Planning for disaster recovery with less federal help

On October 20, FEMA Administrator Cameron Hamilton spoke to state emergency management leaders at the National Emergency Management Association's annual conference in Little Rock. He told them states must increase their financial reserves and emergency capabilities to handle most disasters on their own, according to POLITICO. "Every state must have the appropriate financial reserves," Hamilton said in a recording obtained by POLITICO. He said the reserves are needed "to ensure that recovery efforts can start immediately" instead of waiting on the federal declaration process.

POLITICO reported that the remarks added detail to an internal FEMA memo dated October 15, which said the agency will "strengthen state and local capacity." Hamilton told the conference that changes could begin "in the next six months." He also described a "national mutual aid" approach in which states help each other recover. According to the same report, the administration has not publicly announced specific changes and has continued to approve disaster aid for weather events.

Local governments keep the recovery record

A county public works department clears roads after a storm with its own operators and equipment, and its finance office pays the contractors who haul the debris. Today those costs reach the Public Assistance program only after the President declares a major disaster or emergency under the Stafford Act (42 U.S.C. 5121 et seq.). Reimbursement then depends on records that meet 44 CFR Part 206 and FEMA's Public Assistance Program and Policy Guide (PAPPG).

If fewer events receive a declaration, more of each recovery is paid from state and local reserves. The records behind a claim are made on the day the work is done, before anyone knows whether the storm will be declared. The Maryland Association of Counties made the same point in its coverage of the news: "Counties still have to maintain response capacity regardless of whether a disaster ultimately qualifies for federal assistance." A record kept to the FEMA standard supports a Public Assistance claim when a declaration comes, and accounts for reserve spending to a council or an auditor when one does not.

The deadlines and thresholds already in force

For incidents declared on or after January 6, 2025, FEMA applies PAPPG Version 5.0 (Amended), the edition its policy page lists today. The guide and the regulation set these dates:

• The Request for Public Assistance is due within 30 days after the area is designated (44 CFR 206.202(c); PAPPG p. 45).
• The applicant has 60 days after its first substantive meeting with FEMA to identify and report damage (44 CFR 206.202(d)(1)(ii)). The PAPPG runs the Impact List deadline from the recovery scoping meeting (p. 70).
• Completion deadlines run from the declaration date: 6 months for debris clearance, 6 months for emergency work and 18 months for permanent work (44 CFR 206.204(c)(1)). The state may extend them by 6 months for debris and emergency work, and by 30 months for permanent work, project by project (206.204(c)(2)(ii)).
• A first appeal is due within 60 calendar days from the date of the FEMA determination it disputes (44 CFR 206.206(b)(1)(ii)(A)).

The documentation standard also depends on project size. Under 44 CFR 206.203(c), a large project is funded on "the actual eligible costs documented by a recipient," and a small project on the approved estimate. The regulation sets the dividing line at $1,000,000, adjusted each year for inflation, and FEMA's published figure for fiscal year 2026 is $1,093,800. On a large project, the federal share follows the costs the applicant can document.

Small project files are reviewed too. The Department of Homeland Security Office of Inspector General sampled 20 completed and closed small projects from 8 of FEMA's 10 regions for OIG-26-25 (September 2, 2026). All 20 files were missing documents and information needed to support approval, and the report questioned $3.1 million in costs.

How Ithil keeps the Public Assistance record

Ithil's Disaster Recovery module keeps an organization's Public Assistance record for each declared incident. Every rule it applies is shown on screen in the words of FEMA or the regulation, with the source and page.

Ithil reads FEMA's disaster declarations from OpenFEMA every day for the organization's county. When a new declaration with Public Assistance covers it, Ithil proposes a disaster incident and notifies the organization's administrators, and an administrator confirms it. Ithil then derives nine deadlines from the declaration date, the designation date, the recovery scoping meeting and the FEMA determination. They include the Request for Public Assistance, the Impact List, the three completion deadlines, the first appeal and closeout. An hourly check notifies administrators and supervisors when one is due soon or overdue, and recording the filing closes it.

Each damaged site is a damage assessment with its photographs, location and description of work. Its packet is checked against the 17 items in Table 1 of OIG-26-25. An item is satisfied by a linked document or by a written reason it does not apply, so a bare checkmark cannot be recorded. The Impact List exports under the labels of FEMA's form.

Force account labor and equipment are recorded by the day. Equipment is priced by cost code from FEMA's Schedule of Equipment Rates, with all 465 rates of the 2025 schedule loaded as published. Each labor line is sorted into eligible, ineligible or needs review under the PAPPG rules for its category of work, pay type and budget status. Budgeted straight time on emergency protective measures, for example, is held out of the eligible total from the day it is entered.

In the contract register, a noncompetitive contract cannot be awarded until its circumstance and written justification are recorded, and a time and materials contract needs a ceiling price first. Cost plus a percentage of cost has no entry at all, since 2 CFR 200.324(c) prohibits it.

Sites and contracts are grouped into Public Assistance projects, each with its FEMA category of work. Ithil classifies each project as small or large against FEMA's threshold for the declaration's fiscal year, and shows which column of the PAPPG documentation tables applies. It fills FEMA's five summary records from that record: force account labor, force account equipment, materials, rented equipment and contract work. Each downloads as a spreadsheet or a PDF, with a list of anything still missing for FEMA.

A damage assessment is an inspection in Ithil. Inspections and work orders are event sourced and hash chained, so the history of who recorded what, and when, is append only. The mechanism is described in an earlier post.

Setting up the record

Four things in Ithil are set up before an incident and read during one: the asset register for owned equipment, insurance policies with their covered locations, pre-positioned contracts with their procurement record, and the damage assessment form the field crews fill in. To see the recovery workflow on a sample disaster, contact the Ithil team or write to contact@ithil.ai.