance (PA) Program policies throughout the disaster recovery lifecycle.

The PAPPG provides a robust and streamlined guide for evaluating eligibility under the PA Program. It consolidates relevant policies into a single document, while also referencing external FEMA policies and resources to support stakeholders involved in the implementation of each recovery step. The release of Version 5.0 Amended reflects FEMA's continued commitment to improving access to the PA Program, reducing the documentation burden on our customers, and promoting fair and timely recovery efforts. By integrating cost-effective hazard mitigation measures, Version 5.0 also helps facilitate resilient rebuilding in communities affected by disasters.

Significant updates in this edition include policy changes related to Tribal Nations, resilience and mitigation, and adjustments based on Title 2 Code of Federal Regulations (C.F.R.) updates that took effect on October 1, 2024. FEMA will continue to prioritize further updates to PA guidance to ensure continued alignment with emerging needs in disaster recovery and Administration priorities.

We are confident that Version 5.0 Amended of the PAPPG will further enhance the effectiveness, accessibility, and resilience of the PA Program as it supports the recovery of communities across the nation.

We look forward to your feedback to help inform the next version. All recommendations for the PAPPG can be sent to FEMA-Recovery-PA-Policy@fema.dhs.gov.

Paul Judson Acting Assistant Administrator Recovery Directorate

1 For previous editions of the PAPPG, refer to: Archives: FEMA Public Assistance Policy | FEMA.gov.

mailto:FEMA-Recovery-PA-Policy@fema.dhs.gov https://www.fema.gov/assistance/public/policy-guidance-fact-sheets/policy-archives

Table of Contents

Foreword

Summary of Changes

Policy and Guidance Documents Incorporated and Superseded

Introduction

I. Document Scope, Purpose, and Use

II. Applicability

III. Document Management and Maintenance

IV. Public Assistance Program Overview

V. Authorities

A. Statutes

1. Stafford Act

2. Other Statutes

B. Regulations

1. Title 44 of the Code of Federal Regulations

2. Title 2 of the Code of Federal Regulations

3. Other C.F.R

C. Policy

D. Public Assistance Web-Based Grants System

Chapter 1: Declarations and Planning

I. Damage Assessments

II. Declaration Request

III. Declaration Evaluation

A. State and Territorial Governments

B. Tribal Nations

IV. Declaration Determinations

A. Incident Type

B. Incident Period

C. Designated Areas

D. Types of Assistance

E. Federal Cost Share

F. Declaration-Related Appeals

G. Recipient Administrative Requirements

H. Application for Federal Assistance

I. FEMA-State/Tribal Nation Agreement

J. Payment Management System

K. Public Assistance Administrative Plan

L. Hazard Mitigation Plan

M. Recipient-Led Public Assistance

Chapter 2: Coordination and Appeal Rights

I. PA Eligibility

A. Simplified Procedures

B. Sampling Procedures

C. Facilitated Discussions

D. Requests for Information

E. Notification of an Ineligibility Determination

F. Appeal Rights and Requirements

G. Appeal Deadlines

H. Appeal Review and Decisions

I. Arbitration

Chapter 3: Applying for Public Assistance and Applicant Eligibility

I. Applicant Eligibility

II. Applicant Briefing

III. Request for Public Assistance

IV. Applicant Eligibility: State, Local, Tribal Nation, and Territorial Government Entities

A. State and Territorial Governments

B. Tribal Nations

C. Local Governments

V. Applicant Eligibility: Private Nonprofit Organizations

A. Organization Eligibility

B. For-Profit Entities

C. Facility Eligibility

D. Multiple Facilities

E. Mixed-Use Facility

F. Mixed-Use Space

G. Multiple Services

H. Use by Multiple Entities

I. Leased Facilities

J. Small Business Administration Loan Requirement

1. Small Business Loan Eligibility

K. Private Nonprofit Services

Chapter 4: General Facility and Work Eligibility

I. Facility Eligibility

A. Public Facility

B. Inactive or Partially Inactive Facility

C. Facility Scheduled for Repair or Replacement

II. General Work Eligibility

A. Emergency Work vs. Permanent Work

B. Minimum Work Eligibility Criteria

1. Result of Declared Incident

i. Documentation and Information to Support Cause of Impacts and Damage

ii. Protecting Tribal Sensitive Locations

2. Within Designated Area

i. Documentation and Information to Support Within Declared Area

3. Legal Responsibility

i. Documentation and Information to Support Legal Responsibility

ii. Facilities Under Contract for Construction

iii. Leased Facilities

iv. Federal Facilities

v. Jurisdiction Over an Area

vi. Conducting Activities on Private Property

vii. Work Under the Authority of Other Federal Agencies

viii. Environmental and Historic Preservation Requirements

ix. Policy Implementation Considerations

x. Resilience Considerations

Chapter 5: Damage and Impact Information

I. Impact List

A. Impact List Submission Deadline

B. Inundated and Submerged Roads

II. Grouping Impacts into Projects

A. Initial Debris Removal Grouping (Category A)

B. Initial Emergency Protective Measures Grouping (Category B)

C. Initial Permanent Work Grouping (Categories C-G)

1. Transportation

2. Water Control

3. Education

4. Housing

5. Health

6. Emergency Service Facilities

7. Other Government Facilities

8. Energy

9. Water/Wastewater

10. Communications/Information Technology

11. Natural and Cultural Resources

D. Final Grouping

E. Building Code and Floodplain Management Administration and Enforcement Activities Grouping (Category I)

F. Grant Management Activities Grouping (Category Z)

Chapter 6: Cost Eligibility

I. Eligibility Requirements

II. Reasonable Costs

A. Reasonable Cost Analysis

III. Applicant (Force Account) Labor

A. Labor Policies

B. Eligibility Criteria for Reimbursement of Employee Labor Costs

1. Reassigned Employees

2. Reassigned Employees Funded from an External Source

3. Backfill Employees

4. Essential Employees Called Back from Furlough

5. Supervisors

6. Other

7. Standby Time

IV. Applicant-Owned and Purchased Equipment

A. FEMA Rates

B. State, Tribal Nation, or Territorial Rates

C. Local Rates

D. Equipment with No Established Rate

E. Telecommunications Equipment Purchase

V. Rented or Leased Equipment

VI. Supplies

VII. Disposition of Equipment and Supplies

A. Disposition of Purchased Equipment

B. Disposition of Purchased Supplies

VIII. Disposition for Small Projects

IX. Disposition of Real Property

X. Procurement and Contracting Requirements

A. Procurement and Contracting Requirements for State and Territorial Government and Tribal Nation Entities

1. Procurement

2. Contracting

B. Procurement and Contracting Requirements for Local Government Agencies and Private Nonprofit Organizations

1. Pre-Procurement Considerations

2. General Federal Procurement Requirements

3. Procurement Methods

C. Noncompetitive Procurement

1. Contract Types

D. Time-and-Materials Contracts

1. Cost-Plus-Percentage-of-Cost or Percentage-of-Construction

2. Additional Contracting Considerations

i. Pre-Positioned Contracts

ii. Cooperative Purchasing

E. Required Documentation and Information for Procurement and Contracting

XI. Mutual Aid

A. Post-Incident Agreements

B. Eligibility

C. Emergency Management Assistance Compact

D. Required Documentation and Information for Mutual Aid

XII. Prisoners

XIII. National Guard

XIV. Direct Federal Assistance

XV. Increased Federal Cost Share for a Limited Timeframe

XVI. Donated Resources

A. Offset Amounts

B. Required Documentation and Information for Donated Resources

XVII. Project Management and Design Services

XVIII. Grant Management and Administration

XIX. Surveys to Assess or Locate Damage or Debris Impacts

XX. Duplication of Benefits

A. Insurance Proceeds

B. Non-Federal Grants and Cash Donations

C. Third-Party Liability

D. Other Federal Awards

XXI. Duplication of Funding Between FEMA Programs

XXII. Interest on Loans

XXIII. Ineligible Costs

A. Loss of Revenue

B. Loss of Useful Service Life

C. Tax Assessments

D. Increased Operating Costs

Chapter 7: Emergency Work Eligibility

XI. Eligibility Considerations for Emergency Work

XII. Debris Removal (Category A)

A. Hazardous Limbs, Trees, and Stumps

1. Hazardous Limb or Branch Removal

2. Hazardous Tree Removal

3. Hazardous Stump Removal

i. Contracted Stump Removal

ii. Documentation Requirements for Hazardous Limbs, Trees, and Stumps

B. Waterways

1. Navigable Waterways

2. Non-Navigable Waterways, Including Flood Control Works and Natural Waterways

3. Identifying Debris Impact Locations

C. Privately-Owned Vehicles and Vessels on Public Property

D. Disposal

1. Recycling Revenue

2. Temporary Staging Sites

3. Hand-Loaded Trucks and Trailers

4. Landfills and Tipping Fees

E. Monitoring Contracted Debris Removal Operations

F. Private Property Debris Removal

1. PPDR Eligibility Determination Process

i. Public Interest

2. Debris Removal from Private Roads

3. Debris Removal from Private Non-Commercial Property

4. Debris Removal from Private Commercial Property

5. Duplication of Benefits in Private Property Debris Removal

XIII. Emergency Protective Measures (Category B)

A. Saving Lives and Protecting Public Health and Safety

B. Protecting Improved Property

C. Emergency Protective Measures on Private Property

D. Emergency Protective Measures Conducted by Private Nonprofit Organizations.. 133

E. Pre-Positioning Resources

F. Increased Operating Costs

G. Emergency Public Transportation and Communication (DFA Only)

H. Flood Fighting

I. Emergency Operations Centers

J. Emergency Access

K. Hazardous Materials

L. Supplies and Commodities

M. Meals

N. Emergency Medical Care

O. Evacuation and Sheltering

1. Evacuation

2. Sheltering

i. Congregate Sheltering

a. Congregate Shelter Facility Costs

b. Congregate Shelter Staff Costs

c. Congregate Shelter Supplies and Commodities

d. Congregate Shelter Services

ii. Non-Congregate Sheltering

a. Requests for Non-Congregate Sheltering

b. Eligible Costs for Non-Congregate Sheltering

c. Ineligible Costs for Non-Congregate Sheltering

d. Survivor Insurance and Non-Congregate Sheltering

e. Time Extensions for Non-Congregate Sheltering

f. NCS Work Eligibility Requirements

g. Data Collection, Management, and Reporting During NCS Operations

3. Host-State or Host-Tribe Evacuation and Sheltering

4. Childcare Services

P. Infectious Disease Incident

Q. Mosquito Abatement

R. Safety Inspections

S. Animal Carcasses

T. Demolition of Private Structures

1. Conditions of Eligibility for Demolition

2. Commercially Owned Structures

3. Eligible Demolition Work

4. Ineligible Work

U. Temporary Relocation of Essential Services

1. Eligible for Temporary Relocation

2. Ineligible for Temporary Relocation

3. Determining Eligibility of Temporary Relocation

4. Lease, Purchase, or Construct

5. Safe Rooms for Temporary School Facilities

6. Temporary Relocation Costs

7. Time Limitations

i. Conditions When Temporary Facility Funding is Limited

a. Improved Project

b. Alternate Project

c. Alternative Procedures Project

8. Disposition Requirements

V. Snow-Related Activities

1. Limited Time Period

2. Eligible Work

W. Emergency Repair or Stabilization

1. Operation Blue Roof (DFA Only)

2. Slope Stabilization

3. Mold Remediation

4. Emergency Berms on Beaches

X. Elections and Polling Activities

XIV. Damage Caused During Performance of Emergency Work

Chapter 8: Permanent Work Eligibility (Categories C-G)

I. Facility Restoration (Categories C-G)

II. Codes and Standards

A. Consensus-Based Codes, Specifications, and Standards

1. Identification Requirements

2. Verification Requirements

3. Additional Eligible Work and Costs

4. Other Considerations

B. Locally Adopted Codes and Standards

C. Codes and Standards Eligibility Criteria

1. Applies to the Type of Restoration Required

2. Appropriate to Pre-Disaster Use

3. Reasonable

4. Written, Formally Adopted, and Implemented

5. Applies Uniformly

6. Enforced

D. Ineligible Upgrades

E. Accessibility for Individuals with Disabilities

F. Path of Travel

G. Permit Requirements

H. Additional Resources

III. Hazard Mitigation

A. Eligibility Criteria

B. Future Damage Reduction

1. Cost Effectiveness

2. Compliance with Legal Requirements

3. Proposing PA Hazard Mitigation

4. Reduce Adverse impacts

5. Post-Repair Hazard Mitigation

6. Completed Hazard Mitigation Eligibility

C. Historic Preservation Compliance

1. Federal Requirement

2. State, Tribal Nation, or Territorial Government Requirement

D. Public Assistance Mitigation Funds for Capped Projects

1. Improved Project

2. Alternate Project

E. Construction Method

F. Pre-Existing Site Conditions

IV. Flexible Restoration (Capped Projects)

A. Processing Projects with Capped Funding

B. Improved Project

1. Use of Improved Project Funds

C. Alternate Project

1. Use of Alternate Project Funds

V. Eligibility Considerations by Facility

A. Roads and Bridges (Category C)

1. Components

2. Road and Bridge Eligibility for Permanent Work

3. Types of Damage

i. Deterioration, Deferred Maintenance, Negligence

ii. Scour and Erosion

4. Inundated and Submerged Roads

i. Inundated Roads with Visible Damage

a. Documentation to Support Claimed Damage

ii. Inundated Roads without Visible Surface Damage

a. Projected Loss of Useful Service Life

iii. Surface Damage Resulting from Reopening Roads Prematurely

iv. Closed Basin Flooding

a. Documentation to Support Claimed Damage for Closed Basin Flooding

v. Gravel Roads

a. Documentation and Information to Support Gravel Loss

b. Documentation and Information to Support Gravel Road Rutting

5. Demonstrating Disaster-Related Damage

B. Water Control Facilities (Category D)

1. Restoring the Capacity of Channels, Basins, and Reservoirs

2. Flood Control Works

C. Buildings and Equipment (Category E)

1. Buildings

i. Earthquake Damage to Welded Steel Moment Frame Buildings

2. Contents and Supplies

i. Files

ii. Library Books and Publications

iii. Irreplaceable Collections and Individual Objects

iv. Research-Related Contents

v. Animals

3. Equipment

4. Vehicles

D. Utilities (Category F)

1. Power Restoration

2. Right-of-Way Clearance

3. Power: Transmission and Distribution System Conductor Replacement

E. Parks, Recreational, Other (Category G)

1. Beaches

F. Landslides and Slope Stabilization

VI. Repair vs. Replacement

A. Calculation

B. Request for Replacement

C. Eligible Funding

D. Replacement of Components of a Facility or System

VII. Relocation

A. FEMA-Directed Relocation

B. Applicant-Driven: Repair vs. Replacement

C. Code-Driven: Part 9 and Other Code and Standard Relocations

D. Eligible Work and Funding

E. Sale or Lease of Property at Original Site

VIII. Environmental and Historic Preservation Requirements

A. Floodplain Management and Wetland Protection

1. Critical Actions

i. Potential Critical Actions

ii. Non-Critical Actions

2. Coastal High Hazard Areas

3. Requirement for Communities Participating in the National Flood Insurance

Program

IX. Facility Located in or Impacting a Floodplain

A. 8-Step Decision-making Process

B. Hydrologic and Hydraulic Studies

C. Facility Located in a Special Flood Hazard Area

1. National Flood Insurance Program

X. Requirement to Obtain and Maintain Insurance

A. Failure to Obtain and Maintain Insurance

XI. Building Code and Floodplain Management Administration and Enforcement (Category I)

A. General Requirements

B. Eligible Work

1. Building Code Administration

2. Code Enforcement

3. Floodplain Management Ordinance and Enforcement

4. Substantial Damage Determinations

C. Ineligible Work

D. Required Documentation and Information for Category I Work

Chapter 9: Scoping, Costing, and Final Reviews

I. Scope of Work Development

A. Traditional Tribal Residential and Ceremonial Structures – Inspecting, Scoping, & Estimating

II. Cost Development

A. Project Thresholds

B. Expedited Projects for Emergency Work

C. Costs for Projects with All Work Completed

D. Estimating Emergency Work Projects with Work to be Completed

E. Estimating Permanent Work Projects with Work to be Completed

1. Projects Requiring Engineering Analysis

2. Applicant Estimates

3. FEMA Estimates

4. Insurance Reductions

III. Compliance Reviews

IV. Obligation

A. Obtaining Funds

B. Strategic Funds Management

Chapter 10: Environmental and Historic Preservation

I. EHP Compliance

A. EHP Compliance Review

1. Required Information and Documentation

B. Projects that Qualify for Streamlined EHP Review

C. Projects Requiring Complex EHP Review

1. Emergency Work (Categories A and B)

2. Debris Removal (Category A)

3. Emergency Protective Measures (Category B)

4. Permanent Work (Categories C-G)

i. Disposition of Original Facility

D. Navigating the EHP Compliance Process

E. Understanding EHP Laws and Executive Orders

1. National Environmental Policy Act

2. National Historic Preservation Act

3. Endangered Species Act

4. Executive Orders 11988 & 11990: Floodplain Management and Wetlands

Protection

5. Coastal Barrier Resources Act

6. Clean Water Act

F. Coordination with Other Federal Agencies

1. Unified Federal Review

G. Partnerships and Resources

1. Heritage Emergency National Task Force

H. Resource Links

Chapter 11: Project Monitoring and Amendments

I. Post Award Change in Scope of Work

II. Work Completion Deadlines

A. Project Schedule

III. Large Project Quarterly Progress Reports

IV. Financial Status Reports

V. Federal Funding Accountability and Transparency Act

VI. Audits

A. Single Audits

B. Government Accountability Office

C. Office of the Inspector General

1. Report Fraud

D. FEMA Office of Civil Rights

E. Recovery of Improper Payments

Chapter 12: Final Reconciliation and Closeout

I. Project Reconciliation and Closeout

A. Small Projects

1. Net Small Project Overrun Appeal Request

2. Small Project Closeout

B. Large Projects

C. Subrecipients

II. Stafford Act Section 705

III. Public Assistance Award Closeout

IV. Documentation Retention Requirements

Appendix A. References and Resources

I. Public Assistance Program References

II. Public Assistance Forms and Templates

III. Statutes

IV. Code of Federal Regulations

V. Environmental Protection Laws

VI. Executive Orders

VII. Historic Preservation Laws and Tools

VIII. Federal Emergency Management Agency References

IX. Other Federal Agencies

Appendix B. Acronyms

Appendix C. Terms and Definitions

Appendix D: Environmental and Historic Preservation Compliance

I. National Environmental Policy Act

II. National Historic Preservation Act

III. Endangered Species Act

IV. Clean Water Act

V. Rivers and Harbors Act

VI. Safe Drinking Water Act

VII. Clean Air Act

VIII. Coastal Barrier Resources Act

IX. Migratory Bird Treaty Act

X. Bald and Golden Eagle Protection Act

XI. Magnuson-Stevens Fishery Conservation and Management Act

XII. Marine Mammal Protection Act

XIII. National Marine Sanctuaries Act

XIV. Coastal Zone Management Act

XV. Farmland Protection Policy Act

XVI. Wild and Scenic Rivers Act

XVII. Resource Conservation and Recovery Act

XVIII. Comprehensive Environmental Response, Compensation and Liability Act

XIX. Executive Order 11988, Floodplain Management

XX. Executive Order 11990, Protection of Wetlands

XXI. Executive Order 13112, Invasive Species

Appendix E: Private Nonprofit Facility Eligibility Examples

I. Facility Owned by PNP – PNP Leases Portion of Facility to For-Profit Service

II. PNP Recreational Center Providing Eligible Services

III. Support Facility Owned by PNP

IV. Facilities Owned by PNP Homeowners’ Association

V. Recreational Center – Primarily Athletic Services

VI. Mixed Use Community Center – Nominal Fee

VII. School Operated by a Religious Institution

VIII. Religious Institution with a Dock, a Church, and a Pastor’s Residence

Appendix F: Mosquito Abatement

Appendix G: Alternative Procedures for Permanent Work

I. Differences Between Standard and Alternative Procedures

II. Fixed Cost Estimate

A. Architectural, Engineering, Environmental Review, and Design Fees

B. Construction and Other Restoration Costs

C. Expert Panel Cost Estimate Review

D. Public Assistance Hazard Mitigation

III. Fixed Cost Offer

A. Fixed Cost Offer Deadlines

IV. Use of Funding

A. Excess Funds

III. Scope of Work Changes

IV. Closeout Requirements

V. Other Considerations

A. Requirement to Obtain and Maintain Insurance

B. Appeals for Alternative Procedures Projects

C. Office of the Inspector General

Appendix H: Mold Remediation

I. Mold Remediation Methods

II. Application of Remediation Methods

Appendix I: Work Eligibility Considerations by Type of Facility

I. General Work Eligibility Considerations for Facilities

II. Work Eligibility Considerations for Roads and Bridges

III. Work Eligibility Considerations for Water Control Facilities

IV. Work Eligibility Considerations for Buildings, Equipment, and Vehicles

V. Work Eligibility Considerations for Contents

VI. Work Eligibility Considerations for Utilities

VII. Work Eligibility Considerations for Parks, Recreation, and Other

Appendix J: Cost-Effective Public Assistance Hazard Mitigation Measures

I. Drainage Structures

II. Transportation Facilities

III. Mechanical, Electrical, Plumbing Components

IV. Pipes

V. Water/Wastewater

VI. Electric Power Systems

VII. Storage Tanks

VIII. Buildings and Structures

IX. Signage

Appendix K: Snow Declarations

I. Record or Near-Record Snowfall

II. Winter Storm or Snowstorm Declaration Requests

Appendix L: Validation of Applicant-Provided Cost Estimates

Appendix M. Consensus-Based Codes, Specifications, and Standards

Tables

Table 1. List of Changes and Clarifications Grouped by General Topic Table 2. SBA Loan Requirements Table 3. PNP Eligible Critical Services Table 4. PNP Eligible Noncritical, Essential Social Services Table 5. PNP Ineligible Services Table 6. Required Documentation and Information for PNP RPA Table 7. Documentation and Information to Support Cause of Impacts and Damage Table 8. Required Documentation and Information to Support Within Declared Area Table 9. Required Documentation and Information to Support Legal Responsibility Table 10. Required Documentation and Information for Labor Costs Table 11. Emergency Work Labor Eligibility Table 12. Required Documentation and Information for Applicant-Owned or Purchased Equipment Costs Table 13. Required Documentation and Information for Rented or Leased Equipment Costs Table 14. Required Documentation and Information for Materials and Supplies Costs Table 15. Required Documentation and Information for Contract Costs Table 16. Required Documentation and Information for Mutual Aid Costs Table 17. Required Documentation and Information for Prison Labor Costs Table 18. Required Documentation and Information for Offset Values for Donated Resources Table 19. Required Documentation and Information for Insurance Proceeds Table 20. Required Documentation and Information for Work Eligibility Table 21. Required Documentation and Information for Debris Removal and Disposal Table 22. Required Documentation and Information for PPDR Table 23. Required Documentation and Information to Support Damage to Inundated or Submerged Roads Table 24. Required Information to Support Damage Resulting from Reopening Roads Prematurely Table 25. Required Documentation and Information to Support Closed Basin Flooding Table 26. Required Documentation and Information to Support Gravel Loss Table 27. Required Documentation and Information to Support Gravel Road Rutting Table 28. Required Documentation and Information to Support Pre-Incident Capacity of Channels, Basins, and Reservoirs Table 29. Required Documentation and Information to Support Pre-Disaster Conductor Condition 204 Table 30. Required Documentation and Information for Category I Work Table 31. Required Documentation and Information to Support Scope of Work Changes Table 32. Deadlines for Submitting Quarterly Progress Reports Table 33. Required Documentation and Information for Quarterly Progress Reports Table 34. Required Documentation and Information to Support a Large Project Closeout Request 255 Table 35. Differences Between Standard and Alternative Procedures Table 36. Eligible Work and Costs for Use of Fixed Cost and Excess Funds Table 37. Mold Remediation Methods Table 38. Application of Mold Remediation Methods Table 39. Work Eligibility Considerations: All Facilities Table 40. Work Eligibility Considerations: Roads and Bridges Table 41. Work Eligibility Considerations: Water Control Facilities Table 42. Work Eligibility Considerations: Buildings, Equipment, and Vehicles Table 43. Work Eligibility Considerations: Contents Table 44. Work Eligibility Considerations: Utilities Table 45. Work Eligibility Considerations: Parks, Recreation, and Other

Table 46. Standard Setting Organization and Consensus-Based Codes, Specifications, and Standards by Facility Type

Figures

Figure 1. 44 C.F.R Figure 2. PA Eligibility Pyramid Figure 3. Applicant Eligibility Figure 4. PNP Eligibility Figure 5. SBA Loan Outcomes Figure 6. Facility Eligibility Figure 7. Categories of Work Figure 8. Cost Eligibility Figure 9. Emergency Work Eligibility Figure 10. Immediate Threats Figure 11. Debris on Public Property Figure 12. Distribution of Supplies Figure 13. Staging Area with Ambulances Figure 14. Evacuees Boarding a Bus Figure 15. Determining Eligibility of Emergency Berms on Beaches Figure 16. Permanent Work Eligibility Figure 17. Path of Travel Figure 18. PA Hazard Mitigation Process Flowchart Figure 19. Typical Beach Profile Figure 20. Category I Work Eligibility Figure 21. Work Completion Deadlines

Summary of Changes This PAPPG version incorporates the following changes:

Table 1. List of Changes and Clarifications Grouped by General Topic

Topic Highlighted V5 Improvements

Tribal Nations To support the protection of tribal significant artifacts, culturally sensitive landscapes and sites, cultural resources, and human remains; clarified that FEMA will not require photos, site maps, and specific location details (such as GPS coordinates) for locations where these cultural artifacts are located;

Clarified that FEMA will accept a Tribal Nation’s certified damage assessment, scope of work for restoration, and estimated costs for traditional tribal residences or tribal ceremonial buildings;

Clarified that for locations where only tribal members are allowed, site inspections by FEMA staff are not permitted;

Clarified that mutual aid agreements or memoranda of understanding are available resources for Tribal Nations and provided guidance on reimbursement when there is no pre-existing written agreement; and, Clarified that if a Tribal Nation received funding from the Bureau of Indian Affairs or Federal Highway Administration for construction or maintenance of tribal roads, those roads are still eligible for FEMA PA funding under a presidentially declared disaster.

Resilience Included language about resilience considerations throughout;

Clarified that PA mitigation measures can be implemented for all hazards, not just the hazard that caused the damage;

Added information and reference to the benefit-cost analysis (BCA)

Toolkit;

Increased opportunities to mitigate improved projects involving facility replacement or relocation; and, Expanded Appendix J to include additional measures, with two measures focused on wildfire

Simplification As a result of stakeholder feedback, removed non-regulatory processes for inclusion in other PA guidance;

Where possible, removed “may” and “should,” and replaced with “must” to clarify requirements; and, Redefined acronyms at the beginning of each chapter and reduced acronym use.

Topic Highlighted V5 Improvements

Documentation and Requirements

Clarified documentation and information requirements for small projects and large projects;

Reduced documentation and information requirements for small projects;

Incorporated PA’s sampling procedures;

Clarified that maintenance records are not always required to substantiate damage;

Included more options for documentation to support legal responsibility; and, Removed requirement for pre-approval prior to completing private property debris removal.

Added Content Incorporated Validated as You Go (VAYGo) content and resources;

Added subsection titled “Telecommunications Equipment Purchase;”

Added “self-insurance or self-insured retention” to list of insurance types; and, Included insurance commitment opportunities which benefit applicants experiencing subsequent disasters.

Clarifications Clarified road damage from damage caused by submerged and inundated as distinct types of damage;

Clarified that snow assistance is not authorized for emergency declarations; and, Conveyed FEMA’s support to report suspicious activities as well as who and how to report.

Private Non-Profit (PNP) Consolidated private non-profit information into one section;

Explained for-profit entities’ ineligibility; and, Clarified that Houses of Worship and faith-based organizations are considered private nonprofit organizations.

Sheltering Removed pre-approval requirement for non-congregate sheltering activities in traditional settings (i.e., hotels/motels, dormitories, etc.);

Removed childcare services as a standalone emergency protective measure and is now only eligible when associated with emergency sheltering; and, Expanded emergency sheltering eligibility to include survivors’ “household pets, service animals, assistance animals” and removed requirement for pet owners to be sheltered for pet sheltering to be eligible.

Topic Highlighted V5 Improvements

Environmental and Historic Preservation (EHP)

Explained and provided examples of projects that have potential to impact EHP resources;

Provided guidance on navigating the EHP compliance process;

Clarified documentation requirements for streamlined EHP reviews and complex EHP reviews;

Provided EHP considerations by category of work; and, Provided examples of project types that may have impacts to natural and cultural resources.

Statutory and Regulatory Updates

Incorporated the revision to 2 C.F.R. Part 200 which integrates Office of Management and Budget (OMB)'s policy priorities and strives to reduce agency and recipient burden;

Updated guidance from the Payment Integrity Information Act, which supersedes the Improper Payments Elimination and Recovery Improvement Act; and, Added compliance with EO 14148, Initial Recissions of Harmful Executive Orders and Actions

Policy and Guidance Documents Incorporated and Superseded Building Code and Floodplain Management Administration and Enforcement

(FEMA Policy 204-079-01)

“Combining Wildfires Under a Major Disaster Declaration” Memo (August 21, 2021)

Consensus-Based Codes, Specifications, and Standards for Public Assistance (FEMA Recovery Interim Policy 104-009-11 Version 2)

“Emergency NCS” Memo (June 28, 2022)

Mission Assignments (FEMA Policy 104-010-3)

Public Assistance Appeals and Arbitration (FEMA Policy 104-22-0001)

Public Assistance Guidance on Inundated and Submerged Roads (FEMA Policy 104-009-13)

Public Assistance Simplified Procedures (FEMA Policy 104-23-001)

“Recovery Program Enhancements to Support Tribal Nations” Memo (November 22, 2023)

“Simplifying the PA Management Costs” Memo (March 01, 2023)

“Simplifying the PA Program 1” Memo (March 28, 2022)

“Simplifying the PA Program 2” Memo (September 6, 2022)

“Wildfire Policy Guidance” Memo (October 17, 2022)

Tribal Declarations Interim Guidance (FP 104-009025-001) https://www.whitehouse.gov/presidential-actions/2025/01/initial-rescissions-of-harmful-executive-orders-and-actions/ https://www.whitehouse.gov/presidential-actions/2025/01/initial-rescissions-of-harmful-executive-orders-and-actions/

(For a list of guidance documents summarized and referenced, please see the Appendix A: References and Resources list.)

Introduction I. Document Scope, Purpose, and Use The Federal Emergency Management Agency’s (FEMA’s) “Public Assistance Program Policy Guide” (PAPPG) contains consolidated Public Assistance (PA) Program policies and procedural requirements for the entire program delivery life cycle. The PAPPG provides comprehensive PA policy to use when evaluating eligibility.

The PAPPG references and provides links to other FEMA policies and documents such as standard operating procedures and fact sheets that provide guidance for those involved with implementing each of the various steps.

Based on extensive feedback from internal and external stakeholders, this version of the PAPPG no longer includes content focused on FEMA’s internal processes. Instead, a new companion document for FEMA staff known as the “Public Assistance Program Delivery Guide”2 provides an overview of how FEMA implements the PA Program.

II. Applicability FEMA applies Version 5 of the PAPPG to incidents declared on or after January 6, 2025. Individuals who have responsibilities managing, implementing, or relating to the PA Program should refer to the PAPPG for PA policy and regulatory procedural requirements.

III. Document Management and Maintenance FEMA generally publishes proposed PA policy language for public comment prior to publishing in the PAPPG.3 When the policy is deemed economically significant,4 FEMA generally publishes it in the Federal Register. Additionally, FEMA is committed to strengthening its nation-to-nation relationship and will consult with tribal officials on actions that have tribal implications.5 FEMA conducts a comprehensive review of this publication no less than every three years. All recommendations for the PAPPG should be sent to FEMA- Recovery-PA-Policy@fema.dhs.gov.

IV. Public Assistance Program Overview The mission of FEMA’s PA Program is to provide assistance to state, local, Tribal Nation, and territorial (SLTT) governments and certain types of private nonprofit (PNP) organizations so that communities can quickly respond to and recover from major disasters or emergencies. Through the PA Program, FEMA provides supplemental federal grant assistance for debris removal, emergency protective measures, and the restoration of disaster-damaged, publicly owned facilities, and specific facilities of certain PNP organizations.

The PA Program also encourages protection of these damaged facilities from future incidents by providing

2 For more information, refer to: Public Assistance Program Delivery Guide.

3 Stafford Act § 325; 42 United States Code (U.S.C.) § 5165c.

4 EO 12866, Regulatory Planning and Review.

5 FEMA Tribal Consultation Policy FEMA Policy #101-002-02.

mailto:FEMA-Recovery-PA-Policy@fema.dhs.gov mailto:FEMA-Recovery-PA-Policy@fema.dhs.gov https://www.fema.gov/assistance/public/library?name=program+delivery&field_keywords_target_id=All https://www.fema.gov/about/organization/tribal-affairs/consultations assistance for hazard mitigation measures and code compliance. FEMA provides this assistance based on the authority granted in statutes, executive orders (EOs), regulations, and policies.

Along with the PAPPG, there are many resources that help navigate the PA Program. References, including EOs, policies, regulations, and laws are available in the Appendix A: References and Resources. The Public Assistance Resource Library6 contains general program guidance that focuses on restoring communities affected by major disasters or emergencies. The “Public Assistance Program Delivery Guide”7 also contains additional process information and context for the PA Program; while its primary audience is FEMA staff, SLTT partners may find it a useful resource. Lastly, definitions for terms used throughout this document can be found in Appendix C. Terms and Definitions.

V. Authorities FEMA provides assistance based on authorities defined in statutes and regulations. These authorities specify requirements that must be met by both FEMA and the communities it serves.

A. Statutes Statutes are federal laws passed by the U.S. Congress and signed by the president. All PA Program assistance must comply with all applicable statutes. The Robert T. Stafford Disaster Relief and Emergency Assistance Act, as amended (Stafford Act), Title 42 of the United States Code (U.S.C.) § 5121 et seq.

authorizes FEMA to provide assistance under the PA Program.

1. STAFFORD ACT

Stafford Act sections that apply to the assistance FEMA provides under the PA Program include:

Title I – Findings, Declarations and Definitions

Title III – Major Disaster and Emergency Assistance Administration o Sec. 308. Nondiscrimination in Disaster Assistance o Sec. 311. Insurance o Sec. 312. Duplication of Benefits o Sec. 316. Protection of Environment o Sec. 323. Minimum Standards for Public and Private Structures o Sec. 324. Management Costs

Title IV – Major Disaster Assistance Programs (applies to Major Disaster Declarations) o Sec. 403. Essential Assistance o Sec. 406. Repair, Restoration, and Replacement of Damaged Facilities o Sec. 407. Debris Removal

6 For more information, refer to: Public Assistance Resource Library | FEMA.gov.

7 For more information, refer to: Public Assistance Program Delivery Guide.

https://www.fema.gov/assistance/public/library https://www.fema.gov/assistance/public/library?name=program+delivery&field_keywords_target_id=All o Sec. 422. Simplified Procedures o Sec. 428. Public Assistance Program Alternative Procedures

Title V – Emergency Assistance Programs (applies to Emergency Declarations) o Sec. 502. Federal Emergency Assistance

Title VII – Miscellaneous o Sec. 705. Disaster Grant Closeout Procedures

2. OTHER STATUTES

Americans with Disabilities Act of 1990

Sections 504 and 508 of the Rehabilitation Act of 1973

Civil Rights Act of 1964

Federally Recognized Tribe List Act of 1994

Environmental and Historic Preservation Acts

Payment Integrity Information Act of 2019

Executive Order 13175, Consultation and Coordination with Indian Tribal Governments

Presidential Memorandum of November 5, 2009, Tribal Consultation

Federally Recognized Tribe List Act of 1994

Fair Labor Standards Act

B. Regulations Regulations8 are federal rules with the force and effect of law that implement a statute based on a federal agency’s interpretation of that statute.9 FEMA and any entity receiving PA assistance must comply with all applicable federal regulations.10

1. TITLE 44 OF THE CODE OF FEDERAL REGULATIONS

FEMA published PA Program rules in the following parts of Title 44 of the Code of Federal Regulations (C.F.R.), Emergency Management and Assistance:11

Part 206 Subpart G, Public Assistance Project Administration;

Part 206 Subpart H, Public Assistance Eligibility; and

Part 206 Subpart I, Public Assistance Insurance Requirements.

8 For the electronic version for the C.F.R., refer to: eCFR.

9 Stafford Act § 321; 42 U.S.C. § 5164.

10 44 C.F.R. § 206.200(b).

11 Stafford Act § 325; 42 U.S.C. § 5165c; 44 C.F.R. § 1.4.

Figure 1. 44 C.F.R.

https://www.ecfr.gov/

Additional regulations that must be adhered to when receiving funding through the PA Program:

Part 7 Subpart A, Nondiscrimination in FEMA-Assisted Programs – General

Part 7 Subpart E, Nondiscrimination on the Basis of Age in Programs or Activities Receiving Federal Financial Assistance from FEMA

Part 9, Floodplain Management and Protection of Wetlands

Part 201, Mitigation Planning

Part 204, Fire Management Assistance Grant (FMAG) Program

Part 206, Federal Disaster Assistance

2. TITLE 2 OF THE CODE OF FEDERAL REGULATIONS

The Office of Management and Budget published 2 C.F.R. Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards to establish uniform rules for federal awards, including but not limited to:

Subpart C – Pre-Federal Award Requirements and Contents of Federal Awards

Subpart E – Cost Principles

Subpart F – Audit requirements

Subpart D – Post Federal Award Requirements

Appendix II - Contract provisions for non-federal entity contract under federal awards, and

Appendix VI - PA Cost Allocation Plans

3. OTHER C.F.R.

7 C.F.R. § 1730.25, Corrective action (Rural Utilities Service [RUS] borrowers only)

15 C.F.R. Part 774, The Commerce Control List

22 C.F.R. Part 121, The United States Munitions List

40 C.F.R. Part 261, Identification and Listing of Hazardous Waste

48 C.F.R. Subpart 2.1, Federal Acquisition Regulation

C. Policy FEMA issues policy to articulate the Agency’s intent and direction in applying statutory and regulatory authority to achieve desired outcomes. The purpose of the PAPPG is to define FEMA’s PA Program policy and procedural requirements. Separate FEMA policies and guidance documents that apply to the PA Program are referenced in the PAPPG where applicable and listed in the Appendix A: References and Resources section.

PA funding must comply with these requirements. Only the Associate Administrator of Recovery at FEMA Headquarters has the authority to modify or waive PA policy.

D. Public Assistance Web-Based Grants System FEMA uses web-based systems to promote transparency and manage project information. Recipients and applicants use PA Grants Portal12 to submit documentation and information, review all aspects of Public PA project applications, and track the progress of their applications. FEMA uses PA Grants Manager13 to review Requests for Public Assistance (RPA), oversee the development and review of project applications, track application progress, and receive necessary information from recipients and applicants.

12 For more information, refer to: Grants Portal.

13 For more information, refer to: Grants Manager.

https://grantee.fema.gov/ https://pagrants.fema.gov/Account/Login?ReturnUrl=%2f

Chapter 1: Declarations and Planning The Stafford Act authorizes the president to provide federal assistance when the magnitude of an incident or threatened incident exceeds the affected state,14 local,15 Tribal Nation,16 and territorial (SLTT) government capabilities to respond and recover. This chapter explains requirements for damage assessments, declaration requests and FEMA’s evaluation criteria, the contents of the declaration, and the initial administrative requirements for a state, Tribal Nation, and territorial (STT) government to receive assistance.

I. Damage Assessments After an incident causes widespread damage, the STT government conducts an initial damage assessment before requesting a joint Preliminary Damage Assessment (PDA) to confirm the need for federal assistance.17 When the STT government determines that the incident exceeds its ability to respond, it requests a joint PDA with FEMA. This initial damage assessment should identify affected jurisdictions, damaged infrastructure, and provide preliminary cost estimates for response and recovery efforts.

Additionally, the STT collects data to assess the need for federal assistance, including evaluating local resource capacity to support ongoing response and recovery.

During a joint PDA, FEMA, SLTT governments, and certain private nonprofit (PNP) organization officials work together to estimate and document the impact and magnitude of the incident.18 Accurate and comprehensive PDAs are critical to enabling efficient response and recovery. FEMA’s “Preliminary Damage Assessment Guide”19 provides detailed information to assist staff involved with damage assessments and describes how FEMA utilizes the information when preparing requests for major disaster declarations. For example, applicants must provide insurance policies when requested during a PDA as FEMA only considers