Summary Paragraph On September 6, 2011, tropical storm Lee flooded the first floor of a building owned by the Central Bradford Progress Authority (Applicant). The Applicant claimed direct administrative costs (DAC), travel, and project management costs on PWs 768, 775, and 5418, but did not include sufficient detail to allow FEMA to determine the reasonableness of the claimed costs. FEMA awarded DAC at closeout for PWs 768 and 5418. In a first appeal letter, the Applicant appealed FEMA’s denial of DAC, project management costs, and travel costs incurred by a contractor. FEMA issued a request for information (RFI) and a Final RFI to ask for more detailed descriptions to resolve discrepancies in the documents. Spreadsheets and invoices the Applicant provided were not sufficient. The RA denied the appeal, but upheld DAC awarded at closeout for PWs 5418 and 768 as an enforcement action. When closing PW 775, the RA stated that she will consider project management costs submitted by the Applicant and will evaluate contracted DAC. The RA determined that the travel expenses were not associated with a specific PW and were therefore not eligible DAC. The Applicant submitted a second appeal claiming $484,755.20 in DAC, $112,500.00 in travel reimbursement, and $6,384.00 in project management costs. Authorities and Second Appeals OMB Circular A-87, 2 C.F.R. § 225. 44 C.F.R. § 13.36. DAP 9525.9, Section 324 Management Costs and Direct Administrative Costs 44 C.F.R. § 13.43(a). Headnotes DAP 9525.9 states that FEMA will reimburse DAC incurred by subgrantees that are tracked, charged, and accounted for directly to a specific project. The DAC that the Applicant submitted were not sufficiently tracked and documented. DAP 9525.9 provides that travel and per diem costs are eligible as DAC if such costs can be and are attributed to individual projects The Applicant does not connect travel costs to individual PWs. 44 C.F.R. § 13.36 states that Applicants must follow applicable Federal procurement laws and standards. Among other requirements, a cost analysis and an evaluation of the specific elements of costs and profits, is required for noncompetitive proposals. The Applicant did not provided sufficient documentation to demonstrate that it met Federal procurement laws and standards for noncompetitive proposals. Pursuant to 44 C.F.R. § 13.43(a), Remedies for Noncompliance, if an Applicant materially fails to comply with any term of an award, FEMA may take a number of actions. During closeout, the Region identified the Applicant’s noncompliance with documentation requirements and exercised its discretionary enforcement authority to limit reimbursement.