FLOOD INSURANCE

Participation of Indian 

Tribes in Federal and 

Private Programs

Report to Congressional Committees

January 2013

GAO-13-226

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-226, a report to 

congressional committees

January 2012

FLOOD INSURANCE

Participation of Indian Tribes in Federal and Private 

Programs

Why GAO Did This Study

Indian tribes’ participation in NFIP is 

extremely low, even though some 

Indian lands are at high risk of flooding. 

In response to a Moving Ahead for 

Progress in the 21st Century Act 

mandate, GAO examined (1) factors 

affecting Indian tribes’ participation in 

NFIP, (2) FEMA’s efforts to increase 

tribes’ participation in NFIP, and (3) 

administrative and legislative actions 

that could increase tribes’ participation.

GAO reviewed FEMA data on 

community participation in NFIP and 

prior GAO reports on flood insurance 

and Indian tribes, interviewed officials 

from selected Indian tribes and 

insurance companies, and collected 

information from relevant agencies and 

industry officials.

What GAO Recommends

GAO recommends that the FEMA 

Administrator examine ways to make 

mapping of tribal lands in flood-prone 

areas a higher priority. FEMA agreed 

with our recommendation.

What GAO Found

As of August 2012, just 37 of 566 federally recognized tribes (7 percent) were 

participating in the National Flood Insurance Program (NFIP), and 3 tribes 

accounted for more than 70 percent of policies. A number of factors have 

affected tribes’ participation. First, the Federal Emergency Management Agency 

(FEMA) has not placed a high priority on mapping rural areas, including many 

Indian lands, for flood risk, and most tribal lands remain unmapped. Without flood 

hazard maps, tribal communities may be unaware of their flood risk, even in highrisk areas. Partly for this reason, the risk of flooding is perceived as relatively low 

on many tribal lands. Further, tribes may lack the resources and administrative 

capacity needed to administer NFIP requirements, and NFIP premiums are often 

too high for low-income tribal members. Finally, unique tribal issues can make 

participation difficult. For example, some Indian tribes do not have reservations

over which they can enact and enforce the land use ordinances that are required 

for NFIP participation. Instead, many have lands that were allotted to individuals 

rather than to a tribal entity, limiting the tribes’ jurisdiction. 

FEMA has done some outreach to tribes, largely through emergency 

management and homeland security training for tribal officials, technical 

assistance to tribes that are preparing their multihazard mitigation plans, and 

marketing through the NFIP FloodSmart campaign. FEMA officials told us that 

the courses offered through its Emergency Management Institute helped to 

educate tribal officials about NFIP and floodplain management and that its 

curricula included courses for floodplain managers on their roles and 

responsibilities, flood insurance, and NFIP rules and regulations. One tribal 

representative told us that he was participating in an ongoing curriculum and 

several tribes had developed multihazard mitigation plans. Finally, both the 

Department of Housing and Urban Development and the U.S. Department of 

Agriculture, Rural Development may provide NFIP information to Indian tribes as 

they provide assistance in the form of housing and infrastructure grants, loans, 

and loan guarantees.

Tribal representatives suggested steps that FEMA could take to encourage 

participation in NFIP—for example, placing a higher priority on mapping Indian 

lands and increasing FloodSmart marketing to tribal leaders rather than 

individuals. Given ongoing congressional interest in private sector alternatives to 

NFIP, GAO also explored whether private alternatives exist that could offer 

affordable coverage to low-income tribal members—for example, by expanding 

access to risk-pooling programs that could help insure more tribal households. 

One such program already insures thousands of Indian properties. Another 

relatively new product, microinsurance, would involve insurers offering less 

expensive policies with relatively low coverage limits but coverage for all tribes. 

FEMA said that its NFIP privatization study mandated by the Biggert-Waters 

Flood Insurance Reform Act of 2012 would include an assessment of these 

alternatives. 

View GAO-13-226. For more information, 

contact Alicia Puente Cackley, (202) 512-8678 

and cackleya@gao.gov.
Page i GAO-13-226 Tribes and Flood Insurance

Letter 1 

Background 4

A Number of Factors Contribute to Indian Tribes’ Low NFIP 

Participation Rate 13

FEMA Has Provided Indian Tribes with Training and Technical 

Assistance on Hazard Mitigation, Including Flood Insurance 20

Boosting Tribes’ Participation in Flood Insurance Programs 23

Conclusions 29

Recommendation 29

Agency Comments 30

Appendix I Objectives, Scope, and Methodology 31

Appendix II Comments from the Federal Emergency Management 

Agency 34

Appendix III GAO Contact and Staff Acknowledgments 36

Tables

Table 1: Participation in NFIP among Federally Recognized Indian 

Tribes (August 2012) 14

Table 2: NFIP Access for Tribes in Alaska (2012) 19

Table 3: Tribal Flood Insurance Policies in Place with AMERIND 

(November 2012) 27

Figures

Figure 1: Number of Major Flood Disaster Declarations by County 

and U.S. Indian Reservation (1980-2005) 6

Figure 2: Alaska Native Fishing Village That Has Experienced 

Flooding (August 2009) 18

Contents 
Page ii GAO-13-226 Tribes and Flood Insurance

Abbreviations

BIA Bureau of Indian Affairs

CRS Congressional Research Service

EMI Emergency Management Institute

FEMA Federal Emergency Management Agency

FIRM Flood Insurance Rate Map

HUD Department of Housing and Urban Development 

ICDBG Indian Community Development Block Grant

IHBG Indian Housing Block Grant

NAHASDA Native American Housing Assistance and Self- 

 Determination Act of 1996

NFIP National Flood Insurance Program

SFHA Special Flood Hazard Area

USDA U.S. Department of Agriculture 

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-13-226 Tribes and Flood Insurance

United States Government Accountability Office

Washington, DC 20548

January 4, 2013

The Honorable Tim Johnson

Chairman

The Honorable Richard C. Shelby

Ranking Member

Committee on Banking, Housing, and Urban Affairs

United States Senate

The Honorable Jeb Hensarling

Chairman

The Honorable Maxine Waters

Ranking Member

Committee on Financial Services

House of Representatives

Flooding is the most common and destructive natural hazard facing the 

nation, resulting in billions of dollars in losses each year. Between 1980 

and 2005, about 97 percent of the U.S. population lived in counties that 

had experienced at least one declared flood disaster, and 45 percent 

lived in counties that had experienced six or more.1 Further, federal 

estimates show that more than half of the U.S. population now lives in 

coastal watershed counties or floodplain areas.2

Congress created the National Flood Insurance Program (NFIP) in 1968 

to mitigate future flood losses nationwide through community floodplain 

management ordinances and to provide access to affordable, federally 

backed flood insurance protection for property owners.

Indian lands have experienced their share of flooding. Some have flooded 

repeatedly, yet few tribes participate in NFIP. In a July 2011 hearing on 

emergency preparedness for natural disasters in Native American 

communities, the Senate Committee on Indian Affairs questioned why 

 

1

We used data that we had reported previously to show trends over time—in this case, a 

25-year period. See GAO, Natural Hazard Mitigation, Various Mitigation Efforts Exist, but 

Federal Efforts Do Not Provide a Comprehensive Strategic Framework, GAO-07-403 

(Washington, D.C.: Aug. 22, 2007).

2

Congressional Research Service, National Flood Insurance Program: Background, 

Challenges, and Financial Status, R40650 (Washington, D.C.: June 12, 2012). 

 
 

Page 2 GAO-13-226 Tribes and Flood Insurance

tribal participation in NFIP was low and whether efforts to encourage 

greater participation had been successful.3 Congress included a mandate 

in section 100237 of the Moving Ahead for Progress in the 21st Century 

Act that required us to examine the factors contributing to the current 

rates of NFIP participation by Indian tribes and members of Indian tribes 

and methods of encouraging such participation.4

For the purposes of this review, we limited our study primarily to flood 

insurance policies held on Indian tribal lands (such as reservations), 

because FEMA does not collect demographic data such as race or ethnic 

origin of NFIP policyholders. Therefore, no comprehensive data are 

available on members of Indian tribes who are living in nontribal 

communities and may carry individual NFIP policies. We also interviewed 

representatives from Alaska, because many Alaska Native communities 

are vulnerable to floods but the tribes lack jurisdiction to adopt and 

enforce land use ordinances, a requirement for community participation in 

NFIP.

In addition, the mandate 

required us to describe steps that the Federal Emergency Management 

Agency (FEMA) within the Department of Homeland Security should take 

to increase awareness and encourage participation in NFIP by Indian 

tribes and members of Indian tribes and to identify any legislative 

changes that would encourage such participation. In response to the 

mandate, this report examines (1) factors contributing to the current low 

levels of NFIP participation by Indian tribes, (2) FEMA’s efforts to 

increase tribes’ participation in NFIP, and (3) administrative and 

legislative actions that could encourage Indian tribes and their members 

to increase their participation in NFIP and potentially other flood 

insurance programs.

In conducting this work, we reviewed NFIP laws and policy documents. 

We reviewed FEMA data on communities participating in NFIP, including 

those designated as tribal communities, and on tribes that had flood 

hazard maps but were not participating in NFIP for various reasons. 

FEMA provided us with information on its process for collecting and 

analyzing the data in its Community Information System database and on 

 

3

Facing Floods and Fires: Emergency Preparedness for Natural Disasters in Native 

Communities: Hearing before the S. Comm. on Indian Affairs, 112th Cong. 44-45

(statement of Sen. Mike Johanns, Member, S. Comm. on Indian Affairs), 2011. 

4

Pub. L. No. 112-141, § 100237, 126 Stat. 405, 957-58 (2012).
 

Page 3 GAO-13-226 Tribes and Flood Insurance

the agency’s data reliability measures.5

We selected the tribes from among those on FEMA’s lists of tribes that 

were participating in NFIP as well as those that had flood hazard maps 

but were not participating in NFIP. We selected a purposive nonrepresentative sample of eight participating tribes for interviews based on 

the number of individual policies within each tribe, geographic diversity, 

and tribe size. We also selected a purposive non-representative sample 

of six nonparticipating tribes for interviews based on the reason for 

nonparticipation, geographic diversity, and tribe size. In addition, our prior 

work related to the Native American Housing Assistance and SelfDetermination Act of 1996 (NAHASDA) program partially informed the 

tribes we selected.

We determined that the data 

FEMA provided to us were sufficiently reliable for our reporting purposes. 

In addition, we reviewed our prior work on flood insurance, Indian tribes,

and disaster preparedness. We also interviewed and gathered 

documentation from officials at FEMA and other federal agencies with 

programs that assist Indian tribes, such as the Bureau of Indian Affairs 

(BIA) within the Department of the Interior, Department of Housing and 

Urban Development (HUD), and the U.S. Department of Agriculture 

(USDA) Rural Development. In addition, we reviewed regulations for 

those agencies’ programs. We spoke with representatives from the State 

of Alaska; the National Flood Determination Association, which provides 

flood mapping data to mortgage lenders and insurers; the insurance and 

reinsurance industries; a nonprofit risk-pooling organization; FloodSmart,

which administered FEMA’s NFIP media campaign; and selected Indian 

tribes.

6

 

5

FEMA maintains data on communities, including Indian tribes, that participate in NFIP 

and on their floodplain management activities in its Community Information System 

database. The data include the FEMA region in which each tribe is located (including state 

and county), community identification numbers and names, date of the most recent flood 

maps, and number of NFIP policies in place for each tribe. The database also contains 

information on mapped communities that do not participate in NFIP. FEMA designates 

communities as “tribal” based on self-reported data from the tribes themselves. 

Specifically, because we had already established 

communication with certain tribes, we selected them over comparable 

tribes on either list. Because of our time constraints and several selected 

tribes being impacted by a natural disaster (Superstorm Sandy), we were 

able to interview five participating and five nonparticipating tribes. We 

6

See GAO, Native American Housing: Tribes Generally View Block Grant Program as 

Effective, but Tracking of Infrastructure Plans and Investments Needs Improvement, 

GAO-10-326 (Washington, D.C.: Feb. 25, 2010). 
 

Page 4 GAO-13-226 Tribes and Flood Insurance

also judgmentally selected a tribe in Alaska that we had contacted

previously to obtain a perspective on NFIP from a tribe in that state. To 

obtain perspectives from the insurance industry, we interviewed 

representatives from an insurance company that we contacted while 

conducting prior work related to the Write-Your-Own insurance program,

a vendor that administers NFIP policies for Write-Your-Own insurance 

companies, and an insurance broker that specializes in working with 

Indian tribes.7

We conducted this performance audit from August 2012 to January 2013 

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 I contains a detailed description of our scope and 

methodology.

Floods can result in the loss of lives, extensive damage to property and 

agriculture, and large-scale disruptions to business and infrastructure, 

such as transportation and water and sewer services.8 The National 

Oceanic and Atmospheric Administration estimates that floods cause 

about 140 deaths in the United States each year, and the Army Corps of 

Engineers estimates that floods cause $6 billion in average annual 

losses. Congress established NFIP in the National Flood Insurance Act of 

1968 to provide policyholders with some insurance coverage for flood 

damage as an alternative to disaster assistance, and to try to reduce the 

escalating costs of repairing flood damage.9

 

7

See GAO, Flood Insurance: Opportunities Exist to Improve Oversight of the WYO 

Program, 

The program was 

subsequently modified by various amendments, including the Flood 

Disaster Protection Act of 1973 (1973 Act) and the National Flood 

GAO-09-455 (Washington, D.C.: Aug. 21, 2009).

8

GAO-07-403. 

9

Pub. L. No. 90-448, Tit. XIII, 82 Stat. 572 (1968).

Background 
 

Page 5 GAO-13-226 Tribes and Flood Insurance

Insurance Reform Act of 1994.10 And most recently, NFIP was amended 

by the Biggert-Waters Flood Insurance Reform Act of 2012.11

The 1973 Act added certain requirements that, according to FEMA 

officials, were intended to encourage community participation in NFIP. 

Specifically, as a condition of future federal financial assistance, 

communities are required to participate in NFIP and to adopt adequate 

floodplain ordinances with effective enforcement provisions consistent 

with federal standards in order to reduce or avoid future flood losses. 

Figure 1, which shows the location of U.S. Indian reservations and major 

flood disaster declarations over a 25-year period, indicates that many 

Indian tribes reside in areas that have experienced multiple floods.

 

10Pub. L. No. 93-234, 87 Stat. 975 (1973); Pub. L. No. 103-325 Tit. V, 108 Stat. 2160 

(1994). 

11Pub. L. No. 112-141, Div. F, Tit. II, Subtit. A, 126 Stat. 405, 916 (2012). 
 

Page 6 GAO-13-226 Tribes and Flood Insurance

Figure 1: Number of Major Flood Disaster Declarations by County and U.S. Indian Reservation (1980-2005)

The 1973 Act denied direct federal financial assistance and financing by 

private lending institutions regulated by federal regulators for acquisition 

or construction purposes in participating communities where flood 

insurance was available unless the property was covered by flood 

insurance. Prior to the 1973 Act, the purchase of flood insurance had 

been voluntary. However, this mandatory purchase requirement, further 

amended by the National Flood Insurance Reform Act of 1994, effectively 
 

Page 7 GAO-13-226 Tribes and Flood Insurance

requires owners of property to obtain flood insurance if they are located in 

a Special Flood Hazard Area (SFHA) within a community participating in 

NFIP and obtain a mortgage from a federally regulated lending institution 

or a federal agency lender or receive direct federal financial assistance 

for acquisition or construction purposes.

The mandatory purchase requirement applies to secured mortgage loans 

from financial institutions such as banks, savings and loan associations, 

savings banks, and credit unions that are supervised by federal agencies, 

including the Federal Deposit Insurance Corporation and the Office of the 

Comptroller of the Currency. It also applies to all mortgage loans secured 

by real estate on which a building is constructed in an SFHA for which 

flood insurance is available if purchased by Fannie Mae and Freddie Mac 

in the secondary mortgage market. Loans and grants through financial 

assistance programs from agencies such as the Federal Housing 

Administration and the Department of Veterans Affairs are also affected.12

The requirement also extends to several federal programs that assist 

Indian tribes. For example, recipients of funds from BIA’s Housing 

Improvement Program, HUD’s Indian Housing Block Grant (IHBG) and 

Indian Community Development Block Grant (ICDBG), and several USDA 

Rural Development loan programs are required to purchase flood 

insurance if an assisted structure is in an SFHA.13

 

12Owners of properties that receive federal financial assistance for acquisition or 

construction purposes in SFHAs in communities that participate in NFIP are required to 

purchase and retain flood insurance. It is important to note that FEMA is prohibited from 

providing certain types of disaster assistance in connection with floods to applicants 

located in SFHAs if the community does not participate in NFIP. See 42 U.S.C. § 4106.

Finally, individuals in

SFHAs who receive federal disaster assistance after September 23, 

1994, for flood disaster losses to real or personal property are required, 

13BIA’s Housing Improvement Program funds home repair, renovation, and replacement. 

The program provides grants to the neediest Indian families who live in substandard 

housing or are without housing and have no other resource for assistance. The IHBG is 

authorized under the Native American Housing Assistance and Self-Determination Act of 

1996 (NAHASDA) program. The IHBG and ICDBG are available to qualifying tribal entities 

to fund several eligible activities related to housing and community development, 

respectively. For additional details on NAHASDA, see GAO-10-326. USDA Rural 

Development provides low-income housing assistance through several programs for 

which Indian tribes or their members are eligible, including the section 515 (Rural Rental 

Housing) and section 502 (Single-Family Housing) loan programs and the section 504 

(Rural Housing Repair and Rehabilitation) loan and grant program. USDA Rural 

Development also provides financing for community infrastructure to tribes through 

multiple programs that may require flood insurance as a loss mitigation measure.
 

Page 8 GAO-13-226 Tribes and Flood Insurance

as a condition for receiving future disaster assistance, to purchase and 

maintain flood insurance coverage on the property. According to FEMA, 

in December 2012 the average NFIP policy cost about $600 per year, 

with policies in SFHAs typically costing more and some policies outside 

SFHAs costing less.

FEMA identifies and maps flood-prone areas throughout the United 

States and its territories that are eligible to participate in NFIP. According 

to a Congressional Research Service (CRS) report on NFIP, FEMA also 

makes flood hazard information available on its website for viewing or 

purchasing.14 The report notes that FEMA works with communities to 

develop new flood hazard data as part of a flood insurance study, issues 

public notification about maps, and engages in education and outreach to 

help ensure that community leaders and residents understand the 

mapping process and the appropriate use of flood maps. The CRS report 

further notes that reliable flood risk data, including updated flood maps, 

and educating residents about flood risk, contribute to mitigating future 

flood losses. Most areas of flood hazard are commonly identified on Flood 

Insurance Rate Maps (FIRM), and areas not yet identified by a FIRM may 

be mapped on Flood Hazard Boundary Maps.15

 

14CRS, R40650. 

Several areas of flood 

hazard are identified on these maps, one of which is the SFHA. The 

SFHA is a high-risk area defined as any land that would be inundated by 

a flood having a 1 percent chance of occurring in a given year (base 

flood); this is the equivalent of a 26 percent chance of flooding over a 30-

year mortgage. According to FEMA, the SFHA constitutes a reasonable 

compromise between the need for building restrictions to minimize 

potential loss of life and property and the economic benefits to be derived 

from floodplain development. Development may take place within an 

SFHA as long as it complies with local floodplain management 

ordinances, which must meet minimum federal requirements. Flood 

insurance is required for insurable structures within high-risk areas to 

protect federal financial investments and assistance used for acquisition 

or construction purposes within communities participating in NFIP.

15A FIRM is an official map of a community on which FEMA has delineated both the 

SFHAs and risk premium zones applicable to a community. A Flood Hazard Boundary 

Map is based on approximate data and identifies the SFHAs within a community. 
 

Page 9 GAO-13-226 Tribes and Flood Insurance

In July 2012, Congress passed the Biggert-Waters Flood Insurance 

Reform Act of 2012.16 The act extends NFIP for 5 years and makes 

reforms to the program that include (1) phasing out subsidies for many 

properties, (2) raising the cap on annual premium increases for other 

policies from 10 to 20 percent, (3) clarifying that certain multifamily 

properties are eligible for NFIP policies, (4) imposing minimum 

deductibles for flood claims, (5) requiring NFIP to establish a reserve 

fund, and (6) establishing a technical mapping advisory council to deal 

with map modernization issues. The act also calls for an assessment by 

FEMA and GAO, separately, of options and strategies for privatizing NFIP 

in the future and authorizes FEMA to pursue private risk-management 

initiatives to determine the capacity of private insurers and markets to 

assist communities in managing the full range of financial risks associated 

with flooding.

Because of its subsidized premium rates and catastrophic hurricanerelated floods in recent years, NFIP has accrued a substantial debt that 

stood at nearly $18 billion as of October 2012.17 We previously reported 

that NFIP was designed to pay operating expenses and flood insurance 

claims with premiums collected on flood insurance policies rather than 

with tax dollars, and that FEMA had statutory authority to borrow funds 

from Treasury to keep NFIP solvent in years when losses were high.18

We noted that by design NFIP was not actuarially sound, because 

Congress authorized subsidized insurance rates for policies covering 

certain structures to encourage communities to join the program. Since 

2000, NFIP has experienced several catastrophic loss years (years with 

$1 billion or more in losses). These years include 2001, 2004, 2005, and 

2008.

19

 

16Pub. L. No. 112-141, Div. F, Tit. II, Subtit. A.

By the end of 2012, NFIP is expected to have experienced 

17The Biggert-Waters Flood Insurance Reform Act of 2012 eliminated insurance premium 

subsidies on new policies and phased out subsidies for certain existing policies, including 

properties that have severe repetitive losses and properties that have incurred floodrelated damage that exceeds the fair market value of the property. Pub. L. No. 112-141, § 

100205. 

18See GAO, FEMA: Action Needed to Improve Administration of the National Flood 

Insurance Program, GAO-11-297 (Washington, D.C.: June 9, 2011). 

19Flooding events corresponding with these losses are Tropical Storm Allison (2001), 

Hurricane Ivan (2004), the Gulf Coast Hurricanes (2005), and Hurricane Ike (2008). 

NFIP Status
 

Page 10 GAO-13-226 Tribes and Flood Insurance

another catastrophic loss year because of the enormous damage from 

the October storm known as Superstorm Sandy.

Under FEMA’s NFIP regulations, a community is defined as any state or 

area or political subdivision thereof or any Indian tribe or authorized tribal 

organization, or Alaska Native Village or authorized native organization, 

that has the authority to adopt and enforce floodplain management 

ordinances for the area under its jurisdiction.20

NFIP has three components: (1) the provision of flood insurance, (2) a 

requirement that participating communities adopt and enforce floodplain 

management regulations, and (3) the identification and mapping of 

floodplains. Community participation in NFIP is voluntary, although some 

states require participation as part of their floodplain management 

program. Each identified flood-prone community must assess its risk of 

flood hazards and determine whether flood insurance and floodplain 

management would benefit the community. However, a community that 

chooses not to participate in NFIP within 1 year of identifying the flood 

hazard and receiving a flood hazard map may face consequences as a 

result of its nonparticipation, because no flood insurance can be sold in 

the community and it may be ineligible for certain types of federal 

assistance because of the acquisition and construction prohibition of 42 

U.S.C. § 4106 such as Stafford Act disaster benefits for home repairs.

Indian tribes, authorized 

tribal organizations, Alaska Native villages, and authorized native 

organizations that have land use authority are considered communities by 

NFIP and can join the program even if no flood hazard map exists that 

covers all tribal lands.

21

 

2044 C.F.R. § 59.1. Although Indian tribes are not explicitly mentioned in the National 

Flood Insurance Act, the Federal Insurance Administrator and subsequently FEMA have 

issued rulemakings that define “community” as including Indian tribes for purposes of 

NFIP. Like all communities, tribal communities must have the authority to adopt and 

enforce floodplain management regulations for the areas within their jurisdiction in order to 

be eligible for participation in NFIP.

A 

community must join NFIP and adopt FEMA-approved floodplain 

management requirements in order for residents to purchase federal flood 

insurance. Once a community begins participating in NFIP, property 

owners can purchase individual NFIP policies. Current law prohibits 

lenders from making loans for real estate in areas at high risk for flooding, 

21See 44 C.F.R. § 206.110(k).

Community Participation
 

Page 11 GAO-13-226 Tribes and Flood Insurance

where the community is participating in NFIP, unless the property is 

covered by flood insurance.22

Communities participating in NFIP do so as part of either the regular or 

emergency program. A community participating in the regular NFIP 

program is usually provided with a FIRM and a flood insurance study. As 

part of their agreement to participate in NFIP, communities adopt and 

enforce floodplain management ordinances and FIRMs. If communities 

do not adopt and enforce these ordinances, they can be placed on 

probation or suspended from the program. However, such actions take 

place only after FEMA has taken steps to help the community become 

compliant. The NFIP emergency program is the initial phase of a 

community’s participation in NFIP and was designed to provide a limited 

amount of flood insurance. A community participating in the emergency 

program either does not have an identified and mapped flood hazard or 

has been provided with a Flood Hazard Boundary Map, and the 

community is required to adopt limited floodplain management standards 

to control future use of its floodplain. According to FEMA, fewer than 3 

percent of the more than 21,000 communities participating in NFIP are in 

the emergency program.

Participating communities can receive 

discounts on flood insurance if they establish floodplain management 

programs that go beyond the minimum requirements of NFIP. FEMA can 

suspend communities that do not comply with the program and 

communities can withdraw from the program (both with sanctions). 

Currently, more than 21,000 communities participate in NFIP.

The federal government has consistently recognized Indian tribes as 

distinct, independent political communities with the inherent powers of a 

limited sovereignty that has never been extinguished. As of August 2012, 

there were 566 federally recognized tribes—341 in the contiguous 48 

states and 225 in Alaska.23

 

2242 USC § 4012a. 

To help manage tribal affairs, tribes have 

formed governments and subsidiaries of tribal governments, including 

schools, housing, health, and other types of corporations. The United 

States has a trust responsibility to recognized Indian tribes and maintains 

a government-to-government relationship with them.

23Since 1979, BIA has regularly published a list of federally recognized Indian tribes in the 

Federal Register. For the latest list, see 77 Fed. Reg. 47.868 (Aug. 10, 2012). 

Indian Tribes
 

Page 12 GAO-13-226 Tribes and Flood Insurance

Tribal lands vary dramatically in size, demographics, and location. They 

range from the Navajo Nation, which consists of about 27,000 square 

miles across portions of Arizona, New Mexico, and Utah, to some tribal 

land areas in California of less than 1 square mile. Over 176,000 

American Indians live on the Navajo reservation, while some other tribal 

lands have fewer than 50 Indian residents. Some Indian reservations 

have a mixture of Indian and non-Indian residents. Most tribal lands are 

rural or remote, although some are near metropolitan areas.24

Over half of Indian tribes, however, do not have reservations or other 

lands over which they could enact and enforce land use ordinances—

which is required for participation in NFIP—and even tribes with 

reservations often do not have authority to enact such ordinances for all 

land within the reservation’s boundaries.25 For example, the Alaska 

Native Claims Settlement Act revoked all existing Indian reservations in 

Alaska except one and, as a result of this law and a Supreme Court case, 

tribes in Alaska generally do not have authority to enact land use 

ordinances.26 Also, a number of Indian reservations, primarily in 

Oklahoma, were disestablished through the allotment of reservation land 

to individual tribal members.27

 

24GAO, Indian Issues: Observations on Some Unique Factors that May Affect Economic 

Activity on Tribal Lands, 

Upon an Indian allottee’s death, these 

allotments passed to heirs and ownership of some allotted land has 

continually been divided with each generation of heirs, resulting in large 

numbers of heirs holding interest in the land as tenants in common. In 

some cases, such “fractionated lands” have up to several hundred 

ownership interests. Fractionation complicates basic homeownership 

issues such as whether to take out a flood insurance policy, because 

such decisions may require agreement among entities with shared 

ownership. Some of these allotments, as well as parcels of land within 

GAO-11-543T (Washington, D.C.: Apr. 7, 2011). 

25We have reported in the past that some tribes are landless. See table 4 in GAO, Indian 

Issues: BLM’s Program for Issuing Individual Indian Allotments on Public Lands Is No 

Longer Viable, GAO-07-23R (Washington, D.C.: Oct. 20, 2006). See Brendale v. 

Confederated Tribes and Bands of Yakima Indian Nations, 492 U.S. 408 (1989).

26Pub. L. No. 92-203, 85 Stat. 688 (1971), codified as amended at 43 U.S.C. §§ 1601-

1629h. 

27The Act of February 8, 1887, commonly referred to as the General Allotment Act, 

authorized the President to allot parcels of land—generally in sizes of 40, 80, or 160 

acres— to individual Indians on Indian reservations and on public lands. Indian General 

Allotment Act, 24 Stat. 388 (1887). See GAO-07-23R. 
 

Page 13 GAO-13-226 Tribes and Flood Insurance

reservation boundaries, have been inherited or purchased by non-Indians 

and Indian tribes generally lack jurisdiction over land owned by nonIndians.

In some cases, although a tribe is not an NFIP participant, the tribe may 

be located in another community that participates in NFIP.

A proposed amendment to the Robert T. Stafford Disaster Relief and 

Emergency Assistance Act would allow Indian tribes to request a major 

disaster declaration by the President.28 The proposed amendment would 

provide Indian tribes with this authority so that they would not be required 

to rely on assistance through a presidential declaration requested by the 

state or locality.29 Federal officials with whom we spoke generally viewed 

this amendment as a positive action in the interest of tribes. For example, 

USDA Rural Development officials said that this authority would make it 

easier for tribes to access disaster relief resources. Representatives of 

several tribes we interviewed said that such a change would open up 

direct communication between the federal government and Indian tribes. 

However, questions remained about how the proposed amendment would 

be implemented. It is not yet clear how the proposed Stafford Act 

amendment would affect Indian tribes’ willingness to participate in NFIP. 

According to FEMA, as of August 2012, 37 out of 566 federally 

recognized tribes nationwide—roughly 7 percent—were participating in 

NFIP (see table 1). The number of policies for each tribe ranged from 1 to 

175, and 14 participating tribes had no individual policies. Across all 

participating Indian tribes, 414 policies were in place, accounting for less 

than 1 hundredth of a percent of all NFIP policies.30

 

28S. 2283, 112th Cong. (2012). 

29The proposed amendment, however, would not prohibit a tribe from receiving assistance 

through a presidential declaration at the request of a state if the President does not make 

a declaration at the request of a tribe. 

30According to FEMA, there were nearly 5.6 million NFIP policies in place as of August 

2012. 

Proposed Amendment to 

the Stafford Disaster Relief 

and Emergency Assistance 

Act

A Number of Factors 

Contribute to Indian 

Tribes’ Low NFIP 

Participation Rate
 

Page 14 GAO-13-226 Tribes and Flood Insurance

Table 1: Participation in NFIP among Federally Recognized Indian Tribes (August 

2012)

Measure Number

Number of federally recognized Indian tribes 566

Number of tribes participating in NFIP 37

Number of participating tribes with insurance 

policies in place

23

Concentration of insurance policies in place 5 tribes (82 percent of policies)

3 tribes (70 percent of policies)

Source: FEMA.

FEMA’s data also show that, among communities that have received 

flood hazard maps but are not participating in NFIP, there are 46 tribal 

communities.

Federal agency officials, tribes, and others described several factors that 

affect whether tribes purchase flood insurance through NFIP or other 

programs. 

FEMA does limited mapping in tribal communities. Flood maps show 

communities and homeowners the level of flood risk they face. According 

to FEMA, as of October 2012, 78 tribal communities had received flood 

hazard maps.31

 

31According to FEMA, 8 of the 37 tribes participating in NFIP did not have their own flood 

hazard maps. Three had their tribal lands mapped on county maps and 5 were 

participating without a map in the NFIP emergency program. As noted, there were also 46 

mapped tribes not participating in NFIP. 

Representatives of the National Flood Determination 

Association, which provides FEMA flood mapping data to mortgage 

lenders and insurers, told us that some tribes that were not participating 

in NFIP had not been mapped and that because they did not know their 

flood risk, they likely did not see the advantages to NFIP participation. In 

discussing the agency’s mapping efforts, FEMA officials explained that 

tribal communities generally included small rural areas that were not a 

high priority for the agency. The officials said that FEMA had focused its 

mapping efforts on heavily populated urban and coastal areas with a high 

risk of flooding. The officials also noted that because of the tribes’ 

sovereignty, the agency needed permission to enter tribal lands and 

conduct mapping activities and that such permission could be difficult to 

obtain. Additionally, they were concerned that tribes might not grant 
 

Page 15 GAO-13-226 Tribes and Flood Insurance

permission for FEMA to publish a map if tribal borders were in dispute. 

They explained that if FEMA could not overcome these challenges, it 

might exclude the tribal area from the watershed map.32

Representatives of a Washington tribe that received its flood hazard 

maps from FEMA in 2004 told us the tribe had participated in NFIP since 

1997, 7 years prior to receiving the maps. The tribe initially participated in 

NFIP’s emergency program and then became a regular participant once 

its maps were finalized. They explained that the tribe had largely been 

motivated by a need to clarify its jurisdictional (land and water) area, 

which flood mapping allowed them to do. Further, they said that joining 

NFIP had provided an opportunity to obtain flood insurance as a tribal 

community instead of participating as part of the surrounding county, 

supporting the tribe’s interest in self-determination.

 However, they 

did not provide us with any specific examples of maps with such 

exclusions.

33

Most nonparticipating tribes that have been mapped face relatively 

low flood risk. According to FEMA, most of the nonparticipating tribal 

communities have very low flood risk. Thirty-five of the 46 tribal 

communities that FEMA told us had been mapped but were not 

participating in NFIP had been determined to have low flood risk. Another 

However, this tribe is 

vulnerable to flooding from several sources, and the representatives 

noted that it had long been proactive in disaster mitigation efforts as a 

whole. Emergency officials from another tribe told us that approximately 

10 percent of their reservation was mapped and that the mapping had 

been done by the Army Corps of Engineers. They said their 

understanding was that until recently, FEMA did not conduct flood 

mapping on federal reservations.

 

32A watershed (also a basin or catchment area) may be defined as an area that drains into 

a lake, stream, or other body of water. In fiscal year 2010, FEMA implemented a 

watershed-based approach for conducting flood hazard studies. Specifically, FEMA 

officials explained that mapping is done at a county and watershed level rather than 

community-by-community. According to FEMA, the overarching principle of the watershed 

approach is to develop a complete, consistent, and connected flood engineering analysis 

within a watershed.

33As previously noted, FEMA assigns a unique community identification number to each 

community listed in its NFIP Community Information System database. The actions of a 

specific community under NFIP directly impact the availability and cost of NFIP policies for 

its residents. For example, a community’s actions could result in its residents receiving 

NFIP policy discounts. For more on Indian self-determination, see GAO-10-326. 
 

Page 16 GAO-13-226 Tribes and Flood Insurance

9 were in the 1-year “opportunity period” for addressing any identified 

flood hazards and joining NFIP, and 2 had been determined to have 

some flood risk but were not participating.

One representative of a participating Washington tribe suggested that 

tribes that are most at risk for flooding should be given priority in efforts to 

encourage tribal participation in NFIP. The tribal representative said that 

expecting those not highly vulnerable to flooding to purchase costly flood 

insurance when they have other priorities would be difficult. When we 

spoke with an emergency management official from a nonparticipating 

Wisconsin tribe, he agreed that because the tribe had not experienced a 

major flood, there was a general lack of urgency on the part of tribal 

leadership about NFIP participation.

Many tribes lack the resources or administrative capacity to join 

NFIP. FEMA officials told us that affordability affected tribes’ participation 

in NFIP as it did other low-income communities and individuals. The 

officials also told us that they had seen slow to no insurance policy growth 

in areas of the country where the economy was not performing well. A 

representative of the National Flood Determination Association agreed 

that the cost of coverage could limit tribes’ participation, noting that there 

is a general lack of funding for mapping. Further, he said that many rural 

communities, including tribal communities, were not in favor of adopting 

land use regulations and did not have the resources to adopt and 

implement them.

Representatives of the participating Washington tribe with the highest 

number of individual policies as of August 2012 acknowledged that NFIP 

participation was administratively burdensome and costly. In particular, 

they explained that developing flood damage reduction ordinances and 

then implementing the ordinances required dedicated staff that not all 

tribes have. In general, they acknowledged that many tribes lacked the 

resources that this tribe had to pursue NFIP participation. Similarly, a 

Wisconsin tribal official said that pursuing NFIP participation could be 

especially challenging for tribes that lacked emergency, planning, or 

zoning functions and tribes that may not even have developed building 

codes on their lands. He emphasized that such limitations should be 

taken into account in examining why tribes may not be participating in 

NFIP.

Many tribes view affordability as a significant issue for their 

members in purchasing NFIP policies. Many tribal representatives said 

that affordability would be an issue for tribal members. For instance, 
 

Page 17 GAO-13-226 Tribes and Flood Insurance

representatives of an Oklahoma tribe told us that while affordability would 

not affect the tribe’s decision to participate in the program, because the 

tribe would use NFIP to insure its government and commercial buildings, 

it would be a factor for individual tribal members. Specifically, they 

explained that paying flood insurance premiums would be challenging for 

individuals who already lacked the resources to afford homeowner, 

renter, and automobile insurance. Representatives of other tribes agreed 

that NFIP premiums would be costly for the members of their tribes. 

Emergency management representatives of a large western tribe told us 

they were not aware of any tribal members who had flood insurance on 

their homes and that even homeowner insurance coverage was rare. 

They explained that the average annual household income on the 

reservation was between $12,000 and $15,000 and that unemployment 

was at least 28 percent. A tribal housing official from Alaska whose 

members can participate in NFIP through the surrounding borough told us 

that he had found that most members of his tribe dropped their 

homeowners insurance as soon as their homes were paid off and that he

expected they would do the same with required flood insurance, which 

can cost more than $1,000 a year.34

 

34As previously noted, under NAHASDA, recipients of HUD grant funds are required to 

obtain flood insurance coverage when the development assisted with those funds is in an 

identified SFHA. The required period for insurance coverage is the useful life of the 

property, as defined by the grantee with HUD approval. 

An official for another Oklahoma tribe 

that was participating in NFIP but had no active individual policies said he 

did not believe flood insurance was a priority for members of his tribe, 

whose average annual household income was $6,000. Figure 2 shows a 

Native Alaska fishing village that has experienced flooding but whose 

residents, according to the tribe’s housing director, have not purchased 

NFIP flood insurance due to the high cost.
 

Page 18 GAO-13-226 Tribes and Flood Insurance

Figure 2: Alaska Native Fishing Village That Has Experienced Flooding (August 2009)

Unique Indian issues also impact tribal participation in NFIP. As 

previously noted, all but one of the tribes in Alaska lack a reservation.

Because the tribes lack jurisdiction to enact and enforce land use 

ordinances over the land where they reside, they cannot directly 

participate as communities in NFIP. In many cases, the tribes are colocated with other government entities that may participate in NFIP, such 

as cities and boroughs, and their members may access NFIP through 

those other entities. Alaska state officials told us that an estimated 66 

percent of the Alaska Native population could participate in NFIP because 

they lived in a city or borough that participated in the program. Based on 

data we compiled and analyzed, 58 of 225 Alaska tribes were co-located 

with a participating community (see table 2).
 

Page 19 GAO-13-226 Tribes and Flood Insurance

Table 2: NFIP Access for Tribes in Alaska (2012)

Measure of access Number

Tribes in Alaska located in an incorporated area that participates 

in NFIP

58

Tribes in Alaska located in an incorporated area that does not 

participate in NFIP

102

Tribes in Alaska located in unincorporated boroughs or 

municipalities(unincorporated areas are not eligible to participate 

in NFIP)

64

Metlakatla Indian Community, Annette Island Reserve (does not 

participate in NFIP)

1 

Total 225 

Source: GAO analysis of data from FEMA, the State of Alaska, and the Bureau of Indian Affairs.

Notes: (1) For this table we focused on the geographic location of specific Alaska Native entities. As a 

result, we counted some entities separately that would normally be combined and we excluded two 

other regional entities. Specifically, we counted Arctic Village and the Village of Venetie separately 

rather than combined under the Native Village of Venetie Tribal Government (Arctic Village and 

Village of Venetie) umbrella entity. Similarly, we counted Saint George Island and Saint Paul Island 

separately rather than combined under the Pribilof Islands Aleut Communities of St. Paul and St. 

George Islands umbrella entity. Finally, we excluded the Central Council of the Tlingit and Haida 

Indian Tribes and the Inupiat Community of the Arctic Slope because they do not have geographic 

locations similar to individual tribes in Alaska. (2) Not all of the villages where the tribes in Alaska 

were historically located are occupied year round. Twenty-four tribes are associated with village 

locations that the state has identified as unpopulated, seasonal-use areas, or of undetermined 

population.

Tribes in Oklahoma and elsewhere that do not have reservations—as well 

as tribes with reservations—face similar challenges in adopting and 

enforcing land use ordinances because they lack jurisdiction over certain 

land. Tribes with reservations do not generally have authority to adopt 

and enforce land use ordinances for land within the reservation’s 

boundaries owned by non-Indians. Likewise, representatives of an 

Oklahoma tribe told us that its lack of participation in NFIP was due in 

part to a reluctance to face possible sanctions because of the tribe’s 

limited ability to enact and enforce ordinances for land owned by nonIndians.35

 

35According to FEMA, a community could face consequences if it had been identified as 

having an SFHA but chose not to participate in NFIP. A community becomes ineligible for 

certain types of assistance 1 year after the effective date of the community’s flood hazard 

map. Participating communities that fail to adopt adequate ordinances or correct 

deficiencies are subject to sanctions. FEMA-imposed sanctions under NFIP may include 

an added premium for each policy sold or renewed in the community or a suspension on 

new policy purchases and existing policy renewals. 

For example, they explained that if a home that had
 

Page 20 GAO-13-226 Tribes and Flood Insurance

experienced repeated flooding was located on land where the tribe had 

limited jurisdiction, the tribe could not take action to mitigate future flood 

damage without the owner’s permission. They said they were aware that 

NFIP does not have a workaround for such circumstances. The tribe had 

chosen to insure all tribal structures and vehicles under a private policy.

In addition, representatives of several tribes explained that tribal 

structures differ from other local government structures but that FEMA did 

not take those differences into account, making participation difficult for 

some tribes. For example, representatives of a participating Washington 

tribe told us that in preparing its multihazard mitigation plan for FEMA 

approval, the tribe realized that the plan template had been created for 

states, as it called for input from counties within the jurisdiction. Instead of 

counties, the tribe had to substitute less specific geographic areas within 

the tribal community. The same tribe was participating in NFIP’s 

Community Rating System program, which allows communities to receive 

discounts on policies for their residents based on floodplain management 

actions the community takes beyond NFIP’s minimum requirements. The 

representatives explained that NFIP also lacked a tribal template for the 

Community Rating System program, which they said would facilitate the 

tribe’s participation.

Without flood hazard maps, tribal communities, including those that may 

be in areas with a higher risk of flooding, may not be sufficiently aware of 

their flood risk. Tribes also may be reluctant to pursue NFIP participation 

if they are uncertain about whether they would qualify and could meet the 

program’s requirements. Further, those with fewer resources and less 

administrative capacity may be less proactive in requesting that FEMA 

map their communities, even though they may be vulnerable to floods.

FEMA’s outreach to tribes in the last few years has largely consisted of 

emergency management and homeland security training for tribal officials 

through its Emergency Management Institute (EMI), direct technical 

assistance to tribes in preparing their multihazard mitigation plans, and 

nationwide outreach for NFIP through its regional offices and the NFIP 

FloodSmart marketing campaign. FEMA officials told us that the agency 

helped to educate tribal officials about NFIP and floodplain management 

through courses offered by EMI under a mitigation curriculum that 

includes courses for floodplain managers on their roles and 

responsibilities, flood insurance, and NFIP rules and regulations. FEMA 

has also developed an emergency management tribal curriculum to 

collaborate with tribal governments in building emergency management 

FEMA Has Provided 

Indian Tribes with 

Training and 

Technical Assistance 

on Hazard Mitigation, 

Including Flood 

Insurance 
 

Page 21 GAO-13-226 Tribes and Flood Insurance

capability and partnerships to ensure continued survival of tribal nations 

and communities.

To some extent, FEMA’s efforts have helped some tribes better 

understand the flood hazards that they face. According to FEMA officials, 

more than 2,000 members from more than 300 Indian tribes have taken 

courses through EMI. The officials added that each regional office had a 

floodplain management specialist as the NFIP point of contact for Indian 

tribes. Officials from two tribes told us that they had participated in EMI 

training. One tribal emergency management official in Wisconsin told us 

that he participated in training with an EMI tribal curriculum group that 

communicated monthly.

FEMA officials also described the direct technical assistance that they 

provided to tribes that were preparing hazard mitigation plans. According 

to FEMA, developing the plans involves identifying the tribe’s critical 

infrastructure, major risks and vulnerabilities, and actions to reduce those 

risks and vulnerabilities for various types of disasters, including floods. 

This assistance provides tribes with an opportunity to learn about the 

risks that their individual communities may face. Representatives from 

several tribes told us that they had completed approved mitigation plans 

or were in the process of completing their plans. Two of the tribes with 

whom we spoke had their plans approved in 2010.

FEMA FloodSmart officials explained that they tried to reach communities 

nationwide with the FloodSmart campaign, but that they targeted those 

communities that were most at risk for flooding. Among these 

communities, they focused on urban areas which had a higher 

concentration of potential flood insurance buyers than rural areas. They 

explained that FloodSmart used a tiered marketing strategy that was 

based on a number of factors that point to a high potential return on 

investment of federal dollars, including: (1) flood insurance policy 

purchase history, (2) potential flood risk as determined by volume of 

SFHA properties, (3) flood event history, (4) volume of structures, and (5) 

media cost. As such, rural areas, including Indian areas, generally 

received lower priority.

FloodSmart officials told us that since February 2007, a total of 671,000 

acquisition-based direct mail pieces had been sent to approximately 

383,000 distinct household addresses within zip codes that intersected 

with Indian reservations. Moreover, according to FloodSmart officials, on 

average, 112,000 direct mail pieces were sent to Indian reservations each 

year, the majority of which were sent to addresses for properties in an 
 

Page 22 GAO-13-226 Tribes and Flood Insurance

SFHA. However, several tribal representatives with whom we spoke still 

told us that they would like more information about NFIP and its 

requirements so that they could decide whether to participate in the 

program and encourage their members to purchase policies through the 

program. In addition, representatives from a few tribes and from an 

insurance company told us that marketing campaigns or other outreach 

efforts may have little effect in Indian communities without the buy-in of 

tribal leaders.

HUD and USDA Rural Development provide assistance in the form of 

housing and infrastructure grants, loans, and loan guarantees to Indian 

tribes. According to officials from both agencies, while neither HUD nor 

USDA is required to provide NFIP outreach, the agencies worked with 

tribes on housing issues that may include determining flood risk to 

housing assistance projects and assessing housing-related issues after 

disasters, such as floods. In addition, the officials said that their field staff 

had FEMA FloodSmart program material on hand for interested parties, 

including Indian tribes.

As part of the IHBG and ICDBG programs, HUD officials in the Office of 

Native American Programs told us that they worked with tribes to identify 

their priorities and to help them determine how to best use HUD funds as 

an investment in addressing their needs. In addition, under both IHBG 

and ICDBG, recipients can use program funds to cover flood insurance 

premiums for properties in some high-risk areas. HUD officials said that 

they conducted outreach to housing authorities in locations where floods 

and other disasters had occurred to assess the status of HUD housing 

stock and to identify displaced families. HUD officials also said that they 

coordinated with FEMA and other agencies locally so that the agencies 

could work together to assess grantees’ damages and needs following a 

disaster, but that they did not know which tribes participated in NFIP. 

HUD regional officials said that they worked closely with individual tribes 

that had been impacted by flooding and other disasters and could offer 

technical and financial assistance to the tribes. Officials from three tribes 

told us that in their experience, HUD officials generally did not approve of 

using HUD assistance to build in an SFHA. An official from one of these 

tribes told us that to address HUD’s requirements for one of its HUDassisted housing developments, the tribe built pads on all of the houses it 

was constructing to elevate them out of the flood zone. In addition, 

officials in HUD’s Office of Environment and Energy told us that they 

provided environmental training and invited grantees, including tribes, to 

attend this training.

HUD and USDA Work with 

Tribes on Housing Issues 

and May Provide Some 

Information on NFIP
 

Page 23 GAO-13-226 Tribes and Flood Insurance

USDA Rural Development has a Native American Coordinator who 

interacts with tribes on programmatic issues, including challenges and 

issues that arise due to flooding. We spoke with the national coordinator, 

who explained that each state office serving a federally or state 

recognized Indian tribe designated an individual to serve as the USDA 

Rural Development state Native American Coordinator. He explained that 

the role had typically been a collateral duty although, in the past, three 

states had employed full-time Native American Coordinators. The 

coordinator’s efforts related to NFIP primarily would be liaising between 

tribal staff and the appropriate Rural Development staff tasked with 

ensuring compliance with program requirements for USDA-funded 

construction or development. Specifically, USDA officials told us that they 

ensured compliance with NFIP requirements only for USDA-funded 

projects where construction or development occurred in an SFHA in an 

NFIP participating community. They explained that USDA’s evaluation of 

NFIP applicability was part of National Environmental Policy Act 

reviews.36 In these cases, USDA officials said they ensured that 

mitigation actions were taken and when this was impractical, the applicant 

for USDA funding purchased flood insurance. The officials told us they did 

not provide any assistance for developing floodplain management 

approaches, but required that borrowers comply with applicable state or 

local floodplain ordinances or permits. Both HUD and USDA officials told 

us that when an area had not been mapped, they might rely on tribal 

elders or another knowledgeable source in determining the location of 

flood-prone areas.

Representatives from HUD and USDA, tribal representatives, and private 

insurers all agreed that more could be done to encourage tribes to 

participate in flood insurance programs. However, FEMA noted that it was 

limited in its efforts by the unique legal issues surrounding Indian tribes 

and their lands. FEMA also told us its focus was on mapping more highly 

populated areas, which typically did not include Indian tribal communities. 

HUD and USDA acknowledged that more information and support could 

 

36National Environmental Policy Act of 1969, Pub. L. No. 91-190, 83 Stat. 852 (1970), 

codified as amended at 42 U.S.C. §§ 4321-4347 (2012). Under the National 

Environmental Policy Act, agencies evaluate the likely environmental effects of projects 

they are proposing using an environmental assessment or, if the projects likely would 

significantly affect the environment, a more detailed environmental impact statement. 

Some actions are not subject to review, including those excluded by section 316 of the 

Stafford Act and certain emergency actions.

Boosting Tribes’ 

Participation in Flood 

Insurance Programs
 

Page 24 GAO-13-226 Tribes and Flood Insurance

encourage tribes to participate in NFIP. For instance, HUD officials in the 

Northern Plains region, where more than 30 federally recognized tribes 

are located, told us that there was likely a need for more education 

among tribes.37

Tribal representatives had a number of suggestions that could lead to 

increased tribal participation, ranging from expanding FEMA outreach and 

education to requiring tribes to have flood insurance. They suggested, 

among other things,

The officials said that they were aware that FEMA had to 

prioritize limited federal dollars for flood mapping activities and that tribal 

lands might not be a top priority. However, they noted that tribes also 

might not be proactive in requesting flood maps for their communities 

because they had received conflicting information about FEMA’s authority 

to map tribal lands. The officials said they had invited FEMA to a regional 

meeting in the last year to share information on disaster topics, including 

floods and flood insurance, with tribal housing officials from the region. As 

previously noted, officials from HUD’s Office of Environment and Energy 

also told us that they were increasing opportunities for HUD grantees, 

including tribes, to obtain information and training on environmental topics 

such as flood risks.

• more emphasis on educating tribes on the importance of flood 

insurance, as at least one tribe had been experiencing more rain each 

year;

• more outreach to tribes, including those without flood hazard maps, to 

help them understand their vulnerability to floods and the advantages 

of NFIP participation;

• meetings that brought together FEMA officials and elected tribal 

councils that could make decisions on behalf of their tribes;

• federal grants to help tribes develop elevation certificates and to 

retrofit older properties to lower risk and make the policies more 

affordable for members;

 

37HUD’s six regional Office of Native American Programs offices are located in Anchorage 

(Alaska), Chicago (Eastern Woodlands), Denver (Northern Plains), Seattle (Northwest), 

Oklahoma City (Southern Plains), and Phoenix (Southwest). 
 

Page 25 GAO-13-226 Tribes and Flood Insurance

• a simulation exercise that included the host tribe, FEMA officials, and 

other government officials with whom tribes would need to coordinate 

in a flood-related disaster; and

• an amendment to the NFIP statute to address issues specific to tribes’ 

limited ability to adopt and enforce land use ordinances.

At least one tribal representative said that it would be reasonable for 

Congress to require a flood mitigation plan across communities and tribal 

lands, regardless of risk level, and that tribes with critical infrastructure in 

a flood-prone area should be required to participate in NFIP or sign a 

waiver of future flood assistance. However, another representative 

suggested that FEMA should address the land use ordinance issue and 

determine, with the tribes’ input, whether NFIP had been financially 

beneficial to tribal members who were able to purchase flood insurance in 

the nontribal community where they lived.

Insurance company officials we spoke with, including a Write-Your-Own 

company and a broker, emphasized the importance of respecting the 

cultural issues of dealing with tribes in any targeted outreach activities. As 

we have seen, for example, the FloodSmart campaign sent thousands of 

pamphlets to individual residents on Indian lands. One insurance broker 

that targets Indian tribes told us that the company had received three 

requests for policies after the mailing. She told us that the company had 

learned that tribal members tend to rely on the views of their tribal leaders 

for guidance and that without the buy-in of these leaders, marketing 

FloodSmart materials to individual members would likely not be a 

successful strategy.

Insurance and reinsurance company officials we spoke with were aware 

of the Biggert-Waters Flood Insurance Reform Act of 2012 requiring 

FEMA and GAO to assess options and strategies for privatizing NFIP in 

the future and authorizing FEMA to pursue private management 

initiatives.38

 

38Pub. L. No. 112-141, § 100232. 

A reinsurance official said that his company had begun to 

examine whether it would be in its interest to become more involved now, 

given that future legislation would likely increase the private sector’s role 

in flood insurance. This official added that his company recognized that 

NFIP was not actuarially sound and that expected additions to the nearly 
 

Page 26 GAO-13-226 Tribes and Flood Insurance

$18 billion deficit from Superstorm Sandy could accelerate congressional 

interest in greater private sector involvement in providing flood insurance. 

Other private sector insurance options may offer tribes an alternative to 

NFIP. A private insurer proposed two related options that could allow 

tribes to purchase flood insurance at a potentially lower cost than under 

NFIP. The first would involve expanding the existing eligible flood 

insurance risk-sharing pools to obtain the critical mass of policies 

necessary to make low-cost flood insurance policies affordable to Indian 

households. The second would establish a new private “microinsurance” 

program offering low-premium policies with small coverage limits tailored 

specifically to Indian tribes, based on similar operations in developing 

countries. 

• Nonprofit Insurance Risk Pool: Two of the tribes we contacted had 

purchased flood insurance through an insurance risk pool offered by 

AMERIND Risk Management Corporation. AMERIND was organized 

in 1986 as a collaborative program between HUD and some Indian 

housing authorities to provide insurance protection for Native 

American low-income housing. It currently operates as a multitribal 

nonprofit corporation working with over 400 tribes and administers 

risk-sharing pools. Since 2002, AMERIND has offered a flood 

insurance endorsement to its standard policy, limited to HUD-assisted 

Indian housing.39 Company officials explained that through a

members-only risk pool, the flood endorsement provides flood 

coverage to about 56,000 structures on tribal lands and charges a 

universal rate of $10 per structure per year (see table 3).40 AMERIND 

has a coverage limit of $15,000 for each covered structure.

 

39The International Risk Management Institute, Inc. defines an endorsement as an 

insurance policy form that changes or adds to the provisions included in one or more of 

the forms that construct a policy, and notes that endorsements may serve to broaden the 

scope of coverage. 

40See GAO, Natural Hazard Mitigation and Insurance: The United States and Selected 

Countries Have Similar Natural Hazard Mitigation Policies but Different Insurance 

Approaches, GAO-09-188R (Washington D.C.: Dec. 22, 2008) for information on the 

private natural perils risk pool in Switzerland that includes flood coverage. 
 

Page 27 GAO-13-226 Tribes and Flood Insurance

Table 3: Tribal Flood Insurance Policies in Place with AMERIND (November 2012)

Measure Number

Number of Indian tribal entities participating 400+

Number of flood insurance policies 206

Number of structures insured

Residential (95 percent)

Commercial (5 percent)

45,000

Source: AMERIND Risk Management Corporation.

An Arizona tribe we contacted uses AMERIND insurance on its HUDassisted tribal housing, and the policies included the flood protection 

endorsement. According to the tribal representative, the tribe has 

used this insurance option for about 8 years. One Oklahoma tribe we 

contacted had not purchased AMERIND’s flood insurance 

endorsement but had purchased property insurance from the 

company. This representative said that because of its affordability 

compared with NFIP and because the company is a multitribal 

corporation, he would refer individual members to AMERIND if they 

lived in HUD IHBG-assisted housing within a floodplain and needed to 

purchase flood insurance. USDA Rural Development also has 

approved AMERIND as an eligible nonflood insurer for its singlefamily housing programs, so Indian tribes and their members can use 

an appropriate AMERIND product to insure projects financed through 

these programs. According to USDA, the intent is to facilitate use of 

its programs by Indian tribes and their members for projects on trust 

land when conventional insurance coverage is unavailable, difficult to 

access, or expensive.

However, the current nonprofit insurance risk-pooling option has 

limitations. First, while the premium rate may be lower than NFIP’s, 

the coverage limits for flood insurance are also generally lower. 

Representatives for AMERIND told us that coverage limits were low 

because the company had not been successful in obtaining 

reinsurance on the private market that would allow the company to 

mitigate its risk and offer full replacement costs for each structure. 

AMERIND does offer to provide double coverage ($30,000 per 

structure) for flood losses, but the premiums are more than 10 times 

the universal rate, ranging from about $150 to $200 per structure. 

These premiums are generally below NFIP rates for properties with 

similar coverage inside SFHAs and are generally comparable to NFIP 

rates for similar coverage outside SFHAs. Second, because 

AMERIND’s flood insurance coverage is available for HUD IHBG-
 

Page 28 GAO-13-226 Tribes and Flood Insurance

assisted structures only, tribes cannot use it for all structures on tribal 

lands. The tribes we interviewed that used AMERIND for flood 

insurance were able to obtain coverage only for HUD IHBG-assisted 

structures.41 Because of this limitation, AMERIND does not have the 

critical mass of policies necessary to offer private low-cost flood 

insurance to all Indian households. Third, communities may still face 

consequences if they are identified as having SFHAs and choose to 

obtain non-NFIP flood insurance. According to FEMA, NFIP aims to 

do more than simply encourage property owners to purchase flood 

insurance. It also encourages them to take measures to mitigate 

potential flood damage to their properties, and NFIP coverage is 

available only when certain flood protection standards have been 

implemented.

• Private Microinsurance: Another potential private sector option 

would be a private microinsurance program. Microinsurance is a 

relatively new product that allows insurers to offer low-premium 

policies with small coverage limits in developing areas. The concept

operates much like AMERIND’s risk pool and is structured to provide 

low-income policyholders with a degree of “livelihood protection” or 

emergency expense support rather than full indemnity for loss. We 

spoke with officials from a reinsurance company that was recently 

awarded a grant from a member of the World Bank group to develop a 

market for microinsurance in an agriculture-based developing country. 

These officials and officials from the reinsurance company’s insurance 

subsidiary said that, given the recent congressional interest in looking 

into private options for flood insurance, they would be interested in 

working with AMERIND or helping to develop another Native 

American flood insurance program that would cover all tribal member 

homeowners and businesses. They said that a mandatory coverage 

provision would solve the coverage problem and reduce uncertainty, 

making the provision of microinsurance more attractive to and 

sustainable for insurers and reinsurers. But they added that even with 

mandatory group coverage, they saw benefits to mapping all lands, 

because a private microinsurance risk pool would need to charge 

more for properties that were located on unmapped tribal lands than 

for similar properties located on mapped tribal lands.

 

41However, they were able to obtain traditional nonflood property coverage from 

AMERIND on structures receiving Rural Development assistance. 
 

Page 29 GAO-13-226 Tribes and Flood Insurance

During the course of our work for this report, FEMA developed a draft 

statement of work for its upcoming private market assessment of NFIP. 

The draft statement, dated December 17, 2012, included a requirement 

for the contractor to assess a broad array of instruments, including 

reinsurance, microinsurance, and flood insurance pools. FEMA officials 

confirmed that the inclusion of microinsurance and insurance pools in the 

study was finalized after we raised and discussed those alternatives with 

them and that they considered both alternatives to be worth studying. 

FEMA officials told us that they planned to issue the statement of work 

early in January 2013.

Congress created NFIP with the intent of providing affordable flood 

insurance to communities and households in order to financially protect 

property owners and reduce the cost of federal postdisaster assistance, 

but participation by Indian tribes has been low. Even on Indian lands that 

have experienced flooding, tribes and tribal members often do not 

participate, and the total number of policies written to tribes and tribal 

members accounts for less than 1 hundredth of a percent of FEMA’s 

portfolio. FEMA has provided tribes with training and technical assistance 

and has to some extent helped tribes to understand the flooding risks 

they face. However, several factors have contributed to the low 

participation rate, including limited mapping on Indian lands; affordability; 

lack of information on NFIP; and tribal land use issues, including 

confusion about legal restrictions on activities on Indian lands. Limited 

mapping, in particular, has contributed to a lack of awareness both of the 

risk of flooding and of the benefits of NFIP. FEMA has generally focused 

its mapping efforts on densely populated and coastal areas in order to 

make the best use of its resources. However, increased mapping of less 

densely populated rural areas, including Indian lands, is in line with 

Congress’s focus on increasing tribes’ participation in NFIP and is key to 

raising awareness of the types of flood risks residents of these areas 

face. Expanding its flood mapping efforts will challenge FEMA to balance 

its need to make the best use of scarce resources with the needs of these 

previously underserved communities.

To help increase Indian tribes’ participation in NFIP, we recommend that 

the Administrator of FEMA examine the feasibility of making mapping of 

tribal lands a higher priority.

Conclusions 

Recommendation 
 

Page 30 GAO-13-226 Tribes and Flood Insurance

We provided a draft of this report for review and comment to USDA Rural 

Development, FEMA within the Department of Homeland Security, HUD, 

and BIA within the Department of the Interior. A letter from the Director of 

the Departmental GAO-OIG Liaison Office within the Department of 

Homeland Security stated that FEMA will take steps to make mapping of 

tribal lands a higher priority. The director also stated that doing so will be 

challenging due to FEMA’s scarce resources and noted the agency’s 

appreciation for GAO’s acknowledgment of its resource limitations. In 

addition, the director said that FEMA will consider the suggestions made 

by tribal representatives for increasing tribal participation in flood 

insurance programs. The letter is reprinted in appendix II. We also 

received technical comments from USDA Rural Development, FEMA, and 

HUD, which we incorporated in the report as appropriate. BIA did not 

provide any comments.

We are sending copies of this report to appropriate congressional 

committees, and the Secretaries of Agriculture, Homeland Security, 

Housing and Urban Development, and Interior. This report will also be 

available at no charge on GAO’s website at http://www.gao.gov.

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

me at (202) 512-8678 or cackleya@gao.gov. Contact points for our 

Offices of Congressional Affairs and Public Affairs may be found on the 

last page of this report. GAO staff who made major contributions to this 

report are listed in appendix III.

Alicia Puente Cackley 

Director, Financial Markets and 

 Community Investment 

Agency Comments
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-13-226 Tribes and Flood Insurance

Our objectives were to examine (1) factors contributing to the current low 

levels of National Flood Insurance Program (NFIP) participation by Indian 

tribes, (2) the Federal Emergency Management Agency’s (FEMA) efforts 

to increase tribes’ participation in NFIP, and (3) administrative and 

legislative actions that could encourage Indian tribes and their members 

to increase their participation in NFIP and potentially other flood 

insurance programs. For the purposes of this review, we limited our study 

primarily to flood insurance policies held on Indian tribal lands (such as 

reservations), because FEMA does not collect demographic data such as 

race or ethnic origin of NFIP policyholders. Therefore, no comprehensive 

data are available on members of Indian tribes who are living in nontribal 

communities and may carry individual NFIP policies. We also interviewed 

representatives from Alaska, because many Alaska Native communities 

are vulnerable to floods, but do not have designated reservations that 

could participate in NFIP. With only one reservation in the state, tribes in 

Alaska can participate in NFIP only through the municipalities in which 

their communities are located.

To address all three objectives, we reviewed NFIP laws and policy 

documents. We reviewed FEMA data on communities participating in 

NFIP, including those designated as tribal communities, and on tribes that 

had flood hazard maps but were not participating in NFIP for various 

reasons. FEMA provided us with information on its process for collecting 

and analyzing the data in its Community Information System database 

and on the agency’s data reliability measures. We determined that the 

data FEMA provided to us were sufficiently reliable for our reporting 

purposes. In addition, we reviewed prior GAO work on flood insurance, 

Indian tribes, and disaster preparedness, and reports by the 

Congressional Research Service, to compile background information on 

NFIP. We interviewed and gathered documentation from officials at 

FEMA and other federal agencies with programs that assist Indian tribes,

such as the Bureau of Indian Affairs (BIA) within the Department of the 

Interior, Department of Housing and Urban Development (HUD), and the 

U.S. Department of Agriculture (USDA) Rural Development. In addition, 

we reviewed regulations for those agencies’ programs. We spoke with 

representatives from the State of Alaska; the National Flood 

Determination Association, which provides flood mapping data to 

mortgage lenders and insurers; the insurance and reinsurance industries; 

a nonprofit risk-pooling organization; FloodSmart, which administered 

FEMA’s NFIP media campaign; and selected Indian tribes.

We selected the tribes from among those on FEMA’s lists of tribes that 

were participating in NFIP and those that had flood hazard maps but were 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-13-226 Tribes and Flood Insurance

not participating in NFIP. We selected a purposive non-representative 

sample of eight participating tribes for interviews based on the number of 

individual policies within each tribe, geographic diversity, and tribe size. 

We also selected a purposive non-representative sample of six 

nonparticipating tribes for interviews based on the reason for 

nonparticipation, geographic diversity, and tribe size. In addition, our prior 

work on the Native American Housing Assistance and Self-Determination 

Act of 1996 (NAHASDA) program partially informed the tribes we 

selected. Specifically, because we had already established 

communication with certain tribes, we selected them over comparable 

tribes on either list. Because of our time constraints and several selected 

tribes being impacted by a natural disaster (Superstorm Sandy), we were 

able to interview five participating and five nonparticipating tribes. We 

also judgmentally selected a tribe in Alaska that we had contacted 

previously to obtain a perspective on NFIP from a tribe in that state. To 

obtain perspectives from the insurance industry, we interviewed 

representatives from an insurance company that we contacted while 

conducting prior work related to the Write-Your-Own insurance program, 

a vendor that administers NFIP flood policies for Write-Your-Own

insurance companies, and an insurance broker that specializes in working 

with Indian tribes.

To determine factors contributing to the current low levels of NFIP 

participation by Indian tribes, we reviewed FEMA’s data on tribal 

community participation. We also asked FEMA officials about the 

agency’s process for mapping Indian lands (or providing flood hazard 

maps to Indian communities), and options for tribes to participate in NFIP. 

In our interviews with other federal officials, tribal representatives, and 

others, we asked about factors that may positively or negatively affect 

whether tribes participate in NFIP.

To determine the efforts FEMA was making to increase awareness of and 

encourage participation in NFIP by Indian tribes, we asked officials at 

FEMA about outreach and technical assistance they provided to Indian 

tribes related to floods and flood insurance. In addition, we asked 

FloodSmart representatives about any efforts to market NFIP to Indian 

tribes and their members. We also asked officials at BIA, HUD, and 

USDA about information they may share with tribes on flood insurance in 

providing program support. Further, we asked tribal representatives about 

their interactions with FEMA and other agencies and information or 

assistance they had received related to NFIP.
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-13-226 Tribes and Flood Insurance

To determine what administrative or legislative actions could encourage 

Indian tribes and their members to increase their participation in NFIP and 

potentially other flood insurance programs, we reviewed NFIP regulations 

and legislation and guidance on FEMA coordination with and outreach to 

Indian tribes. We interviewed representatives from the insurance and 

reinsurance industries about other flood insurance options, in addition to 

NFIP, that may facilitate tribes’ purchase of flood insurance. We also 

asked federal officials and tribal representatives about actions that FEMA 

or Congress could take to encourage tribes participating in NFIP to 

increase their use of the program and tribes not participating to join NFIP.

Participating: Based on number of individual NFIP policies held by the 

tribe, size of tribe, and geographic diversity, a total of eight tribes were 

selected for inclusion as well as six backup tribes. Tribes and backup 

tribes were selected within each region, except in the Northeast region 

where there was only one tribe included in our sample frame. One group 

of selected tribes had the largest number of policies and the backups had 

the second largest number of policies. The other group of tribes had the 

lowest number of policies. Among the cohort of lowest policies, within 

each region, tribes selected were those with the largest enrollment and 

the backups were those with the second largest enrollment.

Nonparticipating: Based on reason for nonparticipation (such as 

withdrawn or suspended from the program), size of tribe, and geographic 

diversity, a total of six tribes were selected for inclusion as well as three 

back-up tribes. Tribes and backup tribes were selected within each 

region, except in the Northeast region where there was only one tribe 

included in our sample frame. Additionally, the one withdrawn tribe and 

the one suspended tribe are also included in our selected tribes. In the 

other three regions, one group of selected tribes had the largest number 

tribal enrollment and the backups had the second largest tribal 

enrollment.

We conducted this performance audit from August 2012 to January 2013 

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.

Tribe Selection Process
Appendix II: Comments from the Federal 

Emergency Management Agency

Page 34 GAO-13-226 Tribes and Flood Insurance

Appendix II: Comments from the Federal 

Emergency Management Agency
Appendix II: Comments from the Federal 

Emergency Management Agency

Page 35 GAO-13-226 Tribes and Flood Insurance
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 36 GAO-13-226 Tribes and Flood Insurance

Alicia Puente Cackley, (202) 512-8678, cackleya@gao.gov

In addition to the contact named above, Andy Finkel (Assistant Director), 

Bernice Benta-Jackson, Emily Chalmers, Brian Friedman, Jeffery 

Malcolm, Marc Molino, Patricia Moye, Roberto Pinero, and Andrew 

Stavisky made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(250687)
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 (http://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 http://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: http://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.