&EPA
United States
Environmental Protection
Agency
REIMBURSEMENT TIPS
for Emergency Laboratory Support
The Water Laboratory Alliance (WLA) provides the Water
Sector with an integrated nationwide network of laboratories with
the analytical capabilities and capacity to support monitoring
and surveillance, and response and remediation in the event
of intentional, unintentional, and natural water contamination.
Emergency response and recovery costs incurred by laboratories
supporting the Water Sector following an incident may be eligible
for reimbursement through local, state, or federal level mechanisms.
The WLA's Response Plan provides a comprehensive approach to
providing a coordinated multi-laboratory response to these events
but does not include detailed guidance on reimbursement. EPA is
considering various reimbursement options/mechanisms to address
laboratory support, including "fee for service" agreements. This tips sheet has been developed to facilitate
public laboratory reimbursement when fee for service agreements have not been established.
While the rules for allowable activities vary between reimbursement mechanisms, lessons learned from past
incidents reveal that reimbursement is commonly not maximized due to either lack of knowledge or failure to follow proper
procedures and processes specific to a particular mechanism. This document presents tips laboratories can use to develop
or refine internal processes and procedures that may maximize their ability to receive reimbursement.
Before an Incident
Identification of appropriate resources and
mechanisms facilitates the reimbursement
process. In general, laboratories that may provide
emergency support services in response to an authorized
Analytical Services Requester (ASR) (e.g., Incident
Commander, Analytical Coordinator, Primary Responding
Laboratory [PRL], and local, state or federal emergency
operations center representative) and seek reimbursement for
these services should prepare in advance. Consideration of
the following pre-incident planning and preparation activities
may be helpful:
- Review reimbursement eligibility, mechanisms, and
resources for laboratory support activities and how they
might differ if response is at a local, state, or federal level.
- Establish emergency procurement procedures and
logistics for essential laboratory supplies.
- Review current staffing and identify personnel and
procedures to support contingency or extraordinary staffing
requirements.
- Review requirements (e.g., sample identification) for
criminal and forensic sample analyses.
- Establish accounting codes to capture, track, and
distinguish routine operational costs from incident support-
Develop...
- and maintain a thorough pre-incident
inventory of critical resources, including
equipment and instrumentation, reagents,
supplies, and consumables related to
specialized or anticipated support activities.
- a comprehensive listing of available
support resources (e.g., personnel,
analytical capabilities and capacities,
analytical instrumentation, sampling
equipment, and supplies) and register your
laboratory with EPA's Compendium of
Environmental Testing Laboratories
(www.epa.gov/compendium), if appropriate.
- and maintain records of all routine
Quality Assurance and Quality Control
(QA/QC) procedures (types and frequency).
- and maintain thorough maintenance
and calibration records for laboratory
equipment and instrumentation including all
required procedures and intervals.
- and maintain standard sample
evidentiary chain of custody protocols
(Note: a link to internal chain of custody
training is available on the WLA Web site).
Office of Water (4608-T) | EPA817-F-09-003 | August 2009 | www.epa.gov/watersecurity
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Reimbursement Tips for Emergency Laboratory Support
related costs (including pre-incident emergency work).
- Describe compensation (e.g., overtime) in the personnel policy and review any limitations on analyst hours (e.g..
maximum number of hours in Biosafety Level 3 on a daily basis).
- Document routine hours of use for equipment and instrumentation.
- Provide secure on-site and off-site storage of all records - documentation (through Federal Office of Management and
Budget) should be maintained for a minimum of three years following final payment.
During and After an Incident
When the potential exists
for laboratory support
reimbursement, laboratories
must maintain accurate records
of expenditures associated
with support of an incident.
The following activities and accounting
procedures may be helpful during and
after an incident:
Coordinate with emergency
management agencies at local,
state, and federal levels to identify
all incident-related activities and
ensure that a complete list is provided
to State Emergency Management
Agency (EMA), Federal Emergency
Management Agency (FEMA) officials
and the Incident Commander, or other
responsible designee.
Review reimbursement eligibility,
mechanisms, and resources for
laboratory support activities.
Review time limitations for potential
reimbursement sources, as well as any
deadlines for requesting extensions.
Develop a detailed cost summary
sheet to support claims for
reimbursement.
Develop and maintain a system to
cross-check and validate all records.
- labor costs in detail utilizing pre-established accounting codes
to identify incident-related costs (including emergency work
conducted before a state or federal declaration of disaster).
Ensure that documentation can 1) distinguish between regular
and overtime hours, 2) provide hours on a per-person, per-day
basis, and 3) provide detail on all tasks performed, including
hours per task and task location. In particular, track costs for...
• staff exchange.
• consulting services.
• data review.
• sample collection, analysis, disposition, and disposal.
- non-labor costs through pre-established accounting codes
and/or detailed logs that 1) separate emergency from
permanent work, 2) provide detail on date, location, task,
analyst/technician, and hours of use, and 3) account for
equipment damage/extraordinary use. In particular, track...
• analytical costs, including use/replacement of reagents and
supplies and QA/QC analyses.
• courier/transport costs for samples; disposition, storage and
disposal of samples, and/or records.
• acquisition of equipment (e.g., autoclaves and computers) and
equipment usage costs associated with the incident (e.g., need
for accelerated equipment maintenance and calibration, need
for earlier replacement of parts, such as microscope bulbs).
• overflow laboratory costs (i.e., the cost of contracting
laboratories to cover routine support).
• incidental costs, such as temporary relocation (e.g., airfare,
lodging, food, rental vehicle).
This resource may be useful in determining eligibility and reimbursement requirements:
FEMA Public Assistance Information: www.fema.gov/government/grant/pa/index.shtm
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CONTACT US: For additional information on the Water Laboratory Alliance, please contact
WLA@epa.gov or see http://cfpub.epa.gov/safewater/watersecurity/wla.cfm.
Latisha Mapp may also be contacted directly at mapp.latisha@epa.gov.
Office of Water (4608-T) | EPA817-F-09-003 | August 2009 | www.epa.gov/watersecurity
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