Pre-award costs directly related to developing a subapplication that are incurred prior to the date of the grant award are allowed, subject to FEMA approval at the time of the award. Pre-award costs may be incurred, for example, when gathering National Environmental Policy Act data or developing a BCA, preparing design specifications, or when holding workshops or meetings related to reviewing proposed alternatives and designs. Pre-award costs are allowable only to the extent that they would have been allowable if incurred after the date of the federal award.[60]
Pre-award costs may be cost shared or applicants and subapplicants may identify them as their non-federal cost share. For more information on cost share requirements, refer to Part 4.
In general, pre-award costs are eligible for activities that involve no commitment of resources other than staffing and associated funding. Costs for activities, such as ground disturbance or construction, or activities that would affect historic properties and/or threatened and endangered species and that are initiated or completed outside of the application period and period of performance are not eligible. In addition, any ground disturbance or construction activity completed before FEMA approval is not allowed and therefore their associated costs are not eligible. Projects initiated or completed prior to the federal award or full approval of the project are not eligible.[61]
Activities directly related to the project, including management costs and project costs, may be eligible for pre-award costs. Any pre-award costs designated as management costs count toward the 5% limit for subrecipient management costs. Eligible management costs activities may include developing the application or subapplication, preparing the BCA, and gathering EHP data. For more on management costs, refer to Part 13.
To be eligible for HMA, pre-award costs must be identified as separate line items in the budget of the subapplication and cannot have been funded by another project, award or program. Applicants and subapplicants who are not selected for awards or subawards will not receive reimbursement for the corresponding pre-award costs.
For HMGP and HMGP Post Fire, eligible pre-award costs are those incurred after the date when HMGP is authorized, which is generally the date of the major disaster declaration.[62]
For BRIC and FMA, the period of eligibility for pre-award costs is addressed in the NOFO.