Continuity of Operations: Agencies Could Improve Planning for	 
Telework during Disruptions (11-MAY-06, GAO-06-740T).		 
                                                                 
To ensure that essential government services are available in	 
emergencies, federal agencies are required to develop continuity 
of operations (COOP) plans. The Federal Emergency Management	 
Agency (FEMA), within the Department of Homeland Security (DHS), 
is responsible for providing guidance to agencies on developing  
such plans. Its guidance states that in their continuity	 
planning, agencies should consider the use of telework--that is, 
work performed at an employee's home or at a work location other 
than a traditional office. The Office of Personnel Management	 
(OPM) recently reported that 43 agencies have identified staff	 
eligible to telework, and that more than 140,000 federal	 
employees used telework in 2004. OPM also reported that many	 
government operations can be carried out in emergencies using	 
telework. For example, telework appears to be an effective	 
strategy for responding to a pandemic--a global outbreak of	 
disease that spreads easily from person to person and causes	 
serious illness and death worldwide. In previous work, GAO	 
identified steps that agencies should take to effectively use	 
telework during an emergency. GAO was asked to testify on how	 
agencies are addressing the use of telework in their continuity  
planning, which is among the topics discussed in a report being  
released today (GAO-06-713).					 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-06-740T					        
    ACCNO:   A53779						        
  TITLE:     Continuity of Operations: Agencies Could Improve Planning
for Telework during Disruptions 				 
     DATE:   05/11/2006 
  SUBJECT:   Continuity of operations				 
	     Continuity of operations plan			 
	     Emergency preparedness				 
	     Emergency response 				 
	     Federal agencies					 
	     Influenza						 
	     Pandemic						 
	     Policy evaluation					 
	     Remote access					 
	     Staff utilization					 
	     Strategic planning 				 
	     Telecommuting					 

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GAO-06-740T

     

     * Results in Brief
     * Background
     * Few Agencies Demonstrated That They Had Adequately Prepared
     * Contacts and Acknowledgements
     * PDF6-Ordering Information.pdf
          * Order by Mail or Phone

Mr. Chairman and Members of the Committee:

I appreciate the opportunity to participate in the Committee's hearing on
pandemic influenza and continuity of operations (COOP) planning. As you
know, essential government services can be interrupted by a range of
events, including terrorist attacks, severe weather, building-level
emergencies, and public health emergencies, such as pandemic influenza.
The federal government requires agencies to develop plans for ensuring the
continuity of essential services during such emergencies. To assist
agencies, the Federal Emergency Management Agency (FEMA), within the
Department of Homeland Security (DHS), which is responsible for managing
federal response and recovery efforts following any national incident, has
issued guidance that defines the elements of a viable COOP capability.

A potentially useful option for continuity planning is telework (in which
work is performed at an employee's home or at a work location other than a
traditional office); this alternative has gained widespread attention over
the past decade in both the public and private sectors as a human capital
flexibility that offers a variety of potential benefits to employers,
employees, and society. In a December 2005 report to Congress, the Office
of Personnel Management (OPM) indicated that 43 of the 82 federal agencies
it surveyed had employees eligible to telework during 2004, and more than
140,000 federal employees used telework that year.1

OPM also reported that there is a symbiotic relationship between COOP and
telework because many government functions that must be carried out in
emergencies can be accomplished using telework. Similarly, we reported in
April 2004 that telework is an important and viable option for federal
agencies in continuity planning and implementation efforts, especially as
the duration of an emergency event is extended.2 This option appears
particularly appropriate in the case of pandemic influenza, which occurs
when an influenza virus causes an outbreak of disease that spreads easily
from person to person and results in serious illness worldwide. Experts
believe that the effects of a pandemic could come in waves that last for
weeks or even months, in which time absentee rates could reach 40 percent
during peak periods due to illness, the need to care for family members,
and fear of infection. Recent executive branch  guidance  states that
social distancing measures, such as telework, may be appropriate public
health interventions for infection control and containment during a
pandemic outbreak.

1 OPM, The Status of Telework in the Federal Government 2005 (Washington,
D.C.: Dec. 2005)

2 GAO, Human Capital: Opportunities to Improve Federal Continuity Planning
Guidance, GAO-04-384 (Washington, D.C.: Apr. 20, 2004).

GAO recognizes the importance of telework and continuity planning and is
striving to lead by example on these issues. For example, during certain
emergencies, our current telework policy allows me to approve telework for
all employees in an affected area to promote continuity of operations. We
are also completing a supplement to our COOP plan that addresses
preparations specific to a pandemic, and are coordinating our continuity
planning efforts with those of other legislative branch agencies.

As you requested, I will discuss how agencies are addressing the use of
telework in their continuity planning, based on work described in a report
that we are issuing today.3 In earlier work, we identified steps agencies
that should take to effectively use telework during an emergency, and we
surveyed agency officials responsible for continuity planning at 23 major
agencies.4 For this report, we repeated this survey to obtain updated
information on the extent to which key telework practices were used in
making continuity preparations. We reviewed documentation submitted by
agency officials to support their survey responses and compared these
responses to those from our earlier work; we briefed your staff on the
results of our work on April 13, 2006. This work was conducted in
accordance with generally accepted government auditing standards.

3 GAO, 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).

4 GAO, Continuity of Operations: Agency Plans Have Improved, but Better
Oversight Could Assist Agencies in Preparing for Emergencies, GAO-05-577
(Washington, D.C.: Apr. 28, 2005).

                                Results in Brief

More agencies reported plans for essential team members to telework during
a COOP event than in our previous survey, but few documented that they
made the necessary preparations to effectively use telework during an
emergency:

           0M Nine of the 23 agencies reported that some of their essential
           team members are expected to telework during a COOP event.
           However, only one agency documented that it had notified its team
           members of the expectation that they would telework during such an
           event.
           0M None of the 23 agencies demonstrated that it could ensure
           adequate technological capacity to allow designated personnel to
           telework during an emergency.
           0M Only 3 of the 23 agencies documented testing the ability of
           staff to telework during an emergency.

           FEMA's guidance on COOP planning does not include specific
           information on preparations to use telework during emergencies;
           the absence of such specific guidance contributed to the low
           levels of preparations that agencies reported. Recently, FEMA
           disseminated additional guidance to agencies regarding the
           incorporation of pandemic influenza considerations into COOP
           planning. Although this guidance suggests the use of telework
           during such an event, it does not address the steps agencies
           should take when preparing to use telework during an emergency. If
           agencies do not make adequate preparations, they may not be able
           to use telework effectively to ensure the continuity of their
           essential functions in emergencies, including pandemic influenza
           events.

           In our report, we recommended, among other things, that FEMA
           establish a time line for developing, in consultation with OPM,
           guidance on preparations needed for using telework during a COOP
           event. In commenting on a draft of this report, DHS partially
           agreed with our recommendation and stated that FEMA will
           coordinate with OPM in the development of a time line for telework
           guidance.

                                   Background

Federal operations and facilities have been disrupted by a range of
events, including the terrorist attacks on September 11, 2001; the
Oklahoma City bombing; localized shutdowns due to severe weather
conditions, such as hurricanes Katrina, Rita, and Wilma in 2005; and
building-level events, such as asbestos contamination at the Department of
the Interior's headquarters. In addition, federal operations could be
significantly disrupted by people-only events, such as an outbreak of
severe acute respiratory illness (SARS). Such disruptions, particularly if
prolonged, can lead to interruptions in essential government services.
Prudent management, therefore, requires that federal agencies develop
plans for dealing with emergency situations, including maintaining
services, ensuring proper authority for government actions, and protecting
vital assets.

Until relatively recently, continuity planning was generally the
responsibility of individual agencies. In October 1998, Presidential
Decision Directive (PDD) 67 identified FEMA-which is responsible for
leading the effort to prepare the nation for all hazards and managing
federal response and recovery efforts following any national incident-as
the lead agent for federal COOP planning across the federal executive
branch. FEMA's responsibilities include

           0M formulating guidance for agencies to use in developing viable
           plans;
           0M coordinating interagency exercises and facilitating interagency
           coordination, as appropriate; and
           0M overseeing and assessing the status of COOP capabilities across
           the executive branch.

           In July 1999, FEMA issued the first version of Federal
           Preparedness Circular (FPC) 65, its guidance to the federal
           executive branch on developing viable and executable contingency
           plans that facilitate the performance of essential functions
           during any emergency. FPC 65 applies to all federal executive
           branch departments and agencies at all levels, including locations
           outside Washington, D.C. FEMA released an updated version of FPC
           65 in June 2004, providing additional guidance to agencies on each
           of the topics covered in the original guidance.

           In partial response to a recommendation we made in April 2004, the
           2004 version of FPC 65 also included new guidance on human capital
           considerations for COOP events.5 For example, the guidance
           instructed  agencies to consider telework-also referred to as
           telecommuting or flexiplace-as an option in their continuity
           planning.

           Telework has gained widespread attention over the past decade in
           both the public and private sectors as a human capital flexibility
           that offers a variety of potential benefits to employers,
           employees, and society. In a 2003 report to Congress on the status
           of telework in the federal government, the Director of OPM
           described telework as "an invaluable management tool which not
           only allows employees greater flexibility to balance their
           personal and professional duties, but also allows both management
           and employees to cope with the uncertainties of potential
           disruptions in the workplace, including terrorist threats."6 A
           2005 OPM report on telework  notes the importance of telework in
           responding flexibly to emergency situations, as demonstrated in
           the wake of the devastation caused by Hurricane Katrina, when
           telework served as a tool to help alleviate the issues caused by
           steeply rising fuel prices nationwide.7

           In 2004, we surveyed major federal agencies at your request to
           determine how they planned to use telework during COOP events.8 We
           reported that, although agencies were not required to use telework
           in their COOP plans, 1 of the 21 agency continuity plans in place
           on May 1, 2004, documented plans to address some essential
           functions through telework. In addition, 10 agencies reported that
           they intended to use telework following a COOP event, even though
           those intentions were not documented in their continuity plans.

           The focus on using telework in continuity planning has been
           heightened in response to the threat of pandemic influenza. In
           November 2005, the White House issued a national strategy to
           address this threat, which states that social distancing measures,
           such as telework, may be appropriate public health interventions
           for infection control and containment during a pandemic outbreak.
           The strategy requires federal departments and agencies to develop
           and exercise preparedness and response plans that take into
           account the potential impact of a pandemic on the federal
           workforce. It also tasks DHS-the parent department of FEMA-with
           developing plans to implement the strategy in regard to domestic
           incident management and federal coordination. In May 2006, the
           White House issued an implementation plan in support of the
           pandemic strategy. This plan outlines the responsibilities of
           various agencies and establishes time lines for future actions.

5 GAO, Human Capital: Opportunities to Improve Federal Continuity Planning
Guidance, GAO-04-384 (Washington, D.C.: Apr. 20, 2004).

6 OPM, Report to the Congress: The Status of Telework in the Federal
Government (Washington, D.C.: Jan. 2003).

7 OPM, Report to the Congress: The Status of Telework in the Federal
Government (Washington, D.C.: Dec. 2005).

8 The plans that we reviewed in 2004 were created before the issuance of
FEMA's revised FPC 65, which instructs agencies to consider the use of
telework in their continuity planning.

Few Agencies Demonstrated That They Had Adequately Prepared to Use Telework in a
                                   COOP Event

Although more agencies reported plans for essential team members to
telework during a COOP event than in our 2004 survey, few documented that
they had made the necessary preparations to effectively use telework
during an emergency. While FPC 65 does not require agencies to use
telework during a COOP event, it does state that they should consider the
use of telework in their continuity plans and procedures. All of the 23
agencies that we surveyed indicated that they considered telework as an
option during COOP planning, and 15 addressed telework in their COOP plans
(see table 1). For agencies that did not plan to use telework during a
COOP event, reasons cited by agency officials for this decision included
(1) the need to access classified information-which is not permitted
outside of secured areas-in order to perform agency essential functions
and (2) a lack of funding for the necessary equipment acquisition and
network modifications.

Table 1: Agency Responses to Selected Questions on Telework in COOP Plans

                                                                   Yes (no    
Question                                              Year  Yes   doca) No
Does the agency's COOP plan specifically address      2005   12       3  8 
telework?                                             2004b   2       1 19 
Are any of the agency's essential team members        2005    3       6 14 
expected to telework in a COOP event?                 2004    1       2 19 
Were staff informed of their responsibility to        2005    1      10 12 
telework during a COOP event?                         2004    1       3 18 
Has the agency ensured that it has adequate           2005    0      14  9 
technological capacity for staff to telework during a                   
COOP event?                                           2004    0       5 17 
Will the agency provide technological assistance to   2005    3      11  9 
staff during a COOP event?                            2004    0       5 17 
Has the agency tested the ability of staff to         2005    3       7 13 
telework during a COOP event?                         2004    0       2 20 

Source: Analysis of agency responses to GAO questions.

a Agencies provided a positive response but did not provide adequate
documentation to support their response.

b In 2004, one agency did not respond, resulting in a total of 22
responses.

The agencies that did plan to use telework in emergencies did not
consistently demonstrate that they were prepared to do so. We previously
identified steps agencies should take to effectively use telework during
an emergency. These include preparations to ensure that staff has adequate
technological capacity, assistance, and training.9 Table 1 provides
examples of gaps in agencies' preparations, such as the following:

           0M Nine of the 23 agencies reported that some of their COOP
           essential team members are expected to telework during a COOP
           event. However, only one agency documented that it had notified
           its team members that they were expected to telework during such
           an event.
           0M None of the 23 agencies demonstrated that it could ensure
           adequate technological capacity to allow designated personnel to
           telework during a COOP event.

           No guidance addresses the steps that agencies should take to
           ensure that they are fully prepared to use telework during a COOP
           event. When we reported the results of our 2004 survey, we
           recommended that the Secretary of Homeland Security direct the
           Under Secretary for Emergency Preparedness and Response to
           develop, in consultation with OPM, guidance on the steps that
           agencies should take to adequately prepare for the use of telework
           during a COOP event. However, to date, no such guidance has been
           created.

           In March 2006, FEMA disseminated guidance to agencies regarding
           the incorporation of pandemic influenza considerations into COOP
           planning. The guidance states that the dynamic nature of a
           pandemic influenza requires that the federal government take a
           nontraditional approach to continuity planning and readiness. It
           suggests the use of telework during such an event. According to
           the guidance, agencies should consider which essential functions
           and services can be conducted from a remote location (e.g., home)
           using telework. However, the guidance does not address the steps
           agencies should take when preparing to use telework during an
           emergency. For example, although the guidance states that agencies
           should consider testing, training, and exercising of social
           distancing techniques, including telework, it does not address
           other necessary preparations, such as informing designated staff
           of the expectation to telework or providing them with adequate
           technical resources and support.

           Earlier this month, after we briefed your staff, the White House
           released an Implementation Plan in support of the National
           Strategy for Pandemic Influenza. This plan calls on OPM to work
           with DHS and other agencies to revise existing telework guidance
           and issue new guidance on human capital planning and COOP. The
           plan establishes an expectation that these actions will be
           completed within 3 months.

           If the forthcoming guidance from DHS and other responsible
           agencies does not require agencies to make the necessary
           preparations for telework, agencies are unlikely to take all the
           steps necessary to ensure that employees will be able to
           effectively use telework to perform essential functions during any
           COOP event. In addition, inadequate preparations could limit the
           ability of nonessential employees to contribute to agency missions
           during extended emergencies, including a pandemic influenza
           scenario.

           In summary, Mr. Chairman, although more agencies reported plans
           for essential team members to telework during a COOP event than in
           our previous survey, few documented that they had made the
           necessary preparations to effectively use telework during an
           emergency. In addition, agencies lack guidance on what these
           necessary preparations are. Although FEMA's recent telework
           guidance does not address the steps agencies should take to
           prepare to use telework during an emergency event, new guidance on
           telework and COOP is expected to be released later this year. If
           the new guidance does not specify the steps agencies need to take
           to adequately prepare their telework capabilities for use during
           an emergency situation, it will be difficult for agencies to make
           adequate preparations to ensure that their teleworking staff will
           be able to perform essential functions during a COOP event.

           In our report, we made recommendations aimed at helping to ensure
           that agencies are adequately prepared to perform essential
           functions following an emergency. Among other things, we
           recommended that the Secretary of Homeland Security direct the
           FEMA Director to establish a time line for developing, in
           consultation with OPM, guidance on the steps that agencies should
           take to adequately prepare for the use of telework during a COOP
           event.

           In commenting on a draft of the report, the Director of DHS's
           Liaison Office partially agreed with this recommendation and
           stated that FEMA will coordinate with OPM in the development of a
           time line for further telework guidance. In addition, he stated
           that both FEMA and OPM have provided guidance on the use of
           telework. However, as stated in our report, present guidance does
           not address the preparations agencies should make for using
           telework during emergencies.

           With the release of the White House's Implementation Plan
           regarding pandemic influenza, a time line has now been established
           for the issuance of revised guidance on telework; however, unless
           the forthcoming guidance addresses the necessary preparations,
           agencies may not be able to use telework effectively to ensure the
           continuity of their essential functions.

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

9 GAO, Continuity of Operations: Agency Plans Have Improved, but Better
Oversight Could Assist Agencies in Preparing for Emergencies, GAO-05-577
(Washington, D.C.: Apr. 28, 2005).

                         Contacts and Acknowledgements

For information about this testimony, please contact Linda D. Koontz at
(202) 512-6240 or at [email protected] . Key contributions to this testimony
were made by James R. Sweetman, Jr., Assistant Director; Barbara Collier;
Sairah Ijaz; Nick Marinos; and Kim Zelonis.

(310762)

United States Government Accountability Office

GAO

Testimony

Before the Committee on Government Reform, House of Representatives

For Release on Delivery

Expected at 10:00 a.m. EDT Thursday, May 11, 2006

CONTINUITY OF OPERATIONS

Agencies Could Improve Planning for Telework during Disruptions

Statement of David M. Walker

Comptroller General of the United States

GAO-06-740T

www.gao.gov/cgi-bin/getrpt?GAO-06-740T.

To view the full product, including the scope

and methodology, click on the link above.

For more information, contact Linda D. Koontz at (202) 512-6240 or
[email protected].

Highlights of GAO-06-740T, a testimony before the Committee on Government
Reform, House of Representatives

May 11, 2006

CONTINUITY OF OPERATIONS

Agencies Could Improve Planning for Telework during Disruptions

To ensure that essential government services are available in emergencies,
federal agencies are required to develop continuity of operations (COOP)
plans. The Federal Emergency Management Agency (FEMA), within the
Department of Homeland Security (DHS), is responsible for providing
guidance to agencies on developing such plans. Its guidance states that in
their continuity planning, agencies should consider the use of
telework-that is, work performed at an employee's home or at a work
location other than a traditional office. The Office of Personnel
Management (OPM) recently reported that 43 agencies have identified staff
eligible to telework, and that more than 140,000 federal employees used
telework in 2004.

OPM also reported that many government operations can be carried out in
emergencies using telework. For example, telework appears to be an
effective strategy for responding to a pandemic-a global outbreak of
disease that spreads easily from person to person and causes serious
illness and death worldwide. In previous work, GAO identified steps that
agencies should take to effectively use telework during an emergency.

GAO was asked to testify on how agencies are addressing the use of
telework in their continuity planning, which is among the topics discussed
in a report being released today ( GAO-06-713 ).

Although agencies are not required to use telework in continuity planning,
9 of the 23 agencies surveyed reported plans for essential team members to
telework during a COOP event, compared to 3 in GAO's previous survey.
However, few documented that they made the necessary preparations to
effectively use telework during such an event. For example, only 1 agency
documented that it had communicated this expectation to its emergency team
members.One reason for the low levels of preparations reported is that
FEMA has not provided specific guidance on preparations needed to use
telework during emergencies.

Recently, FEMA disseminated guidance to agencies on incorporating pandemic
influenza considerations into COOP planning. Although this guidance
suggests the use of telework during such an event, it does not address the
steps agencies should take when preparing to use telework during an
emergency. Without specific guidance, agencies are unlikely to adequately
prepare their telework capabilities for use during a COOP event. In
addition, inadequate preparations could limit the ability of nonessential
employees to contribute to agency missions during extended emergencies,
including pandemic influenza.

In its report released today, GAO recommends, among other things, that
FEMA establish a time line for developing, in consultation with the OPM,
guidance on preparations needed for using telework during a COOP event. In
commenting on a draft of the report, DHS partially agreed with GAO's
recommendation and stated that FEMA will coordinate with OPM in developing
a time line for further telework guidance. DHS also stated that both FEMA
and OPM have provided telework guidance. However, as GAO's report stated,
present guidance does not address the preparations federal agencies should
make for using telework during emergencies.

On May 3 the White House announced the release of an Implementation Plan
in support of the National Strategy for Pandemic Influenza. This plan
calls on OPM to work with DHS and other agencies to revise existing
telework guidance and issue new guidance on human capital planning and
COOP. The plan establishes an expectation that these actions will be
completed within 3 months. If the forthcoming guidance does not require
agencies to make necessary preparations for telework, agencies are
unlikely to take all the steps necessary to ensure that employees will be
able to effectively use telework to perform essential functions in
extended emergencies, such as a pandemic influenza.

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