FEMA / SBA / HUD OIGs
Federal Disaster Assistance Integrity
Cross-agency duplication-of-benefits detection across FEMA IA, SBA disaster loans, and CDBG-DR before the 12-36 month recoupment window closes.
The Gap
Addressing the $20B to $80B Annual Duplication-of-Benefits Exposure
Federal disaster assistance programs, including FEMA Individual Assistance (IA), SBA disaster loans, and CDBG-DR, face a significant challenge: the detection and prevention of Duplication of Benefits (DOB). The annual exposure to DOB ranges from $20 billion to $80 billion, creating a critical need for cross-agency detection solutions before the 12-36 month recoupment window closes.
How JIL Closes the Gap
16 deterministic DPI checks, oriented to pre-payment.
The Disaster Payment Integrity engine runs 16 deterministic checks across four families. The orientation is pre-payment avoidance: stopping an improper payment before it leaves eliminates the collection problem, because in disaster programs, recovery from individual survivors does not work (of roughly $1B in Katrina/Rita improper payments, about $7M was ever recovered). Each result carries cited evidence and provenance; a result that crosses an evidentiary threshold becomes a CREB® candidate after human adjudication.
| Family | Checks | Detects |
|---|---|---|
| Duplication of benefits | DOB-01 to DOB-05 | FEMA IA overlap with SBA, NFIP, HUD CDBG-DR, private insurance, or a second registration on the same address (Stafford Act 312; 44 CFR 206.110(h)). |
| Identity & eligibility | ID-01 to ID-04 | Deceased payee (Death Master File), incarcerated at disaster date, identity-proofing failure, ineligible immigration status (SAVE). |
| Property & occupancy | PROP-01 to PROP-03 | Primary residence not matched in deed records, property outside the disaster footprint, concurrent rental assistance and funded lodging. |
| Contractor & disbursement | VEND-01, VEND-02, PAY-01, PAY-02 | Debarred repair contractor (SAM), purchase-card anomaly, mule-account routing, Treasury Do Not Pay match. |
Where the recovery is
Prevention plus entity-level recovery. Never survivor-facing.
JIL stays strictly on the integrity side. Revenue comes from pre-payment avoidance (avoided dollars, no collection risk) and entity-level recovery against Public Assistance overpayments and contractors, which is collectible because FEMA can offset future federal awards. There is no survivor-facing claim, financing, or maximization product. Procurement runs on the established recovery-audit-contractor (RAC) contingency model: paid on validated avoidance or on collection, refunded if a determination is overturned on appeal.
Property + Insurance Reconciliation
Ensuring Accurate Reconciliation of Property and Insurance Claims
Our solution includes detailed property and insurance reconciliation checks to verify that beneficiaries have not received overlapping benefits. This ensures that disaster assistance funds are used efficiently and effectively, reducing the risk of fraud and improper payments.
Evidence to Recoupment
One ledger, three evidence bundles.
Every finding is packaged for its purpose. CREB® (Court-Ready Evidence Bundle) supports enforcement and recoupment with self-authenticating documentation under FRE 902(14). RREB™ (Recovery-Ready Evidence Brief) packages collectible entity-level overpayments for offset and collections without the court framing. AREB (Audit-Ready Evidence Bundle) attests the payments that were correct, the proof an agency hands an auditor. Sensitive PII is held in sealed escrow so a bundle is producible to an authorized party (DOJ, OIG, or a state MFCU) without broad exposure.
Pricing
Transparent and Competitive Pricing Structure
Pricing -- Fraud Pillar Standard
One model. Bottom-line aligned.
90-Day Pilot
Experience the Benefits with a 90-Day Pilot Program
We invite agencies to participate in a 90-day pilot program to experience the full capabilities of JIL Sovereign's Federal Disaster Assistance solution. This pilot will demonstrate the solution's effectiveness in detecting DOB and providing actionable evidence for recoupment.