CRS Updates – 2021 and 2022

Presentations by ISO/Verisk at the 2022 KAMM Conference

Introduction and Overview of the Community Rating System Program – Amanda Gowans, ISO/Verisk

The 2021 Addendum to the CRS Coordinator’s Manual – Amanda Gowans, ISO/Verisk

 

 

What’s Changed in Risk Rating 2.0 and CRS

May 2022

Risk Rating 2.0 (RR 2.0) rating methodology now incorporates a wide range of rating variables; however, two major ones that are no longer used are Base Flood Elevations and flood zones.  In the old methodology (RR 1.0), properties in moderate-low risk zones (e.g., B, C, X) with minimal losses could qualify for a lower-cost Preferred Risk Policy (PRP); however, they did not receive a CRS discount.  If they did not qualify for the PRP, they could be written as a standard-rated Zone X policy and receive 5% or 10% discount depending upon the CRS Class.  Buildings in Zone A would get the full discount.

In RR 2.0, because the flood zone is no longer a rating variable, the discount that had applied to just Zone A policies now applies to all policies.  So, a policy in Zone X receives the same discount.  While there are numerous variations and nuances.

Link to the two-page Fact Sheet– RR+2.0 Fact Sheet and CRS

Effective January 2021

FEMA Releases Addendum for the Community Rating System Manual

January 2021

FEMA recently released the Community Rating System 2021 Addendum, a companion guide for the current Coordinator’s Manual. Together, these documents establish and explain various elements of the Community Rating System program including an official description, how the program operates, and how class ratings (Class 10 to Class 1) are determined.  The documents will remain effective until a fully revised edition of the Coordinator’s Manual is issued in the future.

The program provides incentives to encourage local jurisdictions to implement floodplain management best practices that exceed the minimum community-based floodplain management requirements of the National Flood Insurance Program.  In return, NFIP flood insurance policy holders can receive reductions in their flood insurance premium.

With the 2021 Addendum, FEMA incorporates three new opportunities for communities to earn credit for a reduction in NFIP policy premiums.  These include:

  • Protecting threatened and endangered species.
  • Mitigating substantial damage.
  • Promoting flood insurance.

In addition, new prerequisites allow for both new credit opportunities and simplification for communities.  These prerequisites include:

  • A plan for managing floodplain-related construction certificates (including elevation certificates) to reach Class 9.
  • The implementation of 1-foot of freeboard to reach Class 8. 

Link to the 2021 Addendum – fema_community-rating-system_coordinator-manual_addendum-2021. 

For more information, view the info on the FEMA website. 

 

 

Frequently Asked Questions about the 2021 Addendum

The Addendum is effective Jan. 1, 2021 and will be used in conjunction with the 2017 edition of the Coordinator’s Manual.  The expiration date noted on the 2017 Coordinator’s Manual is no longer applicable.  Both documents will be in force at a community’s next cycle verification after Jan. 1, 2021 and continue until the next full update of the FEMA CRS Coordinator’s Manual Addendum – 2017 Edition.

Communities may take advantage of the new credit opportunities presented in the Addendum at any time and need not wait until a scheduled verification visit.

Link to the FAQs – fema_community-rating-system_coordinator-manual_addendum-2021_FAQs

 

 

CRS Update Resources

Class 9 Prerequisite

The CRS program has always required communities to collect and maintain Elevation Certificates for communities to be a CRS Class 9.  Details of what must be correct on them and information about other required construction certificates has traditionally been included under Activity 310.  The CRS program required a 90% accuracy for all Elevation Certificates collected by a community.

In 2021, the CRS will be issuing an addendum to the 2017 Manual that clarifies the Activity 310 requirements.  This addendum will become effective January 1, 2021 meaning all elevation certificates collected beyond then will be held to this new standard. 

For the changes in the Class 9 prerequisite for Elevation Certificates and other construction certificates, a template for written construction certificate management procedures is available below).  The template will help a community produce a document that describes the manner in which its office collects, reviews, corrects, and maintains the certificates, and how they are made available to inquirers. 

Construction Certificate Management Procedures

One of the changes in the 2021 Addendum to the Coordinator’s Manual is a new element CCMP, construction certificate management procedures, under Activity 310 (Elevation Certificates).  This element replaces the current EC element and will be worth the same number of credit points.  In addition, credit for this element became a Class 9 prerequisite beginning in January 2021 when the 2021 Addendum became effective. 

Written procedures are important to the community and to the CRS because they address what certificates the community requires for development in the floodplain and how that community collects, reviews, corrects, maintains, and makes available the floodplain-related construction certificates required by the CRS.  These floodplain-related construction certificates include the Elevation Certificate, Floodproofing Certificate for Non-Residential Buildings, and Residential Basement Floodproofing Certificate. 

Previously, CRS communities were required to submit a written description of how the community maintains, stores, and provides copies of certificates to inquirers.  For credit for element CCMP, a community will need to expand its current construction certificate maintenance procedures to cover the collection, review, and correction process, and require staff to follow these official internal procedures.  Also, the procedures will be required to be approved by the head of the department who oversees the staff and duties involved in the procedures.  This could mean multiple department heads will be approving these procedures if multiple departments are involved in the procedures.  The department head(s) must see the procedures and place their signature on the document for it to be considered “approved.” Accurate and readily available data on a building’s flood zone, elevation, and other construction information are essential to insurance agents for processing an application for a flood insurance.

The CRS wants to be sure everyone knows what the procedures are and follows them so all construction certificates get collected, reviewed, corrected, and maintained appropriately for CRS standards.  Formal written procedures, when followed, will assist communities to reach the desired outcome of 90% accuracy needed to maintain participation in the CRS.  These procedures are also a Class 9 prerequisite under the 2021 Addendum.  A community’s construction certificate management procedures for element CCMP are evaluated only at cycle time. 

A community must receive credit for this element to meet the amended Class 9 criteria in the 2021 Addendum.  This is an “all-or-nothing” element, meaning there will be no proration of credit.  The Addendum specifically lists the required items to cover in the procedures.  To receive the full 38 points for this element, a community must make sure that it adequately covers all of the required topics.  A CCMP template has been created to guide communities in generating their written management procedures.  CCMPs are required for all cycles started after January 1, 2021.

CRS Resources and Training Video

Link to a 25 minute webinar– CRS Resources Training & Video; search for “CRS Activity 310 Changes for 2021. 

Class 8 Prerequisite

Previously, there was no prerequisite requirements for communities to become a CRS Class 8.  In 2021, the CRS will be issuing an addendum to the 2017 Manual that will implement a new Class 8 prerequisite for freeboard for all new and currently participating CRS communities. 

The Class 8 freeboard prerequisite affects Class 5 through Class 8 communities.  Communities in Classes 1 through 4 already meet the new freeboard prerequisite and Class 9 communities will not be affected. 

Read the CRS Class 8 Freeboard Prerequisite FAQ to learn more.

New Process for Repetitive Loss Data

FEMA is making changes to their Repetitive Loss data protocols.

Obtaining CRS Repetitive Loss Data

FEMA’s protocols for repetitive loss data are changing.  The ISO no longer distributes NFIP repetitive loss data to CRS communities.  All communities must request repetitive loss data (repetitive loss lists) directly from the FEMA Regional Office.  As described in Section 501.b of the Coordinator’s Manual, a community currently due for a CRS verification cycle visit will need a current repetitive loss property list, and new communities applying for CRS entry will also need a current list.  To begin the process of obtaining repetitive loss data, a community should coordinate with its FEMA Regional Office.

FEMA Region IV – Victor Geer Victor.Geer@fema.dhs.gov

To help ensure the correct data are being provided, a community should let its ISO/CRS Specialist know it will be requesting data for CRS purposes.  The ISO/CRS Specialist will help by providing a transmittal sheet to submit to FEMA that clarifies which data set is being requested.  This important step ensures that a community will receive the appropriate repetitive loss list.

ISO will no longer distribute NFIP repetitive loss data to CRS communities.  All communities must request repetitive loss data (repetitive loss lists) directly from the FEMA Regional Office.  Communities in a verification cycle visit sill requires a current repetitive loss property list, and new communities applying for CRS entry also will need a current list.

Before repetitive loss data can be provided by the FEMA Regional 4 or DOW, communities must have an Information Sharing and Access Agreement (ISAA) in place with FEMA. 

The ISAA is a written form that must be fully executed before FEMA may release any NFIP data to the community.

Link to Making Corrections to the Repetitive Loss List is a one-page CRS handout that describes the new procedure communities submit to FEMA corrections to the repetitive loss list, using the Repetitive Loss Update Worksheet, also known as the AW-501.

 

 

 

 

 

Mitigation Matters!  

Have questions, contact us at help@kymitigation.org.

KAMM mailing address: KAMM, PO Box 1016, Frankfort, KY 40602-1016.  

 

Don’t forget to join the KAMM group on LinkedIn and Facebook.

KAMM is a non-profit 501 (c) (3)