Emergency Management · Policy & Law · Workforce Analysis · March 2026
A comprehensive account of the FEMA Review Council's December 2025 draft report, the litigation it spawned and preceded, the political actors shaping FEMA's dismantling, and what it all means for the Americans who depend on the agency when disaster strikes.
Section 1
On January 24, 2025, President Trump signed Executive Order 14180 and established the FEMA Review Council. DHS Secretary Kristi Noem and Secretary of Defense Pete Hegseth co-chaired the Council, which spent nine months gathering feedback — 11,708 public comments, 1,387 survey responses from state, local, tribal, and territorial agencies, listening sessions across 13 cities, and four sessions with tribal nations — before producing a draft final report for a scheduled December 11, 2025 public meeting.
That meeting was cancelled hours before it was to begin. The document analyzed here — marked DRAFT//PRE-DECISIONAL//DELIBERATIVE — reached the public through leaks and sits between an original 160-plus-page Council document and a 20-page condensed version Noem's office was assembling. As of March 2026, no final report has been officially released. The Council's mandate expires March 25, 2026.
The report's ten key recommendations are organized under one governing doctrine: disaster response should be locally executed, state or tribally managed, and federally supported.
| # | Recommendation | What it proposes | Public alignment |
|---|---|---|---|
| 1 | FEMA 2.0 | Rename FEMA; cut staff ~50% over 2–3 years; shift from DC-centric to lean coordination agency | Counter |
| 2 | Remain in DHS | Keep FEMA within DHS for unified national security approach | Partial |
| 3 | States lead | Shift primary disaster leadership to state/tribal/territorial governments | Partial |
| 4 | Keep federal assets | Preserve US&R, NDMS, IPAWS, and other specialized federal capabilities | Aligned |
| 5 | Raise thresholds | Reset per-capita indicators; add minimum state expenditure before federal aid kicks in | Counter |
| 6 | Replace HMGP (R3P) | Two-phase Refined Risk Reduction Program: rapid 5% advance + 10% strategic allocation | Partial |
| 7 | FAIR program | Consolidate 15+ individual assistance categories into one direct payment per household | Aligned |
| 8 | RAPID program | Replace Public Assistance with parametric block grants paid within 30 days of declaration | Aligned |
| 9 | NFIP reform | Shift toward private market via "take-out" program; modernize flood maps; implement Risk Rating 2.0 | Partial |
| 10 | Cap admin costs | Cap overhead at below 25 cents per dollar; simplify grants; strengthen post-employment ethics rules | Aligned |
Section 2
The Council gathered extensive public feedback — yet its two most high-profile structural recommendations directly contradict that feedback. The areas of alignment are largely administrative and process-oriented; the areas of conflict are structural and consequential.
Section 3
"I expected the council's report to serve as a 'north star' for the agency — offering clarity and predictability to FEMA and the entire emergency management enterprise. And it hasn't happened, at least not yet." — Pete Gaynor, former FEMA Administrator, Trump administration
"I think where it leaves us now, at the end of the year, is still just wondering what is going to be next." — Deanne Criswell, former FEMA Administrator, Biden administration
"The unexplained cancellation was a frustrating disruptor for the local communities. Agencies across the country had been waiting to see what onus or what responsibilities were going to be placed on the locals overall, and now no one knows what's going to happen." — Tom Sivak, former FEMA Regional Administrator
Agree FEMA needs decentralization. The Cato Institute calls the new declaration formula "a promising idea." But the 50% staff cut is widely viewed as too far, too fast ahead of hurricane season.
The National Low Income Housing Coalition called the key proposals "incredibly damaging to disaster survivors" that would "set our disaster recovery system back decades." Disaster frequency is rising — not falling.
Broadly back RAPID block grants, FAIR direct payment, and admin cost caps — all areas with genuine public consensus. Want these separated from the staffing overhaul.
H.R. 4669 passed the House T&I Committee without waiting for the Council. It largely aligns with pragmatist reforms but breaks sharply on independence — it removes FEMA from DHS entirely.
Former FEMA Administrator Pete Gaynor also expressed direct skepticism: "It's a tall order to say we're just going to pass off [NFIP] to the private sector. I don't think it's going to happen." The NFIP currently insures approximately 4.7 million properties representing more than $1.3 trillion in total insured coverage — and carries over $20 billion in existing debt.
Section 4
The short answer: the reservist workforce type, in its current form, is effectively already being dismantled — whether or not the administration formally "eliminates" it by name. The dismantling proceeds not through a single dramatic policy announcement, but through contract non-renewals, DHS approval requirements, 30-day rolling extensions, and deliberate attrition.
The Review Council's report does not explicitly call for eliminating the reservist designation — it calls for a 50% overall staff reduction over 2–3 years, with most reductions expected to come from the disaster workforce. But the proposed FEMA 2.0 model — a lean, coordination-focused agency where states take the lead — structurally eliminates the operational need for a large surge-deployable reservist workforce, even if the employment category is never formally abolished.
The practical reality as of March 2026: FEMA court filings in the AFGE litigation document that "CORE employees are currently working on disasters that include the recent winter storm, late 2025 flooding in Western Washington, the 2025 Los Angeles fires, Hurricane Helene, Hurricane Milton, wildfires in Maui, and flash flooding in Kerr County, Texas" — and that CORE employees "make up about 90% of the FEMA workforce that remains on the ground for months, if not years, after a disaster to provide support." Their quiet elimination is ongoing as this document is being read.
Section 5
There are two distinct legal proceedings bearing on FEMA's workforce, one governmentwide and one specifically targeting FEMA's CORE reductions.
Track 1 — The Governmentwide RIF Lawsuit: On April 28, 2025, AFGE and a coalition of labor unions, nonprofits, and local governments filed suit in the Northern District of California, challenging Executive Order 14210 — the mass RIF directive — as unconstitutional. The district court granted a preliminary injunction; the Supreme Court then stayed it in July 2025, finding the government was likely to succeed on the executive authority argument, while noting it was not yet reviewing specific agency reorganization plans.
Track 2 — The FEMA-Specific Supplemental Complaint: On January 27, 2026, AFGE led a broad coalition — including AFSCME, SEIU, and municipalities including San Francisco, Chicago, Baltimore, Harris County Texas, and King County Washington — and filed a supplemental complaint in the Northern District of California, directly targeting DHS's December 2025 decision to severely reduce FEMA's staffing beginning January 1, 2026. The complaint alleges violations of PKEMRA's statutory protections for FEMA's independence and operational capacity.
Judge Susan Illston opened the hearing by stating her preliminary view was to deny the injunction request, noting the evidentiary record was insufficiently developed. She did not rule from the bench — but she ordered expedited discovery of extraordinary scope: depositions of Secretary Noem, FEMA Administrator Karen Evans, and the chief human capital officers of both DHS and FEMA. She also ordered production of all documents and communications surrounding CORE non-renewals and all internal "target" reduction communications.
A case management conference is scheduled for May 8, 2026. A hearing on the motion to dismiss is set for May 12, 2026. No injunction is currently in place — meaning the cuts proceed unblocked while discovery is conducted.
Parallel to the litigation, a group of current and former FEMA staff published a public letter — the "Katrina Declaration" — arguing that under Secretary Noem, "FEMA is enacting processes and leadership structures that echo the conditions PKEMRA was designed to prevent." House Democrats separately called on Trump to fire Noem, arguing the CORE cuts "illegally subvert" the post-Katrina law's guardrails. Former FEMA official Michael Coen warned publicly: "This will delay recoveries across the country — in western North Carolina, in Kerr County, Texas, in Florida, in Vermont and Kentucky, in Maui, in Los Angeles."
Section 6
Nominally a part-time, unpaid volunteer capped at 130 days per year. Functionally described by insiders as "de facto chief of staff." Has directed firings, signed off on contract approvals, and ordered polygraph tests of FEMA officials. His financial disclosures — legally required to be public — have not been released.
Not listed on FEMA's organizational charts. No clear appointment authority. Spearheaded — alongside Karen Evans — the review of all FEMA contracts worth $100,000 or more. Her contract review bottleneck blocked disaster relief funds for Hurricane Helene survivors and prompted public protests from Republican Senators Budd and Tillis of North Carolina.
Acting FEMA Administrator Cameron Hamilton — who created and signed the memo terminating BRIC — testified before Congress on May 7, 2025, stating: "I do not believe it is in the best interest of the American people to eliminate FEMA." He was summoned to Noem's office the following day. Lewandowski, sitting at Noem's desk, fired him. His replacement, David Richardson, is a personal friend of Lewandowski with no prior experience managing natural disasters.
The court's discovery order — covering Noem, Evans, and all CORE non-renewal communications — will almost certainly surface internal communications involving Lewandowski and Voorhies. Their roles sit at the precise intersection the PKEMRA argument targets: DHS political leadership exercising operational control over FEMA functions that Congress designated as operationally independent. If internal communications show Lewandowski directing the CORE cuts that the DOJ attorney was unable to explain in court, the statutory independence argument becomes dramatically stronger.
Section 7
The BRIC story is arguably the single most legally explosive thread in the entire FEMA situation — because it doesn't merely involve a policy dispute. It involves a federal agency openly defying a federal court order for months while simultaneously denying to the press that it had terminated the program at all.
On April 4, 2025, FEMA announced the termination of BRIC and canceled all previous awards from fiscal years 2020–2023, including $882 million appropriated under the Bipartisan Infrastructure Law. FEMA called the program "politicized" and an example of "waste, fraud and abuse." The irony: BRIC launched during the first Trump administration. Its funding came from the Biden-era Bipartisan Infrastructure Law, but Trump-era initiative created the program. Cameron Hamilton signed the termination memo — weeks before Lewandowski fired him for showing independence before Congress.
This is where the BRIC litigation cuts to the heart of the report's credibility. Recommendation 6 proposes replacing HMGP with a two-phase R3P program — but says nothing about BRIC, which was being illegally terminated while the Council was still conducting its listening sessions. Tribal nations, states, and local governments repeatedly told the Council that BRIC was among the most critical programs they relied upon and called for its restoration. Yet the report that emerged effectively validated the termination by folding mitigation into a new framework without acknowledging that a court had already ruled the termination unlawful. The Council's report and the administration's conduct in the BRIC litigation are fundamentally incompatible positions: the report presents itself as evidence-based reform while the administration simultaneously defied a court order restoring one of the programs the evidence most strongly supported.
Section 8
The Review Council's Recommendation 2 — keeping FEMA within DHS — has become one of the most contested conclusions in the report. The political opposition to it is striking precisely because it is bipartisan and comes from both ends of the spectrum simultaneously.
On March 24, 2025 — the same day Noem stood in a Cabinet meeting and declared FEMA would be "eliminated" — Rep. Jared Moskowitz (D-FL) and Rep. Byron Donalds (R-FL) introduced the FEMA Independence Act. It would remove FEMA from DHS and restore it as an independent, cabinet-level agency reporting directly to the President. Moskowitz, who previously served as Florida's Emergency Management Director, argued: "DHS has become too big and too slow to oversee what needs to be a quick and flexible emergency response."
Donalds argued FEMA had become "overly-bureaucratic, overly-politicized and overly-inefficient," and that establishing it as an independent agency would improve all of these fronts. The bill would require Senate confirmation of a FEMA director and up to four deputy directors, and would establish a dedicated FEMA Inspector General — a structural oversight mechanism that does not currently exist.
The more consequential vehicle is H.R. 4669, the bipartisan Fixing Emergency Management for Americans (FEMA) Act, which passed the House Transportation and Infrastructure Committee on a bipartisan 57–3 vote. It restores FEMA's original status as an independent agency reporting directly to the President; establishes a Recovery Task Force to close more than 1,000 lingering disaster declarations; requires clear survivor notices; strictly prohibits political discrimination in disaster assistance; and directs OMB to publish a centralized public website tracking disaster funding. The National Low Income Housing Coalition and its coalition of more than 900 organizations are actively lobbying for it to be included in the FY2026 DHS spending bill.
The Review Council's decision to keep FEMA within DHS is now directly contradicted by the lived experience of 2025–2026. Every single dysfunction documented in this report — the AFGE litigation, the BRIC defiance, the Lewandowski-Voorhies contract review bottleneck, the Hamilton firing, the North Carolina funding freeze, the polygraph campaigns, the false declaration of FEMA's non-involvement in its own staffing decisions — traces back to the same root cause: DHS leadership using its authority over FEMA as a political lever.
The Post-Katrina Emergency Management Reform Act was specifically designed to give FEMA's Administrator statutory independence — including the direct authority to advise the President and the Homeland Security Council without going through the DHS Secretary. The "Katrina Declaration" signed by current and former FEMA staff argues that the current DHS structure is replicating precisely the conditions PKEMRA was designed to prevent.
In that light, Recommendation 2 isn't merely a structural disagreement — it is the recommendation most directly implicated by every other legal and political conflict now playing out in federal court. The AFGE litigation's central argument, the BRIC defiance, and the ongoing Lewandowski controversy all trace to the same structural problem the Council chose not to solve: FEMA's operational independence from DHS political leadership is currently nonexistent. Keeping FEMA within DHS — as the Council recommends — preserves the very conditions that have produced the chaos the report was commissioned to address. It is, in effect, a recommendation to institutionalize the problem.
Section 9
Section 10
One of the most consistent sources of public confusion in news coverage of the FEMA workforce crisis is the failure to distinguish between fundamentally different categories of FEMA employees. When the public hears that FEMA has "23,000 employees," they picture 23,000 people sitting in FEMA offices. When they hear that 1,000 were "laid off," they picture career civil servants being fired. Neither image is accurate — and the confusion matters enormously for understanding what is actually being lost.
Hired through competitive process; earn career tenure after 3 years. The "civil service" employees. They write policy, manage programs, staff headquarters and regional offices year-round. Roughly 6,100 positions as of early 2025. DOGE buyouts primarily targeted this group — approximately 2,000 have departed. These are the employees most people imagine when they think of "FEMA staff."
Hired for 2–4 year terms under the Stafford Act. May be renewed. Eligible for the same benefits as PFTs but earn no career tenure or competitive service status. Constitute approximately 39% of FEMA's total workforce — roughly 8,000+ employees. They are the people actually on the ground at disasters for months or years. Court filings confirm they make up ~90% of FEMA's disaster-zone presence.
Deploy on-call during emergencies on 30-day renewable periods. Must be available to deploy within 24–48 hours. Two-year hire periods renewable indefinitely. The main FEMA surge workforce during active disasters. Ineligible for DOGE buyouts; instead being eliminated through non-renewal of 30-day extensions at DHS's direction.
Residents hired locally in the affected community for 120-day appointments, extendable based on need. Provide community-specific knowledge and language skills. The most temporary and community-rooted worker type.
Perhaps the most consequential — and least understood — dynamic in FEMA's current crisis is the slow, systemic replacement of permanent civil servants (PFTs) with CORE employees over the past decade and a half. This was not a deliberate policy decision so much as an institutional adaptation to two realities: rising disaster frequency that required surge capacity, and congressional budget constraints that made adding permanent headcount politically difficult.
This matters for several reasons that the public — and frankly, much political commentary — has failed to appreciate:
Of those 23,000, roughly 8,000+ are CORE employees on 2–4 year renewable terms. Several thousand more are Reservists on 30-day renewable periods. The "permanent" civil service workforce is actually only about 6,100 — and 2,000 of those have already left. What appears to be a large bureaucracy is in reality a thin permanent core propped up by a contractual workforce that can be wound down through non-renewal without any formal RIF action, congressional notification, or legal process beyond what PKEMRA requires.
This is the opposite error. CORE employees are federal employees, not contractors. They receive federal benefits, work inside FEMA's chain of command, and in many cases have worked for FEMA for a decade or more through successive 2–4 year renewals. They write grant decisions. They staff disaster recovery centers. They are often the only FEMA presence in a disaster zone for the first year of recovery. The court filing that states CORE employees "make up about 90% of the FEMA workforce that remains on the ground for months, if not years, after a disaster" is not describing contract workers — it is describing federal employees whose tenure structure simply does not accumulate into permanent civil service status.
This conflates the legal structure with the operational reality. Many CORE employees have been continuously renewed for 10, 15, or 20 years. They built careers at FEMA in good faith, developing institutional knowledge and disaster expertise that cannot be rebuilt quickly. The decision not to renew them is not the expiration of a contract — it is the operational equivalent of a layoff, without the legal protections, severance rights, or civil service appeal processes that a formal RIF would provide. Because non-renewal requires no RIF process, it is invisible in labor statistics and generates no formal record of job losses — which is precisely why it is the administration's preferred mechanism for workforce reduction.
The Review Council's report criticizes FEMA's "District of Columbia-centric headquarters" and calls for rebalancing toward field personnel. But the workforce planning emails revealed in litigation show a target of 41% reduction to the disaster workforce — the CORE and Reservist employees who are the field. The 15% reduction targeted to PFTs primarily hits headquarters. The practical effect of the plan as documented is therefore the inverse of what the report recommends: field capacity is being cut more deeply than headquarters bureaucracy.
The GAO's addition of federal disaster assistance to its "High Risk List" in February 2025 — before the current round of cuts — was driven in part by exactly this problem. FEMA had already been losing experienced staff faster than it could replace them, and the institutional knowledge embedded in CORE employees who had spent years managing specific disasters was identified as a non-recoverable asset once lost. The 24 senior leaders who departed FEMA through voluntary programs in 2025, documented by GAO, represent a category of expertise — relationships with state emergency managers, knowledge of specific open disaster files, understanding of FEMA's internal IT systems — that cannot be replaced by hiring new PFTs or even new CORE employees. They learned it through years of doing it. That knowledge is now gone.