On March 13, 2020 the President declared the ongoing Coronavirus Disease 2019 (COVID-19) pandemic of sufficient severity and magnitude to warrant an emergency declaration pursuant to section 501(b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5121-5207. This declaration makes available to state, territorial, tribal, and local government entities such as cities, towns, counties, and authorities, as well as certain private non-profit (PNP) organizations, Public Assistance (PA) funding to help defray the costs associated with the ongoing response to COVID-19.

The following is a brief description of what types of costs (specific to local government entities) are potentially eligible for reimbursement under this declaration.

Eligible Costs

Costs potentially eligible for reimbursement under this declaration are those expenses that fall under the FEMA Category B, Emergency Protective Measures expense category. A few examples of these costs are:

  • Labor/supply costs associated with your response to COVID-19
  • Measures taken to protect staff and community members Overtime paid to employees preparing for and responding to COVID-19
  • Costs of PPE associated with COVID-19
  • Costs for contractors performing emergency protective work Other costs the organization would not normally incur during regular operations
  • Any other costs associated with preparing for, responding to, or recovering from the COVID-19 pandemic

What Should We Do Now?

As your organization prepares to manage its COVID-19 response, you should begin tracking costs by setting up cost centers to capture disaster-related charges such as:

  • Labor
  • Supplies
  • Equipment

Even if your jurisdiction never encounters a COVID-19 case, the costs you incurred to prepare may be eligible for reimbursement.

Can A Vendor Help Us With This Process?

Due to the strain on local government agencies in dealing with a public health crisis of this magnitude and the extreme complexity of federal disaster reimbursement guidelines, FEMA subrecipients such as local governments are encouraged to contract with an experienced vendor to provide oversight and advocacy on their behalf through the PA reimbursement process.

Vendor costs are eligible for reimbursement under this declaration.

Federal procurement regulations permit entities to issue emergency contracts for exigent circumstances. After the issuance of a temporary emergency contract, your normal procurement procedures must be followed, usually through the issuance of an RFP to replace the emergency contract with a competitively bid award. The RFP must meet all the requirements of federal procurement as defined under 2 C.F.R. § 200.317-326.

Download “What the COVID-19 Emergency Declaration Means for Local Governments”

Please contact us for additional information and guidance.