START HERE –> THRESHOLD REQUIREMENTS FOR ALL CATEGORIES OF HOUSING ASSISTANCE

  1. Home must be located in a disaster declared county 
  1. Home uninhabitable, inaccessible due to disaster, or require repair 
    • FEMA inspection establishes requirements. 
  1. Must be US Citizen/LPR/Qualified Alien living in household
    • Can be minor if parent or guardian applying on child’s behalf  
    • IMMIGRATION IMPLICATIONS – detailed household information could be shared with the DHS/ICE (change from previous disasters) during application process; discuss with client
  1. The client must have insufficient or no insurance coverage; 
    • If client’s insurance proceeds are not timely, then they can seek FEMA assistance and repay FEMA their insurance proceeds. 

PROGRAM OVERVIEW

TEMPORARY HOUSING ASSISTANCE

Renters and Homeowners

  1. Temporary Sheltering Assistance

Direct payment from FEMA to Hotel via voucher (short-term assistance: usually 5-14 days but can be extended up to 6 months in 14 day intervals).

2. Rental Assistance

Covers rent only (can cover security deposit but does NOT cover utilities that are not included in rent). Lasts up to 18 months unless extended (recertification every 2-3 months). Can recertify with a declaration and explanation of continuing need; proof of pre-disaster rent and income; proof of post-disaster rent and income; proof of attempts to return to self-sufficiency; and permanent housing plan. 

Be aware of potential for miscommunication with this issue – applicants may not realize that FEMA inspector is asking whether they are willing to move TEMPORARILY and may indicate that they are unwilling to relocate even though they are seeking rental assistance.

3. Temporary Housing Units (“FEMA Trailer”) [Not counted toward max award cap] 

Can be supplied by FEMA (mobile homes, can be dorms on military bases, or rooms on cruise ships, etc.). Available if home is destroyed or uninhabitable and cannot use rental assistance due to housing shortage. Lasts up to 18 months (can be extended). 

HOME REPAIR ASSISTANCE

Homeowners Only

Money to make home habitable (safe, sanitary, functional); may include structural, foundation, water, sewage, heating, cooling but NO cosmetic repairs or improvements

HOME REPLACEMENT ASSISTANCE

Homeowners Only

Money to assist homeowner with cost of replacing a destroyed home – not intended to cover entire cost of home replacement or to return home to pre-disaster condition. Can be combined w/ SBA Disaster Loan to use as a down payment, but must be approved by Regional Administrator. 

COMMON DENIAL REASONS

Failure to Prove Occupancy 

  • WHAT DOES FEMA USUALLY REQUEST TO PROVE?
    • Driver’s license
  • HOW TO APPEAL:
    • Send sworn declaration with missing information
      • Utility bills – within 3 months prior to disaster 
      • Employer’s statement – within 3 months prior to disaster 
      • Copy of your lease or rent receipts – issued and date prior to the disaster and not expired at the time of the disaster 
      • Stand-alone Declaration – may be accepted as a last resort 

Applicant has Sufficient Insurance 

  • HOW TO APPEAL IF APPLICANT DOES NOT HAVE INSURANCE:
    • Send in a sworn declaration clarifying that applicant does not have insurance 
  • HOW TO APPEAL IF APPLICANT HAS INSURANCE BUT IT IS INSUFFICIENT:
    • Review policy and exclusions 
    • Identify the FEMA eligible losses that client has and insurance does not cover and submit declaration with substantiating documentation

Failure to Verify Ownership 

  • WHAT DOES FEMA REQUEST TO PROVE?
    • Deed, Contract for Deed or Mortgage Documents
    • INCLUDES FEMA QUASI-OWNERSHIP where client does not pay rent but pays for the maintenance OR property taxes 
  • HOW TO APPEAL:
    • Clarify FEMA’s issue (denial letter will not tell you) – applicant is spouse, etc. 
    • Send sworn declaration with missing information 
      • Any supporting documents showing applicant’s name tied to the property (Marriage License, Tax Receipts, etc.) 
      • May include notarized affidavits from third persons (legal owner of the home, family member, person who pays the property tax) 

Home is Safe to Occupy

  • HOW TO APPEAL:
    • Declaration explaining damage and other facts (if they have received some money, explain what client has done with the money) 
    • Contractor’s estimate (Your expert!) 
      • FEMA will call the contractor so they must be available to talk about estimate given [MOST IMPORTANT] 
      • Should be itemized 
      • Should say that damage was caused by the disaster 
    • Photos are not required, although may be helpful 
  • IMPORTANT ITEMS TO CONVEY TO CLIENT TO MANAGE EXPECTATIONS:
    • A “win” is getting a second inspection, not money AND final amount awarded may not match estimate

Shared Household Problems (Applicants from same housing unit but separate households)

  • HOW TO APPEAL:
    • File a declaration to show that the two households filing for relief are “roommates” (household members with an independent financial responsibility that are not dependents of each other and are not married, such as renters whose names are on the lease). 
    • If one member exhausted the money available for the whole unit, the second applicant may be out of luck.

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