Lesson 5 Overview and Objectives

This lesson provides an overview of project deadlines, processes, and procedures for requesting time extensions. This lesson also explains the relationship between the period of performance and project deadlines for the Applicant to receive Public Assistance grant funding.

At the end of this lesson, participants will be able to:

  • Describe project deadlines
  • Discuss time extension procedures and processes
  • Explain the relationship between the period of performance and project deadlines
Project Deadlines

FEMA only provides Public Assistance funding for work completed and costs incurred within regulatory deadlines. The deadline for Emergency Work is six months from the declaration date. The deadline for Permanent Work is 18 months from the declaration date.

If an Applicant determines the need for additional time to complete a project, including direct administrative costs related to the project, the Applicant must submit a written request for a time extension to the Recipient with the following information:

  • Documentation substantiating delays beyond its control
  • A detailed justification for the delay
  • Status of the work
  • The project timeline with the projected completion date
Waterfront homes and roads damaged by a storm surge from Hurricane Ike.
Time Extension Requests (1 of 2)

The Recipient has authority to extend deadlines for individual projects based on extenuating circumstances. It may extend Emergency Work projects by six months and Permanent Work projects by 30 months. FEMA has authority to extend individual project deadlines beyond these timeframes if extenuating circumstances justify additional time.

 FEMA generally considers some of the following to be extenuating circumstances beyond the Applicant's control:

  • Permitting or Environmental and Historic Preservation compliance delays due to other agencies involved
  • Environmental limitations (such as short construction window)
  • Inclement weather (site access prohibited or adverse impact on construction)
  • Magnitude of the event, such as catastrophic disasters
A community damaged by Hurricane Katrina in Louisiana.
Time Extension Requests (2 of 2)

FEMA generally considers the following to be circumstances within the control of the Applicant and NOT justifiable for a time extension:

  • Permitting or environmental delays due to Applicant delays in requesting permits
  • Lack of funding
  • Change in administration or cost accounting system
  • Compilation of cost documentation

FEMA only provides Public Assistance funding for work performed on or before the approved deadline.

FEMA staff performing a site inspection.
Time Extension Document and Submission Requirements

A time extension request should be submitted by the Recipient to the Regional Administrator prior to the current approved deadline. It must be specific to one project and include the following information with supporting documentation:

  • Dates and provisions of all previous time extensions
  • Construction timeline/project schedule in support of requested time extension
  • Basis for the time extension request, including specific details about the following:
    • Delay in obtaining permits, including permitting agencies involved and application dates
    • Environmental delays or limitations, such as short a construction window or nesting seasons, including dates of correspondence with various agencies
    • Inclement weather, such as prolonged severe weather conditions prohibiting access to the area or adversely impacting construction
    • Any other reason for the delay
A man typing on a laptop computer.
Time Extension Approval Process

The Regional Administrator will review the request and make a determination. The Recipient will be notified of the Regional Administrator's determination in writing. If the Regional Administrator approves the request, the letter shall reflect the approved completion date and any other requirements the Regional Administrator may determine necessary to ensure that the new completion date is met.

If the Regional Administrator denies the time extension request, the Recipient may, upon completion of the project, be reimbursed for eligible project costs incurred only up to the latest approved completion date. If the project is not completed, no Federal funding will be provided for that project.

Hands typing on a laptop that says "schedule," with a notebook, pen, and documents.
Time Extension Request Reconciliation and Closeout

All approved time extension documents will be available for the Recipient to review in the project file in EMMIE. Once all work has been completed, the Applicant should close out the project to certify that the work is complete. FEMA will close Large Projects individually as each is completed. FEMA closes all Small Projects together when the last Small Project is completed.

To ensure a timely closeout process, the Applicant should notify the Recipient immediately as it completes each Large Project and when it has completed its last Small Project. The Applicant should include the following information with its closeout request:
  • Certification that project is complete
  • Date of project completion
  • Copies of any Recipient time extensions
Business woman working on a laptop in an office.
Closing Out Large Projects (1 of 3)

With the exception of Capped Projects, the final eligible amount for a Large Project is the actual documented cost of the completed, eligible scope of work. Therefore, upon completion of each Large Project that FEMA obligated based on an estimated amount, the Applicant should provide documentation to support the actual costs. If the actual costs significantly differ from the estimated amount, the Applicant should provide an explanation and supporting documentation for the difference.

A person's hands typing on a calculator and opening a folder of documents.
Closing Out Large Projects (2 of 3)

The Recipient must certify that all incurred costs are associated with the approved scope of work and that the Applicant completed all work in accordance with FEMA regulations and policies. The Recipient must submit its certification of the Applicant's completion of each Large Project with the final payment of claim and supporting documentation to FEMA within 180 days from the date that the Applicant completes each Large Project.

The Recipient must also submit its certification of each of its own Large Projects within 180 days of the date of completion. FEMA reviews the documentation and, if necessary, obligates additional funds or reduces funding based on actual costs to complete the eligible scope of work.

A woman's hand pointing at a calendar with a pen, with a laptop in the background.
Closing Out Large Projects (3 of 3)

If the project included approved hazard mitigation measures, FEMA does not re-evaluate the cost-effectiveness of the Hazard Mitigation Program based on the final actual cost. If during the review, FEMA determines that the Applicant performed work that was not included in the approved scope of work, FEMA will designate the project as an Improved Project, cap the funding at the original estimated amount, and review the additional scope of work for Environmental and Historic Preservation compliance.

For Capped Projects, the Applicant must provide documentation to support that it used the funds in accordance with the eligibility criteria described in Chapter 2:VII.G and guidance provided on the Alternative Procedures site. If the amount expended is less than the Capped Project amount, FEMA reduces the funding. Once FEMA completes the necessary review and funding adjustments, FEMA closes the project.

A FEMA Public Assistance specialist working on a computer.
Closing Out Small Projects (1 of 3)

Once FEMA obligates a Small Project, FEMA does not adjust the approved amount of an individual Small Project. This applies even when FEMA obligates the project based on an estimate, and actual costs for completing the eligible scope of work differ from the estimated amount. FEMA only adjusts the approved amount on individual Small Projects if one of the following conditions applies:

  • Applicant did not complete the approved scope of work
  • Applicant requests additional funds related to an eligible change in the scope of work
  • Project contains inadvertent errors or omissions
  • Actual insurance proceeds differ from the amount deducted in the project

 In these cases, FEMA only adjusts the specific cost items affected.

A Public Assistance Project Specialist records data about a new water heater in a school in Wisconsin.
Closing Out Small Projects (2 of 3)

If the individual Small Project amount cannot be adjusted, the Applicant may request additional funding if the total actual cost of all its Small Projects combined exceeds the total amount obligated for all its Small Projects.

FEMA refers to this as a Net Small Project Overrun Appeal. The appeal must include actual cost documentation for all Small Projects that FEMA originally funded based on estimate amounts.

Stacks of papers and books 325x527 (jpg)
Closing Out Small Projects (3 of 3)

To close Small Projects, the Recipient must certify that the Applicant completed the approved scope of work for all its Small Projects. The Recipient must submit the certification of completion for all the Applicant's small projects to FEMA within 180 days from the date that the Applicant completes its last Small Project.

The Recipient must also submit certification of completion for all its own Small Projects within 180 days of the date of completion of its last Small Project. Once FEMA receives the Recipient's certification, FEMA closes all of the Applicant's Small Projects.

A restaurant that is now open for business after having been partially flooded during Hurricane Sandy.
Period of Performance and Project Deadlines (1 of 2)

As discussed previously, the Period of Performance is the period of time during which the Applicant is expected to complete all physical work and to incur and expend approved funds. Applicants are responsible for ensuring that all approved activities are completed by the end of the grant Period of Performance.

During the performance of eligible work, project completion deadlines are set from the date that a major disaster or emergency is declared and apply to all projects approved under State disaster assistance grants.

Work in progress to restore a community center in North Carolina.
Period of Performance and Project Deadlines (2 of 2)

Although the Period of Performance is established up front, the Recipient can close out the grant earlier. If all projects have been completed, then the Recipient should request grant closeout before the Period of Performance expires.

Alternatively, an Applicant may request to extend the Period of Performance and project deadlines if faced with extenuating circumstances or unusual project requirements beyond the Applicant's control. The Recipient may extend the deadlines for an additional six months for debris clearance and emergency work; and an additional 30 months, on a project by project basis, for permanent work. Any extensions beyond the Recipients authority must be sent to the FEMA Regional Administrator for consideration.

Piles of debris collected from Sanford, FL neighborhoods.
Lesson 5 Summary

In this lesson, you learned how to:

  • Describe project deadlines
  • Discuss time extension procedures and processes
  • Explain the relationship between the period of performance and project deadlines

The next lesson will review the course objectives. Participants will take a Post-Course Assessment and complete the Course Evaluation Form.