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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

January 2013: 

Flood Insurance: 

Participation of Indian Tribes in Federal and Private Programs: 

GAO-13-226: 

GAO Highlights: 

Highlights of GAO-13-226, a report to congressional committees. 

Why GAO Did This Study: 

Indian tribes’ participation in NFIP is extremely low, even though 
some Indian lands are at high risk of flooding. In response to a 
Moving Ahead for Progress in the 21st Century Act mandate, GAO 
examined (1) factors affecting Indian tribes’ participation in NFIP, 
(2) FEMA’s efforts to increase tribes’ participation in NFIP, and (3) 
administrative and legislative actions that could increase tribes’ 
participation. GAO reviewed FEMA data on community participation in 
NFIP and prior GAO reports on flood insurance and Indian tribes, 
interviewed officials from selected Indian tribes and insurance 
companies, and collected information from relevant agencies and 
industry officials. 

What GAO Found: 

As of August 2012, just 37 of 566 federally recognized tribes (7 
percent) were participating in the National Flood Insurance Program 
(NFIP), and 3 tribes accounted for more than 70 percent of policies. A 
number of factors have affected tribes’ participation. First, the 
Federal Emergency Management Agency (FEMA) has not placed a high 
priority on mapping rural areas, including many Indian lands, for 
flood risk, and most tribal lands remain unmapped. Without flood 
hazard maps, tribal communities may be unaware of their flood risk, 
even in high-risk areas. Partly for this reason, the risk of flooding 
is perceived as relatively low on many tribal lands. Further, tribes 
may lack the resources and administrative capacity needed to 
administer NFIP requirements, and NFIP premiums are often too high for 
low-income tribal members. Finally, unique tribal issues can make 
participation difficult. For example, some Indian tribes do not have 
reservations over which they can enact and enforce the land use 
ordinances that are required for NFIP participation. Instead, many 
have lands that were allotted to individuals rather than to a tribal 
entity, limiting the tribes’ jurisdiction. 

FEMA has done some outreach to tribes, largely through emergency 
management and homeland security training for tribal officials, 
technical assistance to tribes that are preparing their multi-hazard 
mitigation plans, and marketing through the NFIP FloodSmart campaign. 
FEMA officials told us that the courses offered through its Emergency 
Management Institute helped to educate tribal officials about NFIP and 
floodplain management and that its curricula included courses for 
floodplain managers on their roles and responsibilities, flood 
insurance, and NFIP rules and regulations. One tribal representative 
told us that he was participating in an ongoing curriculum and several 
tribes had developed multi-hazard mitigation plans. Finally, both the 
Department of Housing and Urban Development and the U.S. Department of 
Agriculture, Rural Development may provide NFIP information to Indian 
tribes as they provide assistance in the form of housing and 
infrastructure grants, loans, and loan guarantees. 

Tribal representatives suggested steps that FEMA could take to 
encourage participation in NFIP—for example, placing a higher priority 
on mapping Indian lands and increasing FloodSmart marketing to tribal 
leaders rather than individuals. Given ongoing congressional interest 
in private sector alternatives to NFIP, GAO also explored whether 
private alternatives exist that could offer affordable coverage to low-
income tribal members—-for example, by expanding access to risk-
pooling programs that could help insure more tribal households. One 
such program already insures thousands of Indian properties. Another 
relatively new product, microinsurance, would involve insurers 
offering less expensive policies with relatively low coverage limits 
but coverage for all tribes. FEMA said that its NFIP privatization 
study mandated by the Biggert-Waters Flood Insurance Reform Act of 
2012 would include an assessment of these alternatives. 

What GAO Recommends: 

GAO recommends that the FEMA Administrator examine ways to make 
mapping of tribal lands in flood-prone areas a higher priority. FEMA 
agreed with our recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-13-226]. For more 
information, contact Alicia Puente Cackley, (202) 512-8678 and 
cackleya@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

A Number of Factors Contribute to Indian Tribes' Low NFIP 
Participation Rate: 

FEMA Has Provided Indian Tribes with Training and Technical Assistance 
on Hazard Mitigation, Including Flood Insurance: 

Boosting Tribes' Participation in Flood Insurance Programs: 

Conclusions: 

Recommendation: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the Federal Emergency Management Agency: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Participation in NFIP among Federally Recognized Indian 
Tribes (August 2012): 

Table 2: NFIP Access for Tribes in Alaska (2012): 

Table 3: Tribal Flood Insurance Policies in Place with AMERIND 
(November 2012): 

Figures: 

Figure 1: Number of Major Flood Disaster Declarations by County and 
U.S. Indian Reservation (1980-2005): 

Figure 2: Alaska Native Fishing Village That Has Experienced Flooding 
(August 2009): 

Abbreviations: 

BIA: Bureau of Indian Affairs: 

CRS: Congressional Research Service: 

EMI: Emergency Management Institute: 

FEMA: Federal Emergency Management Agency: 

FIRM: Flood Insurance Rate Map: 

HUD: Department of Housing and Urban Development: 

ICDBG: Indian Community Development Block Grant: 

IHBG: Indian Housing Block Grant: 

NAHASDA: Native American Housing Assistance and Self-Determination Act 
of 1996: 

NFIP: National Flood Insurance Program: 

SFHA: Special Flood Hazard Area: 

USDA: U.S. Department of Agriculture: 

[End of section] 

January 4, 2013: 

The Honorable Tim Johnson:
Chairman:
The Honorable Richard C. Shelby:
Ranking Member:
Committee on Banking, Housing, and Urban Affairs:
United States Senate: 

The Honorable Jeb Hensarling:
Chairman:
The Honorable Maxine Waters:
Ranking Member:
Committee on Financial Services:
House of Representatives: 

Flooding is the most common and destructive natural hazard facing the 
nation, resulting in billions of dollars in losses each year. Between 
1980 and 2005, about 97 percent of the U.S. population lived in 
counties that had experienced at least one declared flood disaster, 
and 45 percent lived in counties that had experienced six or more. 
[Footnote 1] Further, federal estimates show that more than half of 
the U.S. population now lives in coastal watershed counties or 
floodplain areas.[Footnote 2] 

Congress created the National Flood Insurance Program (NFIP) in 1968 
to mitigate future flood losses nationwide through community 
floodplain management ordinances and to provide access to affordable, 
federally backed flood insurance protection for property owners. 

Indian lands have experienced their share of flooding. Some have 
flooded repeatedly, yet few tribes participate in NFIP. In a July 2011 
hearing on emergency preparedness for natural disasters in Native 
American communities, the Senate Committee on Indian Affairs 
questioned why tribal participation in NFIP was low and whether 
efforts to encourage greater participation had been successful. 
[Footnote 3] Congress included a mandate in section 100237 of the 
Moving Ahead for Progress in the 21st Century Act that required us to 
examine the factors contributing to the current rates of NFIP 
participation by Indian tribes and members of Indian tribes and 
methods of encouraging such participation.[Footnote 4] In addition, 
the mandate required us to describe steps that the Federal Emergency 
Management Agency (FEMA) within the Department of Homeland Security 
should take to increase awareness and encourage participation in NFIP 
by Indian tribes and members of Indian tribes and to identify any 
legislative changes that would encourage such participation. In 
response to the mandate, this report examines (1) factors contributing 
to the current low levels of NFIP participation by Indian tribes, (2) 
FEMA's efforts to increase tribes' participation in NFIP, and (3) 
administrative and legislative actions that could encourage Indian 
tribes and their members to increase their participation in NFIP and 
potentially other flood insurance programs. 

For the purposes of this review, we limited our study primarily to 
flood insurance policies held on Indian tribal lands (such as 
reservations), because FEMA does not collect demographic data such as 
race or ethnic origin of NFIP policyholders. Therefore, no 
comprehensive data are available on members of Indian tribes who are 
living in nontribal communities and may carry individual NFIP 
policies. We also interviewed representatives from Alaska, because 
many Alaska Native communities are vulnerable to floods but the tribes 
lack jurisdiction to adopt and enforce land use ordinances, a 
requirement for community participation in NFIP. 

In conducting this work, we reviewed NFIP laws and policy documents. 
We reviewed FEMA data on communities participating in NFIP, including 
those designated as tribal communities, and on tribes that had flood 
hazard maps but were not participating in NFIP for various reasons. 
FEMA provided us with information on its process for collecting and 
analyzing the data in its Community Information System database and on 
the agency's data reliability measures.[Footnote 5] We determined that 
the data FEMA provided to us were sufficiently reliable for our 
reporting purposes. In addition, we reviewed our prior work on flood 
insurance, Indian tribes, and disaster preparedness. We also 
interviewed and gathered documentation from officials at FEMA and 
other federal agencies with programs that assist Indian tribes, such 
as the Bureau of Indian Affairs (BIA) within the Department of the 
Interior, Department of Housing and Urban Development (HUD), and the 
U.S. Department of Agriculture (USDA) Rural Development. In addition, 
we reviewed regulations for those agencies' programs. We spoke with 
representatives from the State of Alaska; the National Flood 
Determination Association, which provides flood mapping data to 
mortgage lenders and insurers; the insurance and reinsurance 
industries; a nonprofit risk-pooling organization; FloodSmart, which 
administered FEMA's NFIP media campaign; and selected Indian tribes. 

We selected the tribes from among those on FEMA's lists of tribes that 
were participating in NFIP as well as those that had flood hazard maps 
but were not participating in NFIP. We selected a purposive non-
representative sample of eight participating tribes for interviews 
based on the number of individual policies within each tribe, 
geographic diversity, and tribe size. We also selected a purposive non-
representative sample of six nonparticipating tribes for interviews 
based on the reason for nonparticipation, geographic diversity, and 
tribe size. In addition, our prior work related to the Native American 
Housing Assistance and Self-Determination Act of 1996 (NAHASDA) 
program partially informed the tribes we selected.[Footnote 6] 
Specifically, because we had already established communication with 
certain tribes, we selected them over comparable tribes on either 
list. Because of our time constraints and several selected tribes 
being impacted by a natural disaster (Superstorm Sandy), we were able 
to interview five participating and five nonparticipating tribes. We 
also judgmentally selected a tribe in Alaska that we had contacted 
previously to obtain a perspective on NFIP from a tribe in that state. 
To obtain perspectives from the insurance industry, we interviewed 
representatives from an insurance company that we contacted while 
conducting prior work related to the Write-Your-Own insurance program, 
a vendor that administers NFIP policies for Write-Your-Own insurance 
companies, and an insurance broker that specializes in working with 
Indian tribes.[Footnote 7] Appendix I contains a detailed description 
of our scope and methodology. 

We conducted this performance audit from August 2012 to January 2013 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

Floods can result in the loss of lives, extensive damage to property 
and agriculture, and large-scale disruptions to business and 
infrastructure, such as transportation and water and sewer services. 
[Footnote 8] The National Oceanic and Atmospheric Administration 
estimates that floods cause about 140 deaths in the United States each 
year, and the Army Corps of Engineers estimates that floods cause $6 
billion in average annual losses. Congress established NFIP in the 
National Flood Insurance Act of 1968 to provide policyholders with 
some insurance coverage for flood damage as an alternative to disaster 
assistance, and to try to reduce the escalating costs of repairing 
flood damage.[Footnote 9] The program was subsequently modified by 
various amendments, including the Flood Disaster Protection Act of 
1973 (1973 Act) and the National Flood Insurance Reform Act of 1994. 
[Footnote 10] And most recently, NFIP was amended by the Biggert-
Waters Flood Insurance Reform Act of 2012.[Footnote 11] 

The 1973 Act added certain requirements that, according to FEMA 
officials, were intended to encourage community participation in NFIP. 
Specifically, as a condition of future federal financial assistance, 
communities are required to participate in NFIP and to adopt adequate 
floodplain ordinances with effective enforcement provisions consistent 
with federal standards in order to reduce or avoid future flood 
losses. Figure 1, which shows the location of U.S. Indian reservations 
and major flood disaster declarations over a 25-year period, indicates 
that many Indian tribes reside in areas that have experienced multiple 
floods. 

Figure 1: Number of Major Flood Disaster Declarations by County and 
U.S. Indian Reservation (1980-2005): 

[Refer to PDF for image: illustrated U.S. map] 

Map depicts the following: 

Indian reservations; 
Flood disaster declarations, 1980-2005: 
None; 
1; 
2-5; 
6-10; 
More than 10. 

Source: GAO; MapInfo. 

[End of figure] 

The 1973 Act denied direct federal financial assistance and financing 
by private lending institutions regulated by federal regulators for 
acquisition or construction purposes in participating communities 
where flood insurance was available unless the property was covered by 
flood insurance. Prior to the 1973 Act, the purchase of flood 
insurance had been voluntary. However, this mandatory purchase 
requirement, further amended by the National Flood Insurance Reform 
Act of 1994, effectively requires owners of property to obtain flood 
insurance if they are located in a Special Flood Hazard Area (SFHA) 
within a community participating in NFIP and obtain a mortgage from a 
federally regulated lending institution or a federal agency lender or 
receive direct federal financial assistance for acquisition or 
construction purposes. 

The mandatory purchase requirement applies to secured mortgage loans 
from financial institutions such as banks, savings and loan 
associations, savings banks, and credit unions that are supervised by 
federal agencies, including the Federal Deposit Insurance Corporation 
and the Office of the Comptroller of the Currency. It also applies to 
all mortgage loans secured by real estate on which a building is 
constructed in an SFHA for which flood insurance is available if 
purchased by Fannie Mae and Freddie Mac in the secondary mortgage 
market. Loans and grants through financial assistance programs from 
agencies such as the Federal Housing Administration and the Department 
of Veterans Affairs are also affected.[Footnote 12] The requirement 
also extends to several federal programs that assist Indian tribes. 
For example, recipients of funds from BIA's Housing Improvement 
Program, HUD's Indian Housing Block Grant (IHBG) and Indian Community 
Development Block Grant (ICDBG), and several USDA Rural Development 
loan programs are required to purchase flood insurance if an assisted 
structure is in an SFHA.[Footnote 13] Finally, individuals in SFHAs 
who receive federal disaster assistance after September 23, 1994, for 
flood disaster losses to real or personal property are required, as a 
condition for receiving future disaster assistance, to purchase and 
maintain flood insurance coverage on the property. According to FEMA, 
in December 2012 the average NFIP policy cost about $600 per year, 
with policies in SFHAs typically costing more and some policies 
outside SFHAs costing less. 

FEMA identifies and maps flood-prone areas throughout the United 
States and its territories that are eligible to participate in NFIP. 
According to a Congressional Research Service (CRS) report on NFIP, 
FEMA also makes flood hazard information available on its website for 
viewing or purchasing.[Footnote 14] The report notes that FEMA works 
with communities to develop new flood hazard data as part of a flood 
insurance study, issues public notification about maps, and engages in 
education and outreach to help ensure that community leaders and 
residents understand the mapping process and the appropriate use of 
flood maps. The CRS report further notes that reliable flood risk 
data, including updated flood maps, and educating residents about 
flood risk, contribute to mitigating future flood losses. Most areas 
of flood hazard are commonly identified on Flood Insurance Rate Maps 
(FIRM), and areas not yet identified by a FIRM may be mapped on Flood 
Hazard Boundary Maps.[Footnote 15] Several areas of flood hazard are 
identified on these maps, one of which is the SFHA. The SFHA is a high-
risk area defined as any land that would be inundated by a flood 
having a 1 percent chance of occurring in a given year (base flood); 
this is the equivalent of a 26 percent chance of flooding over a 30-
year mortgage. According to FEMA, the SFHA constitutes a reasonable 
compromise between the need for building restrictions to minimize 
potential loss of life and property and the economic benefits to be 
derived from floodplain development. Development may take place within 
an SFHA as long as it complies with local floodplain management 
ordinances, which must meet minimum federal requirements. Flood 
insurance is required for insurable structures within high-risk areas 
to protect federal financial investments and assistance used for 
acquisition or construction purposes within communities participating 
in NFIP. 

In July 2012, Congress passed the Biggert-Waters Flood Insurance 
Reform Act of 2012.[Footnote 16] The act extends NFIP for 5 years and 
makes reforms to the program that include (1) phasing out subsidies 
for many properties, (2) raising the cap on annual premium increases 
for other policies from 10 to 20 percent, (3) clarifying that certain 
multifamily properties are eligible for NFIP policies, (4) imposing 
minimum deductibles for flood claims, (5) requiring NFIP to establish 
a reserve fund, and (6) establishing a technical mapping advisory 
council to deal with map modernization issues. The act also calls for 
an assessment by FEMA and GAO, separately, of options and strategies 
for privatizing NFIP in the future and authorizes FEMA to pursue 
private risk-management initiatives to determine the capacity of 
private insurers and markets to assist communities in managing the 
full range of financial risks associated with flooding. 

NFIP Status: 

Because of its subsidized premium rates and catastrophic hurricane-
related floods in recent years, NFIP has accrued a substantial debt 
that stood at nearly $18 billion as of October 2012.[Footnote 17] We 
previously reported that NFIP was designed to pay operating expenses 
and flood insurance claims with premiums collected on flood insurance 
policies rather than with tax dollars, and that FEMA had statutory 
authority to borrow funds from Treasury to keep NFIP solvent in years 
when losses were high.[Footnote 18] We noted that by design NFIP was 
not actuarially sound, because Congress authorized subsidized 
insurance rates for policies covering certain structures to encourage 
communities to join the program. Since 2000, NFIP has experienced 
several catastrophic loss years (years with $1 billion or more in 
losses). These years include 2001, 2004, 2005, and 2008.[Footnote 19] 
By the end of 2012, NFIP is expected to have experienced another 
catastrophic loss year because of the enormous damage from the October 
storm known as Superstorm Sandy. 

Community Participation: 

Under FEMA's NFIP regulations, a community is defined as any state or 
area or political subdivision thereof or any Indian tribe or 
authorized tribal organization, or Alaska Native Village or authorized 
native organization, that has the authority to adopt and enforce 
floodplain management ordinances for the area under its 
jurisdiction.[Footnote 20] Indian tribes, authorized tribal 
organizations, Alaska Native villages, and authorized native 
organizations that have land use authority are considered communities 
by NFIP and can join the program even if no flood hazard map exists 
that covers all tribal lands. 

NFIP has three components: (1) the provision of flood insurance, (2) a 
requirement that participating communities adopt and enforce 
floodplain management regulations, and (3) the identification and 
mapping of floodplains. Community participation in NFIP is voluntary, 
although some states require participation as part of their floodplain 
management program. Each identified flood-prone community must assess 
its risk of flood hazards and determine whether flood insurance and 
floodplain management would benefit the community. However, a 
community that chooses not to participate in NFIP within 1 year of 
identifying the flood hazard and receiving a flood hazard map may face 
consequences as a result of its nonparticipation, because no flood 
insurance can be sold in the community and it may be ineligible for 
certain types of federal assistance because of the acquisition and 
construction prohibition of 42 U.S.C. § 4106 such as Stafford Act 
disaster benefits for home repairs.[Footnote 21] A community must join 
NFIP and adopt FEMA-approved floodplain management requirements in 
order for residents to purchase federal flood insurance. Once a 
community begins participating in NFIP, property owners can purchase 
individual NFIP policies. Current law prohibits lenders from making 
loans for real estate in areas at high risk for flooding, where the 
community is participating in NFIP, unless the property is covered by 
flood insurance.[Footnote 22] Participating communities can receive 
discounts on flood insurance if they establish floodplain management 
programs that go beyond the minimum requirements of NFIP. FEMA can 
suspend communities that do not comply with the program and 
communities can withdraw from the program (both with sanctions). 
Currently, more than 21,000 communities participate in NFIP. 

Communities participating in NFIP do so as part of either the regular 
or emergency program. A community participating in the regular NFIP 
program is usually provided with a FIRM and a flood insurance study. 
As part of their agreement to participate in NFIP, communities adopt 
and enforce floodplain management ordinances and FIRMs. If communities 
do not adopt and enforce these ordinances, they can be placed on 
probation or suspended from the program. However, such actions take 
place only after FEMA has taken steps to help the community become 
compliant. The NFIP emergency program is the initial phase of a 
community's participation in NFIP and was designed to provide a 
limited amount of flood insurance. A community participating in the 
emergency program either does not have an identified and mapped flood 
hazard or has been provided with a Flood Hazard Boundary Map, and the 
community is required to adopt limited floodplain management standards 
to control future use of its floodplain. According to FEMA, fewer than 
3 percent of the more than 21,000 communities participating in NFIP 
are in the emergency program. 

Indian Tribes: 

The federal government has consistently recognized Indian tribes as 
distinct, independent political communities with the inherent powers 
of a limited sovereignty that has never been extinguished. As of 
August 2012, there were 566 federally recognized tribes--341 in the 
contiguous 48 states and 225 in Alaska.[Footnote 23] To help manage 
tribal affairs, tribes have formed governments and subsidiaries of 
tribal governments, including schools, housing, health, and other 
types of corporations. The United States has a trust responsibility to 
recognized Indian tribes and maintains a government-to-government 
relationship with them. 

Tribal lands vary dramatically in size, demographics, and location. 
They range from the Navajo Nation, which consists of about 27,000 
square miles across portions of Arizona, New Mexico, and Utah, to some 
tribal land areas in California of less than 1 square mile. Over 
176,000 American Indians live on the Navajo reservation, while some 
other tribal lands have fewer than 50 Indian residents. Some Indian 
reservations have a mixture of Indian and non-Indian residents. Most 
tribal lands are rural or remote, although some are near metropolitan 
areas.[Footnote 24] 

[Begin side bar] 
Types of Indian Lands: 
Federal Indian reservation: An area of land reserved for a tribe or 
tribes under treaty or other agreement with the United States, 
executive order, or federal statute or administrative action as 
permanent tribal homelands. 

Allotted lands: Starting with the General Allotment Act in 1887 (also 
known as the Dawes Act) until the Indian Reorganization Act of 1934, 
allotments were conveyed to individual tribe members and held in trust 
by the federal government. As allotments were taken out of trust, they 
became subject to state and local taxation, which resulted in 
thousands of acres passing out of Indian hands. 

Restricted status or restricted fee land: Land title is held by an 
individual Indian person or a tribe and can only be alienated or
encumbered by the owner with the approval of the Secretary of the 
Interior because of limitations contained in the conveyance instrument 
pursuant to federal law. 

State Indian reservations: Lands held in trust by a state for an 
Indian tribe. These lands are not subject to state property tax, 
though they are subject to state law. 
[End of side bar] 

Over half of Indian tribes, however, do not have reservations or other 
lands over which they could enact and enforce land use ordinances--
which is required for participation in NFIP--and even tribes with 
reservations often do not have authority to enact such ordinances for 
all land within the reservation's boundaries.[Footnote 25] For 
example, the Alaska Native Claims Settlement Act revoked all existing 
Indian reservations in Alaska except one and, as a result of this law 
and a Supreme Court case, tribes in Alaska generally do not have 
authority to enact land use ordinances.[Footnote 26] Also, a number of 
Indian reservations, primarily in Oklahoma, were disestablished 
through the allotment of reservation land to individual tribal 
members.[Footnote 27] Upon an Indian allottee's death, these 
allotments passed to heirs and ownership of some allotted land has 
continually been divided with each generation of heirs, resulting in 
large numbers of heirs holding interest in the land as tenants in 
common. In some cases, such "fractionated lands" have up to several 
hundred ownership interests. Fractionation complicates basic 
homeownership issues such as whether to take out a flood insurance 
policy, because such decisions may require agreement among entities 
with shared ownership. Some of these allotments, as well as parcels of 
land within reservation boundaries, have been inherited or purchased 
by non-Indians and Indian tribes generally lack jurisdiction over land 
owned by non-Indians. 

In some cases, although a tribe is not an NFIP participant, the tribe 
may be located in another community that participates in NFIP. 

Proposed Amendment to the Stafford Disaster Relief and Emergency 
Assistance Act: 

A proposed amendment to the Robert T. Stafford Disaster Relief and 
Emergency Assistance Act would allow Indian tribes to request a major 
disaster declaration by the President.[Footnote 28] The proposed 
amendment would provide Indian tribes with this authority so that they 
would not be required to rely on assistance through a presidential 
declaration requested by the state or locality.[Footnote 29] Federal 
officials with whom we spoke generally viewed this amendment as a 
positive action in the interest of tribes. For example, USDA Rural 
Development officials said that this authority would make it easier 
for tribes to access disaster relief resources. Representatives of 
several tribes we interviewed said that such a change would open up 
direct communication between the federal government and Indian tribes. 
However, questions remained about how the proposed amendment would be 
implemented. It is not yet clear how the proposed Stafford Act 
amendment would affect Indian tribes' willingness to participate in 
NFIP. 

A Number of Factors Contribute to Indian Tribes' Low NFIP 
Participation Rate: 

According to FEMA, as of August 2012, 37 out of 566 federally 
recognized tribes nationwide--roughly 7 percent--were participating in 
NFIP (see table 1). The number of policies for each tribe ranged from 
1 to 175, and 14 participating tribes had no individual policies. 
Across all participating Indian tribes, 414 policies were in place, 
accounting for less than 1 hundredth of a percent of all NFIP 
policies.[Footnote 30] 

Table 1: Participation in NFIP among Federally Recognized Indian 
Tribes (August 2012): 

Measure: Number of federally recognized Indian tribes; 
Number: 566. 

Measure: Number of tribes participating in NFIP; 
Number: 37. 

Measure: Number of participating tribes with insurance policies in 
place; 
Number: 23. 

Measure: Concentration of insurance policies in place; 
Number: 5 tribes (82 percent of policies); 3 tribes (70 percent of 
policies). 

Source: FEMA. 

[End of table] 

FEMA's data also show that, among communities that have received flood 
hazard maps but are not participating in NFIP, there are 46 tribal 
communities. 

Federal agency officials, tribes, and others described several factors 
that affect whether tribes purchase flood insurance through NFIP or 
other programs. 

FEMA does limited mapping in tribal communities. Flood maps show 
communities and homeowners the level of flood risk they face. 
According to FEMA, as of October 2012, 78 tribal communities had 
received flood hazard maps.[Footnote 31] Representatives of the 
National Flood Determination Association, which provides FEMA flood 
mapping data to mortgage lenders and insurers, told us that some 
tribes that were not participating in NFIP had not been mapped and 
that because they did not know their flood risk, they likely did not 
see the advantages to NFIP participation. In discussing the agency's 
mapping efforts, FEMA officials explained that tribal communities 
generally included small rural areas that were not a high priority for 
the agency. The officials said that FEMA had focused its mapping 
efforts on heavily populated urban and coastal areas with a high risk 
of flooding. The officials also noted that because of the tribes' 
sovereignty, the agency needed permission to enter tribal lands and 
conduct mapping activities and that such permission could be difficult 
to obtain. Additionally, they were concerned that tribes might not 
grant permission for FEMA to publish a map if tribal borders were in 
dispute. They explained that if FEMA could not overcome these 
challenges, it might exclude the tribal area from the watershed 
map.[Footnote 32] However, they did not provide us with any specific 
examples of maps with such exclusions. 

Representatives of a Washington tribe that received its flood hazard 
maps from FEMA in 2004 told us the tribe had participated in NFIP 
since 1997, 7 years prior to receiving the maps. The tribe initially 
participated in NFIP's emergency program and then became a regular 
participant once its maps were finalized. They explained that the 
tribe had largely been motivated by a need to clarify its 
jurisdictional (land and water) area, which flood mapping allowed them 
to do. Further, they said that joining NFIP had provided an 
opportunity to obtain flood insurance as a tribal community instead of 
participating as part of the surrounding county, supporting the 
tribe's interest in self-determination.[Footnote 33] However, this 
tribe is vulnerable to flooding from several sources, and the 
representatives noted that it had long been proactive in disaster 
mitigation efforts as a whole. Emergency officials from another tribe 
told us that approximately 10 percent of their reservation was mapped 
and that the mapping had been done by the Army Corps of Engineers. 
They said their understanding was that until recently, FEMA did not 
conduct flood mapping on federal reservations. 

Most nonparticipating tribes that have been mapped face relatively low 
flood risk. According to FEMA, most of the nonparticipating tribal 
communities have very low flood risk. Thirty-five of the 46 tribal 
communities that FEMA told us had been mapped but were not 
participating in NFIP had been determined to have low flood risk. 
Another 9 were in the 1-year "opportunity period" for addressing any 
identified flood hazards and joining NFIP, and 2 had been determined 
to have some flood risk but were not participating. 

One representative of a participating Washington tribe suggested that 
tribes that are most at risk for flooding should be given priority in 
efforts to encourage tribal participation in NFIP. The tribal 
representative said that expecting those not highly vulnerable to 
flooding to purchase costly flood insurance when they have other 
priorities would be difficult. When we spoke with an emergency 
management official from a nonparticipating Wisconsin tribe, he agreed 
that because the tribe had not experienced a major flood, there was a 
general lack of urgency on the part of tribal leadership about NFIP 
participation. 

Many tribes lack the resources or administrative capacity to join 
NFIP. FEMA officials told us that affordability affected tribes' 
participation in NFIP as it did other low-income communities and 
individuals. The officials also told us that they had seen slow to no 
insurance policy growth in areas of the country where the economy was 
not performing well. A representative of the National Flood 
Determination Association agreed that the cost of coverage could limit 
tribes' participation, noting that there is a general lack of funding 
for mapping. Further, he said that many rural communities, including 
tribal communities, were not in favor of adopting land use regulations 
and did not have the resources to adopt and implement them. 

Representatives of the participating Washington tribe with the highest 
number of individual policies as of August 2012 acknowledged that NFIP 
participation was administratively burdensome and costly. In 
particular, they explained that developing flood damage reduction 
ordinances and then implementing the ordinances required dedicated 
staff that not all tribes have. In general, they acknowledged that 
many tribes lacked the resources that this tribe had to pursue NFIP 
participation. Similarly, a Wisconsin tribal official said that 
pursuing NFIP participation could be especially challenging for tribes 
that lacked emergency, planning, or zoning functions and tribes that 
may not even have developed building codes on their lands. He 
emphasized that such limitations should be taken into account in 
examining why tribes may not be participating in NFIP. 

Many tribes view affordability as a significant issue for their 
members in purchasing NFIP policies. Many tribal representatives said 
that affordability would be an issue for tribal members. For instance, 
representatives of an Oklahoma tribe told us that while affordability 
would not affect the tribe's decision to participate in the program, 
because the tribe would use NFIP to insure its government and 
commercial buildings, it would be a factor for individual tribal 
members. Specifically, they explained that paying flood insurance 
premiums would be challenging for individuals who already lacked the 
resources to afford homeowner, renter, and automobile insurance. 
Representatives of other tribes agreed that NFIP premiums would be 
costly for the members of their tribes. Emergency management 
representatives of a large western tribe told us they were not aware 
of any tribal members who had flood insurance on their homes and that 
even homeowner insurance coverage was rare. They explained that the 
average annual household income on the reservation was between $12,000 
and $15,000 and that unemployment was at least 28 percent. A tribal 
housing official from Alaska whose members can participate in NFIP 
through the surrounding borough told us that he had found that most 
members of his tribe dropped their homeowners insurance as soon as 
their homes were paid off and that he expected they would do the same 
with required flood insurance, which can cost more than $1,000 a year. 
[Footnote 34] An official for another Oklahoma tribe that was 
participating in NFIP but had no active individual policies said he 
did not believe flood insurance was a priority for members of his 
tribe, whose average annual household income was $6,000. Figure 2 
shows a Native Alaska fishing village that has experienced flooding 
but whose residents, according to the tribe's housing director, have 
not purchased NFIP flood insurance due to the high cost. 

Figure 2: Alaska Native Fishing Village That Has Experienced Flooding 
(August 2009): 

[Refer to PDF for image: photograph] 

Source: GAO. 

[End of figure] 

Unique Indian issues also impact tribal participation in NFIP. As 
previously noted, all but one of the tribes in Alaska lack a 
reservation. Because the tribes lack jurisdiction to enact and enforce 
land use ordinances over the land where they reside, they cannot 
directly participate as communities in NFIP. In many cases, the tribes 
are co-located with other government entities that may participate in 
NFIP, such as cities and boroughs, and their members may access NFIP 
through those other entities. Alaska state officials told us that an 
estimated 66 percent of the Alaska Native population could participate 
in NFIP because they lived in a city or borough that participated in 
the program. Based on data we compiled and analyzed, 58 of 225 Alaska 
tribes were co-located with a participating community (see table 2). 

Table 2: NFIP Access for Tribes in Alaska (2012): 

Measure of access: Tribes in Alaska located in an incorporated area 
that participates in NFIP; 
Number: 58. 

Measure of access: Tribes in Alaska located in an incorporated area 
that does not participate in NFIP; 
Number: 102. 

Measure of access: Tribes in Alaska located in unincorporated boroughs 
or municipalities(unincorporated areas are not eligible to participate 
in NFIP); 
Number: 64. 

Measure of access: Metlakatla Indian Community, Annette Island Reserve 
(does not participate in NFIP); 
Number: 1. 

Measure of access: Total; 
Number: 225. 

Source: GAO analysis of data from FEMA, the State of Alaska, and the 
Bureau of Indian Affairs. 

Notes: (1) For this table we focused on the geographic location of 
specific Alaska Native entities. As a result, we counted some entities 
separately that would normally be combined and we excluded two other 
regional entities. Specifically, we counted Arctic Village and the 
Village of Venetie separately rather than combined under the Native 
Village of Venetie Tribal Government (Arctic Village and Village of 
Venetie) umbrella entity. Similarly, we counted Saint George Island 
and Saint Paul Island separately rather than combined under the 
Pribilof Islands Aleut Communities of St. Paul and St. George Islands 
umbrella entity. Finally, we excluded the Central Council of the 
Tlingit and Haida Indian Tribes and the Inupiat Community of the 
Arctic Slope because they do not have geographic locations similar to 
individual tribes in Alaska. (2) Not all of the villages where the 
tribes in Alaska were historically located are occupied year round. 
Twenty-four tribes are associated with village locations that the 
state has identified as unpopulated, seasonal-use areas, or of 
undetermined population. 

[End of table] 

Tribes in Oklahoma and elsewhere that do not have reservations--as 
well as tribes with reservations--face similar challenges in adopting 
and enforcing land use ordinances because they lack jurisdiction over 
certain land. Tribes with reservations do not generally have authority 
to adopt and enforce land use ordinances for land within the 
reservation's boundaries owned by non-Indians. Likewise, 
representatives of an Oklahoma tribe told us that its lack of 
participation in NFIP was due in part to a reluctance to face possible 
sanctions because of the tribe's limited ability to enact and enforce 
ordinances for land owned by non-Indians.[Footnote 35] For example, 
they explained that if a home that had experienced repeated flooding 
was located on land where the tribe had limited jurisdiction, the 
tribe could not take action to mitigate future flood damage without 
the owner's permission. They said they were aware that NFIP does not 
have a workaround for such circumstances. The tribe had chosen to 
insure all tribal structures and vehicles under a private policy. 

In addition, representatives of several tribes explained that tribal 
structures differ from other local government structures but that FEMA 
did not take those differences into account, making participation 
difficult for some tribes. For example, representatives of a 
participating Washington tribe told us that in preparing its multi-
hazard mitigation plan for FEMA approval, the tribe realized that the 
plan template had been created for states, as it called for input from 
counties within the jurisdiction. Instead of counties, the tribe had 
to substitute less specific geographic areas within the tribal 
community. The same tribe was participating in NFIP's Community Rating 
System program, which allows communities to receive discounts on 
policies for their residents based on floodplain management actions 
the community takes beyond NFIP's minimum requirements. The 
representatives explained that NFIP also lacked a tribal template for 
the Community Rating System program, which they said would facilitate 
the tribe's participation. 

Without flood hazard maps, tribal communities, including those that 
may be in areas with a higher risk of flooding, may not be 
sufficiently aware of their flood risk. Tribes also may be reluctant 
to pursue NFIP participation if they are uncertain about whether they 
would qualify and could meet the program's requirements. Further, 
those with fewer resources and less administrative capacity may be 
less proactive in requesting that FEMA map their communities, even 
though they may be vulnerable to floods. 

FEMA Has Provided Indian Tribes with Training and Technical Assistance 
on Hazard Mitigation, Including Flood Insurance: 

FEMA's outreach to tribes in the last few years has largely consisted 
of emergency management and homeland security training for tribal 
officials through its Emergency Management Institute (EMI), direct 
technical assistance to tribes in preparing their multi-hazard 
mitigation plans, and nationwide outreach for NFIP through its 
regional offices and the NFIP FloodSmart marketing campaign. FEMA 
officials told us that the agency helped to educate tribal officials 
about NFIP and floodplain management through courses offered by EMI 
under a mitigation curriculum that includes courses for floodplain 
managers on their roles and responsibilities, flood insurance, and 
NFIP rules and regulations. FEMA has also developed an emergency 
management tribal curriculum to collaborate with tribal governments in 
building emergency management capability and partnerships to ensure 
continued survival of tribal nations and communities. 

To some extent, FEMA's efforts have helped some tribes better 
understand the flood hazards that they face. According to FEMA 
officials, more than 2,000 members from more than 300 Indian tribes 
have taken courses through EMI. The officials added that each regional 
office had a floodplain management specialist as the NFIP point of 
contact for Indian tribes. Officials from two tribes told us that they 
had participated in EMI training. One tribal emergency management 
official in Wisconsin told us that he participated in training with an 
EMI tribal curriculum group that communicated monthly. 

FEMA officials also described the direct technical assistance that 
they provided to tribes that were preparing hazard mitigation plans. 
According to FEMA, developing the plans involves identifying the 
tribe's critical infrastructure, major risks and vulnerabilities, and 
actions to reduce those risks and vulnerabilities for various types of 
disasters, including floods. This assistance provides tribes with an 
opportunity to learn about the risks that their individual communities 
may face. Representatives from several tribes told us that they had 
completed approved mitigation plans or were in the process of 
completing their plans. Two of the tribes with whom we spoke had their 
plans approved in 2010. 

FEMA FloodSmart officials explained that they tried to reach 
communities nationwide with the FloodSmart campaign, but that they 
targeted those communities that were most at risk for flooding. Among 
these communities, they focused on urban areas which had a higher 
concentration of potential flood insurance buyers than rural areas. 
They explained that FloodSmart used a tiered marketing strategy that 
was based on a number of factors that point to a high potential return 
on investment of federal dollars, including: (1) flood insurance 
policy purchase history, (2) potential flood risk as determined by 
volume of SFHA properties, (3) flood event history, (4) volume of 
structures, and (5) media cost. As such, rural areas, including Indian 
areas, generally received lower priority. 

FloodSmart officials told us that since February 2007, a total of 
671,000 acquisition-based direct mail pieces had been sent to 
approximately 383,000 distinct household addresses within zip codes 
that intersected with Indian reservations. Moreover, according to 
FloodSmart officials, on average, 112,000 direct mail pieces were sent 
to Indian reservations each year, the majority of which were sent to 
addresses for properties in an SFHA. However, several tribal 
representatives with whom we spoke still told us that they would like 
more information about NFIP and its requirements so that they could 
decide whether to participate in the program and encourage their 
members to purchase policies through the program. In addition, 
representatives from a few tribes and from an insurance company told 
us that marketing campaigns or other outreach efforts may have little 
effect in Indian communities without the buy-in of tribal leaders. 

HUD and USDA Work with Tribes on Housing Issues and May Provide Some 
Information on NFIP: 

HUD and USDA Rural Development provide assistance in the form of 
housing and infrastructure grants, loans, and loan guarantees to 
Indian tribes. According to officials from both agencies, while 
neither HUD nor USDA is required to provide NFIP outreach, the 
agencies worked with tribes on housing issues that may include 
determining flood risk to housing assistance projects and assessing 
housing-related issues after disasters, such as floods. In addition, 
the officials said that their field staff had FEMA FloodSmart program 
material on hand for interested parties, including Indian tribes. 

As part of the IHBG and ICDBG programs, HUD officials in the Office of 
Native American Programs told us that they worked with tribes to 
identify their priorities and to help them determine how to best use 
HUD funds as an investment in addressing their needs. In addition, 
under both IHBG and ICDBG, recipients can use program funds to cover 
flood insurance premiums for properties in some high-risk areas. HUD 
officials said that they conducted outreach to housing authorities in 
locations where floods and other disasters had occurred to assess the 
status of HUD housing stock and to identify displaced families. HUD 
officials also said that they coordinated with FEMA and other agencies 
locally so that the agencies could work together to assess grantees' 
damages and needs following a disaster, but that they did not know 
which tribes participated in NFIP. HUD regional officials said that 
they worked closely with individual tribes that had been impacted by 
flooding and other disasters and could offer technical and financial 
assistance to the tribes. Officials from three tribes told us that in 
their experience, HUD officials generally did not approve of using HUD 
assistance to build in an SFHA. An official from one of these tribes 
told us that to address HUD's requirements for one of its HUD-assisted 
housing developments, the tribe built pads on all of the houses it was 
constructing to elevate them out of the flood zone. In addition, 
officials in HUD's Office of Environment and Energy told us that they 
provided environmental training and invited grantees, including 
tribes, to attend this training. 

USDA Rural Development has a Native American Coordinator who interacts 
with tribes on programmatic issues, including challenges and issues 
that arise due to flooding. We spoke with the national coordinator, 
who explained that each state office serving a federally or state 
recognized Indian tribe designated an individual to serve as the USDA 
Rural Development state Native American Coordinator. He explained that 
the role had typically been a collateral duty although, in the past, 
three states had employed full-time Native American Coordinators. The 
coordinator's efforts related to NFIP primarily would be liaising 
between tribal staff and the appropriate Rural Development staff 
tasked with ensuring compliance with program requirements for USDA-
funded construction or development. Specifically, USDA officials told 
us that they ensured compliance with NFIP requirements only for USDA-
funded projects where construction or development occurred in an SFHA 
in an NFIP participating community. They explained that USDA's 
evaluation of NFIP applicability was part of National Environmental 
Policy Act reviews.[Footnote 36] In these cases, USDA officials said 
they ensured that mitigation actions were taken and when this was 
impractical, the applicant for USDA funding purchased flood insurance. 
The officials told us they did not provide any assistance for 
developing floodplain management approaches, but required that 
borrowers comply with applicable state or local floodplain ordinances 
or permits. Both HUD and USDA officials told us that when an area had 
not been mapped, they might rely on tribal elders or another 
knowledgeable source in determining the location of flood-prone areas. 

Boosting Tribes' Participation in Flood Insurance Programs: 

Representatives from HUD and USDA, tribal representatives, and private 
insurers all agreed that more could be done to encourage tribes to 
participate in flood insurance programs. However, FEMA noted that it 
was limited in its efforts by the unique legal issues surrounding 
Indian tribes and their lands. FEMA also told us its focus was on 
mapping more highly populated areas, which typically did not include 
Indian tribal communities. HUD and USDA acknowledged that more 
information and support could encourage tribes to participate in NFIP. 
For instance, HUD officials in the Northern Plains region, where more 
than 30 federally recognized tribes are located, told us that there 
was likely a need for more education among tribes.[Footnote 37] The 
officials said that they were aware that FEMA had to prioritize 
limited federal dollars for flood mapping activities and that tribal 
lands might not be a top priority. However, they noted that tribes 
also might not be proactive in requesting flood maps for their 
communities because they had received conflicting information about 
FEMA's authority to map tribal lands. The officials said they had 
invited FEMA to a regional meeting in the last year to share 
information on disaster topics, including floods and flood insurance, 
with tribal housing officials from the region. As previously noted, 
officials from HUD's Office of Environment and Energy also told us 
that they were increasing opportunities for HUD grantees, including 
tribes, to obtain information and training on environmental topics 
such as flood risks. 

Tribal representatives had a number of suggestions that could lead to 
increased tribal participation, ranging from expanding FEMA outreach 
and education to requiring tribes to have flood insurance. They 
suggested, among other things, 

* more emphasis on educating tribes on the importance of flood 
insurance, as at least one tribe had been experiencing more rain each 
year; 

* more outreach to tribes, including those without flood hazard maps, 
to help them understand their vulnerability to floods and the 
advantages of NFIP participation; 

* meetings that brought together FEMA officials and elected tribal 
councils that could make decisions on behalf of their tribes; 

* federal grants to help tribes develop elevation certificates and to 
retrofit older properties to lower risk and make the policies more 
affordable for members; 

* a simulation exercise that included the host tribe, FEMA officials, 
and other government officials with whom tribes would need to 
coordinate in a flood-related disaster; and: 

* an amendment to the NFIP statute to address issues specific to 
tribes' limited ability to adopt and enforce land use ordinances. 

At least one tribal representative said that it would be reasonable 
for Congress to require a flood mitigation plan across communities and 
tribal lands, regardless of risk level, and that tribes with critical 
infrastructure in a flood-prone area should be required to participate 
in NFIP or sign a waiver of future flood assistance. However, another 
representative suggested that FEMA should address the land use 
ordinance issue and determine, with the tribes' input, whether NFIP 
had been financially beneficial to tribal members who were able to 
purchase flood insurance in the nontribal community where they lived. 

Insurance company officials we spoke with, including a Write-Your-Own 
company and a broker, emphasized the importance of respecting the 
cultural issues of dealing with tribes in any targeted outreach 
activities. As we have seen, for example, the FloodSmart campaign sent 
thousands of pamphlets to individual residents on Indian lands. One 
insurance broker that targets Indian tribes told us that the company 
had received three requests for policies after the mailing. She told 
us that the company had learned that tribal members tend to rely on 
the views of their tribal leaders for guidance and that without the 
buy-in of these leaders, marketing FloodSmart materials to individual 
members would likely not be a successful strategy. 

Insurance and reinsurance company officials we spoke with were aware 
of the Biggert-Waters Flood Insurance Reform Act of 2012 requiring 
FEMA and GAO to assess options and strategies for privatizing NFIP in 
the future and authorizing FEMA to pursue private management 
initiatives.[Footnote 38] A reinsurance official said that his company 
had begun to examine whether it would be in its interest to become 
more involved now, given that future legislation would likely increase 
the private sector's role in flood insurance. This official added that 
his company recognized that NFIP was not actuarially sound and that 
expected additions to the nearly $18 billion deficit from Superstorm 
Sandy could accelerate congressional interest in greater private 
sector involvement in providing flood insurance. 

Other private sector insurance options may offer tribes an alternative 
to NFIP. A private insurer proposed two related options that could 
allow tribes to purchase flood insurance at a potentially lower cost 
than under NFIP. The first would involve expanding the existing 
eligible flood insurance risk-sharing pools to obtain the critical 
mass of policies necessary to make low-cost flood insurance policies 
affordable to Indian households. The second would establish a new 
private "microinsurance" program offering low-premium policies with 
small coverage limits tailored specifically to Indian tribes, based on 
similar operations in developing countries. 

* Nonprofit Insurance Risk Pool: Two of the tribes we contacted had 
purchased flood insurance through an insurance risk pool offered by 
AMERIND Risk Management Corporation. AMERIND was organized in 1986 as 
a collaborative program between HUD and some Indian housing 
authorities to provide insurance protection for Native American low-
income housing. It currently operates as a multitribal nonprofit 
corporation working with over 400 tribes and administers risk-sharing 
pools. Since 2002, AMERIND has offered a flood insurance endorsement 
to its standard policy, limited to HUD-assisted Indian 
housing.[Footnote 39] Company officials explained that through a 
members-only risk pool, the flood endorsement provides flood coverage 
to about 56,000 structures on tribal lands and charges a universal 
rate of $10 per structure per year (see table 3).[Footnote 40] AMERIND 
has a coverage limit of $15,000 for each covered structure. 

Table 3: Tribal Flood Insurance Policies in Place with AMERIND 
(November 2012): 

Measure: Number of Indian tribal entities participating; 
Number: 400+. 

Measure: Number of flood insurance policies; 
Number: 206. 

Measure: Number of structures insured; Residential (95 percent); 
Commercial (5 percent); 
Number: 45,000. 

Measure: Other; 
Number: [Empty]. 

Source: AMERIND Risk Management Corporation. 

[End of table] 

An Arizona tribe we contacted uses AMERIND insurance on its HUD-
assisted tribal housing, and the policies included the flood 
protection endorsement. According to the tribal representative, the 
tribe has used this insurance option for about 8 years. One Oklahoma 
tribe we contacted had not purchased AMERIND's flood insurance 
endorsement but had purchased property insurance from the company. 
This representative said that because of its affordability compared 
with NFIP and because the company is a multitribal corporation, he 
would refer individual members to AMERIND if they lived in HUD IHBG-
assisted housing within a floodplain and needed to purchase flood 
insurance. USDA Rural Development also has approved AMERIND as an 
eligible nonflood insurer for its single-family housing programs, so 
Indian tribes and their members can use an appropriate AMERIND product 
to insure projects financed through these programs. According to USDA, 
the intent is to facilitate use of its programs by Indian tribes and 
their members for projects on trust land when conventional insurance 
coverage is unavailable, difficult to access, or expensive. 

However, the current nonprofit insurance risk-pooling option has 
limitations. First, while the premium rate may be lower than NFIP's, 
the coverage limits for flood insurance are also generally lower. 
Representatives for AMERIND told us that coverage limits were low 
because the company had not been successful in obtaining reinsurance 
on the private market that would allow the company to mitigate its 
risk and offer full replacement costs for each structure. AMERIND does 
offer to provide double coverage ($30,000 per structure) for flood 
losses, but the premiums are more than 10 times the universal rate, 
ranging from about $150 to $200 per structure. These premiums are 
generally below NFIP rates for properties with similar coverage inside 
SFHAs and are generally comparable to NFIP rates for similar coverage 
outside SFHAs. Second, because AMERIND's flood insurance coverage is 
available for HUD IHBG-assisted structures only, tribes cannot use it 
for all structures on tribal lands. The tribes we interviewed that 
used AMERIND for flood insurance were able to obtain coverage only for 
HUD IHBG-assisted structures.[Footnote 41] Because of this limitation, 
AMERIND does not have the critical mass of policies necessary to offer 
private low-cost flood insurance to all Indian households. Third, 
communities may still face consequences if they are identified as 
having SFHAs and choose to obtain non-NFIP flood insurance. According 
to FEMA, NFIP aims to do more than simply encourage property owners to 
purchase flood insurance. It also encourages them to take measures to 
mitigate potential flood damage to their properties, and NFIP coverage 
is available only when certain flood protection standards have been 
implemented. 

* Private Microinsurance: Another potential private sector option 
would be a private microinsurance program. Microinsurance is a 
relatively new product that allows insurers to offer low-premium 
policies with small coverage limits in developing areas. The concept 
operates much like AMERIND's risk pool and is structured to provide 
low-income policyholders with a degree of "livelihood protection" or 
emergency expense support rather than full indemnity for loss. We 
spoke with officials from a reinsurance company that was recently 
awarded a grant from a member of the World Bank group to develop a 
market for microinsurance in an agriculture-based developing country. 
These officials and officials from the reinsurance company's insurance 
subsidiary said that, given the recent congressional interest in 
looking into private options for flood insurance, they would be 
interested in working with AMERIND or helping to develop another 
Native American flood insurance program that would cover all tribal 
member homeowners and businesses. They said that a mandatory coverage 
provision would solve the coverage problem and reduce uncertainty, 
making the provision of microinsurance more attractive to and 
sustainable for insurers and reinsurers. But they added that even with 
mandatory group coverage, they saw benefits to mapping all lands, 
because a private microinsurance risk pool would need to charge more 
for properties that were located on unmapped tribal lands than for 
similar properties located on mapped tribal lands. 

During the course of our work for this report, FEMA developed a draft 
statement of work for its upcoming private market assessment of NFIP. 
The draft statement, dated December 17, 2012, included a requirement 
for the contractor to assess a broad array of instruments, including 
reinsurance, microinsurance, and flood insurance pools. FEMA officials 
confirmed that the inclusion of microinsurance and insurance pools in 
the study was finalized after we raised and discussed those 
alternatives with them and that they considered both alternatives to 
be worth studying. FEMA officials told us that they planned to issue 
the statement of work early in January 2013. 

Conclusions: 

Congress created NFIP with the intent of providing affordable flood 
insurance to communities and households in order to financially 
protect property owners and reduce the cost of federal postdisaster 
assistance, but participation by Indian tribes has been low. Even on 
Indian lands that have experienced flooding, tribes and tribal members 
often do not participate, and the total number of policies written to 
tribes and tribal members accounts for less than 1 hundredth of a 
percent of FEMA's portfolio. FEMA has provided tribes with training 
and technical assistance and has to some extent helped tribes to 
understand the flooding risks they face. However, several factors have 
contributed to the low participation rate, including limited mapping 
on Indian lands; affordability; lack of information on NFIP; and 
tribal land use issues, including confusion about legal restrictions 
on activities on Indian lands. Limited mapping, in particular, has 
contributed to a lack of awareness both of the risk of flooding and of 
the benefits of NFIP. FEMA has generally focused its mapping efforts 
on densely populated and coastal areas in order to make the best use 
of its resources. However, increased mapping of less densely populated 
rural areas, including Indian lands, is in line with Congress's focus 
on increasing tribes' participation in NFIP and is key to raising 
awareness of the types of flood risks residents of these areas face. 
Expanding its flood mapping efforts will challenge FEMA to balance its 
need to make the best use of scarce resources with the needs of these 
previously underserved communities. 

Recommendation: 

To help increase Indian tribes' participation in NFIP, we recommend 
that the Administrator of FEMA examine the feasibility of making 
mapping of tribal lands a higher priority. 

Agency Comments: 

We provided a draft of this report for review and comment to USDA 
Rural Development, FEMA within the Department of Homeland Security, 
HUD, and BIA within the Department of the Interior. A letter from the 
Director of the Departmental GAO-OIG Liaison Office within the 
Department of Homeland Security stated that FEMA will take steps to 
make mapping of tribal lands a higher priority. The director also 
stated that doing so will be challenging due to FEMA's scarce 
resources and noted the agency's appreciation for GAO's acknowledgment 
of its resource limitations. In addition, the director said that FEMA 
will consider the suggestions made by tribal representatives for 
increasing tribal participation in flood insurance programs. The 
letter is reprinted in appendix II. We also received technical 
comments from USDA Rural Development, FEMA, and HUD, which we 
incorporated in the report as appropriate. BIA did not provide any 
comments. 

We are sending copies of this report to appropriate congressional 
committees, and the Secretaries of Agriculture, Homeland Security, 
Housing and Urban Development, and Interior. This report will also be 
available at no charge on GAO's website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-8678 or cackleya@gao.gov. Contact points for 
our Offices of Congressional Affairs and Public Affairs may be found 
on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix III. 

Signed by: 

Alicia Puente Cackley: 
Director, Financial Markets and Community Investment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our objectives were to examine (1) factors contributing to the current 
low levels of National Flood Insurance Program (NFIP) participation by 
Indian tribes, (2) the Federal Emergency Management Agency's (FEMA) 
efforts to increase tribes' participation in NFIP, and (3) 
administrative and legislative actions that could encourage Indian 
tribes and their members to increase their participation in NFIP and 
potentially other flood insurance programs. For the purposes of this 
review, we limited our study primarily to flood insurance policies 
held on Indian tribal lands (such as reservations), because FEMA does 
not collect demographic data such as race or ethnic origin of NFIP 
policyholders. Therefore, no comprehensive data are available on 
members of Indian tribes who are living in nontribal communities and 
may carry individual NFIP policies. We also interviewed 
representatives from Alaska, because many Alaska Native communities 
are vulnerable to floods, but do not have designated reservations that 
could participate in NFIP. With only one reservation in the state, 
tribes in Alaska can participate in NFIP only through the 
municipalities in which their communities are located. 

To address all three objectives, we reviewed NFIP laws and policy 
documents. We reviewed FEMA data on communities participating in NFIP, 
including those designated as tribal communities, and on tribes that 
had flood hazard maps but were not participating in NFIP for various 
reasons. FEMA provided us with information on its process for 
collecting and analyzing the data in its Community Information System 
database and on the agency's data reliability measures. We determined 
that the data FEMA provided to us were sufficiently reliable for our 
reporting purposes. In addition, we reviewed prior GAO work on flood 
insurance, Indian tribes, and disaster preparedness, and reports by 
the Congressional Research Service, to compile background information 
on NFIP. We interviewed and gathered documentation from officials at 
FEMA and other federal agencies with programs that assist Indian 
tribes, such as the Bureau of Indian Affairs (BIA) within the 
Department of the Interior, Department of Housing and Urban 
Development (HUD), and the U.S. Department of Agriculture (USDA) Rural 
Development. In addition, we reviewed regulations for those agencies' 
programs. We spoke with representatives from the State of Alaska; the 
National Flood Determination Association, which provides flood mapping 
data to mortgage lenders and insurers; the insurance and reinsurance 
industries; a nonprofit risk-pooling organization; FloodSmart, which 
administered FEMA's NFIP media campaign; and selected Indian tribes. 

We selected the tribes from among those on FEMA's lists of tribes that 
were participating in NFIP and those that had flood hazard maps but 
were not participating in NFIP. We selected a purposive non-
representative sample of eight participating tribes for interviews 
based on the number of individual policies within each tribe, 
geographic diversity, and tribe size. We also selected a purposive non-
representative sample of six nonparticipating tribes for interviews 
based on the reason for nonparticipation, geographic diversity, and 
tribe size. In addition, our prior work on the Native American Housing 
Assistance and Self-Determination Act of 1996 (NAHASDA) program 
partially informed the tribes we selected. Specifically, because we 
had already established communication with certain tribes, we selected 
them over comparable tribes on either list. Because of our time 
constraints and several selected tribes being impacted by a natural 
disaster (Superstorm Sandy), we were able to interview five 
participating and five nonparticipating tribes. We also judgmentally 
selected a tribe in Alaska that we had contacted previously to obtain 
a perspective on NFIP from a tribe in that state. To obtain 
perspectives from the insurance industry, we interviewed 
representatives from an insurance company that we contacted while 
conducting prior work related to the Write-Your-Own insurance program, 
a vendor that administers NFIP flood policies for Write-Your-Own 
insurance companies, and an insurance broker that specializes in 
working with Indian tribes. 

To determine factors contributing to the current low levels of NFIP 
participation by Indian tribes, we reviewed FEMA's data on tribal 
community participation. We also asked FEMA officials about the 
agency's process for mapping Indian lands (or providing flood hazard 
maps to Indian communities), and options for tribes to participate in 
NFIP. In our interviews with other federal officials, tribal 
representatives, and others, we asked about factors that may 
positively or negatively affect whether tribes participate in NFIP. 

To determine the efforts FEMA was making to increase awareness of and 
encourage participation in NFIP by Indian tribes, we asked officials 
at FEMA about outreach and technical assistance they provided to 
Indian tribes related to floods and flood insurance. In addition, we 
asked FloodSmart representatives about any efforts to market NFIP to 
Indian tribes and their members. We also asked officials at BIA, HUD, 
and USDA about information they may share with tribes on flood 
insurance in providing program support. Further, we asked tribal 
representatives about their interactions with FEMA and other agencies 
and information or assistance they had received related to NFIP. 

To determine what administrative or legislative actions could 
encourage Indian tribes and their members to increase their 
participation in NFIP and potentially other flood insurance programs, 
we reviewed NFIP regulations and legislation and guidance on FEMA 
coordination with and outreach to Indian tribes. We interviewed 
representatives from the insurance and reinsurance industries about 
other flood insurance options, in addition to NFIP, that may 
facilitate tribes' purchase of flood insurance. We also asked federal 
officials and tribal representatives about actions that FEMA or 
Congress could take to encourage tribes participating in NFIP to 
increase their use of the program and tribes not participating to join 
NFIP. 

Tribe Selection Process: 

Participating: Based on number of individual NFIP policies held by the 
tribe, size of tribe, and geographic diversity, a total of eight 
tribes were selected for inclusion as well as six backup tribes. 
Tribes and backup tribes were selected within each region, except in 
the Northeast region where there was only one tribe included in our 
sample frame. One group of selected tribes had the largest number of 
policies and the backups had the second largest number of policies. 
The other group of tribes had the lowest number of policies. Among the 
cohort of lowest policies, within each region, tribes selected were 
those with the largest enrollment and the backups were those with the 
second largest enrollment. 

Nonparticipating: Based on reason for nonparticipation (such as 
withdrawn or suspended from the program), size of tribe, and 
geographic diversity, a total of six tribes were selected for 
inclusion as well as three back-up tribes. Tribes and backup tribes 
were selected within each region, except in the Northeast region where 
there was only one tribe included in our sample frame. Additionally, 
the one withdrawn tribe and the one suspended tribe are also included 
in our selected tribes. In the other three regions, one group of 
selected tribes had the largest number tribal enrollment and the 
backups had the second largest tribal enrollment. 

We conducted this performance audit from August 2012 to January 2013 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the Federal Emergency Management Agency: 

U.S. Department of Homeland Security: 
Washington, DC 20528: 

December 28, 2012: 

Alicia Puente Cackley: 
Director, Financial Markets and Community Investment: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Re: Draft Report GAO-13-226,"Flood Insurance: Participation of Indian 
Tribes in Federal and Private Programs" 

Dear Ms. Cackley: 

Thank you for the opportunity to review and comment on this draft 
report. The U.S. Department of Homeland Security (DHS) appreciates the 
U.S. Government Accountability Office's (GAO's) work in planning and 
conducting its review and issuing this report. 

The Department is pleased to note GAO's acknowledgement of efforts 
undertaken by the Federal Emergency Management Agency (FEMA) to inform 
and encourage Tribal participation in the National Flood Insurance 
Program (NFIP). The draft report contained one recommendation, with 
which the Department concurs. Specifically, GAO recommended that the 
Administrator of FEMA: 

Recommendation: Examine the feasibility of making mapping of tribal 
lands a higher priority. 

Response: Concur. FEMA's Federal and Insurance and Mitigation 
Administration will examine the feasibility of making mapping of 
tribal lands a higher priority by continuing to use FEMA's Risk Map 
products to assist Indian Tribes in making informed decisions 
regarding risk. FEMA will continue to expand its outreach to Tribal 
governments through Regional Tribal Liaisons and Floodplain Management 
Specialists when developing Risk Map products ensuring Indian Tribe 
participation is obtained through meaningful dialogue regarding the 
Tribe's risk and opportunities for mitigation. We appreciate GAO's 
recognition that reprioritizing FEMA's flood mapping efforts will be 
challenging in so far as balancing the need to make the best use of 
increasingly scarce and limited resources with the needs of tribal 
communities. FEMA will also consider and take action, as appropriate, 
on the suggestions made by tribal representatives for increasing 
tribal participation in flood insurance programs. Estimated Completion 
Date: June 30, 2013. 

Again, thank you for the opportunity to review and comment on this 
draft report. Technical comments were previously provided under 
separate cover. Please feel free to contact me if you have any 
questions. We look forward to working with you in the future. 

Sincerely, 

Signed by: 

Jim H. Crumpacker: 
Director: 
Departmental GAO-OIG Liaison Office: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Alicia Puente Cackley, (202) 512-8678, cackleya@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Andy Finkel (Assistant 
Director), Bernice Benta-Jackson, Emily Chalmers, Brian Friedman, 
Jeffery Malcolm, Marc Molino, Patricia Moye, Roberto Pinero, and 
Andrew Stavisky made key contributions to this report. 

[End of section] 

Footnotes: 

[1] We used data that we had reported previously to show trends over 
time--in this case, a 25-year period. See GAO, Natural Hazard 
Mitigation, Various Mitigation Efforts Exist, but Federal Efforts Do 
Not Provide a Comprehensive Strategic Framework, [hyperlink, 
http://www.gao.gov/products/GAO-07-403] (Washington, D.C.: Aug. 22, 
2007). 

[2] Congressional Research Service, National Flood Insurance Program: 
Background, Challenges, and Financial Status, R40650 (Washington, 
D.C.: June 12, 2012). 

[3] Facing Floods and Fires: Emergency Preparedness for Natural 
Disasters in Native Communities: Hearing before the S. Comm. on Indian 
Affairs, 112th Cong. 44-45 (statement of Sen. Mike Johanns, Member, S. 
Comm. on Indian Affairs), 2011. 

[4] Pub. L. No. 112-141, § 100237, 126 Stat. 405, 957-58 (2012). 

[5] FEMA maintains data on communities, including Indian tribes, that 
participate in NFIP and on their floodplain management activities in 
its Community Information System database. The data include the FEMA 
region in which each tribe is located (including state and county), 
community identification numbers and names, date of the most recent 
flood maps, and number of NFIP policies in place for each tribe. The 
database also contains information on mapped communities that do not 
participate in NFIP. FEMA designates communities as "tribal" based on 
self-reported data from the tribes themselves. 

[6] See GAO, Native American Housing: Tribes Generally View Block 
Grant Program as Effective, but Tracking of Infrastructure Plans and 
Investments Needs Improvement, [hyperlink, 
http://www.gao.gov/products/GAO-10-326] (Washington, D.C.: Feb. 25, 
2010). 

[7] See GAO, Flood Insurance: Opportunities Exist to Improve Oversight 
of the WYO Program, [hyperlink, 
http://www.gao.gov/products/GAO-09-455] (Washington, D.C.: Aug. 21, 
2009). 

[8] [hyperlink, http://www.gao.gov/products/GAO-07-403]. 

[9] Pub. L. No. 90-448, Tit. XIII, 82 Stat. 572 (1968). 

[10] Pub. L. No. 93-234, 87 Stat. 975 (1973); Pub. L. No. 103-325 Tit. 
V, 108 Stat. 2160 (1994). 

[11] Pub. L. No. 112-141, Div. F, Tit. II, Subtit. A, 126 Stat. 405, 
916 (2012). 

[12] Owners of properties that receive federal financial assistance 
for acquisition or construction purposes in SFHAs in communities that 
participate in NFIP are required to purchase and retain flood 
insurance. It is important to note that FEMA is prohibited from 
providing certain types of disaster assistance in connection with 
floods to applicants located in SFHAs if the community does not 
participate in NFIP. See 42 U.S.C. § 4106. 

[13] BIA's Housing Improvement Program funds home repair, renovation, 
and replacement. The program provides grants to the neediest Indian 
families who live in substandard housing or are without housing and 
have no other resource for assistance. The IHBG is authorized under 
the Native American Housing Assistance and Self-Determination Act of 
1996 (NAHASDA) program. The IHBG and ICDBG are available to qualifying 
tribal entities to fund several eligible activities related to housing 
and community development, respectively. For additional details on 
NAHASDA, see [hyperlink, http://www.gao.gov/products/GAO-10-326]. USDA 
Rural Development provides low-income housing assistance through 
several programs for which Indian tribes or their members are 
eligible, including the section 515 (Rural Rental Housing) and section 
502 (Single-Family Housing) loan programs and the section 504 (Rural 
Housing Repair and Rehabilitation) loan and grant program. USDA Rural 
Development also provides financing for community infrastructure to 
tribes through multiple programs that may require flood insurance as a 
loss mitigation measure. 

[14] CRS, R40650. 

[15] A FIRM is an official map of a community on which FEMA has 
delineated both the SFHAs and risk premium zones applicable to a 
community. A Flood Hazard Boundary Map is based on approximate data 
and identifies the SFHAs within a community. 

[16] Pub. L. No. 112-141, Div. F, Tit. II, Subtit. A. 

[17] The Biggert-Waters Flood Insurance Reform Act of 2012 eliminated 
insurance premium subsidies on new policies and phased out subsidies 
for certain existing policies, including properties that have severe 
repetitive losses and properties that have incurred flood-related 
damage that exceeds the fair market value of the property. Pub. L. No. 
112-141, § 100205. 

[18] See GAO, FEMA: Action Needed to Improve Administration of the 
National Flood Insurance Program, [hyperlink, 
http://www.gao.gov/products/GAO-11-297] (Washington, D.C.: June 9, 
2011). 

[19] Flooding events corresponding with these losses are Tropical 
Storm Allison (2001), Hurricane Ivan (2004), the Gulf Coast Hurricanes 
(2005), and Hurricane Ike (2008). 

[20] 44 C.F.R. § 59.1. Although Indian tribes are not explicitly 
mentioned in the National Flood Insurance Act, the Federal Insurance 
Administrator and subsequently FEMA have issued rulemakings that 
define "community" as including Indian tribes for purposes of NFIP. 
Like all communities, tribal communities must have the authority to 
adopt and enforce floodplain management regulations for the areas 
within their jurisdiction in order to be eligible for participation in 
NFIP. 

[21] See 44 C.F.R. § 206.110(k). 

[22] 42 USC § 4012a. 

[23] Since 1979, BIA has regularly published a list of federally 
recognized Indian tribes in the Federal Register. For the latest list, 
see 77 Fed. Reg. 47.868 (Aug. 10, 2012). 

[24] GAO, Indian Issues: Observations on Some Unique Factors that May 
Affect Economic Activity on Tribal Lands, [hyperlink, 
http://www.gao.gov/products/GAO-11-543T] (Washington, D.C.: Apr. 7, 
2011). 

[25] We have reported in the past that some tribes are landless. See 
table 4 in GAO, Indian Issues: BLM's Program for Issuing Individual 
Indian Allotments on Public Lands Is No Longer Viable, [hyperlink, 
http://www.gao.gov/products/GAO-07-23R] (Washington, D.C.: Oct. 20, 
2006). See Brendale v. Confederated Tribes and Bands of Yakima Indian 
Nations, 492 U.S. 408 (1989). 

[26] Pub. L. No. 92-203, 85 Stat. 688 (1971), codified as amended at 
43 U.S.C. §§ 1601-1629h. 

[27] The Act of February 8, 1887, commonly referred to as the General 
Allotment Act, authorized the President to allot parcels of land--
generally in sizes of 40, 80, or 160 acres--to individual Indians on 
Indian reservations and on public lands. Indian General Allotment Act, 
24 Stat. 388 (1887). See [hyperlink, 
http://www.gao.gov/products/GAO-07-23R]. 

[28] S. 2283, 112th Cong. (2012). 

[29] The proposed amendment, however, would not prohibit a tribe from 
receiving assistance through a presidential declaration at the request 
of a state if the President does not make a declaration at the request 
of a tribe. 

[30] According to FEMA, there were nearly 5.6 million NFIP policies in 
place as of August 2012. 

[31] According to FEMA, 8 of the 37 tribes participating in NFIP did 
not have their own flood hazard maps. Three had their tribal lands 
mapped on county maps and 5 were participating without a map in the 
NFIP emergency program. As noted, there were also 46 mapped tribes not 
participating in NFIP. 

[32] A watershed (also a basin or catchment area) may be defined as an 
area that drains into a lake, stream, or other body of water. In 
fiscal year 2010, FEMA implemented a watershed-based approach for 
conducting flood hazard studies. Specifically, FEMA officials 
explained that mapping is done at a county and watershed level rather 
than community-by-community. According to FEMA, the overarching 
principle of the watershed approach is to develop a complete, 
consistent, and connected flood engineering analysis within a 
watershed. 

[33] As previously noted, FEMA assigns a unique community 
identification number to each community listed in its NFIP Community 
Information System database. The actions of a specific community under 
NFIP directly impact the availability and cost of NFIP policies for 
its residents. For example, a community's actions could result in its 
residents receiving NFIP policy discounts. For more on Indian self-
determination, see [hyperlink, http://www.gao.gov/products/GAO-10-326]. 

[34] As previously noted, under NAHASDA, recipients of HUD grant funds 
are required to obtain flood insurance coverage when the development 
assisted with those funds is in an identified SFHA. The required 
period for insurance coverage is the useful life of the property, as 
defined by the grantee with HUD approval. 

[35] According to FEMA, a community could face consequences if it had 
been identified as having an SFHA but chose not to participate in 
NFIP. A community becomes ineligible for certain types of assistance 1 
year after the effective date of the community's flood hazard map. 
Participating communities that fail to adopt adequate ordinances or 
correct deficiencies are subject to sanctions. FEMA-imposed sanctions 
under NFIP may include an added premium for each policy sold or 
renewed in the community or a suspension on new policy purchases and 
existing policy renewals. 

[36] National Environmental Policy Act of 1969, Pub. L. No. 91-190, 83 
Stat. 852 (1970), codified as amended at 42 U.S.C. §§ 4321-4347 
(2012). Under the National Environmental Policy Act, agencies evaluate 
the likely environmental effects of projects they are proposing using 
an environmental assessment or, if the projects likely would 
significantly affect the environment, a more detailed environmental 
impact statement. Some actions are not subject to review, including 
those excluded by section 316 of the Stafford Act and certain 
emergency actions. 

[37] HUD's six regional Office of Native American Programs offices are 
located in Anchorage (Alaska), Chicago (Eastern Woodlands), Denver 
(Northern Plains), Seattle (Northwest), Oklahoma City (Southern 
Plains), and Phoenix (Southwest). 

[38] Pub. L. No. 112-141, § 100232. 

[39] The International Risk Management Institute, Inc. defines an 
endorsement as an insurance policy form that changes or adds to the 
provisions included in one or more of the forms that construct a 
policy, and notes that endorsements may serve to broaden the scope of 
coverage. 

[40] See GAO, Natural Hazard Mitigation and Insurance: The United 
States and Selected Countries Have Similar Natural Hazard Mitigation 
Policies but Different Insurance Approaches, [hyperlink, 
http://www.gao.gov/products/GAO-09-188R] (Washington D.C.: Dec. 22, 
2008) for information on the private natural perils risk pool in 
Switzerland that includes flood coverage. 

[41] However, they were able to obtain traditional nonflood property 
coverage from AMERIND on structures receiving Rural Development 
assistance. 

[End of section] 

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