For emergency protective measures to be eligible, the applicant is responsible for showing the work is required due to an immediate threat resulting from the declared incident. In response to COVID-19, FEMA may provide assistance for eligible emergency protective measures implemented for eligible medical care activities in accordance with its COVID-19 policies. The Applicant’s documentation does not demonstrate that the payments provided to its employees were incurred for medical care provided by the Applicant nor that the incurred costs were the tied to the performance of eligible work by the Applicant at its facility. Payment of employee healthcare and workers’ compensation claims is not an eligible emergency protective measure that is necessary to respond to an immediate threat to lives, public health, or safety.

The Applicant has not demonstrated that healthcare and workers’ compensation claims paid to its employees are eligible emergency protective measures necessary to save lives and protect public health and safety in response to the COVID-19 pandemic. Therefore, this appeal is denied.

Stafford Act § 403(a)(1). 44 C.F.R. §§ 206.221€(5), 206.223(a)(1), 206.225(a). PAPPG, at 19, 57. FP 104-21-003, at 4-5; FP 104-21-0004, at 3-4; FP 104-009-19, at 3-4. Fact Sheet, Eligible Emergency Protective Measures, at 1-2.