Senate Republicans are pressing the Federal Emergency Management Agency (FEMA) to disclose the underlying data and actuarial assumptions behind its Risk Rating 2.0 flood pricing overhaul, arguing that opaque risk models and steep premium increases are shrinking participation in the National Flood Insurance Program (NFIP) and weakening the risk pool the system depends on.
A group of senators this week formally urged FEMA to terminate or suspend the Risk Rating 2.0 methodology and publish the modeling inputs that drive premiums, escalating what has become a direct challenge to the program’s transparency, credibility, and actuarial governance.
In a letter to Acting FEMA Administrator Karen Evans, the lawmakers said the framework has pushed premiums higher “in every state,” with FEMA’s own estimates showing roughly 77% of policyholders now paying more than under the prior system. In high-exposure regions such as Louisiana, they said increases “well over 100 percent” have prompted “tens of thousands of homeowners” to drop coverage altogether.
The sharpest criticism focused on model transparency.
The senators wrote that FEMA “has not released the underlying data, assumptions, or modeling used to generate premium increases,” nor provided “a mechanism for meaningful external review.” Without disclosure, they argue, homeowners cannot understand rate changes, lenders cannot underwrite mortgages with confidence, and communities cannot plan mitigation investments.
In a related statement, the group called the “lack of transparency” “beyond troubling,” saying FEMA “refuses to disclose its actuarial model,” limiting public comment and independent scrutiny.
The lawmakers also cited peer-reviewed research indicating Risk Rating 2.0 coincided with an 11–39% decline in new policies and a 5–13% drop in renewals, depending on the size of the increase. Fewer policies translate into a smaller base, greater risk concentration, and more volatile loss costs — the classic mechanics of an adverse-selection spiral, they argued.
“Flood insurance depends on a broad risk pool to function effectively,” they warned, adding that as households exit, “premiums face additional upward pressure” while uninsured losses increasingly shift back to taxpayers through disaster aid.
Their proposed remedies include terminating the current pricing approach, halting premium increases beyond statutory minimums, and providing “full transparency into NFIP rate-setting,” including publication of “all data inputs, modeling assumptions, and actuarial analyses.
