Recommendation: The Administrator of FEMA should assess different approaches, in addition to community assistance visits, for using existing resources to ensure communities' compliance with NFIP requirements. This should include analyzing alternatives to community assistance visits. (Recommendation 1)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of FEMA should identify appropriate steps to ensure it has complete, up-to-date, and reliable records of community assistance visits, including information on why some visit records remain open for a significant period of time. (Recommendation 2)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of FEMA should ensure that communities are consistently collecting data on their substantial damage assessments and that FEMA has a way to readily access those data to evaluate community compliance with NFIP requirements for rebuilding substantially damaged properties. (Recommendation 3)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of FEMA should clarify with NFIP communities its policies on sharing data on NFIP claims and provide such information to those communities as needed. (Recommendation 4)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: As Congress considers reauthorizing NFIP, it should consider comprehensive reform to improve the program's solvency and enhance the nation's resilience to flood risk, which could include actions in six areas: (1) addressing the current debt, (2) removing existing legislative barriers to FEMA's revising premium rates to reflect the full risk of loss, (3) addressing affordability, (4) increasing consumer participation, (5) removing barriers to private-sector involvement, and (6) protecting NFIP flood resilience efforts. In implementing these reforms, Congress should consider the sequence of the actions and their interaction with each other.

Agency: Congress
Status: Open

Comments: As of July 2020, Congress has not passed comprehensive reform of NFIP, but Congress is considering various reforms as it works to reauthorize the program. We will review the status of this item if and when such legislation passes.

Recommendation: To improve the transparency and accountability over the compensation paid to WYO companies and set appropriate compensation rates, the FEMA administrator should take into account WYO company characteristics that may impact companies' expenses and profits when developing the new compensation methodology and rates.

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

Comments: According to FEMA officials, FEMA is responding to this recommendation as part of its development of a final rule on WYO compensation practices, required by the Biggert-Waters Act. FEMA issued a Notice of Proposed Ruling on July 8, 2019 seeking comments by September 6, 2019 regarding possible approaches to incorporate actual flood expense data into the WYO payment methodology.

Recommendation: To promote forward-looking construction and rebuilding efforts while FEMA phases out most subsidies, the Secretary of the Department of Homeland Security should direct FEMA to consider amending NFIP minimum standards for floodplain management to incorporate, as appropriate, forward-looking standards, similar to the minimum standard adopted by the Hurricane Sandy Rebuilding Task Force.

Agency: Department of Homeland Security
Status: Open

Comments: In August 2019, a FEMA official stated that FEMA intends to implement the recommendation in full eventually, but it is unlikely that it will happen as a cohesive effort in 2020, given other ongoing flood insurance reforms. As of August 2020, the status of this recommendation remains unchanged.

Recommendation: To establish full-risk rates for properties with previously subsidized rates that reflect their risk for flooding, the Secretary of the Department of Homeland Security (DHS) should direct the FEMA Administrator to develop and implement a plan, including a timeline, to obtain needed elevation information as soon as practicable.

Agency: Department of Homeland Security
Status: Open
Priority recommendation

Comments: As of January 2020, FEMA continues its multi-year effort to redesign its risk rating system to reflect industry best practices, such as providing credible, understandable rates based on graduated risk. As part of this redesign, FEMA plans to obtain multiple sources of data and information about a property's risk of flooding--from which it may be able to derive elevation information on some properties--to develop the insurance rate. FEMA has delayed implementation of the new risk rating system until 2021, pending further analysis. In addition, FEMA issued a Request for Information on obtaining structural elevation information from third party sources and is reviewing responses from potential vendors. The agency also encourages subsidized policyholders who seek to ensure the appropriateness of their NFIP rates to voluntarily submit elevation documentation. We will continue to monitor the extent to which FEMA is able to produce elevation information for all currently subsidized properties.

Recommendation: To provide transparency and accountability over the payments FEMA makes to WYOs for expenses and profits, the Secretary of Homeland Security should direct the Under Secretary of Homeland Security, FEMA, to determine in advance the amounts built into the payment rates for estimated expenses and profit.

Agency: Department of Homeland Security
Status: Open

Comments: According to FEMA officials, FEMA is responding to this recommendation as part of its development of a final rule on WYO compensation practices, required by the Biggert-Waters Act. FEMA's current payment rates do not explicitly consider WYO insurers' actual expenses and profit. FEMA issued an Advance Notice of Proposed Ruling on July 8, 2019 seeking comments by September 6, 2019 regarding possible approaches to incorporating actual flood insurance expense data into the WYO payment methodology. As of February 2020, FEMA officials said that they were reviewing comments received in response to the July 2019 notice.

Recommendation: To provide transparency and accountability over the payments FEMA makes to WYOs for expenses and profits, the Secretary of Homeland Security should direct the Under Secretary of Homeland Security, FEMA, to annually analyze the amounts of actual expenses and profit in relation to the estimated amounts used in setting payment rates.

Agency: Department of Homeland Security
Status: Open
Priority recommendation

Comments: According to FEMA officials, FEMA is responding to this recommendation as part of its development of a final rule on WYO compensation practices, required by the Biggert-Waters Act. However, GAO has reported that an annual analysis of the WYO insurers' actual expenses and profit could be regularly performed in relation to FEMA's existing payment methodology. FEMA issued an Advance Notice of Proposed Ruling on July 8, 2019 seeking comments by September 6, 2019 regarding possible approaches to incorporating actual flood insurance expense data into the WYO payment methodology. As of February 2020, FEMA officials said that they would complete an annual analysis of WYO data by the end of fiscal year 2020 and that they were reviewing comments received in response to the July 2019 notice.

Recommendation: To provide transparency and accountability over the payments FEMA makes to WYOs for expenses and profits, the Secretary of Homeland Security should direct the Under Secretary of Homeland Security, FEMA, to consider the results of the analysis of payments, actual expenses, and profit in evaluating the methods for paying WYOs.

Agency: Department of Homeland Security
Status: Open

Comments: According to FEMA officials, FEMA is responding to this recommendation as part of its development of a final rule on WYO compensation practices, required by the Biggert-Waters Act. FEMA issued an Advance Notice of Proposed Ruling on July 8, 2019 seeking comments by September 6, 2019 regarding possible approaches to incorporating actual flood insurance expense data into the WYO payment methodology. As of February 2020, FEMA officials said that they were reviewing comments received in response to the July 2019 notice.

Recommendation: To increase the usefulness of the data reported by WYOs to the National Association of Insurance Commissioners (NAIC) and to institutionalize FEMA's use of such data, the Secretary of Homeland Security should direct the Under Secretary of Homeland Security, FEMA, to take actions to obtain reasonable assurance that NAIC flood insurance expense data can be considered in setting payment rates that are appropriate, including identifying affiliated company profits in reported flood insurance expenses.

Agency: Department of Homeland Security
Status: Open

Comments: According to FEMA officials, FEMA is responding to this recommendation as part of its development of a final rule on WYO compensation practices, required by the Biggert-Waters Act. FEMA can also take actions, in addition to any actions related to the rule, to develop method(s) for obtaining reasonable assurance that NAIC data is accurate and usable for setting payment rates before implementation of a new compensation methodology. FEMA issued an Advance Notice of Proposed Ruling on July 8, 2019 seeking comments by September 6, 2019 regarding possible approaches to incorporating actual flood insurance expense data into the WYO payment methodology. As of February 2020, FEMA officials said that they were reviewing comments received in response to the July 2019 notice.

Recommendation: To increase the usefulness of the data reported by WYOs to the National Association NAIC and to institutionalize FEMA's use of such data, the Secretary of Homeland Security should direct the Under Secretary of Homeland Security, FEMA, to develop comprehensive data analysis strategies to annually test the quality of flood insurance data that WYOs report to NAIC.

Agency: Department of Homeland Security
Status: Open

Comments: According to FEMA officials, FEMA is responding to this recommendation as part of its development of a final rule on WYO compensation practices, required by the Biggert-Waters Act. FEMA can also take actions, in addition to any actions related to the rule, to develop and implement data analysis strategies to annually test the quality of flood insurance data WYO insurers report to NAIC before implementation of a new compensation methodology. FEMA issued an Advance Notice of Proposed Ruling on July 8, 2019 seeking comments by September 6, 2019 regarding possible approaches to incorporating actual flood insurance expense data into the WYO payment methodology. As of February 2020, FEMA officials said that they were reviewing comments received in response to the July 2019 notice.

Recommendation: The Secretary of the Department of Homeland Security should direct FEMA to take steps to ensure that its rate-setting methods and the data it uses to set rates result in full-risk premiums rates that accurately reflect the risk of losses from flooding. These steps should include, for example, verifying the accuracy of flood probabilities, damage estimates, and flood maps; ensuring that the effects of long-term planned and ongoing development, as well as climate change, are reflected in the flood probabilities used; and reevaluating the practice of aggregating risks across zones.

Agency: Department of Homeland Security
Status: Open
Priority recommendation

Comments: In April 2018, FEMA officials told us they had begun to redesign NFIP's risk rating system to help ensure policy rates better reflect the risk of flooding. The redesign, known as Risk Rating 2.0, includes efforts to use catastrophe models, stochastic approaches, and updated map information to better reflect the variation in flood risk. These reforms are also intended to improve how FEMA's rating process accounts for general and specific factors that affect flood probabilities and damage. While FEMA initially announced that new rates for all single-family homes would go into effect nationwide on October 1, 2020, it announced in November 2019 that it would defer implementation to October 1, 2021. FEMA said this would allow it to conduct a comprehensive analysis of the proposed rating structure so as to protect policyholders and minimize any unintentional negative effects of the transition, and that the new implementation date would cover all NFIP policies.

Recommendation: The Secretary of the Department of Homeland Security should direct FEMA to ensure that information is collected on the location, number, and losses associated with existing and newly created grandfathered properties in NFIP and to analyze the financial impact of these properties on the flood insurance program.

Agency: Department of Homeland Security
Status: Open

Comments: As of February 2020, FEMA officials said they had finished identifying properties with grandfathered premium rates and that they planned to analyze their economic implications as part of their efforts to update their premium rate setting approach, known as Risk Rating 2.0. FEMA plans to implement this redesign on October 1, 2021.