NCS must be at the direction of and documented through an official order signed by a public health official and approved by the appropriate FEMA Regional Administrator. The Applicant’s supporting documentation does not demonstrate that it provided sheltering services at the request of a public health official. Additionally, the Applicant did not demonstrate it obtained approval from FEMA for its NCS program as required by FEMA policy.

The Applicant did not demonstrate that providing sheltering services for students at two hotels met eligibility criteria under FEMA’s COVID-19 and PA policies for NCS. Consequently, the costs for a contracted security service used to monitor the students are not eligible. Therefore, this appeal is denied.

Stafford Act §§ 403, 502. 44 C.F.R. §§ 206.223(a)(1), 206.225(a). PAPPG, at 66. O&O Policy, at 4-5. FEMA Fact Sheet, Non-Congregate Sheltering. Non-Congregate Sheltering FAQ, at 1, 3. University of Pittsburgh, FEMA-4506-DR-PA, at 2.