INTERNAL AUDIT 

To:          Dan Thomas, Chief Financial Officer 
Copies:     Steve Metruck, Lance Lyttle, Dave McFadden, Stephanie Stebbins- 
Jones, Elizabeth Leavitt, Dave Soike, Larry Ehl, Pete Ramels, 
Dave Freiboth, Bookda Gheisar, Pearse Edwards, Katie Gerard 
From:       Glenn Fernandes, Director, Internal Audit 
Date:        April 24, 2020 
Subject:    FEMA Public Assistance Program  Coronavirus (COVID-19) 

In light of the COVID-19 pandemic and strains placed on Port resources, Internal Audit
volunteered to research potential FEMA reimbursable expenditures and provide a report
back to the Port's Executive Team. 
Background 
On March 13, 2020, the President declared the ongoing Coronavirus Disease 2019
(COVID-19) pandemic of sufficient severity and magnitude to warrant an emergency
declaration (see Appendix A). On March 19, 2020, the Federal Emergency Management 
Agency (FEMA) released a fact sheet that captures expenses of emergency protective
measures that may be eligible under FEMA's Public Assistance Program. As described
in the declaration, FEMA assistance will be provided at a 75 percent federal cost share 
and expense, dating back to January 20, 2020, are considered eligible. The remaining 25
percent should be funded through the State of Washington's Disaster Fund. 

Approach 
Internal Audit initially reviewed FEMA guidance to obtain a general understanding of the
program. We then contacted the Deputy State Coordinating Officer for FEMA, Gary
Urbas, and had several discussions with him, to determine what was an allowable
reimbursement, to better understand the program and processes, and to provide Gary
with an overview of the types of costs the Port was incurring. At Gary's direction, we also
initiated an application through FEMA's grants portal. The application was approved by
Gary's team on Friday, April 17, 2020. This portal will be used to submit documentation
and review the status of claims. The portal currently identifies primary and secondary Port
contacts, as Internal Audit, but these will be updated and transitioned to the businesses
when possible. 
Assessment of Reimbursable Costs 
FEMA will reimburse certain expenditures that are COVID-19 related, emergency and 
safety specific, and are not reimbursed through other programs. Expenses also should
be above and beyond the entity's normal operating costs (See Appendix A). Internal Audit
has isolated potentially reimbursable costs and has discussed these with our FEMA State
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Coordinating Officer. Based on FEMA literature and guidance from our State Coordinating
Officer,  the  Port  is  eligible  to  pursue  the  expenditures  listed  below,  for  FEMA
reimbursement. The Port will likely incur further expenses in the near future, that are not
reflected below. 

Construction Related 
The Port will incur additional expenses for COVID-19 safety-related change orders that
are grouped in the following  categories.  Change orders are yet to be finalized,
accordingly, costs are pending. 
Activity                                                             Cost         Reimbursable 
1-2 hour staggering starting times                           Pending    No 
Addition of a full-time prevention site supervisor              Pending    Yes 
Hand washing stations                                    Pending    Yes 
Hand tool sanitation                                         Pending    Yes 
Purchase of duplicate hand tools                           Pending    No 
Enhanced COVID-19 project-specific safety costs           Pending    Possibly 
Disinfection of Eligible Public Facilities 
FEMA will reimburse the Port for any cleaning materials purchased. This includes
overtime related to cleaning and installation of cleaning dispensers/stands, and to create
a revised schedule to meet employee safety needs. 
Activity                                                               Cost to    Reimbursable 
Date 
Sanitizer, stands, disinfecting spray/wipes, face shields,     $738,486  Yes 
etc. 
Marine Maintenance overtime  cleaning / installation of     $ 13,926  Yes 
cleaning stands 
Aviation Maintenance overtime  safety needs              $  1,020  Yes 

Emergency Personnel Expenses 
FEMA will reimburse the Port for an emergency services overtime and new hires
specifically for emergency services. The Port has not incurred any police department
overtime. To date, only fire department overtime is reflected below. 
Activity                                                               Cost to    Reimbursable 
Date 
Fire Department overtime                                  $  6,450  Yes 


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Internal Audit also took forth specific questions from the Port and had discussions with
our FEMA State Coordinating Officer. Based on those discussions, it was determined
that the following expenses were deemed not eligible for reimbursement under FEMA but
might be eligible through one of the other Coronavirus Aid, Relief, and Economic Security
(CARES) Act Programs. 
$1.44 million  Public health emergency leave (time code 215). At this time, most
Port employees, who are taking COVID-19 related leave, are using this account
code. It is limited to 160 hours and will have an end date. 
Emergency sick leave (time code 216). Required to be offered through the
Families First Coronavirus Response Act (FFCRA). The Port may be eligible to
receive a refundable tax credit for the Social Security and Hospital Insurance
employer paid tax. Although there is only $13,276 in this account at this time, we
expect this number to grow as leave available through 215 is exhausted or ends. 
Expanded FMLA (time code 217), also part of the FFCRA, may have available
tax credits. 
The maintenance and set up fee for a $150 million credit facility. 











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Appendix A 
Coronavirus (COVID-19) 
Pandemic: Eligible Emergency Protective Measures 
Release date: March 19, 2020 
Consistent with the President's national emergency declaration for the coronavirus
(COVID-19) pandemic on March 13, 2020, FEMA urges officials to, without delay, take
appropriate actions that are necessary to protect public health and safety pursuant to
public health guidance and conditions and capabilities in their jurisdictions. FEMA
provides the following guidance on the types of emergency protective measures that may 
be eligible under FEMA's Public Assistance Program in accordance with the COVID-19
Emergency Declaration in order to ensure that resource constraints do not inhibit efforts
to respond to this unprecedented disaster. 
FEMA Public Assistance Program 
In accordance with section 502 of the Robert T. Stafford Disaster Relief and Emergency
Assistance Act, 42 U.S.C. 5121-5207 (the "Stafford Act"), eligible emergency protective
measures taken to respond to the COVID-19 emergency at the direction or guidance of 
public health officials may be reimbursed under Category B of FEMA's Public Assistance
program. FEMA will not duplicate assistance provided by the U.S. Department of Health
and Human Services (HHS), to include the Centers for Disease Control and Prevention
(CDC), or other federal agencies. 
State, territorial, tribal, and local government entities and certain private non-profit
organizations are eligible to apply for Public Coronavirus (COVID-19) Pandemic: Eligible
Emergency   Protective   Measures   |   FEMA.gov   https://www.fema.gov/newsrelease
/2020/03/19/coronavirus-covid-19-pandemic-eligible-emergency-protective 
measures [4/7/2020 1:51:09 PM] Assistance. FEMA assistance will be provided at a 75
percent  federal  cost  share.  This  assistance  will  require  execution  of  a  FEMAState
/Tribal/Territory  Agreement,  as  appropriate,  and  execution  of  an  applicable
emergency plan. Local governments and other eligible PA applicants will apply through
their respective state, tribal or territorial jurisdictions. 
Eligible Assistance 
Under the COVID-19 Emergency Declaration described above, FEMA may provide
assistance for emergency protective measures including, but not limited to, the following,
if not funded by the HHS/CDC or other federal agency. While some activities listed may 
be eligible for funding through HHS/CDC, final reimbursement determinations will be

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coordinated by HHS and FEMA. FEMA will not duplicate any assistance provided by
HHS/CDC): 
Management, control and reduction of immediate threats to public health and 
safety: 
o  Emergency Operation Center costs 
o  Training specific to the declared event 
o  Disinfection of eligible public facilities 
o  Technical assistance to state, tribal, territorial or local governments on
emergency management and control of immediate threats to public health
and safety 
Emergency medical care: 
o  Non-deferrable medical treatment of infected persons in a shelter or 
temporary medical facility 
o  Related medical facility services and supplies 
o  Temporary medical facilities and/or enhanced medical/hospital capacity (for
treatment when existing facilities are reasonably forecasted to become
overloaded in the near term and cannot accommodate the patient load or
to quarantine potentially infected persons) 
o  Use of specialized medical equipment 
o  Medical waste disposal 
o  Emergency medical transport 
Medical sheltering (e.g. when existing facilities are reasonably forecasted to
become overloaded in the near future and cannot accommodate needs) 
o  All sheltering must be conducted in accordance with standards and/or
guidance approved by HHS/CDC and must be implemented in a manner
that incorporates social distancing measures 
o  Non-congregate medical sheltering is subject to prior approval by FEMA
and is limited to that which is reasonable and necessary to address the
public health needs of the event, is pursuant to the direction of appropriate
public health officials and does not extend beyond the duration of the Public
Health Emergency. 
o  Household pet sheltering and containment actions related to household
pets in accordance with CDC guideline. 
o  Purchase  and  distribution  of  food,  water,  ice,  medicine,  and  other
consumable supplies, to include personal protective  equipment and
hazardous material suits movement of supplies and persons. 
o  Security and law enforcement 
o  Communications of general health and safety information to the public. 
o  Search and rescue to locate and recover members of the population
requiring assistance. 
o   Reimbursement for state, tribe, territory and/or local government force
account overtime costs. 
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