Although your organization may not submit a Streamlined Application for FEMA Public Assistance for weeks, or even months, begin tracking and gathering documentation NOW to prepare for your upcoming filing. It’s imperative. The experts at Advis have prepared a list of preparation tips to ensure providers are fully equipped to file successfully.
- Know your health system’s EINs.
Unlike previous disasters, FEMA is now allowing streamlined RPAs and project worksheets. But by doing so, it becomes essential that health systems understand all of the legal entities that report to the parent entity and report those costs accordingly. Although rolling submissions are expected, failure to include all eligible costs in the initial request could cause undue delay.
- Initially establish and maintain open communication with your state emergency management agency.
Each state has various procedural nuances related to submission of the FEMA Request for Public Assistance (“RPA”) and various tasks to be completed thereafter.
- Manage your cost allocation.
CARES Act funding allows for a broader range of cost offsets, as well as offsets for lost revenue; however, FEMA (as currently defined) has a very narrowly defined set of allowable costs. Therefore, providers should allocate prior to submissions of FEMA project worksheets all non-FEMA eligible costs to ensure that all alternative sources of funding have been exhausted.
- Create an electronic repository for collecting and compiling all supporting documentation related to emergency protective measures as defined by FEMA.
Although all documentation may not be necessary for initial FEMA filing, accessible upon audit, a complete record of all supporting documentation underlying the funding requests submitted in the application is imperative.
- Implement a mechanism that only identifies emergency medical services provided to patients.
Ahead of collecting and submitting costs, implement a mechanism to identify medical services provided to patients on an emergency basis, as inpatient services are not eligible for FEMA reimbursement.
- Develop a mechanism to track eligible labor time down to the employee level.
Even if FEMA is accepting samplings of time sheets and activity logs, it does seem FEMA will require the data elements provided by labor worksheets at the employee level, if not during the submission, then, at a minimum, on audit.
- When thinking about supplies, remember that not only new purchases are eligible when responding to a disaster, but inventory taken from existing stock can be eligible for FEMA funding if the inventory is tied to eligible activities.
Ensure your entity is taking the necessary steps to maintain inventory withdrawal and usage records, as this information may be requested by FEMA to tie inventory to eligible activities.
- Clearly document how expenses relate directly to COVID-19.
It is important to supply clear documentation on how expenses directly correlate to COVID-19 response work, specifically to facilitate future FEMA auditing and review. Please recognize that you may not be able to rely on having the same staff available to provide details in upcoming years, so precise proactive documentation is imperative.
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Advis has over 25 years of experience assisting organizations with FEMA filings, document systemization, and retention. Our team has assisted hospitals across the country with FEMA reimbursements. We all acknowledge that the process can be overwhelming.
Our tip list helps you achieve full preparedness when submitting FEMA reimbursement applications. In the weeks and months ahead, shore up your confidence and press ahead.
For more information, or to get in touch with a FEMA expert at Advis, please contact us online or by calling 708-478-7030.
Published: May 12, 2020
