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Reimbursement under CARES Act

Amanda Kellar

Wed, Jul 15, 2020 7:22 PM

A member has a couple of questions about reimbursement under the CARES Act.

What kind of records need to be kept in order get reimbursed from CARES funding for an employee's time who now devotes a portion of it to COVID related matters. For example, if an employee works eight hours a day, and three of those hours are now COVID related, what kind of payroll records will be required to get reimbursed for those three hours.
If there are multiple people working overtime in a department because they work a small portion of their day doing reimbursable COVID-related tasks, would that overtime be reimbursable from CARES funds and, if so, what paperwork would be necessary? If one of that group could be assigned exclusively to the COVID tasks and not have anyone work overtime, would that prevent reimbursement from CARES funds?

Thanks for your responses. Please feel free to reply directly to me at akellar@imla.org mailto:akellar@imla.org or to the list if you prefer.

Amanda

[photo]

Amanda Kellar
Deputy General Counsel / Director of Legal Advocacy
International Municipal Lawyers Association, Inc.

A 51 Monroe St., Suite 404, Rockville, MD, 20850
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A member has a couple of questions about reimbursement under the CARES Act. 1. What kind of records need to be kept in order get reimbursed from CARES funding for an employee's time who now devotes a portion of it to COVID related matters. For example, if an employee works eight hours a day, and three of those hours are now COVID related, what kind of payroll records will be required to get reimbursed for those three hours. 1. If there are multiple people working overtime in a department because they work a small portion of their day doing reimbursable COVID-related tasks, would that overtime be reimbursable from CARES funds and, if so, what paperwork would be necessary? If one of that group could be assigned exclusively to the COVID tasks and not have anyone work overtime, would that prevent reimbursement from CARES funds? Thanks for your responses. Please feel free to reply directly to me at akellar@imla.org<mailto:akellar@imla.org> or to the list if you prefer. Amanda [photo] Amanda Kellar Deputy General Counsel / Director of Legal Advocacy International Municipal Lawyers Association, Inc. A 51 Monroe St., Suite 404, Rockville, MD, 20850 [cid:image003.jpg@01D65ABB.BD2FF7F0]<http://www.facebook.com/IMLA-259977855541/> [cid:image004.jpg@01D65ABB.BD2FF7F0] <http://www.linkedin.com/company/international-municipal-lawyers-association-inc./> [cid:image005.jpg@01D65ABB.BD2FF7F0] <http://twitter.com/imlalegal> [cid:image006.jpg@01D65ABB.BD2FF7F0] <http://soundcloud.com/internationalmunicipallawyersassociation> P (202) 466-5424 ext. 7116 W www.imla.org<http://www.imla.org/> Plan Ahead! IMLA's 85th Annual Conference<http://imla.org/events/conferences>, September 23-27 in La Quinta, CA! IMLA's 2021 Mid-Year Seminar<https://imla.org/events/seminars>, April 23-26, 2021 in Washington, DC!

Brett Kriger

Wed, Jul 15, 2020 7:39 PM

The best answer is to comply with guidance of the state agency designated as the grantee. You must sustain that audit first. The state grantee reimburses the applicant and FEMA reimburses the state. The state audits the applicant and FEMA audits the state (which may include an audit of the applicant).

If the closeout audit finds non compliance with local, state or federal laws, codes, procedures, policy or guidance (or, there is insufficient/conflicting documentation) the claim will be disallowed.

On Jul 15, 2020 2:23 PM, Amanda Kellar akellar@imla.org wrote:
A member has a couple of questions about reimbursement under the CARES Act.

What kind of records need to be kept in order get reimbursed from CARES funding for an employee’s time who now devotes a portion of it to COVID related matters. For example, if an employee works eight hours a day, and three of those hours are now COVID related, what kind of payroll records will be required to get reimbursed for those three hours.
If there are multiple people working overtime in a department because they work a small portion of their day doing reimbursable COVID-related tasks, would that overtime be reimbursable from CARES funds and, if so, what paperwork would be necessary? If one of that group could be assigned exclusively to the COVID tasks and not have anyone work overtime, would that prevent reimbursement from CARES funds?

Thanks for your responses. Please feel free to reply directly to me at akellar@imla.org mailto:akellar@imla.org or to the list if you prefer.

Amanda

[photo]

Amanda Kellar
Deputy General Counsel / Director of Legal Advocacy
International Municipal Lawyers Association, Inc.

W www.imla.org http://www.imla.org/
Plan Ahead!

IMLA’s 85th Annual Conferencehttp://imla.org/events/conferences, September 23-27 in La Quinta, CA!
IMLA’s 2021 Mid-Year Seminarhttps://imla.org/events/seminars, April 23-26, 2021 in Washington, DC!

the simple answer is that FEMA expects an applicant to treat disaster related work like any other Force account work. You vote the work as out is done and what it regular time and what is overtime is in accordance with the normal policy of the applicant. You can't selectively decide which is which for the purpose of "rigging" the reimbursement. The best answer is to comply with guidance of the state agency designated as the grantee. You must sustain that audit first. The state grantee reimburses the applicant and FEMA reimburses the state. The state audits the applicant and FEMA audits the state (which may include an audit of the applicant). If the closeout audit finds non compliance with local, state or federal laws, codes, procedures, policy or guidance (or, there is insufficient/conflicting documentation) the claim will be disallowed. On Jul 15, 2020 2:23 PM, Amanda Kellar <akellar@imla.org> wrote: A member has a couple of questions about reimbursement under the CARES Act. 1. What kind of records need to be kept in order get reimbursed from CARES funding for an employee’s time who now devotes a portion of it to COVID related matters. For example, if an employee works eight hours a day, and three of those hours are now COVID related, what kind of payroll records will be required to get reimbursed for those three hours. 1. If there are multiple people working overtime in a department because they work a small portion of their day doing reimbursable COVID-related tasks, would that overtime be reimbursable from CARES funds and, if so, what paperwork would be necessary? If one of that group could be assigned exclusively to the COVID tasks and not have anyone work overtime, would that prevent reimbursement from CARES funds? Thanks for your responses. Please feel free to reply directly to me at akellar@imla.org<mailto:akellar@imla.org> or to the list if you prefer. Amanda [photo] Amanda Kellar Deputy General Counsel / Director of Legal Advocacy International Municipal Lawyers Association, Inc. A 51 Monroe St., Suite 404, Rockville, MD, 20850 [cid:image003.jpg@01D65ABB.BD2FF7F0]<http://www.facebook.com/IMLA-259977855541/> [cid:image004.jpg@01D65ABB.BD2FF7F0] <http://www.linkedin.com/company/international-municipal-lawyers-association-inc./> [cid:image005.jpg@01D65ABB.BD2FF7F0] <http://twitter.com/imlalegal> [cid:image006.jpg@01D65ABB.BD2FF7F0] <http://soundcloud.com/internationalmunicipallawyersassociation> P (202) 466-5424 ext. 7116 W www.imla.org<http://www.imla.org/> Plan Ahead! IMLA’s 85th Annual Conference<http://imla.org/events/conferences>, September 23-27 in La Quinta, CA! IMLA’s 2021 Mid-Year Seminar<https://imla.org/events/seminars>, April 23-26, 2021 in Washington, DC!