Signed Emergency Memo

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

February 5, 2022

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:

Alexandra Travis
ALEXANDRA
Chief Administrative Officer TRAVIS
Mission Support
Federal Emergency Management Agency

SUBJECT:

Emergency Approval Request of Revisions to Office of Management
and Budget (OMB) Collection 1660-0061 Federal Assistance to
Individuals and Households Program

ERIC N
HYSEN

Digitally signed
by ERIC N HYSEN
Date: 2022.02.14
11:12:44 -05'00'

Digitally signed by
ALEXANDRA TRAVIS
Date: 2022.02.05 20:05:17
-05'00'

The Federal Emergency Management Agency (FEMA) seeks emergency approval from the
Office of Management and Budget (OMB) to revise information collection 1660-0061 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). 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, necessary expenses, and serious needs, and are unable to meet such
expenses or needs through other means.
On August 16, 2021, FEMA requested emergency approval to increase the types of
documentation FEMA may accept from applicants for disaster assistance to demonstrate
eligibility under the IHP during the Disaster Assistance Registration period. FEMA had become
aware that IHP requirements for verification of eligibility during registration were creating
barriers to assistance. As a result, OMB approved our expansion of documentation acceptance
during disaster assistance registration earlier this year.
Applicants who are denied following registration may appeal that decision and others regarding
assistance. As FEMA supporting documentation verification during registration has been
expanded so as not to pose barriers to underserved populations, the agency asks now to do the
same in this collection dealing almost exclusively with assistance-related appeals. Current IHP
requirements for verifying eligibility for IHP financial assistance such as, home repair and
replacement needs, essential needs and personal property assistance, pose a substantial barrier to
underserved populations, including people of color and others adversely impacted by persistent

OMB 1660-0061 Emergency Request in Support of Federal Assistance to Individuals and
Households
poverty and inequality. These barriers often result in underserved applicants being denied for
IHP assistance on appeal when they are unable to provide documentation verifying IHP
assistance cost eligibility within the current restrictions.
Emergency approval of the proposed revisions to this collection is required to ensure FEMA is
able to more efficiently administer the IHP assistance and evolve in order to more equitably
support the ongoing pandemic response and meet the historical demands of disaster response.
The ongoing impacts of the COVID-19 pandemic, in concert with the current flu season and
fluctuating restrictions have impacted the timely availability of essential services. Medical and
dental providers sometimes require applications to pay for documentation or for providers to
complete required forms. This poses additional barriers to disaster survivors by limiting their
ability to obtain personal, public, and commercial records to verify their eligibility and further
underscores the need for FEMA to rapidly implement alternatives to traditional means of
verifying disaster survivor IHP eligibility.
For any declared disaster, unless FEMA is able to accept the increased documentation options,
applicants who cannot satisfy the current and more limited documentation options will likely be
denied assistance. This could impact thousands of survivors if a disaster strikes before this
collection revision is approved. As IHP addresses disaster-related losses that are not covered by
insurance or provided by any other source, the assistance is vital to assist the most vulnerable
disaster survivors in recovering from disasters. Without the IHP assistance, applicants may find
themselves without housing or other necessities following a disaster.
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, FEMA applicants continue to encounter
interruptions and delays in obtaining and updating public records in public offices. As a result,
FEMA is expanding the documentation applicants can submit to FEMA to establish eligibility
for disaster assistance and ultimately support any efforts to appeal a FEMA assistance decision
for lack of traditional supporting documentation.
FEMA requests approval to accept written appeal letters and expanded documentation categories
in support of eligibility for and appeals in support of eligibility for IHP assistance within OMB
Collection 1660-0061 Federal Assistance to Individuals and Households Program in the
following manner:
•

FEMA relies on supporting documentation from the applicant regarding the costs of lost
items, property damage or necessary medical treatment for the award of Individuals &
Household Program assistance. Without this information FEMA cannot determine the
applicant’s need and provide assistance which may prevent applicants from receiving
needed medical care or leave them with medical debt that hinders their disaster recovery.

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OMB 1660-0061 Emergency Request in Support of Federal Assistance to Individuals and
Households
•

As it is difficult to determine the degree of damage and cost in home repair and
replacement assistance, FEMA provides initial funds for the cost of a licensed
technician’s professional assessment associated with the repair or replacement of these
components and applicants may appeal with supporting documentation to include receipts
or estimates of the cost to repair the disaster damage to these specific items.

•

In support of Housing Assistance and some forms of Other Needs Assistance (ONA),
FEMA must collect documentation that identifies an applicant’s insurance settlements or
benefits, to include denials, to ensure FEMA assistance is being provided in accordance
with our authorities. FEMA may not duplicate benefits, to include insurance, and may
only provide assistance for uninsured losses. Some forms of applicable insurance include
homeowner’s insurance, flood insurance, renter’s insurance, medical insurance, and
burial insurance.

•

Applicants must verify the need and the disaster related nature of a disability. FEMA
collects a, itemized bill, receipt, or estimate for the accessibility-related item(s) and
installation or construction costs, and a written and signed statement from a medical or
health care provider, indicating the contact information of the medical provider, the date
of the disability, injury, or illness. disability, injury, or illness, confirmation the disability
limits one or more major life activity (i.e., seeing, walking, hearing, respiration, bending,
etc.), that the disability was caused by the disaster, and that the accessibility-related
structural modification (i.e., exterior ramp, grab bar, and/or accessible path of travel to
the residential entrance) of the dwelling is required to meet the household’s access and
functional need. Accessible temporary housing is always in limited supply and so
assistance that allows applicants with disabilities to more quickly return to their own
home which meets their accessibility needs is vital in supporting the recovery needs of
this vulnerable population.

1. 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 ONA provision of the 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 not covered by insurance or provided
by any other source.

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OMB 1660-0061 Emergency Request in Support of Federal Assistance to Individuals and
Households
The emergency revisions for this collection relate to FEMA’s financial assistance under the
ONA provision of the IHP to individuals and households with home and work-related expenses
as well as medical or dental expenses caused by a disaster. To provide additional flexibility to
disaster survivors who may experience difficulty in gathering specific documents, FEMA has
expanded the types of documents we will accept from applicants to verify criteria on appeal.
Applicants may submit a written appeal if they disagree with any FEMA determination. Per
FEMA’s regulations, an appeal must be in writing and explain the reason for the appeal and be
signed by the person submitting the appeal. If someone other than applicant files submit signed
statement giving that person authority to represent that applicant. By policy, FEMA requests
appeals also include supporting documentation, such as repair bills and estimates that include the
business or entities’ name and phone number. This additional information assists FEMA in
validating the applicant’s additional need without requiring FEMA to inspect the applicant’s
home again, in some instances. This documentation also helps minimize payments for
fraudulent requests. Lastly, while not required, FEMA suggests applicants include the following
information in their appeal, the applicant’s full name, FEMA application number, disaster
number, current address and phone number, and pre-disaster primary residence address. The
information collected from 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. The personally identifiable information requested assists
FEMA in placing the incoming documentation into the correct applicant file in NEMIS.
Any person who incurs disaster-caused medical or dental expenses may apply for and, if eligible,
receive Medical and Dental Assistance. FEMA relies on supporting documentation from the
applicant regarding the costs of the lost items or necessary treatment, applicable insurance
coverage, a written statement from the medical or dental provide identifying the loss or treatment
as disaster-caused and medically necessary. Without this information FEMA cannot determine
the applicant’s need or provide assistance which may prevent applicants from receiving needed
medical care or leave them with medical debt that hinders their disaster recovery.
FEMA also provides assistance for essential tools lost or damaged due to the disaster under
ONA. Essential tools include uninsured losses for tools and items, such as computers, required
for employment or education and not supplied by the employer or school. In order to determine
the applicant’s need and verify the losses were disaster related, FEMA collects the following
documents when applicable; a statement from the employer on company letterhead documenting
the applicant is required to provide their own tools or computer as a condition of employment,
including an itemized list of the tools required by the employer, a statement on school letterhead
documenting a computer is required as a condition of education and the school does not provide
access to computers to use outside of class, such as a school computer lab, an itemized receipt,
estimate, or bill for repair or replacement of the disaster-damaged items, and a written statement
signed by the applicant verifying that the items were disaster-damaged and the following
statement, “I hereby declare under penalty of perjury that the foregoing is true and correct.” It is
vital that applicants return to their jobs with all necessary items to minimize disaster impacts on
applicant’s income and support their individual recovery goals.

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OMB 1660-0061 Emergency Request in Support of Federal Assistance to Individuals and
Households
FEMA’s Home Replacement Assistance may provide financial assistance to owners whose
primary residences were destroyed as a result of a Presidentially declared disaster. Similarly,
FEMA’s Home Repair Assistance seeks to support low income and other vulnerable disaster
survivors who may not have the means to immediately address disaster damage by increasing the
amount of assistance FEMA’s Home Repair Assistance provides for repairs. The IHP recently
expanded this assistance to allow for disaster caused damage-related repair assistance for utilities
such as wells, furnaces and septic systems where local ordinances require repair or construction
of the same. In some instances, FEMA may determine a home repairable, but further disaster
damage or other factors may ultimately lead the home to be condemned. Applicants appealing
for additional funds may provide documentation such as a notice of condemnation for demolition
and removal, a letter of substantive damage, or a notice of demolition to support their claim their
home is destroyed due to the disaster. This supporting documentation helps speed FEMA’s
review and consideration of the appeal by providing third party information on the state of the
applicant’s home due to the disaster.
Upon appeal, eligible applicants may receive assistance up to actual cost when funds are
available under their Housing Assistance maximum. Without heat in the winter or reliable, clean
water for a home, an applicants’ home is not considered habitable, and they must remain in a
temporary housing situation further delaying disaster recovery and utilizing the often-limited
housing resources in the impacted area.
2. 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 eligibility for IHP financial assistance under the more
limited documentation options. There is a substantial risk of a disaster declarations daily during
the current Hurricane Season and the approaching winter storm season. FEMA recently
expanded disaster assistance registration access: FEMA believes this will yield an increase in
appeals that beg the approval of additional supporting documentation allowable on appeal. In
addition, the COVID-19 pandemic has complicated response to all disasters, including the
ongoing wildfires in California and the western states. Disaster response has been further
complicated by international delays in shipping and the implementation of vaccine mandates.
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.

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OMB 1660-0061 Emergency Request in Support of Federal Assistance to Individuals and
Households
3. Public Harm is reasonably likely to Result if Normal Clearance Procedures are
followed
Earlier this year, the Washington Post published a series of articles highlighting the struggle
underserved applicants experience meeting FEMA’s documentation requirements for appeals
and ownership documentation. In response, FEMA expanded the types of documents and the
acceptable dates on the documents that may be used to prove ownership and occupancy during
disaster assistance registration. For those initially denied aid for failure to meet assistance
eligibility elements, the Stafford Act requires the filing or receipt of an appeal to FEMA within
60 days of their decision letter awarding or denying the assistance request. This can be
challenging for applicants working to recover from a disaster, who are often left with lost or
damaged paperwork in the aftermath.
If FEMA does not expand the type of supporting documentation it accepts in support of appeals
for IHP’s crucial financial assistance from survivors, following an earlier approval of the
expansion of supporting documentation during registration, public harm is reasonable 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. The effects of the
COVID-19 pandemic and the Delta and Omicron variants have caused an extraordinary burden
on U.S. individuals and households. Finally, the country is already experiencing winter storms,
and crucial assistance related to extreme winter weather is necessary once more.
4. 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 as
the Atlantic Hurricane Season, winter storm 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’s earlier effort to
expand access to the IHP program through supporting documentation was an unanticipated but
welcome administration priority. The instant request is a logical outgrowth of that earlier move
toward accessibility and equity in the delivery of IHP assistance. 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 1660-0061 Emergency Request in Support of Federal Assistance to Individuals and
Households
Conclusion
Following the normal clearance procedures for OMB approval to collect information during the
ever-changing environment associated with the COVID-19 pandemic and Delta and Omicron
variants will delay FEMA’s ability to assist Americans in their disaster response and recovery to
recurring disasters such as extreme winter weather 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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