FEMA interim inspection policy has some key points that need to be mentioned.
- Homeowners are to be tasked with all damage assessments if they are able to access the home.
- If homeowner is able to live in the home, FEMA will classify the home as having minor damage.
- If the homeowner answered during the assessment question section of the online application that they were not able to live in their home for reasons other than utilities or access issues they would be scheduled a FEMA Verified Loss Inspection.
- FEMA policy statement: "To maintain safety and social distancing in a pandemic environment, this Interim Policy eliminates the need for inspectors to perform an onsite inspection to verify disaster-caused losses."
- FEMA policy statement: "FEMA must re-design the way the Federal government assesses disaster impacts to reduce the number of required inspections and deliver the needed assistance faster."
- FEMA policy statement: "This Interim Policy expedites IHP assistance to disaster survivors by implementing remote inspection processes."
Here are several examples that would allow FEMA to list your home damage as minor and not offer a in-home and on-site inspection:
- Roof was blown off the home during Hurricane Ida. The homeowner setup a tent inside the home. When asked if they were able to live in their home they responded, "Yes". FEMA could at this point list minor damage because the homeowner was able to live in the home.
- Home had flooding and part of the roof over their bedroom was gone. The homeowner sealed the damaged area off and now lives in the other rooms of the home. When asked if they were able to live in their home, they answered, "Yes". In this case, FEMA could list the home as minor damage and deny any in home verified loss inspection.
- A disabled homeowner with a standard landline phone was asked to walk around the home and video record their damage. The home had a tree cleared from the roof then 4 months later a blue tarp now covered the full length of the manufactured home. The homeowner was sent $2,000 for Home Repairs. The homeowner appealed and was awarded an additional $2,000 for home repairs.
FEMA is currently using the Individual Assistance Program and Policy Guide (IAPPG), FP 104-009-03, March of 2019 and 2021 as the main guide and applying the interim policy that is designed to reduce the number of required inspections by "...forgoing inspections for some applicants based on information provided during registration intake."
FEMA Interim Policy was implemented in conjunction with FEMA Policy 104-009-15, “Streamlined Inspection Process Individuals and Households Program Policy (Interim) which eliminated the automatic inspections for applicants who self-report they have minor damage and are able to live in their home.
The only time during the 2020, 2021 and 2022 storm season that FEMA would schedule an on-site in-home inspection was when the homeowner self-report complete destruction of the home.
The interim policy FEMA adopted has reduced the demand for federal grants because of inaccurate damage assessments that relied on the communication skills of the homeowners and their home inspector skills. Before the pandemic and the remote inspection period FEMA inspections were required for every home in the most impacted and distressed areas. Today, FEMA is allowed to use what can only be described as an incompetent and unskilled damage assessor also known as the Homeowner and request they determine their damage level. Once the remote inspection has been finished FEMA leaves no provisions for a in-home and on-site verified loss inspection. FEMA states in their policy that appeals if awarded will be a second remote inspection and the homeowner will be as before allowed to present verifiable documents.
This becomes more of an issue for the uninsured homeowners. When FEMA categorizes a home having Minor Damage that minor damage in their remote inspection could actually be $18,000 in repair costs. Because no physical inspection took place and FEMA did not ask a simple question to the homeowner, "Are you a qualified home inspection person?" The federal government wants to save money by not providing inspections and only assisting properties reported to having major or higher damage which would require an authorized FEMA damage assessment agent.
The state of Louisiana Office of Community Development Disaster Recovery Unit has made the following statement.
"... Hurricanes Laura, Delta, Ida and the May 2021 Severe Storms. ...the budget and program designs are based on how the funds are allocated to Louisiana to ensure these homeowners impacted with major/severe are prioritized first. The state may upon remaining budget funds expand that eligibility especially to vulnerable populations that may have experienced minor damage."
Homeowners level of damage is as follows:
- Minor-Low: Less than $3,000 of FEMA inspected real property damage.
- Minor-High: $3,000 to $7,999 of FEMA inspected real property damage.
- Major-Low: $8,000 to $14,999 of FEMA inspected real property damage and/or more than one foot of flooding on the first floor.
- Major-High: $15,000 to $28,800 of FEMA inspected real property damage and/or four to six feet of flooding on the first floor.
- Severe: Greater than $28,800 of FEMA inspected real property damage or determined destroyed and/or six or more feet of flooding on the first floor.
Typical scenarios for homeowners.
- Owns the home without liens or mortgage.
- Does not have flood or wind insurance on home.
- Many are low-income, moderate-income household.
- Refused to take transitional housing assistance or temporary housing assistance.
- Denied FEMA trailer.
FEMA Remote Inspection Verified Lost and Verifying Losses is critical for homeowners and renters.
FEMA Remote Inspection utilized call center remote inspectors to verify losses and to determine if a homeowner or renter aka the applicant is eligible for Individual Assistance (IA) or Individual and Household Program (IHP) assistance which could offer grants from $50 to $37,900.
FEMA Remote Inspection process; call center representatives would contact the homeowner by phone and coach the homeowner into documenting damage to the home. The inconsistencies are too numerous to list when a temporary call center representative has had minimal training and then expects the homeowners to be able to understand a process that typically requires formal damage assessment training and state licensing. It's also unrealistic for FEMA to expect every homeowner will be able to access the roof or even look to see if parts of the roof has been exposed to the elements. A homeowner on a phone even if the homeowner is using video with the FEMA representative it should not be expected to ask a homeowner to access the attic or crawl space to inspect if any truss, joist or beam has moved or been damaged. Ask yourself when the last time you inspected your roof, attic, walls, floor and foundation and were able to communicate to a structural engineers level that no damage was identified.
FEMA Remote Inspection home repair assistance was offered based only on the type of residence and the homeowners responses to questions during the application for disaster assistance and during the telephone call with a remote inspector who was tasked to rate the level of damage your home sustained.
FEMA Remote Inspection Elimination of all inspections for self-reported “Inaccessibility and Utility Outage. FEMA eliminated automatic inspections for all homeowners and renters who self-reported inaccessibility and/or utility outage as their sole home damage at the time they registered at Disaster Assistance [dot] Gov.
FEMA issued one month of “Rental Assistance" in lieu of an inspection when people were not sure of the damage and said they were going to live in the home.
If the homeowner disagreed with the rental assistance payment as a replacement for an inspection the homeowner could appeal the determination and if they were awarded the appeal or they won the appeal they would then be offered a remote inspection by a FEMA call center representative.
FEMA interim policy focused on sending more money to homeowners for home repairs and not actually verifying the loss with inspections in a pandemic environment.
FEMA policy allowed the following events that prevent homeowners from declaring actual damage that would be verified by FEMA and could lead to additional federal assistance if needed.
FEMA following normal appeals process required documentation to support the appeal request such as repair estimates, contractor estimates. FEMA then would base the appeal decisions and awards of federal grants on the verifiable appeal documentation rather than completing a second appeal report inspection or scheduling an on-site inspection.
FEMA does not have to report to you that documents you may have faxed to them were illegible or that your descriptions of the damage was not clear or that the contractor estimate was not detailed or formatted correctly.
FEMA needs to be able to verify the damage estimates and may email, text, USPS mail, or call the contractor listed on the estimate. It is unknown if FEMA will make additional attempts to verify estimates if no contact was made after the first attempt. You will only have one appeal attempt and if your letter is not in the proper format or your estimates can not be verified then FEMA will simply close your case without additional communications.
How useful will the remote inspections be will depend on the total number of uninsured homeowners repairing or rebuilding their homes to be safe and environmentally healthy.
Your goal as a homeowner is to reduce your disaster debt burden. If your FEMA inspection resulted in having $5,000 in grants but your actual repairs were $10,000 then you should appeal the remote inspection determination and include a formal invoice or estimate for the actual repairs.
- Search for FEMA Policy 104-009-17 and forward it to your GOHSEP and OHSEP at your local parish level. Ask them if they notified the public about this policy which would have been distributed to them first.
- FEMA POLICY: Pandemic Remote Inspection Process Individuals and Households Program Policy (Interim) FEMA Policy FP 104-009-17