Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the Disaster Operations Directorate and the National Preparedness Directorate to improve their approach to developing policies and plans that define roles and responsibilities and planning processes by developing a program management plan, in coordination with DHS and other federal entities, to ensure the completion of the key national preparedness policies and plans called for in legislation, presidential directives, and existing policy and doctrine, to define roles and responsibilities and planning processes, as well as to fully integrate such policies and plans into other elements of the national preparedness system. The program management plan, among other things, should (1) identify the specific schedule of activities that needs to be performed to complete, and identify dependencies among, all policy and planning development and integration activities; (2) identify the type and quantities of resources required to perform, and the schedule for completing, all policy and planning development and integration activities; (3) analyze activity sequences, durations (including the time required to partner and coordinate on an interagency basis with other federal entities), resource requirements, and schedule constraints to create and update the individual policy and plan development project schedules; and (4) control for changes to the project schedules precipitated by outside forces. When outstanding policies and plans are completed, FEMA should also integrate them into training and exercise efforts to ensure that roles and responsibilities are fully communicated and fully understood by emergency response stakeholders.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Implemented

Comments: FEMA's National Preparedness Directorate (NPD) issued a 2011 report on its Strategic Intent for Fiscal Year 2012-2014/Fiscal Year 2012 Operating Plan. The Operating Plan focuses NPD's efforts primarily on implementation of Presidential Policy Directive-8 and addresses development of a National Preparedness Goal, National Preparedness System, 5 planning frameworks, and a National Preparedness Report. The Plan includes many of the elements outlined in GAO's recommendation, including goals, timelines, milestones and measurements of progress, as well as resources associated with implementing the plan. As a result, this recommendation is closed as implemented.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by coordinating with the Department of Homeland Security to develop policies and procedures for issuing after-action reports for National Level Exercises (i.e., TOPOFF (top Officials 4 Exercise)) in 6 months or less, as required by the implementation plan for the National Exercise Program.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Implemented

Comments: FEMA developed policies and procedures to meet the timelines delineated in the National Exercise Program (NEP) Implementation Plan (I-Plan) concerning the release of After Action Reports (AARs) for National Level Exercises (NLEs) and, according to agency officials, FEMA has been working with Department of Homeland Security leadership to ensure more rapid approval and release of AARs through the NEP. As an example, they noted that the NLE 2010 AAR was completed and sent to the interagency for review and comment within 60 days of the exercise. According to officials, following NLE 11, FEMA's National Exercise Division initiated a 14-day turnaround for a Missions Critical Finding Reports and presented findings to the Domestic Resilience Group (DRG) within that timeframe. This recommendation is closed as implemented.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by collaborating with the Homeland Security Council to establish policies and procedures for documenting corrective actions from Principal Level Exercises that are consistent with Homeland Security Exercise and Evaluation Program (HSEEP) guidance and the implementation plan for the National Exercise Program.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Implemented

Comments: In an updated response, FEMA reported in January 2012 that officials met with the National Security Staff (NSS) in June 2011 to explore future processes for Principal Level Exercises (PLEs) corrective actions and to clarify requirements. The NSS informed FEMA that it is committed to ensuring effective identification and tracking of corrective actions from PLEs, and this process is being incorporated into the revised NEP I-Plan. In the meantime FEMA continues to work with NSS to identify and monitor corrective actions from these exercises. For example, recently the NSS and FEMA co-chaired a Corrective Action/Lessons Learned Conference based on issues identified from previous NLEs and (PLEs). During the conference, Federal Departments and Agencies were asked to provide the status on each of their respective corrective actions from these exercises, and follow-up sessions are scheduled to resolve any outstanding items.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by collaborating with the Homeland Security Council to provide FEMA with the information it needs from past principal level exercises to enable it to conduct remedial action tracking and long-term trend analysis, as required by the Post-Katrina Act.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Implemented

Comments: The Federal Emergency Management Agency (FEMA) reported in September 2010 that the agency has obtained access to after action reports from past Principal Level Exercises, noting that remedial action tracking is done at the National Security Staff level for most Cabinet level exercises and that FEMA is working with the National Security Staff of the Homeland Security Council to explore ways to gather data that may be used by key players that are responsible for assessments to conduct analysis of Principal Level Exercises, while protecting sensitive information. FEMA's response noted that long term trend analysis to identify comprehensive and supportable findings is important; there are individual findings that provide significant near-term value and lead to rapid corrective actions that significantly improve preparedness, noting that the findings are captured and reviewed for action and implementation by the National Security Staff and that FEMA is working with the staff to enhance the corrective action identification and tracking process. As a result, this recommendation is closed as implemented.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by ensuring compliance by states that receive grant funds with HSEEP requirements by revising FEMA's grant monitoring guidance, for example by including a checklist of specific HSEEP requirements for state validation and certification.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Not Implemented

Comments: According to the agency response in its 31 U.S. Code section 720 letter, dated September 1, 2010, Federal Emergency Management Agency (FEMA) officials did not concur with this recommendation. They said the Homeland Security Exercise Evaluation Program (HSEEP) is a tool to assist State and local jurisdictions plan, conduct, and evaluate exercises. However, because of the emphasis on "HSEEP compliance" over the past several years, this resource has been perceived as unwieldy and often burdensome to stakeholders; detracting from the ultimate value of HSEEP. FEMA is working to identify all the various reporting requirements that are levied on state/local partners and to ultimately reduce and/or consolidate them so that FEMA is getting the information it requires in a manner that is least burdensome to stakeholders. This recommendation is closed as not implemented.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by involving the National Council on Disability on committees involved in the design and execution of national level exercises, especially on issues related to populations with special needs.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Implemented

Comments: The Federal Emergency Management Agency (FEMA) reported in September 2010 that the agency has added the National Council on Disability to the invitee list for the annual National Exercise Program planning conferences, including National Level Exercises. According to FEMA, the National Exercise Division has begun collaborative discussions directly with the National Council on Disability and through the FEMA Office of Disability Integration and Coordination on how best to incorporate the unique life experiences of people with disabilities in the design and execution of exercises, including national level exercises.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by developing internal control policies and procedures that validate the completeness and accuracy of data used to measure program performance. Such procedures could involve checking whether states and federal agencies are providing data and information needed to measure the performance of the program.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Open

Comments: According to the agency response in its 31 U.S. Code section 720 letter, dated September 1, 2010, the Federal Emergency Management Agency's (FEMA) National Preparedness Directorate/National Exercise Division (NPD/NED) is revising policies and procedures for the National Exercise Program (NEP) and the Homeland Security Exercise Evaluation Program (HSEEP). The revisions will address how FEMA will work with Federal agencies and States to confirm that they are providing data and information needed to measure program performance. NED will coordinate with NPD's National Preparedness Assessment Division (NPAD) on ways to improve the effectiveness of program evaluation for the NEP and HSEEP, as well as the value of exercise data for the Comprehensive Assessment System. This recommendation remains open pending completion of these actions. FEMA provided an update to this response in February 2012 that indicated that NPD is continuing its efforts to revise policies to enable them to validate data provided for program evaluation. An update provided in June 2012 reiterated that NPD/NED is still revising policies and procedures for the NEP and the HSEEP.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by revising the National Exercise Program Implementation Plan to require the use of FEMA's Corrective Action Program for all federal exercises that involve interagency testing of roles and responsibilities or require that federal agencies submit a report to FEMA on the status of their corrective actions resulting from such exercises.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Open

Comments: According to the agency response in its 31 U.S. Code section 720 letter, dated September 1, 2010, the Federal Emergency Management Agency's (FEMA) National Exercise Program Implementation Plan (NEP I-Plan) designates the Corrective Action Program as the mechanism for identifying and tracking corrective actions for exercises. It further states that Departments and Agencies--as well as State, territorial, tribal, and local governments and private sector entities--may submit issues to the Corrective Action Program through the web-based Corrective Action Program System. The NEP I-Plan requires all departments and agencies to maintain a Corrective Action Program that can generate input for, and track assignments from, the Corrective Action Program for unclassified issues. FEMA is chairing a Federal Working Group, established in June 2010, to develop an implementation plan for the Remedial Action Management Program (RAMP). The RAMP Implementation Plan will establish policies and procedures for documenting Federal corrective actions and lessons learned from exercises, real-world events and policy discussions. This will all be coordinated with the NEP reform and revisions to exercise doctrine, including the HSEEP. FEMA reported in June 2012 that a revised NEP I-Plan was being cleared with the Department and that the plan will continue to emphasize a standard corrective action/remedial action process to include periodic reporting on status of NEP corrective actions. NED will solicit input from departments and agencies on how to refine and strengthen this process through development of the revised NEP I-Plan. This recommendation will remain open pending completion of the RAMP implementation plan and revised NEP Implementation Plan.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by developing procedures for including "lessons learned" from real-world incidents in the Corrective Action Program system.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Open

Comments: According to the agency response in its 31 U.S. Code section 720 letter dated September 1, 2010, the Federal Emergency Management Agency's Remedial Action Management Program (RAMP) Implementation Plan will establish policies and procedures for documenting Federal corrective actions and lessons learned from exercises, real-world events and policy discussions. FEMA provided an update in June 2012 that reported that the agency is chairing a Federal Working Group, established in June 2010 to develop an I-Plan for the RAMP. The RAMP I-Plan will establish policies and procedures for documenting Federal corrective actions and lessons learned from exercises, real-world events, and policy discussions. This will be coordinated with the NEP reform and revisions to exercise doctrine, including the HSEEP. Pending completion of the RAMP Implementation Plan, this recommendation will remain open.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the Office of Preparedness Policy, Planning, and Analysis to improve its approach for developing a comprehensive assessment system by enhancing its project management plan to include milestone dates, an assessment of risk, and related mitigation strategies for (1) comprehensively collecting and reporting on disparate information sources, (2) developing quantifiable metrics for target capabilities that are to be used to collect and report preparedness information, and (3) reporting on the results of preparedness assessments to help inform homeland security resource allocation decisions.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Implemented

Comments: In response to our recommendation, the Federal Emergency Management Agency reported in September 2010 that the agency's efforts in implementing the comprehensive assessment system reflected its improved approach. Program officials provided an updated project plan that included milestone dates that included risk assessment and mitigation. As a result, this recommendation is closed as implemented.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Preparedness Directorate to take a more strategic approach to developing the national preparedness system by developing a strategic plan for implementing the national preparedness system that includes the key characteristics of a strategic plan, including coordination, integration, and implementation approaches.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Implemented

Comments: In April 2009, we reported that developing goals and metrics to measure progress towards achieving an integrated system would help FEMA prioritize actions, requirements, and national investments in preparedness and that a strategic plan for the National Preparedness Directorate that describes how it will approach these challenges and mitigate these weaknesses would help FEMA partner with the many organizations whose cooperation and resources are necessary for success. We recommended that FEMA develop a strategic plan for implementing the national preparedness system that includes the key characteristics of a strategic plan, including coordination, integration, and implementation approaches. In response, NPD issued a 2011 report on its Strategic Intent for Fiscal Year 2012-2014. The report defines the mission and responsibilities of the Directorate, its strategic priorities, and the major outcomes anticipated from each of the priorities for the years covered by the plan, many of the program management elements called for in this recommendation. As a result of these efforts to describe and document a strategic approach, FEMA's oversight and management of national preparedness efforts can better ensure effective participation and implementation by federal, state and local stakeholders.