Having hung around some state emergency management agencies I know that some can be "touchy" about FEMA bypassing them and going directly to locals. I expect that is the issue, along with the fact that all the states have to administer the PA program.
Having said that, would you not want input from the widest possible audience? Good ideas can come from anywhere--even the local level. Hopefully some states are sending this down to their local jurisdictions to have them take a look at it and make recommendations. Lord knows that the word "streamlined" does not fit the PA program today!
If you have comments you could try several paths to get your ideas heard. One is send them to your Public Assistance office at your state department of emergency management. Another would be to send your thoughts to IAEM. While they are directly mentioned in the text below, coming from an association that represents "you" would be a good thing. Since NEMA represents the State Directors I don't think your comments would be processed without them sending them back to your state EM office.
See text below:
Recently FEMA has provided to NEMA an advisory about the Bottom Up Review initiative and detailed information regarding the review process. This has been submitted to ALL State Directors and is provided below:
FEMA has initiated a bottom up review (BUR) of the Public Assistance Program, which NEMA has been suggesting for years. The advisory below and the attached document provide detailed information regarding the review and the process. FEMA is inviting stakeholder input and NEMA wants to take full advantage of the opportunity to provide the State perspective. The word from FEMA is to "think out of the box". Everything is on the table. The Administrator is wide open to a total redesign of the PA Program. This is a golden opportunity for innovative thinking.
Specifically, FEMA is seeking input on the following:
1. How should FEMA redesign and streamline the PA Program to provide applicants the greatest flexibility possible in the recovery process while ensuring accountability for the use of taxpayer dollars and compliance with federal statutory requirements?
2. What are the appropriate/optimum roles and responsibilities of FEMA and other Federal agencies, as well as States, Tribes and local communities in a new PA program?
3. If given greater flexibility for the use of PA funding, would States and Tribes be willing to take on more responsibility for program administration; and if so, what would that role be, and what resources would be required to perform that role and meet the responsibilities effectively?
4. If FEMA were to advance funds earlier in the disaster process, what mechanisms would you suggest to do this within FEMA's current statutory authority?
5. If FEMA revamps the PA Program, would grantees and subgrantees prefer to have a fixed budget based on an estimate developed early in the disaster, or the actual cost reimbursement process that currently exists?
6. Can PA be better linked with other FEMA programs? If so, how?
7. What does FEMA need to do to ensure that the program is scalable to small, large and catastrophic disasters?
8. Are there aspects of the existing program that should remain unchanged?
The state review should be based on what is codified in law through the Stafford Act and not be limited to FEMA policy or regulation which may, in some cases, be a more narrow or rigid interpretation of the law than originally intended by Congress. This has been one of NEMA's complaints for the past 10 years is that FEMA unnecessarily limits assistance based on interpretation rather than legislative intent. We know that the Stafford Act was written very broadly so as to allow Presidential discretion.
We are asking each state to submit input to NEMA by April 27. Again, we're looking for innovative thinking and specific suggestions for ways to overhaul the PA Program so that it reflects the intent of the Stafford Act and most importantly, meets the needs of communities when recovering from disasters. We will compile and analyze all the state comments, develop a national response, vet it back through all the states, then submit to FEMA from NEMA. Feel free to share this with your state PA staff who can assist with your state response. Also, you are welcome to submit your comments directly to FEMA. Again, please submit comments to NEMA by April 27. Thank you!!
