Flood Insurance

Public Policy Goals Provide a Framework for Reform Gao ID: GAO-11-670T June 23, 2011

The National Flood Insurance Program (NFIP) has been on GAO's high-risk list since 2006, when the program had to borrow from the U.S. Treasury to cover losses from the 2005 hurricanes. The outstanding debt is $17.8 billion as of June 2011. This sizeable debt, plus operational and management challenges that GAO has identified at the Federal Emergency Management Agency (FEMA), which administers NFIP, have combined to keep the program on the high-risk list. NFIP's need to borrow to cover claims in years of catastrophic flooding has raised concerns about the program's long-term financial solvency. This testimony (1) discusses ways to place NFIP on a sounder financial footing in light of public policy goals for federal involvement in natural catastrophe insurance and (2) highlights operational and management challenges at FEMA that affect the program. In preparing this statement, GAO relied on its past work on NFIP, including a June 2011 report on FEMA's management of NFIP, which focused on its planning, policies, processes, and systems. The management review included areas such as strategic and human capital planning, acquisition management, and intra-agency collaboration.

Congressional action is needed to increase the financial stability of NFIP and limit taxpayer exposure. GAO previously identified four public policy goals that can provide a framework for crafting or evaluating proposals to reform NFIP. These goals are: (1) charging premium rates that fully reflect risks, (2) limiting costs to taxpayers before and after a disaster, (3) encouraging broad participation in the program, and (4) encouraging private markets to provide flood insurance. Successfully reforming NFIP would require trade-offs among these often competing goals. For example, nearly one in four policyholders does not pay full-risk rates, and many pay a lower subsidized or "grandfathered" rate. Reducing or eliminating less than full-risk rates would decrease costs to taxpayers but substantially increase costs for many policyholders, some of whom might leave the program, potentially increasing postdisaster federal assistance. However, these trade-offs could be mitigated by providing assistance only to those who need it, limiting postdisaster assistance for flooding, and phasing in premium rates that fully reflect risks. Increasing mitigation efforts to reduce the probability and severity of flood damage would also reduce flood claims in the long term but would have significant up-front costs that might require federal assistance. One way to address this trade-off would be to better ensure that current mitigation programs are effective and efficient. Encouraging broad participation in the program could be achieved by expanding mandatory purchase requirements or increasing targeted outreach to help diversify the risk pool. Such efforts could help keep rates relatively low and reduce NFIP's exposure but would have to be effectively managed to help ensure that outreach efforts are broadly based. Encouraging private markets is the most difficult challenge because virtually no private market for flood insurance exists for most residential and commercial properties. FEMA's ongoing efforts to explore alternative structures may provide ideas that could be evaluated and considered. Several operational and management issues also limit FEMA's progress in addressing NFIP's challenges, and continued action by FEMA will be needed to help ensure the stability of the program. For example, in numerous past reports, GAO identified weaknesses in areas that include financial controls and oversight of private insurers and contractors, and made many recommendations to address them. While FEMA has made progress in addressing some areas, GAO's June 2011 report identified a number of management challenges facing the program, including strategic and human capital planning, records management, collaboration among offices, and financial and acquisition management. In this report, we also made a number of recommendations to address these challenges. FEMA agreed with the recommendations and discussed the steps being taken to address some of them. GAO has made numerous recommendations aimed at improving financial controls, oversight of private insurers and contractors, and FEMA's management of NFIP. DHS generally agreed with our recommendations.

GAO-11-670T, Flood Insurance: Public Policy Goals Provide a Framework for Reform This is the accessible text file for GAO report number GAO-11-670T entitled 'Flood Insurance: Public Policy Goals Provide a Framework for Reform' which was released on June 23, 2011. This text file was formatted by the U.S. Government Accountability Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products' accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. The portable document format (PDF) file is an exact electronic replica of the printed version. We welcome your feedback. Please E-mail your comments regarding the contents or accessibility features of this document to Webmaster@gao.gov. This is a work of the U.S. government and is not subject to copyright protection in the United States. It may be reproduced and distributed in its entirety without further permission from GAO. Because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. United States Government Accountability Office: GAO: Testimony: Before the Committee on Banking, Housing, and Urban Affairs, U.S. Senate: For Release on Delivery: Expected at 10:00 a.m. EDT: June 23, 2011: Flood Insurance: Public Policy Goals Provide a Framework for Reform: Statement of Orice Williams Brown, Managing Director: Financial Markets and Community Investment: GAO-11-670T: GAO Highlights: Highlights of GAO-11-670T, a testimony before the Committee on Banking, Housing, and Urban Affairs, U.S. Senate. Why GAO Did This Study: The National Flood Insurance Program (NFIP) has been on GAO‘s high- risk list since 2006, when the program had to borrow from the U.S. Treasury to cover losses from the 2005 hurricanes. The outstanding debt is $17.8 billion as of June 2011. This sizeable debt, plus operational and management challenges that GAO has identified at the Federal Emergency Management Agency (FEMA), which administers NFIP, have combined to keep the program on the high-risk list. NFIP‘s need to borrow to cover claims in years of catastrophic flooding has raised concerns about the program‘s long-term financial solvency. This testimony (1) discusses ways to place NFIP on a sounder financial footing in light of public policy goals for federal involvement in natural catastrophe insurance and (2) highlights operational and management challenges at FEMA that affect the program. In preparing this statement, GAO relied on its past work on NFIP, including a June 2011 report on FEMA‘s management of NFIP, which focused on its planning, policies, processes, and systems. The management review included areas such as strategic and human capital planning, acquisition management, and intra-agency collaboration. GAO has made numerous recommendations aimed at improving financial controls, oversight of private insurers and contractors, and FEMA‘s management of NFIP. DHS generally agreed with our recommendations. What GAO Found: Congressional action is needed to increase the financial stability of NFIP and limit taxpayer exposure. GAO previously identified four public policy goals that can provide a framework for crafting or evaluating proposals to reform NFIP. These goals are: * charging premium rates that fully reflect risks, * limiting costs to taxpayers before and after a disaster, * encouraging broad participation in the program, and, * encouraging private markets to provide flood insurance. Successfully reforming NFIP would require trade-offs among these often competing goals. For example, nearly one in four policyholders does not pay full-risk rates, and many pay a lower subsidized or ’grandfathered“ rate. Reducing or eliminating less than full-risk rates would decrease costs to taxpayers but substantially increase costs for many policyholders, some of whom might leave the program, potentially increasing post-disaster federal assistance. However, these trade-offs could be mitigated by providing assistance only to those who need it, limiting post-disaster assistance for flooding, and phasing in premium rates that fully reflect risks. Increasing mitigation efforts to reduce the probability and severity of flood damage would also reduce flood claims in the long term but would have significant up-front costs that might require federal assistance. One way to address this trade-off would be to better ensure that current mitigation programs are effective and efficient. Encouraging broad participation in the program could be achieved by expanding mandatory purchase requirements or increasing targeted outreach to help diversify the risk pool. Such efforts could help keep rates relatively low and reduce NFIP‘s exposure but would have to be effectively managed to help ensure that outreach efforts are broadly based. Encouraging private markets is the most difficult challenge because virtually no private market for flood insurance exists for most residential and commercial properties. FEMA‘s ongoing efforts to explore alternative structures may provide ideas that could be evaluated and considered. Several operational and management issues also limit FEMA‘s progress in addressing NFIP‘s challenges, and continued action by FEMA will be needed to help ensure the stability of the program. For example, in numerous past reports, GAO identified weaknesses in areas that include financial controls and oversight of private insurers and contractors, and made many recommendations to address them. While FEMA has made progress in addressing some areas, GAO‘s June 2011 report identified a number of management challenges facing the program, including strategic and human capital planning, records management, collaboration among offices, and financial and acquisition management. In this report, we also made a number of recommendations to address these challenges. FEMA agreed with the recommendations and discussed the steps being taken to address some of them. View [hyperlink, http://www.gao.gov/products/GAO-11-670T] or key components. For more information, contact Orice Williams Brown at (202) 512-9678 or williamso@gao.gov. [End of section] Chairman Johnson, Ranking Member Shelby, and Members of the Committee: I appreciate the opportunity to participate in today's hearing on National Flood Insurance Program (NFIP) reform. As you know, NFIP is the key component of the federal government's efforts to minimize the damage from and financial impact of floods and is the only source of insurance against flood damage for most residents in vulnerable areas. NFIP has been on GAO's high-risk list since March 2006 after incurring billions of dollars in catastrophic losses from the 2005 hurricanes. Further contributing to NFIP's high-risk classification are operational and management challenges that we have identified within the Federal Emergency Management Agency (FEMA) that affect the program. As of June 2011, NFIP still owed almost $17.8 billion to the Department of the Treasury (Treasury) for loans used to cover losses from the 2005 hurricanes. The magnitude of this debt highlights the many financial challenges the program faces, including structural weaknesses in the way it is funded, and the managerial challenges that have affected FEMA's administration of NFIP. Any efforts to help stabilize NFIP will require addressing both the program's financial challenges and its operational and management issues. My statement today discusses four public policy goals that GAO has developed for evaluating federal involvement in the provision of natural catastrophe insurance and identifies key program areas needing reform, potential ways to better fulfill these goals, and the trade- offs that would be required. This statement also sets out the operational and managerial challenges facing NFIP that we have identified in our past reports, including a report that was issued earlier this month.[Footnote 1] The work that this report was based on was performed from March 2006 through June 2011. We performed our work in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence we obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. Background: The National Flood Insurance Act of 1968 established NFIP as an alternative to providing direct assistance after floods.[Footnote 2] NFIP, which provides government-guaranteed flood insurance to homeowners and businesses, was intended to reduce the federal government's escalating costs for repairing flood damage after disasters. FEMA, which is within the Department of Homeland Security (DHS), is responsible for the oversight and management of NFIP. Since NFIP's inception, Congress has enacted several pieces of legislation to strengthen the program. The Flood Disaster Protection Act of 1973 made flood insurance mandatory for owners of properties in vulnerable areas who had mortgages from federally regulated lenders and provided additional incentives for communities to join the program.[Footnote 3] The National Flood Insurance Reform Act of 1994 strengthened the mandatory purchase requirements for owners of properties located in special flood hazard areas (SFHA) with mortgages from federally regulated lenders.[Footnote 4] Finally, the Bunning-Bereuter- Blumenauer Flood Insurance Reform Act of 2004 authorized grant programs to mitigate properties that experienced repetitive flooding losses. Owners of these repetitive loss properties who do not mitigate may face higher premiums.[Footnote 5] To participate in NFIP, communities agree to enforce regulations for land use and new construction in high-risk flood zones and to adopt and enforce state and community floodplain management regulations to reduce future flood damage. Currently, more than 20,000 communities participate in NFIP. NFIP has mapped flood risks across the country, assigning flood zone designations based on risk levels, and these designations are a factor in determining premium rates. NFIP offers two types of flood insurance premiums: subsidized and full risk. The National Flood Insurance Act of 1968 authorizes NFIP to offer subsidized premiums to owners of certain properties. These subsidized premium rates, which represent about 40 percent to 45 percent of the cost of covering the full risk of flood damage to the properties, apply to about 22 percent of all NFIP policies. To help reduce or eliminate the long-term risk of flood damage to buildings and other structures insured by NFIP, FEMA has used a variety of mitigation efforts, such as elevation, relocation, and demolition. Despite these efforts, the inventories of repetitive loss properties--generally, as defined by FEMA, those that have had two or more flood insurance claims payments of $1,000 or more over 10 years--and policies with subsidized premium rates have continued to grow.[Footnote 6] In response to the magnitude and severity of the losses from the 2005 hurricanes, Congress increased NFIP's borrowing authority from Treasury to about $20.8 billion. Efforts to Reform NFIP's Financial Structure Will Require Balancing Public Policy Goals: We have previously identified four public policy goals for evaluating the federal role in providing natural catastrophe insurance: * charging premium rates that fully reflect actual risks, * limiting costs to taxpayers before and after a disaster, * encouraging broad participation in natural catastrophe insurance programs, and: * encouraging private markets to provide natural catastrophe insurance.[Footnote 7] Taking action to achieve these goals would benefit both NFIP and the taxpayers who fund the program but would require trade-offs. I will discuss the key areas that need to be addressed, actions that can be taken to help achieve these goals, and the trade-offs that would be required. Charging Full-Risk Rates Would Improve NFIP's Financial Soundness but Could Reduce Program Participation: As I have noted, NFIP currently does not charge all program participants rates that reflect the full risk of flooding to their properties.[Footnote 8] First, the act requires FEMA to charge many policyholders less than full-risk rates to encourage program participation. While the percentage of subsidized properties was expected to decline as new construction replaced subsidized properties, today nearly one out of four NFIP policies is based on a subsidized rate. Second, FEMA may "grandfather" properties that are already in the program when new flood maps place them in higher-risk zones, allowing some property owners to pay premium rates that apply to the previous lower-risk zone. FEMA officials told us they made the decision to allow grandfathering because of external pressure to reduce the effects of rate increases, and considerations of equity, ease of administration, and the goals of promoting floodplain management. Similarly, FEMA recently introduced a new rating option called the Preferred Risk Policy Eligibility Extension that in effect equals a temporary grandfathering of premium rates.[Footnote 9] While these policies typically would have to be converted to more expensive policies when they were renewed after a new flood map came into effect, FEMA has extended eligibility for these lower rates. Finally, we have also raised questions about whether NFIP's full-risk rates reflect actual flood risks. Because many premium rates charged by NFIP do not reflect the full risk of loss, the program is less likely to be able to pay claims in years with catastrophic losses, as occurred in 2005, and may need to borrow from Treasury to pay claims in those years.[Footnote 10] Increasing premium rates to fully reflect the risk of loss--including the risk of catastrophic loss--would generally require reducing or eliminating subsidized and grandfathered rates and offers several advantages. Specifically, increasing rates could: * result in premium rates that more fully reflected the actual risk of loss; * decrease costs for taxpayers by reducing costs associated with post- disaster borrowing to pay claims; and: * encourage private market participation, because the rates would more closely approximate those that would be charged by private insurers. However, eliminating subsidized and grandfathered rates and increasing rates overall would increase costs to some homeowners, who might then cancel their flood policies or elect not to buy them at all. According to FEMA, subsidized premium rates are generally 40 percent to 45 percent of rates that would reflect the full risk of loss. For example, the projected average annual subsidized premium was $1,121 as of October 2010, discounted from the $2,500 to $2,800 that FEMA said would be required to cover the full risk of loss.[Footnote 11] In a 2009 report, we also analyzed the possibility of creating a catastrophic loss fund within NFIP (one way to help pay for catastrophic losses).[Footnote 12] Our analysis found that in order to create a fund equal to 1 percent of NFIP's total exposure by 2020, the average subsidized premium--which typically is in one of the highest- risk zones--would need to increase from $840 to around $2,696, while the average full-risk premium would increase from around $358 to $1,149. Such steep increases could reduce participation, either because homeowners could no longer afford their policies or simply deemed them too costly, and increase taxpayer costs for post-disaster assistance to property owners who no longer had flood insurance. However, a variety of actions could be taken to mitigate these disadvantages. For example, subsidized rates could be phased out over time or not transferred with the property when it is sold. Moreover, as we noted in our past work, targeted assistance could be offered to those most in need to help them pay increased NFIP premiums.[Footnote 13] This assistance could take several forms, including direct assistance through NFIP, tax credits, or grants. In addition, to the extent that those who might forgo coverage were actually required to purchase it, additional actions could be taken to better ensure that they purchased policies. According to the RAND Corporation, in SFHAs, where property owners with loans from federally insured or regulated lenders are required to purchase flood insurance, as few as 50 percent of the properties had flood insurance in 2006.[Footnote 14] Limiting Taxpayer Costs Could Be Achieved by Increasing Premium Rates, but Further Mitigation Efforts Could Incur Up-Front Costs: In order to reduce expenses to taxpayers that can result when NFIP borrows from Treasury, NFIP needs to be able to generate enough in premiums to pay its claims, even in years with catastrophic losses--a goal that is closely tied to that of eliminating subsidies and other reduced rates. Since the program's inception, NFIP premiums have come close to covering claims in average loss years but not in years of catastrophic flooding, particularly 2005. Unlike private insurance companies, NFIP does not purchase reinsurance to cover catastrophic losses.[Footnote 15] As a result, NFIP has funded such losses after the fact by borrowing from Treasury. As we have seen, such borrowing exposes taxpayers to the risk of loss. NFIP still owes approximately $17.8 billion of the amount it borrowed from Treasury for losses incurred during the 2005 hurricane season. The high cost of servicing this debt means it may never be repaid, could in fact increase, and will continue to affect the program's solvency and be a burden to taxpayers. Another way to limit costs to taxpayers is to decrease the risk of losses by undertaking mitigation efforts that could reduce the extent of damage from flooding. FEMA has taken steps to help homeowners and communities mitigate properties by making improvements designed to reduce flood damage--for example, elevation, relocation, and demolition. As we have reported, from fiscal year 1997 through fiscal year 2007, nearly 30,000 properties were mitigated using FEMA funds. [Footnote 16] Increasing mitigation efforts could further reduce flood damage to properties and communities, helping to put NFIP on a firmer financial footing and reducing taxpayers' exposure. FEMA has made particular efforts to address the issue of repetitive loss properties through mitigation. These properties account for just 1 percent of NFIP's insured properties but are responsible for 25 percent to 30 percent of claims. Despite FEMA's efforts, the number of repetitive loss properties increased from 76,202 in 1997 to 132,100 in March 2011, or by about 73 percent. FEMA also has some authority to raise premium rates for property owners who refuse mitigation offers in connection with the Severe Repetitive Loss Pilot Grant Program. [Footnote 17] In these situations, FEMA can initially increase premiums to up to 150 percent of their current amount and may raise them again (by up to the same amount) on properties that incur a claim of more than $1,500. However, FEMA cannot increase premiums on property owners who pay the full-risk rate but refuse a mitigation offer, and in no case can rate increases exceed the full-risk rate for the structure. In addition, FEMA is not allowed to discontinue coverage for those who refuse mitigation offers. As a result, FEMA is limited in its ability to compel owners of repetitive loss properties to undertake flood mitigation efforts. Mitigation offers significant advantages. As I have noted, mitigated properties are less likely to be at a high risk for flood damage, making it easier for NFIP to charge them full-risk rates that cover actual losses. Allowing NFIP to deny coverage to owners of repetitive loss properties who refused to undertake mitigation efforts could further reduce costs to the program and ultimately to taxpayers. One disadvantage of increased mitigation efforts is that they can impose up-front costs on homeowners and communities required to undertake them and could raise taxpayers' costs if the federal government elected to provide additional mitigation assistance. Those costs could increase still further if property owners who were dropped from the program for refusing to mitigate later-received federal post- disaster assistance. These trade-offs are not insignificant, although certain actions could be taken to reduce them. For example, federal assistance such as low-cost loans, grants, or tax credits could be provided to help property owners pay for the up-front costs of mitigation efforts. Any reform efforts could explore ways to improve mitigation efforts to help ensure maximum effectiveness. For example, FEMA has three separate flood mitigation programs.[Footnote 18] Having multiple programs may not be the most cost-efficient and effective way to promote mitigation and may unnecessarily complicate mitigation efforts. Depending on How They Were Implemented, Efforts to Encourage Broader Participation Could Reduce Costs: Increasing participation in NFIP, and thus the size of the risk pool, would help ensure that losses from flood damage did not become the responsibility of the taxpayer. Participation rates have been estimated to be as low as 50 percent in SFHAs, where property owners with loans from federally insured and regulated lenders are required to purchase flood insurance, and participation in lower-risk areas is significantly lower.[Footnote 19] For example, participation rates outside of SFHAs have been found to be as low as 1 percent, leaving significant room to increase participation. Expanding participation in NFIP would have a number of advantages. As a growing number of participants shared the risks of flooding, premium rates could be lower than they would be with fewer participants. Currently, NFIP must take all applicants for flood insurance, unlike private insurers, and thus is limited in its ability to manage its risk exposure. To the extent that properties added to the program were in geographic areas where participation had historically been low and in low-and medium-risk areas, the increased diversity could lower rates as the overall risk to the program decreased. Further, increased program participation could reduce taxpayer costs by reducing the number of property owners who might draw on federally funded post- disaster assistance. However, efforts to expand participation in NFIP would have to be carefully implemented, for several reasons. First, as we have noted, NFIP cannot reject applicants on the basis of risk. As a result, if participation increased only in SFHAs, the program could see its concentration of high-risk properties grow significantly and face the prospect of more severe losses. Second, a similar scenario could emerge if mandatory purchase requirements were expanded and newly covered properties were in communities that did not participate in NFIP and thus did not meet standards--such as building codes--that could reduce flood losses. As a result, some of the newly enrolled properties might be eligible for subsidized premium rates or, because of restrictions on how much FEMA can charge in premiums, might not pay rates that covered the actual risk of flooding. Finally, historically FEMA has attempted to encourage participation by charging lower rates; however, doing so results in rates that do not fully reflect the risks of flooding and exposes taxpayers to increased risk. Moderating the challenges associated with expanding participation could take a variety of forms. Newly added properties could be required to pay full-risk rates, and low-income property owners could be offered some type of assistance to help them pay their premiums. Outreach efforts would need to include areas with low and moderate flood risks to help ensure that the risk pool remained diversified. For example, FEMA's goals for NFIP include increasing penetration in low-risk flood zones, among homeowners without federally related mortgages in all zones, and in geographic areas with repetitive losses and low penetration rates. Encouraging Private Market Participation Could Reduce the Federal Government's Exposure but Could Also Decrease NFIP's Stability if Only High-Risk Properties Remained: Currently, the private market provides only a limited amount of flood insurance coverage. In 2009, we reported that while aggregate information was not available on the precise size of the private flood insurance market, it was considered relatively small.[Footnote 20] The 2006 RAND study estimated that 180,000 to 260,000 insurance policies for both primary and gap coverage were in effect.[Footnote 21] We also reported that private flood insurance policies are generally purchased in conjunction with NFIP policies, with the NFIP policy covering the deductible on the private policy. Finally, we reported that NFIP premiums were generally less expensive than premiums for private flood insurance for similar coverage.[Footnote 22] For example, one insurer told us that for a specified amount of coverage for flood damage to a structure, an NFIP policy might be as low as $500, while a private policy might be as high as $900. Similar coverage for flood damage to contents might be $350 for an NFIP policy but around $600 for a private policy. Given the limited nature of private sector participation, encouraging private market participation could transfer some of the federal government's risk exposure to the private markets and away from taxpayers. However, identifying ways to achieve that end has generally been elusive. In 2007, we evaluated the trade-offs of having a mandatory all-perils policies that would include flood risks.[Footnote 23] For example, it would alleviate uncertainty about the types of natural events homeowners insurance covered, such as those that emerged following Hurricane Katrina. However, at the time the industry was generally opposed to an all-perils policy because of the large potential losses a mandatory policy would entail. Increased private market participation is also not without potential disadvantages. First, if the private markets provide coverage for only the lowest-risk properties currently in NFIP, the percentage of high- risk properties in the program would increase. This scenario could result in higher rates as the amount needed to cover the full risk of flooding increased. Without higher rates, however, the federal government would face further exposure to loss. Second, private insurers, who are able to charge according to risk, would likely charge higher rates than NFIP has been charging unless they received support from the federal government. As we have seen, such increases could create affordability concerns for low-income policyholders. Strategies to help mitigate these disadvantages could include requiring private market coverage for all property owners--not just those in high-risk areas--and, as described earlier, providing targeted assistance to help low-income property owners pay for their flood coverage. In addition, Congress could provide options to private insurers to help lower the cost of such coverage, including tax incentives or federal reinsurance. FEMA's Operational and Management Issues May Limit Progress in Achieving NFIP Goals: As Congress weighs NFIP's various financial challenges in its efforts to reform the program, it must also consider a number of operational and management issues that may limit efforts to meet program goals and impair NFIP's stability. For the past 35 years, we have highlighted challenges with NFIP and its administration and operations. For example, most recently we have identified a number of issues impairing the program's effectiveness in areas that include the reasonableness of payments to Write-Your-Own (WYO) insurers, the adequacy of financial controls over the WYO program, and the adequacy of oversight of non-WYO contractors. In our report, which reviews FEMA's management of NFIP, we addressed, among other things, (1) the extent to which FEMA's management practices affect the agency's ability to meet NFIP's mission and (2) lessons to be learned from the cancellation of FEMA's most recent attempt to modernize NFIP's flood insurance policy and claims processing system.[Footnote 24] We found that FEMA faces significant management challenges in areas that affect its administration of NFIP. First, FEMA has not finalized strategic guidance and direction for NFIP and therefore lacks goals and objectives for the program and the necessary starting point for developing performance measures that would assess the program's effectiveness. Second, FEMA faces a number of human capital challenges related to turnover, hiring, and tracking the many contractors that play a key role in NFIP. Further, FEMA lacks a plan that would help ensure consistent day-to-day operations when it deploys staff to respond to federal disasters. Third, collaboration between program and support offices that contribute to administering NFIP has at times been ineffective, leading to challenges in effectively carrying out some key functions, including information technology, acquisition, and financial management. Finally, FEMA does not have a comprehensive set of processes and systems to guide its operations. Specifically, it lacks an updated records management policy, an electronic document management system, procedures to effectively manage unliquidated obligations, and a fully developed and implemented documentation of its business processes. FEMA has begun taking steps to improve its acquisition management and document some of its business processes, but the results of its efforts remain to be seen. Unless it takes further steps to address these management challenges, FEMA will be limited in its ability to manage NFIP's operations or better ensure program effectiveness. In our report we made eight recommendations addressing these issues. DHS agreed with these recommendations and FEMA has begun to take steps to begin addressing some of them. For example, FEMA has begun developing a strategy for the administration of its mitigation and insurance programs, conducting a workforce assessment, holding outreach sessions between program and support offices to improve collaboration, and developing training and certification programs for acquisition management. We also found that the canceled development of the Next Generation Flood Insurance Management System (NextGen), FEMA's latest attempt to modernize NFIP's insurance policy and claims management system, illustrated weaknesses in NFIP's acquisition management activities. Despite investing roughly 7 years and $40 million, FEMA ultimately canceled the effort in November 2009 because it failed to meet user expectations, forcing the agency to continue relying on a 30-year-old system that does not fully support NFIP's mission needs and is costly to maintain and operate. A number of acquisition management weaknesses led to NextGen's failure and cancellation. Specifically, business and functional requirements were not sufficiently defined; system users did not actively participate in determining the requirements for the development of system prototypes or in pilot testing activities; test planning and project risks were not adequately managed; and project management office staffing was limited. As FEMA begins a new effort to modernize the existing legacy system, it plans to apply lessons learned from its NextGen experience. While FEMA has begun implementing some changes to its acquisition management practices, it remains to be seen if they will help FEMA avoid some of the problems that led to NextGen's failure. Unless it develops appropriate acquisitions processes and applies lessons learned from the NextGen failure, FEMA will be unable to develop an effective policies and claims processing system for NFIP. DHS agreed with our recommendations that DHS provide regular oversight of FEMA's next attempt to modernize the system and help ensure FEMA applies lessons learned. Closing Comments: Congressional action is needed to increase the financial stability of NFIP and limit taxpayer exposure. GAO previously identified four public policy goals that can provide a framework for crafting or evaluating proposals to reform NFIP. First, any congressional reform effort should include measures for charging premium rates that accurately reflect the risk of loss, including catastrophic losses. Meeting this goal would require changing the law governing NFIP to reduce or eliminate subsidized rates, limits on annual rate increases, and grandfathered or other rates that do not fully reflect the risk of loss. In taking such a step, Congress may choose to provide assistance to certain property owners, and should consider providing appropriate authorization and funding of such incentives to ensure transparency. Second, because of the potentially high costs of individual and community mitigation efforts, which can reduce the frequency and extent of flood damage, Congress may need to provide funding or access to funds for such efforts and consider ways to improve the efficiency of existing mitigation programs. Moreover, if Congress wished to allow NFIP to deny coverage to owners of properties with repetitive losses who refuse mitigation efforts, it would need to give FEMA appropriate authority. Third, Congress could encourage FEMA to continue to increase participation in the program by expanding targeted outreach efforts and limiting post-disaster assistance to those individuals who choose not to mitigate in moderate-and high-risk areas. And finally, to address the goal of encouraging private sector participation, Congress could encourage FEMA to explore private sector alternatives to providing flood insurance or for sharing insurance risks, provided such efforts do not increase taxpayers' exposure. For its part, FEMA needs to take action to address a number of fundamental operational and managerial issues that also threaten the stability of NFIP and have contributed to its remaining on GAO's high- risk list. These include improving its strategic planning, human capital planning, intra-agency collaboration, records management, acquisition management, and information technology. While FEMA continues to make some progress in some areas, fully addressing these issues is vital to its long-term operational efficiency and financial stability. Chairman Johnson and Ranking Member Shelby, this concludes my prepared statement. I would be pleased to respond to any of the questions you or other members of the Committee may have at this time. GAO Contact and Staff Acknowledgments: Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this statement. For further information about this testimony, please contact Orice Williams Brown at (202) 512-8678 or williamso@gao.gov. This statement was prepared under the direction of Patrick Ward. Key contributors were Christopher Forys, Nima Patel Edwards, Emily Chalmers, and Tania Calhoun. [End of section] Related GAO Products: FEMA: Action Needed to Improve Administration of the National Flood Insurance Program. [hyperlink, http://www.gao.gov/products/GAO-11-297]. Washington, D.C.: June 9, 2011. Flood Insurance: Public Policy Goals Provide A Framework for Reform. [hyperlink, http://www.gao.gov/products/GAO-11-429T]. Washington, D.C.: March 11, 2011. FEMA Flood Maps: Some Standards and Processes in Place to Promote Map Accuracy and Outreach, but Opportunities Exist to Address Implementation Challenges. [hyperlink, http://www.gao.gov/products/GAO-11-17]. Washington, D.C.: December 2, 2010. National Flood Insurance Program: Continued Actions Needed to Address Financial and Operational Issues. [hyperlink, http://www.gao.gov/products/GAO-10-1063T]. Washington, D.C.: September 22, 2010. National Flood Insurance Program: Continued Actions Needed to Address Financial and Operational Issues. [hyperlink, http://www.gao.gov/products/GAO-10-631T]. Washington, D.C.: April 21, 2010. Financial Management: Improvements Needed in National Flood Insurance Program's Financial Controls and Oversight. [hyperlink, http://www.gao.gov/products/GAO-10-66]. Washington, D.C.: December 22, 2009. Flood Insurance: Opportunities Exist to Improve Oversight of the WYO Program. [hyperlink, http://www.gao.gov/products/GAO-09-455]. Washington, D.C.: August 21, 2009. Information on Proposed Changes to the National Flood Insurance Program. [hyperlink, http://www.gao.gov/products/GAO-09-420R]. Washington, D.C.: February 27, 2009. High-Risk Series: An Update. [hyperlink, http://www.gao.gov/products/GAO-09-271]. Washington, D.C.: January 2009. Flood Insurance: Options for Addressing the Financial Impact of Subsidized Premium Rates on the National Flood Insurance Program. [hyperlink, http://www.gao.gov/products/GAO-09-20]. Washington, D.C.: November 14, 2008. Flood Insurance: FEMA's Rate-Setting Process Warrants Attention. [hyperlink, http://www.gao.gov/products/GAO-09-12]. Washington, D.C.: October 31, 2008. National Flood Insurance Program: Financial Challenges Underscore Need for Improved Oversight of Mitigation Programs and Key Contracts. [hyperlink, http://www.gao.gov/products/GAO-08-437]. Washington, D.C.: June 16, 2008. Natural Catastrophe Insurance: Analysis of a Proposed Combined Federal Flood and Wind Insurance Program. [hyperlink, http://www.gao.gov/products/GAO-08-504]. Washington, D.C.: April 25, 2008. National Flood Insurance Program: Greater Transparency and Oversight of Wind and Flood Damage Determinations Are Needed. [hyperlink, http://www.gao.gov/products/GAO-08-28]. Washington, D.C.: December 28, 2007. National Disasters: Public Policy Options for Changing the Federal Role in Natural Catastrophe Insurance. [hyperlink, http://www.gao.gov/products/GAO-08-7]. Washington, D.C.: November 26, 2007. Federal Emergency Management Agency: Ongoing Challenges Facing the National Flood Insurance Program. [hyperlink, http://www.gao.gov/products/GAO-08-118T]. Washington, D.C.: October 2, 2007. National Flood Insurance Program: FEMA's Management and Oversight of Payments for Insurance Company Services Should Be Improved. [hyperlink, http://www.gao.gov/products/GAO-07-1078]. Washington, D.C.: September 5, 2007. National Flood Insurance Program: Preliminary Views on FEMA's Ability to Ensure Accurate Payments on Hurricane-Damaged Properties. [hyperlink, http://www.gao.gov/products/GAO-07-991T]. Washington, D.C.: June 12, 2007. Coastal Barrier Resources System: Status of Development That Has Occurred and Financial Assistance Provided by Federal Agencies. [hyperlink, http://www.gao.gov/products/GAO-07-356]. Washington, D.C.: March 19, 2007. Budget Issues: FEMA Needs Adequate Data, Plans, and Systems to Effectively Manage Resources for Day-to-Day Operations. [hyperlink, http://www.gao.gov/products/GAO-07-139]. Washington, D.C.: January 19, 2007. National Flood Insurance Program: New Processes Aided Hurricane Katrina Claims Handling, but FEMA's Oversight Should Be Improved. [hyperlink, http://www.gao.gov/products/GAO-07-169]. Washington, D.C.: December 15, 2006. GAO'S High-Risk Program. [hyperlink, http://www.gao.gov/products/GAO-06-497T]. Washington, D.C.: March 15, 2006. Federal Emergency Management Agency: Challenges for the National Flood Insurance Program. [hyperlink, http://www.gao.gov/products/GAO-06-335T]. Washington, D.C.: January 25, 2006. Federal Emergency Management Agency: Improvements Needed to Enhance Oversight and Management of the National Flood Insurance Program. [hyperlink, http://www.gao.gov/products/GAO-06-119]. Washington, D.C.: October 18, 2005. Determining Performance and Accountability Challenges and High Risks. [hyperlink, http://www.gao.gov/products/GAO-01-159SP]. Washington, D.C.: November 2000. Standards for Internal Control in the Federal Government. [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. Washington, D.C.: November 1999. Budget Issues: Budgeting for Federal Insurance Programs. [hyperlink, http://www.gao.gov/products/GAO/T-AIMD-98-147]. Washington, D.C.: April 23, 1998. Budget Issues: Budgeting for Federal Insurance Programs. [hyperlink, http://www.gao.gov/products/GAO/AIMD-97-16]. Washington, D.C.: September 30, 1997. National Flood Insurance Program: Major Changes Needed If It Is To Operate Without A Federal Subsidy. [hyperlink, http://www.gao.gov/products/GAO/RCED-83-53]. Washington, D.C.: January 3, 1983. Formidable Administrative Problems Challenge Achieving National Flood Insurance Program Objectives. [hyperlink, http://www.gao.gov/products/RED-76-94]. Washington, D.C.: April 22, 1976. [End of section] Footnotes: [1] See GAO, FEMA: Action Needed to Improve Administration of the National Flood Insurance Program, [hyperlink, http://www.gao.gov/products/GAO-11-297] (Washington, D.C.: June 9, 2011). [2] Pub. L. No. 90-448, Title XIII, 82 Stat. 476 (1968). [3] Pub. L. No. 93-234, �102, 87 Stat. 975, 978 (1973). [4] Pub. L. No. 103-325, 108 Stat. 2255 (1994). [5] Pub. L. No. 108-264, �� 102, 104, 118 Stat. 712, 714, 722 (2004). [6] The Bunning-Bereuter-Blumenauer Flood Insurance Reform Act of 2004 amended the existing definition of the term "repetitive loss structure" to the current one: a structure covered by a contract for flood insurance that has incurred flood-related damage on two occasions, in which the cost of repair, on the average, equaled or exceeded 25 percent of the value of the structure at the time of each such flood event; and at the time of the second incidence of flood- related damage, the contract for flood insurance contains increased cost of compliance coverage, which can help property owners pay for the cost of mitigation measures for flood-damaged properties. 42 U.S.C. � 4121(a). [7] See GAO, Natural Disasters: Public Policy Options for Changing the Federal Role in Natural Catastrophe Insurance, [hyperlink, http://www.gao.gov/products/GAO-08-7] (Washington, D.C.: Nov. 26, 2007). [8] Premium rates that reflect the "full risk" of flooding can mean different things, and there is no standard definition for this term. An actuarial approach to ratemaking would produce rates that cover a best estimate of average expected losses, plus an additional margin for risk. The question then becomes how big the risk margin should be, a decision that will be influenced in turn by the characteristics of the risk (including the magnitude of potential catastrophic losses), the desired margin for safety and speed of building up a contingency reserve, and the availability of other sources of capital to cover excessive losses. The nature of flood risks is such that, because of the potential at any time for catastrophic losses, charging premium rates that reflect the full risk cannot ensure that the NFIP will not have to borrow from Treasury again in the future. As a corollary, the need in any particular year to borrow from Treasury does not, by itself, necessarily indicate that the rates charged were inappropriate or that the program was not being run properly. [9] The Preferred Risk Policy offers low-cost flood insurance to owners and tenants of residential and nonresidential buildings located in moderate-to low-risk areas as long as the property has not, within any 10-year period, incurred two or more flood insurance claim payments or disaster relief payments (including loans and grants) of more than $1,000 each. [10] Implementing rates that reflect the full risk of loss, including catastrophic losses, might not eliminate NFIP's need to borrow funds for larger-than-expected losses that occurred before sufficient reserves had been built. [11] This premium that would be required to cover the full risk of loss is based upon FEMA's calculation that subsidized premium rates are generally 40 percent to 45 percent of those rates. [12] See GAO, Information on Proposed Changes to the National Flood Insurance Program, [hyperlink, http://www.gao.gov/products/GAO-09-420R] (Washington, D.C.: Feb. 27, 2009). The creation of a catastrophic loss fund might not eliminate NFIP's need to borrow funds for larger-than-expected losses that occurred before the fund had been built. Further borrowing could require either a longer period to rebuild the loss fund or debt forgiveness from Congress. [13] See GAO, Flood Insurance: Options for Addressing the Financial Impact of Subsidized Premium Rates on the National Flood Insurance Program, [hyperlink, http://www.gao.gov/products/GAO-09-20] (Washington, D.C.: Nov. 14, 2008). [14] RAND, The National Flood Insurance Program's Market Penetration Rate: Estimates and Policy Implications (Santa Monica, Calif.: 2006). [15] Reinsurance is essentially insurance for insurers--that is, companies buy coverage for all or a part of a policy's liability from other insurers in order to offset exposure. [16] See [hyperlink, http://www.gao.gov/products/GAO-09-20]. [17] Under this program, for single-family properties, a severe repetitive loss is defined as a property covered under a contract for flood insurance that has incurred flood-related damage (1) for which four or more separate claims payments have been made, with the amount of each claim exceeding $5,000, and with the cumulative amount of such claims payments exceeding $20,000, or (2) for which at least two separate claims payments have been made, with the cumulative amount of such claims exceeding the value of the property. 42 U.S.C. � 4102a(b). [18] These programs include the Flood Mitigation Assistance Program, the Repetitive Flood Claims Program, and the Severe Repetitive Loss Program. Moreover, the Hazard Mitigation Grant Program and the Pre- Disaster Mitigation Program are two additional hazard mitigation programs that are not specific to flooding. [19] RAND, The National Flood Insurance Program's Market Penetration Rate. [20] See [hyperlink, http://www.gao.gov/products/GAO-09-420R]. [21] RAND, The National Flood Insurance Program's Market Penetration Rate. [22] See [hyperlink, http://www.gao.gov/products/GAO-09-420R]. [23] See [hyperlink, http://www.gao.gov/products/GAO-08-7]. [24] See [hyperlink, http://www.gao.gov/products/GAO-11-297]. [End of section] GAO's Mission: The Government Accountability Office, the audit, evaluation and investigative arm of Congress, exists to support Congress in meeting its constitutional responsibilities and to help improve the performance and accountability of the federal government for the American people. 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