National Response Framework: FEMA Needs Policies and Procedures
to Better Integrate Non-Federal Stakeholders in the Revision
Process (11-JUN-08, GAO-08-768).
Hurricane Katrina illustrated that effective preparation and
response to a catastrophe requires a joint effort between
federal, state, and local government. The Department of Homeland
Security (DHS), through the Federal Emergency Management Agency
(FEMA), is responsible for heading the joint effort. In January
2008, DHS released the National Response Framework (NRF), a
revision of the 2004 National Response Plan (2004 Plan), the
national preparation plan for all hazards. In response to the
explanatory statement to the Consolidated Appropriations Act of
2008 and as discussed with congressional committees, this report
evaluates the extent to which (1) DHS collaborated with
non-federal stakeholders in revising and updating the 2004 Plan
into the 2008 NRF and (2) FEMA has developed policies and
procedures for managing future NRF revisions. To accomplish these
objectives, GAO reviewed DHS and FEMA documents related to the
revision process, analyzed the relevant statutes, and interviewed
federal and non-federal officials who held key positions in the
revision process.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-08-768
ACCNO: A82327
TITLE: National Response Framework: FEMA Needs Policies and
Procedures to Better Integrate Non-Federal Stakeholders in the
Revision Process
DATE: 06/11/2008
SUBJECT: Disaster planning
Disaster recovery plans
Emergency management
Emergency preparedness
Emergency preparedness programs
Emergency response plans
Emergency response procedures
Federal/state relations
Homeland security
Internal controls
Local governments
National policies
Policy evaluation
Program evaluation
Reporting requirements
Standards
Strategic planning
Written communication
Government information dissemination
Policies and procedures
National Response Framework
National Response Plan
******************************************************************
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GAO-08-768
This is the accessible text file for GAO report number GAO-08-768
entitled 'National Response Framework: FEMA Needs Policies and
Procedures to Better Integrate Non-Federal Stakeholders in the Revision
Process' which was released on June 11, 2008.
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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
June 2008:
National Response Framework:
FEMA Needs Policies and Procedures to Better Integrate Non-Federal
Stakeholders in the Revision Process:
GAO-08-768:
GAO Highlights:
Highlights of GAO-08-768, a report to congressional committees.
Why GAO Did This Study:
Hurricane Katrina illustrated that effective preparation and response
to a catastrophe requires a joint effort between federal, state, and
local government. The Department of Homeland Security (DHS), through
the Federal Emergency Management Agency (FEMA), is responsible for
heading the joint effort. In January 2008, DHS released the National
Response Framework (NRF), a revision of the 2004 National Response Plan
(2004 Plan), the national preparation plan for all hazards. In response
to the explanatory statement to the Consolidated Appropriations Act of
2008 and as discussed with congressional committees, this report
evaluates the extent to which (1) DHS collaborated with non-federal
stakeholders in revising and updating the 2004 Plan into the 2008 NRF
and (2) FEMA has developed policies and procedures for managing future
NRF revisions. To accomplish these objectives, GAO reviewed DHS and
FEMA documents related to the revision process, analyzed the relevant
statutes, and interviewed federal and non-federal officials who held
key positions in the revision process.
What GAO Found:
While DHS included non-federal stakeholders�state, local, and tribal
governments, nongovernmental organizations, and the private sector�in
the initial and final stages of revising the 2004 Plan into the NRF, it
did not collaborate with these stakeholders as fully as it originally
planned or as required by the October 2006 Post-Katrina Emergency
Management Reform Act (Post-Katrina Act). As the revision process began
in 2006, DHS involved both federal and non-federal stakeholders by
soliciting and incorporating their input in determining the key
revision issues and developing the first draft in April 2007. However,
after this first draft was completed, DHS deviated from its revision
work plan by conducting a closed, internal federal review of the draft
rather than releasing it for stakeholder comment because the draft
required further modifications DHS considered necessary. DHS limited
communication with non-federal stakeholders until it released a draft
for public comment 5 months later on September 10, 2007. The following
day, non-federal stakeholders testified at a congressional hearing that
DHS had shut them out during that 5-month period. In addition, the Post-
Katrina Act required that DHS establish a National Advisory Council
(NAC) for the FEMA Administrator by December 2006 to, among other
things, incorporate non-federal stakeholders� input in the revision
process. However, FEMA stated the necessary time to select quality NAC
members required additional time, and FEMA did not announce the NAC�s
membership until June 2007. The NAC did not provide comments on a
revision draft until one month before DHS publicly released the final
NRF in January 2008.
FEMA anticipates that the NRF will be revised in the future; however,
FEMA does not have policies or procedures in place to guide this
process or ensure a collaborative partnership with stakeholders. FEMA
has emphasized the importance of partnering with relevant stakeholders
to effectively prepare for and respond to major and catastrophic
disasters, and the Congress, through the Post-Katrina Act, requires
such partnership. In addition, the Standards for Internal Controls in
the Federal Government calls for policies and procedures that establish
regular communication with stakeholders and monitor performance over
time as essential for achieving desired program goals. Furthermore,
previous GAO work on the Department of Defense�s civil support plans
and the administration�s national pandemic influenza implementation
plan has shown the need for participation of state and local
jurisdictions in emergency planning. Especially in view of a new
administration, the experience of the previous revision process
illustrates the importance of collaborating with stakeholders in
revising a plan that relies on them for its successful implementation.
While the NRF is published by DHS, it belongs to the nation�s emergency
response community. Developing such policies and procedures is
essential for ensuring that FEMA attains the Post-Katrina Act�s goal of
partnering with non-federal stakeholders in building the nation�s
emergency management system, including the periodic review and revision
of the NRF.
What GAO Recommends:
GAO recommends that FEMA develop policies and procedures that guide how
future revision processes will occur, particularly for collaborating
with non-federal stakeholders.
FEMA concurred with our recommendation.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-768]. For more
information, contact William Jenkins at (202) 512-8757 or
[email protected].
[End of section]
Contents:
Letter:
Results in Brief:
Background:
DHS Did Not Collaborate with Non-Federal Stakeholders As Fully As
Planned or Required in Developing the NRF:
FEMA and the Post-Katrina Act Have Recognized the Importance of
Including Non-Federal Stakeholders in Developing National Response
Doctrine, but FEMA Lacks Guidance and Procedures for Future NRF
Revisions:
Conclusions:
Recommendation for Executive Action:
Agency Comments:
Appendix I: Scope and Methodology:
Appendix II: The 17 Key Revision Issues That DHS Identified for the
2004 National Response Plan:
Appendix III: The 12 Work Groups DHS Established during the Revision
Process and Their Composition:
Appendix IV: GAO Contact and Staff Acknowledgments:
Table:
Table 1: The 224 Non-Federal Stakeholders Who Participated in the
Revision Work Groups by Occupational Sector and by Level of Government,
Nongovernmental Organization, and Private Sector:
Figures:
Figure 1: Significant Events and Documents in DHS's Revision of the
2004 National Response Plan into the 2008 National Response Framework:
Figure 2: Relationship among Entities within the September 2006
Revision Work Plan:
Figure 3: DHS's Revision Process as Planned by Its September 2006 Work
Plan and as Required by the October 2006 Post-Katrina Act:
Figure 4: Composition of the 710 Members of the 12 Work Groups by
Federal, State, Local, and Tribal Government, Nongovernmental
Organization, and Private Sector:
Figure 5: DHS's Actual Revision Process Compared with Its Proposed
Process:
Abbreviations:
2004 Plan: 2004 National Response Plan:
DHS: Department of Homeland Security:
FEMA: Federal Emergency Management Agency:
FMFIA: Federal Managers' Financial Integrity Act of 1982:
GAO: Government Accountability Office:
NAC: National Advisory Council:
NRF: 2008 National Response Framework:
[End of section]
United States Government Accountability Office: Washington, DC 20548:
June 11, 2008:
The Honorable Robert C. Byrd:
Chairman:
The Honorable Thad Cochran:
Ranking Member:
Subcommittee on Homeland Security:
Committee on Appropriations:
United States Senate:
The Honorable David E. Price:
Chair:
The Honorable Harold Rogers:
Ranking Member:
Subcommittee on Homeland Security:
Committee on Appropriations:
House of Representatives:
A common axiom in emergency management is that "All disasters are
local." But a key lesson Hurricane Katrina dramatically emphasized was
that major disasters can quickly overwhelm the capacity of local
responders. Thus, preparing for, responding to, and recovering from
major disasters requires partnerships between the federal government
and non-federal stakeholders, such as state, local, and tribal
governments, the private sector, and nongovernmental organizations. In
summarizing the lessons learned from our nation's response to Katrina,
we reported in September 2006 that these federal and non-federal
partnerships were critical to improving catastrophic disaster response.
[Footnote 1] The 2006 Post-Katrina Emergency Management Reform Act
(Post-Katrina Act)[Footnote 2] specifically tasked the Federal
Emergency Management Agency (FEMA) within the Department of Homeland
Security (DHS) to partner with these non-federal stakeholders to build
a national system of emergency management. In outlining his vision for
a "New FEMA" and in testimonies before the Congress, the FEMA
Administrator has acknowledged that FEMA's success depends on its
ability to establish and maintain robust partnerships with non-federal
stakeholders.
DHS issued the National Response Plan in December 2004 (2004 Plan) to
provide common principles and structures to align the efforts of
stakeholders at the local, state, and federal level to ensure an
effective national disaster response system. The events surrounding
Hurricane Katrina in August 2005 and the resulting lessons-learned and
after-action reports by the Congress and administration prompted DHS to
revise the just issued 2004 Plan. DHS released an interim revision of
elements of the 2004 Plan in May 2006 and developed a work plan for a
more comprehensive revision in September 2006. Shortly thereafter,
Congress passed the October 2006 Post-Katrina Act, which made the FEMA
Administrator, through the National Integration Center, responsible for
ongoing management and maintenance of the 2004 Plan, including periodic
review and revision. In addition, the act required the DHS Secretary to
establish a National Advisory Council of non-federal stakeholders to
advise the FEMA Administrator in revising the 2004 Plan. During the
summer of 2007 in the midst of the revision process, non-federal
members of the emergency management community raised concerns over the
extent to which DHS included them in the process. In September 2007,
the House Committee on Transportation and Infrastructure held a hearing
on DHS's management of the revision process and the involvement of non-
federal stakeholders. DHS completed its revision efforts with the
publication of the National Response Framework (NRF) on January 22,
2008.[Footnote 3] The NRF is a guide for how the federal, state, local,
and tribal governments, along with nongovernmental and private sector
entities, will collectively respond to and recover from all disasters,
particularly catastrophic disasters such as Hurricane Katrina,
regardless of their cause. The NRF recognizes the need for
collaboration among the myriad of entities and personnel involved in
response efforts at all levels of government, nonprofit organizations,
and the private sector. See figure 1 depicting the significant events
and documents in the revision of the 2004 Plan into the 2008 NRF.
Figure 1: Significant Events and Documents in DHS's Revision of the
2004 National Response Plan into the 2008 National Response Framework:
[See PDF for image]
This figure is an illustration of significant events and documents in
DHS's Revision of the 2004 National Response Plan into the 2008
National Response Framework, as follows:
December 2004:
National Response Plan (2004 Plan).
August 2005:
Hurricane Katrina.
February - May, 2006:
Katrina after-action and lessons learned reports.
May 2006:
Interim changes to 2004 Plan through Notice of Change.
September 2006:
DHS Work Plan for 2004 Plan revision.
October 2006:
Post-Katrina Emergency Management Reform Act.
October 2006 - January 2008:
DHS's revision of the 2004 Plan[A].
January 2008:
National Response Framework.
Source: GAO analysis.
[A] See figure 5 for a time line on DHS's revision process from October
2006 to January 2008.
[End of figure]
In the explanatory statement accompanying the Consolidated
Appropriations Act of 2008, the appropriations committees tasked GAO to
review the process DHS used to update the NRF, including the process
for including key stakeholders. We conducted our review to determine
the extent to which (1) DHS collaborated with non-federal stakeholders
in revising and updating the 2004 Plan into the 2008 NRF and (2) FEMA
has developed policies and procedures for managing future revisions of
the NRF, for which it is statutorily responsible.
To address our objectives, we reviewed DHS and FEMA documents on the
revision process and applicable statutes to determine the level to
which the revision process was planned. To determine what happened
during the process, we interviewed DHS and FEMA officials as well as
non-federal stakeholders representing state and local levels of
government, emergency management associations, and others who served in
key positions in the revision process, such as the co-leaders of work
groups and members of a steering committee. The statements and views of
these stakeholders are not generalizable to the population of non-
federal stakeholders involved in the revision process. However, we
selected these stakeholders because of their assigned key roles and
believe that their views provided us with a general indication of
stakeholder perspectives on their involvement in the revision process.
To address our objectives, we reviewed DHS and FEMA documents on the
revision process and applicable statutes to determine the level to
which the revision process was planned. In assessing DHS and FEMA
actions related to these objectives, we used criteria from our prior
work on results-oriented government as well as best practices for
federal coordination and collaboration with stakeholders. We also used
criteria in GAO's Standards for Internal Control in the Federal
Government.[Footnote 4] These standards, issued pursuant to the
requirements of the Federal Managers' Financial Integrity Act of 1982
(FMFIA), provide the overall framework for establishing and maintaining
internal control in the federal government. Also pursuant to FMFIA, the
Office of Management and Budget issued Circular A-123, revised December
21, 2004, to provide the specific requirements for assessing and
reporting on internal controls. Internal control standards and the
definition of internal control in Circular A-123 are based on GAO's
Standards for Internal Control in the Federal Government. For more
detailed information on our scope and methodology, see appendix I.
We conducted this performance audit from September 2007 to June 2008,
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Results in Brief:
While DHS included non-federal stakeholders during the initial and
final months of the process of revising the 2004 Plan, it did not
collaborate with them as fully as envisioned in its original work plan
or as required by the 2006 Post-Katrina Act. DHS's management of the
initial stages of the revision process was generally consistent with
the work plan and involved state and local stakeholders in identifying
key issues and developing draft segments of the revised 2004 Plan.
However, DHS deviated from its work plan and did not provide the first
full revision draft to non-federal stakeholders for their comments and
suggestions before conducting an internal, federal review of the draft
because it required further modifications. Instead, DHS sent the first
draft for the internal, federal review for 5 months before requesting
stakeholder comment and without communicating the change in plans with
the non-federal stakeholders. At the end of the 5-month internal
review, DHS released a revised draft in September 2007, providing an
opportunity for non-federal stakeholders as well as the general public
to comment and have access to all non-federal comments submitted. DHS's
approach was also not in accordance with the Post-Katrina Act's
requirement that DHS establish a National Advisory Council (NAC) to
incorporate non-federal input into the revision of national response
doctrine. Although the NAC was to be established within 60 days of the
Act (i.e., December 4, 2006), FEMA, which assumed responsibility for
selecting members, did not name NAC members until June 2007 because of
the additional time needed to review hundreds of applications and
select a high quality body of advisors, according to the FEMA
Administrator. The NAC's first meeting took place in October 2007 after
DHS issued the revised plan for public comment.
While FEMA and the Congress, through the Post-Katrina Act, recognize
the importance of partnering with non-federal stakeholders in disaster
planning and response, FEMA has not yet developed guidance and
procedures--elements specified as essential for planning and achieving
effective results in Standards for Internal Control in the Federal
Government--that describe how future revisions of the National Response
Framework will be managed. The 2004 Plan included such guidance,
including the circumstances that would lead to future revisions--such
as changes in directives, laws, and lessons learned from exercises and
actual events--and time frames for reviewing the plan. In addition,
while these federal internal control standards state that communication
with stakeholders is essential, FEMA has not articulated how it will
involve stakeholders, or how the newly established NAC will be
integrated into the revision process. Especially in view of a new
administration, developing such policies and procedures is essential
for ensuring that FEMA attains the Post-Katrina Act's goal of
partnering with non-federal stakeholders in building the nation's
emergency management system, including the periodic review and revision
of the NRF. According to FEMA, it has not yet developed guidance and
procedures because of the need to focus federal resources on creating
training materials to assist all stakeholders in implementing the
current NRF in anticipation of the pending 2008 hurricane season.
As FEMA begins to implement and review the 2008 NRF, we recommend that
the Administrator develop and disseminate policies and procedures
describing the conditions and time frames under which the next NRF
revision will occur and how FEMA will conduct the next NRF revision.
These policies and procedures should clearly describe how FEMA will
integrate all stakeholders, including the NAC and other non-federal
stakeholders, into the revision process and the methods for
communicating to these stakeholders.
We requested comments on a draft of this report from DHS and FEMA. They
concurred with our recommendations and had no other comments.
Background:
Several federal legislative provisions support preparation for and
response to disasters. The Robert T. Stafford Disaster Relief and
Emergency Assistance Act[Footnote 5] (Stafford Act) primarily
establishes the programs and processes for the federal government to
provide major disaster and emergency assistance to states, local
governments, tribal nations, individuals, and qualified private
nonprofit organizations. FEMA has responsibility for administering the
provisions of the Stafford Act, and the Act provides the FEMA
Administrator with the authority to prepare federal response plans and
programs. In April 1992, FEMA issued a Federal Response Plan, which
outlined how the federal government implements the Stafford Act. The
Federal Response Plan described, among other things, the response and
recovery responsibilities of each federal department and agency for
saving lives and protecting public health and safety during an
emergency or major disaster.
After the events of September 11, 2001, and with the passage of the
Homeland Security Act[Footnote 6] in November 2002, FEMA became part of
the newly formed Department of Homeland Security (DHS).[Footnote 7]
Under the Act, FEMA retained its authority to administer the provisions
of the Stafford Act as well as its designation as the lead agency for
the Federal Response Plan. The Homeland Security Act required DHS to
consolidate existing federal government emergency response plans into a
single, integrated, and coordinated national response plan. In December
2004, DHS issued the 2004 Plan to integrate the federal government's
domestic prevention, preparedness, response, and recovery plans into
one plan that addressed all disaster situations, whether due to nature,
terrorism, or other man-made activities. The 2004 Plan incorporated or
superceded other federal interagency plans such as the Federal Response
Plan and the Federal Radiological Emergency Response Plan.
In August 2005, Hurricane Katrina and, shortly after, hurricanes Wilma
and Rita revealed a number of limitations in the 2004 Plan. Beginning
in February 2006, reports by the House Select Bipartisan Committee to
Investigate the Preparation for and Response to Hurricane Katrina,
[Footnote 8] the Senate Homeland Security and Governmental Affairs
Committee,[Footnote 9] the White House Homeland Security Council,
[Footnote 10] the DHS Inspector General,[Footnote 11] and DHS and FEMA
[Footnote 12] all identified a variety of failures and some strengths
in the preparations for, response to, and initial recovery from
Hurricane Katrina. After reviewing these reports, DHS concluded that
the 2004 Plan required revision. In May 2006, DHS released immediate
modifications to the 2004 Plan pending a more comprehensive review. In
June 2006, Congress passed the Emergency Supplemental Appropriations
Act for Defense, the Global War on Terror, and Hurricane Recovery,
2006.[Footnote 13] In the conference report accompanying this act, the
conferrees recommended that FEMA apply $3 million of its Preparedness,
Mitigation, Response, and Recovery appropriation to immediately review
and revise the 2004 Plan as well as its companion document, the
National Incident Management System, which provides standard command
and management structures that apply to response activities.[Footnote
14]
On October 4, 2006, the Post-Katrina Act was enacted. This act, among
other things, made certain organizational changes within DHS to
consolidate emergency preparedness and emergency response functions
within FEMA, required that DHS maintain FEMA as a distinct entity
within the department, and designated the FEMA Administrator--the new
title of the official who will lead the agency--as the principal
advisor to the President, the Homeland Security Council, and the
Secretary for all matters relating to emergency management. Most of the
organizational changes, such as the transfer of various functions from
DHS's Directorate of Preparedness to FEMA, became effective as of March
31, 2007. Others, such as the increase in the organizational autonomy
for FEMA and the establishment of the National Integration Center,
became effective upon enactment. The Post-Katrina Act specified that
the FEMA Administrator, acting through the Center, "shall ensure
ongoing management and maintenance of the�National Response Plan,"
including periodic review and revision. The Post-Katrina Act also
directed the Secretary to establish a National Advisory Council (NAC)
by December 2006 to, among other things, incorporate state, local, and
tribal government and private sector input in the development and
revision of the 2004 Plan. As established by the Post-Katrina Act, the
NAC is intended to be an ongoing advisory council that draws upon
individuals with a broad body of expertise and geographic and
substantive diversity. The Act requires the NAC to advise the
Administrator on a variety of emergency management issues across the
national preparedness spectrum, including the 2004 Plan.
In January 2008, DHS issued the 2008 NRF, the product of the revision
of the 2004 Plan. The NRF became effective in March 2008 and retained
the basic structure of the 2004 Plan. For example, like the 2004 Plan,
the NRF's core document describes the doctrine that guides national
response actions and the roles and responsibilities of officials and
entities involved in response efforts. Further, the NRF also includes
Emergency Support and Incident Annexes. However, in contrast to the
2004 Plan, FEMA plans to include four partner guides to the NRF that
describe key roles and actions for local, tribal, state, federal and
private sector entities involved in response activities.
DHS Did Not Collaborate with Non-Federal Stakeholders As Fully As
Planned or Required in Developing the NRF:
While DHS included non-federal stakeholders at the initial and final
stages in the process of revising the December 2004 Plan, it did not
collaborate with them as fully as planned in its revision work plan or
as required by the Post-Katrina Act. DHS based the work plan, which was
approved by a White House Homeland Security Council-chaired policy
committee, on a section in the 2004 Plan that provided procedural
guidance for managing revisions of the document. DHS managed the
initial stages of the revision process according to the work plan.
However, DHS deviated from its work plan after the first draft was
completed in April 2007. Instead of widely disseminating the first
draft to all stakeholders, including non-federal stakeholders, for
comment and modification, DHS retained the draft to make modifications
that it felt were necessary and conducted an internal, federal review
of the draft for a 5-month period. DHS delayed the release of the April
2007 draft and provided limited communication to state and local
stakeholders on the status of the review until after releasing the
draft for public comment in September 2007. In addition, DHS did not
manage the revision process in accordance with the Post-Katrina Act's
provision that DHS establish FEMA's NAC by December 2006 and
incorporate the NAC's non-federal input into the revision.
DHS Created a Work Plan to Revise the 2004 National Response Plan,
Specifying Revision Issues, Entities and Tasks, and a Time Line for
Completing the Revision:
Hurricane Katrina hit the Gulf Coast in August 2005 and the nation's
response prompted DHS to revise the 2004 Plan. In May 2006, DHS issued
an official Notice of Change[Footnote 15] to the 2004 Plan to
incorporate lessons learned from the response to hurricanes Katrina,
Wilma, and Rita as well as to incorporate organizational changes within
DHS. This Notice of Change--which was distributed to all
signatories[Footnote 16] of the 2004 Plan, DHS headquarters and
regional offices, and state emergency management and homeland security
offices--noted that DHS intended to initiate a comprehensive
stakeholder review of the 2004 Plan in the fall of 2006. Accordingly,
DHS developed a work plan to manage the revision of the 2004 Plan that
established (1) the issues that were to be the focus of the revision
process, (2) the entities to be created to implement the process and
the tasks involved, and (3) a timeline for completing the revision
process and issuing the final document. DHS based its work plan for
revising the 2004 Plan on guidance found in the Plan itself.
Anticipating that modifications or updates would arise when needed, the
2004 Plan included a section specifying how DHS would conduct interim
changes and full revisions, listing the time frames and circumstances-
-within the first year and every 4 years, or more frequently if the
Secretary deems necessary, to incorporate new presidential directives,
legislative changes, and procedural changes based on lessons learned
from exercises and actual events. The Domestic Readiness Group, an
interagency group that coordinates preparedness and response policy and
is chaired by staff of the White House Homeland Security Council,
approved DHS's work plan in September 2006. For the revision process,
the Domestic Readiness Group was to provide strategic policy
coordination, be a mechanism for vetting the revision at the federal
level, and was to resolve conflicting policy issues.
The work plan contained an initial list of 14 revision issues.
According to FEMA officials, they compiled these issues by reviewing
Hurricane Katrina after-action and lessons-learned reports from the
White House, Congress, GAO, and the DHS Inspector General and
identifying common issues that were raised in multiple reports.
According to the work plan, DHS was to conduct meetings with selected
stakeholders to review the initial list and identify other issues to be
considered during the revision process. The result of these meetings
was to be a finalized list of revision issues that would serve as the
starting point for revising the 2004 Plan.
Based on the 2004 Plan, DHS created three entities to facilitate the
revision process: the Steering Committee, the Writing Team, and 12 Work
Groups.[Footnote 17] DHS provided a copy of the approved work plan to
all participants. The Steering Committee was to conduct the day-to-day
management and oversight of the 2004 Plan revision process, which
included managing the Work Groups and overseeing the Writing Team. The
work plan assigned overall management of the 2004 Plan rewrite to the
Writing Team, which was to assign issues to the Work Groups and track
the Work Groups' progress on resolving the assigned issues. The Work
Groups, which were chaired by designated co-leaders, were to examine
the issues received from the Writing Team and determine if existing
language in the 2004 Plan adequately addressed the issues. If the Work
Groups determined that current language in the 2004 Plan did not
adequately address the issue, they were required to provide
recommendations to the Writing Team on how the issues should be
addressed. Figure 2 shows the relationship between the entities
involved in the revision process.
Figure 2: Relationship among Entities within the September 2006
Revision Work Plan:
[See PDF for image]
This figure is an illustration of relationship among entities within
the September 2006 Revision Work Plan, as follows:
Secretary of Homeland Security: Overall responsibility for 2004 Plan
Revision:
* FEMA Administrator[A];
* National Integration Center;
* Undersecretary for Preparedness[B].
Homeland Security Council Chaired Domestic Readiness Group:
* Provide strategic policy coordination;
* Mechanism for vetting the revision at the federal level;
* Resolve conflicting policy issues.
Steering Committee:
* Day to day management and oversight of the revision process;
* Management of the Work Groups and oversight of the Writing Team.
Writing Team:
* Overall management of the rewrite;
* Assigned and tracked writing issues to Work Groups.
Work Groups:
* Examined writing issues to determine if existing language in
document was adequate;
* If existing language deemed inadequate, provided recommended
changes to Writing Team.
Source: GAO analysis of DHS data.
[A] The work plan referred to the FEMA Administrator by his former
title, which was the Under Secretary for Federal Emergency Management.
[B] Most of the DHS preparedness functions became part of FEMA as part
of the Post-Katrina Act, and the transfer of these responsibilities
became effective on March 31, 2007.
[End of figure]
The revision schedule in the work plan was to begin in December 2006
with a goal to complete the revision process by June 2007. As a first
step in the plan, the Writing Team was to provide the Work Groups with
writing assignments. Once the Work Groups completed their writing
assignments, the Writing Team was to review their recommendations and
submit a draft of the revised NRF to the Steering Committee for its
review and approval. The Steering Committee was to release the first
draft of the revised NRF for stakeholder comment by the end of January
2007 with an approximate 30-day review period. According to the work
plan, the Steering Committee, Writing Team, and Work Groups would
review comments on this first draft, make any needed modifications, and
release a second draft at the end of March 2007 for the final of two 30-
day comment periods. Per the work plan, these two comment periods would
ensure wide dissemination of the product to all stakeholders, including
federal agencies, state and local governments, and major professional
associations. The work plan schedule also included a 2- month internal,
federal review process to take place beginning in May 2007, after which
DHS would provide the final draft for approval to the Domestic
Readiness Group and the signatories of the 2004 Plan, with the final
issuance of the revised 2004 Plan targeted for June 2007. See figure 3
for the proposed timeline for the revision process.
Figure 3: DHS's Revision Process as Planned by Its September 2006 Work
Plan and as Required by the October 2006 Post-Katrina Act:
[See PDF for image]
This figure is an illustration of DHS's Revision Process as planned by
Its September 2006 Work Plan and as required by the October 2006 Post-
Katrina Act, as follows:
September 2006:
Approved revision plan.
October 2006:
Post-Katrina Act enacted.
October-November 2006:
Hold stakeholder meetings.
December 2006:
Start revision process;
Establish NAC.
January 2007:
Release first draft to stakeholders.
March 2007:
Release second draft to stakeholders.
May - June, 2007:
Conduct internal federal review.
June 2007:
Published revised plan.
Source: GAO analysis of DHS data, and the Post-Katrina Act.
[End of figure]
DHS Included Non-Federal Stakeholders at the Beginning of the Revision
Process:
DHS included non-federal stakeholders in the early stages of the 2004
Plan revision process in accordance with the work plan. For example, in
October 2006, DHS hosted a meeting with approximately 90 non-federal
stakeholders where DHS sought feedback on the 14 revision issues from
participants using structured breakout groups. At this meeting, FEMA
reported that non-federal stakeholders identified the need for
enhancements to the 2004 Plan to further describe coordination
processes with the private sector and volunteer organizations. DHS held
a similar meeting with federal stakeholders in November 2006. According
to DHS, it modified the scope of some of the 14 revision issues and
added three additional issues. (See app. II for a listing of the 17
revision issues.)
DHS assigned non-federal stakeholders to serve as members of the
Steering Committee and the Work Groups. Although the work plan called
for the engagement of all levels of stakeholders in the revision
process and described the Steering Committee and Work Groups, it did
not specify the composition of the Work Groups but stated that one non-
federal stakeholder would serve on the Steering Committee. In the
spirit of the plan, DHS selected non-federal officials to serve on the
Steering Committee and Work Groups. Of the 32 members on the Steering
Committee, six members or 19 percent were non-federal officials,
including representatives from state and local government emergency
management associations as well as a local fire department and police
associations. According to a FEMA official, the Steering Committee, led
by FEMA and DHS co-chairs, generally met on a weekly basis via
teleconferences throughout the revision process.
Of the approximately 710 members who served on the 12 Work Groups, 224
officials, or 32 percent, were non-federal officials, including 3 of
the 27 Work Group co-leaders.[Footnote 18] These non-federal officials
included representatives from state and local emergency management
agencies and tribal governments as well as officials from the fire, law
enforcement, and public health sector. See figure 4 for the composition
of the 12 Work Groups members by level of government, nongovernmental
organization, and private sector. See appendix III for a listing of the
12 Work Groups and a table showing the occupational demographics of the
non-federal stakeholders who served on the Work Group.
Figure 4: Composition of the 710 Members of the 12 Work Groups by
Federal, State, Local, and Tribal Government, Nongovernmental
Organization, and Private Sector:
[See PDF for image]
This figure is a pie-chart depicting the following data:
Federal government - approximately 486 members: 68%;
Nongovernmental organization - 79 members: 11%;
State government - 67 members: 9%;
Local government - 35 members: 5%;
Private sector - 34 members: 5%;
Tribal government - 9 members: 2%.
Source: GAO analysis of DHS data.
Note: There was some uncertainty in the exact total number of Work
Group members due to duplication and lack of identifying information in
the data FEMA provided. However, because the inclusion of non-federal
stakeholders is the focus of this report, we took steps to correctly
determine the total number and composition of the non-federal Work
Group members.
[End of figure]
The Writing Team, which consisted of 11 federal officials and private
contractors for administrative support, did not include any non-federal
stakeholders. DHS stated that they invited one non-federal stakeholder
to be on the team but that they were not successful in their attempts
to secure that person.
The 12 Work Groups met in January and February 2007. During that time,
and in accordance with the work plan, the Work Groups met to address
the issues assigned to them by the Writing Team. Most Work Groups
addressed their issues by submitting recommended language changes to
the 2004 Plan, which generally consisted of inserting new language or
clarifying existing language. The Work Groups supported a recommended
language change by providing the rationale for such a change. For
example, the Writing Team tasked the Roles and Responsibilities Work
Group with clarifying and strengthening the role of state governments
in the 2004 Plan. One recommended language change suggested by this
Work Group was to describe the state government's role in the
coordination of resources through the Emergency Management Assistance
Compact, an interstate mutual aid compact that provides a legal
structure through which affected states may request assistance from
other states during a disaster.[Footnote 19]
All Work Group recommendations were due to the Writing Team by the
middle of February 2007. Although the work plan provided for the Work
Groups' continued involvement after submitting their recommendations,
this did not occur.
DHS Departed from the Work Plan by Conducting an Internal Federal
Review Rather Than Providing a Draft to Non-Federal Stakeholders for
Comment:
On March 13, 2007, DHS officials e-mailed stakeholders that the release
of the first revision draft for the first 30-day comment period was
being delayed. According to the message, DHS still planned to release
the draft within the next several weeks and issue a final document by
June 1, 2007. The message noted that once an updated timeline was
approved, DHS would share the dates with the stakeholders.
According to FEMA officials, the first draft of the revised 2004 Plan
was completed in April 2007 and incorporated many of the Work Groups'
recommendations. However, rather than sending this first draft to
stakeholders for comment, DHS conducted its internal, federal review of
the draft document for approximately 5 months until September 2007.
FEMA officials said that DHS did not release this April 2007 draft for
comment because the draft required further modifications DHS considered
necessary. An April 11, 2007, notice subsequently posted on DHS's Web
site described the status of the process and its plans to further
revise the draft for comment.
"As the NRP revision process unfolded, it became apparent that some
important issues were more complex than we originally thought and
require national-level policy decisions. We also came to the
realization that creating a more user-friendly document that clearly
addressed the roles and responsibilities of stakeholders and incident
management structures would require substantial format changes to the
NRP� An updated timeline has not been determined but we will share one
with you quickly."
FEMA officials said that the length of time for the review and approval
process, about 3 months longer than planned, was unpredictable and that
it took longer than they had expected. DHS did not modify or update the
work plan to reflect this deviation from the approved revision process
or propose how the revision process would now be completed.
Certain non-federal stakeholders we interviewed who served on the
Steering Committee and as co-leaders on the Work Groups reported
receiving occasional or no communication from DHS on the decision not
to release the first draft for comment or how the revision process
would be completed during this internal, federal review process. FEMA's
Deputy Administrator acknowledged that the federal government should
have done a better job in communicating the status of the draft and the
revision process to non-federal stakeholders while the document was
undergoing the internal, federal review.
During this internal, federal review, DHS and FEMA officials continued
to revise the April 2007 draft. For example, FEMA officials said that
they added a chapter to explain the need for all levels of government
to plan for preparedness and response actions and additional language
to clarify the role of state and local governments during disaster
response. At this point in the process, around August 2007, DHS's
Office of the Deputy Secretary[Footnote 20] decided to release a
revised draft just to the Steering Committee and the Domestic Readiness
Group for comment. Writing Team officials assumed that the Deputy
Secretary would make the final decision on whether to incorporate the
comments received while staff from his office would be responsible for
completing any further edits. A draft of this document, dated July
2007, was leaked to the press in August 2007.
During a September 11, 2007, hearing before the House Transportation
and Infrastructure Committee,[Footnote 21] officials representing state
and local emergency management associations expressed their concerns
that the July 2007 leaked draft had changed significantly from the
April 2007 draft. The government affairs committee chair of the
International Association of Emergency Managers[Footnote 22] testified,
"The document we saw bore no resemblance to what we had discussed so
extensively with FEMA and other stakeholders in the December 2006
through February 2007 timeline." Additionally, the National Emergency
Management Association[Footnote 23] representative, who served on the
Steering Committee, expressed his concern that its association had been
effectively shut out of the process, testifying that the collaborative
process in rewriting the 2004 Plan "broke down�with no stakeholder
input, working group involvement, or steering committee visibility.":
After the Internal, Federal Review, DHS Provided All Stakeholders an
Opportunity to Comment before Final Publication and Considered All
Comments in Finalizing the New Framework:
After the approximate 5-month internal, federal review period, DHS
released a draft of the newly renamed National Response Framework for
public comment on September 10, 2007. However, as we stated earlier,
the original work plan called for DHS to provide stakeholders with two
30-day public comment periods before the internal, federal review;
after the review, DHS was to publish the revised document without
further comment by stakeholders. The public comment period starting on
September 10 allowed for both federal and non-federal stakeholders to
provide their reactions to the changes made during the internal federal
review process. FEMA officials said they conducted this unplanned
public comment period to address the work plan's requirement that the
draft NRF be widely disseminated for all stakeholders to review. FEMA
provided a 40-day public comment period for the NRF core document. FEMA
received 3,318 comments on the core NRF. [Footnote 24]
The Writing Team led the adjudication--review, analysis, and
resolution--of the comments received during the public comment period.
The Writing Team examined each comment, made an initial disposition
recommendation--accepted, modified, rejected, or noted--and forwarded
that recommendation to the FEMA leadership and the Domestic Readiness
Group for review. In addition, FEMA posted a spreadsheet on [hyperlink,
http://www.regulations.gov] that included, among other things, the
comments made by non-federal stakeholders and the final disposition
FEMA assigned to each of those comments. This allowed these
stakeholders to see how FEMA did or did not incorporate their comments
into the final NRF document. The Work Groups and Steering Committee,
both of which contained non-federal stakeholders, were not involved in
adjudicating the public comments, although this was called for by the
work plan. A FEMA official said that the agency tried to recruit a non-
federal stakeholder to serve on the Writing Team, but that its efforts
were unsuccessful.
DHS's Establishment of the National Advisory Council Did Not Meet Post-
Katrina Act Deadlines, Which Also Limited Collaboration with Non-
Federal Stakeholders:
The Post-Katrina Act required the DHS Secretary to establish a National
Advisory Council (NAC) by December 2006 to advise the FEMA
Administrator on all aspects of emergency management. Among its
specific responsibilities, the NAC was to incorporate input from state,
local, and tribal governments as well as the private sector in the
revision of the 2004 Plan. The Act stated that the membership of the
NAC should represent a geographic and substantive cross-section of
officials, emergency managers, and emergency response providers, such
as law enforcement, fire service, health scientists, and elected
officials. However, DHS did not incorporate the NAC by amending its
approved September 2006 work plan for revising the 2004 Plan or
establish the NAC in time for the Council to incorporate non-federal
stakeholder input into the revision of the 2004 Plan, as directed by
the October 2006 Post-Katrina Act. According to a FEMA official, DHS
did not amend the work plan to incorporate the NAC because of the
uncertainty surrounding the time it would take to establish the NAC.
The official said FEMA expected that establishing the NAC would take
more time than the Post-Katrina Act allowed because FEMA wanted to
ensure that the NAC's membership complied with the requirements
contained in the Post-Katrina Act while also providing adequate time to
announce the NAC's creation, solicit applications for membership, and
review and select applicants for membership. FEMA announced the
membership of the NAC in June 2007, 6 months after the Post-Katrina Act
deadline, and the NAC did not hold its inaugural meeting until October
22, 2007, the last day of the public comment period for the base NRF.
According to the FEMA Administrator, it was more important for the
agency to invest the time needed to review hundreds of applications and
create a high quality body of advisors than to rush the process to meet
the 60-day statutory deadline for establishing the NAC.
As a result, the NAC's only involvement in the NRF revision process
occurred when FEMA provided it with a copy of a draft in December 2007,
2 months after the public comment period closed. According to the NAC
chairman, the NAC gathered and consolidated comments from individual
members and provided these comments to the FEMA Administrator
approximately one month before FEMA published the NRF in January 2008.
[Footnote 25] The chairman noted that these comments were from
individual members and did not reflect the official comments of the NAC
as a whole. For the next NRF revision, the chairman stated that he
expected the NAC to be actively involved with FEMA throughout the
entire revision process. For example, he suggested that the NAC could
have a role in the adjudication of public comments by representing non-
federal stakeholders during the adjudication process to ensure FEMA is
aware of issues that are critically important to state and local
governments. The NAC is currently exploring its role in reviewing and
implementing the 2008 NRF. For example, at the NAC's February 2008
meeting the NAC Chairman approved a standing committee on the NRF that
may focus on actions that can help FEMA implement and train
stakeholders on the NRF. While the NAC filed a charter on February 6,
2007, the charter reflects the NAC's broad array of statutory
responsibilities, but does not detail any specific responsibilities the
NAC would undertake relative to the NRF revision process. See figure 5
for a comparison of DHS's actual revision process with its proposed
process.
Figure 5: DHS's Actual Revision Process Compared with Its Proposed
Process:
[See PDF for image]
This figure is an illustration of DHS's actual Revision Process
compared with Its Proposed Process, as follows:
Date: September 2006;
DHS's Actual Revision Process: Approved revision work plan;
DHS's Revision Process By Work Plan and Post-Katrina Act: Approved
revision work plan.
Date: October 2006;
DHS's Actual Revision Process:
DHS's Revision Process By Work Plan and Post-Katrina Act:
Date:
DHS's Actual Revision Process: Post-Katrina Act enacted;
DHS's Revision Process By Work Plan and Post-Katrina Act: Post-Katrina
Act enacted.
Date: October - November 2006;
DHS's Actual Revision Process: Hold stakeholder meetings;
DHS's Revision Process By Work Plan and Post-Katrina Act: Hold
stakeholder meetings.
Date: December 2006;
DHS's Revision Process By Work Plan and Post-Katrina Act:
* Start revision process;
* Establish NAC.
Date: January 2007;
DHS's Actual Revision Process: Started revision process;
DHS's Revision Process By Work Plan and Post-Katrina Act: Release first
draft to stakeholders.
Date: March 2006;
DHS's Revision Process By Work Plan and Post-Katrina Act: Release
second draft to stakeholders.
Date: April 2007;
DHS's Actual Revision Process: Produced first draft but did not release
to stakeholders.
Date: April - August 2007:
DHS's Actual Revision Process: Conducted internal federal review of
first draft.
Date: June 2007:
DHS's Actual Revision Process: Announced NAC membership;
DHS's Revision Process By Work Plan and Post-Katrina Act: Publish
revised plan.
Date: September 2007;
DHS's Actual Revision Process: Congressional hearing of revision
process.
Date: September - October 2007:
DHS's Actual Revision Process: Release first draft for public comments.
Date: October - December 2007;
DHS's Actual Revision Process: Adjudicated public comments.
Date: December 2007:
DHS's Actual Revision Process: NAC reviewed a draft NRF.
Date: January 2008:
DHS's Actual Revision Process: Published NRF.
Source: GAO analysis of DHS data, and the Post-Katrina Act.
[End of figure]
The late establishment of the NAC also hindered FEMA from fully
collaborating with non-federal stakeholders who were involved in the
revision process established by the approved work plan. In particular,
two non-federal Steering Committee members stated that after the August
2007 leak of the draft NRF, FEMA stopped sharing drafts with non-
federal officials. FEMA officials said that the reason for this
decision was because FEMA had yet to establish the NAC, its official
advisory committee. FEMA officials said that the absence of an official
advisory committee raised fairness concerns about which members of the
non-federal community should be allowed to provide input before the
public comment period. As a result, FEMA stopped sharing pre-decisional
drafts with non-federal members of the Steering Committee because FEMA
did not plan to provide the same opportunity to other non-federal
stakeholders until the public comment period.
FEMA and the Post-Katrina Act Have Recognized the Importance of
Including Non-Federal Stakeholders in Developing National Response
Doctrine, but FEMA Lacks Guidance and Procedures for Future NRF
Revisions:
While FEMA has recognized the importance of partnering with non-federal
stakeholders to achieve the nation's emergency management goals, both
in congressional testimonies as well as in its January 2008 strategic
plan, FEMA has not yet developed guidance and procedures for how future
revisions of the NRF will be managed or how the newly established
National Advisory Council will be integrated into the revision process
in accordance with the Post-Katrina Act. Standards for Internal Control
in the Federal Government state that management guidance, policies, and
procedures are an integral part of any agency's planning for, and
achieving, effective results.[Footnote 26] Developing such policies and
procedures for how the NRF will be revised in the future and how FEMA
will integrate the NAC and other non-federal stakeholders in the
process is essential for helping to ensure that FEMA attains its goal
of partnering with nonfederal stakeholders to help achieve the nation's
emergency management goals.
FEMA and the Post-Katrina Act Stress Partnership and Communication with
Non-Federal Stakeholders in Achieving the Nation's Emergency Management
Goals:
FEMA has recognized the importance of including the input of non-
federal stakeholders to help achieve the nation's emergency management
goals. For example, in November 2006, the FEMA Administrator outlined
his vision for a "New FEMA,"[Footnote 27] asserting FEMA's dedication
to partnering with all states and the private sector because of FEMA's
reliance on its partners to accomplish the national emergency response
objectives. More recently, in congressional testimonies the FEMA
Administrator has reaffirmed the need for FEMA to partner with both
federal and non-federal stakeholders.[Footnote 28] In addition, one
objective in FEMA's Strategic Plan for 2008-2013 is to engage public
and private stakeholders in developing and communicating clear national
doctrine and policy.[Footnote 29] To achieve this objective, the
Strategic Plan identifies the need to engage stakeholders early and
often in the process of developing national doctrine. This is in
accordance with internal control standards for the federal government
that state that information should be communicated to those who need it
and in a form and within a time frame that enables them to carry out
their responsibility for an agency to achieve its objectives.[Footnote
30] For example, management should ensure there are adequate means of
communicating with and obtaining information from external stakeholders
who may have a significant impact on the agency's achieving its goals.
In October 2005, we also reported that frequent communication among
collaborating organizations and stakeholders is a means to facilitate
working across boundaries, prevent misunderstanding, and achieve agency
objectives.[Footnote 31] Frequent communication is one of a number of
practices that enhance and sustain collaboration.
Recognizing the importance of collaboration, the Post-Katrina Act
requires that the FEMA Administrator partner with non-federal
stakeholders from state, local, and tribal governments, the private
sector, and nongovernmental organizations to build a national system of
emergency management that can effectively and efficiently utilize the
full measure of the nation's resources to respond to all disasters,
including catastrophic incidents, and acts of terrorism.[Footnote 32]
Specifically, the Post-Katrina Act directs the FEMA Administrator,
through the National Integration Center, to periodically review and
revise the National Response Plan and any successor to such plan and,
as discussed above, to establish the NAC to incorporate non-federal
stakeholder input in the revision and development of the Plan, among
other things. The Post-Katrina Act further directs the FEMA
Administrator to appoint council members who represent a geographic and
substantive cross section of officials, emergency managers, and
emergency response providers from the non-federal community.
The FEMA Administrator's statements, the agency's latest strategic
plan, and the Post-Katrina Act also reflect a key precept related to
government performance and results--that stakeholders can have a
significant effect in determining whether a federal agency's program or
action will succeed or fail, and as such, stakeholders need to be
involved in major planning efforts conducted by the agency.[Footnote
33] Such involvement is important to help agencies ensure that their
efforts and resources are targeted at the highest priorities and is
particularly important in instances where federal agencies face a
complex political environment, such as emergency management in which
FEMA's successes depend on the actions of non-federal partners at the
state and local levels.
FEMA Has Not Yet Developed Guidance and Procedures for Managing Future
Revisions or Integrating the National Advisory Council into the
Revision Process:
While FEMA officials and the National Response Framework acknowledge
that the NRF will need to be revised in the future, FEMA has not
developed guidance or policies on how it will manage future revisions
or described how the NAC will be incorporated into the next NRF
revision process. FEMA officials said that the agency has not yet
developed guidance and procedures for any future NRF revisions because
of the need to focus federal resources on creating training materials
to assist all stakeholders in implementing the current NRF in
anticipation of the pending 2008 hurricane season. As mentioned earlier
in this report, the 2004 Plan included a section specifying the
circumstances, such as lessons learned from exercises and actual
events, and time frames under which it would need to be reviewed and
revised. This section is in accordance with the federal internal
control standard of monitoring operations to assess the quality of
performance over time and ensure that the findings of reviews and
evaluations are resolved. The 2008 NRF, while it states that it merits
periodic review and revision, does not contain such language regarding
the circumstances and time frames for its review and revision. In
addition, FEMA officials said that the process established for the last
revision (the 2006-approved work plan) would not be applicable for any
future revisions because it did not consider the role of the NAC. The
NAC has also not yet determined how it would like to be involved in the
next NRF revision process. The NAC's charter, approved in February
2007, does not provide specific procedures on how it is to be involved
and, according to the chairman, the NAC's NRF subcommittee expects to
focus its efforts on helping FEMA train non-federal stakeholders.
Having such guidance and procedures in place is an important internal
control, and we have identified this need for other agencies in similar
circumstances to FEMA's management of future NRF revisions. As we
discussed earlier in this report, control activities--such as guidance,
policies, and procedures--are an integral part of an agency's planning
for and achieving effective results.[Footnote 34] In addition, while
internal controls should be flexible to meet an agency's needs, they
should also be clearly documented, readily available, and properly
maintained. We have also previously reported on the need to include
state and local jurisdictions in the development of national response
plans because they are key stakeholders and would be on the front lines
if an incident occurs.
* In April 2008, we reported on the need for the Department of
Defense's Northern Command to collaborate and communicate with non-
federal stakeholders and establish a process to guide such
collaboration in accessing information on state emergency response
plans and capabilities, noting that the absence of effective
collaboration could impede intergovernmental planning for catastrophic
incidents and overall coordination.[Footnote 35] Specifically, we
reported that federal officials involved the states only minimally in
the development of the Department of Defense's major homeland defense
and civil support plans and that defense officials were generally not
familiar with state emergency response plans and capabilities and had
not established a process for gaining access to this information. We
also reported that each agency's roles and responsibilities for
planning for homeland defense and civil support during a catastrophic
disaster were not clearly defined. We recommended, among other things,
that the Department of Defense develop a thorough process to guide its
coordination with the states. The department generally agreed with the
recommendation and stated that it was coordinating with DHS to develop
synchronized plans of integrated federal, state, and local operational
capabilities to affect a coordinated national response. It is essential
for both the Department of Defense and DHS to have such guidance in
place, as both DHS's National Response Framework and the Northern
Command's Concept of Operations emphasize coordination with non-federal
stakeholders in order to prevent, prepare for, respond to, and recover
from catastrophic natural and manmade disasters.
* In August 2007, we reported on the administration's approach to
preparing for a pandemic influenza by issuing, among other things, a
National Strategy for Pandemic Influenza (Strategy) in November 2005,
and a National Strategy for Pandemic Influenza Implementation Plan
(Plan) in May 2006.[Footnote 36] We reported, among other things, that
state and local jurisdictions were not directly involved in developing
the Strategy and Plan. Neither the Strategy nor Plan described the
involvement of key stakeholders, such as state, local, and tribal
entities, in their development, even though these stakeholders would be
on the front lines in a pandemic and the Plan identifies actions they
should complete. Officials told us that while the drafters of the Plan
were generally aware of their concerns, state, local, and tribal
entities were not directly involved in reviewing and commenting on the
Plan. We concluded that opportunities existed to improve the usefulness
of the Plan because it was viewed as an evolving document and was
intended to be updated on a regular basis to reflect ongoing policy
decisions as well as improvements in domestic preparedness. However,
time frames or mechanisms for updating the Plan were undefined. We
recommended that the White House Homeland Security Council establish a
specific process and time frame for updating the Plan and that the
update process should involve key non-federal stakeholders and
incorporate lessons learned from exercises and other sources, but the
Homeland Security Council did not provide comments on this
recommendation.
Without similar policies and procedures documenting the circumstances
and time frames under which it would review and revise the NRF and its
process for collaborating with non-federal stakeholders, FEMA cannot
ensure that future revision processes will be conducted in accordance
with management's directives.
Conclusions:
All disasters occur locally, and the initial post-disaster response is
local. However, large-scale disasters usually exceed local response
capabilities. Effective preparation and response for major and
catastrophic disasters require well-planned and well-coordinated
actions among all those who would have a role in the response to such
disasters. The 2008 NRF is a guide for the myriad of entities and
personnel involved in response efforts at all levels. The NRF
recognizes the need for collaboration among these stakeholders to
collectively respond to and recover from all disasters, particularly
catastrophic disasters such as Hurricane Katrina, regardless of their
cause.
To help ensure that the NRF meets the needs of all stakeholders who
have a role in its effective implementation, it is essential that DHS
fully collaborate with non-federal stakeholders in its development and
revision. DHS initially involved non-federal stakeholders in the
revision of the 2004 Plan but omitted a key step in its work plan by
not obtaining and incorporating their comments on the first full draft.
Instead, DHS undertook a closed, internal federal review of the draft
that lasted about 5 months with little communication with the non-
federal partners. The result was a breach of trust with DHS's non-
federal partners in the drafting process.
The Post-Katrina Act gives responsibility for maintaining and updating
the NRF to FEMA and charges the Administrator's National Advisory
Council with incorporating non-federal stakeholder input into the NRF's
development and revision. Established too late to fulfill this role in
the creation of the current NRF, the NAC is now functioning, and it is
important that there be compatible policies and procedures for how the
NAC will fulfill its statutory charge.
Contrary to effective government internal control and management
principles, FEMA has not yet developed policies and procedures for
guiding future revisions of the NRF, including specifying the
conditions and time frames under which FEMA would review and revise the
NRF and how FEMA will involve the NAC and collaborate with other non-
federal stakeholders. Especially in view of a new administration, non-
federal stakeholder participation and ownership is essential in any
revision of the NRF, and the lessons learned from the process for
revising the 2004 Plan will apply in the future to FEMA's and DHS's
efforts to develop and revise other national plans and policies that
make up the national preparedness system. While the NRF is published by
DHS, it belongs to the nation's emergency response community that is
collectively responsible for effectively implementing the NRF's
provisions should another catastrophic disaster like Hurricane Katrina
occur.
Recommendation for Executive Action:
We recommend that the FEMA Administrator develop and disseminate
policies and procedures that describe (1) the circumstances and time
frames under which the next NRF revision will occur and (2) how FEMA
will conduct the next NRF revision, including how its National Advisory
Council and other non-federal stakeholders--state, local, and tribal
governments; the private sector; and nongovernmental organizations--
will be integrated into the revision process and the methods for
communicating with these stakeholders.
Agency Comments:
We requested comments on a draft of this report from DHS and FEMA. They
concurred with our recommendations and had no other comments.
We are sending copies of this report to the Secretary of Homeland
Security, FEMA Administrator, and interested congressional committees.
We will also provide copies to others on request. If you or your staff
have any questions about this report or wish to discuss the matter
further, please contact me at (202) 512-8777 or [email protected].
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. See appendix IV
for a list of key contributors to this report.
Signed by:
William O. Jenkins, Jr.
Director, Homeland Security and Justice Issues:
[End of section]
Appendix I: Scope and Methodology:
This report addresses the following questions: (1) To what extent did
the Department of Homeland Security (DHS) collaborate with non-federal
stakeholders in revising and updating the December 2004 National
Response Plan into the January 2008 National Response Framework (NRF)?
(2) To what extent has FEMA developed policies and procedures for
managing future revisions of the NRF?
To address these questions, we interviewed DHS, FEMA, and non-federal
stakeholders who were directly involved in the revision and update of
the 2004 Plan into the 2008 NRF, and we reviewed DHS and FEMA documents
on the revision process. Because there were over 700 federal and non-
federal officials who participated in the Steering Committee and Work
Groups, we interviewed those who held key positions. The FEMA officials
and non-federal stakeholders we interviewed held key positions in the
revision process, such as the FEMA Administrator and Deputy
Administrator and the two FEMA co-chairs of the Steering Committee. The
non-federal stakeholders we interviewed included four of the five non-
federal officials who served as Steering Committee members and all
three of the non-federal officials who served as co-leaders of Work
Groups; these non-federal stakeholders also held positions in state,
county, and city governments and non-governmental organizations.
To determine the extent to which DHS collaborated with non-federal
stakeholders, we first determined the revision process that DHS had
planned to follow to revise the 2004 Plan. We reviewed DHS's September
2006 revision work plan that had been approved by the Domestic
Readiness Group of White House's Homeland Security Council and
interviewed FEMA and non-federal officials who served in key positions
in the revision process. We also reviewed applicable statutes,
primarily the October 2006 Post-Katrina Emergency Management Reform
Act, for statutory requirements related to the revision process. To
determine what happened during the revision process and the extent to
which DHS involved non-federal stakeholders in that process, we
interviewed FEMA officials and non-federal stakeholders who served in
key positions in the revision process and the chairman of FEMA's
National Advisory Council (NAC). Further, we reviewed DHS documentation
citing the roles provided to non-federal stakeholders in the revision
process and explaining how the actual revision process was conducted,
FEMA documentation on the process and time frames related to the NAC's
establishment, NAC documentation regarding its role in the revision
process, and congressional testimony from non-federal stakeholders on
how DHS conducted and included them in the revision process. To
determine the extent to which FEMA had policies and procedures in place
for future revisions of the NRF, we interviewed FEMA officials.
The non-federal officials we interviewed represented state and local
levels of government, emergency management associations, and other non-
federal entities. While the statements and views of the stakeholders we
interviewed are not generalizable to the some 230 non-federal
stakeholders involved in the revision process, we chose to speak to
them because of their assigned key roles.
There is some uncertainty in our determination of the total number of
non-federal members in the 12 Work Groups, and thus the total number of
Work Group members, due to duplication or the lack of adequate
information identifying a member as federal in the data provided by
FEMA. However, because DHS's inclusion of non-federal members in the
revision process is the focus of this report, we took steps to
correctly determine the number and composition of the 224 non-federal
members. Based on our analysis of FEMA's data for federal members, we
believe the total of 486 federal members is a reasonable approximation,
and therefore, the grand total of 710 Work Group members is also a
reasonable approximation.
[End of section]
Appendix II: The 17 Key Revision Issues That DHS Identified for the
2004 National Response Plan:
In the 2004 National Response Plan revision work plan approved by the
Domestic Readiness Group, a White House Homeland Security Council-
chaired policy committee, in September 2006, DHS identified 14 key
issues that it wanted the revision process to address. According to
FEMA officials, these issues were compiled by reviewing Hurricane
Katrina after-action and lessons-learned reports from the White House,
Congress, GAO, and DHS's Inspector General and identifying common
issues that were raised in multiple reports. The work plan directed DHS
to conduct meetings with stakeholders to review the initial list and
identify other issues to be considered during the revision process.
These issues were to serve as the starting point from which the 2004
Plan revision would be conducted. DHS held meetings with non-federal
stakeholder and federal stakeholders in October and November 2006
respectively. After these meetings, DHS identified three additional
revision issues to its initial list contained in the approved work
plan. The 17 key revision issues are listed below--the 3 issues added
after the stakeholder meetings are indicated with a note.
The revision issues are categorized by whether they were to be
addressed in either the 2004 Plan base document or its annexes. The
2004 Plan comprised four major components: the Base Plan, Emergency
Support Function Annexes, Support Annexes, and Incident Annexes. The
Base Plan provided an overview of the structure and processes
comprising a national approach to domestic response actions. The 15
Emergency Support Function Annexes detailed the missions, policies,
structures, and responsibilities of federal agencies for coordinating
resource and programmatic support, such as mass care and shelter, to
states, tribes, and other federal agencies or other jurisdictions and
entities. The nine Support Annexes provided guidance and described the
functional processes and administrative requirements necessary to
ensure the 2004 Plan's efficient and effective implementation. The
seven Incident Annexes addressed contingency or hazard situations
requiring specialized application of the 2004 Plan, such as biological,
catastrophic, and nuclear/radiological incidents.
The key revision issues identified for the 2004 National Response Plan
base document were:
* clarify roles and responsibilities of key structures, and positions,
and levels of government;
* strengthen role of states and private sector;
* integrate National Incident Management System concepts, principles,
terminology, systems, and organizational processes into the revised
National Response Plan;
* review Joint Field Office structure and operations, to include
Unified Command; and:
* incorporate proactive planning for incidents that render state and
local governments incapable of an effective response.
The key revision issues identified for the annexes to the 2004 National
Response Plan base document were:
* examine all existing National Response Plan annexes and proposed new
annexes;
* strengthen External Affairs and Public Affairs Annexes;
* review logistics management issues; [Footnote 37]
* examine evacuation and sheltering issues; [Footnote 38]
* ensure the integration of all search and rescue assets;
* review the scope of public safety and security missions;
* incorporate companion animal issues;
* improve process for identifying and accepting donated goods and the
integration of volunteers;
* clarify international support mechanisms;
* ensure consistency with National Emergency Communication Strategy;
* refine the Catastrophic Incident Supplement to include the review of
a possible increased Department of Defense responsibility, and;
* review federal incident management plans and determine their
appropriate linkage to the National Response Plan.[Footnote 39]
[End of section]
Appendix III: The 12 Work Groups DHS Established during the Revision
Process and Their Composition:
The 2004 National Response Plan revision work plan approved by the
Domestic Readiness Group in September 2006 directed DHS to establish
Work Groups to rewrite portions of the 2004 Plan. While the work plan
did not specify the number of Work Groups that should be established,
DHS formed 12 Work Groups that were co-led by federal officials or a
combination of federal and non-federal officials. The 12 Work Groups
were:
* Catastrophic Planning;
* Communications;
* Companion Animals;
* Evacuations and Sheltering (co-led by non-federal stakeholder);
* Functions;
* Incident Management and Coordination;
* International Support;
* National Incident Management System;
* Roles and Responsibilities (co-led by non-federal stakeholder);
* Special Needs;
* Training and Implementation, and;
* Volunteer and Donation Management (co-led by non-federal
stakeholder).
Of the 709 members who served on the 12 Work Groups, 224 officials, or
32 percent, were non-federal. These non-federal stakeholders included
representatives from state, tribal, and local government as well as the
private sector and nongovernmental organizations. Further, the non-
federal stakeholders came from various occupational sectors. See table
1 for a description of these 224 non-federal stakeholders.
Table 1: The 224 Non-Federal Stakeholders Who Participated in the
Revision Work Groups by Occupational Sector and by Level of Government,
Nongovernmental Organization, and Private Sector:
Occupational sector[A]: Animal, plant and food[B];
Level of government: Local: 2;
Level of government: Tribal: [Empty];
Level of government: State: 5;
Nongovernmental organization: 12;
Private sector: 2;
Total: 21.
Occupational sector[A]: Critical infrastructure[C];
Level of government: Local: 1;
Level of government: Tribal: [Empty];
Level of government: State: [Empty];
Nongovernmental organization: 3;
Private sector: 11;
Total: 15.
Occupational sector[A]: Disaster assistance services[D];
Level of government: Local: [Empty];
Level of government: Tribal: [Empty];
Level of government: State: [Empty];
Nongovernmental organization: 24;
Private sector:
-; Total: 24.
Occupational sector[A]: Elected government officials;
Level of government: Local: [Empty];
Level of government: Tribal: 1;
Level of government: State: [Empty];
Nongovernmental organization: [Empty];
Private sector: [Empty];
Total: 1.
Occupational sector[A]: Emergency management and homeland security[E];
Level of government: Local: 7;
Level of government: Tribal: 7;
Level of government: State: 40;
Nongovernmental organization: 8;
Private sector: 4;
Total: 66.
Occupational sector[A]: Emergency medical providers and health
sector[F];
Level of government: Local: 5;
Level of government: Tribal: [Empty];
Level of government: State: 8;
Nongovernmental organization: 9;
Private sector: [Empty];
Total: 22.
Occupational sector[A]: Fire and search and rescue;
Level of government: Local: 4;
Level of government: Tribal: [Empty];
Level of government: State: [Empty];
Nongovernmental organization: 3;
Private sector: [Empty];
Total: 7.
Occupational sector[A]: General business[G];
Level of government: Local: [Empty];
Level of government: Tribal: [Empty];
Level of government: State: [Empty];
Nongovernmental organization: [Empty];
Private sector: 12;
Total: 12.
Occupational sector[A]: General government[H];
Level of government: Local: 3;
Level of government: Tribal: [Empty];
Level of government: State: [Empty];
Nongovernmental organization: [Empty];
Private sector: [Empty];
Total: 3.
Occupational sector[A]: Logistics and transportation[I];
Level of government: Local: 1;
Level of government: Tribal: [Empty];
Level of government: State: 1;
Nongovernmental organization: 2;
Private sector: 3;
Total: 7.
Occupational sector[A]: Military and national security related[J];
Level of government: Local: [Empty];
Level of government: Tribal: [Empty];
Level of government: State: 3;
Nongovernmental organization: [Empty];
Private sector: 2;
Total: 5.
Occupational sector[A]: Police and corrections;
Level of government: Local: 10;
Level of government: Tribal: [Empty];
Level of government: State: 3;
Nongovernmental organization: 2;
Private sector: [Empty];
Total: 15.
Occupational sector[A]: Special needs populations[K];
Level of government: Local: 1;
Level of government: Tribal: [Empty];
Level of government: State: [Empty];
Nongovernmental organization: 7;
Private sector: [Empty];
Total: 8.
Occupational sector[A]: Standards and accreditation bodies;
Level of government: Local: [Empty];
Level of government: Tribal: [Empty];
Level of government: State: [Empty];
Nongovernmental organization: [Empty];
Private sector: [Empty];
Total: 0.
Occupational sector[A]: Volunteerism and voluntary organizations[L];
Level of government: Local: [Empty];
Level of government: Tribal: [Empty];
Level of government: State: 7;
Nongovernmental organization: 8;
Private sector: [Empty];
Total: 15.
Occupational sector[A]: Unidentified[M];
Level of government: Local: 1;
Level of government: Tribal: 1;
Level of government: State: [Empty];
Nongovernmental organization: 1;
Private sector: [Empty];
Total: 3.
Occupational sector[A]: Total non-federal stakeholders;
Level of government: Local: 35;
Level of government: Tribal: 9;
Level of government: State: 67;
Nongovernmental organization: 79;
Private sector: 34;
Total: 224.
Source: GAO analysis of FEMA data.
[A] We developed this list of occupational sectors based on our
analysis and categorization of the entities these 224 non-federal
stakeholders represented.
[B] Includes agriculture, animal control, animal health & welfare, food
production and security, and veterinary associations.
[C] Includes communications, cybersecurity, information technology,
public works, and water.
[D] Includes emergency food support, Red Cross, and religion-based
assistance services.
[E] Includes business continuity, contingency planning, crisis
management, and risk analysis.
[F] Includes emergency medical technicians, health officials,
pharmacists and physicians associations; health departments and
systems; and medical aviation.
[G] Includes Chambers of Commerce, commodities trading, general
consulting firms, public relations, and trade associations.
[H] Includes cities association, city managers association, and city
officials.
[I] Includes package delivery services, revenue collection, supply-
chain management, and mass transit.
[J] Includes civilian air patrol, military affairs, and a national
security related business association.
[K] Includes children, disabilities, and low income housing.
[L] Includes national, state, and local agencies that coordinate
individual volunteers or coordinate voluntary organizations.
[M] Unidentified means that we were able to determine the non-federal
stakeholder's level of government, nongovernmental organization, or the
private sector, but we could not determine the stakeholder's
occupational sector. We excluded one unidentified non-federal
stakeholder from this table for whom we could neither determine the
individual's occupational sector nor level of government, a
nongovernmental organization, or the private sector.
[End of table]
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
William O. Jenkins, Jr., (202) 512-8777 or [email protected]:
Acknowledgments:
The following teams and individuals made key contributions to this
report: Pille Anvelt, Patrick Bernard, Sam Hinojosa, Christopher
Keisling, David Lysy, Sally Williamson, and Candice Wright, Homeland
Security & Justice Team; Michele Fejfar, Applied Research & Methods;
and Christine Davis, Jan Montgomery, and Janet Temko, General Counsel.
[End of section]
Footnotes:
[1] GAO, Catastrophic Disasters: Enhanced Leadership, Capabilities, and
Accountability Controls Will Improve the Effectiveness of the Nation's
Preparedness, Response, and Recovery System, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-06-618] (Washington, D.C.: Sept.
6, 2006).
[2] The Post-Katrina Act was enacted as Title VI of the Department of
Homeland Security Appropriations Act, 2007, Pub. L. No. 109-295, 120
Stat. 1355 (2006).
[3] The new National Response Framework became effective on March 22,
2008.
[4] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-21.3.1]
(Washington, D.C.: November 1999).
[5] 42 U.S.C. 5121 et. seq.
[6] Pub. L. No. 107-296, 116 Stat. 2135 (2002).
[7] Our report will refer to individual DHS components such as FEMA
where the component has a defined, specific authority or can be
identified as being specifically responsible for a particular action or
decision. Otherwise, any reference to DHS will refer to DHS as a whole
unless clearly specified otherwise.
[8] U.S. House of Representatives, House Select Bipartisan Committee to
Investigate the Preparation for and Response to Hurricane Katrina, A
Failure of Initiative: Final Report of the House Select Bipartisan
Committee to Investigate the Preparation for And Response to Hurricane
Katrina (Washington, D.C.: Feb. 15, 2006).
[9] U.S. Senate Committee on Homeland Security and Governmental
Affairs, Hurricane Katrina: A Nation Still Unprepared (Washington,
D.C.: May 2006).
[10] White House Homeland Security Council, The Federal Response to
Hurricane Katrina: Lessons Learned (Washington, D.C.: Feb. 23, 2006).
[11] Department of Homeland Security Office of Inspector General, A
Performance Review of FEMA's Disaster Management Activities in Response
to Hurricane Katrina, OIG-06-32 (Washington, D.C.: Mar. 31, 2006).
[12] Federal Emergency Management Agency, DHS/FEMA Initial Response
Hotwash: Hurricane Katrina in Louisiana, DR-1603-LA (Feb. 13, 2006).
[13] Pub. L. No. 109-234, 120 Stat. 418 (2006).
[14] H.R. Conf. Rep. No. 109-494, at 118 (2006).
[15] According to the December 2004 National Response Plan, a Notice of
Change for updates to the Plan must specify the date, number, subject,
purpose, background, and action required and provide the change
language on one or more numbered and dated insert pages that would
replace the modified pages in the Plan. Once published, the
modifications were to be considered part of the Plan for operational
purposes pending a formal revision and reissuance of the entire
document.
[16] There were 32 signatories to the 2004 National Response Plan--the
heads of 15 federal departments, plus the Central Intelligence Agency,
Environmental Protection Agency, FBI, Federal Communications
Commission, General Services Administration, NASA, National
Transportation Safety Board, Nuclear Regulatory Commission, Office of
Personnel Management, Small Business Administration, Social Security
Administration, Tennessee Valley Authority, U.S. Agency for
International Development, U.S. Postal Service, American Red Cross,
Corporation for National and Community Service, and National Voluntary
Organizations Active in Disaster.
[17] The work plan also established a fourth entity, the Interagency
Task Force. The work plan primarily charged the Task Force with
resolving conflicts in preparedness and response policy before these
conflicts were presented to the Domestic Readiness Group for
resolution.
[18] Some Work Groups had one leader and others had two or three co-
leaders.
[19] GAO reported on this state-level compact in GAO, Emergency
Management Assistance Compact: Enhancing EMAC's Collaborative and
Administrative Capacity Should Improve National Disaster Response,
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-854] (Washington,
D.C.: June 29, 2007).
[20] The DHS Deputy Secretary at the time resigned from his position in
October 2007.
[21] Readiness in the Post-Katrina and Post-9/11 World, Hearing of U.S.
House Representatives, Committee on Transportation and Infrastructure,
Subcommittee on Economic Development, Public Buildings, and Emergency
Management, Sept. 11, 2007. The purpose of this hearing was to explore
the process for revising the 2004 National Response Plan.
[22] The International Association of Emergency Managers is a non-
profit educational organization of emergency managers and disaster
response professionals from all levels of government, as well as the
military, the private sector and volunteer organizations in 58
countries, with the mission to serve its members by providing
information, networking and professional opportunities, and to advance
the emergency management profession.
[23] The National Emergency Management Association is a nonprofit,
nonpartisan association of emergency management and homeland security
professionals with a mission to provide national leadership and
expertise in comprehensive emergency management; serve as a vital
emergency management information and assistance resource; and advance
continuous improvement in emergency management through strategic
partnerships, innovative programs, and collaborative policy positions.
[24] FEMA also released NRF's supplemental materials--including the
Emergency Support Function Annexes, the Support Annexes, and the
Incident Annexes--for a 30-day public comment period and received 2,385
comments on these documents. See appendix II for descriptions of these
NRF supplemental materials.
[25] NAC submitted comments by using the form that FEMA asked the
public to use when submitting comments on [hyperlink,
http://www.regulations.gov].
[26] GAO, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-
21.3.1].
[27] Federal Emergency Management Agency, Director Paulison Lays Out
Vision for "New FEMA," Press Release FNF-06-019 (November 2006).
[28] "Reforming FEMA: Are We Making Progress?" R. David Paulison
statement for the record before the United States House of
Representatives, House Homeland Security Committee, Subcommittee on
Emergency Communications, Preparedness, and Response and Subcommittee
on Management, Investigations, and Oversight, February 28, 2007; and
"The 2007 Hurricane Season: Are We Prepared?" R. David Paulison Oral
Statement Before the United States House of Representatives, House
Homeland Security Committee, Subcommittee on Emergency Communications,
Preparedness, and Response, May 15, 2007.
[29] Federal Emergency Management Agency, FEMA Strategic Plan Fiscal
Years 2008-2013: The Nation's Preeminent Emergency Management and
Preparedness Agency, FEMA P-422 (January 2008).
[30] GAO, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-
21.3.1].
[31] GAO, Results-Oriented Government: Practices That Can Help Enhance
and Sustain Collaboration among Federal Agencies, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-06-15] (Washington, D.C.: October
2005).
[32] The Post-Katrina Act, Pub. L. No. 109-295, � 611, 120 Stat. 1355,
1396-1397 (amending the Homeland Security Act, � 503(b)(2)(B).
[33] GAO, Executive Guide: Implementing the Government Performance and
Results Act, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/GGD-96-
118] (Washington, D.C.: June 1996).
[34] GAO, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-
21.3.1].
[35] GAO, Homeland Defense: Steps Have Been Taken to Improve U.S.
Northern Command's Coordination with States and National Guard Bureau,
but Gaps Remain, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-
252] (Washington, D.C.: Apr. 16, 2008).
[36] GAO, Influenza Pandemic: Further Efforts are Needed to Ensure
Clearer Federal Leadership Roles and Effective National Strategy,
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-781] (Washington,
D.C.: Aug. 14, 2007). See also GAO, Influenza Pandemic: Opportunities
Exist to Clarify Federal Leadership Roles and Responsibilities and
Improve Pandemic Planning, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-07-1257T] (Washington, D.C.: Sept. 26, 2007).
[37] . This issue was added after DHS presented the initial 14 key
revision issues identified in the work plan at stakeholder meetings
with non-federal and federal stakeholders in October and November 2006.
[38] See footnote 1.
[39] See footnote 1.
[End of section]
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