On September 15, PIA became the first national insurance association to ask Federal Emergency Management Agency (FEMA) administrator Deanne Criswell to delay the scheduled Oct. 1 implementation of Risk Rating 2.0 (RR 2.0).

While PIA supports RR 2.0, the more details FEMA released about its implementation, the more concerned we became about the planned rollout. We highlighted those concerns throughout the summer in regular meetings with FEMA, but the feedback we received did not adequately address our concerns. Our growing frustration with FEMA’s refusal to provide, among other things, more robust agent training and education, along with on-the-ground reports from PIA flood agents all over the country, led, last week, to our calling for a delay.

This week, PIA’s call for a delay was echoed by a bipartisan group of senators led by Sens. Bob Menendez (D-NJ) and Bill Cassidy (R-LA) and including Senate Majority Leader Chuck Schumer (D-NY). Among other reasons to delay RR 2.0’s implementation, the letter highlights the challenges confronting independent agents, who are, essentially, the face of the new rating methodology for consumers trying to understand the changes to their rates.

The Senate letter followed three earlier Congressional requests for delays from other members: House minority whip Steve Scalise (R-LA), 38 House members led by Reps. Bill Pascrell (D-NJ) and Garret Graves (R-LA), and Senator John Cornyn (R-TX).

The Menendez-led letter, like those sent by Sen. Cornyn and Reps. Scalise and Graves, asks FEMA to delay the implementation of RR 2.0. It does not ask Congress to legislate a delay. By contrast, some of the congressional letters are addressed to House and Senate leadership, asking Congress to legislate a delay of indefinite length and/or to assume control of the timing of RR 2.0 implementation.

While we share their desire for a delay, the ultimate implementation of RR 2.0 must not depend on Congressional action. If consumers are made to wait for RR 2.0 until Congress acts, the new methodology may never be implemented. For that reason, PIA is calling on FEMA to delay RR 2.0 for a specific period: until April 1, 2022.

PIA will continue its efforts to educate and inform our independent agent members about RR 2.0, and we will continue to work with congressional, regulatory, and industry allies to urge FEMA to delay RR 2.0 before its scheduled implementation date of October 1.