Disaster Discourse: The Hagerty Blog

A New Version of the PAPPG is Coming and FEMA Wants to Hear from You!

Last month, FEMA announced that it will be releasing a fourth edition (Version 4) of the Public Assistance Program and Policy Guide (PAPPG), scheduled for publication January 2020.  It will be applicable to incidents declared on or after the date of publication.

The PAPPG is a single volume document that combines all Public Assistance (PA) policy and provides an overview of the PA Program implementation processes and practices.  The PA program is FEMA’s largest grant program, as it provides disaster response and recovery assistance to state, local, tribal and territorial (SLTT) government and certain nonprofit organizations.

The PAPPG consolidates PA policy in one place, making it critical to understanding how FEMA will implement the program and provide assistance.  For this latest version, FEMA has released the draft document for a 45-day public comment period, accepting comments until Monday, November 18, 2019. FEMA has stated that any comments received will be reviewed and considered for the final version of the guide.

The Hagerty team encourages all past, current, and future FEMA PA recipients and sub-recipients to consider reviewing the draft version of the PAPPG and submitting comments to FEMA. Let your voices or concerns be heard before this new guidance is finalized and published!

The Hagerty team is taking this opportunity to provide our feedback to FEMA in an effort to help shape policy to maximize the benefits for applicants, streamline and reduce recovery timelines, and minimize the administrative burden on communities impacted by disaster. Our team’s comments focus on policy changes that will have the most impact to communities recovering from disasters, including the following key takeaways:

1) Timelines 

We believe some of the new timelines and deadlines proposed for tasks, such as submitting documentation after project completion and RFI responses, will be very burdensome on applicants struggling to recover from disasters. Since many staff supporting recoveries are going above and beyond their day jobs to complete recovery-related tasks, imposing more stringent deadlines not found in law or regulation may help FEMA administer PA but does not lead to more effective local recovery and further confuses an already-complex PA process.  Notably, these new and excessive deadlines run counter to FEMA’s third strategic goal: “reduce the complexity of FEMA.”

2) Section 428 Guidance 

The draft PAPPG now promotes Section 428 as a first option for all permanent work.  Section 428 stems from the 2013 Sandy Recovery Improvement Act (SRIA) and it includes several pilot programs – including for permanent work – aimed at making recovery assistance more flexible, efficient and easy to administer.   We believe some of the policy pertaining to Section 428 implementation, particularly regarding the use of hazard mitigation funding, needs further clarification.

3) Appeals

Previous policy guidance encouraged FEMA field staff to resolve all disputes up front with PA applicants.  According to a 2017 fact sheet, FEMA correctly says that “[i]n many cases, eligibility issues arise from a lack of mutual understanding.”  However, the PAPPG draft eliminates all mention of resolving eligibility disputes up front – and implies that FEMA can formally deny eligibility without trying to resolve issues initially.  This will needlessly delay recovery as it forces recovering communities to enter the PA formal appeals process, which according to the Government Accountability Office (GAO) can take years to complete with a low probability that denials are overturned.  We at Hagerty believe this will undermine FEMA’s stated objective to allow locals – not the federal government – to drive recovery.

Additionally, the Hagerty team has reviewed the latest draft and will be sharing a comprehensive analysis after Version 4 is published in January. Stay tuned!

Hagerty Consulting is an emergency management consulting firm that helps our clients prepare for and recover from disasters. Established in 2001, Hagerty Consulting’s work includes some of the nation’s largest recovery and preparedness projects in more than 30 states, including 9/11, Hurricane Katrina, and Hurricane Sandy.  You can learn more about our disaster recovery practice here.