National Preparedness:

DHS and HHS Can Further Strengthen Coordination for Chemical, Biological, Radiological, and Nuclear Risk Assessments

GAO-11-606: Published: Jun 21, 2011. Publicly Released: Jun 21, 2011.

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The anthrax attacks of 2001 and more recent national reports have raised concerns that the United States is vulnerable to attacks with chemical, biological, radiological, and nuclear (CBRN) agents. Because of the potential consequences of such attacks, members of Congress have expressed the need for the Departments of Homeland Security (DHS) and Health and Human Services (HHS) to coordinate in assessing risks posed by CBRN agents. GAO was asked to examine how DHS and HHS coordinate on the development of CBRN risk assessments and the extent to which they have institutionalized such efforts. GAO examined relevant laws, presidential directives, collaboration best practices, and internal control standards; analyzed DHS and HHS CBRN risk assessments; and interviewed DHS and HHS officials.

DHS and HHS have coordinated with each other and with other federal departments to develop CBRN risk assessments, but neither department has written procedures for developing these assessments. GAO's best practices for interagency collaboration and federal standards for internal control indicate that agencies can best enhance and sustain coordination by adopting key practices, such as defining desired common outcomes, agreeing on roles and responsibilities, and developing written policies and procedures to help ensure that management directives are enforced. Such practices and standards could help DHS and HHS institutionalize their agreements on these sensitive and technical issues to better ensure coordination, collaboration, and continuity beyond the tenure of any given official or individual office. (1) DHS develops two types of CBRN risk assessments--terrorism risk assessments (TRA) and material threat assessments (MTA). TRAs assess the relative risks posed by multiple CBRN agents based on variable threats, vulnerabilities, and consequences. MTAs assess the threat posed by given CBRN agents or classes of agents and potential human exposures in plausible, high-consequence scenarios. DHS develops TRAs through interagency workgroups and has developed some MTAs in this way, which allow partners, such as HHS and the Department of Defense, to assess risk models and review and comment on the assessments. However, DHS does not have interagency agreements or written procedures for TRA and MTA development. In addition, DHS's processes and coordination with HHS for MTA development have varied, and HHS officials would like to be more involved. DHS officials told GAO they intend to develop procedures through interagency agreements with federal partners by June 2012 but have not yet established interim time frames or milestones for doing so. By establishing interim time frames and milestones for developing and obtaining interagency agreement on its CBRN risk assessments, DHS could better ensure that it completes its plans in the intended time frame. (2) HHS develops one type of CBRN risk assessment--modeling the public health consequences of attacks using information from DHS MTAs--through an interagency body that includes DHS and other departments, such as the Departments of Defense and Veterans Affairs. HHS signed an interagency agreement and charters with these partners, consistent with interagency coordination best practices. However, HHS does not have written procedures detailing the processes for developing the modeling reports, such as when and how its partners are to provide input and review and comment on the overall report. Written procedures for development and review of the modeling reports could provide HHS with standardized direction for obtaining, evaluating, and incorporating interagency input. In addition, the interagency agreement expires in June 2011, and HHS officials were not certain whether they would renew it based on ongoing revisions to the interagency charters. Renewing the interagency agreement or determining if the revised charters sufficiently outline key practices for working across agency boundaries could help ensure participating departments' commitment to work collaboratively. GAO recommends that DHS establish time frames and milestones to better ensure timely development and interagency agreement on written procedures for development of DHS's CBRN risk assessments and that HHS develop written procedures for obtaining and incorporating interagency input into its modeling reports and determine whether to renew its interagency agreement. DHS and HHS generally agreed. HHS expressed concern that the report implied it does not vet its products through its interagency partners, but GAO believes that it appropriately credited HHS with having a process to do so in the report.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: On October 10, 2012, the DHS Under Secretary for Science and Technology signed the document titled Strategic Implementation Plan for Conducting Material Threat Assessments (MTAs) and Issuance of Material Threat Determinations (MTDs). On November 15, 2012, the HHS Assistant Secretary for Preparedness and Response (ASPR) also signed the same document, finalizing it as guidance for both DHS and HHS in developing future MTAs and MTDs. This document outlines the roles, responsibilities, policies, and procedures for DHS and HHS to collaborate in conducting MTAs and issuing MTDs. Finalization of this guidance document addresses the spirit of our recommendation and we therefore consider the recommendation to be implemented by this action. In addition, in May 2013, DHS's Science and Technology Directorate's Chemical and Biological Defense Division (S&T CBD) and HHS's Biomedical Advanced Research and Development Authority--within the office of ASPR--jointly signed a memorandum of agreement (MOA). The MOA is designed to provide a framework for coordination to meet mutual requirements for modeling public health emergency responses, including with medical countermeasures, for incidents involving chemical, biological, radiological, or nuclear (CBRN) materials. Such modeling is used in S&T CBD's development of DHS's CBRN terrorism risk assessments. The MOA is intended to promote collaboration, the provision of subject matter expertise, and facilitate data and information exchange between DHS and HHS experts. Finalization of this MOA addresses the spirit of our recommendation and we therefore consider the recommendation to be implemented by this action. On October 24, 2013, the DHS Acting Under Secretary for Science and Technology signed the September 2013 document titled CBRN Terrorism Risk Assessments (TRAs) Engagement Strategy. DHS developed this document in direct response to our recommendation. It outlines DHS's strategy for engaging relevant stakeholders at other federal departments and agencies in the production and use of DHS's CBRN TRAs, as well as establishes three overarching goals for DHS's engagement with other federal stakeholders in the development of TRAs: Goal 1: Establish a clear path to guide engagement of strategic partners in the development of the TRAs. Goal 2: Identify policies and procedures for prioritizing future efforts to continually improve the evidence-base, utility, and communication of TRA products. Goal 3: Provide guidance and support for stakeholders in the appropriate use and interpretation of TRA results in support of U.S. national preparedness efforts. On February 4, 2014, the HHS Assistant Secretary for Preparedness and Response also signed the same document, finalizing it as guidance for both DHS and HHS. Finalization of this guidance document addresses the spirit of our recommendation and we therefore consider the recommendation to be implemented by this action.

    Recommendation: To ensure that DHS senior officials are able to monitor progress on the development of the proposed strategic and implementation plans for DHS's CBRN risk assessment efforts, the Secretary of Homeland Security should develop and document interim time frames and milestones as part of a plan to develop, finalize, and obtain interagency agreement on the written procedures for interagency development of the TRAs and MTAs that DHS intends to issue as strategic and implementation plans.

    Agency Affected: Department of Homeland Security

  2. Status: Closed - Implemented

    Comments: On June 29, 2012, the Assistant Secretary for Preparedness and Response (ASPR) noted that "HHS continues to work with DHS on an improved process for consensus regarding the types of threat scenario(s) used to produce medical and public health consequences assessments and civilian medical countermeasure requirements, which we anticipate will be completed in the coming months. Once completed these improvements will be incorporated into any written templates for medical countermeasure requirements generation." In September 2014, ASPR officials noted that HHS had developed written procedures for obtaining, evaluating, and incorporating interagency input into the development and review of the modeling reports. HHS cited the Department of Homeland Security's November 2012 Strategic Implementation Plan to Conduct Material Threat Assessments as evidence of these procedures.

    Recommendation: To ensure that HHS and its federal partners are fully aware of and agree with the processes for developing the public health and medical consequence modeling reports and that consistent and effective interagency coordination continues, the Secretary of Health and Human Services should develop written procedures for obtaining, evaluating, and incorporating interagency input into the development and review of the modeling reports, to supplement the Public Health Emergency Medical Countermeasures Enterprise (PHEMCE) memorandum of understanding (MOU) and working group charters.

    Agency Affected: Department of Health and Human Services

  3. Status: Closed - Implemented

    Comments: On June 29, 2012, the Assistant Secretary for Preparedness and Response provided documentation that indicated it had finalized the interagency memorandum of understanding between the Department of Health and Human Services, the Centers for Disease Control, the National Institutes of Health, and the Food and Drug Administration. As a result, this recommendation is closed as implemented.

    Recommendation: To ensure that HHS and its federal partners are fully aware of and agree with the processes for developing the public health and medical consequence modeling reports and that consistent and effective interagency coordination continues, the Secretary of Health and Human Services should determine whether to renew the MOU or whether alternate coordination mechanisms, such as the PHEMCE senior council charter, are sufficient to confirm federal departments' agreement to work collaboratively.

    Agency Affected: Department of Health and Human Services

 

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