During the performance of FEMA Public Assistance-related projects, work processes are expected to commence as stated and funds are expected to be obligated/disbursed for approved Scopes of Work. However, there are times when circumstances beyond the Applicant's control cause the project to turn out differently than planned. For example, Applicants may discover hidden damage, additional work needed for proper completion, delays in the work schedule, or costs becoming higher than estimated.

When participating in the Public Assistance program, Applicants and Recipients must follow specific procedures to ensure that FEMA is notified of all changes that occur. The Applicant should engage the Recipient and FEMA as soon as changes to the scope of work are identified. This will allow FEMA time to review changes for eligibility, as well as special considerations requirements, before the Applicant begins the work. If the Applicant begins work associated with a change before FEMA review and approval, Public Assistance funding may be jeopardized.

There are several instances which may result in a change in the scope of work, including:

• Improved Projects
• Alternate Projects
• Hazard Mitigation
• Environmental and historic preservation discoveries
• Alternative Procedures

Here are some examples of revisions to the scope of work that FEMA may approve:

• Applicant discovers damage not visible during the site inspection
• Applicant discovers hidden damage while completing previously approved work
• Documented repair method turns out not to be feasible
• Professional recommendations for repair differ from the documented repair method, if limited to the least costly method of repairing the damage
• A project contains inadvertent errors or omissions
• Applicant wishes to pursue an Improved or Alternate Project

When requesting changes in the scope of work, Applicants must ensure that the work is performed within the FEMA Public Assistance specified Period of Performance. The Period of Performance is the time during which the non-Federal entity may incur new obligations to carry out the work authorized under the Federal award.

For the overall grant, the Period of Performance is four years from date of the declared disaster or emergency, if permanent work was declared. Applicants are responsible for ensuring that all approved activities are completed by the end of the grant Period of Performance.

The project Period of Performance to complete the work is 6 months for Emergency Work and 18 months for Permanent Work. Extensions may be granted by the Recipient or upon official request to FEMA.

If an Applicant realizes that the change in the scope of work will affect the ability to complete the project within the Period of Performance, the Applicant must request a written time extension.

We will discuss this further in Lesson 5.

For all Public Assistance funded projects, Applicants must be sure to use Public Assistance funding only for eligible work. As discussed in the last lesson, any additional work that is needed outside of the scope of work requires a change to the scope of work. This notification of additional damage or costs applies only to projects already identified and approved by FEMA.

Changes in Scope of Work due to one of the following reasons are generally eligible:

• Alternate repair method is more cost-effective than the original proposed repair method
• Original repair method is not technically feasible
• There is an increase in previously approved quantities due to errors and omissions
• Hidden, disaster-related damage is discovered during construction

Change in scope of work requests should be submitted to FEMA through the State prior to the approved project deadline and include detailed changes to the scope of work and cost estimate. The change in scope of work request must also clearly explain the reason for the scope change, including:

• Supporting documentation such as technical reports, if the original scope of work is not feasible
  
• Construction timeline/project schedule

If hidden damage is found during the performance of eligible work, the change in scope of work request must also include:

• Documentation which identifies the damage, as well as documentation which substantiates that the damage is related to the declared incident; as well as proposed scope of work to address repair of these new damages, if available
  
• Photographs documenting damage
  
• Change orders, if available

FEMA provides three options for an Applicant to use Public Assistance grant funds differently for restoring a facility to its pre-disaster design and function. These options are called Capped Projects, since FEMA caps the amount of Public Assistance funding based on the estimated amount needed to restore the damaged facility to its pre-disaster design and function.

The three capped project options are:

• Improved Project
• Alternate Project
• Alternative Procedures

The funding limit for a capped project may include some Direct Administrative Costs and indirect administrative costs based on the scope of work to restore the facility to its pre-disaster design and function. However, the capped amount does not include costs that are only related to, or only triggered by, changes to the pre-disaster design or function of the damaged facility.

These include, but are not limited to, costs related to additional:

• Engineering and design
• Environmental and Historic Preservation compliance requirements
• Work required by applicable and federally required triggered codes and standards upgrades

Each type of capped project is subject to different eligibility and process requirements, which will be discussed throughout this lesson.

An Improved Project is a capped project that restores a facility to pre-disaster function of at least the same capacity and incorporates improvements or changes to the facility's pre-disaster design that are not required by applicable codes and standards.

• Federal share of the approved estimated cost to restore the damaged facility to pre-disaster design and function
• Federal share of the actual costs of completing the Improved Project

FEMA only increases eligible funding for an Improved Project if the Applicant identifies an error or omission in the original scope of work or cost estimate related to restoring the facility to its pre-disaster design and function.

Improved facilities must serve the same pre-disaster building functions and operations to receive Public Assistance grant funding on an improved project. The Applicant is replacing rather than repairing a facility.

• Laying asphalt on a gravel road
• Repairing a firehouse that originally had two bays with a firehouse that has three bays
• Incorporating requirements dictated by a code or standard that does not meet Public Assistance eligibility criteria
• Relocating a facility when the relocation is not required by FEMA

An Alternate Project is a project that does not restore a facility to its pre-disaster function. If the Applicant determines that public welfare would not be best served by restoring a damaged facility, the Applicant may request approval from FEMA to apply Public Assistance funding toward a different facility that benefits the same community. The Alternate Project must be a permanent project that benefits the public and serves the same general area that was being served by the original facility.

• Ninety percent (75 percent for private nonprofit organizations) of the Federal share of the estimate to restore the original facility
• The Federal share of the actual cost of completing the Alternate Project

The Applicant may use Alternate Project funds to:

• Repair, expand, mitigate, or construct a facility that would otherwise be an eligible facility under the Public Assistance Program
  
• Demolish facilities
  
• Purchase capital equipment that has a useful life of at least 1 year and is equal to, or greater than, $5,000 per unit
  
• Fund project shortfalls due to mandatory flood insurance reductions taken from Public Assistance Program funding for repairs to buildings in Special Flood Hazard Areas
  
• Supplement funds for an Improved Project
  
• Conduct cost-effective hazard mitigation measures, regardless of whether the facility was damaged by the incident and whether the measures reduce the risk of future damage from the same type of incident or of the same type of damage caused by the incident

Alternate Project funds may also be used for hazard mitigation under the following conditions/criteria:

• Funding does not duplicate other FEMA mitigation funding
  
• Projects reduce the risk of future damage to a facility that is otherwise eligible either under the Public Assistance or Hazard Mitigation Assistance programs

The Applicant may NOT use Alternate Project funds to:

• Meet budget shortfalls
  
• Create a new community plan
  
• Landscape
  
• Pay for operating expenses
  
• Purchase supplies, furniture, or equipment costing less than $5,000 per unit
  
• Pay the non-Federal share of any Public Assistance project
  
• Fund buyouts for mitigation, such as acquisition of flood-prone property to create open space
  
• Supplement funds on projects that utilize other Federal agency grants
  
• Fund a project located in a FEMA-designated floodway

An Alternative Procedure is an option Applicants may use for Large Projects toward restoring a facility to its pre-disaster design and function; or toward a project that would otherwise be an Improved or Alternate Project; or for other projects, including a combination of projects.

FEMA and the Applicant must reach an agreement on the alternate procedures project within 12 months of the declaration, unless an extension is approved by the Public Assistance Director.

When the Applicant agrees to a capped project under Alternative Procedures, the Applicant may utilize any one or more of the following:

• Consolidation of multiple capped projects
  
• Elimination of reduced funding for an Alternate Project
  
• Retention of excess funds for approved purposes
  
• Third-party expert panel review for estimates with a Federal share of $5 million or greater (FEMA requires this review for estimates that exceed $25 million)

The Applicant may NOT use Alternative Procedures funds for the following:

• Facilities or equipment that are not eligible for Public Assistance funding
  
• To meet the local cost share for other Federal projects
  
• To pay down debts, cover budget shortfalls, or meet operating expenses
  
• To conduct planning and design that go beyond the work related to the project, such as communitywide planning

A Permanent Relocation Project is another option available to Applicants who need to move a facility to a new location. FEMA may approve funding for and require restoration and relocation of an Applicant's destroyed facility at a new location, when all the following conditions apply:

• The facility is subject to repetitive heavy damage because of its location
• For example, facilities located in a Special Flood Hazard Area (SFHA) are subject to repetitive heavy damage
  
• Project approval is not barred by other regulations
  
• The overall project, including all costs, is cost-effective

Eligible work and funding associated with relocation includes land acquisition and construction of necessary support facilities, such as roads, parking lots, and utilities. Demolition and removal of the original facility are also eligible if deemed necessary.

FEMA limits Public Assistance funding to the amount necessary to make the relocated facility and its associated components operational. FEMA considers the proximity of the new site to utilities (water, sewer, and electric) and approves the least costly solution. Construction of an off-site support facility is only eligible if it is a utility that would serve the relocated facility exclusively.

For land acquisition, if the facility was located on 10 acres of land at the time of the incident, and FEMA determines that 10 acres is not necessary for the operation of the facility, FEMA limits Public Assistance funding to the necessary amount of land. In situations where the Applicant owns the facility, but not the land or the support facilities at the original location, the cost to purchase the land or build support facilities is not eligible.

When FEMA requires relocation, FEMA does not provide future Public Assistance funding for repair or replacement of the original facility or for other facilities at the original site unless the facility enables an open space use.

For example, if the Applicant converts the original site to a park, FEMA may provide Public Assistance funding in the future for park components, such as benches, tables, restrooms, or gravel roads.

The Applicant may sell or lease the original facility or the land on which a relocated facility was originally located. The Applicant must inform the purchaser of the property that FEMA will not provide future Public Assistance funding for repair or replacement of the original facility or for other facilities at the original site unless the facility enables an open space use.

The property which the facility is relocated to, and the relocated facility itself, are subject to the real property provisions of 2 CFR part 200, including disposition and reporting requirements under 2 CFR 200.311 and 329, respectively. If the Applicant takes an action, such as demolition, using Public Assistance funds at the original site, FEMA must complete an Environmental and Historic Preservation review before the action occurs.

As discussed in the last lesson, Applicants must always obtain FEMA approval for any scope of work change, even if the total project cost is not affected. Any change in the project that affects the scope or cost of work can only be approved by FEMA. Applicants should not begin work associated with the scope change before FEMA review and approval, or Public Assistance funding will be jeopardized.

To seek approval for a change in the scope of work, an Applicant must provide a written request to the Recipient Public Assistance Representative. The request should include detailed justification and documentation to support the eligibility of the requested change in scope of work. If the request involves previously unreported damage, the Applicant must also provide documentation demonstrating how the incident caused the damage.

If the Recipient agrees that the requested change is justified, the Recipient will forward the request to the applicable FEMA regional office or Program Delivery Manager. FEMA will evaluate the changes for potential special considerations impact and ensure that the changes in the scope of work are eligible for Public Assistance Program funding. FEMA will also engage subject matter experts for technical assistance when necessary to reach a determination of whether the requested change is eligible.

For large projects, when a change in scope or a need for additional funding is discovered, the Applicant should notify the Recipient as soon as possible. The Applicant should never assume that such costs can be reported at the end of the project and that the additional funds will be approved automatically. The request should contain justification for the eligibility of the additional work or costs.

If additional damage to the facility is involved, the Applicant must show how that damage is disaster-related. The Recipient forwards the request to FEMA with a written recommendation. To determine eligibility, FEMA and the Recipient, in cooperation with the local representatives, may conduct a site visit. The timing of the request should be such that the damaged element can be inspected before it is repaired. FEMA will evaluate and notify the Recipient either with an amended project for additional funding or a written denial of the request via Determination Memo.

Small projects are handled differently. If there is a gross error or omission in the scope of work of a small project, the Applicant should make a request for a change as described for a large project.

Cost overruns are not handled on a project-by-project basis; rather, the Applicant may request supplemental funding for a net cost overrun on all small projects by submitting a Net Small Project Overrun Appeal through the Recipients to FEMA.

In the last lesson, three types of capped project options were discussed. Each type of capped project has a different set of approval requirements.

For Improved Projects, the Applicant must obtain approval from the Recipient. If the Improved Project significantly changes the pre-disaster configuration of the facility, the Recipient must forward the request to FEMA to ensure that the Improved Project complies with appropriate Environmental and Historic Preservation laws, regulations, and executive orders.

If FEMA approves the request, the Applicant will need to submit a written revised scope of work to the Recipient. If the Recipient agrees with the new scope of work, the Recipient will submit the written request to FEMA along with a letter of recommendation. The Applicant must receive FEMA approval for beginning work on the project.

Here is an example of an Applicant who followed the correct approval process for an Improved Project scope change:

As the result of a Nor'easter that struck Catastrophe County, the Catastrophe County Airport Hangar sustained damages to the roofing system as well as the aluminum roofing panels. Heavy wind caused separation at the heel and bottom chords of the timber Truss system and at the seams of the corrugated aluminum roofing panels. The original approved scope of work allowed the County to replace the damaged roofing panels.

The County had an engineering firm do a structural analysis of the roof to ensure it was safe for entry and to prepare for repairs. After receiving cost estimates, the County decided to replace the hangar rather than restore the damaged roof. The existing structure was built in the 1970's under old building codes and standards, and the County felt it would be more prudent to replace the structure.

The County submitted a letter to the State detailing reasons for the change in the project. The requested changes included building the new hangar to present codes and standards and turning the hangar sideways for safer aircraft access. The letter stated that the function of the hangar would not change, and the proposed new scope of work was cost effective.

The county summitted the scope of work change to the State. The State forwarded the request to FEMA along with a letter of recommendation. Once FEMA received the letter, they approved the expanded scope of work as a capped improved project because work had not begun, and FEMA was able to consider environmental and historic preservation impacts and conditions. The project scope of work was revised, and the County was able to begin construction for the project.

The scope change approval process for Alternate Projects is similar to the process for Improved Projects. The Applicant must submit a scope change request to the Recipient, and the Recipient will forward the request to FEMA if it agrees with the change.

If FEMA approves the scope change request, the Applicant will have to provide an updated scope of work and submit it to the Recipient. If the Recipient agrees with the updated scope of work, the Recipient will forward the new scope of work to FEMA.

If the Alternate Project involves construction, the Applicant must obtain FEMA approval prior to the start of construction.

Here is an example of an Applicant who followed the correct approval process for an Alternate Project scope change:

The City of Hazard's fire station annex was damaged after a hurricane caused heavy winds and high tidal surges along the Hazard River and coastal areas. The building was inundated with water and damaged beyond repair.

The City evaluated the productivity of the fire station annex, and after consulting their long term community plan determined that rebuilding the structure did not meet the needs of the community. They determined those funds would better meet the needs of the community if they were used to modernize the fleet of school buses operated by the City. They have requested an Alternate Project to purchase three new school buses.

Upon further talks with the City Council, the City decided to abandon the replacement of the fire station annex building and purchase new school buses. The City sent a letter to the State summarizing its plan to purchase the new equipment, along with reasoning to support the lack of need for the annex building. The State received this letter and submitted it to FEMA along with a letter of recommendation.

After receiving approval from FEMA, the City drafted a scope of work change detailing the variations they were making to the project. That letter was submitted to the State and subsequently sent to FEMA with a State support and recommendation letter. Once FEMA received the letter and an Environmental and Historic Preservation review was completed, the project was approved. The Project was revised, and the City was able to begin contracting the purchase of the new buses.

For Alternative Procedures, FEMA, Recipient, and the Applicant must reach agreement on the capped amount within 12 months of the declaration date. Upon request from the Applicant, FEMA may approve a time extension on a project-by-project basis. The Applicant's request must include the circumstances that justify the extension and demonstrate progress on reaching an agreement. In complex or catastrophic incidents, upon request from the Recipient, FEMA may approve an extension for all Applicants.

FEMA, Recipient, and the Applicant document the agreed upon capped amount with either a Fixed Cost Agreement Letter or a Letter of Undertaking, as appropriate. Once the Applicant signs and submits either the Fixed Cost Agreement Letter or the Letter of Undertaking, the Applicant may not revert to project funding based on actual costs.

If FEMA, Recipient, and the Applicant cannot agree on the fixed estimate by the deadline, the project will not be eligible for the Alternative Procedures and FEMA will process it using standard procedures.

For an Alternative Procedures Project with an estimated Federal share of at least $5 million, upon the Applicant's request, FEMA provides a FEMA-funded, independent validation of the cost estimate. The validation is conducted by an expert panel independent of FEMA, Recipient, and the Applicant. FEMA may also direct estimates to the panel for review.

If the Applicant requests this validation, the panel:

• Conducts its review before the Applicant's acceptance and before FEMA's obligation of funds
  
• Limits its review to issues pertaining to the estimated cost (the panel will not make decisions related to the eligibility of the damage or scope of work); however, it may make determinations regarding incorporation of cost elements relating to project execution that could affect the scope of work
  
• May review cost documentation for completed work, if applicable and necessary

If the estimated amount deemed appropriate by the expert panel is less than the Applicant is willing to accept as a capped amount, the Applicant may forgo the Alternative Procedures and request that FEMA process the project using standard procedures. In these cases, FEMA obligates the project based on the estimated amount determined by the expert panel and final funding is based on actual eligible costs.

Details regarding the process for participating in, and preparing projects under, Alternative Procedures, along with templates of the Fixed Cost Agreement Letter and Letter of Undertaking are provided at  the Alternative Procedures link.

To determine eligibility for Permanent Relocation projects, FEMA looks at several things, one of which is to determine whether the project is cost effective. If the cost to relocate the facility is less than the eligible cost to replace the facility at its original location, then the project is cost effective. Note that the value of the land at the original site is not included as part of this evaluation.

An applicable Federal, State, or local code or standard, such as a floodplain management regulation, may also require that a damaged facility be relocated away from a hazardous area, such as a floodway. If the facility is destroyed and eligible for replacement, FEMA will determine whether relocation is cost-effective in the same manner as described previously.

If the facility is eligible for repair, FEMA may evaluate cost effectiveness using its Benefit-Cost Analysis process and software to compare the benefits of the damage prevented to the facility at its original location against the cost of replacement and relocation at the new location.

If relocation is not feasible or cost effective, the Applicant may request an Improved, Alternate, or Alternative Procedure Project.

Properly documenting and requesting a change in the scope of work can prevent problems for both the Recipient and Applicant. It is the Applicant's responsibility to carefully document every step of a Public Assistance funded project and to keep the Recipient and FEMA informed of any action that might differ from the approved scope of work.

If an Applicant does not properly request scope changes or commences with work before the scope change request is approved, the Applicant may face delays in funding or loss in funding. Not having proper documentation throughout closeout of a project may also cause the applicant to lose funding.

If a Recipient or Applicant fails to comply with any term of the Public Assistance award, FEMA may take one or more of the following actions, as appropriate for the circumstances:

• Temporarily withhold cash payments pending correction of the deficiency by the Recipient or Applicant
  
• Deny the use of funds and matching credit for all or part of the cost of the activity not in compliance
  
• Completely or partially terminate the current award for the Recipient or Applicant's program
  
• Withhold future grant program awards
  
• Take other remedies that may be legally available

There are many documented cases where an Applicant lost Public Assistance funding due to changing the scope of work without approval. For example, one Applicant requested funding through the Public Assistance grants program to upgrade the foundation of several damaged trailers. The Applicant based the request on a code requirement applying to repairs of trailers and installation of new trailers. The Applicant proceeded to install several new trailers after the incident and did not use the code and standard required foundation. The Applicant did not wait for FEMA to complete an environmental and historic preservation review before beginning the work or give final approval.

FEMA decided that the upgrades to the foundation of the damaged trailers were not eligible because the Applicant did not enforce the standard and nor did they comply with the environmental and historic preservation review findings. If the Applicant had communicated with FEMA and documented the scope changes before commencing with the work, the Applicant would have known how to proceed without losing the Public Assistance funding.

Improper request and approval for scope changes may also cause delays in funding. Delays in funding may cause delays in the completion of a project. Some project delays are widely publicized and may result in negative public opinion throughout the community.

Here is an example:

A school in need of temporary facilities does not request approval from FEMA in a timely fashion and contracts for work to begin as soon as possible. When FEMA and the State learn that the school plans to begin work immediately, the State advises the school to put the project on hold pending FEMA environmental and historic preservation approval. This causes delays in construction, funding, and more. The media then portrays the delay of the necessary temporary classrooms for children.

Finally, improper changes in the scope of work can generate an audit during or after grant closure. Grant closure is the financial reconciliation of the grant conducted by FEMA and the State, after the parties reach agreement that all applicable administrative actions related to the Public Assistance program are complete and that all program funds related to the disaster have been reconciled.

Throughout the entire life cycle of the grant program, it is critical that the Applicant maintain accurate records of all events and expenditures related to disaster recovery work, in case an audit occurs. The Applicant should have a financial and record keeping system in place that can be used to track all elements of the Public Assistance funded projects.

The information required for audits may include:

• Completed project
• Completed Special Considerations Questions form
• Estimated and actual costs
• Force account labor
• Force account equipment, materials, and purchases
• Photographs of damage, work underway, and work completed
• Insurance information
• Environmental and/or historic alternatives and hazard mitigation opportunities considered
• Environmental review documents
• Receipt and disbursement documents
• Bid documents, procurement procedures, and contracts
• Records of donated goods and services, if any

Applicants should begin the record keeping process before a disaster is declared by the President. The importance of maintaining a complete and accurate set of records for each project cannot be over-emphasized. Not only is the documentation necessary for audits, it also facilitates the project formulation, validation, approval, and funding processes. All documentation should be filed with the corresponding project and maintained by the Applicant as the permanent record of the project.

Even though a single audit must be performed, grant recipients are also subject to additional audits by the Department of Homeland Security (DHS) Office of the Inspector General and State auditors. The Office of Management and Budget (OMB) requires grant recipients to maintain financial and program records for three years beyond the date of the final Financial Status Report or follow their and the Grantee's standard record retention policy if that policy requires record retention beyond the three-year requirement.

If a Financial Status Report is not required, records must be maintained for three years from the date of the final certification of completion of the Applicant's last project, or as directed by the Recipient. Typically, Applicants will be informed of audit requirements during their first meeting with FEMA. Any questions regarding the single audit, or audits in general, should be directed to the appropriate State official or Department of Homeland Security's Office of the Inspector General.

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

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

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.

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

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.

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.

• Certification that project is complete
  
• Date of project completion
  
• Copies of any Recipient time extensions

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.

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.

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.

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.

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.

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.

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.

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.