Background The Robert T. Stafford Disaster Relief and Emergency Assistance Act  (Stafford Act), as amended, establishes the process for states or tribal  entities to request a presidential disaster declaration. The act also  generally defines the federal government’s role during the response and  recovery after a disaster and establishes the programs and process  through which the federal government provides disaster assistance to  state, local governments, tribal entities and individuals. In addition to its  central role in recommending to the President whether to declare a  disaster, FEMA has primary responsibility for coordinating the federal  response when a disaster is declared as well as recovery, which typically  consists of providing grants to assist state and tribal entities to alleviate  the damage resulting from such disasters. Once a disaster is declared,  FEMA provides assistance through the IA, Public Assistance, and Hazard  Mitigation Assistance programs. For instance, some declarations may  provide grants only for IA and others only for Public Assistance. Hazard  Mitigation Assistance grants, on the other hand, are available for all  declarations if the affected area has a FEMA-approved Hazard Mitigation  plan. The process for requesting assistance is the same for the three  types of assistance. Disaster Declaration  Process Under the Stafford Act, states’ governors or tribal chief executives may  request federal assistance, if state and tribal resources are overwhelmed  after a disaster. As part of the request to the President, a governor or  tribal chief executive must affirm that the state or tribe has implemented  an emergency plan and that the situation is of such severity and  magnitude that effective response is beyond the capabilities of the state  or tribal entity, among other things. After a state or tribe submits a request  for disaster declaration through FEMA’s regional office, the regional office  is to evaluate the request and make a regional recommendation through  the RVAR, which is submitted to FEMA headquarters for further review.  The FEMA administrator then is to review the state’s or tribe’s request  and the RVAR, and recommend to the President whether a disaster  declaration is warranted. Figure 1 shows the process for a disaster  declaration from the time a disaster occurs until the President approves or  denies a declaration request. Five Programs Available  under Individual  Assistance The IA program provides financial and direct assistance to disaster  victims for expenses and needs that cannot be met through other means,  such as insurance. The IA comprises five different programs as shown  below. When states or tribal entities request disaster declarations, they  may request assistance under any or all of the five programs. Likewise,  when the President makes a disaster declaration, the declaration may  authorize IA which may also include any or all of the five IA programs.  1.  Individuals and Households Program provides assistance to  eligible disaster survivors with necessary expenses and serious needs  which they are unable to meet through other means, such as  insurance. According to FEMA headquarter officials, direct  assistance is provided to individuals to meet housing needs.  2.  Crisis Counseling Program assists individuals and communities by  providing community-based outreach and psycho-educational  services.  3.  Disaster Legal Services provides assistance through an agreement  with the Young Lawyers Division of the American Bar Association for  free legal help to survivors who are unable to secure legal services  adequate to meet their disaster-related needs.  4.  Disaster Case Management Program involves a partnership  between a FEMA disaster case manager and a survivor to develop  and carry out a Disaster Recovery Plan.  5.  Disaster Unemployment Assistance provides unemployment  benefits and reemployment services to individuals who have become  unemployed as a result of a major disaster and who are not eligible  for regular state unemployment insurance. The Six IA Regulatory  Factors Used to Assess IA  Declaration Requests In accordance with its responsibilities under the Stafford Act, FEMA  issued a regulation in 1999 that outlines the six factors regional and  headquarters officials are to consider when assessing requests for a  disaster declaration and when developing a recommendation to the President for a federal disaster declaration. The regulation states that  FEMA considers the six factors not only to evaluate the need for IA but  also to measure the severity, magnitude, and impact of the disaster. The  state or tribe provides information on these factors when submitting its  disaster declaration request. The six factors for IA include the following:  1.  Concentration of Damages—characterizes the density of the  damage in individual communities. The regulation states that highly  concentrated damages “generally indicate a greater need for federal  assistance than widespread and scattered damages throughout a  state.” For example, concentration of damage data includes the  numbers of homes destroyed, homes with major or minor damages,  and homes affected.  2.  Trauma—the regulation provides conditions that might cause trauma  including large numbers of injuries and deaths, large-scale disruption  of normal community functions, and emergency needs such as  extended loss of power or water.  3.  Special Populations—FEMA considers the impact of the disaster on  special populations, such as low-income populations, the elderly, or  the unemployed.  4.  Voluntary Agency Assistance—involves the availability and  capabilities of voluntary, faith, and community-based organizations,  and state and local programs to help meet both the emergency and  recovery needs of individuals affected by disasters.  5.  Insurance Coverage—addresses the level of insurance coverage  among those affected by disasters. Because disaster assistance  cannot duplicate insurance coverage, as recognized in the regulation,  if a disaster occurred where almost all of the damaged dwellings were  fully insured for the damage that was sustained, FEMA could  conclude that a disaster declaration by the President was not  necessary in accordance with this factor.  6.  Average Amount of Individual Assistance by State—according to  the regulation, there is no set threshold for recommending IA.  However, it states that the averages, depicted in table 1, may prove  useful to states and voluntary agencies as they develop plans and  programs to meet the needs of disaster victims. The inference is that  these averages generally indicate the amount of damages that could  be expected for a state based on its size (small, medium, and large).  The averages contained within the regulation and depicted in table 1  are based on disasters that occurred between July of 1994 and July of  1999. The President  Declared 57 Percent  of All IA Requests  from 2008 through  2016, with Total  Obligations of  Approximately $8.6  Billion The Number of IA  Declarations Varied by  Region and Severe  Storms Were the Most  Frequent Disaster Type The President declared 57 percent of all IA declaration requests from  calendars years 2008 through 2016, with total IA obligations of  approximately $8.6 billion. FEMA received 294 IA declaration requests  from calendar years 2008 through 2016. Of these, the President declared  168 requests (57 percent), and 51 percent of these declarations were  from Regions IV and VI, as shown in table 2. Additionally, of the 126 IA declaration requests denied by the President,  Regions X and IX had the highest percentage of denials, at 71 percent  (10 out of 14) and 67 percent (12 out of 18), respectively, and Region I  had the lowest percentage of denials at 13 percent (2 out of 15), as  shown in table 3. See appendix I for the number of IA declarations  requested, declared, and denied by states and tribes from each FEMA  region for disaster declarations requested from calendar years 2008  through 2016. According to a FEMA headquarters official, when a disaster declaration is  denied, FEMA sends a denial letter to states or tribes based on the  review of all the information available. The letter generally states that the  damage was not of such severity and magnitude as to be beyond the  capabilities of the state, affected local governments, and voluntary  agencies, and accordingly the supplemental federal assistance is not  necessary. Of the emergency management officials we interviewed in 11  states, officials in five states reported that FEMA provided a rationale  behind the denial, while officials in three states reported that no rationale  was provided. Among the various types of disasters for which IA declaration requests  were received, severe storms, flooding, and tornados accounted for the  highest number of IA requests, with drought, fishery closure, and  contaminated water being the least common, as shown in table 4. FEMA IA Obligations  Varied by Region and  State FEMA obligated a total of approximately $8.6 billion in IA for disaster  declarations made from calendar years 2008 through 2016. These actual  obligations were provided to 46 states and they ranged from less than $1  million to more than $1 billion as shown in figure 2. See appendix II for  FEMA’s IA actual obligations by state and type of disasters for disaster  declarations made from calendars years 2008 through 2016. Additionally, actual obligations for IA declarations made from calendar  years 2008 through 2016 varied greatly by FEMA region, as also shown  in figure 3. For example, FEMA Region VI had the highest obligations at  around $3.3 billion. Region X had the lowest obligations at $24.8 million.  As shown in table 5, the amount of obligations for disasters declarations  also varied greatly by state. For example, Louisiana had the highest  obligations at approximately $2 billion, followed by New York and Texas  at about $1.3 billion and $1.1 billion, respectively. The state with the  lowest obligations was the U.S. Virgin Islands at about $2,100. FEMA Regions Varied  in How They  Considered IA  Regulatory Factors  and Did Not  Consistently Obtain  and Document  Information on All  Elements of These  Factors FEMA Regions Varied in  Their Consideration of the  IA Regulatory Factors  Based on Disaster  Circumstances Six of FEMA’s 10 regional offices reported using all six regulatory factors  when evaluating states’ or tribes’ IA declaration requests. Officials from  the other 4 regions reported using five of the six factors, with the  exception being the average amount of individual assistance by state  factor. These officials noted that they do not use this factor because  FEMA considers the factor to be outdated or they consider all of the  factors holistically. Officials from FEMA’s regional offices also generally reported that the  extent to which they consider the six IA regulatory factors equally in all  cases varies, depending on the circumstances of the related disaster.  Specifically, officials from 7 of the 10 regions stated that they use the  regulatory factors on a case-by-case basis as certain factors are more  relevant than others based on the disaster. For example, if a tornado hits  a rural community and completely destroys all properties within the  community with no death or injury, then the regulatory factor for trauma  may not be as applicable, while the concentration of damages regulatory  factor would have greater relevance. On the other hand, if a tornado hits  the center of a town resulting in damages with death and injuries, then the  trauma regulatory factor would become more important to consider. Additionally, officials in 3 of the 10 regions reported that in addition to the  six regulatory factors, they also take into account institutional knowledge  and staff experience when evaluating the regulatory factors. For example,  officials in one region stated that their staff have more than 10 years of IA  declaration experience, and as such, they are familiar with the extent of  the information needed and collect the information accordingly. FEMA Regions Did Not  Consistently Obtain and  Document Information on  All Elements of the IA  Regulatory Factors in  RVARs Based on our analysis of RVARs from July 2012 through December 2016  used to recommend approving or denying IA requests, FEMA regional  offices did not consistently obtain and document information on all  elements of the IA regulatory factors. As described earlier, FEMA regions  are to use the RVAR to document information on the IA factors and to  recommend to the FEMA administrator whether a disaster should be  declared. According to FEMA headquarters officials, FEMA developed the RVAR  template in June 2012 to help ensure consistency across regions when  making recommendations to headquarters on IA declaration requests.  Officials stated that prior to the template, information on the six factors  was mainly provided in narrative format. The new template listed the  various elements found within each of the six regulatory factors, guiding  the regional offices to provide information based on those elements. For  example, instead of providing a general narrative on the trauma factor,  the new template listed the elements to be provided under trauma, such  as the number of injuries and deaths, as well as information on power  outages and disruption of other community functions and services. Also,  instead of summarizing the concentration of damages factor, the template  allowed regional offices to categorize the damage concentration as low,  medium, high, or extreme. Furthermore, the template also provided a  uniform format to present quantitative information such as the number of  homes destroyed; whether home damages are major or minor; the  number of homes affected; and level of home ownership. See appendix III  for a sample RVAR template. We analyzed 81 RVARs developed by the 10 FEMA regions from July  2012 through December 2016 and found that regions did not consistently  obtain and document information on all elements related to each of the  six regulatory factors in their RVARs. As shown in table 6, all 81 RVARs  had at least some elements documented but not all for each of the IA  regulatory factors. For example, for the IA concentration of damages  regulatory factor, the six elements to be addressed include the number of  homes destroyed, damaged or affected, damage concentration, and  damage to critical facilities. While 44 of the 81 RVARs documented all of  the six elements, 37 documented some but not all of the elements.  Similarly, for the trauma regulatory factor, the four elements to be  addressed include injuries, death, power outages, and disruption of  community functions. While 30 of the 81 RVARs documented all of the  four elements, 51 documented some but not all of the elements. For the  insurance coverage factor, while five RVARs documented all of the  elements, 73 RVARs documented some but not all of the elements.  Elements under this factor include home ownership, insurance, and flood  insurance, when applicable. None of the six regulatory factors were fully  documented across all RVARs. See appendix IV for detailed information  on the extent to which all of the elements of the six regulatory factors  were documented in the RVARs from July 2012 through December 2016. FEMA headquarters officials acknowledged that information related to all  the elements for each of the IA regulatory factors were missing from the  RVARs. They stated that they had not collected all information on all  factors because one factor may have more weight than another based on  the specific incident that has occurred. However, they also indicated that  they do not fully know and have not evaluated all of the reasons why a  region may have omitted information on an element of a factor. FEMA  headquarters officials agreed that having complete information on all  elements of the regulatory factors in the RVARs would assist in their  recommendation process. Standards for Internal Control in the Federal Government suggest that  agencies should establish and operate monitoring activities to ensure that  internal controls—such as the documentation of all of the elements of the  IA regulatory factors FEMA regions considered—are effective, and to take  corrective actions as appropriate. Because it is unclear why regions are  not completely documenting all elements related to the current six  regulatory factors, such an evaluation could help FEMA identify whether  any corrective steps are needed. Doing so could help FEMA ensure it is  achieving its stated goals in providing consistency in the evaluation  process and in the types of factors it considers. FEMA and States  Reported Challenges  in the IA Declaration  Process, and FEMA  Is Revising the  Regulatory Factors  Used to Assess  Declaration Requests FEMA and State Officials  Reported Both Positive  Relationships and Some  Challenges in the IA  Declaration Process Officials we interviewed in 9 of the 10 FEMA regions and state  emergency management offices in all 11 states reported the positive  relationship they maintain with each other as a strength in the IA  declaration process. For example, both FEMA regional officials and  state emergency management officials stated that they have a good  working relationship and are in regular communication via telephone or  in-person meetings with each other. Also, state emergency management  officials we spoke to stated that whenever they are in need of assistance,  they know they can reach out to FEMA regional officials for assistance.  However, FEMA regional and state emergency management officials we  spoke to also reported various challenges with the process. These  include the subjective nature of the IA regulatory factors given the lack of  eligibility thresholds, the lack of transparency in the decision-making  process, and difficulty gathering information on IA regulatory factors. Subjective nature of the IA factors and lack of eligibility thresholds.  Officials from 9 of 10 FEMA regions stated the subjective nature of the IA  program is a challenge; and officials in 6 of the 10 regions also said they  found the lack of eligibility thresholds a challenge. An official in one region  stated that unlike FEMA’s Public Assistance program, which has  minimum thresholds for eligibility, it is unclear when states should apply  for IA funds. Under the Public Assistance program, for example, for states  or tribes to qualify for assistance, they must demonstrate that they have  sustained a minimum of $1 million in damages and the impact of  damages must amount to $1.00 per capita in the state. An official in  another region explained that although the subjectivity of the IA factors  provides flexibility in determining the type of IA program needed, having  some quantifiable criteria could help officials explain to states why their  requests were denied or approved. Similarly, officials we interviewed in 7 of the 11 states said they found the  subjective nature of the factors with no threshold to be a challenge. A  state emergency management official in one state said this subjectivity  makes it difficult to determine whether or not the state should make an IA  request. A state emergency management official in another state reported  that the subjectivity can cause the IA declaration process to be  inconsistent, and it is not always clear how or why certain declarations  were approved and others were not. Further, a state emergency  management official in an additional state also pointed to the subjective  nature of the factors with no threshold as a reason for not being able to  provide a more detailed rationale behind a declaration denial. To illustrate this, table 7 shows how four states requested IA declarations  related to the same tornado in 2012 and varied in what they reported  across the six IA factors, such as the levels of damages incurred, special  populations among their residents, and insurance coverage. Two of these  four states—Kentucky and Indiana—received IA declarations and the  other two—Ohio and Illinois—were denied. Lack of transparency. Another challenge reported by FEMA regional  and state emergency management officials was the lack of transparency  in how FEMA evaluates and provides a recommendation to the President  on whether a declaration is warranted. For example, officials we  interviewed in 4 of 10 regions indicated the lack of transparency as a  challenge. A FEMA official in one region stated that the region would like  more transparency regarding what FEMA headquarters recommends to  the President and whether the President’s decision aligns with FEMA’s  recommendation. State emergency management officials we interviewed  in 10 of 11 states also reported that lack of transparency with the IA  process is a challenge. For example, an emergency management official  in one state said it is not clear how or if FEMA considers all of the factors.  Also, an emergency management official in another state reported that it  was unclear to him why his state’s declaration request was denied while  the requests of other states with similar incidents were declared. Difficulty gathering information on IA regulatory factors. Officials in 4  of 10 FEMA regions reported difficulty gathering information, such as  income or insurance coverage, as a challenge. An official in one region  stated that it is difficult to obtain information related to IA factors from  states. For example, the official said that calculating the concentration of  damages is difficult absent technical guidance from FEMA headquarters,  as the current guidance only accounts for the number of structure  damage but not the impact of damage. Further, officials in two FEMA  regions stated that states lack a dedicated IA official, making it difficult for  state officials, who play multiple roles, to provide the necessary  information related to the IA factors in their IA declaration request.  Additionally, a state emergency management official in one state also  reported that lack of staff resources in her state makes it difficult to verify  all the local damage assessments prior to making a declaration request. FEMA Is Taking Steps to  Revise the IA Regulatory  Factors Pursuant to the Sandy Recovery Improvement Act of 2013, in November  2015, FEMA issued a Notice of Proposed Rulemaking to revise the six  current IA regulatory factors to the following proposed factors:  state fiscal capacity and resource availability; uninsured home and personal property losses; disaster-impacted population profile;  impact to community infrastructure;  casualties; and disaster-related unemployment. According to FEMA headquarters officials, the revisions aim to provide  more objective criteria, clarify the threshold for eligibility, and speed the  declaration. The officials said the proposed rule also seeks to provide  additional clarity and guidance for all the established factors. Table 8  shows FEMA’s description of current and proposed IA factors. FEMA received public comments from 14 states in the Federal Register  during the comment period for the proposed rule and proposed  guidance. The 14 states expressed concern about the proposed factor  for state fiscal capacity and resource availability, including the reliability  and relevance of data sources such as total taxable resources. These  states expressed concern that the data collection necessary to meet the  new requirements would fall upon them, adding to the cost burden of  completing an IA disaster declaration request. They also explained that  the use of total taxable resources and other similar data is not an effective  way to assess a state’s current ability to provide resources following a  disaster. Also, these states indicated that the data points such as total  taxable resources and per capita personal income that would be used to  evaluate state fiscal capacity are outdated and inaccurate and would be  an inefficient way to evaluate a state’s true fiscal capacity to respond to a  disaster. Regarding the other five proposed factors, several states in their  comments raised questions about ambiguities in interpreting the factors  or the feasibility and cost of gathering related data. For example, in  regards to the factor on disaster impacted population, five states  expressed concern that the data required for the disaster-impacted  population factor would be a cost burden to the state or that the data  would be inappropriate for evaluation. Additionally, two states said  unemployment related to a disaster incident for the disaster-related  unemployment factor would be hard to quantify in the first 30 days  following a disaster. They stated that this was especially an issue given  that states work to submit an IA disaster declaration request as soon as  possible following a disaster. According to the Office of Management and Budget’s Office of  Information and Regulatory Affairs website, the projected date for  finalization of the proposed rule is September 2018; however, as of April  2018, FEMA officials stated that they were not certain whether that  timeframe would be met. Until the proposed rule is finalized, we will not  know the extent to which the various challenges FEMA regions and state  officials raised in our interviews and in comments on the proposed rule  will be addressed. Conclusions FEMA has obligated over $8.6 billion nationwide in IA from calendar  years 2008 through 2016, highlighting the importance of FEMA’s  evaluation of states’ and tribes’ IA declaration requests. FEMA’s regional  offices evaluate the request and make a regional recommendation  through the Regional Administrator’s Validation and Recommendation,  which documents information on all relevant IA regulatory factors. FEMA  has developed the Regional Administrator’s Validation and  Recommendation to ensure regions consistently obtain and document the  information needed by FEMA to make a disaster declaration  recommendation to the President based on the IA regulatory factors.  However, FEMA’s regional offices do not consistently obtain and  document information on all elements of the current IA regulatory factors.  Because it is unclear why regions are not always documenting all of the  elements related to these factors, evaluating the reasons why could help  FEMA identify if any corrective steps are needed. Doing so could also  help FEMA ensure it is meeting its stated goals in providing consistency  in the evaluation process and in the types of factors it considers. Recommendation for  Executive Action We recommend that the Administrator of FEMA evaluate why regions are  not completing the Regional Administrator’s Validation and  Recommendations for each element of the current IA regulatory factors  and take corrective steps, if necessary. Agency Comments  and Our Evaluation We provided a draft of this report to DHS for its review and comment.  DHS provided written comments, which are summarized below and  reproduced in full in appendix V. DHS concurred with the  recommendation and described planned actions to address it. In addition,  DHS provided written technical comments, which we incorporated into the  report as appropriate. DHS concurred with our recommendation that FEMA evaluate why  regions are not completing the Regional Administrator’s Validation and  Recommendations for each element of the IA regulatory factors and take  corrective steps, if necessary. DHS stated that a FEMA working group  consisting of headquarters stakeholders will draft survey questions for  FEMA region officials to identify the common reasons why an element of  an IA regulatory factor may not be addressed within a RVAR. According  to DHS, the working group will also analyze, assess, and present the  findings of the survey responses to FEMA senior leadership, and if  needed, FEMA will develop and send a memorandum to the regions with  additional guidance regarding the appropriate preparation of RVARs.  DHS stated that the estimated completion date is in the fall of 2018.  These actions, if implemented effectively, should address the intent of our  recommendation. We will send copies of this report to the Secretary of Homeland Security,  the FEMA Administrator, and the appropriate congressional committees. If you or your staff have any questions about this report, please contact  me at (404) 679-1875 or curriec@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. Key contributors to this report are listed in appendix  VI. Appendix I: Individual Assistance  Declarations Requested, Declared, and  Denied, Calendar Years 2008-2016 Table 9 provides the total number of Individual Assistance declaration  requests made, declared, and denied, by region, state, and tribe for  disaster declarations requested from calendar years 2008 through 2016. Appendix II: Individual Assistance Actual  Obligations for Declarations Made,  Calendars Years 2008-2016 Table 10 provides Federal Emergency Management Agency’s (FEMA)  Individual Assistance (IA) actual obligations for declarations made from  calendar years 2008 through 2016 by state and type of disaster. Appendix III: Regional Administrator’s  Validation and Recommendation Template As part of the Federal Emergency Management Agency’s (FEMA)  declaration process, FEMA’s regional offices are to evaluate states’ or  tribes’ declaration requests, including the IA declaration request, and  make a recommendation called the Regional Administrator’s Validation  and Recommendation (RVAR) and submit the RVAR to FEMA  headquarters. In June 2012, FEMA headquarters issued a template for  FEMA regional offices to use in developing the RVAR as identified in  figure 3. Appendix IV: Information on the Elements of  the Six Individual Assistance Regulatory  Factors Tables 11 through 16 provide information on each element of the 6  Individual Assistance (IA) regulatory factors documented in the Regional  Administrator’s Validation and Recommendation (RVAR) from July 2012  through December 2016 by the Federal Emergency Management Agency  region. Appendix V: Comments from the Department  of Homeland Security Appendix VI: GAO Contact and Staff  Acknowledgments GAO Contact Staff  Acknowledgments In addition to the contact named above, Aditi Archer (Assistant Director),  Su Jin Yon (Analyst-In-Charge), Hiwotte Amare, Eric Hauswirth, Susan  Hsu, Jun S. (Joyce) Kang, Christopher Keisling, Heidi Nielson, Hadley  Nobles, Anne Rhodes-Kline, and Jerome (Jerry) Sandau made significant  contributions to this report.
FEMA's IA program provides help to individuals to meet their immediate needs after a disaster, such as shelter and medical expenses. When a state, U.S. territory, or tribe requests IA assistance through a federal disaster declaration, FEMA evaluates the request against regulatory factors, such as concentration of damages, and provides a recommendation to the President, who makes a final declaration decision. GAO was asked to review FEMA's IA declaration process. This report examines (1) the number of IA declaration requests received, declared, and denied, and IA actual obligations from calendar years 2008 through 2016, (2) the extent to which FEMA accounts for the regulatory factors when evaluating IA requests, and (3) any challenges FEMA regions and select states reported on the declaration process and factors and any FEMA actions to revise them. GAO reviewed FEMA's policies, IA declaration requests and obligation data, and FEMA's RVARs from July 2012 through December 2016, the most recent years for which data were available. GAO also reviewed proposed rulemaking comments and interviewed FEMA officials from all 10 regions and 11 state emergency management offices selected based on declaration requests and other factors. From calendar years 2008 through 2016, the Department of Homeland Security's (DHS) Federal Emergency and Management Agency (FEMA) received 294 Individual Assistance (IA) declaration requests from states, U.S. territories, and tribes to help individuals meet their immediate needs after a disaster. Of these, the President declared 168 and denied 126 requests. Across the various types of IA declaration requests, severe storms (190) were the most common disaster type and drought (1) was among the least common. FEMA obligated about $8.6 billion in IA for disaster declarations during this period. GAO found that FEMA regions did not consistently obtain and document information on all elements of established IA regulatory factors when making IA recommendations to headquarters. Following a declaration request, a FEMA region is to prepare a Regional Administrator's Validation and Recommendation (RVAR)—a document designed to include data on each of the six IA regulatory factors for each declaration request as well as the regional administrator's recommendation. GAO reviewed all 81 RVARs from July 2012—the date FEMA began using the new RVAR template—through December 2016. GAO found that regions did not consistently obtain and document information for the elements required under the six regulatory factors (see table). For example, only 44 of the 81 RVARs documented all elements under the concentration of damage factor. By evaluating why regions are not completing all elements of each current IA regulatory factor, FEMA could identify whether any corrective steps are needed. Officials from the 10 FEMA regions and 11 states GAO interviewed, reported positive relationships with each other, but also cited various challenges with the IA declaration process and regulatory factors. For example, these officials told GAO that there are no established minimum thresholds for IA, making final determinations more subjective and the rationale behind denials unclear. However, as required by the Sandy Recovery Improvement Act of 2013, FEMA has taken steps to revise the IA factors by issuing a notice of proposed rulemaking. According to FEMA, the proposed rule aims to provide more objective criteria, clarify the threshold for eligibility, and speed up the IA declaration process. As of April 2018, the proposed rule was still under consideration. According to FEMA officials, they plan to finalize the rule in late 2018; therefore, it is too early to know the extent to which it will address these challenges.