On March 13, 2020 the COVID-19 pandemic was declared a National Emergency by President Trump. This declaration set in motion the availability of FEMA Public Assistance (PA) disaster relief funds to support nonprofit healthcare and higher education organizations, among others, during the recovery. On March 27, 2020, additional FEMA PA disaster relief funds of approximately $45 billion were appropriated through the CARES Act to address the public health emergency. Further, many of the longstanding FEMA policies and procedures are being loosened to streamline and expedite funding for nonprofit healthcare organizations such as hospitals and hospice, as well as certain higher education institutions.
It is important to note that costs and expenses a provider allocates as covered by Provider Relief Funds or other government funds cannot be reimbursed by FEMA PA funds. Hence, the decision regarding allocation of the different federal funds to eligible entity COVID-19 costs and expenses is an important one. Careful advance planning is strongly recommended to ensure maximum appropriate reimbursement from all available federal funds, including FEMA PA funds.
Set forth below are the eligibility requirements, as well as the costs and expenses eligible for reimbursement, and the immediate steps can be taken to strategically prepare for receiving FEMA PA relief funds.
Private, for-profit healthcare and higher education organizations are not eligible for assistance from FEMA PA relief funds. However, private nonprofit (“PNP”) organizations are eligible and must satisfy two requirements:
Additionally, covered state, local, tribal or territorial entities are eligible for FEMA PA, including those that own and/or operate medical care or education facilities.
FEMA may provide PA funds for costs and expenses for emergency protective measures including, but not limited to, the following:
– COVID-19 patients that do not need hospitalization, but do need isolation;
– Patients exposed to COVID-19 who do not need hospitalization; and
– Asymptomatic high-risk individuals needing social distancing as a precautionary measure, such as people over 65 or with certain underlying health conditions.
Additional information about eligible emergency protective measures can be found in the recently updated Coronavirus (COVID-19) Pandemic: Eligible Emergency Protective Measures Fact Sheet, March 19, 2020.
Take Immediate Steps To Prepare For FEMA PA Relief Funds
Historically, FEMA required PA fund requests to be submitted within 30 days of the disaster declaration. FEMA recognized this was an unrealistic timeframe given the ongoing nature of the COVID-19 public health emergency and consequently, extended the deadline for COVID-19 Requests for Public Assistance (RPA) to 30 days after the end of the declared disaster period.
Although the final deadline for an RPA has not yet been established, healthcare and higher education organizations should nonetheless immediately begin to implement processes to secure a successful cost recovery:
Work With FEMA Successfully
Most nonprofit healthcare and higher education organizations have little experience working with FEMA. When communicating with FEMA it is imperative to offer clear and concise explanations of the day-to-day organizational operations to be successful in securing funding.