CONTINUITY OF 

OPERATIONS 

Agency Plans Have 

Improved, but Better 

Oversight Could Assist 

Agencies in Preparing for 

Emergencies 

Statement of Linda D. Koontz 

Director, Information Management Issues 

United States Government Accountability Office

GAO Testimony Before the Committee on 

Government Reform, House of 

Representatives 

For Release on Delivery 

Expected at 2:00 p.m. EDT 

on Thursday, April 28, 2005 

GAO-05-619T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-619T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Linda Koontz at 

(202) 512-6240 or koontzl@gao.gov. 

Highlights of GAO-05-619T, a testimony 

before the Committee on Government 

Reform, House of Representatives 

April 28, 2005

CONTINUITY OF OPERATIONS 

Agency Plans Have Improved, but Better 

Oversight Could Assist Agencies in 

Preparing for Emergencies 

Many of the 23 agencies that GAO reviewed reported using sound practices 

for identifying and validating essential functions, but few provided 

documentation sufficient for GAO to confirm their responses. (GAO 

identified these sound practices based on published literature and in 

consultation with experts on continuity planning.) Agency responses 

indicate that—although aware of the practices—agencies may not have 

followed them thoroughly or effectively. Further, the essential functions 

identified by agencies varied widely: the number of functions identified in 

each plan ranged from 3 to 538 and included ones that appeared to be of 

secondary importance. The absence in FEMA’s guidance of specific criteria 

for identifying essential functions contributed to this condition. Subsequent 

guidance significantly addresses the sound practices that GAO identified. 

Also, the White House has begun a process to improve continuity planning. If

this guidance and process are implemented effectively, they could lead to 

improved identification of essential functions in the executive branch. 

As of May 1, 2004, agencies had made progress in improving compliance 

with FEMA guidance, but significant weaknesses remained. Agencies that 

had plans in place in both years showed significant improvement in the area 

of tests, training, and exercises. However, although some improvement 

occurred for other planning areas, important weaknesses remained: for 

example, 31 of 45 plans did not fully identify mission-critical systems and 

data necessary to conduct essential functions. Inadequate oversight by 

FEMA contributed to the level of weaknesses in agency continuity plans. 

FEMA plans to improve oversight using an online readiness reporting 

system, which it plans to have fully operational later this year, and it has 

already taken other steps to help agencies improve their plans, such as 

conducting an interagency exercise. However, FEMA does not plan to verify 

the readiness information that agencies will report in the system. 

Finally, even though FEMA’s continuity planning guidance in place in May 

2004 did not address telework, one agency’s continuity plan at that time 

included plans to use telework in response to an emergency. In addition, 10 

agencies reported that they planned to use telework following a COOP 

event, but their plans were not clearly documented. 

In its report, GAO made recommendations aimed at helping to improve 

continuity planning. These included establishing a schedule for the 

completion of recently initiated efforts, developing a strategy for short-term 

oversight in the meantime, and developing and implementing procedures 

that verify the agency-reported data used in oversight of agency continuity of 

operations planning. The report includes comments from FEMA. In 

commenting, FEMA agreed that there has been improvement in COOP plans 

and that additional oversight is needed. 

To ensure that essential 

government services are available 

in emergencies, federal agencies 

are required to develop continuity 

of operations plans. According to 

guidance from the Federal 

Emergency Management Agency 

(FEMA), which is responsible for 

providing guidance for and 

assessing agency continuity plans, 

a key element of a viable capability 

is the proper identification of 

essential functions. GAO previously 

reported on agency continuity plan 

compliance, and determined that a 

number of agencies and their 

components did not have 

continuity plans in place on 

October 1, 2002, and those that 

were in place did not generally 

comply with FEMA’s guidance. 

GAO was asked to testify on its 

most recent work in continuity 

planning, which is discussed in a 

separate report, being released 

today (GAO-05-577). In this report, 

GAO reviewed to what extent 

(1) major federal agencies used 

sound practices to identify and 

validate their essential functions, 

(2) agencies had made progress 

since 2002 in improving compliance 

with FEMA guidance, and 

(3) agency continuity of operations 

plans addressed the use of 

telework arrangements (in which 

work is performed at an 

employee’s home or at a work 

location other than a traditional 

office) during emergencies. 
Mr. Chairman and Members of the Committee: 

I appreciate the opportunity to participate in the Committee’s 

hearing on federal continuity of operations planning. As you know, 

essential government services can be interrupted by a range of 

events, including terrorist attacks, severe weather, or building-level 

emergencies. Federal agencies are required by Presidential Decision 

Directive 67 to develop plans for ensuring the continuity of such 

services in emergency situations. The Federal Emergency 

Management Agency (FEMA), which was designated executive 

agent for executive branch continuity of operations (COOP) 

planning, issued Federal Preparedness Circular 65 in July 1999 as 

planning guidance to agencies. The circular states that, in order to 

have a viable COOP capability, agencies should identify their 

essential functions. These functions then provide the basis for 

subsequent planning steps. The circular also identified eight 

elements of a viable COOP capability.1

We previously reviewed agency COOP plan compliance with 

FEMA’s guidance, at your request. At that time, we found that a 

number of agencies and their components did not have continuity 

plans in place as of October 1, 2002, and those that were in place did 

not generally comply with FEMA’s guidance.2

We subsequently assessed plans in place on May 1, 2004, both from 

the agencies that had plans in place in 2002 and from agencies that 

subsequently adopted plans.3 We examined to what extent 

 

i

1

 In June 2004, FEMA released an updated version of FPC 65, providing additional guidance 

to agencies on each of the topics covered in the original guidance, including an annex on

essential functions.

2

 GAO, Continuity of Operations: Improved Planning Needed to Ensure Delivery of 

Essential Serv ces, GAO-04-160 (Washington, D.C.: Feb. 27, 2004.)

3

 As agreed with your staff, we evaluated agency continuity plans in place on May 1, 2004.

Our methodology included evaluating the headquarters continuity plans for 20 of the 23

largest civilian departments and agencies, as well as for 25 components of departments, for 

compliance with the eight elements identified in FPC 65. We provided agencies with

several opportunities to submit relevant documentation as well as respond to preliminary 

findings.

Page 1 GAO-05-619T
● major federal agencies used sound practices to identify and validate 

their essential functions,

● agencies had made progress in improving compliance with the 

guidance outlined in FPC 65 since our 2002 review,4

 and 

● agency continuity of operations plans addressed the use of telework

arrangements (in which work is performed at an employee’s home 

or at a work location other than a traditional office) during 

emergencies. 

At your request, I am summarizing today the findings and 

recommendations of the report on this most recent work, which is 

being released today.5 

Results in Brief

Many of the 23 agencies reported using the eight sound practices for 

identifying and validating essential functions that we identified (for 

example, performing a risk and impact analysis for each essential 

function), but few provided documentation sufficient for us to

confirm their responses. This indicates that agencies—although 

aware of these practices—may not have followed them thoroughly 

or effectively. In addition, the number of functions identified in each 

agency plan ranged from 3 to 538 and included ones that appeared

to be of secondary importance (for example, “provide advice to the 

Under Secretary”). Both FEMA’s June 2004 revision to its guidance 

and a recently initiated White House effort have the potential, if 

effectively implemented, to help agencies better identify their 

essential functions and thus develop better continuity plans. 

However, the lack of a schedule to complete the White House effort 

makes it unclear when these improvements might take place. 

 

i t

i t i

4

Since the June 2004 version of FPC 65 was released after our cutoff date of May 1, 2004, 

we assessed plans against the July 1999 version of FPC 65. 

5

 GAO, Cont nuity of Operations: Agency Plans Have Improved, but Be ter Oversight Could

Ass s Agencies in Prepar ng for Emergencies, GAO-05-577 (Washington, D.C.: Apr. 28, 

2005). 

Page 2 GAO-05-619T
Although agency COOP plans have shown improvement since our 

prior assessment of 2002 plans, most plans in place on May 1, 2004, 

continued to exhibit inconsistencies in the identification of essential 

functions and significant lack of compliance with FEMA’s guidance.

Inadequate oversight by FEMA contributed to the level of 

weaknesses in agency COOP plans. FEMA plans to improve 

oversight using an online readiness reporting system, which it plans

to have fully operational later this year, and it has already taken 

other steps to help agencies improve their plans, such as conducting 

an interagency exercise. However, FEMA no longer plans to verify 

the readiness information that agencies will report in the system. 

Finally, even though FEMA’s continuity planning guidance in place 

in May 2004 did not address telework, one agency’s continuity plan 

in place at that time indicated that it was planning to use telework in

response to an emergency. In addition, 10 agencies reported that

they planned to use telework following a COOP event, but their 

plans were not clearly documented. 

In our report, we made recommendations to the Assistant to the 

President for Homeland Security and to the Secretary of Homeland 

Security to ensure that agencies are adequately prepared to continue 

performing essential functions following an emergency. In

commenting on our findings and recommendations, FEMA agreed 

that there has been improvement in COOP plans and that additional 

oversight is needed. 

Background 

Federal operations and facilities have been disrupted by a range of 

events, including the terrorist attacks on September 11, 2001; the 

Oklahoma City bombing; localized shutdowns due to severe weather 

conditions, such as the closure of federal offices in the Washington, 

D.C., area in September 2003 due to Hurricane Isabel; and buildinglevel events, such as asbestos contamination at the Department of 

the Interior’s headquarters. Such disruptions, particularly if

prolonged, can lead to interruptions in essential government

services. Prudent management, therefore, requires that federal 

Page 3 GAO-05-619T
agencies develop plans for dealing with emergency situations, 

including maintaining services, ensuring proper authority for 

government actions, and protecting vital assets. 

Until relatively recently, continuity planning was generally the 

responsibility of individual agencies. In October 1998, Presidential 

Decision Directive (PDD) 67 identified the Federal Emergency 

Management Agency (FEMA)—which is responsible for responding 

to, planning for, recovering from, and mitigating against disasters—

as the executive agent for federal COOP planning across the federal 

executive branch. FEMA was an independent agency until March 

2003, when it became part of the Department of Homeland Security 

(DHS), reporting to the Under Secretary for Emergency 

Preparedness and Response. Under PDD 67, its responsibilities

include 

● formulating guidance for agencies to use in developing viable plans;

● coordinating interagency exercises and facilitating interagency 

coordination, as appropriate; and 

● overseeing and assessing the status of COOP capabilities across the 

executive branch. 

According to FEMA officials, the directive also required that 

agencies have COOP plans in place by October 1999. 

In July 1999, FEMA first issued Federal Preparedness Circular 

(FPC) 65. FPC 65 is guidance to the federal executive branch for use 

in developing viable and executable contingency plans that facilitate 

the performance of essential functions during any emergency. 

Specifically, the guidance 

● established the identification of essential functions as the basis for 

COOP planning; 

● defined essential functions as those that enable agencies to provide 

vital services, exercise civil authority, maintain safety, and sustain

the economy during an emergency; 

● defined the elements of a viable continuity of operations capability 

according to eight topic areas: identification of essential functions; 

development of plans and procedures; identification of orders of 

Page 4 GAO-05-619T
succession; delegations of authority; provision for alternate 

facilities; provision of interoperable communications; availability of 

vital records; and conduct of regular tests, training, and exercises; 

and 

● set up an interagency working group to coordinate continuity 

planning. 

FPC 65 applies to all federal executive branch departments and 

agencies at all levels, including locations outside Washington, D.C. It 

directed the heads of each agency to assume responsibilities

including 

● developing, approving, and maintaining agency continuity plans and 

procedures; 

● developing a COOP multiyear strategy and program management 

plan; and 

● conducting tests and training of agency continuity plans, 

contingency staffs, and essential systems and equipment. 

At your request, we previously reported on federal agency 

headquarters contingency plans in place in October 2002.6

 At that

time, we determined that most agencies identified at least one 

function as essential, but the functions varied in number and 

apparent importance. Furthermore, while 20 of 23 agencies had 

documented COOP plans, none addressed all the guidance in FPC 

65. We identified inadequate guidance and oversight as factors 

contributing to these weaknesses, and recommended that DHS

(1) ensure that agencies without plans develop them, (2) ensure that

agencies address weaknesses in their plans, and (3) conduct 

assessments of plans that included an independent verification of

agency-provided data and an assessment of identified essential 

functions. In response to these recommendations, DHS reported in 

July 2004 that it (1) was developing an online system to collect data 

 

l i l

6

 GAO, Continuity of Operations: Improved Planning Needed to Ensure Delivery of 

Essential Government Services, GAO-04-160 (Washington, D.C.: Feb. 27, 2004) and 

Continuity of Operations: Improved Planning Needed to Ensure De ivery of Essent a

Services, GAO-04-638T (Washington, D.C.: Apr. 22, 2004).

Page 5 GAO-05-619T
from agencies on the readiness of their continuity plans that would 

evaluate compliance with the guidance, (2) had conducted an 

interagency exercise, and (3) had developed a training program for 

agency continuity planning managers. DHS added that it planned to 

conduct an independent validation of each agency’s self-assessment 

after deployment of the readiness system.

7

Many Agencies Reported Using Sound Continuity Practices, but Few 

Provided Adequate Supporting Documentation 

Based on an analysis of published literature and in consultation with

experts on continuity planning, we identified eight sound practices

related to essential functions that organizations should use when 

developing their COOP plans. These practices, listed in table 1, 

constitute an ongoing process that includes identifying and 

validating essential functions. 

 7

 GAO, Status of Key Recommendations GAO Has Made to DHS and Its Legacy Agencies, 

GAO-04-865R (Washington, D.C.: July 2, 2004).

Page 6 GAO-05-619T
Table 1: Eight Sound Practices for Continuity Planning

Practices 

Establish a structured COOP project work group/committee that includes representatives 

of all agency components, legal advisors, and continuity experts and either includes a 

member of the agency’s executive management or reports to a member of the agency’s 

executive management. Such a committee should be involved in the initial selection of 

essential functions. 

Determine the resources necessary to perform each function. 

Determine the dependencies necessary to perform each function. 

Develop a schedule or project plan for critical stages in the continuity of operations 

program effort. 

Identify and rank plausible threats, vulnerabilities, liabilities, and/or exposures through a

risk assessment.

Perform a risk and impact analysis for each essential function—including prioritization of

essential functions and determination of minimum acceptance level of output and 

recovery time objective for each function. 

Develop and implement a strategy for validating the continuity plan and the underlying 

essential functions. 

Change its essential functions as the result of the validation process. 

Source: GAO. 

With regard to COOP plans in place on May 1, 2004, many of the 23 

agencies reported using some of the sound practices in developing 

plans, included identifying and validating essential functions, but

few provided documentation sufficient for us to validate their 

responses. This indicates that agencies—although aware of these 

practices—may not have followed them thoroughly or effectively. 

For example, it is unlikely that a thorough risk analysis of essential 

functions could be performed without being documented. 

Further, the essential functions identified by agencies varied widely:

the number of functions identified in each plan ranged from 3 to 538.

In addition, the apparent importance of the functions was not

consistent. For example, a number of essential functions were of

clear importance, such as 

● “conduct payments to security holders” and 

● “carry out a rapid and effective response to all hazards,

emergencies, and disasters.” 

Page 7 GAO-05-619T
Other identified functions appeared vague or of questionable 

importance: 

● “champion decision-making decisions” and 

● “provide advice to the Under Secretary.” 

New Guidance and Review Process Could Result in More Consistent Identification of 

Essential Functions

The high level of generality in FEMA’s guidance on essential 

functions contributed to the inconsistencies in agencies’ 

identification of these functions. As was the case during our 2002 

review, the version of FPC 65 in place on May 1, 2004, defined 

essential functions as those that enable agencies to provide vital 

services, exercise civil authority, maintain safety, and sustain the 

economy during an emergency. The document did not, however, 

define a process that agencies could use to select their essential 

functions. 

In June 2004, FEMA released an updated version of FPC 65, 

providing additional guidance to agencies on each of the topics 

covered in the original guidance, including an annex on essential 

functions. The annex lists several categories that agencies must 

consider when determining which functions are essential, including 

● functions that must continue with minimal interruption or cannot be 

interrupted for more than 12 hours without compromising the 

organization’s ability to perform its mission and 

● functions assigned to the agency by federal law or by order of the 

President. 

The new guidance goes on to outline steps addressing the 

prioritization of selected functions as well as the identification of 

resources necessary to accomplish them and of interdependencies 

with other agencies. 

On January 10, 2005, the Assistant to the President for Homeland

Security issued a memorandum outlining additional guidance on 

essential functions and initiated a process to identify and validate 

agency-level functions. The memorandum noted that in the past

Page 8 GAO-05-619T
many departments and agencies had had difficulty clearly 

identifying and articulating their essential functions. It attributed

this difficulty, in part, to the lack of a defined set of national-level 

essential functions to guide agency continuity planning, resulting in 

multiple efforts to develop agency essential functions for different 

specific purposes (e.g., planning for Year 2000 computer continuity, 

information technology planning, and critical infrastructure 

planning). Further, it noted that departments and agencies 

sometimes do not distinguish between a “function” and the specific 

activities necessary to perform the function. 

To address these issues, the memorandum identified eight National 

Essential Functions that are necessary to lead and sustain the 

country during an emergency and, therefore, must be supported 

through continuity capabilities. Table 2 lists the eight National 

Essential Functions. 

Table 2: National Essential Functions 

Functions 

Preserve our constitutional form of government. 

Provide leadership visible to the nation and the world; maintain the trust and confidence 

of the American people. 

Defend the country against all enemies, foreign or domestic, and prevent or interdict 

future attacks.

Maintain and foster effective relationships with foreign nations. 

Protect against threats to the homeland and bring to justice perpetrators of crimes or 

attacks against the nation, its citizens, or its interests.

Provide rapid and effective response to and recovery from the domestic consequences of

an attack or other incident. 

Protect and stabilize the nation’s economy; ensure confidence in financial systems. 

Provide for critical federal government services that address the national health, safety, 

and welfare needs of the nation. 

Source: White House. 

The memorandum asked major agencies to identify their Priority

Mission Essential Functions—those functions that must be 

performed to support or implement the National Essential 

Functions before, during, and in the immediate aftermath of an 

emergency. The document stated that, generally, priority functions

must be uninterrupted or resumed during the first 24 to 48 hours

after the occurrence of an emergency and continued through full 

resumption of all government functions. 

Page 9 GAO-05-619T
When identifying their functions, agencies were asked to also 

identify the National Essential Function that each priority function

supports, the time in which the priority function must be 

accomplished, and the partners necessary to perform the priority 

function. The memorandum asked agencies to reply by February 18,

2005. 

The memorandum emphasized the need for the involvement of

senior-level agency officials, calling for each agency’s functions to 

be first approved by an official with agencywide responsibilities.

The memorandum then laid out a process by which the functions

would be validated by an interagency group within the Homeland 

Security Council. According to FEMA officials, two agencies’ 

essential functions have already been reviewed, and there are plans 

to complete all agency reviews by the end of the summer. The 

validated functions would then be used to support development of a 

new continuity policy and would be used to develop and implement

improved requirements for capabilities, inform the annual budget

process, establish program metrics, and guide training and exercises

and other continuity program activities. The memorandum did not

set any time frames for these later steps. 

Together, FEMA’s revised guidance and the guidance from the 

White House significantly address the best practices that we 

identified. For example:

● Both documents call for agencies to identify dependencies 

necessary to perform the functions.

● FEMA’s guidance calls for agencies to prioritize their essential 

functions and identify the resources necessary to perform them. 

● The White House guidance calls on agencies to identify the recovery 

time necessary for each function and outlines a process to validate 

the initial list of functions.

If implemented effectively, the new guidance and the review process 

conducted by the White House could result in more consistent

identification of essential functions across the executive branch. 

The functions could then form the basis for better plans for 

continuing the most critical functions following a disruption to

normal operations. However, without time frames for completing 

Page 10 GAO-05-619T
the outlined process, it is unclear when the expected improvement

will occur. 

s

Agency COOP Plans Have Improved, but None Address All of 

FEMA’s Guidance 

When compared with our prior assessment, agency continuity plans 

● One agency and nine component agencies that did not have 

review

● the guidance, agencies 

owever, two major agencies did not have plans in place on May 1, 

In addition, after analyzing these plans, we found that none in place 

er 

● Essential functions. Most agency plans identified at least one 

f

e

s. 

● ,

in place on May 1, 2004, showed improved compliance with FEMA’s 

guidance in two ways:

documented continuity plans in place at the time of our 2002

had put such plans in place by May 1. 

For each of the topic areas outlined in

generally made progress in increasing compliance. 

H

2004. As of April 2005, one of these two had finalized its plan. 

on May 1 followed all of FEMA’s guidance. Of the eight topic areas 

identified in FPC 65, these 45 COOP plans generally complied with 

the guidance in two areas (developing plans and procedures and 

order of succession); generally did not comply in one area (tests, 

training, and exercises); and showed mixed compliance in the oth

five areas. Specifically, when examining the governmentwide results

of our analysis of the eight planning topics outlined in FPC 65, we 

determined the following: 

unction as essential and identified which functions must be 

continued under all circumstances. However, less than half th

COOP plans identified interdependencies among the functions,

established staffing and resource requirements, or identified the

mission-critical systems and data needed to perform the function

Plans and procedures. Most plans followed the guidance in this area

including establishing a roster of COOP personnel, activation 

Page 11 GAO-05-619T
procedures, and the appropriate planning time frame (12 hours to 30

days). 

● Orders of succession. All but a few agency plans identified an order 

of succession to the agency head. Most plans included orders of 

succession for other key officials or included officials outside of the 

local area in the succession to the agency head. Many plans did not 

include the orders of succession in the agency’s vital records or 

document training for successors on their emergency duties. 

● Delegations of authority. Few plans adequately documented the 

legal authority for officials to make policy decisions in an 

emergency. 

● Alternate facilities. Most plans documented the acquisition of at 

least one alternate facility, and many included alternate facilities

inside and outside of the local area. However, few plans 

documented that agencies had sufficient space for staff, prepositioned equipment, or appropriate communications capabilities

at their alternate facilities.

● Redundant emergency communications. Most plans identified at 

least two independent media for voice communication. Less than 

half of the plans included adequate contact information, and few 

provided information on backup data links. 

● Vital records. Less than half of the plans fully identified the agency’s 

vital records. Few plans documented the locations of all vital 

records or procedures for updating them. 

● Tests, training, and exercises. While many agencies documented 

some training, very few agencies documented that they had 

conducted tests, training, and exercises at the recommended 

frequency. 

Inadequate Oversight by FEMA Contributes to Noncompliance 

During our prior review of 2002 plans, we found that insufficient 

oversight by FEMA contributed to agencies’ lack of compliance with

the guidance. Specifically, we noted that FEMA had not conducted 

an assessment of agency contingency plans since 1999. As a result, 

we recommended that it conduct assessments of agency continuity

plans that include independent verification of agency-reported 

information. In response, DHS reported that it was developing a 

Page 12 GAO-05-619T
readiness reporting system to assist it in assessing agency plans and 

planned to verify the information reported by the agencies. 

Although neither of these planned actions was completed by May 1, 

2004, FEMA has made subsequent efforts to improve its oversight. 

According to FEMA officials, development of the readiness 

reporting system was completed in March 2005, and the system is 

expected to be operational and certified by October 2005, at which 

time there will be seven locations (including two FEMA locations) 

using the system. They added that once the system becomes fully 

operational, agencies will be required to periodically provide 

updated information on their compliance with FEMA’s guidance. 

These officials also reported that the agency had taken additional 

steps to improve readiness. Specifically, they stated that the 

interagency exercise held in mid-May 2004 successfully activated 

and tested agency plans; they based this assessment on reports 

provided by the agencies. Furthermore, FEMA has begun planning 

for another interagency exercise in 2006. In addition, as of April 

2005, FEMA had provided training to 682 federal, state, and local 

officials from 30 major federal departments and agencies and 209 

smaller agencies—including state, local, and tribal entities. FEMA 

officials stated that because of these additional successful efforts to 

improve readiness, they no longer planned to verify agency-reported 

readiness data. 

While the revised guidance, recent exercise, and ongoing training 

should help ensure that agency continuity plans follow FEMA’s

guidance, FEMA’s ongoing ability to oversee agency continuity 

planning activities will be limited by its reliance on agency-provided 

data. Without verification of such data, FEMA lacks assurance that

agency plans are compliant and that the procedures outlined in

those plans will allow agencies to effectively continue to perform 

their essential functions following a disruption. 

One Agency Plans to Use Telework in Response to an Emergency 

Telework, also referred to as telecommuting or flexiplace, has 

gained widespread attention over the past decade in both the public 

Page 13 GAO-05-619T
and private sectors as a human capital flexibility that offers a variety

of potential benefits to employers, employees, and society. In a 2003 

report to Congress on the status of telework in the federal 

government, the Director of the Office of Personnel Management

(OPM) described telework as “an invaluable management tool 

which not only allows employees greater flexibility to balance their 

personal and professional duties, but also allows both management 

and employees to cope with the uncertainties of potential 

disruptions in the workplace, including terrorist threats.”8

As we reported in an April 2004 report, telework is an important and 

viable option for federal agencies in COOP planning and 

implementation efforts, especially as the duration of an emergency 

event is extended.9 In a July 2003 GAO report, we defined 25 key 

telework practices for implementation of successful federal 

telework programs.

10

Although not required to do so, 1 of the 21 agency continuity plans

in place on May 1, 2004, documented plans to address some 

essential functions through telework. Two other agencies reported 

that they planned to use telework to fulfill their essential functions, 

and eight agencies reported that they planned for nonessential staff

to telework during a COOP event, but their continuity plans do not 

specifically mention telework. 

However, none of the agencies that are planning to use telework 

during a COOP event documented that the necessary preparations 

had taken place. These preparations—derived from the 25 key 

telework practices for the development of an effective telework 

program—include informing and training the staff, ensuring that

there is adequate technological capacity for telework, providing 

technological assistance, and testing the ability to telework. 

 t

i t

8

 U.S. Office of Personnel Management, Report to the Congress: The Sta us of Telework in 

the Federal Government (Washington, D.C.: January 2003). 

9

 GAO, Human Capital: Opportunities to Improve Federal Continuity Planning Guidance, 

GAO-04-384 (Washington, D.C.: Apr. 20, 2004). 

10 GAO, Human Capital: Further Guidance, Ass s ance, and Coordination Can Improve 

Federal Telework Efforts, GAO-03-679 (Washington, D.C.: July 18, 2003). 

Page 14 GAO-05-619T
In summary, Mr. Chairman, although agency COOP plans have 

shown improvement since our prior assessment of 2002 plans, most 

plans in place on May 1, 2004, continued to exhibit inconsistencies 

in the identification of essential functions and significant lack of 

compliance with FEMA’s guidance. Both FEMA’s revision to this 

guidance and a recently initiated White House effort have the 

potential, if effectively implemented, to help agencies better identify 

their essential functions and thus develop better continuity plans. 

However, the lack of a schedule to complete the White House effort 

makes it unclear when these improvements might take place. 

Agencies’ efforts to develop continuity plans could also be aided by 

FEMA’s efforts to develop a readiness reporting system, conduct a 

governmentwide exercise, and train agency COOP planners, as well 

as by any guidance or policies that result from the White House 

effort. 

Finally, even though FEMA’s continuity planning guidance in place 

in May 2004 did not address telework, one agency’s continuity plan 

at that time included plans to use telework in response to an 

emergency. In addition, 10 agencies reported that they planned to 

use telework following a COOP event, but their plans were not 

clearly documented. 

In our report, we make recommendations aimed at helping to ensure 

that agencies are adequately prepared to perform essential functions

following an emergency. We recommended that the Assistant to the 

President for Homeland Security establish a schedule for the 

completion of the recently initiated effort to validate agency 

essential functions and refine federal continuity of operations

policy. We also recommended that the Secretary of Homeland 

Security direct the Under Secretary for Emergency Preparedness 

and Response to

● develop a strategy for short-term oversight that ensures that 

agencies are prepared for a disruption in essential functions while 

the current effort to identify essential functions and develop new 

guidance is ongoing; 

Page 15 GAO-05-619T
● develop and implement procedures that verify the agency-reported 

data used in oversight of agency continuity of operations planning; 

and 

● develop, in consultation with OPM, guidance on the steps that 

agencies should take to adequately prepare for the use of telework

during a COOP event. 

In commenting on our findings and recommendations, the Under 

Secretary for Emergency Preparedness and Response of DHS stated 

that the department agreed that there has been improvement in

COOP plans and attributed that improvement to a renewed 

emphasis by DHS and the White House. The department also agreed 

with the need for additional oversight and noted that FEMA had 

begun conducting COOP site assessments at departments and 

agencies to improve readiness. The Under Secretary’s letter drew 

attention to a number of actions taken after the May 1, 2004, cutoff 

date for our assessment. Finally, the Under Secretary pointed out

that the readiness reporting system that FEMA is developing was 

not intended to be a COOP plan assessment tool, but that it instead

provides key officials with the ability to determine plan status in 

near real time. We continue to believe that it is important for FEMA 

to assess agency plans as part of its oversight responsibilities.

Regardless of the system’s intended use, we believe its capabilities, 

as described by FEMA, make it a valuable tool that the agency 

should use when exercising these responsibilities. 

Mr. Chairman, this concludes my statement. I would be pleased to 

respond to any questions that you or other members of the 

Committee may have at this time. 

Contacts and Acknowledgements 

For information about this testimony, please contact Linda D. 

Koontz at (202) 512-6240 or at koontzl@gao.gov, or James R.

Sweetman at (202) 512-3347 or sweetmanj@gao.gov. Other key 

contributors to this testimony include Barbara Collier, Mike Dolak, 

Nick Marinos, and Jessica Waselkow. 

(310734) Page 16 GAO-05-619T
This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help 

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost 

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To 

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “Subscribe to Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm 

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

GAO’s Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Mail or Phone 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER