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Second Appeal Brief
PA ID# 037-99037-00; Los Angeles County
PW ID# 268; Direct Administrative Costs
Conclusion: The Applicant did not provide sufficiently detailed and descriptive documentation to demonstrate that the direct administrative costs (DAC) were directly related to the performance of eligible tasks.
Wildfires between November 13 and November 28, 2008 were a threat to public safety, resulting in evacuations and widespread damage. Los Angeles County performed emergency protective measures at nine sites. At project closeout, FEMA determined that the Applicant did not identify specific direct administrative tasks performed on a given date, by a specific employee. The Applicant submitted its first appeal requesting reimbursement of $52,979.07 for DAC, providing time cards for each employee and an explanation of the codes defining the task each employee performed. The Region IX Regional Administrator (RA) partially approved the first appeal for $1,963.94 The RA determined the remaining balance was ineligible as the documentation was insufficient to demonstrate that the costs claimed were directly related to eligible administrative tasks in support of PW 268.
Authorities and Previous Appeal Decisions Discussed
- Disaster Assistance Policy (DAP) 9525.9, Section 324 Management Costs and Direct Administrative Costs dated March 12, 2008.
- FEMA’s Second Appeal Decision, Cedar Rapids Community School District, FEMA-DR-IA PW 649 dated April 22, 2013.
- 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.
FEMA’s Second Appeal Decision, Cedar Rapids Community School District, FEMA-DR-IA PW 649
- FEMA noted that terms such as “Project Formulation”, “Project Administration”, Project Management” and “Documentation Development” are too broad and fail to describe specific administrative tasks as required by