IRS Emergency Planning:

Headquarters Plans Supported Response to 2006 Flooding, but Additional Guidance Could Improve All Hazard Preparedness

GAO-07-579: Published: Apr 16, 2007. Publicly Released: May 16, 2007.

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On June 25, 2006, the Internal Revenue Service (IRS) headquarters building suffered flooding during a period of record rainfall and sustained extensive damage to its infrastructure. IRS officials ordered the closure of the building until December 2006 to allow for repairs to be completed. IRS headquarters officials reported activating several of the agency's emergency operations plans. Within 1 month of the flood, over 2,000 employees normally assigned to the headquarters building were relocated to other facilities throughout the Washington, D.C., metropolitan area. GAO was asked to report on (1) how IRS emergency operations plans address federal guidance related to continuity planning and (2) the extent to which IRS emergency operations plans contributed to the actions taken by IRS officials in response to the flood. To address these objectives, GAO analyzed federal continuity guidance, reviewed IRS emergency plans, and interviewed IRS officials.

The IRS headquarters emergency operations plans that GAO reviewed--the headquarters Continuity of Operations (COOP) plan, Incident Management Plan, and three selected business resumption plans--collectively addressed several of the general elements identified within federal continuity guidance for all executive branch departments and agencies. For example, the plans adequately identified the people needed to continue performing essential functions. However, other elements were not addressed or were addressed only in part. Specifically, IRS had two separate lists of essential functions--critical business processes and essential functions for IRS leadership--within its plans, but prioritized only one of the lists. Furthermore, although the COOP plan outlined provisions for tests, training, and exercises, none of the other plans GAO reviewed outlined the need to conduct such activities. While IRS provided overall guidance to its business units on their business resumption plans, the guidance was inconsistent with the federal guidance on several elements, including the preparation of resources and facilities needed to support essential functions and requirements for regular tests, training, and exercises. The IRS Incident Management Plan was particularly useful in establishing clear lines of authority and communications in response to the flooding. Unit-level business resumption plans GAO reviewed contributed to a lesser extent, and the headquarters COOP plan was not activated because of conditions particular to the 2006 flood. Specifically, damage to the building was limited to the basement and subbasement levels, and employees were able to enter the building to retrieve equipment and assets. In addition, alternate work space was available for all employees within a relatively short period, reducing the importance of identifying critical personnel. While its plans helped guide IRS's response to the conditions that resulted from the flood, in more severe emergency events, conditions could be less favorable to recovery. Consequently, unless IRS fills in gaps in its guidance and plans, it lacks assurance that the agency is adequately prepared to respond to the full range of potential disruptions.

Status Legend:

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  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: To strengthen the ability of IRS to respond to the full range of potential disruptions to essential operations, the Commissioner of Internal Revenue should revise IRS internal emergency planning guidance to fully reflect federal guidance on the elements of a viable continuity capability, including the identification and prioritization of essential functions; the preparation of necessary resources and alternate facilities; and the regular completion of tests, training, and exercises of continuity capabilities.

    Agency Affected: Department of the Treasury: Internal Revenue Service

    Status: Closed - Implemented

    Comments: On September 25, 2008, IRS revised its internal emergency planning guidance. Specifically, IRS replaced section 1.16.10 (Business Resumption") of the Internal Revenue Manual with section 10.2.10, Continuity Planning Requirements. Within the new section, IRS established continuity policies and guidance to be followed by IRS organizations. Elements of the guidance included elements of a viable continuity capability, including identifying and prioritizing mission essential functions; preparing continuity facilities and resources; and developing and completing tests, training, and exercises of continuity capabilities.

    Recommendation: To strengthen the ability of IRS to respond to the full range of potential disruptions to essential operations, the Commissioner of Internal Revenue should revise IRS emergency plans in accordance with the new internal guidance.

    Agency Affected: Department of the Treasury: Internal Revenue Service

    Status: Closed - Implemented

    Comments: Following the release of new guidance contained within the Internal Revenue Manual, agency officials completed updates to agency continuity plans since March 2010 that included provisions for key continuity elements, including the identification and prioritization of essential functions; the preparation of necessary resources and alternate facilities; and the regular completion of tests, training, and exercises of continuity capabilities.

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