What guidance and best practices exist for municipalities when receiving and spending funding for COVID-19 vaccine distributions?

One strategy to assist in maximizing multiple funding sources is to, where reasonable, prioritize more restrictive funding and use it first, before tapping into more flexible funding.  For example, it may be advisable to utilize FEMA PA funding first (which is not capped or competitive) for all eligible activities, and then after using FEMA PA, a municipality can use other funding sources for the expenditures ineligible for FEMA reimbursement.  This may help maximize overall federal funding by saving the nonfinite funding programs for use after the finite funding programs.

It will be important to understand the specific documentation and eligibility requirements of each program.  Each municipality will need to demonstrate compliance and validate that its organization met the rules and requirements of the different programs. Failure to meet documentation requirements, or documentation that does not adequately support the municipality’s claim under any given funding source, may result in having to forgo eligible funding.  It will be prudent for municipalities to record and save all documentation, invoices, proofs of payments, procurement methodologies, etc. Below are some points to consider following to help minimize duplication of benefits (“DOB”) and maximize additional funding:

• Documentation should be detailed;
• documentation should be stored centrally and electronically; and
• documentation should be organized logically.

Understanding the differences between Federal funding programs can help a city determine what activity should be applied to each funding source.  Additionally, detailed tracking of costs is often critical to avoid DOB – a requirement that no two funding sources can provide funding for the same item, service, or scope.  In some cases, multiple funding sources can provide funding for the same item, and your organization should identify which funding source will best meet your needs. 

The vaccine distribution process should aim to deploy resources as efficiently as possible. The CDC has identified some best practices municipalities may follow to ensure efficient management of vaccine distribution:^[1]

• Jurisdictions can consider determining a consistent, predictable amount of vaccine to each site or provider. This allows vaccine administrators to schedule patients more efficiently for their second dose within the 28 to 42-day window, if administering Pfizer or Moderna.
• Providers can consider estimating how many patients are due for their second shot on a weekly basis. This requires vaccine distribution to be steady and readily available to the provider. It is recommended that vaccines be closely tracked and allocated in a timely manner.
• Providers should consider prioritizing patients requiring their second dose. A system should be implemented that assesses and determines the appropriate amount of first doses allocated to each site and concurrently prioritizes providers or sites that have patients approaching the end of their 42-day window (six weeks) to receive their second dose. Vaccine distributors must take into consideration the amount of time it takes to place orders and deliver vaccine to providers.
• It is not recommended to hold or place to the side second doses for patients who miss their appointments. Providers should consider evaluating, on a weekly basis, the number of missed appointments and use any remaining as first doses to avoid waste.
• Jurisdictions should consider tracking vaccine administration to identify which providers have a high throughput of vaccine at their location(s), to determine where larger allocation of vaccine can be sent in the future.

Last Revised: May 4, 2021