The Stafford Act § 423 and 44 C.F.R. § 206.206 require appeals to be submitted within 60 days of a determination previously made after notification of the award or denial of award of assistance. A number of the Grantee’s appeals were submitted more than 60 days after notice of a determination previously made, or alternatively prior to the award or denial of award of assistance. With respect to the format and content of appeals, FEMA’s regulations require that an appeal specify the monetary figure in dispute and contain documented justification supporting the applicant’s position. The Grantee has not identified, with specificity, the source of the amounts in dispute. Under DAP 9525.9, FEMA may reimburse reasonable and properly documented DAC if applicants provide information about each activity in sufficient detail so as to allow FEMA to assess employee skill level, the suitability of that skill level to the activity in question, and the level of effort required to complete the activity. The Grantee has not provided documentation explaining why it exceeded agreed upon timeframes for DAC activities or demonstrating that all DAC was directly tied to eligible work. However, the Grantee has provided documentation allowing FEMA to partially reimburse reasonable DAC based on a review of the suitability of employees’ skill levels to the activities performed.

A number of the Grantee’s first appeals were untimely or premature. For many PWs, the Grantee has not substantiated its amounts in dispute or demonstrated through supporting documentation that claimed DAC was reasonable and directly related to eligible work. However, FEMA will reimburse some reasonable and properly documented DAC based on a review of suitability of employees’ skill levels to the activities performed. Therefore, the second appeal is partially granted in the amount of $85,204.50.

Stafford Act § 423(a). 44 C.F.R. § 206.206(a); 2 C.F.R. pt. 225. DAP9525.9, Section 324 Management Costs and Direct Administrative Costs, at 3; PA Guide, at 40. Dep’t of Transp., FEMA-4068-DR-FL, at 5; City of Sweetwater, FEMA-1345-DR-FL, at 3, City of Atlanta, FEMA-4165-DR-GA, at 6, 9-10.