By Murray Wennerlund published 12-1-2022 updated 12-4-2022
Thousands of disaster damaged homes were not inspected properly by FEMA because FEMA was following CDC guidance and not visiting disaster damaged homes for the years 2020/21/22 and has only just recently allowed inspectors to enter the disaster damaged home.
Homeowners to include manufactured homes that sustained damages from any storm from 2020 to 2022 that did not or was not provided a full interior and exterior inspection by an official FEMA inspector should call FEMA and schedule a new inspection.
I spoke with 5 FEMA agents about the incomplete inspections and all 5 agents were willing to schedule a new inspection.
It's important to understand that if your damage assessment is low and your actual costs are higher the difference between the two numbers is called "unmet needs". Your unmet needs are anything that FEMA and your private insurance didn't cover. The program for disaster damage that addresses unmet needs is called HUD CDBG-DR and is a grant program that is managed by your states governors office. Most times it's connected with your states land management or housing management agencies. In all cases it will be part of your executive branch of government and is completely funded by federal tax dollars. This is why it's important that you have a valid and complete FEMA inspection for all declared disasters that were identified in your area.
FEMA inspections will assist you with mitigation years down the road after the disaster and will qualify you for grants and loans when their are no other options. But without a proper inspection by FEMA you are not qualified for any federal assistance at all.
You most be prioritized based on your states disaster program policies. I know the policies from Louisiana and a few from Florida and Texas which are very similar but I find Louisiana is best at finding policy that eliminates homeowners by finding them ineligible early on so not to even budget for offering federal grants to uninsured homeowners or homeowners with unmet needs.
Please read this article completely before contacting me for one on one assistance.
"On March 22, 2022, HUD allocated nearly $3 billion in Community Development Block Grant Disaster Recovery (CDBG-DR) funds appropriated by the Disaster Relief Supplemental Appropriations Act, 2022 for major disasters occurring in 2020 and 2021. " Resource
"The Appropriations Act requires HUD to include with any final allocation for the total estimate of unmet need an additional amount of 15 percent of that estimate for mitigation activities that reduce risk in the MID areas (see Tables 1 and 3)." Resource
HUD determines "unmet need" by collecting data from FEMA inspections. HUD focuses on the most impacted and distressed (MID) areas of the disaster. Then HUD takes it's own data to determine the incomes and housing structure types of the area. This establishes the first allocations of federal tax dollars that is distributed to the state agencies responsible for the management of HUD CDBG-DR grant distribution.
Because FEMA did not inspect homes completely in 2020, 2021 and into 2022 and placed much of the responsibility on the homeowners to document the damages and electronically send to FEMA their (homeowners) reports and pictures.
In my estimates FEMA did not report to HUD the actual or estimated corrected damages each homeowner sustained from the disaster. It's impossible to have standardized inspections that are used to create a budget and allocations for repairs of unmet needs when you are forcing or using the actual homeowner to do the inspection. Even with properly asked questions the homeowner is not a qualified person to assess damage of their own home for reporting to FEMA unless they have worked and were trained by FEMA officially.
With this said and with more clarification using Louisiana as my example the state estimates one half of the allocations for homeowners is going to multi-family housing projects because only $300,000,000 was reported by FEMA and estimated as unmet needs in the state of Louisiana for all declared disasters between 2020 and 2022.
$300 million is less than half of the funding 17,000 households received for the Grant Floods of 2016. That was out of an estimated 49,000 eligible households.
HUD allocated just over $600,000,000 to assist homeowners with unmet needs the state in advance to distributing the grants calculated that most of those households with unmet needs would not qualify because of the HUD policy that states the home has to have sustained major to severe damage before being eligible for grant funding by HUD CDBG-DR programs. This brings me back to the inspection process that FEMA did not complete or completed with the homeowners acting as their own inspectors.
I will describe one case, a manufactured home which was damaged in a hurricane and sustained roof damage from wind and debris to include a falling tree branch that hit the roof. The Blue Roof Program identified weak areas of the roof and sheathed the roof with 1/2" OSB and then place a blue tarp over the full roof of the 14x55 mobile home.
FEMA call the homeowner and asked for pictures, FEMA couldn't see the roof because the homeowner did not own a ladder and couldn't take pictures of the roof damage. The homeowner took a picture of the outside and a few pictures from the inside and FEMA awarded the homeowner $3,000 to complete all repairs.
A second FEMA inspection was requested and FEMA added an additional $2,500 to the repairs allocations but still didn't clearly understand the roof damage.
It's been over one year since that hurricane and now mold, walls, ceiling tiles are water damaged because the roof in parts continued to leak.
FEMA has now scheduled a new inspection which will be conducted by a FEMA inspector since FEMA's policy change June 2022. The home has sustained additional damage because of the repairs not completed and should place the home into the major to severe damage category which will make them eligible for HUD CDBG-DR grant funding to complete the repairs if not replace the full manufactured home.
Next I'll explain using HUD allocations published in the Federal Register how damage assessments are critical for those that need the assistance in the form of grants which do not have to be paid back.
"HUD's Methods for Estimating Serious Unmet Needs for Housing. (Resource)
The data HUD uses to calculate unmet needs for 2020 and 2021 qualifying disasters come from the FEMA Individual Assistance program data on housing-unit damage as of February 10, 2022 and reflect disasters occurring in 2020 and 2021.
The core data on housing damage for both the unmet housing needs calculation and the concentrated damage are based on home inspection data for FEMA's Individual Assistance program and SBA's disaster loan program. HUD calculates “unmet housing needs” as the number of housing units with unmet needs times the estimated cost to repair those units less repair funds already provided by FEMA and SBA."
In the allocations published it is clear if your home inspection did not reflect the actual damage you sustained then the allocations calculation would be wrong. It's a fact that 10's of thousands of homeowners did their own inspections and are not qualify to assess damages to a home but were asked to do so by FEMA call center agents that followed internal guidance and policy during the years 2020 and 2021 to late in 2022.
You may have received a letter from your state stating that you could not be "prioritization of funding because the FEMA inspection" which simply means you either had an inspection that reported less damage than the HUD program allows or your home was not inspected by a FEMA inspector or FEMA did not report to your state that your home was inspected and included the estimated costs of repairs to make your home habitable.
To help you reduce your overall debt burden you must apply for ever grant or non-profit funding for repairs as you can. The best grant program is the HUD CDBG-DR program and can assist based on your states managers just about any income range for households. But their priority sometimes but not all times is on low-income to moderate-income households. In general, most household incomes below 120% AMI are included in these programs. All households that are uninsured will be addressed as well. Your state will have a list of qualifying terms you must match.
But before you are even reviewed to qualify you must be prioritized and that means you must have your FEMA inspection meet the major to severe damage category.
HUD CDBG-DR program policy: FEMA inspected real property damage levels Major to Severe requirements.
Each of the FEMA inspected owner units are categorized by HUD into one of five categories:
To meet the statutory requirement of "most impacted" in this legislative language, homes are determined to have a high level of damage if they have damage of "major-low" or higher. That is, they have a FEMA inspected real property damage of $8,000 or above, personal property damage $3,500 or above, or flooding 1 foot or above on the first floor.
Your state most likely will drop the options that HUD training identifies as alternatives for FEMA damage inspections. Louisiana drop all previously used damage assistance and only is accepting FEMA inspected real property damage reports. The state of Louisiana is aware that during the years 2020-2022 that most inspections were not completed by FEMA and many homeowners who received Individual Assistance (IA) did not request or were not aware they needed to request a home damage inspection.
Now that you have all the information needed to justify asking FEMA for another inspection let's get it done and I'll share with you what I did to get inspections scheduled.
If you are the homeowner and you created an account at disasterassistance.gov then you should either call or email FEMA and request a inspection if you only were awarded IA grants and if you were awarded IHP or Repair Grants that did not cover the repair costs you should ask for another interior and exterior inspection by an official FEMA inspector. Keep in mind you are not filing an appeal you are asking for a new inspection and stating that no inspection was completed by a FEMA inspector for the interior and/or exterior of the home. FEMA will have the records if your inspection was conducted over the phone. If you did have an inspection onsite for both interior and exterior then you should appeal but first ask for a new inspection.
Request an inspection:
You can call 1-800-621-3362.
You can email: ihphelpdesk@fema.dhs.gov
Sample Email to IHP Helpdesk
SUBJECT: Disaster Number [4611] [FULL NAME] [LAST 4 of SSN] [TELEPHONE]
Date: [TODAY's DATE]
Full name: [YOUR NAME AS IT APPEARS ON LETTERS AND EMAILS FROM FEMA]
Impacted property address: [DAMAGED PROPERTY ADDRESS]
Mailing address: [MAILING ADDRESS IF DIFFERENT]
RE: Disaster Number [4611] [FULL NAME] [LAST 4 of SSN] [TELEPHONE]
Hello IHP Helpdesk:
I would like to request a FEMA inspection of both exterior and interior damage caused by the declared disaster [enter disaster type, name and identifier. Example, Hurricane Ida, DR-4611]. I understand FEMA did not do interior and/or exterior inspections due to CDC and FEMA policy. I am requesting an in person exterior and interior inspection by FEMA.
You can email me at [enter email address that is associated with your account] or call [telephone associated with the account].
Thank you,
[FULL NAME]
[DISASTER Number]
[FEMA Application Number]
[Registered Address]
Research Resource: