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Failing in the Right Direction

On March 29, Danny Vinik provided a clear and sober exploration of the complex institutional challenges facing disaster survivors in affected American communities. 

As Chief Strategy and Innovation Officer I’ve helped lead SBP’s efforts in disaster-impacted communities all over the country. My experience has taught me that after disasters human beings have a breaking point — a point at which they can no longer function and contribute as professionals, as spouses, as parents. Each individual’s breaking point is a personalized mixture of individual resilience and preparedness before disaster and the overall time and predictability of recovery after events occur. Thus, SBP has adopted the mission of shrinking the time between disaster and recovery to help fortify people against this breaking point.

Current and former FEMA directors and other disaster experts agree that America’s relief and recovery programs and processes are too numerous and too complicated for survivors to navigate, let alone in such urgent conditions. These programs and resources were created to help, but the frustration and exhaustion of the process often ends with survivors simply giving up.

What follows are recommendations aimed at increasing individual resilience, improving the predictability of recovery resources, and reducing time the time it takes communities to access these resources after disaster.

Increasing Individual Resilience

America needs the National Flood Insurance Program (NFIP), as its services are far too important to far too many each year to simply abandon. That said, the broader goal should be enrolling more people in the program — especially those outside traditionally defined floodplains which are established via outdated maps that often fail to reflect current and future risk.


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Image: Official FIRM (Flood Insurance Rate Map) Panel available at https://msc.fema.gov/portal/se...


Increasing take-up rates improves the resilience of individual homeowners, spreads risk across a broader subscription base, and generates much needed revenue for the program. Efforts to increase coverage areas will be made easier in two ways: 

  1.  Clearer language around risk. The probability estimations that define the floodplains (where the 100 year floodplain = 1% risk of flood in any given year) are not effectively communicating current and future risk in ways that change behavior. Flooding can happen almost anywhere and communicating this clearly and frequently along with clear steps to obtain the right coverage will help.
  2. FEMA should address clearly and frequently the perception that flood insurance is not affordable.  The average cost of coverage is $1,100 and can buy up to $250,000 in coverage. When disasters happen, the value of the right policy is plain to see. Subsidies are always an option for low-income families, but financial institutions could also build insurance costs into the mortgages themselves. Maybe lenders can write a 35-year note that layers in the costs of applicable insurance coverage and policies? This will help protect the client and the asset from the potential consequences of knowable risks. Why couldn’t that work?

No matter how you look at it, the right insurance coverage remains the most accessible and potentially effective method for increasing resilience and providing adequate resources for a prompt and predictable recovery.

 

Increasing Predictability of Recovery Resources 

OneApp

When events occur, survivors are immediately introduced to the application burden — an alphabet soup of acronyms and programs each with a different (but similar) application, each its own scheduled appointments, each its own background/eligibility documentation process. These redundancies burden survivors from the very beginning. FEMA, SBA and HUD should work as partners to develop and establish the primacy of a single, shared application — call it OneApp. This would allow impacted individuals to apply once and have their information shared with all relevant programs,even those that may begin later. This could be tempered by better data sharing agreements are arranged between relevant federal agencies, as much of the information needed to apply for disaster assistance is part of annual tax filings. Perhaps the IRS can share this data with FEMA to help auto-populate some application information after disasters.

FEMA Damage Assessment Methodology

The FEMA damage assessment process relies too heavily on site visits by inspectors to visually assess damages on site. The assessments themselves take time for scheduling and travel, and leave room for human error. At the same time, great advancements have been made in the use of various technologies and big data to collect and assess damage more quickly and at less cost. FEMA should convene technology and insurance industry executives to identify and design pilot opportunities to test new technologies and benefit from recent advances.

FEMA Award Calculations

This is a dense problem that affects both time and predictability.  FEMA cannot clearly explain how award amounts are determined or how long this information may take, making the process incredibly unpredictable for clients. The scheduling and coordination of on-site inspections, calculations and the bureaucratic process that transforms the written assessment into an award letter and funds take even more precious time. This black box calculation coupled with imprecise language in denial letters leave survivors dejected and confused about how and what to appeal. Vinik  asked about award determinations and was referred to a 140 page manual that also failed to explain the process clearly.

This is not the fault of any individual or entity alone. We must recognize that these are early, substantive, front-line interactions between the American government and its disaster-impacted citizens  in urgent times, about critical resources. Public officials, impacted residents and concerned citizens alike should be able to understand how these decisions are made. FEMA should simplify this calculation and deliver notice more quickly.  Clarity around the details of the award determination and the speed of communication and delivery to survivors is crucial for recovery planning and for any appeals the survivor might choose to make.

FEMA Appeals Process

Survivors often do not understand the appeals process and so many applicants take the first answer as the final answer. FEMA should communicate as plainly and frequently about the appellate process as they do about the application process. FEMA could provide how-to tips and guides on addressing common problems in the appeals process and helping applicants submit the strongest appeal possible.

Reducing the Time to Access/Deliver Resources

The long term recovery programs driven by HUD CDBG-DR funds are supposed to act as a safety net for the most vulnerable, but in our current system these funds take the longest to arrive—months after people have hit the ground. Here are a few ideas that could reduce the time it takes for communities to access these resources:

Permanent CBDG-DR Fund at HUD

Instead of subjecting long term recovery activities to literal acts of Congress, a permanently funded Federal Disaster Recovery Fund should be established to allow for immediate availability of long term recovery funds after presidentially declared disaster events. This would allow long term recovery activities to begin quickly, while the supplemental appropriations process runs its course.

Local Preparedness and Recovery Planning

State and local governments should collect and prepare as much information and content about the community, its risks, and the actions they’ll take to help folks recover when/if if the risk ever becomes reality. If communities better understand their risk and the processes for accessing recovery funds after disasters, they could prepare some components of the action plans in advance saving the weeks and months it often takes to develop these from scratch. State and municipal governments could also pre-procure vendors and contractors who would provide services immediately, avoiding at least some of the lengthy post-disaster procurement delays. Proposed activities and draft action plans can be “pre-cleared” with HUD, then quickly scale-adjusted and made event-specific when disasters occur.

Leveraging Markets

The commitment of federal funds in the future should be able to incentivize private market activity today. HUD should tweak regulatory conditions to allow and incentivize bridge loan programs for low income communities immediately after events. Private investors and firms with disaster experience can identify and assist low-income clients today who are highly eligible candidates for CDBG-DR assistance that will arrive months, sometimes years later. This would allow low income communities to be restored at reasonable costs and in record time. Acute and severe human suffering in low-income communities can be transformed in to a planned, maturing investment on balance sheet. Paired with CRA requirements, existing tax credits programs, established Opportunity Zones — the potential for scale is clear. This idea should be tested in a series of pilots. Perhaps it can start in Kashmere Gardens?

The intolerable state is clear — people are giving up. America’s recovery system is failing survivors and disasters are affecting more and more people each year. So we need to take a first step. Let’s experiment and test new ideas, models, and methods. If we can start to isolate and tackle some of these most glaring issues then we might just make some progress. And if we fail, at least we’ll be failing in the right direction.