COST TRACKING AND DOCUMENTATION OF COVID-19 RESPONSE COSTS

Cost Tracking

EMERGENCY COVID-19 RESPONSE FIRST, BUT TRACK & DOCUMENT COSTS

CONSISTENT COST TRACKING AND DOCUMENTATION OF COVID-19 RESPONSE COSTS WILL MAKE A REIMBURSEMENT DIFFERENCE

 

Emergency responses and urgent public health responses are critical priorities. However, financial disaster recovery from the Covid-19 Pandemic response actions will become an essential budget issue in light of reducing tax revenues and increased demand for services.

Accounting Considerations -Tracking and Managing Coronavirus Recovery Costs

Recognizing the logistical and bureaucratic challenges this unprecedented response effort will bring, FEMA is actively working to develop a simplified application and funding process.

 

Your experience with the FEMA Public Assistance Covid-19 Simplified Grant Process will be materially less administratively painful with smoother quicker reimbursement of costs, IF YOU

  1. Accurately track and document all COVID-19 response expenditures

  2. Consistently use activity/cost codes for COVD19 on all purchases of material, labor, supplies, contracts, services, and equipment that are directly related to responding to the COVID-19 pandemic.

  3. ADD NEW COST CODES for operations accounting for payroll, materials/supplies, contracts, and purchasing order protocols regardless of the supporting technology, even if you must use Excel spreadsheets

 

FEMA Public Assistance program is a REIMBURSEMENT program.

 

Applicants for Public Assistance MUST TAKE IMMEDIATE PROACTIVE ACCOUNTING MEASURES

To help you proactively navigate the complex FEMA programs and track eligible costs incurred, the information available here is provided as a PUBLIC SERVICE so that you and your teams can better track Covid-19 disaster-related costs for financial recovery.

IMPORTANT – ONLY FEMA CAN MAKE ELIGIBILITY AND COST DETERMINATIONS

The current FEMA PA Policy & Procedures Guide provides information on emergency work for traditional natural disasters.

FEMA HQ will most likely provide Covid-19 Disaster Specific Guidance in near future

Other points to consider


1. Document Direction or Orders from Public Health Officials. Unlike typical FEMA declarations for storm damage, the pandemic nature of this disaster adds different requirements needed to substantiate costs. FEMA published guidance on March 19, 2020 indicating basic types of eligible emergency protective measures required by the COVID-19 response. In that guidance, FEMA stated that "eligible emergency protective measures taken to respond to the COVID-19 emergency at the direction or guidance of public health officials may be reimbursed under Category B of FEMA's Public Assistance program." Thus, before making significant expenditures with the expectation that FEMA will reimburse those costs, ensure the measures to be taken are at the written direction of a federal, state or local public health official and keep that written guidance with your procurement file. See more about this here.
2. Confirm the "Applicant" and LEGAL RESPONSIBILITY.   Due to the unique considerations and each governor's preferences, certain costs/work may be done by either the applicant or directly by the state through an agreement with the applicant. Understanding upfront who will be responsible for applying for assistance to FEMA will drive contracting standards, responsibilities, and even funding. FEMA is attempting to create and implement a new expedited reimbursement system, but it is a new process, FEMA is still weeks away from the Grants Portal and process being ready.
 
3. Track All Funding - Finance Department Involvement is Critical. FEMA strictly prohibits duplication of benefits. Applicants must be mindful and track all funding, including payments from HHS/CDC or State.  All costs and funding sources must be closely tracked. If other funding is available for FEMA-eligible services or costs, including costs to construct additional capacity, FEMA may adjust otherwise eligible reimbursements.
 
4. Document Escalation of Costs. There are reports across the country of supply and medical staff shortages causing higher than normal costs. When contracting, attempt to get as many quotes as possible from contractors and suppliers and keep detailed documentation of those attempts, and also document the reasons of the escalating costs of these healthcare workers. FEMA requires that cost be "reasonable" in order to qualify for reimbursement. A cost is reasonable if in its nature or amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the costs.
 
5. Track Volunteer and Donated Resources as Possible Credit for Non-Federal Share. When individuals and organizations donate resources to assist with response and recovery operations, the value of those donations may be used to offset the non-federal cost share. Applicants should keep detailed logs of all volunteer hours and donations and even consider appointing a donation and volunteer coordinator to keep a centralized repository. Considering the amount of detail FEMA requires, these documents need to be kept as contemporaneously as possible. The below must be documented:
      a)  The donated resource is from a third-party (a private entity or individual that is not a paid employee of the applicant or federal, state, territorial, or tribal government);
      b)  The donated resource is necessary and reasonable for the accomplishment of the project;
      c)  The applicant uses the resource in the performance of eligible work and within the respective project's period of performance; and
      d)  The applicant or volunteer organization tracks the resources and work performed, including description, specific locations, and hours.

6. Federal Procurement and Contracting Considerations. Contracts must include all federal requirements, terms, and provisions. This can be done when signing, or existing contracts may be modified to ensure compliance. This is a fundamental eligibility requirement to receive FEMA reimbursement. FEMA's Procurement Disaster Assistance Team website has more details on the requirements. Also, make sure to document the procurement process and the emergency conditions requiring the expenditure. Although it may seem obvious and unnecessary right now, many of these costs will be reviewed and audited months or years later without the current pressures.

View Procurement Resources Here

FOOT NOTES

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This website  is intended as a national source of information about the coronavirus (COVID-19) and the delivery of  financial recovery services. It includes resources on eligibility, procurement, grant management delivery, and issues related to various Federal Programs currently supporting Covid-19 financial recovery for governments and non-profits. This website is not affiliated or endorsed or sponsored  by  FEMA  or any other Federal grant program. The information provided in various webpage documents is derived largely from Federal  published materials. In general, under section 105 of the Copyright Act, such works are not entitled to domestic copyright protection under U.S. law and are therefore in the public domain.  The goal is to help navigate the various Federal websites and summarize grant information and requirements. It does not constitute legal advice or grant management advise and is provided for general informational purposes only. Only the Federal Agency responsible for grants can make determinations on eligibility and grant amounts. You should consult with your professional services advisors and State and Federal Grant Coordinators for more detailed guidance on specific Covid-19 financial recovery issues.

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