Letter to FEMA Regarding COVID-19 Reimbursable Expenses

August 25, 2020

The Honorable Pete Gaynor
Federal Emergency Management Agency
500 C Street S.W.
Washington, D.C. 20472

Dear Administrator Gaynor:

We write to you on behalf of our collective organizations to express  concern over recent communications from the Federal Emergency Management Agency (FEMA) indicating the agency intends to eliminate personal protective equipment (PPE) and disinfectants as eligible reimbursable expenses under Public Assistance for COVID-19.

We also understand that FEMA may seek to tie eligibility to an arbitrary distinction between “response” and “reopening.” This proposed change to PPE coverage continues a troubling pattern of shifting costs and responsibilities onto states and localities when they can least afford it. We hope the decision to shift the cost of providing PPE to states and localities is not due to the recent strain on the Disaster Relief Fund by the Lost Wages Assistance program.

PPE is a fundamental need for all COVID-19 related operations and is the definition of an “emergency protective measure.” Shifting policy guidance in the middle of a pandemic is impractical, causes confusion, and disrupts operations in states and localities. It also imposes significant bureaucratic and administrative burdens on states during the auditing process at a time when state and local resources are critically strained.

FEMA and the Administration have long maintained that every disaster is federally supported, state managed, and locally executed. We maintain our long-standing request that FEMA waive the state cost share for COVID-19 assistance which has not been addressed, rather the opposite. We call on FEMA to keep its current guidance on emergency protective measures, and encourage the Administration to provide clear guidance on eligibility of funding streams from across the federal government.


National Governors Association
International City/County Management Association
National Association of Counties
National Conference of State Legislatures
National Emergency Management Association
National League of Cities
The Council of State Governments
The United States Conference of Mayors