Duplication of Benefits - Non-Government Funds

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This policy is archived and has been superseded by the policy currently in effect.

  1. Date Published: August 17, 1999  

  2. Response and Recovery Policy Number: 9525.3

  3. Title: Duplication of Benefits - Non-Government Funds

  4. Purpose: This policy clarifies the issues related to grants and cash donations from third parties for emergency and permanent work under the Public Assistance Program.

  5. Scope and Audience: This policy is applicable to all major disasters and emergencies declared on or after the publication date of this policy and to all emergency and permanent work done under Public Assistance Program grants. This policy is intended for Federal Emergency Management Agency (FEMA) personnel in making eligibility determinations for the Public Assistance Program.

  6. Background:

    1. Communities and private non-profit institutions often look for assistance from the general public, private institutions, and Federal and State agencies to help rebuild their infrastructure following a disaster. This assistance may come in the form of donations, insurance proceeds, volunteer work, or grants. With multiple entities providing assistance, it is possible for different sources to allocate funds to repair the same project. This action may constitute a duplication of benefits
    2. Section 312 (a) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, P.L. 93-288 as amended states that no entity will receive assistance for any loss for which financial assistance has already been received from any other program, from insurance, or from any other source. The use of Federal and/or State funds granted for the same purpose clearly constitutes a duplication of benefits. However, grant or cash donations provided by a private benefactor also may constitute a duplication of benefits.
  7. Policy:

    1. Grants and cash donations designated for specific eligible work. Grants and cash donations from non-Federal sources designated for the same purpose as Federal disaster funds are considered a duplication of benefits. These grants and cash donations will be used to reduce the cost of the total project. Cost shares will be assigned according to the FEMA-State Agreement based upon the reduced project cost.

    2. Grants and cash donations not designated for specific eligible work. Unless otherwise prohibited, grants and cash donations received for unspecified purposes (e.g., "for disaster recovery/relief efforts"), or for work not eligible for FEMA assistance, do not constitute a duplication of benefits.

    3. Insurance. Disaster assistance will not be provided for damages covered by insurance. Disaster assistance provided by FEMA is intended to supplement assistance from other sources; therefore, insurance proceeds should be an applicant's first alternative for disaster assistance. An adjustment for the amount that should be received from insurance coverage is required even if the applicant has not completed negotiations with the insurer.

    4. The retention of duplicated funds is illegal. Duplicated Federal funds must be returned to FEMA.

  8. Supersession: This policy updates and replaces the relevant provisions of previous public assistance policy documents.

  9. Authorities: Robert T. Stafford Disaster Relief and Emergency Assistance Act, Section 312; 44 CFR 13.24 and 206.226(a).

  10. Originating Office: Infrastructure Division, Response and Recovery Directorate

  11. Review Date: Two years from date of publication

  12. Signature:

    Lacy E. Suiter
    Executive Associate Director
    Response and Recovery Directorate

  13. Distribution: Regional Directors, Regional and Headquarters R & R Division Directors

Last Updated: 
02/13/2015 - 12:30
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