To be eligible, costs must be, among requirements, directly tied to the performance of eligible work, necessary and reasonable to accomplish the work properly and efficiently, and adequately documented. The Applicant did not demonstrate the additional NCS costs were reasonable and necessary to address the public health needs of COVID-19, which was needed for FEMA to determine that the number of rooms was reasonable and necessary to shelter residents potentially requiring NCS.

FEMA finds the additional NCS costs were not reasonable and necessary to address the public health needs of the COVID-19 declared event. Therefore, this appeal is denied.

Stafford Act § 403(a)(3). 2 C.F.R. §§ 200.403, 200.404. 44 C.F.R. §§ 206.206(a), 206.223(a)(1), 206.225(a)(1) and(a)(3)(i). PAPPG, at 19, 21-22, 57, 66, 133, and 163. FEMA Fact Sheet, Non-Congregate Sheltering; Non-Congregate Sheltering FAQ, at 1-2; Non-Congregate Sheltering Memorandum, at 2. Hillsborough Cnty., FEMA-4486-DR-FL, at 3; Oregon Dep’t of Human Servs., FEMA-4562-DR-OR, at 3; Baptist Healthcare System, Inc., FEMA-4497-DR-KY, at 2.