MAXIMIZING REIMBURSEMENT OF CORONAVIRUS ACTIVITIES COSTS INCURRED

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 for all states, tribes, territories, and the District of Columbia pursuant to section 501 (b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5121-5207 (the “Stafford Act”). State, Territorial, Tribal, local government entities and certain private non-profit (PNP) organizations are eligible to apply for Public Assistance.

In accordance with section 502 of the Stafford Act, 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. FEMA will not duplicate assistance provided by the Department of Health and Human Services (HHS), including the Centers for Disease Control and Prevention, or other federal agencies. This includes necessary emergency protective measures for activities taken in response to the COVID-19 incident. FEMA assistance will be provided at the 75 percent Federal cost share.

With the federal emergency declaration, costs that you incur for Coronavirus activities THAT ARE NOT ALREADY COVERED BY ANOTHER GRANT PROGRAM are eligible for federal reimbursement.

Here are a few tips for developing documentation that will help you justify the costs to be reimbursed:

Make sure you declare an emergency so that you can execute emergency procurements. You should already have a policy dictating circumstances that allow you to execute an emergency procurement. If you don’t, you can create one that is pretty simple. Here’s an example of what you could use:

Emergency procurement will only be considered when a threat to public health, welfare, or safety exists. Under no circumstances will poor planning be considered an “emergency.” A minimum of two (2) bids will be obtained through telephone, fax, or electronic mail. An Emergency Contract Certification form will be completed by the contracting officer, approved by an appropriate management level executive, and attached to the contract for legal review and approval.

• Identify the costs incurred, both payroll and non-payroll, as associated with Coronavirus activities. This is critical. You have to demonstrate how these costs would not otherwise have been incurred or reimbursable under another grant program. The declaration is clear that this is meant to supplement other grant programs, not to supplant them. On the purchase orders created and invoices received, document that these costs are incremental and not reimbursable from other programs. Indicate the same for payroll costs incurred. Have that documentation reviewed and approved by management level personnel.
• Create a summary of the costs incurred for Coronavirus activities at least bi-weekly. Creating this summary allows you to review the listing quickly to make sure you are capturing all eligible costs timely. The longer you wait to prepare the summary, the more likely it is that you fail to capture an eligible cost.
• Keep a separate file with copies of all documentation, including the weekly summaries. This will facilitate the preparation of the reimbursement request and also facilitate any audit review that occurs.

Taking these simple and straight forward steps will give you the opportunity to maximize reimbursement for costs incurred for Coronavirus activities.