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Homeowner appeals during the recovery process are inevitable, but project managers can take preventative measures and work with case managers to reduce the number of applicant appeals — saving the applicant, project manager and agency administrating the program a significant amount of time and stress.

IBTS has processed close to 2,500 homes for programs receiving funding from the the HUD’s Community Development Block Grant Disaster Recovery (CDBG-DR) program, and been able to mitigate nearly all homeowner appeals.

Below, IBTS Economic Development and Disaster Recovery (EDDR) Coordinator Erica Bueno and IBTS EDDR Team Leader Ian Diem provide their advice for how project managers can establish processes and procedures to manage the applicant scope of work and construction materials appeals process.

During disaster planning, conduct a staffing assessment to determine the support your agency will need.

• Have a plan for how you will meet staffing needs to process thousands of homeowner applications after a major disaster. Identify at least a skeleton staff, including positions such as lawyers, procurement specialists, auditors, administrative support staff and project management staff, among others.

Be prepared for homeowners to have unrealistic expectations about the funding they receive.

• Make sure the basic parameters and goals of the CDBG-DR program are clearly explained to homeowner applicants on day one. In particular, homeowners should know that the goal of the program is give them a decent, safe and sanitary place to live. This means that their preferred design and materials choices may not be allowed or covered under the program.
• Make policies and procedures public through town hall meetings, public forums, public services announcements and local and social media to explain the CDBG-DR process. Provide a clear explanation of the scope of work, the funding applicants will receive and the process moving forward.
• To avoid controversy and public backlash, apply program rules universally to all applications.

Require case managers to have all paperwork signed by the homeowner applicant in the pre-construction meeting.  

• Establish a policy that requires applicants to sign everything during the pre-construction meeting.
• Make sure case managers provide a clear explanation of the construction process to prevent applicants from signing on to things they don’t understand or don’t agree with.
• Consider developing a checklist of items case managers must review with homeowner applicants in the pre-construction meeting.

Promote change orders as an alternative to an appeal.  

• Instruct case managers to explain to homeowners that the scope of work is not set in stone and they can still submit change orders to make construction material changes once construction contractors are in the field. “It makes people more comfortable about not putting in an appeal,” Diem says.
• Change orders are much more likely to succeed, faster and a less-exhaustive process for all involved.

Develop an appeal form for case managers to use.

• Bueno suggests adapting a standard appeal form. “These work great because they allow homeowners to put complaints in their own words,” she says.
• The form must meet the specific needs and requirements of the disaster assistance program.
• Set clearly-defined parameters for the forms, including how they will be processed and time limits for submitting appeal forms.

Encourage case managers to handle appeals in-house before an applicant contacts the state or program administrator.  

• Case managers should explain to applicants that appeals are a last resort. If they submit an appeal, it will delay construction on their home, sometimes by several months.
• Whenever possible, see if you or the case manager can resolve the homeowner’s complaint before it goes to appeal.
  • Resolving complaints internally benefits applicants and the subrecipient helps you avoid appeal-related delays in closeout.
  • Give homeowners specific reasons regarding their complaint and the program. “Even if it’s copy and pasted from the rulebook, give them an answer,” says Bueno. “Spell it out and explain it to them, and let them know that sometimes rules are rules.”
• Common appeals requests that can be addressed in-house include:
  • Scope of work requests to repair damage that didn’t result from the storm. Homeowners should have  clear understanding from the start that CDBG-DR assistance only covers storm damage repairs.
  • Construction material appeals for items not on the approved list of construction materials. Most disaster assistance programs provide a list of approved materials – such as countertops or roofing materials – that can be used in the program.

Be prepared for applicants who know what can and cannot be done, but will fight it anyways.

• If necessary, assist case managers when they’re dealing with a difficult applicant.
• Encourage case managers to notify HUD, the state or other grantee when an applicant will be submitting an appeal. The goal is to alleviate the burden on the administering agency to make the process run smoother and more quickly for the community.

Explain to homeowner applicants that case managers are legally required to give them everything they are eligible for under the CDBG-DR program.

“It can help to tell applicants that case managers are legally obligated to give them everything the program allows them to have,” Diem says. “We are doing everything we legally can to help.”

Read more about the services IBTS provided as a subrecipient of the CDBG-DR program for Cleveland County, Oklahoma.