FEMA released an interim policy, which defines the framework, policy details, and requirements for determining the eligibility of work and costs under the public assistance (PA) program. The guidance outlines the principles behind this policy, requirements for the PA program, including eligibility, coordination of funding, and time limitations. The policy applies to work performed on or after September 15, 2020; prior to this date, policies in place when the work was completed apply.

Although FEMA has, until now, been considered the “payer of last resort,” the new guidance indicates that FEMA PA funding should not be considered funding of last resort, adding that it is “advisable that PA funding is considered concurrently with other federal agency programs and sources.” FEMA may provide PA funding for eligible work under COVID-19 declarations that may also be eligible for funding under the authority of another federal agency. The guidance indicates that potential PA applicants may have the flexibility to determine, in these instances, which source of funding to use for their costs (subject to the purpose and eligibility requirements of each source of funding).

– If FEMA has not awarded PA funding, applicants should withdraw or amend their PA application.

– If FEMA has awarded PA funding already, the applicant should request an updated version of their project worksheet to amend their PA project.