Continuity of Operations
Improved Planning Needed to Ensure Delivery of Essential Government Services
Gao ID: GAO-04-160 February 27, 2004
To ensure that essential government services are available in emergencies--such as terrorist attacks, severe weather, or building-level emergencies-- federal agencies are required to develop continuity of operations (COOP) plans. Responsibility for formulating guidance on these plans and for assessing executive branch COOP capabilities lies with the Federal Emergency Management Agency (FEMA), under the Department of Homeland Security. FEMA guidance, Federal Preparedness Circular (FPC) 65 (July 1999), provides elements of a viable COOP capability, including the requirement that agencies identify their essential functions. GAO was asked to determine the extent to which (1) major civilian executive branch agencies have identified their essential functions and (2) these agencies' COOP plans follow FEMA guidance.
From an assessment of 34 COOP plans against FEMA guidance, GAO found that most agencies' plans identified at least one function as essential. However, the functions identified in each plan varied widely in number-- ranging from 3 to 399--and included functions that appeared to be of secondary importance, while at the same time omitting programs that had been previously defined as high-impact programs. (Examples of these highimpact programs are Medicare, food stamps, and border inspections.) For example, one department included "provide speeches and articles for the Secretary and Deputy Secretary," among its essential functions, but did not include 9 of 10 high-impact programs for which it is responsible. Several factors contributed to these shortcomings: FPC 65 did not provide specific criteria for identifying essential functions; FEMA did not review the essential functions identified when it assessed COOP planning; and it did not conduct tests or exercises to confirm that the essential functions were correctly identified. Unless agencies' essential functions are correctly and completely identified, their COOP plans may not effectively ensure that the most vital government services can be maintained in an emergency. Although all but three of the agencies reviewed had developed and documented some of the elements of a viable COOP plan, none of the agencies could demonstrate that they were following all the guidance in FPC 65. There is a wide variation in the number of agencies that addressed various elements identified in the guidance. A contributing cause for the deficiencies in agency COOP plans is the level of FEMA oversight. In 1999, FEMA conducted an assessment of agency compliance with FPC 65, but it has not conducted oversight that is sufficiently regular and extensive to ensure that agencies correct the deficiencies identified. Because the resulting COOP plans do not include all the elements of a viable plan as defined by FPC 65, agency efforts to provide services during an emergency could be impaired.
Recommendations
Our 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.
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GAO-04-160, Continuity of Operations: Improved Planning Needed to Ensure Delivery of Essential Government Services
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Report to the Chairman, Committee on Government Reform, House of
Representatives:
February 2004:
CONTINUITY OF OPERATIONS:
Improved Planning Needed to Ensure Delivery of Essential Government
Services:
GAO-04-160:
GAO Highlights:
Highlights of GAO-04-160, a report to the Chairman, Committee on
Government Reform, House of Representatives
Why GAO Did This Study:
To ensure that essential government services are available in
emergencies”such as terrorist attacks, severe weather, or building-
level emergencies”federal agencies are required to develop continuity
of operations (COOP) plans. Responsibility for formulating guidance on
these plans and for assessing executive branch COOP capabilities lies
with the Federal Emergency Management Agency (FEMA), under the
Department of Homeland Security. FEMA guidance, Federal Preparedness
Circular (FPC) 65 (July 1999), provides elements of a viable COOP
capability, including the requirement that agencies identify their
essential functions.
GAO was asked to determine the extent to which (1) major civilian
executive branch agencies have identified their essential functions
and (2) these agencies‘ COOP plans follow FEMA guidance.
What GAO Found:
From an assessment of 34 COOP plans against FEMA guidance, GAO found
that most agencies‘ plans identified at least one function as
essential. However, the functions identified in each plan varied widely
in number”ranging from 3 to 399”and included functions that appeared to
be of secondary importance, while at the same time omitting programs
that had been previously defined as high-impact programs. (Examples of
these high-impact programs are Medicare, food stamps, and border
inspections.) For example, one department included ’provide speeches
and articles for the Secretary and Deputy Secretary,“ among its
essential functions, but did not include 9 of 10 high-impact programs
for which it is responsible. Several factors contributed to these
shortcomings: FPC 65 did not provide specific criteria for identifying
essential functions; FEMA did not review the essential functions
identified when it assessed COOP planning; and it did not conduct tests
or exercises to confirm that the essential functions were correctly
identified. Unless agencies‘ essential functions are correctly and
completely identified, their COOP plans may not effectively ensure that
the most vital government services can be maintained in an emergency.
Although all but three of the agencies reviewed had developed and
documented some of the elements of a viable COOP plan, none of the
agencies could demonstrate that they were following all the guidance in
FPC 65. As the figure shows, there is a wide variation in the number of
agencies that addressed various elements identified in the guidance. A
contributing cause for the deficiencies in agency COOP plans is the
level of FEMA oversight. In 1999, FEMA conducted an assessment of
agency compliance with FPC 65, but it has not conducted oversight that
is sufficiently regular and extensive to ensure that agencies correct
the deficiencies identified. Because the resulting COOP plans do not
include all the elements of a viable plan as defined by FPC 65, agency
efforts to provide services during an emergency could be impaired.
What GAO Recommends:
To ensure that the executive branch can provide essential services
during emergencies, GAO recommends, among other things, that the
Secretary of Homeland Security take steps to improve agency COOP plans
and FEMA‘s process for assessing these plans. In commenting on a draft
of this report, the Under Secretary for Emergency Preparedness and
Response agreed that FEMA could do more to improve COOP planning, and
that FEMA has begun making such improvements.
www.gao.gov/cgi-bin/getrpt?GAO-04-160.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Linda Koontz at (202)
512-6240 or koontzl@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Many COOP Plans Did Not Address Previously Identified Essential
Functions or Interdependencies with Other Entities:
Agency COOP Plans Addressed Some, but Not All, of FEMA's Guidance:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendixes:
Appendix I: Scope and Methodology:
Appendix II: Major Civilian Departments and Agencies Selected for
Review:
Appendix III: Thirty-eight High-Impact Programs and Responsible
Agencies:
Appendix IV: Component Agencies Reviewed, with High-Impact Program
Responsibilities:
Appendix V: Comments from the Federal Emergency Management Agency:
Tables:
Table 1: Eight COOP Planning Topics Defined by FPC 65 and Examples of
Actions:
Table 2: Agency COOP Plan Treatment of Essential Functions:
Table 3: Agency COOP Plan Treatment of Plans and Procedures:
Table 4: Agency COOP Plan Treatment of Order of Succession:
Table 5: Agency COOP Plan Treatment of Delegations of Authority:
Table 6: Agency COOP Plan Treatment of Alternate Facilities:
Table 7: Agency COOP Plan Treatment of Emergency Communications:
Table 8: Agency COOP Plan Treatment of Vital Records:
Table 9: Agency COOP Plan Treatment of Tests, Training, and Exercises:
Abbreviations:
COOP: continuity of operations:
FEMA: Federal Emergency Management Agency:
FPC: Federal Preparedness Circular:
OMB: Office of Management and Budget:
PDD: Presidential Decision Directive:
Y2K: year 2000:
Letter February 27, 2004:
The Honorable Tom Davis Chairman, Committee on Government Reform:
House of Representatives:
Dear Mr. Chairman:
As you know, essential government services can be interrupted by a
range of events, including terrorist attacks, severe weather, or
building-level emergencies. Federal agencies are required by
Presidential Decision Directive (PDD) 67 to develop plans for ensuring
the continuity of such services in emergency situations. This directive
also designated the Federal Emergency Management Agency (FEMA) as
executive agent for executive branch continuity of operations (COOP)
planning, which includes the responsibility for formulating guidance on
such planning and for assessing the status of executive branch COOP
capabilities. In response, FEMA issued guidance to agencies, entitled
Federal Preparedness Circular (FPC) 65, in July 1999. The circular
states that in order to have a viable COOP capability, agencies should
identify their essential functions. These functions then provide the
basis for subsequent planning steps. The circular also identified eight
elements of a viable COOP capability.
Concerned about the ability of the federal government to continue to
provide essential services during an emergency, you requested us to
report to you concerning some aspects of headquarters contingency plans
from a number of civilian departments and agencies.[Footnote 1] Between
June and August 2003, we presented your staff with a series of
classified and unclassified briefings on the results of our review of
these plans. In October 2003, you also requested us to review the
actions that FEMA had taken to improve oversight since our assessment.
This report includes the results of work done in response to both
requests.
Our objectives were to determine:
* the extent to which major civilian executive branch agencies have
identified their essential functions and:
* the extent to which these agencies' COOP plans follow the guidance
provided in FPC 65.
To achieve our objectives, we obtained and evaluated the headquarters
contingency plans in place as of October 1, 2002, from 20 of the 23
largest civilian departments and agencies,[Footnote 2] as well as the
headquarters plans for 15 components of civilian cabinet-level
departments, selected because they were responsible for programs
previously deemed high impact by the Office of Management and Budget
(OMB). (Additional information on our scope and methodology can be
found in app. I. The major departments and agencies reviewed are listed
in app. II.)[Footnote 3] We also interviewed the agency officials
responsible for developing these COOP plans, obtained and analyzed FEMA
COOP guidance and documents describing its efforts to provide oversight
and assessments of the federal COOP planning efforts, and interviewed
FEMA officials to clarify the activities described in these documents.
We requested that the National Security Council provide us with a copy
of PDD 67, which lays out the policy guidance for executive branch
contingency planning and describes the authority granted to FEMA and
other agencies. To date, we have not received a copy. Instead, we
relied on the characterization of PDD 67 in FPC 65 and on statements
from FEMA officials on the requirements within PDD 67. Without a copy
of PDD 67, we were unable to verify the responsibilities or scope of
authority of the various executive branch entities that are responsible
for contingency planning. We conducted our assessment between April
2002 and May 2003; in December 2003 and January 2004, we conducted
additional work on FEMA's oversight actions. All of our work was
conducted in accordance with generally accepted government auditing
standards.
The Department of Homeland Security, of which FEMA became a part in
March 2003, reviewed a draft of our briefing and determined that parts
of it were classified. We provided a classified briefing to your staff
on June 30, 2003, and an unclassified briefing (with the classified
pages removed) on July 14, 2003. Upon discussion with Homeland Security
officials, we were able to revise the briefing to include additional
unclassified information, which we then provided to your staff in
August 2003. This report responds to your October 2003 request that we
publish our unclassified findings, updated to reflect FEMA's recent
activities, and officially transmit our recommendations to the
Secretary of Homeland Security.
Results in Brief:
Twenty-nine of the 34 COOP plans[Footnote 4] that we reviewed
identified at least one essential function. However, the functions
identified in these plans varied widely in number--ranging from 3 to
399--and included functions that appeared to be of secondary
importance. At the same time, the plans omitted many programs that OMB
had previously identified as having a high impact on the public.
Agencies did not list among their essential functions 20 of the 38
high-impact programs that had been identified at those agencies. For
example, one department included "provide speeches and articles for the
Secretary and Deputy Secretary" among its essential functions, but it
did not include 9 of its 10 high-impact programs. In addition, although
many agency functions rely on the availability of resources or
functions controlled by another organization, more than three-fourths
of the plans did not fully identify such dependencies. Several factors
contributed to these governmentwide shortcomings: FPC 65 does not
provide specific criteria for identifying essential functions, nor does
it address interdependencies; FEMA did not review the essential
functions identified in its assessments of COOP planning or follow up
with agencies to determine whether they addressed previously identified
weaknesses; and it did not conduct tests or exercises that could
confirm that the identified essential functions were correct. Although
FEMA has begun efforts to develop additional guidance and conduct a
governmentwide exercise, these actions have not yet been completed.
Without better oversight, agencies are likely to continue to base their
COOP plans on ill-defined assumptions that may limit the utility of the
resulting plans.
While all but three of the agencies that we reviewed had developed and
documented some elements of a COOP plan, none of the agencies provided
documentation sufficient to show that they were following all the
guidance in FPC 65. A contributing cause for the deficiencies in agency
COOP plans is the level of FEMA oversight. In 1999, FEMA conducted an
assessment of agency compliance with FPC 65, but it has not conducted
oversight that is sufficiently regular and extensive to ensure that
agencies correct deficiencies identified. FEMA officials told us that
they plan to improve oversight by providing more detailed guidance and
developing a system to collect data from agencies on their COOP
readiness. However, FEMA has not yet determined how it will verify the
agency-reported data, assess the essential functions and
interdependencies identified, or use the data to conduct regular
oversight. If FEMA does not address these shortcomings, agency COOP
plans may not be effective in ensuring that the most vital government
services can be maintained in an emergency.
In light of the essential need for agencies to develop viable COOP
plans and FEMA's responsibility for overseeing the development of such
plans, we are recommending that the Secretary of Homeland Security
direct the Under Secretary for Emergency Preparedness and Response to
take steps to ensure that agencies have plans in place and improve
FEMA's oversight of existing plans.
In commenting on a draft of this report, the Under Secretary agreed
that better COOP planning is needed, and that FEMA could do more to
improve COOP planning. He added that the agency has begun making such
improvements and stated that the federal government is currently poised
to provide services in an emergency. The Under Secretary's commitment
to improve FEMA's oversight of COOP planning can be instrumental in
ensuring that agencies prepare adequate plans. Specifically, once FEMA
ensures that each agency has a COOP plan, ensures that agencies correct
the identified deficiencies in existing plans, and conducts independent
verification and assessments of those plans, it will be in a position
to effectively demonstrate the readiness of federal agencies to respond
to emergencies.
Background:
Federal operations and facilities have been disrupted by a range of
events, including the terrorist attacks on September 11, 2001; the
Oklahoma City bombing; localized shutdowns due to severe weather
conditions, such as the closure of federal offices in Denver for 3 days
in March 2003 due to snow; and building-level events, such as asbestos
contamination at the Department of the Interior's headquarters. Such
disruptions, particularly if prolonged, can lead to interruptions in
essential government services. Prudent management, therefore, requires
that federal agencies develop plans for dealing with emergency
situations, including maintaining services, ensuring proper authority
for government actions, and protecting vital assets.
Until relatively recently, continuity planning was generally the
responsibility of individual agencies. In October 1998, PDD 67
identified FEMA--which is responsible for responding to, planning for,
recovering from, and mitigating against disasters--as the executive
agent for federal COOP planning across the federal executive branch.
FEMA was an independent agency until March 2003, when it became part of
the Department of Homeland Security, reporting to the Under Secretary
for Emergency Preparedness and Response.
PDD 67 is a Top Secret document controlled by the National Security
Council. FPC 65 states that PDD 67 made FEMA, as executive agent for
COOP, responsible for:
* formulating guidance for agencies to use in developing viable plans;
* coordinating interagency exercises and facilitating interagency
coordination, as appropriate; and:
* overseeing and assessing the status of COOP capabilities across the
executive branch.
According to FEMA officials, PDD 67 also required that agencies have
COOP plans in place by October 1999.
In July 1999, FEMA issued FPC 65 to assist agencies in meeting the
October 1999 deadline. FPC 65 states that COOP planning should address
any emergency or situation that could disrupt normal operations,
including localized emergencies. FPC 65 also determined that COOP
planning is based first on the identification of essential functions--
that is, those functions that enable agencies to provide vital
services, exercise civil authority, maintain safety, and sustain the
economy during an emergency. FPC 65 gives no criteria for identifying
essential functions beyond this definition.
Although FPC 65 gives no specific criteria for identifying essential
functions, a logical starting point for this process would be to
consider programs that had been previously identified as important. For
example, in March 1999, as part of the efforts to address the Y2K
computer problem,[Footnote 5] the Director of OMB identified 42
programs with a high impact on the public:
* Of these 42 programs, 38 were the responsibility of the 23 major
departments and agencies that we reviewed. (App. III provides a list of
these 38 high-impact programs and the component agencies that are
responsible for them.):
* Of these 23 major departments and agencies, 16 were responsible for
at least one high-impact program; several were responsible for more
than one.
Programs that were identified included weather service, disease
monitoring and warnings, public housing, air traffic control, food
stamps, and Social Security benefits. These programs, as well as the
others listed in appendix III, continue to perform important functions
for the public.
The Y2K planning to support these high-impact programs included COOP
planning and specifically addressed interdependencies. Planning
included identifying partners integral to program delivery, testing
data exchanges across partners, developing complementary business
continuity and contingency plans, sharing key information on readiness
with other partners and the public, and taking other steps to ensure
that the agency's high-impact program would work in the event of an
emergency.
Although the identification of essential functions was established as
the first step in COOP planning, FPC 65 also identified an additional
seven other planning topics that make up a viable COOP capability. The
guidance provided a general definition of each of the eight topics and
identified several actions that should be completed to address each
topic. Table 1 lists the eight topic areas covered in FPC 65 and
provides an example of an action under each.
Table 1: Eight COOP Planning Topics Defined by FPC 65 and Examples of
Actions:
FPC 65 planning topic: Essential functions should be identified to
provide the basis for COOP planning;
Example of action (element of viable COOP plan): The agency should
prioritize its essential functions.
FPC 65 planning topic: Plans and procedures should be developed and
documented to provide for continued performance of essential functions;
Example of action (element of viable COOP plan): These plans should
include a roster of personnel who can perform the essential functions.
FPC 65 planning topic: Orders of succession should identify alternates
to fill key positions in an emergency;
Example of action (element of viable COOP plan): Succession lists
should be developed for the agency head and other key positions.
FPC 65 planning topic: Delegations of authority should identify the
legal basis for officials to make decisions in emergencies;
Example of action (element of viable COOP plan): Delegations should
include the circumstances under which the authorities begin and end.
FPC 65 planning topic: Alternate facilities should be able to support
operations in a threat-free environment for up to 30 days;
Example of action (element of viable COOP plan): These facilities
should provide sufficient space and equipment to sustain the relocating
organization.
FPC 65 planning topic: Interoperable communications should provide
voice and data communications with others inside and outside the
organization;
Example of action (element of viable COOP plan): The agency should be
able to communicate with agency personnel, other agencies, critical
customers, and the public.
FPC 65 planning topic: Vital records should be identified and made
readily available in an emergency;
Example of action (element of viable COOP plan): Electronic and paper
records should be identified and protected.
FPC 65 planning topic: Tests, training, and exercises should occur
regularly to demonstrate and improve agencies' COOP capabilities;
Example of action (element of viable COOP plan): Individual and team
training should be conducted annually.
Sources: FPC 65, FEMA.
[End of table]
Many COOP Plans Did Not Address Previously Identified Essential
Functions or Interdependencies with Other Entities:
The identification of essential functions is a prerequisite for COOP
planning because it establishes the planning parameters that drive the
agency's efforts in all other planning topics. For example, FPC 65
directs agencies to identify alternative facilities, staff, and
resources necessary to support continuation of their essential
functions. The effectiveness of the plan as a whole and the
implementation of all other elements depend on the performance of this
step.
Of the 34 agency COOP plans we reviewed, 29 plans included at least one
function that was identified as essential. These agency-identified
essential functions varied in number and scope. The number of functions
identified in each plan ranged from 3 to 399. In addition, the apparent
importance of the functions was not consistent. For example, a number
of essential functions were of clear importance, such as:
* "ensuring uninterrupted command, control, and leadership of the
Department";
* "protecting critical facilities, systems, equipment and records";
and:
* "continuing to pay the government's obligations.":
Other identified functions appeared vague or of questionable
importance:
* "provide speeches and articles for the Secretary and Deputy
Secretary";
* "schedule all activities of the Secretary"; and:
* "review fiscal and programmatic integrity and efficiency of
Departmental activities.":
In contrast to the examples just given, agencies did not list among
their essential functions 20 of the 38 "high-impact" programs
identified during the Y2K effort at the agencies we reviewed.
Another important consideration in identifying essential functions is
the assessment of interdependencies among functions and organizations.
As we have previously reported,[Footnote 6] many agency functions rely
on the availability of resources or functions controlled by another
organization, including other agencies, state and local governments,
and private entities. (For example, the Department of the Treasury's
Financial Management Service receives and makes payments for most
federal agencies.) The identification of such interdependencies
continues to be essential to the related areas of information security
and critical infrastructure protection. Although FPC 65 does not use
the term "interdependencies," it directs agencies to "integrate
supporting activities to ensure that essential functions can be
performed.":
Of the 34 plans we reviewed, 19 showed no evidence of an effort to
identify interdependencies and link them to essential functions, which
is a prerequisite to developing plans and procedures to support these
functions and all other elements of COOP planning. Nine plans
identified some key partners, but appeared to have excluded others: for
instance, six agencies either make or collect payments, but did not
mention the role of the Treasury Department in their COOP plans.
The high level of generality in FEMA's guidance on essential functions
contributed to the inconsistencies in agencies' identification of these
functions. In its initial guidance, FPC 65, FEMA provided minimal
criteria for agencies to make these identifications, giving a brief
definition only. According to FEMA officials, the agency is currently
developing revised COOP guidance that will provide more specific
direction on identifying essential functions. According to these
officials, FEMA expects to release the revised guidance in March 2004.
Further, although FEMA conducted several assessments of agency COOP
planning between 1995 and 2001, none of these addressed the
identification of essential functions. In addition, FEMA has begun
development of a system to collect data from agencies on the readiness
of their COOP plans, but FEMA officials told us that they will not use
the system to validate the essential functions identified by each
agency or their interdependencies. According to FEMA officials, the
agencies are better able to make those determinations. However,
especially in view of the wide variance in number and importance of
functions identified, as well as omissions of high-impact programs, the
lack of FEMA review lowers the level of assurance that the essential
functions that have been identified are appropriate.
Additionally, in its oversight role, FEMA had the opportunity to help
agencies refine their essential functions through an interagency COOP
test or exercise. According to FPC 65, FEMA is responsible for
coordinating such exercises. FEMA is developing a test and training
program for COOP activities, but it has not yet conducted an
interagency exercise to test the feasibility of these planned
activities. FEMA had planned a governmentwide exercise in 2002, but the
exercise was cancelled after the September 11 attacks. FEMA is
currently preparing to conduct a governmentwide exercise in mid-May
2004.
Improper identification of essential functions can have a negative
impact on the entire COOP plan, because other aspects of the COOP plan
are designed around supporting these functions. If an agency fails to
identify a function as essential, it will not make the necessary
arrangements to perform that function. If it identifies too many
functions as essential, it risks being unable to adequately address all
of them. In either case, the agency increases the risk that it will not
be able to perform its essential functions in an emergency.
Agency COOP Plans Addressed Some, but Not All, of FEMA's Guidance:
As of October 1, 2002, almost 3 years after the planning deadline
established by PDD 67, 3 of the agencies we reviewed had not developed
and documented a COOP plan. The remaining 20 major federal civilian
agencies had COOP plans in place, and the 15 components[Footnote 7]
that we reviewed also had plans. (App. IV identifies the 15 components
and the high-impact programs for which they are responsible.) However,
none of these plans addressed all the guidance in FPC 65. Of the eight
topic areas identified in FPC 65, these 34 COOP plans generally
complied with the guidance in one area (developing plans and
procedures); generally did not comply in one area (tests, training, and
exercises); and showed mixed compliance in the other six areas.
The following sections present the results of our analysis for each of
the eight planning topics outlined in FPC 65. In analyzing each plan,
we looked for the answers to a series of questions regarding each
planning topic. We present the compiled results for each topic in the
form of a table showing the answers to these questions. Appendix I
provides more detail on our analysis and methods.
Essential Functions:
Although most agency plans identified at least one essential function,
less than half the COOP plans fully addressed other FPC 65 guidance
related to essential functions, such as prioritizing the functions or
identifying interdependencies among them (see table 2). If agencies do
not prioritize their essential functions and identify the resources
that are necessary to accomplish them, their COOP plans will not be
effective, since the other seven topics of the COOP plan are designed
around supporting these functions.
Table 2: Agency COOP Plan Treatment of Essential Functions:
Did the COOP documentation-
Identify agency's essential functions?[A];
Yes: 25;
Partially: 4;
No: 5.
Did the COOP documentation-
Identify which essential functions must be continued under all
circumstances?
Yes: 14;
Partially: 3;
No: 17.
Did the COOP documentation-
Prioritize essential functions?
Yes: 13;
Partially: 2;
No: 19.
Did the COOP documentation-
Establish staffing and resource requirements needed to perform the
essential functions?
Yes: 8;
Partially: 20;
No: 6.
Did the COOP documentation-
Identify mission-critical systems and data necessary to conduct
essential functions?
Yes: 7;
Partially: 12;
No: 15.
Did the COOP documentation-
Integrate supporting activities/identify interdependencies among the
essential functions and functions or resources controlled by others?
Yes: 6;
Partially: 9;
No: 19.
Source: GAO analysis of agency plans.
[A] The analysis for this question addressed only whether essential
functions were named; it did not evaluate the functions chosen.
[End of table]
Plans and Procedures:
FPC 65 calls for COOP plans to be developed and documented that provide
for the performance of essential functions under all circumstances.
Most agency COOP documents included the basic information outlined in
FPC 65 (see table 3). However, in those cases where plans and
procedures are not adequately documented, agency personnel may not know
what to do in an emergency.
Table 3: Agency COOP Plan Treatment of Plans and Procedures:
Did the COOP documentation--
Identify a roster of personnel to perform essential functions?
Yes: 22;
Partially: 6;
No: 6.
Did the COOP documentation--
Identify procedures for employee advisories, alerts, notifications, and
relocation instructions to the alternate facilities?
Yes: 19;
Partially: 11;
No: 4.
Did the COOP documentation--
Establish a goal of becoming operational within 12 hours and
maintaining that capability for 30 days?
Yes: 25;
Partially: 4;
No: 5.
Source: GAO analysis of agency plans.
[End of table]
Order of Succession:
Orders of succession ensure continuity by identifying individuals who
are authorized to act for agency officials in case those officials are
unavailable. Although most agency COOP documents adequately described
the order of succession to the agency head and described orders of
succession by position or title, fewer addressed other succession
planning procedures outlined in FPC 65 (see table 4). If orders of
succession are not clearly established, agency personnel may not know
who has authority and responsibility if agency leadership is
incapacitated in an emergency.
Table 4: Agency COOP Plan Treatment of Order of Succession:
Did the COOP documentation--
Establish an order of succession to the agency head position?
Yes: 28;
Partially: 4;
No: 2.
Did the COOP documentation--
Establish orders of succession to other key leadership positions?
Yes: 19;
Partially: 6;
No: 9.
Did the COOP documentation--
Include officials outside Washington, D.C., in the order of
succession?[A];
Yes: 19;
Partially: 1;
No: 11.
Did the COOP documentation--
Describe orders of succession by position or title?
Yes: 31;
Partially: 2;
No: 1.
Did the COOP documentation--
Include the orders of succession in the agency's emergency vital
records?
Yes: 6;
Partially: 4;
No: 24.
Did the COOP documentation--
Establish rules and procedures for resolving questions regarding
succession in emergencies?
Yes: 14;
Partially: 3;
No: 17.
Did the COOP documentation--
Define the conditions under which succession takes place and how
successors are to be relieved?
Yes: 9;
Partially: 20;
No: 5.
Did the COOP documentation--
Require orientation programs to prepare potential successors for their
emergency duties?
Yes: 0;
Partially: 7;
No: 27.
Source: GAO analysis of agency plans.
[A] Three agencies did not have senior officials outside the local
area.
[End of table]
Delegations of Authority:
To provide for rapid response to emergencies, FPC 65 calls for agencies
to delegate authorities in advance for making policy determinations at
all levels. Generally, these delegations define what actions those
individuals identified in the orders of succession can take in
emergencies. Few agency COOP documents adequately described the
agency's delegations of authority (see table 5). If delegations of
authority are not clearly established, agency personnel may not know
who has authority to make key decisions in an emergency.
Table 5: Agency COOP Plan Treatment of Delegations of Authority:
Did the COOP documentation--
Document the legal authority for officials (including those below the
agency head) to make policy decisions during an emergency?
Yes: 8;
Partially: 16;
No: 10.
Did the COOP documentation--
Identify when emergency legal authorities begin and when they
terminate?
Yes: 5;
Partially: 20;
No: 9.
Source: GAO analysis of agency plans.
[End of table]
Alternate Facilities:
Alternate facilities provide a physical location from which to conduct
essential functions if the agency's existing facilities are
unavailable. Most agency COOP plans document the acquisition of at
least one alternate facility for use in emergencies, but few of those
plans demonstrate that the facilities are capable of meeting the
agencies' emergency operating requirements (see table 6). If alternate
facilities are not provided or are inadequate, agency operations may
not be able to continue in an emergency.
Table 6: Agency COOP Plan Treatment of Alternate Facilities:
Did the COOP documentation--
Document the acquisition of alternate facilities?
Yes: 24;
Partially: 6;
No: 4.
Did the COOP documentation--
Identify alternate facilities both within and outside the local area?
Yes: 20;
Partially: 11;
No: 3.
Did the COOP documentation--
Document the facilities' capability to provide sufficient space and
equipment for the previously identified level of staff?a;
Yes: 2;
Partially: 16;
No: 15.
Did the COOP documentation--
Document the capability to provide interoperable communications with
internal and external organizations, critical customers, and the
public?
Yes: 5;
Partially: 15;
No: 14.
[End of table]
Source: GAO analysis of agency plans.
[A] The number of assessments adds to 33 rather than 34 because one
agency does not relocate staff to an alternate facility. Instead, it
transfers operational responsibility to staff in place at another
location.
Redundant Emergency Communications:
The success of agency operations at an alternate facility depends on
available and redundant communications with internal organizations,
other agencies, critical customers, and the public. Most COOP documents
identified some redundant emergency communications capabilities, but
few included contact information that would be necessary to use those
capabilities in an emergency (see table 7). If communications fail in
an emergency, essential agency operations may not be possible.
Table 7: Agency COOP Plan Treatment of Emergency Communications:
Did the COOP documentation--
Identify at least two independent channels for emergency
communications?
Yes: 25;
Partially: 2;
No: 7.
Did the COOP documentation--
Identify key internal and external contacts and how to reach them?
Yes: 10;
Partially: 10;
No: 14.
Did the COOP documentation--
Identify how emergency communications channels will be used to access
the agency's vital electronic systems?
Yes: 3;
Partially: 4;
No: 27.
[End of table]
Source: GAO analysis of agency plans.
Vital Records:
FPC 65 states that agency personnel must have access to and be able to
use the electronic and hard-copy records and information systems that
are needed to perform their essential functions. About 24 percent of
the COOP plans fully identified agencies' vital paper and electronic
records, while fewer documented the procedures for protecting or
updating them (see table 8). If agency personnel cannot access and use
up-to-date vital records, they may be unable to carry out essential
functions.
Table 8: Agency COOP Plan Treatment of Vital Records:
Did the COOP documentation--
Identify the vital records needed to support the identified essential
functions?
Yes: 8;
Partially: 13;
No: 13.
Did the COOP documentation--
Identify where and how agency personnel are to access the vital
records?
Yes: 2;
Partially: 10;
No: 22.
Did the COOP documentation--
Outline procedures for regularly pre- positioning and updating the
identified vital records?
Yes: 3;
Partially: 15;
No: 16.
[End of table]
Source: GAO analysis of agency plans.
Tests, Training, and Exercises:
Tests, training, and exercises of COOP capabilities are essential to
demonstrate and improve agencies' abilities to execute their plans. Few
agencies have documented that they have conducted tests, training, and
exercises at the recommended frequency (see table 9). If emergency
procedures are not tested and staff is not trained in their use,
planned responses to an emergency may not be adequate to continue
essential functions.
Table 9: Agency COOP Plan Treatment of Tests, Training, and Exercises:
Did the agency--
Conduct annual individual and team training for COOP staff?
Yes: 1;
Partially: 11;
No: 22.
Did the agency--
Conduct annual internal agency testing and exercising of COOP plans and
procedures, including operations at the alternate facilities?
Yes: 3;
Partially: 10;
No: 21.
Did the agency--
Conduct quarterly testing of alert and notification procedures?
Yes: 0;
Partially: 10;
No: 24.
Did the agency--
Conduct refresher orientations for staffs arriving at alternate
facilities?[A];
Yes: 0;
Partially: 0;
No: 33.
Did the agency--
Conduct joint agency exercises, where applicable and feasible?[B];
Yes: 1;
Partially: 0;
No: 29.
Source: GAO analysis of agency plans.
[A] One agency transfers operations, rather than relocating to an
alternate facility.
[B] Four agencies determined that it was not appropriate to run
interagency exercises.
[End of table]
Limitations in FEMA's Oversight Contribute to Noncompliance:
The lack of compliance shown by many COOP plans can be largely
attributed to FEMA's limited guidance and oversight of executive branch
COOP planning. First, FEMA has issued little guidance to assist
agencies in developing plans that address the goals of FPC 65.
Following FPC 65, FEMA issued more detailed guidance in April 2001 on
two of FPC 65's eight topic areas: FPC 66 provides guidance on
developing viable test, training, and exercise programs, and FPC 67
provides guidance for acquiring alternate facilities. However, FEMA did
not produce any detailed guidance on the other six topic areas.
In October 2003, FEMA began working with several members of the
interagency COOP working group to revise FPC 65. FEMA officials expect
this revised guidance, which was still under development as of January
2004, to incorporate the guidance from the previous FPCs and to address
more specifically what agencies need to do to comply with the guidance.
Second, as part of FEMA's oversight responsibilities, its Office of
National Security Coordination is tasked with conducting comprehensive
assessments of the federal executive branch COOP programs. With the
assistance of contractors, the office has performed assessments, on an
irregular schedule, of federal agencies' emergency planning
capabilities:
* In 1995, FEMA performed a survey of agency officials (this assessment
predated FPC 65).
* In 1999, FEMA assessed compliance with the elements of FPC 65 through
a self-reported survey of agency COOP officials, supplemented by
interviews.
* In 2001, FEMA surveyed agency officials to ask, among other things,
about actions that agencies took on and immediately after September 11,
2001.
Of these three assessments, only the 1999 assessment evaluated
compliance with the elements of FPC 65. Following this assessment, FEMA
gave agencies feedback on ways to improve their respective COOP plans,
and it made general recommendations, not specific to individual
agencies, that addressed programwide problems. However, FEMA did not
then follow up to determine whether individual agencies made
improvements in response to its feedback and general recommendations.
Besides inquiring about actions in response to the September 2001
attacks, the 2001 assessment was designed to provide an update on
programwide problems that had been identified in the assessments of
1995 and 1999. It did not address whether individual agency COOP plans
had been revised to correct previously identified deficiencies, nor did
FEMA provide specific feedback to individual agencies.
According to FEMA officials, the system it is developing to collect
agency-reported data on COOP plan readiness will improve FEMA's
oversight. The system is based on a database of information provided by
agencies for the purpose of determining if they are prepared to
exercise their COOP plans, in part by assessing compliance with FPC 65.
However, according to FEMA officials, while they recognize the need for
some type of verification, FEMA has not yet determined a method of
verifying these data.
Without regular assessments of COOP plans that evaluate individual
plans for adequacy, FEMA will not be able to provide information to
help agencies improve their COOP plans. Further, if FEMA does not
verify the data provided by the agencies or follow up to determine
whether agencies have improved their plans in response to such
assessments, it will have no assurance that agencies' emergency
procedures are appropriate.
FEMA officials attributed the limited level of oversight that we found
to two factors. First, they stated that before its transition to the
Department of Homeland Security, the agency did not have the legal or
budgetary authority to conduct more active oversight of the COOP
activities of other agencies. However, FPC 65 states that PDD 67 made
the agency responsible for guidance, coordination, and oversight in
this area, in addition to requiring agencies to develop COOP plans.
Accordingly, although it cannot determine how agencies budget resources
for such planning, it does have the authority to oversee this planning.
Second, according to these officials, until last year, the agency
devoted roughly 13 staff to COOP guidance, coordination, and oversight,
as well as the development of FEMA's own COOP plan. According to the
official responsible for COOP oversight, the agency now has 42
positions authorized for COOP activities, 31 of which were filled as of
December 31, 2003. The agency expects to fill another 4 positions in
fiscal year 2004.
Conclusions:
While most of the federal agencies we reviewed had developed COOP
plans, three agencies did not have documented plans as of October 2002.
Those plans that were in place exhibited weaknesses in the form of
widely varying determinations about what functions are essential and
inconsistent compliance with guidance that defines a viable COOP
capability. The weaknesses that we identified could cause the agencies
to experience difficulties in delivering key services to citizens in
the aftermath of an emergency.
A significant factor contributing to this condition is FEMA's limited
efforts to fulfill its responsibilities first by providing guidance to
help agencies develop effective plans and then by assessing those
plans. Further, FEMA has done very little to help agencies identify
those functions that are truly essential or to identify and plan for
interdependencies among agency functions. FEMA has begun taking steps
to improve its oversight, by developing more specific guidance and a
system to track agency-provided COOP readiness information, and it is
planning a governmentwide exercise. However, although the proposed
guidance and exercise may help agencies improve their plans, the system
that FEMA is developing to collect data on COOP readiness is weakened
by a lack of planning to verify agency-submitted data, validate agency-
identified essential functions, or identify interdependencies with
other activities. Without this level of active oversight, continuity
planning efforts will continue to fall short and increase the risk that
the public will not be able to rely upon the continued delivery of
essential government programs and services following an emergency.
Recommendations for Executive Action:
We are making three recommendations to enhance the ability of the
executive branch to continue to provide essential services during
emergencies.
* To ensure that agencies can continue operations in emergencies and
are prepared for the governmentwide exercise planned for May 2004, we
recommend that the Secretary of Homeland Security direct the Under
Secretary for Emergency Preparedness and Response to take steps to
ensure that agencies that do not have COOP plans develop them by May 1,
2004.
We further recommend that the Secretary direct the Under Secretary to
take steps to improve the oversight of COOP planning by:
* ensuring that agencies correct the deficiencies in individual COOP
plans identified here, as well as those identified in previous
assessments, and:
* conducting assessments of agency continuity plans that include
independent verification of agency-provided information, as well as an
assessment of the essential functions identified and their
interdependencies with other activities.
Agency Comments:
In written comments on a draft of this report, which are reprinted in
appendix V, the Under Secretary for Emergency Preparedness and Response
agreed that better COOP planning is needed to ensure delivery of
essential services, and that FEMA could do more to improve COOP
planning. He added that the agency has begun to correct the identified
deficiencies and stated that the federal government is currently poised
to provide services in an emergency. The Under Secretary's commitment
to improve FEMA's oversight of COOP planning can be instrumental in
ensuring that agencies prepare adequate plans. Specifically, once FEMA
ensures that each agency has a COOP plan, ensures that agencies correct
the identified deficiencies in existing plans, and conducts independent
verification and assessments of those plans, it will be in a position
to effectively demonstrate the readiness of federal agencies to respond
to emergencies.
As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
from the date of this report. At that time, we will send copies to the
Chairmen and Ranking Minority Members of the Subcommittee on Homeland
Security, House Committee on Appropriations; Subcommittee on National
Security, Emerging Threats, and International Relations, House
Committee on Government Reform; and the Subcommittee on Oversight of
Government Management, the Federal Workforce, and the District of
Columbia, Senate Committee on Governmental Affairs. We are also sending
copies to the Secretary of Homeland Security. We will also make copies
available on request. In addition, the report will be available at no
charge on the GAO Web site at [Hyperlink, http://www.gao.gov].
Should you have any questions on matters contained in this report,
please contact me at (202) 512-6240 or by e-mail at [Hyperlink,
koontzl@gao.gov]. Other key contributors to this report
were Barbara Collier, Mirko Dolak, Neela Lakhmani, Susan Sato, James R.
Sweetman, Jr., Jessie Thomas, and Marcia Washington.
Sincerely yours,
Signed by:
Linda D. Koontz
Director, Information Management Issues:
[End of section]
Appendixes:
[End of section]
Appendix I: Scope and Methodology:
To accomplish our objectives, we obtained and evaluated headquarters
contingency plans that were in place as of October 1, 2002, from 20 of
the 23 largest civilian departments and agencies[Footnote 8] (listed in
app. II). We also obtained and evaluated 14 plans covering 15
components[Footnote 9] of civilian cabinet-level departments, selected
because these components were responsible for a program previously
deemed high impact by the Office of Management and Budget (OMB). (App.
III lists these components and the high-impact programs.) We also
interviewed agency officials who were responsible for developing each
of the 34 continuity of operations (COOP) plans (comprising the 20
plans for the largest civilian departments and agencies and the 14
plans covering components with high-impact programs); obtained and
analyzed COOP guidance issued by the Federal Emergency Management
Agency (FEMA) and documents describing its efforts to provide oversight
and assessments of federal COOP planning efforts; and conducted
interviews with FEMA officials to clarify the activities described in
these documents.
To assess the adequacy of agency-identified essential functions, we
analyzed the COOP plans from agencies that were responsible for
programs that OMB designated as having high impact to determine whether
the plans described how those programs would continue to function
during an emergency, and we assessed COOP documentation for evidence of
agency efforts to identify interdependencies between their essential
functions and functions or resources controlled by others. For example,
for those agencies responsible for processing incoming or outgoing
payments, we looked for evidence that the agency had identified
services provided by the Department of the Treasury as necessary to the
continuation of its functions.
To assess how well agency plans followed Federal Preparedness Circular
(FPC) 65, we analyzed the guidance and identified 34 yes/no questions,
grouped by the eight topic areas identified in FPC 65. Each topic area
included two to eight questions. On the basis of the agency contingency
planning documents, we used content analysis to assign an answer of
"yes" (compliant), "no" (not compliant), or "partially" to these 34
questions.
Documents were reviewed and compared independently by several of our
analysts. The analysts then met to compare their assessments and reach
a consensus assessment. We shared these initial assessments with each
agency during structured interviews, giving agency officials the
opportunity to provide additional documentation to demonstrate
compliance. Any supplemental information provided by the agencies was
again reviewed by multiple analysts, first independently and then
jointly.
From this analysis, we created the summary tables that appear in this
report (tables 2 to 9) to compare answers across agencies.
We requested that the National Security Council provide a copy of
Presidential Decision Directive (PDD) 67, which lays out the policy
guidance for executive branch contingency planning and describes the
authority granted to FEMA and other agencies. To date, we have not
received a copy. Instead, we relied on the characterization of PDD 67
in FPC 65 and on statements from FEMA officials on the requirements
within PDD 67. Without a copy of PDD 67, we were unable to verify the
responsibilities or scope of authority of the various executive branch
entities responsible for contingency planning.
We conducted our review between April 2002 and January 2004, in
accordance with generally accepted government auditing standards.
[End of section]
Appendix II: Major Civilian Departments and Agencies Selected for
Review:
Department of Agriculture;
Department of Commerce;
Department of Education;
Department of Energy;
Department of Health and Human Services;
Department of Housing and Urban Development;
Department of Justice;
Department of Labor;
Department of State;
Department of the Interior;
Department of the Treasury;
Department of Transportation;
Department of Veterans Affairs;
Agency for International Development;
Environmental Protection Agency;
Federal Emergency Management Agency;
General Services Administration;
National Aeronautics and Space Administration;
National Science Foundation;
Nuclear Regulatory Commission;
Office of Personnel Management;
Small Business Administration;
Social Security Administration:
[End of section]
Appendix III: Thirty-eight High-Impact Programs and Responsible
Agencies:
Agency: Department of Agriculture;
High-impact programs:
Food safety inspection;
Child nutrition programs;
Food stamps;
Special supplemental nutrition program for women, infants, and
children.
Agency: Department of Commerce;
High-impact programs:
Patent and trademark processing;
Weather service.
Agency: Department of Education;
High-impact programs:
Student aid.
Agency: Department of Energy;
High-impact programs:
Federal electric power generation and delivery.
Agency: Department of Health and Human Services;
High-impact programs:
Disease monitoring and warnings;
Indian health services;
Medicaid;
Medicare;
Organ transplants;
Child care;
Child support enforcement;
Child welfare;
Low income home energy assistance;
Temporary assistance for needy families.
Agency: Department of Housing and Urban Development;
High-impact programs:
Community development block grants;
Housing loans;
Mortgage insurance;
Section 8 rental assistance;
Public housing.
Agency: Department of Justice;
High-impact programs:
Federal prisons;
Immigration.
Agency: Department of Labor;
High-impact programs:
Unemployment insurance.
Agency: Department of State;
High-impact programs:
Passport applications and processing.
Agency: Department of the Interior;
High-impact programs:
Bureau of Indian Affairs programs.
Agency: Department of the Treasury;
High-impact programs:
Cross-border inspection services.
Agency: Department of Transportation;
High-impact programs:
Air traffic control system;
Maritime search and rescue.
Agency: Department of Veterans Affairs;
High-impact programs:
Veterans' benefits;
Veterans' health care.
Agency: Federal Emergency Management Agency;
High-impact programs:
Disaster relief.
Agency: Office of Personnel Management;
High-impact programs:
Federal employee health benefits;
Federal employee life insurance;
Federal employee retirement benefits.
Agency: Social Security Administration;
High-impact programs:
Social Security benefits.
Source: GAO analysis of OMB guidance.
[End of table]
[End of section]
Appendix IV: Component Agencies Reviewed, with High-Impact Program
Responsibilities:
Department: Department of Commerce;
Component: National Oceanic and Atmospheric Administration;
High-impact programs: Weather service.
Component: Patent and Trademark Office;
High-impact programs: Patent and trademark processing.
Department: Department of Health and Human Services;
Component: Centers for Disease Control and Prevention;
High-impact programs: Disease monitoring and warnings.
Component: Center for Medicare and Medicaid Services;
High-impact programs: Medicare and Medicaid.
Component: Food and Drug Administration;
High-impact programs: Organ transplants.
Component: Indian Health Service;
High-impact programs: Indian health services.
Department: Department of Housing and Urban Development;
Component: Government National Mortgage Association;
High-impact programs: Housing loans.
Component: Office of Community Planning and Development;
High-impact programs: Community development block grants.
Component: Office of Housing;
High-impact programs: Section 8 rental assistance and mortgage
insurance.
Component: Office of Public and Indian Housing;
High-impact programs: Public housing.
Department: Department of the Interior;
Component: Bureau of Indian Affairs;
High-impact programs: Indian affairs programs.
Department: Department of the Treasury;
Component: U.S. Customs Service;
High-impact programs: Cross-border inspection services.
Department: Department of Transportation;
Component: Federal Aviation Administration;
High-impact programs: Air traffic control system.
Component: U.S. Coast Guard;
High-impact programs: Maritime search and rescue.
Department: Department of Veterans Affairs;
Component: Veterans Benefits Administration;
High-impact programs: Veterans' benefits.
Source: GAO analysis of OMB guidance.
[End of table]
[End of section]
Appendix V: Comments from the Federal Emergency Management Agency:
U.S. Department of Homeland Security
500 C Street, SW:
Washington, DC 20472:
FEMA:
February 18, 2004:
Linda Koontz:
Director, Information Management Issues
U.S. General Accounting Office
Washington, DC 20548:
Dear Director Koontz:
Thank you for the opportunity to review and comment on your proposed
report entitled Continuity of Operations: Improved Plans Needed to
Ensure Delivery of Essential Services, GAO-04-160. The Department of
Homeland Security (DHS) recognizes its role as the federal government's
Executive Agent for continuity of operations (COOP) and has made
significant strides toward ensuring the delivery of essential
government services in an emergency.
In general, we agree that improved planning is needed to ensure
delivery of essential services. However, we believe that the federal
government is currently poised to provide those services in an
emergency that requires the activation of COOP plans. This capability
was effectively demonstrated during Hurricane Isabel when the Federal
Emergency Management Agency (FEMA) coordinated government-wide COOP
activation preparations. More recently, FEMA worked closely with
federal departments and agencies during the holidays' elevated code-
orange alert to implement COOP plans as necessary.
Your report correctly points out that FEMA could, and should, do more
to improve upon the federal government's COOP capabilities. In that
regard, we believe FEMA has begun to correct the deficiencies you have
identified. Significantly, FEMA will be conducting Forward Challenge
04, a government-wide COOP exercise, in May 2004. This event marks the
first opportunity for the government to demonstrate and evaluate the
effectiveness of its COOP plans. Moreover, and as an outgrowth of the
monthly COOP Working Group that FEMA chairs with some 66 departments
and agencies, FEMA has begun working with the Small Agency Council to
develop and coordinate COOP plans. All of these FEMA efforts and
activities are specifically designed to improve planning and to further
ensure the delivery of essential government services during an
emergency.
On a final note, the President's FY-2005 budget proposal includes an
increase of $27 million for FEMA's Office of National Security
Coordination to be used for COOP and continuity of government programs,
including testing, training, exercising, planning and
interoperability. We believe this budget request, coupled with FEMA's
ongoing initiatives to improve reporting and coordination address your
concerns and further enhance the ability of the Executive branch to
provide essential services during emergencies.
Sincerely,
Signed by:
Michael D. Brown:
Under Secretary
Emergency Preparedness & Response:
(310388):
[End of section]
FOOTNOTES
[1] We also review the human capital considerations relevant to COOP
planning in a forthcoming report.
[2] Three of the selected major agencies did not have documented COOP
plans in place as of October 1, 2002.
[3] Appendix III provides a list of the high-impact programs and the
component agencies responsible for them. Appendix IV identifies the 15
components whose COOP plans we reviewed and the high-impact programs
for which they are responsible.
[4] One COOP plan covered two components. As a result, the 34 COOP
plans we reviewed covered 35 departments and agencies, including
components.
[5] The need to ensure that computers would handle dates correctly in
the year 2000 (Y2K) and beyond resulted in a governmentwide effort to
identify mission-critical systems and high-impact programs supported by
these systems.
[6] U.S. General Accounting Office, Year 2000 Computing Challenge:
Lessons Learned Can Be Applied to Other Management Challenges, GAO/
AIMD-00-290 (Washington, D.C.: Sept. 12, 2000).
[7] We reviewed 14 component plans: 1 plan covered a building that
houses 2 components.
[8] The remaining 3 departments and agencies had not yet developed
plans.
[9] One plan covered a building that houses 2 components responsible
for high-impact programs.
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