Job Aid - In Response to OMB Passbacks

Equitable COVID-19 Response and Recovery
Recipient and Subrecipient Job Aid
A. Introduction
The Equitable COVID-19 Response and Recovery Recipient and Subrecipient Job Aid (Job Aid)
provides the steps Recipients and Subrecipients must take to document that pandemic
response and recovery efforts are conducted in an equitable manner to communities of color
and other underserved populations, including sexual orientation and gender identity minority
groups, persons with disabilities, those with limited English proficiency, and those living at
the margins of our economy. The Job Aid includes specific procedures to ensure equitable
medical care and vaccine administration consistent with equitable pandemic response and
recovery, per FEMA Policy #104-21-0004: Coronavirus (COVID-19) Pandemic Medical Care
Eligible for Public Assistance (Interim) (Version 2), hereinafter called the Medical Care Policy.1

B. Equity Considerations for All COVID-19 Work
Recipients and Subrecipients must prioritize limited resources to ensure an equitable
pandemic response.2 The following items are elements Recipients and Subrecipients may
consider to ensure equitable allocation of resources:
• Using the Centers for Disease Control and Prevention (CDC) Social Vulnerability Index
(SVI) or similar value to determine highest-risk communities;
• Considering communities disproportionately affected by the pandemic, in terms of
infection rates, hospitalization, and mortality; and
• Strengthening data collection efforts to substantiate that COVID-19 aid is reaching the
highest-risk communities and underserved populations.
Recipients and Subrecipients are required to comply with applicable provisions of laws and
authorities prohibiting discrimination, including but not limited to:
• Title VI of the Civil Rights Act of 1964, which prohibits discrimination based on race,
color, or national origin (including limited English proficiency)
• Sections 308 and 309 of the Stafford Act, which require the impartial and equitable
delivery of disasters services and activities, without discrimination on the grounds of

FEMA Policy #104-21-0004: Coronavirus (COVID-19) Pandemic Medical Care Eligible for Public Assistance
(Medical Care Policy) Section C.3.k., March 2021.
2 Medical Care Policy Section B.3.c.
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race, color, religion, nationality, sex, age, disability, English proficiency, or economic
status3
Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination based
on disability
Title IX of the Education Amendments Act of 1972, which prohibits discrimination
based on sex in education programs or activities
Age Discrimination Act of 1975, which prohibits discrimination based on age
U.S. Department of Homeland Security regulation 6 C.F.R. Part 19, which prohibits
discrimination based on religion in social service programs
2 C.F.R 200 - Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, Subpart D – Post Federal Award Requirements §
200.300 Statutory and national policy requirements.

FEMA will monitor compliance for all COVID-19 Work in accordance with 44 C.F.R. Part 7. Of
note, Recipients and Subrecipients must:
• Provide assurances of compliance with nondiscrimination requirements;
• Retain compliance information;
• Submit and retain complete, accurate, and timely reports; and
• Respond to requests for information.4

C. Equitable Vaccine Administration Requirements
In addition to the requirements in Section B, FEMA will take additional steps to ensure
compliance for vaccine-related work.

1. Vaccine Information Requirements
Each Recipient or Subrecipient requesting PA funding for vaccination efforts and associated
activities must substantiate how equity was considered as part of its vaccine administration
strategy. 5 Upon submittal of a vaccination-related project application, the respective
Recipient or Subrecipient must certify that vaccine-related efforts consider equity and
advance supporting highest-risk communities.

Title 44 Code of Federal Regulations (C.F.R.) § 206.11 and Medical Policy Section B.3.d.
44 C.F.R. Part 7.
5 Medical Care Policy Section B.3.c
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Each Recipient or Subrecipient will submit social vulnerability scores and information to
substantiate an equitable vaccine administration strategy, as detailed in Section 5. The
equitable vaccination information must address each of the Recipient’s or Subrecipient’s
vaccine administration sites.6 Appendix A: Equitable Vaccine Administration Information
Submission Templateincludes a template that may be used to submit the information
(Template). One template may be submitted for all of a Recipient’s or Subrecipient’s sites,
even if the Recipient or Subrecipient has or will submit multiple projects. The Template has
three sections:
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Section 1: Recipient/Subrecipient Information
Section 2: Equitable Vaccine Administration Strategy
Section 3: Site-Specific Information

Recipients or Subrecipients may use their own template provided it includes the same level
of detail and information. They should upload the information in the Applicant Profile section
of FEMA’s Public Assistance (PA) Grants Portal.
Recipients and Subrecipients shall collect race, ethnicity, and disability status data, as
outlined in the Medical Care Policy7 to determine whether target populations are being
reached. These data should be collected and used to identify target populations but should
not be submitted to FEMA. In the case of a complaint, audit or questionable compliance,
FEMA may request statistical or summary information based on collected data, such as
percent of each type of population. FEMA will not request, and Recipients and Subrecipients
should not submit to FEMA, personally identifiable information8 to determine compliance with
equitable pandemic response requirements.

2. Timeframes to Submit Information
When to submit the information to FEMA will vary based on the status of vaccination
operations and FEMA funding. Recipients and Subrecipients are grouped as follows to
differentiate between which deadlines apply to which Recipients and Subrecipients:

Medical Care Policy Section C.3.k.ii.
Medical Care Policy Section C.3.k.i.
8 Personally Identifiable Information is defined by OMB Memorandum M-07-1616 and refers to information that
can be used to distinguish or trace an individual’s identity, either alone or when combined with other personal
or identifying information that is linked or linkable to a specific individual.
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Group 1: Recipients or Subrecipients that completed all their vaccination work and
that:
a) FEMA has obligated funding, must submit the information within 30 days of
the issuance of the Medical Care Policy
b) Have applied for, but FEMA has not yet obligated funding, must submit the
information within 30 days of the vaccine-related obligation
c) Have not yet applied for FEMA funding, must submit the information with
their initial request for FEMA vaccination funding
FEMA reviews Group 1 submissions once for completeness and compliance. As work
is complete, there is no overall need from Group 1 to submit ongoing 30-day
reporting. FEMA may request additional information as necessary.

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Group 2: Recipients or Subrecipients that have not yet completed all of their
vaccination work and that:
a) FEMA has obligated funding, must submit the information within 30 days of
the issuance of the Medical Care Policy
b) Have applied for, but FEMA has not yet obligated funding, must submit the
information within 30 days of the initial vaccine-related obligation
c) Have not yet applied for FEMA funding, must submit the information within
30 days of the initial vaccine-related obligation
Group 2 must submit ongoing updates every 30 days until the completion of
vaccination work. FEMA reviews Group 2’s submissions monthly for completeness,
and quarterly for compliance.

3. Review Process
FEMA reviews submissions for completeness and compliance. Failure to comply “could result
in funding reductions and/or delays”.9

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Medical Care Policy B.3.c

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4. Identifying Target Populations
Recipients and Subrecipients shall collect race, ethnicity, and disability status data, as
outlined in the Medical Care Policy.10 The collection of this information should be used to:
• Identify the highest-risk communities;
• Evaluate whether the highest-risk communities and underserved populations are
being reached;
• Refine or improve the strategy, as needed; and
• Demonstrate compliance with the delivery of COVID-19 aid in an equitable manner.

5. Vaccine Administration Information
All Recipients or Subrecipients must submit the following information to FEMA to
demonstrate equitable vaccine administration:11
• The score on the CDC’s Social Vulnerability Index or similar social deprivation,
disadvantage, or vulnerability composite index;
• A description of how the location of the site(s)—relative to other candidate locations—
best advances FEMA’s focus on supporting the highest-risk communities; and
• A strategy to operationalize equitable access at each site, including but not limited to:
o A plan for community outreach and engagement, both before and during
implementation;
o A registration process that advances equity with a focus on prioritizing
minoritized, marginalized, and otherwise disadvantaged groups;
o Equitable physical design of the site, including transportation and accessibility
considerations; and
o A plan for ongoing evaluation and continuous improvement to ensure equitable
access.
Additionally, Recipients or Subrecipients in Group 2 must provide updates to this information
to FEMA every 30 days.

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Medical Care Policy Section C.3.k.i..
Medical Care Policy Section C.3.k.ii.

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a. Social Vulnerability Scores
Recipients and Subrecipients must provide a score, such as the Centers for Disease Control
and Prevention Social Vulnerability Index (CDC SVI) for each proposed site.12 The CDC SVI
specifies that “socially vulnerable populations are especially at risk during public health
emergencies because of factors like socioeconomic status, household composition, minority
status, or housing type and transportation.” The approach should provide specifics, as
appropriate. The Recipients and Subrecipients may choose an alternate score, so long as the
score follows the criteria outlined in the Medical Care Policy.
b. Outreach and Engagement
Recipients and Subrecipients must describe their approach to community outreach and
engagement, both before and during implementation.13
The CDC COVID-19 Vaccination Program Interim Playbook for Jurisdiction Operations Section
12: COVID-19 Vaccination Program Communication14 includes a framework for developing
communication objectives, targeting audiences, messaging considerations, and
communication channels. In addition, the CDC has published “COVID-19 One-Stop Shop
Toolkits” that can assist with communication strategies.15
Communications to disseminate public information should include translation and
interpretation services as necessary16.
The following questions are elements Recipients and Subrecipients may consider when
describing their approach to community outreach and engagement:
• How does the outreach and engagement strategy specifically support access to
vaccinations for the highest-risk communities and underserved populations?
• What outreach and engagement strategies do you intend to utilize to reach high-risk
communities and underserved populations (e.g. leverage community leaders and
community-based organizations)?

Medical Care Policy Section C.3.k.ii.a.
Medical Care Policy Section C.3.k.ii.c.1.
14 CDC COVID-19 Vaccination Program Interim Playbook for Jurisdiction Operations Version 2.0, Section 12,
October 2020.
15 CDC COVID-19 One-Stop Shop Toolkits, February 2021
16 Stafford Act, Section 403(a)(3)(F) and (G); and as described at Chapter 2:VI.B. Emergency Protective
Measures (Category B) at page 58 of the PAPPG (V3.1).
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How are you ensuring your community engagement events are accessible to
individuals with disabilities, limtied english proficiency, and those living at the margins
of our economy?
In what ways does the outreach and engagement strategy address vaccine
confidence?

c. Registration Process
Recipients and Subrecipients must provide a registration process that advances equity with a
focus on prioritizing minoritized, marginalized, and otherwise disadvantaged groups.17 The
following questions are elements Recipients and Subrecipients may consider when
describing their registration process:
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How does your vaccine registration process address digital disparity with online
registration (e.g internet access, computer access, etc.) or other limiting access
factors to registration?
What information or support is provided for registrants to meet their scheduled
vaccine appointment (e.g. discussion of rural areas lack of access to public
transportation, etc.)?
Is your registration system advancing equity with a focus on prioritizing minoritized,
marginalized, and otherwise disadvantaged groups?

d. Vaccine Site Selection
Recipients and Subrecipients must submit a description of how the location of each site relative to other locations – best advances a focus on supporting the highest-risk
communities. This may also include a comparison of vaccination rates for demographic
groups by geographic area18 to identify populations likely to have access barriers in receiving
a vaccine, such as:
• Socioeconomic status barriers;
• Household composition;
• Individuals with disabilities who are home based;
• Minority status and limited English proficiency; and

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Medical Care Policy Section C.3.k.ii.c.2.
Medical Care Policy Section C.3.k.ii.b.

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Housing and transportation barriers, to include crowding or group quarters, access to
a vehicle, and mobile homes.

The following should also be provided for each site:
• The location (address or coordinates);
• Vaccine site type, per FEMA’s Community Vaccination Centers Playbook;
• Site Status (active, planned, or closed);
• Site capacity (doses/day); and
• Actual site throughput (doses provided over the past 30 days).
e. Site Accessibility
Recipients and Subrecipients must also ensure that the vaccine site is accessible, as
outlined in the FEMA Civil Rights COVID Vaccine Checklist19 and the Medical Care Policy.20
Factors of accessibility design include consideration of transportation avenues to and from
the site and accessibility of the physical design of the site itself. Site accessibility
considerations may also include provisions made to use mobile sites or provide
transportation to populations with accessibility constraints. The following questions are
elements Recipients and Subrecipients may consider in describing their site accessibility
approach:
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How are you ensuring access to information at the vaccine site for individuals with
disabilities and/or limited English proficiency?
What assistive technology is your site utilizing for individuals with disabilities?
How are you ensuring that your site, or a portion thereof, is compliant with Americans
with Disabilities Act21 accessibility requirements and for individuals requiring
additional assistance (e.g. older individuals and individuals with cognitive disabilities)?
How are you ensuring that your site is accessible by public transportation?

FEMA Civil Rights COVID Vaccine Checklist: “Civil Rights Considerations During COVID-19 Vaccine Distribution
Efforts,“ 3/21/20 (fema.gov).
20 Medical Care Policy C.3.k.ii.c.
21 Americans with Disabilities Act of 1990,AS AMENDED with ADA Amendments Act of 2008.
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f. Evaluation and Continuous Improvement
Recipients and Subrecipients should include a discussion of their evaluation methods and
approach to continuous improvement related to equitable vaccination efforts.
The following questions are elements Recipients and Subrecipients may consider when
describing their plan for evaluation and continuous improvement:
• How are you evaluating your approach to equitable vaccine administration?
• What tactical adjustments are you making based on your evaluation? Tactical
adjustments may include, but are not limited to: adjusting the physical design of
vaccination sites to promote accessibile design, increasing transportation options
to and from vaccination sites to promote equitable access, adjusting registration
processes to advance equity and prioritize highest-risk and underserved
communities etc.
• What is working well to promote equitable vaccine distribution?

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Equitable Vaccine Administration Information Submission Template
How to Use this Template
Recipients and Subrecipients may use this template for submitting information to FEMA. To submit this information to FEMA,
Recipients and Subrecipients upload this template (or their own template or report that contains the same information and level
of detail) to the Applicant Profile in Grants Portal.
Group 1 Recipients or Subrecipients may use this template to provide the information one time.
Group 2 Recipients or Subrecipients may use this template to provide the information initially and every 30 days thereafter to
provide any updates, improvement, or refinements to the strategy, updated status of sites, and to capture any newly established
sites. If there are no changes, the information must still be provided with a statement that there are no changes since the last
submittal.

Equitable Vaccine Administration Information
Section 1: Recipient/Subrecipient Information
Declaration #

Recipient Name
Subrecipient Name

FEMA PA Code

Section 2: Equitable Vaccine Administration Strategy
Overview of
Strategy

Narrative (If this is a subsequent 30-day submittal, please define any refinements/improvements derived from the ongoing evaluation)

Outreach and
Engagement

Narrative (If this is a subsequent 30-day submittal, please define any refinements/improvements derived from the ongoing evaluation)

Registration
Process

Narrative (If this is a subsequent 30-day submittal, please define any refinements/improvements derived from the ongoing evaluation)

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Physical Site
Design and Access

Narrative (If this is a subsequent 30-day submittal, please define any refinements/improvements derived from the ongoing evaluation)

Evaluation and
Continuous
Improvement Plan

Narrative (If this is a subsequent 30-day submittal, please define any changes to the plan)

Section 3: Site--Specific Information
(If this is a subsequent 30-day submittal, please define any refinements/improvements derived from the ongoing evaluation)
Associated FEMA
Project #

Site

Name

Location

Status

Index
Used

Vulnerability
Score

Site
Type

Site Capacity

Throughput

Additional site-specific details regarding:
•
Outreach and Engagement
•
Registration Process
•
Physical Site Design
•
Evaluation and Continuous
Improvement

Equitable Selection
Considerations

ID

ID

Text

Address
GPS

 Planned
 Active
 Closed

CDC,
SoVI,
Other

Numeric
Value

I-V

Doses/day
projected for
the next 30
days

Doses/day in
the past 30
days

Narrative

Select all that apply:

□ Community outreach and
engagement was
conducted for this site.

□ Site location is accessible.
□ Registration process
addresses digital disparity
and/or other limiting
factors to registration.

□ Site collects data on
demographic information
as detailed in the Medical
Care Policy.

□ Site location supports
highest-risk communities
and underserved
populations.

□ Acted on results of
evaluation and
continuous improvement.

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