To be eligible, costs must be directly tied to the performance of eligible work and adequately documented. The Applicant provided the CLP payments to encourage employees to receive the COVID-19 vaccine. The CLP payments were thus unrelated to any potentially eligible work the employees performed. FEMA determines the eligibility of overtime, premium pay, and compensatory time costs based on the Applicant’s predisaster written labor policy. The CLP payments were not authorized in a written pay policy until September 2021, which was after the beginning of the incident period for the COVID-19 pandemic.

The Applicant’s CLP bonus payments were not tied to eligible emergency work and were not based on a predisaster pay policy. Therefore, this appeal is denied.

Stafford Act § 403(a)(3). 2 C.F.R. § 200.403(g). 44 C.F.R. § 206.225(a)(1). PAPPG, at 21, 23. Medical Care Policy, at 3-4. O&O Policy, at 3-5 The Valley Hospital, FEMA-4488-DR-NJ, at 3. Emory Healthcare, Inc. (GMP 697064), FEMA-4501-DR-GA, at 3.