Template Comments on FEMA IA Reforms

July 2, 2024

Dear partners, advocates, and allies,

As you may be aware, FEMA has implemented new reforms as of March 22, 2024. Although the reforms are in effect through an Interim Final Rule, members of the public, including organizations, may submit comments until July 22, 2024. You can submit comments and read the full reform here. This page contains an explanation of the reforms, a link to a FEMA document explaining the changes, and a comments template. We hope that your organization will take advantage of this opportunity to promote equity for and protect the safety of people with disabilities by submitting comments by July 22, 2024. Please let us know if you have any questions about the reforms or how to submit comments. Please note that individuals as well as organizations are invited to submit comments.

Overview of the Reforms in the Interim Final Rule

The reforms are largely positive and are only available during presidentially declared disasters. Changes include providing $750 in serious needs assistance (formerly called critical needs assistance) to disaster survivors quickly after a disaster occurs without the state requesting it; removing the requirement that disaster survivors apply for and be denied a loan from the Small Business Administration (SBA) to receive FEMA assistance; providing assistance for homeowners who have exhausted insurance requirement; and establishing displacement assistance which will provide eligible survivors with up-front funds to assist with immediate housing options of their choice, such as costs associated with staying with family and friends, until they are able to secure a rental option to focus on their long-term recovery. It will also expand the definition of habitability allowing for repairs to homes with prior need for restoration, and will simplify the FEMA application process. 

In addition to reforms that benefit people with and without disabilities, FEMA has adopted reforms that benefit the Disability Community specifically. Disabled disaster survivors may now use FEMA reimbursement to make certain accessibility improvements that were not in place prior to the declared disaster. This applies to disabled disaster survivors who acquire a disability as a result of the disaster as well as to disabled disaster survivors who needed the modification prior to the disaster but did not yet have it. This change helps survivors with disabilities improve their living conditions by making their homes even more accessible than they were pre-disaster.

However, under this reform, only exterior ramps, grab bars, and paved pathways are covered. While providing these items to disaster survivors with disabilities is beneficial, The Partnership for Inclusive Disaster Strategies recommends that the list be expanded to include additional types of accessibility-related home repair and accessibility-related personal property items. 

Template for comments on the Interim Final Rule - Please note this is a template, feel free to make changes and add items that people in your organization or consumers / members / constituents would like added.

Click on the button below to download the template comments and make them your own!

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