FEDERAL EMERGENCY MANAGEMENT AGENCY CORONAVIRUS DISEASE2019 PUBLIC ASSISTANCE
TECHNICAL ASSISTANCE STUDY DEVELOPMENT AND IMPLEMENTATION GROUP
Methods of Assessing
Duplication of Benefits
with Patient Care Revenue
As Applied by the Federal Emergency
Management Agency to Health Care
Providers’ Public Assistance Claims
During the COVID-19 Emergency
T
he Federal Emergency Management Agency’s (FEMA’s) Public Assistance (PA) program
provides federal assistance to government organizations and certain private nonprofit
entities following major disasters or emergencies declared by the President. Federal law
prohibits FEMA’s PA program from reimbursing an applicant for costs that are covered
by other sources of funding (i.e., it prohibits duplication of benefits [DoB]), which could include
patient care revenue (PCR) from insurance and other private or public funding.
1
FEMA has per-
fected its approach to evaluating DoB when infrastructure has been damaged by a natural disas-
ter but faces significant challenges in evaluating and addressing DoB for health care applicants
that responded to the coronavirus disease2019 (COVID-19) public health emergency (PHE).
To address this challenge, FEMA engaged the Homeland Security Operational Analysis Center
(HSOAC) to develop procedures for accurately evaluating DoB using a standard method and
using alternative methods developed by applicants. In addition to accuracy, FEMA and HSOAC
aimed to require minimal additional data from applicants and to create procedures that would
allow most evaluations to be completed in 15business days each.
The remainder of this introduction describes the PA program, challenges that FEMA faces
in distributing PA to health care applicants while avoiding duplication, and HSOAC’s role
in providing technical assistance to address these challenges. Chapter1 describes the Stan-
dard Method for addressing DoB with PCR. Chapter2 describes our approach to evaluating
applicant methods of addressing DoB, and Chapter3 provides brief conclusions. We have also
Research Report
HS AC
A N FFR D C O PER AT ED BY R AN D U N D E R C O N T R ACT W I TH D H S
HOMELAND SECURITY
OPERATIONAL ANA LYSIS CENTER