Enhanced State Mitigation Planning: Basics for New Enhanced States

Overview

An enhanced state mitigation plan documents a proven commitment to long-term risk reduction. Being enhanced recognizes a state’s ongoing and coordinated work to reduce losses from natural hazards, protect life and property, and create more resilient communities. Enhanced states’ mitigation plans go beyond the minimum requirements. These states’ plans represent holistic mitigation programs integrated across partners, staff and offices. The commitment to mitigation is demonstrated both in the plan and in day to day operations. Enhanced states have the capacity, resources, and/or skills to build resilience for communities across the state.

Enhanced states receive an additional 5% in Hazard Mitigation Grant Program (HMGP) funds after a disaster. This means they receive 20% of estimated eligible Stafford Act assistance instead of 15%. Enhanced states share the responsibility for reducing risk across state agencies and departments. This “sharing the load” reduces risk more efficiently. It also connects the right resources with community needs.

Getting Started

To be enhanced, a state must show it performs beyond the minimum across the entire mitigation program. Enhanced status is not limited to excellence in using FEMA’s Hazard Mitigation Assistance (HMA) and mitigation planning programs. Enhanced states look beyond the emergency management agency to encourage risk reduction across staff, activities, and programs. They use their own, FEMA, and other federal and non-federal resources to advance mitigation outcomes. They routinely include risk reduction in their decision-making and investment decisions.

Enhanced states take their mitigation commitments seriously. They support communities by reviewing local and or tribal mitigation plans on time, providing mitigation training, and being an implementation partner with technical assistance and funding.

Enhanced status is granted based on the current mitigation program. This means the state is going above the minimum when it submits the enhanced plan. The mitigation program should grow over time, but enhanced status is not granted based on future activities. There are no conditional approvals. Documentation is important to demonstrate enhanced status. may know they are operating at a higher level, but they need to show it in the mitigation plan.

States must maintain enhanced status over time. An enhanced state continually manages its performance with respect to mitigation. Enhanced states must be able to adapt to changing circumstances. For example, enhanced states are able to support risk reduction through disasters, staff turnover, or new funding.

FEMA and the state will meet at least once a year to review and validate the mitigation program. This enhanced state validation is required to check that the state is maintaining its mitigation program. The validation is a chance to share the mitigation success stories every year.

What FEMA Evaluates

FEMA reviews six areas to determine if a state meets the enhanced requirements.

  • Standard plan requirements. All enhanced plans must meet the standard state requirements. States submitting for enhanced status must also meet their mitigation planning responsibilities.
  • HMA Grants Management Performance. Because enhanced states get more HMGP funding, FEMA validates the state’s grants management performance. This is one of the first (pre-qualification) steps in the new enhanced plan review process. FEMA reviews the most recent consecutive four quarters of grants performance data during the enhanced review. The state must submit timely, accurate, and complete applications, reports, and analyses. It must complete HMA projects within the required timeframes. The word “all” in this section means the state must meet these requirements 100% of the time. When evaluating grants performance data against the HMA grants performance requirements, FEMA can consider minor or one-time deficiencies or other extenuating circumstances as part of the review. See Appendix B, Section B.5 and the Enhanced State Mitigation Plan Regulation Checklist in the Guide for more information.
  • Integrated Planning. Long-term risk reduction is more effective when it is done in partnership with others. Integrated planning means bringing partners together, aligning goals and strategies across the whole community, and leveraging action for greater resilience. Enhanced states show a history of working across agencies and stakeholders to become more resilient. They have shared objectives and can show mitigation outcomes. Enhanced states also use the full range of FEMA resources to support their risk reduction programs.
  • Demonstrated Commitment to a Comprehensive Mitigation Program. Enhanced states show their commitment through a combination of activities outlined in Element E7 of the Guide. These activities include a demonstrated commitment to:
    • Statewide programs, initiatives, and plans that advance mitigation and resilience.
    • Mitigation training and capability building. This includes helping local governments update and adopt their plans before they expire.
  • Effective Use of Existing Mitigation Programs. Enhanced states demonstrate the full and effective use of their own programs, FEMA programs, other federal programs, and nongovernmental resources to reduce risk. Full and effective use of existing mitigation programs means that an enhanced state uses a broad range of resources to advance mitigation. It uses each resource to the maximum extent possible.
  • Implementation Capability. Enhanced states implement their mitigation plan and support local and tribal (as applicable) governments in implementing theirs. This means there is a system to prioritize actions. The state assesses the effectiveness of mitigation activities and applies lessons learned to the mitigation strategy.

Enhanced states know that risk cannot be reduced in a silo. They use partners and resources across the whole community to increase resilience. They have the skills and resources to reduce risk over the long term.

The Process

Becoming enhanced takes time and effort. There is a lot of information for state partners to put together. This is why the conversation about becoming enhanced must start early. The process in the Guide uses longer lead times and more pre-submission coordination. This pre-work helps states know where they stand so they can get technical assistance to meet the enhanced requirements. States should work with their FEMA regional planner early and often to achieve enhanced status.

The full process is in Appendix B of the Guide. Here is a summary:

  • At least 12 months before expiration: the state notifies FEMA of its interest in becoming enhanced. FEMA will coordinate with the state. The state submits its last four quarters of grants performance data. HMA checks the grants performance data within 90 days and makes recommendations. FEMA’s review helps the state know early on if there are any issues with the grants performance data. It provides a chance to make changes before the official submission.
  • At least 180 days before expiration: the state submits the plan and the region starts the review. The National Grants Management Panel begins. The panel includes FEMA regional and headquarters grants management staff. A panel ensures that FEMA consistently reviews grants management performance across the nation. The review process will take time and the state may need to address required revisions from the panel or regional review. Submitting a plan 3 months before expiration reduces the risk of the plan expiring before FEMA’s review is complete.
  • If the plan meets the grants management requirements and the region approves the plan, at least 60 days before expiration: the plan moves to the National Planning Review Panel. This panel supports consistent review of plans nationwide. It includes a minimum of one regional member from outside the state’s region, one FEMA headquarters member, and one non-FEMA member. FEMA headquarters convenes this panel. The panel reviews the plan, focusing on Elements E1 and E6 through E9. The panel may provide comments on to other elements.
  • At least 30 days before expiration: the panel’s results are returned to the FEMA region. The regional mitigation planning staff prepare the final plan review tool and notify the state whether the plan is approved pending adoption or if it needs revisions.
  • After approvable pending adoption status is granted: the state adopts the plan and submits documentation of adoption to FEMA. FEMA issues the approval letter.

Review timeframes will be longer if revisions are needed. If the timeline for becoming enhanced is not met during the 5-year update, the plan may receive standard plan approval. This ensures there is no lapse in grants eligibility while work progresses on enhanced status.

Submitting a Plan for an Off-Cycle Review

It is not uncommon for a state to be approved as a standard and then submit for enhanced status later. The Guide ties the enhanced submission process to plan expiration. However, a state can submit for enhanced status outside the 5-year approval cycle. This is called an off-cycle review. Even with an off-cycle review, the same overall process is followed . If a plan gets enhanced approval after standard, the approval date of the plan does not change. It remains 5 years from the standard plan approval date.

One year before the state plans to submit for enhanced status, the state should notify the FEMA regional planner. It should submit its most recent four quarters of grants performance data for the HMA pre-qualification. The state and the region will jointly build a submission and review schedule that has enough time for all the steps. The schedule must use the same steps and timeframes as the Guide. Instead of counting down to an expiration date, the state is counting down to a planned submission date

 Not sure about becoming enhanced?

Deciding to become enhanced is an investment of time and resources . It is a decision that needs careful thought and planning. Completing the pre-qualification step does not commit the state to completing the full enhanced plan development and review process. If a state is considering enhanced status, it should complete the grants management pre-qualification step.  

Continue the Conversation

Enhanced status recognizes state mitigation programs that go above and beyond the minimum mitigation planning and program requirements. FEMA is committed to working with states that want to be enhanced. The FEMA regional mitigation planners can help states navigate the process and requirements. It is essential to communicate early and often.

Need more information?

The State Mitigation Planning Policy Guide is FEMA’s official policy on and interpretation of the mitigation planning requirements in the Code of Federal Regulations. This fact sheet summarizes key points about enhanced plans. States should read Section 4 and Appendix B of the Guide for more detailed information. This includes the narrative, the requirements tables, and the procedures.

Questions? Contact the lead Community Planner in the Mitigation Division of your FEMA regional office.

Last updated September 20, 2022