Continuity of Operations
Agencies Could Improve Planning for Telework during Disruptions
Gao ID: GAO-06-740T May 11, 2006
To ensure that essential government services are available in emergencies, federal agencies are required to develop continuity of operations (COOP) plans. The Federal Emergency Management Agency (FEMA), within the Department of Homeland Security (DHS), is responsible for providing guidance to agencies on developing such plans. Its guidance states that in their continuity planning, agencies should consider the use of telework--that is, work performed at an employee's home or at a work location other than a traditional office. The Office of Personnel Management (OPM) recently reported that 43 agencies have identified staff eligible to telework, and that more than 140,000 federal employees used telework in 2004. OPM also reported that many government operations can be carried out in emergencies using telework. For example, telework appears to be an effective strategy for responding to a pandemic--a global outbreak of disease that spreads easily from person to person and causes serious illness and death worldwide. In previous work, GAO identified steps that agencies should take to effectively use telework during an emergency. GAO was asked to testify on how agencies are addressing the use of telework in their continuity planning, which is among the topics discussed in a report being released today (GAO-06-713).
Although agencies are not required to use telework in continuity planning, 9 of the 23 agencies surveyed reported plans for essential team members to telework during a COOP event, compared to 3 in GAO's previous survey. However, few documented that they made the necessary preparations to effectively use telework during such an event. For example, only 1 agency documented that it had communicated this expectation to its emergency team members. One reason for the low levels of preparations reported is that FEMA has not provided specific guidance on preparations needed to use telework during emergencies. Recently, FEMA disseminated guidance to agencies on incorporating pandemic influenza considerations into COOP planning. Although this guidance suggests the use of telework during such an event, it does not address the steps agencies should take when preparing to use telework during an emergency. Without specific guidance, agencies are unlikely to adequately prepare their telework capabilities for use during a COOP event. In addition, inadequate preparations could limit the ability of nonessential employees to contribute to agency missions during extended emergencies, including pandemic influenza. In its report released today, GAO recommends, among other things, that FEMA establish a time line for developing, in consultation with the OPM, guidance on preparations needed for using telework during a COOP event. In commenting on a draft of the report, DHS partially agreed with GAO's recommendation and stated that FEMA will coordinate with OPM in developing a time line for further telework guidance. DHS also stated that both FEMA and OPM have provided telework guidance. However, as GAO's report stated, present guidance does not address the preparations federal agencies should make for using telework during emergencies. On May 3 the White House announced the release of an Implementation Plan in support of the National Strategy for Pandemic Influenza. This plan calls on OPM to work with DHS and other agencies to revise existing telework guidance and issue new guidance on human capital planning and COOP. The plan establishes an expectation that these actions will be completed within 3 months. If the forthcoming guidance does not require agencies to make necessary preparations for telework, agencies are unlikely to take all the steps necessary to ensure that employees will be able to effectively use telework to perform essential functions in extended emergencies, such as a pandemic influenza.
GAO-06-740T, Continuity of Operations: Agencies Could Improve Planning for Telework during Disruptions
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United States Government Accountability Office:
GAO:
Testimony:
Before the Committee on Government Reform:
House of Representatives:
Continuity Of Operations: Agencies Could Improve Planning for Telework
during Disruptions:
Statement of David M. Walker:
Comptroller General of the United States:
GAO Highlights:
Highlights of GAO-06-740T, a testimony before the Committee on
Government Reform, House of Representatives.
Why GAO Did This Study:
To ensure that essential government services are available in
emergencies, federal agencies are required to develop continuity of
operations (COOP) plans. The Federal Emergency Management Agency
(FEMA), within the Department of Homeland Security (DHS), is
responsible for providing guidance to agencies on developing such
plans. Its guidance states that in their continuity planning, agencies
should consider the use of telework”that is, work performed at an
employee‘s home or at a work location other than a traditional office.
The Office of Personnel Management (OPM) recently reported that 43
agencies have identified staff eligible to telework, and that more than
140,000 federal employees used telework in 2004.
OPM also reported that many government operations can be carried out in
emergencies using telework. For example, telework appears to be an
effective strategy for responding to a pandemic”a global outbreak of
disease that spreads easily from person to person and causes serious
illness and death worldwide. In previous work, GAO identified steps
that agencies should take to effectively use telework during an
emergency.
GAO was asked to testify on how agencies are addressing the use of
telework in their continuity planning, which is among the topics
discussed in a report being released today (GAO-06-713).
What GAO Found:
Although agencies are not required to use telework in continuity
planning, 9 of the 23 agencies surveyed reported plans for essential
team members to telework during a COOP event, compared to 3 in GAO‘s
previous survey. However, few documented that they made the necessary
preparations to effectively use telework during such an event. For
example, only 1 agency documented that it had communicated this
expectation to its emergency team members. One reason for the low
levels of preparations reported is that FEMA has not provided specific
guidance on preparations needed to use telework during emergencies.
Recently, FEMA disseminated guidance to agencies on incorporating
pandemic influenza considerations into COOP planning. Although this
guidance suggests the use of telework during such an event, it does not
address the steps agencies should take when preparing to use telework
during an emergency. Without specific guidance, agencies are unlikely
to adequately prepare their telework capabilities for use during a COOP
event. In addition, inadequate preparations could limit the ability of
nonessential employees to contribute to agency missions during extended
emergencies, including pandemic influenza.
In its report released today, GAO recommends, among other things, that
FEMA establish a time line for developing, in consultation with the
OPM, guidance on preparations needed for using telework during a COOP
event. In commenting on a draft of the report, DHS partially agreed
with GAO‘s recommendation and stated that FEMA will coordinate with OPM
in developing a time line for further telework guidance. DHS also
stated that both FEMA and OPM have provided telework guidance. However,
as GAO‘s report stated, present guidance does not address the
preparations federal agencies should make for using telework during
emergencies.
On May 3 the White House announced the release of an Implementation
Plan in support of the National Strategy for Pandemic Influenza. This
plan calls on OPM to work with DHS and other agencies to revise
existing telework guidance and issue new guidance on human capital
planning and COOP. The plan establishes an expectation that these
actions will be completed within 3 months. If the forthcoming guidance
does not require agencies to make necessary preparations for telework,
agencies are unlikely to take all the steps necessary to ensure that
employees will be able to effectively use telework to perform essential
functions in extended emergencies, such as a pandemic influenza.
[Hyperlink, www.gao.gov/cgi-bin/getrpt?GAO-06-740T].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Linda D. Koontz at (202)
512-6240 or koontzl@gao.gov.
[End of section]
Mr. Chairman and Members of the Committee:
I appreciate the opportunity to participate in the Committee's hearing
on pandemic influenza and continuity of operations (COOP) planning. As
you know, essential government services can be interrupted by a range
of events, including terrorist attacks, severe weather, building-level
emergencies, and public health emergencies, such as pandemic influenza.
The federal government requires agencies to develop plans for ensuring
the continuity of essential services during such emergencies. To assist
agencies, the Federal Emergency Management Agency (FEMA), within the
Department of Homeland Security (DHS), which is responsible for
managing federal response and recovery efforts following any national
incident, has issued guidance that defines the elements of a viable
COOP capability.
A potentially useful option for continuity planning is telework (in
which work is performed at an employee's home or at a work location
other than a traditional office); this alternative has gained
widespread attention over the past decade in both the public and
private sectors as a human capital flexibility that offers a variety of
potential benefits to employers, employees, and society. In a December
2005 report to Congress, the Office of Personnel Management (OPM)
indicated that 43 of the 82 federal agencies it surveyed had employees
eligible to telework during 2004, and more than 140,000 federal
employees used telework that year.[Footnote 1]
OPM also reported that there is a symbiotic relationship between COOP
and telework because many government functions that must be carried out
in emergencies can be accomplished using telework. Similarly, we
reported in April 2004 that telework is an important and viable option
for federal agencies in continuity planning and implementation efforts,
especially as the duration of an emergency event is extended.[Footnote
2] This option appears particularly appropriate in the case of pandemic
influenza, which occurs when an influenza virus causes an outbreak of
disease that spreads easily from person to person and results in
serious illness worldwide. Experts believe that the effects of a
pandemic could come in waves that last for weeks or even months, in
which time absentee rates could reach 40 percent during peak periods
due to illness, the need to care for family members, and fear of
infection. Recent executive branch guidance states that social
distancing measures, such as telework, may be appropriate public health
interventions for infection control and containment during a pandemic
outbreak.
GAO recognizes the importance of telework and continuity planning and
is striving to lead by example on these issues. For example, during
certain emergencies, our current telework policy allows me to approve
telework for all employees in an affected area to promote continuity of
operations. We are also completing a supplement to our COOP plan that
addresses preparations specific to a pandemic, and are coordinating our
continuity planning efforts with those of other legislative branch
agencies.
As you requested, I will discuss how agencies are addressing the use of
telework in their continuity planning, based on work described in a
report that we are issuing today.[Footnote 3] In earlier work, we
identified steps agencies that should take to effectively use telework
during an emergency, and we surveyed agency officials responsible for
continuity planning at 23 major agencies.[Footnote 4] For this report,
we repeated this survey to obtain updated information on the extent to
which key telework practices were used in making continuity
preparations. We reviewed documentation submitted by agency officials
to support their survey responses and compared these responses to those
from our earlier work; we briefed your staff on the results of our work
on April 13, 2006. This work was conducted in accordance with generally
accepted government auditing standards.
Results in Brief:
More agencies reported plans for essential team members to telework
during a COOP event than in our previous survey, but few documented
that they made the necessary preparations to effectively use telework
during an emergency:
* Nine of the 23 agencies reported that some of their essential team
members are expected to telework during a COOP event. However, only one
agency documented that it had notified its team members of the
expectation that they would telework during such an event.
* None of the 23 agencies demonstrated that it could ensure adequate
technological capacity to allow designated personnel to telework during
an emergency.
* Only 3 of the 23 agencies documented testing the ability of staff to
telework during an emergency.
FEMA's guidance on COOP planning does not include specific information
on preparations to use telework during emergencies; the absence of such
specific guidance contributed to the low levels of preparations that
agencies reported. Recently, FEMA disseminated additional guidance to
agencies regarding the incorporation of pandemic influenza
considerations into COOP planning. Although this guidance suggests the
use of telework during such an event, it does not address the steps
agencies should take when preparing to use telework during an
emergency. If agencies do not make adequate preparations, they may not
be able to use telework effectively to ensure the continuity of their
essential functions in emergencies, including pandemic influenza events.
In our report, we recommended, among other things, that FEMA establish
a time line for developing, in consultation with OPM, guidance on
preparations needed for using telework during a COOP event. In
commenting on a draft of this report, DHS partially agreed with our
recommendation and stated that FEMA will coordinate with OPM in the
development of a time line for telework guidance.
Background:
Federal operations and facilities have been disrupted by a range of
events, including the terrorist attacks on September 11, 2001; the
Oklahoma City bombing; localized shutdowns due to severe weather
conditions, such as hurricanes Katrina, Rita, and Wilma in 2005; and
building-level events, such as asbestos contamination at the Department
of the Interior's headquarters. In addition, federal operations could
be significantly disrupted by people-only events, such as an outbreak
of severe acute respiratory illness (SARS). Such disruptions,
particularly if prolonged, can lead to interruptions in essential
government services. Prudent management, therefore, requires that
federal agencies develop plans for dealing with emergency situations,
including maintaining services, ensuring proper authority for
government actions, and protecting vital assets.
Until relatively recently, continuity planning was generally the
responsibility of individual agencies. In October 1998, Presidential
Decision Directive (PDD) 67 identified FEMA--which is responsible for
leading the effort to prepare the nation for all hazards and managing
federal response and recovery efforts following any national incident-
-as the lead agent for federal COOP planning across the federal
executive branch. FEMA's responsibilities include:
* formulating guidance for agencies to use in developing viable plans;
* coordinating interagency exercises and facilitating interagency
coordination, as appropriate; and:
* overseeing and assessing the status of COOP capabilities across the
executive branch.
In July 1999, FEMA issued the first version of Federal Preparedness
Circular (FPC) 65, its guidance to the federal executive branch on
developing viable and executable contingency plans that facilitate the
performance of essential functions during any emergency. FPC 65 applies
to all federal executive branch departments and agencies at all levels,
including locations outside Washington, D.C. FEMA released an updated
version of FPC 65 in June 2004, providing additional guidance to
agencies on each of the topics covered in the original guidance.
In partial response to a recommendation we made in April 2004, the 2004
version of FPC 65 also included new guidance on human capital
considerations for COOP events.[Footnote 5] For example, the guidance
instructed agencies to consider telework--also referred to as
telecommuting or flexiplace--as an option in their continuity planning.
Telework has gained widespread attention over the past decade in both
the public and private sectors as a human capital flexibility that
offers a variety of potential benefits to employers, employees, and
society. In a 2003 report to Congress on the status of telework in the
federal government, the Director of OPM described telework as "an
invaluable management tool which not only allows employees greater
flexibility to balance their personal and professional duties, but also
allows both management and employees to cope with the uncertainties of
potential disruptions in the workplace, including terrorist
threats."[Footnote 6] A 2005 OPM report on telework notes the
importance of telework in responding flexibly to emergency situations,
as demonstrated in the wake of the devastation caused by Hurricane
Katrina, when telework served as a tool to help alleviate the issues
caused by steeply rising fuel prices nationwide.[Footnote 7]
In 2004, we surveyed major federal agencies at your request to
determine how they planned to use telework during COOP events.[Footnote
8] We reported that, although agencies were not required to use
telework in their COOP plans, 1 of the 21 agency continuity plans in
place on May 1, 2004, documented plans to address some essential
functions through telework. In addition, 10 agencies reported that they
intended to use telework following a COOP event, even though those
intentions were not documented in their continuity plans.
The focus on using telework in continuity planning has been heightened
in response to the threat of pandemic influenza. In November 2005, the
White House issued a national strategy to address this threat, which
states that social distancing measures, such as telework, may be
appropriate public health interventions for infection control and
containment during a pandemic outbreak. The strategy requires federal
departments and agencies to develop and exercise preparedness and
response plans that take into account the potential impact of a
pandemic on the federal workforce. It also tasks DHS--the parent
department of FEMA--with developing plans to implement the strategy in
regard to domestic incident management and federal coordination. In May
2006, the White House issued an implementation plan in support of the
pandemic strategy. This plan outlines the responsibilities of various
agencies and establishes time lines for future actions.
Few Agencies Demonstrated That They Had Adequately Prepared to Use
Telework in a COOP Event:
Although more agencies reported plans for essential team members to
telework during a COOP event than in our 2004 survey, few documented
that they had made the necessary preparations to effectively use
telework during an emergency. While FPC 65 does not require agencies to
use telework during a COOP event, it does state that they should
consider the use of telework in their continuity plans and procedures.
All of the 23 agencies that we surveyed indicated that they considered
telework as an option during COOP planning, and 15 addressed telework
in their COOP plans (see table 1). For agencies that did not plan to
use telework during a COOP event, reasons cited by agency officials for
this decision included (1) the need to access classified information--
which is not permitted outside of secured areas--in order to perform
agency essential functions and (2) a lack of funding for the necessary
equipment acquisition and network modifications.
Table 1: Agency Responses to Selected Questions on Telework in COOP
Plans:
Question: Does the agency's COOP plan specifically address telework?;
Year: 2005;
Yes: 12;
Yes (no doc[A] ): 3;
No: 8.
Question: Does the agency's COOP plan specifically address telework?;
Year: Year: 2004[B];
Yes: 2;
Yes (no doc[A] ): 1;
No: 19.
Question: Are any of the agency's essential team members expected to
telework in a COOP event?; Year: 2005;
Yes: 3; Yes (no doc[A] ): 6;
No: 14.
Question: Are any of the agency's essential team members expected to
telework in a COOP event?; Year: 2004;
Yes: 1;
Yes (no doc[A] ): 2;
No: 19.
Question: Were staff informed of their responsibility to telework
during a COOP event?; Year: 2005;
Yes: 1;
Yes (no doc[A] ): 10;
No: 12.
Question: Were staff informed of their responsibility to telework
during a COOP event?; Year: 2004;
Yes: 1;
Yes (no doc[A] ): 3;
No: 18.
Question: Has the agency ensured that it has adequate technological
capacity for staff to telework during a COOP event?; Year: 2005;
Yes: 0;
Yes (no doc[A] ): 14;
No: 9.
Question: Has the agency ensured that it has adequate technological
capacity for staff to telework during a COOP event?; Year: 2004;
Yes: 0;
Yes (no doc[A] ): 5;
No: 17.
Question: Will the agency provide technological assistance to staff
during a COOP event?; Year: 2005;
Yes: 3;
Yes (no doc[A] ): 11;
No: 9.
Question: Will the agency provide technological assistance to staff
during a COOP event?; Year: 2004;
Yes: 0;
Yes (no doc[A] ): 5;
No: 17.
Question: Has the agency tested the ability of staff to telework during
a COOP event?; Year: 2005;
Yes: 3;
Yes (no doc[A] ): 7;
No: 13.
Question: Has the agency tested the ability of staff to telework during
a COOP event?; Year: 2004;
Yes: 0;
Yes (no doc[A] ): 2;
No: 20.
Source: Analysis of agency responses to GAO questions.
[A] Agencies provided a positive response but did not provide adequate
documentation to support their response.
[B] In 2004, one agency did not respond, resulting in a total of 22
responses.
[End of table]
The agencies that did plan to use telework in emergencies did not
consistently demonstrate that they were prepared to do so. We
previously identified steps agencies should take to effectively use
telework during an emergency. These include preparations to ensure that
staff has adequate technological capacity, assistance, and
training.[Footnote 9] Table 1 provides examples of gaps in agencies'
preparations, such as the following:
* Nine of the 23 agencies reported that some of their COOP essential
team members are expected to telework during a COOP event. However,
only one agency documented that it had notified its team members that
they were expected to telework during such an event.
* None of the 23 agencies demonstrated that it could ensure adequate
technological capacity to allow designated personnel to telework during
a COOP event.
No guidance addresses the steps that agencies should take to ensure
that they are fully prepared to use telework during a COOP event. When
we reported the results of our 2004 survey, we recommended that the
Secretary of Homeland Security direct the Under Secretary for Emergency
Preparedness and Response to develop, in consultation with OPM,
guidance on the steps that agencies should take to adequately prepare
for the use of telework during a COOP event. However, to date, no such
guidance has been created.
In March 2006, FEMA disseminated guidance to agencies regarding the
incorporation of pandemic influenza considerations into COOP planning.
The guidance states that the dynamic nature of a pandemic influenza
requires that the federal government take a nontraditional approach to
continuity planning and readiness. It suggests the use of telework
during such an event. According to the guidance, agencies should
consider which essential functions and services can be conducted from a
remote location (e.g., home) using telework. However, the guidance does
not address the steps agencies should take when preparing to use
telework during an emergency. For example, although the guidance states
that agencies should consider testing, training, and exercising of
social distancing techniques, including telework, it does not address
other necessary preparations, such as informing designated staff of the
expectation to telework or providing them with adequate technical
resources and support.
Earlier this month, after we briefed your staff, the White House
released an Implementation Plan in support of the National Strategy for
Pandemic Influenza. This plan calls on OPM to work with DHS and other
agencies to revise existing telework guidance and issue new guidance on
human capital planning and COOP. The plan establishes an expectation
that these actions will be completed within 3 months.
If the forthcoming guidance from DHS and other responsible agencies
does not require agencies to make the necessary preparations for
telework, agencies are unlikely to take all the steps necessary to
ensure that employees will be able to effectively use telework to
perform essential functions during any COOP event. In addition,
inadequate preparations could limit the ability of nonessential
employees to contribute to agency missions during extended emergencies,
including a pandemic influenza scenario.
In summary, Mr. Chairman, although more agencies reported plans for
essential team members to telework during a COOP event than in our
previous survey, few documented that they had made the necessary
preparations to effectively use telework during an emergency. In
addition, agencies lack guidance on what these necessary preparations
are. Although FEMA's recent telework guidance does not address the
steps agencies should take to prepare to use telework during an
emergency event, new guidance on telework and COOP is expected to be
released later this year. If the new guidance does not specify the
steps agencies need to take to adequately prepare their telework
capabilities for use during an emergency situation, it will be
difficult for agencies to make adequate preparations to ensure that
their teleworking staff will be able to perform essential functions
during a COOP event.
In our report, we made recommendations aimed at helping to ensure that
agencies are adequately prepared to perform essential functions
following an emergency. Among other things, we recommended that the
Secretary of Homeland Security direct the FEMA Director to establish a
time line for developing, in consultation with OPM, guidance on the
steps that agencies should take to adequately prepare for the use of
telework during a COOP event.
In commenting on a draft of the report, the Director of DHS's Liaison
Office partially agreed with this recommendation and stated that FEMA
will coordinate with OPM in the development of a time line for further
telework guidance. In addition, he stated that both FEMA and OPM have
provided guidance on the use of telework. However, as stated in our
report, present guidance does not address the preparations agencies
should make for using telework during emergencies.
With the release of the White House's Implementation Plan regarding
pandemic influenza, a time line has now been established for the
issuance of revised guidance on telework; however, unless the
forthcoming guidance addresses the necessary preparations, agencies may
not be able to use telework effectively to ensure the continuity of
their essential functions.
Mr. Chairman, this concludes my statement. I would be pleased to
respond to any questions that you or other members of the Committee may
have at this time.
Contacts and Acknowledgements:
For information about this testimony, please contact Linda D. Koontz at
(202) 512-6240 or at koontzl@gao.gov. Key contributions to this
testimony were made by James R. Sweetman, Jr., Assistant Director;
Barbara Collier; Sairah Ijaz; Nick Marinos; and Kim Zelonis.
(310762):
[End of section]
FOOTNOTES
[1] OPM, The Status of Telework in the Federal Government 2005
(Washington, D.C.: Dec. 2005)
[2] GAO, Human Capital: Opportunities to Improve Federal Continuity
Planning Guidance, GAO-04-384 (Washington, D.C.: Apr. 20, 2004).
[3] GAO, Continuity of Operations: Selected Agencies Could Improve
Planning for Use of Alternate Facilities and Telework during
Disruptions, GAO-06-713 (Washington, D.C.: May 11, 2006).
[4] GAO, Continuity of Operations: Agency Plans Have Improved, but
Better Oversight Could Assist Agencies in Preparing for Emergencies,
GAO-05-577 (Washington, D.C.: Apr. 28, 2005).
[5] GAO, Human Capital: Opportunities to Improve Federal Continuity
Planning Guidance, GAO-04-384 (Washington, D.C.: Apr. 20, 2004).
[6] OPM, Report to the Congress: The Status of Telework in the Federal
Government (Washington, D.C.: Jan. 2003).
[7] OPM, Report to the Congress: The Status of Telework in the Federal
Government (Washington, D.C.: Dec. 2005).
[8] The plans that we reviewed in 2004 were created before the issuance
of FEMA's revised FPC 65, which instructs agencies to consider the use
of telework in their continuity planning.
[9] GAO, Continuity of Operations: Agency Plans Have Improved, but
Better Oversight Could Assist Agencies in Preparing for Emergencies,
GAO-05-577 (Washington, D.C.: Apr. 28, 2005).
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