Human Capital
Opportunities to Improve Federal Continuity Planning Guidance Gao ID: GAO-04-384 April 20, 2004Federal agencies must have the capacity to serve the public during disruptions to normal operations. This depends, in part, on continuity efforts that help agencies marshal, manage, and maintain their most important asset--their people, or human capital. GAO identified the human capital considerations relevant to federal continuity efforts; described efforts by the Federal Emergency Management Agency (FEMA) and the Office of Personnel Management (OPM) to address these considerations relevant to continuity of operations (COOP); and described the role Federal Executive Boards (FEB) play in coordinating such efforts outside Washington, D.C.
According to recognized experts from the private and public sectors, continuity efforts should give priority to the immediate aftermath of a crisis--securing the safety of all employees and addressing the needs of employees who perform essential operations. However, experts noted that additional human capital considerations, especially those associated with the majority of an organization's employees who would be needed to resume all other operations, are also crucial and have not been well developed by many public and private sector organizations. To more fully address human capital considerations, experts identified two human capital principles that should guide all continuity efforts--demonstrating sensitivity to individual employee needs and maximizing the contributions of all employees--and six key organizational actions designed to enhance continuity efforts. FEMA and OPM have exhibited leadership in addressing human capital considerations relevant to COOP, but opportunities to improve exist. For example, while both agencies have issued guidance that addresses securing the safety of all employees and responding to the needs of personnel performing essential operations, neither agency's guidance addresses human capital considerations related to resuming broader agency operations. Although not specifically tasked with coordinating emergency preparedness efforts, including COOP, FEBs are uniquely positioned to do so, given their general responsibility for improving coordination among federal activities in areas outside of Washington, D.C. While some FEBs already play an active role in coordinating such efforts, the current context in which FEBs operate, including the lack of a clearly defined role and varying capacities among FEBs, could lead to inconsistent levels of preparedness across the nation.
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-04-384, Human Capital: Opportunities to Improve Federal Continuity Planning Guidance
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Report to the Chairman, Subcommittee on Oversight of Government
Management, the Federal Workforce, and the District of Columbia,
Committee on Governmental Affairs, U.S. Senate:
April 2004:
HUMAN CAPITAL:
Opportunities to Improve Federal Continuity Planning Guidance:
GAO-04-384:
GAO Highlights:
Highlights of GAO-04-384, a report to the Chairman, Subcommittee on
Oversight of Government Management, the Federal Workforce, and the
District of Columbia, Committee on Governmental Affairs, U.S. Senate
Why GAO Did This Study:
Federal agencies must have the capacity to serve the public during
disruptions to normal operations. This depends, in part, on continuity
efforts that help agencies marshal, manage, and maintain their most
important asset”their people, or human capital. GAO identified the
human capital considerations relevant to federal continuity efforts;
described efforts by the Federal Emergency Management Agency (FEMA) and
the Office of Personnel Management (OPM) to address these
considerations relevant to continuity of operations (COOP); and
described the role Federal Executive Boards (FEB) play in coordinating
such efforts outside Washington, D.C.
What GAO Found:
According to recognized experts from the private and public sectors,
continuity efforts should give priority to the immediate aftermath of
a crisis”securing the safety of all employees and addressing the needs
of employees who perform essential operations. However, experts noted
that additional human capital considerations, especially those
associated with the majority of an organization‘s employees who would
be needed to resume all other operations, are also crucial and have
not been well developed by many public and private sector
organizations. To more fully address human capital considerations,
experts identified two human capital principles that should guide all
continuity efforts”demonstrating sensitivity to individual employee
needs and maximizing the contributions of all employees”and six key
organizational actions designed to enhance continuity efforts.
Key Organizational Actions to Enhance Continuity Efforts:
Demonstrate top leadership commitment;
* Instill an approach to continuity planning that includes human
capital considerations.
* Allocate resources and set policies.
* Set direction and pace of recovery.
Seek opportunities for synergy;
* Integrate continuity efforts with broader decision making.
* Consider how continuity investments benefit other program efforts.
Maintain effective communication;
* Build relationships through two-way communication.
* Establish roles, responsibilities, and expectations.
* Develop redundant communication vehicles.
Target investments in training and development;
* Raise awareness of continuity efforts.
* Build skills and competencies to increase flexibility.
* Foster a culture that values flexible employees who are empowered to
make effective decisions.
Leverage the flexibility of human capital;
* Enable employees associated with resumption activities to contribute
to mission results in alternate assignments.
* Sustain the contribution of employees associated with essential
operations.
* Maintain organizational knowledge of staffing requirements and
availability.
Build process to identify and share lessons;
* Create a learning environment.
* Make learning explicit and shared.
Source: GAO.
[End of table]
FEMA and OPM have exhibited leadership in addressing human capital
considerations relevant to COOP, but opportunities to improve exist.
For example, while both agencies have issued guidance that addresses
securing the safety of all employees and responding to the needs of
personnel performing essential operations, neither agency‘s guidance
addresses human capital considerations related to resuming broader
agency operations.
Although not specifically tasked with coordinating emergency
preparedness efforts, including COOP, FEBs are uniquely positioned to
do so, given their general responsibility for improving coordination
among federal activities in areas outside of Washington, D.C. While
some FEBs already play an active role in coordinating such efforts,
the current context in which FEBs operate, including the lack of a
clearly defined role and varying capacities among FEBs, could lead to
inconsistent levels of preparedness across the nation.
What GAO Recommends:
GAO recommends that FEMA and OPM more fully address human capital
considerations in emergency preparedness guidance, including COOP, by
incorporating key actions identified in this report. GAO also
recommends that OPM clearly define the role FEBs play in improving
emergency preparedness coordination and address any resulting capacity
issues. FEMA agreed to implement our recommendations. OPM said its
guidance already incorporates the key actions and highlighted its
leadership role with respect to FEBs. GAO maintains that OPM has
opportunities to address a fuller range of human capital
considerations related to resuming broader agency operations and to
clearly define the role of FEBs.
www.gao.gov/cgi-bin/getrpt?GAO-04-384.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact J. Christopher Mihm at
202-512-6806 or mihmj@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Human Capital Considerations Are Relevant to Continuity Planning and
Implementation Efforts:
FEMA and OPM Have Exhibited Leadership in Addressing Human Capital
Considerations Relevant to COOP:
FEBs Have Opportunities to Coordinate Regional Emergency Planning
Efforts, Including COOP, in Major Metropolitan Areas:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Emergency Human Capital Flexibilities Listed in OPM
Emergency Memorandums:
Leave:
Pay:
Benefits:
Telework:
Emergency Hiring Flexibilities:
Appendix III: Comments from the Federal Emergency Management Agency:
Appendix IV: Comments from the Office of Personnel Management:
Table:
Table 1: Key Organizational Actions to Enhance Continuity Efforts:
Figure:
Figure 1: Six Organizational Actions to Enhance Continuity Efforts:
Letter April 20, 2004:
The Honorable George V. Voinovich:
Chairman, Subcommittee on Oversight of Government Management, the
Federal Workforce, and the District of Columbia:
Committee on Governmental Affairs:
United States Senate:
Dear Mr. Chairman:
The events of September 11, 2001, vividly demonstrated how important it
is, both symbolically and functionally, for federal government agencies
to continue to serve the American public during any emergency or
situation that may disrupt normal operations. Yet terrorist-related
incidents are only one in a broad spectrum of emergencies that can
disrupt an agency's normal operations. Agencies need a high level of
preparedness to deal with the full range of emergencies, including man-
made disasters, whether intentional or not; acts of nature, such as
hurricanes, earthquakes, or disease; and technological emergencies,
including cyber-attacks or computer viruses.
Continuity of operations (COOP) efforts are a comprehensive set of
steps agencies must undertake to help ensure that they can continuously
provide essential operations and resume full services to the American
public in the face of long-term, severe emergencies requiring agencies
to occupy alternate facilities.[Footnote 1] This capacity to serve the
public during any type of disruption to normal operations depends, in
part, on the ability of federal agencies to marshal, manage, and
maintain their most important asset--their people, or human capital.
The planning efforts that help agencies build the capacity to
effectively implement COOP may also help agencies more effectively
implement basic emergency preparedness procedures in dealing with less
severe disruptions to normal operations.
In response to your request that we identify the human capital
considerations in COOP emergencies, this report (1) identifies the
human capital considerations that are relevant to federal agencies'
continuity planning and implementation efforts; (2) describes the COOP
guidance provided by the Federal Emergency Management Agency
(FEMA)[Footnote 2] and emergency preparedness guidance and activities
of the Office of Personnel Management (OPM) to address human capital
considerations relevant to COOP; and (3) describes the role Federal
Executive Boards (FEB) play, relevant to COOP, in coordinating efforts
outside the Washington, D.C., area.
To address human capital considerations that are relevant to continuity
planning and implementation efforts, we reviewed relevant literature,
such as industry journals, federal guidance, and codes of standards on
disaster/emergency management and continuity programs. Because the
available literature was limited in its attention to human capital, we
conducted semistructured interviews and held a 1-day interactive
working session with experts from the private sector, federal agencies,
and other public sector organizations. With input from the National
Academy of Public Administration, the Private Sector Council, and FEMA,
the experts were selected based on their experience and knowledge of
human capital or emergency management as it relates to continuity.
Individuals from a total of 15 organizations, in addition to FEMA,
provided their expertise. The organizations included five federal
agencies--the Centers for Disease Control and Prevention, the
Department of Housing and Urban Development, the Department of Veterans
Affairs, the General Services Administration, and the Social Security
Administration; five private sector businesses--the Gillette Company,
Lockheed Martin Corporation, Macy's West, Marsh & McLennan Companies,
Inc., and Science Applications International Corporation; and five
public institutions--the Business Continuity Institute, the Disaster
Recovery Institute International, Emergency Management Alberta
(Canada), Clark-Atlanta University, and the University of Tasmania
(Australia). We supplemented the information from the expert panel by
interviewing officials from OPM, representatives from FEBs, and
representatives from federal employee unions.
To describe the COOP guidance issued by FEMA and the emergency
preparedness guidance and activities of OPM, we interviewed officials
from both agencies and analyzed relevant documents, including Federal
Preparedness Circular (FPC) 65, which is the primary federal COOP
guidance, and a series of emergency preparedness memorandums issued by
the Director of OPM. To describe the role FEBs play in coordinating
federal efforts relevant to COOP, we interviewed officials from OPM and
the Chicago, Cleveland, and Philadelphia FEBs.
Our review was conducted from February through December 2003 in
accordance with generally accepted government auditing standards.
Appendix I provides additional information on our scope and
methodology.
Results in Brief:
According to experts from private sector businesses, federal agencies,
and other public sector organizations with knowledge of human capital
or continuity planning, continuity planning efforts should and do give
priority to the immediate aftermath of a crisis--securing the safety of
all employees and addressing the needs of employees who perform or
directly support essential operations. However, the experts also note
that other human capital considerations, especially those associated
with the efforts of an organization to resume all other operations, are
also crucial and often have not been well developed. Given that the
majority of employees would be associated with resumption efforts
rather than essential operations, considering this segment of the
organization is an important part of continuity planning. The experts
we contacted identified two key human capital principles that should
guide all continuity efforts: demonstrate sensitivity to individual
employee needs and maximize the contributions of all employees to
mission results.
The experts also identified six organizational actions, which are
listed in table 1, to enhance continuity efforts by addressing
additional human capital considerations that are relevant to
continuity.
Table 1: Key Organizational Actions to Enhance Continuity Efforts:
Demonstrate top leadership commitment;
* Instill an approach to continuity planning that includes human
capital considerations.
* Allocate resources and set policies.
* Set direction and pace of recovery.
Seek opportunities for synergy;
* Integrate continuity efforts with broader decision making.
* Consider how continuity investments benefit other program efforts.
Maintain effective communication;
* Build relationships through two-way communication.
* Establish roles, responsibilities, and expectations.
* Develop redundant communication vehicles.
Target investments in training and development;
* Raise awareness of continuity efforts.
* Build skills and competencies to increase flexibility.
* Foster a culture that values flexible employees who are empowered to
make effective decisions.
Leverage the flexibility of human capital;
* Enable employees associated with resumption activities to contribute
to mission results in alternate assignments.
* Sustain the contribution of employees associated with essential
operations.
* Maintain organizational knowledge of staffing requirements and
availability.
Build process to identify and share lessons;
* Create a learning environment.
* Make learning explicit and shared.
Source: GAO.
[End of table]
In the federal government, FEMA, as executive agent for COOP, and OPM,
as the President's agent and advisor for human capital matters, have
exhibited leadership in addressing human capital considerations
relevant to COOP. For example, FEMA issued FPC 65, which is the primary
guidance for federal agencies to use in developing a viable COOP
capability, to address significant disruptions requiring relocation to
an alternate facility. However, the guidance does not recognize
significant disruptions that do not require relocation to an alternate
facility. Regarding human capital considerations, this guidance
directly addresses the need to secure the safety of all employees and
respond to the needs of personnel performing or supporting essential
operations. OPM has similarly addressed these primary considerations
through several initiatives, including establishing the Emergency
Preparedness subcommittee of the Chief Human Capital Officers Council,
releasing emergency guides for federal employees and managers, and
issuing a series of memorandums outlining the existing human resource
management flexibilities that agencies might employ in emergency
situations. However, neither FEMA's nor OPM's guidance to date has
adequately addressed the human capital considerations related to the
resumption of agency operations that are not considered essential.
Recognizing this, they are working together, as well as with other
federal partners, to more fully address the considerations inherent in
these resumption activities. One expected outcome of this partnership
is an updated and augmented federal COOP guidance that will more fully
address human capital considerations, particularly those regarding
employees who will be involved with broader resumption efforts.
Although not specifically tasked with coordinating COOP efforts, FEBs
are generally responsible for improving coordination among federal
activities in areas outside of Washington, D.C. Officials at OPM, which
provides direction to FEBs, have recognized that the boards can add
value to regional emergency preparedness efforts, including COOP, as
vehicles for communication, coordination, and capacity building. The
FEBs that we visited in Chicago, Cleveland, and Philadelphia are
already playing active roles in emergency preparedness and COOP efforts
by holding COOP training seminars, creating emergency preparedness
committees, and developing and activating emergency dismissal and
closure procedures. However, the lack of a specific role and defined
responsibilities for FEBs with regard to emergency preparedness
efforts, including COOP, as well as a funding structure that results in
differing capacities among FEBs, may lead to inconsistent levels of
preparedness across the nation.
Given the importance of human capital in maintaining essential
functions and resuming full operations during an emergency, we
recommend that the Secretary of Homeland Security direct the Under
Secretary of Emergency Preparedness and Response to expand the
definition of a COOP event to recognize severe disruptions that do not
affect facilities and complete efforts to revise federal COOP guidance
to more fully address human capital considerations by incorporating the
six actions identified in this report. We also recommend that the
Director of OPM more fully address human capital considerations in
emergency preparedness guidance by incorporating the six actions
identified in this report; and determine the appropriate role for FEBs
in coordinating emergency preparedness efforts, including COOP, and
address resulting capacity issues.
On March 10, 2004, we provided a draft of this report to the Secretary
of Homeland Security and the Director of OPM. We received written
comments from the Under Secretary of Emergency Preparedness and
Response on behalf of the Department of Homeland Security (DHS) and
FEMA and from the Director of OPM. In his comments, which are reprinted
in appendix III, the Under Secretary agreed that the report addresses
the human capital considerations that are relevant to COOP guidance and
coordination. He added that DHS and FEMA would incorporate our
recommendations in federal COOP guidance, work jointly with OPM and
other federal partners to improve the federal government's COOP
program, and expand the agency's efforts to improve coordination of
COOP program efforts at the regional level.
In her comments, which are reprinted in appendix IV, the Director of
OPM said the agency has already carried out our recommendation to more
fully address human capital considerations in emergency preparedness
guidance, including COOP, by incorporating the key actions identified
in the report. Most of the supporting examples provided by OPM were
included in the draft report and deal largely with human capital
considerations related to life safety and the needs of personnel
performing essential operations. While such initiatives are important
first steps, there remain opportunities to improve OPM's emergency
preparedness guidance to include a fuller range of human capital
considerations. As such, our recommendation to develop additional
emergency preparedness guidance that incorporates the key actions
identified in the report remains unchanged. The Director also stated
that the leadership role that OPM plays with respect to FEBs was not
sufficiently developed in the report. Most of the supporting examples
that the Director provided were included in the draft report. Moreover,
the additional examples generally do not address our larger point that
the role of FEBs in coordinating emergency preparedness efforts,
including COOP, needs to be clearly defined. As such, we maintain our
conclusion that the context in which FEBs currently operate, including
the lack of a clearly defined role in emergency preparedness efforts
and the varying capacities among FEBs, could lead to inconsistent
levels of preparedness across the nation. The Director of OPM also
suggested several clarifications to the report. We considered these
suggestions and made changes to the report where appropriate.
Background:
The policy of the U.S. government is to have in place a comprehensive
and effective program to ensure continuity of essential federal
functions under all circumstances.[Footnote 3] COOP planning is an
effort conducted by individual agencies to fulfill that policy and
assure that the capability exists to continue essential agency
functions across a wide range of potential emergencies. COOP has been
closely associated with continuity of government programs, which are
meant to ensure the survival of our constitutional form of government.
COOP was first conceived during the Cold War to ensure that the U.S.
government would be able to continue to function in case of a nuclear
war. However, in the wake of the demise of the Soviet Union and the
reduced threat of nuclear attack in the early 1990s, COOP planning
languished.
Following the World Trade Center bombing in 1993 and the Oklahoma City
bombing in 1995, COOP as a program was given renewed attention based on
the recognition of emerging threats and the need to continue essential
functions of the federal government in an all-hazards environment,
which includes acts of nature, accidents, technological emergencies,
and incidents related to military or terrorist attacks. A series of
Presidential Decision Directives (PDD) was issued that began to link
programs for terrorism, critical infrastructure protection, and
COOP.[Footnote 4] In addition, as we approached the turn of the
century, federal agencies also dealt with the Year 2000 computer
problem by developing business continuity and contingency plans to
ensure program delivery in the event of a technology failure or
malfunction. Federal COOP efforts have evolved by building upon the
planning for each of these events that focused on protecting critical
infrastructure, both physical systems and cyber-based systems. The
events of September 11, 2001, highlighted in dramatic fashion the
vulnerabilities agencies face in each of these areas and focused new
attention on the effects such events have on agencies' most important
assets--their people, or human capital.
FEMA, the General Services Administration (GSA), and OPM are the three
agencies that have the most direct impact on individual agency efforts
to develop viable COOP capabilities. PDD 67, which outlined individual
agency responsibilities for COOP, identified FEMA as the executive
agent for federal COOP planning. As executive agent, FEMA has the
responsibility for formulating guidance, facilitating interagency
coordination, and assessing the status of COOP capability across the
federal executive branch. PDD 67 also required GSA to work with FEMA in
providing COOP training for federal agencies and to assist agencies in
acquiring alternate facilities. In addition, the Federal Management
Regulation requires GSA to lead federal Occupant Emergency Program
(OEP) efforts, which are short-term emergency response programs that
establish procedures for safeguarding lives and property during
emergencies in particular facilities.[Footnote 5] As the President's
agent and advisor for human capital matters, OPM has been actively
involved in federal emergency preparedness efforts. OPM has issued a
series of emergency preparedness guides for federal managers,
employees, and their families; issued a number of memorandums relating
to planning, preparedness, and the flexibilities available to agencies
in emergency situations; and held emergency planning and preparedness
forums to help agencies select emergency personnel. In addition, FEMA,
GSA, and OPM collaborate to implement the Federal Workforce Release
Decision and Notification Protocol when emergency situations occur in
the Washington, D.C., area.
Human Capital Considerations Are Relevant to Continuity Planning and
Implementation Efforts:
The current literature indicates, and experts that we consulted
confirmed, that the immediate response to a crisis should give priority
to securing the safety of all employees and addressing the needs of
employees who perform or directly support essential operations. For
example, the standard for emergency management and business continuity,
which was developed by the National Fire Protection Association and
endorsed by FEMA, recommends that organizations include the following
priorities in their continuity program: ensuring the safety and health
of employees, establishing critical functions and processes, and
identifying essential representatives.[Footnote 6]
Consequently, the experts said that these priorities have received most
of the human capital attention in continuity efforts for both the
private and public sectors, including federal agencies. Appropriately,
organizations focus on minimizing the loss of life and injuries, which
is key to all other recovery efforts. Such efforts commonly include
first aid training, evacuation plans and drills, and dismissal
policies. Organizations also focus on identifying the core group of
employees that will establish and maintain essential operations as
dictated by an organization's mission. Organizations, for example,
commonly identify leadership structures to manage crisis response. Even
so, experts noted that organizations vary widely in their effectiveness
in addressing these priorities.
The continuity process, however, extends beyond the goals of life
safety and the performance of essential operations. The experts
identified a number of human capital considerations beyond these goals
that are not well addressed. For example, the priorities discussed
above do not address human capital considerations for employees who are
not involved in providing essential functions. Such employees would be
associated with efforts to fully resume all other operations and
represent the majority of an organization.
The experts identified two principles that should guide actions to more
fully address human capital considerations applicable to all continuity
planning and implementation efforts. The first is recognizing and
remaining sensitive to employees' personal needs during emergencies
when shaping the appropriate organizational expectations of employees.
The emergency event that activates continuity plans may also cause
emergency events in the personal lives of individual employees. Similar
to an organization placing its highest priority on the safety and well-
being of its employees, employees may have high-priority
responsibilities to others. These personal responsibilities may limit
employees' ability to contribute to mission accomplishment until these
other obligations are satisfied.
The second principle experts identified is maximizing the contributions
of all employees, whether in providing essential operations or resuming
full services. This should be done within the limits of an employee's
ability to contribute given the situation, as described in principle
one, and within the limits of the organization to use those
contributions effectively. According to the experts, the experience of
organizations during emergencies has been that employees remain
motivated to contribute to organizational results, which is
increasingly felt the longer the emergency continues. Enabling
employees to contribute promotes more effective delivery of essential
operations and more rapid resumption of full operations. In addition,
in extreme disruptions of employees' personal circumstances, providing
purposeful activities helps avoid the debilitating affects of a
disruption on employees, including job-related anxiety and post-
traumatic stress disorder.
The experts we interviewed also identified six organizational actions
to enhance continuity planning and implementation efforts, listed in
figure 1.
Figure 1: Six Organizational Actions to Enhance Continuity Efforts:
[See PDF for image]
[End of figure]
Each of these actions is described in more detail below.
Demonstrate top leadership commitment;
* Instill an approach to continuity planning that includes human
capital considerations;
* Allocate resources and set policies;
* Set direction and pace of recovery.
Our past work has shown that the demonstrated commitment of top leaders
is perhaps the single most important element of successful change
management and transformation efforts.[Footnote 7] Effective
continuity efforts have the visible support and commitment of their
organization's top leadership. According to the experts, traditional
continuity planning focuses on the operations side of recovery and
often overlooks human capital considerations. As such, it is important
for top leadership to ensure that the appropriate balance is achieved
in considering physical infrastructure, technology, and human capital.
In providing leadership prior to the emergency, leaders demonstrate
their commitment to human capital by establishing plans that value the
organization's intention to manage employees with sensitivity to their
individual circumstances, recover essential operations on a priority
basis, and resume other operations as quickly as possible.
Organizational leaders show commitment to continuity planning by
allocating resources and setting policies that effectively meet the
organization's continuity needs. The experts told us that committed
leaders provide sufficient funding and staff to conduct planning and
preparation efforts effectively. While the resources needed vary from
location to location within an organization, the experts said that
organizations should have enough resources available to develop
effective plans, test critical systems, train all staff, and conduct
simulation exercises. Committed top leadership also ensures that clear
policies and procedures are in place for all aspects of continuity to
ensure that quick and effective decisions are made during times of
emergencies. Those policies and procedures should be fair, shared with
employees and their representatives in advance of an emergency, and
able to be consistently applied to all employees. Experts and union
leaders we met with agree that the cooperation and input from all
components within the organization, including employees and their
representatives, is important in developing these policies.
Following a disruption to normal operations, top leadership sets the
direction and pace of organizational recovery. According to the
experts, top leadership sets direction by providing the legitimate and
identifiable voice of the organization for employees to rally around
during tumultuous times. An expert from Marsh & McLennan Companies,
Inc., a company that lost over 350 people in the World Trade Center on
September 11, 2001, noted that in the aftermath of an emergency there
is a fundamental need for a strong, visible leader to provide constant
reassurance. The expert added that "employees need to know that someone
is in control, even if the leaders do not know all the answers." In
addition, top leaders set the pace of organizational recovery by
providing leadership to both the management team leading recovery of
essential operations and the management team leading the resumption of
all other operations.
Seek opportunities for synergy;
* Integrate continuity efforts with broader decision making;
* Consider how continuity investments benefit other program efforts.
As we have previously reported, effective organizations integrate human
capital approaches as strategies for accomplishing their mission and
programmatic goals.[Footnote 8] According to the experts, strategic
decisions made to improve day-to-day operations, including human
capital approaches, and those made to build continuity readiness are
not exclusive of one another and may have synergies. For example, early
in 2001, GAO made the business decision to supply all of its analysts
with laptop computers for financial reasons and to provide employees
with flexibility in carrying out their work. That business decision,
however, also contributed to our ability to quickly adapt to
unforeseeable circumstances in October 2001. In response to the release
of anthrax bacteria on Capitol Hill, we opened our doors to the 435
members of the House of Representatives and selected members of their
staffs. Over 1,000 GAO employees were immediately able to make use of
their laptops to work from alternate locations. Consequently, we
minimized the disruption to our operations and assisted the House of
Representatives in continuing its operations. To take advantage of such
synergies, the experts said that decisions regarding continuity efforts
should be integrated with broader business decision making.
The integration of continuity planning with broader decision making
helps to ensure that the direction of all efforts is consistent and
provides mutual benefits. In a limited resource environment,
consideration of how continuity investments benefit other program
efforts also helps to strengthen the business case for human capital
investments that are meant to improve continuity capabilities, day-to-
day operations, or both.
Maintain effective communication;
* Build relationships through two-way communication;
* Establish roles, responsibilities, and expectations;
* Develop redundant communication vehicles.
The importance of communication cannot be overstated. According to the
experts, two-way communication with employees, their representatives,
and other stakeholders is key to building relationships and
partnerships that can facilitate organizational recovery efforts. We
have also previously reported that communication is most effective when
done early, clearly, often, and is downward, upward, and
lateral.[Footnote 9] According to a senior National Treasury Employees
Union (NTEU) official, the union was able to capitalize on ongoing two-
way communications with the Internal Revenue Service's (IRS) regional
leadership to provide members with information following the September
11, 2001, attacks. For example, during the recovery efforts, the union
provided supplementary channels for communicating with employees,
including daily joint messages from the IRS Regional Director and the
NTEU Chapter President. In addition, when the local New York office
reopened on September 20, 2001, both the NTEU National President and
the IRS Commissioner greeted employees at the door. From the union's
perspective, communication efforts such as these helped to provide
reassurance and support as well as to maintain employee trust.
According to experts, roles, responsibilities, and performance
expectations must be communicated to all employees, and their
representatives, prior to a disruption to promote the efficient and
effective use of all of an organization's human capital assets. Early
communication enables employees to assess and communicate to the
organization any personal circumstances that may limit their ability to
carry out those roles. The experts and union officials whom we spoke
with agreed that in some cases, more formal communication vehicles,
such as memorandums of understanding or addenda to collective
bargaining agreements, may be necessary to negotiate changes or clarify
roles and responsibilities in continuity plans.
Because effective emergency two-way communication depends greatly on
technology, alternate and redundant communication infrastructures are
necessary. In addition to technological vulnerabilities that can render
different methods of communication useless, people frequently do not
remain tied to the contact number or location listed in emergency
records. To address these challenges, Macy's West, for example, has
built an alternate emergency communication system that serves as an
employee message retrieval system. The system, which is based outside
of the region in case the local phone networks are overloaded, allows
(1) the leadership of Macy's West to leave messages with instructions
for employees, (2) family members to leave messages for employees, and
(3) employees to leave messages for their loved ones.
Target investments in training and development;
* Raise awareness of continuity efforts;
* Build skills and competencies to increase flexibility;
* Foster a culture that values flexible employees who are empowered to
make effective decisions.
Our past work has shown that organizations should consider making
targeted investments in human capital approaches, such as training and
development.[Footnote 10] According to the experts, training and
development programs related to continuity efforts can help to raise
awareness among all employees. The Social Security Administration
(SSA), for example, has developed a video-training course to provide an
overview of COOP, which includes an introduction from the Commissioner
explaining why COOP is so important, a discussion of SSA's critical
workloads and how they would be processed during a disruption, and
references to federal guides and information. The experts noted that
less formal approaches, such as continuity planning awareness weeks,
could also help to raise awareness.
Our recent work has indicated that training and development programs
build skills and competencies that enable employees to fill new roles
and work in different ways, which helps to build organizational
flexibility.[Footnote 11] According to experts, the training and
development goals for employees assigned to the team that performs
essential operations differ from those for the employees assigned to
the team that is responsible for resuming all other organizational
operations. The goal for the team that performs essential operations is
to achieve "critical depth," which occurs when an adequate number of
employees are available to staff each critical function, in the event
that a member of the team expected to perform that function is
unavailable. Organizations can build critical depth in various ways,
including using exercises that simulate an emergency to train backup
employees alongside employees who have primary responsibility for an
essential operation, or allowing backup employees to perform the
operation while the primary employees oversee and critique their
performance. In addition, critical depth can be built through
succession planning. To be effective for this purpose, however, the
scope of succession planning is extended to recognize that there is no
time to develop successors in an emergency and incrementally increase
levels of authority as an individual matures in a position. Therefore,
organizations may have to plan to use predecessors to a position,
including retirees, as successors.
With regard to the team that is responsible for resuming all other
organizational operations, experts said that the training and
development goal is to build sufficient breadth to enable members to
contribute to resumption efforts in a variety of ways. For example,
development programs requiring employees to rotate within an
organization to learn a variety of positions, potentially at a variety
of locations, contribute to critical breadth. We have previously
reported that developmental assignments place employees in new roles or
unfamiliar job environments in order to strengthen skills and
competencies and broaden their experience.[Footnote 12]
Effective training and development initiatives also help to foster a
culture that is characterized by flexible employees who are empowered
to make effective decisions independently. According to experts, such a
culture is often critical to agency recovery and resumption efforts.
Experts from Marsh & McLennan Companies, Inc., reported that effective
decision-making abilities could be developed through formal training
about the parameters in which employees are empowered to make decisions
and on-the-job experiences demonstrating how employees can exercise
authority in making decisions that manage, rather than avoid, risk and
are focused on achieving results.
Leverage the flexibility of human capital;
* Enable employees associated with resumption activities to contribute
to mission results in alternate assignments;
* Sustain the contribution of employees associated with essential
operations;
* Maintain organizational knowledge of staffing requirements and
availability.
The events of September 11, 2001, give ample evidence of the dedication
and flexibility of federal, state, and local government employees in
providing services to the American public. Disruption of normal
operations challenges an organization to use this dedication and
flexibility to its advantage, especially with regard to employees
associated with the resumption of all operations that are not
considered essential. According to the experts, organizations may use
approaches such as telework and geographic dispersion, which includes
regional structure, to increase the ways in which employees may
contribute. As OPM guidance has underscored and presenters at a recent
conference held by the International Telework Association and Council
noted, telework is an important and viable option for federal agencies
in COOP planning and implementation efforts, especially as the duration
of the emergency event is extended.[Footnote 13] However, to make
effective use of telework, experts told us that organizations should
identify those employees who are expected to telework during a
disruption and communicate that expectation to them in advance. In
addition, organizations should provide teleworkers with adequate
support in terms of tools, training, and guidance.[Footnote 14]
Geographic dispersion can also provide a way for employees associated
with resumption activities to continue their normal functions albeit
at or through other locations. For example, SSA recognizes that its
field structure enables the agency to make use of both multiple
locations and telework in providing its employees ways to contribute
because most field functions can be transferred fairly easily from one
location to another in the same region or performed remotely with
laptop computers. Based on these efforts, SSA does not envision a
scenario in which its field employees would not contribute to their
normal functions for more than 72 hours.
Employees demonstrate their flexibility by a willingness to contribute
to the organization in roles that may be unusual. According to the
experts, flexible employees contribute as best they can usually in the
following sequence: (1) providing support to the team performing
essential operations, if needed; (2) continuing to contribute to their
normal mission-related functions; (3) performing an alternate
contribution for their organization; or if none of these can be
accomplished, (4) volunteering in their communities as a direct form of
public service. Federal employees may have additional opportunities to
contribute to not only their own agencies' operations but also other
agencies' operations in serving the American people. In addition, a
recent memorandum from OPM recognizes the value of federal employees
contributing to the general public through community volunteer service
in the range of alternative contributions.[Footnote 15]
Employees associated with providing essential operations may be working
under unusual pressures for extended periods of time, and organizations
need to consider ways to sustain these efforts. The experts recommend
that if the circumstances of the emergency continue long enough to
raise concerns about burnout, organizations consider providing
opportunities for working in shifts; rotating assignments among team
members; providing relief through the use of qualified employees
associated with resumption activities; reemploying retirees; or
utilizing employees from stakeholder or networked organizations, such
as suppliers or contractors.
According to the experts, the ability of organizations to match
staffing requirements with available skills and abilities could be
enhanced through various initiatives, such as job banks, skill profile
databases, and pre-arranged partnerships with other organizations or
community service organizations. For example, job banks that detail
additional jobs that may be required during an emergency but are not
considered essential could allow employees to preselect alternate
contributions that they would be able to perform. In the federal
government, agencies could establish their own job banks; form
interagency partnerships that link the potential needs of several
agencies; and create a cache for volunteer opportunities, possibly tied
to the Citizen Corps.[Footnote 16] Organizations with databases that
collect employee knowledge, skills, and abilities (KSA)--even those
KSAs outside the scope of an employee's normal functions--may
complement the job banks by allowing organizations to match available
KSAs with the unmet needs of the organization.
Build process to identify and share lessons;
* Create a learning environment;
* Make learning explicit and shared.
An evaluation process that explicitly identifies and disseminates
lessons learned during disruptions, or simulations of disruptions,
promotes learning among all of an organization's human capital assets
and helps to improve organizational performance. An organization that
is committed to learning has an inclusive and supportive process and a
framework designed prior to a disruption to gather important data.
According to experts, organizations committed to learning will ensure
that those employees who are key to the recovery and resumption efforts
are involved in the formal evaluation process in a timely manner and
will seek the input from as many other employees as possible. Such an
inclusive environment will enable the organization to discover valuable
lessons learned by employees in unusual circumstances. In addition,
conducting evaluations in a "no-blame," nonattribution atmosphere and
taking organizational ownership of any problems that might be
identified increases the openness with which participants are willing
to share their experiences. To encourage such an environment, FEMA
officials told us that the agency's Office of National Security
Coordination has recently implemented a reporting system that allows
any employee to identify lessons learned anonymously during an
emergency, instead of waiting for the formal review process.
Our past work has shown that human capital approaches are best designed
and implemented based on data-driven decisions.[Footnote 17] According
to experts, having a framework prior to a disruption helps to gather
data important to evaluating the effectiveness of human capital
approaches during a disruption. Some measures that they suggested
include number of employees contributing to mission-related outcomes
each day; degree of contribution (e.g., part time or full time);
location of employee when contributing (e.g., at alternate facility or
home); type of contribution (e.g., performing same function, performing
an alternate function within the department, working with another
department, or volunteering); or obstacles to contribution (e.g.,
organizational or personal).
Once identified, it is important for the lessons learned during the
evaluation to be made explicit and then widely disseminated. According
to experts, the manner and formality of documentation and
dissemination, however, depend on the situation or needs of the
organization (e.g., after-action reports, detailed analyses, executive
summaries, video tapes, CDs, or Web-based reports). There are unique
opportunities in the federal government for agencies to share explicit
lessons learned both internally and with other federal agencies and
stakeholders. For example, following the September 11, 2001, attacks,
senior Department of Housing and Urban Development officials asked the
New York Acting Regional Director to recount her experiences and
lessons learned in front of a video camera. The accounts were edited
down into a 30-minute video entitled Thinking the Unthinkable:
Preparing for Disaster. That video has been used within the department
as a training aid and has been shared with over 50 federal agencies
with the help of the Washington, D.C.-based interagency COOP Working
Group (CWG) and the FEBs in cities across the United States. In Canada,
Emergency Management Alberta (EMA) employs a centralized Disruption
Incident Reporting System for all government agencies, which is
accessible via the Internet, to obtain timely and accurate reporting of
all disruptions and "most importantly, ensure lessons learned can be
documented for follow-up."[Footnote 18] EMA has also created a Lessons
Learned Warehouse Web site to share continuity lessons learned in all
aspects of crisis management.[Footnote 19]
FEMA and OPM Have Exhibited Leadership in Addressing Human Capital
Considerations Relevant to COOP:
As we stated earlier, the human capital considerations related to life
safety and the needs of personnel performing essential operations have
largely been addressed in continuity efforts. In the federal
government, FEMA has issued guidance that has addressed these
considerations and has recognized the opportunity to more fully address
human capital considerations in its guidance. In addition, OPM has
issued federal emergency preparedness guidance relevant to COOP that
also addresses these considerations and is working with FEMA to more
fully address human capital considerations in federal guidance.
FEMA Issued Guidance That Addresses Human Capital Considerations, but
Recognizes Opportunity to Do More:
As executive agent for federal COOP planning, FEMA issued FPC 65 in
July 1999 as the primary guidance for agencies developing viable COOP
plans. According to FPC 65, the purpose of COOP planning is to
facilitate the performance of agency essential functions for up to 30
days during any emergency or situation that may disrupt normal
operations. The five objectives of a viable COOP plan listed in FPC 65
are (1) ensuring the continuous performance of an agency's essential
functions during an emergency; (2) protecting essential facilities,
equipment, records, and other assets; (3) reducing or mitigating
disruptions to operations; (4) reducing loss of life, minimizing damage
and losses; and (5) achieving a timely and orderly recovery from an
emergency and resumption of full service to customers.
The guidance subsequently limits a COOP event to one that significantly
affects the facilities of an organization and requires the
establishment of essential operations at an alternate location.
Therefore, as FEMA recognizes, the guidance does not apply to
significant disruptions that leave facilities intact, such as a severe
acute respiratory syndrome (SARS) outbreak that could lead a large
number of employees to avoid congested areas, including their
workplaces. Although a people-only event such as SARS would
significantly disrupt normal operations, the current COOP guidance
would not apply because facilities would remain available. FPC 65 also
indicates that the guidance is for use at all levels and locations of
federal agencies. FEMA officials acknowledge, however, that the
priority of COOP planning to date has been focused on agency
headquarters located in the Washington, D.C., area.
Given the purpose of COOP and the nature of its objectives, the human
capital considerations FEMA included in the guidance primarily relate
to life safety for all employees and addressing the needs of employees
performing essential operations. For example, the guidance states that
one of the objectives of COOP is "reducing loss of life, minimizing
damage and losses." It also refers to the legal requirement that each
agency develop a viable OEP, which is a short-term emergency response
program that establishes procedures for safeguarding lives and property
during emergencies in particular facilities.[Footnote 20] FPC 65 more
broadly defines life safety by including a statement related to the
need to consider the health and emotional well-being of employees on
the essential operations team. Also, with respect to employees who
perform essential functions, the guidance directs agencies to designate
an emergency team, delegate authority, establish orders of succession,
develop communication plans, develop training programs, and provide for
accountability.
FEMA officials we spoke with recognized that there is a need to go
beyond the human capital considerations that have already been
addressed within federal COOP guidance in order to achieve the full
range of COOP objectives. Specifically, FEMA officials agreed that it
was particularly important to deal with the human capital
considerations inherent to the resumption activities needed to fully
recover from an emergency. To that end, FEMA has taken several steps to
more fully address these considerations. FEMA has worked with a
subcommittee of the interagency CWG--a Washington, D.C.-based group
that meets monthly to discuss issues related to COOP--to rewrite the
federal COOP guidance. The agency has requested OPM's assistance in
incorporating these considerations into the new federal COOP guidance.
FEMA has also worked in cooperation with us as we developed this
report. As a result, FEMA officials told us that the draft guidance
would include an augmented discussion of human capital considerations.
OPM Has Also Exhibited Leadership in Addressing Human Capital
Considerations Related to Emergency Preparedness:
OPM has also recognized the value of human capital in COOP and other
emergency preparedness efforts. In a memorandum to the heads of
executive departments and agencies, for example, the Director of OPM
stated that "the American people expect us to continue essential
government services without undue interruption, no matter the
contingency, and Federal agencies must have the human resources to
accomplish their missions, even under the most extreme of
circumstances."[Footnote 21] To this end, OPM has established the
Emergency Preparedness subcommittee of the Chief Human Capital Officers
Council that is tasked with recommending policy changes, legislative
changes, or other strategies for moving the issue forward. In addition,
OPM has initiated several efforts to help agencies address human
capital considerations in emergency preparedness related to life safety
and the needs of personnel performing essential operations, as well as
to recognize the role that employee organizations and unions could play
in supporting those efforts. These initiatives are important first
steps; however, they do not fully address human capital considerations
related to the resumption of all agency operations that are not
considered essential.
With regard to providing for the safety of all employees, OPM has
issued four preparedness guides to educate federal employees, managers,
and their families on how to protect themselves from a potential
biological,
chemical, or radiological release, whether accidental or
intentional.[Footnote 22] The guides also spell out the
responsibilities of the federal government and individual agencies to
protect employees in the event of an emergency. In addition to the
guides, OPM has addressed safety issues by revising the Washington,
D.C., area emergency dismissal protocols for federal employees and
contractors, in conjunction with FEMA and GSA; issuing memorandums to
all agency heads detailing the "minimum obligations" agencies have to
secure the safety of federal workers; issuing two emergency
preparedness surveys through which federal agencies could report on
their progress in ensuring the safety of their employees; and
highlighting the role that Employee Assistance Programs can play in
responding to employee needs in emergency situations.
Related to providing for the needs of employees performing or
supporting essential operations, OPM has led two forums focusing on
emergency employee designations and the flexibilities that are
available to agencies in emergency situations. OPM has also issued a
series of memorandums outlining the existing human resource management
flexibilities that agencies might employ in emergency
situations.[Footnote 23] Other human capital flexibilities that are
available to agencies in nonemergency situations, such as
telecommuting, job sharing, and flexible scheduling, might provide
additional assistance during emergency situations and are detailed in
OPM's handbook, Human Resources Flexibilities and Authorities in the
Federal Government. (See app. II for a list of human resource
flexibilities that agencies may use to respond to emergency
situations.):
In addition to initiating efforts to address several human capital
considerations, OPM has highlighted the need to work with and through
employee organizations and unions in developing and executing emergency
management strategies. For example, OPM has held meetings with federal
labor union leaders and employee associations to discuss relevant
employee safety issues and has specifically encouraged agencies to work
with and share information on preparedness efforts with applicable
employee organizations and unions. Senior union officials whom we spoke
with from the American Federation of Government Employees and NTEU
agreed that it is important for unions to be involved throughout COOP
planning and implementation efforts. These officials also stated that
unions could be resources for agencies in communicating with employees,
both before and during an emergency, as well as in engaging employees
in recovery and resumption efforts.
FEBs Have Opportunities to Coordinate Regional Emergency Planning
Efforts, Including COOP, in Major Metropolitan Areas:
Although FEMA heads the interagency CWG to help coordinate COOP efforts
in the Washington, D.C., area, the efforts of this group do not apply
to the over 80 percent of federal employees who work outside of this
area. While not specifically tasked with coordinating COOP efforts,
FEBs are generally responsible for improving coordination among federal
activities and programs in major metropolitan areas outside of
Washington, D.C.[Footnote 24] Under the direction of OPM, FEBs support
and promote national initiatives of the President and the
administration and respond to the local needs of federal agencies and
the community. OPM officials have recognized that FEBs can add value to
regional emergency preparedness efforts, including COOP, as vehicles
for communication, coordination, and capacity building. To make use of
these capabilities, OPM has provided FEBs with relevant emergency
preparedness materials, encouraged FEBs to focus on preparedness issues
in their regions, requested that FEBs test their emergency
communication plans, and encouraged FEBs to inform OPM of any
emergency-related events affecting federal employees in the regions.
The FEBs that we visited are already playing active roles in regional
emergency preparedness and COOP efforts. For example, the Chicago FEB
has established committees to deal with Disaster Recovery Planning and
Emergency Release; surveyed its member agencies to determine the status
of COOP planning in the region; sponsored a series of seminars, in
conjunction with GSA and FEMA, on topics related to COOP, sheltering in
place, and national security; participated in regional exercises, such
as TOPOFF 2;[Footnote 25] and sponsored a COOP exercise to provide
agencies with a forum for validating their COOP plans, policies, and
procedures. The Cleveland FEB has established an emergency preparedness
committee to promote awareness and preparation, developed an Employee
Emergency Contingency Handbook that provides basic actions to respond
to emergencies that may be encountered by federal employees, and helped
to make training available to all federal agencies. The Philadelphia
FEB has held several COOP workshops for agencies and regularly shares
relevant information with agency officials via e-mail. In addition,
these FEBs play a role in developing and activating dismissal and
closure procedures for federal agencies located in their particular
regions.
Although both OPM officials and the FEB officials whom we spoke with
recognized that FEBs can add value in coordinating emergency
preparedness efforts, including COOP, and that such a role is a natural
outgrowth of general FEB activities, a specific role and
responsibilities have not been defined. In addition, the current
structure in which FEBs operate results in differing capacities of FEBs
across the nation. For example, each agency's participation in FEB
activities is voluntary. Consequently, FEBs can only make
recommendations to agencies, without the ability to require agency
compliance. Also, FEBs rely on host agencies for funding, which results
in variable funding and staffing from year to year and across FEBs. OPM
has recognized that the roles and capacities of FEBs vary across the
nation and has established an internal working group to study the
strengths and weaknesses of FEBs and develop recommendations for
improving their capacity to coordinate in regions outside of
Washington, D.C. According to OPM, such efforts in regard to local
emergency preparedness and response will include improving
dissemination of information and facilitation of COOP training and
tabletop exercises; addressing the implications for strategic human
capital management in continuing the operations of the federal
government (e.g., alternate work schedules, remote work sites, and
telecommuting capabilities); and developing strategies to better
leverage the network of FEBs to help departments and agencies implement
their initiatives.
Conclusions:
More fully addressing human capital considerations in emergency
preparedness guidance, including COOP, could improve agency response
capabilities to large-scale COOP emergencies or situations; could help
minimize the impact of more common, yet less catastrophic disruptions
(e.g., snowstorms and short-term power outages); and is consistent with
building a more flexible workforce, which would enhance ongoing efforts
across the federal government to create more responsive human capital
management systems. As FEMA works to update its federal COOP guidance
and OPM continues to issue emergency preparedness guidance relevant to
COOP, several areas require attention to more fully address human
capital considerations relevant to COOP.
By limiting COOP to situations that necessitate moving to an alternate
facility, agencies are left without guidance for situations in which an
agency's physical infrastructure is unharmed, but its employees are
unavailable or unable to come to work for an extended period of time.
While facilities and technology would not be affected by such
situations, the unavailability of people to contribute to mission-
related outcomes could cause a significant disruption to normal
operations.
Emergency guidance, including COOP, generally does not extend beyond
consideration of life safety and the needs of employees performing
essential operations. Therefore, the guidance excludes most agency
employees--those who would be associated with resuming all other
operations.
FEBs are uniquely situated to improve coordination of emergency
preparedness efforts, including COOP, in areas outside of Washington,
D.C. However, the context in which FEBs currently operate, including
the lack of a clearly defined role in emergency preparedness efforts,
including COOP, and varying capacities among FEBs, could lead to
inconsistent levels of preparedness across the nation.
Recommendations for Executive Action:
We recommend that the Secretary of Homeland Security direct the Under
Secretary for Emergency Preparedness and Response to take the following
two actions:
* Expand the definition of a COOP event in federal guidance to
recognize that severe emergencies requiring COOP implementation can
include people-only events.
* Complete efforts to revise federal COOP guidance to more fully
address human capital considerations by incorporating the six
organizational actions identified in this report.
We recommend that the Director of OPM take the following two actions:
* Develop and provide additional emergency preparedness guidance to
more fully address human capital considerations by incorporating the
six organizational actions identified in this report.
* Determine the desired role for FEBs to play in improving coordination
of emergency preparedness efforts, including COOP, and identify and
address FEB capacity issues to meet that role. It would be appropriate
for FEBs to be formally incorporated into federal emergency
preparedness guidance, including COOP guidance, for areas outside of
Washington, D.C.
Agency Comments and Our Evaluation:
We provided the Secretary of Homeland Security and the Director of OPM
a draft of this report for review and comment. We received written
comments from the Under Secretary of Emergency Preparedness and
Response on behalf of FEMA and the Department of Homeland Security,
which are reprinted in appendix III. In his comments, the Under
Secretary stated that the draft accurately addressed human capital
considerations relevant to COOP guidance and coordination and noted
that DHS and FEMA will continue to work with OPM and other federal
partners to improve the federal government's COOP plan by incorporating
our recommendations in its federal COOP guidance. In addition, he
stated that FEMA would expand its efforts with its regional offices and
FEBs to improve coordination of COOP programs at the regional level.
The Director of OPM also provided written comments, which are reprinted
in appendix IV. In her comments, the Director noted her appreciation
for our acknowledgement of the agency's leadership role in addressing
human capital considerations relevant to COOP planning. However, the
Director of OPM stated that the agency has already carried out our
recommendation to more fully address human capital considerations in
emergency preparedness guidance, including COOP, by incorporating the
key actions identified in the report. The Director provided numerous
examples of actions OPM has taken to support emergency preparedness
efforts, all of which she noted were influenced by the agency's human
capital framework. In addition, the Director also attached an enclosure
to the agency comments that contain examples of OPM's internal COOP-
related efforts that she believes would be helpful to federal agencies.
Most of the examples of emergency preparedness guidance that the
Director of OPM provided were included in the draft report and deal
largely with the human capital considerations related to life safety
and the needs of personnel performing essential operations. While such
initiatives are important first steps, there remain opportunities to
improve OPM's emergency preparedness guidance to include a fuller range
of human capital considerations, particularly related to the resumption
of all agency operations that are not considered essential. As such,
our assessment of OPM's guidance and our recommendation for the agency
to develop and provide additional emergency preparedness guidance that
incorporates the key actions identified in the report remain unchanged.
With regard to our second recommendation for OPM to determine the
desired role of FEBs in improving coordination of emergency
preparedness efforts, including COOP, and address any resulting
capacity issues, the Director of OPM stated that the leadership role
the agency plays with respect to FEBs was not sufficiently developed in
the report and she provided examples of OPM's support for the FEB's
efforts. Most of the supporting examples that the Director provided
were included in the draft report. Moreover, the additional examples
generally do not address our larger point that the role of FEBs in
coordinating emergency preparedness efforts, including COOP, needs to
be clearly defined. As such, we maintain our conclusion that the
context in which FEBs currently operate, including the lack of a
clearly defined role in emergency preparedness efforts and the varying
capacities among FEBs, could lead to inconsistent levels of
preparedness across the nation.
The Director of OPM suggested several clarifications to the report,
which we considered and incorporated where appropriate. For example,
she suggested both technical and substantive changes to a footnote
describing Federal Executive Associations (FEA) and Federal Executive
Councils (FEC). While we made technical changes in response to these
comments, our work does not allow us to categorically exclude all FEAs
and FECs as viable options for the coordination of emergency
preparedness activities, as the Director suggested in her response.
Instead, we recognize that any guidance provided to FEBs would likely
be beneficial to FEAs and FECs despite their differences. The Director
also provided additional details describing OPM's internal working
group that is studying the strengths and weaknesses of FEBs, and we
have incorporated these details into the report.
We are sending copies of this report to the Ranking Minority Member,
Subcommittee on Oversight of Government Management, the Federal
Workforce, and the District of Columbia, Senate Committee on
Governmental Affairs; the Chairman and Ranking Minority Member, House
Committee on Government Reform; the Chairman and Ranking Minority
Member, Subcommittee on Homeland Security, House Committee on
Appropriations; the Chairman and Ranking Minority Member, Subcommittee
on National Security, Emerging Threats, and International Relations,
House Committee on Government Reform; and other interested
congressional parties. We will also send copies to the Secretary of
Homeland Security, the Under Secretary of Emergency Preparedness and
Response and the Director of OPM. This report will also be available at
no charge on the GAO Web site at [Hyperlink, http://www.gao.gov].
If you or your staff have any questions concerning this report, please
contact me or William Doherty on (202) 512-6806. Key contributors to
this report include Kevin J. Conway, Tiffany Tanner, Thomas Beall, Amy
Choi, Amy Rosewarne, John Smale, and Michael Volpe.
Sincerely yours,
Signed by:
J. Christopher Mihm:
Managing Director, Strategic Issues:
[End of section]
Appendixes:
Appendix I: Objectives, Scope, and Methodology:
The objectives of this report were to:
* identify the human capital considerations that are relevant to
federal agencies' continuity planning and implementation efforts;
* describe the continuity of operations (COOP) guidance provided by the
Federal Emergency Management Agency (FEMA) and emergency preparedness
guidance and activities of the Office of Personnel Management (OPM) to
address human capital considerations relevant to COOP; and:
* describe the role Federal Executive Boards (FEB) play, relevant to
COOP, in coordinating efforts outside of the Washington, D.C., area.
To address human capital considerations that are relevant to continuity
planning and implementation efforts, we reviewed relevant literature,
such as industry journals, federal guidance, and codes of standards on
disaster/emergency management and continuity programs. Because the
available literature was limited in its attention to human capital, we
based our work primarily on semistructured interviews with experts from
private sector businesses, federal government agencies, and public
institutions. We first reviewed industry journals, magazines, and Web
sites; queried state and international auditors; attended a national
business continuity conference; and sought input from the National
Academy of Public Administration (NAPA), the Private Sector Council
(PSC), and FEMA to identify individuals or organizations with the
relevant knowledge needed to address our first objective. We selected
individuals or organizations that had one or more of the following
characteristics: (1) experience responding to, recovering from, and
resuming business activities following an emergency, from which human
capital lessons may have been drawn; (2) experience incorporating human
capital considerations into their organization's continuity planning
efforts; (3) specific human capital expertise that could be applied to
continuity planning and implementation efforts; and (4) specific
continuity expertise that is broad enough to identify those critical
areas that require human capital attention. When an organization was
selected, we then contacted the organization to identify the specific
individuals who had the relevant expertise.
On the basis of these characteristics and the input from NAPA, PSC, and
FEMA, we selected organizations or individuals within organizations to
obtain a diversity of views from both the public and private sector.
Individuals from a total of 15 organizations, in addition to FEMA,
provided their expertise in addressing our objective. The organizations
include five federal agencies--the Centers for Disease Control and
Prevention, the Department of Housing and Urban Development, the
Department of Veterans Affairs, the General Services Administration,
and the Social Security Administration; five private sector businesses-
-the Gillette Company, Lockheed Martin Corporation, Macy's West, Marsh
& McLennan Companies, Inc., and Science Applications International
Corporation; and five public institutions--the Business Continuity
Institute, the Disaster Recovery Institute International, Emergency
Management Alberta (Canada), Clark-Atlanta University, and the
University of Tasmania (Australia).
We then conducted three cycles of work to identify the human capital
considerations that are relevant to continuity, with each subsequent
cycle building upon the information gathered in previous cycles. We
adopted this approach because our initial conversations with experts
indicated that a common perspective of the continuity process could
help structure and focus our subsequent interviews with experts about
the relevant human capital considerations. Cycle one involved
conducting semistructured interviews with experts from FEMA and 5 of
the 15 organizations.[Footnote 26] We asked each to describe a view of
the entire continuity process from a human capital perspective. We used
those descriptions to synthesize a framework that we then shared with
each of the first cycle experts for comment. The experts generally
agreed with the content of the framework and agreed that it would be
useful in focusing subsequent interviews about human capital
considerations. In the second cycle, we used this framework as a
reference when conducting in-depth, semistructured interviews with
experts from all 15 organizations and FEMA about the human capital
considerations relevant to continuity. For the third cycle, we held a
1-day working group, in cooperation with FEMA, to more fully discuss
the human capital considerations previously identified in cycles one
and two. The interactive nature of the working group,which included a
cross-section of the experts and additional representatives from
GAO,[Footnote 27] helped to ensure that we had adequately captured the
key considerations relevant to continuity. As a final check, we
provided all of the experts with a summary document that included the
statements used throughout this report and attributed to the experts.
We asked the experts to review the statements for fundamental
disagreement or fatal flaws. Almost all experts responded and generally
agreed with our treatment of these issues.
To supplement information we received in the three cycles, we held
additional interviews with officials from OPM; representatives from the
Chicago, Cleveland, and Philadelphia FEBs; and representatives from the
National Treasury Employees Union (NTEU) and the American Federation of
Government Employees (AFGE). We spoke with representatives of the FEBs
because the FEBs' role as coordinative bodies in regions across the
nation gives them a unique view of federal emergency preparedness
efforts outside of the Washington, D.C., area. We spoke with
representatives from NTEU and AFGE because unions can play a key role
in addressing human capital considerations.
To describe the COOP guidance provided by FEMA and emergency
preparedness guidance and activities of OPM to address human capital
considerations relevant to COOP, we interviewed officials from both
agencies. In addition, we reviewed and analyzed relevant documents. For
example, we reviewed Federal Preparedness Circular 65, the primary
guidance for federal executive branch COOP, to identify the human
capital considerations that are included in federal COOP guidance. We
also reviewed OPM publications, including four emergency preparedness
guides and a series of memorandums that list available agency
flexibilities in times of emergencies.
To describe the role FEBs play, relevant to COOP, in coordinating
efforts outside of the Washington, D.C., area, we held interviews with
officials from OPM with responsibility for FEBs nationwide and
representatives from the three FEBs discussed above.
We conducted our work from February 2003 through December 2003 in
accordance with generally accepted government auditing standards.
[End of section]
Appendix II: Emergency Human Capital Flexibilities Listed in OPM
Emergency Memorandums:
OPM has issued a series of memorandums outlining the existing human
resources management flexibilities that executive departments and
agencies might employ in emergency situations with and without OPM
approval.[Footnote 28] Other human capital flexibilities and programs,
such as those detailed in OPM's handbook, Human Resources Flexibilities
and Authorities in the Federal Government,[Footnote 29] that are
available to agencies in nonemergency situations may also provide
additional assistance in responding to and recovering from COOP
emergencies. For additional information on these flexibilities, OPM has
advised that agency chief human capital officers, human resources (HR)
directors, or both should contact their assigned OPM human capital
officer. Employees are advised to contact their agency HR offices for
assistance.
A compilation of the emergency flexibilities outlined by OPM in its
emergency guidance memorandums appears below.
Leave:
Excused Absence:
Agencies have the discretion, without OPM approval, to grant excused
absence to employees who are prevented from reporting to work because
of an emergency. The authority to grant excused absence also applies to
employees who are needed for emergency law enforcement, relief, or
recovery efforts authorized by federal, state, or local officials
having appropriate jurisdiction and whose participation in such
activities has been approved by the employing agency. Military leave
under 5 U.S.C. § 6323(b) is appropriate for federal employee members of
the National Guard or Reserves who are called up to assist in an
emergency.[Footnote 30]
Emergency Leave Transfer Program:
Subject to approval by the President, OPM may establish an emergency
leave transfer program, which is separate from the federal leave-
sharing program, to assist employees affected by an emergency or major
disaster. Under 5 U.S.C. § 6391, the emergency leave transfer program
would permit employees in an executive agency to donate unused annual
leave for transfer to employees of the same or other agencies who have
been adversely affected by an emergency and who need additional time
off work without having to use their own paid leave. If agencies
believe there is a need to establish an emergency leave transfer
program to assist employees affected by an emergency, they are to
contact their OPM human capital officer.
Pay:
Premium Pay for Employees Performing Emergency Overtime Work:
In certain emergency or mission-critical situations, agencies have the
discretion, without OPM approval, to apply an annual premium pay cap
instead of a biweekly premium pay cap, subject to the conditions set
forth in 5 U.S.C. § 5547(b) and 5 C.F.R. § 550.106. In this regard, the
agency head, his or her designee, or OPM may determine that an
emergency exists. Agencies have the discretion, without OPM approval,
to apply an annual cap to certain types of premium pay for any pay
period for (1) employees performing work in connection with an
emergency, including work performed in the aftermath of such an
emergency, or (2) employees performing work critical to the mission of
the agency. Such employees may receive premium pay under these
conditions only to the extent that the aggregate of basic pay and
premium pay for the calendar year does not exceed the greater of the
annual rate for (1) General Schedule (GS)-15 step 10 (including any
applicable special salary rate or locality rate of pay, or (2) level V
of the Executive Schedule.
Furlough:
In some emergency situations, agencies have the discretion, without OPM
approval, to furlough employees, that is, to place them in a temporary
status without duties and pay for nondisciplinary reasons. Under 5
C.F.R. § 752.404(d)(2), agencies are relieved of the requirement to
provide employees advanced notice and an opportunity to respond when
the furlough is based on "unforeseeable circumstances," such as a
sudden breakdown in equipment, an act of nature, or a sudden emergency
requiring the agency to immediately curtail activities.
Benefits:
Workers' Compensation Benefits:
Workers' compensation benefits are available when federal employees are
injured or killed while on duty. The Department of Labor may establish
special procedures to provide direct assistance to affected employees
and their families.
Expedited Processing of Retirement and Life Insurance Benefits:
To assist agencies in responding to employee needs during and after an
emergency situation, OPM may establish special expedited arrangements
for processing disability retirement applications; survivor benefits;
and payments under the Federal Employees Group Life Insurance Program,
currently administered by the Metropolitan Life Insurance Company.
Death Gratuity:
Under Section 651 of Pub. L. No. 104-208 (Omnibus Consolidated
Appropriations Act, 1997), 5 U.S.C. § 8133 note, agencies have the
authority, without OPM approval, to pay up to $10,000 to the personal
representative of a civilian employee who dies in the line of duty.
Telework:
Agencies have the discretion, without OPM approval, to approve
telecommuting arrangements and alternative work sites to accommodate
emergency situations. According to OPM, one of the major benefits of
the telework program is the ability of telework employees to continue
working at their alternative work sites during a disruption to
operations. In recognition of the growing importance of teleworkers in
the continuity of agency operations, OPM states that agencies may wish
to modify their current policies concerning teleworkers and emergency
closures. Agencies may also wish to require that some or all of their
teleworkers continue to work at their alternative work sites on their
telework day during emergency situations when the agency is closed.
Although agencies would not have to designate a teleworker as an
emergency employee, OPM states that any requirement that a telework
employee continue to work if the agency closes on his or her telework
day should be included in the employee's formal or informal telework
agreement.
Emergency Hiring Flexibilities:
Emergency Critical Hiring:
Under 5 C.F.R. § 213.3102(i)(2), agencies have the discretion, without
OPM approval, to fill positions for which an emergency or critical
hiring need exists; however, initial excepted appointments under this
authority may not exceed 30 days and may be extended only for an
additional 30 days. Such an extension may be made only if the
appointee's continued employment would be essential to the agency's
operations.
Under 5 C.F.R. § 213.3102(i)(3), OPM may also grant agencies the
authority to temporarily appoint individuals to the excepted service in
positions for which OPM has determined that examination is
impracticable (e.g., because of the time involved). For example, in the
aftermath of the September 11, 2001, attacks, OPM granted agencies
authority to fill positions affected by or that needed to deal with the
attacks for up to 1 year, and later extended that authority.
When OPM grants agencies the authority to appoint individuals under 5
C.F.R. § 213.3102, agencies, not OPM, are responsible for establishing
the qualifications that an individual must have to fill the position.
In addition, in accordance with 5 C.F.R. pt. 330, agencies are not
required to comply with the regulations regarding the Career Transition
Assistance Plan (CTAP), Reemployment Priority List (RPL), and
Interagency CTAP (ICTAP) because these regulations do not apply to
excepted appointments.
Agencies have the discretion, without OPM approval, to use the
authority granted by OPM under 5 C.F.R. § 213.3102 to fill senior-level
positions, as well as positions at lower levels. Under appropriate
circumstances, OPM may also authorize agencies to use a senior-level
position allocation to appoint an individual under this section (5
C.F.R. § 319.104).
Direct-Hire Authority:
Agencies have the authority to appoint candidates directly when OPM
determines there is a critical hiring need, or a shortage of
candidates, for particular occupations, grades (or equivalent),
geographic locations, or some combination of the three. This authority
can be governmentwide or limited to one or more specific agencies
depending on the circumstances.
OPM has granted governmentwide direct-hire authority for GS-0602
Medical Officers, GS-0610 and GS-0620 Nurses, GS-0647 Diagnostic
Radiologic Technicians, and GS-0660 Pharmacists, at all grade levels
and all locations, and for GS-2210 Information Technology Specialists
(Information Security) positions at GS-9 and above, at all locations,
in support of governmentwide efforts to carry out the requirements of
the Government Information Security Reform Act and the
Federal Information Security Management Act. OPM also approved a
direct-hire authority that permits agencies to immediately appoint
individuals with fluency in Arabic or other Middle Eastern languages to
positions in support of the reconstruction efforts in Iraq.
Agencies have the discretion, without OPM approval, to give individuals
in the categories, occupations and specialties, and grades listed above
competitive service career, career-conditional, term, temporary,
emergency indefinite, or overseas limited appointments, as appropriate.
In all cases, agencies must adhere to public notice requirements in
5 U.S.C. §§ 3327 and 3330 and ICTAP requirements.
If agencies believe they have one or more occupations for which an
agency-specific direct-hire authority may be appropriate in support of
emergency relief and recovery efforts, they are to contact their OPM
human capital officer.
Senior Executive Service Limited Emergency Appointments:
To meet a bona fide, unanticipated, urgent need, agencies have the
authority under 5 C.F.R. § 317.601 to make Senior Executive Service
limited emergency appointments of career employees, without OPM
approval. OPM approval is required to appoint individuals who are not
current career employees and OPM cannot delegate this authority;
however, OPM will process such requests on a priority basis and will
also consider temporary position allocations for agencies that identify
the need as essential to deal with the emergency.
Reemploying Retirees:
Agencies have the discretion, without OPM approval, to employ retirees
to deal with an emergency, to replace employees called to active duty
military service, or both. Agencies may immediately offer reemployment
to retirees under any applicable appointing authority. However,
generally, dual compensation restrictions (e.g., 5 U.S.C. §§ 8344 and
8468) require agencies to reduce the pay of a federal civil service
retiree by the amount of his or her annuity. For details, see the CSRS
and FERS Handbook for Personnel and Payroll Offices, Chapter 100 -
Reemployed Annuitants.
OPM may waive these dual compensation restrictions and, upon request,
may also delegate such authority to an agency head or designee to deal
with emergency staffing requirements. See 5 C.F.R. pt. 553 for details.
Dual compensation waivers cannot be approved retroactively. However,
according to OPM guidance, annuitants who agree to work under salary
offset pending a dual compensation waiver may be recognized for their
special service by the agency through an individual cash award.
Reemploying Voluntary Separation Incentive Payment Recipients:
Ordinarily, employees who resign or retire upon acceptance of a
voluntary separation incentive payment (VSIP) (or buyout) can be
reemployed only if they agree to repay the amount of that payment.
However, upon agency's request, OPM may waive the repayment requirement
if the individual's reemployment is necessary to deal with the
emergency situation. (See 5 C.F.R. § 576.203(a)(1).) Persons being
considered for VSIP repayment waivers must be the only qualified
applicants available for the positions and possess expertise and
special qualifications to replace persons lost or otherwise
unavailable. Waivers may be limited by the agency's specific statutory
VSIP authority.
Other Emergency Hiring Flexibilities:
Under 5 C.F.R. pt. 300, subpart E, agencies have the discretion,
without OPM approval, to contract with private sector temporary
employment firms for services to meet their emergency staffing needs.
These contracts may be for 120 days and may be extended for an
additional 120 days, subject to displaced employee procedures.
Agencies have the discretion, without OPM approval, to make competitive
service appointments of 120 days or less without regard to CTAP, ICTAP,
or RPL eligibles. These programs do not apply to such appointments. See
5 C.F.R., pt. 330, Subparts F and G for CTAP/ICTAP conditions and 5
C.F.R. § 330.207(d) for RPL conditions.
Agencies have the discretion, without OPM approval, to appoint current
and former employees from RPL to temporary, term, or permanent
competitive service appointments. Conversely, agencies may make
exceptions to the RPL provisions to appoint others under 5 C.F.R.
330.207(d).
[End of section]
Appendix III: Comments from the Federal Emergency Management Agency:
Office of the Under Secretary:
U.S. Department of Homeland Security
500 C Strect, SW:
Washington, DC 20472:
FEMA:
April 1, 2004:
Mr. J. Christopher Mihm
Managing Director
Strategic Issues,
General Accounting Office
441 G Street, N.W.
Washington, D.C. 20548:
Dear Mr. Mihm:
We have reviewed the draft report number GAO-04-384 titled "Human
Capital - Opportunities to Improve Federal Continuity and Planning
Guidance." We appreciate the opportunity to work with the General
Accounting Office (GAO) during the report's preparation and wish to
thank them for their hard work. We believe that the final draft
accurately addresses human capital considerations relevant to COOP
guidance and coordination.
The Department of Homeland Security and Federal Emergency Management
Agency will continue to work jointly with the Office of Personnel
Management and our other Federal partners to improve the Federal
Government's COOP program by incorporating GAO recommendations in our
COOP guidance. Further, we will continue to expand our efforts with our
Regional Offices and the Federal Executive Boards to improve
coordination of COOP program efforts at the regional level.
If additional information is needed, please contact Mr. Reynold N.
Hoover, Director, Office of National Security Coordination at 202-646-
4145.
Sincerely,
Signed by:
Michael D. Brown:
Under Secretary Emergency Preparedness and Response:
cc:
Tom Ridge, Secretary, DHS:
Admiral James Loy, Deputy Secretary, DHS
Duncan Campbell, Chief of Staff, DHS:
[End of section]
Appendix IV: Comments from the Office of Personnel Management:
OFFICE OF THE DIRECTOR:
UNITED STATES OFFICE OF PERSONNEL MANAGEMENT
WASHINGTON, DC 20415-0001:
APR 01 2004:
Mr. J. Christopher Mihm:
Managing Director, Strategic Issues
United States General Accounting Office
441 G Street, NW.
Washington, DC 20548:
Dear Mr. Mihm:
Thank you for the opportunity for the Office of Personnel Management
(OPM) to review and comment on the General Accounting Office's (GAO)
draft report, HUMAN CAPITAL: Opportunities to Improve Federal
Continuity Planning Guidance (GAO-04-384). We appreciate GAO's
continued support and this report's acknowledgement of our leadership
role and our accomplishments in addressing human capital considerations
relevant to planning for continuity of operations (COOP).
In the past several years, the necessity for the Federal Government to
be prepared to operate during crisis situations has intensified.
Agencies have dealt with emergencies ranging from bad weather, like
hurricanes and snowstorms, to the tragic, unexpected terrorist attacks.
OPM, in sharing a leadership role with the Federal Emergency Management
Agency (FEMA) and the General Services Administration (GSA), has made
it a priority to ensure agencies have the guidance and training
necessary to plan for such situations.
While the report gives OPM high marks in the area of emergency
preparedness education and issues directly related to COOP, it points
out discrepancies and shortcomings in other areas. The primary
criticism leveled at OPM (and FEMA) is that neither agency has issued
guidance adequately addressing human capital considerations related to
the resumption of broader agency operations after an emergency. We
respectfully disagree and provide the following examples of what OPM
has done to support this effort:
* We issued a series of Emergency Preparedness Guides for Federal
managers, employees and their families. The guides are available on the
OPM Web site. * We issued memorandums at the time of emergencies, such
as Hurricane Isabel and the California wildfires, to provide agencies
with flexibilitics available for managing their workforce during crisis
situations.
* We approved the immediate use of additional flexibilities in response
to the 9/11 national emergency, such as emergency temporary
appointments under Schedule A, Senior Executive Service limited
emergency appointments, salary offset waivers to reemploy annuitants,
and Voluntary Separation Incentive Pay (buyout) repayment waivers.
* We issued two annual emergency preparedness surveys to agencies. OPM's
Human Capital Officers then contacted agencies to discuss all items
indicated as not yet completed.
* We established policy regarding teleworking opportunities and benefits
for planned use during closures. OPM and GSA jointly established a
telework website to provide access to guidance issued by both of our
agencies.
* We hosted Emergency Planning and Preparedness Forums to address each
agency's authorities upon closure of the Federal Government in
emergency situations. The forums focused on available flexibilities,
designating emergency personnel, transportation and communications
issues, along with providing time for agencies to share their best
practices. More than 250 employees from over 75 agencies attended the
forums.
* We identified, in concert with the Chief Human Capital Officers
Council, emergency preparedness as one of five key areas critical to
the success of the strategic management of human capital and have
established the Subcommittee on Emergency Preparedness. The
subcommittee is tasked with recommending policy changes, needed
legislation, and other strategies necessary to move issues forward.
One of the primary concerns noted in the GAO report is the resumption
of all agency services, not just essential services, in the wake of an
emergency. This year, OPM's annual survey for emergency preparedness
included questions relating to telework employees. In addition, OPM
issued memorandums to heads of departments and agencies strongly
encouraging telework options as part of their emergency preparedness
procedures. Planned use of telework during a crisis situation will help
address this issue raised in the GAO report.
Two specific actions are recommended for the OPM Director (page 28).
The first recommendation is to more fully address human capital
considerations by incorporating the six key organizational actions
identified in the report. OPM's framework for human capital, developed
in collaboration with GAO, incorporates the six organizational actions
to enhance continuity efforts. The framework provides the context for
our discussions with agencies on human capital, which includes guidance
on emergency preparedness. It is our contention that not only is this
recommendation currently being carried out but has, in fact, been in
place since September 11tH. Provided as an enclosure is a point-by-
point demonstration of measures OPM has taken internally under each of
the six organizational actions. The enclosure will provide agencies
with an example of how OPM has implemented certain COOP initiatives.
The second recommendation for the OPM Director is to determine the
desired role for the Federal Executive Boards (FEBs) to play in
improving coordination of emergency preparedness efforts, including
COOP, and identify and address FEB capacity issues to meet that role.
We note that overall the report has captured the essence of the
activities undertaken by OPM. However, we believe the leadership role
played by OPM, particularly with respect to the FEBs is not
sufficiently developed in the report.
Specifically, on pages 23 and 24 of the draft report, the discussion of
OPM's leadership role should be broadened to include what it has done
to transform the role of the FEBs, particularly in the post-9/11
environment. For example, OPM has developed communications protocols
for emergency preparedness operations for a variety of circumstances,
such as natural disasters, national security operations, and other
unforeseen events that may cause interruptions to the normal course of
operations.
Additionally, on page 25 of the draft report, in discussing the role of
the FEBs, it should be noted that OPM's leadership role has included
expanding its annual FEB training program to cover emergency
preparedness, employee security, and continuity of operations. OPM has
facilitated teleconferences between FEMA and FEBs, and has worked to
enhance the role of FEBs in the continuity of operations planning
process.
Currently, OPM is working with FEMA to provide the FEBs the technical
assistance and staffing they need to build full capacity in this area.
A pilot project with key FEBs is slated to begin this summer.
We recommend the following changes to wording of the draft report:
1. Page 25, footnote - The footnote that references Federal Executive
Associations/Councils (FEA/Cs) is poorly worded, and may create
unrealistic expectations that FEA/Cs can assume the same role as FEBs
in COOP/emergency situations. FEA/Cs are not officially established
bodies. They rely on volunteer members. OPM maintains a listing of the
FEA/Cs to have a point-of-contact for those Federal communities;
however, we do not have official oversight responsibility for FEA/Cs.
They do not have permanent status and often disband and regroup
depending on the local commitment of agency members.
Recommendations:
* Strike the footnote; or:
* Reword the footnote to read: "While this section focuses on FEBs, we
recognize the presence of Federal Executive Associations (FEAs) and
Federal Executive Councils (FECs) in cities where FEBs do not exist.
FEAs and FECs have purposes and objectives similar to FEBs although
they do not function within the same formal set of parameters (e.g.,
officially established by Presidential Memorandum, policy direction and
guidance from the Office of Personnel Management, etc.) as do the FEBs.
FEAs and FECs do not have permanent status and, therefore, are not
currently a viable option for a role in COOP.":
2. Page 26, 2nd paragraph, last sentence - The report states that OPM
"has established an internal working group to study the strengths and
weaknesses of FEBs and develop recommendations for improving the FEB s'
capacity to coordinate in regions outside Washington, D.C.":
Recommendation: Reword to "OPM has established an internal working
group to improve the FEBs' capacity to support local emergency
preparedness and response. Such efforts include:
* Improving dissemination of information, facilitation of COOP training
and tabletop exercises;
* Addressing the implications for strategic Human Capital management in
the continuing the operations of the Federal Government (e.g.,
alternate work schedules, remote work sites, and telecommuting
capabilities); and * Developing strategies to better leverage the
network of FEBs to help departments and agencies implement their
initiatives.":
3. Page 38, Direct-Hire Authority-Missing from this section is the
reference of two additional Governmentwide direct-hire authorities.
On June 20, 2003, OPM approved a direct-hire authority for Nurses in
both the GS-0610 and GS-0620 series. The GS-0620 direct-hire authority
was omitted from the report and should be added.
On July 01, 2003, OPM approved a direct-hire authority in support of
the Administration's critical reconstruction efforts in Iraq. This
direct-hire authority permits agencies to immediately appoint
individuals with fluency in Arabic or other related Middle Eastern
languages to positions in support of those reconstruction efforts.
OPM looks forward to receiving GAO's final report on improving Federal
continuity planning guidance and we will continue with our commitment
to assist agencies with emergency planning and preparedness.
Sincerely,
Signed by:
Kay Coles James:
Director:
Enclosure:
The following is a point-by-point demonstration of what the Office of
Personnel Management(OPM), through guidance from the Director, has
accomplished under each of the six key organizational actions
identified in the General Accounting Office's (GAO) draft report, HUMAN
CAPITAL: Opportunities to Improve Federal Continuity Planning Guidance
(GAO-o4-384).
(A) DEMONSTRATE TOP LEADERSHIP COMMITMENT (P. to of Draft Rpt):
* Instill an approach to continuity planning that includes human
capital considerations:
The paragraph explaining this bullet point reads in part, "...in
providing leadership prior to an emergency, leaders demonstrate their
commitment to human capital by establishing plans that value the
organization's intention to manage employees with sensitivity to their
individual circumstances...":
It is very clear that the OPM Director has incorporated this point in
her overall management philosophy as it pertains to individual
employees. There are several examples:
1) The following two paragraphs are lifted verbatim from OPM's report
to the 9-11 Commission. The passage reflects what was utmost on the OPM
Director's mind in the midst of horrific chaos on the morning of
September 11, 2001:
"OPM Associate Directors and heads of offices began reporting their
emergency contingencies to the Office of the Director as calls from
other Departments across government began filtering in through an
increasingly overloaded phone system. Within minutes of the Pentagon
attacks, streets in downtown Washington, DC were becoming gridlocked.
Multiple large agencies called OPM to either request or inform the
Director of their decisions to let their workforce leave early. Looking
down on the clogged streets from her 5TH floor office, the Director knew
that with all the uncertainties of that fateful hour, staying inside
might be the safest course of action for some Federal employees. She
also recognized that thousands of workers in the Federal Government
likely had children in day care facilities or had panicked children and
loved ones in the surrounding suburbs and there was no way those
individuals were going to remain at work.
At 9:50 am, Director James huddled with her core senior staff and asked
for recommendations and thoughts. Questions from representatives of the
Washington, DC press corps were already streaming in and in fact,
several reporters were in the OPM complex requesting interviews. At
9:58 am ...16 minutes after the attack on the Pentagon, Director James
made the decision to close Federal offices in the Washington, DC area
with the caveat that Federal employees may leave but no one was being
forced out of their building into the growing gridlock and confusion in
the DC streets.
2) When Hurricane Isabel was bearing down on the Washington, DC
metropolitan area in mid September 2003, ominous weather reports and
the subsequent closure of the regional subway system forced the OPM
Director to close Federal offices. Here is a paragraph from the
Director's official announcement that was disseminated to Federal
employees and media outlets in the region,
"In an abundance of caution for the safety and security of Federal
employees and in light of the disruptions of major transportation and
power systems in the region, Federal agencies in the Washington DC area
will remain closed on September 19th. The OPM Director realizes that
there will be Federal employees who will not be impacted by the storm
and she encourages these members:
of the Federal family to demonstrate the spirit of community that they
have exhibited so many times in the past and assist their neighbors or
others who might be in need.":
3) During significant fires, flooding, hurricanes and earthquakes
anywhere in the nation, the OPM Director issues guidance to Federal
agencies as it pertains to leave and benefits to their Federal
employees who have been adversely impacted by the event. OPM has also
marshaled its resources to assist in transferring emergency responders
from one Federal agency to another in order to meet developing crises.
This authority was last used during the late summer of 2003, when 30
massive fires were blazing in 11 States.
4) The Director of OPM has maintained a consistent policy of ensuring
open communication with the staff of this agency. It is her belief that
in order to build trust with employees, they need to be kept fully
aware of incidents that could adversely impact their safety and well
being. Her belief is that the stronger the trust factor the better
chance that employees will listen and cooperate if there is a
potentially life threatening emergency where rapid response is needed.
There are numerous instances where this has been carried out, notably
in the time period between October 2001 - May 2002, during concerns of
anthrax in Washington, DC mailrooms. Appendix "A" contains a sampling
of agency wide memorandums from the Director, which kept employees
aware of her efforts to ensure the protection of the OPM workforce. It
should be noted that these memos are only from the Director. She
directed many other "all employee" communications to be carried out by
pertinent senior staff as well. The documents focus on three separate
incidents:
1. The Director's response to anthrax concerns in general throughout
Washington, DC area and the closure of Brentwood Postal Facility in
late October, 2001.
2. Regular sampling tests taken in the OPM mailroom indicated the
possibility of a trace amount of anthrax present. January 2002. 3. In
May of 2002, regular mailroom testing turned up a single anthrax spore.
Similar communication efforts have been replicated during the recent
risin scare and during an isolated asbestos concern in the OPM
headquarters building. Keeping employees aware not only limits the
spread of rumors and unreliable information but it demonstrates
sensitivity to employee concerns at a time of elevated vigilance in our
nation's capital. In all instances, immediate contact was also made
with the employee unions. They have been very instrumental in helping
make sure that employees are kept fully informed.
* Allocate resources and setpolicies (P. u of Draft Report):
This OPM Director has made a firm commitment to allocate the necessary
resources to maintain a secure environment for the employees at OPM.
While discussing the amount of monies appropriated and specific
protective systems developed would be counter-productive in a public
report, suffice to say advancements have been substantial. We would be
happy to discuss this information privately with investigators from GAO
at a place and time of your choosing. There are a number of steps taken
that can be discussed. They include:
1. Mylar coating on all windows in the OPM headquarters facility aimed
at cutting down on flying glass in the event of a nearby explosion.
2. Installation of a new PA and emergency alert system in the OPM
headquarters. This system, complete with visual notification for the
deaf and hard of hearing has been tested and is in operation.
3. Special training and accommodation has been made for those who are
disabled and require special assistance in an emergency.
4. The Director ordered and received a completely updated Emergency
Occupant Plan (EOP) for the OPM headquarters building.
5. Each employee was given emergency evacuation instructions on a
laminated card, sized to fit alongside their agency ID badge on their
lanyard. Examples of this have been shared on numerous occasions with
security and communication specialists throughout the Government.
6. Teleconferencing capability has been readied between several
locations in the OPM headquarters building and our COOP sites in
Pennsylvania and Virginia.
In addition to allocating resources directly benefiting OPM, this
Director used OPM funding to research, create and publish four
Emergency Preparedness Guides, designed for Federal employees and their
families both in the DC metro area and beyond. This fact is mentioned
elsewhere in the draft GAO report. We are pleased to report that as of
this date nearly 500,000 of the guides have been:
distributed. OPM gathered emergency preparedness leaders from 16
governmental agencies to contribute their expertise to the development
of the guides.
Set direction and pace of recovery (Page 11 of Draft Report):
No event in recent memory has tested the resolve and actions of our
nation's most senior leadership more so than 9-11 The OPM Director's
major decision on that day was to set the direction for the operating
status of the Federal Government for September 12th Her unwavering
belief was that the Nation's Government needed to demonstrate to our
citizenry and governments world wide that America was "open for
business" on 12 September and the United States would not cower at the
hands of terrorists. Her recommendation was met with total support from
the White House. She indeed demonstrated the ability to "set direction
and pace of recovery," when America needed it most.
Among other emergency authorities the Director immediately delegated to
agencies was the authority to approve dual compensation waivers to
execute rapid pace emergency, cleanup, and security teams at the agency
level.
(B) SEEK OPPORTUNITIES FOR SYNERGY (Page 12 of Draft Report):
Consider how continuity investments benefit other program efforts:
We will respond to this point by an answer based on the example you
provided of how GAO addressed this bullet point by providing GAO
employees with laptop computers which enabled them to work from
alternate locations, consequently clearing space for some Congressional
offices, displaced by anthrax concerns, to temporarily occupy. The
Director of OPM exhibited foresight, in our particular building, by
ordering a build-out of excess space in the subbasement of the OPM
headquarters. This area can accommodate about 45-5o people. The work
areas are complete with computers, phones and office supplies. This
space has been made available to Congressional offices and even used
recently by a Senatorial Committee that used the area and facilities to
make final preparations for a Congressional hearing. Consequently, OPM
has garnered its resources and made them available to teammates
Governmentwide. The space can also be utilized by any office within OPM
that is temporarily displaced for any reason (i.e., carpet replacement,
electrical work, etc.).
(C) MAINTAIN EFFECTIVE COMMUNICATION (Page 13 of Draft Report):
Build relationships through 2-way communication:
This aspect of the OPM Director's philosophy of making sure employees
remain aware of circumstances has been fully addressed in a previous
answer. We want to take a moment here and comment on the way the OPM
Director approached communicating and working with labor unions and
other employee organizations
as it pertains to the development of the new personnel system at the
Department of Homeland Security.
Working together, DHS and OPM developed and conducted a comprehensive
and inclusive process for creating a new HR system for DHS. A key
element of the process was the creation of a Design Team. This team,
comprising of 8o DHS employees, supervisors, union representatives, and
OPM staff, compiled an extensive collection of innovative and
successful HR practices and developed a range of options for the new
system. The options were developed after 64 nationwide Focus Groups and
Town Hall meetings were conducted to gain input from employees in all
major DHS components. Also during the options development stage, over
65 public and private sector organizations and HR experts were
contacted. The options for the new system were then reviewed by a
Senior Review Committee (SRC), made up of DHS and OPM officials and the
presidents of DHS' three largest unions (AFGE, NTEU, NAAE).
Emergency protocols have been established to provide immediate contact
within and between all levels of DHS/GSA/OPM/FEMA. Ongoing tests ensure
seamless communications with White House leadership and OPM/DHS.
Establish roles, responsibilities and expectations:
The OPM Director fully concurs with others who believe that
communicating performance expectations to employees prior to disruption
promotes a more efficient outcome and management of human capital
assets. To that end, the Director of OPM has done the following:
1. Overseen and participated in a number of emergency tabletop
exercises with her most senior staff. On one occasion, she has ordered
herself "removed" and turned OPM's response over to the Deputy
Director. In another instance both the Director and Deputy Director
were taken out of the picture and the next person following in
succession ran the operation.
2. Met with the nine people in the official line of succession to go
over and discuss actions and responsibilities should she no longer be
able to carry out the duties of OPM Director.
3. Ensured that each major program office in OPM provided in hard copy
and backed up on CD-ROM (filed away in three separate locations across
the nation) the actions that directorates would take in the event that
the senior leadership of the directorate were incapacitated or
unavailable for whatever reason. Information has been distributed to
multiple remote OPM COOP locations that are maintained at near constant
readiness levels. Contained in the material are draft policy
statements, intergovernmental guidance and draft Executive Orders
covering any eventuality ranging from emergency hiring authority to
the
maintenance of retirement and health benefits for Federal workers to
continuation of the national security background investigation process.
4. Ordered and participated in tabletop exercises and educational
sessions with the second and third tier leadership within OPM to
familiarize them with the duties and responsibilities should the most
senior leadership not be available.
* Develop redundant communication vehicles:
The OPM Director has provided the 100 highest ranking senior managers
at OPM redundant means of emergency communication technology and each
carries it 24/7. Those means of communication are NEXTEL phone,
Blackberry and national pager. The 30 most senior advisors are also
equipped with satellite phones and have access to the GETS (Government
Emergency Telecommunications Service) system in the event of an
emergency. Communication tests are administered frequently whereby each
manager is required to phone into the OPM Situation Room upon receipt
of request.
In regards to mainframe computer servers, again we do not want to
provide any specifics in an open forum as to how the critical
information on Federal employees is maintained by OPM but we can say
that numerous safeguards and redundancies are built into the system and
can be controlled from various locations across the United States
(including one location that has been termed "one of the ten safest
places in the world"). In addition, should OPM suffer a catastrophic
loss of its mainframe, program managers have been instructed to
physically transfer to an undisclosed location and, with redundant
backups in different places nationwide, can reconstruct the data that
has been compromised.
(D) TARGET INVESTMENTS IN TRAINING AND DEVELOPMENT (Page 14 of Draft
Report):
Raise awareness of continuity efforts:
Over the past two and one half years, OPM has completely revamped its
COOP process. Personnel who would be deployed have received significant
information regarding their duties and responsibilities. Several
meetings have included all those who would relocate and at these
meetings COOP manuals were distributed that explains OPM's critical
functions and the means that will be used to ensure that they are
carried out in an emergency. A number of tests involving OPM's "Go-
Teams" have been made. "Go-Teams" are comprised of 6-8 senior OPM
officials, who at the first sign of trouble immediately exit the city
before traffic becomes log-jammed. Their orders are to head immediately
to the OPM COOP relocation site. These individuals have the experience
and authority to make decisions relative to OPM's mission until the
Director and her aides arrive. This concept has also been tested and
fueled vehicles, cash, and packed suitcases are on the ready if needed.
Build skills and competencies to increase flexibility (P. 14 of Draft
Report):
OPM is unique in the sense that large numbers of our employees and the
technology required to fulfill our critical missions are carried out
away from Washington, DC and in intensely secure areas. For example,
our COOP relocation site will have an additional 750-800 employees
already there and that workforce can be tapped to cover any eventuality
or need. Another facet of this flexibility is in the area of succession
planning, and that has already been discussed previously.
(E) LEVERAGE THE FLEXIBILITY OF HUMAN CAPITAL:
* Enable employees associated with resumption activities to contribute
to mission-results in alternate assignments:
The explanatory paragraph in the draft GAO report reads,
"...organizations may use approaches such as telework and geographic
dispersion, which includes regional structure, to increase the ways in
which employees may contribute." The next line in the draft report
points out OPM's guidance by way of symposiums and conferences held for
Government officials which educate about and promote telework as a
viable means of mission critical operations. The Director and her
senior staff lead by example by teleworking at least one day per month.
OPM has sponsored an ongoing number of initiatives to promote telework
to the agencies. Some of the more recent include the all-day November
4th Training Event in 2003, to which agency HR Directors and telework
coordinators were invited, and given telework kits. Government telework
coordinators heard some of the major pioneers and leaders in the field
discuss the advantages of telework. One featured speaker was
internationally known telework expert Gil Gordon. Since the training,
we have distributed 250 telework kits to requesting agencies. We are
currently making additional kits available to agencies as well as
Capitol Hill offices through the Government Printing Office. In
September of 2003, the ITAC (International Telework Association and
Conference) conference in Baltimore for Federal Telework Coordinators
was co-sponsored by OPM and GSA.
Following are the most recent major events in 2004 that OPM has
spearheaded:
Jan 04--Telework "WEB" inar featuring OPM and GSA speakers and Gil
Gordon:
Feb 04--Quarterly Telework Coordinators Meeting:
Two Emergency Preparedness Meetings--OPM and GSA speakers on the
importance of telework as a part of a COOP Plan:
March ii--OPM and GSA Speakers at DEA meeting of COOP planners:
February 23 and 24--Alliance of Work/Life Progress (AWLP) conference in
Phoenix--two special Federal Sessions featuring Telework presentations
by OPM representative, Ms. Abby Block:
Quarterly senior-level telework meetings with GSA (November, February,
May, etc.):
Planned upcoming near-term events pertaining to telework:
Upcoming: Launch of two Telework e-training modules (Telework 101 for
Managers, Telework 101 for Directors) for Federal employees on
www.GoLearn:
May 5--Webinar to introduce two e-training modules (Telework 101 for
Managers, Telework 101 for Directors) on OPM's GoLearn directed at
agency telework coordinators so coordinators can have "hands-on"
training in getting to and promoting the courses:
April 29--OPM coordinators will provide the keynote address on telework
at the Mid Atlantic Intergovernmental Audit Forum for IGs (sponsored by
GAO):
Development of training modules for supervisors, managers and senior
agency officials to be taught at OPM, GSA,USDA and other courses:
A second point was made in the draft report (p.17) suggesting the
importance of geographically spreading out an agency's operations. OPM
as an organization, already possesses wide geographic dispersion. Field
offices and major facilities exist in Pennsylvania, Virginia, Georgia,
Colorado and West Virginia. OPM's critical missions can be carried out
completely without a single person physically housed in Washington, DC.
Sustain the contribution of employees associated with essential
operations:
This is an excellent point and one that should challenge every agency
or department. "Safety and emergency planning" is an element in all of
OPM's senior executive service members' performance plans. As
previously stated, the OPM Director has identified the most senior 100
managers at OPM who will be called upon in the event of an emergency.
This list of managers generally goes three or four deep in each of our
seven major program offices. The Director has built enough redundancy
in her agency planning to allow for rotation of duties in the event of
an extended stay at the COOP relocation site. Keep in mind also, there
are already 75o-800 OPM employees at the COOP location and they can be
utilized as needed.
* Maintain organizational knowledge of staffing requirements and
availability:
This point made in the draft report (p.18) focuses on the need for
agencies to establish some means of adding to its existing staff or
replenishing staff in the:
event of a catastrophic incident. OPM, as the United States
Government's human resources agency, already maintains vast up-to-date
information on positions available, KSA criteria and interagency
partnerships that could be utilized immediately. Please keep in mind
also, that just after 9-11 it was OPM that devised and administered a
program called Patriot, (not to be confused with the Patriot Act) that
matched the talents of retired Federal employees who wanted to
volunteer their abilities, to agencies that needed their particular
skill.
(F) BUILD PROCESS TO IDENTIFY AND SHARE LESSONS (p. 19 of Draft
Report):
* Create a learning environment:
* Make learning explicit and shared:
Like most agencies, OPM does conduct "hot wash" debriefings after each
tabletop exercise and after each major event that causes disruption in
the District of Columbia (Tractor Man, large weather events, World Bank
and IMF demonstrations, etc.). In many instances, these debriefs are
conducted with other agencies and officials from the District of
Columbia and neighboring municipalities. It is our belief that more can
be done in the area of sharing learning experiences. This is an area
that we will study and will report back to you on advances made.
[End of section]
(450177):
FOOTNOTES
[1] The House Committee on Government Reform also asked us to review
agency headquarters COOP plans. We reported on that review in U.S.
General Accounting Office, Continuity of Operations: Improved Planning
Needed to Ensure Delivery of Essential Services, GAO-04-160
(Washington, D.C.: Feb. 27, 2004).
[2] In March 2003, FEMA became a part of the Department of Homeland
Security within the Directorate of Emergency Preparedness and Response.
[3] U.S. Federal Emergency Management Agency, Federal Preparedness
Circular 65 (Washington, D.C: July 26, 1999), 2.
[4] See PDD 62, Protection Against Unconventional Threats to the
Homeland and Americans Overseas, dated May 22, 1998; PDD 63, Critical
Infrastructure Protection (CIP), dated May 22, 1998, which has been
superseded by Homeland Security Presidential Directive 7, Critical
Infrastructure Identification, Prioritization, and Protection, dated
December 17, 2003; and PDD 67, Enduring Constitutional Government and
Continuity of Operations, dated October 21, 1998.
[5] As the lead agency for federal OEP efforts, GSA issued the Occupant
Emergency Program Guide in March 2002. This guidance defines an
occupant emergency, details the roles of GSA and individual agencies
with regard to OEP, and provides step-by-step guidance for agencies to
use in carrying out their responsibilities for the program. An occupant
emergency is defined as an event that may require evacuation of
occupied space or relocation to a safer area. Under OEP, agencies are
required to establish an occupancy emergency plan designated official,
an occupancy emergency plan, and an occupancy emergency organization.
GSA's responsibilities include helping agencies to establish and
maintain the plans and organizations, offering policy guidance about
the program, ensuring proper administration of the program, reviewing
agencies' plans and organizations annually, and helping to train
employees and others for emergencies.
[6] National Fire Protection Association, NFPA 1600: Standard on
Disaster/Emergency Management and Business Continuity Programs
(Quincy, Mass.: February 2000).
[7] See, for example, U.S. General Accounting Office: Results-Oriented
Cultures: Implementation Steps to Assist Mergers and Organizational
Transformations, GAO-03-669 (Washington, D.C.: July 2, 2003);
Highlights of a GAO Forum: Mergers and Transformation: Lessons Learned
for a Department of Homeland Security and Other Federal Agencies, GAO-
03-293SP (Washington, D.C.: Nov. 14, 2002); A Model of Strategic Human
Capital Management, GAO-02-373SP (Washington, D.C.: Mar. 15, 2002); and
Management Reform: Elements of Successful Improvement Initiatives, GAO/
T-GGD-00-26 (Washington, D.C.: Oct. 15, 1999).
[8] See, for example, U.S. General Accounting Office, High-Risk Series:
Strategic Human Capital Management, GAO-03-120 (Washington, D.C.:
January 2003); GAO-03-669; GAO-03-293SP; and GAO-02-373SP.
[9] GAO-03-669 and GAO-03-293SP.
[10] GAO-02-373SP.
[11] We have identified eight core characteristics of a strategic
training and development process that can help make a training and
development program effective and strategically focused on achieving
results. These characteristics are strategic alignment; leadership
commitment and communication; stakeholder involvement; accountability
and recognition; effective resource allocation; partnerships and
learning from others; data quality assurance; and continuous
performance improvement. For more information on these characteristics,
see U.S. General Accounting Office, Human Capital: A Guide for
Assessing Strategic Training and Development Efforts in the Federal
Government, GAO-04-546G (Washington, D.C.: March 2003).
[12] U.S. General Accounting Office, Human Capital: Insights for U.S.
Agencies from Other Countries' Succession Planning and Management
Initiatives, GAO-03-914 (Washington, D.C.: Sept. 15, 2003).
[13] See, for example, U.S. Office of Personnel Management, "Memorandum
for Heads of Executive Departments and Agencies: Washington, DC, Area
Dismissal or Closure Procedures," December 4, 2003, and "Memorandum for
Heads of Executive Departments and Agencies: Level Orange Emergency
Human Resources Management (HRM) Authorities," March 17, 2003.
[14] Our previous work has also identified 25 key practices for
implementation of successful federal telework programs. See U.S.
General Accounting Office, Human Capital: Further Guidance, Assistance,
and Coordination Can Improve Federal Telework Efforts, GAO-03-679
(Washington, D.C.: July 18, 2003).
[15] U.S. Office of Personnel Management, "Memorandum for Heads of
Executive Departments and Agencies: Subject: Widespread Power Outage,"
August 15, 2003.
[16] President Bush created the Citizen Corps in January 2002, as a
component of the USA Freedom Corps, to help coordinate volunteer
activities that will make communities safer, stronger, and better
prepared to respond to any emergency situation. This mission is carried
out through a national network of Citizen Corps Councils that build on
community strengths to implement the program and carry out a local
strategy. FEMA coordinates the program nationally. In this capacity,
FEMA works closely with key stakeholders, including other federal
entities, state and local governments, first responders, emergency
managers, and the volunteer community. More information can be found at
www.citizencorps.gov or by calling 1-877-USA-CORPS.
[17] GAO-02-373SP.
[18] Emergency Management Alberta, "Disruption Incident Reporting
System," www.municipalaffairs.gov.ab.ca/ema/BRP/DIRS.cfm (downloaded
Feb. 19, 2004).
[19] Emergency Management Alberta, "Welcome to the Lessons Learned
Warehouse," www.municipalaffairs.gov.ab.ca/ema/BRP/Welcome.cfm
(downloaded Feb. 19, 2004).
[20] 41 C.F.R. §§ 102-74.230 - 102-74.260 and U.S. General Services
Administration, Occupant Emergency Program Guide (Washington, D.C.:
March 2002).
[21] U.S. Office of Personnel Management, "Memorandum to Heads of
Executive Departments and Agencies: Level Orange Emergency Human
Resources Management (HRM) Authorities," March 17, 2003.
[22] The four guides are entitled A Federal Employee's Emergency Guide,
Federal Manager's/Decision Maker's Emergency Guide, A Federal
Employee's Family Preparedness Guide, and A Federal Employee's Family
Preparedness Guide (For the Washington, D.C. Area).
[23] See U.S. Office of Personnel Management, "Memorandum for Heads of
Departments and Agencies: Wildfires in California," October 27, 2003;
"Memorandum for Heads of Departments and Agencies: Hurricane Isabel,"
September 19, 2003; and "Memorandum for Heads of Executive Departments
and Agencies: Level Orange Emergency Human Resources Management (HRM)
Authorities," March 17, 2003. See also U.S. Office of Personnel
Management, Human Resources Flexibilities and Authorities in the
Federal Government (Washington, DC: July 25, 2001).
[24] Although this section focuses on FEBs, much of the discussion
could also apply to Federal Executive Associations (FEA) and Federal
Executive Councils (FEC) that are located in cities where FEBs do not
exist. FEAs and FECs have purposes and objectives similar to FEBs
although they do not function within the same formal set of parameters
as FEBs (e.g., they are not officially established by Presidential
Memorandum, nor do they receive policy direction or guidance from OPM).
FEAs and FECs also do not have permanent status and, according to OPM,
often disband and regroup depending on the local commitment of agency
members.
[25] TOPOFF 2 was conducted from May 12 through May 16, 2003, and
involved top government officials from federal, state, local, and
Canadian participants in a full-scale exercise that assessed how
responders, leaders, and other authorities would react to the simulated
release of weapons of mass destruction in two U.S. cities, Seattle and
Chicago.
[26] The cycle one participants were FEMA, the Department of Housing
and Urban Development, the Gillette Company, Lockheed Martin
Corporation, the Business Continuity Institute, and Clark-Atlanta
University.
[27] The working group participants were from FEMA, the Department of
Housing and Urban Development, the Social Security Administration,
Lockheed Martin Corporation, Marsh & McLennan Companies, Inc., Science
Applications International Corporation, and the Disaster Recovery
Institute International, as well as representatives from GAO.
[28] See U.S. Office of Personnel Management, "Memorandum for Heads of
Departments and Agencies: Wildfires in California," October 27, 2003;
"Memorandum for Heads of Departments and Agencies: Hurricane Isabel,"
September 19, 2003; and "Memorandum for Heads of Executive Departments
and Agencies: Level Orange Emergency Human Resources Management (HRM)
Authorities," March 17, 2003.
[29] U.S. Office of Personnel Management, Human Resources Flexibilities
and Authorities in the Federal Government (Washington, D.C.: July 25,
2001).
[30] According to 5 U.S.C. § 6323(b), military leave is not to exceed
22 workdays.
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