&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
                                                                                           rm
   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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