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United States Government Accountability Office: 
GAO: 

Report to the Subcommittee on Oversight of Government Management, the 
Federal Workforce, and the District of Columbia, Committee on Homeland 
Security and Governmental Affairs, U.S. Senate: 

July 2011: 

Emergency Preparedness: 

Agencies Need Coordinated Guidance on Incorporating Telework into 
Emergency and Continuity Planning: 

GAO-11-628: 

GAO Highlights: 

Highlights of GAO-11-628, a report to the Subcommittee on Oversight of 
Government Management, the Federal Workforce, and the District of 
Columbia, Committee on Homeland Security and Governmental Affairs, 
U.S. Senate. 

Why GAO Did This Study: 

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. 

What GAO Found: 

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. 

What GAO Recommends: 

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. 

View [hyperlink, http://www.gao.gov/products/GAO-11-628] or key 
components. For more information, contact Bernice Steinhardt at (202) 
512-6543 or steinhardtb@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

OPM, GSA, FEMA, and FPS Have Provided Agencies with Guidance Related 
to Using Telework during Emergencies: 

Agencies May Need Assistance with Incorporating Telework into 
Emergency or Continuity Operations: 

OPM and FEMA Coordinated Recently Issued Guidance with Some 
Stakeholders, but OPM Did Not Tap into the CIO Community: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Examples of Practices Suggested to Federal Agencies for 
Incorporating Telework into Emergency and Continuity Planning and 
Operations: 

Appendix III: Comments from the Office of Personnel Management: 

Appendix IV: Comments from the Department of Homeland Security: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Agency Responsibilities under 2003 OPM-GSA Telework MOU: 

Table 2: OPM's Policy and Policy Guidance Consultation 
Responsibilities, per the Telework Enhancement Act of 2010: 

Table 3: OPM Guidance Related to Use of Telework during Emergencies: 

Table 4: Sources of GSA Guidance Related to Use of Telework during 
Emergencies: 

Table 5: Sources of FEMA and FPS Guidance Related to Use of Telework 
during Emergencies: 

Table 6: Agencies' Responses on the Extent to Which They Have Tested 
IT Infrastructure to Ensure That It Is Capable of Handling Telework or 
Work-at-Home Arrangements during a Pandemic Influenza Outbreak: 

Table 7: Examples of Practices That OPM, GSA, FEMA, or FPS Have 
Suggested to Federal Agencies for Incorporating Telework into 
Emergency or Continuity Planning: 

Abbreviations: 

AWA: alternative workplace arrangement: 

CHCO: Chief Human Capital Officer: 

CIO: Chief Information Officer: 

COOP: continuity of operations: 

DHS: Department of Homeland Security: 

DOE: Department of Energy: 

FCD 1: Federal Continuity Directive 1: 

FEB: Federal Executive Board: 

FEMA: Federal Emergency Management Agency: 

FMR: Federal Management Regulation: 

FPS: Federal Protective Service: 

GSA: General Services Administration: 

IT: information technology: 

MOU: Memorandum of Understanding: 

NARA: National Archives and Records Administration: 

NCP: National Continuity Programs: 

NRC: Nuclear Regulatory Commission: 

OEP: occupant emergency plan: 

OPM: Office of Personnel Management: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

July 22, 2011: 

The Honorable Daniel K. Akaka: 
Chairman: 
The Honorable Ron Johnson: 
Ranking Member: 
Subcommittee on Oversight of Government Management, the Federal 
Workforce, and the District of Columbia: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

Historic snowstorms forced the Office of Personnel Management (OPM) to 
close federal executive agencies in the Washington, D.C., area 
[Footnote 1] for 4 consecutive days in February 2010. The closure 
resulted in a particularly lengthy interruption in the government's 
routine operations and hours of employee productivity were lost. 
Despite being unable to commute to their offices, thousands of federal 
employees continued to work, to some degree, by teleworking from their 
homes, according to OPM estimate[Footnote 2]s. Drawing on this 
experience, the Director of OPM testified in March 2010 that telework 
was "the one effective and important tool that could make the 
difference between shutting down federal government services and 
continuing to operate with minimal interruption in emergency 
situations.[Footnote 3]" 

While achieving widespread use of telework during emergencies could 
enhance the federal government's operational resilience and reduce the 
costs of lost productivity, making use of telework during emergencies 
governmentwide is not a simple undertaking. As we have previously 
reported, implementing telework during normal conditions affects 
several areas of consideration, such as human-capital policies and 
procedures, information technology infrastructure (equipment, 
software, and security), telecommunication infrastructure, and 
facility space utilization.[Footnote 4] In addition, implementing the 
use of telework during an emergency situation requires its 
incorporation into the unique requirements of emergency planning and 
operations. 

Three agencies have drawn on their respective areas of responsibility 
and expertise to offer guidance to executive-branch agencies on how to 
incorporate telework into routine and emergency operations. OPM 
provides governmentwide human-capital policies, and within that 
context has provided guidance to agencies on using telework during 
routine and emergency operations. OPM has also provided technical 
assistance to agencies on implementing their telework programs, such 
as through reviewing their telework policies. The General Services 
Administration (GSA) provides governmentwide guidance on the use of 
federal facilities and the purchase of equipment, and has issued 
guidance regarding facilities, technology, and workplaces to help 
promote telework. The Federal Emergency Management Agency (FEMA) 
provides governmentwide guidance on emergency preparedness, and within 
that context, has offered guidance relating to the potential use of 
telework in agency continuity of operations (COOP) plans and 
operations.[Footnote 5] In addition to these three agencies, the 
Federal Protective Service (FPS) provides governmentwide guidance that 
could influence the potential use of telework during emergencies. FPS 
provides security at GSA-owned or leased facilities and has issued 
guidance to agencies on developing plans to keep building occupants 
safe during emergencies. 

In response to your request to evaluate the role these lead agencies 
are playing in providing guidance that promotes the use of telework 
during emergencies, this report will (1) describe the guidance that 
OPM, GSA, FEMA, and FPS have issued pertaining to the use of telework 
during emergencies; (2) describe 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 FEMA coordinated with other agencies on 
the development of their recently released guidance documents 
pertaining to the use of telework during emergencies. 

To address these three objectives, we reviewed governmentwide telework 
and emergency-related statutes. We also reviewed regulations and 
guidance issued by OPM, GSA, FEMA, and FPS and conducted interviews 
with key officials from each of these agencies regarding each 
objective. We conducted additional data collection and analyses to 
answer selected objectives. To assess the extent to which OPM's recent 
reviews of the agencies' telework policies and programs addressed the 
incorporation of telework into continuity plans, we reviewed OPM's 
annual telework survey and its 2010 evaluation of agency telework 
policies. We compared the methodologies OPM used to generally accepted 
survey and evaluation methodologies. To identify practices suggested 
by OPM, GSA, FEMA, and FPS for incorporating telework into continuity 
or emergency planning, we reviewed these agencies' related 
governmentwide regulations and guidance. We compared these practices 
to practices that GAO previously suggested for the same purpose and 
identified examples of practices suggested by OPM, GSA, FEMA, and FPS 
that were similar to GAO-suggested practices. 

We conducted this performance audit from February 2010 through July 
2011 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

Legislation related to telework began to emerge from Congress in the 
1990s. For example, beginning in 1992, Congress provided funding to 
GSA to establish the first federal telework centers.[Footnote 6] Three 
years later, Congress permanently authorized federal agencies to spend 
money to install telephone lines and related equipment and pay monthly 
charges for federal workers authorized to work at home, in accordance 
with OPM guidelines.[Footnote 7] Within the legislation that evolved 
from 1992 through 2009, the most significant congressional action was 
the enactment of Section 359 of Pub. L. No. 106-346 in October 2000. 
This section required each executive-branch agency to establish a 
telework policy "under which eligible employees of the agency may 
participate in telecommuting to the maximum extent possible without 
diminished employee performance."[Footnote 8] It also directed OPM to 
provide that the law's requirements were applied to 25 percent of the 
federal workforce by April 2001 and to an additional 25 percent of the 
federal workforce in each subsequent year, until 2004 when the law was 
to be applied to 100 percent of the federal workforce. 

From 2005 through 2009, federal workforce participation in routine 
telework has remained low. In calendar year 2009, according to OPM's 
latest survey of federal agency telework coordinators, less than 6 
percent of federal employees employed by the 79 agencies that 
responded to the survey teleworked at least 1 day per month, while 
less than 4 percent of the federal workforce employed by these 
agencies teleworked at least 1 day per week. The estimated percentage 
of employees teleworking at least 1 day per month, relative to the 
number of the federal employees employed by the agencies that 
responded to the survey, has remained between 5 and 7 percent, since 
calendar year 2005. 

The legislation for telework provided both OPM and GSA with leadership 
roles in the implementation of telework in the federal government. 
However, in 2003, we reported that the lack of coordination between 
OPM and GSA had resulted in executive agencies receiving conflicting 
messages on several telework-related topics, including emergency 
closings of government offices. These conflicting messages had created 
confusion for federal agencies in implementing their individual 
telework programs. To provide federal agencies with consistent, 
inclusive, unambiguous support and guidance related to telework, we 
recommended that OPM and GSA better coordinate their efforts.[Footnote 
9] In response, OPM and GSA agreed later that year on a Memorandum of 
Understanding (MOU).[Footnote 10] Under this MOU, OPM and GSA agreed 
to the respective responsibilities listed in table 1. 

Table 1: Agency Responsibilities under 2003 OPM-GSA Telework MOU: 

Agency: OPM; 
Agency responsibilities: 
* Continue to maintain the joint website www.telework.gov; 
* Continue to conduct an annual survey of agency telework programs and 
report to Congress; 
* Develop human-resources management policy and guidance to help 
agencies promote telework, in coordination with GSA. 

Agency: GSA; 
Agency responsibilities: 
* Provide guidance on innovative workplace initiatives; 
* Continue to develop, pilot-test, promote, and provide guidance on 
innovative workplace initiatives; 
* Continue to provide telecenters where a demonstrated need exists; 
* Continue to seek resolution to issues regarding information 
technology (IT) support for telework where concerns about the 
selection, acquisition, funding, and support for home IT equipment 
continue to be a barrier to the successful implementation of telework 
programs. OPM will work with GSA to reach appropriate groups of chief 
information officers (CIO) to facilitate their greater involvement in 
agency long-term planning; 
* Develop innovative workplace policy and guidance as well as policy 
and guidance in other areas under GSA's mission (such as travel, 
facility management/real property, or telecommunications policy) to 
help agencies promote telework, in coordination with OPM; 
* Continue to maintain the federal telework listserv and 
communications with the network of federal agency telework 
coordinators. 

Source: OPM, GSA. 

[End of table] 

The agencies also agreed in the MOU to continue to share draft 
telework documents to ensure mutual concurrence. 

Recently, Congress passed a framework for implementing a comprehensive 
federal telework program. Congress passed the Telework Enhancement Act 
of 2010[Footnote 11] in November 2010, and the President signed it 
into law in December 2010. The law requires each executive agency to 
designate a telework managing officer, establish a telework policy, 
and submit an annual report to the Chair and Vice Chair of the Chief 
Human Capital Officers (CHCO) Council[Footnote 12] on the agency's 
efforts to promote telework. Under the act, OPM is to play a leading 
role in helping agencies implement the new telework provisions. The 
law requires OPM to provide policy and policy guidance for telework in 
several areas, including pay and leave, agency closure, performance 
management, official worksite, recruitment and retention, and 
accommodations for employees with disabilities. In developing its 
telework policy and policy guidance, OPM is to consult with FEMA, GSA, 
and the National Archives and Records Administration (NARA) relative 
to their designated areas of policy responsibility, as listed in table 
2. NARA provides guidance to agencies on ensuring the federal 
government's essential records are, among other things, secure and 
accessible to key federal personnel during emergencies. 

Table 2: OPM's Policy and Policy Guidance Consultation 
Responsibilities, per the Telework Enhancement Act of 2010: 

Agency: GSA; 
Designated areas of policy and policy guidance for telework: 
* Telework centers; 
* Travel; 
* Technology; 
* Equipment; 
* Dependent care. 

Agency: FEMA; 
Designated areas of policy and policy guidance for telework: 
* COOP; 
* Long-term emergencies. 

Agency: NARA; 
Designated areas of policy and policy guidance for telework: 
* Efficient and effective records management; 
* Preservation of records, including Presidential and Vice-
Presidential records. 

Source: Telework Enhancement Act. 

[End of table] 

The Telework Enhancement Act also includes several provisions related 
to the potential use of telework during emergencies. The law requires 
agencies to incorporate telework into their COOP plans. OPM is to 
report annually to Congress and provide its assessment of each 
agency's progress toward its goals, such as the effect of telework on 
emergency readiness. Finally, the act requires the Director of OPM to 
research the utilization of telework that identifies best practices 
and recommendations for the federal government and review the outcomes 
associated with an increase in telework. Agencies with jurisdiction 
over such matters as energy consumption, urban transportation 
patterns, and planning the dispersal of work during periods of 
emergency, shall work cooperatively with the Director, as necessary, 
to carry out these research responsibilities. 

OPM, GSA, FEMA, and FPS Have Provided Agencies with Guidance Related 
to Using Telework during Emergencies: 

OPM, GSA, FEMA, and FPS offer a host of guidance on telework or 
telework-related emergency planning.[Footnote 13] 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. 

After Congress required agencies to establish a telework policy in 
2000,[Footnote 14] OPM provided several telework guidance documents to 
agencies. OPM's major telework guidance is contained in the Guide to 
Telework in the Federal Government.[Footnote 15] According to Federal 
Continuity Directive 1 (FCD 1), OPM is also responsible for developing 
and promulgating personnel guidance to support the operation of 
federal executive-branch agencies during emergencies.[Footnote 16] OPM 
has also issued regulations providing uniform instructions to agencies 
on making payments to employees evacuated due to, among other reasons, 
natural disasters and pandemic health crises.[Footnote 17] OPM also 
has the lead role, by mutual agreement with other agencies in the 
region, in determining when to close federal offices and dismiss 
employees in the Washington, D.C., area. According to OPM, these 
procedures, referred to as the Dismissal Guide, ensure a coordinated 
response to areawide disruptions, which is important given the 
concentration of federal employees in this area. According to an OPM 
official, its dismissal and closure procedures are updated annually. 
The latest procedures were issued in December 2010.[Footnote 18] While 
these procedures directly apply only to executive agencies in the 
Washington, D.C. area, OPM officials explained that agency leaders in 
other regions of the United States use OPM's procedures as a model. In 
addition, OPM's guidance on managing human-capital resources during 
emergencies and continuity events was included in FEMA's directive to 
executive agencies on developing and implementing continuity 
plans.[Footnote 19] Table 3 lists examples of OPM guidance relating to 
the use of telework during various types of emergencies, as provided 
in OPM and FEMA documents. 

Table 3: OPM Guidance Related to Use of Telework during Emergencies: 

Policy area: Pay and leave; 
Sources: 
* Federal regulation 5 C.F.R. part 550, subpart D, Payments During 
Evacuation; 
* Handbook on Pay and Leave Benefits for Federal Employees Affected by 
Severe Weather Conditions or Other Emergency Situations (Washington, 
D.C.: June 2008). 

Policy area: Emergency-specific; 
Sources: 
* Human Resources Flexibilities Available to Assist Federal Employees 
During Emergencies (Washington, D.C.: May 5, 2009); 
Guidance memos pertaining to specific events, such as: 
* Inclement Weather Response in the Washington, DC Area for February 
5, 2010; 
* Planning for Pandemic Influenza (Washington, D.C.: May 2009) and 
Pandemic Influenza 2009: Additional Guidance (Washington, D.C.: July 
2009). 

Policy area: Regional-specific; 
Sources: 
* Washington, DC Area Dismissal and Closure Procedures (Washington, 
D.C.: December 2010). 

Policy area: Continuity planning; 
Sources: 
* Annex J, "Human Capital," in FEMA's FCD 1 (Washington, D.C.: 
February 2008). 

Policy area: Telework; 
Sources: 
* Guide to Telework in the Federal Government (Washington, D.C.: April 
2011). 

Source: OPM and FEMA. 

[End of table] 

Since 2000, OPM has expanded the scope of its guidance on the use of 
telework in the federal government. For example, the telework guidance 
OPM issued in 2001 listed several topics agencies should address in 
their telework policies. The current version of OPM's guidance for 
routine telework, the 2011 Telework Guide, provides guidance for 
managers and employees on an array of topics, such as the telework 
agreement, purchasing equipment, communications, and performance 
management.[Footnote 20] This guide also provides advice on using 
telework during emergencies, continuity events, and pandemics. 
Compared to the 2006 Telework Guide, the immediate predecessor to the 
2011 Guide, the 2011 Guide added: 

* a summary of the major sections of the Telework Enhancement Act; 

* the checklist items that OPM used to evaluate telework policies to 
help agency officials assess and revise their policies; 

* guidance on pay, leave, and work-schedule flexibilities, including 
the new option of unscheduled telework; and: 

* telework and reasonable accommodations for employees with 
disabilities. 

During the same period, OPM expanded some of its emergency-related pay 
and leave policies. For example, OPM broadened its regulations on pay 
during an evacuation to include, in the event of a pandemic health 
crisis, permission for agencies to order employees to work from home 
(or an alternative location), regardless of whether they have a 
telework agreement. 

As the lead agency in the management of federal workplaces, GSA 
provides governmentwide workplace guidance related to telework, 
emergency planning, and continuity planning and operations. Under its 
authority to provide guidance, assistance, and oversight on the 
establishment and operation of alternative workplace arrangements, 
such as telework,[Footnote 21] GSA has issued guidelines, through 
Federal Management Regulation (FMR) Bulletins, on the use of 
information and telecommunication technology to support telework and 
the implementation and operation of alternative workplace 
arrangements, as shown in table 4. GSA, under its responsibility to 
operate, maintain, and protect the buildings and grounds it controls, 
also leads the federal Occupant Emergency Program, which consists of 
short-term emergency-response programs for particular 
facilities.[Footnote 22] Under this program, each agency or facility 
develops and maintains an occupant emergency plan (OEP) which details 
the procedures for safeguarding lives and property, such as evacuation 
or shelter-in-place, in response to a wide range of emergencies. 
[Footnote 23] At the agency level, the OEP and the continuity plan are 
the principal emergency-response plans. According to GSA's 
regulations, GSA approves OEPs for GSA-controlled facilities. Lastly, 
as described in FCD 1, GSA is also responsible for assisting FEMA and 
other federal agencies in continuity planning and operations. GSA's 
ongoing responsibilities include coordinating the provision of 
facilities to support the continuity of the executive-branch agencies 
and providing data on alternate facilities. 

Table 4: Sources of GSA Guidance Related to Use of Telework during 
Emergencies: 

Policy area: Alternative workplace arrangements and telework; 
Sources: 
* Federal regulation 41 C.F.R. §§ 102-74.585 to 102-74.600 on Telework; 
* Federal Management Regulation (FMR) Bulletin 2006-B3, "Guidelines 
for Alternative Workplace Arrangements," 71 Fed. Reg. 13845 (Mar. 17, 
2006); 
* FMR Bulletin 2007-B1, "Information Technology and Telecommunications 
Guidelines for Federal Telework and Other Alternative Workplace 
Arrangement Programs," 72 Fed. Reg. 9532 (Mar. 2, 2007). 

Policy area: Emergency planning; 
Sources: 
* Federal regulation 41 C.F.R. §§ 102-74.230 to 102-74.260 on the 
Occupant Emergency Program; 
* FEMA, "Continuity Facilities," Annex G, FCD 1 (Washington, D.C.: 
February 2008). 

Sources: GSA, FEMA. 

[End of table] 

GSA issued regulations on telework in 2005.[Footnote 24] These 
regulations included references to existing statutory provisions on 
telecommuting and OPM's 2001 guidance regarding telework and telework 
centers. In these regulations, GSA also described the statutory 
obligation of agencies to consider whether the need for space could be 
met by alternative workplace arrangements[Footnote 25] and offered to 
assist agencies with alternative workplace arrangements. In 2006, GSA 
issued an FMR Bulletin that provided significantly expanded guidance 
to agencies on using alternative workplace arrangements. In addition 
to what had been stated in the regulation, the bulletin provided 
detailed information on implementing alternative work arrangements, 
such as teleworking and telework centers. The bulletin addressed such 
topics as the agency's provision of equipment, payment of telework-
related expenses, and factors to consider in using alternative 
workplace arrangements, often with citations to related federal 
regulations or other guidance. GSA issued another FMR bulletin the 
following year that provided agencies with recommendations on the type 
of information technology (IT), telecommunications, and peripheral 
services and equipment,[Footnote 26] as well as security, needed to 
adequately support telework. Like its predecessor, the bulletin also 
provided citations to related federal regulations or guidance issued 
by other federal agencies. 

FEMA and FPS provide governmentwide guidance to federal agencies on 
responding to emergencies. FEMA is responsible for leading the nation 
in developing a national preparedness system, including serving as the 
executive branch's lead agent on matters concerning the continuity of 
national operations.[Footnote 27] To help federal agencies develop 
continuity plans and programs, FEMA offers direction in the FCD 1. 
According to this directive, each federal agency has continuity 
responsibilities and certain agencies have leadership responsibility 
for providing governmentwide guidance or services. For instance, all 
federal agencies are responsible for, among other things, developing 
plans to ensure the continuation of their essential functions and 
incorporating continuity requirements into their daily operations. 
Among other continuity guidance FEMA has issued, FEMA has also 
provided agencies with a COOP plan template to help them develop their 
plans. Both FEMA documents, listed in table 5, include guidance 
relating to the potential use of telework. 

FPS is authorized to protect the buildings, grounds, and property that 
are under the control and custody of GSA, as well as the persons on 
the property.[Footnote 28] Towards that end, FPS provided agencies 
with a guide, template, and instructions on developing an OEP and 
guidelines on responding to various emergency situations. The OEP 
guide refers to the potential use of telework during emergencies. A 
GSA official indicated that those federal agencies that have delegated 
authority to own and operate their own, non-GSA facilities, are 
required to have their own version of the OEP. He said that most of 
these agencies follow FPS's guidance in developing their OEPs. 

Table 5: Sources of FEMA and FPS Guidance Related to Use of Telework 
during Emergencies: 

Department of Homeland Security (DHS) agency: FEMA; 
Policy area: Continuity planning; 
Guidance documents: 
* Federal Executive Branch National Continuity Program and 
Requirements, FCD 1 (Washington, D.C.: February 2008); 
* Continuity of Operations Plan Template and Instructions (Washington, 
D.C.: February 2011). 

Department of Homeland Security (DHS) agency: FPS; 
Policy area: Emergency planning; 
Guidance documents: 
* Occupant Emergency Plans: Development, Implementation and 
Maintenance (Washington, D.C.: May 2010); 
* Occupant Emergency Plans, Supplement 1: Emergency Situations 
(Washington, D.C.: May 2010); 
* Occupant Emergency Plans, Supplement 2: Template Instructions 
(Washington, D.C.: May 2010); 
* Occupant Emergency Plans, Supplement 3: OEP Template (Washington, 
D.C.: May 2010). 

Source: FEMA, FPS. 

[End of table] 

As with some of the OPM and GSA guidance documents, the current 
version of FEMA's guidance on continuity planning, FCD 1, issued in 
2008, has expanded since the original version was issued in 
2004.[Footnote 29] For example, in the 2008 version of FCD 1, the 
description of GSA's responsibilities included such additional duties 
as coordinating the provision of executive-branch facilities to 
support continuity operations. Similarly, the description of OPM's 
additional responsibilities include providing guidance to agencies on 
developing personnel policies that address continuity plans and 
procedures, as well as alternate work options, and coordinating 
continuity efforts before, during, and after an emergency with the 
Federal Executive Boards (FEB).[Footnote 30] In addition, FEMA 
broadened the scope of the guidance to include such topics as using 
risk management to maximize an agency's readiness, and aligning 
acquisition and budgeting to support the continuity program. 

Agencies May Need Assistance with Incorporating Telework into 
Emergency or Continuity Operations: 

Recent Reports Point Out Potential Problems with Incorporating 
Telework into Emergency or Continuity Operations in Various 
Operational Areas: 

Several recent reports from OPM, inspectors general, and GAO have 
identified several examples of potential problems with incorporating 
telework into emergency or routine operations at various agencies. 
These examples identified problems in such operational areas as 
planning, IT, personnel readiness, and program monitoring. For 
instance, in 2010 OPM evaluated the telework policies of 72 executive- 
branch departments and agencies to determine whether the policies 
provided a foundation for effective telework programs.[Footnote 31] 
Each policy was evaluated against two objectives: (1) whether the 
policy could be clearly understood and easily used and (2) whether the 
policy included elements essential to the development and support of 
an effective program, with respect to program implementation, 
participant responsibilities, and program operations. For each 
evaluation objective, OPM developed a checklist of items that OPM 
evaluators used to assess the agencies' telework policies. One of the 
policy checklist questions asked the evaluators to assess whether the 
telework policy "references agency emergency policies (e.g., COOP and 
pandemic)." According to the report, OPM evaluators scored 25 of the 
73 agency telework policies (35 percent) as not referencing the 
agencies' emergency policies at all. 

Other recent reports indicated potential problems in such operational 
areas as IT, personnel, and program monitoring: 

* Information Technology: 

- In 2010, we reported that federal wireless networks were 
increasingly vulnerable to attack and that information on the networks 
was vulnerable to unauthorized use and disclosure.[Footnote 32] 

- In 2009, on the basis of our review of a 2007 Department of Homeland 
Security (DHS) report, we concluded that, in the event of a protracted 
emergency where 40 percent or more of the population was absent from 
school or work, residential users in most locations in the United 
States, including federal teleworkers, would likely experience 
congestion when attempting to use the Internet.[Footnote 33] 

* Personnel Readiness: 

- While OPM's Telework Guide indicates that the potential to use 
telework during an emergency depends on agencies implementing routine 
telework as broadly as possible, OPM's latest telework survey, as 
noted earlier, reported that less than 6 percent of federal employees 
employed by the 79 agencies responding to the 2009 survey teleworked 
at least 1 day per month. 

- In 2010, the Inspector General for the U.S. Nuclear Regulatory 
Commission (NRC) reported that, as of October 2009, most of NRC's 
offices had not identified all of the individuals needed to perform 
essential functions and high-priority tasks while teleworking during a 
pandemic.[Footnote 34] 

* Program Monitoring: 

- According to an OPM official, few agencies in the Washington, D.C., 
area during the winter of 2011 were able to provide data on employees' 
use of telework during an emergency. In issuing its Dismissal 
Procedures in December 2010, OPM requested that agencies in this area 
provide data on the use of telework following any OPM-announced 
dismissal or closure. However, by March 2011, OPM withdrew its request 
because, according to an OPM official, few agencies in the area 
provided the requested data. 

Current Governmentwide Guidance Does Not Provide a Definition or Set 
of Practices for Incorporating Telework into Continuity and Emergency 
Planning: 

Our review of the OPM, GSA, FEMA, and FPS governmentwide guidance on 
telework and telework-related emergency planning found that none of 
the documents provided a definition of what constitutes incorporating 
telework into continuity and emergency planning or operations, or a 
cohesive set of practices that agencies could use to achieve this type 
of incorporation. Such practices would address the wide range of 
factors that could affect the potential use of telework during 
emergency operations such as planning, training, IT infrastructure 
(equipment, software, and security), testing, facilities, data 
collection, and program monitoring. 

OPM's Annual Telework Survey Does Not Define "Integration" of Telework 
into Emergency Plans: 

OPM, in partnership with GSA, has conducted an annual survey of the 
executive-branch agencies since 2001 to ascertain the status of 
telework and gauge agency progress in various aspects of their 
telework programs, such as participation, policy, eligibility, cost 
savings, and technology. Since 2002, OPM has used the survey results 
to prepare its annual report to Congress on the status of telework in 
the federal government. 

Since 2004, the survey has asked agency telework coordinators about 
whether telework had been integrated or incorporated[Footnote 35] into 
the agency's emergency or continuity plans, or both. In the latest 
survey, the 2009 Telework Survey, the question was worded as follows: 
"Telework has been integrated into your agency emergency preparedness/ 
COOP plans." The survey asks the coordinators to respond with either 
Yes or No. A review of the responses to this question, for calendar 
years 2004 through 2009, shows that the number of agencies reporting 
they had integrated telework into their emergency preparedness or 
continuity plans increased from 27 of 78 agencies responding for 
calendar year 2005 (or 35 percent), to 57 of 79 agencies responding 
for calendar year 2009 (or 72 percent). OPM reported that the 2009 
Telework survey results were an example of an encouraging use of 
telework implementation practices.[Footnote 36] 

However, OPM's survey instrument does not describe what OPM means by 
"integrating" telework into emergency or continuity planning and 
operations. The survey does not provide a definition or citation to 
another document. This is also the case for the 2004 through 2008 
surveys. One reference the telework coordinators might have turned to 
was OPM's 2006 Telework Guide, the version in use at the time of the 
2007 through 2009 surveys. However, the 2006 guide did not provide a 
definition or describe a set of practices required to integrate 
telework into emergency or continuity planning and operations, or 
refer to other federal guidance containing such a definition or set of 
practices. 

This lack of a definition or description calls into question the 
reliability of the survey results for assessing agencies' progress. As 
GAO has previously indicated, survey questions should use unambiguous 
language and concrete terms, and specify the conditions that the 
respondents are to report on.[Footnote 37] Without a common 
understanding of what OPM means by "integration," the agency telework 
coordinators who responded to the survey would have applied their own 
understanding of what integration means. As a result, OPM officials 
could not describe what agencies meant when they reported they had 
integrated telework into agency emergency preparedness/COOP plans. The 
question is also vague in that it does not define what it means by 
emergency preparedness plans and seems to treat emergency preparedness 
plans the same as continuity plans. As noted earlier, agencies may 
have several different types of emergency preparedness plans. The 
question does not explain whether the agency is to reply "Yes," if 
telework has been "integrated" into just one emergency preparedness 
plan, or only if telework has been "integrated" into all of the 
emergency preparedness plans, as well as the COOP plan. Lastly, the 
response choice of Yes or No does not permit the coordinator to report 
interim progress, as would be possible if the response choices 
reflected various stages of integration. 

Taken Together, Practices Suggested by Four Agencies Could Help to 
Define the Set of Practices Needed to Incorporate Telework in 
Continuity and Emergency Plans: 

The Telework Enhancement Act of 2010 now requires that federal 
agencies incorporate telework into their COOP plans. However, the act 
itself does not define the standards for adequate incorporation. 
Nevertheless, we found that three lead telework agencies and FPS have 
provided some governmentwide guidance that could help agencies in 
their efforts to incorporate telework into their continuity and 
emergency plans and operations. 

In reviewing several current OPM, GSA, FEMA, and FPS guidance 
documents, we found a number of practices that could help agencies 
incorporate telework into aspects of their continuity or emergency 
planning. Appendix II provides a listing of practices that OPM, GSA, 
FEMA, and FPS have suggested in various telework or emergency-related 
guidance documents. These practices address a variety of operational 
areas, such as human capital, training, facilities, testing, and 
technology infrastructure. However, it would be difficult for an 
agency to use these practices to help achieve telework incorporation 
and assess their progress. First, the practices are included in 
guidance documents that are principally concerned with matters other 
than incorporating telework into emergency plans. For example, as 
noted earlier, OPM's Dismissal Guide describes the announcements and 
procedures that federal executive agencies in the Washington, D.C., 
area are to follow when there are work disruptions in the region, but 
also reminds the agencies that they have a responsibility to ensure 
that their equipment and technical support have been tested, and their 
IT infrastructure can support a large number of teleworkers 
simultaneously. However, the guide does not provide a cross-reference 
to additional OPM or GSA guidance that would help agencies use IT 
equipment and services to support telework, or suggest consultation 
with the agencies' chief information officers (CIO). Moreover, 
according to their 2003 MOU, OPM and GSA agreed to work together to 
help agencies use IT to support telework and facilitate the CIOs 
involvement in related planning. Second, these practices are scattered 
across a wide range of documents, so it is difficult to be certain 
that agencies would consider all operational areas required to fully 
incorporate telework into emergency or continuity planning. For 
example, as illustrated in appendix II, OPM guidance dealing with a 
range of human-capital topics, such as pay and leave and human-
resource flexibilities, also includes practices that could help 
agencies incorporate telework into their continuity and emergency 
planning. But without lead agency collaboration and consensus on a 
comprehensive set of practices on incorporating telework into 
emergency and continuity planning, agencies and OPM cannot be sure 
that each agency has considered all of the relevant areas of its 
operations that may need to be adapted to support teleworkers during 
an emergency. 

It is also not unusual for a lead agency to draw practices, in whole 
or in part, from other lead agencies' guidance. While this helps the 
reader become aware of the potential crosscutting implications of the 
guidance, the description of these practices often does not provide a 
reference to more-specific guidance available from the other lead 
agency, which would also be helpful. For example, FEMA's FCD 1 
suggests repeatedly that agencies consider using telework to support 
continuity operations, but does not reference OPM or GSA telework 
guidance. 

OPM and FEMA Coordinated Recently Issued Guidance with Some 
Stakeholders, but OPM Did Not Tap into the CIO Community: 

OPM and FEMA's Recent Telework-Emergency Guidance Was Coordinated with 
Some Stakeholders: 

OPM and FEMA have both recently released updated guidance pertaining 
to telework and emergency planning, and both agencies reached out to 
some of their stakeholder communities. Following the extended closings 
of federal agencies in the Washington, D.C., area during the February 
2010 snowstorms, OPM updated the Dismissal Guide to introduce 
"unscheduled telework," a new option for federal employees to 
telework, to the extent possible, when severe weather conditions or 
other circumstances disrupt commuting. OPM officials believe this 
option will help maintain the productivity and resilience of the 
federal workforce during periods of heavy snow accumulation, national 
security events, and other regional emergencies and help ensure the 
safety of employees. This new option had effects in areas of policy 
and guidance, such as pay and leave, agency IT capacity, telework data 
collection, and emergency operations. Although only applicable to 
executive-branch agencies in the Washington, D.C., area, OPM officials 
indicated that the guide also serves as a reference and model for 
closures and dismissals due to snow and other emergencies in other 
regions. The guide notes that FEBs coordinate similar dismissal or 
closure procedures in other major metropolitan areas. 

Officials from OPM's Pay and Leave Office led the development of the 
2010 Dismissal Guide. The OPM officials' goal was to coordinate among 
stakeholders and issue the guide before the arrival of winter storms. 
According to these officials, they developed potential revisions and 
began the process of coordination among many stakeholders on October 
28, 2010, by briefing the deputy Chief Human Capital Officers (CHCO) 
on the new concepts and asking for their reactions. 

During November 2010, OPM officials continued to share concepts and 
drafts, receive comments, and incorporate revisions to the draft 
guide. During this period, they sought additional reviews of the draft 
guide from agency human-capital officials. The Executive Director of 
the CHCO Council distributed the draft for agency comment to the 
deputy CHCOs, requesting that they share the draft with the points of 
contacts within their agencies. In addition, OPM officials said they 
consulted with unions, the Metropolitan Washington Council of 
Governments, and the FEMA Office of National Capital Region 
Coordination, among others. 

In December 2010, the OPM officials completed their stakeholder 
reviews and OPM completed its internal clearance process to issue the 
guide. They presented the new Guide to the CHCO Council members and 
the White House staff on December 14 and held a media briefing on the 
new guide when it was issued on December 15. On the same day, OPM 
officials reported they also briefed the FEBs on the new guide. 

FEMA also provided updated guidance in 2010 to agencies on developing 
their continuity plans. In 2004 FEMA issued a template to help 
agencies develop continuity plans. The template provided general 
guidance, sample text, and a template containing all the elements of a 
viable continuity plan. This enabled agencies to insert information 
from the template into their continuity plans as they deemed 
appropriate. FEMA began developing its latest version of the template 
in 2009. By May 2009, FEMA National Continuity Programs (NCP) 
officials had developed the updated template sufficiently to share an 
initial version of it with departments and agencies to prepare for the 
2009 continuity exercise called Eagle Horizon.[Footnote 38] 

FEMA NCP officials continued to update the template during 2010. 
According to NCP officials, the template was discussed during 
Interagency Continuity Working Group meetings and Continuity Advisory 
Group meetings.[Footnote 39] In September and October 2010, NCP 
officials e-mailed more than 100 members of the interagency community, 
including both continuity coordinators and continuity planners, 
requesting comments on the updated template draft. In addition, NCP 
officials provided the GSA Office of Emergency Response and Recovery, 
which has responsibility for policy guidance on alternate continuity 
facilities,[Footnote 40] the opportunity to review and comment on the 
template. 

FEMA finalized the continuity template in February 2011 and posted it 
on its website. The template provided agencies with more-detailed 
guidance for each section of the plan, including proposed language, 
citations for supporting authorities and a glossary of terms. This 
template included guidance on the use of alternative facilities, 
including telework. 

OPM and GSA Coordinated on the Dismissal Guide, but Did Not Involve 
the CIO Community: 

Although OPM officials shared drafts of the Dismissal Guide with other 
federal agencies, including GSA, the coordination between OPM and GSA 
did not involve working together to involve the agencies' CIO 
community.[Footnote 41] As noted earlier, to address coordination 
issues between OPM and GSA, in 2003, the two agencies committed to an 
MOU. Under the MOU, GSA agreed to develop innovative workplace policy 
and guidance and to seek resolution to issues regarding IT support for 
telework where concerns about home IT equipment continue to be a 
barrier to the successful implementation of telework programs. OPM is 
to work with GSA to reach appropriate groups of CIOs to facilitate 
their greater involvement in agency long-term planning. 

The Dismissal Guide noted that the new option of "unscheduled 
telework" could occasion large numbers of employees teleworking 
simultaneously. Consequently, the Dismissal Guide advised agencies 
that they should ensure that their IT infrastructure was in place to 
support this. IT infrastructure includes equipment, software, and 
security. 

However, in 2009, we reported that 12 agencies, including GSA, as 
indicated in table 6, had done some, little, or no testing of the 
ability of their IT infrastructure to handle telework or similar 
arrangements during a protracted emergency, such as a pandemic 
influenza.[Footnote 42] 

Table 6: Agencies' Responses on the Extent to Which They Have Tested 
IT Infrastructure to Ensure That It Is Capable of Handling Telework or 
Work-at-Home Arrangements during a Pandemic Influenza Outbreak: 

Extent: To a great extent; 
Agencies: National Science Foundation. 

Extent: To a moderate extent; 
Agencies: Department of Commerce, Department of Energy, Department of 
the Interior, Department of Labor, Department of State, Department of 
Transportation, Department of Education, Environmental Protection 
Agency, OPM, NRC, Social Security Administration. 

Extent: To some extent; 
Agencies: Department of Justice, Department of Health and Human 
Services, Department of Housing and Urban Development, Department of 
Defense, Department of the Treasury, U.S. Agency for International 
Development, Department of Veterans Affairs. 

Extent: To little or no extent; 
Agencies: DHS, GSA, National Aeronautics and Space Administration, 
Small Business Administration, Department of Agriculture. 

Source: GAO. 

Note: Data are from GAO-09-404. 

[End of table] 

Without adequate testing of IT infrastructure, agencies would not know 
whether they could rely on unscheduled telework to sustain operations 
during emergencies. Some agencies may have limited IT capacity to 
support large numbers of employees attempting to telework 
simultaneously, and might have to take steps to distribute system load 
until the agency capacity is increased. For example, the Department of 
Energy's (DOE) Inspector General reported in 2010 that DOE's COOP plan 
estimates peak employee absenteeism during a pandemic event could be 
as high as 40 percent, or approximately 3,000 employees at DOE 
headquarters; however, DOE's remote access server can only accommodate 
800 concurrent users.[Footnote 43] GSA's last assessment of the 
telework technology environment and the technologies required to 
support 25 to 50 percent of the federal workforce teleworking was 
conducted in 2006. At that time, GSA concluded, "In general most 
organizations do not provide their teleworkers the same level of 
access to agency applications, data, and technical support as their 
office workers, which can hinder a teleworker's ability to perform all 
job duties from their telework site."[Footnote 44] 

Despite the importance of agency IT capacity to support telework 
during emergencies, OPM and GSA did not work together, as outlined in 
their MOU, to reach out to the CIO community regarding potential 
agency capacity limitations. At the time of development of the new 
policy, each of the OPM and GSA officials responsible for coordinating 
on the MOU did not recognize the opportunity to involve the CIO 
community. The OPM official thought the agency telework coordinators 
and CHCOs were aware of the IT capacity issue and would consider this 
in implementing their telework programs. The GSA official thought the 
policy was targeted to the human-resources community and the 
technology issue would be more effectively dealt with in a document 
directed to the IT community. Consequently, GSA officials did not 
offer any governmentwide guidance on ways to address infrastructure 
limitations or provide direct assistance to agencies regarding the 
adequacy of their IT infrastructure. The senior OPM official 
responsible for telework programs acknowledged that consulting with 
the CIO Council prior to issuing the Dismissal Guide would have been 
worthwhile. Going forward, coordination will become even more 
important because the Telework Enhancement Act of 2010 requires OPM to 
consult with GSA on policy and policy guidance for telework in the 
areas of telework technology and equipment. 

Conclusions: 

The Telework Enhancement Act of 2010 requires agencies to incorporate 
telework into their COOP plans. However, there is no governmentwide 
definition or cohesive set of practices for incorporating telework 
into COOP plans. Recent reports offered several examples of challenges 
agencies may face in supporting the use of telework during emergencies 
in such key areas as planning, IT, and personnel readiness. The 
absence of a definition of what constitutes incorporation of telework 
into emergency and continuity plans did not create these potential 
problems in readiness. However, a definition accompanied by a set of 
practices that acknowledged the broad range of operational areas 
affected by incorporating telework into emergency preparedness might 
help agencies identify, avoid, or address any operational problems. 
Such practices would help agencies take the appropriate steps, measure 
their progress, and know when they have achieved success. Some 
practices already in OPM, GSA, FEMA, and FPS guidance documents could 
provide a starting point. 

The lack of a definition for incorporating telework into emergency and 
continuity planning has also affected the reliability of recent OPM 
telework survey results and assessment of agency progress. Since 2004, 
OPM has used its annual survey of agency telework coordinators to 
report on the status of agencies' telework program and policies, 
including agencies' incorporation of telework into emergency plans. 
However, problems with OPM's telework survey methodology, such as a 
lack of a definition for incorporation or integration into continuity 
and emergency planning, and vagueness in question construction, call 
into question the reliability of reported results with respect to this 
issue. Without reliable data, OPM is unable to assess the extent to 
which the federal government as a whole, or an individual agency, is 
making progress on incorporating teleworking into emergency planning 
and operations. 

Over the years, governmentwide telework and emergency-related guidance 
from OPM, GSA, FEMA, and FPS has broadened in scope to include 
references to the potential use of telework during emergencies. In 
addition, these guidance documents suggest practices drawn from other 
lead agencies' guidance. While these guidance features can heighten 
agency officials' awareness of the crosscutting considerations bearing 
on the potential use of telework during emergencies, without lead- 
agency collaboration and consensus on the crosscutting passages in the 
guidance, coordination with a key policy area may be missed. In a 
recent instance, while OPM coordinated with other agencies on its new 
Dismissal Guide, the guide did not address important areas of agency 
IT operations--despite the existence of an MOU between OPM and GSA 
intended to improve interagency coordination specifically on this 
issue. In developing future telework policy and policy guidance 
relating to emergency and continuity planning and operations, OPM will 
need to consult with agencies responsible for key policy areas, now 
including NARA, to ensure all key policy areas are fully considered. 

Recommendations for Executive Action: 

To enhance the potential use of telework during emergencies, we 
recommend that 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, take the following three actions: 

* 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. 

* 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. 

* Establish an interagency coordination process among OPM, FEMA, FPS, 
GSA, and NARA to ensure all major areas of agency operations are 
considered when OPM issues new or updated guidance related to using 
telework during emergencies. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Secretary of Homeland 
Security, the Administrator of GSA, and the Director of OPM for review 
and comment. The Director of OPM and the Director of the Departmental 
GAO/OIG Liaison Office for DHS provided written comments, which we 
have reprinted in appendixes III and IV. In summary, OPM concurred 
with our recommendations and highlighted a number of actions the 
agency has under way or plans to undertake in response. OPM and DHS 
also provided technical comments, which we incorporated as 
appropriate. GSA had no comments on the draft. 

We are sending copies of this report to the congressional committees 
with jurisdiction over DHS and GSA, and their activities; the 
Secretary of Homeland Security; the Administrator of GSA; and the 
Director of Office of Management and Budget. In addition, the report 
will be available at no charge on the GAO website at [hyperlink, 
http://www.gao.gov]. 

If you have any questions about this report, please contact me at 
(202) 512-6543 or steinhardtb@gao.gov. Key contributors to this report 
are listed in appendix V. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. 

Signed by: 

Bernice Steinhardt: 
Director, Strategic Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This report (1) describes the guidance that the Office of Personnel 
Management (OPM), General Services Administration (GSA), Federal 
Emergency Management Agency (FEMA), and Federal Protective Service 
(FPS) have issued pertaining to the use of telework during 
emergencies; (2) assesses the extent to which OPM's recent reviews of 
the agencies' telework policies and programs address the incorporation 
of telework into continuity plans, and the extent to which OPM, FEMA, 
GSA, and FPS offer guidance on incorporating telework into emergency 
and continuity planning; and (3) assesses the extent to which OPM and 
FEMA coordinated with other agencies on the development of their 
recently released guidance documents pertaining to the use of telework 
during emergencies. 

To address these three objectives, we reviewed governmentwide telework 
and emergency-related statutes. We also reviewed regulations issued by 
OPM and GSA, and related governmentwide guidance that OPM, GSA, FEMA, 
and FPS had issued over the past 10 years. Lastly, we conducted 
interviews with key officials from each of these agencies regarding 
each objective. We conducted additional data collection and analyses 
to answer selected objectives, as described below. 

To assess the extent to which OPM's recent reviews of the agencies' 
telework policies and programs addressed the incorporation of telework 
into continuity plans, we reviewed OPM's annual telework survey and 
its 2010 evaluation of agency telework policies. We compared the 
survey question relating to whether telework had been integrated into 
the agency's emergency preparedness/continuity of operations (COOP) 
plans to generally accepted survey methodology. We also reviewed the 
survey results for this question from the first year it was included 
in the survey, in 2004, through the most recent survey, conducted in 
2009. We also compared OPM's description of the methodology it used to 
evaluate agency telework policies to GAO guidelines for developing and 
using checklists. We also reviewed the cumulative scores that OPM 
evaluators assigned to the checklist item--whether the telework policy 
"references agency emergency policies (e.g., COOP and pandemic)." In 
addition to reviewing OPM's recent telework assessments, we reviewed 
recent GAO and inspector general reports to identify examples of 
problems agencies might be having with potentially using telework 
during emergencies. 

To identify practices suggested by OPM, GSA, FEMA, and FPS for 
incorporating telework into continuity or emergency planning, we 
reviewed these agencies' related governmentwide regulations and 
guidance, and identified suggested practices for incorporating 
telework into continuity or emergency planning. We compared these 
practices to practices that GAO previously suggested for the same 
purpose and identified examples of OPM, GSA, FEMA, and FPS suggested 
practices that were similar to GAO-suggested practices. 

We conducted this performance audit from February 2010 through July 
2011 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Examples of Practices Suggested to Federal Agencies for 
Incorporating Telework into Emergency and Continuity Planning and 
Operations: 

In reviewing several current guidance documents, we found that the 
Office of Personnel Management (OPM), General Services Administration 
(GSA), Federal Emergency Management Agency (FEMA), and Federal 
Protective Service (FPS) have suggested to federal agencies, in 
various telework or emergency-related guidance documents, several 
practices for incorporating telework into various aspects of 
continuity or emergency planning. 

Table 7: Examples of Practices That OPM, GSA, FEMA, or FPS Have 
Suggested to Federal Agencies for Incorporating Telework into 
Emergency or Continuity Planning: 

Agency suggesting practice: OPM; 
Practice related to incorporating telework into emergency or 
continuity planning: 
* Agencies should ensure that the equipment, technology, and technical 
support have been tested; 
* Agencies should ensure that the IT infrastructure is in place to 
allow large numbers of employees to telework simultaneously; 
* At least annually, agencies should identify emergency employees 
(including COOP employees) and notify them in writing, including the 
requirement that emergency employees report for work or remain at work 
(or work at home or report to an alternative work site) when 
government operations are disrupted; 
Guidance document describing suggested practice[A]: OPM, Washington, 
DC Area Dismissal or Closure Procedures (Washington, D.C.: December 
2010). 

Agency suggesting practice: OPM; 
Practice related to incorporating telework into emergency or 
continuity planning: 
* All teleworkers and telework managers should receive telework and 
information-security training; 
* All teleworkers should have signed agreements, even for emergency 
telework arrangements; 
Guidance document describing suggested practice[A]: OPM, Planning for 
Pandemic Influenza (Washington, D.C.: May 2009). 

Agency suggesting practice: OPM; 
Practice related to incorporating telework into emergency or 
continuity planning: Employees' telework agreements should state what 
the agency's expectation of employees is regarding teleworking during 
a disruption or emergency; 
Guidance document describing suggested practice[A]: OPM, Guide to 
Telework in the Federal Government (Washington, D.C.: September 2008). 

Agency suggesting practice: OPM; 
Practice related to incorporating telework into emergency or 
continuity planning: Agencies should maximize their telework capacity 
by, among other things, conducting exercises to test employees' 
ability to access agency networks from home; 
Guidance document describing suggested practice[A]: OPM, Human 
Resources Flexibilities Available to Assist Federal Employees During 
Emergencies (Washington, D.C.: May 5, 2009). 

Agency suggesting practice: OPM; 
Practice related to incorporating telework into emergency or 
continuity planning: 
* Agencies utilize human-capital flexibilities, including telework, to 
help the agency continue essential functions during an emergency; 
* Agency develops a process to communicate its human-capital guidance 
for emergencies (e.g. pay, leave, benefits) to managers; 
Guidance document describing suggested practice[A]: FEMA, Annex J, 
"Human Capital," Federal Executive Branch National Continuity Program 
and Requirements, Federal Continuity Directive 1 (FCD 1), (Washington, 
D.C.: August 2008). 

Agency suggesting practice: OPM; 
Practice related to incorporating telework into emergency or 
continuity planning: An agency may order one or more employees to 
evacuate from their work site and perform work from their homes (or an 
alternative location mutually agreeable to the agency and the 
employee) during a pandemic health crisis without regard to whether 
the agency and the employee have a telework agreement in place at the 
time the order to evacuate is issued; 
Guidance document describing suggested practice[A]: Federal regulation 
5 C.F.R Part 550, Subpart D, Payments During Evacuation. 

Agency suggesting practice: OPM; 
Practice related to incorporating telework into emergency or 
continuity planning: In emergency situations, agencies may designate 
the location of the employee's reporting office prior to the emergency 
as the official work site for location-based pay entitlements, such as 
locality pay and special rates; 
Guidance document describing suggested practice[A]: OPM, Handbook on 
Pay and Leave Benefits for Federal Employees Affected by Severe 
Weather Conditions or Other Emergency Situations (Washington, D.C. 
June 2008). 

Agency suggesting practice: GSA; 
Practice related to incorporating telework into emergency or 
continuity planning: Agencies may provide or purchase technical 
equipment and services to support teleworkers; 
Guidance document describing suggested practice[A]: Federal Management 
Regulation: Guidelines for Alternative Workplace Arrangements, Federal 
Management Regulation (FMR) Bulletin 2006-B3, (Mar. 17, 2006). 

Agency suggesting practice: GSA; 
Practice related to incorporating telework into emergency or 
continuity planning: Teleworkers should receive adequate training on 
the use of IT systems and applications needed for effective job 
performance; 
Agencies should provide adequate access to IT systems by means of 
broadband, direct dial, or virtual private network technology; 
Guidance document describing suggested practice[A]: Information 
Technology and Telecommunications Guidelines for Federal Telework and 
Other Alternative Workplace Arrangement Programs, FMR Bulletin 2007-
B1, (Mar. 2, 2007). 

Agency suggesting practice: GSA; 
Practice related to incorporating telework into emergency or 
continuity planning: In addition to alternate facilities, implement 
other nontraditional continuity facility options or virtual offices, 
including work at home/telework; 
Guidance document describing suggested practice[A]: FEMA, Annex G, 
"Continuity Facilities," Federal Executive Branch National Continuity 
Program and Requirements, FCD 1, (Washington, D.C.: February 2008). 

Agency suggesting practice: FEMA; 
Practice related to incorporating telework into emergency or 
continuity planning: 
* Agencies identify and provide for communication capabilities at 
other continuity sites, including telework sites, and provide both 
essential and nonessential staff with related training; 
* Agencies should conduct an annual exercise that incorporates the 
deliberate and preplanned movement of continuity personnel to an 
alternative facility or location; 
* Agencies should demonstrate the capability to perform their 
essential functions within 12 hours after an event and under all 
threat conditions, from their alternate facilities, to include virtual 
office options including telework; 
* Agencies should annually test their capabilities for protecting 
classified and unclassified vital records, and for providing access to 
them from the alternate facility, as reflected in agency testing 
records; 
Guidance document describing suggested practice[A]: FEMA, Federal 
Executive Branch National Continuity Program and Requirements, FCD 1, 
(Washington, D.C.: February 2008). 

Agency suggesting practice: FEMA; 
Practice related to incorporating telework into emergency or 
continuity planning: 
* Have a telework agreement for continuity personnel, if applicable; 
* All organizations must identify and maintain at least one alternate 
facility, which could include alternate uses of existing facilities to 
help initiate and sustain agency operations; 
* Conduct personnel briefings on continuity plans that involve using 
or relocating to continuity facilities (including teleworking) or 
other facilities; 
Guidance document describing suggested practice[A]: FEMA, Continuity 
of Operations Plan Template (Washington, D.C.: November 2010). 

Agency suggesting practice: FPS; 
Practice related to incorporating telework into emergency or 
continuity planning: 
* To facilitate postemergency recovery, consider encouraging 
teleworking to help when circumstances make the main work site 
difficult to access; 
* In developing the OEP, planners should refer to the agency's 
continuity and other plans, and not duplicate these other plans; 
Guidance document describing suggested practice[A]: FPS, Occupant 
Emergency Plans: Development, Implementation and Maintenance 
(Washington, D.C.: May 2010). 

Agency suggesting practice: FPS;
Practice related to incorporating telework into emergency or 
continuity planning: Agencies conduct training to ensure all tenants 
understand emergency procedures and their individual responsibilities; 
Guidance document describing suggested practice[A]: FPS, Occupant 
Emergency Plans, Supplement 3: OEP Template (Washington, D.C.: May 
2010). 

Agency suggesting practice: FPS;
Practice related to incorporating telework into emergency or 
continuity planning: During a pandemic, an office could implement 
flexible work site (telework) policies and flexible work hours 
(staggered shifts), if appropriate; 
Guidance document describing suggested practice[A]: FPS, Occupant 
Emergency Plans, Supplement 1: Emergency Situations (Washington, D.C.: 
May 2010). 

Source: GAO analysis of agency data. 

Notes: Descriptions of practices paraphrase more-detailed descriptions 
in the guidance document. 

[A] The source document was one of the agencies' guidance documents 
that included the listed practice. Other agency guidance documents may 
have also included the listed practice. 

[End of table] 

[End of section] 

Appendix III: Comments from the Office of Personnel Management: 

United States Office Of Personnel Management: 
The Director: 
Washington, DC 20415: 

June 30, 2011: 

Ms. Bernice Steinhardt: 
Director, Strategic Issues: 
U.S. General Accountability Office: 
441 G St, NW: 
Washington DC 20548: 

Dear Ms. Steinhardt: 

Thank you for providing the U.S. Office of Personnel Management (OPM) 
the opportunity to comment on the Government Accountability Office 
draft report. "Emergency Preparedness: Agencies Need Coordinated 
Guidance on Incorporating Telework into Emergency and Continuity 
Planning." We appreciate the opportunity to provide you with comments 
about this report. 

Response to Recommendation: 

Recommendation: To enhance the potential use of telework during 
emergencies we recommend that the Director of OPM, in consultation 
with agencies responsible for key policy areas specified under the 
Telework Act. and other agencies providing governmentwide guidance on 
emergency preparedness, such as FPS, take the following actions: 

* 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. 

* Revise its 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. 

* Establish an interagency coordination process among OPM, FEMA, FPS, 
GSA, and NARA to ensure all major areas of agency operations are 
considered when OPM issues new or updated guidance related to using 
telework during emergencies. 

We will address each recommended action separately. 

Management Response: 

* 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. 

We concur. As we have previously observed, the Telework Enhancement 
Act of 2010 does not confer regulatory or interpretive authority on 
OPM with regard to telework. Nonetheless, OPM has touched upon the 
topic of incorporating telework into emergency planning in guidance
documents, including OPM's Washington, DC, Area Dismissal and Closure 
Procedure guidance. In order to facilitate agency telework planning, 
OPM would be willing to develop a template for a program for 
incorporating telework into emergency and continuity of operations
planning in consultation with FEMA and the other lead agencies named 
in the Telework Enhancement Act, as appropriate. Such a template would 
provide agencies with a basic model that would set out essential steps 
to undertake to ensure that telework is fully incorporated into 
emergency and continuity planning. 

* Revise its 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. 

We concur. Since 2002 OPM has asked agencies to participate in a 
telework data call (Call). Several items in the Call queried whether 
agencies integrated telework into their emergency and continuity of 
operations plans. The items were of low content validity and resulting 
data are unlikely to exhibit reliability. Moreover, the Telework 
Enhancement Act of 2010 expanded OPM's overall research and reporting 
requirements with respect to telework. Consequently, OPM formed and 
implemented a telework measurement group to (1) advise upon the 
development of a general research protocol for telework and (2) 
address some of the recurring validity issues with items included in 
the Call more specifically. OPM has worked with the measurement group 
since January 2011 to ensure that agencies have the tools to meet 
major measurement and reporting requirements in the Act. 

Membership in the measurement group is both inter and intra-agency. 
OPM members include experts in statistics evaluation and survey 
research. The member from General Services Administration is an expert 
in survey method and subject matter, and subject matter and policy
experts are include from the Department of Energy. NASA, Department of 
Defense, Commerce's Patent and Trademark Office and the Defense 
Information Systems Agency. To date, the measurement group has engaged 
in major revision of survey definitions and items. A pilot of the 
instrument is scheduled and agencies will be trained in use of the 
final instrument. Emergency and continuity of operations plans are 
among those items subject to revision. A subject matter expert in 
emergency preparedness has reviewed the items included in the Call and
final comments will be used in the final revision of the instrument 
for the pilot. 

* Establish an interagency coordination process among OPM, FEMA, FPS, 
GSA, and NARA to ensure all major areas of agency operations are 
considered when OPM issues new or updated guidance related to using 
telework during emergencies.  

We concur. On February 17, 2011, OPM held a meeting with agency 
representatives from the Federal Emergency Management Agency (FEMA), 
General Services Administration (GSA), Executive Office of the 
President (EOP), National Archives and Records Administration (NARA) 
and the Office of Management and Budget (OMB) to discuss 
implementation of the Telework Enhancement Act of 2010. During that 
meeting, the group identified additional agencies that should be 
included in future discussions and meetings. While the group has not 
met since the initial meeting on February 17th, OPM will schedule a 
follow-up meeting with all identified appropriate agency 
representatives, including the Federal Protective Service, to ensure 
an interagency coordination process takes place when new or updated 
guidance related to telework during emergencies is proposed.  

Technical comments to the draft report are enclosed. Unless otherwise 
noted, the suggested revisions are meant to provide technical accuracy. 
 
Please contact Ms. Janet Barnes, Deputy Director, Internal Oversight & 
Compliance on (202) 606-3270, should your office require additional 
information.  

Again, my thanks to your office for providing this opportunity to 
update and clarify information in the draft report.  

Sincerely,  

Signed by: 

John Berry: 
Director:  

Enclosure: 

[End of section] 

Appendix IV: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20528: 

July 1, 2011: 

Bernice Steinhardt: 
Director, Strategic Issues: 
441 G Street, NW: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

Re: Draft Report GAO 11-628, "Emergency Preparedness: Agencies Need
Coordinated Guidance on Incorporating Telework into Emergency and 
Continuity Planning" 

Dear Ms. Steinhardt: 

Thank you for the opportunity to review and comment on this draft 
report. The U.S. Department of Homeland Security (DHS) appreciates the 
U.S. Government Accountability Office's work in planning and 
conducting its review and issuing this report. 

The Department is pleased to note the positive acknowledgment of the 
Federal Emergency Management Agency (FEMA) and the Federal Protective 
Service's (FPS) leadership role in providing governmentwide guidance 
on telework-related continuity and emergency planning. Although the 
report does not contain any recommendations specifically directed at 
DHS, the Department remains committed to continuing its work with 
interagency partners, such as the U.S. Office of Personnel Management 
(OPM), refining and enhancing guidance concerning the potential use of 
telework during emergency situations, as appropriate. For example, 
FEMA is currently working with OPM to update and expand Federal 
Continuity Directive 1, in part, as it relates to telework. 

Again, thank you for the opportunity to review and comment on this 
draft report. Technical comments were submitted under separate cover. 
We look forward to working with you on future Homeland Security 
engagements. 

Sincerely, 

Signed by: 

Jim H. Crumpacker: 
Director:
Departmental GAO/OIG Liaison Office: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Bernice Steinhardt, (202) 512-6543 or steinhardtb@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, William Doherty, Assistant 
Director, and Patricia Farrell Donahue, analyst-in-charge, led the 
development of this report. Sharon Hogan and Robert Gebhart made 
significant contributions to this report. Gregory Wilmoth and Tom 
Beall assisted with the design and methodology. Karin Fangman provided 
legal counsel. Robert Love, Len Benning, and James Sweetman provided 
technical assistance. William Trancucci verified the information in 
the report. 

[End of section] 

Related GAO Products: 

Federal Work/Life Programs: Agencies Generally Satisfied with OPM 
Assistance, but More Tracking and Information Sharing Needed. GAO-11-
137. Washington, D.C.: December 16, 2010. 

Human Capital: Telework Programs Need Clear Goals and Reliable Data. 
GAO-08-261T. Washington, D.C.: November 6, 2007. 

Human Capital: Greater Focus on Results in Telework Programs Needed. 
GAO-07-1002T. Washington, D.C.: June 12, 2007. 

Continuity of Operations: Agencies Could Improve Planning for Telework 
during Disruptions. GAO-06-740T. Washington, D.C.: May 11, 2006. 

Continuity of Operations: Selected Agencies Could Improve Planning for 
Use of Alternate Facilities and Telework during Disruptions. GAO-06-
713. Washington, D.C.: May 11, 2006. 

Agency Telework Methodologies: Departments of Commerce, Justice, 
State, the Small Business Administration, and the Securities and 
Exchange Commission. GAO-05-1055R. Washington, D.C.: September 27, 
2005. 

Human Capital: Key Practices to Increasing Federal Telework. GAO-04-
950T. Washington, D.C.: July 8, 2004. 

Facilities Location: Progress and Barriers in Selecting Rural Areas 
and Using Telework. GAO-03-1110T. Washington, D.C.: September 4, 2003. 

Human Capital: Further Guidance, Assistance, and Coordination Can 
Improve Federal Telework Efforts. GAO-03-679. Washington, D.C.: July 
18, 2003. 

[End of section] 

Footnotes: 

[1] For the purposes of dismissals and closures, OPM defines the 
Washington, D.C., area as the District of Columbia; Montgomery and 
Prince George's counties in Maryland; Arlington and Fairfax counties, 
and the independent cities of Alexandria, Fairfax, and Falls Church in 
Virginia. According to OPM, 302,000 federal employees worked in this 
area in December 2010. 

[2] Telework refers to a flexible workplace arrangement where 
employees perform their duties, responsibilities, and other authorized 
activities from approved worksites. The approved worksite is different 
than the location from which the employee would typically work. 

[3] Statement of John Berry, Director, U.S. Office of Personnel 
Management, before the Subcommittee on Economic Development, Public 
Buildings, and Emergency Management, Transportation and Infrastructure 
Committee, United States House of Representatives, Snow Disasters for 
Local, State and Federal Governments in the National Capital Region: 
Response and Recovery Partnerships with FEMA (Washington, D.C.: Mar. 
23, 2010). 

[4] GAO, Human Capital: Further Guidance, Assistance, and Coordination 
Can Improve Federal Telework Efforts, [hyperlink, 
http://www.gao.gov/products/GAO-03-679] (Washington, D.C.: July 18, 
2003). 

[5] COOP efforts are a comprehensive set of steps agencies must 
undertake to help ensure that they can continuously provide essential 
operations and resume full services to the American public in the face 
of long-term, severe emergencies requiring agencies to occupy 
alternate facilities. 

[6] Pub. L. No. 102-393, 106 Stat. 1729, 1745 (Oct. 6, 1992). A GSA- 
sponsored telework center was a facility that (1) provided, on a fee 
for use/service basis, workstations and other office facilities/ 
services used by federal employees from several agencies and was used 
as a geographically-convenient alternative worksite for its users. In 
November 2010, GSA announced that it planned to end its sponsorship 
and funding of its 14 telework centers by March 2011, due to the high 
cost of maintaining the centers relative to their low usage, and the 
increased, widespread use of residential telework. 

[7] Section 620 of Pub. L. No. 104-52, 109 Stat. 468, 501 (Nov. 19, 
1995); 31 U.S.C. 1348 note. 

[8] Section 359 of Pub. L. No. 106-346, 114 Stat. 1356, 1356A-36 (Oct. 
23, 2000); 5 U.S.C. § 6120 note. 

[9] [hyperlink, http://www.gao.gov/products/GAO-03-679], 30. 

[10] Memorandum of Understanding (MOU) Between the U.S. Office of 
Personnel Management (OPM) and the U.S. General Services 
Administration (GSA) Regarding the Government-wide Telework Program 
(October 2003). 

[11] Pub. L. No. 111-292, 124 Stat. 3165 (Dec. 9, 2010), codified at 
chapter 65 of title 5, United States Code. 

[12] The Chief Human Capital Officers Act of 2002, enacted as part of 
the Homeland Security Act of 2002, established a Chief Human Capital 
Officers Council to advise and coordinate the activities of member 
agencies on such matters as the modernization of human-resources 
systems, improved quality of human-resources information, and 
legislation affecting human-resources operations and organizations. 
Pub. L. No. 107-296, § 1303, 116 Stat. 2135, 2288-89 (Nov. 25, 2002), 
5 U.S.C. § 1401 note. 

[13] For the purposes of this report, we use "guidance" as a generic 
term to refer to regulations, directions, guides, bulletins, and other 
documents that these agencies have issued for use by federal agencies. 

[14] Section 359 of Pub. L. No. 106-346 (Oct. 23, 2000). 

[15] Office of Personnel Management, Guide to Telework in the Federal 
Government (Washington, D.C.: April 2011). This guide is referred to 
as "OPM's Telework Guide" in this report. 

[16] Federal Emergency Management Agency, Federal Executive Branch 
National Continuity Program and Requirements, FCD 1(Washington, D.C.: 
February 2008). 

[17] 5 C.F.R. part 550, subpart D, Payments During Evacuation. 

[18] Office of Personnel Management, Washington, DC Area Dismissal or 
Closure Procedures (Washington, D.C.: December 2010). 

[19] Federal Emergency Management Agency, "Human Capital," annex J, 
Federal Continuity Directive 1. 

[20] Until OPM issued an updated telework guide in April 2011, OPM's 
main telework guidance document was A Guide to Telework in the Federal 
Government (OPM-VI-I), which was issued in 2006, according to an OPM 
official. 

[21] 40 U.S.C. §587 (c)(3). GSA also has authority to establish 
telecommuting centers pursuant to 40 U.S.C. §587(b)(1). 

[22] 6 U.S.C. § 232; GSA regulations on occupant emergency programs 
are found at 41 C.F.R. §§ 102-74.230 to 102-74.260. 

[23] Shelter-in-place refers to a set of emergency procedures taken 
inside a building to protect occupants when an emergency situation 
makes it dangerous for occupants to evacuate. 

[24] 41 C.F.R. §§ 102-74.585-600. 

[25] 40 U.S.C. § 587(c)(2). 

[26] Peripheral services and equipment may include video conferencing, 
printers, and scanners. 

[27] 6 U.S.C. §§ 313-314. 

[28] FPS was part of GSA until it was transferred to the Department of 
Homeland Security (DHS) in 2003 pursuant to the Homeland Security Act 
of 2002. Under the act, except for the law enforcement and related 
security functions retained by FPS, GSA retained all powers, 
functions, and authorities related to the operation, maintenance, and 
protection of its buildings and grounds. As a result of the act, GSA 
and FPS both have protection responsibilities for GSA-controlled 
buildings and grounds. 6 U.S.C. §§ 203 and 232; 40 U.S.C. § 1315. 

[29] In 2004, guidance to executive-branch agencies on continuity 
planning and programming was contained in FEMA's Federal Preparedness 
Circular 65, Federal Executive Branch Continuity of Operations 
(Washington, D.C.: June 15, 2004). Federal Preparedness Circular 65 
was succeeded in 2008 by FEMA's Federal Continuity Directive 1 (FCD 1) 
(Washington, D.C.: February 2008). FCD 1 was intended to help 
implement the National Security Presidential Directive 51/Homeland 
Security Presidential Directive 20 (NSPD-51/HSPD-20) National 
Continuity Policy (Washington, D.C.: May 2007), by providing direction 
to the federal executive branch on the development of continuity plans 
and programs. 

[30] FEBs are located in 28 major U.S. metropolitan areas. Their 
mission is to foster communication, coordination, and collaboration 
with federal, state, and local government agencies. One of the FEBs' 
three lines of business is to create effective collaboration on 
emergency response and readiness, and to educate the federal workforce 
on health and safety issues in emergency situations. 

[31] Office of Personnel Management, An Evaluation of Federal Telework 
Policies: Summary Report, Discussion Draft (Washington, D.C.: June 
2010). According to an OPM official, this is the final version of the 
report. 

[32] GAO, Information Security: Federal Agencies Have Taken Steps to 
Secure Wireless Networks, but Further Actions Can Mitigate Risk, 
[hyperlink, http://www.gao.gov/products/GAO-11-43] (Washington, D.C.: 
Nov. 30, 2010). 

[33] GAO, Influenza Pandemic: Key Securities Market Participants Are 
Making Progress, but Agencies Could Do More to Address Potential 
Internet Congestion and Encourage Readiness, [hyperlink, 
http://www.gao.gov/products/GAO-10-8] (Washington, D.C.: Oct. 26, 
2009). 

[34] Office of Inspector General, U.S. Nuclear Regulatory Commission, 
Audit of NRC's Telework Program, OIG-10-A-13 (Washington, D.C.: June 
9, 2010). 

[35] The exact wording of this question has varied over the years. For 
example, recent annual reports have described the survey as asking 
whether telework had been "integrated" into the agency's emergency 
preparedness or continuity plans, while earlier reports describe the 
question as asking whether telework had been "incorporated" into these 
plans. We principally use "incorporation" in this report, as used in 
the Telework Enhancement Act, but on occasion we also use "integrate" 
when it is used in the document being described. 

[36] Office of Personnel Management, 2010 Status of Telework in the 
Federal Government (Washington, D.C.: February 2011). 

[37] For example, see GAO, Federal Transit Administration: Progress 
and Challenges in Implementing and Evaluating the Job Access and 
Reverse Commute Program, [hyperlink, 
http://www.gao.gov/products/GAO-09-496] (Washington, D.C.: May 21, 
2009) and Developing and Using Questionnaires, [hyperlink, 
http://www.gao.gov/products/GAO/PEMD-10.1.7] (Washington, D.C.: 
October 1993). 

[38] According to FEMA, Eagle Horizon is an annual continuity exercise 
for all executive-branch departments and agencies within the National 
Capital Region that requires federal departments and agencies to 
demonstrate their capability to perform mission-essential functions in 
the event of a major emergency. 

[39] According to FCD 1, the Continuity Advisory Group consists of 
continuity managers from federal agencies. It meets quarterly to 
discuss interagency implementation of continuity programs. 

[40] According to annex G of FCD 1, an alternate continuity facility 
is a facility that replicates essential capabilities of the department 
or agency's primary facility by providing systems and configurations 
that are used in daily activities, such as secure communications and 
access to vital records, and can accommodate the relocation of a 
limited number of key leaders and staff, for up to 30 days. 

[41] For the purposes of this report, we define the CIO community as 
including the members of the federal Chief Information Officers 
Council [hyperlink, http://www.cio.gov/] and their designees. The 
council is the principal interagency forum for improving agency 
practices related to the design, acquisition, development, 
modernization, use, operation, sharing, and performance of federal 
government information resources. 6 U.S.C. §3603. 

[42] During a pandemic flu, telework is a key measure to achieve 
social distancing, and large numbers of employees may be expected to 
telework simultaneously. (See GAO, Influenza Pandemic: Increased 
Agency Accountability Could Help Protect Federal Employees Serving the 
Public in the Event of a Pandemic, [hyperlink, 
http://www.gao.gov/products/GAO-09-404] (Washington, D.C.: June 12, 
2009). 

[43] Inspector General, Improvements Needed in the Department's 
Emergency Preparedness and Continuity of Operations Planning, DOE/IG- 
0845 (Washington, D.C.: Department of Energy, January 2011). 

[44] General Services Administration, Telework Technology Cost Study, 
Executive Summary, (Washington, D.C.: May 2, 2006). 

[End of section] 

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