Extreme Heat, FEMA, and the Funding Gap: Why GAO’s New Report Matters for Federal Contractors

The Government Accountability Office’s September 2025 report, EXTREME HEAT: Limited FEMA Assistance Highlights Need for Reevaluation of Agency’s Role (GAO-25-107474), lands a clear message for the procurement community: extreme heat is widespread, costly, and growing—but FEMA’s current funding pathways and policies only marginally address it. GAO’s analysis of the National Weather Service HeatRisk forecasts found that from 2018 to 2024, 97 percent of counties in the contiguous U.S. faced at least one day at a dangerous level of heat, affecting more than 319 million people in total, and the agency reiterates that extreme heat remains the nation’s leading weather-related cause of death.       

For contractors, the key significance is not the hazard’s prevalence but the funding architecture now in flux. GAO finds that FEMA’s mitigation support for heat has been minimal: fewer than 1 percent of 1,235 BRIC awards with obligations from FY 2020–2023 primarily addressed extreme heat, totaling about $963,000—and those few funded capacity-building, not bricks-and-mortar heat projects.      GAO also underscores that no presidential major disaster has ever been declared solely for an extreme heat event; FEMA assistance has tended to flow only when heat follows or accompanies another declared disaster (e.g., commodity distribution in Houston after Hurricane Beryl, when a concurrent heat wave drove extraordinary cooling-center demand).   

Policy shifts intensify the challenge. FEMA’s updated Hazard Mitigation Assistance Program and Policy Guide (version 2.1, effective January 20, 2025) makes retrofit projects whose primary benefit is extreme heat mitigation ineligible as standalone efforts; such retrofits are now only eligible when bundled as secondary benefits within other hazard projects.  At the same time, GAO reports FEMA has not yet evaluated its broader role or capabilities to assist tribal, state, and local governments with planning, response, recovery, and mitigation for extreme heat—nor assessed how its potential end or revision of BRIC could affect these missions.

GAO’s recommendations are directly relevant to capture planning and proposal strategy. The report calls on FEMA to (1) identify quantitative and qualitative evidence communities can use in benefit-cost analyses (BCA) for heat projects; (2) set a plan with milestones to incorporate additional heat activities into BCA; (3) publish modeled examples of heat-focused mitigation projects; and (4) evaluate the agency’s role and close programmatic gaps for heat assistance.  DHS concurred with three recommendations but not the BCA expansion plan, citing the new policy that excludes heat retrofits as stand-alone project types—precisely the sort of policy-program mismatch GAO argues must be addressed to reduce local burdens and improve cost-effectiveness demonstrations.

What does this mean in practice for federal contractors across facilities, energy, public health, emergency services, and food and base operations? First, do not count on heat-only declarations to unlock Stafford Act funding; tie heat relief and resilience measures to multi-hazard scopes where eligible programs and cost-effectiveness evidence already exist. Second, expect BCAs to require more robust health, operations, and continuity data; GAO’s emphasis on evidence signals a premium on measurable benefits such as reduced medical surge, avoided downtime, and maintained service levels during power-constrained heat waves. Third, orient pursuits toward projects where heat mitigation is a co-benefit—nature-based flood measures, energy resilience for shelters and resilience hubs, shading and cool surfaces integrated into broader infrastructure work—until FEMA clarifies its role and any BRIC successor.

Ultimately, GAO’s bottom line is that extreme heat is a national-scale risk while FEMA’s mechanisms and metrics are not yet aligned to fund heat as a primary hazard at scale. Contractors who frame proposals to fit existing eligibility channels, document cross-hazard benefits with credible BCA inputs, and help state and local clients translate operational heat impacts into quantifiable benefits will be best positioned while federal policy catches up.

Disclaimer: This summary is for informational purposes only and reflects GAO’s published findings as of September 2025. It is not legal, financial, or technical advice, and accuracy is not guaranteed. Consult the underlying GAO report and applicable regulations before making decisions.