FEMA Public Assistance Program
On June 4, we sent a memo regarding RCAB’s participation in FEMA’s COVID-19 Public Assistance program. We now have more information and some clarification based on questions that many of you have raised. Since some of you may not have seen the initial memo, we will detail all of the information, both old and new, below.
What is the FEMA Public Assistance Program?
On March 23, FEMA announced that they would provide funding to eligible applicants for costs related to emergency protective measures conducted as a result of the COVID-19 pandemic. Emergency protective measures are activities conducted to address immediate threats to life, public health, and safety. Emergency protective measures include:
- Training staff and volunteers to mitigate the risk of COVID-19
- Disinfection of public facilities
- Purchase and distribution of personal protective equipment
- We do not at this time know if FEMA will reimburse for livestream equipment or sound systems used to conduct outdoor Masses. Please read more below.
What is the timeframe for expenses?
All eligible expenses will be reimbursed as long as they are incurred/paid within the incident period. At the time of this memo, the incident period in Massachusetts is March 27, 2020 through September 27, 2020. However, the Commonwealth and FEMA may likely extend this period as the COVID-19 crisis will be with us beyond September 27. Once we are made aware of an extension, we will let you know.
We will be filing for assistance as one Archdiocesan entity. We will submit all of our parish and school expenses under one umbrella, and once we receive funds from MEMA, we will distribute these funds directly back to the entities that applied.
The First Deadline is July 17 for expenses incurred through June 30
We will be submitting expenses in various stages. The first stage will cover expenses incurred between March 27, 2020 and June 30, 2020. Please submit these expenses to us by July 17, 2020 via our dedicated email: firstname.lastname@example.org (For questions, call 617-833-0811.)
The second phase will cover the timeframe of July 1, 2020 to August 31, 2020. We would ask that you submit your invoices to us by September 18 for this second phase. To recap:
- July 17: Due date to submit expenses incurred from March 27, 2020 – June 30, 2020
- September 18: Due date to submit expenses incurred from July 1, 2020 – August 31, 2020
What if I have an invoice but I am still waiting for the canceled check? Should I submit the invoice anyway?
Please only submit expenses if you have the proof of payment (canceled check or bank statement) to accompany the invoice. It is OK to submit expenses past the deadline – it simply means the expense will go into the next batch that will be processed.
Are the expenses for livestreaming Masses or audio equipment for outdoors Masses a reimbursement expense?
This is an unprecedented disaster and much of the policy is still being developed. We have not received any guidance on the eligibility of these types of expenses. Our best advice would be to capture these costs and provide the documentation in our claim to FEMA, who will make an eligibility determination. Additionally, we strongly suggest that parishes incur only the costs that are necessary to plan for or respond to the pandemic and continue their operations. We do not encourage parishes to spend funds on items that would be “nice to have” based on the belief that it would be reimbursed by FEMA. We will certainly submit all costs to FEMA for their consideration, provided they are COVID-19 related costs.
Do I need to send canceled checks?
A copy of the invoice and cancelled check would be best. However, if the cancelled check is unavailable, a copy of the original check with a copy of the bank statement showing that check has cleared is acceptable.
What is the reimbursement rate?
As of this time, we are told the rate will be 75%.
Volunteer labor can be used to perform tasks/services for which you would otherwise use employees or contract for the service. A reasonable value for that volunteer labor will be assigned based on a prevailing rate in the market. That value can then be used to offset the 25% cost share for other eligible expenses incurred, which effectively will increase the reimbursement received by the value of the volunteer labor. If your ushers are already volunteer positions, there is no market rate for those services. However, if you were to pay an employee or contract someone to maintain the registration system, then the value of that volunteer service could be captured and used to offset the cost share. To aid you in this process, download the Volunteer and Donated Resources Worksheet.
Where Do I Send Documentation?
Please send documentation to our office. We have set up a dedicated email for this purpose: email@example.com. Please call 617-833-0811 if you have any questions.
Individual parishes/ministries that have an accounting system should track COVID-related expenses on a parish/ministry level by setting up a “cost code” for COVID-19. Ideally, use your existing general ledger account structure, but separate the transactions into a COVID-19 department or code.
For QuickBooks Users:
Please create a subaccount “– 80 – FEMA Public Assistance Program COVID-19” within each applicable expense account (ex. 6309 Maintenance Buildings, 6201 Office/Cleaning Supplies etc.) to track direct costs associated with COVID-19.
For Intacct Users:
Please use project number “P-0000618 – FEMA Public Assistance Program COVID 19” to track direct costs associated with COVID-19.
Save and scan all documentation when incurring costs for COVID-19. This would include proposals, contracts, purchase orders, invoices, and checks for goods/services provided. Send documentation to us at firstname.lastname@example.org
Categories for Cost Tracking
Below is a list of categories for cost tracking. The aim is to account for all expenses that are not part of your normal operations or in excess of what would be normally required. Err on the side of caution and include all expenses that you feel meets that criteria:
- Staffing directly related to COVID-19 – any contract or volunteer labor for planning or responding to the disaster
- Personal Protective Equipment (PPE) & Supplies – all equipment, supplies and devices for the both parish personnel or those in the community
- Temporary facilities – establishing exterior facilities (including tents) to perform food/clothing/supply distribution or screening of those that may be infected
- Maintenance (contracted or volunteer) – cleaning, remediation, equipment, personnel and supplies, including sanitization of your public spaces. If utilizing volunteers, be sure to document their name, date of service, duties performed, and hours worked
- Facility Improvements – Construction of or conversion/enhancement of spaces to assist with COVID-19 response
Due to the SBA PPP loans, we are not considering employee labor at this time.
For those parishes who have already begun this process on their own, please continue with the process you have started. We only ask that you let us know that you are filing independently. Please inform us via email: email@example.com.
If you have any questions, please email us at firstname.lastname@example.org or call 617-833-0811.