Emergency Management: Most School Districts Have Developed	 
Emergency Management Plans, but Would Benefit from Additional	 
Federal Guidance (12-JUN-07, GAO-07-609).			 
                                                                 
Congress has raised concerns over emergency management in school 
districts, with a particular interest in how federal agencies	 
provide assistance to school districts. GAO was asked to assess  
(1) the roles of federal and state governments and school	 
districts in establishing requirements and providing resources to
school districts for emergency management planning, (2) what	 
school districts have done to plan and prepare for emergencies,  
and (3) the challenges, if any, school districts have experienced
in planning for emergencies, and communicating and coordinating  
with first responders, parents, and students. To obtain this	 
information, GAO interviewed federal officials, surveyed a	 
stratified random sample of all public school districts, surveyed
state education agencies and state administering agencies,	 
conducted site visits to school districts, and reviewed relevant 
documents.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-609 					        
    ACCNO:   A70591						        
  TITLE:     Emergency Management: Most School Districts Have	      
Developed Emergency Management Plans, but Would Benefit from	 
Additional Federal Guidance					 
     DATE:   06/12/2007 
  SUBJECT:   Emergency management				 
	     Emergency preparedness				 
	     Emergency response plans				 
	     Federal aid to localities				 
	     Federal aid to states				 
	     Federal/state relations				 
	     Grants to states					 
	     Homeland security					 
	     Local governments					 
	     Locally administered programs			 
	     Risk management					 
	     School districts					 
	     Strategic planning 				 
	     State Homeland Security Grant Programs		 
	     Urban Areas Security Initiative			 

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GAO-07-609

   

     * [1]Results in Brief
     * [2]Background

          * [3]Federal Role in Emergency Management
          * [4]Funding of School Districts

     * [5]Many States and School Districts Reported Having Requirement

          * [6]Although No Federal Laws Exist Requiring Emergency Managemen
          * [7]Federal Agencies, State Governments, and School Districts Pr
          * [8]Federal Agencies, State Governments, and School Districts al

     * [9]Most Districts Have Taken Steps to Prepare for Emergencies a

          * [10]Most School Districts Have Undertaken Some Emergency Managem
          * [11]Most Districts Have Emergency Management Plans That Address
          * [12]About Half of All Districts Involved Local Government, Publi

     * [13]School Districts Report Challenges in Planning for Emergenci

          * [14]Competing Priorities, Lack of Equipment, and Limited Experti
          * [15]Some School Districts Reported Difficulty in Communicating a
          * [16]School Districts Have Methods to Communicate with Parents, b

     * [17]Conclusions
     * [18]Recommendations for Executive Action
     * [19]Agency Comments and Our Evaluation
     * [20]Survey of States
     * [21]Survey of School Districts

          * [22]Population
          * [23]Sample Design and Errors
          * [24]Response Rate

     * [25]Site Visits
     * [26]GAO Contacts
     * [27]Acknowledgments
     * [28]GAO's Mission
     * [29]Obtaining Copies of GAO Reports and Testimony

          * [30]Order by Mail or Phone

     * [31]To Report Fraud, Waste, and Abuse in Federal Programs
     * [32]Congressional Relations
     * [33]Public Affairs

Report to Congressional Requesters

United States Government Accountability Office

GAO

June 2007

EMERGENCY MANAGEMENT

Most School Districts Have Developed Emergency Management Plans, but Would
Benefit from Additional Federal Guidance

GAO-07-609

Contents

Letter 1

Results in Brief 4
Background 7
Many States and School Districts Reported Having Requirements for
Emergency Management Plans, and Federal and State Governments and School
Districts Provide Resources for Emergency Management Planning 9
Most Districts Have Taken Steps to Prepare for Emergencies and Developed
Written Plans, but Some Plans Do Not Address Recommended Practices 21
School Districts Report Challenges in Planning for Emergencies as Well as
Difficulties in Communicating with First Responders and Parents, but No
Challenges in Communicating with Students 39
Conclusions 46
Recommendations for Executive Action 47
Agency Comments and Our Evaluation 48
Appendix I Scope and Methodology 51
Survey of States 51
Survey of School Districts 52
Site Visits 54
Appendix II Emergency Management Planning Requirements 57
Appendix III Homeland Security Funding Provided to School Districts 60
Appendix IV Guidance, Training, and Funding States Provided to School
Districts 61
Appendix V Comments from the Department of Homeland Security 63
Appendix VI Comments from the Department of Education 66
Appendix VII Comments from the Department of Health & Human Services 70
Appendix VIII GAO Contacts and Staff Acknowledgments 73

Tables

Table 1: Estimated Frequency of School Districts' Review of Schools'
Emergency Management Plans 12
Table 2: Estimated Number of School Districts That States Reported
Providing Homeland Security Funding during Fiscal Years 2003-2006 14
Table 3: Examples of Guidance, Training, and Equipment the Federal
Government Provides to School Districts 17
Table 4: Selected Practices That Education, DHS, and HHS Recommend School
Districts Take to Prepare for Emergencies 18
Table 5: Key Elements in Emergency Management Plan Templates by Percentage
of School Districts with Written Emergency Management Plans 20
Table 6: Types of Security Enhancements School Districts Made Based on
Vulnerability Assessments 22
Table 7: Activities School Districts Have Taken Responsibility for to
Prepare for Emergencies 25
Table 8: Estimated Percentage of School Districts That Have Procedures for
Communicating with Limited-English Proficient Parents and Students in
Their Emergency Management Plans 29
Table 9: Percentage of School Districts That Use the Following Procedures
for Students with Special Needs in the Event of an Emergency 30
Table 10: Types of Recovery Procedures Addressed in School Districts
Written Emergency Management Plans 31
Table 11: Percentages of School Districts with Written Plans That Include
Certain Types of Procedures to Continue Student Educational Instruction in
the Event of an Extended School Closure 32
Table 12: Percentage of School Districts That Involve Stakeholders in the
Development and Update of Written Emergency Management Plans 35
Table 13: Frequency of Updates to Emergency Management Plans 36
Table 14: Estimated Frequency of Training with Each Type of First
Responder on How to Implement the School District Emergency Management
Plan 37
Table 15: Description of the Population and Sample of Districts 53
Table 16: School Districts Interviewed or Visited during Site Visits 55
Table 17: States Reporting Selected Requirements for School Districts or
Schools for Emergency Management Planning 57
Table 18: States That Reported Providing Homeland Security Funding
Directly to School Districts 60
Table 19: States and the District of Columbia That Reported Provided
Homeland Security Funding to School Districts through Local Jurisdictions
during Fiscal Years 2003--2006 60
Table 20: States and the District of Columbia That Reported Providing
Resources to School Districts to Assist in Emergency Management Planning
61

Figures

Figure 1: States That Reported Having Laws or Other Policies Requiring
School Districts or Schools to Have Emergency Management Plans 11
Figure 2: Estimated Differences in Types of Security Enhancements Made by
Urban and Rural Districts Based on Vulnerability Assessments 23
Figure 3: Estimated Differences in Types of Activities Undertaken by Urban
and Rural Districts to Prepare for Emergencies 26
Figure 4: Estimated Percentages of Urban and Rural Districts' Multi-Hazard
Emergency Management Plans That Include Specific Incidents 27

Abbreviations

CBSA Core Based Statistical Area
CCD Common Core Data
CDC Centers for Disease Control and Prevention
CSA Consolidated Statistical Area
DHS Department of Homeland Security
Education Department of Education
EMS Emergency Medical Services
ERCM Emergency Response and Crisis Management
FEMA Federal Emergency Management Agency
HHS Health and Human Services
ICS Incident Command System
IDEA Individuals with Disabilities Education Act
LEP Limited-English Proficient
NIMS National Incident Management System
NOAA National Oceanic & Atmospheric Administration
SHSP State Homeland Security
Program SRO School Resource Officer
UASI Urban Areas Security Initiative

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United States Government Accountability Office
Washington, DC 20548

June 12, 2007

The Honorable Joseph Lieberman
Chairman
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Bennie Thompson
Chairman
Committee on Homeland Security
House of Representatives

The Honorable Bob Etheridge
The Honorable Sheila Jackson-Lee
House of Representatives

Maintaining the safety and security of the over 49 million students in the
nation's more than 17,000 public school districts has been a focus of
federal, state, and local government for years. Federal and state
governments and school districts have generally focused on crime in and
around schools and violence among students. However, school districts must
be prepared for a range of emergencies within and outside of school
buildings. Events such as the terrorist attacks of September 11, 2001,
natural disasters such as Hurricanes Katrina and Rita in 2005, recent
shootings by armed intruders in schools across the nation, and potential
pandemics have heightened the awareness of the range of events for which
schools should be prepared. In addition, environmental and other types of
hazards can exist in areas near school districts. For example, school
buildings can reside near nuclear plants, electric power plants, railways
that transport hazardous materials, major airports, or major interstates.
Maintaining the safety and security of the over 49 million students in the
nation's more than 17,000 public school districts has been a focus of
federal, state, and local government for years. Federal and state
governments and school districts have generally focused on crime in and
around schools and violence among students. However, school districts must
be prepared for a range of emergencies within and outside of school
buildings. Events such as the terrorist attacks of September 11, 2001,
natural disasters such as Hurricanes Katrina and Rita in 2005, recent
shootings by armed intruders in schools across the nation, and potential
pandemics have heightened the awareness of the range of events for which
schools should be prepared. In addition, environmental and other types of
hazards can exist in areas near school districts. For example, school
buildings can reside near nuclear plants, electric power plants, railways
that transport hazardous materials, major airports, or major interstates.

"Emergency management" refers to the range of efforts involved in building
the capacity to prevent, protect against, respond to, and recover from an
incident. Planning for such incidents vary by the type and scale of the
incident. The federal government's role in emergency management is
principally to support state and local activities and develop the federal
capabilities to respond effectively when state and local governments
require federal assistance. Some federal support comes in the form of
guidance and recommendations. Because the federal government serves as a
partner to all states, it is uniquely positioned to observe and evaluate
the range of emergency management activities across states and local
"Emergency management" refers to the range of efforts involved in building
the capacity to prevent, protect against, respond to, and recover from an
incident. Planning for such incidents vary by the type and scale of the
incident. The federal government's role in emergency management is
principally to support state and local activities and develop the federal
capabilities to respond effectively when state and local governments
require federal assistance. Some federal support comes in the form of
guidance and recommendations. Because the federal government serves as a
partner to all states, it is uniquely positioned to observe and evaluate
the range of emergency management activities across states and local
governments, including school districts, and disseminate information on
recommended practices and successful strategies. In addition, the federal
government, largely through the Department of Homeland Security (DHS),
provides billions of dollars each year in grants and other forms of
assistance to help state and local emergency managers and first responders
(such as law enforcement, fire departments, and emergency medical
services). Other agencies such as the Departments of Education (Education)
and Health and Human Services (HHS) also play a part in supporting state
and local emergency management activities with regard to education and
public health, respectively.

Emergency management for large-scale incidents generally requires
partnerships among federal, state, and local governments, nongovernment
organizations, and the private sector. For example, school districts may
need the assistance of other organizations, including nongovernmental
ones, in evacuating schools and finding shelter for students when an
earthquake renders a school structurally unsafe.

The Congress has raised concerns about whether school districts are
prepared to address a range of emergencies, particularly acts of
terrorism, and how three federal agencies--DHS, Education, and
HHS--provide assistance to school districts. In addition, the Congress has
expressed an interest in getting a better understanding of whether school
districts have emergency management plans that address the needs of
students and parents who are classified as Limited-English Proficient
(LEP), and students with special needs such as those with mental,
physical, motor, developmental, or sensory impairments.

In response to your request to examine the state of emergency management
in the nation's school districts, this report addresses the following
questions: (1) What are the roles of federal and state governments and
school districts in establishing requirements and providing resources to
school districts for emergency management planning? (2) What have school
districts done to plan and prepare for emergencies? (3) What challenges,
if any, have school districts experienced in planning for emergencies and
communicating and coordinating with first responders, parents, and
students?

To obtain the information to address our research objectives, we conducted
interviews, surveys, site visits to school districts, and reviews of
relevant documents and laws identified through surveys and site visits. To
determine the roles and requirements of federal and state governments and
the types of resources provided to districts, we conducted interviews with
officials with Education, HHS, and DHS and reviewed relevant federal laws.
We also administered two surveys, one to state education agencies and one
to state administering agencies (the state agencies to which DHS disburses
emergency management funding^1) in all 50 states and the District of
Columbia. We received responses from 49 of 51 state education agencies and
from 40 of 51 state administering agencies. In the survey to state
administering agencies, we asked specifically about whether states or
local governments provided school districts with federal funding from the
State Homeland Security Program (SHSP), Urban Areas Security Initiative
(UASI), and Citizen Corps grants.^2 To better understand how school
districts plan and prepare for emergencies, we administered a mail survey
to a stratified random sample of school districts in the 50 states and the
District of Columbia. We used the Department of Education's locale coding
system in the Common Core Data (CCD) to identify urban and rural school
districts. Locale codes are based on the specific conditions of schools
and refer to very small geographic areas and circumstances, such as
population density and size. Although several criteria are used by
Education to classify school districts including the percentage of
students located in particular locale codes (assigned to individual
schools), generally, urban districts are located within "large" (equal to
or greater than 250,000 population) or "mid-sized" (less than 250,000
population) cities and rural districts are located in areas designated as
rural by the Census Bureau. Appendix I includes a more detailed discussion
of how urban and rural districts are defined in the CCD. We received 444
of the 554 surveys we mailed to school districts for a response rate of 80
percent, including responses from 24 of the 26 largest school districts in
the country. Using a 95 percent confidence interval, all percentage
estimates included in this report have a margin of error of plus or minus
10 percent or less, unless otherwise noted. We did not survey individual
schools within school districts. To further understand the experiences
districts have had in planning for emergencies and communicating and
coordinating with first responders^3, parents, and students, we visited
selected districts in the states of Florida, Iowa, Massachusetts, North
Carolina, Ohio, and Washington. We selected a geographically diverse group
of states and school districts, some of which had been identified by
national education associations as having implemented recommended
practices in the area of emergency management, some that did and others
that did not receive federal funding for emergency management, and we
included both urban and rural districts. In total, we conducted
semi-structured interviews, either in person or by telephone, with
officials in 27 school districts. For more detailed information on our
scope and methodology, see appendix I. Our work was conducted between
April 2006 and April 2007 in accordance with generally accepted government
auditing standards.

^1For purposes of this report, we use the term "emergency management
funding" to describe emergency preparedness funding DHS provides to
states.

^2Under its Homeland Security Grant Program, DHS provides a range of
grants to states and local governments for emergency management. Based on
our analysis and discussions with DHS officials, the State Homeland
Security Program, Urban Areas Security Initiative, and Citizen Corps
grants are the only grants for which states and local governments can
disburse funds to school districts. The State Homeland Security Program
provides funds to enhance the emergency preparedness of state and local
governments. The Urban Areas Security Initiative grant is awarded to some
states with high threat and high density urban areas that need planning,
exercises, equipment, and training to respond to acts of terrorism.
Citizen Corps funds are provided to states to promote volunteer efforts.

Results in Brief

Although there are no federal laws requiring all school districts to have
emergency management plans, most states and school districts reported
having requirements for such planning, and federal and state governments
and school districts provide financial and other resources for such plans.
Thirty-two states reported having laws or other policies requiring school
districts to have emergency management plans. Based on our survey, we
estimate that 85 percent of school districts have requirements for school
emergency management planning. Education, DHS, and state governments as
well as school districts provide funding for emergency management planning
in schools. DHS awards grants to states and local jurisdictions that may
provide some of these funds to school districts and schools for emergency
management planning. However, DHS program guidance for the State Homeland
Security Program, Urban Areas Security Initiative, and Citizen Corps
grants does not clearly identify school districts as entities to which
state and local governments may disburse grant funds; therefore, some
states receiving DHS funding may be uncertain as to whether such funding
can be allocated to school districts or schools. As a result, school
districts in these states may not have the opportunity to benefit from
this funding. Federal and state governments and school districts also
assist school districts and schools in emergency management planning by
providing other resources such as guidance, training, and equipment.
However, in some instances, federal guidance does not include detailed
information on how school districts can implement recommended practices.

^3In both our site visits and our survey of school districts, we focused
on the traditional definition of first responders--law enforcement, fire,
and EMS. However, the Homeland Security Act, as amended, includes a
broader definition of emergency response providers, including "Federal,
State, and local governmental and nongovernmental emergency public safety,
fire, law enforcement, emergency response, emergency medical (including
hospital emergency facilities), and related personnel, agencies, and
authorities." Homeland Security Act of 2002, Pub. L. No. 107-296, S 2,
(codified at 6 U.S.C. S 101(6)). Homeland Security Presidential Directive
8 defined the term "first responder" as "individuals who in the early
stages of an incident are responsible for the protection and preservation
of life, property, evidence, and the environment, including emergency
response providers as defined in section 2 of the Homeland Security Act of
2002, as well as emergency management, public health, clinical care,
public works, and other skilled support personnel (such as equipment
operators) that provide immediate support services during prevention,
response, and recovery operations."

Most school districts have taken federally recommended steps to plan and
prepare for emergencies including the development of emergency management
plans; while the content of plans vary, many do not include recommended
practices. Based on our survey of school districts, we found that most
school districts, those with and without plans, have undertaken a variety
of recommended practices to prepare for emergencies such as conducting
inspections to identify potential vulnerabilities of school facilities and
grounds and holding school drills and exercises. In addition, we estimate
that 95 percent of all school districts have written emergency management
plans. Nearly all of those plans address multiple hazards such as natural
disasters, intruders, and bombs but few address pandemic influenza or
radiological hazards. The content of school district plans varies
significantly. While most school districts have outlined roles and
responsibilities for staff in their plans, for example, over half of all
school districts with emergency management plans have not employed
procedures for continuing student education in the event of an extended
school closure, such as might occur during a pandemic. Likewise, while
many districts have procedures for special needs students, we found during
our site visits that procedures vary in the extent to which they ensure
the safety of special needs students in an emergency. A higher percentage
of urban school districts' plans included procedures for special needs
students and for communicating with Limited-English Proficient parents and
students compared to rural districts. Fewer than half of all school
districts have involved the local head of government and fewer than half
involved the local public health agency in the development of their plans.
While half of all school districts update their emergency management plans
at least once a year, an estimated 10 percent had never updated their
plans. Finally, while most school districts practice their emergency
management plans annually within the school community, we estimate that
over one-quarter of school districts have never trained with first
responders and over two-thirds of school districts do not regularly train
with community partners on how to implement their school district
emergency management plans. The reasons why school districts do not train
with first responders or community partners are not readily apparent.

Many school district officials said that they experience challenges in
planning for emergencies and some school districts face difficulties in
communicating and coordinating with first responders and parents, but most
said that they do not experience challenges in communicating with
students. Based on our survey of districts, we estimate that in 70 percent
of all school districts, officials struggle to balance priorities related
to educating students and other administrative responsibilities with
activities for emergency management. For example, in some of the districts
we visited, administrators were reluctant to allocate teacher development
training time to emergency management because of other training
priorities. In an estimated 62 percent of all school districts, officials
identified challenges stemming from a lack of equipment, training for
staff, and personnel with expertise in the area of emergency planning.
Officials noted that a lack of equipment and expertise can impact many
aspects of emergency management, including planning for special needs
students. For example, a school district official in Washington said that
the district lacks equipment to evacuate special needs students from some
school buildings and in some cases staff are unsure of how to operate the
existing equipment. Officials also reported problems in communicating and
coordinating with first responders and parents. In an estimated 39 percent
of school districts with emergency management plans, officials experienced
a lack of partnerships, limited time or funding to discuss planning with
first responders, or lack of interoperability between equipment used by
school districts and first responders. About half of the officials in the
27 school districts we interviewed reported difficulty in ensuring that
parents received consistent information from the district during an
emergency. Some of these officials also described problems in
communicating emergency-related information to Limited-English Proficient
parents.

To address issues related to the emergency management of school districts,
we recommend that (1) DHS clearly identify school districts as entities to
which state and local governments may disburse grant funds in its program
guidance for the State Homeland Security Program, Urban Areas Security
Initiative, and Citizen Corps programs to ensure that states and local
governments are aware that they can disburse funding to school districts
and still meet funding requirements; (2) Education, in collaboration with
DHS and HHS, provide guidance to school districts on successful procedures
for sheltering and evacuating special needs students during emergencies;
(3) Education collaborate with HHS to provide specific guidance to states
and school districts on how to incorporate, in emergency management plans,
procedures for the continuation of education in the event of extended
school closures such as those that might occur in the case of a pandemic
(such as pandemic influenza); and (4) DHS and Education identify the
factors that prevent school districts, first responders, and community
partners from training together, develop strategies for addressing those
factors, and promote current efforts that can help school districts in
this area.

We provided copies of this report to DHS, Education, and HHS for review
and comment. DHS generally agreed with the intent of our recommendations
but suggested additional language regarding the need to promote the use of
current resources in efforts to increase school district training with
first responders and community partners, which we incorporated. DHS's
comments are in appendix V. In its comments on the draft report, Education
generally agreed with our recommendations. Education's comments are in
appendix VI. Finally, HHS generally agreed with our recommendations and
asked that we include HHS in our recommendation that federal agencies
provide additional guidance related to special needs students, which we
accepted. HHS's comments are in appendix VII.

Background

Federal Role in Emergency Management

The Homeland Security Act of 2002 created DHS and consolidated most of the
federal programs and agencies with responsibilities for emergency
management into that agency.^4 DHS serves as a federal partner to state
and local governments in emergency management.^5 DHS provides technical
assistance and homeland security grant funding to states and local
governments to enhance their emergency management efforts. States and
local governments have the responsibility for spending DHS grant funds in
accordance with DHS guidelines to meet local emergency management needs.
In fiscal year 2006, DHS awarded $1.7 billion to states, urban areas, and
territories to prepare for and respond to terrorist attacks and other
disasters. States and local governments may then provide a portion of this
funding to a range of entities, as specified in DHS's program guidance.

^4Pub. L. No. 107-296.

^5The Robert T. Stafford Disaster Relief and Emergency Assistance Act,
Pub. L. No. 100-707, provides the legal framework for this partnership.
The Stafford Act is the principal federal statute governing federal
disaster assistance and relief and primarily establishes the programs for
and processes by which the federal government may provide major disaster
and emergency assistance to states and local governments. The Stafford Act
also provides emergency assistance to tribal nations, individuals and
qualified private non-profit organizations. The Federal Emergency
Management Agency (FEMA) is the principal federal agency responsible for
implementing the Stafford Act.

As we have noted in prior reports, emergency management requires
coordinated planning and implementation by a variety of participants.
Effective emergency management requires identifying the hazards for which
it is necessary to be prepared (risk assessments); establishing clear
roles and responsibilities that are effectively communicated and well
understood; and developing, maintaining, and mobilizing needed
capabilities, such as people, skills, and equipment.^6 The plans and
capabilities should be tested and assessed through realistic exercises
that identify strengths and areas that need improvement, with any needed
changes made to both plans and capabilities.

The hazards that school districts may face will vary across the country
depending upon the natural hazards to which their particular areas are
prone and an assessment of other risks for which they need to be prepared,
such as pandemic influenza or the discharge of hazardous substances from
nearby chemical or nuclear plants. Similarly, who should be involved in
emergency planning and response for schools, and the roles of the various
participants will vary by type and size of the emergency incident. For
large-scale emergencies, effective response is likely to involve all
levels of government--federal, state, and local--nongovernment entities,
such as the Red Cross, and the private sector.

Funding of School Districts

The responsibility for funding K-12 education rests primarily with state
and local governments. Approximately 90 percent of spending on education
comes from state, local, and private funds. The federal government
contributes approximately 8 to 10 percent. School districts are
responsible for spending the funds in accordance with applicable federal,
state, and local laws. However, the formulas states use to determine how
to fund school districts and the actual amount of funding states and local
governments spend on education can vary.

^6GAO, Homeland Security: Preparing for and Responding to Disasters,
[34]GAO-07-395T (Washington, D.C.: Mar. 9, 2007); and, Catastrophic
Disasters: Enhanced Leadership, Capabilities, and Accountability Controls
Will Improve the Effectiveness of the Nation's Preparedness, Response, and
Recovery System, [35]GAO-06-618 (Washington, D.C.: Sept. 6, 2006).

Many States and School Districts Reported Having Requirements for Emergency
Management Plans, and Federal and State Governments and School Districts Provide
Resources for Emergency Management Planning

Although no federal laws exist requiring all school districts to have
emergency management plans, most states and school districts reported
having requirements for school emergency management planning, and federal
and state governments and school districts provide financial and other
resources for such planning. Education, DHS, and state governments as well
as school districts provide funding for emergency management planning in
schools. However, DHS program guidance does not clearly identify school
districts as entities to which states and local governments may disburse
grant funds. Not all states receiving DHS funding are aware that such
funding could be disbursed to school districts. In addition to providing
funding, federal and state governments and school districts assist school
districts and schools in emergency management planning by providing other
resources such as guidance, training, and equipment.

Although No Federal Laws Exist Requiring Emergency Management Planning, the
Majority of States and School Districts Have Requirements

Although there are no federal laws requiring all school districts to have
emergency management plans, many states reported having laws or other
policies that do so. Congress has not enacted any broadly applicable laws
requiring all school districts to have emergency management plans, nor
have federal agencies issued any regulations imposing such a requirement
on all school districts. However, the No Child Left Behind Act of 2001
provides that local education agencies (LEAs or school districts) applying
for subgrants under the Safe and Drug Free Schools and Communities Program
include in their grant applications an assurance that either they or their
schools have "a plan for keeping schools safe and drug-free that
includes...a crisis management plan for responding to violent or traumatic
incidents on school grounds." ^7 Thirty-two states reported having laws or
other policies requiring school districts or schools to have a written
emergency management plan (see fig. 1).

^720 U.S.C. S 7114(d)(7)(D). The plans required under the No Child Left
Behind Act of 2001 are not required to address multiple hazards;
therefore, for purposes of this report, we do not consider this to be a
requirement for an emergency management plan.

Figure 1: States That Reported Having Laws or Other Policies Requiring
School Districts or Schools to Have Emergency Management Plans

Several state laws identify a broad range of specific emergencies that
schools or districts are required to address in their plans, while many
other states do not identify particular kinds of crises or use more
general language to refer to the kinds of emergencies that plans must
incorporate. For example, districts in Indiana are required to develop
plans that address, at a minimum, fire; natural disasters such as
tornadoes, floods, and earthquakes; adverse weather conditions, such as
winter storms or extreme heat; nuclear contamination from power plants or
vehicle spills; exposure to chemicals from a variety of sources; and
manmade occurrences, such as student disturbances, weapons, weapons of
mass destruction, water or air supply contamination, and hostage and
kidnapping incidents. In contrast, some states, such as Pennsylvania,
South Dakota, and Texas, among others, do not identify any specific
hazards in their planning requirements.

State emergency planning requirements also vary in their degree of
prescriptiveness regarding plan development and emergency preparedness.
For example, a number of states, including Georgia and Ohio, require that
schools or districts involve partners, such as first responders, other
community leaders, parents, and teachers in the planning process.
Likewise, some states, such as Illinois and Nevada, specifically require
that plans be reviewed annually and updated as appropriate. Additionally,
New Jersey and other states require districts and schools to provide
relevant district and school officials with periodic training related to
emergency plans. In comparison, the requirements of some states, such as
Oregon and Washington, are less detailed. For more detailed information on
state emergency planning requirements, see appendix II.

Many of the school districts we surveyed also reported having emergency
management planning requirements for schools. Based on our survey of
school districts, we estimate that 85 percent of all districts require
schools to have their own written emergency management plans. Of these
districts, 88 percent require that school plans be submitted to them for
review. However, the frequencies of these reviews vary (see table 1).

Table 1: Estimated Frequency of School Districts' Review of Schools'
Emergency Management Plans

Frequency of school district       Percentage estimate of school districts 
review                                                   conducting review 
At least once a year                                                    71 
At least once every 2 years                                              7 
At least once every 3 years                                             13 
Other                                                                    5 
Do not review                                                            4 

Source: GAO analysis of survey data.

Federal Agencies, State Governments, and School Districts Provide Funding for
School Districts' Emergency Management Planning

Education provides funding to some school districts specifically for
emergency management planning through its Emergency Response and Crisis
Management (ERCM) Grant Program.^8 Since fiscal year 2003, Education
dispersed $130 million in such grants to over 400 of the over 17,000^9
school districts in the United States. These grant awards ranged from
$68,875 to $1,365,087. For example, in fiscal year 2004, Seattle Public
Schools received an ERCM grant for $494,144 to train principals in using
the Incident Command System (ICS)^10 and to establish Web-based training,
among other things. In Tampa, Florida, a school district used a fiscal
year 2006 ERCM grant of $487,424 to install a new radio system and sponsor
faculty workshops on emergency response. Other uses reported by school
districts we visited include establishing emergency management plans,
installing equipment such as closed circuit televisions, training school
administrative staff (such as principals) on the National Incident
Management System (NIMS) and the ICS, and purchasing emergency backpacks
for school nurses.

^8The purpose of the ERCM grant program is to provide funds for local
education agencies to improve and strengthen their emergency response
plans. School districts receiving grant funds under this program may use
them to develop improved plans that address all four phases of crisis
response: prevention/mitigation, preparedness, response, and recovery. In
April 2007, Education announced that it was renaming the ERCM grant as the
Readiness and Emergency Management for Schools grant program (REMS) to
reflect terminology used in the emergency management field. This notice
also invited applications for grant funds, with Education estimating that
$24 million will be available to applicants in amounts ranging from
$100,000 to $500,000 per school district. In awarding grants, Education
will give priority to districts that have not previously received an ERCM
grant and that are located in a UASI jurisdiction. Applications must
address, among other things, how districts will coordinate their efforts
with law enforcement, public safety, public health, mental health, and
local government entities, as well as how the applicant will address the
needs of individuals with disabilities. Applicants must also agree to
develop an infectious disease plan that includes plans for continuing
education services. 72 Fed. Reg. 17,139 (Apr. 6, 2007).

^9As reported by the states to the Department of Education and contained
in the Common Core Data (CCD), there were over 17,000 school districts in
the United States in school year 2003-04. This number includes school
districts in Puerto Rico; four outlying areas (American Samoa, Guam,
Northern Marianas, and the U.S. Virgin Islands); the Bureau of Indian
Affairs and the Department of Defense, which were eligible for funds but
we excluded from the sample for our survey of school districts. While
Department of Defense schools are included in the CCD count of school
districts, Education officials said that such schools are not eligible to
receive funding under the ERCM/REMS grant program.

^10The Incident Command System is a standard incident management system to
assist in managing all major incidents. The Incident Command System also
prescribes interoperable communications systems and preparedness before an
incident happens, including planning, training, and exercises. The
Incident Command System was developed in the 1970s following a series of
catastrophic fires. Researchers determined that response problems were
more likely to result from inadequate management rather than from any
other reason. The Incident Command System was designed so that responders
from different jurisdictions and disciplines could work together better to
respond to natural disasters and emergencies, including acts of terrorism.
NIMS includes a unified approach to incident management: standard command
and management structures, and emphasis on preparedness, mutual aid, and
resource management.

DHS also provides funding to states and local jurisdictions for emergency
management planning, and some of this funding can be provided to school
districts or schools for emergency management planning. DHS officials told
us that such funds are available through the State Homeland Security
Program (SHSP), Urban Areas Security Initiative (UASI), and Citizen Corps
grants. Five states--Florida, Hawaii, Michigan, Mississippi, and
Wyoming--reported that they provided approximately $14 million in DHS
funding directly to school districts in these states during fiscal years
2003-2006 (see table 2). Florida, for example, provided about $4.3 million
in SHSP funds over a 2-year period to selected school districts for
training, upgrading the districts' emergency communications, and
controlling access to school facilities, as well as for conducting studies
related to emergency management. In fiscal year 2003, Michigan provided
$8.6 million in SHSP funds to 488 of its 801 school districts to conduct
planning exercises in response to potential terrorist events.

Table 2: Estimated Number of School Districts That States Reported
Providing Homeland Security Funding during Fiscal Years 2003-2006

Fiscal year Estimated number of school districts^a 
2006                                            72 
2005                                            85 
2004                                            70 
2003                                           536 

Source: GAO analysis of state administering agencies survey data.

aStates may have funded the same school districts over multiple years.

In addition, eight states and the District of Columbia reported that they
provided DHS funding to local jurisdictions that then provided a portion
of these funds to school districts or schools for emergency management
planning.^11 For example, South Dakota officials told us they awarded a
portion of the state's fiscal year 2006 SHSP funds to South Dakota's local
counties. These officials said that the counties then provided
approximately $26,000 to 3 of the state's 176 school districts for
emergency management planning efforts. Although Oklahoma did not respond
to our survey of state administering agencies, in February 2007, officials
from its Office of Homeland Security issued a press release and confirmed
to us that it provided $50,000 of DHS funding (SHSP) to five elementary
schools to enhance those schools' physical security. They said that each
school received a $10,000 grant to purchase equipment such as cameras,
magnetometers, concrete barriers, identification systems, and two-way
radios. For additional information on DHS funding that states or their
local jurisdictions provided to school districts, see appendix III.

^11A ninth state distributed DHS funding to its state education agency,
which then provided the funding to public schools in its state.

Although DHS officials told us that some of its emergency planning grant
programs, such as SHSP, UASI, and Citizen Corps allow for the use of funds
at the district or school level, the department's program guidance does
not clearly specify that school districts are among the entities to which
state and local governments may disburse funds.^12 As a result, some
states may not be aware of their availability. For example, state
officials in Alaska and Iowa told us they were not aware that DHS
emergency planning grants could be used by school districts. School
districts in these states do not have the opportunity to benefit from this
funding. In Vermont, one official expressed the view that DHS program
guidance is unclear on the permissible use of these funds.

Eleven of the 49 states^13 responding to surveys we sent to state
education and state administering agencies reported providing state
funding to school districts for emergency management planning (see app. IV
for a listing of these states). For example, the Connecticut State
Department of Education reported that its State Legislature provided
$180,000 for emergency management training in its state. Of these funds,
the state disbursed $30,000 to each of Connecticut's six education centers
to train schools within its region, according to its Department of
Education.^14 To use this funding, the Connecticut State Department of
Education reported that each education center was required to provide a
minimum of three full-day workshops that were open to any school in its
respective region. Hawaii also reported providing approximately $2.1
million to 62 of its 285 schools^15 to assist those schools in contracting
for the services of School Safety Managers (mainly retired law enforcement
officers) in developing school emergency response plans during fiscal
years 2003-2005.

^12DHS guidance for these grant programs provides that state administering
agencies are the only agencies eligible to apply for funding and that they
are responsible for disbursing grant funds to local units of government
and other designated recipients. The guidance identifies a definition of
"local unit of government" which includes "any county, city, village,
town, district, borough, parish, port authority, transit authority,
intercity rail provider, commuter rail system, freight rail provider,
water district, regional planning commission, council of government,
Indian tribe with jurisdiction over Indian country, authorized Tribal
organization, Alaska Native village, independent authority, special
district, or other political subdivision of any State."

^13We included the District of Columbia in our state education and state
administering agency surveys.

In the absence of federal and state sources, schools have been relying on
local school district funds for the emergency management planning that
they have undertaken. Three school districts we visited reported that they
provided funding for emergency management planning in schools. Officials
from a school district in Ohio, Shaker Heights, said that school emergency
management activities are funded from the school district's general fund.
These school district officials told us they spent about $100,000, not
including staff hours and pay, to undertake emergency management planning.
To help prepare for an emergency, officials in Olmsted Falls, Ohio, said
that the school district bought one automated external defibrillator^16
for each of its buildings. Finally, officials from Sequim School District
in Washington told us that they spent $70,000 from their general funds to
install a camera system at one of the two elementary schools located in
their district.

Federal Agencies, State Governments, and School Districts also Provide Guidance,
Training, and Equipment

The federal government also provides guidance, training, and equipment to
school districts to assist in emergency management planning (see table 3).

^14Under Connecticut law, local boards of education, working in
conjunction, are permitted to establish regional educational services
centers, which provide programs and services to schools within their
designated regions. Conn. Gen. Stat. S 10-66a.

^15There were 285 schools (1 school district) in Hawaii as reported by the
state to the U.S. Department of Education.

^16An automated external defibrillator (AED) is a portable electronic
device that diagnoses and treats cardiac arrest by re-establishing an
effective heart rhythm.

Table 3: Examples of Guidance, Training, and Equipment the Federal
Government Provides to School Districts

Examples of Guidance                                                       
      o Education publishes a guide for schools and communities titled        
      Practical Information on Crisis Planning, which explains, among other   
      things, how schools can prepare for an emergency.                       
      o Education created the Emergency Response and Crisis Management        
      Technical Assistance Center to help school districts in emergency       
      management planning. The center provides guidance to school districts   
      through such activities as sharing examples of emergency management     
      plans, assisting with training staff, and evaluating emergency          
      management plans.                                                       
      o DHS created a Web site, How Schools Can Become More Disaster          
      Resistant, that provides guidance for teachers and parents regarding    
      how to prepare emergency management plans. The site also discusses      
      identifying and mitigating hazards, developing response and coping      
      plans, and implementing safety drills.                                  
      o Education funded the development of the National Clearinghouse for    
      Educational Facilities--Disaster Preparedness for Schools. This Web     
      site provides a list of resources (links, books, and journal articles)  
      regarding building or retrofitting schools to withstand natural         
      disasters and terrorism, developing emergency preparedness plans, and   
      using school buildings to shelter community members during emergencies. 
      o The Secret Service, an agency within DHS, collaborated with Education 
      in developing and publishing a Threat Assessment Guide for Schools. The 
      guide was developed following the Columbine High School attack in April 
      1999. Secret Service and Education jointly produced and disseminated a  
      CD-ROM that served as a companion to this guide.                        
Examples of Training                                                       
      o The Federal Emergency Management Agency (FEMA), within DHS, offers    
      online courses including one on emergency management planning for       
      schools.                                                                
      o Education offers two 1- 1/2 day Emergency Management for Schools      
      training sessions that provide school personnel with critical training  
      on emergency management issues, resources, and practices. Emphasis for  
      these trainings is placed on emergency management plan development and  
      enhancement within the framework of four phases of emergency            
      management: prevention and mitigation, preparedness, response, and      
      recovery.                                                               
Examples of Equipment                                                      
      o With funding from DHS and support from Education, the Department of   
      Commerce's National Oceanic & Atmospheric Administration (NOAA)         
      distributed 96,000 NOAA radios to almost all public schools in the      
      United States in 2005 and 2006. These radios are intended to notify     
      school officials of hazards in their area 24 hours a day/7 days a week, 
      even when other means of communication are disabled.^a                  

Source: Education, DHS, and HHS.

aSchools receiving NOAA radios included schools in six states that,
according to DHS, mandate that public schools have radios. These states
are Washington, Tennessee, North Carolina, Maryland, Florida, and
Mississippi. DHS told us that they have procedures in place to allow a
school to request a radio if it did not receive one. DHS officials also
told us that they plan to distribute NOAA radios to non-public schools
(private, independent, parochial and other faith-based institutions),
postsecondary education facilities, and district offices in 2007.

Education, DHS, and HHS have collaborated and developed recommended
practices to assist in preparing for emergencies that can be applied to
school districts.^17 Some of these practices are shown in table 4.

Table 4: Selected Practices That Education, DHS, and HHS Recommend School
Districts Take to Prepare for Emergencies

Recommended practices                                                      
      o Allocate time to emergency management planning.                       
      o Conduct an assessment of vulnerabilities.                             
      o Conduct regular drills.                                               
      o Identify and acquire equipment to mitigate and respond to             
      emergencies.                                                            
      o Identify a storage location and replenish emergency supplies on a     
      regular basis.                                                          
      o Develop an emergency management plan and update the plan on a regular 
      basis. In developing and updating this plan, school districts should:   
                                                                              
              o Identify and address a range of events and hazards specific   
              to the district or schools.                                     
              o Develop roles and responsibilities and procedures for school  
              community members.                                              
              o Develop roles and responsibilities for first responders and   
              community partners.                                             
              o Develop procedures for communicating with key stakeholders    
              such as parents and students, including those who are           
              Limited-English Proficient.                                     
              o Develop procedures for special needs students.                
              o Develop procedures in the plan for recovering from an         
              incident, including continuing student education during an      
              extended school closure.                                        
              o Determine lessons learned after an incident or training.      
              o Develop multi-purpose manuals, with emergency management      
              information, that can be tailored to meet individual school     
              needs.                                                          
                                                                              
      o Include community partners such as local government and public health 
      agencies in planning.                                                   
      o Coordinate the school district's emergency procedures with state and  
      local governments.                                                      
      o Practice the emergency management plan with first responders and      
      community partners on a regular basis.                                  

Source: GAO analysis of Education, DHS, and HHS guidance and training
documents.

We have also recognized the importance of certain of these practices in
our prior reports on emergency management.^18 For example, a central
component of all emergency management plans is defining the roles and
responsibilities of all those with responsibilities for preparing to
respond to an emergency. These roles should be clearly established,
communicated, and understood. We have also emphasized the value of
identifying the types of hazards for which school districts should be
prepared as part of their emergency management efforts. These hazards will
vary across the country; thus, it is appropriate that school emergency
plans include hazards specific to their area. In addition, we have
recognized the importance of realistic training exercises followed by a
careful assessment of those exercises. Those with whom the school
districts should coordinate and train will vary by the type and size of
the emergency. For example, for a potential pandemic flu or other major
infectious outbreak, planning and working with local health authorities
and others is critical. Furthermore, "after action" reports that assess
what went well and what did not go well following real emergency incidents
or exercises, can also contribute to improving emergency management.

^17Education, for example, also obtained input from state and local school
and emergency management officials and associations in developing these
recommended practices.

^18See [36]GAO-07-395T and [37]GAO-06-618 .

The type of guidance available from the federal government on topics
related to emergency management in schools varies significantly; in some
instances federal agencies provide detailed instructions on how to
implement recommended practices while in other instances, guidance is less
detailed. For example, HHS and its Centers for Disease Control and
Prevention (CDC) developed recommended practices with regard to pandemics
and provides school districts with specific recommended steps for planning
and coordination, infection control policies and procedures, and
communications planning. While it also recommends that school districts
plan for the continuity of student learning, its guidance does not provide
specific recommended steps or examples of successful strategies. Rather,
it broadly states that schools should develop scenarios involving short-
and long-term school closures. Likewise, Education's guidance to school
districts, through its recommended practices, clearly states that
districts should incorporate procedures for special needs students in
emergency management plans. However, Education does not provide guidance
on or examples of what those procedures could be.

In addition to the federal government, states provide guidance and
training to school districts. Based on our survey of state administrative
agencies and state education agencies, 47 states reported providing
guidance and 37 states reported providing training. Some states also
reported providing online resources that include guidance and training.
(See app. IV for a listing of these states.) For example:

           o Guidance. South Dakota's Department of Education provides
           guidance on how to distribute food during a crisis or emergency
           event that may occur at schools.

           o Training. The Maryland Department of Education offers periodic
           workshops for school system points-of-contact for emergency
           planning on topics such as threat assessment and pandemic flu.

           o Online Resources. The Idaho Department of Education provides
           links on its Web site to FEMA's course on emergency planning for
           schools and Education's Emergency Response and Crisis Management
           Technical Assistance Center.

Many of the school districts we surveyed also reported providing their
schools with guidance to assist in emergency management planning. For
example, based on our survey, we estimate that 73 percent of all school
districts have an emergency management plan template that includes key
elements schools should include in their plans (see table 5).

Table 5: Key Elements in Emergency Management Plan Templates by Percentage
of School Districts with Written Emergency Management Plans

                                               Estimated percentage of school 
Templates includes                                               districts 
School Campus Plan                                                      95 
Potential use of school facilities                                      93 
School level emergency management team                                  94 
members                                                                    
Procedures for communication with law                                   94 
enforcement                                                                
Procedures for contacting district-level                                92 
incident response team                                                     
ICS positions and staff                                                 76 
Includes special needs student population                               67 

Source: GAO analysis of survey data.

Most Districts Have Taken Steps to Prepare for Emergencies and Developed Written
Plans, but Some Plans Do Not Address Recommended Practices

Almost all school districts have taken steps to prepare for emergencies,
including developing written plans, but some plans lack key elements such
as procedures for special needs students, plans for continued student
education in the event of an extended closure, and procedures for training
regularly with first responders. Most districts, those with and without
plans, have undertaken a variety of federally-recommended activities, such
as conducting vulnerability assessments and school drills and exercises,
as well as additional activities to prepare for an emergency such as
oversight and coordination with other entities. While most districts have
written emergency management plans that address a range of hazards such as
intruders, bombs, and natural disasters, the content of plans varies.
Although most school districts have plans that include roles and
responsibilities for staff, few have procedures for continuing student
education in the event of an extended school closure. Many districts have
procedures in their plans for special needs students, but these procedures
vary in their ability to fully ensure the safety of these students during
an emergency. Fewer than half of all school districts involved a
representative from the local head of government and fewer than half
involved the local public health agency in the development and updating of
their emergency management plans. Finally, we estimate that over
one-quarter of school districts with emergency management plans have never
trained with first responders and over two-thirds of school districts do
not regularly (i.e., at least once a year) train with community partners
on how to implement their school plans.

Most School Districts Have Undertaken Some Emergency Management Activities

Based on our survey of school districts, we estimate that 93 percent of
all school districts conduct inspections of their school buildings and
grounds to identify possible vulnerabilities in accordance with
recommended practices. Of those school districts, 87 percent made security
enhancements to their school facilities and grounds as a result of these
inspections. (See table 6.)

Table 6: Types of Security Enhancements School Districts Made Based on
Vulnerability Assessments

                                                      Estimated percentage of 
Type of security enhancement implemented                  school districts 
Added or enhanced equipment to communicate with                         85 
school employees                                                           
Strengthened the perimeter security of school                           70 
Made inventory changes such as removing hazardous                       69 
materials                                                                  
Enhanced access controls                                                68 
Added or enhanced equipment to communicate with                         41 
law enforcement, fire department, and emergency                            
medical service officials                                                  
Reduced number of portable classrooms                                   10 

Source: GAO analysis of survey data.

A higher percentage of urban school districts have made certain types of
security enhancements to schools in their districts as a result of these
assessments compared with rural school districts. (See fig. 2.)

Figure 2: Estimated Differences in Types of Security Enhancements Made by
Urban and Rural Districts Based on Vulnerability Assessments

Note: Margins of error for rural estimates do not exceed 11 percent.

Based on our survey of school districts, an estimated 73 percent of all
school districts regularly conduct some type of school drill or exercise,
in alignment with recommended practices to prepare for emergency
situations such as evacuations, lockdowns, and shelter-in-place. During
our site visits, we learned that drills were tailored to the needs of the
local community and varied by locality. For example, in Iowa--a state that
is prone to tornados--district officials said the state requires schools
to practice tornado drills twice a year. In Washington--a state that is
prone to earthquakes--district officials stated they practice earthquake
drills twice a year or more.

Our survey of school districts revealed that an estimated 65 percent of
all school districts have a storage location and replenish emergency
supplies such as food, water, and first-aid supplies, as recommended.
During our site visits, school district officials identified a variety of
equipment, supplies, and storage for different types of emergencies. In
Renton, Washington, officials reported storing backpacks in the classrooms
that contain enough food, water, medical supplies, and flashlights, among
other items, for a short-term emergency. For an extended emergency, each
school has a supply of emergency gear that includes: a 2- to 3-day supply
of water, thermal blankets, sanitation needs, and energy bars. Similarly,
school district officials we visited in Des Moines, Iowa, stated they have
two kits for different types of emergencies. The first kit, designed for
school nurses to use in evacuations, is a duffel bag containing medical
supplies such as: bandages, splints, face masks, and eye patches, as well
as equipment such as: folding stretcher, blood pressure kit, stethoscope,
and cold packs. The second kit, designed for custodians, is a garbage can
that contains tools as well as supplies such as a broom, gloves, rope,
water, and bleach, among other items. In contrast, in one Washington
district the disaster kits contain communication equipment, but they do
not include supplies of food or water.

In addition to conducting vulnerability assessments, school drills, and
maintaining emergency supplies, school districts took responsibility for a
number of activities to prepare for emergencies at the district level.
These activities can vary by locality depending on community needs and
include oversight, coordination with other entities, and training. (See
table 7.) For example, in Hardee County, Florida--a district that is
frequently hit by hurricanes--officials stated that the county designated
the schools as shelters for the public and the school district provides
staff, such as maintenance and food service personnel, to work at the
schools as part of a negotiated arrangement. Officials in Pinellas
County--a district that is frequently hit by tornados and hurricanes--told
us they have trained an on-site district level team that coordinates
emergency response activities during an emergency or event.

Table 7: Activities School Districts Have Taken Responsibility for to
Prepare for Emergencies

                                                      Estimated percentage of 
Type of activity                                          school districts 
Ensure school compliance with emergency                                 74 
preparedness requirements                                                  
Negotiate arrangements for use of school buildings                      72 
as temporary shelters                                                      
Coordinate agreements with law enforcement, fire                        68 
department, and emergency medical service                                  
officials                                                                  
Identify security personnel needs at schools                            65 
Identify and train a district-level incident                            62 
response team                                                              

Source: GAO analysis of survey data.

As shown in figure 3, a higher percentage of urban districts took
responsibility for certain types of activities to prepare for an emergency
compared with rural districts.

Figure 3: Estimated Differences in Types of Activities Undertaken by Urban
and Rural Districts to Prepare for Emergencies

aDifferences between urban and rural districts are not statistically
significant.

Most Districts Have Emergency Management Plans That Address Multiple Hazards,
but the Content of Plans Varies Significantly

Most school districts have developed written emergency management plans
that address multiple hazards. Based on our survey of school districts, we
estimate that 95 percent of all school districts have written emergency
management plans with no statistical difference between urban and rural
districts.^19 Of those school districts that have written emergency plans,
nearly all (99.6 percent) address multiple hazards in accordance with
recommended practices to prepare for emergencies. However, the specific
hazards addressed by plans vary. Although most school district plans
address emergency situations arising from intruders or hostages, bombs or
bomb threats, and natural disasters, a smaller percentage of school
districts address pandemic influenza, anthrax, or radiological hazards. A
significantly higher percentage of urban districts address terrorism and
anthrax, for example, compared to rural school districts.^20 (See fig. 4.)

^19Those school districts that did not have a written emergency management
plan cited several reasons for the lack of such plans that included (1) no
requirement to have a written plan, (2) inadequate resources for
experienced personnel to develop emergency plans, and (3) schools, not the
district, have individual plans.

Figure 4: Estimated Percentages of Urban and Rural Districts' Multi-Hazard
Emergency Management Plans That Include Specific Incidents

aDifferences between urban and rural districts are not statistically
significant.

In some instances, the hazards included in emergency plans are specific to
local conditions which is to be expected. For example, school district
officials we visited in Hillsborough, Florida, involved representatives
from the airport in the development of their district plan because airport
traffic was identified as a unique hazard in their local community. In
Ashtabula, Ohio, district officials said their plan addresses evacuations
due to chemical spills because they have a number of chemical plants in
the community.

^20The difference between two estimates is statistically significant if
the probability that the observed or greater difference is due to chance
alone is less than 5 percent (95 percent confidence level).

The extent to which school districts' emergency management plans are
consistent with other recommended practices varies:

Develop Roles and Responsibilities for School Community Members. Based on
our survey, most districts have written roles and responsibilities in
their plans for staff such as superintendents, building engineers or
custodians, principals, teachers, and nurses. Among the plans we reviewed,
some have more detailed instructions on roles and responsibilities than
others. For example, school district officials we visited in Boston,
Massachusetts, have a series of emergency management plans for different
school community members that included district officials, school
administrators, and teachers. The school district document (the Crisis
Command Plan) describes the organizational framework and response
resources that the district will use to manage major emergencies, while a
document for school administrators describes procedures and resources for
school-level incidents. In addition, the district issues a classroom
emergency guide that outlines procedures for teachers to use during an
emergency. In contrast, the district plan for a district in Iowa lists
appropriate actions for specific types of emergencies but does not assign
roles and responsibilities for their implementation.

Develop Roles and Responsibilities for First Responders and Community
Partners. Based on our survey, we estimate that 43 percent of school
districts use the Incident Command System (ICS)--established by DHS as
part of the National Incident Management System (NIMS)^21--to establish
the roles and responsibilities of school district officials, local first
responders, and community partners during an emergency, in accordance with
recommended practices. A significantly higher percentage of urban school
districts--67 percent--were responsible for ensuring that their emergency
plans were in compliance with DHS's NIMS compared to rural school
districts--41 percent.

Develop Procedures for Communicating with Key Stakeholders. Also central
to district emergency plans is the inclusion of procedures for
communicating with key stakeholders such as staff, parents, and students,
including those who are LEP. Our survey suggests that roughly
three-quarters of all school districts have not included written
procedures in their plans for communicating with LEP parents and students,
in accordance with federally recommended practices. A significantly higher
percentage of urban school districts report including procedures for
communicating with such parents and students in their plans compared to
rural school districts. (See table 8.) This difference may, in part, be
explained by the relatively fewer LEP parents and students in rural school
districts.

^21See footnote 10, page 13.

Table 8: Estimated Percentage of School Districts That Have Procedures for
Communicating with Limited-English Proficient Parents and Students in
Their Emergency Management Plans

Limited-English               All school     Urban school     Rural school 
Proficient                     districts        districts        districts 
Parents                               27               59               18 
Students                              28               61               21 

Source: GAO analysis of survey data.

Develop Procedures for Special Needs Students. Although HHS officials and
some education organizations report that the number of special needs
students in the schools is growing, our survey finds that an estimated 28
percent of school districts with emergency management plans do not have
specific provisions for them in their emergency management plans. Although
most school districts reported having procedures for special needs
students, these procedures were not necessarily a part of the written
plan. (See table 9.) However, Education's guidance recommends not only
having procedures for special needs students but including these
procedures in written emergency plans. Officials from two education
associations said the lack of procedures in district plans for evacuating
these students, was a significant concern.^22 According to these
officials, these students may be at increased risk during an emergency.
During our site visits, several school officials who did not have
provisions in their plans for special needs students said it was a school,
not a district-level responsibility. District officials in Marshalltown,
Iowa, for example, said special needs student procedures are the
responsibility of local schools. However, they said that the district does
provide a checklist for schools that includes provisions for special needs
students during an emergency such as communicating to first responders the
location of special needs students who cannot be evacuated due to mobility
impairments. A significantly higher percentage of urban school districts
(77 percent) included procedures for special needs students in their
written plans compared to rural school districts (62 percent). This may be
due, in part, to several reasons such as parents of special needs students
selecting communities to live in based on a district's special needs
resources or districts with low special needs student populations
including procedures for these students in individualized education
programs^23 rather than the district plan.

^22National Education Association and National Association of School
Psychologists.

Table 9: Percentage of School Districts That Use the Following Procedures
for Students with Special Needs in the Event of an Emergency

Procedures for special needs students in an        Estimated percentage of 
emergency                                                 school districts 
Track the location of special needs students                            74 
during the day                                                             
Identify list of district or school staff assigned                      72 
to evacuate or shelter with special needs students                         
during emergency                                                           
Provide devices for transporting special needs                          62 
students to evacuation areas                                               

Source: GAO analysis of survey data.

Note: Responses are not mutually exclusive.

Education officials told us that because there is no agreement among
disability groups on what the best practices are for special needs
students in an emergency, districts usually devise their own
procedures.^24 According to these officials, without the recommendation of
experts, some of these procedures such as keeping special needs students
in their classrooms during some emergencies may not ensure the students
safety in an emergency. The variety of procedures was evident during our
site visits when officials identified several procedures schools use to
incorporate the needs of special needs students in their plans during an
emergency. For example, school district officials in Pinellas County,
Florida, stated that in order to evacuate special needs students during an
emergency they use a buddy system, comprised of school staff, which the
district updates annually. In contrast, officials in a Massachusetts
school district said special needs students must remain in areas of refuge
inside the school building until they are evacuated by first responders.

^23Each student identified as having a disability under the Individuals
with Disabilities Education Act (IDEA) is required to have an
Individualized Education Program. This document outlines the delivery of
educational services and support for that student. While law dictates
minimum requirements for the type of information included in the program,
states and school districts have flexibility in including additional
information in such programs.

^24At a national level, there is also a lack of agreement about a
definition of special needs individuals for the purposes of emergency
management. HHS officials noted that one definition of special needs
individuals, currently being considered for the next revision of the
National Response Plan, will help facilitate awareness and planning for
special needs populations with regard to emergency management.

Develop Procedures for Recovering from an Incident. Over half of all
school districts with written emergency plans include procedures in their
plans to assist with recovering from an incident, in accordance with
recommended practices, such as by restoring district administrative
functions and resuming transportation services. (See table 10.)

Table 10: Types of Recovery Procedures Addressed in School Districts
Written Emergency Management Plans

                                               Estimated percentage of school 
Type of recovery procedure                                       districts 
Providing on-site trauma teams                                          64 
Restoring district administrative functions                             55 
Resuming transportation services                                        53 
Conducting damage assessments of school                                 53 
buildings and grounds                                                      
Locating district employees after a crisis                              49 
is over                                                                    

Source: GAO analysis of survey data.

Develop Procedures for the Continuation of Student Education. Few school
districts' emergency plans contain procedures for continuing student
education in the event of an extended school closure, such as a pandemic
outbreak, although it is a federally recommended practice. Based on our
survey, we estimate that 56 percent of school districts do not include any
of the following procedures (see table 11) in their plans for the
continuation of student education during an extended school closure.
Without such procedures school districts may not be able to educate
students during a school closure that could last from several days to a
year or longer. Moreover, there was no statistical difference between the
percentage of urban and rural school districts that include these
procedures in their written plans. Some school districts we visited stated
they do not have these procedures but are currently working on developing
a continuity of student education plan with their community partners, and
one district official said he would like guidance from the state on how to
provide continued instruction to students during an extended school
closure.^25

Table 11: Percentages of School Districts with Written Plans That Include
Certain Types of Procedures to Continue Student Educational Instruction in
the Event of an Extended School Closure

                                               Estimated percentage of school 
Types of procedure to continue student   districts with written plans that 
educational instruction                                  include procedure 
Electronic or human telephone trees to                                  30 
communicate academic information to                                        
students                                                                   
Web-based distance instruction                                          12 
Mailed lessons and assignments                                          10 
Academic instruction via local radio or                                  7 
television stations                                                        

Source: GAO analysis of survey data.

Note: Responses are not mutually exclusive.

Determine Lessons Learned. Based on our survey of school districts, we
estimate that 38 percent of districts have emergency management plans that
contain procedures for reviewing lessons learned to analyze how well the
plans worked in responding to a drill or emergency. Of the remaining
school districts, 53 percent indicated they have procedures but those
procedures are not included in their plans and 7 percent have no such
procedures.

Develop Multi-Purpose Manuals. Some school districts have multi-purpose
manuals that contain various types of information such as roles and
responsibilities for staff, descriptions of how to respond to different
types of emergencies, as well as site specific information for individual
schools to complete in order to tailor their plan. For example, in Lee
County, North Carolina, the district manual contained a range of materials
and documents for schools to use and complete such as floor plans, student
and faculty rosters, bus routes, and evacuation routes as well as
instructions on the location and handling of utilities, such as gas and
water valves and electrical breaker panels in school buildings, including
a place for photographs for their easy identification. The manual also
identified different types of hazards and delineated administrator and
teacher responsibilities for different types of emergencies. In contrast,
one plan for a district in Washington consisted of a flipchart with
contact information on whom to call during an emergency, and one plan for
a district in Iowa consisted of actions to take for various hazards but
did not outline which staff would be responsible for taking such actions.

^25In at least one school district, Seattle, these plans are included in
the district's Continuity of Operations Plan, which is separate from its
emergency management plan.

About Half of All Districts Involved Local Government, Public Health Agencies,
and Other Partners in Developing and Updating Their Plans and Most Reported Not
Practicing with First Responders

School districts differed in the extent to which they involve community
partner stakeholders in the development and updating of their plans.^26
Fewer than half of school districts with emergency management plans
involve community partners such as the local head of government (43
percent) or the local public health agency (42 percent) when developing
and updating their emergency management plans, as recommended by HHS.^27
During our site visits and survey pretests, school district officials
cited a number of reasons for this lack of involvement, including a
general lack of coordination with local government on emergency management
efforts. Officials cited several benefits in coordinating with local
government entities including the opportunity to share information, take
part in joint training exercises, and receive assistance with their
emergency plans.

While most school districts include at least one representative from the
school and first responder community in the development and updating of
their emergency management plans, fewer involve community partners. (See
table 12.) According to written guidance provided by Education, those
school districts that do not include community partners in the development
and updating of their plans may limit their opportunity to exchange
information with local officials, take advantage of local resources, and
identify gaps in their plan.

^26In our survey, community partners included representatives from: public
health, mental health, local head of government, transportation,
hospitals, Red Cross, faith-based community, and the business community.

^27Twelve percent of school districts do not know whether public health
agencies were included in the development and update of plans. Thirteen
percent of districts do not know whether the local head of government was
included in the development and update of plans.

We estimate that one-third of all school districts (36 percent) have
School Resource Officers (SRO) available at schools during school hours.
An SRO^28 is a fully sworn/commissioned law enforcement officer whose
primary assignment is within the local schools.^29 Of those school
districts that have SROs, 73 percent include procedures in their plan for
involving SROs in the event of an emergency. During our site visits,
school district officials cited several methods they use to involve SROs
in preparing for emergencies such as including them as a stakeholder in
the annual discussion to update the school-level crisis response manual
including procedures for dealing with emergencies, among others. A
significantly higher percentage of urban school districts had SROs
available on school grounds during school hours compared to rural school
districts. We estimate about 81 percent of urban school districts had SROs
available at school campuses during school hours, compared to just 16
percent of rural school districts.

^28This is how we defined an SRO in our survey.

^29Through its COPS (Community Oriented Policing in Schools) in Schools
(CIS) program, the Department of Justice provides three-year grants that
schools may use to hire SROs. The program was designed in part to provide
assistance to law enforcement agencies to help combat violence and reduce
the fear of crime in schools by deploying police officers as SROs.

Table 12: Percentage of School Districts That Involve Stakeholders in the
Development and Update of Written Emergency Management Plans

Stakeholder                Estimated percentage of school districts 
Community Partners                                                  
Local head of government                                         43 
Public health agency                                             42 
American Red Cross                                               30 
First Responders                                                    
Law enforcement                                                  89 
Fire department                                                  85 
Emergency Medical Services                                       67 
School Community                                                    
Superintendent                                                   97 
Teachers                                                         91 
Building engineers                                               83 
Nurses                                                           76 
SROs                                                             42 

Source: GAO analysis of survey data.

More than half of all school districts with emergency management plans
report regularly updating their emergency management plans in accordance
with recommended practices. Specifically, we estimate that 52 percent of
all school districts with emergency plans update these plans at least once
a year. However, 10 percent of all school districts had never updated
their plans. (See table 13.) District officials cited several reasons for
regularly updating their emergency management plans, including (1)
construction modifications or renovations to school buildings, (2) changes
to emergency contact information, (3) procedural changes such as new
drills or evacuation routes, and (4) new legislative requirements, among
others. However, some school district officials we visited had just
recently completed their plans or reported that they had not made any
changes to their plans, since they were first developed. According to
guidance provided by Education, those school districts that do not
regularly update their plans may risk having inaccurate and outdated
information in their plans, which could lead to a delayed response during
an emergency.

Table 13: Frequency of Updates to Emergency Management Plans

                                               Estimated percentage of school 
Frequency of updates                                             districts 
At least once a year                                                    52 
At least once every 2 years                                             14 
At least once every 3 or more years                                     19 
Have not updated the emergency management                               10 
plan                                                                       
After an incident                                                        1 

Source: GAO analysis of survey data.

The frequency with which districts updated their plans differed for urban
and rural areas. A significantly higher percentage of urban school
districts update their emergency management plans annually compared to
rural districts--69 percent versus 43 percent, respectively. Finally, as
many as 13 percent of rural school districts have not updated their
emergency plans at all, compared with 3 percent of urban school districts.

Based on our survey of school districts, we estimate that 55 percent of
school districts with written emergency management plans coordinate them
with city or county emergency response plans. A significantly higher
percentage of urban school districts--78 percent--coordinate their plans
with the local government emergency response plans as compared to rural
school districts (45 percent). For example, in one Ohio school district,
officials told us that the school district plan is a component of the city
plan in that the city will rely upon the district to make selected school
buildings available for use as shelters, if needed in an evacuation.
Likewise, officials in a district in Iowa said that the district plan is
aligned with the county plan in that, during emergencies, the district's
school buses will be used to evacuate persons from the downtown community.
Similarly, in a school district in Massachusetts, officials said that, in
coordination with the local board of health's plan, the district's plan
includes the use of the school facilities as inoculation sites or
quarantine facilities in the event of a large-scale pandemic.

As previously discussed, most school districts identify roles and
responsibilities for first responders and involve them in developing and
updating their plans. However, based on our survey, we estimate that 27
percent of all school districts with emergency management plans have never
trained with any first responders on how to implement the plans, in
accordance with federally recommended practices. Furthermore, we estimate
that about three-quarters of all school districts do not regularly train
(i.e., at least once a year) with each type of first responder--law
enforcement, fire, or EMS--on how to implement the school district plan.
(See table 14.) The reasons why school districts are not training with
first responders are not readily apparent. As we have previously reported,
involving first responder groups in training and exercise programs can
better familiarize and prepare first responders with their roles in an
emergency as well as assess the effectiveness of a school or district's
emergency plan.^30 Without such training, school districts and their first
responder partners may be at risk of not responding effectively during a
school emergency.

Table 14: Estimated Frequency of Training with Each Type of First
Responder on How to Implement the School District Emergency Management
Plan

                                                            Emergency Medical 
                               Law enforcement Firefighters  Services (EMS)^a 
Frequency of training Percentage Percentage                     Percentage
At least once a year                     33           31                25 
At least once every 2                    15           15                11 
years                                                                      
At least once every 3                    19           19                17 
or more years                                                              
Never                                    33           34                46 

Source: GAO analysis of survey data.

Notes: All responses are mutually exclusive. Due to rounding, percentages
in each column may not sum to 100.

aDuring our site visits some officials told us that their emergency
medical service providers were part of the fire department, not a separate
entity.

A significantly higher percentage of urban school districts annually train
with law enforcement and firefighters on the school district emergency
plan. We estimate that nearly half of urban districts annually train
together with law enforcement (42 percent) and firefighters (43 percent)
on the school district emergency plan, whereas less than one-quarter of
rural school districts train annually with law enforcement (23 percent)
and firefighters (23 percent).

School districts report training with community partners--such as local
public health and local government entities--on activities to prepare for
an emergency with similar frequency. Specifically, we estimate that 29
percent of all school districts train with community partners. As with
first responders, the reasons for the lack of training with community
partners are not readily apparent. In our work on Hurricane Katrina, we
reported that involving local community partners in exercise programs and
training could help prepare community partners and enhance their
understanding of their roles in an emergency as well as help assess the
effectiveness of a school district's emergency plan.^31 Without such
training, school districts and their community partners may not fully
understand their roles and responsibilities and could be at risk of not
responding effectively during a school emergency.

^30See [38]GAO-06-618 .

Training differed for urban and rural areas. A significantly higher
percentage of urban school districts train with community partners on how
to implement the school district plan compared to rural school
districts--45 percent versus 26 percent.

Some school districts collaborate with community partners on other aspects
of emergency preparedness. For example, one component of the Citizen Corps
program--Community Emergency Response Teams--instructs citizens on how to
respond to emergencies (e.g., first aid) and participants, in turn,
provide instruction to others. An official with the Highlands County,
Florida school district said that 50 school district employees have
participated in a Community Emergency Response Teams program. Likewise, in
Olmstead Falls, Ohio, school district officials have coordinated with the
American Red Cross in conducting a pandemic immunization drill in school
facilities.

^31See [39]GAO-06-618 .

School Districts Report Challenges in Planning for Emergencies as Well as
Difficulties in Communicating with First Responders and Parents, but No
Challenges in Communicating with Students

In planning for emergencies, many school districts face challenges
resulting from competing priorities, a lack of equipment, and limited
expertise; some school districts experience difficulties in communicating
and coordinating with first responders and parents, but most do not have
such challenges with students. Within their own districts, officials
struggle to balance activities related to educating their students with
those related to recommended practices for emergency management. Officials
also confront a shortage of equipment and expertise necessary for planning
and responding to emergencies. In some cases, officials noted that it was
particularly challenging to plan for special needs students in the absence
of such equipment and expertise. Less prevalent among school districts
were problems in communicating and coordinating with first responders and
parents.

Competing Priorities, Lack of Equipment, and Limited Expertise Are Obstacles to
Implementing Recommended Practices in Emergency Management Planning

School district officials who responded to our survey reported difficulty
in following the recommended practice of allocating time to emergency
management planning, given the higher priority and competing demand on
their time for educating students and carrying out other administrative
responsibilities. Based on our survey of school districts, we estimate
that in 70 percent of all districts, officials consider competing
priorities to be a challenge to planning for emergencies. In at least two
districts we visited, officials said that they have a limited number of
staff development days^32 and they want to use the time to train staff on
instruction rather than emergency planning. For example, in one Florida
district, officials noted that only two days a year were available for
staff development, making it difficult to cover emergency planning as well
as federal and state requirements for schools. Officials in a North
Carolina district said although they had the instructors they needed, they
forfeited some emergency planning activities after the allotted number of
staff development days were cut short.

In an estimated 62 percent of districts, officials cited a lack of
equipment and expertise as impediments to emergency planning. In the
course of our site visits, officials focused primarily on shortages of
three types of equipment: equipment to control or monitor school grounds,
such as locks on doors and surveillance equipment; equipment to evacuate
or maintain a shelter-in-place for students and staff; and communications
equipment, such as two-way radios and satellite phones. Officials in one
Massachusetts school district reported that they do not have adequate
locks on some of the doors to school buildings to implement a lockdown
procedure, for example. Other districts lacked fencing for school grounds
or surveillance cameras for school buildings. Officials also described a
lack of sufficient equipment to maintain a shelter-in-place or evacuate
students. Five of the 27 school districts we interviewed reported that
they do not have generators to maintain power in school buildings. One
superintendent in Washington noted that the district's only school
building is located in a remote mountainous area that could be
inaccessible in the event of an earthquake or heavy snowfall that blocked
the few access roads in and out of the community. Yet, according to this
superintendent, the district does not have a generator to supply
electricity in the event of such an emergency. Although the officials in
one Massachusetts school district did not report problems maintaining a
shelter-in-place facility, they said the district did not have enough
school buses to accommodate all of the students in the case of evacuation.
Finally, school officials in the districts we visited discussed a lack of
equipment to facilitate communication during emergencies. In one North
Carolina district, officials said a lack of two-way radios for staff in
the elementary schools hinders their ability to communicate with one
another and with first responders during an emergency.^33 Similarly, in
one Washington school district, the superintendent told us the district
does not have satellite two-way radios that are needed in case
conventional cellular telephones do not operate under the severe weather
conditions common to the remote and mountainous location. In a district in
Iowa, officials reported a need to replace their aging two-way radios
because the radios' signals cannot penetrate the walls of the school
buildings. Officials in four additional districts stated that their
districts need to update or maintain communication equipment. As
demonstrated in these school districts, the lack of equipment prevents
districts from implementing the procedures in their plans and hinders
communication among district staff and with first responders during
emergencies.

^32Districts allocate staff development days to assist teachers and other
staff with improving skills, provide training, and meet certification
requirements, among other activities.

^33Two-way radios, commonly known as walkie-talkies, are radios that can
alternate between receiving and transmitting messages. Cellular telephones
and satellite telephones are also two-way radios but, unlike
walkie-talkies, simultaneously receive and transmit messages.

In addition to not having sufficient equipment, school district officials
we spoke with described a shortage of expertise in both planning for and
managing emergencies. These officials said their districts lacked
specialized personnel and training with which to develop needed expertise.
One Washington state superintendent said he needed to provide those staff
most likely to be present in an emergency with training on emergency
management but would need additional funding to do so. District officials
in 5 of the 27 districts noted that they do not having sufficient funding
to hire full-time emergency management staff to provide such training or
take responsibility for updating their district plans.^34 Still, other
officials described an unmet need for specific staff positions such as
either an SRO or a school nurse to assist in planning for and responding
to emergencies. According to officials in a North Carolina district, due
to a shortage of funding, the district did not have SROs for the
district's elementary schools. In this district, the SROs have a role in
providing comments on the emergency plans of the schools to which they are
assigned before those plans are submitted to the district for annual
reviews. Similarly, officials in the Lee County district of North Carolina
reported a shortage of school nurses, which they said could precipitate a
medical crisis in an evacuation on days when a nurse is not available to
distribute student medications or attend to those who may become ill.
These officials noted that the lack of expertise makes it difficult to
adequately plan for responding to emergencies.

As previously discussed, school districts reported challenges in
incorporating special needs students in emergency management planning.
According to officials in about half (13 of 27) of the districts in which
we conducted interviews, a lack of equipment or expertise poses challenges
for districts--particularly in the area of evacuating special needs
students. In one Massachusetts school district, while schools assign
persons to special needs students for evacuations, officials reported that
these persons or "buddies" are typically other students, rather than
experienced personnel.^35 The students may not always be in the same
classes as the students to whom they are assigned or may be absent from
school on the day of the emergency. An official in a Washington school
district said that the district tracks the location of special needs
students, but many of the district's schools do not have evacuation
equipment (e.g., evacuation chairs used to transport disabled persons down
a flight of stairs) to remove students from buildings and staff need more
training on how to operate the existing equipment. Lee County, North
Carolina, district officials reported that a shortage of nurses across the
district has led to difficulties in meeting the medical needs of special
needs students during evacuations, because nurses are the only staff
permitted to physically remove medical supplies and distribute medicine.
Because coordination with first responders often occurs at the district
level, delegating responsibility for planning for special needs students
to individual schools can result in a lack of information for first
responders. In one school district in Ohio, a fire department official we
interviewed was unaware that the schools in his area had assigned special
aides to help evacuate special needs students.

^34Three districts, Hardee County, Florida; Ashtabula, Ohio; and Durham,
North Carolina, reported needing a full-time staff person to train staff.
Two districts, Olmsted Falls, Ohio, and Hanover, Massachusetts, reported
needing a full-time staff person to update the district plan.

^35At the time of our visit, the school district used this practice for
its special needs students. However, in a subsequent e-mail message a
district official noted the district no longer uses students as buddies.

School district officials who reported challenges in planning for special
needs students also identified challenges in adequately planning for
temporarily disabled students (e.g., a student with a broken leg),
maintaining a supply of surplus medical supplies for students with special
needs, and ensuring the district maintains privacy standards related to
the conditions of special needs students during emergencies. Finally,
officials in three school districts stated that the districts' school
buildings are not all in compliance with the Americans with Disabilities
Act standards,^36 thus limiting the district's ability to adequately plan
for students with special needs.

^36The Americans with Disabilities Act of 1990 and Section 504 of the
Rehabilitation Act of 1973 generally require that school facilities be
accessible to individuals with disabilities, although there is some
variation in requirements depending on whether a building is new or
existing. The ADA Accessibility Guidelines for Buildings and Facilities
specify the technical requirements for accessibility and address such
issues as the design of doorways, stairwells, elevators, and ramps.

Some School Districts Reported Difficulty in Communicating and Coordinating with
First Responders and Parents

Based on our survey of school districts, an estimated 39 percent of
districts with emergency plans experience challenges in communicating and
coordinating with local first responders.^37 Specifically, these school
districts experience a lack of partnerships with all or specific first
responders, limited time or funding to collaborate with first responders
on plans for emergencies, or a lack of interoperability between the
equipment used by the school district and equipment used by first
responders.

The superintendent of a Washington school district said that law
enforcement has not been responsive to the district's requests to
participate in emergency drills, and, in addition to never having had a
district wide drill with first responders, competition among city, county,
and private first responders has made it difficult for the school district
to know with which first responder entity it should coordinate. In another
Washington district, the superintendent reported not having a local law
enforcement entity in the community, but rather, a deputy from the county
sheriff's department that drives through the local community twice a day.
This superintendent said that based on an absence of a relationship with
law enforcement, he assumed that his district was essentially "on its own"
in responding to emergencies. According to guidance provided by Education,
the lack of partnerships, as demonstrated in these school districts, can
lead to an absence of training that prevents schools and first responders
from understanding their roles and responsibilities during emergencies.

Even when forming partnerships is not a problem, school districts may be
unable to find sufficient time or funding to meet with first responders on
issues related to emergency management planning. An official in the
Chatham, North Carolina, district said that it is difficult to find a
convenient time for both first responders and school district officials to
meet and discuss the district's plan. According to an official in the
Seattle school district, first responders for the district are more likely
to meet with the school district when there are funds available to pay
both first responders and district staff for such efforts. Officials in an
Ohio district said that while first responders drill in school facilities
over the weekends, the district does not have additional funding or staff
to conduct these drills during school hours.

^37Thirteen percent of school districts reported not knowing whether the
district has challenges related to first responders.

Finally, officials we interviewed described a lack of interoperable
equipment as a hindrance to communicating with first responders during
emergencies. In 8 of the 27 districts in which we conducted interviews,
officials said that the two-way radios or other equipment used in their
school districts lacked interoperability with the radios used by first
responders. Officials in an Iowa district said that the lack of
interoperability among first responders^38 impacts the district's ability
to communicate during emergencies because the district shares a radio
frequency with some first responders but not others.

School Districts Have Methods to Communicate with Parents, but Face Challenges
in Ensuring Parents Receive Consistent Information during Incidents

In keeping with recommended practices that call for school districts to
have a way to contact parents of students enrolled in the district, all of
the school districts we interviewed had ways of communicating emergency
procedures to parents prior to (e.g., newsletters), during (e.g., media,
telephone), and after an incident (e.g., letters). Eleven of these
districts have a system that can send instant electronic and telephone
messages to parents of students in the district. Despite these methods, 16
of the 27 districts we interviewed experience difficulties in implementing
the recommended practice that school districts communicate clear,
consistent, and appropriate information to parents regarding an emergency.
For example, officials in a Florida school district said that with
students' increased access to cellular telephones, parents often arrive on
school grounds during an incident to pick up their children before the
district has an opportunity to provide parents with information. Thus,
according to these officials, the district experiences challenges in
simultaneously maintaining control of both the emergency situation and
access to school grounds by parents and others. Other districts discussed
challenges in providing messages, during emergencies, with instructions to
parents for reuniting with their children. Officials in the Boston school
district said that having inaccurate telephone numbers for parents
prevented the district from delivering messages to all parents during or
after emergencies. Representatives of three education associations^39 also
noted that school districts have much to do to ensure that their emergency
management efforts diffuse confusion during emergencies and provide
parents with consistent information.

^38GAO has reported on the range of issues associated with the lack of
interoperability among first responders and the implications of these
issues for emergency management. For a fuller discussion of these issues,
see the following GAO reports: First Responders: Much Work Remains to
Improve Communications Interoperability, [40]GAO-07-301 (Washington, D.C.:
Apr. 2, 2007); Catastrophic Disasters: Enhanced Leadership, Capabilities,
and Accountability Controls Will Improve the Effectiveness of the Nation's
Preparedness, Response, and Recovery System, [41]GAO-06-618 (Washington,
D.C.: Sept. 6, 2006); and Homeland Security: Federal Leadership and
Intergovernmental Cooperation Required to Achieve First Responder
Interoperable Communications, [42]GAO-04-740 (Washington, D.C.: July 20,
2004).

Based on our survey of school districts, an estimated 39 percent of all
school districts provide translators to communicate with LEP parents
during emergencies, but fewer--an estimated 23 percent of all
districts--provide translations of emergency management materials.
Officials in 8 of the 27 districts we interviewed discussed challenges in
retaining bilingual staff to conduct translations of the districts'
messages or in reaching parents who do not speak the languages or dialects
the district translates. In Seattle, where the district provides
translations of 10 of the 47 languages spoken in the schools, the official
we interviewed said that staff often experience "burn out" due to their
dual roles as interpreters and liaisons between the local community and
school district. The problem in retaining bilingual staff was not related
to the level of work required by interpreters in the Hardee County,
Florida, school district, but with the district's inability to recruit
qualified bilingual staff who also want to reside in the rural,
hurricane-prone community. In two different districts, officials were
unsure of whether the district's emergency messages reached parents who
did not speak the translated languages provided by the school district.
Officials in the Pinellas County school district said that they were
unsure about the district's success in getting emergency management
information to parents who speak 1 of the 107 languages for which the
district does not provide translations. Difficulties in accommodating
dialects was also cited by an official of the Ashtabula, Ohio, school
district because staff there have encountered problems ensuring the
messages translated by telephone were understood due to the differences in
dialects of Spanish spoken by some parents and the school officials
providing the translated message. Our findings, while limited to the
districts in which we conducted interviews, are consistent with the
observations of some national education groups that have indicated that
districts, in part due to limited funding, struggle to effectively
communicate emergency-related information to this population of parents.

While school districts experience a range of challenges in planning for
emergencies and in communicating and coordinating with first responders
and parents, officials in all but one of the districts in which we
conducted interviews said that the district did not have problems
communicating emergency procedures to students. While some of these
officials did not provide reasons, as we previously reported, most
districts regularly practice their emergency management plans with their
students and staff.

^39National Education Association, American Association of School
Administrators, and National Association of Secondary School Principals.

Conclusions

While emergency management is overwhelmingly a state and local
responsibility, the federal government plays a critical role in
disseminating information on best practices, providing guidance, and
giving states flexibility to target federal funding to areas of greatest
need. While all three federal agencies involved in emergency management
planning for schools have provided some resources, additional access to
federal resources would enhance the ability of school districts to plan
and prepare for emergencies. Given the challenges many school districts
face due to a lack of necessary equipment and expertise, they do not have
the tools to support the plans they have in place and, therefore, school
districts are left with gaps in their ability to fully prepare for
emergencies. Making it clear to states and local governments that school
districts are among the entities to which they may disburse certain grant
funds they have received from DHS would be one way to diversify the
available emergency management resources to which school districts have
access.

School districts have taken a number of important steps to plan for a
range of emergencies, most notably developing emergency management plans;
however, in many districts these plans or their implementation do not
align with federally recommended practices. For example, because most
districts' plans do not have procedures to ensure the continuity of
education in the event of extended school closures, such as those caused
by a pandemic or natural disasters, school districts, both urban and
rural, are largely not prepared to continue their primary mission of
educating students. Unless the federal government examines strategies for
planning for on-going student instruction in the event of extended school
closures and determines which of those strategies are successful, schools
may not have the information they need to put in place a plan that will
adequately prepare them for emergencies that require such a response. In
addition, while most districts have procedures for special needs students
in place, because there is no agreement on procedures school districts
should use with such students, districts may employ less than optimal or
even risky procedures for evacuating or sheltering these students in an
emergency. Further, while the reasons are not readily apparent and can
vary as to why school districts do not train with first responders and
community partners, by not training together, school districts, first
responders, and community partners may limit their ability to effectively
respond to and mitigate the impact of emergencies when they occur. If the
federal government had information on why school districts do not train
with first responders and community partners, it would be better
positioned to provide assistance to school districts that would enable
them to train with first responders and community partners on a regular
basis.

Finally, our findings show that in some areas there are vast differences
in how urban and rural districts prepare for emergencies and it appears
that urban districts are taking more actions as suggested by recommended
practices to prepare for incidents. It may not be possible for urban and
rural school districts to plan equally given differences in geography,
resources, expertise, and other demographics that may warrant different
approaches. However, it is important that all districts include key
procedures, cover the full range of incidents that could affect them, and
practice their plans to prepare for emergencies because some incidents,
such as natural disasters, may impact urban and rural districts alike.

Recommendations for Executive Action

To help address the challenges school districts face in planning for
emergencies, we recommend that the Secretary of DHS clarify that school
districts are among those entities to which state and local governments
may disburse grant funds received through the State Homeland Security
Program, Urban Areas Security Initiative, and Citizens Corps grant
programs. This should be done through its guidance for these programs so
that states and local governments will know they can disburse these
program funds to school districts.

To address the lack of procedures for continuing student education in the
event of an extended school closure, we recommend that the Secretary of
Education collaborate with the Secretary of HHS in his role as head of the
lead agency on pandemics, to examine and identify successful strategies
for developing such procedures and provide guidance to school districts on
how to include the resulting procedures for the continuation of student
education in their emergency management plans. These agencies may consider
providing specific suggestions for states and districts to work with state
education agencies, health departments, and local community organizations
in the process of developing these procedures.

To help school districts shelter or evacuate students with special needs
and temporarily disabled students in an emergency, we recommend that the
Secretary of Education, in collaboration with the Secretaries of DHS and
HHS, examine and identify successful procedures for sheltering and
removing such students from school buildings and share these procedures
with school districts.

To promote training between school districts and first responders and
between school districts and community partners on how to implement
district emergency management plans, we recommend that the Secretaries of
DHS and Education identify the factors that prevent school districts,
first responders, and community partners from training together and
develop strategies for addressing those factors. These strategies should
include the continued use of any current resources that could facilitate
joint training. DHS and Education should share the strategies with school
districts, first responders, and community partners and encourage them to
consider implementing the strategies as appropriate.

Agency Comments and Our Evaluation

We provided a draft of this report to DHS, Education, and HHS for review
and comment. DHS provided written comments on May 16, 2007, which are
presented in appendix V. In commenting on the draft report, DHS generally
agreed with the intent of our first recommendation that it clarify that
school districts are eligible entities to which states and local
governments may disburse emergency management funding. While the
department stated that it would continue to alert states and local
governments of school districts' eligibility through such activities as
site visits and workshops, it did not comment on whether it would modify
its program guidelines. Taking the opportunity to remind states and local
governments of school districts' eligibility in such one-on-one settings
should help to increase awareness of school districts' eligibility.
However, we continue to believe that DHS should explicitly include school
districts in its program guidance, so that all state and local governments
receiving homeland security funds would have access to guidance that
provides a clear understanding of how to use the funding. DHS disagreed
with the language in our fourth recommendation that the department
collaborate with Education to identify and address the factors that
prevent training among school districts, first responders, and community
partners. DHS suggested that we modify the recommendation to acknowledge
the need for DHS and Education to promote current resources in addressing
these factors. We agree with DHS's suggestion and have revised the
recommendation to recognize the need for DHS and Education to promote
current resources. DHS also suggested that we include a discussion of the
Citizen Corp Council in the report as a resource for collaboration among
local governments, the private sector, and non-profit entities including
school districts. We agree and have revised the report to include
information on the Citizen Corp Council.

Education provided written comments on May 7, 2007, which are included in
appendix VI. Education agreed with all four of our recommendations, but
expressed concern about our statement that there are no federal
requirements for school districts to have emergency management plans,
pointing to a requirement in the No Child Left Behind Act (NCLBA) relating
to safe and drug-free schools. As we explain in the report, we did not
consider plans required under NCLBA to be emergency management plans for
purposes of our report because these plans are not required to address
multiple hazards. While Education acknowledged that we had included this
information in a footnote, it stated that the footnote appeared only once.
We have revised the report to more prominently display this information.

HHS provided written comments on our draft report on May 8, 2007, which
are presented in appendix VII. HHS generally agreed with our
recommendations. However, HHS requested that Education take the lead with
respect to our second recommendation that both agencies provide guidance
to school districts on the continuation of education during extended
school closures because Education is responsible for leading federal
efforts related to the education process. We discussed the issue with
Education officials and they agreed to take the lead on this
recommendation. Thus, we modified the recommendation accordingly. HHS also
requested that we include it in our third recommendation to provide
guidance on evacuating and sheltering special needs students because of
the agency's expertise on special needs students. We agree and have
modified the recommendation to include HHS.

DHS, Education, and HHS also provided technical comments, which we
incorporated where appropriate.

We are sending copies of this report to the Secretaries of Education, DHS,
HHS, and relevant congressional committees. We will also make copies
available to others upon request. In addition, the report will be made
available at no charge on GAO's Web site at http://www.gao.gov .

Please contact us at (202) 512-7215 or (202) 512-8757 if you or your staff
have any questions about this report. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. Major contributors are listed in appendix VI.

Cornelia M. Ashby, Director
Education, Workforce and Income Security Issues

William O. Jenkins, Jr., Director
Homeland Security and Justice Issues

Appendix I: Scope and Methodology

To obtain information on federal, state, and local roles and requirements
for school districts, how school districts prepare and plan, and any
challenges in doing so, we interviewed staff in the Departments of
Education, Homeland Security, and Health and Human Services; conducted an
e-mail survey of state education agencies and an e-mail survey of state
administering agencies; and conducted a mail survey of school districts
from a stratified random sample of public school districts. We also
conducted site visits during which we interviewed district officials,
security administrators, and other officials in 27 school districts in six
states. We conducted our work from April 2006 through March 2007 in
accordance with generally accepted government auditing standards.

Survey of States

To better understand the role of states in how school districts prepare
for emergencies, we designed and administered two surveys--one to state
education agencies and a separate, but similar, one to state administering
agencies--to all 50 states and the District of Columbia. The survey to
state education agencies was conducted between August 2006 and October
2006. The survey included questions about laws that require school
districts to have emergency management plans, state funding provided to
school districts, and any other resources provided to school districts.
The survey of state administering agencies was conducted between November
2006 and January 2007. The survey also included questions about laws
requiring school districts to have emergency management plans, state
funding provided to school districts, and other resources. In this survey
we specifically asked about whether the state allocated portions of the
State Homeland Security Program (SHSP), Urban Areas Security Initiative
(UASI), and Citizen Corps grants to school districts. In 19 states, there
were no UASI funds provided and we did not ask about funding related to
this program for those states.

The practical difficulties of conducting any survey may introduce
nonsampling errors, such as variations in how respondents interpret
questions and their willingness to offer accurate responses. We took steps
to minimize nonsampling errors, including pretesting draft instruments and
following up on specific responses. Specifically, during survey
development, we pretested draft instruments with various officials. For
the survey to state administering agencies, we pretested with officials
representing state administering agencies in California and Maryland in
November 2006. In the pretests, we were generally interested in the
clarity of the questions and the flow and layout of the survey. For
example, we wanted to ensure definitions used in the surveys were clear
and known to the respondents, categories provided in closed-ended
questions were complete and exclusive, and the ordering of survey sections
and the questions within each section was appropriate.

We analyzed the requirements for schools and districts to have emergency
management plans that were reported to us by states. In some cases, we
determined that the laws or other requirements reported in these surveys
did not constitute emergency management planning requirements for purposes
of this report. Accordingly, these survey responses are not included in
our analysis of state requirements. We did not conduct any independent
legal research to identify state legal requirements in this area.

Survey of School Districts

To obtain national-level information on school district management
planning, we administered a mail survey to a stratified random sample of
public school districts. The survey was conducted between September 2006
and January 2007. To obtain the maximum number of responses to our survey,
we sent a follow-up mailing with the full survey instrument to
nonrespondents approximately 3 weeks after the initial mailing, and a
reminder postcard to nonrespondents approximately 4 weeks after the
initial mailing of the survey instrument. The survey included questions
about whether school districts had emergency management plans, activities
related to emergency management plans, characteristics of plans, district
requirements of schools, and coordination with various persons in the
school environment, local community, and first responders.

Population

The target population of 14,432 districts consisted of public school
districts in the 50 states and the District of Columbia with at least one
school in each of their jurisdictions in the 2003-2004 school year.^1 We
used Education's Common Core of Data (CCD) Local Education Agency (School
District) file for the 2003-2004 school year (version 1b) as the basis of
defining our population. To define our sampling frame, we removed
districts from the CCD that were not a component of a supervisory union;
state and federally-operated institutions; other education agencies; had
less than 1 student; were closed; run by the Department of Defense or
Bureau of Indian Affairs; or located in American Samoa, Guam, Northern
Marianas, Puerto Rico, or the Virgin Islands. On the basis of our review
of these data, we determined this source to be adequate for the purposes
of our work.

^1We arrived at our target population of 14,432 by eliminating certain
types of school districts such as: local school districts that are not a
component of a supervisory union, state-operated institutions charged, at
least in part, with providing elementary and/or secondary instruction or
services to a special-need population; federally operated institutions
charged, at least in part, with providing elementary and/or secondary
instruction or services to a special-need population, districts with less
than one student or one school, agencies run by the Department of Defense
or Bureau of Indian Affairs, and districts in U.S. territories.

Sample Design and Errors

The sample design for the mail survey was a stratified random sample of
districts with two certainty strata containing all of the urban and urban
fringe districts with over 100,000 students. We defined the strata
classifications using the locale code in the CCD. We chose districts with
the largest number of students with certainty because the total number of
students in these districts makes up nearly 13 percent of the total
students in our universe. We also included four additional strata--urban,
urban fringe, towns, and rural. Table 15 provides a description of the
universe and sample of districts.

Table 15: Description of the Population and Sample of Districts

Stratum            Population/universe Sample size 
Large urban                         12          12 
Large urban fringe                  14          14 
Urban                              860         125 
Urban fringe                     3,795         135 
Town                             1,785         132 
Rural                            7,966         136 
Total                           14,432         554 

Source: GAO.

We used the metro-centric locale codes assigned to each district in the
03-04 CCD to define urban and rural. We defined urban districts to be
those districts within a central city of a Core Based Statistical Area or
Consolidated Statistical Area (locale codes 1 and 2). Generally, those are
considered to be a central city of a Core Based Statistical Area (CBSA) or
Consolidated Statistical Area (CSA), with the city having a population
greater than or equal to 250,000 (for locale code 1) or a central city of
a CBSA or CSA, with the city having a population less than 250,000 (for
locale 2). Rural districts are any incorporated place, Census-designated
place, or non-place territory and defined as rural by the Census Bureau
(locale codes 7 and 8). These are generally defined as any incorporated
place, Census-designated place, or non-place territory not within a CBSA
or CSA of a large or mid-size city and defined as rural by the Census
Bureau; and any incorporated place, Census-designated place, or non-place
territory within a CBSA or CSA of a large or mid-size city and defined as
rural by the Census Bureau.

Because we surveyed a sample of districts, our results are estimates of a
population of districts and thus are subject to sampling errors that are
associated with samples of this size and type. Our confidence in the
precision of the results from this sample is expressed in 95 percent
confidence intervals, which are expected to include the actual results in
95 percent of the samples of this type. We calculated confidence intervals
for this sample based on methods that are appropriate for a stratified
random sample. We determined that nine of the sampled districts were out
of scope because they were not considered to be school districts. All
estimates produced from the sample and presented in this report are for
the estimated target population of 14,131 districts with at least one
school in the 2003-2004 school year. All percentage estimates included in
this report have margins of error of plus or minus 10 percentage points or
less, unless otherwise noted.

We took steps to minimize nonsampling errors that are not accounted for
through statistical tests, like sampling errors. In developing the mail
survey, we conducted several pretests of draft instruments. We pretested
the survey instrument with district officials in six districts--Baltimore
County, Maryland; Carbon County, Wyoming; Citrus County, Florida; Muleshoe
Independent, Texas; Santa Fe Public Schools, New Mexico; and Vigo County,
Indiana--between July 25, 2006, and August 18, 2006. On the basis of the
pretests, the draft survey instrument underwent some revisions.

Response Rate

We received survey responses from 444, or 80 percent, of the 554 school
districts in the sample.

Site Visits

To understand emergency management planning at the local level, we
conducted site visits and conducted interviews in six states between
September 27, 2006, and November 15, 2006. The states we visited included
Florida, Iowa, Massachusetts, North Carolina, Ohio, and Washington. In
each state, to the extent possible, we visited or interviewed (by
telephone) at least one district that corresponded to the strata in our
survey of school districts. We selected states and school districts that
included recommended practices, some that did and did not receive federal
funding for emergency management, both urban and rural districts, and
those representing geographic diversity. When viewed as a group, the
states and school districts also provided variation across characteristics
such as geographic location, district size, student populations, and the
percentage of students with Limited-English proficiency or disabilities.
We conducted a pretest of questions used in the site visits with the
Alleghany County Public Schools district, in Maryland, on September 13,
2006. We used this interview to determine whether our interview questions
were clear as well as to gauge the amount of time the interviews would
take.

In total, we interviewed officials in 27 school districts. Through our
interviews with district officials, we collected information on the role
of the school district in emergency management planning, state or local
requirements, whether the district received federal, state, or local
funding and guidance, and experiences in communicating and coordinating
with first responders, parents, and students. Table 16 indicates the
school districts we visited during site visits or interviewed, the
corresponding locale code, and other selected characteristics.

Table 16: School Districts Interviewed or Visited during Site Visits

                            Common                                            
                           Core of                         Number of students 
                              Data                             categorized as 
                            Locale Number of Number of        Limited-English 
    District                  Code   schools  students       Proficient (LEP) 
Florida
    Pinellas County      2 (urban)       174   113,651                  3,204 
    School District                                                           
    Hillsborough County   3 (urban       258   189,469                 19,686 
    School District        fringe)                                            
    Hardee County School  6 (town)         9     5,146                    450 
    District                                                                  
    Highlands County     7 (rural)        18    12,049                    517 
    School District                                                           
Washington
    Seattle School       1 (urban)       111    46,746                  5,752 
    District                                                                  
    Renton School        2 (urban)        26    13,236                  1,485 
    District                                                                  
    Sequim School         6 (town)         5     2,950                     48 
    District                                                                  
    Skykomish School     8 (rural)         2        70                      2 
    District                                                                  
    Index School         8 (rural)         1        30                      0 
    District                                                                  
Iowa
    Des Moines           2 (urban)        72    32,194                  3,502 
    Independent                                                               
    Community School                                                          
    District                                                                  
    West Des Moines       4 (urban        15     8,491                    246 
    Community School       fringe)                                            
    District                                                                  
    Marshalltown          5 (town)         9     4,922                  1,203 
    Community School                                                          
    District                                                                  
    Bondurant-Farrar     8 (rural)         2     1,042                      0 
    Community School                                                          
    District                                                                  
Massachusetts
    Boston Public        1 (urban)       136    57,742                  9,789 
    Schools                                                                   
    Holliston Public      3 (urban         4     3,035                      1 
    Schools^a              fringe)                                            
    Hanover Public        3 (urban         5     2,809                      2 
    School District        fringe)                                            
    Greenfield Public     6 (town)         7      1948                     91 
    Schools                                                                   
    Mashpee Public       8 (rural)         3     2,108                      6 
    School System                                                             
North Carolina
    Durham City Schools  2 (urban)        45    30,955                  2,925 
    Wake County Schools   3 (urban       132   114,568                  6,777 
                           fringe)                                            
    Lee County Schools    6 (town)        12     9,242                  1,104 
    Granville County     7 (rural)        14     8,674                    452 
    Schools                                                                   
    Chatham County       8 (rural)        15     7,404                  1,004 
    Schools^a                                                                 
Ohio
    Cleveland Municipal  (1) urban       122    64,670                  3,119 
    Schools                                                                   
    Shaker Heights        3 (urban         9     5,737                     79 
    Schools                fringe)                                            
    Ashtabula Area City   6 (town)        12     4,492                    145 
    Schools^a                                                                 
    Olmsted Falls City   8 (rural)         4     3,388                     12 
    Schools                                                                   

Source: Common Core Data.

aWe interviewed these officials by telephone.

Appendix II: Emergency Management Planning Requirements

Table 17: States Reporting Selected Requirements for School Districts or
Schools for Emergency Management Planning

                            Planning   
                          requirements 
                                        Review                                                    
                 State                    or                                                      
              requirement               update  Requirements                                      
              for school               of plans  pertaining                                       
               districts                by the  to drills or                First      Community  
              or schools                school     other       Parent    responders^b partners^c  
                to have     Specific   district training for involvement involvement  involvement 
               emergency   hazards to  or some    teachers     in the       in the      in the    
              management  be included   other      and/or     planning     planning    planning   
State^a          plans      in plans    entity    students     process     process      process   
Alabama                                                                                           
Alaska             X           X          X          X           X^d          X            X      
Arizona           X^e                                                         X                   
Arkansas                                                                                          
California         X                      X          X            X          X^f                  
Colorado           X                                 X                                            
Connecticut                                                                                       
Delaware          X^e                     X          X                                            
District of                                                                                       
Columbia                                                                                          
Florida            X           X                     X                                            
Georgia            X           X          X                       X           X            X      
Hawaii                                                                                            
Idaho                                                                                             
Illinois           X           X         X^g         X                                            
Indiana            X           X          X                                   X                   
Iowa                                                                                              
Kansas                                                                                            
Kentucky                                                                                          
Maine              X           X          X                                   X            X      
Maryland           X           X                     X                        X            X      
Massachusetts      X           X          X          X                        X                   
Michigan                                                                                          
Minnesota          X                                 X            X           X            X      
Mississippi        X                      X                                                       
Missouri                                                                                          
Montana                                                                                           
Nebraska                                                                                          
Nevada             X           X          X          X            X           X            X      
New Hampshire                                                                                     
New Jersey        X^e                     X          X                        X            X      
New Mexico         X                      X                       X                        X      
New York           X           X          X          X                        X                   
North                                                                                             
Carolina                                                                                          
North Dakota                                                                                      
Ohio               X           X          X                       X           X                   
Oklahoma           X           X                                                                  
Oregon             X                                 X                                            
Pennsylvania      X^e                     X          X                                    X*      
Rhode Island       X           X          X          X            X           X                   
South              X           X                     X                                            
Carolina                                                                                          
South Dakota       X                                 X                                            
Tennessee          X           X                                                                  
Texas              X                                 X                                            
Utah               X           X          X          X            X           X            X      
Vermont            X           X          X                                                       
Virginia           X           X                     X                        X                   
Washington        X^e                                                                             
Wisconsin                                                                                         
West Virginia                                                                                     
Wyoming            X                                 X                                            
Total             32           18         18         21           9           16          10      

Source: GAO analysis of state education agencies' and state administering
agencies' survey responses.

aNeither Louisiana's SEA nor its SAA responded to our survey.

bFor purposes of this report, we define first responders to include fire,
law enforcement, EMS, and state and local emergency management agencies.
States may define this term differently.

cFor purposes of this report, we define community partners to include
public health entities, mental health entities, local heads of government,
transportation entities, hospitals, the Red Cross, the faith-based
community, and the business community. States may define this term
differently.

dSchools are required to form crisis response teams that include, among
others, a parent whose child attends the school. The emergency management
plan must include the names of these team members and their specific job
functions relating to a crisis. However, it is not clear what role, if
any, parents play in developing the emergency management plan.

eThe state requirement specifies that the school or district level plan
must satisfy certain minimum requirements developed by other entities,
such as the state department of education.

fParents may become involved in the emergency preparedness plan
development if the school site council, otherwise tasked with plan
development, delegates planning responsibility to a school safety planning
committee.

gAlthough first responders are not required to be involved in the
development of emergency management plans, districts are required to
invite them to participate in the annual review process.

Appendix III: Homeland Security Funding Provided to School Districts

Table 18: States That Reported Providing Homeland Security Funding
Directly to School Districts

                                                  Amount of grant funding
                Type of DHS grant awarded to    provided to school districts
                states and provided to school  during fiscal years 2003--2006
                          districts                (Dollars in thousands)
                  State                                                       
                Homeland   Urban Areas          Fiscal   Fiscal Fiscal Fiscal 
                Security    Security   Citizen    year     year   year   year 
State         Program   Initiative   Corps     2003     2004   2005   2006 
Hawaii           X                             $110      $71               
Florida          X                              120    2,282 $2,000        
                                          X        $34       36     36     46 
Michigan         X                            8,600                        
Mississippi                            X                  66     60        
Wyoming          X                              386                        
Total                                        $9,020     $266 $2,455 $2,106 
Grand total                                          $13,847               

Source: GAO analysis of state administering agencies' survey data.

Table 19: States and the District of Columbia That Reported Provided
Homeland Security Funding to School Districts through Local Jurisdictions
during Fiscal Years 2003--2006

                                        Type of grant
                 State Homeland Security   Urban Areas Security        
State                 Program                Initiative      Citizen Corps
Alabama                        X                                      X    
District of                                               X                
Columbia                                                                   
Hawaii^a                                                              X    
Minnesota                                                 X                
Nevada                         X                          X           X    
New Jersey                     X                          X                
North Dakota                   X                                           
Pennsylvania                                              X                
South Dakota                   X                                           
Wyoming                                                               X    

Source: GAO analysis of state administering agencies' survey data.

aHawaii distributed DHS funding to its state education agency, which then
provided funding to public schools in its state.

Appendix IV: Guidance, Training, and Funding States Provided to School
Districts 

Table 20: States and the District of Columbia That Reported Providing
Resources to School Districts to Assist in Emergency Management Planning

                                              Training       State funding    
State                Guidance provided     provided          provided      
Alabama                      X                X                 X          
Alaska                       X                                  X          
Arizona                      X                X                            
Arkansas                     X                X                            
California                   X                X                 X          
Colorado                     X                                             
Connecticut                  X                X                 X          
Delaware                     X                X                            
District of Columbia         X                X                            
Florida                      X                                             
Georgia                      X                X                            
Hawaii                       X                                  X          
Illinois                     X                X                            
Idaho^a                                                                    
Indiana                      X                X                            
Iowa                         X                X                            
Kansas                       X                                             
Kentucky                     X                X                            
Louisiana^b                                                                
Maine                        X                X                 X          
Maryland                     X                X                            
Massachusetts                                 X                            
Michigan                     X                X                            
Minnesota                    X                X                            
Mississippi                  X                X                            
Missouri                     X                X                 X          
Montana                      X                X                            
Nebraska                     X                                             
Nevada                       X                                             
New Hampshire                X                X                 X          
New Jersey                   X                X                            
New Mexico                   X                X                            
New York                     X                X                            
North Carolina               X                X                            
North Dakota                 X                X                            
Ohio                         X                X                 X          
Oklahoma                     X                X                            
Oregon                       X                X                            
Pennsylvania                 X                X                            
Rhode Island                 X                                             
South Carolina               X                X                            
South Dakota                 X                                             
Tennessee                    X                X                 X          
Texas                        X                X                            
Utah^c                                                                     
Vermont                      X                X                 X          
Virginia                     X                                             
Washington                   X                X                            
West Virginia                X                X                            
Wisconsin                    X                X                            
Wyoming                      X                                             
Total                       47                37                11         

Source: GAO analysis of state administering and education agencies' survey
data.

aIdaho did not provide guidance, training, or state funding to school
districts for emergency management planning.

bLouisiana's state administering and education agencies did not respond to
our surveys.

cUtah did not provide guidance, training, or state funding to school
districts for emergency management planning.

Appendix V: Comments from the Department of Homeland Security

Appendix VI: Comments from the Department of Education

Appendix VII: Comments from the Department of Health & Human Services

Appendix VIII: GAO Contacts and Staff Acknowledgments

GAO Contacts

Cornelia M. Ashby (202) 512-7215, [email protected]

William O. Jenkins, Jr. (202) 512-8757, [email protected]

Acknowledgments

Kathryn Larin (Assistant Director), Debra Sebastian (Assistant Director),
and Tahra Nichols (Analyst-in-Charge) managed all aspects of this
assignment. Benjamin Jordan, Meaghan Marshall, and Kris Trueblood made
significant contributions to this report. Krista Anderson, Jennifer
Gregory, Lise Levie, and Paul Revesz also made contributions to this
report. Sue Bernstein and Katherine Davis contributed to writing this
report. Jim Ashley, Jean McSween, Amanda Miller, and Joan Vogel provided
key technical support. Sheila McCoy provided legal support.

(130575)

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www.gao.gov/cgi-bin/getrpt?GAO-07-609 .

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Highlights of [51]GAO-07-609 , a report to congressional requesters

June 2007

EMERGENCY MANAGEMENT

Most School Districts Have Developed Emergency Management Plans, but Would
Benefit from Additional Federal Guidance

Congress has raised concerns over emergency management in school
districts, with a particular interest in how federal agencies provide
assistance to school districts. GAO was asked to assess (1) the roles of
federal and state governments and school districts in establishing
requirements and providing resources to school districts for emergency
management planning, (2) what school districts have done to plan and
prepare for emergencies, and (3) the challenges, if any, school districts
have experienced in planning for emergencies, and communicating and
coordinating with first responders, parents, and students. To obtain this
information, GAO interviewed federal officials, surveyed a stratified
random sample of all public school districts, surveyed state education
agencies and state administering agencies, conducted site visits to school
districts, and reviewed relevant documents.

[52]What GAO Recommends

GAO is making several recommendations to DHS, Education, and HHS aimed at
improving school district emergency management planning and preparation.
Education and HHS generally agreed with GAO's recommendations. DHS
generally agreed with the intent of GAO's recommendations.

Although there are no federal laws requiring all school districts to have
emergency management plans, most states and school districts reported
having requirements for such planning, and federal and state governments
and school districts provide financial and other resources. Thirty-two
states reported having laws or other policies requiring school districts
to have emergency management plans. The Departments of Education
(Education) and Homeland Security (DHS) and state governments as well as
school districts provide funding for emergency management planning in
schools. DHS awards grants to states and local jurisdictions that may
provide some of these funds to school districts and schools for emergency
management planning. However, DHS program guidance for certain grants does
not clearly identify school districts as entities to which state and local
governments may disburse grant funds. Thus, states receiving DHS funding
may not be aware that such funding could be allocated to school districts
or schools.

Most school districts have taken federally recommended steps to plan and
prepare for emergencies, including the development of emergency management
plans, but many plans do not include recommended practices. Based on GAO's
survey of school districts, most school districts, those with and without
plans, have undertaken a variety of recommended practices to prepare for
emergencies such as conducting school drills and exercises. In addition,
based on GAO's survey of school districts, an estimated 95 percent of all
school districts have written emergency management plans, but the content
varies. While most school districts have procedures in their plans for
staff roles and responsibilities, for example, school districts have not
widely employed such procedures as, academic instruction via local radio
or television, for continuing student education in the event of an
extended school closure, such as might occur during a pandemic. Likewise,
while many districts have procedures for special needs students, GAO found
during site visits that some of these procedures may not fully ensure the
safety of these students in an emergency. Finally, while most school
districts practice their emergency management plans annually within the
school community, GAO estimates that over one-quarter of school districts
have never trained with any first responders and over two-thirds of school
districts do not regularly train with community partners on how to
implement their school district emergency management plans.

Many school districts experience challenges in planning for emergencies,
and some school districts face difficulties in communicating and
coordinating with first responders and parents, but most do not have such
challenges with students. Based on GAO's survey of school districts, in
many school districts officials struggle to balance priorities related to
educating students and other administrative responsibilities with
activities for emergency management and consider a lack of equipment,
training for staff, and personnel with expertise in the area of emergency
planning as challenges. In an estimated 39 percent of school districts
with emergency management plans, officials experienced a lack of
partnerships, limited time or funding to plan, or lack of interoperability
between equipment used by school districts and first responders. In
interviews, about half of the officials in the 27 school districts GAO
visited reported difficulty in ensuring that parents received consistent
information from the district during an emergency.

References

Visible links
  34. http://www.gao.gov/cgi-bin/getrpt?GAO-07-395T
  35. http://www.gao.gov/cgi-bin/getrpt?GAO-06-618
  36. http://www.gao.gov/cgi-bin/getrpt?GAO-07-395T
  37. http://www.gao.gov/cgi-bin/getrpt?GAO-06-618
  38. http://www.gao.gov/cgi-bin/getrpt?GAO-06-618
  39. http://www.gao.gov/cgi-bin/getrpt?GAO-06-618
  40. http://www.gao.gov/cgi-bin/getrpt?GAO-07-301
  41. http://www.gao.gov/cgi-bin/getrpt?GAO-06-618
  42. http://www.gao.gov/cgi-bin/getrpt?GAO-04-740
  51. http://www.gao.gov/cgi-bin/getrpt?GAO-07-609
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