WELCOME BACK TO DISASTER DISCOURSE QUARTERLY!
Each quarter, we feature thought-leadership from one of Hagerty’s Executives on timely emergency management topics. This quarter, our Senior Advisor for Community Recovery, Stan Gimont, discusses the Biden Administration’s emphasis on equity associated with the ongoing COVID-19 response, recovery, and vaccination missions across America. In this piece, he highlights the importance of equity and how jurisdictions receiving federal funding should be documenting their actions and reporting accordingly to comply with these increased requirements to reduce risk of future funding recoupments.
Understanding the Importance of Equity: Reporting Requirements for Federal COVID-19 Assistance
July 13th, 2021 | By: Stan Gimont, Senior Advisor for Community Recovery
The first trend relates to long-standing concerns about the effectiveness of federal disaster recovery assistance in reaching segments of the public that have the fewest resources to recover from disaster impacts. The unevenness of benefit associated with various programs administered by the Federal Emergency Management Agency (FEMA) has been well documented over the years by various news articles, independent reports, and internal FEMA reviews. A fresh example is a Washington Post article (July 11, 2021) that outlines how a lack of clear legal title to property creates a hurdle to FEMA providing post-disaster assistance to Black households across the South. Problems of this nature are among the reasons that FEMA’s National Advisory Council highlighted equity as a major focus in its November 2020 report to the FEMA Administrator.
These concerns have come into greater focus over the past sixteen months as the nation has worked to meet the health and economic challenges arising from the COVID-19 pandemic. In drafting multiple appropriations acts since March 2020, Congress has taken several approaches to ensuring more targeting of assistance to the most vulnerable segments of society. These actions have taken various forms, such as “phase outs” of stimulus assistance for households above certain income thresholds and directing emergency rental assistance to households at or below 80 percent of area median income (AMI).
Concurrently, Congress began to specify reporting requirements for some COVID-19 response programs to better understand who will benefit from the assistance. A good example is the Emergency Rental Assistance Program (ERAP) enacted in late December 2020. This program directed the Treasury Department to collect income data for households to determine how much funding was provided to households at various income levels: below 30 percent AMI, between 30 and 50 percent AMI, and between 50 and 80 percent AMI. Treasury was also required to separate the income data based on gender, race, and ethnicity, to provide a clearer picture of where recovery dollars were going and who they were helping.
A second trend is the expressed intention of the Biden Administration to focus on equity as a key policy pillar, especially as it relates to ongoing COVID-19 pandemic response efforts. Overall, the Administration’s goal is to provide equitable allocation of COVID-19 resources and relief funds, effective outreach and communication to underserved and minority populations, and improve cultural proficiency within the federal government. These goals are evidenced by the issuance of Executive Order (EO) 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government. Issued January 20, 2021, this EO sets a framework for all federal agencies by stating that “Federal Government should pursue a comprehensive approach to advancing equity for all, including people of color and others who have been historically underserved, marginalized, and adversely affected by persistent poverty and inequality.” Another EO, Ensuring an Equitable Pandemic Response and Recovery, was issued the following day and zeroed in on data by stating that “[T]he lack of complete data, disaggregated by race and ethnicity, on COVID-19 infection, hospitalization, and mortality rates, as well as underlying health and social vulnerabilities, has further hampered efforts to ensure an equitable pandemic response.”
Taken together, these EOs lay out a series of directives to federal agencies and thereby set a standard not only for COVID-related relief but all federal programs through at least 2024. FEMA is already moving to respond to this guidance as witnessed by its recitation of how equity was prioritized in its actions during the first 100 days of the Biden Administration, including deploying 11 mobile vaccination units as well as disability integration specialists and civil rights advisors to help serve hard-to-reach and underserved communities.
The regulatory basis for the enhanced COVID-related data collection is rooted in 2 CFR 200, the Uniform Administrative Requirements for Federal Awards, as issued by the Office of Management and Budget (OMB) as amplified by a March 19, 2021, OMB Memorandum that addresses implementation of the American Rescue Plan (ARP) Act. The March 19 memo includes an appendix that lists steps agencies must take (to the extent permitted by law) to achieve “more equity-oriented results for financial assistance.” These concepts are collectively reflected in the Treasury Department’s Compliance and Reporting Guidance for Fiscal Recovery Funds issued on June 24, 2021.
The third trend to be recognized is the continued movement over the past decade toward evidence-based decision making. In 2018, Congress enacted the Foundations for Evidence-Based Policymaking Act which emphasizes “collaboration and coordination to advance data and evidence-building functions in the federal government by statutorily mandating federal evidence-building activities, open government data, and confidential information protection and statistical efficiency.” President Biden built upon this legislation by issuing a memorandum on January 27, 2021 directing federal agencies to “ensure that the scientific-integrity policies of their agencies consider, supplement, and support their plans for forming evidence-based policies, including the evidence-building plans …”. The overall goal is for federal agencies to collect data on federally funded actions to inform future policy decisions. Viewed through this lens, recipients of federal funding should be prepared to collect and provide a wide range of information on the implementation and impacts of programs administered at the state and local level.
The Way Forward
The massive federal fiscal response to the COVID-19 crisis combined with these three trends is already heightening the attention on data collection and reporting. The Administration’s integration of reporting requirements into pandemic response compliance standards is intended to provide a strong impetus for recipients to be active participants in this effort with the collateral goal of addressing recovery inequities past, present and future. In broader terms, recipients should be prepared for these enhanced programmatic data requests across the spectrum of federal assistance as part of an effort to ensure that equity is a key consideration in program design decisions at the state and local level. A thorough understanding of the Biden Administration’s direction on equity in combination with efforts to accommodate these data expectations will be key to avoiding expensive “after the fact” data collection efforts or non-compliance determinations.
Stan Gimont is a Senior Advisor for Community Recovery with Hagerty. Stan joined Hagerty after 32 years of service with the United States (US) Department of Housing and Urban Development (HUD) including serving as HUD’s Deputy Assistant Secretary for Grant Programs. With Hagerty, Stan provides strategic advisory support focused on HUD Programs, housing issues, and long-term community recovery. Read More
Top Stories this Month
The COVID-19 Pandemic and vaccine distribution…
The US has reported more than 33.67 million people have been infected with COVID-19; while more than 607,000 Americans have died from the virus. To date, over 67.7% of the adult US population have been vaccinated either partially or fully as the highly-transmissible Delta variant continues to spread across the country at a rapid pace.
Recovery effort for Champlain Towers South Condominium continue, with assistance from local, federal sources…
At 1:30 a.m. Eastern Daylight Time (EDT) on Thursday, June 24, the Champlain Towers South condominium, a 12-story building located in Surfside, Florida, partially collapsed with a section of units detaching and falling. Emergency crews were onsite within minutes. Recovery efforts are still taking place, 90 fatalities have now been recorded and an additional 31 people remain unaccounted for.
Wildfires spread across western us while temperatures continue to climb…
Wildfires continue to spread across 12 states. The National Interagency Fire Center (NIFC) reported 58 large fires active in mostly the western US. Interior Secretary Deb Haaland testified before the House Natural Resources Committee on Wednesday June 23, cautioning that the western US could experience “fire years” instead of fire seasons as dry conditions become the new normal for that part of the country, according to The Hill.
Public Health Informatics & Technology (PHIT) Workforce Development Program
This funding opportunity is for public health informatics, which is defined as the effective use of information and information technology to improve population health outcomes. The goal of PHIT is to train at least 4,000 individuals in public health informatics and technology to expand the nation’s public health workforce. The program will prioritize recruiting underrepresented minorities from historically black colleges and universities (HBCU), Tribal Colleges and Universities (TCU), Hispanic Serving Institutions (HSI), Asian American and Native American Pacific Islander Serving Institutions (AANAPISI), and minority serving institutions (MSI).
- Funding Opportunity Number: ARP-PHIT-21-001
- Source: Department of Health and Human Services (HHS) – Office of the National Coordinator
Estimated Total Program Funding: N/A
- Award Ceiling: $10,000,000
- Closing Date: August 11, 2021
- Eligible Applicants: Accredited colleges and universities with terminal degrees in the US.
Emergency Connectivity Fund (ECF)
The ECF is designed to provide funding for schools and libraries for financial support to purchase laptops and tablets, Wi-Fi hotspots, modems, routers, and broadband connections for off-campus use by students, school staff, and library patrons. Eligible schools and libraries can submit requests for funding to purchase equipment and services for the 2021-2022 school year. Learn More
- Funding Opportunity Number: N/A
- Source: Federal Communications Commission (FCC)
- Estimated Total Program Funding: $7,170,000,000
- Award Ceiling: N/A
- Closing Date: August 13, 2021
- Eligible Applicants: Schools and Libraries
Workplace Safety and Health Training on Infectious Diseases, Including COVID-19
This funding opportunity offers eligible entities funding to develop and conduct training and educational programs and small business employers and workers on the recognition, avoidance, and prevention of occupational safety and health hazards in their workplaces, and to inform workers of their rights and employers of their responsibilities. Learn More
- Funding Opportunity Number: SHTG-FY-21-05
- Source: Department of Labor (DOL) – Occupational Safety and Health Administration (OSHA)
- Estimated Total Program Funding: $10,000,000
- Award Ceiling: $200,000
- Closing Date: July 26, 2021
- Eligible Applicants: Non-profit organizations, including labor unions, community-based and faith-based organizations, employer organizations that are not an agency of the government, institutions of higher education supported by governments, and Indian or Native tribes and organizations.
Coronavirus Economic Relief for Transportation Services
This funding opportunity is to provide grants to eligible transportation service providers that have experienced annual revenue losses of 25 percent or more as a direct or indirect result of COVID-19. The priority use of grant funds must be for payroll costs, though grants may be used for operating expenses and the repayment of debt accrued to maintain payroll. Applications can be submitted through the Treasury application portal here. Learn More
- Funding Opportunity Number: TREAS-CERTS-2021
- Source: Department of Treasury (USDT)
- Estimated Total Program Funding: $2,000,000,000
- Award Ceiling: N/A
- Closing Date: July 19, 2021
- Eligible Applicants: Private sector transportation service providers, including Motorcoach, school bus, passenger vessel, and pilotage vessel.
Community Services Block Grant (CSBG) CARES Act Rapid-Cycle Impact Projects
The CSBG is to provide funding for eligible entities to implement community-based projects focused on priority areas to be specified by HHS. Examples include coordination with public health and emergency management to address urgent health and social outcomes for low-income areas, adapting service delivery to a physical distancing environment, making structural reforms to reinvent the safety net, innovations in supports for families impacted by school changes and childcare services, and identifying and training high demand jobs in the post COVID-19 economy. Learn More
- Funding Opportunity Number: HHS-2021-ACF-OCS-ET-1959
- Source: HHS – Administration for Children and Families (ACF) – Office of Community Services (OCS)
Estimated Total Program Funding: $3,850,000
- Award Ceiling: $250,000
- Closing Date: July 26, 2021
- Eligible Applicants: Non-profits that do and do not have a 501(c)(3) status with the Internal Revenue Service (IRS), other than institutions of higher education, and faith-based and community-based organizations.
Tribal Broadband Connectivity Program
This grant is to be used to provide funding to eligible entities to expand access to and adoption of (1) broadband service on Tribal Land, or (2) for programs that promote the use of broadband to access remote learning, telework, or telehealth resources during the COVID-19 pandemic. Learn More
- Funding Opportunity Number: NTIA-TBC-TBCPO-2021-
Source: Department of Commerce (DOC)
- Estimated Total Program Funding: $980,000,000
- Award Ceiling: $50,000,000
- Closing Date: September 1, 2021
- Eligible Applicants: Tribal governments, tribal colleges and universities, tribal organizations, and native organizations such as Native Hawaiian Community, and Alaska Native Corporation.
Fiscal Year (FY) 2021 Regional Catastrophic Preparedness Grant Program (RCPGP)
The FY 2021 Regional Catastrophic Preparedness Grant Program (RCPGP) provides funding to close known capability gaps, encourages innovative regional solutions to issues related to catastrophic incidents, and builds on existing regional preparedness efforts. The purpose of the RCPGP is to build regional capacity to manage catastrophic incidents by improving and expanding collaboration for catastrophic incident preparedness. The National Response Framework (NRF) defines a catastrophic incident as any natural or manmade incident, including terrorism, that results in extraordinary levels of mass casualties, damage, or disruption severely affecting the population, infrastructure, environment, economy, national morale, or government functions. Effective prevention, protection, mitigation, response, and recovery activities require a cohesive regional approach to catastrophic planning. Learn More
- Funding Opportunity Number: Please see website for Region Specific Opportunity DHS-21-GPD-111-(01,2,3,4,5,6,
- Source: Federal Emergency Management Agency
- Estimated Total Program Funding: $1,200,000 (Per Region)
- Award Ceiling: $1,200,000
- Closing Date: July 16, 2021
- Eligible Applicants: City or township governments, County governments, State governments
FY 2021 Homeland Security Preparedness Technical Assistance Program (HSPTAP)
HSPTAP provides financial assistance to professional non-profit organizations in activities to improve and/or build state, local, tribal and territorial (SLTT) capabilities to prevent, protect against, respond to, recover from, and mitigate major events, including threats or acts of terrorism. The overarching programmatic goal focuses on building state and local capabilities through various means and methods, each one aimed at achieving the National Preparedness Goal and furthering our collective efforts to remain a safe and secure nation. Specific HSPTAP program activities anticipated for achieving this goal include, but will not be limited to: developing and disseminating written products; facilitating calls, meetings, or discussions; providing and organizing seminars, training and workshops for key homeland security and emergency preparedness SLTT stakeholders nationwide (e.g., state emergency management directors, state homeland security advisors, and other professional organizations in the public and private sectors, etc.) to share information, knowledge, experiences, and practices relating to current and emerging homeland security, emergency management and public safety issues and efforts. Learn More
- Funding Opportunity Number: DHS-21-NPD-007-00-01
- Source: Federal Emergency Management Agency
- Estimated Total Program Funding: $525,000
- Award Ceiling: $525,000
- Closing Date: July 30, 2021
- Eligible Applicants: Nonprofits having a 501(c)(3) status with the IRS, other than institutions of higher education; Nonprofits that do not have a 501(c)(3) status with the IRS, other than institutions of higher education
FY 2021 State Fire Training (SFT) Systems Grant Program
In accordance with the Federal Fire Prevention and Control Act of 1974, the Superintendent of the National Fire Academy (NFA) delivers training in cooperation with State fire service training agencies. This cooperation includes direct delivery of government-funded courses in the States; the distribution and sharing of student manuals, instructor guides, and other course materials and funding to the States to help supplement and tailor their training delivery needs using NFA courses and programs. State Fire Training Programs support Mission 5 of the 2014 Quadrennial Homeland Security Review: Strengthen National Preparedness and Resilience and of Presidential Policy Directive (PPD-8): National Preparedness through training programs. Learn More
- Funding Opportunity Number: DHS-21-USFA-043-00-01
- Source: Department of Homeland Security
- Estimated Total Program Funding: $1,000,000
- Award Ceiling: $20,000
- Closing Date: July 27, 2021
- Eligible Applicants: State Fire Training Systems as designated by State legislation or Governor
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