The evidence
Why paperwork costs local governments real money.
Every figure below links to its source. Where a number needs context, we give it.
| Finding | What it shows | Source |
|---|---|---|
| $345,419,811 in exceptions on 1,021 of 4,546 FEMA Public Assistance reimbursement requests (Jul 2025 to Jun 2026) | Includes $266.9M on 799 requests not supported by sufficient documentation and $22,517,408 on 82 requests where auditors could not confirm procurement guidelines were followed. These are pre-payment exceptions, not confirmed misspending; most are later resolved with more paperwork. | WBRZ · WAFB, Sep 2026, on the Louisiana Legislative Auditor's review |
| 73% of counties with outstanding claims say their longest has been pending more than two years; 28%, more than six | Reimbursement takes years, and counties carry the cost in the meantime. | NACo, survey of 130+ counties, Oct 2023 |
| $3.1M questioned and $7.9M over-obligated in FEMA small project grants | The Inspector General recommended complete documentation and photo evidence for small projects. | DHS OIG-26-25, Sep 2026 |
| A 12 percent markup denied as cost-plus-percentage-of-cost | FEMA denied the City of Cape Coral the markup on fencing rental under Hurricane Ian (FEMA-4673-DR-FL), on second appeal. One contract sentence, caught only after the money was spent. | FEMA appeal decision |
| "If we don't have proper documentation and follow procurement processes, then we don't get reimbursed." | Kristian Owen, Finance Director, Haywood County, NC, Sep 2025 | Smoky Mountain News |
Rule versions
Which rules apply depends on the date.
The same clause carries a different citation depending on when the award was made or the disaster declared. Getting this wrong is a common, avoidable error.
| Award or declaration | Rules that apply | Cost-plus-percentage-of-cost ban |
|---|---|---|
| Dec 26, 2014 to Nov 11, 2020 | 2 CFR 200 as issued in 2014 | §200.323(d) |
| Nov 12, 2020 to Sep 30, 2024 | 2 CFR 200 as revised in 2020 | §200.324(d) |
| On or after Oct 1, 2024 | 2 CFR 200 as revised in 2024 | §200.324(c) |
| Hurricane Helene, any declaration date | 2024 revisions, by FEMA decision to apply them uniformly to all Helene declarations | §200.324(c) |
| Incidents declared on or after Jan 6, 2025 | FEMA Public Assistance Program and Policy Guide, version 5.0 | PAPPG v5.0 |
OMB proposed a further rewrite of 2 CFR 200 on May 29, 2026 (FR Doc. 2026-10817). As of this writing it is not final. Sources: Federal Register, PAPPG v5.0 · Federal Register, proposed rule · FEMA Helene fact sheet.