FEMA aid for local governments’ COVID-19 response: Learn and follow the ‘rules of the road’ for reimbursement

For communities across America grappling with the challenge of managing COVID-19, one rare piece of encouraging news is that they’ll be able to get at least 75 percent reimbursement for eligible emergency protective measures and pandemic response costs by the Federal Emergency Management Agency (FEMA) under FEMA’s Public Assistance (PA) program.

What’s critical for municipalities, however, is making the right decisions now and keeping the proper records.

As part of the CARES Act, Congress and President Trump have approved $45 billion for the Disaster Relief Fund, available to support the needs of state, local, tribal, and territorial governments at a 75 percent federal cost share.

This funding can cover a wide range of activities conducted after January 20, 2020, including medical response, purchase of personal protective equipment, National Guard deployment support, coordination of logistics, safety measures and community services nationwide.

As reported by AC&C on March 20, 86 percent of local leaders feel very or somewhat prepared for responding to COVID-19. Challenges local leaders described as their key focus areas—including planning and preparation, controlling risk, and cleaning and disinfecting public areas—are, fortuitously, all emergency protective measures for which 75 percent FEMA PA reimbursement will be available.

If there’s just one piece of advice city, county, and municipal leaders need to hear about ensuring they get the FEMA funding they’re entitled to, it’s this: Document. Document. Document. Keeping thorough, specific records of every dollar spent at the local level for preparing for and responding to COVID-19 will be critical, such as:

• Purchase orders for materials and proof of payment.
• Payroll records detailing how municipal employees spent regular, overtime, and detail shifts working on COVID-19 issues and their duties and tasks accomplished.
• Record of equipment used in response, including police cruisers on directed patrols, public works vehicles setting up barricades and ambulances on COVID-19 related calls.
• Time-stamped smartphone photographs documenting exactly what your police, fire, public works, health-department, senior-center, and other agency staff were doing where, when, and why to manage COVID-19.
• Preserved e-mail and text-message trails documenting all requests for COVID-19 responses that your local agencies fulfilled.
• Records of your primary insurance claim submittals and insurance payments.
• Records of donations of equipment, meals, labor received which can be applied as an offset toward your 25% cost share.

Many counties, cities, towns, and other local governments that have been through natural disasters since 2016 already have first-hand experience with FEMA’s new PA Delivery Model, including the Grants Portal System.  This model and system is intended to expedite funding and improve transparency.  However, it can be daunting if you have never been through it before.

If you don’t know what information FEMA will need and how they want it recorded and submitted through the Grants Portal, make sure you learn and master that information as soon as possible—-or you risk piling up painful budget deficits because of rejected costs or “de-obligations” by FEMA. We strongly encourage you to educate yourself on FEMA Public Assistance by taking FEMA Independent Study Courses on recovery (i.e. IS-1000).

Also, be sure to effectively manage costs to ensure you receive the most funding in the shortest amount of time.  We manage our clients’ expenses on disaster recovery projects by separating the expenses that are straightforward and easy for FEMA to approve from other expenses that may not be addressed clearly in FEMA policy.  This allows us to get funding into our clients’ hands as quickly as possible while addressing more nuanced policy positions in coordination with State Emergency Management Officials and FEMA.

We have never had a nationwide natural disaster nor one that has expanded with time, so even FEMA’s capabilities are being tested. On April 9, 2020, FEMA had 2,800 employees supporting COVID-19 pandemic response out of a total 20,550 agency employees ready to respond to other emergencies. FEMA puts out, almost daily, volumes of COVID-19 related policy documents, guidance, FAQs, and rumor-control documents. A smart practice is to designate a responsible officer in your emergency management team to monitor and review all this information and synthesize it into actionable guidance for your department managers and fiscal staff. We are now using secure websites and file sharing platforms to store records for our clients enabling the emergency management, finance and executive team to work with us remotely, which is also unprecedented.

Remember FEMA is a “funder of last resort” for local governments.  It is critical to exhaust all available funding from your insurance provider, as well as available funding from other federal agencies, such as those under the Department of Health and Human Services before applying for FEMA assistance.

COVID-19 is a uniquely challenging disaster in terms of its costs and national scale– an unprecedented situation in which every state, territory, tribe, county, and municipality is experiencing a Presidentially declared disaster, all at the same time. Local governments need to plan for this to be a long-duration, high-impact event in which response and recovery will overlap significantly.

FEMA is a lifesaving partner in ensuring local governments get the emergency resources they need to manage the COVID-19 crisis while also providing critical financial assistance to mitigate losses.  While FEMA cannot make your community financially whole to your pre-disaster conditions, they will help address eligible post disaster expenses. To make that partnership work, local government leaders must arm themselves with the information and guidance to ensure they’re making the right moves and collecting the right data—the right way. The silver lining to this unprecedented event is local, county and state governments will be better prepared and more resilient for addressing future natural disasters by navigating through this COVID-19 pandemic.

Wayne Cobleigh is the vice president of client services at GZA GeoEnvironmental and Jeff Stevens is the vice president of emergency managment at iParametrics. Both have extensive experience advising state, county and municipal clients on natural hazard mitigation, emergency management, community resiliency and technical assistance on securing FEMA Public Assistance and disaster recovery funding. They’re currently working with multiple local governments on COVID-19 FEMA PA Contract Administration.