March 28, 2017

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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

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