TIPS FOR NON-PROFITS ON WHAT TO DO NOW
RE FEMA REIMBURSEMENT FOR NATURAL DISASTERS
September 3, 2021
FEMA makes available Public Assistance funds to reimburse eligible non-profits for costs associated with disasters that are not covered by insurance (including non-covered costs, deductibles, etc.).
ELIGIBLE NON-PROFITS (PNPs)
Non-profit organizations (501(c)3) that are eligible to apply for Public Assistance funds include those that provide critical services, such as education, utility, emergency or medical (including long-term care, outpatient, rehab, etc.).
Education includes primary or secondary schools, including parochial schools, and accredited institutions of higher education.
APPLYING FOR FUNDS
Look out for an announcement from FEMA or your local Office of Emergency Management over the coming weeks for the deadline to submit an initial form to begin this process. If you are not sure if you qualify, submit the form and FEMA will advise.
Costs eligible for reimbursement by FEMA may include:
• Pre-storm preparation (e.g. sandbags, protective measures, labor costs)
• Emergency work (temporary repairs and clean-up)
• Equipment (Rental, purchase, and use of existing equipment)
• Debris Removal (which includes tree cutting, removal, etc.)
• Permanent Repairs to Storm Damage
• Mold Remediation
• Consult FEMA’s PA guide for more information on eligible costs, especially as this can change.
DOCUMENT NOW TO ENSURE PAYMENT LATER – USEFUL TIPS
The following are informal tips from past experience with FEMA Public Assistance (PA) reimbursement requests. PA requests require considerable documentation that is difficult to reconstruct or gather later; during a chaotic situation, do your best to try to keep track of the following upfront, as it will be more difficult to apply for reimbursement without this documentation.
INVOICES AND RECEIPTS
• Keep invoices and receipts for everything that is purchased. This includes all payments to vendor and contractors, and for equipment, generators, supplies, gas, diesel, etc.
• If for some reason only part of the receipt is for storm-related clean-up, jot down the split on the receipt as soon you have it.
• Take photos of all damage to assist later in your FEMA claim.
• It is especially important to take photos of any damage that must be fixed immediately or trees that must be removed immediately.
• FEMA will reimburse for the use of equipment at a set hourly rate, if you can document when and how many hours the equipment was used. This includes new equipment purchased for the storm, as well as equipment previously owned by the nonprofit.
• Keep a log for each piece of equipment of how many hours it was used each day, and if possible by whom. Even informal logs can be used later to fill out the official forms.
• Please keep in mind that at times FEMA will reimburse for the purchase of the equipment, and at times will only reimburse for the hourly usage rate, even if the equipment was purchased specifically for storm clean-up. Don’t buy expensive equipment unless needed, as you may only receive an hourly rate from FEMA reimbursement.
• Generator use costs are sometimes, but not always, reimbursed. It is worthwhile to document in case reimbursement is made available.
• Keep a log for each generator of how many hours it was used each day, and in what location.
• Keep receipts for diesel purchased for the generator, and don’t forget to note the split if the whole purchase was not for this purpose.
• Keep rental receipts.
• For purchased generators, FEMA may reimburse only hours of usage for large, expensive generators, or may reimburse for purchase cost of smaller, low-cost generators.
CONTRACTORS AND PURCHASE OF GOODS – BID REQUIREMENTS
• FEMA requires that you follow your regular procurement process, and they will ask you to provide them with a copy of your procurement policy, if applicable.
• There are also government requirements that must be followed, regardless of your internal procurement process.
• For any good or service that costs over $3,500 up to $150,000, FEMA requires you to get 3 price quotes/bids. For any non-emergency work, do your best to get at least 3 bids from different contractors. (Please note that it is not allowable to split a project into artificial parts in order to stay under the bid threshold.)
• For large purchases over $150,000, consult with FEMA before proceeding, as this will require a more formal bidding process, sealed bids, etc.
Keep a daily time log for any workers who work on storm clean-up, including noting overtime hours. If workers split their time between storm and non-storm-related work, it is important to break out the storm-related work on the time log.
In some circumstances, FEMA will reimburse time worked to prepare for the storm, mitigate during the storm, and clean-up after the storm. For example, for workers hired specifically to deal with storm clean-up. In other instances, FEMA will only reimburse for overtime worked. This can be the case with regular employees of the organization doing non-emergency, post-storm clean-up work.
FEMA will also reimburse for Direct Administrative Cost (DAC) – i.e. time spent by staff preparing documentation for the FEMA claim; filling out forms; meeting with FEMA representatives or internally about how to prepare the claim. Staff working on claims should keep a log of the days and times that they worked on the reimbursement and related, so that you can claim reimbursement for this time.
If you hire contractors or employees to engage in debris removal and haul it away to a dump, instruct them to ask for load tickets at the landfill facility and to give you the load tickets, as FEMA may ask for them to prove that the debris removal was completed properly in a non-hazardous manner.
MOVING FORWARD – HAZARD MITIGATION
Once your organization has qualified as a PNP, this opens up possible additional opportunities to strengthen your facility against a future storm through Hazard Mitigation funded by FEMA.
• When completing FEMA-funded permanent repairs, these projects can include Hazard Mitigation measures to help protect the facility from future storm damage. (As opposed to just restoring the facility – make it better.)
• Eligible PNPs will also be eligible to apply for funding for Hazard Mitigation Projects such as purchasing and installing large generators, flood control, and other projects. Keep an eye out for announcement of availability of Hazard Mitigation funds and let your local Office of Emergency Management know that you have a project to propose for this funding - they can alert you when the process begins.
Printed with thanks so Beth Medrash Govoha, Department of Government Affairs for this informative sheet. BMG offers these informal tips and takes no legal responsibility for the accuracy of this information; it is based on lessons learned.
For more information, see FEMA’s Public Assistance Program and Policy Guide at https://www.fema.gov/sites/default/files/documents/fema_pappg-v4-updated-links_policy_6-1-2020.pdf