COVID-19 Federal Assistance e311


FEMA Funding, Vaccine Distribution

Which resources are available for vaccine efforts, including but not limited to distribution, incentives, and community engagement? In addition, can you summarize resources available for vaccine efforts via the Federal Emergency Management Agency?

There are multiple avenues for municipalities to receive funding for vaccination efforts, including: (i) FEMA Public Assistance (“PA”) funding; (ii) grants provided through the Centers for Disease Control and Prevention (“CDC”); and (iii) the Coronavirus State and Local Fiscal Recovery Fund (“CSLFRF”) which is provided through the American Rescue Plan Act of 2021 (“ARP”). These avenues address vaccine incentive programs and cover costs related to local vaccination efforts.

Importantly, municipalities should strongly consider using funding from more restrictive programs such as FEMA PA before tapping into sources that provide more flexibility, such as CSLFRF funding.

It is advisable to consider FEMA PA (which is not capped or competitive) as the priority fund for any eligible activities not already funded by private insurance programs or the CDC.[1] Notably, FEMA has already provided more than $4.47 billion for expenses related to COVID-19 vaccination at 100% federal cost share.[2] If eligible expenditures under FEMA PA are exhausted, municipalities can then pursue other funding sources for expenditures ineligible for FEMA reimbursement.

The CDC is actively funding state, local, and territorial public health organizations responding to the COVID-19 pandemic, including vaccination efforts. The CDC has received supplemental funds through the Coronavirus Preparedness and Response Supplemental Appropriations Act of 2020; the Coronavirus Aid, Relief and Economic Security Act of 2020; the Paycheck Protection Program and Health Care Enhancement Act; the Coronavirus Response and Relief Supplemental Appropriations Act of 2021; and most recently, the ARP. The CDC is awarding funding received through these congressional appropriations to jurisdictions nationwide.[3] The ARP authorizes $130.2 billion in funds specifically allocated for local governments as a separate appropriation pursuant to CSLFRF.[4]

Municipalities should focus efforts on coordinating with their respective state public health agencies, which predominantly serve as the pass-through entity for CDC funding. Working closely with the pertinent state public health agency will help to prevent depletion of the more flexible CSLFRF funding and will allow tapping into the direct state and federal funding for specific vaccination purposes.

The ARP separately authorizes an additional $7.5 billion as “[f]unding for COVID-19 Vaccine Activities at the [CDC].”[5] The ARP has designated funds to be available to the CDC specifically for such purposes as improving nationwide vaccine distribution and delivering technical support to local governments. As defined under this authority, “technical assistance” provides a host of vaccine efforts for municipalities, including:

  • distribution and administration of vaccines;
  • expansion of community vaccination centers;
  • deployment of mobile vaccination areas;
  • enhancement of data sharing and systems that increase vaccine efficiency, effectiveness, and uptake;
  • facility enhancements;
  • communications with the public; and
  • transportation of individuals to facilitate vaccination.[6]

The U.S. Department of the Treasury’s (“Treasury”) Interim Final Rule (the “Rule”) specifically includes “[e]xpenses related to COVID-19 vaccination programs and sites, including staffing, acquisition of equipment or supplies, facilities costs, and information technology or other administrative expenses” as an eligible use of CSLFRF.[7]

As described in Treasury’s CSLFRF Frequently Asked Questions (“FAQ”) to the Rule, CSLFRF funds may also be used to fund programs that provide incentives which are designed to: (i) influence people who would otherwise not get vaccinated; or (ii) assist people to get vaccinated more quickly, so long as the costs are reasonably proportional to the expected health benefit.[8] For example, Massachusetts is providing fully vaccinated residents who are 18 or older a chance to win one of five $1 million prizes, while those between the ages of 12 and 17 will be eligible to win one of five $300,000 scholarship grants in order to drive increases in vaccinations.[9] In New Jersey, the Governor’s Office launched the “Shot and a Beer” program to also encourage their eligible population to get vaccinated.[10]


Last Updated: August 2, 2021

[1] FEMA, Robert T. Stafford Disaster Relief and Emergency Assistance Act, P.L. 93-288 as Amended, Section 312, at 17-18, available at:

[2] FEMA, “FEMA COVID-19 Vaccination Update,” available at:

[3] CDC COVID-19 State, Tribal, Local, and Territorial Funding, available at: See also “CDC Awards $3 Billion to Expand COVID-19 Vaccine Programs” available at:

[4] American Rescue Plan Act of 2021 § 9901, Pub. L. No. 117-2, amending 42 U.S.C. § 801 et seq., at Sections 602 and 603, available at:

[5] American Rescue Plan Act of 2021 § 9901, Pub. L. No. 117-2, amending 42 U.S.C. § 801 et seq., at Section 262, available at:

[6] Id.

[7] Treas. Reg. 31 CFR 35 at 138, available at:

[8] Coronavirus State and Local Fiscal Recovery Funds, Frequently Asked Questions (as of July 19, 2021) – FAQ #2.12, available at:

[9] National Governors Association, “Covid-19 Vaccine Incentives,” available at

[10] Id.