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United States Government Accountability Office: 
GAO: 

Report to the Committee on Homeland Security and Governmental Affairs, 
U.S. Senate: 

June 2011: 

National Preparedness: 

DHS and HHS Can Further Strengthen Coordination for Chemical, 
Biological, Radiological, and Nuclear Risk Assessments: 

GAO-11-606: 

GAO Highlights: 

Highlights of GAO-11-606, a report to the 
Committee on Homeland Security and Governmental Affairs, U.S. Senate. 

Why GAO Did This Study: 

The anthrax attacks of 2001 and more recent national reports have 
raised concerns that the United States is vulnerable to attacks with 
chemical, biological, radiological, and nuclear (CBRN) agents. Because 
of the potential consequences of such an attack, members of Congress 
have expressed the need for the Departments of Homeland Security (DHS) 
and Health and Human Services (HHS) to coordinate in assessing risks 
posed by CBRN agents. GAO was asked to examine how DHS and HHS 
coordinate on the development of CBRN risk assessments and the extent 
to which they have institutionalized such efforts. GAO examined 
relevant laws, presidential directives, collaboration best practices, 
and internal control standards; analyzed DHS and HHS CBRN risk 
assessments; and interviewed DHS and HHS officials. 

What GAO Found: 

DHS and HHS have coordinated with each other and with other federal 
departments to develop CBRN risk assessments, but neither department 
has written procedures for developing these assessments. GAO’s best 
practices for interagency collaboration and federal standards for 
internal control indicate that agencies can best enhance and sustain 
coordination by adopting key practices, such as defining desired 
common outcomes, agreeing on roles and responsibilities, and 
developing written policies and procedures to help ensure that 
management directives are enforced. Such practices and standards could 
help DHS and HHS institutionalize their agreements on these sensitive 
and technical issues to better ensure coordination, collaboration, and 
continuity beyond the tenure of any given official or individual 
office. 

* DHS develops two types of CBRN risk assessments—terrorism risk 
assessments (TRA) and material threat assessments (MTA). TRAs assess 
the relative risks posed by multiple CBRN agents based on variable 
threats, vulnerabilities, and consequences. MTAs assess the threat 
posed by given CBRN agents or classes of agents and potential human 
exposures in plausible, high-consequence scenarios. DHS develops TRAs 
through interagency workgroups and has developed some MTAs in this 
way, which allow partners, such as HHS and the Department of Defense, 
to assess risk models and review and comment on the assessments. 
However, DHS does not have interagency agreements or written 
procedures for TRA and MTA development. In addition, DHS’s processes 
and coordination with HHS for MTA development have varied, and HHS 
officials would like to be more involved. DHS officials told GAO they 
intend to develop procedures through interagency agreements with 
federal partners by June 2012 but have not yet established interim 
time frames or milestones for doing so. By establishing interim time 
frames and milestones for developing and obtaining interagency 
agreement on its CBRN risk assessments, DHS could better ensure that 
it completes its plans in the intended time frame. 

* HHS develops one type of CBRN risk assessment—modeling the public 
health consequences of attacks using information from DHS MTAs—through 
an interagency body that includes DHS and other departments, such as 
the Departments of Defense and Veterans Affairs. HHS signed an 
interagency agreement and charters with these partners, consistent 
with interagency coordination best practices. However, HHS does not 
have written procedures detailing the processes for developing the 
modeling reports, such as when and how its partners are to provide 
input and review and comment on the overall report. Written procedures 
for development and review of the modeling reports could provide HHS 
with standardized direction for obtaining, evaluating, and 
incorporating interagency input. In addition, the interagency 
agreement expires in June 2011, and HHS officials were not certain 
whether they would renew it based on ongoing revisions to the 
interagency charters. Renewing the interagency agreement or 
determining if the revised charters sufficiently outline key practices 
for working across agency boundaries could help ensure participating 
departments’ commitment to work collaboratively. 

What GAO Recommends: 

GAO recommends that DHS establish time frames and milestones to better 
ensure timely development and interagency agreement on written 
procedures for development of DHS’s CBRN risk assessments and that HHS 
develop written procedures for obtaining and incorporating interagency 
input into its modeling reports and determine whether to renew its 
interagency agreement. DHS and HHS generally agreed. HHS expressed 
concern that the report implied it does not vet its products through 
its interagency partners, but GAO believes that it appropriately 
credited HHS with having a process to do so in the report. 

View [hyperlink, http://www.gao.gov/products/GAO-11-606] or key 
components. For more information, contact William O. Jenkins, Jr. at 
(202) 512-8777 or jenkinswo@gao.gov or Marcia Crosse at (202) 512-7114 
or crossem@gao.gov. [End of section] 

Contents: 

Letter: 

Background: 

DHS and HHS Coordinate on the Development of CBRN Risk Assessments but 
Do Not Have Written Procedures for Their Development: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: DHS and HHS Chemical, Biological, Radiological, and 
Nuclear Risk Assessments: 

Appendix II: Comments from the Department of Homeland Security: 

Appendix III: Comments from the Department of Health and Human 
Services: 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

Related GAO Products: 

Table: 

Table 1: Diseases and Agents for Which HHS Has Developed Medical and 
Public Health Consequence Modeling Reports: 

Abbreviations: 

BTRA: biological terrorism risk assessment: 

CBRN: chemical, biological, radiological, and nuclear: 

CTRA: chemical terrorism risk assessment: 

DHS: Department of Homeland Security: 

HHS: Department of Health and Human Services: 

HSPD: Homeland Security Presidential Directive: 

ITRA: integrated CBRN terrorism risk assessment: 

MOU: memorandum of understanding: 

MTA: material threat assessment: 

PHEMCE: Public Health Emergency Medical Countermeasures Enterprise: 

R/NTRA: radiological and nuclear terrorism risk assessment: 

TRA: terrorism risk assessment: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

June 21, 2011: 

[End of section] 

The Honorable Joseph I. Lieberman: 
Chairman: 
The Honorable Susan M. Collins: 
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The anthrax attacks of 2001 raised concerns that the United States is 
vulnerable to threats from chemical, biological, radiological, and 
nuclear (CBRN) agents, and the 2007 National Strategy for Homeland 
Security stated that terrorists have declared their intention to 
acquire and use CBRN agents as weapons to inflict catastrophic attacks 
against the United States.[Footnote 1] More recently, the May 2010 
National Security Strategy noted that the American people face no 
greater or more urgent danger than a terrorist attack with a nuclear 
weapon, as well as the concern that the effective dissemination of a 
lethal biological agent within a U.S. city would endanger the lives of 
hundreds of thousands of people and have unprecedented economic, 
societal, and political consequences.[Footnote 2] In addition, 
multiple groups have assessed the federal government's ability to 
protect the nation from CBRN agents and deemed it inadequate. For 
example, in January 2010, the congressionally mandated Commission on 
the Prevention of Weapons of Mass Destruction Proliferation and 
Terrorism reported that the federal government lacked the capability 
to rapidly recognize, respond to, and recover from a terrorist attack 
using biological agents. 

Because CBRN agents differ in their potential to be used to cause 
widespread illness and death, members of Congress have expressed the 
need for the Departments of Homeland Security (DHS) and Health and 
Human Services (HHS) to assess the risks posed by CBRN agents in order 
to identify the highest-risk agents, and use their assessments to 
guide development of response capabilities. Response capabilities 
include medical countermeasures such as drugs, vaccines, and devices 
to diagnose, treat, prevent, or mitigate the potential effects of 
exposure to these agents, and CBRN surveillance and detection 
equipment. Assessing the risks posed by CBRN agents requires analyzing 
and modeling areas of great uncertainty, including determining an 
adversary's capability to acquire these agents, develop them into 
weapons, and disseminate them to estimate the plausibility and 
consequences of such attacks. In order to prepare for and respond to 
potential attacks, effective assessment of the risks posed by CBRN 
agents to national security and public health requires successful and 
sustained coordination and collaboration between DHS, HHS, and other 
federal departments and agencies with responsibilities and expertise 
in this area.[Footnote 3] Federal agencies can enhance and sustain 
their collaboration on CBRN risk assessment efforts by engaging in key 
practices--including agreeing on roles, responsibilities, processes, 
and outcomes--and by establishing this collaboration in written 
agreements. Institutionalizing this information in writing can better 
ensure that these agreements continue beyond the tenure of any given 
agency official, enabling future officials to know how they should 
develop CBRN risk assessments collaboratively with their partner 
agencies. 

You asked us to examine interagency coordination between DHS and HHS 
for the development of their CBRN risk assessments. This report 
addresses how DHS and HHS coordinate on the development of CBRN risk 
assessments and the extent to which they have institutionalized such 
efforts through interagency agreements and written procedures. 

To determine how DHS and HHS coordinate on the development of CBRN 
risk assessments and the extent to which they have institutionalized 
such efforts, we reviewed relevant federal laws, presidential 
directives, executive orders, and national strategies. We reviewed 
these documents to identify requirements for DHS and HHS to develop 
and engage in interagency coordination during the development of their 
CBRN risk assessments and compared these requirements against DHS's 
and HHS's efforts. We obtained and reviewed the CBRN risk assessments 
DHS and HHS developed since 2004, the year initial legislative 
requirements were enacted for the departments to develop these 
assessments, to determine how these documents were developed and to 
identify DHS's and HHS's processes for their development. We examined 
coordination between DHS and HHS for the development of CBRN risk 
assessments and did not examine the coordination between other federal 
departments since DHS and HHS have primary responsibility for 
conducting and overseeing CBRN risk assessment activities. For the 
purposes of this report, we consider CBRN risk assessments to include 
DHS's terrorism risk assessments (TRA) and material threat assessments 
(MTA) and HHS's public health and medical consequence modeling 
reports. TRAs assess the risks posed by CBRN agents based on variable 
threats, vulnerabilities, and consequences.[Footnote 4] MTAs assess 
the threat posed by given CBRN agents and the potential number of 
human exposures in plausible high-consequence scenarios. Modeling 
reports assess the public health and medical consequences of attacks 
with CBRN agents for given scenarios. (See app. I for more information 
on the TRAs, MTAs, and modeling reports.) We reviewed our best 
practices to enhance and sustain agency collaboration, as well as 
Standards for Internal Control in the Federal Government, for 
guidelines on internal controls--an integral component of an 
organization's management that provides reasonable assurance that 
objectives including effectiveness and efficiency of operations are 
being achieved--and the Project Management Institute's Standard for 
Program Management for program management best practices.[Footnote 5] 
We compared these practices and standards to DHS's and HHS's CBRN risk 
assessment development activities and related documents. We also 
interviewed officials from multiple DHS and HHS offices, components, 
and agencies--including DHS's Science and Technology Directorate and 
HHS's Office of the Assistant Secretary for Preparedness and Response--
to obtain information on their interagency coordination processes for 
CBRN risk assessment development. 

We conducted this performance audit from January 2011 through June 
2011 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

DHS leads federal interagency coordination and planning for emergency 
response to catastrophic CBRN incidents in the United States. DHS is 
responsible for assessing the risks posed by various CBRN agents, as 
directed by the Project BioShield Act of 2004[Footnote 6] and Homeland 
Security Presidential Directives (HSPD) 10 (Biodefense for the 21st 
Century), 18 (Medical Countermeasures against Weapons of Mass 
Destruction), and 22 (National Domestic Chemical Defense). To this 
end, DHS's Science and Technology Directorate develops CBRN TRAs and 
MTAs. 

* Each TRA assesses the relative risks posed by multiple CBRN agents 
based on variable threats, vulnerabilities, and consequences. Since 
2004, DHS has developed seven TRA reports, with additional TRAs to be 
published in 2011. 

* Each MTA assesses the threat posed by a given, individual CBRN agent 
or class of agents and the potential number of human exposures in 
plausible, high-consequence scenarios. Since 2004, DHS has developed 
17 MTA reports. 

DHS uses the MTAs to determine which CBRN agents pose a material 
threat sufficient to affect national security.[Footnote 7] (See 
appendix I for more information on DHS's TRAs and MTAs.) 

HHS leads the federal public health and medical response to potential 
CBRN incidents. Under the Project BioShield Act, HHS is required to 
assess, on an ongoing basis, the potential public health consequences 
of those CBRN agents that DHS determines pose a material threat 
sufficient to affect national security. This law requires HHS to 
determine for which of these agents medical countermeasures are 
necessary to protect the public's health.[Footnote 8] HHS conducts 
these activities through the Public Health Emergency Medical 
Countermeasures Enterprise (PHEMCE), a federal interagency decision- 
making body HHS established in 2006.[Footnote 9] Officials from HHS, 
[Footnote 10] DHS,[Footnote 11] the Department of Defense,[Footnote 
12] the Department of Veterans Affairs, the Department of Agriculture, 
and the Executive Office of the President participate in the PHEMCE 
working groups and senior council. The PHEMCE working groups and 
senior council serve as the primary means of communication between 
these federal departments on CBRN medical countermeasure issues. As 
part of their activities, PHEMCE working group members develop medical 
consequence modeling reports to help assess the potential public 
health and medical consequences of attacks with given CBRN agents, 
which is an interim step in determining what types and quantities of 
medical countermeasures may be required to respond. Since 2004, HHS 
has issued 19 modeling reports for various CBRN agents. HHS develops 
modeling reports using data from DHS's MTAs, such as the number of 
individuals exposed to a given agent, to calculate the number of 
individuals who may become ill, be hospitalized, or die based on the 
MTA scenarios. (See appendix I for more information on HHS's modeling 
reports.) 

DHS and HHS Coordinate on the Development of CBRN Risk Assessments but 
Do Not Have Written Procedures for Their Development: 

DHS and HHS have coordinated with each other and with other federal 
departments for the development of CBRN risk assessments, but neither 
has written procedures for developing these assessments. Such written 
procedures are important for enhancing and sustaining collaboration 
because they can help ensure that the departments institutionalize 
agreements on their respective roles and responsibilities, processes 
for developing the risk assessments, and desired outcomes. DHS and HHS 
officials are currently discussing DHS's processes for developing CBRN 
risk assessments because HHS officials said that they are concerned 
that they have not been consistently involved early or substantively 
enough in the process. DHS officials told us they intend to develop 
written procedures through interagency agreements with federal 
partners by June 2012, but DHS has not yet established interim time 
frames and milestones as part of a plan to ensure that it accomplishes 
these results by that time. HHS has signed a memorandum of 
understanding (MOU) and working group charters with DHS and other 
federal partners that participate in PHEMCE, but the department does 
not have written procedures that detail the interagency processes that 
PHEMCE working group members are to use to develop modeling reports. 
Also, agency officials were not certain whether HHS will renew the 
MOU, which expires in June 2011, based on ongoing revisions to the 
working group charters. 

DHS Coordination with HHS on the Development of Its CBRN Risk 
Assessments Has Varied, and DHS Has Not Yet Established Related 
Written Procedures: 

Starting with the first biological terrorism risk assessment (BTRA) in 
2006, DHS coordinated with HHS and other federal partners prior to 
issuing the TRAs.[Footnote 13] For the 2006 BTRA, DHS consulted with 
interagency experts via an ad hoc process to solicit their input 
during the development of the risk assessment or to have them comment 
on the draft document. DHS did not have interagency agreements or 
written procedures to articulate roles, responsibilities, or processes 
for interagency development or review of the risk assessment. In 
addition, DHS did not have interagency working groups or other 
structures to regularly solicit and receive partner input. For 
example, according to HHS officials, DHS did not involve HHS as the 
2006 BTRA was being developed but did ask HHS to comment on it after 
it was drafted. According to DHS officials, working groups were not 
established for the 2006 BTRA because of the limited time that DHS had 
to complete this task. 

Since the 2006 BTRA, interagency coordination for the development and 
review of the TRAs has become more structured and been strengthened, 
according to DHS officials. This strengthening of coordination was 
based in part on feedback received from its interagency partners. For 
example, DHS officials said that HHS officials wanted to be 
consistently involved earlier in the development of the TRAs to be 
able to raise issues prior to reviewing the draft reports. DHS 
established two types of federal interagency working groups designed 
to increase the structure for obtaining interagency input on 
developing and reviewing TRAs.[Footnote 14] First, DHS established a 
working group for each TRA composed of CBRN experts from a variety of 
federal agencies, including HHS. For example, the integrated CBRN 
terrorism risk assessment (ITRA) working group includes officials from 
HHS's Office of the Assistant Secretary for Preparedness and Response 
and the National Institutes of Health. These working groups meet 
monthly to quarterly on an ongoing basis and provide a forum for 
members to (1) assess TRA modeling results, (2) request specialized 
studies to be included, and (3) review and comment on draft TRA 
reports.[Footnote 15] Second, DHS established a working group composed 
of experts from the intelligence community so DHS can obtain their 
input into and review of threat analysis data for the TRAs. According 
to DHS officials, this working group meets on an as-needed basis. 

DHS does not have interagency agreements or written procedures to 
define the process for how the TRAs should be developed with DHS's 
interagency partners, the products that should be produced, or the 
roles and responsibilities of involved agencies. Not having agreements 
and procedures is not consistent with our best practices for 
interagency collaboration and federal standards for internal control. 
According to our best practices, federal agencies engaged in 
interagency coordination can enhance and sustain their collaboration 
by adopting key practices--including defining and articulating a 
common outcome, agreeing on roles and responsibilities, and 
establishing compatible policies and procedures for operating across 
agency boundaries. In addition, agencies can strengthen their 
commitment to work collaboratively by articulating their agreements on 
these key practices in documents, such as MOUs or interagency planning 
documents, signed by senior officials in the respective agencies. 
[Footnote 16] Further, federal standards for internal control call for 
agencies to develop written policies and procedures that enforce 
management's directives.[Footnote 17] 

DHS officials stated that interagency coordination to date has relied 
on the personal relationships established by involved officials, and 
that DHS was not required to develop interagency agreements or written 
procedures. However, DHS officials agree that such interagency 
agreements and written procedures should be developed, and they plan 
to develop them by June 2012, as directed by the Chief Medical and 
Science Advisor in the Chemical and Biological Division of DHS's 
Science and Technology Directorate in early 2011.[Footnote 18] 

DHS began an effort to develop written policies and procedures for the 
TRA working groups at the end of 2010. Specifically, DHS drafted a 
charter for the working group that developed the 2011 ITRA, and DHS 
officials told us in October 2010 that they planned to do the same for 
the three other TRA working groups by the end of fiscal year 2011. 
However, as of March 2011, DHS officials said they had ended their 
efforts to finalize the ITRA charter and develop charters for the 
other working groups. 

DHS officials told us that they have begun drafting a strategic plan 
for DHS's overall CBRN risk assessment efforts and implementation 
plans for each of the TRAs and for the MTAs. The strategic and 
implementation plans, according to DHS officials, will contain written 
procedures to define TRA and MTA (1) interagency development 
processes, (2) products, and (3) roles and responsibilities for 
involved agencies. In addition, DHS officials said they will seek to 
have these plans signed by senior leaders at each of DHS's partner 
agencies to demonstrate interagency agreement on these procedures. DHS 
officials emphasized the importance of having their partners sign the 
documents to establish their commitment to working collaboratively on 
DHS's CBRN risk assessments based on the agreements articulated within 
the plans. At the time of our review, DHS did not have documentation 
available for us to review related to this initiative. HHS officials 
said that they had not seen the draft plans and were not in a position 
to agree or disagree with DHS's approach but have told DHS they would 
like to collaborate on this effort. 

Moreover, DHS has not yet developed interim time frames and milestones 
as part of a plan--consistent with standard practices for program 
management--to develop, finalize, and obtain interagency agreement on 
the proposed strategic and implementation plans. According to DHS 
officials, such milestones include drafting the strategic and 
implementation plans with input from DHS's interagency partners, 
obtaining approval from DHS senior management and general counsel to 
distribute the drafts, receiving and incorporating any changes 
requested by the partners, and obtaining interagency signatures on the 
final documents to institutionalize the interagency agreements. The 
Chief Medical and Science Advisor in the Chemical and Biological 
Division of DHS's Science and Technology Directorate initially told us 
in March 2011 that DHS planned to complete this effort by the end of 
September 2011, but has since extended this estimated completion date 
to June 2012.[Footnote 19] Establishing interim time frames would 
identify targeted dates for completing these milestone activities, 
among others, by June 2012. 

DHS's coordination with HHS and other agencies, as well as its 
processes for developing MTAs, have varied. Based on our analysis of 
DHS's processes for developing 17 MTAs from 2004 to 2010, DHS used at 
least four different processes for interagency coordination. For most 
of the MTAs, DHS held a preliminary discussion with HHS on the need 
for a new MTA, as well as the scope and scenario to be assessed. In 
some of these cases, DHS followed the preliminary discussion with HHS 
by convening two interagency workshops, one to solicit input on the 
proposed approach to developing the MTA and the other to solicit 
interagency comments on the MTA once it was drafted. However, in other 
cases, DHS only held the preliminary discussion with HHS and the later 
workshop to review the draft document. For one MTA, DHS did not hold a 
preliminary discussion with HHS or convene any workshops during its 
development. 

A DHS official involved with the MTA coordination process said that 
while DHS had defined a general approach to developing MTAs, the 
actual processes followed for a given MTA varied over time, were ad 
hoc, and were not guided by interagency agreements or written 
procedures. As a result, the process for obtaining interagency input 
was inconsistent from 2004 to 2010. He said that in those instances 
that DHS did not solicit interagency input through the workshops, DHS 
officials worked to obtain such input by contacting the interagency 
experts directly. He also said that DHS sometimes did not convene 
interagency workshops to reduce travel and other costs associated with 
holding these workshops in person. 

HHS officials described DHS's processes for developing MTAs as ad hoc 
and varied and said that they wanted more substantive and consistent 
coordination with DHS. HHS officials also told us that, in general, 
they had not been involved in key MTA development decisions. HHS uses 
the MTAs to help assess the medical and public health consequences of 
attacks with CBRN agents and determine the amount and type of 
countermeasures to develop and buy to respond to potential CBRN 
incidents. HHS officials told us that their early and consistent 
involvement in the development of an MTA can affect how useful the MTA 
is to HHS for these decisions. HHS officials cited the development of 
the smallpox MTA, which DHS began developing in 2010 at HHS's request, 
as an example of improved coordination in which HHS was involved more 
substantively. For this MTA, DHS officials said they consulted with 
HHS on the development of the MTA prior to its development and are 
engaged in ongoing discussions with HHS throughout the development 
process.[Footnote 20] However, HHS officials told us that this 
modified process was also an ad hoc effort that has only been used to 
develop the smallpox MTA, and they had no assurance that DHS would 
necessarily use this process for developing future MTAs. 

DHS does not have interagency agreements or written procedures to 
define the process for how the MTAs should be developed with its 
interagency partners, the products that should be produced, or the 
roles and responsibilities of involved agencies. Not having this 
documentation is not consistent with our best practices for 
interagency collaboration and federal standards for internal control. 
DHS officials said they plan to develop them by June 2012. DHS tried 
to develop an interagency agreement related to MTA development in 
2008. Specifically, DHS drafted an MOU for DHS and HHS for issuing 
statements related to particular CBRN agents that pose a material 
threat to the nation based on MTA results. HHS officials said they did 
not sign the draft MOU, which was sent to HHS in July 2008, because 
they disagreed with some of its principles. For example, HHS officials 
expressed concern about their level of involvement in providing input 
into the assumptions and data used to develop the MTAs. In January 
2011, DHS considered renewing its effort to have a revised MOU signed 
by HHS. However, DHS and HHS officials told us that these efforts were 
superseded by their ongoing discussions related to DHS's proposed 
strategic and implementation plans. As of May 2011, HHS officials told 
us that their concerns had not yet been resolved with DHS. 

By establishing interim time frames and milestones for developing and 
obtaining interagency agreement on its CBRN risk assessment efforts, 
DHS management could be better positioned to ensure that the 
department's proposed strategic and implementation plans are completed 
in the intended time frame. Such interim time frames and milestones 
could better ensure that DHS completes the strategic and 
implementation plans by June 2012 by, for example, allowing DHS senior 
leadership to monitor the department's progress on meeting interim 
time frames for achieving milestones for completion of these plans. 
DHS officials told us that these strategic and implementation plans 
will help ensure that DHS and its interagency partners achieve 
agreement on TRA and MTA interagency development processes and 
outcomes and agency roles and responsibilities, as well as establish 
DHS's and its partners' commitment to work collaboratively on these 
risk assessments. The proposed strategic and implementation plans 
could better ensure that future interagency coordination for the 
development of the TRAs and MTAs does not depend solely on personal 
relationships among officials from DHS and its federal partners, but 
is instead institutionalized at the department and continues beyond 
the tenure of any given official. In addition, as new interagency 
officials join the TRA working groups or MTA workshops, the proposed 
plans could better ensure that these new officials understand DHS's 
CBRN risk assessment development and review processes, the status of 
current TRA or MTA development, and their respective roles and 
responsibilities for these efforts. 

HHS Signed an Interagency Agreement and Coordinates with DHS to 
Develop Modeling Reports but Does Not Have Written Procedures for 
Their Development: 

HHS has signed an interagency agreement with DHS and other federal 
partners to develop public health and medical consequence modeling 
reports but does not have written procedures that specifically outline 
how HHS and its federal partners, including DHS, are to develop and 
review these modeling reports. In 2008, HHS signed an MOU and working 
group charters with its PHEMCE partners--including DHS, the Department 
of Defense, and others--which support interagency coordination for 
PHEMCE activities, including developing public health and medical 
consequence modeling reports, among other activities.[Footnote 21] 
Together, the PHEMCE MOU and working group charters--which stipulate 
the overall responsibilities and minimum meeting frequencies of the 
interagency working groups--are consistent with best practices for 
collaboration and generally serve to enhance and sustain agency 
collaboration by defining common outcomes and providing interagency 
agreement on roles and responsibilities as called for in our previous 
work.[Footnote 22] However, the MOU and charters do not delineate how 
PHEMCE partners are to conduct medical consequence modeling, develop 
reports, and usher them through the interagency review process. 
[Footnote 23] Not having this documentation is not consistent with 
federal standards for internal control, which call for agencies to 
develop written policies and procedures that enforce management's 
directives.[Footnote 24] 

From 2004 through 2006, the Executive Office of the President led 
interagency coordination efforts to assess public health and medical 
consequences, develop CBRN modeling reports, and establish medical 
countermeasure requirements. In 2006, HHS began leading the assessment 
of public health and medical consequences of CBRN agents and setting 
strategies for developing and acquiring medical countermeasures 
through the interagency PHEMCE. According to HHS officials, the PHEMCE 
working groups provide HHS officials with a structure for coordinating 
and obtaining interagency input on the modeling reports, among other 
activities. For example, HHS officials told us that within the PHEMCE 
working groups, interagency participants discuss any assumptions 
inherent in data about the agent or in planned responses to attacks 
outlined in the MTA scenarios and the range of variables and their 
parameters to make informed decisions on the inputs used to develop 
the modeling reports. HHS officials told us that the contractors and 
HHS staff who run the mathematical models for the modeling reports 
also participate in all PHEMCE working group meetings. 

As part of assessing public health and medical consequences and 
developing the modeling reports, PHEMCE working group members assess 
and discuss each section of the modeling reports, including the 
background information about the agent and the availability of medical 
countermeasures. Although the PHEMCE MOU and charters do not contain 
specific procedures for how PHEMCE partners are to develop the 
modeling reports, they help ensure overall coordination with DHS and 
other federal partners for PHEMCE activities. The Assistant Secretary 
for Preparedness and Response noted that collaboration with DHS has 
improved greatly over the past several years under the PHEMCE 
structure. In addition, DHS officials told us that they regularly 
attend PHEMCE meetings and are satisfied with the level of 
coordination. However, HHS officials noted that there are only a 
limited number of experts within PHEMCE and the federal government who 
have worked with CBRN agents or with individuals infected with these 
agents. They added that bringing all of these experts together to 
provide input on the modeling reports and other PHEMCE activities can 
be challenging because these experts often have competing 
responsibilities. 

According to HHS officials, the department did not develop written 
procedures for the development of modeling reports because the 
processes for conducting medical consequence modeling and developing 
the reports are constantly evolving and improving. For example, 
officials stated that more recent reports incorporate more factors and 
information than earlier versions. In addition, HHS officials told us 
that they do not have guidance or templates for the modeling reports 
because each CBRN agent is unique in the way it is transmitted and 
causes illness or injury and may not fit into a predetermined 
template. However, written procedures for the development and review 
of the modeling reports could provide HHS with standardized direction 
for obtaining, evaluating, and incorporating interagency input on 
these reports, while still allowing HHS to improve the modeling 
reports based on new scientific factors or information or new modeling 
techniques, or to tailor the reports to the characteristics of 
specific agents or types of agents. Furthermore, written procedures 
could also better ensure that future interagency coordination for the 
development of the modeling reports does not depend on personal 
relationships between officials from HHS, DHS, and other federal 
agencies. Written procedures could also help ensure that PHEMCE 
participants approach the development and review of each report 
consistently. In addition, as new interagency officials join the 
PHEMCE working groups, written procedures could help these new 
officials better understand PHEMCE's processes for assessing public 
health consequences and conducting modeling, the status of current 
modeling report development, and their respective roles and 
responsibilities in this effort. 

The 2008 MOU is set to expire in June 2011. However, according to HHS, 
the structure, membership, and roles of some PHEMCE participants has 
changed. For example, PHEMCE now includes officials from the 
Department of Agriculture, while participants from the Executive 
Office of the President no longer participate at the senior council 
level. HHS is currently revising the PHEMCE senior council charter to 
reflect the new structure and will include clarification of roles and 
responsibilities of the PHEMCE senior council. HHS officials told us 
they will determine whether to renew the MOU once they revise the 
senior council charter. Best practices for collaboration suggest that 
federal agencies engaged in interagency coordination can enhance and 
sustain their collaboration by articulating these practices in written 
agreements, such as MOUs. It is not clear whether the revised senior 
council charter will define and articulate common outcomes or 
establish compatible policies and procedures for operating across 
agency boundaries. Revising the charter to include this information, 
or renewing the PHEMCE MOU and updating it to reflect current 
membership if it does not, could help demonstrate the commitment of 
all participating federal departments to working collaboratively and 
helping to ensure sustained interagency coordination for the 
development of modeling reports and other PHEMCE activities. 

Conclusions: 

In order to prepare for and respond to potentially catastrophic 
attacks with CBRN agents, effective assessment of the risks posed by 
these agents to national security and public health requires 
successful and sustained coordination and collaboration between DHS, 
HHS, and other responsible federal departments and agencies. DHS and 
HHS have been developing CBRN risk assessments--DHS's TRAs and MTAs 
and HHS's medical consequence modeling reports--since 2004, and their 
processes for coordinating risk assessment development have evolved 
over the past 7 years but have not been fully institutionalized in 
writing. Developing written agreements could help DHS and HHS reach 
concurrence on procedures acceptable to both departments on their 
expected levels of involvement in developing their respective risk 
assessments. Given the additional value incorporated into the CBRN 
risk assessments from DHS and HHS working collaboratively to harness 
all available expertise, DHS and HHS could enhance their risk 
assessment processes by establishing written procedures for developing 
and reviewing these assessments. Establishing written procedures also 
includes updating existing interagency agreements, such as the PHEMCE 
MOU, or determining whether other agreements HHS is developing may be 
sufficient. Written procedures would provide direction for interagency 
coordination. In addition, interagency agreements could help ensure 
that sustained coordination continues beyond the tenure of any given 
agency official, enabling future officials to know their respective 
roles and responsibilities. While DHS intends to develop such 
procedures by June 2012 in collaboration with its partners, 
establishing interim time frames and milestones for developing the 
strategic and implementation plans could allow DHS senior leadership 
to monitor departmental progress to better ensure completion of these 
efforts to institutionalize interagency coordination. 

Recommendations for Executive Action: 

To ensure that DHS senior officials are able to monitor progress on 
the development of the proposed strategic and implementation plans for 
DHS's CBRN risk assessment efforts, we recommend that the Secretary of 
Homeland Security develop and document interim time frames and 
milestones as part of a plan to develop, finalize, and obtain 
interagency agreement on the written procedures for interagency 
development of the TRAs and MTAs that DHS intends to issue as 
strategic and implementation plans. 

To ensure that HHS and its federal partners are fully aware of and 
agree with the processes for developing the public health and medical 
consequence modeling reports and that consistent and effective 
interagency coordination continues, we recommend that the Secretary of 
Health and Human Services take the following two actions: 

* develop written procedures for obtaining, evaluating, and 
incorporating interagency input into the development and review of the 
modeling reports, to supplement the PHEMCE MOU and working group 
charters, and: 

* determine whether to renew the MOU or whether alternate coordination 
mechanisms, such as the PHEMCE senior council charter, are sufficient 
to confirm federal departments' agreement to work collaboratively. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to DHS and HHS for their review. 
Both departments provided written comments, which are summarized below 
and reprinted in appendixes II and III, respectively. The departments 
also provided technical comments, which we incorporated where 
appropriate. 

DHS concurred with, and HHS generally agreed with, the basis for the 
recommendations and discussed actions planned or under way to address 
them. With regard to the first recommendation, DHS stated that the 
department has begun efforts to develop milestones and time frames for 
its strategic and implementation plans for interagency TRA and MTA 
development. In addition, DHS stated that enhanced coordination with 
HHS and its other federal partners for the development of the TRAs and 
MTAs was important, especially as the MTAs support HHS's medical 
countermeasure decision making. 

With regard to the second recommendation, HHS stated that it 
conceptually agreed that institutionalizing agreements and procedures 
for the development of the modeling reports in writing is important. 
However, HHS expressed concern that the report implies that HHS does 
not vet its products through PHEMCE partners, including its modeling 
reports. We disagree. The report states, for example, that PHEMCE 
provides a means for HHS to coordinate and obtain interagency input on 
modeling reports, among other activities. With regard to the third 
recommendation, HHS stated that it concurs and had taken action to 
renew the PHEMCE interagency MOU. 

HHS also commented that our use of the term "risk" is not consistent 
with DHS's and HHS's use of this term. DHS defines risk as the 
potential for an adverse outcome assessed as a function of threats, 
vulnerabilities, and consequences and risk assessment as a process to 
assign probabilities to such outcomes. HHS pointed out that while 
DHS's MTAs assess threat, they do not include an assessment of the 
probability that a particular agent will be used. We recognize that 
the MTAs and HHS's medical consequence modeling reports do not 
individually contain all three elements of threat, vulnerability, and 
consequence and an assessment of probability that make up DHS's 
definition of risk. However, for the purposes of this report we 
consider both the MTAs and the modeling reports to be CBRN risk 
assessments. The MTAs contain assessments of threat and vulnerability, 
and modeling reports contain assessments of consequence and 
vulnerability based on the MTAs. These two types of assessments, along 
with DHS's TRAs, provide measurements of risk consistent with the 
departments' use of the term. We modified the language in the report 
to appropriately clarify the use of this term. 

Finally, HHS stated that the report's focus on HHS's modeling reports 
creates an inaccurate perception of these documents as end products. 
This was not our intention. Specifically, the report states that these 
documents are not intended by HHS to be end products and represent an 
interim step of assessing potential public health and medical 
consequences and determining what types and quantities of medical 
countermeasures HHS may need to respond to a CBRN event. However, to 
address HHS's concerns, we modified text in appendix I discussing the 
modeling reports to clarify that these are interim products. 

We are sending copies of this report to the Secretary of Homeland 
Security, the Secretary of Health and Human Services, and interested 
congressional committees. The report is also available at no charge on 
the GAO Web site at [hyperlink, http://www.gao.gov]. If you or your 
staffs have any questions about this report, please contact William O. 
Jenkins, Jr. at (202) 512-8777 or jenkinswo@gao.gov or Marcia Crosse 
at (202) 512-7114 or crossem@gao.gov. Contact points for our Offices 
of Congressional Relations and Public Affairs may be found on the last 
page of this report. Key contributors to this report are listed in 
appendix IV. 

Signed by: 

William O. Jenkins, Jr. 
Director, Homeland Security and Justice: 

Signed by: 

Marcia Crosse: 
Director, Health Care: 

[End of section] 

Appendix I: DHS and HHS Chemical, Biological, Radiological, and 
Nuclear Risk Assessments: 

[End of section] 

In response to provisions in the Project BioShield Act of 2004 
[Footnote 25] and Homeland Security Presidential Directives (HSPD) 10 
(Biodefense for the 21st Century), 18 (Medical Countermeasures against 
Weapons of Mass Destruction), and 22 (National Domestic Chemical 
Defense), the Department of Homeland Security (DHS) and the Department 
of Health and Human Services (HHS) develop three types of chemical, 
biological, radiological, and nuclear (CBRN) risk assessments--DHS's 
terrorism risk assessments (TRA) and material threat assessments (MTA) 
and HHS's public health and medical consequence modeling reports. 

Risk and Risk Assessment: 

The DHS Risk Lexicon defines risk as the potential for an adverse 
outcome assessed as a function of threats, vulnerabilities, and 
consequences associated with an incident, event, or occurrence. 
[Footnote 26] Threats are defined as entities, actions, or natural or 
man-made occurrences that have or indicate the potential to harm life, 
information, operations, or property. Vulnerabilities are defined as 
the physical features or operational attributes that render an entity, 
asset, system, network, or geographic area susceptible or exposed to 
hazards. Consequences are defined as the potential or actual effects 
of an event, incident, or occurrence. The DHS Risk Lexicon defines 
risk assessment as the product or process that collects information 
and assigns values to risks for the purpose of informing priorities, 
developing or comparing courses of action, and informing decision 
making. According to DHS, risk information is usually one of many 
factors--and not necessarily the sole factor--that decision makers 
consider when deciding which strategy to pursue to manage risk. 

DHS and HHS CBRN Risk Assessments: 

DHS Terrorism Risk Assessments: 

In response to provisions in HSPD-10, HSPD-18, and HSPD-22, DHS 
conducts CBRN risk assessments and coordinates with appropriate 
subject matter experts, including those in HHS, in developing these 
risk assessments. DHS has issued seven classified TRAs to date, and 
one is currently in development. DHS issued three successive 
biological TRAs (BTRA) in 2006, 2008, and 2010; two chemical TRAs 
(CTRA) in 2008 and 2010; and two integrated CBRN TRAs (ITRA) in 2008 
and 2011.[Footnote 27] In addition, DHS also plans to issue the first 
radiological and nuclear TRA (R/NTRA) in 2011. The results of the 
individual BTRAs, CTRAs, and R/NTRAs are combined to develop the 
comprehensive ITRAs.[Footnote 28] Each TRA assesses the relative risks 
posed by multiple CBRN agents based on variable threats, 
vulnerabilities, and consequences. DHS updated these TRAs biennially 
in the past, and DHS officials said that they plan to update them 
quadrennially going forward, in part to reflect current terrorism 
event probabilities and accurately determine relative CBRN terrorism 
risk. TRA results are based on risk modeling that assesses the 
likelihood of a terrorist attack using a CBRN agent, combined with the 
consequences that would result from a successful attack. Modeling of 
the likelihood of an attack is based on an assessment of the actions 
that an adversary, such as a terrorist, is determined to be likely to 
pursue--based in part on intelligence community inputs--combined with 
an assessment of the vulnerability of U.S. population centers to such 
an attack. DHS uses risk modeling techniques and computer software to 
calculate TRA results based on millions of hypothetical CBRN terrorism 
attack scenarios that include variable likelihood figures and 
consequence parameters. 

DHS Material Threat Assessments: 

Under the Project BioShield Act of 2004, DHS is required, on an 
ongoing basis, to assess the threat posed by specific CBRN agents and 
to issue determinations for those CBRN agents that pose a material 
threat to the U.S. population sufficient to affect national security. 
[Footnote 29] In response to these requirements, DHS has issued 17 
classified MTAs to date, each of which assesses the threat posed by a 
given CBRN agent or class of agents and the potential numbers of human 
exposures in plausible, high-consequence scenarios.[Footnote 30] DHS 
solicits intelligence community officials to define and articulate the 
plausible, high-consequence attack scenarios that might be pursued by 
terrorists seeking to maximize casualties. These scenarios are then 
analyzed to determine the results of an MTA to provide an estimate of 
the number of people exposed to different dose levels of an agent in 
the scenario. HHS uses the MTAs to inform medical consequence modeling 
to support defining requirements for medical countermeasures to 
mitigate the health effects of CBRN agents. 

HHS Public Health and Medical Consequence Modeling Reports: 

The Project BioShield Act of 2004 calls for HHS to assess the public 
health consequences of exposure to those CBRN agents that DHS 
determines are material threats to the nation.[Footnote 31] In 
response, HHS has issued 19 modeling reports for CBRN agents, using 
the data from the corresponding DHS MTA to calculate the number of 
individuals who may become ill, be hospitalized, or die based on the 
MTA scenario. To develop these estimates from the MTAs, HHS consults 
with experts and uses available scientific data, such as data on how 
much of an agent is needed to cause infection and how long it takes to 
develop symptoms of disease after exposure. In addition, HHS assesses 
the status of current countermeasure development and availability, 
including applicable countermeasures that the Department of Defense 
may be developing. HHS uses the modeling reports as an interim step to 
help assess public health and medical consequences and determine which 
medical countermeasures are needed, and in what quantity, and the 
optimal timing for treating the affected population following an 
attack.[Footnote 32] 

HHS modeling reports assess factors that may affect the number of 
individuals who may be infected with a given CBRN agent--such as the 
quantity of the agent released, the timing of the release, 
environmental conditions, population demographics, and the timing of 
medical countermeasure administration, among others--and may include 
multiple exposure scenarios as appropriate. For example, depending 
upon the agent, some modeling reports may account for differences in 
height, weight, and lung function among individuals of different 
genders and ages to model short-and long-term health effects for these 
populations because the course of disease caused by an agent can 
differ based on these characteristics. Other modeling reports may 
evaluate multiple exposure scenarios--such as inhalation of or skin 
contact with an agent--to determine the numbers of potentially 
infected individuals. 

Modeling reports may also evaluate potential health consequences 
resulting from different response strategies based on the time it 
takes to detect an attack by environmental sampling or by individuals 
presenting at hospitals, initiate a medical countermeasure prophylaxis 
campaign, and distribute and dispense medical countermeasures to the 
affected area and individuals. Modeling report results include 
analyses of the range of individuals who may die without treatment 
with medical countermeasures and optimal time frames for providing 
medical countermeasures to prevent significant numbers of deaths from 
infection with an agent. Modeling reports also identify gaps in 
knowledge, such as limited scientific information about the response 
of a particular CBRN agent to a countermeasure, and the extent to 
which HHS assesses short-and long-term medical countermeasures needs 
as a result of exposure to an agent. (See table 1 for the HHS modeling 
reports developed to date.) 

Table 1: Diseases and Agents for Which HHS Has Developed Medical and 
Public Health Consequence Modeling Reports: 

Biological: 
* Anthrax[A]; 
* Botulism; 
* Glanders and melioidosis (Burkholderia); 
* Junin virus; 
* Marburg virus[B]; 
* Plague; 
* Q fever, Rocky Mountain spotted fever, and typhus (Rickettsia); 
* Smallpox; 
* Tularemia. 

Chemical: 
* Blood agents; 
* Low volatility nerve agents; 
* Pulmonary agents; 
* Vesicants; 
* Volatile nerve agents. 

Radiological and nuclear: 
* Improvised nuclear device; 
* Radiological dispersal device. 

Source: HHS. 

[A] HHS has issued four separate modeling reports for anthrax to 
examine particular issues in addition to countermeasure needs, such as 
countermeasure cost and effectiveness and different strategies for 
using anthrax vaccine. 

[B] The Marburg modeling report includes considerations for Ebola 
virus. 

[End of table] 

[End of section] 

Appendix II: Comments from the Department of Homeland Security: 

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

June 8, 2011: 

William O. Jenkins: 
Director, Homeland Security and Justice: 
U.S. Government Accountability Office: 
441 G. Street NW: 
Washington, DC 20548: 

Re: Draft Report GA0-11-606, "National Preparedness: DHS and III-IS Can
Further Strengthen Coordination for Chemical, Biological, 
Radiological, and Nuclear Risk Assessments" 

Dear Mr. Jenkins: 

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

The Department is pleased to note the report recognizes that DHS, the 
U.S. Department of Health and Human Services (HHS), and other key 
federal partners have been coordinating and developing Chemical, 
Biological, Radiological, and Nuclear (CBRN) risk assessments since
2004. These assessments are critical to supporting the Nation's CBRN 
preparedness and defense-related activities, including investments for 
prevention, protection, surveillance, detection, response, and 
recovery. 

DHS is fully committed to supporting the National CBRN Defense 
Strategies and all our federal partners to ensure key risk assessments 
are conducted in a collaborative and coordinated manner to yield 
quality products. These assessments are based on current, available 
science and knowledge and our best judgments to understand the risks 
inherent in CBRN agents. The inevitable degree of uncertainty 
associated with understanding these agents and their use is also a 
contributing factor. As such, it is critical for our federal, state, 
local, and tribal partners to utilize these assessments with the 
understanding of the assessments' intended uses, applications, and 
limitations when making decisions. 

The draft report contained one recommendation directed to DHS. 
Specifically, to ensure that DHS senior officials are able to monitor 
progress on the development of the proposed strategic and 
implementation plans for DHS's CBRN risk assessment efforts, GAO 
recommended that the Secretary of Homeland Security: 

Recommendation: Develop and document interim time frames and 
milestones as part of a plan to develop, finalize, and obtain 
interagency agreement on the written procedures for interagency 
development of the TRAs and MTAs that DHS intends to issue as 
strategic and implementation plans. 

Response: Concur. DHS agrees that the collaboration and coordination 
between DHS and HHS for conducting the CBRN risk assessments — 
terrorist risk assessments (TRAs) and material threat assessments 
(MTAs) can be enhanced and strengthened. For example, the MTAs 
encompass population exposure modeling for consensus scenarios and 
support HHS's public health modeling and medical countermeasures 
requirements development efforts resulting in the issuance of Material 
Threat Determinations to facilitate better preparations for and 
responses to potentially catastrophic attacks with CBRN agents. DHS 
has initiated efforts to map out the timeline and milestones to ensure 
timely development of a Strategic Implementation Plan for conducting 
these critically important assessments. 

Again, thank you for the opportunity to review and comment on this 
draft report. Sensitivity comments have been submitted under separate 
cover. We look forward to working with you on future Homeland Security 
issues. 

Sincerely, 

Signed by: 

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

[End of section] 

Appendix III: Comments from the Department of Health and Human 
Services: 

Department Of Health & Human Services:	
Office Of The Secretary: 
Assistant Secretary for Legislation: 
Washington, DC 20201: 

June 2, 2011: 

Marcia Crosse: 
Director, Health Care: 
William 0. Jenkins: 
Director, Homeland Security and Justice: 
U.S. Government Accountability Office: 
441 G Street N.W. 
Washington, DC 20548: 

Dear Ms. Crosse and Mr. Jenkins: 

Attached are comments on the U.S. Government Accountability Office's 
(GAO) draft report entitled: "National Preparedness: DHS and HHS Can 
Further Strengthen Coordination for Chemical, Biological, 
Radiological, and Nuclear Risk Assessments" (GAO-11606). 

The Department appreciates the opportunity to review this report 
before its publication. 

Sincerely, 

Signed by: 

Jim R. Esquea: 
Assistant Secretary for Legislation: 

Attachment: 

[End of letter] 

General Comments Of The Department Of Health And Human Services (HHS) 
On The Government Accountability Office'S (GAO) Draft Report Entitled, 
"National Preparedness: DHS And HHS Can Further Strengthen 
Coordination For Chemical, Biological, Radiological, And Nuclear Risk 
Assessments" (GA0-11-606): 

The Department appreciates the opportunity to review and comment on 
this draft report. 

Throughout this report, GAO's use of the term "risk" is not consistent 
with its use by HHS and the Department of Homeland Security (DHS). For 
example, a material threat assessment (MTA) evaluates threat, which is 
a component of risk, but not risk, because it does not include an 
assessment of the probability or likelihood of a particular agent 
being used. We have raised this issue with GAO previously and the 
response has been that GAO prefers to use the term "risk" in a more 
generic way. Nevertheless, the Department wants to make official note 
of this concern. 

Similarly, throughout this draft report there is a focus on the 
consequence modeling reports as if they are the end product of the 
Public Health Emergency Medical Countermeasures Enterprise (PHEMCE) 
working groups. This is not an accurate assessment. The modeling 
report feeds into the consequence assessment process within the 
working groups that develop the scenario-based requirements (SBRs) 
that discuss the agent, the disease characteristics, the types of 
consequences, the number of injuries by types, and other factors. The 
PHEMCE working group members develop SBRs for delivery, not modeling 
reports. The modeling is one input and documentation to support the 
SBRs and product-specific requirements (PSRs). GAO's focus on the 
modeling reports as representative of the medical consequence 
assessment and not including discussion of the SBR development process 
can be misleading as it does not accurately describe the entire 
process. 

Conceptually, we agree with GAO's emphasis in this report on 
memorializing agreements and institutionalizing best practices for 
development of the terrorism risk assessments (TRAs), MTAs, and 
consequence modeling reports in written documents, and the report 
makes many useful observations about current deficiencies in this 
regard. However, we are concerned that the language used in this 
report implies that HHS does not vet the PHEMCE work products 
(including modeling reports, SBRs, and PSRs), when in actuality there 
is a transparent process, albeit one that is not documented in a 
charter. 

HHS concurs with GAO that the PHEMCE interagency memorandum of 
understanding (MOU), which expires in June 2011, demonstrates the 
commitment of all participating federal departments to work 
collaboratively on PHEMCE issues. For this reason, HHS has undertaken 
efforts to renew this MOU with its interagency partners. 

[End of section] 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

William O. Jenkins, Jr., (202) 512-8777 or jenkinswo@gao.gov: 

Marcia Crosse, (202) 512-7114 or crossem@gao.gov: 

Staff Acknowledgments: 

In addition to the contacts named above, Sheila K. Avruch, Assistant 
Director; Edward George, Assistant Director; David Alexander; 
Katherine Davis; Shana R. Deitch; Bonnie Doty; Tracey King; David 
Lysy; Carolina Morgan; Roseanne Price; and David Schneider made 
significant contributions to this report. 

[End of section] 

Related GAO Products: 

Public Health Preparedness: Developing and Acquiring Medical 
Countermeasures Against Chemical, Biological, Radiological, and 
Nuclear Agents. [hyperlink, http://www.gao.gov/products/GAO-11-567T]. 
Washington, D.C.: April 13, 2011. 

Measuring Disaster Preparedness: FEMA Has Made Limited Progress in 
Assessing National Capabilities. [hyperlink, 
http://www.gao.gov/products/GAO-11-260T]. Washington, D.C.: March 17, 
2011. 

Biosurveillance: Efforts to Develop a National Biosurveillance 
Capability Need a National Strategy and a Designated Leader. 
[hyperlink, http://www.gao.gov/products/GAO-10-645]. Washington, D.C.: 
June 30, 2010. 

National Security: Key Challenges and Solutions to Strengthen 
Interagency Collaboration. [hyperlink, 
http://www.gao.gov/products/GAO-10-822T]. Washington, D.C.: June 9, 
2010. 

Homeland Defense: DOD Can Enhance Efforts to Identify Capabilities to 
Support Civil Authorities during Disasters. [hyperlink, 
http://www.gao.gov/products/GAO-10-386]. Washington, D.C.: March 30, 
2010. 

Homeland Defense: DOD Needs to Take Actions to Enhance Interagency 
Coordination for Its Homeland Defense and Civil Support Missions. 
[hyperlink, http://www.gao.gov/products/GAO-10-364]. Washington, D.C.: 
March 30, 2010. 

Combating Nuclear Terrorism: Actions Needed to Better Prepare to 
Recover from Possible Attacks Using Radiological or Nuclear Materials. 
[hyperlink, http://www.gao.gov/products/GAO-10-204]. Washington, D.C.: 
January 29, 2010. 

Biosurveillance: Developing a Collaboration Strategy Is Essential to 
Fostering Interagency Data and Resource Sharing. [hyperlink, 
http://www.gao.gov/products/GAO-10-171]. Washington, D.C.: December 
18, 2009. 

Homeland Defense: Planning, Resourcing, and Training Issues Challenge 
DOD's Response to Domestic Chemical, Biological, Radiological, 
Nuclear, and High-Yield Explosive Incidents. [hyperlink, 
http://www.gao.gov/products/GAO-10-123]. Washington, D.C.: October 7, 
2009. 

Interagency Collaboration: Key Issues for Congressional Oversight of 
National Security Strategies, Organizations, Workforce, and 
Information Sharing. [hyperlink, 
http://www.gao.gov/products/GAO-09-904SP]. Washington, D.C.: September 
25, 2009. 

Project BioShield Act: HHS Has Supported Development, Procurement, and 
Emergency Use of Medical Countermeasures to Address Health Threats. 
[hyperlink, http://www.gao.gov/products/GAO-09-878R]. Washington, 
D.C.: July 24, 2009. 

Project BioShield: HHS Can Improve Agency Internal Controls for Its 
New Contracting Authorities. [hyperlink, 
http://www.gao.gov/products/GAO-09-820]. Washington, D.C.: July 21, 
2009. 

National Preparedness: FEMA Has Made Progress, but Needs to Complete 
and Integrate Planning, Exercise, and Assessment Efforts. [hyperlink, 
http://www.gao.gov/products/GAO-09-369]. Washington, D.C.: April 30, 
2009. 

Risk Management: Strengthening the Use of Risk Management Principles 
in Homeland Security. [hyperlink, 
http://www.gao.gov/products/GAO-08-904T]. Washington, D.C.: June 25, 
2008. 

Emergency Management: Observations on DHS's Preparedness for 
Catastrophic Disasters. [hyperlink, 
http://www.gao.gov/products/GAO-08-868T]. Washington, D.C.: June 11, 
2008. 

Highlights of a Forum: Strengthening the Use of Risk Management 
Principles in Homeland Security. [hyperlink, 
http://www.gao.gov/products/GAO-08-627SP]. Washington, D.C.: April 15, 
2008. 

Project BioShield: Actions Needed to Avoid Repeating Past Problems 
with Procuring New Anthrax Vaccine and Managing the Stockpile of 
Licensed Vaccine. [hyperlink, http://www.gao.gov/products/GAO-08-88]. 
Washington, D.C.: October 23, 2007. 

Homeland Security: Applying Risk Management Principles to Guide 
Federal Investments. [hyperlink, 
http://www.gao.gov/products/GAO-07-386T]. Washington, D.C.: February 
7, 2007. 

Risk Management: Further Refinements Needed to Assess Risk and 
Prioritize Protective Measures at Ports and Other Critical 
Infrastructure. [hyperlink, http://www.gao.gov/products/GAO-06-91]. 
Washington, D.C.: December 15, 2005. 

Results-Oriented Government: Practices That Can Help Enhance and 
Sustain Collaboration among Federal Agencies. [hyperlink, 
http://www.gao.gov/products/GAO-06-15]. Washington, D.C.: October 21, 
2005. 

[End of section] 

Footnotes: 

[1] White House, National Strategy for Homeland Security (Washington, 
D.C., October 2007). 

[2] White House, National Security Strategy (Washington, D.C., May 
2010). 

[3] Collaboration can be broadly defined as any joint activity that is 
intended to produce more public value than could be produced when 
organizations act alone. 

[4] According to the DHS Risk Lexicon, threats are entities, actions, 
or occurrences, whether natural or man-made, that have or indicate the 
potential to harm life, information, operations, and/or property; 
vulnerabilities are physical features or operational attributes that 
render an entity, asset, system, network, or geographic area 
susceptible or exposed to hazards; and consequences are potential or 
actual effects of an event, incident, or occurrence. DHS, DHS Risk 
Lexicon: 2010 Edition (Washington, D.C., September 2010). 

[5] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21, 
2005); GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999); and Project Management Institute, 
The Standard for Program Management, 2nd ed. (Newton Square, Pa., 
2008). The criteria in GAO/AIMD 00-21.3.1, dated November 1999, issued 
pursuant to the requirements of the Federal Managers' Financial 
Integrity Act of 1982 (FMFIA), provide the overall framework for 
establishing and maintaining internal control in the federal 
government. Also pursuant to FMFIA, the Office of Management and 
Budget issued Circular A-123, revised December 21, 2004, to provide 
the specific requirements for assessing the reporting on internal 
controls. Internal control standards and the definition of internal 
control in Circular A-123 are based on GAO's Standards for Internal 
Control in the Federal Government. See also the Related GAO Products 
section at the end of this report. 

[6] 42 U.S.C. § 247d-6b(c)(2)(A). 

[7] Since 2004, DHS determined that 14 of 17 CBRN agents that it 
assessed in MTAs pose a material threat to the nation and issued 
material threat determinations for those agents. The 14 material 
threat determinations that DHS has issued to date are for Bacillus 
anthracis (anthrax), Burkholderia mallei (glanders), Burkholderia 
pseudomallei (melioidosis), Clostridium botulinum (botulism toxin), 
Ebola virus (hemorrhagic fever), Francisella tularensis (tularemia), 
Junin virus (hemorrhagic fever), Marburg virus (hemorrhagic fever), 
multidrug-resistant Bacillus anthracis (MDR anthrax), Rickettsia 
prowazekii (typhus), Variola major (smallpox), Yersinia pestis 
(plague), radiological agents, and nuclear agents. 

[8] 42 U.S.C. § 247d-6b(c)(2)(B). The Project BioShield Act authorizes 
the federal government to use specific contracting authorities to 
procure certain medical countermeasures for these agents and 
established the Project BioShield Special Reserve Fund for the 
acquisition of certain medical countermeasures, some of which may not 
yet qualify for approval or licensing. 

[9] PHEMCE is responsible for providing recommendations to the 
Secretary of Health and Human Services on (1) prioritized requirements 
for CBRN medical countermeasures, (2) coordination of medical 
countermeasure development and acquisition activities to address the 
requirements, and (3) strategies for distributing medical 
countermeasures held in national stockpiles. In addition to these 
responsibilities, PHEMCE is also responsible for countermeasures for 
pandemic influenza and other emerging infectious diseases. 

[10] HHS officials from the Centers for Disease Control and 
Prevention, the Food and Drug Administration, the National Institutes 
of Health, and the Office of the Assistant Secretary for Preparedness 
and Response participate in PHEMCE, in addition to officials from 
other HHS offices. 

[11] DHS officials from DHS's Science and Technology Directorate and 
Office of Health Affairs participate in PHEMCE. 

[12] The Department of Defense has exclusive responsibility for 
research, development, acquisition, and deployment of medical 
countermeasures to prevent or mitigate the health effects of CBRN 
agents and naturally occurring diseases on armed forces personnel. 
Under the PHEMCE structure, the Department of Defense also coordinates 
with HHS to share information and resources for common CBRN medical 
countermeasure priorities to reduce duplication of effort. 

[13] DHS develops its TRAs by integrating information from the 
intelligence and law enforcement communities, as well as input from 
the scientific, medical, and public health communities, among others. 

[14] In addition to HHS, members of the TRA working groups include the 
Department of Defense, the Environmental Protection Agency, and the 
Nuclear Regulatory Commission, among others. 

[15] DHS convenes separate working groups for each of the TRAs that 
DHS produces. Each working group is responsible for development and 
review of its respective TRA, in conjunction with the contractors that 
DHS utilizes to develop TRA data inputs and perform related 
mathematical modeling. Separate working groups exist for the BTRA, the 
chemical TRA (CTRA), the radiological and nuclear TRA (R/NTRA), and 
the ITRA. 

[16] See [hyperlink, http://www.gao.gov/products/GAO-06-15]. 
Additional key practices include establishing mutually reinforcing or 
joint strategies to achieve the outcome; identifying and addressing 
needs by leveraging resources; developing mechanisms to monitor, 
evaluate, and report the results of collaborative efforts; reinforcing 
agency accountability for collaborative efforts through agency plans 
and reports; and reinforcing individual accountability for 
collaborative efforts through agency performance management systems. 

[17] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[18] The Chemical and Biological Division in DHS's Science and 
Technology Directorate is the DHS entity responsible for the 
development of the TRAs and MTAs. 

[19] The Project Management Institute, The Standard for Program 
Management. The Standard for Program Management calls for establishing 
time frames and milestones as part of a plan to ensure that intended 
results are achieved. 

[20] HHS officials said that as of May 2011, they had not reviewed the 
draft smallpox MTA because it had not yet been completed. 

[21] The PHEMCE MOU and charters support interagency coordination 
between HHS, the Department of Defense, and the Department of Veterans 
Affairs, in addition to DHS. 

[22] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[23] According to HHS officials, the modeling reports are not intended 
to be end products but rather one step in the process of determining 
medical countermeasure needs in the event of an attack with a CBRN 
agent. 

[24] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[25] 42 U.S.C. § 247d-6b(c)(2)(A),(B). 

[26] DHS, DHS Risk Lexicon: 2010 Edition (Washington, D.C., September 
2010). Developed by DHS's intradepartmental Risk Steering Committee, 
the purpose of the DHS Risk Lexicon is to establish and make available 
a comprehensive list of terms and meanings relevant to the practice of 
homeland security risk management and analysis. 

[27] DHS was originally scheduled to issue the second ITRA in 2010. 
However, DHS published it in 2011 and plans to issue future iterations 
quadrennially thereafter (e.g., 2015, 2019, etc.) so that the ITRA, 
which relies on data contained in the BTRA, CTRA, and radiological and 
nuclear TRA (R/NTRA), will be produced in the years following 
publication of these other assessments. The next iterations of the 
BTRA, CTRA, and R/NTRA are scheduled for 2014. 

[28] The 2008 ITRA was developed based on the results of the 2008 BTRA 
and CTRA, as well as a radiological and nuclear appendix to the 2008 
ITRA report. The 2011 R/NTRA is the first standalone R/NTRA to be 
produced, and its results will be combined with those from the 2010 
BTRA and CTRA to develop the 2011 ITRA. 

[29] 42 U.S.C. § 247d-6b(c)(2)(A). 

[30] Since 2004, DHS determined that 14 of 17 CBRN agents that it 
assessed in MTAs pose a material threat to the nation and issued 
material threat determinations for those agents. The 14 material 
threat determinations that DHS has issued to date are for Bacillus 
anthracis (anthrax), Burkholderia mallei (glanders), Burkholderia 
pseudomallei (melioidosis), Clostridium botulinum (botulism toxin), 
Ebola virus (hemorrhagic fever), Francisella tularensis (tularemia), 
Junin virus (hemorrhagic fever), Marburg virus (hemorrhagic fever), 
multidrug-resistant Bacillus anthracis (MDR anthrax), Rickettsia 
prowazekii (typhus), Variola major (smallpox), Yersinia pestis 
(plague), radiological agents, and nuclear agents. 

[31] 42 U.S.C. § 247d-6b(c)(2)(B). 

[32] Medical countermeasures include drugs, biologic products, and 
devices to identify, treat, prevent, or mitigate potential health 
effects from exposure to CBRN agents. HHS acquires CBRN medical 
countermeasures to treat the potentially exposed population after an 
attack in order to prevent the onset of disease as well as to treat 
individuals who have developed disease resulting from such an attack. 

[End of section] 

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