Federal Emergency Management Agency
500 C Street SW
Washington, DC 20472
May 15, 2025
Re: Docket ID: DHS-2025-0013, Request for Public Input on Experiences With FEMA Disaster Responses
The Partnership for Inclusive Disaster Strategies (The Partnership) is the only U.S. disability-led nonprofit organization that focuses on the rights, needs, and inclusion of people with disabilities and people with access and functional needs throughout all planning, programs, services, and procedures before, during, and after disasters and emergencies. We achieve our mission through disability-led disaster response and community resilience; community engagement, organizing, and leadership development; advocacy and systems change; training, technical assistance, and research; and unwavering support for local disability organizations.
The Partnership is a convener for local disability organizations, advocates, emergency managers, public health officials, federal, state/territorial and local government agencies, first responders, and allies across the country to address the urgent needs and systemic gaps and barriers people with disabilities face before, during, and after disasters and emergencies.
Thank you for the opportunity to provide comments to the FEMA Review Council.
FEMA’s Indispensable Role
FEMA’s capacity to coordinate across agencies, jurisdictions, and logistics cannot be duplicated by states or private entities. In times of crisis, FEMA is often the only national entity with the scale and mandate to meet disabled survivors’ immediate and long-term needs. Whether it’s funding housing repairs and temporary housing modifications, replacing essential mobility aids, or facilitating accessible evacuation protocols, FEMA provides services that no other agency is positioned to deliver.
Eliminating or weakening FEMA would disproportionately endanger disabled people, who already face increased risk during disasters. Many rely on FEMA to recover not just property but also their autonomy and health. This system must be fortified, not fragmented.
The Partnership’s Disability & Disaster Hotline frequently supports disabled disaster survivors who find relief only after FEMA interventions. These include situations when disabled disaster survivors have been stranded in unsafe housing, as well as barriers to receiving Temporary Shelter Assistance that have been resolved through FEMA’s engagement.
Preserve and Strengthen Individual Assistance Reforms
The 2024 Individual Assistance reforms were a watershed moment. Removing barriers such as requiring unnecessary documentation and permitting self-declarative statements for property ownership was instrumental in enabling disabled and non-disabled people to qualify for FEMA. Improved programs like Serious Needs Assistance and Displacement Assistance, when implemented swiftly, filled long-standing gaps.
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 both to individuals who acquired a disability as a result of the disaster and to those who had a disability beforehand but lacked needed modifications. This change helps improve living conditions by making homes more accessible post-disaster. However, the current coverage is limited to exterior ramps, grab bars, and paved pathways. The Partnership recommends expanding this list to include additional accessibility-related home repairs and personal property items.
However, overall implementation remains uneven. Some survivors are still erroneously told that inspections are required prior to receiving aid. The reforms must be embraced and fully enforced by FEMA. To facilitate this, there must be robust training and oversight. Appeals processes should be streamlined with consistent due dates, accessible forms must be readily available, and representative public education campaigns to increase awareness must be conducted.
Expand and Fully Staff the Regional Disability Integration Specialists (RDIS)
FEMA’s RDIS are a critical bridge between policy and practice. Yet, many regions have one RDIS to serve multiple states and other regions have no RDIS at all. These specialists are essential to embedding disability inclusion across FEMA programs.
We urge that at least one RDIS be assigned per state and territory, with consideration for geography, disaster frequency, and population demographics. RDIS staff should be empowered to make decisions, direct resources, and collaborate directly with state and local disability organizations.
Modernize FEMA’s Learning Management System (LMS)
FEMA’s current LMS is outdated and often inaccessible. Training lacks real-world scenarios involving disabled people, and materials are frequently not screen-reader compatible or available in multiple formats.
A fully modernized LMS must include disability rights law, effective communication, real case studies, and modules tailored to rural and frontier areas. Disability related courses and material should be co-designed and facilitated by disability-led organizations. Modernization must go beyond content and include infrastructure improvements for accessibility and remote access.
Establish a Cross-Agency Housing Task Force
Institutionalizing disabled disaster survivors in nursing facilities and other congregate care facilities is a recurring failure. FEMA must lead a coordinated effort with HUD, HHS, including ACL, to ensure disabled survivors are housed in accessible, affordable, integrated housing in the community.
The Housing Task Force must prioritize community-based solutions and fund essential supports such as food/water delivery, accessible transportation, and in-home attendant services. FEMA should fund and promote accessible shelter and long-term housing models.
Improve and Strengthen Inter-Agency Coordination
Disabled disaster survivors often fall through the cracks of siloed systems. FEMA must work with HHS, HUD, DOJ, and state partners to synchronize efforts. This is particularly needed for access, data-sharing, and cross-training.
Memoranda of Understanding should formalize this collaboration. Efficient disaster assistance cannot be achieved without cross-agency collaboration.
Ensure Strict Compliance with Section 504
Every dollar FEMA distributes must be tied to civil rights compliance. Grantees must demonstrate ADA and Section 504 adherence, not merely promise it.
FEMA should fund monitoring systems and impose consequences on jurisdictions that fail to uphold disability rights. Civil rights enforcement must not be optional, especially during crises.
Remove Barriers to Individual Assistance (IA)
Registration, inspections, and appeals must meet obligations to be accessible under Section 504 of the Rehabilitation Act. This includes providing electronic materials that are Section 508 compliant, Braille, large-print, sign language interpreters and other auxiliary aids and services. To support all people with disabilities in receiving IA, plain language should be used, and materials in Easy Read language (short, simplified sentences with visuals) should be available. Many disabled disaster survivors never apply because they cannot access or understand the process.
FEMA should publish step-by-step guides and FAQs in all accessible formats and languages, including sign language videos. Every Disaster Recovery Center (DRC) must meet physical and communication access standards.
Partner with Disability-Led Organizations (DLOs) and Disability-Related Organizations
DLOs know their communities, have built trust, and can implement solutions quickly. FEMA must formalize partnerships with DLOs, nationally and locally, across all phases of emergency management.
This includes Centers for Independent Living, Statewide Independent Living Councils, Protection & Advocacy agencies, Councils on Developmental Disabilities, and others. Funding must support both services and policy development. FEMA’s success depends on meaningful representation of disability voices. Without this, FEMA will lose sight of disabled people’s reality.
Build Disability Competency Across the Field
Training on disability cannot be optional. It must be required for FEMA all staff and contractors. It must cover ADA/504 compliance, including effective communication, accessibility, and modifications to policy, practice, and procedure.
Training must be interactive and scenario-based. DLOs should lead these efforts to ensure training is grounded in lived experience and best practices.
Collect and Publish Disaggregated Disability Data
FEMA cannot remedy what it doesn’t track. FEMA must collect, analyze, and publish anonymized data on disaster survivors by disability, demographic characteristics, geography, and type of assistance provided.
Data must be used to evaluate program effectiveness and guide reforms. Public transparency is essential for accountability.
Highlight Personal and Organizational Experiences
The Partnership’s Disability and Disaster Hotline has supported survivors denied aid due to disability, institutionalized for lack of accessible shelter, or left without medication due to policy gaps. These are not anomalies, they are systemic failures.
One caller, a wheelchair user without power or water for multiple days after Hurricane Helene in North Carolina, was denied temporary shelter assistance by FEMA. Only through collaborative engagement with FEMA’s Office of Disability Integration and Coordination (ODIC) did they receive support. Such situations must inform policy change.
Reform, Not Retreat
The emergency management system needs reform not dismantling. FEMA plays an irreplaceable role in disaster response. The answer to inefficiency is accountability, not austerity.
The Partnership welcomes this review and commits to working with FEMA and its partners to realize an inclusive, rights-based disaster recovery system for all.
Comment on Docket No. DHS-2025-0013 – FEMA Review Council RFI
Leave a Comment
Updated: May 16, 2025 by admin
Federal Emergency Management Agency
500 C Street SW
Washington, DC 20472
May 15, 2025
Re: Docket ID: DHS-2025-0013, Request for Public Input on Experiences With FEMA Disaster Responses
The Partnership for Inclusive Disaster Strategies (The Partnership) is the only U.S. disability-led nonprofit organization that focuses on the rights, needs, and inclusion of people with disabilities and people with access and functional needs throughout all planning, programs, services, and procedures before, during, and after disasters and emergencies. We achieve our mission through disability-led disaster response and community resilience; community engagement, organizing, and leadership development; advocacy and systems change; training, technical assistance, and research; and unwavering support for local disability organizations.
The Partnership is a convener for local disability organizations, advocates, emergency managers, public health officials, federal, state/territorial and local government agencies, first responders, and allies across the country to address the urgent needs and systemic gaps and barriers people with disabilities face before, during, and after disasters and emergencies.
Thank you for the opportunity to provide comments to the FEMA Review Council.
FEMA’s Indispensable Role
FEMA’s capacity to coordinate across agencies, jurisdictions, and logistics cannot be duplicated by states or private entities. In times of crisis, FEMA is often the only national entity with the scale and mandate to meet disabled survivors’ immediate and long-term needs. Whether it’s funding housing repairs and temporary housing modifications, replacing essential mobility aids, or facilitating accessible evacuation protocols, FEMA provides services that no other agency is positioned to deliver.
Eliminating or weakening FEMA would disproportionately endanger disabled people, who already face increased risk during disasters. Many rely on FEMA to recover not just property but also their autonomy and health. This system must be fortified, not fragmented.
The Partnership’s Disability & Disaster Hotline frequently supports disabled disaster survivors who find relief only after FEMA interventions. These include situations when disabled disaster survivors have been stranded in unsafe housing, as well as barriers to receiving Temporary Shelter Assistance that have been resolved through FEMA’s engagement.
Preserve and Strengthen Individual Assistance Reforms
The 2024 Individual Assistance reforms were a watershed moment. Removing barriers such as requiring unnecessary documentation and permitting self-declarative statements for property ownership was instrumental in enabling disabled and non-disabled people to qualify for FEMA. Improved programs like Serious Needs Assistance and Displacement Assistance, when implemented swiftly, filled long-standing gaps.
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 both to individuals who acquired a disability as a result of the disaster and to those who had a disability beforehand but lacked needed modifications. This change helps improve living conditions by making homes more accessible post-disaster. However, the current coverage is limited to exterior ramps, grab bars, and paved pathways. The Partnership recommends expanding this list to include additional accessibility-related home repairs and personal property items.
However, overall implementation remains uneven. Some survivors are still erroneously told that inspections are required prior to receiving aid. The reforms must be embraced and fully enforced by FEMA. To facilitate this, there must be robust training and oversight. Appeals processes should be streamlined with consistent due dates, accessible forms must be readily available, and representative public education campaigns to increase awareness must be conducted.
Expand and Fully Staff the Regional Disability Integration Specialists (RDIS)
FEMA’s RDIS are a critical bridge between policy and practice. Yet, many regions have one RDIS to serve multiple states and other regions have no RDIS at all. These specialists are essential to embedding disability inclusion across FEMA programs.
We urge that at least one RDIS be assigned per state and territory, with consideration for geography, disaster frequency, and population demographics. RDIS staff should be empowered to make decisions, direct resources, and collaborate directly with state and local disability organizations.
Modernize FEMA’s Learning Management System (LMS)
FEMA’s current LMS is outdated and often inaccessible. Training lacks real-world scenarios involving disabled people, and materials are frequently not screen-reader compatible or available in multiple formats.
A fully modernized LMS must include disability rights law, effective communication, real case studies, and modules tailored to rural and frontier areas. Disability related courses and material should be co-designed and facilitated by disability-led organizations. Modernization must go beyond content and include infrastructure improvements for accessibility and remote access.
Establish a Cross-Agency Housing Task Force
Institutionalizing disabled disaster survivors in nursing facilities and other congregate care facilities is a recurring failure. FEMA must lead a coordinated effort with HUD, HHS, including ACL, to ensure disabled survivors are housed in accessible, affordable, integrated housing in the community.
The Housing Task Force must prioritize community-based solutions and fund essential supports such as food/water delivery, accessible transportation, and in-home attendant services. FEMA should fund and promote accessible shelter and long-term housing models.
Improve and Strengthen Inter-Agency Coordination
Disabled disaster survivors often fall through the cracks of siloed systems. FEMA must work with HHS, HUD, DOJ, and state partners to synchronize efforts. This is particularly needed for access, data-sharing, and cross-training.
Memoranda of Understanding should formalize this collaboration. Efficient disaster assistance cannot be achieved without cross-agency collaboration.
Ensure Strict Compliance with Section 504
Every dollar FEMA distributes must be tied to civil rights compliance. Grantees must demonstrate ADA and Section 504 adherence, not merely promise it.
FEMA should fund monitoring systems and impose consequences on jurisdictions that fail to uphold disability rights. Civil rights enforcement must not be optional, especially during crises.
Remove Barriers to Individual Assistance (IA)
Registration, inspections, and appeals must meet obligations to be accessible under Section 504 of the Rehabilitation Act. This includes providing electronic materials that are Section 508 compliant, Braille, large-print, sign language interpreters and other auxiliary aids and services. To support all people with disabilities in receiving IA, plain language should be used, and materials in Easy Read language (short, simplified sentences with visuals) should be available. Many disabled disaster survivors never apply because they cannot access or understand the process.
FEMA should publish step-by-step guides and FAQs in all accessible formats and languages, including sign language videos. Every Disaster Recovery Center (DRC) must meet physical and communication access standards.
Partner with Disability-Led Organizations (DLOs) and Disability-Related Organizations
DLOs know their communities, have built trust, and can implement solutions quickly. FEMA must formalize partnerships with DLOs, nationally and locally, across all phases of emergency management.
This includes Centers for Independent Living, Statewide Independent Living Councils, Protection & Advocacy agencies, Councils on Developmental Disabilities, and others. Funding must support both services and policy development. FEMA’s success depends on meaningful representation of disability voices. Without this, FEMA will lose sight of disabled people’s reality.
Build Disability Competency Across the Field
Training on disability cannot be optional. It must be required for FEMA all staff and contractors. It must cover ADA/504 compliance, including effective communication, accessibility, and modifications to policy, practice, and procedure.
Training must be interactive and scenario-based. DLOs should lead these efforts to ensure training is grounded in lived experience and best practices.
Collect and Publish Disaggregated Disability Data
FEMA cannot remedy what it doesn’t track. FEMA must collect, analyze, and publish anonymized data on disaster survivors by disability, demographic characteristics, geography, and type of assistance provided.
Data must be used to evaluate program effectiveness and guide reforms. Public transparency is essential for accountability.
Highlight Personal and Organizational Experiences
The Partnership’s Disability and Disaster Hotline has supported survivors denied aid due to disability, institutionalized for lack of accessible shelter, or left without medication due to policy gaps. These are not anomalies, they are systemic failures.
One caller, a wheelchair user without power or water for multiple days after Hurricane Helene in North Carolina, was denied temporary shelter assistance by FEMA. Only through collaborative engagement with FEMA’s Office of Disability Integration and Coordination (ODIC) did they receive support. Such situations must inform policy change.
Reform, Not Retreat
The emergency management system needs reform not dismantling. FEMA plays an irreplaceable role in disaster response. The answer to inefficiency is accountability, not austerity.
The Partnership welcomes this review and commits to working with FEMA and its partners to realize an inclusive, rights-based disaster recovery system for all.
Category: Announcement, Disability Advocacy, Disability Advocacy, Disaster Response, FEMA, Uncategorized Tags: disability, disability rights, disasters, FEMA, news