Updated FEMA Guidance: Eligible Medical Care and Vaccine-Related Expenses

FEMA has released updated guidance for Public Assistance regarding work performed as a direct result of the COVID-19 pandemic on or after January 20, 2020. The latest updates confirm that the entire cost of emergency protective measures are made eligible as equitable pandemic responses, and are covered by FEMA through September 30, 2021. The new policy extends the deadline beyond 6 months of the date of the declaration; the policy specifies that applicants will be notified at least 30 days before the deadline is to be established.

Updated General Eligibility Requirements and Funding Considerations

The new policy has modified the general eligibility requirements. Factors that FEMA will evaluate include:

  • Whether the cost was necessary and reasonable in order to respond to the COVID-19 pandemic;
  • Whether the cost conforms to the standard PA program eligibility and other federal requirements; and
  • Whether the applicant followed FEMA’s established practices and policies and procedures that apply when federal funding is not available.

If an applicant applies for FEMA funding and then decides to seek funding from another federal agency, notification to FEMA should occur no later than 30 days after that decision is made. Failure to notify in a timely manner may result in collections or de-obligation of funding.

If Public Assistance funding has yet to be awarded at the time of the decision, applicants should withdraw or amend their application no later than 30 days post-decision. If funding has already been received, applicants must request an updated version of its application to amend the project in question.

Eligible Medical Care Expenses

The latest guidance confirms 100% coverage for eligible medical care expenses. Pre-existing medical care guidance remains largely unchanged with the exception of the following additional conditions.

To qualify, recipients must make some showing that they focused the use of FEMA funding on the highest-risk communities and underserved populations as defined by established measures, such as the CDC Social Vulnerability Index. Recipients must as show they prioritized limited resources to ensure equitable pandemic response under the regulations.

For COVID-19 declarations, FEMA will use Medicare rates as the basis to determine reasonable costs for eligible clinical care not covered by another funding source.

Eligible Costs Associated with Vaccinations

Additionally, in addition to onsite infection control and emergency medical care measures,

the latest update establishes that “work and associated costs to support the distribution and administration of COVID-19 vaccines” now qualify as costs eligible for FEMA Public Assistance.

FEMA outlines expansive eligibility for the following vaccine-related expenses:

  • Community vaccination centers;
  • PPE, equipment, supplies, etc.;
  • Transportation and storage of vaccines;
  • Facility support costs;
  • Additional staffing (consistent with FEMA PA labor policies);
  • Emergency medical care costs related to vaccine administrations;
  • On-site infection control costs (e.g., masks, disinfection, temp scanning, physical barriers, medical waste disposal, etc.);
  • Resources to support mobile vaccine sites for remote areas or to transport individuals with lack of access/mobility;
  • Communications to the public, including call center costs;
  • IT equipment and systems (registration, tracking, inventory management, analytics, reporting needs, etc.); and
  • Training and technical assistance for proper storage, handling, distribution, and administration per CDC guidance.

Recipients are also required to collect vaccination data on race, ethnicity, and disability status in order to qualify for FEMA funds for vaccination. The guidance provides information on what each site selected for vaccination administration must document and report to FEMA every 30 days. This information includes:

  • Your Score on the CDC’s Social Vulnerability Index or a similar social deprivation, disadvantage, or vulnerability composite index;
  • A Description of how the location of the site best advances FEMA’s focus on supporting the highest-risk communities; and
  • Your site strategy to operationalize equitable distribution.

The policy confirms that Federally Qualified Health Centers (FQHCs), Rural Health Clinics (RHCs), and Critical Access Hospitals (CAHs) may apply for vaccine funding.

For specific guidance regarding FEMA Public Assistance, please contact ADVIS online or at 708-478-7030  to see how best we may assist your organization in seeking reimbursement as a result of your response to COVID-19.

Published: April 9, 2021