Common ground between the FEMA Act of 2025 and the FEMA Review Council Report

The need for reform at the Federal Emergency Management Agency (FEMA) is an issue recognized on both sides of the aisle, but agreement has, to date, been elusive. Two policy documents have recently been produced: the bipartisan Fixing Emergency Management for Americans Act (FEMA Act) in the U.S. House of Representatives, and the report from President Trump’s FEMA Review Council. Despite the challenges of finding middle ground, these two proposals share encouraging alignment in a few ways, particularly when viewed in the context of their goals — and in some cases, the direction of their implementations as well.

A History of Dysfunction

This bipartisan concern about how FEMA is managed has a long history. In 2014, Chris Edwards authored a report for the CATO Institute exploring the conservative perspective. Edwards characterizes the agency’s actions as “plagued by poor decisionmaking, wasteful spending, and excessive bureaucracy.” [1] Edwards concludes that FEMA should be dismantled with some functions reverting to the states, some privatized, and the rest transferred to other government agencies. While this is not a fringe position on the right, there are more moderate prescriptions as well.

Meanwhile, Carlos Martín et al. of the Brookings Institution wrote that FEMA’s “historically imbalanced development has produced programmatic siloes, yet our communities need these programs to work seamlessly … Different skillsets can create inter-agency tension, and the institutional and professional management across them has become challenging, if not impossible.” [2] Again, the concerns the paper discusses center on bureaucracy that hinders action, poor management of funds, and general dysfunction. It analyzes the current state of FEMA and recommends reform of the agency as a solution, an approach more common on the left but also championed by some on the right, if with different implementation details.

Recent Efforts

On July 23, 2025, Representative Sam Graves introduced H.R. 4669, the FEMA Act. The legislation has since accrued 83 total sponsors — roughly 19% of House membership — and passed out of committee on a vote of 57 to 3. The official summary of the bill characterizes it as “reestablish[ing] the Federal Emergency Management Agency … as an independent, cabinet-level agency” and “mak[ing] broad changes to FEMA’s disaster and hazard mitigation assistance programs.” [3]

The FEMA Review Council (FRC) was established by President Donald Trump, via executive order, on January 24, 2025. The stated goals were to produce a review “by individuals highly experienced at effective disaster response and recovery, who shall recommend to the President improvements or structural changes to promote the national interest and enable national resilience.” [4]

The efforts that produced these two documents are not strictly analogous; on the one hand we have a bipartisan piece of legislation with strong approval from the committee, and on the other we have a partisan policy proposal from the current majority party. While reading this comparison, it is important to keep in mind that the FRC report is an aspirational expression of policy goals, whereas the FEMA Act is a concrete legislative proposal that has already made significant progress through the legislative process where proposals are fine-tuned and adjusted to gain consensus.

Fundamental Differences

The FRC Parametric Estimate

The FRC report calls for a parametric approach, where the characteristics of the hazard that created the disaster would be utilized to determine the cost estimate for the disaster, and many proposals in the report are defined in reference to this overall cost estimate. The specific parametric model was not drafted for the report — this is a policy proposal, not a piece of legislation — and the report calls for a working group comprised of State, Tribal, and Territorial government (STT) representatives and private stakeholders to define the parametric model. Additionally, there is a new “high performing state” designation that comes into play when determining federal cost share. This designation would be earned through compliance with auditing and reporting requirements.

FEMA Act Cost Estimation Updates

The Stafford Act currently defines cost estimation methodology for each program separately. Whereas the FRC report unifies the cost estimation and then defines various program limits as percentages of that estimate, the FEMA Act keeps the cost estimation and award amounts defined by each program.

The Common Ground

Both documents agree more on what the problems are than they do on how to solve those problems. However, agreement on the goals is the first step to reaching agreement on implementation, and there are some areas where implementation details are starting to align as well.

Public Assistance

The current Public Assistance (PA) Program, created by the Stafford Act, is slow and requires STTs to front the funds for later reimbursement. The process requires damage assessments, a presidential declaration of emergency or major disaster, and specific authorization of categories for which funding can be provided. Each of these steps comprises time-consuming sub-processes, and the entire process is replete with bureaucratic waste and inefficiency.

Figure 1: Stafford Act Declaration Request Process [5]

The FEMA Act amends the Stafford Act to add an entirely new section as an alternative to the existing PA Program coverage for repair, restoration, and replacement of damaged facilities. This new section would be opt-in for 180 days after the Act goes into effect before becoming the primary statute, with the original repair and replacement authority expiring on December 31, 2032. Cost estimation would revert to the applicant, in compliance with limited guidelines, and the estimate would be presumed accurate unless criminal fraud is evidenced. Additionally, the Act creates a block grant alternative for small disasters. Applicants who utilize the block grants would not be eligible for traditional PA; this is a strict alternative. Block grants are capped at 80% of the amount that an applicant would otherwise receive from the PA Program, but applicants are free to use that money however they deem fit, so long as they meet some basic restrictions to avoid misuse. These grants do not increase if the actual damage costs exceed the original estimate. The only mechanism to increase the grant amount is discretion granted to the FEMA administrator to accommodate unforeseen circumstances.

The FRC report proposes replacing PA entirely with a new structure, dubbed the Reformed and Partnered Initiative for Disasters (RAPID) program. RAPID program grants would pay 50–75% of the parametric estimate as immediate funds. The actual determination of this cost share is described as dependent on the high performing state designation with such states also eligible for presidential approval for increased funds. Eligibility for funds would be “limited to eligible applicants, eligible facilities, eligible work, and eligible costs.” [6]

Figure 2: RAPID Direct Funding Flow Chart [7]

Both proposals reject project-by-project approvals in favor of direct funding that applicants have broad freedom to use. The FEMA Act creates the new program as an alternative which allows applicants to determine if, how, and how quickly they wish to transition to the new plan, whereas the FRC report recommends that the PA Program be completely replaced with the assertion that it “reduces the administrative burden on all stakeholders and prevents added confusion from overlapping approaches.” [8] This does not preclude a transition period in any concrete legislation arising from the proposal.

Hazard Mitigation

The Stafford Act provides a variety of hazard mitigation grants: the Hazard Mitigation Grant Program (HMGP), Flood Mitigation Assistance Grant Program (FMA), Building Resilient Infrastructure and Communities (BRIC), and Safeguarding Tomorrow Revolving Loan Fund Program (STRLF). [9] These programs, respectively, provide funds to ensure that post-disaster rebuilding includes mitigation measures, for pre-disaster infrastructure resilience, to build flood resiliency, and to back revolving loans that enable STTs to fund resiliency efforts.

The FEMA Act makes a variety of updates to the hazard mitigation framework. The mitigation planning section is updated to allow for a pre-approval process for existing hazard mitigation grant programs with approved hazard mitigation plans. Competitive pre-disaster grants are restructured via a formula that accounts for, among other factors, individual state risk and economic need. It also allows for advance payment of HMGP grants rather than offering only reimbursement.

The FRC report proposes complete elimination of the HMGP to be replaced with a two-phase funding structure that allocates 5% of the parametric estimate for the Refined Risk Reduction Program (R3P) and 10% for strategic mitigation. The R3P money is intended to help states begin immediate mitigation tasks as part of the recovery, and such funds would be delivered within 30 days of the disaster declaration. The strategic allocation would be distributed pursuant to administration priorities that are related to the National Flood Insurance Program (NFIP).

Both approaches agree on the need to speed up recovery funding to STTs. The FEMA Act accomplishes this by creating a framework for pre-approval, while the FRC report relies on the parametric estimate to make the process quicker. The disagreement here is less about a policy preference and more about the structural differences between the FRC report — overarching parametric estimate — and the FEMA Act — reforms of the existing statute. One interesting divergence is the FRC report’s strategic allocation that earmarks funds to try to take pressure off the NFIP. This is a case of leveraging the hazard mitigation framework to serve another conservative policy goal rather than a goal in and of itself. While it’s a divergence in implementation, it doesn’t speak to a divergence in goals for the hazard mitigation framework itself.

STT Primacy and Flexibility

Beyond any specific program, a shared philosophy runs through both documents. Both solutions demonstrate respect for STT primacy by shifting responsibility and control. Primarily, this takes the form of process and design being granted to STTs while money allocation and verification stay with FEMA.

Examples from the FEMA Act include the small disaster block grants — which allow substantial autonomy for state governors to manage qualifying disasters, and the preapproved mitigation plans — which rely on state processes, not federal, for development.

The FRC report specifically states their key doctrinal guide to be “Disaster response should be locally executed, state or tribally managed, and federally supported.” [10] This doctrine is consistent across the recommended policies.

Other Common Cause

There are a few other cases of commonality worth mentioning that don’t qualify as agreement on a goal but are suggestive of a retreat from active disagreement. These observations are drawn from changes observed between a leaked draft of the FRC report and the published version. It is important to keep in mind that leaked policy documents have questionable veracity.

First, the final FRC report removed a recommendation to ensure that FEMA remained a part of the DHS while a large part of the FEMA Act is converting FEMA back into an independent cabinet-level agency. The choice by the FRC to not actively take an oppositional position is an encouraging development for bipartisanship. Additionally, the draft FRC report recommended a 50% reduction in staffing at FEMA. This recommendation appears to be part of the broader goal of the Trump administration to downsize the federal government. As that goal is tangential to FEMA reform, it is gratifying to see that removed as it focuses attention on the competing recommendations of substance for FEMA reform and removes the distraction of other policy initiatives.

Conclusion

There is much disagreement left in the big picture, but the shared goals provide reason for optimism. We have a partisan policy brief and a bipartisan legislative proposal that are moving in some of the same general directions. That alignment runs deeper than shared frustration with the status quo — in at least one area, the two documents are converging not just on what needs to change, but on how to change it. A major policy position of the current administration is reduction in federal staff and the closure of some agencies. Yet despite that pressure — and the longstanding conservative position that FEMA should be dismantled entirely — the council recommends reform over elimination. There are, however, some significant differences of opinion that remain between the two that I hope to write about in the near future.

1 C. Edwards, “The Federal Emergency Management Agency: Floods, Failures, and Federalism” (Cato Institute, December 2014), https://www.cato.org/downsizing-government-essay/federal-emergency-management-agency-floods-failures-federalism.

2 Kousky Martin C., “Federal Disaster Management Is a Confusing Patchwork. Reforming FEMA and Improving Interagency Coordination Can Fix It,” Brookings (Brookings Institution, August 2023), https://www.brookings.edu/articles/federal-disaster-management-is-a-confusing-patchwork-reforming-fema-and-improving-interagency-coordination-can-fix-it/.

3 Congressional Research Service, “H.r.4669 — FEMA Act of 2025” (Congress.gov, July 2025), https://www.congress.gov/bill/119th-congress/house-bill/4669.

4 The White House, “Council to Assess the Federal Emergency Management Agency. The White House,” January 2025, https://www.whitehouse.gov/presidential-actions/2025/01/council-to-assess-the-federal-emergency-management-agency/.

5 Congressional Research Service, “A Brief Overview of FEMA’s Public Assistance Program” (Congress.gov, January 2025), https://www.congress.gov/crs-product/IF11529.

6 President’s Council to Assess the Federal Emergency Management Agency, “Final Report,” n.d., https://www.dhs.gov/sites/default/files/2026-05/26_0507_fema%20review%20council_final%20report.pdf.

7 Ibid.

8 Ibid.

9 Congressional Research Service, “Federal Emergency Management Agency (FEMA) Hazard Mitigation Assistance” (Congress.gov, August 2024), https://www.congress.gov/crs-product/IN11187.

10 President’s Council to Assess the Federal Emergency Management Agency, “Final Report.”