EMAP and Disaster Response and Recovery

Indigenous Services Canada (ISC) decision making processes for the Emergency Management Assistance Program (EMAP) response and recovery funding streams are vague for several reasons:

ISC funds response and recovery on a case-by-case basis.

• This means they look at every EMAP claim independently which is why they only provide general guidance for eligibility.

  • The upside of this is it can create positive policy flexibility that First Nations can take advantage of as every Nation and emergency is unique.

  • The downside is ISC can also suddenly deem projects to be ineligible if they do not see how the current case is similar to a past approval. This gives them an ‘out’. This also creates space for bias because federal decision makers come and go which creates knowledge gaps on their end.

ISC will only provide “Approvals in Principle”

• Under the response and recovery streams ISC reimburses eligible costs based on policy eligibility and submitted invoices. This places the majority of risk on First Nations. It means ISC never guarantees final approval until they can validate spending which can be years later. ISC can be vague in their decisions at first because they require a lot of documents and they discuss eligibility at several internal levels, this takes time.

  • Funding advances can be spent quickly during a disaster. ISC typically will not issue more advance funds until they can verify that all invoices are submitted, eligible, and the money was spent on the item or services listed on the invoice.

  • ISC does not have a large team in their regions or in Ottawa waiting to review receipts and invoices. If they are overwhelmed with paper work, the decision making process is slow.

• Remember, an approval in principle is just an acknowledgment from ISC that the item, service, project appears to be eligible, the final decision is typically made many months to years later. If a Nation decides to spend its own funds they always have to be prepared to potentially not get the money back or owe advanced funds that are spent on things that are not deemed eligible.

ISC regions vary in their experience

• Some ISC regional staff have never dealt with a large scale disaster response or recovery so they don’t have the systems in place to manage the work load and work pace. If a region has not yet experienced a long-term disaster recovery (5+ years) they will require more time to review project requests, have fewer concrete answers, and decision making time will increase.

ISC relies on provincial/territorial/non-profit policy

• ISC likes to use their bi-lateral agreements with provinces, territories, and non-profits to deflect accountability. They will say things like “We rely on X’s policy for funding decisions” or “We funded X to provide that service” This means First Nations now have to work within bi-lateral agreements that were developed without them and multiple policies from multiple jurisdictions which makes the entire process even more unclear.

These are just some examples of the challenges First Nations face during a response or recovery.

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