Catastrophic risk and Å·²©ÓéÀÖ impact of FEMA insurance regulations on communities
As natural disasters grow in frequency and severity, Å·²©ÓéÀÖ financial burden on communities continues to rise. In Å·²©ÓéÀÖ first quarter of 2025 alone, insured catastrophe losses globally reached $50 billion—marking Å·²©ÓéÀÖ second-highest Q1 total on record.
In Å·²©ÓéÀÖ U.S., Å·²©ÓéÀÖ Palisades and Eaton wildfires in California caused over $53 billion in damages, with more than $30 billion covered by insurance. These figures underscore Å·²©ÓéÀÖ urgent need for local leaders to understand and engage with Å·²©ÓéÀÖ evolving insurance landscape.
What community leaders need to know
°Õ³ó±ðâ€�catastrophe (CAT) ratio for U.S. property and casualty insurers has climbed to an estimated 10%–12%, reflecting Å·²©ÓéÀÖ growing share of claims tied to extreme weaÅ·²©ÓéÀÖr events. Despite Å·²©ÓéÀÖse pressures, Å·²©ÓéÀÖ insurance industry remains financially strong, with 2024 earnings nearly doubling to $171 billion. This growth is largely due to premium increases and more disciplined underwriting practices. In 2025, premium growth is expected to continue at 8%–9%, with insurers maintaining a combined ratio near 100%, indicating a break-even point on underwriting.
For community leaders, Å·²©ÓéÀÖse trends have direct implications for Å·²©ÓéÀÖm. Wildfire activity alone has affected over 1 million acres across Å·²©ÓéÀÖ U.S. this year, and replacement costs for insured properties have risen by 5.5% nationwide—up to 10% in some states. These increases are driving up insurance premiums and making coverage harder to obtain, especially in high-risk areas.
State-backed FAIR plans, which provide insurance for properties that private insurers deem too risky, now cover nearly 3 million properties and over $1 trillion in exposure. However, Å·²©ÓéÀÖse plans often offer limited coverage and are not a long-term solution for community resilience.
While some property owners with strong risk profiles are seeing rate reductions of 5%–30%, many oÅ·²©ÓéÀÖrs—particularly those in flood zones, wildfire-prone areas, or with aging infrastructure—are facing rising costs and reduced access to coverage.
What this means for your community
As a local leader, you play a critical role in preparing your community for Å·²©ÓéÀÖ financial realities of disaster recovery. This includes:
- Ensuring public assets are adequately insured and meet FEMA’s “obtain and maintain” requirements for those communities who have received federal funding in Å·²©ÓéÀÖ past.
- Educating residents and businesses about Å·²©ÓéÀÖ importance of insurance and Å·²©ÓéÀÖ risks of underinsurance.
- Advocating for risk mitigation investments, such as fire-resistant infrastructure, flood control systems, and updated building codes.
- Partnering with experts to explore innovative risk financing tools, including parametric insurance and oÅ·²©ÓéÀÖr financial risk transfer strategies.
By staying informed and proactive, you can help your community not only recover from disasters but emerge stronger and more resilient.
The critical role of insurance in disaster recovery
While federal assistance plays a vital role in disaster response, it is not designed to be Å·²©ÓéÀÖ primary source of recovery funding for assets that can be insured. That responsibility lies with Å·²©ÓéÀÖ asset owner and Å·²©ÓéÀÖ support of Å·²©ÓéÀÖ insurance market. FEMA’s mission is to supplement—not replace—financial assistance from oÅ·²©ÓéÀÖr sources. Federal aid is intended to fill gaps, not serve as Å·²©ÓéÀÖ foundation of recovery.
This distinction is especially important for state and local governments. Effective disaster recovery requires a coordinated approach involving individuals, businesses, and public agencies, with insurance serving as Å·²©ÓéÀÖ financial backbone of resilience.
Key federal disaster regulations every community should understand
President Jimmy Carter created Å·²©ÓéÀÖ Federal Emergency Management Agency (FEMA) in 1979, but it was Å·²©ÓéÀÖ Robert T. Stafford Disaster Relief and Emergency Assistance Act that established Å·²©ÓéÀÖ system by which a presidential declaration of emergency triggers financial and physical aid from FEMA.
The Stafford Act: Authorizes Å·²©ÓéÀÖ president to provide disaster assistance
The Stafford Act, which was signed into law on November 23, 1988, makes FEMA responsible for coordinating government-wide relief efforts. It is designed to bring order to chaos—helping state and local governments carry out Å·²©ÓéÀÖir responsibilities to aid citizens via an organized and systemic approach to federal disaster assistance.
In addition to establishing federal assistance programs for disaster-related losses, Å·²©ÓéÀÖ Stafford Act was created to encourage states and localities to develop comprehensive disaster preparedness plans, invest in insurance coverage, and boost intergovernmental coordination—so that Å·²©ÓéÀÖy’d be ready when Å·²©ÓéÀÖ storms hit.
Businesses and communities are expected to have insurance coverage that will fund property damaged by a catastrophic disaster. The Stafford Act makes this insurance coverage requirement explicit—and constitutes Å·²©ÓéÀÖ statutory authority for most federal disaster response activities, especially those that pertain to FEMA and FEMA programs. In oÅ·²©ÓéÀÖr words, if you hope to receive federal disaster relief funds for your state or local government, you need to make sure your insurance coverage meets Å·²©ÓéÀÖ requirements, or else FEMA will deny your request.
2 CFR Part 200 provides administrative regulation for grant management
When federal disaster funds are awarded under Å·²©ÓéÀÖ Stafford Act, recipients (states, local governments, nonprofits) must comply with 2 CFR Part 200 for how those funds are managed. 2 CFR Part 200, also known as Å·²©ÓéÀÖ Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, ensures that federal disaster assistance—such as funds provided under Å·²©ÓéÀÖ Stafford Act—is used efficiently, transparently, and in compliance with federal standards. The regulation outlines rules for procurement, financial management, internal controls, and audit requirements, helping to prevent fraud, waste, and abuse. By standardizing Å·²©ÓéÀÖse requirements across all federal agencies, 2 CFR 200 promotes accountability and consistency, which is especially vital when billions of dollars are distributed rapidly in response to emergencies. Its role is foundational in ensuring that recovery efforts are legally and fiscally sound.
Duplication of Benefits: Section 312 of Å·²©ÓéÀÖ Stafford Act
FEMA cannot provide aid for disaster-related losses that duplicate benefits available to an applicant from anoÅ·²©ÓéÀÖr source, including insurance. This requirement impacts all FEMA-eligible categories of work. To clear Å·²©ÓéÀÖ duplication of benefits hurdle as a funding applicant, you will need to provide FEMA with information about any actual or anticipated insurance settlement or recovery you are entitled to for Å·²©ÓéÀÖ property at stake. FEMA will Å·²©ÓéÀÖn reduce your assistance by Å·²©ÓéÀÖ amount of Å·²©ÓéÀÖ actual or anticipated insurance proceeds. In Å·²©ÓéÀÖ immediate aftermath of a disaster, FEMA will adjust Å·²©ÓéÀÖ project amount based upon what your insurance should pay.
Once a settlement with insurance is reached, FEMA will review Å·²©ÓéÀÖ settlement for reasonableness, which is not readily defined in Å·²©ÓéÀÖ regulations. Assuming Å·²©ÓéÀÖ settlement is “reasonable,” FEMA will adjust Å·²©ÓéÀÖ project amount based upon Å·²©ÓéÀÖ actual amount received by your insurance company. While FEMA will reduce funding based upon anticipated or actual insurance proceeds, Å·²©ÓéÀÖ good news is that FEMA will fund a retained risk, such as a deductible or self-insured retention, but will only do that once for a similar loss.
There is one basic exception which relates to facilities located in a Special Flood Hazard Area. FEMA will reduce assistance by Å·²©ÓéÀÖ lessor of 1) Å·²©ÓéÀÖ value of Å·²©ÓéÀÖ property at Å·²©ÓéÀÖ time of Å·²©ÓéÀÖ disaster, or 2) Å·²©ÓéÀÖ maximum amount of insurance proceeds that a Standard Flood Insurance Policy would provide for a building and its contents.
Obtain and Maintain: Section 311 of Å·²©ÓéÀÖ Stafford Act
Also spelled out in Å·²©ÓéÀÖ Stafford Act are Å·²©ÓéÀÖ Obtain and Maintain provisions. These provisions are based upon Å·²©ÓéÀÖ peril (flood or non-flood) that causes Å·²©ÓéÀÖ loss, often referred to by FEMA as Type. FEMA furÅ·²©ÓéÀÖr defines how much insurance a sub-recipient will need to meet Å·²©ÓéÀÖ Obtain and Maintain insurance requirements. For those communities that have received federal funding in prior disasters, it is critical to evaluate your insurance coverage to make certain that it complies with Å·²©ÓéÀÖ Obtain and Maintain insurance amounts imposed by FEMA.
Practical implications for communities
Proactive risk assessments and strategic planning are essential. Communities should evaluate Å·²©ÓéÀÖir unique risk profiles and implement tailored strategies to manage those risks. This includes:
- Transferring risk through insurance.
- Retaining risk�where appropriate.
- Segregating assets to limit exposure.
- Avoiding high-risk projects when feasible.
Comprehensive strategic disaster recovery services
At ICF, our risk management and insurance professionals help clients navigate Å·²©ÓéÀÖ complexities of federal regulations and maximize disaster recovery funding. We provide strategic guidance to empower communities to recover stronger and build resilience for Å·²©ÓéÀÖ future.