Who Holds the Proof? Housing Tenure, Documentation, and Administrative Burden in Federal Disaster Assistance

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Abstract

Disaster assistance requires households to document their needs under administrative rules, often after disasters have destroyed the necessary records. Drawing on administrative burden theory, we argue that housing tenure shapes this documentation work by determining both the resources households can access and their control over the evidence agencies require. We analyze approximately 22.1 million applications to the Federal Emergency Management Agency’s Individuals and Households Program from 2002 to 2025. Using logit, least squares, and linear probability models with neighborhood and year fixed effects for 2011–2023, supplemented by year-specific models, we examine approval, award amounts, and recorded denial reasons. Renters are 2.42 percentage points more likely than homeowners to be denied for missing documentation, despite being less likely to be denied on substantive eligibility or insurance grounds. This documentation gap appears in every year from 2015 to 2023. Contrary to our expectation that greater resources ease documentation, higher income does not consistently reduce documentation-related denial; only the highest-income groups have a modest advantage. Approval is lower among applicants farther from Disaster Recovery Centers and higher in counties with more recent disaster experience. Because aggregate approval rates and award amounts do not reveal where disadvantages arise, equity assessments based on these totals may miss the stage of the claims process at which renters fall behind. We extend administrative burden theory by arguing, with evidence consistent with this account, that compliance capacity depends not only on applicants’ resources but also on their relationships with the people and institutions that control the required evidence.

Authors

• Daein Kang, Georgia Institute of Technology
  Presenting Author

• Brian Y. An, Georgia Institute of Technology
  Non-Presenting Co-Author