Use case
Reconciliation basis, closeout clocks, and Section 705 recoupment limits — cited to the section and page so you can verify each one yourself. Ask a specific closeout question and read the cited policy.
Citations checked against current published sources 2026-09-04
"We're closing out a disaster with a mix of small and large projects. The recipient wants certifications, one large project came in $400k under the obligated amount and another ran over. Which deadline applies to which project, what has to be in the package, and how long can FEMA come back at us afterward?"
Small projects are funded on the approved estimate and are not adjusted to actual costs except under conditions PAPPG v5 Chapter 12 lists, such as: incomplete scope of work, an approved scope change, actual insurance proceeds above or below the estimated deduction, errors or omissions, hidden damage, non-compliance, or fraud, waste, or abuse (PDF pp. 257-258; 44 CFR 206.205(a)). Large projects reconcile to the actual documented cost of completing the approved scope (44 CFR 206.205(b)). Paste the project's classification and obligated amount; PAPPAIA returns the governing rule with the section and page.
90 days for a subrecipient's actual-cost documentation on a large project. 180 days for the recipient's certification and final claim, measured from the work completion date or the project completion deadline, whichever occurs first. 90 days for the subrecipient's certification of completion for all small projects to the recipient, from the last small project completion date or the last approved completion deadline, whichever is sooner — where no NSPO appeal is being requested. 60 days for a net small project overrun appeal (PAPPG v5 Ch. 12, PDF pp. 258-259; 44 CFR 206.204(e), 206.205). The 90- and 180-day clocks run from the obligation date instead when work was finished before obligation. If the subrecipient's small projects are not all obligated when the 60-day NSPO window would start, that window runs 60 days from the date FEMA obligated its last small project (PAPPG v5 Ch. 12, PDF p. 258).
Table 34 requires a large project closeout package to include, among other items: final inspection report, summaries of scope and expenditures, source documents for force account labor and equipment, materials and contract costs, procurement documentation, mutual aid agreements, the final statement of loss, correspondence with regulatory agencies, change orders, pay policies, codes and standards incorporated into the scope, documentation substantiating compliance with all award terms and conditions including EHP, and photos of completed work for Categories C-G (PAPPG v5, PDF p. 259). Ask how your transmittal index compares with Table 34.
Stafford Act Section 705 gives FEMA 3 years to give notice of intent to recover payments, absent evidence of fraud. FEMA states the clock as running from the date the recipient submitted the certification of project completion (PAPPG v5, PDF p. 261); the statute runs it from transmission of the final expenditure report for project completion as certified by the recipient (42 U.S.C. § 5205(a)(1); PAPPG v5, PDF p. 262). It does not protect private nonprofits, and it does not apply once FEMA has issued a final administrative decision (FEMA Policy FP 205-081-2 Version 2). Section 705(c) separately bars recovery where the payment was authorized by an approved agreement specifying costs, the costs were reasonable, and the purpose of the grant was accomplished (PAPPG v5 Ch. 12, PDF p. 261).
FEMA does not normally review an overrun on an individual small project; the route is a net small project overrun appeal across all of a subrecipient's small projects, filed within 60 days of the latest work completion date (44 CFR 206.204(e)(2)). Large project overruns from unit-price variation, eligible scope change, or delay go through the recipient to the Regional Administrator (44 CFR 206.204(e)). An underrun on a small project does not reduce the federal payment (44 CFR 206.205(a)). An underrun on a large project does: FEMA reconciles the actual costs and amends the project to reduce funding to the eligible actual cost (PAPPG v5, PDF p. 260). Section 428 capped projects are funded on a fixed cost estimate rather than reconciled to actuals, and FEMA approves no additional funds if actual costs exceed the cap. The fixed amount is adjusted only for insurance and for approved scope changes tied to hazard mitigation, and is reduced if approved PA mitigation is not completed (PAPPG v5, Appendix G, PDF pp. 295-296).
A large project is reconciled to the actual documented cost of completing the approved scope of work, not the obligated estimate (44 CFR 206.205(b)). Documentation supporting your actual costs is due within 90 days of work completion. The recipient's completion certification and final claim are due to FEMA within 180 days of the work completion date or the project completion deadline, whichever occurs first. If work was finished before obligation, both clocks run from the obligation date instead. Where eligible actual costs exceed the initial approval, the Regional Administrator obligates additional funds.
Sources
PAPPAIA retrieves the passages of your upload most relevant to the question you ask and puts them beside the governing policy. It does not read a closeout package end to end, and it cannot tell you what your file is missing.
Free while PAPPAIA is in public preview. Answers are grounded in cited policy sources and include exact references for independent verification. General information, not legal or grant-compliance advice.
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