Public Assistance Eligibility Overview

For a project to receive FEMA Public Assistance funding, it must meet four core eligibility requirements: Applicant, Facility, Work, and Cost. FEMA evaluates each of these components to ensure the applicant is eligible, the facility is eligible, the work performed is tied to the disaster, and the associated costs are reasonable and properly documented. All four elements must be in place before FEMA can approve funding. The following overview explains what each requirement means and how it applies to local governments, utilities, and private nonprofits seeking assistance.

Applicant Eligibility

To qualify for FEMA Public Assistance (PA), an applicant must be an organization responsible for providing essential public or community services. FEMA reviews each potential applicant to verify that the entity is eligible under the PA program, has legal responsibility for the damaged facility, and performs services that benefit the general public. Eligible applicants typically include:

Counties and local jurisdictions within those counties that are included in the federal disaster declaration.
State government agencies that assisted in the declared counties.
Private non-profit (PNP) organizations that own or operate facilities that provide certain services otherwise performed by a government agency.

An additional eligible applicant includes Houses of Worship that offer:

Critical-Services: Houses of worship that operate facilities offering critical services, such as utilities, water/wastewater, private schools, or other essential public-service functions, may apply directly for PA grants for both emergency and permanent work.
Providing Essential, Non-critical Services: For other houses of worship that provide community services, social support, homeless shelters, or similar functions, PA funding for permanent work requires first applying for a disaster loan from U.S. Small Business Administration (SBA). FEMA may provide funds to cover what SBA or insurance does not.

Documentation Required for PNP and House of Worship Applicants

Private nonprofit applicants must submit documentation to demonstrate eligibility, including:

Proof of nonprofit status
Ownership or legal responsibility for the damaged facility
Evidence that the facility provides eligible public or essential services

For houses of worship offering essential non-critical services:

Proof of SBA loan application, and
Either an SBA denial or documentation showing loan funds are insufficient to cover eligible repairs.

Facility Eligibility

Even if the applicant is eligible, FEMA must also confirm that the facility itself meets certain requirements. The applicant must own or be legally responsible for the facility at the time of the disaster, and the facility must be located within the counties designated in the federal disaster declaration. In addition, the facility must be used for an eligible purpose, meaning it supports governmental functions or provides essential community services.

Examples include public buildings, water and wastewater infrastructure, emergency service facilities, utilities, and parks or recreational areas. For private nonprofits, the facility must be open to the general public and used primarily for eligible services. Houses of worship, for example, must show that their facility is regularly used by the community and not limited to members only. Most importantly, the damage to the facility must be a direct result of the declared disaster event.

Work Eligibility

FEMA also evaluates whether the work being claimed is eligible for reimbursement. Eligible work must be required as a direct result of the disaster and must fall into one of FEMA’s approved categories.

Emergency work includes debris removal and actions taken to protect lives, property, and public health immediately following the disaster.
Permanent work involves restoring damaged facilities to pre-disaster condition, such as repairing roads, bridges, utilities, buildings, and parks.

All work must be necessary, properly documented, and completed in compliance with federal requirements—including environmental and historic preservation laws. FEMA may also approve mitigation measures as part of permanent repairs if the improvements reduce the likelihood of similar damage in future disasters.

Cost Eligibility

For a project to be eligible for FEMA Public Assistance, costs must be reasonable, necessary, and directly tied to eligible work performed because of the disaster. Applicants must maintain thorough documentation, including contracts, timesheets, procurement records, invoices, and equipment logs, to demonstrate how costs were incurred.

All costs must comply with federal procurement and financial regulations, including the standards outlined in the Public Assistance Program and Policy Guide (PAPPG) and the Code of Federal Regulations, Title 2, Part 200.

FEMA Public Assistance is a cost-share program, meaning expenses are split between FEMA, the State of Tennessee, and the applicant. In Tennessee, the standard cost share is 75% federal, 12.5% state, and 12.5% applicant. Maintaining clear records helps ensure applicants receive the maximum allowable reimbursement and remain compliant through project closeout.

Understanding the Four Components

FEMA reviews eligibility in a specific order: first confirming the applicant, then the facility, followed by the work, and finally the costs. If any one of these components does not meet FEMA’s requirements, the project may be deemed ineligible. By understanding these four pillars of eligibility, applicants can better prepare documentation, avoid delays, and ensure they meet the requirements for securing Public Assistance funding.