FEMA Deductable Proposal Re-emerges
You may recall that this time last year, we filed a new
issue under 'things I didn't think I would advocate on' as I was preparing for
a career in education policy when AASA joined four other national organizations
in a letter to the Federal Emergency Management Agency (FEMA), responding to
its proposal to establish a deductible for its public assistance program. As
with many regulatory issues, we’re often playing “wack-a-mole” – just when we
think an issue is done, it pops right back up.
After receiving thousands of (mostly negative) comments last
year, they submitted a Supplemental Advance Notice of Proposed Rulemaking,
issuing clarifications on several points. However, despite the clarifications,
our objections still stand.
FEMA’s proposal is considering the establishment of a
disaster deductible, requiring a predetermined level of financial or other
commitment from a recipient (grantee) before FEMA would provide assistance
under the public assistance program when authorized by a Presidential major
disaster declaration. FEMA believes the deductible model would incentive
recipients to make meaningful improvements in disaster planning, fiscal
capacity for disaster response and recovery, and risk mitigation, while
contributing to more effective stewardship of taxpayer dollars.
AASA, in coordination with the Association of Educational
Services Agencies, the Association of School Business Officials International,
the National Rural Education Advocacy Consortium, and the National Rural Education
Association sent another response urging caution and restraint. The public
assistance program has historically been a federal program and this policy
would shift federal responsibility to the state and local level, arguably at a
time (post-disaster) that they can least afford it. Further, as sub-grantees,
school district's ability to receive FEMA disaster funds would be impacted by
their state's willingness/ability to meet or address the deductible. The groups
expressed concern that this proposal stands to disproportionately and
negatively impact the neediest.
Read FEMA's updated proposal
here.
Read the full letter here.