IAEM-USA submitted comments to FEMA in opposition to the proposed revision to the Disaster Declaration Factor of the Public Assistance Program. In short, IAEM-USA feels there are legitimate policy questions related to the per-capita indicator and the declarations process, but FEMA’s proposed change, coming as it does when state and local budgets are already stretched to the breaking point, is ill-timed. IAEM-USA urges FEMA to withdraw this misguided proposal and start over once COVID is behind us and the economy regains some balance. Then, and only then, should FEMA, Capitol Hill, and state and local stakeholders representing the whole of America consider this as part of a comprehensive effort to reduce the costs of disasters to the federal government in a way that does not bankrupt state and local governments. FEMA is accepting written comments on the current proposal until March 12, 2021. IAEM-USA President Judson Freed, CEM, will participate in a Feb. 24 public meeting on this topic. Complete information on the changes, public meeting, and how to submit comments is available at regulations.gov. Members may direct questions to IAEM Government Affairs Director Thad Huguley.