Navigating Overtime and Compensatory Time Reimbursement with FEMA

FEMA reimburses applicants for eligible overtime and compensatory time costs incurred during disaster response and recovery efforts. Here's a breakdown of the key criteria for reimbursement based on your pre-disaster written labor policy:

Policy Requirements:

• No Funding Contingency: Your policy should not state that overtime or compensatory time is only paid if federal funding is available (after a Presidential declaration).  These costs should be eligible regardless of FEMA funding.
• Uniform Application:  The policy should apply consistently to all employees,  ensuring everyone receives overtime or compensatory time based on the same established criteria.
• Clear Activation Criteria:  The policy must have objective, pre-determined criteria for triggering overtime and compensatory time.  This could involve specific work hour thresholds or emergency situations.

Meeting these requirements allows FEMA to consider your overtime and compensatory time costs for reimbursement.

Documentation and Evaluation:

• Pre-Disaster Policy Documentation: Provide FEMA with a copy of your pre-disaster written labor policy to demonstrate compliance with the above criteria.
• Reasonableness and Necessity: FEMA will evaluate the claimed overtime and compensatory time hours based on:
  • Severity of the disaster event
  • Specific circumstances of the work performed
  • Employee's function and role in the response/recovery effort

Following these guidelines ensures your labor policy aligns with FEMA's requirements and strengthens your application for reimbursement of overtime and compensatory time costs.

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