After a disaster strikes and an applicant has requested Public Assistance help from FEMA, submitting all damages along with the supporting documentation is often long and arduous. One method to help speed up the obligation of small, completed work projects is by submitting the projects as APP CERT projects.
In August 2022, FEMA increased the established threshold for Small Project maximum for the agency’s Public Assistance (PA) program to $1 million. The goal was that the increased threshold would reduce the administrative burden on state, local, tribal, or territorial (SLTT) governments and private non-profit (PNP) organizations receiving FEMA financial grants following a disaster. The PA Simplified Procedures Policy streamlines application procedures for Small Project funding under the PA program, simplifies the implementation of the PA program and supports rapid recovery for applicants. The use of simplified procedures, such as submitting self-certified estimates and summary reports, should allow applicants to receive funding early and promote rapid recovery from the disaster.
To be able to take advantage of submitting Subrecipient (Applicant) Certification projects, or APP CERT projects as they are commonly called, an applicant’s projects must have the following requirements:
- The Project must be a small project that is greater than the minimum threshold but less than $1M. For fiscal year 2023, the small project minimum threshold is $3,800.
- The project must be classified as a category B-G project.
- The work for the project must already be completed.
All other projects, including Category A projects, completed work projects greater than $1M, and any project where the work has not been completed, are not eligible to utilize the simplified APP CERT process. These projects must be developed using documentation required through the Essential Elements of Information (EEIs) in FEMA’s Grants Portal, which is the normal, more time-consuming process.
To streamline the process, the applicant must submit to FEMA the signed APP CERT form for damage and work instead of providing comprehensive source documentation. This form certifies that the damage was directly caused by the declared incident. More detailed guidelines and what is required are included in FEMA Policy FP-104-23-001 and are outlined here as follows:
- Damage: All damage claimed was a direct result of the Presidential emergency and major disaster declaration. The damage did not result from a lack of maintenance.
- Work Claimed: All work claimed to restore the facility to its pre-disaster design function, and capacity was required as a direct result of the Presidential emergency and major disaster declarations, is located within the designated area, and is the applicant’s legal responsibility.
- Impartial and Equitable Delivery of Public Assistance: All work claimed was delivered in an impartial and equitable manner as required by Title VI of the Civil Rights Act, Section 308 of the Stafford Act, 42 U.S.C. § 5151, and applicable provisions of laws and authorities prohibiting discrimination.
- Code and Standard Compliance: All facilities are being restored in accordance with all federal and SLTT code and standard requirements.
- Procurement and Contracting: The applicant is using the most restrictive of either its own documented policies and procedures for procurement or federal procurement and contracting laws in accordance with 2 C.F.R. Part 200. The applicant is following Environmental Protection Agency guidelines for the procurement of recovered materials; and including all applicable required contract provisions.
- Cost Reasonableness: All costs claimed are reasonable and of a type generally recognized as ordinary and necessary for the type of facility and work as required by 44 C.F.R. § 206.228 and 2 C.F.R. § 200.404.
- Duplication of Benefits: No work or costs are being claimed that another funding source covers.
- Documentation Retention: All documentation is being retained in accordance with 2 C.F.R. §§ 200.334 and 200.337 and will be provided upon request.
- True and Correct Statements: All information provided is true and correct. Upon submittal, the certified Project Application becomes a legal document. It is a violation of federal law to intentionally make false statements or hide information when applying for Public Assistance.
If you have completed work projects that are less than $1M, then take full advantage and utilize FEMA’s APP CERT process when submitting your small projects into Grants Portal. You’ll save time by only having to submit summary cost documentation along with your signed APP CERT form certifying the costs as a direct result of the disaster. FEMA will then develop the project based on the provided certification and cost summaries, and you can get back to focusing on your pre-disaster work.