Signed Emergency Justification Memo

U.S. Department of Homeland Security
Washington, D.C. 20472

March 16, 2021

MEMORANDUM FOR:

Dominic Mancini
Acting Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget

THROUGH:

Eric Hysen
Chief Information Officer
Department of Homeland Security

FROM:

Tracey L. Showman
Chief Administrative Officer
Federal Emergency Management Agency

SUBJECT:

Emergency Approval Request of Revisions to Office of Management
and Budget (OMB) Collection 1660-0002 Disaster Assistance
Registration in support of COVID-19 Funeral Assistance

ERIC N
HYSEN

Digitally signed by ERIC
N HYSEN
Date: 2021.03.18
11:28:02 -04'00'

The Federal Emergency Management Agency (FEMA) seeks emergency approval from the
Office of Management and Budget (OMB) to revise information collection 1660-0002 Disaster
Assistance Registration to allow Call Center staff to use a current instrument in a modified
manner. It is vital that the revisions to the currently approved information collection be
implemented as soon as possible due to the Consolidated Appropriations Act, 2021 signed into
law on December 27, 2020, which allocated up to two (2) billion dollars to provide financial
assistance to individuals or households with COVID-19 related funeral expenses. In accordance
with the Paperwork Reduction Act (PRA) and the OMB implementing regulations at 5 C.F.R. §
1320.13: (1) this information is necessary to the mission of the agency, (2) this information is
necessary prior to the normal timeframes established under the PRA, (3) public harm is
reasonably likely to result if normal clearance procedures are followed, and (4) unanticipated
events have occurred.
FEMA requests approval to revise OMB Collection 1660-0002 Disaster Assistance Registration
to allow Call Center staff to use the current version of instrument 009-0-1T, Tele-Registration in
the following modified manner:
•

Call Center staff will provide clarifying statements to applicants regarding how the
currently approved disaster assistance questions in the script relate to COVID-19 Funeral
Assistance;

•

The currently approved response fields in the registration script will be utilized to capture
the following COVID-19 Funeral Assistance related data:
o Damaged Dwelling Address field – Used to indicate the address where the
deceased individual passed away,
o County/Parish/Municipio Where the Damage Occurred field – Used to
indicate the County/Parish/Municipio where the deceased individual passed away,
o Date When the Damage Occurred field – Used to indicate when the COVID-19
funeral expenses were incurred,
o Medical/Dental/Funeral or Burial Insurance field – Used to indicate any
Funeral or Burial Insurance, and any assistance provided by another source (i.e.
State, voluntary organization, etc.), and
o Name, Social Security Number (SSN), Date of Birth fields in the Occupants
section – Used to indicate the name, date of birth, and SSN for the Co-Applicant
and of each Deceased Individual(s). and

•

Applicants will be advised at the conclusion of the registration process that the following
documents will need to be submitted for verification and prevention of duplication of
benefits purposes:
o a death certificate for the deceased individual indicating COVID-19 attributed to
the cause of death,
o documentation including receipts or a funeral contract indicating the cost of the
funeral expenses incurred, the date funeral expenses were incurred, confirmation
the funeral was for the deceased individual, and the name of the person who paid
for the funeral, and
o documentation from other sources including settlement amounts paid by funeral
or burial insurance or any assistance provided by a state agency, voluntary
agency, or other sources.

•

The applicant will also be sent electronically or by mail a Request for Information (RFI)
letter after registration outlining the requested documentation.

Mission Essential Information
The Robert T. Stafford Disaster Relief and Emergency Assistance Act (Public Law 93-288) (the
Stafford Act), as amended, is the legal basis for FEMA to provide disaster-related financial
assistance and services to individuals who apply for disaster assistance benefits in the event of a
federally-declared disaster. Regulations in title 44 of the Code of Federal Regulations (CFR),
Subpart D, “Federal Assistance to Individuals and Households,” implement the policy and
procedures set forth in section 408 of the Stafford Act, 42 U.S.C. 5174, as amended. This
program provides financial assistance and, if necessary, direct assistance to eligible individuals
and households who, as a direct result of a major disaster or emergency, have uninsured or
under-insured damage, necessary expenses, and serious needs which are not covered through
other means. The “Other Needs Assistance” (ONA) provision of FEMA’s Individuals and
Households Program (IHP) provides financial assistance to address disaster related medical,
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dental, funeral, childcare, personal property, transportation, and other necessary expenses or
serious needs resulting from a major disaster.
Currently, when the President declares a Federal disaster or emergency, disaster survivors can
register for assistance using one of the following instruments:
•

FEMA Form 009-0-1Int (English) or 009-0-2Int (Spanish) – allows disaster
survivors to apply for assistance by accessing the forms through
www.Disaster.Assistance.gov via desktop or mobile devices.

•

FEMA Form 009-0-1T – disaster survivors can call FEMA’s 1-800 number to speak
with a FEMA Human Service Representative to apply for disaster assistance over the
telephone.

• FEMA Form 009-0-1 (English) and 009-0-2 (Spanish) – is the paper version of the
disaster assistance registration form. This is only used in rare circumstances when
FEMA’s registration system is not accessible or when phone lines are down.
The information collected from one of the above instruments is electronically transferred to
FEMA’s official system of record, the National Emergency Management Information System
(NEMIS), so the data can be stored and processed.
Due to the passing of the Consolidated Appropriations Act, 2021 into law on December 27,
2020, which allocated up to two (2) billion dollars to provide financial assistance to individuals
or households with COVID-19 related funeral expenses, FEMA requests an Emergency Waiver
to utilize the current FEMA Form 009-0-1T, Tele-Registration script in a modified manner to
gather necessary COVID-19 funeral related information to effectively provide assistance in a
timely manner. This modified instrument will be referred to as 009-0-1T-COVID-FA.
According to the Center for Disease Control’s COVID Data Tracker, there have been
approximately 344,497 COVID-19 related deaths in the United States as of December 31, 2020.
FEMA estimates approximately 500,000 applicant registrations for COVID-19 Funeral
Assistance as a result of the Consolidated Appropriations Act, 2021. FEMA’s IHP has
determined that utilizing a modified version of the current FEMA Form 009-0-1T, TeleRegistration disaster assistance script is the best method to effectively accept and process these
registrations.
Paperwork Reduction Act Timeframes
To meet the requirements of the Consolidated Appropriations Act, 2021, FEMA intends to begin
accepting COVID-19 Funeral Assistance registrations in mid-March 2021. Adhering to the
standard PRA timeframe would hinder the ability to swiftly begin providing assistance to
individuals and households as directed under the Act.

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Public Harm is reasonably likely to Result if Normal Clearance Procedures are followed
The effects of the COVID-19 pandemic have caused an extraordinary economic burden on U.S.
individuals and households. Public harm in the form of unexpected financial burden related to
funeral and burial expenses will continue to impact Americans without FEMA’s implementation
of the modified method of collecting COVID-19 funeral related data. FEMA’s use of the
information will ensure that individuals and households who have been burdened unexpectedly
with COVID-19 funeral or burial expenses are provided with the financial assistance available to
them. If FEMA were required to follow the normal clearance process, it would be impossible to
collect the necessary information for assistance delivery in a timely and effective manner.
Unanticipated Events
The public health and economic effects of the COVID-19 pandemic continue to increase, and the
full scope of the impact to Americans is not fully known at this time. FEMA must act
immediately to provide necessary financial assistance to individuals and households in
accordance with the Consolidated Appropriations Act, 2021.
Conclusion
Following the normal clearance procedures for OMB approval to collect information during the
COVID-19 pandemic will delay FEMA’s ability to assist Americans by helping to alleviate
financial burden as a result of unexpected funeral or burial costs. As discussed, FEMA certifies
that this request meets the requirements of 5 C.F.R. § 1320.13(a) and it is vital that this revised
collection be implemented immediately because: (1) this information is essential to the mission
of the Agency, (2) this information is necessary prior to the timeframes established under the
PRA, (3) public harm will result if normal clearance procedures are followed, and (4)
unanticipated events have occurred.
The Department of Homeland Security respectfully requests your approval of FEMA’s
emergency revision to allow Call Center staff to use a current instrument in a modified manner.
Thank you for your consideration.

__________________________________________
Approve

________________________
Date

__________________________________________
Disapprove

________________________
Date

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