COVID-19 Federal Assistance e311


FEMA Funding, Vaccine Distribution

May municipalities use CLFRF and/or CRF disbursements to cover the cost of vaccine incentives?

The U.S. Department of Treasury’s (“Treasury”) updated Frequently Asked Questions (“FAQ”) as of May 27, 2021, indicates that municipalities may in some circumstances use CLFRF funds to cover the cost of vaccine incentives.  Question #2.12 of the FAQ outlines the following inquiry:

“May recipients use funds to pay for vaccine incentive programs (e.g., cash, or in-kind transfers, lottery programs, or other incentives for individuals who get vaccinated)?

Yes. Under the Interim Final Rule, recipients may use Coronavirus State and Local Fiscal Recovery Funds to respond to the COVID-19 public health emergency, including expenses related to COVID-19 vaccination programs. See forthcoming 31 CFR 35.6(b)(1)(i). Programs that provide incentives reasonably expected to increase the number of people who choose to get vaccinated, or that motivate people to get vaccinated sooner than they otherwise would have, are an allowable use of funds so long as such costs are reasonably proportional to the expected public health benefit.”[1]

The fact sheet issued by Treasury discusses the importance of providing “care for those impacted by the virus and through services that address disparities in public health that have been exacerbated by the pandemic.”[2] Thus the use of funds towards harder-to-reach populations, and those who may not have otherwise been vaccinated without these special events and entertainment, may qualify as sufficiently supporting the public health response.[3]

While CLFRF funds are an allowable source, Treasury has not provided updated guidance related to the utilization of CRF funding for this purpose. The allowability of vaccine incentives under CRF is still unknown.

Last Revised: June 3, 2021