Continuity of Operations: Improved Planning Needed to Ensure	 
Delivery of Essential Services (22-APR-04, GAO-04-638T).	 
                                                                 
To ensure that essential government services are available in	 
emergencies--such as terrorist attacks, severe weather, or	 
building-level emergencies--federal agencies are required to	 
develop continuity of operations (COOP) plans. Responsibility for
formulating guidance on these plans and for assessing executive  
branch COOP capabilities lies with the Federal Emergency	 
Management Agency (FEMA), under the Department of Homeland	 
Security. FEMA guidance, Federal Preparedness Circular (FPC) 65  
(July 1999), identifies elements of a viable COOP capability,	 
including the requirement that agencies identify their essential 
functions. This statement summarizes the findings of a February  
2004, GAO report, for which GAO was asked to determine the extent
to which (1) major civilian executive branch agencies have	 
identified their essential functions and (2) these agencies' COOP
plans follow FEMA guidance.					 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-638T					        
    ACCNO:   A09845						        
  TITLE:     Continuity of Operations: Improved Planning Needed to    
Ensure Delivery of Essential Services				 
     DATE:   04/22/2004 
  SUBJECT:   Agency evaluation					 
	     Agency missions					 
	     Emergency preparedness				 
	     Federal agencies					 
	     Monitoring 					 
	     Noncompliance					 
	     Operations research				 
	     Planning						 

******************************************************************
** 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-04-638T

United States General Accounting Office

GAO	Testimony Before the Committee on Government Reform, House of
Representatives

For Release on Delivery

Expected at 10:00 a.m. EDT CONTINUITY OF

Thursday, April 22, 2004

OPERATIONS

       Improved Planning Needed to Ensure Delivery of Essential Services

Statement of Linda D. Koontz
Director, Information Management Issues

GAO-04-638T

Highlights of GAO-04-638T, a testimony before the Committee on Government
Reform, House of Representatives

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

This statement summarizes the findings of a February 2004, GAO report, for
which GAO was asked to determine the extent to which (1) major civilian
executive branch agencies have identified their essential functions and
(2) these agencies' COOP plans follow FEMA guidance.

In a February 2004 report, GAO recommended that the Secretary of Homeland
Security take steps to improve agency COOP plans and FEMA's process for
assessing these plans. DHS agreed that improvements were needed in the
COOP planning process, and that FEMA could do more to ensure such
improvements were made.

www.gao.gov/cgi-bin/getrpt?GAO-04-638T.

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

April 22, 2004

CONTINUITY OF OPERATIONS

Improved Planning Needed to Ensure Delivery of Essential Government Services

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

Although all but three of the agencies reviewed had developed and
documented some of the elements of a viable COOP plan, none of the
agencies could demonstrate that they were following all the guidance in
FPC

65. As the figure shows, there is a wide variation in the number of
agencies that addressed various elements identified in the guidance. A
contributing cause for the deficiencies in agency COOP plans is the level
of FEMA oversight. In 1999, FEMA conducted an assessment of agency
compliance with FPC 65, but it has not conducted oversight that is
sufficiently regular and extensive to ensure that agencies correct the
deficiencies identified. Because the resulting COOP plans do not include
all the elements of a viable plan as defined by FPC 65, agency efforts to
provide services during an emergency could be impaired.

Elements That Were Included in Agency COOP Plans in Place as of October 1,
2002

Mr. Chairman and Members of the Committee:

I appreciate the opportunity to participate in the Committee's hearing on
federal continuity of operations planning. As you know, events such as
terrorist attacks, severe weather, or building-level emergencies can
disrupt the delivery of essential government services. To minimize the
risk of disruption, federal agencies are required to develop plans for
ensuring the continuity of essential services in emergency situations. The
Federal Emergency Management Agency (FEMA), which was designated executive
agent for executive branch continuity of operations (COOP) planning,
issued planning guidance in July 1999. This guidance, known as Federal
Preparedness Circular (FPC) 65, states that in order to have a viable COOP
capability, agencies should identify their essential functions.
Identifying essential functions is the first of eight elements of a viable
COOP capability, and provides the basis for subsequent planning steps.

At your request, we analyzed the continuity of operations plans in place
at 20 major civilian departments and agencies1 as of October 1, 2002. We
reported the results of our analysis to you in February.2 My remarks today
will summarize those results. Specifically, I will discuss

o  	the extent to which agencies have identified their essential
functions, and

o  the extent to which their plans follow the guidance provided in FPC 65.

In conducting the analysis for our February report, we obtained and
evaluated the headquarters contingency plans in place as of October 1,
2002, from 20 of the 23 largest civilian departments and agencies, as well
as the headquarters plans for 15 components of civilian cabinet-level
departments, selected because they were responsible for programs
previously deemed high impact by the Office of Management and Budget
(OMB). (The major departments and agencies reviewed are listed in
attachment I.)3 We also reviewed supporting documentation and

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

2U.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.)

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

  Results in Brief

interviewed the agency officials responsible for developing these plans,
obtained and analyzed FEMA guidance and documents describing its efforts
to provide oversight and assessments of the federal continuity planning
efforts, and interviewed FEMA officials to clarify the activities
described in these documents. This testimony is based on previously
published work, which was conducted in accordance with generally accepted
government auditing standards, from April 2002 through January of this
year.4

Twenty-nine of the 34 COOP plans5 that we reviewed identified at least one
essential function. However, the functions identified in these plans
varied widely in number-ranging from 3 to 399-and included functions that
appeared to be of secondary importance. At the same time, the plans
omitted many programs that OMB had previously identified as having a high
impact on the public. Agencies did not list among their essential
functions 20 of the 38 high-impact programs that had been identified at
those agencies. For example, one department included "provide speeches and
articles for the Secretary and Deputy Secretary" among its essential
functions, but it did not include 9 of its 10 high-impact programs. In
addition, although many agency functions rely on the availability of
resources or functions controlled by another organization, more than
three-fourths of the plans did not fully identify such dependencies.
Several factors contributed to these governmentwide shortcomings: FPC 65
does not provide specific criteria for identifying essential functions,
nor does it address interdependencies; FEMA did not review the essential
functions identified in its assessments of COOP planning or follow up with
agencies to determine whether they addressed previously identified
weaknesses; and it did not conduct tests or exercises that could confirm
that the identified essential functions were correct. Although the agency
has begun efforts to develop additional guidance and conduct a
governmentwide exercise, these actions have not yet been completed.
Without better oversight, agencies are likely to continue to base their
COOP plans on illdefined assumptions that may limit the utility of the
resulting plans.

4We also reported on the human capital considerations relevant to COOP
planning and implementation in U.S. General Accounting Office, Human
Capital: Opportunities to Improve Federal Continuity Planning Guidance,
GAO-04-384 (Washington, D.C.: Apr. 20, 2004).

5One COOP plan covered two components. As a result, the 34 COOP plans we
reviewed covered 35 departments and agencies, including components.

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

In our report, we made several recommendations to the Secretary of
Homeland Security to enhance the ability of the federal government to
provide essential services during emergencies. In response to a draft of
our report, the Under Secretary for Emergency Preparedness and Response
agreed that better planning is needed to ensure delivery of essential
services, and that the department could do more to improve. He added that
the department has begun to correct the identified deficiencies and stated
that the federal government is currently poised to provide services in an
emergency. Once the department assesses and independently verifies the
status of agencies' plans, it will have convincing evidence to support
such statements about readiness in the future.

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

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

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

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

o  	coordinating interagency exercises and facilitating interagency
coordination, as appropriate; and

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

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

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

Although FPC 65 gives no specific criteria for identifying essential
functions, a logical starting point for this process would be to consider
programs that had been previously identified as important. For example, in
March 1999, as part of the efforts to address the Y2K computer

problem,6 the Director of OMB identified 42 programs with a high impact on
the public:

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

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

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

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

In addition to requiring agencies to identify their essential functions,
FPC 65 also defined an additional seven planning topics that make up a
viable COOP capability. The guidance provided a general definition of each
of the eight topics and identified several actions that should be
completed to address each topic. Table 1 lists the eight topic areas
covered in FPC 65 and provides an example of an action under each.

6The need to ensure that computers would handle dates correctly in the
year 2000 (Y2K) and beyond resulted in a governmentwide effort to identify
mission-critical systems and high-impact programs supported by these
systems.

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

FPC 65 planning topic Example of action (element of viable COOP plan)

Essential functions should be identified to provide the basis for The
agency should prioritize its essential functions. COOP planning.

Plans and procedures should be developed and documented to These plans
should include a roster of personnel who can provide for continued
performance of essential functions. perform the essential functions.

Orders of succession should identify alternates to fill key positions
Succession lists should be developed for the agency head and in an
emergency. other key positions.

Delegations of authority should identify the legal basis for officials
Delegations should include the circumstances under which the to make
decisions in emergencies. authorities begin and end.

Alternate facilities should be able to support operations in a
threat-These facilities should provide sufficient space and equipment to
free environment for up to 30 days. sustain the relocating organization.

Interoperable communications should provide voice and data communications
with others inside and outside the organization.

The agency should be able to communicate with agency personnel, other
agencies, critical customers, and the public.

 Vital records should be identified and made readily available in an Electronic
             and paper records should be identified and protected.

emergency.

Tests, training, and exercises should occur regularly to Individual and
team training should be conducted annually. demonstrate and improve
agencies' COOP capabilities.

Sources: FPC 65, FEMA.

Many COOP Plans Did 	The identification of essential functions is a
prerequisite for COOP preparation because it establishes the parameters
that drive the agency's

  Not Address Previously Identified Essential Functions or Interdependencies
  with Other Entities

efforts in all other planning topics. For example, FPC 65 directs agencies
to identify alternative facilities, staff, and resources necessary to
support continuation of their essential functions. The effectiveness of
the plan as a whole and the implementation of all other elements depend on
the performance of this step.

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

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

o  "protecting critical facilities, systems, equipment and records"; and

o  "continuing to pay the government's obligations."

Other identified functions appeared vague or of questionable importance:

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

o  "schedule all activities of the Secretary"; and

o  	"review fiscal and programmatic integrity and efficiency of
Departmental activities."

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

Another important consideration in identifying essential functions is the
assessment of interdependencies among functions and organizations. As we
have previously reported,7 many agency functions rely on the availability
of resources or functions controlled by another organization, including
other agencies, state and local governments, and private entities. (For
example, the Department of the Treasury's Financial Management Service
receives and makes payments for most federal agencies.) The identification
of such interdependencies continues to be essential to the related areas
of information security and critical infrastructure protection. Although
FPC 65 does not use the term "interdependencies," it directs agencies to
"integrate supporting activities to ensure that essential functions can be
performed."

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

The high level of generality in FEMA's guidance on essential functions
contributed to the inconsistencies in agencies' identification of these
functions. In its initial guidance, FPC 65, FEMA provided minimal criteria
for agencies to make these identifications, giving a brief definition
only. According to FEMA officials, the agency is currently developing
revised

7U.S. General Accounting Office, Year 2000 Computing Challenge: Lessons
Learned Can Be Applied to Other Management Challenges, GAO/AIMD-00-290
(Washington, D.C.: Sept. 12, 2000).

COOP guidance that will provide more specific direction on identifying
essential functions. They expect the guidance to be released this Summer.

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

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

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

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

As of October 1, 2002, almost 3 years after the planning deadline
established by PDD 67, 3 of the agencies we reviewed had not developed and
documented a COOP plan. The remaining 20 major federal civilian agencies
had COOP plans in place, and the 15 components8 that we reviewed also had
plans.

However, after analyzing these plans, we found that none of them addressed
all the guidance in FPC 65. Of the eight topic areas identified in FPC 65,
these 34 COOP plans generally complied with the guidance in one area
(developing plans and procedures); generally did not comply in one area
(tests, training, and exercises); and showed mixed compliance in the other
six areas. Specifically, when examining the governmentwide results of our
analysis of the eight planning topics outlined in FPC 65, we found the
following:

o  	Essential functions. Most agency plans identified at least one
function as essential. However, less than half the COOP plans prioritized
the functions, identified interdependencies among the functions, or
identified the mission-critical systems and date needed to perform the
functions.

o  	Plans and procedures. Most plans followed the guidance in this area,
including a roster of COOP personnel, activation procedures, and the
appropriate planning time frame (12 hours to 30 days).

o  	Orders of succession. All but a few agency plans identified an order
of succession to the agency head. Fewer plans included orders of
succession for other key officials or included officials outside of the
local area in the succession to the agency head. Most plans did not
include the orders of succession in the agency's vital records or document
training for successors on their emergency duties.

o  	Delegations of authority. Few plans adequately documented the legal
authority for officials to make policy decisions in an emergency.

o  	Alternate facilities. Most plans documented the acquisition of at
least one alternate facility, and many include alternate facilities inside
and outside of the local area. However, few plans documented that

8 We reviewed 14 component plans: 1 plan covered a building that houses 2
components. Attachment III identifies the 15 components and the
high-impact programs for which they are responsible.

agencies had adequate space for staff, pre-positioned equipment, or appropriate
           communications capabilities at their alternate facilities.

o  	Redundant emergency communications. Most plans identified at least two
independent media for voice communication. Few plans included adequate
contact information or information on backup data links.

o  	Vital records. About one-quarter of plans fully identified the
agency's vital records. Few plans documented the locations of all vital
records or procedures for updating them.

o  	Tests, training, and exercises. While many agencies documented some
training, very few agencies documented that they had conducted tests,
training, and exercises at the recommended frequency.

Limitations in FEMA's Oversight Contribute to Noncompliance

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

In October 2003, FEMA began working with several members of the
interagency COOP working group to revise FPC 65. Agency officials expect
this revised guidance, which should incorporate the guidance from the
previous FPCs and address more specifically what agencies need to do to
comply with the guidance, to be released this summer. In addition, a
member of the staff of the White House Homeland Security Council told us
in March that the Council was also working on a new policy framework for
federal COOP activities.

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

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

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

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

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

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

Without regular assessments of COOP plans that evaluate individual plans
for adequacy, FEMA will not be able to provide information to help
agencies improve their COOP plans. Further, if it does not verify the data
provided by the agencies or follow up to determine whether agencies have
improved their plans in response to such assessments, FEMA will have
little assurance that agencies' emergency procedures are appropriate.

Agency officials attributed the limited level of oversight that we found
to two factors. First, they stated that before its transition to the
Department of Homeland Security, the agency did not have the legal or
budgetary authority to conduct more active oversight of the COOP
activities of other agencies. However, FPC 65 states that PDD 67 made the
agency

responsible for guidance, coordination, and oversight in this area, in
addition to requiring agencies to develop COOP plans. Accordingly,
although it cannot determine how agencies budget resources for such
planning, it does have the authority to oversee this planning. Second,
according to these officials, until last year, the agency devoted roughly
13 staff to COOP guidance, coordination, and oversight, as well as the
development of FEMA's own plan. According to the official responsible for
COOP oversight, the agency now has 42 positions authorized for such
activities, 31 of which were filled as of December 31, 2003. The agency
expects to fill another 4 positions in fiscal year 2004.

In summary, Mr. Chairman, while most of the agencies we reviewed had
continuity of operations plans in place, those plans exhibited weaknesses
in the form of widely varying determinations about what functions are
essential and inconsistent compliance with guidance that defines a viable
COOP capability. Agencies could experience difficulties in delivering key
services to citizens in the aftermath of an emergency as a result of these
weaknesses.

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

In our report, we made several recommendations to the Secretary of
Homeland Security to enhance the ability of the federal government to
provide essential services during emergencies. In response to a draft of
our report, the Under Secretary for Emergency Preparedness and Response
agreed that better COOP planning is needed to ensure delivery

of essential services, and that the department could do more to improve
COOP planning. He added that FEMA has begun to correct the identified
deficiencies and stated that the federal government is currently poised to
provide services in an emergency. Once FEMA assesses and independently
verifies the status of agencies' plans, it will have convincing evidence
to support such statements about readiness in the future.

Mr. Chairman, this concludes my statement. I would be pleased to respond
to any questions that you or other members of the Committee may have at
this time.

For information about this testimony, please contact Linda D. Koontz at
(202) 512-6240 or at [email protected], or Mirko Dolak, Assistant Director,
at (202) 512-6362 or [email protected]. Other key contributors to this
testimony include Barbara Collier, Neela Lakhmani, Susan Sato, James R.
Sweetman, Jr., Jessie Thomas, and Marcia Washington.

  Contacts and Acknowledgements

Attachment I: Major Civilian Departments and Agencies Selected for Review

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

Attachment II: 38 High-Impact Programs and Responsible Agencies Included
in Our Review

Agency High-impact programs

Department of Agriculture Food safety inspection

                      Child nutrition programs Food stamps

Special supplemental nutrition program for women, infants, and children

     Department of Commerce Patent and trademark processing Weather service
Department of Education Student aid Department of Energy Federal electric power
                            generation and delivery

Department of Health and Human Disease monitoring and warnings Services

                        Indian health services Medicaid

 Medicare Organ transplants Child care Child support enforcement Child welfare
                       Low income home energy assistance

Temporary assistance for needy families

Department of Housing and Urban Community development block grants
Development

Housing loans

Mortgage insurance

Section 8 rental assistance

Public housing

Department of Justice Federal prisons

                                  Immigration

Department of Labor Unemployment insurance

Department of State Passport applications and processing

Department of the Interior Bureau of Indian Affairs programs

Department of the Treasury Cross-border inspection services

Department of Transportation Air traffic control system

Maritime search and rescue

Department of Veterans Affairs Veterans' benefits

Veterans' health care

Agency High-impact programs

Federal Emergency Management Disaster relief Agency

        Office of Personnel Management Federal employee health benefits

Federal employee life insurance

Federal employee retirement benefits Social Security Administration Social
                               Security benefits

                     Source: GAO analysis of OMB guidance.

Attachment III: Component Agencies Reviewed, with High-Impact Program
Responsibilities

                   Department Component High-impact programs

Department of Commerce 	National Oceanic and Atmospheric Weather service
Administration

          Patent and Trademark Office Patent and trademark processing

Department of Health Centers for Disease Control    Disease monitoring and 
           and          and Prevention                               warnings 
      Human Services                                  
                        Center for Medicare and        Medicare and Medicaid  
                        Medicaid Services             
                        Food and Drug Administration     Organ transplants    
                            Indian Health Service     Indian health services  

Department of Housing and Government National Mortgage Association Housing
loans Urban Development

Office of Community Planning and Community development block grants
Development

Office of Housing 	Section 8 rental assistance and mortgage insurance

Office of Public and Indian Housing Public housing

Department of the Bureau of Indian Affairs     Indian affairs programs     
Interior                                    
Department of the U.S. Customs Service             Cross-border inspection 
Treasury                                                          services 
                     Federal Aviation                                         
Department of     Administration              Air traffic control system
Transportation                              
                     U.S. Coast Guard              Maritime search and rescue 

Department of Veterans Veterans Benefits Administration Veterans' benefits
Affairs

                     Source: GAO analysis of OMB guidance.

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.

GAO's Mission

Obtaining Copies of GAO Reports and Testimony

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.

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.htm

Waste, and Abuse in E-mail: [email protected]

Federal Programs Automated answering system: (800) 424-5454 or (202)
512-7470

Jeff Nelligan, Managing Director, [email protected] (202) 512-4800

Public Affairs 	U.S. General Accounting Office, 441 G Street NW, Room 7149
Washington, D.C. 20548
*** End of document. ***