Your Action Plan Should Be Ready Before the Money Shows Up

Your state action plan shouldn’t begin when HUD announces funding. It should be mostly done by then.

That might sound aggressive, but I’ve watched the difference between states that are ready and states that scramble, and the gap is enormous. The states that deliver effective disaster recovery aren’t necessarily smarter or better resourced. They’re just earlier.

The Problem with Playing Catch-Up

When HUD announces a CDBG-DR allocation, the clock starts. States need to develop an action plan, submit it for public comment, get HUD approval, and then start standing up programs. That process takes months under the best circumstances.

Now imagine starting from scratch. You need to assess unmet needs, design programs, engage stakeholders, draft the plan, run it through legal review — all while HUD’s timeline is ticking. States in this position end up rushing their plans, and rushed plans create problems that echo through the entire recovery.

I’ve seen action plans that stall at HUD review because they weren’t thorough enough. I’ve seen plans that get approved but don’t reflect what communities actually need because the needs assessment was done too fast. And I’ve seen states stuck rewriting their plans six months after approval because programs designed under time pressure don’t work in practice.

All of this is avoidable.

What Proactive States Do Differently

The states that consistently deliver strong action plans share a few habits.

First, they maintain templates. Not generic templates — living documents built from previous disasters and updated with lessons learned. When a new disaster hits and funding is announced, they’re not staring at a blank page. They have a framework that captures their standard program designs, compliance language, and administrative structures. They plug in the specifics of the new disaster and move.

Second, they assess unmet needs early. As soon as a disaster occurs — before any federal funding is even discussed — these states are gathering data. They’re talking to local officials. They’re analyzing FEMA individual assistance data. They’re identifying gaps between what insurance and FEMA cover and what communities actually need to recover. By the time HUD funding arrives, they already know where the money should go.

Third, they engage stakeholders before they have to. Public comment periods required by HUD go more smoothly when you’ve already been in conversation with community leaders, advocacy organizations, and local governments. States that wait until the formal comment period to hear from communities for the first time get surprised. States that have been listening all along get confirmation.

Plans That Drive Recovery vs. Plans That Check a Box

There’s a meaningful difference between an action plan that gets approved and an action plan that actually drives recovery.

An approved plan satisfies HUD’s requirements. It has the right sections, the right language, the right assurances. It passes review. But that doesn’t mean it works.

A plan that drives recovery does something more: it reflects genuine understanding of what the disaster did to the community and designs programs that address those specific impacts. It has realistic timelines. It allocates resources based on data, not guesswork. It builds in flexibility to adjust as conditions change — because they always change.

The difference usually comes down to preparation. States that rush their plans tend to borrow heavily from other states’ templates or past plans without adapting them to current conditions. The plan reads fine but doesn’t fit. Programs launch and immediately need modifications. Implementation delays stack up. Communities wait longer for help.

States that prepare early write plans that fit their disasters because they took the time to understand what happened and what’s needed.

Start Now

If your state is disaster-prone — and increasingly, most states are — don’t wait for the next disaster to think about your action plan. Build your templates now. Develop relationships with the organizations and agencies you’ll need during recovery. Create a framework for rapid needs assessment that you can activate as soon as a disaster declaration is issued.

The action plan isn’t just a document you submit to HUD. It’s the blueprint for your entire recovery. The quality of that blueprint determines how fast and how effectively you can help your communities rebuild. Treating it as something you figure out after the money arrives is the wrong approach.

The states that recover well are the ones that were ready before anyone asked them to be.