Catastrophic Disasters: Enhanced Leadership, Capabilities, and	 
Accountability Controls Will Improve the Effectiveness of the	 
Nation's Preparedness, Response, and Recovery System (06-SEP-06, 
GAO-06-618).							 
                                                                 
Hurricane Katrina was the largest, most destructive natural	 
disaster in our nation's history. The problems experienced in	 
responding to Katrina resulted in a number of investigations--by 
congressional committees, the White House Homeland Security	 
Council, and others--regarding the preparations for and response 
to Katrina. GAO assisted the congressional investigations and,	 
under the Comptroller General's authority, initiated a number of 
Katrina-related reviews. In March 2006 testimony, GAO provided	 
its preliminary observations to Congress. The purpose of this	 
report is to summarize what went well and why, what did not go	 
well and why, and what changes are needed to improve the nation's
readiness to respond to a catastrophic disaster; and to identify 
selected issues associated with the Gulf Coast's recovery. This  
report is based on GAO's prior work on catastrophic disasters,	 
including Hurricane Andrew in 1992, the over 30 GAO reports	 
completed to date on Hurricanes Katrina and Rita, ongoing GAO	 
work, and other Hurricane Katrina reviews and lessons learned.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-06-618 					        
    ACCNO:   A60305						        
  TITLE:     Catastrophic Disasters: Enhanced Leadership,	      
Capabilities, and Accountability Controls Will Improve the	 
Effectiveness of the Nation's Preparedness, Response, and	 
Recovery System 						 
     DATE:   09/06/2006 
  SUBJECT:   Accountability					 
	     Disaster planning					 
	     Disaster recovery					 
	     Disaster recovery plans				 
	     Emergency preparedness				 
	     Emergency preparedness programs			 
	     Emergency response 				 
	     Emergency response plans				 
	     Emergency response procedures			 
	     Federal response plan				 
	     Federal/state relations				 
	     First responders					 
	     Fraud						 
	     Hurricane Katrina					 
	     Hurricane Rita					 
	     Hurricanes 					 
	     Impacted area programs				 
	     Internal controls					 
	     Interstate programs				 
	     Natural disasters					 
	     Performance appraisal				 
	     Program abuses					 
	     Program evaluation 				 
	     Risk management					 
	     Program coordination				 
	     Gulf Coast 					 
	     National Response Plan				 

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GAO-06-618

     

     * Results in Brief
     * Background
          * Stafford Act Is the Principal Federal Statute on Federal Dis
          * Federal Disaster Assistance and Relief Is to Be Administered
          * Interstate Disaster Assistance was also Provided through the
          * The Homeland Security Act Requires a Comprehensive Approach
          * DHS Policies and Plans Have Identified a Strategy for Buildi
          * Federal Government Is a Major Partner in Long-Term Recovery
          * Congress and the Administration Have Engaged in Numerous Eff
     * Leadership Is Critical for Preparing for, Responding to, and
          * Communicating and Clearly Defining Leadership Roles, Respons
          * Provisions of the NRP Regarding Incidents of National Signif
          * Proactive Response Provisions of the NRP's Catastrophic Inci
          * Federal Coordination Issues with the NRP Have Not Been Fully
          * DHS Reported Taking Some Actions to Improve Leadership in Re
          * As a Result of FEMA's Performance during Hurricane Katrina,
     * Enhanced Capabilities for Catastrophic Response and Recovery
          * Capabilities Were Not Adequate for a Catastrophic Disaster
               * Situational Assessment and Awareness
               * Emergency Communications
               * Evacuations
               * Search and Rescue
               * Logistics
               * Mass Care, Housing, and Human Services
          * Effective Capabilities Development Requires Adequate Plannin
               * Planning and Coordination
               * Examples of Good Planning
               * Examples Where Planning and Coordination Should Be Improved
               * Training and Exercises
          * DHS Reported Taking Some Actions to Improve Capabilities in
          * Additional Work Is Needed to Address FEMA's Human Resource C
          * Building Capabilities for Catastrophic Disasters Calls for a
     * Balance Needed between Quick Provision of Assistance and Ens
          * Catastrophic Disaster Controls and Accountability Mechanism
          * Hurricane Katrina Highlighted Several Contracting Deficienci
               * Acquisition planning
               * Business arrangements
               * Contract Monitoring and Oversight
               * Practices to Help Ensure Successful Acquisition Outcomes
          * Lack of Controls Limited Accountability in the Receipt and D
          * Control Weaknesses in Individual Assistance Payments Resulte
     * Long-Term Recovery and Rebuilding Efforts Raise Issues for C
          * Long-Term Recovery Is a Shared Responsibility and a Number o
               * Assessing Environmental Hazards Involves the Environmental P
               * Rebuilding and Strengthening the Levees Involves the U.S. Ar
               * Despite Federal Assistance, States and School Districts Face
               * Duration of Housing Assistance for Victims of Hurricanes Kat
               * Questions Raised about FEMA's National Flood Insurance Progr
          * A Framework to Enhance Federal Financial Assistance's Perfor
     * Conclusions
     * Recommendations
          * Recommendations for Executive Action
          * Matters for Congressional Consideration
     * Agency Comments
     * GAO Contacts
     * GAO Contact
     * Acknowledgments
     * GAO's Mission
     * Obtaining Copies of GAO Reports and Testimony
          * Order by Mail or Phone
     * To Report Fraud, Waste, and Abuse in Federal Programs
     * Congressional Relations
     * Public Affairs

Report to Congressional Committees

United States Government Accountability Office

GAO

September 2006

CATASTROPHIC DISASTERS

Enhanced Leadership, Capabilities, and Accountability Controls Will
Improve the Effectiveness of the Nation's Preparedness, Response, and
Recovery System

GAO-06-618

Contents

Letter 1

Results in Brief 5
Background 10
Leadership Is Critical for Preparing for, Responding to, and Recovering
from Catastrophic Disasters 19
Enhanced Capabilities for Catastrophic Response and Recovery Are Needed 36
Balance Needed between Quick Provision of Assistance and Ensuring
Accountability to Protect against Waste, Fraud, and Abuse 71
Long-Term Recovery and Rebuilding Efforts Raise Issues for Congress to
Consider 84
Conclusions 96
Recommendations 98
Agency Comments 101
GAO Contacts 103
Appendix I Summary of Key Open GAO Recommendations on Catastrophic
Disasters 105
Appendix II Comments from the Department of Homeland Security 121
Appendix III Comments from the Small Business Administration 133
Appendix IV GAO Contact and Staff Acknowledgments 136
Related GAO Products 137

Tables

Table 1: Findings in Reports by Congress and the Administration 18
Table 2: Implementation of White House Homeland Security Council
Recommendations for the 2006 Hurricane Season: Recommendations Related to
Leadership Issues 33
Table 3: Implementation of White House Homeland Security Council
Recommendations for the 2006 Hurricane Season: Recommendations Related to
Regarding Capabilities 66
Table 4: Key Open Recommendations Made Prior to Hurricanes Katrina and
Ritaaa 105
Table 5: Recent Open Recommendations Made in the Aftermath of Hurricanes
Katrina and Ritaa 109
Table 6: New GAO Recommendations Formalized in this Report 120

Abbreviations

DCMS Disaster Credit Management System DOD Department of Defense DHS
Department of Homeland Security

ESF Emergency Support Function FCO Federal Coordinating Officer FEMA
Federal Emergency Management Agency

HHS Health and Human Services HSPD Homeland Security Presidential
Directive IHP Individuals and Households Program

JFO Joint Field Office

NDMS National Disaster Medical System NFC National Finance Center NFIP
National Flood Insurance Program NIMS National Incident Management System

NOAA National Oceanographic and Atmospheric Administration NRP National
Response Plan PFO Principal Federal Officer SBA Small Business
Administration

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United States Government Accountability Office

Washington, DC 20548

September 6, 2006 September 6, 2006

The Honorable Susan M. Collins Chairman The Honorable Joseph I. Lieberman
Ranking Minority Member Committee on Homeland Security and Governmental
Affairs United States Senate The Honorable Susan M. Collins Chairman The
Honorable Joseph I. Lieberman Ranking Minority Member Committee on
Homeland Security and Governmental Affairs United States Senate

The Honorable Peter T. King Chairman The Honorable Bennie G. Thompson
Ranking Minority Member Committee on Homeland Security House of
Representatives The Honorable Peter T. King Chairman The Honorable Bennie
G. Thompson Ranking Minority Member Committee on Homeland Security House
of Representatives

The Honorable Tom Davis Chairman The Honorable Henry A. Waxman Ranking
Minority Member Committee on Government Reform House of Representatives
The Honorable Tom Davis Chairman The Honorable Henry A. Waxman Ranking
Minority Member Committee on Government Reform House of Representatives

Just over 1 year ago, Hurricane Katrina made final landfall in coastal
Louisiana and Mississippi, and its destructive force extended to the
western Alabama coast. Hurricane Katrina was the worst natural disaster in
our nation's history in geographic scope, the extent and severity of its
destruction and damage, and the number of persons displaced from their
homes. Hurricane Katrina and the following Hurricanes Rita and Wilma-also
among the most powerful hurricanes in the nation's history-graphically
illustrated the limitations at that time of the nation's readiness and
ability to respond effectively to a catastrophic disaster-that is, a
disaster whose effects almost immediately overwhelm the response
capacities of affected state and local first responders and require
outside action and support from the federal government and other entities.
Reports by the House Select Bipartisan Committee to Investigate the Just
over 1 year ago, Hurricane Katrina made final landfall in coastal
Louisiana and Mississippi, and its destructive force extended to the
western Alabama coast. Hurricane Katrina was the worst natural disaster in
our nation's history in geographic scope, the extent and severity of its
destruction and damage, and the number of persons displaced from their
homes. Hurricane Katrina and the following Hurricanes Rita and Wilma-also
among the most powerful hurricanes in the nation's history-graphically
illustrated the limitations at that time of the nation's readiness and
ability to respond effectively to a catastrophic disaster-that is, a
disaster whose effects almost immediately overwhelm the response
capacities of affected state and local first responders and require
outside action and support from the federal government and other entities.
Reports by the House Select Bipartisan Committee to Investigate the
Preparation for and Response to Hurricane Katrina,1 the Senate Homeland
Security and Governmental Affairs Committee,2 the White House Homeland
Security Council,3 the Department of Homeland Security (DHS) Inspector
General,4 and DHS and the Federal Emergency Management Agency (FEMA)5 have
all identified a variety of failures and some strengths in the
preparations for, response to, and initial recovery from Hurricane
Katrina. Collectively, these reports, along with GAO's various reports and
testimonies, have chronicled the strengths and weaknesses of federal,
state, local, and nongovernmental efforts, and offered a number of
specific recommendations for improving the nation's ability to effectively
prepare for and respond to catastrophic disasters. Legislation to
reorganize the federal government's emergency response responsibilities
has been introduced in both the House and the Senate and the
administration has undertaken several efforts to address disaster
management weaknesses identified in the aftermath of the 2005 hurricane
season.

The 2005 hurricane season was particularly active, and the National
Oceanographic and Atmospheric Administration (NOAA) estimated that there
was a 75-percent probability of another active hurricane season in 2006
(the hurricane season runs from June 1st through November 30th each year).
However, NOAA reminds us that hurricane-spawned catastrophic disasters can
occur even in years with near-normal or below-normal levels of activity.
The nation's second most destructive hurricane-Andrew in 1992-occurred
during a season with otherwise below normal activity. Moreover, the nation
must be prepared to respond to and recover from a wide range of other
disasters that may occur at any time of year and could be the result of
nature or human action, such as a possible influenza pandemic or terrorist
attack.

1A Failure of Initiative: Final Report of the House Select Bipartisan
Committee to Investigate the Preparation for And Response to Hurricane
Katrina (Washington, D.C.: Feb. 15, 2006).

2Hurricane Katrina: A Nation Still Unprepared (Washington, D.C.: May
2006).

3The Federal Response to Hurricane Katrina: Lessons Learned (Washington,
D.C.: Feb. 23, 2006).

4A Performance Review of FEMA's Disaster Management Activities in Response
to Hurricane Katrina, OIG-06-32 (Washington, D.C.: Mar. 31, 2006).

5DHS/FEMA Initial Response Hotwash: Hurricane Katrina in Louisiana,
DR-1603-LA (Baton Rouge, La.: Feb. 13, 2006).

In a March 2006 testimony,6 we provided our preliminary observations
regarding the preparedness for, response to, and recovery from Hurricanes
Katrina and Rita. We noted that the key issues were in many ways very
reminiscent of the issues identified in the wake of Hurricane Andrew in
19927 and fell into three broad, interrelated categories: (1) leadership,
including clearly defined roles and responsibilities of all key
participants; (2) building and sustaining effective capabilities through
coordinated planning, training, and exercises; and (3) maintaining
accountability for the use of resources while providing assistance and
resources as quickly as possible. The overall objective of this work was
(1) to provide Congress with a summary of what went well and why, what did
not go well and why, and what specific changes are needed to improve this
nation's emergency preparedness, response, and recovery system; and (2)
identify selected issues associated with the Gulf Coast's recovery.
Following the themes from our prior work, this report discusses the major
findings from our recent and ongoing work on the aftermath of Hurricane
Katrina and relevant findings from Congress and the administration with
respect to (1) the actions of government agencies during Hurricane Katrina
that made positive contributions to the response and recovery and those
that were less positive; (2) catastrophic disaster leadership roles and
responsibilities; (3) capabilities to prepare for, respond to, and recover
from catastrophic disasters; (4) recognizing the tension between the need
for timely action and the need for appropriate controls and accountability
mechanisms; and (5) selected longer-term recovery issues, including the
rebuilding effort along the Gulf Coast.

This report is based on our work on Hurricanes Katrina and Rita and our
visits to the areas most affected by Hurricanes Katrina and Rita-Alabama,
Louisiana, Mississippi, and Texas. We interviewed various officials,
including senior federal officials, the governors of Alabama, Louisiana,
Mississippi, and Texas, and the mayor of New Orleans. We also analyzed
information from the various involved federal agencies, such as FEMA and
the Department of Defense (DOD) and the federal audit community; state
organizations including state emergency management agencies; National
Guard officials in the states, state agencies and state auditors; local
officials; and representatives from nongovernmental agencies. We also have
studied the findings in reports issued by Congress, DHS/FEMA, DHS's Office
of Inspector General, and the White House Homeland Security Council.

6GAO, Hurricane Katrina: GAO's Preliminary Observations Regarding
Preparedness, Response, and Recovery, GAO-06-442T (Washington, D.C.: Mar.
8, 2006).

7GAO, Disaster Management: Improving the Nation's Response to Catastrophic
Disasters, GAO/RCED-93-186 (Washington, D.C.: July 23, 1993).

In addition, we have an extensive body of work on prior catastrophic
disasters. For example, we drew upon several past reviews in 1993,
examining the federal response to Hurricane Andrew. We also conducted
extensive work following the events of September 11, 2001,8 and on tsunami
preparedness and recovery issues.9 Our reports focused on improving the
immediate response to catastrophic disasters that raise unique challenges,
and we made various recommendations within this context, many of which
continue to apply and help form the basis of our views today, including
the issue of FEMA's future organizational placement. In the months
following Hurricane Katrina, we provided support to congressional
investigations of the preparedness for and response to Hurricane Katrina
and have issued reports on such topics as the military's role in
catastrophic disasters;10 contracting practices for response and recovery
activities;11 the evacuation of hospitals, nursing homes and other
vulnerable populations;12 charitable assistance and the coordination
between FEMA and the Red Cross;13 ensuring the appropriate use and
accountability for international assistance;14 and issues associated with
guarding against fraud in the provision of expedited assistance to
disaster victims.15 To date we have published over 30 GAO reports and
testimonies on Hurricane Katrina-related matters. We will continue to
focus on ways to improve the nation's readiness and capacity to respond to
catastrophic disasters as well as issues associated with the long-term
recovery of the Gulf Coast region, including housing, health care, levee
reconstruction, and economic recovery.

8GAO, Disaster Assistance: Information on FEMA's Post 9/11 Public
Assistance to the New York City Area, GAO-03-926 (Washington, D.C.: Aug.
29, 2003); and GAO, September 11: Overview of Federal Disaster Assistance
to the New York City Area, GAO-04-72 (Washington, D.C.: Oct. 31, 2003).

9GAO, U.S. Tsunami Preparedness: Federal and State Partners Collaborate to
Help Communities Reduce Potential Impacts, but Significant Challenges
Remain, GAO-06-519 (Washington, D.C.: June 5, 2006); and Foreign
Assistance: USAID Has Begun Tsunami Reconstruction in Indonesia and Sri
Lanka, but Key Projects May Exceed Initial Cost and Schedule Estimates,
GAO-06-488 (Washington, D.C.: Apr. 14, 2006).

10GAO, Hurricane Katrina: Better Plans and Exercises Needed to Guide the
Military's Response to Catastrophic Natural Disasters, GAO-06-643
(Washington, D.C.: May 15, 2006).

11See GAO, Agency Management of Contractors Responding to Hurricanes
Katrina and Rita, GAO-06-461R (Washington, D.C.: Mar. 16, 2006); Hurricane
Katrina: Planning for and Management of Federal Disaster Recovery
Contracts, GAO-06-622T (Washington, D.C.: Apr. 10, 2006); and Hurricane
Katrina: Improving Federal Contracting Practices in Disaster Recovery
Operations, GAO-06-714T (Washington, D.C.: May 4, 2006).

12See GAO, Disaster Preparedness: Preliminary Observations on the
Evacuation of Hospitals and Nursing Homes Due to Hurricanes, GAO-06-443R
(Washington, D.C.: Feb. 16, 2006); and Disaster Preparedness: Preliminary
Observations on the Evacuation of Vulnerable Populations due to Hurricanes
and Other Disasters, GAO-790T (Washington, D.C.: May 18, 2006); Disaster
Preparedness: Limitations in Federal Evacuation Assistance for Health
Facilities Should be Addressed, GAO-06-826 (Washington, D.C.: July 20,
2006).

We conducted our work from September 2005 through August 2006, in
accordance with generally accepted government auditing standards.

                                Results in Brief

While much of the publicity regarding Hurricane Katrina has focused on
what did not go well in connection with the governments' activities, there
are notable exceptions. For example, the National Weather Service and the
National Hurricane Center provided accurate forecasts of the time and
location of Hurricane Katrina's landfall, accompanied by warnings of the
hurricane's potential destructive force. Dedicated and heroic efforts by
many, including local first responders, hospital personnel, the U.S. Coast
Guard, the National Guard, active duty military troops, and volunteers
saved thousands of lives. Federal agencies such as the Postal Service, the
Social Security Administration, the National Finance Center, the Forest
Service, and the Internal Revenue Service demonstrated their flexibility
and adaptability, responding to Katrina's challenges. Many states sent
supplies, first responders, National Guard personnel, and other resources
to assist the areas hardest hit by the disasters. Many charitable,
faith-based and private sector organizations supplemented governmental
efforts providing food and shelter for thousands. Despite these efforts,
various reports and our own work on the 2005 catastrophic disasters
suggest that the substantial human, financial, and technological resources
and capabilities marshaled by governments at all levels were inadequate to
meet the immediate challenges posed by the disaster's unprecedented
geographic scope, degree of damage, and the resulting number of hurricane
victims who had to be relocated.

13See GAO, Hurricanes Katrina and Rita: Provision of Charitable
Assistance, GAO-06-297T (Washington, D.C.: Dec. 13, 2005); and Hurricanes
Katrina and Rita : Coordination between FEMA and Red Cross Should Be
Improved for the 2006 Hurricane Season, GAO-06-712 (Washington, D.C.: June
8, 2006).

14GAO, Hurricane Katrina: Comprehensive Procedures Are Needed to Ensure
Appropriate Use of and Accountability for International Assistance,
GAO-06-460 (Washington, D.C.: Apr. 6, 2006).

15GAO, Expedited Assistance for Victims of Hurricanes Katrina and Rita:
FEMA's Control Weaknesses Exposed the Government to Significant Fraud and
Abuse, GAO-06-655 (Washington, D.C.: June 16, 2006).

In preparing for, responding to, and recovering from any catastrophic
disaster, the legal authorities, roles and responsibilities, and lines of
authority at all levels of government must be clearly defined, effectively
communicated, and well understood in order to facilitate rapid and
effective decision making. The experience of Hurricane Katrina showed the
need to improve leadership at all levels of government in order to better
respond to a catastrophic disaster. For example, there were problems
experienced with roles and responsibilities under the National Response
Plan (NRP),16 and ambiguities concerning what constituted an incident of
national significance to trigger the NRP as well as what constituted a
catastrophic incident to trigger the proactive response of the NRP's
Catastrophic Incident Annex. On May 25, 2006, DHS released changes to the
NRP regarding leadership issues, such as which situations require
secretarial leadership; the process for declaring incidents of national
significance; and the scope of the NRP and its Catastrophic Incident
Annex. The revised NRP clearly states that the Secretary of Homeland
Security, who reports directly to the President, is responsible for
declaring and managing incidents of national significance, including
catastrophic incidents. DHS has not yet published the final supplement to
the Catastrophic Incident Annex, which is intended to provide more detail
for implementing the annex. Until the supplement is final and distributed,
agencies that have responsibilities under the supplement cannot complete
the implementation plans and agreements needed to make the annex and
supplement fully operational. The White House Homeland Security Council
report included 44 recommendations that were intended to be implemented
quickly, of which 18 are focused on improving and clarifying the legal
authorities, roles and responsibilities, and lines of authority. DHS has
provided limited information on the status of its implementation of the
White House recommendations, although it has reported actions taken on
some issues raised in the White House Homeland Security Council report and
in other critiques. For example, DHS has designated principal federal
officials and federal coordinating officers for regions and states at-risk
of hurricanes and further described their respective roles in coordinating
disaster response-a source of some confusion in the federal response to
Hurricane Katrina. However, the changes may not have fully resolved the
leadership issues with regard to the roles of the principal federal
officer and federal coordinating officer. While the Secretary of Homeland
Security may avoid conflicts by appointing a single individual to serve in
both positions in non-terrorist incidents, confusion may persist if the
Secretary of Homeland Security does not exercise this discretion to do so.
Furthermore, this discretion does not exist for terrorist incidents, and
the revised NRP does not specifically provide a rationale for this
limitation. Congress also has raised concerns that FEMA's performance
problems exhibited during the hurricane response may stem from its
organizational placement and its budgetary relationship within DHS. As we
stated in our March 8 and May 9, 2006, testimonies, organizational changes
alone, while potentially important, will not be enough to adequately
address the underlying systemic conditions that resulted in FEMA's
performance problems during the last hurricane season. In our view, a
number of other factors may be ultimately more important to FEMA's success
in responding to and recovering from future disasters, including
catastrophic disasters, than its organizational placement. We have
identified several factors that Congress should consider as it deliberates
FEMA's organizational placement: (1) mission relevancy, (2) similarity of
goals and objectives, (3) the ability to leverage the effectiveness of
other agencies, and (4) gains through consolidation.

16The National Response Plan is the basis for how federal departments and
agencies are to work together with state, local, and tribal governments
and the private sector in managing domestic incidents.

As stated earlier, numerous reports and our own work suggest that the
substantial resources and capabilities marshaled by state, local, and
federal governments and nongovernmental organizations were insufficient to
meet the immediate challenges posed by the unprecedented degree of damage
and the resulting number of hurricane victims caused by Hurricanes Katrina
and Rita. Developing the capabilities needed for catastrophic disasters
should be part of an overall national preparedness effort that is designed
to integrate and define what needs to be done, where, based on what
standards, how it should be done, and how well it should be done. The
nation's experience with Hurricanes Katrina and Rita reinforces some of
the questions surrounding the adequacy of capabilities in the context of a
catastrophic disaster-particularly in the areas of (1) situational
assessment and awareness; (2) emergency communications; (3) evacuations;
(4) search and rescue; (5) logistics; and (6) mass care and sheltering.
Ensuring that needed capabilities such as these are available requires
effective planning and coordination, as well as training and exercises in
which the capabilities are realistically tested and problems identified
and subsequently addressed in partnership with other federal, state, and
local stakeholders, as capabilities are built upon the appropriate
combination of people, skills, processes, and assets. In addition, ongoing
work is still needed by DHS to address FEMA's human resource challenges.
Finally, as we stated in our March 2006 testimony, the use of a risk
management methodology-integrating systematic concern for risk into the
normal cycle of agency decision making and implementation-should be
central to assessing the risk for catastrophic disasters, guiding the
development of national capabilities and the expertise that can be used to
respond effectively to catastrophic disasters.

Although controls and accountability mechanisms help to ensure that
resources are used appropriately, during a catastrophic disaster
decision-makers struggle with the tension between implementing controls
and accountability mechanisms and the demand for rapid response and
recovery assistance. On one hand, our work found many examples where quick
action could not occur due to procedures that required extensive,
time-consuming processes, delaying the delivery of vital supplies and
other assistance. On the other hand, we also found examples where FEMA's
processes under assistance programs to disaster victims left the federal
government vulnerable to fraud and the abuse of expedited assistance
payments. We estimate that through February 2006, FEMA made about $600
million to $1.4 billion in improper and potentially fraudulent payments to
applicants who used invalid information to apply for expedited cash
assistance. DHS and FEMA have reported a number of actions that are to be
in effect for the hurricane season so that federal recovery programs will
have more capacity to rapidly handle a catastrophic incident but also
provide accountability. Examples include significantly increasing the
quantity of pre-positioned supplies, such as food, ice, and water; placing
global positioning systems on supply trucks to track their location and
better manage the delivery of supplies; an enhanced phone system for
victim assistance applications that can handle up to 200,000 calls per
day; and improved computer systems and processes for verifying the
eligibility of those applying for assistance. Effective implementation of
these and other planned improvements will be critical to achieving their
intended outcomes. Finally, catastrophic disasters not only require a
different magnitude of capabilities and resources for effective response,
they may also require more flexible policies and operating procedures. In
a catastrophe, streamlining, simplifying, and expediting decision making
should quickly replace "business as usual" and the unquestioned following
of long-standing policies and operating procedures used in normal
situations for providing relief to disaster victims. At the same time,
controls and accountability mechanisms must be sufficient to provide the
documentation needed for expense reimbursement and reasonable assurance
that resources have been used legally and for the purposes intended.

The federal government also will be a major partner in the longer-term
recovery and rebuilding of individuals and communities along the Gulf
Coast. Among the areas requiring federal attention are (1) assessing the
environmental hazards created by the storms; (2) rebuilding and
strengthening the levees; (3) providing assistance to school districts
that have enrolled large numbers of evacuee children; and (4) building the
capacity to address demand in multiple victims assistance programs such as
financial assistance or loans for repair and replacement of housing and
the rebuilding of businesses.

This report summarizes recommendations we have made in our work, some
following Hurricane Andrew in 1992 and others in the aftermath of
Hurricanes Katrina and Rita. We are also updating and formalizing several
recommendations initially presented in our March 8, 2006, testimony.
Specifically, we are recommending that DHS (1) rigorously re-test, train,
and exercise its recent clarification of the roles, responsibilities, and
lines of authority for all levels of leadership, implementing changes
needed to remedy identified coordination problems; (2) direct that the NRP
base plan and its supporting Catastrophic Incident Annex be supported by
more robust and detailed operational implementation plans; (3) provide
guidance and direction for federal, state, and local planning, training,
and exercises to ensure such activities fully support preparedness,
response, and recovery responsibilities at a jurisdictional and regional
basis; (4) take a lead in monitoring federal agencies' efforts to prepare
to meet their responsibilities under the NRP and the interim National
Preparedness Goal; (5) use a risk management approach in deciding whether
and how to invest finite resources in specific capabilities for a
catastrophic disaster; and (6) provide guidance on advanced procurement
practices and procedures for those federal agencies with roles and
responsibilities under the NRP so that these agencies can better manage
disaster-related procurement, and establish an assessment process to
monitor agencies' continuous planning efforts for their disaster-related
procurement needs and the maintenance of capabilities. We are also
recommending that Congress give federal agencies explicit authority to
take actions to prepare for all types of catastrophic disasters when there
is warning. We also offer some factors that Congress may wish to consider
as it carries out its oversight and legislative responsibilities with
regard to national preparedness and the recovery of the Gulf Coast region.

We provided a draft of this report to DHS for review and comment. On
August 28, 2006, DHS provided official written comments that generally
concurred with our recommendations and described an array of actions it
has taken, has underway, or planned to implement them. The full text of
DHS' comments is included in appendix II. We also provided relevant
sections of the draft report to various federal departments and agencies
including the departments of Agriculture, Education, Health and Human
Services, Housing and Urban Development, Labor, and State, as well as the
Small Business Administration, Environmental Protection Agency, and Social
Security Administration. All but two either stated they had no comments or
generally agreed with the sections that addressed their areas of
responsibility. The Department of Labor noted that it had reached
agreement with FEMA on coordination for disaster worker safety issues.
SBA's comments basically reiterated its comments on our July 28, 2006
report on its disaster assistance, to which we responded in that report.

                                   Background

Hurricanes Katrina and Rita left more than 1,500 dead, affected over
90,000 square miles, caused more than $80 billion in damage, and forced
mass evacuations from five states along the Gulf Coast, according to DHS.
An estimated 600,000 households were displaced from affected areas and
50,000 to 100,000 households remained in temporary housing 6 months later.
As a result, 44 states and the District of Columbia received hundreds of
thousands of evacuees, providing them with care and shelter over an
extended period. These events tested the nation's ability to respond to
catastrophic events and demonstrated the importance of ensuring the
effectiveness of federal, state, and local emergency response plans and
the ability to quickly synchronize intergovernmental efforts. This
catastrophic disaster provided a sobering picture of the overwhelming
strains on disaster response and recovery capacities if there are
back-to-back catastrophic disasters in the same area.

Significant local, state, and federal resources were mobilized to respond
to the Hurricane Katrina disaster, along with significant participation
from charitable and private-sector organizations. Among federal agencies,
the National Weather Service and its National Hurricane Center were
proactive and vigilant, accurately predicted and tracked the size, scale,
and path of Hurricane Katrina, and regularly contacted local, state and
federal leaders to apprise them of the situation. The Coast Guard,
National Guard, and state and local responders acted quickly to implement
search and rescue efforts that saved thousands of stranded and desperate
victims. The National Guard and the active military also played a major
role in saving lives, providing food and shelter, and transporting victims
who needed immediate medical care. Federal agencies such as the Postal
Service, Social Security Administration, National Finance Center, Forest
Service, and Internal Revenue Service demonstrated their flexibility in
performing needed activities and services, and responding in the face of
many challenges. However, the capabilities of several federal, state, and
local agencies were clearly overwhelmed. As events unfolded in the
immediate aftermath and ensuing days after Hurricane Katrina's final
landfall, responders at all levels of government-many victims
themselves-encountered significant breakdowns in vital areas such as
emergency communications as well as obtaining and deploying essential
supplies and equipment.

Stafford Act Is the Principal Federal Statute on Federal Disaster Assistance to
States and Localities

There are several federal legislative and executive provisions that
support preparation for and response to emergency situations. The Robert
T. Stafford Disaster Relief and Emergency Assistance Act (the Stafford
Act)17 primarily establishes the programs and processes for the federal
government to provide major disaster and emergency assistance to states,
local governments, tribal nations, individuals, and qualified private
nonprofit organizations. Upon a governor's request, the President can
declare an "emergency" or a "major disaster" under the Stafford Act, which
triggers specific types of federal relief. The Stafford Act defines an
emergency as any occasion or instance for which, in the determination of
the President, federal assistance is needed to supplement state and local
efforts and capabilities to save lives and to protect property and public
health and safety, or to lessen or avert the threat of a catastrophe in
any part of the United States. Under an emergency declaration, the federal
government has authority to engage in various emergency response
activities, such as debris removal, temporary housing assistance, and the
distribution of medicine, food, and other consumables. The Stafford Act
places a $5 million limit on federal emergency assistance, but the
President may exceed the limit, followed by a report to Congress.

The Stafford Act defines a "major disaster" as any natural catastrophe or,
regardless of cause, any fire, flood, or explosion, in any part of the
United States, which the President determines causes damage of sufficient
severity and magnitude to warrant major disaster assistance under the
Stafford Act to supplement the efforts and available resources of states,
local governments, and disaster relief organizations in alleviating
damage, loss, hardship, or suffering. Under a major disaster declaration,
the federal government has the authority to engage in the same activities
authorized under an emergency declaration, but without the $5 million
ceiling. In addition, major disaster assistance includes a variety of
assistance not available in the context of an emergency declaration. For
example, in a major disaster, the federal government may provide
unemployment assistance, food coupons to low-income households, and
repair, restoration and replacement of certain damaged facilities, among
other things.

1742 U.S.C. S:S: 5121-5206.

For Hurricane Katrina, the President issued emergency declarations under
the Stafford Act for Louisiana on August 27, 2005, and Mississippi and
Alabama on August 28, 2005. The President made major disaster declarations
for Florida on August 28, 2005, and Louisiana, Mississippi, and Alabama on
August 29, 2005, the same day that Hurricane Katrina made final landfall
in Plaquemines Parish, Louisiana at 6:10 a.m. and about 4 hours later at
the Louisiana/Mississippi border.

Federal Disaster Assistance and Relief Is to Be Administered by FEMA under the
Stafford Act

FEMA, within DHS, has responsibility for administering the provisions of
the Stafford Act, the principal federal statute governing federal disaster
assistance and relief. FEMA was an independent agency from 1979 until 2003
and was a cabinet-level agency from 1996 to 2003. FEMA became part of the
newly formed DHS in March 2003. Prior to FEMA's creation in 1979, federal
disaster response and recovery was managed by an agency within the
Department of Housing and Urban Development (HUD). The 1960s and early
1970s brought massive disasters requiring major federal response and
recovery operations by the Federal Disaster Assistance Administration, the
department within HUD responsible at that time for disaster response and
recovery. Hurricane Carla struck in 1962, Hurricane Betsy in 1965,
Hurricane Camille in 1969, and Hurricane Agnes in 1972. A major earthquake
hit Alaska in 1964, and the San Fernando earthquake rocked Southern
California in 1971. To respond to national concern regarding these events,
Congress passed the 1974 Disaster Relief Act that established the process
of presidential disaster declarations. However, emergency and disaster
activities were still fragmented. Many parallel programs and policies
existed at the state and local level, compounding the complexity of
federal disaster relief efforts. In 1979, President Carter issued an
executive order that merged many of the separate disaster-related
responsibilities into a new, independent Federal Emergency Management
Agency. Among other agencies, FEMA absorbed the Federal Insurance
Administration, the National Fire Prevention and Control Administration,
the National Weather Service Community Preparedness Program, the Federal
Preparedness Agency of the General Services Administration, and the
Federal Disaster Assistance Administration activities from HUD. Civil
defense responsibilities were also transferred to the new agency from the
Defense Department's Defense Civil Preparedness Agency.

Interstate Disaster Assistance was also Provided through the Emergency
Management Assistance Compact

In addition to resources provided by the federal government, states
affected by a catastrophic disaster can also turn to other states for
assistance in obtaining needed surge capacity-the ability to draw on
additional resources, such as personnel and equipment, needed to respond
to and recover from the incident. One way of sharing personnel and
equipment across state lines is through the use of an interstate compact
that provides a legal and administrative framework for such emergency
requests. Following the devastation of Hurricane Andrew in 1992, the
Southern Governors' Association, along with the Virginia Department of
Emergency Services, formed the Southern Regional Emergency Management
Assistance Compact (SREMAC) in August 1993. In 1995, SREMAC opened
membership to any state or territory, becoming the Emergency Management
Assistance Compact (EMAC), approved by Congress in 1996.18 As of September
2005, EMAC included all 50 states, the District of Columbia, Puerto Rico,
and the U.S. Virgin Islands and has been activated during a variety of
emergency events including hurricanes, floods, wildfires, and the
September 11 terrorist attacks. Administered by the National Emergency
Management Association (NEMA),19 the compact establishes a structure for
requesting and deploying assistance, reimbursing states that provide
assistance, and conferring liability and workers' compensation protection.
EMAC was not designed to supplant federal support nor does it obligate
member states to provide resources to another state.

The deployment of resources through EMAC in response to Hurricanes
Katrina, Rita, and Wilma was by far the largest use of state-to-state
mutual assistance in U.S. history. According to EMAC, as of March 24,
2006, Louisiana and Mississippi had made almost 1,900 requests for
assistance resulting in the deployment of 61,450 civilian and National
Guard personnel.

18Pub. L. No. 104-321, 110 Stat. 3877 (1996).

19 The National Emergency Management Association is a non-partisan,
non-profit 501(c)(3) association affiliated with The Council of State
Governments.

The Homeland Security Act Requires a Comprehensive Approach to Disaster
Preparation and Response

The Homeland Security Act of 2002 20 required the newly established DHS to
develop a comprehensive National Incident Management System (NIMS). NIMS
is intended to provide a consistent framework for incident management at
all jurisdictional levels regardless of the cause, size, or complexity of
the situation and to define the roles and responsibilities of federal,
state, and local governments, and various first responder disciplines at
each level during an emergency event. NIMS established the Incident
Command System as a standard incident management organization with five
functional areas-command, operations, planning, logistics, and finance and
administration-for management of all major incidents. It also prescribes
interoperable communications systems and preparedness before an incident
happens, including planning, training, and exercises.

The Homeland Security Act of 2002 also required DHS to consolidate
existing federal government emergency response plans into a single,
integrated and coordinated national response plan. In December 2004, DHS
issued the National Response Plan (NRP), intended to be an all-discipline,
all-hazards plan establishing a single, comprehensive framework for the
management of domestic incidents where federal involvement is necessary.
The NRP does not apply to the majority of incidents occurring each year
that are handled by local jurisdictions or agencies through established
authorities and existing plans under the planning assumption that
incidents are typically managed at the lowest possible geographic,
organizational, and jurisdictional level. Rather, the NRP is applicable to
incidents that go beyond the state and local level and require a
coordinated federal response. The NRP, operating within the framework of
NIMS, provides the structure and mechanisms for national-level policy and
operational direction for domestic incident management. The NRP also
includes a Catastrophic Incident Annex, which describes an accelerated,
proactive national response to catastrophic incidents. A draft of a more
detailed and operationally specific Catastrophic Incident Supplement for
the NRP's Catastrophic Incident Annex had not been approved at the time of
Hurricane Katrina, although the NRP's 120-day schedule for implementing
the supplement had passed. Once finalized, the supplement, as supported by
agency-level implementation agreements and plans, is to serve as the
operational framework for implementing the Catastrophic Incident Annex for
all types of catastrophes.

20Pub. L. No. 107-296, 116 Stat. 2135 (2002).

DHS Policies and Plans Have Identified a Strategy for Building and Sustaining
Preparedness, Response, and Recovery Capabilities

Capabilities-the ability to carry out specific tasks under particular
conditions with desired results-are built upon the appropriate combination
of people, skills, processes, and assets. Catastrophic disasters place
particularly wide-ranging demands on emergency response capabilities. By
their very nature, catastrophic disasters involve extraordinary levels of
mass casualties, damage, or disruption that are likely to immediately
overwhelm state and local responders. For non-catastrophic disasters, the
federal government has historically been in a support and assist role,
providing resources and other assistance to enable state and local
governments to carry out their responsibilities. However, for catastrophic
disasters that can overwhelm the ability of state and local and voluntary
agencies to adequately provide victims with essential services, the
federal government generally plays a more central role-providing selected
resources where they are needed or likely to be needed. As we noted in our
1993 report following Hurricane Andrew, where there is warning of a
catastrophic disaster, federal agencies need to mobilize resources and
deploy personnel before the disaster strikes so that the federal
government is ready and able to act quickly to assist the affected areas.
However, current law-in particular the Stafford Act-does not explicitly
authorize such pre-declaration activities.

Developing the capabilities needed for large-scale disasters is part of an
overall national preparedness effort that should integrate and define what
needs to be done, where, based on what standards, how it should be done,
and how well it should be done. Along with the NRP and NIMS, DHS has
developed the National Preparedness Goal, as required by Homeland Security
Presidential Directive 8 (HSPD-8). Considered as a group, these three
documents are intended to guide investments in emergency preparedness and
response capabilities. The NRP describes what needs to be done in response
to an emergency incident, the NIMS describes how to manage what needs to
be done, and the National Preparedness Goal describes how well it should
be done.

The interim National Preparedness Goal is particularly important for
determining what capabilities are needed, especially for a catastrophic
disaster. The December 2005 draft National Preparedness Goal defines both
the 37 major capabilities that first responders should possess to prevent,
protect from, respond to, and recover from a wide range of incidents and
the most critical tasks associated with these capabilities. An inability
to effectively perform these critical tasks would, by definition, have a
detrimental impact on effective protection, prevention, response, and
recovery capabilities. Since September 11, 2001, the federal government
has awarded almost $14 billion in grants and assistance to state and local
governments to assist in building emergency management capabilities.

Federal Government Is a Major Partner in Long-Term Recovery

Because of the widespread physical and economic damage to the Gulf Coast,
there are numerous examples of the federal government playing a major role
in support of state and local recovery efforts. Debris removal and repairs
to the region's public infrastructure and residential and commercial
properties are proceeding, to a significant extent, from federal funding
designated for the area and much remains to be done. The U.S. Army Corps
of Engineers is reconstructing the New Orleans levee system to fix those
parts of the system that failed during Hurricane Katrina. The federal role
in rebuilding will be particularly important for transportation and health
infrastructures and federal facilities.

Our prior work has identified state efforts underway to develop long-term
rebuilding strategies. In Louisiana, the governor and the mayor of New
Orleans have charged different groups with guiding various aspects of the
rebuilding efforts. In Mississippi, the Governor's Commission on Recovery,
Rebuilding and Renewal was formed to develop a strategy for rebuilding the
affected areas of Mississippi. On November 1, 2005, the President issued
Executive Order 13390, which directed the creation of a central figure in
the administration's efforts to support the Gulf Coast recovery and
rebuilding phases.21 Specifically, the President directed the Secretary of
Homeland Security to establish within the department the position of
Coordinator of Federal Support for the Recovery and Rebuilding of the Gulf
Coast region. The federal coordinator is responsible for developing
principles and goals, leading the development of federal recovery
activities, and monitoring the implementation of designated federal
support. The coordinator also serves as the focal point for managing
information flow, requests for actions, and discussions with Congress,
state and local governments, the private sector, and community leaders.

21"Establishment of a Coordinator of Federal Support for the Recovery and
Rebuilding of the Gulf Coast Region," Exec. Order No. 13390, 70 Fed. Reg.
67327 (2005).

Congress and the Administration Have Engaged in Numerous Efforts to Identify and
Recommend Improvements to Catastrophic Disaster Preparedness, Response, and
Recovery

Beginning in February 2006, several reports from Congress and the
administration have explored the events surrounding Hurricane Katrina and
chronicled many weaknesses and some strengths of the preparation and
response efforts, providing observations and recommendations to improve
national preparedness for and response to catastrophic disasters. Table 1
contains the resulting reports and a brief description of their findings.

Table 1: Findings in Reports by Congress and the Administration

Title and author              Major findings                               
DHS/FEMA Initial Response     Found improvements needed in areas of        
Hotwash: Hurricane Katrina in communications and interoperability; FEMA    
Louisiana (February 13, 2006) staffing; unified command; logistics and     
                                 staging; and operating procedures.           
Source: FEMA                  Recommendations for FEMA included: work to   
                                 strengthen emergency management capability   
                                 at state and local levels; review emergency  
                                 management architecture for response and     
                                 recovery operations; train, equip, and staff 
                                 response teams; improve the financial        
                                 management of disasters; improve leadership  
                                 and management; establish command authority  
                                 in the Joint Field Office (JFO); and         
                                 continue catastrophic planning with federal, 
                                 state, and local governments.                
A Failure of Initiative:      Identified 14 major findings including:      
Final Report of the House     critical elements of the NRP were executed   
Select Bipartisan Committee   late, ineffectively or not at all; there was 
to Investigate the            massive communications damage; command and   
Preparation for and Response  control was impaired at all levels, delaying 
to Hurricane Katrina          relief; and the military played an           
(February 15, 2006)           invaluable role but coordination was         
                                 lacking, among others. No recommendations    
Source: House of              provided.                                    
Representatives               
                                 
House Select Bipartisan       
Committee                     
The Federal Response to       Identified 17 critical challenges including  
Hurricane Katrina: Lessons    National Preparedness, Integrated Use of     
Learned (February 23, 2006)   Military Capabilities, Communications,       
                                 Logistics and Evacuation, Search and Rescue, 
Source: White House Homeland  Public Safety and Security, Public Health    
Security Council              and Medical Support, Human Services, Mass    
                                 Care and Housing, Public Communications,     
                                 Critical Infrastructure and Impact           
                                 Assessment, Environmental Hazards and Debris 
                                 Removal, Foreign Assistance,                 
                                 Non-Governmental Aid, Training, Exercises,   
                                 and Lessons Learned, Professional            
                                 Development and Education, Citizen and       
                                 Community Preparedness. Identified 125       
                                 recommendations for DHS, DOD, and other      
                                 federal departments and agencies, including  
                                 44 that were to be implemented by June 1,    
                                 2006.                                        
A Performance Review of       Found FEMA adapted to new response plans     
FEMA's Disaster Management    with difficulty; FEMA provided record levels 
Activities in Response to     of support but needs to improve delivery     
Hurricane Katrina (March 31,  structure; and FEMA needs to improve         
2006)                         readiness. Identified 38 recommendations.    
                                 
Source: Department of         
Homeland Security's Office of 
Inspector General             
Hurricane Katrina: A Nation   Found differing roles at different levels of 
Still Unprepared: Report of   government affected the response; long-term  
the Committee on Homeland     and short-term warnings went unheeded;       
Security and Governmental     preparation proved insufficient; response at 
Affairs (May 2006)            all levels of government was unacceptable;   
                                 long-term factors contributed to poor        
Source: U.S. Senate Committee response; and waste, fraud and abuses were   
on Homeland Security and      identified. Report identified seven          
Governmental Affairs          foundational recommendations based on        
                                 identified systemic weaknesses and           
                                 challenges.                                  

Source: GAO analysis of executive branch and congressional reports.

  Leadership Is Critical for Preparing for, Responding to, and Recovering from
                             Catastrophic Disasters

Our March 2006 testimony, along with the House, Senate, White House
Homeland Security Council, and DHS reports on the preparation for and
response to Hurricane Katrina discussed the vital importance of federal,
state, and local leadership, including clearly defined and well understood
roles and responsibilities. All the various critiques of Hurricane Katrina
concluded that leadership at all levels of government should be improved.
In preparing for, responding to, and recovering from any catastrophic
disaster, the legal authorities, roles and responsibilities, and lines of
authority for the preparation and response at all levels of government
must be clearly defined, effectively communicated, and well understood in
order to facilitate rapid and effective decision making. For example,
during Hurricane Katrina, separate roles specified in the NRP and in the
Stafford Act resulted in leadership uncertainty and may have slowed the
response, and some of the NRP's provisions were unclear and may have
hindered the federal government's ability to guide a more proactive
response. DHS has reported taking a number of actions to address
leadership issues raised in the various Hurricane Katrina reports,
particularly making revisions to the NRP to clarify roles,
responsibilities, and lines of authority. Another leadership issue raised
in the aftermath of the disaster was whether the organizational placement
of FEMA is appropriate for its mission.

Communicating and Clearly Defining Leadership Roles, Responsibilities, and Lines
of Authority in Advance of Catastrophic Disasters Is Essential to Effective
Response

Our March 2006 testimony, and other reports issued on the preparation for
and response to Hurricanes Katrina and Rita, have all identified the
importance of improved leadership and clearly defined and well understood
roles, responsibilities, and lines of authority at all levels of
government, especially in times of a catastrophe. In the response to
Hurricane Katrina there was confusion regarding roles and responsibilities
under the NRP. This included uncertainty concerning the roles of the
Secretary of Homeland Security, the Principal Federal Officer (PFO), and
the Federal Coordinating Officer (FCO), under the NRP.

At the time of Hurricane Katrina, there were three key roles in the
management of a catastrophic disaster. First, with the passage and
subsequent implementation of the Homeland Security Act of 2002, the
Secretary of Homeland Security became the cabinet-level focal point for
response to natural and man-made crises (such as major disasters and
terrorist incidents) requiring a coordinated response and developing a
single, coordinated national response plan for such crises and incidents.
We view this as a strategic role to coordinate federal activities and
policy from a national standpoint and be directly responsible and
accountable to the President, which is consistent with recommendations we
made in 1993. The revised NRP clearly states that the Secretary of
Homeland Security, who reports directly to the President, is responsible
for declaring and managing incidents of national significance, including
catastrophic incidents.

The response to Hurricane Katrina identified unresolved issues regarding
lines of authority with respect to the Secretary of Homeland Security and
the FEMA Director, as well as the key officials reporting to them, the PFO
to the secretary and the FCO to the FEMA Director. For example, in
response to Katrina, the Secretary of Homeland Security initially
designated the head of FEMA as the PFO, who appointed separate FCOs for
Alabama, Louisiana, and Mississippi. It was not, however, clear who was
responsible for coordinating the overall federal effort at a strategic
level. Our fieldwork indicated that the lack of clarity in leadership
roles and responsibilities resulted in disjointed efforts of many federal
agencies involved in the response, a myriad of approaches and processes
for requesting and providing assistance, and confusion about who should be
advised of requests and what resources would be provided within specific
time frames. The House Select Committee also found difficulties with roles
and responsibilities, including federal officials' unfamiliarity with
their roles and responsibilities under the NRP and NIMS. Likewise, the
White House Homeland Security Council made numerous recommendations,
including giving the PFO the same authority as an FCO to execute
responsibilities and coordinate federal response assets. According to the
White House Homeland Security Council report, giving the PFO this
authority could be accomplished without a change to the Stafford Act by
simply designating the PFO as an FCO.

In our March 8, 2006, testimony, we recommended that DHS clarify and
communicate the roles of the secretary, the PFO, and the FCO, consistent
with the provisions of the Homeland Security Act and the Stafford Act. In
May 2006, DHS revised the NRP to state that the Secretary of Homeland
Security may choose to combine the roles of the PFO and FCO in a single
individual to help ensure synchronized federal coordination for incidents
other than terrorist incidents.22 In instances where a single PFO/FCO has
been appointed, the revised NRP states that deputy FCOs will be designated
for the affected states to support the PFO/FCO. In addition, DHS has
pre-designated regional officials who will be PFOs and FCOs in the event
of an incident of national significance.

22The NRP revisions include a Quick Reference Guide that provides a
condensed, 23-page overview of the NRP as modified.

The NRP revisions may not fully resolve the leadership issues with respect
to the PFO and FCO roles. While the secretary may avoid conflicts by
appointing a single individual to serve as PFO and FCO in non-terrorist
incidents, confusion may persist if the secretary does not exercise this
discretion. Furthermore, this discretion does not exist for terrorist
incidents that may result in a Stafford Act declaration. In a
terrorist-caused incident, the PFO and FCO roles cannot be combined in a
single individual, as might be the case in a natural disaster. The revised
NRP does not specifically provide a rationale for this limitation,
although a terrorist incident would involve law enforcement and criminal
investigation activities that the PFO must coordinate with the Attorney
General's representative, the FBI Special Agent-in-Charge. Nevertheless,
it is not clear whether, and to what extent, the PFO's roles and
responsibilities might conflict with those of the FCO in a terrorist
incident resulting in a Stafford Act declaration. Given the persistent
confusion about the NRP regarding key federal leadership roles and
responsibilities in a catastrophic disaster, we are recommending that the
Secretary of Homeland Security rigorously re-test, train, and exercise its
recent clarification of the roles, responsibilities, and the lines of
authority for all levels of leadership, implementing changes needed to
remedy identified coordination problems.

New GAO recommendation to DHS to re-test, train and exercise its recent    
clarification of leadership roles                                          
DHS should rigorously re-test, train, and exercise its recent              
clarification of the roles, responsibilities, and lines of authority for   
all levels of leadership, implementing changes needed to remedy identified 
coordination problems.                                                     
    For more detailed information about our recommendations, see appendix I.  

Provisions of the NRP Regarding Incidents of National Significance Were Not
Clear at the Time of Hurricane Katrina, and Revisions Potentially Raise New
Issues

We identified an ambiguity in the NRP's triggering mechanisms that existed
at the time Hurricane Katrina hit the Gulf Coast-i.e., what actions were
necessary to activate the NRP. The NRP distinguished between incidents
that required DHS coordination and those that did not. Only those
requiring DHS coordination, termed "incidents of national significance,"
triggered activation of the NRP. However, it was not clear whether the
Secretary of Homeland Security needed to make a formal declaration of such
an incident to trigger the NRP or whether such an incident was
automatically triggered by one of four criteria contained in Homeland
Security Presidential Directive-5 (HSPD-5).23 In our March 2006 testimony,
we recommended that DHS clarify in the NRP whether the Secretary of
Homeland Security must formally declare an incident of national
significance to activate the NRP and, if not, whether the secretary must
take any specific actions when the President, in effect, activates the NRP
by declaring a Stafford Act emergency or major disaster.

The May 25, 2006, revisions to the NRP make clear that the Secretary of
Homeland Security must formally declare an incident of national
significance.24 The four factors stated in HSPD-5 continue to be primary
criteria for such a declaration, but the revised NRP states that the
Secretary of Homeland Security is not limited to these criteria and may
consider other factors in deciding whether to declare an incident of
national significance. According to the revisions, the key is whether the
incident is of such severity, magnitude, or complexity that it requires
the Secretary of Homeland Security to manage the federal response.

While clarifying the declarations process for incidents of national
significance, the revised NRP potentially raises new implementation
issues. First, the May 2006 revisions of the NRP state that the NRP is
"always in effect," but it is not clear what this means operationally.
Previously, the NRP only applied to incidents of national significance,
which were defined as those incidents requiring DHS coordination. Under
the revised NRP, incidents of national significance are not simply those
incidents requiring DHS coordination, but those that must be managed
directly by the Secretary of Homeland Security. While the revised NRP
makes clear that incidents of national significance must be declared by
and managed by the Secretary of Homeland Security, the revised NRP also
applies to incidents of lesser severity that may nevertheless require some
federal involvement. According to the revised NRP, such incidents are to
be managed by the federal department or agency with jurisdictional
authority based on a scaled and flexible implementation of the NRP. There
is no declarations process for incidents of lesser severity and there are
no specific plans detailing how agencies are to address such incidents. In
the absence of any implementation plans or a specific declaration or
designation process, leadership issues may arise in responding to issues
of lesser severity.

23The HSPD-5 criteria are: (1) a federal department or agency acting under
its own authority has requested the assistance of the Secretary of
Homeland Security; (2) the resources of state and local authorities are
overwhelmed and federal assistance has been requested by the appropriate
state and local authorities, for example, under the Stafford Act; (3) more
than one federal department or agency has become substantially involved in
responding to an incident; or (4) the Secretary of Homeland Security has
been directed by the President to assume responsibility for managing a
domestic incident.

24According to the Catastrophic Incident Annex, all catastrophic incidents
are Incidents of National Significance. Implementation of the annex
requires a separate catastrophic incident designation by the Secretary of
Homeland Security.

Proactive Response Provisions of the NRP's Catastrophic Incident Annex Were
Unclear at the Time of Hurricane Katrina, and Implementation Issues Remain

The NRP's Catastrophic Incident Annex also was a source of considerable
criticism after Hurricane Katrina. Under the NRP, a catastrophic incident
is any natural or manmade incident (including terrorism) that results in
extraordinary levels of mass casualties, damage, or disruption severely
affecting the population, infrastructure, environment, economy, national
morale, and/or government functions. A catastrophic incident could result
in sustained national impacts over a prolonged period of time; almost
immediately exceeds resources normally available to state, local, tribal,
and private-sector authorities in the impacted area; and significantly
interrupts governmental operations and emergency services to such an
extent that national security could be threatened. The annex describes an
accelerated, proactive national response to catastrophic incidents and
establishes protocols to pre-identify and rapidly deploy essential
resources expected to be urgently needed. At the time of Hurricane
Katrina, a draft supplement to the annex would have limited the annex's
scope to no-notice or short-notice catastrophic incidents, not incidents
that may evolve or mature to catastrophic magnitude, which could be the
case with strengthening hurricanes. Importantly, and consistent with a
prior GAO recommendation, the revised NRP does not include this
limitation. While stating that the catastrophic incident annex is
primarily designed to address no-notice or short-notice catastrophic
incidents that defy advance planning and resource pre-positioning, the
revised NRP states that projected catastrophic incidents (e.g.,
hurricanes) are also covered by the annex. In the event there is time to
assess the requirements and plan for a catastrophic event, the proactive
federal response and pre-positioning of assets is to be tailored to
address the specific situation.

A proactive approach to catastrophic disasters when there is warning is
consistent with recommendations we made in 1993 following Hurricane
Andrew.25 FEMA generally agreed with our findings and recommendations and
had begun taking actions to address them. We noted that some of the
improvements necessary in the overall federal response were outside of
FEMA's control, such as Presidential action to strengthen leadership for
the federal response by designating a key White House or cabinet-level
official to oversee the federal government's overall preparedness and
response activities for catastrophic disasters. In 1996, FEMA became a
cabinet agency whose director reported directly to the President,
consistent with our 1993 recommendation to the President.

The Homeland Security Act of 2002 made FEMA a part of DHS in March 2003,
with its director reporting to the Secretary of Homeland Security. As a
result of the new national response framework brought about by the
Homeland Security Act, HSPD-5 and the NRP, the Secretary of Homeland
Security became the cabinet-level focal point for emergency preparedness
and response, and the principal Federal official for domestic incident
management. The role assigned to the secretary through this framework is
consistent with our 1993 recommendation. However, the experience of
Katrina revealed some of the same problems that led to our 1993
recommendation, including a lack of clarity with regard to federal
leadership roles and responsibilities for the response. For example, the
secretary promptly designated the Director of FEMA as PFO under the NRP,
whose responsibilities included serving as the secretary's personal
representative on the scene, providing situational awareness, and
coordinating the federal response. However, as noted in subsequent
testimony and congressional reports, problems arose with regard to the
FEMA Director's reporting relationship with the secretary and the White
House during the response, and it was unclear who was directly accountable
to the President for the overall federal strategic coordination and
management of the incident. The Secretary of Homeland Security did not
perform this role, and the Director of FEMA was not in a position to
effectively perform this role. As noted above, the revised NRP addresses
this issue with respect to incidents of national significance, by
requiring the Secretary of Homeland Security to declare such incidents,
including those deemed catastrophic, and to manage the federal response
following such a declaration. Maintaining at the secretary level the
strategic role, described earlier, of coordinating federal activities and
policy from a national standpoint, and being directly responsible and
accountable to the President, is critical to ensuring an efficient federal
response and vital presidential leadership during a catastrophic disaster.
These responsibilities should be performed by the secretary and not
delegated to the PFO or FCO in such circumstances.

25 See GAO, Disaster Management: Improving the Nation's Response to
Catastrophic Disasters, GAO/RCED-93-186 (Washington, D.C.: July 23, 1993);
and Disaster Management: Recent Disasters Demonstrate the Need to Improve
the Nation's Response Strategy, GAO/T-RCED-93-46 (Washington, D.C.: May
25, 1993).

We continue to believe that our other 1993 recommendations still apply in
terms of improving the nation's response to catastrophic disasters. For
example, the NRP's catastrophic incident annex needs to be supported with
more robust and detailed operational implementation plans. In addition, we
are renewing our recommendation that Congress should consider giving
federal agencies explicit authority to take actions to prepare for
catastrophic disasters when there is warning. In 1993 we found that
federal response time could be reduced by encouraging agencies to do as
much advance preparation as possible prior to a disaster declaration. When
there is early warning, as there is for hurricanes, DOD and other federal
agencies need to mobilize resources and deploy personnel before the
catastrophe strikes. However, current law-in particular, the Stafford
Act-does not explicitly authorize such pre-declaration activities.
Therefore, federal agencies may fail to undertake advance preparation,
because of uncertainty over whether FEMA will request their assistance and
whether costs incurred before a disaster declaration will ultimately be
reimbursed by FEMA.

New GAO matter for congressional consideration                             
Congress should give federal agencies explicit authority to take actions   
to prepare for catastrophic disasters when there is warning.               
    For more detailed information about our recommendations, see appendix I.  

Our review of the NRP and its catastrophic incident annex-as well as
lessons from Hurricane Katrina-demonstrate the need for DHS and other
federal agencies to develop robust and detailed operational plans to
implement the catastrophic incident annex and its supplement in
preparation for and response to future catastrophic disasters. DHS has not
yet released the supplement to the catastrophic incident annex, more than
a year after Katrina and its original target date. The catastrophic
incident supplement is intended as the more operationally specific
companion to the catastrophic incident annex. For example, the September
2005 draft supplement includes operations to be carried out by local,
state, and federal responders; detailed execution schedules and
implementation strategies; functional capability overviews (such as
coverage for transportation support); and key responsibilities of federal
departments and agencies. Until DHS finalizes and distributes the
supplement, neither DHS nor other federal agencies that have
responsibilities under the supplement can finalize the detailed
implementation plans required to make the NRP fully operational for
catastrophic disasters. Therefore, as noted in our March testimony, we are
recommending that DHS direct that the NRP base plan and its Catastrophic
Incident Annex be supported by more robust and detailed operational
implementation plans, particularly the Catastrophic Incident Supplement to
the NRP. Such operational plans should, for example, further define and
leverage those military capabilities that might be needed in a
catastrophic disaster.26

New GAO recommendation to DHS for detailed and robust implementation plans 
for the NRP                                                                
DHS should direct that the NRP base plan and its Catastrophic Incident     
Annex be supported by more robust and detailed operational implementation  
plans, particularly the Catastrophic Incident Supplement to the NRP. Such  
operational plans should, for example, further define and leverage those   
military capabilities that might be needed in a catastrophic disaster.     
    For more detailed information about our recommendations, see appendix I.  

Federal Coordination Issues with the NRP Have Not Been Fully Addressed by Recent
Revisions

Our ongoing Hurricane Katrina-related work has identified other examples
of possible implementation issues within the NRP related to coordination
within and across federal government entities. These involve coordination
issues for search and rescue, the military response, worker safety and the
role and responsibilities of the Red Cross. First, the NRP did not fully
address search and rescue missions. While tens of thousands of people were
rescued through the efforts of the military, civilian government, and
private rescuers, the lack of clarity in search and rescue plans led to
operations that, according to aviation officials, were not as efficient as
they should have been. Under the National Search and Rescue Plan27 the
Coast Guard ordinarily had responsibility for providing or arranging
maritime search and rescue services, and the Air Force ordinarily had
responsibility for providing or arranging non-maritime search and rescue.
The plan also called on DOD to support civil search and rescue, and it
stated that DOD and Coast Guard commands should provide their facilities
for civil search and rescue to the fullest extent practicable. While the
NRP acknowledged the existence of the National Search and Rescue Plan, the
NRP did not specifically address how the Coast Guard and the Air Force
organizational responsibilities in the National Search and Rescue Plan
coincided with the NRP's urban search and rescue annex. In addition, the
National Search and Rescue Plan had not been updated to reflect the NRP.
As a result of the lack of clear search and rescue guidance, the aviation
portion of military search and rescue operations was not fully integrated
with the helicopter search and rescue operations of the Coast Guard and
other rescuers. Moreover, no one had the total picture of the missions
that had been resourced and the missions that still needed to be performed
during the response to Hurricane Katrina.

26GAO, Hurricane Katrina: GAO's Preliminary Observations Regarding
Preparedness, Response, and Recovery, GAO-06-442T (Washington, D.C.: Mar.
8, 2006).

Second, the military mounted a massive response to Hurricane Katrina that
saved many lives and greatly assisted recovery efforts. However, the NRP
made little distinction between the military response to smaller, regional
disasters and the military response to large-scale, catastrophic natural
disasters even though past disasters had shown that the military tends to
play a much larger role in catastrophes. We found a lack of understanding
within the military and among federal, state, and local responders as to
the types of assistance and capabilities that DOD might provide in the
event of a catastrophe-for example, timely damage assessments or
communications capabilities-the timing of this assistance, and the
respective contributions of the active-duty and National Guard forces. For
example, neither the NRP, DHS, nor DOD had fully identified the military's
extensive reconnaissance assets or communications capabilities that could
be brought to bear in a catastrophe. In the absence of this planning, some
of the military's available assets were never requested or proactively
deployed.

27The National Search and Rescue Plan (1999) provides an overall plan for
coordination of search and rescue operations, the effective use of all
available resources, mutual assistance, and efforts to improve such
cooperation and services. The goal of the plan is to integrate available
resources that can be used for search and rescue into a cooperative
network for greater protection of life and property and to ensure greater
efficiency and economy.

To improve the military response to catastrophic disasters, we have
recommended that the Secretary of Defense (1) provide proposed revisions
of the NRP to DHS that addresses the proactive functions the military is
expected to make during a catastrophic incident, and (2) establish
milestones and expedite the development of detailed plans and exercises to
fully account for the unique capabilities and support that the military is
likely to provide to civil authorities in response to the full range of
domestic disasters, including catastrophic disasters. Furthermore, the
plans and exercises should specifically address the use of reconnaissance,
communications, and search and rescue capabilities; integration of active
component and National Guard and Reserve forces; and the role the military
might be expected to play in logistics.28 DOD should direct the National
Guard Bureau to work with state governors to develop and maintain a list
of the types of capabilities the National Guard will likely provide in
response to domestic natural disasters. DOD commented on our
recommendations, partially concurring with each of them: DOD said that
proactive military functions can be identified in all 15 major disaster
scenarios and said it is working with the Department of Homeland Security
to revise the NRP. While DOD stated that the long-term focus of the U.S.
government should be to develop more robust domestic disaster capabilities
within the Department of Homeland Security, it acknowledged that DOD will
need to assume a more robust response role in the interim period, when
other responders lack the resources and expertise to handle a particular
disaster. DOD also listed a number of steps it is taking to improve its
disaster response planning and exercises. It also said that consistent
with its Strategy for Homeland Defense and Civil Support the active
component should complement, but not duplicate, the National Guard's
likely role as an early responder. DOD said that logistics planning and
execution are the clear responsibility of FEMA and individual states, and
DOD would remain ready in a supporting role. However, we continue to
believe that DOD should plan and prepare to assume additional emergency
support function responsibilities during catastrophic disasters when other
responders may be overwhelmed.

28 GAO-06-643 .

Recent GAO recommendations to DOD improve                                  
the military's response to catastrophic      
natural disasters                            DOD response
DOD should provide proposed revisions of the DOD is working with DHS to    
NRP to DHS that address the proactive        revise the NRP and            
functions the military is expected to        acknowledged that DOD will    
perform during a catastrophic incident.      need to assume a more robust  
                                                response role when other      
                                                responders lack the resources 
                                                and expertise to handle a     
                                                particular disaster.          
DOD should establish milestones and expedite DOD detailed a number of      
the development of detailed plans and        actions it is taking to       
exercises that address specifically the use  enhance its disaster planning 
of various military resources and role(s)    and exercises.                
the military might be expected to play in    
order to fully account for the unique        
capabilities and support that the military   
is likely to provide to civil authorities in 
response to the full range of domestic       
disasters, including catastrophic disasters. 
Plans and exercise should address the use of 
(1) reconnaissance, communication and search 
and rescue capabilities; (2) active and      
reserve forces; and (3) possible logistics   
role for the military.                       
DOD should direct the National Guard Bureau  DOD partially concurred with  
to work with state governors to develop and  this recommendation. DOD was  
maintain a list of types of capabilities the developing scalable           
National Guard will likely provide in        capability packages.          
response to domestic natural disasters.      
    For more detailed information about our recommendations, see appendix I.

Third, our ongoing work examining worker safety issues has found that the
Department of Labor's Occupational Safety and Health Administration (OSHA)
and FEMA officials disagreed about which agency was responsible for
ensuring the safety and health of response and recovery workers. OSHA and
FEMA disagreed over who had the leadership role as the Safety and Health
Coordinator at the Joint Field Office in each state and in the field. This
lack of clarity about each other's roles and procedures resulted in
delayed implementation of the NRP's Worker Safety and Health Support
Annex. Following a review of the draft of this report, OSHA reported that
their agency and FEMA have worked together to develop procedures for role
of the Safety and Health Coordinator in the Joint Field Office and for the
NRP's Worker Safety and Health Support Annex.

Lastly, the Red Cross and FEMA also had differing views about their roles
and responsibilities under Emergency Support Function-6 (ESF-6) of the
NRP, which hampered efforts to coordinate federal mass care assistance.
The two organizations differed in their understanding of the role of the
ESF-6 coordinator, according to a key FEMA official tasked with providing
strategic vision and leading efforts to coordinate federal mass care,
housing, and human services assistance. This difference in expectations
about the role of the ESF-6 coordinator created tension between FEMA and
the Red Cross and affected the organizations' working relationship.
Additionally, Red Cross staffing policies, which directed staff and
volunteers to rotate every 2 to 3 weeks and the absence of a comprehensive
FEMA system to track Red Cross requests for assistance also hindered the
Red Cross and FEMA's working relationship during hurricane relief efforts.
Red Cross and FEMA officials have stated they are working to clarify
future roles and responsibilities.

To clarify roles and responsibilities within ESF-6 for the 2006 hurricane
season, and to help ensure that FEMA's resource tracking system will meet
the needs of those requesting FEMA assistance, we have recommended that
the Secretary of DHS should direct FEMA to work with the Red Cross as soon
as possible to reach agreement on the operating procedures that they will
both use in the event of an incident of national significance and ensure
that FEMA obtains input from the Red Cross as it develops a resource
tracking system. DHS did not provide a response to our recommendations,
noting that FEMA was actively preparing for the hurricane season. We have
also recommended that the Chief Executive Officer of the Red Cross
implement ESF-6 staffing strategies that better facilitate the development
of working relationships and retain institutional knowledge.29

The Red Cross endorsed and is taking actions, as applicable, to address,
two of our recommendations. For example, the Red Cross said it has been
working closely with FEMA in recent months to develop and finalize a
memorandum of understanding that outlines areas of mutual support and
cooperation with respect to response and recovery in
presidentially-declared disasters and emergencies. Overall, the Red Cross
agreed with our conclusion that coordination between FEMA and the Red
Cross could be improved for the 2006 hurricane season. With respect to our
recommendation about staffing strategies, the Red Cross said that it is in
the process of hiring ESF-6 reservists who will be deployed for extended
periods of time to perform Red Cross ESF-6 mass care functions at the
federal level.

29GAO, Hurricanes Katrina and Rita: Coordination between FEMA and the Red
Cross Should Be Improved for the 2006 Hurricane Season, GAO-06-712
(Washington, D.C.: June 8, 2006).

Recent GAO recommendations to                                              
improve FEMA and Red Cross     
coordination                   DHS and Red Cross response
DHS should direct FEMA to work The Red Cross commented that it has been    
with the Red Cross as soon as  working closely with FEMA in recent months  
possible to reach agreement on to develop and finalize a memorandum of     
the operating procedures that  understanding that outlines areas of mutual 
they will both use in the      support and cooperation with respect to     
event of an incident of        response and recovery in                    
national significance.         presidentially-declared disasters and       
DHS should ensure that FEMA    emergencies.                                
obtains input from the Red     
Cross as it develops a         
resource tracking system.      
The Chief Executive Officer of The Red Cross said that it is in the        
the Red Cross should implement process of hiring ESF-6 reservists who will 
ESF-6 staffing strategies that be deployed for extended periods of time to 
better facilitate the          perform Red Cross ESF-6 mass care functions 
development of working         at the federal level.                       
relationships and retain       
institutional knowledge.       
    For more detailed information about our recommendations, see appendix I.

DHS Reported Taking Some Actions to Improve Leadership in Response to Findings
in Congress' and the Administration's Reviews

In addition to changes to the NRP, DHS has reported taking other actions
to improve DHS leadership during major disasters. In July 2006, Secretary
of Homeland Security Chertoff sent letters to the governors of Alabama,
Louisiana, and Mississippi identifying the PFO and FCO for their
respective states with the purpose of permitting coordinated,
collaborative federal, state, pre-disaster planning and communications.
Each of these letters differed somewhat in content, but generally
summarized the agreements on DHS's assistance for each state, including
pre-positioned supplies and equipment and identified key federal and state
roles and responsibilities in the event of a catastrophic event. Each
letter also emphasized that evacuation "is fundamentally a state and local
responsibility." Similar letters were also sent to the chief executive of
all the states and territories, according to DHS.

DHS has also reported taking other actions to improve DHS leadership
during major disasters through communications such as press releases,
speeches by top officials, and congressional testimonies by the Secretary
of Homeland Security, the Undersecretary for Preparedness, the recently
confirmed Undersecretary for Federal Emergency Management (who is also the
FEMA Director), and FEMA's Director of Operations. These reported actions
include improvements to national preparedness and integrating the use of
the military's capabilities. Table 2 lists the White House Homeland
Security Council recommendations regarding leadership, with the White
House Homeland Security Council report's "critical action"
recommendations. According to DHS officials, they were to have implemented
11 recommendations that the White House Homeland Security Council said
were essential for the 2006 hurricane season. However, DHS has not
provided us with the documentation needed to verify these actions. DHS
officials have stated that they have put a more experienced senior
leadership team in place at FEMA and created a National Operations Center
to improve coordination and situational awareness.

Table 2: Implementation of White House Homeland Security Council
Recommendations for the 2006 Hurricane Season: Recommendations Related to
Leadership Issues

                                                           Supporting         
                                       Primary agency(ies) agency(ies)        
Recommendation related to           responsible for     responsible for    
leadership                          implementation      implementation     
Critical Action Recommendation:     Department of       All federal        
Ensure co-location of relevant      Homeland Security   agencies           
federal, state, and local                               
decision-makers, including leaders                      
of state National Guards, to                            
enhance unity of effort.                                
Critical Action Recommendation: For Department of       Office of          
events preceded by warning, ensure  Homeland Security   Management and     
preparations to pre-position a                          Budget, Department 
fully resourced and integrated                          of Defense         
interagency Federal Joint Field                         
Office (JFO) to coordinate and, if                      
necessary, direct federal support                       
to the disaster.                                        
Critical Action Recommendation:     Department of       N/A                
Co-locate a single Department of    Defense, Department 
Defense point of contact at the JFO of Homeland         
and current FEMA regional offices   Security            
to enhance coordination of military                     
resources supporting the response.                      
Critical Action Recommendation:     Department of       All federal        
Identify and develop rosters of     Homeland Security   agencies           
federal, state, and local                               
government personnel who are                            
prepared to assist in disaster                          
relief.                                                 
Critical Action Recommendation:     Department of       Homeland Security  
Enhance ongoing review of state     Homeland Security   Council            
evacuation plans and incorporate                        
planning for                                            
continuity-of-government to ensure                      
continuation of essential and                           
emergency services.                                     
Establish an interagency team of    Department of       All federal        
senior planners with appropriate    Homeland Security   agencies           
emergency management experience to                      
conduct a comprehensive, 90-day                         
review of the NRP and the NIMS.                         
Revise the NRP to address           Department of       All federal        
situations that render state and    Homeland Security   agencies           
local governments incapable of an                       
effective response.                                     
PFO should have the authority to    Department of       N/A                
execute responsibilities and        Homeland Security   
coordinate federal response assets.                     
Establish National Information      Department of       All federal        
Requirements and a National         Homeland Security   agencies           
Information Reporting Chain.                            
Establish the Disaster Response     Homeland Security   Members of the     
Group.                              Council             Homeland Security  
                                                           Council            
Develop recommendations for         Department of       N/A                
revision of the NRP to delineate    Homeland Security,  
the circumstances, objectives, and  Department of       
limitations of when DOD might       Defense             
temporarily assume the lead for the                     
federal response to a catastrophic                      
incident.                                               
Revise the Immediate Response       Department of       N/A                
Authority policy to allow           Defense             
commanders, in appropriate                              
circumstances, to exercise this                         
authority even without a request                        
from local officials.                                   
Establish standards for "pushing"   Department of       All federal        
the pre-positioning of federal      Homeland Security   agencies           
assets to states and locals, in the                     
case of an imminent catastrophe.                        

Source: GAO analysis of DHS and Homeland Security Council data

Note: N/A = not applicable

As a Result of FEMA's Performance during Hurricane Katrina, Questions Have Been
Raised about Its Organizational Placement

FEMA's performance problems in responding to Hurricane Katrina have been
well documented in the several reports. In addition to the problems
related to roles and responsibilities and lines of authority previously
discussed, the House Select Committee noted that (1) senior officials were
ill prepared due to their lack of experience and knowledge of the required
roles and responsibilities prescribed by the NRP; (2) having lost a number
of top disaster specialists, senior leaders, and other experienced
personnel since 2002, DHS and FEMA lacked adequately trained and
experienced staff for the Katrina response; and (3) FEMA's logistics
systems were unable to support large-scale logistical challenges. There is
concern among members of Congress that the causes of FEMA's response and
recovery problems may stem from FEMA's organizational placement and its
budgetary relationship within DHS.

Different approaches have been suggested for addressing FEMA's performance
problems in responding to Hurricane Katrina. The White House Homeland
Security Council report's recommendations covered areas such as improving
DHS expertise and experience, development of a national crisis
communications system, and development of DHS regions that are fully
staffed, trained, and equipped to manage and coordinate all preparedness
activities and any emergency that may require a substantial federal
response. There are some proposals in Congress that would keep FEMA within
DHS, but statutorily reorganize the agency's responsibilities and lines of
authority. Other proposals would remove FEMA from DHS and reconstitute it
as an independent agency, much as it was prior to the creation of DHS. As
we stated in our March 8 and May 9, 2006, testimonies, organizational
changes alone, while potentially important, are not enough to adequately
address the underlying systemic conditions that resulted in FEMA's
performance problems. In our view, a number of factors may be ultimately
more important to FEMA's success in responding to and recovering from
future disasters than its organizational placement. Conditions underlying
FEMA's performance during Hurricane Katrina involved the experience and
training of DHS or FEMA leadership; the clarity of FEMA's mission and
related responsibilities and authorities to achieve mission performance
expectations; the adequacy of its human, financial, and technological
resources; and the effectiveness of planning, exercises, and related
partnerships. These issues must be addressed whether or not FEMA remains
in DHS. For example, we believe that the position of FEMA Director and
other key FEMA leadership and managerial positions could benefit from
having statutory professional qualifications requirements. In addition,
Congress should consider a term appointment for the FEMA Director and
other selected positions.

If an organizational change remains under consideration, our past work
could be helpful. Before the formation of DHS in 2003, we testified before
the House Select Committee on Homeland Security that reorganizations of
government agencies frequently encounter start-up problems and
unanticipated consequences, are unlikely to fully overcome obstacles and
challenges, and may require additional modifications in the future.30 Some
considerations from our prior work that are relevant to FEMA's
organizational placement include.

           o  Mission Relevancy: Is homeland security a major part of the
           agency or program mission? Is it the primary mission of the agency
           or program?

           o  Similar Goal and Objectives: Does the agency or program being
           considered share primary goals and objectives with the other
           components and programs in the department as a whole?

           o  Leverage Effectiveness: Does the agency or program under
           consideration create synergy and help to leverage the
           effectiveness of other agencies and programs within the department
           as a whole?

           o  Gains through Consolidation: Does the agency or program being
           considered improve the efficiency and effectiveness of homeland
           security missions through eliminating duplications and overlaps,
           closing gaps, and aligning or merging common roles and
           responsibilities?

In addition, the dispersion of responsibility for preparedness and
response across more than one federal agency was a problem we identified
during the formation of DHS. When Congress created DHS, it separated
FEMA's responsibilities for preparedness and response activities into two
DHS directorates. Responsibility for preparedness for terrorism disasters
was placed in the department's Border and Transportation Security
Directorate, which included FEMA's Office of National Preparedness. Other
types of FEMA disaster preparedness and response efforts were transferred
to the department's Emergency Preparedness and Response Directorate, which
included FEMA. In January 2003, we observed that this organizational
arrangement would challenge FEMA in ensuring the effective coordination of
preparedness and response efforts and enhancing the provision and
management of disaster assistance for efficient and effective response. A
division of responsibility remains under the recent DHS reorganization
resulting from Secretary Chertoff's Second Stage Review. Preparedness
efforts-including planning, training, exercising, and funding-are
consolidated into a Preparedness Directorate, while FEMA maintains
responsibility for response and recovery missions and reports directly to
the Secretary of Homeland Security.31 Secretary Chertoff has stated that
the reorganization would refocus FEMA on its historic mission of response
and recovery. Legislation has been introduced in both the House and Senate
that would reorganize the emergency management structure of the federal
government. Two of the bills, for example, would amend the Homeland
Security Act to create a new emergency management organization within DHS
that would combine FEMA and the Preparedness Directorate.32

30GAO, Homeland Security: Critical Design and Implementation Issues
GAO-02-957T (Washington, D.C.: July 17, 2002).

    Enhanced Capabilities for Catastrophic Response and Recovery Are Needed

Developing the capabilities needed for large-scale disasters is part of an
overall national preparedness effort that is designed to integrate and
define what needs to be done, where, based on what standards, how it
should be done, and how well it should be done. The nation's experience
with Hurricane Katrina reinforces some of the concerns surrounding the
adequacy of the nation's capabilities in the context of a catastrophic
disaster-particularly for capabilities such as the assessment of the
disaster's effects, communications, logistics of supplies and services,
and mass care and sheltering of victims. Ensuring that needed capabilities
are available requires effective planning and coordination and training
and exercises whereby capabilities are realistically tested, and problems
are identified and subsequently addressed across all stakeholders. DHS has
reported taking some actions to improve capabilities in response to
findings in Congress' and the administration's reviews. However, ongoing
work is still needed by DHS to address FEMA's significant human resource
challenges (e.g., a large number of open positions, skill gaps, and
succession planning challenges). Finally, risk management principles can
be applied as part of the development of capabilities to guide federal,
state, and local decision making by thinking about risk systematically
within the normal cycle of development and implementation at all levels.

31As a result of the Secretary's Second Stage Review, the Director of FEMA
also became the Undersecretary of Emergency Management.

32See  United States Emergency Management Authority Act of 2006, S. 3595,
109th Cong. S: 504 (2006); National Emergency Management Reform and
Enhancement Act of 2006, H.R. 5351, 109th Cong. S: 502(b) (2006).

Capabilities Were Not Adequate for a Catastrophic Disaster

The various reports and our own work on FEMA's performance before, during,
and after Hurricane Katrina suggest that FEMA's human, financial, and
technological resources and capabilities were insufficient to meet the
challenges posed by the unprecedented degree of damage and the resulting
number of hurricane victims. For example, the Senate's report concluded
that FEMA did not have the resources to fulfill the mission and respond
effectively in a catastrophic event and recommended that DHS develop the
national capabilities-especially adequate surge capacity-it needs to
respond to catastrophic disasters, ensuring it has sufficient full-time
staff, response teams, contracting personnel, and adequately trained and
sufficiently staffed reserve corps to ramp up capabilities, when needed.
The Senate report also identified the need for DHS to complete and/or
adopt technology and information management systems to effectively manage
catastrophic disaster-related activities. The report concluded that
resources are needed for staffing and preparation of regional strike
teams, better development of a trained cadre of reservists, and the
development of new logistics capabilities. FEMA's assessment of its
initial response concluded that the agency needed to lead an audit of
current staffing capability and workforce demands for staff in a severe or
catastrophic event and determine the number of personnel available to
serve in each position or unit for such an event. Their assessment also
concluded that FEMA needs to develop a communications suite that operates
independently of normal communications infrastructure and is able to be
moved into disaster locations. Similarly, the White House Homeland
Security Council report identified the need for each homeland security
region to have access to the resources, equipment, and personnel needed to
establish a self-sufficient, temporary Joint Field Office to direct
response and recovery efforts anywhere within the region.

In developing its lessons learned from Hurricane Katrina, the White House
Homeland Security Council has recommended that future preparedness of the
federal, state, and local authorities should be based on the risk,
capabilities, and needs structure of the National Preparedness Goal. More
specifically, the White House Homeland Security Council recommended that
the National Preparedness Goal and its target capabilities list should be
used, for example, in (1) defining required capabilities and what levels
of those capabilities are needed, including those within the purview of
the federal government; (2) developing mutual aid agreements and compacts
informed by the National Preparedness Goal's requirements; and (3)
developing strategies to meet required levels of capabilities that
prioritize investments on the basis of risk.

Developing the capabilities needed for large-scale disasters is part of an
overall national preparedness effort that is designed to integrate and
define what needs to be done, where, based on what standards, how it
should be done, and how well it should be done. The NRP defines
"preparedness" as the "range of deliberate, critical tasks and activities
necessary to build, sustain, and improve the operational capability to
prevent, protect against, respond to, and recover from domestic incidents.
Preparedness is a continuous process involving efforts at all levels of
government and between government and private-sector and nongovernmental
organizations to identify threats, determine vulnerabilities, and identify
required resources." In our earlier work on the National Preparedness
Goal, we observed that if properly planned and executed, the goal and its
related products, such as program implementation plans and requirements,
may help guide the development of realistic budget and resource plans for
an all-hazards national preparedness program.33 However, questions remain
regarding what should be expected in terms of the expanded capabilities
and mutual aid needed from other jurisdictions to meet the demands of a
catastrophic disaster. The nation's experience with Hurricane Katrina
reinforces some of the questions surrounding the adequacy of capabilities
in the context of a catastrophic disaster-particularly in the areas of (1)
situational assessment and awareness, (2) emergency communications, (3)
evacuations, (4) search and rescue, (5) logistics, and (6) mass care and
sheltering.

  Situational Assessment and Awareness

Situational assessment and awareness activities are a critical capability
common across all phases of an incident (i.e., preparedness, response, and
recovery), to immediately estimate services needed by communities and
disaster victims. The NRP notes that following a disaster, state and local
governments are responsible for conducting initial damage assessments, but
it also notes that state and local officials could be overwhelmed in a
catastrophe. Our prior work has pointed out that the NRP does not specify
the proactive means or capabilities the federal government should use to
conduct damage assessments and gain situational awareness when the
responsible state and local officials are overwhelmed. For example, the
military has significant assets to provide situational assessment and
awareness, and although some of its capabilities were employed during
Hurricane Katrina, there had been no advance planning among federal,
state, and local responders as to how DOD might support this capability in
the event of a catastrophic disaster. As a result, response efforts were
hampered by the federal government's failure to fully use its available
assets to conduct timely, comprehensive damage assessments in Louisiana
and Mississippi. In 1993, we also identified the failure to quickly assess
damage and gain situational awareness as a problem during Hurricane Andrew
in 1992.34 We recommended then that FEMA improve its catastrophic disaster
response capability by using existing authority to aggressively respond to
catastrophic disasters, assessing the extent of damage, and then advising
state and local officials of identified needs and the federal resources
available to address them.

33 GAO, Homeland Security: DHS' Efforts to Enhance First Responders'
All-Hazards Capabilities Continue to Evolve, GAO-05-652 (Washington, D.C.:
July 11, 2005).

Our analysis shows that neither the NRP nor DOD's functional plan
specifically called for the proactive use of the military's extensive
reconnaissance assets as part of a proactive response to catastrophic
incidents. About 4 days after Katrina's landfall the military began
providing imagery data from some of its reconnaissance assets to its
forces and civilian agencies, although some information was classified due
to its source and could not be shared directly with civilian agencies.
Also, some agencies were not able to access some of the available
information because the data files were too large to download. A National
Guard Hurricane Katrina after-action review reported that the adjutants
general in Mississippi and Louisiana required real-time imagery that the
military community should have been able to provide, but did not. Because
state and local officials were overwhelmed and the military's extensive
reconnaissance capabilities were not effectively leveraged, responders
began organizing and deploying without fully understanding the extent of
the damage or the required assistance. In contrast, DOD officials told us
that almost immediately after Hurricane Rita struck Louisiana and Texas in
September 2005, considerable assets were made available to assess damage,
primarily because of lessons learned from Hurricane Katrina.

34See GAO, Disaster Management: Improving the Nation's Response to
Catastrophic Disasters, GAO-93-186 (Washington, D.C.: July 23, 1993); and
Disaster Management: Recent Disasters Demonstrate the Need to Improve the
Nation's Response Strategy, GAO-93-46 (Washington, D.C.: May 25, 1993).

To improve the military response to catastrophic disasters, we have
recommended that the Secretary of Defense establish milestones and
expedite the development of detailed plans and exercises to fully account
for the unique capabilities and support that the military is likely to
provide to civil authorities in response to the full range of domestic
disasters, including catastrophes; and that the plans and exercises should
specifically address the use of reconnaissance capabilities.35 In May
2006, the Assistant Secretary of Defense for Homeland Defense testified
that U.S. Northern Command was developing a reconnaissance annex to its
Defense Support to Civil Authorities Contingency Plan and had tested the
annex's concepts during an 11-day exercise in May 2006.

Recent GAO recommendations to DOD to                                       
improve the military response to           
catastrophic disasters                     DOD response
DOD establish milestones and expedite the  U.S. Northern Command was       
development of detailed plans and          developing a reconnaissance     
exercises capabilities and support to      annex to its Defense Support to 
civil authorities in response to the full  Civil Authorities Contingency   
range of domestic disasters, including     Plan and had tested the annex's 
catastrophes; the plans and exercises      concepts during an 11-day       
should specifically address the use of     exercise in May 2006.           
reconnaissance capabilities.               
    For more detailed information about our recommendations, see appendix I.

  Emergency Communications

Emergency communications is a critical capability common across all phases
of an incident. Agencies communications systems during a catastrophic
disaster must first be operable, with sufficient communications to meet
everyday internal and emergency communication requirements. Once operable,
they then should have communications interoperability whereby public
safety agencies (e.g., police, fire, emergency medical services, etc.) and
service agencies (e.g., public works, transportation, and hospitals) can
communicate within and across agencies and jurisdictions in real time as
needed. Hurricane Katrina caused significant damage to the communication
infrastructure in Louisiana and Mississippi, which further contributed to
a lack of situational awareness for military and civilian officials.
Hurricane Katrina destroyed or severely degraded many commercial landline
and cellular telephone systems. In addition, emergency radio systems usage
exceeded their capacity, making it difficult to establish necessary
connections between officials and responders at the local, state, and
federal levels, and to implement other capabilities. For example, even
when local officials were able to conduct damage assessments, the lack of
communications assets caused delays in transmitting the results of the
assessments. As a result, it was difficult for officials to share
situational awareness.

35 GAO-06-643 .

The military, other government agencies, and public companies all have
extensive communications assets and capabilities, but DHS has
responsibility for coordinating communications for disaster response
operations under the NRP. Our work has found, however, that neither DHS
nor DOD fully identified the extensive military communication capabilities
that could be leveraged as part of a proactive federal response to
catastrophic disasters.36 For example, although DOD's emergency response
plan addressed internal military communications requirements, DOD did not
address the communication requirements of communities affected by a
catastrophic natural disaster, and it did not address coordination with
civilian responders. As previously noted, we have made recommendations to
the Secretary of Defense to develop detailed plans and exercises regarding
the unique capabilities and support, such as communications capabilities,
that the military is likely to provide to civil authorities.37 In May
2006, the Assistant Secretary of Defense for Homeland Defense testified
that DOD had taken a number of steps to increase communications
capabilities in regions affected by disasters. These include authorizing
the Command of U.S. Northern Command to deploy communications capabilities
and develop pre-scripted requests for assistance for deployable
communications options.

36 GAO-06-643.

37Typically, military equipment cannot communicate with civilian police,
fire, and emergency medical systems unless it is augmented with
specialized equipment. During Hurricane Katrina, the military and civilian
agencies deployed mobile communication vans that were able to connect
different communications systems that are normally incompatible.

Recent GAO recommendations to DOD                                          
improve federal leadership and     
cooperation in communications      DOD response
DOD should develop detailed plans  DOD has taken a number of steps to      
and exercises regarding the unique increase communications capabilities in 
capabilities and support, such as  regions affected by disasters. These    
communications capabilities, that  include authorizing the Command of U.S. 
the military is likely to provide  Northern Command to deploy              
to civil authorities.              communications capabilities and develop 
                                      pre-scripted requests for assistance    
                                      for deployable communications options.  
    For more detailed information about our recommendations, see appendix I.

Our prior work on interoperable communications identified problem
definition, performance goals and standards, and defining the roles of
federal, state, local government and other entities as the three principal
challenges to achieving effective interoperable communications for first
responders. The single greatest barrier to addressing the decades-old
problems of interoperable communications has been the lack of effective,
collaborative, interdisciplinary, and intergovernmental planning. Our 2004
recommendations called for DHS to: (1) work with the Federal
Communications Commission (FCC) to develop a nationwide database of
interoperable communications frequencies and a common nomenclature so that
first responders from different disciplines and jurisdictions can quickly
identify shared frequencies when arriving at the scene of an incident; (2)
establish interoperability requirements whose achievement can be measured;
and (3) encourage states through DHS grants to establish statewide bodies
that will develop a comprehensive statewide interoperable communications
plan and condition the purchase of new equipment on the adoption of such a
plan.38 DHS responded that it was developing a nationwide database of
interoperable public safety communications frequencies and also said it
planned to work on a common nomenclature across public safety disciplines
and jurisdictions. DHS also said it is developing a methodology to
establish a national baseline of public safety communication and
interoperability capabilities with input from the public safety community.
On June 16, 2006, the FCC published a Notice of Proposed Rulemaking to
address and implement the recommendations of an independent panel that
reviewed the impact of Hurricane Katrina on communications networks. The
FCC identified 18 actions that the Commission can take in conjunction with
the private sector and state and local governments, and other federal
departments, to promote heightened readiness and preparedness, and
effective and efficient response and recovery efforts.39

38GAO, Homeland Security: Federal Leadership and Intergovernmental
Cooperation Required to Achieve First Responder Interoperable
Communications, GAO-04-740 (Washington, D.C.: July 20, 2004).

  Evacuations

By definition, a catastrophic disaster like Hurricane Katrina will impact
a large geographic area, necessitating the evacuation of people-including
vulnerable populations, such as hospital patients, nursing home residents,
and transportation-disadvantaged populations who were not in such
facilities. Although state and local governments can order evacuations,
health care facilities can be exempt from these orders. Hospital and
nursing home administrators often face challenges related to evacuations
caused by hurricanes, including deciding whether to evacuate and obtaining
transportation. Nursing home administrators must locate receiving
facilities that can accommodate residents who may need a place to live for
a long period of time. If a hospital or nursing home does decide to
evacuate, contractors providing transportation for hospitals and nursing
homes could be unable to provide enough vehicles during a major disaster
because local demand for transportation could exceed supply.

We have conducted work related to the evacuation of special needs
populations in the aftermath of Hurricane Katrina. The National Disaster
Medical System (NDMS) is the primary federal program that supports the
evacuation of patients in need of hospital care during disasters such as
hurricanes. We found that the program has two limitations in its design
that constrain its assistance to state and local governments with patient
evacuation. The first limitation is that NDMS evacuation efforts begin at
a mobilization center, such as an airport, and do not include
short-distance transportation assets, such as ambulances or helicopters,
to move patients out of health care facilities to mobilization centers.
Even during a catastrophe when state and local government capabilities are
almost immediately overwhelmed, short-distance transportation remains a
state and local responsibility.40 The second limitation is that NDMS
supports the evacuation of patients needing hospital care; the program was
not designed nor is it currently configured to move people who do not
require hospitalization, such as nursing home residents, which remains a
state and local responsibility.

39Federal Communications Commission, Notice of Proposed Rulemaking,
FCC-06-83 (Washington, D.C.: June 19, 2006).

40The September 2005 draft Catastrophic Incident Supplement to the NRP is
intended to be used with the Catastrophic Incident Annex when a
catastrophic incident almost immediately overwhelms the capabilities of
state and local governments. The draft supplement does not describe what,
if any, role the federal government is to play in coordinating with state
and local authorities for this kind of transportation.

NDMS supplemented state and local emergency response capabilities with
federal resources and services and helped evacuate about 2,900 people
during recent hurricanes, including Hurricane Katrina. According to
program officials the program was actually designed to evacuate and
transport hospital patients starting from a federally-designated
mobilization center, although NDMS supported evacuation efforts during
Hurricane Katrina that included nursing home residents. NDMS officials
explained that the program does not have agreements with nursing homes
that could receive evacuated nursing home residents or appropriate
transportation such as special buses that could transport them.

To address limitations in how the federal government provides assistance
with the evacuation of health care facilities, we have recommended that
the Secretary of Homeland Security clearly delineate how the federal
government will assist state and local governments with the movement of
patients and residents out of hospitals and nursing homes to a
mobilization center where NDMS transportation begins; and in consultation
with the other NDMS federal partners-the Secretaries of Defense, Health
and Human Services, and Veterans Affairs-clearly delineate how to address
the needs of nursing home residents during evacuations, including the
arrangements necessary to relocate these residents.41 DHS said it would
take the recommendation under advisement as it reviews the National
Response Plan, confirming that the federal government becomes involved in
evacuations only when the capabilities of state and local governments are
overwhelmed.

41GAO, Disaster Evacuations: Limitation in Federal Assistance to Health
Facilities for Transportation Should Be Addressed, GAO-06-826 (Washington,
D.C.: July 20, 2006).

Recent GAO recommendations to DHS to                                       
improve federal assistance for health  
facility and nursing home disaster     
evacuations                            DHS response
DHS should clearly delineate how the   DHS said it would take the          
federal government will assist state   recommendation under advisement as  
and local governments with the         it reviews the NRP and stated that  
movement of patients and residents out all NDMS federal partners are       
of hospitals and nursing homes to a    currently reviewing a memorandum of 
mobilization center where NDMS         agreement with a view towards       
transportation begins.                 working with state and local        
                                          partners to delineate and clarify   
                                          roles and responsibilities.         
DHS should in consultation with the    
other NDMS federal partners-the        
Secretaries of Defense, Health and     
Human Services, and Veterans           
Affairs-clearly delineate how to       
address the needs of nursing home      
residents during evacuations,          
including the arrangements necessary   
to relocate these residents.           
    For more detailed information about our recommendations, see appendix I.

We conducted work examining the nation's efforts to protect children after
the Gulf Coast hurricanes and identified evacuation challenges for this
population.42 Thousands of children were reported missing to the National
Center for Missing and Exploited Children, which utilized its trained
investigators to help locate missing children after the evacuation.43
Officials from this center stated that both the American Red Cross and
FEMA had some information on the location of children in their databases;
however, they said it was difficult to obtain this information because of
privacy concerns. These officials told us that standing agreements for
data sharing among organizations tracking missing children, the Red Cross,
and FEMA could help locate missing persons more quickly. Regarding foster
children, Louisiana child welfare officials told us it was difficult to
contact foster parents who had evacuated because the emergency contact
information for them was limited and located in case records that was
inaccessible for weeks following the storm. They said updated emergency
contact information for foster parents and automated case file systems
could help locate and serve foster children more quickly. Also, child
welfare officials told us that having an adequate number of trained staff
present during large-scale evacuations can help ensure that families stay
together.

42GAO, Lessons Learned for Protecting and Educating Children after the
Gulf Coast Hurricanes, GAO-06-680R (Washington, D.C.: May 11, 2006).

43We observed that while the reasons children were separated from their
families are not fully understood, in many cases children were evacuated
separately from parents and sent to different shelters. All of the
instances of children reported missing to the National Center for Missing
and Exploited Children were resolved by March 2006. All of the children
reported missing were not necessarily unaccompanied or in harm's way; some
who were safe were probably reported as missing because non-guardians
(such as neighbors) could report a child as missing.

  Search and Rescue

Search and rescue is the capability to coordinate and conduct urban search
and rescue response efforts for all hazards. Urban search and rescue
response efforts require a seamless transition from finding stranded
people, rescuing them, and transporting them to safe shelter, which may
call on the additional skills and resources of responders, along with
support from other emergency support functions such as public safety.
Capabilities also can include accessing, medically stabilizing, and
extricating victims trapped in damaged or collapsed structures. The U. S.
Coast Guard, state and local agencies, and military assets rescued
thousands in the aftermath of Hurricane Katrina. Almost 6,000 Coast Guard
personnel from throughout the country conducted one of the largest search
and rescue missions in its history as part of an even larger multi-agency,
multi-level search and rescue effort, according to the White House
Homeland Security Council report. The Coast Guard retrieved more than
33,000 people along the Gulf Coast, including more than 12,000 by air, and
11,000 by surface, plus 9,403 evacuated from hospitals. Almost one-third
of the Coast Guard's entire fleet was dedicated to rescue efforts,
according to the White House Homeland Security Council report.

Search and rescue capabilities must also include ensuring the safety of
first responders. For example, following Hurricane Katrina's landfall,
Coast Guard rescue swimmers involved in the helicopter-based rescues told
us that safety and security became a concern as time passed and
individuals became frustrated because they had no food or water. In some
instances, tensions among survivors became heated when rescue swimmers
prioritized the rescues of children, women, and the elderly over
able-bodied men. For boat operations, officials explained that they dealt
with security challenges by deploying Coast Guard security teams with the
rescue personnel to provide armed security coverage for both Coast Guard
personnel and FEMA urban search and rescue teams.

In addition, although tens of thousands of people were rescued after
Hurricane Katrina through the efforts of military, civil government, and
private rescuers, the lack of clarity in search and rescue plans led to
operations that were not as efficient as they should have been. As we
noted in our discussion of leadership, the NRP at that time addressed only
part of the search and rescue mission, and the National Search and Rescue
Plan had not been updated to reflect the NRP. According to Louisiana
National Guard officials, they worked with the Coast Guard to coordinate
aviation operations, but the aviation search and rescue efforts that were
being directed from two different command sites were not integrated. For
example, some military aircraft received their direction from a military
task force at the Superdome, while others received their direction from
the Coast Guard or the Joint Task Force that was in command of the active
troops on the ground. According to military officials, better integration
of search and rescue efforts could reduce duplications of effort for
search and rescue aircraft. As previously noted, GAO has made
recommendations to the Secretary of Defense to improve planning for the
search and rescue support that the military is likely to provide to civil
authorities.44

  Logistics

Our work and that of others indicates that logistics systems-the
capability to identify, dispatch, mobilize, and demobilize and to
accurately track and record available critical resources throughout all
incident management phases--were often totally overwhelmed by Hurricane
Katrina. Critical resources apparently were not available, properly
distributed, or provided in a timely manner. The result was duplication of
deliveries, lost supplies, or supplies never being ordered. Reviews of
acquisition efforts indicated that while these efforts were noteworthy
given the scope of Hurricane Katrina, agencies needed additional
capabilities to (1) adequately anticipate requirements for needed goods
and services; (2) clearly communicate responsibilities across agencies and
jurisdictions; and (3) deploy sufficient numbers of personnel to provide
contractor oversight. For example, a factor that affected the military
response was the large and unanticipated logistics role it was asked to
assume. Under the NRP, FEMA is responsible for coordinating logistics
during disaster response efforts, but during Hurricane Katrina, FEMA
quickly became overwhelmed, in part because it lacked the people,
processes, and technology to maintain visibility-from order through final
delivery-of the supplies and commodities it had ordered. As a result of
FEMA's lack of visibility over the meals that were in transit, DOD had to
airlift 1.7 million meals to Mississippi to respond to a request from the
Adjutant General of Mississippi, who was concerned that food supplies were
nearly exhausted.

44 GAO-06-643 .

Similarly, our work examining the coordination between FEMA and the Red
Cross to provide relief to disaster victims found that FEMA did not have a
comprehensive system to track requests for assistance it received from the
Red Cross on behalf of voluntary organizations and state and local
governments for items such as water, food, and cots. The absence of such a
system created more work for the Red Cross and slowed the delivery of
relief services. The Red Cross was only able to follow up on these
requests informally-a process that took time and was often ineffective.
FEMA officials were often unable to provide the Red Cross with accurate
information regarding FEMA's ability to fulfill a request or when expected
items would be delivered, causing many requests to go unfilled or be
filled too late to be of use. The unreliability of FEMA's supply systems
required the Red Cross to try to follow up on requests through other
informal channels-a process the Red Cross reported as being inefficient
and only marginally effective. Other voluntary organizations also told us
that in many cases the unreliability of FEMA's supply systems hindered
their attempts to provide mass care services, and, as a result, they had
to scale back on their service provision.

In contrast, response efforts benefited from the logistical support of the
U.S. Forest Service. As the White House Homeland Security Council reported
in February 2006, about 3,000 members of the Forest Service  also deployed
to the region to support response efforts. Forest Service personnel in
Mississippi, Louisiana, Florida, and Alabama established support camps,
provided aviation assistance, and transported needed supplies to relief
workers. The base camps they established were capable of supporting 1,000
emergency responders at each site. According to the Forest Service, nearly
2,760 Forest Service employees nationwide were called upon to provide
assistance by using their incident management abilities to help manage
evacuation centers and base camps, provide logistical support, clear
roadways, and operate mobilization centers and trailer staging areas. They
also helped navigate the federal procurement system and successfully
obtained needed emergency response supplies, the White House Homeland
Security Council noted. Forest Services' incident management teams helped
to supply more than 600,000 people with 2.7 million meals, 4 million
gallons of water, and 40 million pounds of ice. One Forest Service region
sent nearly 470 people, including various types of interagency responder
teams, buying teams, and other services in the relief effort, according to
the Forest Service.

  Mass Care, Housing, and Human Services

This emergency support function includes the non-medical mass care,
housing, and human services needs of individuals and families. Mass care
is the capability to provide immediate shelter, feeding centers, basic
first aid, and bulk distribution of needed items and related services to
affected persons. Charities and government agencies that provide human
services, supported by federal resources, helped meet the mass care needs
of the hundreds of thousands of evacuees.

Recognizing the historically large role of charities in responding to
disasters, DHS collaborated with the American Red Cross in the development
of the NRP and gave it considerable responsibilities. In addition, the NRP
establishes a separate support annex that defines the capability to
effectively manage and deploy volunteers and unsolicited donations.
Federal and charitable organization officials we spoke to indicated that
because of the catastrophic nature of the storms, in some cases volunteers
and donations were not well integrated into response and recovery
activities.

Charities have taken steps to improve coordination of relief efforts since
September 11, 2001. These efforts have included sharing information about
relief services through daily conference calls and the use of electronic
databases. Additionally, charities coordinated service delivery to meet
the needs of evacuees. For example, the Red Cross did not work in areas
that might become flooded or in structures that could be compromised by
strong winds. During our visits to the Gulf Coast region in October 2005,
we observed that in areas where the Red Cross did not provide services,
the Salvation Army and smaller organizations-often local churches-were
able to meet many of the charitable needs of hard-to-reach communities.
Despite these efforts, charities faced some challenges in coordinating
service delivery. For example, some charities reported that the electronic
database created to share information about services provided to evacuees
was still in its developmental stage and, therefore, not ready to be
activated on such a large scale. Some concerns were also raised about
smaller charities' abilities to provide adequate disaster relief services.
Additionally, some Gulf Coast areas did not have sufficient shelter
facilities, in part because the Red Cross had in effect "shelter
protection policies" to promote evacuation of low-lying areas, which
prohibited the placement of shelters in areas prone to high winds, storm
surge, and flooding-causing some of the most severely affected areas to be
without sheltering facilities. In addition, some shelters were accessible
to the general population only during limited daylight hours.

In addition to immediate food and shelter, individuals may need help
replacing Social Security checks, obtaining food stamps or other basic
federal support benefits and services. Our preliminary work indicated that
a number of federal and state programs provided assistance and services to
eligible individuals and families before the catastrophic disaster.
Significant ongoing assistance after the catastrophic disaster has also
been required. Such basic federal support programs as food stamps, social
security, unemployment insurance, and income assistance played an
important role in the immediate response to those displaced or otherwise
affected by Hurricane Katrina. To ensure delivery of benefits, and in some
cases, to address the sharp rise in new applications, these programs set
up operations in shelters, disaster recovery centers, other sites, and
some programs served an unprecedented number of people in their offices
that serve the public. For example, Hurricane Katrina disrupted mail
delivery of monthly social security checks, leaving many social security
recipients without key income support. However, the Social Security
Administration had procedures in place to provide emergency payments and,
with about 1,300 offices nationwide, had the capability to quickly deploy
staff and equipment from other offices to address the increased workload.
Individuals affected by Hurricane Katrina also overwhelmed the state of
Louisiana's food stamp, welfare, and unemployment offices. State and local
officials we visited said they struggled to find equipment and supplies to
handle the increase and to obtain other help such as security for crowd
control. Louisiana-overwhelmed in its efforts to issue unemployment checks
to evacuees without stable addresses-rushed to implement a debit card
payment system and encountered some challenges doing so. The debit card
payment systems the states of Alabama, Louisiana, and Mississippi had in
place for income assistance and food stamps allowed them to continue
benefit payments that were uninterrupted when beneficiaries relocated. In
addition, over 2 million families received food assistance through the
U.S. Department of Agriculture's Disaster Food Stamp Program.

Effective Capabilities Development Requires Adequate Planning, Coordination,
Training, and Exercises

Capabilities are built upon the appropriate combination of people, skills,
processes, and assets. Ensuring that needed capabilities are available
requires effective planning and coordination and training and exercises in
which the capabilities are realistically tested, problems identified and
lessons learned, and subsequently addressed in partnership with other
federal, state, and local stakeholders.

  Planning and Coordination

As we identified in our March 2006 testimony, the ability of the nation to
prepare for, respond to, and recover from catastrophic disasters can be
enhanced through strong advance planning, both within and among responder
organizations. By their very nature, catastrophic disasters involve
extraordinary levels of mass casualties, damage, or disruption that likely
will immediately overwhelm state and local responders, circumstances that
make sound planning for catastrophic events all the more crucial.
Identifying, obtaining, and pre-positioning adequate quantities of key
supplies, such as food, ice, water, and blankets, and delivering those
supplies quickly when and where needed is an important component of
planning. Another example is the previously discussed planning challenges
states and localities face in preparing for and carrying out the
evacuation of transportation-disadvantaged populations, such as the
elderly or persons with disabilities, during a disaster. Our work in this
area has noted challenges in identifying these populations, determining
their needs, and providing for and coordinating their transportation. Some
emergency management officials told us they did not yet have a good
understanding of the size, location, and composition of the
transportation-disadvantaged in their communities. However, we have also
observed efforts in some locations to address the evacuation needs of the
transportation-disadvantaged by encouraging citizens to voluntarily
register with their local emergency management agency, integrating social
service providers into emergency planning, and other measures.

  Examples of Good Planning

In some cases, sound advance planning contributed to a more effective
response during Hurricane Katrina. For example:

           o  U. S. Coast Guard-The Coast Guard was able to mitigate some of
           the communication shortfalls it experienced, in part because of
           its planning assumption that "communications systems could be
           heavily damaged or destroyed" during a natural disaster. This
           assumption prompted Coast Guard officials to build into their
           contingency plans approaches that were not reliant on
           communication systems and that allowed personnel to act
           independently or with limited guidance from commanding officers.
           As a result of the contingency plan, personnel in charge of the
           assets knew their mission prior to the storm and did not need to
           communicate any further with district command to fulfill their
           operation. In addition, as planned, the Coast Guard pre-placed
           communication equipment before the storm. Members of the Coast
           Guard Auxiliary were notified prior to the hurricane's landfall
           and provided communication capabilities after the storm passed,
           which according to Coast Guard officials, was critical to
           conducting search and rescue operations.

           o  National Finance Center-Planning for continuity of operations
           enabled the National Finance Center (NFC) in New Orleans paid more
           than half a million federal workers on time while Hurricane
           Katrina was bearing down, then made subsequent payrolls-NFC's
           largest ever-without any delays. According to officials, NFC had
           gone through various diverse scenarios in disaster recovery
           planning and exercises as part of its preparedness for just such
           an event. There was a structured timeline for reviewing the
           continuity of operations plan every year, beginning with
           continuity of operations plan requirements and business impact
           analysis at the unit level. A NFC official said that key NFC staff
           members worked the weekend before landfall at the New Orleans
           facility to complete payroll processing for federal employees,
           then shut down operations and deployed to backup locations before
           the hurricane hit New Orleans. NFC backup data was trucked out of
           the New Orleans facility. When Hurricane Katrina made landfall in
           Louisiana shortly after 6 a.m. on Monday, August 29, 2005 NFC had
           already sent an advance deployment team to its backup sites in
           Philadelphia, Pennsylvania and Grand Prairie, Texas. That same
           night, the trucks arrived at an alternate processing facility
           outside Philadelphia. The backup tapes also enabled the New
           Orleans NFC staff restore many operations within 2 days of the
           devastation. Within a 50-hour period, NFC had the data center
           recovered and began catch-up processing to bring applications up
           to current state.

           o  Social Security Administration---The Social Security
           Administration had enhanced planning and pre-established
           procedures in place to provide immediate emergency payments to the
           significant number of beneficiaries who evacuated and did not
           receive their monthly checks. With these procedures in place, the
           Social Security Administration had the capability to deploy staff
           and equipment from its 1,300 offices across the nation to address
           the increased workload.

           o  Department of Defense-The White House Homeland Security
           Council's report also identified DOD's preparedness efforts for
           the 2005 hurricane season. DOD approved a standing order to
           prepare and organize for severe weather disaster operations, which
           was based on prior assistance for hurricane recovery operations.
           This order expedited the pre-positioning of senior military
           representatives known as Defense Coordinating Officers, to act as
           liaisons with other governmental organizations in the projected
           disaster area prior to an event. The order also authorized the use
           of DOD installations as logistical staging areas for FEMA. The
           military also took steps to proactively respond as Katrina
           strengthened in the Gulf of Mexico, and it published warning and
           planning orders and was positioned to respond with both National
           Guard and federal forces by the time Katrina made landfall on
           August 29, 2005.
           o  U.S. Postal Service-The Postal Service was relatively
           well-prepared for the aftermath of Hurricane Katrina. While the
           hurricane damaged some 500 post offices, the Postal Service was
           able to establish limited services just days after the disaster.
           As early as August 26, 2005, USPS was anticipating a landfall in
           the Gulf Coast and was diverting some mail from processing plants
           in that region to minimize the effects of potential disruption to
           its processing capabilities. By the time the storm passed on
           August 30, some 500 postal facilities in Alabama, Mississippi, and
           Louisiana had been damaged and were incapable of providing
           delivery service. On September 1, 2005, the Postal Service set up
           temporary centers for the pickup of checks in Mississippi,
           Louisiana, and Alabama. In New Orleans proper, two post offices
           were designated as Social Security check pickup points for a short
           period of time. Reconstituting regular mail delivery in the areas
           affected by Hurricane Katrina was a priority. For those now
           displaced from their homes, the Postal Service says that it can
           provide relatively efficient delivery service if customers submit
           a change of address form in person, by toll-free telephone, or on
           the Internet. The Postal Service now has the capability, through
           innovations in sorting technology, to intercept mail at its
           original sorting point that is addressed to an address that has
           changed, and re-route the mail to a new address. Thus, it can
           avoid the cost and delay of physically transporting mail to the
           former delivery post office for flagging and forwarding under a
           local change of address request.
           o  Internal Revenue Service-The Internal Revenue Service (IRS)
           worked in coordination with FEMA to address the human services
           needs of individuals and families. The IRS began staffing Disaster
           Assistance Centers in more than a dozen states. The IRS assigned
           nearly 5,000 employees to augment the FEMA hurricane victim
           registration effort and established its own dedicated toll-free
           disaster number and a special section of their internet web site,
           according to the Treasury Department. IRS employees were taking
           calls seven days a week over two shifts to help people with the
           process of registering with FEMA to obtain benefits, answering
           approximately 950,000 registration calls for FEMA and filling
           orders for over 291,000 Disaster Relief Kits. Through February 2,
           2006, they answered more than 100,000 calls on the special IRS
           toll-free line for affected taxpayers. In addition, the IRS issued
           filing and payment relief guidelines, launched a special toll-free
           disaster hotline, and created a Hurricane Katrina disaster link at
           www.irs.gov web site to expedite the processing of transcript and
           tax return requests.

  Examples Where Planning and Coordination Should Be Improved

           o  DHS Nationwide Plan Review: State and Local Catastrophic
           Disaster Planning-In the aftermath of Hurricane Katrina, DHS has
           responded to the need to ascertain the status of the nation's
           emergency preparedness planning, as identified both by Congress
           and the President. On September 15, 2005, the President ordered
           DHS to undertake an immediate review, in cooperation with local
           counterparts, of emergency plans in every major city in America.
           In addition, the Safe, Accountable, Flexible, Efficient
           Transportation Equity Act: A Legacy for Users required the
           Secretary of Transportation and the Secretary of Homeland Security
           to jointly review and assess federal and state evacuation plans
           for catastrophic hurricanes impacting the Gulf Coast Region.45
           Finally, in the conference report to the Department of Homeland
           Security Fiscal Year 2006 Appropriations Act, the conferees
           directed DHS to report on the status of catastrophic planning,
           including mass evacuation planning, in all 50 states and the 75
           largest urban areas.46 In response, DHS developed the Nationwide
           Plan Review in coordination with the Department of Transportation
           and support from the Department of Defense.

           The Nationwide Plan Review included two phases. In Phase 1,
           released in February 2006, all states and urban areas submitted
           self-assessments of their emergency operations plans, focusing on
           their adequacy and feasibility to manage the consequences of a
           catastrophic event.47 In Phase 2, released in June 2006, DHS
           employed peer review teams to visit states and urban areas, where
           these teams reviewed and validated the self-assessments, and
           helped determine requirements for federal planning assistance. At
           the conclusion of each visit, the peer review team completed a
           comprehensive report and submitted it to DHS.

           The June 2006, DHS Phase 2 report found that current catastrophic
           planning is unsystematic, not linked within a national planning
           system, and the status of plans and planning gives grounds for
           significant national concern. The report found a systemic problem
           of outmoded planning processes, products, and tools, which all
           contribute to inadequate catastrophic planning. DHS found that
           emergency operations rely on plans that are created in isolation,
           insufficiently detailed, and not subject to adequate review. The
           report identified 15 findings specific to state and urban area
           planning, and 24 findings specific to the federal government's
           role and efforts to support catastrophic disaster planning. DHS
           concluded that the result of these systemic planning problems
           translates to uneven performance and repeated and costly
           operational miscues, and critical response time lost to correct
           the misperceptions of federal, state, and local responders about
           their roles, responsibilities, and actions.

           DHS's findings call for a fundamental modernization of the
           nation's planning processes. According to its report, planning
           modernization must be managed as a single program with established
           funding. Further, according to DHS, the goal of the modernization
           program must be to establish a networked, collaborative national
           planning system that satisfies planners' information needs;
           provides procedures and tools to accomplish pre-incident plan
           synchronization; allows faster development or revision of existing
           plans; and provides flexible options that accommodate the diverse
           hazards and threats. However, DHS states that the next phase that
           needs to be addressed is the development of an implementation
           strategy to begin to address the 40 findings in the White House
           Homeland Security Council report in a rational way. Such an
           implementation strategy can prioritize remedial actions based on a
           risk management model that considers threats, vulnerabilities, and
           consequences.

           o  Department of Defense-Our recent report on DOD and the National
           Guard's planning for and response to Hurricane Katrina illustrates
           an example of the need for coordinated planning in advance of a
           disaster. While multiple agencies support each "Emergency Support
           Function" in the NRP, DOD does not have the primary responsibility
           for any emergency support function, as DOD's role is primarily
           that of a support agency. We found that pre-Katrina plans
           involving the military were inadequate in several ways. Neither
           the NRP nor DOD's disaster plans incorporate lessons learned from
           past catastrophes to fully delineate the military capabilities
           needed to respond to a catastrophic disaster.48 DOD is aware of
           disaster response problems described in this report and is
           beginning to take actions to address the lessons learned from
           Hurricane Katrina and to prepare for the next catastrophic event.
           DOD has been conducting its own reviews and is also examining the
           lessons and recommendations in reports from a White House review
           panel, congressional oversight committees, and other sources. We
           noted that DOD is taking some actions to address catastrophic
           disaster response problems. For example, DOD officials stated that
           it is currently updating its emergency response plan and intends
           to use a contingency plan rather than a less detailed functional
           plan to guide its military support to civil authority missions.
           DOD also has an organizational realignment underway that gives a
           single Army organization that is responsible for domestic disaster
           response and will be capable of deploying within 18 hours as joint
           task forces for catastrophes anywhere in the United States.

           o  FEMA-Enhancing planning and coordination efforts may also
           benefit other federal agencies' efforts to provide response and
           recovery services. For example, our observations of the
           Individuals and Households Program (IHP), which provides housing
           and other financial assistance to disaster victims, suggest that
           FEMA's program planning was reactive and ad hoc, with IHP
           procedures differing from disaster area to disaster area. Our work
           examining the IHP program indicated that FEMA lacked final plans,
           policies, and procedures that specifically addressed the types of
           unique challenges the agency could expect to face in catastrophic
           circumstances. In commenting on a draft of our report, FEMA
           officials said they had previously identified the need to develop
           plans to expand its disaster registration intake and applicant
           assistance process and to temporarily relocate victims to outside
           the area after a catastrophic disaster. However, they said the $20
           million to address these requirements and others that were
           requested and provided in the FY 2005 Disaster Supplemental
           appropriation were not available for commitment until days before
           Katrina made landfall. They also said that their planning efforts
           were significantly slowed by staff commitments to the 2004 and
           2005 hurricane seasons. One of the consequences of this lack of
           planning for catastrophic disasters was that FEMA's systems and
           processes for verifying applicant eligibility for IHP assistance
           were overwhelmed, resulting in payments made to thousands of
           ineligible applicants.49 FEMA officials said that these problems
           more directly reflected a failure of system capacity that could
           not be overcome by any amount of planning. Nonetheless, if FEMA
           had developed and implemented a plan for an expandable disaster
           registration intake and applicant assistance process after
           identifying the need for such a plan, systems and processes for
           verifying applicant eligibility for IHP assistance would have been
           better prepared to manage the unprecedented volume of requests and
           reduce the number of payments made to ineligible applicants.

           In addition,  FEMA did not have sufficient pre-positioned
           supplies, equipment, and services (e.g., debris removal) contracts
           in place prior to Katrina to meet the demand during the response,
           particularly for needs such as temporary housing and public
           buildings. The experience of Katrina highlighted the need for
           better logistics planning and the need for contracts to be in
           place prior to the disaster that could be activated to lean
           forward and provide surge capacity for critical supplies and
           services. For example, because FEMA had not planned for a
           catastrophic disaster such as Katrina, FEMA spent funds for
           temporary housing that were hardly used. In addition, because FEMA
           did not inform the Corps of Engineers prior to Katrina that the
           Corps would be responsible for acquiring portable classrooms, the
           Corps lacked sufficient knowledge of the market for this commodity
           to obtain the best deal for the government. In these and other
           instances, better planning could have avoided some unnecessary
           costs.

45Pub. L. No. 109-59, 119 Stat. 1144, 1934 (2005).

46H.R. Rep. No. 109-241, at 68 (2006).

47As used in the Nationwide Review Plan, the term "state" refers to any
state of the United States, the District of Columbia, the Commonwealth of
Puerto Rico, the Virgin Islands, Guam, American Samoa, the Commonwealth of
the Northern Mariana Islands, and any possession of the United States. The
term "urban areas" refers to the 55 Fiscal Year 2005 Urban Areas Security
Initiative program grantees; and the 20 major cities selected for the
Nationwide Plan Review by DHS were based on a DHS analysis of 2004
population, risk, and need.

48 GAO-06-643 .

           o  Small Business Administration-In another example, SBA needs
           enhanced strategic planning to ensure its ability to provide
           timely loans, as our ongoing work in this area indicates. As the
           primary federal lender to disaster victims SBA's disaster loan
           program provides loans to businesses, homeowners, and renters to
           rebuild and replace uninsured or underinsured property damaged by
           a disaster. However, as more fully described in our recently
           issued report, several factors affected SBA's ability to provide
           timely disaster assistance to victims of the Gulf Coast
           hurricanes, including the large volume of applications that SBA
           processed.50 For example, SBA planned the maximum user capacity
           for its new Disaster Credit Management System (DCMS) based solely
           on its experience during the 1994 Northridge earthquake-the single
           largest disaster SBA had previously faced-and other historical
           data. SBA did not consider information available from catastrophe
           risk models and disaster simulations, such as the likelihood and
           severity of damages from potential natural disasters, to help
           predict the volume of applications that might be expected from
           such events. SBA's limited planning contributed to insufficient
           DCMS user capacity, thus restricting the number of staff that
           could access DCMS and process applications in a timely manner. SBA
           also did not completely stress test DCMS before implementation and
           received the incorrect computer hardware from its contractor,
           which reduced user capacity and contributed to the system
           instability, outages, and slow response times initially
           experienced by SBA staff. As a result of these and other factors,
           SBA faced significant delays and backlogs in processing loan
           applications.

                        Going forward, SBA may be able to process disaster
                        loans more efficiently by implementing an
                        Internet-based application feature. In order to
                        provide more timely disaster assistance in the
                        future, we recommended that the Administrator of SBA
                        direct the Office of Disaster Assistance to take the
                        following four actions: (1) reassess DCMS's maximum
                        user capacity and related loan processing resource
                        needs based on such things as lessons learned from
                        the Gulf Coast hurricanes, a review of information
                        available from catastrophe risk modeling firms and
                        disaster simulations, and related cost
                        considerations; (2) conduct complete stress testing
                        to ensure that DCMS can function as planned for
                        maximum user capacity levels; (3) improve management
                        controls over assessing contractor performance
                        through inspections of all equipment purchased or
                        leased to support DCMS; and (4) expedite plans to
                        resume business processing reengineering efforts to
                        analyze the disaster loan process and identify ways
                        to more efficiently process loan applications,
                        including an evaluation of the feasibility of
                        implementing a secure Internet-based application
                        feature for home loan applicants. SBA disagreed with
                        some of our findings but generally agreed with these
                        recommendations.

49  GAO-06-403T .

50 GAO, Small Business Administration: Actions Needed to Provide More
Timely Disaster Assistance, GAO-06-860 (Washington, D.C.: July 28, 2006).

Recent GAO recommendations to SBA to provide                               
more timely disaster assistance in the future   SBA response
SBA should reassess the Disaster Credit         SBA disagreed with some of 
Management System's (DCMS) maximum user         our findings but generally 
capacity and related loan processing resource   agreed with these          
needs based on such things as lessons learned   recommendations.           
from the Gulf Coast hurricanes, a review of     
information available from catastrophe risk     
modeling firms and disaster simulations, and    
related cost considerations.                    
Conduct complete stress testing to ensure that  
DCMS can function at planned for maximum user   
capacity levels.                                
Improve management controls over assessing      
contractor performance through inspections of   
all equipment purchased or leased to support    
DCMS.                                           
Expedite plans to resume business processing    
reengineering efforts to analyze the disaster   
loan process and identify ways to more          
efficiently process loan applications including 
an evaluation of the feasibility of             
implementing a secure Internet-based            
application feature for home loan applicants.   
    For more detailed information about our recommendations, see appendix I.

In addition our preliminary analysis from an ongoing review indicates that
SBA's overall planning efforts for providing timely recovery assistance in
response to large scaled disasters appears to be insufficient and may have
contributed to the delays in providing affordable disaster assistance to
victims in the Gulf Coast Region. For example, at the time of the Gulf
Coast hurricanes, SBA lacked a comprehensive, documented plan for
providing timely disaster recovery assistance. Disaster recovery experts
have told us that such a plan would address various aspects of SBA's
response including staffing capacity, telecommunication needs and other
logistical support, as well as coordination with federal, state, and local
entities in providing appropriate disaster recovery assistance. In
addition, SBA did not have any full-time staff responsible for planning
its disaster recovery activities. Rather, SBA relied extensively on the
experience and knowledge of its field office staff to determine its
response needs and carry out SBA's role. SBA officials stated that it
recently started developing a response plan; however, it was unclear when
this plan would be completed and implemented. We plan to complete our
review of these issues and issue a report later this year.

           o  Child Welfare-Findings from our recent work and from other
           agency "after action" reports point to the need to improve current
           plans and strengthen related agreements and understandings of
           expectations between governments and other organizations that will
           be responders in the event of a future catastrophe. Our work has
           identified areas where prior to an incident, obstacles can be
           identified and agreements to address them reached between
           agencies, levels of governments, and private and nongovernmental
           organizations. Our recent work examining Louisiana's child welfare
           system's response to the disaster and education system identified
           lessons learned by the state's child welfare officials, including
           the need for state disaster plans to include evacuation
           information and instructions for social workers and their foster
           parents. In a recent national survey, child welfare officials in
           20 states and the District of Columbia reported that they had a
           written child welfare disaster plan.51 Of these, 13 states
           reported that their plan addressed identifying children under
           state care who may be dispersed after a disaster, and 14 reported
           that their plan addressed continuing services for children under
           state care who may be dispersed. Child welfare agencies could also
           benefit from standing data-sharing agreements that would speed
           efforts to locate displaced children in the event of the type of
           evacuation witnessed prior to and after Katrina's landfall.52
           Louisiana child welfare officials told us that, during the
           response to Hurricane Katrina, they had to sign a memorandum of
           understanding for sharing information with the American Red Cross,
           but by the time the memorandum was finalized and approved the
           demand had abated, and the Red Cross had closed its shelters.

           To better assist states in developing child welfare disaster
           plans, we recommended to the Secretary of Health and Human
           Services that child welfare disaster planning guidance should
           address the dispersion of children and families within and across
           state lines. This guidance should include information on (1)
           preserving child welfare records, (2) identifying children who may
           be dispersed, (3) identifying new child welfare cases and
           providing services, (4) coordinating services and sharing
           information with other states, and (5) placing children from other
           states. We also recommended that the secretary develop and provide
           training on child welfare disaster planning to all states. HHS
           responded by stating that it has taken action to update the
           guidance and provide training to states and will encourage them to
           develop and submit disaster plans for review. Finally, to ensure
           continuity of services within or across state lines for the
           children under state care, we have recommended that Congress
           should consider requiring that states develop and submit child
           welfare disaster plans for HHS review.

51We surveyed 50 states, the District of Columbia, and Puerto Rico; 20
states and the District of Columbia reported that they had a written plan,
17 states and Puerto Rico reported they did not have a written plan, and
11 states did not respond to the disaster planning questions in our
survey.

52GAO, Federal Action Needed to Ensure States Have Plans to Safeguard
Children in the Child Welfare System Displaced by Disasters. GAO-06-944
(Washington, DC.: July 28, 2006).

Recent GAO recommendations to DHHS and the                                 
Congress to safeguard children in states'      
child welfare systems                          HHS responses
DHHS should ensure that the department's child HHS has taken action to     
welfare disaster planning guidance address the update the guidance and     
dispersion of children and families within and provide training to states  
across state lines, and develop and provide    and will encourage them to  
training on child welfare disaster planning to develop and submit disaster 
all states.                                    plans for review.           
To ensure continuity of services within or     
across state lines for the children under      
state care, Congress should consider requiring 
that states develop and submit child welfare   
disaster plans for HHS review.                 
    For more detailed information about our recommendations, see appendix I.

  Training and Exercises

Clear roles and coordinated planning are necessary, but not sufficient by
themselves to ensure effective disaster management. It is important to
test the plans and participants' operational understanding of their roles
and responsibilities through robust training and exercise programs.
Training and exercising are designed to test emergency management plans
and increase the level of understanding of those roles and
responsibilities on the part of officials, contrasting catastrophic versus
non-catastrophic disasters. Involving key federal, state, and local
leaders-including elected leaders-in robust training and exercise programs
can better familiarize and prepare leaders with their roles in a
catastrophic disaster. DHS has taken the lead to establish and maintain a
comprehensive training and exercise program and standards to meet the
national preparedness goal, as required by Homeland Security Presidential
Directive 8 (HSPD-8). For example, the 15 national planning scenarios
developed by DHS and the Homeland Security Council provide the basis for
disaster exercises throughout the nation.

In our previous work on Hurricanes Andrew and Hugo,53 we identified the
need for the federal government to upgrade training and exercises for
state and local governments specifically geared towards catastrophic
disaster response. Hurricane Katrina demonstrated the potential benefits
of applying lessons learned from training exercises and experiences with
actual hurricanes, as well as the dangers of ignoring them. During our
fieldwork, we found examples of how an incomplete understanding of NRP and
NIMS roles and responsibilities could lead to misunderstandings, problems,
and delays. In Louisiana, for example, some city officials were unclear
about federal roles. In Mississippi, we were told that county and city
officials were not implementing NIMS because they did not understand its
provisions.

Our recent review of DOD's preparedness and response to Hurricane Katrina
reported that inadequate exercises prior to Hurricane Katrina created a
lack of understanding within the military and among federal, state, and
local responders as to the types of assistance and capabilities, the
timing of assistance, and the contributions that the military might
provide. We noted that DOD is likely to contribute substantial support to
state and local authorities, including search and rescue assets,
evacuation assistance, provision of supplies, damage assessment assets,
and possibly helping to ensure public safety. However, we found that few
exercises led by DHS or DOD focused on catastrophic natural disasters and
none called for a major deployment of DOD capabilities.

In the aftermath of Hurricane Katrina, we have made several
recommendations designed to build the capabilities to respond to and
recover from catastrophic disasters. To ensure that agencies are
adequately prepared to continue performing essential functions following
an emergency, we recommended to DHS that it improve the assessment and
oversight of agency continuity planning and develop guidance on telework
in such planning.54 DHS partially agreed and stated that FEMA will be
conducting assessments in conjunction with its upcoming interagency
exercise. To improve the military response to catastrophic disasters, as
previously noted, we recently called for improving military plans and
exercises and resolving response problems associated with damage
assessment, communication, search and rescue, and logistics issues.55 We
noted that DOD is taking steps to improve its future response, including
expanding its training programs to accommodate planners from other
agencies and to improve its disaster response planning and exercises. Also
as first noted in our March 8, 2006, testimony, we are recommending that
documents such as the NRP and the catastrophic incident annex be supported
and supplemented by more detailed and robust operational implementation
plans. Such operational plans should, for example, further define and
leverage any military capabilities as might be needed in a catastrophic
disaster.

53See GAO, Disaster Assistance: DOD's Support for Hurricanes Andrew and
Iniki and Typhoon Omar, GAO/NSIAD-93-180 (Washington, D.C.: June 18,
1993); and Disaster Assistance: Federal, State, and Local Responses to
Natural Disasters Need Improvement, GAO/RCED-91-43 (Washington, D.C.: Mar.
6, 1991).

Recent GAO recommendations to DHS to                                       
improve federal continuity of        
operations                           DHS responses
DHS should conduct an assessment of  FEMA will be conducting assessments   
agency continuity of operations      in conjunction with its upcoming      
plans.                               interagency exercise.                 
DHS should develop a methodology for DHS stated it had a methodology, but  
assessing agency continuity of       GAO believes it will not fully ensure 
operations plans.                    emergency preparedness.               
DHS should establish a timeline for  FEMA will coordinate with OPM to      
developing agency guidance for       develop further telework guidance.    
telework.                            
    For more detailed information about our recommendations, see appendix I.

Finally, as initially presented in our March 8, 2006, testimony, we are
recommending that DHS should provide guidance and direction for federal,
state, and local planning, training, and exercises to ensure such
activities fully support preparedness, response, and recovery
responsibilities at a jurisdictional and regional basis. This should also
include the application of lessons learned from actual catastrophes and
other disasters.

54GAO, Continuity of Operations: Selected Agencies Could Improve Planning
for Use of Alternate Facilities and Telework during Disruptions,
GAO-06-713 (Washington, D.C.: May 11, 2006).

55 GAO-06-643 .

New GAO recommendations to DHS improve federal, state, and local training  
and exercises                                                              
DHS should provide guidance and direction for federal, state, and local    
planning, training, and exercises to ensure such activities fully support  
preparedness, response, and recovery responsibilities at a jurisdictional  
and regional basis. This should also include the application of lessons    
learned from actual catastrophes and other disasters.                      
    For more detailed information about our recommendations, see appendix I.  

In addition, we observed in our earlier work on the National Preparedness
Goal that if properly planned and executed, the goal and its related
products, such as program implementation plans and requirements, may help
guide the development of realistic budget and resource plans for an
all-hazards national preparedness program.56 However, questions remain
regarding what should be expected in terms of basic capabilities for most
disasters compared to the expanded capabilities and mutual aid needed from
other jurisdictions to meet the demands of a catastrophic disaster.
Consequently, we recommend that DHS take the lead in monitoring federal
agencies' efforts to meet their responsibilities under the NRP and the
interim National Preparedness Goal, including the development, testing,
and exercising of agency operational plans to implement their
responsibilities under the NRP, NIMS, and the National Preparedness Goal.

New GAO recommendations to DHS monitor federal agencies' efforts to meet   
their responsibilities under the NRP                                       
DHS should take the lead in monitoring federal agencies' efforts to meet   
their responsibilities under the NRP and the interim National Preparedness 
Goal, including the development, testing, and exercising of agency         
operational plans to implement their responsibilities under the NRP, NIMS, 
and the National Preparedness Goal.                                        
    For more detailed information about our recommendations, see appendix I.  

DHS Reported Taking Some Actions to Improve Capabilities in Response to Findings
in Congress' and the Administration's Reviews

DHS and the administration have engaged in an effort to respond to the
White House Homeland Security Council's study of lessons learned about
capabilities from Hurricane Katrina. The White House Homeland Security
Council's report originally identified 125 recommendations to improve
future disaster preparedness, response, and recovery capabilities. As
table 3 shows, 27 recommendations that were to be implemented prior to
June 1, 2006, are focused on improving capabilities. However, DHS has not
provided information to support the actions it has reported taking to
implement these 27 recommendations, including which actions have resulted
in changes in operational readiness and capabilities.

56 GAO-05-652 .

Table 3: Implementation of White House Homeland Security Council
Recommendations for the 2006 Hurricane Season: Recommendations Related to
Regarding Capabilities

                                                         Supporting           
Recommendation related to        Primary agency(ies)  agency(ies)          
capabilities ("Critical Action"  responsible for      responsible for      
recommendations are noted)       implementation       implementation       
Critical Action Recommendation:  Department of        Department of        
Establish rapid deployable       Homeland Security    Defense, Department  
communications as well as                             of Commerce, Federal 
institute a structure for                             Communications       
consolidated federal operational                      Commission           
reporting to the Department of                        
Homeland Security to ensure                           
situational awareness                                 
Critical Action Recommendation:  Department of        Department of        
Encourage states to pre-contract Homeland Security    Justice, Office of   
with service providers for key                        Management and       
disaster relief efforts, such as                      Budget               
debris removal and the provision                      
of critical commodities.                              
Critical Action Recommendation:  Department of        All federal agencies 
Designate locations throughout   Homeland Security    
the country for receiving,                            
staging, moving, and integrating                      
federal disaster relief                               
personnel and assets to ensure                        
the most effective employment.                        
Critical Action Recommendation:  Department of        Department of        
Update and utilize the national  Homeland Security    Defense, Department  
Emergency Alert System in order                       of Commerce, Federal 
to provide the general public                         Communications       
with advanced notification of                         Commission,          
and instruction for disasters                         Department of Health 
and emergencies.                                      and Human Services   
Critical Action Recommendation:  Department of        Office of Management 
Enhance the mechanism for        Homeland Security    & Budget, Department 
providing federal funds to                            of Treasury,         
states for preparations upon                          Homeland Security    
warning of an imminent                                Council              
emergency.                                            
Establish a National Information Department of        All federal agencies 
and Knowledge Management System. Homeland Security    
Establish a National Reporting   Department of        All federal agencies 
System.                          Homeland Security    
Promote future preparedness of   Department of        All federal agencies 
the federal, state, and local    Homeland Security    
authorities based on the risk,                        
capabilities and needs structure                      
of the National Preparedness                          
Goal.                                                 
Establish standard that each     Department of        All federal agencies 
Homeland Security Region must be Homeland Security    
able to establish a                                   
self-sufficient, initial JFO                          
anywhere within the region.                           
Complete the review of National  Department of        All federal agencies 
Security and Emergency           Homeland Security    
Preparedness (NS/EP)                                  
communications policy by April                        
30, 2006.                                             
Organize an interagency group to Homeland Security    All federal agencies 
begin the development of a       Council, Office of   
national emergency               Science and          
communications strategy. An      Technology Policy    
interim strategy to be completed                      
May 31, 2006, should provide                          
sufficient guidance and                               
direction to address the                              
deficiencies identified in the                        
Hurricane Katrina response.                           
Establish and maintain a         Department of        N/A                  
deployable communications        Homeland Security    
capability to quickly gain and                        
retain situational awareness                          
when responding to catastrophic                       
incidents.                                            
Establish a Chief Logistics      Department of        N/A                  
Officer to oversee all logistics Homeland Security    
operations across multiple                            
support functions.                                    
Streamline procedures for        Department of        All federal agencies 
issuing mission assignments to   Homeland Security    
other departments and agencies.                       
These mission assignments will                        
be identified in advance of an                        
emergency so that logisticians                        
can operationalize assets and                         
provide resource support                              
rapidly. In addition, other                           
departments and agencies should                       
establish procedures for                              
promptly executing mission                            
assignments.                                          
Designate DOT as the primary     Department of        All federal agencies 
federal agency responsible for   Transportation       
developing the federal                                
government's capability to                            
conduct mass evacuations when                         
disasters overwhelm state and                         
local governments. DOT should,                        
in coordination with HHS, DOD,                        
Veterans Affairs, DHS, and the                        
American Red Cross (ARC) plan,                        
train, and conduct exercises for                      
the timely evacuation of                              
patients and transportation of                        
medical supplies and personnel.                       
Evaluate (in coordination with   Department of        Department of        
the Department of                Homeland Security    Transportation       
Transportation) all state                             
evacuation plans as well as the                       
evacuation plans of the 75                            
largest urban areas.                                  
Develop the capability to surge  Department of        All federal agencies 
federal law enforcement          Justice              
resources in the immediate                            
aftermath of a disaster.                              
DOJ and DHS should each develop, Department of        All federal agencies 
in coordination with the other,  Justice, Department  
the capability to rapidly deploy of Homeland Security 
a contingent of federal law                           
enforcement officers to prevent                       
and respond to civil disorder.                        
Develop a unified and            Department of Health All Emergency        
strengthened public health and   and Human Services   Support Function     
medical command for federal                           (ESF)-8 Agencies     
disaster response.                                    
Establish a rapidly-deployable   Department of        All federal agencies 
public affairs teams, able to    Homeland Security    
operate self-sufficiently, in                         
austere conditions. These teams                       
should be established across all                      
federal departments and agencies                      
with key Homeland Security                            
responsibilities.                                     
Establish an integrated public   Department of        All federal agencies 
alert and warning system in      Homeland Security    
coordination with all relevant                        
departments and agencies.                             
Review, revise, and finalize the Department of        All federal agencies 
Interim NIPP within 90 days.     Homeland Security    
Form an Impact Assessment        National Economic    Department of        
Working Group to provide an      Council              Homeland Security,   
overall economic impact                               Treasury, Commerce,  
assessment of major disasters,                        Energy ,Labor,       
including the Departments of                          President's Council  
Homeland Security, Treasury,                          of Economic Advisors 
Commerce, Energy (Energy                              
Information Administration), and                      
Labor as well as the President's                      
Council of Economic Advisors.                         
Establish an office with         Department of        N/A                  
responsibility for integrating   Homeland Security    
non-governmental and other                            
volunteer resources into                              
federal, state, and local                             
emergency response plans and                          
mutual aid agreements. Further,                       
DHS should establish a distinct                       
organizational element to assist                      
faith-based organizations.                            
Conduct state and local          Department of        All federal agencies 
officials training and           Homeland Security    
exercises.                                            
Establish a National Exercise    Department of        All federal agencies 
and Evaluation Program (NEEP).   Homeland Security    
Develop the capability to        Department of        N/A                  
rapidly activate a JTF-State for Defense              
contingencies.                                        
Provide training, technical, and Department of        All federal agencies 
other assistance in support of   Homeland Security    
other departments' and agencies'                      
homeland security professional                        
development programs.                                 

Source: GAO analysis of DHS and Homeland Security Council data.

Note: N/A = not applicable.

Additional Work Is Needed to Address FEMA's Human Resource Challenges

The various reports and our own work on FEMA's performance before, during,
and after Hurricane Katrina suggest that FEMA's human resources were
insufficient to meet the challenges posed by the unprecedented degree of
damage and the resulting number of hurricane victims. The Senate's report
concluded that FEMA did not have the resources necessary to fulfill the
mission and respond effectively in a catastrophic event and recommended
that DHS develop the national capabilities-especially surge capacity-it
needs to respond to catastrophic disasters, ensuring it has sufficient
full-time staff and the support, such as contracting personnel and
adequately trained and sufficiently staffed reserve corps, to ramp up
capabilities, as needed. FEMA's initial response assessment concluded that
the agency needed to lead an audit of current staffing capability and
workforce demands for staff in a severe or catastrophic event and
determine the number of personnel available to serve in each position or
unit for such an event.

As stated during the March 8, 2006 hearing, strategic national leadership
is provided by the Secretary of Homeland Security, who is to act as a
focal point for natural and manmade crises and emergency planning under
the provisions of the Homeland Security Act. We stated our belief that
other strategic national leadership positions such as the Undersecretary
for Federal Emergency Management (who is also the Director of FEMA) and
other key leadership and managerial positions within FEMA and DHS could
benefit from having statutory, professional qualifications requirements.
In addition, Congress could consider a term appointment for the
Undersecretary for Federal Emergency Management and selected other
positions within DHS.

To improve the staffing level of its permanent full-time employees, on
February 22, 2006, FEMA announced a hiring initiative to fill identified
vacancies and attain a 95 percent staffing level in 95 days. The
identified vacancies are based on the positions FEMA had already allocated
but not staffed; however, the current allocation of positions has not been
validated in a strategic workforce planning process. This staffing effort
was to be completed before the hurricane season that began on June 1.
However, the hiring initiative did not meet this target. Although FEMA was
able to increase its staffing level from 76.5 percent to 81.6 percent
between February 22 and May 29, the agency did not reach a staffing level
of 95 percent. In June, a FEMA Human Resources official told us that while
Human Resources was working toward reaching the 95 percent staffing goal
in August, the agency has not established a "hard" deadline because of the
priority FEMA gives to life-saving and life-sustaining operations in
emergencies that could significantly slow or suspend other operations.
Although not part of the 95-percent staffing effort, a related effort to
fill Senior Executive Service vacancies has not made similar progress,
decreasing from 74 percent to 61 percent between February 22 and May 29.
According to FEMA officials, they expected that the time required to fill
Senior Executive Service positions would be greater than the time required
to fill other positions. In addition, the number of FEMA Senior Executive
Service positions has increased since February 22, thus FEMA's level of
Senior Executive Service staffing on May 29 was less than at the beginning
of the period. Finally, as of May 29, FEMA had six Senior Executive
Service positions that, although not vacant, had incumbents who were in an
"acting" capacity.

Building Capabilities for Catastrophic Disasters Calls for a Risk Management
Approach

In earlier work that included an examination of the draft National
Preparedness Goal, we observed that if properly planned and executed, the
goal and its related products, such as program implementation plans and
requirements, may help guide the development of realistic budget and
resource plans for an all-hazards national preparedness program. However,
questions remain regarding what should be expected in terms of basic
capabilities for most disasters compared to the expanded capabilities and
mutual aid needed from other jurisdictions to meet the demands of a
catastrophic disaster.57

Risk management can be central to assessing needs and resources in the
event of future catastrophic disasters. A decision-making process using
risk-management principles can guide the development of federal
capabilities and the expertise that can be used to respond effectively to
catastrophic disasters. The goal of risk management is to integrate
systematic concern for risk into the normal cycle of agency decision
making and implementation. In the aftermath of Hurricane Katrina, we
identified the need for a risk management decision-making approach to
develop the nation's capabilities and expertise to respond to a
catastrophic disaster. Given the likely costs, Congress may wish to
consider the use of a risk-management framework as it carries out its
oversight and legislative responsibilities with regard to national
preparedness and the recovery.

57 GAO, Homeland Security: DHS's Efforts to Enhance First Responders'
All-Hazards Capabilities Continue to Evolve, GAO-05-652 (Washington, D.C.:
July 11, 2005).

Our risk management framework calls for risk assessment based on three
components of risk-threat, vulnerability, and criticality (i.e., the
severity of the consequences of an incident). Using the information
gathered through risk assessment, agencies can then: (1) assess the
likelihood that an adverse event will occur whether caused by nature or
man; (2) identify and select among alternatives to reduce the
vulnerability to such an event; and (3) take actions that might reduce the
consequences of one or more potential adverse events should they occur.
This is a continuous process and should consider all hazards. Our risk
management framework calls for links between risk-mitigation strategies,
strategic goals, and plans and budgets. The framework also calls for an
assessment of the value and risks of various courses of action as a tool
for setting priorities and allocating resources, and the use of
performance measures to assess outcomes and adjust future actions as
needed.

Building and sustaining needed capabilities should be based on a risk
assessment that would identify the vulnerabilities of communities or
regions to potential disasters of various magnitudes and causes and how
they should be addressed within available resources and with contingency
planning. Periodic assessments of all hazards should determine if plans
remain viable, actual capabilities match planned capabilities, and the
contingency plans are appropriate. Because different states and areas face
different risks, not every state or area should be expected to have the
same capability to prepare for a catastrophic disaster. In our previous
work examining the draft National Preparedness Goal, we observed that
DHS's assessment and reporting implementation plan, intended to accurately
identify the status of capabilities at the state, regional, and local
levels, is vital for establishing a baseline and providing an ongoing
feedback loop upon which preparedness decisions at multiple levels of
government can be based. Assessment of catastrophic disaster planning and
capability needs will be a critical piece. As a result, we recommend that
DHS use an all-hazards, risk management approach in deciding whether and
how to invest federal resources in specific capabilities for a
catastrophic disaster.

New GAO recommendation to DHS to use a risk management approach            
Given that resources are finite, DHS should use a risk management approach 
in deciding whether and how to invest in specific capabilities for a       
catastrophic disaster.                                                     
    For more detailed information about our recommendations, see appendix I.  

Balance Needed between Quick Provision of Assistance and Ensuring Accountability
                   to Protect against Waste, Fraud, and Abuse

Effective controls and accountability mechanisms for the use of resources
during a catastrophic disaster are essential to ensure that resources are
used appropriately, but there is a tension between normal controls and
accountability procedures and the need to deliver assistance
expeditiously. As we stated in February 2006, the inspectors general of
the various federal departments have been conducting much of the detailed
Hurricane Katrina-related work on fraud, waste, and abuse in individual
federal programs.58 In the wake of Hurricane Katrina, contracts were let
quickly with little competition, funds were spent for temporary housing
that was never used, and hundreds of millions of dollars might have been
provided to ineligible persons for cash assistance because of an inability
to verify their social security numbers or other information. Our work,
and that of the DHS Inspector General and others across the audit
community, have identified a number of problems that have resulted in
inadequate accountability for the use of resources during and after
Hurricane Katrina, including (1) contracting problems; (2) accounting for
and managing international assistance that was offered; (3) tracking and
managing food, water, and ice deliveries; and (4) screening fraudulent
applications for assistance. These problems might have been avoided if
there had been better planning for delivering assistance during
catastrophic disasters.

58GAO, Statement by Comptroller General David M. Walker on GAO's
Preliminary Observations Regarding Preparedness and Response to Hurricanes
Katrina and Rita, GAO-06-365R . (Washington: D.C.: Feb. 1, 2006).

Catastrophic Disaster Controls and Accountability Mechanisms Should Be Flexible
to Address the Urgent Need for Delivery of Assistance

Ensuring accountability during a catastrophic disaster requires the
appropriate people, processes, and technology to, among other things,
qualify benefit applicants; report and account for contracts awarded (in
advance of or after the event) for such things as debris removal,
temporary shelter, feeding, and medical care for disaster victims; and
documenting reimbursable expenses, such as first responder overtime. Of
necessity, initial response efforts focus on the immediate, urgent tasks
of search and rescue and services such as medical care and food and
shelter for those displaced by the disaster. In any major disaster there
is the difficult task of putting in place controls and accountability
mechanisms that reduce the potential for waste, fraud, and abuse but are
flexible enough to provide assistance and resources quickly.

To date, Congress has appropriated approximately $88 billion of federal
support through emergency supplemental appropriations to federal agencies
for hurricane disaster relief and recovery efforts related to the 2005
hurricanes. 59 For Stafford Act activities, Congress makes appropriations
to the Disaster Relief Fund, which FEMA administers. The Stafford Act, the
principal federal disaster assistance statute, authorizes three general
types of major disaster assistance: (1) public assistance grants to state
and local governments and certain private nonprofit organizations, (2)
hazard mitigation grant programs, and (3) individual assistance programs.
For example, in the individual assistance area, FEMA may provide direct
assistance (temporary housing units) and financial assistance (grant
funding for temporary housing and other disaster-related needs) to
disaster victims through IHP. FEMA had provided about $5.6 billon in IHP
benefits as of April 2006.

As we stated in our March 8, 2006, testimony, catastrophic disasters not
only require a different magnitude of capabilities and resources for
effective response, but they may also require more flexible policies and
operating procedures. In a catastrophe, streamlining, simplifying, and
expediting decision making should quickly replace "business as usual" and
the unquestioned following of long-standing policies and operating
procedures used in normal situations for providing relief to disaster
victims. When there is a catastrophic disaster, temporarily suspending
certain rules and regulations may be necessary in order to expedite relief
and recovery of the affected area, even if such a suspension requires
legislation. The key is to recognize when flexibility is needed to meet
response and recovery needs in a catastrophic disaster. Across our work we
have discovered many examples where quick action could not occur as
agencies followed procedures that required extensive, time-consuming
processes, delaying the delivery of vital supplies and other assistance.
In other cases, urgent need was used to bypass standard procedures without
better outcomes. Processes and controls must be sufficient to provide the
documentation needed for expense reimbursement and reasonable assurance
that resources have been used legally and for the purposes intended.

59Four emergency supplemental appropriations acts account for the
approximately $88 billion in hurricane relief. See Emergency Supplemental
Appropriations Act to Meet Immediate Needs Arising From the Consequences
of Hurricane Katrina, 2005, Pub. L. No. 109-61, 119 Stat. 1988 (2005);
Second Emergency Supplemental Appropriations Act to Meet Immediate Needs
Arising From the Consequences of Hurricane Katrina, 2005, Pub. L. No.
109-62, 119 Stat. 1990 (2005); Emergency Supplemental Appropriations to
Address Hurricanes in the Gulf of Mexico, Pub. L. No. 109-148, div. B,
title I, 119 Stat. 2680, 2745 (2005); and Further Hurricane Disaster
Relief and Recovery, Pub. L. No. 109-234, title II, 120 Stat. 418, 443
(2006).

As we saw in the aftermath of Hurricane Katrina, the lack of internal
controls and other accountability mechanisms established prior to the
disaster can result in delay, uncertainty, and wasted or misdirected
resources. The aftermath of a catastrophic disaster is not the time to
determine what rules and procedures to suspend or streamline. It is
important that essential accountability mechanisms be designed and ready
to implement prior to the event, just as an incident management structure
should be understood and ready to implement prior to an event.
Decentralization of responsibilities enhances the challenge of assuring
that controls and accountability mechanisms are being followed.

Hurricane Katrina Highlighted Several Contracting Deficiencies

The government's response to Hurricanes Katrina and Rita depended heavily
on contractors to deliver ice, water, and food supplies; patch rooftops;
and provide housing to displaced residents and temporary facilities to
local government agencies. Audits by the inspectors general at several
agencies, along with the major Hurricane Katrina "after action" reports,
identified deficiencies in the award and execution of many of the
individual contracts. From a broader perspective, our past work has shown
that, to ensure successful acquisition outcomes in any environment,
certain critical success factors must be in place: sound acquisition
planning, good business arrangements, and effective contract monitoring
and oversight. To do so, decision makers and acquisition personnel need
sufficient knowledge and clearly defined and communicated roles and
responsibilities. We identified deficiencies under each of the critical
success factors.

  Acquisition planning

Our work on contracting issues following Hurricane Katrina indicates that
some key federal agencies involved in responding to the disaster did not
have adequate acquisition plans for carrying out their assigned
responsibilities. For example, while contracts for some items were in
place prior to the storm, FEMA did not adequately anticipate needs for
such services as providing temporary housing and public buildings. Better
planning for requirements could have avoided some costs, such as the $3
million FEMA spent for 4,000 base camp beds that were never used. Another
example was the government's approach to acquiring refrigerated truck
services. During the 2005 hurricane season, the U. S. Army Corps of
Engineers (Corps), the Department of Transportation, and FEMA had
contracts with three separate contractors for refrigerated truck
services.60 We did not find a coordinated plan for obtaining these
services. By not taking a coordinated approach, the agencies may have
missed opportunities to make the most cost-effective use of their
contracts. For example, the government obtained selected refrigerated
truck services using an existing contract with Department of
Transportation at an average price over 60 percent higher than the price
FEMA paid for similar services.

  Business arrangements

Having good business arrangements requires that agencies have sufficient
knowledge about the goods and services available in the market to satisfy
their requirements, as well as the ability to translate that knowledge
into sound business decisions in using their contracts. We found instances
where insufficient knowledge of the market or unsound ordering practices
led to excessive or wasteful expenditures.

In one case, FEMA tasked the Corps with acquiring temporary classrooms for
Mississippi within a very short time frame. To meet the requirement, the
Corps placed a non-competitive order for the classrooms under an existing
agreement for portable buildings. Because the Corps had not been formally
assigned this task prior to Katrina's landfall, contracting officials
lacked sufficient knowledge of the industry and information about
suppliers, inventories, and prices that would have been useful in
negotiating a good deal.61 The business arrangement the Corps used
involved layers of subcontractors: the Corps purchased 45 portable
buildings from a contractor, who in turn purchased the 45 buildings from a
distributor, who in turn purchased them from another distributor, who had
purchased the 45 buildings from the manufacturer. Each subcontractor added
an additional fee, resulting in the Corps agreeing to a price that was 63
percent higher than the manufacturer's price.

60One contractor provided ice production and transport services, another
provided cold storage and transport services, and a third contractor
provided a variety of transportation services, including refrigerated
trucks.

61GAO, Hurricane Katrina: Army Corps of Engineers Contract for Mississippi
Classrooms, GAO-06-454 (Washington D.C.: May 1, 2006).

Another example involved the process for ordering and delivering ice.
According to Corps officials, FEMA ordered at least double the amount of
ice required, resulting in an oversupply of ice and a lack of distribution
sites available to handle the volume ordered. One FEMA official working at
the local level told us that to ensure that he would receive an adequate
amount of ice for first few days, he doubled his initial orders. He said
that he kept ordering more ice because headquarters did not provide timely
notification of when his shipments would arrive. At the end of hurricane
season 2005, FEMA had over 2,000 truckloads of excess ice, which costs the
government over $500,000 per month for storage and additional
transportation costs. The Senate report on Katrina noted that when
Hurricane Katrina hit, and FEMA realized the scope of the temporary
housing needs, the agency began buying all of the travel trailers it could
find. Unfortunately, FEMA purchased approximately $900 million worth of
manufactured homes and modular homes that could not be used because FEMA's
own regulations do not allow for these types of homes to be placed in
flood plains. Further, some of the homes purchased did not fit FEMA's size
standards. However, FEMA seemingly had no plans for how the homes would be
used when the purchases were made.

  Contract Monitoring and Oversight

Effective monitoring-to ensure that goods and services are delivered in
accordance with the agreed upon schedule, cost, quality, and quantity
provisions in the contract-relies on having sufficient numbers of trained
and properly-deployed personnel to oversee contractor performance. Our
work indicated that the number of monitoring staff available was not
always sufficient, nor were they effectively deployed to provide
sufficient oversight. For example, on FEMA's contracts for installing
temporary housing in four states, only 17 of the 27 technical monitors
necessary to oversee contractor performance had been assigned at the time
of our review. In another case, Corps officials told us that progress in
the temporary roof program was slowed due to the lack of sufficient
monitors.

Deployment practices did not always provide for appropriate notification
of responsibilities or overlap of rotating contracting personnel, thus
making knowledge transfer and continuity of contract management operations
difficult. For example, for four of the contracts we reviewed, officials
were either unaware or not notified by FEMA of their oversight
responsibilities. The lack of overlap between oversight personnel for a
large temporary housing contract left the most recent contract
administrator with no knowledge or documentation of who had authorized the
contractor to perform certain activities or why the activities were being
performed.

  Practices to Help Ensure Successful Acquisition Outcomes

We identified a number of emergency response practices in the public and
private sectors that provide insight into how the federal government can
better manage its disaster-related procurements. These practices include

           o  developing knowledge of contractor capabilities and prices by
           identifying available commodities and services and establishing
           vendor relationships before they are needed,

           o  establishing a scalable operations plan to adjust the level of
           capacity required to effectively respond to the need,

           o  formally assigning and communicating disaster-related
           responsibilities, with joint training for government and
           contractor personnel, and

           o  providing sufficient numbers of field-level contracting staff
           with the authority needed to meet mission requirements.

We found a positive example of acquisition practices used during the
response to Katrina in our recent review of the Coast Guard's response and
recovery missions.62 Under the NRP, the Coast Guard is the co-lead agency
along with the Environmental Protection Agency for Emergency Support
Function 10: Oil and Hazardous Materials Response along coastal areas.
Prior to Hurricane Katrina, the Coast Guard had basic ordering agreements
with fixed prices and other pre-established terms and conditions with
private companies to facilitate a rapid response. These agreements were be
used to respond to oil spills, for acquiring the use of equipment for
vessel salvage and for the use of helicopters. According to Coast Guard
officials, they have used basic ordering agreements for this particular
mission since the early 1990s, and have extensive knowledge of the market
for these particular goods and services. Although we have not conducted a
thorough evaluation of the Coast Guard's Marine Environmental Protection
clean-up efforts, these agreements contributed to the successful cost
control of the marine environmental pollution response after Hurricane
Katrina, according to Coast Guard officials.

62 GAO, Coast Guard: Observations on the Preparation, Response, and
Recovery Missions Related to Hurricane Katrina, GAO-06-903 (Washington
D.C.: July 31, 2006).

To help ensure successful acquisition outcomes, we recommend that DHS
provide guidance on advance procurement practices and procedures for those
federal agencies with roles and responsibilities under the NRP, so that
these agencies can better manage disaster-related procurements. These
practices should be in advance of disasters, ongoing and continuous, and
include (1) developing knowledge of contractor capabilities, and available
commodities, services, and prices, as well as developing pre-established
vendor relationships, on a competitive basis whenever feasible; (2)
establishing scalable operations plans to adjust the level of capacity
needed to respond; (3) formally assigning and communicating
disaster-related responsibilities and, where feasible, incorporating
necessary training; and (4) providing sufficient numbers of field-level
contracting staff to meet mission requirements. DHS should also establish
an assessment process to monitor agencies' continuous planning efforts for
their disaster-related procurement needs and the maintenance of
capabilities.

New GAO recommendations to DHS improve advanced procurement practices and  
procedures                                                                 
DHS should provide guidance on advance procurement practices and           
procedures for those federal agencies with roles and responsibilities      
under the NRP, so that these agencies can better manage disaster-related   
procurements. These practices should be in advance of disasters, ongoing   
and continuous, and include (1) developing knowledge of contractor         
capabilities, and available commodities, services and prices as well as    
developing pre-established vendor relationships, on a competitive basis    
whenever feasible; (2) establishing scalable operations plans to adjust    
the level of capacity needed to respond; (3) formally assigning and        
communicating disaster-related responsibilities and, where feasible,       
incorporating necessary training; and (4) providing sufficient numbers of  
field-level contracting staff to meet mission requirements. DHS should     
also establish an assessment process to monitor agencies' continuous       
planning efforts for their disaster related procurement needs and the      
maintenance of capabilities.                                               
    For more detailed information about our recommendations, see appendix I.  

Lack of Controls Limited Accountability in the Receipt and Distribution of
International Assistance

Federal agencies involved in managing international assistance were not
prepared to coordinate, receive, distribute, or account for the
assistance. The NRP establishes the Department of State as the coordinator
of all offers of international assistance. As part of its Stafford Act
responsibilities, FEMA has authority to accept the assistance and
coordinate its distribution.63 Agency officials involved in the cash and
in-kind assistance during Hurricane Katrina told us the agencies were not
prepared to accept international assistance for use in the United States,
because the U.S. government had not received such substantial amounts of
international disaster assistance before. Therefore, they told us that
they developed ad hoc processes to accept, receive, and distribute the
cash and in-kind assistance. Understandably, not all of these ad hoc
processes contained controls to support full accountability. For example,
we recently reported that no agency tracked and confirmed that the
assistance arrived at its destinations.64 Also, we found that lack of
procedures, inadequate information up front about the donations, and
insufficient coordination resulted in the U.S. government agreeing to
receive food and medical items that were unsuitable for use in the United
States and entailed storage costs of about $80,000. DOD's lack of internal
guidance regarding the State Department's coordinating process resulted in
some foreign military donations that arrived without State Department,
FEMA, or DOD oversight.

In the aftermath of Katrina, we recommended that DHS and DOD, in
consultation with the Department of State, establish within the NRP-or
other appropriate plans-clearly delineated policies and procedures for the
acceptance, receipt, and distribution of international assistance to
improve the policies, procedures, planning, and oversight of international
cash and in-kind donations to the U.S. government in response to
disasters. DOD and DHS generally agreed with our recommendations. DHS
noted that, in some cases, actions were already underway to address the
recommendations.

6342 U.S.C. S: 5201(b).

64GAO, Hurricane Katrina: Comprehensive Policies and Procedures Are Needed
to Ensure Appropriate Use of and Accountability for International
Assistance, GAO-06-460 (Washington D.C.: Apr. 6, 2006).

Recent GAO recommendations to DHS and DOD                                  
to improve accountability for international 
assistance                                  DOD and DHS responses
DHS and DOD, in consultation with the       DOD and DHS generally agreed   
Department of State, should establish       with our recommendations. DHS  
within the NRP-or other appropriate         noted that, in some cases,     
plans-clearly delineated policies and       actions were already underway. 
procedures for the acceptance, receipt, and 
distribution of international assistance.   
    For more detailed information about our recommendations, see appendix I.

Control Weaknesses in Individual Assistance Payments Resulted in Fraud and Abuse

When responding to the needs of the victims of a catastrophic disaster,
FEMA must balance controls and accountability mechanisms with the
immediate need to deliver resources and assistance in an environment where
the agency's initial response efforts must focus on life-saving and
life-sustaining tasks. Nonetheless, our work has identified flaws in the
programs designed to assist disaster victims, which would leave the
federal government vulnerable to fraud and abuse of individual assistance
payments.

As mentioned earlier, FEMA provides direct assistance-such as temporary
housing units-and financial assistance-such as grant funding for temporary
housing and other disaster-related expenses-to disaster victims through
IHP. Under IHP, FEMA may provide disaster assistance to individuals and
households who have uninsured (or underinsured) needs that cannot be met
through other means. IHP assistance is limited to 18 months.65 The maximum
amount of financial assistance available is adjusted annually for
inflation and was capped at $27,200 in 2006. IHP provides assistance to
cover certain expenses not covered by insurance or which individuals or
households cannot cover with their own resources. Because IHP benefits are
statutorily capped, the program may not cover all losses to damaged
property or restore such property to its condition before the disaster.66
To receive assistance, applicants must qualify for benefits through a
process implemented primarily by FEMA contractors and temporary disaster
employees in a network of permanent and temporary field offices. The
benefits provided to disaster victims of hurricanes in 2005 far surpassed
the number of registrants, beneficiaries, and the dollar value amount of
benefits provided under the program for named hurricane disasters in 2003
and 2004 combined.

65FEMA may extend this 18-month limit if it determines that, due to
extraordinary circumstances, an extension would be in the public interest.
44 C.F.R. S: 206.110(e).

66The maximum of IHP assistance is statutorily capped at $25,000, adjusted
annually to reflect changes in the Consumer Price Index. 42 U.S.C S:
5174(h). In 2005, the maximum was $26,200.

Under the IHP, disaster victims in declared counties must first register
and apply for assistance with FEMA, by phone, in person at a disaster
recovery center, or over the Internet. FEMA does not provide monetary
assistance to any individual without first receiving an application from
and taking steps to validate the eligibility of that individual based on
the application. For some IHP benefits, applicants above a certain income
threshold must first apply to the SBA for disaster loan assistance.67

Many of the challenges FEMA faced after Hurricane Katrina stemmed from the
magnitude of the disaster, including the number of victims who were
displaced from their homes, and related issues in planning, trained staff,
and limitations for implementation of the program. As we have reported,
FEMA's processes for validating eligibility in the wake of Hurricane
Katrina were partially successful. Our work, however, has identified
significant flaws in the process for disaster victim applications that
leave the federal government vulnerable to fraud and abuse of individual
assistance payments.68

We estimate that through February 2006, FEMA made about 16 percent, or $1
billion, in improper and potentially fraudulent payments to applicants who
used invalid information to apply for disaster assistance. Based on our
statistical sample, we are 95-percent confident that the range of improper
and potentially fraudulent payments is from $600 million to $1.4 billion.
In our assessment of whether a payment was improper and potentially
fraudulent, we did not test for other evidence of impropriety or potential
fraud, such as insurance fraud and bogus damage claims. This means our
review potentially understates the magnitude of improper payments made.
Examples of fraud and abuse include payments to applicants who used post
office boxes, United Parcel Service stores, and cemeteries as their
damaged property addresses. In one case, FEMA paid nearly $6,000 to our
applicant who submitted a vacant lot as a damaged address.69

67Loans from the Small Business Administration are considered to be the
primary means of disaster assistance for disaster victims who have the
financial ability to repay such loans.

68GAO, Expedited Assistance for Victims of Hurricanes Katrina and Rita:
FEMA's Control Weaknesses Exposed the Government to Significant Fraud and
Abuse, GAO-06-403T (Washington, D.C.: Feb. 13, 2006).

For Internet applications, limited automated controls were in place to
verify an applicant's identity. However, we found no independent
verification of the identity of applicants who applied for disaster
assistance over the telephone. To demonstrate the vulnerability inherent
in the call-in applications, we used falsified identities, bogus
addresses, and fabricated disaster stories to register for IHP and found
that we were able to obtain $2,000 expedited assistance checks from FEMA
through these means.70 As we previously testified, FEMA continued to
provide our undercover operations with additional disaster-related
assistance payments even after FEMA received indications from various
sources that our applications may have been bogus.71 Other control
weaknesses included the lack of any validation of damaged property
addresses for both Internet and telephone registrations. Our work in this
area revealed that thousands of applicants misused social security
numbers-i.e., used social security numbers that were never issued or
belonged to deceased or other individuals. Our case study investigations
of several hundred applications also revealed the use of bogus damaged
property addresses. For example, our visits to over 200 of the case study
damaged properties in Texas and Louisiana showed that at least 80 of these
properties were bogus-including vacant lots and nonexistent apartments. We
found that FEMA also made duplicate expedited assistance payments to about
5,000 of the nearly 11,000 debit card recipients-once through the
distribution of debit cards and again by check or electronic funds
transfer. We found that although debit cards were used predominantly to
obtain cash, food, clothing, and personal necessities, a small number were
used for adult entertainment, bail bond services, and weapons purchase,
which do not appear to be items or services that are essential to satisfy
disaster-related needs.

69GAO, Hurricanes Katrina and Rita: Improper and Potentially Fraudulent
Individual Assistance Payments Estimated to Be between $600 Million and
$1.4 Billion, GAO-06-844T (Washington, D.C.: June 14, 2006).

70Expedited Assistance-a component of the IHP program during Hurricanes
Katrina and Rita-took the form of $2,000 payments to disaster victims to
help with the immediate, emergency needs for food, shelter, clothing, and
personal necessities.

71  GAO-06-844T.

To reduce waste, fraud and abuse in expedited assistance for disaster
victims, we have recommended that the Secretary of Homeland Security
direct the Undersecretary for Federal Emergency Management to take six
actions to address the weaknesses we identified in the administration of
IHP: (1) establish an identity verification process for IHP registrants
applying via both the Internet and telephone; (2) develop procedures to
improve the existing review process of duplicate registrations containing
the exact same social security number (SSN); (3) establish an address
verification process for IHP registrants applying via both the Internet
and telephone; (4) explore entering into an agreement with other agencies
to periodically authenticate information contained in IHP registrations;
(5) establish procedures to collect duplicate expedited assistance
payments or to offset these amounts against future payments; and (6)
ensure that any future distribution of IHP debit cards includes
instructions on their proper use.72

DHS and FEMA concurred fully with four of our six recommendations, and
partially concurred with the remaining two recommendations. FEMA and DHS
stated that they have already taken actions to address some of these
recommendations. These actions include instituting an Internet application
process that will prevent all duplicate applications from the Internet,
and conducting data sharing tests with the Social Security Administration.
In addition, DHS and FEMA stated that, starting in June 2006, all
registration addresses (including those provided through phone-in
applications) will be subjected to an online verification during the
application process. While these are steps in the right direction, we will
follow up on whether the actions taken fully address our recommendations.
Going forward it will be important for FEMA to establish effective
controls to prevent fraudulent and improper payments before they occur,
because fraud prevention is a far more effective control than detecting
improper and potentially fraudulent payments after they are made. Our
experience with organizations that rely on a process that attempts to
detect improper and potentially fraudulent payments after they are made is
that the organization recovers only a fraction of the payments that should
not have been made.

72 GAO, Expedited Assistance for Victims of Hurricanes Katrina and Rita:
FEMA's Control Weaknesses Exposed the Government to Significant Fraud and
Abuse, GAO-06-655 (Washington, D.C.: June 16, 2006).

Recent GAO recommendations                                                 
to DHS to reduce waste      
fraud and abuse in the      
Individuals and Households  
Program                     DHS's responses
Establish an identity       FEMA and DHS stated that they have already     
verification process for    taken actions to address some of these         
IHP registrants applying    recommendations, including instituting an      
via both the Internet and   Internet application process that will prevent 
telephone.                  all duplicate registrations from the Internet, 
Develop procedures to       and conducting data sharing tests with the     
improve the existing review Social Security Administration. In addition,   
process of duplicate        DHS and FEMA stated that, starting in June     
registrations containing    2006, all registration addresses (including    
the exact same SSN.         those provided through phone-in applications)  
Establish an address        will be subjected to an online verification    
verification process for    during the registration process. While these   
IHP registrants applying    are steps in the right direction, we will      
via both the Internet and   follow up on whether the actions taken fully   
telephone.                  address our recommendations.                   
Explore entering into an    
agreement with other        
agencies to periodically    
authenticate information    
contained in IHP            
registrations.              
Establish procedures to     
collect duplicate expedited 
assistance payments or to   
offset these amounts        
against future payments.    
Ensure that any future      
distribution of IHP debit   
cards includes instructions 
on their proper use.        
    For more detailed information about our recommendations, see appendix I.

DHS has also reported taking a number of other actions and initiatives
designed to improve timeliness and accountability in providing goods and
services to the affected areas and their victims. However, because DHS did
not provide us documentation to verify these actions and initiatives, we
could not determine their status, including the extent to which they are
operational. According to DHS, their current efforts are designed to
enhance the debris removal guidance, processes and policies to, in part,
ensure consistent cost-sharing for federal contracting (through the Corps)
and local government contracting. FEMA has also announced a number of
customer service improvement efforts so federal recovery programs will
have the capacity to handle a catastrophic incident. These include (1)
doubling FEMA's registration capacity to 200,000 per day; (2) instituting
a pilot project for deployable Mobile Registration Intake Centers; (3)
enhancing identity verification during registration; (4) increasing the
daily home inspection capacity of FEMA contracted firms from 7,000 per day
to 20,000; and (5) updating its policies to improve and quicken
determination of applicant eligibility for FEMA's IHP program along with
determining eligibility for any expedited assistance available under the
program.

Long-Term Recovery and Rebuilding Efforts Raise Issues for Congress to Consider

The federal government will be a major partner in the longer-term
rebuilding of the Gulf Coast because of the widespread damage and economic
impact. Rebuilding raises issues concerning the need for consensus on what
rebuilding should be done, where and based on what standards, who will pay
for what, and what oversight is needed to ensure federal funds are spent
for their intended purposes. In addition, federal programs will face
financial difficulties in responding to the long-term needs, and there is
uncertainty concerning the impact of catastrophic disasters on the
availability and affordability of insurance. Among the issues that will
require federal attention include (1) assessing the environmental hazards
created by the storms; (2) rebuilding and strengthening the levees; (3)
providing assistance to school districts that have enrolled large numbers
of evacuee children; (4) continuing to provide assistance for temporary
housing, and (5) assuring the financial soundness of the National Flood
Insurance Program. Finally, our March 2006 testimony identified guidelines
that may enhance federal financial assistance's performance in the
restoration of the Gulf Coast.

Long-Term Recovery Is a Shared Responsibility and a Number of Federal Agencies
Will Play a Role in Addressing Multiple Recovery-Related Issues

State and local officials will have the lead on determining the future
needs of the Gulf Coast. However, a number of federal agencies have
responsibilities related to the long-term recovery. The recovery should be
guided by careful planning that balances the need for speedy economic
recovery with actions that reduce the impact of future storms, such as
elevating structures located in areas at highest risk of damage from
future flooding. In Louisiana and Mississippi, several efforts are
underway to implement long-term rebuilding strategies. The actions of
state, local, and federal governments, individuals, and nongovernmental
entities will affect the speed and nature of the region's recovery.

Our March 2006 testimony identified a number of issues that will require
the attention of the Administration and Congress. Among those issues
include the rebuilding the region's transportation, health infrastructures
and federal facilities, and the availability and affordability of
insurance coverage. We also have ongoing work examining other issues that
will require federal attention, including (1) assessing the environmental
hazards created by the storms; (2) rebuilding and strengthening the
levees; (3) providing assistance to school districts that have enrolled
large numbers of evacuee children; (4) continuing to provide assistance
for temporary housing; and (5) assuring the financial soundness of the
National Flood Insurance Program.

  Assessing Environmental Hazards Involves the Environmental Protection Agency

Immediately following Katrina, areas along the Gulf Coast faced a number
of environmental challenges associated with oil and hazardous material
releases resulting from the storm. EPA and federal and state partners
continue to monitor air, water, and sediment for potential chemicals of
concern such as heavy metals including lead and arsenic; polycyclic
aromatic hydrocarbons; pesticides; and diesel and oil range organics and
have jointly issued public reports with CDC that provide recommendations
on steps individuals can take to limit potential exposure. EPA is also
continuing to provide support to Louisiana and Mississippi in assessing
drinking water and wastewater infrastructure. Following initial
assessments of drinking water and wastewater impacts in Louisiana and
Mississippi at the request of the states, FEMA, and the Corps, Louisiana
requested additional EPA assistance in conducting needs assessments of
repairs at drinking water systems in the state. These facilities are now
largely operational, but distribution systems are still being repaired,
leaving some areas without service. Through its Office of Recovery and
Removal, Mississippi is reviewing wastewater and drinking water needs, and
EPA has offered to assist, if needed. While EPA has largely completed its
response to hazardous material releases, which has included responding to
spills at industrial facilities and collecting orphaned chemical drums and
tanks, the agency continues to oversee cleanup of a million-gallon oil
spill at a Murphy oil facility in St. Bernard Parish, Louisiana. Finally,
EPA continues to assist in hazardous debris removal by coordinating
recycling efforts for damaged refrigerators and electronic goods, removing
and safely disposing of thousands of household hazardous waste containers
such as paint cans and propane tanks, and working with the Army Corps of
Engineers and local agencies to remove CFCs and other refrigerants from
abandoned appliances that are harmful to the environment.

Areas along the Gulf Coast are also facing environmental challenges as
they begin long-term rebuilding efforts. Large-scale demolition efforts
now underway along the Gulf Coast create the potential for release of
asbestos and other hazardous pollutants. EPA has noted that the number of
houses requiring demolition, the sheer volume of debris, and limited
landfill space available to accept contaminated debris raise a number of
environmental concerns. In addition to EPA's continued role in assisting
the Corps and local agencies with the removal of hazardous household waste
and appliances, EPA also has a role in ensuring that debris containing
asbestos and other pollutants is removed and disposed of appropriately. At
the request of the Louisiana and Mississippi Departments of Environmental
Quality, EPA has provided some flexibility regarding regulated asbestos
materials from homes to facilitate demolition activities in the state of
Louisiana and in six counties in Mississippi. This flexibility still
requires appropriate practices to ensure protection of public health and
the environment. Efforts to reduce the volume of debris by grinding and
burning certain types of debris also present environmental challenges, as
these activities have the potential to release hazardous air pollutants.
EPA continues to work with Louisiana to determine if these practices are
appropriate. Continued monitoring will be necessary to minimize the
environmental risks associated with demolition and debris removal
activities. We are evaluating environmental challenges facing the Gulf
Coast, including EPA's oversight of federal asbestos requirements, in an
ongoing review of the agency's role in hurricane response.

  Rebuilding and Strengthening the Levees Involves the U.S. Army Corps of
  Engineers

We also examined and monitored the Corps plans to repair 169 miles of
levees and floodwalls damaged by Hurricane Katrina to pre-storm
conditions. Completion of these repairs was planned for June 1, 2006, the
start of the 2006 hurricane season. On June 1, 2006, the Corps announced
that 100 percent of pre-hurricane levels of protection had been restored
although some construction contracts were not yet completed. In instances
where the Corps could not complete permanent repairs by June 1, 2006, it
made interim repairs and developed emergency procedures to protect against
flooding in the event of a hurricane.

After completing these repairs, the Corps planned to (1) repair all pumps,
motors and pumping stations by about March 2007; (2) restore sections of
existing hurricane protection projects that have settled over time to
their original design elevations; and (3) complete construction of
incomplete portions of five previously authorized hurricane and flood
control projects by September 2007. The Corps also planned to undertake
further work to restore, construct, and enhance hurricane protection for
southeastern Louisiana by 2010. For example, in April 2006, FEMA released
advisory flood elevations for New Orleans and the surrounding area based
on a one percent annual chance of flooding, also called a 100-year flood.
In response, the Corps is revising its plans and cost estimates to raise
the height of levees and floodwalls to provide the area with a 100-year
level of protection.

Since September 2005, the Congress has appropriated more than $7 billion
to the Corps for portions of this work and additional appropriations are
expected. Our ongoing work indicates, however, that the Corps does not
have a comprehensive strategy and implementation plan to integrate and
manage this work and is currently revising its cost estimates for most
system enhancements. Instead, the Corps appears to be following a
piecemeal approach, similar to its past practice of building projects
without giving sufficient attention to the interrelationships between
projects or fully considering whether they will provide an integrated
level of hurricane protection for the region. We plan to continue our
examination of the Corps' plans and efforts, and to issue a report on this
work later this year.

  Despite Federal Assistance, States and School Districts Face Continuing
  Challenges Regarding Funding and Displaced Students

State and local education officials faced challenges in restarting schools
and educating displaced students. Hundreds of thousands of students, from
kindergarten to the 12th grade, were displaced by the hurricanes. In
addition, Louisiana officials said that 29 schools were destroyed and
about half of the state's schools were damaged, and Mississippi officials
said that 16 schools were destroyed and over half of the state's districts
reported some damage. Districts in areas directly affected by the storms
and those that enrolled displaced students faced financial challenges. For
example, local property tax revenue-a key funding source for schools-may
be undercut in areas with property damage, and state funding for schools
may also be undercut from the effects of the storms. The large number of
displaced students in some districts led to a strain on classroom space,
books, teachers, school buses and drivers, and counseling services.
Congress initially appropriated a total of approximately $1.4 billion
under the Restart and Emergency Impact Aid programs to help reopen
elementary and secondary schools and serve displaced students;73 Congress
subsequently appropriated an additional $235 million under the Emergency
Impact Aid program for serving displaced students.74 Federal assistance
for displaced students must be obligated by September 30, 2006, and must
be used only for expenses incurred during the 2005-2006 school year; yet,
state officials reported that a large number of displaced students are
likely to remain in their new districts for longer than a year.

In addition, state and district officials expressed the need for
flexibility in meeting the requirements of the No Child Left Behind Act of
2001. Upon request of the affected states, the U.S. Department of
Education quickly granted some flexibility regarding certain No Child Left
Behind Act requirements. State officials were also concerned about the
effect of displaced students on their No Child Left Behind Act academic
accountability results. As of June 1, 2006, Education had granted several
states flexibility with regard to how schools are accountable for the
academic achievement of displaced students for the 2005-2006 school year.
Although some states received flexibility in how schools are accountable
for academic achievement, schools were still responsible for ensuring that
displaced students participated in 2005-2006 academic assessments. State
and local school officials could promote continuity of operations after
large-scale emergencies by developing plans that include locating
displaced employees and working closely with other local officials to
focus resources on reopening schools. The reopening of schools is vital
for community recovery. Also, federal regulatory flexibility in reporting
and other requirements can allow states and districts to focus on
rebuilding.

73 Pub. L. No. 109-148.

74 Pub. L. No. 109-234.

  Duration of Housing Assistance for Victims of Hurricanes Katrina and Rita Will
  Require Federal Attention

Our ongoing work on the recovery of the Gulf Coast has identified several
issues regarding temporary housing that will require federal attention.
These issues generally relate to the question of how long the federal
government should provide disaster housing assistance to victims of
Hurricanes Katrina and Rita under FEMA and HUD administered programs.
Typically, FEMA's IHP provides temporary housing.75 IHP requires an
assessment of eligibility before it can provide housing assistance.76
According to FEMA officials, in order to house the large number of
displaced residents quickly, FEMA used its authority under Section 403 of
the Stafford Act to allow states to provide temporary housing for evacuees
of Hurricane Katrina. Section 403 of the Stafford Act authorizes the
agency to provide assistance essential to meeting immediate threats to
life and property resulting from a major disaster, including emergency
shelter. By using this authority, FEMA allowed states to house evacuees
without assessing eligibility. According to FEMA, approximately 60,000
households received temporary housing under this authority. In early 2006,
FEMA began determining the eligibility of those it is assisting under
Section 403 to transition to IHP. In March 2006, FEMA announced that it
would no longer provide temporary housing benefits under Section 403 as of
May 31, 2006.77 Households deemed ineligible because they do not meet the
IHP eligibility criteria will no longer receive housing assistance from
FEMA, potentially leaving thousands of people without housing if they are
unable to obtain other housing assistance. For example, FEMA officials
estimate that approximately 20 percent of the 45,000 households in Texas
receiving assistance under Section 403 authority will be ineligible for
assistance under IHP.

75 Section 408 of the Stafford Act.

76 Eligibility requirements for receiving assistance under IHP include
demonstrating that an applicant's pre-disaster residence is located in the
declared disaster area; that damage to the property was not covered by
insurance; and that the applicant is unable to return to their
pre-disaster home due to damage caused by the disaster.

Victims who receive assistance under FEMA's IHP are eligible to receive
temporary housing assistance generally up to 18 months after the date of
the disaster declaration. FEMA reported that as of April 2006, it had
approved temporary housing assistance for more than 825,000 households
displaced by Hurricanes Katrina and Rita. Although some FEMA officials
told us that many victims of Hurricanes Katrina and Rita will require
housing assistance beyond this limit, it is unclear who will provide it.
According to a FEMA official assigned to Louisiana, state and local
governments are not currently capable of providing housing assistance
after the FEMA assistance ends. FEMA may extend this assistance beyond the
18 month period if it determines that due to extraordinary circumstances
an extension would be in the public interest.

For victims of Hurricane Katrina who resided in public or other
HUD-assisted housing units damaged or destroyed by the storm, HUD
initially provided assistance through its Katrina Disaster Housing
Assistance Program. According to HUD, it assisted approximately 15,000
families through this program. In December 2005, Congress appropriated
$390 million for temporary rental voucher assistance for victims of
Hurricanes Katrina and Rita. 78 Subsequently, HUD established a new
program-the Disaster Voucher Program-and in February 2006 began
transitioning those from the previous program to the new program. Under
the Disaster Voucher Program, households received a housing voucher that
covers 100 percent of the rent for up to 18 months. According to HUD
guidance, a family is eligible to reoccupy its previously-occupied public
or assisted housing unit if and when it becomes available. However, HUD
has not yet issued guidance on what housing assistance will be available
to displaced residents whose units are not going to be available by the
time the assistance ends or those with permanently damaged units79.
Moreover, as a result of the hurricanes, the housing shortage is even more
acute in the affected areas, including public and assisted housing. For
example, some residents resided in public housing units that the storms
damaged or destroyed. HUD plans to demolish some of its severely damaged
public housing stock in New Orleans and other areas affected by the
hurricanes.

77 FEMA announced certain exceptions to the May 31 deadline. In
particular, FEMA stated that it planned to make every effort to notify
states of the IHP eligibility status of evacuees before April 15. If this
notification occurred after April 15, states could request additional time
to provide eligible and ineligible evacuees with a 30-day lease
termination notice. Specifically, states could receive up to 15 additional
days for eligible evacuees, and up to 30 additional days for ineligible
evacuees. Also, for ineligible evacuees, the state would be reimbursed for
contractual lease termination costs associated with leases that require
greater than 30 days notice. FEMA subsequently extended the May 31
deadline to June 30 for 11 jurisdictions. FEMA further extended the
deadline for one of these jurisdictions-Houston, Texas-until September
30th.

78 The Department of Defense Appropriations Act, 2006 (P.L. 109-148).

In response to the hurricanes, HUD's Federal Housing Administration also
issued a 90-day moratorium on foreclosures for all FHA-insured loans on
properties located in areas affected by Hurricanes Katrina and Rita. HUD
subsequently extended the moratorium on foreclosures twice for areas
eligible for FEMA's Individual Assistance, because it found that due to
magnitude of the storm damage, lenders and borrowers may still need
additional time to develop and finalize plans for home repair and
resumption of mortgage payments. According to HUD, the last moratorium on
foreclosures was extended to August 31, 2006. In addition to the
moratoriums, HUD issued guidance instructing lenders servicing FHA-insured
mortgage loans not to report hurricane related delinquencies to credit
bureaus, not to charge late fees, and to expand their efforts to contact
displaced borrowers. Furthermore, HUD offered special mortgage assistance
to borrowers in eligible areas who could not maintain mortgage payments
due to hurricane related property damage, curtailment of income or
increased living expenses. Under this initiative, HUD may make payments to
lenders on behalf of borrowers for up to 12 months worth of mortgage
payments (principal, interest, taxes, and insurance). This special
mortgage assistance is available to eligible borrowers through May 31,
2007. Borrowers are not required to repay HUD until the FHA-insured first
mortgage is paid in full. It is unclear, however, what additional
assistance lenders and servicers of FHA-insured single-family mortgages
may provide and what impact this may have on borrowers and FHA as the
guarantor of these mortgages.

79 Under the Disaster Voucher Program, funding must be obligated by
September 30, 2007. Unless expressly renewed or extended by law,
assistance may not continue beyond the time the obligated funds are
expended.

We plan to continue our examination of the federal role in providing
housing assistance in response to Hurricanes Katrina and Rita, and to
issue a report on this work by the end of this year.

  Questions Raised about FEMA's National Flood Insurance Program Structure and
  Long-Term Solvency

Although homeowner insurance policies typically cover damage and losses
from fire or theft and often from wind-driven rain, they do not cover
flood damage because private insurance companies are largely unwilling to
bear the economic risks associated with the potentially catastrophic
impact of flooding, including damage from storm surges. To provide some
insurance protection for flood victims, as well as incentives for
communities to adopt and enforce floodplain management regulations to
reduce future flood damage, Congress established the National Flood
Insurance Program (NFIP) in 1968.80 Homeowners with mortgages from
federally regulated lenders on property in communities identified to be in
special high-risk flood hazard areas are required to purchase flood
insurance on their dwellings for, at minimum, the amount of the
outstanding mortgage. Optional, lower-cost coverage is also available
under the NFIP to protect homes in areas of low to moderate risk. The NFIP
provides insurance protection of up to $250,000 for homes and up to
$100,000 for personal property.81 As of December 2005, the NFIP had about
4.8 million policies in force. About 3 million (62 percent) of the
policies were for properties in the five states impacted by Hurricanes
Katrina and Rita-Alabama, Florida, Louisiana, Mississippi, and Texas.

The NFIP was created in part to reduce taxpayer funded payments to owners
of flood-damaged properties by having payments for such damage paid
through flood insurance policyholder premiums. The claims from Hurricanes
Katrina and Rita required unprecedented borrowing from the Treasury of
$18.5 billion at the time of our January 2006 testimony, raising anew
questions about its structure and long-term solvency.82 The program's
financial resources are insufficient to meet future expected losses, in
part because policy subsidies and repetitive loss properties have
contributed to continuing losses to the program. Specifically, the program
is not actuarially sound because a high proportion of insurance properties
are subsidized-about 26 percent at the time of FEMA's 2004 review. Policy
holders for these properties, built before flood plain regulations were
established in their communities, pay premiums that represent about 35 to
40 percent of the true risk premium. In January 2006, FEMA estimated the
program had a shortfall of $750 million in annual premium income because
of policy subsidies.

80The National Flood Insurance Act of 1968. The act, as amended, is
codified at 42 U.S.C. S:S: 4001 to 4129.

81NFIP coverage is also available for other structures such as apartment
buildings, schools, churches, businesses and condominium associations, but
the coverage terms differ in various respects from homeowners' coverage.

82 GAO, Federal Emergency Management Agency: Challenges for the National
Flood Insurance Program, GAO-06-335T (Washington, D.C.: Jan. 25, 2006).

The portion of subsidized polices that most adversely impact the program's
financial solvency are about 49,000 repetitive loss properties (as of
March 2004) for which two or more claims of $1,000 or more have been paid
in a 10-year period. Although these properties make up only about 1
percent of the properties insured under the NFIP, they account for 25 to
30 percent of all claims losses. As of March 2004, nearly half of all
nationwide repetitive loss property insurance payments had been made in
Louisiana, Texas, and Florida. These properties accounted for about $4.6
billion in claims payments from 1978 to March 2004. A significant number
of repetitive loss properties were affected by Hurricanes Katrina and
Rita, and a FEMA management official predicted that the inventory of
repetitive loss properties would increase as a result of damage from the
two storms.

As part of its flood plain management strategy, NFIP policies encourage
states and local communities to elevate or remove damaged properties from
the flood plain. In addition to paying claims for flood damage, NFIP
policies pay up to $30,000 for the cost of complying with mitigation
actions required under state or local floodplain management laws or
ordinances, such as elevating, moving, or demolishing the damaged
structures. This increased cost of compliance (ICC) coverage is available
under the NFIP's standard flood insurance policy for properties that
suffer substantial damage, including repetitive loss properties.83 In an
upcoming revision to the standard flood insurance policy, FEMA plans to
make permanent the increase in time to complete work and receive an ICC
payment. It is too early in the recovery process to determine the impact
of the mitigation actions on the national inventory of repetitive loss
properties.

For all these reasons, and others described in our March 2006 testimony,
we have placed the NFIP on our list of high-risk government programs. In
2004 we made recommendations to FEMA on strategies to better ensure that
FEMA's map modernization achieves the intended benefits of improved flood
mitigation, increased flood insurance participation, and improved
multi-hazard mitigation and risk management capabilities.84 DHS and FEMA
generally agreed with our recommendations. FEMA said that it planned to
refine existing standards, in coordination with stakeholders, to ensure
consistent data collection and analysis for all communities commensurate
with their flood risk; that it would continue to collaborate with
stakeholder groups to develop an effective strategy to include states and
communities with varying levels of capabilities and resources; and that it
planned to refine performance measures for this map modernization
objective to make them more useful and quantifiable. In 2005, we
recommended that FEMA use a statistically valid method to select claims
for quality review because its existing sampling and internal controls did
not provide management with the information needed to have reasonable
assurance that program objectives are being achieved. We also recommended
that FEMA set target dates for implementing the provisions of the Flood
Insurance Reform Act of 2004.85 FEMA said its existing sampling method was
sufficient for the purposes for which it was used and that it was working
diligently to implement the requirements of the 2004 reform act.86

83The NFIP standard flood insurance policy considers a property
substantially damaged if the cost of repairing it exceeds 50 percent of
its market value at the time of the flood.

84GAO, Flood Map Modernization: Program Strategy Shows Promise, but
Challenges Remain, GAO-04-417 (Washington, D.C.: Mar. 31, 2004).

85GAO, Federal Emergency Management Agency: Improvements Needed to Enhance
Oversight and Management of the National Flood Insurance Program,
GAO-06-119 (Washington, D.C.: Oct. 18, 2005).

86In response to the Flood Insurance Reform Act of 2004, FEMA recently
published an interim final rule establishing a regulatory appeals process
for flood insurance claimants. National Flood Insurance Program; Appeal of
Decisions Relating to Flood Insurance Claims, 71 Fed. Reg. 30294 (2006).

Recent GAO recommendations to DHS                                          
to enhance oversight and          
management of NFIP                DHS responses
Flood Map Modernization 2004      
FEMA should ensure that its map   FEMA said that it planned to refine      
modernization achieves the        existing standards, in coordination with 
intended benefits of improved     stakeholders, to ensure consistent data  
flood mitigation, increased flood collection and analysis for all          
insurance participation, and      communities commensurate with their      
improved multi-hazard mitigation  flood risk; that it would continue to    
and risk management capabilities. collaborate with stakeholder groups to   
                                     develop an effective strategy to include 
                                     states and communities with varying      
                                     levels of capabilities and resources;    
                                     and that it planned to refine            
                                     performance measures for this map        
                                     modernization objective to make them     
                                     more useful and quantifiable.            
National Flood Insurance Program 2005
FEMA should use a statistically   FEMA said its existing sampling method   
valid method to select claims for was sufficient for the purposes for      
quality review because existing   which it was used.                       
sampling and internal controls    
did not provide management with   
the information needed to have    
reasonable assurance that program 
objectives are being achieved.    
FEMA should set target dates for  FEMA responded that it was working       
implementing the provisions of    diligently to implement the requirements 
the Flood Insurance Reform Act of of the 2004 reform.                      
2004.                             
    For more detailed information about our recommendations, see appendix I.

A Framework to Enhance Federal Financial Assistance's Performance in the
Restoration of the Gulf Coast

Finally, in our March 8 testimony, we identified an accountability and
performance framework from relevant GAO past work that may be considered
regarding the provision of federal financial assistance for the
restoration of the Gulf Coast:87

           o  Identify the scope of the problem. For example, does the
           problem reflect broader industry wide or regional economic
           conditions? For the Gulf Coast, this would involve financial and
           economic analyses, perhaps utilizing current studies of prior
           conditions and the ongoing progress of recovery and rebuilding.
           o  Clearly establish the effect of the problem on the national
           interest-such as whether federal involvement is needed because the
           problem presents potentially large economy wide or regional
           consequences. For example, in the Gulf Coast, Congress should
           consider whether the proposed rebuilding plans are reasonable and
           the involvement of state and local governments and the private
           sector will not, on their own, provide necessary capital.
           o  Establish clear, concise, and consistent legislative goals and
           objectives associated with the response. For example, in the Gulf
           Coast, building on the President's decision to appoint a
           Coordinator of Federal Support for the Recovery and Rebuilding of
           the Gulf Coast region, Congress should ensure that the goals of
           all aspects of federal involvement are clear, measurable, and
           agreed-upon by all participants.
           o  Protect the government's financial interest. In the Gulf Coast,
           for example, controls might be put in place so there is review of
           the most important financial and operating plans that rely on
           federal investments.

87GAO, Guidelines for Rescuing Large Failing Firms and Municipalities,
GAO/GGD-84-34 (Washington, D.C.: Mar. 29, 1984).

In terms of protecting the government's financial interest, our ongoing
work in this area found that there is no one agency or central collection
point that exists to compile and report on how the emergency supplemental
appropriations funds provided to 23 different federal agencies are being
spent. Without a framework and mechanisms in place to collect and
consolidate information from these agencies on a periodic basis, it will
be difficult for decision makers to determine how much federal funding has
been spent and by whom, whether more may be needed, or whether too much
has been provided. The ability to separately track and report on these
funds is important to help ensure better accountability and clearly
identify the status of funding provided in direct response to these
hurricanes at both the individual federal agency level as well as the
government wide level. Also, it is important to provide transparency so
that hurricane victims, affected states, as well as American taxpayers,
know how these funds are being spent. We will issue a report later this
year that addresses the federal government's ability to track and report
on the hurricane relief funds received.

                                  Conclusions

Since September 11, 2001, the federal government has awarded billions of
dollars in grants and assistance to state and local governments to assist
in strengthening emergency management capabilities. DHS has developed
several key policy documents, including the NRP, NIMS, and the interim
National Preparedness Goal to guide federal, state, and local efforts. The
aftermath of the 2005 hurricane season resulted in a reassessment of the
federal role in preparing for and responding to catastrophic events. The
studies and reports of the past year-by Congress, the White House Homeland
Security Council, the DHS-IG, DHS and FEMA, GAO, and others-have provided
a number of insights into the strengths and limitations of the nation's
capacity to respond to catastrophic disasters and resulted in a number of
recommendations for strengthening that capacity. Collectively, these
studies and reports paint a complex mosaic of the challenges that the
nation-federal, state, local, and tribal governments, nongovernmental
entities, the private sector, and individual citizens-faces in preparing
for, responding to, and recovering from catastrophic disasters. In
addition to the reports issued to date, there are numerous ongoing
analyses of various facets of the nation's preparedness and response
efforts before and after Hurricane Katrina.

Improving the nation's ability to prepare, respond, and recover from
catastrophic disasters will take three critical inputs: (1) leaders and
professionals with the right knowledge, skills, and experience; (2) plans
and guidance that detail what needs to be done, by whom, how, and how
well; and finally (3) clear criteria and expectations that are clearly
communicated, well understood, and result in appropriate, coordinated
actions from all levels of government, their emergency planners and
responders, and the nonprofit and private-sector organizations that will
be providing support. This requires the development of thoughtful
strategic planning and assessment, along with developing and sustaining
needed skills and assets. Effective training and exercises based on
realistic scenarios is a key component of building and maintaining needed
skills and capabilities. As we noted in past GAO work, overall federal
assistance has not been guided by a clear, risk-based strategic plan that
would provide a basis for realistic budgeting and resource planning.88
Ultimately, the federal government must determine how much it will cost to
develop and maintain these needed capabilities and what the federal
government can afford to pay. Other levels of government face a similar
challenge. DHS and its partners and stakeholders-governmental and
nongovernmental, public and private-face the challenge of working together
to coordinate preparedness activities and formulate realistic budgets and
resource plans to share these costs and support and sustain implementation
of an efficient and effective all-hazards national preparedness program.

88 GAO, Homeland Security: DHS' Effort to Enhance First Responders'
All-Hazards Capabilities Continue to Evolve, GAO-04-652 (Washington, D.C.:
July 11, 2005).

Catastrophic disasters are unique in their scope and the magnitude of
their effects. In preparing for any disaster, but particularly
catastrophic disasters, it is essential to have in place through
contracts, prepositioning of key supplies, and other means the needed
surge capacity to respond quickly and effectively to the destruction and
dislocation that results from the catastrophe. In moving forward, one
critical challenge will be determining if the initial and long-term
efforts to implement specific initiatives will truly close the identified
gaps in the nation's capacity to prepare for, respond to, and recover from
catastrophic disasters. Sound recommendations and initiatives must be
effectively implemented to achieve the intended improvements. Currently,
there is little available information on the operational readiness of many
of the reforms and actions DHS has announced in recent months. The first
real test of these actions will come with the next major hurricane or
other major disaster. DHS has conducted some exercises in recent weeks,
but there is little available information on the results of those
exercises. In addition, some of the reforms, such as revisions to the NRP,
may have clarified some issues, such as the role of the Secretary of
Homeland Security in declaring incidents of national significance, while
potentially raising new issues, such as how the NRP, which DHS now states
is in effect at all times, would be operationalized in incidents of lesser
severity. While the scope of the NRP has broadened, DHS and other federal
agencies may be without a road map for dealing with incidents of lesser
severity until they supplement the NRP with detailed, scalable operational
plans. Likewise, DHS and other federal agencies may be without a road map
in responding to catastrophic incidents until they supplement the NRP's
catastrophic incident annex with the detailed operational plans envisioned
by the NRP. To be effective, the NRP must be supported by robust
operational plans for implementing its provisions.

Appropriate controls and accountability mechanisms for the use of
resources during a catastrophic disaster are essential to ensure that the
resources are used appropriately, but there is always a tension between
normal controls and accountability mechanisms and the need to deliver
assistance expeditiously, especially when responders and governments are
providing life-saving and life-sustaining services in a time-critical
environment. DHS and state and local governments all face a significant
challenge in ensuring that relief payments and services are only sent to
valid registrants while also distributing those relief payments and
services as fast as possible. Thus, all levels of governments must further
develop and strengthen controls to ensure accountability, because-as FEMA
has learned from prior experience-pursuing collection activities after
disaster relief payments have been made is costly, time-consuming, and
ineffective. Upfront controls are all the more crucial given the estimated
billions of dollars in erroneous or excessive payments related to
Hurricanes Katrina and Rita.

Finally, given the magnitude of Hurricane Katrina's devastation of the
physical and economic infrastructure in the Gulf Coast-both public and
private sector-rebuilding is likely to take years, if not decades, to
complete. As a result, all levels of government will have a critical role
in the effort, not just the federal government and not solely or even
primarily through FEMA's post-disaster recovery and mitigation funding.
Some communities were so totally devastated that they almost face
rebuilding their communities from the ground up. These long-term recovery
and rebuilding efforts offer an opportunity to mitigate the potential
impact of future hurricanes, and employ both direct governmental funding
and forms of fiscal and monetary support from the banking and insurance
industries. In light of how long this effort may take, GAO will continue
to examine current recovery issues and long-term rebuilding activities.

                                Recommendations

In this report we are making several new recommendations updating and
formalizing several recommendations first posed in our March 8, 2006,
testimony on preliminary observations regarding preparedness, response,
and recovery; and one new recommendation on advance procurement practices
and procedures:

Recommendations for Executive Action

           o  Rigorously re-test, train, and exercise its recent
           clarification of the roles, responsibilities, and lines of
           authority for all levels of leadership, implementing changes
           needed to remedy identified coordination problems.

           o  Direct that the NRP base plan and its Catastrophic Incident
           Annex be supported by more robust and detailed operational
           implementation plans, particularly the Catastrophic Incident
           Supplement to the NRP. Such operational plans should, for example,
           further define and leverage those military capabilities that might
           be needed in a catastrophic disaster.

           o  Provide guidance and direction for federal, state, and local
           planning, training, and exercises to ensure such activities fully
           support preparedness, response, and recovery responsibilities at a
           jurisdictional and regional basis. This should also include the
           application of lessons learned from actual catastrophic and other
           disasters.

           o  Take the lead in monitoring federal agencies' efforts to meet
           their responsibilities under the NRP and the interim National
           Preparedness Goal, including the development, testing, and
           exercising of agency operational plans to implement their
           responsibilities under the NRP, NIMS, and the interim National
           Preparedness Goal.

           o  Given that resources are finite, apply an all-hazards, risk
           management approach in deciding whether and how to invest in
           specific capabilities for a catastrophic disaster.

           o  Provide guidance on advance procurement practices and
           procedures for those federal agencies with roles and
           responsibilities under the NRP, so that these agencies can better
           manage disaster-related procurements, such as food, shelter, and
           debris removal. These practices should be in advance of disasters,
           ongoing and continuous, and include (1) developing knowledge of
           contractor capabilities and available commodities, services and
           prices as well as developing pre-established vendor relationships,
           on a competitive basis whenever feasible; (2) establishing
           scalable operations plans to adjust the level of capacity needed
           to respond; (3) formally assigning and communicating
           disaster-related responsibilities and, where feasible,
           incorporating necessary training; and (4) providing sufficient
           numbers of field-level contracting staff to meet mission
           requirements. DHS should also establish an assessment process to
           monitor agencies' continuous planning efforts for their
           disaster-related procurement needs and the maintenance of
           capabilities.

Matters for Congressional Consideration

Reaffirming a recommendation we made following Hurricane Andrew, we
recommend that Congress:

           o  Give federal agencies explicit authority to take actions to
           prepare for catastrophic disasters when there is warning.

We also offer some analytical frameworks and factors that Congress may
wish to consider in carrying out its oversight and legislative
responsibilities with regard to national preparedness and the recovery of
the Gulf Coast region:

           o  Use a risk management framework to assist in its oversight and
           legislative decision-making regarding the nation's capacity to
           respond to catastrophic disasters.

           o  If Congress is considering a change in FEMA's organizational
           placement, it should consider (1) whether factors such as the
           qualifications, experience, and training of the leadership and the
           adequacy of resources led to its performance difficulties; (2)
           criteria such as mission relevancy, similar goals, and objectives
           (present and future); (3) leveraging the effectiveness of other
           agencies and programs or the new department as a whole; and (4)
           gains in efficiency and effectiveness through eliminating
           duplications and overlaps.

           o  If Congress is considering a change in the qualifications of
           the Undersecretary for Federal Emergency Management, it should
           consider establishing statutory professional qualifications for
           the Undersecretary and other selected key positions within DHS and
           term appointments for the Undersecretary and selected other
           positions.

           o  Consider the four conditions that we suggested in 1984, as a
           framework of ideas about how to structure future financial
           assistance programs and what program requirements to include to
           achieve Congressional goals and objectives while minimizing the
           risk of financial loss to the government. These guidelines are a
           useful framework for developing assistance programs for the Gulf
           Coast restoration:

                        o  The scope of the problem should be identified,
                        such as if the problem reflects broader industry wide
                        or regional economic conditions. For the Gulf Coast,
                        this would involve financial and economic analyses,
                        perhaps utilizing current studies of prior conditions
                        and the ongoing progress of recovery and rebuilding.

                        o  The effect of the problem on the national interest
                        should be clearly established, for example, whether
                        the problem presents potentially large economy wide
                        or regional consequences. For example, in the Gulf
                        Coast, Congress should consider the costs of
                        municipal and corporate collapse and the challenges
                        associated with providing assistance.

                        o  The legislative goals and objectives associated
                        with the response should be clear, concise, and
                        consistent. For example, in the Gulf Coast, goals and
                        objectives for rebuilding should be clearly stated,
                        working with the state and local groups already
                        tasked with recovery planning and with the
                        Administration's Coordinator of Federal Support for
                        the Recovery and Rebuilding of the Gulf Coast region.

                        o  Lastly, the government's financial interest should
                        be protected. In the Gulf Coast, controls might be
                        put in place so that the most important financial and
                        operating plans will be reviewed.

This report also identifies the major findings, conclusions, and 74
recommendations and matters for congressional consideration from our prior
and ongoing work on catastrophic disasters. Appendix I summarizes 24 key
GAO recommendations identified in work prior to Hurricane Katrina. These
24 prior recommendations were not adopted or in effect when Hurricane
Katrina hit the Gulf Coast and remain listed by GAO as open
recommendations, that is, recommendations not fully implemented. We
continue to believe that, for the most part, these recommendations are
still viable. In addition, appendix I lists 43 GAO recommendations from
GAO reports in the aftermath of Hurricanes Katrina and Rita, and 7 new
recommendations formalized in this report.

                                Agency Comments

We provided a draft of this report to DHS for review and comment, and also
provided relevant sections of the draft report to various federal
departments and agencies including the departments of Agriculture,
Education, HHS, HUD, Labor, and State, as well as SBA, EPA and Social
Security Administration. The Departments of State and HHS said they had no
comments on our draft. The Department of Agriculture's Food and Nutrition
Service, the Department of Education, EPA, HUD, and the Social Security
Administration provided additional technical comments that we
incorporated, and the Social Security Administration also stated that they
were pleased to be included in the report as an example of good planning.

DHS provided written comments on August 28, 2006, signed by the
Undersecretary for Federal Emergency Management and the Undersecretary for
Preparedness. DHS's comments are reproduced in full in appendix II. DHS
also provided technical comments that we incorporated as appropriate. DHS
generally concurred with the six new recommendations in our draft report
and described an array of actions it has taken, has underway, or planned
to implement those recommendations. DHS also described actions it has
taken to address the expansion of search and rescue capabilities; the
supply pre-positioning and tracking of emergency supplies, such as food,
ice, and water; FEMA staffing; and the acceptance and management of
international donations for disaster response and relief.

If effectively implemented, the actions that DHS described should
basically address the problems that we described in the draft report.
However, as we noted in our report, the NRP revisions may not fully
resolve the leadership issues with respect to the PFO and FCO roles and
questions remain with regard to how the NRP, which now states it is in
effect at all times would be operationalized in incidents of severity less
than the incidents of national significance that are to be managed by the
Secretary of Homeland Security. Because we did not have time to evaluate
DHS' actions completed to date, we cannot reach any conclusions regarding
the extent to which those actions are fully operational and have improved
disaster preparedness and response capabilities.

In commenting on our recommendations, DHS stated that planning for patient
evacuation out of hospitals and nursing homes is being coordinated by HHS,
as Coordinating Agency for the NRP's Emergency Support Function 8. We
understand that responding to our recent recommendation of planning for
patient evacuation out of hospitals and nursing homes will involve
coordination among various agencies, including HHS, and addressed our
recommendations to DHS because it is responsible for the NRP, the
Catastrophic Incident Annex and its Supplement, and the activation of
NDMS.89

89 GAO, Limitations in Federal Evacuation Assistance for Health Facilities
Should be Addressed, GAO-06-826 (Washington, D.C.: July 20, 2006).

On August 14, 2006, we received written comments from the Department of
Labor who stated that our report correctly points out that OSHA and FEMA
had experienced difficulties in agreeing on roles and procedures. OSHA has
reported that their agency and FEMA have worked together to develop
procedures for role of the Safety and Health Coordinator in the Joint
Field Office and for the NRP's Worker Safety and Health Support Annex.

SBA's Associate Administrator for Disaster Assistance provided written
comments on August 14, 2006, on a draft of the SBA segment of this report.
SBA's comments basically reiterate the comments it made on our earlier
report 90 and are reproduced in full in appendix III. SBA stated that more
emphasis should have been given to its improvement efforts and the
benefits of DCMS compared with its previous system and stated its concerns
regarding the use of catastrophe risk model data in determining the user
requirements of DCMS. It was not within the scope of our work to conduct a
comparative analysis of DCMS and SBA's previous system, but we recognized
some of the benefits the agency realized by adopting DCMS. We continue to
believe that catastrophe risk modeling firms provide critical information,
such as the likelihood and severity of damages from potential
catastrophes. Combined with other elements of a comprehensive planning
process, such information would have been useful in planning the maximum
user capacity of DCMS. If SBA had considered this information, it may have
expanded the maximum user requirement for DCMS and been better prepared to
reduce the backlog of loan applications.

                                  GAO Contacts

We are sending copies of this report to the appropriate congressional
committees; the Secretary of Homeland Security; the Director, Office of
Management and Budget; and other interested parties. In addition, this
report will be available at no charge on the GAO Web site at
http://www.gao.gov .

Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. For further
information about this report, please contact William Jenkins, Jr,
Director, GAO Homeland Security and Justice Issues Team, at (202)-512-8757
or at [email protected] . GAO staff who were major contributors to this
report are listed in appendix IV.

90 GAO, Small Business Administration: Actions Needed to Provide More
Timely Assistance, GAO-06-860 (Washington, D.C.: July 28, 2006)

Sincerely yours,

David M. Walker

Comptroller General

of the United States

Appendix I: Summary of Key Open GAO Recommendations on Catastrophic
Disasters

The following three tables show GAO's recommendations on dealing with
catastrophic disasters made before Hurricane Katrina, in the aftermath of
Katrina, and new recommendations formalized in this report. The tables
also show the agency response to each recommendation. Recommendations are
given in chronological order in each table, with the most recent
recommendations listed first.

Table 4: Key Open Recommendations Made Prior to Hurricanes Katrina and
Ritaa

Title and GAO product                                                      
number                Summary of recommendations  Agency response
Reserve Forces:       Recommendations to the      The department generally 
Actions Needed to     Secretary of Defense:       agreed with our          
Better Prepare the                                recommendations and      
National Guard for    To improve the Army and the cited actions it was     
Future Overseas and   Air National Guard's        taking to implement      
Domestic Missions,    preparedness to perform     them. DOD partially      
GAO-05-21             homeland security missions, agreed with our          
                         the Secretary of Defense    recommendation that DOD  
                         should:                     develop plans to manage  
                                                     the risk associated with 
                            o  Assess how support    the declining readiness  
                            for current operations   of non-deployed Army     
                            will affect the          National Guard forces.   
                            readiness of             We agreed that the Army  
                            non-deployed Army        Campaign Plan is a       
                            National Guard forces    significant step in      
                            for future overseas and  planning to address      
                            domestic missions.       National Guard readiness 
                            o  Specify how the Army  problems because it      
                            plans to restructure and identifies goals and     
                            provide the Guard        objectives and assigns   
                            resources-personnel,     responsibilities for     
                            equipment, and           actions to plan for      
                            training-consistent with transforming its forces. 
                            its 21st century role.   However, we believed the 
                            o  Establish the full    Army Campaign Plan did   
                            range of the National    not fully meet the       
                            Guard's homeland         intent of our            
                            missions, including      recommendation because   
                            those led by DOD and     it lacked specificity    
                            those conducted in       about how the Army would 
                            support of civilian      address the readiness of 
                            authorities.             non-deployed Army        
                            o  Identify the National National Guard forces in 
                            Guard's capabilities to  the near term and how    
                            perform these missions   all Guard units will be  
                            and any shortfalls in    converted to the modular 
                            personnel, equipment,    design. DOD concurred    
                            and training needed to   with our recommendation  
                            perform these missions   to establish the full    
                            successfully.            range of the National    
                            o  Develop a plan to     Guard's homeland         
                            manage the risk          missions, to identify    
                            associated with the      the capabilities needed  
                            declining readiness of   to perform those         
                            non-deployed Army        missions and develop a   
                            National Guard forces,   plan to address any      
                            including identifying    shortfalls, and to       
                            funding for any          establish readiness      
                            personnel and equipment  standards and measures   
                            required to mitigate     for the Guard's homeland 
                            unacceptable levels of   security missions.       
                            risk.                    However, in its          
                            o  Establish readiness   comments, DOD said it    
                            standards and measures   would take a different   
                            for the Guard's homeland approach to              
                            security missions so     accomplishing the tasks  
                            that the readiness for   than we recommended. We  
                            these missions can be    believe the approach DOD 
                            systematically measured  proposes meets the       
                            and accurately reported. intent of our            
                                                     recommendation, and we   
                                                     have modified the        
                                                     wording of our           
                                                     recommendation to        
                                                     reflect the proposed     
                                                     change in organizational 
                                                     responsibilities.        
Homeland Security:    Recommendations to the      DHS said that it was     
Federal Leadership    Secretary of Homeland       developing a nationwide  
and Intergovernmental Security:                   database of              
Cooperation Required                              interoperable public     
to Achieve First      To address a fundamental    safety communications    
Responder             barrier to successfully     frequencies and also     
Interoperable         addressing the decades-old  said it planned to work  
Communications,       problems of interoperable   on a common nomenclature 
GAO-04-740            communications-the lack of  across public safety     
                         effective, collaborative,   disciplines and          
                         interdisciplinary, and      jurisdictions. With      
                         intergovernmental planning, respect to our second    
                         the Secretary of Homeland   recommendation, DHS said 
                         Security should:            it would develop a       
                                                     methodology to establish 
                            o  Work with the Federal a national baseline of   
                            Communications           public safety            
                            Commission and the       communication and        
                            National                 interoperability         
                            Telecommunications and   capabilities with input  
                            Information Agency to    from the public safety   
                            develop a nationwide     community. However, the  
                            database of              DHS letter did not       
                            interoperable            directly address our     
                            communications           recommendation about     
                            frequencies and a common encouraging states to    
                            nomenclature for those   create statewide bodies  
                            frequencies and          for interoperable        
                            establish clear          communications that      
                            timeframes to complete   would establish          
                            both efforts.            statewide                
                            o  Establish             interoperability plans   
                            interoperability         for federal, state, and  
                            requirements whose       local communications     
                            achievement can be       systems in all frequency 
                            measured.                bands.                   
                            o  Through grant         
                            guidance, encourage      
                            states to establish a    
                            single statewide body    
                            that will develop a      
                            comprehensive statewide  
                            interoperable            
                            communications plan.     
                            o  Require that federal  
                            grant funding of new     
                            equipment shall be       
                            approved only upon       
                            certification by the     
                            statewide body that such 
                            grants conform with the  
                            statewide                
                            interoperability plan.   
                            o  In conjunction with   
                            the Director of OMB,     
                            review the               
                            interoperability mission 
                            and functions now        
                            performed by Wireless    
                            Public Safety            
                            Interoperable            
                            Communications Program   
                            and establish these      
                            functions as a long-term 
                            program with adequate    
                            coordination authority   
                            and funding.             
Homeland Security:    Recommendations to the      DHS generally agreed     
Management of First   Secretary of Homeland       with our recommendations 
Responder Grants in   Security:                   but also stated that     
the National Capital                              National Capital Region  
Region Reflects the   To help ensure that         jurisdictions had worked 
Need for Coordinated  emergency preparedness      cooperatively together   
Planning and          grants and associated funds to identify              
Performance Goals,    are managed in a way that   opportunities for        
GAO-04-433            maximizes their             synergies and lay a      
                         effectiveness, the          foundation for meeting   
                         secretary should:           the challenges noted in  
                                                     the report. DHS agreed   
                            o  Work with the         that there is a need to  
                            National Capital Region  continue to improve      
                            jurisdictions to develop preparedness by          
                            a coordinated strategic  developing more specific 
                            plan to establish goals  and improved             
                            and priorities for       preparedness standards,  
                            enhancing first          clearer performance      
                            responder capacities     goals, and an improved   
                            that can be used to      method for tracking      
                            guide the use of federal regional initiatives.    
                            emergency preparedness   However, DHS and GAO     
                            funds.                   disagreed about          
                            o  Monitor the plan's    oversight roles and      
                            implementation to ensure responsibilities.        
                            that funds are used in a 
                            way that promotes        
                            effective expenditures   
                            that are not             
                            unnecessarily            
                            duplicative.             
                            o  Identify and address  
                            gaps in emergency        
                            preparedness and         
                            evaluate the             
                            effectiveness of         
                            expenditures in meeting  
                            those needs by adapting  
                            standards and            
                            preparedness guidelines. 
Flood Map             Recommendations to the      DHS and FEMA generally   
Modernization:        Secretary of Homeland       agreed with our          
Program Strategy      Security:                   recommendations. FEMA    
Shows Promise, but                                said that it planned to  
Challenges Remain,    To help ensure that FEMA's  refine existing          
GAO-04-417            map modernization achieves  standards, in            
                         the intended benefits of    coordination with        
                         improved flood mitigation,  stakeholders, to ensure  
                         increased flood insurance   consistent data          
                         participation, and improved collection and analysis  
                         multi-hazard mitigation and for all communities      
                         risk management             commensurate with their  
                         capabilities through the    flood risk; that it      
                         production of more accurate would continue to        
                         and accessible flood maps   collaborate with         
                         the Secretary of Homeland   stakeholder groups to    
                         Security should direct the  develop an effective     
                         Undersecretary of Emergency strategy to include      
                         Preparedness and Response   states and communities   
                         to take the following four  with varying levels of   
                         actions:                    capabilities and         
                                                     resources; that it had   
                            o  Develop and implement begun planning to ensure 
                            data standards that will that additional staffing 
                            enable FEMA, its         needs are met; and that  
                            contractor, and its      it planned to refine     
                            state and local partners performance measures for 
                            to identify and use      this map modernization   
                            consistent data          objective to make them   
                            collection and analysis  more useful and          
                            methods for communities  quantifiable.            
                            with similar risk.       
                            o  Develop and implement 
                            strategies for           
                            partnering with state    
                            and local entities with  
                            varying levels of        
                            capabilities and         
                            resources.               
                            o  Ensure that it has    
                            the staff capacity to    
                            effectively implement    
                            the nationwide mapping   
                            contract and the overall 
                            map modernization        
                            program.                 
                            o  Develop and implement 
                            useful performance       
                            measures that define     
                            FEMA' s progress in      
                            increasing stakeholders' 
                            awareness and use of the 
                            new maps, including      
                            improved mitigation      
                            efforts and increased    
                            participation rates in   
                            purchasing flood         
                            insurance.               
Continuity of         Recommendations to the      DHS agreed that better   
Operations: Improved  Secretary of Homeland       continuity of operations 
Planning Needed to    Security:                   planning is needed to    
Ensure Delivery of                                ensure delivery of       
Essential Government  To enhance the ability of   essential services and   
Services, GAO-04-160  the executive branch to     that FEMA could do more  
                         continue to provide         to improve continuity of 
                         essential services during   operations planning and  
                         emergencies, the secretary  has begun to correct the 
                         should:                     identified deficiencies. 
                                                     DHS has since reported   
                            o  Direct the            to GAO that it had taken 
                            Undersecretary of        several actions to       
                            Preparedness to take     improve agency           
                            steps to improve the     continuity of operations 
                            oversight of continuity  plans, including         
                            of operations planning   conducting an            
                            by ensuring that         interagency exercise in  
                            agencies correct the     2004 and providing       
                            deficiencies in          training to more than    
                            individual continuity of 350 continuity of        
                            operations plans         operations planning      
                            identified here, as well managers at 65 agencies. 
                            as those identified in   In addition, DHS         
                            previous assessments.    officials reported that  
                            o  Conduct assessments   after it fully deploys a 
                            of agency continuity     Readiness Reporting      
                            plans that include       System to track agency   
                            independent verification compliance with FEMA     
                            of agency-provided       guidance, agencies will  
                            information, as well as  be required to           
                            an assessment of the     periodically report to   
                            essential functions      FEMA on their            
                            identified and their     compliance. DHS reports  
                            interdependencies with   that its Readiness       
                            other activities.        Reporting System will be 
                                                     used to assist it in     
                                                     assessing agency         
                                                     contingency plans using  
                                                     information provided by  
                                                     the agencies. Agencies   
                                                     will then be required to 
                                                     provide periodic updates 
                                                     on their level of        
                                                     compliance with FEMA     
                                                     guidance.                
Disaster Management:  In 1993, in response to     FEMA generally agreed    
Recent Disasters      Hurricane Andrew, we        with our findings and    
Demonstrate the Need  conducted several reviews   recommendations and had  
to Improve the        and made recommendations    begun taking actions to  
Nation's Response     regarding the unique        address them. These      
Strategy,             challenges involved in      included a proposal in   
GAO/T-RCED-93-46 ;    responding to catastrophic  FEMA's fiscal year 1994  
Disaster Management:  disasters.                  budget request to        
Improving the                                     restructure in a manner  
Nation's Response to  Recommendations to FEMA:    it felt came close to    
Catastrophic                                      our recommendation that  
Disasters,               o  FEMA should improve   FEMA form a disaster     
GAO/RCED-93-186 ; and    its catastrophic         unit. In addition, FEMA  
Disaster Assistance:     disaster response        told us it would revise  
DOD's Support for        capability by using      and update its training  
Hurricanes Andrew and    existing authority to    and exercises on the     
Iniki and Typhoon        aggressively respond to  basis of the lessons     
Omar, NSIAD-93-180       catastrophic disasters,  learned from recent      
                            assessing the extent of  catastrophic disasters;  
                            damage, and then         developing methods to    
                            actively advising state  better determine state   
                            and local officials of   and local preparedness   
                            identified needs and the for disaster response;   
                            federal resources        and seeking clarified    
                            available to address     legislative authority    
                            them, as well as the     when a catastrophic      
                            extent to which DOD      disaster is predicted.   
                            resources will be needed                          
                            to supplement those of   At the time we said      
                            the Red Cross in meeting FEMA's recent            
                            mass care needs.         initiatives are a good   
                            o  FEMA should enhance   start toward improving   
                            the capacity of state    its response to future   
                            and local governments to catastrophic disasters.  
                            respond to catastrophic  However, we noted that   
                            disasters by (a)         some of the improvements 
                            continuing to give them  necessary in the overall 
                            increasing flexibility   federal response are     
                            to match grant funding   outside of FEMA's        
                            with individual response control. Presidential    
                            needs, (b) upgrading     action is needed to      
                            training and exercises   strengthen leadership    
                            for catastrophic         for the federal response 
                            disaster response, and   by designating a key     
                            (c) assessing each       White House official to  
                            state's preparedness for oversee preparedness and 
                            catastrophic disaster    response activities.     
                            response.                Furthermore, legislative 
                                                     action is needed to      
                         Matters for Congressional   improve all federal      
                         Consideration:              agencies' preparedness   
                                                     when there is warning of 
                         Congress should consider    a disaster and to allow  
                                                     DOD to activate Reserve  
                            o  Giving FEMA and other units for catastrophic   
                            federal agencies         disaster relief.         
                            explicit authority to                             
                            take actions to prepare  However, FEMA's mission, 
                            for catastrophic         placement, and           
                            disasters when there is  all-hazards approach     
                            warning.                 have been re-configured  
                            o  Removing statutory    several times and the    
                            restrictions on DOD's    recommendations to FEMA  
                            authority to activate    have remained open. We   
                            Reserve units for        did subsequently closed  
                            catastrophic disaster    our matters for          
                            relief.                  congressional            
                                                     consideration when it    
                                                     appeared Congress would  
                                                     not take any action on   
                                                     the removing             
                                                     restrictions on Reserve  
                                                     activations, and when it 
                                                     considered legislation   
                                                     for giving agencies      
                                                     explicit authority to    
                                                     prepare for pending      
                                                     catastrophic disaster.   
                                                     However, given the       
                                                     failures witnessed in    
                                                     Hurricane Katrina and    
                                                     the new threat of        
                                                     terrorism we are         
                                                     reopening these          
                                                     recommendations to       
                                                     Congress.                

Source: GAO analysis

aAn open recommendation is one that the agency has not fully implemented.

Table 5: Recent Open Recommendations Made in the Aftermath of Hurricanes
Katrina and Ritaa

Title and GAO       Summary of                                             
product number      recommendations           Agency response
Federal Action      Recommendations to the    Regarding our                
Needed to Ensure    Secretary of Health and   recommendations that HHS     
States Have Plans   Human Services:           ensure that the department's 
to Safeguard                                  guidance and training to     
Children in the     To better assist states   states on child welfare      
Child Welfare       in developing child       disaster planning address    
System Displaced by welfare disaster plans,   the dispersion of children   
Disasters,          we are recommending that  and families, the            
GAO-06-944          the Secretary of Health   Administration for Children  
                       and Human Services        and Families stated that it  
                                                 has taken action to update   
                          o  Ensure that the     the guidance and provide     
                          department's child     training to states and will  
                          welfare disaster       encourage them to develop    
                          planning guidance      and submit disaster plans    
                          address the dispersion for review.                  
                          of children and        
                          families within and    
                          across state lines.    
                          This guidance should   
                          include information on 
                          o  preserving child    
                          welfare records,       
                          identifying children   
                          who may be dispersed,  
                          o  identifying new     
                          child welfare cases    
                          and providing          
                          services,              
                          o  coordinating        
                          services and sharing   
                          information with other 
                          states, and placing    
                          children from other    
                          states.                
                          o  Develop and provide 
                          training on child      
                          welfare disaster       
                          planning to all        
                          states.                
                                                 
                       Recommendations to        
                       Congress:                 
                                                 
                       To ensure continuity of   
                       services within or across 
                       state lines for the       
                       children under state      
                       care, Congress should     
                       consider requiring that   
                       states develop and submit 
                       child welfare disaster    
                       plans for HHS review.     
SMALL BUSINESS      In order to provide more  SBA stated that it generally 
ADMINISTRATION:     timely disaster           agreed with our              
ACTIONS NEEDED TO   assistance in the future, recommendations and intended 
PROVIDE MORE TIMELY we recommend that the     to improve the delivery of   
DISASTER            Administrator of SBA      the Disaster Loan Program    
ASSISTANCE,         direct its Office of      for events of all sizes.     
GAO-06-860          Disaster Assistance to    However, SBA disagreed with  
                       take the following four   some of the findings and     
                       actions:                  conclusions in our draft     
                                                 report.                      
                          o  Reassess the        
                          Disaster Credit        
                          Management System      
                          (DCMS) maximum user    
                          capacity and related   
                          loan processing        
                          resource needs based   
                          on such things as      
                          lessons learned from   
                          the Gulf Coast         
                          hurricanes, a review   
                          of information         
                          available from         
                          catastrophe risk       
                          modeling firms and     
                          disaster simulations,  
                          and related cost       
                          considerations.        
                          o  Conduct complete    
                          stress testing to      
                          ensure that DCMS can   
                          function at planned    
                          for maximum user       
                          capacity levels.       
                          o  Improve management  
                          controls over          
                          assessing contractor   
                          performance through    
                          inspections of all     
                          equipment purchased or 
                          leased to support      
                          DCMS.                  
                          o  Expedite plans to   
                          resume business        
                          processing             
                          reengineering efforts  
                          to analyze the         
                          disaster loan process  
                          and identify ways to   
                          more efficiently       
                          process loan           
                          applications,          
                          including an           
                          evaluation of the      
                          feasibility of         
                          implementing a secure  
                          Internet-based         
                          application feature    
                          for home loan          
                          applicants.            
Title and GAO       Summary of                Agency response              
product number      recommendations           
Disaster            Recommendations to the    DHS stated that it will take 
Evacuations:        Secretary of Homeland     our recommendations under    
Limitation in       Security:                 advisement as it reviews the 
Federal Assistance                            National Response Plan.      
to Health           To address limitations in According to DHS, all of the 
Facilities for      how the federal           NDMS federal partners are    
Transportation      government provides       currently reviewing the NDMS 
Should be           assistance with the       memorandum of agreement with 
Addressed,          evacuation of health care a view towards working with  
GAO-06-826          facilities, we recommend  state and local partners to  
                       that the Secretary of     alter, delineate, and        
                       Homeland Security take    otherwise clarify roles and  
                       the following two         responsibilities as          
                       actions:                  appropriate. However, we     
                                                 noted that, as stated in the 
                          o  Clearly delineate   draft report, neither NDMS   
                          how the federal        documents, the NRP, nor the  
                          government will assist draft Catastrophic Incident  
                          state and local        Supplement to the NRP-to be  
                          governments with the   used in cases when the       
                          movement of patients'  capabilities of state and    
                          and residents out of   local governments are almost 
                          hospitals and nursing  immediately                  
                          homes to a             overwhelmed-describe the     
                          mobilization center    federal role in coordinating 
                          where National         with state and local         
                          Disaster Medical       authorities during hospital  
                          System (NDMS)          and nursing home             
                          transportation begins. evacuations. We also noted   
                          o  In consultation     that reliance on state and   
                          with the other NDMS    local resources was          
                          federal partners-the   inadequate when multiple     
                          Secretaries of         facilities in a community    
                          Defense, Health and    had to evacuate              
                          Human Services, and    simultaneously.              
                          Veterans                                            
                          Affairs-clearly        DOD disagreed with our       
                          delineate how to       conclusions concerning the   
                          address the needs of   federal role in short        
                          nursing home residents distance transportation and  
                          during evacuations,    the successful evacuation of 
                          including the          nursing home residents       
                          arrangements necessary during Hurricane Rita.       
                          to relocate these      However, during a            
                          residents.             catastrophic incident, the   
                                                 capabilities of state and    
                                                 local governments may almost 
                                                 immediately become           
                                                 overwhelmed. As we stated    
                                                 above in our response to     
                                                 DHS's comments, the federal  
                                                 role in these situations has 
                                                 not been described. Second,  
                                                 Our draft report did         
                                                 describe NDMS's evacuation   
                                                 of people, including nursing 
                                                 home residents. However, we  
                                                 also noted that the NDMS     
                                                 after-action report on       
                                                 hurricanes Katrina and Rita  
                                                 states that NDMS was not     
                                                 optimally prepared to manage 
                                                 the nursing home             
                                                 requirements of evacuees who 
                                                 did not require              
                                                 hospitalization. For this    
                                                 reason, we believe that      
                                                 explicit consideration of    
                                                 the needs of nursing home    
                                                 residents is warranted.      
                                                                              
                                                 HHS and Veterans Affairs     
                                                 concurred with our           
                                                 recommendations.             
Continuity of       Recommendations to the    DHS partially agreed and     
Operations:         Secretary of Homeland     stated that FEMA would be    
Selected Agencies   Security:                 conducting assessments of    
Could Improve                                 the six agencies in          
Planning for Use of To improve the assessment conjunction with its         
Alternate           and oversight of agency   upcoming interagency         
Facilities and      continuity planning and   exercise.                    
Telework during     developing guidance on                                 
Disruptions,        including telework in     DHS stated that FEMA         
GAO-06-713          such planning, and to     currently has an assessment  
                       ensure that agencies are  program and a methodology    
                       adequately prepared to    that includes (1) a          
                       continue performing       self-assessment tool to      
                       essential functions       assist senior leaders in     
                       following an emergency,   performing internal          
                       the Secretary of Homeland assessments, (2) the         
                       Security should direct    government wide exercise     
                       the Undersecretary for    planned for June 2006, and   
                       Federal Emergency         (3) a plan for an expanded   
                       Management to:            comprehensive department and 
                                                 agency assessment program.   
                          o  Before the upcoming DHS stated that the agency's 
                          interagency exercise,  efforts are constrained by   
                          conduct an assessment  resources, and that          
                          of the continuity of   additional resources are     
                          operations plans of    required to support the      
                          the six agencies whose large number of federal      
                          alternate facilities   offices and facilities that  
                          were included in our   could benefit from recurring 
                          review and report any  continuity of operations     
                          deficiencies to the    planning assessments.        
                          head of the agency for                              
                          correction.            While these steps outline an 
                          o  Develop a           overall approach to          
                          methodology for        assessing agency plans, they 
                          individual agency      do not constitute a          
                          continuity of          methodology for assessing    
                          operations plan        agency compliance with FPC   
                          assessments that       65. Without such a           
                          independently          methodology, the agency will 
                          evaluates executive    have limited assurance that  
                          branch agencies'       agencies have taken the      
                          compliance with        necessary steps to prepare   
                          Federal Preparedness   for an emergency.            
                          Circular (FPC) 65,                                  
                          including the extent   In responding to our         
                          to which agencies (1)  recommendation on developing 
                          identify essential     guidance on agencies' use of 
                          functions; (2)         telework, DHS partially      
                          identify the levels of agreed and stated that FEMA  
                          staff and resources    will coordinate with OPM in  
                          required at their      the development of a         
                          alternate facilities;  timeline for further         
                          and (3) plan, conduct, telework guidance. However,  
                          and document the       as stated in our report,     
                          necessary tests and    present guidance does not    
                          exercises at the       address the preparations     
                          appropriate scope and  agencies should make for     
                          frequency. The         using telework during        
                          methodology should     emergencies and it is        
                          include a mechanism    unclear whether and when     
                          for reporting any      FEMA will release such       
                          deficiencies to the    guidance.                    
                          head of the agency for 
                          correction.            
                          o  Establish a         
                          timeline for           
                          developing, in         
                          consultation with the  
                          Office of Personnel    
                          Management (OPM),      
                          guidance on the steps  
                          that agencies should   
                          take to adequately     
                          prepare for the use of 
                          telework during a      
                          continuity of          
                          operations event.      
Hurricanes Katrina  Recommendations to the    DHS did not provide a        
and Rita:           Secretary of Homeland     response to our              
Coordination        Security:                 recommendations, noting that 
between FEMA and                              FEMA was actively preparing  
the Red Cross       To clarify roles and      for the hurricane season.    
Should Be Improved  responsibilities within                                
for the 2006        ESF-6 for the 2006        Overall, the Red Cross       
Hurricane Season,   hurricane season and to   agreed with our conclusion   
GAO-06-712          help ensure that FEMA's   that coordination between    
                       resource tracking system  FEMA and the Red Cross could 
                       will meet the needs of    be improved for the 2006     
                       those requesting FEMA     hurricane season. The Red    
                       assistance, the Secretary Cross also highlighted       
                       of DHS should             actions under way with       
                                                 respect to our first two     
                          o  Direct FEMA to work recommendations. With        
                          with the Interim       respect to our               
                          President and Chief    recommendation about         
                          Executive Officer of   staffing strategies, the Red 
                          the Red Cross as soon  Cross said that it is in the 
                          as possible to reach   process of hiring ESF-6      
                          agreement on the       reservists who will be       
                          operating procedures   deployed for extended        
                          that they will both    periods of time to perform   
                          use in the event of an Red Cross ESF-6 mass care    
                          incident of national   functions at the federal     
                          significance. Given    level.                       
                          the lack of progress   
                          FEMA and the Red Cross 
                          have made thus far in  
                          reaching agreement on  
                          the operating          
                          procedures and that    
                          the new hurricane      
                          season is beginning,   
                          they may wish to use   
                          mediation to speed the 
                          agreement.             
                                                 
                       Direct FEMA to ensure     
                       that it obtains input     
                       from the Red Cross as it  
                       develops a resource       
                       tracking system.          
                                                 
                          o  Recommendations to  
                          the Interim President  
                          and Chief Executive    
                          Officer of the Red     
                          Cross:                 
                          o  Implement ESF-6     
                          staffing strategies    
                          that better facilitate 
                          the development of     
                          working relationships  
                          and retain             
                          institutional          
                          knowledge.             

Title and GAO                                                              
product number   Summary of recommendations     Agency response
Expedited        Recommendations to the         DHS and FEMA concurred     
Assistance for   Secretary of Homeland          fully with four of our six 
Victims of       Security:                      recommendations, and       
Hurricanes                                      partially concurred with   
Katrina and      That the Secretary of Homeland the remaining two          
Rita: FEMA's     Security directs               recommendations. FEMA and  
Control          Undersecretary for Federal     DHS concurred fully that   
Weaknesses       Emergency Management to take   FEMA (1) improve           
Exposed the      six actions to address the     procedures to review       
Government to    weaknesses we identified in    registrations containing   
Significant      the administration of          the same SSNs and other    
Fraud and Abuse, Individuals and Households     duplicate information; (2) 
GAO-06-655       Program (IHP).                 subject all registration   
                                                   addresses to verification  
                       o  Establish an identity    during the registration    
                       verification process for    process; (3) explore       
                       IHP registrants applying    entering into agreements   
                       via both the Internet and   with other agencies, such  
                       telephone, to provide       as the Social Security     
                       reasonable assurance that   Administration, to         
                       disaster assistance         periodically authenticate  
                       payments are made only to   IHP information; and (4)   
                       qualified individuals.      issue proper instructions  
                       Within this process         to any future debit card   
                                                   recipients. FEMA and DHS   
                               o  establish        stated that they have      
                               detailed criteria   already taken actions to   
                               for registration    address these              
                               and provide clear   recommendations. These     
                               instructions to     actions include            
                               registrants on the  instituting an Internet    
                               identification      application process that   
                               information         will prevent all duplicate 
                               required,           registrations from the     
                               o  create a field   Internet, implementing     
                               within the          procedures so that call    
                               registration that   centers will no longer     
                               asks registrants to accept duplicate           
                               provide their name  registrations with the     
                               exactly as it       same SSN in the same       
                               appears on their    disaster, and conducting   
                               social security     conference calls and       
                               card in order to    conducting data sharing    
                               prevent name and    tests with the Social      
                               social security     Security Administration.   
                               number (SSN)        In addition, DHS and FEMA  
                               mismatches,         stated that, starting in   
                               o  fully field test June 2006, all             
                               the identity        registration addresses     
                               verification        (even phone-in) will be    
                               process prior to    subjected to an online     
                               implementation,     verification during the    
                               o  ensure that call registration process.      
                               center employees    While these are steps in   
                               give real-time      the right direction, we    
                               feedback to         will follow up on whether  
                               registrants on      the actions taken fully    
                               whether their       address our                
                               identities have     recommendations.           
                               been validated, and                            
                               o  establish a      FEMA and DHS partially     
                               process that uses   concurred with our         
                               alternative means   recommendation concerning  
                               of identity         duplicate payments. FEMA   
                               verification to     and DHS took exception     
                               expeditiously       with our categorization of 
                               handle legitimate   some payments as being     
                               applicants that are potential duplicates, and  
                               rejected by         with our assessment that   
                               identity            they should initiate       
                               verification        actions to collect         
                               controls.           duplicate Expedited        
                                                   Assistance payments.       
                       o  Develop procedures to    However, for all our case  
                       improve the existing review study examples, we         
                       process of duplicate        conducted further          
                       registrations containing    investigative work to      
                       the exact same SSN and to   confirm that the payments  
                       identify the reasons why    were made to actual        
                       registrations flagged as    duplicates, not covered by 
                       invalid or as potential     the separated household    
                       duplicates have been        policy, and were therefore 
                       overridden and approved for improper payments. As for  
                       payment.                    initiating actions to      
                       o  Establish an address     collect duplicate          
                       verification process for    payments, DHS and FEMA     
                       IHP registrants applying    stated that they had       
                       via both the Internet and   processed for recoupment   
                       telephone, to provide       nearly all the payments    
                       reasonable assurance that   they believed were         
                       disaster assistance         duplicates as of April 1,  
                       payments are made only to   2006. While we have not    
                       qualified individuals.      assessed the effectiveness 
                       Within this process         of FEMA's recoupment       
                                                   process, we continue to    
                               o  create a uniform believe that FEMA should   
                               method to input     attempt to recoup as many  
                               street names and    dollars of improper        
                               numbers and         payments as possible,      
                               apartment numbers   including those duplicate  
                               into the            payments that we           
                               registration,       identified that FEMA       
                               o  institute        questioned.                
                               procedures to check                            
                               IHP registration    Going forward it will be   
                               damaged addresses   important for FEMA to      
                               against publicly    establish effective        
                               available address   controls to prevent        
                               databases so that   fraudulent and improper    
                               payments are not    payments before they       
                               made based on bogus occur, because fraud       
                               property addresses, prevention is a far more   
                               o  fully field test effective control than     
                               the address         detecting improper and     
                               verification        potentially fraudulent     
                               process prior to    payments after they are    
                               implementation,     made. Our experience with  
                               o  ensure that call organizations that rely on 
                               center employees    a process that attempts to 
                               can give real time  detect improper and        
                               feedback to         potentially fraudulent     
                               registrants on      payments after they are    
                               whether addresses   made is that the           
                               have been           organization recovers only 
                               validated, and      a fraction of the payments 
                               o  establish a      that should not have been  
                               process that uses   made.                      
                               alternative means   
                               of address          
                               verification to     
                               expeditiously       
                               handle legitimate   
                               applicants that are 
                               rejected by address 
                               verification        
                               controls.           
                                                   
                       o  Explore entering into an 
                       agreement with other        
                       agencies, such as the       
                       Social Security             
                       Administration, to          
                       periodically authenticate   
                       information contained in    
                       IHP registrations.          
                       o  Establish procedures to  
                       collect duplicate expedited 
                       assistance payments or to   
                       offset these amounts        
                       against future payments.    
                       Such duplicate payments     
                       include                     
                                                   
                               o  the payments     
                               made to IHP         
                               recipients who      
                               improperly received 
                               the $2,000 debit    
                               cards and an        
                               additional $2,000   
                               Expedited           
                               Assistance check or 
                               Electronic Funds    
                               Transfer, and       
                               o  the thousands of 
                               duplicate Expedited 
                               Assistance payments 
                               made to the same    
                               IHP registration    
                               number.             
                                                   
                       o  Ensure that any future   
                       distribution of IHP debit   
                       cards includes instructions 
                       on the proper use of IHP    
                       funds, similar to those     
                       instructions provided to    
                       IHP check and Electronic    
                       Funds Transfer recipients,  
                       to prevent improper usage.  

Title and GAO                                                              
product number  Summary of recommendations      Agency response
Hurricane       Recommendations to the          DOD commented on our four  
Katrina: Better Secretary of Defense:           recommendations, partially 
Plans and                                       concurring with each of    
Exercises       To improve the military         them. With respect to our  
Needed to Guide response to catastrophic        first recommendation-to    
the Military's  disasters, the Secretary of     revise the NRP to fully    
Response to     Defense should                  address the proactive      
Catastrophic                                    functions that the         
Natural            o  Provide proposed          military will be expected  
Disasters,         revisions of the NRP to the  to perform during a        
GAO-06-643         Secretary of the Department  catastrophic incident-DOD  
                      of Homeland Security that    said that proactive        
                      addresses the proactive      military functions can be  
                      functions the military is    identified in all 15 major 
                      expected to make during a    disaster scenarios and     
                      catastrophic incident.       said it is working with    
                      o  Establish milestones and  the Department of Homeland 
                      expedite the development of  Security to revise the     
                      detailed plans and exercises NRP. While DOD stated that 
                      to fully account for the     the long-term focus of the 
                      unique capabilities and      U.S. government should be  
                      support that the military is to develop more robust     
                      likely to provide to civil   domestic disaster          
                      authorities in response to   capabilities within the    
                      the full range of domestic   Department of Homeland     
                      disasters, including         Security, it acknowledged  
                      catastrophes. The plans and  that DOD will need to      
                      exercises should             assume a more robust       
                      specifically address the     response role in the       
                                                   interim period and when    
                              o  use of            other responders lack the  
                              reconnaissance       resources and expertise to 
                              capabilities to      handle a particular        
                              assess damage,       disaster.                  
                              o  use of                                       
                              communications       With respect to our second 
                              capabilities to      recommendation that        
                              facilitate support   concerned the development  
                              to civil             of detailed plans and      
                              authorities,         exercises, DOD listed a    
                              o  integration of    number of steps it is      
                              active component and taking to improve its      
                              National Guard and   disaster response planning 
                              Reserve forces,      and exercises and said     
                              o  use of search and that consistent with its   
                              rescue capabilities  Strategy for Homeland      
                              and the military's   Defense and Civil Support  
                              role in search and   the active component       
                              rescue, and          should complement, but not 
                              o  role the military duplicate, the National    
                              might be expected to Guard's likely role as an  
                              play in logistics.   early responder. On June   
                                                   27, 2006, the Assistant    
                      o  Direct the Chief of the   Secretary of Defense for   
                      National Guard Bureau to     Homeland Defense sent      
                      work with the state          DOD's final response,      
                      governors and adjutants      listing some               
                      general to develop and       recently-completed         
                      maintain a list of the types exercises as well as steps 
                      of capabilities the National that DOD was taking to     
                      Guard will likely provide in enhance interagency        
                      response to domestic natural planning efforts.          
                      disasters under                                         
                      state-to-state mutual        DOD also partially         
                      assistance agreements along  concurred with our third   
                      with the associated units    recommendation-that the    
                      that could provide these     Chief of the National      
                      capabilities. This           Guard Bureau work with the 
                      information should be made   state governors and        
                      available to the Northern    adjutants general to       
                      Command, U.S. Joint Forces   develop and maintain a     
                      Command, and other           list of the types of       
                      organizations with federal   capabilities the National  
                      military support to civil    Guard will likely provide  
                      authority planning           in response to domestic    
                      responsibilities.            natural disasters under    
                      o  Establish milestones and  state-to-state mutual      
                      identify the types of        assistance agreements.     
                      scalable federal military                               
                      capabilities and the units   Finally, DOD partially     
                      that could provide those     concurred with our         
                      capabilities in response to  recommendation that it     
                      the full range of domestic   identify the types of      
                      disasters and catastrophes   scalable federal military  
                      covered by DOD's defense     capabilities and units     
                      support to civil             that will provide those    
                      authorities' plans.          capabilities in response   
                                                   to the full range of       
                   Matters for Congressional       domestic disasters and     
                   Consideration:                  catastrophes. In its final 
                                                   response to our report,    
                   In a 1993 report we suggested   DOD stated it had analyzed 
                   that Congress consider removing potential gaps between     
                   the statutory restriction on    state and other federal    
                   DOD's authority to              agency response, and had   
                   involuntarily activate Reserve  developed 18 pre-scripted  
                   units for catastrophic disaster mission assignments to     
                   relief. In view of the          address DOD support to     
                   significant military downsizing FEMA, and had validated    
                   that has occurred since we      these assignments during   
                   first raised this matter and    an exercise. DOD also      
                   the need to actively engage the reported that it had       
                   total force in order to meet    developed scalable         
                   missions at home and abroad, we capability packages in     
                   continue to believe that        conjunctions with U.S.     
                   Congress should consider        Northern Command's         
                   lifting or modifying the        contingency plan for       
                   mobilization restriction-10     defense support to civil   
                   U.S.C. S:12304 (c)(1)-that      authorities, and it was    
                   limits reserve component        staffing forces to         
                   participation in catastrophic   accelerate                 
                   natural disasters.              force/capabilities         
                                                   necessary to support a     
                                                   catastrophic event.        

Title and GAO                                                              
product number     Summary of recommendations     Agency response
U.S. Tsunami       Recommendations to the         Commerce, representing   
Preparedness:      Secretary of Commerce:         NOAA, concurred with all 
Federal and State                                 six recommendations.     
Partners           To help improve national       However, in NOAA         
Collaborate to     tsunami preparedness, the      suggested a revision to  
Help Communities   Secretary of Commerce should   one of the               
Reduce Potential   direct the National            recommendations with     
Impacts, but       Oceanographic and Atmospheric  which we disagree. In    
Significant        Administration (NOAA)          response to our          
Challenges Remain, Administrator to take the      recommendation that NOAA 
GAO-06-519         following six actions          evaluate the Tsunami     
                                                     Ready program to         
                         o  Work with the FEMA       determine what barriers, 
                         Director and the United     if any, exist to         
                         States Geological Survey    participation and what   
                         (USGS) Director to create   modifications are needed 
                         standardized tsunami loss   to encourage more        
                         estimation software to help high-risk communities to 
                         communities determine the   participate, NOAA        
                         potential impact of         suggested changing the   
                         tsunamis and identify       recommendation's focus   
                         appropriate mitigation      from "high-risk" to      
                         actions.                    "at-risk" communities.   
                         o  Reduce the number of     According to NOAA all    
                         tsunami warning false       U.S. coastal communities 
                         alarms by (1) completing    should be prepared for a 
                         the planned expansion of    tsunami no matter how    
                         tsunami detection stations; rare. While we agree     
                         (2) reexamining NWS rules   that preparing all U.S.  
                         dictating when a warning    coastal communities for  
                         will be issued and to which a tsunami may be a       
                         areas; (3) establishing a   laudable long-term goal, 
                         routine process for other   given the agency's       
                         federal and state experts   limited resources, it    
                         to formally review and      may be an unrealistic    
                         comment on the centers' use goal in the short-term.  
                         of seismic data; and (4)    Therefore, we believe    
                         setting performance goals   that NOAA should use a   
                         to guide improvements.      risk-based approach and  
                         o  Work with the states to  target initial           
                         conduct periodic end-to-end participation in the     
                         tests of the tsunami        Tsunami-Ready program to 
                         warning system, including   those communities that   
                         NOAA Weather Radio and the  face the greatest risk.  
                         Emergency Alert System, to  Homeland Security,       
                         ensure the system will      representing FEMA,       
                         function as intended during commented on one of the  
                         a tsunami emergency.        six recommendations and  
                         o  Evaluate the Tsunami     indicated that while it  
                         Ready program to determine  concurred with the       
                         what barriers, if any,      recommendation, that     
                         exist to participation and  NOAA work with FEMA and  
                         what modifications are      USGS to create           
                         needed to encourage more    standardized tsunami     
                         high-risk communities to    loss estimation          
                         participate.                software, it was         
                         o  Evaluate the National    concerned that FEMA did  
                         Tsunami Hazard Mitigation   not have the funding or  
                         Program to determine what   the staff resources to   
                         has worked well in the past pursue such a request    
                         and what high priority      and that such a request  
                         activities remain to be     from NOAA would have to  
                         completed and to help       address these resource   
                         inform strategic planning   needs.                   
                         efforts.                                             
                         o  Develop comprehensive    The Department of the    
                         risk-based strategic plans  Interior commented that  
                         for the Tsunami Program and the report was a         
                         National Tsunami Hazard     thorough,                
                         Mitigation Program that     well-researched          
                         consider input from states  examination of the       
                         and federal partners and    nation's tsunami warning 
                         include metrics for         system and that it       
                         measuring progress toward   correctly recognizes the 
                         achieving program goals.    need for close           
                                                     collaboration at the     
                                                     federal, state, and      
                                                     local levels to have an  
                                                     effective tsunami        
                                                     warning system. Interior 
                                                     also said that it        
                                                     supports the need for a  
                                                     risk-based approach to   
                                                     prioritizing federal     
                                                     investments in this      
                                                     system and is actively   
                                                     collaborating with NOAA  
                                                     to provide the hazard    
                                                     assessments necessary    
                                                     for such an approach.    
Hurricane Katrina: Recommendations to the         DOD and DHS generally    
Comprehensive      Secretary of Homeland          agreed with our          
Policies and       Security:                      recommendations. DHS     
Procedures Are                                    noted that, in some      
Needed to Ensure   To help ensure that the        cases, actions were      
Appropriate Use of cognizant agencies fulfill     already underway to      
and Accountability their responsibility to        address the              
for International  account for and effectively    recommendations. Both    
Assistance,        manage foreign donations and   made suggestions to      
GAO-06-460         maintain adequate internal     clarify the wording, and 
                      controls over government       we adjusted the          
                      resources, the Secretary of    recommendations based on 
                      Homeland Security, in          their suggestions.       
                      consultation with the          
                      Secretary, Department of       
                      State, should:                 
                                                     
                         o  Establish within the     
                         NRP-or other appropriate    
                         plans-clearly delineated    
                         policies and procedures for 
                         the acceptance, receipt,    
                         and distribution of         
                         international assistance.   
                         o  Incorporate the          
                         following actions and       
                         procedures into their       
                         guidance:                   
                                                     
                                 o  Develop          
                                 policies,           
                                 procedures, and     
                                 plans to help       
                                 ensure              
                                 international cash  
                                 donations for       
                                 disaster relief and 
                                 assistance are      
                                 accepted and used   
                                 appropriately as    
                                 needed,             
                                 o  Place            
                                 international cash  
                                 donations in an     
                                 account that would  
                                 pay interest while  
                                 decisions are       
                                 pending on their    
                                 use to maintain the 
                                 purchasing power of 
                                 those donations,    
                                 o  Maintain         
                                 oversight of        
                                 foreign donated     
                                 in-kind assets by   
                                 tracking them from  
                                 receipt to          
                                 disbursement, to    
                                 reasonably ensure   
                                 that assistance is  
                                 delivered where it  
                                 is intended, and    
                                 o  Establish plans  
                                 for the acceptance  
                                 of foreign-donated  
                                 items that include  
                                 coordinating with   
                                 regulatory          
                                 agencies, such as   
                                 US Department of    
                                 Agriculture and     
                                 Food and Drug       
                                 Administration, in  
                                 advance, in order   
                                 to prevent the      
                                 acceptance of items 
                                 that are prohibited 
                                 from distribution   
                                 in the United       
                                 States regardless   
                                 of waivers that     
                                 might be            
                                 established to      
                                 expedite the        
                                 importing of        
                                 foreign assistance; 
                                 these plans should  
                                 also include        
                                 Department of State 
                                 obtaining           
                                 information on      
                                 acceptable or       
                                 unacceptable items  
                                 in order to         
                                 communicate to the  
                                 international       
                                 community what is   
                                 needed or what can  
                                 not be accepted.    
                                                     
                      Recommendations to the         
                      Secretary of Defense:          
                                                     
                      The Secretary of Defense, in   
                      consultation with the          
                      Secretaries of State and       
                      Homeland Security, should:     
                                                     
                         o  Establish within the     
                         NRP-or other appropriate    
                         plans-clearly delineated    
                         policies and procedures to  
                         ensure that foreign         
                         military offers of          
                         assistance for domestic     
                         disasters are coordinated   
                         through the Department of   
                         State to ensure they are    
                         properly accepted and       
                         safeguarded and used as     
                         intended.                   
                                                     
                      Develop and issue internal DOD 
                      guidance to commanders on the  
                      agreed-upon process to         
                      coordinate assistance through  
                      Department of State.           
Federal Emergency  Recommendations to the         FEMA offered comments    
Management Agency: Secretary of Homeland          principally in three     
Improvements       Security:                      areas: (1) its           
Needed to Enhance                                 disappointment that we   
Oversight and      To improve FEMA's oversight    had not directly         
Management of the  and management of the NFIP and addressed the issue of   
National Flood     make it more actuarially       whether Congress         
Insurance Program, sound, we recommend that the   intended the flood       
GAO-06-119 ;       Secretary of the Department of insurance program to     
Future Financial   Homeland Security direct the   restore damaged property 
Stability of the   Undersecretary for Emergency   to its pre-flood         
National Flood     Preparedness and Response to:  condition; (2) its view  
Insurance Program,                                that the method of       
GAO-06-174T ; and     o  Use a methodologically   choosing its sample for  
Oversight and         valid approach to draw      operational reviews was  
Management of the     statistically               appropriate and that its 
National Flood        representative samples of   financial and internal   
Insurance Program,    claims for underwriting and controls are             
GAO-06-183T           claims portions of          wide-ranging and include 
                         operational reviews and for processes that we did    
                         quality assurance           not address; and (3) its 
                         re-inspections of claims by view that contrary to    
                         general adjusters.          the impression given in  
                         o  Develop documented plans our draft report, FEMA   
                         with milestones for         has worked diligently to 
                         implementing requirements   implement the            
                         of the Flood Insurance      requirements of the      
                         Reform Act of 2004 to       Flood Insurance Reform   
                         provide policyholders with  Act of 2004.             
                         a flood insurance claims                             
                         handbook that meets         We responded that (1) we 
                         statutory requirements, to  believed that we have    
                         establish a regulatory      addressed the issue of   
                         appeals process, and to     congressional intent     
                         ensure that insurance       consistent with our      
                         agents meet minimum NFIP    statutory mandate by     
                         education and training      explaining the statutory 
                         requirements.               and regulatory           
                                                     provisions that affect   
                                                     both dollar ceilings and 
                                                     other coverage           
                                                     limitations; (2) FEMA's  
                                                     sampling and internal    
                                                     controls still did not   
                                                     provide management with  
                                                     the information needed   
                                                     to assess the overall    
                                                     performance of           
                                                     companies, the overall   
                                                     accuracy of the          
                                                     underwriting of NFIP     
                                                     policies and the         
                                                     adjustment of            
                                                     claims-information that  
                                                     FEMA needs to have       
                                                     reasonable assurance     
                                                     that program objectives  
                                                     are being achieved; and  
                                                     (3) we described several 
                                                     actions FEMA had taken   
                                                     in its efforts to comply 
                                                     with the act, while      
                                                     noting that it had not   
                                                     fully implemented the    
                                                     act's requirements.      

Source: GAO analysis.

aAn open recommendation is one that the agency has not fully implemented.

Table 6: New GAO Recommendations Formalized in this Report

We are making several additional recommendations regarding preparedness,   
response, and recovery:                                                    
                                                                              
Recommendations to the Secretary of Homeland Security:                     
                                                                              
The Secretary should:                                                      
                                                                              
      o  Rigorously re-test, train, and exercise its recent clarification of  
      the roles, responsibilities, and lines of authority for all levels of   
      leadership, implementing changes needed to remedy identified            
      coordination problems.                                                  
      o  Direct that the NRP base plan and its Catastrophic Incident Annex be 
      supported by more robust and detailed operational implementation plans, 
      particularly the Catastrophic Incident Supplement to the NRP. Such      
      operational plans should, for example, further define and leverage      
      those military capabilities that might be needed in a catastrophic      
      disaster.                                                               
      o  Provide guidance and direction for federal, state, and local         
      planning, training, and exercises to ensure such activities fully       
      support preparedness, response, and recovery responsibilities at a      
      jurisdictional and regional basis. This should also include the         
      application of lessons learned from actual catastrophic and other       
      disasters.                                                              
      o  Take the lead in monitoring federal agencies' efforts to meet their  
      responsibilities under the NRP and the interim National Preparedness    
      Goal, including the development, testing, and exercising of agency      
      operational plans to implement their responsibilities under the NRP,    
      NIMS, and the National Preparedness Goal.                               
      o  Given that resources are finite, apply an all-hazards risk           
      management approach in deciding whether and how to invest in specific   
      capabilities for a catastrophic disaster.                               
      o  Provide guidance on advance procurement practices and procedures for 
      those federal agencies with roles and responsibilities under the NRP,   
      so that these agencies can better manage disaster-related procurements. 
      These practices should be in advance of disasters, ongoing and          
      continuous, and include (1) developing knowledge of contractor          
      capabilities, and available commodities, services and prices as well as 
      developing pre-established vendor relationships, on a competitive basis 
      whenever feasible; (2) establishing scalable operations plans to adjust 
      the level of capacity needed to respond; (3) formally assigning and     
      communicating disaster-related responsibilities and, where feasible,    
      incorporating necessary training; and (4) providing sufficient numbers  
      of field-level contracting staff to meet mission requirements. DHS      
      should also establish an assessment process to monitor agencies'        
      continuous planning efforts for their disaster related procurement      
      needs and the maintenance of capabilities.                              
                                                                              
Matter for Congressional Consideration:                                    
                                                                              
      o  We again recommend, as we did in 1993 in the aftermath of Hurricane  
      Andrew, that Congress give federal agencies explicit authority to take  
      actions to prepare for catastrophic disasters when there is warning.    

Source: GAO analysis.

Appendix II: Comments from the Department of Homeland Security

Appendix III: Comments from the Small Business Administration

Appendix IV: A Appendix IV: GAO Contact and Staff Acknowledgments

GAO Contact

Norman Rabkin, Managing Director, GAO Homeland Security and Justice Issues
Team, (202)-512-8777 ( [email protected] )

Acknowledgments

In addition to the contact named above the following individuals from
GAO's Homeland Security and Justice Team also made contributions to this
report: William O. Jenkins Jr., Director; Sharon Caudle, Assistant
Director; John Vocino, Analyst-In-Charge; Daniel Rodriguez; Kathryn
Godfrey; and Christine Davis, GAO Office of General Counsel.

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Hurricane Katrina: Improving Federal Contracting Practices in Disaster
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Hurricane Katrina: Planning for and Management of Federal Disaster
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(440504)

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and methodology, click on the link above.

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Highlights of GAO-06-618 , a report to congressional committees

September 2006

CATASTROPHIC DISASTERS

Enhanced Leadership, Capabilities, and Accountability Controls Will
Improve the Effectiveness of the Nation's Preparedness, Response, and
Recovery System

Hurricane Katrina was the largest, most destructive natural disaster in
our nation's history. The problems experienced in responding to Katrina
resulted in a number of investigations-by congressional committees, the
White House Homeland Security Council, and others--regarding the
preparations for and response to Katrina. GAO assisted the congressional
investigations and, under the Comptroller General's authority, initiated a
number of Katrina-related reviews. In March 2006 testimony, GAO provided
its preliminary observations to Congress.

The purpose of this report is to summarize what went well and why, what
did not go well and why, and what changes are needed to improve the
nation's readiness to respond to a catastrophic disaster; and to identify
selected issues associated with the Gulf Coast's recovery. This report is
based on GAO's prior work on catastrophic disasters, including Hurricane
Andrew in 1992, the over 30 GAO reports completed to date on Hurricanes
Katrina and Rita, ongoing GAO work, and other Hurricane Katrina reviews
and lessons learned.

What GAO Recommends

This report includes six recommendations to the Secretary of Homeland
Security with which DHS generally agreed, describing actions taken to
implement them. The report also includes a matter for congressional
consideration.

Hurricane Katrina was a catastrophic disaster whose scope and destruction
severely tested all levels of governments in the affected areas and the
nation as a whole. It almost immediately overwhelmed state and local first
responders, and the response required outside action and support from many
sources. The heroic efforts by many saved thousands of lives. The federal
government, many states, local governments, plus nonprofit and private
sector organizations provided substantial personnel and resources to
assist in the response, but these proved insufficient to meet the
immediate challenges posed by Hurricane Katrina's effects.

The three basic elements in preparing for, responding to and recovering
from any catastrophic disaster are (1) leadership; (2) capabilities; and
(3) accountability. Leadership in the form of legal authorities, roles and
responsibilities, and lines of authority at all levels of government must
be clearly defined, effectively communicated, and well understood in order
to facilitate rapid and effective decision making. DHS has made revisions
to the National Response Plan designed to further clarify federal roles
and responsibilities, but their effect has not yet been tested in an
actual disaster.

Developing the capabilities needed for catastrophic disasters should be
part of an overall national effort designed to integrate and define what
needs to be done, where, by whom, and how well. Ensuring needed
capabilities are ready requires effective planning and coordination, plus
robust training and exercises in which the capabilities are realistically
tested, problems identified, and subsequently addressed in partnership
with federal, state, local, and nongovernmental stakeholders. In addition,
integrating an all-hazards risk management framework into decision making
is central to assessing catastrophic disaster risks and guiding the
development of national capabilities to prevent or mitigate where possible
and respond to such risks. DHS has announced a number of actions to
improve readiness and response for catastrophic disasters, but there is
little information available on the extent to which these changes are
operational.

Accountability controls and mechanisms ensure that resources are used
appropriately for valid purposes. Following a catastrophic disaster,
decision-makers face a tension between the demand for rapid response and
recovery assistance-including assistance to victims-and implementing
appropriate controls and accountability mechanisms. Our work and that of
others found, for example, the processes for confirming disaster victims'
eligibility for assistance were insufficient and resulted in millions of
dollars in questionable payments to fraudulent claimants. Also, some
contracts had insufficient provisions to ensure that prices were fair and
reasonable. DHS has reported that it has taken steps to address some of
the concerns, including working to complete more contracts for key
services in advance of a disaster and improving its ability to verify
individual claimant eligibility for disaster benefits and assistance.
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