Emergency Preparedness: Agencies Need Coordinated Guidance on Incorporating Telework into Emergency and Continuity Planning
Highlights
When historic snowstorms forced lengthy closings of federal offices in the National Capital Region in 2010, thousands of employees continued to work from their homes, making clear the potential of telework in mitigating the effects of emergencies. GAO was asked to (1) describe the guidance lead agencies have issued pertaining to the use of telework during emergencies; (2) describe Office of Personnel Management (OPM) and other assessments related to agencies' incorporation of telework into emergency or continuity planning, and the extent to which the lead agencies have provided definitions and practices to support agency planning; and (3) assess the extent to which OPM and the Federal Emergency Management Agency (FEMA) coordinated with other agencies on recent guidance documents. To address these objectives, GAO reviewed relevant statutes, regulations, guidance documents, and OPM's telework survey methodology, and interviewed key officials of agencies providing telework and telework-related emergency guidance.
OPM, the General Services Administration (GSA), FEMA, and the Federal Protective Service (FPS) offer a host of telework and telework-related emergency guidance. These lead agencies provide advice to other federal agencies through regulations, directives, guides, bulletins, and other documents. Several of these guidance documents have expanded significantly in recent years, broadening the scope of the topics that they address and describing broader responsibilities for the lead agencies. The Telework Enhancement Act of 2010 requires agencies to incorporate telework policies into their continuity of operations plans, but recent OPM reviews and other agency reports identify potential problems agencies may face in achieving this incorporation in various operational areas. GAO's review of the OPM, GSA, FEMA, and FPS governmentwide guidance on telework or telework-related emergency planning found that none of the documents provide a definition of what constitutes incorporating telework into continuity and emergency planning or a cohesive set of practices that agencies could use to achieve this type of incorporation. Additionally, this lack of a definition or description calls into question the reliability of the results of a survey OPM annually conducts to assess agencies' progress. In reviewing several lead-agency guidance documents, GAO found a number of practices, in areas such as information technology (IT) infrastructure and testing, that could help agencies incorporate telework in aspects of their continuity or emergency planning. However, because the practices are scattered among various documents principally concerned with other matters, it would be difficult for an agency to use these practices to help achieve telework incorporation and assess its progress. Both OPM and FEMA coordinated the development of their recent guidance. OPM updated its Washington, D.C., area dismissal and closure procedures to introduce "unscheduled telework," a new option for federal employees to telework when emergencies disrupt commuting. While developing these procedures, OPM officials reported coordinating with GSA, agency human-capital officials, FEMA, unions, and the Metropolitan Washington Council of Governments, among others. However, OPM and GSA did not work together to reach out to agency chief information officers regarding potential agency capacity limitations. Consequently, officials did not offer any governmentwide guidance on ways to address IT infrastructure limitations or provide direct assistance to agencies regarding the adequacy of their IT infrastructure. In February 2011, FEMA provided agencies with more-detailed guidance for developing continuity plans. According to FEMA officials, in 2010 they shared a draft of the guidance with the interagency community, including both continuity coordinators and continuity planners, and GSA. GAO recommends that OPM consult with other lead agencies to develop a definition and cohesive set of practices for incorporating telework into emergency and continuity planning; improve its related data collection; and establish an interagency coordination process for guidance. OPM concurred with GAO's recommendations.
Recommendations
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Office of Personnel Management | To enhance the potential use of telework during emergencies, the Director of OPM, in consultation with agencies responsible for key policy areas specified under the Telework Act and with other agencies providing governmentwide guidance on emergency preparedness, such as FPS, should develop (1) a definition of what constitutes incorporating telework in emergency and continuity plans and (2) a cohesive set of practices that agencies should implement to achieve successful incorporation. |
With OPM input, the Federal Emergency Management Agency published a revised Federal Continuity Directive 1 in October 2012 detailing new policies and clarifications to give direction for the further development of continuity plans and programs for agencies. The document provides a definition of what constitutes incorporating telework into emergency and continuity plans and outlines a number of practices to achieve successful incorporation, including planning, training, IT infrastructure, and data collection. Such a definition and set of practices will better position agencies to implement the Telework Enhancement Act of 2010 and effectively utilize telework during emergencies.
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| Office of Personnel Management | To enhance the potential use of telework during emergencies, the Director of OPM, in consultation with agencies responsible for key policy areas specified under the Telework Act and with other agencies providing governmentwide guidance on emergency preparedness, such as FPS, should revise OPM's data-collection methodology to ensure agencies and OPM report reliable results on the extent to which agencies have incorporated telework into their emergency and continuity planning and operations. |
OPM revised its data collection methodology for its 2013 Telework data call by adding questions about incorporating telework into agency continuity of operations plans. In April 2014, OPM administered the revised 2013 telework data call survey to executive agencies. In April 2015, GAO confirmed agencies responded to OPM's revised survey about the extent to which they have incorporated telework into their continuity of operations plans. Taking these steps will increase the likelihood that agencies and OPM are reporting data that are relevant and consistent with Federal Continuity Directive 1 Annex G guidance on incorporating telework into agencies' continuity plan.
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| Office of Personnel Management | To enhance the potential use of telework during emergencies, the Director of OPM, in consultation with agencies responsible for key policy areas specified under the Telework Act and with other agencies providing governmentwide guidance on emergency preparedness, such as FPS, should establish an interagency coordination process among OPM, FEMA, FPS, GSA, and the National Archives and Records Administration (NARA) to ensure all major areas of agency operations are considered when OPM issues new or updated guidance related to using telework during emergencies. |
To address the GAO report findings, in August 2011 OPM reconvened the interagency group of agencies that were designated in the Telework Enhancement Act of 2010 to be responsible for providing telework policy and policy guidance for telework. In addition to this interagency consultation required by the act, OPM has designated a position responsible for liaison between OPM and the emergency preparedness community. This liaison represents OPM's interests in other interagency continuity community working groups. OPM distributes its telework guidance through the FEMA Interagency Continuity Working Group (ICWG)and the FEMA Continuity Advisory Group (CAG) for review and comment by the continuity community. OPM also participates in the White House Resilience Group (DRG) which addresses issues that cannot be resolved at lower levels. These review processes provide the participation, reviews and comment necessary to provide consideration of agency operations when OPM issues new or updated guidance related to using telework during emergencies.
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