What Agents Need to Know About First Floor Height
PIA is closely monitoring an issue affecting the National Flood Insurance Program’s (NFIP) PIVOT rating system and the First Floor Height (FFH) data used in determining flood insurance premiums.
On or around September 8, 2026, the NFIP began experiencing a malfunction involving First Floor Height data. While the situation continues to develop, the disruption has the potential to affect new business as well as certain transactions involving existing NFIP policies. PIA is working with industry partners to seek clarification and solutions and wants agents to understand the potential impacts.
New Business Appears Most Directly Affected
The most significant and immediate concern involves new-business quotes.
When the NFIP rating system cannot obtain the necessary First Floor Height data, PIVOT may apply an assumed FFH. In some cases, that assumed value can result in a substantially higher quoted premium than would be produced using the property’s actual First Floor Height.
As a result, agents should carefully review new-business quotes that appear unusually high. A quote generated while this issue persists may not reflect the premium that ultimately applies once accurate FFH information is available.
Agents should be cautious about representing a potentially affected premium as final until the transaction has been successfully processed.
Existing Policies and Renewals May Also Be Affected
In-force policies generally appear to be retaining their existing First Floor Height information, and many renewals are processing normally. However, inconsistent results have been reported.
Transactions that could potentially trigger the application of new or assumed FFH information include:
- Renewals
- Endorsements
- Policy rollovers
- Transfers
- Cancellations and rewrites
- Other transactions that cause a policy to be rerated
Because results have varied, agents should not assume that every existing policy or renewal is unaffected. Unexpected premium changes warrant additional review.
Renewal Billing Creates an Additional Concern
The situation could become particularly important when it affects renewal billing.
Write-Your-Own (WYO) carriers must generate renewal billing within required NFIP timeframes, generally 45 days before expiration, although many carriers begin the process earlier.
If accurate renewal offers or bills cannot be produced on schedule, the effects could extend beyond the policyholder and insurance agent. Mortgage lenders and servicers, WYO carriers, real estate professionals, and others who depend upon evidence of continuous flood insurance coverage could also be affected.
For example, a mortgage lender or servicer may be unable to make an escrow payment if a valid renewal bill has not been produced.
Agents should therefore pay particular attention to approaching renewals, especially policies for which premiums are paid through mortgage escrow accounts.
Elevation Certificates May Provide an Option
Existing NFIP rating guidelines allow an Elevation Certificate to provide actual property elevation information rather than relying on an assumed First Floor Height.
When an assumed FFH results in an unexpectedly unfavorable premium, agents should consider whether obtaining an Elevation Certificate could help establish the property’s actual elevation information.
This may be particularly valuable when accurate automated FFH data is not available before coverage needs to be bound.
What PIA Recommends Agents Do Now
Until FEMA provides definitive guidance or reliable FFH data functionality is restored, PIA encourages agents to take the following precautions:
- Closely review unusually high new-business quotes. Determine whether an assumed First Floor Height could be contributing to the premium.
- Pay close attention to renewals and endorsements. Investigate transactions in which the premium changes unexpectedly from previous indications.
- Exercise caution when communicating premiums. Avoid representing a potentially affected premium as final until the transaction has successfully processed through the NFIP rating system.
- Consider an Elevation Certificate when appropriate. Actual elevation information may help address unfavorable results caused by an assumed FFH.
- Monitor renewal billing. Give particular attention to escrowed policies requiring payment by a mortgage lender or servicer.
- Document policyholder communications. Maintain appropriate records when explaining that a quote, renewal, or other transaction may have been affected by the FFH issue.
- Watch for additional guidance. Continue monitoring communications from FEMA, the NFIP, and WYO carriers for corrective action, implementation information, and instructions regarding affected policies.
PIA Is Engaged
PIA recognizes the operational challenges this situation creates for independent insurance agents and their customers. The lack of consistent FFH information can create uncertainty at the very point when agents are trying to provide consumers with accurate pricing and dependable coverage.
The insurance industry is working to obtain additional clarification and solutions through the Flood Insurance Producers National Committee (FIPNC), the Insurance Institute for Business and Home Safety (IBHS), PIA, the Independent Insurance Agents and Brokers of America (IIABA), and other industry stakeholders.
At this time, a definitive repair date and comprehensive guidance addressing all potentially affected transactions have not been published.
This remains a developing situation. PIA will continue to advocate for clarity and solutions that allow independent agents to provide their customers with accurate, timely flood insurance information. Agents should continue to monitor FEMA, NFIP, and WYO carrier communications as the situation evolves.