Federal Emergency Management Agency - Funeral Assistance

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Program level Payment Integrity results

Sponsoring agency: Department of Homeland Security

View on Federal Program Inventory

PROGRAM METRICS

$1,698 M

in FY 2024 outlays, with a

96.5%

payment accuracy rate

PROGRAM METRICS

$301 M

in FY 2025 outlays, with a

95.7%

payment accuracy rate

  • Improper payment estimates over time
    View as:

    Chart toggle amounts:
    Proper payments
    Overpayment
    Underpayment
    Technically improper
    Unknown

Payment Integrity results

  • FY 2024 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    10/2021 - 09/2022


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-2.11

  • Actions taken & planned to mitigate improper payments

    Mitigation strategy Description of the corrective action Completion date Status
    Automation
    The National Emergency Management Information System (NEMIS) is the information technology system that houses the survivor case files and is the master database that the Federal Emergency Management Agency (FEMA) uses to administer its assistance programs and make disaster assistance decisions. NEMIS supports assistance programs across the Individuals and Households Program (IHP) spectrum, which is divided into Housing Assistance and Other Needs Assistance (ONA). Because Funeral Assistance is a part of ONA, FEMA uses NEMIS to support funeral assistance processing. The system is primarily designed to support disaster relief to individuals and households whose property has been damaged or destroyed rather than the loss of life associated with funeral assistance. However, FEMA conducted a robust review of existing NEMIS business rules including automated system controls for verifying information such as addresses, and identity were conducted. This review was necessary due to the anticipated intervention required to support a disaster declaration limited to only COVID-19 Funeral Assistance instead of the full range of assistance offered under a traditional IHP declaration. FEMA’s processing system, NEMIS, performs automated checks on certain data elements within a funeral assistance application to identify potential duplications. FEMA checks for duplications in data fields such as applicant or co-applicant social security number; damaged dwelling address (DDA); and deceased individual’s name, and social security number. FEMA routes all these sources of potential duplication, when identified, to the Duplicate Investigation queue for manual review. Applications in the Duplicate Investigation queue require manual clearance of any potential duplications before they may continue being processed. For most Individual Assistance programs processed through NEMIS, the DDA field pertains to the address where real or personal property damage occurred. In the case of COVID-19 Funeral Assistance, FEMA uses the DDA data field to document the location where the COVID-19 death occurred. During the COVID-19 pandemic, many deaths occurred at shared locations such as hospitals and medical facilities. As such, the DDA data field is a common source of potential duplications identified by the NEMIS system. All financial related errors are attributed to the required human intervention for manually processingCOVID-19 funeral assistance, to include manually reviewing NEMIS flags.
    FY2024 Q1
    Completed
    Training
    The Federal Emergency Management Agency (FEMA) acquired the services of a call center service provider contractor to assist with processing the large volume of COVID-19 Funeral Assistance applications. The contractor takes incoming registration calls, enters data for new and prior registrations, performs initial case eligibility reviews, and makes outbound calls to verify the authenticity of received documents. FEMA identified process improvements for COVID-19 Funeral Assistance staff, including granting the contractor access to Homeland Security Information Network support pages. The resource serves to increase access to guidance and standard operating procedures. FEMA is also expanding collaboration with the contractor to improve the frequency and quality of quality control reporting. FEMA's Individual Assistance Division, Cadre Management and Training Branch developed an eLearning training course and provided it to FEMA Applicant Services Section personnel on April 3, 2023, as refresher training for staff processing COVID-19 Funeral Assistance. The eLearning training course covers the following topics: • Criteria used to identify potential sources of duplication; • Policies related to only a single beneficiary for each decedent; • Actions to take if multiple applicants apply for the same deceased individual; • Criteria not to exceed maximum award limit of $9,000 per decedent; and • Policies and procedures related to applicants who receive assistance from other sources including insurance, pre-paid arrangements, and other voluntary or government agencies.
    FY2024 Q1
    Completed
    Change Process
    The Federal Emergency Management Agency (FEMA) acquired the services of a call center service provider contractor to assist with processing the large volume of COVID-19 Funeral Assistance applications. The contractor takes incoming registration calls, enters data for new and prior registrations, performs initial case eligibility reviews, and makes outbound calls to verify the authenticity of received documents. FEMA identified process improvements for COVID-19 Funeral Assistance staff, including contractor support, and has taken the following corrective actions: • Launched Homeland Security Information Network support pages and granted access to the contractor on July 26, 2022, as a resource to improve access to outside agents, as well as enable rapid access to current guidance, standard operating procedures, and other resources. • Continued to make progress on improving the frequency and quality of quality control (QC) reporting and calibrations between FEMA and the contractor. For example, communication between contractors and QC teams is enhanced by assigning FEMA staff to coordinate communication and assist with scheduling requests. In addition, calibration and training session scheduling were improved by requesting more contractor input prior to sessions to meet the needs of the contractor. The quantity of QC inspections and frequency of reporting has been addressed through collaborative effort to streamline access and distribution of QC monitoring reports enabling more effective real time coaching opportunities to improve contractor performance.
    FY2024 Q1
    Completed
    Cross Enterprise Sharing
    A COVID-19 Funeral Assistance Task Force was created and led by a Federal Coordinating Officer (FCO). The task force coordinated with the DHS Office of General Counsel (OGC), Office of Information and Regulatory Affairs and Congressional representatives for policy implementation which is publicly available onFEMA.gov. Extensive collaboration efforts also included working with Department, interagency, state and community partners including the DHS Office of the Inspector General (OIG), Operational Reporting Branch, Communications Division, Service Center Support, External Affairs, State, Tribal and Territorial Consultations, National funeral Home Directors, Board of Medical Examiners; Community Partners such as Veteran Services, DHS, and the Department of Treasury's Bureau of Fiscal Services.
    FY2024 Q1
    Completed
    Audit
    The Payment Integrity Information Act of 2019 (PIIA) requires agencies to review and assess all programs and activities they administer and identify those determined to be susceptible to significant improper payments, estimate the annual amount of improper payments, and submit those estimates to Congress. In accordance with the Office of Management and Budget (OMB) Circular No. A-123, Appendix C, "Requirements for Payment Integrity Improvement", federal agencies are required to assess improper payments and report annually on their efforts. In compliance with these requirements, the Federal Emergency Management Agency (FEMA) Funeral Assistance program has conducted reviews and published results in 2024, over fiscal year (FY) 2022 program disbursement activity. FEMA also performed an assessment of internal control over financial reporting including performing tests of operating effectiveness, for the FY 2023 and FY 2024 performance period. These internal control assessments included a review over Grants Management with no material internal control issues noted. In addition to internal compliance and control audits and PIIA assessments utilizing a random statistical sampling of COVID-19 Funeral Assistance disbursements, the following audit corrective actions have been taken: • FEMA Office of the Chief Financial Officer conducted quarterly internal control testing for the annual test of operating effectiveness over COVID Funeral Assistance potential risks. • The Government Accountability Office (GAO) was required to conduct 60-day incremental audits in support of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) funding inclusive of one review specific to COVID-19 Funeral Assistance. • The DHS Office of the Inspector General (OIG) initiated an audit engagement for COVID-19 Funeral Assistance. • The quantity of Quality Control (QC) inspections and frequency of reporting has been addressed through collaborative effort to streamline access and distribution of QC monitoring reports enabling more effective real time coaching opportunities to improve contractor performance.
    FY2024 Q4
    Completed
    Predictive Analytics
    Due to the expanded nature of COVID-19 Funeral assistance, the Federal Emergency Management Agency (FEMA) implemented additional reports to monitor and mitigate the potential for Improper Payments (IPs) and Unknown Payments (UPs). These daily reports identify data anomalies, to include (1) funeral assistance applications containing three or more decedents; (2) applications without decedent information; (3) applications transferred to another disaster; and (4) applications canceled as exact duplicates. Identification of these data elements were used to provide reminders and supplemental refresher trainings. Additionally, FEMA Recovery established a new section in the Reporting and Analytics Division in October 2022, solely dedicated to payment integrity, including case reviews, application of fraud prevention tools and controls, and coordination of guidance and procedure changes with the Individual Assistance (IA) program.
    FY2024 Q1
    Completed
    Training
    The Federal Emergency Management Agency (FEMA) Individual Assistance (IA) Division provided refresher training in March 2023 to staff processing requests for COVID-19 Funeral Assistance. Going forward, FEMA will continue to coordinate with the Program Management Section (PMS) to send reminders to the staff processing funeral determinations to help reinforce guidance and enable personnel to mitigate errors. FEMA is also providing detailed instructions and examples of information processing that staff should verify on the internet and how to appropriately document within the application file record comments. In the early stages of COVID-19 Funeral Assistance, the internet search was not an option to resolving missing verification points. This was causing multiple calls to applicants asking them to provide the information, when funeral homes were not responding to verification calls, and leading to a high number of ineligible cases. Later guidance was updated to include an internet search in order to find information that would help with the verification process and reduce the burden on the applicant to provide. The internet search can assist caseworkers in finding a phone number of the funeral home, validating the funeral home is a valid business and confirming the death occurred by locating an obituary.
    FY2025
    Planned
    Change Process
    The Federal Emergency Management Agency (FEMA) is strengthening the insurance verification process to assist in the review for a potential duplication of benefits. Through Funeral Assistance program reviews, there were noted instances applicant submitted limited insurance documents from life insurance companies, but it was not clear if the decedent actually had funeral and/or burial insurance coverage within the policy. As such, the program has made updates to the current operating procedures to strengthen the insurance verification process. FEMA will consider insurance specifically intended only for funeral and burial costs a duplication of benefits and will not consider more general insurance for which proceeds may be used towards funeral costs. This will continue to be program’s approach and it will be further clarified in the next version of the Individual Assistance Program and Policy Guide (IAPPG). In addition, FEMA is also enhancing the change management process as it relates to critical changes made throughout the assistance period to ensure that all relevant personnel and staff are aware of changes to the operating procedures and program requirements.
    FY2025
    Planned
    Audit
    The Payment Integrity Information Act of 2019 (PIIA) requires agencies to review and assess all programs and activities they administer and identify those determined to be susceptible to significant improper payments, estimate the annual amount of improper payments, and submit those estimates to Congress. In accordance with the Office of Management and Budget (OMB) Circular A-123, Appendix C, "Requirements for Payment Integrity Improvement", federal agencies are required to assess improper payments and report annually on their efforts. In compliance with these requirements, the Federal Emergency Management Agency (FEMA) Funeral Assistance program will conduct a review and publish results in 2025 over fiscal year (FY) 2023 program disbursement activity. In addition, FEMA will perform an assessment of internal control over financial reporting including performing tests of operating effectiveness, for the FY 2025 performance period. These internal control assessments include a review over Grants Management.
    FY2025
    Planned

Overpayments

The DHS Federal Emergency Management Agency (FEMA) provides financial assistance under the Other Needs Assistance (ONA) provision of the Individuals and Households Program (IHP) to individuals and households with disaster-related funeral expenses. Under the Coronavirus Response and Relief Supplemental Appropriations Act, 2021, and the American Rescue Plan Act of 2021, FEMA is authorized to provide financial assistance for funeral costs specifically related to COVID-19 for funeral expenses at 100 percent federal cost share. In accordance with the requirements for the program, funeral assistance would only be provided to applicants that had met the eligibility and documentation requirements while also not having exceeded the funeral assistance maximum award amounts (for each COVID-19 related funeral and/or annual maximum ONA award amounts by applicant): • Eligibility – To include but not limited to requirements such as the decedent’s cause of death, incurred funeral expenses that were not covered by other sources (such as insurance, assistance from voluntary agencies, etc.), location of death, etc. Per program policy requirements, FEMA will verify applicant eligibility prior to awarding Funeral Assistance. • Required Documentation – To include but not limited to documentation requirements such as a death certificate, proof of funeral expenses, insurance or funeral benefits, etc. Per program policy requirements, FEMA must receive all required documentation prior to awarding Funeral Assistance. As the FEMA Funeral Assistance program was designed as a reimbursement program to provide financial assistance to those that had already incurred costs and met the required eligibility and documentation requirements, it was determined that all identified overpayments are inside of the agency's control to prevent improper payments from occurring.
Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $52.42 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $52.42 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $0.0 M

Overpayment type Eligibility element/information needed Eligibility amount
Overpayments Within Agency Control Financial $50.84 M
Overpayments Within Agency Control Receiving Benefits from Other Sources $1.57 M

Overpayment type Mitigation strategies taken Mitigation strategies planned
Overpayments within the agency’s control Audit, Automation, Change Process, Cross Enterprise Sharing, Predictive Analytics, Training Audit, Change Process, Training

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $7.05 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $7.05 M

Eligibility element/information needed Eligibility amount
Financial $7.05 M

Mitigation strategies taken Mitigation strategies planned
Audit, Automation, Change Process, Cross Enterprise Sharing, Predictive Analytics, Training Audit, Change Process, Training

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

Additional information

$7.05 M

Unknown Payment Details

Evaluation of corrective actions

The majority of the Federal Emergency Management Agency (FEMA) identified Improper Payments (IPs) stemmed from the required human intervention for manually processing COVID-19 Funeral Assistance disbursements. As such, the majority of the FEMA corrective actions taken have focused on policy and procedural enhancements, training, and process improvements to reduce and prevent future IPs. The COVID-19 pandemic brought overwhelming grief to many families. FEMA has remained committed to help people before, during, and after disasters and is dedicated to helping ease some of the financial stress and burden caused by the virus.

The Consolidated Appropriations Act, 2021, appropriated additional funding to the Disaster Relief Fund to reimburse funeral expenses incurred through December 31, 2020. Subsequently, the American Rescue Plan Act of 2021 (ARPA; enacted March 11,2021) also required FEMA to provide Funeral Assistance for deaths associated with the COVID-19 pandemic and did not limit the date for expenses incurred. FEMA began accepting applications on April 12, 2021 and, per FEMA’s policy, the agency will reimburse for eligible funeral expenses incurred after January 20, 2020, for deaths attributed to the COVID-19 pandemic. Although the COVID-19 incident period ended on May 11, 2023, FEMA will continue to provide funeral assistance reimbursements until September 30, 2025 to those that have lost loved ones due to the pandemic.

As highlighted above, the FEMA Funeral Assistance program related to the COVID-19 pandemic is expected to complete all disbursement activity by the end of fiscal year (FY) 2025 and has seen substantial reductions in the program's disbursement size and activity already. For example, in the less than six months of FY 2021 that FEMA disbursed Funeral Assistance, the program disbursed over $1,166 million. For the full FY 2022 reporting period, the FEMA Funeral Assistance program disbursed just over $1,697 million. Disbursement activity for the FEMA Funeral Assistance program is down to just over $300 million in FY 2023. With the reduction in the program size coupled with the expected end of the program in September 2025, it is not cost beneficial for the agency to implement extensive corrective actions for the sunsetting program in FY 2025.

By expanding costs eligible for reimbursement under COVID-19 Funeral Assistance, the Federal Emergency Management Agency (FEMA) reasonably used the discretion and authority under the Robert T. Stafford Disaster Relief Emergency Assistance Act (Stafford Act). This action appropriately balanced the need to streamline the assistance process to account for the differences between a nationwide emergency resulting in over one million deaths in the United States – simultaneously impacting every state, territory, and Tribal Nation – and a traditional major disaster declaration. FEMA has acknowledged that the agency's guidance must be consistent with the law and applied equitably but reiterates the agency's broad statutory and regulatory authorities related to Funeral Assistance, providing the agency flexibility to expand current policy. Given the varied nature of disasters and the many different laws and customs related to funerals, burials, reinternments across the states, territories, and Tribal Nations, there is always a potential for disaster specific policy.

The FEMA Funeral Assistance program related to the COVID-19 pandemic is expected to complete all disbursement activity by the end of fiscal year (FY) 2025 and has seen substantial reductions in the program's disbursement size and activity already. For example, in the less than six months of FY 2021 that FEMA disbursed Funeral Assistance, the program disbursed over $1,166 million. For the full FY 2022 reporting period, the FEMA Funeral Assistance program disbursed just over $1,697 million. Disbursement activity for the FEMA Funeral Assistance program is down to just over $300 million in FY 2023. With the reduction in the program size coupled with the expected end of the program in September 2025, it is not cost beneficial for the agency to implement extensive corrective actions for the sunsetting program in FY 2025.

The majority of the Federal Emergency Management Agency (FEMA) identified Improper Payments (IPs) stemmed from the required human intervention for manually processing COVID-19 Funeral Assistance disbursements. As such, the majority of the FEMA corrective actions taken have focused on policy and procedural enhancements, training, and process improvements to reduce and prevent future IPs.

The Payment Integrity Information Act of 2019 (PIIA) requires agencies to review and assess all programs and activities they administer and identify those determined to be susceptible to significant improper payments, estimate the annual amount of improper payments, and submit those estimates to Congress. In accordance with the Office of Management and Budget (OMB) Circular A-123, Appendix C, "Requirements for Payment Integrity Improvement", federal agencies are required to assess improper payments and report annually on their efforts. In compliance with these requirements, the FEMA Funeral Assistance program will conduct a review and publish results in 2025 over fiscal year (FY) 2023 program disbursement activity. The results of the 2025 review will provide a more holistic indicator as to the continued success of the corrective action efforts.

Although the Federal Emergency Management Agency (FEMA) Funeral Assistance program is reporting an estimated error rate that identifies the program is susceptible to significant improper payments, FEMA is confident that the agency's corrective action plans are being effectively implemented and prioritized to limit and reduce the Improper Payments (IPs) for the Funeral Assistance program. The majority of the FEMA identified IPs stemmed from the required human intervention for manually processing COVID-19 Funeral Assistance disbursements. As such, the majority of the FEMA corrective actions taken and additional action planned to be taken focus on policy and procedural enhancements, training, and process improvements to reduce and prevent future IPs.

The Payment Integrity Information Act of 2019 (PIIA) requires agencies to review and assess all programs and activities they administer and identify those determined to be susceptible to significant improper payments, estimate the annual amount of improper payments, and submit those estimates to Congress. In accordance with the Office of Management and Budget (OMB) Circular A-123, Appendix C, "Requirements for Payment Integrity Improvement", federal agencies are required to assess improper payments and report annually on their efforts. Incompliance with these requirements, the FEMA Funeral Assistance program will conduct a review and publish results in 2025 over fiscal year (FY) 2023 program disbursement activity. The results of the 2025 review will provide a more holistic indicator as to the continued success of the corrective action efforts.

Future payment integrity outlook

Federal Emergency Management Agency - Funeral Assistance has NOT established a baseline.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $300.05 M
Current year +1 estimated future improper payments $10.5 M
Current year +1 estimated future unknown payments $0 M
Current year +1 estimated future improper payment and unknown payment rate 3.5 %

The program's current year improper payment and unknown payment rate of 3.5 % may or may not be the tolerable rate. The agency has not yet determined the tolerable rate for this program.

As 2024 is the first year that testing has been conducted for the Federal Emergency Management Agency (FEMA) Funeral Assistance program, a second consecutive year of testing is expected to be completed with results published in 2025. Per the Office of Management and Budget (OMB) Circular No. A-123, Appendix C guidance, based on that 24-month reporting period, a baseline will be established at that time if no significant changes are noted. From the established baseline, the agency will have a more accurate basis to establish a tolerable rate. However, based on the intent of the program and the program's relation to a nationwide emergency disaster, it is expected that the tolerable rate will be established at approximately 2.5 percent.

Although the Federal Emergency Management Agency (FEMA) Funeral Assistance program is reporting an estimated error rate that identifies the program is susceptible to significant improper payments, FEMA is confident that the agency has what is needed with respect to internal controls, human capital and information system and other infrastructure to reduce Improper Payments (IPs) and Unknown Payments (UPs) to a tolerable rate. FEMA has specific reporting requirements established by the Disaster Recovery Reform Act of 2018 (DRRA), as amended. The DRRA authorizes FEMA to waive a debt owed to the Government if covered assistance provided to an individual or household on or after October 28, 2012, was distributed in error by FEMA or if such assistance is subject to a claim or legal action. Section 1216(a)(3) of the DRRA requires the DHS Office of the Inspector General (OIG) to monitor FEMA’s distribution of covered assistance to individuals and households to determine the percentage distributed based on an error. Should the error rate exceed 4 percent of the total amount of covered assistance distributed, the DRRA requires FEMA to report actions it will take to reduce the error rate to congressional committees. FEMA will continue to strive to improve the IP rates for the Funeral Assistance program with the existing resourcing. However, as error rates continue to be reported below the 4 percent threshold established by the DRRA to prompt for congressional notification and attention, FEMA is confident that the agency does not specifically need additional human capital, information system and other infrastructure, etc. resourcing to sustain and further reduce the estimated error rate for the program.

No additional resources have been requested specifically for the Federal Emergency Management Agency (FEMA) Funeral Assistance program in the DHS FY 2025 Budget. To continue to support disaster response, FEMA included a major disaster allocation to address ongoing Stafford Act disasters in the FY 2025 budget request which includes funding for continued recovery efforts in support of COVID-19, Hurricanes Maria, Fiona, and Ian, and other disaster activity.

Additional programmatic information

In response to the COVID-19 pandemic, President Donald J. Trump issued a nationwide emergency declaration under Section 501(b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act; 42 U.S.C. §§5121 et seq.). Subsequently, President Trump and President Joseph R. Biden, Jr. approved major disaster declarations for 50 states, 5 territories, the District of Columbia, and 3 tribes under Stafford Act Section 401. Funeral Assistance is a form of Other Needs Assistance (ONA) that the Federal Emergency Management Agency (FEMA) may provide when the President authorizes the Individuals and Households Program (IHP)—a type of Individual Assistance (IA)—pursuant to a Stafford Act declaration of emergency or major disaster.

In the case of the COVID-19 pandemic, Congress authorized FEMA to provide Funeral Assistance through legislation. Congress required FEMA to provide assistance for pandemic-related funeral expenses incurred on or after January 20 through December 31, 2020, for deaths attributable to COVID-19 under the Stafford Act COVID-19 pandemic declarations pursuant to Section 201 of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (P.L.116-260, Div. M). Congress also authorized a 100 percent federal cost share. Additionally, Congress appropriated $2 billion to the Disaster Relief Fund (DRF), to remain available until expended, to carry out such purposes. Subsequently, Congress required FEMA to provide assistance for pandemic-related funeral expenses incurred on or after January 20, 2020, at a 100 percent federal cost share, pursuant to Section 4006 the American Rescue Plan Act of 2021 (ARPA; P.L. 117-2). Congress also appropriated $50 billion to the DRF, to remain available until September 30, 2025, for costs associated with major disaster declarations, to include the provision of assistance under ARPA Section 4006. The Stafford Act COVID-19 pandemic declarations for the declared States, territories, and District of Columbia (but not the three tribes) were then amended to reflect the authorization of IA, limited to COVID-19 Funeral Assistance. FEMA began accepting applications on April 12, 2021 through a dedicated call center.

Per FEMA’s policy on COVID-19 Funeral Assistance, the agency will reimburse up to $9,000 in eligible funeral expenses incurred on or after January 20, 2020, at 100 percent federal cost share, for deaths attributed to the COVID-19 pandemic and for applicants that have met the eligibility criteria to receive COVID-19 Funeral Assistance. As of October 2022, FEMA had provided over $2.8 billion to eligible applicants with over 400,000 applications approved that, on average, has provided applicants an average award of $6,400 to cover eligible funeral expenses incurred related to the loss of a loved one due to the COVID-19 pandemic.

In order to disburse the Funeral Assistance timely and equitably, FEMA has had over 9.5 million web page views, translated graphics into over 29 different languages, supported 76 languages through the helpline, and has placed over 22,000 outbound calls to applicants. On February 9, 2023, the FEMA Administrator announced that on May 11, 2023, the agency will close the incident periods for all emergency and major disasters declared for the COVID-19 pandemic under the Stafford Act. FEMA guidance reports that the end of the incident period will not affect the application or eligibility for Funeral Assistance, and that “FEMA intends to continue providing COVID-19 Funeral Assistance through September 30, 2025, which is the date identified by Congress in the ARPA appropriation”.

Accountability for detecting, preventing, and recovering improper payments

Department-wide, Component managers are responsible for completing internal control work on payment processing as part of the Department’s Office of Management and Budget (OMB) Circular No. A-123 efforts. They are further responsible for establishing and maintaining sufficient internal controls, including a control environment that prevents improper payments from being made, effectively managing improper payment risks, and promptly detecting and recovering any improper payments that may occur. Management’s efforts, to include within DHS Headquarters as well Components, around improper payments are subject to an annual compliance review by the DHS’s Office of Inspector General (OIG). These measures are designed to hold the appropriate personnel accountable for meeting applicable improper payment reduction targets and establishing and maintaining strong internal controls around payment management.

Department-wide, the goals and requirements for strong payment integrity are communicated to all levels of staff throughout the DHS Office of the Chief Financial Officer and to relevant program office and procurement staff. The Department has taken extensive measures to ensure that managers, accountable officers, to include Component Chief Financial Officers (CFOs), programs, States, and localities are held accountable for reducing and recapturing improper payments. The Department’s CFO and senior staff have incorporated improper payment expectations and performance in their annual performance plans.

The Federal Emergency Management Agency (FEMA) regularly engages with recipients and process owners in monthly remediation meetings to ensure that appropriate accountable officials are actively taking actions to reduce Improper Payments (IPs) and identify and categorize Unknown Payment (UP) transactions as either proper or improper. If a transaction is deemed proper, no further action is taken. If a transaction is deemed technically improper, FEMA requires a corrective action be put in place in order resolve issues surrounding procedures, policies, and trainings. If a transaction is deemed improper and is associated with monetary loss, then the transaction is submitted through the FEMA debt collection process including Notice of Potential Debt Letters and Treasury Offset, if applicable.

In addition, FEMA tracks any changes to the program. Training, information sharing, and the documentation of new processes will be prioritized. Payment management reviews related to Internal Control over Financial Reporting are conducted within the DHS control environment each fiscal year accompanied with processes to review and examine for improper payments, to include but not limited to duplicate payment reviews, card payment reviews, payroll analysis, etc.

  • FY 2025 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    10/2022 - 09/2023


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-2.61

Causes

The DHS Federal Emergency Management Agency (FEMA) provides financial assistance under the Other Needs Assistance (ONA) provision of the Individuals and Households Program (IHP) to individuals and households with disaster-related funeral expenses. Under the Coronavirus Response and Relief Supplemental Appropriations Act, 2021, and the American Rescue Plan Act of 2021, FEMA is authorized to provide financial assistance for funeral costs specifically related to COVID-19 for funeral expenses at 100 percent federal cost share. In accordance with the requirements for the program, funeral assistance would only be provided to applicants that had met the eligibility and documentation requirements while also not having exceeded the funeral assistance maximum award amounts (for each COVID-19 related funeral and/or annual maximum ONA award amounts by applicant):
• Eligibility – To include but not limited to requirements such as the decedent’s cause of death, incurred funeral expenses that were not covered by other sources (such as insurance, assistance from voluntary agencies, etc.), location of death, etc. Per program policy requirements, FEMA will verify applicant eligibility prior to awarding Funeral Assistance.
• Required Documentation – To include but not limited to documentation requirements such as a death certificate, proof of funeral expenses, insurance or funeral benefits, etc. Per program policy requirements, FEMA must receive all required documentation prior to awarding Funeral Assistance.

Improper payments identified have been primarily related to inadequate supporting documentation to substantiate eligibility and an inaccurate review and/or calculation by FEMA of the reimbursement amount to be disbursed that aligns within program guidance and payment cap thresholds established per event and per applicant.

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $9.1 M
Amount of overpayments outside the agency's control $0.0 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
Amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
Amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $9.1 M

Underpayment root cause Underpayment amount
Amount of underpayments $3.89 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $3.89 M

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

The amount that could either be proper or improper but the agency is unable to determine whether it was proper or improper as a result of insufficient or lack of documentation $0.0 M

Prevention

Per program policy requirements, applicants may only receive financial assistance for expenses incurred that have not already been covered, paid, and/or reimbursed by other sources. As noted in the required documentation, applicants for the Federal Emergency Management Agency (FEMA) Funeral Assistance reimbursement must provide FEMA with proof of funds received from other sources specifically designated for funeral costs. COVID-19 Funeral Assistance may not duplicate burial or funeral insurance proceeds, pre-planned or pre-paid funeral contracts, pre-paid trust for funeral expenses, irrevocable trust for Medicaid, financial assistance from voluntary organizations, government programs or agencies, or any other sources specifically designated for funeral expenses. As noted in the required documentation, applicants for Funeral Assistance must provide FEMA with documentation demonstrating that funeral expenses had been incurred for the decedent. The documentation, such as receipts or funeral home contract, must include all the following information:
• The applicant’s name indicated as the responsible party for the expenses;
• The total amount of the funeral expenses;
• The decedent’s name; and
• The date funeral expenses were incurred.

The National Emergency Management Information System (NEMIS) is the information technology system that houses the survivor case files and is the master database that FEMA uses to administer its assistance programs and make disaster assistance decisions. NEMIS supports assistance programs across the Individuals and Households Program (IHP) spectrum, which is divided into Housing Assistance and Other Needs Assistance (ONA). Because Funeral Assistance is a part of ONA, FEMA uses NEMIS to support funeral assistance processing.

FEMA’s processing system, NEMIS, performs automated checks on certain data elements within a funeral assistance application to identify potential duplications. FEMA checks for duplications in data fields such as applicant or co-applicant social security number; damaged dwelling address (DDA); and deceased individual’s name, and social security number. FEMA routes all these sources of potential duplication, when identified, to the Duplicate Investigation queue for manual review. Applications in the Duplicate Investigation queue require manual clearance of any potential duplications before they may continue being processed. For most Individual Assistance programs processed through NEMIS, the DDA field pertains to the address where real or personal property damage occurred. In the case of COVID-19 Funeral Assistance, FEMA uses the DDA data field to document the location where the COVID-19 death occurred. During the COVID-19 pandemic, many deaths occurred at shared locations such as hospitals and medical facilities. As such, the DDA data field is a common source of potential duplications identified by the NEMIS system. All financial related errors are attributed to the required human intervention for manually processing COVID-19 funeral assistance, to include manually reviewing NEMIS flags.

FEMA acquired the services of a call center service provider contractor to assist with processing the large volume of COVID-19 Funeral Assistance applications. The contractor takes incoming registration calls, enters data for new and prior registrations, performs initial case eligibility reviews, and makes outbound calls to verify the authenticity of received documents. FEMA identified process improvements for COVID-19 Funeral Assistance staff, including granting the contractor access to Homeland Security Information Network support pages. The resource serves to increase access to guidance and standard operating procedures. FEMA is also expanding collaboration with the contractor to improve the frequency and quality of quality control reporting. FEMA's Individual Assistance Division, Cadre Management and Training Branch developed an eLearning training course and provided it to FEMA Applicant Services Section personnel on April 3, 2023, as refresher training for staff processing COVID-19 Funeral Assistance.

The Payment Integrity Information Act of 2019 (PIIA) requires agencies to review and assess all programs and activities they administer and identify those determined to be susceptible to significant improper payments, estimate the annual amount of improper payments, and submit those estimates to Congress. In accordance with the Office of Management and Budget (OMB) Circular No. A-123, Appendix C, "Requirements for Payment Integrity Improvement", federal agencies are required to assess improper payments and report annually on their efforts. In compliance with these requirements, the FEMA Funeral Assistance program has conducted reviews and published results in 2024 and 2025, over fiscal year (FY) 2022 and 2023 program disbursement activity. The FEMA Funeral Assistance program will conduct a review and publish results in 2026 over FY 2024 program disbursement activity. As FEMA is assessing disbursement activity for the program two years in arrears, impacts of corrective actions taken in 2024 and prior may be seen in the 2026 assessment results.
By expanding costs eligible for reimbursement under COVID-19 Funeral Assistance, the Federal Emergency Management Agency (FEMA) used the discretion and authority under the Robert T. Stafford Disaster Relief Emergency Assistance Act (Stafford Act). FEMA has acknowledged that the agency's guidance must be consistent with the law but reiterates the agency's broad statutory and regulatory authorities related to Funeral Assistance, providing the agency flexibility to expand current policy. Given the varied nature of disasters and the many different laws and customs related to funerals, burials, reinternments across the states, territories, and Tribal Nations, there is always a potential for disaster specific policy.

Most of the identified Improper Payments (IPs) stemmed from the required human intervention for manually processing COVID-19 Funeral Assistance disbursements. As such, most of the FEMA corrective actions taken have focused on policy and procedural enhancements, training, and process improvements to reduce and prevent future IPs.

FEMA began accepting applications on April 12, 2021 and, per FEMA’s policy, the agency will reimburse for eligible funeral expenses incurred after January 20, 2020, for deaths attributed to the COVID-19 pandemic. Although the COVID-19 incident period ended on May 11, 2023, FEMA will continue to provide funeral assistance reimbursements for applications received by September 30, 2025. The FEMA Funeral Assistance program related to the COVID-19 pandemic is expected to complete all disbursement activity by no later than March 30, 2026 and has seen substantial reductions in the program's disbursement size. With the reduction in the program size coupled with the end of the application period on September 30, 2025, it is not cost beneficial for the agency to implement extensive corrective actions for the sunsetting program.

The majority of the Federal Emergency Management Agency (FEMA) identified Improper Payments (IPs) stemmed from the required human intervention for manually processing COVID-19 Funeral Assistance disbursements. As such, most of the FEMA corrective actions taken have focused on policy and procedural enhancements, training, and process improvements to reduce and prevent future IPs.

The Payment Integrity Information Act of 2019 (PIIA) requires agencies to review and assess all programs and activities they administer and identify those determined to be susceptible to significant improper payments, estimate the annual amount of improper payments, and submit those estimates to Congress. In accordance with the Office of Management and Budget (OMB) Circular A-123, Appendix C, "Requirements for Payment Integrity Improvement", federal agencies are required to assess improper payments and report annually on their efforts. In compliance with these requirements, the FEMA Funeral Assistance program will conduct a review and publish results in 2026 over fiscal year (FY) 2024 program disbursement activity. As FEMA is assessing disbursement activity for the program two years in arrears, impacts of corrective actions taken in 2024 and prior may be seen in the 2026 assessment results.

FEMA began accepting applications on April 12, 2021 and, per FEMA’s policy, the agency will reimburse for eligible funeral expenses incurred after January 20, 2020, for deaths attributed to the COVID-19 pandemic. Although the COVID-19 incident period ended on May 11, 2023, FEMA will continue to provide funeral assistance reimbursements for applications received by September 30, 2025. The FEMA Funeral Assistance program related to the COVID-19 pandemic is expected to complete all disbursement activity by no later than March 30, 2026 and has seen substantial reductions in the program's disbursement size. With the reduction in the program size coupled with the end of the application period on September 30, 2025, it is not cost beneficial for the agency to implement extensive corrective actions for the sunsetting program.

Payment type Mitigation strategies taken Mitigation strategies planned
Overpayments Audit Audit
Underpayments Audit Audit

Eligibility element/information needed Description of the eligbility element/information
Financial The financial position or status of a beneficiary, recipient, or their family
Receiving Benefits from Other Sources Beneficiary or recipient is receiving benefits from an additional source

Additional information

In response to the COVID-19 pandemic, President Donald J. Trump issued a nationwide emergency declaration under Section 501(b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act; 42 U.S.C. §§5121 et seq.). Subsequently, President Trump and President Joseph R. Biden, Jr. approved major disaster declarations for fifty states, five territories, the District of Columbia, and three tribes under Stafford Act Section 401. Funeral Assistance is a form of Other Needs Assistance (ONA) that the Federal Emergency Management Agency (FEMA) may provide when the President authorizes the Individuals and Households Program (IHP)—a type of Individual Assistance (IA)—pursuant to a Stafford Act declaration of emergency or major disaster.

In the case of the COVID-19 pandemic, Congress authorized FEMA to provide Funeral Assistance through legislation. Congress required FEMA to provide assistance for pandemic-related funeral expenses incurred on or after January 20 through December 31, 2020, for deaths attributable to COVID-19 under the Stafford Act COVID-19 pandemic declarations pursuant to Section 201 of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (P.L.116-260, Div. M). Congress also authorized a 100 percent federal cost share. Additionally, Congress appropriated $2 billion to the Disaster Relief Fund (DRF), to remain available until expended, to carry out such purposes. Subsequently, Congress required FEMA to provide assistance for pandemic-related funeral expenses incurred on or after January 20, 2020, at a 100 percent federal cost share, pursuant to Section 4006 the American Rescue Plan Act of 2021 (ARPA; P.L. 117-2). Congress also appropriated $50 billion to the DRF, to remain available until September 30, 2025, for costs associated with major disaster declarations, to include the provision of assistance under ARPA Section 4006. The Stafford Act COVID-19 pandemic declarations for the declared States, territories, and District of Columbia (but not the three tribes) were then amended to reflect the authorization of IA, limited to COVID-19 Funeral Assistance.

Per FEMA’s policy on COVID-19 Funeral Assistance, the agency will reimburse up to $9,000 in eligible funeral expenses incurred on or after January 20, 2020, at 100 percent federal cost share, for deaths attributed to the COVID-19 pandemic and for applicants that have met the eligibility criteria to receive COVID-19 Funeral Assistance. FEMA began accepting applications on April 12, 2021, through a dedicated call center. Execution of the program has enabled over 9.5 million web page views, translated graphics into over 29 different languages, and supported 76 languages through the helpline. On February 9, 2023, the FEMA Administrator announced that on May 11, 2023, the agency will close the incident periods for all emergency and major disasters declared for the COVID-19 pandemic under the Stafford Act. FEMA guidance reports that the end of the incident period will not affect the application or eligibility for Funeral Assistance, and that “FEMA intends to continue providing COVID-19 Funeral Assistance through September 30, 2025, which is the date identified by Congress in the ARPA appropriation”. The application period was officially closed by FEMA on September 30, 2025 and all disbursement activity is expected to be completed by no later than March 30, 2026.

Reduction target

4.0 %

Although the Federal Emergency Management Agency (FEMA) Funeral Assistance program is reporting an estimated error rate that identifies the program is susceptible to significant improper payments, FEMA is confident that the agency has what is needed with respect to internal controls, human capital and information system and other infrastructure to reduce Improper Payments (IPs) and Unknown Payments (UPs) to a tolerable rate.

FEMA has specific reporting requirements established by the Disaster Recovery Reform Act of 2018 (DRRA), as amended. The DRRA authorizes FEMA to waive a debt owed to the Government if covered assistance provided to an individual or household on or after October 28, 2012, was distributed in error by FEMA or if such assistance is subject to a claim or legal action. Section 1216(a)(3) of the DRRA requires the DHS Office of Inspector General (OIG) to monitor FEMA’s distribution of covered assistance to individuals and households to determine the percentage distributed based on an error. Should the error rate exceed 4 percent of the total amount of individuals and households covered assistance distributed, to include the COVID-19 Funeral Assistance, the DRRA requires FEMA to report actions it will take to reduce the error rate to congressional committees.

FEMA will continue to strive to improve the IP rates for the Funeral Assistance program with the existing resourcing. The FEMA Funeral Assistance program related to the COVID-19 pandemic is expected to complete all disbursement activity by no later than March 30, 2026 and has seen substantial reductions in the program's disbursement size. With the reduction in the program size coupled with the end of the application period on September 30, 2025, it is not cost beneficial for the agency to implement extensive corrective actions for the sunsetting program.

No additional resources have been requested specifically for the Federal Emergency Management Agency (FEMA) Funeral Assistance program in the DHS fiscal year (FY) 2026 budget. To continue to support disaster response, FEMA included proposed budget allocations to address ongoing Stafford Act disasters in the FY 2026 budget request which includes continued Disaster Relief Fund (DRF) funding for Individual Assistance.

For additional detail on the DHS FY 2026 budget, please refer to the DHS.gov website.

Department-wide, Component managers are responsible for completing internal control work on payment processing as part of the Department’s Office of Management and Budget (OMB) Circular No. A-123 efforts. They are further responsible for establishing and maintaining sufficient internal controls, including a control environment that prevents improper payments from being made, effectively managing improper payment risks, and promptly detecting and recovering any improper payments that may occur. Management’s efforts, to include within DHS Headquarters as well Components, around improper payments are subject to an annual compliance review by the DHS’s Office of Inspector General (OIG). These measures are designed to hold the appropriate personnel accountable for meeting applicable improper payment reduction targets and establishing and maintaining strong internal controls around payment management.

The goals and requirements for strong payment integrity are communicated Department-wide to all levels of staff throughout the DHS Office of the Chief Financial Officer and to relevant program office and procurement staff. The Department has taken extensive measures to ensure that managers, accountable officers, to include Component Chief Financial Officers (CFOs), programs, States, and localities are held accountable for reducing and recapturing improper payments. The Department’s CFO and senior staff have incorporated improper payment expectations and performance in their annual performance plans.

The Federal Emergency Management Agency (FEMA) regularly engages with recipients and process owners in monthly remediation meetings to ensure that appropriate accountable officials are actively taking actions to reduce Improper Payments (IPs) and identify and categorize Unknown Payment (UP) transactions as either proper or improper. If a transaction is deemed proper, no further action is taken. If a transaction is deemed technically improper, FEMA requires a corrective action be put in place in order resolve issues surrounding procedures, policies, and trainings. If a transaction is deemed improper and is associated with monetary loss, then the transaction is submitted through the FEMA debt collection process including Notice of Potential Debt Letters and Treasury Offset, if applicable.

In addition, FEMA tracks any changes to the program. Training, information sharing, and the documentation of new processes will be prioritized. Payment management reviews related to Internal Control over Financial Reporting are conducted within the DHS control environment each fiscal year accompanied with processes to review and examine for improper payments, to include but not limited to duplicate payment reviews, card payment reviews, payroll analysis, etc.

$3.89 M