“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.”
lives, and restore normalcy as quickly as possible. It sometimes becomes difficult 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.
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Ensure all adverse eligibility rulings in writing (Determination Memorandum – DM), so FEMA’s exact reasons can be weighed against current laws and policies. If a DM is anticipated, Subrecipients should request a Facilitated Discussion
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(through the Recipient) with FEMA leadership to find resolution. 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 one who can properly document and justify that response.
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.
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