While one would assume that a Subrecipient would not arbitrarily take on extraordinary work unless it was required to achieve a prompt response and recovery following a disaster, this alone is not sufficient to satisfy FEMA’s eligibility requirements. Often how a Subrecipient describes what was done and the reasons for doing it will be key determining factors.
Because this criteria is very broad, it is extremely important to succinctly define the what, why, where, how, and by whom for every task for which a Subrecipient hopes to seek reimbursement. It is equally important to further support a claim with all pertinent documentation, such as damage photographs or condemnation notices.
First and foremost, Subrecipients know best what needs to be done in the immediate aftermath of a disaster. However, it is not uncommon for those efforts to be questioned by FEMA months, or even years, after an event. If a Subrecipient clearly believes that their efforts were required as the result of an event, and FEMA and the state do not agree, the Subrecipient must be prepared to appeal that determination in accordance with CFR 44 206.440 (Appeals).
While this requirement might seem self- explanatory, this area is often subject to disagreement between Subrecipients and FEMA. The following are examples of questions that may be asked to satisfy this requirement: