TRACK WITH SPECIAL COST CODES FOR COVID-19 AND DOCUMENT - DOCUMENT!!!
Document all work performed and costs incurred. All affected entities should document work performed (including paid and volunteer assistance) and costs incurred (including copies of all receipts and time logs). Consider COST CODES for all Covid-19 supplies, specific Covid-19 contracts, labor and equipment and any unbudgeted expense related to Covid-19
These records can support ALL FEDERAL ASSISTANCE claims and will be required to support claims to FEMA or HHS or any other State or Federal Agency for additional assistance.
Scope of Eligible Work and Costs.
Presently, there is little information regarding the scope of actions and funding that is contemplated under the nationwide declaration. FEMA's Declaration Fact Sheet, available here, states only that "eligible emergency protective measures taken to respond to the COVID-19 emergency at the direction or guidance of public health officials may be reimbursed under Category B of the agency's Public Assistance program." The individual state declarations confirm this and note expressly that the Individual Assistance Program has not yet been authorized.
Emergency protective measures includes activities that must be done immediately to save lives,protect public health and safety, protect improved property, and eliminate or lessen the immediate threat of additional damage, and can include costs associated with overtime and sick leave for permanent employees and straight time and overtime associated with temporary employees, transporting and pre-positioning equipment, purchasing equipment and supplies providing essential commodities,evacuating and sheltering individuals, and providing medical care and transport. Emergency protective measures eligibility can be more restrictive for private non-profit organizations than for governmental entities. However,the Stafford Act has rarely been used for pandemics and there may be repeated changes to eligibility criteria as different types of emergency measures to save lives, protect public health and safety, and eliminates or lessen the immediate threat of additional damage (such as temperature screening, building access control, decontamination, and other virus-specific actions) are undertaken by governments and private non-profit organizations.
Traditional Category B Costs. FEMA's guidance regarding the work and costs traditionally considered as eligible Category B work provides some insight into the type of funding that may be provided to eligible entities under the COVID-19 declaration. This may include work to slow transmission of the virus through isolation and treatment of patients who have contracted the virus, and through quarantine and social distancing measures. Eligible work may also include communications about public health risks, social distancing, and how to get tested for the virus. It may also include enforcement of social distancing measures (e.g., through activation of the national guard to enforce/administer gubernatorial orders closing schools, bars, restaurants, concerts, museums, and the like), construction of tent testing sites and tent systems to expand the capacity of hospitals, disinfection of facilities contaminated with the virus, and where necessary, delivery of food and medical supplies to those denied freedom of movement by public health orders. We expect FEMA to provide some guidance specifically targeted at COVID-19 response.
Increased Operating Expenses and Loss of Income.
The social distancing measures needed to slow transmission of COVID-19 will substantially reduce economic activity and employment in at least the short run. For many state and local governments and non-profits eligible to receive grants from FEMA, this will result insubstantial losses in fee and tax revenue. FEMA's PA Program generally does not fund "increased operating expenses" or lost revenue from reduced fees or taxes generated from economic activity. These impacts will be addressed at least partially by additional federal legislation. MORE ON THIS SUBJECT LATER