Background

		FEMA’s Disaster Assistance Authority and Declaration Process

The Robert T. Stafford Disaster Relief and Emergency Assistance Act of  1988 (Stafford Act) generally defines the federal government’s role during  the response and recovery after a major disaster. It establishes the  programs and processes through which the federal government provides  disaster assistance to state and local governments, tribes, certain  nonprofit organizations, and individuals. FEMA has steady-state and  emergency organizational structures. Under a steady-state when FEMA is  not in active response to a disaster, FEMA employees conduct activities  that “strengthen the Homeland Security Enterprise” and perform  functions that align with the Quadrennial Homeland Security Review  (QHSR) goals, which include strengthening capacity to withstand  hazards, and improving preparedness in all levels and segments of  society. However, when a disaster declaration is requested by a  Governor and approved by the President, FEMA executes its emergency  organizational structure as discussed below.
The Stafford Act establishes the process for states to request a  presidential major disaster declaration. Once a declaration has been  declared by the President, FEMA may provide disaster assistance  pursuant to the authorities in the Stafford Act. In order to request that the  President issue a major disaster declaration, a Governor submits a  declaration request certifying that the damage requires resources beyond  the state’s capability. The request must also include an estimate of the  amount and severity of damage and losses and preliminary estimates of  the types and amount of disaster assistance needed, among other  things. Once a disaster is declared, FEMA provides assistance primarily  through one or more of the following three assistance programs:  Individual Assistance, Public Assistance, and Hazard Mitigation. Not all  programs are activated for every disaster. The determination to activate a  program is based on the needs identified during the assessment  conducted as part of the declaration request. The Disaster Relief Fund is  the major source of federal disaster recovery assistance when a disaster  is declared. The Disaster Relief Fund is appropriated no-year funding  which allows FEMA to direct, coordinate, manage and fund response and  recovery efforts associated with domestic major disasters and  emergencies.

		FEMA’s Disaster Reserve Workforce and Organizational Structure

Under the Stafford Act, FEMA has the authority to augment its permanent  full-time staff with temporary personnel when needed, without regard to  the appointment and compensation provisions governing Title 5  appointments of permanent full-time staff. Permanent full-time  employees manage FEMA’s day-to-day activities, and a portion of these  employees are expected to deploy when a disaster is declared. The DAE  is one type of temporary, on-call employee. See appendix II for a detailed  description of categories of disaster workforce employees. DAEs  comprise the largest portion of the disaster workforce employed under  FEMA’s emergency organizational structure. As of February 2012, there  were 9,981 DAEs. DAEs are activated to perform disaster activities  directly related to specific disasters, emergencies, projects, or activities of  a non-continuous nature.paid when they are deployed (including per-diem), and do not receive any  Federal benefits with the exception of sick leave, holiday pay, and  administrative leave. They are assigned to one of 23 functional disaster  cadres. For example, the Individual Assistance cadre provides referrals  and guides individuals through the FEMA assistance process, while the  Hazard Mitigation cadre assists in educating the public and local  governments on methods to reduce the risk of loss of property and life  from a future disaster. See appendix III for a description of each cadre  and their primary duties.
DAEs serve two-year appointments, are only  FEMA’s organizational structure is decentralized and comprised of  headquarters and ten regional offices. FEMA’s Administrator, in  accordance with the Post-Katrina Emergency Management Reform Act of  2006 (Post-Katrina Act), appoints a Regional Administrator to head each  regional office.tribal governments, and other nongovernmental organizations—provide  emergency management within their respective geographical area. See  appendix IV, FEMA’s organizational chart, and figure 1 for a map of  FEMA’s regions.

	Opportunities Exist to Strengthen Policies and Procedures That Govern the DAE Program

FEMA has taken steps to enhance its management of the program, but  has not developed or updated policies and procedures that align with the  day-to-day management of the DAE program. FEMA has not provided  guidance for how regional cadre managers should undertake their duties  in the management of DAEs. Furthermore, FEMA could better monitor  both its regions’ implementation of DAE policies and DAEs’  implementation of FEMA’s disaster policies and procedures in order to  reduce the risk of inconsistent application. In addition, FEMA does not  have policies and procedures for how it communicates with DAEs when  they are not deployed.

		FEMA Has Not Yet Provided Guidance to Cadre Managers Related to DAE Management

FEMA has not yet developed guidance for cadre managers that outlines  how they should manage DAEs in their cadre such as guidance for  understanding and handling reserve pay and benefits, the deployment  process, training procedures, and evaluation techniques. Specifically, 14  of 16 regional cadre managers we interviewed said that they have not  seen or are not aware of documented guidance for their duties as cadre  manager such as hiring, training, and developing DAEs from  headquarters, and 10 of 16 stated that having written guidance would be  beneficial to their job. For example, one regional cadre manager said  that there are inconsistencies across regions with how cadre managers  hire, train, and utilize their DAEs. Another cadre manager added that  inconsistent hiring processes affect morale among DAEs. Instructions on  how to manage are handed down from experienced colleagues, but are  not documented for consistent use, according to another cadre manager.  FEMA stated in 1999 that it planned to establish guidelines and  requirements for cadre management functions and intended this guidance  to be applied consistently at headquarters and in the regions, but this  effort was not completed.manager’s handbook; however, the handbook was not finalized or  officially adopted across FEMA. The director of IWMO stated that he did  not know why the cadre manager’s handbook had not been completed  since 2008. In February 2012, during the course of our review, FEMA   In 2008, FEMA officials drafted a cadre  began its Disaster Workforce Transformation.effort includes creating a National Disaster Reservist Program intended to  overhaul the current DAE program and examine issues such as cadre  management. Further, IWMO officials stated that in fiscal year 2012, they  intend to develop a new cadre management handbook, revise FEMA  DAE policy, conduct regularly scheduled meetings and conference calls  with cadre managers, and conduct a national conference designed to  educate cadre managers on their roles. However, FEMA does not have  time frames or milestones for completing and disseminating cadre  manager guidance as part of its Disaster Workforce Transformation and  related activities.
According to FEMA, this  In the absence of cadre manager guidance, IWMO officials stated that  FEMA Instruction 8600.1, issued in 1991, is the best source for  information and guidance on the roles and responsibilities of cadre  managers. The document outlines DAE policy for recruitment and hiring,  reappointment, appraisals, and benefit eligibility. However, many of its  sections are obsolete or inoperative. For example, FEMA Instruction  8600.1 states that the office directors are responsible for the recruitment,  selection, training, use, and management of their DAE cadres. According  to FEMA, the regional cadre managers currently have these  responsibilities; however the 8600.1 policy is not updated to reflect this  change in responsibility. In addition, 9 of 16 regional cadre managers we  interviewed stated that FEMA Instruction 8600.1 was either outdated, in  need of revision, or not applied consistently across the organization. One regional cadre manager said that he would like anything from  headquarters with respect to guidance, but all that he has seen is FEMA  Instruction 8600.1, which is outdated. This manager added that it was  unclear whether any steps have been taken to ensure that FEMA  Instruction 8600.1 is applied consistently across regions. Another regional  manager said when they have to give new hires a copy of FEMA  Instruction 8600.1, they amend the document to reflect recent policy  changes.
Of the remaining cadre managers we interviewed, 2 said that they were not sure  whether FEMA Instruction 8600.1 was applied consistently across regions, and 5 did not  mention the issue.
A 2010 DHS OIG report recommended that FEMA review and update key  DAE program benefit policies, procedures, and guidance to eliminate  conflicts and inconsistencies between interim policies and permanent  overall guidance. In response to the IG’s report, FEMA officials stated  that FEMA Instruction 8600.1 was under revision. In March 2012 during  the course of our review, FEMA officials stated that the revision of FEMA  Instruction 8600.1 has been placed on hold pending the results of  FEMA’s fiscal year 2012 workforce transformation initiative to ensure all  issues that result from the transformation effort are identified. According  to standard practices for program management, an organization should  develop a program schedule that establishes the timeline for program  milestones and deliverables.previous efforts to create guidance for cadre managers, establishing time  frames and milestones could help FEMA ensure accountability for  completing and disseminating the cadre manager handbook and a  revised FEMA Instruction 8600.1.

		FEMA Could Better Monitor Implementation of Policies and Procedures

FEMA’s decentralized structure allows for flexibility in responding to  disasters; however, FEMA does not monitor how the regions implement  DAE policies, and how DAEs implement disaster policies and procedures.  Without such a mechanism, it will be difficult for FEMA to provide  assurance that both its regions and DAEs implement DAE policies and  disaster policies and procedures consistently. For example, DAEs in  focus groups we conducted and regional cadre managers we interviewed  expressed concerns about the inconsistency across regions in  interpreting FEMA policy. Specifically, they raised concerns about  inconsistencies across regions or cadres in how supervisors interpret  both DAE administrative policies and/or cadre-specific disaster policies.  For example, one focus group participant said that although there are  standard policies and procedures, each disaster is different, with different  supervisors that interpret these policies differently. Another focus group  participant reiterated this point, stating that the regions and cadres direct  their DAEs on how to approach disaster tasks differently, which lead to  inefficiencies in providing disaster assistance. Participants in the public  assistance cadre, for example, raised concerns about the variability that  exists in how supervisors and managers interpret public assistance policy  on documenting damage assessments, leading to differences in how well  the worksheets are prepared. One participant stated that there are  inconsistencies across regions when preparing the project worksheets  used to document disaster damage and provide cost estimates and plans  for repair. Specifically, this focus group participant stated that in certain  regions DAEs are instructed to focus on the number of worksheets  passed through the system. Although it is not referred to as a quota, the  participant stated that if a DAE does not achieve this number, he or she  will be sent home before completing his deployment. Conversely, in other  regions, supervisors and other managers do not apply a goal for the  number of worksheets to be completed and are concerned with quality  rather than quantity. These variations can lead to inconsistencies in how  the worksheets are completed. Another focus group participant stated  that the inefficiencies and inconsistencies that run across the board were  problematic adding that when determining eligibility for public assistance,  sometimes things are made eligible in one state that are not eligible in  another state. Moreover, a 2007 Booz Allen Hamilton preliminary report  entitled Restructuring and Enhancement of the Intermittent Disaster  Workforce System also identified inconsistencies in the application of  policies and standard operating procedures across regions and cadres.
In March 2012 during the course of our review, FEMA officials stated that  the agency intends to establish a centralized management structure  responsible for the development of FEMA disaster assistance policies  and procedures. FEMA policy states that headquarters is responsible for  developing the agency’s policies and procedures for disaster assistance  and the regional offices are responsible for the implementation of these  policies and procedures. We recognize that FEMA’s decentralized  structure allows for flexibility in handling disasters as each region can  encounter different types of disasters and the regional structure can  facilitate disaster assistance. In a February 2012 FEMA town hall  meeting, FEMA’s Administrator acknowledged that there are  inconsistencies across the FEMA regions, and noted that due to  differences in how regions operate, it is problematic to deploy someone  based in one region to another during a disaster.cadre manager we interviewed cited inconsistency in policy application  saying, “there is an ongoing problem of the right hand not knowing what  the left hand is doing with respect to when policies are implemented or  are in conflict with one another”. Without routinely monitoring how  disaster policies and procedures are being implemented across regions  by DAEs and how the regions implement DAE policies, FEMA lacks  reasonable assurance that it is administering its disaster assistance  consistently across regions in accordance with its mission.
Standards for Internal Controls in the Federal Government call for an  organization’s controls to be designed to assure that ongoing monitoring  occurs in the course of normal operations and that it includes regular  management and supervisory activities, comparisons and   Moreover, according to FEMA’s Capstone Doctrine,  reconciliations. which describes FEMA’s mission, purpose, and defines the agency’s  principles, FEMA advocates the practice of consistent decision making by  those with authority to act.monitoring of the regional implementation of DAE policies and  procedures, as well as how DAEs implement disaster policies, could help  provide FEMA with reasonable assurance that disaster assistance is  being implemented by DAEs in accordance with policy and consistently  across regions.

		Opportunities Exist to Communicate Cadre- Specific Information More Consistently with DAEs When Not Deployed

FEMA does not have policies and procedures for how it will communicate  cadre-specific information to DAEs when not deployed. Most DAEs do not  have access to cadre-specific information when not deployed, although  FEMA has recently taken steps to increase communication. The majority  of the cadre-specific information for DAEs is housed on FEMA’s internal  website and is not accessible by DAEs when they are not deployed. This  is because when DAEs are not deployed, they do not have access to their  FEMA-issued equipment such as laptops, as well as their FEMA e-mail  accounts. As a result, DAEs are not able to access information directly,  including changes in policies and procedures that may occur while they  are not deployed, and may not immediately be prepared to provide  assistance to survivors during a disaster. Once DAEs are deployed to a  disaster, they are typically provided equipment, such as laptops, and  FEMA e-mail addresses, which are used to receive policy and procedural  updates. However, DAEs in the focus groups we conducted raised  concerns about their inability to access this type of information prior to  being deployed to a disaster. For example, one focus group participant  told us that it is difficult to keep up with changes as they happen when  they are not deployed because they receive very little information when  they are not deployed. Another focus group participant told us that they  cannot access policy changes because they do not have access to  information behind FEMA’s firewall. We also heard from one DAE that  because she was not provided program information related to her job, it  was difficult for her to feel comfortable representing FEMA to disaster  victims without access to information such as materials related to  applicant services.
Thirteen of 16 regional cadre managers we interviewed said that they  communicate policy and procedural updates to DAEs when they are not  deployed via personal e-mail accounts, however, not all cadre managers  believe that it is their responsibility to convey policy updates to their DAEs  when they are not deployed. For example, one cadre manager who is  responsible for 180 DAEs told us she believes that policy changes should  come from FEMA headquarters and should be posted on FEMA.gov.  Consequently, this cadre manager does not forward policy changes to  personal e-mail accounts.
According to another cadre manager, communicating policies and  procedures to DAEs when they are not deployed is difficult because  DAEs are completely disconnected from the mechanisms typically used  to share information with FEMA staff during non-deployment. Further, he  added that this proved to be a problem during disasters in 2010 where  DAEs that had not been deployed for a while were unfamiliar with FEMA’s  recent policy updates. The manager said this situation was problematic  because management did not always have the time to walk these DAEs  through policy changes. Ultimately, this lack of access to information  among DAEs had an impact on DAE readiness because it extended their  learning curve and potentially created delays in providing service in some  cases.
According to an official from FEMA’s Office of the Chief Information  Officer, cadre managers have developed their own strategy for  communicating with DAEs when they are not deployed. In addition,  officials from IWMO told us that cadre managers are best suited to  determine the precise information and content that will meet the needs of  their respective cadre. Therefore, cadre managers are encouraged by  IWMO to develop informative resource pages for their DAEs. For  example, we found that the Hazard Mitigation cadre has developed a  platform to communicate and share a vast array of resources with DAEs  without access to FEMA’s internal website. Specifically, Hazard  Mitigation’s disaster workforce resources are available on both FEMA’s  internal website as well as the Hazard Mitigation Disaster Workforce  portal on the Homeland Security Information Network (HSIN), which can  be accessed via any Internet connection with a login and password. The  portal provides resources for each of the different functional areas of  Hazard Mitigation, including web links, contact information, tasks books,  job aids, policies, publications, and training materials for the Hazard  Mitigation workforce. However, as of March 2012, these tools were limited  to the Hazard Mitigation Cadre. According to IWMO, other cadres,  including Alternate Dispute Resolution, Community Relations, Individual  Assistance, and Environmental & Historic Preservation have internal  websites that contain programmatic policies and procedures. However,  these sites are not readily available to DAEs who do not have access to  FEMA’s internal website. In a budget-constrained environment,  leveraging existing mechanisms can help agencies achieve efficiencies.  While our prior work has identified issues with the HSIN platform, it could  be used to provide DAEs greater access to FEMA resources. According  to FEMA’s Office of the Chief Information Officer, HSIN would be an  appropriate tool for DAEs to use to stay connected to FEMA because it  would allow them access to pertinent information from anywhere and  would not represent an additional cost to FEMA.
Inconsistent access to information among non-deployed DAEs, in addition  to inconsistent communication strategies with DAEs among regional  cadre managers, may hinder FEMA’s mission of providing assistance to  disaster survivors, by extending the amount of time it takes DAEs to  familiarize themselves with the most current cadre-specific policies and  procedures when they are deployed. However, FEMA has taken some  steps to improve DAEs’ access to information when they are not  deployed. For example, part of FEMA’s Disaster Workforce  Transformation includes plans intended to increase communication to  DAEs. FEMA stated that it plans to have consistent, two-way  communication with DAEs even when they are not deployed. According  to FEMA, this communication will include sending weekly e-mails about  agency activities to each of the personal e-mail addresses it has on file  for its entire workforce and developing a dedicated employee-focused  website accessible to all of its employees. However, the employee- focused website contains a minimal amount of cadre-specific information.  Since FEMA will rely on its cadres to provide their own content, the extent  to which FEMA’s new centralized employee-focused website will include  cadre-specific policies and procedures that DAEs need to perform their  duties while deployed, such as those provided by the Hazard Mitigation  cadre via its HSIN portal, is not clear. For example, as of March 2012,  FEMA’s publicly available website for its employees included an  Employee Information and Resource Center that houses general  information such as travel policies, newsletters, and information related to  the FEMA’s Disaster Workforce Transformation and FQS. Unlike the  Hazard Mitigation portal on HSIN, FEMA’s employee website did not  include cadre-specific information such as Concept of Operations  documents that describe how specific cadre efforts are conducted in the  pre- and post-disaster environment, or field office guides and Go Kits  which contain cadre-specific guidance, which are resources that DAEs  can access to better prepare themselves for future disasters while they  are not deployed.
As part of FEMA’s Disaster Workforce Transformation efforts, it  developed an employee-focused website; however, according to FEMA,  the new employee website was not intended to be a long-term solution,  nor was it intended to replace FEMA’s internal website used to  communicate with its workforce. FEMA has not developed a plan with  milestones for how it will communicate not only general information but  cadre-specific information to DAEs when they are not deployed.  According to FEMA, the agency is examining other solutions that would  allow the agency’s entire workforce to have access to all information, but  a specific time frame has not been determined. According to standard  practices for program management, an organization should develop a  program schedule that establishes the timeline for program milestones  and deliverables. As FEMA implements its Disaster Workforce  Transformation, developing a plan with time frames and milestones for  how it will better communicate cadre-specific policies, procedures, and  other information to DAEs when they are not deployed would provide  FEMA with a roadmap to help ensure that it is providing DAEs the tools  they need to be prepared for disaster deployments.

	FEMA Could Strengthen Human Capital Management Controls

FEMA has not established standardized hiring or salary criteria to help  ensure that basic qualifications are met by prospective DAEs, and that  regional managers consistently determine initial DAE salaries and award  promotions. Moreover, FEMA’s performance appraisal system for DAEs  does not adhere to internal control standards, which would help ensure  that managers have information to better inform performance  management decisions.

		FEMA Has Not Established Standardized Hiring and Salary Criteria for DAEs

FEMA has not established standardized hiring criteria for prospective  DAEs, and FEMA headquarters provides limited guidance to regions on  which to base DAE salary determinations.
According to FEMA Instruction 8600.1 of 1991, the primary document  outlining DAE program policies, regional cadre managers are responsible  for the recruitment, selection, use, and management of their respective  DAE cadres. Our review of policies and interviews with regional cadre  managers as well as officials in FEMA headquarters indicate that DAEs  are hired by regional cadre managers without being assessed against  established criteria to determine their qualification for the position.  Regional cadre managers make the initial hiring selection, and then send  a hiring package with the individual’s qualifications and a proposed salary  to the Office of the Chief Component Human Capital Officer (OCCHCO).  OCCHCO officials stated that they then review the individual’s package to  verify that the selected individual is qualified for the position and that the  proposed salary is appropriate based on experience and skills described  in the individual’s resume. However, criteria used by OCCHCO officials in  assessing the qualifications and pay of a DAE applicant are not  documented; rather, OCCHCO officials stated that these decisions are  based on general knowledge. An OCCHCO official who reviews the hiring  package containing the applicant’s paperwork said that she believes that  regional cadre managers do not always use the same criteria for  evaluating qualifications and selecting a DAE candidate as the OCCHCO  official uses in approving the proposal. In addition, a regional cadre  manager from Hazard Mitigation said that the national cadre manager at  headquarters provides guidance for hiring. In contrast, another regional  manager said that there is no written guidance available, and that  regional cadre managers are on their own in making hiring decisions.
According to OCCHCO, the agency’s hiring criteria for DAEs is contained  within FEMA Instruction 8600.1. This policy states that “consideration  should be given to the specific job functions, the qualifications required to  perform those jobs, and Equal Employment Opportunity requirements.”  However, the policy does not provide explicit information on the  qualifications for different cadres or positions, such as the relevant  experience, education, or skills. For example, there is no FEMA-wide  guidance on the preferred skills and experience of prospective DAEs for a  given position in the IA cadre or the PA cadre, which focus on different  aspects of assistance, and thus, require different expertise. OCCHCO  officials agreed that it would be useful to have a list of bulleted skills and  qualifications that are desired by each cadre for making hiring decisions.  An OCCHCO official who reviews hiring and salary recommendations  said there is no specific guidance provided to regions related to hiring  criteria, other than FEMA Instruction 8600.1, because they believe that  the regions have competent people hiring DAEs.
The 2007 preliminary report by Booz Allen Hamilton on FEMA’s disaster  workforce stated that the lack of standardization in recruitment standards,  interviewing processes, and hiring practices led to a wide disparity in the  qualifications of DAEs across the regions, which the report noted may  impair FEMA’s ability to effectively respond to a disaster. Moreover, one  regional cadre manager said that morale is lowered when unqualified  DAEs are hired, and another said that many DAEs complain that there is  significant variation across regions in terms of the skills required for  different positions. In addition, a DAE who participated in our focus group  stated that if FEMA had asked the right questions, he would not have  been hired, since he did not have the necessary technological skills to  use the laptop, GPS, and digital camera that FEMA provided to him.
Standards for Internal Controls in the Federal Government call for  agencies to identify appropriate knowledge and skills needed for various  jobs. According to FEMA, when FQS is implemented in 2012, position- specific training and position task requirements will be defined for each of  the 322 positions to provide more specificity; however, FEMA could not  provide details about how or if this will translate into better hiring criteria   By standardizing hiring criteria, FEMA would be  for prospective DAEs. better positioned to hire people with the requisite skills and have  reasonable assurance that hiring decisions are being made consistently  across regions.
In addition, FEMA headquarters provides limited guidance for regions to  use to make DAE salary determinations. According to a FEMA official, in  addition to FEMA Instruction 8600.1, the “Grant C. Peterson Memo”  (Peterson Memo) of 1992 put forth guidance for pay levels and  promotions. This guidance outlines five pay grades (A through E), as  well as the three levels within each pay grade and relates these pay  grades to their approximate GS or GM federal grade level.
FEMA could not provide details about how FQS will translate into better hiring criteria for  prospective DAEs in addition to identifying the requisite training and skills needed by  newly hired DAEs to become qualified under FQS.
Peterson Memo states that all DAEs will be given a tentative pay grade at  the time of the initial appointment, and within 90 days a decision will be  made as to whether or not that tentative grade is appropriate or should be  changed to a different grade. The Peterson Memo lists position titles that  would be assigned to Grades A through E, but it does not clarify how a  DAE is to be assigned to one of the three levels within each grade. In  addition, the memo does not establish criteria on which to base initial  salary decisions or reconsiderations within the 90-day window.
An OCCHCO official stated that it is possible that cadre managers have  developed their own criteria for placing DAE hires in certain pay  categories. For example, the OCCHCO official noted that some cadre  managers bring everyone in on a C-1 level (approximately $21/hour) until  they are able to “learn about the organization,” a process which is not  quantified or measured. We noted variation among regional cadre  managers with respect to pay determinations, with some managers  proposing pay according to the candidate’s experience, and others basing  pay determinations solely on the job title. For example, six regional cadre  managers said that pay determinations depend on the candidate’s  experience, education, and background and one added that individuals  with the same job title could be paid differently depending on their  experience. In contrast, three different regional cadre managers said that  pay is based on the job title or position the DAE is hired to fill; for  example, one said that a data entry DAE would start in the A or B pay  grade, while construction managers would be assigned to the C pay  grade. Variation in salaries across regions and cadres can lower morale  among DAEs who are deployed in multiple regions and notice DAEs that  are paid more despite having less responsibility, according to two regional  cadre managers. A senior FEMA official in a recent “town hall meeting”  acknowledged that there have been issues with the pay and promotion  system for DAEs for many years, and that leadership will be looking at the  issue. In addition, the Assistant Administrator for Response said that  there is currently no consistency with pay determinations or raises, and  that changes to the pay system will be a part of FEMA’s Disaster  Workforce Transformation. Additionally, 8 of 16 regional cadre managers  we interviewed stated that they do not receive guidance or would like to  receive more guidance related to salary determinations, including the  criteria used by headquarters. FEMA headquarters could clarify what  kind of professional experience gained prior to joining FEMA is  considered relevant for different positions and cadres or to what extent  disaster-specific responsibilities may factor into salary determinations.  Ten of 16 regional cadre managers said that headquarters has previously  denied pay determinations proposed by the region, and two of these  regional cadre managers responded by asking the applicant to revise his  or her resume and re-send it to headquarters. One of these regional  cadre managers noted that he did not know what headquarters was  looking for when making decisions regarding whether to place a  candidate in pay Grade B or C.
During recent town hall meetings between agency leadership and  employees, a FEMA official acknowledged that pay grade distribution and  pay raise inconsistencies are an issue in the DAE program. The Assistant  Administrator for Response noted that more than 90 percent of DAEs are  in the C category or above, and as a result there are DAEs in higher pay  grades performing work that should be done by lower-paid DAEs.  According to FEMA officials, they will be looking into these issues as part  of FEMA’s Disaster Workforce Transformation. In addition, FEMA officials  noted that FQS will institutionalize pay determinations for DAEs based on  job title, but as of March 2012, they could not provide details regarding  this effort. Standards for Internal Control in the Federal Government state  that good human capital policies and practices should include  establishing appropriate practices for compensating and promoting  personnel. We have reported that agencies may abide by these  standards by basing compensation on achievements and performance.  By establishing standardized criteria for making DAE salary and  promotion determinations, FEMA could increase transparency around  salary determinations and reduce unnecessary variation across regions.

		Performance Appraisals for DAEs Do Not Adhere to Internal Control Standards

FEMA’s performance appraisal system for DAEs is not consistent with  internal control standards, which would help ensure that managers have  information to better inform performance management decisions.  Standards for Internal Control in the Federal Government state that  agencies should establish appropriate practices for evaluating,  counseling, and disciplining personnel. In addition, these standards  state that effective management of an organization’s workforce include  identifying appropriate knowledge and skills needed for various jobs and  providing candid and constructive counseling, and performance  appraisals. We have previously reported that agencies could adhere to  these internal control standards through a number of actions, such as  ensuring that: promotions and compensation of employees are based on periodic employees are provided with appropriate feedback and given  suggestions for improvement; or that employment is terminated when performance is consistently below  standards.
Performance appraisal systems are intended to provide agencies with  information related to the effectiveness of employees and serve as a  mechanism to identify and improve performance deficiencies. FEMA’s  performance management system for DAEs is based on a performance  appraisal form that is not consistent with internal control standards, which  state that counseling should be candid and constructive. According to  FEMA Instruction 8600.1, supervisors are required to complete a  performance appraisal form for DAEs at the end of each DAE’s  deployment. As shown in figure 2, all DAE reservists are rated on seven  elements, and supervisors are rated on an additional seven elements.addition, there is a narrative portion of the performance appraisal form  where supervisors are required to include written comments.
For each element, a DAE may be given an “S” for Satisfactory, “U” for  Unsatisfactory, or “N/A” if a supervisor had no opportunity to observe the  DAE’s performance; these ratings are essentially a pass/fail system.  However, it is unclear what constitutes successful completion of each  element, and FEMA headquarters has not provided any written guidance  to regions for assigning ratings. For example, FEMA lacks criteria that  can be used to make the determination that a DAE should receive an S or  a U for a given element. FEMA Instruction 8600.1 addresses what cadre  managers should do with the appraisal form, but not specifically how to  assign a rating and what content managers should include in the narrative  portion. Eleven of 16 regional cadre managers we interviewed stated that   These regional cadre managers  DAEs are not given honest appraisals.stated that ratings are not always an accurate reflection of performance  because currently there is a conflict of interest because supervisors (who  are also DAEs) must evaluate subordinate DAEs who could be their  supervisors in the next deployment. According to the Director of IWMO,  when FQS is implemented in fiscal year 2012, DAEs will continue to  supervise other DAEs in the field. This official said that the qualification  requirements under FQS will help ensure that the supervising DAEs have  the professionalism to manage other DAEs. However, given the fact that  DAEs may continue to serve at levels below the one for which they are  qualified, the conflict of interest could continue. While we recognize that  ensuring supervisors provide candid ratings can be challenging for  agencies, strengthening the controls in place for developing performance  ratings could help FEMA provide both managers and DAEs more  meaningful performance information.
In addition, the performance appraisal system could be more transparent  by providing managers with additional information to use when making  performance management decisions. For example, because the appraisal  form usually provides little information to managers regarding a DAE’s  performance during a disaster, one regional cadre manager noted that  branch directors contact the regions and let them know of any problems  with their cadre members. The manager added that instead of or in  addition to reviewing the performance appraisal forms, supervisors and  managers must make phone calls and send e-mails to give a picture of a  DAE’s performance and areas for improvement. In addition, it is not clear  how performance appraisals are utilized in decisions related to  reappointment, performance deficiencies, pay, and promotions for DAEs.  FEMA headquarters has not provided guidance to regions to clarify these  issues, according to 13 of 16 regional cadre managers and OCCHCO.  According to an IWMO official, the office previously known as Disaster  Reserve Workforce Division had been actively involved in redesigning the  performance appraisal process, including improving the appraisal form  and maintenance of performance records. However, he said that when  the office was revamped and realigned into IWMO, the effort languished.  IWMO and OCCHCO officials noted in March 2012 that performance  management is a critical component of the supervision of DAEs and  stated that it must be improved in fiscal year 2012 during FEMA’s  Disaster Workforce Transformation effort. However, FEMA does not  currently have specific plans to revamp the performance appraisal  system.
We have previously reported that one of the key practices for effective  performance management is making meaningful distinctions in  performance, including providing management with the objective and fact- based information it needs to recognize top performers and providing the    necessary information and documentation to deal with poor performers. Similarly, we have previously reported that performance appraisals  should provide meaningful distinctions in performance for staff, which is  difficult to accomplish with a pass/fail system. We also reported that a  limited number of performance categories may not provide managers with  the information they need to reward top performers and address  performance issues, as well as deprive staff of the feedback they need to  improve. In addition, 13 of 16 regional cadre managers stated that the  appraisal process could be improved in various ways, such as  implementing a rating scale instead of a pass/fail rating. Specifically,  using multiple rating levels provides a useful framework for making  distinctions in performance by allowing an agency to differentiate, at a  minimum, between poor, acceptable, and outstanding performance. We  have reported that two-level rating systems by definition will generally not  provide meaningful distinctions in performance ratings, with possible  exceptions for employees in entry-level or developmental bands.  Similarly, a 2007 preliminary report by Booz Allen Hamilton on the DAE  program found that there was a lack of standardization and fairness in the  performance review system, specifically that the system was not  managed evenly and did not distinguish between levels of performance.  The report noted that an inadequate performance review system affects  the development and assignment of DAEs, as well as their contribution to  FEMA’s overall response to disasters. Taking steps to establish a more  rigorous performance management system that addresses the  weaknesses we identified could help provide FEMA with more information  regarding how effectively DAEs are performing and a mechanism to  identify and improve any performance deficiencies. By providing clear  criteria and guidance for assigning ratings, as well as how the ratings are  to be used, FEMA could help to ensure that DAEs’ performance  appraisals better reflect actual performance and provide managers with  information to better inform performance management decisions.

	FEMA’s DAE Training Is Not Consistent with Key Attributes of Effective Training and Development Programs

FEMA’s DAE training is not consistent with key attributes of effective  training and development programs that could help to ensure that its  training and development investments are targeted strategically. FEMA  does not have a plan to ensure that all DAEs receive required training  under FQS, which would ensure accountability for qualifying DAEs. In  addition, FEMA does not track how much it spends on DAE training,  which hinders FEMA’s ability to plan for future training.

		FEMA Does Not Have a Plan to Ensure DAEs Receive Required Training

FEMA does not have a plan with time frames and milestones to ensure  DAEs receive training, including required training for its new credentialing  program, FQS. FEMA provides the majority of its training to DAEs in the  field during disasters. Under FQS, DAEs must complete required training  and demonstrate successful performance in specific areas in order to be  qualified in their job title. Therefore, DAEs’ career track will be aligned to  their deployments, and subsequently tied to their opportunities to  participate in field training. Regional cadre managers and DAEs we spoke  with had concerns about the amount of training DAEs received during  disasters as well as FEMA’s reliance upon on-the-job training for new  DAEs due to limited training opportunities. Thirteen of 16 regional cadre  managers said that they would like more opportunities for DAEs to  receive training. For example, one Human Resource cadre manager  said that required training courses were not available the past year, and  that some courses, such as those developed for human resource  managers, had not been offered for 3 or 4 years. In addition, one DAE  said that the amount of training they received was insufficient and added  that it was a disservice to the applicants for FEMA assistance because  DAEs may not know how to properly assist the public. Another DAE, who  also holds a management position, told us that half of the DAEs deployed  in Community Relations in his current disaster did not have any training  other than on-the-job training. Furthermore, IWMO officials said some  regions provide general pre-deployment orientation materials, such as  instructions on completing certain administrative tasks; otherwise, it is up  to the cadre manager to provide DAEs information pertinent to their  assignment prior to their deployment. Therefore, the extent to which a  DAE receives orientation depends on the cadre, the region, and the  timing of deployments.
Under FQS, DAEs will be assigned job titles, and each DAE will either be  designated as a trainee or qualified for that job title. For a DAE to become  qualified, they must complete required training and meet the minimum  number of deployments and various deployment experiences. According  to FEMA, approximately 20 percent of the current DAEs (2,005 of 9,981)  are considered trainees and will need training and future deployments to  become qualified. However, according to FEMA, as of March 2012, 136  courses were not available because they were being revised or not yet  developed. In addition, FEMA stated that of the 136 courses, 83 are in  various stages of pilot testing and they have developed a schedule to  revise or develop courses through the end of fiscal year 2012. Officials  said that if a course will not be developed in the foreseeable future,  exemptions can be made for the DAE to be fully qualified if they have  completed the remaining requirements.
According to key attributes for federal training programs, agencies should  have agency planning documents such as training plans, and training and  development design and evaluation documents, which focus on  identifying targeted performance improvements and report on progress in  achieving results. As previously mentioned, successful organizations  should also establish timelines for program milestones and deliverables.  According to FEMA officials, the agency has begun an initiative intended  to identify the number of personnel, by position, needed to respond to and  manage various incidents. It is also intended to determine the number of  training courses they will need based on the number of open position task  books. In fiscal year 2012 FEMA plans to implement this initiative as well  as FQS in order to develop a plan to train DAEs, according to the agency.  However, FEMA officials also said that qualifying all DAEs under FQS will  depend on each DAE’s commitment to making themselves available for  deployments and the level of disaster activity. DAEs are required to  update their availability for deployments at least every 30 days, and must  be available for deployments for at least 60 days a year. FEMA does not  have a plan or time frames in place to ensure that all DAEs are qualified  under FQS and receive required training; instead, FEMA is depending on  DAEs to commit to be deployed. A plan with time frames and milestones  for how and when it will train all of its DAEs will provide FEMA with a  roadmap and ensure accountability for qualifying DAEs under FQS.

		Systematically Tracking Training Cost Could Allow FEMA to Better Plan for Future Training Expenses

FEMA does not track how much of the Disaster Relief Fund is spent on  training for DAEs while deployed to JFOs. As a result, FEMA does not  have a comprehensive picture of costs and expenses, and other financial  information related to training and development activities. All expenses  incurred at a JFO, including training costs, are funded by the Disaster  Relief Fund. Comptrollers at the JFO are responsible for approving and  monitoring all the funds used at a JFO; however, they are not required to  track the training costs. The Disaster Field Training Operations cadre is  responsible for developing a training plan based on the training needs of  the DAEs deployed to a particular JFO. The training plan then must be  approved by the Federal Coordinating Officer. FEMA’s Deputy Director  for Field Operations said the plan does not include the costs associated  with the recommended courses unless the training is being provided by a  contractor. Costs associated with training—such as travel expenses, per  diem for the instructors, and copy materials—are all included in the  administrative costs of the JFO. FEMA’s Deputy Director for Field  Operations further stated that there is no accounting code specific to  training costs, therefore, the agency does not currently have the needed  information to identify those costs specific to completed courses. The  official added that FEMA maintains a few codes that have some  relationship to training, such as a code for training-related office supplies  and printing costs. The official noted that it may be possible to  accumulate all of the training-related codes that are currently in existence  and come up with an estimate of the total cost associated with training;  however, this figure would not provide a complete picture of training  costs.
FEMA’s Disaster Readiness and Support account is part of the Disaster  Relief Fund. It funds generalized, non-disaster specific initiatives such as  training that provides disaster readiness and preparedness support  across FEMA. In fiscal year 2011, the Disaster Readiness and Support  account totaled $304.7 million, of which $9 million was dedicated to  disaster-related training for all FEMA employees, including DAEs. Of the  $9 million, $3 million of this is dedicated to pay for the salaries and  benefits of DAEs while they are deployed solely for training. According to  FEMA, the amount of the Disaster Readiness and Support account is  determined by working with FEMA offices annually to review their  requirements. A spend plan is created and then reviewed and approved  by FEMA’s Deputy Administrator, DHS and the Office of Management  and Budget before transmittal to Congress.
Prior to fiscal year 2012, the Emergency Management Institute was  responsible for managing the $9 million in disaster specific training funds.  This responsibility is now with IWMO; however, according to IWMO  officials, they are still coordinating their efforts with the Emergency  Management Institute. According to the Emergency Management  Institute, it cannot separate how much of the Disaster Readiness and  Support account is spent on DAE training, except for the $3 million  allocated for salaries and benefits. According to IWMO officials, in fiscal  year 2013 they will begin funding the majority of training courses in JFOs  using the Disaster Readiness and Support account rather than the more  general Disaster Relief Fund. As of March 2012, the fiscal year 2012  spend plan and projected future costs had not been finalized. However,  IWMO officials said that the proposed fiscal year 2012 budget for FQS is  $7.8 million, which was based on the training budget of prior years’  training as well as future needs. According to key practices for training  management, agencies should have accounting, financial, and  performance reporting systems that produce credible, reliable and  consistent data on agency activities, including training and development   Since FEMA does not know how much money it historically  programs.has spent on training at the JFOs using the Disaster Relief Fund, it does  not have a complete picture of the total cost to train DAEs both at the  Emergency Management Institute and at the JFOs each year. Further,  FEMA does not have reasonable assurances that the proposed fiscal  year 2013 FQS budget is at an appropriate level to cover the total training  costs. Without a systematic process to track training costs, FEMA does  not have a complete picture of training, including its total costs.  Developing a systematic process to track such training costs would  provide FEMA with additional information to inform decisions about  allocating future funding for training and assist it in doing so effectively.

	FEMA Announced Impending Transformation of DAE Program, but It Is Too Soon to Evaluate the Effectiveness of the Agency’s Planned Actions

On April 17, 2012 FEMA announced plans to transform the DAE program.  Among the changes, FEMA will change the name to the FEMA Reservist  Program. According to FEMA, as of June 1, 2012, the agency will begin  offering DAEs the opportunity to seek new appointments in the Reservist  Program by applying for specific incident management positions within  FQS. The Reservists selected at the end of the application process will be  assigned to nationally managed cadres, which will replace all regionally- based cadres by the end of 2012. FEMA announced that as of July 1,  2012, DAEs who transition to the Reservist Program before the end of  2012 will have their pay “grandfathered” into the new program and  therefore be exempt from the new rules regarding having pay determined  based on their FQS position. In addition, FEMA stated it will establish a  goal and policy to deploy all Reservists at least once per year with the  length of the deployment depending on operational needs, which is  intended to ensure that all Reservists have the current incident response  experience and demonstrated performance required by FQS.  Furthermore, FEMA stated that it will begin providing Reservists required  FQS training by utilizing a portion of annual deployment days and  allowing Reservists to complete some mandatory training from home.  Moreover, FEMA announced that it would be issuing Reservists mobile  communication and computing equipment upon their first deployment, to  ensure that they are mission ready immediately upon checking into a  disaster and that they have continuous access to the FEMA network and  FEMA e-mail, if they choose, regardless of deployment status. These  efforts, if implemented effectively should address a number of the  challenges we identified with FEMA’s management of the DAE program.  However, FEMA has not identified specifics to these broad plans that  allowed us to evaluate the effectiveness of its planned actions. Therefore,  it is too soon to determine whether the planned actions will be  implemented as stated and whether they will fully address the problems  we identified.

	Conclusions

FEMA relies heavily upon DAEs to respond to disasters. The agency has  taken steps to improve the program, such as establishment of a  credentialing program, FQS, and a planned transformation of the DAE  program; however, it is too soon to assess the extent to which these  efforts will address the challenges we identified with FEMA’s  management of the DAE program, the workforce, and training. For  example, while FEMA intends to provide guidance to cadre managers,  including a revised FEMA Instruction 8600.1 by the end of 2012, FEMA  has experienced difficulty in the past in completing similar efforts, such as  the 2008 cadre management handbook that was never finalized. Thus,  establishing time frames for completing deliverables such as the revised  FEMA Instruction 8600.1 and a cadre manager handbook for DAE  management would help ensure accountability for completing initiatives.  Furthermore, FEMA’s decentralized structure allows for flexibility;  however, establishing a mechanism to ensure ongoing monitoring of  regional implementation of DAE policies and procedures and DAEs’  implementation of FEMA’s disaster policies and procedures can assist  management in ensuring that disaster assistance is conducted in  accordance with policy and consistently applied across regions. In  addition, establishing policies and procedures for how FEMA will  communicate with DAEs and developing a plan with time frames and  milestones for how it will better communicate policies and procedures and  cadre-specific information to DAEs when not deployed would help ensure  that it is providing DAEs with the tools they need to be prepared for  disaster deployments.
Further, FEMA’s human capital controls do not adhere to internal control  standards for hiring, compensation, and performance appraisals. By  standardizing criteria for hiring and salary determinations, FEMA would  have greater assurance that DAEs have the necessary skills and  qualifications, as well as ensure consistency across regions. In addition,  taking steps to establish a more rigorous performance management  system would provide FEMA with more information regarding how  effectively DAEs are performing and provide a mechanism to identify and  improve any performance deficiencies.
Moreover, FEMA’s management of DAE training is not consistent with  training key practices for planning and tracking training costs.  Establishing a plan with milestones for training DAEs would provide  FEMA with a roadmap to train its DAE workforce and ensure  accountability for qualifying DAEs under FQS. Finally, developing a  systematic process for capturing training costs would provide FEMA with  additional information to inform its decisions about allocating future  funding for training and assist it in doing so effectively.

	Recommendations for Executive Action

To help DHS improve the management of DAEs and build on some of the  actions taken to date, we recommend that the Secretary of Homeland  Security direct the Administrator of FEMA to take the following seven  actions:  1.  Establish timelines for development and dissemination of DAE cadre  management guidance and revisions to FEMA Instruction 8600.1;  2.  Establish a mechanism to monitor both its regions’ implementation of  DAE policies and procedures and DAEs’ implementation of FEMA’s  disaster policies and procedures to ensure consistency.  3.  Develop a plan with time frames and milestones for how it will better  communicate policies and procedures and cadre-specific information  to DAEs when they are not deployed;  4.  Establish standardized criteria for hiring DAEs that include defined  qualifications and skill sets to make hiring decisions and salary  determinations;  5.  Establish a more rigorous performance appraisal system that includes  criteria and guidance to serve as a basis for performance ratings, as  well as how ratings could be used, and a process to address  performance deficiencies;  6.  Establish a plan with milestones to ensure all DAEs have  opportunities to participate in training and are qualified; and  7.  Develop a systematic process to track training costs.

	Agency Comments and Our Evaluation

We provided a draft of this report to DHS for comment. We received  written comments from DHS on the draft report, which are summarized  below and reproduced in full in appendix VIII. DHS concurred with the  recommendations and indicated that FEMA has taken or is taking steps to  address them. The actions DHS reported are important first steps;  however, FEMA’s implementation plans do not fully address one of the  seven recommendations, as discussed below. Moreover, insufficient  detail is provided related to FEMA’s plans for three of the  recommendations; thus it is not clear to what extent these plans will fully  address the three recommendations.
In regards to the first recommendation, that FEMA establish time frames  for development and dissemination of DAE cadre management guidance  and revisions to FEMA Instruction 8600.1, DHS agreed and stated that  FEMA Instruction 8600.1, which is now called the FEMA Reservist  Program Directive, was revised and, as of May 11, 2012, is in FEMA’s  Office of the Chief Counsel for final review. Furthermore, DHS stated that  the estimated timeline for approval and publishing of this instruction is  June 1, 2012. In addition, DHS stated that the Cadre Manager’s  Handbook, the FEMA Reservist Program Manual, the Reservist Pay  Directive, and the Reservist Handbook are being developed with an  estimated timeline for development, approval, and dissemination  approximately 90 days after the signing of the FEMA Reservist Program  Directive. It will be important that the FEMA Reservist Program Directive  align with the planned Disaster Workforce Transformation. These actions,  if implemented effectively, would address the intent of the  recommendation.
In reviewing the draft of the second recommendation that FEMA establish  a mechanism to monitor disaster policies and procedures to ensure  consistency, FEMA officials requested clarification, stating that the  recommendation was too broad as it focused on FEMA’s disaster policies  rather than DAEs. We agreed and modified the recommendation to more  clearly state that FEMA should monitor how the regions implement DAE  policies and procedures and how DAEs implement disaster policies and  procedures. DHS agreed with our revised recommendation and  discussed several actions it has taken or has underway to address the  recommendation. Specifically, it stated that (1) in December 2011, the  FEMA Administrator directed the agency to identify, review, and centrally  post all agency doctrine, policies, and directives, (2) all documents were  posted to their respective locations on April 13, 2012, and (3) the  agency’s policies guiding DAEs are now available on the FEMA intranet.   Moreover, FEMA stated that it has also established and is working to  improve a number of mechanisms through which it validates compliance  with the agency policies and standards. FEMA also stated that  communication with reservists on disaster policies and procedures will be  initiated from FEMA headquarters to ensure consistency. FEMA has  taken actions to make policies and procedures readily available to  reservists; however, FEMA did not provide details about the mechanisms  it has established for its regions to monitor DAE policies and procedures  or DAEs’ implementation of FEMA’s disaster policies. Thus, it is not clear  to what extent these actions will fully address the recommendation.
In regards to the third recommendation, that FEMA develop a plan with  time frames and milestones for how it will better communicate policies  and procedures and cadre-specific information to DAEs when they are  not deployed, DHS agreed and stated that the FEMA Reservist Program  Directive requires Headquarters, Regional, and National Cadre  Management leadership to provide consistent two-way messaging to all  Reservists, deployed or not, through e-mail, websites, webinars, and  other outreach, and estimates that these efforts will be completed by  September 30, 2012. However, DHS did not provide details on the types  of information that it will be providing DAEs. Thus, it is not clear to what  extent FEMA’s planned actions will fully address the recommendation. To  fully meet the intent of the recommendation, FEMA needs to ensure that it  is communicating both cadre-specific and administrative information to  DAEs.
In regards to the fourth recommendation, that FEMA establish  standardized criteria for hiring DAEs that include defined qualifications  and skill sets to make hiring decisions and salary determinations, DHS  agreed and stated that the FEMA Qualification System (FQS) Position  Task Books define specific qualifications and skills for each required  position and will be the basis for establishing standardized criteria for  hiring Reservists, including pay. Currently, Position Task Books are used  to document and record tasks performed by the trainees, in order to  become qualified under FQS. It will be important for FEMA to define skills  and/or necessary experience applicants must have prior to being hired for  each position, and how if at all, any prior experience will impact salary  determinations. Without doing so, DHS will not fully address the intent of  the recommendation.
In regards to the fifth recommendation, that FEMA establish a more  rigorous performance appraisal system that includes criteria and  guidance to serve as a basis for performance ratings, as well as how  ratings could be used, and a process to address performance  deficiencies, DHS agreed. DHS stated that upon implementation of the  FEMA Reservist Program Directive and the publishing of various  supporting directives and handbooks, FEMA’s Incident Workforce  Management Office will coordinate with FEMA’s Office of the Chief  Component Human Capital Office to develop a more robust Reservist  performance appraisal system that will, among other things, establish  performance standards, identify successful task completion, and improve  performance deficiencies. These actions, if implemented effectively,  would address the intent of the recommendation.
In regards to the sixth recommendation, that FEMA establish a plan with  milestones to ensure all DAEs have opportunities to participate in training  and are qualified, DHS agreed and stated that as part of the changes in  the DAE program through the Disaster Reservist Program, FEMA will  ensure that all DAEs have opportunities to participate in training and are  qualified to serve in a primary disaster-specific job title on the basis of  FEMA’s Force Structure requirements. Furthermore, FEMA plans to  complete this by September 30, 2013. However, DHS did not provide  details on how it plans to ensure that DAEs will become qualified by  September 2013, including when it will complete the FEMA Force  Structure which had not been finalized as of April 2012. It will be  important for FEMA to develop intermediate milestones to provide a  roadmap for how it will qualify its workforce. Thus, it is not clear to what  extent FEMA’s plans will fully address the intent of the recommendation.
In regards to the seventh recommendation, that FEMA develop a  systematic process to track training costs, DHS agreed and stated that  FEMA has combined all funding for FQS supportive training into a single  account to ensure a process for tracking training costs, course offerings,  and force structure requirements. DHS also stated that it will include all of  this information in the Incident Qualification Certification System— intended to be the primary FQS tracking system—to track all FQS-related  training costs. In addition, DHS stated that it should be completed by  October 1, 2012. These actions, if implemented effectively, would  address the intent of the recommendation.
DHS also provided technical comments that we incorporated, where  appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees, the Secretary of the Department of Homeland  Security and the Administrator of the Federal Emergency Management  Agency. The report will also be available at no charge on the GAO  website at http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-8777 or jenkinswo@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. GAO staff who made major contributions to  this report are listed in appendix IX.

Appendix I: Objectives, Scope, and Methodology

The objectives of this report were to determine (1) to what extent does the  Federal Emergency Management Agency (FEMA) have policies and  procedures in place to govern the Disaster Assistance Employee (DAE)  program; (2) to what extent are FEMA’s human capital controls over the  DAE workforce consistent with internal control standards; and (3) to what  extent does FEMA’s DAE training incorporate key attributes of effective  training and development programs. In addition, we describe FEMA’s  initiative to transform the DAE program announced in April 2012 as it  relates to the three questions above.
We addressed each objective by reviewing relevant FEMA documents.  To determine the extent to which FEMA has policies and procedures in  place to govern its DAE program; and to determine the extent to which  FEMA’s human capital management controls over the DAE workforce are  consistent with internal control standards, we analyzed relevant  documents on FEMA’s organizational structure as well as both program- specific and human capital-related guidance, policies, and procedures  produced by FEMA headquarters and regional offices. We also compared  FEMA’s human capital controls with criteria in Standards for Internal  Control in the Federal Government.
The Fiscal Year 2010 Department of Homeland Security Appropriations Act required  FEMA to submit a report of quarterly obligations of funds against the Disaster Readiness  and Support (DRS). training attended by DAEs in a JFO. We compared FEMA’s management  of DAE training with key attributes of effective training and development  programs to determine the extent to which they are aligned.
To address all three objectives, we reviewed previous Department of  Homeland Security Inspector General Reports, and a FEMA sponsored  study conducted by Booz Allen Hamilton on FEMA’s disaster workforce.
We found the conclusions and recommendations drawn in each report to  be sufficient based on the methodologies used. In addition, we conducted  interviews with FEMA officials in headquarters and in the regions. We  interviewed officials in the following offices in FEMA headquarters: Office  of Response and Recovery, Incident Workforce Management Office  (IWMO), Office of the Chief Component Human Capital Officer  (OCCHCO), Emergency Management Institute, Office of Policy, Planning,  and Analysis (OPPA), Field Based Operations, Training Exercise and  Doctrine (TED), Office of the Chief Information Officer (OCIO) and  national cadre managers. In addition to interviews with officials in FEMA  headquarters, we conducted site visits to four FEMA regions. We  selected regions that were geographically dispersed and had a Joint Field  Office with Individual and Public Assistance programs operating as of  September 2011. In each of the four selected regions, we interviewed the  Regional Administrator and Regional Cadre Managers. In addition, we  visited one JFO in each of the selected regions. In each selected JFO, we  interviewed the Federal Coordinating Officer and Branch Chiefs from  selected cadres. We focused our interviews on the following DAE cadres:  (1) Individual Assistance (IA); (2) Public Assistance (PA); (3) Hazard  Mitigation; (4) Disaster Field Training Operations; (5) Human Resources  (HR); and (6) Community Relations. We focused on IA, PA, Hazard  Mitigation, and CR because these cadres are responsible for  administrating the disaster assistance program and interacting with the  public. In addition, we chose HR and Disaster Field Training Operations  because they are responsible for the management and training of DAEs.  In addition, we interviewed officials from the state emergency  management agency, for the state in which the JFO was located. Table 1  lists the FEMA regions, JFO locations, and State Emergency  Management Agencies we visited.
To obtain the views of DAEs on issues related to all three of our  objectives, we conducted 16 focus group sessions with a total of 125  DAEs at the four selected JFOs. These sessions involved structured  small-group discussions designed to gain more in-depth information  about issues DAEs face. Discussions were guided by a moderator who  used a list of discussion topics to encourage participants to share their  thoughts and experiences as DAEs. Specifically, discussion topics  included the hiring process, training, policies and procedures, FQS and  communication by regional managers; however, not all topics were  discussed in each group. Each focus group involved 5 to 12 DAE  participants. There were four types of focus groups based on job titles: IA  and PA supervisors, IA and PA non-supervisors, and supervisors and  non-supervisors from other cadres other than IA and PA. We completed  written summaries of each focus group, and used content analysis  software to categorize responses and identify common themes across the  focus groups, using appropriate checks to ensure accuracy. The results  of the focus groups are not generalizable. However, the views we  obtained from them provided us with valuable examples of DAE  experiences. In addition, to obtain further perspectives from regional  management on hiring, training, deployments, policies and procedures  and FQS, we conducted follow-up interviews with 16 regional cadre  managers we interviewed during our site visits. In addition, we reviewed  FEMA’s April 2012 memorandum announcing the transformation of the  DAE program, but did not assess its planned actions to transform the  DAE program because the agency is in the early planning stages.
We conducted this performance audit from April 2011 through May 2012  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.

Appendix II: Categories of Disaster Workforce Employees

Appendix II: Categories of Disaster Workforce  Employees Description  Stafford Act federal employees who work on an on-call intermittent basis “forming the major  workforce for FEMA in times of emergency or disaster.” They are also known as reservists.  DAEs are temporary personnel appointed and compensated without regard to the  provisions of Title 5, United States Code, governing appointments in competitive service.  They are activated in direct response to a disaster declaration to support the work of FEMA  at the disaster site. FEMA appoints DAEs in 2-year cycles, as intermittent employees who  are deployed as needed for emergencies and/or disasters.
Federal employees hired under the authority of the Stafford Act on a temporary full-time  basis for 2- and 4-year terms. These terms are renewable if there is ongoing disaster work  and funding available. Similar to DAEs, COREs are temporary personnel appointed and  compensated without regard to the provisions of Title 5, United States Code, governing  appointments in competitive service.
Temporary federal employees covered by Title 5 provisions. They do not have specified  appointment periods. Federal Coordinating Officers (FCO) are included in this employment  group.
Permanent federal employees hired in accordance with Title 5, United States Code.
Staff locally hired under the authority of the Stafford Act for an initial period of 120 days.  This period of time is renewable. Local hires augment the reservist workforce. They are  hired for positions that “do not require FEMA-specific expertise, or when limited advance  training or minimal on-the-job orientation or training is sufficient.” In certain instances local  hires may convert to DAEs.   .
OIG: FEMA’s Management of Disaster Assistance Employee Deployment and Payroll Processes,  Appendix C Director’s Policy 1-99, March 1999.

Appendix III: Cadre List and Descriptions

There are 23 functional disaster cadres excluding the Disaster Generalist  Group, which was created to augment the External Affairs, Individual  Assistance, and Public Assistance cadres and provide surge staff when  required.

Appendix IV: FEMA Organizational Chart— Highlight of Response Directorate’s Incident Workforce Management Office

Appendix V: Disaster Assistance Employee Program Office Reorganization Timeline, April 2008 through May 2012

Appendix VI: Incident Workforce Management Office Organizational Structure and Proposed Roles

Appendix VII: FEMA Disaster Assistance Employee Pay Scale, Calendar Year 2011

Appendix VIII: Comments from the Department of Homeland Security

Appendix IX: GAO Contact and Staff Acknowledgments

	GAO Contact

	Acknowledgments

In addition to the contact named above, Leyla Kazaz, Assistant Director,  managed this assignment. Martene Bryan, Landis Lindsey, Lauren  Membreno, Aku Pappoe and Michelle Su made significant contributions  to the work. Cynthia Saunders assisted with design and methodology.  Tracey King provided legal support and analysis. Linda Miller and Debbie  Sebastian provided assistance in report preparation. Robert Robinson  developed the report graphics.

Summary:
Why GAO Did This Study

Since fiscal year 2007 FEMA has obligated $33 billion in disaster assistance payments. FEMA relies heavily upon its cadre of DAEs, a reserve workforce who interact with disaster survivors. GAO was asked to review the management and training of DAEs. Specifically, this report addresses the extent to which (1) FEMA has policies and procedures in place to govern the DAE program; (2) FEMAs human capital controls over the DAE workforce are consistent with internal control standards; and (3) FEMAs DAE training incorporates key attributes of effective training and development programs. In addition, GAO describes FEMAs initiative to transform the DAE program announced in April 2012. GAO reviewed management documents such as program-specific and human capital-related guidance, interviewed FEMA officials, and conducted 16 focus group sessions with DAEs in four selected joint field offices chosen to provide geographic dispersion, among other factors. The results of the focus groups are not generalizable, but provide valuable insight into DAE experiences.

What GAO Found

The Federal Emergency Management Agency (FEMA) has taken steps to enhance its management of the Disaster Assistance Employee (DAE) program, such as through the establishment of a credentialing program, the FEMA Qualification System (FQS); however, management controls and training could be strengthened. For example, FEMA does not monitor how the regions implement DAE policies and how DAEs implement disaster policies across regions to ensure consistency. FEMAs Administrator noted that due to differences in how regions operate, it is problematic to deploy someone based in one region to another during a disaster. Establishing a mechanism to monitor both the regional implementation of DAE policies and procedures and DAEs implementation of disaster policies could help provide FEMA with reasonable assurance that disaster assistance is conducted in accordance with policy and implemented consistently.
FEMAs human capital controls could be strengthened. FEMAs regional DAE managers are responsible for hiring DAEs, but FEMA has not established hiring criteria and has limited salary criteria. By establishing standardized criteria for making hiring and salary decisions, FEMA would be better positioned to hire people with requisite skills and better ensure consistency across regions. Likewise, FEMAs performance appraisal system for DAEs is not consistent with internal control standards. FEMA does not have criteria for supervisors to assign DAEs satisfactory or unsatisfactory ratings. Thirteen of 16 regional DAE managers GAO interviewed stated that the appraisal process could be improved, such as implementing a rating scale instead of a pass/fail rating. FEMA officials noted that performance management is a critical component in DAE supervision and must be improved in fiscal year 2012. Establishing a more rigorous performance management system that includes criteria for given performance elements as well as guidance could help FEMA ensure that DAEs performance appraisals more accurately reflect performance and provide needed information to managers.
FEMAs DAE training is not consistent with key attributes of effective training and development programs, such as a plan for training staff. FEMA does not have a plan to ensure DAEs receive necessary training such as FQS requirements. Further, 13 of 16 regional DAE managers GAO spoke to said that they would like more opportunities for DAEs to receive training. A plan to ensure that all DAEs have opportunities for training and completing FQS requirements with related milestones would provide FEMA with a roadmap and ensure accountability for qualifying DAEs under FQS. In addition, FEMA does not track how much of the Disaster Relief Fund is spent on training for DAEs. Developing a systematic process to track training costs could provide FEMA with information to help it determine whether it is allocating its resources effectively.
In an April 2012 memo, FEMA announced plans to transform the DAE program beginning in June 2012; however, this effort is still in the early stages and as a result, it is too soon to evaluate the effectiveness of FEMAs planned actions.

What GAO Recommends

GAO recommends, among other things, that FEMA establish a mechanism to monitor both its regions implementation of DAE policies and DAEs implementation of disaster policies; criteria for hiring and compensating DAEs; and a plan to train DAEs within a set time frame. DHS concurred with the recommendations.