GAO-20-503, DISASTER ASSISTANCE: Additional Actions Needed

DISASTER

ASSISTANCE

Additional Actions

Needed to Strengthen

FEMA’s Individuals

and Households

Program

Report to Congressional Requesters

September 2020

GAO-20-503

United States Government Accountability Office

Highlights of GAO-20-503, a report to

congressional requesters

September 2020

DISASTER ASSISTANCE

Additional Actions Needed to Strengthen FEMA’s

Individuals and Households Program

What GAO Found

From 2016 through 2018, 5.6 million people applied for disaster assistance from

the Federal Emergency Management Agency (FEMA), and 4.4 million were

referred to the Individuals and Households Program (IHP) for assistance. For

eligible survivors, FEMA’s IHP can offer financial assistance—including money

for personal property losses and repair of certain home damages. The IHP may

also provide rental assistance or direct housing assistance, such as trailers,

when justified by the lack of available housing resources.

Individuals and Households Program (IHP) Assistance Awarded to Almost 2 Million Survivors

from 2016 through 2018

Type of Assistance

Amount of Assistance

Total Financial Assistance

$5.98 billion

Total Temporary Housing Assistance

12,805 housing units

Source: GAO analysis of IHP applicant data, as of February 24, 2020. | GAO-20-503

Of the 4.4 million referred to IHP, FEMA found almost 2 million eligible. On

average, FEMA awarded about $4,200 to homeowners and $1,700 to renters

during 2016 through 2018. FEMA determined roughly 1.7 million ineligible for IHP

assistance, and the most common reasons for ineligibility were insufficient

damage, failure to submit evidence to support disaster loses, and failure to make

contact with the FEMA inspector. The remaining applicants either withdrew from

IHP or received no determination due to missing insurance information. Program

outcomes also varied across demographic groups, such as age and income.

GAO found that survivors faced numerous challenges obtaining aid and

understanding the IHP, including the following:

• FEMA requires that certain survivors first be denied a Small Business

Administration (SBA) disaster loan before receiving certain types of IHP

assistance. FEMA, state, territory, and local officials said that survivors

did not understand and were frustrated by this requirement. GAO found

that FEMA did not fully explain the requirement to survivors and its

process for the requirement may have prevented many survivors from

being considered for certain types of assistance, including low-income

applicants who are less likely to qualify for an SBA loan. By fully

communicating the requirement and working with SBA to identify options

to simplify and streamline this step of the IHP process, FEMA could help

ensure that survivors receive all assistance for which they are eligible.

• Opportunities also exist to improve survivors’ understanding of FEMA’s

eligibility and award determinations for the IHP, for example, that an

ineligible determination is not always final, but may mean FEMA needs

more information to decide the award. By enhancing the clarity of its

determinations and providing more information to survivors about their

award, the agency could improve survivors’ understanding of the IHP,

better manage their expectations, build trust, and improve transparency.

Why GAO Did This Study

During the 2017 and 2018 disaster

seasons,

several sequential, large-

scale disasters created an

unprecedented demand for federal

disaster assistance. GAO was asked to

review issues related to the federal

response and recovery to the 2017

disaster season and

, specifically, the

effectiveness of the I

HP.

This report addresses (1) IHP

outcomes and challenges faced by

survivors from 2016 through 2018

; (2)

challenges FEMA faced implementing

the IHP during the same period

; and

(3)

FEMA efforts to assess and

improve the IHP,

among other things.

To answer th

ese objectives, GAO

analyzed data from all IHP applicants

from 2016 through 2018 and reviewed

relevant documentation and policies.

GAO also interviewed FEMA, state,

territory,

local, and nonprofit officials;

met with survivors; and visited

locations affected by hurricanes in

2017 and 2018 selected to include

multiple FEMA regions and other

characteristics.

What GAO Recommends

GAO is making 14 recommendations

and DHS concurred

To address challenges faced by

survivors, GAO recommends

improving the communication

of the

SBA loan requirement, identifying ways

to simplify the application process,

improve the IHP award determination

letters, and provide more information to

survivor

s about their award.

To address challenges FEMA faced

implementing the IHP, GAO

recommends improving the

communication of guidance changes,

ensure employee engagement to raise

morale, and improve training among

call center staff. GAO also

United States Government Accountability Office

Disaster Survivors Sought Assistance from the Individuals and Households Program (IHP) to

Recover from Hurricane Michael in Panama City, Florida

Further, GAO found that since 2016, FEMA faced challenges implementing the

IHP through its call center and field workforce, as well as coordinating with state

and local officials, as noted below:

• Regarding workforce management, GAO found that FEMA has faced

challenges managing its call center and field staff. Specific to their call

center workforce—who help survivors apply for IHP and process

assistance—challenges using program guidance, low morale, and

inadequate training following the catastrophic 2017 hurricane season

affected their work supporting disaster survivors. For example, while

FEMA issues standard operating procedure updates for processing IHP

applications, staff we spoke to at all four call centers noted that they

could not maintain awareness of IHP guidance because of its large

volume and frequent changes, which made it difficult for staff to

appropriately address survivor needs. Identifying ways to improve the

accessibility and usability of program guidance would help staff better

assist survivors. Further, FEMA staff at disaster recovery centers (DRC)

lacked some skills and capabilities needed to support survivors, such as

knowledge to provide accurate guidance about required documents. By

identifying and implementing strategies, such as on-the-job training, to

ensure staff at its DRCs have the needed capabilities, FEMA could

improve support and streamline the survivor experience.

• Regarding coordination, GAO found that state and local officials

generally had trouble understanding the IHP. For example, these officials

said that FEMA did not provide sufficient training, support, and guidance

that was needed in order for them to be able to effectively work with

FEMA to facilitate IHP assistance. Further, local officials expressed

challenges coordinating with FEMA regarding temporary housing units,

such as recreational vehicles. By providing more information on the IHP

to local officials, and implementing best practices for information-sharing

with recovery partners, FEMA could help ensure that state and local

recovery partners are better able to help survivors navigate the IHP and

effectively deliver temporary housing units to survivors.

Lastly, FEMA has planned or implemented multiple efforts to improve assistance

to survivors since 2017, including a redesign of the Individual Assistance

Program, which includes the IHP. However, GAO found that FEMA did not

complete activities that are critical to the success of a process improvement

effort, according to GAO’s Business Process Reengineering Assessment Guide.

Specifically, the agency did not fully assess customer and stakeholder needs and

performance gaps in the program, or set improvement goals and priorities for the

redesign. By completing these process improvement activities, FEMA will be able

to further refine the redesigned Individual Assistance Program, and more

effectively direct and focus its implementation efforts.

recommends strategies to ensure

DRC staff have the skills to support

survivors. GAO also recommends

improving IHP information provided to

state, local, tribal, and territorial

recovery partners; and identifying and

implementing best practices for

informati

on sharing and coordination

on the delivery of temporary

transportable housing.

To further FEMA efforts to assess

and improve the IHP, GAO

recommends corrections to the

methodology used to survey

survivors; following key process

improvement activities

—including

engaging stakeholders, assessing

performance gaps, and prioritization

of process improvement

—during

program redesign activities; and

establishing time

frames for strategic

planning and implementation of

program improvement efforts.

To view the supplements online, click:

http://www.gao.gov/products/GAO

-20-

674SP

and

http://www.gao.gov

/products/GAO-20-

675SP

View GAO-20-503. For more

information, contact

Chris Currie at (404)

679

-1875 or [email protected].

Page i GAO-20-503 Disaster Assistance

Letter 1

Background 7

FEMA Expended at Least $11.8 Billion through the IHP and

Generally Used a Consistent Process to Provide Assistance to

About 3 Million Disaster Survivors from 2010 through 2019 12

Survivors Had Varying Program Outcomes and Faced Challenges

Understanding and Navigating the IHP 22

FEMA Faced Challenges in Managing its IHP Workforce and

Supporting and Coordinating with Local Officials from 2016

through 2018 49

FEMA Assesses IHP Performance and Has Ongoing Efforts to

Improve Program Delivery, but Opportunities Exist to Further

Enhance These Efforts 67

Conclusions 75

Recommendations for Executive Action 76

Agency Comments and Our Evaluation 78

Appendix I Objectives, Scope, and Methodology 88

Appendix II Summary of Eligibility, Verification, and Delivery Considerations for

Individuals and Households Program Assistance 102

Appendix III Outcomes in the Individuals and Households Program by the Social

Vulnerability of an Applicant’s Community 110

Appendix IV The Small Business Administration’s Minimum Income Guidelines

for the Disaster Loan Program, Fiscal Year 2018 117

Appendix V Example of the Ineligible Determination Letter for the Individuals and

Households Program, 2019 118

Contents

Page ii GAO-20-503 Disaster Assistance

Appendix VI The Federal Emergency Management Agency’s Recent Efforts to

Improve the Individuals and Households Program 120

Appendix VII Comments from the Department of Homeland Security 124

Appendix VIII GAO Contact and Staff Acknowledgments 139

Tables

Table 1: Referred Applicants Who Appealed a Determination on

Financial Assistance from the Individuals and Households

Program (IHP) and Appeal Approval Rates, 2016 – 2018 29

Table 2: Time between Key Events in the Financial Assistance

Process for the Individuals and Households Program

(IHP), 2016 – 2018 31

Table 3: Number of Potentially Low-Income Individuals and

Households Program (IHP) Applicants Who Did Not

Submit the Small Business Administration (SBA) Loan

Application and Had Personal Property Loss Verified by

the Federal Emergency Management Agency (FEMA),

2016 – 2018 41

Table 4: General Eligibility Requirements, Verifications, and

Selected Adjusted Procedures to Meet Eligibility for the

Federal Emergency Management Agency’s (FEMA)

Individuals and Households Program Assistance 102

Table 5: Description of the Federal Emergency Management

Agency’s (FEMA) Eligibility Considerations for Types of

Direct Housing Assistance under the Individuals and

Households Program, according to March 2019 Guidance 104

Table 6: Description of the Federal Emergency Management

Agency’s (FEMA) Eligibility Considerations for Types of

Financial Housing Assistance under the Individuals and

Households Program (IHP), according to March 2019

Guidance 106

Table 7: Description of the Federal Emergency Management

Agency’s (FEMA) Eligibility Considerations for Types of

Other Needs Assistance under the Individuals and

Page iii GAO-20-503 Disaster Assistance

Households Program (IHP), according to March 2019

Guidance 107

Table 8: Referred Applicants Who Appealed a Determination on

Financial Assistance from the Individuals and Households

Program (IHP), and Appeal Approval Rates, by Social

Vulnerability, for Major Disaster Declarations That

Included Individual Assistance in U.S. States and Puerto

Rico, 2016 – 2018 114

Table 9: Time between Key Events in the Individuals and

Households Program (IHP) Financial Assistance Process,

by Social Vulnerability, for Major Disaster Declarations

That Included Individual Assistance in U.S. States and

Puerto Rico, 2016 – 2018 115

Table 10: The Small Business Administration’s (SBA) Minimum

Annual Income Guidelines (in dollars) for the Disaster

Loan Program, Fiscal Year 2018 117

Table 11: Description of the Federal Emergency Management

Agency’s (FEMA) Recent Efforts to Improve the

Individuals and Households Program (IHP) 120

Figures

Figure 1: Types of Assistance Available under the Individuals and

Households Program 9

Figure 2: Federal Emergency Management Agency (FEMA)

Regions, Four National Processing Service Centers, and

Field Locations for Hurricane Michael Recovery Efforts in

Florida 12

Figure 3: Expenditures for the Individuals and Households

Program and Number of Major Disaster Declarations

That Included Individual Assistance, 2010 – 2019 13

Figure 4: Percentage of Expenditures by Type of Financial

Assistance under the Individuals and Households

Program, 2010 – 2019 14

Figure 5: Number of Applicants Who Received Financial

Assistance from the Individuals and Households Program

(IHP) and Median and Average Award Amounts, 2010 –

2019 15

Figure 6: The Federal Emergency Management Agency’s (FEMA)

Process for Financial Assistance under the Individuals

and Households Program (IHP) 16

Page iv GAO-20-503 Disaster Assistance

Figure 7: Eligibility Status Rates for Disaster Survivors Referred to

the Federal Emergency Management Agency’s (FEMA)

Individuals and Households Program, from 2010 through

2019 18

Figure 8: Notional Case of Two Families with Similar Damage and

Different Awards Because of Individuals and Households

Program Eligibility Criteria and Circumstances 20

Figure 9: Federal Emergency Management Agency (FEMA)

Process for Assessing Need and Providing Direct

Housing Assistance to Eligible Survivors 21

Figure 10: Referred Applicants and Approval Rates for the

Individuals and Households Program (IHP), 2016 – 2018 24

Figure 11: Average Award Amounts and Number of Owners and

Renters Who Received Financial Assistance through the

Individuals and Households Program (IHP), 2016 – 2018 26

Figure 12: Most Common Reasons Referred Applicants Were

Determined Ineligible for Assistance from the Individuals

and Households Program (IHP), 2016 – 2018 28

Figure 13: Process for Determining a Survivor’s Eligibility for

Disaster Assistance from the Federal Emergency

Management Agency (FEMA) and the Small Business

Administration (SBA) 35

Figure 14: Small Business Administration (SBA) Loan Status of

Survivors Who Applied for Assistance from the

Individuals and Households Program (IHP), 2016 – 2018 36

Figure 15: Selected Steps and Required Coordination to Deliver a

Transportable Temporary Housing Unit through the

Federal Emergency Management Agency’s (FEMA)

Individuals and Households Program (IHP) 64

Figure 16: Referred Applicants and Approval Rates for the

Individuals and Households Program (IHP), by Social

Vulnerability, for Major Disaster Declarations That

Included Individual Assistance in U.S. States and Puerto

Rico, 2016 – 2018 111

Figure 17: Average Award Amounts and Number of Owners and

Renters Who Received Financial Assistance through the

Individual and Households Program (IHP), by Social

Vulnerability, for Major Disaster Declarations That

Included Individual Assistance in U.S. States and Puerto

Rico, 2016 – 2018 112

Figure 18: Most Common Reasons Referred Applicants Were

Determined Ineligible for Assistance from the Individuals

Page v GAO-20-503 Disaster Assistance

and Households Program (IHP), by Social Vulnerability,

for Major Disaster Declarations That Included Individual

Assistance in U.S. States and Puerto Rico, 2016 – 2018 113

Abbreviations

DHS Department of Homeland Security

DRC Disaster Recovery Center

FEMA Federal Emergency Management Agency

IHP Individuals and Households Program

NGO Nongovernmental organization

NPSC National Processing Service Center

ONA Other needs assistance

SBA Small Business Administration

SOP Standard Operating Procedures

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Page 1 GAO-20-503 Disaster Assistance

441 G St. N.W.

Washington, DC 20548

September 30, 2020

Congressional Requesters

In 2017, Hurricanes Harvey, Irma, and Maria, along with devastating

wildfires in California, affected more than 47 million people in the United

States—about 15 percent of the national population—and Hurricanes

Florence and Michael caused significant damage in 2018.

The Federal

Emergency Management Agency (FEMA), a component of the

Department of Homeland Security (DHS), leads the nation’s efforts to

prepare for, protect against, respond to, recover from, and mitigate

against the risk of disasters.

FEMA’s Individuals and Households

Program (IHP) provides financial assistance and direct services to eligible

individuals and households who have uninsured or underinsured

necessary expenses and serious needs as a result of a disaster.

For

example, the IHP provides various types of financial assistance for home

repairs, child care, and transportation and is intended to distribute this

assistance quickly.

In 2019, we reported on FEMA’s efforts to provide disaster assistance to

individuals who are older or have disabilities.

We recommended, among

other things, that FEMA implement new application questions that

improve FEMA’s ability to identify and address survivors’ disability-related

needs. FEMA concurred and implemented this recommendation in May

2019 by using a revised application that asked directly if survivors had a

disability. According to FEMA’s analysis, the percentage of survivors that

identified as having a disability-related need increased substantially after

implementing the revised application questions. However, FEMA did not

concur with our recommendation to improve communication of applicants’

disability-related information across FEMA programs. We continue to

Hurricane Harvey was in Texas; Hurricane Irma was in Alabama, Florida, Georgia, North

Carolina, South Carolina, Puerto Rico, and the U.S. Virgin Islands; and Hurricane Maria

was in Puerto Rico and the U.S. Virgin Islands. Unless otherwise noted, the years

discussed in this report are calendar years because that is how the Federal Emergency

Management Agency accounts for disaster declarations.

See 6 U.S.C. § 313.

See 42 U.S.C. § 5174.

GAO, Disaster Assistance: FEMA Action Needed to Better Support Individuals Who Are

Older or Have Disabilities, GAO-19-318 (Washington, D.C.: May 14, 2019).

Letter

Page 2 GAO-20-503 Disaster Assistance

believe that FEMA can improve this communication through cost-effective

ways, such as revising guidance to remind program officials to review

survivor case files for disability-related needs. In 2018, we reported our

initial observations on the federal response and key recovery challenges

for the 2017 hurricanes and wildfires.

Among other things, we reported

that federal, state, territory, and local officials faced challenges finding

temporary housing for disaster survivors. Further, state officials noted

challenges in managing housing programs, such as staffing shortfalls,

and challenges in coordinating with FEMA that led to delays in providing

assistance to survivors.

After a disaster, survivors are vulnerable. According to FEMA,

catastrophic disasters are difficult and life-changing events that disrupt

lives and hurt communities economically and socially. For example,

severe disasters may lead to the loss of life, render homes uninhabitable,

destroy important documents and possessions, and permanently displace

people from their communities. To help individuals and households deal

with the effects of disasters, FEMA established a strategic goal in its

2018-2022 Strategic Plan to reduce the complexity of FEMA to, among

other things, streamline disaster survivor experiences in dealing with the

agency.

You asked us to review a broad range of issues related to disaster

response and recovery following the 2017 disaster season. This report

addresses: (1) IHP expenditures from 2010 through 2019 and the

processes that FEMA used to deliver IHP assistance to disaster

survivors, (2) outcomes and challenges survivors experienced in

obtaining IHP assistance from 2016 through 2018, (3) challenges FEMA

experienced with implementing the IHP from 2016 through 2018, and (4)

the extent to which FEMA has assessed the IHP and initiated efforts to

improve the program in recent years.

GAO, 2017 Hurricanes and Wildfires: Initial Observations on the Federal Response and

Key Recovery Challenges, GAO-18-472 (Washington, D.C.: Sept. 4, 2018). Also, see

Wildfire Disasters: FEMA Could Take Additional Actions to Address Unique Response and

Recovery Challenges, GAO-20-5 (Washington, D.C.: Oct. 9, 2019); U.S. Virgin Islands

Recovery: Additional Actions Could Strengthen FEMA’s Key Disaster Recovery Efforts,

GAO-20-54 (Washington, D.C.: Nov. 19, 2019);and Puerto Rico Disaster Recovery: FEMA

Actions Needed to Strengthen Project Cost Estimation and Awareness of Program

Guidance, GAO-20-221 (Washington, D.C.: Feb. 5, 2020).

We are currently reviewing FEMA’s process for inspecting damaged property for its IHP.

Page 3 GAO-20-503 Disaster Assistance

To address our first objective, we reviewed relevant laws and FEMA IHP

program guidance, including the March 2019 Individual Assistance

Program and Policy Guide,

to understand FEMA’s policies and

processes for providing assistance through the IHP, including how

disaster survivors apply for IHP assistance and how FEMA determines

applicants’ eligibility for assistance and the type and amount of assistance

to provide. We also analyzed IHP expenditure data from FEMA’s

Integrated Financial Management Information System, and application,

eligibility, award, and appeals data from the National Emergency

Management Information System for major disaster declarations that

included Individual Assistance during calendar years 2010 through 2019.

We selected the most recent 10-year period because we wanted to focus

on long-term trends. We assessed the reliability of data from these two

systems by reviewing existing information about these systems’

capabilities, interviewing data users and managers responsible for these

data from FEMA’s Office of the Chief Financial Officer and Recovery

Analytics Division, and cross-checking data across different sources to

ensure data consistency. Based on these steps, we determined these

data to be sufficiently reliable for the purposes of describing IHP applicant

and expenditure data. We also interviewed officials from FEMA’s

Individual Assistance Division and IHP Service Delivery Branch to discuss

IHP expenditures and processes.

To address our second objective, we analyzed FEMA’s IHP applicant

data from the National Emergency Management Information System for

all 5.6 million disaster survivors who applied for assistance for major

disaster declarations that included Individual Assistance from 2016

through 2018—the 3 most recent years for which complete application

data were available. We analyzed FEMA’s IHP applicant data to identify

and compare various outcomes, such as approval, award, and appeal

rates, overall and across different survivor groups, from 2016 through

2018. We assessed the reliability of FEMA’s IHP applicant data by

reviewing existing information about the National Emergency

Management Information System, including internal controls; interviewing

data users and managers responsible for these data from FEMA’s

Federal Emergency Management Agency (FEMA), Individual Assistance Program and

Policy Guide (IAPPG), FP 104-009-03 (Washington, D.C.: Mar. 4, 2019).

The Integrated Financial Management Information System is FEMA’s official accounting

and financial system that tracks all of the agency’s financial transactions. National

Emergency Management Information System is a database system used to track disaster

data for FEMA and grantees. Although the IHP may offer direct housing assistance, we

use “award” to refer to financial assistance throughout this report.

Page 4 GAO-20-503 Disaster Assistance

Recovery Analytics Division; and testing the data for missing data,

outliers, and obvious errors. Based on these steps, we determined these

data to be sufficiently reliable for the purposes of reporting IHP outcomes

from 2016 through 2018.

We also conducted semistructured interviews with state emergency

management officials, local officials responsible for leading disaster

recovery efforts, and officials from nongovernmental organizations (NGO)

that help disaster survivors access and navigate the IHP from California,

Florida, North Carolina, Texas, and Puerto Rico. We selected these four

states and Puerto Rico because they were among those states and U.S.

territories that experienced significant damage from disasters during

calendar years 2016 through 2018. For our interviews with local officials

responsible for disaster recovery efforts, we selected two counties in each

state and two municipalities in Puerto Rico that had higher numbers of

IHP applications.

For our interviews with NGO officials, we selected one

or two NGOs in each of our selected states and Puerto Rico, which we

identified through discussions with FEMA, state, and local officials, and

officials from other NGOs.

Further, we interviewed officials responsible

for implementing the IHP from FEMA’s headquarters and all four National

Processing Service Centers (NPSC), as well as FEMA’s Regions II, IV,

VI, and IX, which are the regions responsible for liaising with and

supporting our four selected states and Puerto Rico. The results of our

interviews cannot be generalized; however, they provide valuable

perspectives on particular challenges that disaster survivors faced in

obtaining IHP assistance.

In addition, we reviewed the requirement for certain IHP applicants to also

apply to the Small Business Administration’s (SBA) Disaster Home Loan

Program, and FEMA’s communication of this requirement to survivors.

We compared FEMA’s process and communication efforts regarding this

requirement to the goals and objectives in FEMA’s 2018-2022 Strategic

Plan

and the federal government’s roles and responsibilities outlined in

We interviewed local officials from Harris County, TX; Jefferson County, TX; Bay County,

FL; Jackson County, FL; Craven County, NC; Pender County, NC; Butte County, CA;

Sonoma County, CA; Caguas, PR; and Bayamon, PR.

We interviewed officials from Lone Star Legal Aid (TX); The Facilitators: Camp Ironhorse

(PR); Endeavors (PR and NC); Rebuild Bay County (FL); SBP (FL); and Catholic Charities

(CA).

Federal Emergency Management Agency, 2018-2022 Strategic Plan, (Washington,

D.C.: Mar. 15, 2018).

Page 5 GAO-20-503 Disaster Assistance

the National Disaster Recovery Framework.

We also analyzed previous

and current versions of FEMA’s IHP ineligible determination letters using

the Flesch Reading Ease score,

the Plain Writing Act of 2010,

and the

Substance Abuse and Mental Health Administration’s guidance on

disaster communications.

Lastly, we compared the amount of

information FEMA provides to IHP applicants about their case for

assistance to the federal government’s roles and responsibilities outlined

in the National Disaster Recovery Framework and the Substance Abuse

and Mental Health Administration’s key principles for serving individuals

suffering from trauma, such as those who experienced a disaster.

To address our third objective, we interviewed officials responsible for

implementing the IHP from FEMA’s headquarters and all four NPSCs, as

well as FEMA Regions II, IV, VI, and IX. We also interviewed state,

territory, local, and NGO officials in California, Florida, North Carolina,

Texas, and Puerto Rico, to understand their experiences, including any

challenges, working with FEMA to deliver the IHP. The results of our

interviews cannot be generalized; however, they provide valuable context

for any challenges FEMA experienced with implementing the IHP.

Further, we analyzed FEMA’s standard operating procedures for the IHP

and documentation on workforce capabilities, as well as information

provided to state and local officials, and compared them to Standards for

Internal Control in the Federal Government, a GAO human capital guide,

Department of Homeland Security. National Disaster Recovery Framework, 2nd ed.

(Washington, D.C.: June 2016).

Flesch Reading Ease scores fall on a scale from 0 to 100, with 0 being nearly

impossible to read and 100 being simple enough for a fifth grader to read. The formula is

based on average sentence length and average word length. The version we used was

included in the Microsoft Word processing software. As we have previously reported, the

Flesch Reading Ease score is one of the most widely used, tested, and reliable formulas

for calculating readability. See GAO, Vehicle Data Privacy: Industry and Federal Efforts

Under Way, but NHTSA Needs to Define Its Role, GAO-17-656 (Washington, D.C.: July

28, 2017).

Pub. L. No. 111-274, 124 Stat. 2861 (codified at 5 U.S.C. § 301 note).

epartment of Homeland Security. National Disaster Recovery Framework; Substance

Abuse and Mental Health Services Administration, Communicating in a Crisis: Risk

Communication Guidelines for Public Officials, SAMHSA Publication No. PEP19-01-01-

005 (Rockville, MD, 2019).

Substance Abuse and Mental Health Services Administration, SAMHSA’s Concept of

Trauma and Guidance for a Trauma-Informed Approach, HHS Publication No. (SMA) 14-

4884 (Rockville, MD, 2014).

Page 6 GAO-20-503 Disaster Assistance

FEMA’s 2018–2022 Strategic Plan, and the National Disaster Recovery

Framework.

To address our fourth objective, we analyzed documentation on FEMA

assessments and performance reports for the IHP, as well as data on

surveys that FEMA conducted with survivors who applied for the IHP. We

compared FEMA’s methodology for its IHP surveys to the Office of

Management and Budget’s Standards and Guidelines for Statistical

Surveys.

We also analyzed documentation on FEMA initiatives and

recommendations aimed at addressing challenges with the IHP, and

compared these efforts with key process improvement and program

management activities from GAO’s Business Process Reengineering

Assessment Guide and The Standard for Program Management.

also interviewed officials from FEMA’s Individual Assistance Division and

Recovery Analytics Division, which manages data and analytics for

Individual Assistance, and the IHP Service Delivery Branch, which

manages the IHP.

We conducted this performance audit from October 2018 to September

2020 in accordance with generally accepted government auditing

standards. Those standards require that we plan and perform the audit to

obtain sufficient, appropriate evidence to provide a reasonable basis for

our findings and conclusions based on our audit objectives. We believe

that the evidence obtained provides a reasonable basis for our findings

and conclusions based on our audit objectives.

Further information on our scope and methodology can be found in

appendix I.

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G

(Washington, D.C.: September 2014); and Human Capital: A Guide for Assessing

Strategic Training and Development Efforts in the Federal Government, GAO-04-546G

(Washington, D.C.: March 2004); and Federal Emergency Management Agency, 2018–

2022 Strategic Plan; and Department of Homeland Security, National Disaster Recovery

Framework.

Office of Management and Budget, Standards and Guidelines for Statistical Surveys

(Washington, D.C.: September 2006).

GAO, Business Process Reengineering Assessment Guide, Version 3,

GAO/AIMD-10.1.15 (Washington, D.C.: May 1997). Project Management Institute, Inc.,

The Standard for Program Management—Fourth Edition® (2017).

Page 7 GAO-20-503 Disaster Assistance

The Robert T. Stafford Disaster Relief and Emergency Assistance Act

(Stafford Act) establishes the process for states, territories, and tribes to

request a presidential major disaster or emergency declaration, which, if

approved, triggers a variety of federal response and recovery programs

for government and nongovernmental entities, households, and

individuals. One of these programs is FEMA’s Individual Assistance

Program, which provides assistance to disaster survivors to cover

necessary expenses and serious needs such as housing assistance,

counseling, child care, unemployment compensation, or medical

expenses, that cannot be met through insurance or low-interest loans.

The Individual Assistance Program consists of six sub-programs:

• IHP. Provides financial assistance and direct services for housing and

other types of assistance to individuals and households who have

uninsured or underinsured necessary expenses and serious needs

due to a disaster;

• Mass Care and Emergency Assistance. Provides life-sustaining

services and resources to disaster survivors, such as shelter and

food;

• Crisis Counseling Assistance and Training Program. Assists

individuals and communities in recovering from psychological effects

of a disaster;

• Disaster Unemployment Assistance. Provides unemployment

benefits and reemployment services to individuals unemployed

because of a disaster;

• Disaster Legal Services. Provides free legal help to low-income

survivors of a disaster; and

• Disaster Case Management. Provides a survivor with a single point

of contact to facilitate access to a broad range of services.

Almost three-fourths of the expenditures under the Individual Assistance

Program were for the IHP from 2010 through 2019.

We discuss IHP

expenditures later in this report.

An expenditure is an amount paid by federal agencies, by cash or cash equivalent, to

liquidate government obligations.

Background

FEMA’s Role in Providing

Disaster Assistance to

Individuals and

Households

Page 8 GAO-20-503 Disaster Assistance

The IHP provides two categories of assistance: (1) housing assistance

and (2) other needs assistance (ONA).

Housing assistance. FEMA may provide financial and direct (i.e.,

nonfinancial) housing assistance to individuals and households, who are

displaced or whose residences are rendered uninhabitable as a result of

damage caused by a major disaster.

Financial assistance may include

lodging expense reimbursement for time spent at hotels or other

temporary lodging, rental assistance, and home repair or replacement

assistance.

Based on a request from the state, territory, or tribal government, FEMA

may provide direct housing assistance when eligible disaster survivors

are unable to use rental assistance. This type of assistance includes the

repair and lease of multifamily housing units—such as apartments—for

temporary use by survivors, direct lease assistance, and Transportable

Temporary Housing Units, such as recreational vehicles or manufactured

housing units. Transportable Temporary Housing Units can be placed on

private sites, commercial sites or on group sites. Commercial sites are

existing manufactured home sites with available pads that FEMA may

lease. Group sites require additional approval when housing needs

cannot be met by other direct temporary housing options. They may

include publicly-owned land with adequate available utilities. FEMA may

also provide assistance for permanent or semipermanent housing

construction when no alternative housing resources are available and the

types of temporary housing discussed above are unavailable, infeasible,

or not cost-effective.

ONA. This consists of financial assistance for other necessary expenses

and serious needs caused by the disaster. Some types of ONA are only

provided if an individual does not qualify for a disaster loan from the SBA;

this assistance includes personal property (e.g., furniture) and

transportation assistance, and group flood insurance policies (collectively

referred to as SBA-dependent ONA). However, FEMA requires

individuals with certain income levels based on family size to apply to the

SBA Disaster Loan Program and be denied or receive a partial loan

42 U.S.C. 5174(b)(1)). FEMA may provide such assistance to individuals with disabilities

whose residences are rendered inaccessible or uninhabitable as a result of damage

caused by a major disaster.

42 U.S.C. § 5174(c)(4).

IHP Assistance

Permanent Housing Construction Provided

through the Individuals and Households

Program

The Federal Emergency Management Agency

(FEMA) made repairs to the stairs, elevated

entrance (top), and interior (bottom) of the

home through the Permanent Housing

Construction program. This included new

appliances and cabinets in the kitchen, and

repairs to the doors, windows, walls, ceiling,

light fixtures, and floor.

Source: GAO; photos taken by GAO while on site in Puerto

Rico | GAO-20-503

Page 9 GAO-20-503 Disaster Assistance

before FEMA will consider them for SBA-dependent ONA. Other types of

ONA can be provided regardless of SBA loan qualification, including

funeral, medical, dental, child care, critical needs, and clean and removal

assistance, and other miscellaneous items (e.g., tools).

Figure 1 illustrates the types of IHP housing assistance and ONA

available to individuals. However, not all types of assistance are

automatically available for every disaster declaration.

Figure 1: Types of Assistance Available under the Individuals and Households Program

FEMA requires individuals with certain incomes based on family size to apply to the Small Business

Administration (SBA) Disaster Loan Program and be denied or receive a partial loan before FEMA will

consider them for SBA-dependent ONA.

FEMA plans to implement moving and storage assistance as non-SBA dependent ONA in fall 2020,

according to agency officials.

Critical needs assistance may be provided to survivors with immediate or critical needs

because they are displaced from their primary dwelling. Immediate or critical needs are

life-saving and life-sustaining items, including: water, food, first aid, prescriptions, infant

formula, diapers, consumable medical supplies, durable medical equipment, personal

hygiene items, and fuel for transportation.

Page 10 GAO-20-503 Disaster Assistance

According to FEMA officials, the IHP is intended to supplement

individuals’ recovery efforts and is not a substitute for insurance. Most

forms of IHP assistance are capped at a maximum amount an eligible

survivor can receive, which is adjusted annually based on changes in the

Consumer Price Index for All Urban Consumers, as published by the

Department of Labor, and IHP assistance is generally limited to 18

months following the date of the disaster declaration. FEMA may extend

the period of assistance upon a determination, at the request of a state,

territorial, or tribal government, that due to extraordinary circumstances

an extension would be in the public interest.

In 2018, the Stafford Act was amended by the Disaster Recovery Reform

Act of 2018, and those amendments generally apply to each major

disaster and emergency declared by the President on or after August 1,

2017.

The act includes a provision that establishes separate maximum

amounts for financial housing assistance and ONA, thus doubling the

maximum amount an eligible survivor could receive.

For example, prior

to the enactment of the act, the maximum amount of financial assistance

an eligible survivor could receive in 2018 was $34,000. As a result of the

act, the maximum amount of financial assistance an eligible survivor

could receive in 2018 was $68,000 ($34,000 for financial housing

assistance plus $34,000 for ONA). The act also removed temporary

housing assistance and assistance for disability-related real and personal

property items from the financial assistance limits, so there is no limit for

those items.

The IHP is managed by FEMA’s IHP Service Delivery Branch, which is

decentralized and has staff at FEMA headquarters in Washington, D.C.,

and four NPSCs located in Winchester, Virginia; Hyattsville, Maryland;

Denton, Texas; and Caguas, Puerto Rico. According to FEMA officials,

the branch has approximately 1,300 staff and consists of three sections—

(1) Program Management, (2) Field Services, and (3) Applicant Services.

42 U.S.C. § 5174(h), (c)(1)(B)(iii); 44 C.F.R. § 206.110(b), (e). As discussed below,

temporary housing assistance and assistance for disability-related real and personal

property items are not subject to the financial assistance limits. 42 U.S.C. § 5174(h).

Pub. L. No. 115-254, div. D, § 1202(a), 132 Stat. 3186, 3438.

Id. at § 1212, 132 Stat. at 3448 (codified at 42 U.S.C. § 5174(h)).

Id.

IHP Organization

Page 11 GAO-20-503 Disaster Assistance

1. The Program Management Section develops and implements policies,

ensures coordination throughout the IHP, and manages direct housing

efforts.

2. The Field Services Section delivers services to disaster survivors and

coordinates the deployment of resources to the field. This section

includes the Housing Inspections Services Unit, Disaster Recovery

Center (DRC) Unit, and Disaster Survivor Assistance Unit.

3. The Applicant Services Section includes almost 1,000 call center and

case processing staff who help survivors apply for FEMA assistance,

answer their questions on the Disaster Helpline, and process cases

for IHP assistance.

IHP operations are implemented in the field by staff from FEMA’s regions,

the Individual Assistance and Disaster Survivor Assistance cadres, FEMA

Corps, and the Housing Inspections Unit.

Staff from FEMA’s regions

manage and oversee the implementation of the IHP at Joint Field Offices

and Area Field Offices for disaster declarations in their region.

In areas

impacted by a disaster, FEMA establishes DRCs, which are facilities

where survivors may go to apply for the IHP and obtain information about

other FEMA programs, as well as other disaster assistance programs.

During 2016 through 2018, the daily average total staff from the Individual

Assistance and Disaster Survivor Assistance cadres and FEMA Corps

supporting Individual Assistance and IHP operations was over 3,000. To

provide an example of how IHP operations are organized, figure 2 shows

the FEMA regions and four NPSCs, as well as the field locations for

FEMA’s recovery efforts for Hurricane Michael in Florida.

A “cadre” is a group of FEMA employees organized by operational or programmatic

functions and FEMA Qualification System positions that perform disaster-related activities

during FEMA disaster operations. FEMA Corps are members of AmeriCorps National

Civilian Community Corps who work under supervision of FEMA staff.

A Joint Field Office is a temporary federal multiagency coordination center established

locally to facilitate field-level domestic incident management activities, and provides a

central location for coordination of federal, state, territory, local, tribal, nongovernmental,

and private-sector organizations with primary responsibility for activities associated with

threat response and incident support. An Area Field Office supports a Joint Field Office

and is its forward element responsible for a specific geographic area.

Federal Emergency Management Agency

(FEMA) Field Services Section Tent and

Staff

FEMA deploys staff to the field to assist

survivors at Disaster Recovery Centers and

conduct survivor outreach.

Source: GAO; photos taken by GAO while on site in Florida

and North Carolina. | GAO-20-503

Page 12 GAO-20-503 Disaster Assistance

Figure 2: Federal Emergency Management Agency (FEMA) Regions, Four National Processing Service Centers, and Field

Locations for Hurricane Michael Recovery Efforts in Florida

FEMA Expended at

Least $11.8 Billion

through the IHP and

Generally Used a

Consistent Process to

Provide Assistance to

About 3 Million

Disaster Survivors

from 2010 through

2019

Page 13 GAO-20-503 Disaster Assistance

For the 161 major disaster declarations from calendar years 2010 through

2019 that included Individual Assistance, FEMA expended at least $11.8

billion in IHP assistance to eligible survivors—$10.4 billion in financial

assistance, including ONA, and at least $1.4 billion in direct housing

assistance (see fig.3). Approximately 40 percent of the $11.8 billion from

2010 through 2019 was expended in 2017 due to Hurricanes Harvey,

Irma, Maria, and the California wildfires. IHP financial assistance

expenditures ranged from a low of $235 million in 2014 to a high of $4.2

billion in 2017. IHP direct housing expenditures ranged from a low of at

least $4 million in 2010 to a high of at least $507 million in 2017.

Figure 3: Expenditures for the Individuals and Households Program and Number of Major Disaster Declarations That Included

Individual Assistance, 2010 – 2019

Notes: Expenditures have not been adjusted for inflation. Financial assistance includes other needs

assistance (ONA).

Three types of IHP financial assistance accounted for 89 percent of

expenditures from 2010 through 2019—home repair (48 percent), rental

assistance (26 percent), and personal property assistance under ONA (15

percent), as shown in figure 4.

FEMA Expended over $11

Billion through the IHP for

About 3 Million Eligible

Survivors from 2010

through 2019

Type of Assistance Awarded

Page 14 GAO-20-503 Disaster Assistance

Figure 4: Percentage of Expenditures by Type of Financial Assistance under the

Individuals and Households Program, 2010 – 2019

From 2010 through 2019, FEMA determined that about 3 million survivors

were eligible for IHP assistance, and the number of survivors who

received IHP financial assistance ranged from a low of about 58,000 in

2015 to a high of about 1.7 million in 2017. The overall median and

average amounts of IHP financial assistance that FEMA provided per

eligible survivor were $1,332 and $3,522, respectively, for the 10-year

period from 2010 through 2019.

The average amount of IHP financial

assistance provided to eligible survivors ranged from a low of $2,508 in

2017 to a high of $6,916 in 2016. The median amount provided to eligible

survivors ranged from a low of $927 in 2017 to a high of $3,391 in 2012

(see fig. 5). From 2010 through 2019, approximately 1 percent of all IHP

In this report, “average” amount of IHP assistance refers to the mean amount. We

present the median in addition to the average (mean) assistance amount because the

distribution of IHP financial assistance is skewed toward larger amounts, as indicated by

the substantial difference between the average and median amounts of IHP assistance.

This is because some survivors received significantly higher amounts of IHP financial

assistance, which increases the mean value (because it is based on all values in the

distribution), but does not affect the median value, which is less sensitive to extreme

values (because it is based on the middle value of the data).

Amount of IHP Assistance per

Eligible Survivor

Page 15 GAO-20-503 Disaster Assistance

applicants who received IHP financial assistance (33,051) received the

maximum award under the Stafford Act or the Stafford Act, as amended

by the Disaster Recovery Reform Act of 2018. Regarding the amount of

IHP financial assistance that FEMA provided per eligible survivor during

this 10-year time period, FEMA stated that it encourages all disaster

survivors with damage to apply for the IHP, which leads to a larger pool of

eligible applicants and many of them have minimal damage, thus, driving

down the average award amount.

Figure 5: Number of Applicants Who Received Financial Assistance from the

Individuals and Households Program (IHP) and Median and Average Award

Amounts, 2010 – 2019

Note: Award amounts have not been adjusted for inflation.

Page 16 GAO-20-503 Disaster Assistance

While FEMA adjusts the IHP to respond to disaster scenarios and

changes in technology—such as developing new forms of assistance and

developing smartphone applications to help disaster survivors register for

assistance—the IHP has generally followed a consistent process for

delivering assistance. This process includes the following four key steps:

(1) application, (2) referral, (3) verification of disaster-caused losses, and

(4) eligibility and award determination. In certain disasters, FEMA may

also offer direct housing assistance and use a separate process to

evaluate their eligibility and deliver assistance, when relevant. Throughout

this process, survivors have the opportunity to appeal certain IHP

decisions (see fig. 6).

Figure 6: The Federal Emergency Management Agency’s (FEMA) Process for Financial Assistance under the Individuals and

Households Program (IHP)

Note: The IHP generally limits applications for assistance to one per household. An applicant may

represent one person or multiple people.

FEMA processes the application information using its National

Emergency Management Information System—which collects and routes

applications through all decision points following rules defined in the

software—and refers disaster survivors to the IHP that meet certain

conditions, including that the survivor reported that they experienced

FEMA Generally Used a

Consistent Process for

Delivering Assistance and

Found Fewer than Half of

Applicants Eligible for

Assistance from 2010 to

2019

Page 17 GAO-20-503 Disaster Assistance

home damages or personal losses because of the disaster.

Lastly,

FEMA must review documentation to verify that survivors meet the

general eligibility to receive assistance.

From 2010 through 2019, FEMA found that less than half (46.7 percent)

of disaster survivors referred to the program were eligible for assistance.

During this time, FEMA did not make an eligibility determination for

577,000 (9.1 percent) of disaster survivors referred to the program

because they did not submit insurance information. Over 416,000 (72.1

percent) of those who received no eligibility decision due to insurance

information were survivors from disasters in 2017 and 2018. In cases

where FEMA does not make an eligibility determination because of

missing insurance documentation, FEMA communicates this decision to

survivors as a denial of assistance, by mail or email. Applicants have 60

days to appeal the decision and up to a year to provide insurance

documentation. Figure 7 shows trends in eligibility rates.

IHP assistance is available for disaster-caused damages to the home, referred to as real

property, for applicants who own their home as their primary residence. Other assistance

is available, for both homeowners and renters, for items that were lost or damaged due to

the disaster, referred to as personal property. Throughout the report, we refer to disaster

damages, which may mean real property or personal property losses.

Page 18 GAO-20-503 Disaster Assistance

Figure 7: Eligibility Status Rates for Disaster Survivors Referred to the Federal

Emergency Management Agency’s (FEMA) Individuals and Households Program,

from 2010 through 2019

Note: From 2010 through 2019, FEMA also did not make eligibility determinations for 156 applicants

with a status that remained “pending.” This reflects less than .01 percent of referred survivors and is

not visible on the figure. According to FEMA, pending eligibility determinations reflect a processing

error that require manual corrections to ensure payment of any eligible assistance.

After the National Emergency Management Information System refers

disaster survivors to the IHP for assistance, FEMA may conduct a

housing inspection specifically to assess and verify that the IHP covered

disaster damages. The inspection does not collect information on all

damages because IHP assistance does not address all damages

resulting from a disaster; for example, home repair assistance provides

assistance only to restore the home to a safe and sanitary living or

functioning condition.

Inspectors record the cause of damage and

See 44 C.F.R. § 206.117(b)(2)(iii).

FEMA Considers Various

Factors to Determine

Type and

Amount of Assistance

Page 19 GAO-20-503 Disaster Assistance

confirm the size of the home and number of people living there, among

other details. The inspector will also verify eligible transportation losses

caused by the disaster.

FEMA considers a variety of factors specific to the disaster survivor’s

unique circumstances when determining the type and amount of

assistance to award and may use alternative verifications to determine

eligibility based on disaster-specific circumstances, as was the case for

multiple disasters in 2017 and 2018. Further, each type of assistance may

have additional conditions of eligibility and verification requirements

beyond the general eligibility requirements noted above. For example, in

the case of multiple roommates who share a damaged residence, FEMA

follows different eligibility criteria and limitations when determining the

amount of personal property assistance but follows the standard criteria

for awarding transportation assistance, among others.

See appendix II

for a summary of adjusted verification procedures for general eligibility

requirements, as well as the additional eligibility requirements and

verification procedures specific to each type of assistance.

According to FEMA officials, considerations that frequently affect award

determination are availability of insurance, number of people in the

household, and whether the IHP allows assistance for the survivor’s

specific disaster damages and losses. For example, FEMA subtracts any

insurance settlements an applicant receives from their award. FEMA

considers household composition and provides assistance for personal

property damages in one bedroom when there is only one adult living in

the home, even if there were multiple bedrooms with damages. Figure 8

below demonstrates these considerations.

We plan to conduct a review in late 2020 on the challenges FEMA faced managing

housing inspections for the determination of IHP awards.

While transportation assistance is limited to one damaged vehicle per household, FEMA

may consider providing assistance for more than one vehicle in the case of roommates

when the survivor provides justification of their need.

Page 20 GAO-20-503 Disaster Assistance

Figure 8: Notional Case of Two Families with Similar Damage and Different Awards Because of Individuals and Households

Program Eligibility Criteria and Circumstances

FEMA sends all IHP applicants an award determination letter explaining

the applicant’s eligibility for IHP assistance and, if eligible, the amount of

assistance awarded.

Page 21 GAO-20-503 Disaster Assistance

FEMA monitors cases where the inspection finds over $17,000 or more in

eligible damages for homeowners or renters whose home received major

damage to determine the number of survivors who may need and be

eligible for temporary housing. FEMA can provide direct housing

assistance for up to 18 months, depending on their needs, which may be

extended due to extraordinary circumstances when the affected state,

territory, or tribe requests an extension in writing. Figure 9 shows this

process.

Figure 9: Federal Emergency Management Agency (FEMA) Process for Assessing Need and Providing Direct Housing

Assistance to Eligible Survivors

Survivors may request a review of certain decisions within 60 days after

the date that FEMA notifies them of the award or denial of assistance,

and the request must be submitted in writing, explain the reason for

appealing, and include a signature.

FEMA reviews the survivor’s written

appeal and any documentation provided with the appeal. Upon review,

FEMA either provides a written decision or requests more information

from the survivor. FEMA must provide the survivor with a response within

90 days of when FEMA receives the appeal. From 2010 through 2019,

about 303,000 survivors (4.8 percent) submitted about 463,000 appeals

for FEMA decisions on their IHP applications. Of the approximately

44 C.F.R. § 206.115(a), (b).

FEMA May Provide Direct

Housing Assistance

Survivors Have the Right to

Appeal

Page 22 GAO-20-503 Disaster Assistance

463,000 total appeals, FEMA approved over 115,000 (25 percent) and

denied over 336,000 appeals (about 73 percent).

From 2016 through 2018, survivors from 52 major disaster declarations

that included Individual Assistance applied for assistance from FEMA’s

IHP. Based on our analysis, survivors had varying program outcomes—

such as approval for and timeliness of financial assistance—depending

on their characteristics, such as age, gross annual income, and insurance

coverage, as well as the social vulnerability of the community in which

they lived. We also found that survivors faced challenges with

understanding and navigating the IHP, which may have prevented them

from receiving assistance for which they may have otherwise been

eligible. Specifically, survivors experienced challenges with the

requirement to apply for SBA’s disaster loan program, and understanding

FEMA’s eligibility and award decisions.

According to our analysis of FEMA’s IHP applicant data for 2016 through

2018, there were differences in approval rates, financial assistance

received, reasons for ineligibility, appeal rates, and time between key

The remaining approximately 2 percent of appeals were pending, withdrawn, or no

decision could be made.

Survivors Had

Varying Program

Outcomes and Faced

Challenges

Understanding and

Navigating the IHP

Identifying Vulnerable Communities Using

the Centers for Disease Control and

Prevention’s Social Vulnerability Index

The Centers for Disease Control and

Prevention created the Social Vulnerability

Index to help public health officials and

emergency response planners identify and

map the communities that will most likely

need continued support to recover following

an emergency or natural disaster. The index

indicates the relative social vulnerability of

census tracts in U.S. states and the District of

Columbia, and Puerto Rico. Census tracts are

subdivisions of counties for which the U.S.

Census Bureau collects statistical data

through the American Community Survey.

The index ranks tracts on 15 variables,

including unemployment, minority status, and

disability, and further groups them into the

following four themes—(1) socioeconomic

status, (2) household composition and

disability, (3) minority status and language, (4)

housing and transportation—as well as an

overall ranking. The index is a 0 to 1 scale,

with higher scores indicating greater

vulnerability.

Source: Centers for Disease Control and Prevention. |

GAO-20-503

Program Outcomes Varied

across Survivor Groups

Page 23 GAO-20-503 Disaster Assistance

events of the IHP financial assistance process for different groups of

survivors, including renters, older survivors, survivors with lower incomes,

survivors without property insurance, and survivors living in more socially

vulnerable communities. See appendix III for our analysis of IHP

outcomes by levels of social vulnerability in survivors’ communities. Also,

see our supplemental materials for our full analysis of program outcomes

for calendar years 2016, 2017, and 2018, and selected major disasters in

2016 through 2018.

Referred applicants’ characteristics and approval rates. Of the 5.6

million people who applied for FEMA assistance from 2016 through 2018,

4.4 million (78 percent) were referred to the IHP. We found that the

majority of referred applicants reported that they did not have flood

insurance coverage (92 percent) or property insurance coverage (63

percent); were from multiperson households (62 percent); owned their

homes (57 percent); or lived at or below 200 percent of the federal

poverty guideline (53 percent).

In addition, we found that 50 percent of

referred applicants were between the ages of 25 and 49, and roughly 40

percent of referred applicants reported a gross annual income below

$25,000, or lived in a community with the highest levels of social

vulnerability.

According to our analysis, 45 percent of all referred applicants were

approved for financial IHP assistance from 2016 through 2018. Of the

over 2.4 million referred applicants who were not approved, roughly 1.7

million were ineligible, almost 450,000 did not receive a decision from

FEMA because of missing insurance documentation, and over 260,000

had their applications withdrawn.

We found that approval rates varied

See GAO, Supplemental Material for GAO-20-503: Select Disaster Profiles for FEMA’s

Individuals and Households Program 2016-2018, GAO-20-674SP (Washington, D.C.;

September 2020); and Supplemental Material for GAO-20-503: FEMA Individuals and

Households Program Applicant Data 2016-2018, GAO-20-675SP (Washington, D.C.;

September 2020).

Federal poverty guidelines represent an annual household income for different

household sizes and locations. For example, the following families lived at 200 percent of

the federal poverty guideline in 2018: a family of two living in one of the 48 contiguous

states or the District of Columbia with a gross annual income of $32,920; a family of five

living in one of the 48 contiguous states or the District of Columbia with a gross annual

income of $58,840; and a family of five living in Hawaii with a gross annual income of

$67,680.

A survivor can voluntarily withdraw their application for IHP assistance. FEMA can

withdraw a survivor’s application for assistance if the applicant failed to provide a required

signature or could not be contacted.

Federal Poverty Guidelines

Each year, the Department of Health and

Human Services issues federal poverty

guidelines, which represent an annual

household income for different household

sizes and locations. For example, the 2018

poverty guideline for a family of four in any of

the 48 contiguous states and the District of

Columbia was $25,100. In comparison, the

2018 guidelines for a family of four in Alaska

and Hawaii were $31,380 and $28,870,

respectively. The guidelines are not defined

for U.S territories.

Federal poverty guidelines are used to

determine financial eligibility for certain federal

programs. For example, the Department of

Agriculture’s National School Lunch Program

provides lunches to children in schools for

free if their household income is below 130

percent of the poverty guidelines, and at a

reduced price if their household income is

between 130 percent and 185 percent of the

guidelines.

Source: Department of Health and Human Services and

Department of Agriculture. | GAO-20-503

Page 24 GAO-20-503 Disaster Assistance

across survivor groups (see fig. 10). For example, from 2016 through

2018, we found that the following groups were approved for IHP

assistance at higher rates: renters (47 percent); applicants with reported

gross annual incomes less than $10,000 (52 percent); and those who

reported no insurance coverage on their real or personal property (50

percent).

Figure 10: Referred Applicants and Approval Rates for the Individuals and Households Program (IHP), 2016 – 2018

Notes: The data used to create survivor groups were reported by the survivor in their FEMA

application. We found that less than 1 percent of referred applicants had missing age, household

size, or ownership status data, and 16 percent had missing gross annual income data, which also

Page 25 GAO-20-503 Disaster Assistance

affects our federal poverty guideline analysis. We conducted an analysis of other socioeconomic

characteristics of applicants with missing income information and found that they are somewhat more

likely to have lived in communities characterized by lower levels of socioeconomic vulnerability than

those who provided income information. See appendix I for more details.

Federal poverty guidelines represent a household income for different household sizes and

locations. The guidelines are not defined for U.S territories. We calculated guidelines for relevant U.S.

territories by multiplying the federal poverty guideline for the 48 contiguous states and the District of

Columbia by the same factor that the Small Business Administration used to calculate its minimum

income guidelines for U.S. territories.

Financial IHP assistance received. According to our analysis, almost 2

million applicants received financial IHP assistance from FEMA from 2016

through 2018. The average amounts of financial assistance homeowners

and renters received from FEMA during this period were $4,184 and

$1,675, respectively.

We found that average award amounts varied

across survivor groups (see fig. 11). For example, from 2016 through

2018, we found that the following groups had the highest average award

amounts: homeowners under the age of 25 ($5,012); renters ages 65 and

older ($1,723); homeowners and renters from households with three

people or more ($4,940 and $2,116, respectively); and homeowners and

renters living at or below the federal poverty guideline ($4,852 and

$1,958, respectively).

For the purposes of this report, average refers to the mean. We did not include group

flood insurance in our analysis of average IHP award amounts because this type of

assistance is not a direct payment to the applicant. FEMA directly purchases group flood

insurance certificates—that cost $600 and provide 3 years of coverage—on behalf of

applicants who are required to obtain and maintain flood insurance. From 2016 through

2018, less than 3 percent of all awarded applicants received group flood insurance.

Page 26 GAO-20-503 Disaster Assistance

Figure 11: Average Award Amounts and Number of Owners and Renters Who Received Financial Assistance through the

Individuals and Households Program (IHP), 2016 – 2018

Notes: The data used to create survivor groups were reported by the survivor in their FEMA

application. We found that less than 1 percent of awarded applicants had missing age, household

size, or ownership status data, and 15 percent had missing gross annual income data, which also

affects our federal poverty guideline analysis. We conducted an analysis of other socioeconomic

characteristics of applicants with missing income information and found that they are somewhat more

likely to have lived in communities characterized by lower levels of socioeconomic vulnerability than

those who provided income information. See appendix I for more details.

We did not include group flood insurance in our analysis of average IHP award amounts because

this type of assistance is not a direct payment to the applicant. FEMA directly purchases group flood

insurance certificates—that cost $600 and provide 3 years of coverage—on behalf of applicants who

are required to obtain and maintain flood insurance. From 2016 through 2018, less than 3 percent of

all awarded applicants received group flood insurance.

Page 27 GAO-20-503 Disaster Assistance

Federal poverty guidelines represent a household income for different household sizes and

locations. The guidelines are not defined for U.S territories. We calculated guidelines for relevant U.S.

territories by multiplying the federal poverty guideline for the 48 contiguous states and the District of

Columbia by the same factor that the Small Business Administration used to calculate its minimum

income guidelines for U.S. territories.

Most common reasons for an ineligible determination. According to

our analysis, from 2016 through 2018, the three most common reasons

FEMA determined that an applicant was ineligible for financial assistance

were (1) insufficient damage (36 percent of all referred applicants), (2)

failure to submit evidence to support disaster losses or needs (15 percent

of all referred applicants), and (3) failure to make contact with the FEMA

inspector (7 percent of all referred applicants). We also analyzed the most

common reasons for an ineligibility determination across survivor groups

and found differences in the rates at which certain applicants were

determined ineligible for IHP assistance because of insufficient

damages.

For example, lower-income applicants were determined

ineligible for financial assistance because of insufficient damage at higher

rates than higher-income applicants (see fig. 12).

FEMA will determine an applicant ineligible for IHP assistance if the agency does not

find enough damage to the applicant’s home or property to meet the IHP’s $50 minimum

threshold or the damages do not impact the habitability of the home.

Page 28 GAO-20-503 Disaster Assistance

Figure 12: Most Common Reasons Referred Applicants Were Determined Ineligible for Assistance from the Individuals and

Households Program (IHP), 2016 – 2018

Notes: The data used to create survivor groups were reported by the survivor in their FEMA

application. We found that less than 1 percent of referred applicants had missing age, household

size, or ownership status data, and 16 percent had missing gross annual income data, which also

affects our federal poverty guideline analysis. We conducted an analysis of other socioeconomic

characteristics of applicants with missing income information and found that they are somewhat more

likely to have lived in communities characterized by lower levels of socioeconomic vulnerability than

those who provided income information. See appendix I for more details. Applicants may receive

multiple ineligible determinations.

Page 29 GAO-20-503 Disaster Assistance

Federal poverty guidelines represent a household income for different household sizes and

locations. The guidelines are not defined for U.S territories. We calculated guidelines for relevant U.S.

territories by multiplying the federal poverty guideline for the 48 contiguous states and the District of

Columbia by the same factor that the Small Business Administration used to calculate its minimum

income guidelines for U.S. territories.

Appeal rates. According to our analysis, roughly 153,000 applicants (less

than 4 percent of all referred applicants) submitted almost 223,000

appeals to FEMA from 2016 through 2018. Of the applicants who

appealed a FEMA determination, approximately 30 percent were

successful. We found that the percentage and success rate of applicants

who appealed a FEMA determination varied across survivor groups (see

table 1). For example, from 2016 through 2018, we found that the

following groups had among the highest percentage of applicants who

appealed a FEMA determination and appeal success rate: homeowners;

applicants ages 65 and older; and those who reported a gross annual

income of less than $10,000.

Table 1: Referred Applicants Who Appealed a Determination on Financial Assistance from the Individuals and Households

Program (IHP) and Appeal Approval Rates, 2016 – 2018

Group

Number and percent of referred

applicants who appealed

Percent who won

their appeal

All

153,114

3.5

30.2

Ownership status

Homeowner

125,086

5.0

32.9

Renter

27,130

1.5

18.6

Age

Under 25

3,704

1.5

27.7

25 to 49

54,460

2.5

28.2

50 to 64

56,089

4.6

30.7

65 and older

38,263

5.4

32.4

Household size

42,201

2.6

28.8

46,372

4.2

31.1

3 or more

64,541

4.0

30.4

Gross annual income

Less than $10,000

40,398

5.7

32.4

$10,000 to less than $25,000

50,232

4.3

30.8

$25,000 to less than $50,000

28,669

2.9

28.2

$50,000 and above

20,526

2.5

28.5

Federal poverty guideline

100% or below

64,199

5.2

31.2

Above 100% to 200%

41,449

3.9

30.6

Above 200% to 300%

15,642

2.7

29.3

Above 300%

18,535

2.3

28.2

Property insurance coverage

No coverage

100,539

3.7

32.1

Personal property only

3,960

1.8

20.1

Real and personal property

48,478

3.5

27.0

Page 30 GAO-20-503 Disaster Assistance

Group

Number and percent of referred

applicants who appealed

Percent who won

their appeal

Flood insurance coverage

No coverage

143,901

3.6

30.6

Coverage

9,213

2.5

22.7

Disaster location

U.S. states

102,330

3.0

26.7

Puerto Rico

47,773

5.3

37.4

U.S. Virgin Islands

1,754

5.2

25.1

Other U.S. territories

1,257

7.3

37.3

Source: GAO analysis of the Federal Emergency Management Agency’s (FEMA) IHP applicant data, as of February 24, 2020. I GAO-20-503

Note: The data used to create survivor groups were self-reported by the survivor in their FEMA

application. We found that less than 1 percent of applicants who appealed had missing age or

ownership status data, and 9 percent had missing gross annual income data, which also affects our

federal poverty guideline analysis. We conducted an analysis of other socioeconomic characteristics

of applicants with missing income information and found that they are somewhat more likely to have

lived in communities characterized by lower levels of socioeconomic vulnerability than those who

provided income information. See appendix I for more details.

Federal poverty guidelines represent a household income for different household sizes and

locations. The guidelines are not defined for U.S territories. We calculated guidelines for relevant U.S.

territories by multiplying the federal poverty guideline for the 48 contiguous states and the District of

Columbia by the same factor that the Small Business Administration used to calculate its minimum

income guidelines for U.S. territories.

Time between key events of the IHP process. We analyzed the

numbers of days between a survivor’s application date and dates for the

following key events in the IHP process for financial assistance: first

inspection, first award, and final decision, which, for the purposes of our

analysis, indicates the end of a survivor’s involvement in the IHP process

for financial assistance. We found that, from 2016 through 2018, the

average time between survivors’ application and first inspection was 30

days;

between survivors’ application and first award was 37days;

and

Only survivors who report home or personal property damages in their FEMA application

will receive an inspection.

We excluded Critical Needs Assistance records from our analysis of the time between

application and first award dates because, according to FEMA officials, the agency does

not typically provide this type of assistance. According to our analysis, FEMA provided

Critical Needs Assistance—a one-time payment of $500—to over 925,000 applicants in 14

of the 52 major disaster declarations that included Individual Assistance from 2016

through 2018. An affected state, territorial, or tribal government must request that FEMA

authorize Critical Needs Assistance for specific geographic areas or all counties declared

for Individual Assistance, as the assistance is subject to a state/federal cost-share.

FEMA’s Individual Assistance Division Director may authorize the assistance when the

identified areas are or will be inaccessible for an extended period of time (i.e., 7 days or

longer). Survivors who complete a FEMA application and pass identify verification may be

eligible for Critical Needs Assistance if they state an emergency need for food,

medication, gas, shelter, or clothing at the time of application, and are displaced from their

primary residence as a result of the disaster. We found that the average time between a

survivor’s application date and award date for Critical Needs Assistance was 1.7 days.

Page 31 GAO-20-503 Disaster Assistance

that referred applicants were involved in the IHP financial assistance

process was 49 days.

We found that the average time between key events in the IHP process

for financial assistance varied across survivor groups (see table 2).

For

example, from 2016 through 2018, we found that the following groups

experienced longer times, on average, between their application and first

inspection, first award, and final decision dates: homeowners; applicants

ages 65 and older; and those who reported a gross annual income of less

than $10,000.

Table 2: Time between Key Events in the Financial Assistance Process for the Individuals and Households Program (IHP),

2016 – 2018

Group

Average time

to first

inspection

(days)

Average

time to first

award

(days)

Average time to final

decision (days)

Referred

applicants

Awarded

applicants

All

Ownership status

Homeowner

Renter

Age

Under 25

25 to 49

50 to 64

65 and older

Household size

3 or more

Gross annual income

Less than $10,000

$10,000 to less than $25,000

$25,000 to less than $50,000

$50,000 and above

We excluded from this analysis applicants who only received Critical Needs Assistance

and took no further action to pursue other financial assistance, which we defined as not

submitting any documents to FEMA, not having any recorded contacts with FEMA, and

not receiving an inspection. From 2016 through 2018, we identified about 318,000

applicants, or 16 percent of all applicants who received assistance, who only received

Critical Needs Assistance and took no further action to pursue other financial assistance.

Also, see our supplemental materials for additional analysis on the time between

application and key points in the IHP financial assistance process for 2016, 2017, and

2018, and for select disasters during 2016 through 2018. GAO-20-674SP and

GAO-20-675SP.

Page 32 GAO-20-503 Disaster Assistance

Group

Average time

to first

inspection

(days)

Average

time to first

award

(days)

Average time to final

decision (days)

Referred

applicants

Awarded

applicants

Federal poverty guideline

100% or below

Above 100% to 200%

Above 200% to 300%

Above 300%

Property insurance coverage

No coverage

Personal property only

Real and personal property

Flood insurance coverage

No coverage

Coverage

Disaster location

U.S. states

Puerto Rico

100

133

U.S. Virgin Islands

124

Other U.S. territories

Source: GAO analysis of the Federal Emergency Management Agency’s (FEMA) IHP applicant data, as of February 24, 2020. I GAO-20-503

Note: The data used to create survivor groups were reported by the survivor in their FEMA

application. We found that less than 1 percent of referred, awarded, and inspected applicants had

missing age, household size, or ownership status data, and roughly 15 percent had missing gross

annual income data, which also affects our federal poverty guideline analysis. We conducted an

analysis of other socioeconomic characteristics of applicants with missing income information and

found that they are somewhat more likely to have lived in communities characterized by lower levels

of socioeconomic vulnerability than those who provided income information. See appendix I for more

details.

We excluded Critical Needs Assistance records from our analysis of the time to first award date.

We excluded from our analysis of the time to final decision applicants with a pending decision on

their case for IHP assistance. In addition, we excluded those who only received Critical Needs

Assistance and took no further action to pursue other financial assistance, which we defined as not

submitting any documents to FEMA, not having any recorded contacts with FEMA, and not receiving

an inspection. We also excluded records related to retroactive processing of IHP awards made

necessary by Section 1212 of the Disaster Recovery Reform Act of 2018.

Federal poverty guidelines represent a household income for different household sizes and

locations. The guidelines are not defined for U.S territories. We calculated guidelines for relevant U.S.

territories by multiplying the federal poverty guideline for the 48 contiguous states and the District of

Columbia by the same factor that the Small Business Administration used to calculate its minimum

income guidelines for U.S. territories.

Page 33 GAO-20-503 Disaster Assistance

The Stafford Act limits FEMA’s IHP assistance to necessary expenses

and serious needs unable to be met through other means.

Because

some categories of IHP assistance are for expenses and needs that may

also be addressed by an SBA loan, FEMA coordinates with SBA to

determine a survivor’s eligibility for personal property assistance,

transportation assistance, and group flood insurance, which FEMA refers

to collectively as SBA-dependent ONA.

After receiving a survivor’s

application information, FEMA automatically refers them to SBA to

complete a disaster loan application if they reported a gross household

income and family size that meet SBA’s minimum income guidelines to be

considered for a loan (see app. IV for SBA’s minimum income guidelines

for fiscal year 2018), reported self-employment income, or refused to

provide their income in their disaster assistance application.

FEMA will

continue to move applicants who were referred to SBA through the steps

of the IHP process, including the inspection process, but FEMA requires

42 U.S.C. § 5174(a).

In coordination with SBA, FEMA determined that moving and storage assistance is not a

duplication of benefits with SBA’s disaster loan program, according to FEMA officials.

Officials explained that the SBA disaster loan may be used toward costs to move personal

property prior to a disaster in order to minimize damage, while FEMA’s moving and

storage assistance is intended to help survivors move or store essential personal property

while repairing their home or moving to a new residence not damaged in the disaster.

Officials told us that FEMA plans to implement moving and storage assistance as non-

SBA-dependent ONA in fall 2020.

FEMA also shares application information with SBA and other partner agencies through

its disaster assistance application system, Disaster Assistance Center, which is the single

information collection point for multiple sources of federal disaster assistance, including

SBA’s disaster loan. FEMA’s Disaster Assistance Center maintains disaster survivor

application information collected through various media including: (1) the

www.disasterassistance.gov website, (2) FEMA’s mobile application, (3) via telephone,

and (4) paper forms. When a survivor applies for disaster assistance, FEMA’s Disaster

Assistance Center collects their application information and routes it accordingly. If the

applicant is requesting assistance from a FEMA program, information is shared with

FEMA’s National Emergency Management Information System, which processes the

information and returns status updates. For other participating agency programs, such as

SBA’s disaster loan, FEMA’s Disaster Assistance Center routes survivors’ application

information to a secure data exchange point to share the information with external partner

agencies. Participating agencies receive survivors’ application information to determine

their eligibility for assistance, continue processing their case, and identify any potential

duplication of assistance.

Survivors Experienced

Challenges with the IHP

Requirement to Apply for

an SBA Loan

Some Survivors Who Applied

for IHP Assistance Are Also

Required to Apply for an SBA

Loan

Page 34 GAO-20-503 Disaster Assistance

that these applicants be declined an SBA loan or receive a partial loan

before the agency considers them for SBA-dependent ONA. IHP

applicants who are referred to SBA may apply for a disaster loan online,

by mail, or in-person at a disaster center. Upon receiving a completed

loan application, SBA conducts four tests of a survivor’s ability to repay a

loan using the information in their loan application and credit report.

Survivors who lack or have a limited ability to repay an SBA loan are

referred back to FEMA to be considered for SBA-dependent ONA. Figure

13 shows FEMA’s process for determining an IHP applicant’s eligibility for

SBA-dependent ONA, and SBA’s initial repayment and credit assessment

process for a loan.

Page 35 GAO-20-503 Disaster Assistance

Figure 13: Process for Determining a Survivor’s Eligibility for Disaster Assistance from the Federal Emergency Management

Agency (FEMA) and the Small Business Administration (SBA)

According to our analysis of FEMA’s IHP applicant data from 2016

through 2018, over 3.9 million IHP applicants had an SBA loan status. Of

those, approximately 2 million lacked the ability to repay an SBA loan; 1.7

million did not complete the loan application; 141,000 were approved for

an SBA loan; and 103,000 had their loan canceled, declined, or

withdrawn (see fig. 14).

Page 36 GAO-20-503 Disaster Assistance

Figure 14: Small Business Administration (SBA) Loan Status of Survivors Who Applied for Assistance from the Individuals

and Households Program (IHP), 2016 – 2018

Note: The figure does not include approximately 8,600 IHP applicants whose SBA loan application

was received by the SBA but not yet processed, or in the inspection, manual review, or appeal

processes.

As previously stated, from 2016 through 2018, over 1.7 million survivors

who applied for IHP assistance and were referred to SBA did not

complete a loan application, according to our analysis of FEMA’s IHP

applicant data. Based on our interviews with FEMA, state, territory, local,

and NGO officials, survivors may not complete the SBA loan application

because they do not understand that it is a requirement of the IHP. For

example, officials from 3 of 4 states—Texas, Florida, and California—and

Puerto Rico, 4 of 10 localities, and 5 of 7 NGOs said that survivors did not

understand or were confused by the requirement to complete an SBA

disaster loan application for FEMA’s IHP. In addition, FEMA field officials

leading recovery efforts for hurricanes Maria and Florence, and the

California wildfires, as well as staff from 2 of 4 NPSCs, told us that

survivors had challenges understanding the IHP requirement to apply for

an SBA loan. FEMA recovery officials in Puerto Rico said that the agency

faces challenges with the IHP requirement to apply for an SBA loan in

every disaster, and Individual Assistance officials from 2 of the 4 FEMA

regional offices we selected for interviews noted that this requirement has

been a long-standing issue with the program.

FEMA informs disaster survivors about SBA’s disaster loan program

through a variety of methods. For example, FEMA staff share information

on SBA’s disaster loan program during interactions with survivors. After

completing the IHP application, an applicant who is referred to the SBA is

verbally notified that they must also complete and return an application to

SBA to be considered for a disaster loan as well as certain types of

Survivors Did Not Understand

the IHP Requirement to Apply

for an SBA Loan

Page 37 GAO-20-503 Disaster Assistance

assistance from FEMA.

We observed a NPSC staff member inform a

person of their eligibility to apply for an SBA loan after helping them

complete their FEMA application over the phone. We also observed

another NPSC staff member tell an individual calling into FEMA’s Disaster

Helpline that they could apply for an SBA loan to assist with personal

property losses and, if denied, may be eligible to receive personal

property assistance from FEMA. Further, Individual Assistance officials

from one of the FEMA regional offices we selected for interviews and field

officials who led recovery efforts for Hurricane Florence told us that they

conducted outreach to survivors who applied for FEMA assistance to

inform them about SBA’s disaster loan during recovery operations.

Additionally, FEMA published news releases through its website about

SBA’s disaster loan and its relationship to IHP assistance. For instance,

in a March 2018 news release, FEMA explained that disaster survivors in

Puerto Rico who suffered damage or loss from Hurricane Maria and were

referred to SBA can benefit from other FEMA assistance if they complete

and submit SBA’s loan application.

However, we found that FEMA did not fully or consistently explain the IHP

requirement to apply for an SBA loan in some of its modes for

communicating with survivors.

• First, we found that the amount and clarity of information about the

requirement to apply for an SBA loan varies significantly across

FEMA’s public disaster webpages. For example:

• FEMA’s public webpage for Hurricane Michael in Florida included

SBA’s contact information and a link to a video titled “Reasons to

Apply for a SBA Loan,” which explains SBA’s disaster loan,

including the requirement to submit an SBA loan application for

the IHP, in American Sign Language.

However, FEMA’s public

According to FEMA officials, the full text of the notification provided during application is

as follows: “If you receive a notification from SBA in regards to your Disaster Loan referral,

you must complete and return an application in order to be considered for a loan as well

as certain types of grant assistance. You can apply online, in person by visiting a Disaster

Recovery Center, or by submitting the application by mail. If the SBA finds that you cannot

afford a loan, they will automatically refer you to FEMA’s Individuals and Households

Program for help. SBA makes the determination if you can afford a loan. If SBA approves

you for a loan, they will contact you. If SBA finds that you cannot afford a loan, FEMA will

contact you.”

Federal Emergency Management Agency, Florida Hurricane Michael (DR-4399),

accessed on March 30, 2020, https://www.fema.gov/disaster/4399. We accessed this

website using Google Chrome and Microsoft Edge.

Page 38 GAO-20-503 Disaster Assistance

webpage for Hurricane Michael in Georgia did not contain any

information on SBA’s disaster loan;

and

• FEMA’s public webpage for Hurricane Florence in North Carolina

included general information on SBA’s disaster loan and explained

that some survivors who applied for FEMA assistance may be

referred to SBA for a loan and that there is no obligation to accept

a loan. However, the webpage did not state that IHP applicants

referred to SBA will not be considered for SBA-dependent ONA if

they do not submit a loan application.

In comparison, FEMA’s public webpage for Hurricane Florence in

South Carolina was more explicit about the requirement to apply

for an SBA loan. For example, the webpage stated that “survivors

referred to the SBA should complete a loan application as soon as

possible as this will ensure all eligible assistance under FEMA’s

Individuals and Households Program is provided,” and “applicants

who receive SBA loan applications must submit them to SBA for a

possible referral for further assistance consideration for personal

property, vehicle repair or replacement, and moving and storage

expenses.”

• Second, FEMA’s IHP brochure—which FEMA distributes by mail—

explains that the agency works with the SBA to offer low-interest

loans to disaster survivors; however, it does not explicitly state that

IHP applicants referred to the SBA must apply for and be declined or

receive a partial loan before FEMA will consider them for SBA-

dependent ONA.

• Third, the letter FEMA sends to survivors after they apply for IHP

assistance includes information on SBA’s disaster loan program and

states that “if you are referred to SBA, you must complete an

application with SBA prior to being considered for certain FEMA

Federal Emergency Management Agency, Georgia Hurricane Michael (DR-4400),

accessed on March 30, 2020, https://www.fema.gov/disaster/4400. We accessed this

website using Google Chrome and Microsoft Edge.

Federal Emergency Management Agency, North Carolina Hurricane Florence (DR-

4393), accessed on March 30, 2020, https://www.fema.gov/disaster/4393. We accessed

this website using Google Chrome and Microsoft Edge.

Federal Emergency Management Agency, South Carolina Hurricane Florence (DR-

4394), accessed on March 30, 2020, https://www.fema.gov/disaster/4394. We accessed

this website using Google Chrome and Microsoft Edge.

Federal Emergency Management Agency, Help After a Disaster: FEMA Individual

Assistance Can Help You Recover, FEMA B-545 (Washington, D.C.: April 2019).

Page 39 GAO-20-503 Disaster Assistance

assistance.” However, we found that FEMA’s IHP award

determination letters do not include essential information about the

SBA disaster loan program. Specifically, the letters do not include the

IHP applicant’s SBA loan application status or explain how their SBA

loan application status may affect their eligibility for SBA-dependent

ONA.

According to the National Disaster Recovery Framework, the federal

government plays an important role in providing accessible information to

the public and all stakeholders involved in recovery, including information

about federal grants and loans with potential applications to recovery. It

also states that the federal government is responsible for ensuring that

information is distributed in an accessible manner and is well understood,

so that all stakeholders, including individuals, are informed and aware of

the process and have realistic expectations for recovery.

In addition, the

Individual Assistance Division’s role is to ensure that disaster survivors

receive the best possible level of service to maximize their recovery,

according to FEMA. FEMA officials agreed that a complete explanation of

the requirement to apply for an SBA loan on its public disaster webpages

and in its IHP brochure and award determination letter would be helpful to

survivors. By improving the completeness and consistency of its

communication of the requirement to apply for an SBA disaster loan,

FEMA can help ensure that IHP applicants are aware of the requirement

so they can take the necessary actions to be considered for every type of

IHP assistance that will help them address their disaster losses and

recovery needs.

Based on our interviews and analyses, FEMA’s current process for

determining an applicant’s eligibility for SBA-dependent ONA resulted in

challenges for survivors in pursuing and obtaining disaster assistance and

may have been a barrier that prevented many potentially low-income IHP

applicants with FEMA-verified personal property losses from being

considered for personal property assistance.

According to FEMA, state, and local officials we met with, FEMA’s current

process for SBA-dependent ONA, which requires some IHP applicants to

also apply for an SBA loan, created an additional burden on disaster

survivors. For example, Individual Assistance officials from two of the

FEMA regional offices we selected for interviews and staff from the

Puerto Rico NPSC explained that the process of obtaining disaster

assistance is burdensome because survivors have to interact with many

Department of Homeland Security. National Disaster Recovery Framework.

Opportunities Exist to Simplify

the IHP Process, Which May

Particularly Benefit Survivors

Who Are Low Income and Less

Likely to Qualify for an SBA

Loan

Page 40 GAO-20-503 Disaster Assistance

different federal agencies, including FEMA and SBA. Similarly, the Texas

General Land Office’s report on lessons learned from the Hurricane

Harvey response stated that the requirement to apply for an SBA loan

frustrated already traumatized disaster survivors who do not have much

experience in dealing with the complex federal bureaucracy and are

confused by all the forms they must fill out, many of which ask the same

questions.

State and local officials from Texas said that FEMA should

do more to synchronize the IHP with other federal disaster assistance

programs, such as SBA’s disaster loan, to reduce the number of times

survivors have to engage with the federal government.

In addition, FEMA’s current process for SBA-dependent ONA can also

delay IHP assistance to survivors, according to FEMA and local officials

we interviewed. For example, Individual Assistance officials from one of

the FEMA regional offices we selected for interviews said that the

requirement for some IHP applicants to also apply for an SBA loan is

tedious and frustrating, and delays assistance to some survivors.

Likewise, county officials from California told us that the requirement to

apply for an SBA loan is a very frustrating part of the IHP process

because it delays the delivery of disaster assistance to survivors. These

officials explained that survivors spend weeks to months going through

the SBA loan process only to be denied in the end.

We analyzed FEMA’s IHP applicant data from 2016 through 2018 and

found that FEMA’s current process for SBA-dependent ONA may have

prevented many IHP applicants from being considered for personal

property assistance—a type of SBA-dependent ONA—including low-

income applicants who are less likely to qualify for an SBA loan. We

identified tens of thousands of potentially low-income IHP applicants with

tens of millions of dollars in FEMA-verified personal property loss who

were referred to the SBA but did not submit an SBA loan application (see

table 3). We reviewed award data for these potentially low-income

applicants and found that 47 percent to 58 percent of them received an

award for other types of IHP assistance. Although these applicants met

the agency’s requirements to receive other types of financial IHP

assistance, FEMA could not consider these applicants for personal

property assistance under its current process because they did not submit

an SBA loan application.

Texas General Land Office, Hurricane Harvey: Texas at Risk, (Austin, TX: Aug. 24,

2018).

Page 41 GAO-20-503 Disaster Assistance

Table 3: Number of Potentially Low-Income Individuals and Households Program (IHP) Applicants Who Did Not Submit the

Small Business Administration (SBA) Loan Application and Had Personal Property Loss Verified by the Federal Emergency

Management Agency (FEMA), 2016 – 2018

Sources: GAO analysis of FEMA’s IHP applicant data, as of February 24, 2020, and the Centers for Disease Control and Prevention’s 2016 Social Vulnerability Index. I GAO-20-503

We analyzed IHP applicants’ reported gross annual income, household size, and address, and used

three methods to identify applicants who may be low income. It is not appropriate to sum the results

for each method.

Federal poverty guidelines represent a household income for different household sizes and

locations. The guidelines are not defined for U.S territories. We calculated guidelines for relevant U.S.

territories by multiplying the federal poverty guideline for the 48 contiguous states and the District of

Columbia by the same factor that the SBA used to calculate its minimum income guidelines for U.S.

territories.

The Centers for Disease Control and Prevention’s Social Vulnerability Index indicates the relative

vulnerability of census tracts in the U.S. and Puerto Rico. Census tracts are subdivisions of counties

for which the U.S. Census Bureau collects statistical data through the American Community Survey.

The index ranks tracts on 15 variables, including unemployment, minority status, and disability, and

further groups them into themes. One of these themes is socioeconomic vulnerability, which

measures the number of people who are unemployed, living in poverty, and do not have a high

school diploma, as well as per capita income. The index is a 0 to 1 scale, with higher scores

indicating greater vulnerability. In the table, we reported data on applicants from tracts with a

socioeconomic vulnerability of greater than .75.

Approximately 73,000 of the roughly 272,000 IHP applicants who did not complete an SBA loan

application and had FEMA-verified personal property losses did not provide an gross annual income

in their FEMA application. Of these applicants, over 23,500 lived in census tracts characterized by the

highest levels of socioeconomic vulnerability and had almost $33 million in FEMA-verified personal

property losses.

FEMA’s 2018-2022 Strategic Plan states that navigating complex federal

programs is an unnecessary added burden in times of disaster. The plan

includes a goal to reduce the complexity of disaster assistance programs

and a related objective to streamline the disaster survivor experience.

Method used to identify IHP applicants who may be low

income

Number of applicants who

did not submit an SBA loan

application and had FEMA-

verified personal property

loss

Total FEMA-

verified

personal

property loss

(dollars)

Percentage of

applicants who

received other

IHP financial

assistance

Reported gross annual income was less than $25,000

39,926

60,258,397

Less than $10,000

11,492

18,554,815

$10,000 to less than $25,000

28,434

41,703,582

Reported gross annual income fell at or below 200% of

the federal poverty guideline

70,411

125,612,689

At or below 100% of the guideline

17,573

30,775,723

Above 100% up to 200% of the guideline

52,838

94,836,966

Damaged residence located in a census tract with the

highest level of socioeconomic vulnerability

77,309

124,256,597

U.S. census tracts

61,831

105,450,650

Puerto Rico census tracts

15,478

18,805,948

Page 42 GAO-20-503 Disaster Assistance

According to the plan, FEMA must streamline and integrate existing

disaster assistance programs and processes, and deliver assistance and

support in as simple a manner as possible. In addition, the plan states

that understanding barriers that limit or prevent access to programs,

especially for vulnerable populations, remains essential to FEMA’s

mission.

According to FEMA officials, the agency is reviewing its process for

determining an IHP applicant’s eligibility for SBA-dependent ONA to

address a recent recommendation made by the Department of Homeland

Security’s Office of Inspector General. Officials said FEMA has developed

a working group that is coordinating with SBA to identify potential

solutions for verifying an applicant’s self-reported income or ensuring that

applicants who do not meet SBA’s minimum income guidelines based on

self-reported income have their SBA loan eligibility validated in some way

prior to receiving SBA-dependent ONA. According to FEMA officials, the

working group is in the process of gathering information and doing

outreach to other agencies that may verify income or dependent

information in their current processes. However, FEMA has not

developed guidance nor established specific time frames for completing

these actions. More importantly, it remains unclear whether FEMA’s

actions will simplify or streamline the disaster assistance process for

survivors. By assessing the extent to which its process for determining an

applicant’s eligibility for SBA-dependent ONA limits or prevents access to

IHP assistance, and working with SBA to identify options to simplify and

streamline the process, FEMA can help ensure that its process does not

delay or serve as a barrier to IHP assistance, particularly for low-income

applicants who are less likely to qualify for an SBA loan.

Federal Emergency Management Agency, 2018-2022 Strategic Plan.

Page 43 GAO-20-503 Disaster Assistance

After making an eligibility and award decision on an applicant’s case,

FEMA sends them a determination letter that states their eligibility for

receiving IHP assistance and, if eligible, the amount of assistance FEMA

awarded to them. The determination letter is FEMA’s primary method of

communicating eligibility and award decisions to IHP applicants.

However, survivors experienced challenges in understanding the letter,

according to FEMA, state, local, and NGO officials we interviewed. For

example, state officials from 2 of 5 states—California and Florida—as well

as officials from 7 of 10 localities and 5 of 7 NGOs, said that FEMA’s

determination letters are unclear and incomplete. As a result, survivors

have trouble understanding the letters and how to respond, and may stop

pursuing assistance after receiving a FEMA determination letter because

they believe the letter represents a final denial, according to state, local,

and NGO officials we interviewed.

We heard about this challenge directly from a survivor while observing

FEMA staff as they conducted applicant outreach in North Carolina after

Hurricane Florence. The individual, who was in the act of removing

flooring, dry wall, and cabinetry damaged by a tree falling through her

roof, said she received a letter from FEMA stating that she was denied

assistance and threw the letter away in anger. FEMA staff informed the

individual that her FEMA application had not been denied and explained

that the purpose of the letter was to inform her that she needed to seek

payment for damages through her insurance company before FEMA is

able to provide assistance.

Further, FEMA officials we interviewed from disaster recovery efforts in 3

of 5 selected states, as well as 3 of 4 selected FEMA regional offices, 3 of

4 NPSCs, and headquarters told us that survivors experienced

challenges in understanding FEMA’s determination letter, as described

below.

• FEMA field officials we interviewed in North Carolina, Florida, and

California said that FEMA’s determination letters are not clear and

confuse survivors. Additionally, staff responsible for conducting

survivor outreach in North Carolina after Hurricane Florence told us

Disaster Survivors Faced

Challenges Understanding

FEMA’s Eligibility and

Award Decisions

FEMA Has Taken Some Steps

to Clarify Its IHP Award

Determination Letters, but

Survivors Continue to Struggle

to Understand These Letters

Roof and Interior Damage to a Survivor’s

Home as a Result of Hurricane Florence

Source: GAO; photos taken by GAO while on site in North

Carolina. | GAO-20-503

Page 44 GAO-20-503 Disaster Assistance

that they spend much of their time explaining the determination letters

to survivors.

• Individual Assistance officials from two of the FEMA regional offices

we selected for interviews said the letters are confusing and do not

provide enough detail, and suggested that FEMA rewrite the letters in

a way that tells survivors they need to take action before FEMA can

process their assistance, instead of just stating that they are ineligible.

• FEMA officials involved with efforts to improve IHP systems and

processes told us that the number of calls to FEMA’s Disaster

Helpline increases when determination letters are sent because

survivors have questions about what the letter means. We observed

an individual calling into FEMA’s Disaster Helpline to ask for help in

understanding the determination letter he received. The individual

said he was confused by the letter, which stated that he was ineligible

for assistance, and that the agency needs to communicate more

clearly.

The most recent version of the determination letter FEMA sends to an

ineligible applicant states multiple times that they are not eligible to

receive assistance. For example, immediately following the salutation, a

short introductory paragraph states the purpose of the letter, which is to

“explain why [the applicant] is not eligible for FEMA assistance.” After

reading this short paragraph, the applicant would then read the following

phrases, “ASSISTANCE NOT APPROVED,” and, “You are not eligible

for the following assistance because.” While the letter includes

instructions on how to appeal FEMA’s determination, it does not explicitly

state that the determination is not final (see a copy of the IHP

determination letter FEMA sends to ineligible applicants in app. V).

FEMA has tried to clarify its letters for the IHP through public

communications during disaster recovery efforts and improve the letters

through periodic internal reviews. Specifically, FEMA published news

releases that aim to clarify the purpose of the determination letter,

describe why an applicant may be determined ineligible for assistance,

and explain steps they should take if they need more information or

disagree with FEMA’s decision. For example, in May 2016, FEMA

published a news release titled, “A Letter from FEMA May Require

Follow-Up,” which stated that “Texas storm survivors who receive a letter

from FEMA that they are ineligible for disaster assistance should not give

We observed this during our visit to FEMA’s National Processing Service Center in

Winchester, Virginia, in March 2019.

Page 45 GAO-20-503 Disaster Assistance

up—but should follow up instead.” In a June 2019 news release, FEMA

wrote that “residents who receive a letter saying they are ineligible for

federal assistance may still qualify for help,” and “the letter can mean

several things—and it does not necessarily mean the case is closed.”

FEMA also periodically reviews its IHP determination letters. For

example, in 2016, FEMA reviewed all IHP letters, including the

determination letters. The goal of the revision effort was to create letters

that are easy for survivors to read and understand. After revising the

letters, FEMA conducted 22 focus groups with a total of 76 IHP applicants

from three states—California, Louisiana, and South Carolina—to obtain

feedback on the revised letters. According to FEMA officials, the agency

established a working group comprised of FEMA staff from various

organizational components to review the findings from the focus groups,

as well as feedback from internal and external FEMA partners, and was

responsible for ensuring that all correspondence was accessible,

understandable, and in accordance with the Plain Language Act of 2010.

The working group conducted another review of all IHP letters sent to

disaster survivors, including the determination letters, from July through

November 2018. Among other actions, the working group revised the

determination letters to reflect policy updates and make them easier for

disaster survivors to read and understand by incorporating plain

language. According to officials, FEMA published the revised letters in

August 2019. FEMA officials said the agency is tentatively scheduled to

conduct focus groups with disaster survivors in 2021 to obtain feedback

on the letters introduced in 2019.

We reviewed current and previous versions of FEMA’s ineligible

determination letters and found that FEMA’s 2016 and 2018 revision

efforts resulted in letters that were easier to read relative to previous

versions. However, the sections explaining the purpose of the letter and

the applicant’s eligibility for assistance in the current version of FEMA’s

ineligible determination letters were still not written in plain language and

required a reading level of a high school senior.

It is critical that FEMA

continue to improve the readability of its letters because, according to our

We assessed readability using Flesch Reading Ease scores. Scores fall on a scale from

0 to 100, with 0 being nearly impossible to read and 100 being simple enough for a fifth

grader to read. A score of 60 or above qualifies as “plain language.” The formula is based

on average sentence length and average word length. The version we used was included

in the Microsoft Word processing software. As we have previously reported, the Flesch

Reading Ease score is one of the most widely used, tested, and reliable formulas for

calculating readability. See GAO-17-656.

Page 46 GAO-20-503 Disaster Assistance

analysis of FEMA’s IHP applicant data, from 2016 through 2018, over 35

percent of all applicants referred to the IHP were from communities with

the highest levels of socioeconomic vulnerability—an indicator of relative

vulnerability that measures, among other things, the number of people

who do not have a high school diploma.

The National Disaster Recovery Framework states that the federal

government is responsible for ensuring that information is distributed in

an accessible manner and is well understood, so that the public,

Congress, the private sector, and all stakeholders are informed and

aware of the process and have realistic expectations for recovery.

According to the Substance Abuse and Mental Health Services

Administration’s 2019 report on communicating effectively with the public

before, during, and after a crisis, such as a disaster, greater

communication success will be achieved if the information provided is

easily understood, especially when people are under high stress.

Further, it is common for disaster survivors to have difficulties thinking

clearly and concentrating, and seeking financial assistance to rebuild and

repair damages can add to the already high levels of stress and

frustration caused by the disaster or traumatic event, according to the

Substance Abuse and Mental Health Services Administration.

Lastly, the Plain Writing Act of 2010 states that information supplied to the

public regarding any federal benefit (including in paper and electronic

publications, forms, notices, or instructions) must be, among other things,

clear, concise, well-organized, and appropriate for the intended

audience.

The President’s guidance for implementing this act states that

“agencies should communicate with the public in a way that is clear,

simple, meaningful, and jargon-free,” and notes that “a lack of clarity may

prevent people from becoming sufficiently aware of programs or services

for which they are eligible.” In addition, federal plain language guidelines

state that agencies should write in a way that guides the reader to

understand what they need to know to achieve the best outcome, which,

for a disaster survivor, would be to obtain assistance to address their

losses and recovery needs. By using federal guidance and best practices

for communicating with the public to ensure that applicants understand

that an “ineligible” determination does not mean they cannot continue to

Department of Homeland Security. National Disaster Recovery Framework.

Substance Abuse and Mental Health Services Administration, Communicating in a

Crisis: Risk Communication Guidelines for Public Officials.

Pub. L. No. 111-274, 124 Stat. 2861.

Page 47 GAO-20-503 Disaster Assistance

pursue assistance, the agency can enhance the clarity of the letters and

minimize the likelihood that applicants will prematurely end their pursuit of

IHP assistance.

Although FEMA provides disaster survivors who apply for IHP assistance

with information describing the program, applicants need additional

information to improve their understanding of the program, including

FEMA’s eligibility and award determinations. After a disaster survivor

applies for the IHP, FEMA sends them an informational brochure and

cover letter explaining program steps and the types of assistance

available through the IHP. FEMA also provides survivors with a copy of

their completed application to review for accuracy.

However, we found that FEMA does not provide applicants with the

information needed to understand the agency’s decisions on their case

for IHP assistance. For example, some individuals who participated in

focus groups for FEMA’s 2016 effort to revise its letters said they wanted

an explanation of how FEMA determined their award amount, as well as a

list of all the items they received assistance for, included in the award

determination letter. FEMA’s current award determination letter does not

include this information. Additionally, FEMA field officials and county

officials in North Carolina told us that FEMA does not provide a summary

of the site inspection, which makes it difficult for an applicant to

understand and, if necessary, appeal FEMA’s decisions.

FEMA, state, local, and NGO officials we interviewed told us that

survivors experienced challenges in understanding FEMA’s eligibility and

award determinations. For example, a section chief from the IHP Service

Delivery Branch told us that survivors struggle with the lack of

transparency in the program and understanding the assistance they

received from FEMA. The official leading FEMA’s response and recovery

efforts for Hurricane Michael told us that survivors did not understand

what losses FEMA covered and how FEMA determined the amount of

assistance to provide. In addition, officials we interviewed from 3 of 4

states—Texas, Florida, and California—and Puerto Rico, 5 of 10

localities, and 3 of 7 NGOs said that survivors do not understand FEMA’s

eligibility and award determinations. Further, state, local, and NGO

officials told us that survivors had incorrect expectations of the level of

assistance FEMA can provide through the program.

Officials we interviewed described multiple benefits of providing survivors

with more information about their case and FEMA’s eligibility and award

determinations. For example, staff from the NPSC in Puerto Rico and

FEMA Provides Survivors with

Information Describing the IHP,

but They Nee

d Additional

Information to Better

Understand FEMA’s Award

Determinations

Page 48 GAO-20-503 Disaster Assistance

officials from an NGO in Florida explained that survivors would feel that

they have been treated fairly by FEMA if the agency provided them with

more information to help them understand their case and FEMA’s award

decision. In addition, the official leading FEMA’s response and recovery

efforts for Hurricane Maria in Puerto Rico noted that the more information

FEMA gives to survivors, the better their experience in the recovery

process will be. Also, providing survivors with additional information about

the award they received may help FEMA manage survivors’ expectations

of the agency and the IHP, a challenge cited by multiple FEMA officials

we met with. Lastly, additional information would help applicants appeal

FEMA’s decisions on their case—an action that FEMA encourages

survivors to do and that increases the likelihood of receiving any

assistance from the agency, according to local and NGO officials we met

with.

Officials told us the agency has considered including in the award

determination letter the damage information that FEMA utilizes to

calculate applicants’ awards. The National Emergency Management

Information System—the system FEMA uses to process IHP cases for

assistance—contains detailed information on the amount of damage to

specific aspects of the home and household items, which FEMA records

during the inspection. However, according to officials, FEMA decided not

to include this information in its award determination letter because it

would require system changes to allow for the damage information to be

pulled from the National Emergency Management Information System

into the letter. In addition, FEMA would have to change the current

configuration of the letter to include this information, which may result in a

significant increase in the length of the letter, according to officials.

Officials also said that applicants may receive more detailed information

to better understand their case and FEMA’s eligibility and award

determinations by calling FEMA’s Disaster Helpline to ask about their

case or request a copy of their case file. However, as we have previously

reported, individuals may face challenges receiving assistance over the

phone due to unanswered calls and long wait times.

Further, staff from

the NPSC in Puerto Rico explained that requesting and obtaining a case

file is challenging, and officials from an NGO in Texas reported delays in

GAO-19-318. In this report, we found that, in the days after Hurricane Maria, up to 69

percent of calls to FEMA’s Disaster Assistance Helpline went unanswered and the daily

average wait time for answered calls peaked at almost an hour and a half, according to

our analysis of FEMA data.

Page 49 GAO-20-503 Disaster Assistance

receiving case files for the survivors they were helping to appeal FEMA’s

decisions.

The award determination letter is FEMA’s primary method of

communicating eligibility and award decisions to applicants. The current

version of the letter does not include any information about the amount of

damages verified by FEMA during the inspection nor other important

information, such as insurance settlements, that the agency factors into

its award decisions. According to the National Disaster Recovery

Framework, the federal government plays an important role in providing

accessible information to the public and all stakeholders involved in

recovery, including information about federal grants and loans with

potential applications to recovery. Further, the federal government is

responsible for ensuring that information is distributed in an accessible

manner and is well understood, so that all stakeholders, including

individuals, are informed and aware of the process and have realistic

expectations for recovery.

In addition, according to the Substance

Abuse and Mental Health Services Administration, trustworthiness and

transparency are key principles of a trauma-informed approach, and a

program that is trauma-informed ensures that processes and decisions

are conducted with transparency and with the goal of building and

maintaining trust with those involved in the system. By identifying and

implementing strategies for providing additional information to applicants

about how FEMA determined their eligibility for assistance and the

amount of assistance to award, the agency could help applicants better

understand its eligibility and award determinations, and better manage

their expectations, build trust, and improve program transparency.

Since 2016, FEMA’s call center workforce faced challenges using the

program guidance to assist survivors and struggled with low morale, and

following the catastrophic 2017 hurricane season, worked without

adequate training. FEMA field staff also worked with limited capability to

assist survivors. Lastly, state and local officials we spoke with reported

limited understanding of the program and coordination challenges, which

affected their ability to assist survivors and implement direct housing units

for survivors.

Department of Homeland Security. National Disaster Recovery Framework.

FEMA Faced

Challenges in

Managing its IHP

Workforce and

Supporting and

Coordinating with

Local Officials from

2016 through 2018

Page 50 GAO-20-503 Disaster Assistance

FEMA staff that we interviewed in all four of the IHP’s call centers noted

that they could not maintain awareness of IHP guidance because of its

large volume and frequent changes to it, which affected the quality of their

customer interactions and the consistency of their casework supporting

award determinations. We identified over 90 program guidance

documents that staff used to register and process IHP applications for

disasters declared from 2016 through 2018. Furthermore, from 2016

through 2018, FEMA sent 2,999 (an average of three per day)

notifications to NPSC staff, communicating changes or clarifications in

IHP procedures and guidance. For example, one staff noted that FEMA

changed program guidance for survivors in the U. S. Virgin Islands to

receive assistance for purchasing a generator—that could result in

survivors not being awarded assistance for which they were otherwise

eligible if staff were not aware of the new guidance.

Staff in one location

noted that FEMA frequently updates guidance but that these changes are

not bolded or highlighted in any way, so staff must read through the entire

guidance to identify the new information, and they do not have enough

time to review these guidance document in the course of their work.

The Policy and Doctrine Unit of the IHP is responsible for developing

guidance documents—called Standard Operating Procedures (SOPs)—

which include detailed instructions for NPSC staff on how to

operationalize their caller services and casework in accordance with

policies and regulations. Throughout 2016, IHP management officials

consolidated over 250 IHP documents, including SOPs, job aids, and

Frequently Asked Questions, into a set of 70 SOPs and guidance

documents to help NPSC staff process cases more efficiently and provide

survivors with relevant information. Program officials also create disaster-

specific SOPs as needed, and we identified 21 such documents for

disasters declared in 2016 through 2018. According to program officials,

According to FEMA officials, there were two adjustments made in disaster-specific

guidance aimed at expanding assistance for generators in the U.S. Virgin Islands. On

October 4, 2017, FEMA waived a requirement to demonstrate medical need, and on

December 18, 2017, FEMA extended the eligibility period to receive assistance.

Inadequate Guidance and

Training for Staff and

Morale Issues Affected

IHP Services for Survivors

Frequent Changes in IHP

Guidance Are a Challenge for

FEMA Call Center Staff

The Federal Emergency Management

Agency (FEMA) Manages Four Call

Centers to Support Delivery of Individuals

and Households Program (IHP) Assistance

to Disaster Survivors

The four National Processing Service

Centers—located in Winchester, Virginia;

Hyattsville Maryland; Denton, Texas, and

Caguas, Puerto Rico—house about 1,000

caller services and casework staff who play a

key role in registering survivors, answering

questions, and processing IHP applications.

On any given day, the program assigns their

work—either on the phone or processing

applications—across any of the open disaster

declarations based on demand. These four

centers have physical offices, however many

staff can work from home, and FEMA can set

up additional temporary locations and call

upon other federal partners to provide surge

support during high disaster activity. For

example, FEMA leveraged thousands of

Internal Revenue Service and U.S. Census

Bureau employees to support historic call

volume in 2017.

Source: GAO summary of FEMA officials’ interviews and

documentation. | GAO-20-503

Page 51 GAO-20-503 Disaster Assistance

the variety of assistance types and the specifics of each survivor’s

application require a large volume of guidance.

According to IHP management officials, guidance is continually updated

with input from processing staff. FEMA communicates changes in

guidance and reminders to staff of existing procedures, through “pre-

shifts”—notifications that staff access before they begin work each day—

and occasional “flash notifications”—sent by email to communicate time-

sensitive changes in guidance.

According to program officials, information about what content changed in

FEMA’s IHP policies and procedures from 2016 through 2018 is not

readily available because FEMA did not keep a record of changes to

SOPs. Further, when program officials update the guidance documents,

they do not highlight these changes in the text. The IHP Policy and

Doctrine Unit began tracking these changes in a spreadsheet in 2019,

which officials stated would allow IHP Policy and Doctrine Unit

management to better monitor the changes and the effect of those

changes on program implementation. However, this spreadsheet does

not directly improve the accessibility or usability of information about

guidance changes for NPSC staff. According to officials, between April

2019 and March 2020, the program posted over 600 pre-shifts, about

one-third of which contained reminders to staff based on existing

information in guidance; the remaining two-thirds contained various types

of updates, such as new call transfer procedures or specific procedural

changes made to guidance. Pre-shifts related to updated guidance

include a summary of the major changes to the document.

Internal control standards state that management should communicate

the necessary quality information to achieve objectives internally. To this

end, management takes steps such as determining the appropriate

method of communication based on factors such as availability, among

others, and periodically evaluating these methods.

Additionally, FEMA’s

2018-2022 Strategic Plan states that the agency must evaluate

operations and simplify processes and systems, taking a strategic

approach to improve the capabilities of its workforce and efficiency of

processes, among other things.

As of March 2020, IHP management

officials stated that they were exploring technology-based solutions to

GAO-14-704G.

Federal Emergency Management Agency, 2018-2022 Strategic Plan, (Washington,

D.C.: March 15, 2018).

Page 52 GAO-20-503 Disaster Assistance

make the existing guidance more easily searchable; however, program

officials have not developed a plan to evaluate the methods used to

communicate changes in program guidance to NPSC staff responsible for

applying the guidance while providing services to disaster survivors.

Given the importance of the guidance for over 1,000 staff implementing

the program, as well as surge support staff who assist during high

disaster activity, evaluating methods for communicating future SOP

changes to improve the accessibility and usability of program guidance

for NPSC staff can help with quality customer interactions and consistent

casework supporting award determinations.

Opportunities exist to improve employee engagement and morale among

NSPC staff. Our work finds that employee engagement is one component

of employee morale and results in better organizational performance;

increased productivity; and higher customer service ratings, among other

benefits. Employee engagement relies on effective management and

communication with employees and includes establishing clear

expectations and priorities, providing effective coaching and feedback,

and showing appreciation to staff.

According to NPSC staff at all four locations, poor employee engagement

from their management and supervisors resulted in pressures related to

productivity, among other challenges, particularly since the 2017

hurricane season, and resultant high work volume for IHP call center

staff. However, program managers countered that these perspectives

among staff did not reflect management activities. These differences in

perspectives between staff and managers related to employee

engagement activities included the following:

• NPSC staff in all four locations stated they felt pressured to meet

productivity standards, which conflicted with providing quality service

to the survivor, and some staff stated they were concerned that

managers could fire them for not completing tasks quickly enough.

According to NPSC staff, calls can take a long time because survivors

are traumatized by the disaster or may have limited education and

struggle to understand requirements. Taking extra time on a call can

also reduce the need for survivors to call back multiple times to have

their needs met, according to NPSC staff. While NPSC management

developed productivity metrics for staff in 2017, during that year

program officials determined they would not use the productivity

GAO-20-349T; GAO-15-585.

Opportunities Exist to Improve

Employee Engagement and

Morale among NPSC Staff

Page 53 GAO-20-503 Disaster Assistance

metric because it was unreliable. According to program management

officials, FEMA never terminated an employee based on this

proposed productivity metric, and terminations from calendar years

2016 through 2018 represented 1 percent or less of assigned agents

each year. Nonetheless, due to the ineffective employee engagement,

specifically poor communication and unclear performance

expectations, staff we spoke with stated they had experienced

significant job pressure since 2017.

• NPSC staff in three locations discussed that supervisors and program

managers do not provide effective feedback and coaching to staff

when they faced challenges with the speed or accuracy of their work.

Given the complexity of the program, staff in all four locations told us

they felt pressure from managers should they find errors in staffs’

survivor interactions or case processing. They stated that supervisors

and program managers did not provide sufficient coaching or

feedback to address any issues with their performance. Rather, staff

were concerned that managers would provide staff with a poor

evaluation, possibly threatening their jobs. However, according to

NPSC managers, performance evaluations also consider whether the

outcome for survivors was correct when quality control processes

identify errors in staff processing. Additionally, NPSC staff stated that

they faced low morale or poor employee engagement in the absence

of effective mentoring and coaching activities. For example, staff in

two centers stated that their supervisors reprimanded them rather

than providing effective support—in one case for asking the

supervisor questions too often, and in another case for spending too

much time with an applicant.

• NPSC staff we spoke to also told us that managers did not

communicate key changes in their work. For example, management

did not communicate to staff the implications for processing awards

following the enactment of the Disaster Recovery Reform Act of 2018,

or changes in the registration script. Staff also noted they were

unprepared for the rollout of a new phone system during the response

to Hurricane Harvey.

• NPSC staff stated that managers did not show appreciation for their

work. For example, one NPSC staff member said that FEMA used to

acknowledge efforts by awarding an employee of the month, but that

no longer happens. NPSC managers stated that staff have been

eligible for awards under a continuous program in place since 2012,

although FEMA did not provide details on the extent of staff awards

since 2017.

Comments on Employee Morale and

Engagement from Individuals and

Households Program Call Center Staff

The staff member used to love the job, but

now feels anxiety because of FEMA treating

[call center] staff like a number and

replaceable…staff can be fired for small

mistakes even if the outcome is right. The

morale is very low and some staff have had to

go to therapy.

Performance quotas make the job stressful

given how complicated the program is. Call

center staff are expected to make it black and

white and it just is not. Staff can fail their

Quality Control review and then they are so

scared of making mistakes, they work more

slowly, and then get dinged for only finishing

10 cases in a day. New hires are scared to do

processing because getting a bad mark will

mean losing their job.

When call volume is high, leadership is

always looking for ways to limit the time call

center staff are on the phone with the

applicant. However, some of those [survivors]

really need the time and the [nonprofit]

services would really help them, but because

of time constraints staff cannot provide great

customer service.

Source: GAO interviews with call center staff | GAO-20-503

Page 54 GAO-20-503 Disaster Assistance

While staff and managers’ perspectives on the level of staff morale and

the state of employee engagement efforts differed, NPSC staff are the

intended recipients of employee engagement efforts, and staff we spoke

to consistently cited engagement challenges that undermined morale in

all four call center locations. Accordingly, opportunities exist to improve

employee engagement and morale, particularly during and after the

periods of high work volume, as was the case following the 2017 and

2018 hurricane seasons.

In 2017 and 2018, the IHP took actions that decreased its focus on

employee engagement and morale. In particular, our review of the NPSC

management and supervisor individual performance goals found that an

explicit focus on employee morale and activities associated with

employee engagement was included in 2016; however, we found that the

IHP omitted the goals in 2017 and 2018. Officials removed the goal

referencing morale after a 7 percent increase in the employee’s overall

satisfaction from September 2016 to September 2017 on an employee

satisfaction survey, according to NPSC management officials.

Furthermore, in 2016, the performance expectations included clarifying

performance expectations with the employee; periodic meetings to

discuss coaching topics; and creating individual development plans with

the employee focused on the most effective training and development

opportunities for their professional or technical growth, among other

things. However, these detailed performance expectations were absent

from goals in 2017 and 2018. Lastly, while NPSC management and

supervisory performance expectations for 2017 and 2018 included a

minimum of one quarterly meeting to discuss challenges and improve the

overall work environment, management allowed the program to waive this

requirement during periods of high work volume.

Beginning in 2019, NPSC management began or reinstated multiple

activities intended to improve employee engagement. For example, in

October 2019, NPSC management implemented further employee

recognition awards, similar to an employee-of-the-month to celebrate

employee successes. Additionally, as of March 2020, NPSC management

was preparing a pilot program to assess the ability for supervisors to

conduct biweekly discussions with each team member to discuss

performance, core competencies, and individual professional

development. FEMA had hired about 40 new staff, to focus on providing

personal coaching to NPSC staff. NPSC management also conducted the

employee satisfaction survey again during February and March of 2020

and, according to IHP managers, the program will consider the results in

selecting 2021 performance goals, along with other methods of obtaining

Page 55 GAO-20-503 Disaster Assistance

feedback from employees, such as town halls and small group

meetings.

Although it is too early to determine the effect of these

activities, improved employee engagement provides an opportunity to

clarify performance expectations, such as the faulty understanding NPSC

staff had about productivity standards, which contributed to low morale

during the high workloads following the 2017 hurricane season, according

to NPSC staff we interviewed.

Our work finds that what matters most in improving engagement levels is

valuing employees—that is, an authentic focus on their performance,

career development, and inclusion and involvement in decisions affecting

their work. We also found that attention to work-life balance is important

for employee morale.

While NSPC management has begun or

reinstated several activities intended to improve employee engagement,

NSPC management had decreased their focus on employee morale just

before staff would face significant pressure from the 2017 and 2018

disasters. NPSC management also stated that continual efforts should be

made to focus on call center staff morale because of their important

customer service function. By including a focus on performance feedback,

career development, communication, and attention to work-life balance

while completing planned employee engagement activities and, further,

when assessing employee satisfaction scores and implementing

additional steps to strengthen employee engagement, FEMA will be

better able to ensure NPSC management and supervisor attention on

employee morale.

NPSC staff told us that they did not have adequate training to provide

quality and consistent performance when completing registration and

case processing. Staff explained that FEMA provided compressed

versions of the training for the different work activities—such as

registration or case processing—due to high disaster activity in 2017 and

2018. The training FEMA provided did not effectively support staff in

applying the guidance to answer survivors’ questions and process cases

they encountered in their work, according to NSPC staff. In 3 of the 4

locations, staff cited case processing training—which provides details

such as what documentation is needed to meet eligibility requirements for

Other efforts included quarterly all-hands meetings for staff appreciation and

communication with NPSC management, brown bags to discuss issues identified by staff,

a revived awards and recognition program, and the creation of an employee group

designed to elevate staff concerns to NPSC management.

GAO-20-349T; GAO-15-585.

Limited Training for NPSC

Staff in 2017 and 2018

Affected Service to Survivors

Page 56 GAO-20-503 Disaster Assistance

each type of assistance—as helpful for working effectively while

supporting survivors, for example, during registration or calling the

helpline. However, staff stated that they do not take this training before

they answer calls from survivors. Further, NPSC staff in all four locations

noted that there needed to be more customer service training, for

example, to help survivors when dealing with the trauma caused by the

disaster. In one location, staff gave examples of program managers

providing a briefing on processing appeals and processing applicants for

continued temporary housing assistance, but managers expected them to

complete those work activities without complete training.

NPSC program managers confirmed that FEMA provided all NPSC staff

compressed training in phases during catastrophic disaster operations in

2017 and 2018. For example, the comprehensive training to answer

survivors’ questions includes a 10-day curriculum. According to program

managers, FEMA officials compressed this training to a 5-hour surge

training before staff began answering calls when survivors apply for

assistance. FEMA provided an additional 3-day training that provided

NPSC staff with more skills needed to assist survivors calling FEMA with

questions about the status of their application and steps for processing

awards and appeals. In an effort to make staff available quickly, these

surge training efforts also omitted evaluation and feedback activities that

are protocol during nonsurge training. Officials stated that supervisor

support is also provided to NPSC staff to ensure that they understand

how to accomplish their assigned tasks. However, as we stated

previously, NSPC staff we interviewed stated that they have not received

consistent support from supervisors and management since 2017.

Our prior work on assessing training efforts in the federal government

states that an agency should evaluate the effectiveness of its training and

development efforts, to include obtaining feedback, assessing

Appeal processing is how FEMA ensures that applicants have the ability to request a

review of a decision made by the IHP, which generally includes requesting needed

information and documents from survivors who wish to appeal and assessing the new

information against the eligibility requirements. Continued temporary housing assistance is

an additional award for rental or temporary housing beyond the initial period of assistance,

which is typically 2 months. FEMA can award continued temporary housing assistance

based on need and generally only when adequate, alternate housing is not available, or

when the applicant’s permanent housing plan has not been fulfilled through no fault of the

applicant. Processing these cases generally includes reviewing all elements of a survivor’s

eligibility; reviewing the basis for their continued needs; and contacting the survivor or

landlord to collect additional information, among other steps.

Page 57 GAO-20-503 Disaster Assistance

competency, and analyzing relevant data.

Internal controls standards

state that management should demonstrate a commitment to develop

competent individuals in those units, such as through training, to enable

the organization to operate in an efficient manner and help achieve the

organization’s objectives.

We recognize that during disasters FEMA

needs to deploy staff quickly—such as the thousands of staff from across

the federal government who provided surge support to call centers in

2017. However, to effectively support IHP service delivery, staff need

training that allows them to provide quality and consistent performance,

as NPSC staff are on the front line of providing service to survivors and

processing their application for disaster assistance. By assessing the

effectiveness of the IHP training and employee support during surge

events and implementing any necessary changes, FEMA can optimize

efforts to ensure that NPSC staff have the skills to provide consistently

accurate and quality service to disaster survivors.

DRCs provide an important resource to survivors who do not have

electricity or reliable cellphone service, as is often the case following a

disaster, as well as other groups who do not regularly use computers.

However, the limitations of staff qualifications and capabilities at these

locations resulted in missed opportunities to help survivors quickly. For

example, one survivor we spoke with encountered multiple challenges,

but in the end, her visits to the DRC enabled her to resolve errors in her

case and resulted in an IHP award that allowed her family to rebuild their

home (see sidebar). This case demonstrates both the value of the DRCs

as a resource to survivors but also the challenges that exist when staff

are unable to provide consistent information to support survivors

navigating recovery. Officials who worked on all five major disasters we

looked at reported problems with DRC staff capabilities to support

survivors.

DRC staff lack the skills and abilities to consistently support

survivors. Officials we interviewed from California, six localities, and one

NGO described challenges survivors experienced with receiving accurate

and consistent guidance from FEMA field staff, including at FEMA’s

DRCs. For example, local officials from Florida and North Carolina said

FEMA staff at the DRCs lacked knowledge of the IHP and, as a result,

could not effectively assist survivors. Further, staff in 2 of the 4

GAO-04-546G.

GAO-14-704G.

Opportunities Exist to

Better Support Survivors

by Increasing Capabilities

at Disaster Recovery

Centers

Page 58 GAO-20-503 Disaster Assistance

NPSCs said that DRC staff gave many survivors incomplete or incorrect

information. For example, NPSC staff said that DRC staff gave survivors

inaccurate guidance about the documentation they needed to submit,

which can delay assistance. Roughly 90 percent of DRC staff in

Hurricane Irma were trainees, and almost all DRC staff in Hurricane Maria

were newly hired and trained, according to the Chief of FEMA’s DRC

Unit.

DRC staff lack capabilities needed to assist survivors. Individual

Assistance Program leadership from FEMA Region VI told us that FEMA

is missing an opportunity to provide better assistance to survivors by

using DRC staff as a force multiplier. Officials explained that DRC staff

can check the status of a survivor’s case, and fax in documents, but they

cannot make changes to their case. For example, they cannot correct the

spelling of a name, update an address, or reinstate an inspection when

the home becomes accessible. In order to make changes to a case,

survivors are required to call FEMA. However, these officials noted that

survivors faced long wait times on the phone, and some had difficulties

communicating over the phone.

FEMA has identified improving DRC capabilities as a lesson learned from

prior major disasters. In the Hurricane Sandy After-Action Report, FEMA

noted multiple areas for improvement, including that the DRCs did not

always meet survivor needs efficiently and that the DRCs did not

consistently offer the same services.

A key lesson learned from the

2017 disasters was that FEMA needed to have more qualified staff at the

DRCs and cited providing survivors with inconsistent information as a

common complaint, according to FEMA’s DRC Unit Chief. FEMA officials

we met with suggested some strategies that FEMA should implement to

provide better service to survivors at the DRCs, including deploying full-

time NPSC staff who are more experienced and providing on-the-job

training to reservists targeted to enable them to help resolve frequent

challenges in the case file, such as updating contact information. For

example, a program official from FEMA Region VI said that FEMA

provided additional training to reservists at the DRCs for Hurricane

Harvey, enabling DRC staff to provide more effective support to survivors

in the field. The additional training enabled DRC staff to make simple

changes to a survivor’s case file, and officials recommended that FEMA

use this successful strategy in future disasters. Although FEMA officials

Federal Emergency Management Agency, Hurricane Sandy FEMA After-Action Report.

(Washington, D.C.: July 1, 2013).

One Survivor Visits the Disaster Recovery

Center (DRC), Showing Evidence to

Support Her Case

A survivor we met with in Puerto Rico

explained her experience with FEMA’s

Individuals and Households Program. She

applied for assistance after Hurricane Maria,

but did not hear back from FEMA for six

weeks. She made at least 10 visits to the

DRC in Bayamon—an hour long round trip—

to obtain an update on the status of her case

and address her recovery needs. She visited

the DRC so often because she faced

challenges with translation and receiving

consistent information from FEMA staff over

the phone. During one visit, she collected

information on how to get help from two non-

profits assisting disaster survivors. She told us

she also received inconsistent answers from

DRC staff. For example, on three separate

visits to the DRC, she received different

explanations for why FEMA denied her rental

assistance. She eventually learned that the

FEMA inspector omitted from her case photos

of the damage to her home. With help of DRC

staff, she submitted her own photos to FEMA

and received a new inspection to inform

FEMA’s IHP award decision.

The survivor said FEMA awarded her about

$40,000 in total assistance—roughly $31,000

five months after she applied and an

additional $9,000 following the enactment of

the Disaster Recovery Reform Act of 2018.

She also received a condo leased by FEMA

through the Direct Lease Program (see

below), where she lives with her husband and

son, while she completes repairs on her

home.

Source: GAO; photos taken by GAO while on site in Puerto

Rico. | GAO-20-503

Page 59 GAO-20-503 Disaster Assistance

stated that curriculum development and funding challenges may affect the

expansion of this practice, they added that the training allowed staff to

better assist survivors at the DRCs. FEMA also has an ongoing training

program for field staff prior to hurricane season and offers a refresher

course at other times, as available.

The DRC Unit Chief stated that FEMA tries to update trainings so field

staff can remain aware of frequently changing guidance; however, our

work found that FEMA is not always able to provide necessary field

training. In May 2020, we reported on FEMA’s challenges in managing

the disaster workforce in 2017 and 2018, which included staff working at

the DRCs, and found that FEMA faced staffing shortages; could not

reliably determine staffs’ ability to perform their functions; and faced

challenges with staff development efforts, such as training.

Specifically,

we reported that not knowing staffs’ ability to perform their functions

created operational challenges, including negatively affecting the delivery

of assistance. For example, we reported that staff FEMA thought were

qualified did not know eligibility and documentation requirements or how

to use the program’s information management system. Lastly, we found

that most staff cited on-the-job training as the most useful, but FEMA

faced challenges in providing such training. We made three

recommendations for FEMA to (1) develop a plan to ensure that FEMA

provides reliable information on staff abilities, (2) develop mechanisms to

assess how effectively the workforce meets mission needs, and (3) create

a staff development program. FEMA concurred with all three

recommendations and, as of April 2020, FEMA provided us with their

plans to begin addressing them; however, these actions are broad in

nature, to improve human capital management across the entire agency,

and may not precisely target the unique challenges with staff skills and

capabilities providing direct support to disaster survivors at the DRCs.

According to FEMA’s 2018-2022 Strategic Plan, the agency prioritizes

maintaining a skilled, knowledgeable, efficient, and survivor-focused

incident workforce and plans to strengthen the incident workforce by

building capabilities and capacities to fulfill its responsibility to effectively

respond to a catastrophic event. Further, the plan states that FEMA must

GAO, FEMA Disaster Workforce: Actions Needed to Address Deployment and Staff

Development Challenges, GAO-20-360 (Washington, D.C.: May 4, 2020).This report

discussed challenges affecting FEMA’s entire incident management workforce, which is

organized into 23 cadres, which are groups of staff organized by operational or

programmatic functions. Staff working at the DRC are part of the Individual Assistance

cadre.

Page 60 GAO-20-503 Disaster Assistance

create innovative and efficient solutions to provide the most effective

support to survivors, and reduce the number of duplicative interactions

that survivors experience when accessing programs. By identifying and

implementing strategies to ensure that staff at its DRCs have the needed

skills and capabilities, such as through targeted, on-the-job training,

FEMA could improve support to survivors who visit the DRCs and

streamline the survivor experience.

Local officials from all 10 localities, as well as officials from two states—

Texas and Florida—and Puerto Rico told us that local officials needed a

better understanding of the IHP, through additional training, support, or

guidance, to assist survivors navigating the recovery process. For

example, local officials told us they did not understand the types of

assistance available through the IHP; requirements survivors must meet

to receive assistance; or how the process works, in general. As previously

discussed, determining the type and amount of assistance for disaster

survivors through the IHP is a process that weighs various eligibility

criteria, and FEMA staff must follow more than 90 procedural documents

that program officials frequently update, in order to determine eligibility

and deliver assistance. While much of this guidance is designed for

FEMA staff, it contains details on how IHP staff process applications,

determine eligibility, and deliver assistance that local officials we spoke to

did not understand. Since 2016, FEMA has published the publically

available Individuals and Households Program Unified Guidance, which

compiles FEMA policy for each type of assistance under the IHP into one

comprehensive document, to serve as a singular resource for state, local,

territorial, and tribal governments.

However, this document has not

Federal Emergency Management Agency, Individuals and Households Program Unified

Guidance (FP 104-009-03) (Washington, D.C.: September 2016). In March 2019, FEMA

published new guidance, the Individual Assistance Program and Policy Guide, which

combines the guidance on the IHP with guidance on the other five key programs under

Individual Assistance and provides some additional details on eligibility criteria for the IHP,

among other changes.

Local Officials Did Not

Understand the IHP and

Reported Information

Sharing and Coordination

Challenges with FEMA

FEMA Did Not Provide

Sufficient Training, Support, or

Guidance on the IHP to Local

Officials

Page 61 GAO-20-503 Disaster Assistance

contained certain details about processing assistance, appeals, or

disaster-specific assistance information.

Officials we interviewed from 6 of the 10 localities told us FEMA did not

provide any training, support, or specific guidance for their disaster, and

officials from four localities told us that they had to learn about the IHP on

their own during disaster recovery operations. For example, county

officials from Texas said they did not receive any training on the IHP from

FEMA and searched the internet to learn about the program. As another

example, county officials from North Carolina told us that they received

pieces of information on the IHP from meetings with FEMA, the state, and

NGOs. They explained that, absent sufficient support, they had to

personally search for key information on program processes and

requirements, all while trying to help constituents through their crises, as

well as addressing their own recovery needs.

Additionally, officials from 6 of 10 localities noted that FEMA provided

them with a liaison to address their questions and concerns about the

IHP. However, turnover of FEMA liaisons created challenges with

receiving consistent support from FEMA. In addition, local officials from 4

of our 5 selected states and territories reported receiving inconsistent and

conflicting guidance from FEMA officials on the IHP. Officials from 7 of 10

localities explained that they needed to be knowledgeable on the program

to help disaster survivors in their community understand and navigate the

program. According to county officials in California, survivors typically

direct their questions to local officials first, and survivors became

frustrated when local officials cannot answer them.

FEMA’s role is to coordinate federal resources to supplement state, local,

tribal, and territorial capabilities; however, we and DHS have previously

reported that local officials have capability gaps related to implementing

federal recovery programs, including the IHP. FEMA coordinates primarily

with states, tribes, and territories, and the National Disaster Recovery

Framework assigns states the primary responsibility for planning and

For example, often during initial processing or an appeal, FEMA staff need details

regarding damages or expenses before making a final determination. While the policy

guide states that verifications may be needed to process awards and appeals, internal

guidance details specific information for certain damages, and procedures for when

appeals may be denied because of an inability to verify information with other entities such

as contractors and insurance companies. According to FEMA officials, disaster-specific

changes are generally initiated by the state, territory, or tribe and those officials are

informed of any changes FEMA approves.

Page 62 GAO-20-503 Disaster Assistance

managing all aspects of the recovery of their communities. States act in

support of local communities, evaluate their capabilities, and assist

overwhelmed local governments. We reported in May 2020 that gaps

exist in states’ capacity to support longer-term recovery.

Texas state

officials we met with explained that emergency managers prioritize

response capabilities over recovery. Further, a state official we met with

from Florida explained that local officials typically have a better

understanding of FEMA’s infrastructure recovery programs and do not

recognize the importance of the IHP until after a disaster. Furthermore,

state and territorial officials consistently report capability challenges to

manage recovery in their communities, according to DHS’ National

Preparedness Reports from 2018 and 2019.

State and local officials suggested various ways that FEMA could improve

local officials’ access to information on the IHP, which included providing

training or informational materials on the IHP to local officials. Program

officials from one region stated that the program looks for opportunities to

provide training on the IHP, such as through conferences, social media,

and webinars. IHP officials from two regions noted that, during

nondisaster periods, FEMA provides training or technical assistance to

states, tribal governments, and voluntary agency partners through the

regions. FEMA may provide training to local officials when coordinated by

the state official managing assistance to individuals. However, only 10

states have staff tasked with overseeing assistance to individuals, which

could include managing housing recovery. This presents a challenge for

FEMA providing training to state officials and supporting efforts to train

local officials, according to IHP management officials.

According to the National Disaster Recovery Framework, successful

recovery requires informed and coordinated leadership throughout all

levels of government and phases of the recovery process. The federal

government plays an important role in providing accessible information

about federal grants and loans to the public and all stakeholders involved

in recovery, including local officials. The federal government’s supporting

role is especially important during the early weeks of a disaster, when

governments in the affected area are overwhelmed with response and

GAO, National Preparedness: Additional Actions Needed to Address Gaps in the

Nation’s Emergency Management Capabilities, GAO-20-297 (Washington D.C.: May 4,

2020).

Department of Homeland Security, 2018 National Preparedness Report (Washington,

D.C.: Nov. 14, 2018); and 2019 National Preparedness Report (Washington, D.C.: Dec. 2,

2019).

Page 63 GAO-20-503 Disaster Assistance

short-term recovery efforts. By identifying and implementing strategies to

provide readily accessible information about the IHP to state, local, tribal,

and territorial officials, FEMA can help ensure that local officials

understand the IHP, which is essential for a successful recovery.

Officials from 7 of the 10 localities we met with reported challenges in

coordinating with FEMA on direct housing efforts, specifically for the

Transportable Temporary Housing Units, which FEMA has used most

often to provide temporary housing assistance to survivors since 2010.

Officials from four of these localities reported a lack of coordination by

FEMA on the delivery or placement of FEMA direct housing units, which

delayed the assistance to survivors.

To provide the Transportable Temporary Housing Units, FEMA must

assess the local property; determine what type of site the unit will placed

on; and take steps to prepare the site and the unit before the survivor can

move in, such as ensuring that utilities are properly installed and

available. This process involves coordination between multiple

organizations within FEMA and the state and local agencies. Figure 15

below describes this process.

Local Officials Reported Direct

Housing Coordination

Challenges with FEMA

Page 64 GAO-20-503 Disaster Assistance

Figure 15: Selected Steps and Required Coordination to Deliver a Transportable Temporary Housing Unit through the Federal

Emergency Management Agency’s (FEMA) Individuals and Households Program (IHP)

According to officials in Texas, Florida, and North Carolina, challenges

with information sharing and coordination often resulted in delays. For

example, county officials from Texas said FEMA did not communicate

with them on the timing or location for the contractor’s delivery of

Transportable Temporary Housing Units. As a result, the county officials

faced challenges in hooking units up to utilities, such as water, sewage,

and electricity, which caused delays making Transportable Temporary

Housing Units available for survivors. Officials said some units sat on

survivors’ property for months without utilities and without the county’s

knowledge. County officials from Texas also said that FEMA would not

share information on the timing or location for the contractor’s delivery of

Transportable Temporary Housing Units, citing restrictions to protect the

personal information of the survivor receiving the unit. A state official from

North Carolina reported that FEMA’s contractors did not consistently

communicate the placement of units in a timely manner. In addition,

county officials from North Carolina said FEMA contractors failed to tell

Page 65 GAO-20-503 Disaster Assistance

them about the delivery of a unit and, as a result, the survivor who

received the unit did not have electricity.

FEMA delivers housing units using contractors, and IHP officials said that

the contractors were responsible for coordinating with local officials on the

placement of units. According to FEMA’s Direct Housing Guide, there are

multiple points of coordination between the contractor, state and local

officials, and IHP and FEMA logistics officials in the field.

For example,

the field logistics officials are responsible for ensuring oversight of

contractor activities delivering and installing the housing units, including

ensuring that the contractor provides regular status updates. The Direct

Housing Guide also states that FEMA field officials enter milestone dates

into FEMA’s Housing Operations Management Enterprise System to

monitor progress, including dates the unit arrives onsite, ready for

electric, and ready for occupancy. However, program officials said this

system—which is FEMA’s system of record for tracking direct temporary

housing assistance—lacks controls; is inconsistently used by field staff;

and has incomplete information, contributing to information-sharing

challenges. According to IHP officials, updating this system as part of

agency-wide modernization efforts is a priority that will promote better

information sharing for all recovery partners. FEMA has yet to identify

when the new system will be available for use in program delivery, and

we have previously reported delays with this agency-wide effort.

According to the National Disaster Recovery Framework, disaster

operational coordination crosses all mission areas and is critical to

efficient and effective recovery activities, including disaster housing.

Local, regional, state, tribal, territorial, and insular area governments have

primary responsibility for the recovery of their communities and will need

leadership and coordination mechanisms to be in place in order to

effectively assess and evaluate recovery issues, determine priorities,

Logistics field officials report to the Branch Director for Direct Housing under the

Logistics Section Chief. Similarly, IHP field officials report to a Branch Director for Direct

Housing under the Individual Assistance Branch Director.

See GAO, FEMA Grants Modernization: Improvements Needed to Strengthen Program

Management and Cybersecurity, GAO-19-164 (Washington, D.C.: Apr. 9, 2019). FEMA is

developing a new, agency-wide enterprise data system that will include a dedicated

solution for delivering housing missions, including Transportable Temporary Housing

Units. The Grants Management Modernization platform will allow FEMA and state, local,

and tribal partners to integrate the delivery of direct housing while streamlining the

process by replacing paper-based processes with electronic transactions and mobile

device data capture.

Manufactured Housing Units (top) and

Recreational Vehicles (bottom) in a Group

Site Providing Transportable Temporary

Housing for Survivors of Hurricane

Michael

Source: GAO; photos taken by GAO while on site in Florida. |

GAO-20-503

Page 66 GAO-20-503 Disaster Assistance

engage partners, identify and coordinate key resources, and implement

recovery strategies.

The FEMA official responsible for leading the direct housing mission in

North Carolina after Hurricane Florence said a best practice from her

experience was to increase engagement between FEMA and local

officials. She recommended that FEMA designate staff to serve as a

liaison between FEMA, direct housing contractors, and local officials to

ensure that local officials receive the information they need to carry out

their responsibilities in the direct housing process, such as ensuring that

units comply with local ordinances and hooking up utilities to the unit.

Program officials have developed multiple efforts to improve coordination

for providing direct housing, including the Transportable Temporary

Housing Units. For example, in September 2018, FEMA created the

Sheltering and Housing Field Teams, which include subject matter

experts from other units, such as general counsel and logistics, which will

provide technical support to the Joint Field Office and FEMA Regional

officials for developing a direct housing strategy after a disaster.

According to FEMA officials, field officials complete the strategy

implementation, but these teams may not provide ongoing coordination

support through delivery of units in the same way as a liaison identified as

a best practice in North Carolina. In April 2020, FEMA had planned for an

online repository of direct housing resources to provide job aids for direct

housing staff and, as of May 2020, it was planning to develop a public

guide.

While these efforts present opportunities to improve information sharing

about direct housing assistance generally, the efforts do not provide a

process for coordinating among FEMA; contractors; and state, local, and

tribal and territorial partners to effectively deliver Transportable

Temporary Housing Units to disaster survivors. While program officials

await a new system of record for delivering direct housing assistance,

identifying and implementing best practices for information-sharing and

coordination with recovery partners on the delivery of Transportable

Temporary Housing Units will help ensure that FEMA and local officials

deliver direct housing units to survivors in an efficient and effective

manner.

Joint Field Offices are multiagency coordination centers established near disaster sites

for coordinating major disaster response and recovery efforts.

Page 67 GAO-20-503 Disaster Assistance

FEMA collects and analyzes data to track the agency’s progress on IHP

performance measures and assess survivors’ experiences with the

program. For example, FEMA’s 2018-2022 Strategic Plan includes the

following four performance measures that are related to the IHP: (1)

decrease the percentage of FEMA and overall federal in-person

inspections; (2) raise applicant satisfaction with the simplicity of the IHP;

(3) increase the timeliness of financial IHP assistance awards; and (4)

improve the accuracy of IHP financial assistance. Further, FEMA

established several additional performance measures to assess the

timeliness of IHP services and processes, such as telephone application

and helpline services, case processing, inspections, and the provision of

financial and direct assistance to survivors.

FEMA also conducts three different telephone surveys to assess

survivors’ experiences with the IHP, and FEMA uses its survey results to

assess program performance.

However, the methodology that FEMA

uses for its surveys does not fully align with federal standards for

statistical surveys, limiting FEMA’s ability to use survey results to

determine how well the IHP is performing. FEMA builds its sample of

survivors to survey using a stratified random design, which is a type of

probability sampling. The target population for each of FEMA’s IHP

These surveys are (1) an initial survey to measure the quality of disaster assistance

information and services received by survivors during the initial application process; (2) a

contact survey to measure the quality of disaster assistance information and services

received by survivors while they checked the status of their case online or during

interactions with FEMA staff; and (3) an assessment survey to measure the quality of

disaster assistance information and services received by survivors after FEMA determines

their eligibility for IHP assistance.

FEMA Assesses IHP

Performance and Has

Ongoing Efforts to

Improve Program

Delivery, but

Opportunities Exist to

Further Enhance

These Efforts

FEMA Collects and

Analyzes Data to Assess

IHP Performance and

Survivor Experiences, but

Its Survey Methodology

Does Not Fully Align with

Federal Standards

Page 68 GAO-20-503 Disaster Assistance

surveys varies depending on the goal of the survey. For example, the

goal of the initial IHP survey is to measure the quality of disaster

assistance information and services received by survivors during the

initial application process. The target population for this survey consists of

all survivors who applied for IHP assistance during a 2-week period. From

this population, FEMA selects a number of applicants to survey from each

open disaster declaration based on a declaration’s proportion of all IHP

applications during a 2-week period.

Because FEMA uses a probability

sampling design for its IHP surveys, the estimates derived from the

survey data have sampling error associated with them.

But FEMA does

not calculate sampling error for the survey estimates that program

managers use, inhibiting their ability to accurately assess program

performance. FEMA also does not currently adjust the raw survey data

with sampling weights to reflect the stratification and variable patterns in

survey response between the different disaster declarations in the survey

population, meaning that unadjusted survey estimates are statistically

biased.

FEMA officials told us that they believe the IHP survey methodology is

valid for measuring program performance. Officials said that there

typically tends to be little variance in applicants’ satisfaction scores

between disasters that would warrant the implementation of weighting

procedures. According to the Office of Management and Budget’s

Standards and Guidelines for Statistical Surveys, surveys should employ

weights appropriate for the sample design to calculate population

estimates.

Further, variance estimates should be calculated by a

method appropriate to a survey’s sample design, taking into account

probabilities of selection, stratification, clustering, and the effects of

nonresponse. Officials told us that in 2011 they conducted a unit

nonresponse analysis on a recently retired survey that is similar to one of

For example, if, during a 2-week period, applications for disaster A made up 90 percent

of total IHP applications, then FEMA allocates 90 percent of the sample size for its survey

to applicants from disaster A.

In statistics, sampling error is the error caused by observing a sample instead of the

whole population.

Statistical bias arises when the sample survey estimates are expected to systematically

differ from the result obtained by surveying the entire population of all applicants.

Office of Management and Budget’s Statistical Policy Directive Step No. 2, guideline

4.1.1 Steps 1 and 3, and guideline 3.2.12. Office of Management and Budget, Standards

and Guidelines for Statistical Surveys (Washington, D.C.: September 2006).

Page 69 GAO-20-503 Disaster Assistance

the current IHP surveys and determined that nonresponse bias was not

present.

FEMA officials noted that they plan to conduct a new

nonresponse bias analysis based on additional demographic information

to determine if there are any factors FEMA should weigh in the survey

results. In August 2020, officials told us they completed a preliminary

nonresponse bias analysis on one of FEMA’s IHP surveys. However,

FEMA did not provide a time frame for completing this analysis for all IHP

surveys. Without (1) weighting the survey data to reflect the stratification

of its survey design, (2) adjusting the base sampling weights for survey

nonresponse within each stratum, and (3) calculating the sampling error

for the survey data after adjusting the base sampling weights for

nonresponse, FEMA is limited in its ability to use IHP survey results as

accurate, analytical evidence of experiences for all survivors who applied

for IHP assistance and to assess program performance.

Since 2017, FEMA has planned or implemented numerous efforts aimed

at addressing challenges with delivering disaster assistance to survivors

and satisfying legislative requirements. See appendix VI for a more

detailed description of each of the efforts listed below.

Housing Assistance Initiative. In April 2017, FEMA launched the

Housing Assistance Initiative, which resulted in dozens of

recommendations and multiple long-term goals for improving FEMA’s

approach to delivering safe, durable housing to survivors through the IHP

following any disaster. As of May 2020, FEMA has implemented all but

one recommendation for this initiative, according to officials.

2017 Hurricane Season FEMA After-Action Report. In July 2018,

FEMA released its 2017 Hurricane Season FEMA After-Action Report,

which contained four broad recommendations for improving the IHP,

Unit nonresponse is the failure of a member of the sample to respond to the survey as a

whole. Nonresponse bias may be defined as systematic error in estimates (e.g., customer

satisfaction rates) that are attributable to systematic differences between the responses of

those who do respond and the responses that would have been obtained from

nonrespondents had they responded.

FEMA Has Numerous

Efforts to Improve the IHP

but Did Not Complete Key

Process Improvement

Activities

FEMA Has Planned or

Implemented Numerous Efforts

to Improve Assistance to

Disaster Survivors, Including a

Redesign of the Individual

Assistance Program

Page 70 GAO-20-503 Disaster Assistance

including direct housing assistance and coordination with state and local

governments. As of May 2020, FEMA has implemented two of these

recommendations, according to officials.

Individual Assistance Program Redesign. In March 2019, the

Recovery Directorate established a cross-functional project team to

develop a vision and implementation strategy for the holistic delivery of

disaster assistance to individuals and households through Individual

Assistance Programs, including the IHP.

Annual Customer Experience Action Plan for the Individual

Assistance Program. In June 2019, FEMA released its Annual

Customer Experience Action Plan for the program that described eight

separate efforts to improve customer service, including plans to develop

new surveys and test program design changes for the IHP.

Disaster Recovery Reform Act of 2018. In addition to the efforts

initiated by FEMA, the Disaster Recovery Reform Act of 2018 includes

seven provisions related to the IHP that FEMA is required to implement.

As of May 2020, FEMA has implemented five of these provisions.

Following the 2017 disaster season, FEMA initiated an effort to redesign

the Individual Assistance Program, including the IHP. However, the

agency did not fully assess customer and stakeholder needs and

performance gaps in the program, or set improvement goals and priorities

for the effort—activities that are critical to the success of a process

improvement effort, according to GAO’s Business Process Reengineering

Assessment Guide.

FEMA officials told us that the agency typically

receives significant amounts of criticism following any implementation of

the program and, in response, the agency or Congress tweaks or

changes parts of the program. Officials explained that these changes may

further complicate the agency’s implementation of the Individual

Assistance Program and, rather than continuing to take a piecemeal

approach to improving the program, FEMA decided to undertake a holistic

effort to assess the program’s vision and identify ways to improve the

delivery of disaster assistance through the program.

GAO, Business Process Reengineering Assessment Guide, Version 3,

GAO/AIMD-10.1.15 (Washington, D.C.: May 1997). Business process reengineering

focuses on redesigning a process as a whole in order to achieve the greatest possible

benefits to the organization and its customers.

FEMA’s Redesign Effort Is

Leadership

-Driven, but FEMA

Did Not Fully Assess

Stakeholder Needs and

Performance Gaps, or Set

Improvement Goals and

Priorities

Page 71 GAO-20-503 Disaster Assistance

We assessed FEMA’s early efforts to redesign the Individual Assistance

Program against GAO’s Business Process Reengineering Assessment

Guide, which identifies key practices for process improvement and

provides a general framework for assessing a reengineering or redesign

effort, from initial strategic planning and goal-setting to

postimplementation assessments.

We found that FEMA has

implemented numerous activities that are critical to the success of a

process improvement effort, according to the guide. Specifically, FEMA

demonstrated executive leadership’s commitment to the effort; engaged

stakeholders and subject matter experts to collect and analyze their

expectations for the delivery of disaster assistance through the Individual

Assistance Program; reassessed its vision and developed new

fundamentals, or principles, for the program; and developed success

criteria—a set of yes or no questions—to ensure that the redesigned

program adheres to the new fundamentals or principles. However, we

identified additional actions FEMA could take to help ensure that its

improvement effort is sound and positioned for success.

Engage with customers and stakeholders to better understand their

needs. FEMA officials said the agency conducted outreach with about 10

NPSC staff during the stakeholder outreach phase to obtain their

perspectives on the Individual Assistance Program, including the IHP.

Officials explained that they requested to meet with NPSC staff who had

previously experienced a disaster, as it is relatively common for these

staff to be disaster survivors themselves. However, FEMA did not engage

with any survivors external to the agency or NGOs that assist survivors

and only engaged with one external stakeholder – a local official from a

city in Florida that was impacted by Hurricane Michael. Officials stated

that they would prioritize external engagement after identifying and

refining ideas for providing assistance. However, according to GAO’s

Business Process Reengineering Assessment Guide, a comprehensive

understanding of customers’ and stakeholders’ needs and expectations is

a key input for improving the type, cost, quality, and timeliness of the

products and services the agency provides. Further, reassessing

customer and stakeholder needs helps agencies reevaluate and clarify its

strategic vision and goals and provides direction and focus for an

agency’s efforts to improve its performance.

GAO/AIMD-10.1.15.

Page 72 GAO-20-503 Disaster Assistance

Assess current processes to identify performance gaps, and

develop improvement goals focused on outcomes important to

customers and stakeholders. FEMA did not assess the major or core

processes in the current program to identify any performance gaps for the

improvement effort. FEMA officials said they selectively scrutinized

certain issues voiced during their engagement with internal stakeholders.

For example, in response to internal stakeholders’ concern about FEMA

providing IHP assistance for repetitive loss, officials said they assessed

10 years of program data to determine the percentage of applicants who

received home repair assistance multiple times. Officials also conducted

an environmental scan of federal disaster assistance programs, and

analyzed the strengths, weaknesses, opportunities, and threats of

different ways that the federal government provides disaster assistance,

for example, reimbursement, grants to individuals, grants to states, and

loans. Officials explained that they conducted the environmental scan to

identify authorities that federal agencies have to provide assistance that

FEMA may not be using, not to assess the performance of the Individual

Assistance Program, including the IHP. According to GAO’s Business

Process Reengineering Assessment Guide, leading organizations

recognize that process improvement efforts should be informed by fact-

based performance analysis. These organizations typically assess which

of their major or core processes are in greatest need of improvement. By

analyzing the gap between where they are and where they need to be to

achieve its mission and satisfy customer and stakeholder requirements,

agencies can target those processes that are in most need of

improvement, and then set achievable and measurable improvement

goals. These improvement goals should be sharply focused on outcomes

linked to the agency’s defined mission, as well as outcomes important to

customers and stakeholders, according to the guide.

Select and prioritize processes for improvement. As of May 2020, the

Individual Assistance Division was continuing to define and refine the new

vision and fundamental concepts for the redesigned Individual Assistance

Program. The project lead for the improvement effort told us that the

project team was assessing how FEMA would implement the new vision

and fundamental concepts, including any legislative, regulatory, and

organizational barriers. As part of that assessment, the project team

identified actions FEMA could take in the near term to implement the new

vision and fundamental concepts that do not require legislative changes,

according to the project lead. However, FEMA officials have not explicitly

GAO/AIMD-10.1.15.

Page 73 GAO-20-503 Disaster Assistance

identified and prioritized processes that need to be improved based on

formal selection criteria. According to GAO’s Business Process

Reengineering Assessment Guide, the agency should list processes that

are candidates for improvement and then decide which processes should

have the highest priority for agency action, based on formal selection

criteria, which might emphasize processes with the strongest link to the

agency’s mission or the highest impact on customers.

FEMA officials explained that the intent of the redesign effort was to

develop a new vision for the Individual Assistance Program and

conceptualize ideas that may lead to program changes, and not to identify

and scrutinize all the gaps or challenges with the current processes.

Officials added that identifying performance gaps does not lend itself to

identifying novel ways to provide assistance. However, by (1) obtaining a

more comprehensive understanding of customer and stakeholder needs

through additional engagement; (2) assessing current gaps in

performance, and developing improvement goals to address any

identified gaps; and (3) prioritizing processes for improvement based on

documented selection criteria, FEMA will be able to further refine its new

vision and fundamentals for the Individual Assistance Program, and more

effectively direct and focus the agency’s implementation efforts.

FEMA has taken steps to integrate its efforts to improve the IHP;

however, the agency has not established time frames for finalizing its

strategic plan or developing implementation plans for the efforts

described in its strategic plan. As previously stated, in addition to its effort

to redesign the Individual Assistance Program, FEMA has many other

ongoing and planned IHP improvement efforts. Some of these other

efforts seem to be directly relevant to the redesign effort. For example, as

part of its Annual Customer Experience Action Plan for the Individual

Assistance Program, FEMA plans to develop a customer journey map of

the recovery process to identify additional touchpoints where customer

experience data can be used to inform changes to FEMA’s Individual

Assistance Programs, including the IHP. As another example, as part of

the Housing Assistance Initiative, FEMA is implementing an initiative to

modernize, enhance, and diversify how the agency gathers applicant data

and assesses damages for the IHP.

In September 2019, the Deputy Assistant Administrator for FEMA’s

Recovery Directorate directed the Individual Assistance Division to

GAO/AIMD-10.1.15.

FEMA Has Taken Steps to

Integrate IHP Improvement

Efforts, but

Has Not

Established Time Frames for

Finalizing its Implementation

Plans

Page 74 GAO-20-503 Disaster Assistance

establish an Office of Strategy and Innovation. The division began piloting

the office in January 2020. The office has two sections—Strategy and

Innovation—and will provide the division with services and resources to

advance organizational, programmatic, service-delivery, and customer-

experience goals, including efforts to revision, modernize, and

strategically resource the Individual Assistance Program. The primary

functions of the Strategy Section include, among other things,

coordinating strategic planning for the division and conducting

stakeholder engagement activities, such as focus groups, to inform the

division’s priorities. The primary functions of the Innovation Section

include, among other things, leading the development of proposals,

alternative solutions, and business cases to inform the division’s priorities

and investments, and developing pilots and implementation plans.

According to FEMA officials, the Office of Strategy and Innovation led the

development of a Strategic Plan for the Individual Assistance Division

during 2019 and 2020. The plan describes the division’s three strategic

goals and 10 strategic objectives. The plan also describes the various

efforts related to each of the division’s strategic objectives, including

efforts to redesign the Individual Assistance Program, develop a customer

journey map, and modernize IHP damage assessments. According to the

strategic plan, the Individual Assistance Division will use the plan to guide

annual priorities, resource allocations, and performance measurements,

and develop individual implementation plans and direct resources and

funding to guide and support its strategic goals and objectives.

According to FEMA officials, as of July 2020, the strategic plan was not

finalized and FEMA had not established time frames for finalizing the

plan. Further, the draft strategic plan does not include time frames for

developing implementation plans for the efforts described in the plan.

According to GAO’s Business Process Reengineering Assessment

Guide, agencies should have an overall improvement strategy that

provides a means to coordinate and integrate the various improvement

projects, set priorities, and make appropriate budget decisions. The

strategy should include a discussion of what improvement projects are

necessary; how they are interrelated; the order in which they will be

pursued; and their goals, time frames, resource requirements, and key

participants.

The project lead for the redesigned Individual Assistance

Program agreed that the redesign effort should be synchronized with

GAO/AIMD-10.1.15.

Page 75 GAO-20-503 Disaster Assistance

other FEMA IHP improvement efforts. In addition, leading practices for

program management indicate that project schedules should be

developed to define project milestones and identify and sequence

activities in order to determine start and end dates for each activity.

Establishing time frames for finalizing its draft strategic plan and

developing implementation plans that integrate its IHP improvement

efforts will put FEMA in a better position to coordinate and manage its

limited resources more effectively.

FEMA’s IHP provided over $11 billion to about 3 million disaster survivors

from 2010 through 2019. However, IHP applicants are confused by

FEMA’s requirement that certain applicants must apply for an SBA

disaster loan to be considered for SBA-dependent ONA, and the lack of

clarity related to the process may disproportionately impact low-income

survivors who are less likely to qualify for an SBA loan. Improving how the

requirement is communicated to survivors, assessing the extent to which

the process limits or prevents survivors’ access to IHP assistance, and

working with SBA to identify options to simplify the disaster assistance

application process would help ensure that survivors receive all of the IHP

assistance for which they are eligible. Similarly, FEMA’s IHP award

determination letters often confuse survivors and provide limited

information. Improving the clarity and readability of these letters and

providing additional information regarding determination decisions would

help ensure that survivors understand the reasons for FEMA’s decisions.

FEMA has also experienced challenges in managing the IHP workforce.

For instance, FEMA did not track changes made to SOPs from 2016

through 2018 and call center staff faced challenges with their awareness

of changes to the guidance. Identifying ways to improve the accessibility

and usability of information about guidance changes for NPSC staff would

help ensure that FEMA provides quality information to those delivering

direct service to survivors. Also, by including a focus on morale,

performance feedback, career development, communication, and

attention to work-life balance while implementing planned employee

engagement activities and, further, when assessing employee satisfaction

scores, and implementing additional steps to strengthen employee

engagement, FEMA will be better able to ensure NPSC management and

supervisor attention on employee morale. In addition, assessing the

effectiveness of IHP training and support provided to NSPC staff during

Project Management Institute, Inc., The Standard for Program Management, Fourth

Edition, 2017.

Conclusions

Page 76 GAO-20-503 Disaster Assistance

surge events would help ensure that FEMA addresses training concerns

and provides effective support to survivors. Further, identifying and

implementing strategies to ensure that staff at DRCs have the needed

skills and capabilities would help to provide consistent service to

survivors.

State and local officials stated that FEMA did not provide sufficient

training, support, or guidance regarding the IHP. Identifying and

implementing strategies to provide readily accessible information and

resources about the IHP would help FEMA ensure that local officials

understand the program better. Local officials also experienced

challenges in coordinating with FEMA on direct housing assistance,

particularly on the delivery of Transportable Temporary Housing Units,

which resulted in delays to survivors being able to move in. Identifying

and implementing best practices for information sharing and coordinating

among local officials and other recovery partners would help ensure that

FEMA can optimize the delivery of direct housing units to disaster

survivors.

FEMA assesses IHP performance and has ongoing efforts to improve the

program, but these efforts are lacking in various respects. Specifically,

FEMA collects and analyzes data to assess IHP performance and

survivor experiences, but correcting and refining FEMA’s methodology to

fully align with federal standards would help ensure that the survey results

are valid. Also, FEMA has not completed key process improvement

activities for its efforts to improve the IHP, including engaging with

additional program customers and stakeholders to obtain a more

comprehensive understanding of their requirements, and assessing

performance gaps between current processes and customer and

stakeholder needs. Finally, though FEMA drafted a strategic plan for the

Individual Assistance Division, FEMA did not set time frames for finalizing

the strategic plan or developing implementation plans for the efforts

described in the plan. Establishing time frames for finalizing the strategic

plan and developing implementation plans that integrate all current and

planned initiatives and recommendations related to the IHP would help

ensure the success of current and future FEMA efforts to improve the

IHP.

We are making the following 14 recommendations to FEMA:

The FEMA Administrator should improve the completeness and

consistency of its communication of the requirement to apply for an SBA

Recommendations for

Executive Action

Page 77 GAO-20-503 Disaster Assistance

disaster loan prior to being considered for SBA-dependent other needs

assistance. (Recommendation 1)

The FEMA Administrator should assess the extent to which its process for

determining an applicant’s eligibility for SBA-dependent other needs

assistance limits or prevents survivors’ access to IHP assistance, and

work with SBA to identify options to simplify and streamline the disaster

assistance application process for survivors. (Recommendation 2)

The FEMA Administrator should improve the IHP award determination

letters by using federal guidance and best practices for communicating

with the public to ensure that applicants understand that an “ineligible”

determination does not mean they cannot continue to pursue assistance.

(Recommendation 3)

The FEMA Administrator should identify and implement strategies to

provide additional information to applicants about how FEMA determined

their eligibility for assistance and the amount of assistance to award.

(Recommendation 4)

The FEMA Administrator should evaluate the method for communicating

changes in IHP standard operating procedures (SOP) to identify ways to

improve their accessibility and usability by National Processing Service

Center (NPSC) staff. (Recommendation 5)

The FEMA Administrator should use desirable characteristics of

employee engagement—including performance feedback, career

development, communication, and attention to work-life balance—while

completing planned activities for improving morale among call center

staff. (Recommendation 6)

The FEMA Administrator should use desirable characteristics of

employee engagement—including performance feedback, career

development, communication, and attention to work-life balance—when

assessing NPSC staff satisfaction scores and identifying additional steps

to strengthen employee morale. (Recommendation 7)

The FEMA Administrator should assess the effectiveness of the IHP

training and support for NPSC staff during surge events and implement

any necessary changes. (Recommendation 8)

The FEMA Administrator should identify and implement strategies to help

ensure staff deployed to Disaster Recovery Centers (DRC) have the

Page 78 GAO-20-503 Disaster Assistance

needed skills and capabilities to provide support and consistent service to

survivors. (Recommendation 9)

The FEMA Administrator should identify and implement strategies to

provide readily accessible information and resources, such as guidance

and training, about the Individuals and Households Program to state,

local, tribal, and territorial officials. (Recommendation 10)

The FEMA Administrator should identify and implement best practices for

information sharing and coordinating with local officials, and other

recovery partners, on the delivery of Transportable Temporary Housing

Units in the interim while FEMA completes system improvements.

(Recommendation 11)

The FEMA Administrator should correct and refine the methodology used

to survey survivor experiences with the IHP by (1) weighting the survey

data to reflect the stratification of its survey design, (2) adjusting the base

sampling weights for survey nonresponse within each stratum, and (3)

calculating the sampling error for the survey data after adjusting the base

sampling weights for nonresponse. (Recommendation 12)

The FEMA Administrator should complete the following key process

improvement activities as part of its effort to redesign the Individual

Assistance Program: (1) engage with additional program customers and

stakeholders to obtain a more comprehensive understanding of their

needs; (2) assess performance gaps between current processes and

customer and stakeholder needs, and develop measurable and

achievable improvement goals to address any identified performance

gaps; and (3) prioritize the processes that need improvement based on

documented selection criteria. (Recommendation 13)

The FEMA Administrator should establish time frames for finalizing the

Individual Assistance Division’s draft strategic plan and developing

implementation plans that integrate its IHP improvement efforts.

(Recommendation 14)

We provided a draft of this report to the Department of Homeland Security

(DHS) and FEMA for their review and comment. DHS provided written

comments, which are reproduced in appendix VII. In its comments, DHS

concurred with our recommendations and described actions under way or

planned to address them. FEMA provided technical comments, which we

incorporated as appropriate.

Agency Comments

and Our Evaluation

Page 79 GAO-20-503 Disaster Assistance

With regard to our first recommendation, that FEMA improve the

completeness and consistency of its communication of the requirement to

apply for an SBA disaster loan prior to being considered for SBA-

dependent ONA, DHS stated that FEMA will review the SBA referral

information within the IHP award letters during the upcoming 2020-2021

letter review process to ensure letters provide a comprehensive and clear

explanation of the requirement that applicants must complete the SBA

loan process before FEMA will consider their eligibility for SBA-dependent

ONA. FEMA will also review its public messaging about SBA-dependent

ONA to ensure consistency across communication modes so that

survivors clearly understand the necessity of applying for an SBA loan.

DHS estimated that these efforts would be completed by April 29, 2022.

These actions, if fully implemented, should address the intent of our

recommendation.

With regard to our second recommendation, that FEMA assess the extent

to which its process for determining an applicant’s eligibility for SBA-

dependent ONA limits or prevents survivors’ access to IHP assistance,

and work with SBA to identify options to simplify and streamline the

disaster assistance application process for survivors, DHS reiterated

FEMA’s action described in this report to initiate a workgroup with the

SBA to review the process for determining which applicants are required

to submit an SBA application prior to being evaluated for SBA-dependent

ONA. DHS stated that main focus of the effort is to assess the process for

verifying information provided by applicants prior to making assistance

decisions as well as to consider options for streamlining and simplifying

coordination between FEMA and SBA. DHS reported that FEMA

anticipates providing recommendations to agency leadership at both

agencies by December 2020, and that both agencies will decide on which

recommendations to implement by December 2021. DHS noted that

some recommendations may require significant technology changes that

may take three to five years to implement. Our report identified multiple

challenges survivors experienced with FEMA’s current process for

determining an applicant’s eligibility for SBA-dependent ONA, including

that the process is burdensome and may have prevented many

applicants from being considered for SBA-dependent ONA. As such, it

will be important for FEMA to identify and consider options for improving

its processes that specifically address the challenges described in this

report. We will monitor FEMA’s efforts in this area to assess the extent to

which they fully implement our recommendation.

With regard to our third recommendation, that FEMA improve the IHP

award determination letters by using federal guidance and best practices

Page 80 GAO-20-503 Disaster Assistance

for communicating with the public to ensure that applicants understand

that an “ineligible” determination does not mean they cannot continue to

pursue assistance, DHS stated that FEMA will include a review of the

appeal language and information in the determination letter as part of the

2020-2021 letter review process. As we noted in our report, survivors

have trouble understanding the letters and how to respond, and may stop

pursuing assistance after receiving a FEMA determination letter because

they believe the letter represents a final denial. For this reason, it is

critical that FEMA ensure that survivors clearly understand that a

determination letter does not represent a final decision. DHS estimated

that FEMA’s effort to implement our recommendation will be completed

by April 29, 2022. At that time, we will assess the agency’s actions to

determine the extent to which they address the intent of our

recommendation.

With regard to our fourth recommendation, that FEMA identify and

implement strategies to provide additional information to applicants about

how FEMA determined their eligibility for assistance and the amount of

assistance to award, DHS stated that FEMA will include a review all the

IHP award letters as part of the 2020-2021 letter review process to

ensure the use of plain language and a description of how FEMA makes

eligibility decisions. As noted in our report, survivors experienced

challenges in understanding FEMA’s eligibility and award determinations

and FEMA’s current award determination letter does not include important

information, such as the amount of damages verified during the site

inspection, that the agency factors into its award decisions. We also

described multiple benefits of providing survivors with more information

about their case and FEMA’s eligibility and award determinations,

including increased trust and transparency and an improved survivor

experience. For these reasons, it is important that FEMA not only ensure

a description of how the agency makes award and eligibility decisions, but

also consider ways to provide applicants with more information about

their case. DHS estimated that FEMA’s effort to implement our

recommendation will be completed by April 29, 2022. At that time, we will

assess the agency’s actions to determine the extent to which they

address the intent of our recommendation.

With regard to our fifth recommendation, that FEMA evaluate the method

for communicating changes in IHP standard operating procedures (SOP)

to identify ways to improve their accessibility and usability by National

Processing Service Center (NPSC) staff, DHS stated that on May 21,

2019 FEMA updated its internal processing procedures manual website,

which provides IHP guidance for field and call center staff, to clearly

Page 81 GAO-20-503 Disaster Assistance

display all guidance topics on one page so that staff may quickly identify

the guidance needed to assist disaster survivors. Also, FEMA plans to

award a contract to improve the searchability of its internal processing

procedures manual and update the user interface by September 30,

2020. The improvements are focused on developing a document tagging

taxonomy framework and enabling staff to search for appropriate

guidance by specific disaster and their user role. DHS estimated that

FEMA’s effort to implement our recommendation will be completed by

December 31, 2021. These actions, if fully implemented, should address

the intent of the recommendation.

With regard to our sixth recommendation, that FEMA use desirable

characteristics of employee engagement—including performance

feedback, career development, communication, and attention to work-life

balance—while completing planned activities for improving morale among

call center staff, DHS stated that FEMA has developed a strategic

communication plan that will be a resource to build call center

management in support for four major elements: (1) enhancing

communication, (2) fostering unity, (3) awards and recognition, and (4)

training and development. FEMA also has an employee advisory

committee over the call center staff, whose mission is to facilitate a

culture of teamwork and communication by providing actionable feedback

between employees and management. FEMA is also completing the

development of a Leadership Academy to train all call center supervisors.

In addition to these efforts, our report noted further employee recognition

awards, a pilot effort to increase communication between supervisors and

staff, and new staff hires to provide coaching to call center staff. Our

report found low morale in the call center workforce, which provides an

important customer service function. For this reason, it is important that

FEMA not only complete supervisor training through their new Leadership

Academy, but continue to implement and complete the other efforts we

describe to improve employee engagement. DHS estimated that FEMA’s

effort to implement our recommendation will be completed by December

31, 2021. At that time, we will assess the agency’s actions to determine

the extent to which they address the intent of our recommendation.

With regard to our seventh recommendation, that FEMA use desirable

characteristics of employee engagement—including performance

feedback, career development, communication, and attention to work-life

balance—when assessing NPSC staff satisfaction scores and identifying

additional steps to strengthen employee morale, DHS stated that FEMA’s

NPSC call center employee advisory committee continues to make

recommendations to enhance the organization’s morale, and FEMA is

Page 82 GAO-20-503 Disaster Assistance

taking steps to provide additional training opportunities and increase

communication. This includes a focus group initiative FEMA began in May

2020 with a goal to provide leadership with actionable data and

information from employees. FEMA plans that the next series of focus

groups will be centered on topics which scored lowest in the staff

satisfaction survey, and will result in recommendations to leadership for

improvement. DHS estimated that FEMA’s efforts to implement our

recommendation will be completed by May 31, 2021. These actions, if

fully implemented, should address the intent of our recommendation.

With regard to our eighth recommendation, that FEMA assess the

effectiveness of the IHP training and support for NPSC staff during surge

events and implement any necessary changes, DHS stated that FEMA is

currently in the process of evaluating ways to assess effectiveness of

training during surge in response to a disaster. FEMA is considering

conducting pre- and post-assessments of training and whether to conduct

a post training survey at the conclusion of trainings. DHS estimated that

FEMA’s effort to implement our recommendation will be completed by

July 30, 2021. At that time, we will assess the agency’s actions to

determine the extent to which they address the intent of our

recommendation.

With regard to our ninth recommendation, that FEMA identify and

implement strategies to help ensure staff deployed to Disaster Recovery

Centers (DRC) have the needed skills and capabilities to provide support

and consistent service to survivors, DHS stated that FEMA is in the

process of completing revisions to the IHP training program provided to

staff deployed to DRCs. These trainings expand upon the services

provided to survivors who visit a DRC, including coaching as part of their

qualification process, and include an updated just-in-time refresher

training for all staff assigned to DRCs. FEMA is also in the process of

developing formal courses for the DRC manager and the IHP Housing

Crew Lead, who work in the DRC as the supervisor and subject matter

expert, respectively. DHS estimated that FEMA’s efforts to implement our

recommendation will be completed by December 31, 2021. These

actions, if fully implemented, should address the intent of our

recommendation.

With regard to our tenth recommendation, that FEMA identify and

implement strategies to provide readily accessible information and

resources, such as guidance and training, about the Individuals and

Households Program to state, local, tribal, and territorial officials, DHS

described recent efforts to improve or provide guidance on disaster

Page 83 GAO-20-503 Disaster Assistance

housing to its state, local, territory and tribal partners. Specifically, DHS

stated that FEMA (1) improved the consistency of disaster housing

messaging in the Comprehensive Preparedness Guide, which includes

guidance on national housing priorities, types of housing, key

considerations and housing-specific planning recommendations that

jurisdictions can apply when developing or improving housing plans; (2)

delivered a presentation on FEMA housing assistance to the 2019 grant

recipients of the Regional Catastrophic Preparedness Grant Program,

which aims to build state and local capacity to manage catastrophic

incidents by improving and expanding regional collaboration for

catastrophic incident preparedness; and (3) issued the State-

Administered Direct Housing Grant Guide, which describes, among other

things, the processes and requirements for its program for providing

grants to state, territory, or tribal governments to administer direct

temporary housing assistance or permanent housing construction.

DHS also reiterated some of FEMA’s publically-available guidance on

Individual Assistance programs, including the IHP, which we described in

this report. For example, FEMA’s Individual Assistance Program and

Policy Guide serves as a single resource of all Individual Assistance

policies and describes (1) specific programs and assistance available; (2)

information on which forms of assistance are automatically activated in a

Presidential disaster declaration; and (3) information on which forms of

assistance must be requested. The guide includes a chapter on the IHP

which details, among other things, program eligibility and specific

documents applicants may be required to provide to FEMA to receive

assistance. DHS noted that the guide is available to all FEMA partners,

including state, local, tribal, and territorial officials on FEMA’s website.

According to DHS, FEMA plans to publish an updated Individual

Assistance Program and Policy Guide that incorporates policy changes

authorized by the Disaster Recovery Reform Act of 2018 on June 30,

2021.

As we noted in this report, local officials experienced challenges

understanding the IHP and expressed a need for additional support to

improve their ability to effectively assist disaster survivors and manage

recovery efforts in their communities. The local officials we met with

experienced these challenges despite the existence of publically-available

guidance on the IHP, such as the Individuals and Households Program

Unified Guidance, which FEMA first published in 2016 and preceded the

Individual Assistance Program and Policy Guide. While FEMA’s recent

and planned efforts described above may result in improved or additional

sources of information about the IHP, to fully address our

Page 84 GAO-20-503 Disaster Assistance

recommendation, FEMA should identify and implement strategies to

provide information on the IHP that local officials need to manage a

successful recovery. We will continue to monitor FEMA’s efforts in this

area to assess the extent to which they fully address the intent of our

recommendation.

With regard to our eleventh recommendation, that FEMA identify and

implement best practices for information sharing and coordinating with

local officials, and other recovery partners, on the delivery of

Transportable Temporary Housing Units in the interim while FEMA

completes system improvements, DHS noted that FEMA’s Direct Housing

Guide includes guidance on coordinating with local officials and other

recovery partners on the delivery of Transportable Temporary Housing

Units. DHS also stated that FEMA will establish working groups with

relevant stakeholders to identify best practices and lessons learned on

information sharing and coordination with local officials in the delivery of

Transportable Temporary Housing Units. These working groups will

incorporate identified best practices and lessons learned into FEMA’s

Direct Housing Guide. DHS estimated that these efforts would be

completed by June 30, 2021. These actions, if fully implemented, should

address the intent of our recommendation.

With regard to our twelfth recommendation, that FEMA correct and refine

the methodology used to survey survivor experiences with the IHP by (1)

weighting the survey data to reflect the stratification of its survey design,

(2) adjusting the base sampling weights for survey nonresponse within

each stratum, and (3) calculating the sampling error for the survey data

after adjusting the base sampling weights for nonresponse, DHS stated

that FEMA will weight the survey data to reflect the stratification of the

survey design. FEMA will also identify which variables are most relevant

to nonresponse for each of the IHP surveys, and conduct research on

calculating sampling error for weighted data to better understand the level

of resources required to complete these calculations on a quarterly basis.

Then, FEMA will decide whether it is necessary or reasonable to adjust

the base sampling weights for survey nonresponse within each stratum,

and calculate the sampling error for the survey data after adjusting the

base sampling weights for nonresponse. DHS estimated that these efforts

would be completed by December 31, 2022. We continue to believe that

FEMA will be limited in its ability to use IHP survey results as accurate,

analytical evidence of applicant’s experiences with the program and to

assess program performance without fully implementing all parts of our

recommendation.

Page 85 GAO-20-503 Disaster Assistance

With regard to our thirteenth recommendation, that FEMA complete the

following key process improvement activities as part of its effort to

redesign the Individual Assistance Program: (1) engage with additional

program customers and stakeholders to obtain a more comprehensive

understanding of their needs; (2) assess performance gaps between

current processes and customer and stakeholder needs, and develop

measurable and achievable improvement goals to address any identified

performance gaps; and (3) prioritize the processes that need

improvement based on documented selection criteria, DHS stated that

FEMA will complete these key process improvement activities for its

redesign effort by December 31, 2021. At that time, we will assess the

agency’s actions to determine the extent to which they address the intent

of our recommendation.

With regard to our fourteenth recommendation, that FEMA establish time

frames for finalizing the Individual Assistance Division’s draft strategic

plan and developing implementation plans that integrate its IHP

improvement efforts, DHS stated that FEMA finalized and published the

Individual Assistance 2020-2024 Strategic Plan on August 21, 2020 and

established milestones for creating implementation plans for each goal

and objective of the plan. According to FEMA’s milestones, the agency

plans to create all implementation plans by December 29, 2023. These

actions should address the intent of our recommendation.

We are sending copies of this report to the Secretary of Homeland

Security, the FEMA Administrator, and the appropriate congressional

committees. If you or your staff have any questions about this report,

please contact me at (404) 679-1875 or [email protected]v. Contact points

for our Offices of Congressional Relations and Public Affairs may be

found on the last page of this report. Key contributors to this report are

listed in appendix VIII. In addition, the report will be available at no charge

on the GAO website at http://www.gao.gov.

Chris P. Currie

Director, Homeland Security and Justice

Page 86 GAO-20-503 Disaster Assistance

List of Requesters

The Honorable Michael B. Enzi

Chairman

Committee on the Budget

United States Senate

The Honorable Ron Johnson

Chairman

The Honorable Gary C. Peters

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Rand Paul, M.D.

Chairman

Subcommittee on Federal Spending Oversight

and Emergency Management

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Marco Rubio

Chairman

Committee on Small Business and Entrepreneurship

United States Senate

The Honorable Maxine Waters

Chairwoman

Committee on Financial Services

House of Representatives

The Honorable Bennie G. Thompson

Chairman

Committee on Homeland Security

House of Representatives

The Honorable Carolyn B. Maloney

Chairwoman

The Honorable James Comer

Ranking Member

Committee on Oversight and Reform

House of Representative

Page 87 GAO-20-503 Disaster Assistance

The Honorable Nydia Velázquez

Chairwoman

Committee on Small Business

House of Representatives

The Honorable Peter DeFazio

Chairman

The Honorable Samuel “Sam” Graves

Ranking Member

Committee on Transportation and Infrastructure

House of Representatives

The Honorable Al Green

Chairman

Subcommittee on Oversight and Investigations

Committee on Financial Services

House of Representatives

The Honorable Emanuel Cleaver II

House of Representatives

The Honorable Jim Jordan

House of Representatives

The Honorable Michael McCaul

House of Representatives

The Honorable Gary Palmer

House of Representatives

The Honorable Ann Wagner

House of Representatives

Appendix I: Objectives, Scope, and

Methodology

Page 88 GAO-20-503 Disaster Assistance

This report addresses (1) expenditures from 2010 through 2019 for the

Individuals and Households Program (IHP) and the processes that the

Federal Emergency Management Agency (FEMA) used to deliver IHP

assistance to disaster survivors; (2) program experiences and outcomes,

and challenges survivors faced in obtaining assistance from 2016 through

2018; (3) challenges FEMA experienced with implementing the IHP from

2016 through 2018; and (4) the extent to which FEMA has assessed the

IHP and initiated efforts to improve the program in recent years.

To address our first objective, we analyzed IHP expenditures from

FEMA’s Integrated Financial Management Information System, and

application, eligibility, award, and appeals data from the National

Emergency Management Information System for major declarations that

included Individual Assistance during calendar years 2010 through 2019.

We reported on the most recent 10-year time frame for this objective

because we wanted to focus on long-term trends. Regarding direct

housing expenditures, FEMA could not precisely account for a certain

subset of expenditures and, therefore, provided expenditures to us that

excluded this subset of expenditures. Consequently, we state in this

report that direct housing expenditures are at least a certain amount. We

assessed the reliability of data from these two systems by reviewing

existing information about these systems, interviewing data users and

managers responsible for these data from FEMA’s Office of the Chief

Financial Officer and Recovery Analytics Division, and cross-checking

data across disparate sources to ensure consistency. Based on these

steps, we determined these data to be sufficiently reliable for the

purposes of analyzing IHP expenditures and selected data from 2010

through 2019. We also interviewed officials from FEMA’s Individual

Assistance Division and IHP Service Delivery Branch and reviewed

relevant laws, including the Robert T. Stafford Disaster Relief and

Emergency Assistance Act

and FEMA IHP program guidance, including

the March 2019 Individual Assistance Program and Policy Guide,

understand FEMA’s policies and processes for providing assistance

through the IHP, including how disaster survivors apply for IHP

The Integrated Financial Management Information System is FEMA’s official accounting

and financial system that tracks all of the agency’s financial transactions. The National

Emergency Management Information System is a database system used to track disaster

data for FEMA and grantees.

42 U.S.C. § 5121 et seq.

Federal Emergency Management Agency, Individual Assistance Program and Policy

Guide (IAPPG), FP 104-009-03 (Washington, D.C.: March 4, 2019).

Appendix I: Objectives, Scope, and

Methodology

Appendix I: Objectives, Scope, and

Methodology

Page 89 GAO-20-503 Disaster Assistance

assistance and how FEMA determines applicants’ eligibility for assistance

and the type and amount of assistance to provide.

To address our second objective, we analyzed FEMA’s IHP applicant

data from the National Emergency Management Information System for

all 5.6 million disaster survivors who applied for assistance for major

disaster declarations that included Individual Assistance during 2016

through 2018—the 3 most recent years for which complete application

data were available.

FEMA provided these data, as of February 24,

2020, from its National Emergency Management Information System. We

analyzed FEMA’s IHP applicant data to identify and compare various

outcomes, such as approval, award, and appeal rates, overall and across

different survivor groups, for 2016 through 2018. We assessed the

reliability of FEMA’s IHP applicant data by reviewing existing information

about the National Emergency Management Information System,

including internal controls; interviewing data users and managers

responsible for these data from FEMA’s Recovery Analytics Division; and

testing the data for missing data, outliers, and obvious errors. Based on

these steps, we determined these data to be sufficiently reliable for the

purposes of reporting IHP outcomes from 2016 through 2018.

We also conducted semistructured interviews with state emergency

management officials, local officials responsible for leading disaster

recovery efforts, and officials from nongovernmental organizations (NGO)

that help disaster survivors access and navigate the IHP from California,

Florida, North Carolina, Texas, and Puerto Rico. We selected these four

states and Puerto Rico because they represented multiple FEMA Regions

and had a significant number of Individual Assistance disaster

declarations, higher levels of IHP expenditures, or higher numbers of

Generally, survivors have 60 days from the date of an Individual Assistance disaster

declaration to apply for IHP assistance. FEMA may extend the application period when the

state, territorial, or tribal government requests more time to collect applications from the

affected population. After the end of the application period, FEMA will accept late

applications for an additional 60 days. 44 C.F.R. § 206.112. Disaster survivors must write

a letter to FEMA with the details of the extenuating circumstances that prevented them

from applying for assistance in a timely manner with accompanying documentation, if

applicable. FEMA will not allow applicants to complete an application after that 60-day

grace period. The latest Individual Assistance disaster declaration for which we analyzed

data was disaster number 4407, which occurred on November 12, 2018. The last day for

survivors of this disaster to apply for IHP assistance was February 15, 2019. IHP

assistance is limited to 18 months following the date of the disaster declaration. FEMA

may extend the period of assistance due to extraordinary circumstances, if such an

extension is in the public interest.

Appendix I: Objectives, Scope, and

Methodology

Page 90 GAO-20-503 Disaster Assistance

valid applications for the IHP from 2016 through 2018. For our interviews

with local officials responsible for disaster recovery efforts, we selected

two counties in each state and two municipalities in Puerto Rico that had

higher numbers of valid IHP applications.

For our interviews with NGO

officials, we selected one or two NGOs in each of our selected states and

Puerto Rico, which we identified through discussions with FEMA, state,

and local officials, and officials from other NGOs.

Further, we interviewed

officials responsible for implementing the IHP from FEMA’s headquarters

and all four National Processing Service Centers (NPSC), as well as

FEMA’s Regions II, IV, VI, and IX, which are the Regions responsible for

liaising with and supporting our four selected states and Puerto Rico. At

each NPSC, we interviewed eight to 11 staff, selected by FEMA, who

communicate with disaster survivors and process their applications to

obtain information about survivor experiences and challenges with the

IHP. In total, we interviewed 38 of these staff using the same set of

questions. The results of our interviews cannot be generalized; however,

they provide valuable perspectives on particular challenges that disaster

survivors faced in obtaining IHP assistance.

In addition, we reviewed FEMA documentation and interviewed agency

officials to understand FEMA’s process for determining an applicant’s

eligibility for Small Business Administration (SBA)-dependent other needs

assistance (ONA). We also reviewed FEMA’s public disaster webpages,

news releases, and IHP documents, and observed FEMA officials to

understand how FEMA communicated its process to survivors. Lastly, we

analyzed FEMA’s IHP applicant data and interviewed FEMA, state,

territory, local, and NGO officials to assess whether FEMA’s process was

a challenge for survivors. We compared FEMA’s process and

communication efforts to the goals and objectives in FEMA’s 2018-2022

Strategic Plan

and the federal government’s roles and responsibilities

We interviewed local officials from Harris County, TX; Jefferson County, TX; Bay County,

FL; Jackson County, FL; Craven County, NC; Pender County, NC; Butte County, CA;

Sonoma County, CA; Caguas, PR; and Bayamon, PR.

We interviewed officials from Lone Star Legal Aid (TX), The Facilitators: Camp Ironhorse

(PR), Endeavors (PR and NC), Rebuild Bay County (FL), SBP (FL), and Catholic Charities

(CA).

Federal Emergency Management Agency, 2018-2022 Strategic Plan, (Washington, D.C.:

Mar. 15, 2018).

Appendix I: Objectives, Scope, and

Methodology

Page 91 GAO-20-503 Disaster Assistance

outlined in the National Disaster Recovery Framework.

We also

analyzed previous and current versions of FEMA’s IHP ineligible

determination letter using the Flesch Reading Ease score,

the Plain

Writing Act of 2010,

and the Substance Abuse and Mental Health

Administration’s guidance on disaster communications.

Lastly, we

compared the information FEMA provides to IHP applicants about their

case for assistance to the federal government’s roles and responsibilities

outlined in the National Disaster Recovery Framework and the Substance

Abuse and Mental Health Administration’s key principles for serving

individuals suffering from trauma, such as those who experienced a

disaster.

To address our third objective, we interviewed officials responsible for

implementing the IHP from FEMA’s headquarters and all four NPSCs, as

well as FEMA’s Regions II, IV, VI, and IX. At each NPSC, we interviewed

eight to 11 staff, selected by FEMA, who communicate with disaster

survivors and process their applications to obtain their experiences in

working on the IHP. In total, we interviewed 38 of these staff using the

same set of questions. We also interviewed state, territory, local, and

NGO officials in California, Florida, North Carolina, Texas, and Puerto

Rico, to understand their experiences, including any challenges, working

with FEMA to deliver the IHP. The results of our interviews cannot be

Department of Homeland Security. National Disaster Recovery Framework, Second

Edition (Washington, D.C.: June 2016).

Flesch Reading Ease scores fall on a scale from 0 to 100, with 0 being nearly impossible

to read and 100 being simple enough for a fifth grader to read. The formula is based on

average sentence length and average word length. The version we used was included in

the Microsoft Word processing software. As we have previously reported, the Flesch

Reading Ease score is one of the most widely used, tested, and reliable formulas for

calculating readability. See GAO-17-656, Vehicle Data Privacy: Industry and Federal

Efforts Under Way, but NHTSA Needs to Define Its Role (Washington, D.C.: July 28,

2017). To prepare FEMA’s ineligible determination letters for analysis, we deleted headers

and addresses and replaced phone numbers with “PHONE”, website addresses with

“URL”, and email addresses with “MAIL.”

Pub. L. No. 111-274, 124 Stat. 2861 (codified at 5 U.S.C. § 301 note).

Department of Homeland Security. National Disaster Recovery Framework. Substance

Abuse and Mental Health Services Administration, Communicating in a Crisis: Risk

Communication Guidelines for Public Officials. SAMHSA Publication No. PEP19-01-01-

005 (Rockville, MD: 2019).

Substance Abuse and Mental Health Services Administration, SAMHSA’s Concept of

Trauma and Guidance for a Trauma-Informed Approach. HHS Publication No. (SMA) 14-

4884 (Rockville, MD: 2014).

Appendix I: Objectives, Scope, and

Methodology

Page 92 GAO-20-503 Disaster Assistance

generalized: however, they can provide valuable context for the

challenges that FEMA experienced with implementing the IHP. Further,

we analyzed FEMA’s standard operating procedures for the IHP and

documentation on workforce capabilities, as well as information provided

to state and local officials, and compared them to Standards for Internal

Control in the Federal Government, a GAO human capital guide, FEMA’s

2018–2022 Strategic Plan, and the National Disaster Recovery

Framework.

To address our fourth objective, we interviewed officials from FEMA’s

Individual Assistance Division and Recovery Analytics Division, and the

IHP Service Delivery Branch. We analyzed documentation on FEMA

assessments and performance reports for the IHP, as well as data on

surveys that FEMA conducted with survivors who applied for the IHP. We

compared FEMA’s methodology for its IHP surveys to the Office of

Management and Budget’s Standards and Guidelines for Statistical

Surveys.

We also analyzed documentation on FEMA initiatives and

recommendations aimed at addressing challenges with the IHP and

compared these efforts with key process improvement and program

management activities from GAO’s Business Process Reengineering

Assessment Guide and The Standard for Program Management.

We analyzed FEMA’s IHP applicant data from 2016 through 2018, by

year and for the 3-year time frame, for the full population of IHP

applicants, as well as for groups of IHP applicants, which we created

using information found in IHP applications. Specifically, we analyzed IHP

referrals, approval rates, the types and amounts of IHP assistance

applicants received, the most common reasons for ineligibility, appeal

rates, the time between key events in the IHP financial assistance

process, SBA disaster loan application status, and amounts of FEMA-

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G

(Washington, D.C.: September 2014); and Human Capital: A Guide for Assessing

Strategic Training and Development Efforts in the Federal Government, GAO-04-546G

(Washington, D.C.: March 2004); Federal Emergency Management Agency, 2018–2022

Strategic Plan; and Department of Homeland Security, National Disaster Recovery

Framework, Second Edition.

Office of Management and Budget, Standards and Guidelines for Statistical Surveys

(Washington, D.C.: September 2006).

GAO, Business Process Reengineering Assessment Guide, Version 3,

GAO/AIMD-10.1.15 (Washington, D.C.: May 1997). Project Management Institute, Inc.,

The Standard for Program Management, Fourth Edition, 2017.

Analyzing Program

Outcomes Using

FEMA’s IHP Applicant

Data

Appendix I: Objectives, Scope, and

Methodology

Page 93 GAO-20-503 Disaster Assistance

verified personal property loss—which, for the purposes of this report, we

refer to as program outcomes.

We analyzed program outcomes for different groups of IHP applicants,

which we created using self-reported information from IHP applications.

Specifically, we created groups for the following categories:

homeownership status, age, household size, gross annual income,

federal poverty guideline, property insurance coverage, flood insurance

coverage, disaster location, and social vulnerability.

FEMA’s application for IHP assistance asks survivors to indicate their

homeownership status. We used the following two homeownership status

groups for our analysis: (1) owners, and (2) renters. We identified about

21,800 referred applicants (0.5 percent of all referred applicants) who did

not indicate a homeownership status in their IHP application.

FEMA’s IHP application asks survivors to provide a birth date for the

primary applicant and co-applicant, if applicable. To determine a

survivor’s age at the time they applied for IHP assistance, we used the

birth date provided for the primary applicant in their IHP application. We

used the following four age groups for our analysis: (1) under 25, (2) 25 to

49, (3) 50 to 64, and (4) 65 and older. We identified approximately 11,900

referred applicants (0.3 percent of all referred applicants) who did not

provide a birth date for the primary applicant or provided an illogical birth

date in their IHP application (i.e., the birth date the applicant provided was

on or after the application date).

FEMA’s IHP application asks survivors to indicate the number of

occupants in their home. We used the following three household size

groups for our analysis: (1) one, (2) two, and (3) three or more. We

identified about 30 referred applicants who did not provide household size

information in their IHP application.

FEMA’s application for IHP assistance also asks the applicant to provide

their gross annual income. We used the following four gross annual

income groups for our analysis: (1) less than $10,000, (2) $10,000 to less

than $25,000, (3) $25,000 to less than $50,000, and (4) $50,000 and

above. We identified about 697,000 referred applicants (16.0 percent of

Survivor and Community

Characteristics among the

IHP Applicant Population

Homeownership Status

Age

Household Size

Gross Annual Income

Appendix I: Objectives, Scope, and

Methodology

Page 94 GAO-20-503 Disaster Assistance

all referred applicants) who did not provide gross annual income

information in their IHP application.

We analyzed each IHP applicant’s reported gross annual income and

household size to calculate their reported gross annual income as a

percentage of the federal poverty guideline for the applicable year. We

used the federal poverty guidelines from the same year as the Individual

Assistance disaster declaration for which a survivor applied for IHP

assistance.

Each year, the Department of Health and Human Services issues federal

poverty guidelines, which represent a household income for different

household sizes and locations. There are three sets of guidelines: (1) 48

contiguous states and D.C., (2) Alaska, and (3) Hawaii.

The federal

poverty guidelines are not defined for U.S territories. Federal poverty

guidelines are used to determine financial eligibility for certain federal

programs.

According to the Department of Health and Human Services,

in cases in which a federal program using the poverty guidelines serves

any of those jurisdictions, the federal office that administers the program

is responsible for deciding whether to use the contiguous-states-and-D.C.

guidelines for those jurisdictions or to follow some other procedure. The

SBA established its minimum income guidelines for its Disaster Home

Loan Program using the federal poverty guidelines, according to a June

1985 agency memorandum. Specifically, SBA increased the federal

We used the Centers for Disease Control and Prevention’s Social Vulnerability Index to

analyze the socioeconomic vulnerability of the communities in which referred and awarded

IHP applicants lived. Socioeconomic vulnerability measures the number of people who are

unemployed, living in poverty, and do not have a high school diploma, as well as per

capita income. We found that referred and awarded applicants who provided income

information in their IHP application and those who did not lived in communities

characterized by lower and higher levels of socioeconomic vulnerability in roughly the

same proportion. For example, roughly 36 percent of referred applicants who provided

income information in their IHP application and 33 percent of those who did not lived in

communities characterized by the highest levels of socioeconomic vulnerability. However,

we also found that referred and awarded applicants who did not provide income

information in their IHP application were somewhat more likely to have lived in

communities characterized by lower levels of socioeconomic vulnerability.

For example, the 2018 poverty guideline for a family of four in any of the 48 contiguous

states and the District of Columbia was $25,100. In comparison, the 2018 guidelines for a

family of four in Alaska and Hawaii were $31,380 and $28,870, respectively.

For example, the Department of Agriculture’s National School Lunch Program provides

lunches to children in schools for free if their household income is below 130 percent of

the poverty guidelines and at a reduced price if their household income is between 130

percent and 185 percent of the guidelines.

Federal Poverty Guideline

Appendix I: Objectives, Scope, and

Methodology

Page 95 GAO-20-503 Disaster Assistance

poverty guidelines for a single person household by 150 percent and all

other households by 125 percent to create the minimum income

guidelines for its loan program. To include all IHP applicants in our

analysis, we calculated federal poverty guidelines for relevant U.S.

territories by multiplying the federal poverty guideline for the 48

contiguous states and the District of Columbia by the same factor that the

SBA used to calculate its minimum income guidelines for U.S. territories.

From 2016 through 2018, almost 1.2 million IHP applicants (over 21

percent of all IHP applicants) were survivors of disasters that occurred in

the following U.S. territories: U.S. Virgin Islands, Puerto Rico, American

Samoa, and the Commonwealth of the Northern Mariana Islands.

We used the following four federal poverty guideline groups for our

analysis: (1) 100 percent or below; (2) above 100 percent to 200 percent;

(3) above 200 percent to 300 percent; and (4) above 300 percent. As

stated previously, we identified about 697,000 referred applicants (16.0

percent of all referred applicants) who did not provide gross annual

income information. As a result, we could not categorize these referred

applicants into our federal poverty guideline groups.

We reviewed the types of insurance coverage survivors reported having

in their IHP application and identified 17 discrete types of coverage. Of

these 17 types, 11 were types of real and/or personal property insurance

coverage. In addition, some survivors indicated that they did not have real

or personal property insurance, or did not provide insurance coverage

information in their application. We used the following three property

insurance coverage groups for our analysis: (1) no property coverage; (2)

only personal property coverage; and (3) real and personal property

coverage. For the purpose of our analyses, we included in the group with

no real or personal property insurance survivors who did not provide

insurance coverage information in their application. From 2016 through

2018, roughly 0.2 percent of all referred IHP applicants did not provide

property insurance coverage information in their IHP application. We

included flood insurance coverage in the real and personal property

coverage group. We did not report IHP outcomes for referred applicants

who only had real property coverage because this group accounted for

less than 0.1 percent of all referred applicants (roughly 2,900).

We also reviewed FEMA’s IHP applicant data to determine if survivors

reported having flood insurance in their IHP applications. We used the

following two flood insurance coverage groups for our analysis: (1) no

coverage; and (2) coverage. We included in our coverage group survivors

who explicitly reported having flood insurance in their IHP application.

Property Insurance Coverage

Flood Insurance Coverage

Appendix I: Objectives, Scope, and

Methodology

Page 96 GAO-20-503 Disaster Assistance

We also created groups based on the location of the Individual

Assistance disaster declaration for which a survivor applied for IHP

assistance. We used the following four disaster location groups for our

analysis: (1) U.S. states;

(2) Puerto Rico; (3) U.S. Virgin Islands; and (4)

other U.S. territories. For example, survivors of Hurricane Maria in Puerto

Rico who applied for IHP assistance were included in our Puerto Rico

disaster location group.

We also analyzed the address information that survivors provided in their

IHP application to determine the social vulnerability of their community.

To determine the social vulnerability of an IHP applicant’s community, we

used the address information that the applicant reported in their

application to identify the census tract they lived in and matched that

census tract to the Centers for Disease Control and Prevention’s 2016

Social Vulnerability Index. The Centers for Disease Control and

Prevention created the Social Vulnerability Index to help public health

officials and emergency response planners identify and map the

communities that will most likely need continued support to recover

following an emergency or natural disaster. The index indicates the

relative social vulnerability of census tracts in the U.S. and Puerto Rico.

Census tracts are subdivisions of counties for which the U.S. Census

Bureau collects statistical data through the American Community Survey.

The index ranks tracts on 15 variables, including unemployment, minority

status, and disability, and further groups them into the following four

themes: (1) socioeconomic status; (2) household composition and

disability; (3) minority status and language; (4) housing and

transportation, as well as an overall ranking. The index is a 0 to 1 scale,

with higher scores indicating greater vulnerability. The Social Vulnerability

Index scores for a tract in Puerto Rico reflect levels of vulnerability

relative to other tracts in Puerto Rico, not other tracts in the U.S.

We used the following social vulnerability groups for our analysis: (1)

overall – least vulnerable; (2) overall – most vulnerable; (3)

socioeconomic status – least vulnerable; (4) socioeconomic status – most

vulnerable; (5) household composition and disability – least vulnerable;

(6) household composition and disability – most vulnerable; (7) minority

status and language – least vulnerable; (8) minority status and language

– most vulnerable; (9) housing and transportation – least vulnerable; and

(10) housing and transportation – most vulnerable. For the purposes of

This group includes survivors who applied for IHP assistance for disasters in any of the

48 contiguous states, Alaska, Hawaii, and the District of Columbia.

Disaster Location

Social Vulnerability of a

Survivor’s Community

Appendix I: Objectives, Scope, and

Methodology

Page 97 GAO-20-503 Disaster Assistance

our analysis, the least vulnerable tracts had a Social Vulnerability Index

score of .25 or less, and the most vulnerable tracts had a score of greater

than .75. We were not able to assign a Social Vulnerability Index score to

roughly 2,200 referred IHP applicants from U.S. states (less than 0.1

percent of all referred IHP applicants from U.S. states) and roughly

36,200 referred IHP applicants from Puerto Rico (4.0 percent of all

referred IHP applicants from Puerto Rico).

We reviewed FEMA’s IHP applicant data to determine the status of

applicants’ cases for IHP assistance. The six possible case statuses in

FEMA’s data were (1) not referred to the IHP, (2) approved, (3) ineligible,

(4) no decision because of insurance, (5) withdrawn, and (6) pending. We

counted the number of applicants who were referred to the IHP. To

determine approval rates for IHP assistance, we calculated the

percentage of all referred applicants that FEMA approved for IHP

assistance. From 2016 through 2018, over 5.6 million survivors applied

for IHP assistance. FEMA referred 4.4 million applicants to the IHP to be

considered for assistance. FEMA approved 44.8 percent of these referred

applicants (about 2.0 million) for IHP assistance. The remaining 55.2

percent of referred applicants (about 2.4 million) were not approved for

IHP assistance. This includes the 39.0 percent of referred applicants

(about 1.7 million) who FEMA determined ineligible for IHP assistance;

the 10.2 percent of referred applicants (about 446,700) who did not

receive a decision from FEMA because of missing insurance

documentation; the 6.0 percent of referred applicants (about 260,500)

who had their applications withdrawn;

and the less than 0.1 percent of

referred applicants (about 70) who had a pending case.

We reviewed FEMA’s IHP applicant data to determine whether applicants

received IHP financial assistance, the types of financial assistance they

received, and the total amount of financial assistance that FEMA awarded

to them. FEMA’s IHP applicant data includes records for all the types of

IHP financial assistance the agency considered an applicant for, as well

as the amount of funds FEMA provided for each type of assistance. We

counted the number of applicants who received any IHP financial

assistance. We also added all IHP applicants who received an award for

A survivor can voluntarily withdraw their application for IHP assistance. FEMA can

withdraw a survivor’s application for assistance if the applicant failed to provide a required

signature or could not be contacted.

Analysis of IHP Outcomes

Analysis of IHP Referrals and

Approval Rates

Analysis of IHP Financial

Assistance Received

Appendix I: Objectives, Scope, and

Methodology

Page 98 GAO-20-503 Disaster Assistance

a particular type of IHP financial assistance to determine how many

people received each type of IHP financial assistance. To determine the

total amount of IHP financial assistance an applicant received, we added

the amounts FEMA awarded the applicant for each type of IHP financial

assistance, excluding group flood insurance.

We then calculated the

average and median total award amounts for IHP applicants who

received IHP financial assistance.

We reviewed FEMA’s IHP applicant data to identify any ineligible

determinations that applicants received, including the corresponding

reason for ineligibility. Applicants may receive multiple ineligible

determinations. We identified over 40 different reasons for ineligibility,

and counted the number and calculated the percentage of referred IHP

applicants who had each reason to determine the three most common

reasons.

We reviewed FEMA’s IHP applicant data to determine whether an

applicant appealed any of FEMA’s determinations on their application for

assistance. We counted the number of IHP applicants who had at least

one appeal record in their application for assistance and calculated the

percentage of referred IHP applicants who appealed a FEMA

determination. Further, we counted the number of IHP applicants who

received an award after their appeal and calculated the percentage of IHP

applicants who successfully appealed a FEMA determination. We also

counted the number of appeals that IHP applicants submitted to FEMA.

We reviewed FEMA’s IHP applicant data to identify the date a survivor

applied for IHP assistance and dates for the following key events in the

IHP process for financial assistance: first inspection; first award; and final

decision, which, for the purposes of our analysis, indicates the end of a

survivor’s involvement in the IHP process for financial assistance. We

determined the number of days between a survivor’s application date and

The National Flood Insurance Reform Act of 1994 requires FEMA applicants to obtain

and maintain flood insurance after receiving IHP assistance for real and/or personal

property losses, when the predisaster home is located in a Special Flood Hazard Area.

See 44 C.F.R. § 206.110(k)(2). Group flood insurance is established for each disaster

declaration that results from flooding and authorizes the Individual Assistance Program.

FEMA directly purchases group flood insurance certificates—that cost $600 and provide 3

years of coverage—on behalf of applicants who are required to obtain and maintain flood

insurance. From 2016 through 2018, less than 3 percent of all awarded IHP applicants

received group flood insurance.

For the purposes of this report, average refers to the mean.

Analysis of Reasons for

Ineligible Determination

Analysis of Appeals

Analysis of Time between Key

Events in the IHP Financial

Assistance Process

Appendix I: Objectives, Scope, and

Methodology

Page 99 GAO-20-503 Disaster Assistance

the dates for the key events that applied to their experience with the IHP.

For example, only survivors who reported home or personal property

damages to FEMA will receive an inspection. We then calculated the

average and median number of days between survivors’ application date

and first inspection; first award; and final decision dates, excluding any

negative results from our analysis (i.e., the application date was after the

first inspection; first award; or final decision date).

We excluded Critical Needs Assistance records from our analysis of the

time between survivors’ application dates and the dates that FEMA

awarded them IHP assistance for the first time. According to FEMA

officials, the provision of Critical Needs Assistance is not typical.

We analyzed the number of days from survivors’ application date and

dates they received a final decision from FEMA for (1) applicants who

were referred to the IHP and (2) applicants who received IHP assistance.

For this analysis, we excluded applicants with a pending decision on their

application for IHP assistance. In addition, we excluded those who only

received Critical Needs Assistance and took no further action to pursue

other forms of financial IHP assistance, which we defined as (1) not

submitting any documents to FEMA, (2) not having any recorded contacts

with FEMA, and (3) not receiving an inspection—three data points

included in FEMA’s IHP applicant data. From 2016 through 2018, roughly

16 percent of all survivors who received assistance (roughly 318,000)

only received Critical Needs Assistance and took no further action to

pursue other forms of financial IHP assistance. We also excluded records

Out of the over 1 million applicants included in these analyses, we identified less than 60

cases where the application date was after the first award or final decision date.

An affected state, territorial, or tribal government must request that FEMA authorize

Critical Needs Assistance for specific geographic areas or all counties declared for

Individual Assistance, as the assistance is subject to a state/federal cost-share. FEMA’s

Individual Assistance Division Director may authorize the assistance when the identified

areas are or will be inaccessible for an extended period of time (i.e., 7 days or longer).

Survivors who complete a FEMA application and pass identify verification may be eligible

for Critical Needs Assistance if they state an emergency need for food, medication, gas,

shelter, or clothing at the time of application, and are displaced from their primary

residence as a result of the disaster. According to our analysis, FEMA provided Critical

Needs Assistance—a one-time payment of $500—to over 925,000 survivors in 14 of the

52 Individual Assistance disaster declarations from 2016 through 2018. We also found

that the average time between a survivor’s application and award dates for Critical Needs

Assistance was 1.7 days.

Appendix I: Objectives, Scope, and

Methodology

Page 100 GAO-20-503 Disaster Assistance

related to retroactive processing for IHP awards made necessary by

Section 1212 of the Disaster Recovery Reform Act of 2018.

We reviewed FEMA’s IHP applicant data to determine the status of IHP

applicants’ application for a disaster loan from the SBA.

We identified 16

different statuses in FEMA’s data and counted the number of IHP

applicants with each status. We then grouped the 16 statuses into five

categories: (1) loan approved; (2) applicant lacked repayment ability; (3)

applicant did not complete loan application; (4) loan canceled, declined,

or withdrawn; and (5) other, and counted the number of IHP applicants in

each category.

We reviewed FEMA’s IHP applicant data to identify applicants who did

not complete an application for SBA’s Disaster Loan Program and

experienced personal property loss, which FEMA verified through an

inspection.

We counted the number of IHP applicants who did not

complete an SBA loan application and had FEMA-verified personal

property loss in their application for assistance. In addition, we added

dollar amounts of FEMA-verified personal property loss, which we took

from the latest inspection record, for these applicants. As previously

stated, FEMA’s IHP applicant data include dates for certain events in the

IHP financial assistance process, such as FEMA inspections. We also

reviewed these applicants’ award records to determine the percentage of

these applicants who received other forms of IHP financial assistance

from FEMA.

42 U.S.C. § 5174(h).

The Stafford Act limits FEMA’s IHP assistance to necessary expenses and serious

needs unable to be met through other means. Because some categories of IHP

assistance are for expenses and needs that may also be addressed by an SBA loan,

FEMA coordinates with SBA to determine a survivor’s eligibility for personal property

assistance, transportation assistance, and group flood insurance, which FEMA refers to

collectively as SBA-dependent other needs assistance.

After receiving a survivor’s application information, FEMA automatically refers the

survivor to SBA to complete a disaster loan application if they reported a gross household

income and household size that meet SBA’s minimum income guidelines to be considered

for a loan (see appendix IV for SBA’s minimum income guidelines for fiscal year 2018);

reported self-employment income; or refused to provide their income in their disaster

assistance application. FEMA will continue to move applicants who were referred to SBA

through the steps of the IHP process, including the inspection process, but FEMA requires

that these applicants be declined an SBA loan before the agency considers them for SBA-

dependent other needs assistance, such as assistance for personal property losses.

Analysis of Small Business

Administration Disaster Loan

Application Status

Analysis of FEMA-Verified

Personal Property Damages

for IHP Applicants Who Did

Not Complete an Application

for the Small Business

Administration’s Disaster Loan

Program

Appendix I: Objectives, Scope, and

Methodology

Page 101 GAO-20-503 Disaster Assistance

We conducted this performance audit from October 2018 to September

2020 in accordance with generally accepted government auditing

standards. Those standards require that we plan and perform the audit to

obtain sufficient, appropriate evidence to provide a reasonable basis for

our findings and conclusions based on our audit objectives. We believe

that the evidence obtained provides a reasonable basis for our findings

and conclusions based on our audit objectives.

Appendix II: Summary of Eligibility,

Verification, and Delivery Considerations for

Individuals and Households Program

Assistance

Page 102 GAO-20-503 Disaster Assistance

In order to consider an applicant for IHP assistance, FEMA reviews

documentation and uses other verification procedures to ensure that

survivors meet the general eligibility requirements. However, when

disaster-specific conditions make these requirements burdensome for

survivors, FEMA may adjust the acceptable documentation to meet the

requirement, as was the case, for example, for multiple disasters in 2017

and 2018. See table 4 below for a summary of these general eligibility

requirements and selected examples of adjusted verification procedures.

Table 4: General Eligibility Requirements, Verifications, and Selected Adjusted Procedures to Meet Eligibility for the Federal

Emergency Management Agency’s (FEMA) Individuals and Households Program Assistance

Eligibility

requirements

Verification process Selected examples of adjusted verification procedures

U.S. citizenship or

qualified status

Applicants self-certify their qualifying

citizenship status on a declaration and

release form.

Program procedures state that disaster survivors who registered for

assistance at a public Disaster Assistance Center on or after

September 19, 2017, do not have to sign this form, due to changes in

the registration script. Although disaster-specific procedures for

survivors of Hurricane Maria in Puerto Rico note that this form was

suspended, survivors were required to provide the signed form because

FEMA used paper applications in the disaster due to communication

issues.

Identify verification

FEMA typically verifies an applicant’s

identity through an automated public

records search at the time of

registration or through a FEMA

inspection.

When FEMA is unable to verify an applicant’s identity, applicants may

be asked to submit documentation providing identity, such as a Social

Security card along with another federal or state-issued identification, a

U.S. passport, or a federal document containing the full or last four

digits of the Social Security number. On a case-by-case basis, FEMA

may allow applicants in the U.S. territories to submit specific

documents, such as a voter registration card.

Insurance, or other

forms of

assistance, do not

meet disaster-

caused needs

Applicants are required to inform

FEMA of all insurance coverage that

may meet their disaster-caused needs.

Insured applicants must provide

documentation that identifies their

insurance settlements or benefits

before FEMA will consider their

eligibility.

If survivors have not provided their insurance settlement information,

FEMA may call the insurance company to request the necessary

information to make award determinations. For example, in North

Carolina following Hurricane Florence, standard practice for all staff

processing assistance included calling the insurance provider and

processing assistance if the provider confirmed the information verbally

or in writing.

Proof of

occupancy

FEMA verifies occupancy at the time

of registration and requests documents

at the time of the housing inspection,

as needed. Acceptable documents

include utility bills; bank statements;

paystubs; or a valid driver’s license,

among other documents.

As a last resort, if the listed documentation is not available, survivors

may provide a written statement indicating how long they lived in the

disaster-damaged residence and a statement to explain why the

standard verification documentation is unavailable. For example,

officials in Florida stated that many residents could not access these

documents because they were lost during the damages caused by

Hurricane Michael.

Appendix II: Summary of Eligibility,

Verification, and Delivery Considerations for

Individuals and Households Program

Assistance

Appendix II: Summary of Eligibility,

Verification, and Delivery Considerations for

Individuals and Households Program

Assistance

Page 103 GAO-20-503 Disaster Assistance

Eligibility

requirements Verification process Selected examples of adjusted verification procedures

Proof of ownership

FEMA may verify the survivor’s

homeownership status through the

inspection or an automated public

records search. If both are

unsuccessful, the survivor may submit

certain documents, such as a deed or

mortgage statement, which are

preferred forms of verification.

FEMA guidance provides a list of alternate verification documents that

survivors may provide if preferred documents are not available. Some

of these alternate documents include a property tax receipt or a will

naming the survivor as the heir to the property. In Puerto Rico following

Hurricanes Irma and Maria, survivors faced significant challenges

providing acceptable proof of ownership, according to FEMA officials. In

November 2018, FEMA began a process in which 75 staff reached out

to more than 20,000 survivors who were awaiting an assistance

determination due to missing ownership verification. According to IHP

officials, FEMA approved almost $34 million in assistance for about

11,000 survivors.

Source: GAO summary of FEMA program guidance and information.| GAO-20-503

Federal Emergency Management Agency, Individual Assistance Program and Policy Guide, FP 104-

009-03 (Washington, D.C.: Mar. 4, 2019).

See 42 U.S.C. § 5174(i).

See 42 U.S.C. § 5174(a)(1); 44 C.F.R. § 206.110(a).

See 42 U.S.C. § 5174(i).

Federal Emergency Management Agency, Individual Assistance Program and Policy Guide.

Survivors who indicated that they are renting their home during registration do not need to provide

documentation for proof of ownership.

In addition to the general program eligibility criteria—citizenship, identity,

insurance, occupancy, and ownership—FEMA requires survivors to meet

further eligibility criteria that are specific to the category—either housing

or other needs assistance—and the specific type of assistance. The IHP

also must review documentation and assess losses to determine

survivors’ eligibility for each type of assistance, and there are other

delivery considerations that affect what assistance and how much

assistance FEMA will award to an eligible applicant.

Housing assistance. To be eligible for housing assistance—including

direct and financial housing assistance—the applicant must not have

other sources of aid to cover their housing losses, such as insurance, and

also demonstrate qualifying levels of damage. Specifically, FEMA may

only provide housing assistance when the disaster has displaced the

survivor or caused damage that renders the home uninhabitable or, with

respect to individuals with disabilities, rendered inaccessible or

uninhabitable, as a result of damage caused by a major disaster, as

found by an assessment of damages and losses identified during FEMA’s

Appendix II: Summary of Eligibility,

Verification, and Delivery Considerations for

Individuals and Households Program

Assistance

Page 104 GAO-20-503 Disaster Assistance

inspection.

There are additional eligibility and verification requirements in

place, and varied delivery considerations, depending on the specific type

of direct or financial housing assistance offered.

Direct housing assistance has additional eligibility considerations, and

FEMA does not provide this in all disasters. The state, territory, or tribe

must submit a written request to FEMA for approval. Then FEMA may

provide direct housing assistance when disaster survivors who registered

for FEMA assistance are unable to use rental assistance.

Next, FEMA

identifies applicants who may need direct housing based on a FEMA

inspection finding at least $17,000 in losses for homeowners, or renters

whose residence was found to be destroyed or received major damages.

Table 5 provides more details on the description and considerations for

each type of direct housing assistance.

Table 5: Description of the Federal Emergency Management Agency’s (FEMA) Eligibility Considerations for Types of Direct

Housing Assistance under the Individuals and Households Program, according to March 2019 Guidance

Type and description of assistance

Eligibility, verification, and delivery considerations

Multifamily lease and repair (MLR). FEMA may make

repairs or improvements to existing, vacant multifamily

housing units (e.g., apartments) and use the repaired units

under MLR as temporary housing for eligible applicants.

MLR is not intended to repair or improve individual units to

rehouse the predisaster tenants.

For applicants, eligibility for MLR housing is based on an individual

assessment of need gathered during an interview.

Further, FEMA must verify that the property is eligible for MLR, which

requires that it is located near community services (i.e., schools, grocery

stores, etc.); can be leased to FEMA for a minimum of 18 months; and

allow FEMA to make needed improvements for reasonable

accommodations, among other things. Once a property is eligible, FEMA

completes a process to approve the property, contract for necessary

repairs, and finalize lease agreements.

Direct lease. FEMA may lease existing residential

properties for use as temporary housing. Direct lease

properties are those that are not typically available to the

public, such as corporate apartments or vacation rentals.

FEMA does not use units available to survivors with rental

assistance, such as hotels and motels, for direct lease.

For applicants, eligibility considerations for providing direct lease units is

based on an individual assessment of need gathered during an

interview.

Further, FEMA only considers direct lease when housing needs exceed

the capacity to provide MLR or Transportable Temporary Housing Units

in a timely manner and when FEMA has identified properties that are

generally not available to the public and meet eligibility criteria. Those

criteria for properties include being located near community services

(i.e., schools, grocery stores, etc.); the property owner agreeing to

specific lease provisions (i.e., the option to extend the lease beyond 18

months); and the rental rate is within an approved limit.

42 U.S.C. 5174(b)(1)). For example, FEMA may provide financial assistance to repair a

home to a safe and sanitary living or functioning condition. 44 C.F.R. § 206.117(b)(2)(iii).

FEMA regulations define safe as secure from disaster-caused hazards or threats to

occupants; sanitary as being free of disaster-caused health hazards; and functional as an

item or home capable of being used for its intended purpose. 44 C.F.R. § 206.111.

42 U.S.C. § 5174(c)(1)(B)(i).

Appendix II: Summary of Eligibility,

Verification, and Delivery Considerations for

Individuals and Households Program

Assistance

Page 105 GAO-20-503 Disaster Assistance

Type and description of assistance

Eligibility, verification, and delivery considerations

Transportable Temporary Housing Units (TTHU). FEMA

may choose to provide eligible applicants a TTHU in the

form of recreational vehicles or manufactured housing

units, which FEMA can purchase or lease. Both options are

to provide housing for a limited period. FEMA also

determines what type of site to use for these units, which

may be

private site: Private sites are sites provided by an applicant

at no cost to FEMA, typically on their property near their

predisaster residence;

commercial site: Commercial sites are existing

manufactured home parks with available pads that FEMA

may lease; and.

group site: The state, tribal, or territorial government

provides these sites—such as park land—and the land is

built out to include the utilities and other requirements for

temporary housing.

For applicants, eligibility considerations for which type of TTHU to

provide is based on an individual assessment of need gathered during

an interview. Such factors include the applicant’s household composition

and the amount of time the survivor needs temporary housing.

Further, FEMA will complete the process to identify eligible sites,

prepare the sites for the TTHU, ensure compliance with environmental

and historic preservation laws, consider floodplain management, and

manage the disposal of TTHUs through either sales or donations.

Permanent housing construction. FEMA may provide

financial or direct assistance to make permanent repairs or

construct permanent or semipermanent housing.

• Repairs are completed as needed to restore the home

to a habitable condition. This may include the interior

walls; doors; floors; roof; and preexisting accessibility

features, among other components. All repairs will be

of average “builder grade” quality and must meet

federal, local, and industry construction codes, as

applicable.

• New construction will also be “builder grade” quality

and meet the same code requirements, but FEMA and

state, local, tribal, and territorial partners collaborate to

determine the appropriate type of construction for the

area.

FEMA may provide financial assistance or direct assistance to

individuals and households to construct permanent or semipermanent

housing in insular areas outside the continental U.S. FEMA may also

consider providing such assistance in other locations where no

alternative housing resources are available and other types of temporary

housing assistance are infeasible or not cost-effective.

For applicants, eligibility considerations for providing permanent housing

construction vary, depending on whether the assistance is for repair or

replacement:

• Repair may be considered when the FEMA inspection finds losses

over $17,000 but not over the maximum assistance, and the home

is not destroyed. The applicant must demonstrate on appeal that

they cannot use home repair assistance to make their home

“habitable,” among other requirements to meet timeliness and cost-

effectiveness considerations.

• New construction may be considered when the FEMA inspection

finds that the home is destroyed and new construction is more cost-

effective than making repairs. Applicants must also follow additional

terms for new construction, for example, that they obtain and

maintain flood insurance on a property in a flood area, among other

requirements.

Applicants are also required to disclose all other forms of assistance that

may be a duplication of benefits and cannot accept a disaster home loan

from the Small Business Administration to be eligible for permanent

housing construction.

Source: GAO summary of FEMA program guidance. | GAO-20-503

Table 6 provides more details on the description and requirements for

each type of financial housing assistance.

Appendix II: Summary of Eligibility,

Verification, and Delivery Considerations for

Individuals and Households Program

Assistance

Page 106 GAO-20-503 Disaster Assistance

Table 6: Description of the Federal Emergency Management Agency’s (FEMA) Eligibility Considerations for Types of Financial

Housing Assistance under the Individuals and Households Program (IHP), according to March 2019 Guidance

Type and description of assistance

Eligibility, verification, and delivery considerations

Lodging. FEMA may provide this assistance for

applicants’ out-of-pocket temporary lodging

expenses, such as the cost and taxes for short-term

hotel accommodations following a disaster.

In addition to habitability, applicants who indicate during registration that their

home is inaccessible or without power may be eligible for lodging assistance

for the dates of the utility outage. The applicant must provide verifiable receipts

with the following information:

• The applicant’s name or further documentation to prove the applicant

reimbursed a third party for the expenses.

• The name, address, and phone number of the accommodation

• The dates of occupancy.

• The itemized expenses incurred, to identify expenses excluded, such as

phone, laundry, internet, and pet charges.

Rental assistance. FEMA awards an initial rental

assistance payment based on the Fair Market Rent

for the area according to the Department of Housing

and Urban Development and the number of

bedrooms required. The amount of assistance is

intended to cover the monthly rent and essential

utilities (i.e., gas, electric, water, oil, trash, and

sewer) for the housing unit for 2 months and may be

used to pay a security deposit. FEMA may award

continued rental assistance for up to 18 months to

applicants based on documented need. When local

housing market rate increases result in an inability

for applicants to find an affordable rental unit, FEMA

may award a rental assistance rate increase at the

request of the state, tribal, or territorial government.

Once this increase is approved, FEMA applies the

new rate to eligible applicants’ future rental

assistance awards.

In addition to habitability, applicants who indicate during registration that their

home is inaccessible or without power, and indicate a willingness to relocate,

may be eligible. Eligibility considerations for initial rental assistance are met

through the answers on the registration for assistance and FEMA’s inspection.

To demonstrate eligibility for continued rental assistance, the applicant shows

that they have not been able to fulfill their permanent housing plan—which is a

plan with a realistic time frame for the applicant to return to permanent housing

that is similar to their predisaster housing. FEMA generally expects that renters

will use their initial rental assistance to find permanent housing. When a

homeowner’s FEMA inspection shows losses exceeding the amount of initial

rental assistance, FEMA will automatically send a form to request continued

rental assistance. Otherwise, homeowners and renters must request this form

by calling FEMA. The survivor must submit the Application for Continued

Temporary Housing Assistance form and provide

• a copy of the signed current lease/rental agreement,

• proof that prior rental assistance was used for temporary housing,

• proof of predisaster housing costs, and

• current and predisaster household income.

Home repair. FEMA may award financial home

repair assistance to repair the damaged home to a

safe and sanitary or functioning condition. It is not

intended to return the home to its predisaster

condition and only includes certain components of

the property, such as the foundation; walls; and

windows, among others.

In order to be eligible for home repair assistance, applicants must own the

home as their primary residence, ownership must be verified, and the applicant

must have uninsured losses. Otherwise, FEMA’s inspection identifies the

eligible components, and the program’s system generates the eligible award

amount.

Home replacement. For homeowners whose

primary residence was destroyed, FEMA may

provide financial assistance that may be applied

toward purchasing a new, permanent residence.

FEMA calculates the replacement award amount

according to the consumer price index data for the

types of housing in the damage location and

establishes award amounts based on the type of

home (e.g., manufactured home, travel trailer, or

single-family home).

In order to be eligible for home replacement assistance, FEMA must verify that

applicants own the home as their primary residence, the residence was

functional prior to the disaster, and that the damage is not insured. FEMA’s

system may automatically verify ownership, and FEMA’s inspection verifies the

property as destroyed.

Source: GAO summary of FEMA program guidance. | GAO-20-503

Appendix II: Summary of Eligibility,

Verification, and Delivery Considerations for

Individuals and Households Program

Assistance

Page 107 GAO-20-503 Disaster Assistance

Other needs assistance (ONA). This consists of financial assistance for

other necessary expenses and serious needs caused by the disaster.

Some types of ONA are only provided if a survivor does not qualify for a

disaster loan from the Small Business Administration (SBA); this

assistance includes personal property and transportation assistance and

group flood insurance policies (collectively referred to as SBA-dependent

ONA). FEMA requires survivors with certain incomes and household

sizes to apply to the SBA Disaster Loan Program and be denied or

receive a partial loan before FEMA will consider them for SBA-dependent

ONA. Other types of ONA can be provided regardless of SBA loan

qualification, including funeral, medical, dental, child care, critical needs,

and clean and removal assistance, and other miscellaneous items (e.g.,

tools). Further, for certain types of other needs assistance—child care,

funeral, and transportation—the maximum amount of assistance

applicants may receive varies and is determined by each state, territory,

and tribe on a yearly basis. ONA is subject to a nonfederal cost share of

25 percent, paid by the respective state, territorial, or tribal government.

Table 7 provides more details on the description and requirements for

each type of ONA.

Table 7: Description of the Federal Emergency Management Agency’s (FEMA) Eligibility Considerations for Types of Other

Needs Assistance under the Individuals and Households Program (IHP), according to March 2019 Guidance

Type and description of assistance

Eligibility, verification, and delivery considerations

Funeral. FEMA may provide financial assistance to an

individual who incurs expenses related to a death or

disinterment attributed directly or indirectly to a

declared disaster. This assistance covers funeral

services, which may include preparation of the

deceased (e.g., embalming, cremation); use of

facilities; staff for viewing and graveside service;

among other things.

Eligibility for funeral assistance requires that a government-licensed medical

official attributed the death to the declared disaster, either directly or

indirectly, and the applicant for assistance incurred eligible expenses.

show this, the applicant must provide the following documents:

• an official death certificate or qualifying statement indicating the disaster

as the direct or indirect cause of death;

• receipts or verifiable estimates for the eligible expenses; and

• burial insurance or other forms of burial assistance received.

The maximum amount of funeral assistance varies according to the states,

territorial, or tribal decisions. For example, these amounts ranged from a low

of $5,000 to a high of $15,000 for the catastrophic hurricanes in 2017 and

2018.

Medical and dental. FEMA may provide financial

assistance to an individual who incurs disaster-caused

medical or dental expenses. Such expenses include

injury or illness caused by the disaster; replacement of

prescribed medication; and the veterinary expenses for

a service animal, among other things.

Eligibility for all medical or dental assistance requires the applicant to provide

two key documents: (1) a verifiable statement that the medical or dental

injury was a direct result of the disaster, and (2) itemized bills or estimates

from a medical provider. Specific losses have additional requirements, for

example, verifying expenses for a service animal require the above

documentation as well as proof that the applicant required the service animal

and the type of work performed by the service animal.

42 U.S.C. § 5174(g); 44 C.F.R. § 206.110(i).

Appendix II: Summary of Eligibility,

Verification, and Delivery Considerations for

Individuals and Households Program

Assistance

Page 108 GAO-20-503 Disaster Assistance

Type and description of assistance

Eligibility, verification, and delivery considerations

Child care. FEMA may provide financial assistance to

households who have a disaster-caused increased

financial burden for child care. FEMA will award a

onetime payment to reflect up to 8 weeks of the

household’s increased financial burden, plus any

eligible expenses, subject to the state, tribal, or

territorial maximum.

Eligibility for child care assistance is based on the applicant’s increased

financial burden for child care—due to a decrease in household income, an

increase in child care expenses, or both—as a resul

t of the declared disaster.

FEMA calculates this burden as the percentage of household income for

child care costs predisaster as compared to postdisaster. To show this, the

applicant must provide documentation of the following:

• pre- and postdisaster gross income;

• pre- and postdisaster child care expenses and fees;

• postdisaster child care contract;

• postdisaster child care provider’s license; and

• signed, written statement of need from the applicant.

The maximum amount of child care assistance varies according to the states’

decisions. For example, these amounts ranged from a low of $700 to a high

of $2,400 for the catastrophic hurricanes in 2017 and 2018.

Critical needs. FEMA may provide critical needs

assistance to survivors with immediate or critical needs

because they are displaced from their primary dwelling.

This is a onetime award payment, which cannot

exceed $500. Immediate or critical needs are life-

saving and life-sustaining items, including water, food,

first aid, prescriptions, infant formula, diapers,

consumable medical supplies, durable medical

equipment, personal hygiene items, and fuel for

transportation.

The affected state, tribal, or territorial government must submit a written

request within 14 days of the disaster declaration. The Individual Assistance

Program’s Division Director generally authorizes this assistance when the

disaster caused a majority of individuals to be displaced from their homes for

7 days or longer.

Eligibility for critical needs assistance is determined based on information

gathered during the registration process. Specifically, their registration must

meet four conditions:

• pass FEMA’s identity verification,

• affirm during registration that they have critical needs and request

assistance for those expenses,

• the primary residence is located in the approved area, and

• they are displaced from their primary residence as a result of the

disaster.

Clean and removal. Clean and removal assistance is

intended to help households with real-property flood

damage that did not affect the home’s habitability. For

example, this assistance helps homeowners address

contamination from flooding in a timely manner.

Eligibility for clean and removal assistance is determined through the results

of a FEMA inspection that finds that at least one real-property line item is

flood damaged. The applicant must also receive a denial for home repair

assistance because the damage did not affect the habitability of the home.

Miscellaneous items. State, territorial, and tribal

governments, in consultation with FEMA, have

identified standard miscellaneous line items that can

assist with recovery. These items include chainsaws;

dehumidifiers; and generators, among other things.

Eligibility for miscellaneous items requires that the items were purchased or

rented within 30 days of the start of the incident start date or up to the last

day of the incident period, which is greater. To verify eligibility, applicants

must provide an itemized receipt or equipment rental agreement for eligible

expenses.

Personal property. FEMA may award personal

property assistance for the specific line items as

identified by each state, tribal, or territorial other needs

assistance administrative option selection form.

Personal property line items include appliances;

clothing; and furniture, among other things.

Eligible personal property requires that the item needs repair or replacement

and the survivor owned and used the item prior to the disaster. There are

further eligibility requirements for each type of personal property. For

example, assistance for clothing line items is based on the number of

household members and the condition of disaster-damaged clothing. FEMA

verifies eligible personal property losses during the inspection, and the

program’s system generates the eligible award amount based on consumer

price index data.

Appendix II: Summary of Eligibility,

Verification, and Delivery Considerations for

Individuals and Households Program

Assistance

Page 109 GAO-20-503 Disaster Assistance

Type and description of assistance

Eligibility, verification, and delivery considerations

Transportation assistance. FEMA may provide

transportation assistance to applicants with disaster-

caused vehicle repair or replacement expenses for

certain vehicle types—such as cars and vans—or

other types as approved for the declaration, such as

motorcycles and boats. Assistance is usually limited

to one vehicle sustaining serious damages.

However, when household circumstances require

more than one vehicle, FEMA considers whether to

provide additional assistance.

To receive assistance, FEMA may verify damages during the inspection.

Otherwise, the applicant must submit

• a copy of the vehicle registration valid at the time of the disaster,

• a

description of damages for all vehicle(s) owned (year, make, and model).

and

• proof of liability insurance coverage or a statement that insurance

coverage does not exist.

For repair, applicants provide documentation from the mechanic that

confirms the damage is disaster caused, identifies repair costs, and includes

the mechanic’s contact information. For replacement, applicants may provide

a similar bill, or documentation from a state or local agency to confirm that

the vehicle was towed or salvaged due to the disaster and was not available.

Any additional vehicles would be required to meet all applicable conditions of

eligibility, as described above. Additionally, the applicant must certify in

writing that the damaged vehicle is essential for the household’s daily usage,

and outline the relevant circumstances for additional vehicles, among other

things.

The maximum amount of transportation assistance varies according to the

states’ decisions and whether the vehicle can be repaired or needs to be

replaced. For example, the transportation repair amounts ranged from a low

of $550 to a high of $9,425, and replacement ranged from a low of $4,000 to

a high of $9,425 for the catastrophic hurricanes in 2017 and 2018.

Moving and storage. Financial assistance for

moving and storage covers expenses for storing

certain personal property—such as appliances and

furniture—to help households avoid additional

damage during home repairs.

To be eligible for moving and storage assistance, the FEMA inspection

needs to determine that the home is not habitable due to the disaster. To

receive assistance, the applicant must submit documents showing the dates

and costs for moving and storage expenses and provide a statement

detailing the reasons the expenses were required, a description of the

personal property, and other details.

Group flood insurance policy. To reduce future

flood expenses, FEMA directly buys National Flood

Insurance Program coverage for applicants when

FEMA requires a flood insurance policy as a

condition of assistance. FEMA may pay up to $600

for 3 years for individuals who may not be able to

purchase a policy.

FEMA verifies eligibility for the group flood insurance policy by identifying the

flood-damaged items during the inspection. Additionally, the residence must

be located in an identified flood hazard area, and the applicant must not be in

violation of a previous requirement to obtain and maintain flood insurance,

among other requirements.

Source: GAO summary of FEMA program guidance. | GAO-20-503

For a complete discussion of FEMA’s funeral assistance and eligibility considerations, see our report,

Disaster Response: Federal Assistance and Selected States and Territory Efforts to Identify Deaths

from 2017 Hurricanes, GAO-19-486 (Washington, D.C.: Sept. 13, 2019).

Appendix III: Outcomes in the Individuals and

Households Program by the Social

Vulnerability of an Applicant’s Community

Page 110 GAO-20-503 Disaster Assistance

Based on our analysis of the Federal Emergency Management Agency’s

(FEMA) Individuals and Households Program (IHP) applicant data, we

found that there are differences in approval rates, financial assistance

received, reasons for ineligibility, appeal rates, and time between key

events of the IHP financial assistance process for applicants living in the

least and most socially vulnerable communities. See figures 16-18 and

tables 8 and 9 below for our analysis of program outcomes by the social

vulnerability of an applicant’s community for major disaster declarations

that included Individual Assistance in U.S. states and Puerto Rico from

2016 through 2018.

See our supplemental materials for our full analysis of program outcomes for calendar

years 2016, 2017, and 2018, and selected major disasters in 2016 through 2018. GAO,

Supplemental Material for GAO-20-503: Select Disaster Profiles for FEMA’s Individuals

and Households Program 2016-2018, GAO-20-674SP (Washington, D.C.; September

2020); and Supplemental Material for GAO-20-503: FEMA Individuals and Households

Program Applicant Data 2016-2018, GAO-20-675SP (Washington, D.C.; September

2020).

Appendix III: Outcomes in the Individuals

and Households Program by the Social

Vulnerability of an Applicant’s Community

Appendix III: Outcomes in the Individuals and

Households Program by the Social

Vulnerability of an Applicant’s Community

Page 111 GAO-20-503 Disaster Assistance

Figure 16: Referred Applicants and Approval Rates for the Individuals and Households Program (IHP), by Social Vulnerability,

for Major Disaster Declarations That Included Individual Assistance in U.S. States and Puerto Rico, 2016 – 2018

Note: The Centers for Disease Control and Prevention’s Social Vulnerability Index indicates the

relative social vulnerability of census tracts in the U.S. and Puerto Rico. Census tracts are

subdivisions of counties for which the U.S. Census Bureau collects statistical data through the

American Community Survey. The index ranks tracts on 15 variables, including unemployment,

minority status, and disability, and groups them into four themes and an overall ranking. For example,

the housing and transportation theme measures, among other things, the number of mobile homes,

buildings with 10 or more housing units, and households with no vehicle. The index is a 0 to 1 scale,

with higher scores indicating greater vulnerability. The least-vulnerable tracts had a score of .25 or

less, and the most-vulnerable tracts had a score of greater than .75. We could not identify a tract for

less than 1 percent of referred applicants in U.S. states and 4 percent of referred applicants in Puerto

Rico.

Financial IHP Assistance

Approval Rates

Appendix III: Outcomes in the Individuals and

Households Program by the Social

Vulnerability of an Applicant’s Community

Page 112 GAO-20-503 Disaster Assistance

Figure 17: Average Award Amounts and Number of Owners and Renters Who Received Financial Assistance through the

Individual and Households Program (IHP), by Social Vulnerability, for Major Disaster Declarations That Included Individual

Assistance in U.S. States and Puerto Rico, 2016 – 2018