Flood Insurance: Participation of Indian Tribes in Federal and Private Programs
Published: 2013-01-04T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Indian tribes' participation in NFIP is extremely low, even though some Indian lands are at high risk of flooding. In response to a Moving Ahead for Progress in the 21st Century Act mandate, GAO examined (1) factors affecting Indian tribes' participation in NFIP, (2) FEMA's efforts to increase tribes' participation in NFIP, and (3) administrative and legislative actions that could increase tribes' participation. GAO reviewed FEMA data on community participation in NFIP and prior GAO reports on flood insurance and Indian tribes, interviewed officials from selected Indian tribes and insurance companies, and collected information from relevant agencies and industry officials.
section_title: What GAO Found
paragraphs: As of August 2012, just 37 of 566 federally recognized tribes (7 percent) were participating in the National Flood Insurance Program (NFIP), and 3 tribes accounted for more than 70 percent of policies. A number of factors have affected tribes' participation. First, the Federal Emergency Management Agency (FEMA) has not placed a high priority on mapping rural areas, including many Indian lands, for flood risk, and most tribal lands remain unmapped. Without flood hazard maps, tribal communities may be unaware of their flood risk, even in high-risk areas. Partly for this reason, the risk of flooding is perceived as relatively low on many tribal lands. Further, tribes may lack the resources and administrative capacity needed to administer NFIP requirements, and NFIP premiums are often too high for low-income tribal members. Finally, unique tribal issues can make participation difficult. For example, some Indian tribes do not have reservations over which they can enact and enforce the land use ordinances that are required for NFIP participation. Instead, many have lands that were allotted to individuals rather than to a tribal entity, limiting the tribes' jurisdiction.
FEMA has done some outreach to tribes, largely through emergency management and homeland security training for tribal officials, technical assistance to tribes that are preparing their multihazard mitigation plans, and marketing through the NFIP FloodSmart campaign. FEMA officials told us that the courses offered through its Emergency Management Institute helped to educate tribal officials about NFIP and floodplain management and that its curricula included courses for floodplain managers on their roles and responsibilities, flood insurance, and NFIP rules and regulations. One tribal representative told us that he was participating in an ongoing curriculum and several tribes had developed multihazard mitigation plans. Finally, both the Department of Housing and Urban Development and the U.S. Department of Agriculture, Rural Development may provide NFIP information to Indian tribes as they provide assistance in the form of housing and infrastructure grants, loans, and loan guarantees.
Tribal representatives suggested steps that FEMA could take to encourage participation in NFIP--for example, placing a higher priority on mapping Indian lands and increasing FloodSmart marketing to tribal leaders rather than individuals. Given ongoing congressional interest in private sector alternatives to NFIP, GAO also explored whether private alternatives exist that could offer affordable coverage to low-income tribal members--for example, by expanding access to risk-pooling programs that could help insure more tribal households. One such program already insures thousands of Indian properties. Another relatively new product, microinsurance, would involve insurers offering less expensive policies with relatively low coverage limits but coverage for all tribes. FEMA said that its NFIP privatization study mandated by the Biggert-Waters Flood Insurance Reform Act of 2012 would include an assessment of these alternatives.
section_title: What GAO Recommends
paragraphs: GAO recommends that the FEMA Administrator examine ways to make mapping of tribal lands in flood-prone areas a higher priority. FEMA agreed with our recommendation.

section_title: Letter
paragraphs: Flooding is the most common and destructive natural hazard facing the  nation, resulting in billions of dollars in losses each year. Between 1980  and 2005, about 97 percent of the U.S. population lived in counties that  had experienced at least one declared flood disaster, and 45 percent  lived in counties that had experienced six or more. Further, federal  estimates show that more than half of the U.S. population now lives in  coastal watershed counties or floodplain areas.
Congress created the National Flood Insurance Program (NFIP) in 1968  to mitigate future flood losses nationwide through community floodplain  management ordinances and to provide access to affordable, federally  backed flood insurance protection for property owners.
Indian lands have experienced their share of flooding. Some have flooded  repeatedly, yet few tribes participate in NFIP. In a July 2011 hearing on  emergency preparedness for natural disasters in Native American  communities, the Senate Committee on Indian Affairs questioned why  tribal participation in NFIP was low and whether efforts to encourage  greater participation had been successful. Congress included a mandate  in section 100237 of the Moving Ahead for Progress in the 21st Century  Act that required us to examine the factors contributing to the current  rates of NFIP participation by Indian tribes and members of Indian tribes  and methods of encouraging such participation. In addition, the mandate  required us to describe steps that the Federal Emergency Management  Agency (FEMA) within the Department of Homeland Security should take  to increase awareness and encourage participation in NFIP by Indian  tribes and members of Indian tribes and to identify any legislative  changes that would encourage such participation. In response to the  mandate, this report examines (1) factors contributing to the current low  levels of NFIP participation by Indian tribes, (2) FEMA’s efforts to  increase tribes’ participation in NFIP, and (3) administrative and  legislative actions that could encourage Indian tribes and their members  to increase their participation in NFIP and potentially other flood  insurance programs.
For the purposes of this review, we limited our study primarily to flood  insurance policies held on Indian tribal lands (such as reservations),  because FEMA does not collect demographic data such as race or ethnic  origin of NFIP policyholders. Therefore, no comprehensive data are  available on members of Indian tribes who are living in nontribal  communities and may carry individual NFIP policies. We also interviewed  representatives from Alaska, because many Alaska Native communities  are vulnerable to floods but the tribes lack jurisdiction to adopt and  enforce land use ordinances, a requirement for community participation in  NFIP.
In conducting this work, we reviewed NFIP laws and policy documents.  We reviewed FEMA data on communities participating in NFIP, including  those designated as tribal communities, and on tribes that had flood  hazard maps but were not participating in NFIP for various reasons.  FEMA provided us with information on its process for collecting and  analyzing the data in its Community Information System database and on  the agency’s data reliability measures.FEMA provided to us were sufficiently reliable for our reporting purposes.  In addition, we reviewed our prior work on flood insurance, Indian tribes,  and disaster preparedness. We also interviewed and gathered  documentation from officials at FEMA and other federal agencies with  programs that assist Indian tribes, such as the Bureau of Indian Affairs  (BIA) within the Department of the Interior, Department of Housing and  Urban Development (HUD), and the U.S. Department of Agriculture  (USDA) Rural Development. In addition, we reviewed regulations for  those agencies’ programs. We spoke with representatives from the State  of Alaska; the National Flood Determination Association, which provides  flood mapping data to mortgage lenders and insurers; the insurance and  reinsurance industries; a nonprofit risk-pooling organization; FloodSmart,  which administered FEMA’s NFIP media campaign; and selected Indian  tribes.
See GAO, Native American Housing: Tribes Generally View Block Grant Program as  Effective, but Tracking of Infrastructure Plans and Investments Needs Improvement,  GAO-10-326 (Washington, D.C.: Feb. 25, 2010). also judgmentally selected a tribe in Alaska that we had contacted  previously to obtain a perspective on NFIP from a tribe in that state. To  obtain perspectives from the insurance industry, we interviewed  representatives from an insurance company that we contacted while  conducting prior work related to the Write-Your-Own insurance program,  a vendor that administers NFIP policies for Write-Your-Own insurance  companies, and an insurance broker that specializes in working with  Indian tribes. Appendix I contains a detailed description of our scope and  methodology.
We conducted this performance audit from August 2012 to January 2013  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: Floods can result in the loss of lives, extensive damage to property and  agriculture, and large-scale disruptions to business and infrastructure,  such as transportation and water and sewer services. The National  Oceanic and Atmospheric Administration estimates that floods cause  about 140 deaths in the United States each year, and the Army Corps of  Engineers estimates that floods cause $6 billion in average annual  losses. Congress established NFIP in the National Flood Insurance Act of  1968 to provide policyholders with some insurance coverage for flood  damage as an alternative to disaster assistance, and to try to reduce the  escalating costs of repairing flood damage.subsequently modified by various amendments, including the Flood  Disaster Protection Act of 1973 (1973 Act) and the National Flood   The program was  Insurance Reform Act of 1994. And most recently, NFIP was amended  by the Biggert-Waters Flood Insurance Reform Act of 2012.
The 1973 Act added certain requirements that, according to FEMA  officials, were intended to encourage community participation in NFIP.  Specifically, as a condition of future federal financial assistance,  communities are required to participate in NFIP and to adopt adequate  floodplain ordinances with effective enforcement provisions consistent  with federal standards in order to reduce or avoid future flood losses.  Figure 1, which shows the location of U.S. Indian reservations and major  flood disaster declarations over a 25-year period, indicates that many  Indian tribes reside in areas that have experienced multiple floods.
The 1973 Act denied direct federal financial assistance and financing by  private lending institutions regulated by federal regulators for acquisition  or construction purposes in participating communities where flood  insurance was available unless the property was covered by flood  insurance. Prior to the 1973 Act, the purchase of flood insurance had  been voluntary. However, this mandatory purchase requirement, further  amended by the National Flood Insurance Reform Act of 1994, effectively  requires owners of property to obtain flood insurance if they are located in  a Special Flood Hazard Area (SFHA) within a community participating in  NFIP and obtain a mortgage from a federally regulated lending institution  or a federal agency lender or receive direct federal financial assistance  for acquisition or construction purposes.
The mandatory purchase requirement applies to secured mortgage loans  from financial institutions such as banks, savings and loan associations,  savings banks, and credit unions that are supervised by federal agencies,  including the Federal Deposit Insurance Corporation and the Office of the  Comptroller of the Currency. It also applies to all mortgage loans secured  by real estate on which a building is constructed in an SFHA for which  flood insurance is available if purchased by Fannie Mae and Freddie Mac  in the secondary mortgage market. Loans and grants through financial  assistance programs from agencies such as the Federal Housing  Administration and the Department of Veterans Affairs are also affected.  The requirement also extends to several federal programs that assist  Indian tribes. For example, recipients of funds from BIA’s Housing  Improvement Program, HUD’s Indian Housing Block Grant (IHBG) and  Indian Community Development Block Grant (ICDBG), and several USDA  Rural Development loan programs are required to purchase flood  insurance if an assisted structure is in an SFHA. Finally, individuals in  SFHAs who receive federal disaster assistance after September 23,  1994, for flood disaster losses to real or personal property are required,  as a condition for receiving future disaster assistance, to purchase and  maintain flood insurance coverage on the property. According to FEMA,  in December 2012 the average NFIP policy cost about $600 per year,  with policies in SFHAs typically costing more and some policies outside  SFHAs costing less.
FEMA identifies and maps flood-prone areas throughout the United  States and its territories that are eligible to participate in NFIP. According  to a Congressional Research Service (CRS) report on NFIP, FEMA also  makes flood hazard information available on its website for viewing or  purchasing. The report notes that FEMA works with communities to  develop new flood hazard data as part of a flood insurance study, issues  public notification about maps, and engages in education and outreach to  help ensure that community leaders and residents understand the  mapping process and the appropriate use of flood maps. The CRS report  further notes that reliable flood risk data, including updated flood maps,  and educating residents about flood risk, contribute to mitigating future  flood losses. Most areas of flood hazard are commonly identified on Flood  Insurance Rate Maps (FIRM), and areas not yet identified by a FIRM may  be mapped on Flood Hazard Boundary Maps. Several areas of flood  hazard are identified on these maps, one of which is the SFHA. The  SFHA is a high-risk area defined as any land that would be inundated by  a flood having a 1 percent chance of occurring in a given year (base  flood); this is the equivalent of a 26 percent chance of flooding over a 30- year mortgage. According to FEMA, the SFHA constitutes a reasonable  compromise between the need for building restrictions to minimize  potential loss of life and property and the economic benefits to be derived  from floodplain development. Development may take place within an  SFHA as long as it complies with local floodplain management  ordinances, which must meet minimum federal requirements. Flood  insurance is required for insurable structures within high-risk areas to  protect federal financial investments and assistance used for acquisition  or construction purposes within communities participating in NFIP.
In July 2012, Congress passed the Biggert-Waters Flood Insurance  Reform Act of 2012. The act extends NFIP for 5 years and makes  reforms to the program that include (1) phasing out subsidies for many  properties, (2) raising the cap on annual premium increases for other  policies from 10 to 20 percent, (3) clarifying that certain multifamily  properties are eligible for NFIP policies, (4) imposing minimum  deductibles for flood claims, (5) requiring NFIP to establish a reserve  fund, and (6) establishing a technical mapping advisory council to deal  with map modernization issues. The act also calls for an assessment by  FEMA and GAO, separately, of options and strategies for privatizing NFIP  in the future and authorizes FEMA to pursue private risk-management  initiatives to determine the capacity of private insurers and markets to  assist communities in managing the full range of financial risks associated  with flooding.
subsections: section_title: NFIP Status
paragraphs: Because of its subsidized premium rates and catastrophic hurricane- related floods in recent years, NFIP has accrued a substantial debt that  stood at nearly $18 billion as of October 2012. We previously reported  that NFIP was designed to pay operating expenses and flood insurance  claims with premiums collected on flood insurance policies rather than  with tax dollars, and that FEMA had statutory authority to borrow funds  from Treasury to keep NFIP solvent in years when losses were high.  We noted that by design NFIP was not actuarially sound, because  Congress authorized subsidized insurance rates for policies covering  certain structures to encourage communities to join the program. Since  2000, NFIP has experienced several catastrophic loss years (years with  $1 billion or more in losses). These years include 2001, 2004, 2005, and  2008. By the end of 2012, NFIP is expected to have experienced  another catastrophic loss year because of the enormous damage from  the October storm known as Superstorm Sandy.
section_title: Community Participation
paragraphs: Under FEMA’s NFIP regulations, a community is defined as any state or  area or political subdivision thereof or any Indian tribe or authorized tribal  organization, or Alaska Native Village or authorized native organization,  that has the authority to adopt and enforce floodplain management  ordinances for the area under its jurisdiction. Indian tribes, authorized  tribal organizations, Alaska Native villages, and authorized native  organizations that have land use authority are considered communities by  NFIP and can join the program even if no flood hazard map exists that  covers all tribal lands.
See 44 C.F.R. § 206.110(k). where the community is participating in NFIP, unless the property is  covered by flood insurance. Participating communities can receive  discounts on flood insurance if they establish floodplain management  programs that go beyond the minimum requirements of NFIP. FEMA can  suspend communities that do not comply with the program and  communities can withdraw from the program (both with sanctions).  Currently, more than 21,000 communities participate in NFIP.
Communities participating in NFIP do so as part of either the regular or  emergency program. A community participating in the regular NFIP  program is usually provided with a FIRM and a flood insurance study. As  part of their agreement to participate in NFIP, communities adopt and  enforce floodplain management ordinances and FIRMs. If communities  do not adopt and enforce these ordinances, they can be placed on  probation or suspended from the program. However, such actions take  place only after FEMA has taken steps to help the community become  compliant. The NFIP emergency program is the initial phase of a  community’s participation in NFIP and was designed to provide a limited  amount of flood insurance. A community participating in the emergency  program either does not have an identified and mapped flood hazard or  has been provided with a Flood Hazard Boundary Map, and the  community is required to adopt limited floodplain management standards  to control future use of its floodplain. According to FEMA, fewer than 3  percent of the more than 21,000 communities participating in NFIP are in  the emergency program.
section_title: Indian Tribes
paragraphs: The federal government has consistently recognized Indian tribes as  distinct, independent political communities with the inherent powers of a  limited sovereignty that has never been extinguished. As of August 2012,  there were 566 federally recognized tribes—341 in the contiguous 48   To help manage tribal affairs, tribes have  states and 225 in Alaska.formed governments and subsidiaries of tribal governments, including  schools, housing, health, and other types of corporations. The United  States has a trust responsibility to recognized Indian tribes and maintains  a government-to-government relationship with them.
Tribal lands vary dramatically in size, demographics, and location. They  range from the Navajo Nation, which consists of about 27,000 square  miles across portions of Arizona, New Mexico, and Utah, to some tribal  land areas in California of less than 1 square mile. Over 176,000  American Indians live on the Navajo reservation, while some other tribal  lands have fewer than 50 Indian residents. Some Indian reservations  have a mixture of Indian and non-Indian residents. Most tribal lands are  rural or remote, although some are near metropolitan areas.
We have reported in the past that some tribes are landless. See table 4 in GAO, Indian  Issues: BLM’s Program for Issuing Individual Indian Allotments on Public Lands Is No  Longer Viable, GAO-07-23R (Washington, D.C.: Oct. 20, 2006). See Brendale v.  Confederated Tribes and Bands of Yakima Indian Nations, 492 U.S. 408 (1989). reservation boundaries, have been inherited or purchased by non-Indians  and Indian tribes generally lack jurisdiction over land owned by non- Indians.
In some cases, although a tribe is not an NFIP participant, the tribe may  be located in another community that participates in NFIP.
section_title: Proposed Amendment to the Stafford Disaster Relief and Emergency Assistance Act
paragraphs: A proposed amendment to the Robert T. Stafford Disaster Relief and  Emergency Assistance Act would allow Indian tribes to request a major  disaster declaration by the President. The proposed amendment would  provide Indian tribes with this authority so that they would not be required  to rely on assistance through a presidential declaration requested by the   Federal officials with whom we spoke generally viewed  state or locality.this amendment as a positive action in the interest of tribes. For example,  USDA Rural Development officials said that this authority would make it  easier for tribes to access disaster relief resources. Representatives of  several tribes we interviewed said that such a change would open up  direct communication between the federal government and Indian tribes.  However, questions remained about how the proposed amendment would  be implemented. It is not yet clear how the proposed Stafford Act  amendment would affect Indian tribes’ willingness to participate in NFIP.
section_title: A Number of Factors Contribute to Indian Tribes’ Low NFIP Participation Rate
paragraphs: According to FEMA, as of August 2012, 37 out of 566 federally  recognized tribes nationwide—roughly 7 percent—were participating in  NFIP (see table 1). The number of policies for each tribe ranged from 1 to  175, and 14 participating tribes had no individual policies. Across all  participating Indian tribes, 414 policies were in place, accounting for less  than 1 hundredth of a percent of all NFIP policies.
FEMA’s data also show that, among communities that have received  flood hazard maps but are not participating in NFIP, there are 46 tribal  communities.
Federal agency officials, tribes, and others described several factors that  affect whether tribes purchase flood insurance through NFIP or other  programs.
FEMA does limited mapping in tribal communities. Flood maps show  communities and homeowners the level of flood risk they face. According  to FEMA, as of October 2012, 78 tribal communities had received flood  hazard maps.Association, which provides FEMA flood mapping data to mortgage  lenders and insurers, told us that some tribes that were not participating  in NFIP had not been mapped and that because they did not know their  flood risk, they likely did not see the advantages to NFIP participation. In  discussing the agency’s mapping efforts, FEMA officials explained that  tribal communities generally included small rural areas that were not a  high priority for the agency. The officials said that FEMA had focused its  mapping efforts on heavily populated urban and coastal areas with a high  risk of flooding. The officials also noted that because of the tribes’  sovereignty, the agency needed permission to enter tribal lands and  conduct mapping activities and that such permission could be difficult to  obtain. Additionally, they were concerned that tribes might not grant   Representatives of the National Flood Determination  permission for FEMA to publish a map if tribal borders were in dispute.  They explained that if FEMA could not overcome these challenges, it  might exclude the tribal area from the watershed map. However, they  did not provide us with any specific examples of maps with such  exclusions.
Representatives of a Washington tribe that received its flood hazard  maps from FEMA in 2004 told us the tribe had participated in NFIP since  1997, 7 years prior to receiving the maps. The tribe initially participated in  NFIP’s emergency program and then became a regular participant once  its maps were finalized. They explained that the tribe had largely been  motivated by a need to clarify its jurisdictional (land and water) area,  which flood mapping allowed them to do. Further, they said that joining  NFIP had provided an opportunity to obtain flood insurance as a tribal  community instead of participating as part of the surrounding county,  supporting the tribe’s interest in self-determination. vulnerable to flooding from several sources, and the representatives  noted that it had long been proactive in disaster mitigation efforts as a  whole. Emergency officials from another tribe told us that approximately  10 percent of their reservation was mapped and that the mapping had  been done by the Army Corps of Engineers. They said their  understanding was that until recently, FEMA did not conduct flood  mapping on federal reservations.
As previously noted, FEMA assigns a unique community identification number to each  community listed in its NFIP Community Information System database. The actions of a  specific community under NFIP directly impact the availability and cost of NFIP policies for  its residents. For example, a community’s actions could result in its residents receiving  NFIP policy discounts. For more on Indian self-determination, see GAO-10-326.
9 were in the 1-year “opportunity period” for addressing any identified  flood hazards and joining NFIP, and 2 had been determined to have  some flood risk but were not participating.
One representative of a participating Washington tribe suggested that  tribes that are most at risk for flooding should be given priority in efforts to  encourage tribal participation in NFIP. The tribal representative said that  expecting those not highly vulnerable to flooding to purchase costly flood  insurance when they have other priorities would be difficult. When we  spoke with an emergency management official from a nonparticipating  Wisconsin tribe, he agreed that because the tribe had not experienced a  major flood, there was a general lack of urgency on the part of tribal  leadership about NFIP participation.
Many tribes lack the resources or administrative capacity to join  NFIP. FEMA officials told us that affordability affected tribes’ participation  in NFIP as it did other low-income communities and individuals. The  officials also told us that they had seen slow to no insurance policy growth  in areas of the country where the economy was not performing well. A  representative of the National Flood Determination Association agreed  that the cost of coverage could limit tribes’ participation, noting that there  is a general lack of funding for mapping. Further, he said that many rural  communities, including tribal communities, were not in favor of adopting  land use regulations and did not have the resources to adopt and  implement them.
Representatives of the participating Washington tribe with the highest  number of individual policies as of August 2012 acknowledged that NFIP  participation was administratively burdensome and costly. In particular,  they explained that developing flood damage reduction ordinances and  then implementing the ordinances required dedicated staff that not all  tribes have. In general, they acknowledged that many tribes lacked the  resources that this tribe had to pursue NFIP participation. Similarly, a  Wisconsin tribal official said that pursuing NFIP participation could be  especially challenging for tribes that lacked emergency, planning, or  zoning functions and tribes that may not even have developed building  codes on their lands. He emphasized that such limitations should be  taken into account in examining why tribes may not be participating in  NFIP.
Many tribes view affordability as a significant issue for their  members in purchasing NFIP policies. Many tribal representatives said  that affordability would be an issue for tribal members. For instance,  representatives of an Oklahoma tribe told us that while affordability would  not affect the tribe’s decision to participate in the program, because the  tribe would use NFIP to insure its government and commercial buildings,  it would be a factor for individual tribal members. Specifically, they  explained that paying flood insurance premiums would be challenging for  individuals who already lacked the resources to afford homeowner,  renter, and automobile insurance. Representatives of other tribes agreed  that NFIP premiums would be costly for the members of their tribes.  Emergency management representatives of a large western tribe told us  they were not aware of any tribal members who had flood insurance on  their homes and that even homeowner insurance coverage was rare.  They explained that the average annual household income on the  reservation was between $12,000 and $15,000 and that unemployment  was at least 28 percent. A tribal housing official from Alaska whose  members can participate in NFIP through the surrounding borough told us  that he had found that most members of his tribe dropped their  homeowners insurance as soon as their homes were paid off and that he  expected they would do the same with required flood insurance, which   An official for another Oklahoma tribe  can cost more than $1,000 a year.that was participating in NFIP but had no active individual policies said he  did not believe flood insurance was a priority for members of his tribe,  whose average annual household income was $6,000. Figure 2 shows a  Native Alaska fishing village that has experienced flooding but whose  residents, according to the tribe’s housing director, have not purchased  NFIP flood insurance due to the high cost.
Unique Indian issues also impact tribal participation in NFIP. As  previously noted, all but one of the tribes in Alaska lack a reservation.  Because the tribes lack jurisdiction to enact and enforce land use  ordinances over the land where they reside, they cannot directly  participate as communities in NFIP. In many cases, the tribes are co- located with other government entities that may participate in NFIP, such  as cities and boroughs, and their members may access NFIP through  those other entities. Alaska state officials told us that an estimated 66  percent of the Alaska Native population could participate in NFIP because  they lived in a city or borough that participated in the program. Based on  data we compiled and analyzed, 58 of 225 Alaska tribes were co-located  with a participating community (see table 2).
Tribes in Oklahoma and elsewhere that do not have reservations—as well  as tribes with reservations—face similar challenges in adopting and  enforcing land use ordinances because they lack jurisdiction over certain  land. Tribes with reservations do not generally have authority to adopt  and enforce land use ordinances for land within the reservation’s  boundaries owned by non-Indians. Likewise, representatives of an  Oklahoma tribe told us that its lack of participation in NFIP was due in  part to a reluctance to face possible sanctions because of the tribe’s  limited ability to enact and enforce ordinances for land owned by non- Indians. For example, they explained that if a home that had  experienced repeated flooding was located on land where the tribe had  limited jurisdiction, the tribe could not take action to mitigate future flood  damage without the owner’s permission. They said they were aware that  NFIP does not have a workaround for such circumstances. The tribe had  chosen to insure all tribal structures and vehicles under a private policy.
In addition, representatives of several tribes explained that tribal  structures differ from other local government structures but that FEMA did  not take those differences into account, making participation difficult for  some tribes. For example, representatives of a participating Washington  tribe told us that in preparing its multihazard mitigation plan for FEMA  approval, the tribe realized that the plan template had been created for  states, as it called for input from counties within the jurisdiction. Instead of  counties, the tribe had to substitute less specific geographic areas within  the tribal community. The same tribe was participating in NFIP’s  Community Rating System program, which allows communities to receive  discounts on policies for their residents based on floodplain management  actions the community takes beyond NFIP’s minimum requirements. The  representatives explained that NFIP also lacked a tribal template for the  Community Rating System program, which they said would facilitate the  tribe’s participation.
Without flood hazard maps, tribal communities, including those that may  be in areas with a higher risk of flooding, may not be sufficiently aware of  their flood risk. Tribes also may be reluctant to pursue NFIP participation  if they are uncertain about whether they would qualify and could meet the  program’s requirements. Further, those with fewer resources and less  administrative capacity may be less proactive in requesting that FEMA  map their communities, even though they may be vulnerable to floods.
section_title: FEMA Has Provided Indian Tribes with Training and Technical Assistance on Hazard Mitigation, Including Flood Insurance
paragraphs: FEMA’s outreach to tribes in the last few years has largely consisted of  emergency management and homeland security training for tribal officials  through its Emergency Management Institute (EMI), direct technical  assistance to tribes in preparing their multihazard mitigation plans, and  nationwide outreach for NFIP through its regional offices and the NFIP  FloodSmart marketing campaign. FEMA officials told us that the agency  helped to educate tribal officials about NFIP and floodplain management  through courses offered by EMI under a mitigation curriculum that  includes courses for floodplain managers on their roles and  responsibilities, flood insurance, and NFIP rules and regulations. FEMA  has also developed an emergency management tribal curriculum to  collaborate with tribal governments in building emergency management  capability and partnerships to ensure continued survival of tribal nations  and communities.
To some extent, FEMA’s efforts have helped some tribes better  understand the flood hazards that they face. According to FEMA officials,  more than 2,000 members from more than 300 Indian tribes have taken  courses through EMI. The officials added that each regional office had a  floodplain management specialist as the NFIP point of contact for Indian  tribes. Officials from two tribes told us that they had participated in EMI  training. One tribal emergency management official in Wisconsin told us  that he participated in training with an EMI tribal curriculum group that  communicated monthly.
FEMA officials also described the direct technical assistance that they  provided to tribes that were preparing hazard mitigation plans. According  to FEMA, developing the plans involves identifying the tribe’s critical  infrastructure, major risks and vulnerabilities, and actions to reduce those  risks and vulnerabilities for various types of disasters, including floods.  This assistance provides tribes with an opportunity to learn about the  risks that their individual communities may face. Representatives from  several tribes told us that they had completed approved mitigation plans  or were in the process of completing their plans. Two of the tribes with  whom we spoke had their plans approved in 2010.
FEMA FloodSmart officials explained that they tried to reach communities  nationwide with the FloodSmart campaign, but that they targeted those  communities that were most at risk for flooding. Among these  communities, they focused on urban areas which had a higher  concentration of potential flood insurance buyers than rural areas. They  explained that FloodSmart used a tiered marketing strategy that was  based on a number of factors that point to a high potential return on  investment of federal dollars, including: (1) flood insurance policy  purchase history, (2) potential flood risk as determined by volume of  SFHA properties, (3) flood event history, (4) volume of structures, and (5)  media cost. As such, rural areas, including Indian areas, generally  received lower priority.
FloodSmart officials told us that since February 2007, a total of 671,000  acquisition-based direct mail pieces had been sent to approximately  383,000 distinct household addresses within zip codes that intersected  with Indian reservations. Moreover, according to FloodSmart officials, on  average, 112,000 direct mail pieces were sent to Indian reservations each  year, the majority of which were sent to addresses for properties in an  SFHA. However, several tribal representatives with whom we spoke still  told us that they would like more information about NFIP and its  requirements so that they could decide whether to participate in the  program and encourage their members to purchase policies through the  program. In addition, representatives from a few tribes and from an  insurance company told us that marketing campaigns or other outreach  efforts may have little effect in Indian communities without the buy-in of  tribal leaders.
subsections: section_title: HUD and USDA Work with Tribes on Housing Issues and May Provide Some Information on NFIP
paragraphs: HUD and USDA Rural Development provide assistance in the form of  housing and infrastructure grants, loans, and loan guarantees to Indian  tribes. According to officials from both agencies, while neither HUD nor  USDA is required to provide NFIP outreach, the agencies worked with  tribes on housing issues that may include determining flood risk to  housing assistance projects and assessing housing-related issues after  disasters, such as floods. In addition, the officials said that their field staff  had FEMA FloodSmart program material on hand for interested parties,  including Indian tribes.
As part of the IHBG and ICDBG programs, HUD officials in the Office of  Native American Programs told us that they worked with tribes to identify  their priorities and to help them determine how to best use HUD funds as  an investment in addressing their needs. In addition, under both IHBG  and ICDBG, recipients can use program funds to cover flood insurance  premiums for properties in some high-risk areas. HUD officials said that  they conducted outreach to housing authorities in locations where floods  and other disasters had occurred to assess the status of HUD housing  stock and to identify displaced families. HUD officials also said that they  coordinated with FEMA and other agencies locally so that the agencies  could work together to assess grantees’ damages and needs following a  disaster, but that they did not know which tribes participated in NFIP.  HUD regional officials said that they worked closely with individual tribes  that had been impacted by flooding and other disasters and could offer  technical and financial assistance to the tribes. Officials from three tribes  told us that in their experience, HUD officials generally did not approve of  using HUD assistance to build in an SFHA. An official from one of these  tribes told us that to address HUD’s requirements for one of its HUD- assisted housing developments, the tribe built pads on all of the houses it  was constructing to elevate them out of the flood zone. In addition,  officials in HUD’s Office of Environment and Energy told us that they  provided environmental training and invited grantees, including tribes, to  attend this training.
USDA Rural Development has a Native American Coordinator who  interacts with tribes on programmatic issues, including challenges and  issues that arise due to flooding. We spoke with the national coordinator,  who explained that each state office serving a federally or state  recognized Indian tribe designated an individual to serve as the USDA  Rural Development state Native American Coordinator. He explained that  the role had typically been a collateral duty although, in the past, three  states had employed full-time Native American Coordinators. The  coordinator’s efforts related to NFIP primarily would be liaising between  tribal staff and the appropriate Rural Development staff tasked with  ensuring compliance with program requirements for USDA-funded  construction or development. Specifically, USDA officials told us that they  ensured compliance with NFIP requirements only for USDA-funded  projects where construction or development occurred in an SFHA in an  NFIP participating community. They explained that USDA’s evaluation of  NFIP applicability was part of National Environmental Policy Act   In these cases, USDA officials said they ensured that  reviews.mitigation actions were taken and when this was impractical, the applicant  for USDA funding purchased flood insurance. The officials told us they did  not provide any assistance for developing floodplain management  approaches, but required that borrowers comply with applicable state or  local floodplain ordinances or permits. Both HUD and USDA officials told  us that when an area had not been mapped, they might rely on tribal  elders or another knowledgeable source in determining the location of  flood-prone areas.
section_title: Boosting Tribes’ Participation in Flood Insurance Programs
paragraphs: Representatives from HUD and USDA, tribal representatives, and private  insurers all agreed that more could be done to encourage tribes to  participate in flood insurance programs. However, FEMA noted that it was  limited in its efforts by the unique legal issues surrounding Indian tribes  and their lands. FEMA also told us its focus was on mapping more highly  populated areas, which typically did not include Indian tribal communities.  HUD and USDA acknowledged that more information and support could  encourage tribes to participate in NFIP. For instance, HUD officials in the  Northern Plains region, where more than 30 federally recognized tribes  are located, told us that there was likely a need for more education  among tribes. The officials said that they were aware that FEMA had to  prioritize limited federal dollars for flood mapping activities and that tribal  lands might not be a top priority. However, they noted that tribes also  might not be proactive in requesting flood maps for their communities  because they had received conflicting information about FEMA’s authority  to map tribal lands. The officials said they had invited FEMA to a regional  meeting in the last year to share information on disaster topics, including  floods and flood insurance, with tribal housing officials from the region. As  previously noted, officials from HUD’s Office of Environment and Energy  also told us that they were increasing opportunities for HUD grantees,  including tribes, to obtain information and training on environmental topics  such as flood risks.
Tribal representatives had a number of suggestions that could lead to  increased tribal participation, ranging from expanding FEMA outreach and  education to requiring tribes to have flood insurance. They suggested,  among other things, more emphasis on educating tribes on the importance of flood  insurance, as at least one tribe had been experiencing more rain each  year; more outreach to tribes, including those without flood hazard maps, to  help them understand their vulnerability to floods and the advantages  of NFIP participation; meetings that brought together FEMA officials and elected tribal  councils that could make decisions on behalf of their tribes;  federal grants to help tribes develop elevation certificates and to  retrofit older properties to lower risk and make the policies more  affordable for members; a simulation exercise that included the host tribe, FEMA officials, and  other government officials with whom tribes would need to coordinate  in a flood-related disaster; and an amendment to the NFIP statute to address issues specific to tribes’  limited ability to adopt and enforce land use ordinances.
At least one tribal representative said that it would be reasonable for  Congress to require a flood mitigation plan across communities and tribal  lands, regardless of risk level, and that tribes with critical infrastructure in  a flood-prone area should be required to participate in NFIP or sign a  waiver of future flood assistance. However, another representative  suggested that FEMA should address the land use ordinance issue and  determine, with the tribes’ input, whether NFIP had been financially  beneficial to tribal members who were able to purchase flood insurance in  the nontribal community where they lived.
Insurance company officials we spoke with, including a Write-Your-Own  company and a broker, emphasized the importance of respecting the  cultural issues of dealing with tribes in any targeted outreach activities. As  we have seen, for example, the FloodSmart campaign sent thousands of  pamphlets to individual residents on Indian lands. One insurance broker  that targets Indian tribes told us that the company had received three  requests for policies after the mailing. She told us that the company had  learned that tribal members tend to rely on the views of their tribal leaders  for guidance and that without the buy-in of these leaders, marketing  FloodSmart materials to individual members would likely not be a  successful strategy.
Insurance and reinsurance company officials we spoke with were aware  of the Biggert-Waters Flood Insurance Reform Act of 2012 requiring  FEMA and GAO to assess options and strategies for privatizing NFIP in  the future and authorizing FEMA to pursue private management  initiatives.examine whether it would be in its interest to become more involved now,  given that future legislation would likely increase the private sector’s role  in flood insurance. This official added that his company recognized that  NFIP was not actuarially sound and that expected additions to the nearly   A reinsurance official said that his company had begun to  $18 billion deficit from Superstorm Sandy could accelerate congressional  interest in greater private sector involvement in providing flood insurance.
Other private sector insurance options may offer tribes an alternative to  NFIP. A private insurer proposed two related options that could allow  tribes to purchase flood insurance at a potentially lower cost than under  NFIP. The first would involve expanding the existing eligible flood  insurance risk-sharing pools to obtain the critical mass of policies  necessary to make low-cost flood insurance policies affordable to Indian  households. The second would establish a new private “microinsurance”  program offering low-premium policies with small coverage limits tailored  specifically to Indian tribes, based on similar operations in developing  countries.
Nonprofit Insurance Risk Pool: Two of the tribes we contacted had  purchased flood insurance through an insurance risk pool offered by  AMERIND Risk Management Corporation. AMERIND was organized  in 1986 as a collaborative program between HUD and some Indian  housing authorities to provide insurance protection for Native  American low-income housing. It currently operates as a multitribal  nonprofit corporation working with over 400 tribes and administers  risk-sharing pools. Since 2002, AMERIND has offered a flood  insurance endorsement to its standard policy, limited to HUD-assisted  Indian housing. Company officials explained that through a  members-only risk pool, the flood endorsement provides flood  coverage to about 56,000 structures on tribal lands and charges a  universal rate of $10 per structure per year (see table 3). AMERIND  has a coverage limit of $15,000 for each covered structure.
An Arizona tribe we contacted uses AMERIND insurance on its HUD- assisted tribal housing, and the policies included the flood protection  endorsement. According to the tribal representative, the tribe has  used this insurance option for about 8 years. One Oklahoma tribe we  contacted had not purchased AMERIND’s flood insurance  endorsement but had purchased property insurance from the  company. This representative said that because of its affordability  compared with NFIP and because the company is a multitribal  corporation, he would refer individual members to AMERIND if they  lived in HUD IHBG-assisted housing within a floodplain and needed to  purchase flood insurance. USDA Rural Development also has  approved AMERIND as an eligible nonflood insurer for its single- family housing programs, so Indian tribes and their members can use  an appropriate AMERIND product to insure projects financed through  these programs. According to USDA, the intent is to facilitate use of  its programs by Indian tribes and their members for projects on trust  land when conventional insurance coverage is unavailable, difficult to  access, or expensive.
However, the current nonprofit insurance risk-pooling option has  limitations. First, while the premium rate may be lower than NFIP’s,  the coverage limits for flood insurance are also generally lower.  Representatives for AMERIND told us that coverage limits were low  because the company had not been successful in obtaining  reinsurance on the private market that would allow the company to  mitigate its risk and offer full replacement costs for each structure.  AMERIND does offer to provide double coverage ($30,000 per  structure) for flood losses, but the premiums are more than 10 times  the universal rate, ranging from about $150 to $200 per structure.  These premiums are generally below NFIP rates for properties with  similar coverage inside SFHAs and are generally comparable to NFIP  rates for similar coverage outside SFHAs. Second, because  AMERIND’s flood insurance coverage is available for HUD IHBG- assisted structures only, tribes cannot use it for all structures on tribal  lands. The tribes we interviewed that used AMERIND for flood  insurance were able to obtain coverage only for HUD IHBG-assisted  structures. Because of this limitation, AMERIND does not have the  critical mass of policies necessary to offer private low-cost flood  insurance to all Indian households. Third, communities may still face  consequences if they are identified as having SFHAs and choose to  obtain non-NFIP flood insurance. According to FEMA, NFIP aims to  do more than simply encourage property owners to purchase flood  insurance. It also encourages them to take measures to mitigate  potential flood damage to their properties, and NFIP coverage is  available only when certain flood protection standards have been  implemented.
Private Microinsurance: Another potential private sector option  would be a private microinsurance program. Microinsurance is a  relatively new product that allows insurers to offer low-premium  policies with small coverage limits in developing areas. The concept  operates much like AMERIND’s risk pool and is structured to provide  low-income policyholders with a degree of “livelihood protection” or  emergency expense support rather than full indemnity for loss. We  spoke with officials from a reinsurance company that was recently  awarded a grant from a member of the World Bank group to develop a  market for microinsurance in an agriculture-based developing country.  These officials and officials from the reinsurance company’s insurance  subsidiary said that, given the recent congressional interest in looking  into private options for flood insurance, they would be interested in  working with AMERIND or helping to develop another Native  American flood insurance program that would cover all tribal member  homeowners and businesses. They said that a mandatory coverage  provision would solve the coverage problem and reduce uncertainty,  making the provision of microinsurance more attractive to and  sustainable for insurers and reinsurers. But they added that even with  mandatory group coverage, they saw benefits to mapping all lands,  because a private microinsurance risk pool would need to charge  more for properties that were located on unmapped tribal lands than  for similar properties located on mapped tribal lands.
During the course of our work for this report, FEMA developed a draft  statement of work for its upcoming private market assessment of NFIP.  The draft statement, dated December 17, 2012, included a requirement  for the contractor to assess a broad array of instruments, including  reinsurance, microinsurance, and flood insurance pools. FEMA officials  confirmed that the inclusion of microinsurance and insurance pools in the  study was finalized after we raised and discussed those alternatives with  them and that they considered both alternatives to be worth studying.  FEMA officials told us that they planned to issue the statement of work  early in January 2013.
section_title: Conclusions
paragraphs: Congress created NFIP with the intent of providing affordable flood  insurance to communities and households in order to financially protect  property owners and reduce the cost of federal postdisaster assistance,  but participation by Indian tribes has been low. Even on Indian lands that  have experienced flooding, tribes and tribal members often do not  participate, and the total number of policies written to tribes and tribal  members accounts for less than 1 hundredth of a percent of FEMA’s  portfolio. FEMA has provided tribes with training and technical assistance  and has to some extent helped tribes to understand the flooding risks  they face. However, several factors have contributed to the low  participation rate, including limited mapping on Indian lands; affordability;  lack of information on NFIP; and tribal land use issues, including  confusion about legal restrictions on activities on Indian lands. Limited  mapping, in particular, has contributed to a lack of awareness both of the  risk of flooding and of the benefits of NFIP. FEMA has generally focused  its mapping efforts on densely populated and coastal areas in order to  make the best use of its resources. However, increased mapping of less  densely populated rural areas, including Indian lands, is in line with  Congress’s focus on increasing tribes’ participation in NFIP and is key to  raising awareness of the types of flood risks residents of these areas  face. Expanding its flood mapping efforts will challenge FEMA to balance  its need to make the best use of scarce resources with the needs of these  previously underserved communities.
section_title: Recommendation
paragraphs: To help increase Indian tribes’ participation in NFIP, we recommend that  the Administrator of FEMA examine the feasibility of making mapping of  tribal lands a higher priority.
section_title: Agency Comments
paragraphs: We provided a draft of this report for review and comment to USDA Rural  Development, FEMA within the Department of Homeland Security, HUD,  and BIA within the Department of the Interior. A letter from the Director of  the Departmental GAO-OIG Liaison Office within the Department of  Homeland Security stated that FEMA will take steps to make mapping of  tribal lands a higher priority. The director also stated that doing so will be  challenging due to FEMA’s scarce resources and noted the agency’s  appreciation for GAO’s acknowledgment of its resource limitations. In  addition, the director said that FEMA will consider the suggestions made  by tribal representatives for increasing tribal participation in flood  insurance programs. The letter is reprinted in appendix II. We also  received technical comments from USDA Rural Development, FEMA, and  HUD, which we incorporated in the report as appropriate. BIA did not  provide any comments.
We are sending copies of this report to appropriate congressional  committees, and the Secretaries of Agriculture, Homeland Security,  Housing and Urban Development, and Interior. This report will also be  available at no charge on GAO’s website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-8678 or cackleya@gao.gov. Contact points for our  Offices of Congressional Affairs and Public Affairs may be found on the  last page of this report. GAO staff who made major contributions to this  report are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objectives were to examine (1) factors contributing to the current low  levels of National Flood Insurance Program (NFIP) participation by Indian  tribes, (2) the Federal Emergency Management Agency’s (FEMA) efforts  to increase tribes’ participation in NFIP, and (3) administrative and  legislative actions that could encourage Indian tribes and their members  to increase their participation in NFIP and potentially other flood  insurance programs. For the purposes of this review, we limited our study  primarily to flood insurance policies held on Indian tribal lands (such as  reservations), because FEMA does not collect demographic data such as  race or ethnic origin of NFIP policyholders. Therefore, no comprehensive  data are available on members of Indian tribes who are living in nontribal  communities and may carry individual NFIP policies. We also interviewed  representatives from Alaska, because many Alaska Native communities  are vulnerable to floods, but do not have designated reservations that  could participate in NFIP. With only one reservation in the state, tribes in  Alaska can participate in NFIP only through the municipalities in which  their communities are located.
To address all three objectives, we reviewed NFIP laws and policy  documents. We reviewed FEMA data on communities participating in  NFIP, including those designated as tribal communities, and on tribes that  had flood hazard maps but were not participating in NFIP for various  reasons. FEMA provided us with information on its process for collecting  and analyzing the data in its Community Information System database  and on the agency’s data reliability measures. We determined that the  data FEMA provided to us were sufficiently reliable for our reporting  purposes. In addition, we reviewed prior GAO work on flood insurance,  Indian tribes, and disaster preparedness, and reports by the  Congressional Research Service, to compile background information on  NFIP. We interviewed and gathered documentation from officials at  FEMA and other federal agencies with programs that assist Indian tribes,  such as the Bureau of Indian Affairs (BIA) within the Department of the  Interior, Department of Housing and Urban Development (HUD), and the  U.S. Department of Agriculture (USDA) Rural Development. In addition,  we reviewed regulations for those agencies’ programs. We spoke with  representatives from the State of Alaska; the National Flood  Determination Association, which provides flood mapping data to  mortgage lenders and insurers; the insurance and reinsurance industries;  a nonprofit risk-pooling organization; FloodSmart, which administered  FEMA’s NFIP media campaign; and selected Indian tribes.
We selected the tribes from among those on FEMA’s lists of tribes that  were participating in NFIP and those that had flood hazard maps but were  not participating in NFIP. We selected a purposive non-representative  sample of eight participating tribes for interviews based on the number of  individual policies within each tribe, geographic diversity, and tribe size.  We also selected a purposive non-representative sample of six  nonparticipating tribes for interviews based on the reason for  nonparticipation, geographic diversity, and tribe size. In addition, our prior  work on the Native American Housing Assistance and Self-Determination  Act of 1996 (NAHASDA) program partially informed the tribes we  selected. Specifically, because we had already established  communication with certain tribes, we selected them over comparable  tribes on either list. Because of our time constraints and several selected  tribes being impacted by a natural disaster (Superstorm Sandy), we were  able to interview five participating and five nonparticipating tribes. We  also judgmentally selected a tribe in Alaska that we had contacted  previously to obtain a perspective on NFIP from a tribe in that state. To  obtain perspectives from the insurance industry, we interviewed  representatives from an insurance company that we contacted while  conducting prior work related to the Write-Your-Own insurance program,  a vendor that administers NFIP flood policies for Write-Your-Own  insurance companies, and an insurance broker that specializes in working  with Indian tribes.
To determine factors contributing to the current low levels of NFIP  participation by Indian tribes, we reviewed FEMA’s data on tribal  community participation. We also asked FEMA officials about the  agency’s process for mapping Indian lands (or providing flood hazard  maps to Indian communities), and options for tribes to participate in NFIP.  In our interviews with other federal officials, tribal representatives, and  others, we asked about factors that may positively or negatively affect  whether tribes participate in NFIP.
To determine the efforts FEMA was making to increase awareness of and  encourage participation in NFIP by Indian tribes, we asked officials at  FEMA about outreach and technical assistance they provided to Indian  tribes related to floods and flood insurance. In addition, we asked  FloodSmart representatives about any efforts to market NFIP to Indian  tribes and their members. We also asked officials at BIA, HUD, and  USDA about information they may share with tribes on flood insurance in  providing program support. Further, we asked tribal representatives about  their interactions with FEMA and other agencies and information or  assistance they had received related to NFIP.
To determine what administrative or legislative actions could encourage  Indian tribes and their members to increase their participation in NFIP and  potentially other flood insurance programs, we reviewed NFIP regulations  and legislation and guidance on FEMA coordination with and outreach to  Indian tribes. We interviewed representatives from the insurance and  reinsurance industries about other flood insurance options, in addition to  NFIP, that may facilitate tribes’ purchase of flood insurance. We also  asked federal officials and tribal representatives about actions that FEMA  or Congress could take to encourage tribes participating in NFIP to  increase their use of the program and tribes not participating to join NFIP.
subsections: section_title: Tribe Selection Process
paragraphs: Participating: Based on number of individual NFIP policies held by the  tribe, size of tribe, and geographic diversity, a total of eight tribes were  selected for inclusion as well as six backup tribes. Tribes and backup  tribes were selected within each region, except in the Northeast region  where there was only one tribe included in our sample frame. One group  of selected tribes had the largest number of policies and the backups had  the second largest number of policies. The other group of tribes had the  lowest number of policies. Among the cohort of lowest policies, within  each region, tribes selected were those with the largest enrollment and  the backups were those with the second largest enrollment.
Nonparticipating: Based on reason for nonparticipation (such as  withdrawn or suspended from the program), size of tribe, and geographic  diversity, a total of six tribes were selected for inclusion as well as three  back-up tribes. Tribes and backup tribes were selected within each  region, except in the Northeast region where there was only one tribe  included in our sample frame. Additionally, the one withdrawn tribe and  the one suspended tribe are also included in our selected tribes. In the  other three regions, one group of selected tribes had the largest number  tribal enrollment and the backups had the second largest tribal  enrollment.
We conducted this performance audit from August 2012 to January 2013  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Comments from the Federal Emergency Management Agency
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Andy Finkel (Assistant Director),  Bernice Benta-Jackson, Emily Chalmers, Brian Friedman, Jeffery  Malcolm, Marc Molino, Patricia Moye, Roberto Pinero, and Andrew  Stavisky made key contributions to this report.