Emergency Management: Status of School Districts' Planning and Preparedness

Emergency Management: Status of School Districts' Planning and
Preparedness (17-MAY-07, GAO-07-821T).

Events such as the recent shootings by armed intruders in schools
across the nation, natural disasters, the terrorist attacks of
September 11, 2001, and potential pandemics have heightened
awareness for the need for school districts to be prepared to
address a range of emergencies within and outside of schools
buildings. Congress has raised concerns over school preparedness,
with a particular interest in how federal agencies provide
assistance to school districts. This testimony discusses
preliminary findings related to GAO's review of emergency
management in school districts, including (1) the roles of
federal and state governments 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 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 agencies that administer federal grants
that can be used for school emergency management planning,
conducted site visits to school districts, and reviewed relevant
documents.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-07-821T
ACCNO: A69739
TITLE: Emergency Management: Status of School Districts'
Planning and Preparedness
DATE: 05/17/2007
SUBJECT: Communication
Educational facilities
Emergency management
Emergency preparedness
Federal aid to localities
Federal funds
Federal/state relations
First responders
Homeland security
Locally administered programs
Requirements definition
School districts
Strategic planning
Students
National Incident Management System

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GAO-07-821T

* [1]Background
* [2]Federal and State Governments Provide Resources to School Di

* [3]Although No Federal Laws Exist Requiring School District Eme
* [4]Federal Agencies and States Provide Funding for School Distr
* [5]Federal Agencies and States Provide Guidance, Training, and

* [6]Most Districts Have Taken Steps to Prepare for Emergencies,

* [7]Most School Districts Have Undertaken Some Emergency Managem
* [8]Most Districts Have Emergency Management Plans That Address

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

* [10]Competing Priorities, Lack of Equipment, and Limited Experti
* [11]Some School Districts Reported Difficulty in Communicating a
* [12]School Districts Have Methods to Communicate With Parents, b

* [13]Concluding Observations
* [14]GAO Contacts
* [15]GAO's Mission
* [16]Obtaining Copies of GAO Reports and Testimony

* [17]Order by Mail or Phone

* [18]To Report Fraud, Waste, and Abuse in Federal Programs
* [19]Congressional Relations
* [20]Public Affairs

Testimony

Before the Committee on Homeland Security, House of Representatives

United States Government Accountability Office

GAO

For Release on Delivery
Expected at 10:00 a.m. EDT
Thursday, May 17, 2007

EMERGENCY MANAGEMENT

Status of School Districts' Planning and Preparedness

Statement of Cornelia M. Ashby, Director
Education, Workforce, and Income Security

GAO-07-821T

Mr. Chairman and Members of the Committee:

I am pleased to be here today to discuss emergency management in public
school districts. The nation's more than 17,000 school districts are
responsible for maintaining the safety and security of approximately 49
million public school students. Events such as the recent shootings by
armed intruders in schools across the nation, natural disasters such as
Hurricanes Katrina and Rita in 2005, the terrorist attacks of September
11, 2001, and potential pandemics have heightened awareness of the need
for school districts to be prepared to address a range of emergencies
within and outside of school buildings.

My testimony today is drawn from ongoing work we have conducted for this
Committee and other congressional requesters on emergency management in
school districts. We anticipate completing the report in June 2007.
"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 varies 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.

My testimony today will focus on (1) the role of the federal and state
governments 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, briefly, (3) the
challenges school districts have experienced in planning for emergencies
and communicating and coordinating with first responders, parents, and
students. When discussing the federal government, I am primarily referring
to the three agencies included in our report--the Departments of Homeland
Security (DHS), Education (Education), and Health and Human Services
(HHS).

To determine the role of the federal and state governments, planning
requirements for school districts and schools, and the types of resources
provided to districts, we conducted interviews with officials representing
DHS, Education, and HHS 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) in all 50 states and the District of
Columbia. 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. Using a
95 percent confidence interval, all percentage estimates included in this
statement have a margin of error of plus or minus 10 percent or less,
unless otherwise noted. To further understand the experiences districts
have had in planning for emergencies and communicating and coordinating
with first responders^1, parents, and students, we visited selected
districts in the states of Florida, Iowa, Massachusetts, North Carolina,
Ohio, and Washington. In total, we conducted semi-structured interviews,
either in person or by telephone, with officials in 27 school districts.
We are conducting the review in accordance with generally accepted
government auditing standards.

In summary, federal and state governments support emergency management in
school districts with a range of resources and most school districts have
developed emergency management plans despite facing challenges; however
not all of these plans incorporate recommended practices. Federal and
state governments provide funding, guidance, training, and equipment; and
many states require school districts to develop emergency management plans
or engage in other planning activities. However, funding guidance for some
federal grant programs does not clearly identify school districts as
entities to which state and local governments may disburse these grant
funds. Therefore, some states receiving this funding may be uncertain as
to whether such funding can be allocated to school districts or schools;
and as a result, school districts may not have the opportunity to benefit
from this funding. At the local level, 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, many school districts do not include procedures
for special needs students in their plans and many districts have not
employed any procedures in their plans for continuing student education in
the event of an extended school closure, such as might occur during a
pandemic. Additionally, school districts are generally not training with
their first responders (i.e., law enforcement, fire, and Emergency Medical
Services [EMS]) and community partners (such as the local head of
government and local public health agency), which are both federally
recommended practices. Finally, many school district officials said that
they experience challenges in planning for emergencies due to a lack of
equipment, training for staff, and expertise 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 emergency procedures to students. We are currently
considering recommendations that federal agencies clarify and improve
guidance to states and school districts to better enable school districts
to incorporate recommended practices for emergency management.

^1In 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 (6
U.S.C. 101), 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."

Background

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.^2 DHS serves as a federal partner to state
and local governments in emergency management.^3 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.

^2Pub. L. No. 107-296.

^3The 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.^4 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.

^4GAO, Homeland Security: Preparing for and Responding to Disasters,
[21]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, [22]GAO-06-618 (Washington, D.C.: Sept. 6, 2006).

Federal and State Governments Provide Resources to School Districts for
Emergency Management Planning, While Only States Have Laws that Require School
Emergency Management Planning

Although no federal laws exist requiring school districts to have
emergency management plans, most states reported having requirements for
school emergency management planning; however, the federal government,
along with states, provides financial and other resources for such
planning. Education, DHS, and state governments 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, the federal government
assists school districts and schools in emergency management planning by
providing other resources such as guidance, training, and equipment.

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

Although there are no federal laws requiring 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. While
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",
Education has not issued any regulations imposing such a requirement on
all school districts.^5 However, 32 of the states responding to our survey
of state administering agencies and state education agencies reported
having laws or other policies requiring school districts or schools to
have a written emergency management plan (see fig. 1). 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.

^520 U.S.C. S 7114(d)(7)(D). However, these plans 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

Federal Agencies and States Provide Funding for School Districts' Emergency
Management Planning

Education and DHS provided some funding to school districts for emergency
management. Education provides funding to some school districts
specifically for emergency management planning through its Emergency
Response and Crisis Management (ERCM) Grant Program.^6 Since fiscal year
2003, Education dispersed $130 million in such grants to over 400 of the
over 17,000^7 school districts in the United States. These grant awards
ranged from $68,875 to $1,365,087.

DHS provides funding to states and local jurisdictions for emergency
management planning, some of which 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, Urban
Areas Security Initiative, and Citizen Corps grants.^8 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. 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.^9

6The 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. 72 Fed. Reg.
17,139 (April 6, 2007)

^7As 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. Department
of Defense schools are included in the CCD count of school districts, but
according to Education officials, such schools are not eligible to receive
funding under the ERCM/REMS grant program.

^8The 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.

^9A 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 these three grant programs 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.^10 As a
result, some states may not be aware of their availability.

State governments also provide state funds to school districts. Eleven of
the 49 states^11 responding to surveys we sent to state education and
state administering agencies reported providing state funding to school
districts for emergency management planning.

Federal Agencies and States Provide Guidance, Training, and Equipment for
Emergency Management in School Districts

The federal government also provides guidance, training, and equipment to
school districts to assist in emergency management planning (see table 1).

^10DHS 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" that was used in the Conference Report
accompanying the DHS Appropriations Act of 2006, and 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."

^11We included the District of Columbia in our state education and state
administering agency surveys.

Table 1: 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 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.
Examples of training
o The Federal Emergency Management Agency (FEMA), within DHS, offers
on-line 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 those 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, and 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.^12 Some of these practices are shown in table 2.

^12Education, for example, also obtained input from state and local school
and emergency management officials and associations in developing these
recommended practices.

Table 2: 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.

The type of guidance available from the federal government on topics
related to these recommended practices varies significantly; in some
instances, federal agencies provide detailed instructions on how to
implement recommended practices while, in other instances, guidance is
less detailed.

We have also recognized the importance of certain of these practices in
our prior reports on emergency management.^13 We have noted 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 is critical.

^13See [23]GAO-07-395T and [24]GAO-06-618 .

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.

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

Almost all school districts have taken steps to prepare for emergencies,
including developing written plans, but some plans do not address
federally recommended practices such as establishing procedures for
special needs students and procedures for continued student education in
the event of an extended closure. Additionally, many school districts do
not have procedures for training regularly with first responders and
community partners.

Most School Districts Have Undertaken Some Emergency Management Activities

Many school districts, those with and without emergency management plans,
have undertaken activities to prepare for emergencies. 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. Security
enhancements included adding or enhancing equipment to communicate with
school employees, strengthening the perimeter security of the school, and
enhancing access controls.

In addition to conducting vulnerability assessments, many school districts
carry out a number of other activities to prepare for emergencies such as
conducting some type of school drill or exercise and maintaining a storage
location for and replenishing emergency supplies such as food, water, and
first-aid supplies, as recommended. Additionally, school districts took
responsibility for a number of activities to prepare for emergencies at
the district level such as negotiating the use of school buildings as
community shelters and identifying security needs in schools. These
activities can vary by locality depending on community needs and include
oversight, coordination with other entities, and training.

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.^14 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. (See fig. 2.) In some instances, the
hazards included in emergency plans are specific to local conditions,
which is to be expected.

^14Those 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 2: Estimated Percentages of Urban and Rural Districts' Multi-Hazard
Emergency Management Plans that Include Specific Types of Incidents

aDifferences between urban and rural districts are not statistically
significant.

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

Develop Roles and Responsibilities for School Community Members. Based on
our survey of school districts, most districts have written roles and
responsibilities in their plans for staff such as superintendents,
building engineers or custodians, principals, teachers, and nurses.

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)^15-- to establish
the roles and responsibilities of school district officials, local first
responders, and community partners during an emergency, in accordance with
recommended practices.

Develop Procedures for Communicating with Key Stakeholders. 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 Limited-English Proficient. Our survey finds that roughly
three-quarters of all school districts have not included written
procedures in their plans for communicating with Limited-English
Proficient parents and students, in accordance with federally recommended
practices.

Develop Procedures for Special Needs Students. Although 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. 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.
According to these officials, 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.

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. School districts' plans include such procedures as
providing on-site trauma teams, restoring district administrative
functions, and conducting assessments of damage to school buildings and
grounds.

^15The 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. Specifically, 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.

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 3) 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.

Table 3: 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. In contrast, other
districts provide less information. For example, one district's plan
consisted of a flipchart with contact information on whom to call during
an emergency.

Involve Local Government and Public Heath Agencies in Developing and
Updating Plans. School districts differed in the extent to which they
involve community partners in the development and updating of their
plans.^16 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.^17
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. More than half (52 percent) of all school
districts with emergency management plans report regularly (i.e., at least
once a year) updating their emergency management plans in accordance with
recommended practices. However, 10 percent of all school districts had
never updated their plans.

Train with First Responders. 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. 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 first responders
with and prepare first responders for their roles in an emergency as well
as assess the effectiveness of a school or district emergency plan.^18

16In 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.

^17Twelve 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.

^18See [25]GAO-06-618 .

Train with Community Partners. School districts report training with
community partners--such as local government and local public health
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.^19 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.

School Districts Report Challenges in Planning for Emergencies and Difficulties
in Communicating with First Responders and Parents

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.

Competing Priorities, Lack of Equipment, and Limited Expertise Are Obstacles to
Incorporating 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 an estimated 62 percent of districts, officials cited a lack of
equipment and expertise as impediments to emergency planning. For example,
officials in one Massachusetts school district we visited reported that
they do not have adequate locks on some of the doors to school buildings
to implement a lockdown procedure. In a North Carolina district we
visited, 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.^20 As demonstrated in these
school districts, the lack of equipment would prevent districts from
implementing the procedures in their plans and hinder communication among
district staff and with first responders during emergencies. 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. For
example, district officials in 5 of the 27 districts we interviewed noted
that they do not have sufficient funding to hire full-time emergency
management staff to provide such training or take responsibility for
updating their district plans. These officials noted that the lack of
expertise makes it difficult to adequately plan for responding to
emergencies.

^19See [26]GAO-06-618 .

School districts we interviewed also 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.
For example, an official in one 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

^20Two-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.

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

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.^21 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. For example, the superintendent of a Washington school
district we visited 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 districtwide 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. 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.
Additionally, in 8 of the 27 districts we interviewed, officials said that
the two-way radios or other equipment used in their school districts
lacked interoperability with the radios used by first responders.^22

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 27 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 having 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.
Representatives of three education associations^23 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.

^21Thirteen percent of school districts reported not knowing whether the
district has challenges related to first responders.

^22GAO 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, [27]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, [28]GAO-06-618 (Washington,
D.C.: Sept. 6, 2006); and Homeland Security: Federal Leadership and
Intergovernmental Cooperation Required to Achieve First Responder
Interoperable Communications. [29]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 Limited-English
Proficient parents during emergencies, but fewer--an estimated 23 percent
of all districts--provide translations of emergency management materials.
Officials in eight 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. Our findings, 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.

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 discussed, most districts regularly practice
their emergency management plans with their students and staff.

Concluding Observations

The federal government plays a critical role in assisting school districts
to prepare for emergencies by providing funding, giving states flexibility
to target federal funding for emergency management to areas of greatest
need, disseminating information on best practices and other guidance, and
providing training and equipment. 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. 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.
Additional clarity regarding access to federal resources and improved
guidance may enhance the ability of school districts to plan and prepare
for emergencies. We are currently considering recommendations to address
these issues.

^23National Education Association, American Association of School
Administrators, and National Association of Secondary School Principals.

GAO Contacts

For further information regarding this testimony, please contact me on
(202) 512-8403 or William O. Jenkins, Jr. on (202) 512-8757. Individuals
making contributions to this testimony include Kathryn Larin, Debra
Sebastian, Tahra Nichols, and Kris Trueblood.

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www.gao.gov/cgi-bin/getrpt?GAO-07-821T .

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Highlights of [37]GAO-07-821T , a testimony before the Committee on
Homeland Security, House of Representatives

May 17, 2007

EMERGENCY MANAGEMENT

Status of School Districts' Planning and Preparedness

This testimony discusses preliminary findings related to GAO's review of
emergency management in school districts, including (1) the roles of
federal and state governments 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 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
agencies that administer federal grants that can be used for school
emergency management planning, conducted site visits to school districts,
and reviewed relevant documents.

Federal and state governments have a role in supporting emergency
management in school districts. While no federal laws require school
districts to have emergency management plans, 32 states reported having
laws or policies requiring school districts to have such plans. The
Departments of Education and Homeland Security (DHS) provide funding for
emergency management planning in schools. However, some DHS program
guidance, for specific grants, does not clearly identify school districts
as entities to which state and local governments may disburse grant funds.
Thus, states receiving this funding may be uncertain as to whether such
funding can be allocated to school districts or schools and therefore may
not have the opportunity to benefit from this funding. States also provide
funding and other resources to school districts to assist them in planning
for emergencies.

School districts have taken steps to plan for a range of emergencies, as
most have developed multi-hazard emergency management plans; however some
plans and activities do not address federally recommended practices. For
example, based on GAO's survey of a sample of public school districts, an
estimated 56 percent of all school districts have not employed any
procedures in their plans for continuing student education in the event of
an extended school closure, such as might occur during a pandemic, and
many do not include procedures for special needs students. Fewer than half
of districts with emergency plans involve community partners when
developing and updating these plans. Finally, school districts are
generally not training with first responders or community partners on how
to implement their school district emergency plans.

Estimated Percentages of Urban and Rural Districts' Multi-Hazard Emergency
Management Plans that Include Specific Types of Incidents

^aDifferences between urban and rural districts are not statistically
significant.

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. For example, in an estimated 62 percent of districts, officials
identified challenges stemming from a lack of equipment, training for
staff, and personnel with expertise in the area of emergency planning as
obstacles to implementing recommended practices.

References

Visible links
21. http://www.gao.gov/cgi-bin/getrpt?GAO-07-395T
22. http://www.gao.gov/cgi-bin/getrpt?GAO-06-618
23. http://www.gao.gov/cgi-bin/getrpt?GAO-07-395T
24. http://www.gao.gov/cgi-bin/getrpt?GAO-06-618
25. http://www.gao.gov/cgi-bin/getrpt?GAO-06-618
26. http://www.gao.gov/cgi-bin/getrpt?GAO-06-618
27. http://www.gao.gov/cgi-bin/getrpt?GAO-07-301
28. http://www.gao.gov/cgi-bin/getrpt?GAO-06-618
29. http://www.gao.gov/cgi-bin/getrpt?GAO-04-740
37. http://www.gao.gov/cgi-bin/getrpt?GAO-07-821T
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