The eligibility of premium pay costs is based on the applicant’s predisaster written labor policy, provided the policy meets certain FEMA criteria. The Applicant has not demonstrated it provided premium pay in accordance with a predisaster written labor policy in effect prior to the start of the incident period. In response to COVID-19, certain labor costs associated with medical staff providing treatment to COVID-19 patients may be eligible. The Applicant did not show costs for claimed work were tied to the treatment of COVID-19 patients as required under FEMA policy.

FEMA finds that the claimed premium pay costs were not provided under a labor policy that meets FEMA policy requirements, nor were the costs tied to eligible emergency work. Therefore, the 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, 133. Medical Care Policy, at 4. Osceola County, FEMA-4486-DR-FL, at 3; Attica Hospital District #1, FEMA-4504-DR-KS, at 3; The Valley Hospital, FEMA-4488-DR-NJ, at 2-3; Emory Healthcare, Inc. (GMP 697064), FEMA-4501-DR-GA, at 3 (Oct. 28, 2024).