September 3, 2024
Administrator Deanne Criswell
Federal Emergency Management Agency
500 C Street, SW.
Washington, DC 20472

 

Re: 44 CFR Part 206 [Docket ID FEMA–2023–0005] RIN 1660–AB09 Comments on Update of FEMA's Public Assistance Regulations

 

Dear Administrator Criswell,

The Partnership for Inclusive Disaster Strategies (The Partnership) appreciates the opportunity to submit comments on the proposed rule to update FEMA’s Public Assistance regulations.

The Partnership is the only U.S. disability-led nonprofit organization with a focused mission on equity for 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 encounter before, during, and after disasters and emergencies.

Thank you for expanding the list of “eligible Private Nonprofit (PNP) facility” for FEMA Public Assistance reimbursement. However, the current definition of an “eligible Private Nonprofit (PNP) facility” is not broad enough. It does not encompass private nonprofit organizations that are vital in providing services to people with disabilities and older adults. Organizations that should be included as PNPs that may receive FEMA Public Assistance reimbursement are Centers for Independent Living, as well as Protection and Advocacy Systems, Councils on Developmental Disabilities, University Centers for Excellence in Developmental Disability, Assistive Technology programs, ADA Centers, Aging and Disability Resource Centers, and Area Agencies on Aging. All of these disability/older adult focused organizations have assisted people with disabilities in disaster preparedness, response, and recovery. This assistance has included force multiplying and amplifying critical information, conducting virtual and door-to-door wellness checks, providing and arranging for personal assistance services, coordinating and providing accessible transportation, replacing durable medical equipment and other disability supplies, and acting as community hubs for charging and distribution centers, along other emergency protective measures. (Eligible emergency protective measures under Public Assistance Programs and Policy Guidelines (PAPPG: pg. 110-111).

 Centers for Independent Living (CILs) are particularly well situated to be recognized as eligible PNPs for reimbursement of emergency protective measures provided to people with disabilities and others with access and functional needs throughout disasters. The Administration for Community Living defines Centers for Independent Living (CILs) “as consumer-controlled, community-based, cross-disability, nonresidential private non-profit agency that are designed and operated within a local community by individuals with disabilities, and provides an array of independent living services.”

There are more than 400 Centers for Independent Living across the country, which are consumer-controlled, community-based, cross-disability, nonresidential, private nonprofit agencies that provide Independent Living (IL) services.

 At a minimum, CILs are required to provide the following IL core services:

• Information and referral;
• Skills training;
• Peer support;
• Individual and systems advocacy; and
• Transition from nursing facilities and other institutions to the community, diversion from being institutionalized, and facilitate transition of youth to postsecondary life.

“CILs also may provide, among other services: psychological counseling, assistance in securing housing or shelter, personal assistance services, transportation referral and assistance, physical therapy, mobility training, rehabilitation technology, recreation, and other services necessary to improve the ability of individuals with significant disabilities to function independently in the family or community and/or to continue in employment.” 

“Each state and U.S. territory is required to maintain a Statewide Independent Living Council (SILC). The SILC and the Centers for Independent Living (CILs) within the state develop a State Plan for Independent Living (SPIL). The SPIL is a document required by law that indicates how the Independent Living (IL) Network is going to improve independent living services for individuals with disabilities over the next three years. It identifies the needs and priorities of consumers, providers, and other stakeholders and sets forth goals and objectives to respond to them.”

Many states and territories include emergency preparedness, response, and recovery as part of their SPIL. The SPIL goals serve as a guiding framework for CILs to provide a unique role in their local communities. However, activities that extend beyond the federally funded core services often remain unfunded, including critical emergency preparedness, response, and recovery efforts. 

Goals under the SPIL often cover a variety of aspects of emergency management, and can include:

• “Disaster Preparedness/Response/Recovery Resulting in Systemic Change. People with disabilities will have equal access to the community resources as a result of, but not limited to, disasters, natural (Example: hurricane or pandemic), human-made (Example: terrorism, civil unrest, or a mass shooting), or technological (Example: chemical spills, power outages, or mass cybersecurity breach)” -  Florida State Plan for Independent Living  
• "During times of emergency, Centers work collaboratively to assist people with disabilities to coordinate services with local community partners" - Texas State Plan for Independent Living 
• “AZSILC engages in environmental justice education, outreach, and advocacy related to existing or emerging environmental impacts on the disability community, such as: climate change, air pollution, toxic exposure, extreme heat, epidemics and pandemics, and public safety threats.” - Arizona State Plan for Independent Living 

Having disaster/emergency related goals in the SPILs encourages CILs to support consumers prepare for, respond to, and recover from disasters and emergencies. 

In past disasters, CILs and other disability and aging organizations have helped people with disabilities during disaster response, for example: 

• Transporting and pre-positioning equipment and other resources for response;
• Distributing supplies and commodities;
• Medical care and transport;
• Evacuation and sheltering,
• Search and rescue to locate people with disabilities survivors, household pets, and service animals requiring assistance;
• Use or lease of temporary generators for facilities that provide essential community services; and
• Dissemination of accessible information to the public to provide warnings and guidance about health and safety hazards using various strategies, such as flyers, public service announcements, or newspaper campaigns.

All of these are listed as eligible emergency protective measures under Public Assistance Programs and Policy Guidelines (PAPPG: pg. 110-111).

 

Below are examples from the field across the country: 

Region 1:

The Vermont Center for Independent Living (VCIL) was hit hard by flooding in July 2023 and then a year later July 2024, Vermont was hit again with awful flooding. VCIL lost their main office and it has been heartbreaking as they try to rebuild. VCIL peers were hit in many ways including initially needing one on one support through policy and outreach work. When the flooding hit they worked with FEMA to hold daily stakeholder meetings. 

These meetings were helpful in making connections with FEMA, State of Vermont response as well as connection to other community members. VCIL took a leadership role within the Disability Community around these meetings ensuring that the response was accessible. In the beginning, they called all their active peers to hear what was happening to ensure people had what they needed. VCIL Peer Advocate Counselors helped make connections to peers in need of medications and food. They continued to help support peers one-on-one throughout that time. They supported peers in getting connected to the disaster centers and help with applications. In addition, they worked on accessibility issues and had support from FEMA representatives in that work.

 

Region 2:

In recent years Puerto Rico has been adversely impacted by many disasters including tropical storms, hurricanes, earthquakes, tornadoes, COVID-19 pandemic, floodings, etc. In the aftermath of the most historic disaster on the island in the last decade, Hurricane Maria, Movimiento para el Alcance de Vida Independiente (MAVI) one of two CILs in Puerto Rico, united with our local disability organizations: the PR UCEDD, the State Council for Developmental Disabilities, the PR Protection and  Advocacy State Agency and the PR Assistive Technology Program to provide immediate response efforts  that impacted over 9,000 people with disabilities and their family members, with:

• food, 
• clothing, 
• assistive equipment, 
• generators, 
• water, 
• medications, 
• transportation to and cleaning of homes, etc. 

As nonprofits and state agencies with limited resources, we did not have immediate access to funding and resources to assist families in dire circumstances. However, thanks to the collaboration of organizations on the mainland such as the Partnership for Inclusive Disaster Strategies, FODAC, Trach Mommas and  others, we were able to ensure that people with disabilities remain well and were able to return to their homes, thus  preventing their institutionalization.  

During the aftermath of other disasters, the CIL continued to step up and also began providing  generators, and currently are working with the Department of Energy to install solar panel systems with  batteries for energy dependent individuals across the island.  

In 2018, MAVI worked side by side with FEMA and the Puerto Rico Emergency Management Bureau  (PREMB) to create and maintain the Core Advisory Groups (CAGs) which are a whole community group that brings together non-profit organizations, state, municipal and federal agencies, community  organizations and people with disabilities within the community to work together to ensure the well being of people with disabilities before, during and after disasters. These CAGs and the CIL have worked alongside PREMB at the EOC to provide response efforts during disasters, they have helped review and work on mass care state emergency plan to ensure they are inclusive of people with disabilities’ needs. We have also created checklists and visual communication toolkits and provided them to municipal governments to assist them in the development of their municipal emergency plans to ensure they are inclusive. MAVI  is also inspecting shelters across the 78 municipalities of the island, reviewing and pointing out any  accessibility issues that could hinder full access for people with disabilities that must use these shelters in emergencies.  

During the COVID outbreak MAVI received CDC funding to create vaccinations events across the island, ensuring people with disabilities had all the reasonable accommodations they needed to get vaccinated and ensure their health during the pandemic. We also created a protocol that vaccination sites could use to ensure that people with disabilities were well informed and provided equitable services during any type of massive vaccination event. This protocol was shared with the PR Health Department and highlighted by the CDC  as one of the best practices emerging from their funding.

In New Jersey, DIAL – Center for Independent Living has collaborated with FEMA officials to support regional Disaster Recovery Centers (DRCs). They also work with officials from state, county, and local Office of Emergency Management (OEMs) to assist people with disabilities after disasters.

 

Region 3: 

In Williamsport, Pennsylvania, Roads to Freedom Center for Independent Living (RTFCIL) has been reimbursed for emergency protective measures through a number of the counties they serve. RTFCILs conducted emergency relocations in response to COVID-19 outbreaks in nursing facilities during the federally declared disaster and public health emergency. They argued that the residents were essentially unhoused, living under conditions similar to those in homeless shelters. RTFCIL petitioned FEMA for support but faced challenges due to a lack of clear guidance from FEMA on utilizing CILs during disasters. This led to contradictory responses from various government agencies, which delayed their relocation efforts and hindered coordination with other Pennsylvania CILs.

Despite these challenges, after FEMA published the Addendum: Delivering Personal Assistance Services in Congregate and Non-Congregate Sheltering later in 2020 that explicitly named CILs as eligible providers for personal assistance services during declared disasters, RTFCIL successfully applied for reimbursements for some of their relocation work.

In Philadelphia, in previous disasters, Liberty Resources, Inc. (LRI) has provided an array of services for disabled disaster survivors, such as:

• Assisted with emergency food distribution for people with disabilities and older adults unable to leave their homes;
• Developed and implemented programs to ensure that people with emergent need have access to personal care attendants;
• Provided personal protective equipment for people with disabilities and their personal attendants; and
• Advocated for mobile healthcare for people with disabilities and older adults unable to leave their homes, and connected such individuals to those services.

 

Region 4:

In disasters, the CIL of North Central Florida in Gainesville and Ocala, Florida

• Staffed Emergency Operation Centers to provide Technical Assistance on how to meet Access and Functional Needs during a disaster
• Staffed Emergency Shelters (General population and Special Needs) to provide Technical Assistance on how to meet program access, effective communication, amd Access and Functional Needs during a disaster
• Provided Durable Medical Equipment to people with disabilities who need it when recovering from disasters.
• Provided sign language interpreting services to shelters and to Emergency Management professionals when making Public Service Announcements before, during, and after disasters.
• Participated on Multi Agency Assessment Teams (MAAST) who went into shelters after storms to assess and meet needs of people with disabilities within the shelter.
• Provided services at Disaster Recovery Centers and Points of Distributions following a disaster.
• Provided home repair and modifications to homes damaged by disasters

The CIL of Gulf Coast (CILGC) in Fort Myers, Florida has assisted thousands of individuals with disabilities during disasters with: 

• Communication or alternate format needs
• Durable medical equipment replacement
• Conducting ADA access surveys at shelters and other locations where disaster related services have been provided
• Advocacy to ensure equal access to services
• Delivery of supplies door-to-door for consumers who cannot travel 
• Housing supports and individual preparedness activities
• CILGC serves as a community hub for resources and charging stations

Before, during and after disasters CIL of the Keys in Key Largo, Florida supports people with disabilities:

Before:

• Assisting consumers develop hurricane and communication plans. CILK provides assistance to people with disabilities regarding: Disaster kit checklist, what to bring to a shelter, list of important phone numbers and websites. Providing education workshops through our partnership with the Red Cross. MOU between CIL of the Keys and Red Cross. CIL of the Keys is part of the Red Cross Disability Integration Team. This team from the Red Cross ensures that all shelters and other service delivery sites, as well as all programs, services and communications are equally accessible to all clients, including those with disabilities and others with access and functional needs.
• Sending out written materials in accessible formats at the beginning of hurricane season each year with information on how to prepare and how to access local resources. Provide info about hurricane preparedness in our quarterly newsletters and social media.
• Contacting consumers directly before a storm to ensure they are going/have gone to a safe location of their choosing.
• Identifying local resources providing hurricane related services before, during and after a hurricane.
• Working with local public transportation to make sure that people who are homeless know how to take their pets on the bus to a shelter, and they know the rules of the pet friendly shelter. Work with homeless advocacy groups to make sure the homeless know how to get to the shelters on public transportation.
• Participating in local stakeholder groups on behalf of individuals with disabilities.

During:

• Ensuring communication via phone, text, or/and email with consumers.

After:

• Visiting emergency shelters to assess the status of people with disabilities, and advocate for unmet needs.
• Providing assistive devices to disabled people in local shelters.
• Accepting pallets of food and serving as distribution sites.
• Distributing supplies such as adult depends, generators, cleaning supplies, to people with disabilities and their families.
• Distributing assistive devices for disabled people. Securing donations of wheelchairs and other assistive devices nation-wide and coordinate shipping and distribution at the local level.
• Identifying and assisting individuals with disabilities who are displaced or dealing with unstable housing and in need of advocacy.
• Providing post hurricane Long-term case management: Assessment, Recovery Planning, Resource Coordination, Referrals and Follow-up. Assisting consumers in finding accessible housing in the event of damage to their previous housing. Providing long-term assistance to consumers on the road to recovery.
• Assisting in applying for disaster services such as:
  • Disaster unemployment benefits (DUA)
  • Disaster food stamps benefits (D-SNAP)
  • FEMA Individual Assistance and appeals and follow ups through all the process
  • Disaster SBA benefits
  • Medicare/Medicaid and other programs for replacement wheelchairs and other assistive devices
• Serving as a community hub where disabled disaster survivors can use free fax services, computer access and WIFI access to send important documentation to different organizations such as FEMA, SBA, DCF, Unemployment, insurance companies, etc.
• Providing information and referral in possible sources of funding post hurricane.
• Participating in community organizing activities to empower people with disabilities in the affected areas.
• Participating in stakeholder groups and systemic advocacy efforts aimed at increasing the supply of affordable, accessible housing options in the affected areas.

Suncoast Center for Independent Living in Sarasota, Florida has:

• Provided transportation for individuals with disabilities who were affected by Hurricane Ian and tropical storm Debby
• Coordinated Influenza and COVID-19 vaccines mini clinics for people 60 and over and individuals with disabilities who were affected by Hurricane Ian in Manatee and Sarasota County
• Purchased and provided hygiene products, clothing, furniture, bedding, cleaning supplies, appliances for Individuals with disabilities and their families who were affected by Hurricane Ian and tropical storm Debby
• Purchased and delivered food to those individuals with disabilities who were affected by COVID-19, Hurricane Ian, and tropical storm Debby
• Provided Durable Medical Equipment, laptops, and Assistive Technology to those individuals who may have lost theirs during Hurricane Ian and tropical storm Debby
• Provided resources to community partners and those who sustained major loss from the flooding caused by tropical storm Debby at the MARC’s (Multi-Agency Resource Center) in Manatee and Sarasota County
• Provided resources at the DRC (Disaster Recovery Center) sites in Manatee and Sarasota County
• Provided Information and Referrals to those individuals with disabilities and their families before and after disasters such as COVID-19, Hurricane Ian, and tropical storm Debby
• Assisted individuals with disabilities with transitioning from their homes, (due to the damage that was done in Hurricane Ian and tropical storm Debby), shelters, homelessness, and the hospitals
• Hosted FEMA events after Hurricane Ian
• Provided home repairs and modifications for those individuals with disabilities who had limited income and insurance after their homes were damaged by Hurricane Ian
• Provided and hosted events and programs such as Tai Chi, yoga, and music therapy, that could alleviate the stress and trauma caused by COVID-19, Hurricane Ian, and tropical storm Debby

In disasters, TARP Center for Independent Living in Paris, Tennessee could help with:

• Providing durable medical equipment
• Disseminating accessible information to the public to provide warnings and guidance about health and safety hazards using various strategies, such as flyers, public service announcements, or newspaper campaigns.
• Providing IT equipment, and using office internet.
• Distributing supplies and commodities.
• Providing information and referrals.

In disasters, Disability Rights Florida has: 

• Helped survivors submit and appeal FEMA applications
• Evaluated shelters for compliance and provided recommendations
• Supported survivors through the complaint process 
• Disseminated critical life-saving information

 

Region 5:

Disability Network Mid-Michigan in Midland, Michigan, during disasters such as the 100-year flood that occurred two months into the pandemic in 2020, as well as the pandemic itself, Disability Network Mid-Michigan has helped people with:

• Locating food, clothing, and accessible shelter

• Gaining access to up-to-date and accurate information about the emergency situations around them in language they can understand

• Access to technology for vital communication with family, service providers, and health care

• Transportation and support for vaccine acquisition

• Assistance with understanding and advocating for their rights as people with disabilities and service animal owners

• Critical wellness checks to reduce isolation and loneliness

• Assistance with acquiring or replacing adaptive equipment

• Advocacy for those isolated in congregate care settings with little to no family or community contact

In disasters, Disability Network West Michigan in Muskegon, Michigan has or are able to:

• Assist the individual/families with identifying affordable, accessible housing,
• Provide systems advocacy for needed services, and
• Assist with identifying accessibility barriers and work with the individual toward barrier elimination.

CILs in Illinois can provide:

• Personal contact with their consumers with disabilities, 
• Provision of durable medical equipment, 
• Relocation services and supports etc. 
• On-the-ground staff support that can make the difference between life and death of consumers living within the community.

In response to previous disasters, The National Center for Disability, Equity, and

Intersectionality led by the University of Cincinnati Center for Excellence in Developmental Disabilities (UCCEDD) in Cincinnati, Ohio has:

• Developed accessible, plain language versions of information disseminated by and from community officials,
• Organized community engagement opportunities for people with disabilities and their families to express needs and concerns,
• Offered insights to federal policymakers on the needs and priorities of the disability community,
• Compiled a comprehensive list of state-specific policies, legislation, and litigation related to school mask mandates during the COVID-19 pandemic,
• Distributed Social Stories in various languages to enhance understanding and support,
• Delivered presentations on "Your Rights" and strategies for addressing discrimination during crises at multiple venues.

 

Region 6: 

The Coalition for Barrier Free Living (CBFL) in Houston, Sugar Land, and Angleton Texas, in their most recent disaster, Hurricane Beryl wreaked havoc on the internal processes necessary to rescue or aid after the storm to persons with disabilities and the elderly. 

Taking the initiative to respond to the many calls they received during this time they:

• Provided food and water to those directly impacted by the storm
• Provided transportation to alternate areas for temporary aid
• Partnered with other companies to navigate home repairs and contracted services for disabled persons in their home
• Created a safe space to congregate as they made calls for assistance or reached out to family members to let them know they were okay

In disasters, The Valley Association for Independent Living (VAIL) in McAllen and Laredo, Texas has:

• played a pivotal role in assisting persons with disabilities before, during, and after natural disasters, such as hurricanes and flooding, in South Texas, by coordinating distribution centers, disseminating essential preparedness information in accessible formats, and educating the disability community about the assistance available if there is damage to their homes. 
• developed the Hidalgo County Inclusive Response Committee in Texas. This committee focuses on individuals with disabilities taking part in creating and implementing strategies that ensure the community receives the necessary support and resources during emergency situations.
• facilitated Community Emergency Response Training specifically designed for Deaf persons in their community. These training sessions equip Deaf individuals with the knowledge and skills to effectively respond to emergencies, ensuring that their peers are not left vulnerable during times of crisis.

In disasters, Disability Rights Texas has: 

• Helped survivors submit and appeal FEMA applications
• Evaluated shelters for compliance and provided recommendations
• Supported survivors through the complaint process 
• Disseminated critical life-saving information

 

Region 7:

CILs in Iowa and Nebraska have been supporting their consumers with the recent floods and tornadoes that have caused generational damage.

 

Region 8:

North Central Independent Living Services in Black Eagle, Montana has assisted seniors and people with disabilities to both register for Code Red if desired, and teaching, and providing forums on sheltering in place following a disaster. 

 

Region 9:

In disasters, Disability Community Resource Center (DCRC) in Los Angeles, California has:

• Assisted people with disabilities in advocating for their rights, such as finding ADA accessible shelters and arranging transportation options.
• Coordinated with City, County and State emergency managers to better respond to affected members of the community.
• Acted as an information disseminator to people with disabilities in regards to pertinent disaster information from public agencies.
• Provided Durable Medical Equipment to people with disabilities in need of such devices, which may have been lost or damaged.
• Assisted energy partners with evacuating customers with disabilities before and during Public Safety Power Shutoffs (PSPS) that may have medical conditions requiring electricity; as well as providing backup batteries/generators to such persons.
• Worked with people with disabilities to create personalized emergency preparedness plans that consider their individual circumstances.
• Provided go-bags to assist in community preparedness.
• Worked with individuals with disabilities to get the help they needed during and after a disaster by collaborating with public and private agencies, providing information and referral, and advocating on their behalf.
• Conducted emergency preparedness trainings based around disability to better prepare and respond to future emergencies and disasters people with disabilities may face in Los Angeles County.

In disasters, Resources for Independence Central Valley in Fresno, Merced, and Visalia California has:

• Provided disaster kits to individuals in need after wildfire evacuations.
• Offered disaster kits, portable Yeti batteries, hotel stays, transportation, and food vouchers during Public Safety Power Shutoffs (PSPS) and Non-PSPS (Weather Related).

Aloha Independent Living Hawaiʻi on Maui, Hawaiʻi was able to work closely with FEMA disability integration in situations where they were unable to advocate for items that survivors need. CILs can advise people of different FEMA programs, which may be beneficial to their access and functional needs. CILs also advise disabled disaster survivors on available non-governmental benefits. This is especially true in Hawaiʻi, where the culture is conflict avoidant, promoting the idea that one should not make a fuss about anything. In many cases, even if the survivor has the courage to ask for something once, they will not try again if they are denied.

The Hawaiʻi State Council on Developmental Disabilities (HCDD) provided critical

emergency disaster support to individuals with developmental disabilities and their families affected by the Maui wildfires. Key initiatives included:

• Disability Hui: The HCDD organized regular Zoom meetings with FEMA, the American Red Cross, and a broad coalition of cross-disability and aging organizations, state agencies, nonprofit and for-profit organizations, and individuals to address the specific needs of the aging and disability community in Maui. These meetings provided real time information on available support and updates on disaster relief efforts. HCDD ensured meeting and information accessibility through American Sign Language (ASL) interpreters, closed captioning, and plain language.
• Collaborating with other state and local agencies to coordinate resources and services for individuals with disabilities to provide information on housing, transportation, medical care, and other essential needs.
• Advocating for the needs of individuals with disabilities before state and federal agencies in the recovery process.
• Providing resources, emotional support, community support groups, and counseling services.
• Distributing information about disaster relief programs, assistance, and resources through various channels, including social media, websites, and community outreach.

 

Region 10:

In Marysville and Lakewood, Washington, The Center For Independence (CFI) began building relationships with partners at the local level in 2006. They have consistently expanded their outreach to include state, region, nation/territories and other countries.

• They joined WA State Partners including the WA Dept of Health and Division of Emergency Management immediately after the Oso WA landslide in May of 2014 to create the WA State Coalition for Inclusive Emergency Planning/Preparedness (WA-CIEP).
• Together, CFI and WA CIEP have engaged with partners in every declared event since that day in 2014. This also includes hotline work with the Partnership (PIDS) and deployments to active recoveries with a lot of work being possible over phone and broadband communication options.
• One huge success that continues to this day is that they had recently included engaging as subject matter experts regarding access for COVID-19 related response. CFI works closely with Pierce and Snohomish Counties alongside WA CIEP, WA DOH to assure access to testing, PPE, pharmacy MCMs and vaccines. 
• WA State Plan for Independent Living (WA-SPIL) has included aspects and goals for Inclusion and access since the update directly following the creation of WA CIEP.
• WA CIEP and the Independent Living Network have met frequently with peers and partners from WA State, Region 10, and nationally. They have consistently engagement with FEMA R10 RDIS as well as WA EMD Access and Functional Needs lead (A position they helped create) to coordinate with WA DOH Office of Resilience and Health Security (ORHS), all disability related organizations and community members to support every Essential Support Function (ESF) especially ESF 6 and 8.

These are just a few examples of the many organizations  working tirelessly on the front lines, striving to support people with disabilities during disasters. The ability of CILs and other disability and aging organizations to continue offering these essential services depends heavily on being recognized as “eligible Private Non Profit facility” to establish operational sustainability plans.

In addition to offering the services listed above and more to disabled disaster survivors, CILs have specific expertise. CILs know how to provide services in ways that are compliant with ADA and section 504 obligations. This means they are located in a physically compliant venue, and know how to procure auxiliary aids and services such as sign language interpreters and material in accessible format, along with being  familiar with the legal rights of people with disabilities during disasters. It also means CILs have deep familiarity with the local disability community and may be able to assist with locating disabled community members and because they have a relationship with individuals, they better understand their needs. Because they are trusted sources, the disability community may be more inclined to visit CILs whether it be virtually or physically, and to give credence to instructions and information provided by CILs.

This can also be said for Protection and Advocacy Systems, Councils on Developmental Disabilities, University Centers for Excellence in Developmental Disability, Assistive Technology programs, ADA Centers, Aging and Disability Resource Centers and the Area Agencies on Aging serve a similar purpose for older adults.

Additionally, the National Council on Disability’s (NCD) 2023 report The Impacts of Extreme Weather Events on People with Disabilities, found disability-led nonprofit organizations, especially CILs, that met the needs of the disability community before, during and after disasters reported difficulty in applying for and receiving reimbursement through FEMA’s Public Assistance Program.

Moreover, NCD’s 2021 Progress Report discussed the problem with the current PNP definition. “The standing definition of PNPs often exclude facilities such as CILs and similar nonprofits that operate in an open and public manner to ensure that certain populations have the services they need to survive.” NCD recommended in that report that FEMA issue guidance expanding the definition of PNPs to include CILs and other organizations, ensuring they can continue to provide disaster relief services to people with disabilities.

Explicitly recognizing that CILs and other disability and aging organizations are eligible private nonprofit for Public Assistance will support the resiliency of disability and aging communities. Whole community recovery cannot be achieved until everyone including people with disabilities and older adults can recover. CILs and other disability and aging nonprofits that are compensated for their services can provide the bridge to disability community recovery, and thus whole community recovery.

Thank you for considering our comments and recommendations, which aim to ensure that FEMA's Public Assistance regulations fully include and support organizations vital to people with disabilities and older adults.

Shaylin Sluzalis and Germán Parodi

Co-Executive Directors