Determining Eligibility: Methods for Presenting Disaster-Related Costs to FEMA to Obtain Eligibility


...necessary to protect property, protect lives, and restore normalcy as quickly as possible. It becomes very difficult sometimes to explain, months later, that what was done was prudent and cost- effective at the time. The key to a favorable recovery is good documentation. It is hard to explain to a FEMA debris specialist that you paid $42 a cubic yard to remove debris by hand if they view debris removal only as an activity involving large equipment normally ranging from $12-$20 a cubic yard. However, if that debris was hand-cleared in a park because heavy equipment could not be operated, then the cost should be considered reasonable.

In addition to good documentation, make sure that the personnel who are best prepared to support your position are available to respond to questions. This can be done by having an internal team in place prior to a disaster who understand what will be needed to recover financially.


As evidenced by the overview given here, eligibility can become very confusing. The confusion is further amplified when field inspectors or grant developers from other states add their local interpretations to the mix. Ideally, FEMA will publish disaster- specific guidance memorandums to be followed for each disaster, however, even when they are published, they are not always followed.

Ask for all adverse eligibility rulings in writing, so FEMA’s exact reasons can be weighed against current laws and policies. Once this information is obtained, a Subrecipient’s first recourse is to advise the state of any disputes and solicit its support. If that is unsuccessful, ask the on-site state/FEMA personnel to forward the information to the Disaster Field Office level for review, which is often where disputes are resolved. It is extremely important to resolve eligibility and any other disputes “on the ground,” as the formal appeals process can be very time consuming and extremely frustrating.

Nobody knows better how to respond to a disaster than the Subrecipient, and the successful Subrecipient is the onewho can properly document and justify that response.

“Nobody knows better how to respond to a disaster than the Subrecipient, and the successful Subrecipient is the one who can properly document and justify that response.”

Terry Kelly/