Section 705(a) prohibits FEMA from initiating an administrative action to recover PA payments made to a state or local government after the date that is three years after the date of transmission of the final expenditure report for project completion as certified by the recipient. FEMA is barred from recovering PA funds previously awarded because the Determination Memorandum notifying the Applicant and Recipient of FEMA’s intent to recover payments fell beyond the three-year statute of limitations included within section 705(a) of the Stafford Act.

FEMA is barred by section 705(a) of the Stafford Act from deobligating the previously awarded funds beyond the three-year statute of limitations. Therefore, this appeal is granted.

Stafford Act § 705(a). FP 205-081-2.