Which funding source(s) should a municipality consider for use regarding vaccine-related expenses?

The American Rescue Plan Act (“ARP”) authorizes $350 billion for the “Coronavirus State Fiscal Recovery Fund” (“CSFRF”), and $130.2 billion of these funds is allocated specifically for local governments as a separate appropriation known as “Coronavirus Local Fiscal Recovery Fund” (“CLFRF”).^[1]

In addition to the above, the ARP separately authorizes $7.5 billion as “Funding for COVID-19 Vaccine Activities at the [Centers for Disease Control and Prevention]” (“CDC”).^[2] The ARP authorizes funds to the CDC for such purposes as (1) enhancing and improving nationwide vaccine distribution, and (2) providing technical support to state, local and tribal governments. “Technical support” is defined under this authority to include the following: distribution and administration of vaccines; expansion of community vaccination centers; deployment of mobile vaccination areas; enhancement of data sharing and systems that increase vaccine safety, effectiveness and uptake; facilities enhancements; communication with the public; and transportation of individuals to facilitate vaccinations.^[3]

Local governments may consider coordinating closely with their respective state public health agency, which will serve as the pass-through entity for the bulk of the CDC funding. As stated in its April 6, 2021 news release, 60% of the most recently announced vaccine funding from the CDC must be distributed to local health departments, community-based organizations, and community health centers.^[4] By working closely with the relevant state public health agency, local municipalities will be able to tap into the direct state and federal funding available specifically for vaccination purposes and thus will not need to resort in the first instance to the more flexible funding under its control such as the CLFRF.

Separate from both sets of funds above, President Biden’s Memorandum dated January 21, 2021, also authorizes FEMA to “fund 100 percent of the cost of activities associated with all mission assignments for the use of the National Guard under 32 U.S.C. 502(f) to respond to COVID-19.” ^[5] This includes federal funding for COVID-related activities such as vaccine administration that were previously determined eligible from the beginning of the COVID-19 pandemic in January 2020 and through September 30, 2021.

As stated in previous FAQs, the needs of every municipality are different, including the vaccination resource needs.  For example, a community might host a predominantly rural population that may need multiple small distribution sites or a largely homebound population, in which mobile sites would be the most appropriate measure. In order to ensure that the appropriate resources are being utilized, the municipality should develop a comprehensive plan for the use of all of the ARP funds.  The following are a few steps that a municipality could take in developing this plan:

• Conduct a comprehensive capacity assessment and unmet needs analysis;
• Form a cross-sector recovery oversight committee;
• Engage the served community;
• Assess and catalog available funding to prioritize needs; and
• Develop a short and long-term recovery strategy.

These community engagement and planning efforts will help to provide municipalities with the information needed to allocate enough financial resources necessary to address local vaccination needs and to strategically use available funding sources.

Last Revised: May 4, 2021