Which PAPPG Version Applies to Your Disaster?

The Public Assistance Program and Policy Guide (PAPPG) version that governs your grant is set by a single fact: the date the President declared the disaster or emergency. FEMA applies PAPPG Version 5 to incidents declared on or after January 6, 2025, and Version 4 to incidents declared on or after June 1, 2020 — which in practice means Version 4 covers declarations from June 1, 2020 through January 5, 2025. Declarations before June 1, 2020 fall under earlier, archived editions (Version 3.1 and prior).

Nothing else moves that anchor. The date the damage occurred, the date you submit your Request for Public Assistance, and the date the work is performed do not change which PAPPG applies — applicability keys off the declaration itself. If you manage grants across multiple disasters, you may be working under two different rulebooks at the same time, and that is by design.

The declaration date rule

Each PAPPG edition states its own applicability in nearly identical terms. The Version 5 introduction states that FEMA applies Version 5 to incidents "declared on or after January 6, 2025" (Introduction, Section II, Applicability). The Version 4 introduction says the same for incidents declared on or after June 1, 2020 (Introduction, Section V, Applicability). Each new edition supersedes the last — the v5 foreword notes it supersedes Version 4.1 (the June 1, 2020 edition as amended), and the v4 foreword notes it superseded Version 3.1 — but supersession is forward-looking only. A disaster declared under Version 4 stays under Version 4 for its entire lifecycle, even if closeout happens years after Version 5 took effect.

That is why FEMA archives previous editions rather than retiring them: the v5 foreword points readers to the PAPPG archives on FEMA.gov for prior versions, because older declarations still need them as the operative policy reference.

One wrinkle worth knowing for current disasters: the edition now in circulation is Version 5.0 Amended. Its cover note explains that v5 was amended to reflect Executive Orders issued on and after January 20, 2025, with changes to Chapters 4, 6, 8, and 10, Appendices A, B, C, D, and G, and removal of the option for an independent expert-panel cost-estimate review for projects with a federal cost share greater than $5 million. It remains the edition that applies to incidents declared on or after January 6, 2025.

Version timeline at a glance

Declaration date vs. incident date

The declaration date and the incident are two different things, and only the first controls the PAPPG version. Under 44 CFR § 206.32(f), the incident period is the time interval during which the disaster-causing incident occurs; it is established by FEMA in the FEMA-State Agreement and published in the Federal Register. The declaration typically comes later — sometimes weeks later, after preliminary damage assessments and the governor's or tribal chief executive's request.

The PAPPG itself treats the two dates as distinct: for example, a governor's — or, for Tribal Nation declarations, a tribal chief executive's — request to add areas to a declaration is due within 30 days of the declaration date or the end of the incident period, whichever is later. (The Request for Public Assistance runs on a different clock entirely: an applicant must submit its RPA within 30 days after its area is designated, per 44 CFR § 206.202(c).) So a severe storm that struck in December 2024 but was declared in February 2025 is a Version 5 disaster, even though every dollar of damage predates v5's effective date. Working the other direction, a disaster declared January 3, 2025 stays under Version 4 even though most project formulation happened well into the v5 era.

Why the version matters

PAPPG versions are not editorial refreshes — substantive rules change. The Version 5 Summary of Changes lists, among other things: reduced documentation requirements for small projects, removal of the pre-approval requirement for private property debris removal, removal of pre-approval for non-congregate sheltering in traditional settings such as hotels and dormitories, expanded pet and service-animal sheltering eligibility, removal of childcare as a standalone emergency protective measure, consolidation of private nonprofit guidance, and incorporation of the revised 2 CFR Part 200 that took effect October 1, 2024. Version 5 also replaced "may" and "should" with "must" in many places to clarify what is actually required. Apply v5 assumptions to a v4 disaster (or vice versa) and you can miss a pre-approval that is still required — or paper a file for approvals that no longer exist.

Versions also absorb standalone policies. Version 5 incorporates and supersedes more than a dozen separate documents, including the Public Assistance Appeals and Arbitration policy (FEMA Policy 104-22-0001), Public Assistance Simplified Procedures (FEMA Policy 104-23-001), the Consensus-Based Codes, Specifications, and Standards interim policy, and the 2023 management-costs simplification memo. For a v5 disaster, the PAPPG itself is where that policy now lives; for an older disaster, the standalone document may still be the operative citation — which matters when you are drafting an appeal and need to cite the policy that actually applied to your declaration.

Version 4 made its own structural change: it incorporated the Alternative Procedures for Permanent Work pilot policy and established Alternative Procedures as the first option considered for all large permanent work projects.

Where to check

• The declaration itself. Every declaration carries its date, and under 44 CFR § 206.40(a) the initial designations of assistance types are usually announced in the declaration. FEMA lists declarations and their dates at fema.gov/disaster/declarations.
• The Federal Register. The incident period is established in the FEMA-State Agreement and published in the Federal Register per 44 CFR § 206.32(f) — useful for confirming which damage falls inside the covered interval.
• The PAPPG's own applicability statement. Version 5 states its effective scope in the Foreword and in Introduction Section II; Version 4 in its Foreword and Introduction Section V. When in doubt, read the front matter of the edition you are holding.
• FEMA's archives. The v5 foreword directs readers to the archived prior editions on FEMA.gov for disasters governed by older versions.

Common mistakes when the wrong version is used

1. Keying off the incident date instead of the declaration date. Damage in late 2024 declared in 2025 is a v5 disaster. The incident period defines what damage is covered, not which policy applies.
2. Applying the newest guide to an older open disaster. Version 5 applies only to incidents declared on or after January 6, 2025. A 2023 declaration still in closeout remains a Version 4 disaster, no matter how current the work is.
3. Citing a superseded standalone policy — or missing one that still applies. Policies like the appeals and simplified-procedures policies were folded into v5. Cite the version of the rule in effect for your declaration, not the most recent PDF you can find.
4. Assuming dollar thresholds come from the PAPPG version. FEMA establishes a minimum project threshold each federal fiscal year; that threshold applies to incidents declared within that fiscal year and is based on the Consumer Price Index (44 CFR § 206.202(d)(2)). FEMA also establishes the dollar threshold dividing large from small projects each federal fiscal year, adjusted annually for the Consumer Price Index (44 CFR § 206.203(c)). Two v5 disasters declared in different fiscal years can have different thresholds.
5. Overlooking the Amended edition. If you are working a 2025 declaration from an early copy of Version 5.0, check Chapters 4, 6, 8, and 10 and Appendices A–D and G against Version 5.0 Amended — including the removed expert-panel cost-review option.
6. Forgetting date-pinned rules inside a version. Even under the right version, some tests pin to specific dates — codes and standards generally must apply as of the declaration date, and labor cost eligibility is tied to the labor policy in effect before the incident start. The version is the first date question, not the last.

If you are new to the program, start with the PA program overview — but before you rely on any eligibility rule, confirm your declaration date and pull the matching PAPPG.