Frequently Asked Questions - FEMA Reporting (COVID-19)

FEMA Reporting (COVID-19)

In a FEMA webinar they mentioned a $3,300 expense limit - is this a single expense or group expense?

For example, if a face mask order is $3,300 per case would it qualify if it is a single PO?

Our understanding is that FEMA is talking about the aggregate cost. There is a minimum threshold before you can request reimbursement from FEMA but it is not per expense item. We will be able to group activities to meet this threshold.

The sub-category (Expense Sub-Activity) drop down menu is not showing the items, it just stays at "loading" mode.

Do not open the template in Google Sheets. Download the file into Excel. Additionally, you will need to select an Expense Activity before you Select a Sub-Activity. 

Are food spoilage costs and donated food eligible for reimbursement?

No food spoilage does not qualify as an emergency protective measure. Donated food also does not qualify.

For expenses that are not captured in the upcoming submission (January 20 - April 30), because they were not correctly coded with CF1/CF2 codes, are these expenses still eligible for FEMA reimbursement once we journal them to the correct chartstring?

Does the invoice/service date of a transaction need to be reported in the same GL month to make it eligible for reimbursement?

The CF1/CF2 codes are not a requirement for FEMA reimbursement. They were created internally to help up track these expenses. Expenses that have not been coded with the CF1/CF2 should be included in the submission if they are for qualified emergency protective work. The timing of the expense doesn't matter so long as there is an audit trail.

Are costs recorded when a PO is issued or when a product is received?

Costs are eligible for FEMA reimbursement when the material is received and paid for. Our costs are recorded to the ledger when the voucher is approved and journaled. Depending on when we submit our request for reimbursement, the actual receipt of and payment for the material may or may not have occurred. We will need to work with Procurement and Accounts Payable to review this on a case by case basis. For now, if the expense has been recorded in the ledger, please include it in your reporting.

Is equipment purchased for employees to work remotely eligible for FEMA reimbursement?

This may qualify under temporary relocation of essential services if the equipment was solely purchased as the result of the pandemic. We will collect the data and evaluate whether the cost is eligible or not. One thing to note is that FEMA does take into account any salvage value of the equipment when providing reimbursement.

Do we have an idea of what the future timeline for submissions will be?

The disaster end date has not been set. The incident period can go on for years. We will establish a  timeline for future submissions once we’ve completed the data collection for the first reporting period.

Does additional funding for internships qualify for FEMA reimbursement?

A number of our students lost internships as a result of COVID-19 and we provided them with additional internship funding. This funding was not supported by CARES Act funding. Does this additional funding qualify for FEMA reimbursement?

The costs reimbursable by FEMA are costs related to response and recovery from the emergency. Funding provided directly to students that were not paid as the result of emergency work does not qualify for reimbursement. If these students were specifically hired to facilitate remote learning these expenses may qualify under temporary relocation of essential services.

Should we track research expenses related to COVID-19 with a CF1 or CF2?

Yes, please track research related to COVID-19 with a CF1 or CF2 code.

Can the template data be pulled at any entity level?

The default is L3 and L4. You can change it when you run your Cal Answers report. But when you include it please run it at the L3 or L4.

Should we include lost revenue to recharge units in the FEMA template?

Lost revenue will not be covered by FEMA. However, it is advisable that the costs be reviewed to ensure that there are no eligible costs within the content of the revenue loss totals.

Are other costs associated with labor for online teaching eligible for FEMA reimbursement?

Not all labor qualifies for reimbursement under emergency work (category B). Typically, for existing employees only overtime labor is eligible for reimbursement from FEMA. Other pay may be eligible for part-time, reclassified and seasonal employees and employees hired specifically in response to the COVID-19 impacts. If your division has labor costs in one of the eligible activities, please let us know when you submit your report and we will follow-up with you.

If we hired faculty or GSIs to support online courses, could they qualify for FEMA reimbursement?

Yes, these costs may qualify under temporary relocation of essential service if these individuals were specifically hired to facilitate remote work. Base pay for temporary or reassigned employees qualifies if they are doing work within an eligible activity. We will need to work with HR to provide documentation that these employees were specifically hired as the result of the pandemic to perform this work and not hired in the normal course of our business.

Does admin leave qualify for FEMA reimbursement?

Administrative leave does not qualify for FEMA funding because the individual on leave is not doing work to protect from the virus. FEMA will only provide reimbursement for work related to emergency protective measures (category B). We are working with HR and Government Relations to understand other types of funding that may provide relief for eligible paid leave and FMLA based on specific eligibility criteria.

What is the period we are reporting on in the FEMA template?

We will limit the data for the first reporting to data recorded in the ledger from January 20 – April 30, 2020. Once we receive and analyze the data from January 20 – April 30, 2020, we will determine the next reporting period and intervals of reporting.

Because the reporting requirements for FEMA are so complex we are planning for a staggered collection of data. This will allow us to refine our approach, if needed, to ensure compliance. The Public Health Emergency for California was declared on March 22, 2020. The incident period for reporting eligible expenses related to the emergency is January 20, 2020, until it is declared over. We have 60 days from the declared end date to request reimbursement for all eligible expenses, but we can submit multiple applications/versions until the period closes.

As the COVID specific chartfields were not set up until mid-March, it may require units to work with their departments to identify COVID-19 related expenses in the ledger that are not specifically identified as such. Additionally, any expenses incurred in January will need to be reviewed to see if they fall within the review period.

Which activities are ineligible for FEMA reimbursement?

A complete list of known eligible and potentially eligible activities is included in the guidelines

Costs that are ineligible include: 

  • Costs that were covered by gifts 

  • Costs covered through CARES or other federal funds

Which activities are potentially eligible for FEMA reimbursement?

A complete list of known eligible and potentially eligible activities is included in the guidelines

The broad categories include:

  • Emergency operations (activities related to Emergency Operations Center)

  • Increased cleaning and sanitation

  • Purchases including PPE and sanitation supplies

  • Use of facilities as sheltering and/or hospital locations

For emergency protective measures, FEMA will only reimburse labor-related expenses for these eligible activities related to:

  • Overtime for regular and seasonal employees (non-exempt)

  • Regular and overtime for temporary or redirected employees

Should I include costs that might be covered by gifts in the FEMA reporting template?

Yes, you should include these costs in the Expense Reporting tab and any associated revenue in the Revenue Received_Fundraising tab. The Revenue Received_Fundraising tab also allows you to provide a narrative summary of any fundraising activities related to COVID-19 in the additional notes section and identify the associated expenses included in the Expense Reporting Template for which this funding has been used. We will review this revenue against the FEMA eligible requests to ensure that we are not duplicating requests for funding from more than one source as appropriate. We will also be working with University Development & Alumni Relations (UDAR) to track this funding.

How will the reimbursement be distributed if it is received?

How each unit is reimbursed is to be determined based on how we receive the funds from FEMA.