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GAO-13-250R: 

United States Government Accountability Office: 
Washington, DC 20548: 

March 22, 2013: 

The Honorable Bennie G. Thompson: 
Ranking Member: 
Committee on Homeland Security: 
House of Representatives: 

Subject: FEMA Reservists: Training Could Benefit from Examination of 
Practices at Other Agencies: 

Dear Mr. Thompson: 

Hurricane Sandy made landfall on October 29, 2012, in New Jersey, 
leaving extensive flooding, loss of life, and property damage across 
the eastern United States in its wake. Within 3 days of the 
hurricane's landfall, more than 2,300 Federal Emergency Management 
Agency (FEMA) personnel were working to support response operations, 
including search and rescue, power restoration, communications, and 
logistical support in states affected by the storm. Hurricane Sandy 
was one of 46 federal major disaster declarations in fiscal year 2012. 
From fiscal year 2007 through fiscal year 2012, there have been 422 
federal major disaster declarations in which FEMA has obligated $39 
billion in major disaster assistance payments.[Footnote 1] 

Within the Department of Homeland Security (DHS), FEMA is tasked with 
leading the nation in mitigating, responding to, and recovering from 
major disasters, both natural and man-made. To carry out its mission, 
FEMA relies heavily upon its Reservist Program, an on-call reserve 
workforce that is deployed when needed to assist disaster survivors. 
As of February 2013, there were 6,795 reservists, who constituted 36 
percent of FEMA's disaster workforce. In April 2012, FEMA announced 
that it was transforming its reservist workforce, formerly known as 
Disaster Assistance Employees. Among other things, the transformation 
to the Reservist Program transitioned reservist assignments from a 
regionally based structure to a nationally managed program. 

We have identified several challenges related to FEMA's reservist 
training practices. Specifically, in May 2012, we reported that FEMA's 
reservist training was not consistent with key attributes of effective 
training and development programs that could help to ensure that its 
training and development investments were targeted strategically. We 
recommended that FEMA establish a plan to ensure all reservists have 
opportunities to participate in training and are qualified and that 
FEMA develop a systematic process to track training costs.[Footnote 2] 
FEMA officials agreed with the recommendations. In October 2012 the 
agency launched the FEMA Qualification System (FQS) and the Incident 
Qualification Certification System (IQCS) to track reservist training 
and qualifications.[Footnote 3] According to the officials, they 
anticipate that IQCS will enable FEMA to better track training costs. 
In April 2012, we also reported that FEMA's training information 
system did not provide a comprehensive or accurate account of all 
training activities of FEMA employees, including reservists, and we 
recommended that FEMA develop systematic processes to collect and 
analyze training data.[Footnote 4] FEMA agreed with the recommendation 
and is increasing its capacity for analyzing training data through the 
development of a human capital data warehouse. 

You asked us to assess FEMA's reservist workforce training. Our 
objective was to examine how FEMA's reservist workforce training 
compares with training of other similar agencies, and to what extent 
FEMA has examined these agencies' training programs to identify useful 
practices. In addition, the enclosure provides additional information 
on reservist program characteristics that may affect training. 
Specifically, the enclosure provides information on reserve program 
missions, organizational structure, hiring process and pay, and 
approaches to deployment at FEMA and the three similar agencies--Small 
Business Administration (SBA); Fire and Aviation Management (FAM), 
which is within the U.S. Department of Agriculture's Forest Service; 
and the U.S. Coast Guard, within DHS. 

To compare reservist training at FEMA with training at similar 
agencies--that is, agencies with a disaster mission--we selected three 
agencies by evaluating the comparability of 10 potential organizations 
with FEMA. We identified these 10 organizations based on a judgmental 
selection of agencies with disaster-related programs or missions, 
including those with an international focus, military function, public 
health mission, role in Katrina, or a relationship with FEMA in 
developing its qualification system. We evaluated the organizations 
and selected SBA, the Forest Service, and the Coast Guard for our 
review because each has a domestic mission and a reservist program 
that includes temporary or part-time employees (similar to FEMA's 
program).[Footnote 5] Within FEMA and the three selected reservist 
programs, we compared segments of these programs that were related to 
disaster response or recovery and composed of employees who have 
temporary appointments and who work on an intermittent (on-call) or 
seasonal basis. We consider these types of employees reservists for 
the purposes of this report. We selected FEMA Reservists, but did not 
consider in our comparison permanent full-time FEMA staff with 
collateral, disaster-related duties in the field; FEMA's Cadre of On-
Call Response/Recovery Employees (CORE) because they are hired on a 
temporary, full-time basis for 2-and 4-year terms; or the National 
Civilian Community Corps-FEMA Corps program, as Corps Members serve 
full-time for 10-month terms with an option to renew for an additional 
10-month term. We selected the following employee categories at the 
comparison agencies because they maintain a contingent of reservists 
as defined above: the Coast Guard Selected Reserve; SBA surge and 
surge plus staff, including term intermittent and Schedule A staff; 
[Footnote 6] and Forest Service temporary seasonal employees and 
administratively determined (AD) employees.[Footnote 7] 

At FEMA and at each of the selected agencies, we reviewed reserve 
program documentation, such as training-related manuals, legislation 
related to each program, hiring and deployment guidance, and fiscal 
year 2012 budget documents, where available. We also interviewed 
agency officials responsible for overseeing the training programs to 
compare reservist training requirements, funding sources, and delivery 
mechanisms, and to identify information described in the enclosure, 
including reserve program missions, hiring, and deployment processes. 
In addition, to identify the extent to which FEMA examined other 
agencies' practices, we reviewed a contractor's draft evaluation of 
FEMA's reserve program and interviewed FEMA officials responsible for 
overseeing the program.[Footnote 8] We compared this information to 
our prior work on effective training programs, which included 
practices such as learning from other organizations as a core 
characteristic of a strategic training process.[Footnote 9] 

We conducted this performance audit from May 2012 through March 2013 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Results in Brief: 

We compared FEMA's training of reservists with the training provided 
to reservists at the SBA, the Forest Service, and the Coast Guard--
agencies with a disaster mission--and found similarities and 
differences; and, moreover, FEMA had not examined other agencies' 
training programs to identify useful practices.[Footnote 10] All four 
training programs shared some similar attributes with regard to 
training requirements, funding sources, training delivery, and 
training evaluation. For example, FEMA and two of the comparison 
agencies have a credentialing program used to document reservist 
qualifications. Differences included the timing of when training is 
delivered and the use of job aids to reinforce reservists' 
understanding of material covered in training courses. Regarding 
timing, SBA, the Forest Service, and the Coast Guard each train their 
reservists in advance of deploying these individuals to a disaster. 
However, factors such as the way in which FEMA funds its disaster 
program have limited the agency's ability to train its reservists in 
advance of deployments to disasters. FEMA plans to begin allowing up 
to 2 weeks of reservist training outside of deployments under the new 
reservist program during fiscal year 2013. Differences we identified 
in training practices indicate that an examination of other agencies' 
reserve training programs could be beneficial. For example, FEMA may 
benefit from examining the Coast Guard's use of job aids, which 
reinforce reservist training course material after course work is 
completed. As part of our work identifying key attributes of 
successful training programs, we have previously identified developing 
partnerships and learning from others as a core characteristic of a 
strategic training process.[Footnote 11] FEMA officials stated that 
while they had not looked to other agencies' training programs, 
training practices at other agencies that we highlighted in this 
report provide useful information for FEMA as it works to improve its 
reservist training efforts. 

To enhance its training of reservists, we are recommending that FEMA 
examine the training practices of other agencies with disaster 
reservist workforces to identify potentially useful practices. DHS 
concurred with our recommendation and described plans to address it. 
DHS, SBA, and the Forest Service provided technical comments, which we 
incorporated as appropriate. 

Background: 

SBA, the Forest Service, the Coast Guard, and FEMA each have reserve 
programs established to supplement full-time agency staff when 
responding to disasters. These additional resources have unique 
missions during response and recovery efforts, such as processing 
loans, extinguishing wildfires, securing ports, or assisting with 
temporary housing. Descriptions of these reservist programs are listed 
in table 1. 

Agency: Small Business Administration; 
Reserve program and description of staff: Term intermittent surge 
staff: Deployed to assist businesses, non-profits, and households 
affected by disasters, primarily with loans. Surge staff are on SBA's 
payroll and are to be called upon to respond to disaster activity when 
the core group, such as permanent, cadre, and term seasonal staff, 
have been exhausted. Surge staff compete for employment lasting for a 
period of more than 1 year and not to exceed 4 years. These staff are 
typically used when work is sporadic, unpredictable and cannot be 
regularly scheduled in advance or during a drastic increase in 
disaster activity; 
Number of reservists[A]: 1,730. 

Agency: Small Business Administration; 
Reserve program and description of staff: Surge Plus staff: Term 
intermittent staff may be supplemented by surge plus reservists 
(Schedule A staff), who are employees hired without competing for 
employment, when surge staff have been exhausted; 
Number of reservists[A]: 1,319. 

Agency: Forest Service; 
Reserve program and description of staff: Temporary employees: 
Deployed to fight wildfires. Limited to working 1,039 hours in a given 
position per year. They may be rehired each year if there is a need, 
but they are terminated at the end of the fire season or period of 
need; 
Number of reservists[A]: 3,725. 

Agency: Forest Service; 
Reserve program and description of staff: Administratively determined 
emergency workers: Deployed to fight wildfires. Hired for surge 
capacity in each geographical area. They are not guaranteed any 
quantity of hours deployed; 
Number of reservists[A]: 6,273. 

Agency: Coast Guard; 
Reserve program and description of staff: Selected reserve: Deployed 
to supplement active duty personnel during disasters or routine 
maritime safety and security operations.[B] Required to perform 24 
days of inactive duty training commonly known as drill weekends, and 
12 days of annual training. The 24 days is normally on-the-job 
training (OJT), and the 12 days of annual training may be OJT or 
classroom training. For disasters, they can be ordered to active duty 
for no more than 60 days in any 4-month period, and no more than 120 
days in any 2-year period; 
Number of reservists[A]: 8,105. 

Agency: FEMA; 
Reserve program and description of staff: Reservists: Deployed to 
assist disaster survivors and their communities through functions such 
as directly supporting individuals and families with obtaining housing 
and other disaster benefits. FEMA is establishing a policy to deploy 
all reservists a minimum of once a year with the length of the 
deployment depending on operational needs. A deployment will be, on 
average, approximately 30 days in length, but may be longer; 
Number of reservists[A]: 6,795. 

Source: GAO analysis of reserve program documents and interviews with 
agency officials. 

[A] Totals listed for the number of reservists at each agency were 
provided as of the following dates: SBA (December 2012); Forest Service 
(February 2013); Coast Guard (October 2012); FEMA (February 2013). 

[B] Coast Guard reservists are recalled, activated, mobilized, or 
ordered to active duty, according to Coast Guard officials. However, 
for our purposes in this report, we refer to reservists as deployed 
when they are on active duty, as this term is used when referring to 
the same scenario at the other agencies compared here. 

[End of table] 

FEMA's Reservist Training Shares Some Attributes with Selected 
Agencies' Training, but FEMA Has Not Examined Practices from Agencies' 
Training Programs: 

SBA, the Forest Service, the Coast Guard, and FEMA have training 
programs that are designed to fit the respective needs of the 
reservist programs. These training programs vary with regard to 
training requirements, funding sources and needs determination, 
training delivery, and training evaluation. 

FEMA Shares Similarities with Selected Agency Training Programs, but 
Differences Exist: 

Overview of Training Programs at Selected Agencies: 

As shown in figure 1, the training programs of FEMA and the three 
selected agencies have varying characteristics, as called for by the 
specific training needs of the program. 

Figure 1: Overview of SBA, Forest Service, Coast Guard, and FEMA 
Reservist Training Programs: 

[Refer to PDF for image: illustrated table] 

Small Business Administration: 
Training for reserves is provided on a just-in-time basis. Session 
topics include customer service, loan processing, loan closing and 
disbursement, and field inspections for damage loss verification. 
Regional administrators, regional communication directors, and 
district and disaster public information officers receive training 
focused on crisis communications, dealing with the media, and 
understanding disaster assistance provided by other federal agencies. 
Training includes sessions on best practices in preparedness 
communications to assist district offices with an effective strategy 
to target local business owners and residents. 

U.S. Forest Service: 
All Forest Service employees who are deployed to fires must complete 
the basic firefighting course, which typically lasts 1 week. In 
addition, they must receive annual refresher training. Firefighter 
qualifications are already entered into a system prior to an employee 
being deployed to fight a fire as proof that they are qualified. There 
are, however, opportunities for trainees to shadow qualified 
firefighters during an event as a way to help prepare the next wave of 
potential firefighters. Shadowing and any other onsite training is 
done according to the standards of the National Wildfire Coordinating 
Group (NWCG). This group sets minimum training, experience, and 
physical fitness standards for wildland fire positions. Firefighting 
agencies like the Forest Service that belong to the NWCG, issue 
Incident Qualification Cards to individuals who successfully complete 
the NWCG required training, experience, and physical fitness standards 
established in the Wildland Fire Qualification System Guide. 

U.S. Coast Guard: 
Reservists attend basic training and are provided more specialized 
training specific to their job requirements. Once a reserve member 
completes basic training, additional training requirements are based 
on their occupational specialty and requirements of the position 
assigned. The requirements include the following: 

Required to perform 24 days of inactive duty training known as drill 
weekends, and 12 days of annual training. The 24 days is normally on-
the-job training (OJT), and the 12 days of annual training may be OJT 
or classroom training. For disasters, they can be ordered to active 
duty for no more than 60 days in any 4-month period, and no more than 
120 days in any 2-year period. Reservists earn points for membership, 
participation, and the completion of certain correspondence courses. 
These points are used to calculate a reservist’s retirement 
eligibility and retirement pay. 

These training requirements are essentially the same as those for an 
active duty member with the same rating and serving in the same type 
of position, according to Coast Guard officials. 

Federal Emergency Management Agency (FEMA): 
FEMA established the following training principles for the new FEMA 
Reservist Program in a policy directive:[A] 

* Directive: FEMA shall train and certify all reservists in accordance 
with the FEMA Qualification System (FQS).[B] 

* Directive: All reservists shall receive training in government 
ethics, fraud detection and prevention, equal rights, privacy, and 
security. 

* Directive: The delivery of training shall take place in-person at 
FEMA headquarters, Emergency Management Institute, FEMA regions, field 
offices, and via the Internet, and be by methods most effective and 
efficient for the government. Reservists may be activated for up to 2 
weeks annually solely to complete training, including through verified 
telework from home or a remote location.[C] 

Source: GAO analysis of SBA, FAM, Coast Guard and FEMA data. 

[A] FEMA, FEMA Reservist Program. FD 010-6 Revision Number: 01. June 
14, 2012. 

[B] According to FEMA officials, FQS is a performance-based system 
whereby employees are determined to be either in trainee or qualified 
status in one of 322 jobs, each of which has a related position task 
book. Position task books outline required activities, tasks, and 
behaviors, and serve as a record for task completion. FQS, which was 
launched in October 2012, is FEMA's effort to credential all employees 
in incident management or support positions, including the reservist 
workforce. Examples of reservist courses include field attorney 
training, and basic training in community relations and congressional 
affairs. 

[C] FEMA has not yet implemented this directive, but plans limited 
implementation in fiscal year 2013 depending on available funding. 

[End of figure] 

Training Requirements: 

FEMA and selected agency training requirements are listed in figure 2. 
Similarities were evident in training types offered and in 
credentialing programs. 

[Refer to PDF for image: illustrated table] 

Introductory training (e.g., orientation, basic training: 
* Small Business Administration: Just-in-Time (JIT) training required 
of all reservists before deployment of activation; length, location, 
and content of introductory training depends on job function; 
* U.S. Forest Service: Basic fire training provided before responding 
to fires; orientation also provided to each new reservist; 
* U.S. Coast Guard: Basic training, with length depending on prior 
experience. Drills one weekend per month and 2 weeks per year. 
Additionally, members are expected to participate in Class A training, 
which prepares members to function as third class petty officers in 
the career path they chose during recruitment; 
* Federal Emergency Management Agency (FEMA): None: prior to new 
reservist program, FEMA regions conducted orientation on an ad hoc 
basis. FEMA is considering adopting a new hire orientation but does 
not yet have a deadline for making a decision. 

Advanced training (i.e., courses beyond introductory training): 
* Small Business Administration: Some reservists receive additional 
training if serving as team leads; some centers allow reservists to 
serve as team leads; other do not; 
* U.S. Forest Service: Courses for advancement identified in Incident 
Qualifications Certification System (IQCS), which standardizes 
qualifications for specific job categories and for advancement; 
voluntary for temps and administratively determined reservists; 
* U.S. Coast Guard: Class C school provides advanced/specialized 
skills and knowledge to perform a a task or group of tasks, required 
by a specific Coach Guard position completed after A-school; 
* Federal Emergency Management Agency (FEMA): Courses for advancement 
identified in FQS, which standardizes qualifications for specific job 
categories and for advancement. Two-week training allowed, outside of 
disaster deployments, per year for FQS requirements under the new 
reservist program. The 2 week training allowance was not fully 
implemented as of December 2012. 

Refresher training: 
* Small Business Administration: Refresher training provided through 
JIT and is required for reservists prior to each deployment provided 
the employee has not been deployed within the previous 6 months; 
* U.S. Forest Service: Annual refresher training prior to fire season; 
* U.S. Coast Guard: Upon arriving at disasters, reservists are able to 
receive area familiarization because active duty staff are responding 
to the disaster (e.g., oil spill); refresher training provided during 
drill time; 
* Federal Emergency Management Agency (FEMA): No requirements to do 
refresher training before deployment. 

Credentialing: 
* Small Business Administration: None; 
* U.S. Forest Service: Incident Qualifications Certification System 
(IQCS) standardizes qualifications for specific job categories and for 
advancement; voluntary for temps and administratively determined 
reservists. Note: National Wildfire Coordinating Group (multiple 
agencies) determine the classes and content for the basic and 
specialty training; 
* U.S. Coast Guard: Performance Qualification Standards (PQS), similar 
to FEMA Qualification System (FQS), with task books to complete 
indicating certification; 
* Federal Emergency Management Agency (FEMA): FEMA Qualification 
System (FQS) standardizes qualifications for specific job categories 
and for advancement. Reservists must complete the training required 
for their specific job category within a predetermined amount of time. 

Source: GAO analysis of SBA, FAM, Coast Guard and FEMA data. 

[End of figure] 

Training type. Each of the agencies has three types of training--
introductory, advanced, and refresher.[Footnote 12] Each agency has 
reservists across multiple functional disciplines and training is 
specialized for each discipline and varies depending on the specific 
job title. SBA's reservists participate in a systematic Just-in-Time 
training program as the agency gears up to meet its disaster recovery 
mission. Both the Forest Service and the Coast Guard have training 
requirements that include a certification process for their reservists 
who are involved in disaster response. Upon deploying its reservists, 
FEMA provides on-the-job training at joint field offices or any other 
appropriate field offices.[Footnote 13] FEMA plans to allow 2 weeks of 
training outside of deployments in response to reservist concerns 
about lack of training before deployments. 

Credentialing. Three of the four agencies have credentialing programs--
to document reservist qualifications--as shown in figure 2. The Forest 
Service and Coast Guard have credentialing programs similar to the 
FEMA Qualification System (FQS), while SBA does not have a 
credentialing program. Additionally, industry standards may affect an 
agency's credentialing requirements. For example, the National 
Wildfire Coordinating Group (NWCG) establishes, among other things, 
minimum requirements for training, experience, and physical fitness 
levels for wildland fire positions at all of its member agencies, 
including the Forest Service, as part of an effort to establish 
national mobilization standards. 

Training Funding Sources and Needs Determination: 

The types of funding sources for reservist training and how training 
needs are determined vary across the four agencies, as shown in figure 
3. 

Figure 3: Comparison of Agency Funding Sources and Training Needs 
Determination: 

[Refer to PDF for image: illustrated table] 

Funding Source: 
* Small Business Administration: No training appropriation for 
reservists. Headquarters allocates funds for operations, training 
considered an operational cost; 
* U.S. Forest Service: No training appropriation for reservists. 
Headquarters allocates funds for operations, training considered an 
operational cost; 
* U.S. Coast Guard: The Coast Guard receives an annual appropriation 
for reservists’ training costs, which includes weekend drills and the 
2 weeks per year of required reservist training; 
* Federal Emergency Management Agency (FEMA): Appropriated Disaster 
Relief Fund (DRF) and, within DRF, the Disaster Readiness and Support 
fund (DRS). DRF is used for training at Joint Field Offices for just-
in-time training. DRS is used to send reservists for formal training 
at Emergency Management Institute and other locations. 

How training needs are determined: 
* Small Business Administration: Training needs and curriculum 
determined locally; 
* U.S. Forest Service: Training need determinations depend on the 
course types. Introductory course needs are determined locally, 
intermediate regionally, and advanced are determined nationally; 
* U.S. Coast Guard: Training needs determined locally by reserve 
program offices located at Coast Guard districts; 
* Federal Emergency Management Agency (FEMA): Under the new reservist 
program, training needs are to be centrally determined through FEMA 
Qualification System (FQS). Reservist position task books (PTB) 
identify courses required to be qualified for a position in FQS. PTB 
progress is to be tracked in FQS, which allows FEMA to determine which 
courses are needed for reservists. As of January 2013, this process 
was implemented, according to FEMA officials. 

Source: GAO analysis of SBA, FAM, Coast Guard and FEMA data. 

[End of figure] 

SBA and the Forest Service do not have appropriations separately 
designated for reservist training. Instead, training costs are part of 
overall agency operating costs. The Coast Guard, on the other hand, 
has reservist training funds identified each year through its annual 
budget request and appropriation. Of the four agencies, only FEMA 
funds training outside of an annual budget allocation. FEMA's 
reservist training funds are provided by the Disaster Relief Fund, 
which is appropriated no-year funding that allows FEMA to manage and 
fund response and recovery efforts associated with domestic major 
disasters and emergencies.[Footnote 14] FEMA also funds reservist 
training through the Disaster Readiness and Support account, within 
the Disaster Relief Fund. According to FEMA officials, FEMA plans to 
fund most training courses through the Disaster Readiness and Support 
account in fiscal year 2013. For the fiscal year 2013 budget, FEMA 
justified its request by identifying training funding needed to 
fulfill reservist training needs, according to FEMA officials. 

With the exception of FEMA, each agency locally determines, at a 
minimum, introductory training needs. FEMA uses its centralized FQS 
system to determine training needs of reservists. Under FQS, 
reservists are to complete required training and demonstrate 
successful performance in specific areas in order to be qualified for 
their job titles. 

Administrative and Legal Factors May Affect Training Funding: 

Before implementation of the new FEMA reservist program, most of the 
funding for training FEMA reservists was available primarily when 
reservists were deployed, which limited the amount of training that 
was provided before deployments occur. Most reservist training 
occurred at field offices used during disaster response activities and 
was funded by the Disaster Relief Fund; limited additional training at 
FEMA's Emergency Management Institute was funded by the Disaster 
Readiness and Support account, within the Disaster Relief 
Fund.[Footnote 15] For each of the other agencies, training funds are 
not dependent on whether reservists are deployed, thereby allowing 
more flexibility in when training may be provided. Under FEMA's new 
reservist program, according to FEMA officials, FEMA plans for 
reservists to be allowed to train at the Emergency Management 
Institute and their homes (for web-based courses) outside of disaster 
deployments. While certain types of training are to continue to take 
place at disaster sites, FEMA officials acknowledged that having 
certain training courses take place in the midst of a disaster may not 
be feasible. Such courses include intermediate-and advanced-level 
training, according to the officials. 

Legal requirements also affect the Coast Guard's training funding. For 
the Coast Guard, reservists are required to participate in at least 48 
scheduled drills or training periods during each year and serve on 
active duty for training of not less than 12 days during each year or 
not more than 30 days during each year.[Footnote 16] Therefore, the 
Coast Guard must request training funding and obtain an appropriation, 
since the training is mandated by law. The three other agencies do not 
have such legal requirements for reservist training. 

Training Delivery Mechanisms: 

FEMA's delivery of training is comparable to that of the other three 
agencies in terms of format, use of third-party providers, and 
location, but its timing of training differs, as shown in figure 4. 

Figure 4: Comparison of Agency Training Delivery Mechanisms: 

[Refer to PDF for image: illustrated table] 

Format: 
* Small Business Administration: On-the-job training (OJT) and 
classroom; 
* U.S. Forest Service: Classroom, OJT (task books, apprenticeship), 
and web-based; 
* U.S. Coast Guard: Classroom, web-based, OJT, and job aids; 
* Federal Emergency Management Agency (FEMA): Classroom, web-based, 
OJT, and correspondence courses. 

Third-party providers: 
* Small Business Administration: None; 
* U.S. Forest Service: Fire schools, interagency partnerships. The 
Forest Service is responsible for funding the training; 
* U.S. Coast Guard: FEMA’s Emergency Management Institute; 
* Federal Emergency Management Agency (FEMA): Third-party partnerships 
include Emergency Management Institute courses taught externally 
through Management Concept Institute. Third-party involvement also 
includes collaboration with various subject matter experts on 
leadership and management courses. 

Timing (i.e., training provided to reservist before he/she responds to 
a disaster event): 
* Small Business Administration: Reservists are provided Just-in-Time 
training both before events and during the agency’s response to the 
event; reservists cannot be deployed or activated unless they received 
minimum training; 
* U.S. Forest Service: Prior to and during fire season; 
* U.S. Coast Guard: Routinely and before events; reservists cannot be 
deployed unless they received basic training/boot camp; 
* Federal Emergency Management Agency (FEMA): Under the new reservist 
program, training is to be provided both before and during deployments 
to disasters. However, as of December 2012, training before deployment 
had not been implemented, pending funding availability. 

Location: 
* Small Business Administration: Training provided at SBA field office 
centers and remotely at disaster site; 
* U.S. Forest Service: Local units/forests (lower-level courses), 
geographical/regional training centers (higher-level) and 
apprenticeship academies; 
* U.S. Coast Guard: Local/regional/national OJT. Training provided at 
Coast Guard centers (e.g., Yorktown, VA), at duty stations, at events, 
and online; 
* Federal Emergency Management Agency (FEMA): Emergency Management 
Institute, Joint Field Offices (disaster site), and regional offices. 
FEMA plans to allow reservists to train at home, although this 
delivery mechanism has not been fully implemented. 

Source: GAO analysis of SBA, FAM, Coast Guard and FEMA data. 

[End of figure] 

Format. All of the agencies use a mix of classroom and on-the-job 
training. FEMA, the Forest Service, and the Coast Guard formalize on-
the-job training using position task books to document employees' 
experiences. The Coast Guard makes use of an additional tool--job 
aids--which give reservists step-by-step instructions for job tasks 
after training takes place. 

Third-party providers. FEMA uses third-party providers for teachers 
and in consultation in leadership and management courses. The Forest 
Service uses fire schools and interagency partnerships, such as the 
National Wildfire Coordinating Group, and the Coast Guard sends 
reservists to FEMA's Emergency Management Institute for training. SBA 
does not use third parties for training reservists. 

Timing. FEMA differs from the three comparison agencies in terms of 
when it provides training for its reservists. Officials from all of 
the comparison agencies emphasized the importance of providing 
classroom and on-the-job training to reservists before they are 
permitted to work without supervision at a disaster. In contrast, FEMA 
did not provide orientation or basic training to reservists prior to 
deployments, nor did it generally deploy reservists for training 
immediately prior to responding to a disaster. According to FEMA 
officials, FEMA plans to seek funding in order to provide 14 days of 
training annually to reservists outside of disaster deployments. 

Location. All of the agencies provide classroom or on-the-job training 
in local areas, at regional and national training centers, and at 
disaster sites. For example, during Hurricane Irene, SBA staff 
traveled to multiple field locations outside of their home regions in 
order to help train customer service representatives where management 
staff were occupied responding to the disaster. According to SBA 
officials, it was more efficient to send staff to locations where 
there were large numbers of individuals that needed training. 

Training Evaluation: 

The agencies we compared evaluate the effectiveness of reservist 
training in several ways. Both FEMA and the Coast Guard use 
Kirkpatrick's evaluation technique.[Footnote 17] Figure 5 lists 
evaluation techniques used by FEMA and the selected agencies. 

Figure 5: Comparison of Agency Reservist Training Evaluation 
Techniques: 

[Refer to PDF for image: illustrated table] 

Small Business Administration: 
Reservist training is evaluated by SBA through course evaluations and 
through feedback from loan customers and internal stakeholders. 

* Course evaluations. Participants from each course are given an 
opportunity to submit an evaluation of the course to help improve the 
delivery of the material presented. 

* Feedback from loan customers. Since 2009, the Office of Disaster 
Assistance (ODA) has used its call center in Buffalo to reach out to 
its customers to rate the quality of the service they received from 
call center staff in order to retrain reservists as necessary. 
Approximately 80 percent of their customers are asked to provide their 
feedback about their experience with call center customer service 
representatives (CSR), according to ODA officials. 

* Internal stakeholders. In addition to consumer feedback from 
disaster survivors, SBA CSRs will also receive feedback from internal 
stakeholders, such as ODA’s loan processers, who handle much of the 
paperwork collected by CSRs at the Disaster Recovery Center (DRC). 
Likewise, operators at the call center in Buffalo may receive 
complaints or need clarification regarding information that they 
received from a CSR in the field. 

U.S. Forest Service: 
According to Forest Service officials, reservist training courses are 
evaluated through feedback on the courses from reservists, performance 
evaluations on incidents, as well as completion of the mentorship 
process with the position task books. Forest Service employees utilize 
a position task book to become qualified to perform the job. In 
addition to evaluation of courses by students, instructors check 
course materials for outdated information to report to the National 
Wildfire Coordination Group (NWCG) training office to see if 
corrections need to be made. NWCG’s goal is to evaluate each course 
every 5 years. 

U.S. Coast Guard: 
The Coast Guard employs Kirkpatrick’s Model for evaluating the 
effectiveness of its training programs, according to Coast Guard 
officials. The Kirkpatrick’s model includes four levels of measurement 
at the Coast Guard, although the Coast Guard’s emphasis is on the 
levels 1-3, according to Coast Guard officials. 

Federal Emergency Management Agency (FEMA): 
FEMA uses Kirkpatrick training evaluation levels 1-3 on student 
evaluations for all courses offered to reservists, according to FEMA 
officials. The officials stated that each student is allowed to 
provide direct feedback during each course offering. 

Source: GAO analysis of SBA, FAM, Coast Guard and FEMA data. 

[End of figure] 

FEMA Has Not Examined Training Practices at Selected Agencies: 

FEMA adopted its qualification system from another agency, but has not 
examined the training practices of other agencies with a reservist 
workforce to identify applicable useful practices. According to FEMA 
officials, FEMA consulted the Forest Service's Wildland Fire 
Qualification System to develop FEMA's FQS and associated training 
requirements. FQS training requirements provide what training is 
necessary to qualify reservists for positions. FQS, however, does not 
address training practices, such as timing and delivery mechanisms. 
The officials stated that elements within the Wildland Fire 
Qualification System served as a baseline and guidance for 
establishing a FEMA credentialing system that ensures FEMA's disaster 
workforce is equipped with the skills, knowledge, and experience to 
perform effectively during a disaster. FEMA officials stated that they 
studied features of the Wildland Fire Qualification System including 
position qualifications and required training. FEMA's efforts to 
identify practices in developing the FQS system are noteworthy; 
however, evaluating training activities at other similar agencies may 
uncover useful practices related to training beyond qualification 
issues, such as timing of training delivery, course evaluation 
techniques, or supplementary training materials. For example, when 
comparing reservist programs, we identified several potentially useful 
practices that demonstrate how evaluating other training efforts may 
uncover useful activities: 

* Training reservists before deployment at SBA, the Forest Service, 
and the Coast Guard. FEMA officials stated that a complaint among 
reservists was that training was not provided before deployment to 
disasters. FEMA's new program includes a provision for 2 weeks of 
training outside of disaster deployments. Since the new program is not 
yet fully implemented, pending funding availability, FEMA may learn 
from other agencies' approaches to this form of training. 

* Job aids used to reinforce and refresh reservists understanding of 
material covered in training courses at the Coast Guard. FEMA 
implemented position task books as part of the October 2012 launch of 
FQS. The Coast Guard's job aids, in use for several years, may provide 
useful information for how reservists can rely on documents that 
reinforce training course material after course work is completed to 
better understand their positions. 

* Use of customer feedback at SBA call centers to retrain SBA 
reservists to better serve loan applicants. According to FEMA 
officials, FEMA is not currently receiving feedback from SBA that 
could be useful for improving FEMA reservist training.[Footnote 18] 
For example, according to SBA officials, SBA routinely receives 
feedback from loan applicants about the level of customer service its 
representatives provided. While SBA solicits feedback about its own 
processes, some of this feedback may entail information about FEMA 
that may assist FEMA in better training its reservists. 

A 2007 Booz Allen preliminary report that evaluated FEMA's disaster 
workforce program also identified certain key practices related to 
training--primarily that several agencies' (the Forest Service, Coast 
Guard, and World Health Organization) reservist training and 
credentialing were standardized, while FEMA's training was not 
standardized and did not include credentialing at that time. The 
report also identified benefits of standardized training and 
credentialing, including preparation of personnel to support disasters 
in any geographic location. Given that FQS went into effect in October 
2012, the identification of practices that could help further 
standardize its reservist qualifications and training could better 
position FEMA to achieve such benefits. Further, as part of our work 
identifying key attributes of successful training programs, we have 
previously identified developing partnerships and learning from others 
as a core characteristic of a strategic training process.[Footnote 19] 
In addition to benchmarking high-performing organizations, these 
efforts allow an agency to keep abreast of current practices, enhance 
efficiency, and increase the effectiveness of its training and 
development programs. FEMA officials stated that while they had not 
looked to other agencies' training programs because they had been 
focused on developing the qualification system, other agencies' 
training practices that we highlighted in this report provide useful 
information as FEMA works to improve its reservist training efforts. 
These officials said that this information would be particularly 
helpful since FEMA recently launched its new reservist program. An 
examination of the training practices of other agencies with reservist 
workforces could help FEMA identify useful practices to enhance its 
training programs for the new reservist program. 

Conclusions: 

FEMA relies heavily upon its reservist workforce to meet the daunting 
task of leading the nation in mitigating, responding to, and 
recovering from major natural and man-made disasters. For this reason, 
a fully trained and deployable reservist workforce is critical to 
accomplishing the agency's disaster response mission. FEMA has made 
some progress in addressing weaknesses in its reserve training 
program, for example, by planning to track training costs and ensuring 
that all reservists are trained and qualified before they are 
deployed. However, additional effort could be made to ensure that its 
reservist training benefits from useful practices at other agencies 
with disaster missions. Results of our comparison of selected 
agencies' training programs show similarities in the factors that may 
affect training, such as reservist training requirements, delivery, 
and evaluation. At the same time, differences we identified in 
training practices indicate that FEMA could benefit from examining 
other agencies' reserve training programs. Such an examination of the 
training practices of other disaster response agencies to identify 
applicable practices could help FEMA enhance the readiness of its 
reservist workforce. 

Recommendation for Executive Action: 

To enhance its training of reservists and meet its goal of having 
qualified reservists, we recommend that the FEMA Administrator examine 
the training practices of other agencies with disaster reservist 
workforces to identify potentially useful practices. 

Agency Comments: 

We requested comments on this report from the Departments of Homeland 
Security and Agriculture and the Small Business Administration. On 
March 8, 2013, DHS--commenting for FEMA and the Coast Guard--and the 
Department of Agriculture provided written comments, which are 
summarized below and reprinted in enclosures II and III. The 
Departments of Homeland Security and Agriculture and the Small 
Business Administration also provided technical comments, which we 
incorporated as appropriate. 

In commenting on the draft report, DHS concurred with the 
recommendation to examine training practices of other agencies with 
disaster reservist workforces to identify potentially useful practices 
and described actions planned to address it. DHS stated that FEMA will 
work to coordinate with other organizations to address the 
recommendation and plans to develop a corrective action plan within 60 
calendar days of receiving the final report. DHS also stated that FEMA 
agrees that valuable insight may be gained by assessing training 
programs of other agencies. 

The Department of Agriculture stated that it agrees with the findings 
and recommendation that FEMA examine reservist training programs of 
other federal agencies. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the 
Secretaries of Homeland Security and Agriculture, the Administrator of 
the Small Business Administration, and selected congressional 
committees. This report will also be available at no charge on the GAO 
web site at [hyperlink, http://www.gao.gov. Should you or your staff 
have any questions, please contact me at (202) 512-9610 or 
CaldwellS@gao.gov. Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
report. Key contributors to this report were Leyla Kazaz, Assistant 
Director; Ben Atwater; Martene Bryan; Tracey King; Landis Lindsey; 
Lauren Membreno; Linda Miller; Cindy Saunders; and Edith Sohna. 

Sincerely yours, 

Signed by: 

Stephen L. Caldwell: 
Director, Homeland Security and Justice: 

Enclosures--3: 

[End of section] 

Enclosure I: Federal Emergency Management Agency, U.S. Coast Guard, 
Small Business Administration, and U.S. Forest Service's Reserve 
Program Profiles: 

To supplement our comparison of reservist training practices and to 
provide context for the reservist operating environment, this 
enclosure provides information about reserve program missions and 
funding, reservist definitions and organizational structure, hiring 
process and pay, and deployment practices for FEMA and the three 
selected agencies in our review. 

Federal Emergency Management Agency Reservist Program: 

The Federal Emergency Management Agency's (FEMA) Disaster Assistance 
Employee (DAE) program was transformed into the current FEMA Reservist 
Program beginning in April 2012. All DAEs (hereafter referred to as 
FEMA reservists) were required to re-apply for positions in the new 
reservist program. According to FEMA officials, the agency anticipates 
hiring a total of 10,900 reservists for the new program. During the 
first phase of reservist hiring, 6,795 reservists where hired as of 
February 2013. The second phase of reservist hiring was scheduled to 
commence in February 2013, according to FEMA officials. Under the Post-
Katrina Emergency Management Reform Act of 2006 (Post-Katrina Act), 
FEMA is responsible for developing standards for deployment 
capabilities including credentialing of personnel likely to respond to 
natural disasters, acts of terrorism, and other man-made disasters. 
[Footnote 20] The FEMA Qualification System (FQS), which FEMA began 
developing in July 2010, is the agency's effort to credential all 
employees, including the reservist workforce, in incident management 
or support positions.[Footnote 21] FEMA launched FQS in October 2012 
for implementation, and, as of January 2013, FQS was in use by all 
reservist groups (known as cadres), according to FEMA officials. 

In June 2012, FEMA issued an administrative directive that governs its 
reservist program.[Footnote 22] Summarized below is the directive's 
content related to reservist mission, management structure, hiring 
process and pay, and deployment.We did not evaluate the extent to 
which FEMA has implemented the reservist program directives summarized 
here because FEMA was in the process of implementing its new reservist 
program during our review. 

Mission: 

FEMA reservists support FEMA's mission, as defined by the Post-Katrina 
Act. FEMA's mission is, among other things, to develop a federal 
response capability that can act effectively and rapidly deliver 
assistance essential to saving lives or protecting or preserving 
property or public health and safety in a natural disaster, act of 
terrorism, or other man-made disaster.[Footnote 23] The Robert T. 
Stafford Disaster Relief and Emergency Assistance Act also provides 
FEMA with authority to appoint and adjust the compensation of 
temporary personnel (i.e., reservists) as may be necessary, without 
regard to the provisions of title 5, United States Code, governing 
appointments in the competitive service.[Footnote 24] 

Reservist Definitions and Organizational Structure: 

FEMA reservists are federal employees who form the nucleus of FEMA's 
incident workforce. Reservists staff disaster response centers; 
interview disaster survivors; conduct and verify damage assessments; 
provide administrative, financial, and logistical support; and perform 
a wide variety of other tasks as identified by staffing needs and 
operational requirements. Reservist program managers (RPM) manage 
national-level groups of reservists organized by operational function 
and FQS position. 

Hiring Process and Pay: 

DAEs holding active appointments who reapply and transition directly 
from the DAE Program into the Reservist Program before the end of 
calendar year 2012, without any break in service, shall be paid at the 
DAE Program rate to which they were last entitled or the Reservist 
Program rate for their FQS position, whichever is higher. However, if 
an individual applies for a position that is subordinate to his or her 
qualified FQS position, then the individual will receive the pay rate 
of the subordinate position. If there is a break in service, a former 
DAE who returns to the Reservist Program shall receive pay in 
accordance with the new reservist program requirements. 

The following applies to hiring new recruits: 

* FEMA's Assistant Administrator for Response, in coordination with 
program offices, shall determine the size of cadres by functional job 
category through analysis of factors such as historical deployment 
data, FEMA readiness requirements, and FEMA's force structure. 
[Footnote 25] 

* Recruiting for reservist cadres shall include efforts to hire 
personnel for the required number and distribution of positions 
identified by the FEMA Force Structure. In determining the sources and 
methods for recruiting reservists, FEMA shall consider the most 
efficient means to recruit the best-qualified candidates for the 
specific positions, the FQS qualifications required to perform the 
duties, and nondiscrimination and diversity requirements. 

* FEMA pays reservists for those periods when they are activated and 
working or in a travel or training status. At all other times, 
reservists remain FEMA employees in a nonpay status. No reservist will 
be entitled to civil service retirement by virtue of his/her 
employment as a reservist.[Footnote 26] 

Deployment Practices: 

FEMA's Incident Workforce Management Office (IWMO) leads the effort to 
identify and select the FQS-qualified reservist personnel from the 
FEMA headquarters program offices, which train, maintain, and provide 
program policy for distinct reservist cadres deployed in support of 
disaster declarations. Each cadre has at least one designated, full-
time manager responsible for a wide range of cadre-specific 
activities, including ensuring that reservists in their cadres are 
trained, available, and ready to perform incident management and 
support functions in accordance with FQS. 

IWMO centrally deploys fully equipped, FQS-certified reservists and 
trainees in specific FQS positions. Upon arrival in the field, 
reservists join the incident management and support organization under 
the day-to-day direction of on-site FQS-certified supervisors, and 
perform work that corresponds to their FQS position task book 
positions. Those on-site supervisors manage day-to-day reservist 
performance, referring certain matters of recognition and discipline 
to FEMA management to ensure consistent, nationwide application of 
policy. 

The process outlined below in figure 6 describes how FEMA deploys 
reservists during a disaster: 

Figure 6: FEMA Reservist Deployment Process: 

[Refer to PDF for image: process illustration] 

Program Area supervisor identifies staffing requirement and submits 
deployment order to Regional Staffing Point of Contact (SPOC); 

SPOC reviews and submits Name Deployment Order to FEMA Automated 
Deployment Database; 

Deployment Unit processes Deployment Request; 

Deployment Unit notifies SPOC and employee; 

If employee accepts deployment, request is processed by deployment 
unit and employee is deployed. 

Source: FEMA. 

[End of figure] 

U.S. Coast Guard Reserve Program: 

Mission: 

The U.S. Coast Guard is responsible for maritime safety and security 
when preparing for and responding to natural disasters or incidents, 
in accordance with the National Response Framework (NRF), issued by 
FEMA in 2008 to present the guiding principles for all response 
entities to prepare for and provide a unified national response to 
disasters and emergencies. For example, according to the NRF, the 
Coast Guard has lead authority for certain mass migration management 
scenarios and significant oil or hazardous substance spill incidents 
in the maritime environment. The purpose of the Coast Guard reserve is 
to provide trained units and qualified persons available for active 
duty in the armed forces, in time of war or national emergency, and at 
other times as national security may require to fill the needs of the 
armed forces whenever more units and persons are needed than are in 
the active duty components.[Footnote 27] These trained units and 
qualified individuals also respond to domestic disasters, such as 
Hurricane Sandy. 

The Coast Guard reserve is one of the reserve components of the armed 
forces.[Footnote 28] By federal law, any member of the Coast Guard 
reserve serving on active duty or inactive duty training status has 
"the same authority, rights and privileges in the performance of that 
duty as a member of the regular Coast Guard of corresponding grade or 
rating."[Footnote 29] This provision allows qualified reservists to 
enforce federal law and make lawful arrests, when necessary, within 
the scope of their assigned duties. This authority allows reservists 
to function, interchangeably, with the same military and civil powers 
as their regular component counterparts, whether during inactive duty 
drills or while serving under active duty orders. 

Funding: 

Congress appropriated $134.3 million for the Coast Guard reserve 
program in fiscal year 2012.[Footnote 30] The appropriation funds all 
training and administration costs related to reservists. When 
reservists are activated for duty, the Coast Guard's financial 
accounts used to fund active duty personnel activities are used by 
requesting commands to fund reservist costs, according to Coast Guard 
officials. As of March 2013, the Coast Guard was operating under the 
continuing resolution for funding across the federal government. 
[Footnote 31] 

Reservist Definitions and Organizational Structure: 

According to Coast Guard policy documentation, the reserve force is to 
be always ready to mobilize with competencies in boat operations, 
disaster planning and response, expeditionary warfare, marine safety, 
port security, and law enforcement. Coast Guard officials stated that 
reservists respond to coastal disasters as well as to emergencies on 
the Great Lakes and in the Midwest. For example, after Hurricane 
Sandy, in October 2012, 157 reservists were deployed to assist in the 
response. The Coast Guard, including reservists, deployed to areas 
throughout New York and New Jersey with environmental threats caused 
by the hurricane, according to FEMA documentation of agency roles 
during the response. Coast Guard responders, including reservists, 
assessed affected areas and environmentally sensitive areas for 
pollution and hazardous materials. The assessments were to be used to 
appropriately respond to identified areas of pollution for cleanup. 
Figure 7 shows Coast Guard reservist locations throughout the United 
States. 

Figure 7: Coast Guard Locations and Number of Reservist Positions 
Assigned, as of October 2012: 

[Refer to PDF for image: illustrated U.S. map] 

District 1: 976 reservists; 
District 5: 833 reservists; 
Atlantic area: 148 reservists; 
District 7: 920 reservists; 
District 8: 988 reservists; 
District 9: 549 reservists; 
District 11: 547 reservists; 
Pacific area: 51 reservists; 
District 13: 437 reservists; 
District 14: 115 reservists; 
District 17: 56 reservists; 
Washington, D.C. area units: 
* Commandant of the Coast Guard: 207 reservists; 
* Deputy Commandant for Mission Support (DCMS): 752 reservists; 
[DCMS headquarters are in Washington, D.C., with elements stationed 
nationwide]; 
* Deployable Operations Group (DOG): 1,525 reservists; 
[DOG headquarters are in Arlington, VA, with Port Security Units 
stations nationwide]. 

Source: USCG; Map Resources (map). 

Note: According to Coast Guard officials, reservists are assigned to 
Coast Guard locations but may be deployed to respond to disasters 
worldwide. The officials also stated that Coast Guard districts have 
merged over time, resulting in the elimination of some district 
numbers. 

[End of figure] 

Hiring Process and Pay: 

Hiring process. Federal enlistment regulations for the armed forces 
govern Coast Guard hiring of the selected reserve. Coast Guard 
requires the qualifications listed in figure 8. 

Figure 8: U.S. Coast Guard Recruit Qualifications: 

[Refer to PDF for image: illustrated table] 

Citizenship: U.S. citizen or resident alien; 

Age: Active duty: 17 with parental consent to 27 years old (up to 32 
if attending a Coast Guard specialty school); 
Education: Must have a high school diploma GEDs are accepted in very 
rare cases; 
Family: Maximum of two dependents; 
Background: Credit check; Security clearance check; Criminal record 
review. 

Age: Reserve: 17-39 years old
Education: Minimum score of 45 on the Armed Services Vocational 
Aptitude Battery test of qualifications for military service; 
Background: Second or third degree misdemeanor and felony convictions 
are disqualifying. 

Source: USCG. 

[End of figure] 

According to Coast Guard officials, for certain positions or skill 
sets, the Reserve program hires a mix of personnel with prior service, 
who already have been tested and trained, as well as new recruits 
without such skill sets. The Coast Guard also recruits first 
responders, such as police officers, according to officials. The Coast 
Guard does not advertise for vacant positions, but instead conducts 
general military advertising through local recruiting offices for both 
active duty and reserve personnel. 

Reserve candidates take the Armed Services Vocational Aptitude Battery 
(ASVAB) test at a Coast Guard recruiting office. If a potential 
recruit receives a qualifying score on the ASVAB, the recruit 
completes a hiring package that includes information for a background 
check, criminal history, and financial history. The package is 
reviewed by the Coast Guard, and if the hiring package is approved, 
the recruit is to be assigned a job specialty and position, which is 
determined by a combination of the ASVAB results, individual 
preference, and the needs of the Coast Guard. There are three 
categories of recruits: (1) New Accessions (no prior military 
service), (2) Released from Active Duty, and (3) Direct Entry Program 
(new to the Coast Guard but have specialized expertise). The hiring 
process takes 4 to 6 months. The Coast Guard recruits approximately 
1,000 people per year to maintain its desired reservist staffing 
levels, according to Coast Guard officials. Coast Guard officials 
determine the number of recruits required each year based on the 
forecasted reservist attrition rate, which includes factors such as 
separations, retirements, and integrations to active duty. Active duty 
and reservist personnel commit to serving for 8-year-long periods, 
which can be a combination of active and reserve duty. 

Pay. With respect to pay structure, the different duty statuses 
determine pay. For example, during active duty for training (2 weeks 
per year), a reservist is provided the same pay as active duty 
personnel and may receive a similar allowance, according to Coast 
Guard officials. During inactive duty (2 days per month), the pay 
scale for reserve pay is used. Pay is also based on the reservist's 
military rank, years of service, and status as an officer or enlisted 
member. 

Deployment: 

Deployment of Coast Guard reservists is governed by U.S. statute. 
Deployment scenarios are listed in figure 9, including deployments 
that may be ordered with and without the consent of reservists, which 
include overseas deployments. 

Figure 9: Coast Guard Reservist Activation Legal Framework: 

[Refer to PDF for image: table] 

Activation with reservist consent: 
At any time, with the consent of that reservist.[A] 

Activation without reservist consent: 
In time of war or of national emergency declared by Congress, or when 
otherwise authorized by law, for the duration of the war or emergency 
and for 6 months thereafter;[B] 
In time of national emergency declared by the President for not more 
than 24 consecutive months;[C] 
When the President determines that it is necessary to augment the 
active forces for any named operational mission or to provide 
assistance in responding to an emergency involving the use or 
threatened use of a weapon of mass destruction or a terrorist attack 
or threatened terrorist attack in the United States that results, or 
could result, in significant loss of life or property, for not more 
than 365 consecutive days;[D] 
To aid in the prevention of an imminent, serious natural or man made 
disaster, accident, catastrophe, act of terrorism, or transportation 
security incident, for not more than 60 days in any 4-month period and 
not more than 120 days in any 2-year period.[E] 

Source: U.S. Code. 

[A] 10 U.S.C. § 12301(d). 

[B] 10 U.S.C. § 12301(a). 

[C] 10 U.S.C. § 12302. 

[D] 10 U.S.C. § 12304. 

[E] 14 U.S.C. § 712. 

[End of figure] 

The Coast Guard's Mobilization Readiness Tracking Tool (MRTT) is used 
to determine who is available for mobilization within needed skill 
sets, according to Coast Guard officials. The Coast Guard area 
commands enter requirements into MRTT based on the skill sets, 
military occupational specialties, and required pay grades needed for 
the disaster response. Reservists may apply to fulfill a requirement 
or the operational commander may involuntarily recall a reservist 
based on the reservist's skill set and the recall authority relied 
upon for the disaster response, according to Coast Guard officials. 

Reservist activation decisions for deploying to disasters are executed 
by the Coast Guard Pacific or Atlantic area commands. If reservists 
must be involuntarily deployed for domestic response, both the 
Commandant of the Coast Guard and the Secretary of Homeland Security 
must approve the activation. Reservists have up to 48 hours from the 
time of activation notification to report for duty, according to Coast 
Guard officials. 

Small Business Administration's Office of Disaster Assistance: 

Mission: 

The Small Business Administration's (SBA) Office of Disaster 
Assistance's (ODA) mission is to provide low-interest disaster loans 
to homeowners, renters, and businesses of all sizes. This mission also 
includes providing loans to private and nonprofit organizations. 
Disaster victims may use these loans to repair or replace real estate, 
personal property, machinery; equipment, inventory, and business 
assets that have been damaged or destroyed in a declared disaster. 
SBA's disaster loans are the primary form of federal assistance for 
the repair and rebuilding of nonfarm, private sector disaster losses, 
particularly those not covered by insurance. Specifically, SBA 
provides disaster assistance through its Disaster Loan Program (DLP) 
to help recovery efforts after disasters, such as earthquakes, 
hurricanes, floods, and terrorist attacks. In addition to its disaster 
loan program, SBA helps small businesses recover from disasters 
through technical assistance and procurement programs. As of March 31, 
2012, SBA had approved more than 1.9 million loans, for over $50 
billion, since its inception in 1953. 

SBA provides financial assistance for non-insured losses in the form 
of Home Disaster Loans to homeowners or renters to repair or replace 
disaster-damaged real estate or personal property owned by the 
victims.[Footnote 32] Renters are eligible for their personal property 
losses, including automobiles. Business Physical Disaster Loans are 
also made available to qualified businesses to repair or replace 
disaster-damaged property owned by the business, including real 
estate, inventories, supplies, machinery, and equipment. Businesses of 
any size are eligible. Private nonprofit organizations such as 
charities, churches, and private universities, are also eligible. 
Additionally, SBA's Economic Injury Disaster Loans provide working 
capital loans for a variety of small businesses to help meet their 
ordinary and necessary financial obligations that cannot be met as a 
direct result of a disaster. These loans are intended to assist 
through the disaster recovery period. 

SBA's reservists are hired and deployed to accommodate the anticipated 
workload of declared disasters. The size of a disaster affects the 
number of loan requests SBA receives, and consequently the resources 
SBA must activate to serve its customers. Upon declaration of a 
disaster, SBA assesses its need to deploy or activate reservists to 
help with recovery. ODA maintains reserve lists to keep a running 
count of employees that are available to report back to work when 
called upon. As an event unfolds, ODA expands office space and calls 
on staff and reservists to meet the anticipated workload. 

Funding: 

Costs for ODA travel and per diem for Just-in-Time training for 
reservists was $4,088,165 in fiscal year 2012. 

Reservist Definitions and Organizational Structure: 

ODA reservist personnel available for duty totaled 3,049 as of 
December 2012. Reserve employees are either selected through 
competitive procedures to term intermittent appointments or hired 
directly outside of the competitive placement process as Schedule A 
appointees.[Footnote 33] Additionally, management has identified 
certain former ODA employees as resources to call back to service for 
response to large-scale events, according to ODA officials. Table 2 
identifies SBA reservist categories we evaluated for this report. 

Table 2: SBA's Office of Disaster Assistance Reserve Categories: 

Reserve category: Term intermittent (surge); 
Description: Term Intermittent employees are surge staff 
who are called upon to respond to disaster activity when the core group 
of permanent, cadre[A] and term seasonal[B] staff have all been 
exhausted. Term intermittent staff compete for employment for a period 
of more than 1 year and not to exceed 4 years. Term intermittent 
employees are typically used when: 
* work is sporadic, unpredictable and cannot be regularly scheduled in 
advance and; 
* there is a drastic increase in disaster activity; 
Number of reservists, as of December 2012: 1,730. 

Reserve category: Surge plus; 
Description: Surge plus employees are called when all permanent, cadre, 
term seasonal, and term intermittent staff have been exhausted. These 
individuals are Schedule A employees who are hired without competing 
for employment; 
Number of reservists, as of December 2012: 1,319. 

Source: GAO analysis of SBA data. 

Notes: For the purposes of this report, we did not compare term 
seasonal employees with FEMA reservists because of the nature of their 
appointments. Employment for term seasonal employees is expected to 
last at least 6 months and is less sporadic than for FEMA reservists. 

[A] Cadre employees are full-time equivalent employees on a seasonal 
schedule. 

[B] Term seasonal employees compete for employment and are appointed 
for more than 1 year and not to exceed 4 years. 

[End of table] 

The ODA organizational structure and assets are functionally based and 
geographically dispersed, minimizing reliance on a single region, 
according to ODA staffing strategy documentation. See figure 10 for 
location of ODA field office centers. While there are additional 
offices within SBA that support disasters, the primary offices that 
support a disaster response are as follows: 

* ODA headquarters at SBA's central office in Washington, D.C. 

* The Customer Service Center (CSC), located in Buffalo, New York. 
Disaster victims contact this center when they have questions about 
their loan applications. Services for disaster victims include a call 
center, e-mail response, disaster application mailing capabilities, 
and preapplication data entry assistance, and the center provides 
services to the other centers as needed. 

* Two disaster Field Operations Centers (FOC): FOC-E (East) is located 
in Atlanta, Georgia, and FOC-W (West) is located in Sacramento, 
California. The two FOCs are responsible for the coordination of 
preliminary damage assessments, field operations, and information 
dissemination. 

* A centralized loan Processing and Disbursement Center (PDC) located 
in Fort Worth, Texas. The PDC mails out and receives applications, 
evaluates them, and disburses funds to eligible borrowers. 

* The Office of Disaster Personnel (ODP) provides human resource 
support, the Administrative Services Center (ASC) provides 
administrative support, the Office of Disaster Strategic Engagement 
and Effectiveness (ODSEE) provides employee relations, training, and 
development support, the Disaster Credit Management Systems (DCMS) 
Operations Center oversees the DCMS system, and the Damage 
Verification Center (DVC) provides the loss verification/inspection 
function. All of these units are located in Herndon, Virginia. 

Figure 10: Office of Disaster Assistance Field Office Center Locations: 

[Refer to PDF for image: illustrated U.S. map] 

Atlanta: Field Operations Center-East; 

Buffalo: Customer Service Center; 

Dallas/Fort Worth: Loan Processing and Disbursement Center; 

Sacramento: Field Operations Center-West; 

Washington, D.C.: Office of Disaster headquarters; 

Herndon, Virginia: Disaster Credit Management System Operations 
Center; Administrative Support Center; Office of strategic Engagement 
and Effectiveness; Damage Verification Center. 

Source: SBA; Map Resources (map). 

[End of figure] 

Hiring Process and Pay: 

Hiring process. Center directors are instructed to submit a reservist 
staffing request to ODA headquarters. If the request is approved, then 
the Office of Disaster Personnel manages the hiring process for each 
center. The vast majority of ODA's hiring processes for reservists 
follow Office of Personnel Management's (OPM) guidance--which is 
closely associated with the position descriptions (PD) for each of its 
employee types. Prior to posting a reservist job announcement, ODA's 
Office of Disaster Personnel performs a job analysis and uses an 
assessment tool to determine the specific functions performed under 
the job title it plans to fill. Additionally, it gathers information 
from in-house subject matter experts (SME)--usually staff who work 
with human resources staff to provide additional background 
information for the position description. ODA also uses OPM 
qualification standards to help determine the experience requirements 
related to the job title. ODA posts all job openings on the USA Jobs 
web site, but during a major disaster, employs various other methods, 
including advertising locally, to get the largest pool of applicants 
as possible. Once the announcement closes, both the SMEs and human 
resources staff review applications to determine which applicants are 
best qualified. Applicants deemed qualified are asked to complete a 
self-assessment that rates the applicant's experience using a 
numerical value. According to ODA officials, this process also follows 
OPM's standards and helps determine which applicants are best 
qualified, well qualified, or qualified. 

ODA does not use face-to-face interviews with reservists, which is a 
departure from how permanent staff are hired. Once reservists are 
brought on board, SBA uses their introductory training period (between 
1 and 3 weeks) to help determine who is qualified to be a reservist in 
its program. SBA's goal is to cast a wide net in order to have a large 
enough pool of reservists. Hiring is done year round, but the agency 
may increase the number of job announcements it publishes based on an 
increase in disaster activity. All hiring decision making and 
processing are done centrally in ODA's Herndon, Virginia location. 

Figure 11 outlines how SBA determines the appropriate staffing levels 
and skills required for specific disasters and more details are 
presented below. 

Figure 11: Small Business Administration (SBA) Reservist Staffing 
Level Determination: 

[Refer to PDF for image: process illustration] 

Assess application volume; 
Validate staffing levels; 
Determine unique disaster characteristics; 
Identify resources in surge or surge plus; 
In process/hire surge staff. 

Source: SBA. 

[End of figure] 

* Assess application volume. When deemed necessary, the ODA 
Scalability Model is to be executed to validate the staffing needs. 
[Footnote 34] 

* Validate staffing levels. When appropriate, upon receiving the 
results from the Scalability Model, as well as other disaster 
information, centers are to review and identify the predetermined 
staffing levels to ensure that they have the staff needed to respond. 

* Determine the unique disaster characteristics. In addition to 
validating that their current staffing levels are adequate to respond 
to the disaster, centers are also to make sure that their available 
staff have requisite skill sets needed to meet the needs of the 
disaster. 

* Identify resources in surge or surge plus pool. Once the resource 
requirements are identified, the centers, along with the Office of 
Disaster Personnel, are to identify staff with the requisite skills 
within the surge or surge plus pools if these skills are not available 
within the core staff. 

* In process/hire surge staff. According to the application/workload 
analysis to determine the appropriate staffing action, if it is 
determined that SBA's field centers require resources from the surge 
or surge plus pools, the centers, in coordination with ODP, are to 
either place staff in pay status, hire staff, or execute a contract 
based on the needs for responding to the disaster. 

Pay. According to SBA officials, the agency's reservist pay rates are 
aligned with OPM's General Schedule (GS) and range from GS-5 to GS-12. 
Reservist pay grade and rate of pay are determined using the same set 
of OPM guidelines as for other classes of employees, which includes 
meeting certain qualification requirements in accordance with OPM's 
Qualification Standards. With the exception of those reservists who 
are Fair Labor Standards Act (FLSA) exempt, SBA's reservists are 
eligible for overtime, which is offered at a rate of 1.5 times an 
individual's hourly regular rate of pay. SBA uses OPM guidelines and 
policies to determine if reservists are eligible for pay raises, 
including within-grade increases and promotions. SBA's term 
intermittent employees are not authorized benefits unless they were 
enrolled in benefits in a federal appointment immediately preceding 
the term intermittent appointment. 

Deployment Practices: 

SBA categorizes disasters into levels based on estimates of the number 
of anticipated applications. This categorization enables SBA to 
determine an appropriate surge level for scaling resources and 
operations to meet the needs of disaster victims. Figure 12 provides 
an overview of the surge process. 

Figure 12: Overview of SBA Surge Process: 

[Refer to PDF for image: process illustration] 

Core capability: 

Level I: Up to 100,000 applications; 
Leverage current Office of Disaster Assistance (ODA) staff; 
Call up reserves, as necessary; 
Engage Small Business Development Centers, Service Corps of Retired 
Executives, and Women’s Business Centers in local outreach. 
Level II: 100,000 to 250,000 applications; 
Level I plus: Cross-train existing ODA personnel, as necessary. 

Surge capability: 

Level III: 250,000 to 500,000 applications; 
Level II plus: Loan-processing staff move to double shift approach; 
Begin to hire new personnel; Overflow to Sacramento, CA, as necessary; 
Activate Disaster Oversight Council. 

Level IV: Over 500,000 applications; 
Level III plus: Utilize district and program offices; Procure space 
through General Services Administration, as necessary. 

Source: SBA. 

Note: Small Business Development Centers (SBDC) are made up of a 
unique collaboration of SBA, state and local governments, and private 
sector funding resources that are to work together to provide an array 
of technical assistance to small businesses and aspiring 
entrepreneurs. Service Corps of Retired Executives Association is a 
nonprofit association supported by SBA that is dedicated to helping 
small businesses achieve their goals through education and mentorship. 
Women's Business Centers is a national network of nearly 100 
educational centers designed to provide entrepreneurs (especially 
women who are economically or socially disadvantaged) comprehensive 
training and counseling on a variety of topics to help them start and 
grow their own businesses. 

[End of figure] 

Forest Service Fire and Aviation Management: 

Mission: 

The Fire and Aviation Management (FAM) unit within the U.S. Department 
of Agriculture's Forest Service is charged with fire prevention, fire 
suppression, and using prescribed fires to support environmental 
resource and social objectives. As part of its mission, FAM protects 
life, property, and natural resources on 193 million acres of national 
forest system land and 20 million acres of adjacent state and private 
property. In addition to wildland fire management, FAM has 
increasingly been tasked with responding to nonfire national 
emergencies like Hurricane Katrina. FAM does not have a formal reserve 
program, and it operates under legal authorities that govern all 
temporary federal employees, which we discuss later in the hiring and 
pay section of this enclosure. 

Funding: 

FAM analyzes historical trends and drought conditions to estimate 
firefighting capability requirements for each year. This planning is 
used to support funding requests for firefighting resources that fall 
into two categories: pre-suppression and suppression. Pre-Suppression 
funds, used to secure and train fire fighting assets, and support the 
prevention and the state and volunteer fire assistance programs, are 
allocated at the beginning of the fiscal year, while suppression 
funds, used to fight fires, are allocated during suppression 
activities. If depletion of suppression funds occurs as a result of 
support of regional and or national wildfires, the agency has the 
ability to leverage funding from other Forest Service programs to meet 
the funding need. 

Wildland fire management represents a growing portion of the Forest 
Service's program activities, increasing from 13 percent of its total 
budget in 1991 to about 50 percent in 2009. In fiscal year 2012, the 
total Wildland Fire Management appropriations--including both the 
regular Wildland Fire Management appropriations, as well as the FLAME 
Wildfire Suppression Reserve Fund--was $2 billion.[Footnote 35] 

Reservist Definitions and Organizational Structure: 

The FAM workforce organizational structure is three-tiered, made up of 
firefighters from local, state, and federal governments. Given the 
unpredictable nature of fires, FAM utilizes established federal and 
state cooperative agreements to enable it to surge beyond annual 
firefighting capability projections by using local, state, and federal 
firefighting personnel. Command and control for FAM fire suppression 
operations is also decentralized, with locations in national forests, 
for example, to cope with the unpredictable nature of fires. 

As previously mentioned, unlike the Coast Guard and FEMA, FAM does not 
have a traditional reserve program. All FAM employees who are deployed 
to fight a fire, including full-time and part-time employees, must 
abide by the same basic training requirements. See table 3 for a full 
description of the two employee reserve types, and figure 13 for the 
location of operating centers that utilize FAM reservists, as well as 
the number of reservists assigned to these centers as of December 2012. 

Table 3: Fire and Aviation Management (FAM) Reserve Categories: 

Reserve Category: Temporary/"1039" employees; 
Description: A temporary appointment is appropriate for work that is 
expected to last no more than 1 year. Temporary appointments can also 
be used for seasonal work that is needed every year when the work 
requires less than 1,040 hours of duty, excluding overtime and 
eligible training each year. Temporary employees with a seasonal 
schedule, that is, "temporary seasonal," have annually recurring work 
that is expected to last less than 6 months (less than 1,040 hours) 
each year. This time limitation can be exceeded for training purposes 
up to 120 days in the first year of the appointment and up to 80 hours 
each subsequent year; 
Number of reservists, as of November 2012: 3,725. 

Reserve Category: Administratively determined (AD)/"casuals"/emergency 
firefighters; 
Description: An individual who is not a regular agency employee and is 
hired for temporary emergency (nonrecurring) service under the AD Pay 
Plan and procedures. Once the emergency has ended, the individual's 
employment is terminated; 
Number of reservists, as of November 2012: 6,273. 

Source: GAO analysis of FAM data. 

Note: For the purposes of this report, permanent seasonal employees 
were not compared with FEMA reservists because they are permanent, 
career employees. 

[A] See 5 C.F.R. § 316.401. 

[End of table] 

According to FAM officials, the annual cost to support and train 
reservists (temporary and administratively determined) is difficult to 
estimate because reservist training is conducted simultaneously with 
training for permanent employees and does not require additional 
funds. Further, this cost is minimal because, according to FAM 
officials, there are only two training requirements for FAM 
reservists. When first hired, reservists are required to take a 1-week 
basic firefighting training, typically offered at a local fire 
station. Subsequently, reservists are to attend a 1-day fire refresher 
training annually. This refresher training is already scheduled for 
regular/permanent employees and involves no additional training cost, 
such as for a hired instructor, or travel costs, if offered in an area 
in which reservists are located. 

Figure 13: Number of Temporary and Administratively Determined 
Employees at Fire and Aviation Management (FAM) Operating Centers, as 
of December 2012: 

[Refer to PDF for image: illustrated U.S. map] 

Region 1: 
Temp: 597; 
AD: 295. 

Region 2: 
Temp: 302; 
AD: 234. 

Region 3: 
Temp: 653; 
AD: 944. 

Region 4: 
Temp: 535; 
AD: 442. 

Region 5: 
Temp: 717; 
AD: 1,625. 

Region 6: 
Temp: 719; 
AD: 792. 

Region 8: 
Temp: 24; 
AD: 1,064. 

Region 9: 
Temp: 178; 
AD: 870. 

Region 10: 
Temp: 0; 
AD: 7. 

Source: USDA, FAM, Map Resources (map). 

[End of figure] 

Hiring Process and Pay: 

Hiring. As temporary employees, FAM reservists are hired in accordance 
with OPM regulations that authorize federal temporary employment 
programs in the excepted and competitive service.[Footnote 36] The 
specific applicable qualification requirements for these temporary 
appointments focus on the applicant's ability to demonstrate that he 
or she can successfully perform the duties of the position. FAM 
utilizes detailed position descriptions to hire temporary employees. 
However, the ultimate responsibility lies with the applicant to 
provide enough information during the application process so a 
qualification determination can be made. ADs are hired by the local 
FAM unit in the event of an emergency and sent to where there is a 
need. Such hiring is of uncertain or temporary duration and must be 
terminated when other employment methods can be initiated, such as the 
hiring of temporary or seasonal employees to replace the ADs. 

Pay. FAM temporary employee pay rates are aligned with the federal 
General Schedule and depend on the employee's position. Employees are 
paid overtime at a rate of 1.5 times their normal salary. Depending on 
the severity of the fire, employees may be offered additional hazard 
pay or Sunday and night pay. AD salaries are not aligned with the 
General Schedule. These reservists are paid under the provisions of 
the AD pay plan in effect at the time of hire. This pay plan applies 
when it becomes necessary to hire persons to: 

* cope with a sudden and unexpected emergency caused by a fire, or 
extreme fire potential, flood, storm, or any other all-hazard 
emergency, and: 

* provide emergency assistance to states under formalized agreements, 
and meet mission assignments issued by FEMA. 

Deployment Practices: 

FAM has a mobilization process in place for deployments that, 
according to FAM officials, endeavors to use the regular employed 
personnel that are available for incidents first before using the ADs 
to supplement the work-force. The local FAM unit or team at the fire 
determines the resources needed to fight the fire and places a request 
for reservists in FAM's Resource Order Status System (ROSS). FAM does 
not deploy specific individuals; instead, requests entered into ROSS 
specify certain qualifications needed to respond to the fire. As shown 
in figure 14, employees are required to update their availability for 
a fire assignment in ROSS, being sure to check with their supervisors 
to make sure they can actually take the time off to help fight the 
fire. These employees are then deployed through a dispatch system. 
Depending on the type of disaster, requests for specific types of 
positions are submitted to the dispatch system, which sorts through 
all of the employees that have made themselves available to find a 
match based on the characteristics of the request and the employees' 
credentials. 

Figure 14: Fire and Aviation Management (FAM) Deployment Process: 

[Refer to PDF for image: process illustration] 

Employees record firefighting training and qualifications in the 
Incident Qualification and Certification System (IQCS); 

Employees update their availability for a fire assignment in the 
Resource Order Status System (ROSS); 

Requests for firefighters are submitted to ROSS, which sorts through 
list of available employees to find a match based on characteristics of 
request and employees’ credentials; 

Using ROSS, employees are then deployed depending on the type of 
disaster. 

Source: U.S. Forest Service. 

Note: Fires are distinguished by Type (Type I through Type V). Each 
type of fire requires a different skill set or firefighters who are 
increasingly more qualified to work more dangerous fires. Type I fires 
are significantly more complex than Type V. 

[End of figure] 

The local dispatch office is to check ROSS for availability of 
qualified personnel locally and order regular employees before 
ordering an AD. FAM attempts to utilize the "closest forces" concept 
to save costs on mobilization of resources. If no one with the desired 
qualifications is available locally, the request is elevated to the 
Geographic Area Coordination Center. If the request cannot be filled 
there, it is then elevated to the National Interagency Coordination 
Center. Individuals can be dispatched either locally or nationally, or 
both. FAM attempts to fulfill requests and make decisions at the local 
level, unless the local level does not have the desired resources. 
Also, FAM attempts to deploy on a rotational basis; however, if there 
is an employee who needs training or additional experience, FAM is to 
try to deploy the employee to the fire. ROSS does not identify whether 
an individual's task book (used by the Forest Service to track on-the-
job experience after getting basic training) is about to expire or how 
many assignments a person has had.[Footnote 37] This information is 
all locally managed. Once employees are deployed, they have to remove 
themselves from ROSS to prevent being called again. Typical 
deployments are for 14-day periods. 

Enclosure II: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20528: 

March 8, 2013: 

Stephen L. Caldwell: 
Director, Homeland Security and Justice: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Re: Draft Report GAO-13-250R, "FEMA Reservists: Training Could Benefit 
from Examination of Practices at Other Agencies" 

Dear Mr. Caldwell: 

Thank you for the opportunity to review and comment on this draft 
report. The U.S. Department of Homeland Security appreciates the U.S. 
Government Accountability Office's (GAO's) work in planning and 
conducting its review and issuing this report. 

The Department is pleased to note GAO's acknowledgment of progress 
made by the Federal Emergency Management Agency (FEMA) to address 
weaknesses in its Reservist Training Program. The information and 
analysis provided in this report will help FEMA further strengthen the 
training of its Reservist workforce. 

The draft report contained one recommendation, with which the 
Department concurs. Specifically, GAO recommended that the FEMA 
Administrator: 

Recommendation: Examine the training practices of other agencies with 
disaster reservist workforces to identify potentially useful practices. 

Response: Concur. The FEMA Response Incident Workforce Management 
Office (IWMO) agrees that valuable insight may be gained by assessing 
training programs and support systems of other agencies that maintain 
a similar reservist workforce. For example, developing and 
implementing the FEMA Qualification System (FQS) to track 
qualifications and courses needed for specific reservist job 
categories, we employed the services and expertise of various external 
organizations to create and expand the training and certification of 
our reservist workforce. These partnerships proved useful in 
developing the current FQS, and we look forward to continuing to 
expand our reservist training program through the examination and 
possible application of best practices from other federal agencies 
with similar workforces. 

Moving forward, the IWMO program staff will work to coordinate with 
other organizations and agencies to address this recommendation and 
will prepare a detailed corrective action plan within 60 calendar days 
upon receipt of GAO's final report. As our corrective action plan has 
not yet been developed, the estimated completion date for fully 
responding to this recommendation is: To Be Determined. 

Again, thank you for the opportunity to review and comment on this 
draft report. Technical comments were previously provided under 
separate cover. Please feel free to contact me if you have any 
questions. We look forward to working with you in the future. 

Sincerely, 

Signed by: 

Jim H. Crumpacker: 
Director: 
Departmental GAO-OIG Liaison Office: 

[End of section] 

Enclosure III: Comments from the United States Department of 
Agriculture: 

United States Department of Agriculture: 
Forest Service: 
Washington Office: 
I400 Independence Avenue, SW: 
Washington, DC 20250: 

File Code: 1420: 
Date: March 8, 2013: 

Mr. Stephen L. Caldwell: 
Director, Homeland Security and Justice: 
U.S. Government Accountability Office: 
441 G. Street, NW: 
Washington, DC 20548: 

Dear Mr. Caldwell: 

Thank you for the opportunity to comment on the draft report "FEMA 
Reservists: Training Could Benefit from Examination of Practices at 
Other Agencies" (GAO-13-250R). The report examines how FEMA's 
reservist workforce training compares with training of other similar 
agencies, and to what extent FEMA has examined these agencies training 
programs to identify useful practices. 

The Department of Agriculture generally agrees with GAO's findings and 
recommendation that FEMA examine the reservist training programs of 
other federal agencies. 

If you have any questions, please contact Thelma Strong, Chief 
Financial Officer, at (202) 205-1321 or tstrong@fs.fed.us. 

Sincerely, 

Signed by: 

Thomas L. Tidwell: 
Chief: 

[End of section] 

Footnotes: 

[1] This includes obligations for Individual Assistance, Public 
Assistance, and Hazard Mitigation, only for major disaster 
declarations declared from fiscal years 2007 through 2012. 

[2] GAO, Disaster Assistance Workforce: FEMA Could Enhance Human 
Capital Management and Training, [hyperlink, 
http://www.gao.gov/products/GAO-12-538] (Washington, D.C.: May 25, 
2012). 

[3] FQS establishes qualification and performance standards for FEMA's 
disaster workforce, including reservists. IQCS is the information 
system managed by the Bureau of Land Management (BLM), originally used 
to track training and certifications for wildland firefighters. BLM 
created a specific version of IQCS for FEMA to track reservist 
training and qualifications. These systems are intended to better 
track reservist training needs and costs, but other factors determine 
whether reservists have an opportunity to receive training, such as 
course availability. 

[4] GAO, Federal Emergency Management Agency: Workforce Planning and 
Training Could Be Enhanced by Incorporating Strategic Management 
Principles, [hyperlink, http://www.gao.gov/products/GAO-12-487] 
(Washington, D.C.: Apr. 26, 2012). 

[5] Other organizations considered were the Army Corps of Engineers, 
Centers for Disease Control and Prevention, Department of State 
(Civilian Corps), National Guard, Red Cross, U.S. Agency for 
International Development, and the World Health Organization. 

[6] Term intermittent staff are on SBA's payroll and are to be called 
upon to respond to disaster activity when the core group, such as 
permanent, full-time equivalent employees on a seasonal schedule 
(known as cadre employees), and term seasonal staff, have been 
exhausted. Schedule A staff are employees hired without competing for 
employment, when term intermittent staff have been exhausted. 

[7] Reserve program segments not considered in our comparison because 
the employees were not temporary or part-time and employed on an 
intermittent or on-call basis included: the Coast Guard individual 
ready and stand-by reserve and Forest Service permanent seasonal 
employees. SBA term seasonal employees were not considered in the 
comparison because they are employed on a full-time seasonal work 
schedule and their employment is expected to last at least 6 months. 

[8] The evaluation we reviewed was preliminary. However, our review of 
the evaluation was limited to determining whether FEMA had examined 
other agencies' practices and not in assessing the evaluation itself. 
Therefore, we determined the evaluation to be sufficiently reliable 
for our purposes. 

[9] GAO, Human Capital: A Guide for Assessing Strategic Training and 
Development Efforts in the Federal Government, [hyperlink, 
http://www.gao.gov/products/GAO-04-546G] (Washington, D.C.: Mar. 1, 
2004). 

[10] For the purposes of this report, when referring to the Forest 
Service reservists we are specifically referring to the Forest 
Service's firefighting reservists managed by FAM. 

[11] [hyperlink, http://www.gao.gov/products/GAO-04-546G]. 

[12] The Forest Service also offers intermediate-level courses, which 
it distinguishes from advanced-level courses. FEMA offers refresher 
training, but it is not required of reservists. 

[13] Joint field offices are locations where federal, state, and local 
officials convene to administer their respective disaster assistance 
programs. 

[14] No-year funds are available for obligation for an indefinite 
period of time. 

[15] The Emergency Management Institute's mission is to train 
officials in emergency management at all levels of government to 
prepare for, protect against, respond to, recover from, and mitigate 
the potential effects of all types of disasters and emergencies. 

[16] 10 U.S.C. § 10147 and Department of Defense Instruction 1215.06, 
section 6.1.4.1.2. 

[17] The Kirkpatrick Model, developed by educational theorist Donald 
Kirkpatrick, employs four levels of evaluating training effectiveness. 
Level 1, reaction, gathers "reactive feedback" from the trainees by 
asking them to express their satisfaction with the training, the 
quality of the instructors, the content, training material, and the 
learning environment; Level 2, learning, assesses learners' mastery of 
the training immediately after completing the course, while Level 3, 
behavior, determines whether the training has prepared trainees to 
perform various tasks and duties while on the job. Level 4, results, 
measures results of training that contribute to the overall 
organization and is normally reported as a return on investment. 

[18] During disaster responses, both FEMA and SBA reservists may 
interact with disaster victims seeking federal assistance. 

[19] [hyperlink, http://www.gao.gov/products/GAO-04-546G]. 

[20] 6 U.S.C. § 320. 

[21] According to FEMA officials, FQS is a performance-based system 
whereby employees are determined to be either in trainee or qualified 
status in one of 322 jobs, each of which has a related position task 
book. Position task books outline required activities, tasks, and 
behaviors, and serve as a record for task completion. 

[22] FEMA, FEMA Reservist Program. FD 010-6 Revision Number: 01. June 
14, 2012. 

[23] 6 U.S.C. § 313(b)(2)(C). Fiscal year 2012 funding for FEMA's 
reservist program totaled $2,644,700. 

[24] 42 U.S.C. § 5149(b)(1). 

[25] According to FEMA officials, FEMA's force structure analysis will 
not be available until the second quarter of fiscal year 2013. 

[26] In November 2012, the U.S. Office of Personnel Management (OPM) 
granted FEMA reservists, and other intermittent federal employees 
engaged in emergency response and recovery work, eligibility for 
health benefits while they are in pay status. OPM stated the following 
in its notice of the new rule: In light of the need for agencies to 
attract and bring emergency workers on board quickly and in 
recognition of the hazardous conditions those employees often face, 
OPM has concluded that its current policy of categorically excluding 
intermittent employees from Federal Employee Health Benefit Program 
(FEHBP) coverage is no longer in the public interest and should be 
changed. Therefore, OPM is issuing this interim regulation to allow 
agencies to request FEHBP coverage for intermittent employees engaged 
in emergency response and recovery work as defined by the Stafford 
Act. In addition, if OPM grants any such requests, it is reserving the 
authority to limit FEHBP coverage for intermittent employees to the 
periods during which they are in a pay status. This would promote 
parity between intermittent employees and temporary employees like the 
wildland firefighters, who receive FEHBP coverage when called up for 
duty. It would also allow OPM the discretion to craft an appropriate 
approach to health insurance coverage based on the potentially diverse 
work schedules of intermittent employees. 

[27] 10 U.S.C. § 10102. 

[28] 10 U.S.C. § 10101. 

[29] 14 U.S.C. § 704. 

[30] Pub. L. No. 112-74, 125 Stat. 786, 953 (2011). 

[31] Pub. L. No. 112-175, 126 Stat. 1313 (2012). 

[32] SBA can make loans to eligible victims of declared disasters as 
defined by the Small Business Act. Section 7 of the Small Business 
Act, as amended, authorizes SBA's Physical Disaster and Economic 
Injury Loan Programs. 15 U.S.C. § 636. 

[33] Schedule A appointees may be used to fill special jobs and unique 
circumstances such as short-term, critical hiring situations where the 
use of standard qualification requirements and rating practices 
required during traditional competitive procedures are impractical. 

[34] According to SBA's Disaster Preparedness and Recovery Plan, SBA 
has a system in place that employs risk modeling to scale its existing 
operations to effectively respond to disasters that require varying 
levels of support. This scalability model covers five functional 
components: human capital, infrastructure, partnerships, and 
technology, and communications ensuring appropriate responses in each. 
Each component can scale, separately or in concert with the others, 
according to the surge that is required to meet various levels of 
disaster. 

[35] Pub. L. No. 112-74, 125 Stat. 786, 1022-24 (2011). The FLAME 
Wildfire Suppression Reserve Fund is an appropriation providing funds 
to cover fires that are sufficiently large and complex or when the 
Suppression account is expected to be completely obligated. It is 
intended to address the impacts of increasing wildfire suppression 
costs and their effects on other agency programs. 

[36] See 5 C.F.R. pt. 316, § 213.104. 

[37] Position task books (PTB) identify all critical tasks required to 
perform the job for most standard incident management and prescribed 
fire positions. PTB responsibilities are contained within the Wildland 
Fire Qualifications Systems Guide, PMS 310-1. A PTB must be completed 
within 3 years from the time the first task is evaluated. 

[End of section] 

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