MOTION-- Since the start of the COVID-19 Pandemic, the City has committed tens of millions of dollars
in funding from the general fund and loans from special funds in order to shelter
vulnerable people in environments that make them less susceptible to COVID-19 infection.
Among the strategies implemented by the City has been Project Roomkey, which operated
at various hotel properties providing over 1200 rooms for unhoused people. During the
Trump Administration, the Federal Emergency Management Agency guidance allowed for
reimbursements to cities of only 75% of costs of Project Roomkey, creating tremendous
budgetary pressure on the City's limited resources.
When the Biden administration announced a move from a 75% FEMA reimbursement
program for the City's pandemic expenses to a 100% reimbursement, the expenses eligible
for the expanded reimbursement included, among other things, "sheltering at risk
Local governments and agencies, including the City of Los Angeles, are already owed
hundreds of millions in FEMA reimbursements. As the pandemic continues, those
reimbursement requests will increase. Providing immediate reimbursement on existing
requests, or providing front fronting on new requests for the continuation and expansion of
Project RoomKey will help provide critical immediate relief for those already experiencing
homelessness. At current averages, the cost for 10,000 hotel units for 6 months would total
approximately $365M dollars.
To date, the city has only received a portion of the reimbursements for those eligible
expenses from FEMA, and has had to sacrifice services and slow the expansion of other
programs to shelter unhoused residents and support the pandemic recovery. The general
fund deficit of over $700 million means that there are no General Fund cash options to
provide the initial funding necessary to engage hotels in contracts that would be
reimbursable by FEMA, despite the more generous reimbursement opportunity.
Further, FEMA has instructed the Governor's office that the only unhoused persons eligible
for shelter longer than a quarantine period are those over 65 years of age or with an
underlying medical condition. Any other unhoused individuals would be eligible for a
reimbursed room only if they test positive for COVID-19 or were exposed to someone who
tested positive for COVID-19 and therefore require a limited quarantine period.
During major emergencies, the California Office of Emergency Services coordinates with
local agencies to determine needs, and in turn requests assistance from the Federal
Emergency Management Agency. For Los Angeles, the City’s Emergency Operations Center plays a critical role in that process, and has effectively done so during earthquakes and
other disasters. The pandemic has exposed critical vulnerability for homeless populations,
and while increased reimbursement rates for efforts such as Project RoomKey would be a
welcome relief, the City of Los Angeles needs immediate access to financial resources to
front-fund those reimbursements. Recognizing we are waiting for significant
reimbursements even prior to the announcement of increased reimbursement rates, we
must call upon the state and federal government's immediate assistance to secure
advanced funding to capitalize on this opportunity to provide emergency shelter to
thousands of displaced Angelenos.
WE THEREFORE MOVE that the Council INSTRUCT the City Administrative Officer to do the
1. Report to Council on potential funding sources for a substantially increased
utilization of Project Roomkey that would be FEMA-reimbursement eligible and not
restricted from federal reimbursement like the Coronavirus Relief Funds, including
but not limited to borrowing from special funds;
2. Seek immediate written guidance from FEMA on the timeline for when the city will
receive reimbursements for these expenses; and
3. Seek revisions of FEMA's previously issued guidance to specify that all unhoused
people are inherently more vulnerable to COVID-19 and therefore Project Roomkey
expenses for sheltering any unhoused person are reimbursable.
WE FURTHER MOVE that the Council REQUEST a report from the City Attorney on whether
the city can use federal funds, including FEMA reimbursements, for any activity that could
be considered a taking, and whether requiring involuntary hotel participation in Project
Roomkey could endanger the availability of FEMA reimbursement.
WE FURTHER MOVE that the Council INSTRUCT the CLA and CAO, in consultation with the
City Attorney's office, to report on whether the pending American Recovery Plan legislation
would allow the city to spend funds allocated to the city on FEMA-reimbursable expenses
or whether the use of new federal aid funds would preclude the city from seeking FEMA
reimbursements for otherwise eligible expenses financed out of new federal relief.
WE FURTHER MOVE that the City Council REQUEST the Emergency Operation Center,
including the Emergency Management Department, the City Administrative Officer, and the
Housing and Community Investment Department to formally request through the
California Office of Emergency Services, an advance of $150,000,000 from the Federal
Emergency Management Agency, creating an opportunity to front fund 40% of an effort to
provide 10,000 hotel rooms for the next 6 months.
WE FURTHER MOVE that the Housing and Community Investment Department and the
Chief Administrative Officer request from FEMA and HUD additional vouchers for
permanent housing placements to further implement permanent solutions for those
housed through Project RoomKey and beyond.