For mid-market FEMA Public Assistance applicants
FEMA obligated your disaster money. Keeping it is a documentation problem.
Reoblige builds the PAPPG-grade evidence file — and drafts the appeal — that keeps obligated Public Assistance dollars from being deobligated at closeout.
You get back: a certification-ready Recovery File — every cost line mapped to PAPPG V5 and 2 CFR 200, insurance offset reconciled, and a drafted Project Worksheet or appeal for your authorized representative to sign.
Fixed, reimbursable fees. Never hourly, never a percentage of what FEMA restores.
Primary sources
Read the rules yourself — not just our summary of them.
Every regulatory reference on this page traces to a specific primary source. These are the same citations a senior PA specialist checks before a cost line or appeal argument ships.
42 U.S.C. Chapter 68
The Robert T. Stafford Disaster Relief and Emergency Assistance Act — §§406/407 (PA categories), §324 (management costs), §312 (anti-duplication of benefits). Read the statute — Cornell Law LII →
PA project administration
Subpart G governs Public Assistance project administration, including the administrative appeal process and its filing windows. Read 44 CFR Part 206 — eCFR →
Uniform Guidance
Cost reasonableness (200.404), procurement (200.317–327), and fee allowability (200.459) — the framework every cost line and fee structure in a Recovery File is tested against. Read 2 CFR Part 200 — eCFR →
FP 104-009-2
FEMA's Public Assistance Program and Policy Guide, Version 5 — the eligibility ruleset for declarations on or after January 6, 2025. Read the Federal Register notice →
The work was eligible. The dollars still get clawed back.
FEMA obligates Public Assistance dollars fast and reconciles them slowly — sometimes years later. The burden of proof sits entirely on you, and funds are recovered whenever a cost cannot be verified with the documentation provided or is not tied to eligible work. Here is where mid-market applicants lose money for avoidable reasons:
"Could not be verified"
Labor and equipment costs stripped at closeout because the timesheets, usage logs, and rates were never assembled the way FEMA requires.
A Determination Memo lands
The appeal window starts the day you receive it — 60 days, on the written record, against the PAPPG and 2 CFR 200. Miss it and the record closes.
The contingency trap
A percentage-of-recovery consultant's fee is unallowable for reimbursed grant work — and can quietly make your own recovery unreimbursable.
Duplication of benefits
Insurance proceeds not reconciled against claimed costs, triggering an anti-duplication recovery you never saw coming.
Procurement defects
A contract that didn't meet full-and-open-competition rules surfaces at closeout and unwinds the reimbursement behind it.
Downstream exposure
Everything has to survive a later 2 CFR 200 Subpart F audit and DHS OIG review — long after the recovery office has moved on.
What Reoblige hands back
Not software your recovery office has to operate. A defended, closeout-ready outcome — the same ubiquitous file, whether you are documenting a project or fighting a denial.
Closeout Documentation Package
Every reimbursable cost — labor, equipment, materials, contracts, force account — mapped to PAPPG V5 and 2 CFR 200, with the source-trace appendix and completeness checklist.
Deobligation Defense
The Recovery File plus a drafted first appeal with correct policy citations, red-teamed against FEMA's own appeal record and filed before the 60-day clock.
Second Appeal Package
A drafted second administrative appeal to FEMA Headquarters, argued on the written record when a first appeal is denied.
Managed Recovery Program
Ongoing documentation, closeout, and deadline tracking across every Project Worksheet in one declaration, capped to your management-cost budget.
Insurance-offset reconciliation
Settlement statements reconciled to claimed costs so a Stafford Act §312 duplication finding never surfaces at closeout.
Source-trace audit trail
Every cost line traced to its source document, page, eligibility basis, and specialist release — the record an auditor would ask for.
How the file gets built
An AI production engine does the extraction, classification, reconciliation, and drafting. Two human chokepoints gate every file: a senior PA specialist releases it, and your authorized representative certifies it.
Intake
Cost records, prior FEMA letters, and insurance settlements land in a secure portal against a structured checklist per Project Worksheet.
Normalize
Every document is parsed to a canonical cost-line schema: source doc, date, amount, category, project, facility.
Eligibility map
Each cost line is mapped to PAPPG V5 eligibility and 2 CFR 200.404 reasonableness; edge cases are flagged.
Gap scan
The engine runs insurance-offset math and procurement checks and predicts exactly what FEMA would cite — so it gets fixed first.
Specialist release
A senior PA specialist reviews the flagged items and the drafted Project Worksheet or appeal: "will FEMA cite this?"
Certify & submit
Your authorized representative certifies; the Recovery File and submission checklist go to the Recipient and FEMA with a full audit trail.
Fixed fees, scoped to be reimbursable
Priced per deliverable — never hourly, never cost-plus, never a percentage of recovery. Fees are scoped to fit inside your 5% subrecipient management-cost pool, so in most engagements the file that defends your dollars is paid for with FEMA-funded dollars.
| Offer | Unit | Price |
|---|---|---|
| Deobligation-Risk Scan | Per applicant portfolio | Free |
| Closeout Documentation Package | Per Project Worksheet | $2,500–$9,000 |
| Deobligation Defense (first appeal) | Per appeal package | $6,000–$18,000 |
| Second Appeal (FEMA HQ) | Per second appeal | $10,000–$30,000 |
| Managed Recovery Program | Per disaster event, monthly | $4,000–$15,000/mo |
The out-clause
If the free Deobligation-Risk Scan finds no recoverable exposure in your obligated projects, there is nothing to buy and you owe nothing.
Every engagement is a fixed fee agreed in writing before work begins. We do not take a percentage of what FEMA restores — 2 CFR 200.459 makes that unallowable, and we will not put your own recovery at risk.
You stay the applicant of record. We prepare; your authorized representative certifies and files.
What proof will look like
Reoblige is pre-launch. We will not invent testimonials, client names, or win-rates. These slots fill in with real FEMA determinations as the first Recovery Files clear reconciliation — and not before.
[PLACEHOLDER] First-appeal outcome on a documented Deobligation Defense engagement — published here once a real determination clears, with the cost categories restored. No figure is shown until it is measured.
[PLACEHOLDER] Dollars protected at closeout across a full disaster event, once a Managed Recovery cohort completes reconciliation. Not invented in the meantime.
[PLACEHOLDER] Named recovery coordinator's account of the intake-to-certification workflow, published only with their written consent.
Sample deliverable
What a Recovery File cost-line entry actually looks like.
Illustrative example built from a fictional Project Worksheet — not a real applicant, facility, or FEMA determination. This is the shape and level of detail every real Recovery File returns.
| Cost line | Category | PAPPG V5 eligibility | Status |
|---|---|---|---|
| PW-014 · [Facility Co.] roof repair labor | Force account labor | Eligible — 2 CFR 200.430 | Ready |
| PW-014 · Contractor invoice #2281 | Procurement | Reasonableness review — 200.404 | Review |
| PW-019 · Insurance settlement offset | §312 duplication check | Reconciliation needed | Open |
| PW-022 · Equipment usage log | FEMA equipment rate | Eligible — FEMA rate schedule | Ready |
Each row in a real Recovery File links to the source document, the specific PAPPG V5 or 2 CFR 200 citation, and the senior PA specialist's release note. Eligibility calls shown here are illustrative, never a guarantee of any specific applicant's outcome.
What applicants ask before they start
Isn't this just something our accountant can do?
Can we afford it in a disaster year?
Do we hand over control of our FEMA relationship?
What if FEMA still denies the appeal?
Is the AI making the eligibility calls?
How fast can you move when a deobligation letter shows up?
Resource center
Glossary and related reading, for anyone doing this in-house.
You don't need to send Reoblige anything to use these. They're the same terms and thresholds our PA specialists work from.
Glossary
Project Worksheet (PW) — FEMA's per-project scope-and-cost document. Deobligation — FEMA's recovery of previously obligated funds at closeout or audit. Determination Memo — the letter that starts the 60-day appeal clock. Management-cost pool — the 5%/7% reimbursable budget (DRRA §1215) that can fund documentation help.
Full operating blueprint
The complete dossier behind this desk — market sizing, competitor landscape, and the deterministic release gates that keep every filing specialist-reviewed and applicant-certified.
When to keep this in-house
If your disaster event involves a single small Project Worksheet with straightforward, well-documented costs, an in-house grants manager working directly from the PAPPG may be enough. Outside help earns its fee once multiple Project Worksheets, an insurance offset, or a deobligation letter are in play.
Related sources
See the primary-source basis above for the Stafford Act, 44 CFR Part 206, 2 CFR Part 200, and PAPPG V5 references this desk operates within.
Get a free Deobligation-Risk Scan
Tell us where you are in the grant, and a senior PA specialist will read your exposure — no fee, no obligation. If there's nothing recoverable, we'll tell you.
Scope, boundaries & disclaimers
Reoblige is a documentation and managed-service provider. What that means, precisely:
- We prepare; you certify and file. The applicant's authorized representative certifies and submits every Project Worksheet, Recovery File, and appeal to the Recipient and FEMA. We never certify or file on your behalf.
- Not legal advice. Reoblige does not provide legal advice and does not represent applicants in litigation. Preparing and drafting Public Assistance administrative appeals is work applicants and disaster-recovery consultants perform routinely; where a matter escalates to arbitration before the Civilian Board of Contract Appeals or to litigation, you should engage counsel.
- Fee treatment. Fees are structured as reasonable, fixed professional-service costs consistent with 2 CFR 200.404 and 2 CFR 200.459, scoped to the Section 1215 management-cost pool. Reimbursability depends on your award and Recipient's determination; we do not guarantee any specific reimbursement or appeal outcome.
- Data handling. Cost records enter a secure intake portal, are processed to a canonical cost-line schema, and are retained only through the grant period plus the 2 CFR 200 record-retention window. Access is limited to the analysts and senior PA specialist assigned to your disaster event.
Reoblige is an independent service and is not affiliated with, endorsed by, or acting on behalf of FEMA, the Department of Homeland Security, or any federal or state agency. Statutory and policy references (Stafford Act, 44 CFR Part 206, 2 CFR Part 200, PAPPG Version 5, DRRA §1215) are provided for context and are current as of July 2026; applicants remain responsible for compliance under the authorities in effect for their declaration.
Page content and primary-source citations last reviewed 2026-07-18.