In coordination with representatives from the Federal Emergency Management Agency and Texas Division of Emergency Management, the Texas Hospital Association offers the following information to clarify the process by which hospitals that experienced damage as a result of Hurricane Harvey should submit claims for reimbursement to FEMA.
Federal law limits eligibility for FEMA funds to public and private nonprofit hospitals. Investor-owned hospitals are eligible only for low-interest loans through the
U.S. Small Business Administration.
FEMA funding is considered last resort funding, which means any insurance policies and other funding mechanisms must be exhausted first. FEMA pays only the non-insured portion of any eligible damages. In addition, only those nonprofit hospitals in a
FEMA-designated disaster area are eligible for assistance.
The first step in the claims process is to submit the following forms to T-DEM via email no later than Oct. 31. This submission not binding and is considered only a notice of intent to apply for reimbursement for costs sustained during Hurricane Harvey and resulting flooding.
1. Request for Public Assistance: Required for public and private hospitals. This form notifies the state that a facility will request FEMA assistance and is required in order to receive a response from FEMA.
2. Designation Authorized Sub-recipients's Agent: Required for public and private hospitals. This form identifies the individuals in the hospital with whom TDEM and FEMA will work on the full application for assistance.
3. Direct Deposit Authorization: Required for public and private hospitals. Includes information on the account into which public assistance funds will be deposited.
4. PNP Facility Questionnaire: Required ONLY for private hospitals.
Submission of the RPA and accompanying forms triggers assignment of a FEMA case manager to the hospital. This individual then schedules a kickoff meeting with the hospital and works with hospital staff to identify eligible costs and categories of available funding, complete the full application for assistance and document the claims. See the
detailed FEMA guide for categories of costs possibly eligible for reimbursement.
In general, costs related to business interruption are not considered eligible for reimbursement. However, according to FEMA staff, hospitals represent a unique situation in claims management and adjudication because of the challenge in determining whether a cost is incurred as part of normally doing business, despite the disaster, or is a cost directly attributable and the result of the disaster.
Documenting the claim thoroughly and comprehensively is vitally important. Working closely with the designated FEMA case manager also is important. Hospitals are advised to keep detailed inventories with documented costs and record the roles of all employees and contractors related to the hurricane. Mitigation activities are crucial. When selecting vendors, hospitals also must strictly follow all federal laws related to procurement to be eligible for FEMA funding. In addition, if a hospital received FEMA reimbursement in the past and was required to maintain a certain level of insurance as a condition of reimbursement, eligibility for future funding will depend on documenting that it obtained and maintained that required level of insurance. Once T-DEM or FEMA approves a scope of work for reimbursement, hospitals may not deviate from it.