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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations for Congress

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FEMA’s Individuals and Households Program
November 3, 2022May 15, 2023
(IHP)—Implementation and Considerations for Elizabeth M. Webster
Congress
Analyst in Emergency Analyst in Emergency
Management and Disaster Management and Disaster
The Federal Emergency Management Agency (FEMA) may provide several forms of federal The Federal Emergency Management Agency (FEMA) may provide several forms of federal
Recovery Recovery
assistance, if authorized pursuant to a presidential declaration of emergency or major disaster assistance, if authorized pursuant to a presidential declaration of emergency or major disaster

under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act; P.L. under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act; P.L.
93-288,93-288, as amended; codified at 42 U.S.C. §§5121 et seq.), including assistance for individuals as amended; codified at 42 U.S.C. §§5121 et seq.), including assistance for individuals

and households to recover—known as Individual Assistance (IA). and households to recover—known as Individual Assistance (IA).
There are various forms of IA that can help affected individuals and households recover from a disaster. This report provides There are various forms of IA that can help affected individuals and households recover from a disaster. This report provides
an overview of the Individuals and Households Program (IHP), a form of IA authorized under Stafford Act Section 408 (42 an overview of the Individuals and Households Program (IHP), a form of IA authorized under Stafford Act Section 408 (42
U.S.C. §5174). The IHP is the only form of IA, and the only FEMAU.S.C. §5174). The IHP is the only form of IA, and the only FEMA assistance authorized pursuant to assistance authorized pursuant to a an emergency or major disaster declaration, disaster declaration,
that provides grants of financial assistance directly to individuals and households to support their disaster recovery (FEMA that provides grants of financial assistance directly to individuals and households to support their disaster recovery (FEMA
may also provide direct assistance under the IHP). To that end, IHP assistance may include financial and/or direct assistance may also provide direct assistance under the IHP). To that end, IHP assistance may include financial and/or direct assistance
for housing and financial assistance for other needs to eligible individuals and households who have uninsured or under-for housing and financial assistance for other needs to eligible individuals and households who have uninsured or under-
insured necessary expenses and serious needs as a result of a disaster that cannot be met through other means or forms of insured necessary expenses and serious needs as a result of a disaster that cannot be met through other means or forms of
assistance. Specifically, this report describes the categories and types of available IHP Housing Assistance assistance. Specifically, this report describes the categories and types of available IHP Housing Assistance a ndand Other Needs Other Needs
Assistance (ONA), as well as the considerations or limitations associated with the provision of each form of IHP assistance, Assistance (ONA), as well as the considerations or limitations associated with the provision of each form of IHP assistance,
and IHP assistance generally. It also provides some specific examples when IHP assistance was implemented to support the and IHP assistance generally. It also provides some specific examples when IHP assistance was implemented to support the
recovery from recent disasters, including the Coronavirus Disease 2019 (COVID-19)recovery from recent disasters, including the Coronavirus Disease 2019 (COVID-19) pandemic. pandemic.
State, territory, and Indian tribal governments do not automatically receive IA when a disaster occurs. Instead, the governor State, territory, and Indian tribal governments do not automatically receive IA when a disaster occurs. Instead, the governor
of an affected state or territory or the chief executive of an affected Indian tribal government must request that the President of an affected state or territory or the chief executive of an affected Indian tribal government must request that the President
declare an emergency or major disaster and that IA be authorized. When making such a request, the state, declare an emergency or major disaster and that IA be authorized. When making such a request, the state, territ oryterritory, or Indian , or Indian
tribal government must demonstrate that the incident exceeds its capacity to effectively respond without federal assistance. tribal government must demonstrate that the incident exceeds its capacity to effectively respond without federal assistance.
FEMA then evaluates the request using set factors, and provides a recommendation to the President, who determines whether FEMA then evaluates the request using set factors, and provides a recommendation to the President, who determines whether
to authorize the request for a Stafford Act declaration authorizing IA. The process by which requests for IA are evaluated, to authorize the request for a Stafford Act declaration authorizing IA. The process by which requests for IA are evaluated,
and the way aspects of the IHP are implemented, changed in 2018 and 2019. These changes were made through the and the way aspects of the IHP are implemented, changed in 2018 and 2019. These changes were made through the
enactment of the Disaster Recovery Reform Act of 2018 (DRRA, Division D of P.L. 115-254),enactment of the Disaster Recovery Reform Act of 2018 (DRRA, Division D of P.L. 115-254), a new rule going into effect a new rule going into effect
(which updated the IA factors FEMA evaluates when considering a governor’s request for a major disaster declaration (which updated the IA factors FEMA evaluates when considering a governor’s request for a major disaster declaration
authorizing IA), and updates to FEMA’s IA guidance, including the authorizing IA), and updates to FEMA’s IA guidance, including the Individual Assistance Program and Policy Guide
(IAPPG)
. In addition to an overview of IHP assistance, this report discusses the process for requesting IA, the factors . In addition to an overview of IHP assistance, this report discusses the process for requesting IA, the factors
considered when determining whether to authorize IA (and specifically IHP assistance), and significant program considered when determining whether to authorize IA (and specifically IHP assistance), and significant program
implementation updates and considerations. implementation updates and considerations.
Finally, this report discusses some of the potential IHP-related challenges and considerations that may be of interest to Finally, this report discusses some of the potential IHP-related challenges and considerations that may be of interest to
Congress, including considerations for increasing transparency associated with FEMA’s IA factors evaluation, which is part Congress, including considerations for increasing transparency associated with FEMA’s IA factors evaluation, which is part
of the disaster declaration process; addressing the current lack of IHP assistance cost data, which is needed to support an of the disaster declaration process; addressing the current lack of IHP assistance cost data, which is needed to support an
evaluation of the cost of IHP assistance; and assessing whether FEMA’s current IHP assistance programs are sufficient to evaluation of the cost of IHP assistance; and assessing whether FEMA’s current IHP assistance programs are sufficient to
meet the needs of future disaster survivors. Other program-related challenges are also addressed, including application meet the needs of future disaster survivors. Other program-related challenges are also addressed, including application
requirements linking FEMA assistance with the Small Business Administration’s Disaster Loan Program, a requirement that requirements linking FEMA assistance with the Small Business Administration’s Disaster Loan Program, a requirement that
has hindered access to disaster assistance for some individualshas hindered access to disaster assistance for some individuals . .

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Contents
Introduction ..................................................................................................................................... 1
Overview of Stafford Act Section 408—Federal Assistance to Individuals and
Households ................................................................................................................................... 3
Housing Assistance ................................................................................................................... 4
Financial Housing Assistance ............................................................................................. 5
Direct Housing Assistance .................................................................................................. 9
Legislative Changes and Significant Program Updates: Housing Assistance .................. 12
Other Needs Assistance ........................................................................................................... 13
SBA-Dependent ONA ...................................................................................................... 14
Non-SBA-Dependent ONA .............................................................................................. 18
Legislative Changes and Significant Program Updates: ONA ......................................... 21
Approving Requests for Individual Assistance ............................................................................. 21 22
FEMA’s Evaluation of the IA Factors: Major Disaster ........................................................... 23
Recent IA Legislation, Rulemaking, and Guidance .......................................................... 23
IA Factors .......................................................................................................................... 24 24
Evaluating the Need for IHP Assistance: Governor’s Request for a Major Disaster ........ 25
Implementing IHP Assistance ....................................................................................................... 28
Applying for IHP Assistance ................................................................................................... 28 Registration Period......... 28
Registration Period ................................................................................................... 28
Applicant Eligibility .......................................................................................................... 29
Appealing FEMA’s Decisions Regarding IHP Assistance ...................................................... 32
Recoupment of Improper Payments and Requests for Waivers Waivers Requirements ............................................ 33
General IHP Limitations ......................................................................................................... 35....... 34
Limitations on What IHP Assistance Covers .......................................................................... 34 35
Limitations on the Period of Availability ................................................................................ 35 36
Limitations Related to Avoiding a Duplication of Benefits .................................................... 39 40
IHP Challenges and Congressional Considerations ...................................................................... 40 41
Increasing Transparency Regarding FEMA’s Evaluation of Requests for Major
Disaster Declarations Authorizing IA—IHP ........................................................................ 40 41
Expanding Access to Data to Track the Cost of IHP Assistance ............................................. 42 43
Ensuring IHP Assistance Can Meet Future Disaster Survivors’ Needs—Including
Following Incidents with Economic Consequences ............................................................ 45 46
Closing Considerations .................................................................................................................. 48

Figures
Figure 1. FEMA Direct Temporary Housing Assistance Options Sequence of Delivery .............. 10
Figure 2. FEMA and SBA Screening Process ............................................................................... 16
Figure 3. IA Programs and Consideration Factors ........................................................................ 25
Figure 4. Potential for IHP Approval based on a comparison of the Estimated Cost of IHP
Assistance and the ICC Ratio ..................................................................................................... 27 27

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Tables
Table 1. Types of Housing Assistance and Other Needs Assistance ............................................... 4
Table 2. Individual Assistance Factors for States/Territories and Tribes ....................................... 24
Table 3. Eligibility for Types of Housing Assistance .................................................................... 30
Table 4. Time- and Financial-Based Limitations on IHP Assistance Programs ......................... 37

... 36 Table A-1. IA Factors for a Governor’s Major Disaster Declaration Request Authorizing
IA ................................................................................................................................................ 57 59
Table A-2. IA Factors for a Chief Executive’s Major Disaster Declaration Request
Authorizing IA ..................................................................................................................... 60...... 58
Table B-1. Roles of the Federal and State/Territory/Indian Tribal Governments in IHP
Administration ............................................................................................................................ 60 61
Table C-1. Data Fields Associated with Each IA OpenFEMA Dataset ...................................... 64... 63

Appendixes
Appendix A. Overview of the Factors Considered when Evaluating a Governor or Chief
Executive’s Request for IA .............................................................................................. 50........... 49
Appendix B. IHP Roles of the Federal and State/Territory/Tribal Governments ........................ 61.. 60
Appendix C. Individual Assistance OpenFEMA Datasets and Data Fields .................................. 62 63

Contacts
Author Information ........................................................................................................................ 68 69


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Introduction
After the President issues an emergency or major disaster declaration under the Robert T. Stafford After the President issues an emergency or major disaster declaration under the Robert T. Stafford
Disaster Relief and Emergency Assistance Act (Stafford Act), the Federal Emergency Disaster Relief and Emergency Assistance Act (Stafford Act), the Federal Emergency
Management Agency (FEMA) may provide three primary forms of disaster assistance: Individual Management Agency (FEMA) may provide three primary forms of disaster assistance: Individual
Assistance (IA), Public Assistance (PA), and Hazard Mitigation Assistance (HMA).1 Assistance (IA), Public Assistance (PA), and Hazard Mitigation Assistance (HMA).1
IA provides aid to affected individuals and households, and can take the form of assistance for IA provides aid to affected individuals and households, and can take the form of assistance for
housing and/or other needs through the Individuals and Households Program (IHP).2 In addition housing and/or other needs through the Individuals and Households Program (IHP).2 In addition
to providing IHP assistance, FEMA’s IA program includes the Crisis Counseling Assistance and to providing IHP assistance, FEMA’s IA program includes the Crisis Counseling Assistance and
Training Program;3 Disaster Unemployment Assistance;4 Disaster Legal Services;5 and Disaster Training Program;3 Disaster Unemployment Assistance;4 Disaster Legal Services;5 and Disaster
Case Management,6 Case Management,6 al all of which are beyond the scope of this report.7 The IHP and other forms of of which are beyond the scope of this report.7 The IHP and other forms of
IA are funded through the Disaster Relief Fund (DRF), which is managed by FEMA.8 IA are funded through the Disaster Relief Fund (DRF), which is managed by FEMA.8
The IHP is the focus of this report. It is the only form of IA, and the only FEMA assistance The IHP is the focus of this report. It is the only form of IA, and the only FEMA assistance
authorized pursuant to authorized pursuant to aan emergency or major disaster declaration, that provides grants of financial assistance directly disaster declaration, that provides grants of financial assistance directly
to individualsto individuals and households to support their disaster recovery by helping address housing and and households to support their disaster recovery by helping address housing and
other needs (FEMA may also provide direct assistance for housing under the IHP). This report other needs (FEMA may also provide direct assistance for housing under the IHP). This report
begins with an overview of the IHP, including the categories and types of IHP begins with an overview of the IHP, including the categories and types of IHP assistanc eassistance that may that may
be made available,be made available, selected considerations or limitations associated with each type of assistance, selected considerations or limitations associated with each type of assistance,
and selected legislativeand selected legislative and program updates. This report then outlines the process for requesting and program updates. This report then outlines the process for requesting
and authorizing IA, including the factors that FEMA considers when evaluating a governor or and authorizing IA, including the factors that FEMA considers when evaluating a governor or
chief executive’s request for a major disaster declaration chief executive’s request for a major disaster declaration authorizing IA (these factors are
described in more detail in Appendix A).9 Other IA administrative information, including the

1 Disaster Relief1 Disaster Relief Act of 1974 (P.L. 93-288) (retitled the Robert TAct of 1974 (P.L. 93-288) (retitled the Robert T . Stafford Disaster Relief and Emergency Assistance . Stafford Disaster Relief and Emergency Assistance
Act and codified,Act and codified, as amended, at 42 U.S.C.as amended, at 42 U.S.C. §§5121§§5121 et seq.). et seq.). T heThe Robert T Robert T . Stafford Disaster Relief. Stafford Disaster Relief and Emergency and Emergency
Assistance ActAssistance Act is hereinafter referred to as the Stafford Act. is hereinafter referred to as the Stafford Act. T heThe Federal Emergency Management Agency’s (FEMA’s) Federal Emergency Management Agency’s (FEMA’s)
“How a Disaster Gets“How a Disaster Gets Declared” Declared” webpage, web page, available at https://www.fema.gov/disasters/how-declared,available at https://www.fema.gov/disasters/how-declared, provides provides
additional information on the declaration process and the types of assistance that may be authorized pursuant to a additional information on the declaration process and the types of assistance that may be authorized pursuant to a
presidential declaration of emergency or major disaster (hereinafter FEMA, “presidential declaration of emergency or major disaster (hereinafter FEMA, “ How a Disaster GetsHow a Disaster Gets Declared”). Declared”). T heThe
IndividualIndividual Assistance (IA) program, and specifically the IndividualsAssistance (IA) program, and specifically the Individuals and Householdsand Households Program (IHP), is the focus of this Program (IHP), is the focus of this
report. For information on FEMA’s other programs, including the Publicreport. For information on FEMA’s other programs, including the Public Assistance (PA) program, which may provide Assistance (PA) program, which may provide
grants to sub-federalgrants to sub-federal governments and certain private nonprofit organizations for emergency work following an governments and certain private nonprofit organizations for emergency work following an
emergency or major disasteremergency or major disaster declaration, and permanent work following a major disaster declaration, seedeclaration, and permanent work following a major disaster declaration, see CRS CRS In Focus In Focus
IF11529, IF11529, A Brief Overview of FEMA’s Public Assistance Program Program, by Erica A. Lee, and CRS, by Erica A. Lee, and CRS Report R46749, Report R46749, FEMA’s
Public Assistance Program : A Prim er: A Primer and Considerations for Congress
, by Erica A. Lee. For additional information on , by Erica A. Lee. For additional information on
FEMA’s Hazard Mitigation Assistance (HMA) fundsFEMA’s Hazard Mitigation Assistance (HMA) funds for mitigation and resiliency projects and programs to reducefor mitigation and resiliency projects and programs to reduce the the
threat or impacts of future disasters, see CRSthreat or impacts of future disasters, see CRS Insight IN11187, Insight IN11187, Federal Em ergencyEmergency Management Agency (FEMA)
Hazard Mitigation Assistance
, by Diane P. Horn. , by Diane P. Horn.
2 Stafford Act Section 408—Federal Assistance to Individuals 2 Stafford Act Section 408—Federal Assistance to Individuals and Householdsand Households (hereinafter referred to as the IHP)(hereinafter referred to as the IHP) —is —is
codifiedcodified at 42 U.S.C.at 42 U.S.C. §5174 and the citation to the U.S. Code is§5174 and the citation to the U.S. Code is used used hereinafter. IHP assistance may be authorized hereinafter. IHP assistance may be authorized
pursuant to either an emergency or major disaster declaration. pursuant to either an emergency or major disaster declaration.
3 Stafford Act Section 416, 42 U.S.C.3 Stafford Act Section 416, 42 U.S.C. §5183. §5183.
4 Stafford Act Section 410, 42 U.S.C.4 Stafford Act Section 410, 42 U.S.C. §5177. §5177.
5 Stafford Act Section 415, 42 U.S.C.5 Stafford Act Section 415, 42 U.S.C. §5182. §5182.
6 Stafford Act Section 426, 42 U.S.C.6 Stafford Act Section 426, 42 U.S.C. §5189d. §5189d.
7 7 T heseThese other forms of IA other forms of IA, with the exception of Crisis Counseling, may only be authorized pursuant to a major disaster declaration. may only be authorized pursuant to a major disaster declaration.
8 FEMA publishes The IHP and Crisis Counseling may be authorized pursuant to either an emergency or major disaster declaration (42 U.S.C. §5192(a)(6) (authorizing the President to provide assistance in accordance with 42 U.S.C. §5174 (IHP) and 42 U.S.C. §5183 (Crisis Counseling)). 8 FEMA publishes monthly reports with information on the Disaster Relief Fundmonthly reports with information on the Disaster Relief Fund (DRF) and available funding.(DRF) and available funding. See See
FEMA, “Disaster Relief Fund:FEMA, “Disaster Relief Fund: Monthly Reports,” https://www.fema.gov/about/reports-and-data/disaster-relief-fund-Monthly Reports,” https://www.fema.gov/about/reports-and-data/disaster-relief-fund-
monthly-reports. For more information on the DRF and its history, see CRSmonthly-reports. For more information on the DRF and its history, see CRS Report R45484, Report R45484, The Disaster Relief Fund:
Overview and Issues
, by William L. Painter. , by William L. Painter.
9 For information on the Public Assistance (PA) factors considered when evaluating a governor or chief executive’s
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authorizing IA (these factors are described in more detail in Appendix A).9 Other IA administrative information, including the application process for individuals and households, application process for individuals and households, eligibility eligibility requirements, and how assistance requirements, and how assistance
decisions may be appealed, is also included. This report concludes by describing some of the decisions may be appealed, is also included. This report concludes by describing some of the
IHP’s general program limitations, as IHP’s general program limitations, as wel well as selected as selected chal engeschallenges and considerations that may be and considerations that may be
of interest to Congress, including related to increasing transparency in IA declaration decisions, of interest to Congress, including related to increasing transparency in IA declaration decisions,
expanding access to IHP spending data, and ensuring IHP assistance can meet the needs of future expanding access to IHP spending data, and ensuring IHP assistance can meet the needs of future
disaster survivors. disaster survivors. Additional y,Additionally, Appendix B details the roles of the state/territory and federal details the roles of the state/territory and federal
government in providing IHP assistance,government in providing IHP assistance, and and Appendix C provides an overview of FEMA’s provides an overview of FEMA’s
publicly availablepublicly available IHP program data. IHP program data.

Selected Definitions
State:: Per Stafford Act Section 102(4), the termPer Stafford Act Section 102(4), the term “state” means “any State of the United States, the District“state” means “any State of the United States, the District of of
Columbia, Puerto Rico, the Virgin Islands, Guam, AmericanColumbia, Puerto Rico, the Virgin Islands, Guam, American Samoa, and the CommonwealthSamoa, and the Commonwealth of the Northern of the Northern
Mariana Islands” (42 U.S.C.Mariana Islands” (42 U.S.C. §5122(4)). §5122(4)).
Governor: Per Stafford Act Section 102(5), the term: Per Stafford Act Section 102(5), the term “governor”“governor” means “the chief executive of any State” (42 means “the chief executive of any State” (42
U.S.C.U.S.C. §5122(5)). §5122(5)).
Indian Tribal Government:: Per Stafford Act Section 102(6), the termPer Stafford Act Section 102(6), the term “Indian tribal government” means “the “Indian tribal government” means “the
governing body of any Indian orgoverning body of any Indian or Alaska Native tribe,Alaska Native tribe, band, nation, pueblo, vil age, or community that the Secretary band, nation, pueblo, vil age, or community that the Secretary
of the Interior acknowledgesof the Interior acknowledges to exist as an Indian tribe under the to exist as an Indian tribe under the Federal y Federally Recognized Indian Tribe List Act of Recognized Indian Tribe List Act of
1994 (25 U.S.C. §§479a et seq.)” (42 U.S.C. §5122(6)). 1994 (25 U.S.C. §§479a et seq.)” (42 U.S.C. §5122(6)).
Chief Executive:: Per Stafford Act Section 102(12), the termPer Stafford Act Section 102(12), the term “Chief Executive” means “the person who is the “Chief Executive” means “the person who is the
Chief, Chairman, Governor,Chief, Chairman, Governor, President,President, or similaror similar executive official of an Indian tribal government” (42 U.S.C. executive official of an Indian tribal government” (42 U.S.C.
§5122(12)).§5122(12)).
Uninhabitable
:: FEMA’s FEMA’s IAPPG defines “uninhabitable” as “a defines “uninhabitable” as “a dwel ingdwelling that is not safe, sanitary, or fit to occupy” that is not safe, sanitary, or fit to occupy”
(FEMA, (FEMA, IAPPG, p. 78)., p. 78).
Safe: FEMA’s : FEMA’s IAPPG defines “safe” as being secure from disaster-caused hazards or threats to occupants (FEMA, defines “safe” as being secure from disaster-caused hazards or threats to occupants (FEMA,
IAPPG, p. 78). , p. 78).
Sanitary: FEMA’s : FEMA’s IAPPG defines “sanitary” as being free of disaster-caused health hazards (FEMA, defines “sanitary” as being free of disaster-caused health hazards (FEMA, IAPPG, p. 78). , p. 78).
Functional:: FEMA also requiresFEMA also requires that disaster-damaged components be functional prior to the disaster. that disaster-damaged components be functional prior to the disaster.
“‘Functional’ refers“‘Functional’ refers to an itemto an item or home capable of being used for its intended purpose” (FEMA, or home capable of being used for its intended purpose” (FEMA, IAPPG, p. 78). , p. 78).




9 For information on the Public Assistance (PA) factors considered when evaluating a governor or chief executive’s request for a major disaster declaration, see 44 C.F.R.request for a major disaster declaration, see 44 C.F.R. §206.48(a) and FEMA’s §206.48(a) and FEMA’s Tribal Declarations Pilot Guidance, ,
January 2017, pp. 34-36, https://www.fema.gov/sites/default/files/2020-04/tribal-declaration-pilot-guidance.pdf January 2017, pp. 34-36, https://www.fema.gov/sites/default/files/2020-04/tribal-declaration-pilot-guidance.pdf
(hereinafter FEMA, (hereinafter FEMA, Tribal Declarations Pilot Guidance). ).
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Overview of Stafford Act Section 408—Federal
Assistance to Individuals and Households

Following an incident, the President may Following an incident, the President may
Emergency Declarations Authorizing IA
authorize the IHP10 and authorize the IHP10 and al owallow FEMA FEMA to to
The President may declare The President may declare an emergencyan emergency under the under the
provide financial and/or direct assistance provide financial and/or direct assistance for
Stafford Act when federal assistance is necessary to save Stafford Act when federal assistance is necessary to save
for housing, as housing, as wel well as financial assistance as financial assistance for
lives lives and protect public health and safety. Although the and protect public health and safety. Although the
for other needs (referred to as Other Needs other needs (referred to as Other Needs
President may authorize IA pursuant to an emergency or President may authorize IA pursuant to an emergency or
major major disaster declaration, the IHP is disaster declaration, the IHP is the only form of IAone of only two
Assistance or ONA) to eligible Assistance or ONA) to eligible individuals individuals
forms of IA that may be authorized pursuant to an that may be authorized pursuant to an emergency
and households. The IHP only covers
declaration. According to FEMA, however, it is
uninsured or under-insured necessary
uncommon for IA-IHP to be authorized pursuant to an
expenses and serious needs resulting from the emergency declaration.
disaster that cannot be otherwise met.11 IHP
The IHP has been authorized pursuant to an emergency
assistance is intended to meet basic needs
and households. The IHP only covers emergency declaration (Crisis Counseling may also be uninsured or under-insured necessary authorized pursuant to an emergency) (42 U.S.C. expenses and serious needs resulting from §5192(a)(6)). the disaster that cannot be otherwise met.11 According to FEMA, it is uncommon for IA-IHP to be IHP assistance is intended to meet basic authorized pursuant to an emergency declaration. The IHP needs (e.g., repairing a home to make it has been authorized pursuant to an emergency declaration three timesdeclaration three times since 1985. Most recently,since 1985. Most recently, the Florida Surfside safe to occupy12 or replacing standard the
Florida Surfside Building Col apseBuilding Col apse (3560-EM-FL) received a presidential household appliances like refrigerators13)— emergency declaration authorizing IA-IHP on June 25, and is not designed to return primary 2021. Prior (3560-EM-FL) received
(e.g., repairing a home to make it safe to
a presidential emergency declaration authorizing IA-IHP
occupy12 or replacing standard household
on June 25, 2021. Prior to that, the Texas Explosion
appliances like refrigerators13)—and is not
(EM-3363-TX) received a presidential declaration of
designed to return primary residences or
emergency to that, the Texas Explosion (EM-3363-TX) residences or property to their pre-disaster received a presidential declaration of emergency on April 19, 2013, for which IHP assistance on April 19, 2013, for which IHP assistance
property to their pre-disaster condition. As
was added on May 1, was added on May 1, condition. As such, per FEMA’s guidance, 2013, and Connecticut received2013, and Connecticut received a
presidential declaration of emergency for Hurricane
such, per FEMA’s guidance, “IHP assistance
Irene (EM-3331-CT) on August 27, 2011, for which IHP
is not a substitute for insurance and cannot
assistance was added on September 2, 2011. According
compensate for al losses caused by a
to FEMA, these are the only emergencies a presidential declaration “IHP assistance is not a substitute for of emergency for Hurricane Irene (EM-3331-CT) on insurance and cannot compensate for all August 27, 2011, for which IHP assistance was added on losses caused by a disaster.... ”14 September 2, 2011. According to FEMA, these are the only emergencies for which the IHP has been authorized from The IHP is authorized under Stafford Act for which the
disaster.... ”14
IHP has been authorized from January 1, 1985 to January 1, 1985 to
December December 6, 2021.6, 2021.
The IHP is authorized under Stafford Act Section 408—Federal Assistance to
(FEMA, “Florida (FEMA, “Florida Surfside Building Col apseSurfside Building Col apse (3560-EM-FL),” Individuals and Households.15 The (3560-EM-
Section 408—Federal Assistance to
FL),” https://www.fema.gov/disaster/3560; FEMA, “Texas https://www.fema.gov/disaster/3560; FEMA, “Texas
Individuals and Households.15 Thesubcategories of Housing Assistance and
Explosion (EM-3363-TX),” https://www.fema.gov/ Explosion (EM-3363-TX),” https://www.fema.gov/
subcategories of Housing Assistance and
disaster/3363; FEMA, “Connecticut Hurricane Irene disaster/3363; FEMA, “Connecticut Hurricane Irene
(EM-3331-CT),” (EM-3331- ONA, as well as the types of IHP CT),” https://www.fema.gov/disaster/3331; https://www.fema.gov/disaster/3331;
email assistance under each subcategory, are ONA, as wel as the types of IHP assistance
email correspondence fromcorrespondence from FEMA CongressionalFEMA Congressional Affairs
under each subcategory, are listed in Affairs staff, listed in Table 1.
staff, December 6, 2021).

December 6, 2021). 10 42 U.S.C.10 42 U.S.C. §5174; 44 C.F.R.§5174; 44 C.F.R. §206.110(a); and Federal Emergency Management Agency (FEMA), §206.110(a); and Federal Emergency Management Agency (FEMA), Individual
Assistance Program and Policy Guide (IAPPG)
, v. 1.1, FP 104-009-03, May 2021, pp. 6 and 41, , v. 1.1, FP 104-009-03, May 2021, pp. 6 and 41,
https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf (hereinafter FEMA, https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf (hereinafter FEMA, IAPPG). In March 2019, ). In March 2019,
FEMA releasedFEMA released updated guidanceupdated guidance to serve as a comprehensive IA program policy resource: the to serve as a comprehensive IA program policy resource: the Individual Assistance
Program and Policy Guide (IAPPG)
applies to emergencies and disasters applies to emergencies and disasters declared declared on or after March 1, 2019. It was on or after March 1, 2019. It was
subsequentlysubsequently updated in May 2021, and Versionupdated in May 2021, and Version 1.1 applies to incidents declared1.1 applies to incidents declared on or after May 26, 2021. on or after May 26, 2021. T heThe IAPPG
includesincludes a chapter dedicated to IHP implementation and administration. Prior to the release of the a chapter dedicated to IHP implementation and administration. Prior to the release of the IAPPG, the , the
Individuals and Households Program Unified Guidance (IHPUG) served as the policy guide served as the policy guide for the IHP. for the IHP. T heThe IHPUG
applies to incidents declaredapplies to incidents declared on or after September 26, 2016, through February 28, 2019. For additional information on on or after September 26, 2016, through February 28, 2019. For additional information on
FEMA’s IndividualFEMA’s Individual Assistance (IA) program, see CRSAssistance (IA) program, see CRS In Focus IF11298, In Focus IF11298, A Brief Overview of FEMA’s Individual
Assistance Program
, by Elizabeth M. Webster. , by Elizabeth M. Webster.
11 42 U.S.C. 11 42 U.S.C. §5174; 44 C.F.R.§5174; 44 C.F.R. §206.110(a); and FEMA, §206.110(a); and FEMA, IAPPG, p. 41. , p. 41.
12 FEMA, 12 FEMA, IAPPG, p. 85. , p. 85.
13 FEMA, 13 FEMA, IAPPG, p. 167. , p. 167.
14 FEMA, 14 FEMA, IAPPG, pp. 6 and 41. , pp. 6 and 41.
15 42 U.S.C.15 42 U.S.C. §5174. §5174.
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Table 1. Types of Housing Assistance and Other Needs Assistance
Housing Assistance:
Housing Assistance:
ONA:
ONA:
Financial
Direct
SBA-Dependenta
Non-SBA-Dependentb
Lodging Expense Lodging Expense
Multi-Family Lease Multi-Family Lease and and
Personal Property Personal Property
Funeral Assistance Funeral Assistance
Reimbursement Reimbursement
Repair Repair
Assistance Assistance
Medical and Dental Medical and Dental
Rental Assistance Rental Assistance
Transportable Temporary Transportable Temporary
Transportation Assistance Transportation Assistance
Assistance Assistance
Home Home Repair Assistance Repair Assistance
Housing Units Housing Units
Group Flood Insurance Group Flood Insurance
Childcare Assistance Childcare Assistance
Home Home Replacement Replacement
Direct Direct Lease Lease
Policy Policy
Assistance Assistance for for
Assistance Assistance
Permanent Housing Permanent Housing
Miscel aneous Miscellaneous Items Items
Construction Construction
Moving and Storage Moving and Storage
Assistance Assistance
Critical Needs Assistance Critical Needs Assistance
Clean and Sanitize Clean and Sanitize
Assistance Assistance
Sources: CRS’s interpretation of “Figure 5: Housing Assistance”CRS’s interpretation of “Figure 5: Housing Assistance” and “Figure 28: Other Needs Assistance,and “Figure 28: Other Needs Assistance, Non-Non-
SBA-Dependent and SBA-Dependent” of theSBA-Dependent and SBA-Dependent” of the FEMA, FEMA, Individual Assistance Program and Policy Guide (IAPPG), v. 1.1, , v. 1.1,
FP 104-009-03, May 2021, pp. 44 and 146, https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf; FP 104-009-03, May 2021, pp. 44 and 146, https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf;
and Memorandum fromand Memorandum from Keith Turi, FEMA Assistant Administrator,Keith Turi, FEMA Assistant Administrator, Recovery Directorate Recovery Directorate to FEMA Regional to FEMA Regional
Administrators,Administrators, “RE: Amendment to FP 104-009-03, Individual Assistance Program and Policy Guide, Version “RE: Amendment to FP 104-009-03, Individual Assistance Program and Policy Guide, Version
1.1,” September1.1,” September 2, 2021, pp. 11-12, https://www.fema.gov/sites/default/files/documents/fema_iappg-policy-2, 2021, pp. 11-12, https://www.fema.gov/sites/default/files/documents/fema_iappg-policy-
amendments-memo.pdf. amendments-memo.pdf.
Notes: The different types of Housing AssistanceThe different types of Housing Assistance may constitute either financial or direct assistance; however, may constitute either financial or direct assistance; however,
al all types of Other Needs Assistancetypes of Other Needs Assistance (ONA) are forms of financial assistance. The term “SBA” refers(ONA) are forms of financial assistance. The term “SBA” refers to the to the Smal
Small BusinessBusiness Administration. Administration.
a. SBA-Dependent ONA is only available to individuals or households that do not qualify for an SBA disaster a. SBA-Dependent ONA is only available to individuals or households that do not qualify for an SBA disaster
loan or whose SBA disaster loan amount is insufficient. Eligibility loan or whose SBA disaster loan amount is insufficient. Eligibility for SBA-Dependent ONA is determined by for SBA-Dependent ONA is determined by
FEMA in col aboration with SBA (see 42 U.S.C.FEMA in col aboration with SBA (see 42 U.S.C. §5174(e); and 44 C.F.R. §206.119). §5174(e); and 44 C.F.R. §206.119).
b. Non-SBA-Dependent ONA may be awarded regardless b. Non-SBA-Dependent ONA may be awarded regardless of the individual or household’s SBA disasterof the individual or household’s SBA disaster loan loan
status (see 42 U.S.C. status (see 42 U.S.C. §5174(e); and 44 C.F.R. §206.119).§5174(e); and 44 C.F.R. §206.119).
More detailed descriptions of these IHP assistance options, as More detailed descriptions of these IHP assistance options, as wel well as programmatic changes as programmatic changes
following the enactment of the Disaster Recovery Reform Act of 2018 (DRRA, Division D of following the enactment of the Disaster Recovery Reform Act of 2018 (DRRA, Division D of
P.L. 115-254), are described in the sections that follow. P.L. 115-254), are described in the sections that follow.
Housing Assistance
FEMA has many different types of housing assistance that it can employ, depending on the FEMA has many different types of housing assistance that it can employ, depending on the
disaster-caused housing needs of affected individuals and households. Options may include disaster-caused housing needs of affected individuals and households. Options may include
Financial Housing Assistance (i.e., a grant of money) and/or Direct Housing Assistance (i.e., a Financial Housing Assistance (i.e., a grant of money) and/or Direct Housing Assistance (i.e., a
place to live temporarily). Per FEMA’s regulations and place to live temporarily). Per FEMA’s regulations and IAPPG guidance, the appropriate type of guidance, the appropriate type of
housing assistance depends on considerations of “cost effectiveness, convenience to the housing assistance depends on considerations of “cost effectiveness, convenience to the
individualsindividuals and households and the suitability and availabilityand households and the suitability and availability of the types of assistance.”16 Other of the types of assistance.”16 Other
relevant considerations relate to the individualrelevant considerations relate to the individual or household’s “disaster-caused losses, access to or household’s “disaster-caused losses, access to
life-sustaining services, cost-effectiveness, and other factors.”17 life-sustaining services, cost-effectiveness, and other factors.”17

16 44 C.F.R. §206.110(c). 16 44 C.F.R. §206.110(c).
17 FEMA, 17 FEMA, IAPPG, p. 43. See, p. 43. See also 44 C.F.R. §206.117(b). With regard to other factors, for example, some forms of IHP also 44 C.F.R. §206.117(b). With regard to other factors, for example, some forms of IHP
assistance consider access to wrap-around services, which FEMA states in its guidanceassistance consider access to wrap-around services, which FEMA states in its guidance may includemay includebasic social basic social
services, access to transportation, police/fire protection, emergency/health care services, communications, utilities, services, access to transportation, police/fire protection, emergency/health care services, communications, utilities,
grocery stores, child care, and educational institutions” (FEMA, grocery stores, child care, and educational institutions” (FEMA, IAPPG, p. 117). According to its guidance,, p. 117). According to its guidance, “FEMA
“FEMA (continued...) Congressional Research Service Congressional Research Service

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In addition, individuals and households may require multiple types of housing assistance when a In addition, individuals and households may require multiple types of housing assistance when a
disaster affects their home’s habitability.18 For example, a household may need to use FEMA’s disaster affects their home’s habitability.18 For example, a household may need to use FEMA’s
Rental Assistance program to temporarily rent alternative accommodations while repairs are Rental Assistance program to temporarily rent alternative accommodations while repairs are
made to their primary residence through FEMA’s Home Repair Assistance program. (Households made to their primary residence through FEMA’s Home Repair Assistance program. (Households
are referred to because IHP assistance may be limited based on people’s specific living are referred to because IHP assistance may be limited based on people’s specific living
arrangements (e.g., if they are members of a family, roommates, or boarders).19) arrangements (e.g., if they are members of a family, roommates, or boarders).19)
FEMA first looks to provide financial assistance such FEMA first looks to provide financial assistance such
Defining “Cost Share”
as Rental Assistance and Repair Assistance before as Rental Assistance and Repair Assistance before
A cost share includes the portions of a federal A cost share includes the portions of a federal
providing other types of housing assistance.20 In providing other types of housing assistance.20 In
assistance program borne by the federal assistance program borne by the federal
some cases, FEMA may authorize a state, territory, or some cases, FEMA may authorize a state, territory, or government and a nonfederal entity (2 C.F.R. government and a nonfederal entity (2 C.F.R.
Indian tribal government’s request for Direct Indian tribal government’s request for Direct
§§200.29 and 200.306). The nonfederal entity §§200.29 and 200.306). The nonfederal entity
may contribute cash or use third party in-kind may contribute cash or use third party in-kind
Housing Assistance when eligible applicants are Housing Assistance when eligible applicants are
contributions to meet contributions to meet its portion of the cost its portion of the cost
unable to use Rental Assistance because affordable unable to use Rental Assistance because affordable
share (per the criteria share (per the criteria in 2 C.F.R. §200.306). in 2 C.F.R. §200.306).
housing resources are unavailable.21 housing resources are unavailable.21
By statute, the federal government pays 100% By statute, the federal government pays 100%
of the cost associated with providing IHP
The federal share of the costs of IHP Housing The federal share of the costs of IHP Housing
of the cost associated with providing IHP Housing Assistance.Housing Assistance. The federalThe federal government government
Assistance is 100%.22 Assistance is 100%.22
pays 75% of the cost associated with providing pays 75% of the cost associated with providing
IHP ONA, and the nonfederal share of ONA is IHP ONA, and the nonfederal share of ONA is
Financial Housing Assistance
paid from funds made available by the state, paid from funds made available by the state,
territory,territory, or Indian tribal government (42 or Indian tribal government (42
Financial Housing Assistance is a grant provided Financial Housing Assistance is a grant provided
U.S.C. U.S.C. §5174(g); and 44 C.F.R. §206.110(i)). §5174(g); and 44 C.F.R. §206.110(i)).
directly to the individual directly to the individual or household by FEMA, or household by FEMA,
Although the Stafford Act does not provide the Although the Stafford Act does not provide the
and includes funding for temporary lodging expenses and includes funding for temporary lodging expenses
authority to adjust the federal share of ONA authority to adjust the federal share of ONA
(i.e., Lodging Expense Reimbursement (LER)), (42 U.S.C. (42 U.S.C. §5174(g)(2)), FEMA may waive or §5174(g)(2)), FEMA may waive or
(i.e., Lodging Expense Reimbursement (LER)),
adjust the cost share for disasteradjust the cost share for disaster grants in grants in
rental of temporary housing (i.e., Rental Assistance), rental of temporary housing (i.e., Rental Assistance),
insular areas such as the Virgin Islands, Guam, insular areas such as the Virgin Islands, Guam,
and to repair or replace a damaged primary residence and to repair or replace a damaged primary residence
American American Samoa, and the NorthernSamoa, and the Northern Mariana Mariana
(i.e., Repair Assistance and Replacement Assistance, (i.e., Repair Assistance and Replacement Assistance,
Islands (48 U.S.C. Islands (48 U.S.C. §1469a).

will §1469a). will not provide Direct not provide Direct T emporaryTemporary Housing Assistance in locations where disaster survivors will Housing Assistance in locations where disaster survivors will not have access to not have access to
wrap-around services” (FEMA, wrap-around services” (FEMA, IAPPG, p. 117). For example, this applies to FEMA’s evaluation of Multi-Family , p. 117). For example, this applies to FEMA’s evaluation of Multi-Family
Lease and Repair (MLR) properties (FEMA, Lease and Repair (MLR) properties (FEMA, IAPPG, p. 110), as well, p. 110), as well as site selection for as site selection for T ransportable T emporary
Housing Units (T T HUsTransportable Temporary Housing Units (TTHUs) (FEMA, ) (FEMA, IAPPG, pp. 114 and 116). , pp. 114 and 116).
18 42 U.S.C. 18 42 U.S.C. §5174(b) and (c); 44 C.F.R. §206.110(c); and FEMA, §5174(b) and (c); 44 C.F.R. §206.110(c); and FEMA, IAPPG, pp. 78 and 93. FEMA’s , pp. 78 and 93. FEMA’s IAPPG defines defines
“uninhabitable” as “a dwelling“uninhabitable” as “a dwelling that is not safe, sanitary, or fit to occupy.” (FEMA, that is not safe, sanitary, or fit to occupy.” (FEMA, IAPPG, p. 78). , p. 78).
19 FEMA, 19 FEMA, IAPPG, pp. 57-62. Per FEMA’s guidance,, pp. 57-62. Per FEMA’s guidance, “Generally, FEMA provides all eligible“Generally, FEMA provides all eligible IHP awardsIHP awards under only under only
the head of household’s application to assist all members of the pre-disaster household. Only the head of household the head of household’s application to assist all members of the pre-disaster household. Only the head of household
willwill be eligible be eligible for additional categories of IHP assistance” (FEMA, for additional categories of IHP assistance” (FEMA, IAPPG, p. 57). , p. 57).
20 44 C.F.R. §206.110(c). FEMA’s Financial Housing Assistance programs can be20 44 C.F.R. §206.110(c). FEMA’s Financial Housing Assistance programs can be implemented using existing implemented using existing
resources (e.g., Rental Assistance can help a household temporarily rent available alternative accommodations), but resources (e.g., Rental Assistance can help a household temporarily rent available alternative accommodations), but
FEMA’s Direct HousingFEMA’s Direct Housing Assistance programs requireAssistance programs require additional coordination with the affected state, territory, or additional coordination with the affected state, territory, or
Indian tribal government and overhead/administration support (e.g., FEMA may need to lease properties and make any Indian tribal government and overhead/administration support (e.g., FEMA may need to lease properties and make any
neededneeded repairs or improvements to ensure accessibility). repairs or improvements to ensure accessibility).
21 FEMA, 21 FEMA, IAPPG, p. 94. Direct , p. 94. Direct T emporaryTemporary Housing Assistance may be approved if the following Housing Assistance may be approved if the following three fact ors three factors have have
been verified, per FEMA’s been verified, per FEMA’s IAPPG: (1) a lack of available housing: (1) a lack of available housing prevents eligible applicants from making useprevents eligible applicants from making use of of
Rental Assistance; (2) increasing the Rental Assistance rate to 125% of the U.S. Department of Housing and Urban Rental Assistance; (2) increasing the Rental Assistance rate to 125% of the U.S. Department of Housing and Urban
Development’s (HUD’s) Fair Market Rent (FMR) willDevelopment’s (HUD’s) Fair Market Rent (FMR) will be insufficient to meet the disaster-causedbe insufficient to meet the disaster-caused housing needs;housing needs; and and
(3) assistance from providers, including(3) assistance from providers, including other federal and nonfederal government sources, as wellother federal and nonfederal government sources, as well as nonprofit and as nonprofit and
voluntary organizations, is insufficient to meet eligible applicants’ disaster-causedvoluntary organizations, is insufficient to meet eligible applicants’ disaster-caused temporary housing needs. temporary housing needs.
22 42 U.S.C.22 42 U.S.C. §5174(g)(1); 44 C.F.R. §206.110(i)(1); and FEMA, §5174(g)(1); 44 C.F.R. §206.110(i)(1); and FEMA, IAPPG, p. 5. For more information on cost shares, see , p. 5. For more information on cost shares, see
CRSCRS Report R41101, Report R41101, FEMA Disaster Cost-Shares: Evolution and Analysis, by Natalie Keegan, by Natalie Keegan and Elizabeth M. and Elizabeth M.
Webster. Webster.
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respectively).23 Brief descriptions of the types of Financial Housing Assistance, and select respectively).23 Brief descriptions of the types of Financial Housing Assistance, and select
considerations or limitations associated with each type of assistance, are included below.24 considerations or limitations associated with each type of assistance, are included below.24
Lodging Expense Reimbursement (LER)
LER provides LER provides funding for out-of-pocket hotel, motel, or other short-term temporary lodging funding for out-of-pocket hotel, motel, or other short-term temporary lodging
costs, including taxes, when the applicant is displaced from their primary residence because the costs, including taxes, when the applicant is displaced from their primary residence because the
declared disaster affected its habitability or accessibility (i.e., it cannot be entered). Two of the declared disaster affected its habitability or accessibility (i.e., it cannot be entered). Two of the
limitations on LER Assistance include (1) assistance is not to exceed seven days from the limitations on LER Assistance include (1) assistance is not to exceed seven days from the
approved date of an Initialapproved date of an Initial Rental Assistance award (unless an extension is authorized); and (2) Rental Assistance award (unless an extension is authorized); and (2)
expenses incurred during mandatory evacuations are not reimbursable.25 expenses incurred during mandatory evacuations are not reimbursable.25
Rental Assistance
Rental Assistance Rental Assistance providesprovides funding to applicants to funding to applicants to
Defining “Fair Market Rent”
rent alternative temporary housing rent alternative temporary housing
44 C.F.R. 44 C.F.R. §206.111 defines Fair Market Rent §206.111 defines Fair Market Rent
accommodations (including funding for monthly accommodations (including funding for monthly
(FMR) as “housing market-wide (FMR) as “housing market-wide estimates estimates of of
rent, essential utilities, and a security deposit) rent, essential utilities, and a security deposit)
rents that provide opportunities to rent standard rents that provide opportunities to rent standard
while the applicant is displaced from their primary while the applicant is displaced from their primary
quality housing throughout the geographic area in quality housing throughout the geographic area in
which rental housing units are in competition. which rental housing units are in competition.
residence because it is uninhabitable, inaccessible, residence because it is uninhabitable, inaccessible,
The fair market rent rates applied are those The fair market rent rates applied are those
affected by a utility outage, or unavailable. FEMA affected by a utility outage, or unavailable. FEMA
identified by the Department of Housing and identified by the Department of Housing and
may provide up to two months of Initial Rental may provide up to two months of Initial Rental
Urban Development Urban Development as being adequate for as being adequate for
Assistance. Awards are based on (1) the number of Assistance. Awards are based on (1) the number of
existing rental housing in a particular area.” existing rental housing in a particular area.”
required bedrooms, as established by the U.S. required bedrooms, as established by the U.S.
Department of Housing and Urban Development (HUD); and (2) the Fair Market Rent (FMR) Department of Housing and Urban Development (HUD); and (2) the Fair Market Rent (FMR)
where the pre-disaster residence is located. This is the case regardless of whether the where the pre-disaster residence is located. This is the case regardless of whether the
individual/householdindividual/household is renting in the same area or an area with higher rental costs.26 is renting in the same area or an area with higher rental costs.26
Unlike Unlike Initial Rental Assistance, Continued Temporary Housing Assistance (a continuation of Initial Rental Assistance, Continued Temporary Housing Assistance (a continuation of
Rental Assistance) is based on the location of the post-disaster housing unit, and the assistance Rental Assistance) is based on the location of the post-disaster housing unit, and the assistance
rate may be increased in accordance with HUD FMR.27rate may be increased in accordance with HUD FMR.27

Rental Assistance, including both Initial Rental Assistance and Continued Temporary Housing Assistance, may be provided “for a total of 18 months or until the end of the 18-month period of 23 FEMA, 23 FEMA, IAPPG, pp. 43 and 78. , pp. 43 and 78.
24 24 T heThe FEMA FEMA IAPPG, beginning, beginning on page 78, lists additional conditions of applicant eligibility, eligibleon page 78, lists additional conditions of applicant eligibility, eligible expenses, expenses,
requiredrequired documentation, program limitations and exclusions, and exceptions for each type of Financial Housing documentation, program limitations and exclusions, and exceptions for each type of Financial Housing
Assistance. Assistance.
25 FEMA, 25 FEMA, IAPPG, pp. 78-79. , pp. 78-79.
26 FEMA, 26 FEMA, IAPPG, p. 80. , p. 80. T heThe FEMA FEMA IAPPG states “FEMA uses states “FEMA uses the applicable [FMR] rate basedthe applicable [FMR] rate based upon the location of upon the location of
the housing unit, the number of bedrooms in the housing unit, and the fiscal year in whichthe housing unit, the number of bedrooms in the housing unit, and the fiscal year in which the major disaster the major disaster
declaration wasdeclaration was issued.”issued.” (FEMA, (FEMA, IAPPG, p. 109 (see “Fair Market Rent (FMR)” text box), p. 109 (see “Fair Market Rent (FMR)” text box))..) FEMA uses FEMA uses its FMR its FMR
Calculator to evaluate the need for a Rental Assistance rate increase, and may authorize a rate increase “Calculator to evaluate the need for a Rental Assistance rate increase, and may authorize a rate increase “ when the FMR when the FMR
Calculator demonstrates available housingCalculator demonstrates available housing for the area is insufficient to meet the disasterfor the area is insufficient to meet the disaster -caused housing-caused housing need, or when need, or when
elevated housingelevated housing market rates adversely impact eligiblemarket rates adversely impact eligible applicants’ ability to applicants’ ability to o btainobtain rental resources” (FEMA, rental resources” (FEMA, IAPPG, ,
p. 85). HUD’s Office of Policy Development and Research (PD&R) posts FMR information at p. 85). HUD’s Office of Policy Development and Research (PD&R) posts FMR information at
https://www.huduser.gov/portal/datasets/fmr.html. https://www.huduser.gov/portal/datasets/fmr.html.
27 FEMA, 27 FEMA, IAPPG, p. 81. Applicants for Continued , p. 81. Applicants for Continued T emporaryTemporary Housing Assistance must submit Housing Assistance must submit an application for an application for
continued assistance, along with supporting documentation. continued assistance, along with supporting documentation. T heyThey must have a continuing need for assistance and must must have a continuing need for assistance and must
be unablebe unable to return to their pre-disaster residence, and adequateto return to their pre-disaster residence, and adequate alternate housing must bealternate housing must be unavailable or they must not unavailable or they must not
have fulfilledhave fulfilled their permanent housing plan through no fault of their own. 44 C.F.R.their permanent housing plan through no fault of their own. 44 C.F.R. §206.114 includes the criteria for §206.114 includes the criteria for
continued assistance. continued assistance.
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Rental Assistance, including both Initial Rental Assistance and Continued Temporary Housing
Assistance, may be provided “for a total of 18 months or until the end of the 18-month period of
assistance, whichever comes first,” unless the period of assistance is extended.28 In addition, assistance, whichever comes first,” unless the period of assistance is extended.28 In addition,
applicants can receive an additionalapplicants can receive an additional month of rent when used for a security deposit.29 month of rent when used for a security deposit.29
Home Repair Assistance
Home Repair Assistance Home Repair Assistance providesprovides funding to funding to
Maximum IHP Housing Award
homeowners to repair homeowners to repair an owner-occupied primary an owner-occupied primary
In FY2023, the maximum amount of financial In FY2023, the maximum amount of financial
residence, utilities, and residential infrastructure residence, utilities, and residential infrastructure
assistance for housing is $41,000 (adjusted assistance for housing is $41,000 (adjusted
(e.g., privately-owned access routes).30 The (e.g., privately-owned access routes).30 The
annual yannually). Financial assistance to rent alternative ). Financial assistance to rent alternative
objective of Home Repair Assistance is to make the objective of Home Repair Assistance is to make the
housing accommodations does not count housing accommodations does not count
towards the housing assistance cap, and towards the housing assistance cap, and
disaster survivors’ home “safe, sanitary, or disaster survivors’ home “safe, sanitary, or
exempted from the housing assistance cap are exempted from the housing assistance cap are
functional.”31 Two limitations on Home Repair functional.”31 Two limitations on Home Repair
accessibility-related accessibility-related repair or replacement costs. repair or replacement costs.
Assistance include (1) it is subject to the maximum Assistance include (1) it is subject to the maximum
(DHS/FEMA, “Notice of Maximum Amount of (DHS/FEMA, “Notice of Maximum Amount of
amount of financial assistance for housing, with amount of financial assistance for housing, with
Assistance Assistance Under the Individuals and Households Under the Individuals and Households
some exemptions (described below); and (2) it is some exemptions (described below); and (2) it is
Program,” Program,” 87 87 Federal Register 64512, October 25, 64512, October 25,
not intended to improve or even to return the not intended to improve or even to return the
2022, https://www.govinfo.gov/content/pkg/FR- 2022, https://www.govinfo.gov/content/pkg/FR-
2022-10-25/pdf/2022-23162.pdf.)
primary residence to its pre-disaster condition, with primary residence to its pre-disaster condition, with
2022-10-25/pdf/2022-23162.pdf.) the exceptions of making reasonable hazard the exceptions of making reasonable hazard
mitigation measures to make the home more resilient (described below) or improvements as mitigation measures to make the home more resilient (described below) or improvements as
required to conform with current local building code requirements or ordinances.32 required to conform with current local building code requirements or ordinances.32
FEMA’s guidance specifies some accessibility-related items as being eligible FEMA’s guidance specifies some accessibility-related items as being eligible for Home Repair for Home Repair
Assistance. Assistance. Specifical ySpecifically, per the , per the IAPPG, disaster-damaged grab bars and an access ramp are , disaster-damaged grab bars and an access ramp are
eligibleeligible for Home Repair Assistance, and are exempted from the maximum amount of financial for Home Repair Assistance, and are exempted from the maximum amount of financial
assistance for housing.33 assistance for housing.33 Additional yAdditionally, in September 2021, FEMA amended its Home Repair , in September 2021, FEMA amended its Home Repair
Assistance policy to extend eligibilityAssistance policy to extend eligibility for accessibility-related real property items to people with for accessibility-related real property items to people with
disaster-caused disabilities. Thus, FEMA disaster-caused disabilities. Thus, FEMA wil will now fund post-disaster accessibility-related items now fund post-disaster accessibility-related items
(i.e., these items were not damaged by the disaster because the homeowner did not have a (i.e., these items were not damaged by the disaster because the homeowner did not have a
disabilitydisability at the time of the disaster, but their disabilityat the time of the disaster, but their disability was caused by the disaster and they now was caused by the disaster and they now
have a need for accessibility items), includinghave a need for accessibility items), including:
an exterior ramp; an exterior ramp;
grab bars; and grab bars; and

• a paved path to the home’s entrance.34 28 FEMA, 28 FEMA, IAPPG, pp. 41, 80-81. FEMA can extend the IHP period of assistance at the written request of the affected , pp. 41, 80-81. FEMA can extend the IHP period of assistance at the written request of the affected
state, territory, or Indian tribal government. state, territory, or Indian tribal government.
29 FEMA, 29 FEMA, IAPPG, pp. 80-81. , pp. 80-81.
30 A non-exhaustive list of real property components that are eligible for repair is included30 A non-exhaustive list of real property components that are eligible for repair is included in the FEMAin the FEMA IAPPG on on
page 86. It includespage 86. It includes components such as the structural components of a home (e.g., foundation, exterior walls, roof). components such as the structural components of a home (e.g., foundation, exterior walls, roof).
Additionally, assistance to repair real property components impacted by disasterAdditionally, assistance to repair real property components impacted by disaster -caused-caused mold growth is eligiblemold growth is eligible for for
Home Repair Assistance (Memorandum from Keith Home Repair Assistance (Memorandum from Keith T uriTuri, FEMA Assistant Administrator, Recovery Directorate to , FEMA Assistant Administrator, Recovery Directorate to
FEMA Regional Administrators, “RE: Amendment to FP 104-009-03, Individual Assistance Program and Policy FEMA Regional Administrators, “RE: Amendment to FP 104-009-03, Individual Assistance Program and Policy
Guide,Guide, Version Version 1.1,” September 2, 2021, pp. 9-10, https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1,” September 2, 2021, pp. 9-10, https://www.fema.gov/sites/default/files/documents/fema_iappg-
policy-amendments-memo.pdf (hereinafter Memorandum from Keith policy-amendments-memo.pdf (hereinafter Memorandum from Keith T uriTuri RE: Amendment to the IAPPG) RE: Amendment to the IAPPG) ). ).
31 FEMA, 31 FEMA, IAPPG, p. 85. , p. 85.
32 FEMA, 32 FEMA, IAPPG, pp. 85-88. Repair Assistance for privately-owned access routes includes, pp. 85-88. Repair Assistance for privately-owned access routes includes additional eligibility additional eligibility
conditions, and limitations and exclusions (see FEMA, conditions, and limitations and exclusions (see FEMA, IAPPG, pp. 89-90 for details). , pp. 89-90 for details).
33 FEMA, 33 FEMA, IAPPG, p. 86. DRRA, p. 86. DRRA Section 1212 exempted accessibility-related repair costs from the financial assistance Section 1212 exempted accessibility-related repair costs from the financial assistance
cap. cap.
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 a paved path to the home’s entrance.34
The Home Repair Assistance provided for mitigation is limited. The Home Repair Assistance provided for mitigation is limited. Stil Still, repairs may include hazard , repairs may include hazard
mitigation measures that make the housing more resilient. mitigation measures that make the housing more resilient. Specifical ySpecifically, reasonable hazard , reasonable hazard
mitigation measures may be permitted, even if they improve upon a component’s pre-disaster mitigation measures may be permitted, even if they improve upon a component’s pre-disaster
condition. On June 10, 2021, FEMA announced that mitigation assistance provided for Home condition. On June 10, 2021, FEMA announced that mitigation assistance provided for Home
Repair Assistance for disasters declared on or after May 26, 2021 would “Repair Assistance for disasters declared on or after May 26, 2021 would “al owallow eligible eligible
homeowners ... [to] repair or rebuild stronger, more durable homes.” Per the agency’s homeowners ... [to] repair or rebuild stronger, more durable homes.” Per the agency’s
announcement, FEMA’s Home Repair Assistance announcement, FEMA’s Home Repair Assistance wil will include the following specific mitigation include the following specific mitigation
measures: measures:
Roof repair to withstand higher winds and help prevent water infiltration; Roof repair to withstand higher winds and help prevent water infiltration;
Elevating a water heater or furnace to avoid future flood damage; and Elevating a water heater or furnace to avoid future flood damage; and
Elevating or moving an electrical panel to avoid future flood damage.35 Elevating or moving an electrical panel to avoid future flood damage.35
FEMA also permits Home Repair Assistance to be used to address disaster-caused mold.36 FEMA also permits Home Repair Assistance to be used to address disaster-caused mold.36
Home Replacement Assistance
Home Replacement Assistance Home Replacement Assistance providesprovides funding to homeowners to help replace a disaster-funding to homeowners to help replace a disaster-
destroyed owner-occupied primary residence.37 Home Replacement Assistance is unavailable for destroyed owner-occupied primary residence.37 Home Replacement Assistance is unavailable for
non-traditional housing or residence types, such as tents, lean-to structures, yurts, and converted non-traditional housing or residence types, such as tents, lean-to structures, yurts, and converted
shipping containers.38 Funding for Home Replacement Assistance may be applied toward the shipping containers.38 Funding for Home Replacement Assistance may be applied toward the
purchase of a new permanent residence, even if the cost of the new permanent residence exceeds purchase of a new permanent residence, even if the cost of the new permanent residence exceeds
the maximum IHP housing award.39 the maximum IHP housing award.39
When FEMA’s Financial Housing Assistance programs are unable to meet the disaster-caused When FEMA’s Financial Housing Assistance programs are unable to meet the disaster-caused
housing needs of individuals and households, FEMA may authorize a state, territory, or Indian housing needs of individuals and households, FEMA may authorize a state, territory, or Indian
tribal government’s request for Direct Housing Assistance. This may be done when eligible tribal government’s request for Direct Housing Assistance. This may be done when eligible
applicants are unable to use Rental Assistance because affordable housing resources are applicants are unable to use Rental Assistance because affordable housing resources are
unavailable.40

34 Memorandum from Keith T uri RE: Amendment to the IAPPG, p. 10.
unavailable.40 35 FEMA’s guidance35 FEMA’s guidance details details the specific types of mitigation measures availablethe specific types of mitigation measures available for Hom e for Home Repair Assistance, and its Repair Assistance, and its
regulations and guidanceregulations and guidance impose limitations on the mitigation assistance that may be provided, includingimpose limitations on the mitigation assistance that may be provided, including that it may that it may
only be awardedonly be awarded for disaster-damagedfor disaster-damaged real property components that existed and were functional prior to the real property components that existed and were functional prior to the de clareddeclared
disaster (FEMA, “Hazard Mitigation Under the Individualsdisaster (FEMA, “Hazard Mitigation Under the Individuals and Householdsand Households Program,” release, June 10, 2021, Program,” release, June 10, 2021,
https://www.fema.gov/fact-sheet/hazard-mitigation-under-individuals-and-households-program; 44 C.F.R. §§206.111 https://www.fema.gov/fact-sheet/hazard-mitigation-under-individuals-and-households-program; 44 C.F.R. §§206.111
and 206.117(a), (b)(2)(i), (b)(2)(iii), and (b)(2)(iv); and FEMA, IAPPG, pp. 85and 206.117(a), (b)(2)(i), (b)(2)(iii), and (b)(2)(iv); and FEMA, IAPPG, pp. 85 -88). -88).
36 Memorandum from Keith 36 Memorandum from Keith T uriTuri RE: Amendment to the IAPPG, p. 9. RE: Amendment to the IAPPG, p. 9.
37 FEMA, 37 FEMA, IAPPG, p. 91. FEMA calculates the award, p. 91. FEMA calculates the award amount usingamount using the consumer price index data for the types of the consumer price index data for the types of
housing in the area where the damagehousing in the area where the damage occurred (the type of pre-disaster home could includeoccurred (the type of pre-disaster home could include a “a “ manufactured home, manufactured home,
travel trailer, houseboat, or residential construction (e.g., single-family home)”).travel trailer, houseboat, or residential construction (e.g., single-family home)”).
38 FEMA, 38 FEMA, IAPPG, p. 92. , p. 92.
39 FEMA, 39 FEMA, IAPPG, p. 91. , p. 91.
40 FEMA, 40 FEMA, IAPPG, p. 94. Direct , p. 94. Direct T emporaryTemporary Housing Assistance may be approved if the following Housing Assistance may be approved if the following three factors have three factors have
been verified, per FEMA’s been verified, per FEMA’s IAPPG: (1) a lack of available housing: (1) a lack of available housing prevents eligible applicants from making useprevents eligible applicants from making use of of
Rental Assistance; (2) increasing the Rental Assistance rate to 125% of the U.S. Department of Housing and Urban Rental Assistance; (2) increasing the Rental Assistance rate to 125% of the U.S. Department of Housing and Urban
Development’s (HUD’s) Fair Market Rent (FMR) willDevelopment’s (HUD’s) Fair Market Rent (FMR) will be insufficient to meet the disasterbe insufficient to meet the disaster -caused-caused housing needs;housing needs; and and
(3) assistance from providers, including(3) assistance from providers, including other federal and nonfederal government sources, as wellother federal and nonfederal government sources, as well as nonprofit and as nonprofit and
voluntary organizations, is insufficient to meet eligible applicants’ disaster-causedvoluntary organizations, is insufficient to meet eligible applicants’ disaster-caused temporary housing needs. temporary housing needs.
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link to page 14 link to page 14 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

Direct Housing Assistance
Direct Housing Assistance is housing provided to the individual Direct Housing Assistance is housing provided to the individual or household by FEMA or the or household by FEMA or the
state, territory, or Indian tribal government.41 There are two forms of Direct Housing Assistance: state, territory, or Indian tribal government.41 There are two forms of Direct Housing Assistance:
(1) Direct Temporary Housing Assistance, which includes Multi-Family Lease and Repair (1) Direct Temporary Housing Assistance, which includes Multi-Family Lease and Repair
(MLR), Transportable Temporary Housing Units (TTHUs), and Direct Lease; and (2) Permanent (MLR), Transportable Temporary Housing Units (TTHUs), and Direct Lease; and (2) Permanent
Housing Construction (PHC).42 Housing Construction (PHC).42
Direct Housing Assistance must be requested in writing by the affected state, territory, or tribe, Direct Housing Assistance must be requested in writing by the affected state, territory, or tribe,
and FEMA and FEMA wil will only authorize it when: only authorize it when:
1. Rental Assistance cannot be used by eligible 1. Rental Assistance cannot be used by eligible applicants due to insufficient applicants due to insufficient
available available housing resources; housing resources;
2. increasing the Rental Assistance rate to 125% of the HUD FMR 2. increasing the Rental Assistance rate to 125% of the HUD FMR wil will be be
insufficient to meet the housing needs; and insufficient to meet the housing needs; and
3. assistance from other providers (e.g., government and voluntary organizations) is 3. assistance from other providers (e.g., government and voluntary organizations) is
insufficient to meet the housing needs.43 insufficient to meet the housing needs.43
Unlike Unlike some forms of Financial Housing Assistance, Direct Housing Assistance is not subject to some forms of Financial Housing Assistance, Direct Housing Assistance is not subject to
the limitthe limit of the maximum amount of financial assistance an individual or household is eligibleof the maximum amount of financial assistance an individual or household is eligible to to
receive; however, other eligibilityreceive; however, other eligibility and programmatic limitations apply.44 and programmatic limitations apply.44
FEMA follows a sequence of delivery when determining which Direct Housing Assistance FEMA follows a sequence of delivery when determining which Direct Housing Assistance
options to implement. Per FEMA’s options to implement. Per FEMA’s IAPPG, this is based on “locations and numbers of eligible , this is based on “locations and numbers of eligible
applicants and the availability,applicants and the availability, feasibility, and cost-effectiveness of each option.”45 That sequence feasibility, and cost-effectiveness of each option.”45 That sequence
general ygenerally follows the order depicted i follows the order depicted in Figure 1. PHC, which is included at the end of the PHC, which is included at the end of the
sequence, may only be provided in insular areas and locations where other housing options are sequence, may only be provided in insular areas and locations where other housing options are
“unavailable, infeasible, or not cost-effective.”46 Brief descriptions of the types of Direct Housing “unavailable, infeasible, or not cost-effective.”46 Brief descriptions of the types of Direct Housing
Assistance, and selected considerations or limitations associated with each type of assistance, are Assistance, and selected considerations or limitations associated with each type of assistance, are
included below.47 included below.47

41 DRRA41 DRRA Section 1211(a) amended the Stafford Act to expand the types of FEMA IHP assistance that state, Section 1211(a) amended the Stafford Act to expand the types of FEMA IHP assistance that state, territor yterritory, ,
and Indian tribal governments may request to administer to include Direct and Indian tribal governments may request to administer to include Direct T emporaryTemporary Housing Assistance under Housing Assistance under
Section 408(c)(1)(B) and Permanent Housing Construction under Section 408(c)(4), in addition to Other Needs Section 408(c)(1)(B) and Permanent Housing Construction under Section 408(c)(4), in addition to Other Needs
Assistance under Section 408(e) (which state, territory, and Indian tribal governments were already permitted to Assistance under Section 408(e) (which state, territory, and Indian tribal governments were already permitted to
administer). On Julyadminister). On July 28, 2020, FEMA announced the publication of the 28, 2020, FEMA announced the publication of the State-Adm inisteredAdministered Direct Housing Grant
Guide
, available, available at https://www.fema.gov/sites/default/files/2020-07/fema_state-administered-directat https://www.fema.gov/sites/default/files/2020-07/fema_state-administered-direct -housing-grant-housing-grant --
guide_DRRA1211_July2020.pdf, which made guide_DRRA1211_July2020.pdf, which made st atestate, local, tribal and, local, tribal and territory governments eligible to receive grants to territory governments eligible to receive grants to
provide Direct Housingprovide Direct Housing Assistance for a limited period of time; this pilot grant program concluded on October 5, 2020. Assistance for a limited period of time; this pilot grant program concluded on October 5, 2020.
T heThe State-Adm inisteredAdministered Direct Housing Grant Guide states that FEMA will states that FEMA will implement a permanent grant program implement a permanent grant program
after issuingafter issuing final regulations. As of December 2021, FEMA has not yet begun the rulemaking final regulations. As of December 2021, FEMA has not yet begun the rulemaking pr ocessprocess (email (email
correspondence from FEMA Congressional Affairs staff, December 6, 2021).correspondence from FEMA Congressional Affairs staff, December 6, 2021).
42 FEMA, 42 FEMA, IAPPG, p. 93. , p. 93.
43 FEMA, 43 FEMA, IAPPG, p. 94., p. 94. HUD’s PD&R posts FMR information at https://www.huduser.gov/portal/datasets/fmr.html. HUD’s PD&R posts FMR information at https://www.huduser.gov/portal/datasets/fmr.html.
44 FEMA, 44 FEMA, IAPPG, p. 93. , p. 93.
45 FEMA, 45 FEMA, IAPPG, p. 95. According to a December 2020 U.S. Government Accountability Office (GAO) report, FEMA , p. 95. According to a December 2020 U.S. Government Accountability Office (GAO) report, FEMA
also considers the “convenience to individuals and householdsalso considers the “convenience to individuals and households and timeliness and availability of and timeliness and availability of o therother forms of forms of
assistance” (GAO,assistance” (GAO, Disaster Housing: Improved Cost Data and Guidance Would Aid FEMA Activation Decisions, ,
GAO-21-116, December 2020, pp. 5 and 10 (see footnotes 13 and 22), https://www.gao.gov/products/GAO-21-116 GAO-21-116, December 2020, pp. 5 and 10 (see footnotes 13 and 22), https://www.gao.gov/products/GAO-21-116
(hereinafter GAO, (hereinafter GAO, Disaster Housing: Im provedImproved Cost Data and Guidance)). )).
46 FEMA, 46 FEMA, IAPPG, pp. 93 and 95. , pp. 93 and 95.
47 47 T heThe FEMA FEMA IAPPG, beginning, beginning on page 93, lists additional conditions of applicant eligibility, program limitations and on page 93, lists additional conditions of applicant eligibility, program limitations and
exclusions, and considerations for each type of Direct Housingexclusions, and considerations for each type of Direct Housing Assistance.Assistance.
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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

Figure 1. FEMA Direct Temporary Housing Assistance Options Sequence of Delivery

Source: DevelopedDeveloped by CRS based on “Figure 22: Generalby CRS based on “Figure 22: General Sequence of FEMA Direct Housing Assistance Sequence of FEMA Direct Housing Assistance
Options” of the FEMA, Options” of the FEMA, Individual Assistance Program and Policy Guide (IAPPG), v. 1.1, FP 104-009-03, May 2021, p. , v. 1.1, FP 104-009-03, May 2021, p.
95, https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf. 95, https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf.
Notes: MLR stands for Multi-Family MLR stands for Multi-Family Lease and Repair; TTHUs stands for Transportable Temporary Housing Lease and Repair; TTHUs stands for Transportable Temporary Housing
Units; and PHC stands for Permanent Housing Construction. Units; and PHC stands for Permanent Housing Construction.
Multi-Family Lease and Repair (MLR)
MLR assistance temporarily places disaster survivors in a FEMA-leased, currently existing, MLR assistance temporarily places disaster survivors in a FEMA-leased, currently existing,
vacant multi-family housing unit (e.g., an apartment in a building that FEMAvacant multi-family housing unit (e.g., an apartment in a building that FEMA has leased; FEMA has leased; FEMA
must have exclusive use of the property for temporary housing for a period of not less than 18 must have exclusive use of the property for temporary housing for a period of not less than 18
months from the declaration date) that FEMA has repaired or improved, if needed (e.g., to make a months from the declaration date) that FEMA has repaired or improved, if needed (e.g., to make a
unit accessible).48 MLR is not intended to make repairs or improvements to multi-family housing unit accessible).48 MLR is not intended to make repairs or improvements to multi-family housing
units for the purpose of rehousing existing tenants.49 With regard to determining the eligibilityunits for the purpose of rehousing existing tenants.49 With regard to determining the eligibility of of
a property for MLR, there are several eligibilitya property for MLR, there are several eligibility requirements that must be met, including that the requirements that must be met, including that the
MLR-eligibleMLR-eligible property must be located in a county or jurisdiction designated for IA or, if there property must be located in a county or jurisdiction designated for IA or, if there
are no availableare no available properties in the area designated to receive IA, the MLR-eligibleproperties in the area designated to receive IA, the MLR-eligible property must property must
be in the same state or territory, located within reasonable commuting distance of the declared be in the same state or territory, located within reasonable commuting distance of the declared
area, and affected by the same incident.50 FEMA area, and affected by the same incident.50 FEMA wil will prioritize the use of MLR properties based prioritize the use of MLR properties based
on an evaluation of considerations, such as cost, time to complete repairs, proximity to wrap-on an evaluation of considerations, such as cost, time to complete repairs, proximity to wrap-
around services, and accessibility.51 around services, and accessibility.51
Transportable Temporary Housing Units (TTHUs)
TTHUs place disaster survivors in FEMA-purchased or leased temporary housing units (i.e., TTHUs place disaster survivors in FEMA-purchased or leased temporary housing units (i.e.,
Recreational Vehicles (RVs) or Manufactured Housing Units (MHUs)).52 TTHU sites must meet Recreational Vehicles (RVs) or Manufactured Housing Units (MHUs)).52 TTHU sites must meet

48 FEMA, 48 FEMA, IAPPG, p. 107., p. 107. FollowingFollowing Hurricane Sandy,Hurricane Sandy, Section 1103 of the Sandy Recovery Improvement Act of 2013 Section 1103 of the Sandy Recovery Improvement Act of 2013
(Division B(Division B of P.L. 113-2) formalized FEMA’s Multi-Family Lease and Repair (MLR) program. of P.L. 113-2) formalized FEMA’s Multi-Family Lease and Repair (MLR) program.
49 FEMA, 49 FEMA, IAPPG, p. 107. , p. 107.
50 DRRA50 DRRA Section 1213 amended Stafford Act Section 408(c)(1)(B)(ii)(I)(aa) to allow FEMA to enter into lease Section 1213 amended Stafford Act Section 408(c)(1)(B)(ii)(I)(aa) to allow FEMA to enter into lease
agreements with owners of multi-family rental properties “agreements with owners of multi-family rental properties “ impacted by a major disaster or located in areas covered by a impacted by a major disaster or located in areas covered by a
major disaster declaration.” Seemajor disaster declaration.” See also FEMA, also FEMA, IAPPG, pp. 107-108. , pp. 107-108.
51 FEMA, 51 FEMA, IAPPG, p. 110. , p. 110.
52 52 T he types of T ransportable T emporaryThe types of Transportable Temporary Housing Units ( Housing Units (T T HUsTTHUs) include Recreational Vehicles (RVs)) include Recreational Vehicles (RVs) or or
Manufactured HousingManufactured Housing Units (MHUs). MHUs are built to meet the construction and safety standards set forth by HUD Units (MHUs). MHUs are built to meet the construction and safety standards set forth by HUD
at 24 C.F.R.at 24 C.F.R. Part 3280. A manufactured home is definedPart 3280. A manufactured home is defined in 24 C.F.R.in 24 C.F.R. §3280.2 as “§3280.2 as “ ... a structure, transportable in one or ... a structure, transportable in one or
more sections ... and whichmore sections ... and which is built on a permanent chassis and designedis built on a permanent chassis and designed to be usedto be used as as a dwellinga dwelling with or without a with or without a
permanent foundation when connected to the required utilities.... ” permanent foundation when connected to the required utilities.... ” T heThe IAPPG provides additional information on the provides additional information on the
certification standards that FEMA-provided RVscertification standards that FEMA-provided RVs and MHUs must meet (FEMA, and MHUs must meet (FEMA, IAPPG, pp. 112-113; see 24 C.F.R. , pp. 112-113; see 24 C.F.R.
§§3280 et seq. for the Manufactured Home Construction and Safety Standards). §§3280 et seq. for the Manufactured Home Construction and Safety Standards).
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specific requirements that include (1) providing access to available and functional utilities;53 (2) specific requirements that include (1) providing access to available and functional utilities;53 (2)
complying with government ordinances; and (3) satisfying federal floodplain management and complying with government ordinances; and (3) satisfying federal floodplain management and
Environmental Planning and Historic Preservation (EHP) compliance review requirements.54 The Environmental Planning and Historic Preservation (EHP) compliance review requirements.54 The
IAPPG states that “FEMA selects locations based on the cost-effectiveness, timeliness, and states that “FEMA selects locations based on the cost-effectiveness, timeliness, and
suitability of each potential site,”55 and the suitability of each potential site,”55 and the IAPPG includes a complete list of requirements and includes a complete list of requirements and
considerations for the eligibilityconsiderations for the eligibility and prioritization of each site type.56 and prioritization of each site type.56
FEMA has the statutory authority to dispose of FEMA has the statutory authority to dispose of
TTHU Site Types
TTHUs via sale or donation when requested, in TTHUs via sale or donation when requested, in
Private Sites are provided at no cost to FEMA are provided at no cost to FEMA
writing, by the affected state, territory, or Indian writing, by the affected state, territory, or Indian
by the applicant ( by the applicant (usual yusually on the applicant’s on the applicant’s
tribal government when certain conditions are tribal government when certain conditions are
property); property);
met,57 including that a TTHU can be sold to its met,57 including that a TTHU can be sold to its
Commercial Sites al owallow FEMA to lease FEMA to lease
occupants if they lack permanent housing, or a occupants if they lack permanent housing, or a
available pads in an existing manufactured home available pads in an existing manufactured home
park; and
TTHU may be sold, transferred, donated, or made TTHU may be sold, transferred, donated, or made
available park; and available to a government entity or voluntary to a government entity or voluntary
Group Sites are provided by the state or local are provided by the state or local
government (e.g., publicly owned park land), and government (e.g., publicly owned park land), and
organization to enable them to continue providing organization to enable them to continue providing
are only considered are only considered when no other Direct when no other Direct
temporary housing to eligible temporary housing to eligible occupants who are occupants who are
Temporary Housing Assistance options can meet Temporary Housing Assistance options can meet
unable to afford to purchase the TTHU from unable to afford to purchase the TTHU from
the housing need. the housing need.
FEMA.58 FEMA.58
Direct Lease
Direct Lease places disaster survivors in FEMA-leased residential properties.59 To be eligible for Direct Lease places disaster survivors in FEMA-leased residential properties.59 To be eligible for
Direct Lease, (1) a property must be a residential property that is not Direct Lease, (1) a property must be a residential property that is not typical ytypically available available to the to the
general public (e.g., a vacation rental); and (2) the owner must permit permanent accessibility-general public (e.g., a vacation rental); and (2) the owner must permit permanent accessibility-
related modifications or improvements to be made.60 The related modifications or improvements to be made.60 The IAPPG includes a complete list of includes a complete list of
Direct Lease property compliance standards and prioritization considerations.61 Direct Lease property compliance standards and prioritization considerations.61
Permanent Housing Construction (PHC)
PHC is a last resort used to provide financial or direct assistance for permanent or semi- PHC is a last resort used to provide financial or direct assistance for permanent or semi-
permanent housing, and can include repairs or new home construction.62 permanent housing, and can include repairs or new home construction.62 Additional yAdditionally, per the , per the
IAPPG, PHC is only available, PHC is only available “in insular areas outside the continental U.S.” or “in other “in insular areas outside the continental U.S.” or “in other
locations where no alternative housing resources are available and other types of Temporary locations where no alternative housing resources are available and other types of Temporary

53 FEMA, 53 FEMA, IAPPG,, pp. 113-116. Utilities include available and functional sanitation, electrical service, and potable pp. 113-116. Utilities include available and functional sanitation, electrical service, and potable
water service. water service.
54 FEMA, 54 FEMA, IAPPG, p. 112. , p. 112.
55 FEMA, 55 FEMA, IAPPG, p. 112. , p. 112.
56 FEMA, 56 FEMA, IAPPG, pp. 113-116. , pp. 113-116.
57 42 U.S.C.57 42 U.S.C. §5174(d)(2); FEMA, §5174(d)(2); FEMA, IAPPG, p. 119 (see the considerations for authorizing the disposal of , p. 119 (see the considerations for authorizing the disposal of T T HUsTTHUs through through
salessales and donations). and donations).
58 42 U.S.C. 58 42 U.S.C. §5174(d)(2); see also FEMA, §5174(d)(2); see also FEMA, IAPPG, pp. 119-124. , pp. 119-124.
59 FEMA, 59 FEMA, IAPPG, p. 124. FEMA developed its Direct Lease program in 2017, and it has been implemented since 2018 , p. 124. FEMA developed its Direct Lease program in 2017, and it has been implemented since 2018
as a form of Direct as a form of Direct T emporaryTemporary Housing Assistance (email correspondence from FEMA Congressional Affairs staff, Housing Assistance (email correspondence from FEMA Congressional Affairs staff,
March 9, 2019). March 9, 2019).
60 FEMA, 60 FEMA, IAPPG, p. 125. , p. 125. T heThe ability to use stand-alone residential sites that are not typically available to the public ability to use stand-alone residential sites that are not typically available to the public
distinguishesdistinguishes Direct Lease from MLR (e.g., FEMA may leaseDirect Lease from MLR (e.g., FEMA may lease a vacation property when apartments are unavailable). a vacation property when apartments are unavailable).
61 FEMA, 61 FEMA, IAPPG, pp. 125-126. , pp. 125-126.
62 FEMA, 62 FEMA, IAPPG, p. 127. , p. 127.
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Housing Assistance are unavailable, infeasible or not cost-effective.”63 The Housing Assistance are unavailable, infeasible or not cost-effective.”63 The IAPPG details the details the
information that must be included in PHC requests, as information that must be included in PHC requests, as wel well as additional eligibilityas additional eligibility conditions and conditions and
assistance thresholds. For example, for PHC repairs, the real property verified loss amount must assistance thresholds. For example, for PHC repairs, the real property verified loss amount must
exceed $12 per square foot up to the disaster-specific financial cost cap, but the property has not exceed $12 per square foot up to the disaster-specific financial cost cap, but the property has not
been destroyed and repairs are more cost-effective than new construction; or, for PHC new been destroyed and repairs are more cost-effective than new construction; or, for PHC new
construction, the disaster destroyed the pre-disaster residence, or the real property verified loss construction, the disaster destroyed the pre-disaster residence, or the real property verified loss
amount exceeds $12 per square foot and the residence is repairable, but new construction is more amount exceeds $12 per square foot and the residence is repairable, but new construction is more
cost-effective.64 cost-effective.64
Legislative Changes and Significant Program Updates: Housing Assistance
Several sections of DRRA65 amended the Several sections of DRRA65 amended the
DRRA Separated the Maximum
provision of Housing Assistance under Stafford provision of Housing Assistance under Stafford
Awards for Housing Assistance and
Act Section 408. These statutory amendments Act Section 408. These statutory amendments
ONA
changed the implementation of IHP Housing changed the implementation of IHP Housing
Prior to DRRA’s enactment, the Stafford Act Prior to DRRA’s enactment, the Stafford Act
Assistance, and are reflected in the current Assistance, and are reflected in the current
imposed imposed a total limita total limit on the maximumon the maximum amount of amount of
IAPPG..
al all IHP financial assistance an individual or IHP financial assistance an individual or
household could receivehousehold could receive for a single disasterfor a single disaster (i.e., (i.e.,
Allowance of State-Administered
housing assistance and ONA combined to count housing assistance and ONA combined to count
Direct Housing Assistance (DRRA
towards the cap). towards the cap).
Section 1211)—State Administration of —State Administration of
DRRA Section 1212 created two separate limits DRRA Section 1212 created two separate limits on on
Assistance for Direct Temporary Housing Assistance for Direct Temporary Housing
the financial assistance eligible the financial assistance eligible individuals and individuals and
and Permanent Housing Construction— households may receive:households may receive: one for housing assistance one for housing assistance
and Permanent Housing Construction—
and one for ONA. and one for ONA. Additional y, Additionally, DRRA exempted DRRA exempted
al owsallows state, territory, and Indian tribal state, territory, and Indian tribal
some some forms of assistance that previouslyforms of assistance that previously counted counted
governments to administer the provision governments to administer the provision
towards the limit. towards the limit. Thus, post-DRRA, financial Thus, post-DRRA, financial
of Direct Temporary Housing Assistance of Direct Temporary Housing Assistance
assistance for housing-related needs may not assistance for housing-related needs may not
(i.e., MLR, TTHUs, and Direct Lease) (i.e., MLR, TTHUs, and Direct Lease)
exceed $41,000 (FY2023; adjusted exceed $41,000 (FY2023; adjusted annual yannually), and ), and
financial assistance for ONA may not exceed financial assistance for ONA may not exceed
and Permanent Housing Construction, in and Permanent Housing Construction, in
$41,000 (FY2023; adjusted annual y). $41,000 (FY2023; adjusted annual y).
addition to ONA.66 addition to ONA.66
The enactment of DRRA Section 1212 effectively The enactment of DRRA Section 1212 effectively

Increase Maximum IHP Award increased the amount of financial assistance an increased the amount of financial assistance an
Increase Maximum IHP Award
Amounts (DRRA Section 1212) individual or household could be eligible individual or household could be eligible to receive to receive
Amounts (DRRA Section 1212)
Assistance to Individuals and through the IHP. through the IHP.
Assistance to Individuals andHouseholds—established separate caps of
(DHS/FEMA, “Notice of Maximum Amount of (DHS/FEMA, “Notice of Maximum Amount of
Households—established separate caps of Assistance Assistance Under the Individuals and Households Under the Individuals and Households
equal amounts for the maximum amount equal amounts for the maximum amount
Program,” Program,” 87 87 Federal Register 64512, October 25, 64512, October 25,
of financial assistance eligible of financial assistance eligible individuals individuals
2022, https://www.govinfo.gov/content/pkg/FR- 2022, https://www.govinfo.gov/content/pkg/FR-
and households may receive for Financial and households may receive for Financial
2022-10-25/pdf/2022-23162.pdf.) 2022-10-25/pdf/2022-23162.pdf.)

63 FEMA, 63 FEMA, IAPPG, p. 127. According to the , p. 127. According to the IAPPG, Guam, the Commonwealth of the Northern Mariana Islands, , Guam, the Commonwealth of the Northern Mariana Islands,
American Samoa, and the U.S.American Samoa, and the U.S. Virgin Islands Virgin Islands are insularare insular areas, and the Alaskan interior is an example of a remote area areas, and the Alaskan interior is an example of a remote area
(FEMA, (FEMA, IAPPG, p. 76). , p. 76). Unavailable means temporary housing options are unavailable for a reasonable cost or in a means temporary housing options are unavailable for a reasonable cost or in a
reasonable amount of time. reasonable amount of time. Infeasible means there are no available rental housing resources, or forms of Direct means there are no available rental housing resources, or forms of Direct
T emporaryTemporary Housing Assistance cannot be used Housing Assistance cannot be used because because of various challenges (e.g., distance, time delays), which of various challenges (e.g., distance, time delays), which
FEMA cannot overcome with reasonable means. FEMA cannot overcome with reasonable means. Not cost-effective means the provision of other forms of Direct means the provision of other forms of Direct
T emporaryTemporary Housing Assistance would Housing Assistance would cost more than providing PHC. cost more than providing PHC.
64 FEMA, 64 FEMA, IAPPG, p. 141. , p. 141.
65 For more information on DRRA, see CRS65 For more information on DRRA, see CRS Report R46776, Report R46776, The Disaster Recovery Reform Act of 2018 (DRRA):
Im plem entationImplementation Updates for Select Provisions
, coordinated by Elizabeth M. Webster and Bruce, coordinated by Elizabeth M. Webster and Bruce R. LindsayR. Lindsay , and CRS , and CRS
Report R45819, Report R45819, The Disaster Recovery Reform Act of 2018 (DRRA): A Sum m arySummary of Selected Statutory Provisions, ,
coordinated by Elizabeth M. Webster and Brucecoordinated by Elizabeth M. Webster and Bruce R. Lindsay. R. Lindsay.
66 DRRA66 DRRA Section 1211(a). PostSection 1211(a). Post -DRRA, although the federal government is still responsible for housing-DRRA, although the federal government is still responsible for housing assistance assistance
(continued...) Congressional Research Service Congressional Research Service

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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

Housing Assistance and ONA.67 It also removed financial assistance to rent alternative Housing Assistance and ONA.67 It also removed financial assistance to rent alternative
housing accommodations (i.e., Lodging Expense Reimbursement, Rental Assistance, and housing accommodations (i.e., Lodging Expense Reimbursement, Rental Assistance, and
Continued Temporary Housing Assistance) from the cap,68 and created an exception to Continued Temporary Housing Assistance) from the cap,68 and created an exception to
the cap for accessibility-related repair or replacement costs associated with real and the cap for accessibility-related repair or replacement costs associated with real and
personal property (e.g., eligible household items).69 personal property (e.g., eligible household items).69
Expanded MLR Property Eligibility (DRRA Section 1213)—Multifamily —Multifamily
Lease and Repair Assistance—expands the eligible areas for MLR,70 and deducts Lease and Repair Assistance—expands the eligible areas for MLR,70 and deducts
the value of improvements from the value of the lease agreement.71 the value of improvements from the value of the lease agreement.71
Other Needs Assistance
Individuals and households may require Other Needs Assistance (ONA), which provides a grant Individuals and households may require Other Needs Assistance (ONA), which provides a grant
of financial assistance for disaster-related necessary expenses and serious needs that are not of financial assistance for disaster-related necessary expenses and serious needs that are not
covered by insurance or provided by another source. A covered by insurance or provided by another source. A necessary expense is defined as “the cost is defined as “the cost
associated with acquiring an item, obtaining a service, or paying for any other activity that meets associated with acquiring an item, obtaining a service, or paying for any other activity that meets
a serious need.” A a serious need.” A serious need is defined as “the requirement for an item or service that is is defined as “the requirement for an item or service that is
essential to an applicant’s abilityessential to an applicant’s ability to prevent, mitigate, or overcome a disaster-caused hardship, to prevent, mitigate, or overcome a disaster-caused hardship,
injury, or adverse condition.”72 injury, or adverse condition.”72
There are many types of ONA, which There are many types of ONA, which fal fall into two subcategories: (1) SBA-Dependent ONA, and into two subcategories: (1) SBA-Dependent ONA, and
(2) Non-SBA-Dependent ONA (SBA refers to the (2) Non-SBA-Dependent ONA (SBA refers to the Smal Small Business Administration) (the reason for Business Administration) (the reason for
the SBA’s involvement is described in the following section). the SBA’s involvement is described in the following section).
There are several limitations on the amount of ONA an individualThere are several limitations on the amount of ONA an individual or household is eligibleor household is eligible to to
receive. Applicants may receive up to the maximum amount of financial assistance for ONA.73 receive. Applicants may receive up to the maximum amount of financial assistance for ONA.73
Additional y, available Additionally, available ONA assistance may be further limited by the affected state, territory, or ONA assistance may be further limited by the affected state, territory, or
Indian tribal government. This is because the affected state, territory, or Indian tribal government Indian tribal government. This is because the affected state, territory, or Indian tribal government
predetermines some items that are eligiblepredetermines some items that are eligible for ONA assistance, and establishes the number of for ONA assistance, and establishes the number of
items that can be ONA-funded and/or the maximum amount of ONA funding that can be items that can be ONA-funded and/or the maximum amount of ONA funding that can be
provided for select items.74 For example, “FEMA may award applicants Funeral Assistance and provided for select items.74 For example, “FEMA may award applicants Funeral Assistance and

costs, state, territory, and Indian tribal governments may elect to administer Direct costs, state, territory, and Indian tribal governments may elect to administer Direct T emporaryTemporary Housing Assistance and Housing Assistance and
Permanent Housing Construction. In addition, DRRA Section 1211(b) provides a mechanism for state and local units of Permanent Housing Construction. In addition, DRRA Section 1211(b) provides a mechanism for state and local units of
government to be reimbursedgovernment to be reimbursed for locally-implemented housing solutions. for locally-implemented housing solutions.
67 DRRA 67 DRRA Section 1212. Section 1212.
68 FEMA, 68 FEMA, IAPPG, pp. 41-42. , pp. 41-42.
69 DRRA69 DRRA Section 1212. Section 1212.
70 DRRA70 DRRA Section 1213(b). EligibleSection 1213(b). Eligible MLR properties include both properties that are located in areas covered by an MLR properties include both properties that are located in areas covered by an
emergency or major disasteremergency or major disaster declaration and areas that are impacted by a major disasterdeclaration and areas that are impacted by a major disaster . .
71 DRRA 71 DRRA Section 1213(a). Section 1213(a).
72 FEMA, 72 FEMA, IAPPG, p. 145. , p. 145.
73 Financial assistance for ONA may not exceed $41,000 (FY2023; adjusted annually) (DHS/FEMA,73 Financial assistance for ONA may not exceed $41,000 (FY2023; adjusted annually) (DHS/FEMA, “Notice of “Notice of
Maximum Amount of Assistance Under the IndividualsMaximum Amount of Assistance Under the Individuals and Householdsand Households Program,” 87 Program,” 87 Federal Register 64512, 64512,
October 25, 2022, https://www.govinfo.gov/content/pkg/FR-2022-10-25/pdf/2022-23162.pdf). October 25, 2022, https://www.govinfo.gov/content/pkg/FR-2022-10-25/pdf/2022-23162.pdf).
74 FEMA, 74 FEMA, IAPPG, p. 147. State, territory, and Indian tribal governments establish the maximum amount of assistance , p. 147. State, territory, and Indian tribal governments establish the maximum amount of assistance
that may be awardedthat may be awarded for some categories of ONA, includingfor some categories of ONA, including T ransportation Transportation Assistance for repair or replacement, Assistance for repair or replacement,
Funeral Assistance, and ChildFuneral Assistance, and Child Care Assistance. Personal Property and Miscellaneous Items may also beCare Assistance. Personal Property and Miscellaneous Items may also be requested,requested, and and
the requesting state, territory, and Indian tribal government must list the additional items, maximum quantity, the requesting state, territory, and Indian tribal government must list the additional items, maximum quantity,
maximum awardmaximum award amount, and justification and situations for use. amount, and justification and situations for use. T hisThis is submitted is submitted to FEMA annually via the “ONA to FEMA annually via the “ONA
Administrative Option Selection Form” (FEMA, “Individuals and HouseholdsAdministrative Option Selection Form” (FEMA, “Individuals and Households Program (IHP)—Other Needs Program (IHP)—Other Needs
Assistance Administrative Option Selection,” form, O.M.B. Control No. 1660Assistance Administrative Option Selection,” form, O.M.B. Control No. 1660 -0061, expires December 31, 2021, -0061, expires December 31, 2021,
https://www.fema.gov/sites/default/files/documents/fema_individuals-households_ONA-administrative-(continued...) Congressional Research Service Congressional Research Service

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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

Child Care Assistance up to the limits established by the STT [state, territory, or tribal] Child Care Assistance up to the limits established by the STT [state, territory, or tribal]
government in the ONA Administrative Option Selection Form.... ”75 government in the ONA Administrative Option Selection Form.... ”75
Additional y, Additionally, ONA, unlike housing assistance, is subject to a cost share.76 The federal share for ONA, unlike housing assistance, is subject to a cost share.76 The federal share for
ONA is 75%, and the nonfederal cost share is the remaining 25%. The statutory text states that ONA is 75%, and the nonfederal cost share is the remaining 25%. The statutory text states that
“the non-Federal share “the non-Federal share shal shall be paid from funds made available by the state.”77 Thus, the affected be paid from funds made available by the state.”77 Thus, the affected
state, territory, or Indian tribal government—rather than the individual/household—bears state, territory, or Indian tribal government—rather than the individual/household—bears
responsibility for covering a portion of the costs associated with providing ONA.78 responsibility for covering a portion of the costs associated with providing ONA.78
SBA-Dependent ONA
FEMA and the FEMA and the Smal Small Business Administration (SBA) collaborate to determine an applicant’s Business Administration (SBA) collaborate to determine an applicant’s
eligibilityeligibility for some forms of Other Needs Assistance.79 This is because IHP assistance for for some forms of Other Needs Assistance.79 This is because IHP assistance for
Personal Property Assistance, Transportation Assistance, and Group Flood Insurance Policy Personal Property Assistance, Transportation Assistance, and Group Flood Insurance Policy
assistance—the three forms of SBA-Dependent ONA—are forms of assistance that may also be assistance—the three forms of SBA-Dependent ONA—are forms of assistance that may also be
addressed by an SBA disaster loan. To avoid the statutory prohibition on duplicative assistance,80 addressed by an SBA disaster loan. To avoid the statutory prohibition on duplicative assistance,80
FEMA FEMA refers IHP applicants who meet the SBA’s minimum income test to first apply for a low-refers IHP applicants who meet the SBA’s minimum income test to first apply for a low-
interest SBA disaster loan before they are eligibleinterest SBA disaster loan before they are eligible to receive SBA-Dependent ONA through the to receive SBA-Dependent ONA through the
IHP.81 If the applicant does not qualify for an SBAIHP.81 If the applicant does not qualify for an SBA disaster loan or their SBA disaster loan amount disaster loan or their SBA disaster loan amount
is insufficient to meet their disaster-caused expenses or serious needs, then they can be referred is insufficient to meet their disaster-caused expenses or serious needs, then they can be referred
back to FEMA for consideration for IHP assistance—and back to FEMA for consideration for IHP assistance—and specifical yspecifically for SBA-Dependent ONA. for SBA-Dependent ONA.
The SBA and FEMA have a Computer Matching Agreement, the purpose of which is to “share The SBA and FEMA have a Computer Matching Agreement, the purpose of which is to “share
data and financial/benefits award decisions of individuals ... to verify eligibilitydata and financial/benefits award decisions of individuals ... to verify eligibility for benefits, for benefits,
prevent duplicative aid from being provided in response to the same disaster or emergency, and prevent duplicative aid from being provided in response to the same disaster or emergency, and

https://www.fema.gov/media-library-data/1544535263707-b64302090b362e43b9acec0517150836/
Individuals_and_Households_ONA_Administrative_Option_ (FEMA_Form_010-0-11)recover aid when duplication of benefits is identified.”82 As described in the Computer Matching Agreement, the steps in the application process are as follows: • the disaster survivor registers with FEMA for possible assistance; option_Form_010-0-11.pdf; FEMA, .pdf; FEMA, IAPPG, pp. 147, , pp. 147,
149). However, the “149). However, the “ ONA Administrative Option Selection Form” may be changed “ONA Administrative Option Selection Form” may be changed “ during any nonduring any non -disaster period or -disaster period or
within three days of a major disasterwithin three days of a major disaster declaration” (FEMA, declaration” (FEMA, IAPPG p. 149). p. 149).
75 FEMA, 75 FEMA, IAPPG, p. 149. , p. 149.
76 See76 See the “Defining ‘Cost Shares’” text box for the “Defining ‘Cost Shares’” text box for t hethe cost share definition. cost share definition.
77 42 U.S.C.77 42 U.S.C. §5174(g)(2)(B). §5174(g)(2)(B).
78 42 U.S.C.78 42 U.S.C. §5174(g)(2); 44 C.F.R. §206.110(i)(2); and FEMA, §5174(g)(2); 44 C.F.R. §206.110(i)(2); and FEMA, IAPPG, p. 147. , p. 147.
79 Small79 Small Business Business Administration (SBA), “Computer Matching Agreement Between U.S. SmallAdministration (SBA), “Computer Matching Agreement Between U.S. Small Business Business
Administration and U.S.Administration and U.S. Department of Homeland Security, Federal Emergency Management Agency,” 84Department of Homeland Security, Federal Emergency Management Agency,” 84 Federal
Register
2651, February 7, 2019, https://www.govinfo.gov/content/pkg/FR-2019-02-07/pdf/2019-01508.pdf 2651, February 7, 2019, https://www.govinfo.gov/content/pkg/FR-2019-02-07/pdf/2019-01508.pdf
(hereinafter SBA, “Computer Matching Agreement”); and FEMA, (hereinafter SBA, “Computer Matching Agreement”); and FEMA, IAPPG, p. 145. Per the Computer Matching , p. 145. Per the Computer Matching
Agreement, “Agreement, “T hisThis Agreement establishes the Computer Matching program between DHS Agreement establishes the Computer Matching program between DHS [Department of Homeland [Department of Homeland
Security]/FEMA and SBA.Security]/FEMA and SBA. T he The Computer Matching program seeks to ensure that applicants for SBA Disaster Loans Computer Matching program seeks to ensure that applicants for SBA Disaster Loans
and DHS/FEMAand DHS/FEMA Individuals Individuals and Householdsand Households Program (IHP), which provides Other Needs Assistance (ONA) and Program (IHP), which provides Other Needs Assistance (ONA) and
HousingHousing Assistance (HA), are eligibleAssistance (HA), are eligible to receive benefits and do not receive a duplication of benefits for the same to receive benefits and do not receive a duplication of benefits for the same
disaster. Additionally, the Computer Matching program seeks to establish or verify initial eligibility for DHS/FEMA disaster. Additionally, the Computer Matching program seeks to establish or verify initial eligibility for DHS/FEMA
and SBAand SBA disaster assistance.... ” Further, the purpose of the Computer Matching Agreement is to “disaster assistance.... ” Further, the purpose of the Computer Matching Agreement is to “ share data and share data and
financial/benefits awardfinancial/benefits award decisions decisions of individuals,of individuals, businesses,businesses, and/or other entities to verify eligibility for benefits, and/or other entities to verify eligibility for benefits,
prevent duplicative aid from being provided in response to the same disaster or emergency, and recover aid when prevent duplicative aid from being provided in response to the same disaster or emergency, and recover aid when
duplication of benefits is identified.” duplication of benefits is identified.”
80 42 U.S.C.80 42 U.S.C. §5155. §5155.
81 81 T heThe other forms of ONA may be awarded other forms of ONA may be awarded regardless regardless of the individual’sof the individual’s or household’s Smallor household’s Small Business Business
Administration (SBA) disaster loan status and are referred to as Non-SBA-Dependent ONA. Administration (SBA) disaster loan status and are referred to as Non-SBA-Dependent ONA.
82 SBA, “Computer Matching Agreement,” 84 Federal Register 2650. Congressional Research Service Congressional Research Service

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link to page 20 link to page 20 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

recover aid when duplication of benefits is identified.”82 As described in the Computer Matching
Agreement, the steps in the application process are as follows:
 the disaster survivor registers with FEMA for possible assistance;
an applicant whose income does not meet the SBA minimum income threshold to an applicant whose income does not meet the SBA minimum income threshold to
warrant an SBA disaster loan referral may be considered for SBA-Dependent warrant an SBA disaster loan referral may be considered for SBA-Dependent
ONA, but if the applicant meets the SBA’s minimum income test to apply for an ONA, but if the applicant meets the SBA’s minimum income test to apply for an
SBA disaster loan, then FEMA SBA disaster loan, then FEMA automatical yautomatically refers applicant to the SBA;83 refers applicant to the SBA;83
once referred to the SBA, to be considered for assistance through the SBA or once referred to the SBA, to be considered for assistance through the SBA or
FEMA, the applicant must apply for an SBA FEMA, the applicant must apply for an SBA disaster loan, which is based on disaster loan, which is based on
credit-worthiness; and credit-worthiness; and
the applicant the applicant wil be automatical y will be automatically referred back to FEMA for consideration for referred back to FEMA for consideration for
SBA-Dependent ONA if the applicant’s SBA disaster loan application is denied SBA-Dependent ONA if the applicant’s SBA disaster loan application is denied
or the loan amount is insufficient to meet their unmet needs (the SBA or the loan amount is insufficient to meet their unmet needs (the SBA wil will contact contact
applicants who are determined able to afford a loan and FEMA applicants who are determined able to afford a loan and FEMA wil will contact contact
applicants found unable to afford a loan). If, however, the SBA approves the applicants found unable to afford a loan). If, however, the SBA approves the
applicant’s SBA disaster loan application and the applicant does not accept the applicant’s SBA disaster loan application and the applicant does not accept the
loan, FEMA loan, FEMA wil will not provide any SBA-dependent ONA to that applicant.84not provide any SBA-dependent ONA to that applicant.84
Figure 2 depicts the general process for determining eligibilitydepicts the general process for determining eligibility for SBA-Dependent ONA.85 As for SBA-Dependent ONA.85 As
listed above, there are two pathways for individuals and households to be considered for SBA-listed above, there are two pathways for individuals and households to be considered for SBA-
Dependent ONA: (1) FEMA refers applicants to the SBA Disaster Loan Program if their income Dependent ONA: (1) FEMA refers applicants to the SBA Disaster Loan Program if their income
meets the SBA’s minimum income test (see the “Yes” path)—in this case, the referred IHP meets the SBA’s minimum income test (see the “Yes” path)—in this case, the referred IHP
applicant must submit an application for an SBA disaster loan; or (2) FEMA considers the applicant must submit an application for an SBA disaster loan; or (2) FEMA considers the
applicant for SBA-Dependent ONA if the applicant’s income does not meet the SBA’s minimum applicant for SBA-Dependent ONA if the applicant’s income does not meet the SBA’s minimum
income test (see the “No” path).86 If the SBA denies the applicant’s SBA disaster loan request or income test (see the “No” path).86 If the SBA denies the applicant’s SBA disaster loan request or
the loan amount is insufficient to meet their recovery needs (i.e., a partial SBA disaster loan), the the loan amount is insufficient to meet their recovery needs (i.e., a partial SBA disaster loan), the
applicant is referred back to FEMA to be considered for SBA-Dependent ONA. According to the applicant is referred back to FEMA to be considered for SBA-Dependent ONA. According to the
FEMA officials, FEMA contacts the disaster survivor if the SBA determines they cannot afford a FEMA officials, FEMA contacts the disaster survivor if the SBA determines they cannot afford a
loan.87

82 SBA, “Computer Matching Agreement,” 84 Federal Register 2650.
loan.87 In a September 2020 report, the U.S. Government Accountability Office (GAO) found the interconnected SBA Disaster Loan and SBA-Dependent ONA application process burdensome.88 GAO stated that it “may have prevented many survivors from being considered for certain types of assistance.... ,” and noted that “[b]y 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.”89 As of July 2022, FEMA 83 According to the Government Accountability Office (GAO), “FEMA informs disaster survivors about SBA’s 83 According to the Government Accountability Office (GAO), “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 disaster loan program through a variety of methods. For example, FEMA staff share information on SBA’s disaster
loan program duringloan program during interactions with survivors. After completing the IHP application, an applicant who is referred to interactions with survivors. After completing the IHP application, an applicant who is referred to
the SBAthe SBA is is verbally notified that they must also complete and return an application to SBA to be considered for a verbally notified that they must also complete and return an application to SBA to be considered for a
disaster loan asdisaster loan as well well as certain types of assistance from FEMA.” GAO,as certain types of assistance from FEMA.” GAO, Disaster Assistance: Additional Actions Needed
to Strengthen FEMA’s Individuals and Households Program
, GAO-20-503, September 2020, pp. 36-37, , GAO-20-503, September 2020, pp. 36-37,
https://www.gao.gov/assets/710/709775.pdf (hereinafter GAO, https://www.gao.gov/assets/710/709775.pdf (hereinafter GAO, Disaster Assistance: IHP). ).
84 SBA, 84 SBA, “Computer Matching Agreement,” 84“Computer Matching Agreement,” 84 Federal Register 2651-2652. 2651-2652.
85 For more information on the process of determining whether an applicant may qualify for a SBA85 For more information on the process of determining whether an applicant may qualify for a SBA disaster disaster loan and loan and
how FEMA ONA assistance and SBAhow FEMA ONA assistance and SBA disaster loans intersect, see CRSdisaster loans intersect, see CRS Report R45238, Report R45238, FEMA and SBA Disaster
Assistance for Individuals and Households: Application Processes, Determ inationsDeterminations, and Appeals
, by Bruce, by Bruce R. Lindsay R. Lindsay
and Elizabeth M. Webster. and Elizabeth M. Webster.
86 SBA, 86 SBA, “Computer Matching Agreement,” 84“Computer Matching Agreement,” 84 Federal Register 2651. “[I]f SBA approves the applicant’s loan 2651. “[I]f SBA approves the applicant’s loan
application and the applicant does not accept the loan, DHS/FEMA willapplication and the applicant does not accept the loan, DHS/FEMA will not provide any SBA-dependent ONA to that not provide any SBA-dependent ONA to that
applicant.” applicant.”
87 GAO,87 GAO, Disaster Assistance: IHP, p. 37 (footnote 49). , p. 37 (footnote 49).
88 GAO, Disaster Assistance: IHP, p. 79. 89 GAO, Disaster Assistance: IHP, p. GAO Highlights. Congressional Research Service Congressional Research Service

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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

In a September 2020 report, the U.S. Government Accountability Office (GAO) found the
interconnected SBA Disaster Loan and SBA-Dependent ONA application process burdensome.88
GAO stated that it “may have prevented many survivors from being considered for certain types
of assistance... ,” and noted that “[b]y fully communicating the requirement and working with
SBA to identify options to simplify and streamline this step of the IHP process, FEMA c ould help
ensure that survivors receive al assistance for which they are eligible.”89 As of October 2021,
FEMA reported it was responding to the recommendation by updating its initial letters to disaster
survivors explaining the SBA disaster loan application requirement, and working with the SBA to
simplify and streamline the application process for disaster survivorsreported that the agency is revising its letters to IHP applicants and is developing a notice of proposed rulemaking related to SBA-Dependent ONA, which, according to GAO, FEMA planned to publish by January 2023.90 .90
Figure 2. FEMA and SBA Screening Process

Source: Developed Developed by CRS based on “Figure 27: SBA Disasterby CRS based on “Figure 27: SBA Disaster Loan Application Process”Loan Application Process” of the FEMA, of the FEMA,
Individual Assistance Program and Policy Guide (IAPPG), v. 1.1, FP 104-009-03, May 2021, p. 145, , v. 1.1, FP 104-009-03, May 2021, p. 145,
https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf. https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf.
Note: SBA-Dependent ONA provides financial assistance for other disaster-relatedSBA-Dependent ONA provides financial assistance for other disaster-related expenses and needs, expenses and needs,
including for Personalincluding for Personal Property Assistance,Property Assistance, Transportation Assistance,Transportation Assistance, and Group Flood Insurance Policies. and Group Flood Insurance Policies.
Brief descriptions of the types of SBA-Dependent ONA, and selected considerations or Brief descriptions of the types of SBA-Dependent ONA, and selected considerations or
limitations associated with the specific types of assistance, are included below.91 limitations associated with the specific types of assistance, are included below.91
Personal Property Assistance
Personal Property Assistance provides funding to repair or replace eligible items damaged or Personal Property Assistance provides funding to repair or replace eligible items damaged or
destroyed as a result of a declared emergency or disaster.92 Eligible Personal Property items destroyed as a result of a declared emergency or disaster.92 Eligible Personal Property items
include standard household appliances (and selected accessibility items); essential clothing; include standard household appliances (and selected accessibility items); essential clothing;
standard furnishings; and essential, specialized tools and equipment required by an employer standard furnishings; and essential, specialized tools and equipment required by an employer
(essential equipment for self-employment is ineligible)(essential equipment for self-employment is ineligible) or for education.93 Per the IAPPG, FEMA and the affected state, territory, or Indian tribal government determine the personal property that may be eligible for assistance, including establishing the maximum 90 GAO, Disaster or for education.93

88 GAO, Disaster Assistance: IHP, p. 79.
89 GAO, Disaster Assistance: IHP, p. GAO Highlights.
90 GAO, Disaster Assistance: IHP, pp. 76-77 (see Recommendations 1 and 2). See, pp. 76-77 (see Recommendations 1 and 2). See also the status of Recommendations also the status of Recommendations
1 and 2 in the “Recommendations for Executive Action” table on the 1 and 2 in the “Recommendations for Executive Action” table on the webpageweb page for the GAO for the GAO Disaster Assistance: IHP report, available at https://www.gao.gov/products/gao-20-503, last accessed May 15, 2023. In addition, during the 117th Congress, Senators Gary Peters and James Lankford introduced bipartisan legislation to simplify the application process itself by creating a consolidated application for federal disaster assistance (see Disaster Assistance Simplification Act (S. 4599), introduced July 21, 2022; see also U.S. Senate Committee on Homeland Security and Governmental Affairs, “Peters and Lankford Bipartisan Bill to Simplify Application Process for Federal Disaster Assistance Advances in Senate: Legislation Would Create Universal Application for Disaster Survivors,” press release, August 5, 2022, https://www.hsgac.senate.gov/media/dems/peters-and-lankford-bipartisan-bill-to-simplify-application-process-for-federal-disaster-assistance-advances-in-senate/). 91 TheAssistance: IHP
report, available at https://www.gao.gov/products/gao-20-503.
91 T he FEMA FEMA IAPPG includes includes additional conditions of applicant eligibility, eligibleadditional conditions of applicant eligibility, eligible expenses, requiredexpenses, required documentation, documentation,
and program limitations and exclusions for each type of SBA-Dependent ONA, beginningand program limitations and exclusions for each type of SBA-Dependent ONA, beginning on page 166. on page 166.
92 FEMA, 92 FEMA, IAPPG, pp. 166-167. , pp. 166-167.
93 FEMA, 93 FEMA, IAPPG, p. 167. , p. 167.
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Per the IAPPG, FEMA and the affected state, territory, or Indian tribal government determine the
personal property that may be eligible for assistance, including establishing the maximum
quantity that may be awarded for each item. This is done through the “ONA Administrative quantity that may be awarded for each item. This is done through the “ONA Administrative
Option Selection Form’s” “Standard Personal Property Line Items” list.94 Option Selection Form’s” “Standard Personal Property Line Items” list.94
Accessibility items that are eligible Accessibility items that are eligible for Personal Property Assistance and are exempted from the for Personal Property Assistance and are exempted from the
ONA maximum amount of financial assistance include: ONA maximum amount of financial assistance include:
Computer (if it is a person’s sole means of communication); Computer (if it is a person’s sole means of communication);
Raised—or elevated—toilet seat (for people who have mobility limitations); Raised—or elevated—toilet seat (for people who have mobility limitations);
Front-loading washer (for people who use a wheelchair/have mobility Front-loading washer (for people who use a wheelchair/have mobility
limitations); limitations);
Side-by-side refrigerator (for people who use a wheelchair/have mobility Side-by-side refrigerator (for people who use a wheelchair/have mobility
limitations); limitations);
Hospital-style bed; Hospital-style bed;
Walker; Walker;
Wheelchair; Wheelchair;
Shower chair; Shower chair;
Specialty Smoke Alarm (for people who are vision/hearing-impaired); and Specialty Smoke Alarm (for people who are vision/hearing-impaired); and
Text telephone devices (TTYs or TDDs).95 Text telephone devices (TTYs or TDDs).95
Transportation Assistance
Transportation Assistance provides funding to repair or replace a vehicle damaged by a declared Transportation Assistance provides funding to repair or replace a vehicle damaged by a declared
emergency or disaster.96 Unlike most forms of IHP assistance, applicants do not need to live in the emergency or disaster.96 Unlike most forms of IHP assistance, applicants do not need to live in the
area designated to receive IA, provided: (1) the vehicle was damaged as a direct result of the area designated to receive IA, provided: (1) the vehicle was damaged as a direct result of the
presidential ypresidentially-declared emergency or major disaster; and (2) the damage occurred in the area -declared emergency or major disaster; and (2) the damage occurred in the area
designated to receive IA.97 Additionaldesignated to receive IA.97 Additional eligibility eligibility requirements include that the applicant: (1) owns requirements include that the applicant: (1) owns
or leases the vehicle; and (2) does not own an operational second vehicle, or additional or leases the vehicle; and (2) does not own an operational second vehicle, or additional
operational vehicles are insufficient to meet the needs of the household.98 Per the operational vehicles are insufficient to meet the needs of the household.98 Per the IAPPG, FEMA , FEMA
and the affected state, territory, or Indian tribal government determine the maximum amount of and the affected state, territory, or Indian tribal government determine the maximum amount of
Transportation Assistance that may be awarded for repair or replacement, which is based on the Transportation Assistance that may be awarded for repair or replacement, which is based on the
degree of damage and the state/territory/tribe-set maximum established in the “ONA degree of damage and the state/territory/tribe-set maximum established in the “ONA
Administrative Option Selection Form.”99 Administrative Option Selection Form.”99
Group Flood Insurance Policy
Individuals and households who receive federal financial assistance for flood-related damage— Individuals and households who receive federal financial assistance for flood-related damage—
including IHP assistance for Home Repair, Home Replacement, PHC, or Personal Property including IHP assistance for Home Repair, Home Replacement, PHC, or Personal Property

Assistance—are required to buy and maintain flood insurance for future flood damage to insurable real and personal property as a condition of IHP eligibility.100 To reduce future flood 94 FEMA, 94 FEMA, IAPPG, pp. 166-167. , pp. 166-167.
95 FEMA, 95 FEMA, IAPPG, p. 146. , p. 146.
96 FEMA, 96 FEMA, IAPPG, p. 170. Eligible, p. 170. Eligible vehicles includevehicles include cars, vans, sport utility vehicles (SUVs),cars, vans, sport utility vehicles (SUVs), and trucks, and may and trucks, and may
includeinclude motorcycles, boats, golf carts, etc. if specifiedmotorcycles, boats, golf carts, etc. if specified by by the affected state, territory, or Indian tribal government on the affected state, territory, or Indian tribal government on
their “ONA Administrative Option Selection Form.” their “ONA Administrative Option Selection Form.”
97 FEMA, 97 FEMA, IAPPG, p. 170. , p. 170.
98 FEMA,98 FEMA, IAPPG, pp. 170, 172. , pp. 170, 172.
99 FEMA, 99 FEMA, IAPPG, p. 170. , p. 170.
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Assistance—are required to buy and maintain flood insurance for future flood damage to
insurable real and personal property as a condition of IHP eligibility.100 To reduce future flood
expenses, the Group Flood Insurance Policy (GFIP) enables FEMA or the state, territory, or expenses, the Group Flood Insurance Policy (GFIP) enables FEMA or the state, territory, or
Indian tribal government to directly purchase a GFIP on an applicant’s behalf if the applicant is Indian tribal government to directly purchase a GFIP on an applicant’s behalf if the applicant is
required to purchase and maintain flood insurance, but could not otherwise purchase a policy.101 required to purchase and maintain flood insurance, but could not otherwise purchase a policy.101
GFIPs are established under the National Flood Insurance Program (NFIP). The premium for a GFIPs are established under the National Flood Insurance Program (NFIP). The premium for a
three-year certificate of coverage costs $2,400,102 and it covers real and personal property three-year certificate of coverage costs $2,400,102 and it covers real and personal property
equaling the maximum amount of financial assistance available for both Housing Assistance and equaling the maximum amount of financial assistance available for both Housing Assistance and
ONA (e.g., for FY2023, $82,000).103ONA (e.g., for FY2023, $82,000).103
There are a few special eligibility There are a few special eligibility criteria that must be met for a person to be eligiblecriteria that must be met for a person to be eligible for a GFIP, for a GFIP,
including (1) the damage was caused by flooding and the flood-damaged items are insurable including (1) the damage was caused by flooding and the flood-damaged items are insurable
under the NFIP; (2) the applicant is eligibleunder the NFIP; (2) the applicant is eligible for IHP Home Repair, Home Replacement, or for IHP Home Repair, Home Replacement, or
Personal Property Assistance, and is therefore required to purchase and maintain flood insurance, Personal Property Assistance, and is therefore required to purchase and maintain flood insurance,
but otherwise lacks the ability to do so; and (3) the property is located in a Special Flood Hazard but otherwise lacks the ability to do so; and (3) the property is located in a Special Flood Hazard
Area (SFHA).104 Two limitations of note: (1) the cost of the GFIP cannot exceed the remaining Area (SFHA).104 Two limitations of note: (1) the cost of the GFIP cannot exceed the remaining
amount of financial assistance available to the applicant through ONA. If the GFIP policy cost amount of financial assistance available to the applicant through ONA. If the GFIP policy cost
exceeds this, FEMA exceeds this, FEMA wil will not purchase a policy; however, the applicant is not purchase a policy; however, the applicant is stil still responsible for responsible for
purchasing a flood insurance policy; and (2) upon the expiration of the GFIP, the applicant must purchasing a flood insurance policy; and (2) upon the expiration of the GFIP, the applicant must
purchase and maintain flood insurance. Failure to do so may affect future IHP eligibility.105 purchase and maintain flood insurance. Failure to do so may affect future IHP eligibility.105
Non-SBA-Dependent ONA
Non-SBA-Dependent types of ONA may be awarded regardless of the individual or household’s Non-SBA-Dependent types of ONA may be awarded regardless of the individual or household’s
SBA disaster loan status.106SBA disaster loan status.106
Brief descriptions of the types of Non-SBA-Dependent ONA, and selected considerations or Brief descriptions of the types of Non-SBA-Dependent ONA, and selected considerations or
limitations associated with the specific types of assistance, are included below.107 limitations associated with the specific types of assistance, are included below.107

100 44 C.F.R. §206.110(k)(3); FEMA, IAPPG, p. 63.
101 FEMA, 101 FEMA, IAPPG, p. 172. , p. 172.
102 Per 44 C.F.R. §61.17(b), the Group Flood Insurance Policy (GFIP) premium is102 Per 44 C.F.R. §61.17(b), the Group Flood Insurance Policy (GFIP) premium is a “flat fee of $600 per insured” and a “flat fee of $600 per insured” and
44 C.F.R.44 C.F.R. §61.17(d) states that the term is for 36 months—or 3 years; however, the regulation notes that the premium §61.17(d) states that the term is for 36 months—or 3 years; however, the regulation notes that the premium
may bemay be adjusted “ adjusted “to reflect NFIP loss experience and any adjustment of benefits under the IHP programto reflect NFIP loss experience and any adjustment of benefits under the IHP program .” FEMA’s .” FEMA’s
guidanceguidance notes the premium is $2,400 (FEMA, notes the premium is $2,400 (FEMA, IAPPG, p. 172). , p. 172).
103 FEMA, 103 FEMA, IAPPG, p. 172. , p. 172. T heThe maximum amount of financial assistance for IHP Housing maximum amount of financial assistance for IHP Housing Assistance and ONA for Assistance and ONA for
disastersdisasters declared on or after October 1, 2022, can be found at DHS/FEMA,declared on or after October 1, 2022, can be found at DHS/FEMA,Notice of Maximum Amount of Notice of Maximum Amount of
Assistance Under the IndividualsAssistance Under the Individuals and Householdsand Households Program,” 87 Program,” 87 Federal Register 64512, October 25, 2022, 64512, October 25, 2022,
https://www.govinfo.gov/content/pkg/FR-2022-10-25/pdf/2022-23162.pdf. https://www.govinfo.gov/content/pkg/FR-2022-10-25/pdf/2022-23162.pdf.
104 FEMA, 104 FEMA, IAPPG, p. 173. , p. 173. T oTo be eligible be eligible for GFIP, the property cannot be located in a sanctioned community, Coastal for GFIP, the property cannot be located in a sanctioned community, Coastal
Barrier ResourcesBarrier Resources System (CBRS)System (CBRS) area, or otherwise protected area (OPA). area, or otherwise protected area (OPA). T heThe FEMA FEMA IAPPG defines the different defines the different
types of Flood Zones and Protected Areas, includingtypes of Flood Zones and Protected Areas, including Special Special Flood Hazard Areas (SFHAs),Flood Hazard Areas (SFHAs), sanctioned sanctioned com munitiescommunities, ,
CBRSCBRS units, and OPAs, beginning on page 63. Individualsunits, and OPAs, beginning on page 63. Individuals who receive federal financial assistance for flooding must who receive federal financial assistance for flooding must
purchase flood insurance on real or personal property that is, or will be,purchase flood insurance on real or personal property that is, or will be, in an SHFAin an SHFA and can be insuredand can be insured under the under the
National Flood Insurance Program (NFIP). Section 582 of the National Flood Insurance Reform Act of 1994 (NFIRA, National Flood Insurance Program (NFIP). Section 582 of the National Flood Insurance Reform Act of 1994 (NFIRA,
P.L. 103-325) prohibits the provision of federal financial assistance for repair, replacement or restoration of damaged P.L. 103-325) prohibits the provision of federal financial assistance for repair, replacement or restoration of damaged
personal or real property if the receipt of financial assistance was conditioned on their obtaining and maintaining flood personal or real property if the receipt of financial assistance was conditioned on their obtaining and maintaining flood
insurance, and they fail to do soinsurance, and they fail to do so (codified at 42 U.S.C. §5154a). .
105 FEMA, 105 FEMA, IAPPG, p. 174. , p. 174.
106 FEMA, 106 FEMA, IAPPG, p. 149. , p. 149.
107 107 T heThe FEMA FEMA IAPPG includes includes additional conditions of applicant eligibility, eligibleadditional conditions of applicant eligibility, eligible expenses, requiredexpenses, required documentation, documentation,
and program limitations and exclusions for each type of Nonand program limitations and exclusions for each type of Non -SBA-Dependent ONA, beginning-SBA-Dependent ONA, beginning on page 150. on page 150.
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Funeral Assistance
Funeral Assistance provides funding to assist with eligible Funeral Assistance provides funding to assist with eligible funeral expenses (e.g., interment or funeral expenses (e.g., interment or
reinterment, funeral and officiant services, and death certificates).108 Unlike most forms of IHP reinterment, funeral and officiant services, and death certificates).108 Unlike most forms of IHP
assistance, applicants do not need to live in the area designated to receive IA,109 provided they assistance, applicants do not need to live in the area designated to receive IA,109 provided they
incurred or incurred or wil will incur expenses related to a death or disinterment that is directly or indirectly incur expenses related to a death or disinterment that is directly or indirectly
attributable to the attributable to the presidential y presidentially declared emergency or major disaster,110 and the expenses are not declared emergency or major disaster,110 and the expenses are not
covered by other sources (e.g., burial insurance or assistance from voluntary agencies).111 covered by other sources (e.g., burial insurance or assistance from voluntary agencies).111
FEMA COVID-19 Funeral Assistance
In response to the Coronavirus Disease In response to the Coronavirus Disease 2019 (COVID-19) pandemic, Congress2019 (COVID-19) pandemic, Congress authorized FEMA to provide authorized FEMA to provide
COVID-19 Funeral AssistanceCOVID-19 Funeral Assistance through Section 201 of the Coronavirus Response and Relief Supplemental through Section 201 of the Coronavirus Response and Relief Supplemental
Appropriations Act, 2021 (Division M of the Consolidated Appropriations Act, 2021, P.L.Appropriations Act, 2021 (Division M of the Consolidated Appropriations Act, 2021, P.L. 116-260), and Section 116-260), and Section
4006 of the American4006 of the American Rescue Plan Act of 2021 (P.L. 117-2), which authorized FEMA to provide financial assistance Rescue Plan Act of 2021 (P.L. 117-2), which authorized FEMA to provide financial assistance
for COVID-19-related funeral expenses at 100% federal cost share. for COVID-19-related funeral expenses at 100% federal cost share.
Although FEMA’s role in administering Funeral AssistanceAlthough FEMA’s role in administering Funeral Assistance typical y typically varies varies depending on the preferencedepending on the preference of the of the
affected state, territory,affected state, territory, or tribe, in the case of COVID-19 Funeral Assistance,or tribe, in the case of COVID-19 Funeral Assistance, FEMA administeredFEMA administered the program the program
under the ONA FEMA Option and FEMA also issued interimunder the ONA FEMA Option and FEMA also issued interim policy guidance to “streamlinepolicy guidance to “streamline the deliverythe delivery of Funeral of Funeral
Assistance” because of the “unprecedented number of deaths caused by COVID-19.” Assistance” because of the “unprecedented number of deaths caused by COVID-19.”
(FEMA, (FEMA, IAPPG, p. 148; FEMA, “FEMA Policy: COVID-19 Funeral Assistance:, p. 148; FEMA, “FEMA Policy: COVID-19 Funeral Assistance: Individuals and Households Program Individuals and Households Program
Policy (Interim), v. 2, FEMA Policy # 104-21-0001, June 29, 2021, https://www.fema.gov/sites/default/files/Policy (Interim), v. 2, FEMA Policy # 104-21-0001, June 29, 2021, https://www.fema.gov/sites/default/files/
documents/fema_covid-19-funeral-assistance-interim-policy-version-2_06-29-2021.pdf.) documents/fema_covid-19-funeral-assistance-interim-policy-version-2_06-29-2021.pdf.)
Child Care Assistance
Child Care Assistance is provided in the form of a one-time payment that covers up to eight Child Care Assistance is provided in the form of a one-time payment that covers up to eight
cumulative weeks of childcare and eligible expenses (e.g., registration fees), or the maximum cumulative weeks of childcare and eligible expenses (e.g., registration fees), or the maximum
amount of Child Care Assistance identified in the state/territory/tribe’s “ONA Administrative amount of Child Care Assistance identified in the state/territory/tribe’s “ONA Administrative
Option Selection Form,” whichever is less.112 The assistance can be used to care for children aged Option Selection Form,” whichever is less.112 The assistance can be used to care for children aged
13 and under, and/or children up to age 21 who have a disability13 and under, and/or children up to age 21 who have a disability as defined by federal law and as defined by federal law and
need assistance with activities of daily living.113 Three eligibilityneed assistance with activities of daily living.113 Three eligibility considerations are: (1) the considerations are: (1) the
increased financial burden for child care must be caused by the disaster either because of a increased financial burden for child care must be caused by the disaster either because of a
disaster-caused decrease in gross household income or a disaster-caused increase in the cost of disaster-caused decrease in gross household income or a disaster-caused increase in the cost of
child care;114 (2) other childcare services must not be available;115 and (3) the care provider must child care;114 (2) other childcare services must not be available;115 and (3) the care provider must

108 FEMA, 108 FEMA, IAPPG, pp. 150-152. , pp. 150-152.
109 FEMA, 109 FEMA, IAPPG, p. 150. , p. 150.
110 FEMA, 110 FEMA, IAPPG, p. 150 , p. 150
111 FEMA, 111 FEMA, IAPPG, p. 151. , p. 151.
112 FEMA, 112 FEMA, IAPPG, p. 155. , p. 155.
113 FEMA, 113 FEMA, IAPPG, p. 155. , p. 155. T heThe IAPPG defines defines activities of daily living as “routine activities that people tend to do as “routine activities that people tend to do
every day without needing assistance. every day without needing assistance. T hereThere are six basic are six basic ADLs [activities of daily living]: eating, bathing, dressing, ADLs [activities of daily living]: eating, bathing, dressing,
toileting, transferring (walking), and continence.” toileting, transferring (walking), and continence.”
114 FEMA, 114 FEMA, IAPPG, p. 156. , p. 156. T oTo determine if post-disaster child care costs create a financial burden, determine if post-disaster child care costs create a financial burden, according to the according to the
IAPPG “ “ FEMA compares the percentage of the household’s grossFEMA compares the percentage of the household’s gross income spent for child care expenses before the income spent for child care expenses before the
disaster to the percentage spent following the disaster.... If the percentage of household gross income spent on child disaster to the percentage spent following the disaster.... If the percentage of household gross income spent on child
care postcare post -disaster is higher than the percentage of household gross income spent on child care pre-disaster is higher than the percentage of household gross income spent on child care pre -disaster, the -disaster, the
household has an increasedhousehold has an increased financial burdenfinancial burden for child care and may be eligiblefor child care and may be eligible for assistancefor assistance to cover the increase.” to cover the increase.”
EligibleEligible individuals individuals and householdsand households may receive FEMA assistance for the difference spent on premay receive FEMA assistance for the difference spent on pre - and post- and post -disaster -disaster
child care. child care.
115 FEMA, 115 FEMA, IAPPG, p. 156. , p. 156.
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be licensed, regulated, or registered per the applicable state, territory, tribal or local government’s be licensed, regulated, or registered per the applicable state, territory, tribal or local government’s
laws.116 laws.116
Medical and Dental Assistance
Medical and Dental Assistance provides funding to assist with medical and dental expenses (e.g., Medical and Dental Assistance provides funding to assist with medical and dental expenses (e.g.,
injury, injury, il nessillness, loss of prescribed medication or equipment, insurance deductibles and , loss of prescribed medication or equipment, insurance deductibles and
copayments, and loss or injury of a service animal).117 Unlike most forms of IHP assistance, copayments, and loss or injury of a service animal).117 Unlike most forms of IHP assistance,
applicants do not need to live in the designated declared area, provided they incurred medical or applicants do not need to live in the designated declared area, provided they incurred medical or
dental expenses as a direct result of the dental expenses as a direct result of the presidential ypresidentially declared emergency or major disaster.118 declared emergency or major disaster.118
Miscellaneous Expenses
Miscel aneousMiscellaneous Expenses provides funding to reimburse people for purchasing or renting eligible Expenses provides funding to reimburse people for purchasing or renting eligible
items to assist with their disaster recovery efforts.119 Eligible items can include carbon monoxide items to assist with their disaster recovery efforts.119 Eligible items can include carbon monoxide
and smoke detectors, dehumidifiers or humidifiers, chainsaws, generators, and weather radios,120 and smoke detectors, dehumidifiers or humidifiers, chainsaws, generators, and weather radios,120
but the availabilitybut the availability of such items of such items wil will depend on what the state, territory, or Indian tribal depend on what the state, territory, or Indian tribal
government included in the government included in the miscel aneousmiscellaneous line items on their “ONA Administrative Option line items on their “ONA Administrative Option
Selection Form”; additional Selection Form”; additional miscel aneousmiscellaneous items could also be included by the state, territory, or items could also be included by the state, territory, or
tribe.121 tribe.121
Moving and Storage Assistance
Moving and Storage Assistance122 provides funding to store and then return essential personal Moving and Storage Assistance122 provides funding to store and then return essential personal
property and households goods to a repaired primary residence, or relocate essential personal property and households goods to a repaired primary residence, or relocate essential personal
property and households goods to a new primary residence, to avoid additional damage to such property and households goods to a new primary residence, to avoid additional damage to such
items.123 A few limitations on the receipt of assistance include (1) expenses are limited to the items.123 A few limitations on the receipt of assistance include (1) expenses are limited to the
period of assistance (i.e., 18 months following the date of the declaration) or up to the maximum period of assistance (i.e., 18 months following the date of the declaration) or up to the maximum
amount of financial assistance for ONA, whichever comes first; and (2) if the damage results amount of financial assistance for ONA, whichever comes first; and (2) if the damage results
from flooding and the applicant failed to maintain flood insurance as a condition of receiving from flooding and the applicant failed to maintain flood insurance as a condition of receiving
previous federal assistance, then FEMA previous federal assistance, then FEMA wil will not provide assistance for the first $1,000 of not provide assistance for the first $1,000 of
expenses.124

expenses.124 Critical Needs Assistance Critical Needs Assistance (sometimes referred to as “Immediate Needs Assistance”) can be requested by an affected state, territory, or Indian tribal government within 14 days of a Stafford 116 FEMA, 116 FEMA, IAPPG, p. 156. , p. 156.
117 FEMA, 117 FEMA, IAPPG, p. 153. , p. 153.
118 FEMA, 118 FEMA, IAPPG, p. 153. , p. 153.
119 FEMA, 119 FEMA, IAPPG, pp. 160-162. , pp. 160-162.
120 FEMA, 120 FEMA, IAPPG, pp. 160-162. Miscellaneous items may assist disaster survivors with gaining access, pp. 160-162. Miscellaneous items may assist disaster survivors with gaining access to their property to their property
or assistingor assisting with cleaning efforts. Reimbursements for chainsawswith cleaning efforts. Reimbursements for chainsaws and generators are permitted under limited and generators are permitted under limited
circumstances if certain conditions are met. circumstances if certain conditions are met.
121 FEMA, 121 FEMA, IAPPG, pp. 160-161. Per the , pp. 160-161. Per the IAPPG, “Assistance for Miscellaneous Items is limited to the quantity , “Assistance for Miscellaneous Items is limited to the quantity
establishedestablished for the item by the for the item by the ST T STT government on the ‘ONA Administrative Option Selection Form.’”government on the ‘ONA Administrative Option Selection Form.’”
122 Previously, Moving and Storage Assistance was122 Previously, Moving and Storage Assistance was classified classified as SBA-Dependent ONA. It wasas SBA-Dependent ONA. It was updated updated to a Non-SBA-to a Non-SBA-
Dependent category of ONA in Version 1.1 of FEMA’s Dependent category of ONA in Version 1.1 of FEMA’s IAPPG (FEMA, (FEMA, IAPPG, p. 9). , p. 9).
123 FEMA, 123 FEMA, IAPPG, p. 162. , p. 162.
124 FEMA,124 FEMA, IAPPG, pp. 162 and 164. , pp. 162 and 164.
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Critical Needs Assistance
Critical Needs Assistance (sometimes referred to as “Immediate Needs Assistance”) can be
requested by an affected state, territory, or Indian tribal government within 14 days of a Stafford
Act declaration, when needed, to assist applicants from a specific geographic area who are Act declaration, when needed, to assist applicants from a specific geographic area who are
displaced from their primary residence or who have to temporarily shelter elsewhere.125 The displaced from their primary residence or who have to temporarily shelter elsewhere.125 The
eligibility eligibility period is period is general ygenerally up to 30 days from the Stafford Act declaration (unless an extension up to 30 days from the Stafford Act declaration (unless an extension
is requested by affected state, territory, or tribe, and approved by FEMA).126 Critical Needs is requested by affected state, territory, or tribe, and approved by FEMA).126 Critical Needs
AssistanceAssistance is provided in the form of a one-time payment of $500 per household and can be used is provided in the form of a one-time payment of $500 per household and can be used
to purchase life-saving and life-sustaining items; the non-exhaustive list of life-saving and life-to purchase life-saving and life-sustaining items; the non-exhaustive list of life-saving and life-
sustaining items includes “water, food, first aid, prescriptions, infant formula, diapers, CMS sustaining items includes “water, food, first aid, prescriptions, infant formula, diapers, CMS
[consumable medical supplies], DME [durable medical equipment], personal hygiene items, and [consumable medical supplies], DME [durable medical equipment], personal hygiene items, and
fuel for transportation.”127 fuel for transportation.”127
Clean and Sanitize Assistance
Clean and Sanitize Assistance (CSA) is an expanded form of the previously available, Clean and Clean and Sanitize Assistance (CSA) is an expanded form of the previously available, Clean and
Removal Assistance. CSA can be requested by an affected state, territory, or Indian tribal Removal Assistance. CSA can be requested by an affected state, territory, or Indian tribal
government and approved by FEMA for any type of incident (the previous version of this government and approved by FEMA for any type of incident (the previous version of this
assistance, referred to as Clean and Removal Assistance, was limited to “flood” incidents).128 assistance, referred to as Clean and Removal Assistance, was limited to “flood” incidents).128
CSA is provided in the form of a one-time payment, which is limited to $300 (previously, Clean CSA is provided in the form of a one-time payment, which is limited to $300 (previously, Clean
and Removal Assistance was limited to $550 per household), to “ensure minimal damage to the and Removal Assistance was limited to $550 per household), to “ensure minimal damage to the
home is addressed in order to prevent additional losses and potential health and safety home is addressed in order to prevent additional losses and potential health and safety
concerns.”129 Eligibilityconcerns.”129 Eligibility is limited to applicants who do not qualify for Home Repair Assistance is limited to applicants who do not qualify for Home Repair Assistance
because their primary residence was not rendered uninhabitable.130 because their primary residence was not rendered uninhabitable.130
Legislative Changes and Significant Program Updates: ONA
As described in detail As described in detail above in the above in the “Legislative Changes and Significant Program Updates:
Housing Assistance”
section, DRRA Section 1212 amended the provision of ONA by establishing section, DRRA Section 1212 amended the provision of ONA by establishing
separate financial caps of equal amounts for ONA and Financial Housing Assistance, and creating separate financial caps of equal amounts for ONA and Financial Housing Assistance, and creating
an exception to the cap for accessibility-related repair or replacement costs (for a list of eligible an exception to the cap for accessibility-related repair or replacement costs (for a list of eligible
personal property items, see the shaded text box “Accessibility Items Eligiblepersonal property items, see the shaded text box “Accessibility Items Eligible for Personal for Personal
Property Assistance”).131 Property Assistance”).131

Approving Requests for Individual Assistance Federal assistance is intended to supplement—not supplant—the local, state, territory, or Indian tribal government’s response and recovery efforts.132 For this reason, state, territory, and Indian 125 FEMA,125 FEMA, IAPPG, p. 164. , p. 164.
126 FEMA, 126 FEMA, IAPPG, p. 164. , p. 164.
127 FEMA, 127 FEMA, IAPPG, pp. 164-165. , pp. 164-165.
128 Memorandum from Keith 128 Memorandum from Keith T uriTuri RE: Amendment to the IAPPG, p. 11; and FEMA, RE: Amendment to the IAPPG, p. 11; and FEMA, IAPPG, p. 165. , p. 165.
129 Memorandum from Keith 129 Memorandum from Keith T uriTuri RE: Amendment to the IAPPG, pp. 11 RE: Amendment to the IAPPG, pp. 11 -12. -12.
130 Memorandum from Keith 130 Memorandum from Keith T uriTuri RE: Amendment to the IAPPG, p. 11 RE: Amendment to the IAPPG, p. 11 . .
131 DRRA131 DRRA Section 1212. For more information on DRRA, see CRSSection 1212. For more information on DRRA, see CRS Report R46776, Report R46776, The Disaster Recovery Reform Act
of 2018 (DRRA): Im plementationImplementation Updates for Select Provisions
, coordinated by Elizabeth M. Webster and Bruce, coordinated by Elizabeth M. Webster and Bruce R. R.
Lindsay; and CRSLindsay; and CRS Report R45819, Report R45819, The Disaster Recovery Reform Act of 2018 (DRRA): A Sum m arySummary of Selected
Statutory Provisions
, coordinated by Elizabeth M. Webster and Bruce, coordinated by Elizabeth M. Webster and Bruce R. LindsayR. Lindsay .
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Approving Requests for Individual Assistance
Federal assistance is intended to supplement—not supplant—the local, state, territory, or Indian
tribal government’s response and recovery efforts.132 For this reason, state, territory, and Indian
tribal governments do not automatical y. 132 The governor or chief executive’s request must document that the “situation is of such severity and magnitude that effective response is beyond the capabilities of the State and affected local governments” and that supplemental federal assistance is necessary (44 C.F.R. §§206.35 and 206.36). To justify a declaration of emergency, supplemental federal assistance must be needed to “save lives and to protect property, public health and safety, or to lessen or avert the threat (continued...) Congressional Research Service 21 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations tribal governments do not automatically receive a presidential declaration of emergency or major receive a presidential declaration of emergency or major
disaster, nor do they disaster, nor do they automatical yautomatically receive Individual Assistance (IA).133 Instead, following an receive Individual Assistance (IA).133 Instead, following an
incident,134 the governor or chief executive must request that the President declare an emergency ,134 the governor or chief executive must request that the President declare an emergency
or major disaster authorizing IA.135 The governor or chief executive’s request must demonstrate or major disaster authorizing IA.135 The governor or chief executive’s request must demonstrate
that they are unable to effectively respond to the incident without federal assistance.136 To that that they are unable to effectively respond to the incident without federal assistance.136 To that
end, the request must include information about the actions taken and resources that have been or end, the request must include information about the actions taken and resources that have been or
wil will be committed, and an estimate of the amount and severity of the disaster-caused damages, in be committed, and an estimate of the amount and severity of the disaster-caused damages, in
addition to other required information.137 addition to other required information.137
Using the information submitted by the governor or chief executive in their major disaster Using the information submitted by the governor or chief executive in their major disaster
declaration request, FEMA evaluates specific factors to determine whether there is a need for declaration request, FEMA evaluates specific factors to determine whether there is a need for
supplemental federal assistance to individuals (i.e., IA).138 This includes information collected supplemental federal assistance to individuals (i.e., IA).138 This includes information collected
through the Preliminary Damage Assessment (PDA) process, which is validated by local, state, through the Preliminary Damage Assessment (PDA) process, which is validated by local, state,
territory, Indian tribal government, and federal authorities.139 FEMA then provides a territory, Indian tribal government, and federal authorities.139 FEMA then provides a
recommendation to the President.140 The decision to grant an emergency or major disaster recommendation to the President.140 The decision to grant an emergency or major disaster
declaration request is at the President’s sole discretion.141 declaration request is at the President’s sole discretion.141
The President’s initial notice declaring a major disaster may indicate that IA has been authorized, The President’s initial notice declaring a major disaster may indicate that IA has been authorized,
and may specify the types of IA authorized. The notice also includes the sentenceand may specify the types of IA authorized. The notice also includes the sentence:
Further, you are authorized to make changes to this declaration for the approved assistance Further, you are authorized to make changes to this declaration for the approved assistance
to the extent allowable under the Stafford Act. to the extent allowable under the Stafford Act.

132 T he governor or chief executive’s request must document that the “situation is of such severity and magnitude that
effective response is beyond the capabilities of the State and affected local governments” and that supplemental federal
assistance is necessary (44 C.F.R. §§206.35 and 206.36). T o justify a declaration of emergency, supplemental federal
assistance must be needed to “save lives and to protect property, public health and safety, or to lessen or avert the threat
of a disaster” (44 C.F.R. §206.35). T o According to FEMA, this sentence has been included in presidential declarations under the Stafford Act since 2009, and it “authorizes FEMA to make changes to programs approved in the declaration (e.g., add counties), but not to approve additional forms of assistance. As such, since 2009, FEMA has sought White House approval when states [and territories] or tribes request additional types of assistance under a declaration.” Thus, although FEMA’s regulations state that FEMA has the delegated authority to “determine and designate the types of assistance to be made of a disaster” (44 C.F.R. §206.35). To justify a declaration of major disaster, federal assistance must be needed justify a declaration of major disaster, federal assistance must be needed to to
“supplement the efforts and available resources of the State, local governments, disaster relief organizations, and “supplement the efforts and available resources of the State, local governments, disaster relief organizations, and
compensation by insurance for disaster-related losses” (44 C.F.R.compensation by insurance for disaster-related losses” (44 C.F.R. §206.36). §206.36).
133 44 C.F.R. §§206.35-206.38, and 206.40(a); and FEMA, “ 133 44 C.F.R. §§206.35-206.38, and 206.40(a); and FEMA, “ How a Disaster GetsHow a Disaster Gets Declared.” Declared.”
134 An 134 An incident is is defined as “[a]ny condition which meets the definition of major disaster or emergency as set forth in defined as “[a]ny condition which meets the definition of major disaster or emergency as set forth in
§206.2 which causes§206.2 which causes damage damage or hardship that may result in a or hardship that may result in a P residentialPresidential declaration of a major disaster or an declaration of a major disaster or an
emergency” (44 C.F.R. §206.32(e)). emergency” (44 C.F.R. §206.32(e)).
135 42 U.S.C.135 42 U.S.C. §§5191 and 5170; 44 C.F.R. §§206.35, 206.36, 206.38, and 206.40(a); and FEMA, “How a Disaster Gets §§5191 and 5170; 44 C.F.R. §§206.35, 206.36, 206.38, and 206.40(a); and FEMA, “How a Disaster Gets
Declared.” It is possibleDeclared.” It is possible for the President to unilaterally declare an emergency under Stafford Act Section 501(b) when for the President to unilaterally declare an emergency under Stafford Act Section 501(b) when
the federal government has the primary responsibility for response because “the federal government has the primary responsibility for response because “ the emergency involves a subject area for the emergency involves a subject area for
which, underwhich, under the Constitution or laws of the United States, the United States exercises exclusive or preeminent the Constitution or laws of the United States, the United States exercises exclusive or preeminent
responsibility and authority.” For more information about the disaster declaration process, see CRSresponsibility and authority.” For more information about the disaster declaration process, see CRS Report R43784, Report R43784,
FEMA’s Disaster Declaration Process: A Primer, by Bruce, by Bruce R. Lindsay. R. Lindsay.
136 44 C.F.R. §§206.35 and 206.36. 136 44 C.F.R. §§206.35 and 206.36.
137 For a list and description of information requirements to accompany a governor or chief executive’s request for an 137 For a list and description of information requirements to accompany a governor or chief executive’s request for an
emergency declaration and a major disaster declaration, see 44 C.F.R. §206.35 and 44 C.F.R. §206.36, respectively.emergency declaration and a major disaster declaration, see 44 C.F.R. §206.35 and 44 C.F.R. §206.36, respectively.
138 44 C.F.R. §206.48(b); and FEMA, 138 44 C.F.R. §206.48(b); and FEMA, Tribal Declarations Pilot Guidance, pp. 36-38. , pp. 36-38.
139 FEMA, 139 FEMA, Preliminary Damage Assessment Guide, August, August 2021, p. 1, https://www.fema.gov/sites/default/files/2021, p. 1, https://www.fema.gov/sites/default/files/
documents/fema_2021-pda-guide.pdf (hereinafter FEMA, documents/fema_2021-pda-guide.pdf (hereinafter FEMA, Prelim inary Dam age Assessm entPreliminary Damage Assessment Guide). ).
140 44 C.F.R. §206.37(c). 140 44 C.F.R. §206.37(c).
141 44 C.F.R. §206.38. 141 44 C.F.R. §206.38.
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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

According to FEMA, this sentence has been included in presidential declarations under the
Stafford Act since 2009, and it “authorizes FEMA to make changes to programs approved in the
declaration (e.g., add counties), but not to approve additional forms of assistance. As such, since
2009, FEMA has sought White House approval when states [and territories] or tribes request
additional types of assistance under a declaration.” Thus, although FEMA’s regulations state that
FEMA has the delegated authority to “determine and designate the types of assistance to be made
available,” available,” in practice, FEMA has stated that they in practice, FEMA has stated that they wil will seek the President’s approval when seek the President’s approval when
authorizing additional forms of assistance.142 authorizing additional forms of assistance.142
The following sections describe the process by which FEMA evaluates a governor or chief The following sections describe the process by which FEMA evaluates a governor or chief
executive’s request for a major disaster authorizing Individual Assistance and, executive’s request for a major disaster authorizing Individual Assistance and, specifical yspecifically, IHP , IHP
assistance. assistance.
FEMA’s Evaluation of the IA Factors: Major Disaster
There is no automatic threshold for authorizing a request for Individual Assistance. Instead, There is no automatic threshold for authorizing a request for Individual Assistance. Instead,
FEMA’s regulations and guidance detail the factors that help FEMA assess the “severity, FEMA’s regulations and guidance detail the factors that help FEMA assess the “severity,
magnitude, and impact of a disaster, as magnitude, and impact of a disaster, as wel well as the capabilities of the affected jurisdictions” and as the capabilities of the affected jurisdictions” and
whether the incident has overwhelmed the requesting government’s capabilities, making Stafford whether the incident has overwhelmed the requesting government’s capabilities, making Stafford
Act assistance necessary.143 As noted above, FEMA evaluates these factors to provide the Act assistance necessary.143 As noted above, FEMA evaluates these factors to provide the
President with a recommendation regarding whether to declare a major disaster authorizing IA, President with a recommendation regarding whether to declare a major disaster authorizing IA,
and to identify the types of IA that should be made availableand to identify the types of IA that should be made available (e.g., low disaster-related (e.g., low disaster-related
unemployment may indicate there is not a need for Disaster Unemployment Assistance).144 unemployment may indicate there is not a need for Disaster Unemployment Assistance).144
Recent IA Legislation, Rulemaking, and Guidance
In 2018 and 2019, FEMA’s IA program, including the IHP, was modified through legislation and In 2018 and 2019, FEMA’s IA program, including the IHP, was modified through legislation and
changes to FEMA’s guidance. Following numerous natural disasters that affected the United changes to FEMA’s guidance. Following numerous natural disasters that affected the United
States, including Hurricanes Harvey, Irma, and Maria in 2017 and the devastating wildfires in States, including Hurricanes Harvey, Irma, and Maria in 2017 and the devastating wildfires in
California during 2017 and 2018, the Disaster Recovery Reform Act of 2018 (DRRA, Division D California during 2017 and 2018, the Disaster Recovery Reform Act of 2018 (DRRA, Division D
of P.L. 115-254) was enacted on October 5, 2018. DRRA amended many sections of the Stafford of P.L. 115-254) was enacted on October 5, 2018. DRRA amended many sections of the Stafford
Act, including sections related to the provision of IHP, to improve assistance and services Act, including sections related to the provision of IHP, to improve assistance and services
provided in support of disaster recovery. In addition, in early March 2019, FEMA released provided in support of disaster recovery. In addition, in early March 2019, FEMA released
updated guidance for managing IA:updated guidance for managing IA: Individual Assistance Program and Policy Guide (IAPPG), ,
which applies to emergencies and disasters declared on or after March 1, 2019. The which applies to emergencies and disasters declared on or after March 1, 2019. The IAPPG was was
updated in May 2021, including to incorporate the IA updates authorized by DRRA. updated in May 2021, including to incorporate the IA updates authorized by DRRA.
Further, on March 21, 2019, as required by Section 1109 of the Sandy Recovery Improvement Further, on March 21, 2019, as required by Section 1109 of the Sandy Recovery Improvement
Act of 2013 (SRIA, Division B of P.L. 113-2), FEMA issued its final rule revising the factors Act of 2013 (SRIA, Division B of P.L. 113-2), FEMA issued its final rule revising the factors
considered when evaluating a governor’s request for a major disaster authorizing IA to establish considered when evaluating a governor’s request for a major disaster authorizing IA to establish

more objective criteria for evaluating the need for assistance, to clarify eligibility requirements, and to expedite a presidential declaration determination (codified at 44 C.F.R. §206.48(b)).145 The updated factors became effective June 1, 2019. 142 44 C.F.R. §206.40; and email correspondence from FEMA Congressional Affairs staff, June 12, 2020.142 44 C.F.R. §206.40; and email correspondence from FEMA Congressional Affairs staff, June 12, 2020.
143 DHS/FEMA,143 DHS/FEMA, “Factors Considered When Evaluating a Governor’s Request“Factors Considered When Evaluating a Governor’s Request for Individualfor Individual Assistance for a Major Assistance for a Major
Disaster,” 84Disaster,” 84 Federal Register 10632, March 21, 2019, https://www.govinfo.gov/content/pkg/FR-2019-03-21/pdf/ 10632, March 21, 2019, https://www.govinfo.gov/content/pkg/FR-2019-03-21/pdf/
2019-05388.pdf (hereinafter DHS/FEMA, “2019-05388.pdf (hereinafter DHS/FEMA, “ Factors Considered When Evaluating a RequestFactors Considered When Evaluating a Request for IA”)for IA”) ; see also ; see also
DHS/FEMA,DHS/FEMA,Factors Considered When Evaluating a Governor’s RequestFactors Considered When Evaluating a Governor’s Request for Individualfor Individual Assistance for a Major Assistance for a Major
Disaster; Correction,” 84Disaster; Correction,” 84 Federal Register 25685, June 4, 2019, https://www.govinfo.gov/content/pkg/FR-2019-06-04/ 25685, June 4, 2019, https://www.govinfo.gov/content/pkg/FR-2019-06-04/
pdf/2019-11656.pdf; 44 C.F.R. §206.48(b); and FEMA, pdf/2019-11656.pdf; 44 C.F.R. §206.48(b); and FEMA, Tribal Declarations Pilot Guidance, pp. 34 and 36. , pp. 34 and 36.
Additionally, “Additionally, “ Appendix D; Appendix D; T ribalTribal-Specific Considerations” of FEMA’s -Specific Considerations” of FEMA’s Prelim inary Dam age Assessm entPreliminary Damage Assessment Guide
includesincludes useful useful resources and uniqueresources and unique considerations for Indian tribal governments during the PDA process.considerations for Indian tribal governments during the PDA process.
144 FEMA, 144 FEMA, Individual Assistance Declarations Factors Guidance, June 2019, p. 13, https://www.regulations.gov/, June 2019, p. 13, https://www.regulations.gov/
document/FEMA-2014-0005-0071 (hereinafter FEMA, document/FEMA-2014-0005-0071 (hereinafter FEMA, IA Declarations Factors Guidance). ).
145 Section 1109 of SRIA; DHS/FEMA, “Factors Considered When Evaluating a Request for IA”; and 44 C.F.R. §206.48(b). Congressional Research Service Congressional Research Service

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link to page 28 link to page 29 link to page 28 link to page 29 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

more objective criteria for evaluating the need for assistance, to clarify eligibility requirements,
and to expedite a presidential declaration determination (codified at 44 C.F.R. §206.48(b)).145 The
updated factors became effective June 1, 2019.
FEMA uses a separate set of factors when evaluating a chief executive of an Indian tribal FEMA uses a separate set of factors when evaluating a chief executive of an Indian tribal
government’s request for a major disaster authorizing IA.146 FEMA’s release of the government’s request for a major disaster authorizing IA.146 FEMA’s release of the Tribal
Declarations Pilot Guidance
in January 2017, made effective specific factors considered when in January 2017, made effective specific factors considered when
evaluating a chief executive’s request for a major disaster declaration authorizing IA.147 The pilot evaluating a chief executive’s request for a major disaster declaration authorizing IA.147 The pilot
period for the factors used to evaluate a chief executive’s request for a Stafford Act declaration period for the factors used to evaluate a chief executive’s request for a Stafford Act declaration
began January 10, 2017, and is ongoing. Following this pilot period, FEMAbegan January 10, 2017, and is ongoing. Following this pilot period, FEMA has stated that it plans to implement plans to implement
this authority through a rulemaking.148 this authority through a rulemaking.148
IA Factors
Per FEMA’s regulations and guidance, the IA factors FEMA evaluates differ depending on Per FEMA’s regulations and guidance, the IA factors FEMA evaluates differ depending on
whether the requesting entity is a state/territory or Indian tribal governmentwhether the requesting entity is a state/territory or Indian tribal government. Table 2 lists the lists the
factors considered when evaluating IA requests made by a governor of an affected state or factors considered when evaluating IA requests made by a governor of an affected state or
territory, as territory, as wel well as a chief executive of an affected Indian tribal governmentas a chief executive of an affected Indian tribal government. Figure 3 lists the lists the
various forms of IA and the associated IA factors that FEMA considers when recommending various forms of IA and the associated IA factors that FEMA considers when recommending
which IA programs to authorize pursuant to a governor’s request for a major disaster declaration which IA programs to authorize pursuant to a governor’s request for a major disaster declaration
authorizing IA. authorizing IA.
Table 2. Individual Assistance Factors for States/Territories and Tribes
Factors Considered When When Evaluating a
Factors Considered When When Evaluating a
Governor’s Request for IA
Chief Executive’s Request for IA
State Fiscal Capacity and Resource Availability State Fiscal Capacity and Resource Availability
Tribal Government Resources Tribal Government Resources
Uninsured Home Uninsured Home and Personal Property Losses and Personal Property Losses
Voluntary Agency and Other Assistance Voluntary Agency and Other Assistance
Disaster-Impacted Population Profile Disaster-Impacted Population Profile
Availability Availability of Housing Resourcesof Housing Resources
Impact to Community Infrastructure Impact to Community Infrastructure
Uninsured Home Uninsured Home and Personal Property Lossesand Personal Property Losses
Casualties Casualties
Disaster-Impacted Population Profile Disaster-Impacted Population Profile
Disaster Disaster Related Unemployment Related Unemployment
Impact to Community Infrastructure Impact to Community Infrastructure
Casualties Casualties
The Unique Conditions That May Affect Tribal The Unique Conditions That May Affect Tribal
GovernmentsGovernments
Sources: 44 C.F.R.44 C.F.R. §206.48(b); and FEMA, §206.48(b); and FEMA, Tribal Declarations Pilot Guidance,, January 2017, pp. 36-38, January 2017, pp. 36-38,
https://www.fema.gov/sites/default/files/2020-04/tribal-declaration-pilot-guidance.pdf. https://www.fema.gov/sites/default/files/2020-04/tribal-declaration-pilot-guidance.pdf.

145 Section 1109 of SRIA; DHS/FEMA, “ Factors Considered When Evaluating a Request for IA”; and 44 C.F.R.
§206.48(b).
Notes: FEMA also considers other relevant information provided by the state, territory, or tribe in its declaration request. 146 Initially, the factors for states/territories and Indian tribal governments were the same.146 Initially, the factors for states/territories and Indian tribal governments were the same. Section 1110 of the Sandy Section 1110 of the Sandy
Recovery Improvement Act of 2013 (SRIA, Division BRecovery Improvement Act of 2013 (SRIA, Division B of P.L. 113-2) amended Stafford Act Sections 401 and 501 (42 of P.L. 113-2) amended Stafford Act Sections 401 and 501 (42
U.S.C.U.S.C. §§5170 and 5191) to enable chief executives of affected Indian tribal governments to request a major disaster or §§5170 and 5191) to enable chief executives of affected Indian tribal governments to request a major disaster or
emergency (alternatively, the Indian tribe may receive assistance through the state’s declaration). Initially, FEMA used emergency (alternatively, the Indian tribe may receive assistance through the state’s declaration). Initially, FEMA used
the same factors to evaluate a governor or chief executive’s request for a presidential major disaster declaration, which the same factors to evaluate a governor or chief executive’s request for a presidential major disaster declaration, which
allowedallowed Indian tribal governments to exercise this authority immediately upon SRIA’s enactment. According to Indian tribal governments to exercise this authority immediately upon SRIA’s enactment. According to
FEMA’s websiteFEMA’s website “T ribal “Tribal Declarations Pilot Guidance,” available Declarations Pilot Guidance,” available at https://www.fema.gov/disasters/tribal-declarations, at https://www.fema.gov/disasters/tribal-declarations,
the period when Indian tribal governments could usethe period when Indian tribal governments could use the state/the state/t erritoryterritory regulations ran from January 29, 2013, when regulations ran from January 29, 2013, when
SRIASRIA was was enacted, through January 9, 2017, when FEMA releasedenacted, through January 9, 2017, when FEMA released its its Tribal Declarations Pilot Guidance. .
147 FEMA, 147 FEMA, Tribal Declarations Pilot Guidance. .
148 FEMA, “148 FEMA, “ T ribalTribal Declarations Pilot Guidance,” https://www.fema.gov/disaster/tribal-declarations. Declarations Pilot Guidance,” https://www.fema.gov/disaster/tribal-declarations.
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link to page link to page 5453
FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

Notes: FEMA also considers other relevant information provided by the state, territory, or tribe in its
declaration request.
Figure 3. IA Programs and Consideration Factors

Source: Developed Developed by CRS based on the FEMA, by CRS based on the FEMA, Individual Assistance Declarations Factors Factors Guidance, June 2019, p. , June 2019, p.
13, https://www.regulations.gov/document/FEMA-2014-0005-0071. 13, https://www.regulations.gov/document/FEMA-2014-0005-0071.
Notes: This figure is based on the table listing the Individual Assistance (IA) programs and factors that FEMA This figure is based on the table listing the Individual Assistance (IA) programs and factors that FEMA
considersconsiders when evaluating a governor’swhen evaluating a governor’s request for a majorrequest for a major disaster declaration authorizing IA. disaster declaration authorizing IA.
Evaluating the Need for IHP Assistance: Governor’s Request for a Major
Disaster

Just as there is no automatic threshold for authorizing a request for IA, there is no automatic Just as there is no automatic threshold for authorizing a request for IA, there is no automatic
threshold for authorizing IHP assistance.149 Instead, per the FEMA regulation related to threshold for authorizing IHP assistance.149 Instead, per the FEMA regulation related to
evaluating a governor’s request for IA, two principal factors are considered when evaluating the evaluating a governor’s request for IA, two principal factors are considered when evaluating the
need for the IHP:need for the IHP:
1. Fiscal Capacity; and 1. Fiscal Capacity; and
2. Uninsured Home and Personal Property Losses.150 2. Uninsured Home and Personal Property Losses.150
FEMA’s evaluation of the Fiscal Capacity factor is detailed i FEMA’s evaluation of the Fiscal Capacity factor is detailed in Appendix A. Information Information
collected during the damage assessment process is submitted to FEMA to support the agency’s collected during the damage assessment process is submitted to FEMA to support the agency’s
evaluation of the Uninsured Home and Personal Property Losses factor. evaluation of the Uninsured Home and Personal Property Losses factor. Additional yAdditionally, the damage , the damage
assessment process helps establish the estimated cost of assistance. assessment process helps establish the estimated cost of assistance.

Per FEMA’s Preliminary Damage Assessment Guide, “The cost of assistance estimate is established by assessing and categorizing the degree of damage of disaster-impacted residences.” 149 FEMA, 149 FEMA, IA Declarations Factors Guidance, p. 15. , p. 15.
150 Per 44 C.F.R. §206.48(b), “State fiscal capacity (44 CFR 206.48(b)(1)(i)) and uninsured home and150 Per 44 C.F.R. §206.48(b), “State fiscal capacity (44 CFR 206.48(b)(1)(i)) and uninsured home and personal property personal property
losseslosses (44 CFR(44 CFR 206.48(b)(2)) are the principal factors that FEMA will206.48(b)(2)) are the principal factors that FEMA will consider when evaluating the need for consider when evaluating the need for
supplemental Federal assistance undersupplemental Federal assistance under the Individualsthe Individuals and Householdsand Households Program but FEMA willProgram but FEMA will always always consider all consider all
relevant information submitted as part of a declaration request. If the need for supplemental Federalrelevant information submitted as part of a declaration request. If the need for supplemental Federal assistance under assistance under
the Individualsthe Individuals and Householdsand Households Program is not clear from the evaluation of the principal factors, FEMA willProgram is not clear from the evaluation of the principal factors, FEMA will turn to the turn to the
other factors to determine the level of need.” other factors to determine the level of need.”
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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

Per FEMA’s Preliminary Damage Assessment Guide, “The cost of assistance estimate is
established by assessing and categorizing the degree of damage of disaster-impacted residences.”
FEMA established four categories of damage: (1) destroyed; (2) major; (3) minor; or (4) affected. FEMA established four categories of damage: (1) destroyed; (2) major; (3) minor; or (4) affected.
According to FEMA’s According to FEMA’s Preliminary Damage Assessment Guide, the cost of assistance estimate , the cost of assistance estimate
“encompasses a significant portion of a Presidential disaster declaration request.” However, “encompasses a significant portion of a Presidential disaster declaration request.” However,
although it is a significant consideration, other information is submitted as part of the declaration although it is a significant consideration, other information is submitted as part of the declaration
request package, and FEMA considers request package, and FEMA considers al all relevant information submitted by the requesting relevant information submitted by the requesting
state/territory or tribe. Moreover, FEMA’s guidance explains, state/territory or tribe. Moreover, FEMA’s guidance explains,
There There is no set number of damaged homes that will automatically trigger a is no set number of damaged homes that will automatically trigger a Presidential Presidential
disasterdisaster declaration declaration for a state,for a state, tribe, or territory. Each disastertribe, or territory. Each disaster must be evaluated must be evaluated
individually on the impacts that have overwhelmed the capacity and resources of the state, individually on the impacts that have overwhelmed the capacity and resources of the state,
tribal, or territorial government.tribal, or territorial government. During During the PDA process,the PDA process, state,state, tribal, or territorial tribal, or territorial
governments should consider all factors that FEMA uses to evaluate a disaster request and governments should consider all factors that FEMA uses to evaluate a disaster request and
write a compelling impact statement to demonstrate how the impacts of the disaster have write a compelling impact statement to demonstrate how the impacts of the disaster have
generally outweighed the capacity and resources of the impacted governments.151 generally outweighed the capacity and resources of the impacted governments.151
Although there is no set threshold, FEMA has provided requesting states/territories with Although there is no set threshold, FEMA has provided requesting states/territories with
information to help them evaluate the likelihoodinformation to help them evaluate the likelihood that their request for a major disaster declaration that their request for a major disaster declaration
authorizing IA authorizing IA wil will be approved, which is based on historic approval data.152 be approved, which is based on historic approval data.152 Specifical ySpecifically, FEMA , FEMA
provided data reflecting IA approvals versus estimated cost of assistance dollar ranges. This data provided data reflecting IA approvals versus estimated cost of assistance dollar ranges. This data
demonstrates that the higher the estimated cost of IHP assistance, the more likely a request demonstrates that the higher the estimated cost of IHP assistance, the more likely a request wil be
will be granted—“given other factors that may be taken into account.”153granted—“given other factors that may be taken into account.”153
FEMA also provided data showing approved disaster declarations for different IHP Cost-to- FEMA also provided data showing approved disaster declarations for different IHP Cost-to-
Capacity (ICC) Ratios, which compare the estimated cost of IHP assistance to the state’s fiscal Capacity (ICC) Ratios, which compare the estimated cost of IHP assistance to the state’s fiscal
resources (see the “ICC Ratio Formula” text box).154 The higher the estimated cost of IHP resources (see the “ICC Ratio Formula” text box).154 The higher the estimated cost of IHP
assistance and the lower the state’s fiscal resources, the more likely a request assistance and the lower the state’s fiscal resources, the more likely a request wil will be granted.155be granted.155
ICC Ratio Formula
The Individuals and Households The Individuals and Households Program (IHP) Cost-to-Capacity (ICC) Ratio is derived fromProgram (IHP) Cost-to-Capacity (ICC) Ratio is derived from a ratio of the a ratio of the
estimated cost of IHP assistance based on the Preliminaryestimated cost of IHP assistance based on the Preliminary Damage AssessmentDamage Assessment (PDA) to the state’s Total Taxable (PDA) to the state’s Total Taxable
ResourcesResources (TTR). The ICC Ratio may be considered(TTR). The ICC Ratio may be considered to provide an indication of the likelihoodto provide an indication of the likelihood that IHP assistance that IHP assistance
wilwil be authorized. be authorized.

ICC Ratio = Estimated Cost of IHP from PDA ICC Ratio = Estimated Cost of IHP from PDA
(State TTR in bil ions / $1 mil ion) (State TTR in bil ions / $1 mil ion)

The estimated cost of IHP assistance comes from informationThe estimated cost of IHP assistance comes from information col ected during the PDA process on uninsured col ected during the PDA process on uninsured
home and personal property losseshome and personal property losses (this relates(this relates to the Uninsured Hometo the Uninsured Home and Personal Property Lossesand Personal Property Losses factor). factor).
TTR data is calculated TTR data is calculated annual yannually by the U.S. Department of the Treasury and represents by the U.S. Department of the Treasury and represents the “unduplicated sum of the “unduplicated sum of
the income flows produced within a State and the incomethe income flows produced within a State and the income flows, receivedflows, received by its residents,by its residents, which a State could which a State could
potential ypotentially tax” (this relates to the Fiscal tax” (this relates to the Fiscal Capacity factor). Capacity factor).

151 FEMA, 151 FEMA, Preliminary Damage Assessment Guide, pp. 28-41. , pp. 28-41.
152 FEMA, 152 FEMA, IA Declarations Factors Guidance, pp. 14-15. , pp. 14-15.
153 FEMA, 153 FEMA, IA Declarations Factors Guidance, p. 14. According to FEMA, based, p. 14. According to FEMA, based on historical request data from 2008 on historical request data from 2008
to 2016, incidents for which the dollar amount of estimated costs of assistance wasto 2016, incidents for which the dollar amount of estimated costs of assistance was $1.5 million or less$1.5 million or less were were declared declared
6% of the time; incidents for which the dollar amount of estimated costs of assistance was6% of the time; incidents for which the dollar amount of estimated costs of assistance was between $1.5 million and between $1.5 million and
$7.5 million were declared$7.5 million were declared 42% of the time, and incidents for which the dollar amount of estimated costs of assistance 42% of the time, and incidents for which the dollar amount of estimated costs of assistance
waswas $7.5 million or more were$7.5 million or more were declared declared 90% of the time. 90% of the time.
154 FEMA, 154 FEMA, IA Declarations Factors Guidance, p. 14. , p. 14.
155 FEMA, 155 FEMA, IA Declarations Factors Guidance, p. 15. , p. 15.
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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

According to FEMA, based on historical request data from 2008 to 2016, incidents with an ICC Ratio greater than According to FEMA, based on historical request data from 2008 to 2016, incidents with an ICC Ratio greater than
25 receive25 receive IHP assistance 85% of the time; incidents with an ICC Ratio between 10 and 25 receiveIHP assistance 85% of the time; incidents with an ICC Ratio between 10 and 25 receive IHP assistance IHP assistance
45% of the time,45% of the time, and incidents with an ICC Ratio lessand incidents with an ICC Ratio less than 10 receivethan 10 receive IHP assistance 10% of the time. IHP assistance 10% of the time.
(FEMA, (FEMA, Individual Assistance Declarations Factors Guidance,, p. 14; FEMA, p. 14; FEMA, Preliminary Damage Assessment Guide, p. 28; , p. 28;
and U.S. Department of and U.S. Department of the Treasury (Treasury), “Total Taxable Resources,Treasury (Treasury), “Total Taxable Resources, Estimates,”Estimates,” https://home.treasury.gov/https://home.treasury.gov/
policy-issues/economic-policy/total-taxable-resources.policy-issues/economic-policy/total-taxable-resources. For an overviewFor an overview of TTR, including how it is estimated and of TTR, including how it is estimated and
the limitationsthe limitations of using TTR as a measurementof using TTR as a measurement of fiscal capacity, see Treasury,of fiscal capacity, see Treasury, Office of Economic Policy,Office of Economic Policy, Treasury
Methodology for Estimating Total Taxable Resources (TTR)
, December, December 2002, https://www.treasury.gov/resource-2002, https://www.treasury.gov/resource-
center/economic-policy/Documents/nmpubsum.pdf.) center/economic-policy/Documents/nmpubsum.pdf.)
Additional y, Additionally, FEMA released information about the potential for IHP approval based on a FEMA released information about the potential for IHP approval based on a
comparison of the estimated cost of IHP assistance and the ICC Ratio, as depicted icomparison of the estimated cost of IHP assistance and the ICC Ratio, as depicted in Figure 4.
This figure combines the information in FEMA’s guidance on the IA factors related to the This figure combines the information in FEMA’s guidance on the IA factors related to the
estimated cost of assistance for past requested and approved declarations156 and the ICC Ratio for estimated cost of assistance for past requested and approved declarations156 and the ICC Ratio for
past requested and approved declarations.157 Again, this information is only intended to provide past requested and approved declarations.157 Again, this information is only intended to provide
an indication of the likelihoodan indication of the likelihood of a request being approved; it does not represent a threshold for of a request being approved; it does not represent a threshold for
when IA and the IHP when IA and the IHP wil will be authorized. be authorized.
Figure 4. Potential for IHP Approval based on a comparison of the Estimated Cost of
IHP Assistance and the ICC Ratio

Source: Developed Developed by CRS based on the Federalby CRS based on the Federal Emergency Management Agency (FEMA), “Individual Emergency Management Agency (FEMA), “Individual
AssistanceAssistance Declarations Factors Final Rule and Guidance,” webinar, AprilDeclarations Factors Final Rule and Guidance,” webinar, April 30, 2019; FEMA, “Individual Assistance 30, 2019; FEMA, “Individual Assistance
Declarations:Declarations: New Rule and Guidance,” PowerPoint slides,New Rule and Guidance,” PowerPoint slides, May 2019. A copy of the PowerPoint may be May 2019. A copy of the PowerPoint may be
provided to congressional clientsprovided to congressional clients by CRS upon request. by CRS upon request.
Notes: FEMA expanded on its FEMA expanded on its Individual Assistance Declarations Factors Guidance in the webinar and associated in the webinar and associated
PowerPoint by providing an examplePowerPoint by providing an example of how the Estimated Cost of Individuals and Households Programof how the Estimated Cost of Individuals and Households Program (IHP) (IHP)
Assistance Assistance and the IHP Cost-to-Capacity Ratio—or ICC Ratio—may relateand the IHP Cost-to-Capacity Ratio—or ICC Ratio—may relate to the likelihoodto the likelihood a a
state/territory/Indian tribal government wilstate/territory/Indian tribal government wil receive receive IHP Assistance.IHP Assistance. As described above, there are no thresholds As described above, there are no thresholds
for receiving IHP assistance, so in for receiving IHP assistance, so in al all instances, it is possibleinstances, it is possible that the request for assistance could be authorized, that the request for assistance could be authorized,
regardlessregardless of the estimatedof the estimated cost of IHP assistance and the ICC Ratio.cost of IHP assistance and the ICC Ratio.
According to FEMA’s guidance on the IA factors, after the principal factors are evaluated (i.e., According to FEMA’s guidance on the IA factors, after the principal factors are evaluated (i.e.,
(1) Fiscal Capacity and (2) Uninsured Home and Personal Property Losses), FEMA (1) Fiscal Capacity and (2) Uninsured Home and Personal Property Losses), FEMA wil will consider consider
the remaining factors, as appropriate.158 States/territories should also include other relevant the remaining factors, as appropriate.158 States/territories should also include other relevant
information in their major disaster declaration request, as detailed in FEMA’s regulation at 44 information in their major disaster declaration request, as detailed in FEMA’s regulation at 44

C.F.R. §206.48(b), and in FEMA’s Preliminary Damage Assessment Guide and Individual 156 FEMA, 156 FEMA, IA Declarations Factors Guidance, p. 14. See, p. 14. See the information provided in “the information provided in “T ableTable 1: Estimated Cost of 1: Estimated Cost of
Assistance Compared to Declaration Decision Comparative.” Assistance Compared to Declaration Decision Comparative.”
157 FEMA, 157 FEMA, IA Declarations Factors Guidance, p. 14. See, p. 14. See the information provided in “the information provided in “T ableTable 2: Number 2: Number of IA Requests of IA Requests
and Granted IA Requestsand Granted IA Requests by ICCby ICC Ratio.”Ratio.”
158 FEMA, 158 FEMA, IA Declarations Factors Guidance, p. 15. , p. 15.
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C.F.R. §206.48(b), and in FEMA’s Preliminary Damage Assessment Guide and Individual
Assistance Declarations Factors Guidance
. FEMA . FEMA wil will provide a recommendation for the provide a recommendation for the
President based on President based on al all of the availableof the available information, which information, which wil will be forwarded to the President with be forwarded to the President with
the governor’s request.159 Ultimately, however, the decision to approve a governor’s request for a the governor’s request.159 Ultimately, however, the decision to approve a governor’s request for a
major disaster declaration authorizing IA is at the discretion of the President.160major disaster declaration authorizing IA is at the discretion of the President.160
A detailed description of A detailed description of al all of the IA factors can be found of the IA factors can be found inin Appendix A.
Implementing IHP Assistance
Once a presidential declaration of emergency or major disaster authorizing IA and assistance Once a presidential declaration of emergency or major disaster authorizing IA and assistance
through the IHP has been issued, individuals and households may apply to FEMA for assistance. through the IHP has been issued, individuals and households may apply to FEMA for assistance.
The following sections provide a brief overview of the application process for individuals, as The following sections provide a brief overview of the application process for individuals, as wel
well as eligibilityas eligibility requirements, and information on appealing FEMA’s decisions regarding the requirements, and information on appealing FEMA’s decisions regarding the
provision of IHP assistance.161 provision of IHP assistance.161
Applying for IHP Assistance
The following sections describe aspects of applying for IHP assistance, including the period when The following sections describe aspects of applying for IHP assistance, including the period when
applicants can register for assistance, and IHP applicant eligibilityapplicants can register for assistance, and IHP applicant eligibility requirements, including requirements, including
descriptions of the general eligibilitydescriptions of the general eligibility conditions. conditions.
Registration Period
After an emergency or major disaster declaration has been issued and IA has been authorized, After an emergency or major disaster declaration has been issued and IA has been authorized,
applicants (i.e., individuals) may register for FEMA IHP assistance.162 Individuals and households applicants (i.e., individuals) may register for FEMA IHP assistance.162 Individuals and households
can register for assistance online, by telephone, or in-person at a Disaster Recovery Center can register for assistance online, by telephone, or in-person at a Disaster Recovery Center
(DRC).163(DRC).163
Individuals and households have 60 days from the date of a declaration authorizing Individual Individuals and households have 60 days from the date of a declaration authorizing Individual
Assistance to apply for FEMA IHP assistance. This 60-day period is known as the Assistance to apply for FEMA IHP assistance. This 60-day period is known as the Initial
Registration Period.164 FEMA may extend the Registration Period at the request of the state, .164 FEMA may extend the Registration Period at the request of the state,
territory, or Indian tribal government (e.g., to establish the same registration deadline for territory, or Indian tribal government (e.g., to establish the same registration deadline for
subsequently designated areas—per the subsequently designated areas—per the IAPPG, “[f]or individuals in areas subsequently , “[f]or individuals in areas subsequently
designated for IA after the date of declaration, the registration deadline is designated for IA after the date of declaration, the registration deadline is stil still 60 days after the 60 days after the
date of declaration, not 60 days from the day the county or parish was designated for IA, unless date of declaration, not 60 days from the day the county or parish was designated for IA, unless

extended”).165 FEMA will continue to accept late registrations for an additional 60 days after the Initial Registration Period if the applicant submits a written justification and documentation 159 44 C.F.R. §206.37(c)(1). 159 44 C.F.R. §206.37(c)(1).
160 44 C.F.R. §206.38(a). 160 44 C.F.R. §206.38(a).
161 For more information on the IHP application process, see FEMA, 161 For more information on the IHP application process, see FEMA, IAPPG, pp. 69-77. For more information on IHP , pp. 69-77. For more information on IHP
eligibilityeligibility considerations, see FEMA, considerations, see FEMA, IAPPG, pp. 46-66; and Memorandum from Keith , pp. 46-66; and Memorandum from Keith T uriTuri RE: Amendment to the RE: Amendment to the
IAPPG, pp. 1-9. For more information on the IHP appeals process, see FEMA, IAPPG, pp. 1-9. For more information on the IHP appeals process, see FEMA, IAPPG, pp. 66-68. See also CRS, pp. 66-68. See also CRS Report Report
R47297, R47297, Disaster Survivor FAQ: FEMA Individuals and Households Program , by Elizabeth M. Webster, for additional , by Elizabeth M. Webster, for additional
information on frequently asked questions that arise as disaster survivors navigate the IHP application process and information on frequently asked questions that arise as disaster survivors navigate the IHP application process and
receive IHP assistance. receive IHP assistance.
162 When an emergency or major disaster is162 When an emergency or major disaster is declared,declared, areas of the impacted state/territory are “designated” as having areas of the impacted state/territory are “designated” as having
been deemedbeen deemed eligible eligible for federal assistance (44 C.F.R. §206.2(a)(6); and FEMA,for federal assistance (44 C.F.R. §206.2(a)(6); and FEMA, IAPPG, p. 5). Designated, p. 5). Designated areas can be areas can be
“counties, parishes, tribes or tribal lands,“counties, parishes, tribes or tribal lands, municipalities, villages, or districts.” municipalities, villages, or districts.”
163 FEMA, 163 FEMA, IAPPG, p. 69. , p. 69.
164 FEMA,164 FEMA, IAPPG, pp. 70-71; 44 C.F.R. §206.112; and email from FEMA Congressional Affairs staff, May 25, 2021. , pp. 70-71; 44 C.F.R. §206.112; and email from FEMA Congressional Affairs staff, May 25, 2021.
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extended”).165 FEMA wil continue to accept late registrations for an additional 60 days after the
Initial Registration Period if the applicant submits a written justification and documentation
165 FEMA, IAPPG, pp. 70-71; 44 C.F.R. §206.112; and email from FEMA Congressional Affairs staff, May 25, 2021. Congressional Research Service 28 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations explaining the circumstances that prevented them from applying on time—this is known as the explaining the circumstances that prevented them from applying on time—this is known as the
Late Application Period. FEMA does not accept applications submitted after the Late Application . FEMA does not accept applications submitted after the Late Application
Period concludes.166 Period concludes.166
Applicant Eligibility
The registration process requires applicants to submit a Declaration and Release Form,167 and The registration process requires applicants to submit a Declaration and Release Form,167 and
other information to complete their application for IHP assistance (e.g., related to identity other information to complete their application for IHP assistance (e.g., related to identity
verification, insurance, pre-disaster annual gross income, disaster-caused losses).168 verification, insurance, pre-disaster annual gross income, disaster-caused losses).168
IHP Application Requirements
Required information to complete an IHP application includes: Required information to complete an IHP application includes:

certification that the applicant is, certification that the applicant is, or is the parent/guardian of a minor who is,or is the parent/guardian of a minor who is, a U.S. citizen, noncitizen a U.S. citizen, noncitizen
national, a qualified alien; national, a qualified alien;

the primary applicant’s social the primary applicant’s social security number (or social security number of a minor in the household who is security number (or social security number of a minor in the household who is
a U.S. citizen, noncitizen national, or qualified alien); a U.S. citizen, noncitizen national, or qualified alien);

current and pre-disaster addresses; current and pre-disaster addresses;

names of pre-disaster names of pre-disaster household occupants;household occupants;

contact information; contact information;

insurance information; insurance information;

financial information (i.e., financial information (i.e., pre-disasterpre-disaster household annual gross income);household annual gross income);

disaster-caused losses; disaster-caused losses; and
and •
banking information banking information (for direct deposit of financial assistance). (for direct deposit of financial assistance).
(FEMA, (FEMA, IAPPG, pp. 71-72.) , pp. 71-72.)
IHP applicants must meet general eligibility IHP applicants must meet general eligibility requirements, as follows: requirements, as follows:
1. “[t]he applicant must be a U.S. citizen, noncitizen national, or qualified 1. “[t]he applicant must be a U.S. citizen, noncitizen national, or qualified alien”alien” (or (or
the parent or guardian of a minor child who is a U.S. citizen, noncitizen national, the parent or guardian of a minor child who is a U.S. citizen, noncitizen national,
or qualified alien); or qualified alien);
2. “FEMA 2. “FEMA must be able to verify the applicant’s identity”; must be able to verify the applicant’s identity”;
3. “[t]he applicant’s insurance, or other forms of disaster assistance received, cannot 3. “[t]he applicant’s insurance, or other forms of disaster assistance received, cannot
meet their disaster-caused needs”; and meet their disaster-caused needs”; and
4. “[t]he applicant’s necessary expenses and serious needs are directly caused by a 4. “[t]he applicant’s necessary expenses and serious needs are directly caused by a
declared disaster.”169 declared disaster.”169

165 FEMA, IAPPG, pp. 70-71; 44 C.F.R. §206.112; and email from FEMA Congressional Affairs staff, May 25, 2021.
Each type of IHP assistance requires that additional eligibility conditions be met, and may require additional documentation.170 For example, Home Repair and Home Replacement assistance are only available to homeowners, and some forms of assistance require proof of occupancy and/or 166 FEMA,166 FEMA, IAPPG, pp. 70-71; 44 C.F.R. §206.112; and email from FEMA Congressional Affairs staff, May 25, 2021. , pp. 70-71; 44 C.F.R. §206.112; and email from FEMA Congressional Affairs staff, May 25, 2021.
167 DHS/FEMA,167 DHS/FEMA, “Declaration and Release,” Form, O.M.B. No. 1660“Declaration and Release,” Form, O.M.B. No. 1660 -0002, expires August 31, 2022-0002, expires August 31, 2022,
https://www.disasterassistance.gov/sites/default/files/daip/Declaration_and_Release_FEMA_Form_009 -0-
3_(Aug2022).pdf.
. 168 FEMA, 168 FEMA, IAPPG, pp. 71-72. , pp. 71-72. T heThe standard mechanism for verifying loss and determining eligibility standard mechanism for verifying loss and determining eligibility —in —in the case of the case of
the IHP—is an on-site inspection conducted by a FEMA inspector (or other method of verification, such as a geospatial the IHP—is an on-site inspection conducted by a FEMA inspector (or other method of verification, such as a geospatial
inspection or a review of documentation for losses that cannot be verified through an inspection). inspection or a review of documentation for losses that cannot be verified through an inspection).
169 FEMA, 169 FEMA, IAPPG, p. 46. , p. 46.
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Each type of IHP assistance requires that additional eligibility conditions be met, and may require
additional documentation.170 For example, Home Repair and Home Replacement assistance are
only available to homeowners, and some forms of assistance require proof of occupancy and/or
ownership.171ownership.171 Table 3 lists the eligibility lists the eligibility of homeowners and renters for the different forms of of homeowners and renters for the different forms of
Housing Assistance. Housing Assistance.
Table 3. Eligibility for Types of Housing Assistance
Housing Assistance:
Housing Assistance:
Financial
Homeowner/Renter
Direct
Homeowner/Renter
Lodging Expense Lodging Expense
Homeowner/Renter Homeowner/Renter
Multi-Family Lease Multi-Family Lease and and
Homeowner/Renter Homeowner/Renter
Reimbursement Reimbursement
Repair Repair
Rental Assistance Rental Assistance
Homeowner/Renter Homeowner/Renter
Transportable Temporary Transportable Temporary
Homeowner/Renter Homeowner/Renter
Housing Units Housing Units
Home Home Repair Assistance Repair Assistance
Homeowner Homeowner
Direct Direct Lease Lease
Homeowner/Renter Homeowner/Renter
Home Home Replacement Replacement
Homeowner Homeowner
Permanent Housing Permanent Housing
Homeowner Homeowner
Assistance Assistance
Construction Construction
Source: CRS interpretation of FEMA, CRS interpretation of FEMA, Individual Assistance Program and Policy Guide (IAPPG), v. 1.1, FP 104-009-03, , v. 1.1, FP 104-009-03,
May 2021, pp. 78-144, https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf. May 2021, pp. 78-144, https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf.
Notes: The different types of Housing AssistanceThe different types of Housing Assistance include different eligibilityinclude different eligibility criteria.criteria. ONA may be available to ONA may be available to
eligibleeligible applicants regardlessapplicants regardless of homeownership/renterof homeownership/renter status. status.
Additional Information Information on IHP Eligibility of People Experiencing Homelessness
FEMA does not provide Housing Assistance to applicants experiencing homelessness prior to a FEMA does not provide Housing Assistance to applicants experiencing homelessness prior to a
disaster declaration because “the need for housing was not caused by the disaster”; however, disaster declaration because “the need for housing was not caused by the disaster”; however,
applicants experiencing homelessness may be eligible for forms of ONA.172 applicants experiencing homelessness may be eligible for forms of ONA.172
Additional Information Information on the Requirement that IHP Applicants be Citizens,
Noncitizen Nationals, or Qualified Aliens

Many forms of FEMA assistance are available Many forms of FEMA assistance are available regardless of the applicant’s immigration status. regardless of the applicant’s immigration status.
For example, disaster survivors may be eligible for mass care and emergency assistance, such as For example, disaster survivors may be eligible for mass care and emergency assistance, such as
emergency sheltering support, as emergency sheltering support, as wel well as most forms of Individual Assistance, including the Crisis as most forms of Individual Assistance, including the Crisis
Counseling Assistance and Training Program, Disaster Case Management, and Disaster Legal Counseling Assistance and Training Program, Disaster Case Management, and Disaster Legal
Services.173 The IHP policy, however, includes restrictions based on immigration status. To be Services.173 The IHP policy, however, includes restrictions based on immigration status. To be
eligibleeligible for IHP assistance, “[t]he applicant must be a U.S. citizen, non-citizen national, or for IHP assistance, “[t]he applicant must be a U.S. citizen, non-citizen national, or
qualified alien.”174 qualified alien.”174
Limitations on the availability Limitations on the availability of Individual Assistance to “non-qualified aliens” is a frequent of Individual Assistance to “non-qualified aliens” is a frequent
subject of congressional questions. As noted above, FEMA’s IHP policy limits the provision of subject of congressional questions. As noted above, FEMA’s IHP policy limits the provision of
assistance to “qualified aliens.” FEMA’s “qualified alien” definition is based on 8 U.S.C. §1641, assistance to “qualified aliens.” FEMA’s “qualified alien” definition is based on 8 U.S.C. §1641,

170 See the IAPPG guidance on the type of IHP assistance being requested for additional requirements.
which defines “qualified alien” for purposes of eligibility for federal public benefits. This statute is a provision of Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, known as PRWORA.175 Under another provision of PRWORA, 8 U.S.C. §1611, so- 171 FEMA, 171 FEMA, IAPPG, pp. 46, 51-55; Memorandum from Keith , pp. 46, 51-55; Memorandum from Keith T uriTuri RE: Amendment to the IAPPG, pp. 2 RE: Amendment to the IAPPG, pp. 2 -9. -9.
172 FEMA, 172 FEMA, IAPPG, p. 61. , p. 61.
173 FEMA, 173 FEMA, IAPPG, p. 48. , p. 48.
174 FEMA, 174 FEMA, IAPPG, p. 46. , p. 46. T heThe IAPPG defines each of these citizenship statuses (i.e., U.S. defines each of these citizenship statuses (i.e., U.S. citizen, noncitizen national, citizen, noncitizen national,
and qualifiedand qualified alien) in Figurealien) in Figure 6 on page 47. 175 Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA); P.L. 104-193; 8 U.S.C. §§1601-1646. Congressional Research Service 30 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations called “non-qualified aliens” are generally rendered ineligible 6 on page 47.
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which defines “qualified alien” for purposes of eligibility for federal public benefits. This statute
is a provision of Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act
of 1996, known as PRWORA.175 Under another provision of PRWORA, 8 U.S.C. §1611, so-
cal ed “non-qualified aliens” are general y rendered ineligible for federal public benefits.176 CRS for federal public benefits.176 CRS
Report R46510, Report R46510, PRWORA’s Restrictions on Noncitizen Eligibility for Federal Public Benefits:
Legal Issues
, by Ben Harrington, explains this legal framework and its application to FEMA , by Ben Harrington, explains this legal framework and its application to FEMA
disaster relief as follows: disaster relief as follows:
8 U.S.C. §1611(b) provides 8 U.S.C. §1611(b) provides that the baseline that the baseline eligibility rule restrictingeligibility rule restricting federal federal public public
benefits to “qualified aliens” does not apply to “[s]hort-term, non-cash, in-kind emergency benefits to “qualified aliens” does not apply to “[s]hort-term, non-cash, in-kind emergency
disaster relief.” By carving out “non-cash” disaster assistance from the baseline eligibility disaster relief.” By carving out “non-cash” disaster assistance from the baseline eligibility
restriction for federal public benefits, PRWORA implies that the restriction does apply to restriction for federal public benefits, PRWORA implies that the restriction does apply to
other forms of disaster relief (including cash assistance). FEMA has interpreted PRWORA other forms of disaster relief (including cash assistance). FEMA has interpreted PRWORA
this way—to bar nonqualified aliens from eligibility for disaster relief paid in cash—and this way—to bar nonqualified aliens from eligibility for disaster relief paid in cash—and
the interpretation does not appear to have generated disagreement.177 the interpretation does not appear to have generated disagreement.177
Additional Information Information on Determining IHP Award Amounts
As noted above, IHP awards are subject to As noted above, IHP awards are subject to
Award Amount Determination:
statutory funding caps for each applicant, and statutory funding caps for each applicant, and
Example for Home Repair Assistance
are designed to meet basic needs.178 For are designed to meet basic needs.178 For
According to the According to the IAPPG, “Home Repair Assistance , “Home Repair Assistance
example, IHP assistance is generally limited example, IHP assistance is generally limited to to
award amounts are based on repair or replacement award amounts are based on repair or replacement of of
essential living essential living spaces.179 spaces.179
components that are of average quality, size, components that are of average quality, size, or or
capacity.” FEMA bases these award amounts on local capacity.” FEMA bases these award amounts on local
The amount of assistance an applicant receives The amount of assistance an applicant receives
costs—more costs—more specifical y, specifically, on localized average repair on localized average repair
through the IHP through the IHP wil will vary based on multiple vary based on multiple
costs (i.e., costs (i.e., FEMA does not have a flat rate for Home FEMA does not have a flat rate for Home
factors that are “specific to the disaster factors that are “specific to the disaster
Repair Assistance costs for different components). Repair Assistance costs for different components).
survivor’s unique circumstances.” According to FEMA, the agency uses a tool/service According to FEMA, the agency uses a tool/service
survivor’s unique circumstances.”180 IHP
cal ed180 IHP called RSMeans to determine RSMeans to determine and award reasonable and award reasonable
awards awards wil will depend on the applicant’s status depend on the applicant’s status
localized costs. localized costs.
(e.g., homeowner, renter, roommate), the (e.g., homeowner, renter, roommate), the
(FEMA, (FEMA, IAPPG, p. 88; FEMA briefing on June 22, 2021.) , p. 88; FEMA briefing on June 22, 2021.)
number of household members and household number of household members and household

175 T itle IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA); P.L. 104-
193; 8 U.S.C. §§1601-1646.
composition, the type(s) of assistance being requested and the associated eligibility criteria and limitations specific to the requested assistance, as well as the loss amount determined by FEMA 176 COFA—Compacts of Free Association—migrants are an example of a group of people who are ineligible 176 COFA—Compacts of Free Association—migrants are an example of a group of people who are ineligible for IHP for IHP
assistance. For additional information, see GAO, assistance. For additional information, see GAO, Com pactsCompacts of Free Association: Populations in U.S. Areas Have
Grown, with Varying Reported Effects
, GAO-20-491, June 2020, pp. 11-13, https://www.gao.gov/assets/gao-20-, GAO-20-491, June 2020, pp. 11-13, https://www.gao.gov/assets/gao-20-
491.pdf. 491.pdf. T ableTable 1 of the report lists compact migrant eligibility for select federal programs, footnote j of which states, 1 of the report lists compact migrant eligibility for select federal programs, footnote j of which states,
“[a]ccording to officials of the Federal Emergency Management Agency, compact migrants are ineligible“[a]ccording to officials of the Federal Emergency Management Agency, compact migrants are ineligible for disaster for disaster
assistance programs, such asassistance programs, such as the Individualsthe Individuals and Householdsand Households Program, that are considered to be federal publicProgram, that are considered to be federal public benefits benefits
and are thus subjectand are thus subject to citizenship requirements; however, they may be eligibleto citizenship requirements; however, they may be eligible to receive certain types of shortto receive certain types of short -term, -term,
noncash, in-kind emergency relief. For example, compact migrants may receive Public Assistance Emergency noncash, in-kind emergency relief. For example, compact migrants may receive Public Assistance Emergency
Assistance services such asAssistance services such as search and rescue;search and rescue; emergency medical care; emergency massemergency medical care; emergency mass care; emergency shelter; and care; emergency shelter; and
provision of food, water, medicine, and other essential needs.” provision of food, water, medicine, and other essential needs.”
177 See177 See CRS CRS Report R46510, Report R46510, PRWORA’s Restrictions on Noncitizen Eligibility for Federal Public Benefits: Legal
Issues
, by Ben Harrington, p. 13 (citations omitted). , by Ben Harrington, p. 13 (citations omitted).
178 FEMA, 178 FEMA, IAPPG, pp. 6 and 41. , pp. 6 and 41.
179 FEMA, 179 FEMA, Preliminary Damage Assessment Guide, p. 28. As described, p. 28. As described in FEMA’s in FEMA’s Preliminary Damage Assessment
Guide
, “, “ [a]n essential living space is[a]n essential living space is a room within a home that serves the function of a bedroom, bathroom, kitchen, a room within a home that serves the function of a bedroom, bathroom, kitchen,
and/or living room that is regularly occupied or usedand/or living room that is regularly occupied or used by one orby one or more members of the household and requiresmore members of the household and requires repair to repair to
bringbring its functionality back to the home (e.g., kitchens are considered essential as long as there is not another its functionality back to the home (e.g., kitchens are considered essential as long as there is not another
undamagedundamaged kitchen in the home).” kitchen in the home).”
180 GAO,180 GAO, Disaster Assistance: IHP, p. 19. , p. 19.
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composition, the type(s) of assistance being requested and the associated eligibility criteria and
limitations specific to the requested assistance, as wel as the loss amount determined by FEMA
(i.e., the FEMA-Verified (i.e., the FEMA-Verified Loss (FVL) amount)181 and whether and to what extent the real and Loss (FVL) amount)181 and whether and to what extent the real and
personal property losses were insured.182personal property losses were insured.182
A FEMA inspection is used to verify losses related to real and personal property, and is typically A FEMA inspection is used to verify losses related to real and personal property, and is typically
conducted on-site by a FEMA inspector, but may also be completed via a geospatial inspection or conducted on-site by a FEMA inspector, but may also be completed via a geospatial inspection or
based on documentation of losses (e.g., medical based on documentation of losses (e.g., medical bil sbills or receipts for automobile repairs).183 or receipts for automobile repairs).183
Applicants may not receive the full FVL amount, including because their losses may be covered Applicants may not receive the full FVL amount, including because their losses may be covered
in whole or in part by insurance. in whole or in part by insurance. Additional y, Additionally, some forms of IHP Housing Assistance and some forms of IHP Housing Assistance and al
all forms of ONA are subject to the maximum amount of financial assistance (with some forms of ONA are subject to the maximum amount of financial assistance (with some
exceptions),184 and some forms of ONA are subject to further financial limits established by the exceptions),184 and some forms of ONA are subject to further financial limits established by the
affected state, territory, or Indian tribal government.185 affected state, territory, or Indian tribal government.185
As stated above, insurance also factors into the amount of financial assistance an applicant may As stated above, insurance also factors into the amount of financial assistance an applicant may
receive. IHP applicants must inform FEMA of receive. IHP applicants must inform FEMA of al all insurance coverage that may help meet their insurance coverage that may help meet their
disaster-caused needs, and must provide FEMA with documentation identifying their insurance disaster-caused needs, and must provide FEMA with documentation identifying their insurance
settlements or benefits before FEMA settlements or benefits before FEMA wil will consider an applicant’s eligibilityconsider an applicant’s eligibility for assistance that for assistance that
may be covered by private insurance.186may be covered by private insurance.186
The amount of financial assistance an applicant may be eligible The amount of financial assistance an applicant may be eligible for is based on their FVL amount for is based on their FVL amount
minus their net insurance settlement (i.e., their gross settlement minus their deductible), up to the minus their net insurance settlement (i.e., their gross settlement minus their deductible), up to the
maximum amount of financial assistance.187 Per FEMA’s guidance, maximum amount of financial assistance.187 Per FEMA’s guidance,
After an applicant submits their insurance settlement information, FEMA compares the net After an applicant submits their insurance settlement information, FEMA compares the net
settlement amount received for each loss to the maximum amount of assistance available settlement amount received for each loss to the maximum amount of assistance available
for that type of IHP assistance.188 for that type of IHP assistance.188
Appealing FEMA’s Decisions Regarding IHP Assistance
FEMA may deny IHP applicants’ requests for IHP assistance for a variety of reasons, ranging FEMA may deny IHP applicants’ requests for IHP assistance for a variety of reasons, ranging
from determinations related to the applicant’s eligibilityfrom determinations related to the applicant’s eligibility for IHP assistance for IHP assistance general ygenerally or the or the
specific type of IHP assistance being requested, to a finding by FEMA that the applicant failed to specific type of IHP assistance being requested, to a finding by FEMA that the applicant failed to
purchase and maintain flood insurance as a requirement of receiving previous federal disaster purchase and maintain flood insurance as a requirement of receiving previous federal disaster
assistance.189 If this occurs, applicants for IHP assistance may appeal FEMA’s determinations, assistance.189 If this occurs, applicants for IHP assistance may appeal FEMA’s determinations,
including, but not limited to, appeals ofincluding, but not limited to, appeals of:
applicant eligibility applicant eligibility determinations;190determinations;190

181 T he 181 The FEMA-Verified Loss (FVL) FEMA-Verified Loss (FVL) amount is defined asamount is defined as “[t]he total dollar amount of IHP eligible disaster“[t]he total dollar amount of IHP eligible disaster -caused -caused
damagedamage to real and personal property as verified by FEMA.” (FEMA, to real and personal property as verified by FEMA.” (FEMA, IAPPG, p. 50.) , p. 50.)
182 GAO,182 GAO, Disaster Assistance: IHP, pp. 18-20. , pp. 18-20.
183 FEMA, 183 FEMA, IAPPG, p. 72. , p. 72.
184 42 U.S.C.184 42 U.S.C. §5174(h)(4). §5174(h)(4). T hereThere are exceptions to the maximum amount of financial assistance for select disaster are exceptions to the maximum amount of financial assistance for select disaster --
damageddamaged accessibility-related real and personal property items (FEMA, accessibility-related real and personal property items (FEMA, IAPPG, pp. 86 and 146). , pp. 86 and 146).
185 FEMA, 185 FEMA, IAPPG, pp. 147 and 149; see also 44 C.F.R., pp. 147 and 149; see also 44 C.F.R. §206.120(c) and (d). §206.120(c) and (d).
186 FEMA, 186 FEMA, IAPPG, pp. 49-51. , pp. 49-51.
187 FEMA, 187 FEMA, IAPPG, p. 50. In instances where an applicant’s deductible, p. 50. In instances where an applicant’s deductible exceeds their “insurance verified loss”exceeds their “insurance verified loss” amount amount, ,
such that their net settlement is $0, FEMA may provide assistance for their FEMA Verifiedsuch that their net settlement is $0, FEMA may provide assistance for their FEMA Verified L oss Loss (FVL) (FVL) amount. amount.
188 FEMA, 188 FEMA, IAPPG, p. 51. , p. 51.
189 44 C.F.R. §206.113. 189 44 C.F.R. §206.113.
190 44 C.F.R. §206.115(a)(1); FEMA, 190 44 C.F.R. §206.115(a)(1); FEMA, IAPPG, p. 66. Applicants have 60 days to appeal initial eligibility, p. 66. Applicants have 60 days to appeal initial eligibility determinations. determinations.
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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

the amount and/or type(s) of assistance received;191 and the amount and/or type(s) of assistance received;191 and
late application rejections.192 late application rejections.192
FEMA explains the appeal process as follows: FEMA explains the appeal process as follows:
To appeal any IHP assistance-related FEMA determination, applicants must To appeal any IHP assistance-related FEMA determination, applicants must
submit a written appeal explaining submit a written appeal explaining the reason for the appeal with documentation the reason for the appeal with documentation
supporting the appeal request.193supporting the appeal request.193
Once FEMA receives an appeal, a caseworker who was not involved in the case Once FEMA receives an appeal, a caseworker who was not involved in the case
shal shall review the appeal and file to determine if there is sufficient information to review the appeal and file to determine if there is sufficient information to
change FEMA’s determination. change FEMA’s determination.
If there is not sufficient information, FEMA If there is not sufficient information, FEMA wil will either (1) contact the applicant either (1) contact the applicant
to request additional information with a deadline of 30 days; (2) contact a third to request additional information with a deadline of 30 days; (2) contact a third
party (e.g., contractor, insurance company) to verify the supporting party (e.g., contractor, insurance company) to verify the supporting
documentation; and/or (3) schedule an appeal inspection.194documentation; and/or (3) schedule an appeal inspection.194
FEMA’s FEMA’s shal shall provide appeal determinations to the applicant in writing within 90 provide appeal determinations to the applicant in writing within 90
days of receiving the written appeal letter, and FEMA’s appeal decision is final days of receiving the written appeal letter, and FEMA’s appeal decision is final
(i.e., it cannot be appealed again).195 (i.e., it cannot be appealed again).195
Recoupment of Improper Payments and Requests for WaiversWaivers Requirements
Federal laws require federal agencies, including FEMA, to identify and recover Federal laws require federal agencies, including FEMA, to identify and recover improper
payments.196 FEMA, however, does have some discretion not to pursue recoupment. DRRA
Section 1216(a) authorizes FEMA to waive debts owed by individuals who received IHP
assistance if the four required conditions for a waiver are met:197
1. “The covered assistance was distributed based on FEMA error. Even in
circumstances where no debtor fault exists, not al ineligible assistance results
from FEMA error.” For example, FEMA payments provided in advance of other
funds, such as insurance, would not be considered to be assistance that was
distributed based on FEMA error.

payments (i.e., “any payment that should not have been made or that was made in an incorrect amount”)—a process known as recoupment.196 Examples of improper payments include overpayments, payments made to ineligible recipients, payments used for ineligible services, and duplication of benefits. There are some circumstances, however, when FEMA may not pursue recoupment. FEMA is required to waive recoupment of IHP assistance in two situations, provided the debt does not involve fraud, a false claim, or misrepresentation by the debtor or party having an interest in the claim: 1. “if the covered assistance [i.e., IHP assistance] was distributed based on an error by the Agency [i.e., FEMA] and such debt shall be construed as a hardship; and 191 44 C.F.R. §206.115(a)(2); FEMA, 191 44 C.F.R. §206.115(a)(2); FEMA, IAPPG, p. 66. Applicants may also appeal decisions, p. 66. Applicants may also appeal decisions related to the specific type of related to the specific type of
IHP assistance they are receiving. For example, an applicant may appeal FEMA’s denial of their request for Continued IHP assistance they are receiving. For example, an applicant may appeal FEMA’s denial of their request for Continued
T emporaryTemporary Housing Assistance (44 C.F.R. §206.115(a)(5)), or FEMA’s denial of their request to purchase a FEMA- Housing Assistance (44 C.F.R. §206.115(a)(5)), or FEMA’s denial of their request to purchase a FEMA-
provided Mobile Housingprovided Mobile Housing Unit (44 C.F.R. §206.115(a)(8)). Unit (44 C.F.R. §206.115(a)(8)).
192 44 C.F.R. §206.115(a)(4); FEMA, 192 44 C.F.R. §206.115(a)(4); FEMA, IAPPG, p. 66. , p. 66.
193 44 C.F.R. §206.115(b); FEMA, 193 44 C.F.R. §206.115(b); FEMA, IAPPG, pp. 66-67. Appeals must also be signed, pp. 66-67. Appeals must also be signed by the applicant (or person they by the applicant (or person they
have authorized to act on his/her behalf). have authorized to act on his/her behalf).
194 44 C.F.R. §206.115(f); FEMA, 194 44 C.F.R. §206.115(f); FEMA, IAPPG, p. 68. , p. 68.
195 44 C.F.R. §206.115(f); FEMA, 195 44 C.F.R. §206.115(f); FEMA, IAPPG, p. 68. , p. 68.
196 Section 2(d)(2) of the Improper Payments Information Act of 2002 (IPIA, P.L. 107-300) defines196 Section 2(d)(2) of the Improper Payments Information Act of 2002 (IPIA, P.L. 107-300) defines improper payments
as “any payment that should not have been made or that was made in an incorrect amount (including overpayments and as “any payment that should not have been made or that was made in an incorrect amount (including overpayments and
underpayments) ... and includesunderpayments) ... and includes any payment to an ineligible recipient, any payment for an any payment to an ineligible recipient, any payment for an ine ligibleineligible service, any service, any
duplicate payment.... ” For more information, see CRSduplicate payment.... ” For more information, see CRS Report R45257, Report R45257, Improper Payments in High-Priority
Program sPrograms: In Brief
, by Garrett Hatch. FEMA lists, as reasons for recoupment, evidence of, by Garrett Hatch. FEMA lists, as reasons for recoupment, evidence of: duplication of benefits; duplication of benefits;
assistance provided in error (i.e., the applicant was not eligibleassistance provided in error (i.e., the applicant was not eligible for the assistance they received); misusefor the assistance they received); misuse of funds;of funds; and and
fraudfraud (FEMA, (FEMA, IAPPG, , p. 178).
197 DRRA Section 1216(a)(2)(A), P.L. 115-254.
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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

2. “There was no fault on behalf of the debtor. ‘Fault’ exists if, considering al
circumstances, it is determined that the debtor knew or should have known that
an error existed but failed to take action to have it corrected.” For example, fault
could be the result of a direct or indirect act or omission by the debtor that was
“erroneous or inaccurate or otherwise wrong.” Fault is also presumed if the
debtor misuses FEMA assistance, including to pay expenses not caused by the
disaster, or using funds “in a manner inconsistent with their intended use.”
3. “The collection of the debt would be against equity and good conscience. . The
legal obligation to pay a debt to FEMA may be overcome by other consideration
if enforcement of the debt would be unfair to the point of violating equity and
good conscience.” For example, if the collection of the debt would result in
undue hardship, such as by depriving the debtor of basic necessities, it may be
considered against equity and good conscience.
4. “There is no indication the debt involves fraud, the presentation of a false claim,
or misrepresentation by the debtor or any party having an interest in the
claim.”198
When FEMA provides IHP recipients with a notice of potential debt, the individual pp. 176-178). Congressional Research Service 33 link to page 33 link to page 16 link to page 16 link to page 25 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations 2. “if such [covered] assistance [i.e., IHP assistance] is subject to a claim or legal action.... ”197 IHP recipients that receive a notice of potential debt from FEMA may choose may choose
to appeal the potential debt.to appeal the potential debt.199 If they do not appeal the potential debt or If they do not appeal the potential debt or their appeal is not
grantedif FEMA denies their appeal, the debt , the debt becomes final, and the individual may then pay the debt, unless FEMA must waive the debt.198 General IHP Limitations IHP assistance is subject to limitations. For example, as described above, the provision of IHP is subject to applicant eligibility restrictions,199 and there are caps on the maximum amount of financial assistance an individual or household is eligible to receive.200 Additional becomes final (i.e., the debt is established).200 When the debt has been
established, individuals may pay the debt or request a debt waiver.201
FEMA added a waiver notice to al debt recoupment letters to instruct recipients on the waiver
process.202 The information provided to individuals focuses on affirmations that they were not at
fault (i.e., there was no “Misrepresentation,” “Failure to Disclose,” “Knowledge of Error,”
“Misuse,” or “Other Fault”), and that collection of the debt would be against equity and good
conscience (i.e., they must show they “gave up a benefit because of the overpayment, or ..
changed ... [their] position for the worse because of the overpayment” or “[c]ollection of the
overpayment would be unduly difficult, grossly unfair, or would prevent ... [them] or [their]

198 FEMA, “ Instruction 116-1-2: Individuals and Households Program Recoupment ,” v. 2, May 2019.
199 FEMA, IAPPG, pp. 66 and 177.
200 FEMA, IAPPG, p. 177.
201 FEMA, IAPPG, pp. 180-181. Individuals may pay the debt, or request a payment arrangement, debt compromise, or
a debt waiver.
202 FEMA, 2019 DRRA Report, p. 18; and FEMA, “ DRRA Provisions 1210(A)-1219,” https://www.fema.gov/disasters/
disaster-recovery-reform-act-2018/provisions-1210-1219 (see “ Debt Waiver and Recoupment (Section 1216 a and b)”).
FEMA’s process for considering an IHP waiver request is detailed in “Instruction 116-1-2: Individuals and Household
Program Recoupment .” T he general process is as follows: after a debt has been established, individuals who would like
to request a waiver may contact FEMA, and then t he Office of Chief Financial Officer (OCFO) will mail them a waiver
fact sheet to aid in their application. T he OCFO then forwards completed waiver requests to FEMA’s IHP staff for
analysis and a recommendation. “ The OCFO makes the final agency determination [as to] whether the criteria for [a]
waiver [as] mandated by DRRA have been met and notifies the applicant. ” (Email from FEMA Congressional Affairs
staff, February 11, 2021.) A template debt letter can be found in “Appendix B: T emplate for a Notice and Debt Let ter
Resulting from a Major Disaster or Emergency Declared on or after October 28, 2012 ” and “ Appendix C: Waiver
Information Sheet ” of FEMA, “ Instruction 116-1-2: Individuals and Households Program Recoupment ,” v. 2, May
2019, pp. 37-42. For additional information on the recoupment process, see CRS Infographic IG10024, How FEMA
Individual Assistance Works
, by Elizabeth M. Webster.
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family members from obtaining basic necessities”).203 The onus is on the IHP recipient to
demonstrate whether or not a waiver is appropriate.204
General IHP Limitations
IHP assistance is subject to limitations. For example, as described above, the provision of IHP is
subject to applicant eligibility restrictions,205 and there are caps on the maximum amount of
financial assistance an individual or household is eligible to receive.206
Additional limitations, described below, include limitations related to the fact that IHP assistance limitations, described below, include limitations related to the fact that IHP assistance
is not intended as a substitute for insurance and there are limitations on what IHP assistance is not intended as a substitute for insurance and there are limitations on what IHP assistance
covers, limitations related to the IHP period of assistance, which is covers, limitations related to the IHP period of assistance, which is general ygenerally limited to a period limited to a period
of 18 months from the date of the declaration, and limitations related to avoidingof 18 months from the date of the declaration, and limitations related to avoiding assistance that assistance that
would constitute a duplication of benefits. would constitute a duplication of benefits.
Limitations on What IHP Assistance Covers
The IHP is not intended as a substitute for insurance and there are limitations on what IHP The IHP is not intended as a substitute for insurance and there are limitations on what IHP
assistance covers. In short: “IHP assistance does not address assistance covers. In short: “IHP assistance does not address al all damages resulting from a damages resulting from a
disaster.”disaster.”207
201 To provide some examples of IHP assistance limitations, the IHP does To provide some examples of IHP assistance limitations, the IHP does not provide assistance to provide assistance to
Enable homeowners to repair or replace vacation properties or secondary Enable homeowners to repair or replace vacation properties or secondary
residences. The IHP only provides financial assistance for Home Repair or Home residences. The IHP only provides financial assistance for Home Repair or Home
Replacement when the disaster resulted in damage to the owner-occupied Replacement when the disaster resulted in damage to the owner-occupied
primary residence.primary residence.208202 Relatedly, Home Repair Assistance and Home Replacement Relatedly, Home Repair Assistance and Home Replacement
Assistance are unavailable to landlords unless they permanently reside in the Assistance are unavailable to landlords unless they permanently reside in the
damaged damaged dwel ing.209
dwelling.203 • Enable homeowners to repair Enable homeowners to repair al all disaster-caused damage or restore their home to disaster-caused damage or restore their home to
its pre-disaster condition. Home Repair Assistance only provides assistance to its pre-disaster condition. Home Repair Assistance only provides assistance to
restore the home to a safe, sanitary, or functional condition.restore the home to a safe, sanitary, or functional condition.210
204 • Enable homeowners to make improvements using Home Repair Assistance. Enable homeowners to make improvements using Home Repair Assistance.
General yGenerally, the objective of Home Repair Assistance is to make the disaster , the objective of Home Repair Assistance is to make the disaster
survivors’ home safe, sanitary, or functional, not to return the home to its pre-survivors’ home safe, sanitary, or functional, not to return the home to its pre-
disaster condition or to improve it. Repairs, however, may include specific
hazard mitigation measures to make the housing more resilient.211

203 “Appendix C: Waiver Information Sheet ” of FEMA, “ Instruction 116-1-2: Individuals and Households Program
Recoupment ,” v. 2, May 2019, p. 41.
204 FEMA, IAPPG, p. 181.
205 197 Section 5602(a) of the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 (P.L. 117-263). 198 FEMA, IAPPG, pp. 177-182 (see “Figure 33: FEMA Process for Identifying and Validating Debt Payments”). 199 FEMA, FEMA, IAPPG, p. 46. For additional information, see the, p. 46. For additional information, see theApplicant Eligibility section. section.
206200 42 U.S.C. 42 U.S.C. §5174(h). For additional information, see the§5174(h). For additional information, see the “Legislative Changes and Significant Program Updates:
Housing Assistance”
and and Legislative Changes and Significant Program Updates: ONA” sections. sections.
207201 GAO, GAO, Disaster Assistance: IHP, pp. 10 and 18. , pp. 10 and 18.
208202 42 U.S.C. 42 U.S.C. §5174(b)(1), (c)(2)(A), (c)(3)(A); FEMA, §5174(b)(1), (c)(2)(A), (c)(3)(A); FEMA, IAPPG, p. 43; GAO, , p. 43; GAO, Disaster Assistance: IHP, p. 18. , p. 18.
209203 42 U.S.C. 42 U.S.C. §5174(b)(1); FEMA, §5174(b)(1); FEMA, IAPPG, pp. 87 and 92. , pp. 87 and 92.
210204 44 C.F.R. §206.117(b)(2)(i)(E); FEMA, 44 C.F.R. §206.117(b)(2)(i)(E); FEMA, IAPPG, p. 85; GAO, , p. 85; GAO, Disaster Assistance: IHP, p. 18. Congressional Research Service 34 link to page 40Assistance: IHP, p. 18.
211 FEMA, IAPPG, pp. 85-86; FEMA, “Hazard Mitigation Under the Individuals and Households Program,” press
release, June 10, 2021, https://www.fema.gov/fact -sheet/hazard-mitigation-under-individuals-and-households-program
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disaster condition or to improve it. Repairs, however, may include specific hazard mitigation measures to make the housing more resilient.205 • Enable applicants to repair or replace Enable applicants to repair or replace al all damaged personal property items. There damaged personal property items. There
are limitations on the amount and type of Personal Property Assistance items that are limitations on the amount and type of Personal Property Assistance items that
are eligibleare eligible for repair or replacement, and FEMA also considers household for repair or replacement, and FEMA also considers household
composition in making award determinations.composition in making award determinations.212206
Limitations on the Period of Availability
The IHP period of assistance is limited. Some forms of IHP assistance come to applicants in the The IHP period of assistance is limited. Some forms of IHP assistance come to applicants in the
form of a grant of financial assistance to pay for specific disaster-caused eligible expenses (e.g., form of a grant of financial assistance to pay for specific disaster-caused eligible expenses (e.g.,
Medical and Dental Assistance), and some may involve multiple assistance payments (e.g., Medical and Dental Assistance), and some may involve multiple assistance payments (e.g.,
Continued Temporary Housing Assistance) or multiple months of assistance (e.g., the forms of Continued Temporary Housing Assistance) or multiple months of assistance (e.g., the forms of
Direct Temporary Housing Assistance). For most forms of IHP assistance, the period of assistance Direct Temporary Housing Assistance). For most forms of IHP assistance, the period of assistance
is is general y limited generally limited to a period of 18 months from the date of the declaration (unless extended).to a period of 18 months from the date of the declaration (unless extended).213
207 However, some forms of IHP assistance have shorter periods of availability. However, some forms of IHP assistance have shorter periods of availability.
Some types of IHP assistance also include additional Some types of IHP assistance also include additional time-based considerations. For example, the time-based considerations. For example, the
period of Initial Rental Assistance is up to two months, but then FEMA may provide Continued period of Initial Rental Assistance is up to two months, but then FEMA may provide Continued
Temporary Housing Assistance. Together, FEMA may provide Initial Rental Assistance and Temporary Housing Assistance. Together, FEMA may provide Initial Rental Assistance and
Continued Temporary Housing Assistance for up to 18 months or until the end of the 18-month Continued Temporary Housing Assistance for up to 18 months or until the end of the 18-month
period of assistance, whichever comes first (plus a security deposit)—unless extended.period of assistance, whichever comes first (plus a security deposit)—unless extended.214208
Different forms of IHP assistance have different limitations on the availability Different forms of IHP assistance have different limitations on the availability of assistance, of assistance,
including set time periods of availabilityincluding set time periods of availability (although extensions may be approved), limitations on (although extensions may be approved), limitations on
the maximum amount of financial assistance that can be provided, or a combination of time- and the maximum amount of financial assistance that can be provided, or a combination of time- and
financial-based financial-based limitations. limitations. Table 4 describes the time and financial limitationsdescribes the time and financial limitations for the various for the various
forms of IHP assistance.forms of IHP assistance.


205 FEMA, IAPPG, pp. 85-86; FEMA, “Hazard Mitigation Under the Individuals and Households Program,” press release, June 10, 2021, https://www.fema.gov/fact-sheet/hazard-mitigation-under-individuals-and-households-program (hereinafter FEMA, “Hazard Mitigation Under the IHP”). (hereinafter FEMA, “Hazard Mitigation Under the IHP”).
212206 44 C.F.R. §206.119(b)(2)(i) and (c). See also GAO, 44 C.F.R. §206.119(b)(2)(i) and (c). See also GAO, Disaster Assistance: IHP, p. 20. Figure, p. 20. Figure 8 of GAO’s8 of GAO’s Disaster
Assistance: IHP
report provides a side-by-side report provides a side-by-side example of how household composition affects eligibility for home example of how household composition affects eligibility for home
damagedamage and personal property losses. and personal property losses.
213207 42 U.S.C. 42 U.S.C. §5174(c)(1)(B)(iii); and 44 C.F.R. §206.110(e); GAO, §5174(c)(1)(B)(iii); and 44 C.F.R. §206.110(e); GAO, Disaster Assistance: IHP, p. 10. , p. 10. T heThe period of period of
assistance may be extended—by assistance may be extended—by t hethe President according to 42 U.S.C. §5174(c)(1)(B)(iii), or the FEMA Assistant President according to 42 U.S.C. §5174(c)(1)(B)(iii), or the FEMA Assistant
Administrator for the Disaster Assistance Directorate according to 44 C.F.R. §206.110(e)—if it is determined that “Administrator for the Disaster Assistance Directorate according to 44 C.F.R. §206.110(e)—if it is determined that “ due due
to extraordinary circumstances an extension would be in the public interest.” to extraordinary circumstances an extension would be in the public interest.”
214208 FEMA, FEMA, IAPPG, p. 80. , p. 80.
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Table 4. Time- and Financial-Based Limitations on IHP Assistance Programs
Housing/ONA
Type of Assistance
Time Limitation
Financial Limitation
Housing Assistance: Housing Assistance:
Lodging Expense Lodging Expense
Available Available from the incident start date and not to from the incident start date and not to
Does not count toward the maximum Does not count toward the maximum amount of financial amount of financial
Financial Financial
Reimbursement Reimbursement
exceed seven days from exceed seven days from the Initial Rental Assistance the Initial Rental Assistance
assistance award for Housing Assistance. assistance award for Housing Assistance.
approval date. approval date.
Initial Rental Initial Rental
Available Available for up to two months. for up to two months.
Does not count toward the maximum Does not count toward the maximum amount of financial amount of financial
Assistance Assistance
assistance award for Housing Assistance. assistance award for Housing Assistance.

Initial Rental AssistanceInitial Rental Assistance awards are based on the HUD FMR for awards are based on the HUD FMR for
the area wherethe area where the pre-disasterthe pre-disaster residence residence is located, and the is located, and the
number of bedrooms requirednumber of bedrooms required by the household. by the household.
Continued Continued
With Initial Rental Assistance, With Initial Rental Assistance, available for up to 18 available for up to 18
Does not count toward the maximum Does not count toward the maximum amount of financial amount of financial
Temporary Housing Temporary Housing
months or the end of the 18-month period of months or the end of the 18-month period of
assistance award for Housing Assistance. assistance award for Housing Assistance.
Assistance Assistance
assistance, whichever comes assistance, whichever comes first. first.

Continued Temporary Housing AssistanceContinued Temporary Housing Assistance awards are based on awards are based on
the HUD FMR for the area where the post-disaster housing unit the HUD FMR for the area where the post-disaster housing unit
is located. is located.
Home Home Repair Repair
NA NA
Subject to the maximum Subject to the maximum amount of financial assistance for amount of financial assistance for
Assistance Assistance
Housing Assistance. Housing Assistance.
Home Home Replacement Replacement
NA NA
Subject to the maximum Subject to the maximum amount of financial assistance for amount of financial assistance for
Assistance Assistance
Housing Assistance. Housing Assistance.

HomeHome Replacement Assistance can be applied toward the Replacement Assistance can be applied toward the
purchase of a new home that exceeds the maximumpurchase of a new home that exceeds the maximum award. award.
Housing Assistance: Housing Assistance:
Multi-Family Lease Multi-Family Lease
Available Available for up to 18 months fromfor up to 18 months from the date of the the date of the
NA NA
Direct Direct
and Repair and Repair
declaration. declaration.

Transportable Transportable
Available Available for up to 18 months fromfor up to 18 months from the date of the the date of the
NA NA

Temporary Housing Temporary Housing
declaration. declaration.

Units Units

Direct Direct Lease Lease
Available Available for up to 18 months fromfor up to 18 months from the date of the the date of the
NA NA
declaration. declaration.
CRS- CRS-3736


Housing/ONA
Type of Assistance
Time Limitation
Financial Limitation
Housing Assistance: Housing Assistance:
Permanent Housing Permanent Housing
NA NA
NA NA
Direct Direct
Construction Construction
ONA: Personal Property ONA: Personal Property
NA NA
Affected state/territory/Indian Affected state/territory/Indian tribal government identifiestribal government identifies eligible eligible
SBA-Dependent SBA-Dependent
Assistance Assistance
personal property items and the maximum personal property items and the maximum quantity that may be quantity that may be
awarded for each personal property item. awarded for each personal property item.

Subject to the maximumSubject to the maximum amount of financial assistance for ONA. amount of financial assistance for ONA.
Transportation Transportation
NA NA
Affected state/territory/Indian Affected state/territory/Indian tribal government establishestribal government establishes the the
Assistance Assistance
maximum maximum amount of Transportation Assistance that may be amount of Transportation Assistance that may be
awarded. awarded.

Subject to the maximumSubject to the maximum amount of financial assistance for ONA. amount of financial assistance for ONA.
Group Flood Group Flood
NA NA
The premium The premium for a three-year certificatefor a three-year certificate of coverage is $2,400. of coverage is $2,400.
Insurance Policy Insurance Policy

Subject to the maximumSubject to the maximum amount of financial assistance for ONA. amount of financial assistance for ONA.
ONA: Funeral Assistance ONA: Funeral Assistance
NA NA
Affected state/territory/Indian Affected state/territory/Indian tribal government establishestribal government establishes the the
Non-SBA-Dependent Non-SBA-Dependent
maximum maximum amount of Funeral Assistanceamount of Funeral Assistance that may be awarded. that may be awarded.



Subject to the maximum Subject to the maximum amount of financial assistance for ONA. amount of financial assistance for ONA.

Medical and Dental Medical and Dental
NA NA
Subject to the maximum Subject to the maximum amount of financial assistance for ONA. amount of financial assistance for ONA.

Assistance Assistance

Child Care Child Care
Available Available for up to eight cumulative weeks. for up to eight cumulative weeks.
Affected state/territory/Indian Affected state/territory/Indian tribal government establishestribal government establishes the the
Assistance Assistance
maximum maximum amount of Child Care Assistance that may be awarded. amount of Child Care Assistance that may be awarded.

Child Care AssistanceChild Care Assistance awards cover the household’s increased awards cover the household’s increased
financial burden for up to eight cumulative weeks of child care, financial burden for up to eight cumulative weeks of child care,
plus any eligibleplus any eligible expenses, or the maximum amount of assistance expenses, or the maximum amount of assistance
for Child Care Assistance established by the affected for Child Care Assistance established by the affected
state/territory/Indian tribal government, whicheverstate/territory/Indian tribal government, whichever is less. is less.

Subject to the maximumSubject to the maximum amount of financial assistance for ONA. amount of financial assistance for ONA.
CRS- CRS-3837


Housing/ONA
Type of Assistance
Time Limitation
Financial Limitation
Assistance Assistance for for
Items must have been purchased/rented within 30 Items must have been purchased/rented within 30
Affected state/territory/Indian Affected state/territory/Indian tribal government identifiestribal government identifies items items
Miscel aneous Miscellaneous Items Items
days after the incident start date or up to the last days after the incident start date or up to the last
eligible eligible for reimbursement. for reimbursement.
day of the incident period, whichever is greater. day of the incident period, whichever is greater.

Subject to the maximumSubject to the maximum amount of financial assistance for ONA. amount of financial assistance for ONA.
Moving and Storage Moving and Storage
Available Available from the incident period start date through from the incident period start date through
Subject to the maximum Subject to the maximum amount of financial assistance for ONA. amount of financial assistance for ONA.
Assistance Assistance
the 18-month period of assistance. the 18-month period of assistance.
Critical Needs Critical Needs
Available Available up to 30 days fromup to 30 days from the date of the the date of the
$500 per eligible $500 per eligible household (unless otherwisehousehold (unless otherwise authorized by authorized by
Assistance Assistance
declaration. declaration.
FEMA). FEMA).

Subject to the maximumSubject to the maximum amount of financial assistance for ONA. amount of financial assistance for ONA.
Clean and Sanitize Clean and Sanitize
NA NA
$300 per eligible $300 per eligible household. household.
Assistance Assistance

Subject to the maximumSubject to the maximum amount of financial assistance for ONA. amount of financial assistance for ONA.
Sources: FEMA, FEMA, Individual Assistance Program and Policy Guide (IAPPG), v. 1.1, FP 104-009-03, May 2021, https://www.fema.gov/sites/default/files/documents/fema_iappg-, v. 1.1, FP 104-009-03, May 2021, https://www.fema.gov/sites/default/files/documents/fema_iappg-
1.1.pdf; and Memorandum from1.1.pdf; and Memorandum from Keith Turi, FEMA Assistant Administrator,Keith Turi, FEMA Assistant Administrator, Recovery Directorate Recovery Directorate to FEMA Regional Administrators,to FEMA Regional Administrators, “RE: Amendmen t “RE: Amendment to FP 104-009-03, to FP 104-009-03,
Individual Assistance ProgramIndividual Assistance Program and Policy Guide, Version 1.1,” Septemberand Policy Guide, Version 1.1,” September 2, 2021, pp. 11-12, https://www.fema.gov/sites/default/files/documents/fema_iappg-policy-2, 2021, pp. 11-12, https://www.fema.gov/sites/default/files/documents/fema_iappg-policy-
amendments-memo.pdf. amendments-memo.pdf.
Notes: Specific accessibility-related Specific accessibility-related real real and personal property items are not subject to the maximumand personal property items are not subject to the maximum amount of financial assistance that may be provided for Housing amount of financial assistance that may be provided for Housing
AssistanceAssistance and ONA, respectively. and ONA, respectively.

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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

Limitations Related to Avoiding a Duplication of Benefits
The Stafford Act prohibits FEMA from providing The Stafford Act prohibits FEMA from providing
Defining “Duplication of Benefits”
assistance that could constitute a duplication of assistance that could constitute a duplication of
(DOB)
benefits, including in the provision of IHP benefits, including in the provision of IHP
There is a statutory prohibition on providing a There is a statutory prohibition on providing a
assistance. assistance.215 Additional y209 Additionally, when applying for IHP , when applying for IHP
duplication of benefits. 42 U.S.C. duplication of benefits. 42 U.S.C. §5155 requires §5155 requires
assistance, applicants “must agree to return funds assistance, applicants “must agree to return funds
the President, in consultation with the heads of the President, in consultation with the heads of
to FEMA when the assistance provided by FEMA to FEMA when the assistance provided by FEMA
the federal agencies administering the federal agencies administering financial financial
assistance programs,assistance programs, to “assure that no such to “assure that no such
duplicates assistance from another source.” duplicates assistance from another source.”216210
person ... wil person ... wil receive receive such assistance with such assistance with
Federal agencies are supposed to coordinate to Federal agencies are supposed to coordinate to
respect to any part of such loss respect to any part of such loss as to which he as to which he
has receivedhas received financial assistance under any other financial assistance under any other
avoid providing a duplication of benefits, and to avoid providing a duplication of benefits, and to
program or from insurance or any other source.” program or from insurance or any other source.”
rectify situations when a duplication occurs. rectify situations when a duplication occurs.217211 To To
As explained in FEMA’s As explained in FEMA’s regulation at 44 C.F.R. regulation at 44 C.F.R.
prevent a duplication of benefits from occurring, prevent a duplication of benefits from occurring,
§206.191(d)(1)(i), a duplication of benefits occurs §206.191(d)(1)(i), a duplication of benefits occurs
FEMA’s regulations include a delivery sequence FEMA’s regulations include a delivery sequence
when an agency provides assistance, when an agency provides assistance, but providing but providing
for disaster assistance, which “establishes the order for disaster assistance, which “establishes the order
such assistance was the primary responsibility such assistance was the primary responsibility of of
in which disaster relief agencies and organizations in which disaster relief agencies and organizations
another agency and that agency with primary another agency and that agency with primary
responsibility provide assistance.” responsibility later provides assistance. later provides assistance.
provide assistance.”218212 For example, before disaster For example, before disaster
survivors may receive Housing Assistance, they survivors may receive Housing Assistance, they
must first see if their needs may be met through voluntary agencies and mass care, and insurance. must first see if their needs may be met through voluntary agencies and mass care, and insurance.
If the disaster survivors have uninsured or underinsured needs, or if their insurance benefits are If the disaster survivors have uninsured or underinsured needs, or if their insurance benefits are
significantly delayed, then federal assistance may be available.significantly delayed, then federal assistance may be available.219213

Example: Duplication of Benefits in the Context of COVID-19 Funeral Assistance
During the COVID-19 pandemic, a question frequently came up related to the reason pre-paid funerals were During the COVID-19 pandemic, a question frequently came up related to the reason pre-paid funerals were
ineligibleineligible to receiveto receive FEMA COVID-19 Funeral Assistance.FEMA COVID-19 Funeral Assistance. FEMA cited duplication of benefits as the justification, FEMA cited duplication of benefits as the justification,
explaining, explaining,
“Any source of payment designated “Any source of payment designated specifical y specifically to pay for a funeral priorto pay for a funeral prior to death is considered a duplication to death is considered a duplication
and is not eligibleand is not eligible for reimbursement.for reimbursement. COVID-19 Funeral AssistanceCOVID-19 Funeral Assistance may not duplicate burial or funeral may not duplicate burial or funeral
insurance proceeds,insurance proceeds, pre-planned or pre-paid funeral contracts, pre-paid trust for funeral expenses, pre-planned or pre-paid funeral contracts, pre-paid trust for funeral expenses,
irrevocableirrevocable trust for Medicaid, financial assistance from voluntary organizations, government programs or trust for Medicaid, financial assistance from voluntary organizations, government programs or
agencies, or any other sourcesagencies, or any other sources specifical y specifically designated for funeral expenses. designated for funeral expenses. Any eligibleAny eligible COVID-19 Funeral COVID-19 Funeral
AssistanceAssistance wil be reduced by the amount of other assistance you received for the same expenses.” wil be reduced by the amount of other assistance you received for the same expenses.”
(FEMA, “Funeral Assistance (FEMA, “Funeral Assistance FAQ,” https://www.fema.gov/disaster/coronavirus/economic/funeral-assistance/faq; FAQ,” https://www.fema.gov/disaster/coronavirus/economic/funeral-assistance/faq;
FEMA, “COVID-19 Funeral Assistance Individuals and Households Program Policy (Interim),” v. 2, FP 04FEMA, “COVID-19 Funeral Assistance Individuals and Households Program Policy (Interim),” v. 2, FP 04 -21-0001, -21-0001,
June 29, 2021, https://www.fema.gov/sites/default/files/documents/fema_covid-19-funeral-assistance-interim-policy-June 29, 2021, https://www.fema.gov/sites/default/files/documents/fema_covid-19-funeral-assistance-interim-policy-
version-2_06-29-2021.pdf.) version-2_06-29-2021.pdf.)

215 209 42 U.S.C. 42 U.S.C. §5155; 44 C.F.R.§5155; 44 C.F.R. §206.191. §206.191.
216210 FEMA, FEMA, IAPPG, p. 176. In addition to returning funds, p. 176. In addition to returning funds that duplicate assistance provided from another source, that duplicate assistance provided from another source,
applicants must agree to return funds that were provided in error, spent on expenses inappropriately, or obtained applicants must agree to return funds that were provided in error, spent on expenses inappropriately, or obtained
through fraudulent means. through fraudulent means.
217211 44 C.F.R. §206.191(b)(1). 44 C.F.R. §206.191(b)(1).
218212 44 C.F.R. §206.191(d)(1)(i) and (d)(2). 44 C.F.R. §206.191(d)(1)(i) and (d)(2).
219213 44 C.F.R. §206.191(d)(2)(ii). See also 44 C.F.R. 44 C.F.R. §206.191(d)(2)(ii). See also 44 C.F.R. §206.113(a)(3); FEMA, §206.113(a)(3); FEMA, IAPPG, p. 51. FEMA’s regulations state , p. 51. FEMA’s regulations state
“FEMA may only provide assistance: …“FEMA may only provide assistance: … In a situation where the applicant has insurance, when the insuredIn a situation where the applicant has insurance, when the insured individual individual
or household’s insurance proceeds have been significantly delayedor household’s insurance proceeds have been significantly delayed [i.e., 30 days[i.e., 30 days or more from the date a claim was or more from the date a claim was
filed, per the IAPPG] through no fault of his, her or their own, and the applicant has agreed to repay the assistance to filed, per the IAPPG] through no fault of his, her or their own, and the applicant has agreed to repay the assistance to
FEMA or the State from insurance proceeds that he, she or they receive later….” FEMA or the State from insurance proceeds that he, she or they receive later….”
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link to page 18 link to page link to page 18 link to page 2625 link to page link to page 2625 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

One source of confusion related to the sequence of delivery and IHP assistance relates to the One source of confusion related to the sequence of delivery and IHP assistance relates to the
requirement to apply for SBA disaster loans before receiving some forms of IHP assistance. requirement to apply for SBA disaster loans before receiving some forms of IHP assistance.
Specifical ySpecifically, although FEMA does not require applicants to first apply for an SBA disaster loan , although FEMA does not require applicants to first apply for an SBA disaster loan
before being considered for Housing Assistance, FEMA does require applicants to apply for an before being considered for Housing Assistance, FEMA does require applicants to apply for an
SBA disaster loan before they can be considered for SBA-Dependent ONA. As described in the SBA disaster loan before they can be considered for SBA-Dependent ONA. As described in the
“SBA-Dependent ONA” section, because the forms of SBA-Dependent ONA may also be section, because the forms of SBA-Dependent ONA may also be
addressed by an SBA disaster loan, disaster survivors must first apply for an SBA disaster loan, addressed by an SBA disaster loan, disaster survivors must first apply for an SBA disaster loan,
and if denied or the loan amount is insufficient to cover their unmet needs, the disaster survivor and if denied or the loan amount is insufficient to cover their unmet needs, the disaster survivor
may then be eligiblemay then be eligible for SBA-Dependent ONA.for SBA-Dependent ONA.220214 It is worth noting that SBA disaster loans can It is worth noting that SBA disaster loans can
also help address the housing needs of disaster survivors (e.g., SBA Real Property Disaster Loans also help address the housing needs of disaster survivors (e.g., SBA Real Property Disaster Loans
for creditworthy homeowners), yet there is not a requirement for applicants to pursue an SBA for creditworthy homeowners), yet there is not a requirement for applicants to pursue an SBA
disaster loan before becoming eligible to receive IHP Housing Assistance.disaster loan before becoming eligible to receive IHP Housing Assistance.221215
FEMA may coordinate with voluntary agencies to address outstanding unmet needs when disaster FEMA may coordinate with voluntary agencies to address outstanding unmet needs when disaster
survivors have received survivors have received al all of the federal assistance for which they are eligible.of the federal assistance for which they are eligible.222216 Other forms of Other forms of
federal assistance may also be availablefederal assistance may also be available to meet the unmet needs of disaster survivors, depending to meet the unmet needs of disaster survivors, depending
on the disaster.on the disaster.223217
IHP Challenges and Congressional Considerations
The following sections address some of the potential IHP-related The following sections address some of the potential IHP-related chal engeschallenges and considerations and considerations
that may be of interest to Congress, including with regard to FEMA’s evaluation of the IA factors that may be of interest to Congress, including with regard to FEMA’s evaluation of the IA factors
and presidential declaration recommendation, evaluating the cost of IHP assistance, and and presidential declaration recommendation, evaluating the cost of IHP assistance, and
considering whether FEMA’s current IHP assistance programs are sufficient to meet the needs of considering whether FEMA’s current IHP assistance programs are sufficient to meet the needs of
future disaster survivors. future disaster survivors.
Increasing Transparency Regarding FEMA’s Evaluation of
Requests for Major Disaster Declarations Authorizing IA—IHP
Some Members of Congress have expressed concern with the declaration process that results in Some Members of Congress have expressed concern with the declaration process that results in
the President’s approval or denial of a Stafford Act major disaster declaration authorizing the President’s approval or denial of a Stafford Act major disaster declaration authorizing
Individual Assistance and/or Public Assistance.Individual Assistance and/or Public Assistance.224218 A common source of confusion and frustration A common source of confusion and frustration
relates to the declaration decisionmaking process—relates to the declaration decisionmaking process—specifical yspecifically, the limited insight into FEMA’s , the limited insight into FEMA’s
evaluationevaluation of the IA factors, and the lack of information regarding FEMA’s declaration of the IA factors, and the lack of information regarding FEMA’s declaration
recommendation to the President. recommendation to the President.

220 214 44 C.F.R. §206.191(d)(2)(iii) and (d)(2)(iv). 44 C.F.R. §206.191(d)(2)(iii) and (d)(2)(iv).
221215 For additional information on the SBA Disaster Loan Program, see CRS For additional information on the SBA Disaster Loan Program, see CRS Report R41309, Report R41309, The SBA Disaster Loan
Program : Overview and Possible Issues for Congress
, by Bruce, by Bruce R. Lindsay. R. Lindsay.
222216 For more information on the sequence of delivery, see For more information on the sequence of delivery, see CRS CRS Report R44553, Report R44553, SBA and CDBG-DR Duplication of
Benefits in the Adm inistrationAdministration of Disaster Assistance: Background, Policy Issues, and Options for Congress
,, by Bruce by Bruce
R. Lindsay and EugeneR. Lindsay and Eugene Boyd; and CRSBoyd; and CRS Report R45238, Report R45238, FEMA and SBA Disaster Assistance for Individuals and
Households: Application Processes, Determ inationsDeterminations, and Appeals
, by Bruce, by Bruce R. Lindsay and Elizabeth M. Webster. R. Lindsay and Elizabeth M. Webster.
223 217 For example, Congress For example, Congress may appropriate funding for the Department of Housing and Urban Development’s may appropriate funding for the Department of Housing and Urban Development’s
Community Development Block GrantCommunity Development Block Grant —Disaster Recovery (CDBG-DR)—Disaster Recovery (CDBG-DR) program (HUD, “program (HUD, “ Community Development Community Development
Block Grant Disaster Recovery Program,” https://www.hudexchange.info/programs/cdbg-dr/).Block Grant Disaster Recovery Program,” https://www.hudexchange.info/programs/cdbg-dr/). See See also CRSalso CRS Report Report
R43520, R43520, Com m unity Developm entCommunity Development Block Grants and Related Program s: A Prim erPrograms: A Primer, by Joseph V. Jaroscak. , by Joseph V. Jaroscak.
224218 Additional information on the declaration process can be found Additional information on the declaration process can be found in thein theApproving Requests for Individual
Assistance”
section. section.
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Although there is some publicly available Although there is some publicly available information related to the information related to the decisionmakingdecision making process process
associated with evaluating major disaster declaration requests, the available information is associated with evaluating major disaster declaration requests, the available information is
limited.limited. FEMA publishes Preliminary Damage Assessment (PDA) Reports, which are posted to FEMA publishes Preliminary Damage Assessment (PDA) Reports, which are posted to
FEMA’s website and include information about the incident, the type(s) of Stafford Act FEMA’s website and include information about the incident, the type(s) of Stafford Act
assistance requested and the areas for which assistance was requested, a summary of the damage assistance requested and the areas for which assistance was requested, a summary of the damage
assessment information, which support FEMA’s evaluation of the IA and PA factors, and the assessment information, which support FEMA’s evaluation of the IA and PA factors, and the
President’s decision to declare a major disaster or deny the request (as President’s decision to declare a major disaster or deny the request (as wel well as the assistance as the assistance
authorized and the areas designated to receive such assistance).authorized and the areas designated to receive such assistance).225 Historical y219 Historically, there was a PDA , there was a PDA
Report publication requirement authorized inReport publication requirement authorized in previous annual appropriations legislation.previous annual appropriations legislation.226
220 Although not currently required by legislation, FEMAAlthough not currently required by legislation, FEMA has continued to publish the PDA Reports has continued to publish the PDA Reports
for the major disaster declaration requests to its website (beginning in FY2008 through the for the major disaster declaration requests to its website (beginning in FY2008 through the
present).present).227 221 Congress could establish the PDA reporting requirement in permanent law and could Congress could establish the PDA reporting requirement in permanent law and could
consider specifying the information to be included in such reports. consider specifying the information to be included in such reports.
As noted above, the PDA Reports provide a summary of the damage assessment information, but As noted above, the PDA Reports provide a summary of the damage assessment information, but
they merely list the information related to the factors (e.g., for IA, the total number of impacted they merely list the information related to the factors (e.g., for IA, the total number of impacted
residences and degree of damage; percentages associated with the affected population profile residences and degree of damage; percentages associated with the affected population profile
groups; and the ICC Ratio and IA cost estimate). The PDA Reports do not include any analysis as groups; and the ICC Ratio and IA cost estimate). The PDA Reports do not include any analysis as
to how the information was evaluated by FEMA or how the information submitted in the to how the information was evaluated by FEMA or how the information submitted in the
declaration request informed FEMA’s recommendation to the President. Portions of FEMA’s declaration request informed FEMA’s recommendation to the President. Portions of FEMA’s
evaluation of the factors and recommendation to the President may evaluation of the factors and recommendation to the President may fal fall into one of the nine into one of the nine
exemptions to the Freedom of Information Act (FOIA; 5 U.S.C. §552) statute’s rules of exemptions to the Freedom of Information Act (FOIA; 5 U.S.C. §552) statute’s rules of
disclosure.disclosure.228222 For example, Exemption 5 applies to “inter-agency or intra-agency memorandums For example, Exemption 5 applies to “inter-agency or intra-agency memorandums
or letters that would not be availableor letters that would not be available by law to a party other than an agency in litigationby law to a party other than an agency in litigation with the

225 with the 219 FEMA, “Preliminary Damage Assessment Reports,” https://www.fema.gov/disaster/how-declared/preliminary- FEMA, “Preliminary Damage Assessment Reports,” https://www.fema.gov/disaster/how-declared/preliminary-
damage-assessments/reports (hereinafter FEMA, “damage-assessments/reports (hereinafter FEMA, “ PDA Reports”). PDA Reports”). T heThe President may approve the governor’s request President may approve the governor’s request
in whole or in part (i.e., some or all forms of requestedin whole or in part (i.e., some or all forms of requested assistance may be authorized for some or all of the areas assistance may be authorized for some or all of the areas
requested). requested).
226220 Section 569 of the Consolidated Appropriations Act, 2008 (P.L. 110-161) required that FEMA submit reports to the Section 569 of the Consolidated Appropriations Act, 2008 (P.L. 110-161) required that FEMA submit reports to the
Senate Committee on Homeland Security and Governmental Affairs (HSGAC),Senate Committee on Homeland Security and Governmental Affairs (HSGAC), the House Committee on Homeland the House Committee on Homeland
Security (HouseSecurity (House Homeland), the House Committee on Homeland), the House Committee on T ransportationTransportation and Infrastructure (T and Infrastructure (T &I), and the House and &I), and the House and
Senate Committees on Appropriations, and publish reports to FEMA’s websiteSenate Committees on Appropriations, and publish reports to FEMA’s website that summarize the damage assessment that summarize the damage assessment
information (i.e., the Preliminary Damage Assessment (PDA)) that was usedinformation (i.e., the Preliminary Damage Assessment (PDA)) that was used to determine whether to declare a major to determine whether to declare a major
disaster. disaster. T hisThis PDA Report publication requirement was PDA Report publication requirement was in effect through FY2015, making its last appearance in an in effect through FY2015, making its last appearance in an
enacted appropriations measure in Section 531 of the Department of Homeland Security Appropriations Act, 2015 enacted appropriations measure in Section 531 of the Department of Homeland Security Appropriations Act, 2015
(P.L. 114-4). (P.L. 114-4). T heThe requirement continued as report language in FY2016 (the PDA reports were referred to as requirement continued as report language in FY2016 (the PDA reports were referred to as
“Preliminary Disaster Assessments” in Explanatory Statement Submitted By Mr. Rogers“Preliminary Disaster Assessments” in Explanatory Statement Submitted By Mr. Rogers of Kentucky, Chairman of the of Kentucky, Chairman of the
HouseHouse Committee on Appropriations Regarding HouseCommittee on Appropriations Regarding House Amendment No. 1 to the Senate Amendment on H.R. 2029—Amendment No. 1 to the Senate Amendment on H.R. 2029—
Continued: Consolidated Appropriations Act, 2016, Continued: Consolidated Appropriations Act, 2016, Congressional Record, vol. 161, no. 184 (December 17, 2015), p. , vol. 161, no. 184 (December 17, 2015), p.
H10175, https://congress.gov/crec/2015/12/17/CREC-2015-12-17-pt3-PgH10161.pdf). More recently, the report H10175, https://congress.gov/crec/2015/12/17/CREC-2015-12-17-pt3-PgH10161.pdf). More recently, the report
associated with H.R. 3931—Department of Homeland Security Appropriations Act, 2020 included the following associated with H.R. 3931—Department of Homeland Security Appropriations Act, 2020 included the following
commentary: “Preliminary Damage Assessments.—commentary: “Preliminary Damage Assessments.—T heThe Committee is concerned that FEMA has stopped publishing Committee is concerned that FEMA has stopped publishing
the reports and summaries of preliminary damage assessmentsthe reports and summaries of preliminary damage assessments in accordance with section 531 of the Department of in accordance with section 531 of the Department of
Homeland Security Appropriations Act, 2015, P.L. 114-4. The Committee understands that FEMA will resume Homeland Security Appropriations Act, 2015, P.L. 114-4. The Committee understands that FEMA will resume
publishingpublishing these reports and summariesthese reports and summaries and encourages them to do so expeditiously” (U.S. Congress,and encourages them to do so expeditiously” (U.S. Congress, House House
Committee on Appropriations, Committee on Appropriations, Departm ent of Hom elandDepartment of Homeland Security Appropriations Bill, 2020 , 116th Cong., 1st sess., July , 116th Cong., 1st sess., July
24, 2019, H.Rept. 116-180, p. 59). 24, 2019, H.Rept. 116-180, p. 59).
227 221 FEMA, “PDA Reports.” It can take time for the most recent PDA reports to be published. FEMA, “PDA Reports.” It can take time for the most recent PDA reports to be published.
228 T he 222 The Freedom of Information Act (FOIA; 5 U.S.C. §552). For additional Freedom of Information Act (FOIA; 5 U.S.C. §552). For additional informat ioninformation on the Freedom of Information on the Freedom of Information
Act, includingAct, including FOIA exemptions, see CRSFOIA exemptions, see CRS Report R41933, Report R41933, The Freedom of Inform ation of Information Act (FOIA): Background,
Legislation, and Policy Issues
,, by Meghan M. Stuessy;by Meghan M. Stuessy; CRS Report CRS Report R46238, R46238, The Freedom of Inform ation of Information Act (FOIA):
A Legal Overview
,, by Daniel J. Sheffner; and CRSby Daniel J. Sheffner; and CRS Infographic IG10019, Infographic IG10019, The Freedom of Inform ation of Information Act (FOIA), by , by
Daniel J. Sheffner. Daniel J. Sheffner.
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agency.” agency.”229223 It is possible that portions of FEMA’s analysis concerning its evaluation of the factors It is possible that portions of FEMA’s analysis concerning its evaluation of the factors
and recommendations to the President related to a specific major disaster declaration request and recommendations to the President related to a specific major disaster declaration request
could be protected from mandatory disclosure under FOIA by Exemption 5. could be protected from mandatory disclosure under FOIA by Exemption 5.
Congress could require FEMA to revise its guidance on how the IA factors are evaluated. Congress could require FEMA to revise its guidance on how the IA factors are evaluated.
Revisions to FEMA’s Revisions to FEMA’s IA Declarations Factors Guidance (states/territories) and the (states/territories) and the Tribal
Declarations Pilot Guidance
, including to provide more specific information or scenarios that , including to provide more specific information or scenarios that
il ustrateillustrate how FEMA applies the information and data submitted in the state/territory/tribal how FEMA applies the information and data submitted in the state/territory/tribal
government’s declaration request in its evaluation of the IA factors, could be useful to requesting government’s declaration request in its evaluation of the IA factors, could be useful to requesting
states, territories, and tribes when developing their major disaster declaration requests. Revising states, territories, and tribes when developing their major disaster declaration requests. Revising
FEMA’s guidance to clarify how the agency analyzes the information submitted by the FEMA’s guidance to clarify how the agency analyzes the information submitted by the
state/territory/tribe may help support congressional initiatives to increase agency transparency. state/territory/tribe may help support congressional initiatives to increase agency transparency.
However, it is the President, and not FEMA, who ultimately has the discretion to approve major However, it is the President, and not FEMA, who ultimately has the discretion to approve major
disaster declaration requests. Increasing transparency related to FEMA’s evaluation of the factors disaster declaration requests. Increasing transparency related to FEMA’s evaluation of the factors
may help states/territories/tribes make their best case for needing supplemental federal assistance may help states/territories/tribes make their best case for needing supplemental federal assistance
following a disaster, but it may not affect the ultimate outcome of declaration decisions. following a disaster, but it may not affect the ultimate outcome of declaration decisions.
Additional y, Additionally, Congress could require FEMA to assess new approaches for evaluating the IA Congress could require FEMA to assess new approaches for evaluating the IA
factors that incorporate more quantitative data,factors that incorporate more quantitative data,230224 and could consider requiring FEMA to revise and could consider requiring FEMA to revise
the IA factors to incorporate any findings of such an evaluation.the IA factors to incorporate any findings of such an evaluation. In December 2022, Congress required the Comptroller General to conduct a review of FEMA’s IA factors, including assessing (1) the criteria FEMA uses to assess requests for major disaster declarations authorizing IA; (2) the consistency with which FEMA uses the factors to assess the impact of disasters on communities; and (3) the impact the updated factors have had on equity in disaster response outcomes. The GAO was also required to provide Congress with recommendations to improve the use of the IA factors to increase equity in disaster recovery outcomes.225
Expanding Access to Data to Track the Cost of IHP Assistance
Some Members of Congress frequently express interest in understanding the total cost of disaster Some Members of Congress frequently express interest in understanding the total cost of disaster
assistance provided for a specific incident or form of IHP assistance; however, it is difficult to assistance provided for a specific incident or form of IHP assistance; however, it is difficult to
provide information on the total cost of IHP Housing Assistance, and FEMA’s publicly available provide information on the total cost of IHP Housing Assistance, and FEMA’s publicly available
data sources for IHP financial assistance lack granularity. data sources for IHP financial assistance lack granularity.
Although FEMA makes information on the costs of Financial Housing Assistance publicly Although FEMA makes information on the costs of Financial Housing Assistance publicly
availableavailable through the “OpenFEMA Data Sets” for Individual Assistance, as through the “OpenFEMA Data Sets” for Individual Assistance, as wel well as the declared as the declared
disasters disasters webpagesweb pages for presidentially declared Stafford Act emergencies and major disasters, for presidentially declared Stafford Act emergencies and major disasters,231
Direct Housing Assistance information is not general y publicly available.232 In December 2020,
the GAO reported that FEMA “does not track cost data for direct housing programs.”
Additional y, administrative cost information is only tracked at the overal Individual Assistance
program level, and not at a more granular IHP program level, and indirect administrative costs are

229226 223 5 U.S.C. 5 U.S.C. §552(b)(5). §552(b)(5).
230224 Challenges Challenges associated with FEMA’sassociated with FEMA’s evaluation of the IA factors, including related to the vagueness of the factors evaluation of the IA factors, including related to the vagueness of the factors
and the lack of a quantitative approach, are addressedand the lack of a quantitative approach, are addressed by Christopher Currie, Director, Homeland Security and Justice by Christopher Currie, Director, Homeland Security and Justice
T eamTeam, GAO, including, GAO, including in his responses to Representatives in his responses to Representatives T hompsonThompson, Katko, and Barragan during, Katko, and Barragan during a hearing by the a hearing by the
HouseHouse Committee on Homeland Security focusedCommittee on Homeland Security focused on on Ensuring Equity in Disaster Preparedness, Response, and
Recovery
(U.S. Congress, (U.S. Congress, House Committee on Homeland Security, House Committee on Homeland Security, Ensuring Equity in Disaster Preparedness,
Response, and Recovery
, 117th Cong., 1st sess.,, 117th Cong., 1st sess., October 27, 2021). October 27, 2021).
231 See FEMA, “ 225 Section 5601(b)(1) and (2) of the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 (P.L. 117-263). Per Section 5601(b)(3), Congress required the GAO to submit a report on its review the final rule to the House Committee on Transportation and Infrastructure and the Senate Committee on Homeland Security and Governmental Affairs within a year of enactment (i.e., December 23, 2023). 226 See FEMA, “OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets; see also FEMA, “OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets; see also FEMA, “ Declared
Disasters,” https://www.fema.gov/disaster/declarations.
232 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 13. For select incidents, however, FEMA has
provided publicly available information on direct housing assistance. For example, FEMA’s fact sheet on “Hurricane
Maria by the Numbers” from August 21, 2020 included total dollars approved for both finan cial and direct housing
assistance, as well as ONA, and included a “Federal Housing Snapshot” section with funding for specific forms of IHP,
including Direct Lease and Multi-Family Lease and Repair (the version of the “ DR-4339 Hurricane Maria by the
Numbers” released November 2, 2021 does not provide the previously available level of granularity regarding IHP
assistance, available at https://www.fema.gov/fact-sheet/hurricane-maria-numbers).
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not collected.233 The GAO provided recommendations to al ow FEMA to analyze the full cost of
providing Housing Assistance.234 FEMA is developing a new system (cal edDeclared Disasters,” https://www.fema.gov/disaster/declarations. Congressional Research Service 42 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations Direct Housing Assistance information is not generally publicly available.227 In December 2020, the GAO reported that FEMA “does not track cost data for direct housing programs.” Additionally, administrative cost information is only tracked at the overall Individual Assistance program level, and not at a more granular IHP program level, and indirect administrative costs are not collected.228 The GAO provided recommendations to allow FEMA to analyze the full cost of providing Housing Assistance.229 FEMA is developing a new system (called the “Grants the “Grants
Management Modernization System”), which is to include a disaster housing assistance Management Modernization System”), which is to include a disaster housing assistance
component.component.235230 In June 2021, the Department of Homeland Security (DHS) reported to the GAO In June 2021, the Department of Homeland Security (DHS) reported to the GAO
that FEMA that FEMA wil will continue refining the requirements needed to capture the full cost of providing continue refining the requirements needed to capture the full cost of providing
Housing Assistance and that “FEMA plans to identify a system for implementation by September Housing Assistance and that “FEMA plans to identify a system for implementation by September
30, 2024.”30, 2024.”236231 Consistent with the GAO’s recommendations, with which DHS concurred, Consistent with the GAO’s recommendations, with which DHS concurred,237232
Congress could consider requiring FEMA to expand the IHP program and administrative data the Congress could consider requiring FEMA to expand the IHP program and administrative data the
agency collects and maintains to ensure agency collects and maintains to ensure al all of the data needed to accurately evaluate each of the data needed to accurately evaluate each
program’s implementation costs are program’s implementation costs are col ected.238collected.233 This could also help ensure FEMA is able to This could also help ensure FEMA is able to
accurately assess the cost-effectiveness of its housing programs and make informed decisions accurately assess the cost-effectiveness of its housing programs and make informed decisions
about the cost-effectiveness of its programs when determining what housing assistance options to about the cost-effectiveness of its programs when determining what housing assistance options to
activate in support of a specific disaster.activate in support of a specific disaster.239234 Further, once the expanded direct housing assistance Further, once the expanded direct housing assistance
data exists, Congress may seek for FEMA to publicly report on the costs of its Direct Housing data exists, Congress may seek for FEMA to publicly report on the costs of its Direct Housing
Assistance programs by publishing the data in the IA OpenFEMA Data Sets. Such a requirement
would be consistent with other congressional efforts to increase government transparency and
FEMA accountability, and would provide the public with a more complete picture of the costs of
IHP Housing Assistance.
Additional y, while IHP financial assistance data is publicly available,240 the data lacks
granularity. FEMA provides several datasets, which provide publicly available IA—IHP data:

233 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 13.
234 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 20.
235 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 14; see also GAO, FEMA Grants Modernization:
Im provem ents Needed to Strengthen Program Managem ent and Cybersecurity
, GAO-19-164, April 9, 2019, p. 55,
https://www.gao.gov/assets/700/698347.pdf.
236 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 46; GAO, “Disaster Housing: Improved Cost Data
and Guidance Would Aid 227 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 13. For select incidents, however, FEMA has provided publicly available information on direct housing assistance. For example, FEMA’s fact sheet on “Hurricane Maria by the Numbers” from August 21, 2020 included total dollars approved for both financial and direct housing assistance, as well as ONA, and included a “Federal Housing Snapshot” section with funding for specific forms of IHP, including Direct Lease and Multi-Family Lease and Repair (the version of the “DR-4339 Hurricane Maria by the Numbers” released November 2, 2021 does not provide the previously available level of granularity regarding IHP assistance, available at https://www.fema.gov/fact-sheet/hurricane-maria-numbers). 228 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 13. 229 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 20. 230 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 14; see also GAO, FEMA Grants Modernization: Improvements Needed to Strengthen Program Management and Cybersecurity, GAO-19-164, April 9, 2019, p. 55, https://www.gao.gov/assets/700/698347.pdf. 231 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 46; GAO, “Disaster Housing: Improved Cost Data and Guidance Would Aid FEMA Activation Decisions,” GAO-21-116, December 15, 2020, https://www.gao.gov/FEMA Activation Decisions,” GAO-21-116, December 15, 2020, https://www.gao.gov/
products/gao-21-116 (see the status of Recommendation 1 as of products/gao-21-116 (see the status of Recommendation 1 as of November 10, 2021 May 15, 2023, in the , in the T able: “ Table: “Recommendations Recommendations
for Executive Action”). for Executive Action”).
237 T he232 The GAO’s GAO’s Disaster Housing: Improved Cost Data and Guidance report included two recommendations: the report included two recommendations: the
FEMA Administrator should (1) “identify and make changes to the applicable data system to capture cost data ... for FEMA Administrator should (1) “identify and make changes to the applicable data system to capture cost data ... for
each of its housing assistance programs that will allow the agency to analyze the full cost of providing assistance under each of its housing assistance programs that will allow the agency to analyze the full cost of providing assistance under
each program”; andeach program”; and (2) “specify the information needed to compare the projected costs of each direct housing program (2) “specify the information needed to compare the projected costs of each direct housing program
in its guidancein its guidance for assessingfor assessing which programs to activate.” (GAO, which programs to activate.” (GAO, Disaster Housing: Improved Cost Data and
Guidance
, pp. 20 and 46.) , pp. 20 and 46.)
238233 GAO, GAO, Disaster Housing: Improved Cost Data and Guidance, p. 12; see also Department of Homeland Security , p. 12; see also Department of Homeland Security
(DHS)(DHS) Office of Inspector General (OIG), Office of Inspector General (OIG), FEMA Purchased More Manufactured Housing Units Than It Needed in
Texas After Hurricane Harvey
, OIG-20-15, February 26, 2020, p. 7, https://www.oig.dhs.gov/sites/default/files/assets/, OIG-20-15, February 26, 2020, p. 7, https://www.oig.dhs.gov/sites/default/files/assets/
2020-03/OIG-20-15-Feb20.pdf. For example, the DHS OIG2020-03/OIG-20-15-Feb20.pdf. For example, the DHS OIG found that “found that “ FEMA did not maintain complete records of FEMA did not maintain complete records of
MHU [manufactured housingMHU [manufactured housing unit] and unit] and T PSTPS [tank and pump systems] program costs.” [tank and pump systems] program costs.”
239234 In 2011, the DHS OIG In 2011, the DHS OIG reported that FEMA did not maintain “reliable program effectiveness and cost information” reported that FEMA did not maintain “reliable program effectiveness and cost information”
to evaluate housing programs (in the context of the referenced report, the DHAP’s cost effectiveness could notto evaluate housing programs (in the context of the referenced report, the DHAP’s cost effectiveness could not be be
evaluated dueevaluated due to insufficient data) (DHSto insufficient data) (DHS OIG,OIG, Effectiveness and Costs of FEMA’s Disaster Housing Assistance
Program
, OIG-11-102, August 2011, pp. 1 and 7-8, https://www.oig.dhs.gov, OIG-11-102, August 2011, pp. 1 and 7-8, https://www.oig.dhs.gov/sites/default/files/assets/Mgmt/OIG_11-102_Aug11.pdf). /assets/Mgmt/OIG_11-102_Aug11.pdf).
T heThe GAO also found that “cost data issues ... have persisted and largely GAO also found that “cost data issues ... have persisted and largely precluded precluded FEMA from demonstrating the FEMA from demonstrating the
relative costrelative cost -effectiveness of its housing programs.... -effectiveness of its housing programs.... T heThe data limitations also limited our ability to compare the costs data limitations also limited our ability to compare the costs
and costand cost -effectiveness of direct housing programs.... ” (GAO,-effectiveness of direct housing programs.... ” (GAO, Disaster Housing: Im provedImproved Cost Data and Guidance, ,
pp. 10-11).
240 See FEMA, “ OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets; see also FEMA, “ Declared
Disasters,” https://www.fema.gov/disaster/declarations.
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 Housing Assistance Program Data–Owners;
 Housing Assistance Program Data–Renters;
 Individuals and Households Program (IHP) Flood Damage;
 Individuals and Households Program–Valid Registrations;
 Individual Assistance Housing Registrants–Large Disasters; and
Assistance programs by publishing the data in the IA OpenFEMA Data Sets. Such a requirement would be consistent with other congressional efforts to increase government transparency and FEMA accountability, and would provide the public with a more complete picture of the costs of IHP Housing Assistance. Additionally, while IHP financial assistance data is publicly available,235 the data lacks granularity. FEMA provides several datasets, which provide publicly available IA—IHP data: • Housing Assistance Program Data–Owners; • Housing Assistance Program Data–Renters; • Individuals and Households Program (IHP) Flood Damage; • Individuals and Households Program–Valid Registrations; • Individual Assistance Housing Registrants–Large Disasters; and • Registration Intake and Individuals Household Program (RI–IHP). Registration Intake and Individuals Household Program (RI–IHP).
The datasets include different data fields that provide program information, including related to The datasets include different data fields that provide program information, including related to
FEMA inspections and verified losses, and IHP awards. Some of the datasets provide the total FEMA inspections and verified losses, and IHP awards. Some of the datasets provide the total
IHP amount approved for Housing Assistance and ONA,IHP amount approved for Housing Assistance and ONA,241236 some also provide the amount of some also provide the amount of
Housing Assistance awarded and the amount of ONA awarded.Housing Assistance awarded and the amount of ONA awarded.242237 However, funding information However, funding information
for specific types of Housing Assistance and ONA is limited or aggregated, making it unclear for specific types of Housing Assistance and ONA is limited or aggregated, making it unclear
how much funding was provided for specific types of IHP Housing Assistance and ONA. For how much funding was provided for specific types of IHP Housing Assistance and ONA. For
example, some of the datasets include data fields for Home Repair Assistance, Home example, some of the datasets include data fields for Home Repair Assistance, Home
Replacement Assistance, and Rental Assistance, but Home Repair and Home Replacement Replacement Assistance, and Rental Assistance, but Home Repair and Home Replacement
Assistance are aggregated in some datasets, as are some other types of Financial Housing Assistance are aggregated in some datasets, as are some other types of Financial Housing
Assistance.Assistance.243238 Assistance provided for Assistance provided for al all types of ONA is types of ONA is general ygenerally aggregated. aggregated.244239 To the extent To the extent
that granularity is provided with regard to awards for specific types of ONA, the data is limited to that granularity is provided with regard to awards for specific types of ONA, the data is limited to
Personal Property Assistance,Personal Property Assistance,245240 but it is unclear how much assistance was provided for other but it is unclear how much assistance was provided for other
specific types of ONA.specific types of ONA.246 (See241 (See Table C-1 for a list of the data fields provided for each of the for a list of the data fields provided for each of the
above-listed datasets.) Congress could consider requiring FEMA to provide data fields detailing
the financial assistance provided for the specific types of Financial Housing Assistance and ONA,
and could request information from FEMA on any potential chal enges associated with providing

241 235 See FEMA, “OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets; see also FEMA, “Declared Disasters,” https://www.fema.gov/disaster/declarations. 236 For example, the Housing Assistance Program Data—Owners and—Renters datasets include For example, the Housing Assistance Program Data—Owners and—Renters datasets include the data field:the data field: T otal Total
Approved IHP Amount, which refers to the “[t]otal amount approved in dollars under FEMA’s IHP program.”Approved IHP Amount, which refers to the “[t]otal amount approved in dollars under FEMA’s IHP program.”
242 237 For example, the Registration Intake and Individuals For example, the Registration Intake and Individuals Household Program (RI–IHP) dataset provides the HA Household Program (RI–IHP) dataset provides the HA
[Housing[Housing Assistance] Amount and the ONA Amount, which refers to the “Assistance] Amount and the ONA Amount, which refers to the “ [t]otal amount awarded for Housing [t]otal amount awarded for Housing
Assistance (HA) in dollars from the IndividualAssistance (HA) in dollars from the Individual and Householdsand Households Program (IHP)” and the “[t]otal amount awarded in Program (IHP)” and the “[t]otal amount awarded in
dollars for Other Needsdollars for Other Needs Assistance (ONA) from the IndividualAssistance (ONA) from the Individual and Householdsand Households Program (IHP),” respectively. Program (IHP),” respectively.
243 238 For example, the Housing Assistance Program Data–Owners dataset includes For example, the Housing Assistance Program Data–Owners dataset includes a Repair/Replace Amount data field a Repair/Replace Amount data field
that provides the “[t]otal amount of Repair and/or Replacement approved in dollars for Housingthat provides the “[t]otal amount of Repair and/or Replacement approved in dollars for Housing Assistance (HA) under Assistance (HA) under
FEMA’s IHP program (note that renters are not eligible for this type of assistance becauseFEMA’s IHP program (note that renters are not eligible for this type of assistance because they do not own the they do not own the
structure).” For the IHP Validstructure).” For the IHP Valid Registrations dataset, however, the Repair Amount and Replacement Amount are Registrations dataset, however, the Repair Amount and Replacement Amount are
separate data fields. separate data fields.
244239 For example, the Housing Assistance Program Data–Owners dataset’s Other Needs Amount data field For example, the Housing Assistance Program Data–Owners dataset’s Other Needs Amount data field provides the provides the
“[t]otal amount of Other Needs (ONA) assistance approved in dollars“[t]otal amount of Other Needs (ONA) assistance approved in dollars under FEMA’s IHP program (this couldunder FEMA’s IHP program (this could include, include,
personal property, transportation, medical, dental, funeral, essential tools, moving/storage, miscellaneous and other personal property, transportation, medical, dental, funeral, essential tools, moving/storage, miscellaneous and other
needs).” needs).”
245 240 For example, the IHP Valid For example, the IHP Valid Registrations dataset provides the amount of ONA awardedRegistrations dataset provides the amount of ONA awarded for Personal Property for Personal Property
Assistance. Assistance.
246241 As an example of an exception As an example of an exception t oto the statement that it is unclear how much assistance is the statement that it is unclear how much assistance is provided for other types of provided for other types of
ONA, FEMA doesONA, FEMA does track and provide publiclytrack and provide publicly available information on some forms of assistance. In the case of the available information on some forms of assistance. In the case of the
COVID-19 pandemic and the FEMA COVID-19 Funeral Assistance, for example, FEMA regularly releases COVID-19 pandemic and the FEMA COVID-19 Funeral Assistance, for example, FEMA regularly releases
information about the amount of Funeral Assistance provided. For example, on November 1, 2021, FEMA issuedinformation about the amount of Funeral Assistance provided. For example, on November 1, 2021, FEMA issued a
state-by-state breakdown of the Funeral Assistance provided t o assist with COVID-19-related funeral costs for deaths
occurring on or after January 20, 2020 (see FEMA, “ FEMA COVID-19 Funeral Assistance State-by-State
Breakdown,” release HQ-21-239, November 1, 2021, https://www.fema.gov/press-release/20211101/fema-covid-19-
funeral-assistance-state-state-breakdown).
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above-listed datasets.) Congress could consider requiring FEMA to provide data fields detailing the financial assistance provided for the specific types of Financial Housing Assistance and ONA, and could request information from FEMA on any potential challenges associated with providing such information. (The types of IHP Financial Housing Assistance and ONA are listed isuch information. (The types of IHP Financial Housing Assistance and ONA are listed in Table
1.)
Ensuring IHP Assistance Can Meet Future Disaster Survivors’
Needs—Including Following Incidents with Economic
Consequences
Some Members of Congress have expressed concern regarding whether current IHP assistance Some Members of Congress have expressed concern regarding whether current IHP assistance
programs can meet the needs of future disaster survivors, including disaster survivors of disasters programs can meet the needs of future disaster survivors, including disaster survivors of disasters
resulting in economic—rather than physical—losses. resulting in economic—rather than physical—losses.
Stafford Act emergency and major disaster declarations tend to contemplate natural disasters that Stafford Act emergency and major disaster declarations tend to contemplate natural disasters that
result in physical damages, such as hurricanes, floods, and wildfires.result in physical damages, such as hurricanes, floods, and wildfires.247242 Emergencies and major Emergencies and major
disasters also commonly have economic consequences that may cause disaster survivors to disasters also commonly have economic consequences that may cause disaster survivors to
experience economic hardship (e.g., people may be unable to work or may lose experience economic hardship (e.g., people may be unable to work or may lose inc omeincome as a result as a result
of a disaster). Although there have been major disaster declarations for incidents that did not of a disaster). Although there have been major disaster declarations for incidents that did not
result in extensive physical damages, these incidents have been result in extensive physical damages, these incidents have been historical yhistorically uncommon (e.g., the uncommon (e.g., the
presidential Stafford Act major disaster declarations for the COVID-19 presidential Stafford Act major disaster declarations for the COVID-19 pandemic248pandemic243 and the 1992 and the 1992
Los AngelesLos Angeles civil unrest).civil unrest).249244 Federal assistance provided for these incidents was intended—in Federal assistance provided for these incidents was intended—in
part—to help address the economic consequences of these disasters. For example, in the case of part—to help address the economic consequences of these disasters. For example, in the case of
the COVID-19 pandemic, the President issued a presidential memorandum that authorized the the COVID-19 pandemic, the President issued a presidential memorandum that authorized the
Lost Wages Assistance (LWA) program under ONA’s statutory authority to Lost Wages Assistance (LWA) program under ONA’s statutory authority to al ow FEMA to
provide grants to states, territories, and the District of Columbia for supplemental lost wages
payments to individuals receiving unemployment insurance—which was a novel use of ONA.250
Additional y, following the 1992 Los Angeles riots, IHP assistance was provided for temporary

247 T he Stafford Act defines “emergency” as “ allow FEMA to state-by-state breakdown of the Funeral Assistance provided to assist with COVID-19-related funeral costs for deaths occurring on or after January 20, 2020 (see FEMA, “FEMA COVID-19 Funeral Assistance State-by-State Breakdown,” release HQ-21-239, November 1, 2021, https://www.fema.gov/press-release/20211101/fema-covid-19-funeral-assistance-state-state-breakdown). FEMA’s webpage on “COVID-19 Funeral Assistance” includes funeral assistance totals by state and territory for eligible funeral assistance related to COVID-19, available at https://www.fema.gov/disaster/coronavirus/economic/funeral-assistance#totals. 242 The Stafford Act defines “emergency” as “any occasion or instance for which, in the determination of the President, any occasion or instance for which, in the determination of the President,
FederalFederal assistance isassistance is needed to supplement State and local efforts and capabilities to save lives and to protect property needed to supplement State and local efforts and capabilities to save lives and to protect property
and publicand public health and safety, or to lessen or avert the threat of a catastrophe in any part of the United States” (42 U.S.C. health and safety, or to lessen or avert the threat of a catastrophe in any part of the United States” (42 U.S.C.
§5122(1)). §5122(1)). T heThe Stafford Act defines “ Stafford Act defines “ major disaster” as “major disaster” as “ any natural catastrophe (including any hurricane, tornado, any natural catastrophe (including any hurricane, tornado,
storm, high water, winddrivenstorm, high water, winddriven water, tidal wave,water, tidal wave, tsunami, earthquake, volcanic eruption, landslide, mudslide, tsunami, earthquake, volcanic eruption, landslide, mudslide,
snowstorm, or drought), or, regardlesssnowstorm, or drought), or, regardless of cause,of cause, any fire, flood, or explosion, in any part of the United States, which in any fire, flood, or explosion, in any part of the United States, which in
the determination of the President causes damagethe determination of the President causes damage of sufficient severity and magnitude to warrant major disaster of sufficient severity and magnitude to warrant major disaster
assistance under this chapter to supplement the efforts and available resources of States, local governments, and assistance under this chapter to supplement the efforts and available resources of States, local governments, and
disaster relief organizations in alleviating the damage, loss, hardship, or suffering causeddisaster relief organizations in alleviating the damage, loss, hardship, or suffering caused thereby” (42 U.S.C. thereby” (42 U.S.C.
§5122(2)). §5122(2)).
248243 For additional examples of public health incidents that received Stafford Act emergency declarations, see CRS For additional examples of public health incidents that received Stafford Act emergency declarations, see CRS
Insight IN11229, Insight IN11229, Stafford Act Assistance for Public Health Incidents, by Erica A. Lee and Bruce, by Erica A. Lee and Bruce R. Lindsay. R. Lindsay.
249244 With the exception of the California Fire during With the exception of the California Fire during a Period of Civil Unrest (DR-942-CA) related to the criminal trial a Period of Civil Unrest (DR-942-CA) related to the criminal trial
verdict in the beating of Rodney King (i.e., the 1992 Los Angeles riots), the major disaster declaration requests under verdict in the beating of Rodney King (i.e., the 1992 Los Angeles riots), the major disaster declaration requests under
the Stafford Act for other incidents of civil unrest werethe Stafford Act for other incidents of civil unrest were denied, includingdenied, including major disaster major disaster decla rationdeclaration requests for civil requests for civil
unrest in Baltimore, MD, related to the death of Freddy Gray in 2015, civil unrest in North Dakota related to the Dakota unrest in Baltimore, MD, related to the death of Freddy Gray in 2015, civil unrest in North Dakota related to the Dakota
AccessAccess Pipeline in 2017, and civil unrest in Minneapolis, MN, related to the death of George Floyd in 2020. See Pipeline in 2017, and civil unrest in Minneapolis, MN, related to the death of George Floyd in 2020. See
FEMA, “California Fire DuringFEMA, “California Fire During a Period of Civil Unrest (DR-942-CA),” https://www.fema.gov/disaster/942. For a Period of Civil Unrest (DR-942-CA),” https://www.fema.gov/disaster/942. For
additional information and considerations related to the use of the Stafford Act to support additional information and considerations related to the use of the Stafford Act to support t hethe federal response to federal response to
incidents of civil unrest, see CRSincidents of civil unrest, see CRS Report R46665, Report R46665, Stafford Act and Selected Federal Recovery Program sPrograms for Civil
Unrest: Historical Perspectives and Policy Observations
, coordinated by Bruce, coordinated by Bruce R. Lindsay.
250 President Donald J. T rump, “Memorandum on Authorizing the Other Needs Assistance Program for Major Disaster
Declarations Related to Coronavirus Disease 2019,” August 8, 2020, https://trumpwhitehouse.archives.gov/
presidential-actions/memorandum-authorizing-needs-assistance-program-major-disaster-declarations-related-
coronavirus-disease-2019/. See also, FEMA, “ Lost Wages Supplemental Payment Assistance Guidelines,”
https://www.fema.gov/disaster/coronavirus/governments/supplemental-payments-lost-wages-guidelines.
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R. Lindsay. Congressional Research Service 45 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations provide grants to states, territories, and the District of Columbia for supplemental lost wages payments to individuals receiving unemployment insurance—which was a novel use of ONA.245 Additionally, following the 1992 Los Angeles riots, IHP assistance was provided for temporary rental and mortgage assistance (this form of IHP assistance is no longer available—see additional rental and mortgage assistance (this form of IHP assistance is no longer available—see additional
information below),information below),251246 among other things. among other things.252247
During the early response to the COVID-19 pandemic, Congress considered the federal During the early response to the COVID-19 pandemic, Congress considered the federal
government’s options for providing rental assistance payments to individuals experiencing government’s options for providing rental assistance payments to individuals experiencing
financial hardship due to the pandemic.financial hardship due to the pandemic.253 Additional y, 248 Additionally, the Surfside Buildingthe Surfside Building Collapse in June Collapse in June
2021, raised congressional questions about the availability2021, raised congressional questions about the availability of federal assistance for disaster of federal assistance for disaster
survivors with mortgages on destroyed or inaccessible homes.survivors with mortgages on destroyed or inaccessible homes.254249 Although Rental Assistance is a Although Rental Assistance is a
form of IHP assistance,form of IHP assistance,255250 it is premised on an individual it is premised on an individual being displaced from their primary being displaced from their primary
residence because it is uninhabitable, inaccessible, unavailable due to forced relocation, or residence because it is uninhabitable, inaccessible, unavailable due to forced relocation, or
nonfunctional due to utilitynonfunctional due to utility outages.outages.256251 FEMA does not have the statutory authority to provide FEMA does not have the statutory authority to provide
temporary rental or mortgage payments when people experience disaster-caused financial temporary rental or mortgage payments when people experience disaster-caused financial
hardship. However, this has not always been the case. Prior to May 2002, the Stafford Act hardship. However, this has not always been the case. Prior to May 2002, the Stafford Act
authorized the President to provide temporary mortgage or rental payments to or on behalf of authorized the President to provide temporary mortgage or rental payments to or on behalf of
individualsindividuals and families meeting certain criteria (see block text below). Section 206 of the and families meeting certain criteria (see block text below). Section 206 of the
Disaster Mitigation Act of 2000 (DMA2K, P.L. 106-390), amended the Stafford Act to remove Disaster Mitigation Act of 2000 (DMA2K, P.L. 106-390), amended the Stafford Act to remove
temporary mortgage and rental payments, and it also added the language predicating assistance on temporary mortgage and rental payments, and it also added the language predicating assistance on
displacement.257 The 2001 version of Stafford Act Section 408(b)—Temporary Mortgage and
Rental Payments read as follows:
The President is authorized to provide assistance on a temporary basis in the form of
mortgage or rental payments to or on behalf of individuals and families who, as a result of
financial hardship caused by a major disaster
, have received written notice of
dispossession or eviction from a residence by reason of a foreclosure of any mortgage or
lien, cancellation of any contract of sale, or termination of any lease, entered into prior to

251 In 1992, the Stafford Act included the provision of temporary rental and mortgage assistance (42 U.S.C. 245 President Donald J. Trump, “Memorandum on Authorizing the Other Needs Assistance Program for Major Disaster Declarations Related to Coronavirus Disease 2019,” August 8, 2020, https://trumpwhitehouse.archives.gov/presidential-actions/memorandum-authorizing-needs-assistance-program-major-disaster-declarations-related-coronavirus-disease-2019/. See also, FEMA, “Lost Wages Supplemental Payment Assistance Guidelines,” https://www.fema.gov/disaster/coronavirus/governments/supplemental-payments-lost-wages-guidelines. 246 In 1992, the Stafford Act included the provision of temporary rental and mortgage assistance (42 U.S.C. §5174(b), §5174(b),
1988 ed.). Section 404(b) of the Disaster Relief Act of 1974 (P.L. 93-288) initially established the provision of 1988 ed.). Section 404(b) of the Disaster Relief Act of 1974 (P.L. 93-288) initially established the provision of
temporary mortgage or rental payments for individuals. Section 206 of the Disaster Mitigation Act of 2000 (DMA2K, temporary mortgage or rental payments for individuals. Section 206 of the Disaster Mitigation Act of 2000 (DMA2K,
P.L. 106-390) amended the Stafford Act to remove temporary mortgage and rental payments. P.L. 106-390) amended the Stafford Act to remove temporary mortgage and rental payments.
252 247 In a In a Los Angeles Times op-ed, then FEMA Regional op-ed, then FEMA Regional Director, William Medigovich, stated that, “Director, William Medigovich, stated that, “ FEMA made an FEMA made an
exceptional effort to qualify the Los Angelesexceptional effort to qualify the Los Angeles riots as a disasterriots as a disaster under the Stafford Act, which doesunder the Stafford Act, which does not include riot in its not include riot in its
definition of ‘disaster.’” William Medigovich, “Federal Aiddefinition of ‘disaster.’” William Medigovich, “Federal Aid for Riot Victims,” for Riot Victims,” Los Angeles Times, January 27, 1993, , January 27, 1993,
https://www.latimes.com/archives/la-xpm-1993-01-27-me-1695-story.html. Notably, FEMA’s Preliminary Damage https://www.latimes.com/archives/la-xpm-1993-01-27-me-1695-story.html. Notably, FEMA’s Preliminary Damage
Assessment Reports for both the Maryland Civil Unrest incident in 2015 and the North Dakota Civil Unrest incident in Assessment Reports for both the Maryland Civil Unrest incident in 2015 and the North Dakota Civil Unrest incident in
2017 stated that the governor’s request for a major disaster declaration was2017 stated that the governor’s request for a major disaster declaration was denied baseddenied based on the determination that on the determination that
supplemental federal assistance under the Stafford Act “is not appropriate for this event” (see the FEMA, “Maryland—supplemental federal assistance under the Stafford Act “is not appropriate for this event” (see the FEMA, “Maryland—
Civil Unrest Denial of Appeal,” Preliminary Damage Assessment Report, July 29, 2015, https://www.fema.gov/sites/Civil Unrest Denial of Appeal,” Preliminary Damage Assessment Report, July 29, 2015, https://www.fema.gov/sites/
default/files/2020-09/PDAReportAppealDenialMD.pdf; and FEMA, “default/files/2020-09/PDAReportAppealDenialMD.pdf; and FEMA, “ North Dakota—Civil Unrest Denial,” North Dakota—Civil Unrest Denial,”
Preliminary Damage Assessment Report, May 18, 2017, https://www.fema.gov/sites/default/files/2020-03/Preliminary Damage Assessment Report, May 18, 2017, https://www.fema.gov/sites/default/files/2020-03/
PDAReportDenialND.pdf). FEMA’s PDA Report for Minnesota’s Civil Unrest incident in 2020 stated supplemental PDAReportDenialND.pdf). FEMA’s PDA Report for Minnesota’s Civil Unrest incident in 2020 stated supplemental
federal assistance “federal assistance “ was not warranted or appropriate” (FEMA, “Minnesota—Civil Unrest Denial of Appeal, was not warranted or appropriate” (FEMA, “Minnesota—Civil Unrest Denial of Appeal,
Preliminary Damage Assessment ReportPreliminary Damage Assessment Report , August, August 18, 2020, https://www.fema.gov/sites/default/files/documents/18, 2020, https://www.fema.gov/sites/default/files/documents/
PDAReport_AppealDenial-MN.pdf). PDAReport_AppealDenial-MN.pdf).
253248 FEMA, “ FEMA, “ Coronavirus (COVID-19) Response,” https://www.fema.gov/disaster/coronavirus. Coronavirus (COVID-19) Response,” https://www.fema.gov/disaster/coronavirus.
254249 FEMA, “Florida Surfside FEMA, “Florida Surfside Building Collapse Building Collapse (3560-EM-FL),” https://www.fema.gov/disaster/3560. (3560-EM-FL),” https://www.fema.gov/disaster/3560.
255250 42 U.S.C. 42 U.S.C. §5174(c)(1)(A). §5174(c)(1)(A).
256251 Stafford Act Section 408(b)(1) specifies that housing assistance is intended to assist “ Stafford Act Section 408(b)(1) specifies that housing assistance is intended to assist “individuals individuals and households and households
who are who are displaced from their predisaster prim aryprimary residences or whose or whose predisaster prim ary primary residences are rendered
uninhabitable
, or with respect to individuals with disabilities,, or with respect to individuals with disabilities, rendered inaccessible rendered inaccessible or uninhabitable, as a resultor uninhabitable, as a result of of
damagedamage caused caused by a major disaster [emphasis added]”by a major disaster [emphasis added]” (42 U.S.C.(42 U.S.C. §5174(b)(1)). See also FEMA, §5174(b)(1)). See also FEMA, IAPPG, pp. 80-81. , pp. 80-81.
257 T he Disaster Mitigation Act of 2000 (DMA2K, P.L. 106-390), was enacted on October 30, 2000. DMA2K’s
amendments went into effect 18 months after the date of the enactment , which was April 30, 2002.
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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

such disaster. Such assistance s hallCongressional Research Service 46 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations displacement.252 The 2001 version of Stafford Act Section 408(b)—Temporary Mortgage and Rental Payments read as follows: The President is authorized to provide assistance on a temporary basis in the form of mortgage or rental payments to or on behalf of individuals and families who, as a result of financial hardship caused by a major disaster, have received written notice of dispossession or eviction from a residence by reason of a foreclosure of any mortgage or lien, cancellation of any contract of sale, or termination of any lease, entered into prior to such disaster. Such assistance shall be provided for the duration of the period of financial be provided for the duration of the period of financial
hardship but not to exceed 18 months [emphasis added].hardship but not to exceed 18 months [emphasis added].258253
DMA2K was DMA2K was general ygenerally intended to control the federal cost of disaster assistance; however, the intended to control the federal cost of disaster assistance; however, the
specific justification for removing the provision of mortgage and rental payments from the specific justification for removing the provision of mortgage and rental payments from the
amended version of the Stafford Act is not specified in the committee reports on the amended version of the Stafford Act is not specified in the committee reports on the bil .259bill.254
During a Senate hearing in 2003, the DHS OIG cited the reason Congress eliminated the During a Senate hearing in 2003, the DHS OIG cited the reason Congress eliminated the
temporary mortgage and rental payments program as being the fact that the program was seldom temporary mortgage and rental payments program as being the fact that the program was seldom
used, and also cited FEMA’s program implementation used, and also cited FEMA’s program implementation chal enges.260 Despite chal engeschallenges.255 Despite challenges with the with the
program, the DHS OIG stated that the “effects of the 9/11 terrorist attack .program, the DHS OIG stated that the “effects of the 9/11 terrorist attack . .. demonstrated genuine . demonstrated genuine
need for programs such as this. Therefore, we have recommended ..need for programs such as this. Therefore, we have recommended ... that Congress consider
reinstating the program under the Stafford Act.”261 Congress may evaluate the extent to which the
Stafford Act can be used to support individuals and families recovering from the economic, rather
than physical, effects of emergencies and major disasters. Congress could also consider the
sufficiency of existing IHP programs and whether there is a need to expand the forms of IHP
assistance to specifical y address the needs of disasters survivors experiencing the detrimental
economic consequences of disasters.262
Closing Considerations
FEMA may provide a variety of programs to meet the housing and other needs of disaster
survivors through the IHP. Congressional actions263 have helped codify these programs,264

258 42 U.S.C. that Congress consider reinstating the program under the Stafford Act.”256 As an additional example, in recent Congresses, concerns have related to the inability of the IHP to compensate disaster survivors for their loss of property value resulting from disasters such as wildfires, building collapses, and chemical spills, which may not damage or destroy the property (and may not result in Stafford Act declarations that provide IA).257 252 The Disaster Mitigation Act of 2000 (DMA2K, P.L. 106-390), was enacted on October 30, 2000. DMA2K’s amendments went into effect 18 months after the date of the enactment, which was April 30, 2002. 253 42 U.S.C. §5174(b), 2001, https://www.govinfo.gov/content/pkg/USCODE-2001-title42/pdf/USCODE-2001-§5174(b), 2001, https://www.govinfo.gov/content/pkg/USCODE-2001-title42/pdf/USCODE-2001-
title42-chap68-subchapIV-sec5174.pdf. title42-chap68-subchapIV-sec5174.pdf.
259 254 U.S. U.S. Congress, HouseCongress, House Committee on Committee on T ransportationTransportation and Infrastructure, and Infrastructure, Disaster Mitigation and Cost Reduction Act
of 1999
, 106th Cong., 1st sess., March 3, 1999, H.Rept. 106-40, pp. 1, 12, and 17, https://www.congress.gov/106/crpt/, 106th Cong., 1st sess., March 3, 1999, H.Rept. 106-40, pp. 1, 12, and 17, https://www.congress.gov/106/crpt/
hrpt40/CRPThrpt40/CRPT -106hrpt40.pdf. -106hrpt40.pdf.
260255 During the 108th Congress, then-DHS Deputy Inspector General, Richard “Rick” L. Skinner, included During the 108th Congress, then-DHS Deputy Inspector General, Richard “Rick” L. Skinner, included in his in his
statement, in the “Individual Assistance Review”statement, in the “Individual Assistance Review” section, with regardsection, with regard to “Eligibility Issuesto “Eligibility Issues in the Mortgage and Rental in the Mortgage and Rental
Assistance Program,” that “FEMA historically has not had to implement the Mortgage and Rental Assistance (MRA) Assistance Program,” that “FEMA historically has not had to implement the Mortgage and Rental Assistance (MRA)
program on a large scale becauseprogram on a large scale because previous disastersprevious disasters did did not coincide with nor result in widespreadnot coincide with nor result in widespread unemployment and unemployment and
national economic losses. From the inception of MRA until September 11, 2001, only $18.1 million had been awarded national economic losses. From the inception of MRA until September 11, 2001, only $18.1 million had been awarded
under the program for 68 declaredunder the program for 68 declared disasters, compared to approximately $76 million as a result of the New York disasters, compared to approximately $76 million as a result of the New York
disaster alone. Becausedisaster alone. Because it wasit was seldom used,seldom used, Congress Congress eliminated the program when it enacted the Disaster Mitigation eliminated the program when it enacted the Disaster Mitigation
Act of 2000 (DMA 2000) making the program unavailable after May 1, 2002.” U.S. Congress,Act of 2000 (DMA 2000) making the program unavailable after May 1, 2002.” U.S. Congress, Senate Committee on Senate Committee on
Environment and Public Works, Subcommittee on Clean Air, Climate Change, and Environment and Public Works, Subcommittee on Clean Air, Climate Change, and N uclearNuclear Safety, Safety, Review of the
General Accounting Office Report on FEMA’s Activities After the Terrorist Attacks on Septem berSeptember 11, 2001
, 108th , 108th
Cong., 1st sess.,Cong., 1st sess., September 24, 2003, S.Hrg. 108-364, p. 253, https://www.govinfo.gov/content/pkg/CHRG-September 24, 2003, S.Hrg. 108-364, p. 253, https://www.govinfo.gov/content/pkg/CHRG-
108shrg92386/pdf/CHRG-108shrg92386.pdf (hereinafter U.S. Congress, 108shrg92386/pdf/CHRG-108shrg92386.pdf (hereinafter U.S. Congress, Review of the GAO Report on FEMA’s
Activities After Septem ber After September 11, 2001
). ).
261256 U.S. U.S. Congress, Congress, Review of the GAO Report on FEMA’s Activities After September 11, 2001, pp. 253-254 (Statement , pp. 253-254 (Statement
of Rick Skinner, DHSof Rick Skinner, DHS Deputy IG).
262 Additional housing-related considerations can be found in CRS Report R46855, Housing Issues in the 117th
Congress
, coordinated by Katie Jones, as well as considerations included in previous versions of the Housing Issues
report.
263 Congressional actions include passing the Post -Katrina Emergency Management Reform Act of 2006 (PKEMRA,
P.L. 109-295), the Sandy Recovery Improvement Act of 2013 (SRIA, P.L. 113-2), and DRRA (P.L. 115-254).
264 For example, following Hurricane Sandy, SRIA formalized FEMA’s Multifamily Lease and Repair program (§1103
of SRIA, P.L. 113-2, as it amends §408(c)(1)(B) of the Stafford Act, 42 U.S.C. §5174(c)(1)(B)), and FEMA developed
its Direct Lease program, which “allows FEMA to lease existing residential properties for eligible applicants to use as
temporary housing” (email correspondence from FEMA Congressional Affairs staff, March 9, 2019).
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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

increased potential funding for disaster survivors,265 Deputy IG). 257 Congress has provided assistance to compensate losses associated with selected incidents. For example, through the Hermit’s Peak/Calf Canyon Fire Assistance Act (Div. G of P.L. 117-180), allowable damages related to loss of property included “a decrease in the value of real property” (see Section 104(d)(4)(A)(ii)). Notably, the U.S. Forest Service assumed responsibility of the Hermit’s Peak/Calf Canyon Fire and it was determined that the United States should compensate the victims (see Section 102(a), which details the congressional findings). There was no Stafford Act declaration for the East Palestine, OH, train derailment that occurred in February 2023 when a Norfolk Southern freight train derailed, and twenty of the affected cars contained hazardous materials (U.S. Environmental Protection (continued...) Congressional Research Service 47 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations Congress may evaluate the extent to which the Stafford Act can be used to support individuals and families recovering from the economic, rather than physical, effects of emergencies and major disasters. Congress could also consider the sufficiency of existing IHP programs and whether there is a need to expand the forms of IHP assistance to specifically address the needs of disasters survivors experiencing the detrimental economic consequences of disasters.258 Closing Considerations FEMA may provide a variety of programs to meet the housing and other needs of disaster survivors through the IHP. Congressional actions259 have helped codify these programs,260 increased potential funding for disaster survivors,261 and expanded the ability for state, territory, and expanded the ability for state, territory,
and Indian tribal governments to participate in and customize the delivery of IHP housing and Indian tribal governments to participate in and customize the delivery of IHP housing
assistance programs in their communities.assistance programs in their communities.266262 However, insurance remains the best option for However, insurance remains the best option for
returning real and personal property to their pre-disaster condition. Moreover, individuals and returning real and personal property to their pre-disaster condition. Moreover, individuals and
households seeking to fully-recover following a disaster may find IHP assistance alone to be households seeking to fully-recover following a disaster may find IHP assistance alone to be
insufficient. Congress may consider whether the IHP can adequately meet the needs of future insufficient. Congress may consider whether the IHP can adequately meet the needs of future
disaster survivors—including those suffering from the economic effects of a disaster, and may disaster survivors—including those suffering from the economic effects of a disaster, and may
wish to evaluate options to best meet the needs of future disaster survivors. wish to evaluate options to best meet the needs of future disaster survivors.

265 For example, DRRA Section 1212 (P.L. 115-254) both separated the cap on the maximum amount of financial
assistance eligible individuals and households may receive for housing assistance and ONA, and also exempted some
forms of assistance that previously counted towards the cap.
266 DRRA Section 1211 (P.L. 115-254) allows state, territory, and Indian tribal governments to administer Direct
T emporary Housing Assistance and Permanent Housing Construction , in addition to ONA.
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49

link to page 63 link to page 64 link to page 64 link to page 26 link to page 26 Agency, “East Palestine, Ohio Train Derailment,” last accessed May 2, 2023, https://www.epa.gov/east-palestine-oh-train-derailment). Concerns have included the potential loss in property value resulting from the train derailment (see, for example, Anna Bahney and Chris Isidore, “Norfolk Southern Balks at Compensating Homeowners in East Palestine,” CNN, March 14, 2023, https://www.cnn.com/2023/03/12/homes/norfolk-southern-east-palestine-home-values/index.html). 258 Additional housing-related considerations can be found in CRS Report R46855, Housing Issues in the 117th Congress, coordinated by Katie Jones, as well as considerations included in previous versions of the Housing Issues report. 259 Congressional actions include passing the Post-Katrina Emergency Management Reform Act of 2006 (PKEMRA, P.L. 109-295), the Sandy Recovery Improvement Act of 2013 (SRIA, P.L. 113-2), and DRRA (P.L. 115-254). 260 For example, following Hurricane Sandy, SRIA formalized FEMA’s Multifamily Lease and Repair program (§1103 of SRIA, P.L. 113-2, as it amends §408(c)(1)(B) of the Stafford Act, 42 U.S.C. §5174(c)(1)(B)), and FEMA developed its Direct Lease program, which “allows FEMA to lease existing residential properties for eligible applicants to use as temporary housing” (email correspondence from FEMA Congressional Affairs staff, March 9, 2019). 261 For example, DRRA Section 1212 (P.L. 115-254) both separated the cap on the maximum amount of financial assistance eligible individuals and households may receive for housing assistance and ONA, and also exempted some forms of assistance that previously counted towards the cap. 262 DRRA Section 1211 (P.L. 115-254) allows state, territory, and Indian tribal governments to administer Direct Temporary Housing Assistance and Permanent Housing Construction, in addition to ONA. Congressional Research Service 48 link to page 61 link to page 62 link to page 25 link to page 25 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

Appendix A. Overview of the Factors Considered
when Evaluating a Governor or Chief Executive’s
Request for IA

FEMA uses two separate sets of factors to FEMA uses two separate sets of factors to
Declaration Request Timing
determine whether to recommend that Individual determine whether to recommend that Individual
Requesting states, territories, Requesting states, territories, and tribes must and tribes must
Assistance (IA) be authorized: one applies to Assistance (IA) be authorized: one applies to
request an emergency request an emergency declaration “within 5 days declaration “within 5 days
states/territories pursuant to a governor’s request, states/territories pursuant to a governor’s request,
after the need for [emergency] assistance ... after the need for [emergency] assistance ...
and one applies to Indian tribal governments and one applies to Indian tribal governments
becomes becomes apparent, but no longer than 30 days apparent, but no longer than 30 days
after the occurrence of the incident.” Major after the occurrence of the incident.” Major
pursuant to a chief executive’s request. These pursuant to a chief executive’s request. These
disaster declaration requests must be submitted disaster declaration requests must be submitted
factors are described in detail below. factors are described in detail below. Additional yAdditionally, ,
“within 30 days of the occurrence of the “within 30 days of the occurrence of the
a list of the factors considered for governors’ a list of the factors considered for governors’
incident.” Extensions of the 30-day period may incident.” Extensions of the 30-day period may
requests, including FEMA’s considerations and requests, including FEMA’s considerations and
be requested in writing by the affected be requested in writing by the affected
sources for the information/data considered, is sources for the information/data considered, is
state/territory state/territory or tribe during the 30-day period. or tribe during the 30-day period.
included in included in Table A-1. A list of the factors A list of the factors
(44 C.F.R. (44 C.F.R. §206.35(a); 44 C.F.R. §206.36(a)). §206.35(a); 44 C.F.R. §206.36(a)).
considered for chief executives’ requests, including considered for chief executives’ requests, including
FEMA’s considerations and sources for the information/data considered, is included FEMA’s considerations and sources for the information/data considered, is included inin Table A-
2
.
Additional 2. Additional information about the declaration process is included in the information about the declaration process is included in the “Approving Requests
for Individual Assistance” sectionsection of the report. of the report.
Factors Considered When Evaluating a Governor’s Request for IA
FEMA issued a final rule revising the factors considered when evaluating a governor’s request for FEMA issued a final rule revising the factors considered when evaluating a governor’s request for
IA on March 21, 2019, as required by Section 1109 of the Sandy Recovery Improvement Act of IA on March 21, 2019, as required by Section 1109 of the Sandy Recovery Improvement Act of
2013 (SRIA, Division B of P.L. 113-2).2013 (SRIA, Division B of P.L. 113-2).267263 The factors were revised to establish what FEMA The factors were revised to establish what FEMA
characterized as “more objective” criteria for evaluating the need for assistance, clarify eligibility characterized as “more objective” criteria for evaluating the need for assistance, clarify eligibility
requirements, and expedite a presidential declaration determination. These factors became requirements, and expedite a presidential declaration determination. These factors became
effective June 1, 2019. FEMA also produced guidance for use by states and territories when effective June 1, 2019. FEMA also produced guidance for use by states and territories when
drafting requests for major disaster declarations authorizing IA.drafting requests for major disaster declarations authorizing IA.268264
The factors considered when evaluating a governor’s request for a major disaster declaration The factors considered when evaluating a governor’s request for a major disaster declaration
authorizing IA are intended to help FEMA assess the “severity, magnitude, and impact of a authorizing IA are intended to help FEMA assess the “severity, magnitude, and impact of a
disaster,” as disaster,” as wel well as the capabilities of the affected jurisdictions.as the capabilities of the affected jurisdictions.269 Additional y265 Additionally, according to , according to
FEMA, the same IA factors would be considered in the event a state or territory requests IHP FEMA, the same IA factors would be considered in the event a state or territory requests IHP
assistance pursuant to an emergency declaration, and the assistance pursuant to an emergency declaration, and the Individual Assistance Declarations
Factors Guidance
(hereinafter referred to as the (hereinafter referred to as the IA Declarations Factors Guidance) would be ) would be
useful in evaluating the need for IHP assistance.useful in evaluating the need for IHP assistance.270266 The factors are also used to identify the The factors are also used to identify the

267 263 DHS/FEMA, DHS/FEMA,Factors Considered When Evaluating a RequestFactors Considered When Evaluating a Request for IA”; 44 C.F.R.for IA”; 44 C.F.R. §206.48(b). §206.48(b).
268264 FEMA, FEMA, IA Declarations Factors Guidance. .
269265 DHS/FEMA, DHS/FEMA, “Factors Considered When Evaluating a Request“Factors Considered When Evaluating a Request for IA,” 84for IA,” 84 Federal Register 10633; and 44 C.F.R. 10633; and 44 C.F.R.
§206.48(b). §206.48(b).
270266 According to FEMA, “[w]hile FEMA’s regulations in 44 CFR According to FEMA, “[w]hile FEMA’s regulations in 44 CFR 206.48 only expressly apply to requests for major 206.48 only expressly apply to requests for major
disasters, in the event that a state did request IHP under an emergency declaration, the factors outlined in that provision disasters, in the event that a state did request IHP under an emergency declaration, the factors outlined in that provision
wouldwould still be relevant to [assessing] whether the event was beyond state and local capabilities as it related to [the] IHP. still be relevant to [assessing] whether the event was beyond state and local capabilities as it related to [the] IHP.
Likewise,Likewise, the the Individual Assistance Declarations Factors Guidance (June 2019) would (June 2019) would be relevant, in particular the be relevant, in particular the
discussiondiscussion of the Principal Factors for evaluating the need for IHP [italics added].”of the Principal Factors for evaluating the need for IHP [italics added].” FEMA also noted that IHP FEMA also noted that IHP
authorization pursuant to an emergency declaration is “extremely rare” and stated that the agency would encourage a authorization pursuant to an emergency declaration is “extremely rare” and stated that the agency would encourage a
(continued...) Congressional Research Service Congressional Research Service

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link to page 29 link to page 29 link to page 29 link to page 29 link to page 29 link to page 29 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

appropriate types of IA to authorize (e.g., significant casualties could indicate the need for ONA appropriate types of IA to authorize (e.g., significant casualties could indicate the need for ONA
for Funeral Assistance and Medical and Dental Assistance, and Crisis Counseling)for Funeral Assistance and Medical and Dental Assistance, and Crisis Counseling) (Figure 3 lists lists
the factors considered when evaluating the need for each type of IA). the factors considered when evaluating the need for each type of IA).
There are six IA factors that are considered pursuant to a governor’s request for a major disaster There are six IA factors that are considered pursuant to a governor’s request for a major disaster
declaration authorizing IA.declaration authorizing IA.271267 Per the regulation, Per the regulation,
State fiscal capacity (44 CFR State fiscal capacity (44 CFR 206.48(b)(1)(i))206.48(b)(1)(i)) and uninsured home and personal property and uninsured home and personal property
losseslosses (44 CFR 206.48(b)(2)) are(44 CFR 206.48(b)(2)) are the principal factors that FEMA the principal factors that FEMA will considerwill consider when when
evaluatingevaluating the need for supplementalthe need for supplemental Federal assistanceFederal assistance under the Individualsunder the Individuals and and
Households Program but FEMA will always consider all relevant information submitted Households Program but FEMA will always consider all relevant information submitted
as part of a declaration request. If the need for supplemental Federal assistance under the as part of a declaration request. If the need for supplemental Federal assistance under the
Individuals andIndividuals and Households Program is not Households Program is not clear from theclear from the evaluation of the evaluation of the principal principal
factors, FEMA will turn to the other factors to determine the level of need.factors, FEMA will turn to the other factors to determine the level of need.272268
Factor 1: State Fiscal Capacity and Resource Availability
When FEMA evaluates the State Fiscal Capacity and Resource Availability When FEMA evaluates the State Fiscal Capacity and Resource Availability (44 C.F.R. (44 C.F.R.
§206.48(b)(1)) factor, FEMA considers the availability of government and private-sector §206.48(b)(1)) factor, FEMA considers the availability of government and private-sector
resources,resources,273269 and the circumstances that contributed to the state having insufficient resources, and the circumstances that contributed to the state having insufficient resources,
potential ypotentially necessitating supplemental federal assistance. necessitating supplemental federal assistance.274270 The following factors are evaluated: The following factors are evaluated:
1. 1. Fiscal Capacity (44 C.F.R. (44 C.F.R.
Defining “TTR” and “GDP”
§206.48(b)(1)(i)—a principal factor for the §206.48(b)(1)(i)—a principal factor for the
Total Taxable Resources (TTR) represents Total Taxable Resources (TTR) represents the the
IHP): IHP):275271 FEMA evaluates the state’s capacity FEMA evaluates the state’s capacity “unduplicated sum of the income“unduplicated sum of the income flows flows
to manage disaster response and recovery by to manage disaster response and recovery by
produced within a State and the income flows, produced within a State and the income flows,
considering considering:
received received by its residents,by its residents, which a State could which a State could
potential ypotentially tax.” tax.”
a. a. State Total Taxable Resources (TTR): :
FEMA first considers the state’s TTR, (FEMA, (FEMA, IA Declarations Factors Guidance,, p. 7.)
FEMA first considers the state’s TTR,
p. 7.) which is an annual fiscal capacity which is an annual fiscal capacity

estimate calculated by the U.S. estimate calculated by the U.S.
State gross domestic State gross domestic product (GDP) measures product (GDP) measures
the “sum of the distributions by industry and
Department of Treasury (TTR data is
Department of the Treasury (TTR data is the “sum of the distributions by industry and state of the components of gross domestic state of the components of gross domestic
available available for the 50 states and the for the 50 states and the
income which is the sum of the costs incurred income which is the sum of the costs incurred
District of Columbia). “Increases or District of Columbia). “Increases or
and incomes and incomes earned in the production of earned in the production of
decreases in TTR could indicate a decreases in TTR could indicate a
GDP.” GDP.”
strengthening or declining State strengthening or declining State
(FEMA, (FEMA, IA Declarations Factors Guidance,, p. 8.) p. 8.)
economy.” economy.”276

272 state that is considering requesting an emergency declaration state that is considering requesting an emergency declaration authorizin gauthorizing IA—IHP to instead consider requesting IA—IHP to instead consider requesting a a
major disaster declaration, “unless the event was a type that did not meet the major disaster definition,” because major disaster declaration, “unless the event was a type that did not meet the major disaster definition,” because
“[e]vents that have a significant enough impact on individuals“[e]vents that have a significant enough impact on individuals and householdsand households to warrant IHP are likely to have the to warrant IHP are likely to have the
need for other types of Individual Assistance.... ” (email correspondence from FEMA Congressionalneed for other types of Individual Assistance.... ” (email correspondence from FEMA Congressional Affairs staff, Affairs staff,
November 27, 2019). November 27, 2019).
271267 DHS/FEMA, DHS/FEMA, “Factors Considered When Evaluating a Request“Factors Considered When Evaluating a Request for IA,” 84for IA,” 84 Federal Register 10663; and 44 C.F.R. 10663; and 44 C.F.R.
§206.48(b). §206.48(b).
272268 44 C.F.R. §206.48(b). 44 C.F.R. §206.48(b).
273269 FEMA considers the availability of local, state/territory/tribal government, nongovernmental organizations, and FEMA considers the availability of local, state/territory/tribal government, nongovernmental organizations, and
private sector resources. private sector resources.
274270 44 C.F.R. §206.48(b)(1). 44 C.F.R. §206.48(b)(1).
275271 Additional discussion Additional discussion of the principal factors for the IHP can be found in the of the principal factors for the IHP can be found in the Evaluating the Need for IHP
Assistance: Governor’s Request for a Major Disaster”
section. section.
276 272 44 C.F.R. §206.48(b)(1)(i)(A). FEMA, 44 C.F.R. §206.48(b)(1)(i)(A). FEMA, IA Declarations Factors Guidance, p. 7. , p. 7. T otalTotal taxable resources ( taxable resources (T T R) isTTR) is (continued...)
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b. b. State Gross Domestic Product (GDP): FEMA: FEMA can also consider the state’s can also consider the state’s
GDP (which is available GDP (which is available when considering requests by the territories), and when considering requests by the territories), and
may do so when TTR data is unavailable or inaccurate/misleading because may do so when TTR data is unavailable or inaccurate/misleading because
there is a two-year lag.there is a two-year lag.277
273 c. c. Per Capita Personal Income by Local Area: FEMA can use per capita : FEMA can use per capita
personal income, calculated by the BEA, to assess the need for supplemental personal income, calculated by the BEA, to assess the need for supplemental
assistance in each local area. For example, areas with a lower per capita assistance in each local area. For example, areas with a lower per capita
personal income may have a personal income may have a smal ersmaller tax base and fewer available resources, tax base and fewer available resources,
which could indicate the need for supplemental federal assistance.which could indicate the need for supplemental federal assistance.278
274 FEMA’s guidance explains that “[p]er capita personal income by local area FEMA’s guidance explains that “[p]er capita personal income by local area
when considered when considered holistical yholistically with TTR (and when appropriate GDP by State) with TTR (and when appropriate GDP by State)
wil will help to identify areas of concentrated need at the micro local area and help to identify areas of concentrated need at the micro local area and
individualindividual level in addition to the macro State level.”level in addition to the macro State level.”279275
d. d. Other Factors: FEMA may also consider other information provided by the : FEMA may also consider other information provided by the
state related to its fiscal capacity, such as an incident that affects the state’s state related to its fiscal capacity, such as an incident that affects the state’s
abilityability to collect funds (e.g., a disaster that reduces tourism and affects the to collect funds (e.g., a disaster that reduces tourism and affects the
tax base).tax base).280
276 2. 2. Resource Availability (44 C.F.R. §206.48(b)(1)( (44 C.F.R. §206.48(b)(1)(i ii)): FEMA evaluates whether )): FEMA evaluates whether
the disaster-caused needs can be met using non-Stafford Act sources by the disaster-caused needs can be met using non-Stafford Act sources by
evaluating:281
evaluating277 a. a. State, Tribal, and Local Government; Non-Governmental Organizations
(NGO); and Private Sector Activity: FEMA considers the resources and : FEMA considers the resources and
services that have and services that have and wil will be provided by local, state/territory, and Indian be provided by local, state/territory, and Indian

tribal governments, and nongovernmental and private sector organizations. calculated annually by the U.S. Department of the calculated annually by the U.S. Department of the T reasuryTreasury (Treasury) (ADAMHA [Alcohol, Drug Abuse, (Treasury) (ADAMHA [Alcohol, Drug Abuse, and Mental and Mental
Health Administration] Health Administration] Reorganizat ionReorganization Act, P.L. 102-321). An increase in Act, P.L. 102-321). An increase in T T RTTR may indicate a strengthening state may indicate a strengthening state
economy and a decrease may indicate a decliningeconomy and a decrease may indicate a declining economy; or a lower economy; or a lower T T RTTR may indicate a state may indicate a state e conomyeconomy that is less that is less
resilient to the financial burdensresilient to the financial burdens associated with disasters and a higher associated with disasters and a higher T T RTTR may indicate higher resilience (FEMA, may indicate higher resilience (FEMA, IA
Declarations Factors Guidance
, pp. 7-8). , pp. 7-8). T T RTTR data organized by state is available from the data organized by state is available from the T reasury (T reasury, “ Total
T axable Resources, Treasury (Treasury, “Total Taxable Resources, Estimates,” https://home.treasury.gov/policy-issues/economic-policy/total-taxable-resources). For Estimates,” https://home.treasury.gov/policy-issues/economic-policy/total-taxable-resources). For
an overview of an overview of T T RTTR, including how, including how it is estimated and the limitations of using it is estimated and the limitations of using T T RTTR as a measurement of fiscal as a measurement of fiscal
capacity, see capacity, see T reasuryTreasury, Office of Economic Policy, , Office of Economic Policy, Treasury Methodology for Estim atingEstimating Total Taxable Resources
(TTR)
, December 2002, https://www.treasury.gov/resource-center/economic-policy/Documents/nmpubsum.pdf. , December 2002, https://www.treasury.gov/resource-center/economic-policy/Documents/nmpubsum.pdf.
277273 FEMA, FEMA, IA Declarations Factors Guidance, p. 8. FEMA’s, p. 8. FEMA’s guidance guidance notes, with regardnotes, with regard to the two-year to the two-year T TRTTR data lag, data lag,
“It is possible“It is possible that a State’s that a State’s T T RTTR data could be strong or trending upwards data could be strong or trending upwards when in fact recent events may have caused when in fact recent events may have caused
a significant drop in the State fiscal capacity that is not yet reflected. a significant drop in the State fiscal capacity that is not yet reflected. T hisThis significant drop could be significant drop could be caused caused by events by events
such assuch as a previous disaster or a financial downturn.” 44 C.F.R.a previous disaster or a financial downturn.” 44 C.F.R. §206.48(b)(1)(i)(B). FEMA, §206.48(b)(1)(i)(B). FEMA, IA Declarations Factors
Guidance
, p. 8. , p. 8. T T RTTR is provided for the 50 states and the District of Columbia. is provided for the 50 states and the District of Columbia. State grossState gross domestic product (GDP) domestic product (GDP)
data is calculated by the Bureaudata is calculated by the Bureau of Economic Analysis (BEA) for the states and territories, with the exception of Puerto of Economic Analysis (BEA) for the states and territories, with the exception of Puerto
Rico, the data for which isRico, the data for which is published published by the U.S.by the U.S. Census Bureau (FEMA, Census Bureau (FEMA, IA Declarations Factors Guidance, p. 8; see , p. 8; see
also BEA, “Regional Economic Accounts,” https://www.bea.gov/data/economic-accounts/regional (hereinafter BEA, also BEA, “Regional Economic Accounts,” https://www.bea.gov/data/economic-accounts/regional (hereinafter BEA,
“Regional Economic Accounts”)). For an overview of State GDP,“Regional Economic Accounts”)). For an overview of State GDP, including including how it is estimated, see U.S.how it is estimated, see U.S. Department Department
of Commerce, BEA, of Commerce, BEA, Gross Dom estic Domestic Product by State Estim ationEstimation Methodology, 2017, https://www.bea.gov/sites/, 2017, https://www.bea.gov/sites/
default/files/methodologies/0417_GDP_by_State_Methodology.pdf. default/files/methodologies/0417_GDP_by_State_Methodology.pdf.
278274 44 C.F.R. §206.48(b)(1)(i)(C). Local area per capita income is the “personal income of the residents of a given area 44 C.F.R. §206.48(b)(1)(i)(C). Local area per capita income is the “personal income of the residents of a given area
divideddivided by the resident population of the area.” It may indicate a locality has a smaller tax base and, therefore, fewer by the resident population of the area.” It may indicate a locality has a smaller tax base and, therefore, fewer
resources to help local resources to help local disast erdisaster survivors (FEMA, survivors (FEMA, IA Declarations Factors Guidance, p. 8). Local area per capita , p. 8). Local area per capita
income data isincome data is collected from the BEA (BEA, “Regional Economic Accounts”). collected from the BEA (BEA, “Regional Economic Accounts”).
279275 FEMA, FEMA, IA Declarations Factors Guidance, p. 8. , p. 8.
280276 44 C.F.R. §206.48(b)(1)(i)(D); FEMA, 44 C.F.R. §206.48(b)(1)(i)(D); FEMA, IA Declarations Factors Guidance, p. 8. , p. 8.
281277 44 C.F.R. §206.48(b)(1)(ii); FEMA, 44 C.F.R. §206.48(b)(1)(ii); FEMA, IA Declarations Factors Guidance, p. 8. , p. 8.
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tribal governments, and nongovernmental and private sector organizations.
For example, related to considering the need for housing assistance, states For example, related to considering the need for housing assistance, states
can provide information about affordable housing resources within a can provide information about affordable housing resources within a
reasonable commuting distance of the affected area.reasonable commuting distance of the affected area.282
278 b. b. Cumulative Effect of Recent Disasters: FEMA considers the state’s recent : FEMA considers the state’s recent
disaster history, including both gubernatorial (i.e., state-level) and disaster history, including both gubernatorial (i.e., state-level) and
presidential (i.e., Stafford Act) disaster declarations, occurring in the presidential (i.e., Stafford Act) disaster declarations, occurring in the
previous 24-month period, which could affect the availability of recovery previous 24-month period, which could affect the availability of recovery
resources. FEMA is particularly interested in disasters occurring in the resources. FEMA is particularly interested in disasters occurring in the
current budget/fiscal cycle.current budget/fiscal cycle.283279
Factor 2: Uninsured Home and Personal Property Losses
When FEMA evaluates the Uninsured Home and Personal Property Losses (44 C.F.R. When FEMA evaluates the Uninsured Home and Personal Property Losses (44 C.F.R.
§206.48(b)(2)—a principal factor for the IHP) factor, FEMA considers the results of the FEMA-§206.48(b)(2)—a principal factor for the IHP) factor, FEMA considers the results of the FEMA-
State Preliminary Damage Assessment (PDA) process to examine the extent of damage and State Preliminary Damage Assessment (PDA) process to examine the extent of damage and
estimated cost of IHP assistance.estimated cost of IHP assistance.284280 The state may provide the following PDA data for FEMA’s The state may provide the following PDA data for FEMA’s
evaluation:evaluation:
1. 1. Cause of Damage: the “peril: the “peril that caused the disaster damage” (e.g., a hurricane), that caused the disaster damage” (e.g., a hurricane),
and whether the disaster survivors have insurance coverage for that peril; and whether the disaster survivors have insurance coverage for that peril;285281
2. 2. Impacted Jurisdictions and Concentration of Damage: the concentration of : the concentration of
damages, including whether damages are isolated to one area or are widespread, damages, including whether damages are isolated to one area or are widespread,
which could indicate the counties that need IA or an increased need for which could indicate the counties that need IA or an increased need for
supplemental federal assistance because a supplemental federal assistance because a smal small area has significant damage;area has significant damage;286
282 3. 3. Impacted Homes and Degree of Damage: the number of homes damaged and : the number of homes damaged and
degree to which they are damaged (i.e., whether habitability is affected), which degree to which they are damaged (i.e., whether habitability is affected), which
may indicate the need for different types of IA and the extent to which IA may be may indicate the need for different types of IA and the extent to which IA may be
needed;needed;287
283 4. 4. Estimated Cost of Assistance: the estimated cost of assistance based on the PDA : the estimated cost of assistance based on the PDA
data288data284 and historical data related to FEMA assistance, which helps determine the and historical data related to FEMA assistance, which helps determine the

282 278 44 C.F.R. §206.48(b)(1)(ii)(A); FEMA, 44 C.F.R. §206.48(b)(1)(ii)(A); FEMA, IA Declarations Factors Guidance, p. 9. , p. 9. T heThe FEMA FEMA Preliminary Damage
Assessm entAssessment Guide
provides provides informat ioninformation regarding assessing regarding assessing available available state/territory/tribal and local government state/territory/tribal and local government
resources, as wellresources, as well as as voluntary organization resources on page 34. voluntary organization resources on page 34.
283279 44 C.F.R. §206.48(b)(1)(ii)(B). FEMA, 44 C.F.R. §206.48(b)(1)(ii)(B). FEMA, IA Declarations Factors Guidance, p. 9. , p. 9. T heThe FEMA FEMA Preliminary Damage
Assessm entAssessment Guide
provides information regarding the cumulative effect of recent disasters on pages 34 provides information regarding the cumulative effect of recent disasters on pages 34 -35. -35.
284 280 44 C.F.R. §206.48(b)(2); FEMA, 44 C.F.R. §206.48(b)(2); FEMA, IA Declarations Factors Guidance, p. 9. , p. 9.
285281 44 C.F.R. §206.48(b)(2)(i); FEMA, 44 C.F.R. §206.48(b)(2)(i); FEMA, IA Declarations Factors Guidance, p. 9. , p. 9. T heThe FEMA FEMA Preliminary Damage
Assessm entAssessment Guide
provides information regarding documenting the cause provides information regarding documenting the cause of damageof damage on pages 36on pages 36 -37. -37.
286282 44 C.F.R. §206.48(b)(2)(ii); FEMA, 44 C.F.R. §206.48(b)(2)(ii); FEMA, IA Declarations Factors Guidance, p. 9. , p. 9. T heThe FEMA FEMA Preliminary Damage
Assessm entAssessment Guide
provides information regarding documenting the concentration of damage on page 37. provides information regarding documenting the concentration of damage on page 37.
287 283 44 C.F.R. §206.48(b)(2)(iii); see information on the categories of home damage in FEMA, 44 C.F.R. §206.48(b)(2)(iii); see information on the categories of home damage in FEMA, Preliminary Damage
Assessm entAssessment Guide
, p. 28. Per FEMA’s , p. 28. Per FEMA’s IA Declarations Factors Guidance, the , the stat estate typically provides information on typically provides information on
the number of homes impacted and degreethe number of homes impacted and degree of damageof damage at the countyat the county - and state-level (FEMA, - and state-level (FEMA, IA Declarations Factors
Guidance
, p. 9). , p. 9).
288284 FEMA, FEMA, Preliminary Damage Assessment Guide, p. 28. “, p. 28. “T heThe cost of assistance estimate is established cost of assistance estimate is established by assessing by assessing
and categorizing the degreeand categorizing the degree of damageof damage of disaster-impacted residences.of disaster-impacted residences. T his This calculation is mostly data driven, is calculation is mostly data driven, is
calculated with FEMA support, and encompasses a significant portion of a Presidential disaster declaration request.”calculated with FEMA support, and encompasses a significant portion of a Presidential disaster declaration request.”
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“probable grant assistance that “probable grant assistance that wil will be awarded for ONA in addition to grant be awarded for ONA in addition to grant
assistance for housing”;assistance for housing”;289
285 5. 5. Homeownership Rate: the estimated rate of homeownership for the affected : the estimated rate of homeownership for the affected
homes, which may influence whether the IHP is needed, and what types of homes, which may influence whether the IHP is needed, and what types of
housing assistance should be made available;housing assistance should be made available;290286
6. 6. Insurance Coverage: the percentage of affected applicants with insurance for the : the percentage of affected applicants with insurance for the
peril that caused the damage helps FEMA assess whether IHP assistance is peril that caused the damage helps FEMA assess whether IHP assistance is
needed and what the probable grant of assistance may be because IHP assistance needed and what the probable grant of assistance may be because IHP assistance
is intended to assist with uninsured or under-insured necessary expenses and is intended to assist with uninsured or under-insured necessary expenses and
serious needs;serious needs;291287 and and
7. 7. Other: other relevant PDA data submitted by the state that may demonstrate a : other relevant PDA data submitted by the state that may demonstrate a
need for supplemental federal assistance for individuals. need for supplemental federal assistance for individuals.292288
Factor 3: Disaster Impacted Population Profile
When FEMA When FEMA evaluates the Disaster Impacted Population Profile (44 C.F.R. §206.48(b)(3)) factor, evaluates the Disaster Impacted Population Profile (44 C.F.R. §206.48(b)(3)) factor,
FEMA considers the affected community’s demographics as compared with national averages, to FEMA considers the affected community’s demographics as compared with national averages, to
evaluate whether there is an increased need for supplemental federal assistance.evaluate whether there is an increased need for supplemental federal assistance.293289 FEMA FEMA
considers population data reported by the U.S. Census Bureau and other federal agencies, considers population data reported by the U.S. Census Bureau and other federal agencies,
including the percentage of the populationincluding the percentage of the population:
1. in poverty status; 1. in poverty status;
2. receiving government assistance (e.g., Supplemental Nutrition Assistance 2. receiving government assistance (e.g., Supplemental Nutrition Assistance
Program (SNAP) benefits); Program (SNAP) benefits);
3. the pre-disaster unemployment rate; 3. the pre-disaster unemployment rate;
4. 65 years of age or older; 4. 65 years of age or older;
5. 18 years of age or younger; 5. 18 years of age or younger;

289 6. who are individuals with disabilities; 285 44 C.F.R. §206.48(b)(2)(iv). 44 C.F.R. §206.48(b)(2)(iv). T heThe estimated cost of assistance can be used estimated cost of assistance can be used by by states to determine the likelihood they states to determine the likelihood they
willwill receive a major disasterreceive a major disaster declaration (FEMA, declaration (FEMA, IA Declarations Factors Guidance, pp. 9-10 and 14-15). , pp. 9-10 and 14-15). T he FEMA
Prelim inary Dam age Assessm entThe FEMA Preliminary Damage Assessment Guide provides information for states to estimate the cost of assistance on pages 28 provides information for states to estimate the cost of assistance on pages 28 --
32. 32.
290 286 44 C.F.R. §206.48(b)(2)(v); FEMA, 44 C.F.R. §206.48(b)(2)(v); FEMA, IA Declarations Factors Guidance, p. 10. IHP assistance is provided for both , p. 10. IHP assistance is provided for both
homeowners and renters, but different forms of IHPhomeowners and renters, but different forms of IHP assistance are available to homeowners (e.g., homeowners may be assistance are available to homeowners (e.g., homeowners may be
edibleedible for Home Repair and Home Replacement assistance, in addition to forms of Direct Housingfor Home Repair and Home Replacement assistance, in addition to forms of Direct Housing Assistance). Assistance).
291287 44 C.F.R. §206.48(b)(2)(vi). According to FEMA’s guidance, 44 C.F.R. §206.48(b)(2)(vi). According to FEMA’s guidance, with regardwith regard to assessingto assessing insurance coverage, “[t]he insurance coverage, “[t]he
State shouldState should attempt to provide this information through the State insurance commissioner or office and other attempt to provide this information through the State insurance commissioner or office and other
appropriate sources.... FEMA currently utilizes National Flood Insurance Program (NFIP) data to determine insuranceappropriate sources.... FEMA currently utilizes National Flood Insurance Program (NFIP) data to determine insurance
penetration rates for flood damages and Censuspenetration rates for flood damages and Census data to determine homeowners’ insurance coverage percentages.... data to determine homeowners’ insurance coverage percentages....
[T[T ]he percentage of owner-occupied homes with a mortgage may be used]he percentage of owner-occupied homes with a mortgage may be used to estimate an insurance penetration rate, due to estimate an insurance penetration rate, due
to the assumption that a home with a mortgage wouldto the assumption that a home with a mortgage would require require home insurance coverage” (FEMA,home insurance coverage” (FEMA, IA Declarations
Factors Guidance
, p. 10). , p. 10). T he FEMA Prelim inary Dam age Assessm entThe FEMA Preliminary Damage Assessment Guide provides information for states to provides information for states to
estimate the level of applicable insurance coverage on pagesestimate the level of applicable insurance coverage on pages 33 33-34 and in Appendix I. -34 and in Appendix I.
292 288 44 C.F.R. §206.48(b)(2)(vii); FEMA, 44 C.F.R. §206.48(b)(2)(vii); FEMA, IA Declarations Factors Guidance, p. 10. , p. 10.
293289 44 C.F.R. §206.48(b)(3); FEMA, 44 C.F.R. §206.48(b)(3); FEMA, IA Declarations Factors Guidance, pp. 10-11. Data sources include Census, pp. 10-11. Data sources include Census data, data,
as wellas well as as information from the Bureau of Labor and Statistics. In addition to helping FEMA evaluate appropriate information from the Bureau of Labor and Statistics. In addition to helping FEMA evaluate appropriate
forms of assistance, this information may also be usedforms of assistance, this information may also be used to help direct outreach efforts (e.g., FEMA may need to provide to help direct outreach efforts (e.g., FEMA may need to provide
information in multiple languagesinformation in multiple languages based based on the languageson the languages commonly spoken in an affected jurisdiction). commonly spoken in an affected jurisdiction). T he FEMA
Prelim inary Dam age Assessm entThe FEMA Preliminary Damage Assessment Guide provides information to help states illustrate the disaster’s impact on affected provides information to help states illustrate the disaster’s impact on affected
populations on page 37. populations on page 37.
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6. who are individuals with disabilities;
7. who speak a language other than English7. who speak a language other than English and speak English less than “very and speak English less than “very
wel well”; and”; and
8. FEMA 8. FEMA also considers “any unique considerations regarding American Indian and also considers “any unique considerations regarding American Indian and
Alaskan Native Tribal populations.” Alaskan Native Tribal populations.”294290
Factor 4: Impact to Community Infrastructure
When FEMA evaluates the Impact to Community Infrastructure (44 C.F.R. §206.48(b)(4)) factor, When FEMA evaluates the Impact to Community Infrastructure (44 C.F.R. §206.48(b)(4)) factor,
FEMA considers the disaster-caused disruption, damage, or destruction to community FEMA considers the disaster-caused disruption, damage, or destruction to community
infrastructure components, which may make it difficult for disaster survivors to reside in the infrastructure components, which may make it difficult for disaster survivors to reside in the
community and may hinder community recovery.community and may hinder community recovery.295291 FEMA considers state-provided information FEMA considers state-provided information
on disruptions to the following community services lasting more than 72 hours: on disruptions to the following community services lasting more than 72 hours:
1. 1. Life-Saving and Life-Sustaining Services: “services that provide an essential : “services that provide an essential
community function that, if interrupted, community function that, if interrupted, wil will affect public health and safety in a affect public health and safety in a
community,” such as police, fire, and emergency medical services (EMS) (i.e., community,” such as police, fire, and emergency medical services (EMS) (i.e.,
examples of life-saving services), and grocery stores (i.e., an example of a life-examples of life-saving services), and grocery stores (i.e., an example of a life-
sustaining service), and the unavailabilitysustaining service), and the unavailability of which may indicate the need for a of which may indicate the need for a
more robust response;more robust response;296
292 2. 2. Essential Community Services: services that improve quality of life,: services that improve quality of life, such as such as
schools and childcare providers, and social services, disruptions to which schools and childcare providers, and social services, disruptions to which wil
will hinder community recovery;hinder community recovery;297293 and and
3. 3. Transportation Infrastructure and Utilities: infrastructure and services, the : infrastructure and services, the
unavailability unavailability of which could, for example, render housing uninhabitable or of which could, for example, render housing uninhabitable or
inaccessible, or affect the delivery of services, hindering community recovery.inaccessible, or affect the delivery of services, hindering community recovery.298294
Factor 5: Casualties
When FEMA evaluates the Casualties (44 C.F.R. §206.48(b)(5)) factor, FEMA considers the When FEMA evaluates the Casualties (44 C.F.R. §206.48(b)(5)) factor, FEMA considers the
number of individuals who are missing, injured, or deceased as a result of a disaster, which number of individuals who are missing, injured, or deceased as a result of a disaster, which
indicates how traumatic an event was for a community and may indicate the appropriate types of indicates how traumatic an event was for a community and may indicate the appropriate types of
IA to provide (e.g., ONA for Funeral Assistance and Medical and Dental Assistance, and Crisis IA to provide (e.g., ONA for Funeral Assistance and Medical and Dental Assistance, and Crisis
Counseling).Counseling).299

294295 Factor 6: Disaster Related Unemployment When FEMA evaluates the Disaster Related Unemployment (44 C.F.R. §206.48(b)(6)) factor, FEMA considers the number of individuals who may have lost work or become unemployed as a 290 44 C.F.R. §206.48(b)(3)(i)-(viii); FEMA, 44 C.F.R. §206.48(b)(3)(i)-(viii); FEMA, IA Declarations Factors Guidance, pp. 10-11. According to FEMA’s , pp. 10-11. According to FEMA’s
guidance,guidance, “[t]hese population demographic data points are relevant to all of FEMA’s IA programs and are a valuable “[t]hese population demographic data points are relevant to all of FEMA’s IA programs and are a valuable
source of information to determine if specific programs are neededsource of information to determine if specific programs are needed after a disaster.” after a disaster.”
295291 44 C.F.R. §206.48(b)(4); FEMA, 44 C.F.R. §206.48(b)(4); FEMA, IA Declarations Factors Guidance, pp. 11-12. , pp. 11-12. T heThe FEMA FEMA Preliminary Damage
Assessm entAssessment Guide
provides information for states to estimate the impact to critical community infrastructure on page provides information for states to estimate the impact to critical community infrastructure on page
38. 38.
296292 44 C.F.R. §206.48(b)(4)(i); FEMA, 44 C.F.R. §206.48(b)(4)(i); FEMA, IA Declarations Factors Guidance, p. 12. , p. 12.
297293 44 C.F.R. §206.48(b)(4)(ii); FEMA, 44 C.F.R. §206.48(b)(4)(ii); FEMA, IA Declarations Factors Guidance, p. 12. , p. 12.
298294 44 C.F.R. §206.48(b)(4)(iii); FEMA, 44 C.F.R. §206.48(b)(4)(iii); FEMA, IA Declarations Factors Guidance, p. 12. , p. 12.
299295 44 C.F.R. §206.48(b)(5); FEMA, 44 C.F.R. §206.48(b)(5); FEMA, IA Declarations Factors Guidance, p. 12. , p. 12. T heThe FEMA FEMA Preliminary Damage
Assessm entAssessment Guide
provides information for states to estimate the disaster-caused deaths and injuries, provides information for states to estimate the disaster-caused deaths and injuries, which indicates which indicates
disaster-causeddisaster-caused trauma, on page 39. trauma, on page 39.
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Factor 6: Disaster Related Unemployment
When FEMA evaluates the Disaster Related Unemployment (44 C.F.R. §206.48(b)(6)) factor,
FEMA considers the number of individuals who may have lost work or become unemployed as a
result of the disaster and who do not qualify for standard unemployment insurance. FEMA also result of the disaster and who do not qualify for standard unemployment insurance. FEMA also
considers impacts to major employers in the affected jurisdiction, which could indicate the considers impacts to major employers in the affected jurisdiction, which could indicate the
potential for a prolonged recovery process due to people being out of work, and may indicate the potential for a prolonged recovery process due to people being out of work, and may indicate the
need for Disaster Unemployment Assistance.need for Disaster Unemployment Assistance.300296
Factors Considered whenWhen Evaluating a Chief Executive’s Request
for IA
Section 1110 of the Sandy Recovery Improvement Act of 2013 (SRIA, Division B of P.L. 113-2), Section 1110 of the Sandy Recovery Improvement Act of 2013 (SRIA, Division B of P.L. 113-2),
amended the Stafford Act to amended the Stafford Act to al owallow the chief executive of an affected Indian tribal government to the chief executive of an affected Indian tribal government to
request a major disaster or emergency declaration (alternatively, the Indian tribe may receive request a major disaster or emergency declaration (alternatively, the Indian tribe may receive
assistance through the state’s declaration).assistance through the state’s declaration).301 Initial y297 Initially, FEMA used the same factors to evaluate a , FEMA used the same factors to evaluate a
governor or chief executive’s request for a presidential major disaster declaration, which governor or chief executive’s request for a presidential major disaster declaration, which al owedallowed
Indian tribal governments to exercise this authority immediately upon SRIA’s enactment.Indian tribal governments to exercise this authority immediately upon SRIA’s enactment.302298
However, FEMA’s release of the However, FEMA’s release of the Tribal Declarations Pilot Guidance in January 2017, made in January 2017, made
effective specific factors considered when evaluating a chief executive’s request for a major effective specific factors considered when evaluating a chief executive’s request for a major
disaster declaration.disaster declaration.303299 When the pilot period concludes (no specific time has been set), FEMA When the pilot period concludes (no specific time has been set), FEMA
wil will develop regulations informed by the pilot.develop regulations informed by the pilot.304300
The factors considered when evaluating a chief executive’s request for a major disaster The factors considered when evaluating a chief executive’s request for a major disaster
declaration authorizing Individual Assistance are intended to help FEMA evaluate whether an declaration authorizing Individual Assistance are intended to help FEMA evaluate whether an
event has overwhelmed the tribal government’s capabilities, making Stafford Act assistance event has overwhelmed the tribal government’s capabilities, making Stafford Act assistance
necessary.necessary.305
301 The nine IA factors that are evaluated by FEMA pursuant to a chief executive’s request for a The nine IA factors that are evaluated by FEMA pursuant to a chief executive’s request for a
major disaster declaration authorizing IA are as follows—no single factor is determinative:major disaster declaration authorizing IA are as follows—no single factor is determinative:306

300302 Factor 1: Uninsured Home and Personal Property Losses When FEMA evaluates the Uninsured Home and Personal Property Losses factor, FEMA evaluates the damage to the primary residences of enrolled tribal members303 and, if requested 296 44 C.F.R. §206.48(b)(6); FEMA, 44 C.F.R. §206.48(b)(6); FEMA, IA Declarations Factors Guidance, pp. 12-13. , pp. 12-13. T oTo be eligible be eligible for Disaster for Disaster
Unemployment Assistance (DUA), an individualUnemployment Assistance (DUA), an individual must (1) have been previously employed or selfmust (1) have been previously employed or self -employed; (2) -employed; (2)
rendered joblessrendered jobless or had their employment interrupted as a direct result of a major disaster;or had their employment interrupted as a direct result of a major disaster; and (3) be and (3) be i neligible ineligible for for
regularregular unemployment insurance (44 C.F.R. §206.141; 42 U.S.C.unemployment insurance (44 C.F.R. §206.141; 42 U.S.C. §5177; FEMA, §5177; FEMA, IAPPG, pp. 9 and 239-243). For more , pp. 9 and 239-243). For more
information on Disaster Unemployment Assistance, see CRSinformation on Disaster Unemployment Assistance, see CRS Report RS22022, Report RS22022, Disaster Unem ploym ent Unemployment Assistance
(DUA)
, by Julie, by Julie M. Whittaker. M. Whittaker.
301297 Section 1110 of the Sandy Recovery Improvement Act of 2013 (SRIA, Division B of P.L. 113-2) amended Stafford Section 1110 of the Sandy Recovery Improvement Act of 2013 (SRIA, Division B of P.L. 113-2) amended Stafford
Act Sections 401 and 501 (42 U.S.C. §§5170 and 5191). Act Sections 401 and 501 (42 U.S.C. §§5170 and 5191).
302 298 According to FEMA’s website According to FEMA’s website “T ribal “Tribal Declarations Pilot Guidance,” available at https://www.fema.gov/disasters/ Declarations Pilot Guidance,” available at https://www.fema.gov/disasters/
tribal-declarations, the period when Indian tribal governments could use the state/territory regulations ran from January tribal-declarations, the period when Indian tribal governments could use the state/territory regulations ran from January
29, 2013, when SRIA29, 2013, when SRIA was was enacted, through January 9, 2017, when FEMA releasedenacted, through January 9, 2017, when FEMA released its its Tribal Declarations Pilot
Guidance
on January 10, 2017. on January 10, 2017.
303299 FEMA, FEMA, Tribal Declarations Pilot Guidance. .
304300 FEMA, FEMA, Tribal Declarations Pilot Guidance, p. 3. , p. 3.
305301 FEMA, FEMA, Tribal Declarations Pilot Guidance, p. 34. “Appendix D; , p. 34. “Appendix D; T ribalTribal-Specific Considerations” of FEMA’s -Specific Considerations” of FEMA’s
Prelim inary Dam age Assessm entPreliminary Damage Assessment Guide includes includes useful useful resources and uniqueresources and unique considerations for Indian tribal considerations for Indian tribal
governments during the PDA process. governments during the PDA process.
306302 FEMA, FEMA, Tribal Declarations Pilot Guidance, p. 34. , p. 34.
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Factor 1: Uninsured Home and Personal Property Losses
When FEMA evaluates the Uninsured Home and Personal Property Losses factor, FEMA
evaluates the damage to the primary residences of enrolled tribal members307 and, if requested
and approved, non-enrolled members of the tribal community308 by categorizing homes based on
303 FEMA, Tribal Declarations Pilot Guidance, p. 8. Per FEMA’s guidance, enrolled tribal members are “[people] ... the Indian tribal government recognizes as an enrolled member ... at the beginning of the incident period.” Congressional Research Service 55 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations and approved, non-enrolled members of the tribal community304 by categorizing homes based on damage and assessing the magnitude of the disaster and concentration of damages.damage and assessing the magnitude of the disaster and concentration of damages.309
305 Factor 2: Availability of Housing Resources
When FEMA evaluates the Availability When FEMA evaluates the Availability of Housing Resources factor, FEMA considers the of Housing Resources factor, FEMA considers the
availability availability of accessible temporary housing resources.of accessible temporary housing resources.310306
Factor 3: Casualties
When FEMA evaluates the Casualties factor, FEMA considers disaster-caused “deaths or injuries When FEMA evaluates the Casualties factor, FEMA considers disaster-caused “deaths or injuries
[including] of cultural, religious, and government leaders.”[including] of cultural, religious, and government leaders.”311
307 Factor 4: Impact to Community Infrastructure
When FEMA evaluates the Impact to Community Infrastructure factor, FEMA considers the When FEMA evaluates the Impact to Community Infrastructure factor, FEMA considers the
disaster’s impacts that may adversely affect the “population’s ability to safely and securely reside disaster’s impacts that may adversely affect the “population’s ability to safely and securely reside
within the community,” including the large-scale disruption of community functions and services; within the community,” including the large-scale disruption of community functions and services;
impacts to cultural and spiritual facilities; and emergency needs (e.g., extended or widespread impacts to cultural and spiritual facilities; and emergency needs (e.g., extended or widespread
power failure).power failure).312308
Factor 5: Disaster Impacted Population Profile
When FEMA evaluates the Disaster Impacted Population Profile factor, FEMA considers the When FEMA evaluates the Disaster Impacted Population Profile factor, FEMA considers the
affected community’s demographics, including populations that may have a greater need for affected community’s demographics, including populations that may have a greater need for
recovery support (e.g., people with disabilities and others with access and functional needs).recovery support (e.g., people with disabilities and others with access and functional needs).313
309 Factor 6: Voluntary Agency and Other Assistance
When FEMA evaluates the Voluntary Agency and Other Assistance factor, FEMA considers the When FEMA evaluates the Voluntary Agency and Other Assistance factor, FEMA considers the
extent to which the needs of disaster survivors can be met by voluntary agencies, and the local extent to which the needs of disaster survivors can be met by voluntary agencies, and the local
and state governments.and state governments.314

307 FEMA, Tribal Declarations Pilot Guidance, p. 8. Per FEMA’s guidance, enrolled tribal members are “[people] ...
the Indian tribal government recognizes as an enrolled member ... at the beginning of the incident period.”
308310 Factor 7: Tribal Government Resources When FEMA evaluates the Tribal Government Resources factor, FEMA considers the efforts that have or will be made and the resources that have or will be committed by the tribal government for response and recovery.311 304 FEMA, FEMA, Tribal Declarations Pilot Guidance, p. 34. , p. 34. T heThe Indian tribal government may request that FEMA expand IA Indian tribal government may request that FEMA expand IA
eligibilityeligibility to extend assistance to non-enrolled members of the tribal community, including “to extend assistance to non-enrolled members of the tribal community, including “ adopted children, widows adopted children, widows
and widowers,and widowers, and descendants”and descendants” (FEMA, (FEMA, Tribal Declarations Pilot Guidance, p. 18). , p. 18).
309305 FEMA, FEMA, Tribal Declarations Pilot Guidance, p. 37. , p. 37.
310306 FEMA, FEMA, Tribal Declarations Pilot Guidance, p. 37. , p. 37.
311307 FEMA, FEMA, Tribal Declarations Pilot Guidance, p. 37. , p. 37.
312308 FEMA, FEMA, Tribal Declarations Pilot Guidance, p. 37. , p. 37.
313309 FEMA, FEMA, Tribal Declarations Pilot Guidance, p. 37. , p. 37.
314310 FEMA, Tribal Declarations Pilot Guidance, p. 37. 311 FEMA, FEMA, Tribal Declarations Pilot Guidance, p. 37. , p. 37.
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Factor 7: Tribal Government Resources
When FEMA evaluates the Tribal Government Resources factor, FEMA considers the efforts that
have or wil be made and the resources that have or wil be committed by the tribal government
for response and recovery.315
Factor 8: Unique Conditions that may Affect Tribal Governments
When FEMA evaluates the Unique Conditions that may Affect Tribal Governments factor, FEMA When FEMA evaluates the Unique Conditions that may Affect Tribal Governments factor, FEMA
considers the tribe’s unique needs and the conditions that are unique to the tribal community, such considers the tribe’s unique needs and the conditions that are unique to the tribal community, such
as: “[n]eeds associated with remote locations”;as: “[n]eeds associated with remote locations”;316312 the disaster’s impact on the tribal government’s the disaster’s impact on the tribal government’s
economy or livelihood; and “[c]ultural or spiritual considerations.”economy or livelihood; and “[c]ultural or spiritual considerations.”317
313 Factor 9: Other Relevant Information
FEMA also considers Other Relevant Information provided by the tribal government. FEMA also considers Other Relevant Information provided by the tribal government.318314












315 FEMA, Tribal Declarations Pilot Guidance, p. 37.
316 FEMA, Tribal Declarations Pilot Guidance, p. 37. Examples included in FEMA’s guidance are the tribe’s
accessibility, and the availability of food, water and medical supplies.
317 FEMA, Tribal Declarations Pilot Guidance, p. 38. T he FEMA Preliminary Damage Assessment Guide provides
considerations for tribes to convey information regarding unique conditions affecting tribal communities on page 41 .
318 FEMA, Tribal Declarations Pilot Guidance, p. 38.
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Table A-1. IA Factors for a Governor’s Major Disaster Declaration Request
Authorizing IA
Applies to Applies to Af ectedAffected States and Territories States and Territories
Supporting Information/Data
IA Factors
FEMA Considers
Sources
State Fiscal Capacity and Resource State Fiscal Capacity and Resource
Availability Availability of state/territory of state/territory
U.S. Department of U.S. Department of the Treasury, Treasury,
AvailabilityaAvailabilitya
resources resources and circumstances and circumstances
Bureau of Economic Analysis, Bureau of Economic Analysis,
contributing to the lack thereof. contributing to the lack thereof.
State/territory State/territory reported other reported other
limitslimits on a state/territory’son a state/territory’s treasury treasury
or ability to col ector ability to col ect funds and funds and
resourceresource availability availability
Uninsured Home Uninsured Home and Personal and Personal
Disaster-caused Disaster-caused real and personal real and personal
State/territory State/territory reported fol owing reported fol owing
Property Property LossesbLossesb
property losses, property losses, including including
the Preliminary the Preliminary Damage Damage
consideration of whether losses consideration of whether losses
Assessment Assessment
were insured and the estimated were insured and the estimated
cost of assistance. cost of assistance.
Disaster Impacted Population
Demographics 312 FEMA, Tribal Declarations Pilot Guidance, p. 37. Examples included in FEMA’s guidance are the tribe’s accessibility, and the availability of food, water and medical supplies. 313 FEMA, Tribal Declarations Pilot Guidance, p. 38. The FEMA Preliminary Damage Assessment Guide provides considerations for tribes to convey information regarding unique conditions affecting tribal communities on page 41. 314 FEMA, Tribal Declarations Pilot Guidance, p. 38. Congressional Research Service 57 link to page 63 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations Supporting Information/Data IA Factors FEMA Considers Sources Disaster Impacted Population Demographics of the affected of the affected
U.S. Census Bureau (see the U.S. Census Bureau (see the
Profile Profile
population that may indicate population that may indicate
American American Community Survey Community Survey
additional needs and the need for a additional needs and the need for a
(ACS)), other federal agencies (ACS)), other federal agencies
more more robust response. robust response.
Impact to Community Impact to Community
Disaster-caused Disaster-caused impacts to impacts to
State/territory State/territory reported reported
Infrastructure Infrastructure
community infrastructure that may community infrastructure that may
adverselyadversely affect the safety and affect the safety and
security of disastersecurity of disaster survivors and survivors and
hinder community recovery. hinder community recovery.
Casualties Casualties
Number of individuals who are Number of individuals who are
State/territory State/territory reported reported
missing, missing, injured,injured, or deceased due to or deceased due to
the disaster,the disaster, resulting in trauma to resulting in trauma to
the community. the community.
Disaster Disaster Related Unemployment Related Unemployment
Number of disaster survivors Number of disaster survivors who who
State/territory State/territory reported reported
lost their work or became lost their work or became
unemployed due to the disaster, unemployed due to the disaster,
and who do not qualify for standard and who do not qualify for standard
unemployment insurance. unemployment insurance.
Sources: 44 C.F.R.44 C.F.R. §206.48(b); FEMA, §206.48(b); FEMA, Individual Assistance Declarations Factors Guidance,, June 2019, June 2019,
https://www.regulations.gov/document/FEMA-2014-0005-0071; FEMA, https://www.regulations.gov/document/FEMA-2014-0005-0071; FEMA, Preliminary Damage Assessment Guide, ,
August 2021, pp. 15 and 28-41, https://www.fema.gov/sites/default/files/documents/fema_2021-pda-guide.pdf. August 2021, pp. 15 and 28-41, https://www.fema.gov/sites/default/files/documents/fema_2021-pda-guide.pdf.
Notes: Per 44 C.F.R.Per 44 C.F.R. §206.48(b), “FEMA §206.48(b), “FEMA wil will always consideralways consider al all relevant information submitted as part of a relevant information submitted as part of a
declaration request.” declaration request.”
a. Fiscal Capacity is a principal factor for the IHP (44 C.F.R. §206.48(b)(1)(i)).a. Fiscal Capacity is a principal factor for the IHP (44 C.F.R. §206.48(b)(1)(i)).
b. Uninsured Homeb. Uninsured Home and Personal Property Lossesand Personal Property Losses is a principal factor for the IHP (44 C.F.R.is a principal factor for the IHP (44 C.F.R. §206.48(b)(2)). §206.48(b)(2)).
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Table A-2. IA Factors for a Chief Executive’s Major Disaster Declaration Request
Authorizing IA
Applies to Applies to Af ected Federal yAffected Federally Recognized Tribes Recognized Tribes
Supporting Information/Data
IA Factors
FEMA Considers
Sources
Uninsured Home Uninsured Home and Personal and Personal
Disaster-caused Disaster-caused real and personal real and personal
Tribe reported fol owing the Tribe reported fol owing the
Property Property LossesaLossesa
property losses property losses of enrol edof enrol ed tribal tribal
Preliminary Preliminary Damage Assessment Damage Assessment
members members and—if requested by the and—if requested by the
tribe—memberstribe—members of the tribal of the tribal
community, including consideration community, including consideration
of the amount of damage and of the amount of damage and
whether there are high whether there are high
concentrations of damage. concentrations of damage.
Availability Availability of Housing Resources of Housing Resources
Availability Availability of temporary housing of temporary housing
Tribe reported Tribe reported
resources. resources.
Casualties Casualties
Number of individuals who are Number of individuals who are
Tribe reported Tribe reported
missing, missing, injured,injured, or deceased due to or deceased due to
the disaster,the disaster, including cultural, including cultural,
religious,religious, and government leaders. and government leaders.
Impact to Community Impact to Community
Disaster-caused Disaster-caused impacts to impacts to
Tribe reported Tribe reported
Infrastructure Infrastructure
community infrastructure that may community infrastructure that may
adverselyadversely affect the safety and affect the safety and
security of disastersecurity of disaster survivors. survivors.
Disaster Impacted Population
Demographics Congressional Research Service 58 FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations Supporting Information/Data IA Factors FEMA Considers Sources Disaster Impacted Population Demographics of the affected of the affected
U.S. Census Bureau, tribe reported U.S. Census Bureau, tribe reported
Profile Profile
population—including populations population—including populations
unique considerations unique considerations not reflected not reflected
with greater needs—that may with greater needs—that may
in U.S. Census Bureau data in U.S. Census Bureau data
indicate the need for a more indicate the need for a more robust robust
response. response.
Voluntary Agency and Other Voluntary Agency and Other
Ability of state or local government, Ability of state or local government,
Tribe reported Tribe reported
Assistance Assistance
or voluntary agency resources or voluntary agency resources to to
meet the needs of disaster meet the needs of disaster
survivors. survivors.
Tribal Government Resources Tribal Government Resources
Availability Availability of tribal resourcesof tribal resources for for
Tribe reported Tribe reported
response or recovery, response or recovery, including including
resourcesresources that have been or wilthat have been or wil be be
used. used.
Unique Conditions that Affect Unique Conditions that Affect
Needs or conditions unique to the Needs or conditions unique to the
Tribe reported Tribe reported
Tribal Governments Tribal Governments
tribal community. tribal community.
Other Relevant Information Other Relevant Information
Other relevant information Other relevant information
Tribe reported Tribe reported
provided by the tribe. provided by the tribe.
Sources: FEMA, FEMA, Tribal Declarations Pilot Guidance,, January 2017, pp. 36-38, https://www.fema.gov/sites/default/January 2017, pp. 36-38, https://www.fema.gov/sites/default/
files/2020-04/tribal-declaration-pilot-guidance.pdf; FEMA, files/2020-04/tribal-declaration-pilot-guidance.pdf; FEMA, Preliminary Damage Assessment Guide, August 2021, pp. , August 2021, pp.
15 and D1-D9, https://www.fema.gov/sites/default/files/documents/fema_2021-pda-guide.pdf. 15 and D1-D9, https://www.fema.gov/sites/default/files/documents/fema_2021-pda-guide.pdf.
Notes:
a. Uninsured home and personal property losses—a. Uninsured home and personal property losses—specifical y specifically the “disaster-relatedthe “disaster-related impacts to homes and impacts to homes and
personal property are the principal factors FEMA and the President use to determine personal property are the principal factors FEMA and the President use to determine if the [tribe’s] request if the [tribe’s] request
[for a presidential[for a presidential major major disaster declaration including IA] should be approved.” (FEMA,disaster declaration including IA] should be approved.” (FEMA, Preliminary Damage
Assessment Guide
, p. D-5.) , p. D-5.)
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Appendix B. IHP Roles of the Federal and
State/Territory/Tribal Governments
The roles of the federal and state/territory/Indian tribal governments in administering the IHP The roles of the federal and state/territory/Indian tribal governments in administering the IHP
vary—vary—especial yespecially depending on the category of IHP assistance (i.e., Housing Assistance or ONA) depending on the category of IHP assistance (i.e., Housing Assistance or ONA)
being provided. A comparison of the roles of the federal government and state/territory/Indian being provided. A comparison of the roles of the federal government and state/territory/Indian
tribal governments is included intribal governments is included in Table B-1.
Table B-1. Roles of the Federal and State/Territory/Indian Tribal Governments in IHP
Administration
State/Territory/Indian Tribal
Action
Government
Federal Government
Emergency or Major Emergency or Major
The governor or chief executive requests The governor or chief executive requests
The FEMA Regional Administrator The FEMA Regional Administrator
Disaster Disaster Declaration Declaration
a presidential a presidential declaration of emergencydeclaration of emergency or
reviews or reviews the governor or chief executive’s the governor or chief executive’s
and Individual and Individual
major major disaster,disaster, as wel as well as IA. as IA.
request and makes request and makes a recommendationa recommendation to to
Assistance Assistance (IA) (IA)
the President, who has the authority to the President, who has the authority to
Authorization Authorization
approve or deny the declaration request approve or deny the declaration request
and request for Iand request for IA.a
Housing Assistance Housing Assistance
The state/territory/Indian tribal The state/territory/Indian tribal
FEMA administers FEMA administers financial housing financial housing
Administration Administration
government may elect government may elect to administer to administer
assistance, and may administer assistance, and may administer Direct Direct
Direct Direct Temporary Housing Assistance Temporary Housing Assistance
Temporary Housing Assistance if the Temporary Housing Assistance if the
and Permanent Housing and Permanent Housing Construction.b
Construction.b state/territory/Indian tribal government state/territory/Indian tribal government

elects elects not tonot to.b
The state/territory/Indian tribal The state/territory/Indian tribal

government is expected to establish the government is expected to establish the
FEMA coordinates with the State-Led FEMA coordinates with the State-Led
State-Led Disaster State-Led Disaster Housing Task Housing Task ForceForce.c
Disaster Disaster Housing Task Housing Task ForceForce.c
Other Needs Other Needs
The state/territory/Indian tribal The state/territory/Indian tribal
FEMA may administer FEMA may administer ONA when the ONA when the
Assistance Assistance (ONA) (ONA)
government selects government selects the ONA the ONA
state/territory/Indian tribal government state/territory/Indian tribal government
Administration Administration
administration option and may elect to administration option and may elect to
elects to use the FEMA Option, or FEMA elects to use the FEMA Option, or FEMA
solely solely administer administer ONA (i.e.,ONA (i.e., the the
may co-administer ONA with the may co-administer ONA with the
State/Tribe Option) or co-administer State/Tribe Option) or co-administer
state/territory/Indian tribal government state/territory/Indian tribal government
ONA with FEMA (i.e., ONA with FEMA (i.e., the Joint Option). the Joint Option).
when the Joint Option is when the Joint Option is selectedselected.d
The state/territory/Indian tribal The state/territory/Indian tribal
government may also elect for FEMA to government may also elect for FEMA to
administeradminister ONA (i.e.,ONA (i.e., the FEMA Optionthe FEMA Option).d
Housing Cost Share Housing Cost Share
0% (regardless 0% (regardless of electionof election to administer to administer
100%e
Direct Direct Temporary Housing AssistanceTemporary Housing Assistance or or
Permanent Housing ConstructionPermanent Housing Construction)).e
ONA Cost Share ONA Cost Share
25%f
75%f
Sources: 44 C.F.R.44 C.F.R. Part 206, Subparts B and D; FEMA, Part 206, Subparts B and D; FEMA, Individual Assistance Program and Policy Guide (IAPPG), v. , v.
1.1, FP 104-009-03, May 2021, https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf1.1, FP 104-009-03, May 2021, https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf (hereinafter (hereinafter
FEMA, FEMA, IAPPG); FEMA, ); FEMA, Tribal Declarations Declarations Pilot Guidance,, January 2017, https://www.fema.gov/sites/default/files/January 2017, https://www.fema.gov/sites/default/files/
2020-04/tribal-declaration-pilot-guidance.pdf (hereinafter FEMA, 2020-04/tribal-declaration-pilot-guidance.pdf (hereinafter FEMA, Tribal Declarations Pilot Guidance). ).
Notes: In addition to the federalIn addition to the federal and state/territory/Indian tribal governments,and state/territory/Indian tribal governments, local governments and nonprofit local governments and nonprofit
organizations may also play rolesorganizations may also play roles in supporting the provisionin supporting the provision of housing assistance and assistance for other of housing assistance and assistance for other
needs. needs.
a. 44 C.F.R.a. 44 C.F.R. §206.37; FEMA, §206.37; FEMA, IAPPG, p. 3; and FEMA, , p. 3; and FEMA, Tribal Declarations Pilot Guidance, pp. 27-29. , pp. 27-29.
b. §1211(a) of the Disasterb. §1211(a) of the Disaster Recovery Recovery Reform Act of 2018 (DRRA, P.L. 115-254). Prior to DRRA’sReform Act of 2018 (DRRA, P.L. 115-254). Prior to DRRA’s enactment enactment
the federal government both administered the federal government both administered and assumed the costs associated with IHP housing assistance. and assumed the costs associated with IHP housing assistance.
Post-DRRA, although the federal government is stil responsiblePost-DRRA, although the federal government is stil responsible for housing assistance costs, state, for housing assistance costs, state,
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territory, territory, and Indian tribal governments may elect to administer Directand Indian tribal governments may elect to administer Direct Temporary Housing Assistance and Temporary Housing Assistance and
Permanent Housing Construction. Permanent Housing Construction.
c. FEMA, c. FEMA, IAPPG, pp. 93-94. The State-Led Disaster, pp. 93-94. The State-Led Disaster Housing Task ForceHousing Task Force brings together federal, local,brings together federal, local, and and
state/territory/Indian tribal governments, state/territory/Indian tribal governments, as wel as well as private and nonprofit partners, to determineas private and nonprofit partners, to determine the scope the scope
of the disaster-caused housing needs and develop potential solutions (see the FEMAof the disaster-caused housing needs and develop potential solutions (see the FEMA IAPPG for specific State- for specific State-
Led DisasterLed Disaster Housing Task Force duties). Housing Task Force duties).
d. 44 C.F.R. d. 44 C.F.R. §206.120(b); FEMA, §206.120(b); FEMA, IAPPG, pp. 147-148; and FEMA, , pp. 147-148; and FEMA, Tribal Declarations Pilot Guidance,, pp. 22-23. The pp. 22-23. The
state, territory, state, territory, or Indian tribal government can selector Indian tribal government can select one of three options for the administration of ONA: one of three options for the administration of ONA:
(1) the FEMA Option; (2) the Joint Option; or (3) the State, Territorial,(1) the FEMA Option; (2) the Joint Option; or (3) the State, Territorial, or Indian Tribal Government or Indian Tribal Government
Option. Under the FEMA Option, FEMA is responsibleOption. Under the FEMA Option, FEMA is responsible for for al all tasks associated with the administration of tasks associated with the administration of
ONA. Under the State, Territorial,ONA. Under the State, Territorial, or Indian Tribal Government Option, FEMA provides ONA as a grant to or Indian Tribal Government Option, FEMA provides ONA as a grant to
the state, territory,the state, territory, or Indian tribal government, which administersor Indian tribal government, which administers ONA. Under the Joint Option, the state, ONA. Under the Joint Option, the state,
territory,territory, or Indian tribal government administersor Indian tribal government administers ONA jointly with FEMA, splitting responsibilitiesONA jointly with FEMA, splitting responsibilities for for
various administrativevarious administrative tasks (see Figure 30 in the tasks (see Figure 30 in the IAPPG for the list of ONA administration responsibilities). for the list of ONA administration responsibilities).
e. 42 U.S.C. e. 42 U.S.C. §5174(g)(1); 44 C.F.R. §206.110(i)(1); and FEMA, §5174(g)(1); 44 C.F.R. §206.110(i)(1); and FEMA, IAPPG, p. 5. , p. 5.
f. f.
42 U.S.C. 42 U.S.C. §5174(g)(2); 44 C.F.R. §206.110(i)(2); and FEMA, §5174(g)(2); 44 C.F.R. §206.110(i)(2); and FEMA, IAPPG, p. 5. Stafford Act Section 408(g)(2)(A) , p. 5. Stafford Act Section 408(g)(2)(A)
specifies specifies that “the Federal share that “the Federal share shal shall be 75 percent [emphasis added]” (42 U.S.C. §5174(g)(2)(A)). This be 75 percent [emphasis added]” (42 U.S.C. §5174(g)(2)(A)). This
framing indicates that the Stafford Act does not framing indicates that the Stafford Act does not al owallow the federal share for ONA to be the federal share for ONA to be ad justedadjusted (although (although
this may be done through legislation).this may be done through legislation). Additional y, Additionally, “the non-Federal share “the non-Federal share shal shall be paid from funds made be paid from funds made
available by the State [emphasisavailable by the State [emphasis added]” (42 U.S.C. §5174(g)(2)(B)). The nonfederal share of ONA is not added]” (42 U.S.C. §5174(g)(2)(B)). The nonfederal share of ONA is not
paid for by the individuals benefiting from the assistance. For contrast, the cost sharing provisionpaid for by the individuals benefiting from the assistance. For contrast, the cost sharing provision for Public for Public
AssistanceAssistance Category B—EmergencyCategory B—Emergency Protective Measures states “[t]he FederalProtective Measures states “[t]he Federal share of assistance under this share of assistance under this
section section shal shall be not less than 75 percent of the eligible 75 percent of the eligible cost of such assistance [emphasis added]” (42 U.S.C. cost of such assistance [emphasis added]” (42 U.S.C.
§5170b(b)), and FEMA has a regulation for increasing the Public Assistance§5170b(b)), and FEMA has a regulation for increasing the Public Assistance federal share for emergency federal share for emergency
work and permanent work (see 44 C.F.R. §206.47). work and permanent work (see 44 C.F.R. §206.47).
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Appendix C. Individual Assistance OpenFEMA
Datasets and Data Fields
OpenFEMA is “FEMA’s data delivery platform which provides data sets to the public in open, OpenFEMA is “FEMA’s data delivery platform which provides data sets to the public in open,
industry standard, machine-readable formats.”industry standard, machine-readable formats.”319315 FEMA’s OpenFEMA Datasets include FEMA’s OpenFEMA Datasets include
Individual Assistance (IA) information related to the Individuals and Households Program (IHP), Individual Assistance (IA) information related to the Individuals and Households Program (IHP),
including Housing Assistance and Other Needs Assistance (ONA). including Housing Assistance and Other Needs Assistance (ONA).
Specifical ySpecifically, FEMA provides several datasets, which provide publicly available, FEMA provides several datasets, which provide publicly available IA—IHP data:IA—IHP data:320
316 • Housing Assistance Program Data–Owners (according to FEMA’s description, Housing Assistance Program Data–Owners (according to FEMA’s description,
the data starts with disaster declaration DR-4116-IL, declared May 10, 2013); the data starts with disaster declaration DR-4116-IL, declared May 10, 2013);
Housing Assistance Program Data–Renters (according to FEMA’s description, Housing Assistance Program Data–Renters (according to FEMA’s description,
the data starts with disaster declaration DR-4116-IL, declared May 10, 2013); the data starts with disaster declaration DR-4116-IL, declared May 10, 2013);
Individuals and Households Program (IHP) Flood Damage; Individuals and Households Program (IHP) Flood Damage;
Individuals and Households Program—Valid Registrations (according to Individuals and Households Program—Valid Registrations (according to
FEMA’s FEMA’s description, the data starts with disaster declaration DR-1439-TX, description, the data starts with disaster declaration DR-1439-TX,
declared November 5, 2002); declared November 5, 2002);
Individual Assistance Housing Registrants—Large Disasters; and Individual Assistance Housing Registrants—Large Disasters; and
Registration Intake and Individuals Household Program (RI–IHP) (according to Registration Intake and Individuals Household Program (RI–IHP) (according to
FEMA’s description, the data starts with disaster declaration DR-4116-IL, FEMA’s description, the data starts with disaster declaration DR-4116-IL,
declared May 10, 2013).declared May 10, 2013).321317
Table C-1 includes a list of the data fields, with descriptions, associated with the provision of IHP includes a list of the data fields, with descriptions, associated with the provision of IHP
awards for each IA dataset. awards for each IA dataset.





319 315 FEMA, “ FEMA, “ OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets. OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets.
320316 In addition to datasets on the Individual Assistance program, FEMA’s OpenFEMA Data Sets also provide data on In addition to datasets on the Individual Assistance program, FEMA’s OpenFEMA Data Sets also provide data on
disaster declarations, emergency management, Public Assistance, Hazard Mitigation, the National Flood Insurance disaster declarations, emergency management, Public Assistance, Hazard Mitigation, the National Flood Insurance
Program, and other “miscellaneous” data on data visualizations and metadata. See FEMA, “Program, and other “miscellaneous” data on data visualizations and metadata. See FEMA, “ OpenFEMA Data Sets,” OpenFEMA Data Sets,”
https://www.fema.gov/about/openfema/data-sets. https://www.fema.gov/about/openfema/data-sets.
321 317 FEMA, “ FEMA, “ OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets. FEMA’s datasets include OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets. FEMA’s datasets include
descriptions of howdescriptions of how the data wasthe data was generated andgenerated and associated caveats, as wellassociated caveats, as well as descriptions of the data fields.as descriptions of the data fields.
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Table C-1. Data Fields Associated with Each IA OpenFEMA Dataset
✔ indicates a data field is provided for a dataset; ✔ indicates a data field is provided for a dataset; — indicates a data field is unavailable for a dataset. — indicates a data field is unavailable for a dataset.
Individuals
Individuals
Individual
Registration
Housing
HousingHousing Housing Individuals Individuals Individual Registration
Assistance Assistance
Assistance Assistance
and and
and and
Assistance Assistance
Intake and Intake and
Households Households
Households Households
Housing Housing
Individuals Individuals
Data Fields
Program Program
Program Program
Data— Data—
Data— Data—
Program Program
Program— Program—
Registrants— Registrants—
Household Household
Owners Owners
Renters Renters
(IHP) Flood (IHP) Flood
Valid Valid
Large Large
Program Program
Damage Damage
Registrations Registrations
Disasters Disasters
(RI–IHP) (RI–IHP)
Valid Valid
✔ ✔
✔ ✔
— —
— —
— —
✔ ✔
Registration Registrationsa
Average Average
✔ ✔
— —
— —
— —
— —
— —
FEMA FEMA
Inspected Inspected
DamagebDamageb
FEMA FEMA
✔ ✔
✔ ✔
— —
✔ ✔
✔ ✔
— —
Inspection Inspectionsc
Total FEMA Total FEMA
✔ ✔
— —
— —
✔ ✔
✔ ✔
— —
Inspected Inspected
DamagedDamaged
Ranges of Ranges of
✔ ✔
✔ ✔
— —
✔ ✔
✔ ✔
— —
FEMA FEMA
Inspected Inspected
DamageeDamagee
Eligible Eligible
✔ ✔
✔ ✔
✔ ✔
✔ ✔
— —
✔ ✔
and/or and/or
Approved for Approved for
IHP IHP
AssistancefAssistancef
Total IHP Total IHP
✔ ✔
✔ ✔
✔ ✔
✔ ✔
— —
✔ ✔
Amoun Amountg
Repair/ Repair/
✔ ✔
✔ ✔
— —
✔ ✔
✔ ✔
— —
Replace Replace
AmounAmounth
Rental Rental
✔ ✔
✔ ✔
— —
✔ ✔
✔ ✔
— —
Amoun Amounti
Personal Personal
— —
— —
— —
✔ ✔
— —
— —
Property Property
AmounAmountj
HA Amoun HA Amountk
— —
— —
— —
✔ ✔
— —
✔ ✔
ONA ONA
✔ ✔
✔ ✔
— —
✔ ✔
— —
✔ ✔
Amoun Amountl
Approved Approved
✔ ✔
✔ ✔
— —
— —
— —
— —
BetweenmBetweenm
Total Max Total Max
✔ ✔
✔ ✔
— —
✔ ✔
— —
— —
GrantsnGrantsn
Average Average
— —
— —
✔ ✔
— —
— —
— —
Award Award
AmounAmounto
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Individuals
Individuals
Individual
Registration
Housing
HousingHousing Housing Individuals Individuals Individual Registration
Assistance Assistance
Assistance Assistance
and and
and and
Assistance Assistance
Intake and Intake and
Households Households
Households Households
Housing Housing
Individuals Individuals
Data Fields
Program Program
Program Program
Data— Data—
Data— Data—
Program Program
Program— Program—
Registrants— Registrants—
Household Household
Owners Owners
Renters Renters
(IHP) Flood (IHP) Flood
Valid Valid
Large Large
Program Program
Damage Damage
Registrations Registrations
Disasters Disasters
(RI–IHP) (RI–IHP)
Flood Flood
— —
— —
— —
✔ ✔
— —
— —
Insurance Insurance
Premium Premium
AmounAmountp
Referral Referralsq
— —
— —
— —
✔ ✔
— —
✔ ✔
SBA SBA
— —
— —
— —
✔ ✔
— —
— —
ApprovedrApprovedr
Flood Flood
— —
— —
— —
✔ ✔
— —
— —
Damage Damage
AmounAmounts
Foundation Foundation
— —
— —
— —
✔ ✔
✔ ✔
— —
Damage Damage
AmounAmountt
Roof Damage Roof Damage
— —
— —
— —
✔ ✔
✔ ✔
— —
Amoun Amountu
Source: FEMA, “OpenFEMA Data Sets,” “Individual Assistance,”FEMA, “OpenFEMA Data Sets,” “Individual Assistance,” https://www.fema.gov/about/openfema/data-https://www.fema.gov/about/openfema/data-
sets#individual. sets#individual.
Notes: The data fields included in Table D-1 are current as of NovemberThe data fields included in Table D-1 are current as of November 10, 2021.10, 2021. Al All of the IA datasets, with of the IA datasets, with
the exception of the IHP Flood Damage dataset, include the disasterthe exception of the IHP Flood Damage dataset, include the disaster number, state, county, city, zip code, and a number, state, county, city, zip code, and a
unique ID assigned to the record.unique ID assigned to the record. The IHP Flood Damage dataset includes the disasterThe IHP Flood Damage dataset includes the disaster number and state, as number and state, as wel
well as the incident type. The Individuals and Households Program—Validas the incident type. The Individuals and Households Program—Valid Registrations (hereinafter IHP Valid Registrations (hereinafter IHP Valid
Registrations) dataset includes the incident type and declaration date. The Individual AssistanceRegistrations) dataset includes the incident type and declaration date. The Individual Assistance Housing Housing
Registrants—LargeRegistrants—Large Disasters Disasters is hereinafter referredis hereinafter referred to as “Housing Registrants—Largeto as “Housing Registrants—Large Disasters.”Disasters.”
a. a. Valid Registrations:: For For the the Housing Assistance Program Data—Owners and—and—Renters, and , and RI—IHP datasets, datasets,
Valid Registrations Valid Registrations refers refers to the “[c]ount of FEMA registration[s] . .to the “[c]ount of FEMA registration[s] . . within the state, county, zip where the within the state, county, zip where the
registrationregistration is valid. In order to be a valid registration,is valid. In order to be a valid registration, the applicant must be in an Individual Assistance the applicant must be in an Individual Assistance
declared state and county and have registereddeclared state and county and have registered within the FEMA designated registration period.” The within the FEMA designated registration period.” The RI—
IHP
dataset also includes the total numbers of valid registrations submitted through the dataset also includes the total numbers of valid registrations submitted through the cal call center, website, center, website,
and mobileand mobile devices devices (data fields are Valid Cal Center Registrations,(data fields are Valid Cal Center Registrations, Valid Web Registrations,Valid Web Registrations, and Valid and Valid
Mobile Registrations,Mobile Registrations, respectively). respectively).
b. b. Average FEMA Inspected Damage: For the : For the Housing Assistance Program Data—Owners dataset, Average dataset, Average
FEMA Inspected Damage refers FEMA Inspected Damage refers to the “[a]verage inspected damage (based on FEMA’s inspection guidelines) to the “[a]verage inspected damage (based on FEMA’s inspection guidelines)
for valid registrationfor valid registration owners within the state, county, zip that had a completedowners within the state, county, zip that had a completed inspection.” inspection.”
c. c. FEMA Inspections:: For the For the Housing Assistance Program Data—Owners andandRenters datasets, Total datasets, Total
Inspected refers Inspected refers to the “[t]otal FEMA applicants who receivedto the “[t]otal FEMA applicants who received an inspection.” For the an inspection.” For the IHP Valid Registrations
dataset, Inspection Issued address the question: “Has a FEMA inspection been issued to determinedataset, Inspection Issued address the question: “Has a FEMA inspection been issued to determine damage damage
amount?”; and Inspection Returned address the question: “Has a FEMA issued inspection been performed amount?”; and Inspection Returned address the question: “Has a FEMA issued inspection been performed
to determineto determine damage amount?” For the damage amount?” For the Housing Registrants—Large Disasters,, Inspected Indicator answersInspected Indicator answers the the
question: “Has the applicant been inspected by FEMA?” question: “Has the applicant been inspected by FEMA?”
d. d. Total FEMA Inspected Damage: For the : For the Housing Assistance Program Data—Owners dataset, Total dataset, Total
Damage refers Damage refers to the “[t]otal damage recorded by FEMA at the time of inspection.” For the to the “[t]otal damage recorded by FEMA at the time of inspection.” For the IHP Valid
Registrations
dataset, RPFVL refers dataset, RPFVL refers to the “FEMA-determined value of disaster-caused damage to real to the “FEMA-determined value of disaster-caused damage to real
property components, including floors,property components, including floors, wal s, walls, access roads and bridges, electrical,access roads and bridges, electrical, plumbing, HVAC,plumbing, HVAC, etc. etc.
Note: IHP does not address land damage”; and PPFVL refersNote: IHP does not address land damage”; and PPFVL refers to the “FEMA-determined value of disaster-to the “FEMA-determined value of disaster-
caused damage to personal property components, including appliances, furniture, etc. Note: IHP does not caused damage to personal property components, including appliances, furniture, etc. Note: IHP does not
address land damage.” For the address land damage.” For the Housing Registrants—Large Disasters,, RPFVL refersRPFVL refers to the “[r]eal property to the “[r]eal property
damage amount observed by FEMA.” damage amount observed by FEMA.”
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e. e. Ranges of FEMA Inspected Damage: For the : For the Housing Assistance Program Data—Owners dataset, there dataset, there
are different data fields related to the FEMA Inspected Damage associated with the “[c]ount of valid are different data fields related to the FEMA Inspected Damage associated with the “[c]ount of valid
registrationregistration owners within the state, county, zip that had a completedowners within the state, county, zip that had a completed inspection (based on FEMA’s inspection (based on FEMA’s
guidelines) where the inspected damage guidelines) where the inspected damage fel fell between” different dol ar amounts, including (1) No FEMA between” different dol ar amounts, including (1) No FEMA
Inspected Damage; (2) FEMA Inspected Damage between $1 and $10,000; (3) FEMA Inspected Damage Inspected Damage; (2) FEMA Inspected Damage between $1 and $10,000; (3) FEMA Inspected Damage
between $10,001 and $20,000; (4) FEMA Inspected Damage between $20,001 and $30,000; and (5) FEMA between $10,001 and $20,000; (4) FEMA Inspected Damage between $20,001 and $30,000; and (5) FEMA
Inspected Damage > $30,000. For the Inspected Damage > $30,000. For the Housing Assistance Program Data—Renters dataset, there are different dataset, there are different
data fieldsdata fields related to inspections for Renters. “Renters do not receiverelated to inspections for Renters. “Renters do not receive a ful home inspection as they are a ful home inspection as they are
only eligibleonly eligible for the itemsfor the items that they own. Instead a degree of damage is assigned. This is a count of valid that they own. Instead a degree of damage is assigned. This is a count of valid
registrationregistration renters who wererenters who were deemed to have had” the fol owing damage: (1) Inspected with No Damage; deemed to have had” the fol owing damage: (1) Inspected with No Damage;
(2) Total with Moderate Damage; (3) Total with Major Damage; and (4) Total with Substantial Damage.(2) Total with Moderate Damage; (3) Total with Major Damage; and (4) Total with Substantial Damage. For For
the the IHP Valid Registrations dataset, Renter Damage Leveldataset, Renter Damage Level refers refers to the “FEMA-determined levelto the “FEMA-determined level of damage to of damage to
a a dwel ingdwelling occupied by a renter. Minor, occupied by a renter. Minor, Moderate, Major, or Destroyed”; DestroyedModerate, Major, or Destroyed”; Destroyed addresses the addresses the
question: “Was the home destroyed by the disaster?” For the question: “Was the home destroyed by the disaster?” For the Housing Registrants—Large Disasters dataset, dataset,
DestroyedDestroyed addresses the question: “Is the structure permanently uninhabitable”? addresses the question: “Is the structure permanently uninhabitable”? Additional yAdditionally, for the , for the
Housing Registrants—LargeHousing Registrants—Large Disasters Disasters dataset, Renter Damage Leveldataset, Renter Damage Level refers refers to the “Levelto the “Level of Damage: of Damage:
Moderate, Major, Destroyed”;Moderate, Major, Destroyed”; and Personal Property Verified Lossand Personal Property Verified Loss refers refers to the “FEMA Verified Loss to the “FEMA Verified Loss
captured during the inspection of personal property.” captured during the inspection of personal property.”
f. f.
Eligible and/or Approved for IHP Assistance: For the : For the Housing Assistance Program Data—Owners and—and—
Renters datasets, Approved for FEMA Assistance refers datasets, Approved for FEMA Assistance refers to the “[n]umber of FEMA applicants who were to the “[n]umber of FEMA applicants who were
approved for FEMA’sapproved for FEMA’s IHP assistance.”IHP assistance.” For the For the IHP Flood Damage dataset, Total Registrations refers dataset, Total Registrations refers to “[t]he to “[t]he
Total (sum) number of disaster survivorTotal (sum) number of disaster survivor registrants awarded FEMA funds.” For the registrants awarded FEMA funds.” For the IHP Valid Registrations
dataset, IHP Eligible addressesdataset, IHP Eligible addresses the question: “Was the applicant eligiblethe question: “Was the applicant eligible for the Individual Housing Program for the Individual Housing Program
(IHP)? NOTE: Applicants that received(IHP)? NOTE: Applicants that received an HA and/or ONA award”; HA Eligiblean HA and/or ONA award”; HA Eligible addresses the question: addresses the question:
“Was the applicant eligible“Was the applicant eligible for the Housing Assistancefor the Housing Assistance program? NOTE: Doesprogram? NOTE: Does not include applicants not include applicants
licensed into Direct Housing that did not receivelicensed into Direct Housing that did not receive an HA award”; and ONA Eligiblean HA award”; and ONA Eligible addresses the question: addresses the question:
“Was the applicant eligible“Was the applicant eligible for the Other Needs Assistance (ONA) program?” For the for the Other Needs Assistance (ONA) program?” For the RI—IHP dataset, IHP dataset, IHP
Eligible refersEligible refers to the “[t]otal number of valid registrationsto the “[t]otal number of valid registrations eligible eligible for IHP assistance”; HA Eligible refersfor IHP assistance”; HA Eligible refers to to
the “[t]otal number of valid registrationsthe “[t]otal number of valid registrations eligible eligible for Housing Assistance (HA)”; and ONA Eligible refersfor Housing Assistance (HA)”; and ONA Eligible refers to to
the “[t]otal number of valid registrationsthe “[t]otal number of valid registrations eligible eligible for Other Needs Assistance (ONA).” for Other Needs Assistance (ONA).”
g. g. Total Approved IHP Amount:: For the For the Housing Assistance Program Data—Owners and—and—Renters datasets, datasets,
Total Approved IHP Amount refers Total Approved IHP Amount refers to the “[t]otal amount approved in dol arsto the “[t]otal amount approved in dol ars under FEMA’s IHP under FEMA’s IHP
program.” For the program.” For the IHP Valid Registrations dataset, Total Approved IHP Amount refers dataset, Total Approved IHP Amount refers to the “[t]otal financial to the “[t]otal financial
IHP award for Housing Assistance (HA) and/or Other Needs AssistanceIHP award for Housing Assistance (HA) and/or Other Needs Assistance (ONA), in U.S. dol ars.”(ONA), in U.S. dol ars.” For the For the
RI—IHP dataset, IHP Amount refers dataset, IHP Amount refers to the “[t]otal IHP Amount awarded in dol arsto the “[t]otal IHP Amount awarded in dol ars for Housing Assistance for Housing Assistance
(HA) and Other Needs Assistance (ONA) among eligible(HA) and Other Needs Assistance (ONA) among eligible applicants for designated incident.” For the applicants for designated incident.” For the IHP
Flood Damage
dataset, Total Award Amount refers dataset, Total Award Amount refers to “[t]he Total (sum) amount awarded for Home repair, to “[t]he Total (sum) amount awarded for Home repair,
replacementreplacement and personal property.” and personal property.”
h. h. Repair/ Replace Amount:: For the For the Housing Assistance Program Data—Owners and—and—Renters datasets, datasets,
Repair/Replace Amount refers Repair/Replace Amount refers to the “[t]otal amount of Repair and/or Replacement approved in dol ars for to the “[t]otal amount of Repair and/or Replacement approved in dol ars for
Housing AssistanceHousing Assistance (HA) under FEMA’s IHP program (note that renters are not eligible(HA) under FEMA’s IHP program (note that renters are not eligible for this type of for this type of
assistance because they do not own the structure).” For Renters, there is the caveat that they are ineligible assistance because they do not own the structure).” For Renters, there is the caveat that they are ineligible
for Home Repair/Replacementfor Home Repair/Replacement because they do not own the structure. Forbecause they do not own the structure. For the the IHP Valid Registrations and and
for the for the Housing Registrants—Large Disasters datasets, Repair Amount and Replacement Amount are separate datasets, Repair Amount and Replacement Amount are separate
data fields,data fields, where Repair Amount referswhere Repair Amount refers to the “[a]mount of Repair Assistanceto the “[a]mount of Repair Assistance awarded in U.S. dol ars”; and awarded in U.S. dol ars”; and
Replacement Amount refersReplacement Amount refers to the “[a]mount of Replacement Assistance awarded in U.S.to the “[a]mount of Replacement Assistance awarded in U.S. dol ars.” dol ars.”
i. i.
Rental Amount:: For the For the Housing Assistance Program Data––Owners and—and—Renters datasets, Rental Amount datasets, Rental Amount
refersrefers to the “[t]otal amount of Rental Assistanceto the “[t]otal amount of Rental Assistance approved in dol ars for Housing Assistanceapproved in dol ars for Housing Assistance (HA) under (HA) under
FEMA’s IHP program.” For the FEMA’s IHP program.” For the IHP Valid Registrations and for the and for the Housing Registrants—Large Disasters
datasets, Rental Assistancedatasets, Rental Assistance Amount refersAmount refers to the “[a]mount of Rental Assistance awarded in U.S. dol ars.” to the “[a]mount of Rental Assistance awarded in U.S. dol ars.”
j. j.
Personal Property Amount:: For the For the IHP Valid Registrations dataset, Personal Property Amount refers dataset, Personal Property Amount refers to to
the “[a]mount of ONA awarded for Personal Property Assistancethe “[a]mount of ONA awarded for Personal Property Assistance in U.S. dol ars.”in U.S. dol ars.”
k. k. HA Amount:: For the For the IHP Valid Registrations dataset, HA Amount refersdataset, HA Amount refers to the “[t]otal amount awarded for to the “[t]otal amount awarded for
Housing Assistance Housing Assistance under IHP.” For the under IHP.” For the RI—IHP dataset, HA Amount refersdataset, HA Amount refers to the “[t]otal amount to the “[t]otal amount
awarded for Housing Assistanceawarded for Housing Assistance (HA) in dol ars(HA) in dol ars from the Individual and Households Program (IHP)from the Individual and Households Program (IHP) .” .”
l. l.
ONA Amount:: For the For the Housing Assistance Program Data—Owners and—Renters,, and and IHP Valid Registrations
datasets Other Needs Amount refersdatasets Other Needs Amount refers to the “[t]otal amount of Other Needs (ONA) assistance approved in to the “[t]otal amount of Other Needs (ONA) assistance approved in
dol arsdol ars under FEMA’s IHP program (this could include, personal property, transportation, medical,under FEMA’s IHP program (this could include, personal property, transportation, medical, dental, dental,
funeral, essential tools,funeral, essential tools, moving/storage,moving/storage, miscel aneous miscellaneous and other needs).” For the and other needs).” For the RI—IHP dataset, ONA dataset, ONA
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Amount refers to the “[t]otal amount awarded in dol ars Amount refers to the “[t]otal amount awarded in dol ars for Other Needs Assistance (ONA) from the for Other Needs Assistance (ONA) from the
Individual and Households ProgramIndividual and Households Program (IHP).” (IHP).”
m. m. Approved Between:: For the For the Housing Assistance Program Data—Owners and—Renters datasets, there are datasets, there are
different data fields related to the “[c]ount of valid registration different data fields related to the “[c]ount of valid registration [owners or renters] within the state, county, [owners or renters] within the state, county,
zip that receivedzip that received a financial grant froma financial grant from FEMA that FEMA that fel fell between” different dol ar amounts, including (1) between” different dol ar amounts, including (1)
Approved between $1 and $10,000; (2) Approved between $10,001 and $25,000; and (3) Approved Approved between $1 and $10,000; (2) Approved between $10,001 and $25,000; and (3) Approved
between $25,001 and Max. between $25,001 and Max.
n. n. Total Max Grants: For the : For the Housing Assistance Program Data—Owners and—Renters datasets, Total Max datasets, Total Max
Grants refers Grants refers to the “[c]ount of valid registration [owners or renters] within the state, county, zip that to the “[c]ount of valid registration [owners or renters] within the state, county, zip that
receivedreceived the maximum financial grant from FEMA.” For the the maximum financial grant from FEMA.” For the IHP Valid Registrations dataset, the IHP Max dataset, the IHP Max
addressesaddresses the question: “[f]or disastersthe question: “[f]or disasters declared prior to August 1, 2017, did the applicant receivedeclared prior to August 1, 2017, did the applicant receive the the
maximummaximum IHP grant from FEMA?” It also includes the HA Max and ONA Max, which also relateIHP grant from FEMA?” It also includes the HA Max and ONA Max, which also relate to to
maximummaximum grants for Housing Assistance and ONA,grants for Housing Assistance and ONA, respectively,respectively, for disasters declared after August 1, 2017 for disasters declared after August 1, 2017
(which covers(which covers the period fol owing the enactment of the Disasterthe period fol owing the enactment of the Disaster Recovery ReformRecovery Reform Act of 2018, Section Act of 2018, Section
1212 of which separated the maximum1212 of which separated the maximum amount of financial assistance caps for Housing Assistanceamount of financial assistance caps for Housing Assistance and and
ONA). ONA).
o. o. Average Award Amount:: For the For the IHP Flood Damage dataset, Average dataset, Average Award Amount refersAward Amount refers to “[t]he to “[t]he
Average amount per Registrant awarded for Home repair, Average amount per Registrant awarded for Home repair, replacement replacement and personal property.” and personal property.”
p. p. Flood Insurance Premium Amount:: For the For the IHP Valid Registrations dataset, FIP Amount refers dataset, FIP Amount refers to “[t]he to “[t]he
amount of the applicant’s Flood Insurance Premium amount of the applicant’s Flood Insurance Premium (FIP) that was paid for by FEMA, in U.S.(FIP) that was paid for by FEMA, in U.S. dol ars.” dol ars.”
q. q. Referrals:: For the For the IHP Valid Registrations dataset, IHP Referred refersdataset, IHP Referred refers to the “IHP referralto the “IHP referral status NOTE: status NOTE:
Does not include applicants referred Does not include applicants referred to TSA only”; HA Referred addressesto TSA only”; HA Referred addresses the question: “Was the applicant the question: “Was the applicant
referredreferred to the Housing Assistance program?”; and ONA Referredto the Housing Assistance program?”; and ONA Referred addresses addresses the question: “Was the the question: “Was the
applicant referredapplicant referred to the Other Needs Assistance (ONA) program?” For the to the Other Needs Assistance (ONA) program?” For the RI—IHP dataset, IHP Referrals dataset, IHP Referrals
refersrefers to the “[c]umulative number of applicants referredto the “[c]umulative number of applicants referred to the IHP Program”; HA Referralsto the IHP Program”; HA Referrals refers refers to the to the
“[t]otal number of applications referred“[t]otal number of applications referred to the Housing Assistance (HA) Program”; and ONA Referrals to the Housing Assistance (HA) Program”; and ONA Referrals
refersrefers to the “[t]otal number of applications referredto the “[t]otal number of applications referred to the Other Needs Assistance (ONA) Program.” to the Other Needs Assistance (ONA) Program.”
r. r. SBA Approved: For the : For the IHP Valid Registrations dataset, SBA Approved addresses dataset, SBA Approved addresses the question: “Is applicant the question: “Is applicant
approved for a approved for a Smal Business Administration Small Business Administration loan? Approval does not equate to acceptance of the loan as loan? Approval does not equate to acceptance of the loan as
one can be approved, but not accept.” one can be approved, but not accept.”
s. s. Flood Damage Amount:: For the For the IHP Valid Registrations dataset, Flood Damage Amount refers dataset, Flood Damage Amount refers to the to the
“FEMA-determined amount of damage to real and personal property due to flood damage, in U.S. “FEMA-determined amount of damage to real and personal property due to flood damage, in U.S. dol ars.” dol ars.”
t. t.
Foundation Damage Amount:: For the For the IHP Valid Registrations dataset, Foundation Damage Amount dataset, Foundation Damage Amount
refersrefers to the “[a]mount of damage reportedto the “[a]mount of damage reported to the foundation of the damage to the foundation of the damage dwel ing, dwelling, in U.S. dol ars.”in U.S. dol ars.” For For
the the Housing Registrants—Large Disasters dataset, Foundation Damage Amount refersdataset, Foundation Damage Amount refers to the “[f]oundation to the “[f]oundation
damage amount observed by FEMA.” damage amount observed by FEMA.”
u. u. Roof Damage Amount: For the : For the IHP Valid Registrations dataset, Roof Damage Amount refers dataset, Roof Damage Amount refers to the to the
“[a]mount of damage reported to the damaged “[a]mount of damage reported to the damaged dwel ing’s dwelling’s roof, in U.S. dol ars.”roof, in U.S. dol ars.” For the For the Housing
Registrants—Large Disasters
dataset, Roof Damage Amount refers dataset, Roof Damage Amount refers to “[r]oof damage amount observed by to “[r]oof damage amount observed by
FEMA.” FEMA.”
The Individuals and Households Program–Valid Registrations (IHP Valid The Individuals and Households Program–Valid Registrations (IHP Valid Registrations) and the Registrations) and the
Individual Assistance Housing Registrants–Large Disasters (Housing Registrants—Large Individual Assistance Housing Registrants–Large Disasters (Housing Registrants—Large
Disasters) datasets include detailed applicant information, including with regard toDisasters) datasets include detailed applicant information, including with regard to:
applicant age (IHP Valid applicant age (IHP Valid Registrations); Registrations);
household composition (i.e., the number of individuals living in the household) household composition (i.e., the number of individuals living in the household)
(IHP Valid (IHP Valid Registrations and Housing Registrants—Large Disasters); Registrations and Housing Registrants—Large Disasters);
occupant(s) age(s) (i.e., the number of occupants under 2 years of age; between 2 occupant(s) age(s) (i.e., the number of occupants under 2 years of age; between 2
and 5 years of age; between 6 and 18 years of age; between 19 and 64 years of and 5 years of age; between 6 and 18 years of age; between 19 and 64 years of
age; and over the age of 65) (IHP Validage; and over the age of 65) (IHP Valid Registrations); Registrations);
gross income (IHP Valid Registrations and Housing Registrants—Large gross income (IHP Valid Registrations and Housing Registrants—Large
Disasters); Disasters);
whether the applicant is an owner or renter of the damaged whether the applicant is an owner or renter of the damaged dwel ingdwelling (IHP Valid (IHP Valid
Registrations and Housing Registrants—Large Disasters); Registrations and Housing Registrants—Large Disasters);
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whether the damaged whether the damaged dwel ingdwelling is the applicant’s primary residence (IHP Valid is the applicant’s primary residence (IHP Valid
Registrations and Housing Registrants—Large Disasters); Registrations and Housing Registrants—Large Disasters);
the damaged the damaged dwel ingdwelling residence type (e.g., single-family home, apartment) (IHP residence type (e.g., single-family home, apartment) (IHP
Valid Valid Registrations and Housing Registrants—Large Disasters); Registrations and Housing Registrants—Large Disasters);
whether the applicant has homeowner’s insurance (IHP Valid Registrations and whether the applicant has homeowner’s insurance (IHP Valid Registrations and
Housing Registrants—Large Disasters); Housing Registrants—Large Disasters);
whether the applicant has flood insurance (IHP Valid whether the applicant has flood insurance (IHP Valid Registrations and Housing Registrations and Housing
Registrants—Large Disasters); and Registrants—Large Disasters); and
the registration method (e.g., telephone, mobile application) (IHP Valid the registration method (e.g., telephone, mobile application) (IHP Valid
Registrations). Registrations).322318
The Individuals and Households Program–Valid Registrations (IHP Valid The Individuals and Households Program–Valid Registrations (IHP Valid Registrations) and the Registrations) and the
Individual Assistance Housing Registrants–Large Disasters (Housing Registrants—Large Individual Assistance Housing Registrants–Large Disasters (Housing Registrants—Large
Disasters) datasets also include data fields to account for applicant-reported needs, as Disasters) datasets also include data fields to account for applicant-reported needs, as fol ows:
follows: • utilities utilities are out of service (IHP Validare out of service (IHP Valid Registrations); Registrations);
home damage (IHP Valid home damage (IHP Valid Registrations); Registrations);
whether habitability repairs are required (IHP Valid whether habitability repairs are required (IHP Valid Registrations and Housing Registrations and Housing
Registrants—Large Disasters); Registrants—Large Disasters);
automobile(s) damage (IHP Valid automobile(s) damage (IHP Valid Registrations); Registrations);
emergency items needs (IHP Valid Registrations); emergency items needs (IHP Valid Registrations);
food needs (IHP Valid food needs (IHP Valid Registrations); Registrations);
shelter needs (IHP Valid shelter needs (IHP Valid Registrations); and Registrations); and
accommodations requirements for the applicant’s access or functional needs (IHP accommodations requirements for the applicant’s access or functional needs (IHP
Valid Valid Registrations and Housing Registrants—Large Disasters).Registrations and Housing Registrants—Large Disasters).323319
Further, the Individuals and Households Program–Valid Registrations (IHP Valid Further, the Individuals and Households Program–Valid Registrations (IHP Valid Registrations) Registrations)
and the Individual Assistance Housing Registrants–Large Disasters (Housing Registrants—Large and the Individual Assistance Housing Registrants–Large Disasters (Housing Registrants—Large
Disasters) datasets also include data fields that provide detailed information about specific Disasters) datasets also include data fields that provide detailed information about specific
damage to the property, includingdamage to the property, including:
the water level (i.e., depth of water that affected the damaged the water level (i.e., depth of water that affected the damaged dwel ingdwelling) (IHP ) (IHP
Valid Valid Registrations and Housing Registrants—Large Disasters); Registrations and Housing Registrants—Large Disasters);
high-water mark location (IHP Valid high-water mark location (IHP Valid Registrations); Registrations);
whether flood damage was recorded (IHP Valid Registrations); whether flood damage was recorded (IHP Valid Registrations);

322 FEMA, “ • whether there is damage to the foundation (IHP Valid Registrations and Housing Registrants—Large Disasters); and 318 FEMA, “OpenFEMA Dataset: Individuals and HouseholdsOpenFEMA Dataset: Individuals and Households Program-ValidProgram-Valid Registrations,” v1, last data refresh Registrations,” v1, last data refresh
November 6, 2021, https://www.fema.gov/openfema-data-page/individuals-and-households-program-valid-November 6, 2021, https://www.fema.gov/openfema-data-page/individuals-and-households-program-valid-
registrations-v1; and FEMA “registrations-v1; and FEMA “ OpenFEMA Dataset: Individual Assistance HousingOpenFEMA Dataset: Individual Assistance Housing Registrants-Large Disasters,” v1, Registrants-Large Disasters,” v1,
last data refresh November 8, 2021, https://www.fema.gov/openfema-data-page/individual-assistance-housing-last data refresh November 8, 2021, https://www.fema.gov/openfema-data-page/individual-assistance-housing-
registrants-large-disasters-v1. registrants-large-disasters-v1.
323319 FEMA, “ FEMA, “ OpenFEMA Dataset: Individuals and HouseholdsOpenFEMA Dataset: Individuals and Households Program-ValidProgram-Valid Registrations,” v1, last data refresh Registrations,” v1, last data refresh
November 6, 2021, https://www.fema.gov/openfema-data-page/individuals-and-households-program-valid-November 6, 2021, https://www.fema.gov/openfema-data-page/individuals-and-households-program-valid-
registrations-v1; and FEMA “registrations-v1; and FEMA “ OpenFEMA Dataset: Individual Assistance HousingOpenFEMA Dataset: Individual Assistance Housing Registrants-Large Disasters,” v1, Registrants-Large Disasters,” v1,
last data refresh November 8, 2021, https://www.fema.gov/openfema-data-page/individual-assistance-housing-last data refresh November 8, 2021, https://www.fema.gov/openfema-data-page/individual-assistance-housing-
registrants-large-disasters-v1. registrants-large-disasters-v1. T heThe IHP Valid Registrations dataset also includes IHP Valid Registrations dataset also includes the most recent Housing Assistance the most recent Housing Assistance
decision (the data fielddecision (the data field for which is HA Status). for which is HA Status).
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whether there is damage to the whether there is damage to the foundation (IHP Valid Registrations and Housing
Registrants—Large Disasters); and
 whether there is damage to the roof (IHP Valid roof (IHP Valid Registrations and Housing Registrations and Housing
Registrants—Large Disasters). Registrants—Large Disasters).324
Final y320 Finally, the Individuals and Households Program–Valid Registrations (IHP Valid, the Individuals and Households Program–Valid Registrations (IHP Valid Registrations) Registrations)
and the Individual Assistance Housing Registrants–Large Disasters (Housing Registrants—Large and the Individual Assistance Housing Registrants–Large Disasters (Housing Registrants—Large
Disasters) datasets also include data fields on select forms of IHP assistance for which applicants Disasters) datasets also include data fields on select forms of IHP assistance for which applicants
are found eligible,are found eligible, including applicant eligibilityincluding applicant eligibility for the following programs: for the following programs:
Transitional Sheltering Assistance (TSA) program (and whether the applicant Transitional Sheltering Assistance (TSA) program (and whether the applicant
checked into a TSA property) (IHP Valid checked into a TSA property) (IHP Valid Registrations and Housing Registrations and Housing
Registrants—Large Disasters); Registrants—Large Disasters);
Rental Assistance (IHP Valid Rental Assistance (IHP Valid Registrations and Housing Registrants—Large Registrations and Housing Registrants—Large
Disasters) (and the Rental Assistance end date, and rental resource city, state, and Disasters) (and the Rental Assistance end date, and rental resource city, state, and
zip code in the case of Housing Registrants—Large Disasters); zip code in the case of Housing Registrants—Large Disasters);
Repair Assistance (IHP Valid Repair Assistance (IHP Valid Registrations and Housing Registrants—Large Registrations and Housing Registrants—Large
Disasters); Disasters);
Personal Property Assistance (IHP Valid Registrations and Housing Registrants— Personal Property Assistance (IHP Valid Registrations and Housing Registrants—
Large Disasters); and Large Disasters); and
SBA Disaster Loan (Housing Registrants—Large Disasters). SBA Disaster Loan (Housing Registrants—Large Disasters).325321


Author Information

Elizabeth M. Webster Elizabeth M. Webster

Analyst in Emergency Management and Disaster Analyst in Emergency Management and Disaster
Recovery Recovery


Acknowledgments
Brion Long, Visual Information Specialist, developed the figures for this report.Brion Long, Visual Information Specialist, developed the figures for this report.
Ben Harrington, Legislative Attorney; Katie Jones, Analyst in Housing Policy; Erica A. Lee, Ben Harrington, Legislative Attorney; Katie Jones, Analyst in Housing Policy; Erica A. Lee,
Analyst in Emergency Management and Disaster Recovery; Bruce R. Lindsay, Specialist in Analyst in Emergency Management and Disaster Recovery; Bruce R. Lindsay, Specialist in

324 FEMA, “ American National Government; and Daniel J. Sheffner, Legislative Attorney, provided editorial comments and suggestions. 320 FEMA, “OpenFEMA Dataset: Individuals and HouseholdsOpenFEMA Dataset: Individuals and Households Program-ValidProgram-Valid Registrations,” v1, last data refresh Registrations,” v1, last data refresh
November 6, 2021, https://www.fema.gov/openfema-data-page/individuals-and-households-program-valid-November 6, 2021, https://www.fema.gov/openfema-data-page/individuals-and-households-program-valid-
registrations-v1; and FEMA “registrations-v1; and FEMA “ OpenFEMA Dataset: Individual Assistance HousingOpenFEMA Dataset: Individual Assistance Housing Registrants-Large Disasters,” v1, Registrants-Large Disasters,” v1,
last data refresh November 8, 2021, https://www.fema.gov/openfema-data-page/individual-assistance-housing-last data refresh November 8, 2021, https://www.fema.gov/openfema-data-page/individual-assistance-housing-
registrants-large-disasters-v1. registrants-large-disasters-v1.
325321 FEMA, “ FEMA, “ OpenFEMA Dataset: Individuals and HouseholdsOpenFEMA Dataset: Individuals and Households Program-ValidProgram-Valid Registrations,” v1, last data refresh Registrations,” v1, last data refresh
November 6, 2021, https://www.fema.gov/openfema-data-page/individuals-and-households-program-valid-November 6, 2021, https://www.fema.gov/openfema-data-page/individuals-and-households-program-valid-
registrations-v1; and FEMA “registrations-v1; and FEMA “ OpenFEMA Dataset: Individual Assistance HousingOpenFEMA Dataset: Individual Assistance Housing Registrants-Large Disasters,” v1, Registrants-Large Disasters,” v1,
last data refresh November 8, 2021, https://www.fema.gov/openfema-data-page/individual-assistance-housing-last data refresh November 8, 2021, https://www.fema.gov/openfema-data-page/individual-assistance-housing-
registrants-large-disasters-v1. registrants-large-disasters-v1.
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American National Government; and Daniel J. Sheffner, Legislative Attorney, provided editorial
comments and suggestions.
Shel eyShelley Harlan, Editor, helped edit the report text and footnotes. Harlan, Editor, helped edit the report text and footnotes.
James M. Specht, Section Research Manager, and Lauren R. Stienstra, Section Research James M. Specht, Section Research Manager, and Lauren R. Stienstra, Section Research
Manager, provided structural and editorial comments and suggestions. Manager, provided structural and editorial comments and suggestions.


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