FEMA established programmatic deadlines across all COVID-19 declarations, stating that RPAs must be submitted to FEMA no later than July 1, 2022. However, FEMA has authority to extend the RPA deadline when the request is justified based on extenuating circumstances beyond the applicant’s or the recipient’s control. The Applicant began COVID-19-related work in 2021. Therefore, it does not meet the criteria set forth in the example contained in the COVID-19 policy’s example, which states an extenuating circumstance may include an applicant who did not anticipate conducting COVID-19 work and did not conduct work until after July 1, 2022. Further, the Applicant’s generalized descriptions of staff shortages and increased workload do not constitute extenuating circumstances beyond the Applicant’s control to justify a time extension. In addition, the Applicant's lack knowledge and lack of understanding of the PA program are also not extenuating circumstances to justify a time extension.

The Applicant did not submit the RPA within the programmatic deadline, and neither the Applicant nor the Recipient demonstrated an extenuating circumstance beyond either’s control to justify extending the RPA deadline. Therefore, this appeal is denied.