Understanding FEMA’s Public Assistance Program During the COVID-19 Pandemic

Through the Disaster Relief Fund (DRF) $45 billion is currently available to respond to the COVID-19 Pandemic. Currently, eligible recipients can apply for reimbursement for costs associated with Emergency Protective Measures, defined as Category B Work per FEMA’s Public Assistance Program policy. The FEMA Public Assistance Program is one of the primary processes to help applicants (subrecipients) at the local level obtain reimbursement for costs associated with COVID-19 response. Once a federal disaster declaration is made by the President, FEMA begins coordinating with the states on implementing the Public Assistance Program to ensure that local applicants (subrecipients) can obtain funding. If the disaster is ongoing, as is the case with the COVID-19 Pandemic, the Public Assistance Program provides reimbursements on a rolling basis. Under the Public Assistance Program, the recipients are defined as the state governments, while subrecipients are defined as an eligible entity such as a city, county, or eligible non-profit.

Click here for FEMA’s COVID-19 Pandemic: Public Assistance Simplified Application

Click here for FAQs related to the Public Assistance Program and Guidance – including Immediate Needs Funding (INF), which helps expedite the funds distribution process.

Click here for the Federal Disaster Assistance Code of Regulations (44 CFR Part 206) – for additional reference.

To begin the application process for FEMA Public Assistance funding, eligible subrecipients first view a virtual briefing and create an account through FEMA’s PA Grants Portal, then submit a Request for Public Assistance form (RPA). They then begin the process of development and submittal of the necessary Project Worksheets and back-up documentation (click here to view project worksheets). Both FEMA and the respective state reviews the subrecipient’s submitted documents, and sign the final Project Worksheet, which then goes through a final review and approval process. FEMA and the state work closely with the subrecipient to develop the Project Worksheets and ensure that funding is being used correctly, and that subrecipients receive the financial assistance for which they are eligible.

Steps for Receiving FEMA Public Assistance Funding

Timeline for Receiving FEMA Immediate Needs Funding through the Public Assistance Program

Responsibilities of FEMA, Recipients, and Subrecipients – Public Assistance Program

In the Public Assistance (PA) program, FEMA, the Recipient (State), and the Subrecipient (Applicants: city, county, local public entity, eligible nonprofit) each have a responsibility with respect to how the PA program is implemented and coordinate together to deliver the program in the affected communities.

Below are the roles and responsibilities of FEMA, the Recipient, and the Subrecipient.

FEMA Responsibilities:

  • Coordinates with all state, local, and federal agencies
  • Establishes a joint field office
  • Collects project and cost data
  • Approves grants and obligates funds
  • Provides technical assistance

Recipient Responsibilities (State):

  • Educates subrecipients
  • Works with FEMA to manage public assistance program
  • Collects project and cost data
  • Dispurses grants to subrecipients
  • Monitors and manages use of grants by subrecipients

Subrecipient Responsibilities (Applicants: city, county, local public entity, eligible nonprofit):

  • Requests assistance
  • Identifies damaged facilities
  • Provides information to support request
  • Maintains accurate documentation
  • Performs necessary work (repairs, debris, etc.)

Source: FEMA’s Public Assistance Program Explained

FEMA Public Assistance Program – Reimbursable Costs

Not all costs incurred during a disaster are eligible for FEMA reimbursement. Eligible Assistance

under the COVID-19 Emergency Declaration may provide assistance for emergency protective measures including (but not limited to) the following, if not funded by the HHS/CDC or other federal agency. While some activities listed may be eligible for funding through HHS/CDC, final reimbursement determinations will be coordinated by HHS and FEMA. FEMA will not duplicate any assistance provided by HHS/CDC. Click here for more information on FEMA’s reimbursement eligibility guidelines under the Public Assistance Program.

Management, control and reduction of immediate threats to public health and safety

  • Emergency Operation Center costs
  • Training specific to the declared event
  • Disinfection of eligible public facilities
  • Technical assistance to state, tribal, territorial or local governments on emergency management and control of immediate threats to public health and safety

Emergency medical care

  • Non‐deferrable medical treatment of infected persons in a shelter or temporary medical facility
  • Related medical facility services and supplies
  • Temporary medical facilities and/or enhanced medical/hospital capacity (for treatment when existing facilities are reasonably forecasted to become overloaded in the near term and cannot accommodate the patient load or to quarantine potentially infected persons)
  • Use of specialized medical equipment
  • Medical waste disposal
  • Emergency medical transport

Medical sheltering (e.g. when existing facilities are reasonably forecasted to become overloaded in the near future and cannot accommodate needs)

  • All sheltering must be conducted in accordance with standards and/or guidance approved by HHS/CDC and must be implemented in a manner that incorporates social distancing measures
  • Non‐congregate medical sheltering is subject to prior approval by FEMA and is limited to that which is reasonable and necessary to address the public health needs of the event, is pursuant to the direction of appropriate public health officials and does not extend beyond the duration of the Public Health Emergency.
  • Household pet sheltering and containment actions related to household pets in accordance with CDC guideline.
  • Purchase and distribution of food, water, ice, medicine, and other consumable supplies, to include personal protective equipment and hazardous material suits movement of supplies and persons.
  • Security and law enforcement
  • Communications of general health and safety information to the public.
  • Search and rescue to locate and recover members of the population requiring assistance.
  • Reimbursement for state, tribe, territory and/or local government force account overtime costs.

FEMA Schedule of Equipment Rates for “Force Account” Equipment

FEMA provides a schedule of their equipment rates via the link here. The 2019 schedule is the most current, and will remain so until an updated schedule is posted on this webpage. The 2019 schedule of equipment rates include a list of equipment eligible for “Force Account” equipment reimbursement, and the amount per hour that each piece of equipment is valued.

Important: FEMA could require that subrecipients provide documentation that shows that this equipment was used specifically related to COVID-19 response, as opposed to general operations. Further, when applying for Force Account equipment use reimbursement, subrecipients must be able to document, through Force Account labor sheets, the personnel operating each piece of equipment.

Please be advised that this a high-level overview of the FEMA Payment Assistance Program. Throughout the COVID-19 Pandemic, it is important to note that FEMA has the authority to introduce alternative procedures. FAMA and FEMSA membership should continue to monitor this process.

Click here for the Member Notice in pdf.

If you have any questions, please contact the GAC Co-chairs:
John Granby at jgranby@lionprotects.com
Lee Morris at lmorris@oshkoshcorp.com
David Durstine at ddurstine@idexcorp.com
or GAC Sr. Adviser Dave Gatton at dgatton@dinitiatives.com