National Response Framework:

FEMA Needs Policies and Procedures to Better Integrate Non-Federal Stakeholders in the Revision Process

GAO-08-768: Published: Jun 11, 2008. Publicly Released: Jun 11, 2008.

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Hurricane Katrina illustrated that effective preparation and response to a catastrophe requires a joint effort between federal, state, and local government. The Department of Homeland Security (DHS), through the Federal Emergency Management Agency (FEMA), is responsible for heading the joint effort. In January 2008, DHS released the National Response Framework (NRF), a revision of the 2004 National Response Plan (2004 Plan), the national preparation plan for all hazards. In response to the explanatory statement to the Consolidated Appropriations Act of 2008 and as discussed with congressional committees, this report evaluates the extent to which (1) DHS collaborated with non-federal stakeholders in revising and updating the 2004 Plan into the 2008 NRF and (2) FEMA has developed policies and procedures for managing future NRF revisions. To accomplish these objectives, GAO reviewed DHS and FEMA documents related to the revision process, analyzed the relevant statutes, and interviewed federal and non-federal officials who held key positions in the revision process.

While DHS included non-federal stakeholders--state, local, and tribal governments, nongovernmental organizations, and the private sector--in the initial and final stages of revising the 2004 Plan into the NRF, it did not collaborate with these stakeholders as fully as it originally planned or as required by the October 2006 Post-Katrina Emergency Management Reform Act (Post-Katrina Act). As the revision process began in 2006, DHS involved both federal and non-federal stakeholders by soliciting and incorporating their input in determining the key revision issues and developing the first draft in April 2007. However, after this first draft was completed, DHS deviated from its revision work plan by conducting a closed, internal federal review of the draft rather than releasing it for stakeholder comment because the draft required further modifications DHS considered necessary. DHS limited communication with non-federal stakeholders until it released a draft for public comment 5 months later on September 10, 2007. The following day, non-federal stakeholders testified at a congressional hearing that DHS had shut them out during that 5-month period. In addition, the Post-Katrina Act required that DHS establish a National Advisory Council (NAC) for the FEMA Administrator by December 2006 to, among other things, incorporate nonfederal stakeholders' input in the revision process. However, FEMA stated the necessary time to select quality NAC members required additional time, and FEMA did not announce the NAC's membership until June 2007. The NAC did not provide comments on a revision draft until one month before DHS publicly released the final NRF in January 2008. FEMA anticipates that the NRF will be revised in the future; however, FEMA does not have policies or procedures in place to guide this process or ensure a collaborative partnership with stakeholders. FEMA has emphasized the importance of partnering with relevant stakeholders to effectively prepare for and respond to major and catastrophic disasters, and the Congress, through the Post-Katrina Act, requires such partnership. In addition, the Standards for Internal Controls in the Federal Government calls for policies and procedures that establish regular communication with stakeholders and monitor performance over time as essential for achieving desired program goals. Furthermore, previous GAO work on the Department of Defense's civil support plans and the administration's national pandemic influenza implementation plan has shown the need for participation of state and local jurisdictions in emergency planning. Especially in view of a new administration, the experience of the previous revision process illustrates the importance of collaborating with stakeholders in revising a plan that relies on them for its successful implementation. While the NRF is published by DHS, it belongs to the nation's emergency response community. Developing such policies and procedures is essential for ensuring that FEMA attains the Post- Katrina Act's goal of partnering with non-federal stakeholders in building the nation's emergency management system, including the periodic review and revision of the NRF.

Recommendation for Executive Action

  1. Status: Closed - Implemented

    Comments: FEMA established provisions that direct the conditions and timing of revisions to the National Response Framework in DHS's Integrated Planning Guidance (a three-year revision cycle with the first revision by the end of fiscal year 2011), and developed a proposed National Response Framework Review and Revision Process paper for consideration by the Congress and National Advisory Council.

    Recommendation: The FEMA Administrator should develop and disseminate policies and procedures that describe (1) the circumstances and time frames under which the next NRF revision will occur and (2) how FEMA will conduct the next NRF revision, including how its National Advisory Council and other non-federal stakeholders--state, local, and tribal governments; the private sector; and nongovernmental organizations--will be integrated into the revision process and the methods for communicating with these stakeholders.

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


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