On August 31, 2026, FEMA announced a pilot program under Indiana’s storm and flood disaster declaration (FEMA-4933-DR) that changes how Public Assistance funding is delivered. For qualifying projects, funding is approved in advance, based on professionally prepared cost estimates, rather than reimbursed after work is completed and documented.

The pilot changes when funding arrives. It does not change the rules that govern spending it.

Drawing on our analysis of the announcement, its statutory foundation, and the broader federal reform agenda, this resource explains what the shift means for state and local applicants, and how prepared organizations can position themselves to benefit.

What this resource covers:

• The legal foundation, why Section 428 of the Stafford Act makes the pilot durable rather than improvised
• Staying power: how the FEMA Review Council’s recommendations, pending federal legislation, and live agency practice now converge on the same delivery model
• Opportunities for applicants, faster funding, protection from cost escalation, and retained savings for eligible uses
• Risks to price in, why the approved estimate becomes the award, and cost overruns become the applicant’s responsibility
• What the pilot does not change: federal purchasing, documentation, closeout, and audit
  requirements under 2 CFR Part 200 remain fully in effect
• From risk to readiness, the capabilities that position applicants to benefit before the model reaches their jurisdiction

The advance-payment model rewards preparation. Applicants with disciplined scoping, defensible estimates, and structured documentation are positioned to benefit. Applicants without them absorb new risk.