&EPA
United States
Environmental Protection
Agency
REIMBURSEMENT TIPS
for Water Sector Emergency Response and Recovery
Emergency response and recovery costs incurred by drinking water and wastewater
utilities may be eligible for reimbursement through local, state, or federal level
mechanisms. While the rules for allowable activities vary between reimbursement
mechanisms, lessons learned from past incidents reveal that reimbursement is commonly not
maximized. This is often due to lack of knowledge of or failure to follow proper procedures
and processes specific to a particular mechanism. This document presents tips drinking water
and wastewater utilities can use to maximize their ability to receive reimbursement.
Reimbursement Tips before an Incident
Consider joining a mutual aid and assis-
tance program. Mutual aid and assistance programs
can include local agreements, state programs, or Water/
Wastewater Agency Response Networks (WARNs).
Although these programs are not reimbursement mecha-
nisms, they often outline procedures for tracking infor-
mation for reimbursement.
Review the actual coverage and limits of
your insurance policy(s). Insurance is often the
first source of payment. When reviewing your insurance
policy, keep the following in mind:
• Coverage for all buildings, facilities, and capital
equipment.
• Accuracy of capital/fixed assets lists.
Review codes, construction standards, and
engineering design for all systems (current
and future projects). The Federal Emergency Man-
agement Agency (FEMA) Public Assistance Program
(PA Program) pays to restore damaged items to their
previous condition. Incorporating up-to-date codes,
standards, and engineering design can help present a
strong case to officials to fund the replacement of older
systems according to "new" standards.
Review the eligibility of likely activities and
resource needs following an incident. While
eligible costs vary by reimbursement mechanism, there
are several types of costs typically covered:
• Pre-disaster emergency work, compensatory time, and
mutual aid and assistance
• Emergency work (personnel time, equipment usage,
and emergency supplies)
• Temporary re-location and permanent work (facility
contents and facility restoration to pre-disaster design
and function)
Review after action and auditor reports from past
incidents to incorporate lessons learned from other
jurisdictions.
Develop accounting, documentation, and
emergency procurement procedures and
personnel policies you will use during a di-
saster. After an incident, pre-disaster procedures and
personnel policies must be followed to be eligible for
reimbursement.
• Establish disaster-related accounting codes to capture,
track, and report all disaster-related costs.
• Incorporate photos, videos, and Geographic Information
Systems (GIS) into your procedures for documenting
regular maintenance, facility contents, and damages.
• Describe compensation in your personnel policy,
including overtime during disasters to help retain per-
sonnel and ensure timely recovery.
Maintain thorough pre-disaster mainte-
nance records for permanent facilities. Of-
ficials need to verify that maintenance is occurring and
was documented before the incident. Records help avoid
questions of improper maintenance or deferred mainte-
nance following a disaster.
Maintain an inventory of facility contents
and emergency supplies. Officials may need to
verify damaged contents following the incident. An ac-
curate inventory may help avoid conflicts over reim-
bursement following a disaster.
Office of Water (4608-T) | EPA817-F-09-004 | August 2009 | www.epa.gov/watersecurity
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Reimbursement Tips for for Water Sector Emergency Response and Recovery
Be aware of and prepare to leverage hazard
mitigation programs to aid in the rebuilding
process. Every permanent work project has the poten-
tial for hazard mitigation (measures taken in advance of a
disaster aimed at decreasing or eliminating its impact on
society and the environment). Hazard mitigation funding
from mechanisms such as the Stafford Act may be avail-
able. To be eligible for funding, an entity must have an
approved hazard mitigation plan in place.
Other items to consider.
• Identify personnel, procedures, and an organizational
structure to maximize full reimbursement.
• Train personnel on procedures and data required for
documentation.
• Back up critical information for reimbursement off-
site in a secure location.
Reimbursement Tips after an Incident
Coordinate efforts with emergency
management agencies at the local, state,
and federal level. Local officials may have
information specific to the incident you are dealing
with. They can also help connect you to state officials
coordinating directly with FEMA. In coordination with
the state, identify and report to FEMA all potential
incident-related projects and retain a copy of the list. Be
aware of time limitations with the FEMA PA Program
and request extensions from officials if needed.
Be aware of and plan for the regular rota-
tion schedule of state and federal officials.
Officials could rotate out on a regular basis. Officials
rotating in may have no direct experience with the dam-
age systems have sustained. Plan to train and/or brief
new officials quickly to bring them up to speed.
Document emergency work before a federal
declaration of disaster. Changing circumstances
as an incident unfolds may dictate that FEMA decides
to issue a declaration of disaster. If this happens,
emergency work completed before the declaration of
disaster may become eligible for reimbursement.
Document labor costs. Maintain detailed
timesheets of labor costs that distinguish emergency
from permanent work and regular time from overtime.
• Work/costs to install temporary infrastructure, repair
damage, and complete targeted damage and safety as-
sessments may be eligible for reimbursement.
• Provide detail on tasks performed, hours for each
task, and the location of the task.
• Include hours of labor per person per day.
• Develop a summary sheet to support claims for reim-
bursement.
• Complete paperwork as you go rather than waiting
until the end of the incident response.
Document equipment usage time. Reimburse-
ment is based on application of equipment rates to each
hour of eligible use. Maintain detailed logs that sepa-
rate emergency from permanent work. Provide detail
on date, location, task, and operator(s). Remember to
account for equipment damage/extraordinary use and
small fixed asset machines (e.g., compressors or weld-
ers) as these have reimbursement costs also.
Document material purchases. Maintain ac-
curate and detailed records of material purchases that
separate emergency work from permanent work. Track
what in-stock supplies are used, as well as the cost to
replace them.
Cross check, validate, and store all records.
This includes records covering labor, materials, equip-
ment, and purchase orders/invoices. The federal Office of
Management and Budget requires that an entity granted
federal aid under the FEMA PA Program maintain
financial and program records for three years following
final payment. To ensure compliance with established
policies of the federal government, the U.S. Department
of Homeland Security (DHS) Office of Inspector General
can review and audit records at any time during a disaster
or the three year period following final payment. Entities
may also be subject to additional audits by state auditors.
For More Information: A variety of
mechanisms are available to provide cost
reimbursement. One of the main federal
sources of reimbursement funding for
the water sector is the FEMA PA Program:
www.fema.gov/government/grant/
pa/reference.shtm
Office of Water (4608-T) | EPA817-F-09-004 | August 2009 | www.epa.gov/watersecurity
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