Labor costs associated with medical staff providing treatment to COVID-19 patients may be eligible. For primary medical care facilities, increased operating costs for administrative activities are not eligible. The labor costs are associated with administrative duties including reviewing CDC recommendations, presenting best practices, and developing safe and reasonable use guidelines. As these are not directly tied to medical staff providing treatment to COVID-19 patients, they are not eligible for PA under the applicable FEMA COVID-19 medical care policy.

The Applicant has not demonstrated the requested labor costs are directly tied to the treatment of COVID-19 patients, rather than ineligible increased operating costs for administrative activities. Therefore, this appeal is denied.

Stafford Act §403(a)(3). 44 C.F.R. §§ 206.223(a)(1), 206.225(a), 206.225 (a)(3)(i). PAPPG, at 19, 21, 57. FP 104-21-0004, at 3-4.