    Human Capital: Opportunities to Improve Federal Continuity
    Planning Guidance (20-APR-04, GAO-04-384).

    Federal agencies must have the capacity to serve the public
    during disruptions to normal operations. This depends, in part,
    on continuity efforts that help agencies marshal, manage, and
    maintain their most important asset--their people, or human
    capital. GAO identified the human capital considerations relevant
    to federal continuity efforts; described efforts by the Federal
    Emergency Management Agency (FEMA) and the Office of Personnel
    Management (OPM) to address these considerations relevant to
    continuity of operations (COOP); and described the role Federal
    Executive Boards (FEB) play in coordinating such efforts outside
    Washington, D.C.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-04-384
        ACCNO:   A09833
      TITLE:     Human Capital: Opportunities to Improve Federal
    Continuity Planning Guidance
         DATE:   04/20/2004
      SUBJECT:   Emergency preparedness
    	     Federal agencies
    	     Internal controls
    	     National preparedness
    	     Human capital

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    GAO-04-384

    United States General Accounting Office

    GAO	Report to the Chairman, Subcommittee on Oversight of Government Management,
     the FederalWorkforce, and the District of Columbia, Committee on Governmental
                                  Affairs, U.S. Senate

    April 2004

    HUMAN CAPITAL

             Opportunities to Improve Federal Continuity Planning Guidance

                                           a

    GAO-04-384

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

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

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

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

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

    April 2004

    HUMAN CAPITAL

    Opportunities to Improve Federal Continuity Planning Guidance

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

    Key Organizational Actions to Enhance Continuity Efforts

    Demonstrate top  o  Instill an approach to continuity planning that
    includes human leadership commitment capital considerations

    o  Allocate resources and set policies

    o  Set direction and pace of recovery Seek opportunities for  o  Integrate
    continuity efforts with broader decision making synergy  o  Consider how
    continuity investments benefit other program efforts Maintain effective  o
        Build relationships through two-way communication communication  o
    Establish roles, responsibilities, and expectations

    o  Develop redundant communication vehicles

    Target investments in  o  Raise awareness of continuity efforts
    training and  o  Build skills and competencies to increase flexibility
    development  o  Foster a culture that values flexible employees who are

    empowered to make effective decisions Leverage the flexibility  o  Enable
    employees associated with resumption activities to of human capital
    contribute to mission results in alternate assignments

    o  	Sustain the contribution of employees associated with essential
    operations

    o  Maintain organizational knowledge of staffing requirements and

    availability Build process to identify  o  Create a learning environment
    and share lessons  o  Make learning explicit and shared

    Source: GAO.

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

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

    Contents

      Letter

    Results in Brief
    Background
    Human Capital Considerations Are Relevant to Continuity Planning

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

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

    Conclusions
    Recommendations for Executive Action
    Agency Comments and Our Evaluation

    1 3 6

    8

    20

    24 26 26 27

    Appendixes
                    Appendix I:       Objectives, Scope, and Methodology       30
                                 Emergency Human Capital Flexibilities Listed
                   Appendix II:                     in OPM
                                            Emergency Memorandums              33
                                                    Leave                      33
                                                     Pay                       34
                                                   Benefits                    35
                                                   Telework                    35
                                        Emergency Hiring Flexibilities         36
                  Appendix III: Comments from the Federal Emergency Management
                                                    Agency                     40
                                    Comments from the Office of Personnel      41
                  Appendix IV:                    Management

    Table Table 1:	Key Organizational Actions to Enhance Continuity Efforts

    Figure Figure 1:	Six Organizational Actions to Enhance Continuity
    Efforts 10

    Contents

    Abbreviations

    AFGE American Federation of Government Employees
    COOP continuity of operations
    CTAP Career Transition Assistance Plan
    CWG COOP Working Group
    DHS Department of Homeland Security
    EMA Emergency Management Alberta
    FEB Federal Executive Board
    FEMA Federal Emergency Management Agency
    FPC Federal Preparedness Circular
    GS General Schedule
    GSA General Services Administration
    HR human resources
    ICTAP Interagency CTAP
    IRS Internal Revenue Service
    KSA knowledge, skills, and abilities
    NAPA National Academy of Public Administration
    NTEU National Treasury Employees Union
    OEP Occupant Emergency Program
    OPM Office of Personnel Management
    PDD Presidential Decision Directive
    PSC Private Sector Council
    RPL Reemployment Priority List
    SARS severe acute respiratory syndrome
    SSA Social Security Administration
    VSIP voluntary separation incentive payment

    This is a work of the U.S. government and is not subject to copyright
    protection in the United States. It may be reproduced and distributed in
    its entirety without further permission from GAO. However, because this
    work may contain copyrighted images or other material, permission from the
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    separately.

    A

    United States General Accounting Office Washington, D.C. 20548

    April 20, 2004

    The Honorable George V. Voinovich

    Chairman, Subcommittee on Oversight of Government Management, the Federal
    Workforce, and the District of Columbia Committee on Governmental Affairs
    United States Senate

    Dear Mr. Chairman:

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

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

    In response to your request that we identify the human capital
    considerations in COOP emergencies, this report (1) identifies the human
    capital considerations that are relevant to federal agencies' continuity

    1 The House Committee on Government Reform also asked us to review agency
    headquarters COOP plans. We reported on that review in U.S. General
    Accounting Office,

    Continuity of Operations: Improved Planning Needed to Ensure Delivery of
    Essential Services, GAO-04-160 (Washington, D.C.: Feb. 27, 2004).

    planning and implementation efforts; (2) describes the COOP guidance
    provided by the Federal Emergency Management Agency (FEMA)2 and emergency
    preparedness guidance and activities of the Office of Personnel Management
    (OPM) to address human capital considerations relevant to COOP; and (3)
    describes the role Federal Executive Boards (FEB) play, relevant to COOP,
    in coordinating efforts outside the Washington, D.C., area.

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

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

    To describe the COOP guidance issued by FEMA and the emergency
    preparedness guidance and activities of OPM, we interviewed officials from
    both agencies and analyzed relevant documents, including Federal

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

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

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

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

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

    Table 1: Key Organizational Actions to Enhance Continuity Efforts

    Demonstrate top  o  Instill an approach to continuity planning that
    includes human

                                 leadership commitment

    capital considerations

    o  Allocate resources and set policies

    o  Set direction and pace of recovery

    Seek opportunities for  o  Integrate continuity efforts with broader
    decision making

    synergy  o  Consider how continuity investments benefit other program
    efforts

    Maintain effective  o  Build relationships through two-way communication
    communication  o  Establish roles, responsibilities, and expectations

    o  Develop redundant communication vehicles

    Target investments in  o  Raise awareness of continuity efforts
    training and
    development  o  Build skills and competencies to increase flexibility

    o  Foster a culture that values flexible employees who are empowered to
    make effective decisions

    Leverage the flexibility  o  Enable employees associated with resumption
    activities to of human capital contribute to mission results in alternate
    assignments

    o  Sustain the contribution of employees associated with essential
    operations

    o  Maintain organizational knowledge of staffing requirements and
    availability

    Build process to identify  o  Create a learning environment and share
    lessons  o  Make learning explicit and shared

    Source: GAO.

    In the federal government, FEMA, as executive agent for COOP, and OPM, as
    the President's agent and advisor for human capital matters, have
    exhibited leadership in addressing human capital considerations relevant
    to COOP. For example, FEMA issued FPC 65, which is the primary guidance
    for federal agencies to use in developing a viable COOP capability, to
    address significant disruptions requiring relocation to an alternate
    facility. However, the guidance does not recognize significant disruptions
    that do not require relocation to an alternate facility. Regarding human
    capital considerations, this guidance directly addresses the need to
    secure the safety of all employees and respond to the needs of personnel
    performing or supporting essential operations. OPM has similarly addressed
    these primary considerations through several initiatives, including
    establishing the Emergency Preparedness subcommittee of the Chief Human
    Capital Officers Council, releasing emergency guides for federal employees
    and managers, and issuing a series of memorandums

    outlining the existing human resource management flexibilities that
    agencies might employ in emergency situations. However, neither FEMA's nor
    OPM's guidance to date has adequately addressed the human capital
    considerations related to the resumption of agency operations that are not
    considered essential. Recognizing this, they are working together, as well
    as with other federal partners, to more fully address the considerations
    inherent in these resumption activities. One expected outcome of this
    partnership is an updated and augmented federal COOP guidance that will
    more fully address human capital considerations, particularly those
    regardingemployees who will be involved with broader resumption efforts.

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

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

    On March 10, 2004, we provided a draft of this report to the Secretary of
    Homeland Security and the Director of OPM. We received written comments
    from the Under Secretary of Emergency Preparedness and

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

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

    Background	The policy of the U.S. government is to have in place a
    comprehensive and effective program to ensure continuity of essential
    federal functions under

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

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

    FEMA, the General Services Administration (GSA), and OPM are the three
    agencies that have the most direct impact on individual agency efforts to
    develop viable COOP capabilities. PDD 67, which outlined individual

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

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

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

      Human Capital Considerations Are Relevant to Continuity Planning and
      Implementation Efforts

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

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

    establishing critical functions and processes, and identifying essential
    representatives.6

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

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

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

    The second principle experts identified is maximizing the contributions of
    all employees, whether in providing essential operations or resuming full

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

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

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

    Figure 1: Six Organizational Actions to Enhance Continuity Efforts

    Source: GAO.

    Each of these actions is described in more detail below.

    Demonstrate top leadership commitment

    o  Instill an approach to continuity planning that includes human capital
    considerations

    o  Allocate resources and set policies

    o  Set direction and pace of recovery

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

    Organizational leaders show commitment to continuity planning by
    allocating resources and setting policies that effectively meet the
    organization's continuity needs. The experts told us that committed
    leaders provide sufficient funding and staff to conduct planning and
    preparation efforts effectively. While the resources needed vary from
    location to location within an organization, the experts said that
    organizations should have enough resources available to develop effective
    plans, test critical systems, train all staff, and conduct simulation
    exercises. Committed top leadership also ensures that clear policies and
    procedures are in place for all aspects of continuity to ensure that quick
    and effective decisions are made during times of emergencies. Those
    policies and

    7 See, for example, U.S. General Accounting Office: Results-Oriented
    Cultures: Implementation Steps to Assist Mergers and Organizational
    Transformations, GAO-03669 (Washington, D.C.: July 2, 2003); Highlights of
    a GAO Forum: Mergers and Transformation: Lessons Learned for a Department
    of Homeland Security and Other Federal Agencies, GAO-03-293SP (Washington,
    D.C.: Nov. 14, 2002); A Model of Strategic Human Capital Management,
    GAO-02-373SP (Washington, D.C.: Mar. 15, 2002); and Management Reform:
    Elements of Successful Improvement Initiatives, GAO/T-GGD-00-26
    (Washington, D.C.: Oct. 15, 1999).

    procedures should be fair, shared with employees and their representatives
    in advance of an emergency, and able to be consistently applied to all
    employees. Experts and union leaders we met with agree that the
    cooperation and input from all components within the organization,
    including employees and their representatives, is important in developing
    these policies.

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

    Seek opportunities for synergy

    o  Integrate continuity efforts with broader decision making

    o  Consider how continuity investments benefit other program efforts

    As we have previously reported, effective organizations integrate human
    capital approaches as strategies for accomplishing their mission and
    programmatic goals.8 According to the experts, strategic decisions made to
    improve day-to-day operations, including human capital approaches, and
    those made to build continuity readiness are not exclusive of one another
    and may have synergies. For example, early in 2001, GAO made the business
    decision to supply all of its analysts with laptop computers for financial
    reasons and to provide employees with flexibility in carrying out their
    work. That business decision, however, also contributed to our ability to
    quickly adapt to unforeseeable circumstances in October 2001. In response
    to the release of anthrax bacteria on Capitol Hill, we opened our doors to
    the 435 members of the House of Representatives and selected

    8 See, for example, U.S. General Accounting Office, High-Risk Series:
    Strategic Human Capital Management, GAO-03-120 (Washington, D.C.: January
    2003); GAO-03-669; GAO-03293SP; and GAO-02-373SP.

    members of their staffs. Over 1,000 GAO employees were immediately able to
    make use of their laptops to work from alternate locations. Consequently,
    we minimized the disruption to our operations and assisted the House of
    Representatives in continuing its operations. To take advantage of such
    synergies, the experts said that decisions regarding continuity efforts
    should be integrated with broader business decision making.

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

    Maintain effective communication

    o  Build relationships through two-way communication

    o  Establish roles, responsibilities, and expectations

    o  Develop redundant communication vehicles

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

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

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

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

    Target investments in training and development

    o  Raise awareness of continuity efforts

    o  Build skills and competencies to increase flexibility

    o  Foster a culture that values flexible employees who are empowered to
    make effective decisions

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

    10 GAO-02-373SP.

    be processed during a disruption, and references to federal guides and
    information. The experts noted that less formal approaches, such as
    continuity planning awareness weeks, could also help to raise awareness.

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

    With regard to the team that is responsible for resuming all other
    organizational operations, experts said that the training and development
    goal is to build sufficient breadth to enable members to contribute to
    resumption efforts in a variety of ways. For example, development programs
    requiring employees to rotate within an organization to learn a variety of
    positions, potentially at a variety of locations, contribute to

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

    critical breadth. We have previously reported that developmental
    assignments place employees in new roles or unfamiliar job environments in
    order to strengthen skills and competencies and broaden their
    experience.12

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

    Leverage the flexibility of human capital

    o  Enable employees associated with resumption activities to contribute to
    mission results in alternate assignments

    o  Sustain the contribution of employees associated with essential
    operations

    o  Maintain organizational knowledge of staffing requirements and
    availability

    The events of September 11, 2001, give ample evidence of the dedication
    and flexibility of federal, state, and local government employees in
    providing services to the American public. Disruption of normal operations
    challenges an organization to use this dedication and flexibility to its
    advantage, especially with regard to employees associated with the
    resumption of all operations that are not considered essential. According
    to the experts, organizations may use approaches such as telework and
    geographic dispersion, which includes regional structure, to increase the
    ways in which employees may contribute. As OPM guidance has underscored
    and presenters at a recent conference held by the International Telework
    Association and Council noted, telework is an important and viable option
    for federal agencies in COOP planning and implementation efforts,
    especially as the duration of the emergency event

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

    is extended.13 However, to make effective use of telework, experts told us
    that organizations should identify those employees who are expected to
    telework during a disruption and communicate that expectation to them in
    advance. In addition, organizations should provide teleworkers with
    adequate support in terms of tools, training, and guidance. 14 Geographic
    dispersion can also provide a way for employees associated with resumption
    activities to continue their normal functions albeit at or through other
    locations. For example, SSA recognizes that its field structure enables
    the agency to make use of both multiple locations and telework in
    providing its employees ways to contribute because most field functions
    can be transferred fairly easily from one location to another in the same
    region or performed remotely with laptop computers. Based on these
    efforts, SSA does not envision a scenario in which its field employees
    would not contribute to their normal functions for more than 72 hours.

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

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

    14 Our previous work has also identified 25 key practices for
    implementation of successful federal telework programs. See U.S. General
    Accounting Office, Human Capital: Further Guidance, Assistance, and
    Coordination Can Improve Federal Telework Efforts, GAO-03679 (Washington,
    D.C.: July 18, 2003).

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

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

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

    Build process to identify and share lessons

    o  Create a learning environment

    o  Make learning explicit and shared

    An evaluation process that explicitly identifies and disseminates lessons
    learned during disruptions, or simulations of disruptions, promotes

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

    learning among all of an organization's human capital assets and helps to
    improve organizational performance. An organization that is committed to
    learning has an inclusive and supportive process and a framework designed
    prior to a disruption to gather important data. According to experts,
    organizations committed to learning will ensure that those employees who
    are key to the recovery and resumption efforts are involved in the formal
    evaluation process in a timely manner and will seek the input from as many
    other employees as possible. Such an inclusive environment will enable the
    organization to discover valuable lessons learned by employees in unusual
    circumstances. In addition, conducting evaluations in a "noblame,"
    nonattribution atmosphere and taking organizational ownership of any
    problems that might be identified increases the openness with which
    participants are willing to share their experiences. To encourage such an
    environment, FEMA officials told us that the agency's Office of National
    Security Coordination has recently implemented a reporting system that
    allows any employee to identify lessons learned anonymously during an
    emergency, instead of waiting for the formal review process.

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

    Once identified, it is important for the lessons learned during the
    evaluation to be made explicit and then widely disseminated. According to
    experts, the manner and formality of documentation and dissemination,
    however, depend on the situation or needs of the organization (e.g.,
    afteraction reports, detailed analyses, executive summaries, video tapes,
    CDs, or Web-based reports). There are unique opportunities in the federal
    government for agencies to share explicit lessons learned both internally
    and with other federal agencies and stakeholders. For example, following
    the September 11, 2001, attacks, senior Department of Housing and Urban

    17 GAO-02-373SP.

    Development officials asked the New York Acting Regional Director to
    recount her experiences and lessons learned in front of a video camera.
    The accounts were edited down into a 30-minute video entitled Thinking the
    Unthinkable: Preparing for Disaster. That video has been used within the
    department as a training aid and has been shared with over 50 federal
    agencies with the help of the Washington, D.C.-based interagency COOP
    Working Group (CWG) and the FEBs in cities across the United States. In
    Canada, Emergency Management Alberta (EMA) employs a centralized
    Disruption Incident Reporting System for all government agencies, which is
    accessible via the Internet, to obtain timely and accurate reporting of
    all disruptions and "most importantly, ensure lessons learned can be
    documented for follow-up." 18 EMA has also created a Lessons Learned
    Warehouse Web site to share continuity lessons learned in all aspects of
    crisis management.19

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

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

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

    As executive agent for federal COOP planning, FEMA issued FPC 65 in July
    1999 as the primary guidance for agencies developing viable COOP plans.
    According to FPC 65, the purpose of COOP planning is to facilitate the
    performance of agency essential functions for up to 30 days during any
    emergency or situation that may disrupt normal operations. The five
    objectives of a viable COOP plan listed in FPC 65 are (1) ensuring the
    continuous performance of an agency's essential functions during an
    emergency; (2) protecting essential facilities, equipment, records, and

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

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

    other assets; (3) reducing or mitigating disruptions to operations; (4)
    reducing loss of life, minimizing damage and losses; and (5) achieving a
    timely and orderly recovery from an emergency and resumption of full
    service to customers.

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

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

    FEMA officials we spoke with recognized that there is a need to go beyond
    the human capital considerations that have already been addressed within
    federal COOP guidance in order to achieve the full range of COOP

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

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

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

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

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

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

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

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

    In addition to initiating efforts to address several human capital
    considerations, OPM has highlighted the need to work with and through
    employee organizations and unions in developing and executing emergency
    management strategies. For example, OPM has held meetings with federal

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

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

    labor union leaders and employee associations to discuss relevant employee
    safety issues and has specifically encouraged agencies to work with and
    share information on preparedness efforts with applicable employee
    organizations and unions. Senior union officials whom we spoke with from
    the American Federation of Government Employees and NTEU agreed that it is
    important for unions to be involved throughout COOP planning and
    implementation efforts. These officials also stated that unions could be
    resources for agencies in communicating with employees, both before and
    during an emergency, as well as in engaging employees in recovery and
    resumption efforts.

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

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

    The FEBs that we visited are already playing active roles in regional
    emergency preparedness and COOP efforts. For example, the Chicago FEB has
    established committees to deal with Disaster Recovery Planning and
    Emergency Release; surveyed its member agencies to determine the

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

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

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

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

    capabilities); and developing strategies to better leverage the network of
    FEBs to help departments and agencies implement their initiatives.

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

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

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

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

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

      Executive Action two actions:

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

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

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

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

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

      Agency Comments and Our Evaluation

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

    The Director of OPM also provided written comments, which are reprinted in
    appendix IV. In her comments, the Director noted her appreciation for our
    acknowledgement of the agency's leadership role in addressing human
    capital considerations relevant to COOP planning. However, the Director of
    OPM stated that the agency has already carried out our recommendation to
    more fully address human capital considerations in emergency preparedness
    guidance, including COOP, by incorporating the key actions

    identified in the report. The Director provided numerous examples of
    actions OPM has taken to support emergency preparedness efforts, all of
    which she noted were influenced by the agency's human capital framework.
    In addition, the Director also attached an enclosure to the agency
    comments that contain examples of OPM's internal COOP-related efforts that
    she believes would be helpful to federal agencies.

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

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

    The Director of OPM suggested several clarifications to the report, which
    we considered and incorporated where appropriate. For example, she
    suggested both technical and substantive changes to a footnote describing
    Federal Executive Associations (FEA) and Federal Executive Councils (FEC).
    While we made technical changes in response to these comments, our work
    does not allow us to categorically exclude all FEAs and FECs as viable
    options for the coordination of emergency preparedness activities, as the
    Director suggested in her response. Instead, we recognize that any

    guidance provided to FEBs would likely be beneficial to FEAs and FECs
    despite their differences. The Director also provided additional details
    describing OPM's internal working group that is studying the strengths and
    weaknesses of FEBs, and we have incorporated these details into the
    report.

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

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

    Sincerely yours,

    J. Christopher Mihm Managing Director, Strategic Issues

    Appendix I

                           Objectives, Scope, and Methodology

    The objectives of this report were to

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

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

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

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

    On the basis of these characteristics and the input from NAPA, PSC, and
    FEMA, we selected organizations or individuals within organizations to
    obtain a diversity of views from both the public and private sector.
    Individuals from a total of 15 organizations, in addition to FEMA,
    provided

    Appendix I
    Objectives, Scope, and Methodology

    their expertise in addressing our objective. The organizations include
    five federal agencies-the Centers for Disease Control and Prevention, the
    Department of Housing and Urban Development, the Department of Veterans
    Affairs, the General Services Administration, and the Social Security
    Administration; five private sector businesses-the Gillette Company,
    Lockheed Martin Corporation, Macy's West, Marsh & McLennan Companies,
    Inc., and Science Applications International Corporation; and five public
    institutions-the Business Continuity Institute, the Disaster Recovery
    Institute International, Emergency Management Alberta (Canada),
    Clark-Atlanta University, and the University of Tasmania (Australia).

    We then conducted three cycles of work to identify the human capital
    considerations that are relevant to continuity, with each subsequent cycle
    building upon the information gathered in previous cycles. We adopted this
    approach because our initial conversations with experts indicated that a
    common perspective of the continuity process could help structure and
    focus our subsequent interviews with experts about the relevant human
    capital considerations. Cycle one involved conducting semistructured
    interviews with experts from FEMA and 5 of the 15 organizations.1 We asked
    each to describe a view of the entire continuity process from a human
    capital perspective. We used those descriptions to synthesize a framework
    that we then shared with each of the first cycle experts for comment. The
    experts generally agreed with the content of the framework and agreed that
    it would be useful in focusing subsequent interviews about human capital
    considerations. In the second cycle, we used this framework as a reference
    when conducting in-depth, semistructured interviews with experts from all
    15 organizations and FEMA about the human capital considerations relevant
    to continuity. For the third cycle, we held a 1-day working group, in
    cooperation with FEMA, to more fully discuss the human capital
    considerations previously identified in cycles one and two. The
    interactive nature of the working group, which included a cross-section of
    the experts and additional representatives from GAO,2

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

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

    Appendix I
    Objectives, Scope, and Methodology

    helped to ensure that we had adequately captured the key considerations
    relevant to continuity. As a final check, we provided all of the experts
    with a summary document that included the statements used throughout this
    report and attributed to the experts. We asked the experts to review the
    statements for fundamental disagreement or fatal flaws. Almost all experts
    responded and generally agreed with our treatment of these issues.

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

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

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

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

    Appendix II

    Emergency Human Capital Flexibilities Listed in OPM Emergency Memorandums

    OPM has issued a series of memorandums outlining the existing human
    resources management flexibilities that executive departments and agencies
    might employ in emergency situations with and without OPM approval.1 Other
    human capital flexibilities and programs, such as those detailed in OPM's
    handbook, Human Resources Flexibilities and Authorities in the Federal
    Government, 2 that are available to agencies in nonemergency situations
    may also provide additional assistance in responding to and recovering
    from COOP emergencies. For additional information on these flexibilities,
    OPM has advised that agency chief human capital officers, human resources
    (HR) directors, or both should contact their assigned OPM human capital
    officer. Employees are advised to contact their agency HR offices for
    assistance.

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

      Leave

    Excused Absence	Agencies have the discretion, without OPM approval, to
    grant excused absence to employees who are prevented from reporting to
    work because of an emergency. The authority to grant excused absence also
    applies to employees who are needed for emergency law enforcement, relief,
    or recovery efforts authorized by federal, state, or local officials
    having appropriate jurisdiction and whose participation in such activities
    has been approved by the employing agency. Military leave under 5 U.S.C.
    S: 6323(b) is appropriate for federal employee members of the National
    Guard or Reserves who are called up to assist in an emergency.3

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

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

    3 According to 5 U.S.C. S: 6323(b), military leave is not to exceed 22
    workdays.

    Appendix II Emergency Human Capital Flexibilities Listed in OPM Emergency
                                      Memorandums

        Emergency Leave Transfer Program

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

    Pay

        Premium Pay forEmployees Performing Emergency Overtime Work

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

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

    Appendix II Emergency Human Capital Flexibilities Listed in OPM Emergency
                                      Memorandums

    breakdown in equipment, an act of nature, or a sudden emergency requiring
    the agency to immediately curtail activities.

      Benefits

    Workers' Compensation Workers' compensation benefits are available when
    federal employees are

    Benefits	injured or killed while on duty. The Department of Labor may
    establish special procedures to provide direct assistance to affected
    employees and their families.

    Expedited Processing of To assist agencies in responding to employee needs
    during and after an Retirement and Life emergency situation, OPM may
    establish special expedited arrangements Insurance Benefits for processing
    disability retirement applications; survivor benefits; and

    payments under the Federal Employees Group Life Insurance Program,

    currently administered by the Metropolitan Life Insurance Company.

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

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

    Appendix II Emergency Human Capital Flexibilities Listed in OPM Emergency
                                      Memorandums

    the agency closes on his or her telework day should be included in the
    employee's formal or informal telework agreement.

      Emergency Hiring Flexibilities

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

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

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

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

    Direct-Hire Authority	Agencies have the authority to appoint candidates
    directly when OPM determines there is a critical hiring need, or a
    shortage of candidates, for

    Appendix II Emergency Human Capital Flexibilities Listed in OPM Emergency
                                      Memorandums

    particular occupations, grades (or equivalent), geographic locations, or
    some combination of the three. This authority can be governmentwide or
    limited to one or more specific agencies depending on the circumstances.

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

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

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

    Senior Executive Service To meet a bona fide, unanticipated, urgent need,
    agencies have the Limited Emergency authority under 5 C.F.R. S: 317.601 to
    make Senior Executive Service limited Appointments emergency appointments
    of career employees, without OPM approval.

    OPM approval is required to appoint individuals who are not current career
    employees and OPM cannot delegate this authority; however, OPM will
    process such requests on a priority basis and will also consider temporary
    position allocations for agencies that identify the need as essential to
    deal with the emergency.

    Reemploying Retirees	Agencies have the discretion, without OPM approval,
    to employ retirees to deal with an emergency, to replace employees called
    to active duty military service, or both. Agencies may immediately offer
    reemployment to retirees

    Appendix II Emergency Human Capital Flexibilities Listed in OPM Emergency
                                      Memorandums

    under any applicable appointing authority. However, generally, dual
    compensation restrictions (e.g., 5 U.S.C. S:S: 8344 and 8468) require
    agencies to reduce the pay of a federal civil service retiree by the
    amount of his or her annuity. For details, see the CSRS and FERS Handbook
    for Personnel and Payroll Offices, Chapter 100 - Reemployed Annuitants.

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

        Reemploying Voluntary Separation Incentive Payment Recipients

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

        Other Emergency Hiring Flexibilities

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

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

    Agencies have the discretion, without OPM approval, to appoint current and
    former employees from RPL to temporary, term, or permanent competitive
    service appointments. Conversely, agencies may make

    Appendix II Emergency Human Capital Flexibilities Listed in OPM Emergency
    Memorandums

    exceptions to the RPL provisions to appoint others under 5 C.F.R.
    330.207(d).

    Appendix III

    Comments from the Federal Emergency Management Agency

    Appendix IV

    Comments from the Office of Personnel Management

    Appendix IV
    Comments from the Office of Personnel
    Management

    Appendix IV
    Comments from the Office of Personnel
    Management

    Appendix IV
    Comments from the Office of Personnel
    Management

    Appendix IV
    Comments from the Office of Personnel
    Management

    Appendix IV
    Comments from the Office of Personnel
    Management

    Appendix IV
    Comments from the Office of Personnel
    Management

    Appendix IV
    Comments from the Office of Personnel
    Management

    Appendix IV
    Comments from the Office of Personnel
    Management

    Appendix IV
    Comments from the Office of Personnel
    Management

    Appendix IV
    Comments from the Office of Personnel
    Management

    Appendix IV
    Comments from the Office of Personnel
    Management

    Appendix IV
    Comments from the Office of Personnel
    Management

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