August 29, 2025

National Council on Disability
1331 F Street NW, Suite 850
Washington, DC 20004

Public Comment: Integrating Disability and Access and Functional Needs Coordination Across the Emergency Support Functions and Developing a Comprehensive State Toolkit

Dear Chair and Members of the National Council on Disability,

We at The Partnership for Inclusive Disaster Strategies (The Partnership) thank the Council for the opportunity to participate in this panel and submit comments on improving the outcome of people with disabilities before, during, and after disasters. As the only U.S. disability‑led nonprofit organization focused solely on the rights and needs of people with disabilities and people with access and functional needs across all phases of emergency management, we convene local disability organizations, advocates, emergency managers, public health officials, first responders,  local, state/territory, and federal agencies, and other stakeholders. We deliver disability‑led disaster response, training, technical assistance, and policy advocacy. My comments today will cover why disability and access and functional needs integration must be system‑wide, how an access and functional needs coordinator adds value to each emergency support function, the asset of disability-led community based organizations (CBOs), and essential elements of a state toolkit for disability and access and functional needs integration. 

Our recommendations reflect the Partnership’s direct experience supporting disabled disaster survivors and incorporate insights from trusted sources such as the Government Accountability Office, the Federal Emergency Management Agency’s Office of Disability Integration and Coordination (ODIC), state access and functional needs guidance, and the latest FEMA program updates.

Why Disability and Access and Functional Needs Integration Must Be System‑Wide

Federal civil rights law requires state and local governments to provide equal access to emergency programs. Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act prohibit discrimination and require effective communication, reasonable modifications, and accessible facilities. One in four U.S. adults has a disability, and people with disabilities are 2-4 times more likely to be injured or die in disasters than nondisabled people, making systemic inclusion a life-safety imperative. In the wake of major hurricanes in 2017, the Government Accountability Office (GAO) found that FEMA’s efforts were inconsistent; regional offices lacked clear procedures for integrating disability advisors, and had not provided sufficient training, leaving state and local managers ill‑prepared to serve people with disabilities. A subsequent GAO report noted that FEMA did not establish clear objectives or a training plan for its disability integration approach, leading to uneven implementation. During those disasters many people with disabilities could not be located or assisted, and inaccessibility of the FEMA Individual Assistance application deterred people from applying.

FEMA’s Office of Disability Integration and Coordination (ODIC) has worked to close persistent access gaps by advancing inclusive practices, such as accessible evacuation and transportation; communication access; accessible shelters and temporary housing; and guidance on dietary, personal-assistance, and service-animal needs. As FEMA moves the functions of ODIC to the Office of Civil Rights, the statutory responsibilities of the Disability Coordinator established in 6 U.S.C. § 321b must continue and, consistent with the Post-Katrina Emergency Management Reform Act, must report directly to the Administrator. The Disability Coordinator’s duties expressly include consulting with organizations representing people with disabilities to inform planning and relief efforts. We note our productive relationship with Dr. Sherman Gillums, Jr. during his time as ODIC Director and, after his March 4, 2025 departure, our engagement with Acting Administrator Elizabeth Edge; however, since June 2025, repeated outreach has not received a response. All of this raises concerns about continuity, transparency, and compliance. 

At the state level, some are adopting “whole‑community” approaches. Two examples are Colorado and Nevada which operationalize this approach by staffing state-level access and functional needs coordinators who apply the CMIST (Communication, Maintaining Health, Independence, Support/Safety/Self-determination, and Transportation) framework across preparedness, response, and recovery. The Department of Justice’s ADA Best Practices Tool Kit for State and Local Government provides checklists for emergency management, including shelter accessibility. Yet these tools remain systemically underutilized.

Integrating a dedicated access and functional needs coordinator into the Emergency Operations Center (EOC) with access across each ESF is critical to translate federal guidance into practice, ensure compliance with civil‑rights obligations, and improve outcomes for disabled disaster survivors.

How an Access and Functional Needs Coordinator Adds Value to Each Emergency Support Function

The National Response Framework organizes federal, state, and local response activities into fifteen ESFs. Below is a blueprint for integrating an access and functional needs coordinator into each ESF. The coordinator participates in planning and operations, and provides functional‑needs expertise to ESF leads and incident command.The integration of the Access and Functional Needs resource framework into ESFs is essential for life-safety and equitable resource coordination. Access and Functional Needs planning uses a whole-community approach and applies the CMIST lens to identify needs and operationalize supports.

Examples of Access and Functional Needs and CMIST in practice across ESFs:

ESF #1: Transportation

• Coordinate with transportation officials to ensure evacuation plans include wheelchair‑accessible buses, lift‑equipped vehicles, paratransit, and accessible evacuation routes and hubs throughout the community.
• Ensure transportation assets are ready to provide services to people who use wheelchairs or other mobility aids, and service animals handlers.
• Plan for accessible return to home transportation, including vehicles for re‑entry when evacuation orders are lifted.

ESF #2: Communications

• Ensure emergency alerts in every mode, press briefings, and public service announcements are actionable and provided with captioning, American Sign Language interpreters, in plain language, and multilingual formats. Establish contracts for rapid sign language and CART services, and ensure all public websites and social media messages are 508 complaint.
• Guarantee TTY (teletypewriter), relay, and text‑message options for hotlines. Work with external‑affairs personnel (ESF #15) to ensure communication strategies reach and are accessible to people with disabilities and people with access and functional needs.

ESF #3: Public Works and Engineering

• Advise on accessible design and practices when restoring infrastructure, clearing debris, or constructing temporary facilities.
• Identify areas in the community with a high density of people with disabilities that require priority restoration power through publically available data like EMPOWER data and partnerships with providers such as utilities.

ESF #4: Firefighting

• Train responders in techniques for interacting with people with different access needs with expertise from people with lived experience. Ensure decontamination stations can accommodate mobility devices and service animals.

ESF #5: Information and Planning

• Collect and analyze data on shelters’ accessibility, accessible transportation resources, and unmet needs. Incorporate these data into incident action plans.
• Pre‑script resource requests for accessible vehicles, interpreters, personal‑assistance services, durable medical equipment (DME), and consumable medical supplies (CMS). Coordinate with ESF #7 (Logistics) to activate these resources.

ESF #6: Mass Care, Emergency Assistance, Temporary Housing, and Human Services

• Ensure mass care sites are accessible and for shelters to use CMIST-based intake, provide accessible cots, refrigeration/power for medications and devices, personal‑assistance services, and communication supports. All together, ensure mass care sites and amenities are physically and programmatically accessible.
• Enforce policies that keep service animals with their handlers. If the state has an ESF dedicated to animal services (e.g., Florida’s ESF‑17), integrate disability considerations there as well.
• Develop and coordinate methods for home delivery of essential supplies to people who cannot reach or access a POD due to disability or access and functional need. 
• Advise on accessible temporary housing options and modifications (ramps, grab bars, accessible bathrooms).                                                                                                                                                                      

ESF #7: Logistics

• Maintain caches of wheelchairs, walkers, batteries, oxygen concentrators, hearing‑assistive devices, reading glasses, temporary ramps, accessible showers, portable lifts, tactile signage, and other disability equipment needed in shelters and recovery centers. Coordinate distribution and resupply.
• Ensure Points of Distribution (PODs) are physically accessible, provide effective communication, and include disability-related supplies (e.g., adaptive equipment, backup power) so people with disabilities can safely obtain essential resources.

ESF #8: Public Health and Medical Services

• Streamline processes for replacing medications and DME lost or damaged in disasters.
• Coordinate personal assistance services at home continuity, oxygen/respiratory supplies, and accessible alternate health care sites.
• Support public health in developing protocols and infection-control measures accessible to people with disabilities, for example, distribute masks that include transparent panels for people who rely on lip reading, provide plain-language and accessible-format health guidance, and incorporate non-congregate sheltering options with wrap-around essential services.

ESF #9: Search and Rescue

• Train search teams on how to support people with different access and functional needs, e.g. ask the person how to support them evacuate, where at all possible evacuate mobility aids and any necessary equipment. Ensure training is developed or co-developed by people with lived experience as disabled people. 

ESF #10: Oil and Hazardous Materials Response

• Ensure decontamination sites accommodate wheelchairs and mobility aids and that instructions are provided in multiple formats. Plan for cleaning or replacing contaminated mobility and assistive devices and service animal gear.

ESF #11: Agriculture and Natural Resources

• Coordinate with feeding operations to meet individual dietary needs and provide accessible distribution.
• Plan for supporting farmers with disabilities, including ensuring accessible recovery assistance, adaptive equipment, and continuity of agricultural operations after disasters.

ESF #12: Energy

• Work with utilities to develop programs to provide alternative power backup sources for households using life‑sustaining equipment.
• Provide charging stations at shelters and CBOs serving as hubs, and coordinate fuel for generators used by CBO’s serving at risk communities.

ESF #13: Public Safety and Security

• Ensure law‑enforcement officers receive training on interacting respectfully with people with disabilities, crisis de-escalation, and accessible evacuation/re-entry. Ensure training is developed or co-developed by people with lived experience as disabled people. 

ESF #14: Cross-Sector Business and Infrastructure

• Work through the ESF-14 lead to include disability related needs (DME/CMS, oxygen supplies) into private-sector coordination and priority lists.
• Identify disability-led community partners to collaborate with to meet community needs.
• Monitor and mitigate cascading disruptions (oxygen, fuel, power, pharmacy delivery,) affecting people with disabilities and people with access and functional needs, and coordinate with ESFs to prevent duplication and miscommunication.

ESF #15: External Affairs

• Collaborate with public information officers to ensure all public messages (press releases, social media, websites) are 508 compliant. Ensure there are ASL interpreters for press conferences, captioning for televised announcements, and materials in plain language, Braille, and large print. Engage disability‑led organizations to disseminate information to their networks.
• Establish channels for people with disabilities to report unmet needs and provide feedback on response efforts; conduct rapid community surveys to understand unmet access and functional needs.

The Asset of Disability-Led Community-Based Organizations 

Disability-led CBOs, Centers for Independent Living (CILs), Protection & Advocacy (P&A) systems, Developmental Disability (DD) Councils, and Statewide Independent Living Councils (SILCs) are force multipliers that extend emergency managers' reach, help close access gaps, and accelerate successful outcomes. They provide ADA-competent services, possess deep local trust, and maintain real-time situational awareness of disabled people’s needs.

Examples:

• Puerto Rico (MAVI, CIL): After Hurricane Maria and subsequent events, MAVI and partners from the Independent Living Network provided food, assistive equipment, generators, water, transportation, accessibility audits, and are instrumental in the Core Advisory Groups. MAVI also leads ongoing preparedness initiatives, state-funded trainings for individuals, agencies, and communities; and solar energy education.
• Wisconsin (Statewide Council on Physical Disabilities): Leads emergency preparedness efforts, and published an Emergency Preparedness Toolkit for the community and a voluntary access and functional needs information pipeline to local emergency management, coded in ArcGIS to inform evacuation resources and sheltering. Recently began engaging with the Office of Health and Emergency Planning on adopting new funding-formula metrics (serviceable area and drive time) to strengthen Hazard Vulnerability Assessments and target zone-specific risks (e.g., industrial adjacency).
• California (Disability Rights California (DRC) – P&A): A majority of post-disaster requests to DRC involve help accessing FEMA financial assistance. DRC assists survivors through the appeal process and identifies programs they qualify for to support recovery. In between disasters, they train people with disabilities on emergency preparedness, help them improve their readiness, participate in the Statewide Access and Functional Needs Council with investor-owned utilities, and educate attorneys and service providers on disability inclusion.
• Disability-led organizations nationwide have stepped into operational roles during federally declared disasters. In the Southeast and Gulf Coast, they have provided accessible evacuations and DME equipment. In the Midwest and Great Plains they have staffed disaster recovery centers to ensure ADA compliance and help survivors complete FEMA applications. In western states, they have acted as charging hubs, accessible transportation coordinators, and conveners for regional disability task forces. 

This demonstrates that disability-led CBOs consistently deliver essential emergency protective measures and recovery services that federal and state systems alone cannot fulfill.

Essential Elements of a State Toolkit for Disability and Access and Functional Needs Integration

A comprehensive toolkit equips state emergency management agencies to implement and operationalize disability and access and functional needs integration. It should include the following components:

• Center Equity in All Phases. Use equity as a foundational lens across preparedness, response, recovery, and mitigation; prioritize access to services, information, sheltering, and funding. In fall 2021, FEMA defined equity as "[t]he consistent and systematic fair, just and impartial treatment of all individuals."
• Build on Whole-Community Engagement. Embed trust-based partnerships with disability advocates, disability-led organizations, CBOs, CILs, and peer leaders; co-design plans and communications with people with lived experience (co-leadership, not one-off consultation).
• Summarize ADA Title II and Section 504 requirements. Include DOJ’s ADA Best Practices Tool Kit for emergency management and the Post‑Katrina Emergency Management Reform Act. Provide access checklists for mass care sites, evacuations, and public information.
• Provide a position description detailing qualifications, duties, and reporting structure. The coordinator should have authority to advise incident command and all ESF leads, both in preparedness and during EOC activation. Include an organizational chart showing the coordinator’s placement. Incorporate job aids for the coordinator and ESF leads.
• Compile contact lists for cross-disability entities like Statewide Independent Living Councils, Centers for Independent Living, Protection and Advocacy agencies, Developmental Disability Councils, Area Agencies on Aging; along Councils for the Blind, and organizations led by or for Deaf and hard-of-hearing people; interpreters, accessible transportation providers, and assistive technology programs. Encourage formal MOUs.
• Provide guidance on accessible alerting and information dissemination. Include sample accessible press‑release templates; requirements for sign language interpreters, captioning, and plain language; and procedures for using VRI, TTY/relay services and text‑based alerts.
• Offer guidance on identifying and coordinating accessible transportation resources (paratransit providers, accessible buses, lift‑equipped vans), establishing accessible pickup points, and support evacuee re-entry.
• Provide guidance for integrated shelter operations (urgent medical needs, DME, PAS, service-animal accommodations, physical and programmatic accessibility).
• Provide detailed CMIST guidance to replace siloed “special needs” models/annexes. 
• Add a mental/behavioral health continuity module (accessible crisis counseling, sensory-friendly spaces, tele-behavioral options, and continuity for existing care). 
• Collaborate with utilities to create programs that provide reliable backup power options for households with people dependent on life-sustaining equipment. . Include guidance on establishing charging hubs at shelters and obtaining generator fuel for responding CBOs.
• Outline training curricula that is developed or co-developed by people with lived disability experience for law‑enforcement officers on disability etiquette, communication strategies, and service animal protocols. 
• Provide guidance on accessible rebuilding standards, accessible temporary housing placements, and connections to community development agencies for accessible design. Include protocols for integrating disability services into long‑term recovery programs.
• Survey the Community to Understand access and functional needs. Use rapid surveys and feedback loops (hotlines, CBO partners) to quantify CMIST resource disruptions and deliberate interventions.
• Ensure the inclusion of people with disabilities in exercises and after‑action reviews.
• Develop templates for capturing lessons learned and measuring performance (e.g., accessible shelter readiness, time to deploy accessible transportation, satisfaction surveys among disabled evacuees). Require after‑action reports to address disability‑related gaps and assign corrective actions.
• Require accessible communications in partner briefings and meetings (captioning/ASL, plain language, 508 compliant web forms) and ensure accessible customer service at mass care sites.
• Ensure accessible applications, appeals, inspections, and rebuilding programs; include disability representation in LTRGs/Resilience Coalitions.
• Disability Integration Is Not a Box-Check. Place access and functional needs coordinators in leadership roles across planning, exercises, and operations with explicit authority and resourcing in emergency operation plans.

Such a toolkit should be regularly updated, and aligned with best practices from across the nation. States should implement these changes in their next revision of emergency management plans and exercise cycles. 

Recommendations to the National Council on Disability

• Recommend that every state and large local emergency management agency designate an access and functional needs coordinator as part of its EOC structure. The role should be codified in state plans.
• Request that FEMA and DOJ provide technical assistance and enforcement to ensure state and local agencies comply with ADA and Section 504 obligations. Many jurisdictions still lack accessible shelters and communications; federal oversight and training are needed.
• Encourage development of a national model for access and functional needs integration across all ESFs, adaptable by states/localities, with CMIST-aligned ESF checklists and performance metrics. Such a model should be consistent across jurisdictions.
• Support state adoption and adaptation of comprehensive toolkits, including the elements described above. NCD should partner with FEMA, HHS/ASPR, and ACL to identify funding, technical assistance, and peer‑to‑peer learning opportunities.
• Promote metrics and accountability by recommending that FEMA require states to report on accessible alerting and communications, accessible mass care sites, provision of emergency personal assistance services and in shelters, transportation, and satisfaction of needs met by disabled survivors. FEMA should publish plain language reports on how they are meeting the needs of people with disabilities throughout the disaster phases. Performance measures are essential to identify gaps and drive improvement.
• Encourage whole community engagement by urging states to involve people with disabilities and disability‑led organizations in planning, preparedness, response, recovery, and mitigation efforts. 

In closing

Integrating a dedicated access and functional needs coordinator as part of each Emergency Support Function and equipping states with comprehensive toolkits will significantly improve disaster outcomes for people with disabilities and people with access and functional needs. As disasters become more frequent and severe, we must establish practices that protect and empower all members of our communities.

The Partnership for Inclusive Disaster Strategies is ready to collaborate with the National Council on Disability, FEMA, and state and local partners to advance these recommendations and ensure that no one is left behind in times of crisis. Thank you for your leadership and for considering these comments.

Respectfully submitted,

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