Emergency Management
Most School Districts Have Developed Emergency Management Plans, but Would Benefit from Additional Federal Guidance Gao ID: GAO-07-609 June 12, 2007Congress has raised concerns over emergency management in school districts, with a particular interest in how federal agencies provide assistance to school districts. GAO was asked to assess (1) the roles of federal and state governments and school districts in establishing requirements and providing resources to school districts for emergency management planning, (2) what school districts have done to plan and prepare for emergencies, and (3) the challenges, if any, school districts have experienced in planning for emergencies, and communicating and coordinating with first responders, parents, and students. To obtain this information, GAO interviewed federal officials, surveyed a stratified random sample of all public school districts, surveyed state education agencies and state administering agencies, conducted site visits to school districts, and reviewed relevant documents.
Although there are no federal laws requiring all school districts to have emergency management plans, most states and school districts reported having requirements for such planning, and federal and state governments and school districts provide financial and other resources. Thirty-two states reported having laws or other policies requiring school districts to have emergency management plans. The Departments of Education (Education) and Homeland Security (DHS) and state governments as well as school districts provide funding for emergency management planning in schools. DHS awards grants to states and local jurisdictions that may provide some of these funds to school districts and schools for emergency management planning. However, DHS program guidance for certain grants does not clearly identify school districts as entities to which state and local governments may disburse grant funds. Thus, states receiving DHS funding may not be aware that such funding could be allocated to school districts or schools. Most school districts have taken federally recommended steps to plan and prepare for emergencies, including the development of emergency management plans, but many plans do not include recommended practices. Based on GAO's survey of school districts, most school districts, those with and without plans, have undertaken a variety of recommended practices to prepare for emergencies such as conducting school drills and exercises. In addition, based on GAO's survey of school districts, an estimated 95 percent of all school districts have written emergency management plans, but the content varies. While most school districts have procedures in their plans for staff roles and responsibilities, for example, school districts have not widely employed such procedures as, academic instruction via local radio or television, for continuing student education in the event of an extended school closure, such as might occur during a pandemic. Likewise, while many districts have procedures for special needs students, GAO found during site visits that some of these procedures may not fully ensure the safety of these students in an emergency. Finally, while most school districts practice their emergency management plans annually within the school community, GAO estimates that over one-quarter of school districts have never trained with any first responders and over two-thirds of school districts do not regularly train with community partners on how to implement their school district emergency management plans. Many school districts experience challenges in planning for emergencies, and some school districts face difficulties in communicating and coordinating with first responders and parents, but most do not have such challenges with students. Based on GAO's survey of school districts, in many school districts officials struggle to balance priorities related to educating students and other administrative responsibilities with activities for emergency management and consider a lack of equipment, training for staff, and personnel with expertise in the area of emergency planning as challenges. In an estimated 39 percent of school districts with emergency management plans, officials experienced a lack of partnerships, limited time or funding to plan, or lack of interoperability between equipment used by school districts and first responders. In interviews, about half of the officials in the 27 school districts GAO visited reported difficulty in ensuring that parents received consistent information from the district during an emergency.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-07-609, Emergency Management: Most School Districts Have Developed Emergency Management Plans, but Would Benefit from Additional Federal Guidance
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
June 2007:
Emergency Management:
Most School Districts Have Developed Emergency Management Plans, but
Would Benefit from Additional Federal Guidance:
GAO-07-609:
GAO Highlights:
Highlights of GAO-07-609, a report to congressional requesters
Why GAO Did This Study:
Congress has raised concerns over emergency management in school
districts, with a particular interest in how federal agencies provide
assistance to school districts. GAO was asked to assess (1) the roles
of federal and state governments and school districts in establishing
requirements and providing resources to school districts for emergency
management planning, (2) what school districts have done to plan and
prepare for emergencies, and (3) the challenges, if any, school
districts have experienced in planning for emergencies, and
communicating and coordinating with first responders, parents, and
students. To obtain this information, GAO interviewed federal
officials, surveyed a stratified random sample of all public school
districts, surveyed state education agencies and state administering
agencies, conducted site visits to school districts, and reviewed
relevant documents.
What GAO Found:
Although there are no federal laws requiring all school districts to
have emergency management plans, most states and school districts
reported having requirements for such planning, and federal and state
governments and school districts provide financial and other resources.
Thirty-two states reported having laws or other policies requiring
school districts to have emergency management plans. The Departments of
Education (Education) and Homeland Security (DHS) and state governments
as well as school districts provide funding for emergency management
planning in schools. DHS awards grants to states and local
jurisdictions that may provide some of these funds to school districts
and schools for emergency management planning. However, DHS program
guidance for certain grants does not clearly identify school districts
as entities to which state and local governments may disburse grant
funds. Thus, states receiving DHS funding may not be aware that such
funding could be allocated to school districts or schools. Most school
districts have taken federally recommended steps to plan and prepare
for emergencies, including the development of emergency management
plans, but many plans do not include recommended practices. Based on
GAO‘s survey of school districts, most school districts, those with and
without plans, have undertaken a variety of recommended practices to
prepare for emergencies such as conducting school drills and exercises.
In addition, based on GAO‘s survey of school districts, an estimated 95
percent of all school districts have written emergency management
plans, but the content varies. While most school districts have
procedures in their plans for staff roles and responsibilities, for
example, school districts have not widely employed such procedures as,
academic instruction via local radio or television, for continuing
student education in the event of an extended school closure, such as
might occur during a pandemic. Likewise, while many districts have
procedures for special needs students, GAO found during site visits
that some of these procedures may not fully ensure the safety of these
students in an emergency. Finally, while most school districts practice
their emergency management plans annually within the school community,
GAO estimates that over one-quarter of school districts have never
trained with any first responders and over two-thirds of school
districts do not regularly train with community partners on how to
implement their school district emergency management plans. Many school
districts experience challenges in planning for emergencies, and some
school districts face difficulties in communicating and coordinating
with first responders and parents, but most do not have such challenges
with students. Based on GAO‘s survey of school districts, in many
school districts officials struggle to balance priorities related to
educating students and other administrative responsibilities with
activities for emergency management and consider a lack of equipment,
training for staff, and personnel with expertise in the area of
emergency planning as challenges. In an estimated 39 percent of school
districts with emergency management plans, officials experienced a lack
of partnerships, limited time or funding to plan, or lack of
interoperability between equipment used by school districts and first
responders. In interviews, about half of the officials in the 27 school
districts GAO visited reported difficulty in ensuring that parents
received consistent information from the district during an emergency.
What GAO Recommends:
GAO is making several recommendations to DHS, Education, and HHS aimed
at improving school district emergency management planning and
preparation. Education and HHS generally agreed with GAO‘s
recommendations. DHS generally agreed with the intent of GAO‘s
recommendations.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-609].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Cornelia Ashby at (202)
512-7215 or ashbyc@gao.gov or William O. Jenkins, Jr. at (202) 512-8757
or jenkinsw@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Many States and School Districts Reported Having Requirements for
Emergency Management Plans, and Federal and State Governments and
School Districts Provide Resources for Emergency Management Planning:
Most Districts Have Taken Steps to Prepare for Emergencies and
Developed Written Plans, but Some Plans Do Not Address Recommended
Practices:
School Districts Report Challenges in Planning for Emergencies as Well
as Difficulties in Communicating with First Responders and Parents, but
No Challenges in Communicating with Students:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Survey of States:
Survey of School Districts:
Site Visits:
Appendix II: Emergency Management Planning Requirements:
Appendix III: Homeland Security Funding Provided to School Districts:
Appendix IV: Guidance, Training, and Funding States Provided to School
Districts:
Appendix V: Comments from the Department of Homeland Security:
Appendix VI: Comments from the Department of Education:
Appendix VII: Comments from the Department of Health & Human Services:
Appendix VIII: GAO Contacts and Staff Acknowledgments:
Tables:
Table 1: Estimated Frequency of School Districts' Review of Schools'
Emergency Management Plans:
Table 2: Estimated Number of School Districts That States Reported
Providing Homeland Security Funding during Fiscal Years 2003-2006:
Table 3: Examples of Guidance, Training, and Equipment the Federal
Government Provides to School Districts:
Table 4: Selected Practices That Education, DHS, and HHS Recommend
School Districts Take to Prepare for Emergencies:
Table 5: Key Elements in Emergency Management Plan Templates by
Percentage of School Districts with Written Emergency Management Plans:
Table 6: Types of Security Enhancements School Districts Made Based on
Vulnerability Assessments:
Table 7: Activities School Districts Have Taken Responsibility for to
Prepare for Emergencies:
Table 8: Estimated Percentage of School Districts That Have Procedures
for Communicating with Limited-English Proficient Parents and Students
in Their Emergency Management Plans:
Table 9: Percentage of School Districts That Use the Following
Procedures for Students with Special Needs in the Event of an
Emergency:
Table 10: Types of Recovery Procedures Addressed in School Districts
Written Emergency Management Plans:
Table 11: Percentages of School Districts with Written Plans That
Include Certain Types of Procedures to Continue Student Educational
Instruction in the Event of an Extended School Closure:
Table 12: Percentage of School Districts That Involve Stakeholders in
the Development and Update of Written Emergency Management Plans:
Table 13: Frequency of Updates to Emergency Management Plans:
Table 14: Estimated Frequency of Training with Each Type of First
Responder on How to Implement the School District Emergency Management
Plan:
Table 15: Description of the Population and Sample of Districts:
Table 16: School Districts Interviewed or Visited during Site Visits:
Table 17: States Reporting Selected Requirements for School Districts
or Schools for Emergency Management Planning:
Table 18: States That Reported Providing Homeland Security Funding
Directly to School Districts:
Table 19: States and the District of Columbia That Reported Provided
Homeland Security Funding to School Districts through Local
Jurisdictions during Fiscal Years 2003--2006:
Table 20: States and the District of Columbia That Reported Providing
Resources to School Districts to Assist in Emergency Management
Planning:
Figures:
Figure 1: States That Reported Having Laws or Other Policies Requiring
School Districts or Schools to Have Emergency Management Plans:
Figure 2: Estimated Differences in Types of Security Enhancements Made
by Urban and Rural Districts Based on Vulnerability Assessments:
Figure 3: Estimated Differences in Types of Activities Undertaken by
Urban and Rural Districts to Prepare for Emergencies:
Figure 4: Estimated Percentages of Urban and Rural Districts' Multi-
Hazard Emergency Management Plans That Include Specific Incidents:
Abbreviations:
CBSA: Core Based Statistical Area:
CCD: Common Core Data:
CDC: Centers for Disease Control and Prevention:
CSA: Consolidated Statistical Area:
DHS: Department of Homeland Security:
Education: Department of Education:
EMS: Emergency Medical Services:
ERCM: Emergency Response and Crisis Management:
FEMA: Federal Emergency Management Agency:
HHS: Health and Human Services:
ICS: Incident Command System:
IDEA: Individuals with Disabilities Education Act:
LEP: Limited-English Proficient:
NIMS: National Incident Management System:
NOAA: National Oceanic & Atmospheric Administration:
SHSP: State Homeland Security Program:
SRO: School Resource Officer:
UASI: Urban Areas Security Initiative:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
June 12, 2007:
The Honorable Joseph Lieberman:
Chairman:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Bennie Thompson:
Chairman:
Committee on Homeland Security:
House of Representatives:
The Honorable Bob Etheridge:
The Honorable Sheila Jackson-Lee:
House of Representatives:
Maintaining the safety and security of the over 49 million students in
the nation's more than 17,000 public school districts has been a focus
of federal, state, and local government for years. Federal and state
governments and school districts have generally focused on crime in and
around schools and violence among students. However, school districts
must be prepared for a range of emergencies within and outside of
school buildings. Events such as the terrorist attacks of September 11,
2001, natural disasters such as Hurricanes Katrina and Rita in 2005,
recent shootings by armed intruders in schools across the nation, and
potential pandemics have heightened the awareness of the range of
events for which schools should be prepared. In addition, environmental
and other types of hazards can exist in areas near school districts.
For example, school buildings can reside near nuclear plants, electric
power plants, railways that transport hazardous materials, major
airports, or major interstates.
"Emergency management" refers to the range of efforts involved in
building the capacity to prevent, protect against, respond to, and
recover from an incident. Planning for such incidents vary by the type
and scale of the incident. The federal government's role in emergency
management is principally to support state and local activities and
develop the federal capabilities to respond effectively when state and
local governments require federal assistance. Some federal support
comes in the form of guidance and recommendations. Because the federal
government serves as a partner to all states, it is uniquely positioned
to observe and evaluate the range of emergency management activities
across states and local governments, including school districts, and
disseminate information on recommended practices and successful
strategies. In addition, the federal government, largely through the
Department of Homeland Security (DHS), provides billions of dollars
each year in grants and other forms of assistance to help state and
local emergency managers and first responders (such as law enforcement,
fire departments, and emergency medical services). Other agencies such
as the Departments of Education (Education) and Health and Human
Services (HHS) also play a part in supporting state and local emergency
management activities with regard to education and public health,
respectively.
Emergency management for large-scale incidents generally requires
partnerships among federal, state, and local governments, nongovernment
organizations, and the private sector. For example, school districts
may need the assistance of other organizations, including
nongovernmental ones, in evacuating schools and finding shelter for
students when an earthquake renders a school structurally unsafe.
The Congress has raised concerns about whether school districts are
prepared to address a range of emergencies, particularly acts of
terrorism, and how three federal agencies--DHS, Education, and HHS--
provide assistance to school districts. In addition, the Congress has
expressed an interest in getting a better understanding of whether
school districts have emergency management plans that address the needs
of students and parents who are classified as Limited-English
Proficient (LEP), and students with special needs such as those with
mental, physical, motor, developmental, or sensory impairments.
In response to your request to examine the state of emergency
management in the nation's school districts, this report addresses the
following questions: (1) What are the roles of federal and state
governments and school districts in establishing requirements and
providing resources to school districts for emergency management
planning? (2) What have school districts done to plan and prepare for
emergencies? (3) What challenges, if any, have school districts
experienced in planning for emergencies and communicating and
coordinating with first responders, parents, and students?
To obtain the information to address our research objectives, we
conducted interviews, surveys, site visits to school districts, and
reviews of relevant documents and laws identified through surveys and
site visits. To determine the roles and requirements of federal and
state governments and the types of resources provided to districts, we
conducted interviews with officials with Education, HHS, and DHS and
reviewed relevant federal laws. We also administered two surveys, one
to state education agencies and one to state administering agencies
(the state agencies to which DHS disburses emergency management
funding[Footnote 1]) in all 50 states and the District of Columbia. We
received responses from 49 of 51 state education agencies and from 40
of 51 state administering agencies. In the survey to state
administering agencies, we asked specifically about whether states or
local governments provided school districts with federal funding from
the State Homeland Security Program (SHSP), Urban Areas Security
Initiative (UASI), and Citizen Corps grants.[Footnote 2] To better
understand how school districts plan and prepare for emergencies, we
administered a mail survey to a stratified random sample of school
districts in the 50 states and the District of Columbia. We used the
Department of Education's locale coding system in the Common Core Data
(CCD) to identify urban and rural school districts. Locale codes are
based on the specific conditions of schools and refer to very small
geographic areas and circumstances, such as population density and
size. Although several criteria are used by Education to classify
school districts including the percentage of students located in
particular locale codes (assigned to individual schools), generally,
urban districts are located within "large" (equal to or greater than
250,000 population) or "mid-sized" (less than 250,000 population)
cities and rural districts are located in areas designated as rural by
the Census Bureau. Appendix I includes a more detailed discussion of
how urban and rural districts are defined in the CCD. We received 444
of the 554 surveys we mailed to school districts for a response rate of
80 percent, including responses from 24 of the 26 largest school
districts in the country. Using a 95 percent confidence interval, all
percentage estimates included in this report have a margin of error of
plus or minus 10 percent or less, unless otherwise noted. We did not
survey individual schools within school districts. To further
understand the experiences districts have had in planning for
emergencies and communicating and coordinating with first
responders[Footnote 3], parents, and students, we visited selected
districts in the states of Florida, Iowa, Massachusetts, North
Carolina, Ohio, and Washington. We selected a geographically diverse
group of states and school districts, some of which had been identified
by national education associations as having implemented recommended
practices in the area of emergency management, some that did and others
that did not receive federal funding for emergency management, and we
included both urban and rural districts. In total, we conducted semi-
structured interviews, either in person or by telephone, with officials
in 27 school districts. For more detailed information on our scope and
methodology, see appendix I. Our work was conducted between April 2006
and April 2007 in accordance with generally accepted government
auditing standards.
Results in Brief:
Although there are no federal laws requiring all school districts to
have emergency management plans, most states and school districts
reported having requirements for such planning, and federal and state
governments and school districts provide financial and other resources
for such plans. Thirty-two states reported having laws or other
policies requiring school districts to have emergency management plans.
Based on our survey, we estimate that 85 percent of school districts
have requirements for school emergency management planning. Education,
DHS, and state governments as well as school districts provide funding
for emergency management planning in schools. DHS awards grants to
states and local jurisdictions that may provide some of these funds to
school districts and schools for emergency management planning.
However, DHS program guidance for the State Homeland Security Program,
Urban Areas Security Initiative, and Citizen Corps grants does not
clearly identify school districts as entities to which state and local
governments may disburse grant funds; therefore, some states receiving
DHS funding may be uncertain as to whether such funding can be
allocated to school districts or schools. As a result, school districts
in these states may not have the opportunity to benefit from this
funding. Federal and state governments and school districts also assist
school districts and schools in emergency management planning by
providing other resources such as guidance, training, and equipment.
However, in some instances, federal guidance does not include detailed
information on how school districts can implement recommended
practices.
Most school districts have taken federally recommended steps to plan
and prepare for emergencies including the development of emergency
management plans; while the content of plans vary, many do not include
recommended practices. Based on our survey of school districts, we
found that most school districts, those with and without plans, have
undertaken a variety of recommended practices to prepare for
emergencies such as conducting inspections to identify potential
vulnerabilities of school facilities and grounds and holding school
drills and exercises. In addition, we estimate that 95 percent of all
school districts have written emergency management plans. Nearly all of
those plans address multiple hazards such as natural disasters,
intruders, and bombs but few address pandemic influenza or radiological
hazards. The content of school district plans varies significantly.
While most school districts have outlined roles and responsibilities
for staff in their plans, for example, over half of all school
districts with emergency management plans have not employed procedures
for continuing student education in the event of an extended school
closure, such as might occur during a pandemic. Likewise, while many
districts have procedures for special needs students, we found during
our site visits that procedures vary in the extent to which they ensure
the safety of special needs students in an emergency. A higher
percentage of urban school districts' plans included procedures for
special needs students and for communicating with Limited-English
Proficient parents and students compared to rural districts. Fewer than
half of all school districts have involved the local head of government
and fewer than half involved the local public health agency in the
development of their plans. While half of all school districts update
their emergency management plans at least once a year, an estimated 10
percent had never updated their plans. Finally, while most school
districts practice their emergency management plans annually within the
school community, we estimate that over one-quarter of school districts
have never trained with first responders and over two-thirds of school
districts do not regularly train with community partners on how to
implement their school district emergency management plans. The reasons
why school districts do not train with first responders or community
partners are not readily apparent.
Many school district officials said that they experience challenges in
planning for emergencies and some school districts face difficulties in
communicating and coordinating with first responders and parents, but
most said that they do not experience challenges in communicating with
students. Based on our survey of districts, we estimate that in 70
percent of all school districts, officials struggle to balance
priorities related to educating students and other administrative
responsibilities with activities for emergency management. For example,
in some of the districts we visited, administrators were reluctant to
allocate teacher development training time to emergency management
because of other training priorities. In an estimated 62 percent of all
school districts, officials identified challenges stemming from a lack
of equipment, training for staff, and personnel with expertise in the
area of emergency planning. Officials noted that a lack of equipment
and expertise can impact many aspects of emergency management,
including planning for special needs students. For example, a school
district official in Washington said that the district lacks equipment
to evacuate special needs students from some school buildings and in
some cases staff are unsure of how to operate the existing equipment.
Officials also reported problems in communicating and coordinating with
first responders and parents. In an estimated 39 percent of school
districts with emergency management plans, officials experienced a lack
of partnerships, limited time or funding to discuss planning with first
responders, or lack of interoperability between equipment used by
school districts and first responders. About half of the officials in
the 27 school districts we interviewed reported difficulty in ensuring
that parents received consistent information from the district during
an emergency. Some of these officials also described problems in
communicating emergency-related information to Limited-English
Proficient parents.
To address issues related to the emergency management of school
districts, we recommend that (1) DHS clearly identify school districts
as entities to which state and local governments may disburse grant
funds in its program guidance for the State Homeland Security Program,
Urban Areas Security Initiative, and Citizen Corps programs to ensure
that states and local governments are aware that they can disburse
funding to school districts and still meet funding requirements; (2)
Education, in collaboration with DHS and HHS, provide guidance to
school districts on successful procedures for sheltering and evacuating
special needs students during emergencies; (3) Education collaborate
with HHS to provide specific guidance to states and school districts on
how to incorporate, in emergency management plans, procedures for the
continuation of education in the event of extended school closures such
as those that might occur in the case of a pandemic (such as pandemic
influenza); and (4) DHS and Education identify the factors that prevent
school districts, first responders, and community partners from
training together, develop strategies for addressing those factors, and
promote current efforts that can help school districts in this area.
We provided copies of this report to DHS, Education, and HHS for review
and comment. DHS generally agreed with the intent of our
recommendations but suggested additional language regarding the need to
promote the use of current resources in efforts to increase school
district training with first responders and community partners, which
we incorporated. DHS's comments are in appendix V. In its comments on
the draft report, Education generally agreed with our recommendations.
Education's comments are in appendix VI. Finally, HHS generally agreed
with our recommendations and asked that we include HHS in our
recommendation that federal agencies provide additional guidance
related to special needs students, which we accepted. HHS's comments
are in appendix VII.
Background:
Federal Role in Emergency Management:
The Homeland Security Act of 2002 created DHS and consolidated most of
the federal programs and agencies with responsibilities for emergency
management into that agency.[Footnote 4] DHS serves as a federal
partner to state and local governments in emergency
management.[Footnote 5] DHS provides technical assistance and homeland
security grant funding to states and local governments to enhance their
emergency management efforts. States and local governments have the
responsibility for spending DHS grant funds in accordance with DHS
guidelines to meet local emergency management needs. In fiscal year
2006, DHS awarded $1.7 billion to states, urban areas, and territories
to prepare for and respond to terrorist attacks and other disasters.
States and local governments may then provide a portion of this funding
to a range of entities, as specified in DHS's program guidance.
As we have noted in prior reports, emergency management requires
coordinated planning and implementation by a variety of participants.
Effective emergency management requires identifying the hazards for
which it is necessary to be prepared (risk assessments); establishing
clear roles and responsibilities that are effectively communicated and
well understood; and developing, maintaining, and mobilizing needed
capabilities, such as people, skills, and equipment.[Footnote 6] The
plans and capabilities should be tested and assessed through realistic
exercises that identify strengths and areas that need improvement, with
any needed changes made to both plans and capabilities.
The hazards that school districts may face will vary across the country
depending upon the natural hazards to which their particular areas are
prone and an assessment of other risks for which they need to be
prepared, such as pandemic influenza or the discharge of hazardous
substances from nearby chemical or nuclear plants. Similarly, who
should be involved in emergency planning and response for schools, and
the roles of the various participants will vary by type and size of the
emergency incident. For large-scale emergencies, effective response is
likely to involve all levels of government--federal, state, and local-
-nongovernment entities, such as the Red Cross, and the private sector.
Funding of School Districts:
The responsibility for funding K-12 education rests primarily with
state and local governments. Approximately 90 percent of spending on
education comes from state, local, and private funds. The federal
government contributes approximately 8 to 10 percent. School districts
are responsible for spending the funds in accordance with applicable
federal, state, and local laws. However, the formulas states use to
determine how to fund school districts and the actual amount of funding
states and local governments spend on education can vary.
Many States and School Districts Reported Having Requirements for
Emergency Management Plans, and Federal and State Governments and
School Districts Provide Resources for Emergency Management Planning:
Although no federal laws exist requiring all school districts to have
emergency management plans, most states and school districts reported
having requirements for school emergency management planning, and
federal and state governments and school districts provide financial
and other resources for such planning. Education, DHS, and state
governments as well as school districts provide funding for emergency
management planning in schools. However, DHS program guidance does not
clearly identify school districts as entities to which states and local
governments may disburse grant funds. Not all states receiving DHS
funding are aware that such funding could be disbursed to school
districts. In addition to providing funding, federal and state
governments and school districts assist school districts and schools in
emergency management planning by providing other resources such as
guidance, training, and equipment.
Although No Federal Laws Exist Requiring Emergency Management Planning,
the Majority of States and School Districts Have Requirements:
Although there are no federal laws requiring all school districts to
have emergency management plans, many states reported having laws or
other policies that do so. Congress has not enacted any broadly
applicable laws requiring all school districts to have emergency
management plans, nor have federal agencies issued any regulations
imposing such a requirement on all school districts. However, the No
Child Left Behind Act of 2001 provides that local education agencies
(LEAs or school districts) applying for subgrants under the Safe and
Drug Free Schools and Communities Program include in their grant
applications an assurance that either they or their schools have "a
plan for keeping schools safe and drug-free that includes.a crisis
management plan for responding to violent or traumatic incidents on
school grounds."[Footnote 7] Thirty-two states reported having laws or
other policies requiring school districts or schools to have a written
emergency management plan (see fig. 1).
Figure 1: States That Reported Having Laws or Other Policies Requiring
School Districts or Schools to Have Emergency Management Plans:
[See PDF for image]
Source: GAO analysis of survey data; (Map) Map Resources.
[End of figure]
Several state laws identify a broad range of specific emergencies that
schools or districts are required to address in their plans, while many
other states do not identify particular kinds of crises or use more
general language to refer to the kinds of emergencies that plans must
incorporate. For example, districts in Indiana are required to develop
plans that address, at a minimum, fire; natural disasters such as
tornadoes, floods, and earthquakes; adverse weather conditions, such as
winter storms or extreme heat; nuclear contamination from power plants
or vehicle spills; exposure to chemicals from a variety of sources; and
manmade occurrences, such as student disturbances, weapons, weapons of
mass destruction, water or air supply contamination, and hostage and
kidnapping incidents. In contrast, some states, such as Pennsylvania,
South Dakota, and Texas, among others, do not identify any specific
hazards in their planning requirements.
State emergency planning requirements also vary in their degree of
prescriptiveness regarding plan development and emergency preparedness.
For example, a number of states, including Georgia and Ohio, require
that schools or districts involve partners, such as first responders,
other community leaders, parents, and teachers in the planning process.
Likewise, some states, such as Illinois and Nevada, specifically
require that plans be reviewed annually and updated as appropriate.
Additionally, New Jersey and other states require districts and schools
to provide relevant district and school officials with periodic
training related to emergency plans. In comparison, the requirements of
some states, such as Oregon and Washington, are less detailed. For more
detailed information on state emergency planning requirements, see
appendix II.
Many of the school districts we surveyed also reported having emergency
management planning requirements for schools. Based on our survey of
school districts, we estimate that 85 percent of all districts require
schools to have their own written emergency management plans. Of these
districts, 88 percent require that school plans be submitted to them
for review. However, the frequencies of these reviews vary (see table
1).
Table 1: Estimated Frequency of School Districts' Review of Schools'
Emergency Management Plans:
Frequency of school district review: At least once a year;
Percentage estimate of school districts conducting review: 71.
Frequency of school district review: At least once every 2 years;
Percentage estimate of school districts conducting review: 7.
Frequency of school district review: At least once every 3 years;
Percentage estimate of school districts conducting review: 13.
Frequency of school district review: Other;
Percentage estimate of school districts conducting review: 5.
Frequency of school district review: Do not review;
Percentage estimate of school districts conducting review: 4.
Source: GAO analysis of survey data.
[End of table]
Federal Agencies, State Governments, and School Districts Provide
Funding for School Districts' Emergency Management Planning:
Education provides funding to some school districts specifically for
emergency management planning through its Emergency Response and Crisis
Management (ERCM) Grant Program.[Footnote 8] Since fiscal year 2003,
Education dispersed $130 million in such grants to over 400 of the over
17,000[Footnote 9] school districts in the United States. These grant
awards ranged from $68,875 to $1,365,087. For example, in fiscal year
2004, Seattle Public Schools received an ERCM grant for $494,144 to
train principals in using the Incident Command System (ICS)[Footnote
10] and to establish Web-based training, among other things. In Tampa,
Florida, a school district used a fiscal year 2006 ERCM grant of
$487,424 to install a new radio system and sponsor faculty workshops on
emergency response. Other uses reported by school districts we visited
include establishing emergency management plans, installing equipment
such as closed circuit televisions, training school administrative
staff (such as principals) on the National Incident Management System
(NIMS) and the ICS, and purchasing emergency backpacks for school
nurses.
DHS also provides funding to states and local jurisdictions for
emergency management planning, and some of this funding can be provided
to school districts or schools for emergency management planning. DHS
officials told us that such funds are available through the State
Homeland Security Program (SHSP), Urban Areas Security Initiative
(UASI), and Citizen Corps grants. Five states--Florida, Hawaii,
Michigan, Mississippi, and Wyoming--reported that they provided
approximately $14 million in DHS funding directly to school districts
in these states during fiscal years 2003-2006 (see table 2). Florida,
for example, provided about $4.3 million in SHSP funds over a 2-year
period to selected school districts for training, upgrading the
districts' emergency communications, and controlling access to school
facilities, as well as for conducting studies related to emergency
management. In fiscal year 2003, Michigan provided $8.6 million in SHSP
funds to 488 of its 801 school districts to conduct planning exercises
in response to potential terrorist events.
Table 2: Estimated Number of School Districts That States Reported
Providing Homeland Security Funding during Fiscal Years 2003-2006:
Fiscal year: 2006;
Estimated number of school districts[A]: 72.
Fiscal year: 2005;
Estimated number of school districts[A]: 85.
Fiscal year: 2004;
Estimated number of school districts[A]: 70.
Fiscal year: 2003;
Estimated number of school districts[A]: 536.
Source: GAO analysis of state administering agencies survey data.
[A] States may have funded the same school districts over multiple
years.
[End of table]
In addition, eight states and the District of Columbia reported that
they provided DHS funding to local jurisdictions that then provided a
portion of these funds to school districts or schools for emergency
management planning.[Footnote 11] For example, South Dakota officials
told us they awarded a portion of the state's fiscal year 2006 SHSP
funds to South Dakota's local counties. These officials said that the
counties then provided approximately $26,000 to 3 of the state's 176
school districts for emergency management planning efforts. Although
Oklahoma did not respond to our survey of state administering agencies,
in February 2007, officials from its Office of Homeland Security issued
a press release and confirmed to us that it provided $50,000 of DHS
funding (SHSP) to five elementary schools to enhance those schools'
physical security. They said that each school received a $10,000 grant
to purchase equipment such as cameras, magnetometers, concrete
barriers, identification systems, and two-way radios. For additional
information on DHS funding that states or their local jurisdictions
provided to school districts, see appendix III.
Although DHS officials told us that some of its emergency planning
grant programs, such as SHSP, UASI, and Citizen Corps allow for the use
of funds at the district or school level, the department's program
guidance does not clearly specify that school districts are among the
entities to which state and local governments may disburse
funds.[Footnote 12] As a result, some states may not be aware of their
availability. For example, state officials in Alaska and Iowa told us
they were not aware that DHS emergency planning grants could be used by
school districts. School districts in these states do not have the
opportunity to benefit from this funding. In Vermont, one official
expressed the view that DHS program guidance is unclear on the
permissible use of these funds.
Eleven of the 49 states[Footnote 13] responding to surveys we sent to
state education and state administering agencies reported providing
state funding to school districts for emergency management planning
(see app. IV for a listing of these states). For example, the
Connecticut State Department of Education reported that its State
Legislature provided $180,000 for emergency management training in its
state. Of these funds, the state disbursed $30,000 to each of
Connecticut's six education centers to train schools within its region,
according to its Department of Education.[Footnote 14] To use this
funding, the Connecticut State Department of Education reported that
each education center was required to provide a minimum of three full-
day workshops that were open to any school in its respective region.
Hawaii also reported providing approximately $2.1 million to 62 of its
285 schools[Footnote 15] to assist those schools in contracting for the
services of School Safety Managers (mainly retired law enforcement
officers) in developing school emergency response plans during fiscal
years 2003-2005.
In the absence of federal and state sources, schools have been relying
on local school district funds for the emergency management planning
that they have undertaken. Three school districts we visited reported
that they provided funding for emergency management planning in
schools. Officials from a school district in Ohio, Shaker Heights, said
that school emergency management activities are funded from the school
district's general fund. These school district officials told us they
spent about $100,000, not including staff hours and pay, to undertake
emergency management planning. To help prepare for an emergency,
officials in Olmsted Falls, Ohio, said that the school district bought
one automated external defibrillator[Footnote 16] for each of its
buildings. Finally, officials from Sequim School District in Washington
told us that they spent $70,000 from their general funds to install a
camera system at one of the two elementary schools located in their
district.
Federal Agencies, State Governments, and School Districts also Provide
Guidance, Training, and Equipment:
The federal government also provides guidance, training, and equipment
to school districts to assist in emergency management planning (see
table 3).
Table 3: Examples of Guidance, Training, and Equipment the Federal
Government Provides to School Districts:
Examples of Guidance:
* Education publishes a guide for schools and communities titled
Practical Information on Crisis Planning, which explains, among other
things, how schools can prepare for an emergency;
* Education created the Emergency Response and Crisis Management
Technical Assistance Center to help school districts in emergency
management planning. The center provides guidance to school districts
through such activities as sharing examples of emergency management
plans, assisting with training staff, and evaluating emergency
management plans;
* DHS created a Web site, How Schools Can Become More Disaster
Resistant, that provides guidance for teachers and parents regarding
how to prepare emergency management plans. The site also discusses
identifying and mitigating hazards, developing response and coping
plans, and implementing safety drills;
* Education funded the development of the National Clearinghouse for
Educational Facilities--Disaster Preparedness for Schools. This Web
site provides a list of resources (links, books, and journal articles)
regarding building or retrofitting schools to withstand natural
disasters and terrorism, developing emergency preparedness plans, and
using school buildings to shelter community members during emergencies;
* The Secret Service, an agency within DHS, collaborated with Education
in developing and publishing a Threat Assessment Guide for Schools. The
guide was developed following the Columbine High School attack in April
1999. Secret Service and Education jointly produced and disseminated a
CD-ROM that served as a companion to this guide.
Examples of Training:
* The Federal Emergency Management Agency (FEMA), within DHS, offers
online courses including one on emergency management planning for
schools;
* Education offers two 1-½ day Emergency Management for Schools
training sessions that provide school personnel with critical training
on emergency management issues, resources, and practices. Emphasis for
these trainings is placed on emergency management plan development and
enhancement within the framework of four phases of emergency
management: prevention and mitigation, preparedness, response, and
recovery.
Examples of Equipment:
* With funding from DHS and support from Education, the Department of
Commerce's National Oceanic & Atmospheric Administration (NOAA)
distributed 96,000 NOAA radios to almost all public schools in the
United States in 2005 and 2006. These radios are intended to notify
school officials of hazards in their area 24 hours a day/7 days a week,
even when other means of communication are disabled.[A].
Source: Education, DHS, and HHS.
[A] Schools receiving NOAA radios included schools in six states that,
according to DHS, mandate that public schools have radios. These states
are Washington, Tennessee, North Carolina, Maryland, Florida, and
Mississippi. DHS told us that they have procedures in place to allow a
school to request a radio if it did not receive one. DHS officials also
told us that they plan to distribute NOAA radios to non-public schools
(private, independent, parochial and other faith-based institutions),
postsecondary education facilities, and district offices in 2007.
[End of table]
Education, DHS, and HHS have collaborated and developed recommended
practices to assist in preparing for emergencies that can be applied to
school districts.[Footnote 17] Some of these practices are shown in
table 4.
Table 4: Selected Practices That Education, DHS, and HHS Recommend
School Districts Take to Prepare for Emergencies:
Recommended practices:
* Allocate time to emergency management planning;
* Conduct an assessment of vulnerabilities;
* Conduct regular drills;
* Identify and acquire equipment to mitigate and respond to
emergencies;
* Identify a storage location and replenish emergency supplies on a
regular basis;
* Develop an emergency management plan and update the plan on a regular
basis. In developing and updating this plan, school districts should:
- Identify and address a range of events and hazards specific to the
district or schools;
- Develop roles and responsibilities and procedures for school
community members;
- Develop roles and responsibilities for first responders and community
partners;
- Develop procedures for communicating with key stakeholders such as
parents and students, including those who are Limited-English
Proficient;
- Develop procedures for special needs students;
- Develop procedures in the plan for recovering from an incident,
including continuing student education during an extended school
closure;
- Determine lessons learned after an incident or training;
- Develop multi-purpose manuals, with emergency management information,
that can be tailored to meet individual school needs;
* Include community partners such as local government and public health
agencies in planning;
* Coordinate the school district's emergency procedures with state and
local governments;
* Practice the emergency management plan with first responders and
community partners on a regular basis.
Source: GAO analysis of Education, DHS, and HHS guidance and training
documents.
[End of table]
We have also recognized the importance of certain of these practices in
our prior reports on emergency management.[Footnote 18] For example, a
central component of all emergency management plans is defining the
roles and responsibilities of all those with responsibilities for
preparing to respond to an emergency. These roles should be clearly
established, communicated, and understood. We have also emphasized the
value of identifying the types of hazards for which school districts
should be prepared as part of their emergency management efforts. These
hazards will vary across the country; thus, it is appropriate that
school emergency plans include hazards specific to their area. In
addition, we have recognized the importance of realistic training
exercises followed by a careful assessment of those exercises. Those
with whom the school districts should coordinate and train will vary by
the type and size of the emergency. For example, for a potential
pandemic flu or other major infectious outbreak, planning and working
with local health authorities and others is critical. Furthermore,
"after action" reports that assess what went well and what did not go
well following real emergency incidents or exercises, can also
contribute to improving emergency management.
The type of guidance available from the federal government on topics
related to emergency management in schools varies significantly; in
some instances federal agencies provide detailed instructions on how to
implement recommended practices while in other instances, guidance is
less detailed. For example, HHS and its Centers for Disease Control and
Prevention (CDC) developed recommended practices with regard to
pandemics and provides school districts with specific recommended steps
for planning and coordination, infection control policies and
procedures, and communications planning. While it also recommends that
school districts plan for the continuity of student learning, its
guidance does not provide specific recommended steps or examples of
successful strategies. Rather, it broadly states that schools should
develop scenarios involving short-and long-term school closures.
Likewise, Education's guidance to school districts, through its
recommended practices, clearly states that districts should incorporate
procedures for special needs students in emergency management plans.
However, Education does not provide guidance on or examples of what
those procedures could be.
In addition to the federal government, states provide guidance and
training to school districts. Based on our survey of state
administrative agencies and state education agencies, 47 states
reported providing guidance and 37 states reported providing training.
Some states also reported providing online resources that include
guidance and training. (See app. IV for a listing of these states.) For
example:
* Guidance. South Dakota's Department of Education provides guidance on
how to distribute food during a crisis or emergency event that may
occur at schools.
* Training. The Maryland Department of Education offers periodic
workshops for school system points-of-contact for emergency planning on
topics such as threat assessment and pandemic flu.
* Online Resources. The Idaho Department of Education provides links on
its Web site to FEMA's course on emergency planning for schools and
Education's Emergency Response and Crisis Management Technical
Assistance Center.
Many of the school districts we surveyed also reported providing their
schools with guidance to assist in emergency management planning. For
example, based on our survey, we estimate that 73 percent of all school
districts have an emergency management plan template that includes key
elements schools should include in their plans (see table 5).
Table 5: Key Elements in Emergency Management Plan Templates by
Percentage of School Districts with Written Emergency Management Plans:
Templates includes: School Campus Plan;
Estimated percentage of school districts: 95.
Templates includes: Potential use of school facilities;
Estimated percentage of school districts: 93.
Templates includes: School level emergency management team members;
Estimated percentage of school districts: 94.
Templates includes: Procedures for communication with law enforcement;
Estimated percentage of school districts: 94.
Templates includes: Procedures for contacting district-level incident
response team; Estimated percentage of school districts: 92.
Templates includes: ICS positions and staff;
Estimated percentage of school districts: 76.
Templates includes: Includes special needs student population;
Estimated percentage of school districts: 67.
Source: GAO analysis of survey data.
[End of table]
Most Districts Have Taken Steps to Prepare for Emergencies and
Developed Written Plans, but Some Plans Do Not Address Recommended
Practices:
Almost all school districts have taken steps to prepare for
emergencies, including developing written plans, but some plans lack
key elements such as procedures for special needs students, plans for
continued student education in the event of an extended closure, and
procedures for training regularly with first responders. Most
districts, those with and without plans, have undertaken a variety of
federally-recommended activities, such as conducting vulnerability
assessments and school drills and exercises, as well as additional
activities to prepare for an emergency such as oversight and
coordination with other entities. While most districts have written
emergency management plans that address a range of hazards such as
intruders, bombs, and natural disasters, the content of plans varies.
Although most school districts have plans that include roles and
responsibilities for staff, few have procedures for continuing student
education in the event of an extended school closure. Many districts
have procedures in their plans for special needs students, but these
procedures vary in their ability to fully ensure the safety of these
students during an emergency. Fewer than half of all school districts
involved a representative from the local head of government and fewer
than half involved the local public health agency in the development
and updating of their emergency management plans. Finally, we estimate
that over one-quarter of school districts with emergency management
plans have never trained with first responders and over two-thirds of
school districts do not regularly (i.e., at least once a year) train
with community partners on how to implement their school plans.
Most School Districts Have Undertaken Some Emergency Management
Activities:
Based on our survey of school districts, we estimate that 93 percent of
all school districts conduct inspections of their school buildings and
grounds to identify possible vulnerabilities in accordance with
recommended practices. Of those school districts, 87 percent made
security enhancements to their school facilities and grounds as a
result of these inspections. (See table 6.)
Table 6: Types of Security Enhancements School Districts Made Based on
Vulnerability Assessments:
Type of security enhancement implemented: Added or enhanced equipment
to communicate with school employees;
Estimated percentage of school districts: 85.
Type of security enhancement implemented: Strengthened the perimeter
security of school;
Estimated percentage of school districts: 70.
Type of security enhancement implemented: Made inventory changes such
as removing hazardous materials;
Estimated percentage of school districts: 69.
Type of security enhancement implemented: Enhanced access controls;
Estimated percentage of school districts: 68.
Type of security enhancement implemented: Added or enhanced equipment
to communicate with law enforcement, fire department, and emergency
medical service officials;
Estimated percentage of school districts: 41.
Type of security enhancement implemented: Reduced number of portable
classrooms;
Estimated percentage of school districts: 10.
Source: GAO analysis of survey data.
[End of table]
A higher percentage of urban school districts have made certain types
of security enhancements to schools in their districts as a result of
these assessments compared with rural school districts. (See fig. 2.)
Figure 2: Estimated Differences in Types of Security Enhancements Made
by Urban and Rural Districts Based on Vulnerability Assessments:
[See PDF for image]
Source; GAO analysis of survey data.
Note: Margins of error for rural estimates do not exceed 11 percent.
[End of figure]
Based on our survey of school districts, an estimated 73 percent of all
school districts regularly conduct some type of school drill or
exercise, in alignment with recommended practices to prepare for
emergency situations such as evacuations, lockdowns, and shelter-in-
place. During our site visits, we learned that drills were tailored to
the needs of the local community and varied by locality. For example,
in Iowa state that is prone to tornados district officials said the
state requires schools to practice tornado drills twice a year. In
Washington state that is prone to earthquakes district officials stated
they practice earthquake drills twice a year or more.
Our survey of school districts revealed that an estimated 65 percent of
all school districts have a storage location and replenish emergency
supplies such as food, water, and first-aid supplies, as recommended.
During our site visits, school district officials identified a variety
of equipment, supplies, and storage for different types of emergencies.
In Renton, Washington, officials reported storing backpacks in the
classrooms that contain enough food, water, medical supplies, and
flashlights, among other items, for a short-term emergency. For an
extended emergency, each school has a supply of emergency gear that
includes: a 2-to 3-day supply of water, thermal blankets, sanitation
needs, and energy bars. Similarly, school district officials we visited
in Des Moines, Iowa, stated they have two kits for different types of
emergencies. The first kit, designed for school nurses to use in
evacuations, is a duffel bag containing medical supplies such as:
bandages, splints, face masks, and eye patches, as well as equipment
such as: folding stretcher, blood pressure kit, stethoscope, and cold
packs. The second kit, designed for custodians, is a garbage can that
contains tools as well as supplies such as a broom, gloves, rope,
water, and bleach, among other items. In contrast, in one Washington
district the disaster kits contain communication equipment, but they do
not include supplies of food or water.
In addition to conducting vulnerability assessments, school drills, and
maintaining emergency supplies, school districts took responsibility
for a number of activities to prepare for emergencies at the district
level. These activities can vary by locality depending on community
needs and include oversight, coordination with other entities, and
training. (See table 7.) For example, in Hardee County, Florida
district that is frequently hit by hurricanes officials stated that the
county designated the schools as shelters for the public and the school
district provides staff, such as maintenance and food service
personnel, to work at the schools as part of a negotiated arrangement.
Officials in Pinellas County district that is frequently hit by
tornados and hurricanes told us they have trained an on-site district
level team that coordinates emergency response activities during an
emergency or event.
Table 7: Activities School Districts Have Taken Responsibility for to
Prepare for Emergencies:
Type of activity: Ensure school compliance with emergency preparedness
requirements;
Estimated percentage of school districts: 74.
Type of activity: Negotiate arrangements for use of school buildings as
temporary shelters;
Estimated percentage of school districts: 72.
Type of activity: Coordinate agreements with law enforcement, fire
department, and emergency medical service officials;
Estimated percentage of school districts: 68.
Type of activity: Identify security personnel needs at schools;
Estimated percentage of school districts: 65.
Type of activity: Identify and train a district-level incident response
team;
Estimated percentage of school districts: 62.
Source: GAO analysis of survey data.
[End of table]
As shown in figure 3, a higher percentage of urban districts took
responsibility for certain types of activities to prepare for an
emergency compared with rural districts.
Figure 3: Estimated Differences in Types of Activities Undertaken by
Urban and Rural Districts to Prepare for Emergencies:
[See PDF for image]
Source: GAO analysis of survey data.
[A] Differences between urban and rural districts are not statistically
significant.
[End of figure]
Most Districts Have Emergency Management Plans That Address Multiple
Hazards, but the Content of Plans Varies Significantly:
Most school districts have developed written emergency management plans
that address multiple hazards. Based on our survey of school districts,
we estimate that 95 percent of all school districts have written
emergency management plans with no statistical difference between urban
and rural districts.[Footnote 19] Of those school districts that have
written emergency plans, nearly all (99.6 percent) address multiple
hazards in accordance with recommended practices to prepare for
emergencies. However, the specific hazards addressed by plans vary.
Although most school district plans address emergency situations
arising from intruders or hostages, bombs or bomb threats, and natural
disasters, a smaller percentage of school districts address pandemic
influenza, anthrax, or radiological hazards. A significantly higher
percentage of urban districts address terrorism and anthrax, for
example, compared to rural school districts.[Footnote 20] (See fig. 4.)
Figure 4: Estimated Percentages of Urban and Rural Districts' Multi-
Hazard Emergency Management Plans That Include Specific Incidents:
[See PDF for image]
Source: GAO analysis of survey data.
[A] Differences between urban and rural districts are not statistically
significant.
[End of figure]
In some instances, the hazards included in emergency plans are specific
to local conditions which is to be expected. For example, school
district officials we visited in Hillsborough, Florida, involved
representatives from the airport in the development of their district
plan because airport traffic was identified as a unique hazard in their
local community. In Ashtabula, Ohio, district officials said their plan
addresses evacuations due to chemical spills because they have a number
of chemical plants in the community.
The extent to which school districts emergency management plans are
consistent with other recommended practices varies:
Develop Roles and Responsibilities for School Community Members. Based
on our survey, most districts have written roles and responsibilities
in their plans for staff such as superintendents, building engineers or
custodians, principals, teachers, and nurses. Among the plans we
reviewed, some have more detailed instructions on roles and
responsibilities than others. For example, school district officials we
visited in Boston, Massachusetts, have a series of emergency management
plans for different school community members that included district
officials, school administrators, and teachers. The school district
document (the Crisis Command Plan) describes the organizational
framework and response resources that the district will use to manage
major emergencies, while a document for school administrators describes
procedures and resources for school-level incidents. In addition, the
district issues a classroom emergency guide that outlines procedures
for teachers to use during an emergency. In contrast, the district plan
for a district in Iowa lists appropriate actions for specific types of
emergencies but does not assign roles and responsibilities for their
implementation.
Develop Roles and Responsibilities for First Responders and Community
Partners. Based on our survey, we estimate that 43 percent of school
districts use the Incident Command System (ICS) established by DHS as
part of the National Incident Management System (NIMS)[Footnote 21] to
establish the roles and responsibilities of school district officials,
local first responders, and community partners during an emergency, in
accordance with recommended practices. A significantly higher
percentage of urban school districtsó67 percent were responsible for
ensuring that their emergency plans were in compliance with DHS's NIMS
compared to rural school districtsó41 percent.
Develop Procedures for Communicating with Key Stakeholders. Also
central to district emergency plans is the inclusion of procedures for
communicating with key stakeholders such as staff, parents, and
students, including those who are LEP. Our survey suggests that roughly
three-quarters of all school districts have not included written
procedures in their plans for communicating with LEP parents and
students, in accordance with federally recommended practices. A
significantly higher percentage of urban school districts report
including procedures for communicating with such parents and students
in their plans compared to rural school districts. (See table 8.) This
difference may, in part, be explained by the relatively fewer LEP
parents and students in rural school districts.
Table 8: Estimated Percentage of School Districts That Have Procedures
for Communicating with Limited-English Proficient Parents and Students
in Their Emergency Management Plans:
Limited-English Proficient: Parents;
All school districts: 27;
Urban school districts: 59;
Rural school districts: 18.
Limited-English Proficient: Students;
All school districts: 28;
Urban school districts: 61;
Rural school districts: 21.
Source: GAO analysis of survey data.
[End of table]
Develop Procedures for Special Needs Students. Although HHS officials
and some education organizations report that the number of special
needs students in the schools is growing, our survey finds that an
estimated 28 percent of school districts with emergency management
plans do not have specific provisions for them in their emergency
management plans. Although most school districts reported having
procedures for special needs students, these procedures were not
necessarily a part of the written plan. (See table 9.) However,
Education's guidance recommends not only having procedures for special
needs students but including these procedures in written emergency
plans. Officials from two education associations said the lack of
procedures in district plans for evacuating these students, was a
significant concern.[Footnote 22] According to these officials, these
students may be at increased risk during an emergency. During our site
visits, several school officials who did not have provisions in their
plans for special needs students said it was a school, not a district-
level responsibility. District officials in Marshalltown, Iowa, for
example, said special needs student procedures are the responsibility
of local schools. However, they said that the district does provide a
checklist for schools that includes provisions for special needs
students during an emergency such as communicating to first responders
the location of special needs students who cannot be evacuated due to
mobility impairments. A significantly higher percentage of urban school
districts (77 percent) included procedures for special needs students
in their written plans compared to rural school districts (62 percent).
This may be due, in part, to several reasons such as parents of special
needs students selecting communities to live in based on a district's
special needs resources or districts with low special needs student
populations including procedures for these students in individualized
education programs[Footnote 23] rather than the district plan.
Table 9: Percentage of School Districts That Use the Following
Procedures for Students with Special Needs in the Event of an
Emergency:
Procedures for special needs students in an emergency: Track the
location of special needs students during the day;
Estimated percentage of school districts: 74.
Procedures for special needs students in an emergency: Identify list of
district or school staff assigned to evacuate or shelter with special
needs students during emergency;
Estimated percentage of school districts: 72.
Procedures for special needs students in an emergency: Provide devices
for transporting special needs students to evacuation areas;
Estimated percentage of school districts: 62.
Source: GAO analysis of survey data.
Note: Responses are not mutually exclusive.
[End of table]
Education officials told us that because there is no agreement among
disability groups on what the best practices are for special needs
students in an emergency, districts usually devise their own
procedures.[Footnote 24] According to these officials, without the
recommendation of experts, some of these procedures such as keeping
special needs students in their classrooms during some emergencies may
not ensure the students safety in an emergency. The variety of
procedures was evident during our site visits when officials identified
several procedures schools use to incorporate the needs of special
needs students in their plans during an emergency. For example, school
district officials in Pinellas County, Florida, stated that in order to
evacuate special needs students during an emergency they use a buddy
system, comprised of school staff, which the district updates annually.
In contrast, officials in a Massachusetts school district said special
needs students must remain in areas of refuge inside the school
building until they are evacuated by first responders.
Develop Procedures for Recovering from an Incident. Over half of all
school districts with written emergency plans include procedures in
their plans to assist with recovering from an incident, in accordance
with recommended practices, such as by restoring district
administrative functions and resuming transportation services. (See
table 10.)
Table 10: Types of Recovery Procedures Addressed in School Districts
Written Emergency Management Plans:
Type of recovery procedure: Providing on-site trauma teams;
Estimated percentage of school districts: 64.
Type of recovery procedure: Restoring district administrative
functions;
Estimated percentage of school districts: 55.
Type of recovery procedure: Resuming transportation services;
Estimated percentage of school districts: 53.
Type of recovery procedure: Conducting damage assessments of school
buildings and grounds;
Estimated percentage of school districts: 53.
Type of recovery procedure: Locating district employees after a crisis
is over;
Estimated percentage of school districts: 49.
Source: GAO analysis of survey data.
[End of table]
Develop Procedures for the Continuation of Student Education. Few
school districts' emergency plans contain procedures for continuing
student education in the event of an extended school closure, such as a
pandemic outbreak, although it is a federally recommended practice.
Based on our survey, we estimate that 56 percent of school districts do
not include any of the following procedures (see table 11) in their
plans for the continuation of student education during an extended
school closure. Without such procedures school districts may not be
able to educate students during a school closure that could last from
several days to a year or longer. Moreover, there was no statistical
difference between the percentage of urban and rural school districts
that include these procedures in their written plans. Some school
districts we visited stated they do not have these procedures but are
currently working on developing a continuity of student education plan
with their community partners, and one district official said he would
like guidance from the state on how to provide continued instruction to
students during an extended school closure.[Footnote 25]
Table 11: Percentages of School Districts with Written Plans That
Include Certain Types of Procedures to Continue Student Educational
Instruction in the Event of an Extended School Closure:
Types of procedure to continue student educational instruction:
Electronic or human telephone trees to communicate academic information
to students;
Estimated percentage of school districts with written plans that
include procedure: 30.
Types of procedure to continue student educational instruction: Web-
based distance instruction;
Estimated percentage of school districts with written plans that
include procedure: 12.
Types of procedure to continue student educational instruction: Mailed
lessons and assignments;
Estimated percentage of school districts with written plans that
include procedure: 10.
Types of procedure to continue student educational instruction:
Academic instruction via local radio or television stations;
Estimated percentage of school districts with written plans that
include procedure: 7.
Source: GAO analysis of survey data.
Note: Responses are not mutually exclusive.
[End of table]
Determine Lessons Learned. Based on our survey of school districts, we
estimate that 38 percent of districts have emergency management plans
that contain procedures for reviewing lessons learned to analyze how
well the plans worked in responding to a drill or emergency. Of the
remaining school districts, 53 percent indicated they have procedures
but those procedures are not included in their plans and 7 percent have
no such procedures.
Develop Multi-Purpose Manuals. Some school districts have multi-purpose
manuals that contain various types of information such as roles and
responsibilities for staff, descriptions of how to respond to different
types of emergencies, as well as site specific information for
individual schools to complete in order to tailor their plan. For
example, in Lee County, North Carolina, the district manual contained a
range of materials and documents for schools to use and complete such
as floor plans, student and faculty rosters, bus routes, and evacuation
routes as well as instructions on the location and handling of
utilities, such as gas and water valves and electrical breaker panels
in school buildings, including a place for photographs for their easy
identification. The manual also identified different types of hazards
and delineated administrator and teacher responsibilities for different
types of emergencies. In contrast, one plan for a district in
Washington consisted of a flipchart with contact information on whom to
call during an emergency, and one plan for a district in Iowa consisted
of actions to take for various hazards but did not outline which staff
would be responsible for taking such actions.
About Half of All Districts Involved Local Government, Public Health
Agencies, and Other Partners in Developing and Updating Their Plans and
Most Reported Not Practicing with First Responders:
School districts differed in the extent to which they involve community
partner stakeholders in the development and updating of their
plans.[Footnote 26] Fewer than half of school districts with emergency
management plans involve community partners such as the local head of
government (43 percent) or the local public health agency (42 percent)
when developing and updating their emergency management plans, as
recommended by HHS.[Footnote 27] During our site visits and survey
pretests, school district officials cited a number of reasons for this
lack of involvement, including a general lack of coordination with
local government on emergency management efforts. Officials cited
several benefits in coordinating with local government entities
including the opportunity to share information, take part in joint
training exercises, and receive assistance with their emergency plans.
While most school districts include at least one representative from
the school and first responder community in the development and
updating of their emergency management plans, fewer involve community
partners. (See table 12.) According to written guidance provided by
Education, those school districts that do not include community
partners in the development and updating of their plans may limit their
opportunity to exchange information with local officials, take
advantage of local resources, and identify gaps in their plan.
We estimate that one-third of all school districts (36 percent) have
School Resource Officers (SRO) available at schools during school
hours. An SRO[Footnote 28] is a fully sworn/commissioned law
enforcement officer whose primary assignment is within the local
schools.[Footnote 29] Of those school districts that have SROs, 73
percent include procedures in their plan for involving SROs in the
event of an emergency. During our site visits, school district
officials cited several methods they use to involve SROs in preparing
for emergencies such as including them as a stakeholder in the annual
discussion to update the school-level crisis response manual including
procedures for dealing with emergencies, among others. A significantly
higher percentage of urban school districts had SROs available on
school grounds during school hours compared to rural school districts.
We estimate about 81 percent of urban school districts had SROs
available at school campuses during school hours, compared to just 16
percent of rural school districts.
Table 12: Percentage of School Districts That Involve Stakeholders in
the Development and Update of Written Emergency Management Plans:
Community Partners.
Stakeholder: Local head of government;
Estimated percentage of school districts: 43.
Stakeholder: Public health agency;
Estimated percentage of school districts: 42.
Stakeholder: American Red Cross;
Estimated percentage of school districts: 30.
First Responders.
Stakeholder: Law enforcement;
Estimated percentage of school districts: 89.
Stakeholder: Fire department;
Estimated percentage of school districts: 85.
Stakeholder: Emergency Medical Services;
Estimated percentage of school districts: 67.
School Community.
Stakeholder: Superintendent;
Estimated percentage of school districts: 97.
Stakeholder: Teachers;
Estimated percentage of school districts: 91.
Stakeholder: Building engineers;
Estimated percentage of school districts: 83.
Stakeholder: Nurses;
Estimated percentage of school districts: 76.
Stakeholder: SROs;
Estimated percentage of school districts: 42.
Source: GAO analysis of survey data.
[End of table]
More than half of all school districts with emergency management plans
report regularly updating their emergency management plans in
accordance with recommended practices. Specifically, we estimate that
52 percent of all school districts with emergency plans update these
plans at least once a year. However, 10 percent of all school districts
had never updated their plans. (See table 13.) District officials cited
several reasons for regularly updating their emergency management
plans, including (1) construction modifications or renovations to
school buildings, (2) changes to emergency contact information, (3)
procedural changes such as new drills or evacuation routes, and (4) new
legislative requirements, among others. However, some school district
officials we visited had just recently completed their plans or
reported that they had not made any changes to their plans, since they
were first developed. According to guidance provided by Education,
those school districts that do not regularly update their plans may
risk having inaccurate and outdated information in their plans, which
could lead to a delayed response during an emergency.
Table 13: Frequency of Updates to Emergency Management Plans:
Frequency of updates: At least once a year; Estimated percentage of
school districts: 52.
Frequency of updates: At least once every 2 years;
Estimated percentage of school districts: 14.
Frequency of updates: At least once every 3 or more years;
Estimated percentage of school districts: 19.
Frequency of updates: Have not updated the emergency management plan;
Estimated percentage of school districts: 10.
Frequency of updates: After an incident;
Estimated percentage of school districts: 1.
Source: GAO analysis of survey data.
[End of table]
The frequency with which districts updated their plans differed for
urban and rural areas. A significantly higher percentage of urban
school districts update their emergency management plans annually
compared to rural districtsó69 percent versus 43 percent, respectively.
Finally, as many as 13 percent of rural school districts have not
updated their emergency plans at all, compared with 3 percent of urban
school districts.
Based on our survey of school districts, we estimate that 55 percent of
school districts with written emergency management plans coordinate
them with city or county emergency response plans. A significantly
higher percentage of urban school districtsó78 percent coordinate their
plans with the local government emergency response plans as compared to
rural school districts (45 percent). For example, in one Ohio school
district, officials told us that the school district plan is a
component of the city plan in that the city will rely upon the district
to make selected school buildings available for use as shelters, if
needed in an evacuation. Likewise, officials in a district in Iowa said
that the district plan is aligned with the county plan in that, during
emergencies, the district's school buses will be used to evacuate
persons from the downtown community. Similarly, in a school district in
Massachusetts, officials said that, in coordination with the local
board of health's plan, the district's plan includes the use of the
school facilities as inoculation sites or quarantine facilities in the
event of a large-scale pandemic.
As previously discussed, most school districts identify roles and
responsibilities for first responders and involve them in developing
and updating their plans. However, based on our survey, we estimate
that 27 percent of all school districts with emergency management plans
have never trained with any first responders on how to implement the
plans, in accordance with federally recommended practices. Furthermore,
we estimate that about three-quarters of all school districts do not
regularly train (i.e., at least once a year) with each type of first
responder law enforcement, fire, or EMS on how to implement the school
district plan. (See table 14.) The reasons why school districts are not
training with first responders are not readily apparent. As we have
previously reported, involving first responder groups in training and
exercise programs can better familiarize and prepare first responders
with their roles in an emergency as well as assess the effectiveness of
a school or district's emergency plan.[Footnote 30] Without such
training, school districts and their first responder partners may be at
risk of not responding effectively during a school emergency.
Table 14: Estimated Frequency of Training with Each Type of First
Responder on How to Implement the School District Emergency Management
Plan:
Frequency of training: At least once a year;
Law enforcement: Percentage: 33;
Firefighters: Percentage: 31;
Emergency Medical Services (EMS)[A]: Percentage: 25.
Frequency of training: At least once every 2 years;
Law enforcement: Percentage: 15;
Firefighters: Percentage: 15;
Emergency Medical Services (EMS)[A]: Percentage: 11.
Frequency of training: At least once every 3 or more years;
Law enforcement: Percentage: 19;
Firefighters: Percentage: 19;
Emergency Medical Services (EMS)[A]: Percentage: 17.
Frequency of training: Never;
Law enforcement: Percentage: 33;
Firefighters: Percentage: 34;
Emergency Medical Services (EMS)[A]: Percentage: 46.
Source: GAO analysis of survey data.
Notes: All responses are mutually exclusive. Due to rounding,
percentages in each column may not sum to 100.
[A] During our site visits some officials told us that their emergency
medical service providers were part of the fire department, not a
separate entity.
[End of table]
A significantly higher percentage of urban school districts annually
train with law enforcement and firefighters on the school district
emergency plan. We estimate that nearly half of urban districts
annually train together with law enforcement (42 percent) and
firefighters (43 percent) on the school district emergency plan,
whereas less than one-quarter of rural school districts train annually
with law enforcement (23 percent) and firefighters (23 percent).
School districts report training with community partners' such as local
public health and local government entities on activities to prepare
for an emergency with similar frequency. Specifically, we estimate that
29 percent of all school districts train with community partners. As
with first responders, the reasons for the lack of training with
community partners are not readily apparent. In our work on Hurricane
Katrina, we reported that involving local community partners in
exercise programs and training could help prepare community partners
and enhance their understanding of their roles in an emergency as well
as help assess the effectiveness of a school district's emergency
plan.[Footnote 31] Without such training, school districts and their
community partners may not fully understand their roles and
responsibilities and could be at risk of not responding effectively
during a school emergency.
Training differed for urban and rural areas. A significantly higher
percentage of urban school districts train with community partners on
how to implement the school district plan compared to rural school
districtsó45 percent versus 26 percent.
Some school districts collaborate with community partners on other
aspects of emergency preparedness. For example, one component of the
Citizen Corps program--Community Emergency Response Teams--instructs
citizens on how to respond to emergencies (e.g., first aid) and
participants, in turn, provide instruction to others. An official with
the Highlands County, Florida school district said that 50 school
district employees have participated in a Community Emergency Response
Teams program. Likewise, in Olmstead Falls, Ohio, school district
officials have coordinated with the American Red Cross in conducting a
pandemic immunization drill in school facilities.
School Districts Report Challenges in Planning for Emergencies as Well
as Difficulties in Communicating with First Responders and Parents, but
No Challenges in Communicating with Students:
In planning for emergencies, many school districts face challenges
resulting from competing priorities, a lack of equipment, and limited
expertise; some school districts experience difficulties in
communicating and coordinating with first responders and parents, but
most do not have such challenges with students. Within their own
districts, officials struggle to balance activities related to
educating their students with those related to recommended practices
for emergency management. Officials also confront a shortage of
equipment and expertise necessary for planning and responding to
emergencies. In some cases, officials noted that it was particularly
challenging to plan for special needs students in the absence of such
equipment and expertise. Less prevalent among school districts were
problems in communicating and coordinating with first responders and
parents.
Competing Priorities, Lack of Equipment, and Limited Expertise Are
Obstacles to Implementing Recommended Practices in Emergency Management
Planning:
School district officials who responded to our survey reported
difficulty in following the recommended practice of allocating time to
emergency management planning, given the higher priority and competing
demand on their time for educating students and carrying out other
administrative responsibilities. Based on our survey of school
districts, we estimate that in 70 percent of all districts, officials
consider competing priorities to be a challenge to planning for
emergencies. In at least two districts we visited, officials said that
they have a limited number of staff development days[Footnote 32] and
they want to use the time to train staff on instruction rather than
emergency planning. For example, in one Florida district, officials
noted that only two days a year were available for staff development,
making it difficult to cover emergency planning as well as federal and
state requirements for schools. Officials in a North Carolina district
said although they had the instructors they needed, they forfeited some
emergency planning activities after the allotted number of staff
development days were cut short.
In an estimated 62 percent of districts, officials cited a lack of
equipment and expertise as impediments to emergency planning. In the
course of our site visits, officials focused primarily on shortages of
three types of equipment: equipment to control or monitor school
grounds, such as locks on doors and surveillance equipment; equipment
to evacuate or maintain a shelter-in-place for students and staff; and
communications equipment, such as two-way radios and satellite phones.
Officials in one Massachusetts school district reported that they do
not have adequate locks on some of the doors to school buildings to
implement a lockdown procedure, for example. Other districts lacked
fencing for school grounds or surveillance cameras for school
buildings. Officials also described a lack of sufficient equipment to
maintain a shelter-in-place or evacuate students. Five of the 27 school
districts we interviewed reported that they do not have generators to
maintain power in school buildings. One superintendent in Washington
noted that the district's only school building is located in a remote
mountainous area that could be inaccessible in the event of an
earthquake or heavy snowfall that blocked the few access roads in and
out of the community. Yet, according to this superintendent, the
district does not have a generator to supply electricity in the event
of such an emergency. Although the officials in one Massachusetts
school district did not report problems maintaining a shelter-in-place
facility, they said the district did not have enough school buses to
accommodate all of the students in the case of evacuation. Finally,
school officials in the districts we visited discussed a lack of
equipment to facilitate communication during emergencies. In one North
Carolina district, officials said a lack of two-way radios for staff in
the elementary schools hinders their ability to communicate with one
another and with first responders during an emergency.[Footnote 33]
Similarly, in one Washington school district, the superintendent told
us the district does not have satellite two-way radios that are needed
in case conventional cellular telephones do not operate under the
severe weather conditions common to the remote and mountainous
location. In a district in Iowa, officials reported a need to replace
their aging two-way radios because the radios' signals cannot penetrate
the walls of the school buildings. Officials in four additional
districts stated that their districts need to update or maintain
communication equipment. As demonstrated in these school districts, the
lack of equipment prevents districts from implementing the procedures
in their plans and hinders communication among district staff and with
first responders during emergencies.
In addition to not having sufficient equipment, school district
officials we spoke with described a shortage of expertise in both
planning for and managing emergencies. These officials said their
districts lacked specialized personnel and training with which to
develop needed expertise. One Washington state superintendent said he
needed to provide those staff most likely to be present in an emergency
with training on emergency management but would need additional funding
to do so. District officials in 5 of the 27 districts noted that they
do not having sufficient funding to hire full-time emergency management
staff to provide such training or take responsibility for updating
their district plans.[Footnote 34] Still, other officials described an
unmet need for specific staff positions such as either an SRO or a
school nurse to assist in planning for and responding to emergencies.
According to officials in a North Carolina district, due to a shortage
of funding, the district did not have SROs for the district's
elementary schools. In this district, the SROs have a role in providing
comments on the emergency plans of the schools to which they are
assigned before those plans are submitted to the district for annual
reviews. Similarly, officials in the Lee County district of North
Carolina reported a shortage of school nurses, which they said could
precipitate a medical crisis in an evacuation on days when a nurse is
not available to distribute student medications or attend to those who
may become ill. These officials noted that the lack of expertise makes
it difficult to adequately plan for responding to emergencies.
As previously discussed, school districts reported challenges in
incorporating special needs students in emergency management planning.
According to officials in about half (13 of 27) of the districts in
which we conducted interviews, a lack of equipment or expertise poses
challenges for districts--particularly in the area of evacuating
special needs students. In one Massachusetts school district, while
schools assign persons to special needs students for evacuations,
officials reported that these persons or "buddies" are typically other
students, rather than experienced personnel.[Footnote 35] The students
may not always be in the same classes as the students to whom they are
assigned or may be absent from school on the day of the emergency. An
official in a Washington school district said that the district tracks
the location of special needs students, but many of the district's
schools do not have evacuation equipment (e.g., evacuation chairs used
to transport disabled persons down a flight of stairs) to remove
students from buildings and staff need more training on how to operate
the existing equipment. Lee County, North Carolina, district officials
reported that a shortage of nurses across the district has led to
difficulties in meeting the medical needs of special needs students
during evacuations, because nurses are the only staff permitted to
physically remove medical supplies and distribute medicine. Because
coordination with first responders often occurs at the district level,
delegating responsibility for planning for special needs students to
individual schools can result in a lack of information for first
responders. In one school district in Ohio, a fire department official
we interviewed was unaware that the schools in his area had assigned
special aides to help evacuate special needs students.
School district officials who reported challenges in planning for
special needs students also identified challenges in adequately
planning for temporarily disabled students (e.g., a student with a
broken leg), maintaining a supply of surplus medical supplies for
students with special needs, and ensuring the district maintains
privacy standards related to the conditions of special needs students
during emergencies. Finally, officials in three school districts stated
that the districts' school buildings are not all in compliance with the
Americans with Disabilities Act standards,[Footnote 36] thus limiting
the district's ability to adequately plan for students with special
needs.
Some School Districts Reported Difficulty in Communicating and
Coordinating with First Responders and Parents:
Based on our survey of school districts, an estimated 39 percent of
districts with emergency plans experience challenges in communicating
and coordinating with local first responders.[Footnote 37]
Specifically, these school districts experience a lack of partnerships
with all or specific first responders, limited time or funding to
collaborate with first responders on plans for emergencies, or a lack
of interoperability between the equipment used by the school district
and equipment used by first responders.
The superintendent of a Washington school district said that law
enforcement has not been responsive to the district's requests to
participate in emergency drills, and, in addition to never having had a
district wide drill with first responders, competition among city,
county, and private first responders has made it difficult for the
school district to know with which first responder entity it should
coordinate. In another Washington district, the superintendent reported
not having a local law enforcement entity in the community, but rather,
a deputy from the county sheriff's department that drives through the
local community twice a day. This superintendent said that based on an
absence of a relationship with law enforcement, he assumed that his
district was essentially "on its own" in responding to emergencies.
According to guidance provided by Education, the lack of partnerships,
as demonstrated in these school districts, can lead to an absence of
training that prevents schools and first responders from understanding
their roles and responsibilities during emergencies.
Even when forming partnerships is not a problem, school districts may
be unable to find sufficient time or funding to meet with first
responders on issues related to emergency management planning. An
official in the Chatham, North Carolina, district said that it is
difficult to find a convenient time for both first responders and
school district officials to meet and discuss the district's plan.
According to an official in the Seattle school district, first
responders for the district are more likely to meet with the school
district when there are funds available to pay both first responders
and district staff for such efforts. Officials in an Ohio district said
that while first responders drill in school facilities over the
weekends, the district does not have additional funding or staff to
conduct these drills during school hours.
Finally, officials we interviewed described a lack of interoperable
equipment as a hindrance to communicating with first responders during
emergencies. In 8 of the 27 districts in which we conducted interviews,
officials said that the two-way radios or other equipment used in their
school districts lacked interoperability with the radios used by first
responders. Officials in an Iowa district said that the lack of
interoperability among first responders[Footnote 38] impacts the
district's ability to communicate during emergencies because the
district shares a radio frequency with some first responders but not
others.
School Districts Have Methods to Communicate with Parents, but Face
Challenges in Ensuring Parents Receive Consistent Information during
Incidents:
In keeping with recommended practices that call for school districts to
have a way to contact parents of students enrolled in the district, all
of the school districts we interviewed had ways of communicating
emergency procedures to parents prior to (e.g., newsletters), during
(e.g., media, telephone), and after an incident (e.g., letters). Eleven
of these districts have a system that can send instant electronic and
telephone messages to parents of students in the district. Despite
these methods, 16 of the 27 districts we interviewed experience
difficulties in implementing the recommended practice that school
districts communicate clear, consistent, and appropriate information to
parents regarding an emergency. For example, officials in a Florida
school district said that with students' increased access to cellular
telephones, parents often arrive on school grounds during an incident
to pick up their children before the district has an opportunity to
provide parents with information. Thus, according to these officials,
the district experiences challenges in simultaneously maintaining
control of both the emergency situation and access to school grounds by
parents and others. Other districts discussed challenges in providing
messages, during emergencies, with instructions to parents for
reuniting with their children. Officials in the Boston school district
said that having inaccurate telephone numbers for parents prevented the
district from delivering messages to all parents during or after
emergencies. Representatives of three education associations[Footnote
39] also noted that school districts have much to do to ensure that
their emergency management efforts diffuse confusion during emergencies
and provide parents with consistent information.
Based on our survey of school districts, an estimated 39 percent of all
school districts provide translators to communicate with LEP parents
during emergencies, but fewer--an estimated 23 percent of all
districts--provide translations of emergency management materials.
Officials in 8 of the 27 districts we interviewed discussed challenges
in retaining bilingual staff to conduct translations of the districts'
messages or in reaching parents who do not speak the languages or
dialects the district translates. In Seattle, where the district
provides translations of 10 of the 47 languages spoken in the schools,
the official we interviewed said that staff often experience "burn out"
due to their dual roles as interpreters and liaisons between the local
community and school district. The problem in retaining bilingual staff
was not related to the level of work required by interpreters in the
Hardee County, Florida, school district, but with the district's
inability to recruit qualified bilingual staff who also want to reside
in the rural, hurricane-prone community. In two different districts,
officials were unsure of whether the district's emergency messages
reached parents who did not speak the translated languages provided by
the school district. Officials in the Pinellas County school district
said that they were unsure about the district's success in getting
emergency management information to parents who speak 1 of the 107
languages for which the district does not provide translations.
Difficulties in accommodating dialects was also cited by an official of
the Ashtabula, Ohio, school district because staff there have
encountered problems ensuring the messages translated by telephone were
understood due to the differences in dialects of Spanish spoken by some
parents and the school officials providing the translated message. Our
findings, while limited to the districts in which we conducted
interviews, are consistent with the observations of some national
education groups that have indicated that districts, in part due to
limited funding, struggle to effectively communicate emergency-related
information to this population of parents.
While school districts experience a range of challenges in planning for
emergencies and in communicating and coordinating with first responders
and parents, officials in all but one of the districts in which we
conducted interviews said that the district did not have problems
communicating emergency procedures to students. While some of these
officials did not provide reasons, as we previously reported, most
districts regularly practice their emergency management plans with
their students and staff.
Conclusions:
While emergency management is overwhelmingly a state and local
responsibility, the federal government plays a critical role in
disseminating information on best practices, providing guidance, and
giving states flexibility to target federal funding to areas of
greatest need. While all three federal agencies involved in emergency
management planning for schools have provided some resources,
additional access to federal resources would enhance the ability of
school districts to plan and prepare for emergencies. Given the
challenges many school districts face due to a lack of necessary
equipment and expertise, they do not have the tools to support the
plans they have in place and, therefore, school districts are left with
gaps in their ability to fully prepare for emergencies. Making it clear
to states and local governments that school districts are among the
entities to which they may disburse certain grant funds they have
received from DHS would be one way to diversify the available emergency
management resources to which school districts have access.
School districts have taken a number of important steps to plan for a
range of emergencies, most notably developing emergency management
plans; however, in many districts these plans or their implementation
do not align with federally recommended practices. For example, because
most districts' plans do not have procedures to ensure the continuity
of education in the event of extended school closures, such as those
caused by a pandemic or natural disasters, school districts, both urban
and rural, are largely not prepared to continue their primary mission
of educating students. Unless the federal government examines
strategies for planning for on-going student instruction in the event
of extended school closures and determines which of those strategies
are successful, schools may not have the information they need to put
in place a plan that will adequately prepare them for emergencies that
require such a response. In addition, while most districts have
procedures for special needs students in place, because there is no
agreement on procedures school districts should use with such students,
districts may employ less than optimal or even risky procedures for
evacuating or sheltering these students in an emergency. Further, while
the reasons are not readily apparent and can vary as to why school
districts do not train with first responders and community partners, by
not training together, school districts, first responders, and
community partners may limit their ability to effectively respond to
and mitigate the impact of emergencies when they occur. If the federal
government had information on why school districts do not train with
first responders and community partners, it would be better positioned
to provide assistance to school districts that would enable them to
train with first responders and community partners on a regular basis.
Finally, our findings show that in some areas there are vast
differences in how urban and rural districts prepare for emergencies
and it appears that urban districts are taking more actions as
suggested by recommended practices to prepare for incidents. It may not
be possible for urban and rural school districts to plan equally given
differences in geography, resources, expertise, and other demographics
that may warrant different approaches. However, it is important that
all districts include key procedures, cover the full range of incidents
that could affect them, and practice their plans to prepare for
emergencies because some incidents, such as natural disasters, may
impact urban and rural districts alike.
Recommendations for Executive Action:
To help address the challenges school districts face in planning for
emergencies, we recommend that the Secretary of DHS clarify that school
districts are among those entities to which state and local governments
may disburse grant funds received through the State Homeland Security
Program, Urban Areas Security Initiative, and Citizens Corps grant
programs. This should be done through its guidance for these programs
so that states and local governments will know they can disburse these
program funds to school districts.
To address the lack of procedures for continuing student education in
the event of an extended school closure, we recommend that the
Secretary of Education collaborate with the Secretary of HHS in his
role as head of the lead agency on pandemics, to examine and identify
successful strategies for developing such procedures and provide
guidance to school districts on how to include the resulting procedures
for the continuation of student education in their emergency management
plans. These agencies may consider providing specific suggestions for
states and districts to work with state education agencies, health
departments, and local community organizations in the process of
developing these procedures.
To help school districts shelter or evacuate students with special
needs and temporarily disabled students in an emergency, we recommend
that the Secretary of Education, in collaboration with the Secretaries
of DHS and HHS, examine and identify successful procedures for
sheltering and removing such students from school buildings and share
these procedures with school districts.
To promote training between school districts and first responders and
between school districts and community partners on how to implement
district emergency management plans, we recommend that the Secretaries
of DHS and Education identify the factors that prevent school
districts, first responders, and community partners from training
together and develop strategies for addressing those factors. These
strategies should include the continued use of any current resources
that could facilitate joint training. DHS and Education should share
the strategies with school districts, first responders, and community
partners and encourage them to consider implementing the strategies as
appropriate.
Agency Comments and Our Evaluation:
We provided a draft of this report to DHS, Education, and HHS for
review and comment. DHS provided written comments on May 16, 2007,
which are presented in appendix V. In commenting on the draft report,
DHS generally agreed with the intent of our first recommendation that
it clarify that school districts are eligible entities to which states
and local governments may disburse emergency management funding. While
the department stated that it would continue to alert states and local
governments of school districts' eligibility through such activities as
site visits and workshops, it did not comment on whether it would
modify its program guidelines. Taking the opportunity to remind states
and local governments of school districts' eligibility in such one-on-
one settings should help to increase awareness of school districts'
eligibility. However, we continue to believe that DHS should explicitly
include school districts in its program guidance, so that all state and
local governments receiving homeland security funds would have access
to guidance that provides a clear understanding of how to use the
funding. DHS disagreed with the language in our fourth recommendation
that the department collaborate with Education to identify and address
the factors that prevent training among school districts, first
responders, and community partners. DHS suggested that we modify the
recommendation to acknowledge the need for DHS and Education to promote
current resources in addressing these factors. We agree with DHS's
suggestion and have revised the recommendation to recognize the need
for DHS and Education to promote current resources. DHS also suggested
that we include a discussion of the Citizen Corp Council in the report
as a resource for collaboration among local governments, the private
sector, and non-profit entities including school districts. We agree
and have revised the report to include information on the Citizen Corp
Council.
Education provided written comments on May 7, 2007, which are included
in appendix VI. Education agreed with all four of our recommendations,
but expressed concern about our statement that there are no federal
requirements for school districts to have emergency management plans,
pointing to a requirement in the No Child Left Behind Act (NCLBA)
relating to safe and drug-free schools. As we explain in the report, we
did not consider plans required under NCLBA to be emergency management
plans for purposes of our report because these plans are not required
to address multiple hazards. While Education acknowledged that we had
included this information in a footnote, it stated that the footnote
appeared only once. We have revised the report to more prominently
display this information.
HHS provided written comments on our draft report on May 8, 2007, which
are presented in appendix VII. HHS generally agreed with our
recommendations. However, HHS requested that Education take the lead
with respect to our second recommendation that both agencies provide
guidance to school districts on the continuation of education during
extended school closures because Education is responsible for leading
federal efforts related to the education process. We discussed the
issue with Education officials and they agreed to take the lead on this
recommendation. Thus, we modified the recommendation accordingly. HHS
also requested that we include it in our third recommendation to
provide guidance on evacuating and sheltering special needs students
because of the agency's expertise on special needs students. We agree
and have modified the recommendation to include HHS.
DHS, Education, and HHS also provided technical comments, which we
incorporated where appropriate.
We are sending copies of this report to the Secretaries of Education,
DHS, HHS, and relevant congressional committees. We will also make
copies available to others upon request. In addition, the report will
be made available at no charge on GAO's Web site at http://www.gao.gov.
Please contact us at (202) 512-7215 or (202) 512-8757 if you or your
staff have any questions about this report. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Major contributors are listed in appendix
VI.
Signed by:
Cornelia M. Ashby, Director:
Education, Workforce and Income Security Issues:
Signed by:
William O. Jenkins, Jr., Director:
Homeland Security and Justice Issues:
[End of section]
Appendix I: Scope and Methodology:
To obtain information on federal, state, and local roles and
requirements for school districts, how school districts prepare and
plan, and any challenges in doing so, we interviewed staff in the
Departments of Education, Homeland Security, and Health and Human
Services; conducted an e-mail survey of state education agencies and an
e-mail survey of state administering agencies; and conducted a mail
survey of school districts from a stratified random sample of public
school districts. We also conducted site visits during which we
interviewed district officials, security administrators, and other
officials in 27 school districts in six states. We conducted our work
from April 2006 through March 2007 in accordance with generally
accepted government auditing standards.
Survey of States:
To better understand the role of states in how school districts prepare
for emergencies, we designed and administered two surveys--one to state
education agencies and a separate, but similar, one to state
administering agencies--to all 50 states and the District of Columbia.
The survey to state education agencies was conducted between August
2006 and October 2006. The survey included questions about laws that
require school districts to have emergency management plans, state
funding provided to school districts, and any other resources provided
to school districts. The survey of state administering agencies was
conducted between November 2006 and January 2007. The survey also
included questions about laws requiring school districts to have
emergency management plans, state funding provided to school districts,
and other resources. In this survey we specifically asked about whether
the state allocated portions of the State Homeland Security Program
(SHSP), Urban Areas Security Initiative (UASI), and Citizen Corps
grants to school districts. In 19 states, there were no UASI funds
provided and we did not ask about funding related to this program for
those states.
The practical difficulties of conducting any survey may introduce
nonsampling errors, such as variations in how respondents interpret
questions and their willingness to offer accurate responses. We took
steps to minimize nonsampling errors, including pretesting draft
instruments and following up on specific responses. Specifically,
during survey development, we pretested draft instruments with various
officials. For the survey to state administering agencies, we pretested
with officials representing state administering agencies in California
and Maryland in November 2006. In the pretests, we were generally
interested in the clarity of the questions and the flow and layout of
the survey. For example, we wanted to ensure definitions used in the
surveys were clear and known to the respondents, categories provided in
closed-ended questions were complete and exclusive, and the ordering of
survey sections and the questions within each section was appropriate.
We analyzed the requirements for schools and districts to have
emergency management plans that were reported to us by states. In some
cases, we determined that the laws or other requirements reported in
these surveys did not constitute emergency management planning
requirements for purposes of this report. Accordingly, these survey
responses are not included in our analysis of state requirements. We
did not conduct any independent legal research to identify state legal
requirements in this area.
Survey of School Districts:
To obtain national-level information on school district management
planning, we administered a mail survey to a stratified random sample
of public school districts. The survey was conducted between September
2006 and January 2007. To obtain the maximum number of responses to our
survey, we sent a follow-up mailing with the full survey instrument to
nonrespondents approximately 3 weeks after the initial mailing, and a
reminder postcard to nonrespondents approximately 4 weeks after the
initial mailing of the survey instrument. The survey included questions
about whether school districts had emergency management plans,
activities related to emergency management plans, characteristics of
plans, district requirements of schools, and coordination with various
persons in the school environment, local community, and first
responders.
Population:
The target population of 14,432 districts consisted of public school
districts in the 50 states and the District of Columbia with at least
one school in each of their jurisdictions in the 2003-2004 school
year.[Footnote 40] We used Education's Common Core of Data (CCD) Local
Education Agency (School District) file for the 2003-2004 school year
(version 1b) as the basis of defining our population. To define our
sampling frame, we removed districts from the CCD that were not a
component of a supervisory union; state and federally-operated
institutions; other education agencies; had less than 1 student; were
closed; run by the Department of Defense or Bureau of Indian Affairs;
or located in American Samoa, Guam, Northern Marianas, Puerto Rico, or
the Virgin Islands. On the basis of our review of these data, we
determined this source to be adequate for the purposes of our work.
Sample Design and Errors:
The sample design for the mail survey was a stratified random sample of
districts with two certainty strata containing all of the urban and
urban fringe districts with over 100,000 students. We defined the
strata classifications using the locale code in the CCD. We chose
districts with the largest number of students with certainty because
the total number of students in these districts makes up nearly 13
percent of the total students in our universe. We also included four
additional strata--urban, urban fringe, towns, and rural. Table 15
provides a description of the universe and sample of districts.
Table 15: Description of the Population and Sample of Districts:
Stratum: Large urban;
Population/universe: 12;
Sample size: 12.
Stratum: Large urban fringe;
Population/universe: 14;
Sample size: 14.
Stratum: Urban;
Population/universe: 860;
Sample size: 125.
Stratum: Urban fringe;
Population/universe: 3,795;
Sample size: 135.
Stratum: Town;
Population/universe: 1,785;
Sample size: 132.
Stratum: Rural;
Population/universe: 7,966;
Sample size: 136.
Stratum: Total;
Population/universe: 14,432;
Sample size: 554.
Source: GAO.
[End of table]
We used the metro-centric locale codes assigned to each district in the
03-04 CCD to define urban and rural. We defined urban districts to be
those districts within a central city of a Core Based Statistical Area
or Consolidated Statistical Area (locale codes 1 and 2). Generally,
those are considered to be a central city of a Core Based Statistical
Area (CBSA) or Consolidated Statistical Area (CSA), with the city
having a population greater than or equal to 250,000 (for locale code
1) or a central city of a CBSA or CSA, with the city having a
population less than 250,000 (for locale 2). Rural districts are any
incorporated place, Census-designated place, or non-place territory and
defined as rural by the Census Bureau (locale codes 7 and 8). These are
generally defined as any incorporated place, Census-designated place,
or non-place territory not within a CBSA or CSA of a large or mid-size
city and defined as rural by the Census Bureau; and any incorporated
place, Census-designated place, or non-place territory within a CBSA or
CSA of a large or mid-size city and defined as rural by the Census
Bureau.
Because we surveyed a sample of districts, our results are estimates of
a population of districts and thus are subject to sampling errors that
are associated with samples of this size and type. Our confidence in
the precision of the results from this sample is expressed in 95
percent confidence intervals, which are expected to include the actual
results in 95 percent of the samples of this type. We calculated
confidence intervals for this sample based on methods that are
appropriate for a stratified random sample. We determined that nine of
the sampled districts were out of scope because they were not
considered to be school districts. All estimates produced from the
sample and presented in this report are for the estimated target
population of 14,131 districts with at least one school in the 2003-
2004 school year. All percentage estimates included in this report have
margins of error of plus or minus 10 percentage points or less, unless
otherwise noted.
We took steps to minimize nonsampling errors that are not accounted for
through statistical tests, like sampling errors. In developing the mail
survey, we conducted several pretests of draft instruments. We
pretested the survey instrument with district officials in six
districts--Baltimore County, Maryland; Carbon County, Wyoming; Citrus
County, Florida; Muleshoe Independent, Texas; Santa Fe Public Schools,
New Mexico; and Vigo County, Indiana--between July 25, 2006, and August
18, 2006. On the basis of the pretests, the draft survey instrument
underwent some revisions.
Response Rate:
We received survey responses from 444, or 80 percent, of the 554 school
districts in the sample.
Site Visits:
To understand emergency management planning at the local level, we
conducted site visits and conducted interviews in six states between
September 27, 2006, and November 15, 2006. The states we visited
included Florida, Iowa, Massachusetts, North Carolina, Ohio, and
Washington. In each state, to the extent possible, we visited or
interviewed (by telephone) at least one district that corresponded to
the strata in our survey of school districts. We selected states and
school districts that included recommended practices, some that did and
did not receive federal funding for emergency management, both urban
and rural districts, and those representing geographic diversity. When
viewed as a group, the states and school districts also provided
variation across characteristics such as geographic location, district
size, student populations, and the percentage of students with Limited-
English proficiency or disabilities. We conducted a pretest of
questions used in the site visits with the Alleghany County Public
Schools district, in Maryland, on September 13, 2006. We used this
interview to determine whether our interview questions were clear as
well as to gauge the amount of time the interviews would take.
In total, we interviewed officials in 27 school districts. Through our
interviews with district officials, we collected information on the
role of the school district in emergency management planning, state or
local requirements, whether the district received federal, state, or
local funding and guidance, and experiences in communicating and
coordinating with first responders, parents, and students. Table 16
indicates the school districts we visited during site visits or
interviewed, the corresponding locale code, and other selected
characteristics.
Table 16: School Districts Interviewed or Visited during Site Visits:
Florida.
District: Pinellas County School District;
Common Core of Data Locale Code: 2 (urban);
Number of schools: 174;
Number of students: 113,651;
Number of students categorized as Limited-English Proficient (LEP):
3,204.
District: Hillsborough County School District;
Common Core of Data Locale Code: 3 (urban fringe);
Number of schools: 258;
Number of students: 189,469;
Number of students categorized as Limited-English Proficient (LEP):
19,686.
District: Hardee County School District;
Common Core of Data Locale Code: 6 (town);
Number of schools: 9;
Number of students: 5,146;
Number of students categorized as Limited-English Proficient (LEP):
450.
District: Highlands County School District;
Common Core of Data Locale Code: 7 (rural);
Number of schools: 18;
Number of students: 12,049;
Number of students categorized as Limited-English Proficient (LEP):
517.
Washington.
District: Seattle School District;
Common Core of Data Locale Code: 1 (urban);
Number of schools: 111;
Number of students: 46,746;
Number of students categorized as Limited-English Proficient (LEP):
5,752.
District: Renton School District;
Common Core of Data Locale Code: 2 (urban);
Number of schools: 26;
Number of students: 13,236;
Number of students categorized as Limited- English Proficient (LEP):
1,485.
District: Sequim School District;
Common Core of Data Locale Code: 6 (town);
Number of schools: 5;
Number of students: 2,950;
Number of students categorized as Limited- English Proficient (LEP):
48.
District: Skykomish School District;
Common Core of Data Locale Code: 8 (rural);
Number of schools: 2;
Number of students: 70;
Number of students categorized as Limited-English Proficient (LEP): 2.
District: Index School District;
Common Core of Data Locale Code: 8 (rural);
Number of schools: 1;
Number of students: 30;
Number of students categorized as Limited- English Proficient (LEP): 0.
Iowa.
District: Des Moines Independent Community School District;
Common Core of Data Locale Code: 2 (urban);
Number of schools: 72;
Number of students: 32,194;
Number of students categorized as Limited-English Proficient (LEP):
3,502.
District: West Des Moines Community School District;
Common Core of Data Locale Code: 4 (urban fringe);
Number of schools: 15;
Number of students: 8,491;
Number of students categorized as Limited-English Proficient (LEP):
246.
District: Marshalltown Community School District;
Common Core of Data Locale Code: 5 (town);
Number of schools: 9;
Number of students: 4,922;
Number of students categorized as Limited-English Proficient (LEP):
1,203.
District: Bondurant-Farrar Community School District;
Common Core of Data Locale Code: 8 (rural);
Number of schools: 2;
Number of students: 1,042;
Number of students categorized as Limited-English Proficient (LEP): 0.
Massachusetts.
District: Boston Public Schools;
Common Core of Data Locale Code: 1 (urban);
Number of schools: 136;
Number of students: 57,742;
Number of students categorized as Limited-English Proficient (LEP):
9,789.
District: Holliston Public Schools[A];
Common Core of Data Locale Code: 3 (urban fringe);
Number of schools: 4;
Number of students: 3,035;
Number of students categorized as Limited-English Proficient (LEP): 1.
District: Hanover Public School District;
Common Core of Data Locale Code: 3 (urban fringe);
Number of schools: 5;
Number of students: 2,809;
Number of students categorized as Limited-English Proficient (LEP): 2.
District: Greenfield Public Schools;
Common Core of Data Locale Code: 6 (town);
Number of schools: 7;
Number of students: 1948;
Number of students categorized as Limited-English Proficient (LEP): 91.
District: Mashpee Public School System;
Common Core of Data Locale Code: 8 (rural);
Number of schools: 3;
Number of students: 2,108;
Number of students categorized as Limited-English Proficient (LEP): 6.
North Carolina.
District: Durham City Schools;
Common Core of Data Locale Code: 2 (urban);
Number of schools: 45;
Number of students: 30,955;
Number of students categorized as Limited- English Proficient (LEP):
2,925.
District: Wake County Schools;
Common Core of Data Locale Code: 3 (urban fringe);
Number of schools: 132;
Number of students: 114,568;
Number of students categorized as Limited-English Proficient (LEP):
6,777.
District: Lee County Schools;
Common Core of Data Locale Code: 6 (town);
Number of schools: 12;
Number of students: 9,242;
Number of students categorized as Limited- English Proficient (LEP):
1,104.
District: Granville County Schools;
Common Core of Data Locale Code: 7 (rural);
Number of schools: 14;
Number of students: 8,674;
Number of students categorized as Limited-English Proficient (LEP):
452.
District: Chatham County Schools[A];
Common Core of Data Locale Code: 8 (rural);
Number of schools: 15;
Number of students: 7,404;
Number of students categorized as Limited-English Proficient (LEP):
1,004.
Ohio.
District: Cleveland Municipal Schools;
Common Core of Data Locale Code: (1) urban;
Number of schools: 122;
Number of students: 64,670;
Number of students categorized as Limited-English Proficient (LEP):
3,119.
District: Shaker Heights Schools;
Common Core of Data Locale Code: 3 (urban fringe);
Number of schools: 9;
Number of students: 5,737;
Number of students categorized as Limited-English Proficient (LEP): 79.
District: Ashtabula Area City Schools[A];
Common Core of Data Locale Code: 6 (town);
Number of schools: 12;
Number of students: 4,492;
Number of students categorized as Limited-English Proficient (LEP):
145.
District: Olmsted Falls City Schools;
Common Core of Data Locale Code: 8 (rural);
Number of schools: 4;
Number of students: 3,388;
Number of students categorized as Limited-English Proficient (LEP): 12.
Source: Common Core Data.
[A] We interviewed these officials by telephone.
[End of table]
[End of section]
Appendix II: Emergency Management Planning Requirements:
Table 17: States Reporting Selected Requirements for School Districts
or Schools for Emergency Management Planning:
State[A]: Alabama;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Alaska;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
X[D];
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: X.
State[A]: Arizona; State requirement for school districts or schools to
have emergency management plans: X[E];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Arkansas;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: California;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process: X;
Planning requirements: First responders[B] involvement in the planning
process: X[F];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Colorado;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Connecticut;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Delaware;
State requirement for school districts or schools to have emergency
management plans: X[E];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: District of Columbia;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Florida;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Georgia;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process: X;
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: X.
State[A]: Hawaii;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Idaho;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Illinois;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: X[G];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Indiana;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Iowa;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Kansas;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Kentucky;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Maine;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: X.
State[A]: Maryland;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: X.
State[A]: Massachusetts;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Michigan;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Minnesota;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process: X;
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: X.
State[A]: Mississippi;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Missouri;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Montana;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Nebraska;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Nevada;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process: X;
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: X.
State[A]: New Hampshire;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: New Jersey;
State requirement for school districts or schools to have emergency
management plans: X[E];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: X.
State[A]: New Mexico;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process: X;
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: X.
State[A]: New York;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: North Carolina;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: North Dakota;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Ohio;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process: X;
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Oklahoma;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Oregon;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Pennsylvania;
State requirement for school districts or schools to have emergency
management plans: X[E];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: X*.
State[A]: Rhode Island;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process: X;
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: South Carolina;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: South Dakota;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Tennessee;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Texas;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Utah;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process: X;
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: X.
State[A]: Vermont;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: X;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Virginia;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans: X;
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: X;
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Washington;
State requirement for school districts or schools to have emergency
management plans: X[E];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Wisconsin;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: West Virginia;
State requirement for school districts or schools to have emergency
management plans: [Empty];
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: [Empty];
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Wyoming;
State requirement for school districts or schools to have emergency
management plans: X;
Planning requirements: Specific hazards to be included in plans:
[Empty];
Planning requirements: Review or update of plans by the school district
or some other entity: [Empty];
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: X;
Planning requirements: Parent involvement in the planning process:
[Empty];
Planning requirements: First responders[B] involvement in the planning
process: [Empty];
Planning requirements: Community partners[C] involvement in the
planning process: [Empty].
State[A]: Total;
State requirement for school districts or schools to have emergency
management plans: 32;
Planning requirements: Specific hazards to be included in plans: 18;
Planning requirements: Review or update of plans by the school district
or some other entity: 18;
Planning requirements: Requirements pertaining to drills or other
training for teachers and/or students: 21;
Planning requirements: Parent involvement in the planning process: 9;
Planning requirements: First responders[B] involvement in the planning
process: 16;
Planning requirements: Community partners[C] involvement in the
planning process: 10.
Source: GAO analysis of state education agencies' and state
administering agencies' survey responses.
[A] Neither Louisiana's SEA nor its SAA responded to our survey.
[B] For purposes of this report, we define first responders to include
fire, law enforcement, EMS, and state and local emergency management
agencies. States may define this term differently.
[C] For purposes of this report, we define community partners to
include public health entities, mental health entities, local heads of
government, transportation entities, hospitals, the Red Cross, the
faith-based community, and the business community. States may define
this term differently.
[D] Schools are required to form crisis response teams that include,
among others, a parent whose child attends the school. The emergency
management plan must include the names of these team members and their
specific job functions relating to a crisis. However, it is not clear
what role, if any, parents play in developing the emergency management
plan.
[E] The state requirement specifies that the school or district level
plan must satisfy certain minimum requirements developed by other
entities, such as the state department of education.
[F] Parents may become involved in the emergency preparedness plan
development if the school site council, otherwise tasked with plan
development, delegates planning responsibility to a school safety
planning committee.
[G] Although first responders are not required to be involved in the
development of emergency management plans, districts are required to
invite them to participate in the annual review process.
[End of table]
[End of section]
Appendix III: Homeland Security Funding Provided to School Districts:
Table 18: States That Reported Providing Homeland Security Funding
Directly to School Districts:
State: Hawaii;
Type of DHS grant awarded to states and provided to school districts:
State Homeland Security Program: X;
Type of DHS grant awarded to states and provided to school districts:
Urban Areas Security Initiative: [Empty];
Type of DHS grant awarded to states and provided to school districts:
Citizen Corps: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2003: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2004: $110;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2005: $71;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2006: [Empty].
State: Florida;
Type of DHS grant awarded to states and provided to school districts:
State Homeland Security Program: X;
Type of DHS grant awarded to states and provided to school districts:
Urban Areas Security Initiative: [Empty];
Type of DHS grant awarded to states and provided to school districts:
Citizen Corps: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2003: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2004: 120;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2005: 2,282;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2006: $2,000.
State: Florida;
Type of DHS grant awarded to states and provided to school districts:
State Homeland Security Program: [Empty];
Type of DHS grant awarded to states and provided to school districts:
Urban Areas Security Initiative: [Empty];
Type of DHS grant awarded to states and provided to school districts:
Citizen Corps: X;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2003: $34;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2004: 36;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2005: 36;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2006: 46.
State: Michigan;
Type of DHS grant awarded to states and provided to school districts:
State Homeland Security Program: X;
Type of DHS grant awarded to states and provided to school districts:
Urban Areas Security Initiative: [Empty];
Type of DHS grant awarded to states and provided to school districts:
Citizen Corps: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2003: 8,600;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2004: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2005: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2006: [Empty].
State: Mississippi;
Type of DHS grant awarded to states and provided to school districts:
State Homeland Security Program: [Empty];
Type of DHS grant awarded to states and provided to school districts:
Urban Areas Security Initiative: [Empty];
Type of DHS grant awarded to states and provided to school districts:
Citizen Corps: X;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2003: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2004: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2005: 66;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2006: 60.
State: Wyoming;
Type of DHS grant awarded to states and provided to school districts:
State Homeland Security Program: X;
Type of DHS grant awarded to states and provided to school districts:
Urban Areas Security Initiative: [Empty];
Type of DHS grant awarded to states and provided to school districts:
Citizen Corps: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2003: 386;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2004: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2005: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2006: [Empty].
State: Total;
Type of DHS grant awarded to states and provided to school districts:
State Homeland Security Program: [Empty];
Type of DHS grant awarded to states and provided to school districts:
Urban Areas Security Initiative: [Empty];
Type of DHS grant awarded to states and provided to school districts:
Citizen Corps: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2003: $9,020;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2004: $266;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2005: $2,455;
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2006: $2,106.
State: Grand total;
Type of DHS grant awarded to states and provided to school districts:
State Homeland Security Program: [Empty];
Type of DHS grant awarded to states and provided to school districts:
Urban Areas Security Initiative: [Empty];
Type of DHS grant awarded to states and provided to school districts:
Citizen Corps: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2003: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2004: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2005: [Empty];
Amount of grant funding provided to school districts during fiscal
years 2003--2006 (Dollars in thousands): Fiscal year 2006: $13,847.
Source: GAO analysis of state administering agencies' survey data.
[End of table]
Table 19: States and the District of Columbia That Reported Provided
Homeland Security Funding to School Districts through Local
Jurisdictions during Fiscal Years 2003--2006:
State: Alabama;
Type of grant: State Homeland Security Program: X;
Type of grant: Urban Areas Security Initiative: [Empty];
Type of grant: Citizen Corps: X.
State: District of Columbia;
Type of grant: State Homeland Security Program: [Empty];
Type of grant: Urban Areas Security Initiative: X;
Type of grant: Citizen Corps: [Empty].
State: Hawaii[A];
Type of grant: State Homeland Security Program: [Empty];
Type of grant: Urban Areas Security Initiative: [Empty];
Type of grant: Citizen Corps: X.
State: Minnesota;
Type of grant: State Homeland Security Program: [Empty];
Type of grant: Urban Areas Security Initiative: X;
Type of grant: Citizen Corps: [Empty].
State: Nevada;
Type of grant: State Homeland Security Program: X;
Type of grant: Urban Areas Security Initiative: X;
Type of grant: Citizen Corps: X.
State: New Jersey;
Type of grant: State Homeland Security Program: X;
Type of grant: Urban Areas Security Initiative: X;
Type of grant: Citizen Corps: [Empty].
State: North Dakota;
Type of grant: State Homeland Security Program: X;
Type of grant: Urban Areas Security Initiative: [Empty];
Type of grant: Citizen Corps: [Empty].
State: Pennsylvania;
Type of grant: State Homeland Security Program: [Empty];
Type of grant: Urban Areas Security Initiative: X;
Type of grant: Citizen Corps: [Empty].
State: South Dakota;
Type of grant: State Homeland Security Program: X;
Type of grant: Urban Areas Security Initiative: [Empty];
Type of grant: Citizen Corps: [Empty].
State: Wyoming;
Type of grant: State Homeland Security Program: [Empty];
Type of grant: Urban Areas Security Initiative: [Empty];
Type of grant: Citizen Corps: X.
Source: GAO analysis of state administering agencies' survey data.
[A] Hawaii distributed DHS funding to its state education agency, which
then provided funding to public schools in its state.
[End of table]
[End of section]
Appendix IV: Guidance, Training, and Funding States Provided to School
Districts:
Table 20: States and the District of Columbia That Reported Providing
Resources to School Districts to Assist in Emergency Management
Planning:
State: Alabama;
Guidance provided: X;
Training provided: X;
State funding provided: X.
State: Alaska;
Guidance provided: X;
Training provided: [Empty];
State funding provided: X.
State: Arizona;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Arkansas;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: California;
Guidance provided: X;
Training provided: X;
State funding provided: X.
State: Colorado;
Guidance provided: X;
Training provided: [Empty];
State funding provided: [Empty].
State: Connecticut;
Guidance provided: X;
Training provided: X;
State funding provided: X.
State: Delaware;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: District of Columbia;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Florida;
Guidance provided: X;
Training provided: [Empty];
State funding provided: [Empty].
State: Georgia;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Hawaii;
Guidance provided: X;
Training provided: [Empty];
State funding provided: X.
State: Illinois;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Idaho[A];
Guidance provided: [Empty];
Training provided: [Empty];
State funding provided: [Empty].
State: Indiana;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Iowa;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Kansas;
Guidance provided: X;
Training provided: [Empty];
State funding provided: [Empty].
State: Kentucky;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Louisiana[B];
Guidance provided: [Empty];
Training provided: [Empty];
State funding provided: [Empty].
State: Maine;
Guidance provided: X;
Training provided: X;
State funding provided: X.
State: Maryland;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Massachusetts;
Guidance provided: [Empty];
Training provided: X;
State funding provided: [Empty].
State: Michigan;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Minnesota;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Mississippi;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Missouri;
Guidance provided: X;
Training provided: X;
State funding provided: X.
State: Montana;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Nebraska;
Guidance provided: X;
Training provided: [Empty];
State funding provided: [Empty].
State: Nevada;
Guidance provided: X;
Training provided: [Empty];
State funding provided: [Empty].
State: New Hampshire;
Guidance provided: X;
Training provided: X;
State funding provided: X.
State: New Jersey;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: New Mexico;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: New York;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: North Carolina;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: North Dakota;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Ohio;
Guidance provided: X;
Training provided: X;
State funding provided: X.
State: Oklahoma;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Oregon;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Pennsylvania;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Rhode Island;
Guidance provided: X;
Training provided: [Empty];
State funding provided: [Empty].
State: South Carolina;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: South Dakota;
Guidance provided: X;
Training provided: [Empty];
State funding provided: [Empty].
State: Tennessee;
Guidance provided: X;
Training provided: X;
State funding provided: X.
State: Texas;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Utah[C];
Guidance provided: [Empty];
Training provided: [Empty];
State funding provided: [Empty].
State: Vermont;
Guidance provided: X;
Training provided: X;
State funding provided: X.
State: Virginia;
Guidance provided: X;
Training provided: [Empty];
State funding provided: [Empty].
State: Washington;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: West Virginia;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Wisconsin;
Guidance provided: X;
Training provided: X;
State funding provided: [Empty].
State: Wyoming;
Guidance provided: X;
Training provided: [Empty];
State funding provided: [Empty].
State: Total;
Guidance provided: 47;
Training provided: 37;
State funding provided: 11.
Source: GAO analysis of state administering and education agencies'
survey data.
[A] Idaho did not provide guidance, training, or state funding to
school districts for emergency management planning.
[B] Louisiana's state administering and education agencies did not
respond to our surveys.
[C] Utah did not provide guidance, training, or state funding to school
districts for emergency management planning.
[End of table]
[End of section]
Appendix V: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
May 15, 2007:
Ms. Cornelia M. Ashby:
Director:
Education, Workforce and Income Security Issues:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Mr. William O. Jenkins, Jr.
Director:
Homeland Security and Justice Issues:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Ashby and Mr. Jenkins:
Thank you for the opportunity to review and comment on the Government
Accountability Office's (GAO's) draft report GAO-07-609 entitled
Emergency Management: Most School Districts Have Emergency Management
Plans, but Would Benefit from Additional Federal Guidance.
The draft report addresses each of the three areas of inquiry, i. e.,
respective roles of Federal and State governments and school districts
in establishing requirements and providing resources to school
districts for emergency management planning; school districts' efforts
to plan and prepare for emergencies; and challenges the school
districts have experienced in planning for emergencies; and
communicating and coordinating with first responders, parents, and
students.
The data collected from school districts and States are helpful in
identifying gaps in emergency management capabilities.
Regarding readiness activities, the report includes various activities
under "planning" (planning, training, equipping, exercising, etc.) To
help determine next steps, it would be useful to know the relative
degree to which districts report that they engage in each activity. The
report does not estimate relative gaps among various shortfalls, such
as guidance/technical assistance, funding, training, and equipment.
Such estimates would help prioritize and focus next steps to address
shortfalls. GAO may wish to consider this as an area for future study.
The report states that fewer than half of school districts with
emergency management plans involve community partners in developing and
updating such plans. The report does not include the local Citizen
Corps Council as a readily-available resource for collaboration among
local government, private sector, and non-profit entities that should
also include local school districts. We recommend that this be added to
the report.
With respect to the draft report's recommendations, we concur with the
first recommendation directed the Department and request that the
second recommendation be reworded. The two recommendations for the
Department are as follows:
Recommendation 1: Clarify that school districts are among those
entities to which state and local governments may disburse grant funds
received through the State Homeland Security Program, Urban Areas
Security Initiative, and Citizens Corps (sic) grant programs.
Response: The Department of Homeland Security (DHS) will continue to re-
affirm that school districts and universities are eligible entities of
DHS State Homeland Security Grant funds based on the definition of
"local units of government" in the Conference Report accompanying the
DHS Appropriations Act of FY 2007 and the States' applicable statutes.
The Conference Report accompanying the DHS Appropriations Act of 2007
provides a definition of what the term "local units of government"
means. Specifically, a local unit of government is defined as "any
county, city, village, town, district, borough, parish, port authority,
transit authority, intercity rail provider, commuter rail system,
freight rail provider, water district, regional planning commission,
council of government, Indian tribe with jurisdiction over Indian
country, authorized Tribal organization, Alaska Native village,
independent authority, special district, or other political subdivision
of any State."
DHS will continue to clarify that school districts and universities are
eligible recipients of DHS State Homeland Security Grant funds as it
administers its preparedness grant programs. This clarification
currently occurs and will be re-emphasized during site visits,
monitoring visits, seminars, workshops, town hall meetings, etc. as
well as during day-to-day interaction and collaboration with State and
local customers.
Recommendation 2: With the Department of Education, identify the
factors that prevent school districts, first responders, and community
partners from training together and develop strategies for addressing
those factors.
Response: Nonconcur as written. Recommend that this recommendation be
revised to state: .the Secretaries of DHS and Education identify the
factors that prevent school districts, first responders, and community
partners from training together, and promote current resources (e.g.,
local Citizen Corps Councils) and the development of new strategies for
addressing those factors.
Thank you again for the opportunity to comment on this draft report and
we look forward to working with you on future homeland security issues.
Sincerely,
Signed by:
Steven J. Pecinovsky:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Appendix VI: Comments from the Department of Education:
United States Department Of Education:
Office Of Safe And Drug-Free Schools:
May 7, 2007:
Ms. Cornelia M. Ashby:
Director, Education, Workforce, and Income Security Issues:
Mr. William O. Jenkins:
Director, Homeland Security and Justice Issues:
Government Accountability Office:
441 G Street, N.W.
Washington, DC 20548:
Dear Ms. Ashby and Mr. Jenkins:
Thank you for sharing your proposed report, "Emergency Management: Most
School Districts Have Emergency Plans, but Would Benefit from
Additional Federal Guidance" (GAO-07-609), and offering us an
opportunity to comment on the draft document.
While we share your conclusion that schools and school districts face
many challenges in planning effectively for emergencies and that more
work needs to be done, we believe that the results of your recent
survey include some very positive news. The vast majority of districts
(about 95 percent) report having written emergency plans, and nearly
all of those plans address multiple hazards. About 85 percent of school
districts have developed specific requirements for school emergency
planning, and many districts are taking the important steps of
practicing their emergency management plans and reviewing and revising
those plans at least annually.
The draft report contained four recommendations for executive action.
To help address the challenges school districts face in planning for
emergencies, we recommend that the Secretary of DHS clarify that school
districts are among those entities to which state and local governments
may disburse grant funds received through the State Homeland Security
Program, Urban Areas Security Initiative, and Citizen Corps grant
programs. This should be done through its guidance for these programs
so that states and local governments will know they can disburse these
program funds to school districts.
We support the recommendation. In working with schools and school
districts around emergency management issues in the past several years,
we have observed that schools may not routinely be part of local
emergency management activities. The kind of guidance recommended by
the draft could help encourage the inclusion of school districts in
such efforts and increase their access to available funding to support
important emergency management activities.
To address the lack of procedures for continuing student education in
the event of an extended school closure, we recommend that the
Secretary of HHS, as the lead agency on pandemics, and the Secretary of
Education examine and identify successful strategies for developing
such procedures and provide guidance to school districts on how to
include the resulting procedures for the continuation of student
education in their emergency management plans. These agencies may
consider providing specific suggestions for states and districts to
work with state education agencies, health departments, and local
community organizations in the process of developing these procedures.
We agree with this recommendation. We believe that schools will play
several critical roles in the event of an outbreak of pandemic
influenza, including developing and implementing procedures for
continuing student learning in the event of an extended school closure.
We have already identified this issue as a priority. Since fiscal year
2006, we have required grantees under our Emergency Response and Crisis
Management (ERCM) grant program (which we have since renamed Readiness
and Emergency Management for Schools, or "REMS") to develop a written
plan designed to prepare the school district for a possible infectious
disease outbreak, such as pandemic influenza. Plans must include
disease surveillance, school closure decision-making processes,
business continuity issues, and continuation of educational services.
To help school districts shelter or evacuate students with special
needs and temporarily disabled students in an emergency, we recommend
that the Secretary of Education, in collaboration with the Secretary of
DHS, examine and identify successful procedures for sheltering and
removing such students from school buildings and share these procedures
with school districts.
We agree with this recommendation. Students and staff with special
needs, as well as temporarily disabled students or staff, pose special
challenges for emergency management planning, and those needs must be
explicitly addressed in developing plans, and in practicing and
updating those plans. Under the REMS program, we require that
applicants demonstrate that they have taken into consideration the
communication, transportation, and medical needs of individuals with
disabilities within their school district. Some grant sites have made
incorporating information about students and staff with special needs
an important focus of their planning and implementation efforts. We
have shared information about some of the strategies they have
developed in our training activities.
But our work with school districts has also taught us that the students
and staff with special needs have a wide range of disabilities that
require varied and specialized responses and planning actions. We look
forward to working with the Secretary of DHS on developing and sharing
procedures to shelter or evacuate students or staff with special needs
from school buildings, and remain open to a broad range of approaches
given the evolving nature of this field.
To promote training between school districts and first responders and
between school districts and community partners on how to implement
district emergency management plans, we recommend that the Secretaries
of DHS and Education identify the factors that prevent school
districts, first responders, and community partners from training
together and develop strategies for addressing those factors. DHS and
Education should share the strategies with school districts, first
responders, and community partners and encourage them to consider
implementing the strategies as appropriate.
We agree with this recommendation. The challenges that schools, first
responders, and other community partners face in collaborating to
develop, practice, and fine tune emergency management plans are
significant. Using the experience of our REMS grantees, and working
with DHS, we believe that we can identify some common barriers to this
necessary collaboration, and identify strategies that have helped some
communities increase the extent to which school emergency management
activities, involving all of the necessary partners, are a shared
responsibility.
In addition to our responses to the report's recommendations, we would
like to express concern about the impression, conveyed at the beginning
of the "Highlights" section of the draft report and repeated throughout
the draft, that there are no Federal laws requiring school districts to
have emergency management plans. While we agree that the requirements
in 20 U.S.C. Section 7114(d)(7)(D) do not require that such plans
address multiple hazards, the provisions do require that schools
districts participating in the Safe and Drug-Free Schools and
Communities Act State Grants program (which includes most school
districts in the country) submit an assurance that they have "a plan
for keeping schools safe and drug-free that includes . a crisis
management plan for responding to violent or traumatic incidents on
school grounds." In a footnote on page nine, the draft report explains
that you have made a distinction between the current Federal
requirement to have a plan and a Federal requirement to have a plan
that addresses multiple hazards. Your explanation appears only in this
one footnote, and only after the original, arguably misleading
statement has appeared several times in the draft report. We encourage
you to revise your statement in each of the places it appears in the
report. We offer the following language.
"Although the No Child Left Behind Act of 2001 requires school
districts participating in the Safe and Drug-Free Schools and
Communities Act State Grants program to submit an assurance that they
have a crisis management plan for responding to violent or traumatic
incidents on school grounds, there are no federal laws requiring school
districts to have emergency management plans that address multiple
hazards."
Under separate cover, we have transmitted some additional technical
comments that we hope will be helpful to you as you finalize the draft
report.
Again, thank you for sharing the report with us and allowing us the
opportunity to submit comments concerning your draft. I hope that you
will let me know if we can provide any clarifying information about the
comments and concerns contained in this letter, or assist in any other
way as you finalize your report on this very important issue.
Sincerely,
Signed by:
Deborah A. Price:
Assistant Deputy Secretary:
[End of section]
Appendix VII: Comments from the Department of Health & Human Services:
Department Of Health & Human Services:
Office of the Assistant Secretary for Legislation:
Washington, D.C. 20201:
May 8 2007:
Ms. Cornelia M. Ashby:
Director, Education, Workforce, And Income Security Issues:
U.S. Government Accountability Office:
Washington, DC 20548:
Dear Ms. Ashby:
Enclosed are the Department's comments on the U.S. Government
Accountability Office's (GAO) draft report entitled, "Emergency
Management: Most School Districts Have Emergency Management Plans, but
Would Benefit from Additional Federal Guidance" (GAO-07-609).
The Department appreciates the opportunity to review and comment on
this draft before its publication.
Sincerely,
Signed by:
Vincent J. Ventimiglia:
Assistant Secretary for Legislation:
General Comments Of The Department Of Health And Human Services (HHS)
On The Government Accountability Office's (GAO) Draft Report Entitled:
Emergency Management: Most School Districts Have Emergency Management
Plans, But Would Benefit From Additional Federal Guidance (GAO 07-609):
HHS Comment:
"To address the lack of procedures for continuing student education in
the event of an extended school closure, we recommend that the
Secretary of HHS, as head of the lead agency on pandemics, and the
Secretary of Education examine and identify successful strategies for
developing such procedures and provide guidance to school districts on
how to include the resulting procedures for the continuation of student
education in their emergency management plans."
HHS and Education work closely on issues related to pandemic influenza
and school closures. While HHS provides leadership on health-related
issues such as reducing disease transmission, Education leads
activities related to the educational process, including continuation
of education. Therefore, this recommendation should be rewritten to
place Education as the lead, with support from HHS.
It might be appropriate to include HHS in the recommendation on
identifying successful procedures for helping students with special
needs. CDC/NCBDDD would be able to provide expertise in this area.
Technical Comments Of The Department Of Health And Human Services (HHS)
On The Government Accountability Office's (GAO) Draft Report Entitled:
Emergency Management: Most School Districts Have Emergency Management
Plans, But Would Benefit From Additional Federal Guidance (GAO 07-609):
Throughout the report there is reference to "special needs" individuals
(students or the general population). It should be noted in the report
that the disability community throughout the nation has been involved
in reaching consensus on the definition of "special needs" for the
pending National Response Plan (NRP) which is currently under revision.
One consensus definition of special needs will help facilitate
awareness and planning for special needs populations and hopefully
result in Federal, State, and local agencies reaching out to those
populations and including them as partners in emergency planning and
response. Once the revised NRP is approved, it would be beneficial for
the school districts to adopt the NRP "special needs" definition to
ensure better awareness and preparedness in all communities and ensure
consistency throughout the nation.
[End of section]
Appendix VIII: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Cornelia M. Ashby (202) 512-7215, ashbyc@gao.gov:
William O. Jenkins, Jr. (202) 512-8757, jenkinswo@gao.gov:
Acknowledgments:
Kathryn Larin (Assistant Director), Debra Sebastian (Assistant
Director), and Tahra Nichols (Analyst-in-Charge) managed all aspects of
this assignment. Benjamin Jordan, Meaghan Marshall, and Kris Trueblood
made significant contributions to this report. Krista Anderson,
Jennifer Gregory, Lise Levie, and Paul Revesz also made contributions
to this report. Sue Bernstein and Katherine Davis contributed to
writing this report. Jim Ashley, Jean McSween, Amanda Miller, and Joan
Vogel provided key technical support. Sheila McCoy provided legal
support.
FOOTNOTES
[1] For purposes of this report, we use the term "emergency management
funding" to describe emergency preparedness funding DHS provides to
states.
[2] Under its Homeland Security Grant Program, DHS provides a range of
grants to states and local governments for emergency management. Based
on our analysis and discussions with DHS officials, the State Homeland
Security Program, Urban Areas Security Initiative, and Citizen Corps
grants are the only grants for which states and local governments can
disburse funds to school districts. The State Homeland Security Program
provides funds to enhance the emergency preparedness of state and local
governments. The Urban Areas Security Initiative grant is awarded to
some states with high threat and high density urban areas that need
planning, exercises, equipment, and training to respond to acts of
terrorism. Citizen Corps funds are provided to states to promote
volunteer efforts.
[3] In both our site visits and our survey of school districts, we
focused on the traditional definition of first responders--law
enforcement, fire, and EMS. However, the Homeland Security Act, as
amended, includes a broader definition of emergency response providers,
including "Federal, State, and local governmental and nongovernmental
emergency public safety, fire, law enforcement, emergency response,
emergency medical (including hospital emergency facilities), and
related personnel, agencies, and authorities." Homeland Security Act of
2002, Pub. L. No. 107-296, § 2, (codified at 6 U.S.C. § 101(6)).
Homeland Security Presidential Directive 8 defined the term "first
responder" as "individuals who in the early stages of an incident are
responsible for the protection and preservation of life, property,
evidence, and the environment, including emergency response providers
as defined in section 2 of the Homeland Security Act of 2002, as well
as emergency management, public health, clinical care, public works,
and other skilled support personnel (such as equipment operators) that
provide immediate support services during prevention, response, and
recovery operations."
[4] Pub. L. No. 107-296.
[5] The Robert T. Stafford Disaster Relief and Emergency Assistance
Act, Pub. L. No. 100-707, provides the legal framework for this
partnership. The Stafford Act is the principal federal statute
governing federal disaster assistance and relief and primarily
establishes the programs for and processes by which the federal
government may provide major disaster and emergency assistance to
states and local governments. The Stafford Act also provides emergency
assistance to tribal nations, individuals and qualified private non-
profit organizations. The Federal Emergency Management Agency (FEMA) is
the principal federal agency responsible for implementing the Stafford
Act.
[6] GAO, Homeland Security: Preparing for and Responding to Disasters,
GAO-07-395T (Washington, D.C.: Mar. 9, 2007); and, Catastrophic
Disasters: Enhanced Leadership, Capabilities, and Accountability
Controls Will Improve the Effectiveness of the Nation's Preparedness,
Response, and Recovery System, GAO-06-618 (Washington, D.C.: Sept. 6,
2006).
[7] 20 U.S.C. § 7114(d)(7)(D). The plans required under the No Child
Left Behind Act of 2001 are not required to address multiple hazards;
therefore, for purposes of this report, we do not consider this to be a
requirement for an emergency management plan.
[8] The purpose of the ERCM grant program is to provide funds for local
education agencies to improve and strengthen their emergency response
plans. School districts receiving grant funds under this program may
use them to develop improved plans that address all four phases of
crisis response: prevention/mitigation, preparedness, response, and
recovery. In April 2007, Education announced that it was renaming the
ERCM grant as the Readiness and Emergency Management for Schools grant
program (REMS) to reflect terminology used in the emergency management
field. This notice also invited applications for grant funds, with
Education estimating that $24 million will be available to applicants
in amounts ranging from $100,000 to $500,000 per school district. In
awarding grants, Education will give priority to districts that have
not previously received an ERCM grant and that are located in a UASI
jurisdiction. Applications must address, among other things, how
districts will coordinate their efforts with law enforcement, public
safety, public health, mental health, and local government entities, as
well as how the applicant will address the needs of individuals with
disabilities. Applicants must also agree to develop an infectious
disease plan that includes plans for continuing education services. 72
Fed. Reg. 17,139 (Apr. 6, 2007).
[9] As reported by the states to the Department of Education and
contained in the Common Core Data (CCD), there were over 17,000 school
districts in the United States in school year 2003-04. This number
includes school districts in Puerto Rico; four outlying areas (American
Samoa, Guam, Northern Marianas, and the U.S. Virgin Islands); the
Bureau of Indian Affairs and the Department of Defense, which were
eligible for funds but we excluded from the sample for our survey of
school districts. While Department of Defense schools are included in
the CCD count of school districts, Education officials said that such
schools are not eligible to receive funding under the ERCM/REMS grant
program.
[10] The Incident Command System is a standard incident management
system to assist in managing all major incidents. The Incident Command
System also prescribes interoperable communications systems and
preparedness before an incident happens, including planning, training,
and exercises. The Incident Command System was developed in the 1970s
following a series of catastrophic fires. Researchers determined that
response problems were more likely to result from inadequate management
rather than from any other reason. The Incident Command System was
designed so that responders from different jurisdictions and
disciplines could work together better to respond to natural disasters
and emergencies, including acts of terrorism. NIMS includes a unified
approach to incident management: standard command and management
structures, and emphasis on preparedness, mutual aid, and resource
management.
[11] A ninth state distributed DHS funding to its state education
agency, which then provided the funding to public schools in its state.
[12] DHS guidance for these grant programs provides that state
administering agencies are the only agencies eligible to apply for
funding and that they are responsible for disbursing grant funds to
local units of government and other designated recipients. The guidance
identifies a definition of "local unit of government" which includes
"any county, city, village, town, district, borough, parish, port
authority, transit authority, intercity rail provider, commuter rail
system, freight rail provider, water district, regional planning
commission, council of government, Indian tribe with jurisdiction over
Indian country, authorized Tribal organization, Alaska Native village,
independent authority, special district, or other political subdivision
of any State."
[13] We included the District of Columbia in our state education and
state administering agency surveys.
[14] Under Connecticut law, local boards of education, working in
conjunction, are permitted to establish regional educational services
centers, which provide programs and services to schools within their
designated regions. Conn. Gen. Stat. § 10-66a.
[15] There were 285 schools (1 school district) in Hawaii as reported
by the state to the U.S. Department of Education.
[16] An automated external defibrillator (AED) is a portable electronic
device that diagnoses and treats cardiac arrest by re-establishing an
effective heart rhythm.
[17] Education, for example, also obtained input from state and local
school and emergency management officials and associations in
developing these recommended practices.
[18] See GAO-07-395T and GAO-06-618.
[19] Those school districts that did not have a written emergency
management plan cited several reasons for the lack of such plans that
included (1) no requirement to have a written plan, (2) inadequate
resources for experienced personnel to develop emergency plans, and (3)
schools, not the district, have individual plans.
[20] The difference between two estimates is statistically significant
if the probability that the observed or greater difference is due to
chance alone is less than 5 percent (95 percent confidence level).
[21] See footnote 10, page 13.
[22] National Education Association and National Association of School
Psychologists.
[23] Each student identified as having a disability under the
Individuals with Disabilities Education Act (IDEA) is required to have
an Individualized Education Program. This document outlines the
delivery of educational services and support for that student. While
law dictates minimum requirements for the type of information included
in the program, states and school districts have flexibility in
including additional information in such programs.
[24] At a national level, there is also a lack of agreement about a
definition of special needs individuals for the purposes of emergency
management. HHS officials noted that one definition of special needs
individuals, currently being considered for the next revision of the
National Response Plan, will help facilitate awareness and planning for
special needs populations with regard to emergency management.
[25] In at least one school district, Seattle, these plans are included
in the district's Continuity of Operations Plan, which is separate from
its emergency management plan.
[26] In our survey, community partners included representatives from:
public health, mental health, local head of government, transportation,
hospitals, Red Cross, faith-based community, and the business
community.
[27] Twelve percent of school districts do not know whether public
health agencies were included in the development and update of plans.
Thirteen percent of districts do not know whether the local head of
government was included in the development and update of plans.
[28] This is how we defined an SRO in our survey.
[29] Through its COPS (Community Oriented Policing in Schools) in
Schools (CIS) program, the Department of Justice provides three-year
grants that schools may use to hire SROs. The program was designed in
part to provide assistance to law enforcement agencies to help combat
violence and reduce the fear of crime in schools by deploying police
officers as SROs.
[30] See GAO-06-618.
[31] See GAO-06-618.
[32] Districts allocate staff development days to assist teachers and
other staff with improving skills, provide training, and meet
certification requirements, among other activities.
[33] Two-way radios, commonly known as walkie-talkies, are radios that
can alternate between receiving and transmitting messages. Cellular
telephones and satellite telephones are also two-way radios but, unlike
walkie-talkies, simultaneously receive and transmit messages.
[34] Three districts, Hardee County, Florida; Ashtabula, Ohio; and
Durham, North Carolina, reported needing a full-time staff person to
train staff. Two districts, Olmsted Falls, Ohio, and Hanover,
Massachusetts, reported needing a full-time staff person to update the
district plan.
[35] At the time of our visit, the school district used this practice
for its special needs students. However, in a subsequent e-mail message
a district official noted the district no longer uses students as
buddies.
[36] The Americans with Disabilities Act of 1990 and Section 504 of the
Rehabilitation Act of 1973 generally require that school facilities be
accessible to individuals with disabilities, although there is some
variation in requirements depending on whether a building is new or
existing. The ADA Accessibility Guidelines for Buildings and Facilities
specify the technical requirements for accessibility and address such
issues as the design of doorways, stairwells, elevators, and ramps.
[37] Thirteen percent of school districts reported not knowing whether
the district has challenges related to first responders.
[38] GAO has reported on the range of issues associated with the lack
of interoperability among first responders and the implications of
these issues for emergency management. For a fuller discussion of these
issues, see the following GAO reports: First Responders: Much Work
Remains to Improve Communications Interoperability, GAO-07-301
(Washington, D.C.: Apr. 2, 2007); Catastrophic Disasters: Enhanced
Leadership, Capabilities, and Accountability Controls Will Improve the
Effectiveness of the Nation's Preparedness, Response, and Recovery
System, GAO-06-618 (Washington, D.C.: Sept. 6, 2006); and Homeland
Security: Federal Leadership and Intergovernmental Cooperation Required
to Achieve First Responder Interoperable Communications, GAO-04-740
(Washington, D.C.: July 20, 2004).
[39] National Education Association, American Association of School
Administrators, and National Association of Secondary School
Principals.
[40] We arrived at our target population of 14,432 by eliminating
certain types of school districts such as: local school districts that
are not a component of a supervisory union, state-operated institutions
charged, at least in part, with providing elementary and/or secondary
instruction or services to a special-need population; federally
operated institutions charged, at least in part, with providing
elementary and/or secondary instruction or services to a special-need
population, districts with less than one student or one school,
agencies run by the Department of Defense or Bureau of Indian Affairs,
and districts in U.S. territories.
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