Transitional Sheltering Assistance Policy 

(Interim)

FEMA Policy #104-009-20 

BACKGROUND 

Transitional Sheltering Assistance (TSA) is a short-term, non-congregate sheltering form of 

assistance for displaced disaster survivors taking refuge in emergency shelter locations. The 

intent of TSA is to provide sheltering using facilities, including but not limited to, hotels and 

motels for survivors as they transition from emergency shelters to temporary or permanent 

housing solutions. 

Based on lessons learned from previous TSA activations and the coronavirus (COVID-19) 

pandemic, and in alignment with FEMA's Strategic Plan to reduce complexity and simplify 

disaster recovery, the Recovery Directorate issues this Interim Policy for TSA to be applied 

under emergency or major disaster declarations that include Individual Assistance (IA). 

PURPOSE 

This document serves as FEMA's Interim Policy on TSA in accordance with Chapter 2, Section 

IX, of FEMA Policy 104-009-03, Individual Assistance Program and Policy Guide, published in 

March 2019. This interim policy is effective for disasters declared on or after August 22, 2020. 

PRINCIPLES 

A. TSA will provide temporary non-congregate sheltering to alleviate immediate threats to life 

resulting from a Presidentially declared disaster that includes Individual Assistance. 

B. FEMA will provide standardized timelines and milestones, including end dates, to help 

manage expectations, and emphasize the short-term nature of this temporary sheltering 

solution. 

C. FEMA will activate TSA based on a state, tribal, or territorial government’s (STT’s) 

demonstrated need for non-congregate sheltering. 

D. FEMA will coordinate with whole community partners to meet the human services needs 

of survivors in TSA, using all available state, local, tribal, and/or territorial (SLTT) and 

federal assistance for disaster survivors. 

E. FEMA will clearly communicate information about this assistance to survivors in a simple 

and effective manner. 

F. FEMA will promote STT understanding of the scope, benefits, limitations, and costs of 

assistance. 

G. FEMA will use standard criteria from the Individuals and Households Program (IHP) to 

determine household eligibility and definitive guidance to reduce complexity and prevent 

inconsistency in the delivery of TSA. 

FEMA Policy #104-009-20 Page 1 of 8 
H. FEMA will coordinate with SLTTs and other whole community partners to plan for the 

needs of people with disabilities and others with access and functional needs. 

REQUIREMENTS 

A. AUTHORIZING TSA 

FEMA may authorize TSA when the following conditions exist: 

1. Congregate shelters are overcrowded or insufficient in number and location to meet the 

sheltering demand; or 

2. Areas of designated communities are inaccessible, and it is projected the condition of 

inaccessibility may exceed 30 days. 

FEMA authorizes TSA when an STT requests assistance supporting the emergency needs of 

survivors in the area of the Presidentially declared disaster for IA. The STT must submit the 

request through the Federal Coordinating Officer (FCO) and Regional Administrator (RA) to 

the Individual Assistance Division Director (IADD) at FEMA Headquarters (HQ). When the 

request package is submitted to the IADD for final review and approval, a signed letter with the 

FCO's recommendation and the RA’s concurrence, must be included. FEMA's IADD may 

approve the request, deny the request, or ask for additional information prior to a final decision. 

The STT request package must include, as substantiated by data-informed analysis, that the 

congregate shelter population count has stabilized and/or address: 

1. STT activation request letter signed by the Governor/Tribal Chief Executive (TCE) or the 

Governor's/TCE’s Authorized Representative (GAR/TAR); 

2. A signed, fully executed and accepted Resource Request Form (RRF) received from 

field-based FEMA staff, and containing all necessary elements as noted in the TSA RRF 

template; 

3. Specific length of time the STT is requesting TSA be made available, to include 

justification for the requested duration with the understanding that the TSA minimum 

activation is 30 days and the maximum period of assistance cannot exceed 180 days 

from the date of declaration; 

4. Identification of the IA designated counties for which the STT is requesting TSA; 

FEMA, in coordination with the STT government, will conduct an analysis to identify the 

locations of participating hotels, motels, or other facilities to be utilized for TSA. 

5. Acknowledgement of the STT cost share for TSA; 

6. An assessment of utility outages in identified counties along with estimated restoration 

dates; and 

7. Justification that the conditions for TSA exist. The following factors that are applicable to 

the current disaster must be addressed: 

a. The current shelter capacity does not meet the sheltering needs of the displaced 

population; and/or 

b. Congregate shelter support resources are inadequate to sustain existing shelter 

needs (e.g., shelter operators and other partners project that they will be unable to 

sustain congregate shelter operations for 30 days); and/or 

FEMA Policy #104-009-20 Page 2 of 8 
c. Areas of designated communities are inaccessible and are projected to remain 

inaccessible for greater than 30 days; and/or 

d. Facilities serving as congregate shelter(s) need to return to their pre-disaster use 

(e.g., schools to provide education); and/or 

e. Available rental resources, as determined by FEMA in coordination with the STT, are 

not sufficient to meet the needs of the displaced population within the affected areas. 

B. PERIOD OF ASSISTANCE 

Based on the documented need supported by the data and analysis in the request package, 

the IADD may approve TSA for not less than 30 days and up to 180 days from the date of the 

emergency or major disaster declaration. 

C. CONDITIONS OF INITIAL REGISTRANT ELIGIBILITY 

TSA is authorized for FEMA disaster assistance registrants who have a documented need. 

TSA is intended to be a short-term sheltering option, serving as a bridge to temporary or 

permanent housing. The initial period of TSA eligibility is 30 days, subject to the following 

registrant eligibility criteria. 

To be considered for TSA eligibility, registrants must: 

1. Register with FEMA within 60 days from date of declaration; and 

2. Be a U.S. citizen, non-citizen national, or qualified alien; and 

3. Complete a valid registration with FEMA for federal disaster assistance; and 

4. Pass identity verification; and 

5. Pass occupancy verification; and 

6. Have a primary residence located in an area designated for TSA; and 

7. Be the head of household and/or not be linked with another valid registration for FEMA 

assistance; and 

8. Have a current sheltering location of mass shelter (including churches/houses of 

worship), hotel/motel, car, or place of employment; and 

9. At least one of the following must be present: 

a. Indicate the home is physically inaccessible; or 

b. Report home damage that displaced the registrant and was caused by the event 

occurring within the incident period; or 

c. Have a completed home assessment on file indicating the home is not safe to 

occupy, the utilities are out, or the home is inaccessible. 

D. CONTINUED REGISTRANT ELIGIBILITY 

FEMA will conduct periodic reviews of registrants' continued TSA eligibility, generally in 14-day 

intervals. Registrants who meet the conditions of continued eligibility may remain in TSA. 

There may be eligibility intervals that are longer to accommodate holidays, to align reviews 

across multiple TSA activations, or due to other exigent circumstances. 

FEMA Policy #104-009-20 Page 3 of 8 
This guidance delegates authority from the IADD to the FCO to waive continued eligibility for 

an individual registrant. 

Registrants are no longer eligible to remain in TSA if any of the following uniform criteria apply: 

1. The registrant has completed a FEMA registration, but does not meet the conditions for 

referral to FEMA Housing Assistance; or 

2. The registrant voluntarily withdrew from consideration for disaster assistance; or 

3. The registrant's pre-disaster primary residence is safe to occupy based on FEMA’s home 

assessment; or 

4. The registrant will continue to occupy the damaged dwelling while repairs are being 

made, based on information provided during the home assessment and/or recorded 

through casework or calls to the FEMA Helpline; or 

5. The registrant has insurance providing Additional Living Expense or Loss of Use 

coverage verified by the home assessment; or 

6. The registrant is identified as insured after registration and has not been made eligible 

for temporary housing assistance; or 

7. The registrant does not respond to FEMA outreach efforts after at least three contact 

attempts; or 

8. The registrant is included with another household already receiving FEMA IHP 

assistance; or 

9. The registrant chooses not to accept Direct Temporary Housing assistance when 

offered; or 

10. The registrant has been licensed into a FEMA Temporary Housing Unit (THU); or 

11. The registrant no longer needs TSA because emergency temporary repairs have been 

completed; or 

12. The registrant does not comply with the TSA Terms and Conditions; or 

13. The registrant has received FEMA Temporary Housing Assistance and adequate rental 

resources are available; or 

14. The registrant has obtained alternate temporary or long-term housing, based on 

information recorded through casework or calls to the FEMA Helpline. 

Each eligibility review interval will include all initial and uniform continued eligibility criteria, as 

listed in Sections C and D. Additional eligibility factors will be implemented at each eligibility 

review interval. See Appendix A with Intervals 1 through 3. 

As determined by FEMA HQ, in consultation with TSA field-deployed coordination staff, 

additional eligibility factors from Appendix A may be adjusted due to disaster-specific exigent 

circumstances either by request of the STT or by FEMA leadership. FEMA HQ will notify STTs 

and registrants in a timely manner about any adjustments to additional eligibility factors using a 

combination of written documentation and a registrant’s preferred communication mechanism. 

When a registrant becomes ineligible for TSA, they will be provided notice that they have 

seven days remaining in TSA. Notification will be in the form of a phone call, text, and/or email, 

FEMA Policy #104-009-20 Page 4 of 8 
depending on the registrant’s identified communication preference documented in the 

registrant’s FEMA application. 

Registrants are required to sign a Terms & Conditions document at their initial check-in to a 

TSA hotel. This document notes that in some instances an expedited check out will be 

required, such as: 

1. When a registrant is licensed into a THU, they will be provided three additional nights in 

TSA to coordinate their move; 

2. When a registrant identifies repairs have been made to the damaged dwelling, or they 

have obtained alternate housing, they will be provided three additional nights in TSA to 

coordinate their move; 

3. In instances of fraud, registrants may be notified of immediate termination of TSA 

eligibility; or 

4. When there is a credible belief that a registrant is a threat to themselves or others, 

registrants may be notified of immediate termination of TSA eligibility. 

E. MODIFICATION OF TSA IMPLEMENTATION 

At the written request of the STT, when accompanied by sufficient justification, including a 

recommendation from the FCO and/or RA (see Section A of this policy), the IADD may 

authorize: 

1. The addition of counties not initially designated for TSA; and/or 

2. An increase in the applicable General Services Administration (GSA) lodging rate of up to 

300%. 

a. The applicable rate can subsequently be decreased to the GSA lodging rate. 

b. Such requests must include information or specific data justifying the requested 

increase or decrease to the GSA lodging rate. 

c. Any adjustment to the established lodging rate will be applied during the next 

eligibility review. 

F. EXTENDING TSA 

If the IADD authorizes TSA for fewer than the maximum 180-day period of assistance, the RA 

has the authority to extend TSA up to the maximum 180-day period from the date of the 

declaration. In coordination with the FCO, the STT can submit a written request to extend TSA 

to the RA. 

The request must: 

1. Be received a minimum of 30 days prior to the end of the approved TSA period of 

assistance; and 

2. Include the dates for the previously approved TSA period(s) of assistance associated 

with the event; and 

3. Specify exigent circumstances justifying an extension (e.g., continued lack of rental 

resources, inability to access impacted areas, demonstrated need for a direct housing 

mission); and 

FEMA Policy #104-009-20 Page 5 of 8 
____________________________________ 

____________________________________ 

4. Include the end date for the requested extension; and 

5. Submit an exit strategy describing the actions and/or components that will assist 

registrants' transition to temporary or permanent housing solutions, including state or 

local housing and community development organizations. 

G. ENDING TSA 

TSA will end when: 

1. The STT does not request an extension prior to the end of the authorized TSA period of 

assistance; 

2. The RA denies an extension request beyond the authorized TSA period of assistance; or 

3. The period of assistance reaches 180 days from the date of declaration. 

Keith Turi 

Assistant Administrator, Recovery Directorate 

August 23, 2020 

Date 

FEMA Policy #104-009-20 Page 6 of 8 
 

ADDITIONAL INFORMATION 

REVIEW CYCLE 

FEMA Policy 104-009-20, Transitional Sheltering Assistance Policy (Interim), will be reviewed, 

reissued, revised and/or rescinded within one year of the issue date. 

AUTHORITIES and REFERENCES 

Authorities 

A. Section 403, 42 U.S.C. 5107b, Essential Assistance, of the Robert T. Stafford Disaster Relief 

and Emergency Assistance Act, as amended. 

B. Section 408, 42 U.S.C. 5174, Federal Assistance to Individuals and Households, of the Robert 

T. Stafford Disaster Relief and Emergency Assistance Act, as amended. 

C. Section 502, 42 U.S.C. 5192, Federal Emergency Assistance, of the Robert T. Stafford 

Disaster Relief and Emergency Assistance Act, as amended. 

Policies do not have the force and effect of law, except as authorized by law or as incorporated 

into a contract. 

References 

A. FEMA Policy 104-009-3, Individual Assistance Program and Policy Guide, March 2019. 

MONITORING AND EVALUATION 

Following the review of this policy, FEMA will consider changes necessary to FEMA Policy 104-

009-3, Individual Assistance Program and Policy Guide. 

QUESTIONS 

Direct questions to Zachary Usher, Branch Chief, Mass Care/Emergency Assistance, Voluntary 

Agency Coordination, Community Services, at Zachary.Usher@fema.dhs.gov. 

FEMA Policy #104-009-20 Page 7 of 8 
 

 

APPENDIX A: TSA ELIGIBILITY REVIEW MATRIX 

In addition to all initial and uniform continued eligibility criteria, these additional factors will be 

implemented at each eligibility review interval, with Interval 1 generally beginning after the first 

14 days that the registrant receives TSA, as follows: 

Eligibility

Review 

Intervals 

Ineligible Reason Explanation 

1 

Housed 

Registrant reports being back in damaged dwelling or 

alternate housing; new rental unit, Pre-disaster HUD; 

housing paid by other entities; DHAP, etc. 

No Habitability

Repairs Required 

FEMA home assessment indicates no disaster caused 

damage preventing the registrant from moving back to 

their primary dwelling. 

2 

Utilities Restored or 

Home Accessible 

(ERU-ERIA) only 

Utilities confirmed as restored and/or the home is now 

accessible. 

Appeal = Home is 

Safe to Occupy 

A home assessment appeal indicates the home is now 

habitable. 

Ineligible >30 days Registrant was notified of TSA eligibility and has not 

checked into a hotel in 30 days or more from notification. 

Not in Hotel Confirmed registrant is not currently checked into a hotel. 

Inaccessible 

The registrant indicates the dwelling is inaccessible at the 

time of registration and has not updated their accessibility 

or received a home assessment. 

3 

 Leased/Licensed 

into FEMA Direct 

Housing 

FEMA leased a registrant into a direct housing option. 

 Refused HUD 

Housing Assistance 

The registrant was referred to HUD housing and the 

registrant refused HUD housing assistance. 

Eligibility review criteria are cumulative and will continue throughout the duration of the 

approved TSA assistance period. 

As determined by FEMA HQ, in consultation with TSA field-deployed coordination staff, 

additional eligibility factors from Appendix A may be adjusted as a result of disaster specific 

exigent circumstances. 

FEMA Policy #104-009-20 Page 8 of 8