Follow Us: 

786-235-8534 | EMinfo@cdrmaguire.com

Emergency protective measures conducted before, during, and after an event are eligible under Public Assistance as Category B expenses if the measures eliminate or lesson immediate threats to lives, public health, or safety.
It goes without saying that in the current situation, the health and security of our employees, their families, and our clients and partners is of paramount importance.  We are here to support and work with you during this challenging time.  Did you know your agency may be eligible for up to 75% reimbursement from FEMA for additional costs you have incurred as a result of the COVID-19 National Emergency Declaration?

 

CDR Maguire is an emergency management consulting firm that helps clients prepare for and recover from disasters. During this unprecedented crisis, state and local governments, and various government agencies must prepare.  Preparations include identifying and documenting all eligible costs related to emergency measures taken as a result of the COVID-19 Declaration, to maximize and speed up the federal reimbursement process, and help you recoup the additional costs incurred as a result.

 

CDR Maguire provides organizations and agencies with subject matter experts, personnel staffing, procedures, management tools, finance tools and other capabilities necessary to support you during emergency operations.

 

CDR Maguire’s services include but are not limited to:
Providing personnel to support your Finance Department in properly identifying and documenting all eligible costs related to emergency measures taken.

Providing support personnel to establish project cost accounting framework and modifications to your financial accounting systems to be able to track these costs in your financial ERP.

Providing financial analysts to assist your Finance Department in budgeting estimated burn rates for week-long and month-long deployments of emergency and essential staff.

Providing support staff to research other disaster grant funding sources outside of FEMA’s Public Assistance that could assist agencies for the economic consequence of this unprecedented crisis.

Contact us at eminfo@cdrmaguire.com for reimbursement and application assistance.

CATEGORY B ELIGIBILITY INFORMATION

EXAMPLES OF ELIGIBLE ACTIVITIES

Transporting and pre-positioning equipment and other resources for response

Costs related to pre-positioning resources, specifically for the declared incident are eligible if the resources are used in the performance of eligible Emergency Work.

Emergency Operation Center (EOC) related costs

Increased utility costs

Costs to lease a facility

Meal costs

Supply costs

Sanitization costs

Dissemination of information to the public to provide warnings and guidance about health and safety hazards using various strategies, such as

Text messaging

Flyers

Public service announcements

Newspaper campaigns

Emergency access

Supplies and commodities

Medical care and transport

Evacuation and sheltering, including that provided by another State or Tribal government

Childcare**

Safety inspections

Security, such as barricades, fencing, or law enforcement

Use or lease of temporary generators for facilities that provide essential community services

** Disaster-specific guidance for childcare eligibility and costs from FEMA has been requested but awaiting response.

EXAMPLES OF ELIGIBLE COSTS

EOC costs

Laptop computers for remote work

Force Account Labor

Straight Time (could be eligible depending on declaration)

Comp time

Overtime

Fringe Benefits

Force Account Equipment

Rented or purchased equipment

Supplies from stock

EXAMPLES OF INELIGIBLE COSTS

For non-essential employees, the following is typically non-eligible

Straight Time (Regular Time)

Comp time

Overtime

Fringe Benefits

Provision of food for general public

Feeding programs operated by schools may be eligible under another federal program

School make-up days, including contracted costs for bus service for make-up days

Costs that are Eligible Under Other Federal Awards – FEMA is legally prohibited from duplicating benefits from other sources, such as from insurance or other federal awards. Public Assistance is funding of last resort. If the Applicant receives funding from another source for the same work that FEMA funded, FEMA reduces the eligible cost or de-obligates funding to prevent a duplication of benefits.
Loss of Revenue – FEMA cannot provide PA funding for revenue lost due to the event. Examples include:
State opened a toll road for evacuation and did not charge a toll

States waive the normal fee for ferry service to encourage alternate transportation after an Incident

Events are canceled as a result of an entity using a venue for incident-related activities, such as sheltering

Hospitals release non-critical patients to make room for survivors

Hospitals sustain damage that reduces pre-existing capacity

COMMON ISSUES WITH CATEGORY B REIMBURSEMENT

DOCUMENTATION

In past events, applicants have had difficulties in creating, maintaining, and providing all required documentation for Category B reimbursement. Documentation requirements vary between activities. The below three conditions are typical requirements for Category B expenses:
Tie the cost to an eligible activity

Properly document the activity (who, what, when, where, how much) (214s/Daily Reports)

Legally responsible

POLICIES

The existence of certain policies is a requirement before an event. Such policies include:
Payment Policy

Procurement Policy

Applicants must abide by these policies. The payment policy cannot state that overtime is allowed only when there is a Federal declaration.

PAYROLL TIME KEEPING

For any Category B expense, applicants must tie all costs to an eligible activity. This applies to the time claimed for staff performing an eligible Category B activity. Applicants must provide an activity log (214/Daily), comments, etc. that illustrates what employees were doing during the time claimed by the applicant. Those activity logs or comments need to show that the employees were performing eligible Category B activities, i.e. working in EOC responding, operating a generator, etc.

PROCUREMENT

Non-compliance with federal procurement requirements remains a leading cause, nationwide, of deobligations and eligibility issues related to costs. Limited circumstances exist under which there are exceptions to noncompetitive procurement requirements. Relevant to this event is the exception that exists due to emergency or exigent circumstances. If circumstances are of such severity and magnitude that they prevent the undertaking of a procurement action, then strict adherence to these regulations is not required so long as the emergency or exigent circumstances exist. If the governmental entity is not going to use a competitive process to purchase goods and services, they need to document the reason, and for emergency and exigency circumstances, the date those circumstances started and ended.

FORCE ACCOUNT LABOR

DOCUMENTATION

Name of the Employee

Job Title and Function

Type of Employee (i.e., full-time exempt, full-time non-exempt, part-time, temporary, prisoner, etc.)

Days and Hours worked and Pay rate(s)

Days and Hours Worked preceding the event, starting the pay period;

Days and Hours Worked during the event; and

Days and Hours Worked after the event, ending the pay period.

Fringe Rate(s) for that Position

Description of Work Performed

Comments in Timesheet

Accompanying Activity Log

Daily Report

FOR THE PROJECT

Entity’s Pay Policy

Fringe Benefit Calculations

Proof of Payment

Payroll Register

*Additional Questions and Documentation Requests May be Asked to Clarify Above Documentation.

FORCE ACCOUNT EQUIPMENT (OWNED BY APPLICANT)

FOR EACH PIECE OF EQUIPMENT

Type of Equipment and Attachments used

Include year, make, and model of equipment

Size/capacity (e.g., horsepower, wattage)

Locations Equipment Used

Days and Hours Used

Usage Logs

Operator Name

Schedule of rates, including rate components

RENTED OR PURCHASED EQUIPMENT

FOR EACH PIECE OF EQUIPMENT

Rental or lease agreements

Invoices from vendor

Days and Hours Used

Usage Logs

Proof of Payment to Vendor

Canceled Check, both sides of check

FOR THE PROJECT

Procurement Policy

Contract Procuring the Equipment

Relevant Solicitation Documentation

Bid Tabulations

Solicitation

Proposals

SUPPLIES FROM STOCK

Historical cost records

Receipts, Account Transactions, etc.

Inventory records

Listing of:

Type of supplies

Quantities used

Support documentation such as Daily Logs recording what item was used for, where it was moved to, etc.

COMMON EOC COSTS

MEALS

Sign-In Sheets

If provided by a vendor:

Contract Procuring the Equipment

Relevant Solicitation Documentation

Solicitation

Proposals

Bid Tabulations

LEASING A BUILDING, I.E. FOR OVERFLOW OF EOC OPERATIONS

If provided by a vendor:

Contract Procuring the space

Relevant Solicitation Documentation

Solicitation

Proposals

Bid Tabulations

Invoices from Vendor

Proof of Payment

I.e. Canceled check, both sides of check

PURCHASED SUPPLIES

If provided by a vendor

Contract Procuring supplies

Relevant Solicitation Documentation

Solicitation

Proposals

Bid Tabulations

Invoices or Purchase Orders

Showing quantities of supplies

With unit amount

Proof of Payment

I.e. Canceled check, both sides of check

OTHER FEDERAL AID

In addition to FEMA’s Public Assistance Program, there have been other federal programs authorized to provide assistance to states to address the COVID-19 outbreak. These non-FEMA sources, include $8.8 billion to the CDC for preparedness and response activities. A Notice of Funding Availability is expected soon pursuant to this appropriation, and the Department of Health (DOH) will develop a spend plan to outline costs eligible for funding through the CDC. Typically, when this type of funding is allocated, it is generally with the focus of Public Health, and for issues such as, Epidemiology, surveillance, monitoring travelers, laboratory capacity, testing surge, case identification, lab equipment supplies and shipping, etc.- essentially,  for ramped up functions of the Public Health Departments so they can deal with the surge. FEMA’s duplication of benefits guidance requires that eligible activities funded through other federal sources should be claimed through those other programs, so long as funding is available.

 

There is also the Emergency Management Preparedness and Assistance that is available for certain costs. Costs that can be charged to EMPA for COVID-19 response are limited to the salaries charged to that grant. No other costs are to be charged to EMPA, i.e. supplies, equipment, or overtime.

EMERGENCY PROTECTIVE MEASURES CONDUCTED BY PRIVATE NON-PROFIT ORGANIZATIONS

For PNPs, eligible emergency protective measures are generally limited to activities associated with preventing damage to an eligible facility and its contents.

 

Emergency services are usually the responsibility of State, Territorial, Tribal, or local governments. Therefore, PNPs are generally not legally responsible for those services and FEMA does not provide PA funding to PNPs for the costs associated with providing those services. When a PNP provides emergency services at the request of, and certified by, the legally responsible government entity, FEMA provides PA funding through that government entity as the eligible applicant. These services include:
Fire and rescue activities

Animal control

Emergency ambulance service for evacuation

211 call services, if tracked and related to eligible work

Other similarly urgent governmental services

For PNPs, operating costs are generally not eligible even if the services are emergency services, unless the PNP performs an emergency service at the request of and certified by the legally responsible government entity. In such case, FEMA provides PA funding through that government entity as the eligible applicant.

 

The following are eligible under limited circumstances based on specific criteria described in each of the referenced sections:
Expenses related to operating a facility or providing an emergency service

The services are specifically related to eligible emergency actions to save lives, or protect public health and safety, or improved property

Triage and medically necessary tests and diagnosis

Treatment, stabilization, and monitoring

First-aid assessment and provision of first aid

A one-time 30-day supply of prescriptions for acute conditions or to replace maintenance prescriptions

Vaccinations for survivors and emergency workers to prevent outbreaks of infectious and communicable diseases

Durable medical equipment

Consumable medical supplies

Temporary facilities, such as tents or portable buildings for treatment of survivors

Meals are eligible PA expenses if:

Meals are required based on a labor policy or written agreement

Conditions constitute a level of severity that requires employees to work abnormal, extended work hours without a reasonable amount of time to provide for their own meals;

Food or water is not reasonably available for employees to purchase

The costs are for a limited period based on the exigency of the circumstances; and

The Applicant tracks and documents the additional costs

Temporary relocation of essential services, including safe rooms for schools

HAVE QUESTIONS OR FOR UPDATES?

FILL OUT THE FORM, WE ARE HERE TO HELP!

[]
1 Step 1
keyboard_arrow_leftPrevious
Nextkeyboard_arrow_right
FormCraft - WordPress form builder