The evidence

Why paperwork costs local governments real money.

Every figure below links to its source. Where a number needs context, we give it.

FindingWhat it showsSource
$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 sixReimbursement 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 grantsThe 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-costFEMA 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 2025Smoky 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 declarationRules that applyCost-plus-percentage-of-cost ban
Dec 26, 2014 to Nov 11, 20202 CFR 200 as issued in 2014§200.323(d)
Nov 12, 2020 to Sep 30, 20242 CFR 200 as revised in 2020§200.324(d)
On or after Oct 1, 20242 CFR 200 as revised in 2024§200.324(c)
Hurricane Helene, any declaration date2024 revisions, by FEMA decision to apply them uniformly to all Helene declarations§200.324(c)
Incidents declared on or after Jan 6, 2025FEMA Public Assistance Program and Policy Guide, version 5.0PAPPG 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.