Defining FEMA’s Approach to Equity and Emergency Management: Policy Considerations

October 14, 2022 R47280

Defining FEMA’s Approach to Equity and
October 14, 2022
Emergency Management: Policy
Erica A. Lee
Considerations
Analyst in Emergency
Management and Disaster
A range of emergency managers, scholars, and representatives at federal and subfederal
Recovery
governments in the United States have found that underserved communities often suffer

disproportionate impacts of disasters (such as exposure to extreme heat; incapacity to evacuate;
Elizabeth M. Webster
greater likelihood to suffer injury or death), yet have fewer resources to cope. Further, some
Analyst in Emergency
Members of Congress have expressed concern that federal disaster assistance does not adequately
Management and Disaster
reach these populations. Members of the House and Senate have introduced several bills that
Recovery
would expand FEMA’s authorities to improve assistance to underserved communities, and

several congressional committees have conducted hearings examining equity in the context of
emergency management.

Central to these concerns and actions is the question of how to define and interpret FEMA’s existing authorities with regard
to equity, including the application of federal civil rights law. The Robert T. Stafford Disaster Relief and Emergency
Assistance Act does not define equity, raising questions regarding what relevant actions FEMA is authorized or required to
undertake. By contrast, FEMA’s recently published definition of equity focuses on the fair, just, and impartial treatment of
individuals whom the agency serves. FEMA’s National Advisory Council, an advisory body of officials, emergency
managers, and emergency responders from subfederal governments, the private sector and nongovernmental organizations,
offers a different interpretation of equity, advising the agency to take action to improve equity in program outcomes.
FEMA has responded to such findings and concerns by undertaking a series of policy and procedure changes. These changes
include, but are not limited to, the following:
 Forming a Civil Rights Advisory Group to promote equity in FEMA-administered assistance for COVID-
19 vaccination efforts nationwide;
 Modifying documentation requirements found to impede access to Individual Assistance for some hazard-
affected individuals and households, particularly those in underserved communities;
 Focusing the agency’s 2022-2026 Strategic Plan around several goals related to equity, including
diversifying the FEMA workforce and promoting equity in assistance programs;
 Incorporating four FEMA grant programs in the Biden Administration’s Justice40 initiative, which aims to
deliver 40% of overall benefits of certain federal investments to disadvantaged communities; and
 Publishing a definition of equity and underserved communities intended to inform the above efforts and
future equity-focused initiatives.
The 117th Congress faces key questions regarding FEMA’s approach to and definition of equity in the administration of
federal disaster assistance. Policy issues include whether and how to further codify FEMA’s authorities with respect to the
promotion and assurance of equity in the administration of federal disaster assistance; how to monitor FEMA’s collection of
data to ensure the delivery of equitable disaster assistance; whether and how to respond to the varying capacity of subfederal
governments to pursue and administer federal relief; and whether and how to modify eligibility requirements that may result
in disparities in program access and outcomes.

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Defining FEMA’s Approach to Equity and Emergency Management: Policy Considerations

Introduction
Federal disaster relief may not adequately reach underserved individuals and communities in the
United States, according to recent academic research and U.S. government reports (see text box
for definition of “underserved”).1 Further, some experts find that the current design of federal
relief programs may exacerbate differences in the rate and extent of recovery among individuals
and communities depending on their wealth, income, race, ethnicity, gender, sexual orientation,
immigration status, age, and disability, among others.2
These findings build upon research of academics, government officials, and nonfederal
stakeholders showing how underserved communities may be disproportionately affected by
hazards.3 Individuals and communities with fewer financial and social resources often inhabit
places that are more physically vulnerable to hazards—for example, lowlands prone to flooding,
deteriorating or mobile homes, or remote, rural areas that are easily cut off from emergency
supplies and responders—resulting in greater risk and losses.4 Additionally, individuals and
communities with lower incomes and fewer resources are often less likely to have access to
financial resources (insurance, savings, or safety net through personal loans or gifts), to cover

1 See, for example, National Advisory Council (NAC), 2020 Report to the FEMA Administrator, November 2020, p. 6,
https://www.fema.gov/sites/default/files/documents/fema_nac-report_11-2020.pdf (hereinafter NAC, 2020 Report);
Government Accountability Office (GAO), Statement of Chris P. Currie, Director, Homeland Security and Justice,
Testimony Before the Committee on Homeland Security, House of Representatives, Disaster Recovery: Efforts to
Identify and Address Barriers to Receiving Federal Recovery Assistance, GAO-22-105488, October 27, 2021,
https://www.gao.gov/assets/gao-22-105488.pdf; and Oronde Drakes et al., “Social Vulnerability and Short-Term
Disaster Assistance in the United States,” International Journal of Disaster Risk Reduction, vol. 53 (February 2021).
For different findings, see Angel Griego et al., “Social Vulnerability, Disaster Assistance, and Recovery: A Population-
Based Study of Hurricane Harvey in Greater Houston, Texas,” International Journal of Disaster Risk Reduction, vol.
51 (December 2020).
2 See, for example, prepared Statement of Chauncia Willis, Co-Founder and CEO of the Institute for Diversity and
Inclusion in Emergency Management, U.S. Congress, House Committee on Homeland Security, Ensuring Equity in
Disaster Preparedness, Response, and Recovery, 117th Cong., 1st sess., October 27, 2021, H.Rept. 117-35, pp. 17-18
(hereinafter House Homeland, Ensuring Equity in Disaster Preparedness, Response, and Recovery); GAO, Disaster
Recovery: Additional Actions Needed to Identify and Address Potential Recovery Barriers, GAO-22-104039,
December 15, 2021, https://www.gao.gov/products/gao-22-104039; and Junia Howell and James Elliot, “Damages
Done: The Longitudinal Impacts of Natural Hazards on Wealth Inequality in the United States,” Social Problems, vol.
66, no. 3 (August 2019), pp. 448–467 (hereinafter Howell and Elliot, “Damages Done”).
3 See, for example, Kathleen Tierney, The Social Roots of Risk (Palo Alto: Stanford University Press, 2014)
(hereinafter Tierney, Social Roots of Risk); GAO, Disaster Recovery: School Districts in Socially Vulnerable
Communities Faced Heightened Challenges After Recent Natural Disasters, GAO-22-104606, January 2022,
https://www.gao.gov/assets/gao-22-104606.pdf; and Curtis Brown, submitted testimony, U.S. Congress, House
Appropriations Committee, The Role of FEMA & Emergency Management in the COVID-19 Response, 117th Cong., 1st
sess., March 16, 2021, pp. 11-12 (hereinafter Curtis Brown, Role of FEMA). For recent discussion among emergency
managers, see International Association of Emergency Managers, Diversity in Emergency Management: Lessons
Learned, special issue, June 2021, https://www.iaem.org/Portals/25/documents/2021/
IAEM_June%202021_Bulletin_FINAL_062521.pdf; and FEMA, “Social Vulnerability,” National Risk Index:
Technical Documentation, November 2021, pp. 4-1 through 4-2, https://hazards.fema.gov/nri/social-vulnerability.
4 See, for example, Tierney, Social Roots of Risk; Jeremy Hoffman et al., “The Effects of Historical Housing Policies
on Resident Exposure to Intra-Urban Heat: A Study of 108 US Urban Areas,” Climate, vol. 8, no. 1 (2020); Bryan
Boruff et al., “Erosion Hazard Vulnerability of US Coastal Counties,” Journal of Coastal Research, vol. 21, no. 5
(2005), pp. 932-942; and Alice Fothergill and Lori Peek, “Poverty and Disasters in the United States: A Review of
Recent Sociological Findings,” Natural Hazards, vol. 32 (2004), pp. 89-110 (hereinafter Fothergill and Peek, “Poverty
and Disasters”).
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Defining FEMA’s Approach to Equity and Emergency Management: Policy Considerations

disaster-caused losses, unexpected costs, and local cost-shares.5 In short, underserved
communities may suffer disproportionate impacts of disasters and have fewer resources to cope.
In the wake of such findings, the Federal Emergency Management Agency (FEMA) worked to
redress potential inequities in its delivery of federal disaster assistance. FEMA established new
work units to promote civil rights, modified agency policies that were found to result in
inequitable outcomes, and solicited policy proposals with the goal of improving access to disaster
relief programs. FEMA’s 2022-2026 Strategic Plan (hereinafter Strategic Plan) acknowledges
that some individuals and communities may struggle to understand and participate in FEMA’s
disaster assistance programs, and that FEMA must work with state, local, tribal, and territorial
(SLTT) partners and underserved communities to understand their unique challenges.6 FEMA
Administrator Deanne Criswell recently affirmed that “FEMA pursues a comprehensive approach
to advancing equity as a critical and foundational part of our mission.”7
Some Members of Congress and other stakeholders continue to raise concerns that federal
disaster assistance may not assist survivors equitably. Areas of recent congressional interest
include whether existing federal disaster assistance authorities appropriately consider underserved
communities, and how to delimit FEMA’s authority to enhance program access and promote
equitable outcomes in disaster assistance. In the 117th Congress, some Members of the Senate and
House introduced several bills that would expand FEMA’s authorities to improve assistance to
underserved communities.8 Congressional committees have also conducted hearings examining
equity in the context of emergency management.9
What Is Equity?
The concept of equity generally relates to fairness. In U.S. law, this concept is exemplified in
requirements for impartial treatment that are established in statute, regulations, and Executive

5 See for example, Carolyn Kousky and Roger Cooke, “Explaining the Failure to Insure Catastrophic Risks,” The
Geneva Papers 37, (2012); Lloyd Dixon et al., “The Cost and Affordability of Flood Insurance in New York City:
Economic Impacts of Rising Premiums and Policy Options for One- to Four-Family Homes,” RAND Corporation,
2017; GAO, Puerto Rico Recovery: FEMA Made Progress in Approving Projects but Should Identify and Assess Risks
to the Recovery, GAO-21-264, pp. 33-35, https://www.gao.gov/products/gao-21-264; Fothergill and Peek, “Poverty and
Disasters”; National Research Council, Increasing National Resilience to Hazards and Disasters: The Perspective from
the Gulf Coast of Louisiana and Mississippi: Summary of a Workshop, Washington: National Academies Press, 2011.
6 FEMA, 2022-2026 Strategic Plan, December 2021, pp. 11-12; (hereinafter FEMA, Strategic Plan),
https://www.fema.gov/about/strategic-plan. See also FEMA, “FEMA Administrator Deanne Criswell Delivers Speech
at National Hurricane Conference,” release, April 13, 2022, https://www.fema.gov/fact-sheet/fema-administrator-
deanne-criswell-delivers-speech-national-hurricane-conference (hereinafter FEMA, “Administrator Criswell Speech at
National Hurricane Conference”).
7 Memorandum from Federal Emergency Management Agency (FEMA) Administrator Deanne Criswell to the
National Advisory Council Chairman W. Nim Kidd, October 15, 2021, https://www.fema.gov/sites/default/files/
documents/fema_response-2020-nac-report.pdf.
8 Examples include S. 4159/H.R. 7688—FEMA Equity Act; S. 3093/H.R. 5780—Disaster Equity and Fairness Act; S.
2471/H.R. 4707—Reforming Disaster Recovery Act; S. 2362—Fairness in Federal Disaster Declarations Act of 2021;
and S. 3128/H.R. 5802—National Flood Insurance Program Reauthorization and Reform Act of 2021.
9 See, for examples, House Homeland, Ensuring Equity in Disaster Preparedness, Response, and Recovery; U.S.
Congress, Senate Committee on Homeland Security and Governmental Affairs, Examining FEMA’s Strategic Priorities
and Disaster Preparedness, 117th Cong., 2nd sess., June 22, 2022, https://www.hsgac.senate.gov/imo/media/doc/
Opening%20Statement-Peters-2022-06-22.pdf; and U.S. Congress, House Committee on Transportation and
Infrastructure, Subcommittee on Economic Development, Public Buildings, and Emergency Management, FEMA
Priorities for 2022 and the 2022-2026 Strategic Plan, 117th Cong., 2nd sess., April 5, 2022,
https://congressional.proquest.com/congressional/docview/t39.d40.tr04050122.o14?accountid=12084.
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Orders.10 However, stakeholders and scholars may retain quite different understandings of what
equity means when it comes to the provision of federal assistance—like that authorized under the
Robert T. Stafford Disaster Relief and Emergency Assistance Act (The Stafford Act, P.L. 93-288;
42 U.S.C. §§5121 et seq.).
Some policymakers and government officials focus on equity as measured by treatment of
individuals in different stages of a program—e.g., access, evaluation, distribution. They question,
for example, whether administrators treat each applicant impartially, ensure fair access, assess
eligibility without discrimination, and administer assistance in the same manner.11 One discrete
measure of equity in this context could be the provision of application materials in all languages
relevant to an affected community.
Others might measure equity through program outcomes. Among the relevant questions could be
whether policies and programs exacerbate existing inequities among different applicants—for
example, awarding greater sums to wealthier survivors, or to homeowners over comparably
lower-income renters. Or, by contrast, do (and should) relief programs reduce pre-existing social
disparities among program participants (particularly if those disparities contribute to their
vulnerability to hazards)?12
These conceptions of equity are not exhaustive, but are common in discussions among emergency
managements and disaster relief stakeholders, as detailed below.
This report discusses FEMA’s existing authorities relevant to equity, operating definitions of
equity in the context of emergency management, recent FEMA actions concerning equity, and
related congressional considerations. Further, this report serves as a foundation for other products
related to equity and emergency management, including CRS Report R47244, FEMA’s Approach
to Equity and Emergency Management: Disaster Declarations and Policy Considerations.
Terms
Underserved Communities: Different stakeholders use a range of terms to refer to groups that encounter
barriers to accessing disaster assistance, experience discrimination, and/or face disproportionate risks from
hazards.13 This report uses the term “underserved communities” to align with FEMA’s use,14 defined as
“populations sharing a particular characteristic, as well as geographic communities, that have been systematically
denied a ful opportunity to participate in aspects of economic, social, and civic life.”15 Examples include

10 See, for example, the nondiscrimination provisions in Section 308 of the Stafford Act; 42 U.S.C. §§6101 et seq.; 42
U.S.C. §§12101-12213; 42 U.S.C. §§2000d et seq.; 29 U.S.C. §794; Executive Order 14020, “Establishment of the
White House Gender Policy Council” (see Section 6); and Executive Order 13985, “Advancing Racial Equity and
Support for Underserved Communities Through the Federal Government.”
11 See discussion of procedural equity, access, and quality in Susan T. Gooden, “From Equality to Social Equity,”
Public Administration Evolving, 1st ed., Mary Guy and Marilyn Rubin, eds., New York: Routledge, 2015.
12 See discussion in Oronde Drakes et al., “Social Vulnerability and Short-Term Disaster Assistance in the United
States,” International Journal of Disaster Risk Reduction, vol. 53 (February 2021).
13 See, for example, “low-capacity community” in FEMA, Summary of Stakeholder Feedback: Building Resilient
Infrastructure and Communities, March 2020, pp. 24-25, 36, https://www.fema.gov/sites/default/files/2020-06/
fema_bric-summary-of-stakeholder-feedback-report.pdf; “populations of concern” in Gamble, J.L. et al., Populations
of Concern. The Impacts of Climate Change on Human Health in the United States: A Scientific Assessment (U.S.
Global Change Research Program, Washington, DC, 2016), pp. 247-286 (chapter 9), http://dx.doi.org/10.7930/
J0Q81B0T.
14 See FEMA, Glossary, “Underserved Populations/Communities”; see also FEMA, Strategic Plan.
15 Section 2, definitions, in President Joseph R. Biden Jr., Executive Order 13985, “Advancing Racial Equity and
Support for Underserved Communities Through the Federal Government,” 86 Federal Register 7009, January 25,
2021, govinfo.gov/content/pkg/FR-2021-01-25/pdf/2021-01753.pdf (hereinafter Executive Order 13985).
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communities of individuals that have been “denied consistent and systematic fair, just, and impartial treatment,”
including “Black, Latino, and Indigenous and Native American persons, Asian Americans and Pacific Islanders and
other persons of color; members of religious minorities; lesbian, gay, bisexual, transgender, and queer (LGBTQ+)
persons; persons with disabilities; persons who live in rural areas; and persons otherwise adversely affected by
persistent poverty or inequality.”16
Social Vulnerability: This report adopts FEMA’s definition of social vulnerability in the context of emergency
management, meaning “the susceptibility of social groups to the adverse impacts of natural hazards, including
disproportionate death, injury, loss, or disruption of livelihood.”17 Per the U.S. Centers for Disease Control and
Prevention (CDC), higher levels of social vulnerability (including poverty, limited English proficiency, disability, and
minority status) within a disaster-affected community may correspond to fewer resources available to reduce and
mitigate suffering and loss, and for this reason, warrant federal or other assistance.18
Equity: Neither the Stafford Act nor FEMA’s regulations define equity. In fall 2021, FEMA defined equity as “[t]he
consistent and systematic fair, just and impartial treatment of all individuals.”19
State: For purposes of the Stafford Act and this report, “‘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)).
Tribe: The term “tribe” refers to Indian tribal governments. Per the Stafford Act, “[t]he 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” (42 U.S.C. §5122(6)).
Chief Executive: Generally, Stafford Act assistance is requested by the “governor” (i.e., “the chief executive of
any State” (42 U.S.C. §5122(5)), or the “chief executive” (i.e., “the person who is the Chief, Chairman, Governor,
President, or similar executive official of an Indian tribal government” (42 U.S.C. §5122(12)).
Equity in FEMA’s Existing Federal Authorities
Statute and Regulations
The Stafford Act aims to alleviate “the suffering and damage which result from ... disasters,”
given congressional findings that disasters severely affect communities, governments,
individuals, and families.20 The statute’s findings do not address the potentially disproportionate
effects of hazards on underserved communities, as explained by a range of government and
scholarly research.21 Furthermore, Stafford Act authorities generally do not specifically target
assistance to underserved communities.22 Finally, FEMA’s ability to develop race- or sex-
conscious programs for the benefit of certain minorities may be limited by the constitutional

16 Section 2, Executive Order 13985.
17 FEMA, National Risk Index: Primer, November 2020, https://www.fema.gov/sites/default/files/2020-11/
fema_national-risk-index_primer.pdf.
18 U.S. Centers for Disease Control and Prevention (CDC), “CDC SVI Documentation 2018,” CDC SVI 2018
Documentation—1/31/2020, January 31, 2020, https://www.atsdr.cdc.gov/placeandhealth/svi/documentation/
SVI_documentation_2018.html (hereinafter CDC, SVI 2018) (see for information on the CDC Social Vulnerability
Index).
19 CDC, SVI 2018.
20 42 U.S.C. §5121(b).
21 See sources in footnote 3.
22 One exception, noted above, is Pre-Disaster Mitigation, which provides a higher federal cost share for “small,
impoverished communities” than it does for others. Section 102(a) of the Disaster Mitigation Act of 2000 (P.L. 106-
390), as it amends Stafford Act Section 203(a), 42 U.S.C §5133(a).
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requirement that the government afford all individuals equal protection under the law.23 All of
these factors may constrain FEMA’s ability to address inequities observed in disaster relief access
and program outcomes.
FEMA must comply with several statutory authorities related to equity. As a federal entity, FEMA
is prohibited from intentionally discriminating on the basis of race.24 FEMA is required to comply
with federal civil rights laws, such as Title VI of the Civil Rights Act of 1964 (42 U.S.C. §2000d),
and Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. §794). Under these laws, FEMA
may not discriminate on the basis of different categories (e.g., nationality, age) when delivering
federal assistance, and must ensure that individuals with disabilities may participate in FEMA’s
programs. A declaration of emergency or major disaster under the Robert T. Stafford Disaster
Relief and Emergency Assistance Act (Stafford Act, P.L. 93-288, as amended; 42 U.S.C. §§5121
et seq.) does not waive federal civil rights laws and legal authorities—all of which remain in
effect.25
Both the Stafford Act and FEMA’s regulations prohibit discrimination in the provision of disaster
assistance.26 The Stafford Act’s nondiscrimination provision requires FEMA and other
organizations to perform disaster relief operations and provide assistance in an “equitable and
impartial manner, without discrimination on the grounds of race, color, religion, nationality, sex,
age, disability, English proficiency, or economic status.”27 Additionally, federal regulations
require that governments receiving FEMA assistance collect data necessary to demonstrate
compliance with this requirement as well as other civil rights laws.28 FEMA’s statutory and
regulatory authorities relevant to equity are listed chronologically in Table 1.
Table 1. Equity and FEMA Authorities—Chronology
Statute/Regulation
Description
Title 32A of C.F.R. published Regulations prohibiting discrimination on the ground of race, color, or national
January 9, 1965
origin, under any program or activity receiving federal financial assistance from the
Office of Emergency Planning (a FEMA predecessor) were published to effectuate
the provisions of Title VI of the Civil Rights Act of 1964.29

23 See discussion of race-conscious programming and policies in CRS Legal Sidebar LSB10631, The American Rescue
Plan Act: Equal Protection Challenges, by Christine J. Back and April J. Anderson; and CRS Report R45481,
“Affirmative Action” and Equal Protection in Higher Education, by Christine J. Back.
24 See relevant discussion in CRS Legal Sidebar LSB10737, Equal Protection Does Not Mean Equal SSI Benefits for
Puerto Rico Residents, Says Supreme Court, by Mainon A. Schwartz.
25 See also FEMA, “Office of Equal Rights, External Civil Rights Division,” https://www.fema.gov/about/offices/
equal-rights.
26 42 U.S.C. §5151; see also 44 C.F.R. §206.11(b).
27 42 U.S.C. §5151; see also 44 C.F.R. §206.11(b). Other applicable authorities include 44 C.F.R. Part 7—
Nondiscrimination in Federally-Assisted Programs; and 44 C.F.R. §206.11—Nondiscrimination in Disaster Assistance.
See U.S. Departments of Justice, Homeland Security (DHS), Housing and Urban Development, Health and Human
Services, and Transportation, “Guidance to State and Local Governments and Other Federally Assisted Recipients
Engaged in Emergency Preparedness, Response, Mitigation, and Recovery Activities on Compliance with Title VI of
the Civil Rights Act of 1964,” January 9, 2020, https://www.dhs.gov/publication/guidance-state-and-local-
governments-and-other-federally-assisted-recipients-engaged (hereinafter DHS, “Guidance to State and Local
Governments on Compliance with Title VI of the Civil Rights Act of 1964”).
28 44 C.F.R. §7.10(b); DHS, “Guidance to State and Local Governments on Compliance with Title VI of the Civil
Rights Act of 1964.”
29 Section 1, Title 32A, Chapter 1—Office of Emergency Planning, 30 Federal Register 321-324, January 9, 1965,
https://archives.federalregister.gov/issue_slice/1965/1/9/314-324.pdf. Section 1 of Title 32A stated, “no person in the
United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the
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Statute/Regulation
Description
P.L. 93-288, enacted May 22, Section 311(a) of the Disaster Relief Act of 1974 required the President to issue
1974
regulations to ensure that personnel, governments, and organizations provide
federal assistance “in an equitable and impartial manner, without discrimination on
the grounds of race, color, religion, nationality, sex, age, or economic status.”30
FEMA established, March 13, President Jimmy Carter created the Federal Emergency Management Agency
1979
(FEMA) in 1979 in Executive Order 12127, and subsequently delegated most
response and recovery authorities authorized in the Disaster Relief Act of 1974 to
the agency.31 Subsequently, FEMA updated existing regulations on
nondiscrimination in federal disaster assistance.
P.L. 100-707, enacted
The Disaster Relief and Emergency Assistance Amendments of 1988 amended the
November 23, 1988
Disaster Relief Act of 1974, retitling it “The Robert T. Stafford Disaster Relief and
Emergency Assistance Act,” and retaining prior statutory language on
nondiscrimination in the provision of federal disaster assistance.
P.L. 106-390, enacted
The Disaster Mitigation Act of 2000 authorized pre-disaster mitigation assistance
October 30, 2000
and a higher federal cost share for “small, impoverished communities.”32
Title VI of P.L. 109-295,
The Post-Katrina Emergency Management Reform Act of 2006 (PKEMRA) created
enacted October 4, 2006
the position of Disability Coordinator in FEMA to “ensure that the needs of
individuals with disabilities are being properly addressed in emergency
preparedness and disaster relief.”33 Additionally, PKEMRA amended the Stafford
Act to specify that federal assistance must be provided without discrimination on
the basis of disability or English proficiency.34
Division B of P.L. 113-2,
The Sandy Recovery Improvement Act of 2013 (SRIA) amended the Stafford Act
enacted January 29, 2013
to allow federally recognized tribes to request an emergency or major disaster
declaration directly (rather than through a state request), and required FEMA to
issue regulations implementing this authority with consideration of “the unique
conditions that affect the general welfare of tribal governments.”35 Some tribal
governments and members, Members of Congress, FEMA, and other stakeholders

benefits of, or be otherwise subjected to discrimination under any program or activity receiving Federal financial
assistance from the Office of Emergency Planning.” Subsequently, per FEMA’s final rule, “The regulations of the
former FPA [Federal Preparedness Agency] appear in Title 32A. This rule removes certain obsolete regulations from
the Code, transfers the remaining regulations in title 32A CFR to Title 44, and makes changes for outdated
nomenclature, statutory provisions and references and organization,” effective July 1, 1980. This followed the
establishment of FEMA by Executive Order 12127 of March 31, 1979. See FEMA, Final Rule, “Transfer,
Redesignation, Removal, and Revisions of Regulations,” 45 Federal Register 44575, July 1, 1980,
https://archives.federalregister.gov/issue_slice/1980/7/1/44522-44777.pdf.
30 Section 311(a) of the Disaster Relief Act of 1974 (P.L. 93-288), amended as Stafford Act Section 308; 42 U.S.C.
§5151. Other applicable authorities include Title VI of the Civil Rights Act of 1964; Section 504 of the Rehabilitation
Act of 1973; 44 C.F.R. Part 7—Nondiscrimination in Federally-Assisted Programs; and 44 C.F.R. §206.11—
Nondiscrimination in Disaster Assistance. See DHS, “Guidance to State and Local Governments on Compliance with
Title VI of the Civil Rights Act of 1964.”
31 Executive Order 12127, “Federal Emergency Management Agency,” 44 Federal Register 19367-19368, April 3,
1979, https://archives.federalregister.gov/issue_slice/1979/4/3/19367-19368.pdf. See also FEMA, “History of FEMA,”
https://www.fema.gov/about/history.
32 Section 102(a) of the Disaster Mitigation Act of 2000 (P.L. 106-390), as it amends Stafford Act Section 203(a); 42
U.S.C §5133(a).
33 Section 611 of the Post-Katrina Emergency Management Reform Act of 2006 (PKEMRA, Title VI of P.L. 109-295)
amended Title V of the Homeland Security Act of 2002 (6 U.S.C. §§311 et seq.), including by establishing the
Disability Coordinator position in Section 513; 6 U.S.C. §321b.
34 Section 689a of PKEMRA; 42 U.S.C. §5151(a).
35 Section 1110 of the Sandy Recovery Improvement Act of 2013 (SRIA, Division B of P.L. 113-2); 42 U.S.C.
§§5170(b) and (c), and §5122(6).
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Statute/Regulation
Description
explained that this authority was necessary to recognize tribal independence and
sovereignty.36
Division D of P.L. 115-254,
The Disaster Recovery Reform Act of 2018 (DRRA) authorized the President
enacted October 5, 2018
(through FEMA) to waive certain restrictions prohibiting the provision of
duplicative assistance, and authorized the FEMA Administrator to waive the
recoupment of assistance provided through the Individuals and Households
Program if doing so would be against “equity and good conscience,” among other
considerations.37 This provision fol owed congressional concern and related
legislative actions that recouping disaster relief from individuals—particularly low-
income individuals—constituted an “unfair financial hardship.”38
Source: Compiled by CRS.
FEMA Policies
FEMA has implemented federal statutes and regulations on equity, civil rights, and
nondiscrimination through a number of means, including but not limited to those listed below (for
recent actions, see “Recent FEMA Equity-Related Actions”).
 FEMA established the External Civil Rights Division within the Office of Equal
Rights, which is responsible for compliance with and enforcement of federal civil
rights authorities, including the nondiscrimination requirement in the Stafford
Act, for public-facing programs.39
 FEMA appointed a disability coordinator in 2007, as required by the Post-Katrina
Emergency Management Reform Act of 2006 (Title IV of P.L. 109-295), and in
2010, FEMA created the Office of Disability Integration and Coordination to
support the work of the disability coordinator.40

36 FEMA, Tribal Declarations Pilot Guidance, January 2017, p. 4, https://www.fema.gov/sites/default/files/2020-04/
tribal-declaration-pilot-guidance.pdf (states, “The Stafford Act now reflects that tribal governments are sovereign and
acknowledges the government-to-government relationship between the United States and tribal governments.”); Heidi
Adams, “Sovereignty, Safety, and Sandy: Tribal Governments Gain (Some) Equal Standing Under the Hurricane Sandy
Relief Act,” American Indian Law Journal, vol. 2, no. 1 (Spring 2013), pp. 376-387; Heidi Adams, “Sovereignty,
Safety, and Security: Tribal Governments Under the Stafford and Homeland Security Acts,” American Indian Law
Journal, vol. 1, no. 1 (Fall 2012), pp. 127-146; Rep. Rahall, Debate on the Sandy Recovery Improvement Act of 2013,
Congressional Record, daily edition, vol. 159 (January 14, 2013), p. H72; Courtney Stouff, “Native Americans and
Homeland Security: Failure of the Homeland Security Act to Recognize Tribal Sovereignty,” Penn State Law Review,
vol. 103 (2003-2004), pp. 375-394; and Senators Begich and Tester, Letter for FEMA Administrator Craig Fugate,
March 4, 2014, https://www.indian.senate.gov/news/press-release/tester-and-begich-call-faster-action-tribal-disaster-
recovery-provision-0.
37 Sections 1210 and 1216(a) of the Disaster Recovery Reform Act of 2018 (DRRA, Division D of P.L. 115-254). The
DRRA Section 1216(a) waiver authority was similar to the waiver authority granted for survivors of disasters declared
on August 28, 2005, through December 31, 2010, pursuant to Section 565 of the Disaster Assistance Recoupment
Fairness Act of 2011 (Division D, Title V of P.L. 112-74) (for background, see Rep. Pryor, “Statements on Introduced
Bills and Joint Resolutions,” Congressional Record, vol. 157 (April 12, 2011), pp. S2394-2395).
38 Senate Committee on Homeland Security and Governmental Affairs website, “Pryor, Landrieu, and Cochran
Announce FEMA Recoupment Plan,” February 9, 2012, https://www.hsgac.senate.gov/subcommittees/disaster-
recovery-and-intergovernmental-affairs/majority-media/pryor-landrieu-and-cochran-announce-fema-recoupment-plan.
39 FEMA, “External Civil Rights Division,” fema.gov/about/offices/equal-rights/civil-rights.
40 FEMA, “Office of Disability Integration and Coordination,” https://www.fema.gov/about/offices/disability.
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 FEMA provides accessible—and in some cases, multi-lingual—communication
in certain FEMA guidance documents and public-facing virtual and in-person
meetings.41
 FEMA established tribal consultation policy pursuant to Executive Order 13175
for “communicating and collaborating with tribal governments to exchange
information, receive input, and consider the views of tribes on actions that have
tribal implications.”42
 FEMA has also developed policies and priorities that incorporate equity-based
components in accordance with statutory authorities. For example, FEMA may
waive the requirement to recoup assistance provided through the Individuals and
Households Program (IHP) if enforcement of the debt would be against “equity
and good conscience.”43 FEMA’s instruction for implementing this authority
includes examples of qualifying circumstances and explains “[t]he legal
obligation to pay a debt to FEMA may be overcome by other consideration if
enforcement of the debt would be unfair to the point of violating equity and good
conscience.”44
Congressional Considerations
Defining Equity: The Stafford Act and FEMA’s Authorities
There is not a single, unified concept of equity in the context of disaster assistance authorities and
programs. As described above, the Stafford Act does not define equity, nor do FEMA’s
regulations. In fall 2021, however, the agency offered a definition of equity: “[t]he consistent and
systematic fair, just and impartial treatment of all individuals.”45 This definition governs how
FEMA approaches reported barriers faced by underserved populations to “ensure all survivors
have access to disaster assistance.”46
Other stakeholders have offered meaningfully distinct definitions of equity in the context of
federal disaster assistance. Among these divergent definitions was one authored by FEMA’s
National Advisory Council (NAC), a statutorily authorized advisory body of subfederal officials,
emergency response providers, and related nonprofit and private sector representatives that serves
at the pleasure of the Administrator.47 In November 2020—ten months before FEMA issued its

41 FEMA, “Accessibility Statement,” https://www.fema.gov/about/offices/equal-rights/accessibility.
42 Executive Order 13175, “Consultation and Coordination with Indian Tribal Governments,” 65 Federal Register
67249-67252, November 9, 2000, https://www.govinfo.gov/content/pkg/FR-2000-11-09/pdf/00-29003.pdf; FEMA,
“Tribal Consultations,” https://www.fema.gov/about/tribes/consultations.
43 42 U.S.C. §5174a(a)(2)(iii). For additional information on Individuals and Households Program (IHP) debt
recoupment waivers, see the “Section 1216: Flexibility” section of 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.
44 FEMA, “Instruction 116-1-2: Individuals and Households Program Recoupment,” vol. 2, May 2019, pp. 16-17, 30.
45 FEMA, “FEMA Defines Equity in Its Mission of Making Programs More Accessible,” HQ-21-208, September 9,
2021, https://www.fema.gov/press-release/20210909/fema-defines-equity-its-mission-making-programs-more-
accessible (hereinafter FEMA, “FEMA Defines Equity”).
46 FEMA, “FEMA Defines Equity.”
47 Section 508 of PKEMRA (P.L. 109-295) authorized the NAC to advise—without enforcement authorities—the
FEMA administrator “on all aspects of emergency management.”
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equity definition—the NAC offered a different definition to encourage the agency to incorporate
equity in its relief programs: “The core definition of equity is to provide the greatest support to
those with greatest need to achieve a certain minimum outcome.”48 The NAC explicitly
distinguished this from equality, defined as “providing the same resources to everyone regardless
of need.”49 As noted above, the U.S. Constitution and several statutes prevent FEMA from
discriminating against individuals on the basis of race, national origin, sex, and other classes.
Considerations for Congress—Defining Equity
Some stakeholders, including FEMA’s National Advisory Council, argue that the Stafford Act’s
nondiscrimination provisions require FEMA to improve program equity, such as by reducing
barriers to accessing aid and promoting equitable outcomes.50 One recent legal analysis, for
example, argues the Stafford Act’s requirement that FEMA deliver assistance without
discrimination requires FEMA to ensure disaster relief programs do not exacerbate preexisting
inequities.51 FEMA’s NAC additionally asserted that the provision of federal assistance to
wealthier communities that do not need the assistance undermines the core tenets of the Stafford
Act to provide federal assistance only when necessary:52
first responders do not rescue people who can evacuate themselves, they only rescue people
who need help. Recovery programs, however, seem to do just that. They provide an
additional boost to wealthy homeowners and others with less need, while lower-income
individuals and others sink further into poverty after disasters.53
Consistent with these ideas, the first goal of FEMA’s Strategic Plan is to “instill equity as a
foundation of emergency management.” To that end, FEMA Administrator Deanne Criswell’s
foreword to the Strategic Plan states:
Systems that foster inequality serve no one, especially in times of crisis. We must recognize
that disasters affect individuals and communities differently, commit ourselves to reducing
barriers to access, and deliver equitable outcomes for all whom we serve.54
Yet the Strategic Plan concedes FEMA is limited in what it—as an agency—can provide in terms
of federal assistance, acknowledging that “FEMA assistance is not designed to solve societal
inequities.”55 FEMA Assistant Administrator for Recovery Keith Turi previously acknowledged

48 NAC, 2020 Report, p. 11.
49 NAC, 2020 Report, p. 11.
50 NAC, 2020 Report, pp. 11-12; Thomas Frank, “How FEMA Helps White and Rich Americans Escape Floods,”
Politico’s E&E News, May 25, 2022, https://www.politico.com/news/2022/05/27/unfair-fema-climate-program-floods-
00032080; Thomas Frank, “FEMA Home Elevation Funds Could Violate Civil Rights Law,” ClimateWire E&E News,
June 15, 2022, https://www.eenews.net/articles/fema-home-elevation-funds-could-violate-civil-rights-law/.
51 Hannah Perls and Dane Underwood, “Equitable Disaster Relief: An Analysis of FEMA’s Legal Authority to
Integrate Equity Under the Stafford Act,” Harvard Environmental and Energy Law Program, October 13, 2021,
https://eelp.law.harvard.edu/2021/10/equitable-disaster-relief/. See also Comment submitted by Texas Housers, FEMA,
“Request for Information on FEMA Programs, Regulations, and Policies; Public Meetings; Extension of Comment
Period,” FEMA-2021-0011-0277, p. 5.
52 Per 42 U.S.C. §§5170(a) and (b)(1), and 5191(a) and (c)(1), a governor or tribal chief executive shall submit a
request for a Stafford Act major disaster or emergency declaration “based on a finding that the [disaster/situation] is of
such severity and magnitude that effective response is beyond the capabilities of the State and the affected local
governments and that Federal assistance is necessary.”
53 NAC, 2020 Report, p. 6.
54 Letter from the Administrator in FEMA’s Strategic Plan, p. 3.
55 FEMA, Strategic Plan, pp. 9, 13.
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the different understandings of equitable relief: “Our programs have been built on providing
equal treatment to survivors, but that’s not necessarily equal outcome.”56
Must FEMA ensure simply fair and equitable treatment of survivors, or work to promote
equitable outcomes in its programs? Congress could determine that the Stafford Act is not
designed as a tool to promote or guarantee equity, particularly equitable outcomes, and decide to
retain existing authorities. Alternatively, Congress could decide to clarify disparate interpretations
of the Stafford Act’s requirements and ideas about equitable assistance. Congress could consider
whether there is a need to amend the Stafford Act to define equity in the context of Stafford Act
assistance, potentially drawing upon definitions based on fairness, minimum outcomes, or access,
as outlined by FEMA and FEMA’s NAC. Alternatively, Congress could craft an equity definition,
or require FEMA to undertake rulemaking to promulgate FEMA’s operational definition that
currently exists in policy. Congress could also decide to leave in place FEMA’s current
interpretation to preserve agency flexibility, or to clarify and limit FEMA’s authorities to
undertake such action. Should Congress do so, Congress could consider the sufficiency of
FEMA’s existing authorities to ensure equity in FEMA’s pre- and post-disaster assistance
programs.
Recent FEMA Equity-Related Actions
FEMA has undertaken a series of recent actions with the goal of promoting equity in its
operations and grant programs (see Table 2 for a list of recent FEMA equity initiatives). FEMA,
its state, local, tribal, and territorial (SLTT) partners, and stakeholders have long designed policy
to recognize that some disaster survivors may have unique needs that must be considered (e.g.,
individuals with disabilities and others with access and functional needs).57 FEMA’s more recent
equity initiatives arguably broadened and centralized existing efforts to recognize the distinct
needs of diverse survivor populations.
Table 2. Selected Recent FEMA Equity-Focused Actions and Policies
Date
Summary of Action or Policy
August 2016
DHS, of which FEMA is a component, issued guidance in concert with the
Departments of Justice, Health and Human Services, Housing and Urban
Development, and Transportation to federal grantees and subfederal governments
on compliance with Title VI of the Civil Rights Act of 1964 during emergency
preparedness, response, and recovery efforts.58 FEMA established a civil rights
section of the agency website.
April 2020
FEMA released guidance on the enforcement of civil rights requirements in the
delivery of Stafford Act assistance for the COVID-19 pandemic.59

56 Quoted in Rebecca Hersher and Ryan Kellman, “Why Fema Aid Is Unavailable to Many Who Need It the Most,”
NPR Science, June 29, 2021, https://www.npr.org/2021/06/29/1004347023/why-fema-aid-is-unavailable-to-many-who-
need-it-the-most.
57 FEMA, Developing and Maintaining Emergency Operations Plans: Comprehensive Preparedness Guide (CPG) 101,
Version 3.0, September 2021, pp. 5-6, https://www.fema.gov/sites/default/files/documents/fema_cpg-101-v3-
developing-maintaining-eops.pdf.
58 U.S. Department of Justice, “Federal Agencies Issue Joint Guidance to Help Emergency Preparedness, Response and
Recovery Providers Comply with Title VI of the Civil Rights Act,” August 16, 2016, https://www.justice.gov/opa/pr/
federal-agencies-issue-joint-guidance-help-emergency-preparedness-response-and-recovery; DHS, “Guidance to State
and Local Governments on Compliance with Title VI of the Civil Rights Act of 1964.”
59 FEMA, “Ensuring Civil Rights During the COVID-19 Response,” April 9, 2020, https://www.fema.gov/sites/default/
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Date
Summary of Action or Policy
February 2021
FEMA established the Civil Rights Advisory Group to promote equitable vaccine
policies in distribution of Stafford Act assistance and in the operations of
grantees.60
April 2021
FEMA issued a Request for Information (RFI) seeking information from the public
on how the agency’s programs, regulations, and policies could “better advance the
goals of equity for all, environmental justice, and bolster resilience to the impacts
of climate change.”61
July 2021
FEMA forms the Equity Enterprise Steering Group composed of members of
different FEMA work units to focus on “assessing issues like access and delivery of
FEMA programs, services, and activities.”62
September 2021
FEMA released a memorandum amending FEMA’s Individual Assistance program
guidance in accordance with the Biden Administration and FEMA’s equity
initiatives “to Advance Equity for Disaster Survivors.”63 Modifications include
expanding the forms of accepted documentation to verify an applicant’s occupancy
and ownership, which is required before FEMA can provide certain types of
assistance through the Individuals and Households Program (IHP). Policy changes
make IHP assistance available, including to applicants with properties passed down
via heirship, as well as people who own mobile homes or travel trailers.64 These
documentation restrictions previously disproportionately affected low-income,
Black applicants, according to FEMA and news sources.65
September 2021
FEMA publishes a definition of equity with reference to Executive Order 13985,
Advancing Racial Equity and Support for Underserved Communities Through the
Federal Government.66

files/2020-07/fema_ensuring-civil-rights-during-covid-19-response.pdf.
60 FEMA, “FEMA Takes Action to Ensure Equity in Vaccine Distribution,” February 9, 2021, https://www.fema.gov/
blog/fema-takes-action-ensure-equity-vaccine-distribution; FEMA, “FEMA Ensures Equitable Distribution of COVID-
19 Vaccines,” HQ-21-060, March 9, 2021, https://www.fema.gov/press-release/20210309/fema-ensures-equitable-
distribution-covid-19-vaccines; DHS Office of Inspector General, “FEMA Made Efforts to Address Inequities in
Disadvantaged Communities Related to COVID-19 Community Vaccination Center Locations and Also Plans to
Address Inequity in Future Operations,” September 28, 2022, OIG-22-74.
61 DHS/FEMA, “Request for Information on FEMA Programs, Regulations, and Policies,” 86 Federal Register 21325-
21328, April 22, 2021.
62 FEMA, “FEMA Announces Initial Initiatives to Advance Equity,” July 21, 2021, https://www.fema.gov/press-
release/20210721/fema-announces-initial-initiatives-advance-equity.
63 Memorandum from Keith Turi, Assistant Administrator of the FEMA Recovery Directorate, to FEMA Regional
Administrators, “Amendment to FP 104-009-03, Individual Assistance Program and Policy Guide, Version 1.1,”
September 2, 2021, https://www.fema.gov/sites/default/files/documents/fema_iappg-policy-amendments-memo.pdf
(hereinafter, “Memorandum from Keith Turi”); FEMA, “FEMA Makes Changes to Individual Assistance Policies to
Advance Equity for Disaster Survivors,” HQ-21-193, September 2, 2021, https://www.fema.gov/press-release/
20210902/fema-makes-changes-individual-assistance-policies-advance-equity-disaster (hereinafter FEMA, “Changes
to IA Policies to Advance Equity”).
64 “Memorandum from Keith Turi”; FEMA, “Changes to IA Policies to Advance Equity.”
65 “Memorandum from Keith Turi,” p. 2; FEMA, “Changes to IA Policies to Advance Equity”; Hannah Dreier and
Andrew Ba Tran, “The Real Damage: Why FEMA Is Denying Disaster Aid to Black Families That Have Lived for
Generations in the Deep South,” Washington Post, July 11, 2021, https://www.washingtonpost.com/
nation/2021/07/11/fema-black-owned-property/.
66 FEMA, “FEMA Defines Equity in its Mission of Making Programs More Accessible,” HQ-21-208, September 9,
2021, https://www.fema.gov/press-release/20210909/fema-defines-equity-its-mission-making-programs-more-
accessible.
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Date
Summary of Action or Policy
December 2021
FEMA publishes its 2022-2026 Strategic Plan; the first goal is to “instil equity as a
foundation of emergency management.”67
February 2022
FEMA releases its “Equity Action Plan” delineating means to implement its
commitment to equity in the 2022-2026 Strategic Plan. 68
July 2022
FEMA announces that four agency programs wil be covered under President
Biden’s Justice40 Initiative, which aims to deliver 40% of overall benefits of certain
federal investments to disadvantaged communities.69
Source: Compiled by CRS.
Considerations for Congress—Recent FEMA Actions
Congress may continue or initiate oversight actions to monitor FEMA’s recent equity initiatives,
including progress in achieving the goals set forth in the agency’s Strategic Plan and Equity
Action Plan.70 Congress could, for example, track FEMA’s progress towards meeting the equity-
based goals and performance measures outlined in its Strategic Plan, and/or require FEMA to
identify the specific resources needed to advance equity in fulfillment of FEMA’s goal of
instilling equity as a foundation of emergency management. This could include potential
congressional support, such as broadening agency authorities or appropriating funding for equity
initiatives or in anticipation of expanded program access and expenditures.
Congress may also suggest new priorities. For example, through the Equity Action Plan, several
Members of Congress and emergency management stakeholders have promoted efforts to
streamline the application process for states and individual applicants’ applications for
assistance—to promote equity, reduce administrative burdens, and expedite recovery.71 Given
these overlapping interests, Congress could potentially direct FEMA to simplify its applications
and review process.
Alternatively, Congress may decide to clarify FEMA’s authorities should it find that proposed
agency actions exceed the scope of existing statute and regulations.

67 FEMA, Strategic Plan.
68 Department of Homeland Security (DHS)/FEMA, “Agency Equity Action Plan,” https://assets.performance.gov/cx/
equity-action-plans/2022/EO%2013985_FEMA_Equity%20Action%20Plan_2022.pdf (hereinafter FEMA, “Equity
Action Plan”). See also, General Services Administration and Office of Management and Budget, “Advancing an
Equitable Government,” https://www.performance.gov/equity/); FEMA, “Equity Action Plan Summary,”
https://www.whitehouse.gov/wp-content/uploads/2022/04/FEMA-EO13985-equity-summary.pdf.
69 FEMA, “FEMA Announces Programs Included in the Biden-Harris Administration’s Justice40 Initiative to Increase
Equity, Community Resilience,” July 15, 2022, https://www.fema.gov/press-release/20220715/fema-announces-
programs-included-biden-harris-administrations-justice40.
70 FEMA, “Equity Action Plan” (the FEMA equity action plan was required pursuant to Executive Order 13985). See
also, General Services Administration and Office of Management and Budget, “Advancing an Equitable Government,”
https://www.performance.gov/equity/.
71 FEMA, “Equity Action Plan,” p. 15; Comment submitted by United Way of Greater Houston, “Request for
Information on FEMA Programs, Regulations, and Policies; Public Meetings; Extension of Comment Period,” FEMA-
2021-0011-0285; Testimony of Daniele Koerner, Delaware County Department of Emergency Services, in U.S.
Congress, Senate Special Committee on Aging, Inclusive Disaster Management: Improving Preparedness, Response,
Recovery, 117th Cong., 1st sess., November 18, 2021, pp. 11-12; Comments by Representative Mucarsel-Powell, U.S.
Congress, Subcommittee on Economic Development, Public Buildings, and Emergency Management, House
Committee on Transportation and Infrastructure, An Assessment of Federal Recovery Efforts from Recent Disasters, pp.
48-49.
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Data Collection and Analysis for Program Evaluation
FEMA collects limited demographic data on program applicants and recipients.72 For example,
applicants for Individuals and Households Program (IHP) assistance provide information on
citizenship status, address, insurance, household pre-disaster annual gross income, and other
applicant identifying information.73 FEMA does not, however, currently collect data on
applicants’ race, ethnicity, education, and other demographic characteristics, which limits
FEMA’s ability to understand the nature and extent of disparities in the provision of federal
disaster assistance across different population groups. GAO noted that the Individual Assistance
program lacks data and analysis that it would need to identify potential access barriers and
disparate outcomes.74
In January 2022, FEMA published a notice and request for comment on the collection of
demographic information from applicants for relief, and in May 2022 published responses to 32
comments received.75 FEMA did not specify what additional data would be collected, though the
agency did note that questions regarding race, ethnicity, and tribal membership would be
included, and that the agency would not be adding a question regarding citizenship status.76 The
agency did explain that
FEMA intends to add demographic questions to existing data collections for grant
programs.... Such information is necessary to assess and enforce FEMA’s civil rights
obligations; its nondiscrimination and equity requirements and obligations as outlined in
federal civil rights laws, such as the Civil Rights Act of 1964, the Rehabilitation Act, and
the Stafford Act, as well as relevant Executive Orders. Collection of this information will
also allow grant offices to identify and remove barriers to application, qualification and
award, and permitting activities directly affecting disaster survivors to identify and remove
barriers to equity and enhance programmatic accessibility.77
Among the comments were concerns that additional data collection could raise privacy concerns
and exacerbate the demands on applicants, and suggestions for interagency data sharing.78 Many
other comments supported FEMA’s efforts to solicit more data and ensure that different
communities had access to FEMA assistance.

72 Existing statutes and the U.S. Constitution do not prohibit the collection of such data. See CRS Legal Sidebar
LSB10631, The American Rescue Plan Act: Equal Protection Challenges, by Christine J. Back and April J. Anderson.
73 FEMA, Individual Assistance Program and Policy Guide (IAPPG), Version 1.1, FP 104-009-03, May 2021, p. 255,
https://www.fema.gov/sites/default/files/documents/fema_iappg-1.1.pdf, (hereinafter FEMA, IAPPG), p. 72.
74 Statement of Chris P. Currie, Director, Homeland Security and Justice, Testimony Before the Committee on
Homeland Security, House of Representatives, Disaster Recovery: Efforts to Identify and Address Barriers to
Receiving Federal Recovery Assistance, GAO-22-105488, October 27, 2021, p. 6, https://www.gao.gov/assets/gao-22-
105488.pdf.
75 DHS/FEMA, “Agency Information Collection Activities: Proposed Collection; Comment Request; Generic
Clearance for Civil Rights and Equity,” 87 Federal Register 3836-3837, January 25, 2022, https://www.govinfo.gov/
content/pkg/FR-2022-01-25/pdf/2022-01314.pdf; DHS/FEMA, “Agency Information Collection Activities: Submission
for OMB Review. See also Thomas Frank, “FEMA to Start Tracking Race of Disaster-Aid Applicants,” Scientific
American E&E News, January 26, 2022, https://www.scientificamerican.com/article/fema-to-start-tracking-race-of-
disaster-aid-applicants/.
76 Comment Request; Generic Clearance for Civil Rights and Equity,” 87 Federal Register 30246-30251, May 18,
2022, https://www.govinfo.gov/content/pkg/FR-2022-05-18/pdf/2022-10620.pdf.
77 DHS/FEMA, “Agency Information Collection Activities: Submission for OMB Review; Comment Request; Generic
Clearance for Civil Rights and Equity,” 87 Federal Register 30247, May 18, 2022, https://www.govinfo.gov/content/
pkg/FR-2022-05-18/pdf/2022-10620.pdf.
78 Ibid.
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Considerations for Congress—Data Collection and Evaluation
Congress may wish to monitor FEMA’s implementation of recent efforts to expand applicant
demographic data collection efforts, including the scope, agency use, and public access to the
data collected. Congress may also consider directing FEMA to utilize measurable criteria by
which the agency may monitor progress on meeting equity criteria for each program. For
example, FEMA’s Flood Mitigation Assistance program utilizes quantitative criteria to meet their
stated equity goals, whereas the Building Resilient Communities and Infrastructure (BRIC)
program does not.79 Relatedly, Congress may assess potential risks to disaster survivors’ privacy
and/or increased application complexity should FEMA collect additional demographic data.
FEMA’s Strategic Plan includes research questions the agency may use to address “evidence
gaps” relevant to its three strategic goals, including the goal to ensure the equitable delivery of
assistance.80 Congress could request periodic updates on FEMA’s findings and conduct oversight
over subsequent agency actions. For example, Congress may wish to monitor potential policy
changes undertaken if certain groups are found to face significant barriers to access, and agency
efforts to evaluate the efficacy of such policy changes. Congress may also request particular data
and/or responses to particular program evaluation questions enabled by new data (e.g., disparities
in program access or award amount by race).
SLTT Capacity Constraints
Governments serving disadvantaged communities may face capacity constraints that inhibit their
ability to pursue and receive relief. Governments representing lower-income communities may
have fewer financial resources, fewer emergency management and recovery personnel, and less
technical expertise and experience navigating complex federal grant programs.81 Further,
communities that are smaller, rural, and lower-income may not be able to easily afford and secure
consultant services to assist with FEMA grant application and review.82 In recent years, experts

79 See CRS Report R46989, FEMA Hazard Mitigation: A First Step Toward Climate Adaptation, by Diane P. Horn.
80 FEMA, Strategic Plan, Appendix 2, pp. 32-35.
81 See remarks of FEMA Administrator Deanne Criswell at the National Hurricane Conference in which the
Administrator states, “We know that small and disadvantaged communities continue to face barriers in taking on
mitigation projects. This is because the development of plans and getting through the application process takes time, it
can be costly, and it can be overwhelming.... This is especially difficult for emergency management offices with limited
staff and small budgets. I personally know what it was like to have a team of two fulfilling our day-to-day duties while
trying to navigate bureaucratic federal assistance programs—the issue is a lack of capacity, not of interest.” (FEMA,
“Administrator Criswell Speech at National Hurricane Conference”). See also FEMA, Strategic Plan, pp. 11-12; Carlos
Martín, “How Our Disaster Recovery Should Improve in the Face of Stronger Hurricanes,” Urban Wire, Urban
Institute, September 4, 2019, https://www.urban.org/urban-wire/how-our-disaster-recovery-should-improve-face-
stronger-hurricanes; Rachel Lawrence et al., “Disaster Preparedness Resource Allocation and Technical Support for
Native American Tribes in California, Journal of Homeland Security and Emergency Management, vol. 13, no. 3
(2016), pp. 351-365; GAO, Puerto Rico Recovery: FEMA Made Progress in Approving Projects, but Should Identify
and Assess Risks to the Recovery, GAO-21-264, May 2021, https://www.gao.gov/assets/gao-21-264.pdf, pp. 32-33;
Nicole Dash and Walter Gillis Peacock, “And the Poor Get Poorer: A Neglected Black Community,” in Hurricane
Andrew, Ethnicity, Gender and the Sociology of Disasters, Walter Gillis Peacock, Betty Hearn Morrow, and Hugh
Gladwin, eds., Routledge, 1997, pp. 216-219; and GAO, Disaster Resilience: FEMA Should Take Additional Steps to
Streamline Hazard Mitigation Grants and Assess Program Effects, GAO-21-140, February 2021, https://www.gao.gov/
assets/gao-21-140.pdf.
82 GAO, Disaster Recovery: Additional Actions Needed to Identify and Address Potential Recovery Barriers, GAO-22-
104039, December 15, 2021, pp. 25-26, https://www.gao.gov/products/gao-22-104039; Thomas Frank, “FEMA
Climate Grants Pose Challenge for Poor Communities,” E&E News ClimateWire, June 1, 2021; GAO, Disaster
Resilience: FEMA Should Take Additional Steps to Streamline Hazard Mitigation Grants and Assess Program Effects,
GAO-21-140, February 2021, https://www.gao.gov/assets/gao-21-140.pdf; Comment submitted by Washington State
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and emergency management stakeholders have raised concerns that SLTTs representing
underserved communities receive fewer grants and lower grant awards, for reasons including
insufficient capacity and financial resources.83 Experts do not know to what extent grant
application complexity may keep these communities from seeking available federal assistance.84
To assist jurisdictions with such shortfalls, FEMA sometimes provides supplemental federal
personnel to communities. For example, some states have embedded FEMA Integration Teams
(FITs) in their emergency operations centers. Additionally, in response to specific incidents,
FEMA may deploy FEMA Incident Management Assistance Teams, Urban Search and Rescue,
and federal personnel from across the government through Mission Assignments, or work
orders.85 These resources are limited: for example, FITs are not embedded in every state. During
times of high demand, FEMA may not be able to fulfill all requests for federal assets.
Among the programs that have raised equity-related concerns is FEMA Public Assistance. Public
Assistance provides grants to SLTTs and eligible nonprofits for at least 75% of eligible disaster
response and recovery costs. Lower-income communities that are unable to meet the 25%
nonfederal cost share may not pursue every possible assistance opportunity, or may struggle to
navigate the complex, multi-step application review process in a timely manner.86 While the
President is authorized to increase the federal cost share, FEMA generally supports such increases
by considering recovery costs—not a community’s financial resources. Additionally, PA is a
reimbursement-based program. Applicants generally carry out—and pay for—eligible response
and recovery activities before they receive reimbursement. The need to cover up-front costs has
strained SLTTs with low financial resources—particularly those facing catastrophic damages.87

Emergency Management Division, FEMA, “Request for Information on FEMA Programs, Regulations, and Policies;
Public Meetings; Extension of Comment Period,” FEMA-2021-0011-0154.
83 Alessandra Jerolleman, “Challenges of Post-Disaster Recovery in Rural Areas,” in Shirley Laska, Ed., Louisiana’s
Response to Extreme Weather (Springer Open Press, 2020), pp. 285-310; GAO, Statement of Chris P. Currie, Director,
Homeland Security and Justice, Testimony Before the Subcommittee on Emergency Preparedness, Response, and
Recovery, Committee on Homeland Security House of Representatives, Disaster Resilience: Opportunities to Improve
National Preparedness, GAO-22-106046, May 17, 2022, pp. 8-9, https://www.gao.gov/assets/gao-22-106046.pdf;
questions from Delegate Eleanor Holmes Norton, U.S. Congress, House Committee on Oversight and Reform,
Hurricane Ida And Beyond: Readiness, Recovery, and Resilience, 117th Cong, 1st sess., October 5, 2021; Comment
submitted by California Office of Emergency Services, FEMA, “Request for Information on FEMA Programs,
Regulations, and Policies; Public Meetings; Extension of Comment Period,” FEMA-2021-0011-0261, p. 5.
84 For discussion of this issue with respect to hazard mitigation assistance, see GAO, Disaster Resilience: FEMA
Should Take Additional Steps to Streamline Hazard Mitigation Grants and Assess Program Effects, GAO-21-140,
February 2021, https://www.gao.gov/assets/gao-21-140.pdf, pp. 21-22.
85 See, FEMA, “FEMA Integration Team Launches in Maryland,” release R3-19-NR-007, May 2, 2019,
https://www.fema.gov/press-release/20210318/fema-integration-team-launches-maryland; FEMA, “Field Operations,
Incident Management Assistance Teams,” https://www.fema.gov/about/offices/field-operations#imat; FEMA, “Urban
Search & Rescue,” https://www.fema.gov/emergency-managers/national-preparedness/frameworks/urban-search-
rescue; and FEMA, “Federal Agency Mission Assignments,” https://www.fema.gov/partnerships/mission-assignments.
86 Jasmine Butler, “Turning the Tide Toward Equity: Simplifying Federal Flood Assistance Applications,” American
Flood Coalition Blog, May 2020, https://floodcoalition.org/2020/05/turning-the-tide-toward-equity-simplifying-
federal-flood-assistance-applications/; Comment Submitted by Washington State Emergency Management Division,
FEMA, “Request for Information on FEMA Programs, Regulations, and Policies; Public Meetings; Extension of
Comment Period,” FEMA-2021-0011-0154.
87 Comment Submitted by Washington State Emergency Management Division, FEMA, “Request for Information on
FEMA Programs, Regulations, and Policies; Public Meetings; Extension of Comment Period,” FEMA-2021-0011-
0154. The Commonwealth of Puerto Rico cites the reimbursement procedures as one of the primary factors
contributing to territory-wide recovery delays following the 2017 hurricanes. FEMA, Puerto Rico Recovery: FEMA
Made Progress in Approving Projects but Should Identify and Asses Risks to Recovery, GAO-21-264, May 2021, pp.
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Considerations for Congress—SLTT Capacity Constraints
Congress could consider addressing concerns that SLTT capacity shortfalls create hardship for
disadvantaged communities and individuals through several means. It could seek more
information on the problem, perhaps by requiring FEMA to evaluate and report on its deployment
of federal operational assistance. Congress could conduct oversight on the existing deployment of
federal personnel, technical assistance, and financial assistance for staffing to evaluate the
distribution of FEMA operational resources across communities with varying capacity and need.
Should Congress identify shortfalls, Congress could consider appropriating additional funds to
FEMA to expand federal resources available to enhance SLTT capacity.88 Congress could also
consider requiring FEMA to identify means of simplifying existing applications and requests for
assistance that may disproportionately strain SLTT governments with fewer resources and less
technical expertise.
Congress could also consider addressing concerns regarding disparate SLTT capacity to cover
nonfederal cost shares. To that end, Congress could consider authorizing a means for the
President to provide supplemental assistance to hazard-stricken, underserved communities. For
example, Congress could amend the Stafford Act to allow for an increased cost share for the
Public Assistance program for small, rural, impoverished, or otherwise disadvantaged
communities, and require FEMA to engage in a rulemaking or develop guidance detailing such
implementation. However, Congress may weigh the potential problems and legal restrictions on
targeting federal assistance based on race or national origin, and consider alternative means of
defining underserved populations.89 For example, Congress could target assistance based on
historical access to federal disaster assistance, vulnerability to future hazards, or physical
isolation from emergency services.
Congress may wish to weigh potential burdens on federal finances and personnel that may result
from expanding direct assistance to subfederal partners. Without additional appropriations,
existing FEMA resources may be strained if the agency commits additional personnel or funds to
subfederal response and recovery efforts. Additionally, Congress may determine that additional
subfederal assistance is at odds with the tenet that Stafford Act assistance should supplement—
rather than supplant—SLTT resources.
Stafford Act Eligibility and Equity
Under current law, different types of entities and groups of individuals are eligible for different
forms of federal disaster assistance. Any affected disaster survivor may access certain forms of
assistance (for example, Crisis Counseling) when they are made available to a jurisdiction under a
Stafford Act declaration. Other forms of assistance have more restrictive eligibility requirements
that must be met (for example, assistance for home repair is available only to homeowners).90

33-36.
88 Comment Submitted by State of Alaska Division of Homeland Security and Emergency Management, FEMA,
“Request for Information on FEMA Programs, Regulations, and Policies; Public Meetings; Extension of Comment
Period,” FEMA-2021-0011-0001.
89 See CRS Report R45481, “Affirmative Action” and Equal Protection in Higher Education, by Christine J. Back; and
CRS Legal Sidebar LSB10631, The American Rescue Plan Act: Equal Protection Challenges, by Christine J. Back and
April J. Anderson.
90 Many forms of FEMA assistance are available to individuals regardless of citizenship, such as emergency sheltering
support, Crisis Counseling, Disaster Case Management, and Disaster Legal Services; however, assistance through the
Individuals and Households Program requires that the applicant be a U.S. citizen, non-citizen national, or qualified
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Some Members of Congress and stakeholders have raised concerns that particular limitations on
eligibility are at odds with the Stafford Act’s nondiscrimination requirements. Concerns include
limitations on IHP assistance for individuals who are homeless;91 relief programs directed at
property owners and property damages that may favor wealthier and/or whiter communities;92
and restrictions on Stafford Act assistance for some nonprofit organizations that often serve
vulnerable communities.93
FEMA has modified some applicant eligibility policies to address findings that eligibility
restrictions may have resulted in inequitable distribution of Stafford Act assistance. For example,
FEMA adjusted the method to determine the minimum amount of damage required to qualify for
Direct Temporary Housing Assistance to address restrictions on residents with lower-value
homes.94 FEMA also expanded the forms of documentation the agency will accept to establish
occupancy and ownership.95 Upon issuing this updated guidance, FEMA stated that the change

alien (FEMA, IAPPG, pp. 46-47).
91 FEMA, IAPPG, p. 61 details limitations on assistance to individuals who are homeless. See also comments by
Christopher P. Currie in response to questions by Representative Barragán, House Homeland, Ensuring Equity in
Disaster Preparedness, Response, and Recovery, p. 62; Comment Submitted by National Low Income Housing
Coalition, FEMA, “Request for Information on FEMA Programs, Regulations, and Policies; Public Meetings;
Extension of Comment Period,” FEMA-2021-0011-0235.
92 See also comments by Representative Torres and Chauncia Willis, House Homeland, Ensuring Equity in Disaster
Preparedness, Response, and Recovery, p. 68; Christopher Flavelle, “Why Does Disaster Aid Often Favor White
People?” New York Times, updated October 27, 2021, https://www.nytimes.com/2021/06/07/climate/FEMA-race-
climate.html; Rebecca Hersher and Ryan Kellman, “Why FEMA Aid Is Unavailable to Many Who Need It the Most,”
NPR Science, June 29, 2021, https://www.npr.org/2021/06/29/1004347023/why-fema-aid-is-unavailable-to-many-who-
need-it-the-most; Gary Long, “FEMA Loses Dolly Battle; Disaster Aid Sparring Ends After Eight Years,” The
Brownsville Herald, February 23, 2017; La Union Del Pueblo Entero et al. vs. Federal Emergency Management
Agency (FEMA), Civil No. 1:08-Cv-487, United States District Court for the Southern District of Texas, Brownsville
Division, 2017; Howell and Elliot, “Damages Done.”
93 For example, see concerns over restrictions of Public Assistance for protection and advocacy groups for individuals
with disability, Comment Submitted by National Disability Rights Network, FEMA, “Request for Information on
FEMA Programs, Regulations, and Policies; Public Meetings; Extension of Comment Period,” FEMA-2021-0011-
0205.
94 FEMA now uses a verified loss amount of at least $12 per square foot as the threshold for providing such assistance
for homeowners (FEMA, IAPPG, p. 96; see also testimony of FEMA Administrator Criswell, U.S. Congress, House
Committee on Transportation and Infrastructure, Subcommittee on Economic Development, Public Buildings, and
Emergency Management, FEMA Priorities for 2022 and the 2022-2026 Strategic Plan, 117th Cong., 1st sess., April 5,
2022). Previously, property owners had to have a real property verified loss amount of at least $17,000 (FEMA,
IAPPG). The goal of this policy change, according to the FEMA Administrator, was to “ensure equitable damage
evaluations regardless of the amount of damage to the home” (Statement of Deanne Criswell, FEMA Administrator
Before the U.S. Congress, House Committee on Transportation and Infrastructure, Subcommittee on Economic
Development, Public Buildings, and Emergency Management, FEMA Priorities for 2022 and the 2022-2026 Strategic
Plan, 117th Cong., 1st sess., April 5, 2022, p. 2, https://transportation.house.gov/imo/media/doc/
Criswell%20Testimony2.pdf).
95 “Memorandum from Keith Turi”; FEMA, “Changes to IA Policies to Advance Equity”; and FEMA, Strategic Plan.
For example, FEMA will accept a “written self-declarative statement ... from applicants whose pre-disaster residence
was passed down via heirship,” which in this context, FEMA defines as “the legal right to receive real and personal
property under state law upon the death of an ancestor or next of kin,” pp. 8-9. Prior to this policy change, there were
reports that some African American families in the Southern United States were prevented from receiving assistance
for which they may have otherwise been eligible because they own property passed down by heirship and lack the
formal or traditional documentation FEMA previously would accept to prove ownership (e.g., deed or deed of trust to
the property). Hannah Dreier and Andrew Ba Tran, “The Real Damage: Why FEMA Is Denying Disaster Aid to Black
Families That Have Lived for Generations in the Deep South,” Washington Post, July 11, 2021,
https://www.washingtonpost.com/nation/2021/07/11/fema-black-owned-property/.
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was made to “reduce barriers to access experienced by underserved populations.”96 Furthermore,
FEMA’s Strategic Plan adopts a “people first approach” that seeks to expand eligibility to
enhance underserved communities’ participation, including by revising its guidance.97
Considerations for Congress—Stafford Act Eligibility
Congress may consider existing statutory eligibility restrictions and their consequences for
disaster survivors and communities, particularly those that are socially vulnerable. For example,
Congress may consider legislation extending existing forms of assistance to currently ineligible
individuals experiencing homelessness and/or renters, who on average receive less federal
disaster assistance than homeowners.98 Alternatively, Congress may consider directing FEMA to
identify forms of assistance needed by underserved groups that are not currently authorized in
statute.
Congress could also address eligibility restrictions established in regulations or policy by
directing FEMA to review and update such policies to address findings that they burden particular
disadvantaged communities and individuals (e.g., rural communities, renters, certain nonprofits).
Alternatively, Congress could consider directing FEMA to modify eligibility determination
procedures to reduce burdens on these communities (simplifying processes and determination
letters, for example).
Conclusion
Newly proposed legislation in the 117th Congress attempts to redress concerns that federal relief
may not be equitably accessed and distributed. FEMA has separately undertaken a range of
actions to promote equity in its disaster mitigation and relief programs. Differing interpretations
of FEMA’s authority to redress these concerns may continue to face Congress as the extent,
frequency, severity, and effects of disasters increase. Further discussion is likely to address equity
issues in the context of the disaster declaration process and specific FEMA disaster assistance
programs.

Author Information

Erica A. Lee
Elizabeth M. Webster
Analyst in Emergency Management and Disaster
Analyst in Emergency Management and Disaster
Recovery
Recovery

96 FEMA, “Changes to IA Policies to Advance Equity”; see also FEMA, Strategic Plan, p. 11 (see “Equity in Action”
text box).
97 FEMA, Strategic Plan, p. 11.
98 Statement of Lori Peek, House Homeland, Ensuring Equity in Disaster Preparedness, Response, and Recovery, p. 8
(in which the witness stated that “[a]t present, ... many Government programs do not consider equity in providing aid
and therefore can actually deepen and create sustained inequalities. This leaves already vulnerable people even more at
risk. For example, a recent study by Drakes and colleagues revealed low levels of post-disaster aid disbursement in
places where households have high levels of social vulnerability—specifically those in rural areas, renters, the
unmarried, black and Asian Americans, and those with low incomes received less aid”).
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Acknowledgments
Jared Nagel, Senior Research Librarian, supported the research efforts associated with developing this
report. April Anderson, Legislative Attorney; Libby Perl, Specialist in Housing Policy; Diane Horn,
Specialist in Flood Insurance and Emergency Management; and Lauren R. Stienstra, Section Research
Manager, provided structural and editorial comments and suggestions. Shelley Harlan, Editor, helped edit
the report text and footnotes.

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