Eligible PM activities are those that include oversight of an eligible project from design phase to the completion of work. Ineligible PM activities are those necessary to requesting, obtaining, and administering Federal disaster subgrants. Eligible DAC work includes activities related to developing the scope of work (SOW) component for one specific project worksheet. The costs at issue pertain to work the Applicant’s contractor performed to support the eligibility of changes to the approved scopes of work for two specific PWs; these are DAC rather than PM costs.

Because the costs at issue pertain to work the Applicant’s contractor performed to support the eligibility of changes to the approved scopes of work, they are DAC rather than PM costs. Accordingly, the Applicant’s request to re-classify the DAC charges to PM costs is denied.

44 C.F.R. §§ 206.201(i)(1), (j); 206.206(a). Response and Recovery Policy 9525.6, Project Supervision and Mgmt. Costs of Subgrantees, at 2-3 (Apr. 22, 2001); Memorandum from Ass’t Adm’r Disaster Assistance Directorate, FEMA, to Reg’l Adm’rs, et al. (Sept. 8, 2009) at Attachment; Columbus Reg’l. Hosp. v. FEMA, 708 F.3d 893, at 899 (7th Cir. 2013). Office of Personnel Management v. Richmond, 496 U.S. 414 (1990).