Montgomery County has finished collecting $176.4 million in federal reimbursements for its COVID-19 response, closing the books on a reimbursement effort that stretched across six years and required fighting off four separate FEMA denials. County officials announced the milestone after the final payment of $1,657,190 arrived on August 5.
The county's reimbursement came through FEMA's Public Assistance program, according to Montgomery Community Media, which reported that FEMA denied the county's reimbursement requests four times before officials successfully appealed three of those denials. Per the county's Office of Emergency Management and Homeland Security, Montgomery County sought or received more through FEMA Public Assistance than any other Maryland jurisdiction, a comparison OEMHS based on state legislative documents.
County Executive Marc Elrich said the county was determined not to leave possible funds unclaimed, and that it ultimately received the money it was eligible for. The county had spent roughly $190 million responding to the pandemic, and the federal reimbursements covered costs for staff, lab tests, test kits, food distribution, and protective gear, the outlet reported.
A Six-Year Paper Trail Rooted in Emergency Spending
The reimbursement saga traces back to the earliest months of the pandemic. In December 2020, Elrich requested a $20.7 million special appropriation from county reserve funds to extend COVID-19 testing, food security, and health outreach programs in Black and Latino communities, according to Montgomery County Government, which noted that officials explicitly planned to pursue FEMA reimbursement for all eligible expenses at the time. That approach treated local reserves as bridge funding while the county waited on federal cost recovery that would take years to materialize.
The county also received $183.4 million directly from the federal Coronavirus Relief Fund under the CARES Act, covering immediate unbudgeted pandemic expenses incurred during 2020, per records from the Department of Budget and Management. That direct relief fund was separate from the FEMA Public Assistance reimbursements that took years longer to finalize, illustrating how federal COVID aid arrived to local governments through multiple, differently timed channels.
Shifting Federal Cost-Share Rules Complicated the Math
Part of what made the reimbursement process so drawn out was a moving federal cost-share formula. In March 2022, President Biden extended a 100% federal cost share through July 1, 2022, for eligible COVID-19 Public Assistance emergency protective measures, up from the statutory minimum of 75%, according to Hagerty Consulting. Starting July 2, 2022, FEMA reduced that rate to 90%, a level that held until the national pandemic incident period officially ended on May 11, 2023, per the California Governor's Office of Emergency Services.
That meant expenses incurred later in the pandemic were reimbursed at a lower ratio than costs incurred during the full federal cost-share window, adding another layer of complexity to the county's claims. FEMA's Public Assistance program covers pandemic costs under Category B Emergency Protective Measures, which includes non-congregate sheltering, personal protective equipment, and public health communications, while explicitly prohibiting duplicate assistance from other federal agencies such as HHS or the CDC, according to FEMA.
Appeals Ran Through State and Federal Channels
In Maryland, federal Public Assistance grant funds pass through the Maryland Department of Emergency Management, which serves as the official state recipient managing grant administrative plans and forwarding municipal appeals to FEMA Region 3, per MDEM. Local governments appealing FEMA Public Assistance denials must file administrative appeals within 60 calendar days of receiving a formal determination notice, under Section 423 of the Stafford Act and Title 44 of the Code of Federal Regulations, according to FEMA. Montgomery County ultimately won three appeals.
Nationwide, FEMA's most common grounds for denying or auditing municipal COVID-19 Public Assistance claims included potential duplication of benefits from patient care revenues, lack of documentation, and non-compliance with strict procurement standards, per Baker Donelson. Those same categories of obstacles likely shaped the administrative battles local governments across the country, including Montgomery County, faced in securing full reimbursement.
Elrich also credited federal assistance from U.S. Senator Chris Van Hollen and U.S. Representative Jamie Raskin in helping the county navigate federal bureaucracy throughout the multi-year appeal and auditing process, Montgomery Community Media reported. With the final payment now collected, the county's six-year reimbursement effort, which began with emergency reserve spending in the earliest, most uncertain days of the pandemic, has come to a close.
