FEMA Individual Assistance Programs: An Overview

FEMA Individual Assistance Programs: An Overview

FEMA Individual Assistance Programs:
April 17, 2024
An Overview
Elizabeth M. Webster
Following a presidential declaration of emergency or major disaster under the Robert T. Stafford
Specialist in Emergency
Disaster Relief and Emergency Assistance Act (Stafford Act; P.L. 93-288, as amended; 42
Management and Disaster
U.S.C. §§5121 et seq.), the Federal Emergency Management Agency (FEMA) may provide three
Recovery
primary forms of assistance: Individual Assistance (IA), Public Assistance (PA), and Hazard

Mitigation Assistance (HMA). IA, which is the focus of this report, helps disaster survivors
recover. PA provides grants to local, state, territorial, and Indian tribal governments, as well as

certain private nonprofit organizations for emergency protective measures, debris removal
operations, and repair or replacement of damaged public infrastructure. HMA funds mitigation and resiliency projects and
programs to reduce the threat or impacts of future disasters.
This report provides brief descriptions of the IA categories:
1. Crisis Counseling Assistance and Training Program;
2. Disaster Case Management;
3. Disaster Legal Services;
4. Disaster Unemployment Assistance;
5. Individuals and Households Program; and
6. Mass Care and Emergency Assistance.
The Individuals and Households Program (IHP) is covered in greatest detail herein because it is the primary program for
providing financial and direct assistance to disaster survivors following a presidential declaration of emergency or major
disaster. In addition to the IHP, the Crisis Counseling Assistance and Training Program may be authorized pursuant to either
an emergency or major disaster declaration. The other forms of IA may only be authorized pursuant to a major disaster
declaration.
The IA program information included herein is based on FEMA’s comprehensive IA program policy resource, the Individual
Assistance Program and Policy Guide (IAPPG), which was released in May 2021 and applies to emergencies and disasters
declared on or after May 26, 2021 (previous versions of the guidance apply to disasters declared prior to this date).
Additionally, FEMA has issued policy and program updates through a September 2, 2021, memorandum, various releases
and fact sheets, and an interim final rule changing its IHP regulations.
This report also briefly describes the IA factors considered when evaluating a governor or chief executive’s request for IA
pursuant to a major disaster declaration. State, territory, and Indian tribal governments do not automatically receive a
presidential Stafford Act declaration, nor do they automatically receive IA, when a disaster occurs. Instead, the governor or
tribal chief executive must request that the President declare an emergency or major disaster and that IA be authorized.
FEMA then evaluates the governor or chief executive’s request using set factors and provides a recommendation to the
President, who has sole discretion to authorize such a request. The evaluation of the IA factors, in addition to helping FEMA
determine whether or not to recommend the President declare a major disaster, helps FEMA identify the types of IA that are
needed.
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Contents
Introduction ..................................................................................................................................... 1
Individual Assistance Programs ...................................................................................................... 2
Crisis Counseling Assistance and Training Program ................................................................ 2
Immediate Services Program (ISP) ..................................................................................... 3
Regular Services Program (RSP) ........................................................................................ 3
Disaster Case Management ....................................................................................................... 4
Immediate Disaster Case Management (IDCM) ................................................................. 4
Disaster Case Management (DCM) .................................................................................... 4
Disaster Legal Services ............................................................................................................. 5
Disaster Unemployment Assistance .......................................................................................... 5
Individuals and Households Program ....................................................................................... 6
Housing Assistance ............................................................................................................. 7
Other Needs Assistance..................................................................................................... 10
Mass Care and Emergency Assistance .................................................................................... 13
IA Factors for a Major Disaster Declaration ................................................................................. 13

Tables
Table 1. Types of Housing Assistance and Other Needs Assistance ............................................... 7
Table 2. IA Factors for a Governor’s Major Disaster Declaration Request ................................... 16
Table 3. IA Factors for a Chief Executive’s Major Disaster Declaration Request ........................ 17

Contacts
Author Information ........................................................................................................................ 18

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FEMA Individual Assistance Programs: An Overview

Introduction
When a disaster occurs, the Federal Emergency Management Agency (FEMA) may assist disaster
survivors with their recovery when the Individual Assistance (IA) program is 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; 42 U.S.C. §§5121
et seq.).1 This report provides brief descriptions of forms of IA, including the Crisis Counseling
Assistance and Training Program (CCP);2 Disaster Case Management (DCM),3 Disaster Legal
Services (DLS);4 Disaster Unemployment Assistance (DUA);5 and assistance for housing and/or
other needs (referred to as other needs assistance or ONA) through the Individuals and
Households Program (IHP).6 Also included is a brief overview of Mass Care and Emergency
Assistance (MC/EA).
All forms of IA may be authorized pursuant to a major disaster declaration; however, only the
IHP and CCP may be authorized pursuant to either an emergency or major disaster declaration.7
In addition, the IHP is the only form of FEMA assistance that provides grants directly to
individuals and households to support their disaster recovery by helping address their housing and
other needs (FEMA may also provide direct assistance for housing under the IHP). All forms of
IA are funded through the Disaster Relief Fund (DRF), which is managed by FEMA.8 The federal
government provides 100% of the funding for CCP, DCM, DLS, DUA, and IHP-Housing
Assistance. IHP-ONA, however, is subject to a statutorily set 75% federal and 25% nonfederal
cost share, borne by the affected state, territory, or tribe. MC/EA services are funded under the
Public Assistance program, and are subject to a cost share that shall be not less than 75% federal
and 25% nonfederal, which may be adjusted.9

1 Disaster Relief Act of 1974 (P.L. 93-288) (retitled the Robert T. Stafford Disaster Relief and Emergency Assistance
Act—hereinafter Stafford Act—and codified, as amended, at 42 U.S.C. §§5121 et seq.). 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 is the focus of this report. For information on
FEMA’s other disaster assistance 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 416, 42 U.S.C. §5183.
3 Stafford Act Section 426, 42 U.S.C. §5189d.
4 Stafford Act Section 415, 42 U.S.C. §5182.
5 Stafford Act Section 410, 42 U.S.C. §5177.
6 Stafford Act Section 408, 42 U.S.C. §5174.
7 Stafford Act Section 502(a)(6), 42 U.S.C. §5192(a)(6), as amended by Section 7321 of the James M. Inhofe National
Defense Authorization Act for Fiscal Year 2023 (P.L. 117-263), which amended the Stafford Act to enable Crisis
Counseling to be authorized pursuant to an emergency declaration.
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.
9 Stafford Act Section 403(b), 42 U.S.C. §5170b(b). For additional information on the federal cost share for disaster
assistance, see CRS Report R47646, Stafford Act Cost Shares: History, Trends, Analysis, by Erica A. Lee.
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FEMA Individual Assistance Programs: An Overview

The program-related information included in this report is based on FEMA’s guidance, which was
released in May 2021. The Individual Assistance Program and Policy Guide (IAPPG) is FEMA’s
comprehensive IA program policy resource; it applies to emergencies and disasters declared on or
after May 26, 2021 (previous versions of the guidance apply to disasters declared prior to this
date).10 FEMA has released additional program guidance, including via a September 2, 2021,
memorandum, which also is used with the IAPPG.11 Additionally, FEMA has issued policy and
program updates through various releases and fact sheets, and an interim final rule changing its
IHP regulations.12
In addition to an overview of the IA programs, this report briefly describes the process for
authorizing IA, focusing primarily on the factors FEMA considers when evaluating a governor or
chief executive’s request for a major disaster declaration that authorizes IA. The factors FEMA
considers when evaluating a governor’s request for IA were revised via rulemaking and went into
effect in June 2019, as required by Section 1109 of the Sandy Recovery Improvement Act of 2013
(SRIA, Division B of P.L. 113-2).13 The factors FEMA considers when evaluating a chief
executive’s request for a major disaster declaration were updated in January 2017 with FEMA’s
release of the Tribal Declarations Pilot Guidance.14
Individual Assistance Programs
Various types of FEMA IA may be provided to disaster survivors.15 The available IA options
depend on the type of Stafford Act declaration, and the type(s) of IA requested by the governor or
tribal chief executive. Brief descriptions of each form of IA are included below.
Crisis Counseling Assistance and Training Program16
The Crisis Counseling Assistance and Training Program (CCP) supplements efforts to assist
disaster survivors and communities recovering from the effects of an emergency or major disaster

10 FEMA’s Individual Assistance Program and Policy Guide (IAPPG), v. 1.1, FP 104-009-03, May 2021, available at
https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf (hereinafter FEMA, IAPPG), and related
guidance can be found at FEMA, “Individual Assistance Resource Library,” https://www.fema.gov/assistance/
individual/library.
11 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).
12 Department of Homeland Security (DHS)/FEMA, “Individual Assistance Program Equity,” 89 Federal Register
3990-4125, January 22, 2024.
13 44 C.F.R. §206.48(b).
14 FEMA, Tribal Declarations Pilot Guidance, January 2017, pp. 36-38, https://www.fema.gov/sites/default/files/2020-
04/tribal-declaration-pilot-guidance.pdf (hereinafter FEMA, Tribal Declarations Pilot Guidance). Section 1110 of the
Sandy Recovery Improvement Act of 2013 (SRIA, Division B of P.L. 113-2) authorized tribal chief executives to
request presidential Stafford Act declarations.
15 For a brief reference on FEMA’s IA programs, see CRS In Focus IF11298, A Brief Overview of FEMA’s Individual
Assistance Program, by Elizabeth M. Webster; see also CRS Infographic IG10024, How FEMA Individual Assistance
Works, by Elizabeth M. Webster. For additional information on FEMA’s IA programs, as well as other federal
assistance for disaster response and recovery, see CRS Report RL31734, Federal Disaster Assistance Response and
Recovery Programs: Brief Summaries, coordinated by Maura Mullins.
16 42 U.S.C. §5183; 44 C.F.R. §206.171; see also FEMA, IAPPG, pp. 203-233; Substance Abuse and Mental Health
Services Administration (SAMHSA), “Crisis Counseling Assistance and Training Program (CCP),”
https://www.samhsa.gov/dtac/ccp; SAMHSA, “Crisis Counseling Assistance and Training Program (CCP) Toolkit,”
(continued...)
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through community-based outreach and the provision of services, such as crisis counseling,
psycho-education, coping skills development, and linking disaster survivors with other resources,
such as individuals and agencies that help survivors in the recovery process.17
Following a presidential emergency or major disaster declaration, FEMA may provide CCP grant
funding to enable local, state, territory, and tribal government mental health agencies to provide
CCP services or contract with local or private mental health service providers to offer CCP
services.18 CCP also funds training for individuals providing such counseling services.19 In order
for CCP to be made available, the state, territory, or tribe must conduct a needs assessment within
10 days of the declaration authorizing IA, and submit a federal award application (which FEMA,
in coordination with the Substance Abuse and Mental Health Services Administration, must
approve).20 As the program supplements state, territory, tribal, and local resources, the affected
government’s CCP application must demonstrate that the need for CCP services exceeds the
capacity of state, territory, tribal, and local resources.21
The CCP provides short- to intermediate-term assistance to support mental and emotional health
needs. Two separate CCP programs provide assistance for different lengths of time:22
Immediate Services Program (ISP)
Immediate Services Program (ISP) funding is provided for up to 60 days following the approval
of IA for a major disaster, and can continue for 30 additional days if an affected
state/territory/tribe has submitted an application for the Regular Services Program.23
Regular Services Program (RSP)
Regular Services Program (RSP) funding is provided for up to nine months following the date of
the notice of award, and can be extended for up to 90 days due to extraordinary circumstance or
for more than 90 days if FEMA determines such an extension of the period of performance is in
the public interest.24 ISP participation is not a prerequisite for the RSP.25
The CCP regulations and guidance specify the application deadlines (i.e., no later than 14 days
following the major disaster declaration for the ISP, and no later than 60 days after the declaration
for the RSP),26 and timing for the availability of the above-referenced program funding; however,

https://www.samhsa.gov/dtac/ccp-toolkit; and FEMA, Crisis Counseling Assistance and Training Program Guidance:
CCP Application Toolkit, Version 5.3, April 2023, https://www.samhsa.gov/sites/default/files/dtac/ccptoolkit/fema-
ccp-guidance.pdf (hereinafter FEMA, CCP Application Toolkit).
17 FEMA, IAPPG, p. 8. Figure 40 in FEMA’s IAPPG lists and describes the available Crisis Counseling Assistance and
Training Program (CCP)-funded services (see FEMA, IAPPG, p. 206).
18 42 U.S.C. §5183(a); FEMA, IAPPG, p. 203; FEMA, CCP Application Toolkit, p. 1.
19 42 U.S.C. §5183(b).
20 FEMA, IAPPG, pp. 207, 214, and 222; FEMA, CCP Application Toolkit, pp. 2-3.
21 FEMA, Disaster Operations Legal Reference, v. 4.0, September 25, 2020, p. 6-99 (hereinafter FEMA, Disaster
Operations Legal Reference).
22 The CCP Immediate Services Program (ISP) is described 44 C.F.R. §206.171(f) and FEMA, IAPPG, pp. 209-217.
The CCP Regular Services Program (RSP) is described 44 C.F.R. §206.171(g) and FEMA, IAPPG, pp. 218-225.
23 44 C.F.R. §206.171(f)(4)(i) and (ii); FEMA, CCP Application Toolkit, p. 2.
24 44 C.F.R. §206.171(g)(4)(i); FEMA, CCP Application Toolkit, p. 3.
25 FEMA, IAPPG, p. 208.
26 44 C.F.R. §206.171(f)(1) and (g)(1).
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as noted, funding time extensions may be approved if requested by the state, territory, or tribe and
approved by federal officials.
Disaster Case Management27
The Disaster Case Management (DCM) program partners case managers with disaster survivors
to develop and implement disaster recovery plans that address the disaster survivors’ unmet
needs, including by providing disaster survivors with a single point of contact to access recovery
resources.28
Following a presidential major disaster declaration, FEMA may provide DCM. There are two
DCM programs that are implemented differently and which provide assistance for different
lengths of time:29
Immediate Disaster Case Management (IDCM)
FEMA-administered Immediate Disaster Case Management (IDCM)30 provides short-term
services to address immediate disaster-caused unmet needs, and refer disaster survivors to
resources. It is focused on the early steps, such as outreach, and development of an individual
recovery plan.31 The period of performance may be 90-180 days (when cases are transferred to
the Disaster Case Management program or local providers), unless an extension is authorized due
to extraordinary circumstances.
FEMA directly implements, administers, and oversees the IDCM program, in coordination with
the affected state, territory, or tribal government, which can be done, including through a mission
assignment to federal agencies for case management, an interagency agreement with national-
level case management partners, a FEMA contract, or direct hiring of case managers.32 FEMA-
administered IDCM does not require a request from the affected state, territory, or tribe; FEMA
makes its determinization on whether IDCM is required based on factors that include “the size of
the impacted populations and the scope of the disaster, as well as the ability of local resources to
adequately meet the immediate disaster-caused unmet needs of survivors.”33
Disaster Case Management (DCM)
Federally funded, state/territory/tribe-managed DCM provides longer-term services, with a period
of performance of up to 24 months from the declaration date, which may be extended for 90 days
pursuant to a written request by the nonfederal entity, with FEMA’s approval.
FEMA may provide DCM grant funding to local, state, territory, and tribal governments or
qualified private organizations to supplement existing case management capabilities by funding
the provision of services, or allowing local, state, territory, and tribal governments to contract

27 42 U.S.C. §5189d; see also FEMA, IAPPG, pp. 183-202; and FEMA, “Disaster Case Management Toolbox,”
https://www.fema.gov/assistance/individual/disaster-survivors/disaster-case-management-toolbox.
28 FEMA, IAPPG, p. 183.
29 The Immediate Disaster Case Management (IDCM) program is discussed in FEMA’s IAPPG from pages 186-187,
and the Disaster Case Management (DCM) program is discussed from pages 188-202.
30 FEMA, IAPPG, p. 186.
31 FEMA, IAPPG, p. 186.
32 FEMA, IAPPG, p. 186.
33 Email correspondence from FEMA Congressional Affairs staff, April 17, 2024 (quoting FEMA, IAPPG, p. 185).
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with local providers to provide disaster case management.34 In order for DCM to be made
available, the nonfederal entity must conduct a needs assessment, and submit a federal award
application within 90 days of the major disaster declaration Authorizing IA (which FEMA must
approve).35 As the program supplements state, territory, tribal, and local resources, the nonfederal
entity’s DCM application must demonstrate that the need for DCM services exceeds the capacity
of state, territory, tribal, and local resources.36
IDCM is not a prerequisite for DCM.37
Disaster Legal Services38
Through the Disaster Legal Services (DLS) program, attorneys provide legal advice, counseling,
and representation in non-fee-generating cases, for free to low-income individuals who require
them in order to secure Stafford Act benefits or make claims arising out of a major disaster.39 For
example, assistance may include replacing disaster-destroyed legal documents, help with home
repair contracts and contractors, and appeals of FEMA decisions.40
Following a presidential major disaster declaration, Disaster Legal Services are provided through
an agreement FEMA has with the American Bar Association’s Young Lawyers Division, when
requested by an affected local, state, territory, or tribal government.41 Disaster survivors can
access such assistance via a local toll-free hotline and through Disaster Recovery Centers.42
Disaster Legal Services are provided until they are no longer needed.43
Disaster Unemployment Assistance44
The Disaster Unemployment Assistance (DUA) program allows the affected state or territory’s
unemployment compensation (UC) agency (or the state UC agency on behalf of a tribe receiving
a declaration) to provide temporary DUA benefits for up to 26 weeks following the declaration of
a major disaster to individuals who were previously employed or self-employed, were rendered
jobless or whose employment was interrupted as a direct result of a presidentially declared major

34 FEMA provides funding for the DCM program, which is implemented through a grant or cooperative agreement (the
cooperative agreement may be used when substantial FEMA involvement is anticipated) (FEMA, IAPPG, p. 185).
DCM defines a qualified private organization as “any non-governmental organization or entity that currently has an
effective ruling letter from the U.S. Internal Revenue Service, granting tax exemption under Sections 501(c) of Internal
Revenue Code of 1954, or satisfactory evidence from the state, territorial, or tribal government that the nonrevenue
producing organization or entity is a nonprofit one organized or doing business under state, territorial, or tribal
government law and that has experience providing case management services” (FEMA, IAPPG, p. 183).
35 FEMA, IAPPG, pp. 191-192; FEMA, Disaster Operations Legal Reference, p. 6-96. The nonfederal entity may
request an extension of the deadline to submit the Disaster Case Management award application within 60 days of the
major disaster declaration.
36 FEMA, IAPPG, p. 188.
37 FEMA, IAPPG, p. 186.
38 42 U.S.C. §5182; 44 C.F.R. §206.164; see also FEMA, IAPPG, pp. 235-237.
39 44 C.F.R. §206.164(a) and (e). For the purposes of Disaster Legal Services (DLS), low-income disaster survivors are
those “who have insufficient resources to secure adequate legal services, whether the insufficiency existed prior to or
resulted from the major disaster” (FEMA, IAPPG, p. 236).
40 FEMA, IAPPG, pp. 8 and 235.
41 FEMA, IAPPG, p. 8.
42 FEMA, IAPPG, p. 237.
43 FEMA, IAPPG, p. 235. FEMA’s statute and regulations do not establish time limitation for Disaster Legal Services.
44 42 U.S.C. §5177; 44 C.F.R. §206.141; see also FEMA, IAPPG, pp. 239-243.
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disaster, and who are ineligible for regular unemployment compensation.45 DUA may also
provide re-employment assistance.46
Following a presidential major disaster declaration, the affected state, territory, or tribal
government may apply for funding for the DUA program.47 The program is overseen by the U.S.
Department of Labor, and administered by the affected state or territory’s UC agency. FEMA
provides the funding for DUA.
Individuals and Households Program48
When the Individuals and Households Program (IHP) is authorized pursuant to a presidential
emergency or major disaster declaration, FEMA may provide financial and/or direct assistance
for housing and financial assistance for other needs (referred to as other needs assistance or
ONA) to eligible disaster survivors who, as a result of a disaster, have uninsured or under-insured
necessary expenses and serious needs that cannot be met through other means or forms of
assistance.49 The IHP is intended to meet basic needs and support recovery efforts, but it does not
compensate disaster survivors for all losses and it is not intended to be a substitute for insurance.
There are additional limits on IHP assistance, including that some forms of IHP assistance are
subject to time-based limitations, and IHP awards for Financial Housing Assistance and ONA are
subject to statutory funding caps that limit the amount of financial assistance an individual or
household may receive for a single emergency or major disaster.50
Disaster survivors must apply for IHP assistance, and IHP applicants must meet general eligibility
requirements.51 Additionally, each type of IHP assistance also requires that additional eligibility
conditions be met, and may require additional documentation. The types of IHP Housing
Assistance and Other Needs Assistance (ONA) are listed in Table 1.

45 FEMA, IAPPG, p. 239. For more information on DUA, see CRS Report RS22022, Disaster Unemployment
Assistance (DUA), by Julie M. Whittaker.
46 FEMA, IAPPG, p. 239.
47 FEMA, IAPPG, p. 243.
48 42 U.S.C. §5174; 44 C.F.R. §§206.110-120; see also FEMA, IAPPG, pp. 41-182. For additional, detailed
information on the Individuals and Households Program (IHP), see CRS Report R47015, FEMA’s Individuals and
Households Program (IHP)—Implementation and Considerations for Congress, by Elizabeth M. Webster; and for a
brief overview of the IHP, see CRS In Focus IF12049, FEMA’s Individuals and Households Program (IHP), by
Elizabeth M. Webster.
49 FEMA, IAPPG, p. 41.
50 42 U.S.C. §5174(h). Assistance for housing-related needs may not exceed $42,500 (FY2024; adjusted annually), and
assistance for other needs assistance (ONA) may not exceed $42,500 (FY2024; adjusted annually). Additionally, ONA
may be somewhat limited because some ONA-eligible items and amounts available to be awarded are predetermined
by FEMA and the state, territorial, or Indian tribal government. Financial assistance to rent alternate housing
accommodations and financial assistance for accessibility-related real and personal property costs are not subject to the
cap. DHS/FEMA, “Notice of Maximum Amount of Assistance Under the Individuals and Households Program,” 88
Federal Register 72520, October 20, 2023.
51 FEMA, IAPPG, p. 46.
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Table 1. Types of Housing Assistance and Other Needs Assistance
Housing Assistance: Financial
Housing Assistance: Direct
ONA
Lodging Expense Reimbursement
Multi-Family Lease and Repair
Serious Needs Assistance
Rental Assistance
Transportable Temporary Housing
Displacement Assistance
Home Repair Assistance
Units
Personal Property Assistance
Home Replacement Assistance
Direct Lease
Transportation Assistance
Permanent Housing Construction
Group Flood Insurance Policy
Funeral Assistance
Medical and Dental Assistance
Childcare Assistance
Assistance for Miscellaneous Items
Moving and Storage 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;
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; DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 3990-4125,
January 22, 2024; and FEMA, “Voluntary Organization Information Sharing for Engagement VOISE Partner Call:
Reforming Individual Assistance,” January 25, 2023 (see slide on “The Future of FEMA Individual Assistance”).
Note: 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.
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). 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.”52 Other relevant considerations relate to the individual or
household’s “disaster-caused losses, access to life-sustaining services, cost-effectiveness, and
other factors.”53 In addition, individuals and households may require multiple types of housing
assistance when a disaster affects their home’s habitability.54 The following two sections briefly
describe each type of Housing Assistance, and are organized by subcategory.

52 42 U.S.C. §5174(b)(2)(A); 44 C.F.R. §206.110(c).
53 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).
54 42 U.S.C. §5174(b) and (c); 44 C.F.R. §206.110(c); and FEMA, IAPPG, pp. 78 and 93. FEMA’s defines
“uninhabitable” as “mean[ing] the dwelling is not safe or sanitary” (44 C.F.R. §206.111).
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Financial Housing Assistance
Financial Housing Assistance is grant funding provided by FEMA directly to the eligible
individual or household.55 Home Repair and Home Replacement Assistance are subject to the
limit on the maximum amount of financial assistance an individual or household is eligible to
receive.56
• Lodging Expense Reimbursement (LER) reimburses eligible individuals for
out-of-pocket short-term lodging costs and taxes when the applicant is displaced
from their primary residence because an emergency or major disaster rendered it
uninhabitable or inaccessible.57
• Rental Assistance (including Initial Rental Assistance and Continued
Temporary Housing Assistance) provides eligible individuals with funding to
rent alternate housing accommodations, including funding for rent, essential
utilities, and a security deposit, while the applicant is displaced from their
primary residence because it is uninhabitable, inaccessible, affected by a utility
outage, or unavailable.58 There are two types of Rental Assistance:
• Initial Rental Assistance allows FEMA to provide up to two months of
assistance.
• Continued Temporary Housing Assistance allows FEMA to provide
assistance for up to 18 months or until the end of the 18-month period of
assistance, whichever comes first (this includes the period of time during
which Initial Rental Assistance was provided), plus a security deposit. The
period of assistance may be extended at the written request of the affected
state, territory, or Indian tribal government.59
• Home Repair Assistance provides funding to eligible homeowners to repair an
owner-occupied primary residence, utilities, and residential infrastructure (e.g.,
privately owned access routes) to make the disaster survivors’ home “safe,
sanitary, or functional.”60 Home Repair Assistance may also provide funding for
selected mitigation measures that make the housing more resilient.61

55 FEMA, IAPPG, p. 43.
56 42 U.S.C. §5174(h)(1) and (4)(A).
57 FEMA, IAPPG, pp. 78-79.
58 FEMA, IAPPG, p. 80. The FEMA IAPPG states that FEMA uses the applicable Fair Market Rent (FMR) rate, which
is based on the housing unit’s location, number of bedrooms, and the fiscal year of the major disaster declaration
(FEMA, IAPPG, p. 109 (see “Fair Market Rent (FMR)” text box)). HUD’s Office of Policy Development and Research
(PD&R) posts FMR information at https://www.huduser.gov/portal/datasets/fmr.html.
59 44 C.F.R. §206.110(e); FEMA, IAPPG, p. 80; FEMA, Disaster Operations Legal Reference, pp. 6—23-24 (it states,
“Although Stafford Act Section 408 refers to only an 18-month temporary housing assistance, FEMA’s implementing
regulations apply this period of assistance to all of IHP” and “The Assistant Administrator for Recovery may extend
this period if he/she determines that due to extraordinary circumstances, an extension would be in the public interest”).
60 FEMA, IAPPG, p. 85. 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, and roof). Additionally, assistance to repair real property components impacted by disaster-caused mold
growth is eligible for Home Repair Assistance (Memorandum from Keith Turi RE: Amendment to the IAPPG, pp. 9-
10,).
61 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; FEMA “FEMA to
Provide Additional Hazard Mitigation Funds to Help Homeowners Affected by Wildfires,” release HQ-22-089, July
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• Home Replacement Assistance provides funding to eligible homeowners to help
replace a disaster-destroyed owner-occupied primary residence. The funding can
be applied toward the purchase of a new permanent residence that exceeds the
maximum award amount.62
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.
Direct Housing Assistance
Direct Housing Assistance is housing provided to the individual or household by FEMA.63 Direct
Housing Assistance is not subject to the limit on the maximum amount of financial assistance an
individual or household is eligible to receive. However, FEMA may only provide Direct Housing
Assistance when Rental Assistance (a type of IHP Financial Housing Assistance) is unavailable or
is insufficient.64
• Multifamily Lease and Repair (MLR) temporarily places eligible individuals 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).65 MLR is not intended to make repairs or improvements
to multi-family housing units for the purpose of rehousing existing tenants.66
• Transportable Temporary Housing Units (TTHUs) temporarily places eligible
individuals in FEMA-purchased or leased temporary housing units (i.e.,
Recreational Vehicles (RVs) or Manufactured Housing Units (MHUs)).67 TTHU

28, 2022, https://www.fema.gov/press-release/20220728/fema-provide-additional-hazard-mitigation-funds-help-
homeowners-affected.
62 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).”
63 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).
64 Direct Housing Assistance must be requested in writing by the affected state, territory, or tribal government, and is
only available when: (1) Rental Assistance cannot be used due to insufficient available housing resources; (2)
increasing the Rental Assistance rate to 125% of the HUD Fair Market Rent (FMR) will not be sufficient to meet the
housing needs; and (3) assistance from other providers (e.g., government and voluntary organizations) is insufficient to
meet the housing needs. FEMA, IAPPG, p. 94.
65 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.
66 FEMA, IAPPG, p. 107.
67 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
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sites must meet specific requirements that include (1) providing access to
available and functional utilities;68 (2) complying with government ordinances;
and (3) satisfying federal floodplain management and Environmental Planning
and Historic Preservation (EHP) compliance review requirements.69 FEMA’s
guidance states that “FEMA selects locations based on the cost-effectiveness,
timeliness, and suitability of each potential site.”70 Sites can include private sites
(i.e., a site provided by the applicant—typically the applicant’s property),
commercial sites (i.e., existing manufactured home parks), or group sites (i.e., a
site provided by the local, state, territory, or tribal government, such as a public
park—this option is only considered when the temporary housing need cannot be
met by the other direct temporary housing options).71
• Direct Lease temporarily places eligible individuals in FEMA-leased residential
properties that are not typically available to the general public (e.g., a vacation
rental).72
• Permanent Housing Construction (PHC) is a last resort that is used to provide
financial or direct assistance for permanent or semi-permanent housing, and can
include repairs or new home construction.73 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 Housing Assistance
are unavailable, infeasible or not cost-effective.”74
Other Needs Assistance
Other Needs Assistance (ONA) provides eligible individuals with a grant of financial assistance
for their other disaster-related necessary expenses and serious needs.75 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.76 Additionally, available

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).
68 FEMA, IAPPG, pp. 113-116. Utilities include available and functional sanitation, electrical service, and potable
water service.
69 FEMA, IAPPG, p. 112.
70 FEMA, IAPPG, p. 112.
71 FEMA, IAPPG, pp. 113-115.
72 FEMA, IAPPG, pp. 124-125. 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). 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).
73 FEMA, IAPPG, p. 127.
74 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 Permanent Housing Construction (PHC).
75 FEMA defines a necessary expense as “the cost associated with acquiring an item, obtaining a service, or paying for
any other activity that meets a serious need,” and a serious need 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” (FEMA, IAPPG, p. 145).
76 42 U.S.C. §5174(h)(2) and (4)(B)..
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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 selected items.77 The following sections provide an overview of each type of ONA,
and are organized by subcategory.
• Serious Needs Assistance is a new form of ONA that provides $750 to eligible
applicants who report they are displaced from their pre-disaster primary
residence, sheltering in their pre-disaster residence but need to shelter elsewhere,
or have a serious need, so they can address their immediate post-disaster needs
for items such as “water, food, first aid, infant formula, diapers, personal hygiene
items, and fuel for or the cost of transportation.”78
• Displacement Assistance is a new form of ONA that provides up-front financial
assistance to eligible applicants when their pre-disaster primary residence is
uninhabitable or inaccessible, so they can immediately obtain short-term
accommodations while they work to secure temporary housing (such as FEMA
Rental Assistance).79
• Personal Property Assistance provides funding to eligible individuals to repair
or replace eligible personal property items damaged or destroyed as a result of a
declared emergency or major disaster.80 Assistance may be provided for ONA-
eligible personal property items set by the affected state/territory/tribe in its
“ONA Administrative Option Selection Form.”81
• Transportation Assistance provides funding to eligible individuals to repair or
replace a vehicle damaged by a declared emergency or major disaster, up to the
maximum award amount set by the affected state/territory/tribe in its “ONA
Administrative Option Selection Form.”82
• Group Flood Insurance Policy enables FEMA or the state, territory, or Indian
tribal government to directly purchase a policy on an applicant’s behalf if the
applicant is required to purchase and maintain flood insurance, but could not

77 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, 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).
78 DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 4012, 4023-4024, and 4123, January 22,
2024.
79 DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 4024 and 4123, January 22, 2024.
80 FEMA, IAPPG, pp. 166-169; DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 4010,
January 22, 2024. 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
or for education, as well as a self-employed individual’s disaster-damaged essential tools and equipment, and required
items for their trade/profession.
81 FEMA, IAPPG, p. 149. The affected state, territory, or tribe may identify ONA-eligible personal property and
miscellaneous items, and can set a maximum number of items each eligible individual or household may receive.
82 FEMA, IAPPG, pp. 149, and 170-172. 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.”
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otherwise purchase a policy.83 The premium for a three-year certificate of
coverage costs $2,400,84 and it covers real and personal property equaling the
maximum amount of financial assistance available for both Housing Assistance
and ONA.85 Upon the group policy’s expiration, the applicant must purchase and
maintain their own flood insurance; failure to do so may affect future IHP
eligibility.86
• Funeral Assistance provides funding to assist eligible individuals with eligible
funeral expenses related to a death that is directly or indirectly attributable to a
declared emergency or major disaster, up to the maximum award amount set by
the affected state/territory/tribe in its “ONA Administrative Option Selection
Form.”87
• Medical and Dental Assistance provides funding to assist eligible individuals
with eligible medical and dental expenses incurred as a direct result of a declared
emergency or major disaster.88
• Child Care Assistance provides funding to assist eligible individuals with a
disaster-caused increased financial burden for childcare for children aged 13 and
under and/or children up to age 21 who have a disability and need assistance with
activities of daily living. Assistance is provided for up to eight cumulative weeks
of childcare and eligible expenses or the maximum award amount set by the
affected state/territory/tribe in its “ONA Administrative Option Selection Form,”
whichever is less.89
• Moving and Storage Assistance provides funding to eligible individuals to
relocate and store essential personal property while repairs are made to the
applicant’s primary residence, and then return the property to the repaired
primary residence.90
• Miscellaneous Expenses provides funding to reimburse eligible individuals for
eligible items purchased or rented after a disaster to assist with their recovery.91
Assistance may be provided for ONA-eligible miscellaneous items set by the

83 FEMA, IAPPG, pp. 172-175.
84 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 three years; however, the regulation notes that the
premium may be adjusted “to reflect NFIP [National Flood Insurance Program] loss experience and any adjustment of
benefits under the IHP program” (FEMA, IAPPG, p. 172).
85 FEMA, IAPPG, p. 172.
86 FEMA, IAPPG, p. 174.
87 FEMA, IAPPG, pp. 149-152. Examples of eligible funeral expenses include interment or reinterment, funeral and
officiant services, and the cost of producing and certifying death certificates.
88 FEMA, IAPPG, pp. 153-155. Examples of eligible medical and dental expenses include costs associated with a
disaster-caused illness or injury, replacing prescribed medication or equipment, and insurance deductibles and
copayments, as well as loss or injury of a service animal.
89 FEMA, IAPPG, pp. 155-160.
90 FEMA, IAPPG, pp. 162-164. Items may be relocated to a temporary housing unit if they will be returned to the
repaired primary residence. Appliances and furniture, but not recreational items, are eligible to move and store.
91 FEMA, IAPPG, pp. 160-162. Miscellaneous items may assist disaster survivors with gaining access to their property
or assisting with cleaning efforts. Examples of eligible miscellaneous items may include carbon monoxide and smoke
detectors, and a dehumidifier or humidifier. Chainsaws and generators may be permitted under limited circumstances if
certain conditions are met.
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affected state/territory/tribe in its “ONA Administrative Option Selection
Form.”92
• Clean and Sanitize Assistance is provided to eligible individuals in the form of
a one-time payment limited to $300 to “ensure minimal damage to the home is
addressed in order to prevent additional losses and potential health and safety
concerns.”93
Mass Care and Emergency Assistance94
Mass Care and Emergency Assistance (MC/EA) involves federal coordination and support of
state, local, tribal, and territorial government efforts to provide life-sustaining services to disaster
survivors prior to, during, and following an incident through short-term recovery.95 Examples of
MC/EA include emergency feeding and sheltering. Unlike the other forms of assistance discussed
in this report, MC/EA is authorized and funded through FEMA’s Public Assistance—rather than
Individual Assistance—program.
IA Factors for a Major Disaster Declaration
Federal assistance is intended to supplement—not supplant—the local, state, territory, or Indian
tribal government’s response and recovery efforts.96 For this reason, state, territory, and Indian
tribal governments do not automatically receive a presidential declaration of emergency or major
disaster, nor do they automatically receive Individual Assistance (there is no threshold for
authorizing IA).97 Instead, following an incident,98 the governor or chief executive must request
that the President declare an emergency or major disaster authorizing IA.99 The governor or chief
executive’s request must demonstrate that they are unable to effectively respond to the incident
without federal assistance.100 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

92 FEMA, IAPPG, p. 149. The affected state, territory, or tribe may identify ONA-eligible personal property and
miscellaneous items, and can set a maximum number of items each eligible individual or household may receive.
93 Memorandum from Keith Turi RE: Amendment to the IAPPG, pp. 11-12.
94 FEMA, IAPPG, pp. 16-40. The IAPPG chapter on Mass Care and Emergency Assistance (MC/EA) includes an
overview of the program, as well as descriptions of assistance, including support related to (1) sheltering; (2) feeding;
(3) the distribution of emergency supplies; (4) individuals with disabilities and others with access and functional needs;
(5) reunification; (6) pets, service animals, and assistance animals; (7) mass evacuees; (8) Transitional Sheltering
Assistance (TSA); (9) Operation Blue Roof programs; and (10) the National Mass Care Exercise.
95 FEMA, IAPPG, p. 6.
96 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
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).
97 44 C.F.R. §§206.35-206.38, and 206.40(a); and FEMA, “How a Disaster Gets Declared.”
98 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)).
99 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 “exclusive or preeminent responsibility and authority.”
100 44 C.F.R. §§206.35 and 206.36.
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severity of the disaster-caused damages, in addition to other required information.101 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).102 This includes information collected through the
Preliminary Damage Assessment (PDA) process, which is validated by local, state, territory,
Indian tribal government, and federal authorities.103 FEMA then provides a recommendation to
the President.104 The decision to grant an emergency or major disaster declaration request is at the
President’s sole discretion.105
FEMA issued a final rule updating 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).106 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.107 Thus, there are six IA factors
that are considered pursuant to a governor’s request for a major disaster declaration authorizing
IA.108 These factors are intended to help FEMA assess the “severity, magnitude, and impact of a
disaster,” as well as the capabilities of the affected jurisdictions.109 The factors are also used to
identify the 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).
FEMA uses a separate set of factors when evaluating a chief executive of an affected Indian tribal
government’s request for a major disaster authorizing IA. Section 1110 of SRIA amended the
Stafford Act to allow chief executives to request an emergency or major disaster declaration on

101 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.
102 44 C.F.R. §206.48(b); and FEMA, Tribal Declarations Pilot Guidance, pp. 36-38.
103 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).
104 44 C.F.R. §206.37(c).
105 44 C.F.R. §206.38.
106 DHS/FEMA, “Factors Considered When Evaluating a Governor’s Request for Individual Assistance for a Major
Disaster,” 84 Federal Register 10632-10664, 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”); 44 C.F.R.
§206.48(b).
107 FEMA, Individual Assistance Declarations Factors Guidance, June 2019, https://www.regulations.gov/document/
FEMA-2014-0005-0071.
108 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 would
be useful in evaluating the need for IHP assistance. As described by 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 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).
109 DHS/FEMA, “Factors Considered When Evaluating a Request for IA,” 84 Federal Register 10633; and 44 C.F.R.
§206.48(b).
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behalf of the tribe (alternatively, the tribe may receive assistance through the state’s
declaration).110 Initially, FEMA used the same factors to evaluate a governor or chief executive’s
request for a major disaster declaration, which allowed tribal governments to exercise this
authority immediately upon SRIA’s enactment (using the previous IA factors—before they were
revised and made effective in June 2019).111 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.112 When the pilot period concludes (no
specific time has been set), FEMA has stated that it will develop regulations informed by the
pilot.113 Thus, there are nine factors considered when evaluating a chief executive’s request for a
major disaster declaration authorizing IA, which are intended to help FEMA evaluate whether an
event has overwhelmed the tribal government’s capabilities, making Stafford Act assistance
necessary.114
No single factor is determinative; FEMA considers all relevant information submitted by the
governor or chief executive as part of a declaration request, and the President has the sole
discretion to approve a major disaster declaration request authorizing IA.115
Brief descriptions of the factors FEMA evaluates when considering a governor’s request are
included in Table 2, and Table 3 provides brief descriptions of the factors FEMA evaluates when
considering a chief executive’s request.

110 Section 1110 of SRIA (P.L. 113-2).
111 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.
112 FEMA, Tribal Declarations Pilot Guidance.
113 FEMA, Tribal Declarations Pilot Guidance, p. 3; and FEMA, “Tribal Declarations Pilot Guidance,”
https://www.fema.gov/disasters/tribal-declarations.
114 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 Preliminary Damage Assessment process.
115 Per FEMA’s regulation at 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 C.F.R. 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.... ”; and FEMA, Tribal Declarations Pilot
Guidance, p. 34.
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Table 2. IA Factors for a Governor’s Major Disaster Declaration Request
Applies to Affected States and Territories
Supporting
Information/
IA Factors
Description
Data Sources
State Fiscal
FEMA considers the availability of government and private-sector
U.S. Department
Capacity and
resources, and the circumstances that contributed to the state/territory
of the Treasury,
Resource
having insufficient resources, potentially necessitating supplemental federal Bureau of
Availabilitya
assistance. FEMA evaluates (1) Fiscal Capacity (a principal factor for
Economic
considering the need for the IHP), which indicates the state/territory’s
Analysis,
ability manage disaster response and recovery, by considering its ability to
state/territory
raise revenue for disaster response and recovery based on either total
reported other
taxable resources (TTR) or gross domestic product (GDP), as well as per
limits on a
capita personal income by locality and other factors affecting the
state/territory’s
state/territory’s ability to col ect funds; and (2) Resource Availability,
treasury or ability
which indicates whether the disaster-caused needs can be met using non-
to col ect funds
Stafford Act sources. Also considered is the cumulative effect of recent
and resource
disasters occurring in the previous 24 months.
availability
Uninsured
FEMA considers the results of the FEMA-State Preliminary Damage
State/territory
Home and
Assessment (PDA) process to examine the extent of damage and
reported
Personal
estimated cost of IHP assistance (a principal IHP factor). An affected
fol owing the
Property
state/territory may provide data for consideration, including (1) the
Preliminary
Lossesb
damage-causing peril; (2) the percentage of affected applicants with
Damage
insurance for such peril; (3) the concentration of damages; (4) the number Assessment
of homes damaged and degree of damage; (5) the estimated cost of
assistance; (6) the estimated homeownership rate for the affected homes;
and (7) other relevant PDA data that may demonstrate a need for
supplemental assistance.
Disaster
FEMA considers the affected community’s demographics as compared
U.S. Census
Impacted
with national averages (based on U.S. Census Bureau and other federal
Bureau
Population
data), to evaluate whether there is an increased need for supplemental
(American
Profile
federal assistance.
Community
Survey), other
federal agencies
Impact to
FEMA considers the disaster-caused disruption, damage, or destruction to
State/territory
Community
community infrastructure components, which may make it difficult for
reported
Infrastructure
disaster survivors to reside in the community and may hinder community
recovery—specifically, disruption, damage, or destruction for more than
72 hours to any/all of the fol owing: (1) “Life-Saving and Life-Sustaining
Services” that provide an “essential community function that .. wil affect
public health and safety” (e.g., police, medical facilities); (2) “Essential
Community Services” that improve quality of life (e.g., social services); and
(3) “Transportation Infrastructure and Utilities” that, for example, render
housing uninhabitable or inaccessible.
Casualties
FEMA considers the number of individuals who are missing, injured, or
State/territory
deceased as a result of a disaster, which indicates community trauma.
reported
Disaster Related FEMA considers the number of individuals who may have lost work or
State/territory
Unemployment
become unemployed as a result of the disaster and who do not qualify for
reported
standard unemployment insurance. FEMA also considers impacts to major
employers in the affected jurisdiction, which could indicate the potential
for a prolonged recovery process.
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.
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Notes: 44 C.F.R. §206.48(b). FEMA considers 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 3. IA Factors for a Chief Executive’s Major Disaster Declaration Request
Applies to Affected Federally Recognized Tribes
Supporting
Information/
IA Factors
Description
Data Sources
Uninsured
FEMA evaluates the damage to the primary residences of enrol ed tribal
Tribe reported
Home and
members and, if requested and approved, non-enrol ed members of the
fol owing the
Personal
tribal community, by categorizing homes based on damage and assessing
Preliminary
Property
the magnitude of the disaster and concentration of damages.
Damage
Lossesa
Assessment
Availability of
FEMA considers the availability of accessible temporary housing
Tribe reported
Housing
resources.
Resources
Casualties
FEMA considers disaster-caused “deaths or injuries [including] of cultural,
Tribe reported
religious, and government leaders.”
Impact to
FEMA considers the disaster’s impacts that may adversely affect the
Tribe reported
Community
“population’s ability to safely and securely reside within the community,”
Infrastructure
including the large-scale disruption of community functions and services;
impacts to cultural and spiritual facilities; and emergency needs.
Disaster
FEMA considers the affected community’s demographics, including
U.S. Census
Impacted
populations that may have a greater need for recovery support.
Bureau, tribe
Population
reported unique
Profile
considerations
not reflected in
U.S. Census
Bureau data
Voluntary
FEMA considers the extent to which disaster survivors’ needs can be met
Tribe reported
Agency and
by voluntary agencies, and the local and state governments.
Other
Assistance
Tribal
FEMA considers the tribal government’s efforts that have or wil be made
Tribe reported
Government
and the resources that have or wil be committed.
Resources
Unique
FEMA considers the tribe’s unique needs and the conditions that are
Tribe reported
Conditions that
unique to the tribal community (e.g., needs associated with remote
Affect Tribal
locations or the impact on the tribal government’s economy).
Governments
Other Relevant
Other relevant information provided by the tribe.
Tribe reported
Information
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:
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FEMA Individual Assistance Programs: An Overview

a. 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).

Author Information

Elizabeth M. Webster

Specialist in Emergency Management and Disaster
Recovery

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Congressional Research Service
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