City EM follow up on PA questions

From: Poole, Jamie

Sent: Thu May 14 13:53:17 2020

Subject: City EM follow up on PA questions

Importance: Normal

Attachments: COVID-19 Purchase and Distribution of Food FP-104-010-03 (04.11.20).pdf; FW: [Localtribal-em] FW: RX Public Assistance COVID-19 FEMA DailyUpdate 5.14.2020;

City EMs,

Here are the PA question updates I read this morning during our meeting. I will include other updates for today in a separate email.

QUESTION: Some agencies have an increased cost for delivering meals because they are not being picked up like normal.

a. Can they put in for staff time if it is an increase from normal, although it is not overtime?

b. Can they put in for increased vehicle maintenance/fuel costs?

c. Can the put in for increased cost to prepare more meals than normal?

Julie’s Response:

FEMA Wrote”: Basically I can say without understanding the context of the word “agency” the response will be fairly general as PNPs have different criteria in what would be eligible, for instance an eligible PNP owns an ineligible facility, any work for that facility would be ineligible. We would also need to know a lot more about food delivery and the circumstances surrounding it (Policy Attached) particularly regarding the (1) legal responsibility, (2) indicators that may demonstrate the need to purchase and distribute food in response to the COVID-19 pandemic and (3) the populations in an impacted community that may need the provision of food as a lifesaving and life-sustaining commodity.

Attached is the Food Delivery Policy, can you justify the need based upon the criteria attached?

Jamie’s note:

Please also see attached email I forwarded today with updated clarification on purchase and distribution of food. In the email attached refers to local government more than private non-profit.

QUESTION: Many agencies are putting in touchless features in their restrooms to try to prevent spread of disease, can they include these costs for soap dispensers, paper towel dispensers, foot grabs, etc. Are these eligible costs?

QUESTION: Some agencies are adding barriers like you see in some grocery stores up in their public buildings. Are these costs eligible?

Julie’s Response:

Question #

Topic

Sub-Topic v2

Region

Questions

Answer for SharePoint

CAT B Eligibility

Disinfecting Facility

Is extra sanitizing / disinfecting / cleaning of City facilities because of COVID-19 by our custodial vendor would be eligible work under Category B.

• For eligible public and PNP facilities, costs associated with disinfecting the facility to eliminate or lessen an immediate threat to lives, public health, and safety are eligible. The work should be consistent with current public health guidance as it relates to disinfection recommendations. The following CDC guidance for disinfection is available online at:

o www.cdc.gov/coronavirus/2019-ncov/community/organizations/cleaning-disinfection.html for community facilities; and

o www.cdc.gov/coronavirus/2019-ncov/infection-control/control-recommendations.html for healthcare facilities.

• In cases where disinfection may appear to be an increased operating cost (e.g., cleaning and disinfection are a part of normal operating costs), funding may be eligible if:

o The facility provides services that are specifically related to eligible emergency actions to save lives or protect public health and safety or improved property;

o The costs are for a limited time based on the exigency of the circumstances; and

o The Applicant tracks and documents the additional costs.

Examples may include increased cleaning and disinfection costs in emergency, medical, and custodial care facilities treating patients infected with COVID-19.

• Policies on labor costs, purchase of supplies and equipment, and contracted services apply as with any other incident (e.g., costs must be reasonable and procurement requirements must be followed).

HI Jamie, There is no specific guidance so we’ll have to break it down with what guidance we have for now. The basis for eligibility is the activity has to be directly related to a public health officials order or guidance to protect life, health, safety and slow the response of the disease. This all appears to do so, however is it an emergency activity in response to COVID-19 ? I’ve included some of the requirements for disinfecting a facility above. So breaking it down, is the facility or activity ( restroom equipment/supplies)providing services that are specifically related to eligible emergency actions to save lives or protect health? FEMA may consider the touchless soap dispensers as an increased operating cost, I’ll check in with FEMA on this, they have been sending a lot of questions up to FEMA HQ. I do know that some PPE may be eligible, such as face masks, however, most agencies do not have face masks in their normal supplies, but do have restrooms with soap dispensers, so this leans me toward touchless soap dispensers being more of an increased operating cost.

Thank you,

Jamie Poole

Outreach and Technology Coordinator

Pronouns: she/her/hers

Clackamas County Disaster Management | 2200 Kaen Road, Oregon City, OR 97045

503-278-9150 (cell) | Jpoole@clackamas.us |www.clackamas.us/dm

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