-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-160 					        				        
  TITLE:     Continuity of Operations: Improved Planning Needed to Ensure
Delivery of Essential Government Services  
     DATE:   02/27/2004

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Report to the Chairman, Committee on Government Reform, House of 
Representatives:

February 2004:

CONTINUITY OF OPERATIONS:

Improved Planning Needed to Ensure Delivery of Essential Government 
Services:

GAO-04-160:

GAO Highlights:

Highlights of GAO-04-160, a report to the Chairman, Committee on 
Government Reform, House of Representatives

Why GAO Did This Study:

To ensure that essential government services are available in 
emergenciesï¿½such as terrorist attacks, severe weather, or building-
level emergenciesï¿½federal agencies are required to develop continuity 
of operations (COOP) plans. Responsibility for formulating guidance on 
these plans and for assessing executive branch COOP capabilities lies 
with the Federal Emergency Management Agency (FEMA), under the 
Department of Homeland Security. FEMA guidance, Federal Preparedness 
Circular (FPC) 65 (July 1999), provides elements of a viable COOP 
capability, including the requirement that agencies identify their 
essential functions.

GAO was asked to determine the extent to which (1) major civilian 
executive branch agencies have identified their essential functions 
and (2) these agenciesï¿½ COOP plans follow FEMA guidance.

What GAO Found:

From an assessment of 34 COOP plans against FEMA guidance, GAO found 
that most agenciesï¿½ plans identified at least one function as 
essential. However, the functions identified in each plan varied widely 
in numberï¿½ranging from 3 to 399ï¿½and included functions that appeared to 
be of secondary importance, while at the same time omitting programs 
that had been previously defined as high-impact programs. (Examples of 
these high-impact programs are Medicare, food stamps, and border 
inspections.) For example, one department included ï¿½provide speeches 
and articles for the Secretary and Deputy Secretary,ï¿½ among its 
essential functions, but did not include 9 of 10 high-impact programs 
for which it is responsible. Several factors contributed to these 
shortcomings: FPC 65 did not provide specific criteria for identifying 
essential functions; FEMA did not review the essential functions 
identified when it assessed COOP planning; and it did not conduct tests 
or exercises to confirm that the essential functions were correctly 
identified. Unless agenciesï¿½ essential functions are correctly and 
completely identified, their COOP plans may not effectively ensure that 
the most vital government services can be maintained in an emergency.

Although all but three of the agencies reviewed had developed and 
documented some of the elements of a viable COOP plan, none of the 
agencies could demonstrate that they were following all the guidance in 
FPC 65. As the figure shows, there is a wide variation in the number of 
agencies that addressed various elements identified in the guidance. A 
contributing cause for the deficiencies in agency COOP plans is the 
level of FEMA oversight. In 1999, FEMA conducted an assessment of 
agency compliance with FPC 65, but it has not conducted oversight that 
is sufficiently regular and extensive to ensure that agencies correct 
the deficiencies identified. Because the resulting COOP plans do not 
include all the elements of a viable plan as defined by FPC 65, agency 
efforts to provide services during an emergency could be impaired.

What GAO Recommends:

To ensure that the executive branch can provide essential services 
during emergencies, GAO recommends, among other things, that the 
Secretary of Homeland Security take steps to improve agency COOP plans 
and FEMAï¿½s process for assessing these plans. In commenting on a draft 
of this report, the Under Secretary for Emergency Preparedness and 
Response agreed that FEMA could do more to improve COOP planning, and 
that FEMA has begun making such improvements. 

www.gao.gov/cgi-bin/getrpt?GAO-04-160.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Linda Koontz at (202) 
512-6240 or [email protected].

[End of section]

Contents:

Letter:

Results in Brief:

Background:

Many COOP Plans Did Not Address Previously Identified Essential 
Functions or Interdependencies with Other Entities:

Agency COOP Plans Addressed Some, but Not All, of FEMA's Guidance:

Conclusions:

Recommendations for Executive Action:

Agency Comments:

Appendixes:

Appendix I: Scope and Methodology:

Appendix II: Major Civilian Departments and Agencies Selected for 
Review:

Appendix III: Thirty-eight High-Impact Programs and Responsible 
Agencies:

Appendix IV: Component Agencies Reviewed, with High-Impact Program 
Responsibilities:

Appendix V: Comments from the Federal Emergency Management Agency:

Tables:

Table 1: Eight COOP Planning Topics Defined by FPC 65 and Examples of 
Actions:

Table 2: Agency COOP Plan Treatment of Essential Functions:

Table 3: Agency COOP Plan Treatment of Plans and Procedures:

Table 4: Agency COOP Plan Treatment of Order of Succession:

Table 5: Agency COOP Plan Treatment of Delegations of Authority:

Table 6: Agency COOP Plan Treatment of Alternate Facilities:

Table 7: Agency COOP Plan Treatment of Emergency Communications:

Table 8: Agency COOP Plan Treatment of Vital Records:

Table 9: Agency COOP Plan Treatment of Tests, Training, and Exercises:

Abbreviations: 

COOP: continuity of operations:

FEMA: Federal Emergency Management Agency:

FPC: Federal Preparedness Circular:

OMB: Office of Management and Budget:

PDD: Presidential Decision Directive:

Y2K: year 2000:

Letter February 27, 2004:

The Honorable Tom Davis Chairman, Committee on Government Reform: 
House of Representatives:

Dear Mr. Chairman:

As you know, essential government services can be interrupted by a 
range of events, including terrorist attacks, severe weather, or 
building-level emergencies. Federal agencies are required by 
Presidential Decision Directive (PDD) 67 to develop plans for ensuring 
the continuity of such services in emergency situations. This directive 
also designated the Federal Emergency Management Agency (FEMA) as 
executive agent for executive branch continuity of operations (COOP) 
planning, which includes the responsibility for formulating guidance on 
such planning and for assessing the status of executive branch COOP 
capabilities. In response, FEMA issued guidance to agencies, entitled 
Federal Preparedness Circular (FPC) 65, in July 1999. The circular 
states that in order to have a viable COOP capability, agencies should 
identify their essential functions. These functions then provide the 
basis for subsequent planning steps. The circular also identified eight 
elements of a viable COOP capability.

Concerned about the ability of the federal government to continue to 
provide essential services during an emergency, you requested us to 
report to you concerning some aspects of headquarters contingency plans 
from a number of civilian departments and agencies.[Footnote 1] Between 
June and August 2003, we presented your staff with a series of 
classified and unclassified briefings on the results of our review of 
these plans. In October 2003, you also requested us to review the 
actions that FEMA had taken to improve oversight since our assessment. 
This report includes the results of work done in response to both 
requests.

Our objectives were to determine:

* the extent to which major civilian executive branch agencies have 
identified their essential functions and:

* the extent to which these agencies' COOP plans follow the guidance 
provided in FPC 65.

To achieve our objectives, we obtained and evaluated the headquarters 
contingency plans in place as of October 1, 2002, from 20 of the 23 
largest civilian departments and agencies,[Footnote 2] as well as the 
headquarters plans for 15 components of civilian cabinet-level 
departments, selected because they were responsible for programs 
previously deemed high impact by the Office of Management and Budget 
(OMB). (Additional information on our scope and methodology can be 
found in app. I. The major departments and agencies reviewed are listed 
in app. II.)[Footnote 3] We also interviewed the agency officials 
responsible for developing these COOP plans, obtained and analyzed FEMA 
COOP guidance and documents describing its efforts to provide oversight 
and assessments of the federal COOP planning efforts, and interviewed 
FEMA officials to clarify the activities described in these documents.

We requested that the National Security Council provide us with a copy 
of PDD 67, which lays out the policy guidance for executive branch 
contingency planning and describes the authority granted to FEMA and 
other agencies. To date, we have not received a copy. Instead, we 
relied on the characterization of PDD 67 in FPC 65 and on statements 
from FEMA officials on the requirements within PDD 67. Without a copy 
of PDD 67, we were unable to verify the responsibilities or scope of 
authority of the various executive branch entities that are responsible 
for contingency planning. We conducted our assessment between April 
2002 and May 2003; in December 2003 and January 2004, we conducted 
additional work on FEMA's oversight actions. All of our work was 
conducted in accordance with generally accepted government auditing 
standards.

The Department of Homeland Security, of which FEMA became a part in 
March 2003, reviewed a draft of our briefing and determined that parts 
of it were classified. We provided a classified briefing to your staff 
on June 30, 2003, and an unclassified briefing (with the classified 
pages removed) on July 14, 2003. Upon discussion with Homeland Security 
officials, we were able to revise the briefing to include additional 
unclassified information, which we then provided to your staff in 
August 2003. This report responds to your October 2003 request that we 
publish our unclassified findings, updated to reflect FEMA's recent 
activities, and officially transmit our recommendations to the 
Secretary of Homeland Security.

Results in Brief:

Twenty-nine of the 34 COOP plans[Footnote 4] that we reviewed 
identified at least one essential function. However, the functions 
identified in these plans varied widely in number--ranging from 3 to 
399--and included functions that appeared to be of secondary 
importance. At the same time, the plans omitted many programs that OMB 
had previously identified as having a high impact on the public. 
Agencies did not list among their essential functions 20 of the 38 
high-impact programs that had been identified at those agencies. For 
example, one department included "provide speeches and articles for the 
Secretary and Deputy Secretary" among its essential functions, but it 
did not include 9 of its 10 high-impact programs. In addition, although 
many agency functions rely on the availability of resources or 
functions controlled by another organization, more than three-fourths 
of the plans did not fully identify such dependencies. Several factors 
contributed to these governmentwide shortcomings: FPC 65 does not 
provide specific criteria for identifying essential functions, nor does 
it address interdependencies; FEMA did not review the essential 
functions identified in its assessments of COOP planning or follow up 
with agencies to determine whether they addressed previously identified 
weaknesses; and it did not conduct tests or exercises that could 
confirm that the identified essential functions were correct. Although 
FEMA has begun efforts to develop additional guidance and conduct a 
governmentwide exercise, these actions have not yet been completed. 
Without better oversight, agencies are likely to continue to base their 
COOP plans on ill-defined assumptions that may limit the utility of the 
resulting plans.

While all but three of the agencies that we reviewed had developed and 
documented some elements of a COOP plan, none of the agencies provided 
documentation sufficient to show that they were following all the 
guidance in FPC 65. A contributing cause for the deficiencies in agency 
COOP plans is the level of FEMA oversight. In 1999, FEMA conducted an 
assessment of agency compliance with FPC 65, but it has not conducted 
oversight that is sufficiently regular and extensive to ensure that 
agencies correct deficiencies identified. FEMA officials told us that 
they plan to improve oversight by providing more detailed guidance and 
developing a system to collect data from agencies on their COOP 
readiness. However, FEMA has not yet determined how it will verify the 
agency-reported data, assess the essential functions and 
interdependencies identified, or use the data to conduct regular 
oversight. If FEMA does not address these shortcomings, agency COOP 
plans may not be effective in ensuring that the most vital government 
services can be maintained in an emergency.

In light of the essential need for agencies to develop viable COOP 
plans and FEMA's responsibility for overseeing the development of such 
plans, we are recommending that the Secretary of Homeland Security 
direct the Under Secretary for Emergency Preparedness and Response to 
take steps to ensure that agencies have plans in place and improve 
FEMA's oversight of existing plans.

In commenting on a draft of this report, the Under Secretary agreed 
that better COOP planning is needed, and that FEMA could do more to 
improve COOP planning. He added that the agency has begun making such 
improvements and stated that the federal government is currently poised 
to provide services in an emergency. The Under Secretary's commitment 
to improve FEMA's oversight of COOP planning can be instrumental in 
ensuring that agencies prepare adequate plans. Specifically, once FEMA 
ensures that each agency has a COOP plan, ensures that agencies correct 
the identified deficiencies in existing plans, and conducts independent 
verification and assessments of those plans, it will be in a position 
to effectively demonstrate the readiness of federal agencies to respond 
to emergencies.

Background:

Federal operations and facilities have been disrupted by a range of 
events, including the terrorist attacks on September 11, 2001; the 
Oklahoma City bombing; localized shutdowns due to severe weather 
conditions, such as the closure of federal offices in Denver for 3 days 
in March 2003 due to snow; and building-level events, such as asbestos 
contamination at the Department of the Interior's headquarters. Such 
disruptions, particularly if prolonged, can lead to interruptions in 
essential government services. Prudent management, therefore, requires 
that federal agencies develop plans for dealing with emergency 
situations, including maintaining services, ensuring proper authority 
for government actions, and protecting vital assets.

Until relatively recently, continuity planning was generally the 
responsibility of individual agencies. In October 1998, PDD 67 
identified FEMA--which is responsible for responding to, planning for, 
recovering from, and mitigating against disasters--as the executive 
agent for federal COOP planning across the federal executive branch. 
FEMA was an independent agency until March 2003, when it became part of 
the Department of Homeland Security, reporting to the Under Secretary 
for Emergency Preparedness and Response.

PDD 67 is a Top Secret document controlled by the National Security 
Council. FPC 65 states that PDD 67 made FEMA, as executive agent for 
COOP, responsible for:

* formulating guidance for agencies to use in developing viable plans;

* coordinating interagency exercises and facilitating interagency 
coordination, as appropriate; and:

* overseeing and assessing the status of COOP capabilities across the 
executive branch.

According to FEMA officials, PDD 67 also required that agencies have 
COOP plans in place by October 1999.

In July 1999, FEMA issued FPC 65 to assist agencies in meeting the 
October 1999 deadline. FPC 65 states that COOP planning should address 
any emergency or situation that could disrupt normal operations, 
including localized emergencies. FPC 65 also determined that COOP 
planning is based first on the identification of essential functions--
that is, those functions that enable agencies to provide vital 
services, exercise civil authority, maintain safety, and sustain the 
economy during an emergency. FPC 65 gives no criteria for identifying 
essential functions beyond this definition.

Although FPC 65 gives no specific criteria for identifying essential 
functions, a logical starting point for this process would be to 
consider programs that had been previously identified as important. For 
example, in March 1999, as part of the efforts to address the Y2K 
computer problem,[Footnote 5] the Director of OMB identified 42 
programs with a high impact on the public:

* Of these 42 programs, 38 were the responsibility of the 23 major 
departments and agencies that we reviewed. (App. III provides a list of 
these 38 high-impact programs and the component agencies that are 
responsible for them.):

* Of these 23 major departments and agencies, 16 were responsible for 
at least one high-impact program; several were responsible for more 
than one.

Programs that were identified included weather service, disease 
monitoring and warnings, public housing, air traffic control, food 
stamps, and Social Security benefits. These programs, as well as the 
others listed in appendix III, continue to perform important functions 
for the public.

The Y2K planning to support these high-impact programs included COOP 
planning and specifically addressed interdependencies. Planning 
included identifying partners integral to program delivery, testing 
data exchanges across partners, developing complementary business 
continuity and contingency plans, sharing key information on readiness 
with other partners and the public, and taking other steps to ensure 
that the agency's high-impact program would work in the event of an 
emergency.

Although the identification of essential functions was established as 
the first step in COOP planning, FPC 65 also identified an additional 
seven other planning topics that make up a viable COOP capability. The 
guidance provided a general definition of each of the eight topics and 
identified several actions that should be completed to address each 
topic. Table 1 lists the eight topic areas covered in FPC 65 and 
provides an example of an action under each.

Table 1: Eight COOP Planning Topics Defined by FPC 65 and Examples of 
Actions:

FPC 65 planning topic: Essential functions should be identified to 
provide the basis for COOP planning; 
Example of action (element of viable COOP plan): The agency should 
prioritize its essential functions.

FPC 65 planning topic: Plans and procedures should be developed and 
documented to provide for continued performance of essential functions; 
Example of action (element of viable COOP plan): These plans should 
include a roster of personnel who can perform the essential functions.

FPC 65 planning topic: Orders of succession should identify alternates 
to fill key positions in an emergency; 
Example of action (element of viable COOP plan): Succession lists 
should be developed for the agency head and other key positions.

FPC 65 planning topic: Delegations of authority should identify the 
legal basis for officials to make decisions in emergencies; 
Example of action (element of viable COOP plan): Delegations should 
include the circumstances under which the authorities begin and end.

FPC 65 planning topic: Alternate facilities should be able to support 
operations in a threat-free environment for up to 30 days; 
Example of action (element of viable COOP plan): These facilities 
should provide sufficient space and equipment to sustain the relocating 
organization.

FPC 65 planning topic: Interoperable communications should provide 
voice and data communications with others inside and outside the 
organization; 
Example of action (element of viable COOP plan): The agency should be 
able to communicate with agency personnel, other agencies, critical 
customers, and the public.

FPC 65 planning topic: Vital records should be identified and made 
readily available in an emergency; 
Example of action (element of viable COOP plan): Electronic and paper 
records should be identified and protected.

FPC 65 planning topic: Tests, training, and exercises should occur 
regularly to demonstrate and improve agencies' COOP capabilities; 
Example of action (element of viable COOP plan): Individual and team 
training should be conducted annually. 

Sources: FPC 65, FEMA.

[End of table]

Many COOP Plans Did Not Address Previously Identified Essential 
Functions or Interdependencies with Other Entities:

The identification of essential functions is a prerequisite for COOP 
planning because it establishes the planning parameters that drive the 
agency's efforts in all other planning topics. For example, FPC 65 
directs agencies to identify alternative facilities, staff, and 
resources necessary to support continuation of their essential 
functions. The effectiveness of the plan as a whole and the 
implementation of all other elements depend on the performance of this 
step.

Of the 34 agency COOP plans we reviewed, 29 plans included at least one 
function that was identified as essential. These agency-identified 
essential functions varied in number and scope. The number of functions 
identified in each plan ranged from 3 to 399. In addition, the apparent 
importance of the functions was not consistent. For example, a number 
of essential functions were of clear importance, such as:

* "ensuring uninterrupted command, control, and leadership of the 
Department";

* "protecting critical facilities, systems, equipment and records"; 
and:

* "continuing to pay the government's obligations.":

Other identified functions appeared vague or of questionable 
importance:

* "provide speeches and articles for the Secretary and Deputy 
Secretary";

* "schedule all activities of the Secretary"; and:

* "review fiscal and programmatic integrity and efficiency of 
Departmental activities.":

In contrast to the examples just given, agencies did not list among 
their essential functions 20 of the 38 "high-impact" programs 
identified during the Y2K effort at the agencies we reviewed.

Another important consideration in identifying essential functions is 
the assessment of interdependencies among functions and organizations. 
As we have previously reported,[Footnote 6] many agency functions rely 
on the availability of resources or functions controlled by another 
organization, including other agencies, state and local governments, 
and private entities. (For example, the Department of the Treasury's 
Financial Management Service receives and makes payments for most 
federal agencies.) The identification of such interdependencies 
continues to be essential to the related areas of information security 
and critical infrastructure protection. Although FPC 65 does not use 
the term "interdependencies," it directs agencies to "integrate 
supporting activities to ensure that essential functions can be 
performed.":

Of the 34 plans we reviewed, 19 showed no evidence of an effort to 
identify interdependencies and link them to essential functions, which 
is a prerequisite to developing plans and procedures to support these 
functions and all other elements of COOP planning. Nine plans 
identified some key partners, but appeared to have excluded others: for 
instance, six agencies either make or collect payments, but did not 
mention the role of the Treasury Department in their COOP plans.

The high level of generality in FEMA's guidance on essential functions 
contributed to the inconsistencies in agencies' identification of these 
functions. In its initial guidance, FPC 65, FEMA provided minimal 
criteria for agencies to make these identifications, giving a brief 
definition only. According to FEMA officials, the agency is currently 
developing revised COOP guidance that will provide more specific 
direction on identifying essential functions. According to these 
officials, FEMA expects to release the revised guidance in March 2004.

Further, although FEMA conducted several assessments of agency COOP 
planning between 1995 and 2001, none of these addressed the 
identification of essential functions. In addition, FEMA has begun 
development of a system to collect data from agencies on the readiness 
of their COOP plans, but FEMA officials told us that they will not use 
the system to validate the essential functions identified by each 
agency or their interdependencies. According to FEMA officials, the 
agencies are better able to make those determinations. However, 
especially in view of the wide variance in number and importance of 
functions identified, as well as omissions of high-impact programs, the 
lack of FEMA review lowers the level of assurance that the essential 
functions that have been identified are appropriate.

Additionally, in its oversight role, FEMA had the opportunity to help 
agencies refine their essential functions through an interagency COOP 
test or exercise. According to FPC 65, FEMA is responsible for 
coordinating such exercises. FEMA is developing a test and training 
program for COOP activities, but it has not yet conducted an 
interagency exercise to test the feasibility of these planned 
activities. FEMA had planned a governmentwide exercise in 2002, but the 
exercise was cancelled after the September 11 attacks. FEMA is 
currently preparing to conduct a governmentwide exercise in mid-May 
2004.

Improper identification of essential functions can have a negative 
impact on the entire COOP plan, because other aspects of the COOP plan 
are designed around supporting these functions. If an agency fails to 
identify a function as essential, it will not make the necessary 
arrangements to perform that function. If it identifies too many 
functions as essential, it risks being unable to adequately address all 
of them. In either case, the agency increases the risk that it will not 
be able to perform its essential functions in an emergency.

Agency COOP Plans Addressed Some, but Not All, of FEMA's Guidance:

As of October 1, 2002, almost 3 years after the planning deadline 
established by PDD 67, 3 of the agencies we reviewed had not developed 
and documented a COOP plan. The remaining 20 major federal civilian 
agencies had COOP plans in place, and the 15 components[Footnote 7] 
that we reviewed also had plans. (App. IV identifies the 15 components 
and the high-impact programs for which they are responsible.) However, 
none of these plans addressed all the guidance in FPC 65. Of the eight 
topic areas identified in FPC 65, these 34 COOP plans generally 
complied with the guidance in one area (developing plans and 
procedures); generally did not comply in one area (tests, training, and 
exercises); and showed mixed compliance in the other six areas.

The following sections present the results of our analysis for each of 
the eight planning topics outlined in FPC 65. In analyzing each plan, 
we looked for the answers to a series of questions regarding each 
planning topic. We present the compiled results for each topic in the 
form of a table showing the answers to these questions. Appendix I 
provides more detail on our analysis and methods.

Essential Functions:

Although most agency plans identified at least one essential function, 
less than half the COOP plans fully addressed other FPC 65 guidance 
related to essential functions, such as prioritizing the functions or 
identifying interdependencies among them (see table 2). If agencies do 
not prioritize their essential functions and identify the resources 
that are necessary to accomplish them, their COOP plans will not be 
effective, since the other seven topics of the COOP plan are designed 
around supporting these functions.

Table 2: Agency COOP Plan Treatment of Essential Functions:

Did the COOP documentation- 
Identify agency's essential functions?[A]; 
Yes: 25; 
Partially: 4; 
No: 5.

Did the COOP documentation- 
Identify which essential functions must be continued under all 
circumstances? 
Yes: 14; 
Partially: 3; 
No: 17.

Did the COOP documentation- 
Prioritize essential functions? 
Yes: 13; 
Partially: 2; 
No: 19.

Did the COOP documentation- 
Establish staffing and resource requirements needed to perform the 
essential functions? 
Yes: 8; 
Partially: 20; 
No: 6.

Did the COOP documentation- 
Identify mission-critical systems and data necessary to conduct 
essential functions? 
Yes: 7; 
Partially: 12; 
No: 15.

Did the COOP documentation- 
Integrate supporting activities/identify interdependencies among the 
essential functions and functions or resources controlled by others? 
Yes: 6; 
Partially: 9; 
No: 19.

Source: GAO analysis of agency plans.

[A] The analysis for this question addressed only whether essential 
functions were named; it did not evaluate the functions chosen.

[End of table]

Plans and Procedures:

FPC 65 calls for COOP plans to be developed and documented that provide 
for the performance of essential functions under all circumstances. 
Most agency COOP documents included the basic information outlined in 
FPC 65 (see table 3). However, in those cases where plans and 
procedures are not adequately documented, agency personnel may not know 
what to do in an emergency.

Table 3: Agency COOP Plan Treatment of Plans and Procedures:

Did the COOP documentation-- 
Identify a roster of personnel to perform essential functions? 
Yes: 22; 
Partially: 6; 
No: 6.

Did the COOP documentation-- 
Identify procedures for employee advisories, alerts, notifications, and 
relocation instructions to the alternate facilities? 
Yes: 19; 
Partially: 11; 
No: 4.

Did the COOP documentation-- 
Establish a goal of becoming operational within 12 hours and 
maintaining that capability for 30 days? 
Yes: 25; 
Partially: 4; 
No: 5.

Source: GAO analysis of agency plans.

[End of table]

Order of Succession:

Orders of succession ensure continuity by identifying individuals who 
are authorized to act for agency officials in case those officials are 
unavailable. Although most agency COOP documents adequately described 
the order of succession to the agency head and described orders of 
succession by position or title, fewer addressed other succession 
planning procedures outlined in FPC 65 (see table 4). If orders of 
succession are not clearly established, agency personnel may not know 
who has authority and responsibility if agency leadership is 
incapacitated in an emergency.

Table 4: Agency COOP Plan Treatment of Order of Succession:

Did the COOP documentation-- 
Establish an order of succession to the agency head position? 
Yes: 28; 
Partially: 4; 
No: 2.

Did the COOP documentation-- 
Establish orders of succession to other key leadership positions? 
Yes: 19; 
Partially: 6; 
No: 9.

Did the COOP documentation-- 
Include officials outside Washington, D.C., in the order of 
succession?[A]; 
Yes: 19; 
Partially: 1; 
No: 11.

Did the COOP documentation-- 
Describe orders of succession by position or title? 
Yes: 31; 
Partially: 2; 
No: 1.

Did the COOP documentation-- 
Include the orders of succession in the agency's emergency vital 
records? 
Yes: 6; 
Partially: 4; 
No: 24.

Did the COOP documentation-- 
Establish rules and procedures for resolving questions regarding 
succession in emergencies? 
Yes: 14; 
Partially: 3; 
No: 17.

Did the COOP documentation-- 
Define the conditions under which succession takes place and how 
successors are to be relieved? 
Yes: 9; 
Partially: 20; 
No: 5.

Did the COOP documentation-- 
Require orientation programs to prepare potential successors for their 
emergency duties? 
Yes: 0; 
Partially: 7; 
No: 27.

Source: GAO analysis of agency plans.

[A] Three agencies did not have senior officials outside the local 
area.

[End of table]

Delegations of Authority:

To provide for rapid response to emergencies, FPC 65 calls for agencies 
to delegate authorities in advance for making policy determinations at 
all levels. Generally, these delegations define what actions those 
individuals identified in the orders of succession can take in 
emergencies. Few agency COOP documents adequately described the 
agency's delegations of authority (see table 5). If delegations of 
authority are not clearly established, agency personnel may not know 
who has authority to make key decisions in an emergency.

Table 5: Agency COOP Plan Treatment of Delegations of Authority:

Did the COOP documentation-- 
Document the legal authority for officials (including those below the 
agency head) to make policy decisions during an emergency? 
Yes: 8; 
Partially: 16; 
No: 10.

Did the COOP documentation-- 
Identify when emergency legal authorities begin and when they 
terminate? 
Yes: 5; 
Partially: 20; 
No: 9.

Source: GAO analysis of agency plans.

[End of table]

Alternate Facilities:

Alternate facilities provide a physical location from which to conduct 
essential functions if the agency's existing facilities are 
unavailable. Most agency COOP plans document the acquisition of at 
least one alternate facility for use in emergencies, but few of those 
plans demonstrate that the facilities are capable of meeting the 
agencies' emergency operating requirements (see table 6). If alternate 
facilities are not provided or are inadequate, agency operations may 
not be able to continue in an emergency.

Table 6: Agency COOP Plan Treatment of Alternate Facilities:

Did the COOP documentation-- 
Document the acquisition of alternate facilities? 
Yes: 24; 
Partially: 6; 
No: 4.

Did the COOP documentation-- 
Identify alternate facilities both within and outside the local area? 
Yes: 20; 
Partially: 11; 
No: 3.

Did the COOP documentation-- 
Document the facilities' capability to provide sufficient space and 
equipment for the previously identified level of staff?a; 
Yes: 2; 
Partially: 16; 
No: 15.

Did the COOP documentation-- 
Document the capability to provide interoperable communications with 
internal and external organizations, critical customers, and the 
public? 
Yes: 5; 
Partially: 15; 
No: 14.

[End of table]

Source: GAO analysis of agency plans.

[A] The number of assessments adds to 33 rather than 34 because one 
agency does not relocate staff to an alternate facility. Instead, it 
transfers operational responsibility to staff in place at another 
location.

Redundant Emergency Communications:

The success of agency operations at an alternate facility depends on 
available and redundant communications with internal organizations, 
other agencies, critical customers, and the public. Most COOP documents 
identified some redundant emergency communications capabilities, but 
few included contact information that would be necessary to use those 
capabilities in an emergency (see table 7). If communications fail in 
an emergency, essential agency operations may not be possible.

Table 7: Agency COOP Plan Treatment of Emergency Communications:

Did the COOP documentation-- 
Identify at least two independent channels for emergency 
communications? 
Yes: 25; 
Partially: 2; 
No: 7.

Did the COOP documentation-- 
Identify key internal and external contacts and how to reach them? 
Yes: 10; 
Partially: 10; 
No: 14.

Did the COOP documentation-- 
Identify how emergency communications channels will be used to access 
the agency's vital electronic systems? 
Yes: 3; 
Partially: 4; 
No: 27.

[End of table]

Source: GAO analysis of agency plans.

Vital Records:

FPC 65 states that agency personnel must have access to and be able to 
use the electronic and hard-copy records and information systems that 
are needed to perform their essential functions. About 24 percent of 
the COOP plans fully identified agencies' vital paper and electronic 
records, while fewer documented the procedures for protecting or 
updating them (see table 8). If agency personnel cannot access and use 
up-to-date vital records, they may be unable to carry out essential
functions.

Table 8: Agency COOP Plan Treatment of Vital Records:

Did the COOP documentation-- 
Identify the vital records needed to support the identified essential 
functions? 
Yes: 8; 
Partially: 13; 
No: 13.

Did the COOP documentation-- 
Identify where and how agency personnel are to access the vital 
records? 
Yes: 2; 
Partially: 10; 
No: 22.

Did the COOP documentation-- 
Outline procedures for regularly pre- positioning and updating the 
identified vital records? 
Yes: 3; 
Partially: 15; 
No: 16.

[End of table]

Source: GAO analysis of agency plans.

Tests, Training, and Exercises:

Tests, training, and exercises of COOP capabilities are essential to 
demonstrate and improve agencies' abilities to execute their plans. Few 
agencies have documented that they have conducted tests, training, and 
exercises at the recommended frequency (see table 9). If emergency 
procedures are not tested and staff is not trained in their use, 
planned responses to an emergency may not be adequate to continue 
essential functions.

Table 9: Agency COOP Plan Treatment of Tests, Training, and Exercises:

Did the agency-- 
Conduct annual individual and team training for COOP staff? 
Yes: 1; 
Partially: 11; 
No: 22.

Did the agency-- 
Conduct annual internal agency testing and exercising of COOP plans and 
procedures, including operations at the alternate facilities? 
Yes: 3; 
Partially: 10; 
No: 21.

Did the agency-- 
Conduct quarterly testing of alert and notification procedures? 
Yes: 0; 
Partially: 10; 
No: 24.

Did the agency-- 
Conduct refresher orientations for staffs arriving at alternate 
facilities?[A]; 
Yes: 0; 
Partially: 0; 
No: 33.

Did the agency-- 
Conduct joint agency exercises, where applicable and feasible?[B]; 
Yes: 1; 
Partially: 0; 
No: 29. 

Source: GAO analysis of agency plans.

[A] One agency transfers operations, rather than relocating to an 
alternate facility.

[B] Four agencies determined that it was not appropriate to run 
interagency exercises.

[End of table]

Limitations in FEMA's Oversight Contribute to Noncompliance:

The lack of compliance shown by many COOP plans can be largely 
attributed to FEMA's limited guidance and oversight of executive branch 
COOP planning. First, FEMA has issued little guidance to assist 
agencies in developing plans that address the goals of FPC 65. 
Following FPC 65, FEMA issued more detailed guidance in April 2001 on 
two of FPC 65's eight topic areas: FPC 66 provides guidance on 
developing viable test, training, and exercise programs, and FPC 67 
provides guidance for acquiring alternate facilities. However, FEMA did 
not produce any detailed guidance on the other six topic areas.

In October 2003, FEMA began working with several members of the 
interagency COOP working group to revise FPC 65. FEMA officials expect 
this revised guidance, which was still under development as of January 
2004, to incorporate the guidance from the previous FPCs and to address 
more specifically what agencies need to do to comply with the guidance.

Second, as part of FEMA's oversight responsibilities, its Office of 
National Security Coordination is tasked with conducting comprehensive 
assessments of the federal executive branch COOP programs. With the 
assistance of contractors, the office has performed assessments, on an 
irregular schedule, of federal agencies' emergency planning 
capabilities:

* In 1995, FEMA performed a survey of agency officials (this assessment 
predated FPC 65).

* In 1999, FEMA assessed compliance with the elements of FPC 65 through 
a self-reported survey of agency COOP officials, supplemented by 
interviews.

* In 2001, FEMA surveyed agency officials to ask, among other things, 
about actions that agencies took on and immediately after September 11, 
2001.

Of these three assessments, only the 1999 assessment evaluated 
compliance with the elements of FPC 65. Following this assessment, FEMA 
gave agencies feedback on ways to improve their respective COOP plans, 
and it made general recommendations, not specific to individual 
agencies, that addressed programwide problems. However, FEMA did not 
then follow up to determine whether individual agencies made 
improvements in response to its feedback and general recommendations. 
Besides inquiring about actions in response to the September 2001 
attacks, the 2001 assessment was designed to provide an update on 
programwide problems that had been identified in the assessments of 
1995 and 1999. It did not address whether individual agency COOP plans 
had been revised to correct previously identified deficiencies, nor did 
FEMA provide specific feedback to individual agencies.

According to FEMA officials, the system it is developing to collect 
agency-reported data on COOP plan readiness will improve FEMA's 
oversight. The system is based on a database of information provided by 
agencies for the purpose of determining if they are prepared to 
exercise their COOP plans, in part by assessing compliance with FPC 65. 
However, according to FEMA officials, while they recognize the need for 
some type of verification, FEMA has not yet determined a method of 
verifying these data.

Without regular assessments of COOP plans that evaluate individual 
plans for adequacy, FEMA will not be able to provide information to 
help agencies improve their COOP plans. Further, if FEMA does not 
verify the data provided by the agencies or follow up to determine 
whether agencies have improved their plans in response to such 
assessments, it will have no assurance that agencies' emergency 
procedures are appropriate.

FEMA officials attributed the limited level of oversight that we found 
to two factors. First, they stated that before its transition to the 
Department of Homeland Security, the agency did not have the legal or 
budgetary authority to conduct more active oversight of the COOP 
activities of other agencies. However, FPC 65 states that PDD 67 made 
the agency responsible for guidance, coordination, and oversight in 
this area, in addition to requiring agencies to develop COOP plans. 
Accordingly, although it cannot determine how agencies budget resources 
for such planning, it does have the authority to oversee this planning. 
Second, according to these officials, until last year, the agency 
devoted roughly 13 staff to COOP guidance, coordination, and oversight, 
as well as the development of FEMA's own COOP plan. According to the 
official responsible for COOP oversight, the agency now has 42 
positions authorized for COOP activities, 31 of which were filled as of 
December 31, 2003. The agency expects to fill another 4 positions in 
fiscal year 2004.

Conclusions:

While most of the federal agencies we reviewed had developed COOP 
plans, three agencies did not have documented plans as of October 2002. 
Those plans that were in place exhibited weaknesses in the form of 
widely varying determinations about what functions are essential and 
inconsistent compliance with guidance that defines a viable COOP 
capability. The weaknesses that we identified could cause the agencies 
to experience difficulties in delivering key services to citizens in 
the aftermath of an emergency.

A significant factor contributing to this condition is FEMA's limited 
efforts to fulfill its responsibilities first by providing guidance to 
help agencies develop effective plans and then by assessing those 
plans. Further, FEMA has done very little to help agencies identify 
those functions that are truly essential or to identify and plan for 
interdependencies among agency functions. FEMA has begun taking steps 
to improve its oversight, by developing more specific guidance and a 
system to track agency-provided COOP readiness information, and it is 
planning a governmentwide exercise. However, although the proposed 
guidance and exercise may help agencies improve their plans, the system 
that FEMA is developing to collect data on COOP readiness is weakened 
by a lack of planning to verify agency-submitted data, validate agency-
identified essential functions, or identify interdependencies with 
other activities. Without this level of active oversight, continuity 
planning efforts will continue to fall short and increase the risk that 
the public will not be able to rely upon the continued delivery of 
essential government programs and services following an emergency.

Recommendations for Executive Action:

We are making three recommendations to enhance the ability of the 
executive branch to continue to provide essential services during 
emergencies.

* To ensure that agencies can continue operations in emergencies and 
are prepared for the governmentwide exercise planned for May 2004, we 
recommend that the Secretary of Homeland Security direct the Under 
Secretary for Emergency Preparedness and Response to take steps to 
ensure that agencies that do not have COOP plans develop them by May 1, 
2004.

We further recommend that the Secretary direct the Under Secretary to 
take steps to improve the oversight of COOP planning by:

* ensuring that agencies correct the deficiencies in individual COOP 
plans identified here, as well as those identified in previous 
assessments, and:

* conducting assessments of agency continuity plans that include 
independent verification of agency-provided information, as well as an 
assessment of the essential functions identified and their 
interdependencies with other activities.

Agency Comments:

In written comments on a draft of this report, which are reprinted in 
appendix V, the Under Secretary for Emergency Preparedness and Response 
agreed that better COOP planning is needed to ensure delivery of 
essential services, and that FEMA could do more to improve COOP 
planning. He added that the agency has begun to correct the identified 
deficiencies and stated that the federal government is currently poised 
to provide services in an emergency. The Under Secretary's commitment 
to improve FEMA's oversight of COOP planning can be instrumental in 
ensuring that agencies prepare adequate plans. Specifically, once FEMA 
ensures that each agency has a COOP plan, ensures that agencies correct 
the identified deficiencies in existing plans, and conducts independent 
verification and assessments of those plans, it will be in a position 
to effectively demonstrate the readiness of federal agencies to respond 
to emergencies.

As agreed with your office, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 30 days 
from the date of this report. At that time, we will send copies to the 
Chairmen and Ranking Minority Members of the Subcommittee on Homeland 
Security, House Committee on Appropriations; Subcommittee on National 
Security, Emerging Threats, and International Relations, House 
Committee on Government Reform; and the Subcommittee on Oversight of 
Government Management, the Federal Workforce, and the District of 
Columbia, Senate Committee on Governmental Affairs. We are also sending 
copies to the Secretary of Homeland Security. We will also make copies 
available on request. In addition, the report will be available at no 
charge on the GAO Web site at [Hyperlink, http://www.gao.gov].

Should you have any questions on matters contained in this report, 
please contact me at (202) 512-6240 or by e-mail at [Hyperlink, 
[email protected]]. Other key contributors to this report 
were Barbara Collier, Mirko Dolak, Neela Lakhmani, Susan Sato, James R. 
Sweetman, Jr., Jessie Thomas, and Marcia Washington.

Sincerely yours,

Signed by:

Linda D. Koontz 
Director, Information Management Issues:

[End of section]

Appendixes:

[End of section]

Appendix I: Scope and Methodology:

To accomplish our objectives, we obtained and evaluated headquarters 
contingency plans that were in place as of October 1, 2002, from 20 of 
the 23 largest civilian departments and agencies[Footnote 8] (listed in 
app. II). We also obtained and evaluated 14 plans covering 15 
components[Footnote 9] of civilian cabinet-level departments, selected 
because these components were responsible for a program previously 
deemed high impact by the Office of Management and Budget (OMB). (App. 
III lists these components and the high-impact programs.) We also 
interviewed agency officials who were responsible for developing each 
of the 34 continuity of operations (COOP) plans (comprising the 20 
plans for the largest civilian departments and agencies and the 14 
plans covering components with high-impact programs); obtained and 
analyzed COOP guidance issued by the Federal Emergency Management 
Agency (FEMA) and documents describing its efforts to provide oversight 
and assessments of federal COOP planning efforts; and conducted 
interviews with FEMA officials to clarify the activities described in 
these documents.

To assess the adequacy of agency-identified essential functions, we 
analyzed the COOP plans from agencies that were responsible for 
programs that OMB designated as having high impact to determine whether 
the plans described how those programs would continue to function 
during an emergency, and we assessed COOP documentation for evidence of 
agency efforts to identify interdependencies between their essential 
functions and functions or resources controlled by others. For example, 
for those agencies responsible for processing incoming or outgoing 
payments, we looked for evidence that the agency had identified 
services provided by the Department of the Treasury as necessary to the 
continuation of its functions.

To assess how well agency plans followed Federal Preparedness Circular 
(FPC) 65, we analyzed the guidance and identified 34 yes/no questions, 
grouped by the eight topic areas identified in FPC 65. Each topic area 
included two to eight questions. On the basis of the agency contingency 
planning documents, we used content analysis to assign an answer of 
"yes" (compliant), "no" (not compliant), or "partially" to these 34 
questions.

Documents were reviewed and compared independently by several of our 
analysts. The analysts then met to compare their assessments and reach 
a consensus assessment. We shared these initial assessments with each 
agency during structured interviews, giving agency officials the 
opportunity to provide additional documentation to demonstrate 
compliance. Any supplemental information provided by the agencies was 
again reviewed by multiple analysts, first independently and then 
jointly.

From this analysis, we created the summary tables that appear in this 
report (tables 2 to 9) to compare answers across agencies.

We requested that the National Security Council provide a copy of 
Presidential Decision Directive (PDD) 67, which lays out the policy 
guidance for executive branch contingency planning and describes the 
authority granted to FEMA and other agencies. To date, we have not 
received a copy. Instead, we relied on the characterization of PDD 67 
in FPC 65 and on statements from FEMA officials on the requirements 
within PDD 67. Without a copy of PDD 67, we were unable to verify the 
responsibilities or scope of authority of the various executive branch 
entities responsible for contingency planning.

We conducted our review between April 2002 and January 2004, in 
accordance with generally accepted government auditing standards.

[End of section]

Appendix II: Major Civilian Departments and Agencies Selected for 
Review:

Department of Agriculture; 
Department of Commerce; 
Department of Education; 
Department of Energy; 
Department of Health and Human Services; 
Department of Housing and Urban Development; 
Department of Justice; 
Department of Labor; 
Department of State; 
Department of the Interior; 
Department of the Treasury; 
Department of Transportation; 
Department of Veterans Affairs; 
Agency for International Development; 
Environmental Protection Agency; 
Federal Emergency Management Agency; 
General Services Administration; 
National Aeronautics and Space Administration; 
National Science Foundation; 
Nuclear Regulatory Commission; 
Office of Personnel Management; 
Small Business Administration; 
Social Security Administration:

[End of section]

Appendix III: Thirty-eight High-Impact Programs and Responsible 
Agencies:

Agency: Department of Agriculture; 
High-impact programs: 
Food safety inspection; 
Child nutrition programs; 
Food stamps; 
Special supplemental nutrition program for women, infants, and 
children.

Agency: Department of Commerce; 
High-impact programs: 
Patent and trademark processing; 
Weather service.

Agency: Department of Education; 
High-impact programs: 
Student aid.

Agency: Department of Energy; 
High-impact programs: 
Federal electric power generation and delivery.

Agency: Department of Health and Human Services; 
High-impact programs: 
Disease monitoring and warnings; 
Indian health services; 
Medicaid; 
Medicare; 
Organ transplants; 
Child care; 
Child support enforcement; 
Child welfare; 
Low income home energy assistance; 
Temporary assistance for needy families.

Agency: Department of Housing and Urban Development; 
High-impact programs: 
Community development block grants; 
Housing loans; 
Mortgage insurance; 
Section 8 rental assistance; 
Public housing.

Agency: Department of Justice; 
High-impact programs: 
Federal prisons; 
Immigration.

Agency: Department of Labor; 
High-impact programs: 
Unemployment insurance.

Agency: Department of State; 
High-impact programs: 
Passport applications and processing.

Agency: Department of the Interior; 
High-impact programs: 
Bureau of Indian Affairs programs.

Agency: Department of the Treasury; 
High-impact programs: 
Cross-border inspection services.

Agency: Department of Transportation; 
High-impact programs: 
Air traffic control system; 
Maritime search and rescue.

Agency: Department of Veterans Affairs; 
High-impact programs: 
Veterans' benefits; 
Veterans' health care.

Agency: Federal Emergency Management Agency; 
High-impact programs: 
Disaster relief.

Agency: Office of Personnel Management; 
High-impact programs: 
Federal employee health benefits; 
Federal employee life insurance; 
Federal employee retirement benefits.

Agency: Social Security Administration; 
High-impact programs: 
Social Security benefits. 

Source: GAO analysis of OMB guidance.

[End of table]

[End of section]

Appendix IV: Component Agencies Reviewed, with High-Impact Program 
Responsibilities:

Department: Department of Commerce; 
Component: National Oceanic and Atmospheric Administration; 
High-impact programs: Weather service.

Component: Patent and Trademark Office; 
High-impact programs: Patent and trademark processing.

Department: Department of Health and Human Services; 
Component: Centers for Disease Control and Prevention; 
High-impact programs: Disease monitoring and warnings.

Component: Center for Medicare and Medicaid Services; 
High-impact programs: Medicare and Medicaid.

Component: Food and Drug Administration; 
High-impact programs: Organ transplants.

Component: Indian Health Service; 
High-impact programs: Indian health services.

Department: Department of Housing and Urban Development; 
Component: Government National Mortgage Association; 
High-impact programs: Housing loans.

Component: Office of Community Planning and Development; 
High-impact programs: Community development block grants.

Component: Office of Housing; 
High-impact programs: Section 8 rental assistance and mortgage 
insurance.

Component: Office of Public and Indian Housing; 
High-impact programs: Public housing.

Department: Department of the Interior; 
Component: Bureau of Indian Affairs; 
High-impact programs: Indian affairs programs.

Department: Department of the Treasury; 
Component: U.S. Customs Service; 
High-impact programs: Cross-border inspection services.

Department: Department of Transportation; 
Component: Federal Aviation Administration; 
High-impact programs: Air traffic control system.

Component: U.S. Coast Guard; 
High-impact programs: Maritime search and rescue.

Department: Department of Veterans Affairs; 
Component: Veterans Benefits Administration; 
High-impact programs: Veterans' benefits. 

Source: GAO analysis of OMB guidance.

[End of table]

[End of section]

Appendix V: Comments from the Federal Emergency Management Agency:

U.S. Department of Homeland Security 
500 C Street, SW:
Washington, DC 20472:

FEMA:

February 18, 2004:

Linda Koontz:

Director, Information Management Issues 
U.S. General Accounting Office 
Washington, DC 20548:

Dear Director Koontz:

Thank you for the opportunity to review and comment on your proposed 
report entitled Continuity of Operations: Improved Plans Needed to 
Ensure Delivery of Essential Services, GAO-04-160. The Department of 
Homeland Security (DHS) recognizes its role as the federal government's 
Executive Agent for continuity of operations (COOP) and has made 
significant strides toward ensuring the delivery of essential 
government services in an emergency.

In general, we agree that improved planning is needed to ensure 
delivery of essential services. However, we believe that the federal 
government is currently poised to provide those services in an 
emergency that requires the activation of COOP plans. This capability 
was effectively demonstrated during Hurricane Isabel when the Federal 
Emergency Management Agency (FEMA) coordinated government-wide COOP 
activation preparations. More recently, FEMA worked closely with 
federal departments and agencies during the holidays' elevated code-
orange alert to implement COOP plans as necessary.

Your report correctly points out that FEMA could, and should, do more 
to improve upon the federal government's COOP capabilities. In that 
regard, we believe FEMA has begun to correct the deficiencies you have 
identified. Significantly, FEMA will be conducting Forward Challenge 
04, a government-wide COOP exercise, in May 2004. This event marks the 
first opportunity for the government to demonstrate and evaluate the 
effectiveness of its COOP plans. Moreover, and as an outgrowth of the 
monthly COOP Working Group that FEMA chairs with some 66 departments 
and agencies, FEMA has begun working with the Small Agency Council to 
develop and coordinate COOP plans. All of these FEMA efforts and 
activities are specifically designed to improve planning and to further 
ensure the delivery of essential government services during an 
emergency.

On a final note, the President's FY-2005 budget proposal includes an 
increase of $27 million for FEMA's Office of National Security 
Coordination to be used for COOP and continuity of government programs, 
including testing, training, exercising, planning and 
interoperability. We believe this budget request, coupled with FEMA's 
ongoing initiatives to improve reporting and coordination address your 
concerns and further enhance the ability of the Executive branch to 
provide essential services during emergencies.

Sincerely,

Signed by: 

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

(310388):

[End of section]

FOOTNOTES

[1] We also review the human capital considerations relevant to COOP 
planning in a forthcoming report.

[2] Three of the selected major agencies did not have documented COOP 
plans in place as of October 1, 2002.

[3] Appendix III provides a list of the high-impact programs and the 
component agencies responsible for them. Appendix IV identifies the 15 
components whose COOP plans we reviewed and the high-impact programs 
for which they are responsible.

[4] One COOP plan covered two components. As a result, the 34 COOP 
plans we reviewed covered 35 departments and agencies, including 
components.

[5] The need to ensure that computers would handle dates correctly in 
the year 2000 (Y2K) and beyond resulted in a governmentwide effort to 
identify mission-critical systems and high-impact programs supported by 
these systems.

[6] U.S. General Accounting Office, Year 2000 Computing Challenge: 
Lessons Learned Can Be Applied to Other Management Challenges, GAO/
AIMD-00-290 (Washington, D.C.: Sept. 12, 2000).

[7] We reviewed 14 component plans: 1 plan covered a building that 
houses 2 components.

[8] The remaining 3 departments and agencies had not yet developed 
plans.

[9] One plan covered a building that houses 2 components responsible 
for high-impact programs.

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