Providing Federal Support for Governors' Use of the National Guard To Respond to COVID-19

This memorandum directs FEMA to cover 100% of National Guard costs for 10 states and the U.S. Virgin Islands responding to COVID-19 under state control, and directs the Secretary of Defense to request governors order National Guard forces to perform FEMA-issued missions on a reimbursable basis. The 100% federal cost share expires 30 days from signing.

Federal Register Open PDF 85 FR 19639

Impact dates

May 2, 2020
100% federal cost share terminates

Key directives

FEMA shall fund 100% of emergency assistance activities for National Guard forces in specified states/territory under sections 403 and 503 of Stafford Act
Secretary of Defense shall request governors order National Guard to perform duty for FEMA mission assignments under 32 U.S.C. 502(f) on fully reimbursable basis
Secretary of Defense shall publish memorandum in Federal Register

Who is ordered

Timeline

Immediate

100% federal cost share takes effect for specified states/territory
FEMA authorized to fund National Guard emergency assistance activities
Secretary of Defense directed to request governors order National Guard to FEMA missions

Near term (90d)

100% cost share terminates May 2, 2020 (30 days from signing)

Long term

—

Risks & tensions

Limited to 10 states and 1 territory, excluding other states with COVID-19 needs
30-day expiration creates uncertainty for sustained response; possible need for extension
Fully reimbursable basis for DoD missions may create administrative burden vs. direct federal funding
Subject to availability of appropriations creates contingency risk