I've just looked through the awards section of the QRP ARCI Web site. Although FM is not specifically mentioned in the organization's definition of QRP, it is included on the awards application. The same is true for digital modes.

The awards application is available on the site in PDF form here: http://www.qrparci.org/images/stories/GCR_Form.pdf

I hope this is helpful.

73,

Tim - N3TL