COVID-19: FEMA Funding, Programs and Tips for Government and Education Leaders

When President Trump declared a nationwide emergency due to COVID-19, every state and thousands of local governments and not-for-profit entities became eligible for funding through FEMA’s Public Assistance Program. This is FEMA’s largest grant program, and its purpose is to support communities’ recovery from major disasters by providing them with financial assistance for life-saving emergency protective measures and restoring public infrastructure. Local governments, states, tribes, territories and certain private not-for-profit organizations are eligible to apply.

Here are answers to some of the most common questions about the program as well as tips for complying with FEMA requirements.

Who is eligible?

Local governments, states, tribes, territories and certain private not-for-profit organizations are eligible to apply for funding. Eligible private not-for-profits (PNPs) include schools, colleges, utilities, clinics, laboratories, hospitals, long-term care facilities and emergency services providers. PNPs may also be non-critical service providers like community centers, assisted living centers, childcare facilities, food assistance programs, houses of worship and senior centers, among others.

What expenditures are reimbursable?

Expenditures related to management, control and reduction of immediate threats to public health and safety, emergency medical care, medical sheltering, overtime costs, security and law enforcement, and food and supplies distribution, among others. FEMA has released fact sheets related to reimbursable costs for emergency protective measures and sheltering costs.

How does the flow of funding work?

FEMA funding typically flows through the state to eligible applicants, pursuant to a sub-grant agreement between the state and the eligible applicant. The costs are organized into projects and captured in a Project Worksheet (PW). The PW is used to document and approve costs for reimbursement.

Is the process for COVID-19 funding the same as for past natural disaster grants?

FEMA has issued this fact sheet on simplifying the public assistance application process for COVID-19 funding. FEMA is limiting supporting documentation required based on the risk of providing ineligible funding. Experienced applicants will use the same log in, and new users need to contact local or state emergency systems to create an account on the PA Grants Portal.

Tips and information for grantees:

When state and local governments have to work quickly to respond to emergencies, internal controls and compliance with grant requirements can be difficult to manage. Here are some tips for avoiding compliance issues and unreimbursed expenditures:

1. Keep records of all purchases for which you plan to seek reimbursement.
2. Maintain documentation to show that vendors or contractors were selected in accordance with accepted purchasing policies.
3. Retain timesheets and daily payroll activity for emergency workers.
4. When seeking reimbursement, note that allowable costs under the grant are always net of any insurance settlements or other sources of recovery funding other than the PA program, such as funding from Health and Human Services.
5. Costs must be on a shared basis, as specified in the FEMA-State Agreement. In general, the minimum federal share is 75 percent of eligible costs (44 CFR section 206.65). The non-federal share split between the state and each subgrantee may vary.
6. For large projects as defined by FEMA, the subgrantee must make an accounting to the state, just as the state makes an accounting to FEMA. In submitting the accounting, the entity is required to certify that:
   • Reported costs were incurred in performance of eligible work;
   • The approved work was completed;
   • The project is in compliance with the provisions of the FEMA-State Agreement; and
   • Payments for that project were made in accordance with the 44 CFR section 13.21 payment provisions.
7. For improved and alternate projects, if the total costs of the projects do not equal or exceed the approved eligible costs, then an adjustment should be made to reduce eligible costs (44 CFR section 206.205).
8. More information about eligible emergency protective measures can be found in FEMA’s Public Assistance Program and Policy Guide.
9. The FEMA Public Assistance Program is CFDA 97.036. Grant requirements can be found in the 2019 Compliance Supplement.

Resources for Elementary and Secondary Schools

1. School districts should work closely with their local health entities as they weigh operational decisions. The Texas Department of State Health Services (DSHS) is the lead agency in preparedness efforts for Texas. The DSHS website is also providing updated counts of confirmed cases of coronavirus by region.
2. The CDC has issued Interim Guidance for Administrators of US K-12 Schools and Child Care Programs to help with decisions related to COVID-19 
3. The Readiness Emergency Management for Schools (REMS) Technical Assistance (TA) Center has useful information, resources, trainings and tools for addressing infectious diseases and protecting the school community.
4. The USDA has information on flexibilities to allow students to access meal service during school closures.

To find out more about disaster relief funds or for assistance managing FEMA grants, contact a Weaver professional today. We’re here to help.

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