FEMA policy provides that travel expenses related to one specific PW qualify as DAC, while travel expenses “related to general support and not directly tied to one specific project” are indirect costs, and therefore ineligible as DAC. By extension, expenses allocated to every task for all PWs in proportion to the hours worked on the task are not eligible as DAC. CDM Smith utilized its Expense Allocation Methodology to divide travel expenses incurred by its employees to benefit multiple PWs across said PWs on a prorated basis. Accordingly, the costs are not eligible DAC.

Stafford Act § 324 44 C.F.R. §§ 207.2, 207.6; 2 C.F.R. § 200.110 DAP 9525.9, Section 324 Management Costs and Direct Administrative Costs; Memo., DAC Guidance; DAP 9525.11, Payment of Contractors for Grant Management Tasks FEMA-4069-DR-MN, City of Duluth, Mult. PWs, at 5