No, non-state governments are not allowed to totally self-insure to satisfy FEMA's Public Assistance (PA) program's "obtain and maintain insurance" requirements. Here's a breakdown of the policy:

Who Can Self-Insure:

• Only States can use a self-insurance plan to meet FEMA's insurance requirements for PA funding.

Non-State Entities:

• Local governments (cities, counties), Tribal governments, and eligible private non-profit organizations cannot utilize self-insurance to satisfy the insurance requirement.

Exceptions for Flood Insurance:

• An exception exists for flood insurance in some cases. Private non-profit organizations with buildings located in Special Flood Hazard Areas (SFHAs) can potentially meet the flood insurance requirement through self-insurance, but only after they have otherwise met the purchase requirements of the National Flood Insurance Program (NFIP).  The Federal Insurance Administrator has the authority to approve such self-insurance plans for flood coverage.

Insurance Requirement Details:

• FEMA requires applicants to have certain types and amounts of insurance coverage in place to be eligible for PA funding. These requirements are typically based on the type and value of the facilities owned by the applicant.
• The purpose of this requirement is to encourage responsible risk management and lessen the burden on federal disaster recovery funds.

Alternatives for Non-State Entities:

• Local governments, Tribal governments, and eligible non-profits must obtain and maintain commercial property insurance to comply with FEMA's insurance requirements.

Resources:

• DAP9580.3 - FEMA: This document explicitly states that self-insurance is an option for States only. (https://www.fema.gov/assistance/individual)
• FEMA PA Policy Digest: Briefly mentions insurance requirements. ([invalid URL removed])

Important Note:

FEMA regulations can be subject to change.  For the most up-to-date information on insurance requirements and self-insurance options, it's always recommended to consult directly with FEMA program specialists.

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