FEMA Public Assistance Glossary: The Terms Practitioners Actually Use

FEMA Public Assistance (PA) has a vocabulary all its own, and eligibility disputes often turn on how a term is read. The authoritative definitions live in two places: the regulations at 44 CFR 206.201 and 206.221 (available on ecfr.gov), and Appendix C ("Terms and Definitions") of FEMA's Public Assistance Program and Policy Guide, Version 5 (PAPPG v5).

This glossary collects the terms practitioners actually encounter — grouped by roles, declarations, work types, money, and disputes — with each definition paraphrased from those published sources. Where a dollar figure adjusts annually, that is noted.

Who's who: roles and entities

Applicant — A non-federal entity submitting an application for assistance under a recipient's federal award (PAPPG v5, Appendix C). The regulation frames it as a state agency, local government, or eligible private nonprofit applying to the recipient for assistance under the state's grant (44 CFR 206.201(a)). Once funded, an applicant becomes a subrecipient.

Recipient — The government the grant is awarded to, accountable for use of the funds. Generally it is the state for which the disaster is declared, though a Tribal Nation may choose to be a recipient instead of acting as a subrecipient under the state (44 CFR 206.201(m)).

Subrecipient — A non-federal entity that receives a subaward from a pass-through entity (the recipient) to carry out part of a federal program; it does not include individual program beneficiaries (PAPPG v5, Appendix C; 44 CFR 206.201(o)).

Subaward — The award a pass-through entity provides to a subrecipient. It does not include payments to a contractor or to an individual beneficiary (PAPPG v5, Appendix C).

Private nonprofit (PNP) organization — A nongovernmental entity holding an effective IRS ruling letter under Section 501(c), (d), or (e), or satisfactory state evidence of nonprofit status (44 CFR 206.221(f)). A PNP facility provides educational, utility, emergency, medical, or custodial care services, or other essential governmental-type services open to the general public (44 CFR 206.221(e)).

Local government — Broadly defined: counties, municipalities, towns, school districts, special districts, councils of governments, regional entities, and certain tribal organizations and rural communities (PAPPG v5, Appendix C).

Declarations and programs

Declaration — The presidential action that triggers Stafford Act assistance. The declaration designates which types of assistance are authorized and in which areas, and those designations can vary by county (PAPPG v5, Chapter 1).

Major disaster — Any natural catastrophe — or, regardless of cause, any fire, flood, or explosion — that the president determines causes damage severe enough to warrant major disaster assistance under the Stafford Act (PAPPG v5, Appendix C).

Emergency — An occasion when the president determines federal assistance is needed to supplement state, local, tribal, and territorial (SLTT) efforts to save lives, protect property and public health and safety, or lessen or avert the threat of a catastrophe (PAPPG v5, Appendix C).

IA vs. PA — Under a major disaster declaration, the president may authorize Individual Assistance (IA), Hazard Mitigation programs, and Public Assistance (PA). IA — chiefly the Individuals and Households Program — helps eligible individuals and households; PA funds governments and eligible PNPs (PAPPG v5, Chapter 1).

Incident period — The time span during which the disaster-causing incident occurs. Claimed damage must generally have occurred during, and been caused by, the declared incident (PAPPG v5, Appendix C and Chapter 5).

Work, facilities, and projects

Emergency work — Work that must be done immediately to save lives, protect improved property, protect public health and safety, or avert or lessen the threat of a major disaster (PAPPG v5, Appendix C). It covers Categories A and B.

Permanent work — Restorative work, through repair or replacement, to restore an eligible facility on the basis of its pre-disaster design and current applicable codes and standards (PAPPG v5, Appendix C). It covers Categories C–G.

Categories A–G — FEMA's classification of eligible work: A (debris removal) and B (emergency protective measures) are emergency work; C (roads and bridges), D (water control facilities), E (buildings and equipment), F (utilities), and G (parks, recreational, other) are permanent work (PAPPG v5, Chapters 7–8). PAPPG v5 also references Category I for building code and floodplain management administration and enforcement. See the full guide to Categories A–G.

Facility — Any publicly or privately owned building, works, system, or equipment — built or manufactured — or an improved and maintained natural feature. Agricultural land is not a facility (PAPPG v5, Appendix C).

Force account — An applicant's own labor forces and equipment, as opposed to contracted resources (44 CFR 206.221(b); PAPPG v5, Appendix C).

Immediate threat — The threat of additional damage or destruction from an event that can reasonably be expected to occur within five years — the eligibility test behind most Category A and B work (PAPPG v5, Appendix C).

Hazard mitigation (406 mitigation) — Any cost-effective measure that reduces the potential for damage to a facility from a disaster event. FEMA funds it on permanent work projects under Stafford Act Section 406 and calls it "406 mitigation" (PAPPG v5, Appendix C and Chapter 8).

Project — A logical grouping of work required as a result of the declared incident. FEMA must approve an eligible scope of work and itemized cost estimate before funding a project, and a project may span several sites (44 CFR 206.201(k)).

Project Worksheet (PW) — FEMA Form 90-91, the document that records a project's scope of work and cost estimate (44 CFR 206.201(k)). Work estimated below a minimum threshold — $3,000 as published in the regulation, adjusted annually for the Consumer Price Index — is not eligible (44 CFR 206.202(d)).

Scope of work (SOW) — The description of eligible work needed to address an immediate threat or restore a facility to pre-disaster design, function, and capacity plus applicable standards, reflecting the damage description and dimensions (PAPPG v5, Appendix C).

Small project / large project — A small project's final obligated amount (federal plus non-federal) falls below the annually adjusted cost threshold for small project grants; a large project meets or exceeds it (PAPPG v5, Appendix C). Small projects use simplified procedures under Stafford Act Section 422 and are funded on estimates; large projects are reconciled to documented actual costs at closeout. Details in small vs. large projects.

Improved project — A project that restores the facility's pre-disaster function but incorporates improvements or changes to the pre-disaster design (PAPPG v5, Appendix C).

Alternate project — When the applicant determines the public welfare is not best served by restoring the damaged facility and asks FEMA to apply the PA funding to a different facility (PAPPG v5, Appendix C).

Section 428 (alternative procedures) — Stafford Act authority for FEMA to fund large permanent work projects on fixed, capped cost estimates rather than actual costs. Applicants keep flexibility to use excess funds across alternative procedures projects with less itemized cost tracking (PAPPG v5, Appendix G). See Section 428 alternative procedures.

Money: funding and cost terms

Obligation — FEMA's formal commitment of funds. Project approval — the Regional Administrator signing off on work and costs — "is also an obligation of funds to the recipient" (44 CFR 206.201(l)). FEMA obligates the federal share of eligible project costs to the recipient, which then distributes funds to subrecipients (PAPPG v5, Chapter 9).

Federal share / cost share — The portion of total project costs paid with federal funds (PAPPG v5, Appendix C). FEMA's published PA overview states the federal cost share is no less than 75 percent.

Cost Estimating Format (CEF) — The estimating tool FEMA uses for permanent work sites that are less than 90 percent complete when expected costs meet or exceed the large project threshold, applying defined factors and contingency ranges per the CEF Instructional Guide (PAPPG v5, Chapter 9).

Management costs and DAC — Management costs are any indirect cost, direct administrative cost (DAC), or other administrative expense associated with a specific project (PAPPG v5, Appendix C). Under the Disaster Recovery Reform Act of 2018, FEMA may contribute up to 12 percent of the total award — not more than 7 percent for the recipient and 5 percent for the subrecipient — based on actual costs incurred (FEMA Recovery Policy FP 104-11-2; PAPPG v5, Chapter 6).

Duplication of benefits — Funding received from two sources for the same item of work — for example, insurance proceeds and PA funding covering the same repair. FEMA reduces awards to prevent it (PAPPG v5, Appendix C).

Period of performance — The time during which the non-federal entity may incur new obligations to carry out the work authorized under the federal award (PAPPG v5, Appendix C).

Process: from application to closeout

Request for Public Assistance (RPA) — The form a public entity or PNP uses to apply for PA. Requests are due within 30 days after the area is designated in the declaration (PAPPG v5, Appendix C; 44 CFR 206.202(c)).

Grants Portal — The online system applicants use to submit and manage PA project applications, per FEMA's published PA overview.

VAYGo (Validate As You Go) — FEMA's grant payment review process, implemented in 2019 and expanded to all PA and Fire Management Assistance Grant disasters in December 2020. It audits drawdowns to identify improper payments and reduces closeout documentation for recipients with proven internal controls (PAPPG v5, Chapter 11).

Closeout — Final reconciliation of projects and the award. Subrecipients generally certify small project completion within 90 days of the last small project's completion date, and must document actual costs for large projects within 90 days of work completion (PAPPG v5, Chapter 12).

Section 705 — The Stafford Act provision that, in defined circumstances, prohibits FEMA from recovering PA payments made to state, tribal, or local governments. It does not protect PNPs and does not apply once a final administrative decision has been made (FEMA Policy 205-081-2).

Appeals and disputes

First appeal — An applicant may appeal any FEMA determination by submitting a written appeal through the recipient to the Regional Administrator within 60 days of the determination; the recipient forwards it with a recommendation within 120 days (PAPPG v5, Chapter 2; 44 CFR 206.206).

Second appeal — If the first appeal is partially or fully denied, the applicant may appeal through the recipient to the Assistant Administrator for the Recovery Directorate. Second appeal decisions are FEMA's final administrative decision (PAPPG v5, Chapter 2). The mechanics are covered in the PA appeals guide.

Arbitration — Under Stafford Act Section 423, applicants may instead take qualifying disputes to the Civilian Board of Contract Appeals (CBCA): the amount in dispute must exceed $500,000 ($100,000 for rural-area applicants), a timely first appeal must have been filed, and FEMA must have denied it or failed to decide within 180 days. A request is due within 60 days of the first appeal decision, and an applicant may pursue a second appeal or arbitration — not both (PAPPG v5, Chapter 2; FEMA PA Arbitration Fact Sheet).

For how these terms fit together in practice, start with the overview of FEMA Public Assistance or ask PAPPAIA directly.