Article 13: Temporary Facilities & Operating Costs

(Category: costs-eligilbilty)

Article Summary

When the emergency medical delivery system within a declared area is destroyed, severely compromised, or overwhelmed, FEMA may fund extraordinary costs associated with providing temporary facilities for emergency medical care or expanding existing medical care capacity in response to the declared incident, such as establishing an Alternate Care Site (ACS). This funding is strictly limited to the short-term exigency of the circumstances where an immediate surge threat to public health and safety exists.

FEMA may provide assistance and approve funding for an initial 30 days from the date that the facility is operational as an immediate need. If additional time is needed, the Applicant should request FEMA re-assess before the end of the 30 days, and FEMA may grant another 30-day extension as warranted. Applicants must conduct a thorough cost analysis comparing renting, purchasing, or constructing a temporary space to justify that their selection is prudent and reasonable. Meticulous tracking is mandatory, requiring the facility name, exact operational dates, precise services provided, and detailed justifications for the surge in need. If an applicant purchases or constructs a temporary facility, they must report the equity to FEMA and return the federal share once the approved deadline has expired or when the facility is no longer needed. Furthermore, all temporary facilities must fully comply with the Americans with Disabilities Act (ADA) unless explicit non-applicability is clearly substantiated.

Five Key Takeaways for CTA FEMA Compliance

1. Monitor the 30-Day Operational Window: Track costs around the initial 30-day operational limit, and ensure you formally submit an extension request and justification to FEMA before this timeframe expires.
2. Attach a Comprehensive Cost Analysis: Submit a detailed cost analysis with your project application comparing rental, purchase, and construction options to justify that your temporary facility choice is the most economically prudent solution.
3. Reconcile and Return Federal Equity Share: If a temporary facility is purchased or built, establish an accounting mechanism to report the equity to FEMA when the deadline expires and return the federal share of the disposition proceeds.
4. Enforce Strict ADA Compliance Standards: Ensure all temporary structures or modified spaces are fully accessible and usable by disabled persons in accordance with the Americans with Disabilities Act, or explicitly describe why compliance is not applicable.
5. Isolate Eligible Surge Costs from General Care: Meticulously separate eligible temporary operating expenses (like generators or short-term medical contract labor) from ineligible long-term patient care, administrative activities, and routine non-surge expenses.

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