For emergency protective measures to be eligible, the applicant is responsible for showing the work is required due to an immediate threat resulting from the declared incident. In response to COVID-19, FEMA may provide assistance for eligible emergency protective measures implemented for eligible medical care activities in accordance with its COVID-19 policies. The Applicant has not demonstrated that the payments provided to its employees were incurred for medical care provided by the Applicant nor that the incurred costs were tied to the performance of eligible work. Workers’ compensation claims and related administrative costs are not an eligible emergency protective measure necessary to respond to an immediate threat to lives, public health, or safety.

FEMA finds that the Applicant has not demonstrated that the reimbursement of medical costs, lost wages paid to its employees, and associated administrative costs are eligible emergency protective measures necessary to save lives and protect public health and safety in response to the COVID-19 pandemic. Therefore, the appeal is denied.

Stafford Act § 403(a). 44 C.F.R. §§ 206.223(a), 206.221(e)(5), 206.225(a). PAPPG, at 19, 57, 133. Eligible Emergency Protective Measures; COVID-19 Interim Policy, at 3; O&O Policy; Medical Care Policy, at 2. Franciscan Alliance, Inc., FEMA-4489-DR-IL, at 2.