Required Documentation for a FEMA Public Assistance Claim

Last week Steven Weller and Lori Robinson addressed the following issues: Applying for Expense Reimbursement in Response to the Coronavirus Pandemic and FEMA Public Assistance Claims: What Costs are Potentially Reimbursable? Today, they address the documentation required by FEMA if your entity is submitting a Public Assistance claim for COVID-19 related expenses.

What Documentation is Necessary to Substantiate a Public Assistance Claim?

FEMA recommends that applicants document everything on which they spend time or funds related to COVID-19. FEMA has provided the following list of required documentation, which corresponds to the type of expenses incurred.

Labor Expenses – Documentation Required
• Proof of hourly or pay-period rate
• Fringe benefit rate calculations
• Timesheets
• Proof of payment
• Overtime and comp time policies
• Equipment logs identifying operator
• Operator timesheets
• Proof of equipment ownership
• Equipment rate calculations
• Work performed

Materials – Documentation Required
• Purchasing procedure policy
• Replenishment of inventory items
• List of materials used with pricing
• Invoices & Purchase Orders
• Proof of payment
• Where used
• Date used

Rental Equipment – Documentation Required
• Rental/Lease agreement
• Invoices
• Purchase Orders
• Proof of Payment
• Equipment use logs

Contracts for COVID-19 Related Responsive Efforts – Documentation Required
• Contract procurement policy
• Bid process
• Contracts
• Invoices/Purchase Orders
• Proof of payment
• Benefit Cost Analysis
• Change Orders
• Profit Negotiation
• 2 C.F.R. § 200.318 contract requirements
• Debarment verification