At Thomas Howell Ferguson, we are committed to making an impact at every level of government. Our recent success in a FEMA appeal for Central Florida Electric Cooperative (CFEC) is a prime example of how our expertise helps clients navigate complex regulatory challenges and secure the funding they deserve. This victory not only benefits CFEC but also has the potential to shape future FEMA policies on emergency pay eligibility.
With the assistance of the THF Government Consulting Services team, Central Florida Electric Cooperative (CFEC) recently secured a significant win in its FEMA appeal (Appeal #000-UK4RB-00), successfully overturning a long-standing limitation on emergency pay reimbursement. This decision marks a pivotal shift, recognizing that extraordinary costs incurred by essential personnel during disaster response are fully eligible for reimbursement—even if they do not exceed 40 hours per week.
Initially, FEMA’s Determination Memo restricted emergency pay rates to hours worked beyond the standard 40-hour threshold. However, our team successfully demonstrated that these costs should be classified as extraordinary pay. In response to Hurricane Idalia, while many employees were placed on administrative leave, essential personnel were recalled to perform critical emergency operations and received emergency pay under the Cooperative’s labor policy. This policy—developed with our assistance—aligns with FEMA’s compliance criteria, allowing eligible emergency work to qualify for reimbursement, regardless of total hours worked.
This appeal victory carries significant implications. As a FEMA representative noted, “When a decision is made on an appeal that could redefine how FEMA has trained professionals for years to apply a written policy…” This statement underscores the broader impact of our success, potentially setting a new precedent in FEMA’s approach to emergency pay eligibility.
Beyond this individual case, the ruling strengthens the ability of cooperatives and other organizations to properly compensate essential employees for their critical contributions during disasters—while securing full reimbursement for these extraordinary costs. It’s a testament to the power of persistence, specialization, and advocacy in shaping policy for the better.
State Impacts – Driving Results Across Florida
From initial assessments to long-term recovery planning, our team has consistently been at the forefront of statewide initiatives that drive positive change. During this past hurricane season, the Government Consulting Services department sprang into action, deploying its entire team to assist with disaster preparation and recovery for Hurricanes Helene and Milton. Our rapid response efforts helped communities and organizations across Florida begin their journey to recovery. With 30 years of hands-on experience, we leveraged our experience to navigate emergency management protocols, delivering a response that maximized reimbursements and minimized disallowances.
While disaster recovery is a major part of the Government Consulting Services team’s efforts, it is just one facet of our broader impact at the state level. One of our significant achievements is securing multiple contracts under the Florida Department of Management Services State Term Contract. These milestones enhance our ability to support communities statewide by providing critical financial, operational, and strategic services.
Our work with state agencies such as the Florida Division of Emergency Management, Florida Commerce, the Florida Department of Education, and the Florida Department of Military Affairs reflects the dedication of our team. These collaborations position us to take on even larger challenges and expand our contributions across Florida.
Federal Impacts – Looking Toward the Future
At Thomas Howell Ferguson, we believe in making things happen. Over the years, we have built a strong foundation in local and state circles, helping communities recover from disasters, improve financial operations, and navigate government processes. Now, we are taking the next step by expanding into the federal market.
A key milestone in this journey is securing our federal GSA contract—an achievement that positions us to compete at a higher level and offer our experience on a broader scale. With extensive experience in financial performance audits, client accounting services, project management, disaster management, disaster deployments, and integrity monitoring, our team is well-equipped to support federal agencies with the same level of excellence we have delivered at the state and local levels. Currently, we are positioned under GSA categories 541211, 541219, 541611, and OLM, and we are actively working to expand our footprint.
Breaking into the federal market requires more than just skills—it demands strategic partnerships and strong relationships. That’s why we are focused on forging meaningful collaborations with federal entities who share our commitment to excellence and innovation. By working together, we can drive impactful solutions that benefit agencies and the communities they serve.
As we move forward, our goal is clear: to establish Thomas Howell Ferguson as a trusted leader in the federal space, just as we have done at the state and local levels. With our proven track record and relentless drive to succeed, we are ready to make it happen. Contact our dedicated team here to learn more on our government consulting services.
