The Federal Emergency Management Agency (FEMA) and states are currently accepting applications from local governments and certain nonprofits for reimbursement of costs associated with coronavirus/COVID-19 response. The FEMA Public Assistance program is a pipeline of funding activated by a Presidential Emergency or Disaster Declaration. To receive funding under the Public Assistance program, local governments and nonprofits work with their state governments to receive reimbursement for expenses related to COVID-19 response and exposure prevention.
State, tribal, and local governments are all eligible to receive FEMA Public Assistance funding for certain COVID-19 response and prevention costs. Local governments include school districts and government-owned water and sewage treatment facilities.
Private nonprofits are also eligible to apply for FEMA reimbursement funding. The nonprofit must have IRS tax-exempt status under sections 501(c), (d), or (e) of the Internal Revenue Code of 1954, or an equivalent state-based status, and either:
- Provide critical services as defined by FEMA. Critical service providers include:
- educational facilities and institutions
- emergency services
- medical care, including public hospitals, long-term care facilities, clinics, outpatient facilities, and hospices, among other care providers
- Provide essential social-type services as defined by FEMA. Essential social-type service providers include, among others:
- community centers
- alcohol and drug treatment facilities
- assisted living facilities
- childcare facilities
- food assistance programs
- homeless shelters
- houses of worship
- low-income housing
- services related to domestic violence
FEMA reimbursement funding is available only for costs related to certain actions, which FEMA categorizes as “Emergency Protective Measures.” These are measures conducted before, during, and after an incident to eliminate or lessen immediate threats to lives, public health, or safety.
An example is the purchase of personal protective equipment for workers in a medical facility for COVID-19 prevention and treatment. Other COVID-19-related supplies, equipment, and labor costs are eligible, subject to conditions and limitations provided in federal regulations and FEMA guidance.
Costs already covered by a federal agency (such as the Department of Health and Human Services) or by a Paycheck Protection Plan loan are not eligible for reimbursement.
In order to apply, a local government or nonprofit should contact their state agency responsible for managing FEMA funding. In Iowa, governments and nonprofits will work with the Iowa Department of Homeland Security and Emergency Management; you can find the individual contacts for your region on the IDHSEM Federal Public Assistance Program website.
To apply, an organization submits a “Request for Assistance” triggering FEMA to grant access to a FEMA electronic portal. Once the organization has access to the portal, it can submit costs for reimbursement on a project-by-project basis. Applications will be accepted until 30 days following the end of the state’s declaration of emergency.
However, any potentially eligible organization should explore applying for FEMA funding sooner rather than later. FEMA requires specific contemporaneous recordkeeping to support reimbursement claims, and in order to qualify for reimbursement, the purchase of supplies and equipment is subject to certain federal procurement regulations.
Organizations interested in applying for FEMA funding should contact an attorney for specific information about the eligibility of their specific costs, and recordkeeping or procurement measures to best position your organization for FEMA cost reimbursement.
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