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Hospital Financial Recovery in the Midst of a Prolonged Response

As outbreaks of COVID-19 occur across the country, hospitals and healthcare systems continue to respond with live-saving resources and heroic measures to treat and care for patients. The response to the pandemic has created significant financial challenges for hospitals and healthcare systems from the effects of COVID-19 testing, treatment, and care. In addition to the cost incurred for caring for COVID-19 patients, hospitals face a 54% drop in patient visits originally from the cancelation of non-emergency and elective procedures. Deferral of procedures is continuing with the fear that one will get infected with the highly transmissible virus simply by going to a hospital for care.  As a result, hospitals’ staggering losses in revenue are mounting. According to a new study by Strata Decision Technology, United States (U.S.) hospitals are losing an estimated $60.1 billion a month and facing a 114% increase in uninsured patients from individuals losing employer sponsored insurance.

Our team at Hagerty Consulting is working with hospitals, healthcare systems, and universities across the country to maximize federal and state short-term liquidity funding opportunities and long-term cost recovery. We craft custom cost recovery roadmaps by understanding the unique expenses incurred along with revenue lost to strategically apply the various state and federal programs available to meet the needs of each institution.

Available Federal Funding Opportunities

To help offset lost revenue and costs incurred for testing, treating, and caring for COVID-19 patients, the federal government allocated $175 billion in relief to hospitals. This funding has been allocated through the Health & Human Services (HHS) Provider Relief Fund (PRF) as follows:

 

In addition to the $175 billion in relief through the HHS PRF, hospitals are eligible to apply for funding through various other programs, with up to $616 billion in available funding through known allocations and funding streams.

Prospective Federal Funding Opportunities

The U.S. House of Representatives passed the Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act. The HEROES Act would provide an additional $100 billion appropriation for the PRF along with new provisions for unobligated PRF funding– originally allocated from the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Paycheck Protection Program and Healthcare Enhancement (PPPHCE) Act — can be distributed and utilized. Currently, the HEROES Act is being considered by the U.S. Senate. If enacted, the law will likely have much needed application-based distributions that will help healthcare providers not only with incurred eligible expenses from caring for COVID-19 patients, but also lost revenue.

On June 12, 2020, the U.S. House of Representatives also introduced the COVID-19 Hospital Forgiveness Act. This Act would facilitate loan forgiveness for hospitals and healthcare providers who applied for and received Medicare accelerated and advanced payments. Without the COVID-19 Hospital Forgiveness Act, the $40.4 billion total loan amount will begin to be repaid by providers who received loans. These payments would begin in August of 2020 through the offset of additional Medicare payments.

Hospitals are facing a severe economic crisis. Our team at Hagerty Consulting offers real-time guidance to navigate the complex and dynamic disaster recovery funding available,  including programs through the CARES Act, the Federal Emergency Management Agency (FEMA) Public Assistance (PA) Program, the Coronavirus Relief Fund (CRF), and other federal and state grants available to support recovery. Our diverse team of policy, healthcare, and financial management experts work with our hospital and healthcare system clients from start to finish in the complex application process to seek and maximize federal and state reimbursement for COVID-19 incurred costs and revenue loss. We emphasize timeliness and efficiency balanced with regulatory compliance to position organizations to capture eligible costs for reimbursement without experiencing de-obligation in the future.

The COVID-19 emergency is an unprecedented public health and economic challenge. The robust federal funding provided so far has been essential for hospitals to be able to continue to deliver much needed medical care. Going forward, additional federal funding will be necessary to properly outfit our public health infrastructure and prepare hospitals that are caring for the sickest of COVID-19 patients while advancing financial recovery in the midst of a prolonged emergency response.

 

Jeff Bokser is Hagerty Consulting’s Vice President of Healthcare Programs with strategic expertise in all aspects of healthcare operations, finance, crisis management, and recovery. Jeff has over 20 years of experience as a senior leader at NewYork-Presbyterian and Yale New Haven Health. He advanced performance and increased revenue in clinical and nonclinical settings and led innovation in daily operations and care delivery processes. Jeff is nationally recognized in the healthcare sector for his transformational leadership in the areas of emergency and crisis management; security and safety; pandemic and surge planning; and business continuity. Jeff was the system-level executive responsible for Emergency Medical Services, Emergency Management, Business Continuity, Crisis Management, Safety, Security, and Regulatory Compliance for the entire continuum of the NewYork-Presbyterian Hospital & Healthcare System enterprise. He served as Incident Commander guiding 40,000+ employees through numerous internal and external emergency response and recovery operations including Hurricane Sandy, Ebola, H1N1, and 9/11.

HUD Allocates Second Tranche of ESG Funding Under CARES Act

FRIDAY, JUNE 12, 2020 AS OF 4:00 PM EDT

On June 9, 2020, the United States (US) Department of Housing and Urban Development (HUD) announced the allocation of almost $3 billion in additional Emergency Solutions Grant (ESG-CV) funding appropriated by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). These funds, plus $1 billion previously allocated, are available to assist states, local governments, and territories in addressing the needs of individuals and families who are homeless or receiving homeless assistance as a result for the COVID-19 Pandemic. A complete discussion of HUD’s allocation process and amounts can be accessed at: Methodology for Round 2 Allocations of ESG CARES Act Funds.

Many ESG-CV grantees may have been expecting to receive three times the amount they received under the initial $1 billion allocation but, in allocating the $3 billion, HUD implemented the CARES Act directive to abandon the standard ESG allocation formula. The revised formula incorporates a wide range of relevant data points; such as unsheltered homeless populations, sheltered homeless populations, populations at risk of homelessness, and geographical areas with the greatest need, based on factors such as the risk of transmission of COVID-19, high numbers or rates of sheltered and unsheltered homeless, and economic and housing market conditions. 

Breno Assis : Unsplash

Why did Congress push HUD in this direction? As HUD noted in its summary, the long-existing ESG formula “only targets modestly well to homeless and has no targeting to places with high rates of unsheltered homeless. That is because the ESG formula is allocated using the CDBG formula … which only has a modest relationship to where homelessness needs are most severe.” Homeless advocates and, to a degree, HUD have long wanted to refocus the ESG allocation process, and the CARES Act appropriately provided the necessary flexibility for this supplemental funding. Whether this approach translates to future ESG funding is to be determined. 

Eligible ESG uses always include street outreach, emergency shelter, homeless prevention, rapid re-housing, and administration and data costs. The ESG language in the CARES Act opens the door to additional activities such as training on infectious disease prevention and mitigation, hazard pay for staff, and temporary emergency shelters without minimum use periods. HUD’s June 9th press release highlights the ability of grantees to provide hotel/motel vouchers for homeless families and individuals, as well as essential services including childcare, education services, employment assistance, outpatient health services, legal services, mental health services, substance abuse treatment services, and transportation. 

HUD is providing extensive technical assistance to ESG-CV grantees which can be accessed through www.HUDExchange.info. This first stop for any grantee should be the bi-weekly Daily Resource Digest, which provides a range of information from subject matter experts on best practices and lessons learned.

Concurrently, HUD has weekly online “office hours” on COVID-19 response issues for homeless assistance providers every Friday from 2:30 – 4:00 PM EDT. The office hours feature various federal agencies and their partners for a live question-and-answer session, with previous session recordings also available online.

For those grantees that need more hands-on help, there is always direct technical assistance (TA). HUD is likely to expand its direct TA offerings as the CARES Act permitted HUD to use $40 million of the ESG-CV appropriation for the purpose. We are likely to hear more about this in the future as existing efforts are expanded.

ESG-CV grantees should also be aware of various flexibilities already made available by HUD. A few key resources are:  

Expect HUD to maintain an aggressive posture in working with grantees and homeless services providers to deploy ESG-CV funds to ease impacts on families and households and to develop a strategy that integrates these funds alongside emergency assistance available through the Federal Emergency Management Agency’s (FEMA’s) Public Assistance (PA) Program. 

Stan Gimont is a Senior Advisor for Community Recovery with Hagerty. Stan joined Hagerty after 32 years of service with HUD. With Hagerty, Stan provides strategic advisory support focused on HUD Programs, housing issues, and long-term community recovery. From August 2016 through July 2019, Stan served as HUD’s Deputy Assistant Secretary for Grant Programs. In this role he provided management direction and oversight for all aspects of the Community Development Block Grant (CDBG) Program, including long-term disaster recovery (CDBG-DR), the HOME Investment Partnerships Program, the National Housing Trust Fund, as well as HUD’s environmental review responsibilities. From 2017 through 2019, his leadership helped to secure $40 billion in CDBG-DR funding in response to major disasters, such as hurricanes Harvey, Irma, and Maria. As Director of HUD’s Office of Block Grant Assistance from 2008-2016, Stan managed approximately $60 billion in federal funding to assist the nation’s communities in addressing housing, development, and disaster recovery needs. Among Stan’s notable achievements as Director is the implementation of the Neighborhood Stabilization Program in response to the 2008-2010 housing crisis, oversight of CDBG-DR funding for New Jersey and New York in response to Hurricane Sandy, and management of HUD’s National Disaster Resilience Competition in 2014-2015.

National Disaster Resilience Competition Grantees Seek Three Extra Years to Spend Awarded Funds – Why Extension is Good Public Policy

In 2014, the United States (US) Department of Housing and Urban Development (HUD) launched the National Disaster Resilience Competition (NDRC) and in early 2016 awarded almost $1 billion to 13 jurisdictions across the country to pursue the funded projects.

Last week, The New York Times ran an article describing the status of the NDRC projects; highlighting the fact that time is running out to complete these projects by September 30, 2022, the date on which the funds will expire.  This deadline was established in the 2013 legislation ( Public Law (P.L.) 113-2, enacted January 29, 2013) that appropriated the funding in response to Hurricane Sandy and other major disasters that occurred between 2011 and 2013.

John Middelkoop: UnSplash

The New York Times article reported that NRDC grantees are collectively seeking to extend the spending deadline for three years through September 30, 2025 and have brought this request to the attention of their congressional delegations.  While the deadline is still more than two years away, it would be beneficial from an implementation standpoint to resolve the funding uncertainty sooner rather than later.  As The New York Times article noted, grantees were operating on tight timelines before the COVID-19 pandemic, and the resulting disruption in contracting and construction efforts places completion of these projects in jeopardy given the limitation on availability of the Federal funds.

The $1 billion in funding for the NDRC came from Community Development Block Grant-Disaster Recovery (CDBG-DR) funding which, according to the 2013 legislation, had to be under contract (“obligated”) with grantees no later than September 30, 2017.  While the contract/obligation deadline was met, the “inside baseball” problem is that the language of the 2013 appropriation triggered a separate provision at 31 US Code (USC) 1552 which effectively requires that CDBG funds be expended within five years of the end of the obligation period, hence the September 30, 2022 deadline.

Congress can address the deadline by including any of several approaches in forthcoming appropriations legislation.  The cleanest option may be to amend the CDBG-DR language in the 2013 legislation by inserting after the “obligation” language a provision along the lines of “notwithstanding any other provision of law, these funds shall be available for expenditure through September 30, 2025.”  This approach gets the job done for NDRC and provides the additional benefit of extending the availability of regular CDBG-DR funds awarded for 2011-2013 disasters.

NDRC grantees have long known that there would be challenges in completing these activities by September 2022 given the late start of the NDRC effort vis a vis enactment of the 2013 legislation, the complicated nature of the projects, and the compounding effects of current economic and public health issues.  A few grantees have made good progress in expending NDRC funds, but even that minority will be hard pressed to fully execute their projects in the next 28 months.

Substantial planning has already been devoted to these projects, permitting and environmental review has occurred in many instances, and construction bidding and work is imminent. At a time when all levels of government seek ways to stimulate economic recovery in the wake of the pandemic-induced downturn, the effort to extend the availability of NDRC funds is good public policy. Congress should act on this request soon and provide the 13 state and local government NDRC grantees with the assurance that these projects will be seen through to completion.

Stan Gimont is is a Senior Advisor for Community Recovery with Hagerty. Stan joined Hagerty after 32 years of service with HUD. With Hagerty, Stan provides strategic advisory support focused on HUD Programs, housing issues, and long-term community recovery. From August 2016 through July 2019, Stan served as HUD’s Deputy Assistant Secretary for Grant Programs.  In this role he provided management direction and oversight for all aspects of the Community Development Block Grant (CDBG) Program, including long-term disaster recovery (CDBG-DR), the HOME Investment Partnerships Program, the National Housing Trust Fund, as well as HUD’s environmental review responsibilities. From 2017 through 2019, his leadership helped to secure $40 billion in CDBG-DR funding in response to major disasters, such as hurricanes Harvey, Irma, and Maria.  As Director of HUD’s Office of Block Grant Assistance from 2008-2016, Stan managed approximately $60 billion in federal funding to assist the nation’s communities in addressing housing, development, and disaster recovery needs. Among Stan’s notable achievements as Director is the implementation of the Neighborhood Stabilization Program in response to the 2008-2010 housing crisis, oversight of CDBG-DR funding for New Jersey and New York in response to Hurricane Sandy, and management of HUD’s National Disaster Resilience Competition in 2014-2015. 

Understanding FEMA’s Expanded Coverage for Medical Care During the COVID-19 Public Health Emergency

As the response to the COVID-19 pandemic continues to evolve, hospitals and healthcare providers across the country are facing unprecedented financial challenges in managing the triage, testing, and treatment of COVID-19 patients. For those looking to the Federal Emergency Management Agency (FEMA) for funding and support through the Public Assistance (PA) program, additional relief has been granted through the expansion and clarification of eligible costs related to the provision of medical care of suspected and confirmed cases of COVID-19.

Expanding coverage for COVID-19 Medical Care

Published on May 9th, 2020, FEMA’s expanded policy (FEMA Policy FP 104-010-04) on the eligibility of medical care is specific to the COVID-19 pandemic. The policy includes the following key changes for public and private non-profit healthcare applicants: 

  • Expanded eligible medical care activities to meet the reality of healthcare facilities providing COVID-19 care, including inpatient care.
    Historically, FEMA has limited the eligibility of costs related to medical care to emergencies only. This meant that once a patient was past triage and emergency care, additional costs associated with inpatient care were not eligible under the FEMA PA program. For many infected patients, or patients suspected of being infected, emergency room treatment is insufficient, and patients may require inpatient hospitalization and long-term care. This policy supersedes a previously issued FEMA fact sheet that described inpatient care for COVID-19 patients as ineligible (now removed from FEMA’s site). This is a significant expansion of eligibility under the FEMA PA program, but also brings with it additional requirements for healthcare and hospital applicants to track and document their costs.

Photo by Jair Lázaro: Source

  • Established cost reasonableness thresholds for medical care.
    FEMA will utilize pre-disaster Medicare rates as the basis to determine reasonable costs for eligible clinical care, so long as those costs are not duplicated by another source, such as patient or insurance payments.
  • Suspected COVID-19 patients, not just confirmed cases, included as eligible.
    In this policy, FEMA acknowledges that hospitals and healthcare providers are incurring costs for suspected COVID-19 patients, not just for confirmed cases. Therefore, costs associated with the triage and testing of COVID-19 suspected patients are also eligible.
  • Expanded the definition of primary healthcare facilities.
    FEMA’s definition of Primary Medical Facilities generally captures all pre-disaster, existing medical care facilities – hospitals, clinics, outpatient facilities – recognizing the distinct line between emergency, primary, secondary, and tertiary care have been blurred by COVID-19. The policy delineates primary care facilities from temporary facilities and alternate care facilities. Temporary facilities may be existing facilities retrofitted to meet COVID care needs, like changing an existing inpatient facility to a COVID-19 critical care unit, or they may be transforming a hospital parking lot to a testing facility using tents and temporary structures. Alternate care facilities are a specific type of temporary facility that transforms a non-medical facility, like a convention center or a school gymnasium, into a healthcare facility.
  • Clarified the eligibility of wraparound services, such as cleaning, security, and some operational expenses.
    In this expanded policy, FEMA recognizes that adequate treatment and control of the spread of COVID-19 within healthcare facilities goes beyond medical care – it requires cleaning and custodial services, laundry services, and public safety and security services, and limited administrative services. These wraparound services, consistent with the U.S. Department of Health and Human Services’ definition, are included in this policy as eligible costs, even for temporary and alternate care sites.

Limitations of the New Medical Care Policy

While the expansion of this policy will be critical for healthcare providers and communities recovering from the pandemic, there are some limitations and risks that applicants should continue to monitor:

  • Reliance on data and modeling to establish eligibility.
    FEMA reiterates throughout this policy that for costs to be determined necessary and reasonable – a cornerstone of the FEMA PA program – applicants will need to justify operations and costs through specific data. Whether that is through coordination with local public health officials, capturing local data, or use of predictive modeling, an applicant’s ability to forecast, document, and justify continuing their operations will be critical in advocating for eligibility under this new policy.
  • Complexity in navigating (and avoiding) duplication of benefits.
    Expansion of eligible activities under this policy brings additional funding sources to consider for duplication of benefits that are unusual to disaster recovery for healthcare providers. This includes not only patient insurance, billing, Medicaid and Medicare, but also funding from the Coronavirus Aid, Relief, and Economic Security (CARES) Act that covers similar response and recovery costs. As the public continues their outpouring of philanthropic support to healthcare providers, financial or material donations will have to be diligently tracked, too. While FEMA will be reviewing for duplication of benefits, the risk will fall on applicants to document and ensure that their FEMA claims are not covered by some other source.
  • Time limit on recovery activities.
    The policy identifies that eligible medical care costs are limited to those incurred within six months of the date of declaration or until the end of the public health emergency, whichever comes first. Additionally, FEMA determined that all damages must be identified within 60 days from the end of the public health emergency or from an applicant’s approved Request for PA, whichever comes later. While this timeline may be extended under standard FEMA PA procedures, applicants should monitor this timeline closely and ensure that they have strong evidentiary support should an extension be necessary.

The response to and recovery from the impacts of COVID-19 present many challenges, and the expansion of eligible costs under this policy has brought FEMA into a realm of work that they are less familiar with. With that, additional burden will be placed on applicants to prove that their actions and costs are necessary, reasonable, and prudent in the scope of their response to and recovery from COVID-19. Applicants will need to be strong advocates for themselves to ensure that this policy is applied consistently and appropriately. 

For hospitals and healthcare systems seeking to leverage federal funding opportunities, Hagerty can provide expert advice and assist your organization with short-term liquidity and long-term recovery funding guidance. To learn more about COVID-19 recovery funding opportunities and to learn more about Hagerty’s cost recovery practice, visit our Recovery Page.

 

Opportunity to Shape Regulations on Federal Awards

In January, the Office of Management and Budget (OMB) announced proposed changes to Title 2 of the Code of Federal Regulations (2 CFR).  Should these changes go into effect, the requirements will apply to disasters declared after their publication date.  The public comment period ends soon – this upcoming Monday, March 23, 2020.

The purpose of 2 CFR is to provide guidance for and uniformity of administrative requirements, cost principles, and audit requirements for almost all Federal awards.  While OMB proposed changes to 2 CFR Parts 25, 170 and 183, Part 200 is most applicable to disaster grant awards and has been the Hagerty team’s area of focus.

The Hagerty team is taking this opportunity to provide our comments to the OMB to help shape the final changes to the 2 CFR. After reviewing the prosed changes, our team has highlighted the changes we find most significant below:

(1) Closeout Requirements – 2 CFR §§ 200.343, 200.344

  • Requires Non-Federal entities (NFEs) to submit closeout reports and liquidate all financial obligations within 120 days of the period of performance end date (currently 90 days).
  • Requires Subrecipients to submit to the pass-through entity required closeout documentation no later than 90 days after the end date of the period of performance.
  • Encourages Federal awarding agencies to closeout all awards no later than one year after the period of performance ends and requires Federal awarding agencies to initiate closeout at such time if the NFE has not done so, and report to FAPIIS all NFEs not in compliance with the new timing requirements.
  • Allows Federal awarding agencies to make financial adjustments to a previously closed award.

(2) Preference in Contracting – 2 CFR § 200.321

  • Requires NFEs to provide a preference for the purchase, acquisition, or use of goods, products, or materials produced in the United States.
  • The Section currently requires NFEs to “take all necessary affirmative steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible” – commonly known as MBE, WBE, small businesses requirement.
  • The “domestic preference” requirements will replace, not supplement, the MBE, WBE, small business considerations requirement.

(3) Focus on Auditing Requirements – 2 CFR §§ 200.331, 200.513

  • Requires more stringent monitoring, overseeing, and reviewing by pass-through entities of all awards provided to Subrecipients.
  • Changes the criteria for determining which Federal agency is the “cognizant agency” for determining compliance and usage of indirect rate allocations.

(4) Prohibition on certain telecommunications and video surveillance services or equipment – 2 CFR § 200.216

  • Prohibits Federal award recipients from using government funds via grant, cooperative agreement, and loan to enter into contracts (or extend or renew contracts) with entities that use covered technology.

The Hagerty Team encourages our readers to consider reviewing the changes here and provide comments to the OMB. Comments can be submitted directly through federalregister.gov and tips for submitting effective comments has been provided by regulations.gov. All comments submitted become part of a public record and you can see other public comments as they are posted here. Let your voices or concerns be heard before the changes to the 2 CFR are finalized!

Hagerty Consulting is an emergency management consulting firm that helps our clients prepare for and recover from disasters. Established in 2001, Hagerty Consulting’s work includes some of the nation’s largest recovery and preparedness projects in more than 30 states, including 9/11, Hurricane Katrina, and Hurricane Sandy.  You can learn more about our disaster recovery practice here.

Opportunity to Shape New DRRA Policy on FEMA Building Codes Enforcement

 

Unsplash: Jens Behrmann

The Federal Emergency Management Agency (FEMA) has released the draft Recovery Policy on Building Code and Floodplain Management Administration and Enforcement, a document that, according to FEMA, “defines the framework and requirements for consistent and appropriate implementation [of Section 1206 of the Disaster Recovery Reform Act (DRRA)] through the PA Program.” This new policy may offer significant opportunities for state and local governments to improve resilience by providing federal funding for post-disaster code enforcement and code administration activities. FEMA has released the draft document for a 45-day public comment period, accepting comments until Friday, March 6, 2020.

For background, Congress passed the DRRA of 2018 on October 5, 2018 to change how the federal government supports disaster preparedness, response, and recovery and to work towards a more resilient future. The DRRA focuses on how to better incentivize and fund disaster resilience. This particular component of the DRRA, Section 1206, specifically amends sections 402 and 406 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act) to authorize FEMA to provide assistance to state, local, tribal, and territorial (SLTT) governments for building code and floodplain management ordinance administration and enforcement activities.

Overall, the draft policy is rather straightforward: FEMA can now pay for certain post-disaster code enforcement and administration activities within 180 days of the disaster declaration date. Unfortunately, 180 days is typically not long enough for most communities to adopt new and/or enforce codes in recovery projects. However, this timebound requirement comes from the DRRA, so FEMA cannot extend it. Eligible activities include but are not limited to: substantial damage inspections, permitting, and hiring new staff to implement adopted codes. Eligible costs will generally be obligated via a Category G permanent work project worksheet (PW) and will be funded at the permanent work cost-share applicable to the disaster. This opt-in policy will be retroactive to disasters declared on or after August 1, 2017.

The Hagerty Consulting, Inc. (Hagerty) Team is taking this opportunity to provide our feedback to FEMA to help shape the final policy. After review of the draft policy, our Team’s key takeaways include:

What We Like About the Draft Policy

  • Even if communities adopt updated codes after a disaster, FEMA can fund enforcement and administrative activities.[1] Still, it is unlikely that communities will be able to develop and adopt code updates within 180 days of a disaster.
  • Eligible activities extend beyond public facilities to include private and residential structures. This broad scope allows FEMA to support local building departments across the spectrum of post-disaster code enforcement and administration.

What We Think FEMA Should Revise in the New Policy

  • While the draft policy outlines dozens of eligible activities, it restricts FEMA funding to only overtime costs for existing, budgeted employees – the same restriction as Emergency Work under Public Assistance (PA). This part significantly undermines the benefit of the new draft policy. Further, it is inconsistent with FEMA’s position that eligible enforcement and administration activities under this policy are considered permanent work, to be captured on Category G PWs.  DRRA Section 1206 does not appear to strictly limit eligibility of budgeted employees. As such, FEMA should expand eligibility for straight and overtime regardless of local employee status.
    • Note: if communities hire new employees and/or contract out, all costs are eligible. This is in contrast to the limits for budgeted employees described above.
  • The draft policy is retroactive to disasters declared on or after August 1, 2017; however, the mechanism by which communities must opt in is needlessly time limited. FEMA should revise the opt-in requirements and proactively socialize this expanded assistance to ensure that all interested communities are aware of and can opt in if desired.

The Hagerty Team strongly encourages all past, current, and future FEMA PA recipients and sub-recipients to consider reviewing the draft of the Section 1206 policy and submitting comments to FEMA. Let your voices or concerns be heard before this new policy document is finalized and published! If you would like to submit comments to FEMA, you must do so by March 6, 2020 using this comment matrix and submitting to FEMA-Recovery-PA-Policy@fema.dhs.gov.

[1] This does not change the criteria for funding permanent work upgrades only for codes in effect at the time of the disaster pursuant to 44 CFR §206.226(d), or the recently published interim policy on Section 1235(b) on the DRRA. Check back with Disaster Discourse for a future post discussing Section 1235(b) Consensus-Based Codes, Specifications, and Standards.

Ari Renoni is a Deputy Director of Recovery Programs with Hagerty. He supports clients in New York, California, Puerto Rico, Florida, and elsewhere. Prior to Hagerty, Ari worked for the United Nations (UN) World Food Programme (WFP), the UN Children’s Fund (UNICEF), the Ministry of Education in Namibia, and for the Center for Policy Research at the Maxwell School of Citizenship and Public Affairs, Syracuse University. He lives in upstate NY with his wife and two children.