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					 

******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO Product.                                                 **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
******************************************************************
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 [email protected].

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
copyright holder may be necessary if you wish to reproduce this material
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

GAO's Mission	The General Accounting Office, the audit, evaluation and
investigative arm of Congress, exists to support Congress in meeting its
constitutional responsibilities and to help improve the performance and
accountability of the federal government for the American people. GAO
examines the use of public funds; evaluates federal programs and policies;
and provides analyses, recommendations, and other assistance to help
Congress make informed oversight, policy, and funding decisions. GAO's
commitment to good government is reflected in its core values of
accountability, integrity, and reliability.

  Obtaining Copies of GAO Reports and Testimony

The fastest and easiest way to obtain copies of GAO documents at no cost
is through the Internet. GAO's Web site (www.gao.gov) contains abstracts
and fulltext files of current reports and testimony and an expanding
archive of older products. The Web site features a search engine to help
you locate documents using key words and phrases. You can print these
documents in their entirety, including charts and other graphics.

Each day, GAO issues a list of newly released reports, testimony, and
correspondence. GAO posts this list, known as "Today's Reports," on its
Web site daily. The list contains links to the full-text document files.
To have GAO e-mail this list to you every afternoon, go to www.gao.gov and
select "Subscribe to e-mail alerts" under the "Order GAO Products"
heading.

Order by Mail or Phone	The first copy of each printed report is free.
Additional copies are $2 each. A check or money order should be made out
to the Superintendent of Documents. GAO also accepts VISA and Mastercard.
Orders for 100 or more copies mailed to a single address are discounted 25
percent. Orders should be sent to:

U.S. General Accounting Office 441 G Street NW, Room LM Washington, D.C.
20548

To order by Phone: 	Voice: (202) 512-6000 TDD: (202) 512-2537 Fax: (202)
512-6061

  To Report Fraud, Contact:

Web site: www.gao.gov/fraudnet/fraudnet.htmWaste, and Abuse in E-mail:
[email protected] Federal Programs Automated answering system: (800)
424-5454 or (202) 512-7470

Public Affairs	Jeff Nelligan, Managing Director, [email protected] (202)
512-4800 U.S. General Accounting Office, 441 G Street NW, Room 7149
Washington, D.C. 20548

                               Presorted Standard
                              Postage & Fees Paid
                                      GAO
                                Permit No. GI00

United States
General Accounting Office
Washington, D.C. 20548-0001

Official Business
Penalty for Private Use $300

Address Service Requested
*** End of document. ***