How to Write an RFP for FEMA Mitigation Grant Support

In BRIC’s fiscal 2023 round, the last FEMA selected before it announced the program’s end, communities asked for $5.4 billion against $1 billion available. FEMA selected $990.6 million in projects, and by January 2026 it had obligated $38.7 million of that, 3.9% (Congressional Research Service).

FEMA mitigation grant support is consulting that turns a local project into a fundable HMGP, Flood Mitigation Assistance or BRIC subapplication: the benefit-cost analysis, scope, budget, schedule and environmental information reviewers check. You need it when a funding window is open or expected. The RFP succeeds when it buys a cost-effectiveness screen before a full application.

Selection is where the hard work starts, so scope what comes after it.

What this work should deliver

The outcome is a subapplication that clears eligibility and completeness review on the first pass, ranks well on your state’s list and holds up through FEMA’s requests for information and environmental review after selection. For a phased project, it includes the Phase I work FEMA needs before it releases construction money.

Who this is for: counties, cities, towns, special districts and tribal governments. Local governments apply as subapplicants through their state; Annapolis applied for its City Dock grants through the Maryland Department of Emergency Management (FEMA). Nonprofits can’t apply directly for BRIC (FEMA fact sheet), and under HMGP a private nonprofit qualifies as a subapplicant only if it owns or operates an eligible private nonprofit facility (44 CFR 206.434).

It is the wrong purchase when you don’t yet know which project to pursue; a resilience funding strategy ranks the candidates first. It also can’t rescue a lapsed plan. A local government needs a FEMA-approved hazard mitigation plan, revised within five years, to stay eligible for project grants (44 CFR 201.6).

Where the programs stand in September 2026

• HMGP. It opens only after a major disaster declaration, statewide, at up to 15% of the first $2 billion of estimated disaster aid (20% with an enhanced state plan) and a 75% federal share (44 CFR 206.432). States must submit applications within 15 months of the declaration, extendable by up to 240 days (44 CFR 206.436). Maryland’s request for a declaration after the May 2025 Western Maryland flooding was denied, and both appeals failed (Department of Legislative Services).
• FMA. The amended fiscal 2024 round offered up to $600 million, with applications due August 6, 2026 (FEMA). The fiscal 2026 Swift Current opportunity, $600 million announced July 14, 2026, opens only for states with a flood-related declaration between June 1, 2025 and May 31, 2027, and it dropped project scoping as an eligible activity (FEMA).
• BRIC. FEMA announced BRIC’s end on April 4, 2025; a federal court ruled the termination unlawful on December 11, 2025 and ordered FEMA to act on March 6, 2026 (CRS, above). The $1 billion round for fiscal 2024 and 2025 ran from March 25 to July 23, 2026, and FEMA was still reviewing submissions in September (FEMA).

Write the RFP to survive the next change. Ask bidders for program status as of the proposal date, and pay for products that carry across programs: a benefit-cost analysis and a design that would serve HMGP, FMA or BRIC. Our flooding and coastal resilience hub and flood risk management primer cover the project side.

Rules and standards to cite

• Eligibility. 44 CFR 206.434(c) requires HMGP projects to conform to the state and local mitigation plans, solve a problem on their own or as a functional part of a solution, and be cost-effective; projects that only identify or analyze hazards are ineligible. 44 CFR 206.436 lists what each application must contain, including alternatives considered and environmental information.
• Cost-effectiveness. FEMA requires FEMA-approved methods such as its BCA Toolkit, treats a benefit-cost ratio of 1.0 or higher as cost-effective and accepts a narrative method for projects under $1 million (FEMA). Projects not awarded by April 8, 2025 must use a 7% discount rate, up from 3.1%, and the Toolkit remains version 6.0 with no new release scheduled (FEMA BCA notes).
• Benefits you can claim. FEMA’s HMA Guide (Version 2.1, effective January 20, 2025) offers pre-calculated benefits for acquisitions, elevations and mitigation reconstruction in the special flood hazard area, which spare those projects a full analysis. It allows social benefits for projects that keep residents from being displaced, and ecosystem service benefits for projects that restore natural land cover, which helps nature-based projects such as living shorelines. Pre-calculated benefits can’t be combined with a Toolkit analysis.
• Pre-award and management costs. Pre-award costs to develop a subapplication, such as the analysis and design specifications, are allowable if FEMA approves them at award and they appear as separate budget lines; for HMGP they must follow the declaration date. Under HMGP, subrecipient management costs are capped at 5% of the award, and pre-award costs designated as management costs count against that cap. Pre-award costs are allowable only to the extent they would have been after award (HMA Guide, Parts 3 and 13), so if you hope to recover the consultant’s fee, procure the consultant under 2 CFR 200.317-327 from the start.
• Program terms. The 2024-25 BRIC round required at least a conceptual design, barred phased projects and set a 75% federal share (BRIC NOFO). The fiscal 2024 FMA round paid up to 100% for severe repetitive loss and 90% for repetitive loss properties under FMA’s definitions and capped localized flood risk reduction projects at $50 million (FMA NOFO).

The BRIC scoring table is the clearest statement of what FEMA values. Readiness earned 5 points for at least 30% design, 15 for more than 30% and 30 for 90% or more, out of 100; a never-selected subapplicant earned 15 and code adoption and enforcement up to 20. A consultant can move the design and narrative scores, and nobody can move your building code grade in one application cycle.

Sample scope of work

Adapt the bracketed items. Task 1 is the base; make the rest options you exercise in writing.

1. Eligibility and benefit-cost screen. Stowe, Vermont structured its 2025 contract this way (Town of Stowe).

The Consultant shall confirm the project’s eligibility under [HMGP, FMA or BRIC] and its conformance with the [County] hazard mitigation plan, then prepare a screening benefit-cost analysis using FEMA-approved methods and the discount rate in effect on the date of analysis. The Consultant shall document every input and its source and recommend in writing whether to proceed. No further task shall begin without written notice from the [County].

2. Alternatives, scope, cost and schedule. Reviewers look for alternatives considered, so require them.

The Consultant shall document at least [three] alternatives, including no action, and prepare a scope of work, a cost estimate with its basis, design level and contingency stated, and a schedule with milestones FEMA can track.

3. Final benefit-cost analysis. Keep the model and the data together, so the analysis can be defended in a request for information.

The Consultant shall complete the benefit-cost analysis in FEMA’s BCA Toolkit or another FEMA-approved method, claim social or ecosystem service benefits only where the HMA Guide allows them for the project type, and deliver the model files with every hazard, damage and cost input and its source.

4. Environmental and historic preservation information.

The Consultant shall compile the environmental and historic preservation information FEMA requires, including floodplain and wetland findings under 44 CFR Part 9, and identify the permits and consultations the project will need and their expected durations.

5. Subapplication and state coordination. Your deadline is the state’s, which the BRIC fact sheet tells subapplicants to confirm with their state agency.

The Consultant shall prepare the complete subapplication for submission by the [County] through [the State], itemize any pre-award costs as separate budget lines, and meet the State’s deadline of [date].

6. Requests for information and post-selection support.

The Consultant shall answer State and FEMA requests for information within [10] business days and, if the project is selected, support [Phase I deliverables, environmental review and award negotiation] through obligation of funds.

7. Grant management (optional). Price quarterly reporting, amendments and closeout separately, or leave them to your staff.

Deliverables to require

• Eligibility memo and screening benefit-cost analysis, with an input log and a go or no-go recommendation.
• Alternatives analysis, including no action.
• Scope of work, cost estimate with basis and contingency, and schedule.
• Final benefit-cost model files and all supporting data.
• Environmental and historic preservation package, with permits and consultations listed.
• A maintenance plan and budget, since HMGP projects must have manageable future maintenance (44 CFR 206.434).
• Complete subapplication, with pre-award costs itemized.
• A log of every request for information and the response.
• All files in editable form, owned by you.

How to evaluate proposals

The Delaware River Basin Commission’s 2025 RFP for benefit-cost reviews scored qualifications 30, proposal 20, cost 20 and schedule 30, and opened sealed cost proposals only after scoring the technical ones (DRBC). Skip qualification tests built on past benefit-cost ratios; a ratio describes a project, and rewarding high ones rewards optimism.

With federal money, 2 CFR 200.320 allows price-free qualifications-based selection only for architectural and engineering services, and not for other services an engineering firm offers. Stowe hired an engineering firm through its state transportation agency’s prequalified pool; application writing bought on its own needs price competition.

Then settle the conflict question. 2 CFR 200.319 excludes contractors that draft specifications, requirements or statements of work from competing on those procurements. Grimes County, Texas bought pre-award and post-award services, through construction, in one qualifications-based solicitation (Grimes County); Stowe did the same but made design an option it could decline.

Timeline

Phased HMGP projects add a gate. Cambridge, Maryland received $1.7 million for Phase I design and permitting of its Choptank River flood project, with $16 million reserved for construction that follows only after FEMA approves the final design, benefit-cost analysis and environmental plan (City of Cambridge). Our Dorchester County profile follows that project.

Budget and cost drivers

Stowe’s January 2025 award priced the benefit-cost analysis at $20,064 and the HMGP application at $16,059, with project definition ($216,208) and design ($338,365) as later phases if the grant came through. The consultant estimated about 3,500 hours across all four phases, and the town proposed $35,000 for the first two.

FEMA also pays for studies that produce applications. In June 2024 Annapolis announced FEMA grants of $290,499 for Eastport flood mitigation design, including an impact study, analysis of mitigation activities, a cost-benefit analysis and tidal and weather monitors, and $245,000 for a watershed study and concept plans in South Southwood (City of Annapolis). The fiscal 2024 FMA round capped project scoping at $900,000 in federal share, a ceiling rather than a norm.

What moves the price:

• Hydrologic and hydraulic modeling. Stormwater and flood control benefits rest on it; Grimes County’s scope asked for water surface reduction analyses for each candidate drainage project.
• Structure data. Acquisitions and elevations need building-level values and flood depths, less if pre-calculated benefits apply.
• Design level. BRIC points rose with design maturity, and design is where the hours are.
• Environmental complexity. Historic districts and wetlands add documentation; Annapolis needed an environmental assessment and a draft programmatic agreement for City Dock (FEMA).
• Number of subapplications. Each needs its own analysis, scope and budget.
• Post-selection work. Requests for information and Phase I deliverables can outlast the application.

Red flags in proposals

• A benefit-cost ratio quoted before the consultant has seen your data.
• Old program terms: a 3.1% discount rate, BRIC planning or scoping money, or phased BRIC projects.
• Analyses that stack pre-calculated benefits on a Toolkit analysis, or claim social or ecosystem service benefits the HMA Guide doesn’t allow for the project type.
• Fees set as a percentage of the award, which rewards a bigger request over a fundable one.
• Pre-award costs not broken out as separate lines, or HMGP costs dated before the declaration.
• No plan or budget for requests for information and post-selection work.
• A firm that writes the scope and intends to bid the design without saying so.

How we’d approach it

We would spend the first dollars on the benefit-cost screen and the next on design, since BRIC’s 2024-25 scoring gave six times the points to a 90% design as to a 30% one. The inputs matter as much as the math: in the Annapolis Maritime Resilience Initiative, where we were project manager and engagement partner for Phase I, each of the 10 priority sites left with a conceptual design and a planning-level cost estimate. Through Council Fire Labs we built Resilient & Ready with the Resilience Authority to rank projects like those and match them to funding that fits. Our Maryland county profiles track where FEMA’s mitigation money has gone, and our resilience funding hub collects related guides.