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entitled 'Human Capital: Opportunities to Improve Federal Continuity 
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Report to the Chairman, Subcommittee on Oversight of Government 
Management, the Federal Workforce, and the District of Columbia, 
Committee on Governmental Affairs, U.S. Senate:

April 2004:

HUMAN CAPITAL:

Opportunities to Improve Federal Continuity Planning Guidance:

GAO-04-384:

GAO Highlights:

Highlights of GAO-04-384, a report to the Chairman, Subcommittee on 
Oversight of Government Management, the Federal Workforce, and the 
District of Columbia, Committee on Governmental Affairs, U.S. Senate 

Why GAO Did This Study:

Federal agencies must have the capacity to serve the public during 
disruptions to normal operations. This depends, in part, on continuity 
efforts that help agencies marshal, manage, and maintain their most 
important asset—their people, or human capital. GAO identified the 
human capital considerations relevant to federal continuity efforts; 
described efforts by the Federal Emergency Management Agency (FEMA) and 
the Office of Personnel Management (OPM) to address these 
considerations relevant to continuity of operations (COOP); and 
described the role Federal Executive Boards (FEB) play in coordinating 
such efforts outside Washington, D.C.

What GAO Found:

According to recognized experts from the private and public sectors, 
continuity efforts should give priority to the immediate aftermath of 
a crisis—securing the safety of all employees and addressing the needs 
of employees who perform essential operations. However, experts noted 
that additional human capital considerations, especially those 
associated with the majority of an organization’s employees who would 
be needed to resume all other operations, are also crucial and have 
not been well developed by many public and private sector 
organizations. To more fully address human capital considerations, 
experts identified two human capital principles that should guide all 
continuity efforts—demonstrating sensitivity to individual employee 
needs and maximizing the contributions of all employees—and six key 
organizational actions designed to enhance continuity efforts.

Key Organizational Actions to Enhance Continuity Efforts:

Demonstrate top leadership commitment; 
* Instill an approach to continuity planning that includes human 
capital considerations.
* Allocate resources and set policies.
* Set direction and pace of recovery.

Seek opportunities for synergy; 
* Integrate continuity efforts with broader decision making.
* Consider how continuity investments benefit other program efforts.

Maintain effective communication; 
* Build relationships through two-way communication.
* Establish roles, responsibilities, and expectations.
* Develop redundant communication vehicles.

Target investments in training and development; 
* Raise awareness of continuity efforts.
* Build skills and competencies to increase flexibility.
* Foster a culture that values flexible employees who are empowered to 
make effective decisions.

Leverage the flexibility of human capital; 
* Enable employees associated with resumption activities to contribute 
to mission results in alternate assignments.
* Sustain the contribution of employees associated with essential 
operations.
* Maintain organizational knowledge of staffing requirements and 
availability.

Build process to identify and share lessons; 
* Create a learning environment.
* Make learning explicit and shared. 

Source: GAO.

[End of table]

FEMA and OPM have exhibited leadership in addressing human capital 
considerations relevant to COOP, but opportunities to improve exist. 
For example, while both agencies have issued guidance that addresses 
securing the safety of all employees and responding to the needs of 
personnel performing essential operations, neither agency’s guidance 
addresses human capital considerations related to resuming broader 
agency operations. 

Although not specifically tasked with coordinating emergency 
preparedness efforts, including COOP, FEBs are uniquely positioned to 
do so, given their general responsibility for improving coordination 
among federal activities in areas outside of Washington, D.C. While 
some FEBs already play an active role in coordinating such efforts, 
the current context in which FEBs operate, including the lack of a 
clearly defined role and varying capacities among FEBs, could lead to 
inconsistent levels of preparedness across the nation.

What GAO Recommends:

GAO recommends that FEMA and OPM more fully address human capital 
considerations in emergency preparedness guidance, including COOP, by 
incorporating key actions identified in this report. GAO also 
recommends that OPM clearly define the role FEBs play in improving 
emergency preparedness coordination and address any resulting capacity 
issues. FEMA agreed to implement our recommendations. OPM said its 
guidance already incorporates the key actions and highlighted its 
leadership role with respect to FEBs. GAO maintains that OPM has 
opportunities to address a fuller range of human capital 
considerations related to resuming broader agency operations and to 
clearly define the role of FEBs.

www.gao.gov/cgi-bin/getrpt?GAO-04-384.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact J. Christopher Mihm at 
202-512-6806 or mihmj@gao.gov.

[End of section]

Contents:

Letter: 

Results in Brief: 

Background: 

Human Capital Considerations Are Relevant to Continuity Planning and 
Implementation Efforts: 

FEMA and OPM Have Exhibited Leadership in Addressing Human Capital 
Considerations Relevant to COOP: 

FEBs Have Opportunities to Coordinate Regional Emergency Planning 
Efforts, Including COOP, in Major Metropolitan Areas: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendixes:

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Emergency Human Capital Flexibilities Listed in OPM 
Emergency Memorandums: 

Leave: 

Pay: 

Benefits: 

Telework: 

Emergency Hiring Flexibilities: 

Appendix III: Comments from the Federal Emergency Management Agency: 

Appendix IV: Comments from the Office of Personnel Management: 

Table: 

Table 1: Key Organizational Actions to Enhance Continuity Efforts: 

Figure: 

Figure 1: Six Organizational Actions to Enhance Continuity Efforts: 

Letter April 20, 2004:

The Honorable George V. Voinovich: 
Chairman, Subcommittee on Oversight of Government Management, the 
Federal Workforce, and the District of Columbia: 
Committee on Governmental Affairs: 
United States Senate:

Dear Mr. Chairman:

The events of September 11, 2001, vividly demonstrated how important it 
is, both symbolically and functionally, for federal government agencies 
to continue to serve the American public during any emergency or 
situation that may disrupt normal operations. Yet terrorist-related 
incidents are only one in a broad spectrum of emergencies that can 
disrupt an agency's normal operations. Agencies need a high level of 
preparedness to deal with the full range of emergencies, including man-
made disasters, whether intentional or not; acts of nature, such as 
hurricanes, earthquakes, or disease; and technological emergencies, 
including cyber-attacks or computer viruses.

Continuity of operations (COOP) efforts are a comprehensive set of 
steps agencies must undertake to help ensure that they can continuously 
provide essential operations and resume full services to the American 
public in the face of long-term, severe emergencies requiring agencies 
to occupy alternate facilities.[Footnote 1] This capacity to serve the 
public during any type of disruption to normal operations depends, in 
part, on the ability of federal agencies to marshal, manage, and 
maintain their most important asset--their people, or human capital. 
The planning efforts that help agencies build the capacity to 
effectively implement COOP may also help agencies more effectively 
implement basic emergency preparedness procedures in dealing with less 
severe disruptions to normal operations.

In response to your request that we identify the human capital 
considerations in COOP emergencies, this report (1) identifies the 
human capital considerations that are relevant to federal agencies' 
continuity planning and implementation efforts; (2) describes the COOP 
guidance provided by the Federal Emergency Management Agency 
(FEMA)[Footnote 2] and emergency preparedness guidance and activities 
of the Office of Personnel Management (OPM) to address human capital 
considerations relevant to COOP; and (3) describes the role Federal 
Executive Boards (FEB) play, relevant to COOP, in coordinating efforts 
outside the Washington, D.C., area.

To address human capital considerations that are relevant to continuity 
planning and implementation efforts, we reviewed relevant literature, 
such as industry journals, federal guidance, and codes of standards on 
disaster/emergency management and continuity programs. Because the 
available literature was limited in its attention to human capital, we 
conducted semistructured interviews and held a 1-day interactive 
working session with experts from the private sector, federal agencies, 
and other public sector organizations. With input from the National 
Academy of Public Administration, the Private Sector Council, and FEMA, 
the experts were selected based on their experience and knowledge of 
human capital or emergency management as it relates to continuity.

Individuals from a total of 15 organizations, in addition to FEMA, 
provided their expertise. The organizations included five federal 
agencies--the Centers for Disease Control and Prevention, the 
Department of Housing and Urban Development, the Department of Veterans 
Affairs, the General Services Administration, and the Social Security 
Administration; five private sector businesses--the Gillette Company, 
Lockheed Martin Corporation, Macy's West, Marsh & McLennan Companies, 
Inc., and Science Applications International Corporation; and five 
public institutions--the Business Continuity Institute, the Disaster 
Recovery Institute International, Emergency Management Alberta 
(Canada), Clark-Atlanta University, and the University of Tasmania 
(Australia). We supplemented the information from the expert panel by 
interviewing officials from OPM, representatives from FEBs, and 
representatives from federal employee unions.

To describe the COOP guidance issued by FEMA and the emergency 
preparedness guidance and activities of OPM, we interviewed officials 
from both agencies and analyzed relevant documents, including Federal 
Preparedness Circular (FPC) 65, which is the primary federal COOP 
guidance, and a series of emergency preparedness memorandums issued by 
the Director of OPM. To describe the role FEBs play in coordinating 
federal efforts relevant to COOP, we interviewed officials from OPM and 
the Chicago, Cleveland, and Philadelphia FEBs.

Our review was conducted from February through December 2003 in 
accordance with generally accepted government auditing standards. 
Appendix I provides additional information on our scope and 
methodology.

Results in Brief:

According to experts from private sector businesses, federal agencies, 
and other public sector organizations with knowledge of human capital 
or continuity planning, continuity planning efforts should and do give 
priority to the immediate aftermath of a crisis--securing the safety of 
all employees and addressing the needs of employees who perform or 
directly support essential operations. However, the experts also note 
that other human capital considerations, especially those associated 
with the efforts of an organization to resume all other operations, are 
also crucial and often have not been well developed. Given that the 
majority of employees would be associated with resumption efforts 
rather than essential operations, considering this segment of the 
organization is an important part of continuity planning. The experts 
we contacted identified two key human capital principles that should 
guide all continuity efforts: demonstrate sensitivity to individual 
employee needs and maximize the contributions of all employees to 
mission results.

The experts also identified six organizational actions, which are 
listed in table 1, to enhance continuity efforts by addressing 
additional human capital considerations that are relevant to 
continuity.

Table 1: Key Organizational Actions to Enhance Continuity Efforts:

Demonstrate top leadership commitment; 
* Instill an approach to continuity planning that includes human 
capital considerations.
* Allocate resources and set policies.
* Set direction and pace of recovery.

Seek opportunities for synergy; 
* Integrate continuity efforts with broader decision making.
* Consider how continuity investments benefit other program efforts.

Maintain effective communication; 
* Build relationships through two-way communication.
* Establish roles, responsibilities, and expectations.
* Develop redundant communication vehicles.

Target investments in training and development; 
* Raise awareness of continuity efforts.
* Build skills and competencies to increase flexibility.
* Foster a culture that values flexible employees who are empowered to 
make effective decisions.

Leverage the flexibility of human capital; 
* Enable employees associated with resumption activities to contribute 
to mission results in alternate assignments.
* Sustain the contribution of employees associated with essential 
operations.
* Maintain organizational knowledge of staffing requirements and 
availability.

Build process to identify and share lessons; 
* Create a learning environment.
* Make learning explicit and shared. 

Source: GAO.

[End of table]

In the federal government, FEMA, as executive agent for COOP, and OPM, 
as the President's agent and advisor for human capital matters, have 
exhibited leadership in addressing human capital considerations 
relevant to COOP. For example, FEMA issued FPC 65, which is the primary 
guidance for federal agencies to use in developing a viable COOP 
capability, to address significant disruptions requiring relocation to 
an alternate facility. However, the guidance does not recognize 
significant disruptions that do not require relocation to an alternate 
facility. Regarding human capital considerations, this guidance 
directly addresses the need to secure the safety of all employees and 
respond to the needs of personnel performing or supporting essential 
operations. OPM has similarly addressed these primary considerations 
through several initiatives, including establishing the Emergency 
Preparedness subcommittee of the Chief Human Capital Officers Council, 
releasing emergency guides for federal employees and managers, and 
issuing a series of memorandums outlining the existing human resource 
management flexibilities that agencies might employ in emergency 
situations. However, neither FEMA's nor OPM's guidance to date has 
adequately addressed the human capital considerations related to the 
resumption of agency operations that are not considered essential. 
Recognizing this, they are working together, as well as with other 
federal partners, to more fully address the considerations inherent in 
these resumption activities. One expected outcome of this partnership 
is an updated and augmented federal COOP guidance that will more fully 
address human capital considerations, particularly those regarding 
employees who will be involved with broader resumption efforts.

Although not specifically tasked with coordinating COOP efforts, FEBs 
are generally responsible for improving coordination among federal 
activities in areas outside of Washington, D.C. Officials at OPM, which 
provides direction to FEBs, have recognized that the boards can add 
value to regional emergency preparedness efforts, including COOP, as 
vehicles for communication, coordination, and capacity building. The 
FEBs that we visited in Chicago, Cleveland, and Philadelphia are 
already playing active roles in emergency preparedness and COOP efforts 
by holding COOP training seminars, creating emergency preparedness 
committees, and developing and activating emergency dismissal and 
closure procedures. However, the lack of a specific role and defined 
responsibilities for FEBs with regard to emergency preparedness 
efforts, including COOP, as well as a funding structure that results in 
differing capacities among FEBs, may lead to inconsistent levels of 
preparedness across the nation.

Given the importance of human capital in maintaining essential 
functions and resuming full operations during an emergency, we 
recommend that the Secretary of Homeland Security direct the Under 
Secretary of Emergency Preparedness and Response to expand the 
definition of a COOP event to recognize severe disruptions that do not 
affect facilities and complete efforts to revise federal COOP guidance 
to more fully address human capital considerations by incorporating the 
six actions identified in this report. We also recommend that the 
Director of OPM more fully address human capital considerations in 
emergency preparedness guidance by incorporating the six actions 
identified in this report; and determine the appropriate role for FEBs 
in coordinating emergency preparedness efforts, including COOP, and 
address resulting capacity issues.

On March 10, 2004, we provided a draft of this report to the Secretary 
of Homeland Security and the Director of OPM. We received written 
comments from the Under Secretary of Emergency Preparedness and 
Response on behalf of the Department of Homeland Security (DHS) and 
FEMA and from the Director of OPM. In his comments, which are reprinted 
in appendix III, the Under Secretary agreed that the report addresses 
the human capital considerations that are relevant to COOP guidance and 
coordination. He added that DHS and FEMA would incorporate our 
recommendations in federal COOP guidance, work jointly with OPM and 
other federal partners to improve the federal government's COOP 
program, and expand the agency's efforts to improve coordination of 
COOP program efforts at the regional level.

In her comments, which are reprinted in appendix IV, the Director of 
OPM said the agency has already carried out our recommendation to more 
fully address human capital considerations in emergency preparedness 
guidance, including COOP, by incorporating the key actions identified 
in the report. Most of the supporting examples provided by OPM were 
included in the draft report and deal largely with human capital 
considerations related to life safety and the needs of personnel 
performing essential operations. While such initiatives are important 
first steps, there remain opportunities to improve OPM's emergency 
preparedness guidance to include a fuller range of human capital 
considerations. As such, our recommendation to develop additional 
emergency preparedness guidance that incorporates the key actions 
identified in the report remains unchanged. The Director also stated 
that the leadership role that OPM plays with respect to FEBs was not 
sufficiently developed in the report. Most of the supporting examples 
that the Director provided were included in the draft report. Moreover, 
the additional examples generally do not address our larger point that 
the role of FEBs in coordinating emergency preparedness efforts, 
including COOP, needs to be clearly defined. As such, we maintain our 
conclusion that the context in which FEBs currently operate, including 
the lack of a clearly defined role in emergency preparedness efforts 
and the varying capacities among FEBs, could lead to inconsistent 
levels of preparedness across the nation. The Director of OPM also 
suggested several clarifications to the report. We considered these 
suggestions and made changes to the report where appropriate.

Background:

The policy of the U.S. government is to have in place a comprehensive 
and effective program to ensure continuity of essential federal 
functions under all circumstances.[Footnote 3] COOP planning is an 
effort conducted by individual agencies to fulfill that policy and 
assure that the capability exists to continue essential agency 
functions across a wide range of potential emergencies. COOP has been 
closely associated with continuity of government programs, which are 
meant to ensure the survival of our constitutional form of government. 
COOP was first conceived during the Cold War to ensure that the U.S. 
government would be able to continue to function in case of a nuclear 
war. However, in the wake of the demise of the Soviet Union and the 
reduced threat of nuclear attack in the early 1990s, COOP planning 
languished.

Following the World Trade Center bombing in 1993 and the Oklahoma City 
bombing in 1995, COOP as a program was given renewed attention based on 
the recognition of emerging threats and the need to continue essential 
functions of the federal government in an all-hazards environment, 
which includes acts of nature, accidents, technological emergencies, 
and incidents related to military or terrorist attacks. A series of 
Presidential Decision Directives (PDD) was issued that began to link 
programs for terrorism, critical infrastructure protection, and 
COOP.[Footnote 4] In addition, as we approached the turn of the 
century, federal agencies also dealt with the Year 2000 computer 
problem by developing business continuity and contingency plans to 
ensure program delivery in the event of a technology failure or 
malfunction. Federal COOP efforts have evolved by building upon the 
planning for each of these events that focused on protecting critical 
infrastructure, both physical systems and cyber-based systems. The 
events of September 11, 2001, highlighted in dramatic fashion the 
vulnerabilities agencies face in each of these areas and focused new 
attention on the effects such events have on agencies' most important 
assets--their people, or human capital.

FEMA, the General Services Administration (GSA), and OPM are the three 
agencies that have the most direct impact on individual agency efforts 
to develop viable COOP capabilities. PDD 67, which outlined individual 
agency responsibilities for COOP, identified FEMA as the executive 
agent for federal COOP planning. As executive agent, FEMA has the 
responsibility for formulating guidance, facilitating interagency 
coordination, and assessing the status of COOP capability across the 
federal executive branch. PDD 67 also required GSA to work with FEMA in 
providing COOP training for federal agencies and to assist agencies in 
acquiring alternate facilities. In addition, the Federal Management 
Regulation requires GSA to lead federal Occupant Emergency Program 
(OEP) efforts, which are short-term emergency response programs that 
establish procedures for safeguarding lives and property during 
emergencies in particular facilities.[Footnote 5] As the President's 
agent and advisor for human capital matters, OPM has been actively 
involved in federal emergency preparedness efforts. OPM has issued a 
series of emergency preparedness guides for federal managers, 
employees, and their families; issued a number of memorandums relating 
to planning, preparedness, and the flexibilities available to agencies 
in emergency situations; and held emergency planning and preparedness 
forums to help agencies select emergency personnel. In addition, FEMA, 
GSA, and OPM collaborate to implement the Federal Workforce Release 
Decision and Notification Protocol when emergency situations occur in 
the Washington, D.C., area.

Human Capital Considerations Are Relevant to Continuity Planning and 
Implementation Efforts:

The current literature indicates, and experts that we consulted 
confirmed, that the immediate response to a crisis should give priority 
to securing the safety of all employees and addressing the needs of 
employees who perform or directly support essential operations. For 
example, the standard for emergency management and business continuity, 
which was developed by the National Fire Protection Association and 
endorsed by FEMA, recommends that organizations include the following 
priorities in their continuity program: ensuring the safety and health 
of employees, establishing critical functions and processes, and 
identifying essential representatives.[Footnote 6]

Consequently, the experts said that these priorities have received most 
of the human capital attention in continuity efforts for both the 
private and public sectors, including federal agencies. Appropriately, 
organizations focus on minimizing the loss of life and injuries, which 
is key to all other recovery efforts. Such efforts commonly include 
first aid training, evacuation plans and drills, and dismissal 
policies. Organizations also focus on identifying the core group of 
employees that will establish and maintain essential operations as 
dictated by an organization's mission. Organizations, for example, 
commonly identify leadership structures to manage crisis response. Even 
so, experts noted that organizations vary widely in their effectiveness 
in addressing these priorities.

The continuity process, however, extends beyond the goals of life 
safety and the performance of essential operations. The experts 
identified a number of human capital considerations beyond these goals 
that are not well addressed. For example, the priorities discussed 
above do not address human capital considerations for employees who are 
not involved in providing essential functions. Such employees would be 
associated with efforts to fully resume all other operations and 
represent the majority of an organization.

The experts identified two principles that should guide actions to more 
fully address human capital considerations applicable to all continuity 
planning and implementation efforts. The first is recognizing and 
remaining sensitive to employees' personal needs during emergencies 
when shaping the appropriate organizational expectations of employees. 
The emergency event that activates continuity plans may also cause 
emergency events in the personal lives of individual employees. Similar 
to an organization placing its highest priority on the safety and well-
being of its employees, employees may have high-priority 
responsibilities to others. These personal responsibilities may limit 
employees' ability to contribute to mission accomplishment until these 
other obligations are satisfied.

The second principle experts identified is maximizing the contributions 
of all employees, whether in providing essential operations or resuming 
full services. This should be done within the limits of an employee's 
ability to contribute given the situation, as described in principle 
one, and within the limits of the organization to use those 
contributions effectively. According to the experts, the experience of 
organizations during emergencies has been that employees remain 
motivated to contribute to organizational results, which is 
increasingly felt the longer the emergency continues. Enabling 
employees to contribute promotes more effective delivery of essential 
operations and more rapid resumption of full operations. In addition, 
in extreme disruptions of employees' personal circumstances, providing 
purposeful activities helps avoid the debilitating affects of a 
disruption on employees, including job-related anxiety and post-
traumatic stress disorder.

The experts we interviewed also identified six organizational actions 
to enhance continuity planning and implementation efforts, listed in 
figure 1.

Figure 1: Six Organizational Actions to Enhance Continuity Efforts:

[See PDF for image]

[End of figure] 

Each of these actions is described in more detail below.

Demonstrate top leadership commitment; 
* Instill an approach to continuity planning that includes human 
capital considerations; 
* Allocate resources and set policies; 
* Set direction and pace of recovery.

Our past work has shown that the demonstrated commitment of top leaders 
is perhaps the single most important element of successful change 
management and transformation efforts.[Footnote 7] Effective 
continuity efforts have the visible support and commitment of their 
organization's top leadership. According to the experts, traditional 
continuity planning focuses on the operations side of recovery and 
often overlooks human capital considerations. As such, it is important 
for top leadership to ensure that the appropriate balance is achieved 
in considering physical infrastructure, technology, and human capital. 
In providing leadership prior to the emergency, leaders demonstrate 
their commitment to human capital by establishing plans that value the 
organization's intention to manage employees with sensitivity to their 
individual circumstances, recover essential operations on a priority 
basis, and resume other operations as quickly as possible.

Organizational leaders show commitment to continuity planning by 
allocating resources and setting policies that effectively meet the 
organization's continuity needs. The experts told us that committed 
leaders provide sufficient funding and staff to conduct planning and 
preparation efforts effectively. While the resources needed vary from 
location to location within an organization, the experts said that 
organizations should have enough resources available to develop 
effective plans, test critical systems, train all staff, and conduct 
simulation exercises. Committed top leadership also ensures that clear 
policies and procedures are in place for all aspects of continuity to 
ensure that quick and effective decisions are made during times of 
emergencies. Those policies and procedures should be fair, shared with 
employees and their representatives in advance of an emergency, and 
able to be consistently applied to all employees. Experts and union 
leaders we met with agree that the cooperation and input from all 
components within the organization, including employees and their 
representatives, is important in developing these policies.

Following a disruption to normal operations, top leadership sets the 
direction and pace of organizational recovery. According to the 
experts, top leadership sets direction by providing the legitimate and 
identifiable voice of the organization for employees to rally around 
during tumultuous times. An expert from Marsh & McLennan Companies, 
Inc., a company that lost over 350 people in the World Trade Center on 
September 11, 2001, noted that in the aftermath of an emergency there 
is a fundamental need for a strong, visible leader to provide constant 
reassurance. The expert added that "employees need to know that someone 
is in control, even if the leaders do not know all the answers." In 
addition, top leaders set the pace of organizational recovery by 
providing leadership to both the management team leading recovery of 
essential operations and the management team leading the resumption of 
all other operations.

Seek opportunities for synergy; 
* Integrate continuity efforts with broader decision making; 
* Consider how continuity investments benefit other program efforts.

As we have previously reported, effective organizations integrate human 
capital approaches as strategies for accomplishing their mission and 
programmatic goals.[Footnote 8] According to the experts, strategic 
decisions made to improve day-to-day operations, including human 
capital approaches, and those made to build continuity readiness are 
not exclusive of one another and may have synergies. For example, early 
in 2001, GAO made the business decision to supply all of its analysts 
with laptop computers for financial reasons and to provide employees 
with flexibility in carrying out their work. That business decision, 
however, also contributed to our ability to quickly adapt to 
unforeseeable circumstances in October 2001. In response to the release 
of anthrax bacteria on Capitol Hill, we opened our doors to the 435 
members of the House of Representatives and selected members of their 
staffs. Over 1,000 GAO employees were immediately able to make use of 
their laptops to work from alternate locations. Consequently, we 
minimized the disruption to our operations and assisted the House of 
Representatives in continuing its operations. To take advantage of such 
synergies, the experts said that decisions regarding continuity efforts 
should be integrated with broader business decision making.

The integration of continuity planning with broader decision making 
helps to ensure that the direction of all efforts is consistent and 
provides mutual benefits. In a limited resource environment, 
consideration of how continuity investments benefit other program 
efforts also helps to strengthen the business case for human capital 
investments that are meant to improve continuity capabilities, day-to-
day operations, or both.

Maintain effective communication; 
* Build relationships through two-way communication; 
* Establish roles, responsibilities, and expectations; 
* Develop redundant communication vehicles.

The importance of communication cannot be overstated. According to the 
experts, two-way communication with employees, their representatives, 
and other stakeholders is key to building relationships and 
partnerships that can facilitate organizational recovery efforts. We 
have also previously reported that communication is most effective when 
done early, clearly, often, and is downward, upward, and 
lateral.[Footnote 9] According to a senior National Treasury Employees 
Union (NTEU) official, the union was able to capitalize on ongoing two-
way communications with the Internal Revenue Service's (IRS) regional 
leadership to provide members with information following the September 
11, 2001, attacks. For example, during the recovery efforts, the union 
provided supplementary channels for communicating with employees, 
including daily joint messages from the IRS Regional Director and the 
NTEU Chapter President. In addition, when the local New York office 
reopened on September 20, 2001, both the NTEU National President and 
the IRS Commissioner greeted employees at the door. From the union's 
perspective, communication efforts such as these helped to provide 
reassurance and support as well as to maintain employee trust.

According to experts, roles, responsibilities, and performance 
expectations must be communicated to all employees, and their 
representatives, prior to a disruption to promote the efficient and 
effective use of all of an organization's human capital assets. Early 
communication enables employees to assess and communicate to the 
organization any personal circumstances that may limit their ability to 
carry out those roles. The experts and union officials whom we spoke 
with agreed that in some cases, more formal communication vehicles, 
such as memorandums of understanding or addenda to collective 
bargaining agreements, may be necessary to negotiate changes or clarify 
roles and responsibilities in continuity plans.

Because effective emergency two-way communication depends greatly on 
technology, alternate and redundant communication infrastructures are 
necessary. In addition to technological vulnerabilities that can render 
different methods of communication useless, people frequently do not 
remain tied to the contact number or location listed in emergency 
records. To address these challenges, Macy's West, for example, has 
built an alternate emergency communication system that serves as an 
employee message retrieval system. The system, which is based outside 
of the region in case the local phone networks are overloaded, allows 
(1) the leadership of Macy's West to leave messages with instructions 
for employees, (2) family members to leave messages for employees, and 
(3) employees to leave messages for their loved ones.

Target investments in training and development; 
* Raise awareness of continuity efforts; 
* Build skills and competencies to increase flexibility; 
* Foster a culture that values flexible employees who are empowered to 
make effective decisions.

Our past work has shown that organizations should consider making 
targeted investments in human capital approaches, such as training and 
development.[Footnote 10] According to the experts, training and 
development programs related to continuity efforts can help to raise 
awareness among all employees. The Social Security Administration 
(SSA), for example, has developed a video-training course to provide an 
overview of COOP, which includes an introduction from the Commissioner 
explaining why COOP is so important, a discussion of SSA's critical 
workloads and how they would be processed during a disruption, and 
references to federal guides and information. The experts noted that 
less formal approaches, such as continuity planning awareness weeks, 
could also help to raise awareness.

Our recent work has indicated that training and development programs 
build skills and competencies that enable employees to fill new roles 
and work in different ways, which helps to build organizational 
flexibility.[Footnote 11] According to experts, the training and 
development goals for employees assigned to the team that performs 
essential operations differ from those for the employees assigned to 
the team that is responsible for resuming all other organizational 
operations. The goal for the team that performs essential operations is 
to achieve "critical depth," which occurs when an adequate number of 
employees are available to staff each critical function, in the event 
that a member of the team expected to perform that function is 
unavailable. Organizations can build critical depth in various ways, 
including using exercises that simulate an emergency to train backup 
employees alongside employees who have primary responsibility for an 
essential operation, or allowing backup employees to perform the 
operation while the primary employees oversee and critique their 
performance. In addition, critical depth can be built through 
succession planning. To be effective for this purpose, however, the 
scope of succession planning is extended to recognize that there is no 
time to develop successors in an emergency and incrementally increase 
levels of authority as an individual matures in a position. Therefore, 
organizations may have to plan to use predecessors to a position, 
including retirees, as successors.

With regard to the team that is responsible for resuming all other 
organizational operations, experts said that the training and 
development goal is to build sufficient breadth to enable members to 
contribute to resumption efforts in a variety of ways. For example, 
development programs requiring employees to rotate within an 
organization to learn a variety of positions, potentially at a variety 
of locations, contribute to critical breadth. We have previously 
reported that developmental assignments place employees in new roles or 
unfamiliar job environments in order to strengthen skills and 
competencies and broaden their experience.[Footnote 12]

Effective training and development initiatives also help to foster a 
culture that is characterized by flexible employees who are empowered 
to make effective decisions independently. According to experts, such a 
culture is often critical to agency recovery and resumption efforts. 
Experts from Marsh & McLennan Companies, Inc., reported that effective 
decision-making abilities could be developed through formal training 
about the parameters in which employees are empowered to make decisions 
and on-the-job experiences demonstrating how employees can exercise 
authority in making decisions that manage, rather than avoid, risk and 
are focused on achieving results.

Leverage the flexibility of human capital; 
* Enable employees associated with resumption activities to contribute 
to mission results in alternate assignments; 
* Sustain the contribution of employees associated with essential 
operations; 
* Maintain organizational knowledge of staffing requirements and 
availability.

The events of September 11, 2001, give ample evidence of the dedication 
and flexibility of federal, state, and local government employees in 
providing services to the American public. Disruption of normal 
operations challenges an organization to use this dedication and 
flexibility to its advantage, especially with regard to employees 
associated with the resumption of all operations that are not 
considered essential. According to the experts, organizations may use 
approaches such as telework and geographic dispersion, which includes 
regional structure, to increase the ways in which employees may 
contribute. As OPM guidance has underscored and presenters at a recent 
conference held by the International Telework Association and Council 
noted, telework is an important and viable option for federal agencies 
in COOP planning and implementation efforts, especially as the duration 
of the emergency event is extended.[Footnote 13] However, to make 
effective use of telework, experts told us that organizations should 
identify those employees who are expected to telework during a 
disruption and communicate that expectation to them in advance. In 
addition, organizations should provide teleworkers with adequate 
support in terms of tools, training, and guidance.[Footnote 14] 
Geographic dispersion can also provide a way for employees associated 
with resumption activities to continue their normal functions albeit 
at or through other locations. For example, SSA recognizes that its 
field structure enables the agency to make use of both multiple 
locations and telework in providing its employees ways to contribute 
because most field functions can be transferred fairly easily from one 
location to another in the same region or performed remotely with 
laptop computers. Based on these efforts, SSA does not envision a 
scenario in which its field employees would not contribute to their 
normal functions for more than 72 hours.

Employees demonstrate their flexibility by a willingness to contribute 
to the organization in roles that may be unusual. According to the 
experts, flexible employees contribute as best they can usually in the 
following sequence: (1) providing support to the team performing 
essential operations, if needed; (2) continuing to contribute to their 
normal mission-related functions; (3) performing an alternate 
contribution for their organization; or if none of these can be 
accomplished, (4) volunteering in their communities as a direct form of 
public service. Federal employees may have additional opportunities to 
contribute to not only their own agencies' operations but also other 
agencies' operations in serving the American people. In addition, a 
recent memorandum from OPM recognizes the value of federal employees 
contributing to the general public through community volunteer service 
in the range of alternative contributions.[Footnote 15]

Employees associated with providing essential operations may be working 
under unusual pressures for extended periods of time, and organizations 
need to consider ways to sustain these efforts. The experts recommend 
that if the circumstances of the emergency continue long enough to 
raise concerns about burnout, organizations consider providing 
opportunities for working in shifts; rotating assignments among team 
members; providing relief through the use of qualified employees 
associated with resumption activities; reemploying retirees; or 
utilizing employees from stakeholder or networked organizations, such 
as suppliers or contractors.

According to the experts, the ability of organizations to match 
staffing requirements with available skills and abilities could be 
enhanced through various initiatives, such as job banks, skill profile 
databases, and pre-arranged partnerships with other organizations or 
community service organizations. For example, job banks that detail 
additional jobs that may be required during an emergency but are not 
considered essential could allow employees to preselect alternate 
contributions that they would be able to perform. In the federal 
government, agencies could establish their own job banks; form 
interagency partnerships that link the potential needs of several 
agencies; and create a cache for volunteer opportunities, possibly tied 
to the Citizen Corps.[Footnote 16] Organizations with databases that 
collect employee knowledge, skills, and abilities (KSA)--even those 
KSAs outside the scope of an employee's normal functions--may 
complement the job banks by allowing organizations to match available 
KSAs with the unmet needs of the organization.

Build process to identify and share lessons; 
* Create a learning environment; 
* Make learning explicit and shared.

An evaluation process that explicitly identifies and disseminates 
lessons learned during disruptions, or simulations of disruptions, 
promotes learning among all of an organization's human capital assets 
and helps to improve organizational performance. An organization that 
is committed to learning has an inclusive and supportive process and a 
framework designed prior to a disruption to gather important data. 
According to experts, organizations committed to learning will ensure 
that those employees who are key to the recovery and resumption efforts 
are involved in the formal evaluation process in a timely manner and 
will seek the input from as many other employees as possible. Such an 
inclusive environment will enable the organization to discover valuable 
lessons learned by employees in unusual circumstances. In addition, 
conducting evaluations in a "no-blame," nonattribution atmosphere and 
taking organizational ownership of any problems that might be 
identified increases the openness with which participants are willing 
to share their experiences. To encourage such an environment, FEMA 
officials told us that the agency's Office of National Security 
Coordination has recently implemented a reporting system that allows 
any employee to identify lessons learned anonymously during an 
emergency, instead of waiting for the formal review process.

Our past work has shown that human capital approaches are best designed 
and implemented based on data-driven decisions.[Footnote 17] According 
to experts, having a framework prior to a disruption helps to gather 
data important to evaluating the effectiveness of human capital 
approaches during a disruption. Some measures that they suggested 
include number of employees contributing to mission-related outcomes 
each day; degree of contribution (e.g., part time or full time); 
location of employee when contributing (e.g., at alternate facility or 
home); type of contribution (e.g., performing same function, performing 
an alternate function within the department, working with another 
department, or volunteering); or obstacles to contribution (e.g., 
organizational or personal).

Once identified, it is important for the lessons learned during the 
evaluation to be made explicit and then widely disseminated. According 
to experts, the manner and formality of documentation and 
dissemination, however, depend on the situation or needs of the 
organization (e.g., after-action reports, detailed analyses, executive 
summaries, video tapes, CDs, or Web-based reports). There are unique 
opportunities in the federal government for agencies to share explicit 
lessons learned both internally and with other federal agencies and 
stakeholders. For example, following the September 11, 2001, attacks, 
senior Department of Housing and Urban Development officials asked the 
New York Acting Regional Director to recount her experiences and 
lessons learned in front of a video camera. The accounts were edited 
down into a 30-minute video entitled Thinking the Unthinkable: 
Preparing for Disaster. That video has been used within the department 
as a training aid and has been shared with over 50 federal agencies 
with the help of the Washington, D.C.-based interagency COOP Working 
Group (CWG) and the FEBs in cities across the United States. In Canada, 
Emergency Management Alberta (EMA) employs a centralized Disruption 
Incident Reporting System for all government agencies, which is 
accessible via the Internet, to obtain timely and accurate reporting of 
all disruptions and "most importantly, ensure lessons learned can be 
documented for follow-up."[Footnote 18] EMA has also created a Lessons 
Learned Warehouse Web site to share continuity lessons learned in all 
aspects of crisis management.[Footnote 19]

FEMA and OPM Have Exhibited Leadership in Addressing Human Capital 
Considerations Relevant to COOP:

As we stated earlier, the human capital considerations related to life 
safety and the needs of personnel performing essential operations have 
largely been addressed in continuity efforts. In the federal 
government, FEMA has issued guidance that has addressed these 
considerations and has recognized the opportunity to more fully address 
human capital considerations in its guidance. In addition, OPM has 
issued federal emergency preparedness guidance relevant to COOP that 
also addresses these considerations and is working with FEMA to more 
fully address human capital considerations in federal guidance.

FEMA Issued Guidance That Addresses Human Capital Considerations, but 
Recognizes Opportunity to Do More:

As executive agent for federal COOP planning, FEMA issued FPC 65 in 
July 1999 as the primary guidance for agencies developing viable COOP 
plans. According to FPC 65, the purpose of COOP planning is to 
facilitate the performance of agency essential functions for up to 30 
days during any emergency or situation that may disrupt normal 
operations. The five objectives of a viable COOP plan listed in FPC 65 
are (1) ensuring the continuous performance of an agency's essential 
functions during an emergency; (2) protecting essential facilities, 
equipment, records, and other assets; (3) reducing or mitigating 
disruptions to operations; (4) reducing loss of life, minimizing damage 
and losses; and (5) achieving a timely and orderly recovery from an 
emergency and resumption of full service to customers.

The guidance subsequently limits a COOP event to one that significantly 
affects the facilities of an organization and requires the 
establishment of essential operations at an alternate location. 
Therefore, as FEMA recognizes, the guidance does not apply to 
significant disruptions that leave facilities intact, such as a severe 
acute respiratory syndrome (SARS) outbreak that could lead a large 
number of employees to avoid congested areas, including their 
workplaces. Although a people-only event such as SARS would 
significantly disrupt normal operations, the current COOP guidance 
would not apply because facilities would remain available. FPC 65 also 
indicates that the guidance is for use at all levels and locations of 
federal agencies. FEMA officials acknowledge, however, that the 
priority of COOP planning to date has been focused on agency 
headquarters located in the Washington, D.C., area.

Given the purpose of COOP and the nature of its objectives, the human 
capital considerations FEMA included in the guidance primarily relate 
to life safety for all employees and addressing the needs of employees 
performing essential operations. For example, the guidance states that 
one of the objectives of COOP is "reducing loss of life, minimizing 
damage and losses." It also refers to the legal requirement that each 
agency develop a viable OEP, which is a short-term emergency response 
program that establishes procedures for safeguarding lives and property 
during emergencies in particular facilities.[Footnote 20] FPC 65 more 
broadly defines life safety by including a statement related to the 
need to consider the health and emotional well-being of employees on 
the essential operations team. Also, with respect to employees who 
perform essential functions, the guidance directs agencies to designate 
an emergency team, delegate authority, establish orders of succession, 
develop communication plans, develop training programs, and provide for 
accountability.

FEMA officials we spoke with recognized that there is a need to go 
beyond the human capital considerations that have already been 
addressed within federal COOP guidance in order to achieve the full 
range of COOP objectives. Specifically, FEMA officials agreed that it 
was particularly important to deal with the human capital 
considerations inherent to the resumption activities needed to fully 
recover from an emergency. To that end, FEMA has taken several steps to 
more fully address these considerations. FEMA has worked with a 
subcommittee of the interagency CWG--a Washington, D.C.-based group 
that meets monthly to discuss issues related to COOP--to rewrite the 
federal COOP guidance. The agency has requested OPM's assistance in 
incorporating these considerations into the new federal COOP guidance. 
FEMA has also worked in cooperation with us as we developed this 
report. As a result, FEMA officials told us that the draft guidance 
would include an augmented discussion of human capital considerations.

OPM Has Also Exhibited Leadership in Addressing Human Capital 
Considerations Related to Emergency Preparedness:

OPM has also recognized the value of human capital in COOP and other 
emergency preparedness efforts. In a memorandum to the heads of 
executive departments and agencies, for example, the Director of OPM 
stated that "the American people expect us to continue essential 
government services without undue interruption, no matter the 
contingency, and Federal agencies must have the human resources to 
accomplish their missions, even under the most extreme of 
circumstances."[Footnote 21] To this end, OPM has established the 
Emergency Preparedness subcommittee of the Chief Human Capital Officers 
Council that is tasked with recommending policy changes, legislative 
changes, or other strategies for moving the issue forward. In addition, 
OPM has initiated several efforts to help agencies address human 
capital considerations in emergency preparedness related to life safety 
and the needs of personnel performing essential operations, as well as 
to recognize the role that employee organizations and unions could play 
in supporting those efforts. These initiatives are important first 
steps; however, they do not fully address human capital considerations 
related to the resumption of all agency operations that are not 
considered essential.

With regard to providing for the safety of all employees, OPM has 
issued four preparedness guides to educate federal employees, managers, 
and their families on how to protect themselves from a potential 
biological,

chemical, or radiological release, whether accidental or 
intentional.[Footnote 22] The guides also spell out the 
responsibilities of the federal government and individual agencies to 
protect employees in the event of an emergency. In addition to the 
guides, OPM has addressed safety issues by revising the Washington, 
D.C., area emergency dismissal protocols for federal employees and 
contractors, in conjunction with FEMA and GSA; issuing memorandums to 
all agency heads detailing the "minimum obligations" agencies have to 
secure the safety of federal workers; issuing two emergency 
preparedness surveys through which federal agencies could report on 
their progress in ensuring the safety of their employees; and 
highlighting the role that Employee Assistance Programs can play in 
responding to employee needs in emergency situations.

Related to providing for the needs of employees performing or 
supporting essential operations, OPM has led two forums focusing on 
emergency employee designations and the flexibilities that are 
available to agencies in emergency situations. OPM has also issued a 
series of memorandums outlining the existing human resource management 
flexibilities that agencies might employ in emergency 
situations.[Footnote 23] Other human capital flexibilities that are 
available to agencies in nonemergency situations, such as 
telecommuting, job sharing, and flexible scheduling, might provide 
additional assistance during emergency situations and are detailed in 
OPM's handbook, Human Resources Flexibilities and Authorities in the 
Federal Government. (See app. II for a list of human resource 
flexibilities that agencies may use to respond to emergency 
situations.):

In addition to initiating efforts to address several human capital 
considerations, OPM has highlighted the need to work with and through 
employee organizations and unions in developing and executing emergency 
management strategies. For example, OPM has held meetings with federal 
labor union leaders and employee associations to discuss relevant 
employee safety issues and has specifically encouraged agencies to work 
with and share information on preparedness efforts with applicable 
employee organizations and unions. Senior union officials whom we spoke 
with from the American Federation of Government Employees and NTEU 
agreed that it is important for unions to be involved throughout COOP 
planning and implementation efforts. These officials also stated that 
unions could be resources for agencies in communicating with employees, 
both before and during an emergency, as well as in engaging employees 
in recovery and resumption efforts.

FEBs Have Opportunities to Coordinate Regional Emergency Planning 
Efforts, Including COOP, in Major Metropolitan Areas:

Although FEMA heads the interagency CWG to help coordinate COOP efforts 
in the Washington, D.C., area, the efforts of this group do not apply 
to the over 80 percent of federal employees who work outside of this 
area. While not specifically tasked with coordinating COOP efforts, 
FEBs are generally responsible for improving coordination among federal 
activities and programs in major metropolitan areas outside of 
Washington, D.C.[Footnote 24] Under the direction of OPM, FEBs support 
and promote national initiatives of the President and the 
administration and respond to the local needs of federal agencies and 
the community. OPM officials have recognized that FEBs can add value to 
regional emergency preparedness efforts, including COOP, as vehicles 
for communication, coordination, and capacity building. To make use of 
these capabilities, OPM has provided FEBs with relevant emergency 
preparedness materials, encouraged FEBs to focus on preparedness issues 
in their regions, requested that FEBs test their emergency 
communication plans, and encouraged FEBs to inform OPM of any 
emergency-related events affecting federal employees in the regions.

The FEBs that we visited are already playing active roles in regional 
emergency preparedness and COOP efforts. For example, the Chicago FEB 
has established committees to deal with Disaster Recovery Planning and 
Emergency Release; surveyed its member agencies to determine the status 
of COOP planning in the region; sponsored a series of seminars, in 
conjunction with GSA and FEMA, on topics related to COOP, sheltering in 
place, and national security; participated in regional exercises, such 
as TOPOFF 2;[Footnote 25] and sponsored a COOP exercise to provide 
agencies with a forum for validating their COOP plans, policies, and 
procedures. The Cleveland FEB has established an emergency preparedness 
committee to promote awareness and preparation, developed an Employee 
Emergency Contingency Handbook that provides basic actions to respond 
to emergencies that may be encountered by federal employees, and helped 
to make training available to all federal agencies. The Philadelphia 
FEB has held several COOP workshops for agencies and regularly shares 
relevant information with agency officials via e-mail. In addition, 
these FEBs play a role in developing and activating dismissal and 
closure procedures for federal agencies located in their particular 
regions.

Although both OPM officials and the FEB officials whom we spoke with 
recognized that FEBs can add value in coordinating emergency 
preparedness efforts, including COOP, and that such a role is a natural 
outgrowth of general FEB activities, a specific role and 
responsibilities have not been defined. In addition, the current 
structure in which FEBs operate results in differing capacities of FEBs 
across the nation. For example, each agency's participation in FEB 
activities is voluntary. Consequently, FEBs can only make 
recommendations to agencies, without the ability to require agency 
compliance. Also, FEBs rely on host agencies for funding, which results 
in variable funding and staffing from year to year and across FEBs. OPM 
has recognized that the roles and capacities of FEBs vary across the 
nation and has established an internal working group to study the 
strengths and weaknesses of FEBs and develop recommendations for 
improving their capacity to coordinate in regions outside of 
Washington, D.C. According to OPM, such efforts in regard to local 
emergency preparedness and response will include improving 
dissemination of information and facilitation of COOP training and 
tabletop exercises; addressing the implications for strategic human 
capital management in continuing the operations of the federal 
government (e.g., alternate work schedules, remote work sites, and 
telecommuting capabilities); and developing strategies to better 
leverage the network of FEBs to help departments and agencies implement 
their initiatives.

Conclusions:

More fully addressing human capital considerations in emergency 
preparedness guidance, including COOP, could improve agency response 
capabilities to large-scale COOP emergencies or situations; could help 
minimize the impact of more common, yet less catastrophic disruptions 
(e.g., snowstorms and short-term power outages); and is consistent with 
building a more flexible workforce, which would enhance ongoing efforts 
across the federal government to create more responsive human capital 
management systems. As FEMA works to update its federal COOP guidance 
and OPM continues to issue emergency preparedness guidance relevant to 
COOP, several areas require attention to more fully address human 
capital considerations relevant to COOP.

By limiting COOP to situations that necessitate moving to an alternate 
facility, agencies are left without guidance for situations in which an 
agency's physical infrastructure is unharmed, but its employees are 
unavailable or unable to come to work for an extended period of time. 
While facilities and technology would not be affected by such 
situations, the unavailability of people to contribute to mission-
related outcomes could cause a significant disruption to normal 
operations.

Emergency guidance, including COOP, generally does not extend beyond 
consideration of life safety and the needs of employees performing 
essential operations. Therefore, the guidance excludes most agency 
employees--those who would be associated with resuming all other 
operations.

FEBs are uniquely situated to improve coordination of emergency 
preparedness efforts, including COOP, in areas outside of Washington, 
D.C. However, the context in which FEBs currently operate, including 
the lack of a clearly defined role in emergency preparedness efforts, 
including COOP, and varying capacities among FEBs, could lead to 
inconsistent levels of preparedness across the nation.

Recommendations for Executive Action:

We recommend that the Secretary of Homeland Security direct the Under 
Secretary for Emergency Preparedness and Response to take the following 
two actions:

* Expand the definition of a COOP event in federal guidance to 
recognize that severe emergencies requiring COOP implementation can 
include people-only events.

* Complete efforts to revise federal COOP guidance to more fully 
address human capital considerations by incorporating the six 
organizational actions identified in this report.

We recommend that the Director of OPM take the following two actions:

* Develop and provide additional emergency preparedness guidance to 
more fully address human capital considerations by incorporating the 
six organizational actions identified in this report.

* Determine the desired role for FEBs to play in improving coordination 
of emergency preparedness efforts, including COOP, and identify and 
address FEB capacity issues to meet that role. It would be appropriate 
for FEBs to be formally incorporated into federal emergency 
preparedness guidance, including COOP guidance, for areas outside of 
Washington, D.C.

Agency Comments and Our Evaluation:

We provided the Secretary of Homeland Security and the Director of OPM 
a draft of this report for review and comment. We received written 
comments from the Under Secretary of Emergency Preparedness and 
Response on behalf of FEMA and the Department of Homeland Security, 
which are reprinted in appendix III. In his comments, the Under 
Secretary stated that the draft accurately addressed human capital 
considerations relevant to COOP guidance and coordination and noted 
that DHS and FEMA will continue to work with OPM and other federal 
partners to improve the federal government's COOP plan by incorporating 
our recommendations in its federal COOP guidance. In addition, he 
stated that FEMA would expand its efforts with its regional offices and 
FEBs to improve coordination of COOP programs at the regional level.

The Director of OPM also provided written comments, which are reprinted 
in appendix IV. In her comments, the Director noted her appreciation 
for our acknowledgement of the agency's leadership role in addressing 
human capital considerations relevant to COOP planning. However, the 
Director of OPM stated that the agency has already carried out our 
recommendation to more fully address human capital considerations in 
emergency preparedness guidance, including COOP, by incorporating the 
key actions identified in the report. The Director provided numerous 
examples of actions OPM has taken to support emergency preparedness 
efforts, all of which she noted were influenced by the agency's human 
capital framework. In addition, the Director also attached an enclosure 
to the agency comments that contain examples of OPM's internal COOP-
related efforts that she believes would be helpful to federal agencies.

Most of the examples of emergency preparedness guidance that the 
Director of OPM provided were included in the draft report and deal 
largely with the human capital considerations related to life safety 
and the needs of personnel performing essential operations. While such 
initiatives are important first steps, there remain opportunities to 
improve OPM's emergency preparedness guidance to include a fuller range 
of human capital considerations, particularly related to the resumption 
of all agency operations that are not considered essential. As such, 
our assessment of OPM's guidance and our recommendation for the agency 
to develop and provide additional emergency preparedness guidance that 
incorporates the key actions identified in the report remain unchanged.

With regard to our second recommendation for OPM to determine the 
desired role of FEBs in improving coordination of emergency 
preparedness efforts, including COOP, and address any resulting 
capacity issues, the Director of OPM stated that the leadership role 
the agency plays with respect to FEBs was not sufficiently developed in 
the report and she provided examples of OPM's support for the FEB's 
efforts. Most of the supporting examples that the Director provided 
were included in the draft report. Moreover, the additional examples 
generally do not address our larger point that the role of FEBs in 
coordinating emergency preparedness efforts, including COOP, needs to 
be clearly defined. As such, we maintain our conclusion that the 
context in which FEBs currently operate, including the lack of a 
clearly defined role in emergency preparedness efforts and the varying 
capacities among FEBs, could lead to inconsistent levels of 
preparedness across the nation.

The Director of OPM suggested several clarifications to the report, 
which we considered and incorporated where appropriate. For example, 
she suggested both technical and substantive changes to a footnote 
describing Federal Executive Associations (FEA) and Federal Executive 
Councils (FEC). While we made technical changes in response to these 
comments, our work does not allow us to categorically exclude all FEAs 
and FECs as viable options for the coordination of emergency 
preparedness activities, as the Director suggested in her response. 
Instead, we recognize that any guidance provided to FEBs would likely 
be beneficial to FEAs and FECs despite their differences. The Director 
also provided additional details describing OPM's internal working 
group that is studying the strengths and weaknesses of FEBs, and we 
have incorporated these details into the report.

We are sending copies of this report to the Ranking Minority Member, 
Subcommittee on Oversight of Government Management, the Federal 
Workforce, and the District of Columbia, Senate Committee on 
Governmental Affairs; the Chairman and Ranking Minority Member, House 
Committee on Government Reform; the Chairman and Ranking Minority 
Member, Subcommittee on Homeland Security, House Committee on 
Appropriations; the Chairman and Ranking Minority Member, Subcommittee 
on National Security, Emerging Threats, and International Relations, 
House Committee on Government Reform; and other interested 
congressional parties. We will also send copies to the Secretary of 
Homeland Security, the Under Secretary of Emergency Preparedness and 
Response and the Director of OPM. This report will also be available at 
no charge on the GAO Web site at [Hyperlink, http://www.gao.gov].

If you or your staff have any questions concerning this report, please 
contact me or William Doherty on (202) 512-6806. Key contributors to 
this report include Kevin J. Conway, Tiffany Tanner, Thomas Beall, Amy 
Choi, Amy Rosewarne, John Smale, and Michael Volpe.

Sincerely yours,

Signed by:

J. Christopher Mihm: 
Managing Director, Strategic Issues:

[End of section]

Appendixes: 

Appendix I: Objectives, Scope, and Methodology:

The objectives of this report were to:

* identify the human capital considerations that are relevant to 
federal agencies' continuity planning and implementation efforts;

* describe the continuity of operations (COOP) guidance provided by the 
Federal Emergency Management Agency (FEMA) and emergency preparedness 
guidance and activities of the Office of Personnel Management (OPM) to 
address human capital considerations relevant to COOP; and:

* describe the role Federal Executive Boards (FEB) play, relevant to 
COOP, in coordinating efforts outside of the Washington, D.C., area.

To address human capital considerations that are relevant to continuity 
planning and implementation efforts, we reviewed relevant literature, 
such as industry journals, federal guidance, and codes of standards on 
disaster/emergency management and continuity programs. Because the 
available literature was limited in its attention to human capital, we 
based our work primarily on semistructured interviews with experts from 
private sector businesses, federal government agencies, and public 
institutions. We first reviewed industry journals, magazines, and Web 
sites; queried state and international auditors; attended a national 
business continuity conference; and sought input from the National 
Academy of Public Administration (NAPA), the Private Sector Council 
(PSC), and FEMA to identify individuals or organizations with the 
relevant knowledge needed to address our first objective. We selected 
individuals or organizations that had one or more of the following 
characteristics: (1) experience responding to, recovering from, and 
resuming business activities following an emergency, from which human 
capital lessons may have been drawn; (2) experience incorporating human 
capital considerations into their organization's continuity planning 
efforts; (3) specific human capital expertise that could be applied to 
continuity planning and implementation efforts; and (4) specific 
continuity expertise that is broad enough to identify those critical 
areas that require human capital attention. When an organization was 
selected, we then contacted the organization to identify the specific 
individuals who had the relevant expertise.

On the basis of these characteristics and the input from NAPA, PSC, and 
FEMA, we selected organizations or individuals within organizations to 
obtain a diversity of views from both the public and private sector. 
Individuals from a total of 15 organizations, in addition to FEMA, 
provided their expertise in addressing our objective. The organizations 
include five federal agencies--the Centers for Disease Control and 
Prevention, the Department of Housing and Urban Development, the 
Department of Veterans Affairs, the General Services Administration, 
and the Social Security Administration; five private sector businesses-
-the Gillette Company, Lockheed Martin Corporation, Macy's West, Marsh 
& McLennan Companies, Inc., and Science Applications International 
Corporation; and five public institutions--the Business Continuity 
Institute, the Disaster Recovery Institute International, Emergency 
Management Alberta (Canada), Clark-Atlanta University, and the 
University of Tasmania (Australia).

We then conducted three cycles of work to identify the human capital 
considerations that are relevant to continuity, with each subsequent 
cycle building upon the information gathered in previous cycles. We 
adopted this approach because our initial conversations with experts 
indicated that a common perspective of the continuity process could 
help structure and focus our subsequent interviews with experts about 
the relevant human capital considerations. Cycle one involved 
conducting semistructured interviews with experts from FEMA and 5 of 
the 15 organizations.[Footnote 26] We asked each to describe a view of 
the entire continuity process from a human capital perspective. We used 
those descriptions to synthesize a framework that we then shared with 
each of the first cycle experts for comment. The experts generally 
agreed with the content of the framework and agreed that it would be 
useful in focusing subsequent interviews about human capital 
considerations. In the second cycle, we used this framework as a 
reference when conducting in-depth, semistructured interviews with 
experts from all 15 organizations and FEMA about the human capital 
considerations relevant to continuity. For the third cycle, we held a 
1-day working group, in cooperation with FEMA, to more fully discuss 
the human capital considerations previously identified in cycles one 
and two. The interactive nature of the working group,which included a 
cross-section of the experts and additional representatives from 
GAO,[Footnote 27] helped to ensure that we had adequately captured the 
key considerations relevant to continuity. As a final check, we 
provided all of the experts with a summary document that included the 
statements used throughout this report and attributed to the experts. 
We asked the experts to review the statements for fundamental 
disagreement or fatal flaws. Almost all experts responded and generally 
agreed with our treatment of these issues.

To supplement information we received in the three cycles, we held 
additional interviews with officials from OPM; representatives from the 
Chicago, Cleveland, and Philadelphia FEBs; and representatives from the 
National Treasury Employees Union (NTEU) and the American Federation of 
Government Employees (AFGE). We spoke with representatives of the FEBs 
because the FEBs' role as coordinative bodies in regions across the 
nation gives them a unique view of federal emergency preparedness 
efforts outside of the Washington, D.C., area. We spoke with 
representatives from NTEU and AFGE because unions can play a key role 
in addressing human capital considerations.

To describe the COOP guidance provided by FEMA and emergency 
preparedness guidance and activities of OPM to address human capital 
considerations relevant to COOP, we interviewed officials from both 
agencies. In addition, we reviewed and analyzed relevant documents. For 
example, we reviewed Federal Preparedness Circular 65, the primary 
guidance for federal executive branch COOP, to identify the human 
capital considerations that are included in federal COOP guidance. We 
also reviewed OPM publications, including four emergency preparedness 
guides and a series of memorandums that list available agency 
flexibilities in times of emergencies.

To describe the role FEBs play, relevant to COOP, in coordinating 
efforts outside of the Washington, D.C., area, we held interviews with 
officials from OPM with responsibility for FEBs nationwide and 
representatives from the three FEBs discussed above.

We conducted our work from February 2003 through December 2003 in 
accordance with generally accepted government auditing standards.

[End of section]

Appendix II: Emergency Human Capital Flexibilities Listed in OPM 
Emergency Memorandums:

OPM has issued a series of memorandums outlining the existing human 
resources management flexibilities that executive departments and 
agencies might employ in emergency situations with and without OPM 
approval.[Footnote 28] Other human capital flexibilities and programs, 
such as those detailed in OPM's handbook, Human Resources Flexibilities 
and Authorities in the Federal Government,[Footnote 29] that are 
available to agencies in nonemergency situations may also provide 
additional assistance in responding to and recovering from COOP 
emergencies. For additional information on these flexibilities, OPM has 
advised that agency chief human capital officers, human resources (HR) 
directors, or both should contact their assigned OPM human capital 
officer. Employees are advised to contact their agency HR offices for 
assistance.

A compilation of the emergency flexibilities outlined by OPM in its 
emergency guidance memorandums appears below.

Leave:

Excused Absence:

Agencies have the discretion, without OPM approval, to grant excused 
absence to employees who are prevented from reporting to work because 
of an emergency. The authority to grant excused absence also applies to 
employees who are needed for emergency law enforcement, relief, or 
recovery efforts authorized by federal, state, or local officials 
having appropriate jurisdiction and whose participation in such 
activities has been approved by the employing agency. Military leave 
under 5 U.S.C. § 6323(b) is appropriate for federal employee members of 
the National Guard or Reserves who are called up to assist in an 
emergency.[Footnote 30]

Emergency Leave Transfer Program:

Subject to approval by the President, OPM may establish an emergency 
leave transfer program, which is separate from the federal leave-
sharing program, to assist employees affected by an emergency or major 
disaster. Under 5 U.S.C. § 6391, the emergency leave transfer program 
would permit employees in an executive agency to donate unused annual 
leave for transfer to employees of the same or other agencies who have 
been adversely affected by an emergency and who need additional time 
off work without having to use their own paid leave. If agencies 
believe there is a need to establish an emergency leave transfer 
program to assist employees affected by an emergency, they are to 
contact their OPM human capital officer.

Pay:

Premium Pay for Employees Performing Emergency Overtime Work:

In certain emergency or mission-critical situations, agencies have the 
discretion, without OPM approval, to apply an annual premium pay cap 
instead of a biweekly premium pay cap, subject to the conditions set 
forth in 5 U.S.C. § 5547(b) and 5 C.F.R. § 550.106. In this regard, the 
agency head, his or her designee, or OPM may determine that an 
emergency exists. Agencies have the discretion, without OPM approval, 
to apply an annual cap to certain types of premium pay for any pay 
period for (1) employees performing work in connection with an 
emergency, including work performed in the aftermath of such an 
emergency, or (2) employees performing work critical to the mission of 
the agency. Such employees may receive premium pay under these 
conditions only to the extent that the aggregate of basic pay and 
premium pay for the calendar year does not exceed the greater of the 
annual rate for (1) General Schedule (GS)-15 step 10 (including any 
applicable special salary rate or locality rate of pay, or (2) level V 
of the Executive Schedule.

Furlough:

In some emergency situations, agencies have the discretion, without OPM 
approval, to furlough employees, that is, to place them in a temporary 
status without duties and pay for nondisciplinary reasons. Under 5 
C.F.R. § 752.404(d)(2), agencies are relieved of the requirement to 
provide employees advanced notice and an opportunity to respond when 
the furlough is based on "unforeseeable circumstances," such as a 
sudden breakdown in equipment, an act of nature, or a sudden emergency 
requiring the agency to immediately curtail activities.

Benefits:

Workers' Compensation Benefits:

Workers' compensation benefits are available when federal employees are 
injured or killed while on duty. The Department of Labor may establish 
special procedures to provide direct assistance to affected employees 
and their families.

Expedited Processing of Retirement and Life Insurance Benefits:

To assist agencies in responding to employee needs during and after an 
emergency situation, OPM may establish special expedited arrangements 
for processing disability retirement applications; survivor benefits; 
and payments under the Federal Employees Group Life Insurance Program, 
currently administered by the Metropolitan Life Insurance Company.

Death Gratuity:

Under Section 651 of Pub. L. No. 104-208 (Omnibus Consolidated 
Appropriations Act, 1997), 5 U.S.C. § 8133 note, agencies have the 
authority, without OPM approval, to pay up to $10,000 to the personal 
representative of a civilian employee who dies in the line of duty.

Telework:

Agencies have the discretion, without OPM approval, to approve 
telecommuting arrangements and alternative work sites to accommodate 
emergency situations. According to OPM, one of the major benefits of 
the telework program is the ability of telework employees to continue 
working at their alternative work sites during a disruption to 
operations. In recognition of the growing importance of teleworkers in 
the continuity of agency operations, OPM states that agencies may wish 
to modify their current policies concerning teleworkers and emergency 
closures. Agencies may also wish to require that some or all of their 
teleworkers continue to work at their alternative work sites on their 
telework day during emergency situations when the agency is closed. 
Although agencies would not have to designate a teleworker as an 
emergency employee, OPM states that any requirement that a telework 
employee continue to work if the agency closes on his or her telework 
day should be included in the employee's formal or informal telework 
agreement.

Emergency Hiring Flexibilities:

Emergency Critical Hiring:

Under 5 C.F.R. § 213.3102(i)(2), agencies have the discretion, without 
OPM approval, to fill positions for which an emergency or critical 
hiring need exists; however, initial excepted appointments under this 
authority may not exceed 30 days and may be extended only for an 
additional 30 days. Such an extension may be made only if the 
appointee's continued employment would be essential to the agency's 
operations.

Under 5 C.F.R. § 213.3102(i)(3), OPM may also grant agencies the 
authority to temporarily appoint individuals to the excepted service in 
positions for which OPM has determined that examination is 
impracticable (e.g., because of the time involved). For example, in the 
aftermath of the September 11, 2001, attacks, OPM granted agencies 
authority to fill positions affected by or that needed to deal with the 
attacks for up to 1 year, and later extended that authority.

When OPM grants agencies the authority to appoint individuals under 5 
C.F.R. § 213.3102, agencies, not OPM, are responsible for establishing 
the qualifications that an individual must have to fill the position. 
In addition, in accordance with 5 C.F.R. pt. 330, agencies are not 
required to comply with the regulations regarding the Career Transition 
Assistance Plan (CTAP), Reemployment Priority List (RPL), and 
Interagency CTAP (ICTAP) because these regulations do not apply to 
excepted appointments.

Agencies have the discretion, without OPM approval, to use the 
authority granted by OPM under 5 C.F.R. § 213.3102 to fill senior-level 
positions, as well as positions at lower levels. Under appropriate 
circumstances, OPM may also authorize agencies to use a senior-level 
position allocation to appoint an individual under this section (5 
C.F.R. § 319.104).

Direct-Hire Authority:

Agencies have the authority to appoint candidates directly when OPM 
determines there is a critical hiring need, or a shortage of 
candidates, for particular occupations, grades (or equivalent), 
geographic locations, or some combination of the three. This authority 
can be governmentwide or limited to one or more specific agencies 
depending on the circumstances.

OPM has granted governmentwide direct-hire authority for GS-0602 
Medical Officers, GS-0610 and GS-0620 Nurses, GS-0647 Diagnostic 
Radiologic Technicians, and GS-0660 Pharmacists, at all grade levels 
and all locations, and for GS-2210 Information Technology Specialists 
(Information Security) positions at GS-9 and above, at all locations, 
in support of governmentwide efforts to carry out the requirements of 
the Government Information Security Reform Act and the 
Federal Information Security Management Act. OPM also approved a 
direct-hire authority that permits agencies to immediately appoint 
individuals with fluency in Arabic or other Middle Eastern languages to 
positions in support of the reconstruction efforts in Iraq.

Agencies have the discretion, without OPM approval, to give individuals 
in the categories, occupations and specialties, and grades listed above 
competitive service career, career-conditional, term, temporary, 
emergency indefinite, or overseas limited appointments, as appropriate. 
In all cases, agencies must adhere to public notice requirements in 
5 U.S.C. §§ 3327 and 3330 and ICTAP requirements.

If agencies believe they have one or more occupations for which an 
agency-specific direct-hire authority may be appropriate in support of 
emergency relief and recovery efforts, they are to contact their OPM 
human capital officer.

Senior Executive Service Limited Emergency Appointments:

To meet a bona fide, unanticipated, urgent need, agencies have the 
authority under 5 C.F.R. § 317.601 to make Senior Executive Service 
limited emergency appointments of career employees, without OPM 
approval. OPM approval is required to appoint individuals who are not 
current career employees and OPM cannot delegate this authority; 
however, OPM will process such requests on a priority basis and will 
also consider temporary position allocations for agencies that identify 
the need as essential to deal with the emergency.

Reemploying Retirees:

Agencies have the discretion, without OPM approval, to employ retirees 
to deal with an emergency, to replace employees called to active duty 
military service, or both. Agencies may immediately offer reemployment 
to retirees under any applicable appointing authority. However, 
generally, dual compensation restrictions (e.g., 5 U.S.C. §§ 8344 and 
8468) require agencies to reduce the pay of a federal civil service 
retiree by the amount of his or her annuity. For details, see the CSRS 
and FERS Handbook for Personnel and Payroll Offices, Chapter 100 - 
Reemployed Annuitants.

OPM may waive these dual compensation restrictions and, upon request, 
may also delegate such authority to an agency head or designee to deal 
with emergency staffing requirements. See 5 C.F.R. pt. 553 for details. 
Dual compensation waivers cannot be approved retroactively. However, 
according to OPM guidance, annuitants who agree to work under salary 
offset pending a dual compensation waiver may be recognized for their 
special service by the agency through an individual cash award.

Reemploying Voluntary Separation Incentive Payment Recipients:

Ordinarily, employees who resign or retire upon acceptance of a 
voluntary separation incentive payment (VSIP) (or buyout) can be 
reemployed only if they agree to repay the amount of that payment. 
However, upon agency's request, OPM may waive the repayment requirement 
if the individual's reemployment is necessary to deal with the 
emergency situation. (See 5 C.F.R. § 576.203(a)(1).) Persons being 
considered for VSIP repayment waivers must be the only qualified 
applicants available for the positions and possess expertise and 
special qualifications to replace persons lost or otherwise 
unavailable. Waivers may be limited by the agency's specific statutory 
VSIP authority.

Other Emergency Hiring Flexibilities:

Under 5 C.F.R. pt. 300, subpart E, agencies have the discretion, 
without OPM approval, to contract with private sector temporary 
employment firms for services to meet their emergency staffing needs. 
These contracts may be for 120 days and may be extended for an 
additional 120 days, subject to displaced employee procedures.

Agencies have the discretion, without OPM approval, to make competitive 
service appointments of 120 days or less without regard to CTAP, ICTAP, 
or RPL eligibles. These programs do not apply to such appointments. See 
5 C.F.R., pt. 330, Subparts F and G for CTAP/ICTAP conditions and 5 
C.F.R. § 330.207(d) for RPL conditions.

Agencies have the discretion, without OPM approval, to appoint current 
and former employees from RPL to temporary, term, or permanent 
competitive service appointments. Conversely, agencies may make 
exceptions to the RPL provisions to appoint others under 5 C.F.R. 
330.207(d).

[End of section]

Appendix III: Comments from the Federal Emergency Management Agency:

Office of the Under Secretary:

U.S. Department of Homeland Security 
500 C Strect, SW:

Washington, DC 20472:

FEMA:

April 1, 2004:

Mr. J. Christopher Mihm 
Managing Director 
Strategic Issues, 
General Accounting Office 
441 G Street, N.W.
Washington, D.C. 20548:

Dear Mr. Mihm:

We have reviewed the draft report number GAO-04-384 titled "Human 
Capital - Opportunities to Improve Federal Continuity and Planning 
Guidance." We appreciate the opportunity to work with the General 
Accounting Office (GAO) during the report's preparation and wish to 
thank them for their hard work. We believe that the final draft 
accurately addresses human capital considerations relevant to COOP 
guidance and coordination.

The Department of Homeland Security and Federal Emergency Management 
Agency will continue to work jointly with the Office of Personnel 
Management and our other Federal partners to improve the Federal 
Government's COOP program by incorporating GAO recommendations in our 
COOP guidance. Further, we will continue to expand our efforts with our 
Regional Offices and the Federal Executive Boards to improve 
coordination of COOP program efforts at the regional level.

If additional information is needed, please contact Mr. Reynold N. 
Hoover, Director, Office of National Security Coordination at 202-646-
4145.

Sincerely,

Signed by: 

Michael D. Brown: 
Under Secretary Emergency Preparedness and Response:

cc:

Tom Ridge, Secretary, DHS:

Admiral James Loy, Deputy Secretary, DHS 
Duncan Campbell, Chief of Staff, DHS: 

[End of section]

Appendix IV: Comments from the Office of Personnel Management:

OFFICE OF THE DIRECTOR:

UNITED STATES OFFICE OF PERSONNEL MANAGEMENT 
WASHINGTON, DC 20415-0001:

APR 01 2004:

Mr. J. Christopher Mihm:

Managing Director, Strategic Issues 
United States General Accounting Office 
441 G Street, NW.
Washington, DC 20548:

Dear Mr. Mihm:

Thank you for the opportunity for the Office of Personnel Management 
(OPM) to review and comment on the General Accounting Office's (GAO) 
draft report, HUMAN CAPITAL: Opportunities to Improve Federal 
Continuity Planning Guidance (GAO-04-384). We appreciate GAO's 
continued support and this report's acknowledgement of our leadership 
role and our accomplishments in addressing human capital considerations 
relevant to planning for continuity of operations (COOP).

In the past several years, the necessity for the Federal Government to 
be prepared to operate during crisis situations has intensified. 
Agencies have dealt with emergencies ranging from bad weather, like 
hurricanes and snowstorms, to the tragic, unexpected terrorist attacks. 
OPM, in sharing a leadership role with the Federal Emergency Management 
Agency (FEMA) and the General Services Administration (GSA), has made 
it a priority to ensure agencies have the guidance and training 
necessary to plan for such situations.

While the report gives OPM high marks in the area of emergency 
preparedness education and issues directly related to COOP, it points 
out discrepancies and shortcomings in other areas. The primary 
criticism leveled at OPM (and FEMA) is that neither agency has issued 
guidance adequately addressing human capital considerations related to 
the resumption of broader agency operations after an emergency. We 
respectfully disagree and provide the following examples of what OPM 
has done to support this effort:

* We issued a series of Emergency Preparedness Guides for Federal 
managers, employees and their families. The guides are available on the 
OPM Web site. * We issued memorandums at the time of emergencies, such 
as Hurricane Isabel and the California wildfires, to provide agencies 
with flexibilitics available for managing their workforce during crisis 
situations.

* We approved the immediate use of additional flexibilities in response 
to the 9/11 national emergency, such as emergency temporary 
appointments under Schedule A, Senior Executive Service limited 
emergency appointments, salary offset waivers to reemploy annuitants, 
and Voluntary Separation Incentive Pay (buyout) repayment waivers.

* We issued two annual emergency preparedness surveys to agencies. OPM's 
Human Capital Officers then contacted agencies to discuss all items 
indicated as not yet completed.

* We established policy regarding teleworking opportunities and benefits 
for planned use during closures. OPM and GSA jointly established a 
telework website to provide access to guidance issued by both of our 
agencies.

* We hosted Emergency Planning and Preparedness Forums to address each 
agency's authorities upon closure of the Federal Government in 
emergency situations. The forums focused on available flexibilities, 
designating emergency personnel, transportation and communications 
issues, along with providing time for agencies to share their best 
practices. More than 250 employees from over 75 agencies attended the 
forums.

* We identified, in concert with the Chief Human Capital Officers 
Council, emergency preparedness as one of five key areas critical to 
the success of the strategic management of human capital and have 
established the Subcommittee on Emergency Preparedness. The 
subcommittee is tasked with recommending policy changes, needed 
legislation, and other strategies necessary to move issues forward.

One of the primary concerns noted in the GAO report is the resumption 
of all agency services, not just essential services, in the wake of an 
emergency. This year, OPM's annual survey for emergency preparedness 
included questions relating to telework employees. In addition, OPM 
issued memorandums to heads of departments and agencies strongly 
encouraging telework options as part of their emergency preparedness 
procedures. Planned use of telework during a crisis situation will help 
address this issue raised in the GAO report.

Two specific actions are recommended for the OPM Director (page 28). 
The first recommendation is to more fully address human capital 
considerations by incorporating the six key organizational actions 
identified in the report. OPM's framework for human capital, developed 
in collaboration with GAO, incorporates the six organizational actions 
to enhance continuity efforts. The framework provides the context for 
our discussions with agencies on human capital, which includes guidance 
on emergency preparedness. It is our contention that not only is this 
recommendation currently being carried out but has, in fact, been in 
place since September 11tH. Provided as an enclosure is a point-by-
point demonstration of measures OPM has taken internally under each of 
the six organizational actions. The enclosure will provide agencies 
with an example of how OPM has implemented certain COOP initiatives.

The second recommendation for the OPM Director is to determine the 
desired role for the Federal Executive Boards (FEBs) to play in 
improving coordination of emergency preparedness efforts, including 
COOP, and identify and address FEB capacity issues to meet that role. 
We note that overall the report has captured the essence of the 
activities undertaken by OPM. However, we believe the leadership role 
played by OPM, particularly with respect to the FEBs is not 
sufficiently developed in the report.

Specifically, on pages 23 and 24 of the draft report, the discussion of 
OPM's leadership role should be broadened to include what it has done 
to transform the role of the FEBs, particularly in the post-9/11 
environment. For example, OPM has developed communications protocols 
for emergency preparedness operations for a variety of circumstances, 
such as natural disasters, national security operations, and other 
unforeseen events that may cause interruptions to the normal course of 
operations.

Additionally, on page 25 of the draft report, in discussing the role of 
the FEBs, it should be noted that OPM's leadership role has included 
expanding its annual FEB training program to cover emergency 
preparedness, employee security, and continuity of operations. OPM has 
facilitated teleconferences between FEMA and FEBs, and has worked to 
enhance the role of FEBs in the continuity of operations planning 
process.

Currently, OPM is working with FEMA to provide the FEBs the technical 
assistance and staffing they need to build full capacity in this area. 
A pilot project with key FEBs is slated to begin this summer.

We recommend the following changes to wording of the draft report:

1. Page 25, footnote - The footnote that references Federal Executive 
Associations/Councils (FEA/Cs) is poorly worded, and may create 
unrealistic expectations that FEA/Cs can assume the same role as FEBs 
in COOP/emergency situations. FEA/Cs are not officially established 
bodies. They rely on volunteer members. OPM maintains a listing of the 
FEA/Cs to have a point-of-contact for those Federal communities; 
however, we do not have official oversight responsibility for FEA/Cs. 
They do not have permanent status and often disband and regroup 
depending on the local commitment of agency members.

Recommendations:

* Strike the footnote; or:

* Reword the footnote to read: "While this section focuses on FEBs, we 
recognize the presence of Federal Executive Associations (FEAs) and 
Federal Executive Councils (FECs) in cities where FEBs do not exist. 
FEAs and FECs have purposes and objectives similar to FEBs although 
they do not function within the same formal set of parameters (e.g., 
officially established by Presidential Memorandum, policy direction and 
guidance from the Office of Personnel Management, etc.) as do the FEBs. 
FEAs and FECs do not have permanent status and, therefore, are not 
currently a viable option for a role in COOP.":

2. Page 26, 2nd paragraph, last sentence - The report states that OPM 
"has established an internal working group to study the strengths and 
weaknesses of FEBs and develop recommendations for improving the FEB s' 
capacity to coordinate in regions outside Washington, D.C.":

Recommendation: Reword to "OPM has established an internal working 
group to improve the FEBs' capacity to support local emergency 
preparedness and response. Such efforts include:

* Improving dissemination of information, facilitation of COOP training 
and tabletop exercises;

* Addressing the implications for strategic Human Capital management in 
the continuing the operations of the Federal Government (e.g., 
alternate work schedules, remote work sites, and telecommuting 
capabilities); and * Developing strategies to better leverage the 
network of FEBs to help departments and agencies implement their 
initiatives.":

3. Page 38, Direct-Hire Authority-Missing from this section is the 
reference of two additional Governmentwide direct-hire authorities.

On June 20, 2003, OPM approved a direct-hire authority for Nurses in 
both the GS-0610 and GS-0620 series. The GS-0620 direct-hire authority 
was omitted from the report and should be added.

On July 01, 2003, OPM approved a direct-hire authority in support of 
the Administration's critical reconstruction efforts in Iraq. This 
direct-hire authority permits agencies to immediately appoint 
individuals with fluency in Arabic or other related Middle Eastern 
languages to positions in support of those reconstruction efforts.

OPM looks forward to receiving GAO's final report on improving Federal 
continuity planning guidance and we will continue with our commitment 
to assist agencies with emergency planning and preparedness.

Sincerely,

Signed by: 

Kay Coles James: 
Director:

Enclosure:

The following is a point-by-point demonstration of what the Office of 
Personnel Management(OPM), through guidance from the Director, has 
accomplished under each of the six key organizational actions 
identified in the General Accounting Office's (GAO) draft report, HUMAN 
CAPITAL: Opportunities to Improve Federal Continuity Planning Guidance 
(GAO-o4-384).

(A) DEMONSTRATE TOP LEADERSHIP COMMITMENT (P. to of Draft Rpt):

* Instill an approach to continuity planning that includes human 
capital considerations:

The paragraph explaining this bullet point reads in part, "...in 
providing leadership prior to an emergency, leaders demonstrate their 
commitment to human capital by establishing plans that value the 
organization's intention to manage employees with sensitivity to their 
individual circumstances...":

It is very clear that the OPM Director has incorporated this point in 
her overall management philosophy as it pertains to individual 
employees. There are several examples:

1) The following two paragraphs are lifted verbatim from OPM's report 
to the 9-11 Commission. The passage reflects what was utmost on the OPM 
Director's mind in the midst of horrific chaos on the morning of 
September 11, 2001:

"OPM Associate Directors and heads of offices began reporting their 
emergency contingencies to the Office of the Director as calls from 
other Departments across government began filtering in through an 
increasingly overloaded phone system. Within minutes of the Pentagon 
attacks, streets in downtown Washington, DC were becoming gridlocked. 
Multiple large agencies called OPM to either request or inform the 
Director of their decisions to let their workforce leave early. Looking 
down on the clogged streets from her 5TH floor office, the Director knew 
that with all the uncertainties of that fateful hour, staying inside 
might be the safest course of action for some Federal employees. She 
also recognized that thousands of workers in the Federal Government 
likely had children in day care facilities or had panicked children and 
loved ones in the surrounding suburbs and there was no way those 
individuals were going to remain at work.

At 9:50 am, Director James huddled with her core senior staff and asked 
for recommendations and thoughts. Questions from representatives of the 
Washington, DC press corps were already streaming in and in fact, 
several reporters were in the OPM complex requesting interviews. At 
9:58 am ...16 minutes after the attack on the Pentagon, Director James 
made the decision to close Federal offices in the Washington, DC area 
with the caveat that Federal employees may leave but no one was being 
forced out of their building into the growing gridlock and confusion in 
the DC streets.

2) When Hurricane Isabel was bearing down on the Washington, DC 
metropolitan area in mid September 2003, ominous weather reports and 
the subsequent closure of the regional subway system forced the OPM 
Director to close Federal offices. Here is a paragraph from the 
Director's official announcement that was disseminated to Federal 
employees and media outlets in the region,

"In an abundance of caution for the safety and security of Federal 
employees and in light of the disruptions of major transportation and 
power systems in the region, Federal agencies in the Washington DC area 
will remain closed on September 19th. The OPM Director realizes that 
there will be Federal employees who will not be impacted by the storm 
and she encourages these members:

of the Federal family to demonstrate the spirit of community that they 
have exhibited so many times in the past and assist their neighbors or 
others who might be in need.":

3) During significant fires, flooding, hurricanes and earthquakes 
anywhere in the nation, the OPM Director issues guidance to Federal 
agencies as it pertains to leave and benefits to their Federal 
employees who have been adversely impacted by the event. OPM has also 
marshaled its resources to assist in transferring emergency responders 
from one Federal agency to another in order to meet developing crises. 
This authority was last used during the late summer of 2003, when 30 
massive fires were blazing in 11 States.

4) The Director of OPM has maintained a consistent policy of ensuring 
open communication with the staff of this agency. It is her belief that 
in order to build trust with employees, they need to be kept fully 
aware of incidents that could adversely impact their safety and well 
being. Her belief is that the stronger the trust factor the better 
chance that employees will listen and cooperate if there is a 
potentially life threatening emergency where rapid response is needed. 
There are numerous instances where this has been carried out, notably 
in the time period between October 2001 - May 2002, during concerns of 
anthrax in Washington, DC mailrooms. Appendix "A" contains a sampling 
of agency wide memorandums from the Director, which kept employees 
aware of her efforts to ensure the protection of the OPM workforce. It 
should be noted that these memos are only from the Director. She 
directed many other "all employee" communications to be carried out by 
pertinent senior staff as well. The documents focus on three separate 
incidents:

1. The Director's response to anthrax concerns in general throughout 
Washington, DC area and the closure of Brentwood Postal Facility in 
late October, 2001.

2. Regular sampling tests taken in the OPM mailroom indicated the 
possibility of a trace amount of anthrax present. January 2002. 3. In 
May of 2002, regular mailroom testing turned up a single anthrax spore.

Similar communication efforts have been replicated during the recent 
risin scare and during an isolated asbestos concern in the OPM 
headquarters building. Keeping employees aware not only limits the 
spread of rumors and unreliable information but it demonstrates 
sensitivity to employee concerns at a time of elevated vigilance in our 
nation's capital. In all instances, immediate contact was also made 
with the employee unions. They have been very instrumental in helping 
make sure that employees are kept fully informed.

* Allocate resources and setpolicies (P. u of Draft Report):

This OPM Director has made a firm commitment to allocate the necessary 
resources to maintain a secure environment for the employees at OPM. 
While discussing the amount of monies appropriated and specific 
protective systems developed would be counter-productive in a public 
report, suffice to say advancements have been substantial. We would be 
happy to discuss this information privately with investigators from GAO 
at a place and time of your choosing. There are a number of steps taken 
that can be discussed. They include:

1. Mylar coating on all windows in the OPM headquarters facility aimed 
at cutting down on flying glass in the event of a nearby explosion.

2. Installation of a new PA and emergency alert system in the OPM 
headquarters. This system, complete with visual notification for the 
deaf and hard of hearing has been tested and is in operation.

3. Special training and accommodation has been made for those who are 
disabled and require special assistance in an emergency.

4. The Director ordered and received a completely updated Emergency 
Occupant Plan (EOP) for the OPM headquarters building.

5. Each employee was given emergency evacuation instructions on a 
laminated card, sized to fit alongside their agency ID badge on their 
lanyard. Examples of this have been shared on numerous occasions with 
security and communication specialists throughout the Government.

6. Teleconferencing capability has been readied between several 
locations in the OPM headquarters building and our COOP sites in 
Pennsylvania and Virginia.

In addition to allocating resources directly benefiting OPM, this 
Director used OPM funding to research, create and publish four 
Emergency Preparedness Guides, designed for Federal employees and their 
families both in the DC metro area and beyond. This fact is mentioned 
elsewhere in the draft GAO report. We are pleased to report that as of 
this date nearly 500,000 of the guides have been:

distributed. OPM gathered emergency preparedness leaders from 16 
governmental agencies to contribute their expertise to the development 
of the guides.

Set direction and pace of recovery (Page 11 of Draft Report):

No event in recent memory has tested the resolve and actions of our 
nation's most senior leadership more so than 9-11 The OPM Director's 
major decision on that day was to set the direction for the operating 
status of the Federal Government for September 12th Her unwavering 
belief was that the Nation's Government needed to demonstrate to our 
citizenry and governments world wide that America was "open for 
business" on 12 September and the United States would not cower at the 
hands of terrorists. Her recommendation was met with total support from 
the White House. She indeed demonstrated the ability to "set direction 
and pace of recovery," when America needed it most.

Among other emergency authorities the Director immediately delegated to 
agencies was the authority to approve dual compensation waivers to 
execute rapid pace emergency, cleanup, and security teams at the agency 
level.

(B) SEEK OPPORTUNITIES FOR SYNERGY (Page 12 of Draft Report):

Consider how continuity investments benefit other program efforts:

We will respond to this point by an answer based on the example you 
provided of how GAO addressed this bullet point by providing GAO 
employees with laptop computers which enabled them to work from 
alternate locations, consequently clearing space for some Congressional 
offices, displaced by anthrax concerns, to temporarily occupy. The 
Director of OPM exhibited foresight, in our particular building, by 
ordering a build-out of excess space in the subbasement of the OPM 
headquarters. This area can accommodate about 45-5o people. The work 
areas are complete with computers, phones and office supplies. This 
space has been made available to Congressional offices and even used 
recently by a Senatorial Committee that used the area and facilities to 
make final preparations for a Congressional hearing. Consequently, OPM 
has garnered its resources and made them available to teammates 
Governmentwide. The space can also be utilized by any office within OPM 
that is temporarily displaced for any reason (i.e., carpet replacement, 
electrical work, etc.).

(C) MAINTAIN EFFECTIVE COMMUNICATION (Page 13 of Draft Report):

Build relationships through 2-way communication:

This aspect of the OPM Director's philosophy of making sure employees 
remain aware of circumstances has been fully addressed in a previous 
answer. We want to take a moment here and comment on the way the OPM 
Director approached communicating and working with labor unions and 
other employee organizations 
as it pertains to the development of the new personnel system at the 
Department of Homeland Security.

Working together, DHS and OPM developed and conducted a comprehensive 
and inclusive process for creating a new HR system for DHS. A key 
element of the process was the creation of a Design Team. This team, 
comprising of 8o DHS employees, supervisors, union representatives, and 
OPM staff, compiled an extensive collection of innovative and 
successful HR practices and developed a range of options for the new 
system. The options were developed after 64 nationwide Focus Groups and 
Town Hall meetings were conducted to gain input from employees in all 
major DHS components. Also during the options development stage, over 
65 public and private sector organizations and HR experts were 
contacted. The options for the new system were then reviewed by a 
Senior Review Committee (SRC), made up of DHS and OPM officials and the 
presidents of DHS' three largest unions (AFGE, NTEU, NAAE).

Emergency protocols have been established to provide immediate contact 
within and between all levels of DHS/GSA/OPM/FEMA. Ongoing tests ensure 
seamless communications with White House leadership and OPM/DHS.

Establish roles, responsibilities and expectations:

The OPM Director fully concurs with others who believe that 
communicating performance expectations to employees prior to disruption 
promotes a more efficient outcome and management of human capital 
assets. To that end, the Director of OPM has done the following:

1. Overseen and participated in a number of emergency tabletop 
exercises with her most senior staff. On one occasion, she has ordered 
herself "removed" and turned OPM's response over to the Deputy 
Director. In another instance both the Director and Deputy Director 
were taken out of the picture and the next person following in 
succession ran the operation.

2. Met with the nine people in the official line of succession to go 
over and discuss actions and responsibilities should she no longer be 
able to carry out the duties of OPM Director.

3. Ensured that each major program office in OPM provided in hard copy 
and backed up on CD-ROM (filed away in three separate locations across 
the nation) the actions that directorates would take in the event that 
the senior leadership of the directorate were incapacitated or 
unavailable for whatever reason. Information has been distributed to 
multiple remote OPM COOP locations that are maintained at near constant 
readiness levels. Contained in the material are draft policy 
statements, intergovernmental guidance and draft Executive Orders 
covering any eventuality ranging from emergency hiring authority to 
the 
maintenance of retirement and health benefits for Federal workers to 
continuation of the national security background investigation process. 
4. Ordered and participated in tabletop exercises and educational 
sessions with the second and third tier leadership within OPM to 
familiarize them with the duties and responsibilities should the most 
senior leadership not be available.

* Develop redundant communication vehicles:

The OPM Director has provided the 100 highest ranking senior managers 
at OPM redundant means of emergency communication technology and each 
carries it 24/7. Those means of communication are NEXTEL phone, 
Blackberry and national pager. The 30 most senior advisors are also 
equipped with satellite phones and have access to the GETS (Government 
Emergency Telecommunications Service) system in the event of an 
emergency. Communication tests are administered frequently whereby each 
manager is required to phone into the OPM Situation Room upon receipt 
of request.

In regards to mainframe computer servers, again we do not want to 
provide any specifics in an open forum as to how the critical 
information on Federal employees is maintained by OPM but we can say 
that numerous safeguards and redundancies are built into the system and 
can be controlled from various locations across the United States 
(including one location that has been termed "one of the ten safest 
places in the world"). In addition, should OPM suffer a catastrophic 
loss of its mainframe, program managers have been instructed to 
physically transfer to an undisclosed location and, with redundant 
backups in different places nationwide, can reconstruct the data that 
has been compromised.

(D) TARGET INVESTMENTS IN TRAINING AND DEVELOPMENT (Page 14 of Draft 
Report):

Raise awareness of continuity efforts:

Over the past two and one half years, OPM has completely revamped its 
COOP process. Personnel who would be deployed have received significant 
information regarding their duties and responsibilities. Several 
meetings have included all those who would relocate and at these 
meetings COOP manuals were distributed that explains OPM's critical 
functions and the means that will be used to ensure that they are 
carried out in an emergency. A number of tests involving OPM's "Go-
Teams" have been made. "Go-Teams" are comprised of 6-8 senior OPM 
officials, who at the first sign of trouble immediately exit the city 
before traffic becomes log-jammed. Their orders are to head immediately 
to the OPM COOP relocation site. These individuals have the experience 
and authority to make decisions relative to OPM's mission until the 
Director and her aides arrive. This concept has also been tested and 
fueled vehicles, cash, and packed suitcases are on the ready if needed.

Build skills and competencies to increase flexibility (P. 14 of Draft 
Report):

OPM is unique in the sense that large numbers of our employees and the 
technology required to fulfill our critical missions are carried out 
away from Washington, DC and in intensely secure areas. For example, 
our COOP relocation site will have an additional 750-800 employees 
already there and that workforce can be tapped to cover any eventuality 
or need. Another facet of this flexibility is in the area of succession 
planning, and that has already been discussed previously.

(E) LEVERAGE THE FLEXIBILITY OF HUMAN CAPITAL:

* Enable employees associated with resumption activities to contribute 
to mission-results in alternate assignments:

The explanatory paragraph in the draft GAO report reads, 
"...organizations may use approaches such as telework and geographic 
dispersion, which includes regional structure, to increase the ways in 
which employees may contribute." The next line in the draft report 
points out OPM's guidance by way of symposiums and conferences held for 
Government officials which educate about and promote telework as a 
viable means of mission critical operations. The Director and her 
senior staff lead by example by teleworking at least one day per month.

OPM has sponsored an ongoing number of initiatives to promote telework 
to the agencies. Some of the more recent include the all-day November 
4th Training Event in 2003, to which agency HR Directors and telework 
coordinators were invited, and given telework kits. Government telework 
coordinators heard some of the major pioneers and leaders in the field 
discuss the advantages of telework. One featured speaker was 
internationally known telework expert Gil Gordon. Since the training, 
we have distributed 250 telework kits to requesting agencies. We are 
currently making additional kits available to agencies as well as 
Capitol Hill offices through the Government Printing Office. In 
September of 2003, the ITAC (International Telework Association and 
Conference) conference in Baltimore for Federal Telework Coordinators 
was co-sponsored by OPM and GSA.

Following are the most recent major events in 2004 that OPM has 
spearheaded:

Jan 04--Telework "WEB" inar featuring OPM and GSA speakers and Gil 
Gordon:

Feb 04--Quarterly Telework Coordinators Meeting:

Two Emergency Preparedness Meetings--OPM and GSA speakers on the 
importance of telework as a part of a COOP Plan:

March ii--OPM and GSA Speakers at DEA meeting of COOP planners:

February 23 and 24--Alliance of Work/Life Progress (AWLP) conference in 
Phoenix--two special Federal Sessions featuring Telework presentations 
by OPM representative, Ms. Abby Block:

Quarterly senior-level telework meetings with GSA (November, February, 
May, etc.):

Planned upcoming near-term events pertaining to telework:

Upcoming: Launch of two Telework e-training modules (Telework 101 for 
Managers, Telework 101 for Directors) for Federal employees on 
www.GoLearn:

May 5--Webinar to introduce two e-training modules (Telework 101 for 
Managers, Telework 101 for Directors) on OPM's GoLearn directed at 
agency telework coordinators so coordinators can have "hands-on" 
training in getting to and promoting the courses:

April 29--OPM coordinators will provide the keynote address on telework 
at the Mid Atlantic Intergovernmental Audit Forum for IGs (sponsored by 
GAO):

Development of training modules for supervisors, managers and senior 
agency officials to be taught at OPM, GSA,USDA and other courses:

A second point was made in the draft report (p.17) suggesting the 
importance of geographically spreading out an agency's operations. OPM 
as an organization, already possesses wide geographic dispersion. Field 
offices and major facilities exist in Pennsylvania, Virginia, Georgia, 
Colorado and West Virginia. OPM's critical missions can be carried out 
completely without a single person physically housed in Washington, DC.

Sustain the contribution of employees associated with essential 
operations:

This is an excellent point and one that should challenge every agency 
or department. "Safety and emergency planning" is an element in all of 
OPM's senior executive service members' performance plans. As 
previously stated, the OPM Director has identified the most senior 100 
managers at OPM who will be called upon in the event of an emergency. 
This list of managers generally goes three or four deep in each of our 
seven major program offices. The Director has built enough redundancy 
in her agency planning to allow for rotation of duties in the event of 
an extended stay at the COOP relocation site. Keep in mind also, there 
are already 75o-800 OPM employees at the COOP location and they can be 
utilized as needed.

* Maintain organizational knowledge of staffing requirements and 
availability:

This point made in the draft report (p.18) focuses on the need for 
agencies to establish some means of adding to its existing staff or 
replenishing staff in the:

event of a catastrophic incident. OPM, as the United States 
Government's human resources agency, already maintains vast up-to-date 
information on positions available, KSA criteria and interagency 
partnerships that could be utilized immediately. Please keep in mind 
also, that just after 9-11 it was OPM that devised and administered a 
program called Patriot, (not to be confused with the Patriot Act) that 
matched the talents of retired Federal employees who wanted to 
volunteer their abilities, to agencies that needed their particular 
skill.

(F) BUILD PROCESS TO IDENTIFY AND SHARE LESSONS (p. 19 of Draft 
Report):

* Create a learning environment:

* Make learning explicit and shared:

Like most agencies, OPM does conduct "hot wash" debriefings after each 
tabletop exercise and after each major event that causes disruption in 
the District of Columbia (Tractor Man, large weather events, World Bank 
and IMF demonstrations, etc.). In many instances, these debriefs are 
conducted with other agencies and officials from the District of 
Columbia and neighboring municipalities. It is our belief that more can 
be done in the area of sharing learning experiences. This is an area 
that we will study and will report back to you on advances made. 

[End of section]

(450177):

FOOTNOTES

[1] The House Committee on Government Reform also asked us to review 
agency headquarters COOP plans. We reported on that review in U.S. 
General Accounting Office, Continuity of Operations: Improved Planning 
Needed to Ensure Delivery of Essential Services, GAO-04-160 
(Washington, D.C.: Feb. 27, 2004). 

[2] In March 2003, FEMA became a part of the Department of Homeland 
Security within the Directorate of Emergency Preparedness and Response. 


[3] U.S. Federal Emergency Management Agency, Federal Preparedness 
Circular 65 (Washington, D.C: July 26, 1999), 2.

[4] See PDD 62, Protection Against Unconventional Threats to the 
Homeland and Americans Overseas, dated May 22, 1998; PDD 63, Critical 
Infrastructure Protection (CIP), dated May 22, 1998, which has been 
superseded by Homeland Security Presidential Directive 7, Critical 
Infrastructure Identification, Prioritization, and Protection, dated 
December 17, 2003; and PDD 67, Enduring Constitutional Government and 
Continuity of Operations, dated October 21, 1998.

[5] As the lead agency for federal OEP efforts, GSA issued the Occupant 
Emergency Program Guide in March 2002. This guidance defines an 
occupant emergency, details the roles of GSA and individual agencies 
with regard to OEP, and provides step-by-step guidance for agencies to 
use in carrying out their responsibilities for the program. An occupant 
emergency is defined as an event that may require evacuation of 
occupied space or relocation to a safer area. Under OEP, agencies are 
required to establish an occupancy emergency plan designated official, 
an occupancy emergency plan, and an occupancy emergency organization. 
GSA's responsibilities include helping agencies to establish and 
maintain the plans and organizations, offering policy guidance about 
the program, ensuring proper administration of the program, reviewing 
agencies' plans and organizations annually, and helping to train 
employees and others for emergencies.

[6] National Fire Protection Association, NFPA 1600: Standard on 
Disaster/Emergency Management and Business Continuity Programs 
(Quincy, Mass.: February 2000).

[7] See, for example, U.S. General Accounting Office: Results-Oriented 
Cultures: Implementation Steps to Assist Mergers and Organizational 
Transformations, GAO-03-669 (Washington, D.C.: July 2, 2003); 
Highlights of a GAO Forum: Mergers and Transformation: Lessons Learned 
for a Department of Homeland Security and Other Federal Agencies, GAO-
03-293SP (Washington, D.C.: Nov. 14, 2002); A Model of Strategic Human 
Capital Management, GAO-02-373SP (Washington, D.C.: Mar. 15, 2002); and 
Management Reform: Elements of Successful Improvement Initiatives, GAO/
T-GGD-00-26 (Washington, D.C.: Oct. 15, 1999).

[8] See, for example, U.S. General Accounting Office, High-Risk Series: 
Strategic Human Capital Management, GAO-03-120 (Washington, D.C.: 
January 2003); GAO-03-669; GAO-03-293SP; and GAO-02-373SP.

[9] GAO-03-669 and GAO-03-293SP.

[10] GAO-02-373SP.

[11] We have identified eight core characteristics of a strategic 
training and development process that can help make a training and 
development program effective and strategically focused on achieving 
results. These characteristics are strategic alignment; leadership 
commitment and communication; stakeholder involvement; accountability 
and recognition; effective resource allocation; partnerships and 
learning from others; data quality assurance; and continuous 
performance improvement. For more information on these characteristics, 
see U.S. General Accounting Office, Human Capital: A Guide for 
Assessing Strategic Training and Development Efforts in the Federal 
Government, GAO-04-546G (Washington, D.C.: March 2003).

[12] U.S. General Accounting Office, Human Capital: Insights for U.S. 
Agencies from Other Countries' Succession Planning and Management 
Initiatives, GAO-03-914 (Washington, D.C.: Sept. 15, 2003).

[13] See, for example, U.S. Office of Personnel Management, "Memorandum 
for Heads of Executive Departments and Agencies: Washington, DC, Area 
Dismissal or Closure Procedures," December 4, 2003, and "Memorandum for 
Heads of Executive Departments and Agencies: Level Orange Emergency 
Human Resources Management (HRM) Authorities," March 17, 2003.

[14] Our previous work has also identified 25 key practices for 
implementation of successful federal telework programs. See U.S. 
General Accounting Office, Human Capital: Further Guidance, Assistance, 
and Coordination Can Improve Federal Telework Efforts, GAO-03-679 
(Washington, D.C.: July 18, 2003).

[15] U.S. Office of Personnel Management, "Memorandum for Heads of 
Executive Departments and Agencies: Subject: Widespread Power Outage," 
August 15, 2003.

[16] President Bush created the Citizen Corps in January 2002, as a 
component of the USA Freedom Corps, to help coordinate volunteer 
activities that will make communities safer, stronger, and better 
prepared to respond to any emergency situation. This mission is carried 
out through a national network of Citizen Corps Councils that build on 
community strengths to implement the program and carry out a local 
strategy. FEMA coordinates the program nationally. In this capacity, 
FEMA works closely with key stakeholders, including other federal 
entities, state and local governments, first responders, emergency 
managers, and the volunteer community. More information can be found at 
www.citizencorps.gov or by calling 1-877-USA-CORPS.

[17] GAO-02-373SP.

[18] Emergency Management Alberta, "Disruption Incident Reporting 
System," www.municipalaffairs.gov.ab.ca/ema/BRP/DIRS.cfm (downloaded 
Feb. 19, 2004). 

[19] Emergency Management Alberta, "Welcome to the Lessons Learned 
Warehouse," www.municipalaffairs.gov.ab.ca/ema/BRP/Welcome.cfm 
(downloaded Feb. 19, 2004). 

[20] 41 C.F.R. §§ 102-74.230 - 102-74.260 and U.S. General Services 
Administration, Occupant Emergency Program Guide (Washington, D.C.: 
March 2002).

[21] U.S. Office of Personnel Management, "Memorandum to Heads of 
Executive Departments and Agencies: Level Orange Emergency Human 
Resources Management (HRM) Authorities," March 17, 2003.

[22] The four guides are entitled A Federal Employee's Emergency Guide, 
Federal Manager's/Decision Maker's Emergency Guide, A Federal 
Employee's Family Preparedness Guide, and A Federal Employee's Family 
Preparedness Guide (For the Washington, D.C. Area). 

[23] See U.S. Office of Personnel Management, "Memorandum for Heads of 
Departments and Agencies: Wildfires in California," October 27, 2003; 
"Memorandum for Heads of Departments and Agencies: Hurricane Isabel," 
September 19, 2003; and "Memorandum for Heads of Executive Departments 
and Agencies: Level Orange Emergency Human Resources Management (HRM) 
Authorities," March 17, 2003. See also U.S. Office of Personnel 
Management, Human Resources Flexibilities and Authorities in the 
Federal Government (Washington, DC: July 25, 2001).

[24] Although this section focuses on FEBs, much of the discussion 
could also apply to Federal Executive Associations (FEA) and Federal 
Executive Councils (FEC) that are located in cities where FEBs do not 
exist. FEAs and FECs have purposes and objectives similar to FEBs 
although they do not function within the same formal set of parameters 
as FEBs (e.g., they are not officially established by Presidential 
Memorandum, nor do they receive policy direction or guidance from OPM). 
FEAs and FECs also do not have permanent status and, according to OPM, 
often disband and regroup depending on the local commitment of agency 
members.

[25] TOPOFF 2 was conducted from May 12 through May 16, 2003, and 
involved top government officials from federal, state, local, and 
Canadian participants in a full-scale exercise that assessed how 
responders, leaders, and other authorities would react to the simulated 
release of weapons of mass destruction in two U.S. cities, Seattle and 
Chicago. 

[26] The cycle one participants were FEMA, the Department of Housing 
and Urban Development, the Gillette Company, Lockheed Martin 
Corporation, the Business Continuity Institute, and Clark-Atlanta 
University.

[27] The working group participants were from FEMA, the Department of 
Housing and Urban Development, the Social Security Administration, 
Lockheed Martin Corporation, Marsh & McLennan Companies, Inc., Science 
Applications International Corporation, and the Disaster Recovery 
Institute International, as well as representatives from GAO.

[28] See U.S. Office of Personnel Management, "Memorandum for Heads of 
Departments and Agencies: Wildfires in California," October 27, 2003; 
"Memorandum for Heads of Departments and Agencies: Hurricane Isabel," 
September 19, 2003; and "Memorandum for Heads of Executive Departments 
and Agencies: Level Orange Emergency Human Resources Management (HRM) 
Authorities," March 17, 2003.

[29] U.S. Office of Personnel Management, Human Resources Flexibilities 
and Authorities in the Federal Government (Washington, D.C.: July 25, 
2001).

[30] According to 5 U.S.C. § 6323(b), military leave is not to exceed 
22 workdays.

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