Signed Emergency Justification Memo

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

MEMORANDUM FOR:

Sharon Block
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
Mission Support
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 Verification of Disaster Assistance
Occupancy and Ownership.

ERIC N
HYSEN

Digitally signed by
ERIC N HYSEN
Date: 2021.08.16
15:00:20 -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 increase the types of documentation FEMA may accept from
applicants for disaster assistance to demonstrate eligibility under the Individuals and Households
Program (IHP). FEMA has recently become aware that current IHP requirements for verifying
home ownership and occupancy pose a substantial barrier to underserved populations, including
people of color and others adversely impacted by persistent poverty and inequality. These
barriers often result in underserved applicants being denied for IHP assistance when they are
unable to provide documentation verifying IHP eligibility within the current restrictions.
Emergency approval of the proposed revision to this collection is required to ensure FEMA is
able to more equitably administer IHP assistance for the ongoing large wildfires in California
and other western states as well as for major disasters that are anticipated during the peak of the
Atlantic Hurricane Season. So far in 2021, 40,090 wildfires have burned 3,893,239 acres in the
United States, according to the National Interagency Fire Center, with more than 100 fires
currently active. Record heat conditions across the United States point to the likelihood of
increased fire threat. Furthermore, the National Oceanic and Atmospheric Administration
(NOAA) predicts the 2021 hurricane season will be “above normal,” with 13 to 20 named
storms, six to 10 hurricanes, of which three to five will become major hurricanes.

OMB 1660-0002 Emergency Request in Support of Verification of Occupancy and Ownership
The combination of an increase in disaster events coupled with the ongoing impacts of the
COVID-19 pandemic, the increasing threat of the Delta variant, and fluctuating restrictions have
impacted the timely availability of essential services. This poses additional barriers to disaster
survivors by limiting their ability to obtain public and commercial records to verify their
eligibility and further underscores the need for FEMA to immediately implement alternatives to
traditional means of verifying disaster survivor IHP eligibility. For any disaster declared before
FEMA is able to accept the increased documentation options, applicants who cannot satisfy the
more limited documentation options will likely be denied assistance. This could result in the
denial of assistance to thousands of survivors if a disaster strikes before this collection revision is
approved.
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.
As a result of the continuing COVID-19 pandemic and the newly emerged Delta variant, FEMA
applicants have encountered interruptions and delays in obtaining and updating public records in
public offices. Historically, the agency has utilized a combination of public and commercial
validation of ownership and or occupancy. As a result, FEMA is expanding the documentation
applicants can submit to FEMA to establish eligibility for disaster assistance.
FEMA requests approval to accept documentation in support of proof of ownership and or
occupancy of the applicant’s primary residence within OMB Collection 1660-0002 Disaster
Assistance Registration in the following manner:
•

Applicants are currently advised through correspondence what documentation is
acceptable to provide the agency proof of ownership and or occupancy of their primary
residence. The correspondence is delivered via the preferred correspondence method
(electronic or postal mail) indicated by the applicant during the registration intake
outlining the requested documentation.

•

The applicant will also be sent a Request for Information (RFI) letter via the preferred
correspondence method (electronic or postal mail) indicated by the applicant during
registration intake 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
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OMB 1660-0002 Emergency Request in Support of Verification of Occupancy and Ownership
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,
dental, funeral, childcare, personal property, transportation, and other necessary expenses or
serious needs resulting from a major disaster.
Currently, applicants (both owners and renters) must be able to prove they occupied the disasterdamaged primary residence before receiving Housing Assistance (HA) and some types of Other
Needs Assistance (ONA), e.g. Personal Property Assistance, Moving and Storage Assistance,
and Critical Needs Assistance.
When FEMA is unable to verify an applicant’s occupancy of their disaster-damaged primary
residence or ownership of their primary residence, the applicant may provide FEMA with
documentation for occupancy verification, or to prove ownership, and documents had to be dated
within three months prior to the disaster. To provide mission-critical flexibility to disaster
survivors who will likely experience difficulty in gathering specific documents, FEMA has
expanded the types of documents we will accept from applicants to verify IHP eligibility criteria
and the extended acceptable date range for documents to include pre and post disaster where
appropriate. For the purpose of the expanded range of documents, one year prior to the disaster
means within one year prior to the start of the incident period for the declared disaster.
Documents provided to FEMA with a date within the registration period must show pre-disaster
usage, such as a phone or utility bill, or clearly show that the applicant or co-applicant resided at
the damaged dwelling at the time of the disaster.
The information collected from one of the above documents 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.
FEMA makes all attempts to validate ownership and or occupancy through automated public
records searches after the applicant completes the registration process. A secondary validation is
attempted during the agency’s verification process in which FEMA inspectors validate
ownership and or occupancy through an interview process with the applicant. Additionally, the
FEMA inspectors will attempt to validate ownership and or occupancy through public and
commercial entities.
Paperwork Reduction Act Timeframes
In order for FEMA to provide disaster-related financial assistance and services to individuals
under the Stafford Act, adhering to the standard PRA timeframe to accept verification
documentation from applicants without expanding the range of acceptable documents would
hinder FEMA’s ability to provide swift assistance to all applicable individuals and households.
For every disaster declared before the approval of this package, FEMA will have to deny
assistance to survivors who cannot prove ownership under the more limited documentation
options. There is a substantial risk of a disaster declarations daily during the Atlantic Hurricane
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OMB 1660-0002 Emergency Request in Support of Verification of Occupancy and Ownership
Season. The Atlantic Hurricane Season is currently underway and generally peaks from the end
of August through October. In addition, the COVID-19 pandemic has complicated response to
all disasters, including the ongoing wildfires in California and the western states. Disaster
response may be further complicated by the rapidly escalating Delta variant. The pandemic has
made it imperative that FEMA assist survivors to make their permanent dwellings habitable so
that survivors are not left to high density temporary housing situations where COVID-19 could
flourish. To this end, survivors should immediately be allowed to utilize the increased options to
satisfy the ownership and occupancy requirements for assistance.
Public Harm is reasonably likely to Result if Normal Clearance Procedures are followed
The effects of the COVID-19 pandemic and the Delta variant have caused an extraordinary
burden on U.S. individuals and households. If FEMA does not expand the type of
documentation it accepts from survivors to establish IHP eligibility, public harm is reasonably
likely due to unexpected delays related to the delivery of assistance to many impacted
Americans. The collection of additional types of documentation will ensure that all applicable
individuals and households who may have been burdened unexpectedly or previously
underserved have equitable access to IHP assistance.
If FEMA were required to follow the normal clearance process, it would be impossible to
implement the changes needed to address known barriers experienced by historically
underserved applicants in time for major disasters anticipated during the peak Atlantic Hurricane
Season and ongoing wildfires across the U.S.
Unanticipated Events
The effects of the COVID-19 pandemic and the Delta variant continue to impact the American
public and the scope continues to evolve while the Nation deals with recurring disasters such was
the Atlantic Hurricane Season and the western wildfires. While not all impacts are fully known
at this time, restrictions implemented throughout the country may have made it more difficult for
survivors to access or update public records. FEMA must act immediately to provide necessary
financial assistance to individuals and households in accordance with section 408 of the Stafford
Act, 42 U.S.C. 5174.

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OMB 1660-0002 Emergency Request in Support of Verification of Occupancy and Ownership
Conclusion
Following the normal clearance procedures for OMB approval to collect information during the
ever-changing environment associated with the COVID-19 pandemic and the emergence of the
Delta variant will delay FEMA’s ability to assist Americans in their disaster response and
recovery to recurring disasters such was the Atlantic Hurricane Season and the western wildfires.
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 expanding the documentation applicants can submit establishing their
eligibility for disaster assistance.
Thank you for your consideration.

__________________________________________
Approve

________________________
Date

__________________________________________
Disapprove

________________________
Date

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