PA Eligibility Basics: The Four Building Blocks

FEMA's Public Assistance Program and Policy Guide (PAPPG) describes eligibility as a set of four building blocks: the applicant, the facility, the work and the cost. FEMA considers them in that order, by and large, and a project usually needs to clear each one. This page introduces the four blocks in general terms; the PAPPG devotes whole chapters to each, with conditions and exceptions this page does not attempt to cover.

How the pyramid works

The PAPPG calls the four blocks the eligibility pyramid, with the applicant at the base and cost at the top, and describes FEMA's review as moving upward through them. There are variations, as the guide describes them: for government applicants, facility eligibility is not a separate step for debris removal and most emergency protective measures, and for private nonprofits FEMA looks at the facility and the service it provides before deciding whether the organization is an eligible applicant.

Block 1: The applicant

Two broad groups can apply. The first is government — states, territories, Tribal Nations and local governments such as counties, cities, school districts and special districts. The second is certain private nonprofit organizations, including houses of worship and other faith-based organizations, whose facilities provide services the PAPPG treats as eligible. For-profit companies are not eligible applicants as a rule, although governments can hire them to carry out eligible work. Taking part usually starts with a Request for Public Assistance filed through FEMA's Grants Portal, within a window the PAPPG describes.

Block 2: The facility

A facility is, in the PAPPG's terms, a building, system, equipment or improved and maintained natural feature that the applicant owns or is legally responsible for maintaining — roads, water and sewer systems, public buildings, parks and the like, together with their contents, equipment and vehicles. The PAPPG expects the facility to have been in active use when the incident began, with some exceptions for temporary closures. Unimproved natural features and farmland are not facilities, as a rule. For private nonprofits, the service the facility provides is a central part of the question, and a facility used for several purposes may be evaluated on its primary use.

Block 3: The work

The PAPPG describes three general tests for work: it was required as a result of the declared incident, it is located within the area the declaration designates, and it is the legal responsibility of the applicant. Damage from deferred maintenance, wear and tear, a different event or the applicant's own negligence is not treated as incident-related, as a rule. The location test has exceptions — sheltering and evacuation outside the designated area, for example — and legal responsibility can depend on leases and contracts as well as ownership. Eligible work then falls into the emergency and permanent categories described in our page on categories A through G.

Block 4: The cost

Costs are the last block, and not all of the costs that follow a disaster qualify. In general terms, the PAPPG looks for costs that are tied to eligible work, adequately documented, reduced by insurance proceeds and other credits, allowed under federal and state law, consistent with the applicant's own policies, and necessary and reasonable. Reasonableness follows the prudent-person idea in the federal grant regulations, and FEMA may look more closely at costs in some situations, such as work procured without competition. In most disasters, the federal share of eligible costs is at least 75 percent.

Putting the blocks together

In practice the blocks are interdependent: a well-documented cost does not help much if the facility or the work does not qualify, and an eligible facility does not help if the damage traces to something other than the incident. Whether a specific project is eligible depends on its own facts and on the edition of the PAPPG that applies to the disaster — see which PAPPG version applies.