If you and your NFIP insurer disagree on the amount of a flood loss, either side can demand an appraisal

Floodwater standing in front of a row of brick and white-trimmed houses behind a wooden fence
By Preston Stewart, All Seasons Insurance Group  ·  October 29, 2026

A flood claim dispute can be about the value of damaged property rather than whether the loss is covered. If you think the insurer valued your floors, drywall, or furnace too low, the National Flood Insurance Program's Standard Flood Insurance Policy, Dwelling Form includes an appraisal clause. It says that if you and the insurer fail to agree on the actual cash value or, if it applies, the replacement cost of damaged property to settle the amount of loss, either side may demand an appraisal.

StepWhat the Dwelling Form says
TriggerYou and the insurer fail to agree on actual cash value or replacement cost to settle the amount of loss
AppraisersEach side picks a competent and impartial appraiser within 20 days of the other's written request
UmpireChosen by the two appraisers; if no agreement in 15 days, a judge of a court of record in the state may choose
ValuationAppraisers separately state actual cash value, replacement cost, and amount of loss for each item
DecisionA written agreement of the appraisers sets the loss; otherwise any two of the three decide
CostEach side pays its own appraiser; other appraisal and umpire costs are split equally
Lawsuit deadlineWithin one year after the written denial of all or part of the claim, in U.S. District Court

Source: 44 CFR Part 61, Appendix A(1).

What appraisal is for

The clause is written around value: the actual cash value or replacement cost of damaged property and the amount of loss. It is a way to settle a dollar disagreement with people who know construction and pricing, without going straight to court. Before you demand it, make sure you understand what the policy covers and what it does not: An NFIP flood policy does not pay for decks, fences, landscaping, cars, or a hotel while your home is repaired. and Tennessee homeowners with basements should know an NFIP flood policy pays for only a short list of items below ground level.

How it works, step by step

  1. A written request. Either side asks for appraisal. Each side then has 20 days after receiving the other's written request to choose a competent and impartial appraiser.
  2. The umpire. The two appraisers choose an umpire. If they cannot agree within 15 days, you or the insurer may ask a judge of a court of record in the state where the property is located to make the choice. For a Tennessee house, that is a Tennessee court.
  3. Item by item. The appraisers separately state the actual cash value, the replacement cost, and the amount of loss to each item.
  4. Agreement or umpire. If the two appraisers submit a written agreement, that amount is the amount of loss. If they cannot agree, their differences go to the umpire, and a decision agreed to by any two of the three sets the amount.

Who pays for it

Each side pays its own appraiser. The other expenses of the appraisal and the umpire are shared equally. Ask any appraiser you are considering for a fee estimate in writing, and compare that cost with the size of the gap you are trying to close.

Keep the other deadlines in view

Appraisal does not replace the policy's other requirements. The proof of loss rules still matter: A Tennessee flood claim under the NFIP comes with a 60-day proof-of-loss deadline that the adjuster will not file for you.

The policy also says that if you sue, you must start the suit within one year after the date of the written denial of all or part of the claim, and file it in the United States District Court for the district where the property was located at the time of loss. If a denial letter arrives, note the date. Do not assume appraisal pauses or extends the lawsuit deadline; get legal advice before that deadline.

Before you ask for appraisal

For general claim disputes, see Storm Claim Underpaid in Tennessee? Your Next Steps and TDCI explains Actual Cash Value versus Replacement Cost for Tennessee homeowners. Still deciding on flood coverage? Start with Tennessee Flood Insurance: Everything Homeowners Need to Know in 2026

This article is informational only. It summarizes the NFIP Standard Flood Insurance Policy and is not legal advice. It does not promise coverage, eligibility, or any claim result; the policy, NFIP rules, and your insurer control.

Related reading from All Seasons

Free policy review

All Seasons Insurance Group offers a free personal policy review. Call 865-263-1400 or visit asigtn.com/get-a-quote/. This article is informational only and does not promise coverage or eligibility; your policy forms control. Seasons change. So should your coverage.

Can I demand an appraisal on an NFIP flood claim?

The Standard Flood Insurance Policy Dwelling Form says that if you and the insurer fail to agree on the actual cash value or replacement cost to settle the amount of loss, either may demand an appraisal.

How long do I have to pick an appraiser?

Each side chooses a competent and impartial appraiser within 20 days after receiving a written request from the other.

Who picks the umpire?

The two appraisers choose an umpire. If they cannot agree within 15 days, either side may ask a judge of a court of record in the state where the property is located to choose.

How is the final amount decided?

If the appraisers submit a written agreement, that is the amount of loss. If not, their differences go to the umpire, and a decision agreed to by any two sets the amount.

Who pays for a flood claim appraisal?

Each party pays its own appraiser and bears the other expenses of the appraisal and umpire equally.

What do the appraisers actually value?

They separately state the actual cash value, the replacement cost, and the amount of loss to each item.

How long do I have to sue over a flood claim denial?

The policy says a suit must be started within one year after the date of the written denial of all or part of the claim, in the U.S. District Court for the district where the property was located.

How can All Seasons help after reading this?

Call 865-263-1400 or visit asigtn.com/get-a-quote/ for a free personal policy review. Informational only; no coverage promises. Seasons change. So should your coverage.

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