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

December 21, 2021 – March 22, 2024 R47015

FEMA’s Individuals and Households Program
March 22, 2024
(IHP)—Implementation and Considerations for Elizabeth M. Webster
Congress
Specialist in Emergency
Management and Disaster
The Federal Emergency Management Agency (FEMA) may provide several forms of assistance,
Recovery
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 to help disaster survivors

recover—known as Individual Assistance (IA).
There are various forms of IA that can support disaster survivors. This report provides an overview of one type of IA: the
Individuals and Households Program (IHP), which is authorized under Stafford Act Section 408 (42 U.S.C. §5174) and may
be provided pursuant to either an emergency or major disaster declaration. The IHP is the only form of IA, and the only form
of FEMA assistance, 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, such as 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, and in 2024. 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), updates to FEMA’s IA guidance, including the Individual Assistance Program and Policy Guide (IAPPG),
and an interim final rule going into effect (which amended FEMA’s IHP regulations and updated various aspects of the IHP).
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.

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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 disaster survivors, 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 form of FEMA
assistance, that provides grants of financial assistance directly to individuals and households to
address their disaster-caused 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, regulatory, and
guidance/policy-related 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 authorizing IA (these factors are described in

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
Individuals and Households Program or 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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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: the DHS/FEMA interim final rule “Individual Assistance Program Equity” revises FEMA’s
definition of “uninhabitable” to mean “the dwelling is not safe or sanitary” (DHS/FEMA, “Individual Assistance
Program Equity,” 89 Federal Register 4004 and 4120, January 22, 2024; 44 C.F.R. §206.111).

Safe: the DHS/FEMA interim final rule “Individual Assistance Program Equity” revises FEMA’s definition of “safe”
to mean “secure from hazards or threats to occupants” (DHS/FEMA, “Individual Assistance Program Equity,” 89
Federal Register 4004 and 4119, January 22, 2024; 44 C.F.R. §206.111).

Sanitary: the DHS/FEMA interim final rule “Individual Assistance Program Equity” revises FEMA’s definition of
“sanitary” to mean “free of health hazards” (DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal
Register 4004 and 4119, January 22, 2024; 44 C.F.R. §206.111).

Functional: the DHS/FEMA interim final rule also changes the requirement that a disaster-damaged real property
component must be functional immediately before the disaster, meaning it was capable of being used for its
intended purpose (DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 4004, January 22, 2024).

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

Overview of Stafford Act Section 408—Federal
Assistance to Individuals and Households
Following an incident, the President
Emergency Declarations Authorizing IA
may authorize the IHP10 and allow
The President may declare an emergency under the Stafford
FEMA to provide financial and/or direct
Act when federal assistance is necessary to save lives and
assistance for housing, as well as
protect public health and safety. Although the President may
financial assistance for other needs
authorize IA pursuant to an emergency or major disaster
declaration, the IHP is one of only two forms of IA that may be
(referred to as Other Needs Assistance
authorized pursuant to an emergency declaration (Crisis
or ONA) to eligible individuals and
Counseling may also be authorized pursuant to an emergency)
households. The IHP covers uninsured
(42 U.S.C. §5192(a)(6)).
or under-insured necessary expenses
According to FEMA, it is uncommon for IA-IHP to be
and serious needs resulting from the
authorized pursuant to an emergency declaration. The IHP has
disaster that cannot be otherwise met.11
been authorized pursuant to an emergency declaration three
IHP assistance is intended to meet basic
times since 1985. Most recently, the Florida Surfside Building
Col apse (3560-EM-FL) received a presidential emergency
needs (e.g., repairing a home to make it
declaration authorizing IA-IHP on June 25, 2021. Prior to that,
habitable12 or replacing standard
the Texas Explosion (EM-3363-TX) received a presidential
household appliances like
declaration of emergency on April 19, 2013, for which IHP
refrigerators)13—and is not designed to
assistance was added on May 1, 2013, and Connecticut
received a presidential declaration of emergency for Hurricane
return primary residences or property to
Irene (EM-3331-CT) on August 27, 2011, for which IHP
their pre-disaster condition. As such, per
assistance was added on September 2, 2011. According to
FEMA’s guidance, “IHP assistance is
FEMA, these are the only emergencies for which the IHP has
not a substitute for insurance and cannot
been authorized from January 1, 1985 to December 6, 2021.
compensate for all losses caused by a
(FEMA, “Florida Surfside Building Col apse (3560-EM-FL),”
disaster.... ”14
https://www.fema.gov/disaster/3560; FEMA, “Texas Explosion

(EM-3363-TX),” https://www.fema.gov/disaster/3363; FEMA,
The IHP is authorized under Stafford
“Connecticut Hurricane Irene (EM-3331-CT),”
Act Section 408—Federal Assistance to
https://www.fema.gov/disaster/3331; email correspondence
from FEMA Congressional Affairs staff, December 6, 2021).
Individuals and Households.15 The

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. The IAPPG has also been amended, including through the
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 (hereinafter Memorandum from Keith Turi RE: Amendment to the IAPPG).
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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subcategories of Housing Assistance and ONA, as well as the types of IHP assistance under each
subcategory, are listed in Table 1.
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”).
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.
More detailed descriptions of these IHP assistance options, as well as recent significant
programmatic changes, 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, … 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
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).
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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

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
Defining “Cost Share”
assistance such as Rental Assistance and
By statute, the federal government pays 100% of the cost
Repair Assistance before providing other
associated with providing IHP Housing Assistance. The federal
types of housing assistance.21 In some
government pays 75% of the cost associated with providing
cases, FEMA may authorize a state,
IHP ONA, and the nonfederal share of ONA is paid from
funds made available by the state, territory, or Indian tribal
territory, or Indian tribal government’s
government (42 U.S.C. §5174(g); and 44 C.F.R. §206.110(i)).
request for Direct Housing Assistance
Although the Stafford Act does not provide the authority for
when eligible applicants are unable to
the President or FEMA to adjust the federal share of ONA
use Rental Assistance because affordable
(42 U.S.C. §5174(g)(2)), FEMA may waive or adjust the cost
housing resources are unavailable.22
share for disaster grants in insular areas such as the Virgin
Islands, Guam, American Samoa, and the Northern Mariana
The federal share of the costs of IHP
Islands (48 U.S.C. §1469a).
Housing Assistance is 100%.23
Of note, a cost share includes the portions of a federal
assistance program borne by the federal government and a
Financial Housing Assistance
nonfederal entity (2 C.F.R. §§200.29 and 200.306). The
nonfederal entity may contribute cash or use third party in-
Financial Housing Assistance is a grant
kind contributions to meet its portion of the cost share (per
provided directly to the individual or
the criteria in 2 C.F.R. §200.306). However, as the Stafford
Act specifies that the ONA nonfederal share must be paid
household by FEMA, and includes
from “funds made available by the state,” according to FEMA,
funding for temporary lodging expenses
this means that the Stafford Act does not permit states,
(i.e., Lodging Expense Reimbursement
territories, or tribes to count donated resources towards
(LER)), rent for temporary housing
satisfying their nonfederal cost share for ONA.20
accommodations (i.e., Rental
Assistance), and to repair or replace a damaged primary residence (i.e., Repair Assistance and
Replacement Assistance, respectively).24 Brief descriptions of the types of Financial Housing

18 42 U.S.C. §5174(b) and (c); 44 C.F.R. §206.110(c); and FEMA, IAPPG, pp. 78 and 93.
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 FEMA, Disaster Operations Legal Reference, v. 4.0, September 25, 2020, pp. 6—79. For additional information on
cost shares, see CRS Report R47646, Stafford Act Cost Shares: History, Trends, Analysis, by Erica A. Lee.
21 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).
22 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.
23 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 R47646, Stafford Act Cost Shares: History, Trends, Analysis, by Erica A. Lee.
24 FEMA, IAPPG, pp. 43 and 78.
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Assistance, and select considerations or limitations associated with each type of assistance, are
included below.25
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.26
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.27
Continued Temporary Housing Assistance (a continuation of Rental Assistance) is provided
“based on need and generally only when adequate, alternate housing is not available.”
Additionally, applicants must identify and work towards achieving their permanent housing
plan.28 To that end, individuals receiving Continued Temporary Housing Assistance must recertify
their need for such assistance and demonstrate that they are making progress on their permanent
housing plan. Further, they are expected to obtain and occupy permanent housing at the earliest

25 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.
26 FEMA, IAPPG, pp. 78-79.
27 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.
28 FEMA, IAPPG, pp. 80-81; 44 C.F.R. §206.114(a) and (b)(1) and (2). FEMA’s updates to its regulations are making a
change to when IHP applicants seeking continued rental assistance must have established a realistic permanent housing
plan such that the plan no longer needs to be established at the first certification for continued assistance. Instead,
according to FEMA’s interim final rule, “FEMA splits the recertification process into several timeframes and allow
applicants to build upon their preliminary documentation as the disaster recovery continues” (DHS/FEMA, “Individual
Assistance Program Equity,” 89 Federal Register 4035-4037, January 22, 2024).
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possible time.29 Unlike Initial Rental Assistance, Continued Temporary Housing Assistance is
based on the location of the post-disaster housing unit, and the assistance rate may be increased in
accordance with HUD FMR.30
Rental Assistance, including both Initial Rental Assistance and Continued Temporary Housing
Assistance, may be provided “for a total of 18 months or until the end of the 18-month period of
assistance, whichever comes first,” unless the period of assistance is extended.31 In addition,
applicants can receive an additional month of rent when used for a security deposit.32
Home Repair Assistance
Home Repair Assistance provides funding to
Maximum IHP Housing Award
homeowners to repair an owner-occupied primary
In FY2024, the maximum amount of financial
residence, utilities, and residential infrastructure
assistance for housing is $42,500 (adjusted
(e.g., privately owned access routes).33 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 excluded
disaster survivors’ home “safe, sanitary, or
from the housing assistance cap are accessibility-
functional.”34 FEMA may provide repair assistance
related repair or replacement costs.
for a mix of disaster-caused and pre-existing
(DHS/FEMA, “Notice of Maximum Amount of
damage when needed to make a home habitable.35
Assistance Under the Individuals and Households
Two limitations on Home Repair Assistance
Program,” 88 Federal Register 72520, October 20,
include (1) it is subject to the maximum amount of
2023, https://www.govinfo.gov/content/pkg/FR-
financial assistance for housing, with some
2023-10-20/pdf/2023-23168.pdf.)
exclusions (described below); and (2) it is
generally not intended to improve or even to return the primary residence to its pre-disaster
condition, with the exceptions of making reasonable hazard mitigation measures to make the

29 FEMA’s regulation at 44 C.F.R. §206.114, which describes the criteria for receiving continued assistance, does not
specify the period for certification for continued assistance, nor is it specified in FEMA’s guidance. However, in the
past, it has been done in three-month increments—this was specified in a previous version of FEMA’s regulations that
applied to disasters on or before October 2002 (see 44 C.F.R. §206.101(k)(2)), and it is in FEMA releases related to
some recent incidents, such as FEMA’s April 19, 2022, release related to Hurricane Ida, “Continued Rental Assistance:
It’s Here If You Need It,” available at https://www.fema.gov/fact-sheet/continued-rental-assistance-its-here-if-you-
need-it, which states, “Extensions on rental assistance may be granted for three-month periods up to a maximum of 18
months from August 29, 2021, the date of the Hurricane Ida disaster declaration.” Additionally, FEMA’s interim final
rule, effective March 22, 2024, provides a table of timeframes for Continued Temporary Housing Assistance that lists
three phases: Initial Recertification Phase (firsts two payments); Intermediate Recertification Phase (second two
payments); and Concluding Recertification Phase (final payments and any extension of the period of assistance)
(DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 4036, January 22, 2024 (see “Table 5:
Continued Temporary Housing Assistance Timeframes”).
30 FEMA, IAPPG, p. 81.
31 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.
32 FEMA, IAPPG, pp. 80-81.
33 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 RE: Amendment to the IAPPG, pp. 9-10).
34 FEMA, IAPPG, p. 85.
35 DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 4004, January 22, 2024. Prior to the new
rule going into effect, in order for FEMA to provide Repair Assistance, the component had to be functional
immediately prior to the declared incident (44 C.F.R. §206.117(b)(2)(i)(B)).
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home more resilient (described below) or improvements as required to conform with current local
building code requirements or ordinances.36
With regard to eligible hazard mitigation measures, the Home Repair Assistance provided for
mitigation is limited. However, selected reasonable hazard mitigation measures that make homes
more resilient may be permitted (even if they improve upon a component’s pre-disaster
condition). Specifically, in June 2021, FEMA announced initial mitigation measures that are
eligible for Home Repair Assistance, and in July 2022, FEMA announced additional eligible
wildfire mitigation measures.37 Home Repair Assistance includes the following mitigation
measures:
• Roof repair to withstand higher winds and help prevent water infiltration;
• Elevating a water heater or furnace to avoid future flood damage;
• Elevating or moving an electrical panel to avoid future flood damage;
• Covering vents in attics, crawlspaces, and enclosures below decks with metal
screens to prevent embers from entering (for eligible applicants affected by
wildfires); and
• Installing noncombustible leaf guards over gutters (for eligible applicants
affected by wildfires).
FEMA also permits Home Repair Assistance to be used to address disaster-caused mold.38
With regard to improvements, FEMA expanded the provision of Home Repair Assistance for
accessibility-related items to allow individuals with pre-existing or disaster-caused disabilities to
install or construct new real-property components that are necessary to meet their accessibility-
related needs—even if such items were not present in the home prior to the disaster.39 FEMA’s
guidance specifies some accessibility-related items as being eligible for Home Repair Assistance,
including disaster-damaged grab bars and an access ramp.40 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, as they now have a need for
accessibility items, including an exterior ramp; grab bars; and a paved path to the home’s
entrance.41 Accessibility-related items do not count towards the maximum amount of financial
assistance for housing.42

36 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).
37 FEMA’s guidance details the specific types of mitigation measures available for Home Repair Assistance. 44 C.F.R.
§§206.111 and 206.117(a), (b)(2)(i), (b)(2)(iii), and (b)(2)(iv); FEMA, IAPPG, pp. 85-88; 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”); FEMA, “FEMA to Provide Additional Hazard Mitigation Funds to Help Homeowners Affected by Wildfires,”
press release, HQ-22-089, July 28, 2022, https://www.fema.gov/press-release/20220728/fema-provide-additional-
hazard-mitigation-funds-help-homeowners-affected (hereinafter FEMA, “Hazard Mitigation for Wildfires”).
38 Memorandum from Keith Turi RE: Amendment to the IAPPG, p. 9.
39 DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 3997, January 22, 2024.
40 FEMA, IAPPG, p. 86.
41 Memorandum from Keith Turi RE: Amendment to the IAPPG, p. 10.
42 42 U.S.C. §5174(h)(4)(A).
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Home Replacement Assistance
Home Replacement Assistance provides funding to homeowners to help replace a disaster-
destroyed owner-occupied primary residence.43 Home Replacement Assistance is unavailable for
nontraditional housing or residence types, such as tents, lean-to structures, yurts, and converted
shipping containers.44 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.45
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.46
Direct Housing Assistance
Direct Housing Assistance is housing provided to the individual or household by FEMA (or the
state, territory, or Indian tribal government).47 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).48
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

43 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)”).
44 FEMA, IAPPG, p. 92.
45 FEMA, IAPPG, p. 91.
46 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.
47 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).
48 FEMA, IAPPG, p. 93.
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3. assistance from other providers (e.g., government and voluntary organizations) is
insufficient to meet the housing needs.49
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.50
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.”51 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.”52 Brief descriptions of the types of Direct Housing
Assistance, and selected considerations or limitations associated with each type of assistance, are
included below.53
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).54 MLR is not intended to make repairs or improvements to multi-family housing

49 FEMA, IAPPG, p. 94. HUD’s PD&R posts FMR information at https://www.huduser.gov/portal/datasets/fmr.html.
50 FEMA, IAPPG, p. 93.
51 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)).
52 FEMA, IAPPG, pp. 93 and 95.
53 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.
54 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.
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units for the purpose of rehousing existing tenants.55 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.56 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.57
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)).58 TTHU sites must meet
specific requirements that include (1) providing access to available and functional utilities;59 (2)
complying with government ordinances; and (3) satisfying federal floodplain management and
Environmental Planning and Historic Preservation (EHP) compliance review requirements.60 The
IAPPG states that “FEMA selects locations based on the cost-effectiveness, timeliness, and
suitability of each potential site,”61 and the IAPPG includes a complete list of requirements and
considerations for the eligibility and prioritization of each site type.62
TTHU Site Types
Private Sites are provided at no cost to FEMA by the applicant (usually on the applicant’s property).

Commercial Sites allow FEMA to lease available pads in an existing manufactured home park.

Group Sites are provided by the state or local government (e.g., publicly owned park land), and are only
considered when no other Direct Temporary Housing Assistance options can meet the housing need.
FEMA has the statutory authority to dispose of TTHUs via sale or donation when requested, in
writing, by the affected state, territory, or Indian tribal government when certain conditions are
met,63 including that a TTHU can be sold to its occupants if they lack permanent housing, or a

55 FEMA, IAPPG, p. 107.
56 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.
57 FEMA, IAPPG, p. 110.
58 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).
59 FEMA, IAPPG, pp. 113-116. Utilities include available and functional sanitation, electrical service, and potable
water service.
60 FEMA, IAPPG, p. 112.
61 FEMA, IAPPG, p. 112.
62 FEMA, IAPPG, pp. 113-116.
63 42 U.S.C. §5174(d)(2); FEMA, IAPPG, p. 119 (see the considerations for authorizing the disposal of TTHUs through
sales and donations).
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TTHU may be sold, transferred, donated, or made available to a government entity or voluntary
organization to enable them to continue providing temporary housing to eligible occupants who
are unable to afford to purchase the TTHU from FEMA.64
Direct Lease
Direct Lease places disaster survivors in FEMA-leased residential properties.65 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.66 The IAPPG includes a complete list of
Direct Lease property compliance standards and prioritization considerations.67
Permanent Housing Construction (PHC)
PHC is a last resort used to provide repairs or new home construction.68 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
Housing Assistance are unavailable, infeasible or not cost-effective.”69 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.70 Although PHC is not subject to the maximum amount of financial assistance,
there is a cost cap for PHC repair and new construction, which is set at the disaster level.71
Legislative and Regulatory Changes and Significant Program Updates:
Housing Assistance
Several sections of the Disaster Recovery Reform Act of 2018 (DRRA, Division D of P.L. 115-
254) amended the provision of Housing Assistance under Stafford Act Section 408.72 These

64 42 U.S.C. §5174(d)(2); see also FEMA, IAPPG, pp. 119-124.
65 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).
66 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).
67 FEMA, IAPPG, pp. 125-126.
68 FEMA, IAPPG, p. 127.
69 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.
70 FEMA, IAPPG, p. 141.
71 FEMA, IAPPG, p. 128.
72 For more information on DRRA, see CRS Report R46776, The Disaster Recovery Reform Act of 2018 (DRRA):
(continued...)
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statutory amendments changed the implementation of IHP Housing Assistance, and are reflected
in the current IAPPG. DRRA:
• Increased the Maximum IHP
DRRA Separated the Maximum Awards
Award Amounts (DRRA Section
for Housing Assistance and ONA
1212) by establishing separate caps of
Prior to DRRA’s enactment, the Stafford Act imposed a
equal amounts for the maximum
total limit on the maximum amount of all IHP financial
amount of financial assistance eligible
assistance an individual or household could receive for a
individuals and households may
single disaster (i.e., housing assistance and ONA
receive for Financial Housing
combined to count towards the cap).
Assistance and ONA.73 It also
DRRA Section 1212 created two separate limits on the
removed financial assistance to rent
financial assistance eligible individuals and households
may receive: one for housing assistance and one for
alternative housing accommodations
ONA. Additionally, DRRA excluded some forms of
(i.e., Lodging Expense
assistance that previously counted towards the limit.
Reimbursement, Rental Assistance,
Thus, post-DRRA, financial assistance for housing-
and Continued Temporary Housing
related needs may not exceed $42,500 (FY2024;
Assistance) from the cap,
adjusted annually), and financial assistance for ONA may
74 and
not exceed $42,500 (FY2024; adjusted annually).
created an exclusion to the cap for
The enactment of DRRA Section 1212 effectively
accessibility-related repair or
increased the amount of financial assistance an
replacement costs associated with real
individual or household could be eligible to receive
and personal property (e.g., eligible
through the IHP.
household items).75
(DHS/FEMA, “Notice of Maximum Amount of
•
Assistance Under the Individuals and Households
Expanded MLR Property
Program,” 88 Federal Register 72520, October 20, 2023,
Eligibility (DRRA Section 1213) by
https://www.govinfo.gov/content/pkg/FR-2023-10-20/
expanding the eligible areas for
pdf/2023-23168.pdf.)
MLR,76 and deducting the value of
improvements from the value of the lease agreement.77
On January 22, 2024, FEMA published an interim final rule (IFR)—“Individual Assistance
Program Equity”—amending its IHP regulations, which went into effect March 22, 2024.
Significant changes to FEMA’s housing assistance include:
• Allowing Home Repairs for a Mix of Disaster-Caused and Pre-Existing
Damage, enabling disaster survivors to repair their homes to a “safe and sanitary
living or functioning condition,” consistent with the statute, by removing the
regulatory limitations associated with pre-existing damage.
• Expanding Home Repair Assistance for Accessibility-Related Items to allow
individuals with pre-existing or disaster-caused disabilities to install or construct
new real-property components that are necessary to meet their accessibility-

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.
73 DRRA Section 1212.
74 FEMA, IAPPG, pp. 41-42.
75 DRRA Section 1212.
76 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.
77 DRRA Section 1213(a).
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related needs—even if such items were not present in the home prior to the
disaster.78
Other Needs Assistance
Individuals and households may require various types of 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.”79
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.80
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.81 For example, “FEMA may award applicants Funeral Assistance and
Child Care Assistance up to the limits established by the STT [state, territory, or tribal]
government in the ONA Administrative Option Selection Form.... ”82
Additionally, ONA, unlike housing assistance, is subject to a cost share.83 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.”84 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.85

78 DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 3990-4125, January 22, 2024.
79 FEMA, IAPPG, p. 145.
80 Financial assistance for ONA may not exceed $42,500 (FY2024; adjusted annually) (DHS/FEMA, “Notice of
Maximum Amount of Assistance Under the Individuals and Households Program,” 88 Federal Register 72520,
October 20, 2023, https://www.govinfo.gov/content/pkg/FR-2023-10-20/pdf/2023-23168.pdf).
81 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. 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-
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).
82 FEMA, IAPPG, p. 149.
83 See the “Defining ‘Cost Shares’” text box for the cost share definition.
84 42 U.S.C. §5174(g)(2)(B).
85 42 U.S.C. §5174(g)(2); 44 C.F.R. §206.110(i)(2); and FEMA, IAPPG, p. 147.
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Serious Needs Assistance
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.”86
Displacement Assistance
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).87
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.88 Eligible Personal Property items
include standard household appliances (and selected accessibility items); essential clothing;
standard furnishings; essential, specialized tools and equipment required by an employer
(essential equipment for self-employment is ineligible) or for education, as well as a self-
employed individual’s disaster-damaged essential tools and equipment, and required items for
their trade/profession.89
Per the IAPPG, FEMA and the affected state, territory, or Indian tribal government determine the
personal property that may be eligible for assistance, including establishing the maximum
quantity that may be awarded for each item. This is done through the “ONA Administrative
Option Selection Form’s” “Standard Personal Property Line Items” list.90
Accessibility items that are eligible for Personal Property Assistance and are exempted from the
ONA maximum amount of financial assistance include the following items:
• 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);

86 DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 4012, 4023-4024, and 4123, January 22,
2024. Serious Needs Assistance replaced Critical Needs Assistance (sometimes referred to as “Immediate Needs
Assistance”). Critical Needs Assistance could be requested by an affected state, territory, or Indian tribal government
within 14 days of a Stafford Act declaration, when needed, to assist applicants from a specific geographic area who
were displaced from their primary residence or who had to temporarily shelter elsewhere, but Serious Needs Assistance
is available immediately for declarations when IA is authorized and IHP assistance is available, and it is also available
to disaster survivors who have immediate needs—and not only individuals who are displaced or need to shelter
elsewhere.
87 DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 4024 and 4123, January 22, 2024.
88 FEMA, IAPPG, pp. 166-167.
89 FEMA, IAPPG, p. 167; DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 4010, January
22, 2024.
90 FEMA, IAPPG, pp. 166-167.
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• 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).91
Transportation Assistance
Transportation Assistance provides funding to repair or replace a vehicle damaged by a declared
emergency or disaster.92 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.93 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.94 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.”95
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.96
To reduce future flood 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.97 GFIPs are established under the National Flood Insurance Program (NFIP).
The premium for a three-year certificate of coverage costs $2,400,98 and it covers real and

91 FEMA, IAPPG, p. 146.
92 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.”
93 FEMA, IAPPG, p. 170.
94 FEMA, IAPPG, pp. 170, 172.
95 FEMA, IAPPG, p. 170.
96 44 C.F.R. §206.110(k)(3); FEMA, IAPPG, p. 63.
97 FEMA, IAPPG, p. 172.
98 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).
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personal property equaling the maximum amount of financial assistance available for both
Housing Assistance and ONA (e.g., for FY2024, $85,000).99
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).100 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.101
Funeral Assistance
Funeral Assistance provides funding to assist with eligible funeral expenses (e.g., interment or
reinterment, funeral and officiant services, and death certificates).102 Unlike most forms of IHP
assistance, applicants do not need to live in the area designated to receive IA,103 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,104 and the expenses are not
covered by other sources (e.g., burial insurance or assistance from voluntary agencies).105
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.)

99 FEMA, IAPPG, p. 172.
100 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).
101 FEMA, IAPPG, p. 174.
102 FEMA, IAPPG, pp. 150-152.
103 FEMA, IAPPG, p. 150.
104 FEMA, IAPPG, p. 150
105 FEMA, IAPPG, p. 151.
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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.106 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.107 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;108 (2) other childcare services must not be available;109 and (3) the care provider must
be licensed, regulated, or registered per the applicable state, territory, tribal or local government’s
laws.110
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).111 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.112
Miscellaneous Expenses
Miscellaneous Expenses provides funding to reimburse people for purchasing or renting eligible
items to assist with their disaster recovery efforts.113 Eligible items can include carbon monoxide
and smoke detectors, dehumidifiers or humidifiers, chainsaws, generators, and weather radios,114
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

106 FEMA, IAPPG, p. 155.
107 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.”
108 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.
109 FEMA, IAPPG, p. 156.
110 FEMA, IAPPG, p. 156.
111 FEMA, IAPPG, p. 153.
112 FEMA, IAPPG, p. 153.
113 FEMA, IAPPG, pp. 160-162.
114 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.
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Selection Form”; additional miscellaneous items could also be included by the state, territory, or
tribe.115
Moving and Storage Assistance
Moving and Storage Assistance 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.116 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.117
Clean and Sanitize Assistance
Clean and Sanitize 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).118
CSA is provided in the form of a one-time payment, which is limited to $300, to “ensure minimal
damage to the home is addressed in order to prevent additional losses and potential health and
safety concerns.”119 Eligibility is limited to applicants who do not qualify for Home Repair
Assistance because their primary residence was not rendered uninhabitable.120
Legislative and Regulatory Changes and Significant Program Updates: ONA
As described in detail above in the “Legislative and Regulatory 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 excluding accessibility-related repair or replacement costs from the cap (for a list of eligible
personal property items, see the shaded text box “Accessibility Items Eligible for Personal
Property Assistance”).121
Additionally, FEMA’s interim final rule (IFR), “Individual Assistance Program Equity,” which
went into effect March 22, 2024, amended FEMA’s IHP regulations, including related to the
provision of ONA. The amended regulations seek to address long-standing concerns expressed by
some Members of Congress, stakeholders including disaster survivors, and federal agencies
(comments to this effect and FEMA’s responses are detailed throughout the IFR). For example,
some Members of Congress, stakeholders, and the Government Accountability Office found the

115 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.’”
116 FEMA, IAPPG, p. 162.
117 FEMA, IAPPG, pp. 162 and 164.
118 Memorandum from Keith Turi RE: Amendment to the IAPPG, p. 11; and FEMA, IAPPG, p. 165.
119 Memorandum from Keith Turi RE: Amendment to the IAPPG, pp. 11-12.
120 Memorandum from Keith Turi RE: Amendment to the IAPPG, p. 11.
121 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.
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process to receive Small Business Administration (SBA)-Dependent ONA unnecessarily
confusing and onerous; the IFR has simplified this process. Specifically, the IFR removed the
previous requirement that IHP applicants who met the SBA’s minimum income requirements first
apply for an SBA disaster loan, and either be denied or receive a partial loan, before they could be
considered for FEMA’s SBA-Dependent ONA, which included assistance for personal property,
transportation, and GFIPs. The new process allows IHP applicants to receive the IHP assistance
they apply and are eligible for, including all forms of ONA, without first having to apply for an
SBA disaster loan.122 (IHP applicants may still choose to apply for an SBA disaster loan if they
require additional funding to address their unmet real or personal property needs.)
In addition, the IFR established the new forms of ONA: Serious Needs Assistance and
Displacement Assistance (described above). Further, it allows self-employed individuals to
receive Personal Property Assistance for disaster-damaged essential tools and equipment, and
required items for the trade/profession (described above).
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.123 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 (IA).124 Instead, following an
incident,125 the governor or chief executive must request that the President declare an emergency
or major disaster authorizing IA.126 The governor or chief executive’s request must demonstrate
that they are unable to effectively respond to the incident without federal assistance.127 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.128
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

122 DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 4009, January 22, 2024.
123 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).
124 44 C.F.R. §§206.35-206.38, and 206.40(a); and FEMA, “How a Disaster Gets Declared.”
125 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)).
126 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.
127 44 C.F.R. §§206.35 and 206.36.
128 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.
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supplemental federal assistance to individuals (i.e., IA).129 This includes information collected
through the Preliminary Damage Assessment (PDA) process, which is validated by local, state,
territory, Indian tribal government, and federal authorities.130 FEMA then provides a
recommendation to the President.131 The decision to grant an emergency or major disaster
declaration request is at the President’s sole discretion.132
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
available,” in practice, FEMA has stated that they will seek the President’s approval when
authorizing additional forms of assistance.133
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.134 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).135

129 44 C.F.R. §206.48(b); and FEMA, Tribal Declarations Pilot Guidance, pp. 36-38.
130 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).
131 44 C.F.R. §206.37(c).
132 44 C.F.R. §206.38.
133 44 C.F.R. §206.40; and email correspondence from FEMA Congressional Affairs staff, June 12, 2020.
134 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.
135 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).
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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)).136 The
updated factors became effective June 1, 2019.
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.137 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.138 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.139
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 2 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.

136 Section 1109 of SRIA; DHS/FEMA, “Factors Considered When Evaluating a Request for IA”; and 44 C.F.R.
§206.48(b).
137 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.
138 FEMA, Tribal Declarations Pilot Guidance.
139 FEMA, “Tribal Declarations Pilot Guidance,” https://www.fema.gov/disaster/tribal-declarations.
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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.
Figure 2. 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.
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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.140 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.141
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.”
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.142
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.143 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.”144

140 FEMA, IA Declarations Factors Guidance, p. 15.
141 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.”
142 FEMA, Preliminary Damage Assessment Guide, pp. 28-41.
143 FEMA, IA Declarations Factors Guidance, pp. 14-15.
144 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.
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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).145 The higher the estimated cost of IHP
assistance and the lower the state’s fiscal resources, the more likely a request will be granted.146
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).
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 3.
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 declarations147 and the ICC Ratio for
past requested and approved declarations.148 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.

145 FEMA, IA Declarations Factors Guidance, p. 14.
146 FEMA, IA Declarations Factors Guidance, p. 15.
147 FEMA, IA Declarations Factors Guidance, p. 14. See the information provided in “Table 1: Estimated Cost of
Assistance Compared to Declaration Decision Comparative.”
148 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.”
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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

Figure 3. 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.149 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
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.150 Ultimately, however, the decision to approve a governor’s request for a
major disaster declaration authorizing IA is at the discretion of the President.151
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.152

149 FEMA, IA Declarations Factors Guidance, p. 15.
150 44 C.F.R. §206.37(c)(1).
151 44 C.F.R. §206.38(a).
152 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.
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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.153 Disaster survivors can
register for assistance online or through the FEMA mobile application, by telephone, or in-person
at a Disaster Recovery Center (DRC).154
Applicants generally have 60 days from the presidential declaration authorizing Individual
Assistance to apply for IHP assistance. After the end of the initial registration period, FEMA may
accept late applications for an additional 60 days if the applicant provides a reasonable
explanation for the delay (no written justification or documentation explaining the circumstances
that prevented them from applying on time are required; this is a change made by FEMA’s
updated regulations).155 FEMA does not accept applications after this point.156
The registration deadline does not change for areas that are subsequently designated for
assistance (meaning they may have shorter application periods). The registration period, however,
can be extended at the request of the affected state/territory/tribe (with approval from FEMA). If
the Stafford Act declaration is amended to include additional counties following the expiration of
the registration period, then the registration period can be reopened, but only for the newly
authorized counties (this is a change made by FEMA’s updated regulations).157

153 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.”
154 FEMA, IAPPG, p. 69.
155 Department of Homeland Security (DHS)/FEMA, “Individual Assistance Program Equity,” 89 Federal Register
3995 and 4031, January 22, 2024. Reasonable explanations for late applications can include incarceration, that the
applicant was the victim of human trafficking, ongoing domestic situations in which persons pose an immediate threat
to a family member in the same household, major life events (e.g., birth or a child, marriage),
hospitalization/illness/disability of the applicant or an immediate family member, death of an immediate family
member, or proof of personal or business travel out of the area during the application period.
156 FEMA, IAPPG, pp. 70-71; 44 C.F.R. §206.112.
157 DHS/FEMA, “Individual Assistance Program Equity,” 89 Federal Register 4030, January 22, 2024. FEMA
provided CRS with an example of one instance when the registration period was reopened. According to FEMA,
following the 2020 Puerto Rico Earthquakes (DR-4473-PR), the municipality of Rincon was approved and added to the
presidential declaration after the registration period and the 60-day late registration period had ended. Specifically, the
registration period for DR-4473-PR closed on July 2, 2020, and the late registration period closed on September 1,
2020. Rincon Municipality was designated for Individual Assistance on March 25, 2021. Facing the previously
unprecedented situation of having an additional designation for IA more than six months after the late registration
period had already closed, the FEMA Individual Assistance Division consulted with FEMA’s Office of Chief Counsel
(OCC) to identify a solution to provide disaster survivors in Rincon Municipality the opportunity to apply for and
receive assistance. FEMA’s OCC determined that the registration period could be reopened in this one instance to
allow applicants from the Rincon Municipality to apply for assistance. The registration period remained closed for all
other municipalities included in DR-4473-PR.
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Applicant Eligibility
The registration process requires applicants to submit a Declaration and Release Form,158 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).159
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—they must:
1. be a U.S. citizen, noncitizen national, or “qualified alien” (or the parent or
guardian of such a minor);160
2. have their identify verified by FEMA;
3. have disaster-caused needs that cannot be met through their insurance or other
forms of disaster assistance; and
4. have necessary expenses and serious needs that were directly caused by a
declared disaster.161
Each type of IHP assistance requires that additional eligibility conditions be met, and may require
additional documentation.162 For example, Home Repair and Home Replacement assistance are
only available to homeowners, and some forms of assistance require proof of occupancy and/or

158 DHS/FEMA, “Declaration and Release,” Form, O.M.B. No. 1660-0002, expires March 31, 2024,
https://www.fema.gov/sites/default/files/documents/fema_form-ff-104-FY21-128_042022.pdf.
159 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. Other methods to verify losses include a geospatial
inspection or a review of documentation.
160 There are some categories of “aliens lawfully present in the U.S. who are not eligible for IHP assistance,” such as
temporary tourist visa holders, and habitual residents, such as citizens of the Federated States of Micronesia and the
Republic of the Marshall Islands. FEMA, IAPPG, p. 47 (see FEMA’s guidance for a complete list of eligible and
ineligible IHP applicants).
161 FEMA, IAPPG, p. 46. See also FEMA, “Eligibility Criteria for FEMA Assistance,” last updated November 28,
2022, https://www.fema.gov/assistance/individual/program/eligibility; FEMA, “Individuals and Households Program,”
last updated April 5, 2023, https://www.fema.gov/fact-sheet/individuals-and-households-program.
162 See the IAPPG guidance on the type of IHP assistance being requested for additional requirements.
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ownership.163 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.164
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.165 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.”166
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.167 Under another provision of PRWORA, 8 U.S.C. §1611, so-

163 FEMA, IAPPG, pp. 46, 51-55; Memorandum from Keith Turi RE: Amendment to the IAPPG, pp. 2-9.
164 FEMA, IAPPG, p. 61.
165 FEMA, IAPPG, p. 48.
166 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.
167 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.168 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.169
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.170 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.171
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
172 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

168 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.”
169 See CRS Report R46510, PRWORA’s Restrictions on Noncitizen Eligibility for Federal Public Benefits: Legal
Issues, by Ben Harrington, p. 13 (citations omitted).
170 FEMA, IAPPG, pp. 6 and 41.
171 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).”
172 GAO, Disaster Assistance: IHP, p. 19.
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(i.e., the FEMA-Verified Loss (FVL) amount)173 and whether and to what extent the real and
personal property losses were insured.174
A FEMA inspection is used to verify losses related to real and personal property, and is typically
conducted on-site by a FEMA inspector, and FEMA may also verify disaster-caused losses via a
geospatial inspection or documentation (e.g., medical bills or receipts for automobile repairs).175
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
exclusions),176 and some forms of ONA are subject to further financial limits established by the
affected state, territory, or Indian tribal government.177
As stated above, insurance also factors into the amount of financial assistance an applicant may
receive.178 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.179
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.180 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.181
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

173 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.)
174 GAO, Disaster Assistance: IHP, pp. 18-20.
175 FEMA, IAPPG, p. 72.
176 42 U.S.C. §5174(h)(4). There are exclusions to the maximum amount of financial assistance for select disaster-
damaged accessibility-related real and personal property items (FEMA, IAPPG, pp. 86 and 146).
177 FEMA, IAPPG, pp. 147 and 149; see also 44 C.F.R. §206.120(c) and (d).
178 Prior to March 22, 2024, disaster survivors whose net insurance proceeds were equal to or greater than the statutory
maximum amount of financial assistance FEMA can provide under the IHP (42 U.S.C. §5174(h)) were found ineligible
for IHP assistance, but following that date, FEMA’s amended regulations became effective such that underinsured
disaster survivors may receive assistance to address their uninsured or underinsured disaster-caused necessary expenses
and serious needs (up to the maximum amount of financial assistance) even when their net insurance proceeds are equal
to or greater than the maximum amount of financial assistance. DHS/FEMA, “Individual Assistance Program Equity,”
89 Federal Register 4018, January 22, 2024.
179 FEMA, IAPPG, pp. 49-51.
180 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.
181 FEMA, IAPPG, p. 51.
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assistance.182 If this occurs, applicants for IHP assistance may appeal FEMA’s determinations,
including, but not limited to, appeals of
• applicant eligibility determinations;183
• the amount and/or type(s) of assistance received;184 and
• late application rejections.185
FEMA explains the appeal process as follows:
• To appeal any IHP assistance-related FEMA determination, applicants have 60
days from the date on their eligibility notification letter to submit documentation
supporting the appeal request (a written and signed appeal letter of explanation is
not required).186
• 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.187
• FEMA’s shall provide appeal determinations to the applicant in writing within 90
days of receiving the appeal, and FEMA’s decision is final (i.e., it cannot be
appealed again).188
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.189 Examples of improper payments include
overpayments, payments made to ineligible recipients, payments used for ineligible services, and
duplication of benefits.

182 44 C.F.R. §206.113.
183 44 C.F.R. §206.115(a)(1); FEMA, IAPPG, p. 66. Applicants have 60 days to appeal initial eligibility determinations.
184 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)).
185 44 C.F.R. §206.115(a)(4); FEMA, IAPPG, p. 66.
186 44 C.F.R. §206.115(b); FEMA, IAPPG, pp. 66-67; and DHS/FEMA, “Individual Assistance Program Equity,” 89
Federal Register 3999, January 22, 2024.
187 44 C.F.R. §206.115(f); FEMA, IAPPG, p. 68.
188 44 C.F.R. §206.115(f); FEMA, IAPPG, p. 68.
189 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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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
2. “if such [covered] assistance [i.e., IHP assistance] is subject to a claim or legal
action.... ”190
To the first circumstance, according to FEMA, the agency “must proactively assess if [a] potential
debt is the result of FEMA error and if it is FEMA will not proceed with any action to seek the
assistance back from the applicant and ‘waive’ proceeding with debt collection.”191 Further, to the
second circumstance, according to FEMA,
FEMA interprets the waiver requirement for ‘a claim or legal action’ as applicable to
circumstances where, for example, FEMA provides Individual Assistance and then
subsequently a utility is determined responsible for the major disaster event and provides
reimbursement for the losses caused by the utility to the same Individual Assistance
applicants FEMA provided assistance to. In this circumstance FEMA will not determine
its assistance a duplication and will not proceed with any action to seek assistance back
from the applicant.192
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.193
General IHP Limitations
IHP assistance is subject to limitations. For example, as described above, the provision of IHP is
subject to applicant eligibility restrictions,194 and there are caps on the maximum amount of
financial assistance an individual or household is eligible to receive for a single emergency or
major disaster.195
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.

190 Section 5602(a) of the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 (P.L. 117-263).
191 FEMA Office of External Affairs email correspondence with CRS dated October 4, 2023.
192 FEMA Office of External Affairs email correspondence with CRS dated October 4, 2023.
193 FEMA, IAPPG, pp. 177-182 (see “Figure 33: FEMA Process for Identifying and Validating Debt Payments”).
194 FEMA, IAPPG, p. 46. For additional information, see the “Applicant Eligibility” section.
195 42 U.S.C. §5174(h). For additional information, see the “Legislative and Regulatory Changes and Significant
Program Updates: Housing Assistance” and “Legislative and Regulatory Changes and Significant Program Updates:
ONA” sections.
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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.”196
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.197 Further, Home Repair Assistance and Home Replacement
Assistance are unavailable to landlords unless they permanently reside in the
damaged dwelling.198
• Enable homeowners to repair all disaster-caused damage or restore their home to
its pre-disaster condition.199
• Enable homeowners to make improvements using Home Repair Assistance;
however, repairs may include specific hazard mitigation measures to make the
housing more resilient, as well as accessibility-related items.200
• 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.201
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).202
However, some forms of IHP assistance have shorter periods of availability.

196 GAO, Disaster Assistance: IHP, pp. 10 and 18.
197 42 U.S.C. §5174(b)(1), (c)(2)(A), (c)(3)(A); FEMA, IAPPG, p. 43; GAO, Disaster Assistance: IHP, p. 18.
198 42 U.S.C. §5174(b)(1); FEMA, IAPPG, pp. 87 and 92.
199 44 C.F.R. §206.117(b)(2)(i)(E); FEMA, IAPPG, p. 85; GAO, Disaster Assistance: IHP, p. 18.
200 FEMA, IAPPG, pp. 85-86; FEMA, “Hazard Mitigation Under the IHP”; FEMA, “Hazard Mitigation for Wildfires.”
201 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.
202 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.” Per the FEMA Disaster Operations Legal
Reference, v. 4.0, September 25, 2020, pp. 6—23-24, with regard to the IHP period of assistance, it states that, “FEMA
may provide IHP assistance for a ‘period of assistance’ not to exceed 18 months from the date of declaration,” citing
“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. See Stafford Act § 408(c)(1)(B)(iii), 42 U.S.C.
(continued...)
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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.203
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.

§5174(c)(1)(B)(iii) and 44 C.F.R. §206.110(e).” It also states, “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.”
203 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
Subject to the disaster-level cost cap for PHC repair and new
Direct
Construction
construction.
ONA
Serious Needs
NA
$750 for immediate post-disaster needs for items such as food

Assistance
and water, first aid, infant formula and diapers, personal hygiene
items, and fuel for or the cost of transportation.

Subject to the maximum amount of financial assistance for ONA.
Displacement
NA
Incident-specific assistance.
Assistance

Subject to the maximum amount of financial assistance for ONA.
Personal Property
NA
Affected state/territory/Indian tribal government identifies eligible
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.
Funeral Assistance
NA
Affected state/territory/Indian tribal government establishes the
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
CRS-37

Housing/ONA
Type of Assistance
Time Limitation
Financial Limitation
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.
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.
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; 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.
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
Defining “Duplication of Benefits” (DOB)
providing assistance that could constitute
There is a statutory prohibition on providing a duplication of
a duplication of benefits, including in the
benefits. 42 U.S.C. §5155 requires the President, in
provision of IHP assistance.204
consultation with the heads of the federal agencies
Additionally, when applying for IHP
administering financial assistance programs, to “assure that
no such person .. wil receive such assistance with respect
assistance, applicants “must agree to
to any part of such loss as to which he has received financial
return funds to FEMA when the assistance
assistance under any other program or from insurance or
provided by FEMA duplicates assistance
any other source.”
from another source.”205
As explained in FEMA’s regulation at 44 C.F.R.
§206.191(d)(1)(i), a duplication of benefits occurs when an
Federal agencies are supposed to
agency provides assistance, but providing such assistance was
coordinate to avoid providing a
the primary responsibility of another agency and that agency
duplication of benefits, and to rectify
with primary responsibility later provides assistance.
situations when a duplication occurs.206
To prevent a duplication of benefits from occurring, FEMA’s regulations include a delivery
sequence for disaster assistance, which “establishes the order in which disaster relief agencies and
organizations provide assistance.”207 Table 4 depicts the delivery sequence (as updated in
FEMA’s amended regulations).
Figure 4. Sequence of Delivery to Avoid a Duplication of Benefits
Effective March 22, 2024.

Source: Based on CRS’s interpretation of 44 C.F.R. §206.191(d) and DHS/FEMA, “Individual Assistance Program
Equity,” 89 Federal Register 4124, January 22, 2024.

204 42 U.S.C. §5155; 44 C.F.R. §206.191.
205 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.
206 44 C.F.R. §206.191(b)(1).
207 44 C.F.R. §206.191(d)(1)(i) and (d)(2).
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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.)
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.208 Other forms of
federal assistance may also be available to meet the unmet needs of disaster survivors, depending
on the disaster.209
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.210 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.
Although there is some publicly available information related to the decisionmaking process
associated with evaluating major disaster declaration requests, the available information is
limited. FEMA publishes Preliminary Damage Assessment (PDA) Reports, which are posted to

208 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.
209 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.
210 Additional information on the declaration process can be found in the “Approving Requests for Individual
Assistance” section.
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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).211 Historically, there was a PDA Report
publication requirement authorized in previous annual appropriations legislation.212 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).213
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.214 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
agency.”215 It is possible that portions of FEMA’s analysis concerning its evaluation of the factors

211 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).
212 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).
213 FEMA, “PDA Reports.” It can take time for the most recent PDA reports to be published.
214 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.
215 5 U.S.C. §552(b)(5).
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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,216 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.217
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,218
Direct Housing Assistance information is not generally publicly available.219 In December 2020,

216 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).
217 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).
218 See FEMA, “OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets; see also FEMA, “Declared
Disasters,” https://www.fema.gov/disaster/declarations.
219 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 13. For select incidents, however, FEMA has
(continued...)
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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.220 The GAO provided recommendations to allow FEMA to analyze the full cost of
providing Housing Assistance.221 FEMA is developing a new system (called the “Grants
Management Modernization System”), which is to include a disaster housing assistance
component.222 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.”223 Consistent with the GAO’s recommendations, with which DHS concurred,224
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.225 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.226 Further, once the expanded direct housing assistance
data exists, Congress may seek for FEMA to publicly report on the costs of its Direct Housing
Assistance programs by publishing the data in the IA OpenFEMA Data Sets. Such a requirement
would be consistent with other congressional efforts to increase government transparency and

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).
220 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 13.
221 GAO, Disaster Housing: Improved Cost Data and Guidance, p. 20.
222 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.
223 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”).
224 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.)
225 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.”
226 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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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,227 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,228 some also provide the amount of
Housing Assistance awarded and the amount of ONA awarded.229 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.230 Assistance provided for all types of ONA is generally aggregated.231 To the extent
that granularity is provided with regard to awards for specific types of ONA, the data is limited to
Personal Property Assistance,232 but it is unclear how much assistance was provided for other
specific types of ONA.233 (See Table C-1 for a list of the data fields provided for each of the

227 See FEMA, “OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets; see also FEMA, “Declared
Disasters,” https://www.fema.gov/disaster/declarations.
228 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.”
229 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.
230 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.
231 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).”
232 For example, the IHP Valid Registrations dataset provides the amount of ONA awarded for Personal Property
Assistance.
233 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
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
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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.234 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 pandemic235 and the 1992
Los Angeles civil unrest).236 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
provide grants to states, territories, and the District of Columbia for supplemental lost wages

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.
234 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)).
235 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.
236 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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payments to individuals receiving unemployment insurance—which was a novel use of ONA.237
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),238 among other things.239
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.240 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.241 Although Rental Assistance is a
form of IHP assistance,242 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.243 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
displacement.244 The 2001 version of Stafford Act Section 408(b)—Temporary Mortgage and
Rental Payments read as follows:

237 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.
238 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.
239 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).
240 FEMA, “Coronavirus (COVID-19) Response,” https://www.fema.gov/disaster/coronavirus.
241 FEMA, “Florida Surfside Building Collapse (3560-EM-FL),” https://www.fema.gov/disaster/3560.
242 42 U.S.C. §5174(c)(1)(A).
243 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.
244 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.
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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].245
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.246
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.247 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.”248
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).249

245 42 U.S.C. §5174(b), 2001, https://www.govinfo.gov/content/pkg/USCODE-2001-title42/pdf/USCODE-2001-
title42-chap68-subchapIV-sec5174.pdf.
246 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.
247 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).
248 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).
249 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
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).
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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.250
Closing Considerations
FEMA may provide a variety of programs to meet the housing and other needs of disaster
survivors through the IHP. Congressional actions251 have helped codify these programs,252
increased potential funding for disaster survivors,253 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.254 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.

250 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.
251 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).
252 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).
253 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.
254 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).255 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.256
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.257 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.258 The factors are also used to identify the

255 DHS/FEMA, “Factors Considered When Evaluating a Request for IA”; 44 C.F.R. §206.48(b).
256 FEMA, IA Declarations Factors Guidance.
257 DHS/FEMA, “Factors Considered When Evaluating a Request for IA,” 84 Federal Register 10633; and 44 C.F.R.
§206.48(b).
258 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 2 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.259 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.260
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,261 and the circumstances that contributed to the state having insufficient resources,
potentially necessitating supplemental federal assistance.262 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):263 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.”264

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).
259 DHS/FEMA, “Factors Considered When Evaluating a Request for IA,” 84 Federal Register 10663; and 44 C.F.R.
§206.48(b).
260 44 C.F.R. §206.48(b).
261 FEMA considers the availability of local, state/territory/tribal government, nongovernmental organizations, and
private sector resources.
262 44 C.F.R. §206.48(b)(1).
263 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.
264 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.265
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.266 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.”267
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).268
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
evaluating269
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.
265 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.
266 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”).
267 FEMA, IA Declarations Factors Guidance, p. 8.
268 44 C.F.R. §206.48(b)(1)(i)(D); FEMA, IA Declarations Factors Guidance, p. 8.
269 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.270
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.271
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.272 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;273
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;274
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;275
4. Estimated Cost of Assistance: the estimated cost of assistance based on the PDA
data276 and historical data related to FEMA assistance, which helps determine the

270 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.
271 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.
272 44 C.F.R. §206.48(b)(2); FEMA, IA Declarations Factors Guidance, p. 9.
273 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.
274 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.
275 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).
276 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”;277
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;278
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;279 and
7. Other: other relevant PDA data submitted by the state that may demonstrate a
need for supplemental federal assistance for individuals.280
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.281 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;

277 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.
278 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).
279 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.
280 44 C.F.R. §206.48(b)(2)(vii); FEMA, IA Declarations Factors Guidance, p. 10.
281 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.”282
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.283 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;284
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;285 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.286
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).287
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

282 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.”
283 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.
284 44 C.F.R. §206.48(b)(4)(i); FEMA, IA Declarations Factors Guidance, p. 12.
285 44 C.F.R. §206.48(b)(4)(ii); FEMA, IA Declarations Factors Guidance, p. 12.
286 44 C.F.R. §206.48(b)(4)(iii); FEMA, IA Declarations Factors Guidance, p. 12.
287 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.288
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).289 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.290
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.291 When the pilot period concludes (no specific time has been set), FEMA
will develop regulations informed by the pilot.292
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.293
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:294
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 members295 and, if requested

288 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.
289 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).
290 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.
291 FEMA, Tribal Declarations Pilot Guidance.
292 FEMA, Tribal Declarations Pilot Guidance, p. 3.
293 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.
294 FEMA, Tribal Declarations Pilot Guidance, p. 34.
295 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 community296 by categorizing homes based on
damage and assessing the magnitude of the disaster and concentration of damages.297
Factor 2: Availability of Housing Resources
When FEMA evaluates the Availability of Housing Resources factor, FEMA considers the
availability of accessible temporary housing resources.298
Factor 3: Casualties
When FEMA evaluates the Casualties factor, FEMA considers disaster-caused “deaths or injuries
[including] of cultural, religious, and government leaders.”299
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).300
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).301
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.302
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.303

296 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).
297 FEMA, Tribal Declarations Pilot Guidance, p. 37.
298 FEMA, Tribal Declarations Pilot Guidance, p. 37.
299 FEMA, Tribal Declarations Pilot Guidance, p. 37.
300 FEMA, Tribal Declarations Pilot Guidance, p. 37.
301 FEMA, Tribal Declarations Pilot Guidance, p. 37.
302 FEMA, Tribal Declarations Pilot Guidance, p. 37.
303 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”;304 the disaster’s impact on the tribal government’s
economy or livelihood; and “[c]ultural or spiritual considerations.”305
Factor 9: Other Relevant Information
FEMA also considers Other Relevant Information provided by the tribal government.306
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.
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.

304 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.
305 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.
306 FEMA, Tribal Declarations Pilot Guidance, p. 38.
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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—non-enrol ed 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.
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.
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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.b
and Permanent Housing Construction.b)

FEMA coordinates with the State-Led
The state/territory/Indian tribal
Disaster Housing Task Force.c
government is expected to establish the
State-Led 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. 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
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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).
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.”307 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:308
• 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).309
Table C-1 includes a list of the data fields, with descriptions, associated with the provision of IHP
awards for each IA dataset.
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.
Individuals
Individuals
Individual
Registration
Housing
Housing
and
and
Assistance
Intake and
Assistance
Assistance
Households
Households
Housing
Individuals
Program
Program
Program
Program—
Registrants—
Household
Data—
Data—
(IHP) Flood
Valid
Large
Program
Data Fields
Owners
Renters
Damage
Registrations
Disasters
(RI-IHP)
Valid
✔
✔
—
—
—
✔
Registrationsa
Average
✔
—
—
—
—
—
FEMA
Inspected
Damageb

307 FEMA, “OpenFEMA Data Sets,” https://www.fema.gov/about/openfema/data-sets.
308 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.
309 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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Individuals
Individuals
Individual
Registration
Housing
Housing
and
and
Assistance
Intake and
Assistance
Assistance
Households
Households
Housing
Individuals
Program
Program
Program
Program—
Registrants—
Household
Data—
Data—
(IHP) Flood
Valid
Large
Program
Data Fields
Owners
Renters
Damage
Registrations
Disasters
(RI-IHP)
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
Flood
—
—
—
✔
—
—
Insurance
Premium
Amountp
Referralsq
—
—
—
✔
—
✔
SBA
—
—
—
✔
—
—
Approvedr
Flood
—
—
—
✔
—
—
Damage
Amounts
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Individuals
Individuals
Individual
Registration
Housing
Housing
and
and
Assistance
Intake and
Assistance
Assistance
Households
Households
Housing
Individuals
Program
Program
Program
Program—
Registrants—
Household
Data—
Data—
(IHP) Flood
Valid
Large
Program
Data Fields
Owners
Renters
Damage
Registrations
Disasters
(RI-IHP)
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.”
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
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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
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
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FEMA’s Individuals and Households Program (IHP)—Implementation and Considerations

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);
• 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
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• the registration method (e.g., telephone, mobile application) (IHP Valid
Registrations).310
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).311
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
• whether there is damage to the roof (IHP Valid Registrations and Housing
Registrants—Large Disasters).312
Finally, the Individuals and Households Program–Valid Registrations (IHP Valid Registrations)
and the Individual Assistance Housing Registrants–Large Disasters (Housing Registrants—Large

310 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.
311 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).
312 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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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).313

Author Information

Elizabeth M. Webster

Specialist in Emergency Management and Disaster
Recovery

Acknowledgments
Brion Long and Jamie Bush, CRS Visual Information Specialists, developed the figures for this
report.
Ben Harrington, former CRS Legislative Attorney; Katie Jones, Analyst in Housing Policy; Erica
A. Lee, Specialist 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.
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.

313 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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