May states, territories and the District of Columbia demonstrate the 25% cost share for administrative costs through the underlying state-funded benefit payments made to eligible claimants?

Yes, states, territories and the District of Columbia may use the underlying state-funded benefit payments made to eligible claimants to demonstrate that the 25% cost share for their federal LWA award has been met.  At closeout, FEMA will ensure the 25% cost share has been met at the aggregate level, for both benefit payments and administrative costs.  (See [44 C.F.R. § 206.110(i)]).