FEMA Reform Isn’t Law Yet. The PAPPG Still Governs Your Claims.

In May, the FEMA Review Council recommended the most sweeping overhaul of federal disaster assistance since the Stafford Act. We spent a week explaining it, including RAPID, the parametric program meant to replace reimbursement-based Public Assistance.

Five months later, a practical question keeps coming up: what rules apply to the disaster we are working right now?

The answer has not changed. The PAPPG still governs your claims. Agencies that relaxed their documentation because "reimbursement is going away" are taking on the most risk.

Where Reform Actually Stands

The Review Council's report is a set of recommendations, not law. Some changes can be made administratively. The core program changes, including replacing PA with RAPID, consolidating Individual Assistance into FAIR, and changing declaration thresholds, require legislation. The Council itself called for a phased two-to-three-year implementation.

The bipartisan FEMA Act of 2025 (H.R. 4669) is the bill most often named as a vehicle. It takes a different approach from the Council: rather than broadly reducing the federal role, it gives states more flexibility and implementation authority within existing FEMA programs. As of this writing, neither it nor any other reform bill has been enacted.

The most recent FEMA legislation went the other way. The FY27 continuing resolution keeps the existing programs running at FY2026 rates through December 11, with the Disaster Relief Fund available at the rate Stafford Act response and recovery require. That funds the current system. It does not replace it.

What Governs Today

For any disaster declared on or after January 6, 2025, the rulebook is PAPPG Version 5.0. FEMA later issued an amended Version 5.0 reflecting executive orders issued on and after January 20, 2025. It revised several chapters and appendices and removed the independent expert panel cost-estimate review option for projects with a federal share over $5 million. Older disasters stay under the version in effect on their declaration date.

That means everything the PAPPG requires still applies, every time:

• Force account labor tied to a pre-disaster written labor policy, with eligible hours separated from ineligible ones.
• Equipment hours supported by usage records and operator time.
• Contracts procured under federal procurement standards, with the records to prove it.
• Every cost connected to eligible work in a specific category, location, and period.

None of this has been suspended, simplified, or waived while reform is debated.

What Has Actually Changed

Some things did change this year, and none of them made documentation less important.

Transparency became law. Section 313 requires FEMA to publish project-level reimbursement status. Your projects, and how long they sit, are about to be visible to your governing body and the public.

Funding interruptions became real. The spring lapse pushed FEMA into Immediate Needs Funding and paused reimbursement for completed work. Projects with complete documentation were the ones able to move when funding came back.

The state role kept growing. Under current law and under every reform proposal, states carry more of the program management load. States will push documentation expectations down to their subrecipients, not lower them.

Documentation That Works Under Either System

The useful planning insight is that the records PAPPG requires today are the same records any successor program will rely on.

RAPID, as proposed, replaces damage assessment with a parametric trigger and federal closeout with a two-phase audit. But the audit still tests whether the money was spent on eligible response and recovery work. That test runs on the same evidence the PAPPG asks for now: who worked, on what, when, with which equipment, under what authority. A state certifying spending under a block-grant model will need exactly that from its counties. It will just ask for it in its own format.

So the safe bet is not to wait and see. Keep your records to the standard the PAPPG sets today, in a structure organized by operational period and resource, so they can be reported in whatever format the next program asks for. An agency that does that loses nothing if reform passes next year, or if it never does.

The Practical Read

Reform news makes for good conference panels. Reimbursement is still decided by a reviewer reading your Project Worksheet against the PAPPG, one cost at a time.

Until a new law is signed and implemented, plan for the current program, and build documentation that will hold up under the next one too. Those two goals call for the same records, so you can do both now.

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See how NIMS Logic produces PAPPG-aligned cost documentation as a byproduct of running the incident. See how cost recovery works.