FEMA Funding for Costs of Emergency Protective Measures for COVID-19
By Ronald F. DeSoiza, CPA, Partner
Under emergency declarations, FEMA’s Public Assistance program is available to reimburse certain Private Non-Profit (PNP) Organizations for eligible emergency protective measures carried out under the direction or guidance of public health officials. Eligible protective measures are for services for immediate threats to life, public health, and safety. These measures are detailed here.
State, local, tribal, and territorial governments are generally legally responsible for services to protect life, public health, and safety. In performing these services they often contract with a PNP to assist them in their responsibility. In these cases, FEMA Public Assistance funding is provided to the government unit which in turn pays the PNP for providing the services.
In other cases, vital services are performed directly by a PNP facility such as, providing emergency, medical care, or custodial services. In these cases, the PNP is the legally responsible entity in the eyes of FEMA and is eligible for reimbursement of costs for emergency protective measures directly from FEMA as a Public Assistance applicant.
Effective July 1, 2020, FEMA waived the PNP Primary Use and Primary Ownership Facility policies as a result of the Coronavirus (COVID-19) Pandemic Declarations. These policies required that a PNP own or operate an eligible facility. Specifically, these policies required a PNP to operate a facility that provided eligible services, or if services were provided in a mixed-use facility (eligible and non-eligible) that more than 50% of the physical space be dedicated to eligible uses. There was an additional requirement that a mixed use facility had to be owned by the PNP.
Under the COVID-19 Declarations, a PNP may be eligible for assistance even though they do not meet the primary use or primary ownership requirements. Therefore, the requirements to own if mixed use or otherwise a facility totally dedicated to eligible services are not required during the pandemic.
Eligible applicants may submit funding requests to the Recipient and FEMA through the Public Assistance Grants Portal. Instructions can be found here. FEMA will not duplicate any assistance provided by HHS\CDC.
Recipients should work through their FEMA regional points of contact to make sure the proper forms or paperwork have been filled out before applying for a grant.
As always, for further guidance and assistance, please reach out to your PKF O’Connor Davies engagement team members or:
Ronald F. DeSoiza, CPA, ABV
firstname.lastname@example.org | 914.421.5604