FEDERAL DISASTER 

ASSISTANCE

Improved Criteria 

Needed to Assess a 

Jurisdiction’s 

Capability to Respond 

and Recover on Its 

Own

Report to Congressional Addressees

September 2012

GAO-12-838

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-838, a report to 

congressional addressees 

September 2012 

FEDERAL DISASTER ASSISTANCE

Improved Criteria Needed to Assess a Jurisdiction's 

Capability to Respond and Recover on Its Own

Why GAO Did This Study

The growing number of disaster 

declarations—a record 98 in fiscal year 

2011 compared with 65 in 2004—has 

contributed to increased federal 

disaster costs. FEMA leads federal 

efforts to respond to and recover from 

disasters and makes recommendations 

to the President, who decides whether 

to declare a disaster and increase the 

usual federal cost share of 75 percent.

This report addresses (1) the number 

of declarations requested and 

approved from fiscal years 2004-2011

and associated DRF obligations; (2) 

the criteria FEMA used to recommend 

a declaration for PA, and the extent 

that FEMA assessed whether an 

effective response to a disaster was 

beyond the capabilities of state and 

local governments; (3) how FEMA 

determined whether to recommend 

cost share adjustments, and their

costs; and (4) FEMA’s administrative 

cost percentages for declarations. 

GAO reviewed declaration data for 

fiscal years 2004-2011 and conducted 

site visits in 2011 to the two FEMA 

regions with the highest DRF 

obligations. The results are not 

generalizable, but provide insights. 

What GAO Recommends

GAO recommends, among other 

things, that FEMA develop a 

methodology to more accurately 

assess a jurisdiction’s capability to 

respond to and recover from a disaster 

without federal assistance, develop 

criteria for 100 percent cost 

adjustments, and implement goals for 

and track administrative costs. FEMA 

concurred with the first two, but 

partially concurred with the third, 

saying it would conduct a review 

before taking additional action. 

What GAO Found

During fiscal years 2004-2011, the President received governors’ requests for 

629 disaster declarations and approved 539, or 86 percent, of which the Federal 

Emergency Management Agency (FEMA) reported 71 percent were for severe 

storms. For these 539 declarations, FEMA obligated $80.3 billion, or an average 

of about $10 billion a year, from the Disaster Relief Fund (DRF), as of January 

31, 2012. Almost half of the obligations were for Hurricane Katrina; excluding 

obligations for Hurricane Katrina, FEMA obligated $40.6 billion, or an average of 

about $5 billion a year. As of January 31, 2012, FEMA anticipated that when all 

539 declarations are closed, total DRF obligations will be about $91.5 billion.

GAO’s analysis shows that FEMA primarily relied on a single criterion, the per

capita damage indicator, to determine whether to recommend to the President 

that a jurisdiction receive public assistance (PA) funding. However, because 

FEMA’s current per capita indicator, set at $1 in 1986, does not reflect the rise in 

(1) per capita personal income since it was created in 1986 or (2) inflation from 

1986 to 1999, the indicator is artificially low. The indicator would be $3.57 in 2011 

had it been adjusted for increases in per capita income and $2.07 in 2012 had it 

been adjusted for inflation from 1986 to 1999, rather than its current $1.35. 

GAO’s analysis of FEMA’s anticipated obligations for 508 declarations with PA 

during fiscal years 2004-2011 shows that 44 percent and 25 percent would not 

have met the indicator if it had been adjusted for increases in personal income 

and inflation, respectively, since 1986. Further, the per capita indicator does not 

accurately reflect a jurisdiction’s capability to respond to or recover from a 

disaster without federal assistance. GAO identified other measures of fiscal 

capacity, such as total taxable resources, that could be more useful in

determining a jurisdiction’s ability to pay for damages to public structures. 

Developing a methodology to more comprehensively assess state capabilities 

and reexamining the basis for the indicator could help FEMA more accurately 

determine a jurisdiction’s capacity to respond without federal assistance. 

FEMA recommends raising the usual 75 percent federal share for PA to 90 

percent when federal obligations, excluding FEMA administrative costs, meet a 

qualifying threshold. However, FEMA has no specific criteria for assessing 

requests to raise the federal share for emergency work to 100 percent, but relies 

on its professional judgment. For the 539 disaster declarations during fiscal years 

2004-2011, governors made 150 requests to adjust the federal cost share to 90 

or 100 percent; 109, or 73 percent, were approved or statutorily mandated, 

mostly for hurricanes. Without specific criteria for 100 percent cost share, FEMA 

risks making inconsistent or inequitable recommendations to the President. 

GAO’s analysis of administrative costs for 539 disaster declarations during fiscal 

years 2004-2011 shows that administrative cost percentages frequently 

exceeded FEMA’s targets, although FEMA does not require that they be met. 

GAO’s analysis of 1,221 disaster declarations shows that average administrative 

costs doubled from 9 to 18 percent during fiscal years 1989-2011, the time period 

for which FEMA has data available. FEMA is working on short- and long-term 

actions to improve efficiencies in delivering disaster assistance, but the agency 

does not plan to set goals or track performance for administrative costs. Until this 

happens, it will be difficult for FEMA to ensure assistance is being delivered in an 

efficient manner.

View GAO-12-838. For more information, 

contact William O. Jenkins at (202) 512-8757 

or jenkinswo@gao.gov. 
Page i GAO-12-838 Federal Disaster Assistance 

Letter 1 

Background 7

Over 500 Disasters Were Declared during Fiscal Years 2004 

through 2011 with Total Obligations of Over $90 Billion 

Anticipated 14

Eligibility for Assistance Is Primarily Determined Using a Damage 

Estimate Indicator 22

FEMA Does Not Have Specific Criteria to Evaluate Some Cost 

Share Adjustment Requests and Does Not Track Additional 

Costs for All Adjustments 33

Costs of Providing Disaster Assistance Have Increased, but FEMA 

Is Working to Reduce Costs 38

Conclusions 48

Recommendations for Executive Action 50

Agency Comments and Our Evaluation 51

Appendix I GAO Analyses of the Number of Disaster Declarations and 

Amount of Obligations 54

Appendix II Objectives, Scope, and Methodology 65

Appendix III Total Public Assistance Indicator Amount for Fiscal Year 2012, by 

Jurisdiction 69

Appendix IV Description of Three Approaches to Measure a Jurisdiction’s Fiscal 

Capacity 71

Appendix V Comments from the Department of Homeland Security 78

Appendix VI GAO Contact and Staff Acknowledgments 82

Contents
Page ii GAO-12-838 Federal Disaster Assistance 

Tables

Table 1: Number of Disaster Declarations Requested and Approved 

during Fiscal Years 2004 through 2011 14

Table 2: Obligations by Fiscal Year for 539 Disaster Declarations 

during Fiscal Years 2004 through 2011 19

Table 3: Number and Percentage of Closed Disasters Declared 

during Fiscal Years 1989 through 2011, by Obligation 

Amounts as of January 31, 2012 21

Table 4: Number and Percentage of Disasters Declared during 

Fiscal Years 2004 through 2011, by Combined Actual and 

Projected Total Obligation Amounts, as of April 30, 2012 22

Table 5: Three Potential Approaches to Measure a Jurisdiction’s 

Fiscal Capacity 32

Table 6: Number of Cost Share Adjustments Requested and 

Approved, Fiscal Years 2004 through 2011 34

Table 7: Average Administrative Cost Percentages for 1,221 

Disaster Declarations during Fiscal Years 1989 

through 2011 41

Table 8: Average Administrative Cost Percentages by Type of 

Assistance during Fiscal Years 1989 through 2011 44

Table 9: Status of Disaster Declarations during Fiscal Years 1992 

through 2011, as of January 31, 2012 54

Table 10: Number of Disaster Declarations during Fiscal Years 1953 

through 2011 by Jurisdiction 55

Table 11: Disaster Declarations by Incident Type during Fiscal 

Years 2004 through 2011 58

Table 12: Obligations for Disaster Declarations during Fiscal Years 

2004 through 2011, by Jurisdiction, as of January 31, 2012 59

Table 13: Obligations Per Person Including Hurricane Katrina for 

Disaster Declarations during Fiscal Years 2004 through 

2011, by Jurisdiction 61

Table 14: Obligations Per Person Excluding Hurricane Katrina for 

Disaster Declarations during Fiscal Years 2004 through 

2011, by Jurisdiction 63

Table 15: 2010 Population and Total PA Per Capita Indicator 

Amount for Fiscal Year 2012, by Jurisdiction 69

Table 16: PA Indicator Adjusted by Jurisdiction for 2009 TTR 77
Page iii GAO-12-838 Federal Disaster Assistance 

Figures

Figure 1: Number of Disaster Declarations during Fiscal Years 1953 

through 2011 10

Figure 2: Disaster Declaration Process 13

Figure 3: Number of Disaster Declarations during Fiscal Years 2004 

through 2011, by Jurisdiction 16

Figure 4: Major Disaster Declarations by Type of Assistance, Fiscal 

Years 2004 through 2011 17

Figure 5: Disaster Relief Fund Obligations, Including Hurricane 

Katrina, by Jurisdiction during Fiscal Years 2004 through 

2011, as of January 31, 2012 20

Figure 6: Comparison of Actual Public Assistance Per Capita 

Indicator with the Indicators if They Had Been Adjusted 

for Increases in Personal Income and Inflation, 1986 

through 2011 26

Figure 7: Frequency of Declarations above and below FEMA’s 

Target of 20 Percent or Less for Administrative Costs for 

Small Declarations during Fiscal Years 1989 through 2011 42

Figure 8: Frequency of Declarations above and below FEMA’s 

Target of 15 Percent or Less for Administrative Costs for 

Medium Declarations during Fiscal Years 1989 through 

2011 43

Figure 9: Frequency of Declarations above and below FEMA’s 

Target of 12 Percent or Less for Administrative Costs for 

Large Declarations during Fiscal Years 1989 through 2011 44

Figure 10: Number of Disaster Declarations and Amount of 

Obligations by FEMA Region during Fiscal Years 2004 

through 2011 57
Page iv GAO-12-838 Federal Disaster Assistance 

Abbreviations

DHS Department of Homeland Security

DRF Disaster Relief Fund

FCO federal coordinating officer

FEMA Federal Emergency Management Agency

GDP gross domestic product

GSP gross state product

IA Individual Assistance

IFMIS Integrated Financial Management Information System

JFO joint field office

NEMIS National Emergency Management Information System

PA Public Assistance

PCI state personal income

PDA Preliminary Damage Assessment

PPD-8 Presidential Policy Directive-8 

TTR Total Taxable Resources

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-12-838 Federal Disaster Assistance 

United States Government Accountability Office

Washington, DC 20548

September 12, 2012

The Honorable Jason Chaffetz

Chairman

Subcommittee on National Security,

Homeland Defense, and Foreign Operations

Committee on Oversight and Government Reform

House of Representatives

The Honorable Roy Blunt

United States Senate

The growing number of major disaster declarations has contributed to an 

increase in federal expenditures for disaster assistance.1

 

1

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

declarations. In addition to issuing major disaster declarations, the President may issue 

emergency declarations (42 U.S.C. § 5191) and fire assistance declarations (42 U.S.C. § 

5187). If the President declares an emergency, 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. 

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. 

For example, 

during the 8 fiscal years from 2004 through 2011, Presidents declared 26 

percent more major disaster declarations than during the preceding 8 

fiscal years from 1996 through 2003. The Federal Emergency 

Management Agency (FEMA), a component of the Department of 

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

and recover from disasters, both natural and man-made. Disaster 

declarations can trigger a variety of federal response and recovery 

assistance for government and nongovernmental entities, households, 

and individuals. FEMA’s disaster assistance programs include Individual 

Assistance (IA) and Public Assistance (PA), which provide financial 

 
 

Page 2 GAO-12-838 Federal Disaster Assistance 

assistance to individuals and jurisdictions, respectively.2 Typically, FEMA 

pays 75 percent of the PA costs for disaster declarations, and state and 

local governments pay the other 25 percent. However, governors can 

request that the President approve an adjustment to the cost share, so 

that state and local governments would pay less than 25 percent.3

FEMA’s Disaster Relief Fund (DRF) is the major source of federal 

disaster recovery assistance for state and local governments when a 

disaster is declared. The DRF is appropriated no-year funding, which 

allows FEMA to direct, coordinate, manage, and fund response and 

recovery efforts associated with domestic disasters and emergencies.4

FEMA categorizes DRF obligations according to five categories: IA, PA, 

Hazard Mitigation, Mission Assignments, and Administration.5

 

2

Hereafter in this report, jurisdictions refer to U.S. states, the District of Columbia, U.S. 

territories, Freely Associated States (nations in free association with the United States 

under the Compacts of Free Association), and local governments. The IA program 

provides for the necessary expenses and serious needs of disaster victims that cannot be 

met through insurance or low-interest Small Business Administration loans. For example, 

FEMA may provide temporary housing assistance, counseling, unemployment 

compensation, or medical expenses incurred as a result of a disaster. The PA program 

provides for debris removal; emergency protective measures; and the repair, replacement, 

or restoration of disaster-damaged, publicly owned facilities and the facilities of certain 

private nonprofit organizations that provide services otherwise performed by a government 

agency. 

During 

fiscal years 2004 through 2011, PA was the category with the largest 

obligations. In addition, from fiscal years 2004 through 2011, the costs to 

administer some declarations exceeded the amount of federal assistance 

provided. In August 2011, the DRF diminished to a level that caused 

3

44 C.F.R. § 206.47.

4

No-year funds are available for obligation without fiscal year limitation. An obligation is a 

definite commitment that creates a legal liability of the government for the payment of 

goods and services ordered or received, or a legal duty on the part of the United States 

that could mature into a legal liability by virtue of actions on the part of the other party 

beyond the control of the United States. Payment may be made immediately or in the 

future. An agency incurs an obligation, for example, when it places an order, signs a 

contract, awards a grant, purchases a service, or takes other actions that require the 

government to make payments to the public or from one government account to another. 

GAO, A Glossary of Terms Used in the Federal Budget Process, GAO-05-734SP

(Washington, D.C.: September 2005). 

5

Hazard Mitigation provides additional funds to states to assist communities in 

implementing long-term measures to help reduce the potential risk of future damages to 

facilities. Mission Assignments are costs paid by FEMA for work assigned to other 

agencies and departments.
 

Page 3 GAO-12-838 Federal Disaster Assistance 

FEMA to temporarily halt funding on long-term recovery projects and 

focus on immediate needs. According to the FEMA Administrator, 

because of the shortage of available balances in the DRF, FEMA 

accelerated its efforts to recover previously obligated funds from states 

for completed projects that had unexpended balances. During fiscal year 

2011, FEMA deobligated and recovered $2.2 billion from prior disaster 

declarations.

In 2001, we reported on the need for improvements to the criteria and 

eligibility procedures that FEMA used to make recommendations to the 

President for disaster declaration requests.6 In 2012, we reiterated the 

need for FEMA to, among other things, reexamine the criteria FEMA 

primarily uses to make recommendations to the President for disaster 

declaration requests.7 Furthermore, we have identified as a 21st century 

challenge the determination of costs to be borne by federal, state, and 

local governments or the private sector in preparing for, responding to, 

and recovering from disasters of all types.8

This report provides the results of our review of federal disaster 

assistance efforts by addressing the following questions: (1) For each 

fiscal year from 2004 through 2011, how many disaster declaration 

requests did FEMA receive, how many were approved, for which types of 

disasters, and how much were the associated obligations from the DRF? 

(2) What criteria has FEMA used to recommend to the President that a 

disaster declaration is warranted for PA, and to what extent does FEMA 

assess whether an effective response to a disaster is beyond the 

capabilities of state and local governments? (3) How does FEMA 

 

6

GAO, Disaster Assistance: Improvement Needed in Disaster Declaration Criteria and 

Eligibility Assurance Procedures, GAO-01-837 (Washington, D.C.: Aug. 31, 2001).

7

GAO, 2012 Annual Report: Opportunities to Reduce Duplication, Overlap and 

Fragmentation, Achieve Savings, and Enhance Revenue, GAO-12-342SP (Washington, 

D.C.: Feb. 28, 2012), 321–328.

8

Since September 11, 2001, the federal government has provided billions of dollars to 

state and local governments for planning, equipment, and training to enhance the 

capabilities of first responders to respond to both smaller-scale natural disasters and 

terrorist attacks. However, the federal financial assistance provided in the last several 

years has not been guided by a clear risk-based strategic plan that outlines the role of 

federal, state, and local governments in identifying, enhancing, maintaining, and financing 

critical first responder capabilities for emergencies. See GAO, 21st Century Challenges: 

Reexamining the Base of the Federal Government, GAO-05-325SP (Washington, D.C.: 

Feb. 1, 2005). 
 

Page 4 GAO-12-838 Federal Disaster Assistance 

determine whether a cost share adjustment recommendation for PA is 

warranted and how much additional federal assistance did jurisdictions 

receive during fiscal years 2004 through 2011 because of cost share 

adjustments? (4) What were FEMA’s administrative cost percentages for 

disaster declarations during fiscal years 2004 through 2011, how have 

they changed over time, and what actions is FEMA taking, if any, to 

reduce the costs of delivering disaster assistance?

To determine how many disaster declaration requests FEMA received, 

how many were approved, for which types of disasters, and how much 

the associated obligations were from the DRF, we obtained and analyzed 

data for each disaster declaration approved during fiscal years 2004 

through 2011. We focused on this time frame because it contains the 

most current data for disaster declarations. It also comprises the time 

period after FEMA was merged into the newly created DHS, on March 1, 

2003, and predates Hurricane Katrina in 2005. We focused primarily on 

fiscal years 2004 through 2011; however, to provide historical context and 

to compare results across similar periods, we also reviewed obligations 

data during fiscal years 1989 through 2011. In addition, to provide further 

historical perspective, we include information on the number of disaster 

declarations by jurisdiction from the first presidential disaster declaration 

in fiscal year 1953 through fiscal year 2011 in appendix I. FEMA provided 

data to us from its National Emergency Management Information System 

(NEMIS) and Integrated Financial Management Information System 

(IFMIS). To assess the reliability of these data, we reviewed the data that 

FEMA officials provided and discussed data quality control procedures 

with them. We determined that the data we used from these systems 

were sufficiently reliable for the purposes of this report.

To determine the criteria that FEMA used to recommend to the President 

that a disaster declaration was warranted for PA, and to what extent 

FEMA assessed whether an effective response to a disaster was beyond 

the capabilities of jurisdictions, such as state and local governments, we 

examined FEMA policies, regulations, and other documents related to the 

disaster declaration process. We also interviewed FEMA officials in 

headquarters and 2 of 10 FEMA regions as well as officials in two state 
 

Page 5 GAO-12-838 Federal Disaster Assistance 

emergency management agencies.9 In addition, to determine the 

probability that a state was granted PA if the related damage estimate 

met or exceeded the PA per capita indicator, we obtained and analyzed 

data within Preliminary Damage Assessments (PDA) from fiscal years 

2008 through 2011.10

To determine how FEMA evaluated whether a cost share adjustment 

recommendation was warranted and how much additional federal 

assistance jurisdictions received during fiscal years 2004 through 2011 

because of the adjustments, we obtained and reviewed relevant laws, 

regulations, and policies. We also reviewed Standards for Internal Control 

in the Federal Government to assess FEMA’s process for making 

recommendations to the President on the need for cost share 

adjustments.

To assess the reliability of these data, we reviewed 

the data that FEMA officials provided and discussed data quality control 

procedures with them. We determined that the PDA data were sufficiently 

reliable for the purposes of this report.

11

 

9

In addition to conducting interviews with officials in FEMA headquarters, we conducted 

site visits in September 2011 to the two FEMA regions that had the highest total 

obligations during fiscal years 2004 through 2011. The regional administrative offices were 

located in Atlanta, Georgia, and Denton, Texas, respectively. At each region, we 

interviewed the Regional or Deputy Administrator and various other regional personnel. In 

addition, we visited the emergency management agencies for Georgia and Oklahoma and 

interviewed various officials, including the directors for each of these agencies. We 

selected the Georgia and Oklahoma state emergency management agencies based on 

their respective proximity to FEMA’s regional offices, their high level of experience with 

disasters, and their availability for a visit during September 2011. We wanted to avoid 

states that were actively responding to a disaster during that time. While the information 

we obtained on these site visits is not generalizable, the information provided important 

insights into the disaster declaration process. 

We also obtained and analyzed the cost share 

10The PA per capita indicator is an amount of funding, $1.35 per capita for fiscal year 

2012, that is multiplied by the population of the jurisdiction (for example, state) for which 

the governor is requesting a disaster declaration for PA, to arrive at a threshold amount, 

which is compared with the estimated amount of damage done to public structures. 44 

C.F.R. § 206.48 (a)(1). FEMA uses the comparison as an indicator of the jurisdiction’s 

need for federal assistance. For this analysis, we used 4 years of data (fiscal years 2008 

through 2011) instead of 8 years of data (fiscal years 2004 through 2011) because PDA 

summaries are available in electronic format only back to fiscal year 2008. PDAs are 

conducted to identify the amount of damage a jurisdiction has incurred as a result of a 

disaster. Because of the associated workload and length of time required to provide PDA 

summaries in paper format, we did not request that FEMA provide PDA summaries prior 

to fiscal year 2008.

11GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).
 

Page 6 GAO-12-838 Federal Disaster Assistance 

adjustments and types requested, approved, and denied during fiscal 

years 2004 through 2011. We interviewed FEMA officials who process 

cost share adjustment requests and participate in making 

recommendations to the President as to whether the requests should be 

approved or denied. To assess the reliability of these data, we reviewed 

the data that FEMA officials provided and discussed data quality control 

procedures with them. We determined that the cost share adjustment 

data were sufficiently reliable for the purposes of this report.

To determine what FEMA’s administrative cost percentages were for 

disaster declarations, we obtained DRF obligations, projected obligations, 

and related data for 1,221 disaster declarations during fiscal years 1989 

through 2011.12 The projected obligations were FEMA’s estimates, as of 

April 30, 2012, of the anticipated total obligations—actual to date and 

estimated—for each disaster eligible to receive federal disaster 

assistance after April 30, 2012.

13 We compared FEMA’s administrative 

cost percentages for each disaster declaration from fiscal years 2004 

through 2011 with FEMA’s administrative cost percentage target ranges 

and FEMA’s administrative cost percentages for disaster declarations 

from fiscal years 1989 through 2003.14

 

12We examined fiscal years 1989 through 2011 because FEMA does not maintain detailed 

financial data on disaster declarations prior to fiscal year 1989.

We used these time periods 

because they provide larger sample sizes and an opportunity to assess 

potential trends over a longer period of time. In addition, we included 

projected obligations in our analysis because FEMA officials told us that 

administrative costs are typically higher as a percentage of assistance 

costs in the early months following a disaster. By including projected 

obligations, we were able to analyze disaster obligations—actual and 

13In 2008, we analyzed 83 disaster declarations to determine the reliability of FEMA’s 

projections. We found that after the declarations had been open for 6 months, FEMA’s 

projections were within roughly 10 percent of the amount that was ultimately obligated. 

While the results could not be generalized across all disaster declarations, the analysis 

provides valuable insight into the reliability of FEMA’s projections after a declaration has 

been open for 6 months. As our projections data were as of April 30, 2012, all open 

disaster declarations from fiscal years 2004 through 2011 had been open for at least 6 

months. Thus, we believe the projections are reliable for purposes of this report. Our 2008 

analysis can be found within GAO, Disaster Cost Estimates: FEMA Can Improve Its 

Learning from Past Experience and Management of Disaster-Related Resources, 

GAO-08-301 (Washington, D.C.: February 2008). 

14The administrative costs that we identify in this report were defined by FEMA as 

obligations from the DRF that support the delivery of disaster assistance. 
 

Page 7 GAO-12-838 Federal Disaster Assistance 

estimated—for the entire time period that disaster declarations were in 

the following three levels of status: programmatically open, closed, and 

reconciled.15

We conducted this performance audit from July 2011 through September 

2012 in accordance with generally accepted government auditing 

standards.

To assess the reliability of these data, we reviewed the data 

that FEMA officials provided and discussed data quality control 

procedures with them. We determined that the DRF data were sufficiently 

reliable for the purposes of this report. To determine what actions FEMA 

is taking, if any, to reduce the costs of delivering disaster assistance, we 

reviewed relevant FEMA documents and briefings, and interviewed FEMA 

officials.

16 Those standards require that we plan and perform the audit 

to obtain sufficient, appropriate evidence to provide a reasonable basis 

for our findings 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. For more 

information on our scope and methodology, see appendix II.

The Robert T. Stafford Disaster Relief and Emergency Assistance Act 

(Stafford Act), as amended, established the basic process for states to 

request a presidential disaster declaration.17

 

15According to FEMA officials, administrative costs are typically higher as a percentage of 

assistance costs in the early months following a disaster, with the administrative cost 

percentage typically decreasing as the declaration matures. Thus, administrative costs for 

declarations with ongoing assistance, particularly recently declared disasters, could 

overstate final administrative costs as a percentage of total disaster assistance 

obligations. FEMA has three levels of status for disaster declarations—programmatically 

open, closed, and reconciled. Programmatically open means that all financial decisions 

are not completed and eligible work remains. Closed means that financial decisions have 

been made, but all projects are not complete. Reconciled means that all projects are 

complete and the FEMA-state agreement is closed.

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 and local 

16During this time, we reported preliminary observations on opportunities to reduce the 

costs to the federal government related to major disaster declarations. See 

GAO-12-342SP. 321-328. 

1742 U.S.C. § 5170.

Background
 

Page 8 GAO-12-838 Federal Disaster Assistance 

governments, tribes, and certain nonprofit organizations and individuals.18

FEMA’s disaster declarations process is implemented by FEMA 

headquarters as well as its 10 regional offices. FEMA’s Administrator, in 

accordance with the Post-Katrina Emergency Management Reform Act of 

2006 (Post-Katrina Act), appoints a Regional Administrator to head each 

regional office.

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 local governments 

and certain private nonprofit organizations to alleviate the damage 

resulting from such disasters.

19 Regional Administrators—in partnership with state, local, 

and tribal governments, and other nongovernmental organizations—

oversee emergency management activities within their respective 

geographical area.20 Joint Field Offices (JFO) are temporary FEMA 

offices established to respond to declared disasters and are headed by 

Federal Coordinating Officers (FCO) who, among other things, coordinate 

the activities of the disaster reserve workforce deployed for a particular 

disaster. Once a disaster is declared, FEMA deploys Disaster Assistance 

Employees and any other employees needed to the affected 

jurisdiction(s).21 FEMA provides assistance through the PA, IA, and 

Hazard Mitigation programs as well as through Mission Assignments. For 

instance, some declarations may provide grants only for IA and others 

only for PA. Hazard Mitigation grants, on the other hand, are available for 

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

Mitigation plan.

 

1842 U.S.C. § 5121 et seq.

196 U.S.C. § 317.

20“Emergency management” is defined as the managerial function charged with creating 

the framework within which communities reduce vulnerability to hazards and cope with 

disasters. 

21Disaster Assistance Employees are a cadre of temporary reserve staff who go to field 

locations to help communities respond to and recover from disasters.
 

Page 9 GAO-12-838 Federal Disaster Assistance 

According to FEMA, the agency is evolving from originally focusing on 

grants management to being an organization implementing increasingly 

more complex programs, with an increasingly sophisticated and 

specialized workforce and procedures in response to changing 

circumstances and expectations. As illustrated by figure 1, the number of 

disaster declarations has significantly increased since 1953, when the 

first presidential disaster declaration was issued.22

 

22The first presidential disaster declaration was issued in 1953 under the authority of the 

Disaster Relief Act of 1950. Pub. L. No. 81-875, 64 Stat. 1109.

See appendix I for 

more information about the number of disaster declarations.

The Changing Disaster 

Declaration Environment
 

Page 10 GAO-12-838 Federal Disaster Assistance 

Figure 1: Number of Disaster Declarations during Fiscal Years 1953 through 2011

Various factors have contributed to the increase in disaster declarations. 

Population growth has occurred in U.S. geographic areas that are 

vulnerable when a disaster hits, such as those near coastlines. FEMA 

officials also cited more active weather patterns as a factor. FEMA 
 

Page 11 GAO-12-838 Federal Disaster Assistance 

guidance to states and localities and the enhanced capabilities and 

professionalization of state and local emergency management personnel 

have also been factors. For example, in 1999, FEMA published a list of 

factors that it considers when evaluating disaster declaration requests. 

According to FEMA and state emergency management officials from two 

states, the guidance, along with state and local emergency management 

officials’ additional knowledge about the process and the enhanced 

transparency of the process for federal disaster declarations, has helped 

state and local officials better justify a request for federal disaster 

assistance. Increased media attention on disasters, especially those in 

which there have been casualties or deaths, has also been a factor, 

according to FEMA and state emergency management officials for two 

states.

The disaster assistance process generally starts at the local level, 

proceeds to the county and state levels, and then to the federal level. The 

Stafford Act states that the governor of the affected state shall request a 

declaration by the President that a disaster exists.23 FEMA is the primary 

federal disaster assistance agency, but others can have major roles, such 

as the U.S. Army Corps of Engineers, which can provide engineering and 

contracting support to FEMA.24

As part of the request to the President, a governor must affirm that the 

state’s emergency plan has been implemented and the situation is of 

such severity and magnitude that effective response is beyond the 

capabilities of the state and the affected local governments and that 

federal assistance is necessary, among other things.25

 

2342 U.S.C. § 5170. In addition to issuing major disaster declarations, the President may 

issue emergency declarations. If the President declares an emergency, 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.

Before a governor 

24Federal agencies may provide assistance under Titles IV and V of the Stafford Act only 

upon a presidential declaration, but some federal agencies may respond to disasters 

under separate authorities.

2544 C.F.R. § 206.36.

Disaster Declaration 

Process
 

Page 12 GAO-12-838 Federal Disaster Assistance 

asks for federal disaster assistance, state and local officials typically 

conduct an initial PDA to identify the amount of damage and determine if 

the damage exceeds their capability to respond and recover without 

federal assistance. Based on the initial PDA findings, a joint PDA, in 

which FEMA participates, may be requested by the governor.26 FEMA 

uses the joint PDA in its evaluation of the state’s need for federal 

assistance and makes a recommendation to the President as to whether 

the request for a disaster declaration should be approved or denied. Later 

in this report, we discuss in more detail how FEMA evaluates the need for 

PA. To evaluate the need for IA, FEMA considers various factors, 

including insurance coverage; the extent to which volunteer agencies and 

state or local programs can meet the needs of disaster victims; 

concentration of damages due to the disaster; number of deaths and 

injuries; amount of disruption to normal community services; amount of 

emergency needs, such as extended or widespread loss of power or 

water; and special populations, such as elderly or low-income people.27

Figure 2 shows the basic process that is followed from the time a disaster 

occurs until the President approves or denies a governor’s disaster 

declaration request.28

 

26The requirement for a joint PDA may be waived for those incidents of unusual severity 

and magnitude that do not require field damage assessments to determine the need for 

supplemental federal assistance or in other instances as determined by the Regional 

Administrator upon consultation with the state. 44 C.F.R. § 206.33.

2744 C.F.R. § 206.48(b).

28In November 2009, FEMA implemented a new policy for disaster declarations for 

snowstorms. Prior to that, snowstorms were only declared as emergencies. The process 

for snowstorms is the same as that used for other types of disasters; however, a disaster 

declaration resulting from a snowstorm requires record or near-record snowfall—within 10 

percent of a county’s record snowfall as measured in inches. Covered costs for 

snowstorms include sanding, salting, de-icing, and removing snow. 
 

Page 13 GAO-12-838 Federal Disaster Assistance 

Figure 2: Disaster Declaration Process
 

Page 14 GAO-12-838 Federal Disaster Assistance 

During this period, FEMA received 629 disaster declaration requests and 

approved 539 of them. Most disaster declarations were for severe storms. 

FEMA anticipates that when all disasters declared during fiscal years 

2004 through 2011 are closed, its total obligations for these disasters will 

exceed $90 billion.

The President received requests from governors during fiscal years 2004 

through 2011 for 629 disaster declarations and approved 539 of them, or 

86 percent, as shown in table 1.

Table 1: Number of Disaster Declarations Requested and Approved during Fiscal 

Years 2004 through 2011

Fiscal year Number requested Number approved Percentage approved

2004 76 65 86

2005 55 45a 82

2006 67 53 79

2007 78 68 87

2008 79 68 86

2009 72 63 88

2010 90 79 88

2011 112 98 88

Total 629 539 86

Source: GAO analysis of FEMA data.

a

Despite the amount of destruction wrought by Hurricane Katrina in fiscal year 2005, only 4 of the 45 

disaster declarations were associated with Hurricane Katrina—1 declaration each in Florida, 

Alabama, Mississippi, and Louisiana. 

Governors can appeal a decision when the President initially denies a 

disaster declaration request.29

 

2944 C.F.R. § 206.46.

During fiscal years 2004 through 2011, 

governors made 629 requests for disaster declarations, and the President 

ultimately denied 90 of them, or 14 percent.

Over 500 Disasters 

Were Declared during 

Fiscal Years 2004 

through 2011 with 

Total Obligations of 

Over $90 Billion 

Anticipated

Most Declarations for 

Severe Storms, Highest in 

Southeast and Central 

Midwest
 

Page 15 GAO-12-838 Federal Disaster Assistance 

FEMA has 10 regions throughout the United States that, among other 

things, provide technical assistance to state and local officials and make 

recommendations to FEMA headquarters as to whether a disaster 

declaration is warranted. Individual FEMA regions had varying numbers 

of disaster declarations during fiscal years 2004 through 2011. The two 

FEMA regions that had the most disaster declarations were Region IV in 

the Southeast and Region VII in the central Midwest, which together 

accounted for 163, or 30 percent, of the 539 declarations. The two FEMA 

regions that had the fewest declarations were Regions IX and X along the 

west coast, including Alaska, which together accounted for 71 

declarations, or 13 percent. See appendix I, figure 10, for a map that 

shows the number of declarations by FEMA region.

During fiscal years 2004 through 2011, the average number of disaster 

declarations was 9.3 for each of the 58 jurisdictions—that is, the 50 

states, the District of Columbia, 5 territories, and 2 Freely Associated 

States.

30 However, our analysis shows that some jurisdictions had over 

20 disaster declarations, while other jurisdictions had 3 or fewer disaster 

declarations during this period. For example, Oklahoma had the most 

disaster declarations at 25, while Colorado and Guam had 1 each and the

Marshall Islands did not have any. In addition, the 5 jurisdictions with the 

highest number of disaster declarations accounted for 105, or 19 percent, 

of the 539 declarations during fiscal years 2004 through 2011, whereas 

the 4 jurisdictions with the lowest number of disaster declarations 

accounted for 4, or less than 1 percent.31

 

30The 5 territories are American Samoa, Guam, the U.S. Virgin Islands, the 

Commonwealth of the Northern Mariana Islands, and the Commonwealth of Puerto Rico.

The 2 Freely Associated States are the Federated States of Micronesia and the Republic 

of the Marshall Islands. 

See figure 3 for the number of 

disaster declarations for each jurisdiction.

31For the analysis of the jurisdictions with the lowest number of disaster declarations 

during fiscal years 2004 through 2011, we report on 4 jurisdictions because 6 jurisdictions 

tied for the fifth lowest, with 3 disaster declarations each.
 

Page 16 GAO-12-838 Federal Disaster Assistance 

Figure 3: Number of Disaster Declarations during Fiscal Years 2004 through 2011, by Jurisdiction

Note: In addition to Pohnpei, the Federated States of Micronesia consists of three additional major 

island groups, including Chuuk, Yap, and Kosrae. 

As reported by FEMA, severe storms accounted for 71 percent of 

declarations during fiscal years 2004 through 2011. According to FEMA 

officials, a disaster is classified as a severe storm when multiple stormrelated incidents (for example, floods or heavy rains) affect a jurisdiction, 

but no single incident type is responsible for the majority of the damage. 
 

Page 17 GAO-12-838 Federal Disaster Assistance 

See appendix I, table 11, for the number and percentage for each of the 

incident types that occurred during fiscal years 2004 through 2011.

For each disaster declaration, various types of assistance can be 

approved. For example, the President can approve PA only, IA only, or 

PA and IA for each declaration. As shown in figure 4, during fiscal years 

2004 through 2011, 6 percent of the declarations were awarded for IA 

only, while a total of 94 percent of declarations were awarded for either 

PA only or IA and PA.

Figure 4: Major Disaster Declarations by Type of Assistance, Fiscal Years 2004 

through 2011
 

Page 18 GAO-12-838 Federal Disaster Assistance 

Through January 31, 2012, FEMA obligated $80.3 billion, or an average 

of about $10 billion a year, from the DRF for 539 disasters declared 

during fiscal years 2004 through 2011; and FEMA anticipates that when 

all 539 declarations are closed, obligations will be about $91.5 billion. 

Thirteen of these declarations had incurred obligations of over $1 billion 

each.32 Almost half of the $80.3 billion in obligations was for Hurricane 

Katrina. Excluding obligations of $39.7 billion for Hurricane Katrina, FEMA 

obligated $40.6 billion for the other disaster declarations during fiscal 

years 2004 through 2011, or an average of about $5 billion a year. Total 

obligations are higher for fiscal years 2004, 2005, and 2008 than for the 

remaining 5 years primarily because of hurricanes that occurred with 

more frequency or force during those years. For example, over half of the 

$8.8 billion for disasters declared in fiscal year 2004 was due to four 

hurricanes, over half of the $44.9 billion for disasters declared in fiscal 

year 2005 was for Hurricane Katrina, and about half of the $10.3 billion 

for disasters declared in fiscal year 2008 was for Hurricanes Ike and 

Gustav. Table 2 shows the obligations by fiscal year.

 

32In addition to the $80.3 billion for the 539 disaster declarations during fiscal years 2004 

through 2011, FEMA obligated funds for disaster declarations that occurred prior to fiscal 

year 2004 but were still receiving obligations during fiscal years 2004 through 2011. The 

$80.3 billion in obligations also excludes FEMA obligations for Emergency Declarations, 

Fire Management Assistance Grants, and non-DRF obligations of appropriated funds for 

FEMA and federal agencies outside of DHS, such as the Department of Defense and 

Department of Health and Human Services. In addition to the 13 disasters that had 

exceeded $1 billion in obligations, other disasters declared during fiscal years 2004 

through 2011 that were still open as of January 31, 2012, could reach obligations of over 

$1 billion as FEMA continues to obligate funds for them. 

Total Obligations of Over 

$90 Billion Anticipated for 

Disasters Declared during 

Fiscal Years 2004 through 

2011
 

Page 19 GAO-12-838 Federal Disaster Assistance 

Table 2: Obligations by Fiscal Year for 539 Disaster Declarations during Fiscal Years 2004 through 2011

(Dollars in millions) 

Fiscal year

Public 

Assistance

Individual 

Assistance

Hazard 

Mitigation 

Mission 

Assignment Administration Totala

2004 $3,725 $2,741 $435 $817 $1,077 $8,794

2005

(including Katrina)

17,770 15,529 1,431 4,143 5,993 44,867

2005

(excluding Katrina)

2,067 1,504 278 472 776 5,097

2006 2,605 633 206 151 386 3,982

2007 1,628 336 238 6 281 2,488

2008 6,116 1,880 816 157 1,394 10,364

2009 1,700 340 236 41 455 2,772

2010 1,616 828 120 6 451 3,022

2011 1,599 1,213 41 438 769 4,061

Total

(including Katrina)

$36,759 $23,500 $3,522 $5,761 $10,806 $80,349a

Total

(excluding Katrina)

$21,057 $9,476 2,369 $2,090 $5,589 $40,579a

Source: GAO analysis of FEMA data.

Note: This analysis shows obligations from the DRF only and does not include any potential 

administrative cost expenditures from FEMA’s other annual appropriations. Also, the obligations 

exclude obligations by other federal agencies and state and local governments. 

a

Obligations for each year may not add up to the total obligations reported because of rounding. 

Obligations for disaster declarations during fiscal years 2004 through 

2011 varied greatly by FEMA region and jurisdiction. FEMA Region VI 

had the highest obligations at $40.0 billion. However, when excluding 

obligations from all FEMA regions due to Hurricane Katrina, FEMA 

Region IV had the highest obligations at $13.2 billion. FEMA Region X 

had the lowest obligations at $0.6 billion. As shown in figure 5, the 

amount of obligations also varied greatly by jurisdiction for disasters 

declared during fiscal years 2004 through 2011. For example, Louisiana 

had the highest obligations, at $32.3 billion, but after excluding obligations 

for Hurricane Katrina, Florida had the highest obligations, at $9.3 billion, 

while for the jurisdictions with the lowest obligations, Guam had $1.9 

million and the Marshall Islands did not have any. As a comparison, the 

nationwide average obligations per jurisdiction were $1.38 billion, and 

decreased to $700 million when obligations for Hurricane Katrina were 

excluded. Appendix I, figure 10, shows the obligations by FEMA region 

for fiscal years 2004 through 2011.
 

Page 20 GAO-12-838 Federal Disaster Assistance 

Figure 5: Disaster Relief Fund Obligations, Including Hurricane Katrina, by Jurisdiction during Fiscal Years 2004 through 

2011, as of January 31, 2012 

Note: For the jurisdictions that had disaster declarations for Hurricane Katrina, the obligations 

excluding Hurricane Katrina were Alabama, $1.4 billion; Florida, $9.3 billion; Louisiana, $3.8 billion; 

and Mississippi, $236 million. In addition to Pohnpei, the Federated States of Micronesia consists of 

three additional major island groups, including Chuuk, Yap, and Kosrae. 

Furthermore, obligations for individual disaster declarations declared 

during fiscal years 2004 through 2011 varied greatly. For example, as of 

January 31, 2012, FEMA had obligated $28.5 billion for Louisiana’s fiscal 

year 2005 Hurricane Katrina disaster declaration compared with about 
 

Page 21 GAO-12-838 Federal Disaster Assistance 

$803,000 for a South Dakota disaster declaration during that same fiscal 

year. Disaster declarations can take over a decade to close; therefore, to 

obtain a more comprehensive and longer-term perspective, we analyzed 

obligations for 811 disaster declarations during fiscal years 1989 through 

2011 that had been closed as of January 31, 2012.33

Table 3: Number and Percentage of Closed Disasters Declared during Fiscal Years 

1989 through 2011, by Obligation Amounts as of January 31, 2012

Of the 811 closed 

declarations, we found that 440, or 54 percent, had obligations of less 

than $10 million (see table 3).

Obligations for each disaster 

declarationa Number of disaster 

declarations Percentage of total

Less than $1 million 21 3 

$1 million to less than $5 million 261 32

$5 million to less than $10 million 158 19

$10 million to less than $25 million 179 22

$25 million to less than $50 million 81 10

$50 million to less than $100 million 55 7 

At least $100 million 56 7 

Total 811 100

Source: GAO analysis of FEMA data.

a

Obligations include the funds obligated by FEMA from the DRF and exclude obligations by other 

federal agencies and state and local governments. These amounts are not in constant, inflationadjusted dollars, because the data were not detailed enough to identify the specific year an obligation 

was made. 

For those disaster declarations approved during fiscal years 2004 through 

2011, we analyzed the total obligations as of April 30, 2012, for closed 

disasters, and the total projected obligations—actual to date and 

estimated—for those declarations that remained open as of April 30, 

2012.34

 

33We analyzed reconciled and closed disaster declarations because all financial decisions 

have been made for these declarations. 

Specifically, for open declarations as of April 30, 2012, instead of 

analyzing how much FEMA had obligated as of that date, we analyzed 

34Throughout this report, projected obligations refers to the actual amount obligated by 

FEMA as of April 30, 2012, plus the amount FEMA anticipates obligating between April 

30, 2012, and the date a disaster declaration is ultimately reconciled. The information we 

analyzed included projections data for each declaration approved during fiscal years 1989 

through 2011; however, the results within table 4 only focus on fiscal years 2004 to 2011.
 

Page 22 GAO-12-838 Federal Disaster Assistance 

the amount FEMA had obligated plus the amount FEMA anticipated it 

would obligate from the time a declaration was approved through its 

closure. On the basis of our analysis, when all 539 declarations that were 

declared during fiscal years 2004 through 2011 are eventually closed, 

FEMA anticipates that 193, or 36 percent, will have total obligations of 

less than $10 million, thus signifying that these were relatively small 

disasters (see table 4).

Table 4: Number and Percentage of Disasters Declared during Fiscal Years 2004 

through 2011, by Combined Actual and Projected Total Obligation Amounts, as of 

April 30, 2012

Obligations for each disaster 

declarationa Number of disaster 

declarations

Percentage of 

total 

Less than $1 million 5 1

$1 million to less than $5 million 99 18

$5 million to less than $10 million 89 17

$10 million to less than $25 million 140 26

$25 million to less than $50 million 76 14

$50 million to less than $100 million 55 10

At least $100 million 75 14

Total 539 100

Source: GAO analysis of FEMA data.

a

Obligations include the funds obligated by FEMA from the DRF and exclude obligations by other 

federal agencies and state and local governments. These amounts are not in constant, inflationadjusted dollars, because the data were not detailed enough to identify the specific year an obligation 

was made. 

The per capita damage indicator FEMA uses to assess a jurisdiction’s 

eligibility for PA is the primary factor on which disaster declaration 

decisions are based. However, the per capita damage indicator is 

artificially low. In addition, FEMA’s process to determine eligibility for 

federal assistance does not comprehensively assess a jurisdiction’s 

capability to respond to and recover from a disaster on its own.

Eligibility for 

Assistance Is 

Primarily Determined 

Using a Damage 

Estimate Indicator
 

Page 23 GAO-12-838 Federal Disaster Assistance 

According to FEMA and state emergency management officials, FEMA 

has primarily relied on a single indicator, the statewide per capita damage 

indicator, to determine whether to recommend that a jurisdiction receive 

PA funding. In fiscal year 2012, the per capita indicator is $1.35.35 Thus, a 

state with 10 million people would generally have to incur $13.5 million in 

estimated eligible disaster damages to public structures for FEMA to 

recommend that a disaster declaration for PA is warranted.36 However, 

other factors could also influence the recommendation, such as whether a 

jurisdiction has incurred multiple disasters within a short period of time. Of 

the 58 jurisdictions for fiscal year 2012, based on population, California 

has the highest statewide indicator total, at $50.3 million, while Wyoming 

has the lowest amount at $760,895.37

FEMA’s method to determine the affected jurisdictions’ capabilities to 

respond without federal assistance relies on a governor’s certification and 

damage estimates. The Stafford Act requires that a governor’s request for 

a disaster declaration be based on a finding that the disaster is of such 

severity and magnitude that an effective response is beyond the 

capabilities of the jurisdiction and that federal assistance is necessary.

See appendix III, table 15, for the 

total PA per capita indicator amounts for each of the 58 jurisdictions.

38

FEMA officials stated that governors must certify in their letter to the 

President requesting a disaster declaration that the disaster is beyond the 

capabilities of the jurisdiction. FEMA regulations list quantitative and 

qualitative factors, such as recent disasters within the same jurisdiction 

that the agency considers when determining whether a disaster 

declaration is warranted.39

 

3576 Fed. Reg. 63,936 (Oct. 14, 2011).

However, in describing the declarations 

process, FEMA and emergency management officials in two states said 

that FEMA uses the statewide per capita indicator as the primary 

36In addition to using a PA indicator for states, FEMA uses a PA indicator for counties to 

help determine a county’s need for assistance. The countywide per capita indicator for 

fiscal year 2012 is $3.39. 76 Fed. Reg. 63,936 (Oct. 14, 2011).

37FEMA has established a minimum threshold of $1 million in PA damages per disaster in 

the belief that even the lowest population states can cover this level of public assistance 

damage. 44 C.F.R. § 206.48(a)(1).

3842 U.S.C. § 5170. In this report, we consider a state’s capabilities to respond to and 

recover from a disaster to include elements such as the fiscal capacity and preparedness 

of the state. 

3944 C.F.R. § 206.48.

FEMA Relies Almost 

Exclusively on a Single 

Indicator
 

Page 24 GAO-12-838 Federal Disaster Assistance 

determining factor for PA funding. This damage indicator, which FEMA 

has used since 1986, is essentially a proxy fiscal measure of a state’s 

capacity to respond to and recover from a disaster, rather than a more 

comprehensive assessment of a state’s fiscal capacity.

According to our analysis of readily available indicator data, as well as 

officials in two FEMA regions and state emergency management officials 

in two states, the principal factor used to determine eligibility for a disaster 

declaration was whether the damage estimate exceeded the PA per 

capita indicator. Our analysis of 246 disaster declarations during fiscal 

years 2008 through 2011 identified the PA per capita indicator as having 

been the primary determining factor—essentially being used as an 

eligibility threshold.40 Specifically, 244 of the 246 approved disaster 

declarations that we reviewed, or 99 percent, had PA damage estimates 

that met or exceeded the PA per capita indicator in effect in the year in 

which the disaster was declared.41 Seven gubernatorial requests for a 

disaster declaration during fiscal years 2008 through 2011 had a damage 

estimate higher than the PA per capita indicator yet were denied for 

various reasons, such as the damage being a result of multiple storms or 

the normal depreciation of structures rather than a single disaster.

Because FEMA’s current per capita indicator does not reflect the rise in 

(1) per capita personal income since it was created in 1986 or (2) inflation 

from 1986 to 1999, the indicator is artificially low. In 1986, FEMA 

proposed a $1.00 per capita indicator for PA as a means of gauging a 

jurisdiction’s fiscal capacity.42

 

40The Stafford Act prohibits a geographic area from being precluded from receiving 

assistance solely by virtue of an arithmetic formula or sliding scale based on income or 

population. 42 U.S.C. § 5163. We only reviewed FEMA’s PDA summaries as far back as 

fiscal year 2008 because that is when FEMA began maintaining them in electronic format. 

For each of the 308 disaster declarations during fiscal years 2008 through 2011, we 

reviewed the PDA summary to determine whether a governor requested PA and the 

President approved PA, and whether the PA damage estimate met or exceeded the PA 

per capita indicator. Of the 308 PDA summaries, 246 of them included the data necessary 

to determine whether the PA damage estimate met or exceeded the PA per capita 

indicator. 

The indicator was based on the 1983 per 

capita personal income nationwide, then estimated at $11,667. Current 

41As discussed later in this report, the PA per capita indicator remained at $1.00 from 

1986 through 1999 and has been adjusted for inflation on an annual basis since 2000.

4251 Fed. Reg. 13,332 (Apr. 18, 1986).

FEMA’s Per Capita 

Indicator Used to Assess 

Eligibility Is Artificially 

Low
 

Page 25 GAO-12-838 Federal Disaster Assistance 

FEMA officials were unable to explain how per capita personal income 

was used to establish the indicator level at $1.00. However, FEMA 

documentation noted that the agency thought it reasonable that a state 

would be capable of providing $1.00 for each resident of that state to 

cover the damage from a disaster. While the proposed rule was not 

codified in 1986, FEMA began to use the $1.00 per capita indicator 

informally as part of its preliminary damage assessment efforts and did 

not adjust the indicator annually for either inflation or increases in national 

per capita income. In 1998, FEMA considered adjusting the PA indicator 

to $1.51 to account for inflation since 1986, but because of input from 

state emergency management officials, FEMA decided not to do so.

In 1999, FEMA issued a rule codifying the per capita indicator at $1.00, 

which was stipulated to include an annual adjustment for inflation, but the 

rule was silent on whether the indicator would continue to be based on 

nationwide per capita personal income.43

 

4364 Fed. Reg. 47,697 (Sept. 1, 1999).

As a result, the indicator has 

risen 35 percent from $1.00 to $1.35 in the 13 years since FEMA began 

its annual inflationary adjustments. Figure 6 shows the actual increases in 

the per capita indicator for PA from 1986 to 2010 compared with the 

increases that would have occurred if FEMA had adjusted the indicator 

for inflation or the increase in per capita personal income during this 

period.
 

Page 26 GAO-12-838 Federal Disaster Assistance 

Figure 6: Comparison of Actual Public Assistance Per Capita Indicator with the 

Indicators if They Had Been Adjusted for Increases in Personal Income and 

Inflation, 1986 through 2011

FEMA officials stated that the rise in construction and other costs to 

respond to and recover from disasters have outpaced the rise in the per 

capita indicator. In jurisdictions with smaller populations, damage to a 

single building or facility, such as a water treatment facility, could result in 

a damage estimate sufficient to meet the per capita damage threshold 

and warrant a disaster declaration. For example, the damage from 

Hurricane Katrina to a single water treatment facility in Carrollton, 

Louisiana, exceeded Louisiana’s 2005 per capita threshold.44

 

44The Carrollton, Louisiana, water treatment facility was eligible for and did receive PA 

funding.

In addition, 

the Washington National Cathedral incurred approximately $15 million of 

damage during the August 23, 2011, earthquake in Washington, D.C., 
 

Page 27 GAO-12-838 Federal Disaster Assistance 

which has a per capita damage indicator threshold of less than $1 

million.45

The Stafford Act requires that conditions due to a disaster be beyond a 

jurisdiction’s (state and local) capability to respond effectively before 

disaster assistance from the federal government is warranted.46 The law, 

however, prohibits FEMA from denying federal assistance solely by virtue 

of an arithmetic formula or sliding scale based on income or population.47

According to Standards for Internal Control in the Federal Government, 

activities should be established to monitor indicators and controls should 

be aimed at validating the propriety and integrity of such indicators.48

Our analysis of actual and projected obligations for 508 disaster 

declarations in which PA was awarded during fiscal years 2004 through 

2011 showed that fewer disasters would have met either the personal 

income-adjusted or the inflation-adjusted PA per capita indicators for the 

years in which the disaster was declared.

Had 

the indicator been adjusted for inflation beginning when FEMA started 

using it in 1986, the indicator would have risen more than 100 percent, 

from $1.00 to $2.07 in 2012. Had the indicator been adjusted for 

increases in per capita personal income since 1986, the indicator would 

have risen over 250 percent, from $1.00 to $3.57 in 2011, based on 2011 

national per capita personal income of $41,663.

49

 

45FEMA determined that the National Cathedral was not eligible for PA; therefore the 

damage estimate was not included in the PDA and the cathedral was not eligible to 

receive PA funds. The epicenter of the earthquake was in Virginia.

Specifically, our analysis 

showed that 44 percent of the 508 disaster declarations would not have 

met the PA per capita indicator if adjusted for the change in per capita 

personal income since 1986. Similarly, our analysis showed that 25 percent 

4642 U.S.C. § 5170.

4742 U.S.C. § 5163.

48GAO/AIMD-00-21.3.1. 

49Our analysis included FEMA’s projected obligations as of April 30, 2012, for only those 

508 disaster declarations that had received PA and had been declared during fiscal years

2004 through 2011. We did not analyze the 31 disaster declarations that received IA only. 

We analyzed obligations instead of PDA damage estimates for PA because FEMA 

officials stated that estimating the damage from a disaster is sometimes stopped when the

estimate equals or exceeds the PA per capita indicator. Therefore, we concluded that 

conducting the analysis using projected obligations would be more accurate than using 

incomplete PDA damage estimates for PA. 
 

Page 28 GAO-12-838 Federal Disaster Assistance 

of the 508 disaster declarations would not have met the PA per capita 

indicator if adjusted for inflation since 1986.50 Thus, had the indicator been 

adjusted annually since 1986 for personal income or inflation, fewer 

jurisdictions would have met the eligibility criteria that FEMA primarily used 

to determine whether federal assistance should be provided, which would 

have likely resulted in fewer disaster declarations.51

In discussions with FEMA officials about raising the per capita damage 

indicator, they noted that updating the indicator completely in a single 

year could create problems for jurisdictions, which, in response, may 

need to increase their rainy day fund or take other actions to adjust to the 

change. However, FEMA officials stated that adjusting the indicator in a 

phased approach over several years would be more feasible for 

jurisdictions. The current annual inflation adjustment generally increases 

the damage indicator incrementally. However, were the “catch-up” 

inflation adjustment (from $1.35 to $2.07) implemented in a single year, 

the increase would be considerably more than the annual inflation 

adjustments since 1999. For example, for a jurisdiction with a population 

of 5 million, fully implementing the catch-up adjustment for inflation would 

raise the damage indicator from $6.75 million to $10.35 million. Adjusting 

the indicator in phases over several years could help FEMA examine 

future requests for disaster declarations in a manner that reflects changes 

in per capita income or inflation since 1986 and provide jurisdictions more 

time to plan for and adjust to the change.

 

50In addition to our analysis of the 508 disaster declarations, we separately analyzed 144 

of the 508 declarations wherein all financial decisions had been made as of January 31, 

2012. Thus, we relied on actual obligations rather than projections to conduct the analysis. 

Our analysis of the 144 declarations showed that fewer disasters would have met either 

the personal income-adjusted or the inflation-adjusted PA per capita indicators for the 

years in which the disasters were declared. Specifically, our analysis showed that 49 

percent of the 144 disaster declarations would not have met the PA per capita indicator if 

adjusted for the change in per capita personal income since 1986. Similarly, 31 percent of 

the 144 disaster declarations would not have met the PA per capita indicator if adjusted 

for inflation since 1986.

51In May 2012, the DHS Office of Inspector General reached a similar conclusion based 

on its analysis that, if FEMA had continually updated the indicator for changes in 

economic conditions, many recent disasters would not have met the financial statewide 

per capita indicator for federal assistance. See DHS Office of Inspector General, 

Opportunities to Improve FEMA’s Public Assistance Preliminary Damage Assessment 

Process, OIG-12-709 (Washington, D.C.: May 2, 2012). 
 

Page 29 GAO-12-838 Federal Disaster Assistance 

Reliance on the PA per capita indicator to determine a jurisdiction’s 

eligibility for federal assistance—whether the indicator is artificially low or 

adjusted for increases in personal income or inflation—does not provide 

an accurate measure of a jurisdiction’s capability to respond to or recover 

from a disaster without federal assistance. Determining a jurisdiction’s 

fiscal capacity is important because a jurisdiction with greater resources 

should be able to more easily recover in the aftermath of a disaster than a 

jurisdiction with fewer resources. Further, a jurisdiction’s fiscal capacity is 

an important component of the jurisdiction’s overall response and 

recovery capability. 

In 1999, when the rule was codified to set the per capita indicator at 

$1.00, FEMA stated that it recognized that a straight per capita figure may 

not be the best measurement of a state’s capability, but that it provided a 

simple, clear, consistent, and long-standing means of measuring the 

severity, magnitude, and impact of a disaster while at the same time 

ensuring that the President can respond quickly and effectively to a 

governor’s request for assistance.52 As we reported in 2001, per capita 

personal income is a relatively poor indicator of a jurisdiction’s fiscal 

capacity because it does not comprehensively measure all income 

potentially subject to jurisdiction taxation and is not necessarily indicative 

of jurisdiction or local capability to respond effectively without federal 

assistance.53

 

5264 Fed. Reg. at 47,697 (Sept. 1, 1999); 64 Fed. Reg. 3910, 3911 (Jan. 26, 1999).

For example, it does not include income produced in a 

jurisdiction unless it is received as income by a jurisdiction resident. Thus, 

profits retained by corporations for business investment, though 

potentially subject to jurisdiction taxation, are not included in a jurisdiction 

per capita income measure because they do not represent income 

received by jurisdiction residents. In 2001, we recommended that FEMA 

consider alternative criteria. FEMA’s response noted that we provided 

valuable input for the FEMA team that was reviewing the disaster 

declaration process and the criteria used to assess jurisdiction damages. 

According to FEMA, in 2001, the President’s budget for fiscal year 2002 

included a provision for the development of improved guidelines for 

disaster assistance that provided jurisdictions with meaningful criteria that 

must be met to become eligible for federal disaster assistance. FEMA 

undertook a review of disaster declaration guidelines; however, no 

53GAO-01-837. 

FEMA’s Eligibility Process 

Does Not 

Comprehensively Assess a 

Jurisdiction’s Capability to 

Respond and Recover
 

Page 30 GAO-12-838 Federal Disaster Assistance 

changes to the established declaration guidelines were adopted, and 

ultimately, FEMA did not change its reliance on the per capita indicator.

The Post-Katrina Act required FEMA to develop a set of preparedness 

metrics that could be used to assess operational preparedness 

capability.54

Without an established means of assessing jurisdiction response and 

recovery capability, FEMA has continued to rely primarily on the per 

capita damage indicator when determining whether a disaster declaration 

is warranted. The National Preparedness Goal, released in September 

2011, identifies 31 core capabilities and targets. Further, FEMA officials 

stated that jurisdictions provided reports to FEMA on their preparedness, 

including their core capabilities, on December 31, 2011. According to 

FEMA, the state preparedness reports resulted in up to 155 individual 

measures to track residual capability gaps, the results of which are 

reported by core capability in the annual National Preparedness Report. 

These core capabilities are the latest evolution of the Target Capabilities 

List.

Also, Presidential Policy Directive-8 (PPD-8), issued in March 

2011, required the Secretary of Homeland Security to develop a national 

preparedness system to, in part, define existing capabilities and capability 

gaps, and drive investments to close those gaps across the nation’s 

federal, state, local, tribal, and territorial governments. Much of the growth 

in disaster declarations has occurred at the same time (that is, since the 

terrorist attacks of September 11, 2001) that the federal government has 

provided more than $37 billion to state and local governments to enhance 

their preparedness to protect against, respond to, and recover from 

disasters of all types. However, FEMA has not yet finished developing 

metrics to assess state preparedness capability, a fact that limits its ability 

to comprehensively assess jurisdictions’ disaster preparedness and 

capabilities.

55

 

546 U.S.C. § 749.

While the preliminary core capability targets provide a basis for 

jurisdictions to understand the core capabilities, FEMA has not yet 

developed national preparedness capability requirements based on 

established metrics for the core capabilities at the state and local levels—

as called for in the Post-Katrina Act and PPD-8. In addition, according to 

55GAO, Federal Emergency Management Agency: Continuing Challenges Impede 

Progress in Managing Preparedness Grants and Assessing National Capabilities, 

GAO-12-526T (Washington, D.C.: Mar. 20, 2012). 
 

Page 31 GAO-12-838 Federal Disaster Assistance 

FEMA officials, FEMA does not have any plans or policies in place to use 

preparedness data to inform its recommendations regarding presidential 

disaster declarations. Metrics to assess a jurisdiction’s disaster 

preparedness and capabilities could augment the PA per capita indicator, 

and other relevant information, to provide a more comprehensive 

understanding of a jurisdiction’s capacity to respond to and recover from 

a disaster without federal assistance.

The 2011 state preparedness reports provide some potentially useful 

information to understand a state’s response capabilities. However, 

FEMA does not use these reports or an assessment of a jurisdiction’s 

response capabilities to determine eligibility for disaster assistance, and 

the FEMA Administrator stated that state and local governments are 

capable of handling much of the workload related to responding to a 

declared disaster, which has allowed FEMA to mostly focus on recovery 

efforts.56

As we previously reported and continue to believe, Total Taxable 

Resources (TTR), a measure developed by the U.S. Department of the 

Treasury, provides a more comprehensive measure of a jurisdiction’s 

fiscal capacity than FEMA’s current PA indicator.

Recovery refers to efforts aimed at restoring an area to its prior 

status, including the reconstruction of damaged structures, including its 

housing stock, business establishments, public facilities, and the 

environment. The availability of funds is critical to these efforts; however, 

FEMA does not conduct an assessment of a jurisdiction’s fiscal capacity 

to fund a recovery effort without federal assistance before determining 

whether to award federal assistance.

57

 

56The Honorable W. Craig Fugate, FEMA Administrator, Testimony before the House of 

Representatives, Committee on Appropriations Subcommittee on Homeland Security, 

Budget Hearing–Federal Emergency Management Agency–Director and State and Local 

Witnesses, March 7, 2012. 

For example, TTR 

includes much of the business income that does not become part of the 

income flow to jurisdiction residents, undistributed corporate profits, and 

rents and interest payments made by businesses to out-of-jurisdiction real 

estate owners and lenders. In the case of FEMA’s PA program, 

adjustments for TTR in setting the threshold for a disaster declaration 

could result in a more realistic estimate of a jurisdiction’s ability to 

respond to a disaster. Furthermore, since TTR provides estimates of each 

57GAO-01-837. 
 

Page 32 GAO-12-838 Federal Disaster Assistance 

jurisdiction’s fiscal capacity, adjustments for TTR growth would vary by 

jurisdiction. FEMA could also use other measures of fiscal capacity, such 

as state personal income or gross state product, to more accurately 

determine a jurisdiction’s ability to pay for damages to public structures 

without federal assistance.58

Table 5: Three Potential Approaches to Measure a Jurisdiction’s Fiscal Capacity

Table 5 describes three potential 

approaches to measure a jurisdiction’s fiscal capacity. Federal 

departments and agencies have used some of these approaches to help 

determine a jurisdiction’s fiscal capacity and the extent to which a 

jurisdiction should be eligible for federal assistance. For example, the 

Department of Health and Human Services’ Substance Abuse and Mental 

Health Services Administration’s block grant program and Community 

Mental Health Service use TTR. Also, personal income is used by many 

federal grant programs.

Potential approach Description

State Personal Income Personal income is the income received by all persons 

from all sources. Personal income is the sum of net 

earnings by place of residence, property income, and 

personal current transfer receipts.a

Gross State Product (GSP) Also known as Gross Domestic Product by state, GSP is 

the state counterpart of the nation’s gross domestic 

product (GDP), the Bureau of Economic Analysis’ 

featured and most comprehensive measure of U.S. 

economic activity. GDP by state is derived as the sum of 

the GDP originating in all the industries in a state.b

Total Taxable Resources TTR is the unduplicated sum of the income flows 

produced within a state (GSP) and the income flows 

received by its residents (personal resident income) that a 

state can potentially tax. TTR does not consider the actual 

fiscal choices made by states. It measures all income 

flows a state can potentially tax.c

Source: GAO analysis of Bureau of Economic Analysis and U.S. Department of Treasury data.

a

http://www.bea.gov/newsreleases/regional/spi/sqpi_newsrelease.htm, 

b

http://www.bea.gov/newsreleases/regional/gdp_state/gsp_newsrelease.htm, and 

c

http://www.treasury.gov/resource-center/economic-policy/taxable-resources/Pages/Total-Taxable-Re

sources.aspx. 

 

58In addition to TTR, personal resident income, and gross state product, Representative 

Tax System is a measure of fiscal capacity. However, we did not include it as a potential 

means for FEMA to assess fiscal capacity because it is not currently calculated for U.S. 

jurisdictions, although it could be should FEMA choose to do so.
 

Page 33 GAO-12-838 Federal Disaster Assistance 

Without an accurate assessment of a jurisdiction’s capabilities to respond 

to and recover from a disaster without federal assistance, including a 

jurisdiction’s preparedness capabilities and fiscal capacity, FEMA runs 

the risk of recommending that the President award federal assistance to 

jurisdictions that have the capability to respond and recover on their own. 

Reexamining the basis for the PA indicator and the usefulness of 

preparedness metrics and jurisdiction fiscal capacity could help FEMA 

more accurately determine whether a jurisdiction should be eligible for 

federal assistance. In appendix IV, we provide additional information 

about the three approaches to measure a jurisdiction’s fiscal capacity as 

well as examples of how these fiscal measures could assist FEMA in 

more accurately determining whether the magnitude of damage is beyond 

the capacity of the jurisdiction.

According to the Stafford Act, the usual cost share arrangement for 

disaster declarations calls for the federal government to pay not less than 

75 percent of the eligible PA costs of a disaster and nonfederal entities 

(that is, state and local governments) to pay the remaining 25 percent; at 

a governor’s request, the President can adjust this cost share.59

Governors can request that the President reduce the 25 percent cost share 

for nonfederal governments to 10 percent or 0 percent.

 FEMA 

has specific criteria to evaluate a request to adjust the federal share from 

75 percent to 90 percent, but does not have specific criteria to evaluate a 

request to adjust the federal share to 100 percent. Adjusting the federal 

share to 100 percent is typically done for emergency work such as lifesaving activities and debris removal projects through FEMA’s PA 

program. In addition, FEMA does not know the additional costs (that is, 

the costs of paying an additional 15 or 25 percent) associated with either 

type of cost share adjustment because the agency does not track these 

costs.

60

 

5942 U.S.C. §§ 5170b(b), 5172(b), 5173(d). Generally, there is no nonfederal share for IA 

(FEMA’s Other Needs Assistance program does require a cost share). 42 U.S.C.

§ 5174(g).

FEMA generally 

6044 C.F.R. § 206.47. Instead of jurisdictions paying cash for their 25 percent or 10

percent share of eligible PA costs, they can use in-kind donations. According to FEMA, 

donated resources used on eligible work that is essential to meet immediate threats to life 

and property resulting from a major disaster may be credited toward the nonfederal cost 

share. For example, donated resources may include volunteer labor, equipment, 

materials, food, and shelter.

FEMA Does Not Have 

Specific Criteria to 

Evaluate Some Cost 

Share Adjustment 

Requests and Does 

Not Track Additional 

Costs for All 

Adjustments
 

Page 34 GAO-12-838 Federal Disaster Assistance 

follows the same process to evaluate a request from a governor for a cost 

share adjustment as it follows to evaluate a request for a disaster 

declaration, according to FEMA officials. FEMA makes a recommendation 

to the President as to whether the request for a cost share adjustment 

should be approved or denied and the President makes the decision.

For the 539 disaster declarations during fiscal years 2004 through 2011, 

governors requested that the President adjust the usual federal/nonfederal 

(that is, state and local government) cost share 150 times. As shown in 

table 6, 109 of the 150 requests, or 73 percent, were approved during this 

period. However, 23 of the 109 cost share adjustments were required by 

provisions in law; therefore, FEMA’s recommendation was not a factor in 

whether these cost share adjustment requests were approved or denied.61

For example, 10 of the 23 cost share adjustments required by law were for 

Hurricanes Katrina, Wilma, Dennis, and Rita.62

Table 6: Number of Cost Share Adjustments Requested and Approved, Fiscal Years 

2004 through 2011

Fiscal year Number requested Number approved Percent approved

2004 29 22 76

2005 46 42 91

2006 7 5 71

2007 9 3 33

2008 23 17 74

2009 15 7 47

2010 9 6 67

2011 12 7 58

Total 150 109 73

Source: GAO analysis of FEMA data.

 

61 Excluding the 23 legislatively required cost share adjustments from the 150 total 

requests means that FEMA’s recommendation was a factor in 127 of the requested cost 

share adjustments. The President approved 86 of the 127 cost share adjustment requests, 

or 68 percent.

62 See, e.g., Pub. L. No. 110-28, § 4501, 121 Stat. 112, 156 (2007) (“... the Federal share 

of assistance, including direct Federal assistance, provided for the States of Alabama, 

Florida, Louisiana, Mississippi, and Texas in connection with Hurricanes Katrina, Wilma, 

Dennis, and Rita under sections 403, 406, 407, and 408 of the Robert T. Stafford Disaster 

Relief and Emergency Assistance Act... shall be 100 percent of the eligible costs under 

such sections.”). 
 

Page 35 GAO-12-838 Federal Disaster Assistance 

Note: For the number of cost share adjustments requested and approved, we used the fiscal year in 

which the disaster declaration was approved. Of the 109 cost share adjustments, 23 were required by 

legislation. Excluding the 23 cost share adjustments, the President approved 86 of the 127 cost share 

adjustment requests, or 68 percent. 

Our analysis shows that 64 of the 109 cost share adjustments during 

fiscal years 2004 through 2011 were for the following six disasters: 23 for 

Hurricane Katrina, 11 for Hurricane Rita, 9 for Hurricane Ike, 8 for 

Hurricane Ivan, 7 for midwest flooding in fiscal year 2008, and 6 for 

Hurricane Dennis. Furthermore, 34 of the 109 cost share adjustments 

involved a single adjustment, whereas 23 cost share adjustments 

involved multiple adjustments. FEMA officials explained this by stating 

that a 100 percent cost share adjustment could be approved for a 72-hour 

period and the governor could subsequently request another 100 percent 

cost share adjustment for another 72-hour period, which the President 

could approve. For example, the disaster declaration in Louisiana in fiscal 

year 2005 for Hurricane Katrina had 8 cost share adjustments and the 

disaster declaration in Mississippi in fiscal year 2005 for Hurricane Katrina 

had 9 cost share adjustments.

According to FEMA officials, although the process is similar, the agency 

uses different criteria to evaluate a request from a governor to increase 

the federal government share for PA up to 90 percent than it does for 

requests up to 100 percent. Specifically, FEMA may recommend to the 

President that the federal cost share be increased up to 90 percent when 

a disaster is so extraordinary that actual federal obligations, excluding 

FEMA administrative costs, meet or exceed a qualifying threshold. To 

determine the threshold, the jurisdiction population is multiplied by a per 

capita amount, which is $135 for calendar year 2012 (or 100 times the 

2012 per capita damage indicator of $1.35).63

 

6344 C.F.R. § 206.47(b).

Forty-one of the 109 cost 

share adjustments increased the federal cost share to 90 percent and 

reduced the nonfederal share to 10 percent. According to FEMA’s 

regulations, if warranted by the needs of the disaster, FEMA may 

recommend up to 100 percent federal funding for emergency work, such 

as debris removal and emergency protective measures, for a limited 

period in the initial days of the disaster irrespective of the per capita 
 

Page 36 GAO-12-838 Federal Disaster Assistance 

amount.64

Unlike its evaluation of a request that the federal share be increased from 

75 percent up to 90 percent, FEMA does not use specific criteria to 

evaluate requests to adjust the federal cost share up to 100 percent. 

FEMA officials stated that a recommendation to the President for up to a 

100 percent cost share adjustment is based on a subjective assessment 

of the jurisdiction’s needs and that it is usually pretty obvious when a 

jurisdiction needs debris removal and emergency protective measures, 

although the officials acknowledged that FEMA’s recommendation is a 

judgment call. According to FEMA, it does not use the same criteria to 

evaluate a request for a 100 percent cost share adjustment as it uses for 

a 90 percent cost share adjustment because the criteria for the 90 

percent adjustment are based on actual federal obligations. FEMA 

officials explained that they would not be able to apply those criteria for 

the 100 percent adjustment in the initial days of a disaster because there 

would not be much, if any, funding obligated at that point. However, 

criteria for assessing a request for a 100 percent cost share adjustment 

for PA (that is, emergency work) do not have to be the same criteria 

FEMA uses to assess requests for 90 percent cost share adjustments. 

For example, FEMA’s IA grant program uses multiple factors to determine 

whether to recommend to the President that a jurisdiction be granted IA.

 Sixty-eight of the 109 cost share adjustments increased the 

federal cost share to 100 percent.

65

We have previously reported that clear criteria are important for 

controlling federal costs and helping to ensure consistent and equitable 

eligibility determinations.66 For example, if a 100 percent cost share 

adjustment is approved, the federal government could pay millions of 

dollars more than it ordinarily would for a single disaster declaration. 

Furthermore, Standards for Internal Control in the Federal Government

state that internal control activities help ensure that management’s 

directives are carried out and that actions are taken to address risks.67

 

6444 CFR §206.47(d). Generally, 72 hours is the period of time that the federal 

government will pay 100 percent of these costs; however, the President can extend the 

time period.

6544 C.F.R. § 206.48(b).

66GAO/RCED, Disaster Assistance: Improvements Needed in Determining Eligibility for 

Public Assistance, GAO-96-113 (Washington, D.C.: May 1996).

67GAO/AIMD-00-21.3.1. 
 

Page 37 GAO-12-838 Federal Disaster Assistance 

Moreover, internal control standards state that control activities should be 

an integral part of an entity’s accountability for stewardship of government 

resources. Without such activities, FEMA is at risk that its 

recommendations related to 100 percent cost share adjustments may not 

be justified. Further, relying on professional judgment only, FEMA is at 

risk of making inconsistent, and potentially inequitable, recommendations 

to the President about whether to grant 100 percent cost share 

adjustments.

In addition, FEMA officials stated that they do not know the costs 

associated with the 109 cost share adjustments because the agency does 

not track the costs for all cost share adjustments, although on rare 

occasions, at the request of congressional staff, FEMA officials have 

identified the costs associated with cost share adjustments, such as those 

for Hurricane Katrina. The officials stated that they have not routinely 

tracked the additional costs associated with cost share adjustments 

because they did not see a need for this information. According to 

Standards for Internal Control in the Federal Government, program 

managers need financial data to determine whether they are meeting 

their goals for accountability for effective and efficient use of resources.68

Financial information is needed for both external and internal uses, and 

on a day-to-day basis to make operating decisions, monitor performance, 

and allocate resources. Pertinent information should be identified, 

captured, and distributed in a form and time frame that permits people to 

perform their duties efficiently. Because FEMA does not track the costs 

associated with cost share adjustments, FEMA does not know the 

financial impact of its recommendations to the President on whether to 

increase the federal cost share for PA. Understanding the financial impact 

of FEMA’s recommendations to the President for cost share adjustments 

would enable FEMA to make more informed recommendations and 

estimate the impact of the adjustments on available DRF balances.

 

68 GAO/AIMD-00-21.3.1. 
 

Page 38 GAO-12-838 Federal Disaster Assistance 

FEMA’s administrative cost percentages have often surpassed its targets 

for all sizes of disasters and have doubled in size since fiscal year 1989. 

FEMA provided guidance for administrative cost targets but does not 

assess how well the targets were achieved. The agency is working on 

three short- and long-term initiatives to deliver disaster assistance in a 

more efficient manner.

Our analysis of the 539 disaster declarations during fiscal years 2004 

through 2011 shows that 37 percent of the declarations exceeded 

administrative cost percentage targets established in guidance prepared 

by FEMA in 2010.69 Administrative cost percentages varied widely among 

disaster declarations that required a similar amount of federal financial 

assistance, suggesting that certain declarations may have been 

administered more efficiently than others. In addition, FEMA’s average 

administrative cost percentage for disaster declarations has doubled 

since fiscal year 1989.70

FEMA’s administrative costs relate to the delivery of disaster assistance 

programs, such as the PA or IA programs, and are primarily obligated 

 

69In November 2010, FEMA established administrative cost percentage target ranges for 

disaster declarations. According to FEMA officials, the target ranges are not considered 

formal guidance and FEMA officials responsible for managing administrative costs are not 

held accountable for meeting the targets; however, the targets are supposed to shape 

how its leaders in the field think about gaining and sustaining efficiencies in operations. 

Event Level 1 declarations—with projected obligations of $500 million to $5 billion—have 

an administrative cost percentage target range of 8 percent to 12 percent of total 

obligations. Event Level 2 declarations—with projected total obligations from $50 million to 

$500 million—have a target range of 9 percent to 15 percent. Event Level 3 declarations—

with projected obligations of less than $50 million—have a target range of 12 percent to 20 

percent.

70According to FEMA officials, the agency relied on the Statement of Federal Financial 

Accounting Standards 4 to define its administrative costs. Agency officials calculate a 

declaration’s administrative cost percentage by dividing administrative cost obligations by 

total obligations. Total obligations include funds obligated for PA, IA, Hazard Mitigation, 

Mission Assignment, and administration. We calculated administrative cost percentages 

using the formula provided by FEMA.

Costs of Providing 

Disaster Assistance 

Have Increased, but 

FEMA Is Working to 

Reduce Costs

Administrative Cost 

Percentages Often 

Exceeded FEMA’s Targets 

and Have Doubled since 

Fiscal Year 1989
 

Page 39 GAO-12-838 Federal Disaster Assistance 

from the DRF.71 Examples of administrative costs include the salary and 

travel costs for the disaster reserve workforce, rent and security expenses 

associated with JFO facilities, and supplies and information technology 

support for JFO staff. According to FEMA officials, the agency’s 

administrative costs are primarily due to activities at JFOs; however, 

administrative costs can also be incurred at FEMA regional offices, 

headquarters, and other locations.72

We analyzed actual administrative costs for disaster declarations that 

were closed as of April 30, 2012, and, for declarations that were still open 

as of April 30, 2012, we analyzed actual obligations as of April 30, 2012, 

plus the amount that FEMA projected to obligate in the future until the 

declarations are eventually closed.73

• For small disaster declarations (total obligations of less than $50 

million), the target range for administrative costs is 12 percent to 20 

FEMA categorizes disaster 

declarations using three event levels, essentially small, medium, or large 

based on the amount of federal funding obligated for the disaster, and 

has established target ranges for administrative cost percentages for 

each. Our analysis shows that FEMA frequently exceeded the 

administrative cost percentage targets established by FEMA guidance for 

all three sizes of disaster declarations during fiscal years 2004 through 

2011. Specifically:

 

71In addition to FEMA’s administrative costs, funds are obligated from the DRF to 

reimburse states and localities for certain administrative costs. Because these 

administrative costs are for state and local activities rather than FEMA activities, we did 

not include the costs in our administrative cost analyses. Further, certain administrative 

costs associated with disaster declarations are obligated from FEMA’s annual 

appropriations. For example, according to FEMA officials, the salary of a full-time FEMA 

employee who works at headquarters is obligated from the agency’s appropriations, even 

if the employee works on a specific disaster declaration. As FEMA could not quantify the 

amount of administrative costs obligated from its appropriations that related to disaster 

declarations, these costs were excluded from our administrative cost analyses.

72In addition to using JFOs, FEMA utilizes other temporary offices to respond to disaster 

declarations, including Disaster Recovery Centers and PA Processing Centers, which also 

incur administrative costs.

73FEMA uses three categories to characterize the status of a disaster declaration: 

programmatically open, closed, and reconciled. “Programmatically open” means that all 

financial decisions are not completed and eligible work remains. “Closed” means that 

financial decisions have been made, but all projects are not complete. “Reconciled” 

means that all projects are complete and the FEMA-state agreement is closed. 
 

Page 40 GAO-12-838 Federal Disaster Assistance 

percent; for the 409 small declarations that we analyzed, 4 out of 

every 10 had administrative costs that exceeded 20 percent.

• For medium disaster declarations (total obligations of $50 million to 

$500 million), the target range for administrative costs is 9 percent to 

15 percent; for the 111 declarations that we analyzed, almost 3 out of 

every 10 had administrative costs that exceeded 15 percent.

• For large disaster declarations (total obligations greater than $500 

million to $5 billion), the target range for administrative costs is 8 

percent to 12 percent; for the 19 large declarations that we analyzed, 

over 4 out of every 10 had administrative costs that exceeded 12 

percent.74

For small declarations that we analyzed, administrative cost percentages 

averaged 20 percent and ranged from less than 1 percent to 73 percent. 

Thus, on average, small disaster declarations were within the upper limit of 

FEMA’s target range. However, 12 small declarations had administrative 

cost percentages greater than 50 percent, which means that FEMA 

obligated more for administrative costs than for disaster assistance.75

 

74Two of the 19 large disaster declarations had projected obligations over $5 billion, which 

is above the dollar range that FEMA uses to define large declarations. We included them 

in the group of large declarations.

For 

example, if FEMA required $6 million to deliver $4 million in disaster 

assistance to a jurisdiction, then the related administrative cost percentage 

would be 60 percent of the total DRF obligations of $10 million. For medium 

declarations that we analyzed, administrative cost percentages averaged 

12 percent and were, therefore, in the middle of the target range. However, 

administrative cost percentages for medium declarations ranged from less 

than 1 percent to 55 percent and, for 1 medium declaration, FEMA 

obligated more for administrative costs than for disaster assistance. For 

large declarations that we analyzed, administrative cost percentages 

averaged 13 percent—slightly above the upper limit of the target range—

and ranged from 3 percent to 25 percent; therefore, none of the large 

75The administrative cost percentage is a percentage of the total obligation, not a 

percentage of the amount for disaster assistance. For example, if FEMA obligated $5 

million for administrative costs and $5 million for disaster assistance, we divided the $5 

million in administrative costs by $10 million ($5 million in administrative costs plus $5 

million in disaster assistance). Therefore, in this example, the administrative cost 

percentage is 50 percent of the total $10 million obligation for that disaster.
 

Page 41 GAO-12-838 Federal Disaster Assistance 

declarations we analyzed had obligations for administrative costs higher 

than disaster assistance.

FEMA’s administrative cost percentages also differed significantly 

depending on the type of assistance delivered to a jurisdiction. For 

example, for disaster declarations during fiscal years 2004 through 2011, 

the average administrative cost percentage for disaster declarations that 

involved only IA was 34 percent, while the average was less than half of 

that, at 16 percent, for declarations with only PA. Disaster declarations 

that included both IA and PA had an average administrative cost 

percentage of 18 percent.76

According to FEMA, incidents of similar size and type have witnessed 

growing administrative costs since 1989.77

Table 7: Average Administrative Cost Percentages for 1,221 Disaster Declarations

during Fiscal Years 1989 through 2011

Our analysis of 1,221 small, 

medium, and large disaster declarations during fiscal years 1989 through 

2011 confirms this increase. As discussed in more detail later in this 

report, administrative costs have increased dramatically because of a 

number of factors, including the number of staff deployed to a disaster, 

which tripled during fiscal years 1989 through 2009. Since fiscal year 

1989, the average administrative cost percentage for the 1,221 disaster 

declarations doubled from 9 percent in the 1989-to-1995 period to 18 

percent in the 2004-to-2011 period as shown in table 7.

Fiscal years that declaration was 

approved

Average administrative cost 

percentage

1989 to 1995 9 

1996 to 2003 14

2004 to 2011 18

Source: GAO analysis of FEMA data.

As shown in figure 7 for the 409 small declarations during fiscal years 

2004 through 2011, the frequency of declarations that had administrative 

 

76As discussed later in this report, FEMA offered some reasons why administrative cost 

percentages for IA are generally higher than for PA. 

77FEMA, Achieving Efficient JFO Operations: A Guide for Managing Staffing Levels and 

Administrative Costs (Washington, D.C.: November 2010).
 

Page 42 GAO-12-838 Federal Disaster Assistance 

cost percentages above FEMA’s target of no more than 20 percent is five 

times what it was during fiscal years 1989 through 1995.78

Figure 7: Frequency of Declarations above and below FEMA’s Target of 20 Percent or Less for Administrative Costs for Small 

Declarations during Fiscal Years 1989 through 2011

As shown in figure 8 for the 111 medium declarations during fiscal years 

2004 through 2011, the frequency of declarations that had administrative 

cost percentages above FEMA’s target range of no more than 15 percent, 

is almost 10 times what it was during fiscal years 1989 through 1995.

 

78We examined fiscal years 1989 through 2011 because FEMA maintains detailed 

financial data on disaster declarations only back to fiscal year 1989. To examine whether 

administrative costs changed over time, we divided the 23 years into three periods—two 

periods of 8 years each and one period of 7 years. FEMA officials stated that no 

significant changes have been made to the agency’s definition of administrative costs 

during fiscal years 1989 through 2011. 
 

Page 43 GAO-12-838 Federal Disaster Assistance 

Figure 8: Frequency of Declarations above and below FEMA’s Target of 15 Percent or Less for Administrative Costs for 

Medium Declarations during Fiscal Years 1989 through 2011

As shown in figure 9, for the 19 large declarations during fiscal years 

2004 through 2011, the frequency of declarations that had administrative 

cost percentages above FEMA’s target of no more than 12 percent is 42 

percent, whereas, during fiscal years 1996 to 2003, 20 percent of the 

large declarations exceeded FEMA’s target and, during fiscal years 1989 

through 1995, there were no large declarations that exceeded FEMA’s 

target. 
 

Page 44 GAO-12-838 Federal Disaster Assistance 

Figure 9: Frequency of Declarations above and below FEMA’s Target of 12 Percent or Less for Administrative Costs for Large 

Declarations during Fiscal Years 1989 through 2011

Furthermore, our analysis of administrative cost percentages by type of 

disaster assistance shows a similar trend of significant increases since 

fiscal year 1989. As shown in table 8, since fiscal year 1989, 

administrative cost percentages doubled for declarations with IA only, 

quadrupled for declarations with PA only, and doubled for declarations 

with PA and IA.

Table 8: Average Administrative Cost Percentages by Type of Assistance during 

Fiscal Years 1989 through 2011

Type of assistance 1989-1995 1996-2003 2004-2011

IA 17% 27% 34%

PA 4% 11% 16%

PA, IA 9% 14% 18%

Source: GAO analysis of FEMA data.
 

Page 45 GAO-12-838 Federal Disaster Assistance 

FEMA officials created a management guide to better manage some of 

the controllable factors for administrative costs. The guide noted that 

administrative costs had been steadily rising for 20 years and that little 

emphasis had been placed on controlling overall costs. The guide set 

target ranges for administrative costs, but according to FEMA officials, the 

administrative cost goals are not required to be met. While a number of 

factors affect FEMA’s administrative cost percentages, the agency is 

working to better manage some of the factors it can control. According to 

FEMA officials, the amount and type of assistance provided to a 

jurisdiction are factors that significantly affect administrative cost 

percentages. Some of the key factors that FEMA can control include the 

number of staff deployed to a disaster and amount of overtime these staff 

can work. FEMA officials stated that managing staffing levels according to 

need throughout the course of a disaster can be a cost-effective 

alternative to requiring staff to work overtime.

FEMA officials stated that the amount and type of assistance provided to 

a jurisdiction can affect a disaster declaration’s administrative cost 

percentage. For example, FEMA may be able to achieve economies of 

scale for relatively large disasters, thereby reducing the related 

administrative cost percentage. In contrast, relatively small disasters do 

not benefit from economies of scale and may experience high 

administrative cost percentages because of the need for a certain number 

of staff. For instance, according to a FEMA official responsible for 

controlling disaster-related costs, a typical declaration requires a 

minimum of 30 to 35 staff to deliver PA and an additional 30 to 35 people 

to deliver IA. Therefore, even for a small disaster declaration that includes 

IA and PA, 60 to 70 staff will be required to administer the assistance. 

According to FEMA officials, declarations that include IA often experience 

higher administrative cost percentages. Moreover, FEMA officials stated 

that the delivery of IA can be more labor intensive than the delivery of PA, 

as IA often requires one-on-one attention to individuals and families 

affected by a disaster. Costs associated with a typical JFO, such as rent 

and employee travel, can be reduced when FEMA utilizes a virtual JFO; 

however, because of the personal nature of the response required for IA, 

FEMA is rarely able to utilize a virtual JFO for a declaration with IA 

according to FEMA officials.79

 

79A virtual JFO is an off-site location wherein disaster workforce personnel utilize 

communication tools to deliver disaster assistance programs.

Furthermore, while there is no limit on the 

FEMA Provided Targets 

for Administrative Costs in 

Its Guidance to Staff but 

Does Not Assess 

Performance in Achieving 

the Targets
 

Page 46 GAO-12-838 Federal Disaster Assistance 

amount of PA a jurisdiction can receive, the maximum amount an 

individual/household can receive for IA is $31,400 in fiscal year 2012. As 

a result of the limit for IA, it is more difficult for FEMA to achieve 

economies of scale when delivering IA compared with PA.

According to FEMA officials, certain factors that affect administrative 

costs are managed by the designated FCO.80

In November 2010, the FEMA Administrator issued guidance to FCOs on 

how to better control staffing levels and administrative costs associated 

with disaster declarations. For example, the document provided guidance 

on how FCOs can set targets for administrative cost percentages, plan 

staffing levels, time the deployment of staff, and determine whether to use 

virtual JFOs. According to FEMA, the guidance is not required to be 

followed because the agency’s intent was to ensure that it was providing 

guidance to shape how its leaders in the field think about gaining and 

sustaining efficiencies in operations rather than to lay out a prescriptive 

formula. In addition, FEMA has a strategic plan that calls for improving 

the delivery of disaster assistance while minimizing opportunities for 

FCOs are primarily 

responsible for managing JFO operations and planning FEMA’s initial 

disaster response and recovery efforts, including the number of staff 

needed, and when and how long the staff will be deployed. Salaries, 

benefits, and travel costs for FEMA staff, as well as costs associated with 

contractors, account for roughly three-quarters of a disaster declaration’s 

administrative costs. Also, the average number of FEMA staff deployed to 

a disaster has increased significantly, from fewer than 500 in fiscal year 

1989 to over 1,500 in fiscal year 2009. When we asked FEMA why the 

staff deployed to a disaster had tripled during this time, FEMA stated that 

it is extremely difficult to identify any principal factors causing increases in 

staff and costs because of the complexities associated with the 

underlying factors, particularly in light of the span of time involved. In 

addition, for small declarations, a JFO typically closes within 90 days of 

its opening, and FEMA officials stated that the majority of administrative 

costs are obligated before a JFO closes. Therefore, planning for and 

managing the first 90 days of disaster response and recovery can greatly 

affect the administrative costs for a small declaration.

 

80The FCO is a position created by the Stafford Act and is appointed by the President to 

manage federal resource support activities related to disaster declarations. 42 U.S.C. § 

5143. The FCO is responsible for coordinating the timely delivery of federal disaster 

assistance resources and programs to the affected localities.
 

Page 47 GAO-12-838 Federal Disaster Assistance 

waste, fraud, and abuse. To accomplish this, FEMA plans to 

collaboratively adopt and communicate policies and practices that 

successfully safeguard against waste, fraud, and abuse. The plan states 

that, to justify FEMA funding to all of its stakeholders, including taxpayers, 

there must be a focus on identifying outcomes and measuring 

performance. Furthermore, according to the plan, FEMA’s ability to 

analyze and evaluate the results of its plans, programs, and 

organizational initiatives is key to managing its strategic and long-range 

organizational goals. However, neither the guidance to FCOs nor the 

strategic plan sets goals for administrative cost percentages that are 

required to be met or tracked for performance. While we recognize 

complexities exist that can affect administrative costs for disasters, 

FEMA’s implementation of goals to control administrative costs and 

monitoring of performance in achieving these goals would provide 

valuable information in assessing the agency’s performance in this area 

and help to provide reasonable assurance that FEMA is delivering 

disaster assistance in an efficient manner.

FEMA officials are considering other short- and long-term actions to 

increase efficiencies in the delivery of disaster assistance. According to 

FEMA officials, on the basis of a recent review of the PA program, the 

agency created a plan with three initiatives focused on delivering 

assistance to jurisdictions in a more efficient manner. The first initiative 

under this plan attempts to promote consistency across FEMA’s 10 

regional offices. For example, FEMA plans to issue a Public Assistance 

Program Field Operations Pocket Guide to provide consistent guidance 

and approaches to regional staff to help ensure that PA policies are being 

consistently followed across FEMA regions. FEMA provided the PA 

Pocket Guide to FEMA regional staff and state, local, and tribal officials 

who attended FEMA’s PA Conference and State Workshop in April 2012 

to solicit feedback.

The second initiative attempts to reduce the problems associated with 

debris removal. For example, the agency hopes to reduce its reliance on 

the Army Corps of Engineers for debris removal, which FEMA officials 

said can be costlier than hiring local contractors. According to FEMA 

officials, the agency plans to implement this initiative during the next 2 to 

3 years and it may require regulatory changes.

The third initiative addresses inefficiencies within the permanent work 

portion of PA and includes the consideration of a new model to deliver 

this assistance. In October 2011, the FEMA Administrator testified that 

FEMA Is Working to 

Increase Efficiencies in 

Delivering Disaster 

Assistance
 

Page 48 GAO-12-838 Federal Disaster Assistance 

the agency is considering a new, two-step process wherein FEMA and 

the state would agree on the estimated damages for a large-scale project 

and FEMA would make a one-time payment to the state.81 The 

Administrator stated that the agency currently uses a reimbursement 

program, which requires a high degree of FEMA oversight and 

administrative costs.82 While FEMA officials told us that the agency is in 

the conceptual stages of developing the new model, officials have 

identified some potential benefits. For example, the new model could 

lower FEMA’s administrative costs and the time needed to close a 

disaster declaration. In addition, the new model could allow states to 

rebuild as they see fit rather than requiring states to replace damaged 

structures to the status that existed prior to the disaster, which is FEMA’s 

current practice. According to FEMA officials, implementation of this 

model could require regulatory and legislative changes and is, therefore, 

years away.

Disaster declarations have increased over recent decades, and FEMA 

has obligated over $80 billion in federal assistance for disasters declared 

during fiscal years 2004 through 2011, highlighting the importance of 

FEMA’s assessment of jurisdictions’ capabilities to respond and recover 

without federal assistance. The PA per capita indicator is artificially low 

because it does not reflect the rise in per capita personal income since 

1986 or 13 years of inflation from 1986, when the indicator was set at 

$1.00 and adopted for use, to 1999. By primarily relying on an artificially 

low indicator, FEMA’s recommendations to the President are based on 

damage estimates and do not comprehensively assess a jurisdiction’s 

capability to respond to and recover from a disaster on its own. For 

example, on the basis of FEMA’s actual and estimated disaster 

assistance obligations, more than one-third of the 539 major disasters 

declared during fiscal years 2004 through 2011 are expected to have total 

 

81Statement of the Honorable W. Craig Fugate, Administrator, FEMA, before the House 

Committee on Transportation and Infrastructure, Subcommittee on Economic 

Development, Public Buildings, and Emergency Management, Streamlining Emergency 

Management: Improving Preparedness, Response, and Cutting Costs, U.S. House of 

Representatives (Washington, D.C.: October 13, 2011).

82Under the current reimbursement program, the state and local governments pay for the 

item or service and submit documentation to FEMA officials, who review the 

documentation to ensure it is an eligible expense and reimburse the state and local 

governments. 

Conclusions
 

Page 49 GAO-12-838 Federal Disaster Assistance 

DRF obligations of less than $10 million, and more than 60 percent are 

expected to have total obligations of less than $25 million. Therefore, 

many of these declarations were for relatively small disasters. At a 

minimum, adjusting the existing PA per capita indicator fully for changes 

in per capita income or inflation could ensure that the per capita indicator 

more accurately reflects changes in U.S. economic conditions since 1986, 

when the indicator was adopted. Making the appropriate inflation 

adjustment to the indicator would raise it from $1.35 to $2.07. A change of 

this size in 1 year could present challenges for jurisdictions, which could 

find that disasters with PA damage estimates that would now qualify for 

PA would no longer qualify. Thus, phasing in the adjustment over several 

years could provide jurisdictions time to take actions, such as increasing 

any rainy day funds, to adjust to the effects of higher qualifying indicators.

A more comprehensive approach to determine a jurisdiction’s capabilities 

to respond to a disaster would be to replace or supplement the current 

indicator with more complete data on a jurisdiction’s fiscal resources, 

such as TTR, and would be informed by data on a jurisdiction’s response 

and recovery assets and capabilities. Because FEMA’s current approach 

of comparing the amount of disaster damage with the PA per capita 

indicator does not accurately reflect whether a jurisdiction has the 

capabilities to respond to and recover from a disaster without federal 

assistance, developing a methodology that provides a more 

comprehensive assessment of jurisdictions’ response and recovery 

capabilities, including a jurisdiction’s fiscal capacity, could provide FEMA 

with data that are more specific to the jurisdiction requesting assistance. 

For example, developing preparedness metrics in response to the PostKatrina Act and Presidential Policy Directive-8 could provide FEMA with 

readily available information on jurisdictions’ response and recovery 

capabilities. Without an accurate assessment of jurisdictions’ capabilities 

to respond to and recover from a disaster, FEMA runs the risk of 

recommending to the President that federal disaster assistance be 

awarded without considering a jurisdiction’s response and recovery 

capabilities or its fiscal capacity. As we recommended in 2001, we 

continue to believe that FEMA should develop more objective and specific 

criteria to assess the capabilities of jurisdictions to respond to a disaster. 

Given the legislative and policy changes over the past decade, we believe 

that including fiscal and nonfiscal capabilities, including available 

preparedness metrics in its assessment, would allow FEMA to make 

more informed recommendations to the President when determining a 

jurisdiction’s capacity to respond without federal assistance.
 

Page 50 GAO-12-838 Federal Disaster Assistance 

Making informed recommendations to the President about whether cost 

share adjustments should be granted is important for FEMA and the 

requesting jurisdictions because every cost share adjustment has 

financial implications for both entities. A specific set of criteria or factors to 

use when considering requests for 100 percent cost share adjustments 

would provide FEMA a decision-making framework and enable more 

consistent and objectively based recommendations to the President. Also, 

when FEMA recommends that a cost share adjustment be approved and 

the President approves it, the federal government assumes the financial 

burden of paying 15 percent or 25 percent more in PA, which could total 

millions of dollars. Tracking the additional costs to the federal government 

because of cost share adjustments would allow FEMA to better 

understand the financial implications of its recommendations to the 

President.

FEMA’s average administrative costs as a percentage of total DRF 

disaster assistance obligations have risen for disasters of all sizes. The 

agency recognized that delivering assistance in an efficient manner is 

important and published guidance to be used throughout the agency to 

help rein in administrative costs. However, FEMA has not implemented 

the goals and does not track performance against them. Over time, 

reducing administrative costs could save billions of dollars—dollars that 

could be used to fund temporary housing, infrastructure repairs, and other 

disaster assistance. Therefore, incentivizing good management over 

administrative costs by adopting administrative cost percentage goals and 

measuring performance against these goals would help provide FEMA 

with additional assurance that it is doing its utmost to deliver disaster 

assistance in an efficient manner.

To increase the efficiency and effectiveness of the process for disaster 

declarations, we recommend that the FEMA Administrator take the 

following four actions:

1. Develop and implement a methodology that provides a more 

comprehensive assessment of a jurisdiction’s capability to respond to 

and recover from a disaster without federal assistance. This should 

include one or more measures of a jurisdiction’s fiscal capacity, such 

as TTR, and consideration of the jurisdiction’s response and recovery 

capabilities. If FEMA continues to use the PA per capita indicator to 

assist in identifying a jurisdiction’s capabilities to respond to and 

recover from a disaster, it should adjust the indicator to accurately 

reflect the annual changes in the U.S. economy since 1986, when the 

Recommendations for 

Executive Action
 

Page 51 GAO-12-838 Federal Disaster Assistance 

current indicator was first adopted for use. In addition, implementing 

the adjustment by raising the indicator in steps over several years 

would give jurisdictions more time to plan for and adjust to the 

change.

2. Develop and implement specific criteria or factors to use when 

evaluating requests for cost share adjustments that would result in the 

federal government paying up to 100 percent of disaster declaration 

costs.

3. Annually track and monitor the additional costs borne by the federal 

government for the cost share adjustments.

4. Implement goals for administrative cost percentages and monitor 

performance to achieve these goals.

We provided a draft of this report to DHS for comment. We received 

written comments from DHS on the draft report, which are summarized 

below and reproduced in full in appendix V. DHS concurred with three 

recommendations and partially concurred with the fourth 

recommendation.

Regarding the first recommendation, that FEMA develop and implement a

methodology that provides a more comprehensive assessment of a 

jurisdiction’s capability to respond to and recover from a disaster without 

federal assistance, DHS concurred. DHS stated that a review of the 

criteria used to determine a state’s response, recovery, and fiscal 

capabilities is warranted and that such a review would include the need to 

update the per capita indicator as well as a review of alternative metrics. 

DHS stated that any changes would need to be made through the notice 

and comment rulemaking process and that, if changes are made to the 

per capita indicator, FEMA’s Office of Response and Recovery will review 

the feasibility of phasing them in over time. However, the extent to which 

the planned actions will fully address the intent of this recommendation 

will not be known until the agency completes its review and implements a 

methodology that provides a more comprehensive assessment of a 

jurisdiction’s capability to respond and, if the per capita indicator 

continues to be used, adjusts the per capita indicator to accurately reflect 

annual changes in the U.S. economy since 1986. We will continue to 

monitor DHS’s efforts.

Agency Comments 

and Our Evaluation
 

Page 52 GAO-12-838 Federal Disaster Assistance 

Regarding the second recommendation, that FEMA develop and 

implement specific criteria or factors to use when evaluating requests for 

cost share adjustments that would result in the federal government paying 

up to 100 percent of disaster declaration costs, DHS concurred with the 

recommendation and stated that FEMA’s Office of Response and 

Recovery will review specific cost share factors or criteria and develop 

guidelines to support decision making. These actions, if implemented 

effectively, should address the intent of the recommendation.

DHS concurred with the third recommendation, to track and monitor the 

additional costs associated with cost share adjustments, and stated that 

FEMA’s Office of Response and Recovery will be responsible for tracking 

these costs on an annual basis. DHS stated that such actions would 

provide valuable information for budgetary purposes and for decision 

makers who consider requests for cost share adjustments. We agree. 

Thus, these actions, if implemented effectively, should address the intent 

of the recommendation.

DHS partially concurred with the fourth recommendation, to implement 

goals for administrative cost percentages and monitor performance to 

achieve these goals. Specifically, DHS stated that it agrees that setting 

goals and monitoring performance for achieving these goals is a good 

practice in any program and can help ensure more effective and efficient 

operations. However, DHS stated that it plans to conduct a review to 

better understand and describe its current measures. DHS stated that a 

number of factors affect administrative costs, which can present 

difficulties when trying to implement a simple measure of percentage of 

administrative costs to total costs. For example, DHS noted that the types 

of assistance provided and the location of the JFO would affect the 

percentage of administrative costs. DHS also stated that establishing 

meaningful administrative cost percentage goals will be challenging 

because of the many factors involved and that a suite of measures to 

track administrative cost percentages could help ensure more effective 

and efficient operations. Thus, DHS is pursuing development of such a 

suite of measures. We agree that a number of factors affect the 

percentage of administrative costs and that establishing meaningful 

administrative cost percentage goals can be challenging. In developing a 

suite of measures, it is important that FEMA’s leadership be able to use 

them to effectively monitor a disaster declaration’s overall administrative 

costs in addition to the factors that affect administrative costs. If these 

measures allow FEMA to monitor overall administrative costs as well as 

the factors that affect such costs, then development and implementation 

of such measures should meet the intent of the recommendation.
 

Page 53 GAO-12-838 Federal Disaster Assistance 

DHS also provided technical comments, which we incorporated, as 

appropriate.

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

the FEMA Administrator, and appropriate congressional committees. If 

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

me at (202) 512-8777 or JenkinsWO@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Other key contributors to this report are listed 

in appendix VI.

William O. Jenkins, Jr.

Director

Homeland Security and Justice 
Appendix I: GAO Analyses of the Number of 

Disaster Declarations and Amount of 

Obligations

Page 54 GAO-12-838 Federal Disaster Assistance 

Disaster declarations can take a decade or more to close because of a 

number of factors, including the Federal Emergency Management 

Agency’s (FEMA) reimbursement process for Public Assistance (PA) 

infrastructure projects, which can take a long time to finish. In addition, 

some projects are delayed because of disagreements, and sometimes 

litigation, over the appropriate amount that should be obligated, according 

to FEMA officials. As shown below in table 9, the oldest open disaster 

dates back to 1992, making it 20 years old, and only 54 percent of 

disaster declarations from fiscal year 2001 were closed as of January 31, 

2012. All disaster declarations prior to fiscal year 1992 are closed. Table 

9 shows the number of major disaster declarations by fiscal year that 

were open as of January 31, 2012, and the percentage of declarations 

that have been closed for each year since fiscal year 1992.1

Table 9: Status of Disaster Declarations during Fiscal Years 1992 through 2011, as 

of January 31, 2012

Number of disaster declarations

Fiscal year Declared Open Closed Percentage closed

1992 46 1 45 98

1993 39 1 38 97

1994 36 2 34 94

1995 29 4 25 86

1996 72 2 70 97

1997 49 4 45 92

1998 61 8 53 87

1999 53 10 43 81

2000 40 9 31 78

2001 50 23 27 54

2002 42 16 26 62

2003 62 29 33 53

2004 65 46 19 29

2005 45 31 14 31

2006 53 46 7 13

2007 68 65 3 4

2008 68 68 0 0

2009 63 63 0 0

2010 79 79 0 0

2011 98 98 0 0

Source: GAO analysis of FEMA data.

 

1

Figure 1 presented earlier in the report includes data on declarations since 1953, when 

the first presidential disaster declaration was issued.

Appendix I: GAO Analyses of the Number of 

Disaster Declarations and Amount of 

Obligations 
Appendix I: GAO Analyses of the Number of 

Disaster Declarations and Amount of 

Obligations

Page 55 GAO-12-838 Federal Disaster Assistance 

Fifty-nine jurisdictions received major disaster declarations during fiscal 

years 1953 through 2011. Texas had the most, with 86 declarations, while 

Palau had 1. Wyoming, Utah, and Rhode Island had the fewest 

declarations for a state, each with 9 declarations. Table 10 identifies the 

number of disaster declarations for all jurisdictions during fiscal years 

1953 through 2011. 

Table 10: Number of Disaster Declarations during Fiscal Years 1953 through 2011 

by Jurisdiction

Jurisdiction Number of declarations

Texas 86

California 78

Oklahoma 70

New York 65

Florida 63

Louisiana 57

Alabama 55

Kentucky 55

Arkansas 53

Missouri 53

Illinois 51

Mississippi 50

Tennessee 50

Iowa 48

Minnesota 48

Kansas 47

Nebraska 47

Pennsylvania 46

West Virginia 46

Ohio 45

Washington 44

Virginia 43

North Dakota 42

North Carolina 40

Indiana 39

Maine 39

South Dakota 39

Georgia 36

Alaska 35

Wisconsin 35

Vermont 32

New Jersey 31

Oregon 28
Appendix I: GAO Analyses of the Number of 

Disaster Declarations and Amount of 

Obligations

Page 56 GAO-12-838 Federal Disaster Assistance 

Jurisdiction Number of declarations

New Hampshire 27

Massachusetts 26

Hawaii 25

Michigan 25

Puerto Rico 25

Federated States of Micronesia 24

Arizona 23

Idaho 23

New Mexico 23

Maryland 21

Montana 20

Nevada 17

Virgin Islands 17

Colorado 16

Connecticut 16

South Carolina 15

Delaware 14

Northern Mariana Islands 14

Guam 12

American Samoa 11

District of Columbia 10

Rhode Island 9 

Utah 9 

Wyoming 9 

Marshall Islands 7 

Palaua 1 

Source: GAO analysis of FEMA data.

a We did not include Palau in our analysis of disaster declarations during fiscal years 2004 through 

2011 because Palau is a Freely Associated State that, under the terms of its Compact of Free 

Association with the United States, ceased to receive disaster assistance from the U.S. government. 

Prior to entering the compact, Palau received one disaster declaration as a territory. 

The number of major disaster declarations and total obligations varied 

among FEMA regions during fiscal years 2004 through 2011. For 

example, FEMA Region X had 32 declarations, while FEMA Region IV 

had 87. In addition, obligations for FEMA Region VI during this time, 

which was affected by Hurricane Katrina, reached nearly $40 billion, while 

FEMA Region X had obligations of $647 million. See figure 10 for more 

information.
Appendix I: GAO Analyses of the Number of 

Disaster Declarations and Amount of 

Obligations

Page 57 GAO-12-838 Federal Disaster Assistance 

Figure 10: Number of Disaster Declarations and Amount of Obligations by FEMA Region during Fiscal Years 2004 through 

2011

Note: American Samoa, Federated States of Micronesia, Guam, Marshall Islands, U.S. Virgin Islands, 

Commonwealth of the Northern Mariana Islands, and Commonwealth of Puerto Rico are not visually 

represented in the figure, but the number of disaster declarations and obligations due to these 

jurisdictions were included in the figure under Regions II and IX. Specifically, the U.S. Virgin Islands 

and Commonwealth of Puerto Rico are served by FEMA Region II, and America Samoa, Federated 

States of Micronesia, Guam, Marshall Islands, and Commonwealth of the Northern Mariana Islands 

are served by FEMA Region IX. 
Appendix I: GAO Analyses of the Number of 

Disaster Declarations and Amount of 

Obligations

Page 58 GAO-12-838 Federal Disaster Assistance 

FEMA classifies major disaster declarations by incident type, and these 

types include floods, tornadoes, and hurricanes, among other types of 

disasters—both natural and man-made. As shown in table 11, the most 

frequent type of incident was, according to FEMA data, severe storms, 

which accounted for 71 percent of the declarations during fiscal years 

2004 through 2011.

Table 11: Disaster Declarations by Incident Type during Fiscal Years 2004 through 

2011

Incident typea Number of declarations Percentage of total

Severe storm 385 71

Hurricane 37 7 

Flood 34 6 

Fire 21 4 

Snow 20 4

Severe ice storm 12 2 

Tornado 8 1 

Typhoon 7 1 

Other 5 1 

Earthquake 4 1 

Tsunami 3 1

Freezing 2 Less than 0.5

Dam/levee break 1 Less than 0.5

Total 539 100

Source: GAO analysis of FEMA data.

a

We are reporting the incident type for each disaster declaration as assigned by FEMA. 

FEMA obligates funds from the Disaster Relief Fund (DRF) to help 

jurisdictions respond to and recover from declared disasters. FEMA 

classifies these funds into five categories: PA, Individual Assistance, 

Hazard Mitigation, Mission Assignments, and Administration. Table 12 

shows the obligations for each category by jurisdiction.
Appendix I: GAO Analyses of the Number of 

Disaster Declarations and Amount of 

Obligations

Page 59 GAO-12-838 Federal Disaster Assistance 

Table 12: Obligations for Disaster Declarations during Fiscal Years 2004 through 2011, by Jurisdiction, as of January 31, 2012 

(Dollars in millions)

Disaster assistance

Jurisdiction

Public 

Assistance

Individual 

Assistance

Hazard 

Mitigation 

Mission 

Assignment

Total 

assistance Administration

Grand 

total 

Alabama 

(including Katrina)

$656 $903 $99 $383 $2,041 $414 $2,456

Alabama 

(excluding 

Katrina)

536 297 53 320 1,206 228 1,433

Alaska 81 5 7 1 95 25 120

American Samoa 74 66 4 9 153 64 217

Arizona 43 0 2 0 44 9 53

Arkansas 372 53 50 3 477 80 557

California 1,057 113 76 4 1,251 117 1,368

Colorado 0 1 a a 1 2 3

Connecticut 38 18 2 a 58 28 85

Delaware 12 0 1 0 12 2 14

District of Columbia 12 0 0 0 12 1 13

Federated States of

Micronesia

16 8 1 a 25 8 33

Florida 

(including Katrina)

4,904 2,201 498 847 8,449 1,128 9,578

Florida 

(excluding Katrina)

4,687 2,201 490 847 8,225 1,105 9,331

Georgia 190 80 57 1 329 94 422

Guam 1 0 0 0 1 1 2 

Hawaii 56 16 4 a 76 17 93

Idaho 12 0 a 0 12 4 17

Illinois 251 481 23 3 757 98 855

Indiana 213 140 40 3 396 66 463

Iowa 1,626 227 296 10 2,158 169 2,327

Kansas 973 89 94 4 1,160 71 1,231

Kentucky 375 102 45 2 524 108 632

Louisiana 

(including Katrina)

13,682 11,353 981 2,742 28,758 3,579 32,337

Louisiana

(excluding Katrina)

1,770 991 172 328 3,261 587 3,848

Maine 74 4 6 a 84 21 $105

Maryland 96 0 2 0 98 6 104

Massachusetts 173 99 9 1 282 58 340

Michigan 15 45 4 0 64 8 72

Minnesota 168 38 13 3 222 41 264

Mississippi 

(including Katrina)

3,561 3,111 296 1,207 8,174 2,072 10,246
Appendix I: GAO Analyses of the Number of 

Disaster Declarations and Amount of 

Obligations

Page 60 GAO-12-838 Federal Disaster Assistance 

Disaster assistance

Jurisdiction

Public 

Assistance

Individual 

Assistance

Hazard 

Mitigation 

Mission 

Assignment

Total 

assistance Administration

Grand 

total 

Mississippi 

(excluding Katrina)

107 54 6 13 180 56 236

Missouri 592 112 66 152 923 137 1,060

Montana 32 7 1 0 40 17 57

Nebraska 292 8 29 a 329 37 366

Nevada 21 2 2 a 25 5 30

New Hampshire 91 15 12 a 119 28 147

New Jersey 193 232 37 2 464 71 535

New Mexico 57 8 1 0 66 17 82

New York 839 266 40 22 1,168 152 1,320

North Carolina 152 102 5 1 259 70 329

North Dakota 437 209 21 42 710 146 856

Northern Mariana 

Islands

10 14 2 0 26 6 32

Ohio 238 92 29 1 359 45 404

Oklahoma 463 37 38 1 539 82 622

Oregon 106 9 19 0 134 24 159

Pennsylvania 276 298 25 10 610 85 695

Puerto Rico 152 485 17 9 664 99 763

Rhode Island 27 42 4 a 73 18 91

South Carolina 43 8 3 0 54 7 61

South Dakota 200 13 8 1 222 52 273

Tennessee 332 203 56 2 593 118 711

Texas 2,795 1,843 395 280 5,313 1,056 6,369

Utah 28 0 1 0 28 7 36

Vermont 51 28 3 1 82 36 118

Virgin Islands 18 0 1 0 19 8 27

Virginia 144 14 6 a 164 22 187

Washington 209 43 41 a 293 58 352

West Virginia 108 117 19 12 256 58 314

Wisconsin 113 138 30 a 282 50 332

Wyoming 8 3 a 0 11 3 15

Total $36,759 $23,500 $3,522 $5,761 $69,542 $10,806 $80,349

Source: GAO analysis of FEMA data.

Note: Total obligations include obligations for Hurricane Katrina and do not factor in jurisdictions’ 

obligations that exclude Hurricane Katrina. 

a

Obligations less than $0.5 million 
Appendix I: GAO Analyses of the Number of 

Disaster Declarations and Amount of 

Obligations

Page 61 GAO-12-838 Federal Disaster Assistance 

Obligations on a per person basis varied for disasters declared during 

fiscal years 2004 through 2011. For example, including Hurricane Katrina, 

Louisiana had the highest per capita obligations at $7,236, but excluding 

obligations for Hurricane Katrina, American Samoa had the highest 

obligations at $3,795 per person. For the lowest obligations per person, 

Colorado had 81 cents and the Marshall Islands had zero. See tables 13 

and 14 for obligations on a per person basis for all 58 jurisdictions when 

including and excluding obligations for Hurricane Katrina, respectively.

Table 13: Obligations Per Person Including Hurricane Katrina for Disaster 

Declarations during Fiscal Years 2004 through 2011, by Jurisdiction

Rank 

order Jurisdiction

Obligated per person as of 

January 31, 2012

1. Louisiana $7,236

2. American Samoa 3,795

3. Mississippi 3,602

4. North Dakota 1,332

5. Iowa 795

6. Florida 599

7. Alabama 552

8. Northern Mariana Islands 460

9. Kansas 458

10. South Dakota 362

11. Federated States of Micronesia 307

12. Texas 305

13. Virgin Islands 245

14. Nebraska 214

15. Arkansas 208

16. Puerto Rico 200

17. Vermont 194

18. Alaska 191

19. Missouri 189

20. Oklahoma 180

21. West Virginia 174

22. Kentucky 156

23. Tennessee 125

24. New Hampshire 119

25. Rhode Island 87

26. Maine 82
Appendix I: GAO Analyses of the Number of 

Disaster Declarations and Amount of 

Obligations

Page 62 GAO-12-838 Federal Disaster Assistance 

Rank 

order Jurisdiction

Obligated per person as of 

January 31, 2012

27. Hawaii 77

28. Indiana 76

29. New York 70

30. Illinois 69

31. New Jersey 64

32. Montana 63

33. Wisconsin 62

34. Washington 60

35. Pennsylvania 57

36. Minnesota 54

37. Massachusetts 54

38. Georgia 52

39. Oregon 46

40. New Mexico 45

41. North Carolina 41

42. California 40

43. Ohio 36

44. Wyoming 29

45. Virginia 26

46. Connecticut 25

47. District of Columbia 22

48. Maryland 20

49. Delaware 18

50. Utah 16

51. South Carolina 15

52. Nevada 15

53. Idaho 13

54. Guam 12

55. Arizona 10

56. Michigan 7 

57. Colorado 0.81

58. Marshall Islands 0 

Total $23,362

Source: GAO analysis of FEMA data.
Appendix I: GAO Analyses of the Number of 

Disaster Declarations and Amount of 

Obligations

Page 63 GAO-12-838 Federal Disaster Assistance 

Table 14: Obligations Per Person Excluding Hurricane Katrina for Disaster 

Declarations during Fiscal Years 2004 through 2011, by Jurisdiction 

Rank 

order Jurisdiction

Obligated per person as of 

January 31, 2012

1. American Samoa $3,795

2. North Dakota 1,332

3. Louisiana 861

4. Iowa 795

5. Florida 584

6. Northern Mariana Islands 460

7. Kansas 458

8. South Dakota 362

9. Alabama 322

10. Federated States of Micronesia 307

11. Texas 305

12. Virgin Islands 245

13. Nebraska 214

14. Arkansas 208

15. Puerto Rico 200

16. Vermont 194

17. Alaska 191

18. Missouri 189

19. Oklahoma 180

20. West Virginia 174

21. Kentucky 156

22. Tennessee 125

23. New Hampshire 119

24. Rhode Island 87

25. Mississippi 83

26. Maine 82

27. Hawaii 77

28. Indiana 76

29. New York 70

30. Illinois 69

31. New Jersey 64

32. Montana 63

33. Wisconsin 62

34. Washington 60
Appendix I: GAO Analyses of the Number of 

Disaster Declarations and Amount of 

Obligations

Page 64 GAO-12-838 Federal Disaster Assistance 

Rank 

order Jurisdiction

Obligated per person as of 

January 31, 2012

35. Pennsylvania 57

36. Minnesota 54

37. Massachusetts 54

38. Georgia 52

39. Oregon 46

40. New Mexico 45

41. North Carolina 41

42. California 40

43. Ohio 36

44. Wyoming 29

45. Virginia 26

46. Connecticut 25

47. District of Columbia 22

48. Maryland 20

49. Delaware 18

50. Utah 16

51. South Carolina 15

52. Nevada 15

53. Idaho 13

54. Guam 12

55. Arizona 10

56. Michigan 7 

57. Colorado 0.81

58. Marshall Islands 0 

Total $13,222

Source: GAO analysis of FEMA data.
Appendix II: Objectives, Scope, and 

Methodology

Page 65 GAO-12-838 Federal Disaster Assistance 

This report addresses the following questions: (1) For each fiscal year 

from 2004 through 2011, how many disaster declaration requests did 

FEMA receive, how many were approved, for which types of disasters, 

and how much were the associated obligations from the DRF? (2) What 

criteria has FEMA used to recommend to the President that a disaster 

declaration is warranted for PA, and to what extent does FEMA assess 

whether an effective response to a disaster is beyond the capabilities of 

state and local governments? (3) How does FEMA determine whether a 

cost share adjustment recommendation for PA is warranted and how 

much additional federal assistance did jurisdictions receive during fiscal 

years 2004 through 2011 because of cost share adjustments? (4) What 

were FEMA’s administrative cost percentages for disaster declarations 

during fiscal years 2004 through 2011, how have they changed over time, 

and what actions is FEMA taking, if any, to reduce the costs of delivering 

disaster assistance funds?

To determine how many disaster declaration requests FEMA received, 

how many were approved, for which types of disasters, and how much 

the associated obligations were from the DRF, we obtained data for each 

disaster declaration approved during fiscal years 2004 through 2011.1

 

1

The obligations data were current as of January 31, 2012. When finalizing our study, we 

received projected obligations data from FEMA that included updated actual obligations as 

of April 30, 2012. However, we did not receive detailed actual obligations data that would 

have allowed us to update all of our actual obligations data analysis, so this analysis 

remained as of January 31, 2012.

We 

focused on this time frame because it contains the most current data for 

disaster declarations. It also comprises the time period after FEMA was 

merged into the newly created DHS, on March 1, 2003, and predates 

Hurricane Katrina in 2005. We focused primarily on fiscal years 2004 

through 2011; however, to provide historical context and to compare 

results across similar periods, we also reviewed obligations data from 

fiscal years 1989 through 2011. In addition, to provide further historical 

perspective, we include information on the number of disaster 

declarations by jurisdiction from the first presidential disaster declaration 

in fiscal year 1953 through fiscal year 2011 in appendix I. FEMA provided 

data to us from its National Emergency Management Information System 

(NEMIS) and Integrated Financial Management Information System 

(IFMIS). To determine whether the data were reliable, we reviewed the 

data that FEMA officials provided and discussed data quality control 

procedures to ensure the integrity of the data with them. We determined 

Appendix II: Objectives, Scope, and 

Methodology 
Appendix II: Objectives, Scope, and 

Methodology

Page 66 GAO-12-838 Federal Disaster Assistance 

that the data we used from these systems were sufficiently reliable for the 

purposes of this report.

To determine the criteria that FEMA used to recommend to the President 

that a disaster declaration was warranted for PA, and to what extent 

FEMA assessed whether an effective response to a disaster was beyond 

the capabilities of jurisdictions, such as state and local governments, we 

examined FEMA policies, regulations, and other documents related to the 

disaster declarations process. To determine the probability of a disaster 

declaration request being approved for PA if the Preliminary Damage 

Assessments (PDA) met or exceeded the PA per capita indicator, we 

obtained and analyzed data on FEMA’s PDAs from fiscal years 2008 

through 2011. For this analysis, we used 4 years of data (fiscal years 

2008 through 2011) instead of 8 years of data (fiscal years 2004 through 

2011) that we used for other analyses because FEMA did not have data 

for fiscal years 2004 through 2007 in an electronic format. We believe that 

our analysis of 4 years of data is sufficient for purposes of this report. 

Specifically, we analyzed 246 disaster declarations during fiscal years 

2008 through 2011, and excluded 293 declarations during fiscal years 

2004 through 2007 because FEMA had readily available data only for 

PDAs for fiscal years 2008 through 2011. For each of the 246 disaster 

declarations, we reviewed the PDAs to determine whether a state 

requested PA, whether the President approved it, and the extent to which 

the PA damage estimate exceeded the PA per capita indicator.

In addition, we conducted an analysis to determine whether disaster 

declarations from 2004 through 2011 would have met the PA per capita 

indicator if adjusted for the change in per capita personal income since 

1986. Our analysis included FEMA’s projected obligations as of April 30, 

2012, for only those 508 disaster declarations that had received PA and 

had been declared during fiscal years 2004 through 2011. We did not 

analyze the 31 disaster declarations that only received IA. We analyzed 

obligations instead of PDA damage estimates for PA because FEMA 

officials stated that estimating the damage from a disaster is sometimes 

stopped when the estimate equals or exceeds the PA per capita indicator. 

Therefore, we concluded that conducting the analysis using projected 

obligations would be more accurate than using incomplete PDA damage 

estimates for PA. In addition, we separately analyzed actual obligations 

for 144 closed disaster declarations because closed declarations would 

be either complete or very close to being complete. To determine whether 

the data were reliable, we reviewed the data that FEMA officials provided 

and discussed data quality control procedures to ensure the integrity of 
Appendix II: Objectives, Scope, and 

Methodology

Page 67 GAO-12-838 Federal Disaster Assistance 

the data with them. We determined that the data we used from PDAs 

were sufficiently reliable for the purposes of this report.

To determine how FEMA evaluated whether a cost share adjustment 

recommendation was warranted and how much additional federal 

assistance states received during fiscal years 2004 through 2011 

because of the adjustments, we obtained and reviewed relevant laws, 

regulations, and policies. We also obtained and analyzed the cost share 

adjustments and types requested, approved, and denied during fiscal 

years 2004 through 2011. In addition, we interviewed FEMA officials who 

process cost share adjustment requests and participate in making 

recommendations to the President as to whether the requests should be 

approved or denied. We also reviewed internal control standards for the 

federal government related to ensuring management directives are 

carried out and that actions are taken to address risks.2

To determine FEMA’s administrative cost percentages for disaster

declarations, we obtained DRF actual obligations, projected obligations, 

and related data for all 1,221 disaster declarations from fiscal years 1989 

through 2011. While the focus of our objective was fiscal years 2004 

through 2011, we obtained obligations data back to fiscal year 1989 to 

assess potential trends over time because FEMA only maintains 

obligations data since then. To assess FEMA’s current practices, we 

compared FEMA’s administrative cost percentages for disaster 

declarations during fiscal years 2004 through 2011 with FEMA’s target 

ranges for administrative cost percentages. To identify potential trends 

over time, we compared FEMA’s administrative cost percentages during 

fiscal years 1989 through 2003 with FEMA’s administrative cost 

percentages during fiscal years 2004 through 2011 and with FEMA’s 

target ranges. According to FEMA officials, administrative costs are 

typically higher in the early months of a declaration, typically decreasing 

as the declaration matures (that is, as labor-intensive response activities 

decline). In order to ensure the results of both analyses were not skewed 

To determine 

whether the data were reliable, we reviewed the data that FEMA officials 

provided and discussed data quality control procedures to ensure the 

integrity of the data with them. We determined that the cost share 

adjustment data were sufficiently reliable for the purposes of this report.

 

2

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). 
Appendix II: Objectives, Scope, and 

Methodology

Page 68 GAO-12-838 Federal Disaster Assistance 

by declarations that had not yet matured and whose administrative costs 

were high, we analyzed actual administrative costs for disaster 

declarations that were closed as of April 30, 2012. For declarations that 

were still open as of April 30, 2012, we analyzed actual obligations as of 

April 30, 2012, plus the amount that FEMA projected to obligate in the 

future until the declarations are eventually closed. To determine whether 

the data were reliable, we reviewed the data that FEMA officials provided 

and discussed data quality control procedures to ensure the integrity of 

the data with them. We determined that the DRF data were sufficiently 

reliable for the purposes of this report. To determine what actions FEMA 

is taking, if any, to reduce the costs of delivering disaster assistance, we 

interviewed FEMA officials and reviewed relevant policies, documents, 

and briefings.

In addition to conducting interviews with officials in FEMA headquarters 

for all four objectives, we conducted site visits to two FEMA regions—

Regions IV and VI, which had the highest total obligations during fiscal 

years 2004 through 2011. The regional administrative offices were 

located in Atlanta, Georgia, and Denton, Texas, respectively. At each 

region, we interviewed the Regional or Deputy Administrator and various 

other personnel. In addition, we visited the emergency management 

agencies for Georgia and Oklahoma—one state within each of the two 

FEMA regions. We selected the two state emergency management 

agencies—Georgia and Oklahoma—based on their respective proximity 

to FEMA’s regional offices, their high level of experience with disasters, 

and their availability for a visit during September 2011. We wanted to 

avoid states that were actively responding to a disaster during that time. 

While the information we obtained on these site visits is not generalizable, 

the visits provided important insights into the disaster declaration process.

We conducted this performance audit from July 2011 through September

2012 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 findings 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.
Appendix III: Total Public Assistance Indicator 

Amount for Fiscal Year 2012, by Jurisdiction 

Page 69 GAO-12-838 Federal Disaster Assistance 

FEMA uses a PA per capita indicator to help determine a jurisdiction’s 

need for federal assistance in the wake of a disaster. Table 15 shows 

how the indicator is calculated for each jurisdiction. FEMA multiplies the 

2010 population for each jurisdiction by the PA per capita indicator for the 

fiscal year in which the disaster occurs. In fiscal year 2012, the PA per 

capita indicator is $1.35. The results of these calculations are the total 

indicator amounts in table 15. If the PA damage estimate exceeds the 

total indicator amount, a jurisdiction is likely to receive a major disaster 

declaration.

Table 15: 2010 Population and Total PA Per Capita Indicator Amount for Fiscal Year 

2012, by Jurisdiction

Jurisdiction 2010 population

Total indicator amount 

(based on $1.35 per capita)a

California 37,253,956 $50,292,841 

Texas 25,145,561 33,946,507 

New York 19,378,102 26,160,438 

Florida 18,801,310 25,381,769 

Illinois 12,830,632 17,321,353 

Pennsylvania 12,702,379 17,148,212 

Ohio 11,536,504 15,574,280 

Michigan 9,883,640 13,342,914 

Georgia 9,687,653 13,078,332 

North Carolina 9,535,483 12,872,902 

New Jersey 8,791,894 11,869,057 

Virginia 8,001,024 10,801,382 

Washington 6,724,540 9,078,129 

Massachusetts 6,547,629 $,839,299 

Indiana 6,483,802 8,753,133 

Arizona 6,392,017 8,629,223 

Tennessee 6,346,105 8,567,242 

Missouri 5,988,927 8,085,051 

Maryland 5,773,552 7,794,295 

Wisconsin 5,686,986 7,677,431 

Minnesota 5,303,925 7,160,299 

Colorado 5,029,196 6,789,415 

Alabama 4,779,736 6,452,644 

South Carolina 4,625,364 6,244,241 

Louisiana 4,533,372 6,120,052 

Appendix III: Total Public Assistance 

Indicator Amount for Fiscal Year 2012, by 

Jurisdiction 
Appendix III: Total Public Assistance Indicator 

Amount for Fiscal Year 2012, by Jurisdiction 

Page 70 GAO-12-838 Federal Disaster Assistance 

Jurisdiction 2010 population

Total indicator amount 

(based on $1.35 per capita)a

Kentucky 4,339,367 5,858,145 

Oregon 3,831,074 5,171,950 

Oklahoma 3,751,351 5,064,324 

Puerto Rico 3,725,789 5,029,815

Connecticut 3,574,097 4,825,031 

Iowa 3,046,355 4,112,579 

Mississippi 2,967,297 4,005,851 

Arkansas 2,915,918 3,936,489 

Kansas 2,853,118 3,851,709 

Utah 2,763,885 3,731,245 

Nevada 2,700,551 3,645,744 

New Mexico 2,059,179 2,779,892 

West Virginia 1,852,994 2,501,542 

Nebraska 1,826,341 2,465,560 

Idaho 1,567,582 2,116,236 

Hawaii 1,360,301 1,836,406 

Maine 1,328,361 1,793,287 

New Hampshire 1,316,470 1,777,235 

Rhode Island 1,052,567 1,420,965 

Montana 989,415 1,335,710 

Delaware 897,934 1,212,211 

South Dakota 814,180 1,099,143 

Alaska 710,231 958,812a 

North Dakota 672,591 907,998a 

Vermont 625,741 844,750a 

District of Columbia 601,723 812,326a 

Wyoming 563,626 760,895a 

Guam 159,358 215,133a

Federated States of Micronesia 107,154 144,658a,b

Virgin Islands 106,405 143,647a

Marshall Islands 65,859 88,910a,b

American Samoa 55,519 74,951a

Northern Mariana Islands 53,883 $72,742a

Source: GAO analysis of U.S. Census and FEMA data.

a

FEMA has established a minimum threshold of $1 million in PA damages per disaster in the belief 

that even the lowest-population states can cover this level of PA damage. 44 C.F.R. § 206.48(a)(1). 

b

The 2010 populations for the Federated States of Micronesia and the Marshall Islands are estimates 

from the U. S. Census Bureau. 
Appendix IV: Description of Three Approaches 

to Measure a Jurisdiction’s Fiscal Capacity 

Page 71 GAO-12-838 Federal Disaster Assistance 

The Stafford Act requires that a governor’s request for a major disaster 

declaration be based on a finding that the disaster is of such severity and 

magnitude that an effective response is beyond the capabilities of the 

jurisdiction and that federal assistance is necessary.1

Jurisdictions’ abilities to finance their own disaster relief and recovery 

vary with their fiscal capacity, among other factors. A jurisdiction’s fiscal 

capacity is defined as the ability of a government to raise revenue from its 

own sources, by taxes, license fees, user charges, and public enterprises, 

among other devices. Fiscal capacity is usually expressed as a 

percentage of the national average for the 50 states plus the District of 

Columbia, in the form of an index number. For example, if a jurisdiction’s 

capacity is equal to 100 percent or 90 percent of the national average, its 

index number would be 100 or 90, respectively. In general, the ability of 

jurisdictions to pay for public services increases with the size of their 

economies. The simplest application of fiscal capacity criteria to disaster 

assistance is an adjustment of the per capita indicator for every 

jurisdiction. “Richer” jurisdictions—those above the national average—

would have a higher level, reflecting their greater ability to pay, while 

“poorer” jurisdictions would have a lower level. The fiscal capacity index 

could be converted into a percentage (for instance, 110 = 110 percent or 

90 = 90 percent) and applied to each jurisdiction’s per capita indicator 

 In the wake of a 

disaster, FEMA prepares dollar estimates of the damage to public 

infrastructure incurred in an area that would be eligible for federal 

assistance under a federal major disaster declaration. Currently the key 

metric for determining eligibility for federal disaster assistance is a “per 

capita indicator,” which, since 1999, has been adjusted annually for 

inflation. For 2012, the indicator is $1.35 per capita (that is, total 

estimated damages eligible for federal PA divided by the jurisdiction’s 

population equals $1.35 or more). Damage estimates in excess of this 

number typically result in FEMA recommending that the President issue a 

major disaster declaration, which makes jurisdictions eligible for federal 

reimbursement of at least 75 percent of certain repair and replacement 

costs. The per capita indicator FEMA currently uses is not a measure of a 

jurisdiction’s fiscal capacity to address the damages caused by a disaster. 

Rather, there is an assumption that generally jurisdictions are unable 

without federal major disaster assistance to rectify damages that equal or 

exceed $1.35 per capita.

 

1

42 U.S.C. § 5170. 

Appendix IV: Description of Three 

Approaches to Measure a Jurisdiction’s Fiscal 

Capacity 
Appendix IV: Description of Three Approaches 

to Measure a Jurisdiction’s Fiscal Capacity 

Page 72 GAO-12-838 Federal Disaster Assistance 

($1.35 times the population) to get an adjusted indicator. For example, a 

jurisdiction with a population of 10 million would have a per capita 

indicator of $13.5 million dollars ($1.35 times its 10 million population). If 

the jurisdiction’s capacity index was 100 percent, its capacity threshold 

would be the same as the current indicator—$13.5 million. However, if the 

jurisdiction’s fiscal capacity index was 110 (indicating a fiscal capacity 

index 10 percent above the national average), its damage threshold 

would be $14.85 million—$13.5 million plus 10 percent of $13.5 million. 

The variation in the results could be narrowed, if desired, by setting upper 

and lower limits to the adjustments, among other possible methods. 

However, adjusting the per capita indicator according to a jurisdiction’s 

fiscal capacity would not necessarily reduce total federal spending. It is 

possible that disaster assistance adjusted by fiscal capacity, and focused 

on jurisdictions with below-average fiscal capacity, could increase total 

federal spending. How total annual spending is affected would depend on 

the specific disasters taking place for that year, as well as the affected 

jurisdictions.

In addition to the theoretical aspects of comparing and contrasting various 

measurements of fiscal capacity, there are other matters to consider.2

Simple and easy to calculate: For political acceptance and analytical 

ease, the methodology of measurement should be as simple as possible. 

For practicality and transparency, a measure should be easy and 

inexpensive to calculate.

Specifically, there are certain attributes that are desirable in a fiscal 

capacity measure. These attributes could help FEMA determine the 

extent to which the agency could use measurements of jurisdiction fiscal 

capacity when determining a jurisdiction’s eligibility for federal assistance. 

These attributes include the following:

Convenient, available, and timely: Ideally the data for a measure would 

be routinely collected, checked, and published by a government agency 

on a timely basis. For example, the measurement should be possible on 

an annual basis with as little a time lag as possible, in order to provide the 

most timely indicator of jurisdictions’ capacities.

 

2

Stephen M. Barro, “Macroeconomic Versus RTS Measures of Fiscal Capacity: 

Theoretical Foundations and Implications for Canada,” Institute of Intergovernmental 

Relations, Working Paper, (Queens University, 2002), 1-5. 
Appendix IV: Description of Three Approaches 

to Measure a Jurisdiction’s Fiscal Capacity 

Page 73 GAO-12-838 Federal Disaster Assistance 

Comprehensive: A measure should be comprehensive with respect to the 

implementation of its approach. Incompleteness could bias results.

Analytically sound: The principal analytical choice in capacity 

measurement is between economic measures that aim for 

comprehensive measurement free of double-counting, and tax base 

measures that in some way take account of governments’ choices in how 

to tax.3

Does not affect or is not affected by any individual jurisdiction’s fiscal 

choices: Capacity measures should not be affected by or affect a 

jurisdiction’s actual fiscal choices, in terms of what to tax, how to tax, or 

how much to tax. In principle a government’s fiscal behavior could affect 

its own tax bases. No capacity measure makes any adjustments based 

on the impact of taxes on a state’s economy because of the extreme 

difficulty of arriving at a simple method of making such adjustment that 

would earn political consensus.

There is debate among economists as to which type of 

measurement (economic or tax base) is more analytically sound.

The three fiscal capacity measures discussed below provide various 

methods that can be used to determine a jurisdiction’s fiscal capacity. 

Each of these measures has benefits and potential shortcomings 

regarding the extent to which they measure a jurisdiction’s fiscal capacity.

State personal income (PCI): As a measurement of a jurisdiction’s fiscal 

capacity, state personal income is simple, available, and timely. The 

personal income of all residents of a jurisdiction consists of labor 

earnings, proprietors’ and partnership income, rent, interest, dividends, 

and transfers (public cash benefits). It is the most commonly used 

measure in the United States for federal grants. PCI is simple and familiar 

to most people, and it is routinely calculated and published by the federal 

government on a jurisdiction-by-jurisdiction basis. More local measures of 

personal income are less comprehensive, for lack of data. Some 

jurisdictions may choose to tax only part of income, or not to tax it at all. 

 

3

The three fiscal measures we discuss in this appendix are economic measures. 

However, in addition to TTR, personal resident income, and gross state product, 

Representative Tax System (RTS) is a tax base measure. We did not include RTS as a 

potential means for FEMA to assess fiscal capacity because it is not currently calculated 

for U.S. jurisdictions, although it could be should FEMA choose to do so. 

Fiscal Capacity 

Measurements
Appendix IV: Description of Three Approaches 

to Measure a Jurisdiction’s Fiscal Capacity 

Page 74 GAO-12-838 Federal Disaster Assistance 

PCI aims to be a comprehensive measure of residents’ personal income, 

without regard to how they are taxed.

PCI is not a comprehensive measure of a jurisdiction’s fiscal capacity and 

is affected by a jurisdiction’s fiscal choices. The principal shortcoming of 

PCI is its failure to reflect a jurisdiction’s ability to raise tax revenue from 

nonresidents, also known as tax exporting. For example, a jurisdiction 

government may tax nonresident commuters, property owners, shoppers, 

and tourists. The ability to export taxes varies sharply across jurisdictions. 

Also, data on one component of personal income, accrued capital gains, 

is not available. More generally, changes in asset values are not captured 

in any fiscal capacity measures, because of lack of data. Another missing 

element in PCI is the net income of a jurisdiction’s government 

enterprises. An example is state-owned liquor stores, whose profits never 

pass through private hands. Another example is royalties paid to 

governments by extractive industries, such as oil, gas, and uranium. 

These scenarios amount to income received by a jurisdiction’s residents, 

through their government. In one state (Alaska), a share of such 

revenue—a “bonus” payment—is paid directly to state residents, which 

would appear as part of PCI. To a limited extent, PCI is biased to the 

extent to which a jurisdiction government finances transfer payments with 

taxes on income, since this income is counted twice, once by source and 

the second time by receipt.

Gross state product (GSP): As a measure of a jurisdiction’s fiscal 

capacity, GSP is simple, available, timely, and not affected by a 

jurisdiction’s fiscal choices. Also called gross domestic product by state, 

GSP consists of all income “produced” in a state. It includes labor 

earnings of those who work in a jurisdiction, irrespective of their 

residence, the net income of business firms operating in a jurisdiction, 

indirect business taxes paid to the governments of the jurisdiction, and 

the output of the public sector (in national income accounting, 

government output is valued at cost). GSP partially captures the ability of 

a jurisdiction to export taxes, since it includes income received by 

nonresidents and by the residents’ own governments directly. As with 

PCI, with the benefit of government publication, the data are available on 

a timely basis and are easily converted into a fiscal capacity index. It is 

less affected by a jurisdiction’s fiscal choices than PCI because it does 

not double-count income.

Similar to PCI, GSP is not a comprehensive measure of a jurisdiction’s 

fiscal capacity. More specifically, PCI includes income received by a 

jurisdiction’s residents, but not income generated in a jurisdiction but 
Appendix IV: Description of Three Approaches 

to Measure a Jurisdiction’s Fiscal Capacity 

Page 75 GAO-12-838 Federal Disaster Assistance 

received by nonresidents. GSP does not include income received by a 

jurisdiction’s residents that originates elsewhere.

Total taxable resources (TTR): As a measure of a jurisdiction’s fiscal 

capacity, TTR is comprehensive, available, and not affected by 

jurisdictions’ fiscal choices. According to the Department of the Treasury 

(Treasury), the object of TTR is to capture the unduplicated sum of PCI 

and GSP that is susceptible to taxation by a jurisdiction’s government.4

By this means the entirety of income potentially exposed to taxation is 

measured. In practice the calculation is relatively simple. A jurisdiction’s 

GSP is supplemented with income received by jurisdiction residents that 

originated in other jurisdictions. This would include the labor earnings of 

residents who commute to jobs in other jurisdictions, and the capital 

income (mainly interest, dividends, rent, and capital gains) of all 

jurisdiction residents due to asset holdings in other jurisdictions. It 

excludes indirect business taxes paid to the federal government (such as 

the payroll tax and federal excises). TTR is used in two grant programs—

the Department of Health and Human Services’ Substance Abuse and 

Mental Health Services Administration’s block grant program and 

Community Mental Health Service—and is calculated by Treasury.5

TTR is a complex measure of a jurisdiction’s fiscal capacity and is not as 

timely as other measures. A crude measure of TTR is obtained by simply 

averaging a jurisdiction’s PCI and GSP. This was done for official TTR 

estimates between 1992 and 1997. Subsequently the calculations were 

based more closely on the original conceptual framework for TTR. At 

present there is a 2-year lag in the publication of TTR estimates by 

Treasury. As of May of 2012, the most recent year available is 2009. The 

primary reason for the delay in publishing TTR estimates is the need to 

wait for federal excise tax revenues and nontax liabilities, and federal 

civilian enterprise surpluses, to become available. These data are 

provided to Treasury in August or September for the year ending 20 

months prior. According to the Chief of the Regional Product Branch, 

Regional Product Division, at the Bureau of Economic Analysis, it could 

 

4

U.S. Department of the Treasury, Office of Economic Policy, Treasury Methodology for 

Estimating Total Taxable Resources (TTR), (Washington, D.C.: revised November 2002). 

http://www.treasury.gov/resource-center/economic-policy/taxable-resources/Pages/TotalTaxable-Resources.aspx. 

5

Michael L. Compson, “Historical Estimates of Total Taxable Resources for U.S. States, 

1981-2000,” The Journal of Federalism, 33:2 (Spring 2003), 55-72.
Appendix IV: Description of Three Approaches 

to Measure a Jurisdiction’s Fiscal Capacity 

Page 76 GAO-12-838 Federal Disaster Assistance 

be possible to speed up the availability of TTR by 2 or 3 months. In 

addition, TTR is less transparent than PCI or GSP. It relies on 

approximations of capital income (dividends, interest, and rent), since 

such quantities are not reported by place of origination. It does not 

discriminate among income flows according to the degree of susceptibility 

to taxation.

Each of these three measures of a jurisdiction’s fiscal capacity to respond

to and recover from a disaster without federal assistance has its 

limitations and can affect each jurisdiction somewhat differently, 

compared with using the current $1.35 per capita damage estimate 

indicator. FEMA’s current per capita indicator is simple and easy to 

understand, but it is not a measure of a jurisdiction’s fiscal capacity. Nor 

does FEMA have a useful measure of a jurisdiction’s response 

capabilities. All current measures of those capabilities are jurisdictions’ 

self-reported data without reference to common metrics for assessing 

capability. Because FEMA’s per capita indicator does not 

comprehensively assess a jurisdiction’s response and recovery 

capabilities, including a jurisdiction’s fiscal capacity, some combination of 

these measures could provide a more robust and useful assessment of a 

jurisdiction’s capability to respond to and recover from a disaster without 

federal assistance, or with minimal federal assistance. This could include 

exploring the usefulness of supplementing the current damage indicator 

(which does not fully reflect changes in inflation since its adoption in 

1986) with other measures of a jurisdiction’s fiscal capacity and response 

capability.

For example, one potential alternative methodology could involve 

adjusting the per capita indicator for each jurisdiction based on a measure 

of jurisdiction fiscal capacity. If FEMA were to adjust the PA indicator for 

inflation, the adjusted PA indicator for fiscal year 2011 would be $2.07. 

Beginning with the adjusted PA indicator of $2.07, each jurisdiction’s PA 

indicator could then be adjusted based on that jurisdiction’s fiscal 

capacity. For example, if the $2.07 base were adjusted for “jurisdiction A,” 

which has a 2009 TTR index of 71.8, jurisdiction A’s PA indicator would 

be $1.49. If the $2.07 base were adjusted for “jurisdiction B’s” 2009 TTR 

index of 149, jurisdiction B’s PA indicator would be $3.08 (see table16). 

The variation in jurisdiction A’s $1.49 indicator and jurisdiction B’s $3.08 

indicator represents the difference in the two jurisdiction’s fiscal capacities 

in accordance with each jurisdiction’s TTR. In making any changes or 

enhancements to the methods used to assess a jurisdiction’s fiscal 

capacity, policymakers would need to consider the relative priority of key 

Examples of Fiscal 

Measures Applied to the 

Per Capita Indicator
Appendix IV: Description of Three Approaches 

to Measure a Jurisdiction’s Fiscal Capacity 

Page 77 GAO-12-838 Federal Disaster Assistance 

attributes, as previously discussed, and the benefits and costs of 

developing and implementing such changes.

Table 16: PA Indicator Adjusted by Jurisdiction for 2009 TTR

PA indicator 

adjusted for 

inflation, as 

recommended

Jurisdictions’ 2009 

index for TTR 

PA indicator as 

adjusted for 

jurisdiction’s TTR 

fiscal capacity index

Jurisdiction A $2.07 71.8 $1.49

Jurisdiction B $2.07 149.0 $3.08

Source: GAO analysis of Department of Commerce, Department of Treasury, and Bureau of Labor Statistics data.
Appendix V: Comments from the Department 

of Homeland Security

Page 78 GAO-12-838 Federal Disaster Assistance 

Appendix V: Comments from the Department 

of Homeland Security
Appendix V: Comments from the Department 

of Homeland Security

Page 79 GAO-12-838 Federal Disaster Assistance 
Appendix V: Comments from the Department 

of Homeland Security

Page 80 GAO-12-838 Federal Disaster Assistance 
Appendix V: Comments from the Department 

of Homeland Security

Page 81 GAO-12-838 Federal Disaster Assistance 
Appendix VI: GAO Contact and Staff 

Acknowledgments

Page 82 GAO-12-838 Federal Disaster Assistance 

William O. Jenkins Jr., (202) 512-8777 or JenkinsWO@gao.gov

In addition to the contact named above, Leyla Kazaz (Assistant Director), 

David Alexander, Lydia Araya, Peter DelToro, Joseph E. Dewechter, 

Jeffrey Fiore, Carol Henn, R. Denton Herring, Tracey King, Linda Miller, 

Max Sawicky, and Jim Ungvarsky made key contributions to this report.

Appendix VI: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(440978)
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 (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 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, 

http://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 www.gao.gov. 

Contact:

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

E-mail: fraudnet@gao.gov

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

Katherine Siggerud, Managing Director, siggerudk@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

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

Please Print on Recycled Paper.