New FEMA PA Policy Regarding Reopening Costs for COVID-19

The Federal Emergency Management Agency (FEMA) earlier this week released new policy regarding Public Assistance (PA) eligibility for reopening costs for public facilities for COVID-19. The COVID-19 Pandemic: Safe Opening and Operation Work Eligible for Public Assistance (Interim) policy  defines the framework, policy details, and requirements for determining the eligibility of safe opening and operation work costs under the PA program. It provides eligibility to safe opening and operations conducted from January 21, 2021, through September 30, 2021. Reimbursement for eligible costs will be provided at 100 percent federal funding. 

A couple of key points on the new guidance:

  • Reopening costs are PA-eligible from January 21, 2021, through September 20, 2021; reopening costs prior to January 21, 2021, are not eligible.
  • Eligibility for PA reimbursement includes the following types of expenses:
    • PPE and cloth face masks
    • Cleaning and disinfection in accordance with public health guidance (supplies and equipment in excess of regularly budgeted costs)
    • COVID-19 testing
    • Screening and temperature scanning, including purchase of hand-held temperature measuring devices or equipment (cost-reasonableness policy applies as always)
    • Purchase and installation of temporary physical barriers
    • Purchase and storage of PPE and other supplies based on projected need (i.e., stockpile)
  • Based on the language in the guidance, facilities for which reopening costs are eligible are those of eligible PA applicants. We have asked FEMA staff to confirm this interpretation.

Based on the differences in eligibility before and after January 21, SCEMD suggests that, if possible, PA applicants that plan to include reopening expenses in a PA project application put those in a project application separate from any expenses that occurred prior to January 21, 2021, to avoid the policy difference holding up review and processing of the project application. The SCEMD PA team is available to assist with your questions and with submitting PA project applications in FEMA’s Grants Portal via email or phone at (803) 367-7756.