The FEMA Review Council, established in January 2025, was tasked with evaluating and reforming the Federal Emergency Management Agency (FEMA). It aims to improve the agency’s efficiency in disaster response, reduce bureaucracy, and strengthen federal-state cooperation.
The Council has released its Final Report, dated May 7, 2026. The full meeting recording and the presentation can be reviewed online.
Public comments are now being accepted until June 8, 2026.  We encourage participation and submission of comments – please email comments to FEMAreviewcouncil@hq.dhs.gov with “Docket No. DHS-2025-0712” in the subject line. You can read FIRM’s public comment here.
COMPARISON OF FINAL REPORT TO DRAFT REPORT
The adopted Final Report is largely identical to the leaked Draft Final Report. However, the recommendation of “renaming FEMA” as “FEMA 2.0″ has been removed. Also, the recommendation that “FEMA remain housed within the U.S. Department of Homeland Security (DHS)” has been excluded. The Final Report is silent on whether FEMA should become a cabinet-level agency or be housed within a department. Rather than the Draft Report’s aim to “reduce overall staffing by approximately 50%,” the Final Report suggests that FEMA “conduct a strategic review of requirements to determine appropriate staffing levels and address a recent surge in headquarters-based personnel by rebalancing their headquarters vs. field personnel ratio.”
The current version affirms that “the transformed agency should shift training execution to states, expand and leverage existing successful partnerships, continue support of Emergency Management Assistance Compact agreements, empower states with expedited funding, and limit federal on-the-ground response to only incidents that exceed the capabilities and capacities of SLTT stakeholders.” The Council advises “rather than replacing successful programs, the future agency should double down on those with a proven track record of effective federal-state-local partnership.”
NATIONAL FLOOD INSURANCE PROGRAM REFORM
In the Final Report, recommendation #7 proposes to “Reform the National Flood Insurance Program (NFIP) for Financial Stability and Risk Resilience.” The Council has noted legislation will be required in order to implement most NFIP-related recommendations. Sub-recommendations, as copied from the report, include:
- Empower Communities (Better Land-Use Policies): Enhance NFIP participation standards administratively to support intuitive land use choices that result in predictable post-flood outcomes for communities. FEMA could explore ways to modernize the Community Rating System incentives to reward integration of property-level resilience activities; align floodplain standards with this proposal’s modernization of mapping data; and provide support to states to promote risk communication with local land-use planning.
- Modernize Risk Assessment (Update Risk Rating 2.0 & Improve Maps): The NFIP’s updated pricing methodology, Risk Rating 2.0, leveraged advanced technology and data sources to deliver fairer, more individualized rates, must continue to be implemented and updated based on better information and science…The program must also improve the accessibility, transparency, and quality of flood risk data and communication tools for all stakeholders.
- Implement Risk-Based Pricing & Actual Costs: A key to enabling the private market shift is to charge policyholders the actual costs of their policies. FEMA should continue to refine Risk Rating 2.0 implementation. The Council recommends exploring existing subsidies and working with Congress to address affordability challenges for select homeowners.
- Revise ‘Write Your Own’ Compensation: FEMA provides an expense allowance to Write Your Own (WYO) private insurance companies of roughly $1 billion annually to sell, write, and service standard flood insurance policies under the National Flood Insurance Program…The compensation methodology is dated and doesn’t reflect improvements in FEMA’s systems, automated premium pricing methodology, or the expanded use of the direct-to-customer servicing platform
- Shift to Private Market through Depopulation of Existing NFIP Policies: A core component of the solution is a gradual, structured transition of certain existing NFIP policies to the private market in areas where private capacity exists and are consistent with state regulatory frameworks. This would be accomplished by pursuing a voluntary “take-out” program, which would allow FEMA to assess the feasibility of transferring eligible policies to qualified private insurers under existing statutory authority.
- Evaluate Development of Flood Insurance Marketplace: To modernize and enhance the capacity of the national flood insurance system, it is recommended that FEMA evaluate the development of a flood insurance marketplace designed to provide consumers with access to both NFIP and qualified private insurance options when purchasing a new flood policy. The marketplace could leverage private sector capacity through a centralized clearinghouse model, allowing private participating insurers opportunity to offer coverage prior to placement with NFIP.
- Pricing Alignment: The marketplace’s pricing mechanism could reference FEMA’s Risk Rating 2.0 framework as an actuarial benchmark. In addition, the marketplace could encourage depopulation by requiring the insured to select a private flood insurance policy from a marketplace approved insurer that is priced at no more than 10 percent above the NFIP Risk Rating 2.0 actuarial rate for comparable coverage for the same property.
- Address Repetitive Loss Properties: Manage repetitive loss properties through targeted mitigation planning and accountability measures, such as those proposed in the “Repeatedly Flooded Communities Preparation Act” (S.1545). This legislation provides a structured plan to address the highest-risk properties and ensures mitigation is a priority in these areas, thereby reducing the financial burden of repeated claims.
- Reduce Duplicative ESA Burden on the NFIP: The Council recommends that National Marine Fisheries Service (NMFS) be directed to 1) rescind all Biological Opinions (BiOps) relating to FEMA’s implementation of the NFIP and 2) statutorily exempt the NFIP from the ESA. FEMA should focus on a national ESA solution for the NFIP through a renewed partnership with NMFS.
Again, please consider commenting on the Final Report by June 8, 2026.