COVID-19 Federal Assistance e311


Fund Planning & Allocation

Funding Source

American Rescue Plan Act, CARES Act, FEMA

How should a municipality assess and improve equity in its COVID-19 response and recovery?

The U.S. Department of the Treasury’s (“Treasury”) Final Rule expanded the definition of impacted and disproportionately impacted communities and related enumerated eligible uses of Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”). Under the Final Rule, recipients can presume that low-income households were disproportionately impacted by the pandemic.[1] Other disproportionately impacted communities include: (i) households that reside in Qualified Census Tracts (“QCT”); (ii) households receiving services provided by Tribal Governments; (iii) households residing in the U.S. territories or receiving services from these governments; and (iv) households that qualify for certain federal benefits, including:

  • Temporary Assistance for Needy Families (TANF);
  • Supplemental Nutrition Assistance Program (SNAP);
  • Free- and Reduced-Price Lunch (NSLP) and/or School Breakfast (SBP) programs;
  • Medicare Part D Low-Income Subsidies;
  • Supplemental Security Income (SSI);
  • Head Start and/or Early Head Start;
  • Special Supplemental Nutrition Program for Women, Infants, and Children (WIC);
  • Section 8 Vouchers;
  • Low-Income Home Energy Assistance Program (LIHEAP); and
  • Pell Grants.[2]

Additionally, the Final Rule expanded the enumerated eligible uses for disproportionately impacted communities:

Disproportionately Impacted Household and Community Assistance:

  • Pay for community health workers to help households access health & social services;
  • Remediation of lead paint or other lead hazards;
  • Primary care clinics, hospitals, integration of health services into other settings, and other investments in medical equipment & facilities designed to address health disparities;
  • Housing vouchers & assistance relocating to neighborhoods with higher economic opportunity;
  • Investments in neighborhoods to promote improved health outcomes;
  • Improvements to vacant and abandoned properties, including rehabilitation or maintenance, renovation, removal and remediation of environmental contaminants, demolition or deconstruction, greening/vacant lot cleanup & conversion to affordable housing;
  • Services to address educational disparities, including assistance to high-poverty school districts & educational and evidence-based services to address student academic, social, emotional, and mental health needs; and
  • Schools and other educational equipment & facilities.[3] 

Disproportionately Impacted Small Business Assistance:  

  • Rehabilitation of commercial properties, storefront improvements & façade improvements;
  • Technical assistance, business incubators & grants for start-up or expansion costs for small businesses; and
  • Support for microbusinesses, including financial, childcare, and transportation costs.[4]

Disproportionately Impacted Nonprofit Assistance:

Recipients may identify appropriate responses that are related and reasonably proportional to addressing the following disproportionate impacts:

  • Nonprofits operating in Qualified Census Tract;
  • Nonprofits operated by Tribal governments or on Tribal lands; and
  • Nonprofits operating in the U.S. territories.[5]   

Municipalities should consider using CSLFRF to assist disproportionately impacted communities in order to support long-term recovery from the public health emergency.

Responding to the Executive Order

Municipalities should consider taking the following actions to assess and improve equitable COVID-19 response and recovery with the President’s Executive Order[6] in mind

  • Assess equity across COVID-19 response and recovery measures to date, including, but not limited to, provision of healthcare, vaccination administration and outreach, and positioning programs to mitigate adverse economic impacts of COVID-19. Municipalities may use pre-existing tools in helping to identify typically underserved or most-at-risk communities.

    • For example, municipalities could use the CDC’s Social Vulnerability Index to identify community needs or most-at-risk communities based on socioeconomic, demographic, and spatial information. Built on census data, this information may help to establish baselines and targets for outreach and/or support. 
  • Refer to FEMA’s Advisory Civil Rights Considerations During COVID-19 Vaccine Distribution Efforts for a checklist of considerations to plan for equitable vaccine distribution. Additionally, FEMA has included an Equity Job Aid in the COVID-19 Medical Care Policy that outlines expectations for addressing equity in vaccine administration programs, including required reporting and data collection. [FEMA Policy 104-21-004]
  • Consult the U.S. Department of Housing and Urban Development (“HUD”)’s Disaster Impact and Unmet Needs Assessment Kit to identify and prioritize critical unmet needs for long-term community recovery. While this assessment is intended to be completed after a disaster, a similar framework can be argued to apply to communities or areas that qualify under HUD’s National Objectives
  • Evaluate whether highest-risk communities and underserved populations are being reached then identify and address potential barriers for outreach and engagement by:
    • Assessing if common barriers to public information, such as access to technology or language may be impacting accessibility or engagement for highest-risk communities. If possible, explore feasible options to help expand points of communication or outreach, or assess primary language needs of highest-risk communities.
    • Determining if barriers to accessing services or resources, such as timing of available programs, location, or access to public transportation are limiting engagement for highest-risk communities. Municipalities may consider providing additional resources, or changing locations or times to help expand access for highest-risk communities.
  • Leverage existing relationships with community groups, non-profits, front-line workers, or community members to understand local concerns or issues in accessing information or resources.
  • Document efforts to incorporate equity or comply with non-discrimination requirements in recovery efforts and monitor additional requirements that may be put in place for federally funded programs.
  • Assess if equity concerns are captured in your response framework, operational plans, or after-action or mid-action reports. If they are not addressed, update them to include how your municipality addressed equity concerns to help demonstrate compliance. 
  • Document feedback collected through evaluation processes, including efforts to address potential barriers or adaptations to processes to better address equity concerns.
  • For federal funding sources with specific compliance requirements related to equity, like FEMA’s updated guidance for vaccination administration, assess potential gaps in data or information to be able to meet requirements both in data collection, data submission, and critical reporting timelines. Document efforts to close those gaps, as well.
  • Learn from other municipalities and states on their approach to incorporating equity in COVID-19 response, or from organizations that focus on equity programming outside of disaster response.
  • Consult the National League of Cities’ Task Force Report on centering equity in economic development, which includes recommendations and case studies that may be useful for municipalities planning economic development or recovery programs with COVID-19 relief funding.
  • Refer to Treasury’s American Rescue Plan: Centering Equity in Policy Making, which includes direct support to American families, Housing Equity and Access, and State and Local Aid.
  • Lastly, review the Georgetown Climate Center’s published research, tools, and frameworks for communities to assess and plan for equitable disaster preparedness, response, and recovery. This resource is not COVID-19 specific, but does include tools specific to community engagement, data collection, and needs assessments, including in areas of public health, economic recovery, and infrastructure projects.

Last Revised: March 11, 2022

[1] Treas. Reg. 31 CFR 35 at 38, available at:

[2] Department of Treasury, Overview of the Final Rule: “Coronavirus State & Local Fiscal Recovery Funds: Overview of the Final Rule,” January 6, 2022, p. 19, available at

[3] Id., at 20.

[4] Id., at 22.

[5] Id., at 23.

[6] The White House, “Executive Order On Advancing Racial Equity and Support for Underserved Communities Through the Federal Government” available at: