FEDERAL DISASTER 

ASSISTANCE

Individual Assistance 

Requests Often 

Granted, but FEMA 

Could Better 

Document Factors 

Considered

Report to Congressional Requesters

May 2018

GAO-18-366

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-366, a report to 

congressional requesters

May 2018

FEDERAL DISASTER ASSISTANCE 

Individual Assistance Requests Often Granted, but 

FEMA Could Better Document Factors Considered

What GAO Found

From calendar years 2008 through 2016, the Department of Homeland Security’s 

(DHS) Federal Emergency and Management Agency (FEMA) received 294 

Individual Assistance (IA) declaration requests from states, U.S. territories, and 

tribes to help individuals meet their immediate needs after a disaster. Of these, 

the President declared 168 and denied 126 requests. Across the various types of

IA declaration requests, severe storms (190) were the most common disaster 

type and drought (1) was among the least common. FEMA obligated about $8.6 

billion in IA for disaster declarations during this period. 

GAO found that FEMA regions did not consistently obtain and document 

information on all elements of established IA regulatory factors when making IA 

recommendations to headquarters. Following a declaration request, a FEMA 

region is to prepare a Regional Administrator’s Validation and Recommendation 

(RVAR)—a document designed to include data on each of the six IA regulatory 

factors for each declaration request as well as the regional administrator’s 

recommendation. GAO reviewed all 81 RVARs from July 2012—the date FEMA 

began using the new RVAR template—through December 2016. GAO found that 

regions did not consistently obtain and document information for the elements 

required under the six regulatory factors (see table). For example, only 44 of the 

81 RVARs documented all elements under the concentration of damage factor. 

By evaluating why regions are not completing all elements of each current IA 

regulatory factor, FEMA could identify whether any corrective steps are needed. 

Analysis of 81 Regional Administrator’s Validation and Recommendations by Element for 

Each Individual Assistance (IA) Regulatory Factor Documented from July 2012 through 

December 2016

IA Regulatory Factor 

All elements 

documented

Some elements 

documented

No elements 

documented

Concentration of damages 44 37 0

Trauma 30 51 0

Special populations 72 8 1

Voluntary agency assistance 76 5 0

Insurance coverage 5 73 3

Average amount of IA by state 11 66 4

Source: GAO analysis based of Federal Emergency Management Agency’s Regional Administrator’s Validation and 

Recommendations. I GAO-18-366

Officials from the 10 FEMA regions and 11 states GAO interviewed, reported 

positive relationships with each other, but also cited various challenges with the 

IA declaration process and regulatory factors. For example, these officials told 

GAO that there are no established minimum thresholds for IA, making final 

determinations more subjective and the rationale behind denials unclear. 

However, as required by the Sandy Recovery Improvement Act of 2013, FEMA

has taken steps to revise the IA factors by issuing a notice of proposed 

rulemaking. According to FEMA, the proposed rule aims to provide more 

objective criteria, clarify the threshold for eligibility, and speed up the IA 

declaration process. As of April 2018, the proposed rule was still under 

consideration. According to FEMA officials, they plan to finalize the rule in late 

2018; therefore, it is too early to know the extent to which it will address these 

challenges.

View GAO-18-366. For more information, 

contact Chris P. Currie at (404) 679-1875 or 

curriec@gao.gov.

Why GAO Did This Study

FEMA’s IA program provides help to 

individuals to meet their immediate 

needs after a disaster, such as shelter

and medical expenses. When a state, 

U.S. territory, or tribe requests IA 

assistance through a federal disaster 

declaration, FEMA evaluates the 

request against regulatory factors, 

such as concentration of damages,

and provides a recommendation to the 

President, who makes a final 

declaration decision. 

GAO was asked to review FEMA’s IA 

declaration process. This report 

examines (1) the number of IA 

declaration requests received, 

declared, and denied, and IA actual 

obligations from calendar years 2008 

through 2016, (2) the extent to which 

FEMA accounts for the regulatory 

factors when evaluating IA requests, 

and (3) any challenges FEMA regions 

and select states reported on the 

declaration process and factors and 

any FEMA actions to revise them.

GAO reviewed FEMA’s policies, IA 

declaration requests and obligation 

data, and FEMA’s RVARs from July 

2012 through December 2016, the 

most recent years for which data were 

available. GAO also reviewed 

proposed rulemaking comments and 

interviewed FEMA officials from all 10 

regions and 11 state emergency 

management offices selected based on 

declaration requests and other factors. 

What GAO Recommends

GAO recommends that FEMA evaluate 

why regions are not completing the 

RVARs for each element of the current 

IA regulatory factors and take 

corrective steps, if necessary. DHS 

concurred with the recommendation.
Page i GAO-18-366 FEMA Individual Assistance Factors

Letter 1

Background 5

The President Declared 57 Percent of All IA Requests from 2008 

through 2016, with Total Obligations of Approximately $8.6 

Billion 11

FEMA Regions Varied in How They Considered IA Regulatory 

Factors and Did Not Consistently Obtain and Document 

Information on All Elements of These Factors 18

FEMA and States Reported Challenges in the IA Declaration 

Process, and FEMA Is Revising the Regulatory Factors Used to 

Assess Declaration Requests 22

Conclusions 27

Recommendation for Executive Action 28

Agency Comments and Our Evaluation 28

Appendix I Individual Assistance Declarations Requested, Declared, and Denied, 

Calendar Years 2008-2016 30

Appendix II Individual Assistance Actual Obligations for Declarations Made, 

Calendars Years 2008-2016 33

Appendix III Regional Administrator’s Validation and Recommendation Template 43

Appendix IV Information on the Elements of the Six Individual Assistance 

Regulatory Factors 50

Appendix V Comments from the Department of Homeland Security 53

Appendix VI GAO Contact and Staff Acknowledgments 56

Contents
Page ii GAO-18-366 FEMA Individual Assistance Factors

Tables

Table 1: Average Amount of Individual Assistance per Disaster by 

Size of State Contained in 44 C.F.R. § 206.48(b)(6) (July 

1994 to July 1999) 10

Table 2: Information on Individual Assistance (IA) Requests and 

Declarations by Federal Emergency Management Agency 

(FEMA) Region from Calendar Years 2008 through 2016 11

Table 3: Number of Individual Assistance (IA) Declarations Denied 

by Federal Emergency Management Agency (FEMA) 

Region from Calendar Years 2008 through 2016 12

Table 4: Information on Individual Assistance (IA) Declarations 

Requests by Type of Disaster from Calendar Years 2008 

through 2016 13

Table 5: Actual Obligations of Individual Assistance by State for 

Disaster Declarations Made from Calendar Years 2008 

through 2016 16

Table 6: Analysis of 81 Regional Administrator’s Validation and 

Recommendations (RVAR) by Element Pertaining to Each 

Individual Assistance (IA) Regulatory Factor Documented 

from July 2012 through December 2016 20

Table 7: Example of Regional Administrator’s Validation and 

Recommendations Information on the Individual 

Assistance Regulatory Factors for Four States Affected by 

the Same Disaster in 2012 23

Table 8: Federal Emergency Management Agency’s (FEMA) 

Description of Current and Proposed Individual 

Assistance Regulatory Factors 26

Table 9: Individual Assistance Requested, Declared, and Denied, 

by Region, State, and Tribe for Disaster Declarations 

Requested from Calendar Years 2008 through 2016a 30

Table 10: Federal Emergency Management Agency’s Individual 

Assistance (IA) Actual Obligations by State and Type of 

Disaster for Declarations Made from Calendar Years 2008 

through 2016 34

Table 11: Information on Concentration of Damages by Element 

Found in Regional Administrator’s Validation and 

Recommendation (RVAR) from July 2012 through 

December 2016 50

Table 12: Information on Trauma by Element Found in Regional 

Administrator’s Validation and Recommendation (RVAR) 

from July 2012 through December 2016 50
Page iii GAO-18-366 FEMA Individual Assistance Factors

Table 13: Information on Special Populations by Element Found in 

Regional Administrator’s Validation and Recommendation 

(RVAR) from July 2012 through December 2016 51

Table 14: Information on Voluntary Assistance by Element Found 

in Regional Administrator’s Validation and 

Recommendation (RVAR) from July 2012 through 

December 2016 51

Table 15: Information on Insurance Coverage Found in Regional 

Administrator’s Validation and Recommendation (RVAR) 

from July 2012 through December 2016 51

Table 16: Information on Average Amount of Individual Assistance 

by State Found in Regional Administrator’s Validation and 

Recommendations (RVAR) from July 2012 through 

December 2016 52

Figures

Figure 1: Federal Emergency Management Agency’s (FEMA) 

Major Disaster Declaration Process 7

Figure 2: Federal Emergency Management Agency’s (FEMA) 

Individual Assistance (IA) Actual Obligations by Regions 

for Disaster Declarations Made from Calendar Years 

2008 through 2016 15

Figure 3: Federal Emergency Management Agency’s (FEMA) 

Regional Administrator’s Validation and 

Recommendation Template 44

Abbreviations

DHS Department of Homeland Security

FEMA Federal Emergency Management Agency

IA Individual Assistance 

RVAR Regional Administrator’s Validation and Recommendation

Stafford Act Robert T. Stafford Disaster Relief and Emergency

Assistance Act

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-18-366 FEMA Individual Assistance Factors

441 G St. N.W.

Washington, DC 20548

May 31, 2018

The Honorable Kevin McCarthy

Majority Leader

House of Representatives

The Honorable Dianne Feinstein

United States Senate

Natural disasters in 2017, such as the California wild fires and the Atlantic 

hurricane season, affected approximately 25.8 million people in the 

United States—nearly 8 percent of the U.S. population. As a result of 

these disasters, 4.7 million individuals applied for assistance in 2017 from 

the Federal Emergency Management Agency (FEMA) through its 

Individual Assistance (IA) program, which provides help to individuals and 

families to meet their immediate needs, shelter, and medical needs in the 

wake of a disaster. FEMA provided more than $2 billion in IA funds in 

response to these disasters. FEMA is a component of the Department of 

Homeland Security (DHS) that leads the federal effort to prepare, respond 

to, and help recover from disasters, both natural and man-made. 

Following a major disaster declaration by the President, FEMA may 

provide three principal forms of assistance.1 These include IA; Public 

Assistance, which addresses repairs to communities’ and states’

infrastructure; and Hazard Mitigation Assistance, which provides funding 

for projects a state submits to reduce the threat of future damage.

To obtain federal disaster assistance, a state or tribe must request a 

disaster declaration through FEMA (IA declaration), and then FEMA 

 1

In response to a request from a governor of a state or the chief executive of an affected 

Indian tribal government, the President may declare that a major disaster or emergency 

exists. 42 U.S.C. §§ 5170, 5191. If the President declares an emergency, rather than a 

major disaster, the federal government may provide immediate and short-term assistance 

that is necessary to save lives, protect property and public health and safety, or lessen or 

avert the threat of a catastrophe, among other things. 42 U.S.C. § 5192. Federal 

assistance may not exceed $5 million under an emergency declaration unless continued 

emergency assistance is immediately required; there is a continuing and immediate risk to 

lives, property, public health or safety; and necessary assistance will not otherwise be 

provided on a timely basis. 42 U.S.C. § 5193. Additionally, upon the request of a governor, 

the President may issue a fire assistance declaration that provides financial and other 

assistance to supplement state and local firefighting resources for fires that threaten 

destruction that might warrant a major disaster declaration. 44 C.F.R. § 204.21. Hereafter 

in this report, major disaster declarations are referred to as disaster declarations.

Letter
Page 2 GAO-18-366 FEMA Individual Assistance Factors

determines whether to make a recommendation to the President to 

declare a major disaster.2 In reviewing the state or tribe’s IA disaster 

declaration request, FEMA is to consider six primary factors, established 

in regulation in 1999, to determine the severity, magnitude, and impact of 

a disaster event.3 These IA regulatory factors include: (1) concentration of 

damages (e.g., homes destroyed); (2) trauma (e.g., injuries and death); 

(3) special populations (e.g., elderly and disabled); (4) voluntary agency 

assistance; (5) insurance coverage; and (6) average amount of individual 

assistance by state. After Hurricane Sandy, Congress passed the Sandy 

Recovery Improvement Act of 2013 to improve certain aspects of disaster 

assistance, and the act directed FEMA to review, update, and revise the 

IA factors in order to provide more objective criteria, clarify the threshold 

for eligibility, and speed the IA declaration process.4

You asked us to review the IA declaration process and regulatory factors 

along with FEMA’s proposed changes to the factors. This report 

examines (1) the number of IA declaration requests received, declared, 

and denied, including the types of disasters and related obligations for IA 

major disaster declarations from calendar years 2008 through 2016; (2) 

the extent to which FEMA accounts for the six IA factors when evaluating 

state and tribal IA declaration requests; and (3) what challenges, if any, 

FEMA regions and selected states report regarding the factors used in 

the IA declaration process, and what actions, if any, FEMA has taken to 

revise these factors.

To answer our first objective, we reviewed FEMA policies and 

procedures, regulations, and internal documents related to the IA disaster 

declaration process such as FEMA’s guidance on the process, manual on 

damage assessment, and fact sheets on IA programs. We obtained and 

analyzed data from FEMA’s systems for disaster declaration requests 

made by states and tribal entities; and IA actual obligations for 

declarations made from calendar years 2008 through 2016, the most 

 2

Throughout this report, and in accordance with the Stafford Act, “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. See 42 

U.S.C. § 5122(4).

3

44 C.F.R. § 206.48(b).

4

Pub. L. No. 113-2, § 1109, 127 Stat. 4, 47 (2013). 
Page 3 GAO-18-366 FEMA Individual Assistance Factors

recent data available at the beginning of our review.5 To assess the 

reliability of these data, we reviewed the data and discussed data quality 

control procedures with FEMA officials. We determined that the data we 

used from these systems were sufficiently reliable for the purposes of this 

report.

To answer our second objective, we reviewed relevant laws, FEMA 

policies and procedures, regulations, guides, memoranda, internal 

documents, and other documents related to the IA disaster declarations 

process, including the current IA factors established in regulation. We 

reviewed and analyzed the completeness of all 81 FEMA nonemergency 

and nonexpedited Regional Administrator’s Validation and 

Recommendations (RVAR) prepared from July 2012 through December 

2016, the most recent years for which data were available at the time of 

our review.6 We excluded emergency and expedited disaster declaration 

requests because such requests are not required to include all the 

information related to the regulatory factors. We did not include RVARs 

prepared prior to July 2012, after FEMA updated its RVAR guidance and 

training and began recommending the use of a new RVAR template in 

order to help ensure consistency across regions.7 We also obtained a 

copy of the RVAR template, which we determined contained 28 elements, 

most of which pertain to the six IA factors identified in the regulation.8 We 

 5

We requested data on disaster declaration requests, including IA requests, from FEMA’s 

National Emergency Management Information System and IA actual obligations from 

FEMA’s Integrated Financial Management Information System.

6

RVAR is a document submitted by the FEMA regional administrator to FEMA 

headquarters, comprising a state’s or tribe’s disaster declaration request, information on 

the IA regulatory factors compiled through regional assessments of the request, and the 

regional administrator’s validation and recommendation regarding the request.

7

FEMA staff began using the RVAR template for events occurring June 13, 2012, or later. 

As such, we limited our review of the RVARs from July 1, 2012 in order to analyze 

consistent data.

8

See 44 C.F.R. 206.48(b). The elements identified in FEMA’s RVAR template include: (1) 

total estimated federal obligation, (2) recent disasters in the same area in the past/within 

12 months, (3) damage to critical facilities, (4) hazard mitigation measures, (5) impact and 

frequency of prior disasters, (6) level of volunteer assistance, (7) other federal assistance 

available, (8) trauma-death, (9) trauma-injury, (10) trauma-power outage, (11) traumadisruption of community functions/services, (12) damage concentration, (13) homes 

destroyed, (14) homes with major damage, (15) homes with minor damage, (16) homes 

affected, (17) home ownership, (18) insurance, (19) flood insurance, (20) low income, (21) 

median household income, (22) poverty, (23) disabled, (24) elderly, (25) Small Business 

Administration loans, (26) resident loans, (27) Small Business Administration number of 

loans, and (28) resident number of loans.
Page 4 GAO-18-366 FEMA Individual Assistance Factors

used these elements to analyze the 81 RVARs to determine if information 

on the IA regulatory factors were obtained and documented. We 

interviewed officials from FEMA headquarters and all 10 FEMA regions 

on their consideration of the IA regulatory factors and development of the 

RVARs. We also compared the 81 RVARs to Standards for Internal 

Control in the Federal Government.

9 To assess the reliability of the 

RVARs, we reviewed and analyzed the RVARs that FEMA officials 

provided and discussed quality control procedures with them. We 

determined that the information we used from the RVARs was sufficiently 

reliable for the purposes of this report.

To answer our third objective, we reviewed relevant laws and FEMA 

policies and procedures, notices, regulations, and guidance related to the 

IA disaster declaration process and FEMA’s proposed rulemaking, which 

proposes revisions to the current six IA regulatory factors. We interviewed 

officials from all 10 FEMA regions, FEMA headquarters officials, and 

state-level emergency management officials in 11 states to discuss their 

perspectives on the IA declaration process and current regulatory factors, 

any associated challenges, and their perspectives on the proposed 

changes to the current IA regulatory factors. We selected the 11 states 

based on those that have undergone multiple IA requests from calendar 

years 2008 through 2016 and those that have experienced various types 

of disasters in different regions of the country. We selected California, 

Illinois, Indiana, Kentucky, Mississippi, Missouri, New York, Ohio, 

Oklahoma, South Dakota, and Virginia. We made three site visits to 

obtain more detailed information on the IA declaration processes. We 

visited FEMA regions IX and V, and spoke with regional FEMA officials, 

as well as with emergency management officials for the states of 

California and Illinois. We also visited region IV and we spoke with FEMA 

officials for that region. We chose these locations to obtain examples and 

experiences across a wide variety of disaster types and regions. The 

information gathered during these site visits is not generalizable to other 

states or regions, but the details provide insights regarding FEMA’s and 

states’ management of these processes. We also reviewed and 

summarized the 14 public comments states submitted on FEMA’s 

proposed rulemaking that proposes changes to the current IA regulatory 

factors.

 9

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).
Page 5 GAO-18-366 FEMA Individual Assistance Factors

We conducted this performance audit from January 2017 to May 2018 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

finding and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The Robert T. Stafford Disaster Relief and Emergency Assistance Act 

(Stafford Act), as amended, establishes the process for states or tribal 

entities to request a presidential disaster declaration.10 The act also 

generally defines the federal government’s role during the response and 

recovery after a disaster and establishes the programs and process 

through which the federal government provides disaster assistance to 

state, local governments, tribal entities and individuals.11 In addition to its 

central role in recommending to the President whether to declare a 

disaster, FEMA has primary responsibility for coordinating the federal 

response when a disaster is declared as well as recovery, which typically 

consists of providing grants to assist state and tribal entities to alleviate 

the damage resulting from such disasters. Once a disaster is declared, 

FEMA provides assistance through the IA, Public Assistance, and Hazard 

Mitigation Assistance programs. For instance, some declarations may 

provide grants only for IA and others only for Public Assistance. Hazard 

Mitigation Assistance grants, on the other hand, are available for all 

declarations if the affected area has a FEMA-approved Hazard Mitigation 

plan. The process for requesting assistance is the same for the three 

types of assistance.

Under the Stafford Act, states’ governors or tribal chief executives may 

request federal assistance, if state and tribal resources are overwhelmed 

after a disaster.12 As part of the request to the President, a governor or 

tribal chief executive must affirm that the state or tribe has implemented 

an emergency plan and that the situation is of such severity and 

magnitude that effective response is beyond the capabilities of the state 

 10Pub. L. No. 93-288, 88 Stat. 143 (codified as amended at 42 U.S.C. § 5121 et seq.).

11See generally 42 U.S.C. § 5121 et seq. 

12See 42 U.S.C. § 5170. 

Background

Disaster Declaration 

Process
Page 6 GAO-18-366 FEMA Individual Assistance Factors

or tribal entity, among other things. After a state or tribe submits a request 

for disaster declaration through FEMA’s regional office, the regional office 

is to evaluate the request and make a regional recommendation through 

the RVAR, which is submitted to FEMA headquarters for further review. 

The FEMA administrator then is to review the state’s or tribe’s request 

and the RVAR, and recommend to the President whether a disaster 

declaration is warranted. Figure 1 shows the process for a disaster 

declaration from the time a disaster occurs until the President approves or 

denies a declaration request.
Page 7 GAO-18-366 FEMA Individual Assistance Factors

Figure 1: Federal Emergency Management Agency’s (FEMA) Major Disaster Declaration Process
Page 8 GAO-18-366 FEMA Individual Assistance Factors

The IA program provides financial and direct assistance to disaster 

victims for expenses and needs that cannot be met through other means, 

such as insurance. The IA comprises five different programs as shown 

below. When states or tribal entities request disaster declarations, they 

may request assistance under any or all of the five programs. Likewise, 

when the President makes a disaster declaration, the declaration may 

authorize IA which may also include any or all of the five IA programs.

1. Individuals and Households Program provides assistance to 

eligible disaster survivors with necessary expenses and serious needs 

which they are unable to meet through other means, such as 

insurance.13 According to FEMA headquarter officials, direct 

assistance is provided to individuals to meet housing needs.

2. Crisis Counseling Program assists individuals and communities by 

providing community-based outreach and psycho-educational 

services.14

3. Disaster Legal Services provides assistance through an agreement 

with the Young Lawyers Division of the American Bar Association for 

free legal help to survivors who are unable to secure legal services 

adequate to meet their disaster-related needs.15

4. Disaster Case Management Program involves a partnership 

between a FEMA disaster case manager and a survivor to develop 

and carry out a Disaster Recovery Plan.16

5. Disaster Unemployment Assistance provides unemployment 

benefits and reemployment services to individuals who have become 

unemployed as a result of a major disaster and who are not eligible 

for regular state unemployment insurance.17

In accordance with its responsibilities under the Stafford Act, FEMA 

issued a regulation in 1999 that outlines the six factors regional and 

headquarters officials are to consider when assessing requests for a 

disaster declaration and when developing a recommendation to the 

 13See 42 U.S.C. § 5174; 44 C.F.R. §§ 206.110-206.120.

14See 42 U.S.C. § 5183; 44 C.F.R. § 206.171.

15See 42 U.S.C. § 5182; 44 C.F.R. § 206.164.

16See 42 U.S.C. § 5189d.

17See 42 U.S.C. §5177; 44 C.F.R. § 206.141. 

Five Programs Available 

under Individual 

Assistance

The Six IA Regulatory 

Factors Used to Assess IA 

Declaration Requests
Page 9 GAO-18-366 FEMA Individual Assistance Factors

President for a federal disaster declaration.18 The regulation states that 

FEMA considers the six factors not only to evaluate the need for IA but 

also to measure the severity, magnitude, and impact of the disaster. The 

state or tribe provides information on these factors when submitting its 

disaster declaration request. The six factors for IA include the following:

1. Concentration of Damages—characterizes the density of the 

damage in individual communities. The regulation states that highly 

concentrated damages “generally indicate a greater need for federal 

assistance than widespread and scattered damages throughout a 

state.” For example, concentration of damage data includes the 

numbers of homes destroyed, homes with major or minor damages, 

and homes affected.

2. Trauma—the regulation provides conditions that might cause trauma 

including large numbers of injuries and deaths, large-scale disruption 

of normal community functions, and emergency needs such as 

extended loss of power or water.

3. Special Populations—FEMA considers the impact of the disaster on 

special populations, such as low-income populations, the elderly, or 

the unemployed.

4. Voluntary Agency Assistance—involves the availability and 

capabilities of voluntary, faith, and community-based organizations, 

and state and local programs to help meet both the emergency and 

recovery needs of individuals affected by disasters.

5. Insurance Coverage—addresses the level of insurance coverage 

among those affected by disasters.19 Because disaster assistance 

cannot duplicate insurance coverage, as recognized in the regulation, 

if a disaster occurred where almost all of the damaged dwellings were 

fully insured for the damage that was sustained, FEMA could 

 1844 C.F.R. § 206.48(b); see also 42 U.S.C. § 5170. Consistent with 42 U.S.C. § 5170, as 

amended by the Sandy Recovery Improvement Act of 2013, the Governor of an affected 

state or the Chief Executive of an affected Indian tribal government may submit a request 

for a declaration. See Pub. L. No. 113-2, § 1110, 127 Stat. 4, 48 (codified as amended at 

42 U.S.C. §§ 5170, 5191, 5122).

19By law, federal disaster assistance cannot duplicate insurance coverage. See 42 U.S.C. 

§ 5155; 44 C.F.R. § 206.48(b)(5). 
Page 10 GAO-18-366 FEMA Individual Assistance Factors

conclude that a disaster declaration by the President was not 

necessary in accordance with this factor.20

6. Average Amount of Individual Assistance by State—according to 

the regulation, there is no set threshold for recommending IA. 

However, it states that the averages, depicted in table 1, may prove 

useful to states and voluntary agencies as they develop plans and 

programs to meet the needs of disaster victims. The inference is that 

these averages generally indicate the amount of damages that could 

be expected for a state based on its size (small, medium, and large). 

The averages contained within the regulation and depicted in table 1 

are based on disasters that occurred between July of 1994 and July of 

1999.21

Table 1: Average Amount of Individual Assistance per Disaster by Size of State Contained in 44 C.F.R. § 206.48(b)(6) (July 

1994 to July 1999)

Small states 

(under 2 million 

population)

Medium states (2-10 

million population)

Large states (over 

10 million 

population)

Average population (1990 census data) 1,000,057 4,713,548 15,522,791

Number of Disaster Housing applications approved 1,507 2,747 4,679

Number of homes estimated major damage/destroyed 173 582 801

Dollar amount of housing assistance ($) 2.8 million 4.6 million 9.5 million

Number of Individual and Family Grant applications approved 495 1,377 2,071

Dollar amount of Individual and Family Grant assistance ($) 1.1 million 2.9 million 4.6 million

Disaster Housing/Individual and Family Grant combined 

assistance ($)

3.9 million 7.5 million 14.1 million

Source: 44 C.F.R. § 206.48(b)(6). I GAO-18-366

 20This provision does not necessarily result in delayed assistance. FEMA is able to 

provide help to individuals and households that have disaster damages but are waiting on 

insurance or other assistance for help. Those applicants can receive FEMA help as long 

as they agree to reimburse FEMA when they receive their other assistance. See 44 C.F.R. 

§ 206.113(a)(3).

21FEMA headquarters officials stated that the table titled “Average Amount of Assistance 

per Disaster by Size of State” contained within 44 C.F.R. § 206.48(b)(6) is considered 

outdated and is no longer relevant to the declaration process. FEMA officials indicated 

that to satisfy the factor of average amount of IA assistance by state they evaluate the 

total number of homes destroyed and suffering major damage (as well as the accessibility 

and habitability of the dwellings and the community).
Page 11 GAO-18-366 FEMA Individual Assistance Factors

The President declared 57 percent of all IA declaration requests from 

calendars years 2008 through 2016, with total IA obligations of 

approximately $8.6 billion. FEMA received 294 IA declaration requests 

from calendar years 2008 through 2016. Of these, the President declared 

168 requests (57 percent), and 51 percent of these declarations were 

from Regions IV and VI, as shown in table 2.22

Table 2: Information on Individual Assistance (IA) Requests and Declarations by 

Federal Emergency Management Agency (FEMA) Region from Calendar Years 2008 

through 2016

Region IA Requested IA Declared Percentage Declared 

(%)

I 15 13 87

II 18 10 56

III 26 13 50

IV 69 53 77

V 32 16 50

VI 59 32 54

VII 25 13 52

VIII 18 8 44

IX 18 6 33

X 14 4 29

Total 294 168 57

Source: GAO analysis of FEMA data. I GAO-18-366

 22Information on the composition of the FEMA regions by state or tribe related to the IA 

declaration requests is found in appendix I of this report.

The President 

Declared 57 Percent 

of All IA Requests 

from 2008 through 

2016, with Total 

Obligations of 

Approximately $8.6 

Billion

The Number of IA 

Declarations Varied by 

Region and Severe 

Storms Were the Most 

Frequent Disaster Type
Page 12 GAO-18-366 FEMA Individual Assistance Factors

Additionally, of the 126 IA declaration requests denied by the President, 

Regions X and IX had the highest percentage of denials, at 71 percent 

(10 out of 14) and 67 percent (12 out of 18), respectively, and Region I 

had the lowest percentage of denials at 13 percent (2 out of 15), as 

shown in table 3. See appendix I for the number of IA declarations 

requested, declared, and denied by states and tribes from each FEMA 

region for disaster declarations requested from calendar years 2008 

through 2016.

Table 3: Number of Individual Assistance (IA) Declarations Denied by Federal 

Emergency Management Agency (FEMA) Region from Calendar Years 2008 through 

2016

Region IA Requested IA Denied Percentage Denied (%)

X 14 10 71

IX 18 12 67

VIII 18 10 56

III 26 13 50

V 32 16 50

VII 25 12 48

VI 59 27 46

II 18 8 44

IV 69 16 23

I 15 2 13

Total 294 126 43

Source: GAO analysis of FEMA data. I GAO-18-366

According to a FEMA headquarters official, when a disaster declaration is 

denied, FEMA sends a denial letter to states or tribes based on the 

review of all the information available. The letter generally states that the 

damage was not of such severity and magnitude as to be beyond the 

capabilities of the state, affected local governments, and voluntary 

agencies, and accordingly the supplemental federal assistance is not 

necessary. Of the emergency management officials we interviewed in 11 

states, officials in five states reported that FEMA provided a rationale 

behind the denial, while officials in three states reported that no rationale 

was provided.23

 23The other 3 state emergency officials did not provide any comments on the rationale 

behind denied IA declaration requests in their state.
Page 13 GAO-18-366 FEMA Individual Assistance Factors

Among the various types of disasters for which IA declaration requests 

were received, severe storms, flooding, and tornados accounted for the 

highest number of IA requests, with drought, fishery closure, and 

contaminated water being the least common, as shown in table 4.

Table 4: Information on Individual Assistance (IA) Declarations Requests by Type of 

Disaster from Calendar Years 2008 through 2016a

Disaster Types IA Requested IA Declared IA Denied

Severe storm 190 113 77

Flooding 149 92 57

Tornado 117 68 49

Straight-line wind 60 35 25

Hurricane 27 24 3

Wildfire 16 6 10

Mudslide 15 11 4

Tropical storm 14 9 5

Winter storm 12 2 10

Landslide 12 7 5

Earthquake 5 2 3

Snow storm 3 0 3

Typhoon 2 1 1

Ice jam 2 1 1

Tsunami 2 1 1

Explosion 2 0 2

Fishery closure 1 0 1

Contaminated water 1 0 1

Drought 1 0 1

Source: GAO analysis of Federal Emergency Management Agency data. I GAO-18-366

a

Each disaster declaration request may have more than one type of disaster. As such, the table does 

not include a row for totals.
Page 14 GAO-18-366 FEMA Individual Assistance Factors

FEMA obligated a total of approximately $8.6 billion in IA for disaster 

declarations made from calendar years 2008 through 2016. These actual 

obligations were provided to 46 states and they ranged from less than $1 

million to more than $1 billion as shown in figure 2.24 See appendix II for 

FEMA’s IA actual obligations by state and type of disasters for disaster 

declarations made from calendars years 2008 through 2016.

 24Throughout this report, actual obligations refer to funds obligated by FEMA and are not 

adjusted for inflation. Also, these actual obligations were made from the time of the 

declaration to March 2017

FEMA IA Obligations 

Varied by Region and 

State
Page 15 GAO-18-366 FEMA Individual Assistance Factors

Figure 2: Federal Emergency Management Agency’s (FEMA) Individual Assistance (IA) Actual Obligations by Regions for 

Disaster Declarations Made from Calendar Years 2008 through 2016a

a

Figure includes IA actual obligations made from the time of the declaration to March 2017. In 

accordance with the Stafford Act, “state” means any state of the United States, the District of 
Page 16 GAO-18-366 FEMA Individual Assistance Factors

Columbia, Puerto Rico, the Virgin Islands, Guam, American Samoa, and the Commonwealth of the 

Northern Mariana Islands. See 42 U.S.C. § 5122(4).

Additionally, actual obligations for IA declarations made from calendar 

years 2008 through 2016 varied greatly by FEMA region, as also shown 

in figure 3. For example, FEMA Region VI had the highest obligations at 

around $3.3 billion. Region X had the lowest obligations at $24.8 million.

As shown in table 5, the amount of obligations for disasters declarations 

also varied greatly by state. For example, Louisiana had the highest 

obligations at approximately $2 billion, followed by New York and Texas 

at about $1.3 billion and $1.1 billion, respectively. The state with the 

lowest obligations was the U.S. Virgin Islands at about $2,100.

Table 5: Actual Obligations of Individual Assistance by State for Disaster 

Declarations Made from Calendar Years 2008 through 2016a

State Region Total ($)

Louisiana VI 2,003,244,709

New York II 1,309,869,042

Texas VI 1,149,629,671

New Jersey II 656,334,017

Illinois V 621,800,788

Iowa VII 210,526,142

North Dakota VIII 200,890,261

Tennessee IV 199,447,951

North Carolina IV 174,448,712

Pennsylvania III 165,486,633

Michigan V 148,308,502

South Carolina IV 147,945,615

Alabama IV 137,509,405

Florida IV 121,961,283

Missouri VII 116,280,805

Wisconsin V 115,849,685

Indiana V 104,041,429

West Virginia III 100,322,247

Kentucky IV 95,077,277

Mississippi IV 80,929,297

Colorado VIII 79,164,491

Georgia IV 77,397,631

Massachusetts I 70,452,076
Page 17 GAO-18-366 FEMA Individual Assistance Factors

State Region Total ($)

Puerto Rico II 58,237,566

Oklahoma VI 57,607,547

South Dakota VIII 55,503,363

Arkansas VI 54,859,658

California IX 46,917,730

Rhode Island I 38,831,216

Mariana Islands IX 34,281,445

American Samoa IX 32,242,550

Connecticut I 30,878,096

Vermont I 30,362,291

Virginia III 26,530,586

Washington X 13,450,309

Alaska X 11,386,310

Montana VIII 6,634,838

Nebraska VII 6,160,220

Minnesota V 5,532,091

Hawaii IX 4,082,910

Wyoming VIII 3,029,312

Maryland III 2,649,629

Nevada IX 1,893,834

New Hampshire I 1,260,630

Maine I 1,229,976

Virgin Islands II 2,136

Total 8,610,481,911

Source: GAO analysis of Federal Emergency Management Agency data. I GAO-18-366

a

Table includes actual obligations made from the time of the declaration to March 2017. In 

accordance with the Stafford Act, “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. See 42 U.S.C. § 5122(4).
Page 18 GAO-18-366 FEMA Individual Assistance Factors

Six of FEMA’s 10 regional offices reported using all six regulatory factors 

when evaluating states’ or tribes’ IA declaration requests. Officials from 

the other 4 regions reported using five of the six factors, with the 

exception being the average amount of individual assistance by state 

factor. These officials noted that they do not use this factor because 

FEMA considers the factor to be outdated or they consider all of the 

factors holistically.25

Officials from FEMA’s regional offices also generally reported that the 

extent to which they consider the six IA regulatory factors equally in all 

cases varies, depending on the circumstances of the related disaster. 

Specifically, officials from 7 of the 10 regions stated that they use the 

regulatory factors on a case-by-case basis as certain factors are more 

relevant than others based on the disaster. For example, if a tornado hits 

a rural community and completely destroys all properties within the 

community with no death or injury, then the regulatory factor for trauma 

may not be as applicable, while the concentration of damages regulatory 

factor would have greater relevance. On the other hand, if a tornado hits 

 25FEMA headquarters officials indicated that the table titled “Average Amount of 

Assistance per Disaster by Size of State” contained within contained within 44 C.F.R. § 

206.48(b)(6) is considered outdated and is no longer relevant to the declaration process. 

FEMA officials stated that they evaluate the total number of homes destroyed and 

suffering major damage (as well as the accessibility and habitability of the dwellings and 

the community) to satisfy this factor.

FEMA Regions Varied 

in How They 

Considered IA 

Regulatory Factors 

and Did Not 

Consistently Obtain

and Document 

Information on All 

Elements of These 

Factors

FEMA Regions Varied in 

Their Consideration of the 

IA Regulatory Factors 

Based on Disaster 

Circumstances
Page 19 GAO-18-366 FEMA Individual Assistance Factors

the center of a town resulting in damages with death and injuries, then the 

trauma regulatory factor would become more important to consider.

Additionally, officials in 3 of the 10 regions reported that in addition to the 

six regulatory factors, they also take into account institutional knowledge 

and staff experience when evaluating the regulatory factors. For example, 

officials in one region stated that their staff have more than 10 years of IA 

declaration experience, and as such, they are familiar with the extent of 

the information needed and collect the information accordingly.

Based on our analysis of RVARs from July 2012 through December 2016 

used to recommend approving or denying IA requests, FEMA regional 

offices did not consistently obtain and document information on all 

elements of the IA regulatory factors. As described earlier, FEMA regions 

are to use the RVAR to document information on the IA factors and to 

recommend to the FEMA administrator whether a disaster should be 

declared.

According to FEMA headquarters officials, FEMA developed the RVAR 

template in June 2012 to help ensure consistency across regions when 

making recommendations to headquarters on IA declaration requests. 

Officials stated that prior to the template, information on the six factors 

was mainly provided in narrative format. The new template listed the 

various elements found within each of the six regulatory factors, guiding 

the regional offices to provide information based on those elements. For 

example, instead of providing a general narrative on the trauma factor, 

the new template listed the elements to be provided under trauma, such 

as the number of injuries and deaths, as well as information on power 

outages and disruption of other community functions and services. Also, 

instead of summarizing the concentration of damages factor, the template 

allowed regional offices to categorize the damage concentration as low, 

medium, high, or extreme. Furthermore, the template also provided a 

uniform format to present quantitative information such as the number of 

homes destroyed; whether home damages are major or minor; the 

number of homes affected; and level of home ownership. See appendix III 

for a sample RVAR template.

We analyzed 81 RVARs developed by the 10 FEMA regions from July 

2012 through December 2016 and found that regions did not consistently

obtain and document information on all elements related to each of the 

FEMA Regions Did Not 

Consistently Obtain and 

Document Information on 

All Elements of the IA 

Regulatory Factors in 

RVARs
Page 20 GAO-18-366 FEMA Individual Assistance Factors

six regulatory factors in their RVARs.26 As shown in table 6, all 81 RVARs 

had at least some elements documented but not all for each of the IA 

regulatory factors. For example, for the IA concentration of damages 

regulatory factor, the six elements to be addressed include the number of 

homes destroyed, damaged or affected, damage concentration, and 

damage to critical facilities. While 44 of the 81 RVARs documented all of 

the six elements, 37 documented some but not all of the elements. 

Similarly, for the trauma regulatory factor, the four elements to be 

addressed include injuries, death, power outages, and disruption of 

community functions. While 30 of the 81 RVARs documented all of the 

four elements, 51 documented some but not all of the elements. For the 

insurance coverage factor, while five RVARs documented all of the 

elements, 73 RVARs documented some but not all of the elements. 

Elements under this factor include home ownership, insurance, and flood 

insurance, when applicable.27 None of the six regulatory factors were fully 

documented across all RVARs. See appendix IV for detailed information 

on the extent to which all of the elements of the six regulatory factors 

were documented in the RVARs from July 2012 through December 2016.

Table 6: Analysis of 81 Regional Administrator’s Validation and Recommendations 

(RVAR) by Element Pertaining to Each Individual Assistance (IA) Regulatory Factor 

Documented from July 2012 through December 2016

IA regulatory factor All elements 

documented

Some elements 

documented

No elements 

documented

Concentration of 

Damages

44 37 0

Trauma 30 51 0

Special populations 72 8 1

Voluntary agency 

assistance

76 5 0

 26As mentioned earlier, the RVAR template contains 28 elements, most of which pertain to 

the six IA factors based on 44 C.F.R. § 206.48(b). For example, the concentration of 

damages factor contains 6 elements (e.g., homes destroyed, homes with major damage, 

homes with minor damage, homes affected, damage to critical facilities, and damage 

concentration); trauma (e.g., injuries, death, power outages, and disruption of community 

functions/services) and special populations (e.g., low-income, poverty, disabled, and 

elderly) contain 4 elements; insurance has 3 elements (e.g., home ownership, insurance, 

and flood insurance [if applicable]); and voluntary agency assistance (e.g., hazard 

mitigation measures and level of volunteer assistance) and average amount of IA by state 

(e.g., recent disasters in the past 12 months and impact and frequency of prior disasters) 

have 2 elements. 

27The flood insurance element is only applicable when the disaster type is flood related.
Page 21 GAO-18-366 FEMA Individual Assistance Factors

IA regulatory factor All elements 

documented

Some elements 

documented

No elements 

documented

Insurance Coverage 5 73 3

Average amount of 

IA by state

11 66 4

Source: GAO analysis of Federal Emergency Management Agency’s RVAR. I GAO-18-366

FEMA headquarters officials acknowledged that information related to all 

the elements for each of the IA regulatory factors were missing from the 

RVARs. They stated that they had not collected all information on all 

factors because one factor may have more weight than another based on 

the specific incident that has occurred. However, they also indicated that 

they do not fully know and have not evaluated all of the reasons why a 

region may have omitted information on an element of a factor. FEMA 

headquarters officials agreed that having complete information on all 

elements of the regulatory factors in the RVARs would assist in their 

recommendation process.

Standards for Internal Control in the Federal Government suggest that 

agencies should establish and operate monitoring activities to ensure that 

internal controls—such as the documentation of all of the elements of the 

IA regulatory factors FEMA regions considered—are effective, and to take 

corrective actions as appropriate.28 Because it is unclear why regions are 

not completely documenting all elements related to the current six 

regulatory factors, such an evaluation could help FEMA identify whether 

any corrective steps are needed. Doing so could help FEMA ensure it is 

achieving its stated goals in providing consistency in the evaluation 

process and in the types of factors it considers.

 28GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).
Page 22 GAO-18-366 FEMA Individual Assistance Factors

Officials we interviewed in 9 of the 10 FEMA regions and state 

emergency management offices in all 11 states reported the positive 

relationship they maintain with each other as a strength in the IA 

declaration process.29 For example, both FEMA regional officials and 

state emergency management officials stated that they have a good 

working relationship and are in regular communication via telephone or 

in-person meetings with each other. Also, state emergency management 

officials we spoke to stated that whenever they are in need of assistance, 

they know they can reach out to FEMA regional officials for assistance. 

However, FEMA regional and state emergency management officials we 

spoke to also reported various challenges with the process. These 

include the subjective nature of the IA regulatory factors given the lack of 

eligibility thresholds, the lack of transparency in the decision-making 

process, and difficulty gathering information on IA regulatory factors.

Subjective nature of the IA factors and lack of eligibility thresholds.

Officials from 9 of 10 FEMA regions stated the subjective nature of the IA 

program is a challenge; and officials in 6 of the 10 regions also said they 

found the lack of eligibility thresholds a challenge. An official in one region 

stated that unlike FEMA’s Public Assistance program, which has 

minimum thresholds for eligibility, it is unclear when states should apply 

for IA funds. Under the Public Assistance program, for example, for states 

or tribes to qualify for assistance, they must demonstrate that they have 

sustained a minimum of $1 million in damages and the impact of 

 29The remaining one regional office did not make any comment on the FEMA and state 

relationship. We conducted interviews with all 10 FEMA regions and 11 states, including

California, Illinois, Indiana, Kentucky, Mississippi, Missouri, New York, Ohio, Oklahoma, 

South Dakota, and Virginia.

FEMA and States 

Reported Challenges 

in the IA Declaration 

Process, and FEMA 

Is Revising the 

Regulatory Factors 

Used to Assess 

Declaration Requests

FEMA and State Officials 

Reported Both Positive 

Relationships and Some 

Challenges in the IA 

Declaration Process
Page 23 GAO-18-366 FEMA Individual Assistance Factors

damages must amount to $1.00 per capita in the state.30 An official in 

another region explained that although the subjectivity of the IA factors 

provides flexibility in determining the type of IA program needed, having 

some quantifiable criteria could help officials explain to states why their 

requests were denied or approved.

Similarly, officials we interviewed in 7 of the 11 states said they found the 

subjective nature of the factors with no threshold to be a challenge. A 

state emergency management official in one state said this subjectivity 

makes it difficult to determine whether or not the state should make an IA 

request. A state emergency management official in another state reported 

that the subjectivity can cause the IA declaration process to be 

inconsistent, and it is not always clear how or why certain declarations 

were approved and others were not. Further, a state emergency 

management official in an additional state also pointed to the subjective 

nature of the factors with no threshold as a reason for not being able to 

provide a more detailed rationale behind a declaration denial.

To illustrate this, table 7 shows how four states requested IA declarations 

related to the same tornado in 2012 and varied in what they reported

across the six IA factors, such as the levels of damages incurred, special 

populations among their residents, and insurance coverage. Two of these 

four states—Kentucky and Indiana—received IA declarations and the 

other two—Ohio and Illinois—were denied. 

Table 7: Example of Regional Administrator’s Validation and Recommendations Information on the Individual Assistance 

Regulatory Factors for Four States Affected by the Same Disaster in 2012

Region V V V IV

State Ohio Illinois Indiana Kentucky

Disaster period March 2 February 29-March 2 February 29-March 3 February 29-March 3

Type of disaster declaration 

request

Major disaster 

declaration

Major disaster 

declaration

Major disaster 

declaration

Expedited disaster 

declarationa

Type of disaster Tornadoes

Factors

Damage concentration 

Homes destroyed 19 104 187 510

Homes with major damage 23 50 85 244

Homes with minor damage 25 139 107 Not provided

 30See 44 C.F.R. § 206.48(a). 
Page 24 GAO-18-366 FEMA Individual Assistance Factors

Region V V V IV

State Ohio Illinois Indiana Kentucky

Homes affected 78 133 89 Not provided

Damage to critical facilities Not provided Yes Yes Not provided

Damage concentration Provided Provided Provided Provided

Trauma 

Injury Not provided 100 Not provided 300

Death 3 6 13 21

Power outages Yes Yes Yes Yes

Disruption of community 

functions/services

Not provided Yes Yes Yes

Special population

Poverty (%) 9.3 16.90 12.6 18.40

Elderly (%) 11.8 17.90 13.75 12.90

Low-income (%) 1 1 24.7 29.30

Disabled (%) Not provided Not provided Not provided 23.7

Voluntary agency assistance

Hazard mitigation measures Yes Yes Yes Yes

Level of voluntary assistance Provided Provided Provided Provided

Insurance

Insurance (%) 97 20 47 Not provided

Flood insurance (if applicable)b Not applicable Not applicable Not applicable Not provided

Home ownership (%) 99 65 93 Not provided

Average amount of individual assistance by statec

Recent disasters in the past 12 

months

Yes Yes Yes Yes

Impact and Frequency of prior 

disasters

Not provided Not provided Not provided Yes

IA declaration request granted No No Yes Yes

Source: GAO analysis of Federal Emergency Management Agency information. I GAO-18-366

a

Expedited disaster declaration requests are not required to provide all the information related to the 

regulatory factors.

b

Flood insurance element is only applicable when the disaster type is flood related.

c

According to FEMA headquarters officials, the average amounts of individual assistance per disaster 

identified in the average amount of individual assistance by state regulatory factor, are considered 

outdated and they are no longer relevant to the declaration process. Instead, FEMA officials stated 

that they evaluate the total number of homes destroyed and suffering major damaged to satisfy this 

factor.

Lack of transparency. Another challenge reported by FEMA regional 

and state emergency management officials was the lack of transparency 

in how FEMA evaluates and provides a recommendation to the President 
Page 25 GAO-18-366 FEMA Individual Assistance Factors

on whether a declaration is warranted. For example, officials we 

interviewed in 4 of 10 regions indicated the lack of transparency as a 

challenge. A FEMA official in one region stated that the region would like 

more transparency regarding what FEMA headquarters recommends to 

the President and whether the President’s decision aligns with FEMA’s 

recommendation. State emergency management officials we interviewed 

in 10 of 11 states also reported that lack of transparency with the IA 

process is a challenge. For example, an emergency management official 

in one state said it is not clear how or if FEMA considers all of the factors. 

Also, an emergency management official in another state reported that it 

was unclear to him why his state’s declaration request was denied while 

the requests of other states with similar incidents were declared.

Difficulty gathering information on IA regulatory factors. Officials in 4 

of 10 FEMA regions reported difficulty gathering information, such as 

income or insurance coverage, as a challenge. An official in one region 

stated that it is difficult to obtain information related to IA factors from 

states. For example, the official said that calculating the concentration of 

damages is difficult absent technical guidance from FEMA headquarters, 

as the current guidance only accounts for the number of structure 

damage but not the impact of damage. Further, officials in two FEMA 

regions stated that states lack a dedicated IA official, making it difficult for 

state officials, who play multiple roles, to provide the necessary 

information related to the IA factors in their IA declaration request. 

Additionally, a state emergency management official in one state also

reported that lack of staff resources in her state makes it difficult to verify 

all the local damage assessments prior to making a declaration request.

Pursuant to the Sandy Recovery Improvement Act of 2013, in November 

2015, FEMA issued a Notice of Proposed Rulemaking to revise the six 

current IA regulatory factors to the following proposed factors:

• state fiscal capacity and resource availability;

• uninsured home and personal property losses;

• disaster-impacted population profile;

• impact to community infrastructure;

• casualties; and

FEMA Is Taking Steps to 

Revise the IA Regulatory 

Factors
Page 26 GAO-18-366 FEMA Individual Assistance Factors

• disaster-related unemployment.31

According to FEMA headquarters officials, the revisions aim to provide 

more objective criteria, clarify the threshold for eligibility, and speed the 

declaration. The officials said the proposed rule also seeks to provide 

additional clarity and guidance for all the established factors.32 Table 8 

shows FEMA’s description of current and proposed IA factors.

Table 8: Federal Emergency Management Agency’s (FEMA) Description of Current 

and Proposed Individual Assistance Regulatory Factors

Current Factors Proposed Factors

Concentration of Damage State Fiscal Capacity and Resource 

Availability

Trauma Uninsured Home and Personal Property 

Losses

Special Populations Disaster-Impacted Population Profile

Voluntary Agencies Impact to Community Infrastructure

Insurance Casualties

Average Amount of Individual Assistance 

by State

Disaster Related Unemployment

Source: GAO analysis of FEMA information. I GAO-18-366

FEMA received public comments from 14 states in the Federal Register 

during the comment period for the proposed rule and proposed 

guidance.33 The 14 states expressed concern about the proposed factor 

 3180 Fed. Reg. 70,116 (proposed Nov. 12, 2015); see Pub. L. No. 113-2, § 1109, 127 

Stat. at 47 (directing the Administrator of FEMA to, in cooperation with representatives of 

state, tribal, and local emergency management agencies, review, update and revise 

through rulemaking the individual assistance factors in order to provide more objective 

criteria for evaluating the need for assistance to individuals, clarify the threshold for 

eligibility, and speed a declaration of major disaster or emergency).

32In September 2016, FEMA also published and made available for comment a draft 

Individual Assistance Declarations Guidance, which is meant to be proposed companion 

guidance to accompany the proposed rule. See 81 Fed. Reg. 65,369 (published Sept. 22, 

2016). In the draft guidance, FEMA describes how it plans to evaluate a governor’s 

request for a major disaster declaration authorizing Individual Assistance, including a 

general description of each proposed factor, why it is important, and the data sources in 

the proposed factor. 

33FEMA received 58 comments on the proposed rule of which one was withdrawn. As a 

result, in total, 57 comments were submitted by 24 state and county government 

employees representing 14 states, 5 congressional members’ offices, 8 public and private 

organizations, and 20 individuals.
Page 27 GAO-18-366 FEMA Individual Assistance Factors

for state fiscal capacity and resource availability, including the reliability 

and relevance of data sources such as total taxable resources. These 

states expressed concern that the data collection necessary to meet the 

new requirements would fall upon them, adding to the cost burden of 

completing an IA disaster declaration request. They also explained that 

the use of total taxable resources and other similar data is not an effective 

way to assess a state’s current ability to provide resources following a 

disaster. Also, these states indicated that the data points such as total 

taxable resources and per capita personal income that would be used to 

evaluate state fiscal capacity are outdated and inaccurate and would be 

an inefficient way to evaluate a state’s true fiscal capacity to respond to a 

disaster.

Regarding the other five proposed factors, several states in their 

comments raised questions about ambiguities in interpreting the factors 

or the feasibility and cost of gathering related data. For example, in 

regards to the factor on disaster impacted population, five states 

expressed concern that the data required for the disaster-impacted 

population factor would be a cost burden to the state or that the data 

would be inappropriate for evaluation. Additionally, two states said 

unemployment related to a disaster incident for the disaster-related 

unemployment factor would be hard to quantify in the first 30 days 

following a disaster. They stated that this was especially an issue given 

that states work to submit an IA disaster declaration request as soon as

possible following a disaster.

According to the Office of Management and Budget’s Office of 

Information and Regulatory Affairs website, the projected date for 

finalization of the proposed rule is September 2018; however, as of April 

2018, FEMA officials stated that they were not certain whether that 

timeframe would be met. Until the proposed rule is finalized, we will not 

know the extent to which the various challenges FEMA regions and state 

officials raised in our interviews and in comments on the proposed rule 

will be addressed.

FEMA has obligated over $8.6 billion nationwide in IA from calendar 

years 2008 through 2016, highlighting the importance of FEMA’s 

evaluation of states’ and tribes’ IA declaration requests. FEMA’s regional 

offices evaluate the request and make a regional recommendation 

through the Regional Administrator’s Validation and Recommendation, 

which documents information on all relevant IA regulatory factors. FEMA 

has developed the Regional Administrator’s Validation and 

Conclusions
Page 28 GAO-18-366 FEMA Individual Assistance Factors

Recommendation to ensure regions consistently obtain and document the 

information needed by FEMA to make a disaster declaration 

recommendation to the President based on the IA regulatory factors. 

However, FEMA’s regional offices do not consistently obtain and 

document information on all elements of the current IA regulatory factors. 

Because it is unclear why regions are not always documenting all of the 

elements related to these factors, evaluating the reasons why could help 

FEMA identify if any corrective steps are needed. Doing so could also 

help FEMA ensure it is meeting its stated goals in providing consistency 

in the evaluation process and in the types of factors it considers.

We recommend that the Administrator of FEMA evaluate why regions are 

not completing the Regional Administrator’s Validation and 

Recommendations for each element of the current IA regulatory factors 

and take corrective steps, if necessary.

We provided a draft of this report to DHS for its review and comment. 

DHS provided written comments, which are summarized below and 

reproduced in full in appendix V. DHS concurred with the 

recommendation and described planned actions to address it. In addition, 

DHS provided written technical comments, which we incorporated into the 

report as appropriate.

DHS concurred with our recommendation that FEMA evaluate why 

regions are not completing the Regional Administrator’s Validation and 

Recommendations for each element of the IA regulatory factors and take 

corrective steps, if necessary. DHS stated that a FEMA working group 

consisting of headquarters stakeholders will draft survey questions for 

FEMA region officials to identify the common reasons why an element of 

an IA regulatory factor may not be addressed within a RVAR. According 

to DHS, the working group will also analyze, assess, and present the 

findings of the survey responses to FEMA senior leadership, and if 

needed, FEMA will develop and send a memorandum to the regions with 

additional guidance regarding the appropriate preparation of RVARs.

DHS stated that the estimated completion date is in the fall of 2018. 

These actions, if implemented effectively, should address the intent of our 

recommendation. 

We will send copies of this report to the Secretary of Homeland Security, 

the FEMA Administrator, and the appropriate congressional committees. 

Recommendation for 

Executive Action

Agency Comments 

and Our Evaluation
Page 29 GAO-18-366 FEMA Individual Assistance Factors

If you or your staff have any questions about this report, please contact 

me at (404) 679-1875 or curriec@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. Key contributors to this report are listed in appendix 

VI.

Chris P. Currie

Director, Homeland Security and Justice
Appendix I: Individual Assistance Declarations 

Requested, Declared, and Denied, Calendar 

Years 2008-2016

Page 30 GAO-18-366 FEMA Individual Assistance Factors

Table 9 provides the total number of Individual Assistance declaration 

requests made, declared, and denied, by region, state, and tribe for 

disaster declarations requested from calendar years 2008 through 2016.1

Table 9: Individual Assistance Requested, Declared, and Denied, by Region, State, and Tribe for Disaster Declarations 

Requested from Calendar Years 2008 through 2016a

Region State Requested Declared Denied

I 15 13 2

Connecticut 4 3 1

Massachusetts 3 3 0

Maine 1 1 0

New Hampshire 2 1 1

Rhode Island 2 2 0

Vermont 3 3 0

II 18 10 8

New Jersey 6 3 3

New York 7 4 3

Puerto Rico 3 3 0

U.S. Virgin Islands 2 0 2

III 26 13 13

Washington, D.C. 1 0 1

Maryland 4 1 3

Pennsylvania 3 2 1

Virginia 6 2 4

West Virginia 12 8 4

IV 69 53 16

Alabama 9 6 3

Florida 11 7 4

Georgia 7 6 1

Kentucky 12 10 2

Mississippi 15 12 3

North Carolina 5 4 1

South Carolina 3 2 1

 1

Throughout this report, and in accordance with the Stafford Act, “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. See 42 

U.S.C. § 5122(4). 

Appendix I: Individual Assistance 

Declarations Requested, Declared, and 

Denied, Calendar Years 2008-2016
Appendix I: Individual Assistance Declarations 

Requested, Declared, and Denied, Calendar 

Years 2008-2016

Page 31 GAO-18-366 FEMA Individual Assistance Factors

Region State Requested Declared Denied

Tennessee 7 6 1

V 32 16 16

Bad River Band of 

Chippewa

1 0 1

Illinois 11 6 5

Indiana 8 5 3

Michigan 3 1 2

Minnesota 5 2 3

Ohio 2 0 2

Wisconsin 2 2 0

VI 59 32 27

Arkansas 11 9 2

Louisiana 14 5 9

Navajo Nation 1 0 1

New Mexico 1 0 1

Oklahoma 17 9 8

Texas 15 9 6

VII 25 13 12

Iowa 3 3 0

Missouri 16 8 8

Nebraska 6 2 4

VIII 18 8 10

Colorado 5 2 3

Fort Peck Indian 

Reservation

1 0 1

Montana 1 1 0

North Dakota 2 2 0

Oglala Sioux Tribe 1 1 0

South Dakota 6 1 5

Utah 1 0 1

Wyoming 1 1 0

IX 18 6 12

American Samoa 2 1 1

Arizona 1 0 1

California 8 2 6

Guam 2 0 2

Hawaii 3 1 2

Northern Mariana Islands 1 1 0
Appendix I: Individual Assistance Declarations 

Requested, Declared, and Denied, Calendar 

Years 2008-2016

Page 32 GAO-18-366 FEMA Individual Assistance Factors

Region State Requested Declared Denied

Nevada 1 1 0

X 14 4 10

Alaska 5 2 3

Colville Reservation 1 0 1

Oregon 3 0 3

Spokane Tribe 1 0 1

Washington 4 2 2

Total 294 168 126

Source: GAO analysis of Federal Emergency Management Agency data. I GAO-18-366

a

Throughout this report, and in accordance with the Stafford Act, “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. See 42 U.S.C. § 5122(4).
Appendix II: Individual Assistance Actual 

Obligations for Declarations Made, Calendars 

Years 2008-2016

Page 33 GAO-18-366 FEMA Individual Assistance Factors

Table 10 provides Federal Emergency Management Agency’s (FEMA) 

Individual Assistance (IA) actual obligations for declarations made from 

calendar years 2008 through 2016 by state and type of disaster.1

 1

Throughout this report, actual obligations refer to funds obligated by FEMA and are not 

adjusted for inflation. Also, in accordance with the Stafford Act, “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. See 42 

U.S.C. § 5122(4).

Appendix II: Individual Assistance Actual 

Obligations for Declarations Made, 

Calendars Years 2008-2016
Appendix II: Individual Assistance Actual Obligations for 

Declarations Made, Calendars Years 2008-2016

Page 34 GAO-18-366 FEMA Individual Assistance Factors

Table 10: Federal Emergency Management Agency’s Individual Assistance (IA) Actual Obligations by State and Type of Disaster for Declarations Made from 

Calendar Years 2008 through 2016a

State Region Disaster type Individuals and 

Households 

Assistance ($)

Crisis 

Counseling ($)

Unemployment 

Assistance ($)

Legal 

Services ($)

Disaster Case 

Management ($)

Total ($)

Alaska X Flood 11,324,269.69 37,577.00 21,263.78 3,200.00 IA program not 

identifiedb 11,386,310.47

Alabama IV Severe storm(s) 121,080,077.04 5,759,053.27 480,242.64 5,343.20 10,184,689 137,509,405.37

Arkansas VI Severe storm(s);

Tornado

54,433,043.84 92,880.11 333,733.60 0.00 IA program not 

identified

54,859,657.55

Severe storm(s) 52,041,604.92 70,191.77 324,075.94 0.00 IA program not 

identified

52,435,872.63

Tornado 2,391,438.92 22,688.34 9,657.66 0.00 IA program not 

identified

2,423,784.92

American Samoa IX Earthquake 30,934,621.19 1,077,116.70 230,409.00 403.26 IA program not 

identified

32,242,550.15

California IX Fire; Earthquake 44,243,382.00 1,522,770.73 1,151,577.00 0.00 IA program not 

identified

46,917,729.73

Fire 33,179,542.09 1,522,770.73 1,151,577.00 0.00 IA program not 

identified

35,853,889.82

Earthquake 11,063,839.91 IA program not 

identified

IA program not 

identified

IA program 

not identified

IA program not 

identified

11,063,839.91

Colorado VIII Severe storm(s); Fire; 

Flood

68,635,065.72 7,224,031.50 711,567.62 25,753.85 2,568,072.15 79,164,490.84

Severe storm(s) 360,885.29 457,605.11 22,640.27 0.00 IA program not 

identified

841,130.67

Fire No IA program 

identified

1,337,442.37 197,096.49 No IA 

program 

identified

No IA program 

identified

1,534,538.86

Flood 68,274,180.43 5,428,984.02 491,830.86 25,753.85 2,568,072.15 76,788,821.31
Appendix II: Individual Assistance Actual Obligations for 

Declarations Made, Calendars Years 2008-2016

Page 35 GAO-18-366 FEMA Individual Assistance Factors

State Region Disaster type Individuals and 

Households 

Assistance ($)

Crisis 

Counseling ($)

Unemployment 

Assistance ($)

Legal 

Services ($)

Disaster Case 

Management ($)

Total ($)

Connecticut I Severe storm(s); 

Hurricane; Snow

30,397,368.44 IA program not 

identified

55,704.00 ,314.64 423,708.48 30,878,095.56

Severe storm(s) 5,189,469.42 IA program not 

identified

11,373.00 0.00 IA program not 

identified

5,200,842.42

Hurricane 25,207,472.56 IA program not 

identified 

44,331.00 1,314.64 423,708.48 25,676,826.68

Snow 426.46 IA program not 

identified

IA program not 

identified

IA program 

not identified

IA program not 

identified

426.46

Florida IV Severe storm(s); 

Hurricane

117,901,516.08 2,596,762.51 1,051,045.81 5,000.00 406,958.67 121,961,283.07

Severe storm(s) 88,608,589.22 2,163,480.51 523,617.81 0.00 406,958.67 91,702,646.21

Hurricane 29,292,926.86 433,282.00 527,428.00 5,000.00 IA program not 

identified 

30,258,636.86

Georgia IV Severe storm(s); 

Hurricane; Severe ice 

storm

76,554,929.43 467,614.73 375,087.29 0.00 IA program not 

identified

77,397,631.45

Severe storm(s) 69,951,478.43 350,807.73 252,015.29 0.00 IA program not 

identified

70,554,301.45

Hurricane 6,595,983.00 116,807.00 123,072.00 0.00 IA program not 

identified 

6,835,862.00

Severe ice storm 7,468.00 IA program not 

identified

IA program not 

identified

IA program 

not identified

IA program not 

identified

7,468.00

Hawaii IX Flood 3,480,427.34 595,972.17 6,510.86 0.00 IA program not 

identified

4,082,910.37

Iowa VII Severe storm(s); 

Flood

197,796,561.25 3,987,439.72 8,737,371.45 4,769.19 IA program not 

identified

210,526,141.61

Severe storm(s) 193,012,743.41 3,467,467.04 8,640,905.13 4,769.19 IA program not 

identified

205,125,884.77
Appendix II: Individual Assistance Actual Obligations for 

Declarations Made, Calendars Years 2008-2016

Page 36 GAO-18-366 FEMA Individual Assistance Factors

State Region Disaster type Individuals and 

Households 

Assistance ($)

Crisis 

Counseling ($)

Unemployment 

Assistance ($)

Legal 

Services ($)

Disaster Case 

Management ($)

Total ($)

Flood 4,783,817.84 519,972.68 96,466.32 0.00 IA program not 

identified

5,400,256.84

Illinois V Severe storm(s); 

Flood; Tornado; Snow

621,025,781.84 141,055.45 633,950.63 0.00 IA program not 

identified

621,800,787.92

Severe storm(s) 455,030,045.67 23,421.00 469,600.01 0.00 IA program not 

identified

455,523,066.68

Flood 163,462,430.37 IA program not 

identified

109,197.20 0.00 IA program not 

identified

163,571,627.57

Tornado 2,530,838.68 117,634.45 55,153.42 0.00 IA program not 

identified

2,703,626.55

Snow 2,467.12 IA program not 

identified

IA program not 

identified

IA program 

not identified

IA program not 

identified

2,467.12

Indiana V Severe storm(s) 102,526,308.44 1,195,111.95 319,921.63 87.20 IA program not 

identified

104,041,429.22

Kentucky IV Severe storm(s); 

Flood; Severe ice 

storm

93,515,969.88 576,468.33 581,384.81 0.00 403,453.69 95,077,276.71

Severe storm(s) 89,711,214.12 576,468.33 490,548.81 0.00 403,453.69 91,181,684.95

Flood 3,798,728.88 IA program not 

identified

90,836.00 IA program 

not identified

IA program not 

identified

3,889,564.88

Severe ice storm 6,026.88 IA program not 

identified

IA program not 

identified

IA program 

not identified

IA program not 

identified

6,026.88

Louisiana VI Hurricane; Flood 1,917,500,829.58 31,530,368.43 7,448,139.15 21,420.63 46,743,951.16 2,003,244,708.95

Hurricane 619,027,722.59 19,686,788.74 4,735,827.00 14,127.27 6,858,970.00 650,323,435.60

Flood 1,298,473,106.99 11,843,579.69 2,712,312.15 7,293.36 39,884,981.16 1,352,921,273.35

Massachusetts I Severe storm(s); 

Tornado; Hurricane

68,363,204.51 1,452,287.62 423,365.91 335.00 212,882.76 70,452,075.80

Severe storm(s) 58,317,381.21 676,775.41 114,375.91 0.00 IA program not 

identified

59,108,532.53
Appendix II: Individual Assistance Actual Obligations for 

Declarations Made, Calendars Years 2008-2016

Page 37 GAO-18-366 FEMA Individual Assistance Factors

State Region Disaster type Individuals and 

Households 

Assistance ($)

Crisis 

Counseling ($)

Unemployment 

Assistance ($)

Legal 

Services ($)

Disaster Case 

Management ($)

Total ($)

Tornado 4,375,854.67 775,512.21 263,580.00 335.00 212,882.76 5,628,164.64

Hurricane 5,669,968.63 IA program not 

identified 

45,410.00 0.00 IA program not 

identified 

5,715,378.63

Maryland III Hurricane 2,581,835.21 IA program not 

identified 

67,794.00 0.00 IA program not 

identified 

2,649,629.21

Maine I Flood 1,220,974.02 IA program not 

identified

9,002.00 IA program 

not identified

IA program not 

identified

1,229,976.02

Michigan V Flood 148,199,521.59 IA program not 

identified

108,980.00 0.00 IA program not 

identified

148,308,501.59

Minnesota V Severe storm(s); 

Flood

5,302,057.10 0.00 230,034.00 0.00 0.00 5,532,091.10

Severe storm(s) 2,395,457.10 IA program not 

identified

230,034.00 IA program 

not identified

IA program not 

identified

2,625,491.10

Flood 2,906,600.00 IA program not 

identified

IA program not 

identified

IA program 

not identified

IA program not 

identified

2,906,600.00

Missouri VII Flood; Severe 

storm(s)

103,143,107.28 6,062,101.51 971,188.62 5,000.00 6,099,407.32 116,280,804.73 

Flood 15,988,361.87 1,348,262.56 80,939.81 5,000.00 2,603,773.00 20,026,337.24

Severe storm(s) 87,154,745.41 4,713,838.95 890,248.81 0.00 3,495,634.32 96,254,467.49

Mississippi IV Severe storm(s); 

Hurricane; Flood

80,123,535.08 17,617.62 638,572.83 3,195.00 146,376.91 80,929,297.44

Severe storm(s) 33,219,800.59 17,617.62 356,286.05 3,195.00 146,376.91 33,743,276.17

Hurricane 24,432,367.39 IA program not 

identified 

73,137.78 0.00 IA program not 

identified 

24,505,505.17

Flood 22,471,367.10 IA program not 

identified

209,149.00 0.00 IA program not 

identified

22,680,516.10

Montana VIII Severe storm(s) 6,610,866.31 IA program not 

identified

23,972.00 IA program 

not identified

IA program not 

identified

6,634,838.31
Appendix II: Individual Assistance Actual Obligations for 

Declarations Made, Calendars Years 2008-2016

Page 38 GAO-18-366 FEMA Individual Assistance Factors

State Region Disaster type Individuals and 

Households 

Assistance ($)

Crisis 

Counseling ($)

Unemployment 

Assistance ($)

Legal 

Services ($)

Disaster Case 

Management ($)

Total ($)

Nebraska VII Severe storm(s); 

Flood

5,777,326.34 292,823.51 90,070.50 0.00 IA program not 

identified

6,160,220.35

Severe storm(s) 1,502,256.34 IA program not 

identified

13,561.50 IA program 

not identified

IA program not 

identified

1,515,817.84

Flood 4,275,070.00 292,823.51 76,509.00 0.00 IA program not 

identified

4,644,402.51

New Hampshire I Hurricane 1,236,236.91 IA program not 

identified 

24,393.00 IA program 

not identified

IA program not 

identified 

1,260,629.91

New Jersey II Severe storm(s); 

Hurricane

626,445,681.49 10,808,355.17 7,493,369.94 0.00 11,586,610.46 656,334,017.06

Severe storm(s) 16,534,228.93 IA program not 

identified

33,164.00 0.00 IA program not 

identified

16,567,392.93

Hurricane 609,911,452.56 10,808,355.17 7,460,205.94 0.00 11,586,610.46 639,766,624.13

Nevada IX Severe storm(s) 1,893,834.06 IA program not 

identified

IA program not 

identified

IA program 

not identified

IA program not 

identified

1,893,834.06

New York II Hurricane; Severe 

storm(s)

1,190,712,765.04 54,528,126.89 17,719,931.04 269.68 46,907,949.83 1,309,869,042.48

Hurricane 1,127,960,708.68 51,892,473.89 16,721,106.79 269.68 45,692,130.83 1,242,266,689.87

Severe storm(s) 62,752,056.36 2,635,653.00 998,824.25 0.00 1,215,819.00 67,602,352.61

North Carolina IV Severe storm(s); 

Hurricane; Mud/ Land 

Slide

165,714,736.18 1,683,795.10 2,523,839.68 5,000.00 4,521,340.58 174,448,711.54

Severe storm(s) 14,125,060.36 986,839.61 183,754.82 0.00 IA program not 

identified

15,295,654.79

Hurricane 151,589,675.82 696,955.49 2,340,084.86 5,000.00 4,521,340.58 159,153,056.75

Mud/ Landslide 0.00 IA program not 

identified 

IA program not 

identified 

IA program 

not identified 

IA program not 

identified 

0.00

North Dakota VIII Severe storm(s); 

Flood

194,977,101.05 2,009,270.33 3,898,889.69 5,000.00 IA program not 

identified

200,890,261.07
Appendix II: Individual Assistance Actual Obligations for 

Declarations Made, Calendars Years 2008-2016

Page 39 GAO-18-366 FEMA Individual Assistance Factors

State Region Disaster type Individuals and 

Households 

Assistance ($)

Crisis 

Counseling ($)

Unemployment 

Assistance ($)

Legal 

Services ($)

Disaster Case 

Management ($)

Total ($)

Severe storm(s) 8,216,818.62 IA program not 

identified

1,337,457.60 0.00 IA program not 

identified

9,554,276.22

Flood 186,760,282.43 2,009,270.33 2,561,432.09 5,000.00 IA program not 

identified

191,335,984.85

Northern Mariana 

Islands 

IX Typhoon 30,764,794.87 1,136,694.74 697,013.00 5,000.00 1,677,942.40 34,281,445.01

Oklahoma VI Severe storm(s); Fire; 

Tornado

51,131,095.99 2,547,961.19 388,873.33 5,000.00 3,534,616.00 57,607,546.51

Severe storm(s) 27,896,658.64 1,451,811.43 191,232.33 IA program 

not identified

3,534,616.00 33,074,318.40

Fire 8,945,183.13 IA program not 

identified

23,000.00 0.00 IA program not 

identified

8,968,183.13

Tornado 14,289,254.22 1,096,149.76 174,641.00 5,000.00 IA program not 

identified

15,565,044.98

Pennsylvania III Hurricane; Flood 162,245,344.66 801,143.93 1,895,308.00 0.00 544,836.71 165,486,633.30

Hurricane 41,084,124.81 IA program not 

identified

147,840.00 0.00 IA program not 

identified 

41,231,964.81

Flood 121,161,219.85 801,143.93 1,747,468.00 0.00 544,836.71 124,254,668.49

Puerto Rico II Hurricane; Severe 

storm(s)

52,532,483.18 5,659,880.22 45,202.15 IA program 

not identified

IA program not 

identified 

58,237,565.55

Hurricane 30,299,140.51 2,079,175.92 39,309.00 IA program 

not identified

IA program not 

identified 

32,417,625.43

Severe storm(s) 22,233,342.67 3,580,704.30 5,893.15 IA program 

not identified

IA program not 

identified

25,819,940.12

Rhode Island I Hurricane; Severe 

storm(s)

36,689,593.97 1,786,157.00 355,464.54 0.00 IA program not 

identified

38,831,215.51

Hurricane 410,938.22 78,724.00 17,294.88 IA program 

not identified 

IA program not 

identified 

506,957.10
Appendix II: Individual Assistance Actual Obligations for 

Declarations Made, Calendars Years 2008-2016

Page 40 GAO-18-366 FEMA Individual Assistance Factors

State Region Disaster type Individuals and 

Households 

Assistance ($)

Crisis 

Counseling ($)

Unemployment 

Assistance ($)

Legal 

Services ($)

Disaster Case 

Management ($)

Total ($)

Severe storm(s) 36,278,655.75 1,707,433.00 338,169.66 0.00 IA program not 

identified

38,324,258.41

South Carolina IV Hurricane; Flood 128,587,779.98 6,802,962.20 1,107,267.00 5,000.00 11,442,606.00 147,945,615.18

Hurricane 39,663,704.61 2,175,297.41 173,462.00 5,000.00 4,553,144.00 46,570,608.02

Flood 88,924,075.37 4,627,664.79 933,805.00 0.00 6,889,462.00 101,375,007.16

South Dakota VIII Flood; Severe 

storm(s)

55,416,328.60 IA program not 

identified

87,034.10 0.00 IA program not 

identified

55,503,362.70

Flood 4,753,534.43 IA program not 

identified

69,252.45 0.00 IA program not 

identified

4,822,786.88

Severe storm(s) 50,662,794.17 IA program not 

identified

17,781.65 IA program 

not 

identified

IA program not 

identified

50,680,575.82

Tennessee IV Severe storm(s); Fire 194,654,226.96 3,919,165.75 866,622.14 7,935.66 IA program not 

identified

199,447,950.51

Severe storm(s) 190,690,926.96 3,797,041.75 866,622.14 2,935.66 IA program not 

identified

195,357,526.51

Fire 3,963,300.00 122,124.00 IA program not 

identified

5,000.00 IA program not 

identified

4,090,424.00

Texas VI Hurricane; Flood; 

Severe storm(s); Fire

1,104,762,457.87 17,201,156.42 10,175,299.36 10,000.00 17,480,757.00 1,149,629,670.65

Hurricane 887,157,346.07 7,300,332.39 8,384,537.36 0.00 IA program not 

identified

902,842,215.82

Flood 128,976,403.78 3,611,909.01 586,328.00 10,000.00 10,271,993.00 143,456,633.79

Severe storm(s) 73,113,228.76 5,803,009.18 840,459.00 0.00 7,208,764.00 86,965,460.94

Fire 15,515,479.26 485,905.84 363,975.00 0.00 IA program not 

identified

16,365,360.10

Virginia III Hurricane; 

Earthquake

26,453,711.38 68,664.15 8,210.61 0.00 IA program not 

identified

26,530,586.14
Appendix II: Individual Assistance Actual Obligations for 

Declarations Made, Calendars Years 2008-2016

Page 41 GAO-18-366 FEMA Individual Assistance Factors

State Region Disaster type Individuals and 

Households 

Assistance ($)

Crisis 

Counseling ($)

Unemployment 

Assistance ($)

Legal 

Services ($)

Disaster Case 

Management ($)

Total ($)

Hurricane 6,026.88 IA program not 

identified

IA program not 

identified

IA program 

not identified

IA program not 

identified

6,026.88

Earthquake 16,566,971.42 68,664.15 1,346.61 0.00 IA program not 

identified

16,636,982.18

Virgin Islands II Hurricane; Severe 

storm(s)

2,136.07 IA program not 

identified 

IA program not 

identified 

IA program 

not identified 

IA program not 

identified 

2,136.07

Hurricane 656.07 IA program not 

identified 

IA program not 

identified 

IA program 

not identified 

IA program not 

identified 

656.07

Severe storm(s) 1,480.00 IA program not 

identified

IA program not 

identified

IA program 

not identified

IA program not 

identified

1,480.00

Vermont I Hurricane; Severe 

storm(s)

26,557,306.49 1,087,593.46 494,750.04 0.00 2,222,641.00 30,362,290.99

Hurricane 23,398,923.48 1,087,593.46 469,905.03 0.00 2,222,641.00 27,179,062.97

Severe storm(s) 3,158,383.01 IA program not 

identified

24,845.01 0.00 IA program not 

identified

3,183,228.02

Washington X Flood; Mud/ Landslide 10,964,235.08 269,573.00 2,215,653.00 848.15 IA program not 

identified

13,450,309.23

Flood 9,240,849.30 IA program not 

identified

1,620,153.00 848.15 IA program not 

identified

10,861,850.45

Mud/ Landslide 1,723,385.78 269,573.00 595,500.00 0.00 IA program not 

identified

2,588,458.78

Wisconsin V Severe storm(s) 113,491,654.91 2,015,907.43 342,123.00 0.00 IA program not 

identified

115,849,685.34

West Virginia III Hurricane; Flood; 

Severe storm(s)

91,090,572.42 3,117,356.85 292,845.73 0.00 5,821,472.00 100,322,247.00

Hurricane 52,093.97 IA program not 

identified 

IA program not 

identified 

IA program 

not identified 

IA program not 

identified 

52,093.97

Flood 52,939,896.68 2,660,395.92 219,479.00 0.00 5,821,472.00 61,641,243.60
Appendix II: Individual Assistance Actual Obligations for 

Declarations Made, Calendars Years 2008-2016

Page 42 GAO-18-366 FEMA Individual Assistance Factors

State Region Disaster type Individuals and 

Households 

Assistance ($)

Crisis 

Counseling ($)

Unemployment 

Assistance ($)

Legal 

Services ($)

Disaster Case 

Management ($)

Total ($)

Severe storm(s) 38,098,581.77 456,960.93 73,366.73 0.00 IA program not 

identified

38,628,909.43

Wyoming VIII Flood; Severe 

storm(s)

2,737,976.80 222,519.00 68,816.00 0.00 IA program not 

identified

3,029,311.80

Flood 2,736,003.04 222,519.00 68,816.00 0.00 IA program not 

identified

3,027,338.04

Severe storm(s) 1,973.76 IA program not 

identified

IA program not 

identified

IA program 

not identified

IA program not 

identified

1,973.76

Grand total 8,610,481,911.13

Source: GAO analysis of FEMA data. I GAO-18-366

a

Table includes actual obligations made from the time of the declaration to March 2017. Throughout this report, and 

in accordance with the Stafford Act, “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. See 42 

U.S.C. § 5122(4).

b

”IA program not identified” refers to those programs that were not identified in the Integrated Financial 

Management Information System obligations costs data.
Appendix III: Regional Administrator’s 

Validation and Recommendation Template

Page 43 GAO-18-366 FEMA Individual Assistance Factors

As part of the Federal Emergency Management Agency’s (FEMA) 

declaration process, FEMA’s regional offices are to evaluate states’ or 

tribes’ declaration requests, including the IA declaration request, and 

make a recommendation called the Regional Administrator’s Validation 

and Recommendation (RVAR) and submit the RVAR to FEMA 

headquarters. In June 2012, FEMA headquarters issued a template for 

FEMA regional offices to use in developing the RVAR as identified in 

figure 3.1

 1

Throughout this report, and in accordance with the Stafford Act, “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. See 42 

U.S.C. § 5122(4). 

Appendix III: Regional Administrator’s 

Validation and Recommendation Template
Appendix III: Regional Administrator’s 

Validation and Recommendation Template

Page 44 GAO-18-366 FEMA Individual Assistance Factors

Figure 3: Federal Emergency Management Agency’s (FEMA) Regional 

Administrator’s Validation and Recommendation Template
Appendix III: Regional Administrator’s 

Validation and Recommendation Template

Page 45 GAO-18-366 FEMA Individual Assistance Factors
Appendix III: Regional Administrator’s 

Validation and Recommendation Template

Page 46 GAO-18-366 FEMA Individual Assistance Factors
Appendix III: Regional Administrator’s 

Validation and Recommendation Template

Page 47 GAO-18-366 FEMA Individual Assistance Factors
Appendix III: Regional Administrator’s 

Validation and Recommendation Template

Page 48 GAO-18-366 FEMA Individual Assistance Factors
Appendix III: Regional Administrator’s 

Validation and Recommendation Template

Page 49 GAO-18-366 FEMA Individual Assistance Factors

Source: FEMA. | GAO-18-366
Appendix IV: Information on the Elements of 

the Six Individual Assistance Regulatory 

Factors

Page 50 GAO-18-366 FEMA Individual Assistance Factors

Tables 11 through 16 provide information on each element of the 6 

Individual Assistance (IA) regulatory factors documented in the Regional 

Administrator’s Validation and Recommendation (RVAR) from July 2012 

through December 2016 by the Federal Emergency Management Agency 

region.

Table 11: Information on Concentration of Damages by Element Found in Regional Administrator’s Validation and 

Recommendation (RVAR) from July 2012 through December 2016

Factor: Concentration of Damages 2012 RVARs 2013 RVARs 2014 RVARs 2015 RVARs 2016 RVARs

Damage to critical 

facilities

Documented 6 13 3 11 12

Not documented 1 0 11 11 13

Damage concentration Documented 7 12 14 22 25

Not documented 0 1 0 0 0

Homes destroyed Documented 7 12 14 22 24

Not documented 0 1 0 0 1

Homes with major 

damage

Documented 7 12 14 22 24

Not documented 0 1 0 0 1

Homes with minor 

damage

Documented 7 12 14 22 24

Not documented 0 1 0 0 1

Homes affected Documented 7 12 14 22 24

Not documented 0 1 0 0 1

Total number of RVARs 

by year

7 13 14 22 25

Source: GAO analysis of Federal Emergency Management Agency’s RVAR. I GAO-18-366

Table 12: Information on Trauma by Element Found in Regional Administrator’s Validation and Recommendation (RVAR) from 

July 2012 through December 2016

Factor: Trauma 2012 RVARs 2013 RVARs 2014 RVARs 2015 RVARs 2016 RVARs

Death Documented 7 10 13 20 23

Not documented 0 3 1 2 2

Injuries Documented 4 7 11 17 10

Not documented 3 6 3 5 15

Power outage Documented 6 9 13 13 16

Not documented 1 4 1 9 9

Disruption of 

community 

functions/ services

Documented 5 12 11 14 20

Not documented 2 1 3 8 5

Total number of 

RVARs by year

7 13 14 22 25

Source: GAO analysis of Federal Emergency Management Agency’s RVAR. I GAO-18-366

Appendix IV: Information on the Elements of 

the Six Individual Assistance Regulatory 

Factors 
Appendix IV: Information on the Elements of 

the Six Individual Assistance Regulatory 

Factors

Page 51 GAO-18-366 FEMA Individual Assistance Factors

Table 13: Information on Special Populations by Element Found in Regional Administrator’s Validation and Recommendation 

(RVAR) from July 2012 through December 2016

Factor: Special Populations 2012 RVARs 2013 RVARs 2014 RVARs 2015 RVARS 2016 RVARs

Low income Documented 7 10 14 21 22

Not documented 0 3 0 1 3

Poverty Documented 7 12 14 22 25

Not documented 0 1 0 0 0

Disabled Documented 6 10 14 22 25

Not documented 1 3 0 0 0

Elderly Documented 6 12 14 22 25

Not documented 1 1 0 0 0

Total number of 

RVARs by year

7 13 14 22 25

Source: GAO analysis of Federal Emergency Management Agency’s RVAR. I GAO-18-366

Table 14: Information on Voluntary Assistance by Element Found in Regional Administrator’s Validation and 

Recommendation (RVAR) from July 2012 through December 2016

Factor: Voluntary Assistance 2012 RVARs 2013 RVARs 2014 RVARs 2015 RVARs 2016 RVARs

Hazard mitigation Documented 5 13 13 21 25

Not documented 2 0 1 1 0

Level of volunteer 

assistance

Documented 7 13 14 21 25

Not documented 0 0 0 1 0

Total number of 

RVARs by year

7 13 14 22 25

Source: GAO analysis of Federal Emergency Management Agency’s RVAR. I GAO-18-366

Table 15: Information on Insurance Coverage Found in Regional Administrator’s Validation and Recommendation (RVAR) 

from July 2012 through December 2016

Factor: Insurance Coverage 2012 RVARs 2013 RVARs 2014 RVARs 2015 RVARs 2016 RVARs

Home ownership Documented 0 3 0 1 3

Not documented 7 10 14 21 22

Insurance Documented 6 10 13 18 24

Not documented 1 3 1 4 1

Flood insurance (if 

applicable)

Documented 6 7 11 11 15

Not documented 1 1 3 9 6

Not applicablea 0 5 0 2 4

Total number of 

RVARs by year

7 13 14 22 25

Source: GAO analysis of Federal Emergency Management Agency’s RVAR. I GAO-18-366
Appendix IV: Information on the Elements of 

the Six Individual Assistance Regulatory 

Factors

Page 52 GAO-18-366 FEMA Individual Assistance Factors

a

Flood insurance is not applicable if the disaster type is flood related.

Table 16: Information on Average Amount of Individual Assistance by State Found in Regional Administrator’s Validation and 

Recommendations (RVAR) from July 2012 through December 2016

Factor: Average Amount of Individual 

Assistance by State

2012 RVARs 2013 RVARs 2014 RVARs 2015 RVARS 2016 RVARs

Recent disasters 

in the same area in 

past 12 months

Documented 7 13 10 21 25

Not documented 0 0 4 1 0

Impact and 

frequency of prior 

disasters

Documented 2 2 1 5 2

Not documented 5 11 13 17 23

Total number of 

RVARs by year

7 13 14 22 25

Source: GAO analysis of Federal Emergency Management Agency’s RVAR. I GAO-18-366
Appendix V: Comments from the Department 

of Homeland Security

Page 53 GAO-18-366 FEMA Individual Assistance Factors

Appendix V: Comments from the Department 

of Homeland Security
Appendix V: Comments from the Department 

of Homeland Security

Page 54 GAO-18-366 FEMA Individual Assistance Factors
Appendix V: Comments from the Department 

of Homeland Security

Page 55 GAO-18-366 FEMA Individual Assistance Factors
Appendix VI: GAO Contact and Staff 

Acknowledgments

Page 56 GAO-18-366 FEMA Individual Assistance Factors

Chris P. Currie, (404) 679-1875 or curriec@gao.gov

In addition to the contact named above, Aditi Archer (Assistant Director), 

Su Jin Yon (Analyst-In-Charge), Hiwotte Amare, Eric Hauswirth, Susan 

Hsu, Jun S. (Joyce) Kang, Christopher Keisling, Heidi Nielson, Hadley 

Nobles, Anne Rhodes-Kline, and Jerome (Jerry) Sandau made significant 

contributions to this report.

Appendix VI: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101441)
The Government Accountability Office, the audit, evaluation, and investigative 

arm of Congress, exists to support Congress in meeting its constitutional 

responsibilities and to help improve the performance and accountability of the 

federal government for the American people. GAO examines the use of public 

funds; evaluates federal programs and policies; and provides analyses, 

recommendations, and other assistance to help Congress make informed 

oversight, policy, and funding decisions. GAO’s commitment to good government 

is reflected in its core values of accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no cost is 

through GAO’s website (https://www.gao.gov). Each weekday afternoon, GAO 

posts on its website newly released reports, testimony, and correspondence. To 

have GAO e-mail you a list of newly posted products, go to https://www.gao.gov

and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of production and 

distribution and depends on the number of pages in the publication and whether 

the publication is printed in color or black and white. Pricing and ordering 

information is posted on GAO’s website, https://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537.

Orders may be paid for using American Express, Discover Card, MasterCard, 

Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube.

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts.

Visit GAO on the web at https://www.gao.gov.

Contact:

Website: https://www.gao.gov/fraudnet/fraudnet.htm

Automated answering system: (800) 424-5454 or (202) 512-7470

Orice Williams Brown, Managing Director, WilliamsO@gao.gov, (202) 512-4400, 

U.S. Government Accountability Office, 441 G Street NW, Room 7125, 

Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

James-Christian Blockwood, Managing Director, spel@gao.gov, (202) 512-4707

U.S. Government Accountability Office, 441 G Street NW, Room 7814, 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Strategic Planning and 

External Liaison

Please Print on Recycled Paper.