Navigating FEMA Public Assistance and Cost Share

When a disaster strikes, individuals and organizations often donate resources to assist with response activities. These resources include cash donations, grants, volunteer labor, and donated supplies and equipment. Under the Stafford Disaster Relief and Emergency Assistance Act, FEMA’s Public Assistance Program provides aid to those recovering from a disaster. The federal share typically covers 75% of eligible costs; the remaining 25% is the applicant’s responsibility to cost share or “match.” These donations are a key component to meeting the federal match requirement. Matches have three key considerations: the first 30 days, eligibility, and documentation. 

Match Considerations Within the First 30 Days 

In limited circumstances, the federal match may be increased. When the President authorizes an increased federal cost share for a limited period, FEMA applies it to all eligible costs related to work performed through 11:59 p.m. on the expiration date. However, accurately tracking all resources utilized or received during this timeframe is essential during disaster recovery and management. For emergency work specifically, if there is a time-limited 100% federal cost share period:  

• If the applicant uses resources donated during this period. In that case, it may use the value of those donated resources to offset the non-federal cost share incurred after the 100% federal cost share period expires.
• Suppose the applicant uses resources from stock donated during a previous incident or time. It may use the value of those donated resources to offset its non-federal cost share if the applicant has not claimed the resources as an offset in a previous incident.  

What is Eligible as Match Under FEMA Public Assistance Program?  

Grants and cash donations from non-federal sources or donated services, like equipment and supplies, can help meet program match requirements. 

The match is eligible when:   

• The donated resource is from a third party.
• The donated resource is necessary and reasonable. 
• The applicant uses the resource to perform eligible work within the performance period. 
• The applicant tracks the resources and work performed on the project, including description, specific locations, and hours.  

The value of a donated resource is not eligible as a match if the resource is:  

• Donated by a federal agency. 
• Donated by another federally funded source.
• Funded through a federal award. 
• Used as an offset to any other federal award. 
• Used for ineligible work.  

Match requirements generally cannot be paid with other federal funds. However, federal funds may be used as a match if a federal program outlines approval. For instance, HUD’s Community Development Block Grant Disaster Recovery (CDBG-DR) program is an allowed federal match. CDBG-DR can pay for eligible expenses on eligible project worksheets. States routinely use this approach to assist local entities, state agencies, and other public assistance applicants with their cost share requirements.   

It is important to note that using CDBG-DR to make the match presents various challenges. Differences in program requirements, including grant amounts and timing, highlight potential hurdles; however, careful documentation and tracking can help make sure that the match is applied correctly and allowable.  

How Should Match be Documented?  

Applicants are required to track and document the following to support donated resources. Proper documentation supports program requirements, helps prove that assistance is essential to meeting immediate threats resulting from the disaster, and verifies the match through the applicant’s records.  

Documentation requirements for donated services, equipment, or supplies include, but are not limited to:  

For individuals providing an eligible service:  

• Sign-in sheet 
• Name  
• Title and function 
• Date, days, and hours worked  
• Location of work and description of work performed 

For equipment:  

• Date and length of time operating equipment  
• Specific backup documentation if applicant-owned  
• Who donated each piece of equipment  

 For supplies or materials:  

• Quantity used  
• Who donated  
• Location(s) used  
• Invoices or other documentation to validate the claimed value  

Disasters pose extreme challenges to the individuals and communities they impact. To meet cost-sharing requirements, the non-federal contributions must comply with federal requirements and regulations while being reasonable, allowable, allocable, and necessary under the grant program. 

EisnerAmper professionals have decades of experience navigating federal funding and monitoring relief developments at the federal, state, tribal, and local levels. Our team is committed to helping you understand and leverage the available disaster relief options. Contact us to discuss your organization’s unique situation.