INSIGHTi

Potential FEMA Emergency Sheltering
Options During the COVID-19 Pandemic
June 24, 2020
Some hazards (e.g., hurricanes, wildfires) may result in evacuations and displacement of survivors.
According to the Federal Emergency Management Agency (FEMA), state, local, tribal, and territorial
governments (SLTTs) are responsible for coordinating emergency sheltering support after a declaration
under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act; 42 U.S.C.
§§5121 et seq.). The ongoing coronavirus disease 2019 (COVID-19) pandemic may complicate efforts to
provide sheltering in typical congregate settings. This Insight discusses potential emergency sheltering
models previously used by FEMA and challenges posed by COVID-19, as well as policy considerations.
Emergency Sheltering Solutions
The federal government may provide financial assistance through FEMA to SLTTs when the President
declares an emergency or major disaster under the Stafford Act. Emergency sheltering may be authorized
under Stafford Act Section 502 following an emergency declaration and Stafford Act Section 403
following a major disaster declaration or Fire Management Assistance Grant declaration (FMAG). This
assistance is commonly referred to as Public Assistance (PA) Category B—Emergency Protective
Measures. When PA is authorized, FEMA will reimburse state, tribal, territorial, and local governments,
as well as eligible nonprofits (PA Applicants) for at least 75% of eligible costs incurred while performing
eligible work. FEMA’s regulations on emergency sheltering are limited, though program guidance may
be issued for a specific incident.
FEMA usually supports congregate sheltering in facilities with large, open spaces, such as schools and
community centers. Due to the COVID-19 pandemic, however, FEMA has acknowledged the need to
ensure appropriate social distancing. Thus, FEMA issued an interim policy for non-congregate sheltering
in the event of a Stafford Act declaration through December 31, 2020. FEMA also recommends sheltering
with friends or family and other housing solutions.
The following sections describe select, PA-authorized emergency sheltering solutions used in the wake of
past disasters, as well as FEMA’s current interim sheltering policy. Emergency sheltering programs
offered may vary depending on post-disaster needs and shelter availability.
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Congregate Shelters
FEMA may reimburse congregate sheltering costs, including facility leasing and utilities, eligible staffing,
supplies including food and furnishings, and services including cleaning and medical care.
COVID-19 has spread rapidly in congregate shelters, leading the Centers for Disease Control and
Prevention (CDC) to designate this option as “a last resort.” To mitigate risk, FEMA recommends that
congregate shelters provide at least 110 square feet per person. SLTTs should identify additional
sheltering space, use tracking systems for contract tracing, and prepare registration procedures that
separate ill and well evacuees. The CDC also recommends evacuees self-quarantine after leaving a
disaster shelter.
Non-congregate Shelters
FEMA has changed its policy to authorize non-congregate sheltering (i.e., sheltering that affords privacy,
such as dormitories, hotels, and motels, to include cleaning and disinfection) as an eligible emergency
protective measure when needed, if it is the legal responsibility of the PA Applicant (generally, SLTTs are
responsible for protecting public health and safety). The policy is applicable for all Stafford Act declared
incidents between June 1 and December 31, 2020, beginning six days prior to and up to thirty days
following an incident (unless FEMA approves an extension). PA Applicants requesting reimbursement
must provide sufficient documentation and must follow FEMA’s procurement policies when contracting
to carry out emergency protective measures, including the provision of non-congregate sheltering.
Additionally, PA Applicants may not receive assistance that duplicates assistance from other sources or
federal agencies. FEMA will review its policy by December 31, 2020.
Due to the pandemic, FEMA recommends that SLTTs anticipate and mitigate staffing shortages, prepare
registration procedures to separate ill and well evacuees, and secure contracts for infant and child feeding
and hygiene needs.
To provide a recent example, under the Stafford Act declarations for COVID-19, FEMA authorized PA for
non-congregate sheltering for limited periods of time, limited to specific populations (e.g., individuals
diagnosed with or exposed to COVID-19 that do not require hospitalization), if necessary to uphold
public health directives.
Transitional Sheltering Assistance
The Transitional Sheltering Assistance (TSA) program provides temporary hotel/motel accommodations
for eligible disaster survivors transitioning from congregate or non-congregate shelters to temporary or
permanent housing solutions. FEMA’s interim policy describes the information PA Applicants should
collect to ease the transition from non-congregate sheltering to TSA during COVID-19.
TSA is only available once it has been requested by the state, territorial, or Indian tribal government and
approved by FEMA. TSA may be authorized under Stafford Act Sections 502 or 403; however, unlike
PA-reimbursable emergency sheltering, TSA is provided as Direct Federal Assistance (DFA) (i.e., FEMA
pays the lodging providers directly).
FEMA issues disaster-specific guidance when TSA is authorized. The guidance includes TSA eligibility
and program implementation information. Unlike PA-reimbursed congregate emergency sheltering, which
is available to all disaster survivors, TSA applicants must satisfy the eligibility criteria established in the
guidance.

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Operation Blue Roof
In response to some disasters, FEMA has issued a mission assignment to the U.S. Army Corps of
Engineers (USACE) to manage Operation Blue Roof (a form of DFA). The program provides
homeowners with free, fiber-reinforced sheeting to cover damaged roofs, allowing disaster survivors to
remain in their homes while permanent repairs are completed. This program could reduce the need for
emergency shelters if hurricanes or other hazards were to damage homes during the pandemic.
Policy Considerations
State, local, tribal, and territorial governments bear significant responsibility for preparing for, responding
to, and recovering from disasters. To that end, potential congressional considerations to support
emergency sheltering during the pandemic include:
 reducing or eliminating the FEMA PA nonfederal cost share (the nonfederal share is
generally 25%), given potential state and local budget shortfalls;
 reducing the demand for emergency sheltering, such as by extending the CARES Act
(P.L. 116-136) moratoria on evictions and foreclosures, or temporarily extending housing
assistance for individuals who lack housing during the pandemic; and
 examining options to increase COVID-19 testing in shelters, given that FEMA’s
operational guidance documents do not mention plans to provide or expedite testing
sheltered populations.

Author Information

Elizabeth M. Webster
Erica A. Lee
Analyst in Emergency Management and Disaster
Analyst in Emergency Management and Disaster
Recovery
Recovery





Disclaimer
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