Archives

Hagerty Health & Wellness Tips-Staying Safe & Healthy This Fall & Winter

As we enter the fall and winter months, the COVID-19 pandemic continues to rage across the country. Unlike when the pandemic started, we now know how to stop the spread of the virus and mitigate the risks of becoming infected. While it has been a long seven months, we have many more months ahead and must remain vigilant. Collectively, we can all play a role in blunting community spread of COVID-19 and stay safe and healthy this fall and winter by taking the following steps:

  • Get your flu shot. This could be the most important flu vaccine you ever get. The US Centers for Disease Control and Prevention (CDC) suggests getting your flu shot by the end of October. Every year, flu circulates widely in communities. The symptoms are similar to COVID-19 and in some cases can lead to complications requiring hospitalization. The 2018–2019 flu season in the United States, resulted in about half a million hospitalizations and more than 34,000 deaths. Public health experts worry what will happen if flu circulates widely at the same time as COVID-19.The term “twindemic” has already been written about by many media outlets. It refers to two pandemics happening simultaneously and could stretch our health care systems and our doctors and nurses to the breaking point.
  • Continue to Wear a Mask. Evidence shows wearing a mask saves lives. It is often said “I wear a mask to protect you, you wear a mask to protect me.” A study published in Health Affairs compared the COVID-19 growth rate before and after mask mandates in 15 states. It found that daily spread of COVID-19 dropped by 2 percent as more and more masks were worn. In reviewing COVID-19 deaths across 198 countries, another study found that those countries that societal norms favor mask wearing had lower death rates. Lives will be saved by wearing a mask when physical distancing is not possible.
  • Wash Your Hands Often. Frequent hand washing is one of the best ways to prevent the spread of COVID-19. Throughout the day, we all touch many common surfaces and then scratch our faces, eyes or rub our noses without even realizing it. In addition, with mask wearing we now frequently adjust and touch our masks. Viral particles spread from common surfaces to our hands or on the outside of our masks. According to the CDC hand washing or use of alcohol-based hand sanitizer when you can’t wash your hands must be done for 20 seconds to kill the COVID-19 virus. In addition, when washing your hands, it is important to clean all surfaces including palms, under nails, between fingers, back of your hands and even up to your wrists.  Remember to wash your hands before you prepare food and eat, after using the bathroom, and after touching any common surfaces.
  • Find Ways to Maintain Your Physical and Mental Wellbeing. Staying physically fit and mentally healthy is more challenging than ever before. Social isolation, lack of physical activity and the anxiety brought on by living through a pandemic, losing loved ones and friends, economic loss, and more have taken their toll. Seek help from family, friends, professionals, or search for support online. Find activities that can bring joy. Take care of your physical health by finding ways to eat healthy, exercise by taking physically distanced walks or runs outdoors, meditate, or move around your home. This fall and winter staying physically fit and maintaining mental health is even more important than ever before as studies show a direct correlation to a stronger immune system.
  • Stay outdoors. With the change of seasons, it will become more and more difficult to remain outdoors, but the best way to avoid the spread of COVID-19 is to stay in fresh outdoor air, spaced 6 feet apart from other people. Fresh air is constantly moving and circulating allowing the disbursement of respiratory droplets. When indoors, you share more air than when outdoors making it more likely to inhale droplets from an infected person. As the temperatures start to dip below freezing, the National Weather Service suggests wearing layers of lightweight clothes.  On days where it is below zero degrees, plan to stay indoors and socialize virtually. If it is imperative to be inside with others for school, work, or other essential needs, wear a mask.
  • Think differently this holiday season. We all need to get comfortable with the idea that holidays will be different this year.  There cannot be large indoor parties or gatherings this Halloween, Thanksgiving, and winter holiday season. The CDC has published a list of what is considered low, moderate and high risk this holiday season.Although nothing can replace the way we normally carry out traditions, think differently. Try to create outdoor, socially distanced events, drive-by celebrations, and virtual gatherings.  You will create new traditions and memories in the process.

Hagerty Health and Wellness Checklist 

Jeff Bokser is Hagerty Consulting’s Vice President of Healthcare Programs with strategic expertise in all aspects of healthcare operations, finance, crisis management, and recovery. Jeff has over 20 years of experience as a senior leader at NewYork-Presbyterian and Yale New Haven Health. He advanced performance and increased revenue in clinical and nonclinical settings and led innovation in daily operations and care delivery processes. Jeff is nationally recognized in the healthcare sector for his transformational leadership in the areas of emergency and crisis management; security and safety; pandemic and surge planning; and business continuity. Jeff was the system-level executive responsible for Emergency Medical Services, Emergency Management, Business Continuity, Crisis Management, Safety, Security, and Regulatory Compliance for the entire continuum of the NewYork-Presbyterian Hospital & Healthcare System enterprise. He served as Incident Commander guiding 40,000+ employees through numerous internal and external emergency response and recovery operations including Hurricane Sandy, Ebola, H1N1, and 9/11.

HUD Releases CDBG-CV Program Rules, Waivers, and Requirements

The United States (US) Department of Housing and Urban Development (HUD) issued a Federal Register Notice (Notice) on August 20, 2020, addressing a range of issues on the use of $5 billion of Community Development Block Grant (CDBG-CV) appropriated by the Coronavirus Aid, Relief, and Economic Security (CARES) Act to account for costs arising from the COVID-19 pandemic. Pursuant to the CARES Act, HUD allocated an initial $2 billion to all Fiscal Year (FY) 2020 CDBG grantees using standard statutory formulas with an additional $1 billion directed solely to states, insular areas and the District of Columbia (DC). The Notice indicates that HUD will announce the allocation of the remaining $2 billion at an unspecified future time. To view CDBG-CV allocations click on the following link: All CARES Act Grants-Excel.

This Notice adds to the body of CDBG-CV material HUD has issued since early April. Many grantees have already filed amendments to existing action plans and have begun drawing upon their CDBG-CV funds, while other grantees have taken an alternative path to incorporate the funds into their pending FY 2020 action plans.

For the more than 1,200 CDBG local government entitlement grantees, this planning process has been straight forward and facilitated by CARES Act directives and regulatory waivers designed to speed the process. On the other hand, states have awaited the recent Federal Register Notice to gain some clarity on the use of CARES Act funds directed to them and the Notice confirms signals that HUD had been telegraphing over the prior months. Collectively, these steps should enhance the ability of states to direct CDBG resources to areas in need of assistance to address COVID-19 needs.

  • Direct Action – The Notice permits states to carry out activities directly in all jurisdictions, including CDBG entitlement jurisdictions, as is generally the case for the use of CDBG disaster recovery funding. HUD’s rationale is that this step will help facilitate coordination of statewide and regional activities in response to COVID-19.
  • Minimum Funding for Non-entitlement Jurisdictions – HUD is requiring that states set aside a minimum amount of funding for small communities that are not CDBG entitlement jurisdictions. The state-by-state minimum for this purpose is the amount received as the “non-entitlement” amount in the column labeled “04-02-2020 CDBG-CV1” in the above linked Excel file.
  • Ability to Allocate to Entitlement Communities – Consistent with CARES Act language, states may also award CDBG-CV funds directly to Entitlement jurisdictions.
  • Authorization for States to Work in Tribal Areas – States may use their CDBG-CV funds to carry out activities in tribal areas but must obtain the consent of the Indian tribe with jurisdiction over the tribal area. Conversely, states may also provide Indian tribes with funds as subrecipients.
  • Increase in State Administrative and Technical Assistance (TA) Allowance – HUD has used its statutory waiver authority to increase the overall state administrative and TA cap from 3 to 7 percent (maximum split is 5 percent for admin and 2 percent for TA). Concurrently, HUD is waiving the statutory requirement for state matching amounts.

Other actions described by the Notice are also intended to facilitate the use of CDBG-CV funding for COVID-19 response. The Notice restates the CARES Act provision that removes the statutory limitation on public service expenditures for CDBG-CV as well as grantees’ FY 2019 and 2020 CDBG funds. HUD has used the Notice to extend the permissible term of emergency payments for rent, mortgages and utilities from three months to six months. HUD also made it slightly easier to qualify expenses as meeting CDBG national objective requirements through use of the urgent need criteria. Note that there is no change to the statutory requirement that at least 70 percent of a grantee’s funds CDBG-CV must benefit low- and moderate-income persons.

For economic development activities, HUD has provided relief by modifying public benefit criteria. Most notably, HUD is stating that when assistance is provided to businesses due to coronavirus-related disruption, public benefit is derived by stabilizing or sustaining businesses and assistance “may help to avoid complete economic collapse within the grantee’s jurisdiction.” Concurrently, HUD has temporarily increased both the per job CDBG investment cap to $85,000 and the goods and services investment cap to $1,700 per low- and moderate-income person benefitting.

When using CDBG-CV funds for economic development purposes, the Notice reminds grantees that they must “evaluate” such activities using HUD’s Guidelines and Objectives for Evaluating Project Costs and Financial Requirements.

An area of grantee concern that will warrant further HUD guidance relates to compliance with duplication of benefit (DoB) requirements. The CDBG-CV language in the CARES Act contains specific DoB language invoking both the Stafford Act and the Disaster Recovery Reform Act (DRRA). In brief, grantees must take care to avoid situations where a duplication of federal benefit may occur when providing assistance to an individual or entity. HUD skirts the issue by encouraging “each CDBG-CV grantee to become familiar with the range of available assistance and uses and apply its more flexible CDBG-CV assistance to unmet needs or to gaps with special attention to the coronavirus response, prevention, or preparation needs of Low-Middle Income (LMI) persons.” Many grantees have questions about exactly what the DoB standard will be in order to avoid potential audit findings and HUD will need to provide a more definitive response.

Stan Gimont is a Senior Advisor for Community Recovery with Hagerty. Stan joined Hagerty after 32 years of service with HUD. With Hagerty, Stan provides strategic advisory support focused on HUD Programs, housing issues, and long-term community recovery. From August 2016 through July 2019, Stan served as HUD’s Deputy Assistant Secretary for Grant Programs. In this role he provided management direction and oversight for all aspects of the CDBG Program, including long-term disaster recovery CDBG-DR, the HOME Investment Partnerships Program, the National Housing Trust Fund, as well as HUD’s environmental review responsibilities. From 2017 through 2019, his leadership helped to secure $40 billion in CDBG-DR funding in response to major disasters, such as hurricanes Harvey, Irma, and Maria. As Director of HUD’s Office of Block Grant Assistance from 2008-2016, Stan managed approximately $60 billion in federal funding to assist the nation’s communities in addressing housing, development, and disaster recovery needs. Among Stan’s notable achievements as Director is the implementation of the Neighborhood Stabilization Program in response to the 2008-2010 housing crisis, oversight of CDBG-DR funding for New Jersey and New York in response to Hurricane Sandy, and management of HUD’s National Disaster Resilience Competition in 2014-2015.

HUD Technical Assistance Can Help Improve Housing and Community Development Program Outcomes

In support of its many programs, the United States (U.S.) Department of Housing and Urban Development (HUD) offers an extensive array of technical assistance (TA) to grantees and recipients of HUD funding. In an environment where state and local governments are experiencing unique constraints making use of annual, disaster relief, and COVID-19 funding streams, quality TA can be a game changer. TA can help communities develop an effective plan to address a wide range of housing and community development needs.

The gateway to HUD’s TA is the HUD Exchange. On this site, users can retrieve program information, access programmatic resources, obtain training materials and request various forms of hands-on assistance from TA providers funded by HUD. If you are a recipient of HUD funds and are not familiar with the HUD Exchange, a quick review of the website will reveal its depth and pay a dividend the next time you have questions about HUD funding.

One aspect of the site deserves attention relative to HUD’s Community Development Block Grant – Disaster Recovery (CDBG-DR) funding. The specific CDBG-DR page on the HUD Exchange provides users with detailed program information under the headings of Getting Started and Resources and Training Materials. For state and local officials responsible for CDBG-DR funds, these materials successfully outline how to develop and implement a program that makes efficient use of these funds. As recovery needs often change over time, the website can offer insightful help throughout the long-term recovery process.

Since December 2015, Congress has appropriated more than $42 billion for the HUD CDBG-DR program and concurrently enabled HUD to reserve $20 million for disaster recovery TA efforts. A significant portion of the TA funding remains available and CDBG-DR grantees can request different forms of help to improve program performance. Under the heading of “Program Support”, grantees have access to an “Ask A Question” feature but, more importantly, can request hands on-help from HUD’s cohort of competitively selected TA providers. These providers can:

  • Deliver in-depth assistance with implementing, operating, or administering a CDBG-DR program;
  • Address issues that may require site visits and reoccurring communication with consultants; and
  • Provide long-term assistance to build organizational skills and capacity for operating a CDBG-DR program.

Often, CDBG-DR grantees are aware of the website but tend to be less familiar with the in-depth TA opportunities and, accordingly, do not take full advantage of the resources offered. Importantly, HUD provides this service at no cost to grantees so accessing it does not create a drain on administrative and planning allowances available under the CDBG-DR grant. It does not matter where a CDBG-DR grantee is in the recovery process – action plan development, launch, execution or winding down toward closeout – HUD can help grantees address issues both predictable and unique as they pursue their recovery goals. To learn more about this help, contact your HUD field office or visit the HUD Exchange website and look under the tab labeled “Program Support”.

On a related note, as part of efforts to address the COVID-19 pandemic, HUD received additional TA funding under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Grantees can seek the same forms of assistance related to the use of the CDBG and Emergency Solutions Grant (ESG) funding available under the CARES Act.  HUD has been displaying much of its COVID-19 response information via the HUD Exchange and will likely make more information about the range of available TA available soon.

 

Stan Gimont is a Senior Advisor for Community Recovery with Hagerty. Stan joined Hagerty after 32 years of service with HUD. With Hagerty, Stan provides strategic advisory support focused on HUD Programs, housing issues, and long-term community recovery. From August 2016 through July 2019, Stan served as HUD’s Deputy Assistant Secretary for Grant Programs. In this role he provided management direction and oversight for all aspects of the CDBG Program, including long-term disaster recovery CDBG-DR, the HOME Investment Partnerships Program, the National Housing Trust Fund, as well as HUD’s environmental review responsibilities. From 2017 through 2019, his leadership helped to secure $40 billion in CDBG-DR funding in response to major disasters, such as hurricanes Harvey, Irma, and Maria. As Director of HUD’s Office of Block Grant Assistance from 2008-2016, Stan managed approximately $60 billion in federal funding to assist the nation’s communities in addressing housing, development, and disaster recovery needs. Among Stan’s notable achievements as Director is the implementation of the Neighborhood Stabilization Program in response to the 2008-2010 housing crisis, oversight of CDBG-DR funding for New Jersey and New York in response to Hurricane Sandy, and management of HUD’s National Disaster Resilience Competition in 2014-2015.

The Building Blocks of BRIC: Investing in Our Infrastructure

America’s infrastructure is in dire need of repair. One out of every five miles of highway pavement is in poor condition; and, one in nine bridges in the United States (U.S.) is rated structurally deficient. Moreover, the average age of the nation’s 614,387 bridges is over 50 years old. The American Society of Civil Engineers (ASCE) estimates that by 2025, “aging and unreliable” infrastructure will cost American businesses $7 trillion in lost  revenue. In addition, large scale disasters further exacerbate America’s aging infrastructure, especially critical infrastructure.

Critical infrastructure is defined as the assets, systems, and networks essential to societal and economic functions. In 2017, after heavy rainfall, 180,000 California residents were evacuated due to spillway damage at the Oroville Dam. The following year in California, aging PG&E hardware broke loose during heavy winds and resulted in the 2018 Camp Fire. On the East Coast, New York City is still recovering from Hurricane Sandy in which more than 8 million customers lost power and more than half a million homes were destroyed, resulting in more than $65 billion in damages.

For decades, short-term or minimal repairs have served as band aids that keep our aging bridges, tunnels, subways, and electrical grids in operation – but this is not a cost-effective long-term solution.

Tyler Nix: Source

Investing in our infrastructure and lifelines

The Federal Emergency Management Agency’s (FEMA’s) Building Resilient Infrastructure and Communities (BRIC) program creates an annual funding opportunity to make critical investments in infrastructure systems and create system-wide improvements that will help communities withstand the impacts of more frequent and severe natural disasters.  BRIC replaces the Pre-Disaster Mitigation (PDM) program and refocuses mitigation efforts on strengthening core infrastructure sectors, such as water and wastewater, transportation, energy, communications, public health and several others. BRIC’s funding structure will enable high-impact investments with a focus on public infrastructure and critical services and facilities.

As outlined in FEMA’s Notice of Funding Opportunity (NOFO), eligible applicants states, territories and federally-recognized tribes may submit an unlimited number of mitigation project subapplications, each valued up to $50 million in federal share (75 percent of total project cost). This is a significant increase from the $10 million federal share cap under FEMA’s PDM Resilient Infrastructure program in 2019. Moreover, the BRIC NOFO creates a $600,000 state/territory and tribal set-aside for Capability- and Capacity-Building which includes project scoping activities. This set-aside alone is a crucial funding source for communities that have identified weaknesses in their infrastructure systems but require financial assistance with the technical studies, engineering, and alternatives analyses needed to support project development.

The technical criteria identified in the BRIC NOFO further solidifies the program’s prioritization of public infrastructure projects and focus on bolstering community lifelines –   systems that enable continuous operation of critical government and business functions within a community. A project that addresses infrastructure and mitigates risk to one or more community lifelines may earn up to 35 points of 100 points enumerated under the Technical Evaluation Criteria for the National Competition.

BRIC NOFO: Source

A time for action

Now is the time for communities to invest in their future. Events such as the collapse of the Interstate 35W Bridge in Minneapolis in August 2007 stand as stark reminders of the need to invest in aging public assets and the potential consequences of decades of neglect. These are the systems and lifelines that transport communities, provide potable water to families, support health networks, ensure local and global communication, and power homes, schools, and other critical services.

Eligible applicants should start planning how they will promote the BRIC program to potential subapplicants. This includes developing solicitations for project applications (i.e. a Notice of Interest or Intent), publishing fact sheets and training material, and hosting webinars to review programmatic requirements and priorities.  Interested subapplicants should review recent feasibility and planning studies to identify potential BRIC projects. Read more on identifying and screening projects on Hagerty blog on BRIC.

The BRIC program will provide communities with a funding source to proactively address deficiencies in their public infrastructure and community lifeline systems. Timely investments to rehabilitate infrastructure with an objective of creating a “resilient community” can result in an even higher return on investments. As John Roome, the World Bank’s Senior Director of Climate Change noted, investing in resilient infrastructure is not about spending more, but about spending better.

Hagerty is here to help. While the cost share for this program is 75 percent federal and 25 percent non-federal, FEMA will provide 100 percent federal funding for management costs associated with the administration of a BRIC-awarded mitigation measure or project. Therefore, our professionals can help at little-to-no additional cost.

Hagerty’s Mitigation Team are experts in navigating the pre- and post-disaster funding world. We are available to talk about your recovery needs, including how to access all funding available through federal grant programs. To learn more, contact us.

VANESSA CASTILLO is a mitigation and planning specialist with experience in the implementation of the FEMA mitigation programs. Before joining Hagerty, she was a planner with the City of Denver where she specialized in environmental compliance. Prior to Denver, she was a Mitigation Specialist with the state of Colorado where she contributed her expertise to the successful implementation of more than $65 million in Hazard Mitigation Grant Program (HMGP) for Colorado’s largest disaster.

HUD Allocates Second Tranche of ESG Funding Under CARES Act

FRIDAY, JUNE 12, 2020 AS OF 4:00 PM EDT

On June 9, 2020, the United States (US) Department of Housing and Urban Development (HUD) announced the allocation of almost $3 billion in additional Emergency Solutions Grant (ESG-CV) funding appropriated by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). These funds, plus $1 billion previously allocated, are available to assist states, local governments, and territories in addressing the needs of individuals and families who are homeless or receiving homeless assistance as a result for the COVID-19 Pandemic. A complete discussion of HUD’s allocation process and amounts can be accessed at: Methodology for Round 2 Allocations of ESG CARES Act Funds.

Many ESG-CV grantees may have been expecting to receive three times the amount they received under the initial $1 billion allocation but, in allocating the $3 billion, HUD implemented the CARES Act directive to abandon the standard ESG allocation formula. The revised formula incorporates a wide range of relevant data points; such as unsheltered homeless populations, sheltered homeless populations, populations at risk of homelessness, and geographical areas with the greatest need, based on factors such as the risk of transmission of COVID-19, high numbers or rates of sheltered and unsheltered homeless, and economic and housing market conditions. 

Breno Assis : Unsplash

Why did Congress push HUD in this direction? As HUD noted in its summary, the long-existing ESG formula “only targets modestly well to homeless and has no targeting to places with high rates of unsheltered homeless. That is because the ESG formula is allocated using the CDBG formula … which only has a modest relationship to where homelessness needs are most severe.” Homeless advocates and, to a degree, HUD have long wanted to refocus the ESG allocation process, and the CARES Act appropriately provided the necessary flexibility for this supplemental funding. Whether this approach translates to future ESG funding is to be determined. 

Eligible ESG uses always include street outreach, emergency shelter, homeless prevention, rapid re-housing, and administration and data costs. The ESG language in the CARES Act opens the door to additional activities such as training on infectious disease prevention and mitigation, hazard pay for staff, and temporary emergency shelters without minimum use periods. HUD’s June 9th press release highlights the ability of grantees to provide hotel/motel vouchers for homeless families and individuals, as well as essential services including childcare, education services, employment assistance, outpatient health services, legal services, mental health services, substance abuse treatment services, and transportation. 

HUD is providing extensive technical assistance to ESG-CV grantees which can be accessed through www.HUDExchange.info. This first stop for any grantee should be the bi-weekly Daily Resource Digest, which provides a range of information from subject matter experts on best practices and lessons learned.

Concurrently, HUD has weekly online “office hours” on COVID-19 response issues for homeless assistance providers every Friday from 2:30 – 4:00 PM EDT. The office hours feature various federal agencies and their partners for a live question-and-answer session, with previous session recordings also available online.

For those grantees that need more hands-on help, there is always direct technical assistance (TA). HUD is likely to expand its direct TA offerings as the CARES Act permitted HUD to use $40 million of the ESG-CV appropriation for the purpose. We are likely to hear more about this in the future as existing efforts are expanded.

ESG-CV grantees should also be aware of various flexibilities already made available by HUD. A few key resources are:  

Expect HUD to maintain an aggressive posture in working with grantees and homeless services providers to deploy ESG-CV funds to ease impacts on families and households and to develop a strategy that integrates these funds alongside emergency assistance available through the Federal Emergency Management Agency’s (FEMA’s) Public Assistance (PA) Program. 

Stan Gimont is a Senior Advisor for Community Recovery with Hagerty. Stan joined Hagerty after 32 years of service with HUD. With Hagerty, Stan provides strategic advisory support focused on HUD Programs, housing issues, and long-term community recovery. From August 2016 through July 2019, Stan served as HUD’s Deputy Assistant Secretary for Grant Programs. In this role he provided management direction and oversight for all aspects of the Community Development Block Grant (CDBG) Program, including long-term disaster recovery (CDBG-DR), the HOME Investment Partnerships Program, the National Housing Trust Fund, as well as HUD’s environmental review responsibilities. From 2017 through 2019, his leadership helped to secure $40 billion in CDBG-DR funding in response to major disasters, such as hurricanes Harvey, Irma, and Maria. As Director of HUD’s Office of Block Grant Assistance from 2008-2016, Stan managed approximately $60 billion in federal funding to assist the nation’s communities in addressing housing, development, and disaster recovery needs. Among Stan’s notable achievements as Director is the implementation of the Neighborhood Stabilization Program in response to the 2008-2010 housing crisis, oversight of CDBG-DR funding for New Jersey and New York in response to Hurricane Sandy, and management of HUD’s National Disaster Resilience Competition in 2014-2015.

Policy Analysis: Implementing BRIC in a COVID-19 World

As the response to COVID-19 continues to evolve, we are facing an unprecedented challenge nationwide. There are 56 active Presidential Disaster Declarations (all 50 states, five territories, and Washington DC) related specifically to the pandemic. Almost 1.2 million Americans are known to be infected and 68,000 have died (though the actual total numbers could be drastically higher). In some parts of the country, our healthcare system is on the brink of being overwhelmed, as hospitals report critical equipment shortages and face challenges balancing other medical care with COVID-19 treatment needs. Meanwhile, healthcare workers nationwide are suffering widespread layoffs, pay cuts, and furloughs as non-emergency and elective healthcare visits have been delayed or canceled. Without a viable vaccine or herd immunity, the country may be socially distancing to varying degrees for the better part of the next two years.

While heavily entrenched in organizing and implementing the nation’s response, the Federal Emergency Management Agency (FEMA) is being pressed by elected officials to allow for Hazard Mitigation Grant Program (HMGP) funding to be used for the COVID-19 Disaster Declarations. Using HMGP funding in this way would mark a paradigm shift – opening up funding beyond the program’s typical historic focus of floods, tornadoes, and earthquakes.

Though it may seem off-topic to consider long-term resilience in an immediate time of crisis, it is prudent to utilize a disaster event – no matter the hazard – as an opportunity to build back in ways that reduce future risk. Proactive investments to rehabilitate impacted communities while simultaneously mitigating risk increase the activities’ return on investment not only for natural hazards, but that which we face today. While the Hazard Mitigation Assistance (HMA) Program typically funds flood, tornado, wildfire, and earthquake project types, the current pandemic response underscores the mitigation funding opportunities for hardening or retrofitting of critical facilities, infrastructure, or other community assets vital to responding effectively to COVID-19 or similar infectious disease outbreaks.

In addition to these ongoing considerations related to HMGP and COVID-19, on April 10, 2020, FEMA released its draft policy for the new Building Resilient Infrastructure and Communities (BRIC) policy for public comment. The policy describes the new program which would supersede the existing Pre-Disaster Mitigation (PDM) Program as a major funding opportunity focused on investing in and strengthening the nation’s mitigation capabilities in order to protect communities and infrastructure. FEMA is accepting comments during a formal comment period ending on May 11, 2020.

The new grant program’s funding will be connected directly to expenditures made under Presidential Disaster Declarations. Given the scale of the COVID-19 pandemic and response, the annual funding for BRIC in 2021 could reach unprecedented levels. Communities seeking to leverage those funds can lean in by identifying and developing cost-effective and conceptually eligible projects to submit for funding through BRIC.

Annual Funding Amount

  • In addition to enacting various modifications to the program design and requirements, the Disaster Recovery Reform Act of 2018 (DRRA) authorizes FEMA to set aside up to six percent of total estimated disaster expenses associated with each Presidential Disaster Declaration to fund the BRIC Program. These funds will go into the National Public Infrastructure Pre-Disaster Mitigation Fund (NPIPDM), with the annual contributions fluctuating based on the number and cost of disasters in the prior year. Then, on an annual basis, FEMA will assess the total amount available in the fund and determine the total amount available through BRIC each year.
  • FEMA estimates that the annual contributions to the NPIPDM will be between $300-$500 million. This represents a significant increase in both projected amount available annually and the stability of annual award amounts. In contrast, PDM Program annual funding was determined by Congressional appropriations.

Notable Aspects of the Proposed Policy

  • There is no explicit mention of Advanced Assistance projects in the draft policy, which have been used in recent years to support the development of technically feasible, eligible, and cost-effective projects through PDM and HMGP. However, the draft policy does identify “Capability- and Capacity-Building Activities” as an eligible use of assistance. The functional design of this eligible use of assistance is ambiguous, but it may – in part – support a similar project pipeline for communities. Seed funding to develop future projects is critical to the success and longevity of BRIC.
  • The draft policy states that all projects planned to address structures in the Special Flood Hazard Area are contingent upon the jurisdiction participating in the National Flood Insurance Program (NFIP) and the property owner obtaining (if not already possessed) and maintaining flood insurance for the life of the structure. This requirement, which was notably not part of the PDM Program, would preclude mitigation projects from eligibility, regardless of the cost-benefit of the individual projects.
  • The draft policy includes (non-financial) technical assistance “to promote the program, identify potential projects, develop and review applications and mitigation plans, and provide training on grants management.” The specific nature of this technical assistance (availability, scope, request process, etc.) is not yet clear. Providing communities with clear guidance on strong resilient planning opportunities, such as developing, adopting, and implementing more modern or more resilient building code or enacting flood damage prevention ordinances, helps communities best integrate traditional planning with resilience-building.
  • Applicants may request Periods of Performance (POP) beyond 36 months at the time of application for “highly complex projects.” According to the draft policy, specific criteria for receiving approval for an extent POP will be detailed with other program implementation materials. This timeline represents increased flexibility and can help increase the viability of some larger or more interconnected projects.

How Hagerty Can Help

At Hagerty we have the expertise, passion, and commitment to assist you with FEMA hazard mitigation funding streams. Hagerty can assist communities to take advantage of the BRIC Program and help communities to further develop their projects into BRIC applications. Please reach out to Amelia Muccio to walk through the process and any mitigation projects that you might be considering. Please find more information about the BRIC funding in Hagerty’s overview below:

April Geruso is the Director of Resilience at Hagerty Consulting and a subject matter expert in preparedness, pre-disaster recovery planning, cost recovery, and community resilience. With nearly 15 years of experience in emergency management, April has led long-term recovery and resilience activities for disasters totaling $7.5 billion in damages, including recovery from the 2018 wildfires and hurricanes, and 2019 catastrophic flooding. She has also led pre-disaster recovery planning for multiple state and local governments, established protocols for cost recovery activities in New York City post-Hurricane Sandy, and consulted for federal planning efforts as a recovery expert. Prior to joining Hagerty, April served as the Deputy Director of Planning for the City of Philadelphia’s Office of Emergency Management, where she coordinated oversight and implementation of all City of Philadelphia emergency plans.

Michael Levkowitz is a Managing Consultant with Hagerty Consulting’s Preparedness Division with strategic expertise in mitigation planning and funding. Michael has served in a variety of roles supporting local, state, tribal, and federal agencies with hazard mitigation and long-term recovery planning, emergency preparedness, and risk communication. Following the 2019 disasters in Nebraska, Michael began supporting long-term recovery planning and the administration of HMGP funds in the state. Prior to joining Hagerty, Michael served as the Mitigation Strategist for Washington State Emergency Management Division, where he led the state’s effort to maintain and implement its Enhanced Hazard Mitigation Plan and support local jurisdictions and tribal communities in developing and adopting local and tribal hazard mitigation plans.

You can review our overview of BRIC Funding at:

You can review our Previous Blog Post at: