FEMA Issues New Eligibility Rules for COVID-19 Assistance

Throughout the COVID-19 pandemic, assistance for certain healthcare and nonprofit organizations has been available through the FEMA Public Assistance Program. Eligibility is determined by type of applicant, facility, work and costs.

FEMA has now released an interim policy to further define the framework for eligibility. This additional guidance will apply only to work performed on or after September 15, 2020.

Under the interim policy, eligible work must be:

  • The legal responsibility of the applicant (e.g., a private organization cannot apply for relief based on work performed for SLTT governments.)
  • Required as a direct result of the COVID-19 emergency
  • Performed at a “reasonable” cost in nature and amount
  • One of the following emergency protective measures: medical care; purchase and distribution of food; non-congregate medical sheltering; operation of Emergency Operations Centers; communications to disseminate public information regarding health and safety measures or risks and hazards; mass casualty management; purchase and distribution of PPE for healthcare workers, infected patients and first responders*

*Other activities, such as temperature scanning, disinfection, installation of physical barriers, law enforcement and training, may be considered for assistance if they are required to perform the eligible work listed above.

Applying to Multiple Funding Sources
The interim policy also clarifies that FEMA applicants whose work is eligible for other federal relief may apply to more than one program concurrently. The agencies are coordinating closely and will expend funds from the most appropriate source. Under no circumstances can two federal agencies pay an applicant for the same work.

Application Deadline
FEMA also announced it has extended the application deadline beyond the normal six months from date of emergency declaration. A new deadline will be announced at least 30 days prior to the deadline date.

For more information on determining your eligibility for FEMA assistance or tracking and documenting your eligible costs, please contact your Grassi Nonprofit, Healthcare or Grant Compliance advisor, or contact our Crisis Response & Recovery hotline at 212.223.6216 or response@grassicpas.com.


David M. Rottkamp David M. Rottkamp, CPA, is an Audit Partner, Nonprofit Practice Leader, at Grassi. David has over 34 years of experience providing audit and advisory services to the nonprofit and health care industries.  David focuses on organizations serving individuals with special needs, religious organizations, educational institutions, membership associations, social service providers, healthcare providers, foundations, and the arts and culture world. David’s technical knowledge allows him... Read full bio

Joseph Tomaino Joseph Tomaino is the Chief Executive Officer of Grassi Healthcare Advisors, LLC and has nearly 40 years of healthcare management experience working in the nonprofit, for-profit and government-sponsored segments. As a chief executive officer, chief nursing officer, consultant, and educator, Joseph has worked with provider organizations and payers across the U.S. as an architect of value based care -- improving clinical effectiveness along with... Read full bio