The Impacts of Extreme Weather Events on 

People with Disabilities

National Council on Disability

May 4, 2023
National Council on Disability (NCD)

1331 F Street NW, Suite 850

Washington, DC 20004

The Impacts of Extreme Weather Events on People with Disabilities

National Council on Disability, May 4, 2023

Celebrating 39 years as an independent federal agency

This report is also available in alternative formats. Please visit the National Council on Disability 

(NCD) website (www.ncd.gov) or contact NCD to request an alternative format using the following 

information:

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The views contained in this report do not necessarily represent those of the Administration, as this and 

all NCD documents are not subject to the A-19 Executive Branch review process.
National Council on Disability

An independent federal agency making recommendations to the President and Congress 

to enhance the quality of life for all Americans with disabilities and their families.

Letter of Transmittal

May 4, 2023

President Joseph R. Biden, Jr.

The White House

1600 Pennsylvania Avenue, NW

Washington, DC 20500

Dear Mr. President,

The Federal Government has a vitally important duty to protect its most vulnerable citizens in time of 

natural disasters. For people with disabilities the consequences of extreme weather events are often 

exacerbated by the exclusion of their needs in planning for such events and in the federal relief and 

recovery response thereafter. On behalf of the National Council on Disability (NCD), I hereby transmit 

NCD’s report titled The Impacts of Extreme Weather Events on People with Disabilities. The report is 

also available on NCD’s website at www.ncd.gov.

This report examines how extreme weather events in the United States and its territories adversely 

and disproportionately impact people with disabilities. This report examines the enforcement of 

applicable disability rights laws; access to healthcare, housing, employment, and education; and the 

adequacy of emergency management plans, policies, services and resources before, during, and after 

an emergency or major disaster declaration;1

 and the congressional, federal, and state, local tribal and 

territorial (SLTT) response. 

Last year, Category 1 Hurricane Fiona pummeled Puerto Rico, dumping historic levels of rain, and 

unleashing massive flooding, landslides and mudslides. That was followed by Category 4 Hurricane 

Ian that ravaged Florida and South Carolina, causing well over 100 deaths and catastrophic damage to 

homes, schools, businesses, hospitals and other properties. In Puerto Rico, the damage was islandwide, affecting all of its 687,000 residents with disabilities. In Florida, nearly 3 million people with 

disabilities who lived in counties decimated by Hurricane Ian’s fury were impacted and the true extent 

of that impact is not yet clear. 

In fulfillment of our advisory duties, NCD has been advising federal agencies over the years on the 

need to improve the outcome of people with disabilities before, during and after disasters.2

 Yet, today, 

people with disabilities are still 2 to 4 times more likely to be injured or killed in a natural disaster 

than those who are not disabled.3 People with disabilities are far more likely than anyone else to face 

major hardships including displacement from their homes due to a major disaster. Seventy percent of 

people who are deaf and evacuated reported living in unsanitary conditions a month after the disaster 

compared to only 7% of evacuees who are not deaf.4

1331 F Street, NW ■ Suite 850 ■ Washington, DC 20004

202-272-2004 Voice ■ 202-272-2074 TTY ■ 202-272-2022 Fax ■ www.ncd.gov
With the rapidly growing disabled population in the U.S.,5

 the increased prevalence of extreme weather 

events, as evidenced by the more than 300 presidentially declared major disasters across all 50 states 

and U.S. territories since 2017,6 and with the increased intensity of those weather events, the safety 

and well-being of people with disabilities are gravely at risk.

This report provides findings and recommendations to mitigate the impacts of extreme weather events 

on people with disabilities before, during, and after a catastrophic natural disaster and to enhance 

preparation and mitigation and inform policy – all aimed to build a more resilient community. 

Mr. President, adopting the recommendations of this report will mitigate the costs expended by the 

Federal Government in disaster recovery, diminish the misery caused by these disasters but more 

importantly, save lives. We stand ready to coordinate with you, Congress and federal agencies to create 

a fully inclusive national preparedness, recovery and response effort for the millions of people with 

disabilities in our country and in our territories.

Respectfully submitted,

Andrés J. Gallegos, J.D.

Chairman

(The same letter of transmittal was sent to the President Pro Tempore of the U.S. Senate and the Speaker of the 

U.S. House of Representatives.)

2 National Council on Disability
National Council on Disability Members and Staff

Members

Andrés J. Gallegos, Chairman

Claudia Gordon, Vice Chair

Hoskie Benally, Jr.

Sascha Bittner

Theo Braddy

Shawn Kennemer

Risa Rifkin

Neil Romano

Emily Voorde

Staff

Anne C. Sommers McIntosh, Executive Director 

Joan M. Durocher, General Counsel & Director of Policy

Lisa Grubb, Director of Administration, Finance, and Operations

Stacey S. Brown, Staff Assistant

Kimie Eacobacci, Legislative Affairs Specialist

Netterie Lewis, Administrative Support Specialist

Amy Nicholas, Senior Attorney Advisor

Nick Sabula, Public Affairs Specialist

Amged Soliman, Senior Attorney Advisor

Ana Torres-Davis, Senior Attorney Advisor

Keith Woods, Financial Management Analyst

The Impacts of Extreme Weather Events on People with Disabilities 3
4 National Council on Disability
Contents

Letter of Transmittal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  

National Council on Disability Members and Staff . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  

Acknowledgments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  

Key Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  

Key Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Acronym Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  1

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  2

Chapter 1: Laws and Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  3

Chapter 2: Healthcare . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  4

Chapter 3: Housing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  6

Chapter 4: Employment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  8

Chapter 5: Education . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  8

Chapter 6: Emergency Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  9

Appendices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 115

Appendix A: Convening Participants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 115

Appendix B: Report Recommendations by Administration, 

Congress and Agency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 117

Appendix C: Figures, Tables, Map Descriptions . . . . . . . . . . . . . . . . . . . .  12

Appendix D: Definitions and Terminology . . . . . . . . . . . . . . . . . . . . . . . . .  13

Appendix E: Policies, Laws, and Regulations . . . . . . . . . . . . . . . . . . . . . .  13

Endnotes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 143

The Impacts of Extreme Weather Events on People with Disabilities 5
6 National Council on Disability
Acknowledgments

The National Council on Disability (NCD) thanks Leola A. Abraham, Dr. Mark Roberts, Rebecca 

Composto, Elliot Harkavy, Kim Fletcher, and the CNA, Institute for Public Research, Center for 

Vulnerable Population Protection team; Jessica Brody; and Justine “Justice” Shorter and Claire Stanley 

with the National Disability Rights Network (NDRN) for their work in developing this report.

NCD further recognizes and expresses its sincere appreciation to former NCD Council Members 

Daniel Schreck and Dr. Munr Kazmir, whose participation on the report’s subcommittee was 

instrumental in its development and completion.

The Impacts of Extreme Weather Events on People with Disabilities 7
8 National Council on Disability
Executive Summary

In this report, the National Council on Disability 

(NCD) examined how extreme weather events 

and environmental hazards have adversely 

and disproportionately impacted people with 

disabilities in the United States and its territories 

over the past 20 years. The report focuses 

on compliance with applicable federal laws; 

examines applicable federal programs and 

policies and their implementation in health 

care, housing, education, and emergency 

management; and offers findings and 

recommendations to bring about policy and 

system change.

This report defines extreme weather by 

the type of hazard (e.g., drought, flooding, severe 

storm, wildfire, winter weather, tropical cyclone 

[hurricane]) and level of risk by U.S. county and 

U.S. territory. It posits that extreme weather 

events are increasing in frequency and severity 

globally and that this increase has resulted in 

significant economic and social costs, with 

profound effects on people with disabilities.

NCD examined whether SLTT governments 

complied with existing federal statutes and 

regulations when implementing emergency 

management policies for people with disabilities 

and whether federal agencies monitored SLTT 

governments’ plans for compliance and used 

their enforcement capabilities when entities 

were noncompliant. NCD examined what limited 

data were available to illustrate the outcomes of 

people with disabilities before, during, and after 

disasters. The report findings show an urgent 

need to collect aggregated data, to focus on 

equity and inclusion, to improve training, and to 

enforce legislation.

Key Findings

Laws and Regulations

■ Some local governments have not complied 

with federal rules and regulations, even 

though those rules and regulations clearly 

state that programs and services funded 

with federal dollars must be compliant with 

federal disability rights laws. SLTTs and their 

contractors are legally required to comply with 

Title II of the ADA provision of “emergencyand disaster-related programs, services, and 

activities they provide”7 and with section 504 

of the Rehabilitation Act, to ensure federally 

funded programs allow for equal access.

Health Care

■ Extreme weather events are increasing in 

frequency, severity, and cost. The increase 

in extreme weather events is resulting in 

significant social and economic costs to 

people with disabilities, their families, and 

their communities.

The Impacts of Extreme Weather Events on People with Disabilities 9
■ The growing population of people with 

disabilities will strengthen the need 

for accessible health care services and 

providers. It will increase demand on 

resources and strain critical systems, 

including the health care system, and 

emergency management agencies.

■ While the number of people with 

disabilities is increasing, the U.S. health 

care system is facing staffing shortages,8

which will exacerbate poor outcomes for 

people with disabilities during disasters, 

when demand for acute emergency care is 

heightened.

■ People with disabilities who are forced to 

relocate out of state due to a disaster lose 

access to their Medicaid-supported services 

because Medicaid is not transferable across 

state lines.

Housing

■ The current housing shortage, low vacancy 

rates, high prices, limited availability of 

accessible units, the increase of extreme 

weather events that damage and destroy 

existing housing stock, the nexus between 

people with disabilities and poverty and 

areas of low-income being disparately 

impacted by extreme weather events are 

all factors that exacerbate the ability of 

people with disabilities to secure affordable 

accessible housing.

■ HUD’s 5 percent accessibility requirement 

for federally assisted new construction 

housing developments9 does not meet 

the needs of people with disabilities, who 

represent 25 percent of the population.

Employment

■ Employees with disabilities are displaced 

at a disproportionate rate to people without 

disabilities independent of extreme weather 

events. The employment rate of people with 

disabilities is 19.1 percent compared to 63 

percent of people without disabilities.10 People 

with disabilities are 89 percent more likely to 

experience an involuntary job loss than people 

without disabilities.11 After an extreme weather 

event, unemployment rates for employees 

with disabilities are impacted at a higher 

percentage than people without disabilities. 

NCD has heard from disability stakeholders 

about employment loss after extreme weather 

events, and yet there is limited public research 

and data about how disasters impact job rates 

for people with disabilities.

Education

■ Students with disabilities are left behind 

when school districts fail to integrate 

students with disabilities into their 

emergency management plans and policies. 

Lack of planning results in longer delays for 

students with disabilities to return to receive 

necessary educational supports and services.

■ Students with disabilities living in rural, 

tribal, and low-income areas are especially 

susceptible to educational disruption because 

of the present shortage of special education 

professionals, which is exacerbated when an 

extreme weather event occurs.

■ States and territories found difficulty 

acquiring specialized services and 

personnel needed to comply with the IDEA 

requirements.

10 National Council on Disability
Emergency Management

■ People with disabilities face a unique 

set of barriers during disasters, yet 

emergency management agencies 

consistently fail to account for those 

barriers and fail to coordinate with the 

disability organizations and communitybased organizations (CBOs) that 

represent them.

■ There are over 700 tribal nations in the 

United States. According to the Bureau 

of Indian Affairs (BIA), the majority of 

tribal nations do not have an emergency 

management plan, and tribal nations that 

do have a plan tend to not incorporate the 

needs of people with disabilities.

■ Limited auxiliary aids and services to 

achieve effective communications during 

extreme weather events means people 

with disabilities do not have equal access 

to information, which increases the risk 

to their safety and infringes on their civil 

rights.

■ During emergencies and disasters, 

SLTT governments rely on traditional 

emergency alert systems (EASs) that do 

not work for individuals who are Deaf and 

Hard of Hearing, placing those individuals 

at risk of being uninformed during an 

emergency.

■ Jurisdictions face transportation resource 

gaps for emergency evacuations. The 

need for accessible transportation during 

disaster response and evacuation often 

surpasses the resources of the local 

community.

Key Recommendations

Laws and Regulations

■ NCD recommends Congress should 

appropriate funds and require the 

Department of Justice (DOJ), in 

collaboration with other federal 

agencies (OFAs) to increase monitoring 

and enforcement of federal disability 

laws, which requires that emergency 

communications be fully accessible to 

people with disabilities.

■ NCD recommends DOJ should review 

websites such as the National Hurricane 

Center (NHC) to ensure that it is 508 

compliant and that all federal webpages 

are accessible to people who use screen 

readers or other assistive technology 

devices.

Health Care

■ NCD recommends Congress should pass 

the Real Emergency Access for Aging 

and Disability Inclusion for Disasters Act 

(REAADI) to address gaps in meeting civil 

rights obligations to people with disabilities 

impacted by disasters.12

■ NCD recommends Congress should 

appropriate funds to FEMA for the express 

purpose to advise SLTTs emergency 

management agencies (EMAs) and state 

health departments to conduct reviews 

and update emergency management plans 

and guidance to prepare for an increase of 

people with disabilities. The plans should 

be data-driven, inclusive, and compliant 

with disability laws to ensure equal 

The Impacts of Extreme Weather Events on People with Disabilities 11
access including effective communication, 

evacuations, and shelters that provide 

accommodations and modifications to 

ensure the safety of people with disabilities.

■ NCD recommends Congress should require 

state collection of health care demographic 

data relating to functional disability and 

home- and community-based services 

(HCBS) use for all Medicaid enrollees, 

including better data collection across the 

full range of long-term care, group homes, 

and congregate settings, licensed, certified, 

or approved by the state.

■ NCD recommends Congress should 

pass legislation to address the shortage 

of primary care doctors and other health 

care providers. The legislation should 

address shortfalls in the nation’s supply 

of health care providers and include 

inclusive recruitment for a diverse health 

care workforce, loan forgiveness that 

encourages health care providers to work 

with underserved populations, and other 

innovative targeted incentive measures.

■ NCD recommends Congress should 

provide funding to the U.S. Department 

of Health and Human Services (HHS) 

so it can implement section 5307 of the 

Patient Protection and Affordable Care Act. 

Funding section 5307 would allow for the 

development, evaluation, and dissemination 

of research, demonstration projects, and 

model curricula for cultural competency, 

prevention, public health proficiency, 

reduction of health disparities, and aptitude 

for working with individuals with disabilities 

for use in training in health professions 

schools and continuing education 

programs.13

■ NCD recommends Congress should 

make research and development (R&D) 

investments that promote assistive 

technology. This should involve the 

following: (1) making greater investment 

in R&D of accessible apps and devices 

to incentivize developers to create 

innovative technology, which can help 

people with disabilities enhance functional 

performance to improve outcomes in 

areas such as education, employment, 

and independent living; (2) increasing the 

R&D budget for the National Institute 

on Disability, Independent Living, and 

Rehabilitation Research (NIDILRR), the 

Medical Research and Development 

Program; and (3) providing funding to a 

federal unit such as the Administration 

for Community Living to design and fund 

technical assistance on R&D for the 

technology industry to support accessible 

design of emerging technology.

■ NCD recommends Congress should pass 

the Disaster Relief Medicaid Act (DRMA). 

upon passage, states should immediately 

implement DRMA to ensure that individuals 

who are eligible for Medicaid and are forced 

to relocate due to a disaster are able to 

continue to access their Medicaid-supported 

services.

Housing

■ NCD recommends Congress should pass 

legislation to spur affordable housing 

production and measures to preserve 

12 National Council on Disability
existing homes so that people with 

disabilities can return to their homes post 

an extreme weather event as outlined in the 

White House Actions to Ease the Burden of 

Housing Costs. Doing so would expand and 

improve existing forms of federal financing 

for affordable multifamily development 

and allocate a percentage of the housing 

development units to be accessible to 

people with disabilities.

■ NCD recommends HUD should increase 

the number of accessible units from 

the 5 percent accessibility requirement 

for federally assisted new construction 

housing developments to 25 percent, 

which represents the percentage of 

people with disabilities in the United 

States.

■ NCD recommends Congress should 

permanently authorize HUD Community 

Development Block Grant (CDBG) funding 

or in the alternative, streamline the 

authorization process after a disaster so that 

subsidies reach recovering communities 

earlier, and so rebuilding can begin 

immediately following a disaster.

■ NCD recommends HUD should initiate 

a policy that will not approve funding of 

federal financed housing in floodplains.

■ NCD recommends HUD should require 

developers use materials that are more 

resilient to extreme weather events 

indicative of the area, for instance, metal 

shingles in California to mitigate wildfires, 

or a safe room in units designed for people 

with disabilities that should withstand high 

winds from hurricanes or tornadoes.

Employment

■ NCD recommends the Department of Labor 

(DOL) Bureau of Labor Statistics should 

collaborate with the National Institute 

on Disability, Independent Living, and 

Rehabilitation Research to commission 

a study on how individual disasters 

impact people with disabilities in terms of 

employment and economic impacts.

Education

■ NCD recommends Congress should enact 

legislation to combat special education and 

rural teacher shortages across the U.S. and 

appropriate funding for programs to assist in 

recruitment of special education teachers.

Emergency Management

■ NCD recommends that the President 

should sign an executive order (EO) 

charging federal agencies to develop/

update emergency management plans 

to anticipate an increase in extreme 

weather events, address the impact to 

agency functions, and provide guidance 

to the SLTTs. The EO should specifically 

address how each agency will integrate 

people with disabilities into the emergency 

management plan to ensure services for 

people with disabilities are available before, 

during, and after disaster.

■ NCD recommends Congress should 

authorize additional funding and FEMA 

should provide guidance to Tribal Nations 

to strengthen/establish an emergency 

preparedness plan inclusive of people with 

disabilities.

The Impacts of Extreme Weather Events on People with Disabilities 13
■ NCD recommends FEMA should provide 

guidance and training to SLTT partners on 

the legal requirements for Functional Needs 

Support Services for general population 

shelters and the potential loss of shelter 

reimbursement funds and propensity for 

lawsuits should they not provide accessible 

sheltering.

■ NCD recommends FEMA, DOJ, and Federal 

Communications Commission should 

review, consolidate, and enhance existing 

guidance for effective communications 

before, during, and after disasters, compiling 

these materials into a comprehensive guide 

that is distributed, and promoted, across 

SLTT and nongovernmental organization 

(NGO) partners.

Methodology

This report is organized into six chapters 

that examine how existing federal law and 

regulations and federal and state policies and 

programs impact people with disabilities in 

regard to housing, employment, education, and 

emergency management before, during, and 

after an extreme weather event. Each section 

addresses the topics of access and accessibility 

(e.g., access to health care, access to affordable 

and accessible housing and shelter, access to 

employment, access to a free and appropriate 

public education, and how we build resilient 

communities before, during, and after an 

emergency or major disaster declaration). The 

Stafford Act14 provides for two types of disaster 

declarations—emergency declarations and major 

disaster declarations. Both must be declared 

by the President but provide different levels of 

emergency services, assistance programs, and 

funding.15

NCD conducted a literature review on extreme 

weather events and environmental hazards. 

First, NCD examined a selection of relevant 

academic research papers on how extreme 

weather events impact people with disabilities in 

the United States. Second, NCD conducted risk 

mapping and a multistep geospatial analysis to 

spatially demonstrate where extreme weather 

events are occurring in the United States and the 

communities impacted, as well as where people 

with disabilities are concentrated.

NCD identified counties with high 

concentrations of people with disabilities and the 

factors that lead to adverse and disproportionate 

impacts on people with disabilities based on data 

from the Census Bureau ACS disability status 

variables (2015–2019) and other national databases. 

The data included indicators and provided 

estimates and statistics that were disaggregated 

by disability status to reflect the diversity of 

people with disabilities. NCD reviewed disability 

statistics from the Centers for Disease Control and 

Prevention (CDC) and NIDILRR.

Third, NCD conducted stakeholder 

engagement through virtual stakeholder 

convenings using a mixed mode of participant 

engagement. The first and second convenings 

gathered disability experts, advocates, and NGOs 

to identify gaps, insights, and interventions in 

relation to how extreme weather events impact 

people with disabilities and how to improve 

outcomes. The third convening gathered federal, 

state, and local government experts to discuss 

policies, programs, and recommendations in 

relation to how extreme weather events impact 

people with disabilities.

14 National Council on Disability
Risk Mapping of Impacted Communities

To show extreme weather events in the United 

States by county, NCD used data from the 

FEMA NRI. NCD used the risk ratings (very low, 

relatively low, relatively moderate, relatively 

high, and very high) that categorize the relative 

risk for each county and natural hazard. The 

ratings are categorized based on the NRI’s risk 

score, which is a scaled score for all counties 

ranging from 0 to 100 that can be broken down 

by hazard (e.g., flooding, heat) (see figure 1). 

The graph can be found in appendix D with 

all text.

To show where significant concentrations of 

people with disabilities reside, NCD used Census 

Bureau ACS 2015–2019 disability status variables 

data, which comprise the most recent five-year 

data set (see appendix D, figure 2).

NCD then combined the two data sets to 

identify locations in the United States that have 

high risks for natural hazards, high percentages 

of people with disabilities, and high total counts 

of people with disabilities in counties (see 

appendix D, figure 3).

NCD reviewed FEMA emergency and major 

disaster declarations for the past 10 years by 

county (see figure 4).16

To show the economic impacts of extreme 

weather events, NCD referenced the NOAA 

National Centers for Environmental Information 

(NCEI) U.S. Billion-Dollar Weather and Climate 

Disasters data (2022).17 The NOAA data showed 

that in 2021, the United States experienced 

20 separate billion-dollar weather and climate 

disasters, putting 2021 in second place for the 

most disasters in a calendar year, behind the 

record 22 separate billion-dollar events in 2020 

(all inflation-adjusted to 2021 dollars).18 The 

diversity of the billion-dollar disasters indicated 

that costly extreme weather events are not 

limited to a particular type of natural hazard. NCD 

also reviewed the past 10 years (2012–2021) and 

found that the 2010s decade was far costlier than 

the 2000s, 1990s, or 1980s (see figure 5).

The risk mapping analysis enabled NCD 

to identify key locations in the United States 

that are appropriate for reviewing extreme 

weather events and their impact on people with 

disabilities. The mapping analysis also informed 

NCD of key locations to convene stakeholder 

focus groups to provide the most informed input. 

NCD assembled stakeholders from locales where 

people with disabilities are impacted by extreme 

weather and environmental disasters.

Figure 4. County-Level Emergency and Major Disaster Declarations for (a) All

Weather Events and (b) Select Events (2012–2021)

The Impacts of Extreme Weather Events on People with Disabilities 15
NCD identified the following disasters to 

review: hurricanes Harvey, Irma, and Maria 

(2017); western wildfires (2020–2021); and winter 

storm Uri (2021). These extreme weather events 

impacted counties in Texas, California, and Florida 

that have large populations and percentages of 

people with disabilities and are also at a “very 

high” risk of natural hazards.

Hurricane Harvey impacted the Gulf States 

(Texas, Louisiana, Mississippi, Alabama, and 

Florida). In fact, the impact covered 90 percent 

of the state of Florida and the U.S. Virgin Islands. 

Hurricane Irma impacted Georgia, Alabama, 

Tennessee, and South Carolina. Hurricane Maria 

was the strongest storm to hit Puerto Rico in 

nearly a century.19 The western wildfires (2020–

2021) impacted California, Oregon, Washington, 

Idaho, and Montana. Winter storm Uri (2021) had 

a significant impact on Texas.

Website: https://www.climate.gov/sites/default/files/2021-10/BillionDollarDisasters2019_counts_costs_large.png

Figure 5. Billion-Dollar Disaster Events by Type in United States (1980–2019

16 National Council on Disability
Acronym Glossary

AAR after-action report

ABLE Achieving a Better Life Experience Act

ADA Americans with Disabilities Act of 1990

ACA Patient Protection and Affordable Care Act

ACL Administration for Community Living

ACS American Community Survey

AHA Affordable Housing Act

AIVR American Indian Vocational Rehabilitation Service program

AJC American Jobs Centers

ASL American Sign Language

ASPR Office of the Assistant Secretary for Preparedness and Response

AT Assistive Technology

ATBCB Architectural and Transportation Barriers Compliance Board

BIA Bureau of Indian Affairs

BLM Bureau of Land Management

BLS Bureau of Labor Statistics

CAP Common Alerting Protocol

CART Communication Access Realtime Translation

CBPP Center on Budget and Policy Priorities

CBOs community-based organizations

CCAM Coordinating Council on Access and Mobility

CDBG Community Development Block Grant

CDBG-DR Community Development Block Grant-Disaster Recovery

CDBG-MIT CDBG-Mitigation

CDC Centers for Disease Control and Prevention

CCFs congregate care facilities

CIL Centers for Independent Living

CMIST Communication, Maintaining Health, Independence, Support, and Transportation

CRIPA Civil Rights of Institutionalized Persons Act

CMS Centers for Medicare and Medicaid Services

COPD chronic obstructive pulmonary disease

COVID-19 Coronavirus

The Impacts of Extreme Weather Events on People with Disabilities 17
CRCL Office for Civil Rights and Civil Liberties

CVAA Communications and Video Accessibility Act

CPI Consumer Price Index

DCR Division of Civil Rights

DHS U.S. Department of Homeland Security

DIA disability integration advisors

DME Durable Medical Equipment

DMEPOS Durable Medical Equipment, Prosthetics, Orthotics and Supplies

DOD Department of Defense

DOI U.S. Department of Interior

DOJ U.S. Department of Justice

DOL U.S. Department of Labor

DOT U.S. Department of Transportation

DPN disability program navigators

DRMA Disaster Relief Medicaid Act

DSPs Direct Support Professionals

DREDF Disability Rights & Education Defense Fund

EAS emergency alert system

EEOC U.S. Equal Employment Opportunity Commission

EMAs emergency management agencies

EOP emergency operation plans

EPA U.S. Environmental Protection Agency

FAPE free and appropriate public education

FCC Federal Communications Commission

FEMA Federal Emergency Management Agency

FERC Federal Energy Regulatory Commission

FFRMS Federal Flood Risk Management Standard

GAO Government Accountability Office

GDP gross domestic product

GSA General Services Administration

HSAC Homeland Security Advisory Council

HCBS home-and community-based services

HHS U.S. Department of Health and Human Services

HHS OCR U.S. Department of Health and Human Services Office for Civil Rights

HIPAA Health Insurance Portability and Accountability Act of 1996

HRSA Health Resources and Services Administration

HUD U.S. Department of Housing and Urban Development

IDEA Individuals with Disabilities Education Act

IDD intellectual or developmental disabilities

18 National Council on Disability
IEP individualized education program

IHP Individuals and Households Program

IHS Indian Health Service

IPAWS Integrated Public Alert and Warning System

IPCC Intergovernmental Panel on Climate Change

LEAs local education agencies

LTCFs long-term care facilities

MOU memorandum of understanding

NASEM National Academies of Science, Engineering, and Medicine

NCD National Council on Disability

NCHS National Center on Health Statistics

NDT National Transit Database

NIDILRR National Institute on Disability, Independent Living, and Rehabilitation Research

NACIE National Advisory Council on Innovation & Entrepreneurship

NGO nongovernmental organizations

NOAA National Oceanic and Atmospheric Administration

NRCC National Response Coordination Center

NRI National Risk Index

NHC National Hurricane Center

NWS National Weather Service

OCR Office of Civil Rights

ODEP Office of Disability Employment Policy

OFA other federal agency

PA public assistance

PAS personal assistance services

PCAs personal care assistants

PCC post COVID conditions

PHA public housing authorities

PN public notice

PPE personal protective equipment

PTSD post-traumatic stress disorder

PWD people with disabilities

REAADI Real Emergency Access for Aging and Disability Inclusion for Disasters Act

RDIS Regional Disability Integration Specialists

Rehab Act Rehabilitation Act of 1978

RSA Rehabilitation Services Administration

SAMHSA Substance Abuse and Mental Health Services Administration

SBA Small Business Administration

SCI spinal cord injury

The Impacts of Extreme Weather Events on People with Disabilities 19
SE Supported Employment service

SEAs state education agencies

SLTT state, local, tribal, and territorial

SNAP Supplemental Nutrition Assistance Program

SNS strategic national stockpile

SSI Supplemental Security Income

SSDI Social Security Disability Insurance

STEAR State of Texas Emergency Assistance Registry

THIRA Threat and Hazard Identification and Risk Assessment

THSGP Tribal Homeland Security Grant Program

UCLA University of California, Los Angeles

UNEP United Nations Environmental Program

UNDRR United Nations Office for Disaster Risk Reduction

USDA U.S. Department of Agriculture

VR vocational rehabilitation

VRI video remote interpreting

VRS video relay services

WEA wireless emergency alerts

WEF World Economic Forum

WHO World Health Organization

WIOA Workforce Innovation and Opportunity Act

WIPA Work Incentives Planning and Assistance

WMO World Meteorological Organization

20 National Council on Disability
People with disabilities will continue 

to be disproportionately impacted by 

extreme weather events unless emergency planners address the specific 

needs and include people with disabilities in all emergency management activities including mitigation, preparedness, 

response, and recovery and entities that 

receive federal funding comply with federal civil rights and disability laws

The Impacts of Extreme Weather Events on People with Disabilities 21
22 National Council on Disability
Introduction

T

he global mortality rate of people with 

disabilities in natural disasters is up to four 

times higher than that of people without 

disabilities.

20 People with 

disabilities are far more 

likely than anyone else 

to face major hardships 

including displacement 

from their homes due to 

a major disaster. If they 

evacuate, people with disabilities face dangerous 

levels of isolation, squalid living conditions, 

shortages of food and water and electricity, and 

permanent dislocation.21

The increased frequency 

and severity of extreme 

weather events 

and environmental 

hazards adversely and 

disproportionately impact 

people with disabilities 

in the United States and 

its territories. Despite 

this, the needs of people 

with disabilities are being 

overlooked in disaster 

management policy 

and planning. Federal and state emergency 

management planning often fails to include 

people with disabilities.

Recent research shows that people with 

disabilities are being “systematically ignored” 

by governments around the world when it 

comes to planning for 

extreme weather events. 

According to a 2022 

comprehensive review 

and analysis of disability 

inclusion in national 

climate commitments 

and policies, few countries make provisions

for the needs of people with disabilities when 

they make plans for adapting to the effects of 

climate change and 

none mention people 

with disabilities in their 

programs.22

Extreme weather 

events are occurrences of 

unusually severe weather 

or climate conditions that 

can be disruptive and 

deadly23 and cause 

devastating impacts on 

communities and 

agricultural and natural 

ecosystems.24 In the 

United States, when extreme weather events 

occur, the governor of a state or territory may 

request that the president declare a major disaster 

The global mortality rate of people 

with disabilities in natural disasters 

is up to four times higher than that 

of people without disabilities.

According to a 2022 comprehensive 

review and analysis of disability 

inclusion in national climate 

commitments and policies, few 

countries make provisions for the 

needs of people with disabilities 

when they make plans for adapting 

to the effects of climate change and 

none mention disabled people in 

their programs.

The Impacts of Extreme Weather Events on People with Disabilities 23
or emergency. Extreme weather events such as 

severe storms, hurricanes, floods, tornadoes, 

drought, extreme heat events, wildfires, or other 

weather-related emergencies and disasters can

strike quickly and without warning, forcing people 

to quickly evacuate or be confined in their homes 

unexpectedly.25 For the 61 million (26 percent or 1 

in 4) adults in the United States who live with a 

disability,26 emergencies such as fires and floods 

present a real challenge.27

During an emergency or major disaster, 

people who live with physical, sensory, mental, 

or cognitive disabilities are disproportionately 

affected. When an emergency occurs, people with 

disabilities typically have 

fewer reserves to draw 

upon, their options for 

housing and healthcare 

are more limited, and it 

can be harder to recover 

once the immediate 

emergency has passed.

28

The increased prevalence 

of extreme weather 

events will further destroy these reserves and 

further hinder people with disabilities’ ability to 

“rebound” after an extreme weather event.

In the United States, weather-related events 

are happening more often: breaking records, 

claiming lives, and costing billions of dollars. 

These events include record-breaking heat waves, 

increased number and intensity of hurricanes, 

more precipitation and floods, more wildfires, 

more intense droughts, and increasingly severe 

storms.29 Projections indicate that the occurrence 

and severity of some extreme events will continue 

to increase.30

Extreme weather events can damage or 

destroy critical infrastructure and facilities. The 

disruption to critical services disproportionately 

and negatively impacts people with disabilities 

and puts individuals at increased risk. 

Temperature increases and heatwaves can 

lead to brownouts or blackouts. Power outages 

can jeopardize the health and safety of people 

with disabilities, older adults, and people with 

serious health conditions, who often depend on 

equipment powered by electricity.

Extreme weather events are expected to further 

disrupt many areas of life, exacerbating existing 

challenges posed by aging and deteriorating 

infrastructure, stressed ecosystems, and economic 

inequality. Impacts within and across regions 

will not be distributed 

equally.31 People with 

disabilities and those who 

are already vulnerable, 

including lower-income 

and other marginalized 

communities, have lower 

capacity to prepare for 

and cope with extreme 

weather and climaterelated events and are expected to experience 

greater impacts.32

Some regions are prone to extreme weather 

and face disasters year after year, compounding 

the impacts of previous disasters. Certain types 

of extreme weather events are increasing 

in frequency as well as intensity. The rise in 

vulnerability to drought is lengthening wildfire 

seasons in the Western states, and the potential 

for extremely heavy rainfall is becoming more 

common in the Eastern states. A rise in sea 

levels is worsening the hurricane and storm 

surge flooding that coastal communities 

experience.33 With 23 of the 25 most densely 

populated U.S. counties located on the coasts, 

When an emergency occurs, people 

with disabilities typically have fewer 

reserves to draw upon, their options 

for housing and healthcare are 

more limited, and it can be harder 

to recover once the immediate 

emergency has passed.

24 National Council on Disability
a rise in sea levels is a big issue for millions of 

people in the United States.34

As the U.S. population ages, disabilities are 

becoming more prevalent. In addition, studies 

have not yet determined how many citizens 

who contracted COVID-19 will become disabled 

because of long-haul COVID. The increase in the 

number of people with disabilities will increase 

demand for resources and services, place an 

added strain on support systems (e.g., healthcare, 

housing, transportation, employment, education, 

and emergency 

management), and 

exacerbate the drivers of 

insecurity. As the number 

of people with disabilities 

increases, so too will the 

demand for accessible 

services, resources, and 

assistive technologies 

during a disaster, the 

lack of which increases 

the risk to people with 

disabilities.

Furthermore, the 

United States is facing 

staffing shortages in 

healthcare providers and direct care workers;35

affordable, accessible housing; special education 

providers and other workers; accessible places 

of employment; and other support systems. The 

increase in the number of people with disabilities 

paired with the shortage of support systems will 

create a “perfect storm” or critical situation to 

exacerbate the drivers of insecurity and increase 

the risk to people with disabilities, including 

during an extreme weather event where 

individuals are already vulnerable and emergency 

services are already stretched.

There is little data collection on the impact 

of people with disabilities during disasters, 

especially during extreme weather events. 

With an increase in population of people with 

disabilities, all federal agencies who play a role 

in emergency management planning, response 

or recovery should collect bifurcated data on 

the impact extreme weather events have on 

people with disabilities, and then utilize that 

data to improve processes, programs, and plans 

to mitigate the detrimental impact of extreme 

weather events on 

people with disabilities.

During and after an 

extreme weather event, 

federal fund recipients 

must comply with the 

Rehab Act and the ADA 

by making appropriate 

and reasonable 

accommodations to 

ensure that people 

with disabilities have 

equal physical and 

communications access 

to services and programs, 

as defined by federal 

law. Unfortunately, the mechanisms in place 

to enforce disability laws are underutilized. 

Despite numerous reports and recommendations 

concerning people with disabilities, significant 

improvements have not been made.

Extreme Weather Events are 

Increasing in Frequency and Severity

Recent studies describe a significant rise in the 

number of extreme weather event disasters.36

For the purposes of this report, the term disaster

will be reserved for natural hazard–related 

The increase in the number of 

people with disabilities paired with 

the shortage of support systems will 

create a “perfect storm” or critical 

situation to exacerbate the drivers 

of insecurity and increase the risk 

to people with disabilities, including 

during an extreme weather event 

where individuals are already 

vulnerable and emergency services 

are already stretched.

The Impacts of Extreme Weather Events on People with Disabilities 25
disasters, excluding biological and technological 

disasters. Extreme weather event disasters 

include disasters categorized as meteorological, 

climatological, or hydrological.

A 2021 World Meteorological Organization 

(WMO) report found that a disaster related to 

a weather, climate, or water hazard occurred, 

on average, every 

day over the past 50 

years.37 Much of the 

United States has seen 

increases in prolonged 

periods of excessively 

high temperatures, heavy 

downpours, and, in some 

regions, severe floods 

and droughts.38 These 

types of records are expected to continue to 

be broken in the future.

Globally, from 2000 to 2019, there were 7,348 

major recorded disaster events claiming 1.23 million 

lives, affecting 4.2 billion people (many on more 

than one occasion), and resulting in approximately 

$2.97 trillion in global 

economic losses. This 

is a sharp increase over 

the previous 20 years. 

Between 1980 and 1999, 

4,212 disasters were 

linked to natural hazards 

worldwide, claiming 

approximately 1.19 million 

lives, affecting 3.25 billion people, and resulting in 

approximately $1.63 trillion in economic losses.39

The last 20 years have seen the number of 

major floods more than double, from 1,389 to 

3,254, while the incidence of storms grew from 

1,457 to 2,034. Floods and storms were the most 

prevalent events.40

In 2022, the United States experienced 

18 separate billion-dollar weather and climate 

disasters, tying 2017 and 2011 as the 3rd highest 

number of billion-dollar disasters.41 2021 holds 

2nd place for the most disasters in a calendar 

year behind the record 22 separate billion-dollar 

events in 2020.42 What made 2022 stand out 

was the diversity of 

disasters: 1 drought event, 

1 flooding event, 9 severe 

storm events, 3 tropical 

cyclone events, 1 wildfire 

event, and 1 winter storm 

event.43 The 18 events in 

2022 caused at least 474 

direct or indirect fatalitiesthe 8th most disasterrelated fatalities for the contiguous U.S. since 

1980.44 The year 2021 was also unusually deadly. 

The 20 events of 2021 caused at least 688 direct 

or indirect fatalities—the most disaster-related 

fatalities for the contiguous United States since 

2011, and more than double 2020’s 262 deaths.45

The increasing 

frequency and intensity 

of certain types of 

extreme weather include 

the rise in vulnerability 

to drought, lengthening 

wildfire seasons in the 

Western states, and the 

potential for extremely 

heavy rainfall becoming more common in the 

Eastern states. Sea level rise is worsening 

hurricane storm surge flooding.46 Severe storms 

have caused the most billion-dollar disaster 

events (143), while hurricanes and flooding 

represent the second and third most frequent 

event types (56 and 35), respectively.47

A 2021 World Meteorological 

Organization (WMO) report found 

that a disaster related to a weather, 

climate, or water hazard occurred, 

on average, every day over the past 

50 years.

The last 20 years have seen the 

number of major floods more than 

double, from 1,389 to 3,254, while 

the incidence of storms grew from 

1,457 to 2,034. Floods and storms 

were the most prevalent events.

26 National Council on Disability
Recent examples of severe weather events 

include the powerful billion-dollar Hurricane Harvey 

(2017),48 which resulted in devastating flooding 

that inundated Harris County, Texas, with 1 trillion 

gallons of water over a four-day period,49 and 

Winter Storm Uri (2021), a historic cold wave and 

winter storm that impacted many Northwest, 

Central, and Eastern 

states in February 2021. 

The prolonged Arctic 

air caused widespread 

power outages in Texas, 

as well as other southern 

states, with multiple 

days of sustained belowfreezing temperatures. At 

the peak of the outage, 

nearly 10 million people 

were without power.50 Additional impacts included 

frozen water pipes that burst upon thawing, 

causing water damage to buildings. The extreme 

conditions also caused or contributed to the direct 

and indirect deaths of more than 210 people in 

Texas alone.51 During the Western wildfires (2020–

2021),52 severe drought conditions and periods 

of extreme heat provided conditions favorable 

for wildfires,53 which 

impacted the states 

of California, Oregon, 

Washington, Idaho, and 

Montana. The Southern 

and Central U.S. also experienced remarkable late 

autumn tornadoes in 2021.54

Extreme Weather Events are 

Increasing in Cost

As extreme weather events accelerate in 

frequency and grow in intensity, the impacts 

are costly. In 2014, the U.S. National Climate 

Assessment (2014 NCA) found that rising 

temperatures, the resulting increases in the 

frequency or intensity of some extreme weather 

events, rising sea levels, and melting snow and 

ice were already disrupting people’s lives and 

damaging some sectors of the U.S. economy.55

The money spent on disaster recovery efforts can 

mean a loss to productive 

investments and gross 

domestic product (GDP). 

Consequently, real 

disaster costs are high 

and growing faster than 

the U.S. GDP. 56

The National Oceanic 

and Atmospheric 

Administration (NOAA), 

NCEI U.S. Billion-Dollar 

Weather and Climate Disasters (2022) report 

calculates the costs of disasters. The report 

found that from 1980 to 2021, the U.S. has 

sustained 323 distinct billion-dollar disasters 

(weather and climate events) where overall 

damages/costs reached or exceeded at least 

$1 billion in direct losses (CPI-adjusted, 2022).57

The direct losses from these 323 events exceed 

$2.199 trillion (CPIadjusted, 2022).58

The disaster costs 

for 2022 ($165 billion) 

surpassed the disaster 

costs for 2021 ($155.3 billion)59 by $10 billion 

and 2022 had $2 less billion-dollar events. The 

total cost for the last 5 years ($595.5 billion) 

is almost one third of the disaster cost total 

of the last 42 years (1980 to 2022) at $2.476 

trillion (inflation-adjusted to $2022).60 This 

reflects a 5 year average cost of nearly $161.5 

billion per year—a new record.61 The 1980–2022 

In 2021, the U.S. experienced 20 

separate billion-dollar weather and 

climate disasters, putting 2021 in 

second place for the most disasters 

in a calendar year, behind the 

record 22 separate billion-dollar 

events in 2020.

[R]eal disaster costs are high and 

growing faster than the U.S. GDP.

The Impacts of Extreme Weather Events on People with Disabilities 27
annual average cost per year is $57.6 billion 

(CPI-adjusted); the annual average for the most 

recent 5 years (2018–2022) is $119.1 billion 

(CPI-adjusted).62

Between 1980 and 2022, 21 wildfire, 30 

drought, 163 severe storm, 60 tropical cyclone, 37 

flooding, 21 winter storm, 

and 9 freeze billion-dollar 

disaster events affected 

the United States (CPI 

adjusted).63 The 

distribution of damage 

from U.S. billion-dollar 

disaster events from 1980 

to 2022 is dominated by 

tropical cyclones. 

Hurricanes have caused the most damage 

($1,333.6 billion, CPI-adjusted) and also have the 

highest average event cost ($22.2 billion, CPIadjusted). Drought ($327.7 billion, CPI-adjusted), 

severe storms ($383.7 billion, CPI-adjusted), and 

inland flooding ($177.9 billion, CPI-adjusted) have 

also caused considerable damage.65

Severe storms have 

caused the highest 

number of billion-dollar 

disaster events (143), but 

have the lowest average 

event cost ($2.3 billion, 

CPI-adjusted). Hurricanes 

and flooding represent 

the second and third 

most frequent event 

types (56 and 35), respectively. Hurricanes are 

responsible for the highest number of deaths 

(6,697), followed by drought/heat wave events 

(4,139) and severe storms (1,880).66

As hurricanes and flooding tend to occur in 

the southern part of the U.S., from 1980–2022, 

the U.S. South, Central, and Southeast regions 

experienced higher costs from billion-dollar 

disaster events (this was also the case for 

California, New York, New Jersey, Puerto Rico, 

and the U.S. Virgin Islands). The top three most 

impacted states were Texas ($349 billion), 

Louisiana ($278 billion), 

and Florida ($249 

billion).67 The relative 

costs were more acute 

in Louisiana, which has 

a smaller population and 

economy than Texas and 

Florida. Louisiana also 

has a high frequency 

of disaster events, 

which can lead to compounding, cascading 

socioeconomic impacts.68

Regional Impact and Rural 

Communities

While each region of the United States faces 

a unique combination of weather and climate 

events, every state in 

the country, as well as 

Puerto Rico and the 

Virgin Islands, has been 

impacted by at least one, 

billion-dollar disaster 

since 1980. Since 1980, 

there have been more 

than 100 of these events 

that have affected at 

least some part of Texas, while only one event 

has impacted Hawaii (Hurricane Iniki in 1992).69

The U.S. Central, South, and Southeast 

regions typically experience a higher frequency of 

billion-dollar disasters than other regions.

70 These 

same U.S. regions are also projected to have 

The total cost for the last 5 years 

($595.5 billion) is almost one 

third of the disaster cost total of 

the last 42 years (1980 to 2022) 

at $2.476 trillion (inflation-adjusted 

to $2022).64

28 National Council on Disability

While each region of the United 

States faces a unique combination 

of weather and climate events, 

every state in the country, as well as 

Puerto Rico and the Virgin Islands, 

has been impacted by at least one 

billion-dollar disaster since 1980.
the most negative future impacts across several 

socioeconomic metrics.71 Severe local storm 

events are common across the Plains, Southeast, 

and Ohio River Valley states. Winter storm 

impacts are concentrated in the Northeastern 

states, while tropical cyclone impacts range from 

Texas to New England, but also impact many 

inland states. Inland flood 

events—not caused by 

tropical cyclones—often 

occur in states near 

large rivers or the Gulf of 

Mexico, which is a warm 

source of moisture to 

fuel rainstorms. Drought 

impacts are mostly focused in the Southern 

and Plains states, where crop and livestock 

assets are densely populated. Wildfires are most 

common west of the Plains states and in several 

Southeastern states. Concurrent or consecutive 

extreme weather 

events will continue to 

pose unprecedented 

challenges and test 

federal and SLTT 

government EMAs’ 

preparedness and 

coordination efforts 

and complicate 

response and recovery 

efforts. Concurrent or 

consecutive extreme 

weather events will 

stress critical systems 

(e.g., healthcare, housing, transportation, 

education) and support services upon which 

people with disabilities rely and heighten risks, 

compound impacts, and have far-reaching 

consequences for people with disabilities. Some 

U.S. regions experience multiple disasters 

occurring at the same time, much like Louisiana 

faced in 2020 as its local government leaders 

and their emergency managers responded to 

the COVID-19 pandemic and an “epidemic” of 

landfalling hurricanes during the 2020 season.72

Some U.S. regions are prone to and are well 

known for experiencing 

consecutive extreme 

weather events, which 

compound the impacts of 

previous disasters.

According to 

the FEMA NRI – All 

Hazards data, there is a 

particularly high risk of natural hazards along the 

West Coast (specifically in Southern California), 

the Gulf Coast, and Florida. The Gulf Coast states 

will be especially susceptible to sea levels rising. 

States such as Texas, Louisiana, Mississippi, 

Alabama, and Florida may 

experience increased 

storm surges and 

flooding due to rising sea 

levels.

NOAA’s Sea Level 

Rise Technical Report 

projects sea levels along 

the coastline will rise 

an additional 10 to 12 

inches by 2050, with 

specific amounts varying 

regionally, mainly due to 

land height changes. Sea 

level rise will create a profound shift in coastal 

flooding over the next 30 years by causing tide 

and storm surge heights to increase and reach 

further inland. By 2050, “moderate” (typically 

damaging) flooding is expected to occur, on 

The U.S. Central, South, and 

Southeast regions typically 

experience a higher frequency of 

billion-dollar disasters than other 

regions.

By 2050, “moderate” (typically 

damaging) flooding is expected to 

occur, on average, more than 10 

times as often as it does today; this 

flooding can be intensified by local 

factors. “Major” (often destructive) 

flooding is expected to occur 5 times 

as often in 2050 (0.2 events/year) as 

it does today (0.04 events/year).

The Impacts of Extreme Weather Events on People with Disabilities 29
average, more than 10 times as often as it does 

today; this flooding can be intensified by local 

factors. “Major” (often destructive) flooding 

is expected to occur 5 times as often in 2050 

(0.2 events/year) as it does today (0.04 events/

year).73 This is especially troubling for people 

with disabilities living in these areas, and 

especially those with mobility disabilities who 

do not have the funds to raise the elevation of 

their home to mitigate the risk of flood or those 

who are trapped in their home during a flood 

event with no option to evacuate.

U.S. Territories

In September 2017 Hurricane Maria made landfall 

in Puerto Rico and decimated its infrastructure. 

In Maria’s aftermath, some 3.4 million American 

citizens found themselves in a humanitarian 

crisis, facing destroyed infrastructure; power 

outages lasting for over six months; shortages 

of water, food, and fuel; and an uncertain 

future.74 In January 2020, Puerto Rico suffered 

a 6.4 magnitude earthquake and continuing 

aftershocks in the southwestern part of the 

island that destroyed homes and businesses, 

further weakening an already dire economy and 

creating significant impact to the health and 

well-being of the residents of Puerto Rico. In 

March 2020, Puerto Rico, along with the rest of 

the world, was hit with the COVID-19 pandemic, 

which strained health and medical systems. The 

government took early precautions by shuttering 

all businesses, except for essential services. 

These restrictions, though necessary, saddled 

the island with further economic burdens, 

leaving thousands unemployed, resulting in 

increased poverty rates and further widening 

the gap to accessible services for people with 

30 National Council on Disability
disabilities. As a result of these conditions and 

threats, the island experienced an exodus of 

residents to the mainland United States. This 

migration created a shortage of medical doctors, 

educators, and other professionals, further 

exacerbating availability of services for people 

with disabilities.75

Regional Impacts

Some states, counties, and cities are more likely 

than others to have residents with disabilities. 

The percentage of people living with disabilities 

is highest in the South.76 West Virginia has the 

highest share of people with disabilities of any 

state, at 19.4 percent. In Arkansas, Kentucky, 

and Alabama, about 

17 percent of residents 

said they had a disability. 

In contrast, Utah was 

among the lowest, 

with 9.9 percent of the 

population reporting a 

disability in 2015.77

Among counties 

with populations of 65,000 or more, three 

had a quarter or more of residents reporting a 

disability: Pike County, Kentucky (28.7 percent), 

and Calhoun (25.2 percent) and Walker (25.1 

percent) counties, both in Alabama. The share 

of residents with a disability varied widely at 

the county level, with Kendall County in Illinois 

(4.9 percent) among the lowest rates in the 

country. Few of the cities with the largest shares 

of disabled residents in 2015are in the South 

(among places with a minimum population of 

65,000). In Flint, Michigan; Hemet, California; 

and Pueblo, Colorado, roughly 22 percent of 

residents reported having a disability. The town of 

Fishers, Indiana, had one of the lowest shares in 

the nation, with 3.5 percent of residents having a 

disability.78

People with disabilities are more likely to live in 

poverty, be unemployed, and have limited access 

to healthcare before a disaster, which compounds 

these difficulties.79 In the U.S., according to the 

CDC, 61 million adults in the U.S. live with a 

disability—that is 26 percent of (or 1 in 4) adults. 

The CDC data (2020) report that disabilities are 

especially common in older adults, women, and 

people from diverse cultures or backgrounds.

Older Adults

The population is getting older and disabilities 

become more prevalent with age. According to 

CDC data (2020), two 

in five adults aged 65 

years and older have 

disabilities.80 According 

to the American 

Community Survey, 

about half of Americans 

ages 75 and older (49.8 

percent) reported living 

with a disability in 2015, as did about a quarter 

(25.4 percent) of those 65 to 74. In contrast, 

just 6 percent of Americans ages 18 to 34 and 

13 percent of those 35 to 64 said they had a 

disability. In absolute numbers, however, ages 35 

to 64 accounted for more disabled Americans—

nearly 16 million in 2015—than any other age 

group.81

The number of adults over age 65 in the 

U.S. is estimated to reach 84 million, or over 20 

percent of the population, by 2050.82 As people 

grow older and the probability of disabilities 

increases, the use of assistive technology—that 

is, alternate and augmentative communication 

equipment, devices, strategies, tools, and 

People with disabilities are 

more likely to live in poverty, be 

unemployed, and have limited 

access to healthcare before a 

disaster, which compounds these 

difficulties.

The Impacts of Extreme Weather Events on People with Disabilities 31
supportive services that allow individuals to live 

in their homes with dignity and autonomy—may 

increase.83 Using a conservative estimate of 

20 percent of the population age 60 and over 

requiring assistive devices leads to a worldwide 

estimate of at least 800 million items being used 

by older adults by 2050. To meet the needs of 

this population, assistive devices and technology 

need to be available 

and accessible for this 

population, affordable 

and appropriate for their 

needs, and safe for their 

use.84 This need becomes 

even more important 

when disasters occur, 

as these devices may be 

lost, damaged, or unavailable without services 

such as electrical power and refrigeration.85

People from Marginalized or 

Underserved Communities Including 

American Indians or Alaska Natives

People from marginalized or underserved 

communities, including Black and American 

Indians or Alaska Natives, are more likely to 

have disabilities than 

other populations. At 

the high end of the 

scale, American Indians 

or Alaskan Natives are 

most likely to report a 

disability: 17.7 percent,86

or two in five of American Indians or Alaska 

Natives have a disability.87 For comparison, 13.9 

percent of white people and 14.1 percent of 

Black people reported living with a disability, 

followed by 8.8 percent of Hispanic people and 

6.9 percent of Asian people.88

There are shortages in healthcare, housing, 

education, employment, and other support 

systems, which will increase the risk to people 

with disabilities.

While the number of people with disabilities 

is increasing, there is a health care worker 

shortage. The increase in demand for support 

and growing gap in supply will strain the U.S. 

healthcare system 

and impact access 

to healthcare. The 

shortage of care workers 

(e.g., direct support 

professionals (DSPs) and 

personal care assistants 

(PCAs)) places people 

with disabilities at 

additional risk of harm and puts an additional 

burden on the people who care for them.

In addition, it has become harder than ever for 

middle-income Americans to rent or buy a home 

as the U.S. faces a housing shortage. The Census 

Bureau reported that despite the strong demand 

for rentals, the national vacancy rate was at 6.8 

percent in 2019. Still, the increase in the number 

of households paying more than 30 percent of 

their income for rent and 

utilities grew by 261,000 

to 20.8 million in 2018. In 

2018, one in four renters 

spent more than half 

their income on housing, 

especially individuals 

earning between $45,000 and $74,999.89 There 

is also a nationwide shortage of qualified special 

education teachers and related service providers.90

Qualified staff for in-home education can be wholly 

unavailable.91 The COVID-19 pandemic has only 

exacerbated these challenges.92

Using a conservative estimate of 

20 percent of the population age 60 

and over requiring assistive devices 

leads to a worldwide estimate of at 

least 800 million items being used 

by older adults by 2050.

Minority populations, including Black 

and American Indians or Alaska 

Natives, are more likely to have 

disabilities than other populations.

32 National Council on Disability
The mechanisms in place to enforce disability 

laws are underutilized. Despite numerous reports 

and recommendations submitted by NCD and 

other organizations, significant improvements 

have not been made.

Key federal laws such as the ADA,93 the Rehab 

Act,94 and IDEA95 have 

helped people with 

disabilities increase 

their presence in the 

workforce, receive 

improved educational 

services, and live 

independently in the 

community. These and other laws, such as the 

Fair Housing Amendments Act of 1988 and the 

Telecommunications Act of 1996, seek to ensure 

that people with disabilities have the opportunity 

to access housing, education, employment, 

effective communications and other activities 

without discrimination.96 During emergencies 

or disasters, any SLTT partners who accept 

federal emergency/disaster funding must comply 

with the ADA and the Rehab Act; however, the 

mechanisms in place to enforce disability rights 

laws are underutilized.

This report examines 

the federal and SLTT 

government policies and 

programs (specifically 

disaster prevention 

and preparedness and 

response and recovery 

programs) in place to 

support people with disabilities before, during, 

and after a disaster and endeavors to determine 

whether those policies and programs ensure 

accessibility and safety and protect the civil right 

of people with disabilities.

In 2018, one in four renters spent 

more than half their income on 

housing, especially individuals 

earning between $45,000 and 

$74,999.

The Impacts of Extreme Weather Events on People with Disabilities 33
34 National Council on Disability
Chapter 1: Laws and Regulations

During extreme weather events, the rights 

of people with disabilities must not be 

ignored and recipients of federal funds 

must comply with federal disability laws. In 

federally declared emergencies and disasters,97

federal and SLTT government EMAs are 

responsible for ensuring equal access to facilities 

and programs. Key federal laws, including the 

ADA,98 and the Rehab 

Act,99 were enacted to 

ensure that people with 

disabilities have access 

to the same opportunities 

as those without 

disabilities. Section 504 

of the Rehabilitation 

Act specifically states 

that any program or 

activity that receives 

federal financial 

assistance cannot deny 

benefits to people with 

disabilities.100 Other 

laws, such as IDEA (reauthorized in 2004),101 the 

Fair Housing Amendments Act of 1988,102 and 

the Telecommunications Act of 1996,103 seek 

to ensure that individuals with disabilities have 

the opportunity to access housing, education, 

employment, and other activities without 

discrimination.104 In 2010, Congress passed the 

Twenty-First Century Communications and Video 

Accessibility Act (CVAA) to ensure accessibility 

to people with disabilities to the rapidly changing 

telecommunications and information technology 

sector.

In Saving Lives: Including People with 

Disabilities in Emergency Planning (2005), 

NCD reported that “all too often in emergency 

situations the legitimate 

concerns of people with 

disabilities are overlooked 

or swept aside.”105

Seventeen years later, 

we find that emergency 

management planning 

still does not sufficiently 

account for the needs of 

people with disabilities 

and does not afford 

equal access to people 

with disabilities (PWDs) 

during emergencies 

and disasters. In other 

words, disability rights continue to be violated 

and federal laws are not applied consistently. 

People with disabilities will continue to be 

disproportionately impacted by extreme 

weather events unless emergency planners 

address the specific needs and include people 

with disabilities in all emergency management 

People with disabilities will continue 

to be disproportionately impacted 

by extreme weather events unless 

emergency planners address the 

specific needs and include people 

with disabilities in all emergency 

management activities including 

mitigation, preparedness, response, 

and recovery and entities that receive 

federal funding comply with federal 

civil rights and disability laws.

The Impacts of Extreme Weather Events on People with Disabilities 35
activities including mitigation, preparedness, 

response, and recovery and entities that receive 

federal funding comply with federal civil rights 

and disability laws.

Preparedness and Response

Federally Assisted Programs Must Be 

ADA and Rehabilitation Act Compliant

Some SLTTs do not comply with federal rules and 

regulations, even though those rules and 

regulations clearly state that programs and 

services funded with federal dollars must be 

compliant with federal disability rights laws. 

SLTTs and their contractors are legally required to 

comply with Title II of the ADA provision of 

“emergency-and disaster-related programs, 

services, and activities they provide”106 and with 

Section 504 of the Rehabilitation Act, to ensure 

federally funded programs allow for equal access. 

Even during the most challenging notice or 

no-notice disasters, SLTTs, and third parties have 

a legal obligation to ensure that people with 

disabilities who are impacted by extreme 

weather events do not face unlawful 

discrimination in the provision of services before, 

during, and after disasters.107 Title II of the ADA,108

which covers all activities of SLTTs, requires that 

SLTTs give people with disabilities an equal 

opportunity to benefit from all programs, 

services, and activities (e.g., public education, 

employment, transportation, recreation, 

healthcare, social services, courts, voting, and 

town meetings).109 During disasters, people with 

disabilities have the right to access emergency 

information in clear, plain, and actionable 

language; the right to be included in community 

evacuation transportation plans; the right to 

independent living supports in community 

shelters; the right to accessible temporary 

housing; and the right to healthcare.110 In terms of 

shelter, in the landmark case, Olmstead v. L.C.

(1999), the U.S. Supreme Court ruled that 

unjustified segregation of people with disabilities 

constitutes discrimination in violation of Title II of 

the ADA. The court held that public entities must 

provide community-based services to people 

with disabilities when “(1) such services are 

appropriate; (2) the affected persons do not 

oppose community-based treatment; and (3) 

community-based services can be reasonably 

accommodated, taking into account the 

resources available to the public entity and the 

needs of others who are receiving disability 

services from the entity.” This case had a 

36 National Council on Disability
significant impact on the opportunities for people 

with disabilities to live and fully participate in their 

communities.111 Even with the abundance of laws 

and regulations prohibiting the discrimination of 

people with disabilities in emergency 

management activities, people with disabilities 

continue to face discriminatory practices before, 

during and after disasters.

FEMA Developing and Maintaining Emergency 

Operations Plans (2021)112 guide for SLTT 

planners, recommends using demographic data 

and information on the number of individuals 

in the community with 

disabilities; identifying 

mechanisms to 

disseminate timely and 

accessible emergency 

public information using 

multiple methods to 

reach individuals with 

sensory, intellectual and 

cognitive disabilities, 

as well as individuals 

with limited English 

proficiency; identifying 

accessible transportation 

resources (including 

paratransit service vehicles, school buses, 

municipal surface transit vehicles, drivers and/

or trained attendants) that can provide needed 

services during an evacuation; allocating 

adequate shelter space for individuals with 

disabilities who may need additional space for 

assistive devices (e.g., wheelchairs, walkers); 

and planning for sufficient staff, medicines, 

durable medical equipment and supplies during 

an emergency, among other recommendations.113

In addition, SLTT’s should provide in-home 

assistance or sheltering options for individuals 

with disabilities whose survival depends on 

electrically powered equipment during a shelterin-place response, such as during a power 

outage.114

Research has shown that SLTT’s continue to 

neglect the needs of people with disabilities. 

In The Impact of COVID-19 on People with 

Disabilities (2021), NCD reported that during 

the COVID-19 pandemic, civil rights concerns 

continued to impact the lives of people with 

disabilities, in relation to congregate care facilities 

(CCFs) specifically and regarding healthcare 

discrimination more 

broadly. The report stated 

that the “disregard for 

the safety of people 

with disabilities was 

another example of 

the degree to which 

people with disabilities 

were discounted in 

the pandemic”—they 

were “left out of basic 

data gathering on death 

certificates, left out of 

emergency planning and 

distribution of supplies, 

and subjected to ongoing stereotypes and 

assumptions about their health and quality of 

life by healthcare providers, which led to further 

deadly consequences for those people with 

disabilities who needed urgent intensive care at 

the height of the pandemic.”115

Following Hurricane Irene (2011) and 

Hurricane Sandy (2012), in Brooklyn Center 

for Independence of the Disabled et al. v. 

Bloomberg et al. (2012),116 the plaintiffs by way 

of federal class action, sued the City of New 

York—regarding the applicability of certain 

The plaintiffs demonstrated that 

[New York City] failed to create a 

system to evacuate a large number 

of people with disabilities many of 

whom were trapped in high-rise 

buildings during disasters. . . . [T]he 

court ruled in favor of the plaintiffs, 

holding that New York City had 

violated the rights of about 900,000 

of its residents with disabilities . . .

The Impacts of Extreme Weather Events on People with Disabilities 37
portions of Title II of the ADA,117 Section 504 of 

the Rehab Act, and the New York City Human 

Rights Law—for the city’s systemic failure 

to incorporate the unique needs of people 

with disabilities in its emergency and disaster 

planning, which resulted 

in the exclusion of 

those individuals from 

equal participation in 

emergency services. At 

the time, New York City’s 

nearly 900,000 residents 

with disabilities, made 

up about 11 percent of 

its population. The plaintiffs demonstrated that 

the city failed to create a system to evacuate a 

large number of people with disabilities many 

of whom were trapped in high-rise buildings 

during disasters. The city’s limited options to 

accessible transportation, communication, 

and housing, and individuals reliance on the 

availability of specialized equipment, disabilityrelated assistance, 

consumable medical 

supplies, durable 

medical equipment, 

and food, interfered 

with the ability of 

individuals with a variety 

of disabilities to equally 

respond to and recover 

from the city’s emergencies and disasters.118

In November 2013, following a bench trial, 

under federal Judge Jesse M. Furman, the 

The court further held that “because 

of [Los Angeles’s] failure to address 

their unique needs, individuals with 

disabilities are disproportionately 

vulnerable to harm in the event of 

an emergency or disaster.”

38 National Council on Disability
court ruled119 in favor of the plaintiffs, holding 

that New York City had violated the rights of 

about 900,000 of its residents with disabilities 

by failing to accommodate their needs during 

emergencies.120

In 2010, in 

Communities Actively 

Living Independently 

and Free, et al., v. City 

of Los Angeles and 

County of Los Angeles, 

the plaintiffs alleged 

that the County and 

City of Los Angeles, 

California discriminated 

against individuals 

with disabilities in their 

emergency management programs in violation 

of federal law, including Title II of the ADA and 

Section 504 of the Rehab Act. The plaintiffs 

contended that Los Angeles failed to conduct 

the planning required to meet the needs of 

individuals with disabilities and ensure access 

for those individuals 

across the full spectrum 

of its emergency 

programs, services, and 

activities.121 In 2011, 

the court held that the 

plaintiffs were “denied 

the benefits of the city’s 

emergency preparedness 

program because the 

city’s practice of failing to address the needs 

of individuals with disabilities discriminates 

against such individuals by denying them 

meaningful access to the city’s emergency 

preparedness program.” The court further held 

that “because of the city’s failure to address 

their unique needs, individuals with disabilities 

are disproportionately vulnerable to harm in the 

event of an emergency or disaster.”122 To support 

SLTTs to better comply with civil rights and 

disability rights DOJ’s 

ADA Best Practices Tool 

Kit for State and Local 

Governments (March 9, 

2017),123 may be useful 

but may need updating.

Recovery

Federal Agencies 

that Administer 

Funding May Not 

Have Enforcement 

Authorities

Federal agencies responsible for administering 

disaster recovery funding may not have 

enforcement authority and have no mechanism 

to ensure that states and public entities that 

receive federal disaster funding comply with 

federal disability law. In 

disasters, if a state is 

“overwhelmed,” under 

the Robert T. Stafford 

Disaster Relief and 

Emergency Assistance 

Act, 42 U.S.C. §§ 

5121-5206 (1988),124 a 

governor may request 

a disaster declaration 

from the President. As part of the request, the 

governor must take appropriate action under 

state law and direct execution of the state’s 

emergency plan. Based on the governor’s 

request, the President may declare a major 

Federal agencies have oversight 

roles and can monitor how grant 

funding is spent but may not have 

the authority to ensure equitable 

outcomes. Once grant funding is 

distributed, it is incumbent upon the 

SLTTs to ensure compliance with 

disability law.

Also, HHS, under the Stafford Act, 

has a role in disaster response. 

But the relevant component, the 

Administration for Community 

Living (ACL), does not specifically 

work on disaster planning or 

emergency management.

The Impacts of Extreme Weather Events on People with Disabilities 39
disaster or emergency,125 activating an array of 

federal programs to assist in the response and 

recovery effort. States or public entities may 

receive funding via FEMA’s Public Assistance 

(PA) program126 to fund 

the repair, restoration, 

reconstruction, or 

replacement of a public 

facility or infrastructure 

damaged or destroyed 

by a disaster. States 

may also receive funding 

through the U.S. HUD 

CDBG program127 or 

other federal programs.

Any federal funds received by state and 

local governments, and other entities, must 

comply with all federal and applicable SLTT 

disability rights laws. This requirement applies 

to programs, services, and activities provided 

directly by state and local governments, as well 

as those provided through third parties, such 

as the American Red 

Cross, private nonprofit 

organizations, and 

religious entities.128

The ADA also requires 

reasonable modifications 

to policies, practices, 

and procedures when 

necessary to avoid 

discrimination against 

a person with a 

disability129 and taking the steps necessary to 

ensure effective communication for people with 

disabilities.130

Although DOJ can file civil judicial 

actions against noncompliant 

states and entities, settlements may 

take years, leaving people with 

disabilities without basic access to 

programs and supports such as to 

accessible shelter and housing.

40 National Council on Disability
Disability stakeholders shared that federal 

agencies responsible for administering federal 

disaster grants do not have the power to enforce 

federal disability law. Federal agencies have 

oversight roles and can monitor how grant 

funding is spent but may not have the authority 

to ensure equitable outcomes. Once grant 

funding is distributed, it is incumbent upon the 

SLTTs to ensure compliance with disability law. 

some federal agencies can revoke funds when 

projects or programs do not comply with agency 

requirements or applicable laws and regulations. 

DOJ is responsible for the enforcement of 

numerous federal laws which impact people with 

disabilities. These laws include Title II of the ADA 

which applies to state and local governments. 

DOJ enforces the Civil Rights of Institutionalized 

Persons Act (CRIPA), which requires compliance 

with the rights of people residing in facilities such 

as intermediate care facilities and nursing homes; 

and Section 504 of the Rehab Act, which includes 

rights for people with disabilities similar to the 

ADA in regard to federal contractors, entities that 

receive federal financial assistance, and Federal 

Government agencies. Similarly, DOJ shares 

responsibilities with HUD to enforce the Fair 

Housing Act when certain cases are brought to 

federal court.131 For example, HUD CDBG funding 

is distributed though states to local governments 

and local programs. If HUD receives complaints 

of civil rights violations or other civil rights 

complaints, the agency can investigate and work 

with the state or local government to ensure that 

they are complying with the federal requirements 

and report noncompliance to DOJ. In these 

instances, interagency coordination is critical 

to ensure people with disabilities do not have 

long wait times for recovery support such as 

accessible housing.

Also, the U.S. HHS, under the Stafford Act, 

has a role in disaster response. But the relevant 

component, HHS Administration for Community 

Living (ACL), does not specifically work on 

disaster planning or emergency management. 

ACL primarily distributes grant money to 

nonprofit organizations. According to disability 

stakeholders, although the ACL provides funding 

support to nonprofit organizations, the agency 

has no enforcement ability and cannot ensure 

that funding recipients comply with disability 

law. Similarly, the U.S. Environmental Protection 

Agency (EPA) creates water and wastewater 

regulations and is responsible for oversight of the 

implementation of the Public Notification Rule 

(PN),132 which is part of the Safe Drinking Water 

Act (SDWA).133 The PN ensures that consumers 

will know if there is a problem with their drinking 

water. These notices alert consumers about risks 

to public health.134 Although the EPA creates 

and oversees implantation of the regulation, it 

is the states and public water systems that are 

responsible for meeting drinking water standards 

(including monitoring requirements) and notifying 

their consumers. If noncompliance is found, the 

EPA can take civil administrative actions, which 

are nonjudicial enforcement actions in the form 

of a notice of violation or an order. If the violation 

requires judicial action, DOJ files a case on behalf 

of the EPA.135 Although DOJ can file civil judicial 

actions against noncompliant states and entities, 

settlements may take years, leaving people with 

disabilities without basic access to programs 

and supports such as to accessible shelter and 

housing.

Rather than rely on litigation, federal agencies 

administering federal disaster grants must better 

coordinate across agencies and with disability 

rights organizations to identify ways to track and 

The Impacts of Extreme Weather Events on People with Disabilities 41
monitor noncompliance with federal disability 

laws. Proper enforcement of federal disability 

laws means redefining enforcement during all 

phases of the disaster life cycle, including (and 

especially) the preparedness phase. It is critical 

that enforcement includes a new approach to 

disaster with a greater emphasis on universal 

design—one that includes people with disabilities 

and implementation/enforcement of disability 

laws before disaster strikes.

Recommendations

■ Congress should request the Government Accountability Office (GAO) commission a study 

of which states have developed and maintain state-level emergency management plans 

and guidance that fully integrate people with disabilities.

■ DOJ, in coordination with other relevant federal agencies, should provide updated 

comprehensive guidance (similar to its 2022 new Guidance on Web Accessibility136) and 

technical assistance to SLTT governments to better comply with federal civil rights and 

disability laws during emergency preparedness, response, and recovery.

■ DOJ should reissue its Advance Notice of Proposed Rulemaking regarding 

Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services 

of State and Local Government Entities.

■ DOJ Disability Rights Section (DRS) should update the ADA Best Practices Tool Kit for 

State and Local Governments (March 9, 2017)137 to ensure that SLTT governments have the 

latest information on ADA best practices.

■ Department of Homeland Security (DHS) Civil Rights and Civil Liberties (CRCL) and/or DOJ 

DRS and other appropriate governing bodies should prioritize and strengthen oversight and 

enforcement capabilities to ensure recipients and sub recipients of federal funds comply 

with the scope of their obligations to people with disabilities.

■ DHS CRCL and DOJ DRS, should provide guidance to SLTTs emergency management 

operations frontline efforts to ensure nondiscrimination in the provision of emergency and 

disaster-relief services, benefits, and activities.

42 National Council on Disability
Chapter 2: Healthcare

T

he global mortality rate of people with 

disabilities in natural disasters is up to 

four times higher than that of people 

without disabilities.138 People with disabilities 

face dangerous levels of isolation, squalid living 

conditions, shortages of food and water and 

electricity, and permanent dislocation.139 This 

is due to a combination of factors, including a 

scarcity of inclusive planning, lack of accessible 

disaster information, early warning systems 

that do not reach everyone, lack of accessible 

transportation, and 

discriminatory attitudes 

toward people with 

disabilities.

Extreme weather 

events such as extreme 

heat, flooding, severe 

storms, tornadoes, winter weather, wildfires, 

and hurricanes, and environmental hazards 

negatively impact communities in the U.S. and 

its territories. everyone is vulnerable to health 

impacts associated with extreme weather 

events, however, people with disabilities or with 

preexisting physical, behavioral, or chronic health 

conditions are disproportionately impacted.140

According to HHS Climate Action Plan (2021), 

other susceptible groups include communities 

of color, older adults, children, pregnant women, 

people with lower incomes, and those who live 

or work in areas with greater exposure, such 

as people with outdoor jobs.141 Additionally, 

individuals affected by poverty, communities near 

contaminated waste sites or industrial areas, and 

rural areas with limited health systems may be 

more impacted by extreme weather events.142 The 

health effects of extreme weather are worsened 

when events disrupt critical infrastructure.143

Extreme weather events can damage roads, 

bridges, and transportation systems disrupting 

access to hospitals, pharmacies, and healthcare 

services. Extreme 

weather events can 

interrupt utilities, (e.g., 

power), water and 

wastewater services, 

and communications 

systems (e.g., Internet, 

telehealth, and other communications systems) 

that people with disabilities rely on to maintain 

access to health care.144 Research shows 

that serious health risks can arise from utility 

outages; infrastructure and housing damage; 

and disruption or loss of access to sanitation, 

safe food and water supplies, health care, 

communication, and transportation.145 Disruption 

of essential infrastructure and services after 

extreme events can increase population exposure 

to health hazards and reduce their ability to 

adapt.

The global mortality rate of people 

with disabilities in natural disasters 

is up to four times higher than that 

of people without disabilities.

The Impacts of Extreme Weather Events on People with Disabilities 43
Hurricane Maria’s Impact on 

Puerto Rico

In 2017 during Hurricane Maria, Puerto 

Rico experienced a significant loss of basic 

infrastructure including electricity and access 

to food and clean water. Hurricane Maria cut 

nearly all communication across the island 

and destroyed the power grid.146 “The storm 

disrupted medical services across the island 

and many households were left for weeks 

without water, electricity, or cell phone 

coverage. The average household went 

approximately 41 days without cell phone 

service, 68 days without water, and 84 days 

without electricity following the storm. More 

than 30 percent of surveyed households 

reported interruptions to medical care. 

Trouble accessing medications and powering 

respiratory equipment was the most cited 

challenge.”147

Emergency response actions can impact 

an individual’s physical health by injuries and 

premature death and a person’s mental health 

due to trauma or displacement.148 People with 

disabilities are among 

the most vulnerable in an 

emergency, sustaining 

disproportionately high 

rates of morbidity and 

mortality; they are also 

among those least able 

to access emergency support.149

Other impacts from extreme weather and 

climate-related events include a reduction in the 

availability of safe drinking water; a threat to food 

safety, nutrition, and distribution; waterbornerelated illness; vector-borne disease (transmitted 

through insects and pests); and poor air quality150

which increasingly threaten the health and wellbeing of people, particularly populations who are 

already vulnerable.151 Extreme weather events 

have immediate and long-term impacts on people

with disabilities and their caregivers as they 

disrupt access to health care, housing, education, 

employment, community, and other facets of life.152

Preparedness

An Increase in People with Disabilities

The World Health Organization (WHO) reports that 

the number of people with disabilities is increasing 

globally. The increase is due to demographic 

trends including an aging population,153 increases 

in chronic health conditions,154 increasing 

poverty,155 and the disabilities caused by 

COVID-19.156 According to the CDC, in 2020, 61 

million adults in the United States live with a 

disability—that is 26 percent of, or one in four, 

adults.157 This is compared to just three years 

before, in 2017, where people with disabilities 

made up approximately 12 percent of the U.S. 

working-age population.158 The CDC reports that 

disabilities are especially common in older adults, 

women, and people 

from diverse cultures 

or backgrounds.159 An 

increase in the number 

of people with disabilities 

will strengthen the need 

for accessible healthcare 

services and providers. It will increase demand on 

resources and strain critical systems, including the 

healthcare system, and emergency management 

agencies. In 2022, half of people with disabilities 

An increase in the number of people 

with disabilities will strengthen 

the need for accessible healthcare 

services and providers.

44 National Council on Disability
were age 65 and over. Overall, women were 

slightly more likely to have a disability than men, 

partly reflecting the greater life expectancy of 

women. In 2022, the prevalence of disability 

continued to be higher for Blacks and Whites than 

for Hispanics and Asians.160

Older Adults with 

Disabilities

The number of adults 

over age 65 in the United 

States is estimated 

to reach 80 million (or 

over 20 percent of the 

U.S. population) by 

2040 and nearly 95 million by 2060.161 With age, 

disability becomes more common. The increase 

in the older adult population with disabilities will 

increase demand for resources and services, 

including prescription medication, necessary 

medical equipment, and accessible healthcare 

facilities, support 

services, and caregivers. 

The increase in older 

adults will also put those 

who they care for at 

risk. Older adults often 

provide care to younger 

family members. In 2019, 

among the 5.37 million 

people with intellectual 

and developmental 

disabilities (IDD) living 

with a family caregiver, 

24 percent had caregivers who were age 60 

and older. In 2019, 19 percent of adults aged 

65 and older reported they could not function 

at all or had a lot of difficulty with at least one 

of six activities of daily living. The percentage 

reporting any level of difficulty varied. Specifically, 

22 percent reported trouble seeing (even if 

wearing glasses), 31 percent reported difficulty 

hearing (even if wearing hearing aids), 40 

percent reported trouble with mobility (walking 

or climbing stairs), 8 percent reported difficulty 

with communication 

(understanding or 

being understood by 

others), 27 percent 

reported trouble with 

cognition (remembering 

or concentrating), and 

9 percent reported 

difficulty with self-care 

(such as washing or dressing).162 In addition, 

older adults also tend to live in states with high 

disaster risk, such as coastal cities at risk for 

flooding or warmer climates at risk for hurricanes 

and wildfires (e.g., California, Florida, Texas, North 

Carolina), which puts them at heightened risk.

Chronic Health 

Conditions, Poverty, 

and “Long COVID”

The increase in older 

adults with disabilities 

and chronic conditions 

will increase demand for 

health care to address 

chronic conditions such 

as chronic obstructive 

pulmonary disease 

(COPD), emphysema, 

or chronic bronchitis or diagnosed and 

undiagnosed diabetes.163 Poverty increases the 

likelihood of disability. Chronically poor people 

are often at risk of ill health and injuries, which 

may lead to disability.164 Poverty is associated 

In 2019, among the 5.37 million 

people with intellectual and 

developmental disabilities (IDD) 

living with a family caregiver, 24 

percent had caregivers who were 

age 60 and older.

Poverty is associated with 

malnutrition, inadequate access 

to public health services (e.g., 

immunization), poor living 

conditions (e.g., lack of safe water), 

and environmental exposures (e.g., 

unsafe work environments), which 

can lead to health conditions which 

result in disability.

The Impacts of Extreme Weather Events on People with Disabilities 45
with malnutrition, inadequate access to public 

health services (e.g., immunization), poor 

living conditions (e.g., lack of safe water), 

and environmental exposures (e.g., unsafe 

work environments), which can lead to health 

conditions which result in disability.165 The poor 

who become disabled are likely to descend 

further into poverty, with a significant effect 

on their entire household.166 According to the 

CDC, some people who have been infected 

with COVID-19 can experience long-term 

effects from their infection, known as post 

COVID conditions (PCC) or “long COVID.” 

“Long COVID” is considered a disability 

under the ADA.167

An Increased Population Will Strain 

Emergency Management Capabilities

An increase in the number of people with 

disabilities will increase demand for federal and 

SLTT government emergency management 

capability and resources including accessible 

information; accessible evacuations; accessible 

transportation; accessible shelters; sign language 

interpreters; PCAs, access to durable medical 

equipment (DME) (e.g., oxygen equipment 

and accessories, wheelchairs); ATs; and other 

health supports. Emergency management will 

also require more human resources such as 

FEMAs Regional Disability Integration Specialists 

(RDIS) and other disability experts. People with 

disabilities are at increased risk to extreme 

weather events and coastal flooding because of 

their specific needs. Dependence on caregivers 

and others for assistance, and potential reliance 

on medical equipment that could be damaged or 

inoperable during power outages. Individuals with 

disabilities are likely to need special assistance 

during evacuations.

Public health agencies should create inclusive 

emergency preparedness and response plans 

that incorporate people with disabilities169

and disability organizations as stakeholders 

in inclusive health adaptation and disaster 

planning. EMAs should engage the disability 

community by using an all-hazards planning 

process that includes stakeholders from the 

disability community. Federal and state agencies 

should offer trainings that empower people 

with disabilities to participate in the disaster risk 

management process.

Evacuation challenges following 

Hurricanes Harvey, Irma, and Maria

In 2017, three sequential hurricanes—Harvey, 

Irma, and Maria—affected more than 28 

million people. Survivors aged 65 and older 

and those with disabilities faced particular 

challenges evacuating to safe shelter, 

accessing medicine, and obtaining recovery 

assistance. “A range of officials from entities 

that partner with FEMA—including states, 

territories, localities, and nonprofits)—reported 

challenges providing assistance to individuals 

who are older or have disabilities following 

the 2017 hurricanes. For example, officials 

said that many of these individuals required 

specialized assistance obtaining food, 

water, medicine, and oxygen, but aid was 

sometimes difficult to provide. Officials in 

Puerto Rico and the U.S. Virgin Islands cited 

particular difficulties providing this assistance 

due to damaged roads and communication 

systems, as well as a lack of documentation 

of nursing home locations.”168

46 National Council on Disability
Limited Data on Extreme Weather 

Impacts on People With Disabilities

There is limited research and data at the 

national and local levels documenting the 

impacts of extreme weather events on people 

with disabilities. Data collection is key to 

creating a clearer picture of how extreme 

weather events impact people with disabilities 

and the specific vulnerabilities of people with 

disabilities to environmental justice issues. 

Reliable data serve as a starting point for 

developing better policies, programs, and 

initiatives to support people with disabilities. 

Data can help SLTTs better understand 

the needs of their 

communities to better 

prepare, respond, and 

support people with 

disabilities as they 

recover from disasters. 

Historically, there has 

been a lack of data on 

disability.170 Federal and 

state healthcare data 

collection practices fail 

to capture baseline information about functional 

disability status of patients, leaving people 

with disabilities uncounted during and after 

emergencies.171 The U.S. Census Bureau ACS172

does provide disability data across a wide 

range of variables and geographies. In fact, the 

ACS provides county-level disability data for 

variables such as gender, race, veteran status, 

poverty status and employment for people with 

disabilities. However, according to a University 

of Montana Rural Institute report (2017),173 the 

ACS data “is not without limitations.” The ACS 

provides data estimates for disability in rural 

counties and estimates are drawn from smaller 

sample sizes, resulting in higher margins of 

error. These high margins of error make data 

less reliable at smaller geographies and forces 

researchers to aggregate the data to increase 

data validity. This limits the ability to analyze 

county-level disability data, particularly for 

subgroups like race and ethnicity.174 Other 

concerns previously raised about ACS data 

included the ability of the question sets to 

adequately represent the population with 

disabilities, because the data do not capture 

all those eligible for certain benefit programs 

such as Social Security Income/Social Security 

Disability Insurance (SSI/SSDI).175 Disability 

stakeholders stated that 

data should account 

for where people 

with disabilities are 

clustered. For example, 

Gallaudet University 

in Washington, DC, 

has a Deaf community 

where students live and 

learn using American 

Sign Language (ASL). 

Convening participants said that data sets 

often do not include all disability types. For 

example, Deaf individuals are excluded from 

phone surveys; Deafblind individuals, multiply 

marginalized people with disabilities, or those 

who are in carceral or institutional settings or 

are unhoused are often not included in data 

collection or research studies.

In our 2021 Progress Report: The Impact 

of Covid-19 on People with Disabilities,

176

NCD reported that the COVID-19 pandemic 

exposed gaps in disability data collection 

and antidiscrimination laws that need to be 

rectified before the next pandemic or public 

Federal and state healthcare 

data collection practices fail to 

capture baseline information 

about functional disability status 

of patients, leaving people with 

disabilities uncounted during and 

after emergencies.

The Impacts of Extreme Weather Events on People with Disabilities 47
health emergency.177 The report stated that a 

decades-long dearth in the collection of detailed 

disability and functional status information 

has left people with disabilities overlooked. 

The report also noted that there is a complete 

lack of standardized or historical gathering of 

death rates among LTCFs,178 and that disability 

status is not a recognized component of 

mortality data. The report points to the need 

for state collection of healthcare demographic 

data relating to functional disability and HCBS 

use for all Medicaid enrollees, including better 

data collection across the full range of longterm care, group homes, and congregate 

settings licensed, certified, or approved by 

the state. Without these data and analyses, 

it is extremely hard to get a full picture of 

how much emergency Medicaid and other 

measures developed as a response to the 

pandemic benefited people with disabilities. 

It is even more difficult to see, for example, 

whether other populations within the disability 

community, such as Black or Brown people, 

face discernible compound discrimination.179

According to FEMA’s National Preparedness 

Report (2021)180 during initial response efforts of 

the COVID-19 pandemic, “GAO found that the 

Federal Government did not have a process to 

systematically define and ensure the collection 

of standardized data across relevant federal 

agencies and related stakeholders to support 

the response to COVID-19, communicate 

the status of the pandemic with citizens, or 

prepare for future pandemics.”181 Federal and 

SLTT government planning will benefit from 

more accurate data as extreme weather events 

increase in intensity and severity and as the 

number of people with disabilities increases. 

Policymakers can use improved disability data 

to promote the health and safety of this longunderstudied population.

The health staffing shortage is placing 

pressure on an already overwhelmed U.S. 

healthcare system by reducing access to 

healthcare providers, including DSPs. People with 

disabilities and chronic health conditions, and 

persons who rely on DSPs for day-to-day support 

are often more vulnerable to health complications 

and are disproportionately impacted by the 

shortages of healthcare and DSP. Without 

support, PWDs can experience decline in health 

status, face unnecessary hospitalizations due 

to compromised care, or have increased need 

for emergency services. Existing shortages in 

healthcare workers exacerbate risks to individuals 

who require immediate care during disasters and 

are not able to get the assistance they require 

and leaves those individuals and their caregivers 

with reduced support during and after disasters.

The growing shortage of DSPs that existed 

prior to the pandemic became worse during 

the pandemic. In our Progress Report: The 

Impact of Covid-19 on People with Disabilities

(2021),182 NCD reported that well before the 

pandemic, the direct care workforce was 

subject to frequent turnover and a shortage 

of providers who could supply personal care 

services.183 A Mercer report (2018)184 projects 

that by 2025 demand for healthcare workers will 

outpace supply. In its analysis of the U.S. health 

workforce, Mercer estimated that by 2025, 

there will be a shortage of 446,000 home health 

aides, nearly 100,000 medical and laboratory 

technicians, 95,000 nursing assistants, and 

30,000 nurse practitioners.185 Even in 2018, prior 

to the pandemic, this shortage was of concern 

to maintaining health care quality; it has since 

contributed to increases in doctors and nurses 

48 National Council on Disability
leaving their jobs, with 8 percent of doctors 

closing their practices altogether in 2020—an 

estimated loss of 16,000 practices. This reduction 

in healthcare providers amid the pandemic only 

worsened the shortage. Staffing shortages also 

further exacerbated the vulnerabilities of CCF 

residents and staff.186

The United States is 

also facing crisis-level 

shortages of life-saving 

medical supplies and 

pharmaceuticals, such 

as pain medications. 

Common classes 

of drugs affected by 

shortages include 

anesthesia medications, 

antibiotics, pain 

medications, nutrition and electrolyte products, 

and chemotherapy agents. Clinically, patients 

have been harmed by the lack of drugs or 

inferior alternatives, resulting in more than 

15 documented deaths.187 The sum of these 

shortages is placing an unprecedented strain 

on the U.S. health care 

system and impacting 

those who depend on it.

People with 

Disabilities 

and Healthcare 

Disparities and 

Barriers

People with disabilities experience decades of 

health care disparities and systemic barriers to 

healthcare and treatment. Compromised health 

makes people with disabilities more vulnerable 

to extreme weather events, which are likely 

to exacerbate existing health conditions and 

increase barriers to health care. Research shows 

that adults with disabilities are three times more 

likely than adults without disabilities to have 

heart disease, diabetes, cancer, or stroke.188 In 

our Health Equity Framework on People with 

Disabilities (2022), NCD reported that people 

with disabilities are 

“more than three 

times as likely to have 

arthritis, diabetes, and a 

heart attack; five times 

more likely to report 

a stroke, COPD, and 

depression; and more 

likely to be obese.”189

Adults with any level of 

hearing loss are three 

to five times more likely 

to have heart disease and are more likely to 

report fair or poor health compared to those 

who do not have hearing impairments.190 People 

with IDD have a shorter life expectancy than 

people without IDD.191 These underlying medical 

conditions put adults with disabilities at higher 

risk for severe infection, 

hospitalization, or even 

death. In addition, 

factors such as race and 

ethnicity, age, language, 

sex or gender, poverty, 

and low education can 

compound the effects 

of having a disability.192

These disparities are exacerbated if you are a 

person with a disability and a person of color. 

Studies have found that adults with disabilities 

in underserved racial and ethnic groups are 

more likely to report fair to poor health or that 

their health has worsened over the past year, 

In its analysis of the U.S. health 

workforce, Mercer estimated that 

by 2025, there will be a shortage of 

446,000 home health aides, nearly 

100,000 medical and laboratory 

technicians, 95,000 nursing 

assistants, and 30,000 nurse 

practitioners.

Compromised health makes people 

with disabilities more vulnerable to 

extreme weather events, which are 

likely to exacerbate existing health 

conditions and increase barriers to 

health care.

The Impacts of Extreme Weather Events on People with Disabilities 49
compared with people without disabilities in the 

same racial/ethnic groups and with non-Hispanic 

Caucasians with disabilities.193 Indigenous people 

in the United States also have an increased risk 

of chronic conditions including diabetes and heart 

disease. Many tribal nations may have limited 

access to clean water, a key component of 

infection control. In the 

Navajo Nation, about 15 

percent of the population 

does not have access 

to piped water in their 

homes.194 Older adults, 

as a result of chronic 

health conditions and 

limitations, experience 

general “frailty.”195

Women with disabilities 

are likely to receive poorer maternity care,196 and 

pregnant women with disabilities have a much 

higher risk for severe pregnancy- and birth-related 

complications, including 11 times the risk of 

maternal death.197

Extreme Weather 

Events Exacerbate 

Underlying Health 

Conditions

Extreme weather events 

exacerbate underlying 

health conditions, can lead to injury, illness, or 

death, and can have long-term adverse effects on 

mental health. People with disabilities are two to 

four times more likely to be injured or killed in a 

natural disaster.198 Extreme weather events can 

disrupt critical infrastructure, including roads and 

bridges, power/electricity, water and wastewater, 

communications systems, which are essential to 

maintaining access to healthcare and emergency 

response services. Limited access to healthcare 

services includes loss of access to hospitals and 

pharmacies, medication, oxygen, personal care 

assistance, and medical devices. Extreme weather 

events can limit access to food and water. People 

with disabilities, those with preexisting health 

conditions, are especially vulnerable to the health 

impacts of power outages 

due to their reliance on 

electrically powered 

medical equipment such 

as ventilators oxygen, 

BiPAP machines and 

power wheelchairs. 

Extreme weather 

often causes utility 

interruptions. Between 

the 2000s and the 2010s, 

the U.S. saw a 67% increase in significant power 

outages due to weather-related incidents. In 2020, 

U.S. electricity consumers experienced over eight 

hours of power interruptions on average, the 

longest interruption time since the U.S. Energy 

Information Administration began collecting data 

in 2013.199 Children with 

chronic illnesses who 

use medical equipment 

and services that require 

a functioning electrical 

power grid are also 

at significantly higher risk for poor outcomes 

after disasters. In rural communities, power and 

communications can take longer to restore after 

damage from an extreme event, placing people in 

rural communities at high risk.

Extreme temperature days, or days that are 

substantially hotter than the average seasonal 

temperature in summer, or substantially colder 

than the average seasonal temperature in 

Many tribal nations may have 

limited access to clean water, a key 

component of infection control. 

In the Navajo Nation, about 15 

percent of the population does not 

have access to piped water in their 

homes.

People with disabilities are two to 

four times more likely to be injured 

or killed in a natural disaster.

50 National Council on Disability
winter, cause increases in illnesses and death by 

compromising the body’s ability to regulate its 

temperature.200 Exposure to extreme temperature 

may result in more severe health responses 

or death because it exacerbates preexisting 

conditions, including cerebral, respiratory, and 

cardiovascular diseases, and because it has 

a greater impact on 

those who are taking 

prescription or other 

drugs that may affect the 

body’s ability to regulate 

its temperature.201

People whose disabilities 

are affected by 

temperature sensitivity 

or thermoregulation 

are negatively 

impacted by high 

ambient temperatures. People with spinal 

cord injuries (SCIs) are especially at risk 

during extreme weather, both hot and cold, 

because of their inability to control their body 

temperature.202 Socially vulnerable populations 

are disproportionately affected by extreme heat, 

particularly those who live with disabilities, 

communities of color, 

low-income individuals, 

individuals lacking a high 

school diploma, and 

populations 65 or older.14

These groups often 

live in areas with increasing childhood asthma 

diagnoses from climate-driven changes, higher 

labor hour losses from extreme heat exposure, 

and growing climate driven mortality rates.”203

High temperatures in the summer are conclusively 

linked to an increased risk of a range of illnesses 

and death.204 The National Weather Service 

(NWS) confirmed that extreme heat is now the 

leading weather-related killer in America. Rising 

temperatures pose an imminent threat to millions 

of American workers exposed to the elements, 

to students in schools without air-conditioning, 

to seniors in nursing homes without cooling 

resources, and particularly to disadvantaged 

communities.205 Extreme 

heat is linked to elevated 

emergency room visits, 

hospital admissions, and 

mortality for individuals 

with mental health 

issues, cardiovascular and 

respiratory complications, 

and other disabilities. 

Rising temperatures will 

lead to an increase in 

heat-related illnesses and 

deaths.206 Heat waves triple the risk of death for 

people with preexisting psychosocial disabilities. 

With continued warming, cold-related deaths are 

projected to decrease and heat-related deaths are 

projected to increase; in most regions, increases 

in heat-related deaths are expected to outpace 

reductions in cold-related deaths.207

Droughts are 

associated with reduced 

water quality and 

quantity; respiratory 

impacts related to 

reduced air quality; and 

mental health impacts.208 Long periods of record 

high temperatures are associated with droughts 

that contribute to dry conditions and drive 

wildfires in some areas. Wildfires are directly 

linked to air pollution. Wildfire smoke contains 

particulate matter, carbon monoxide, nitrogen 

oxides, and various volatile organic compounds 

People with disabilities, those 

with preexisting health conditions, 

are especially vulnerable to the 

health impacts of power outages 

due to their reliance on electrically 

powered medical equipment 

such as ventilators oxygen, BiPAP 

machines and power wheelchairs.

Heat waves triple the risk of 

death for people with preexisting 

psychosocial disabilities.

The Impacts of Extreme Weather Events on People with Disabilities 51
and can significantly reduce air quality, both 

locally and in areas downwind of fires.209 Smoke 

exposure and inhalation increases respiratory 

and cardiovascular hospitalizations; medication 

dispensations for asthma, bronchitis, chest 

pain, COPD, and respiratory infections; and 

medical visits for lung illnesses. Wildfires are 

associated with burns or other traumatic injury, 

and mental health impacts.210 Wildfires are 

also associated with hundreds of thousands 

of deaths annually. For people with disabilities, 

wildfires are especially dangerous because 

mobility limitations can make it difficult to 

evacuate in an emergency if accessible 

transportation is not available. During wildfires, 

people with disabilities often lose critical AT, 

tools, and devices.

Floods can cause power, water, and gas 

outages; disrupt transportation routes; pollute 

drinking water systems; damage homes, 

buildings, and roads; and cause severe 

environmental problems including landslides 

and mudslides.211 Flooding related to extreme 

precipitation, hurricanes, and coastal storms 

can lead to fatalities and serious injuries when 

people do not (or cannot) evacuate areas that are 

flooded.222 Flooding is also associated with mental 

health impacts; disease spread; contaminated 

water; and carbon monoxide poisoning related 

to power outages.223 People with disabilities who 

California Wildfires

During the 2017 California Wildfire season, there were 9,270 wildfires, the largest of which 

was the Thomas Fire.212 The wildfires led to mass evacuations, displaced over 100,000 

people, caused $12 billion in damages, exceeding the total losses from the previous 10 

costliest fires combined, and took 47 lives.213 People with disabilities struggled to receive 

evacuation information and find adequate transportation and shelter. In addition, professional 

caregivers were ordered to evacuate and unable to work.214 The fires burned rapidly and 

unpredictably, aided by strong winds.215 The speed and unpredictability of the wildfires 

quickly overcame communities while trying to evacuate.216 In California, most people rely on 

personal vehicles for evacuations because there is minimal public transportation for wildfire 

evacuees and some areas have little to no access to public transit.217 People with disabilities 

evacuating from rural areas face particularly steep challenges. In Northern California, many 

people with disabilities live in rural areas and lack the resources to evacuate during disasters. 

Roughly twice as many people with disabilities live in rural areas in Northern California 

versus the rest of the state, and they lack critical infrastructure for safe evacuations.218

After an evacuation occurs, there is still the risk of inhaling polluted air from wildfires. 

After the Thomas Fire, Ventura and Santa Barbara counties had extended periods of air 

quality categorized as “hazardous.”219 This led to an increase in hospital visits related to the 

dangerous air quality.220 While the impact of air pollution is usually temporary, underlying 

health conditions and long-term exposure can lead to severe impacts.221

52 National Council on Disability
live in flood zones, coastal areas, and drought 

prone areas face greater vulnerability to health 

impacts.224

Winter storms and severe thunderstorms are 

associated with traumatic 

injury and death; carbon 

monoxide poisoning 

related to power outages; 

hypothermia and frostbite; 

and mental health 

impacts.225 Freezing 

temperatures and winter 

storms leave people with 

disabilities and chronic 

health conditions without 

power for life-saving 

medical supplies and a way to charge ATs or other 

dependent devices. 

Limited Internet Access Puts 

Communities at Risk

People with disabilities in rural communities, 

U.S. territories, and tribal nations are less 

likely to have access 

to broadband and the 

Internet which limits 

access to national 

weather warnings 

and alerts and limits 

access to telehealth 

options. Limited access 

to the Internet puts 

these communities 

at a disadvantage 

before, during, and 

after disasters. Analysis of 2019 ACS data 

established that people with disabilities, 

Winter Storm Uri in Texas

According to the Disability Rights Texas 

report (2021),226 during Winter Storm Uri in 

Texas (2020), 75 percent of people surveyed 

lost power for 24 hours or longer (22 percent 

for 4 days or longer); 45 percent of those 

who lost power believed they were in 

danger; 80 percent lost water for 24 hours 

or longer (32 percent for 4 days or longer). 

The loss of power and lack of refrigeration 

resulted in spoilage of life-saving medication 

and food; lack of access to medications 

and in-home healthcare assistance; the 

inability to use breathing devices or mobility 

equipment that depend on electric power; 

and trauma impacting mental health.227

Case Study – Proximity to Pollution

A University of Texas at El Paso study 

observed that Houston neighborhoods 

located near pollution sources—like 

Superfund sites and hazardous waste 

facilities—were home to a significantly 

higher proportion of people with disabilities 

than the rest of the city. In addition, race, 

ethnicity, and age all further amplified 

these inequalities—people with disabilities 

of color and those aged 75 years or older 

both lived in even closer proximity to polluted 

areas, likely decreasing their quality of life.228

People with disabilities in rural 

communities, U.S. territories, 

and tribal nations are less likely 

to have access to broadband and 

the Internet which limits access 

to national weather warnings and 

alerts and limits access to telehealth 

options.

The Impacts of Extreme Weather Events on People with Disabilities 53
older adults, and people of color including 

Native Americans, Black, and Latino people 

lacked Internet access in higher proportions 

when compared to their White and Asian 

counterparts. In all groups between the ages of 

18 and 74, Native Americans (non-Latino) had 

the highest percentage 

of people without 

household Internet 

access. When grouped 

by age and disability, 

34 percent of people 

age 75 and older were 

without household 

Internet access, the 

highest percentage of all 

the groups.

According to a June 2021 AARP study, “rural 

residents are much more likely than suburban 

or urban residents to say that access to highspeed internet is a problem—more than half, 58 

percent, vs. about a third of urban and suburban 

residents.”229 About 14.5 million Americans live 

in areas without broadband Internet access, 

and the “urban-rural 

divide is vast. At the 

end of 2019, 17 percent 

of rural residents and 

21 percent who live on 

tribal lands lacked even 

the slowest definition 

of high-speed internet 

access compared with 

about 1 percent in urban 

areas, according to a Federal Communications 

Commission (FCC) report released in January 

2021.”230 The lack of reliable Internet access 

for many rural communities can mean limited 

access to healthcare, specifically telehealth. 

Telehealth can provide medical assistance to 

those who lack reliable transportation. Lack of 

transportation is a recurring problem for people 

with disabilities who live in rural communities or 

are sheltering in place during a disaster.

Tribal nations and Indigenous peoples are 

disproportionately 

vulnerable to the 

impacts of extreme 

weather events, 

due in part to their 

dependence on specific 

geographic areas for 

their livelihoods; unique 

cultural, economic, and 

political characteristics; 

and limited resources 

to prepare for, respond to, and recover from 

extreme weather hazards.231 The 2021 $1.2 

trillion Bipartisan Infrastructure Law232 allocates 

over $13 billion in new tribal infrastructure 

projects is the largest investment in tribal nation 

infrastructure projects. It includes $214 million 

to bring running water to 40 percent of Navajo 

families from the Navajo 

Utah Water Rights 

Settlement, $2 billion 

for a tribal broadband 

connectivity program 

to expand broadband 

Internet access, and 

$11.2 billion in grants 

for abandoned coal 

mine land and water 

reclamation projects. However, according to 

tribal stakeholders NCD spoke with, not enough 

progress has been made to improve Internet 

access on tribal lands, leaving tribes still at risk 

for the next disaster.

Native Americans (non-Latino) 

had the highest percentage of 

people without household Internet 

access. When grouped by age and 

disability, 34 percent of people 

age 75 and older were without 

household Internet access.

At the end of 2019, 17 percent of 

rural residents and 21 percent who 

live on tribal lands lacked even the 

slowest definition of high-speed 

internet access compared with 

about 1 percent in urban areas.

54 National Council on Disability
Assistive Technology, Durable Medical 

Equipment, and Electronic Equipment

Extreme weather events can interrupt utilities. 

Resulting power outages place people with 

disabilities, some who are power dependent 

and require AT or DME at a disproportionate 

health risk. These populations often have 

more health problems, medication needs, 

and/or limited mobility.233 As previously 

discussed, during a power outage people with 

disabilities lose access to medications, DME, 

and ATs. During a power outage, the lack 

of refrigeration can result in the spoilage of 

life-saving medications, such as insulin, which 

needs to be kept cold, impacting people with 

diabetes. Power outages mean the inability to 

use breathing devices or mobility equipment 

that depend on electric power.234 People who 

depend on electric medical devices235 (e.g., 

require oxygen equipment and accessories 

(ventilators), require heat to regulate their 

body temperature due to an SCI, require 

dialysis, or require power for wheelchairs 

are disproportionately at risk during a power 

outage.

People with spinal cord injuries as well as 

mental health disabilities on medication will find 

it difficult to regulate their body temperatures. 

Given the extreme uptick in summer 

temperatures and colder temperatures in the 

winter, provisions have to be available for people 

with disabilities who are unable to regulate 

their body heat, meaning portable generators 

to assist those who are power dependent in 

the winter and portable air-conditioning units 

available to those who are unable to access 

cooling stations.

The loss of power also means the loss 

of access to AT—that is, alternate and 

augmentative communication equipment, 

The Impacts of Extreme Weather Events on People with Disabilities 55
devices, strategies, tools, and supportive 

services that allow individuals to live in their 

homes. Mobile devices for accessing the 

Internet or receiving 

texts are generally the 

most common way 

information would 

be obtained during a 

power outage. Other AT 

products such as videoremote interpreting (VRI), 

transcription services, 

Communication Access 

Realtime Translation 

(CART), and assistive listening devices; or lowtech solutions such as communication boards; 

can assist individuals who are Deaf or Hard of 

Hearing by keeping them informed. However, 

loss of power makes it difficult to charge devices 

and disrupts services, rendering the devices 

useless.239

People with disabilities use AT to maintain 

their independence. A conservative estimate 

of 20 percent of the population age 60 and 

over require an assistive technology device 

leads to a worldwide estimate of at least 800 

million items being used by older adults with 

disabilities by 2050. During disasters, assistive 

products may not function properly or may be 

lost or damaged, increasing the likelihood that 

people with disabilities and at-risk populations 

face threats, vulnerabilities, and severe health 

complications.240 The loss of power can affect 

any assistive devices that need electricity, and 

backup batteries may not always be at hand. 

Medication access and pharmacy refills (or 

refrigeration for some types of medications) 

may also not be present after a disaster.241

According to disability stakeholders, people 

with disabilities require appropriate ATs but 

developers have struggled to get new ATs in the 

market due to lack of investment.

Recovery

Those Forced to 

Relocate Out of 

State Lose Access to 

Medicaid Services

People with disabilities 

forced to relocate out of 

state due to a disaster 

lose their Medicaid 

health benefits, which 

means a disruption in their health care regimen 

which includes access to medicines, medical 

services, and supports. During extreme weather 

Case Study – Winter Storm Uri in 

Texas, 2021

During Winter Storm Uri in 2021, 4.5 million 

homes and business were without power at 

its peak.236 Nearly 70 percent of Texans lost 

power at some point during the storm.237 In a 

Disability Rights Texas survey of 600 people 

with disabilities, 75 percent lost power for 24 

hours or longer.238 One resident lost power 

and heat, and was in danger because she can’t 

control her body temperature, stating “cold 

temperatures are more severe for a person 

with a spinal cord injury.” Another resident 

who lost electricity, struggled with utilizing a 

ventilator (via battery) because the humidifier 

was blowing cold air from the house into her 

lungs, “I could barely use it,” she said.

The loss of power also means 

the loss of access to AT—that 

is, alternate and augmentative 

communication equipment, devices, 

strategies, tools, and supportive 

services that allow individuals to 

live in their homes.

56 National Council on Disability
events, people with disabilities may lose access 

to proof of identification and medical records. 

They may also lose access to their medicines 

and medical services and supports. They may 

be separated from their AT and DME, increasing 

the risk of severe health complications. During 

recovery, people with 

disabilities who do 

not have access to 

medical records and 

other key paperwork 

will struggle to access 

healthcare, services, and 

programs because of 

limited knowledge and 

a complex application 

process. When an 

individual with a disability moves out of state, 

state supports rarely move with them. In the 

case of students, individual education plans 

do not transfer to new schools. In the case 

of adults, state-run Medicaid benefits do not 

transfer out of state.

The Centers for Medicare & Medicaid 

Services (CMS) issued (2021) a final rule “to 

strengthen Medicare 

by expanding access 

to certain durable 

medical equipment, 

such as continuous 

glucose monitors that 

increase diabetes 

treatment choices for 

people with Medicare. The Durable Medical 

Equipment, Prosthetics, Orthotics and Supplies 

(DMEPOS) final rule could help to improve 

accessibility, quality, affordability, empowerment 

and innovation.”242 According to disability 

stakeholders, Medicaid has historically had 

issues maintaining coverage when disaster 

survivors evacuate across state lines and the 

rule will need to be tested and updated over 

time to ensure that services are transportable

and can easily be transferred to new providers in 

the event of disaster.

DRMA, S.2646,243

would ensure that 

individuals receiving 

Medicaid, who are 

forced to relocate due 

to a disaster, are able to 

continue to access their 

Medicaid-supported 

services, making 

coverage transportable

across state lines for 

disaster survivors. DRMA would provide states 

with resources to support the Medicaid needs 

of individuals forced to relocate following a 

disaster. This legislation would designate an 

individual who resides in an area covered under 

a presidential disaster declaration as a reliefeligible survivor and allow them to continue 

to access their Medicaid services if they are 

forced to relocate to 

another state as a 

result of a disaster. 

DRMA helps states 

meet the needs of 

relief-eligible survivors 

through a limited-time 

100 percent federal 

match for displaced individuals and technical 

assistance and support to develop innovative 

state strategies to respond to an influx of 

out-of-state individuals. The bill also creates 

a grant to help states develop an emergency 

response corps to provide HCBS. The legislation 

People with disabilities forced 

to relocate out of state due to a 

disaster lose their Medicaid health 

benefits, which means a disruption 

in their health care regimen which 

includes access to medicines, 

medical services, and supports.

When an individual with a disability 

moves out of state, state supports 

rarely move with them. In the case of 

students, individual education plans 

do not transfer to new schools.

The Impacts of Extreme Weather Events on People with Disabilities 57
also guarantees a 100 percent federal matching 

payment for medical assistance to states in 

disaster areas.244

Extreme Weather Events Contribute 

to Mental Health 

Issues

Experiencing severe 

or repeated extreme 

weather events can 

contribute to anxiety, 

depression, and other 

mental health impacts. 

In the Strategy to 

Address Our National Mental Health Crisis, 

President Biden stated that “the U.S. faces 

an unprecedented mental health crisis among 

people of all ages. “Two out of five adults 

report symptoms of anxiety or depression.”245

Research has found 

correlations between 

disaster exposure and 

psychological distress. 

While a person with a 

disability experiences 

the same natural 

disasters as anyone 

else, the disaster 

is likely to exacerbate daily challenges and 

increase stress.246 The health impacts following 

Hurricanes Irma and Maria in Puerto Rico 

were wide ranging, and increases in anxiety, 

depression, and PTSD were widely reported.247

A study of wildfire survivors showed that 

10 to 30 percent developed diagnosable 

mental health conditions, including PTSD 

and depression.248 Another study found that 

children with disabilities that evacuated during 

the 2017 wildfire 

season exhibited stress, 

grief, emotional and 

behavioral reactions one 

year post-disaster.249

While wildfires have 

been causing stress, 

California has also been 

experiencing a shortage 

of mental health professionals.250 While it is 

well documented that wildfires contribute 

to physical health effects such as lung 

conditions like asthma, COPD, other respiratory 

conditions, and can be life-threatening, studies 

now show that air 

pollution resulting 

from wildfires can also 

contribute to mental 

health issues.251 There 

is limited mental health 

support after a disaster, 

and it is often not 

included in the planning 

process. Communities and organizations 

need structures in place to mentally prepare 

residents for disasters and after disasters, 

those organizations should include traumainformed responses.

The Durable Medical Equipment, 

Prosthetics, Orthotics and Supplies 

(DMEPOS) final rule could help 

to improve accessibility, quality, 

affordability, empowerment and 

innovation.

58 National Council on Disability

A study of wildfire survivors 

showed that 10 to 30 percent 

developed diagnosable mental 

health conditions, including PTSD 

and depression.
Recommendations

■ Congress should pass legislation such as the REAADI in Disasters Act to address gaps 

in meeting civil rights obligations to people with disabilities impacted by disasters. The 

bill would establish a research center to be defined in legislation, to conduct research to 

determine recommended practices for including people with disabilities and older adults 

in planning during and following disasters; Establish a “projects of national significance” 

program to increase the involvement of people with disabilities and older adults in the 

planning and response to disasters and identify strategies for reducing deaths, injuries, 

and losses to those groups as a result of disasters; Establish a National Commission 

on Disability Rights and Disasters that will provide recommendations on how to ensure 

effective emergency preparedness, disaster response, recovery, and community 

resilience efforts for people with disabilities and older adults; Establish Training and 

Technical Assistance Disability and Disaster Centers that provide comprehensive 

training, technical assistance, development of funding sources, and support to state, 

tribal, and local disaster relief; public health entities; social service agencies; and 

stakeholder groups.

■ Congress should appropriate funds to FEMA for the express purpose to advise SLTTs 

EMAs and state health departments to conduct reviews and update emergency 

management plans and guidance to prepare for an increase of people with disabilities. 

The plans should be data-driven, inclusive, and compliant with disability laws to ensure 

equal access including effective communication, evacuations, and shelters that provide 

accommodations and modifications to ensure the safety of people with disabilities.

■ HHS Office of Civil Rights (OCR) should develop additional guidance for healthcare 

providers to actively prepare and plan for an increase of people with disabilities requiring 

healthcare services during disasters.

■ HHS and the National Advisory Council on Innovation & Entrepreneurship (NACIE) should 

launch a multiagency national emergency management strategy to help states plan for an 

increase in the number of people with disabilities to mitigate risks during disasters.

■ Federal and SLTT EMAs and state health departments should request congressional 

funding to surge medical resources (equipment and supplies) for disasters.

■ HHS should provide guidance to SLTTs on standardized disability categories and levels to 

inform emergency management planning. The methodology should be used at all levels of 

government to ensure complete and consistent data collection.

(continued)

The Impacts of Extreme Weather Events on People with Disabilities 59
Recommendations: continued

■ Congress should require state collection of health care demographic data relating to 

functional disability and HCBS use for all Medicaid enrollees, including better data 

collection across the full range of long-term care, group homes, and congregate settings, 

licensed, certified, or approved by the state.

■ FEMA should resurrect the Interagency Coordinating Council to include the U.S. Census 

Bureau, CMS, and DOT, to identify methods to efficiently, collect disability information to 

identify how many people with disabilities are affected during specific disasters, where 

they live or work in the community, and whether they have HCBS needs. This information 

should be used to inform emergency management policies and anonymized data should 

be regularly updated and shared with SLTTs.

■ Congress should pass legislation to address the shortage of primary care doctors and 

other health care providers. The legislation should address shortfalls in the nation’s 

supply of health care providers and include inclusive recruitment for a diverse health 

care workforce, loan forgiveness that encourages health care providers to work with 

underserved populations, and other innovative targeted incentive measures.

■ Congress should provide funding to HHS for the Secretary to implement section 5307 

of the Patient Protection and Affordable Care Act. Funding section 5307 would allow for 

the development, evaluation and dissemination of research, demonstration projects, and 

model curricula for cultural competency, prevention, public health proficiency, reducing 

health disparities, and aptitude for working with people with disabilities, training for use in 

health professions schools and continuing education programs.252

■ FEMA, in coordination with SLTT Department of Public Works, should identify people with 

disabilities in the community at risk of heat-related illnesses and death and ensure such 

individuals have access to cooling stations. If, because of their disabilities they are unable 

to access cooling stations, portable air-conditioning units should be made available to 

mitigate the risk of heat-related illness or death.

■ HHS should commission a study to identify health disparities and gaps in access to 

healthcare in relation to extreme weather impacts on people with disabilities, older adults, 

tribal nations, and other impacted communities. HHS should also identify strategies to 

mitigate those gaps.

60 National Council on Disability
Recommendations: continued

■ State health departments, in coordination with state EMAs, should plan and track medical 

infrastructure and medical equipment and equipment stockpiles, (e.g., medications, 

generators, PPE, and necessary medical equipment like oxygen, dialysis machines, 

wheelchairs, and other DME) to ensure availability and distribution in a disaster, especially 

in U.S. territories.

■ HHS Office of the Assistant Secretary for Preparedness and Response (ASPR), when 

replenishing the Strategic National Stockpile (SNS), should coordinate with SLTT partners 

on available equipment that can be requested from the SNS and provide or update 

guidelines on how to request such equipment.

■ Congress should make R&D investments that promote assistive technology. This should 

involve: (a) Greater investments for R&D of accessible apps and devices to incentivize 

developers to create innovative technology, which can help people with disabilities 

enhance functional performance to improve outcomes in areas such as education, 

employment, and independent living. (b) Increase the R&D budget for NIDILRR, the 

Medical Research and Development Program. (c.) Provide funding to a federal unit such as 

the Administration for Community Living (ACL) to design and fund technical assistance on 

R&D for the technology industry to support accessible design of emerging technology. And 

(d) Provide funding to ACL to establish and expand peer support programs on accessible 

assistive technology. These programs could be provided through independent living centers 

and grassroots experts and should involve a community of practice platform for exchanging 

information and managing requests for peer consultation.

■ The Federal Energy Regulatory Commission (FERC) should work with utility companies to 

improve their power outage notification programs and create public awareness campaigns 

to build knowledge. They should improve power resiliency programs and enhance power 

restoration priority for people with disabilities who are power dependent. Additionally, 

utility companies should invest in portable generators to be made available to people with 

disabilities who are power dependent and unable to evacuate in the event of extended 

power outages.

■ Congress should pass the Disaster Relief Medicaid Act (DRMA). Upon passage, states 

should immediately implement DRMA to ensure that individuals who are eligible for 

Medicaid and are forced to relocate due to a disaster, are able to continue to access their 

Medicaid-supported services.

(continued)

The Impacts of Extreme Weather Events on People with Disabilities 61
Recommendations: continued

■ CMS should clarify and promote its new rules and regulations about replacing ATs and 

DME damaged or lost in a disaster.

■ FEMA should more broadly publicize its mental health programs and the Substance 

Abuse and Mental Health Services Administration (SAMHSA) Disaster Distress Helpline, 

which provide crisis counseling and support to people experiencing emotional distress 

related to natural or human-caused disasters. FEMA should monitor SLTTs execution and 

accessibility of its crisis care hotline and provide guidance as needed to ensure programs 

are accessible to all disabilities.

62 National Council on Disability
Chapter 3: Housing

People with disabilities face significant 

challenges securing affordable, accessible 

housing. The U.S. housing shortage, low 

vacancy rates, high prices, limited availability of 

accessible units, and 

increasing extreme 

weather events that 

damage or destroy 

homes are increasing 

risks for people with 

disabilities who are more 

likely to be low income 

and live in areas affected by disasters.

Poverty rates for people with disabilities is 

more than twice the rate of people without 

disabilities.253 Extreme weather events are 

exacerbating the 

housing crisis as 

disasters damage and 

destroy homes with 

increased frequency 

within the same 

community. People 

with disabilities are 

more likely to live 

in low-income areas

and areas affected by 

disasters, including flood zones where lowincome housing is often built. In the event of 

evacuation, some SLTTs offer a registration 

program for people with disabilities to register 

who may need assistance evacuating their 

home during emergency. However, the majority 

of these registries provide a false sense of 

hope for the person 

with a disability. The 

city of Houston had 

such a registry. During 

Hurricane Harvey 

less than 5 percent 

of registrants were 

contacted and even less 

were provided evacuation assistance.254 Some 

SLTTs operate special needs or medical needs 

shelters which are segregated from the general 

population shelters. These shelters are often 

underfunded, separates 

families, typically only 

allow one other person 

to accompany the PWD, 

are costly to run, and 

often do not have the 

amenities required to 

accommodate a PWD. 

After leaving shelters, 

people with disabilities, 

if their home is damaged 

or destroyed, often cannot afford to move to 

another location or rebuild without assistance 

and may be forced to return to an uninhabitable

People with disabilities are more 

likely to live in low-income areas 

and areas affected by disasters, 

including flood zones where lowincome housing is often built.

[T]he majority of these registries 

provide a false sense of hope 

for the person with a disability. 

The city of Houston had such a 

registry. During Hurricane Harvey 

less than 5 percent of registrants 

were contacted and even less were 

provided evacuation assistance.

The Impacts of Extreme Weather Events on People with Disabilities 63
home. In addition, there is a scarcity of 

accessible temporary housing and personal 

care assistance placing people with disabilities 

at an increased risk of institutionalization 

or homelessness. Finally, government 

assistance programs are complex, confusing, 

and sometimes inaccessible to people with 

disabilities.

Preparedness

The Shortage of Affordable, Accessible 

Housing is a Serious Concern

Living independently and as part of a 

community are goals shared by all families 

and an affordable, 

accessible home is 

key to achieving those 

goals. However, people 

with disabilities face 

significant challenges 

securing affordable, 

accessible housing. The 

U.S. housing shortage, 

low vacancy rates, 

high prices, limited 

availability of accessible units, and increasing 

extreme weather events that damage or 

destroy homes are increasing risks for people 

with disabilities who are more likely to be low 

income and live in areas affected by disasters. 

The White House “Housing Supply Action 

Plan” To Help Close the Housing Supply Gap 

in Five Years (2022) states that the housing 

supply shortfall is more than 1.5 million homes 

nationwide (2021).255 The low housing stock 

correlates with low vacancy rates. A U.S. 

Census Bureau report (2020) showed that the 

“national vacancy rate decreased from 11.4 

percent in 2010 to 9.7 percent in 2020.”256

In 2020, more than 37 million people were 

living in poverty, approximately 3.3 million more 

than in 2019.257 For adults with disabilities, 

the poverty rate is more than twice the rate 

of adults without a disability.258 These factors 

contribute to a housing affordability crisis for 

people with disabilities. Housing is the largest 

expense for families: more than 38 million U.S. 

households live in housing that they cannot 

afford.259 The Federal Government considers 

housing unaffordable if it costs more than 30 

percent of a household’s income. More than 

23 million people (in over 10 million low-income 

households) pay more 

than half their income for 

rent, often forgoing food 

or medicine to keep a 

roof over their heads. Of 

the 23 million,18 percent 

have a disability.260 As 

of July 2020, Census 

data shows that 13.8 

million adults in rental 

housing—one in five 

renters—report being behind on rent, with 

households of color reporting far higher rates of 

missed payments than the national average.261

One report showed that the average rent for 

a basic one-bedroom apartment is $1,063 per 

month, or about 128 percent of an individual 

with a disability’s income, leaving no money for 

food, transportation, and other necessities.262

Moreover, with the end of the eviction 

moratorium (August 26, 2021),263 4.2 million 

renters reported being at risk of losing their 

homes.

One report showed that the average 

rent for a basic one-bedroom 

apartment is $1,063 per month, or 

about 128 percent of an individual 

with a disability’s income, leaving 

no money for food, transportation, 

and other necessities.

64 National Council on Disability
In the United States, an individual living 

solely on SSI cannot afford a safe, decent 

apartment without rental assistance.264 But the 

available assistance is not enough. Of more 

than 10 million people (5 million households) 

who use federal rental assistance to afford 

modest housing, 25 percent (2.5 million) 

have a disability.265 Approximately 4.7 million 

noninstitutionalized 

people with disabilities 

who rely on federal 

monthly SSI have 

incomes averaging 

only about $9,156 per 

year, in other words, 

not enough to afford 

rent. Many people with an IDD live with aging 

caregivers (60 and older). As this generation 

of caregivers ages, their adult children with 

IDD may be at risk of institutionalization 

or homelessness.266 More than 397,000 

individuals live on the street or in shelters; 

many others in expensive institutions at 

a cost of $232 to $1,467 per person per 

day.267 Renters with disabilities struggle to 

find affordable and accessible homes. In 

18 percent of extremely low-income renter 

households, at least one adult member is a 

person with a disability. This accounts for over 

5 million households, which are likely to need 

accessibility features like grab-bars, extra-wide 

hallways, or entry-level bedrooms, further 

limiting their housing options. As of 2011, 

just 3.5 percent of all homes had these basic 

accessibility features.268 While homeowners 

and higher-income households can add such 

features, the lowest-income renters often 

cannot afford to do so. Thus, extremely 

low-income renters with disabilities often 

face severe difficulties in finding affordable, 

available, and accessible housing.269

Increasing Extreme Weather Events 

Exacerbates the Housing Crisis

As extreme weather events increase, they will 

damage or destroy more and more homes or 

make them uninhabitable. In 2021, about 1 in 

10 U.S. homes (or 14.5 

million homes) were 

impacted by natural 

disasters, totaling nearly 

$57 billion in property 

damage.270 People with 

disabilities are more 

likely because of their 

income, to live in areas affected by disasters. 

Unaffordable and insecure housing leaves 

In 2021, about 1 in 10 U.S. homes 

(or 14.5 million homes) were 

impacted by natural disasters, 

totaling nearly $57 billion in 

property damage.

Impact of Recent Disasters on 

Housing

Hurricane Harvey (2017) flooded 154,170 

homes in Harris County, Texas of which only 36 

percent had flood insurance.271 Hurricane Irma 

(2017) destroyed about 25 percent of homes 

in the Florida Keys.272 During Hurricane Laura 

(2020), Grand Isle, Louisiana took a direct hit 

with 100 percent of its homes damaged and 

nearly 40 percent were destroyed.273

California’s wildfire season (2017) burned over 

1.2 million acres, a 112 percent increase over 

the previous year, destroyed or damaged 

32,000 homes, and displaced 100,000 

people.274 The Marshall Fire in Boulder County, 

Colorado (2021) damaged or destroyed more 

than 1,000 homes and businesses.275

The Impacts of Extreme Weather Events on People with Disabilities 65
families less able to cope with extensive repairs 

or rebuilding after extreme weather events 

such as flooding or wildfires. As disasters 

increase, they will have devastating impacts 

damaging or destroying homes or making them 

uninhabitable.

Communities affected by extreme weather 

events are often impacted by multiple natural 

disasters in a relatively short period. In 2015 

and 2016, Harris County, Texas suffered four 

Presidential Declared Disasters before Hurricane 

Harvey (2017). The county was impacted by six 

Presidentially Declared Disasters in 10 years.276 In 

Fall 2020, two hurricanes hit Southwest Louisiana 

within a month, affecting working-class residents 

the most. Homes that survived the high winds 

of the first hurricane 

were damaged by the 

flooding of the second. 

In addition, the COVID-19 

pandemic limited private 

aid and public assistance, 

thereby slowing the 

recovery. Two months later, many families were 

still rebuilding, often living in rented trailers or 

tents as their homes were repaired by a limited 

supply of contractors.277

Section 504 Requirements For Federally 

Assisted New Construction

HUD’s 5 percent accessibility requirement for 

federally assisted new construction housing 

developments278 does not meet the needs of 

people with disabilities, who represent 25 percent 

of the population. The Section 504 requirements 

for federally assisted new construction279 state 

that all federally assisted new construction 

housing developments with five or more units 

must ensure that 5 percent of the dwelling 

units, or at least one unit, are accessible to 

people with mobility disabilities. An additional 2 

percent of the dwelling units, or at least one unit, 

must be accessible for people with hearing or 

visual disabilities. The project must also meet all 

Section 504 requirements in HUD’s implementing 

regulation.280 In the United States, of the 61 million 

adults with disabilities many require accessible 

housing, which includes such features as lowered 

kitchen counters and sinks, widened doorways 

to allow passage by persons in wheelchairs, and 

wheel-in showers. Currently, fewer than 200,000 

housing units in the United States are universally 

accessible, and only a fraction are affordable.281

Neither the aging population nor the impact of 

long COVID has yet to be realized. The need for 

accessible housing will 

increase because of our 

aging population and 

persons newly disabled 

from long COVID. The 

percentage of accessible 

houses must be 

increased to accommodate for the newly disabled 

as well as existing accessible units damaged by 

extreme weather events.

Tribal nations also face a shortage in 

accessible units. In the United States there 

are 574 federally recognized tribal entities (347 

federally recognized American Indian tribes 

within the contiguous 48 states and 227 federally 

recognized tribal entities within the state of 

Alaska).282 According to the U.S. Census, an 

estimated 24 percent of American Indians and 

Alaska Natives live with disabilities, compared to 

19 percent of the general population.283 According 

to tribal stakeholders NCD spoke with, in the 

Navajo Nation, housing is a top priority for people 

with disabilities. Although the Navajo Nation 

Currently, fewer than 200,000 

housing units in the U.S. are 

universally accessible, and only a 

fraction are affordable.

66 National Council on Disability
receives HUD funding, it does not meet the 

needs of the Navajo disability community.

Low-Income People with Disabilities in 

Flood Zones are at High Risk

In the United States, affordable housing units 

tend to be built in flood-prone and coastal areas 

leaving people with disabilities who may be 

low-income, unsafe, and at risk of environmental 

contamination, to contend with expensive 

reconstruction or homeless in the aftermath 

of a natural disaster. The sea level rise has 

increased the damage caused by hurricane 

storm surge flooding.284 Between 1990 and 

2000, affordable housing was often built in 

floodplains where property values are lower 

and developed for multifamily housing, mobile 

homes, and single-family housing in the very 

low-income neighborhoods. Harris County, 

Texas has an estimated 184,546 homes in a 

100-year floodplain; over 26 percent of these 

homes were affected by Hurricane Harvey 

(2017).285 Households of color are more likely 

to live in a floodplain, exacerbating inequalities 

after a disaster strikes and making it harder for 

these communities to recover.286 Some of the 

low-income complexes are privately-owned 

buildings with a U.S. Department of Housing 

and Urban Development (HUD) contract. The 

landlord receives payment from the government 

in exchange for renting to low-income tenants. 

During disasters, residents who are often 

recipients of housing vouchers, cannot afford 

to move to another location without a housing 

choice voucher.287 There appears to be limitations 

preventing individuals to be able to “transfer/

The Impacts of Extreme Weather Events on People with Disabilities 67
transport” their housing voucher to a new 

location leaving them no choice but to return 

to a property that may be un-livable. Some 

disability stakeholders suggested HUD issue 

“climate vouchers” for individuals whose home 

is damaged or destroyed in a disaster.

Scenarios like the one described above 

because of the increased prevalence of extreme 

weather events will also become more prevalent. 

In the United States, the frequency of coastal 

flooding has increased sharply over the last 

few decades, and rising sea levels indicate 

further acceleration. Estimates put 14.6 million 

properties at substantial risk of flooding (2020), 

and 7.1 million single-family homes and 253,000 

multifamily units under threat from storm 

surges, with a total reconstruction cost of $2.65 

trillion.289 The risk of coastal floods damaging or 

destroying low-income homes will triple over the 

next 30 years as rising tides and storm surges 

encroach on low-lying developed areas. By 2050, 

more than 25,000 affordable housing units are 

expected to see coastal flooding at least once in 

a typical year with the largest number of at-risk 

housing units in three states: New Jersey, New 

York, and Massachusetts.290 As extreme weather 

events increase and continue to impact lowincome people with disabilities living in flood 

zones, federal funding, including housing choice 

vouchers and CDBG, are needed. According to 

the Joint Center for Housing Studies at Harvard 

University’s “the State of the Nation’s Housing 

2020 Report,” “funding for Housing for Persons 

with Disabilities has been reduced by 43 percent 

over the decade and critical programs (e.g., 

CDBG funding down 34 percent in 2020) have 

lost funding.”291

Congregate Care Facilities (CCFs) Have 

Insufficient Evacuation Plans

Many states either do not prepare evacuation 

plans for CCFs, or requirements are not robust 

enough to ensure an actionable, executable

evacuation plan that maintains appropriate 

care during and after an evacuation. The 

reliance on CCFs for lower-income people with 

disabilities increases when housing expenses 

rise. The approximately 4.7 million people with 

disabilities who rely on SSI cannot afford to 

live in their own homes, even where homebased care might be available,292 and may live 

in CCFs. In addition, a large, aging population 

will continue to expand the need for accessible 

and integrated housing solutions and health 

care infrastructure.293 The pandemic highlighted 

Case Study

In 2018, tenants of Arbor Court Apartments 

in Houston, Texas filed a federal lawsuit 

against HUD and the owners of Arbor Court 

Apartments, an HUD-funded low-income 

rental housing project. After the complex 

had flooded several times, including in 2016 

and during Hurricane Harvey in 2017, the 

plaintiffs cited “dangerous,” “uninhabitable,” 

and “life-threatening” conditions. The City 

of Houston Fire Marshall deemed it a fire 

hazard. But tenants could not afford to leave 

without voucher assistance which HUD 

allegedly refused to provide. Several of the 

residents identified as living with disabilities. 

One resident, whose sole income was SSDI, 

was unable to move to a more secure, less 

flood-prone residence without the assistance 

of a housing voucher.288

68 National Council on Disability
the tragic impact of substandard conditions at 

CCFs and nursing homes, which are home to 

many of the most at-risk community members. 

The recent CMS Emergency Preparedness Rule 

was designed in part to increase the mitigation 

and preparedness activities of long-term care

facilities to reduce these risks.294 Assisted living 

communities are not regulated nationally like 

nursing homes. Instead, 

each state has its own 

laws, regulations, and 

licensing standards 

for assisted living 

communities. In some 

states, as many as 

25 hours of training 

are required for caregiving staff; other states 

have no training requirements. Even where 

states require robust, actionable evacuation 

plans, they have historically overcommitted 

resources, impacting the ability of all CCFs 

to execute their plans 

(e.g., multiple CCFs will 

have a contract with 

the same transport 

service that only has the 

capacity to evacuate one 

or two CCFs.

Response

Special Needs 

Registries Cause 

Confusion and Are 

Unreliable

Special needs registries (or emergency 

assistance) are not consistently used by local 

emergency management agencies, and create a 

false sense of security for people with disabilities 

that emergency responders will alert and inform 

them and ensure their safety during disasters. 

Some states do not have plans in place for how 

they will use registries and do not address that 

people with disabilities may move or may not 

be home during a disaster. Prior to disasters, 

people with disabilities can sign up on registries 

which are designed to identify individuals 

who may require special assistance during 

emergencies. Disability 

stakeholders said that 

people with disabilities 

expect that, during a 

disaster, individuals 

who have signed up on 

a registry can remain 

in their homes and 

state emergency responders will contact them 

and ensure their safety. In reality, when local 

municipalities are in the midst of a disaster, most 

municipalities have no plan on how to utilize the 

registry list to assist people with disabilities.

A GAO report (2019) 

found that295 Texas 

and Florida operate 

registries to help local 

governments prepare 

to assist residents 

with disabilities during 

evacuations and 

sheltering, but state, 

local, and nonprofit 

officials in those locations 

reported confusion about 

the registries limited effectiveness.

State officials in Texas created a state registry 

to provide local emergency management 

officials with information about the needs 

of community members with disabilities. 

According to representatives of state, local, and 

The pandemic highlighted the tragic 

impact of substandard conditions at 

CCFs and nursing homes, which are 

home to many of the most at-risk 

community members.

The Impacts of Extreme Weather Events on People with Disabilities 69

Special needs registries . . . are 

not consistently used by local 

emergency management agencies, 

and create a false sense of security 

for people with disabilities that 

emergency responders will alert 

and inform them and ensure their 

safety during disasters.
nonprofit agencies, it created a misconception 

among residents who thought being on the 

Texas registry guaranteed direct evacuation or 

transportation assistance. Prior to Hurricane 

Harvey, officials from Texas expressed concerns 

that confusion about the registry would lead 

to residents’ overreliance on public disaster 

services.296 People who registered with 

the State of Texas 

Emergency Assistance 

Registry (STEAR) 

erroneously assumed 

that by registering they 

would receive assistance 

during a natural disaster. 

It was quite the 

opposite, Texas’ purpose for the registry was 

to collect data to better inform SLTTs on the 

disability population in their jurisdiction. Very 

few STEAR registrants received assistance or 

wellness checks during or in the days following 

Hurricane Harvey.297

The state of Florida has a similar registry 

program. However, in addition to providing 

registrant data to local emergency managers to 

use as a tool for disaster 

preparation, their 

registry is also used to 

register people with 

disabilities for special 

needs shelters. Florida, 

by statute, requires special needs shelters 

and uses the registry to determine eligibility. 

Disability stakeholders assert that even though 

persons with disabilities registered for a 

special needs shelter, their names were never 

shared with the county and they were denied 

admittance.

Registries are managed by individual states 

and are not standardized across regions or the 

country. Registries do not guarantee assistance, 

such as accessible transportation to shelters.

Mass Population Shelters Are 

Underprepared for People With 

Disabilities

Some mass population 

shelters do not meet the 

accessibility needs of 

people with disabilities as 

required by law, breaking 

the trust of people with 

disabilities and increasing 

the risk to their safety 

during disasters. SLTTs are obligated to ensure 

equal opportunity for individuals with disabilities 

when providing mass care services.298 The 

Robert T. Stafford Disaster Relief and Emergency 

Assistance Act (Stafford Act) Section 308 

prohibits disability-related discrimination during 

disaster relief and assistance activities.299

However, mass population shelters are often 

not ADA compliant. Disability stakeholders 

reported that shelters 

are often set up in 

schools or houses of 

worship with basic 

design that may not 

physically accommodate 

people with disabilities, like wide aisles for 

navigation and accessible bathroom and bathing 

facilities. During Hurricane Florence (2019), 

Pender County, North Carolina, experienced 

more than 40 inches of rain, and officials 

opened shelters in four middle and elementary 

schools. The Pender County After-Action Report 

In reality, when local municipalities 

are in the midst of a disaster, most 

municipalities have no plan on how 

to utilize the registry list to assist 

people with disabilities.

70 National Council on Disability

Registries do not guarantee 

assistance, such as accessible 

transportation to shelters.
(AAR), identified areas for improvement, 

including developing shelter plans with roles 

and responsibilities, completing Red Cross 

site approval of primary pre-storm shelters, 

and developing a plan to manage special need 

citizens.300 Developing a plan to “manage special 

needs citizens” a.k.a. people with disabilities 

should not be an item that is consistently an 

item to address in an after action report.

Because of the inconsistencies of shelter 

access, people with disabilities often wait out a 

storm in their accessible homes than evacuate 

to an inaccessible shelter. Some feel that 

shelters marginalize people with disabilities. 

People with disabilities going to shelters should 

know that their needs will be met (e.g., they will 

be able to use the restroom, with or without 

assistance).

FEMA’s Mass Care/Emergency Assistance 

Pandemic Planning Considerations for State, 

Local, Tribal, Territorial and Nongovernment 

Organizational Planners, Providers and Support 

Agencies (2020) states that congregate 

sheltering facilities must ensure that facilities 

can accommodate people with disabilities, and 

provide support for household pets, service 

animals, and support animals. Messaging should 

be provided in various languages and forms to 

reach survivors with disabilities.301 Emergency 

managers and shelter operators should 

identify the disability-related needs of a shelter 

and make advance arrangements to meet 

The Impacts of Extreme Weather Events on People with Disabilities 71
those needs. EMAs must involve community 

members with a variety of disabilities in the 

advance planning process to ensure that their 

needs will be accommodated in the aftermath of 

a community disasters.302

Medical/Special Needs Shelters Are 

Underperforming

Medical and special needs shelters are often 

not fully accessible and fail to meet the 

needs of people with disabilities. They are 

often designed only for individuals who are 

power dependent, rather than for all people 

with disabilities. People with disabilities get 

separated from their family, friends, and 

neighbors when they enter ”special needs” or 

“special medical needs” 

shelters, who may not 

know when their loved 

one with a disability left 

the shelter or where 

they went.303

in 2007, DOJ 

instructed state and local governments in their 

ADA Best Practices Toolkit for State and Local 

Governments, Chapter 7, that “the ADA requires 

people with disabilities to be accommodated 

in the most integrated setting appropriate to 

their needs, and the disability-related needs 

of people who are not medically fragile can 

typically be met in a mass care shelter. For this 

reason, people with disabilities should generally 

be housed with their families, friends, and 

neighbors in mass care shelters and not be 

diverted to special needs or medical shelters.”304

FEMA estimates that more than 50 percent of 

individuals visiting disaster recovery centers have 

disabilities that limit their ability.305 As history 

has taught us and is discussed in more detail 

in NCD’s 2019 report, Preserving our Freedom: 

Ending the Institutionalization of People with 

Disabilities, stand-alone “special needs” shelters 

do not provide equivalent provisions to people 

with disabilities. When at least half of the shelter 

population may be people with disabilities, a best 

practice should be to ensure that mass shelters 

are accessible to all and not segregate people 

with disabilities.

Shelters Lack Supplies and Staffing

During a disaster, people with disabilities must 

bring their own medications and equipment 

to shelters and many have limited access to 

support staff, putting them at risk. Emergencies 

can strike quickly and 

force people to evacuate 

promptly. During 

disaster evacuations, 

people with disabilities 

may lose essential 

medications or assistive 

devices.306 Some private nonprofits have 

programs in place to replace lost medications 

and provide equipment for people with 

disabilities.

Historically, shelter operators fail to plan and 

meet the need for personal attendant services 

(PAS), attendant care services, and personal care 

services in shelters. Although PAS is required 

by federal law, this gap has persisted, leading to 

the denial of full and equal services307 increasing 

the risk of institutionalization to people with 

disabilities. In 2021, FEMA updated its Guidance 

on Planning for Personal Assistant Services in 

General Population Shelters and recommended 

that SLTTs incorporate PAS as a natural part of 

. . . [A] best practice should be 

to ensure that mass shelters are 

accessible to all and not segregate 

people with disabilities.

72 National Council on Disability
shelter preparations and that contracts for PAS 

services be established well before an extreme 

weather event.308

Shelter staff and FEMA personnel require 

additional training and resources to provide 

aid and assistance to people with disabilities. 

According to the GAO (2022) FEMA has 

faced long-standing 

challenges with its 

workforce staffing 

including providing 

timely, program-specific 

training.309 Staff who 

work in shelters must 

be trained on disability competency awareness 

to meet the needs in the field. FEMA previously 

offered a two-day disability integration course to 

its nonfederal partners but canceled the course 

in 2017. In 2018, FEMA required all staff to take a 

30-minute training on basic disability integration 

principles and offered targeted ‘just-in-time’ 

training to deployed staff. FEMA’s disability 

integration specialists 

are also critical to 

ensuring that people with 

disabilities are adequately 

supported.

People with 

Disabilities Face 

‘Institutionalization’ 

During Disasters

Due to a lack of accessible shelters, or when 

PAS care is not made available, people with 

disabilities are at risk of being institutionalized.310

While disability rights laws protect against 

people with disabilities from being placed in 

long-term care facilities, these requirements 

are often waived during disasters allowing for 

institutionalization. Emergency managers often 

consider hospitals and CCFs as appropriate 

locations for short-term housing for people with 

disabilities. Individuals may be placed in nursing 

homes, psychiatric institutions, assisted living 

facilities and other long-term care facilities. 

Oftentimes, this occurs 

when a person with 

a disability does not 

require medical care 

but just accessible 

facilities. When a shelter 

is not made accessible 

for all, it places people with disabilities at a 

higher risk of being institutionalized in order to 

attain the needed physical access or services 

required. Such institutionalization is detrimental 

to people with disabilities who were living 

independently and is also a violation of their 

civil rights. As NCD reported in Preserving Our 

Freedom: Ending Institutionalization of People 

with Disabilities During 

and After Disasters,

311

once someone is in 

an institution, they are 

likely to remain even 

after the threat of the 

disaster has passed. 

The DOJ ADA Tool Kit 

(2007) says “people 

should receive services 

in the most integrated setting appropriate to 

the needs of the person, and only persons 

who require the type and level of medical care 

that would ordinarily be provided by trained 

medical personnel in a nursing home or 

hospital” can be placed in a restrictive setting. 

Due to a lack of accessible shelters, 

or when PAS care is not made 

available, people with disabilities 

are at risk of being institutionalized.

While disability rights laws protect 

against people with disabilities 

from being placed in long-term 

care facilities, these requirements 

are often waived during disasters 

allowing for institutionalization.

The Impacts of Extreme Weather Events on People with Disabilities 73
However, HHS CMS issues waivers to these 

rules during disasters, allowing states to place 

people with disabilities in institutions. Some 

states to combat institutionalization have used 

Appendix K waivers to pay legally responsible 

relatives to provide care that is extraordinary

and is necessary in order to prevent 

institutionalization.312

HHS must approve 

the waivers for states to 

cover services that are 

ordinarily not covered.

Recovery

Federal Reimbursement Programs Favor 

Property Owners

Federal housing assistance programs favor 

individuals who own property. Individuals 

recovering from disasters will often require 

documentation to verify their eligibility, such 

as proof of homeownership and insurance 

information, to qualify for federal or other 

assistance. This 

requirement places a 

significant burden of 

proof on the applicant to 

prove home ownership 

if property records are 

destroyed in a disaster 

and limits assistance 

to those who rent. 

FEMA’s Individuals and 

Households Program (IHP) provides financial 

and direct services to eligible individuals and 

households affected by a disaster who have 

uninsured or underinsured necessary expenses 

and serious needs. Federal reimbursement 

programs use property tax data to determine 

property value, favoring homeowners and 

leaving out a huge population, including 

individuals with disabilities who often are not 

homeowners. In Puerto Rico, post Hurricane 

Maria, some individuals did not have titles 

or deeds to their homes, which created a 

significant barrier to 

receiving assistance.

Finding Accessible 

Housing PostDisaster is Difficult 

for People with 

Disabilities

Relocation creates challenges for people 

with disabilities, including separation from 

their support services and community and 

finding affordable, accessible housing. Some 

individuals have difficulty understanding FEMA’s 

IHP application process, including required 

documentation, supporting applications, and 

approval processes. Some low-income families 

do not qualify for disaster 

loans.

After a disaster, some 

individuals leave shelters 

to find their home has 

been destroyed and they 

must find accessible, 

safe housing which 

sometimes requires 

relocating. Individuals 

may land in temporary housing far from their 

support services and community. In addition, 

they may need to replace lost resources such 

as their DME or AT which may have been lost 

or destroyed. People with disabilities may need 

[O]nce someone is in an institution, 

they are likely to remain even 

after the threat of the disaster has 

passed.

This requirement places a 

significant burden of proof on the 

applicant to prove home ownership 

if property records are destroyed in 

a disaster and limits assistance to 

those who rent.

74 National Council on Disability
financial assistance, in the form of rental or 

relocation assistance or to replace assistive 

technologies.

Several federal assistance programs are 

typically activated to support large-scale disaster 

recovery. Unfortunately, these programs fail 

to provide needed assistance to the most 

vulnerable people. 

Through the Emergency 

Housing Voucher 

program, HUD can 

provide housing choice 

vouchers to local public 

housing authorities 

(PHAs) to assist individuals and families. As 

mentioned in an earlier section, there appears to 

be limitations preventing individuals to be able 

to “transfer/transport” their housing voucher 

to a new location requiring them to return to a 

property that may be unlivable.

FEMA IHP process allows FEMA, in 

coordination with states, 

to provide financial 

assistance and direct 

services to individuals 

and households that have 

disaster-related expenses 

and serious needs that 

cannot be met through 

other organizations 

and programs. 

However, FEMA’s IHP 

application process is complicated, may require 

assistance or AT that might not be available 

in the immediate aftermath of a disaster, and 

the approval process is lengthy, leaving people 

without housing and support for extended 

periods. Research has highlighted barriers 

faced such as lack of knowledge of disaster-aid 

processes, discomfort with these processes, 

and difficulty accessing disaster assistance 

facilities because of transportation, childcare, 

and work challenges.313 For some low-income 

individuals and families, FEMA’s IHP grants may 

not be enough to fund rebuilding (e.g., homes 

that have specific accessibility requirements) 

and HUD funding takes 

months or even years to 

reach families. A GAO 

report (2021), “found 

that FEMA requires that 

certain survivors first 

be denied a U.S. Small 

Business Administration (SBA) disaster loan 

before receiving certain Individual Assistance 

(IA) grants, and survivors did not understand and 

were frustrated by this requirement.”314 Some 

FEMA programs require applicants to complete 

the SBA application, even if the applicant does 

not want or cannot qualify for the SBA loan. 

Many applicants will fail 

to apply for SBA disaster 

loans, not realizing that 

the loan application is 

a prerequisite for most 

IHP programs. Disability 

stakeholders said, many 

lower-income families do 

not qualify for disaster 

loans, the FEMA IA 

grants are insufficient 

to fund rebuilding, and funding from HUD takes 

months or even years to reach families.

HUD CDBG-DR Programs Are Not 

Permanently Authorized

HUD’s Community Development Block GrantDisaster Recovery (CDBG-DR) programs are 

People with disabilities may need 

financial assistance, in the form of 

rental or relocation assistance or to 

replace assistive technologies.

FEMA’s IHP application process is 

complicated, may require assistance 

or AT that might not be available 

in the immediate aftermath of a 

disaster, and the approval process 

is lengthy, leaving people without 

housing and support for extended 

periods.

The Impacts of Extreme Weather Events on People with Disabilities 75
supplemental appropriations typically tied to 

a presidentially declared disaster. Unlike other 

recovery assistance programs administered by 

FEMA and SBA, CDBG-DR assistance is not 

permanently authorized leaving communities and 

people with disabilities 

waiting for years for 

accessible housing 

to be rebuilt. HUD’s 

CDBG program provides 

disaster recovery grants 

to rebuild areas impacted 

by extreme weather 

and provide crucial 

seed money to start the 

recovery process. The 

grants help states, cities, 

and counties recover 

from presidentially declared disasters, especially 

in low-income areas.

HUD’s CDBG Mitigation (CDBG-MIT) program 

funds can be used by grantees in areas impacted 

by disasters to carry 

out strategic and highimpact activities to 

mitigate disaster risks 

and reduce future 

losses. The CDBG-DR 

assistance can be used 

to help communities 

recover from disaster.315

This may include building 

accessible facilities in 

the community. CDBG 

MIT and DR, are not standing programs but 

supplemental appropriations tied to a specific 

disaster. CDBG-DR funds are appropriated by 

Congress in response to a specific disaster 

or series of disasters—there is no standing 

authority for HUD to grant DR funds without 

an act of Congress.316 Statutory requirements 

of CDBG-DR appropriations, recovery needs of 

grantees, and waivers 

granted by HUD may 

change from one disaster 

to the next, thus, 

causing grantees to seek 

clarifying guidance each 

disaster about which 

activities are covered 

by the funding. For 

people with disabilities 

who require accessible 

homes, schools, places 

of work and worship, 

waiting years is unacceptable. Reinvestment 

must be part of the disaster recovery process—

not only in getting people back into apartments 

and houses but in rebuilding accessible, habitable

communities. Restoring 

communities after 

disasters presents SLTTs 

opportunities to review 

accessibility standards 

and requirements and 

to update inaccessible 

public facilities and 

infrastructure. The 

recovery process is an 

opportunity to ensure 

that ADA and other 

disability laws, and federal rebuild standards 

are met and to build resilient communities 

accessible to all.

A GAO report (2021), “found 

that FEMA requires that certain 

survivors first be denied a U.S. 

Small Business Administration 

(SBA) disaster loan before receiving 

certain Individual Assistance (IA) 

grants, and survivors did not 

understand and were frustrated by 

this requirement.”

Statutory requirements of CDBG-DR 

appropriations, recovery needs of 

grantees, and waivers granted by 

HUD may change from one disaster 

to the next, thus, causing grantees 

to seek clarifying guidance each 

disaster about which activities are 

covered by the funding.

76 National Council on Disability
Recommendations

■ Congress should pass legislation to spur affordable housing production and measures to 

preserve existing homes so that people with disabilities can return to their homes post 

an extreme weather event as outlined in the White House Actions to Ease the Burden of 

Housing Costs. Doing so would expand and improve existing forms of federal financing for 

affordable multifamily development and allocate a percentage of the housing development 

units to be accessible to people with disabilities.

■ Congress should pass legislation to ease rising costs for renters and prospective 

homebuyers and encourage construction of new affordable and accessible housing units.

■ SLTTs should encourage the construction of universally designed accessible units by 

passing universal design ordinances that go beyond the ADA and require that builders offer 

accessibility features to buyers as upgrades.317

■ HUD should increase the number of accessible units from the 5 percent accessibility 

requirement for federally assisted new construction housing developments to 25 percent, 

which represents the percentage of people with disabilities in the United States.

■ HUD Office of Public and Indian Housing (PIH) should expand its housing voucher 

program318 to offer climate vouchers for families affected by extreme weather events to 

relocate in the event their home is not habitable.

■ HUD should initiate a policy that will not approve funding of federal financed housing in 

floodplains.

■ HUD should require developers use materials that are more resilient to extreme weather 

events indicative of the area, for instance, metal shingles in California to mitigate wildfires, 

or a safe room in units designed for people with disabilities that should withstand high 

winds from hurricanes or tornadoes.

■ HUD should establish and implement a Federal Flood Risk Management Standard 

(FFRMS); update/modernize HUD’s floodplain management regulations in 24 CFR part 55; 

extend increased flood protection across all HUD programs; increase flood resilience; and 

clarify processes and standards, and promote environmental justice concerns in floodplain 

decision-making.

■ CMS should examine and consider changes to emergency preparedness plans to bolster 

the resiliency of the health care sector as part of an administration-wide effort to be ready 

for the next weather-related emergency.

The Impacts of Extreme Weather Events on People with Disabilities 77
Recommendations: continued

■ HHS ASPR should require that states develop written emergency evacuation plans and 

response procedures for CCFs that include situation assessment and plans for protecting 

residents, staff, volunteers, visitors, equipment, medications, and vital records as part of 

the states’ assisted living licensing and regulation requirements.

■ No federal funds—including but not limited to federal funds from DHS and HHS—should 

be used in development, deployment, and maintenance of emergency “special needs” 

registries exclusively created for people with disabilities. Instead of registries, SLTTs 

should take an innovative, holistic, and inclusive approach to include people with disabilities 

in their overall emergency management plans.

■ SLTTs should develop/update shelter management plans with clear roles and responsibilities 

that fully integrate the needs of people with disabilities to meet legal requirements.

■ DOJ and HUD should monitor and enforce compliance obligations for emergency 

sheltering in a disaster consistent with emergency sheltering requirements under the 

Fair Housing Amendments Act. Whether the disaster shelter is considered transient or 

long-term, the rights of people with disabilities in these shelters should be seamlessly 

protected.

■ The federal entity (typically FEMA and DHS) providing funds ultimately received by local 

emergency management departments should require the participation of local staff in 

training on the scope of obligations under the Rehab Act.

■ HHS and DOJ should issue joint guidance and provide technical assistance to SLTTs and 

shelter planners on the ADA and other legal requirements as well as Crisis Standards of 

Care (CSC) requirements for all shelters.

■ SLTTs and emergency planners should involve people with disabilities and disability 

organizations in emergency evacuation planning, ensure that shelters are physically 

accessible, and provide guidance on post-evacuation residency for individuals with 

disabilities.

■ FEMA, SLTTs, and shelter providers should join private nonprofits to develop contingency 

plans to replace lost medications and DME equipment.

■ FEMA should continue outreach to SLTTs on the requirement to provide PAS in shelters 

and advise the importance of acquiring a contract for PAS services prior to a shelter 

opening and advise SLTTs of the proper method for reimbursement following disasters.

78 National Council on Disability
Recommendations: continued

■ FEMA, SLTTs and NGOs (e.g., the Red Cross or religious organizations) should provide 

adequate planning and training, to include disability cultural competency training and 

resources, including supplies and equipment, to staff working in shelters, health care 

professionals, first responders, and search-and-rescue teams to better support people with 

disabilities in shelters. Expand training to individuals and community groups and recruit, 

train, and provide clearance for volunteers with specific skill sets, such as interpreters, 

mental health professionals, counselors, behavioral therapists, and PCAs.

■ The FEMA Administrator should develop a plan for delivering training to FEMA staff 

that promotes competency in disability awareness. The plan should include milestones 

and performance measures and outline how performance will be monitored. (GAO 

Recommendation 6).319 The plan should include FEMA Disability Integration Cadre. NCD 

recommends FEMA should ensure its emergency management workforce receives formal 

training on guidance related to supporting people with disabilities prior to their deployment 

in a disaster response role.320 FEMA should lengthen its two-hour course (IS-368: 

Including People With Disabilities and Others With Access & Functional Needs in Disaster 

Operations (2014))321 and ensure that people with disabilities are consulted during course 

development.

■ SLTT EMAs should ensure that shelter staff receives specific training to address the needs 

of people with IDD and mental/behavioral health issues.

■ FEMA should ensure emergency shelter providers plan for and ensure all shelters 

are accessible and compliant with the ADA and the Rehab Act to avoid the threat of 

institutionalization. Employing local disability organizations to collaborate on shelter 

operations will assist to ensure shelter facilities are more accessible to people with 

disabilities

■ HHS CMS should cease issuing waivers that allow people with disabilities to be 

institutionalized in the absence of accessible shelters and services. Absent an alternative, 

if waivers are issued, SLTTs should require EMA’s to immediately remedy or face severe 

penalties with a stipulation that the people institutionalized be moved into other accessible 

accommodations within a specified short timeframe or additional penalties will be applied.

■ HHS should approve Appendix K waivers for SLTT partners to pay legally responsible 

relatives to provide care during disasters.

The Impacts of Extreme Weather Events on People with Disabilities 79

(continued)
Recommendations: continued

■ Congress should fund legislation to enable states to increase accessibility to HCBS and to 

expand access to assistive technologies in order to promote independence and community 

integration.

■ FEMA should revise and provide technical assistance in plain language to its IHP 

application process

■ which would include enhancing and publishing guidance for requesting and receiving such 

services and removing any challenges related to language accessibility, literacy, technical 

expertise, or disability and the prerequisite to apply for SBA disaster loans.322

■ Congress should permanently authorize HUD Community Development Block Grant 

(CDBG) funding or in the alternative, streamline the authorization process after a 

disaster so that subsidies reach recovering communities earlier, so rebuilding can begin 

immediately following a disaster.

■ HUD should authorize CDBG-DR and CDBG-MIT grants to be used toward long-term 

relocation of housing projects and other infrastructure including building in safer zones or 

retrofitting buildings to be more resilient to expected weather events. HUD should work 

with and offer guidance to local leaders to help community planning and development.

■ HUD should provide guidance to CDBG recipients of the requirement to comply with 

federal disability rights laws and require the incorporation of universal design in any rebuild 

to ensure accessibility for PWDs.

■ HUD should update its CDBG-DR Policy Guidance for Grantees (2019) and include 

references to people with disabilities and use the CDBG to advance equity, access, and 

inclusion.

■ FEMA should provide guidance and training to SLTT partners on the legal requirements for 

Functional Needs Support Services (FNSS) for general population shelters and the potential 

loss of shelter reimbursement funds and propensity for lawsuits should they not provide 

accessible sheltering.

80 National Council on Disability
Chapter 4: Employment

Extreme weather events disrupt access to 

employment for people with disabilities 

and yet there is limited public research 

and data about how disasters impact job rates 

for people with disabilities.323 Employees with 

disabilities are displaced at a disproportionate 

rate to people without disabilities outside of 

extreme weather events. The employment rate of 

people with disabilities is 19.1 percent compared 

to 63 percent of people without disabilities.324

During COVID, unemployment rates were 

12 percent for people with disabilities and only 

9.5 percent for people 

without disabilities.325

Employees with 

disabilities are 89 

percent more likely to 

experience an involuntary 

job loss than those 

without disabilities in the United States.326 Data 

shows people with disabilities are more likely 

to experience an involuntary job loss absent 

of extreme weather events. Extreme weather 

events disrupt the job market, therefore, it is easy 

to hypothesize that since the unemployment 

rate of employees with disabilities is consistently 

higher than those without disabilities. Extreme 

weather events exacerbate the unemployment 

rate of people with disabilities.

Preparedness

Measuring the Impact of Extreme 

Weather on Employment of People with 

Disabilities

Extreme weather events often involve temporary 

disruptions to the local economy through direct 

and indirect effects on local infrastructure, 

business structures, homes, and the workforce, 

and limit access to reliable employment. After 

a natural disaster, the labor demand tends to 

decrease because businesses are forced to close 

or relocate. Even businesses with long-term 

viability will have difficulty 

operating immediately 

after a disaster because 

of disruptions to the 

supply chain, power grid, 

communications, and 

other infrastructure.327

Businesses that are damaged in a disaster 

may take weeks or months to reopen or may 

never reopen due to many factors including 

the loss of customers. In 2017, the California 

Wildfires “destroyed or damaged more than 

10,000 structures in the state (destroyed 9,470, 

damaged 810), a higher tally than the previous 

nine years combined.” According to CalFire, “in 

terms of property damage, 2017 was the most 

People with disabilities are 89 

percent more likely to experience 

an involuntary job loss than people 

without disabilities.

The Impacts of Extreme Weather Events on People with Disabilities 81
destructive wildfire season on record in California 

at the time.”328 In 2012, Hurricane Sandy, which 

was one of the deadliest hurricanes to make 

landfall on the continental U.S., struck the 

northeastern region of the United States resulting 

in over $19 billion in losses and the deaths of 

at least 53 people in New York City. A decade 

later, New York City has 

rebounded. However, 

there is still a void as 

to the labor outcomes 

of people affected by 

Hurricane Sandy.329

Recent COVID-19 pandemic-related layoffs 

have disproportionately impacted people with 

disabilities. From March to April 2020, the 

number of employed working-age people with 

disabilities fell by 20 percent (950,000 people), 

while the number of employed working-age 

people without disabilities decreased by 14 

percent.330

One of the difficulties of measuring 

employment after a disaster is the inability 

to run standard surveys in disaster-affected 

areas.331 While there is some information about 

how the labor market and employment in 

general are impacted by natural hazards, and 

while DOL produces labor force statistics on 

people with disabilities, 

it is unclear whether 

there are Federal 

Government efforts 

underway to measure 

how extreme weather 

events impact the employment outcomes for 

people with disabilities. Although DOL tracks the 

impacts of disasters on people with disabilities 

in terms of employment, the agency primarily 

focuses on large disasters or crises, such as the 

COVID-19 pandemic and its economic impact. 

DOL does not track how individual disasters 

impact people with disabilities in terms of 

One of the difficulties of measuring 

employment after a disaster is the 

inability to run standard surveys in 

disaster-affected areas.

82 National Council on Disability
employment and it does not track real-time 

data. The limited data on how extreme weather 

impacts people with disabilities makes it difficult 

to measure and build capacity.

Recovery

Extreme Weather Events Exacerbate 

Mental Health Issues

Extreme weather events impact the labor 

market by loss of life, injury, and the evacuation 

of people to areas outside the disaster zone. 

After a disaster, individuals may require mental 

health support and other accommodations 

at work that were not previously required. 

Natural disasters can have cascading impacts 

on people with disabilities, further limiting 

employment opportunities Disasters can affect 

stress levels, labor productivity, and mental 

health. Disasters may lead to or exacerbate 

mental health issues. People who become 

unemployed after a disaster must take care 

of their basic life and safety requirements 

before seeking employment.332 It is critical that 

employees are educated and made aware of 

their rights, especially after a disaster. During 

disaster recovery, federal crisis counseling 

programs provide funding and infrastructure for 

individual states to administer and implement 

guidance. DOL provides information on available 

mental health services on its Office of Disability 

Employment Policy website at https://www

.whatcanyoudocampaign.org/psa-campaigns/

mental-health-psa/.

Displaced Employees Require Vocational 

Assistance Programs

People with disabilities displaced after a disaster 

may need access to assistance programs 

such as vocational rehabilitation (VR) services 

to find new employment. The Rehabilitation 

Services Administration (RSA) provides four 

programs that service people with disabilities 

to achieve successful employment outcomes. 

The VR Service Program and the Supported 

Employment Service (SE), both state formula 

grant programs; the American Indian Vocational 

Rehabilitation Service Program (AIVR); and the 

Demonstration and Training programs, which are 

discretionary grant programs with up to five years 

of competitive awards.333

Approximately 1.2 million youths and adults 

are served by the 100-year-old VR Service 

Program each year. The system is designed to 

assist people with disabilities, including those 

with the most significant disabilities, who have 

visual, auditory, physical, intellectual, and learning 

disabilities, and psychosocial or psychological 

disabilities, to achieve and maintain employment. 

The VR Service Program performance data 

from the last decade—FYs 2010 through 

2019—revealed that each year, there were 

approximately one million people with disabilities 

receiving VR services under an individual plan for 

employment.334

In our 2020 report, Progress Report on 

National Disability Policy: Increasing Disability 

Employment, NCD reported that, “historically, 

American Job Centers (AJCs) have been 

found to be physically and programmatically 

inaccessible to people with disabilities and 

not well coordinated with the other parts of 

the adult employment system,335 although 

several identified steps are being taken to 

remedy these barriers.” In its 2018 report, GAO 

found “some gaps exist in federal guidance 

intended to enhance coordination. Employers 

GAO spoke with cited challenges navigating 

workforce programs, yet few agencies reported 

The Impacts of Extreme Weather Events on People with Disabilities 83
documenting roles and responsibilities of 

the agencies they partner with to work with 

employers. While Education and the Department 

of Labor (DOL) have provided some related 

technical assistance, they have not provided 

examples of documentation of roles and 

responsibilities. GAO’s prior work has found 

that such documentation can help improve 

coordination by clarifying who does what in a 

partnership.”336 In addition to schools, VR, and 

Medicaid, the public workforce system also 

provides employment services to people with 

disabilities, albeit to a smaller share of selfidentified people with disabilities, through AJCs.337

Access to Transportation is Necessary 

for Returning to Work

The process of finding employment is 

significantly disrupted if the employee relies on 

accessible public transportation or paratransit. 

As mentioned in previous chapters, disruption or 

damage to critical infrastructure such as public 

facilities, roads, bridges, and public transportation 

systems limits options for people with disabilities 

to get to work. People with disabilities face 

significant obstacles to employment because 

accessible and affordable transportation often 

cannot be found.338 This obstacle is often 

exacerbated after a disaster. Lack of public 

transportation because of damaged infrastructure 

is a common barrier for people with disabilities to 

return to work.339

Employees staffing these services may also 

be displaced during disasters. Many businesses 

may not be able to recover no matter the amount 

of support. In this instance, employees should be 

provided support and job placement assistance 

for alternative employment. Displaced employees 

could benefit from job-search assistance or new 

training if needed.340

84 National Council on Disability
Recommendations

■ DOL Bureau of Labor Statistics should collaborate with the National Institute on Disability, 

Independent Living, and Rehabilitation Research to commission a study on how individual 

disasters impact people with disabilities in terms of employment and economic impacts.

■ Given the dearth of data on employment losses due to natural disasters, DOL should 

create a system to collect and share data on how individual disasters impact people with 

disabilities in terms of employment.

■ Rehabilitation counselors should work with disability program navigators (DPNs) (people 

trained to utilize the One-Stop Career Centers to help people with disabilities) to help 

navigate the web of career services.

■ Federal agencies and private sector employers should offer remote work as an option, 

especially after a disaster where people with disabilities who rely on public transportation 

may not have access to transportation or paratransit services.

The Impacts of Extreme Weather Events on People with Disabilities 85
86 National Council on Disability
Chapter 5: Education

Eighteen extreme weather events affected 

the United States in 2022 with losses 

exceeding $1 billion each.341 As these 

events have shown, extreme weather events 

affect communities, 

school districts, and 

institutions of higher 

education.342 Students 

with disabilities face 

extra risks and challenges 

to their academic, 

physical, and mental well-being when extreme 

weather events disrupt education. U.S. public 

schools provide special education services to 

more than 7.2 million, or 15 percent of all public 

school students343 ages 3 

to 21.344 Since 2017, more 

than 341 presidentially 

declared major disasters 

have occurred across 

all 50 states and U.S. 

territories,345 with 

devastating effects on 

K-12 schools, including 

those in socially 

vulnerable communities 

where disaster recovery is more challenging.346

During the 2018–2019 school year in California, 

more than one million students were impacted by 

school closures because of wildfires, specifically 

the Camp Fire (2018), which impacted more 

than 2,200 schools.347 After Hurricanes Maria 

and Irma (2017), Puerto Rican students missed 

an average of 78 days of school because of 

infrastructure damage 

and transportation 

disruption; the storms 

also accelerated 

declines in school 

enrollment. One year 

later, 1 in 10 students 

with special needs were still not receiving 

special education services.348 Hurricane Harvey 

impacted 181 school districts in Texas, including 

the Houston school district, one of the nation’s 

largest, with more than 

200,000 students.349

Hurricane Harvey kept 

1.4 million students out 

of public schools for at 

least one week.350

Nearly 1 in 10 U.S. 

schools are located in 

a floodplain, placing 

4 million students at 

risk of being flooded 

out of school.351 Students with disabilities face 

challenges during response and evacuation 

and disasters have long-term impacts on 

students’ physical and mental health, and on 

During the 2018–2019 school year 

in California, more than one million 

students were impacted by school 

closures because of wildfires...

After Hurricanes Maria and Irma 

(2017), Puerto Rican students missed 

an average of 78 days of school 

because of infrastructure damage 

and transportation disruption; the 

storms also accelerated declines in 

school enrollment.

The Impacts of Extreme Weather Events on People with Disabilities 87
academic outcomes. More research, data, 

and preparedness planning on how to protect 

students with disabilities during disasters is 

needed.

Preparedness

Students with Disabilities in Rural, 

Tribal, and Low-Income Areas

The special education system lacks resilience, 

or capacity to quickly 

recover, and students 

with disabilities living 

in rural, tribal and 

low-income areas are 

especially susceptible 

to educational disruption because the present 

shortage of special education professionals, 

which is exacerbated when an extreme weather 

event occurs.

Students with disabilities already face multiple 

and substantial barriers to accessing a quality 

inclusive education. Their education is resourceintensive, requiring access to specialized 

equipment, educators with unique training,352 and 

accessible transportation. 

Even before the 

COVID-19 pandemic, the 

United States was facing 

a nationwide shortage 

of qualified special 

education teachers and 

related service providers.353 Research shows 

that these shortages disproportionately impact 

students with disabilities, students of color, 

students from low-income backgrounds, and 

students from rural communities.354 Students in 

rural, territorial, or tribal areas may have access 

to just one occupational therapist,355 a single 

adapted school vehicle, or a few nurses capable 

of tending to specialized needs.356 If a disaster 

puts these assets out of commission, students 

lose services with no alternative.

Multiply Marginalized

Research shows that socially vulnerable groups 

are particularly susceptible to the adverse effects 

of disasters, such as increased housing instability, 

food insecurity, parental job loss, and social 

disconnection.357 In our 

2021 report, The Impact 

of COVID-19 on People 

with Disabilities,

358 NCD 

reported that many 

students with disabilities 

face additional barriers to equal educational 

opportunity as they are multiply marginalized.359

For example, students with disabilities are more 

likely to be low-income,360 are disproportionately 

Black,361 and may be in foster care or juvenile 

justice systems, or both. (About 32 percent of 

children in foster care have disabilities,362 and, 

as noted, up to 85 percent of children in juvenile 

detention have disabilities.) Disabled students also 

may be homeless363 and 

may be English language 

learners.364 Many 

experience intersectional 

discrimination based 

on disability, sex, race, 

ethnicity, and size. These 

additional burdens exacerbate the vulnerabilities 

of students already struggling with academics, 

behavior, planning, speech, motor skills, and other 

areas essential to long-term success.365 Because 

of their marginalization, parents of these children 

may not be aware of the required processes and 

procedures for securing services and accessing 

programs and opportunities.

Hurricane Harvey kept 1.4 million 

students out of public schools for 

at least one week.

Nearly 1 in 10 U.S. schools are 

located in a floodplain, placing 

4 million students at risk of being 

flooded out of school.

88 National Council on Disability
Poverty and Academic Impacts

In the United States, a higher percentage of 

children (18.3 percent) and individuals with 

severe disabilities (26 percent) live in poverty than 

does the population as a whole (13.3 percent; 

U.S. Census Bureau, 2006).366 A January 2022 

GAO report, Disaster Recovery: School Districts 

in Socially Vulnerable Communities Faced 

Heightened Challenges after Recent Natural 

Disasters, reported that most school districts 

that received key federal disaster recovery grants 

following 2017–2019 presidentially declared major 

disasters had elevated proportions of students 

from socially vulnerable groups.367

Academic 

achievement may be 

particularly disrupted 

by disasters in districts 

with high proportions 

of socially vulnerable 

students, including those 

with disabilities. One 

recent study found that 

lower-income school 

districts’ academic 

achievement tended to be adversely affected by 

natural disasters, whereas higher-income districts 

did not see extended declines in academic 

achievement.368 For example, one county 

education official noted that, over the last decade, 

school districts in his county had narrowed the 

gap between White and Hispanic students in high 

school graduation rates and college attendance. 

However, after natural disasters, both rates 

declined for Hispanic students.

Limited Research and Data

Limited research exists on the specific 

educational impacts of natural disasters on 

children with disabilities.369 We do know that 

globally, 86 percent of children with disabilities 

did not participate in national disaster 

management; thus, their fatality rates during 

disasters are 4.3 percent higher than those of 

children without disabilities.370 To impact policy 

on how to better prepare children with a disability 

in disasters data collection on the subject is 

needed. Although research has reported that 

children are particularly vulnerable to the impact 

of extreme weather events,371 few studies 

examined the impacts of extreme weather 

events on children with disabilities and their 

families and how disasters impact physical and 

mental health, and interrupt children’s educational 

achievement.

Few studies address 

how to support young 

people’s feelings 

regarding extreme 

weather events.372

Although some studies 

have examined the 

threats to children’s 

physical health, the 

psychological and mental health impacts of 

extreme weather events have been less wellresearched; however, evidence from extreme 

weather event disasters shows that they can be 

equally devastating. Impacts include significant 

increases in PTSD, depression and anxiety, 

sleep problems, cognitive deficits, and learning 

problems.373 Further, few studies have examined 

the intersection of psychological and mental 

health impacts of extreme weather events on 

children with disabilities and how they disrupt 

students’ academic achievement.

Research on and collection of high-quality data 

concerning children with disabilities is critical for 

One recent study found that lowerincome school districts’ academic 

achievement tended to be adversely 

affected by natural disasters, 

whereas higher-income districts 

did not see extended declines in 

academic achievement.

The Impacts of Extreme Weather Events on People with Disabilities 89
mitigation, preparedness, response, and recovery 

efforts related to disasters. Without research and 

data, the needs of children with disabilities fail 

to be included as an appropriate and significant 

part of nations’ overall discussion of disaster 

management planning.

In the United States, federal, and SLTT EMAs 

and school districts must improve processes 

for collecting data about and including children 

with disabilities and their families in disaster 

management planning. This means identifying 

and then eliminating the challenges faced by 

children with disabilities during disasters.374

These challenges could include the need for 

accommodations such as screen reader access 

to computers, or a sign language interpreter,375

during or after a disaster.

An accurate assessment of people with 

disabilities allows for a proper distribution 

of project resources and provides a greater 

understanding of inclusion needs to local officials. 

It may also be valuable to collect data following 

a disaster to better inform future prevention 

initiatives.376

States and Territories Face Special 

Education Funding Challenges

States and territories faced challenges acquiring 

specialized services and personnel needed to 

comply with federal IDEA requirements. IDEA 

Part B was designed to ensure that all children 

with disabilities are provided a FAPE377 in the 

least restrictive environment. However, many 

states and territories do not have nonfederal 

90 National Council on Disability
funding to cover the costs for these services and 

personnel.378 In addition, school districts have 

historically found it challenging to meet federal 

special education requirements after natural 

disasters. Section 504 of the Rehabilitation Act of 

1973 guarantees that no student “shall, solely by 

reason of her or his disability, be excluded from 

the participation in, be denied the benefits of, or be 

subjected to discrimination under any program or 

activity receiving Federal financial assistance.”379

Per Section 504, for students with disabilities 

who do not require special education services, 

school districts must provide students with 

disabilities with related aids and services (including 

reasonable accommodations) to meet their 

individual needs as adequately as students without 

disabilities.380 One way to 

meet FAPE requirements 

under Section 504 

is the creation of an 

individualized education 

program (IEP)381 per 

IDEA. An IEP includes details about the students’ 

education goals and the supports and services that 

student will receive to meet those goals.382

IDEA Continues to Be Underfunded

Multiple factors impact the quality of education 

provided to students with disabilities, including 

a school district’s access to funding. The lack 

of financial resources and the impact of natural 

disasters can delay recovery and directly impact 

educational services to all students, but especially 

for students with disabilities. Under the 1975 

IDEA legislation, the Federal Government 

committed to pay 40 percent of the excess cost 

of special education. However, that pledge has 

never been met, and current funding is at just 

15.7 percent. The Federal Government provides 

no additional funds to comply with Section 504. 

The IDEA Full Funding Act (S.3213)383—

bipartisan, bicameral legislation to ensure 

Congress’s commitment to fully fund IDEA—was 

reintroduced on November 16, 2021. It would 

require regular increases in IDEA spending, 

increasing direct support for public schools and 

students with disabilities so Congress can meet 

its commitment to schools and children and help 

provide every American student with a quality 

education.384 This legislation is imperative, as 

its passage would ensure ample funding to 

accommodate any additional students requiring 

special education services because of the impact 

of climate change on the student. According to 

the National Education Association, the IDEA 

nationwide shortfall 

in 2021 was $23.58 

billion.385 There is no non 

legislative mechanism to 

ensure that IDEA funding 

commitments are met 

and that additional funds are appropriated for 

compliance with Section 504 of the Rehab Act.

Response

Evacuation and Transferring Schools

For student disaster evacuees with disabilities, 

transferring between school systems presents 

unique challenges. Although there is limited 

data about these student transfers, what data 

is available provides information on population 

movements. Some estimates indicate that 

12 percent of the displaced students have 

disabilities.386 One of the most crucial challenges 

for disaster-recovery efforts is to continue the 

education of student-evacuees while rebuilding 

educational services.387

Some estimates indicate that 

12 percent of the displaced students 

have disabilities. 

The Impacts of Extreme Weather Events on People with Disabilities 91
Studies indicate that the average child requires 

between four and six months to “catch up” 

academically each time they transfer schools.388

Students with disabilities likely require even 

longer. First, families with students with 

disabilities may need 

extra time to secure 

accessible housing, 

meaning they may linger 

in shelters or require 

multiple transfers 

between school districts. 

Without secure housing, 

students may lack the 

residency documentation 

they need to register for school. Second, families 

may not have the educational records (e.g., IEPs, 

504 plans) for the supports and services the 

student requires in their new school district. The 

lack of records may require additional evaluations 

to determine a student’s eligibility, which may 

delay the provision of services. Finally, the new 

school district may require time to procure 

additional equipment or hire additional personnel, 

particularly troublesome if a student transfers to 

a rural, tribal, territorial, 

or low-income school 

district where resources 

are already scarce.

Recovery

Limited 

Functionality and 

Services After 

School Reopening

When schools reopen after an extreme weather 

event, limited school facilities and services can 

deny students with disabilities who remain 

in the disaster-affected district equal access 

to an education. Extreme weather events 

Studies indicate that the average 

child requires between four and six 

months to “catch up” academically 

each time they transfer schools. 

Students with disabilities likely 

require even longer.

92 National Council on Disability
can result in extensive damage to homes, 

education infrastructure, and transportation 

networks. School rebuilding and reopening 

tends to be prioritized by actions that help the 

greatest number of students and staff return 

to learning, which means students who have 

more specialized needs tend to be left behind. 

For example, some students require in-person 

services or supports such as physical therapy 

or behavior intervention strategies to receive 

FAPE.390 If a district’s Braille printer is damaged, 

blind students may not be able to read their 

schoolwork. School personnel who provide 

related services like occupational therapy or 

adapted transportation may be unable to return 

to work because of damaged homes or road 

networks, and schools may experience delays 

hiring new personnel for the same reasons.391

Legal guidance from the U.S. Department 

of Education (ED) OCR is clear: school districts 

owe compensatory services to students with 

disabilities who are denied FAPE, even for 

“situations outside of a district’s control or where 

the district is not at fault.”392 To ensure these 

students’ rights are protected, school districts 

must have a way of recording which services 

were not delivered and for how long, in order to 

provide appropriate resources for compensatory 

services. Guidance393 from ED (2017) recommends 

that IEP or 504 teams meet after a natural disaster 

to determine and document which services can 

and cannot be provided during the period of 

limited functionality, e.g., if trained and certified 

personnel are not available, or if a student cannot 

access school facilities or adapted technology. 

After full functionality is reached, school districts 

must assess students with disabilities for 

regression or loss of skills during the period of 

limited functionality, and these losses must also 

be accounted for during the determination of 

the type, duration, and amount of compensatory 

services. Finally, school districts must track delays 

in eligibility evaluations or starting new special 

education services or accommodations, so 

students can receive appropriate compensatory 

services for those delays.

Hurricane Maria’s Impact on 

Students with Disabilities in 

Puerto Rico

In 2017, Hurricane Maria, a Category 

5 hurricane, disrupted the lives of some 

350,000 Puerto Rican public school students. 

It took nearly five weeks before the first 

public schools began to reopen, though 

most were still operating without power. 

Since the hurricane, some schools have 

been converted into community centers and 

shelters, requiring students to relocate and 

find alternate routes to resume their studies. 

Economic trouble exacerbated by the storm 

forced the closure of 265 schools—roughly 

a quarter of all of the island’s public schools, 

affecting an estimated 60,000 students. 

These school closures had cascading impacts 

on 35 percent or ~103,318 students between 

the ages of 3 and 21 that receive special 

education services in Puerto Rico. One of 

these cascading impacts is that as of March 

2020, ~9,800 special education students did 

not have access to transportation, placing 

the burden on the parents to transport their 

children to school.389

The Impacts of Extreme Weather Events on People with Disabilities 93
In addition to this documentation following 

the extreme weather event, school districts 

should assess their risk factors for educational 

disruption and work with federal and SLTT 

governments to mitigate them. For example, 

some areas may have private service providers 

such as speech or occupational therapists who 

substitute temporarily for school personnel 

who are affected by extreme weather events. 

School districts should consider identifying and 

pre-contracting with these private providers to 

shorten the period during 

which special education 

services are disrupted.

School districts should 

consider making more of 

their transportation fleet 

accessible to students 

with disabilities. During 

disasters, available school 

buses are used as public 

transport rather than for 

schools. Having only a few accessible vehicles 

presents risk to disabled students.

Limited Special Education Staffing

There is a chronic shortage of special education 

teachers in the United States and replacing 

qualified educators after a disaster can be 

challenging. It has been noted that, after extreme 

weather events, some communities lack sufficient 

housing for educators and their families. Thus 

teachers, including special education teachers, 

cannot serve their students, compounding an 

already significant shortage of special education 

professionals.

Several studies have found special education 

teachers provide critical psychological support 

to children with disabilities and their families 

post-disaster, even when schools are closed 

and students have been displaced from their 

school districts.394 School districts must consider 

working with their state and local governments to 

prioritize educational staff 

for access to housing 

close to their schools.

Disruption to 

College-Aged 

Students

Extreme weather events, 

such as heat waves, are 

impacting college-aged 

students with disabilities. 

At the University of California, Los Angeles 

(UCLA), the growing number of heat waves is 

impacting students—either through the increased 

risk of wildfires or more difficulty in learning. 

UCLA’s campus is located near high fire hazard 

zones, according to data from the California 

Department of Forestry and Fire Protection. In 

2019, UCLA administrators canceled classes 

when the Getty Fire spread less than two miles 

from campus.

School rebuilding and reopening 

tends to be prioritized by actions 

that help the greatest number of 

students and staff return to learning, 

which means students who have 

more specialized needs tend to be 

left behind.

94 National Council on Disability
Recommendations

■ Congress should enact legislation to combat special education and rural teacher shortages 

across the United States and appropriate funding for programs to assist in recruitment of 

special education teachers.

■ Congress should require ED to conduct a study assessing the impact of extreme weather 

events on students with and without disabilities. The study should assess the physical, 

psychological, and mental health impacts of extreme weather events, the impact on 

academic achievement and utilize collected data to inform school districts in disaster 

management planning.

■ ED should commission a study to examine the impacts of extreme weather events and 

adaptation strategies on children with disabilities and their families. The study should include 

findings to support disaster planning.

■ Congress should take action to strengthen the safety net for socially vulnerable groups, 

such as students with disabilities, school staff with disabilities, and their families.

■ Congress should provide funding to ED to develop information technology standards 

for secure, interoperable electronic education records. These records must include the 

supports and services a student receives under IDEA and Section 504, and the standards 

must interoperate with electronic health record systems to allow school districts, students, 

and parents to access their IEPs, 504 plans, and supporting medical documentation. Once 

the information technology standards are established, ED should strongly encourage and 

provide technical assistance for local school districts to avail themselves of the technology 

to mitigate delays in special education services because of relocation or loss of records 

due to extreme weather events.

■ Congress should amend the IDEA funding formula to mitigate the high incidence of 

poverty in rural and low-income communities, including U.S. territories.

■ ED should collect standardized tracking and reporting of educational services and supports 

that are unable to be provided to students with disabilities during and after a disaster.

■ Congress should require ED to track and report on post-disaster compensatory services 

provided to students in any school district located in a presidentially declared major natural 

disaster area to better prepare and develop best practices for recovery after extreme 

weather events.

The Impacts of Extreme Weather Events on People with Disabilities 95
96 National Council on Disability
Chapter 6: Emergency Management

Emergency management planning is critical 

to prevent, protect against, mitigate, 

respond to, and recover from the extreme 

weather events that pose a risk to communities. 

As the scope, scale, and frequency of weatherrelated incidents increases, the capabilities of 

FEMA and SLTTs EMAs will be tested. Emergency 

management cannot be reactionary. Climate 

change directly impacts the frequency and 

intensity of natural disasters and our ability to 

ensure the safety of our communities. Building 

community-wide 

resilience to climate 

change through targeted 

mitigation investments 

and leveraging future 

risk data needs to be 

a primary focus for all 

levels of government and 

partners.395 Resilience cannot be achieved without 

equitable consideration for, and participation of, 

all community members. Ensuring equitable 

disaster risk reduction for all marginalized 

populations, including people with disabilities, 

should remain a high priority for emergency 

managers nationwide.396 People with disabilities, 

especially those living in underserved populations, 

are disproportionately impacted by disasters and 

more than ever, federal and SLTTs must include 

people with disabilities in all facets of emergency 

management to ensure that they can participate in, 

and benefit from, programs and services during all 

phases of emergency management.397

Preparedness

Concurrent Extreme Weather Events 

Pose Unprecedented Challenges to 

Federal Agencies and SLTTs

Concurrent extreme weather events pose 

unprecedented challenges to federal and SLTT 

EMAs, reducing capacity, testing capabilities, 

straining resources, 

and complicating and 

potentially delaying 

response and recovery 

efforts, all which impact 

people with disabilities. 

Concurrent disasters of 

unparalleled nature are 

becoming more common, and climate change will 

likely continue to increase disaster activity in the 

coming years.398 According to the DHS National 

Preparedness Report (2021), disasters are lasting 

longer, are increasingly complex, and are happening 

simultaneously. In 2020, the number of disasters 

that were either declared in, or still open at the 

end of the year made up almost 20 percent of 

all federally declared disasters since 1953.399 The 

increased severity, duration, and occurrence rate 

of climate-related disasters puts immense strain 

In 2020, the number of disasters 

that were either declared in, or still 

open at the end of the year made 

up almost 20 percent of all federally 

declared disasters since 1953.

The Impacts of Extreme Weather Events on People with Disabilities 97
on emergency responders. It continues to cause 

delays in recovery efforts which can take weeks, 

months, or even decades.400 At the height of the 

COVID-19 pandemic, the United States experienced 

an unprecedented number of disasters, including 

one of the most active wildfire seasons on record 

across the western U.S., a record of 30 named 

tropical storms and hurricanes, and severe weather, 

including hailstorms and flooding, across the 

Midwest.401 According to the CDC, 47 million 

people were impacted by Hurricanes Harvey, Irma, 

and Maria, and of those, an estimated 12 million 

were people with disabilities. Communities and 

individuals are impacted differently by disasters, 

which often magnify existing social and economic 

trends that drive inequities in recovery. As 

the frequency of natural disasters continues 

to increase, so does the disproportionate risk 

exposure to, and consequences for, individuals and 

communities who are likely to be rendered most 

vulnerable. Several factors, including poverty, lack 

of access to transportation, and crowded housing 

may weaken an individual and community ability 

to prevent financial loss, injury, and fatalities in a 

disaster.402 Concurrent disasters disproportionately 

impact people with disabilities. One of the myriad 

of reasons is the failure 

to provide reasonable 

accommodations in 

the form of supports 

and services during the 

recovery phase of a 

disaster.

Reducing Capacity

When concurrent disasters overwhelm a 

community’s capacity to provide critical services, 

state and federal resources may be available to 

support local emergency response and recovery 

efforts. When multiple large-scale incidents require

simultaneous support, however, state and federal 

capability may be strained, reducing capacity to 

enable ongoing recovery efforts and respond to 

additional incidents. In 

2020, the COVID-19 

pandemic, coupled with 

the active wildfire and 

hurricane seasons, taxed 

the capabilities of the 

emergency management 

community at all levels of 

the government. FEMA’s 

National Response Coordination Center (NRCC) 

was not intended to be staffed full-time. The NRCC 

has been activated for the longest period in FEMA’s 

history—606 days since activating the Response 

In 2020, the COVID-19 pandemic, 

coupled with the active wildfire 

and hurricane seasons, taxed the 

capabilities of the emergency 

management community at all 

levels of the government.

Concurrent disasters in Louisiana

In 2020, changing climate dynamics led to a 

confluence of disaster events that Louisiana 

local government leaders and emergency 

managers had not faced previously: a global 

pandemic and an “epidemic” of landfalling 

hurricanes during the 2020 season, including 

two hurricanes (Marco and Laura) passing 

over the same location within 36 hours with 

150-mile-per-hour winds. The two storms 

in direct succession created difficulties in 

forecasting the magnitude of storm surge 

and wind speeds. The resulting initial 

reporting errors led to issues in immediate 

response and delayed long-term recovery 

efforts. The impacts were later compounded 

by Hurricane Zeta, which passed directly over 

a densely populated area.

98 National Council on Disability
Operations Cell on March 5, 2020, as of November 

1, 2021. It was activated to the highest operating 

level (Level 1) for 168 days, starting on March 19, 

2020. Comparatively, during the 2017 hurricane 

season, for hurricanes Harvey, Irma, and Maria, 

and concurrent wildfires, the NRCC was activated 

at Level 1 for only 76 days (the previous record).403

Testing Capabilities

The concurrent disasters 

of 2020 overwhelmed 

federal, regional, and 

local governments and 

tested capabilities. In 

its COVID-19 Initial 

Assessment Report

(2020), FEMA reported 

being unable to “anticipate SLTT requirements due 

to insufficient understanding of SLTT projected 

consequences and capabilities; regional pandemic 

plans either did not exist or did not account for 

jurisdiction-specific capabilities or deficiencies; and

pandemic plans lacked the specificity and guidance 

to establish data collection 

and reporting mechanisms 

for effective decisionmaking for a national 

event. Thus, decisionmakers initially did not 

have all the information 

they needed to make the 

most informed decisions about scarce resource 

allocation and prioritization of medical supplies.”404

Straining Resources

Concurrent disasters strain resources 

including staffing resources. According to the 

National Advisory Council Report to the FEMA 

Administrator (2020), during disasters, SLTTs 

may not be aware of each other’s resource 

capabilities, potentially resulting in duplicate, 

inadequate, or poorly distributed resources. 

SLTTs may become overly dependent upon 

federal resources, which limits the ability of 

FEMA and other agencies to prepare for and 

respond to simultaneous extreme weather 

events. Just-in-time 

delivery supply chains 

are not designed to 

accommodate a largescale disaster. Material 

and equipment may 

not be available in large 

enough quantities, 

and the transportation 

network may be 

compromised by the 

disaster, due to vulnerable interdependencies and 

cascading effects. Government stockpiles may 

be outdated or quickly exhausted by a large event 

or simultaneous events.405 In addition, mutual aid 

agreements may be impacted by reducing the 

viability of those lending 

and receiving assistance. 

California’s 2020 wildfire 

season stressed local 

capacity due to the 

timing and severity of the 

fires. The large wildfires 

occurred earlier than 

expected and impeded standard patterns of 

state-to-state mutual aid.406

FEMA’s Hurricane AAR (2017)407 states that 

during Hurricanes Harvey, Irma, and Maria, 

FEMA faced multiple challenges. The sequential 

and overlapping timing of the hurricanes caused 

staffing shortages and required FEMA to shift 

staff who were already deployed. There were 

“At the federal level, the National 

Response Coordination Center 

(NRCC) was not designed or intended 

to be staffed full-time and as a result 

FEMA was not prepared to staff the 

NRCC for a long-duration pandemic 

incident of national scale...”

The Impacts of Extreme Weather Events on People with Disabilities 99

[D]uring disasters, SLTTs may not 

be aware of each other’s resource 

capabilities, potentially resulting 

in duplicate, inadequate, or poorly 

distributed resources.
also logistic challenges that complicated efforts 

to deploy federal resources and personnel 

quickly. There was also limited preparedness 

by the U.S. Virgin Islands and Puerto Rico for 

a Category 5 hurricane; and incapacitation of 

local response because of loss of power and 

communications, which led FEMA to assume 

response functions that SLTTs would usually 

perform themselves.

FEMA’s strategic plan states that the agency 

should coordinate with other federal agencies 

and SLTTs to foster a common understanding 

of how concurrent disasters are reshaping 

emergency management. Federal and state 

agencies should build better resources and 

tools to drive understanding of future risk and 

enhance agencies’ ability to act.409 In recent 

years, FEMA has called up its surge capacity 

force – Other Federal Agencies (OFAs) personnel 

supplementing FEMA personnel – much more 

frequently than in the past.410 In 2019, a FEMA 

National Advisory Council convened to address 

the future vision of emergency management 

and FEMA, coordination between FEMA and 

nonfederal partners in an outlook of increasing 

disasters; ways to build capacity and response, 

recovery, preparedness, and mitigation at the 

local, tribal, territorial, and state levels and actions 

FEMA should take to ensure marginalized and 

vulnerable communities recover quickly. Over 20 

recommendations were proffered to the FEMA 

Administrator in November 2020. Disability was 

mentioned only four times in the 52-page report.

The needs of people with disabilities are 

not well integrated in emergency management 

planning. People with disabilities face a 

unique set of barriers during disasters, and 

EMAs consistently fail to account for people 

with disabilities or coordinate with disability 

organizations and CBOs to mitigate the risk. 

Excluding people with disabilities in plan 

development can lead to increased injury and 

death during disasters. People with disabilities 

Response Coordination to Alabama 

Tornadoes (2011)

Following the devastating tornadoes in 

Alabama during the spring of 2011, various 

agencies, organizations, and volunteers 

united to locate recovery resources in the 

community and communicate information 

about those resources to the public. Two 

days after the tornadoes, they formed the 

Alabama Interagency Emergency Response 

Coordinating Committee. The committee was 

led by representatives from Independent 

Living Resources of Greater Birmingham, 

United Cerebral Palsy of Greater 

Birmingham, and the Alabama Governor’s 

Office on Disability. The committee also 

included representatives from FEMA and the 

American Red Cross. A daily conference call 

was attended by as many as 60 individuals 

representing agencies that serve people with 

disabilities and chronic illnesses. Volunteers 

with disabilities scanned media and called 

agency contacts to obtain the latest 

information on disaster recovery resources. 

For instance, volunteers called local 

hospitals, clinics, faith-based organizations, 

and organizations representing clinical 

professionals to request help with crisis 

counseling. Recovery resource information 

was compiled in a database and information 

was disseminated in multiple formats.408

100 National Council on Disability
have unique needs that EMAs must plan 

for before a disaster occurs. Despite the 

documented importance of accounting for 

the unique needs of people with disabilities in 

planning for emergencies, many state and local 

emergency plans throughout the United States 

fail to do so.411 NCD has released multiple reports 

on the outcomes of people with disabilities when 

emergency planning does not incorporate the 

needs of people with disabilities. The negative 

outcomes highlighted in NCD’s prior reports will 

increase because of the increased prevalence 

of extreme weather events. During disasters, 

people with disabilities may have accessibility 

needs that must be met for evacuation and/or 

sheltering. For example, 

during disasters, 

people with disabilities 

may need emergency 

information in clear, plain, 

and actionable language. 

People who are Deaf 

or Hard of Hearing may 

need systems in place to receive messages 

about the need to evacuate or shelter in place. 

People with disabilities may need accessible 

transportation for those who use wheelchairs and 

need evacuation assistance; emergency shelters 

with accessible entrances and bathrooms, 

accessible temporary housing, life-sustaining 

medications, consumable medical supplies, 

durable medical equipment, or assistance in 

eating, dressing, or toileting for people with 

disabilities who require these things to survive 

in an emergency shelter, or in-home assistance 

or sheltering options for people with disabilities 

whose survival depends on electrically powered 

equipment during a shelter-in-place response, 

such as during a power outage.

Federal, state, and local officials often fail to 

engage disability led organizations when planning 

for disasters. As a result, required resources and 

programs to assist people with disabilities during 

and after disasters is inadequate.412

Although there is some engagement and 

collaboration with people with disabilities, 

inclusive disaster management collaboration 

is not happening at scale. Many SLTTs do not 

conduct inclusive planning to meet the needs 

of people with disabilities and ensure access for 

these individuals across the full spectrum of its 

emergency programs, services, and activities.413

During a federal, state, and local government 

convening, participants shared that it is often not 

until a disaster happens 

that federal, state and 

local agencies plan for 

people with disabilities. 

Relationships with the 

disability community 

should start well before 

disasters.

Convening participants shared that state and 

local government EMAs and State Homeland 

Security Advisory Council (HSAC) need to gain 

a better understanding of their communities. 

FEMA’s 2022-2026 Strategic Plan414 speaks to 

the goals of instilling equity as a foundation 

of emergency management and leading the 

whole community in climate resilience. EMAs 

and HSAC teams should engage people with 

disabilities during steady state conditions and 

plan for communications and accommodations 

before disasters. Federal and SLTT emergency 

managers should conduct outreach to 

determine the unique needs of people with 

disabilities, such as who will need assistance 

evacuating their homes and take a people-first, 

Over 20 recommendations were 

proffered to the FEMA Administrator 

in November 2020. Disability was 

mentioned only four times in the 

52-page report.

The Impacts of Extreme Weather Events on People with Disabilities 101
whole-of-community approach to emergency 

management by collaborating and planning 

with people with disabilities and organizations 

representing people with disabilities to create 

fully integrated emergency management policies, 

plans, and programs.

Underrepresentation in Emergency 

Management 

Leadership Roles

During convenings with 

stakeholder organizations 

and separately with 

federal, state, and local 

governments, participants 

said that people with disabilities are not 

represented in emergency management agencies 

in leadership and key decision-making roles nor 

on planning committees in relation to emergency 

management policy, planning, and program 

development While decision-makers come with a 

host of different qualifications and backgrounds, 

it is not possible to replace lived experience. One 

example a participant gave was of a state whose 

emergency management 

division lacks expertise on 

disability but has not hired 

disability coordinators, 

although encouraged to 

do so. Although a few 

states’ EMAs may have 

disability integration roles 

or disability integration 

coordinators, this approach is not adopted 

nationwide. During disasters, because of the 

lack of preparedness for response and recovery, 

the state’s Office for People with Disabilities 

representative (or ADA coordinator) has had to 

step into the emergency management role. Hiring 

people with lived experience would go a long way 

to improve emergency planning and safety.

Gap in Tribal Nations Emergency 

Management Plans

The status of tribal emergency management 

planning is generally unknown. Some Tribal 

Nations’ emergency management plans are out 

of date and/or do not 

specifically include the 

needs of people with 

disabilities. There are 

574 federally recognized 

Tribal Nations in the 

United States and its 

territories and they all have individual concerns 

and challenges.415 Some Tribal Nations are 

well resourced and have robust emergency 

management programs (e.g., Seminole Tribe 

emergency management program), while other 

Tribal Nations do not have any plan in place. It 

is unclear which Tribal Nations have emergency 

management plans, how many of those plans 

are current, and how many specifically are 

inclusive of people with 

disabilities. One indicator 

of community planning 

is FEMA’s Threat and 

Hazard Identification and 

Risk Assessment (THIRA) 

process. FEMA requires 

states, territories, Tribal 

Nations, and urban areas that receive federal 

preparedness grant funding to report their 

threats and hazards of greatest concern and set 

preparedness goals through the THIRA process. 

According to the National Preparedness Report 

(2021), many Tribal Nations have not completed a 

THIRA/Stakeholder Preparedness Review.416

Some Tribal Nations’ emergency 

management plans are out of date 

and/or do not specifically include the 

needs of people with disabilities.

GAO identified that not all Tribal 

Nations have sufficient funding to 

develop emergency management 

departments, which can be a barrier 

to accessing federal resources.

102 National Council on Disability
In a GAO report (2021), GAO identified that 

not all Tribal Nations have sufficient funding to 

develop emergency management departments, 

which can be a barrier to accessing federal 

resources.417 Remote Tribal Nations face specific 

challenges in recovery planning and receiving 

assistance after a disaster, such as a lack of 

access to transportation, 

which makes it difficult 

for Tribal Nation members 

to get to disaster 

recovery centers where 

they can learn about and 

apply for assistance. 

The November 2020 

National Advisory Council 

report suggests that if low-resource communities 

continue to face barriers to accessing funding 

for preparedness and disaster resilience, there 

is a potential for a compounding effect.418 The 

November 2020 National Advisory Council 

report included multiple recommendations to 

the FEMA Administrator. The recommendations 

NCD believes would improve the outcome of 

people with disabilities 

before, during, and 

after disasters has been 

incorporated through 

reference herein.419

A Tribal Nations 

representative told NCD 

that although they have 

emergency operations plans, the plans are not 

“disability specific.” However, the representative 

also said that although people with disabilities 

may not be specifically identified in emergency 

management plans, the concept of taking care of 

seniors or people with special needs is inherent 

in Native American culture. The representative 

said that funding should be set aside for Tribal 

Nations to plan for people with disabilities during 

disasters.

While the Bureau of Indian Affairs (BIA) 

works with Tribes, BIA does not provide 

guidance on emergency management plans or 

conduct emergency management exercises or 

response. Tribal Nations 

are responsible for 

emergency management 

planning for disaster 

events on Tribal lands. 

Tribal Nations have 

requested or applied 

for Federal Government 

funding for planning. 

They also coordinate with states and FEMA 

for funding after a disaster. Tribal Nations have 

access to FEMA’s Tribal Homeland Security 

Grant Program (THSGP),420 which provides $15 

million for all 574 federally recognized tribes to 

enhance their ability to prevent, protect against, 

respond to and recover from potential terrorist 

attacks and other hazards.421 The vast majority of 

tribes do not participate 

in the THSGP because 

the money is given to 

states to distribute and 

while some states share 

the grants with tribes, 

others may only give 

small amounts or none. 

Tribal Nations are exceptionally underserved and 

underrepresented when it comes to emergency 

management planning. Tribal Nations do not 

receive services and support needed to build 

resilience. FEMA and other federal agencies 

should dedicate more staff to help tribes plan for 

the next disaster.422

[A]lthough people with disabilities 

may not be specifically identified in 

emergency management plans, the 

concept of taking care of seniors or 

people with special needs is inherent 

in Native American culture.

Tribal Nations are exceptionally 

underserved and underrepresented 

when it comes to emergency 

management planning.

The Impacts of Extreme Weather Events on People with Disabilities 103
Response

Provide Accessible Communication 

During Disasters

Limited effective communications during extreme 

weather events means people with disabilities 

do not have equal access to information, which 

increases the risk to their safety and infringes on 

their civil rights protections.

Websites

People with disabilities need access to 

information.423 Some weather and emergency 

management websites are not interoperable with 

AT such as screen readers used by people who 

are blind or have low vision. For example, there 

are parts of the National 

Hurricane Center (NHC) 

website that some 

people have difficulty 

accessing. NOAA’s 

website is currently 

updating its site for 508 

compliance.424

ASL, Plain Language and Multiple 

Languages

The way information is transmitted and 

communicated in response to natural disasters 

is not accessible to all people with disabilities. 

During disasters, federal and SLTTs are required 

to provide accessible communications to people 

with disabilities in accordance with the ADA. 

However, information is not always provided 

in accessible, plain language or in different 

languages or in different forms and formats and via 

multiple methods or platforms. Federal and SLTT 

governments must ensure that public warning and 

alert systems are accessible to people who are 

Deaf, Hard of Hearing, blind, low vision, or have 

sensory and cognitive disabilities. Federal and 

SLTT governments must improve communications 

to ensure disaster information is accessible 

to people with disabilities and must integrate 

additional technologies and encourage industry 

innovation to meet the needs of all people. 

Community organizations also provide lifesaving 

and life-sustaining support related to advocacy 

and communication. It is critical that people with 

various communication disabilities, people who are 

Deaf or Hard of Hearing have different means of 

effective communication to stay safe and stay alive.

Traditional Alert and Warning Systems 

Do Not Reach Everyone

Many SLTTs continue 

to rely primarily on the 

traditional EAS that 

interrupt television or 

radio programming 

to provide disaster 

notifications. Also used 

are sirens, loudspeakers, 

and public address systems. More than half (55.1 

percent) of U.S. consumers have “cut the cord” 

from cable and rely on streaming and web-based 

services rather than television.425 EAS in addition, 

auditory alert systems are ineffective for individuals 

who are Deaf and Hard of Hearing and place 

the Deaf community at a high risk of being left 

behind during an emergency. Executive Order 

13407 mandates that the Federal Government 

“include in the public alert and warning system the 

capability to alert and warn all Americans, including 

those with disabilities and those without an 

understanding of the English language.” Although 

some EMAs are improving disaster warnings by 

sending warnings directly to cellphones.

Some weather and emergency 

management websites are not 

interoperable with AT such as screen 

readers used by people who are 

blind or have low vision.

104 National Council on Disability
It is unclear whether the warnings reach all 

people, including individuals without access to 

power sources or internet, people who do not 

have smart phones or social media accounts, 

or those who rely on 

alternative forms of 

communication. People 

with sensory and 

cognitive disabilities are 

specifically among those 

excluded from traditional 

media. FEMA’s IPAWS 

is available for SLTTs to 

sign up and use to alert 

their communities. IPAWS send alerts through the 

EAS, Wireless Emergency Alerts (WEA), NOAA 

Weather Radio, and an Internet-Based Services 

and Unique Systems.427

During disasters people who are Deaf and Hard 

of Hearing may not have equal access to warning 

alerts.428 Video Relay Service (VRS) is a good way 

to reach Deaf people who sign. For Deaf people 

who do not sign, and Hard of Hearing people who 

use residual hearing and augmented hearing for the 

phone, there are captioned relay services. However, 

many jurisdictions do not know who in their 

community requires these services and risk leaving 

these members of the community behind during 

disasters. SLTT EMAs must review their EASs to 

ensure they know the needs of their community 

and that emergency alerts are reaching everyone.

The National Oceanic and Atmospheric 

Administration (NOAA) supports a nationwide 

network of NOAA weather radio stations (NWR). 

The stations broadcast continuously and provide 

local weather service warnings, watches, forecasts, 

and hazard information. NOAA collaborates with 

the Federal Communication Commissions (FCC) 

Emergency Alert System. Federal, state, and 

local EMAs may also access NWR to broadcast 

warnings and post event information on natural, 

environmental and public safety events.429

A benefit of many of the All-Hazards Radios is 

the visual and vibrating 

alarm feature & text 

readouts to ensure that 

people who are deaf and 

hard of hearing receive 

timely alerts.430

Emergency 

Communications 

Need to Be Inclusive

Some SLTTs do not use ASL interpreters when 

broadcasting announcements or emergency 

weather alerts. SLTTs that do not have sign 

language interpreters as part of their emergency 

FEMA’s Common Alerting Protocol

Best Practice

FEMA developed the Common Alerting 

Protocol (CAP), a digital format for 

exchanging emergency alerts, that 

allows a consistent alert message to 

be disseminated simultaneously over 

multiple communications pathways, an 

Integrated Public Alert and Warning System 

(IPAWS) standard. FEMA’s IPAWS office 

has identified emerging technologies 

and assistive technology products that 

support or provide direct alert and warning 

capabilities for people with disabilities, 

including braille readers, wall beacons, sign 

language interpretation, and video remote 

interpreting.426

Some states and counties do not 

provide qualified sign language 

when providing public information 

about emergencies and disasters 

(e.g., during press conferences) 

where vital information is shared 

about emergencies or disasters.

The Impacts of Extreme Weather Events on People with Disabilities 105
preparedness plan may unwittingly hire 

unqualified sign language interpreters; And local 

news stations also fail to use sign language 

interpreters for weather alerts. The national 

shortage of ASL interpreters431 may play a small 

part as to availability, but SLTTs must ensure that 

effective communication, 

a.k.a. sign language 

interpreters are baked 

into their emergency 

management 

preparedness plans to 

ensure that the entire 

community has access 

to all emergency weather 

alerts and updates. 

Convening participants 

stated that Florida’s 

governor and counties have a list of qualified 

interpreters. NCD recommends that all SLTTs 

should create a database of sign language 

interpreters and share that database with 

neighboring SLTTs to help mitigate the usage 

of unqualified or no sign language interpreters 

during broadcast announcements and press 

conferences.

Of additional 

concern, even if sign 

language interpretation 

is integrated into an 

SLTTs emergency 

preparedness plan, often times other languages 

are not provided. For example, in Puerto Rico, 

most Deaf individuals use Puerto Rican Sign 

Language (PRSL) not ASL. However, during 

Hurricane Maria (2017) in Puerto Rico, FEMA 

brought in ASL interpreters who were not able 

to effectively communicate with people who 

were Deaf or Hard-of-Hearing. There are also 

many communities in the United States who use 

PRSL and other international sign languages.

The Need of Accessible Transportation 

for Evacuation is High

Jurisdictions face transportation resource 

gaps for emergency 

evacuations. The 

need for accessible 

transportation during 

disaster response 

and evacuation often 

surpasses the resources 

of the local community, 

forcing jurisdictions to 

be creative, dependent 

on volunteers, and 

with a patchwork 

approach to provide accessible transportation 

to safely evacuate people with disabilities 

during disasters. Accessible transportation 

is critical for evacuating during a disaster. 

During a disaster there may be individuals 

who do not have access to personal or public 

transportation. In rural and tribal communities, 

some people do not 

have consistent access 

to public transportation 

during blue sky days. 

During a convening 

of federal, state, and 

local government representatives, participants 

said that there are more people who need 

accessible transportation than many local 

jurisdictions can accommodate. In other 

words, some jurisdictions do not have enough 

vehicles to evacuate everyone during disasters. 

With limited resources and capabilities, local 

[I]n Puerto Rico, most Deaf 

individuals use Puerto Rican Sign 

Language (PRSL) not ASL. However, 

during Hurricane Maria (2017) in 

Puerto Rico, FEMA brought in ASL 

interpreters who were not able to 

effectively communicate with people 

who were Deaf or Hard of Hearing.

[S]ome jurisdictions do not have 

enough vehicles to evacuate 

everyone during disasters.

106 National Council on Disability
jurisdictions have to be creative to determine 

where resources are available and how to 

work with other federal agencies and SLTTs 

to “braid” their services together. SLTTs often 

work with mutual aid disability organizations 

and other organizations to identify accessible 

transportation options. Community organizations 

who have wheelchair accessible vehicles and 

know where people with disabilities live in 

their community provide transportation support 

during disasters. However, such organizations 

have experienced difficulties attaining 

reimbursements, and when reimbursed, being 

sufficiently compensated to fully cover the costs 

of the services provided.

Some local jurisdictions set up agreements 

with outside jurisdictions to “surge” 

transportation supplies during disasters. 

Although some local jurisdictions’ emergency 

operation plans state that they will provide 

accessible transportation, not all have identified 

the resources to provide such accessible 

transportation. Where contracts, agreements, 

and memorandum of understanding (MOUs) 

with accessible transportation providers exist, 

not all contain the types of emergency services 

provisions one might need. For example, they 

may not explicitly require that the providers 

must be available 24 hours a day, 7 days a week, 

or that the transport is free for those being 

transported.

Paratransit Needs Workers and 

Improvement

Given the limited availability of paratransit 

services, and constraints on such services, SLTT 

The Impacts of Extreme Weather Events on People with Disabilities 107
EMAs do not consistently incorporate paratransit 

agencies into emergency management plans. 

According to the U.S. DOT, paratransit systems 

provide transportation in areas served by fixedroute public transit systems, for people with 

disabilities who cannot use the fixed-route 

transit, in an equivalent manner to the users of 

the fixed-route transit. They only provide services 

within 3⁄4 mile of fixed-route transit lines, and only 

during the hours of operation of those transit 

lines. With few exceptions, paratransit does not 

provide services outside of the specified service 

requirements. The level of service capacity is 

sized to meet the limited demand constrained by 

these service requirements. Seventy-five percent 

of paratransit across 

the U.S. is provided by 

contractors.

The contracts with the 

providers are constrained 

by these requirements 

and it is unclear whether 

the constraints can be 

waived during an emergency. During disasters, 

people with disabilities may need transportation 

to a safe location outside of the evacuation area. 

It is also unclear whether paratransit can provide 

services to evacuees outside of the 3⁄4 mile 

constraints or outside of the normal operating 

hours.

Disability stakeholders recommended a review 

of how paratransit is used during an emergency. 

They said that paratransit needs funding and 

improvement and DOT should provide additional 

funding to contract paratransit workers. The DOT 

Coordinating Council on Access and Mobility 

(CCAM),432 is a multiagency group with 11 federal 

agencies. The purpose of CCAM is to coordinate 

funding and provide expertise on human services 

transportation for three targeted populations: 

people with disabilities, older adults, and people 

of lower income433. CCAM-issued transportation 

coordination guidance aims to reduce overlap 

between the 130 CCAM programs across 

nine agencies that may fund human services 

transportation and incentivize collaboration by 

clarifying eligible reporting into the National Transit 

Database (NTD). CCAM reviews components of 

transportation including access to employment, 

access to health care, and access to community 

living. CCAM was not authorized by Congress to 

review the role of paratransit during a disaster.434

Public Law 117-58, the Infrastructure 

Investment and Jobs Act435 promises to rebuild 

America’s roads, bridges, 

and rails; expand access 

to clean drinking water; 

ensure every American 

has access to highspeed Internet; tackle 

the climate crisis; 

advance environmental 

justice; and invest in communities that have too 

often been left behind. The legislation includes 

$39 billion of new investment to modernize 

transit, in addition to continuing the existing 

transit programs for five years as part of surface 

transportation reauthorization. In total, the 

new investments and reauthorization provide 

$89.9 billion in guaranteed funding for public 

transit over the next five years—the largest 

federal investment in public transit in history. 

The legislation will expand public transit options 

across every state in the country; replace 

thousands of deficient transit vehicles (including 

buses) with clean, zero-emission vehicles. Since 

paratransit service must be provided within three 

quarters of a mile of a bus route or rail station and 

The contracts with the [paratransit] 

providers are constrained by these 

requirements and it is unclear 

whether the constraints can be 

waived during an emergency.

108 National Council on Disability
during the same hours of operation, passengers 

with disabilities who rely on paratransit will reap 

the benefits of the expanded service. A.

FEMA Regional Disability Integration 

Specialists (RDIS) Play a Critical Role

Before disasters, RDIS provide essential 

support to SLTT partners in their planning and 

preparedness efforts. During a disaster, FEMA 

RDIS and other FEMA Disability Integration 

Advisors are critical to adequately support 

people with disabilities. SLTT partners should 

engage and collaborate with FEMA RDIS, statedesignated disability integration coordinators, 

and members of the disability community to 

better understand the needs of people with 

disabilities in disasters. RDIS may also be able to 

help identify resources for shelter, housing, and 

other disaster services. Accessible resources, 

accommodations, and reasonable modifications 

ensure that housing plans and operations include 

people with disabilities. For example, survivors 

with disabilities must often stay near their 

established support systems, which restricts 

accessible housing options.436

Recovery

Community Organizations Have 

Difficulty Getting Compensated

Volunteer organizations play key roles in disaster 

response. They, and other disability-led nonprofit 

organizations, respond to disasters on the 

ground and play a pivotal role in emergency 

response to meet the needs of the disability 

community. However, many disability-led 

nonprofit organizations have reported difficulty 

The Impacts of Extreme Weather Events on People with Disabilities 109
in applying for reimbursement or do not know 

how to be reimbursed for their services. Some 

disability organizations reported that they have 

to prove value to receive reimbursements for 

the life-sustaining and lifesaving work they 

do. FEMA PA funding is available for other 

emergency protective measures (Category B), 

when authorized for a new incident, for work 

necessary to meet 

immediate threats to life 

and property.437 Some 

community disability 

organizations provide 

services that should be 

covered under FEMA 

PA Category B funds 

but have reported 

reimbursement for services is onerous. The 

application process may be unclear or there may 

be a lack of understanding for how disability 

organizations can receive FEMA PA Category 

B Funding support. FEMA has convened a 

federal working group to create a document to 

assist SLTTs and nonprofits on federal disaster 

assistance for people 

with disabilities. The final 

document will simplify 

the different disaster 

relief funding programs 

available to SLTTs and 

nonprofit agencies. 

FEMA’s strategic plan 

for 2022 to 2026 includes removing barriers to 

FEMA programs through a people-first approach 

and include community outreach to make sure 

that FEMA programs are accessible to the whole 

community, including people with disabilities. 

This is also required under Executive Order 

13985, Advancing Racial Equity and Support 

for Underserved Communities Through the 

Federal Government, which requires community 

engagement.

Sharing Lessons Learned Will Enhance 

Emergency Planning

Following disasters, SLTT EMAs and other 

responders do not 

sufficiently share 

lessons learned among 

responders and with 

disability organizations 

and CBOs. While FEMA 

develops and publishes 

Disaster AARs, it is 

unclear how the agency 

shares the best practices and lessons learned 

with OFAs, SLTT EMAs, NGOs, and CBOs 

working with people with disabilities and other 

stakeholders. Efforts by the Partnership for 

Inclusive Disaster Strategies and the National 

State Level Disability Coordinators have resulted 

in the sharing and implementing of numerous 

best practices across the state coordinators and 

nonprofit partners. It 

is important to ensure 

the resources are made 

available to incorporate 

the lessons from 

CBOs working with 

people with disabilities. 

FEMA and SLTT EMAs should proactively share 

best practices and lessons learned with key 

stakeholders. Disability lessons learned should 

be incorporated into overarching Emergency 

Management lessons learned, rather than a side 

issue.

[M]any disability-led nonprofit 

organizations have reported difficulty 

in applying for reimbursement or do 

not know how to be reimbursed for 

their services.

110 National Council on Disability

Disability lessons learned should 

be incorporated into overarching 

Emergency Management lessons 

learned, rather than a side issue.
Recommendations

■ FEMA and emergency managers at all levels of government should develop strategies to 

manage multiple concurrent disasters. Federal entities and SLTTs should adjust planning 

and response protocols developed for “standard” events to satisfy new response needs. 

These strategies could include a list of anticipated gaps, prioritizations for which gaps 

to invest in, and proactive planning to manage those gaps through other means when 

investments are not available. This recommendation works both for the overarching issues 

and the specifics around disability inclusion.

■ FEMA should prioritize the implementation of the FEMA 2020 National Advisory Council 

recommendations (2020-01, 2020-02 2020-03 2020-05, 2020-06, 2020-07, 2020-08, 2020-

09, 2020-11, 2020-12, 2020-13, 2020-15, 2020-18, 2020-19, 2020-20, 2020-21, 2020-22, 

2020-25a).438 Implementation should ensure that the needs of people with disabilities are 

integrated into the final policy, plans and services.

■ FEMA should determine what steps are needed to address the nation’s emergency 

management capability gaps across all levels of government and inform federal partners, 

such as the Office of Management and Budget, and Congress, about what level of 

resources would be necessary to address the known gaps.439

■ SLTTs should put in place state HSAC teams. State HSAC teams meet regularly with 

and coordinate with public health, NGOs, and other area agencies to plan and better 

understand how to work together during response.

■ FEMA should enhance its stakeholder engagement strategy to intentionally include people 

with disabilities and disability-led organizations in emergency management planning and 

exercises. FEMA should then encourage and share this strategy with SLTT EMAs.

■ Federal agencies responsible for emergency preparedness, community resilience, and 

disaster-related services, programs, supports, or activities should engage with national, 

state, and local coalitions of disability-led organizations and stakeholders. These federal 

agencies include but are not limited to: DHS, FEMA, CRCL, HHS, ASPR, ACL, CDC, HUD, 

DOT, DOJ, DRS, ED, OSERS, DOL, the Office of Disability Employment (ODEP), DOD, 

Veterans Affairs, and U.S. Access Board.

(continued)

The Impacts of Extreme Weather Events on People with Disabilities 111
Recommendations: continued

■ FEMA Administrator should communicate to Regional Administrators and RDIS a 

written plan for implementing its new disability integration staffing approach, consistent 

with the objectives established for disability integration. Such a plan should include an 

implementation timeline and details on staff responsibilities, which regions could use to 

evaluate staff performance.440

■ All federal and SLTT EMA’s should engage people with disabilities, disability organizations, 

and CBO’s in disaster management planning. Ensuring that recommendations and 

concerns from people with disabilities are prioritized and incorporated into any disaster 

management plan.

■ The federal and SLTT EMAs should hire people with disabilities to help inform emergency 

management policy and planning.

■ Congress should authorize additional funding and FEMA should provide guidance to Tribal 

Nations to strengthen/establish an emergency preparedness plan inclusive of people with 

disabilities.

■ Tribal Nations should form Disability Advisory Councils to liaise with federal, state, and 

local EMAs.

■ State EMAs should work with Tribal Nations to develop emergency management plans that 

specifically include people with disabilities. FEMA, the Indian Health Service (IHS), and BIA 

should advise and support these efforts.

■ Tribal Nations should put in place personal preparedness plans and create Communication, 

Maintaining Health, Independence, Support, and Transportation (CMIST)441 response teams 

to prepare their communities. Examples of personal preparedness plans are found at 

https://www.ready.gov/disability.

■ Congress should appropriate funds and require DOJ, in collaboration with OFAs to increase 

monitoring and enforcement of federal disability laws, which requires that emergency 

communications be fully accessible to people with disabilities.

■ DOJ should review websites such as the National Hurricane Center (NHC) to ensure that 

it is 508 compliant and that all federal webpages are accessible to people who use screen 

readers or other assistive technology devices.

■ FEMA, FCC, and SLTT partners should inform and encourage all SLTT emergency 

managers to utilize the full IPAWS alerting system, since IPAWs includes EAS, along with 

numerous other, more accessible, communications methods.

112 National Council on Disability
Recommendations: continued

■ Federal and SLTT EMAs should activate alerts via IPAWS simultaneously when they 

activate alert sirens and public address systems, to ensure alerts are accessible for people 

who are Deaf and Hard of Hearing.

■ NOAA, FEMA and/or HHS ASPR and/or ACL should promote the availability and distribution 

of adapted weather radios for people who are Deaf and Hard of Hearing though SLTT, 

Center for Independent Living (CIL), and NGO partners.

■ NOAA, NCEI and the NWS should collaborate with FEMA, state EMAs, and public health 

agencies to share data and develop agile strategies to manage multiple concurrent 

disasters.

■ FEMA, DOJ, and the FCC should review, consolidate, and enhance existing guidance for 

effective communications before, during, and after disasters, compiling these materials 

into a comprehensive guide that is distributed, and promoted, across federal, SLTT, and 

NGO partners.

■ FEMA should hire multilingual sign language interpreters and contract for VRI services for 

all major sign languages, to meet the needs of specific communities such as Puerto Rican 

Spanish Sign Language in the U.S. and its territories.

■ FEMA should better inform SLTT and OFA partners that providing sign language 

interpreters is required for any activities funded by FEMA. Also, FEMA should make its 

VRI services available to all SLTT and OFA partners to ensure that SLTT partners have 

access to such services, whenever needed to support stakeholders and disaster workers 

who are Deaf or Hard of Hearing.

■ All SLTT partners should incorporate provisions for accessible transportation in their 

Emergency Operations Plans. Such incorporation should include analysis of the required 

demand for such services and appropriate contracts, agreements, and MOUs to 

support that demand in an emergency. Appropriate contracts should include emergency 

requirements such as ensuring 24/7 availability on short notice, with costs being charged 

to the jurisdiction, rather than passengers. Such agreements do not need to be commercial 

contracts. In fact, mutual aid agreements with other jurisdictions and/or NGOs may be the 

most effective and cost-effective options, provided that both partners are not impacted by 

the same disaster.

(continued)

The Impacts of Extreme Weather Events on People with Disabilities 113
Recommendations: continued

■ FEMA should assess the resource needs of RDIS to ensure that they are fully resourced 

to meet the needs of their SLTT partners for planning and preparedness. FEMA should 

assess the resource needs to ensure that there is a sufficient cadre of trained disability 

integration advisors (DIA), including reservists to staff all disaster operations.

■ FEMA should conduct outreach to, and training for, community organizations, to ensure 

that all interested community organizations know how to prepare for and apply for PA 

program Category B public assistance funds, when performing essential services.

■ FEMA and SLTT partners should share their processes for capturing and disseminating 

disability-related lessons learned and best practices.

■ The President should sign an executive order (EO) charging federal agencies to develop/

update emergency management plans to anticipate an increase in extreme weather 

events, address the impact to agency functions, and provide guidance to the SLTTs. The 

EO should specifically address how each agency will integrate people with disabilities 

into the emergency management plan to ensure services for people with disabilities are 

available before, during, and after disaster.

114 National Council on Disability
Appendices

Appendix A: Convening Participants

March 21 & 24 2022: NGO Stakeholder Meeting

Allie Cannington Manager of Advocacy and Organizing with The Kelsey

Claire Stanley Public Policy Analyst with the National Disability Rights Network

Gail-Ann Guy-Cupid Assistant Professor of Social Work at the University of the Virgin Islands, 

works with the Disability Rights Center for the Virgin Islands

Gelila Selassie Staff Attorney with Justice in Aging

Germán Parodi Co-Executive Director of The Partnership for Inclusive Disaster Strategies

Hoskie Benally Community & Government Liaison with the Native American Disability Law 

Center

Howard Rosenblum Attorney, Chief Executive Officer and Director of Legal Services with the 

National Association of the Deaf

Justice Shorter National Disaster Protection Advisor with the National Disability Rights 

Network

Laura Weidner Vice President of Government Relations & Advocacy for the Epilepsy Foundation and the Vice Chair for the Consortium of Citizens with Disabilities

Marcie Roth Executive Director and CEO of the World Institute on Disability

Michael Morris Founder and Senior Strategic Advisor of the National Disability Institute

Noah Patton Housing Policy Analyst (Disaster Recovery) with the National Low Income 

Housing Coalition

Olivia Babis Senior Public Policy Analyst with Disability Rights Florida

Philip Kahn-Pauli Policy and Practices Director with RespectAbility

Shaylin Sluzalis Co-Executive Director of The Partnership for Inclusive Disaster Strategies

Stephanie Duke Attorney and Equal Justice Works Disaster Fellow with Disability Rights 

Texas

Zainab Alkebsi Attorney and Policy Counsel with the National Association of the Deaf

May 16, 2022: Government Stakeholder Meeting

David Goldbloom-Helzner Physical Scientist with the Environmental Protection Agency (EPA)

Gabe Cazares Director of the City of Houston’s Mayor’s Office for People with Disabilities

Imke Durre Physical Scientist for NCEI and the Center for Weather and Climate with 

NOAA

Jason T. Lagria Acting Director of the Office of Disability Integration and Coordination 

(ODIC) at FEMA

The Impacts of Extreme Weather Events on People with Disabilities 115
Kevin Perkins Disability Program Manager with the Office of Equal Rights at FEMA

Lisa N. Bothwell Program Analyst with the Office of Policy Analysis & Development, the 

Center for Policy & Evaluation, and the Administration for Community Living at the U.S. HHS

Margaret Schaefer Senior Policy Advisor with the CRCL at the U.S. DHS

Michael Houston Regional Disability Integration Coordinator (Region 8) with the ODIC at 

FEMA

Michael Reardon Supervisory Policy Advisor with the ODEP ODEP’s Employment Related 

Supports Team and the ODEP at the U.S. DOL

Rebekah Tosado Section Chief of the Antidiscrimination Group in the CRCL at the U.S. DHS

Sadie Martinez Access and Functional Needs Coordinator with Colorado’s Office of Emergency Management

Sean T. Barrett Program Analyst with the Office of Compliance and Disability Rights and 

the Office of Fair Housing and Equal Opportunity at U.S. HUD

Shira E. Gordon Trial Attorney with the Office of General Counsel and the Fair Housing Compliance Division at the U.S. HUD

Sonia Klukas Deputy Director of the ODIC at FEMA

Vance Taylor Chief of the Office of Access and Functional Needs with the California Governor’s Office of Emergency Services (CalOES)

Victoria Porto Director of Programs with the CRCL at the U.S. DHS

116 National Council on Disability
Appendix B: Report Recommendations by Administration, 

Congress and Agency

NCD Recommends the Administration:

■ The President sign an executive order (EO) charging federal agencies to develop/update 

emergency management plans to anticipate an increase in extreme weather events, address 

the impact to agency functions, and provide guidance to the SLTTs. The EO should specifically 

address how each agency will integrate people with disabilities into the emergency management 

plan to ensure services for people with disabilities are available before, during, and after disaster.

NCD Recommends Congress:

■ Congress should request the Government Accountability Office (GAO) commission a study 

of which states have developed and maintain state-level emergency management plans and 

guidance that fully integrate people with disabilities.

■ Congress should pass legislation such as the Real Emergency Access for Aging and Disability 

Inclusion for Disasters Act (REAADI) to address gaps in meeting civil rights obligations to people 

with disabilities impacted by disasters. The bill would establish a research center to be defined in 

legislation, to conduct research to determine recommended practices for including people with 

disabilities and older adults in planning during and following disasters; Establish a “projects of 

national significance” program to increase the involvement of people with disabilities and older 

adults in the planning and response to disasters and identify strategies for reducing deaths, 

injuries, and losses to those groups as a result of disasters; Establish a National Commission on 

Disability Rights and Disasters that will provide recommendations on how to ensure effective 

emergency preparedness, disaster response, recovery, and community resilience efforts for 

people with disabilities and older adults; Establish Training and Technical Assistance Disability 

and Disaster Centers that provide comprehensive training, technical assistance, development of 

funding sources, and support to state, tribal, and local disaster relief; public health entities; social 

service agencies; and stakeholder groups.

■ Congress should appropriate funds to FEMA for the express purpose to advise SLTTs emergency 

management agencies (EMAs) and state health departments to conduct reviews and update 

emergency management plans and guidance to prepare for an increase of people with disabilities. 

The plans should be data-driven, inclusive, and compliant with disability laws to ensure equal 

access including effective communication, evacuations, and shelters that provide accommodations 

and modifications to ensure the safety of people with disabilities.

■ Congress should enact legislation to combat special education and rural teacher shortages 

across the United States and appropriate funding for programs to assist in recruitment of special 

education teachers.

The Impacts of Extreme Weather Events on People with Disabilities 117
■ Congress should require state collection of health care demographic data relating to functional 

disability and home- and community-based services (HCBS) use for all Medicaid enrollees, 

including better data collection across the full range of long-term care, group homes, and 

congregate settings, licensed, certified, or approved by the state.

■ Congress should pass legislation to address the shortage of primary care doctors and other 

health care providers. The legislation should address shortfalls in the nation’s supply of health care 

providers and include inclusive recruitment for a diverse health care workforce, loan forgiveness 

that encourages health care providers to work with underserved populations, and other innovative 

targeted incentive measures.

■ Congress should make R&D investments that promote assistive technology. This should involve: 

(a) Greater investments for R&D of accessible apps and devices to incentivize developers 

to create innovative technology, which can help people with disabilities enhance functional 

performance to improve outcomes in areas such as education, employment, and independent 

living. (b) Increase the R&D budget for NIDILRR, the Medical Research and Development 

Program. (c.) Provide funding to a federal unit such as the Administration for Community Living 

(ACL) to design and fund technical assistance on R&D for the technology industry to support 

accessible design of emerging technology. and (d) Provide funding to ACL to establish and 

expand peer support programs on accessible assistive technology. These programs could 

be provided through independent living centers and grassroots experts and should involve a 

community of practice platform for exchanging information and managing requests for peer 

consultation.

■ Congress should pass the Disaster Relief Medicaid Act (DRMA). upon passage, states should 

immediately implement DRMA to ensure that individuals who are eligible for Medicaid and are 

forced to relocate due to a disaster are able to continue to access their Medicaid-supported 

services.

■ Congress should provide funding to HHS for the Secretary to implement section 5307 of 

the Patient Protection and Affordable Care Act. Funding section 5307 would allow for the 

development, evaluation and dissemination of research, demonstration projects, and model 

curricula for cultural competency, prevention, public health proficiency, reducing health disparities, 

and aptitude for working with people with disabilities, training for use in health professions schools 

and continuing education programs.442

■ Congress should pass legislation to ease rising costs for renters and prospective homebuyers and 

encourage construction of new affordable and accessible housing units.

■ Congress should pass legislation to spur affordable housing production and measures to preserve 

existing homes so that people with disabilities can return to their homes post an extreme 

weather event as outlined in the White House Actions to Ease the Burden of Housing Costs. 

Doing so would expand and improve existing forms of federal financing for affordable multifamily 

118 National Council on Disability
development and allocate a percentage of the housing development units to be accessible to 

people with disabilities.

■ Congress should fund legislation to enable states to increase accessibility to HCBS and to expand 

access to assistive technologies in order to promote independence and community integration.

■ Congress should permanently authorize HUD Community Development Block Grant (CDBG) funding 

or in the alternative, streamline the authorization process after a disaster so that subsidies reach 

recovering communities earlier, and so rebuilding can begin immediately following a disaster.

■ Congress should authorize additional funding and FEMA should provide guidance to Tribal Nations 

to strengthen/establish an emergency preparedness plan inclusive of people with disabilities.

■ Congress should require ED to conduct a study assessing the impact of extreme weather events 

on students with and without disabilities. The study should assess the physical, psychological, 

and mental health impacts of extreme weather events, the impact on academic achievement, and 

utilize collected data to inform school districts in disaster management planning.

■ Congress should require ED to track and report on post-disaster compensatory services provided 

to students in any school district located in a presidentially declared major natural disaster area to 

better prepare and develop best practices for recovery after extreme weather events.

■ Congress should provide funding to ED to develop information technology standards for 

secure, interoperable electronic education records. These records must include the supports 

and services a student receives under IDEA and Section 504, and the standards must 

interoperate with electronic health record systems to allow school districts, students, and 

parents to access their IEPs, 504 plans, and supporting medical documentation. Once 

the information technology standards are established, ED should strongly encourage and 

provide technical assistance for local school districts to avail themselves of the technology to 

mitigate delays in special education services because of relocation or loss of records due to 

extreme weather events. Congress should take action to strengthen the safety net for socially 

vulnerable groups, such as students with disabilities, school staff with disabilities, and their 

families.

■ Congress should amend the IDEA funding formula to mitigate the high incidence of poverty in 

rural and low-income communities, including U.S. territories.

NCD Recommends the Center for Medicare & Medicaid Services (CMS):

■ CMS should examine and consider changes to emergency preparedness plans to bolster the 

resiliency of the health care sector as part of an administration-wide effort to be ready for the next 

weather-related emergency.

■ CMS should clarify its new rules and regulations about replacing ATs and DME damaged or lost in 

a disaster.

The Impacts of Extreme Weather Events on People with Disabilities 119
NCD Recommends the U.S. Department of Education:

■ ED should commission a study to examine the impacts of extreme weather events and adaptation 

strategies on children with disabilities and their families. The study should include findings to 

support disaster planning.

■ ED should collect standardized tracking and reporting of educational services and supports that 

are unable to be provided to students with disabilities during and after a disaster.

NCD Recommends the U.S. Department of Health and Human Services (HHS):

■ HHS Office of Civil Rights (OCR) should develop additional guidance for healthcare providers to 

actively prepare and plan for an increase of people with disabilities requiring healthcare services 

during disasters.

■ HHS and the National Advisory Council on Innovation & Entrepreneurship (NACIE) should launch a 

multiagency national emergency management strategy to help states plan for an increase in the 

number of people with disabilities to mitigate risks during disasters.

■ HHS should provide guidance on standardized disability categories and levels to inform federal and 

SLTT government emergency management planning. The methodology should be used at all levels 

of government to ensure complete and consistent data collection.

■ HHS commission a study to identify health disparities and gaps in access to healthcare in relation 

to extreme weather impacts on people with disabilities, older adults, tribal nations, and other 

impacted communities. HHS should also identify strategies to mitigate those gaps.

■ HHS Office of the Assistant Secretary for Preparedness and Response (ASPR), when replenishing 

the Strategic National Stockpile (SNS), should coordinate with SLTT partners on available 

equipment that can be requested from the SNS and provide or update guidelines on how to 

request such equipment.

■ HHS ASPR should require that states develop written emergency evacuation plans and response 

procedures for CCFs that include situation assessment and plans for protecting residents, staff, 

volunteers, visitors, equipment, medications, and vital records as part of the states’ assisted living 

licensing and regulation requirements.

■ HHS and Department of Justice (DOJ) should issue joint guidance and provide technical 

assistance to SLTTs and shelter planners on the ADA and other legal requirements as well as 

Crisis Standards of Care (CSC) requirements for all shelters.

■ HHS should approve Appendix K waivers for SLTT partners to pay legally responsible relatives to 

provide care during disasters.

■ HHS CMS should cease issuing waivers that allow people with disabilities to be institutionalized 

in the absence of accessible shelters and services. Absent an alternative, if waivers are issued, 

120 National Council on Disability
SLTTs should require EMAs to immediately remedy or face severe penalties with a stipulation that 

the people institutionalized be moved into other accessible accommodations within a specified 

short timeframe or additional penalties will be applied.

NCD Recommends the U.S. Department of Homeland Security (DHS)

■ NCD recommends that the DHS CRCL and/or the DOJ DRS and other appropriate governing 

bodies should prioritize and strengthen oversight and enforcement capabilities to ensure 

recipients and sub recipients of federal funds comply with the scope of their obligations to 

people with disabilities.

■ NCD recommends that the DHS CRCL and the DOJ DRS, should provide guidance to SLTTs 

emergency management operations frontline efforts to ensure nondiscrimination in the provision 

of emergency and disaster-relief services, benefits, and activities.

NCD Recommends the U.S. Department of Housing and Urban Development (HUD):

■ HUD should increase the number of accessible units from the 5 percent accessibility requirement 

for federally assisted new construction housing developments to 25 percent, which represents the 

percentage of people with disabilities in the United States.

■ HUD, PIH, should expand its housing voucher program443 to offer climate vouchers for families 

affected by extreme weather events to relocate in the event their home is not habitable.

■ HUD should authorize CDBG-DR and CDBG-MIT grants to be used toward long-term relocation of 

housing projects and other infrastructure including building in safer zones or retrofitting buildings 

to be more resilient to expected weather events. HUD should work with and offer guidance to 

local leaders to help community planning and development.

■ HUD should establish and implement a Federal Flood Risk Management Standard (FFRMS); 

update/modernize HUD’s floodplain management regulations in 24 CFR part 55; extend 

increased flood protection across all HUD programs; increase flood resilience; and clarify 

processes and standards, and promote environmental justice concerns in floodplain decisionmaking.

■ HUD should update its CDBG-DR Policy Guidance for Grantees (2019) and include references to 

people with disabilities and use the CDBG to advance equity, access, and inclusion.

■ HUD should initiate a policy that will not approve funding of federal financed housing in 

floodplains.

■ HUD should require developers use materials that are more resilient to extreme weather events 

indicative of the area, for instance, metal shingles in California to mitigate wildfires, or a safe room 

in units designed for people with disabilities that should withstand high winds from hurricanes or 

tornadoes.

The Impacts of Extreme Weather Events on People with Disabilities 121
NCD Recommends U.S. Department of Justice (DOJ):

■ DOJ, in coordination with other relevant federal agencies, should provide updated comprehensive 

guidance (similar to its 2022 new Guidance on Web Accessibility444) and technical assistance to 

SLTT governments to better comply with federal civil rights and disability laws during emergency 

preparedness, response, and recovery.

■ DOJ should reissue its Advance Notice of Proposed Rulemaking regarding Nondiscrimination 

on the Basis of Disability; Accessibility of Web Information and Services of State and Local 

Government Entities.

■ DOJ and HUD should monitor and enforce compliance obligations for emergency sheltering in a 

disaster consistent with emergency sheltering requirements under the Fair Housing Amendments 

Act. Whether the disaster shelter is considered transient or long-term, the rights of people with 

disabilities in these shelters should be seamlessly protected.

■ DOJ Disability Rights Section (DRS) should update the ADA Best Practices Tool Kit for State 

and Local Governments (March 9, 2017)445 to ensure that SLTT governments have the latest 

information on ADA best practices.

■ DOJ should review websites such as the NHC to ensure that it is 508 compliant and that all 

federal webpages are accessible to people who use screen readers or other assistive technology 

devices.

NCD Recommends the U.S. Department of Labor (DOL):

■ DOL Bureau of Labor Statistics should collaborate with the National Institute on Disability, 

Independent Living, and Rehabilitation Research to commission a study on how individual 

disasters impact people with disabilities in terms of employment and economic impacts.

■ Given the dearth of data on employment losses due to natural disasters, DOL should create a 

system to collect and share data on how individual disasters impact people with disabilities in 

terms of employment.

NCD Recommends the Federal Emergency Management Agency (FEMA):

■ FEMA should more broadly publicize its mental health programs and the Substance Abuse and 

Mental Health Services Administration (SAMHSA) Disaster Distress Helpline, which provide crisis 

counseling and support to people experiencing emotional distress related to natural or humancaused disasters. FEMA should monitor SLTTs execution and accessibility of its crisis care hotline 

and provide guidance as needed to ensure programs are accessible to all disabilities.

■ FEMA should provide guidance and training to SLTT partners on the legal requirements for 

Functional Needs Support Services for general population shelters and the potential loss of shelter 

reimbursement funds and propensity for lawsuits should they not provide accessible sheltering.

122 National Council on Disability
■ The federal entity (typically FEMA and DHS) providing funds ultimately received by local 

emergency management departments should require the participation of local staff in training on 

the scope of obligations under the Rehab Act.

■ FEMA should provide guidance and training to SLTT partners on the legal requirements for 

Functional Needs Support Services (FNSS) for general population shelters and the potential loss 

of shelter reimbursement funds and propensity for lawsuits should they not provide accessible 

sheltering.

■ FEMA should monitor SLTTs’ execution and accessibility of its crisis care hotline ensuring 

accessibility for all disabilities and provide SLTTs with additional guidance as to promoting the 

availability and ease-of-use of the hotline.

■ FEMA, SLTTs, and shelter providers should join private nonprofits to develop contingency plans to 

replace lost medications and DME equipment.

■ FEMA should continue outreach to SLTTs on the requirement to provide PAS in shelters and 

advise the importance of acquiring a contract for PAS services prior to a shelter opening and 

advise SLTTs the proper method for reimbursement following disasters.

■ FEMA Administrator should communicate to Regional Administrators and RDIS a written plan 

for implementing its new disability integration staffing approach, consistent with the objectives 

established for disability integration. Such a plan should include an implementation timeline and 

details on staff responsibilities, which regions could use to evaluate staff performance.446

■ The FEMA Administrator should develop a plan for delivering training to FEMA staff that promotes 

competency in disability awareness. The plan should include milestones and performance 

measures and outline how performance will be monitored. (GAO Recommendation 6).447 The plan 

should include FEMA Disability Integration Cadre. NCD recommends FEMA should ensure its 

emergency management workforce receives formal training on guidance related to supporting 

people with disabilities prior to their deployment in a disaster response role.448 FEMA should 

lengthen its two-hour course (IS-368: Including People With Disabilities and Others With Access 

& Functional Needs in Disaster Operations (2014))449 and ensure that people with disabilities are 

consulted during course development.

■ FEMA should ensure emergency shelter providers plan for and ensure all shelters are accessible 

and compliant with the ADA and the Rehab Act to avoid the threat of institutionalization. 

Employing local disability organizations to collaborate on shelter operations will assist to ensure 

shelter facilities are more accessible to people with disabilities.

■ FEMA should revise and provide technical assistance in plain language to its IHP application 

process which would include enhancing and publishing guidance for requesting and receiving 

such services and removing any challenges related to language accessibility, literacy, technical 

expertise, or disability and the prerequisite to apply for SBA disaster loans.450

The Impacts of Extreme Weather Events on People with Disabilities 123
■ FEMA and emergency managers at all levels of government should develop strategies to manage 

multiple concurrent disasters. Federal entities and SLTTs should adjust planning and response 

protocols developed for “standard” events to satisfy new response needs. These strategies could 

include a list of anticipated gaps, prioritizations for which gaps to invest in, and proactive planning to 

manage those gaps through other means when investments are not available. This recommendation 

works both for the overarching issues and the specifics around disability inclusion.

■ FEMA should enhance its stakeholder engagement strategy to intentionally include people with 

disabilities and disability-led organizations in emergency management planning and exercises. 

FEMA should then encourage and share this strategy with SLTT EMAs.

■ FEMA, FCC, and SLTT partners should inform and encourage all SLTT emergency managers to 

utilize the full IPAWS alerting system, since IPAWs includes EAS, along with numerous other, 

more accessible, communications methods.

■ FEMA, DOJ, and FCC should review, consolidate, and enhance existing guidance for 

effective communications before, during, and after disasters, compiling these materials into a 

comprehensive guide that is distributed, and promoted, across federal, SLTT, and NGO partners.

■ FEMA, in coordination with SLTT Department of Public Works, should identify people with 

disabilities in the community at risk of heat-related illnesses and death and ensure such individuals 

have access to cooling stations. If, because of their disabilities they are unable to access cooling 

stations, portable air-conditioning units should be made available to mitigate the risk of heatrelated illness or death.

■ FEMA should hire multilingual sign language interpreters and contract for VRI services for all major 

sign languages, to meet the needs of specific communities such as Puerto Rican Spanish Sign 

Language in the United States and its territories.

■ FEMA should better inform SLTT and OFA partners that providing sign language interpreters is 

required for any activities funded by FEMA. Also, FEMA should make its VRI services available to 

all SLTT and OFA partners to ensure that SLTT partners have access to such services, whenever 

needed to support stakeholders and disaster workers who are Deaf or Hard-of-Hearing.

■ FEMA should assess the resource needs of RDIS to ensure that they are fully resourced to 

meet the needs of their SLTT partners for planning and preparedness. FEMA should assess the 

resource needs to ensure that there is a sufficient cadre of trained disability integration advisors 

(DIA), including reservists to staff all disaster operations.

■ FEMA should conduct outreach to, and training for, community organizations, to ensure that all 

interested community organizations know how to prepare for and apply for PA program Category 

B public assistance funds, when performing essential services.

■ FEMA should prioritize the implementation of the FEMA 2020 National Advisory Council 

recommendations (2020-01, 2020-02 2020-03 2020-05, 2020-06, 2020-07, 2020-08, 2020-09, 

2020-11, 2020-12, 2020-13, 2020-15, 2020-18, 2020-19, 2020-20, 2020-21, 2020-22, 2020-25a.)451

124 National Council on Disability
Implementation should ensure that the needs of people with disabilities are integrated into the 

final policy, plans, and services.

■ FEMA and SLTT partners should share their processes for capturing and disseminating disabilityrelated lessons learned and best practices.

■ FEMA should resurrect the Interagency Coordinating Council to include the U.S. Census Bureau, 

CMS, and DOT, to identify methods to efficiently, collect disability information to identify how 

many people with disabilities are affected during specific disasters, where they live or work in 

the community, and whether they have HCBS needs. This information should be used to inform 

emergency management policies and anonymized data should be regularly updated and shared 

with SLTTs.

■ FEMA should determine what steps are needed to address the nation’s emergency management 

capability gaps across all levels of government and inform federal partners, such as the Office of 

Management and Budget, and Congress, about what level of resources would be necessary to 

address the known gaps.452

■ Federal and SLTT EMAs should activate alerts via IPAWS simultaneously when they activate alert 

sirens and public address systems, to ensure alerts are accessible for people who are Deaf and 

Hard-of-Hearing.

NCD Recommends the Federal Energy Regulatory Commission (FERC):

■ Federal Energy Regulatory Commission (FERC) should work with utility companies to improve 

their power outage notification programs and create public awareness campaigns to build 

knowledge. They should improve power resiliency programs and enhance power restoration 

priority for people with disabilities who are power dependent. Additionally, utility companies 

should invest in portable generators to be made available to people with disabilities who are 

power dependent and unable to evacuate in the event of extended power outages.

NCD Recommends the National Oceanic and Atmospheric Administration (NOAA):

■ NOAA, NCEI, and the NWS should collaborate with FEMA, state EMAs, and public health 

agencies to share data and develop agile strategies to manage multiple concurrent disasters.

■ NOAA, FEMA, and/or HHS ASPR and/or ACL should promote the availability and distribution of 

adapted weather radios for people who are Deaf and Hard-of-Hearing though SLTT, Center for 

Independent Living (CIL), and NGO partners.

NCD Recommends the Rehabilitation Services Administration:

■ Rehabilitation counselors should work with disability program navigators (DPNs) (people trained 

to utilize the One-Stop Career Centers to help people with disabilities) to help navigate the web of 

career services.

The Impacts of Extreme Weather Events on People with Disabilities 125
NCD Recommends State, Local, Tribal, And Territorial (SLTT) Government Emergency 

Management Agencies (EMAs):

■ Federal and SLTT EMAs and state health departments should request congressional funding to 

surge medical resources (equipment and supplies) for disasters.

■ State health departments, in coordination with state EMAs, should plan and track medical 

infrastructure and medical equipment and equipment stockpiles, (e.g., medications, generators, 

PPE, and necessary medical equipment like oxygen, dialysis machines, wheelchairs, and other 

DME) to ensure availability and distribution in a disaster, especially in U.S. territories.

■ Federal and SLTT governments should encourage the construction of universally designed 

accessible housing units by passing universal design ordinances that go beyond the ADA and 

incentivize builders to offer accessibility features to buyers as upgrades.

■ HUD should provide guidance to CDBG recipients of the requirement to comply with federal 

disability rights laws and require the incorporation of universal design in any rebuild to ensure 

accessibility for PWDs.

■ No federal funds—including but not limited to federal funds from DHS and HHS—should be 

used in development, deployment, and maintenance of emergency “special needs” registries 

exclusively created for people with disabilities. Instead of registries, SLTTs should take an 

innovative, holistic, and inclusive approach to include people with disabilities in their overall 

emergency management plans.

■ SLTTs should develop/update shelter management plans with clear roles and responsibilities that 

fully integrate the needs of people with disabilities to meet legal requirements.

■ SLTTs and emergency planners should involve people with disabilities and disability organizations 

in emergency evacuation planning, ensuring that shelters are physically accessible, and provide 

guidance on post-evacuation residency for individuals with disabilities.

■ FEMA, SLTTs, and NGOs (e.g., the Red Cross or religious organizations) should provide adequate 

planning and training, to include disability cultural competency training and resources, including 

supplies and equipment, to staff working in shelters, health care professionals, first responders, 

and search-and-rescue teams to better support people with disabilities in shelters. Expand training 

to individuals and community groups and recruit, train, and provide clearance for volunteers 

with specific skill sets, such as interpreters, mental health professionals, counselors, behavioral 

therapists, and PCAs.

■ SLTT EMAs should ensure that shelter staff receives specific training to address the needs of 

people with IDD and mental/behavioral health issues.

■ Federal agencies and private sector employers should offer remote work as an option, especially 

after a disaster where people with disabilities who rely on public transportation may not have 

access to transportation or paratransit services.

126 National Council on Disability
■ All federal and SLTT EMA’s should engage people with disabilities, disability organizations, and 

CBO’s in disaster management planning. Ensuring that recommendations and concerns from 

people with disabilities are prioritized and incorporated into any disaster management plan.

■ SLTTs should put in place state HSAC teams. State HSAC teams meet regularly with and 

coordinate with public health, NGOs, and other area agencies to plan and better understand how 

to work together during response.

■ Federal and SLTT EMAs should hire people with disabilities into decision-making or leadership 

roles to help inform emergency management policy and planning.

■ Tribal Nations should form Disability Advisory Councils to liaise with federal, state, and local EMAs.

■ State EMAs should work with Tribal Nations to develop emergency management plans that 

specifically include people with disabilities. FEMA, IHS, and BIA should advise and support these 

efforts.

■ Tribal Nations should put in place personal preparedness plans and create CMIST453

 response 

teams to prepare their communities. Examples of personal preparedness plans are found at 

https://www.ready.gov/disability.

■ SLTT partners should incorporate provisions for accessible transportation in their Emergency 

Operations Plans. Such incorporation should include analysis of the required demand for such 

services and appropriate contracts, agreements, and MOUs to support that demand in an 

emergency. Appropriate contracts should include emergency requirements such as ensuring 24/7 

availability on short notice, with costs being charged to the jurisdiction, rather than passengers. 

Such agreements do not need to be commercial contracts. In fact, mutual aid agreements with 

other jurisdictions and/or NGOs may be the most effective and cost-effective options, provided 

that both partners are not impacted by the same disaster.

■ Federal agencies responsible for emergency preparedness, community resilience, and disasterrelated services, programs, supports, or activities should engage with national, state, and local 

coalitions of disability-led organizations and stakeholders. These federal agencies include but are 

not limited to: DHS, FEMA, CRCL, HHS, ASPR, ACL, CDC, HUD, DOT, DOJ, DRS, ED, OSERS, 

DOL, the Office of Disability Employment (ODEP), DOD, Veterans Affairs, and U.S. Access Board.

The Impacts of Extreme Weather Events on People with Disabilities 127
Appendix C: Figures, Tables, and Map Descriptions

Data: FEMA National Risk Index (NRI) All Hazards Risk Rating in U.S.

Description:

The purpose of this map is to identify risks of extreme weather events in the United States and its 

territories.

It is a map of the United States with all 50 states shown. It shows where extreme weather events 

are concentrated in the United States by county. It uses the FEMA National Risk Index – All Hazards 

data. FEMA’s National Risk Index – All Hazards includes ratings for 18 natural hazards for each county 

in the United States. The next iteration of the FEMA National Risk Index will likely include U.S. 

territories.

The risk is categorized from Very High, Relatively High, Relatively Moderate, Relatively Low, to Very 

Low. The map uses shading of green from dark green to light green to illustrate Very High (dark green) 

to Very Low (light green). The map highlights U.S. counties in dark green that have a risk rating of “Very 

High” when it comes to all hazards. Risk ratings are based on a risk score. The map shows there is 

particularly high risk (or dark green) of natural hazards along the West Coast, specifically in Southern 

California, the Gulf Coast, and Florida.

Data: United States Census Bureau American Community Survey (ACS), Disability Status Variables 

(2015–2019) data; CDC (2019); Census Bureau (2010).

Description:

The purpose of this map is to identify locations in the United States with high percentages of people 

with disabilities.

This is a map of the United States with all 50 states shown. It also includes Guam and the 

Mariana Islands on the bottom left, and Puerto Rico and the U.S. Virgin Islands on the lower right 

side. The map uses U.S. Census Bureau, American Community Survey, Disability Status Variables 

128 National Council on Disability

Figure 1: FEMA National Risk Index (NRI) – All Hazards Risk Rating in U.
(2015–2019) data; Centers for Disease Control and Prevention (CDC) (2019) data; and Census Bureau 

(2010) data sets.

The map shows the percentage of people with a disability in each county of the United States. The 

map uses shading of blue from dark blue to light blue to illustrate the percentage of the population 

with a disability. The percentages range from less than 10 percent to over 30 percent. The lowest 

percentages are in the Plains and Midwest and the highest percentages are in Appalachia. There are 

concentrations of higher percentages of people with disabilities in Arizona, New Mexico, Texas, and 

Kentucky.

Data: FEMA National Risk Index (NRI) – All Hazards data and Census Bureau ACS, Disability Status 

Variables (2015–2019). National Geospatial Data Asset (NGDA) from the U.S. Census Bureau

Description:

The purpose of this map is to show the risks of extreme weather events in the United States overlaid 

with locations in the U.S. with high populations of people with disabilities to identify where in the 

country people with disabilities are more at risk of natural hazards by county.

The map is a combination or layering of the FEMA National Risk Index – All Hazards data and the 

U.S. Census Bureau, American Community Survey, Disability Status Variables (2015–2019) data sets. 

The map also uses Federally Recognized Tribal Entities data from the National Geospatial Data Asset.

The map shows a circle filled in with green for every county in the United States. The circles scale 

from small to large, with the larger dark green circles indicating counties that have high national risk 

index ratings and high populations of people with disabilities.

The map highlights areas in the Bay Area in California, Southern California, Eastern Texas, and 

Florida, where there is a concentration of people with disabilities at high-risk of extreme weather 

events.

Figure 2. Percentage of Populations with a Disability in U

The Impacts of Extreme Weather Events on People with Disabilities 129
130 National Council on Disability

Figure 3: National Risk Index (All Hazards) with Population of People with 

Disabilities by County
Appendix D: Definitions and Terminology

Assistive Technology (AT)

■ AT is any item, piece of equipment, software program, or product system that is used to increase, 

maintain, or improve the functional capabilities of people with disabilities.

■ AT helps people who have difficulty speaking, typing, writing, remembering, pointing, seeing, 

hearing, learning, walking, and many other things. Different disabilities require different assistive 

technologies.

Compounded Poverty

■ Compounded poverty occurs when a series of circumstances and challenges work together to 

create or exacerbate barriers to economic stability.A

Disability

■ The ADA defines a person with a disability as a person who has a physical or mental impairment 

that substantially limits one or more major life activity. This includes people who have a record of 

such an impairment, even if they do not currently have a disability. It also includes individuals who 

do not have a disability but are regarded as having a disability. The ADA also makes it unlawful to 

discriminate against a person based on that person’s association with a person with a disability.454

Disproportionate Impacts/Effects

■ Term used in Executive Order 12898 to describe situations of concern with significantly higher 

and more adverse health and environmental effects on marginalized populations, low-income 

populations, or indigenous peoples.455

Equity

■ The term equity means the consistent and systematic fair, just, and impartial treatment of all 

people, including people who belong to underserved communities that have been denied such 

treatment, such as Black, Latino, Indigenous and Native Americans, Asian Americans, and Pacific 

Islanders, and other persons of color; members of religious minorities; lesbian, gay, bisexual, 

transgender, and queer (LGBTQ+) persons; people with disabilities; people who live in rural areas; 

and people otherwise adversely affected by persistent poverty or inequality.456

■ Equity, related to bias, is the inclusion of more granular race, ethnicity, disability, and gender 

identity demographic information (2021). An equity model that simply treats everyone the same 

“fails individual patients and communities. Assist those with the greatest financial need (2021).”457

A https://www.theatlantic.com/business/archive/2016/04/how-poverty-compounds/478539/

The Impacts of Extreme Weather Events on People with Disabilities 131
■ Equity is a state whereby all people achieve a certain minimum outcome. For example, equity in 

housing would mean that everyone in a community meets a minimum housing threshold (i.e., that 

they are not homeless). See also equality.

458

Equality

■ “The nation’s proper goals regarding individuals with disabilities are to assure equality of 

opportunity, full participation, independent living, and economic self-sufficiency for such 

individuals” (emphasis added), (2020).459

Extreme Weather Events

■ An extreme event is a time and place in which weather, climate, or environmental conditions—

such as temperature, precipitation, drought, or flooding—rank above a threshold value near the 

upper or lower ends of the range of historical measurements. Though the threshold is subjective, 

some scientists define extreme events as those that occur in the highest or lowest 5 percent or 

10 percent of historical measurements. They often describe events by how far they are from the 

mean or by their recurrence interval or probability.460

Fair Treatment

■ Fair treatment means no group of people should bear a disproportionate share of the negative 

environmental consequences resulting from industrial, governmental, and commercial operations or 

policies.461

Indigenous People/Tribal Nations

■ Considering the diversity of indigenous peoples, an official definition of indigenous has not been 

adopted by any UN-system body. Instead, the system has developed a modern understanding of 

this term based on the following:

❍ Self-identification as indigenous peoples at the individual level and acceptance by the 

community as a member

❍ Historical continuity with pre-colonial and/or pre-settler societies

❍ Strong link to territories and surrounding natural resources

❍ Distinct social, economic, or political systems

❍ Distinct language, culture, and beliefs

❍ Form nondominant groups of society

❍ Resolve to maintain and reproduce their ancestral environments and systems as distinctive 

peoples and communities462

132 National Council on Disability
Low Income

■ A reference to populations characterized by limited economic resources. The U.S. Office of 

Management and Budget has designated the Census Bureau’s annual poverty measure as the 

official metric for program planning and analysis, although other definitions exist.463

Marginalized

■ Marginalized means those who have been forced to fall backward politically, economically, and 

socially; those who have been unable to use services because of discrimination, harassment, and 

geographical disconnection; and those communities whose standard of living has been below 

the legal standard as specified in the human development indicators. It also signifies the ultramarginalized and communities on the verge of extinction.464

Under-Served Populations

■ According to the U.S. Census Bureau, populations of people who are not single-race White and 

non-Hispanic, including members of the following population groups: American Indian or Alaskan 

Native; Asian or Pacific Islander; Black, not of Hispanic origin; or Hispanic.465

Network

■ Related to a personal support network.466

People with Disabilities

■ The ADA defines a person with a disability as a person who has a physical or mental impairment 

that substantially limits one or more major life activity. This includes people who have a record of 

such an impairment, even if they do not currently have a disability. It also includes individuals who 

do not have a disability but are regarded as having a disability. The ADA also makes it unlawful to 

discriminate against a person based on that person’s association with a person with a disability.467

■ To be protected by the ADA, one must have a disability or have a relationship or association with an 

individual with a disability. An individual with a disability is defined by the ADA as a person who has 

a physical or mental impairment that substantially limits one or more major life activities, a person 

who has a history or record of such an impairment, or a person who is perceived by others as having 

such an impairment. The ADA does not specifically name all of the impairments that are covered.468

People of Color (POC):

■ A term primarily used in the United States and Canada to describe any person who is not White. 

It does not solely refer to African Americans; rather, it encompasses all Nonwhite groups and 

emphasizes the common experiences of systemic racism.469

The Impacts of Extreme Weather Events on People with Disabilities 133
Underserved Communities

■ The term underserved communities refers to populations sharing a particular characteristic, 

as well as geographic communities, that have been systematically denied a full opportunity to 

participate in aspects of economic, social, and civic life, as exemplified by the list in the preceding 

definition of equity.470

Vulnerable and At-Risk Populations

■ Vulnerable people are those who are relatively (or absolutely) incapable of protecting their own 

interests. More formally, they may have insufficient power, intelligence, education, resources, 

strength, or other needed attributes to protect their own interests.471

■ Vulnerable people are those “unnoticed and ignored by public health officials” and “people pushed 

to the back of the treatment line.”472

Sources

■ A concise summary of evaluating sources includes the author’s credentials or authority, 

the purpose of the source, the intended audience, the quality of the publisher, currency of 

information, and accuracy and objectivity.473

■ Credible academic sources include materials published within the last 10 years, research articles 

written by respected and well-known authors, websites registered by government and educational 

institutions (.gov,.edu,.ac), academic databases (i.e., Academic Search Premier or JSTOR), and 

materials from Google Scholar.474

Risk

■ The potential for an unwanted outcome resulting from an incident or occurrence, as determined 

by its likelihood and the associated consequences.475

Threat

■ A natural or manmade occurrence, individual, entity, or an action having or indicating the potential 

to harm life, information, operations, the environment, and/or property.476

Additional FEMA Definitions

Access/Accessible

■ The suitability or adaptability of programs, services, activities, goods, facilities, privileges, 

advantages, or accommodations provided by a public or private (for-profit or not-for-profit) entity, 

or by any entity with which it contracts, for all members of the population, including people 

with disabilities.477

134 National Council on Disability
Equity

■ The FEMA definition, which is aligned to EO 13985, is “the consistent and systematic fair, just, 

and impartial treatment of all individuals.” FEMA’s overarching equity principle, as aligned to 

the agency’s mission statement, is “ensuring all people are helped before, during, and after 

disasters.”478

■ The core definition of equity is to provide the greatest support to those with greatest need to 

achieve a certain minimum outcome. It is separate from equality, which is providing the same 

resources to everyone regardless of need. One of the core tenets of emergency management 

is to work to stabilize and heal communities from the disruption caused by disaster. As such, it 

is important to recognize the role that equity plays in communities’ ability to mitigate, prepare, 

respond, and recover from a disaster, and by extension, FEMA’s role in supporting that effort.479

Whole of Community

■ The whole community is an inclusive approach to emergency preparedness and management 

through the inclusion of individuals and families, including those with access and functional needs; 

businesses; faith-based and community organizations; nonprofit groups; schools and academia; 

media outlets; and all levels of government, including SLTT and federal partners.

The Impacts of Extreme Weather Events on People with Disabilities 135
Appendix E: Policies, Laws, and Regulations

This section provides an overview of how select legislation applies to extreme weather events and 

people with disabilities.

Achieving a Better Life Experience Act (ABLE Act)

The ABLE Act, which was signed into law on December 19, 2014, is designed to improve the financial 

stability of people with disabilities by authorizing tax-advantaged savings accounts, known as ABLE 

accounts, for youth and adults with disabilities. The law recognizes that many individuals and their 

families depend on a wide variety of means-tested public benefits for income, health care, food, and 

housing assistance. Eligibility for many of these benefits requires applicants to have few assets. Thus, 

to remain eligible for these programs, an individual must remain poor.

ABLE account funds and distributions for qualified disability-related expenses are not taken into 

consideration when determining eligibility for federally funded means-tested benefits, including SSI 

and Medicaid. According to language in the ABLE Act, an ABLE account will, with private savings, 

“secure funding for disability-related expenses on behalf of designated beneficiaries with disabilities 

that will supplement, but not supplant, benefits provided through private insurance, Medicaid, SSI, the 

beneficiary’s employment, and other sources.”

These accounts are similar in construction to college savings accounts; both are included in 

Section 529 of the IRS Code. Assets in ABLE accounts can be used to cover any “qualified disability 

expense” including housing, transportation, support services, and any other expense reasonably 

related to a disability.

An ABLE account may not receive annual contributions exceeding the annual gift-tax exemption 

($14,000 in 2015). A state must also ensure that aggregate contributions to an ABLE account do not 

exceed the state-based limits for 529 accounts.

Affordable Housing Act (AHA)

Officially passed as the Cranston-Gonzalez National Affordable Housing Act of 1990, this law 

established programs focused on housing and economic development programs HOME, Housing 

Opportunities for Persons With AIDS (HOPWA), Shelter Plus Care programs, and established the 

Section 811 Supportive Housing for Persons With Disabilities program and the HOPE programs that 

promoted homeownership opportunities for low-income individuals and people with disabilities. (Public 

Law 101-625)

Americans with Disabilities Act (ADA) 480

The ADA, enacted in 1990 and amended in 2008, prohibits discrimination on the basis of 

disability in employment, state and local government programs, services and activities, public 

accommodations, and commercial facilities. The goal of the ADA is to ensure full participation 

in society for people with disabilities by facilitating equal opportunity, independent living, and 

economic self-sufficiency.

136 National Council on Disability
Title I: Employment

Title I of the ADA prohibits discrimination against people with disabilities in employment both before 

and after they are hired. Access to employment is one of the most important issues affecting 

people with disabilities. Although the ADA has led to increases in accessibility and accommodations 

in employment and public awareness about the capabilities of people with disabilities, there has 

been little change in available employment opportunities for people with disabilities. Reasonable 

accommodations are required for job applicants and employees with disabilities among employers 

with more than 15 employees. However, attitudes and stereotypes about the cost of reasonable 

accommodations and the abilities of people with disabilities persist.

Title II: State and Local Governments

Title II of the ADA requires that state and local governments give people with disabilities an equal 

opportunity to benefit from all state programs, services, and activities (e.g., public education, employment, 

transportation, health care, and social services) in compliance with regulations determined by DOJ. Title 

II also prohibits discrimination against people with disabilities for public transportation services. Under 

Title II, state and local governments must provide accessible buses, subways, or commuter rails, and also 

provide paratransit services in all areas where they operate fixed-route bus or rail systems.

Olmstead v. L.C. (1999) was the landmark case which determined that “unjustified isolation” of a person 

with a disability is a form of discrimination under Title II of the ADA. Under the decision, if a state treatment 

professional determines that community placement is appropriate, then a person with a disability should 

be placed in the community, if the person with a disability chooses. This case had a significant impact on 

the opportunities for people with disabilities to live and fully participate in their communities.

Title III: Public Accommodations and Commercial Facilities

Title III of the ADA requires places of public accommodation and commercial facilities to meet 

accessibility standards. All new construction as well as existing structures must conform to the 

ADA Accessibility Guidelines. Existing structures must remove architectural barriers if doing so can 

be accomplished easily and without significant expense. Places of public accommodation include 

restaurants, hotels, shopping centers, doctor’s offices, and day care centers.

While the applicability of web accessibility is not explicitly addressed in the ADA, recent lawsuits 

(since approximately 2016) and DOJ actions have made this question an increasing concern over the 

past few years. DOJ recently issued new web accessibility guidelines for entities covered by Titles 

II and III https://www.justice.gov/opa/pr/justice-department-issues-web-accessibility-guidance-underamericans-disabilities-act.

481

Architectural Barriers Act of 1968

“The Architectural Barriers Act (ABA) of 1968, as amended, stipulates that all buildings which are (1) 

financed with federal funds, and (2) intended for use by the public, or which may result in employment 

or residence therein of physically handicapped persons, be designed and constructed in accordance 

The Impacts of Extreme Weather Events on People with Disabilities 137
with standards prescribed by the ABA to ensure that such buildings are fully accessible to and usable 

by handicapped individuals. The Act is enforced by the Architectural and Transportation Barriers 

Compliance Board (ATBCB), a federal agency created by Section 502 of the Rehabilitation Act of 1973, 

as amended. On May 9, 1983, the Secretary of Labor and the Executive Director of the ATBCB entered 

into a memorandum of agreement (MOA) whereby the Department agreed to implement a DOL-wide 

accessibility compliance system. This system, which must meet certain minimum criteria set forth by 

the Board, is intended to ensure full compliance with applicable GSA accessibility standards issued 

pursuant to the ABA. In return, the Board has agreed to refrain from initiating enforcement proceedings 

against DOL for noncompliance with accessibility standards if its Executive Director has approved a 

detailed plan for removal of barriers in covered buildings or facilities.”482 Additionally, the ADA builds 

upon the ABA and refers to the ATBCB and assigns it with the authority to define the standards for the 

architectural and communication barriers that are structural in nature.483

Assistive Technology Act of 1998

Initially passed in 1998, and reauthorized in 1994 and again in 1998 and 2004, the Act establishes a 

grant program to provide federal funds to support state programs that address the assistive technology 

needs of people with disabilities. With funds from this program, every state and territory in the 

United States established a Tech Act project (there are currently 54). These projects have developed 

individualized plans to meet state assistive technology needs in specific areas, including financing, 

technical assistance, education, training and other leadership activities, device reutilization, device loan, 

device demonstration, and device referral services.484 In the past, FEMA has had an MOU with the AT 

Act Projects to access their AT Reuse Programs in an emergency as a means of replacing/restoring 

lost DME and AT during a disaster. Many local governments have similarly established partnerships for 

smaller scale weather-related emergency responses with these projects.

Fair Housing Amendments Act of 1988 485

Title VIII of the Civil Rights Act of 1968, known as the Fair Housing Act, prohibited discrimination 

concerning the sale, rental, and financing of housing based on race, religion, national origin, and sex. 

The Fair Housing Amendments Act of 1988 (PL 100-430) expanded this to include disability and family 

status.486

Housing Act

Initially passed as the National Housing Act of 1934, which created the FHA “to encourage 

improvements in housing standards and conditions (and) to provide a system of mutual mortgage 

insurance.” (Public Law 73-479). The law has been amended numerous times to create a range of social 

service public housing programs. Examples include: the United States Housing Act of 1937, which 

created the public housing program (PL 75-412); the Housing Act of 1949 to establish grant programs 

to assist state and local governments; the Housing Act of 1959 that established Section 202 Supportive 

Housing for the Elderly program and the FHA Mortgage Insurance for Nursing Homes program. (Public 

138 National Council on Disability
Law 86-372); and the Housing and Community Development Act of 1974, which created community 

development block grants for state and local governments and established Section 8 rent subsidies 

for low-income families. (Public Law 93-383) Section 8 additional amendments have expanded these 

programs throughout the years, and introduced vouchers to the Section 8 program. (For a complete 

timeline of Housing Act Statutes, see https://www.hud.gov/hudprograms/keystatutes). Twenty-five 

percent of those receiving rental assistance in the United States have disabilities, 20 percent are 

seniors, and 69 percent are seniors, children, or people with disabilities.487

Individuals with Disabilities Education Act (IDEA) 488

The IDEA, enacted in 1975 (at the time called the Education for All Handicapped Children Act, or EHA) 

and reauthorized in 1990 and 2004, ensures that free public education resources are allocated to 

students with disabilities to meet their unique needs. IDEA ensures that students with disabilities have 

the same opportunities as other students. It mandates that students with disabilities who attend public 

schools receive a free appropriate public education that is tailored to their individual needs. The Office 

of Special Education Programs was created to help states with the implementation of IDEA.

Under IDEA, students in special education programs are expected to learn in the least restrictive 

environment, which means they spend as much time in an integrated classroom with their peers 

who do not receive special education services. Separate classes and schools are recommended only 

in cases where the disability is so severe that aids and services in the general education classroom 

are not adequate. How much time students with disabilities spend in general education classes will 

vary based on what is most appropriate for each student. School IEP teams work to ensure the most 

appropriate learning environments for each student.

IEPs are local, not national, and services and supports created or granted by an IEP in one educational 

district does not guarantee the same services or supports will be provided in another locale. IEPs take 

a significant amount of time to create, typically at least 30 to 90 days, assuming all tests, records, and 

medical information is available to the student/family, longer if new testing or assessments or medical 

records must be created. Budget and moneys for supports are set on an annual basis a year in advance, 

based on the currently enrolled students. Money for supports do not transfer with the student.

Medicaid Buy-In

The Ticket to Work Act also created the Medicaid Buy-In program, which offers Medicaid coverage to 

people with disabilities whose income is higher than the allowable substantial gainful activity levels. 

The purpose of the Medicaid Buy-In program is to allow people with disabilities to purchase Medicaid 

coverage while still being able to work. The eligibility requirements and benefits for this optional 

Medicaid program vary across states. Most states review employment status, disability status, income, 

and resources to determine Medicaid Buy-In eligibility. Some states require people who are eligible for 

the Medicaid Buy-In to pay a monthly premium or other cost-sharing charges, which are typically set on 

a sliding fee scale based on income. Many buy-in programs charge a state-specific premium and have 

copayments that are higher than traditional Medicaid.

The Impacts of Extreme Weather Events on People with Disabilities 139
Medicare Durable Medical Equipment, Prosthetics/Orthotics & Supplies Rules

CMS sets the fee services and rules that govern DMEPOS. In addition to setting the reimbursement 

and coverage fees for DMEPOS, the fee guidelines also state the frequency for which DMEPOS items 

may be purchased. Typically, private insurers adopt similar fee and replacement schedules as set forth 

by CMS. Traditionally, there is no exception in the guidelines for items lost or damaged during extreme 

weather events or other emergency disasters.489 However, CMS/Medicare is now replacing some 

DMEPOS and medications lost in disasters if the equipment/medicine was originally purchased under 

Medicare, there is a state or federal disaster declaration or federal public health emergency; and the 

proper disaster codes are placed on the form.490

Patient Protection and Affordable Care Act (ACA)

The ACA, which was signed into law in 2010, requires hospitals and primary care physicians to shift 

their focus to better health outcomes and lower costs enhancing the distribution and accessibility of 

their professional practices. Among the provisions in ACA is the creation of essential health benefits 

required as part of private insurance coverage. ACA Sections 1302(b)(4)(B) and (C) define essential 

health benefits and indicate that providers shall “not make coverage decisions or design benefits in 

ways that discriminate against matching dollars with no waiting list or caps.” In National Federation of 

Independent Business (NFIB) v. Sebelius, the Supreme Court decided that states were not mandated 

to expand Medicaid coverage.

Rehabilitation Act of 1973 (Rehab Act)

(Section 501) Section 501 of the Rehabilitation Act prohibits federal executive branch agencies, 

including the U.S. Postal Service and the Postal Rate Commission, from discriminating against qualified 

people with disabilities. It requires executive branch agencies to take affirmative action in the hiring, 

placing, and advancing of people with disabilities.491

(Section 503) Section 503 of the Rehab Act prohibits federal contractors and subcontractors from 

discriminating in employment against people with disabilities and requires employers take affirmative 

action to recruit, hire, promote, and retain these people.492

(Section 504): Section 504 prohibits discrimination on the basis of disability by any program or 

activity receiving federal financial assistance. It requires compliance with specific standards for design 

and construction of new facilities and ensures the accessibility of programs as a whole.493 Section 504 

has also been used to apply to require accommodations and access to public education for people with 

disabilities who may not require special education and related services under IDEA.

(Section 508): Section 508 requires federal agencies to develop, procure, maintain or use 

Information and Communications Technology (ICT) that is accessible to people with disabilities. ICT is 

any equipment used to create, convert, duplicate, or access information and data, including, without 

limitation to: telephones, mobile devices, televisions, DVD players, video productions, web content, 

electronic documents, online trainings, webinars, teleconferences, software, hardware, lab equipment, 

140 National Council on Disability
and computers. Most states have their own version of section 508 (see https://www.section508.gov/

manage/laws-and-policies/state/).

Stafford Act of 1988

Executive Order 13347 sets forth the role of the Federal Government in effectively addressing the issue 

of Individuals with Disabilities in Emergency Preparedness.494 Sec. 308. Nondiscrimination in Disaster 

Assistance (42 U.S.C. 5151) (a) Regulations for Equitable and Impartial Relief Operations states the 

President shall issue, and may alter and amend, such regulations as may be necessary for the guidance 

of personnel carrying out federal assistance functions at the site of a major disaster or emergency. 

Such regulations shall include provisions for insuring that the distribution of supplies, the processing 

of applications, and other relief and assistance activities shall be accomplished in an equitable and 

impartial manner, without discrimination on the grounds of race, color, religion, nationality, sex, age, 

disability, English proficiency, or economic status.495

Supplemental Security Income (SSI)

SSI is a federal supplemental income program funded by general tax revenues (not Social Security taxes). 

SSI includes a number of work incentives designed to help beneficiaries go to work by minimizing the risk 

of losing their SSI or Medicaid benefits. Under some of these incentives, SSA will exclude some income 

or resources when calculating the benefit amount (such as the earned income exclusion, the student 

earned income exclusion, impairment-related work expenses, and the Plan for Achieving Self Support). 

Other incentives provide continued Medicaid coverage even when the beneficiary is not receiving cash 

benefits (such as the Medicaid Buy-In and section 1619(b) of the Social Security Act).

Social Security Disability Insurance (SSDI)

SSDI is funded by payroll tax contributions from workers and employers. In order to qualify for benefits, 

applicants must reach insured status for Social Security by working enough during the years before 

filing to have contributed a specific amount to the Social Security system through FICA taxes. The level 

of benefits is based on earnings prior to the onset of the disability; SSDI does not consider assets 

or other household income. SSDI benefits are subject to a five-month waiting period, which means 

that SSDI applicants must wait five months after the onset of their disability to receive cash benefits. 

Most SSDI beneficiaries are eligible for Medicare after a two-year waiting period. Like SSI, disability 

is defined as the inability to engage in “substantial gainful activity” because of “one or more severe 

physical or mental impairments that are expected to last at least a year or result in death.”

Telecommunications Act of 1996

A comprehensive law overhauling regulation of the telecommunications industry, revolutionized access 

to telecommunications for people with disabilities through Section 255 of the Act, which requires 

telecommunications products and services to be accessible to people with disabilities, to the extent 

The Impacts of Extreme Weather Events on People with Disabilities 141
readily achievable. Covered products included wired and wireless telecommunication devices, pagers, and 

fax machines, other products that have telecommunications capabilities, and equipment that carriers use 

to provide services. Manufacturers must ensure that products are “designed, developed, and fabricated to 

be accessible to and usable by individuals with disabilities” when it is readily achievable to do so. The U.S. 

Access Board was given the job of developing guidelines that describe what makes telecommunications 

products accessible, and the FCC is responsible for rules and policies to enforce the law.496

Twenty-First Century Communications and Video Accessibility Act of 2010

Requires advanced communications services and products to be accessible by people with disabilities.

Workforce Innovation and Opportunity Act (WIOA)

WIOA, signed into law in 2014, is designed to “help job seekers access employment, education, 

training, and support services to succeed in the labor market and to match employers with the skilled 

workers they need to compete in the global economy.” The Act reauthorizes and amends the Workforce 

Investment Act (1998) and amends the Adult Education and Family Literacy Act, the Wagner-Peyser Act, 

and the Rehab Act.

WIOA programs operate through a network of local centers in each state called AJC, which 

provide youth job training, education, and employment services at a single location. AJCs provide 

skills assessments, information on employment, information on training opportunities, job search and 

placement assistance, up-to-date information on job vacancies, and transition services to job seekers 

regardless of their disability status.

Work Incentives Planning and Assistance (WIPA)

The primary objective of the WIPA initiative is to assist SSA beneficiaries with transitioning from 

dependence on public benefits to paid employment and greater economic self-sufficiency. WIPA 

projects hire and train Community Work Incentives Coordinators (CWICs) to provide in-depth 

counseling to SSI and SSDI beneficiaries about benefits and the effect of work on those benefits. All 

WIPA services are free. In addition, the CWICs conduct outreach efforts to SSI and SSDI beneficiaries 

(and their families) who are potentially eligible to participate in federal or state work incentives 

programs and work in cooperation with federal, state, and private agencies and nonprofit organizations 

that serve SSI and SSDI beneficiaries with disabilities.

142 National Council on Disability
Endnotes

1 FEMA, “How a Disaster Gets Declared,” last modified January 4, 2022, https://www.fema.gov/disaster/

how-declared.

2 NCD, Preserving Our Freedom: Ending Institutionalization of People with Disabilities During and After Disasters 

(2019), https://www.ncd.gov/sites/default/files/NCD_Preserving_Our_Freedom_508.pdf, accessed October 

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