GLOBAL PANDEMIC. LOCAL IMPACT.

CATEGORY B ELIGIBILITY INFORMATION

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

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:

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:

POLICIES

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

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.

DOCUMENTATION

FOR THE PROJECT

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

FOR EACH PIECE OF EQUIPMENT

FOR EACH PIECE OF EQUIPMENT

FOR THE PROJECT

MEALS

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

PURCHASED SUPPLIES

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.

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:

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: