Pursuant to 44 C.F.R. § 206.203(d)(1), funding for improved projects is limited to the Federal share of the approved estimate of eligible costs, or actual costs, whichever is less. The PA Guide notes FEMA may adjust its contribution if the approved costs exceeded the original estimate and costs can be separately documented. The Applicant did not track costs for eligible work separately from improvements to appeal the eligible grant amount. Thus, funding is limited to the estimate of eligible costs when FEMA approved the improved project. Under DAP 9525.9, applicants may be reimbursed for reasonable direct administrative costs that can be identified separately and assigned to a specific project. Not only did the Applicant claim DAC for costs that were not documented with detail to demonstrate reasonableness, but it also claimed DAC for indirect costs divided evenly across multiple PWs, costs that did not correspond to any one specific project, and costs that benefited unrelated projects, all of which are ineligible as DAC.

: The University of Texas Medical Branch (Applicant) has not demonstrated that it tracked costs for eligible work separately from improvement costs, or that all claimed contract labor is eligible as direct administrative costs (DAC). Additionally, the Applicant’s travel expenses are indirect costs, which are ineligible as DAC.

Stafford Act §§ 324(a), 406, 705(c). 2 C.F.R. pts. 215 and 220; 44 C.F.R. §§ 13.22(b), 206.203, 206.206, 207.2. DAP 9525.9, Section 324 Management Costs and Direct Administrative Costs. FP-205-081-2, Stafford Act Section 705, Disaster Grant Closeout Procedures. PA Guide, at 29, 53, 110. PA Policy Digest, at 71. Public Health Trust, FEMA-1561 & 1608-DRs-FL, (Sept. 26, 2016). City of Duluth, FEMA-4069-DR-MN (June 15, 2015). Los Angeles County, FEMA-1810-DR-CA (Mar. 18, 2014). Linn County, FEMA-1763-DR-IA (Aug. 9, 2013). Cedar Rapids Community School District, FEMA-DR-IA (Apr. 22, 2013).