Disaster Assistance: Actions Needed to Strengthen FEMA's Housing Inspections Process
Fast Facts
After a major disaster, survivors can apply for the Federal Emergency Management Administration's Individuals and Households program for temporary housing or home repair funds. Of the 2.7 million applicants from Jan. 2018-Nov. 2021, FEMA authorized housing inspections (to determine eligibility) for about half of them.
FEMA has taken steps to improve its housing inspections process. Since an Apr. 2020 streamlining effort, FEMA's inspectors are using key indicators (e.g., floodwater height in a home) to estimate damages instead of itemizing them. However, FEMA hasn't assessed the accuracy of this approach.
We recommended FEMA address this and more.
Highlights
What GAO Found
About 2.7 million people applied to the Federal Emergency Management Agency (FEMA) Individuals and Households Program for major disasters declared from January 1, 2018 through November 1, 2021. Of these applicants, FEMA authorized housing inspections for about 1.4 million and approved about 710,000 applicants for assistance. For those who were not approved for assistance, the most common reasons for ineligibility were that they had insurance, or had insufficient or no reported damage. The median and mean amounts of Individuals and Households Program assistance per applicant were $2,314 and $4,157, respectively.
Disaster-related Damages to Homes in California (left) and Texas (right) in 2021
FEMA has taken actions since 2018 intended to improve the housing inspections process, but has not always assessed how the changes affect the Individuals and Households Program applicant awards. For example, in part to respond to the COVID-19 pandemic, FEMA streamlined its approach in April 2020 for estimating damages to homes. Instead of recording itemized damages, inspectors estimated the overall damage level of a home based on a smaller set of key indicators (e.g., height of floodwater in a home). However, FEMA has not assessed this new approach to determine if it accurately estimates damages. GAO found that mean awards were 35 percent lower under the new approach than under the prior approach.
In March 2020, FEMA began using applicant self-assessment questions to determine whether to authorize housing inspections for applicants. According to the new policy, applicants who self-assessed having minor home damage would not receive an inspection, and therefore not receive certain types of assistance, unless they took additional steps to request an inspection. FEMA's goal was to reduce the number of required inspections and deliver assistance to applicants with the greatest need first. However, FEMA analysis and GAO's observations indicate that these self-assessments are not a reliable indicator of eligibility. For example, from January 2018 to November 2021, 43 percent of applicants who self-assessed minor damage were found to have eligible damages. Although FEMA discontinued this practice, officials told GAO that the policy remains in place for FEMA to implement at its discretion in the future. Ensuring its policy on the use of self-assessments is supported by evidence could help FEMA ensure it accurately identifies eligibility for assistance.
Why GAO Did This Study
Since 2017, over 300 presidentially-declared major disasters have occurred across the country. Following such disasters, FEMA conducts housing inspections to assess damages and award assistance for home repairs and other needs to survivors who apply under the Individuals and Households Program.
The Additional Supplemental Appropriations for Disaster Relief Act, 2019 included a provision for GAO to review issues following the 2018 disaster season. This report addresses, among other things, (1) how many Individuals and Households Program applicants were authorized housing inspections and received assistance for major disasters declared from January 2018 to November 2021 and (2) the extent to which FEMA has taken actions intended to improve its housing inspections process since 2018.
GAO analyzed Individuals and Households Program applicant data from January 2018 to November 2021 and reviewed relevant documentation and policies. GAO interviewed FEMA officials and contracted housing inspectors; and observed selected housing inspections.
Recommendations
GAO is making seven recommendations to the Department of Homeland Security (DHS), including that FEMA assess the accuracy of its damage level approach and take steps to ensure its policies on the use of self-assessments are supported by evidence in accurately identifying eligibility for assistance. DHS disagreed with two recommendations, but GAO continues to believe they are warranted.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Federal Emergency Management Agency | The FEMA Administrator should develop and implement a policy to consistently report on IHP applicants' housing inspections statuses. (Recommendation 1) |
In April 2024, FEMA officials provided an example of an updated IA Daily Status Report and legend. FEMA revised the Daily Status Report to provide the percentage of issued inspections its contracted housing inspectors returned to FEMA. GAO found that FEMA was reporting on the percentage of "complete" inspections in the IA Daily Status Report, which was misleading because the data included inspections that had not been conducted. FEMA also updated the Daily Status Report legend to define the percentage of returned inspections as the percentage of housing inspections returned by its contracted housing inspectors versus those issued to the contractors. Further, the legend explains the total count of inspections returned by its contracted housing inspectors can include various inspections statuses (complete, withdrawn, inaccessible, no contact, or missed 2 appointments). According to FEMA, IHP housing inspection reports are standard reports that have existed for years, and the agency does not anticipate using any new reports. Additionally, if the agency needs to develop new IHP reports in the future, these reports would be based on existing reports and legends, ensuring the application of standard definitions. As a result of these steps taken by FEMA, we consider this recommendation closed and implemented.
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| Federal Emergency Management Agency | The FEMA Administrator should assess its IHP applicant data to identify and implement ways to improve its recording of eligibility and status codes. (Recommendation 2) |
In February 2024, FEMA officials provided a copy of the Recovery Directorate's (IA Division and Recovery Directorate's Technology and Program Division) Registration Status, Eligibility Code, and Special Handling Query Review paper. This recommendation paper was based on a review of registration status codes, eligibility codes, and special handling queries used in the National Emergency Management Information System. FEMA also completed actions to identify obsolete and duplicative codes and implemented changes to remove them from use. As a result of its review, the Recovery Directorate identified 14 obsolete eligibility codes as having been incorrectly utilized in 283 different registrations from October 2020 through April 2023. In June 2023, the Recovery Directorate removed references to each of these codes from the active Processing Procedure Manual (PPM). As of October 2023, the obsolete eligibility codes only exist in archived data tables that caseworkers cannot use or access. Further, FEMA identified and provided documentation of 100 status codes that it had not utilized over the past 3 years. The agency also removed the 100 inactive status codes from its PPM and archived a list of the codes for historical reference. As a result of these steps taken by FEMA, we consider this recommendation closed and implemented.
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| Federal Emergency Management Agency | The FEMA Administrator should assess the accuracy of the damage level approach for IHP housing inspections and adjust the approach as needed. (Recommendation 3) |
In May 2024, FEMA officials provided an update stating the agency anticipates the public comment period for the Individual Assistance (IA) Program Equity Interim Final Rule will end in July 2024. IA leadership intends to incorporate policy-related feedback from the public comment period into the Individual Assistance Program and Policy Guide (IAPPG) draft prior to publication. According to FEMA officials, the IA Division will make applicable programmatic and/or policy changes to the IAPPG and implement those changes by December 2025.
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| Federal Emergency Management Agency | The FEMA Administrator should take steps to ensure its policies on the use of applicants' self-assessments are supported by evidence, such as assessing the reliability of self-assessment responses to accurately identify eligibility for assistance. (Recommendation 4) |
In February 2024, FEMA officials provided documentation of its updated online application (Registration Intake) for IHP assistance. The updated IHP application continues to ask applicants to self-assess their damage but includes more examples (from a variety of causes of damage) of what constitutes each self-assessed damage response option. Applicants applying online have the examples displayed below each self-assessed damage option. According to FEMA, as of October 2023, applicants applying via FEMA call centers or Disaster Survivor Assistance Teams in communities are offered the opportunity to have the examples read to them before selecting a self-assessed damage option. As a result of these steps taken by FEMA, we consider this recommendation closed and implemented.
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| Federal Emergency Management Agency | The FEMA Administrator should develop and implement a strategy to assess and mitigate fraud risks posed by the remote inspections process. (Recommendation 5) |
In February 2024, FEMA officials stated that its Recovery Reporting and Analytics Division completed its strategy documentation of analysis and fraud case review processes. FEMA provided its Fraud Review Queue User Guide, which describes the procedures for reviewing cases in the Fraud Review Queue in the National Emergency Management Information System (NEMIS). Specifically, the user guide includes steps for reviewing the record in NEMIS, locking fraudulent registrations, and updating registration records to request additional documentation or allow the registration process to continue. The applications reviewed are for presidential disaster declarations (man-made or natural disasters). FEMA also provided its Fraud Review Queue User Guide: COVID-19 Funeral Assistance - Program Operational (Standard Operating Procedure), which provides the procedures for reviewing cases that are flagged for RAD's review in the Fraud Review Queue in NEMIS. The applications reviewed are for COVID Funeral Assistance only. According to FEMA officials, as of March 2024, IA Division's Field Services Section (FSS) is completing all initial housing inspections in person. Additionally, FSS is only conducting remote housing inspections for appeal inspections, after an initial in person inspection was completed and there are no field inspectors deployed and working in the disaster. If an IHP applicant requests an in-person inspection in an appeal request, FSS: 1) assigns an inspector to the field for the inspection; 2) offers a video inspection; and 3) reviews all documents and data in NEMIS while performing the inspection. As of March 2024, FSS plans to maintain its current posture for conducting housing inspections. As a result of these steps taken by FEMA, we consider this recommendation closed and implemented.
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| Federal Emergency Management Agency | The FEMA Administrator should develop and implement a plan with time frames and interim milestones for addressing, in collaboration with relevant stakeholders, technology-related challenges in the housing inspections process. (Recommendation 6) |
In February 2024, FEMA officials provided documentation of the steps the agency took to address technology related challenges in the IHP housing inspections process. Specifically, in September 2023, Recovery Directorate's Technology and Program Division (RTPD) updated versions of the system roadmaps-with timeframes and milestones-for its Automated Construction Estimator (ACE) and National Emergency Management Information System (NEMIS-IA) to address technology related challenges in the housing inspections process. Further, RTPD has completed updates to Recovery Directorate technology systems. For example, in December 2022, RTPD deployed a validation system in NEMIS-IA and ACE, that enables RTPD to develop and deploy validation checks for housing inspectors within days (or less). In November 2023, RTPD continued to add or modify 29 validation checks within ACE. As a result of these steps taken by FEMA, we consider this recommendation closed and implemented.
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| Federal Emergency Management Agency | The FEMA Administrator should develop and implement a strategy to ensure that contracted housing inspectors have the resources needed, including providing official tablets and ensuring contracted housing inspectors have email addresses, to carry out housing inspections and communicate with applicants. (Recommendation 7) |
In February 2024, FEMA reiterated that the Recovery Directorate's strategy included adding a budget line item to purchase iPads in increments of up to 1,000 per year based on approved funding. This strategy remains in place for fiscal year 2024 and will continue each year based on approved funding. FEMA provided purchase requisitions and task orders for the fiscal year 2022 iPad purchases as examples. GAO reported that, in communicating with applicants throughout the housing inspections process, FEMA's contracted housing inspectors do not have or use company email addresses and do not all have agency tablets needed to contact and obtain information from IHP applicants about inspections. Further, some contracted housing inspectors GAO interviewed stated the use of personal email addresses to communicate with IHP applicants creates various challenges. FEMA officials reiterated that, in March 2023, the agency delivered official written notice-to both of its housing inspection contractors-prohibiting their inspectors from using email to communicate with IHP applicants. Further, FEMA stated that it does not believe that government-issued e-mail addresses are a necessary method for inspectors to communicate with applicants. As such, communication is currently performed using text messaging and phone calls only. Accordingly, upon receiving the notice from FEMA, both housing inspection contractors enhanced applicable training materials throughout the spring and early summer of 2023 to emphasize that inspectors should not use email to communicate with IHP applicants. FEMA provided examples of the contractors' training materials, which direct inspectors to use phone and text, and not email to communicate with IHP applicants. According to FEMA, due to the number of modules in their learning management system and rotating assignment of staff, inspectors conducting work by mid-August 2023 would have received the updated guidance. In April 2024, FEMA officials stated contracted housing inspectors receive annual training that reinforces they can only use phone or text as means for communicating with IHP applicants. FEMA officials also stated its contracted housing inspectors are reminded, during the inspection briefing for every disaster, that they cannot use email to communicate with applicants. As a result of these steps taken by FEMA, we consider this recommendation closed and implemented.
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