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Second Appeal Brief
PA ID# 201-35000-00; City of Houston
PW ID# 744; Interim Housing Management Costs
FEMA-3216-EM-TX, City of Houston, Interim Housing Management Costs,
The City of Houston (Applicant) provided sheltering services for approximately 150,000 Hurricane Katrina evacuees. The Applicant retained two professional service firms to handle the day-to-day administration and management of the interim housing program. FEMA approved $48,962,351 in PW 689 for project management cost for the Interim Sheltering Program. Subsequent to the approval of the final version of PW 689 in August 2007, the Applicant requested $120,110 for preparing for an Office of Inspector General audit, $83,308 for verifying occupancy of rental units, $169,078 for conducting post-payment reviews, and $232,696 for digital scanning of program documents. FEMA determined that the statutory administrative allowance covered the claimed costs, denied the request, and prepared PW 744 for zero dollars. The Regional Administrator supported this determination on first appeal.
On February 4, 2008, the Applicant submitted its second appeal requesting $605,191. The appeal reiterates that no statutory limitation for administrative costs exists and that Congress authorized 100 percent Federal funding for assistance Texas provided in connection with Hurricane Katrina. In addition, it contends that the audit expenses should not be considered final audit activities and the costs associated with scanning legal and accounting documents directly relate to delivering disaster housing services and satisfies document retention requirements.
Are the requested costs eligible for direct reimbursement?
Section 202 of the Disaster Mitigation Act of 2000