Continuity of Operations:

Agency Plans Have Improved, but Better Oversight Could Assist Agencies in Preparing for Emergencies

GAO-05-577: Published: Apr 28, 2005. Publicly Released: Apr 28, 2005.

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To ensure that essential government services are available in emergencies, federal agencies are required to develop continuity of operations plans. According to guidance from the Federal Emergency Management Agency (FEMA), which is responsible for providing guidance for and assessing agency continuity plan, a key element of a viable capability is the proper identification of essential functions. GAO previously reported on agency continuity plan compliance, and determined that a number of agencies and their components did not have continuity plans in place on October 1, 2002, and those that were in place did not generally comply with FEMA's guidance. GAO was asked to determine, among other things, to what extent (1) major federal agencies used sound practices to identify and validate their essential functions and (2) agencies had made progress since 2002 in improving compliance with FEMA guidance.

Many of the 23 agencies that GAO reviewed reported using sound practices for identifying and validating essential functions, but few provided documentation sufficient for GAO to confirm their responses. This indicates that agencies--although aware of the practices--may not have followed them thoroughly or effectively. Further, the essential functions identified by agencies varied widely: the number of functions identified in each plan ranged from 3 to 538 and included ones that appeared to be of secondary importance. A major factor contributing to these shortcomings was that FEMA's guidance did not provide specific criteria for identifying essential functions. Subsequent guidance from FEMA and the White House significantly addresses the sound practices GAO identified. In addition, the White House plans further actions to improve continuity planning. If this guidance and these follow-up actions are implemented effectively, they could lead to improved identification of essential functions in the executive branch. As of May 1, 2004, agencies had made progress in improving compliance with FEMA guidance, but significant weaknesses remained. Agencies that had plans in place in both years showed significant improvement in the area of tests, training, and exercises. However, although some improvement occurred for other planning areas, important weaknesses remained: for example, 31 of 45 plans did not fully identify mission-critical systems and data necessary to conduct essential functions. Inadequate oversight by FEMA contributed to the level of weaknesses in agency continuity plans. FEMA plans to improve oversight using an online readiness reporting system, which it plans to have fully operational later this year, and it has already taken other steps to help agencies improve their plans, such as conducting an interagency exercise. However, FEMA does not plan to verify the readiness information that agencies will report in the system.

Status Legend:

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  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: The Secretary of Homeland Security should direct the Under Secretary for Emergency Preparedness and Response to develop and implement procedures that verify the agency-reported data used in oversight of agency continuity of operations planning.

    Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response

    Status: Closed - Implemented

    Comments: In June 2006 as part of the Forward Challenge 06 continuity exercise, FEMA-selected independent evaluators performed assessments of COOP plans from executive branch agencies. These assessments validated information contained within agency COOP plans and identified strengths and weaknesses in an effort to improve agency continuity capabilities.

    Recommendation: The Secretary of Homeland Security should direct the Under Secretary for Emergency Preparedness and Response to develop a strategy for short-term oversight that ensures that agencies are prepared for a disruption in essential functions while the current effort to identify essential functions and develop new guidance is ongoing.

    Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response

    Status: Closed - Implemented

    Comments: Consistent with our recommendation, in May 2006 the Department of Homeland Security outlined a plan for oversight of agency COOP programs. The outlined plan provided a timeline for steps FEMA would take to compile and evaluate agency COOP plans, including assessments by external evaluators prior to a government-wide exercise in June 2006. This oversight could contribute to more effective agency plans, which in turn could increase the likelihood that agencies will effectively respond to emergency disruptions.

    Recommendation: To ensure that agencies are adequately prepared to continue performing essential functions following an emergency, the Assistant to the President for Homeland Security should establish a schedule for the completion of the recently initiated effort to validate agency essential functions and refine federal continuity of operations policy.

    Agency Affected: Executive Office of the President: Office of the Assistant to the President for Homeland Security

    Status: Closed - Not Implemented

    Comments: DHS did not respond to numerous requests for an update on the status of implementation of this recommendation. A review of public information on the federal continuity program did not reveal evidence that this recommendation had been implemented.

    Recommendation: The Secretary of Homeland Security should direct the Under Secretary for Emergency Preparedness and Response to develop, in consultation with the Office of Personnel Management, guidance on the steps that agencies should take to adequately prepare for the use of telework during a continuity of operations event.

    Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response

    Status: Closed - Implemented

    Comments: Consistent with our recommendation, in August 2006, the Office of Personnel Management (OPM) issued guidance on the steps that agencies should take to prepare for the use of telework during a COOP event. The Guide to Telework in the Federal Government provides guidance to agencies on teleworking during COOP events, including a discussion on informing selected employees of their expectation to telework during a COOP event. The new guidance outlines COOP manager and teleworker responsibilities as well as resources telework managers need to consider in implementing telework into agency COOP planning.

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