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

This memorandum directs FEMA to fund 100% of National Guard emergency assistance activities for 13 specified states responding to COVID-19 under state control, and directs the Secretary of Defense to request governors order National Guard forces to perform duty assignments on a reimbursable basis. It limits the 100% federal cost share to orders of 31 days or fewer that must be effective within 2 weeks of the memorandum date.

Federal Register Open PDF 85 FR 20383

Impact dates

Apr 21, 2020
National Guard orders of duty must be effective no later than 2 weeks from memorandum date

Key directives

FEMA to fund 100% of emergency assistance activities for National Guard forces in 13 specified states under sections 403 and 503 of Stafford Act
Secretary of Defense to request governors order National Guard to perform duty assignments pursuant to 32 U.S.C. 502(f) on fully reimbursable basis
Orders of duty must be effective no later than 2 weeks from April 7, 2020
100% federal cost share limited to orders of 31 days or fewer duration

Who is ordered

Timeline

Immediate

FEMA directed to fund 100% of National Guard activities for 13 states
Secretary of Defense directed to request governors order National Guard duty

Near term (90d)

National Guard orders must be effective no later than April 21, 2020
100% cost share limited to 31-day or fewer orders

Long term

Potential extension or expansion dependent on subsequent memoranda or policy changes

Risks & tensions

Limited to 13 states; other states not covered by this memorandum's 100% cost share
31-day order limit creates administrative burden of repeated renewals for extended pandemic response
Fully reimbursable basis for DoD-requested missions creates interagency fiscal complexity
Geographic proximity constraint may limit mission assignments