Experiences Gained: Documentation During Response and Recovery

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A stack of paperwork, organized into manila folders, stacked on a desk.

Paperwork is often the last thing people think of after a natural disaster, yet it’s one of the most important and complicated components of the disaster recovery process. Jurisdictions in the recovery process can be overwhelmed by the amount and specificity of documentation needed. But familiarizing staff with requirements and developing checklists during disaster planning can make the process easier.

“When these disasters happen, it’s controlled chaos and you have to document what is going on,” says Barry Burton, county commissioner of Orange County, Texas, which contracted with IBTS after a severe flooding event in March 2016. “FEMA says the three most important things you can do for them is documentation, documentation, documentation. Without that, any claims you make can be rejected.”

Much of the documentation for both FEMA and CDBG-DR funding must be obtained and managed in real-time. For example, emergency management teams should take photographs during the initial damage assessment, before flood waters recede or debris is removed. Requirements must be communicated with staff in the field in order to capture damage in its original state – as soon as repairs begin, the opportunity to document the damage has passed and localities risk losing funding.

“Take photographs of any kind of damage as soon as it happens,” Burton recommends. “Photographs of a flooded building after the water goes down are not appropriate evidence to [FEMA] that there was damage in that building. It doesn’t stop with a photo, it’s receipts, too – we were denied claims because of receipts.”

Homeowners must also provide proof of any out-of-pocket expenses for CDBG-DR grants. Erica Bueno, IBTS Coordinator who works closely with CDBG-DR sub-grantees, recommends that case managers stress to homeowners the importance of recording all expenses related to the disaster – from buying a tarp to replacing damaged windows. CDBG-DR grants can’t duplicate any assistance from insurance or FEMA, requiring that case managers submit documentation of all sources of funding and what it’s used for.

Failing to comply with documentation requirements can present major complications and even halt funding. Jurisdictions should expect and be prepared for HUD to come in and conduct audits to ensure that CDBG-DR grants are spent as intended.

“HUD likes all documentation presented in a certain way for their audits,” Bueno says. “Case managers should have a checklist for everything that needs to be gathered, especially for the income requirement.”

Because CDBG-DR grants are intended for low-income residents and communities, a significant amount of documentation must be collected from CDBG-DR sub-grantees to demonstrate income eligibility. Bueno recommends enrolling in a HUD training course to learn the ins-and-outs of the program before disaster hits and paperwork starts pouring in.

County and local governments without the capacity to provide enough case managers or keep sufficient documentation typically hire a third party, such as IBTS, to administer documentation throughout disaster recovery and ensure spending is compliant with funding requirements.

Regardless of the grant program, prioritized checklists developed in the planning phase can be one of the most useful tools to maximize funding and ensure that no documentation requirements are overlooked.

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