As It Was The basis for all FEMA reimbursement claims (regardless of whether insurance applies) is “as it was.” What was there immediately prior to the event provides the basis for evaluating the eligible costs associated with repairing or replacing a facility. Once the Subrecipient provides an estimate necessary to repair or replace their facility to its pre-disaster design and function — and it’s agreed upon by FEMA and the state — a baseline estimate will be established. Pre-disaster design is the size or capacity of a facility as originally constructed or subsequently modifed. For instance, if an eligible ofce building designed for a capacity of 250 employees is damaged beyond repair, the eligible funding for the replacement facility is limited to that necessary for 250 employees, even if more than 250 employees were working in the facility prior to the event.
Pre-disaster function is the purpose for which the facility was originally designed or subsequently modifed; basically, “how” was it being used prior to the event. For example, if a Subrecipient designed and constructed a fre station but later altered it in accordance with applicable construction codes or standards to use as a storage facility, the pre-disaster function would be as a storage facility. Ideally a Subrecipient will have a set of plans, drawings, or at the very least photo documentation that predates the declared disaster event. In addition, any maintenance records, documentation of changes that occurred altering the size, capacity, or function of a facility, and other related data should be assembled for review. It is recommended that an applicant not provide their original documents, but rather copies, and that they are aware that any documents provided could at a later date be subject to a FOIA (Freedom of Information Act) request made to FEMA. If such documents provide sensitive data, it is recommended that discussions commence immediately with FEMA so accommodations can be made. In some
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