INSIGHTi

Potential FEMA Emergency Sheltering
Options During the COVID-19 Pandemic
Updated October 5, 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 after a declaration under the
Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act; 42 U.S.C. §§5121 et
seq.). However, the Centers for Disease Control and Prevention (CDC) and FEMA acknowledge that the
ongoing coronavirus disease 2019 (COVID-19) pandemic may complicate efforts to provide emergency
sheltering. This Insight discusses emergency sheltering models used by FEMA, COVID-19-related
emergency sheltering policies, and challenges faced by SLTTs supporting emergency sheltering during the
COVID-19 pandemic, and policy considerations for Congress.
Emergency Sheltering Options
The federal government may provide assistance 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 (FMAG) declaration. This assistance is commonly
referred to as Public Assistance (PA) Category B—Emergency Protective Measures. When PA is
authorized, FEMA will reimburse SLTTs, 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 additional guidance may be issued.
The following sections describe select, PA-authorized emergency sheltering options used in the wake of
recent and past disasters, as well as FEMA’s interim sheltering policy and guidance during COVID-19.
Sheltering options may vary depending on post-disaster needs and shelter availability.
Congregate Shelters
FEMA usually supports emergency congregate shelters (i.e., facilities with large, open spaces, such as
schools and community centers), and may reimburse associated costs, including facility leasing and
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utilities, eligible staffing, supplies including food and furnishings, and services including cleaning and
medical care.
FEMA has acknowledged the need to ensure appropriate social distancing in congregate shelters due to
the COVID-19 pandemic. To mitigate risk in congregate settings, FEMA recommends that congregate
shelters provide at least 110 square feet per person. Agency guidance also recommends that SLTTs
identify additional sheltering space, use tracking systems to locate available space, and prepare
registration procedures that separate ill and well evacuees. Some shelters have provided coronavirus
testing, as recommended by FEMA guidance. CDC recommends shelter residents self-quarantine after
leaving a disaster shelter.
As COVID-19 has spread in congregate shelters, the CDC designated this option as “a last resort.” 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
options.
Non-congregate Shelters
Due to COVID-19 pandemic, FEMA has changed its policy to authorize non-congregate sheltering
(defined by FEMA as sheltering that affords privacy, such as separate dormitory, hotel, or motel rooms for
evacuees from different households) when necessary to reduce risk of exposure or transmission among
survivors. 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, meet all
PA eligibility requirements, and follow FEMA’s procurement policies when contracting out any
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.
The Transitional Sheltering Assistance (TSA) program is an example of a non-congregate sheltering
option. Due to the pandemic, FEMA has issued interim TSA guidance, which applies to emergencies or
major disasters declared on or after August 22, 2020, for which Individual Assistance is authorized. It
allows FEMA to authorize TSA at the request of the affected state/territory/Indian tribe when congregate
shelters are overcrowded or insufficient to meet the need, or areas of communities designated for
assistance are inaccessible and expected to remain so for more than 30 days. The interim TSA guidance
also includes eligibility and program implementation information. Unlike PA-reimbursable emergency
sheltering, TSA is provided as Direct Federal Assistance, meaning FEMA pays the hotel/motel lodging
providers directly. The interim TSA guidance will be either reissued, revised, or rescinded within one year
of August 23, 2020. Additionally, FEMA’s interim non-congregate sheltering policy describes the
information PA Applicants should collect to ease the transition from non-congregate sheltering to TSA
during COVID-19.
Emergency Sheltering Challenges During COVID-19
Emergency managers have recently sheltered disaster survivors in congregate and non-congregate
settings, including in the aftermath of wildfires in California, Oregon, and Washington, and Hurricanes
Laura and Sally. Challenges faced during these efforts have included:
 Insufficient time and resources to revise sheltering plans;
 Staffing shortfalls at congregate and non-congregate sheltering facilities;
 Insufficient non-congregate sheltering capacity;

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 SLTT-borne non-congregate sheltering costs;
 Risk of transmission among evacuees and emergency response personnel at congregate shelters,
including firefighters;
 Reluctance to evacuate due to risk of transmission; and
 Lack of evacuee transportation options that comply with social distancing requirements.
Potential Policy Considerations for Congress
SLTTs bear significant responsibility for preparing for, responding to, and recovering from disasters. To
that end, potential congressional considerations to support the emergency sheltering efforts of SLTTs
during the pandemic include:
 reducing or eliminating the FEMA PA nonfederal cost share (i.e., the SLTT-borne portion
of the costs, which is generally 25%), given potential state and local budget shortfalls;
 evaluating the need to pass legislation to continue the moratoria on residential evictions
that was ordered by the Director of the CDC and is in effect through December 31, 2020,
if needed to help reduce the demand for emergency sheltering; and
 examining options to support or increase staff supporting emergency sheltering, given
pandemic-related staffing unavailability, reductions, and attrition in SLTTs, voluntary
organizations, and the accommodations industry. Direct Federal Assistance and/or the
National Guard could provide additional federal support, though Congress may consider
capacity strains on federal personnel responding to the pandemic, wildfires, and
hurricanes.

Author Information

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





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