Methods of Assessing Duplication of Benefits with Patient Care Revenue

The Federal Emergency Management Agency's (FEMA's) Public Assistance (PA) Program is prohibited by law from reimbursing an applicant for costs that are covered by other sources of funding, which could include insurance or other private or public funding. FEMA has perfected its approach to evaluating duplication of benefits when public infrastructure has been damaged by a natural disaster, but it had not fully developed these capabilities to respond to a public health emergency (PHE). To support the delivery of its PA program in response to the coronavirus disease 2019 (COVID-19) pandemic, FEMA asked the Homeland Security Operational Analysis Center (HSOAC) to develop analytic methods and subsequent guidance to identify duplication of benefits with patient care revenue in grant applications. The center was also asked to review select applications for duplication with patient care revenue. This report documents the researchers' methods of assessing such duplication. It will be of interest primarily to PA applicants, taxpayers, and related stakeholders.

Editor's Note: FEMA requested that HSOAC deploy the methodology documented in this report to identify claims already reimbursed from other sources. This support has also helped FEMA avoid overpaying for wasteful or inappropriate claims. From September 2022 through March 2025, HSOAC evaluated more than $35 billion in COVID-19 public assistance claims across 671 unique applicants spanning 7,928 projects and identified $2.2 billion in potential savings.