Summary Paragraph Following Hurricanes Frances and Jeanne in 2004, FEMA prepared many PWs to reimburse the Applicant to repair damages it incurred. In two Audit Reports, the OIG reviewed 87 Project Worksheets (PWs) and produced six findings with recommendations to deobligate Federal funding. FEMA followed the OIG’s recommendations and deobligated a total of $3,999,584.00 in PA funding. In separate first appeals, the Applicant contested three findings and associated recommendations from the two OIG reports pertaining to: 1) losses covered by insurance, 2) lack of supporting documentation, and 3) time and materials (T&M) contract charges and requested reinstatement of 3,893,902.05 in PA funding. The FEMA Region IV Regional Administrator (RA) denied the first appeals because the Applicant failed to provide information to refute the OIG’s recommendations regarding anticipated insurance proceeds, lack of supporting documentation for contract labor and equipment charges, and issues with its T&M contracts regarding Hurricanes Frances and Jeanne Recovery efforts. Specifically, the RA found that the Applicant had not submitted to FEMA its insurance carrier’s final determination of coverage and statements of loss. In addition, the RA stated that the Applicant did not provide sufficient supporting documentation to re-obligate funding for labor and equipment charges. Finally, the RA agreed with the OIG that the Applicant did not comply with Federal grant procurement regulations when securing its T&M contracts. On second appeal, the Applicant again contests three findings within the two OIG Audit Reports. In support of its claims, the Applicant provides additional documentation related to its insurance policy and proceeds and resubmits documentation related to recommendations 2 and 3. On second appeal, the Applicant has provided documentation demonstrating that certain losses were not covered by insurance and re-obligation of funding is appropriate. However, the Applicant failed to substantiate its claim with regard to funding deobligated due to procurement noncompliance and a lack of supporting documentation. Authorities and Second Appeals Stafford Act § 312. 44 C.F.R. §§ 13.22 and 13.36. OMB Circular A-87, 2 C.F.R. § 225. Headnotes Pursuant to the Stafford Act § 312, FEMA does not provide PA funding for damages covered by insurance because it would constitute a duplication of benefits. While FEMA reduced funding for losses covered by insurance following an OIG recommendation, the Applicant has provided documentation demonstrating that certain losses were not covered by insurance and re-obligation of funding is appropriate. 44 C.F.R. § 13.36 requires applicants to procure contracts using full and open competition and to perform a cost or price analysis in connection with every procurement action, including noncompetitive procurement. The Applicant did not properly procure its debris removal contract and failed to provide a cost analysis, as required by the regulations. Therefore, FEMA cannot determine the reasonableness of the contractor’s prices. According to 44 C.F.R. § 13.22, only allowable costs are eligible for PA funding. OMB Circular A-87 provides that all allowable costs must be reasonable, necessary and adequately documented. FEMA could not verify eligible costs using the supporting documentation submitted by the Applicant.