This is in response to a letter from your office dated November 10, 2017, which transmitted the referenced second appeal on behalf of Christus Health (Applicant). The Applicant is appealing the Department of Homeland Security’s Federal Emergency Management Agency’s (FEMA) reductions for insurance proceeds on 16 PWs. As explained in the enclosed analysis, I have determined that the Applicant’s Deductible Buy Back is an insurance policy and the proceeds the Applicant received from it were correctly deducted by FEMA. In addition, FEMA’s apportionment of the insurance deductible among the facilities covered by the PWs was correct. Accordingly, I am denying this appeal. Please inform the Applicant of my decision. This determination is the final decision on this matter pursuant to 44 C.F.R. § 206.206, Appeals.