FEMA’s Individuals and Households Program
May 15, 2023
(IHP)—Implementation and Considerations for Elizabeth M. Webster
Congress
Analyst in Emergency
Management and Disaster
The Federal Emergency Management Agency (FEMA) may provide several forms of federal
Recovery
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.
93-288, as amended; codified at 42 U.S.C. §§5121 et seq.), including assistance for individuals

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
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 FEMA assistance authorized pursuant to an emergency or major
disaster declaration, 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 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 assistance. Specifically, this report describes the categories and types of available IHP Housing Assistance
and Other Needs 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 recovery from recent disasters, including the Coronavirus Disease 2019 (COVID-19) pandemic.
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
declare an emergency or major disaster and that IA be authorized. When making such a request, the state, territory, or Indian
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
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
enactment of the Disaster Recovery Reform Act of 2018 (DRRA, Division D of P.L. 115-254), a new rule going into effect
(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 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
considered when determining whether to authorize IA (and specifically IHP assistance), and significant program
implementation updates and considerations.
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
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
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
has hindered access to disaster assistance for some individuals.

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

Introduction
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
Management Agency (FEMA) may provide three primary forms of disaster assistance: Individual
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
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
Training Program;3 Disaster Unemployment Assistance;4 Disaster Legal Services;5 and Disaster
Case Management,6 all 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
The IHP is the focus of this report. It is the only form of IA, and the only FEMA assistance
authorized pursuant to an emergency or major disaster declaration, that provides grants of
financial assistance directly to individuals 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 begins with an overview of the IHP, including the categories and
types of IHP assistance that may be made available, selected considerations or limitations
associated with each type of assistance, and selected legislative 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 chief executive’s request for a major disaster declaration

1 Disaster Relief Act of 1974 (P.L. 93-288) (retitled the Robert T. Stafford Disaster Relief and Emergency Assistance
Act and codified, as amended, at 42 U.S.C. §§5121 et seq.). The Robert T. Stafford Disaster Relief and Emergency
Assistance Act is hereinafter referred to as the Stafford Act. The Federal Emergency Management Agency’s (FEMA’s)
“How a Disaster Gets Declared” web page, available at https://www.fema.gov/disasters/how-declared, provides
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, “How a Disaster Gets Declared”). The
Individual Assistance (IA) program, and specifically the Individuals and Households Program (IHP), is the focus of this
report. For information on FEMA’s other programs, including the Public Assistance (PA) program, which may provide
grants to sub-federal governments and certain private nonprofit organizations for emergency work following an
emergency or major disaster declaration, and permanent work following a major disaster declaration, see CRS In Focus
IF11529, A Brief Overview of FEMA’s Public Assistance Program, by Erica A. Lee, and CRS Report R46749, FEMA’s
Public Assistance Program: A Primer and Considerations for Congress, by Erica A. Lee. For additional information on
FEMA’s Hazard Mitigation Assistance (HMA) funds for mitigation and resiliency projects and programs to reduce the
threat or impacts of future disasters, see CRS Insight IN11187, Federal Emergency Management Agency (FEMA)
Hazard Mitigation Assistance, by Diane P. Horn.
2 Stafford Act Section 408—Federal Assistance to Individuals and Households (hereinafter referred to as the IHP)—is
codified at 42 U.S.C. §5174 and the citation to the U.S. Code is used hereinafter. IHP assistance may be authorized
pursuant to either an emergency or major disaster declaration.
3 Stafford Act Section 416, 42 U.S.C. §5183.
4 Stafford Act Section 410, 42 U.S.C. §5177.
5 Stafford Act Section 415, 42 U.S.C. §5182.
6 Stafford Act Section 426, 42 U.S.C. §5189d.
7 These other forms of IA, with the exception of Crisis Counseling, may only be authorized pursuant to a major disaster
declaration. 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 Fund (DRF) and available funding. See
FEMA, “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 CRS Report R45484, The Disaster Relief Fund:
Overview and Issues, by William L. Painter.
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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,
eligibility requirements, and how assistance decisions may be appealed, is also included. This
report concludes by describing some of the IHP’s general program limitations, as well as selected
challenges and considerations that may be 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 disaster survivors. Additionally, Appendix B details
the roles of the state/territory and federal government in providing IHP assistance, and Appendix
C provides an overview of FEMA’s publicly available IHP program data.

Selected Definitions
State: Per Stafford Act Section 102(4), the term “state” means “any State of the United States, the District of
Columbia, Puerto Rico, the Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern
Mariana Islands” (42 U.S.C. §5122(4)).
Governor: Per Stafford Act Section 102(5), the term “governor” means “the chief executive of any State” (42
U.S.C. §5122(5)).
Indian Tribal Government: Per Stafford Act Section 102(6), the term “Indian tribal government” means “the
governing body of any Indian or Alaska Native tribe, band, nation, pueblo, vil age, or community that the Secretary
of the Interior acknowledges to exist as an Indian tribe under the Federally Recognized Indian Tribe List Act of
1994 (25 U.S.C. §§479a et seq.)” (42 U.S.C. §5122(6)).
Chief Executive: Per Stafford Act Section 102(12), the term “Chief Executive” means “the person who is the
Chief, Chairman, Governor, President, or similar executive official of an Indian tribal government” (42 U.S.C.
§5122(12)).
Uninhabitable: FEMA’s IAPPG defines “uninhabitable” as “a dwelling that is not safe, sanitary, or fit to occupy”
(FEMA, IAPPG, p. 78).
Safe: FEMA’s IAPPG defines “safe” as being secure from disaster-caused hazards or threats to occupants (FEMA,
IAPPG, p. 78).
Sanitary: FEMA’s IAPPG defines “sanitary” as being free of disaster-caused health hazards (FEMA, IAPPG, p. 78).
Functional: FEMA also requires that disaster-damaged components be functional prior to the disaster.
“‘Functional’ refers to an item or home capable of being used for its intended purpose” (FEMA, IAPPG, 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. §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
(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
Emergency Declarations Authorizing IA
authorize the IHP10 and allow FEMA to
The President may declare an emergency under the
provide financial and/or direct assistance
Stafford Act when federal assistance is necessary to save
for housing, as well as financial assistance
lives and protect public health and safety. Although the
for other needs (referred to as Other Needs
President may authorize IA pursuant to an emergency or
major disaster declaration, the IHP is one of only two
Assistance or ONA) to eligible individuals
forms of IA that may be authorized pursuant to an
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 times since 1985. Most recently, the Florida Surfside
safe to occupy12 or replacing standard
Building 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 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 was added on May 1,
condition. As such, per FEMA’s guidance,
2013, and Connecticut received 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
January 1, 1985 to December 6, 2021.
Section 408—Federal Assistance to
(FEMA, “Florida Surfside Building Col apse (3560-EM-FL),”
Individuals and Households.15 The
https://www.fema.gov/disaster/3560; FEMA, “Texas
subcategories of Housing Assistance and
Explosion (EM-3363-TX),” https://www.fema.gov/disaster/
3363; FEMA, “Connecticut Hurricane Irene (EM-3331-
ONA, as well as the types of IHP
CT),” https://www.fema.gov/disaster/3331; email
assistance under each subcategory, are
correspondence from FEMA Congressional Affairs staff,
listed in Table 1.
December 6, 2021).

10 42 U.S.C. §5174; 44 C.F.R. §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,
https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf (hereinafter FEMA, IAPPG). In March 2019,
FEMA released updated guidance to serve as a comprehensive IA program policy resource: the Individual Assistance
Program and Policy Guide (IAPPG) applies to emergencies and disasters declared on or after March 1, 2019. It was
subsequently updated in May 2021, and Version 1.1 applies to incidents declared on or after May 26, 2021. The IAPPG
includes a chapter dedicated to IHP implementation and administration. Prior to the release of the IAPPG, the
Individuals and Households Program Unified Guidance (IHPUG) served as the policy guide for the IHP. The IHPUG
applies to incidents declared on or after September 26, 2016, through February 28, 2019. For additional information on
FEMA’s Individual Assistance (IA) program, see CRS In Focus IF11298, A Brief Overview of FEMA’s Individual
Assistance Program, by Elizabeth M. Webster.
11 42 U.S.C. §5174; 44 C.F.R. §206.110(a); and FEMA, IAPPG, p. 41.
12 FEMA, IAPPG, p. 85.
13 FEMA, IAPPG, p. 167.
14 FEMA, IAPPG, pp. 6 and 41.
15 42 U.S.C. §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
Multi-Family Lease and
Personal Property
Funeral Assistance
Reimbursement
Repair
Assistance
Medical and Dental
Rental Assistance
Transportable Temporary
Transportation Assistance Assistance
Home Repair Assistance
Housing Units
Group Flood Insurance
Childcare Assistance
Home Replacement
Direct Lease
Policy
Assistance for
Assistance
Permanent Housing
Miscellaneous Items
Construction
Moving and Storage
Assistance
Critical Needs Assistance
Clean and Sanitize
Assistance
Sources: CRS’s interpretation of “Figure 5: Housing Assistance” and “Figure 28: Other Needs Assistance, Non-
SBA-Dependent and SBA-Dependent” of the FEMA, Individual Assistance Program and Policy Guide (IAPPG), 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;
and Memorandum from Keith Turi, FEMA Assistant Administrator, Recovery Directorate to FEMA Regional
Administrators, “RE: Amendment to FP 104-009-03, Individual Assistance Program and Policy Guide, Version
1.1,” September 2, 2021, pp. 11-12, https://www.fema.gov/sites/default/files/documents/fema_iappg-policy-
amendments-memo.pdf.
Notes: The different types of Housing Assistance may constitute either financial or direct assistance; however,
all types of Other Needs Assistance (ONA) are forms of financial assistance. The term “SBA” refers to the Small
Business Administration.
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 for SBA-Dependent ONA is determined by
FEMA in col aboration with SBA (see 42 U.S.C. §5174(e); and 44 C.F.R. §206.119).
b. Non-SBA-Dependent ONA may be awarded regardless of the individual or household’s SBA disaster loan
status (see 42 U.S.C. §5174(e); and 44 C.F.R. §206.119).
More detailed descriptions of these IHP assistance options, as well as programmatic changes
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.
Housing Assistance
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
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 IAPPG guidance, the appropriate type of
housing assistance depends on considerations of “cost effectiveness, convenience to the
individuals and households and the suitability and availability of the types of assistance.”16 Other
relevant considerations relate to the individual or household’s “disaster-caused losses, access to
life-sustaining services, cost-effectiveness, and other factors.”17

16 44 C.F.R. §206.110(c).
17 FEMA, IAPPG, p. 43. See 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 guidance may include “basic social
services, access to transportation, police/fire protection, emergency/health care services, communications, utilities,
grocery stores, child care, and educational institutions” (FEMA, IAPPG, p. 117). According to its guidance, “FEMA
(continued...)
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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
Rental Assistance program to temporarily rent alternative accommodations while repairs are
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
arrangements (e.g., if they are members of a family, roommates, or boarders).19)
FEMA first looks to provide financial assistance such
Defining “Cost Share”
as Rental Assistance and Repair Assistance before
A cost share includes the portions of a federal
providing other types of housing assistance.20 In
assistance program borne by the federal
some cases, FEMA may authorize a state, territory, or
government and a nonfederal entity (2 C.F.R.
Indian tribal government’s request for Direct
§§200.29 and 200.306). The nonfederal entity
may contribute cash or use third party in-kind
Housing Assistance when eligible applicants are
contributions to meet its portion of the cost
unable to use Rental Assistance because affordable
share (per the criteria in 2 C.F.R. §200.306).
housing resources are unavailable.21
By statute, the federal government pays 100%
The federal share of the costs of IHP Housing
of the cost associated with providing IHP
Housing Assistance. The federal government
Assistance is 100%.22
pays 75% of the cost associated with providing
IHP ONA, and the nonfederal share of ONA is
Financial Housing Assistance
paid from funds made available by the state,
territory, or Indian tribal government (42
Financial Housing Assistance is a grant provided
U.S.C. §5174(g); and 44 C.F.R. §206.110(i)).
directly to the individual or household by FEMA,
Although the Stafford Act does not provide the
and includes funding for temporary lodging expenses
authority to adjust the federal share of ONA
(i.e., Lodging Expense Reimbursement (LER)),
(42 U.S.C. §5174(g)(2)), FEMA may waive or
adjust the cost share for disaster grants in
rental of temporary housing (i.e., Rental Assistance),
insular areas such as the Virgin Islands, Guam,
and to repair or replace a damaged primary residence
American Samoa, and the Northern Mariana
(i.e., Repair Assistance and Replacement Assistance,
Islands (48 U.S.C. §1469a).

will not provide Direct Temporary Housing Assistance in locations where disaster survivors will not have access to
wrap-around services” (FEMA, IAPPG, p. 117). For example, this applies to FEMA’s evaluation of Multi-Family
Lease and Repair (MLR) properties (FEMA, IAPPG, p. 110), as well as site selection for Transportable Temporary
Housing Units (TTHUs) (FEMA, IAPPG, pp. 114 and 116).
18 42 U.S.C. §5174(b) and (c); 44 C.F.R. §206.110(c); and FEMA, IAPPG, pp. 78 and 93. FEMA’s IAPPG defines
“uninhabitable” as “a dwelling that is not safe, sanitary, or fit to occupy.” (FEMA, IAPPG, p. 78).
19 FEMA, IAPPG, pp. 57-62. Per FEMA’s guidance, “Generally, FEMA provides all eligible IHP awards under only
the head of household’s application to assist all members of the pre-disaster household. Only the head of household
will be eligible for additional categories of IHP assistance” (FEMA, IAPPG, p. 57).
20 44 C.F.R. §206.110(c). FEMA’s Financial Housing Assistance programs can be implemented using existing
resources (e.g., Rental Assistance can help a household temporarily rent available alternative accommodations), but
FEMA’s Direct Housing Assistance programs require 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
needed repairs or improvements to ensure accessibility).
21 FEMA, IAPPG, p. 94. Direct Temporary Housing Assistance may be approved if the following three factors have
been verified, per FEMA’s IAPPG: (1) a lack of available housing prevents eligible applicants from making use of
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) will be insufficient to meet the disaster-caused housing needs; and
(3) assistance from providers, including other federal and nonfederal government sources, as well as nonprofit and
voluntary organizations, is insufficient to meet eligible applicants’ disaster-caused temporary housing needs.
22 42 U.S.C. §5174(g)(1); 44 C.F.R. §206.110(i)(1); and FEMA, IAPPG, p. 5. For more information on cost shares, see
CRS Report R41101, FEMA Disaster Cost-Shares: Evolution and Analysis, by Natalie Keegan and Elizabeth M.
Webster.
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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
Lodging Expense Reimbursement (LER)
LER provides 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
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
approved date of an Initial Rental Assistance award (unless an extension is authorized); and (2)
expenses incurred during mandatory evacuations are not reimbursable.25
Rental Assistance
Rental Assistance provides funding to applicants to
Defining “Fair Market Rent”
rent alternative temporary housing
44 C.F.R. §206.111 defines Fair Market Rent
accommodations (including funding for monthly
(FMR) as “housing market-wide estimates of
rent, essential utilities, and a security deposit)
rents that provide opportunities to rent standard
while the applicant is displaced from their primary
quality housing throughout the geographic area in
which rental housing units are in competition.
residence because it is uninhabitable, inaccessible,
The fair market rent rates applied are those
affected by a utility outage, or unavailable. FEMA
identified by the Department of Housing and
may provide up to two months of Initial Rental
Urban Development as being adequate for
Assistance. Awards are based on (1) the number of
existing rental housing in a particular area.”
required bedrooms, as established by the U.S.
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
individual/household is renting in the same area or an area with higher rental costs.26
Unlike 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
rate 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, IAPPG, pp. 43 and 78.
24 The FEMA IAPPG, beginning on page 78, lists additional conditions of applicant eligibility, eligible expenses,
required documentation, program limitations and exclusions, and exceptions for each type of Financial Housing
Assistance.
25 FEMA, IAPPG, pp. 78-79.
26 FEMA, IAPPG, p. 80. The FEMA IAPPG states “FEMA uses the applicable [FMR] rate based upon the location of
the housing unit, the number of bedrooms in the housing unit, and the fiscal year in which the major disaster
declaration was issued.” (FEMA, IAPPG, p. 109 (see “Fair Market Rent (FMR)” text box).) FEMA uses its FMR
Calculator to evaluate the need for a Rental Assistance rate increase, and may authorize a rate increase “when the FMR
Calculator demonstrates available housing for the area is insufficient to meet the disaster-caused housing need, or when
elevated housing market rates adversely impact eligible applicants’ ability to obtain rental resources” (FEMA, IAPPG,
p. 85). HUD’s Office of Policy Development and Research (PD&R) posts FMR information at
https://www.huduser.gov/portal/datasets/fmr.html.
27 FEMA, IAPPG, p. 81. Applicants for Continued Temporary Housing Assistance must submit an application for
continued assistance, along with supporting documentation. They must have a continuing need for assistance and must
be unable to return to their pre-disaster residence, and adequate alternate housing must be unavailable or they must not
have fulfilled their permanent housing plan through no fault of their own. 44 C.F.R. §206.114 includes the criteria for
continued assistance.
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assistance, whichever comes first,” unless the period of assistance is extended.28 In addition,
applicants can receive an additional month of rent when used for a security deposit.29
Home Repair Assistance
Home Repair Assistance provides funding to
Maximum IHP Housing Award
homeowners to repair an owner-occupied primary
In FY2023, the maximum amount of financial
residence, utilities, and residential infrastructure
assistance for housing is $41,000 (adjusted
(e.g., privately-owned access routes).30 The
annually). Financial assistance to rent alternative
objective of Home Repair Assistance is to make the
housing accommodations does not count
towards the housing assistance cap, and
disaster survivors’ home “safe, sanitary, or
exempted from the housing assistance cap are
functional.”31 Two limitations on Home Repair
accessibility-related repair or replacement costs.
Assistance include (1) it is subject to the maximum
(DHS/FEMA, “Notice of Maximum Amount of
amount of financial assistance for housing, with
Assistance Under the Individuals and Households
some exemptions (described below); and (2) it is
Program,” 87 Federal Register 64512, October 25,
not intended to improve or even to return the
2022, https://www.govinfo.gov/content/pkg/FR-
primary residence to its pre-disaster condition, with
2022-10-25/pdf/2022-23162.pdf.)
the exceptions of making reasonable hazard
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
FEMA’s guidance specifies some accessibility-related items as being eligible for Home Repair
Assistance. Specifically, per the IAPPG, disaster-damaged grab bars and an access ramp are
eligible for Home Repair Assistance, and are exempted from the maximum amount of financial
assistance for housing.33 Additionally, in September 2021, FEMA amended its Home Repair
Assistance policy to extend eligibility for accessibility-related real property items to people with
disaster-caused disabilities. Thus, FEMA will now fund post-disaster accessibility-related items
(i.e., these items were not damaged by the disaster because the homeowner did not have a
disability at the time of the disaster, but their disability was caused by the disaster and they now
have a need for accessibility items), including
• an exterior ramp;
• grab bars; and
• a paved path to the home’s entrance.34

28 FEMA, IAPPG, 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.
29 FEMA, IAPPG, pp. 80-81.
30 A non-exhaustive list of real property components that are eligible for repair is included in the FEMA IAPPG on
page 86. It includes components such as the structural components of a home (e.g., foundation, exterior walls, roof).
Additionally, assistance to repair real property components impacted by disaster-caused mold growth is eligible for
Home Repair Assistance (Memorandum from Keith Turi, FEMA Assistant Administrator, Recovery Directorate to
FEMA Regional Administrators, “RE: Amendment to FP 104-009-03, Individual Assistance Program and Policy
Guide, Version 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 Turi RE: Amendment to the IAPPG)).
31 FEMA, IAPPG, p. 85.
32 FEMA, IAPPG, pp. 85-88. Repair Assistance for privately-owned access routes includes additional eligibility
conditions, and limitations and exclusions (see FEMA, IAPPG, pp. 89-90 for details).
33 FEMA, IAPPG, p. 86. DRRA Section 1212 exempted accessibility-related repair costs from the financial assistance
cap.
34 Memorandum from Keith Turi RE: Amendment to the IAPPG, p. 10.
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The Home Repair Assistance provided for mitigation is limited. Still, repairs may include hazard
mitigation measures that make the housing more resilient. Specifically, reasonable hazard
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
Repair Assistance for disasters declared on or after May 26, 2021 would “allow eligible
homeowners ... [to] repair or rebuild stronger, more durable homes.” Per the agency’s
announcement, FEMA’s Home Repair Assistance will include the following specific mitigation
measures:
• Roof repair to withstand higher winds and help prevent water infiltration;
• Elevating a water heater or furnace to avoid future flood damage; and
• 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
Home Replacement Assistance
Home Replacement Assistance provides funding to homeowners to help replace a disaster-
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
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
the maximum IHP housing award.39
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
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
unavailable.40

35 FEMA’s guidance details the specific types of mitigation measures available for Home Repair Assistance, and its
regulations and guidance impose limitations on the mitigation assistance that may be provided, including that it may
only be awarded for disaster-damaged real property components that existed and were functional prior to the declared
disaster (FEMA, “Hazard Mitigation Under the Individuals and Households Program,” release, June 10, 2021,
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. 85-88).
36 Memorandum from Keith Turi RE: Amendment to the IAPPG, p. 9.
37 FEMA, IAPPG, p. 91. FEMA calculates the award amount using the consumer price index data for the types of
housing in the area where the damage occurred (the type of pre-disaster home could include a “manufactured home,
travel trailer, houseboat, or residential construction (e.g., single-family home)”).
38 FEMA, IAPPG, p. 92.
39 FEMA, IAPPG, p. 91.
40 FEMA, IAPPG, p. 94. Direct Temporary Housing Assistance may be approved if the following three factors have
been verified, per FEMA’s IAPPG: (1) a lack of available housing prevents eligible applicants from making use of
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) will be insufficient to meet the disaster-caused housing needs; and
(3) assistance from providers, including other federal and nonfederal government sources, as well as nonprofit and
voluntary organizations, is insufficient to meet eligible applicants’ disaster-caused temporary housing needs.
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Direct Housing Assistance
Direct Housing Assistance is housing provided to the individual or household by FEMA or the
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
(MLR), Transportable Temporary Housing Units (TTHUs), and Direct Lease; and (2) Permanent
Housing Construction (PHC).42
Direct Housing Assistance must be requested in writing by the affected state, territory, or tribe,
and FEMA will only authorize it when:
1. Rental Assistance cannot be used by eligible applicants due to insufficient
available housing resources;
2. increasing the Rental Assistance rate to 125% of the HUD FMR will be
insufficient to meet the housing needs; and
3. assistance from other providers (e.g., government and voluntary organizations) is
insufficient to meet the housing needs.43
Unlike some forms of Financial Housing Assistance, Direct Housing Assistance is not subject to
the limit of the maximum amount of financial assistance an individual or household is eligible to
receive; however, other eligibility and programmatic limitations apply.44
FEMA follows a sequence of delivery when determining which Direct Housing Assistance
options to implement. Per FEMA’s IAPPG, this is based on “locations and numbers of eligible
applicants and the availability, feasibility, and cost-effectiveness of each option.”45 That sequence
generally follows the order depicted in Figure 1. PHC, which is included at the end of the
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
Assistance, and selected considerations or limitations associated with each type of assistance, are
included below.47

41 DRRA Section 1211(a) amended the Stafford Act to expand the types of FEMA IHP assistance that state, territory,
and Indian tribal governments may request to administer to include Direct Temporary Housing Assistance under
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
administer). On July 28, 2020, FEMA announced the publication of the State-Administered Direct Housing Grant
Guide, available at https://www.fema.gov/sites/default/files/2020-07/fema_state-administered-direct-housing-grant-
guide_DRRA1211_July2020.pdf, which made state, local, tribal and territory governments eligible to receive grants to
provide Direct Housing Assistance for a limited period of time; this pilot grant program concluded on October 5, 2020.
The State-Administered Direct Housing Grant Guide states that FEMA will implement a permanent grant program
after issuing final regulations. As of December 2021, FEMA has not yet begun the rulemaking process (email
correspondence from FEMA Congressional Affairs staff, December 6, 2021).
42 FEMA, IAPPG, p. 93.
43 FEMA, IAPPG, p. 94. HUD’s PD&R posts FMR information at https://www.huduser.gov/portal/datasets/fmr.html.
44 FEMA, IAPPG, p. 93.
45 FEMA, IAPPG, p. 95. According to a December 2020 U.S. Government Accountability Office (GAO) report, FEMA
also considers the “convenience to individuals and households and timeliness and availability of other forms of
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
(hereinafter GAO, Disaster Housing: Improved Cost Data and Guidance)).
46 FEMA, IAPPG, pp. 93 and 95.
47 The FEMA IAPPG, beginning on page 93, lists additional conditions of applicant eligibility, program limitations and
exclusions, and considerations for each type of Direct Housing Assistance.
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Figure 1. FEMA Direct Temporary Housing Assistance Options Sequence of Delivery

Source: Developed by CRS based on “Figure 22: General Sequence of FEMA Direct Housing Assistance
Options” of the FEMA, Individual Assistance Program and Policy Guide (IAPPG), v. 1.1, FP 104-009-03, May 2021, p.
95, https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf.
Notes: MLR stands for Multi-Family Lease and Repair; TTHUs stands for Transportable Temporary Housing
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,
vacant multi-family housing unit (e.g., an apartment in a building that FEMA has leased; FEMA
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
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 eligibility of
a property for MLR, there are several eligibility requirements that must be met, including that the
MLR-eligible property must be located in a county or jurisdiction designated for IA or, if there
are no available properties in the area designated to receive IA, the MLR-eligible property must
be in the same state or territory, located within reasonable commuting distance of the declared
area, and affected by the same incident.50 FEMA will prioritize the use of MLR properties based
on an evaluation of considerations, such as cost, time to complete repairs, proximity to wrap-
around services, and accessibility.51
Transportable Temporary Housing Units (TTHUs)
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

48 FEMA, IAPPG, p. 107. Following Hurricane Sandy, Section 1103 of the Sandy Recovery Improvement Act of 2013
(Division B of P.L. 113-2) formalized FEMA’s Multi-Family Lease and Repair (MLR) program.
49 FEMA, IAPPG, p. 107.
50 DRRA 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 “impacted by a major disaster or located in areas covered by a
major disaster declaration.” See also FEMA, IAPPG, pp. 107-108.
51 FEMA, IAPPG, p. 110.
52 The types of Transportable Temporary Housing Units (TTHUs) include Recreational Vehicles (RVs) or
Manufactured Housing Units (MHUs). MHUs are built to meet the construction and safety standards set forth by HUD
at 24 C.F.R. Part 3280. A manufactured home is defined in 24 C.F.R. §3280.2 as “... a structure, transportable in one or
more sections ... and which is built on a permanent chassis and designed to be used as a dwelling with or without a
permanent foundation when connected to the required utilities.... ” The IAPPG provides additional information on the
certification standards that FEMA-provided RVs and MHUs must meet (FEMA, IAPPG, pp. 112-113; see 24 C.F.R.
§§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)
complying with government ordinances; and (3) satisfying federal floodplain management and
Environmental Planning and Historic Preservation (EHP) compliance review requirements.54 The
IAPPG states that “FEMA selects locations based on the cost-effectiveness, timeliness, and
suitability of each potential site,”55 and the IAPPG includes a complete list of requirements and
considerations for the eligibility and prioritization of each site type.56
FEMA has the statutory authority to dispose of
TTHU Site Types
TTHUs via sale or donation when requested, in
Private Sites are provided at no cost to FEMA
writing, by the affected state, territory, or Indian
by the applicant (usually on the applicant’s
tribal government when certain conditions are
property);
met,57 including that a TTHU can be sold to its
Commercial Sites allow FEMA to lease
occupants if they lack permanent housing, or a
available pads in an existing manufactured home
TTHU may be sold, transferred, donated, or made
park; and
available to a government entity or voluntary
Group Sites are provided by the state or local
government (e.g., publicly owned park land), and
organization to enable them to continue providing
are only considered when no other Direct
temporary housing to eligible occupants who are
Temporary Housing Assistance options can meet
unable to afford to purchase the TTHU from
the housing need.
FEMA.58
Direct Lease
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 typically available to the
general public (e.g., a vacation rental); and (2) the owner must permit permanent accessibility-
related modifications or improvements to be made.60 The IAPPG includes a complete list of
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-
permanent housing, and can include repairs or new home construction.62 Additionally, per the
IAPPG, PHC is only available “in insular areas outside the continental U.S.” or “in other
locations where no alternative housing resources are available and other types of Temporary

53 FEMA, IAPPG, pp. 113-116. Utilities include available and functional sanitation, electrical service, and potable
water service.
54 FEMA, IAPPG, p. 112.
55 FEMA, IAPPG, p. 112.
56 FEMA, IAPPG, pp. 113-116.
57 42 U.S.C. §5174(d)(2); FEMA, IAPPG, p. 119 (see the considerations for authorizing the disposal of TTHUs through
sales and donations).
58 42 U.S.C. §5174(d)(2); see also FEMA, IAPPG, pp. 119-124.
59 FEMA, IAPPG, p. 124. FEMA developed its Direct Lease program in 2017, and it has been implemented since 2018
as a form of Direct Temporary Housing Assistance (email correspondence from FEMA Congressional Affairs staff,
March 9, 2019).
60 FEMA, IAPPG, p. 125. The ability to use stand-alone residential sites that are not typically available to the public
distinguishes Direct Lease from MLR (e.g., FEMA may lease a vacation property when apartments are unavailable).
61 FEMA, IAPPG, pp. 125-126.
62 FEMA, IAPPG, p. 127.
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Housing Assistance are unavailable, infeasible or not cost-effective.”63 The IAPPG details the
information that must be included in PHC requests, as well as additional eligibility conditions and
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
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
amount exceeds $12 per square foot and the residence is repairable, but new construction is more
cost-effective.64
Legislative Changes and Significant Program Updates: Housing Assistance
Several sections of DRRA65 amended the
DRRA Separated the Maximum
provision of Housing Assistance under Stafford
Awards for Housing Assistance and
Act Section 408. These statutory amendments
ONA
changed the implementation of IHP Housing
Prior to DRRA’s enactment, the Stafford Act
Assistance, and are reflected in the current
imposed a total limit on the maximum amount of
IAPPG.
all IHP financial assistance an individual or
household could receive for a single disaster (i.e.,
• Allowance of State-Administered
housing assistance and ONA combined to count
Direct Housing Assistance (DRRA
towards the cap).
Section 1211)—State Administration of
DRRA Section 1212 created two separate limits on
Assistance for Direct Temporary Housing
the financial assistance eligible individuals and
and Permanent Housing Construction—
households may receive: one for housing assistance
and one for ONA. Additionally, DRRA exempted
allows state, territory, and Indian tribal
some forms of assistance that previously counted
governments to administer the provision
towards the limit. Thus, post-DRRA, financial
of Direct Temporary Housing Assistance
assistance for housing-related needs may not
(i.e., MLR, TTHUs, and Direct Lease)
exceed $41,000 (FY2023; adjusted annually), and
financial assistance for ONA may not exceed
and Permanent Housing Construction, in
$41,000 (FY2023; adjusted annual y).
addition to ONA.66
The enactment of DRRA Section 1212 effectively
• Increase Maximum IHP Award
increased the amount of financial assistance an
Amounts (DRRA Section 1212)—
individual or household could be eligible to receive
Assistance to Individuals and
through the IHP.
Households—established separate caps of
(DHS/FEMA, “Notice of Maximum Amount of
Assistance Under the Individuals and Households
equal amounts for the maximum amount
Program,” 87 Federal Register 64512, October 25,
of financial assistance eligible individuals
2022, https://www.govinfo.gov/content/pkg/FR-
and households may receive for Financial
2022-10-25/pdf/2022-23162.pdf.)

63 FEMA, IAPPG, p. 127. According to the IAPPG, Guam, the Commonwealth of the Northern Mariana Islands,
American Samoa, and the U.S. Virgin Islands are insular areas, and the Alaskan interior is an example of a remote area
(FEMA, IAPPG, p. 76). Unavailable means temporary housing options are unavailable for a reasonable cost or in a
reasonable amount of time. Infeasible means there are no available rental housing resources, or forms of Direct
Temporary Housing Assistance cannot be used because of various challenges (e.g., distance, time delays), which
FEMA cannot overcome with reasonable means. Not cost-effective means the provision of other forms of Direct
Temporary Housing Assistance would cost more than providing PHC.
64 FEMA, IAPPG, p. 141.
65 For more information on DRRA, see CRS Report R46776, The Disaster Recovery Reform Act of 2018 (DRRA):
Implementation Updates for Select Provisions, coordinated by Elizabeth M. Webster and Bruce R. Lindsay, and CRS
Report R45819, The Disaster Recovery Reform Act of 2018 (DRRA): A Summary of Selected Statutory Provisions,
coordinated by Elizabeth M. Webster and Bruce R. Lindsay.
66 DRRA Section 1211(a). Post-DRRA, although the federal government is still responsible for housing assistance
(continued...)
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Housing Assistance and ONA.67 It also removed financial assistance to rent
alternative housing accommodations (i.e., Lodging Expense Reimbursement,
Rental Assistance, and 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 personal property (e.g., eligible household items).69
• Expanded MLR Property Eligibility (DRRA Section 1213)—Multifamily
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
Other Needs Assistance
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
covered by insurance or provided by another source. A necessary expense is defined as “the cost
associated with acquiring an item, obtaining a service, or paying for any other activity that meets
a serious need.” A serious need is defined as “the requirement for an item or service that is
essential to an applicant’s ability to prevent, mitigate, or overcome a disaster-caused hardship,
injury, or adverse condition.”72
There are many types of ONA, which fall into two subcategories: (1) SBA-Dependent ONA, and
(2) Non-SBA-Dependent ONA (SBA refers to the Small Business Administration) (the reason for
the SBA’s involvement is described in the following section).
There are several limitations on the amount of ONA an individual or household is eligible to
receive. Applicants may receive up to the maximum amount of financial assistance for ONA.73
Additionally, available 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
predetermines some items that are eligible 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
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 Temporary Housing Assistance and
Permanent Housing Construction. In addition, DRRA Section 1211(b) provides a mechanism for state and local units of
government to be reimbursed for locally-implemented housing solutions.
67 DRRA Section 1212.
68 FEMA, IAPPG, pp. 41-42.
69 DRRA Section 1212.
70 DRRA Section 1213(b). Eligible MLR properties include both properties that are located in areas covered by an
emergency or major disaster declaration and areas that are impacted by a major disaster.
71 DRRA Section 1213(a).
72 FEMA, IAPPG, p. 145.
73 Financial assistance for ONA may not exceed $41,000 (FY2023; adjusted annually) (DHS/FEMA, “Notice of
Maximum Amount of Assistance Under the Individuals and Households Program,” 87 Federal Register 64512,
October 25, 2022, https://www.govinfo.gov/content/pkg/FR-2022-10-25/pdf/2022-23162.pdf).
74 FEMA, IAPPG, p. 147. State, territory, and Indian tribal governments establish the maximum amount of assistance
that may be awarded for some categories of ONA, including Transportation Assistance for repair or replacement,
Funeral Assistance, and Child Care Assistance. Personal Property and Miscellaneous Items may also be requested, and
the requesting state, territory, and Indian tribal government must list the additional items, maximum quantity,
maximum award amount, and justification and situations for use. This is submitted to FEMA annually via the “ONA
Administrative Option Selection Form” (FEMA, “Individuals and Households Program (IHP)—Other Needs
Assistance Administrative Option Selection,” form, O.M.B. Control No. 1660-0061, expires December 31, 2021,
https://www.fema.gov/sites/default/files/documents/fema_individuals-households_ONA-administrative-
(continued...)
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Child Care Assistance up to the limits established by the STT [state, territory, or tribal]
government in the ONA Administrative Option Selection Form.... ”75
Additionally, 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
“the non-Federal share shall 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
responsibility for covering a portion of the costs associated with providing ONA.78
SBA-Dependent ONA
FEMA and the Small Business Administration (SBA) collaborate to determine an applicant’s
eligibility for some forms of Other Needs Assistance.79 This is because IHP assistance for
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
addressed by an SBA disaster loan. To avoid the statutory prohibition on duplicative assistance,80
FEMA refers IHP applicants who meet the SBA’s minimum income test to first apply for a low-
interest SBA disaster loan before they are eligible to receive SBA-Dependent ONA through the
IHP.81 If the applicant does not qualify for an SBA disaster loan or their SBA disaster loan amount
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 specifically for SBA-Dependent ONA.
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 eligibility for benefits,
prevent duplicative aid from being provided in response to the same disaster or emergency, and
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, IAPPG, pp. 147, 149). However, the “ONA Administrative Option Selection
Form” may be changed “during any non-disaster period or within three days of a major disaster declaration” (FEMA,
IAPPG p. 149).
75 FEMA, IAPPG, p. 149.
76 See the “Defining ‘Cost Shares’” text box for the cost share definition.
77 42 U.S.C. §5174(g)(2)(B).
78 42 U.S.C. §5174(g)(2); 44 C.F.R. §206.110(i)(2); and FEMA, IAPPG, p. 147.
79 Small Business Administration (SBA), “Computer Matching Agreement Between U.S. Small Business
Administration and U.S. Department 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
(hereinafter SBA, “Computer Matching Agreement”); and FEMA, IAPPG, p. 145. Per the Computer Matching
Agreement, “This Agreement establishes the Computer Matching program between DHS [Department of Homeland
Security]/FEMA and SBA. The Computer Matching program seeks to ensure that applicants for SBA Disaster Loans
and DHS/FEMA Individuals and Households Program (IHP), which provides Other Needs Assistance (ONA) and
Housing Assistance (HA), are eligible 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
and SBA disaster assistance.... ” Further, the purpose of the Computer Matching Agreement is to “share data and
financial/benefits award decisions of individuals, businesses, 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
duplication of benefits is identified.”
80 42 U.S.C. §5155.
81 The other forms of ONA may be awarded regardless of the individual’s or household’s Small Business
Administration (SBA) disaster loan status and are referred to as Non-SBA-Dependent ONA.
82 SBA, “Computer Matching Agreement,” 84 Federal Register 2650.
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• 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
ONA, but if the applicant meets the SBA’s minimum income test to apply for an
SBA disaster loan, then FEMA automatically refers applicant to the SBA;83
• once referred to the SBA, to be considered for assistance through the SBA or
FEMA, the applicant must apply for an SBA disaster loan, which is based on
credit-worthiness; and
• the applicant will be automatically referred back to FEMA for consideration for
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 will contact
applicants who are determined able to afford a loan and FEMA will contact
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
loan, FEMA will not provide any SBA-dependent ONA to that applicant.84
Figure 2 depicts the general process for determining eligibility for SBA-Dependent ONA.85 As
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
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 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
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
FEMA officials, FEMA contacts the disaster survivor if the SBA determines they cannot afford a
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
disaster loan program through a variety of methods. For example, FEMA staff share information on SBA’s disaster
loan program during interactions with survivors. After completing the IHP application, an applicant who is referred to
the SBA is verbally notified that they must also complete and return an application to SBA to be considered for a
disaster loan as well as certain types of 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,
https://www.gao.gov/assets/710/709775.pdf (hereinafter GAO, Disaster Assistance: IHP).
84 SBA, “Computer Matching Agreement,” 84 Federal Register 2651-2652.
85 For more information on the process of determining whether an applicant may qualify for a SBA disaster loan and
how FEMA ONA assistance and SBA disaster loans intersect, see CRS Report R45238, FEMA and SBA Disaster
Assistance for Individuals and Households: Application Processes, Determinations, and Appeals, by Bruce R. Lindsay
and Elizabeth M. Webster.
86 SBA, “Computer Matching Agreement,” 84 Federal Register 2651. “[I]f SBA approves the applicant’s loan
application and the applicant does not accept the loan, DHS/FEMA will not provide any SBA-dependent ONA to that
applicant.”
87 GAO, Disaster Assistance: IHP, p. 37 (footnote 49).
88 GAO, Disaster Assistance: IHP, p. 79.
89 GAO, Disaster Assistance: IHP, p. GAO Highlights.
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reported 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
Figure 2. FEMA and SBA Screening Process

Source: Developed by CRS based on “Figure 27: SBA Disaster Loan Application Process” of the FEMA,
Individual Assistance Program and Policy Guide (IAPPG), v. 1.1, FP 104-009-03, May 2021, p. 145,
https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf.
Note: SBA-Dependent ONA provides financial assistance for other disaster-related expenses and needs,
including for Personal Property Assistance, Transportation Assistance, and Group Flood Insurance Policies.
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
Personal Property Assistance
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
include standard household appliances (and selected accessibility items); essential clothing;
standard furnishings; and essential, specialized tools and equipment required by an employer
(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 Assistance: IHP, pp. 76-77 (see Recommendations 1 and 2). See also the status of Recommendations
1 and 2 in the “Recommendations for Executive Action” table on the web page 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 The FEMA IAPPG includes additional conditions of applicant eligibility, eligible expenses, required documentation,
and program limitations and exclusions for each type of SBA-Dependent ONA, beginning on page 166.
92 FEMA, IAPPG, pp. 166-167.
93 FEMA, IAPPG, p. 167.
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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
Accessibility items that are eligible for Personal Property Assistance and are exempted from the
ONA maximum amount of financial assistance include:
• Computer (if it is a person’s sole means of communication);
• Raised—or elevated—toilet seat (for people who have mobility limitations);
• Front-loading washer (for people who use a wheelchair/have mobility
limitations);
• Side-by-side refrigerator (for people who use a wheelchair/have mobility
limitations);
• Hospital-style bed;
• Walker;
• Wheelchair;
• Shower chair;
• Specialty Smoke Alarm (for people who are vision/hearing-impaired); and
• Text telephone devices (TTYs or TDDs).95
Transportation Assistance
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
area designated to receive IA, provided: (1) the vehicle was damaged as a direct result of the
presidentially-declared emergency or major disaster; and (2) the damage occurred in the area
designated to receive IA.97 Additional eligibility requirements include that the applicant: (1) owns
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 IAPPG, FEMA
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
degree of damage and the state/territory/tribe-set maximum established in the “ONA
Administrative Option Selection Form.”99
Group Flood Insurance Policy
Individuals and households who receive federal financial assistance for flood-related damage—
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, IAPPG, pp. 166-167.
95 FEMA, IAPPG, p. 146.
96 FEMA, IAPPG, p. 170. Eligible vehicles include cars, vans, sport utility vehicles (SUVs), and trucks, and may
include motorcycles, boats, golf carts, etc. if specified by the affected state, territory, or Indian tribal government on
their “ONA Administrative Option Selection Form.”
97 FEMA, IAPPG, p. 170.
98 FEMA, IAPPG, pp. 170, 172.
99 FEMA, IAPPG, p. 170.
100 44 C.F.R. §206.110(k)(3); FEMA, IAPPG, p. 63.
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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
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
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
ONA (e.g., for FY2023, $82,000).103
There are a few special eligibility criteria that must be met for a person to be eligible for a GFIP,
including (1) the damage was caused by flooding and the flood-damaged items are insurable
under the NFIP; (2) the applicant is eligible for IHP Home Repair, Home Replacement, or
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
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
exceeds this, FEMA will not purchase a policy; however, the applicant is still responsible for
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
Non-SBA-Dependent ONA
Non-SBA-Dependent types of ONA may be awarded regardless of the individual or household’s
SBA disaster loan status.106
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

101 FEMA, IAPPG, p. 172.
102 Per 44 C.F.R. §61.17(b), the Group Flood Insurance Policy (GFIP) premium is a “flat fee of $600 per insured” and
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
may be adjusted “to reflect NFIP loss experience and any adjustment of benefits under the IHP program.” FEMA’s
guidance notes the premium is $2,400 (FEMA, IAPPG, p. 172).
103 FEMA, IAPPG, p. 172. The maximum amount of financial assistance for IHP Housing Assistance and ONA for
disasters declared on or after October 1, 2022, can be found at DHS/FEMA, “Notice of Maximum Amount of
Assistance Under the Individuals and Households Program,” 87 Federal Register 64512, October 25, 2022,
https://www.govinfo.gov/content/pkg/FR-2022-10-25/pdf/2022-23162.pdf.
104 FEMA, IAPPG, p. 173. To be eligible for GFIP, the property cannot be located in a sanctioned community, Coastal
Barrier Resources System (CBRS) area, or otherwise protected area (OPA). The FEMA IAPPG defines the different
types of Flood Zones and Protected Areas, including Special Flood Hazard Areas (SFHAs), sanctioned communities,
CBRS units, and OPAs, beginning on page 63. Individuals who receive federal financial assistance for flooding must
purchase flood insurance on real or personal property that is, or will be, in an SHFA and can be insured under the
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
personal or real property if the receipt of financial assistance was conditioned on their obtaining and maintaining flood
insurance, and they fail to do so (codified at 42 U.S.C. §5154a).
105 FEMA, IAPPG, p. 174.
106 FEMA, IAPPG, p. 149.
107 The FEMA IAPPG includes additional conditions of applicant eligibility, eligible expenses, required documentation,
and program limitations and exclusions for each type of Non-SBA-Dependent ONA, beginning on page 150.
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Funeral Assistance
Funeral Assistance provides funding to assist with eligible funeral expenses (e.g., interment or
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
incurred or will incur expenses related to a death or disinterment that is directly or indirectly
attributable to the presidentially 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
FEMA COVID-19 Funeral Assistance
In response to the Coronavirus Disease 2019 (COVID-19) pandemic, Congress authorized FEMA to provide
COVID-19 Funeral Assistance through Section 201 of the Coronavirus Response and Relief Supplemental
Appropriations Act, 2021 (Division M of the Consolidated Appropriations Act, 2021, P.L. 116-260), and Section
4006 of the American 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.
Although FEMA’s role in administering Funeral Assistance typically varies depending on the preference of the
affected state, territory, or tribe, in the case of COVID-19 Funeral Assistance, FEMA administered the program
under the ONA FEMA Option and FEMA also issued interim policy guidance to “streamline the delivery of Funeral
Assistance” because of the “unprecedented number of deaths caused by COVID-19.”
(FEMA, IAPPG, p. 148; FEMA, “FEMA Policy: COVID-19 Funeral Assistance: Individuals and Households Program
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.)
Child Care Assistance
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
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
13 and under, and/or children up to age 21 who have a disability as defined by federal law and
need assistance with activities of daily living.113 Three eligibility considerations are: (1) the
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
child care;114 (2) other childcare services must not be available;115 and (3) the care provider must

108 FEMA, IAPPG, pp. 150-152.
109 FEMA, IAPPG, p. 150.
110 FEMA, IAPPG, p. 150
111 FEMA, IAPPG, p. 151.
112 FEMA, IAPPG, p. 155.
113 FEMA, IAPPG, p. 155. The IAPPG defines activities of daily living as “routine activities that people tend to do
every day without needing assistance. There are six basic ADLs [activities of daily living]: eating, bathing, dressing,
toileting, transferring (walking), and continence.”
114 FEMA, IAPPG, p. 156. To determine if post-disaster child care costs create a financial burden, according to the
IAPPG “FEMA compares the percentage of the household’s gross 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
care post-disaster is higher than the percentage of household gross income spent on child care pre-disaster, the
household has an increased financial burden for child care and may be eligible for assistance to cover the increase.”
Eligible individuals and households may receive FEMA assistance for the difference spent on pre- and post-disaster
child care.
115 FEMA, IAPPG, p. 156.
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be licensed, regulated, or registered per the applicable state, territory, tribal or local government’s
laws.116
Medical and Dental Assistance
Medical and Dental Assistance provides funding to assist with medical and dental expenses (e.g.,
injury, illness, 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,
applicants do not need to live in the designated declared area, provided they incurred medical or
dental expenses as a direct result of the presidentially declared emergency or major disaster.118
Miscellaneous Expenses
Miscellaneous 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
and smoke detectors, dehumidifiers or humidifiers, chainsaws, generators, and weather radios,120
but the availability of such items will depend on what the state, territory, or Indian tribal
government included in the miscellaneous line items on their “ONA Administrative Option
Selection Form”; additional miscellaneous items could also be included by the state, territory, or
tribe.121
Moving and Storage Assistance
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 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
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
from flooding and the applicant failed to maintain flood insurance as a condition of receiving
previous federal assistance, then FEMA will not provide assistance for the first $1,000 of
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, IAPPG, p. 156.
117 FEMA, IAPPG, p. 153.
118 FEMA, IAPPG, p. 153.
119 FEMA, IAPPG, pp. 160-162.
120 FEMA, IAPPG, pp. 160-162. Miscellaneous items may assist disaster survivors with gaining access to their property
or assisting with cleaning efforts. Reimbursements for chainsaws and generators are permitted under limited
circumstances if certain conditions are met.
121 FEMA, IAPPG, pp. 160-161. Per the IAPPG, “Assistance for Miscellaneous Items is limited to the quantity
established for the item by the STT government on the ‘ONA Administrative Option Selection Form.’”
122 Previously, Moving and Storage Assistance was classified as SBA-Dependent ONA. It was updated to a Non-SBA-
Dependent category of ONA in Version 1.1 of FEMA’s IAPPG (FEMA, IAPPG, p. 9).
123 FEMA, IAPPG, p. 162.
124 FEMA, IAPPG, pp. 162 and 164.
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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
eligibility period is generally 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
Assistance 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-
sustaining items includes “water, food, first aid, prescriptions, infant formula, diapers, CMS
[consumable medical supplies], DME [durable medical equipment], personal hygiene items, and
fuel for transportation.”127
Clean and Sanitize Assistance
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
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
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
home is addressed in order to prevent additional losses and potential health and safety
concerns.”129 Eligibility is limited to applicants who do not qualify for Home Repair Assistance
because their primary residence was not rendered uninhabitable.130
Legislative Changes and Significant Program Updates: ONA
As described in detail above in the “Legislative Changes and Significant Program Updates:
Housing Assistance” 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
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 Eligible for Personal
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, IAPPG, p. 164.
126 FEMA, IAPPG, p. 164.
127 FEMA, IAPPG, pp. 164-165.
128 Memorandum from Keith Turi RE: Amendment to the IAPPG, p. 11; and FEMA, IAPPG, p. 165.
129 Memorandum from Keith Turi RE: Amendment to the IAPPG, pp. 11-12.
130 Memorandum from Keith Turi RE: Amendment to the IAPPG, p. 11.
131 DRRA Section 1212. For more information on DRRA, see CRS Report R46776, The Disaster Recovery Reform Act
of 2018 (DRRA): Implementation Updates for Select Provisions, coordinated by Elizabeth M. Webster and Bruce R.
Lindsay; and CRS Report R45819, The Disaster Recovery Reform Act of 2018 (DRRA): A Summary of Selected
Statutory Provisions, coordinated by Elizabeth M. Webster and Bruce R. Lindsay.
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...)
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tribal governments do not automatically receive a presidential declaration of emergency or major
disaster, nor do they automatically receive Individual Assistance (IA).133 Instead, following an
incident,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
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
will be committed, and an estimate of the amount and severity of the disaster-caused damages, in
addition to other required information.137
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
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,
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
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,
and 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
to the extent allowable under the Stafford Act.
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 to
“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. §206.36).
133 44 C.F.R. §§206.35-206.38, and 206.40(a); and FEMA, “How a Disaster Gets Declared.”
134 An incident is defined as “[a]ny condition which meets the definition of major disaster or emergency as set forth in
§206.2 which causes damage or hardship that may result in a Presidential declaration of a major disaster or an
emergency” (44 C.F.R. §206.32(e)).
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
Declared.” It is possible 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 emergency involves a subject area for
which, under 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 CRS Report R43784,
FEMA’s Disaster Declaration Process: A Primer, by Bruce R. Lindsay.
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
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, Tribal Declarations Pilot Guidance, pp. 36-38.
139 FEMA, Preliminary Damage Assessment Guide, August 2021, p. 1, https://www.fema.gov/sites/default/files/
documents/fema_2021-pda-guide.pdf (hereinafter FEMA, Preliminary Damage Assessment Guide).
140 44 C.F.R. §206.37(c).
141 44 C.F.R. §206.38.
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available,” in practice, FEMA has stated that they will seek the President’s approval when
authorizing additional forms of assistance.142
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, specifically, IHP
assistance.
FEMA’s Evaluation of the IA Factors: Major Disaster
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,
magnitude, and impact of a disaster, as well as the capabilities of the affected jurisdictions” and
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
President with a recommendation regarding whether to declare a major disaster authorizing IA,
and to identify the types of IA that should be made available (e.g., low disaster-related
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
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
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
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
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 IAPPG was
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
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
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.
143 DHS/FEMA, “Factors Considered When Evaluating a Governor’s Request for Individual Assistance for a Major
Disaster,” 84 Federal Register 10632, March 21, 2019, https://www.govinfo.gov/content/pkg/FR-2019-03-21/pdf/
2019-05388.pdf (hereinafter DHS/FEMA, “Factors Considered When Evaluating a Request for IA”); see also
DHS/FEMA, “Factors Considered When Evaluating a Governor’s Request for Individual Assistance for a Major
Disaster; Correction,” 84 Federal Register 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, Tribal Declarations Pilot Guidance, pp. 34 and 36.
Additionally, “Appendix D; Tribal-Specific Considerations” of FEMA’s Preliminary Damage Assessment Guide
includes useful resources and unique considerations for Indian tribal governments during the PDA process.
144 FEMA, Individual Assistance Declarations Factors Guidance, June 2019, p. 13, https://www.regulations.gov/
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).
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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 Tribal
Declarations Pilot Guidance 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
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, FEMA has stated that it
plans to implement this authority through a rulemaking.148
IA Factors
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 government. Table 2 lists the
factors considered when evaluating IA requests made by a governor of an affected state or
territory, as well as a chief executive of an affected Indian tribal government. Figure 3 lists the
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
authorizing IA.
Table 2. Individual Assistance Factors for States/Territories and Tribes
Factors Considered When Evaluating a
Factors Considered When Evaluating a
Governor’s Request for IA
Chief Executive’s Request for IA
State Fiscal Capacity and Resource Availability
Tribal Government Resources
Uninsured Home and Personal Property Losses
Voluntary Agency and Other Assistance
Disaster-Impacted Population Profile
Availability of Housing Resources
Impact to Community Infrastructure
Uninsured Home and Personal Property Losses
Casualties
Disaster-Impacted Population Profile
Disaster Related Unemployment
Impact to Community Infrastructure
Casualties
The Unique Conditions That May Affect Tribal
Governments
Sources: 44 C.F.R. §206.48(b); and FEMA, Tribal Declarations Pilot Guidance, January 2017, pp. 36-38,
https://www.fema.gov/sites/default/files/2020-04/tribal-declaration-pilot-guidance.pdf.
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. 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) 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
the same factors to evaluate a governor or chief executive’s request for a presidential major disaster declaration, which
allowed Indian tribal governments to exercise this authority immediately upon SRIA’s enactment. According to
FEMA’s website “Tribal 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 29, 2013, when
SRIA was enacted, through January 9, 2017, when FEMA released its Tribal Declarations Pilot Guidance.
147 FEMA, Tribal Declarations Pilot Guidance.
148 FEMA, “Tribal Declarations Pilot Guidance,” https://www.fema.gov/disaster/tribal-declarations.
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Figure 3. IA Programs and Consideration Factors

Source: Developed by CRS based on the FEMA, Individual Assistance Declarations Factors Guidance, June 2019, p.
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
considers when evaluating a governor’s request for a major 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
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
need for the IHP:
1. Fiscal Capacity; and
2. Uninsured Home and Personal Property Losses.150
FEMA’s evaluation of the Fiscal Capacity factor is detailed in Appendix A. Information 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. Additionally, the damage 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, IA Declarations Factors Guidance, p. 15.
150 Per 44 C.F.R. §206.48(b), “State fiscal capacity (44 CFR 206.48(b)(1)(i)) and uninsured home and personal property
losses (44 CFR 206.48(b)(2)) are the principal factors that FEMA will consider when evaluating the need for
supplemental Federal assistance under the Individuals and 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 Individuals and Households Program is not clear from the evaluation of the principal factors, FEMA will turn to the
other factors to determine the level of need.”
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FEMA established four categories of damage: (1) destroyed; (2) major; (3) minor; or (4) affected.
According to FEMA’s Preliminary Damage Assessment Guide, the cost of assistance estimate
“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
request package, and FEMA considers all relevant information submitted by the requesting
state/territory or tribe. Moreover, FEMA’s guidance explains,
There is no set number of damaged homes that will automatically trigger a Presidential
disaster declaration for a state, tribe, or territory. Each disaster must be evaluated
individually on the impacts that have overwhelmed the capacity and resources of the state,
tribal, or territorial government. During the PDA process, state, tribal, or territorial
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
generally outweighed the capacity and resources of the impacted governments.151
Although there is no set threshold, FEMA has provided requesting states/territories with
information to help them evaluate the likelihood that their request for a major disaster declaration
authorizing IA will be approved, which is based on historic approval data.152 Specifically, FEMA
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 will be
granted—“given other factors that may be taken into account.”153
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
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 will be granted.155
ICC Ratio Formula
The Individuals and Households Program (IHP) Cost-to-Capacity (ICC) Ratio is derived from a ratio of the
estimated cost of IHP assistance based on the Preliminary Damage Assessment (PDA) to the state’s Total Taxable
Resources (TTR). The ICC Ratio may be considered to provide an indication of the likelihood that IHP assistance
wil be authorized.

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

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

151 FEMA, Preliminary Damage Assessment Guide, pp. 28-41.
152 FEMA, IA Declarations Factors Guidance, pp. 14-15.
153 FEMA, IA Declarations Factors Guidance, p. 14. According to FEMA, based on historical request data from 2008
to 2016, incidents for which the dollar amount of estimated costs of assistance was $1.5 million or less were declared
6% of the time; incidents for which the dollar amount of estimated costs of assistance was between $1.5 million and
$7.5 million were declared 42% of the time, and incidents for which the dollar amount of estimated costs of assistance
was $7.5 million or more were declared 90% of the time.
154 FEMA, IA Declarations Factors Guidance, p. 14.
155 FEMA, IA Declarations Factors Guidance, p. 15.
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According to FEMA, based on historical request data from 2008 to 2016, incidents with an ICC Ratio greater than
25 receive IHP assistance 85% of the time; incidents with an ICC Ratio between 10 and 25 receive IHP assistance
45% of the time, and incidents with an ICC Ratio less than 10 receive IHP assistance 10% of the time.
(FEMA, Individual Assistance Declarations Factors Guidance, p. 14; FEMA, Preliminary Damage Assessment Guide, p. 28;
and U.S. Department of the Treasury (Treasury), “Total Taxable Resources, Estimates,” https://home.treasury.gov/
policy-issues/economic-policy/total-taxable-resources. For an overview of TTR, including how it is estimated and
the limitations of using TTR as a measurement of fiscal capacity, see Treasury, Office of Economic Policy, Treasury
Methodology for Estimating Total Taxable Resources (TTR), December 2002, https://www.treasury.gov/resource-
center/economic-policy/Documents/nmpubsum.pdf.)
Additionally, 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 in Figure 4.
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
past requested and approved declarations.157 Again, this information is only intended to provide
an indication of the likelihood of a request being approved; it does not represent a threshold for
when IA and the IHP will 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 by CRS based on the Federal Emergency Management Agency (FEMA), “Individual
Assistance Declarations Factors Final Rule and Guidance,” webinar, April 30, 2019; FEMA, “Individual Assistance
Declarations: New Rule and Guidance,” PowerPoint slides, May 2019. A copy of the PowerPoint may be
provided to congressional clients by CRS upon request.
Notes: FEMA expanded on its Individual Assistance Declarations Factors Guidance in the webinar and associated
PowerPoint by providing an example of how the Estimated Cost of Individuals and Households Program (IHP)
Assistance and the IHP Cost-to-Capacity Ratio—or ICC Ratio—may relate to the likelihood a
state/territory/Indian tribal government wil receive IHP Assistance. As described above, there are no thresholds
for receiving IHP assistance, so in all instances, it is possible that the request for assistance could be authorized,
regardless of the estimated 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., (1)
Fiscal Capacity and (2) Uninsured Home and Personal Property Losses), FEMA will consider 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
C.F.R. §206.48(b), and in FEMA’s Preliminary Damage Assessment Guide and Individual

156 FEMA, IA Declarations Factors Guidance, p. 14. See the information provided in “Table 1: Estimated Cost of
Assistance Compared to Declaration Decision Comparative.”
157 FEMA, IA Declarations Factors Guidance, p. 14. See the information provided in “Table 2: Number of IA Requests
and Granted IA Requests by ICC Ratio.”
158 FEMA, IA Declarations Factors Guidance, p. 15.
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Assistance Declarations Factors Guidance. FEMA will provide a recommendation for the
President based on all of the available information, which will be forwarded to the President with
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.160
A detailed description of all of the IA factors can be found in Appendix A.
Implementing IHP 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.
The following sections provide a brief overview of the application process for individuals, as well
as eligibility requirements, and information on appealing FEMA’s decisions regarding the
provision of IHP assistance.161
Applying for IHP Assistance
The following sections describe aspects of applying for IHP assistance, including the period when
applicants can register for assistance, and IHP applicant eligibility requirements, including
descriptions of the general eligibility conditions.
Registration Period
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
can register for assistance online, by telephone, or in-person at a Disaster Recovery Center
(DRC).163
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 Initial
Registration Period.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
subsequently designated areas—per the IAPPG, “[f]or individuals in areas subsequently
designated for IA after the date of declaration, the registration deadline is still 60 days after the
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).
160 44 C.F.R. §206.38(a).
161 For more information on the IHP application process, see FEMA, IAPPG, pp. 69-77. For more information on IHP
eligibility considerations, see FEMA, IAPPG, pp. 46-66; and Memorandum from Keith Turi RE: Amendment to the
IAPPG, pp. 1-9. For more information on the IHP appeals process, see FEMA, IAPPG, pp. 66-68. See also CRS Report
R47297, Disaster Survivor FAQ: FEMA Individuals and Households Program, by Elizabeth M. Webster, for additional
information on frequently asked questions that arise as disaster survivors navigate the IHP application process and
receive IHP assistance.
162 When an emergency or major disaster is declared, areas of the impacted state/territory are “designated” as having
been deemed eligible for federal assistance (44 C.F.R. §206.2(a)(6); and FEMA, IAPPG, p. 5). Designated areas can be
“counties, parishes, tribes or tribal lands, municipalities, villages, or districts.”
163 FEMA, IAPPG, p. 69.
164 FEMA, IAPPG, pp. 70-71; 44 C.F.R. §206.112; and email from FEMA Congressional Affairs staff, May 25, 2021.
165 FEMA, IAPPG, pp. 70-71; 44 C.F.R. §206.112; and email from FEMA Congressional Affairs staff, May 25, 2021.
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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
Period concludes.166
Applicant Eligibility
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
verification, insurance, pre-disaster annual gross income, disaster-caused losses).168
IHP Application Requirements
Required information to complete an IHP application includes:
•
certification that the applicant is, or is the parent/guardian of a minor who is, a U.S. citizen, noncitizen
national, a qualified alien;
•
the primary applicant’s social security number (or social security number of a minor in the household who is
a U.S. citizen, noncitizen national, or qualified alien);
•
current and pre-disaster addresses;
•
names of pre-disaster household occupants;
•
contact information;
•
insurance information;
•
financial information (i.e., pre-disaster household annual gross income);
•
disaster-caused losses; and
•
banking information (for direct deposit of financial assistance).
(FEMA, IAPPG, pp. 71-72.)
IHP applicants must meet general eligibility requirements, as follows:
1. “[t]he applicant must be a U.S. citizen, noncitizen national, or qualified alien” (or
the parent or guardian of a minor child who is a U.S. citizen, noncitizen national,
or qualified alien);
2. “FEMA must be able to verify the applicant’s identity”;
3. “[t]he applicant’s insurance, or other forms of disaster assistance received, cannot
meet their disaster-caused needs”; and
4. “[t]he applicant’s necessary expenses and serious needs are directly caused by a
declared disaster.”169
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, IAPPG, pp. 70-71; 44 C.F.R. §206.112; and email from FEMA Congressional Affairs staff, May 25, 2021.
167 DHS/FEMA, “Declaration and Release,” Form, O.M.B. No. 1660-0002, expires August 31, 2022.
168 FEMA, IAPPG, pp. 71-72. The standard mechanism for verifying loss and determining eligibility—in the case of
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).
169 FEMA, IAPPG, p. 46.
170 See the IAPPG guidance on the type of IHP assistance being requested for additional requirements.
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ownership.171 Table 3 lists the eligibility of homeowners and renters for the different forms of
Housing Assistance.
Table 3. Eligibility for Types of Housing Assistance
Housing Assistance:
Housing Assistance:
Financial
Homeowner/Renter
Direct
Homeowner/Renter
Lodging Expense
Homeowner/Renter
Multi-Family Lease and
Homeowner/Renter
Reimbursement
Repair
Rental Assistance
Homeowner/Renter
Transportable Temporary Homeowner/Renter
Housing Units
Home Repair Assistance
Homeowner
Direct Lease
Homeowner/Renter
Home Replacement
Homeowner
Permanent Housing
Homeowner
Assistance
Construction
Source: CRS interpretation of FEMA, Individual Assistance Program and Policy Guide (IAPPG), 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.
Notes: The different types of Housing Assistance include different eligibility criteria. ONA may be available to
eligible applicants regardless of homeownership/renter status.
Additional Information on IHP Eligibility of People Experiencing Homelessness
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,
applicants experiencing homelessness may be eligible for forms of ONA.172
Additional Information on the Requirement that IHP Applicants be Citizens,
Noncitizen Nationals, or Qualified Aliens
Many forms of FEMA assistance are available regardless of the applicant’s immigration status.
For example, disaster survivors may be eligible for mass care and emergency assistance, such as
emergency sheltering support, as well as most forms of Individual Assistance, including the Crisis
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
eligible for IHP assistance, “[t]he applicant must be a U.S. citizen, non-citizen national, or
qualified alien.”174
Limitations on the availability 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
assistance to “qualified aliens.” FEMA’s “qualified alien” definition is based on 8 U.S.C. §1641,
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, IAPPG, pp. 46, 51-55; Memorandum from Keith Turi RE: Amendment to the IAPPG, pp. 2-9.
172 FEMA, IAPPG, p. 61.
173 FEMA, IAPPG, p. 48.
174 FEMA, IAPPG, p. 46. The IAPPG defines each of these citizenship statuses (i.e., U.S. citizen, noncitizen national,
and qualified alien) 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.
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called “non-qualified aliens” are generally rendered ineligible for federal public benefits.176 CRS
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
disaster relief as follows:
8 U.S.C. §1611(b) provides that the baseline eligibility rule restricting federal public
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
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
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
Additional Information on Determining IHP Award Amounts
As noted above, IHP awards are subject to
Award Amount Determination:
statutory funding caps for each applicant, and
Example for Home Repair Assistance
are designed to meet basic needs.178 For
According to the IAPPG, “Home Repair Assistance
example, IHP assistance is generally limited to
award amounts are based on repair or replacement of
essential living spaces.179
components that are of average quality, size, or
capacity.” FEMA bases these award amounts on local
The amount of assistance an applicant receives
costs—more specifically, on localized average repair
through the IHP will vary based on multiple
costs (i.e., FEMA does not have a flat rate for Home
factors that are “specific to the disaster
Repair Assistance costs for different components).
survivor’s unique circumstances.”
According to FEMA, the agency uses a tool/service
180 IHP
called RSMeans to determine and award reasonable
awards will depend on the applicant’s status
localized costs.
(e.g., homeowner, renter, roommate), the
(FEMA, IAPPG, p. 88; FEMA briefing on June 22, 2021.)
number of household members and household
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 for IHP
assistance. For additional information, see GAO, Compacts 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-
491.pdf. Table 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 for disaster
assistance programs, such as the Individuals and Households Program, that are considered to be federal public benefits
and are thus subject to citizenship requirements; however, they may be eligible to receive certain types of short-term,
noncash, in-kind emergency relief. For example, compact migrants may receive Public Assistance Emergency
Assistance services such as search and rescue; emergency medical care; emergency mass care; emergency shelter; and
provision of food, water, medicine, and other essential needs.”
177 See CRS Report R46510, PRWORA’s Restrictions on Noncitizen Eligibility for Federal Public Benefits: Legal
Issues, by Ben Harrington, p. 13 (citations omitted).
178 FEMA, IAPPG, pp. 6 and 41.
179 FEMA, Preliminary Damage Assessment Guide, p. 28. As described in FEMA’s Preliminary Damage Assessment
Guide, “[a]n essential living space is a room within a home that serves the function of a bedroom, bathroom, kitchen,
and/or living room that is regularly occupied or used by one or more members of the household and requires repair to
bring its functionality back to the home (e.g., kitchens are considered essential as long as there is not another
undamaged kitchen in the home).”
180 GAO, Disaster Assistance: IHP, p. 19.
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(i.e., the FEMA-Verified Loss (FVL) amount)181 and whether and to what extent the real and
personal property losses were insured.182
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
based on documentation of losses (e.g., medical bills or receipts for automobile repairs).183
Applicants may not receive the full FVL amount, including because their losses may be covered
in whole or in part by insurance. Additionally, some forms of IHP Housing Assistance and all
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
affected state, territory, or Indian tribal government.185
As stated above, insurance also factors into the amount of financial assistance an applicant may
receive. IHP applicants must inform FEMA of all insurance coverage that may help meet their
disaster-caused needs, and must provide FEMA with documentation identifying their insurance
settlements or benefits before FEMA will consider an applicant’s eligibility for assistance that
may be covered by private insurance.186
The amount of financial assistance an applicant may be eligible for is based on their FVL amount
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,
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
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
from determinations related to the applicant’s eligibility for IHP assistance generally or the
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
assistance.189 If this occurs, applicants for IHP assistance may appeal FEMA’s determinations,
including, but not limited to, appeals of
• applicant eligibility determinations;190

181 The FEMA-Verified Loss (FVL) amount is defined as “[t]he total dollar amount of IHP eligible disaster-caused
damage to real and personal property as verified by FEMA.” (FEMA, IAPPG, p. 50.)
182 GAO, Disaster Assistance: IHP, pp. 18-20.
183 FEMA, IAPPG, p. 72.
184 42 U.S.C. §5174(h)(4). There are exceptions to the maximum amount of financial assistance for select disaster-
damaged accessibility-related real and personal property items (FEMA, IAPPG, pp. 86 and 146).
185 FEMA, IAPPG, pp. 147 and 149; see also 44 C.F.R. §206.120(c) and (d).
186 FEMA, IAPPG, pp. 49-51.
187 FEMA, IAPPG, p. 50. In instances where an applicant’s deductible exceeds their “insurance verified loss” amount,
such that their net settlement is $0, FEMA may provide assistance for their FEMA Verified Loss (FVL) amount.
188 FEMA, IAPPG, p. 51.
189 44 C.F.R. §206.113.
190 44 C.F.R. §206.115(a)(1); FEMA, IAPPG, p. 66. Applicants have 60 days to appeal initial eligibility determinations.
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• the amount and/or type(s) of assistance received;191 and
• late application rejections.192
FEMA explains the appeal process as follows:
• To appeal any IHP assistance-related FEMA determination, applicants must
submit a written appeal explaining the reason for the appeal with documentation
supporting the appeal request.193
• Once FEMA receives an appeal, a caseworker who was not involved in the case
shall review the appeal and file to determine if there is sufficient information to
change FEMA’s determination.
• If there is not sufficient information, FEMA will either (1) contact the applicant
to request additional information with a deadline of 30 days; (2) contact a third
party (e.g., contractor, insurance company) to verify the supporting
documentation; and/or (3) schedule an appeal inspection.194
• FEMA’s shall provide appeal determinations to the applicant in writing within 90
days of receiving the written appeal letter, and FEMA’s appeal decision is final
(i.e., it cannot be appealed again).195
Recoupment of Improper Payments and Waivers Requirements
Federal laws require federal agencies, including FEMA, to identify and recover improper
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, IAPPG, p. 66. Applicants may also appeal decisions 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
Temporary Housing Assistance (44 C.F.R. §206.115(a)(5)), or FEMA’s denial of their request to purchase a FEMA-
provided Mobile Housing Unit (44 C.F.R. §206.115(a)(8)).
192 44 C.F.R. §206.115(a)(4); FEMA, IAPPG, p. 66.
193 44 C.F.R. §206.115(b); FEMA, IAPPG, pp. 66-67. Appeals must also be signed by the applicant (or person they
have authorized to act on his/her behalf).
194 44 C.F.R. §206.115(f); FEMA, IAPPG, p. 68.
195 44 C.F.R. §206.115(f); FEMA, IAPPG, p. 68.
196 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
underpayments) ... and includes any payment to an ineligible recipient, any payment for an ineligible service, any
duplicate payment.... ” For more information, see CRS Report R45257, Improper Payments in High-Priority
Programs: In Brief, by Garrett Hatch. FEMA lists, as reasons for recoupment, evidence of duplication of benefits;
assistance provided in error (i.e., the applicant was not eligible for the assistance they received); misuse of funds; and
fraud (FEMA, IAPPG, pp. 176-178).
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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 to appeal the
potential debt. If they do not appeal the potential debt or if FEMA denies their appeal, 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 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
covers, limitations related to the IHP period of assistance, which is generally limited to a period
of 18 months from the date of the declaration, and limitations related to avoiding assistance that
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
assistance covers. In short: “IHP assistance does not address all damages resulting from a
disaster.”201
To provide some examples of IHP assistance limitations, the IHP does not provide assistance to
• Enable homeowners to repair or replace vacation properties or secondary
residences. The IHP only provides financial assistance for Home Repair or Home
Replacement when the disaster resulted in damage to the owner-occupied
primary residence.202 Relatedly, Home Repair Assistance and Home Replacement
Assistance are unavailable to landlords unless they permanently reside in the
damaged dwelling.203
• Enable homeowners to repair all disaster-caused damage or restore their home to
its pre-disaster condition. Home Repair Assistance only provides assistance to
restore the home to a safe, sanitary, or functional condition.204
• Enable homeowners to make improvements using Home Repair Assistance.
Generally, 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-

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, IAPPG, p. 46. For additional information, see the “Applicant Eligibility” section.
200 42 U.S.C. §5174(h). For additional information, see the “Legislative Changes and Significant Program Updates:
Housing Assistance” and “Legislative Changes and Significant Program Updates: ONA” sections.
201 GAO, Disaster Assistance: IHP, pp. 10 and 18.
202 42 U.S.C. §5174(b)(1), (c)(2)(A), (c)(3)(A); FEMA, IAPPG, p. 43; GAO, Disaster Assistance: IHP, p. 18.
203 42 U.S.C. §5174(b)(1); FEMA, IAPPG, pp. 87 and 92.
204 44 C.F.R. §206.117(b)(2)(i)(E); FEMA, IAPPG, p. 85; GAO, Disaster Assistance: IHP, p. 18.
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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 all damaged personal property items. There
are limitations on the amount and type of Personal Property Assistance items that
are eligible for repair or replacement, and FEMA also considers household
composition in making award determinations.206
Limitations on the Period of Availability
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.,
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
Direct Temporary Housing Assistance). For most forms of IHP assistance, the period of assistance
is generally limited to a period of 18 months from the date of the declaration (unless extended).207
However, some forms of IHP assistance have shorter periods of availability.
Some types of IHP assistance also include additional time-based considerations. For example, the
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
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.208
Different forms of IHP assistance have different limitations on the availability of assistance,
including set time periods of availability (although extensions may be approved), limitations on
the maximum amount of financial assistance that can be provided, or a combination of time- and
financial-based limitations. Table 4 describes the time and financial limitations for the various
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”).
206 44 C.F.R. §206.119(b)(2)(i) and (c). See also GAO, Disaster Assistance: IHP, p. 20. Figure 8 of GAO’s Disaster
Assistance: IHP report provides a side-by-side example of how household composition affects eligibility for home
damage and personal property losses.
207 42 U.S.C. §5174(c)(1)(B)(iii); and 44 C.F.R. §206.110(e); GAO, Disaster Assistance: IHP, p. 10. The period of
assistance may be extended—by the 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 “due
to extraordinary circumstances an extension would be in the public interest.”
208 FEMA, IAPPG, 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:
Lodging Expense
Available from the incident start date and not to
Does not count toward the maximum amount of financial
Financial
Reimbursement
exceed seven days from the Initial Rental Assistance
assistance award for Housing Assistance.
approval date.
Initial Rental
Available for up to two months.
Does not count toward the maximum amount of financial
Assistance
assistance award for Housing Assistance.

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

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

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

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

Temporary Housing
declaration.

Units

Direct Lease
Available for up to 18 months from the date of the
NA
declaration.
CRS-36

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

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

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

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

Subject to the maximum amount of financial assistance for ONA.

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

Assistance

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

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

Subject to the maximum amount of financial assistance for ONA.
CRS-37

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

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

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

Subject to the maximum amount of financial assistance for ONA.
Sources: 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-
1.1.pdf; and Memorandum from Keith Turi, FEMA Assistant Administrator, Recovery Directorate to FEMA Regional Administrators, “RE: Amendment to FP 104-009-03,
Individual Assistance Program and Policy Guide, Version 1.1,” September 2, 2021, pp. 11-12, https://www.fema.gov/sites/default/files/documents/fema_iappg-policy-
amendments-memo.pdf.
Notes: Specific accessibility-related real and personal property items are not subject to the maximum amount of financial assistance that may be provided for Housing
Assistance 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
Defining “Duplication of Benefits”
assistance that could constitute a duplication of
(DOB)
benefits, including in the provision of IHP
There is a statutory prohibition on providing a
assistance.209 Additionally, when applying for IHP
duplication of benefits. 42 U.S.C. §5155 requires
assistance, applicants “must agree to return funds
the President, in consultation with the heads of
to FEMA when the assistance provided by FEMA
the federal agencies administering financial
assistance programs, to “assure that no such
duplicates assistance from another source.”210
person ... wil receive such assistance with
Federal agencies are supposed to coordinate to
respect to any part of such loss as to which he
has received financial assistance under any other
avoid providing a duplication of benefits, and to
program or from insurance or any other source.”
rectify situations when a duplication occurs.211 To
As explained in FEMA’s regulation at 44 C.F.R.
prevent a duplication of benefits from occurring,
§206.191(d)(1)(i), a duplication of benefits occurs
FEMA’s regulations include a delivery sequence
when an agency provides assistance, but providing
for disaster assistance, which “establishes the order
such assistance was the primary responsibility of
in which disaster relief agencies and organizations
another agency and that agency with primary
provide assistance.”
responsibility later provides assistance.
212 For example, before disaster
survivors may receive Housing Assistance, they
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
significantly delayed, then federal assistance may be available.213

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
ineligible to receive FEMA COVID-19 Funeral Assistance. FEMA cited duplication of benefits as the justification,
explaining,
“Any source of payment designated specifically to pay for a funeral prior to death is considered a duplication
and is not eligible for reimbursement. COVID-19 Funeral Assistance may not duplicate burial or funeral
insurance proceeds, pre-planned or pre-paid funeral contracts, pre-paid trust for funeral expenses,
irrevocable trust for Medicaid, financial assistance from voluntary organizations, government programs or
agencies, or any other sources specifically designated for funeral expenses. Any eligible COVID-19 Funeral
Assistance wil be reduced by the amount of other assistance you received for the same expenses.”
(FEMA, “Funeral Assistance 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 04-21-0001,
June 29, 2021, https://www.fema.gov/sites/default/files/documents/fema_covid-19-funeral-assistance-interim-policy-
version-2_06-29-2021.pdf.)

209 42 U.S.C. §5155; 44 C.F.R. §206.191.
210 FEMA, IAPPG, p. 176. In addition to returning funds that duplicate assistance provided from another source,
applicants must agree to return funds that were provided in error, spent on expenses inappropriately, or obtained
through fraudulent means.
211 44 C.F.R. §206.191(b)(1).
212 44 C.F.R. §206.191(d)(1)(i) and (d)(2).
213 44 C.F.R. §206.191(d)(2)(ii). See also 44 C.F.R. §206.113(a)(3); FEMA, IAPPG, p. 51. FEMA’s regulations state
“FEMA may only provide assistance: … In a situation where the applicant has insurance, when the insured individual
or household’s insurance proceeds have been significantly delayed [i.e., 30 days 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
FEMA or the State from insurance proceeds that he, she or they receive later….”
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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.
Specifically, 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
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
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
may then be eligible for SBA-Dependent ONA.214 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
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.215
FEMA may coordinate with voluntary agencies to address outstanding unmet needs when disaster
survivors have received all of the federal assistance for which they are eligible.216 Other forms of
federal assistance may also be available to meet the unmet needs of disaster survivors, depending
on the disaster.217
IHP Challenges and Congressional Considerations
The following sections address some of the potential IHP-related challenges and considerations
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
considering whether FEMA’s current IHP assistance programs are sufficient to meet the needs of
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
the President’s approval or denial of a Stafford Act major disaster declaration authorizing
Individual Assistance and/or Public Assistance.218 A common source of confusion and frustration
relates to the declaration decisionmaking process—specifically, the limited insight into FEMA’s
evaluation of the IA factors, and the lack of information regarding FEMA’s declaration
recommendation to the President.

214 44 C.F.R. §206.191(d)(2)(iii) and (d)(2)(iv).
215 For additional information on the SBA Disaster Loan Program, see CRS Report R41309, The SBA Disaster Loan
Program: Overview and Possible Issues for Congress, by Bruce R. Lindsay.
216 For more information on the sequence of delivery, see CRS Report R44553, SBA and CDBG-DR Duplication of
Benefits in the Administration of Disaster Assistance: Background, Policy Issues, and Options for Congress, by Bruce
R. Lindsay and Eugene Boyd; and CRS Report R45238, FEMA and SBA Disaster Assistance for Individuals and
Households: Application Processes, Determinations, and Appeals, by Bruce R. Lindsay and Elizabeth M. Webster.
217 For example, Congress may appropriate funding for the Department of Housing and Urban Development’s
Community Development Block Grant—Disaster Recovery (CDBG-DR) program (HUD, “Community Development
Block Grant Disaster Recovery Program,” https://www.hudexchange.info/programs/cdbg-dr/). See also CRS Report
R43520, Community Development Block Grants and Related Programs: A Primer, by Joseph V. Jaroscak.
218 Additional information on the declaration process can be found in the “Approving Requests for Individual
Assistance” section.
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Although there is some publicly available information related to the decision making process
associated with evaluating major disaster declaration requests, the available information is
limited. 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 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 President’s
decision to declare a major disaster or deny the request (as well as the assistance authorized and
the areas designated to receive such assistance).219 Historically, there was a PDA Report
publication requirement authorized in previous annual appropriations legislation.220 Although not
currently required by legislation, FEMA has continued to publish the PDA Reports for the major
disaster declaration requests to its website (beginning in FY2008 through the present).221
Congress could establish the PDA reporting requirement in permanent law and could 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
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
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
declaration request informed FEMA’s recommendation to the President. Portions of FEMA’s
evaluation of the factors and recommendation to the President may fall into one of the nine
exemptions to the Freedom of Information Act (FOIA; 5 U.S.C. §552) statute’s rules of
disclosure.222 For example, Exemption 5 applies to “inter-agency or intra-agency memorandums
or letters that would not be available by law to a party other than an agency in litigation with the

219 FEMA, “Preliminary Damage Assessment Reports,” https://www.fema.gov/disaster/how-declared/preliminary-
damage-assessments/reports (hereinafter FEMA, “PDA Reports”). The President may approve the governor’s request
in whole or in part (i.e., some or all forms of requested assistance may be authorized for some or all of the areas
requested).
220 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), the House Committee on Homeland
Security (House Homeland), the House Committee on Transportation and Infrastructure (T&I), and the House and
Senate Committees on Appropriations, and publish reports to FEMA’s website that summarize the damage assessment
information (i.e., the Preliminary Damage Assessment (PDA)) that was used to determine whether to declare a major
disaster. This PDA Report publication requirement was 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
(P.L. 114-4). The requirement continued as report language in FY2016 (the PDA reports were referred to as
“Preliminary Disaster Assessments” in Explanatory Statement Submitted By Mr. Rogers of Kentucky, Chairman of the
House Committee on Appropriations Regarding House Amendment No. 1 to the Senate Amendment on H.R. 2029—
Continued: Consolidated Appropriations Act, 2016, Congressional Record, 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
associated with H.R. 3931—Department of Homeland Security Appropriations Act, 2020 included the following
commentary: “Preliminary Damage Assessments.—The Committee is concerned that FEMA has stopped publishing
the reports and summaries of preliminary damage assessments 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
publishing these reports and summaries and encourages them to do so expeditiously” (U.S. Congress, House
Committee on Appropriations, Department of Homeland Security Appropriations Bill, 2020, 116th Cong., 1st sess., July
24, 2019, H.Rept. 116-180, p. 59).
221 FEMA, “PDA Reports.” It can take time for the most recent PDA reports to be published.
222 The Freedom of Information Act (FOIA; 5 U.S.C. §552). For additional information on the Freedom of Information
Act, including FOIA exemptions, see CRS Report R41933, The Freedom of Information Act (FOIA): Background,
Legislation, and Policy Issues, by Meghan M. Stuessy; CRS Report R46238, The Freedom of Information Act (FOIA):
A Legal Overview, by Daniel J. Sheffner; and CRS Infographic IG10019, The Freedom of Information Act (FOIA), by
Daniel J. Sheffner.
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agency.”223 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
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.
Revisions to FEMA’s IA Declarations Factors Guidance (states/territories) and the Tribal
Declarations Pilot Guidance, including to provide more specific information or scenarios that
illustrate 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
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
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
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
following a disaster, but it may not affect the ultimate outcome of declaration decisions.
Additionally, Congress could require FEMA to assess new approaches for evaluating the IA
factors that incorporate more quantitative data,224 and could consider requiring FEMA to revise
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
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
data sources for IHP financial assistance lack granularity.
Although FEMA makes information on the costs of Financial Housing Assistance publicly
available through the “OpenFEMA Data Sets” for Individual Assistance, as well as the declared
disasters web pages for presidentially declared Stafford Act emergencies and major disasters,226

223 5 U.S.C. §552(b)(5).
224 Challenges associated with FEMA’s evaluation of the IA factors, including related to the vagueness of the factors
and the lack of a quantitative approach, are addressed by Christopher Currie, Director, Homeland Security and Justice
Team, GAO, including in his responses to Representatives Thompson, Katko, and Barragan during a hearing by the
House Committee on Homeland Security focused on Ensuring Equity in Disaster Preparedness, Response, and
Recovery (U.S. Congress, House Committee on Homeland Security, Ensuring Equity in Disaster Preparedness,
Response, and Recovery, 117th Cong., 1st sess., October 27, 2021).
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, “Declared
Disasters,” https://www.fema.gov/disaster/declarations.
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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
Management Modernization System”), which is to include a disaster housing assistance
component.230 In June 2021, the Department of Homeland Security (DHS) reported to the GAO
that FEMA will 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
30, 2024.”231 Consistent with the GAO’s recommendations, with which DHS concurred,232
Congress could consider requiring FEMA to expand the IHP program and administrative data the
agency collects and maintains to ensure all of the data needed to accurately evaluate each
program’s implementation costs are collected.233 This could also help ensure FEMA is able to
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
activate in support of a specific disaster.234 Further, once the expanded direct housing assistance
data exists, Congress may seek for FEMA to publicly report on the costs of its Direct Housing

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/
products/gao-21-116 (see the status of Recommendation 1 as of May 15, 2023, in the Table: “Recommendations for
Executive Action”).
232 The GAO’s Disaster Housing: Improved Cost Data and Guidance report included two recommendations: the
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 program”; and (2) “specify the information needed to compare the projected costs of each direct housing program
in its guidance for assessing which programs to activate.” (GAO, Disaster Housing: Improved Cost Data and
Guidance, pp. 20 and 46.)
233 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 12; see also Department of Homeland Security
(DHS) 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/
2020-03/OIG-20-15-Feb20.pdf. For example, the DHS OIG found that “FEMA did not maintain complete records of
MHU [manufactured housing unit] and TPS [tank and pump systems] program costs.”
234 In 2011, the DHS OIG 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 not be
evaluated due to insufficient data) (DHS 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/sites/default/files/assets/Mgmt/OIG_11-
102_Aug11.pdf). The GAO also found that “cost data issues ... have persisted and largely precluded FEMA from
demonstrating the relative cost-effectiveness of its housing programs.... The data limitations also limited our ability to
compare the costs and cost-effectiveness of direct housing programs.... ” (GAO, Disaster Housing: Improved Cost
Data and Guidance, pp. 10-11).
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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).
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
IHP amount approved for Housing Assistance and ONA,236 some also provide the amount of
Housing Assistance awarded and the amount of ONA awarded.237 However, funding information
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
example, some of the datasets include data fields for Home Repair Assistance, Home
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.238 Assistance provided for all types of ONA is generally aggregated.239 To the extent
that granularity is provided with regard to awards for specific types of ONA, the data is limited to
Personal Property Assistance,240 but it is unclear how much assistance was provided for other
specific types of ONA.241 (See Table C-1 for a list of the data fields provided for each of the

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 the data field: Total
Approved IHP Amount, which refers to the “[t]otal amount approved in dollars under FEMA’s IHP program.”
237 For example, the Registration Intake and Individuals Household Program (RI–IHP) dataset provides the HA
[Housing Assistance] Amount and the ONA Amount, which refers to the “[t]otal amount awarded for Housing
Assistance (HA) in dollars from the Individual and Households Program (IHP)” and the “[t]otal amount awarded in
dollars for Other Needs Assistance (ONA) from the Individual and Households Program (IHP),” respectively.
238 For example, the Housing Assistance Program Data–Owners dataset includes a Repair/Replace Amount data field
that provides the “[t]otal amount of Repair and/or Replacement approved in dollars for Housing Assistance (HA) under
FEMA’s IHP program (note that renters are not eligible for this type of assistance because they do not own the
structure).” For the IHP Valid Registrations dataset, however, the Repair Amount and Replacement Amount are
separate data fields.
239 For example, the Housing Assistance Program Data–Owners dataset’s Other Needs Amount data field provides the
“[t]otal amount of Other Needs (ONA) assistance approved in dollars under FEMA’s IHP program (this could include,
personal property, transportation, medical, dental, funeral, essential tools, moving/storage, miscellaneous and other
needs).”
240 For example, the IHP Valid Registrations dataset provides the amount of ONA awarded for Personal Property
Assistance.
241 As an example of an exception to the statement that it is unclear how much assistance is provided for other types of
ONA, FEMA does track and provide publicly 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
information about the amount of Funeral Assistance provided. For example, on November 1, 2021, FEMA issued a
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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 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
programs can meet the needs of future disaster survivors, including disaster survivors of disasters
resulting in economic—rather than physical—losses.
Stafford Act emergency and major disaster declarations tend to contemplate natural disasters that
result in physical damages, such as hurricanes, floods, and wildfires.242 Emergencies and major
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 income as a result
of a disaster). Although there have been major disaster declarations for incidents that did not
result in extensive physical damages, these incidents have been historically uncommon (e.g., the
presidential Stafford Act major disaster declarations for the COVID-19 pandemic243 and the 1992
Los Angeles civil unrest).244 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
the COVID-19 pandemic, the President issued a presidential memorandum that authorized the
Lost Wages Assistance (LWA) program under ONA’s statutory authority to 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,
Federal assistance is needed to supplement State and local efforts and capabilities to save lives and to protect property
and 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.
§5122(1)). The Stafford Act defines “major disaster” as “any natural catastrophe (including any hurricane, tornado,
storm, high water, winddriven water, tidal wave, tsunami, earthquake, volcanic eruption, landslide, mudslide,
snowstorm, or drought), or, regardless of cause, any fire, flood, or explosion, in any part of the United States, which in
the determination of the President causes damage 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
disaster relief organizations in alleviating the damage, loss, hardship, or suffering caused thereby” (42 U.S.C.
§5122(2)).
243 For additional examples of public health incidents that received Stafford Act emergency declarations, see CRS
Insight IN11229, Stafford Act Assistance for Public Health Incidents, by Erica A. Lee and Bruce R. Lindsay.
244 With the exception of the California Fire during 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
the Stafford Act for other incidents of civil unrest were denied, including major disaster declaration 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
Access Pipeline in 2017, and civil unrest in Minneapolis, MN, related to the death of George Floyd in 2020. See
FEMA, “California Fire During 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 the federal response to
incidents of civil unrest, see CRS Report R46665, Stafford Act and Selected Federal Recovery Programs for Civil
Unrest: Historical Perspectives and Policy Observations, coordinated by Bruce R. Lindsay.
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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
information below),246 among other things.247
During the early response to the COVID-19 pandemic, Congress considered the federal
government’s options for providing rental assistance payments to individuals experiencing
financial hardship due to the pandemic.248 Additionally, the Surfside Building Collapse in June
2021, raised congressional questions about the availability of federal assistance for disaster
survivors with mortgages on destroyed or inaccessible homes.249 Although Rental Assistance is a
form of IHP assistance,250 it is premised on an individual being displaced from their primary
residence because it is uninhabitable, inaccessible, unavailable due to forced relocation, or
nonfunctional due to utility outages.251 FEMA does not have the statutory authority to provide
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
authorized the President to provide temporary mortgage or rental payments to or on behalf of
individuals 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
temporary mortgage and rental payments, and it also added the language predicating assistance on

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),
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,
P.L. 106-390) amended the Stafford Act to remove temporary mortgage and rental payments.
247 In a Los Angeles Times op-ed, then FEMA Regional Director, William Medigovich, stated that, “FEMA made an
exceptional effort to qualify the Los Angeles riots as a disaster under the Stafford Act, which does not include riot in its
definition of ‘disaster.’” William Medigovich, “Federal Aid for Riot Victims,” Los Angeles Times, January 27, 1993,
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
2017 stated that the governor’s request for a major disaster declaration was denied based on the determination that
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/
default/files/2020-09/PDAReportAppealDenialMD.pdf; and FEMA, “North Dakota—Civil Unrest Denial,”
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
federal assistance “was not warranted or appropriate” (FEMA, “Minnesota—Civil Unrest Denial of Appeal,
Preliminary Damage Assessment Report, August 18, 2020, https://www.fema.gov/sites/default/files/documents/
PDAReport_AppealDenial-MN.pdf).
248 FEMA, “Coronavirus (COVID-19) Response,” https://www.fema.gov/disaster/coronavirus.
249 FEMA, “Florida Surfside Building Collapse (3560-EM-FL),” https://www.fema.gov/disaster/3560.
250 42 U.S.C. §5174(c)(1)(A).
251 Stafford Act Section 408(b)(1) specifies that housing assistance is intended to assist “individuals and households
who are displaced from their predisaster primary residences or whose predisaster primary residences are rendered
uninhabitable, or with respect to individuals with disabilities, rendered inaccessible or uninhabitable, as a result of
damage caused by a major disaster [emphasis added]” (42 U.S.C. §5174(b)(1)). See also FEMA, IAPPG, pp. 80-81.
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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
hardship but not to exceed 18 months [emphasis added].253
DMA2K was generally intended to control the federal cost of disaster assistance; however, 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 bill.254
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
used, and also cited FEMA’s program implementation challenges.255 Despite challenges with the
program, the DHS OIG stated that the “effects of the 9/11 terrorist attack ... demonstrated genuine
need for programs such as this. Therefore, we have recommended ... 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-
title42-chap68-subchapIV-sec5174.pdf.
254 U.S. Congress, House Committee on Transportation 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/
hrpt40/CRPT-106hrpt40.pdf.
255 During the 108th Congress, then-DHS Deputy Inspector General, Richard “Rick” L. Skinner, included in his
statement, in the “Individual Assistance Review” section, with regard to “Eligibility Issues in the Mortgage and Rental
Assistance Program,” that “FEMA historically has not had to implement the Mortgage and Rental Assistance (MRA)
program on a large scale because previous disasters did not coincide with nor result in widespread unemployment and
national economic losses. From the inception of MRA until September 11, 2001, only $18.1 million had been awarded
under the program for 68 declared disasters, compared to approximately $76 million as a result of the New York
disaster alone. Because it was seldom used, Congress 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, Senate Committee on
Environment and Public Works, Subcommittee on Clean Air, Climate Change, and Nuclear Safety, Review of the
General Accounting Office Report on FEMA’s Activities After the Terrorist Attacks on September 11, 2001, 108th
Cong., 1st sess., 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, Review of the GAO Report on FEMA’s
Activities After September 11, 2001).
256 U.S. Congress, Review of the GAO Report on FEMA’s Activities After September 11, 2001, pp. 253-254 (Statement
of Rick Skinner, DHS 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
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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 Indian tribal governments to participate in and customize the delivery of IHP housing
assistance programs in their communities.262 However, insurance remains the best option for
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
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
wish to evaluate options to best meet the needs of future disaster survivors.

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.
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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
Declaration Request Timing
determine whether to recommend that Individual
Requesting states, territories, and tribes must
Assistance (IA) be authorized: one applies to
request an emergency declaration “within 5 days
states/territories pursuant to a governor’s request,
after the need for [emergency] assistance ...
and one applies to Indian tribal governments
becomes apparent, but no longer than 30 days
after the occurrence of the incident.” Major
pursuant to a chief executive’s request. These
disaster declaration requests must be submitted
factors are described in detail below. Additionally,
“within 30 days of the occurrence of the
a list of the factors considered for governors’
incident.” Extensions of the 30-day period may
requests, including FEMA’s considerations and
be requested in writing by the affected
sources for the information/data considered, is
state/territory or tribe during the 30-day period.
included in Table A-1. A list of the factors
(44 C.F.R. §206.35(a); 44 C.F.R. §206.36(a)).
considered for chief executives’ requests, including
FEMA’s considerations and sources for the information/data considered, is included in Table A-2.
Additional information about the declaration process is included in the “Approving Requests for
Individual Assistance” section 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
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).263 The factors were revised to establish what FEMA
characterized as “more objective” criteria for evaluating the need for assistance, clarify eligibility
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
drafting requests for major disaster declarations authorizing IA.264
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
disaster,” as well as the capabilities of the affected jurisdictions.265 Additionally, according to
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 Individual Assistance Declarations
Factors Guidance (hereinafter referred to as the IA Declarations Factors Guidance) would be
useful in evaluating the need for IHP assistance.266 The factors are also used to identify the

263 DHS/FEMA, “Factors Considered When Evaluating a Request for IA”; 44 C.F.R. §206.48(b).
264 FEMA, IA Declarations Factors Guidance.
265 DHS/FEMA, “Factors Considered When Evaluating a Request for IA,” 84 Federal Register 10633; and 44 C.F.R.
§206.48(b).
266 According to FEMA, “[w]hile FEMA’s regulations in 44 CFR 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
would still be relevant to [assessing] whether the event was beyond state and local capabilities as it related to [the] IHP.
Likewise, the Individual Assistance Declarations Factors Guidance (June 2019) would be relevant, in particular the
discussion of the Principal Factors for evaluating the need for IHP [italics added].” FEMA also noted that IHP
authorization pursuant to an emergency declaration is “extremely rare” and stated that the agency would encourage a
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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) (Figure 3 lists
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
declaration authorizing IA.267 Per the regulation,
State fiscal capacity (44 CFR 206.48(b)(1)(i)) and uninsured home and personal property
losses (44 CFR 206.48(b)(2)) are the principal factors that FEMA will consider when
evaluating the need for supplemental Federal assistance under the Individuals and
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
Individuals and Households Program is not clear from the evaluation of the principal
factors, FEMA will turn to the other factors to determine the level of need.268
Factor 1: State Fiscal Capacity and Resource Availability
When FEMA evaluates the State Fiscal Capacity and Resource Availability (44 C.F.R.
§206.48(b)(1)) factor, FEMA considers the availability of government and private-sector
resources,269 and the circumstances that contributed to the state having insufficient resources,
potentially necessitating supplemental federal assistance.270 The following factors are evaluated:
1. Fiscal Capacity (44 C.F.R.
Defining “TTR” and “GDP”
§206.48(b)(1)(i)—a principal factor for the
Total Taxable Resources (TTR) represents the
IHP):271 FEMA evaluates the state’s capacity
“unduplicated sum of the income flows
to manage disaster response and recovery by
produced within a State and the income flows,
considering
received by its residents, which a State could
potentially tax.”
a. State Total Taxable Resources (TTR):
FEMA first considers the state’s TTR,
(FEMA, IA Declarations Factors Guidance, p. 7.)
which is an annual fiscal capacity

estimate calculated by the U.S.
State gross domestic product (GDP) measures
Department of the Treasury (TTR data is
the “sum of the distributions by industry and
state of the components of gross domestic
available for the 50 states and the
income which is the sum of the costs incurred
District of Columbia). “Increases or
and incomes earned in the production of
decreases in TTR could indicate a
GDP.”
strengthening or declining State
(FEMA, IA Declarations Factors Guidance, p. 8.)
economy.”272

state that is considering requesting an emergency declaration authorizing IA—IHP to instead consider requesting a
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 and households to warrant IHP are likely to have the
need for other types of Individual Assistance.... ” (email correspondence from FEMA Congressional Affairs staff,
November 27, 2019).
267 DHS/FEMA, “Factors Considered When Evaluating a Request for IA,” 84 Federal Register 10663; and 44 C.F.R.
§206.48(b).
268 44 C.F.R. §206.48(b).
269 FEMA considers the availability of local, state/territory/tribal government, nongovernmental organizations, and
private sector resources.
270 44 C.F.R. §206.48(b)(1).
271 Additional discussion 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.
272 44 C.F.R. §206.48(b)(1)(i)(A). FEMA, IA Declarations Factors Guidance, p. 7. Total taxable resources (TTR) is
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b. State Gross Domestic Product (GDP): FEMA can also consider the state’s
GDP (which is available when considering requests by the territories), and
may do so when TTR data is unavailable or inaccurate/misleading because
there is a two-year lag.273
c. Per Capita Personal Income by Local Area: FEMA can use per capita
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
personal income may have a smaller tax base and fewer available resources,
which could indicate the need for supplemental federal assistance.274 FEMA’s
guidance explains that “[p]er capita personal income by local area when
considered holistically with TTR (and when appropriate GDP by State) will
help to identify areas of concentrated need at the micro local area and
individual level in addition to the macro State level.”275
d. Other Factors: FEMA may also consider other information provided by the
state related to its fiscal capacity, such as an incident that affects the state’s
ability to collect funds (e.g., a disaster that reduces tourism and affects the
tax base).276
2. Resource Availability (44 C.F.R. §206.48(b)(1)(ii)): FEMA evaluates whether
the disaster-caused needs can be met using non-Stafford Act sources by
evaluating277
a. State, Tribal, and Local Government; Non-Governmental Organizations
(NGO); and Private Sector Activity: FEMA considers the resources and
services that have and will 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 Treasury (Treasury) (ADAMHA [Alcohol, Drug Abuse, and Mental
Health Administration] Reorganization Act, P.L. 102-321). An increase in TTR may indicate a strengthening state
economy and a decrease may indicate a declining economy; or a lower TTR may indicate a state economy that is less
resilient to the financial burdens associated with disasters and a higher TTR may indicate higher resilience (FEMA, IA
Declarations Factors Guidance, pp. 7-8). TTR data organized by state is available from the Treasury (Treasury, “Total
Taxable Resources, Estimates,” https://home.treasury.gov/policy-issues/economic-policy/total-taxable-resources). For
an overview of TTR, including how it is estimated and the limitations of using TTR as a measurement of fiscal
capacity, see Treasury, Office of Economic Policy, Treasury Methodology for Estimating Total Taxable Resources
(TTR), December 2002, https://www.treasury.gov/resource-center/economic-policy/Documents/nmpubsum.pdf.
273 FEMA, IA Declarations Factors Guidance, p. 8. FEMA’s guidance notes, with regard to the two-year TTR data lag,
“It is possible that a State’s TTR data could be strong or trending upwards when in fact recent events may have caused
a significant drop in the State fiscal capacity that is not yet reflected. This significant drop could be caused by events
such as a previous disaster or a financial downturn.” 44 C.F.R. §206.48(b)(1)(i)(B). FEMA, IA Declarations Factors
Guidance, p. 8. TTR is provided for the 50 states and the District of Columbia. State gross domestic product (GDP)
data is calculated by the Bureau of Economic Analysis (BEA) for the states and territories, with the exception of Puerto
Rico, the data for which is published by the U.S. Census Bureau (FEMA, IA Declarations Factors Guidance, p. 8; see
also BEA, “Regional Economic Accounts,” https://www.bea.gov/data/economic-accounts/regional (hereinafter BEA,
“Regional Economic Accounts”)). For an overview of State GDP, including how it is estimated, see U.S. Department
of Commerce, BEA, Gross Domestic Product by State Estimation Methodology, 2017, https://www.bea.gov/sites/
default/files/methodologies/0417_GDP_by_State_Methodology.pdf.
274 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
divided by the resident population of the area.” It may indicate a locality has a smaller tax base and, therefore, fewer
resources to help local disaster survivors (FEMA, IA Declarations Factors Guidance, p. 8). Local area per capita
income data is collected from the BEA (BEA, “Regional Economic Accounts”).
275 FEMA, IA Declarations Factors Guidance, p. 8.
276 44 C.F.R. §206.48(b)(1)(i)(D); FEMA, IA Declarations Factors Guidance, p. 8.
277 44 C.F.R. §206.48(b)(1)(ii); FEMA, IA Declarations Factors Guidance, p. 8.
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For example, related to considering the need for housing assistance, states
can provide information about affordable housing resources within a
reasonable commuting distance of the affected area.278
b. Cumulative Effect of Recent Disasters: FEMA considers the state’s recent
disaster history, including both gubernatorial (i.e., state-level) and
presidential (i.e., Stafford Act) disaster declarations, occurring in the
previous 24-month period, which could affect the availability of recovery
resources. FEMA is particularly interested in disasters occurring in the
current budget/fiscal cycle.279
Factor 2: Uninsured Home and Personal Property Losses
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-
State Preliminary Damage Assessment (PDA) process to examine the extent of damage and
estimated cost of IHP assistance.280 The state may provide the following PDA data for FEMA’s
evaluation:
1. Cause of Damage: the “peril that caused the disaster damage” (e.g., a hurricane),
and whether the disaster survivors have insurance coverage for that peril;281
2. Impacted Jurisdictions and Concentration of Damage: the concentration of
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
supplemental federal assistance because a small area has significant damage;282
3. Impacted Homes and Degree of Damage: the number of homes damaged and
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
needed;283
4. Estimated Cost of Assistance: the estimated cost of assistance based on the PDA
data284 and historical data related to FEMA assistance, which helps determine the

278 44 C.F.R. §206.48(b)(1)(ii)(A); FEMA, IA Declarations Factors Guidance, p. 9. The FEMA Preliminary Damage
Assessment Guide provides information regarding assessing available state/territory/tribal and local government
resources, as well as voluntary organization resources on page 34.
279 44 C.F.R. §206.48(b)(1)(ii)(B). FEMA, IA Declarations Factors Guidance, p. 9. The FEMA Preliminary Damage
Assessment Guide provides information regarding the cumulative effect of recent disasters on pages 34-35.
280 44 C.F.R. §206.48(b)(2); FEMA, IA Declarations Factors Guidance, p. 9.
281 44 C.F.R. §206.48(b)(2)(i); FEMA, IA Declarations Factors Guidance, p. 9. The FEMA Preliminary Damage
Assessment Guide provides information regarding documenting the cause of damage on pages 36-37.
282 44 C.F.R. §206.48(b)(2)(ii); FEMA, IA Declarations Factors Guidance, p. 9. The FEMA Preliminary Damage
Assessment Guide provides information regarding documenting the concentration of damage on page 37.
283 44 C.F.R. §206.48(b)(2)(iii); see information on the categories of home damage in FEMA, Preliminary Damage
Assessment Guide, p. 28. Per FEMA’s IA Declarations Factors Guidance, the state typically provides information on
the number of homes impacted and degree of damage at the county- and state-level (FEMA, IA Declarations Factors
Guidance, p. 9).
284 FEMA, Preliminary Damage Assessment Guide, p. 28. “The cost of assistance estimate is established by assessing
and categorizing the degree of damage of disaster-impacted residences. This calculation is mostly data driven, is
calculated with FEMA support, and encompasses a significant portion of a Presidential disaster declaration request.”
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“probable grant assistance that will be awarded for ONA in addition to grant
assistance for housing”;285
5. Homeownership Rate: the estimated rate of homeownership for the affected
homes, which may influence whether the IHP is needed, and what types of
housing assistance should be made available;286
6. Insurance Coverage: the percentage of affected applicants with insurance for the
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
is intended to assist with uninsured or under-insured necessary expenses and
serious needs;287 and
7. Other: other relevant PDA data submitted by the state that may demonstrate a
need for supplemental federal assistance for individuals.288
Factor 3: Disaster Impacted Population Profile
When FEMA 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
evaluate whether there is an increased need for supplemental federal assistance.289 FEMA
considers population data reported by the U.S. Census Bureau and other federal agencies,
including the percentage of the population
1. in poverty status;
2. receiving government assistance (e.g., Supplemental Nutrition Assistance
Program (SNAP) benefits);
3. the pre-disaster unemployment rate;
4. 65 years of age or older;
5. 18 years of age or younger;
6. who are individuals with disabilities;

285 44 C.F.R. §206.48(b)(2)(iv). The estimated cost of assistance can be used by states to determine the likelihood they
will receive a major disaster declaration (FEMA, IA Declarations Factors Guidance, pp. 9-10 and 14-15). The FEMA
Preliminary Damage Assessment Guide provides information for states to estimate the cost of assistance on pages 28-
32.
286 44 C.F.R. §206.48(b)(2)(v); FEMA, IA Declarations Factors Guidance, p. 10. IHP assistance is provided for both
homeowners and renters, but different forms of IHP assistance are available to homeowners (e.g., homeowners may be
edible for Home Repair and Home Replacement assistance, in addition to forms of Direct Housing Assistance).
287 44 C.F.R. §206.48(b)(2)(vi). According to FEMA’s guidance, with regard to assessing insurance coverage, “[t]he
State should 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 insurance
penetration rates for flood damages and Census data to determine homeowners’ insurance coverage percentages....
[T]he percentage of owner-occupied homes with a mortgage may be used to estimate an insurance penetration rate, due
to the assumption that a home with a mortgage would require home insurance coverage” (FEMA, IA Declarations
Factors Guidance, p. 10). The FEMA Preliminary Damage Assessment Guide provides information for states to
estimate the level of applicable insurance coverage on pages 33-34 and in Appendix I.
288 44 C.F.R. §206.48(b)(2)(vii); FEMA, IA Declarations Factors Guidance, p. 10.
289 44 C.F.R. §206.48(b)(3); FEMA, IA Declarations Factors Guidance, pp. 10-11. Data sources include Census data,
as well as information from the Bureau of Labor and Statistics. In addition to helping FEMA evaluate appropriate
forms of assistance, this information may also be used to help direct outreach efforts (e.g., FEMA may need to provide
information in multiple languages based on the languages commonly spoken in an affected jurisdiction). The FEMA
Preliminary Damage Assessment Guide provides information to help states illustrate the disaster’s impact on affected
populations on page 37.
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7. who speak a language other than English and speak English less than “very
well”; and
8. FEMA also considers “any unique considerations regarding American Indian and
Alaskan Native Tribal populations.”290
Factor 4: Impact to Community Infrastructure
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
infrastructure components, which may make it difficult for disaster survivors to reside in the
community and may hinder community recovery.291 FEMA considers state-provided information
on disruptions to the following community services lasting more than 72 hours:
1. Life-Saving and Life-Sustaining Services: “services that provide an essential
community function that, if interrupted, will affect public health and safety in a
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-
sustaining service), and the unavailability of which may indicate the need for a
more robust response;292
2. Essential Community Services: services that improve quality of life, such as
schools and childcare providers, and social services, disruptions to which will
hinder community recovery;293 and
3. Transportation Infrastructure and Utilities: infrastructure and services, the
unavailability of which could, for example, render housing uninhabitable or
inaccessible, or affect the delivery of services, hindering community recovery.294
Factor 5: Casualties
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
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
Counseling).295
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, IA Declarations Factors Guidance, pp. 10-11. According to FEMA’s
guidance, “[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 needed after a disaster.”
291 44 C.F.R. §206.48(b)(4); FEMA, IA Declarations Factors Guidance, pp. 11-12. The FEMA Preliminary Damage
Assessment Guide provides information for states to estimate the impact to critical community infrastructure on page
38.
292 44 C.F.R. §206.48(b)(4)(i); FEMA, IA Declarations Factors Guidance, p. 12.
293 44 C.F.R. §206.48(b)(4)(ii); FEMA, IA Declarations Factors Guidance, p. 12.
294 44 C.F.R. §206.48(b)(4)(iii); FEMA, IA Declarations Factors Guidance, p. 12.
295 44 C.F.R. §206.48(b)(5); FEMA, IA Declarations Factors Guidance, p. 12. The FEMA Preliminary Damage
Assessment Guide provides information for states to estimate the disaster-caused deaths and injuries, which indicates
disaster-caused trauma, on page 39.
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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
potential for a prolonged recovery process due to people being out of work, and may indicate the
need for Disaster Unemployment Assistance.296
Factors Considered When 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),
amended the Stafford Act to allow the chief executive of an affected Indian tribal government to
request a major disaster or emergency declaration (alternatively, the Indian tribe may receive
assistance through the state’s declaration).297 Initially, FEMA used the same factors to evaluate a
governor or chief executive’s request for a presidential major disaster declaration, which allowed
Indian tribal governments to exercise this authority immediately upon SRIA’s enactment.298
However, FEMA’s release of the Tribal Declarations Pilot Guidance in January 2017, made
effective specific factors considered when evaluating a chief executive’s request for a major
disaster declaration.299 When the pilot period concludes (no specific time has been set), FEMA
will develop regulations informed by the pilot.300
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
event has overwhelmed the tribal government’s capabilities, making Stafford Act assistance
necessary.301
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:302
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, IA Declarations Factors Guidance, pp. 12-13. To be eligible for Disaster
Unemployment Assistance (DUA), an individual must (1) have been previously employed or self-employed; (2)
rendered jobless or had their employment interrupted as a direct result of a major disaster; and (3) be ineligible for
regular unemployment insurance (44 C.F.R. §206.141; 42 U.S.C. §5177; FEMA, IAPPG, pp. 9 and 239-243). For more
information on Disaster Unemployment Assistance, see CRS Report RS22022, Disaster Unemployment Assistance
(DUA), by Julie M. Whittaker.
297 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).
298 According to FEMA’s website “Tribal 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
29, 2013, when SRIA was enacted, through January 9, 2017, when FEMA released its Tribal Declarations Pilot
Guidance on January 10, 2017.
299 FEMA, Tribal Declarations Pilot Guidance.
300 FEMA, Tribal Declarations Pilot Guidance, p. 3.
301 FEMA, Tribal Declarations Pilot Guidance, p. 34. “Appendix D; Tribal-Specific Considerations” of FEMA’s
Preliminary Damage Assessment Guide includes useful resources and unique considerations for Indian tribal
governments during the PDA process.
302 FEMA, Tribal Declarations Pilot Guidance, p. 34.
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.”
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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.305
Factor 2: Availability of Housing Resources
When FEMA evaluates the Availability of Housing Resources factor, FEMA considers the
availability of accessible temporary housing resources.306
Factor 3: Casualties
When FEMA evaluates the Casualties factor, FEMA considers disaster-caused “deaths or injuries
[including] of cultural, religious, and government leaders.”307
Factor 4: Impact to Community Infrastructure
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
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
power failure).308
Factor 5: Disaster Impacted Population Profile
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
recovery support (e.g., people with disabilities and others with access and functional needs).309
Factor 6: Voluntary Agency and Other Assistance
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
and state governments.310
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, Tribal Declarations Pilot Guidance, p. 34. The Indian tribal government may request that FEMA expand IA
eligibility to extend assistance to non-enrolled members of the tribal community, including “adopted children, widows
and widowers, and descendants” (FEMA, Tribal Declarations Pilot Guidance, p. 18).
305 FEMA, Tribal Declarations Pilot Guidance, p. 37.
306 FEMA, Tribal Declarations Pilot Guidance, p. 37.
307 FEMA, Tribal Declarations Pilot Guidance, p. 37.
308 FEMA, Tribal Declarations Pilot Guidance, p. 37.
309 FEMA, Tribal Declarations Pilot Guidance, p. 37.
310 FEMA, Tribal Declarations Pilot Guidance, p. 37.
311 FEMA, Tribal Declarations Pilot Guidance, p. 37.
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Factor 8: Unique Conditions that may Affect Tribal Governments
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
as: “[n]eeds associated with remote locations”;312 the disaster’s impact on the tribal government’s
economy or livelihood; and “[c]ultural or spiritual considerations.”313
Factor 9: Other Relevant Information
FEMA also considers Other Relevant Information provided by the tribal government.314

Table A-1. IA Factors for a Governor’s Major Disaster Declaration Request
Authorizing IA
Applies to Affected States and Territories
Supporting Information/Data
IA Factors
FEMA Considers
Sources
State Fiscal Capacity and Resource
Availability of state/territory
U.S. Department of the Treasury,
Availabilitya
resources and circumstances
Bureau of Economic Analysis,
contributing to the lack thereof.
State/territory reported other
limits on a state/territory’s treasury
or ability to col ect funds and
resource availability
Uninsured Home and Personal
Disaster-caused real and personal
State/territory reported fol owing
Property Lossesb
property losses, including
the Preliminary Damage
consideration of whether losses
Assessment
were insured and the estimated
cost of assistance.

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.
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Supporting Information/Data
IA Factors
FEMA Considers
Sources
Disaster Impacted Population
Demographics of the affected
U.S. Census Bureau (see the
Profile
population that may indicate
American Community Survey
additional needs and the need for a
(ACS)), other federal agencies
more robust response.
Impact to Community
Disaster-caused impacts to
State/territory reported
Infrastructure
community infrastructure that may
adversely affect the safety and
security of disaster survivors and
hinder community recovery.
Casualties
Number of individuals who are
State/territory reported
missing, injured, or deceased due to
the disaster, resulting in trauma to
the community.
Disaster Related Unemployment
Number of disaster survivors who
State/territory reported
lost their work or became
unemployed due to the disaster,
and who do not qualify for standard
unemployment insurance.
Sources: 44 C.F.R. §206.48(b); FEMA, Individual Assistance Declarations Factors Guidance, June 2019,
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.
Notes: Per 44 C.F.R. §206.48(b), “FEMA will always consider all relevant information submitted as part of a
declaration request.”
a. Fiscal Capacity is a principal factor for the IHP (44 C.F.R. §206.48(b)(1)(i)).
b. Uninsured Home and Personal Property Losses is a principal factor for the IHP (44 C.F.R. §206.48(b)(2)).
Table A-2. IA Factors for a Chief Executive’s Major Disaster Declaration Request
Authorizing IA
Applies to Affected Federally Recognized Tribes
Supporting Information/Data
IA Factors
FEMA Considers
Sources
Uninsured Home and Personal
Disaster-caused real and personal
Tribe reported fol owing the
Property Lossesa
property losses of enrol ed tribal
Preliminary Damage Assessment
members and—if requested by the
tribe—members of the tribal
community, including consideration
of the amount of damage and
whether there are high
concentrations of damage.
Availability of Housing Resources
Availability of temporary housing
Tribe reported
resources.
Casualties
Number of individuals who are
Tribe reported
missing, injured, or deceased due to
the disaster, including cultural,
religious, and government leaders.
Impact to Community
Disaster-caused impacts to
Tribe reported
Infrastructure
community infrastructure that may
adversely affect the safety and
security of disaster survivors.
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Supporting Information/Data
IA Factors
FEMA Considers
Sources
Disaster Impacted Population
Demographics of the affected
U.S. Census Bureau, tribe reported
Profile
population—including populations
unique considerations not reflected
with greater needs—that may
in U.S. Census Bureau data
indicate the need for a more robust
response.
Voluntary Agency and Other
Ability of state or local government, Tribe reported
Assistance
or voluntary agency resources to
meet the needs of disaster
survivors.
Tribal Government Resources
Availability of tribal resources for
Tribe reported
response or recovery, including
resources that have been or wil be
used.
Unique Conditions that Affect
Needs or conditions unique to the
Tribe reported
Tribal Governments
tribal community.
Other Relevant Information
Other relevant information
Tribe reported
provided by the tribe.
Sources: FEMA, Tribal Declarations Pilot Guidance, January 2017, pp. 36-38, https://www.fema.gov/sites/default/
files/2020-04/tribal-declaration-pilot-guidance.pdf; FEMA, Preliminary Damage Assessment Guide, August 2021, pp.
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—specifically the “disaster-related impacts to homes and
personal property are the principal factors FEMA and the President use to determine if the [tribe’s] request
[for a presidential major disaster declaration including IA] should be approved.” (FEMA, Preliminary Damage
Assessment Guide, 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
vary—especially 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
tribal 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
The governor or chief executive requests
The FEMA Regional Administrator
Disaster Declaration
a presidential declaration of emergency or reviews the governor or chief executive’s
and Individual
major disaster, as well as IA.
request and makes a recommendation to
Assistance (IA)
the President, who has the authority to
Authorization
approve or deny the declaration request
and request for IA.a
Housing Assistance
The state/territory/Indian tribal
FEMA administers financial housing
Administration
government may elect to administer
assistance, and may administer Direct
Direct Temporary Housing Assistance
Temporary Housing Assistance if the
and Permanent Housing Construction.b
state/territory/Indian tribal government

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

government is expected to establish the
FEMA coordinates with the State-Led
State-Led Disaster Housing Task Force.c
Disaster Housing Task Force.c
Other Needs
The state/territory/Indian tribal
FEMA may administer ONA when the
Assistance (ONA)
government selects the ONA
state/territory/Indian tribal government
Administration
administration option and may elect to
elects to use the FEMA Option, or FEMA
solely administer ONA (i.e., the
may co-administer ONA with the
State/Tribe Option) or co-administer
state/territory/Indian tribal government
ONA with FEMA (i.e., the Joint Option).
when the Joint Option is selected.d
The state/territory/Indian tribal
government may also elect for FEMA to
administer ONA (i.e., the FEMA Option).d
Housing Cost Share
0% (regardless of election to administer
100%e
Direct Temporary Housing Assistance or
Permanent Housing Construction).e
ONA Cost Share
25%f
75%f
Sources: 44 C.F.R. Part 206, Subparts B and D; 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-1.1.pdf (hereinafter
FEMA, IAPPG); FEMA, Tribal Declarations Pilot Guidance, January 2017, https://www.fema.gov/sites/default/files/
2020-04/tribal-declaration-pilot-guidance.pdf (hereinafter FEMA, Tribal Declarations Pilot Guidance).
Notes: In addition to the federal and state/territory/Indian tribal governments, local governments and nonprofit
organizations may also play roles in supporting the provision of housing assistance and assistance for other
needs.
a. 44 C.F.R. §206.37; FEMA, IAPPG, p. 3; and FEMA, Tribal Declarations Pilot Guidance, pp. 27-29.
b. §1211(a) of the Disaster Recovery Reform Act of 2018 (DRRA, P.L. 115-254). Prior to DRRA’s enactment
the federal government both administered and assumed the costs associated with IHP housing assistance.
Post-DRRA, although the federal government is stil responsible for housing assistance costs, state,
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territory, and Indian tribal governments may elect to administer Direct Temporary Housing Assistance and
Permanent Housing Construction.
c. FEMA, IAPPG, pp. 93-94. The State-Led Disaster Housing Task Force brings together federal, local, and
state/territory/Indian tribal governments, as well as private and nonprofit partners, to determine the scope
of the disaster-caused housing needs and develop potential solutions (see the FEMA IAPPG for specific State-
Led Disaster Housing Task Force duties).
d. 44 C.F.R. §206.120(b); FEMA, IAPPG, pp. 147-148; and FEMA, Tribal Declarations Pilot Guidance, pp. 22-23. The
state, territory, or Indian tribal government can select one of three options for the administration of ONA:
(1) the FEMA Option; (2) the Joint Option; or (3) the State, Territorial, or Indian Tribal Government
Option. Under the FEMA Option, FEMA is responsible for all tasks associated with the administration of
ONA. Under the State, Territorial, or Indian Tribal Government Option, FEMA provides ONA as a grant to
the state, territory, or Indian tribal government, which administers ONA. Under the Joint Option, the state,
territory, or Indian tribal government administers ONA jointly with FEMA, splitting responsibilities for
various administrative tasks (see Figure 30 in the IAPPG for the list of ONA administration responsibilities).
e. 42 U.S.C. §5174(g)(1); 44 C.F.R. §206.110(i)(1); and FEMA, IAPPG, p. 5.
f.
42 U.S.C. §5174(g)(2); 44 C.F.R. §206.110(i)(2); and FEMA, IAPPG, p. 5. Stafford Act Section 408(g)(2)(A)
specifies that “the Federal share shall be 75 percent [emphasis added]” (42 U.S.C. §5174(g)(2)(A)). This
framing indicates that the Stafford Act does not allow the federal share for ONA to be adjusted (although
this may be done through legislation). Additionally, “the non-Federal share shall be paid from funds made
available by the State [emphasis 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 provision for Public
Assistance Category B—Emergency Protective Measures states “[t]he Federal share of assistance under this
section shall be not less than 75 percent of the eligible cost of such assistance [emphasis added]” (42 U.S.C.
§5170b(b)), and FEMA has a regulation for increasing the Public Assistance federal share for emergency
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,
industry standard, machine-readable formats.”315 FEMA’s OpenFEMA Datasets include
Individual Assistance (IA) information related to the Individuals and Households Program (IHP),
including Housing Assistance and Other Needs Assistance (ONA).
Specifically, FEMA provides several datasets, which provide publicly available IA—IHP data:316
• Housing Assistance Program Data–Owners (according to FEMA’s description,
the data starts with disaster declaration DR-4116-IL, declared May 10, 2013);
• Housing Assistance Program Data–Renters (according to FEMA’s description,
the data starts with disaster declaration DR-4116-IL, declared May 10, 2013);
• Individuals and Households Program (IHP) Flood Damage;
• Individuals and Households Program—Valid Registrations (according to FEMA’s
description, the data starts with disaster declaration DR-1439-TX, declared
November 5, 2002);
• Individual Assistance Housing Registrants—Large Disasters; and
• Registration Intake and Individuals Household Program (RI–IHP) (according to
FEMA’s description, the data starts with disaster declaration DR-4116-IL,
declared May 10, 2013).317
Table C-1 includes a list of the data fields, with descriptions, associated with the provision of IHP
awards for each IA dataset.

315 FEMA, “OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets.
316 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
Program, and other “miscellaneous” data on data visualizations and metadata. See FEMA, “OpenFEMA Data Sets,”
https://www.fema.gov/about/openfema/data-sets.
317 FEMA, “OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets. FEMA’s datasets include
descriptions of how the data was generated and associated caveats, as well 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 unavailable for a dataset.
Housing
Housing
Individuals
Individuals
Individual
Registration
Assistance
Assistance
and
and
Assistance
Intake and
Households
Households
Housing
Individuals
Data Fields
Program
Program
Data—
Data—
Program
Program—
Registrants—
Household
Owners
Renters
(IHP) Flood
Valid
Large
Program
Damage
Registrations
Disasters
(RI–IHP)
Valid
✔
✔
—
—
—
✔
Registrationsa
Average
✔
—
—
—
—
—
FEMA
Inspected
Damageb
FEMA
✔
✔
—
✔
✔
—
Inspectionsc
Total FEMA
✔
—
—
✔
✔
—
Inspected
Damaged
Ranges of
✔
✔
—
✔
✔
—
FEMA
Inspected
Damagee
Eligible
✔
✔
✔
✔
—
✔
and/or
Approved for
IHP
Assistancef
Total IHP
✔
✔
✔
✔
—
✔
Amountg
Repair/
✔
✔
—
✔
✔
—
Replace
Amounth
Rental
✔
✔
—
✔
✔
—
Amounti
Personal
—
—
—
✔
—
—
Property
Amountj
HA Amountk
—
—
—
✔
—
✔
ONA
✔
✔
—
✔
—
✔
Amountl
Approved
✔
✔
—
—
—
—
Betweenm
Total Max
✔
✔
—
✔
—
—
Grantsn
Average
—
—
✔
—
—
—
Award
Amounto
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Housing
Housing
Individuals
Individuals
Individual
Registration
Assistance
Assistance
and
and
Assistance
Intake and
Households
Households
Housing
Individuals
Data Fields
Program
Program
Data—
Data—
Program
Program—
Registrants—
Household
Owners
Renters
(IHP) Flood
Valid
Large
Program
Damage
Registrations
Disasters
(RI–IHP)
Flood
—
—
—
✔
—
—
Insurance
Premium
Amountp
Referralsq
—
—
—
✔
—
✔
SBA
—
—
—
✔
—
—
Approvedr
Flood
—
—
—
✔
—
—
Damage
Amounts
Foundation
—
—
—
✔
✔
—
Damage
Amountt
Roof Damage
—
—
—
✔
✔
—
Amountu
Source: FEMA, “OpenFEMA Data Sets,” “Individual Assistance,” https://www.fema.gov/about/openfema/data-
sets#individual.
Notes: The data fields included in Table D-1 are current as of November 10, 2021. All of the IA datasets, with
the exception of the IHP Flood Damage dataset, include the disaster number, state, county, city, zip code, and a
unique ID assigned to the record. The IHP Flood Damage dataset includes the disaster number and state, as well
as the incident type. The Individuals and Households Program—Valid Registrations (hereinafter IHP Valid
Registrations) dataset includes the incident type and declaration date. The Individual Assistance Housing
Registrants—Large Disasters is hereinafter referred to as “Housing Registrants—Large Disasters.”
a. Valid Registrations: For the Housing Assistance Program Data—Owners and—Renters, and RI—IHP datasets,
Valid Registrations refers to the “[c]ount of FEMA registration[s] . . within the state, county, zip where the
registration is valid. In order to be a valid registration, the applicant must be in an Individual Assistance
declared state and county and have registered within the FEMA designated registration period.” The RI—
IHP dataset also includes the total numbers of valid registrations submitted through the call center, website,
and mobile devices (data fields are Valid Cal Center Registrations, Valid Web Registrations, and Valid
Mobile Registrations, respectively).
b. Average FEMA Inspected Damage: For the Housing Assistance Program Data—Owners dataset, Average
FEMA Inspected Damage refers to the “[a]verage inspected damage (based on FEMA’s inspection guidelines)
for valid registration owners within the state, county, zip that had a completed inspection.”
c. FEMA Inspections: For the Housing Assistance Program Data—Owners and—Renters datasets, Total
Inspected refers to the “[t]otal FEMA applicants who received an inspection.” For the IHP Valid Registrations
dataset, Inspection Issued address the question: “Has a FEMA inspection been issued to determine damage
amount?”; and Inspection Returned address the question: “Has a FEMA issued inspection been performed
to determine damage amount?” For the Housing Registrants—Large Disasters, Inspected Indicator answers the
question: “Has the applicant been inspected by FEMA?”
d. Total FEMA Inspected Damage: For the Housing Assistance Program Data—Owners dataset, Total
Damage refers to the “[t]otal damage recorded by FEMA at the time of inspection.” For the IHP Valid
Registrations dataset, RPFVL refers to the “FEMA-determined value of disaster-caused damage to real
property components, including floors, walls, access roads and bridges, electrical, plumbing, HVAC, etc.
Note: IHP does not address land damage”; and PPFVL refers to the “FEMA-determined value of disaster-
caused damage to personal property components, including appliances, furniture, etc. Note: IHP does not
address land damage.” For the Housing Registrants—Large Disasters, RPFVL refers to the “[r]eal property
damage amount observed by FEMA.”
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e. Ranges of FEMA Inspected Damage: For the Housing Assistance Program Data—Owners dataset, there
are different data fields related to the FEMA Inspected Damage associated with the “[c]ount of valid
registration owners within the state, county, zip that had a completed inspection (based on FEMA’s
guidelines) where the inspected damage fell between” different dol ar amounts, including (1) No FEMA
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
Inspected Damage > $30,000. For the Housing Assistance Program Data—Renters dataset, there are different
data fields related to inspections for Renters. “Renters do not receive a ful home inspection as they are
only eligible for the items that they own. Instead a degree of damage is assigned. This is a count of valid
registration renters who were 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. For
the IHP Valid Registrations dataset, Renter Damage Level refers to the “FEMA-determined level of damage to
a dwelling occupied by a renter. Minor, Moderate, Major, or Destroyed”; Destroyed addresses the
question: “Was the home destroyed by the disaster?” For the Housing Registrants—Large Disasters dataset,
Destroyed addresses the question: “Is the structure permanently uninhabitable”? Additionally, for the
Housing Registrants—Large Disasters dataset, Renter Damage Level refers to the “Level of Damage:
Moderate, Major, Destroyed”; and Personal Property Verified Loss refers to the “FEMA Verified Loss
captured during the inspection of personal property.”
f.
Eligible and/or Approved for IHP Assistance: For the Housing Assistance Program Data—Owners and—
Renters datasets, Approved for FEMA Assistance refers to the “[n]umber of FEMA applicants who were
approved for FEMA’s IHP assistance.” For the IHP Flood Damage dataset, Total Registrations refers to “[t]he
Total (sum) number of disaster survivor registrants awarded FEMA funds.” For the IHP Valid Registrations
dataset, IHP Eligible addresses the question: “Was the applicant eligible for the Individual Housing Program
(IHP)? NOTE: Applicants that received an HA and/or ONA award”; HA Eligible addresses the question:
“Was the applicant eligible for the Housing Assistance program? NOTE: Does not include applicants
licensed into Direct Housing that did not receive an HA award”; and ONA Eligible addresses the question:
“Was the applicant eligible for the Other Needs Assistance (ONA) program?” For the RI—IHP dataset, IHP
Eligible refers to the “[t]otal number of valid registrations eligible for IHP assistance”; HA Eligible refers to
the “[t]otal number of valid registrations eligible for Housing Assistance (HA)”; and ONA Eligible refers to
the “[t]otal number of valid registrations eligible for Other Needs Assistance (ONA).”
g. Total Approved IHP Amount: For the Housing Assistance Program Data—Owners and—Renters datasets,
Total Approved IHP Amount refers to the “[t]otal amount approved in dol ars under FEMA’s IHP
program.” For the IHP Valid Registrations dataset, Total Approved IHP Amount refers to the “[t]otal financial
IHP award for Housing Assistance (HA) and/or Other Needs Assistance (ONA), in U.S. dol ars.” For the
RI—IHP dataset, IHP Amount refers to the “[t]otal IHP Amount awarded in dol ars for Housing Assistance
(HA) and Other Needs Assistance (ONA) among eligible applicants for designated incident.” For the IHP
Flood Damage dataset, Total Award Amount refers to “[t]he Total (sum) amount awarded for Home repair,
replacement and personal property.”
h. Repair/ Replace Amount: For the Housing Assistance Program Data—Owners and—Renters datasets,
Repair/Replace Amount refers to the “[t]otal amount of Repair and/or Replacement approved in dol ars for
Housing Assistance (HA) under FEMA’s IHP program (note that renters are not eligible for this type of
assistance because they do not own the structure).” For Renters, there is the caveat that they are ineligible
for Home Repair/Replacement because they do not own the structure. For the IHP Valid Registrations and
for the Housing Registrants—Large Disasters datasets, Repair Amount and Replacement Amount are separate
data fields, where Repair Amount refers to the “[a]mount of Repair Assistance awarded in U.S. dol ars”; and
Replacement Amount refers to the “[a]mount of Replacement Assistance awarded in U.S. dol ars.”
i.
Rental Amount: For the Housing Assistance Program Data––Owners and—Renters datasets, Rental Amount
refers to the “[t]otal amount of Rental Assistance approved in dol ars for Housing Assistance (HA) under
FEMA’s IHP program.” For the IHP Valid Registrations and for the Housing Registrants—Large Disasters
datasets, Rental Assistance Amount refers to the “[a]mount of Rental Assistance awarded in U.S. dol ars.”
j.
Personal Property Amount: For the IHP Valid Registrations dataset, Personal Property Amount refers to
the “[a]mount of ONA awarded for Personal Property Assistance in U.S. dol ars.”
k. HA Amount: For the IHP Valid Registrations dataset, HA Amount refers to the “[t]otal amount awarded for
Housing Assistance under IHP.” For the RI—IHP dataset, HA Amount refers to the “[t]otal amount
awarded for Housing Assistance (HA) in dol ars from the Individual and Households Program (IHP).”
l.
ONA Amount: For the Housing Assistance Program Data—Owners and—Renters, and IHP Valid Registrations
datasets Other Needs Amount refers to the “[t]otal amount of Other Needs (ONA) assistance approved in
dol ars under FEMA’s IHP program (this could include, personal property, transportation, medical, dental,
funeral, essential tools, moving/storage, miscellaneous and other needs).” For the RI—IHP dataset, ONA
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Amount refers to the “[t]otal amount awarded in dol ars for Other Needs Assistance (ONA) from the
Individual and Households Program (IHP).”
m. Approved Between: For the Housing Assistance Program Data—Owners and—Renters datasets, there are
different data fields related to the “[c]ount of valid registration [owners or renters] within the state, county,
zip that received a financial grant from FEMA that fell between” different dol ar amounts, including (1)
Approved between $1 and $10,000; (2) Approved between $10,001 and $25,000; and (3) Approved
between $25,001 and Max.
n. Total Max Grants: For the Housing Assistance Program Data—Owners and—Renters datasets, Total Max
Grants refers to the “[c]ount of valid registration [owners or renters] within the state, county, zip that
received the maximum financial grant from FEMA.” For the IHP Valid Registrations dataset, the IHP Max
addresses the question: “[f]or disasters declared prior to August 1, 2017, did the applicant receive the
maximum IHP grant from FEMA?” It also includes the HA Max and ONA Max, which also relate to
maximum grants for Housing Assistance and ONA, respectively, for disasters declared after August 1, 2017
(which covers the period fol owing the enactment of the Disaster Recovery Reform Act of 2018, Section
1212 of which separated the maximum amount of financial assistance caps for Housing Assistance and
ONA).
o. Average Award Amount: For the IHP Flood Damage dataset, Average Award Amount refers to “[t]he
Average amount per Registrant awarded for Home repair, replacement and personal property.”
p. Flood Insurance Premium Amount: For the IHP Valid Registrations dataset, FIP Amount refers to “[t]he
amount of the applicant’s Flood Insurance Premium (FIP) that was paid for by FEMA, in U.S. dol ars.”
q. Referrals: For the IHP Valid Registrations dataset, IHP Referred refers to the “IHP referral status NOTE:
Does not include applicants referred to TSA only”; HA Referred addresses the question: “Was the applicant
referred to the Housing Assistance program?”; and ONA Referred addresses the question: “Was the
applicant referred to the Other Needs Assistance (ONA) program?” For the RI—IHP dataset, IHP Referrals
refers to the “[c]umulative number of applicants referred to the IHP Program”; HA Referrals refers to the
“[t]otal number of applications referred to the Housing Assistance (HA) Program”; and ONA Referrals
refers to the “[t]otal number of applications referred to the Other Needs Assistance (ONA) Program.”
r. SBA Approved: For the IHP Valid Registrations dataset, SBA Approved addresses the question: “Is applicant
approved for a Small Business Administration loan? Approval does not equate to acceptance of the loan as
one can be approved, but not accept.”
s. Flood Damage Amount: For the IHP Valid Registrations dataset, Flood Damage Amount refers to the
“FEMA-determined amount of damage to real and personal property due to flood damage, in U.S. dol ars.”
t.
Foundation Damage Amount: For the IHP Valid Registrations dataset, Foundation Damage Amount
refers to the “[a]mount of damage reported to the foundation of the damage dwelling, in U.S. dol ars.” For
the Housing Registrants—Large Disasters dataset, Foundation Damage Amount refers to the “[f]oundation
damage amount observed by FEMA.”
u. Roof Damage Amount: For the IHP Valid Registrations dataset, Roof Damage Amount refers to the
“[a]mount of damage reported to the damaged dwelling’s roof, in U.S. dol ars.” For the Housing
Registrants—Large Disasters dataset, Roof Damage Amount refers to “[r]oof damage amount observed by
FEMA.”
The Individuals and Households Program–Valid Registrations (IHP Valid Registrations) and the
Individual Assistance Housing Registrants–Large Disasters (Housing Registrants—Large
Disasters) datasets include detailed applicant information, including with regard to
• applicant age (IHP Valid Registrations);
• household composition (i.e., the number of individuals living in the household)
(IHP Valid Registrations and Housing Registrants—Large Disasters);
• 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
age; and over the age of 65) (IHP Valid Registrations);
• gross income (IHP Valid Registrations and Housing Registrants—Large
Disasters);
• whether the applicant is an owner or renter of the damaged dwelling (IHP Valid
Registrations and Housing Registrants—Large Disasters);
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• whether the damaged dwelling is the applicant’s primary residence (IHP Valid
Registrations and Housing Registrants—Large Disasters);
• the damaged dwelling residence type (e.g., single-family home, apartment) (IHP
Valid Registrations and Housing Registrants—Large Disasters);
• whether the applicant has homeowner’s insurance (IHP Valid Registrations and
Housing Registrants—Large Disasters);
• whether the applicant has flood insurance (IHP Valid Registrations and Housing
Registrants—Large Disasters); and
• the registration method (e.g., telephone, mobile application) (IHP Valid
Registrations).318
The Individuals and Households Program–Valid Registrations (IHP Valid Registrations) and the
Individual Assistance Housing Registrants–Large Disasters (Housing Registrants—Large
Disasters) datasets also include data fields to account for applicant-reported needs, as follows:
• utilities are out of service (IHP Valid Registrations);
• home damage (IHP Valid Registrations);
• whether habitability repairs are required (IHP Valid Registrations and Housing
Registrants—Large Disasters);
• automobile(s) damage (IHP Valid Registrations);
• emergency items needs (IHP Valid Registrations);
• food needs (IHP Valid Registrations);
• shelter needs (IHP Valid Registrations); and
• accommodations requirements for the applicant’s access or functional needs (IHP
Valid Registrations and Housing Registrants—Large Disasters).319
Further, the Individuals and Households Program–Valid Registrations (IHP Valid Registrations)
and the Individual Assistance Housing Registrants–Large Disasters (Housing Registrants—Large
Disasters) datasets also include data fields that provide detailed information about specific
damage to the property, including
• the water level (i.e., depth of water that affected the damaged dwelling) (IHP
Valid Registrations and Housing Registrants—Large Disasters);
• high-water mark location (IHP Valid Registrations);
• whether flood damage was recorded (IHP Valid Registrations);
• whether there is damage to the foundation (IHP Valid Registrations and Housing
Registrants—Large Disasters); and

318 FEMA, “OpenFEMA Dataset: Individuals and Households Program-Valid Registrations,” v1, last data refresh
November 6, 2021, https://www.fema.gov/openfema-data-page/individuals-and-households-program-valid-
registrations-v1; and FEMA “OpenFEMA Dataset: Individual Assistance Housing Registrants-Large Disasters,” v1,
last data refresh November 8, 2021, https://www.fema.gov/openfema-data-page/individual-assistance-housing-
registrants-large-disasters-v1.
319 FEMA, “OpenFEMA Dataset: Individuals and Households Program-Valid Registrations,” v1, last data refresh
November 6, 2021, https://www.fema.gov/openfema-data-page/individuals-and-households-program-valid-
registrations-v1; and FEMA “OpenFEMA Dataset: Individual Assistance Housing Registrants-Large Disasters,” v1,
last data refresh November 8, 2021, https://www.fema.gov/openfema-data-page/individual-assistance-housing-
registrants-large-disasters-v1. The IHP Valid Registrations dataset also includes the most recent Housing Assistance
decision (the data field for which is HA Status).
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• whether there is damage to the roof (IHP Valid Registrations and Housing
Registrants—Large Disasters).320
Finally, the Individuals and Households Program–Valid Registrations (IHP Valid Registrations)
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
are found eligible, including applicant eligibility for the following programs:
• Transitional Sheltering Assistance (TSA) program (and whether the applicant
checked into a TSA property) (IHP Valid Registrations and Housing
Registrants—Large Disasters);
• Rental Assistance (IHP Valid Registrations and Housing Registrants—Large
Disasters) (and the Rental Assistance end date, and rental resource city, state, and
zip code in the case of Housing Registrants—Large Disasters);
• Repair Assistance (IHP Valid Registrations and Housing Registrants—Large
Disasters);
• Personal Property Assistance (IHP Valid Registrations and Housing Registrants—
Large Disasters); and
• SBA Disaster Loan (Housing Registrants—Large Disasters).321

Author Information

Elizabeth M. Webster

Analyst in Emergency Management and Disaster
Recovery

Acknowledgments
Brion Long, Visual Information Specialist, developed the figures for this report.
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
American National Government; and Daniel J. Sheffner, Legislative Attorney, provided editorial
comments and suggestions.

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

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