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COVID-19 Public Assistance Frequently Asked Questions

Below are commonly asked questions and answers regarding the FEMA Public Assistance Program for the COVID-19 disaster.

Table of Contents

General Information for COVID-19 Disaster Declaration

What is the disaster record number for MA’s major disaster declaration for COVID-19?

The disaster recover number for the Commonwealth’s major disaster declaration for COVID-19 is DR-4496.

What category of work is eligible under this major disaster declaration?

Only Category B-Emergency Protective Measures is eligible under DR-4496.

How do FEMA and MEMA work together to implement FEMA PA?

The Federal Emergency Management Agency (FEMA) and the Massachusetts Emergency Management Agency (MEMA) work together as the federal awarding agency and the state recipient to provide funding to the local and state level.

FEMA is the federal agency responsible for providing PA funding and housing the FEMA Grants Portal system, while MEMA is the state agency responsible for providing technical assistance, payment, and post-obligation required activities. FEMA and MEMA are separate entities with separate responsibilities both with the shared goal of effecting a complete and quick recovery.

Where can I find updated guidance from FEMA on PA for COVID-19?

You can find all guidance from FEMA regarding Public Assistance for COVIF-19 here: https://www.fema.gov/media-collection/public-assistance-disaster-specific-guidance-covid-19-declarations

What is FEMA Grants Portal?

FEMA Grants Portal is used by all levels of government and applicants to administer, manage, and collaborate on FEMA Public Assistance. It is a web-based grant management system where all grant related documentation will be stored, managed, used to create projects. It is used by applicants to submit requests for public assistance, identify and upload costs, upload required backup documentation, and track projects.

What is the cost share for FEMA PA for DR-4496?

FEMA announced, on February 2, 2021, that the cost share adjustment of eligible costs under FEMA PA for COVID-19 activities would be 100%. This cost share adjustment is retroactive to all costs incurred from 01/20/2020 going forward to 9/30/2021. For applicants with projects already obligated, there is no action needed to get the balance non-federal cost share. FEMA and MEMA are working together to get versions to already existing projects created and obligated to facilitate payment. As FEMA makes cost share adjustments to previously obligated projects, MEMA will reach out to applicants to create an amendment to the grant agreement.

Where can I find a glossary for common PA terms?

You can find a glossary for common PA terms in the Public Assistance Program and Policy Guide pg. 213:

https://www.fema.gov/sites/default/files/documents/fema_pappg-v4-updated-links_policy_6-1-2020.pdf

Eligible Items Under FEMA Public Assistance (PA)

What activities are eligible for PA reimbursement?

To be eligible for FEMA Public Assistance, activities that are the legal responsibility of the applicant and must be necessary in order to respond to the COVID-19 pandemic and be reasonable pursuant to 2 C.F.R. 200. Additionally, costs must be required as a direct result of the pandemic and must be necessary to save lives and protect public health and safety. Specific costs are listed in FEMA Policy FP 104-009-19, Coronavirus Pandemic: Work Eligible for Public Assistance.

What are some commonly ineligible items for PA reimbursement?

Common items that will not be eligible for reimbursement:

  • Tele-working for non-emergency staff, i.e. staff performing routine activities.
    • Regular or Budgeted Time for employees. Only overtime will be eligible for reimbursement. Please refer to the below table. For unbudgeted employees, such as temporary employees hired specifically as a result of the pandemic may be eligible for reimbursement. For reimbursement of standby time, Applicants must clearly prove that the time was indeed standby, and not idle time. To do this, the Applicant has the burden of proof to provide documentation justifying that COVID-related activities were being completed while on standby. In addition to proving that the time was not idle time, a justification memo must be provided to explain why the standby time was necessary and appropriate. 
      Emergency Work Labor Eligibility
        Overtime Straight-Time
      Budgeted Employees    
      Permanent employee Eligible Not Eligible
      Season employee working during normal season of employment Eligible Not Eligible
      Unbudgeted Employees    
      Essential employee called back from administrative leave Eligible Eligible
      Permanent employee funded from external source Eligible Eligible
      Temporary employee hired to perform eligible work Eligible Eligible
      Seasonal employee working outside normal season of employment Eligible Eligible
      Source: Public Assistance Policy and Program Guide V3.1 April 2018    
  • Delayed Construction Costs.
  • PPE for the general public.
  • Backfill time for employees out sick with COVID-19.

NOTE: FEMA is expected to provide new guidance that may make some previously ineligible costs, such as school re-opening potentially eligible. This FAQ will be updated accordingly.

Who makes the final eligibility determination?

FEMA as the federal awarding agency is the entity responsible for making all final eligibility determinations. MEMA (MA Emergency Management Agency) provides technical assistance in helping applicants create robust and complete reimbursement packages and manage applicant expectations.

How can I get a determination before I submit my costs for reimbursement?

Unfortunately, only formal determinations are issued once a project is submitted to FEMA for review. However, if applicants are unsure if costs are eligible for reimbursement, please contact your assign MEMA Project Coordinator for technical assistance. Even though MEMA cannot provide a final eligibility determination, we can provide guidance on the type of eligibility determinations FEMA has issued.

What are Category Z Management Expenses?

Category Z management costs refer to the administrative costs incurred in the preparation of a FEMA application for all projects submitted under one disaster (including small projects and large projects). Under Category Z, FEMA may provide reimbursement of an Applicant’s administrative expenses up to 5% of the sum of all costs obligated through Category B projects. Category Z costs are funded at a 100% cost share. Category Z costs can be submitted based on actual or estimated expenses, but reimbursement will be based only on actual expenses incurred by the Applicant. 

Applicants may only submit one Category Z management application per disaster. Category Z costs are obligated after FEMA has obligated all of the Applicant’s Category B expenses. Because the length of this disaster is unknown, and unless Applicants know that they have submitted all of the projects they intend to submit to FEMA under Category B, Applicants are encouraged to wait until they have submitted all projects before submitting for Category Z costs. 

What should I do to prepare for Category Z reimbursement?

Applicants should track their direct and indirect administrative costs and begin familiarizing themselves with the Category Z Management Workbook. MEMA has developed a timekeeping sheet, that Applicants can use to track their time on administrative costs. 

Please reference the MEMA website Category Z Management Cost PowerPoint Presentation for further information.

How do I determine which costs to apply for FEMA Public Assistance and which to charge to CARES?

In the interest of leveraging as much federal funding as possible, it is expected that applicants try to get as much as possible reimbursed by FEMA Public Assistance, and charge costs that are not eligible for FEMA Public Assistance to its CARES Act funding.

For questions regarding CARES Act funding, see COVID-19 Resources and Guidance for Municipal Officials.

Applying for FEMA Public Assistance (PA)

What entities are eligible for FEMA PA?

The following entities are eligible to apply for FEMA Public Assistance:

  • State Agencies
  • Tribal Governments
  • Local Governments (please check with MEMA to determine if a Grants Portal account has already been created for your entity); and
  • Certain Private Nonprofit Organizations

If I am a private nonprofit, how do I apply for FEMA PA?

If you are a private nonprofit that has never applied for FEMA Public Assistance before, then the first step in the process is to create an account in Grants Portal. Unfortunately, private nonprofits are not able to create accounts in Grants Portal directly, but will need to complete and submit the Grants Portal Registration Request Form to disaster.recovery@mass.gov . You will also need to send the following documents in this email:

  • Current IRS 501(c)(3) Ruling Letter;
  • Articles of Incorporation/Bylaws;
  • State Licensure (if applicable); and
  • Mission Statement/Brochure of Services.

Once this information is received, MEMA will review and will create an organization on behalf of the PNP. Once the account is created, the staff identified on the Grants Portal Registration Request Form will receive an auto-generated email from Grants Portal with log-in information.

At this time, the PNP authorized users may log into Grants Portal and submit their request for Public Assistance for DR 4496. This request for public assistance must be performed via the FEMA Grants Portal. Please see the video tutorial on how to submit a request for public assistance.

If I belong to a government entity, how do I apply for FEMA PA?

Government entities may create an account directly in Grants Portal, and does not need to go through MEMA to set up an account. Click here to access the FEMA: Grants Portal Account and Request for Public Assistance or a video tutorial.

However, please contact MEMA before creating an account to ensure that a town does not have multiple accounts.

Once I have my account set up- Am I done?

No—applicants will need to make sure that they have an account in FEMA Grants Portal and then must submit an actual Request for Public Assistance for DR 4496. Please see the video tutorial on how to submit a request for public assistance. If a Request for Public Assistance is not submitted, then the applicant will not receive any funding.

How do I know if my request for public assistance has been approved?

Once your Request for Public Assistance has been approved, your entity’s authorized users will receive an auto-generated email from FEMA Grants Portal.

Once my request for PA has been approved, what next?

Once your Request for Public Assistance has been approved, you will receive an auto-generated email from FEMA Grants Portal to complete a Recovery Scoping Video. Please complete and confirm watching this video within a week of your RPA being approved. Additionally, once your RPA has been approved, you will receive an email from your MEMA Project Coordinator introducing themselves and a scheduling request for a meeting to review eligible costs, project development, and answer any questions you may have.

After you have watched your Recovery Scoping Video and met with your MEMA Project Coordinator, you can start on project development.  See Recovery Scoping Video Guide for assistance with completing the Recovery Scoping Video or request a copy from your MEMA Program POC.

Project Development

How do I start a project?

For DR-4496, FEMA is utilizing the Streamlined Project Application. The Streamlined Project Application can only be filled out on FEMA Grants Portal and cannot be submitted via email or hard copy. Only authorized users with log-ins for FEMA Grants Portal may submit a project application. Use the following links for the COVID-19 Streamlined Project Application Template and for a video tutorial on how to start a project.

NOTE: Applicants can submit multiple applications to break costs into logical groupings (e.g. separate applications can be submitted for facility cleaning/disinfection versus vaccination clinic costs). Costs do not need to be submitted on a single application.

Where can I find guidance or a tutorial on how to submit a project via Grants Portal?

Please visit the MEMA web page to find various tutorial on the FEMA Grants Portal.

How can I use narratives to strengthen my application?

Narratives can be used to add extra detail to any component of the packaged submission, or project worksheet (“PW”). In instances where Applicants expect that FEMA may have questions surrounding their application, costs incurred, or details in supporting documentation, narratives can be used to add color and explanation. Additionally, all content contained in the narrative must be supported by the expense documentation. Additional narratives may be recommended for individual cost categories to address specific circumstances and expenses within the application. 

What documentation is required for a project?

Documentation for project varies based on the size of your project. For DR-4496, projects that are between $3,300.00-$131,100.00 are referred to as small projects, while projects exceeding $131,100.00 are referred to as large projects (projects must exceed $3,300.00 to be created). For both small and large projects, a MEMA Workbook is required for work that has already been completed/costs already incurred. To find a template of the MEMA Workbook with a tutorial as well as other forms such as the Small Project Certification, see these guidance and documents. For an overview of documentation needed to submit a “Work Completed” lane project or to submit for reimbursement for a “Standard” lane project, please see below:

Small Project Documentation - from $3,300 - $131,100. Electronic Streamlined Project Application, MEMA Workbook, Subrecipient Small Project Certification Form, Procurement Policy, Pay Policy & Applicable Union Contracts. Large Project Documentation - equal to or exceed $131,100. Electronic Streamlined Project Application, MEMA Workbook, Procurement Policy, Pay Policy & Applicable Union Contracts, Force Account Labor, Force Account Equipment, Materials & Supplies, Contracts

What is Proof of Payment?

Providing proof of payment is a MEMA requirement. All proof of payment should be uploaded under the “Documents” tab for the project in FEMA Grants Portal.

Acceptable proof of payment documentation includes:
1) Copy of signed check and copy of the back showing that it cleared the bank, or
2) Copy of the bank statement showing that the check cleared, or
3) Copy of the Electronic Funds Transfer (EFT) transaction cleared the bank.

4)For government entities: Copy of their own payment/transaction report (e.g. MMARS or MUNIS) issued through a State Finance or State Treasury showing that payment has cleared.
 

What if I did not competitively procure a contract?

Per 2 CFR 200, any contract that for commodities or services that will be utilize federal funding, such as FEMA PA, must be competitively procured.

Per FEMA’s memo, Procurements Under Grants Conducted Under Emergency or Exigent Circumstances for COVID-19, “FEMA recognizes that noncompetitive procurements may be necessary to save lives, to protect property and public health, and to ensure public safety, as well as to lessen or avert the threat of a catastrophe.” Applicants are expected to upload a copy of its own procurement policy, as well as provide a justification on how commodities (such as medical equipment and PPE) and services (such as staff augmentation or cleaning services) were procured. If these contracts were procured non-competitively, MEMA will require an affirmation that the purchase falls under an exemption, such as the micro-purchase threshold or emergency exemption. Please see this template for MEMA Emergency Procurement Form .

What is the different between a “Work Completed” and a “Standard” Lane project?

There are two type of project options applicants can choose to submit via the Streamlined Project Application:

  1. Work Completed Lane: These are projects where all work/costs have been completed/incurred. For large work completed projects, applicants are expected to submit all source documentation, including proof of payment, in order to develop the project. Once a work completed project is obligated by FEMA, then MEMA will be able to pay out the entirety of the project.
  2. Standard Lane: These are projects where work has started or has not started, but includes estimated costs going into the future. The applicant is not expected to submit source documentation or proof of payment, since these costs have not yet been incurred. For these projects, the applicant submits an estimate of costs. Once the project is obligated, the costs are not paid out. Rather the applicant will work with their MEMA Project Coordinator to submit a request for reimbursement (RFR). The applicant must provide all of the above source documentation, proof of payment, and MEMA Workbook in order to get these funds paid.

What happens once I submit my project via Grants Portal?

Once a project is submitted, MEMA reviews the project to ensure a complete application. Often, a request for information will be generated by MEMA and delivered by the applicant’s MEMA Project Coordinator. The applicant must respond to the RFI will all requested information for MEMA to complete its review and submit the project to FEMA.

Once the application is submitted to FEMA, FEMA staff will review the application and will use the application to write a project with a scope and cost. If needed, FEMA will issue its own RFI to get additional information from the applicant. The applicant must respond to the RFI with all requested information for FEMA to complete project worksheet development.

How long will it take for my project to get obligated?

Unfortunately, there is no set timeline for project obligation. There are a lot of factors that play into a project timeline, such as project completeness, project volume, RFI responses, etc.

What happens if FEMA determines my costs to be ineligible? FEMA may review a project and find ineligible costs. FEMA may issue a determination memo denying all or part of an application.  An eligible applicant may appeal any determination previously made related to an application for or the provision of Federal assistance in accordance with the procedures outlined in 44 CFR 206.206. Applicants have an opportunity to appeal FEMA’s decision and request reconsideration within a 60-day time frame from receiving the FEMA determination. The applicant should notify its MEMA Program POC that it wishes to appeal as soon as possible so that MEMA may provide technical assistance. MEMA will review the appeal package and any additional documentation or justification for the ineligible costs and forward to FEMA for reconsideration.

Vaccinations

What costs for vaccinations are eligible for PA?

Local Governments may seek reimbursement for the following costs from FEMA PA related to its vaccination operation:

    • PPE;
    • Equipment (i.e. coolers, freezers);
    • Facility support costs;
    • Medical waste disposal;
    • Communications to disseminate public information regarding vaccinations;
    • Transportation & storage costs of vaccine;
    • Labor costs (overtime for in-house staff); and
    • See https://www.mass.gov/info-details/vaccine-cost-reimbursement for other possible costs and details.

What are the expectations/implications of insurance?

Local governments that are performing vaccinations, are not expected to collect and pursue information from individuals receiving vaccinations. However, if an entity does receive insurance proceeds from its vaccination sites, it is expected that the applicant report this in its FEMA application.

How do I develop my project for vaccination costs?

Vaccination projects should be developed in the FEMA Grants Portal via the Streamlined Project Application. Applicants are free to create “Work Completed” projects once vaccination activities are complete, or may create “Standard” Projects with estimates for vaccination activities. Note: if a “Standard” Project is submitted, payment will not be issued until there is a completed Request for Reimbursement after the project has been obligated.

Please title projects for vaccination costs as “Vaccination-[Applicant Name]”.

A template workbook for estimating Vaccine Administration Unit Costs is available on the MEMA website. Please see your MEMA Program POC with any questions.

Is there a limited time period for estimating future vaccination costs?

If an applicant chooses to create a “Standard” project with estimated costs, FEMA will only allow estimates to go into 90 days into the future. Please estimate your costs for 90 days of a mobilized vaccination site.

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