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COVID 19 FEMA Public Assistance Interim Policy DR- 4488The recently released (Sept 1, 2020) FEMA Interim Policy on COVID 19 (FP104-009-19) applies to work “performed” on or after the date of September 15, 2020Note: Work Completed “before” the date of September 15, 2020 is supported by the prior interpretation of FEMA Region 2 HQ of said COVID 19 Policy, regardless of the project submittal date. FEMA Region 2 maintains that for “completed work” it will apply the Initial Eligibility Guidance specific to Emergency Protective Measures taken to protect Public Health and Safety. * If a single project submittal contains work performed in “both time periods”, the Applicant must document those costs separately.January 20, 2020 through September 14, 2020September 15, 2020 to present day and beyond** There has been significant concern as to the FEMA Disaster Assistance versus other Federal agency funding sources. Over the past several months, federal funds were provided specifically to School Districts. More funds are unpredictable considering this unprecedented disaster event.Example: ESSER = Elementary and Secondary Educational Emergency Relief GEER = Governor’s Emergency Education Relief *** Since June 9 2020, FEMA and NJ OEM expressed items that were NOT Eligible: Alterations or Modifications to a facility, such as, auto sensor sinks, toilets, hand driers, conversion from water fountains to water bottle fill stations, Protective Shield installation to isolate office employees at Main Desk/ Counters, Automated Thermal scanners, including non-contact thermometers, permanent installation of UV Lighting, and Plexi-Glass Shields. Per Initial FEMA Region 2 Guidance:Purchase of Material / Cleaning Supplies needed to directly combat COVID 19.PPE for “Only Staff and Faculty” of the facility It is the responsibility of the facility to provide PPE to protect its staff and faculty … not the public or students. Permanent employee OT performing work to disinfect the facility in compliance to and related to COVID 19.Also Temp / part time employee hourly rates for “all” hours worked performing work directly related to COVID 19 Emergency Protective Measures i.e., Cleaning, disinfecting, security.Contractor Cost to disinfect if it is the selected method. (Ensure reasonable cost and not a debarred vendor)Note all disinfecting needs to be considered for frequency, duration and reasonable costSecurity materials for facilities to ensure directly related COVID 19 compliance as to non - congregating and use of facilities, such as rec equipment and grounds. i.e., temporary fencing, Warning tape, barricades. NOTE: These materials cannot include securing buildings from theft or vandalism. Security personnel (Some hours in some locations) to ensure directly related COVID 19 compliance to non- congregating and use of facilities. NOTE: These hours cannot include securing buildings from theft or vandalism.Important Note: For any costs incurred per the “FEMA Region 2 Initial Guidance” please do provide a written justification and documentation identifying the purchase a/o service procured due to “Initial” expressed policy. This will aide in the FEMA reviewer process, thereby eliminating the FEMA reviewer questioning the claim for reimbursement. Coronavirus Relief Fund (CRF) VS. FEMA Submittal of Project ApplicationThe recent CoronaVirus Relief Fund (CRF) versus FEMA reimbursement of expenses is a decision being made by each individual Local government a/o organization.? NJ OEM does realize this latest CRF funding via the Governor's Office has people guessing what sequence to follow.?I must express to everyone, to please do what seems most reasonable for your circumstance.? Also remember, that the CRF does fund 100% of your costs, whereby FEMA typically provides the Federal Share of 75% per the Stafford Act, thereby leaving the Applicant with a 25% Local cost share. Also recognize, there is a deadline of December 10, 2020 to apply for the?Governor's CRF...?In comparison, at this moment in time, there is No deadline on FEMA applications for reimbursement. However, the State does anticipate that FEMA may present a deadline to apply for COVID 19 expenses very soon. This project application will need to be performed via the FEMA Grants Portal Streamlined Application Process. The deadline to submit a project for reimbursement may be determined and imposed by FEMA upon the State during December 2020 or January 2021, although the State has not been given a definitive date at this time.?Important To Note:??You may Not claim the same incurred costs for both CRF and FEMA fundsFEMA might deny some of your requested incurred costs, whereby the Gov's CRF allows for more recognition and eligibility of incurred expenses reimbursed at 100%If you apply to FEMA first, via the FEMA Grants Portal Streamlined Application Process ...? you “may Not” receive notice of what expenses on your project are denied by FEMA “prior to” the CRF December 2020 deadline and therefore lose out on your CRF opportunity.Joseph Bryski - NJ OEM Public Assistance Unit Supervisor ................
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