Department of Homeland Security

Formal Interpretation Data Base for Code of Federal Regulations

I have worked in five of the ten regions of FEMA as a Stafford Act Employee, Public Assistance Project Specialist. The regions interpret several areas of the Stafford Act differently and therefore there are some unnecessary inconsistencies with the way the program is administered. I suggest that a formal interpretation database should be developed where any employee or citizen could send a request with their reason why they believe the Code of Federal Regulations is being applied incorrectly. This would eliminate valuable man hours that could go into production rather than time lost used to debate the inconsistent field interpretations on whether or not a project is eligible for funding. It would both streamline the grant process for the federal government charged with assisting the applicant and expedite the process for the applicant in need and eligible of such funding. Further, it would reduce time spent for all eligible applicants for funding at both the state and federal level. Once in place and operating, it would ensure that all applicants would be treated equally within the framework of FEMA. NFPA has such a database from which one could be modeled for FEMA. This would be a valuable asset to reduce congressional inquiries and applicant appeals resulting in a more efficient and consistent operation. This type of database could universally serve all branches of the federal government. The areas that are consistently misunderstood or applied incorrectly would be addressed with a formal interpretation. How much money and time would it save? I don’t have the data to even estimate the savings but I believe if implemented, a program like this would be significant in productivity for federal, states, and local governments. It would simplify the process for all US citizens trying to understand the myriad of guidelines, laws and red tape currently in place as well as future ones that will be adopted.



Idea No. 3982