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Second Appeal Brief
PA ID# 113-12000-00; City of Cedar Rapids
PW ID# 1299, 1411, and 9556; Direct Administrative Costs
Conclusion: The documentation submitted by the Applicant did not demonstrate that the costs incurred for contracted labor at $285 per hour were reasonable for grant administration work. Furthermore, The Applicant failed to provide sufficiently detailed and descriptive documentation to demonstrate that the previously funded contracted DAC tasks/activities are eligible or reasonable.
Heavy rainfall beginning in May 2008 resulted in severe flooding that caused extensive damage in the City of Cedar Rapids (Applicant). FEMA prepared three PWs for a combined total of $699,503 for costs to perform emergency and permanent work. Included in the project costs were $33,256 in Direct Administrative Costs (DAC). After the Iowa Homeland Security and Emergency Management Division (Grantee) reviewed the Applicant’s documentation of actual costs, FEMA closed out the three PWs and reduced the total eligible DAC to $27,246 based on the Grantee’s recommendation. The Applicant requested an additional $6,010 in DAC; however, FEMA determined that the Applicant’s documentation did not support the eligibility of $6,010 in DAC associated with a consultant’s hourly rate that exceeded $155. In the first appeals, the Applicant asserted that the DAC was eligible for reimbursement. In the appeals response, the Regional Administrator noted that the Applicant did not justify the hourly rate above $155 and determined that the claims for $6,010 were ineligible. In the second appeals, the Applicant argues that the consultant’s project manager rate was appropriate by virtue of the time required to review and supervise a project officer, reasonable by the Applicant’s adherence to proper contract procurement protocols, and comparable to another consulting contractor’s rates employed by the Grantee.
- Disaster Assistance Policy 9525.9, Section 324 Management Costs and Direct Administrative Costs
- Disaster Assistance Policy (DAP) 9525.9, Section 324 Management Costs and Direct Administrative Costs, Section VII(D)(1).
- DAC include costs that can be tracked, charged and accounted for directly to a specific project, such as staff time to complete field inspection and preparation of a PW. Direct costs are limited to actual reasonable costs incurred for a specific project. Such costs will be considered project costs.