44 C.F.R. § 13.36 required competitive bids for every procurement action, unless one of four exceptions apply, including public exigency. Here, the mold remediation met the “public exigency” exception in 44 C.F.R. § 13.36(d)(4)(i)(B). Even if a procurement exception applies, per 44 C.F.R. §§ 13.36(d)(4)(ii) and13.36(f)(1), an applicant must still conduct a concurrent cost or price analysis to determine whether the contract costs are reasonable. Neither the Applicant nor the Grantee performed such an analysis until submission of the first appeal. FEMA therefore correctly found that a procurement violation existed. Notwithstanding the existence of a procurement violation, FEMA may still award reasonable costs for eligible work, if an applicant adequately supports those costs. City of Pierre, FEMA-1984-DR-SD, at 15. The Grantee’s scope alignment comports with the scope of work prepared by one of the Applicant’s insurers at the time of the disaster and relies on RS Means to estimate itemized costs, establishing that $1,855,018.17 in remediation costs were reasonable. Stafford Act § 312 prohibits FEMA from providing funding for portions of disaster-related damages whose repair receives funding through other sources, including from insurance. Here, the Applicant has submitted relevant portions of each of its insurance policies, which demonstrate that two of them contain categorical mold exclusions or limitations. Benefits under those policies are therefore not duplicative of any funding under PW 10743. However, proceeds under the Applicant’s NFIP policies are duplicative of funding, and FEMA must deduct these amounts from the PW.

The Applicant submitted adequate documentation demonstrating that it incurred $1,855,018.17 in reasonable costs, less $689,485.35 in insurance proceeds. Therefore, this appeal is partially granted in the amount of $1,165,532.82

Stafford Act § 312 44 C.F.R. §§ 13.36(d), (f); 44 C.F.R. § 206.225(a) PA Guide (1999), at 34, 68, 73, and 95; PA Guide (2007), at 41, 95, and 103 City of Pierre, FEMA-1984-DR-SD, at 9, 15; Lafourche Par. Sch. Bd., FEMA-4080-DR-LA, at 3; Williamsburg Reg’l Hospital, PW 718, FEMA-4241-DR-SC, at 8–10