On March 13, 2020, the President declared the ongoing Coronavirus Disease 2019 (COVID-19) pandemic of sufficient severity and magnitude to warrant a nation-wide emergency declaration.  The declaration allows private non-profit (PNP) organizations such as hospitals to apply for FEMA Public Assistance for reimbursement of costs associated with COVID-19 emergency protective measures.

Eligible emergency protective measures taken in response to the COVID-19 pandemic may be reimbursed under Category B of the agency’s Public Assistance program. No alternative source of reimbursement may exist for such costs to be reimbursed by FEMA.  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.  At this time, it is anticipated that eligible expenses will be reimbursed at 75 percent of costs.

COVID-19 related activities for which FEMA reimbursement may exist include:

• Increased Security;
• COVID-19 Testing;
• Establishment of Temporary Facilities for COVID-19 Testing, Treatment & Isolation;
• Transfer of COVID-19 Patients Among Facilities;
• Provision of Medical Goods & Supplies to Red Cross, Local Health Departments and Other Governmental Entities;
• Emergency Medical Care Provided to COVID-19 Patients;
• Emergency Protective Supplies and Goods;
• Forced Account Labor Performed Outside Customary; Job Duties and as a Result of COVID-19 Emergency; and
• Other Emergency Protective Measures.

A presidential emergency declaration resulting from a national pandemic has no precedent.  Much uncertainty currently exists surrounding the manner in which the Public Assistance Program will be administered at a national level.  At this time, FEMA has not issued formal guidance related to the reimbursement of eligible COVID-19 activities.  Applicants generally have 30 days from a presidential emergency declaration to file a Request for Public Assistance. However, this may vary based on individual state.

Based on Advis’ 15 years of experience navigating the FEMA reimbursement process, documentation preparation, compilation, and preservation are crucial to obtaining FEMA funding.  Advis urges hospitals everywhere to take the following key actions at this time in order to optimize their opportunities for FEMA reimbursement:

• Establish a Separate Cost Center for Accounting Purposes to Capture all COVID-19 Related Emergency Preparedness Expenses-Having the ability to capture all emergency preparedness related expenses allows for a more accurate accounting of incurred costs and allows hospitals to more quickly assess the financial impact incurred.
• Establish a Formal Practice for Electronically Capturing & Cataloguing; Retain all COVID-19 Related Expense Documentation-FEMA eligible expenses are only reimbursed if sufficient documentation exists and can be made available:
  • Vendor Contracts
  • Purchase Orders
  • Invoices
  • Proof of Payment Documentation

• Take Photos of any Temporary Facilities Established to Test, Treat and Isolate COVID-19 Patients-Document through photos the establishment of temporary facilities for COVID-19 testing, treatment, and isolation.
• Have Formal Written & Executed Mutual Aid Agreements in Place with Red Cross and Area Shelters-Red Cross & local health departments will commonly not have sufficient resources to respond to an emergency; therefore, they may request assistance from area hospitals: the Establishment of a Mutual Aid Agreement may assist with obtaining FEMA reimbursement for such costs.

Advis can help best position you to receive FEMA assistance. Call us for specific guidance regarding FEMA reimbursement and the maintenance of adequate documentation for submission of claims related to reimbursement for COVID-19 emergency protective measures.  Please contact us at 708-478-7030 with any questions. To see how best we may assist your organization with seeking FEMA reimbursement as a result of COVID-19, contact Ryan Yokley or Ryan Bailey  directly.

Visit The Advis Information Repository for continual guidance regarding the pandemic.

Published: March 17, 2020