Report to Congressional Committees

United States Government Accountability Office

GAO 

June 2008 NATIONAL 

RESPONSE 

FRAMEWORK 

FEMA Needs Policies 

and Procedures to 

Better Integrate 

Non-Federal 

Stakeholders in the 

Revision Process 

GAO-08-768 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

To view the full product, including the scope 

and methodology, click on GAO-08-768. 

For more information, contact William Jenkins 

at (202) 512-8757 or JenkinsWO@gao.gov. 

Highlights of GAO-08-768, a report to 

congressional committees 

June 2008

NATIONAL RESPONSE FRAMEWORK

FEMA Needs Policies and Procedures to Better 

Integrate Non-Federal Stakeholders in the Revision 

Process

While DHS included non-federal stakeholders—state, local, and tribal 

governments, nongovernmental organizations, and the private sector—in the 

initial and final stages of revising the 2004 Plan into the NRF, it did not 

collaborate with these stakeholders as fully as it originally planned or as 

required by the October 2006 Post-Katrina Emergency Management Reform 

Act (Post-Katrina Act). As the revision process began in 2006, DHS involved 

both federal and non-federal stakeholders by soliciting and incorporating their 

input in determining the key revision issues and developing the first draft in 

April 2007. However, after this first draft was completed, DHS deviated from 

its revision work plan by conducting a closed, internal federal review of the 

draft rather than releasing it for stakeholder comment because the draft 

required further modifications DHS considered necessary. DHS limited 

communication with non-federal stakeholders until it released a draft for 

public comment 5 months later on September 10, 2007. The following day, 

non-federal stakeholders testified at a congressional hearing that DHS had 

shut them out during that 5-month period. In addition, the Post-Katrina Act 

required that DHS establish a National Advisory Council (NAC) for the FEMA 

Administrator by December 2006 to, among other things, incorporate nonfederal stakeholders’ input in the revision process. However, FEMA stated the 

necessary time to select quality NAC members required additional time, and 

FEMA did not announce the NAC’s membership until June 2007. The NAC did 

not provide comments on a revision draft until one month before DHS 

publicly released the final NRF in January 2008.

FEMA anticipates that the NRF will be revised in the future; however, FEMA 

does not have policies or procedures in place to guide this process or ensure a 

collaborative partnership with stakeholders. FEMA has emphasized the 

importance of partnering with relevant stakeholders to effectively prepare for 

and respond to major and catastrophic disasters, and the Congress, through 

the Post-Katrina Act, requires such partnership. In addition, the Standards for 

Internal Controls in the Federal Government calls for policies and 

procedures that establish regular communication with stakeholders and 

monitor performance over time as essential for achieving desired program 

goals. Furthermore, previous GAO work on the Department of Defense’s civil 

support plans and the administration’s national pandemic influenza 

implementation plan has shown the need for participation of state and local 

jurisdictions in emergency planning. Especially in view of a new 

administration, the experience of the previous revision process illustrates the 

importance of collaborating with stakeholders in revising a plan that relies on 

them for its successful implementation. While the NRF is published by DHS, it 

belongs to the nation’s emergency response community. Developing such 

policies and procedures is essential for ensuring that FEMA attains the PostKatrina Act’s goal of partnering with non-federal stakeholders in building the 

nation’s emergency management system, including the periodic review and 

revision of the NRF. 

Hurricane Katrina illustrated that 

effective preparation and response 

to a catastrophe requires a joint 

effort between federal, state, and 

local government. The Department 

of Homeland Security (DHS), 

through the Federal Emergency 

Management Agency (FEMA), is 

responsible for heading the joint 

effort. In January 2008, DHS 

released the National Response 

Framework (NRF), a revision of 

the 2004 National Response Plan

(2004 Plan), the national 

preparation plan for all hazards. In 

response to the explanatory 

statement to the Consolidated 

Appropriations Act of 2008 and as 

discussed with congressional 

committees, this report evaluates 

the extent to which (1) DHS 

collaborated with non-federal 

stakeholders in revising and 

updating the 2004 Plan into the 

2008 NRF and (2) FEMA has 

developed policies and procedures 

for managing future NRF revisions. 

To accomplish these objectives, 

GAO reviewed DHS and FEMA 

documents related to the revision 

process, analyzed the relevant 

statutes, and interviewed federal 

and non-federal officials who held 

key positions in the revision 

process. 

What GAO Recommends

GAO recommends that FEMA 

develop policies and procedures 

that guide how future revision 

processes will occur, particularly 

for collaborating with non-federal 

stakeholders. 

FEMA concurred with our 

recommendation. 
Page i GAO-08-768 FEMA's National Response Framework

Letter 1

Results in Brief 4 

Background 6 

DHS Did Not Collaborate with Non-Federal Stakeholders As Fully 

As Planned or Required in Developing the NRF 9 

FEMA and the Post-Katrina Act Have Recognized the Importance 

of Including Non-Federal Stakeholders in Developing National 

Response Doctrine, but FEMA Lacks Guidance and Procedures 

for Future NRF Revisions 22 

Conclusions 27 

Recommendation for Executive Action 28 

Agency Comments 28 

Appendix I Scope and Methodology 30 

Appendix II The 17 Key Revision Issues That DHS Identified 

for the 2004 National Response Plan 32 

Appendix III The 12 Work Groups DHS Established during the 

Revision Process and Their Composition 34 

Appendix IV GAO Contact and Staff Acknowledgments 37 

Table 

Table 1: The 224 Non-Federal Stakeholders Who Participated in the 

Revision Work Groups by Occupational Sector and by 

Level of Government, Nongovernmental Organization, and 

Private Sector 35 

Figures 

Figure 1: Significant Events and Documents in DHS’s Revision of 

the 2004 National Response Plan into the 2008 National 

Response Framework 3 

Contents 
Page ii GAO-08-768 FEMA's National Response Framework

Figure 2: Relationship among Entities within the September 2006 

Revision Work Plan 12 

Figure 3: DHS’s Revision Process as Planned by Its September 2006 

Work Plan and as Required by the October 2006 PostKatrina Act 13 

Figure 4: Composition of the 710 Members of the 12 Work Groups 

by Federal, State, Local, and Tribal Government, 

Nongovernmental Organization, and Private Sector 15 

Figure 5: DHS’s Actual Revision Process Compared with Its 

Proposed Process 21 

Abbreviations 

2004 Plan 2004 National Response Plan

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency 

FMFIA Federal Managers’ Financial Integrity Act of 1982 

GAO Government Accountability Office 

NAC National Advisory Council 

NRF 2008 National Response Framework 

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Page 1 GAO-08-768 FEMA's National Response Framework 

June 11, 2008 

The Honorable Robert C. Byrd 

Chairman 

The Honorable Thad Cochran 

Ranking Member 

Subcommittee on Homeland Security 

Committee on Appropriations 

United States Senate 

The Honorable David E. Price 

Chair 

The Honorable Harold Rogers 

Ranking Member 

Subcommittee on Homeland Security 

Committee on Appropriations 

House of Representatives 

A common axiom in emergency management is that “All disasters are 

local.” But a key lesson Hurricane Katrina dramatically emphasized was 

that major disasters can quickly overwhelm the capacity of local 

responders. Thus, preparing for, responding to, and recovering from major 

disasters requires partnerships between the federal government and nonfederal stakeholders, such as state, local, and tribal governments, the 

private sector, and nongovernmental organizations. In summarizing the 

lessons learned from our nation’s response to Katrina, we reported in 

September 2006 that these federal and non-federal partnerships were 

critical to improving catastrophic disaster response.1

 The 2006 PostKatrina Emergency Management Reform Act (Post-Katrina Act)2

specifically tasked the Federal Emergency Management Agency (FEMA) 

within the Department of Homeland Security (DHS) to partner with these 

non-federal stakeholders to build a national system of emergency 

management. In outlining his vision for a “New FEMA” and in testimonies 

 1

 GAO, Catastrophic Disasters: Enhanced Leadership, Capabilities, and Accountability 

Controls Will Improve the Effectiveness of the Nation’s Preparedness, Response, and 

Recovery System, GAO-06-618 (Washington, D.C.: Sept. 6, 2006). 

2

 The Post-Katrina Act was enacted as Title VI of the Department of Homeland Security 

Appropriations Act, 2007, Pub. L. No. 109-295, 120 Stat. 1355 (2006). 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-08-768 FEMA's National Response Framework 

before the Congress, the FEMA Administrator has acknowledged that 

FEMA’s success depends on its ability to establish and maintain robust 

partnerships with non-federal stakeholders. 

DHS issued the National Response Plan in December 2004 (2004 Plan) to 

provide common principles and structures to align the efforts of 

stakeholders at the local, state, and federal level to ensure an effective 

national disaster response system. The events surrounding Hurricane 

Katrina in August 2005 and the resulting lessons-learned and after-action 

reports by the Congress and administration prompted DHS to revise the 

just issued 2004 Plan. DHS released an interim revision of elements of the 

2004 Plan in May 2006 and developed a work plan for a more 

comprehensive revision in September 2006. Shortly thereafter, Congress 

passed the October 2006 Post-Katrina Act, which made the FEMA 

Administrator, through the National Integration Center, responsible for 

ongoing management and maintenance of the 2004 Plan, including 

periodic review and revision. In addition, the act required the DHS 

Secretary to establish a National Advisory Council of non-federal 

stakeholders to advise the FEMA Administrator in revising the 2004 Plan. 

During the summer of 2007 in the midst of the revision process, nonfederal members of the emergency management community raised 

concerns over the extent to which DHS included them in the process. In 

September 2007, the House Committee on Transportation and 

Infrastructure held a hearing on DHS’s management of the revision 

process and the involvement of non-federal stakeholders. DHS completed 

its revision efforts with the publication of the National Response 

Framework (NRF) on January 22, 2008.3

 The NRF is a guide for how the 

federal, state, local, and tribal governments, along with nongovernmental 

and private sector entities, will collectively respond to and recover from 

all disasters, particularly catastrophic disasters such as Hurricane Katrina, 

regardless of their cause. The NRF recognizes the need for collaboration 

among the myriad of entities and personnel involved in response efforts at 

all levels of government, nonprofit organizations, and the private sector. 

See figure 1 depicting the significant events and documents in the revision 

of the 2004 Plan into the 2008 NRF. 

 3

 The new National Response Framework became effective on March 22, 2008. 
Page 3 GAO-08-768 FEMA's National Response Framework 

Figure 1: Significant Events and Documents in DHS’s Revision of the 2004 National Response Plan into the 2008 National 

Response Framework

a

See figure 5 for a time line on DHS’s revision process from October 2006 to January 2008. 

In the explanatory statement accompanying the Consolidated 

Appropriations Act of 2008, the appropriations committees tasked GAO to 

review the process DHS used to update the NRF, including the process for 

including key stakeholders. We conducted our review to determine the 

extent to which (1) DHS collaborated with non-federal stakeholders in 

revising and updating the 2004 Plan into the 2008 NRF and (2) FEMA has 

developed policies and procedures for managing future revisions of the 

NRF, for which it is statutorily responsible. 

To address our objectives, we reviewed DHS and FEMA documents on the 

revision process and applicable statutes to determine the level to which 

the revision process was planned. To determine what happened during the 

process, we interviewed DHS and FEMA officials as well as non-federal 

Source: GAO analysis; DHS information.

Dec. 04

National Response 

Plan (2004 Plan)

Aug. 05

Hurricane 

Katrina

May 06

Interim changes

to 2004 Plan

through Notice 

of Change

Feb.-May 06

Katrina afteraction and 

lessons-learned 

reports

Sept. 06

DHS Work Plan 

for 2004 Plan 

revision

Oct. 06

Post-Katrina

Emergency 

Management 

Reform Act

Oct. 06 to Jan. 08

DHS’s revision 

of the 2004 Plana

Jan. 08

National Response 

Framework 
Page 4 GAO-08-768 FEMA's National Response Framework 

stakeholders representing state and local levels of government, emergency 

management associations, and others who served in key positions in the 

revision process, such as the co-leaders of work groups and members of a 

steering committee. The statements and views of these stakeholders are 

not generalizable to the population of non-federal stakeholders involved in 

the revision process. However, we selected these stakeholders because of 

their assigned key roles and believe that their views provided us with a 

general indication of stakeholder perspectives on their involvement in the 

revision process. To address our objectives, we reviewed DHS and FEMA 

documents on the revision process and applicable statutes to determine 

the level to which the revision process was planned. In assessing DHS and 

FEMA actions related to these objectives, we used criteria from our prior 

work on results-oriented government as well as best practices for federal 

coordination and collaboration with stakeholders. We also used criteria in 

GAO’s Standards for Internal Control in the Federal Government.

4

 These 

standards, issued pursuant to the requirements of the Federal Managers’ 

Financial Integrity Act of 1982 (FMFIA), provide the overall framework for 

establishing and maintaining internal control in the federal government. 

Also pursuant to FMFIA, the Office of Management and Budget issued 

Circular A-123, revised December 21, 2004, to provide the specific 

requirements for assessing and reporting on internal controls. Internal 

control standards and the definition of internal control in Circular A-123 

are based on GAO’s Standards for Internal Control in the Federal 

Government. For more detailed information on our scope and 

methodology, see appendix I. 

We conducted this performance audit from September 2007 to June 2008, 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

While DHS included non-federal stakeholders during the initial and final 

months of the process of revising the 2004 Plan, it did not collaborate with 

them as fully as envisioned in its original work plan or as required by the 

 4

 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). 

Results in Brief 
Page 5 GAO-08-768 FEMA's National Response Framework 

2006 Post-Katrina Act. DHS’s management of the initial stages of the 

revision process was generally consistent with the work plan and involved 

state and local stakeholders in identifying key issues and developing draft 

segments of the revised 2004 Plan. However, DHS deviated from its work 

plan and did not provide the first full revision draft to non-federal 

stakeholders for their comments and suggestions before conducting an 

internal, federal review of the draft because it required further 

modifications. Instead, DHS sent the first draft for the internal, federal 

review for 5 months before requesting stakeholder comment and without 

communicating the change in plans with the non-federal stakeholders. At 

the end of the 5-month internal review, DHS released a revised draft in 

September 2007, providing an opportunity for non-federal stakeholders as 

well as the general public to comment and have access to all non-federal 

comments submitted. DHS’s approach was also not in accordance with the 

Post-Katrina Act’s requirement that DHS establish a National Advisory 

Council (NAC) to incorporate non-federal input into the revision of 

national response doctrine. Although the NAC was to be established 

within 60 days of the Act (i.e., December 4, 2006), FEMA, which assumed 

responsibility for selecting members, did not name NAC members until 

June 2007 because of the additional time needed to review hundreds of 

applications and select a high quality body of advisors, according to the 

FEMA Administrator. The NAC’s first meeting took place in October 2007 

after DHS issued the revised plan for public comment. 

While FEMA and the Congress, through the Post-Katrina Act, recognize 

the importance of partnering with non-federal stakeholders in disaster 

planning and response, FEMA has not yet developed guidance and 

procedures—elements specified as essential for planning and achieving 

effective results in Standards for Internal Control in the Federal 

Government—that describe how future revisions of the National 

Response Framework will be managed. The 2004 Plan included such 

guidance, including the circumstances that would lead to future 

revisions—such as changes in directives, laws, and lessons learned from 

exercises and actual events—and time frames for reviewing the plan. In 

addition, while these federal internal control standards state that 

communication with stakeholders is essential, FEMA has not articulated 

how it will involve stakeholders, or how the newly established NAC will be 

integrated into the revision process. Especially in view of a new 

administration, developing such policies and procedures is essential for 

ensuring that FEMA attains the Post-Katrina Act’s goal of partnering with 

non-federal stakeholders in building the nation’s emergency management 

system, including the periodic review and revision of the NRF. According 

to FEMA, it has not yet developed guidance and procedures because of the 
Page 6 GAO-08-768 FEMA's National Response Framework 

need to focus federal resources on creating training materials to assist all 

stakeholders in implementing the current NRF in anticipation of the 

pending 2008 hurricane season. 

As FEMA begins to implement and review the 2008 NRF, we recommend 

that the Administrator develop and disseminate policies and procedures 

describing the conditions and time frames under which the next NRF 

revision will occur and how FEMA will conduct the next NRF revision. 

These policies and procedures should clearly describe how FEMA will 

integrate all stakeholders, including the NAC and other non-federal 

stakeholders, into the revision process and the methods for 

communicating to these stakeholders. 

We requested comments on a draft of this report from DHS and FEMA. 

They concurred with our recommendations and had no other comments. 

Several federal legislative provisions support preparation for and response 

to disasters. The Robert T. Stafford Disaster Relief and Emergency 

Assistance Act5

 (Stafford Act) primarily establishes the programs and 

processes for the federal government to provide major disaster and 

emergency assistance to states, local governments, tribal nations, 

individuals, and qualified private nonprofit organizations. FEMA has 

responsibility for administering the provisions of the Stafford Act, and the 

Act provides the FEMA Administrator with the authority to prepare 

federal response plans and programs. In April 1992, FEMA issued a 

Federal Response Plan, which outlined how the federal government 

implements the Stafford Act. The Federal Response Plan described, 

among other things, the response and recovery responsibilities of each 

federal department and agency for saving lives and protecting public 

health and safety during an emergency or major disaster. 

After the events of September 11, 2001, and with the passage of the 

Homeland Security Act6

 in November 2002, FEMA became part of the 

 5

 42 U.S.C. 5121 et. seq. 

6

 Pub. L. No. 107-296, 116 Stat. 2135 (2002). 

Background 
Page 7 GAO-08-768 FEMA's National Response Framework 

newly formed Department of Homeland Security (DHS).7 Under the Act, 

FEMA retained its authority to administer the provisions of the Stafford 

Act as well as its designation as the lead agency for the Federal Response 

Plan. The Homeland Security Act required DHS to consolidate existing 

federal government emergency response plans into a single, integrated, 

and coordinated national response plan. In December 2004, DHS issued 

the 2004 Plan to integrate the federal government’s domestic prevention, 

preparedness, response, and recovery plans into one plan that addressed 

all disaster situations, whether due to nature, terrorism, or other manmade activities. The 2004 Plan incorporated or superceded other federal 

interagency plans such as the Federal Response Plan and the Federal 

Radiological Emergency Response Plan. 

In August 2005, Hurricane Katrina and, shortly after, hurricanes Wilma and 

Rita revealed a number of limitations in the 2004 Plan. Beginning in 

February 2006, reports by the House Select Bipartisan Committee to 

Investigate the Preparation for and Response to Hurricane Katrina,8

 the 

Senate Homeland Security and Governmental Affairs Committee,9

 the 

White House Homeland Security Council,10 the DHS Inspector General,11

and DHS and FEMA12 all identified a variety of failures and some strengths 

in the preparations for, response to, and initial recovery from Hurricane 

Katrina. After reviewing these reports, DHS concluded that the 2004 Plan 

required revision. In May 2006, DHS released immediate modifications to 

the 2004 Plan pending a more comprehensive review. In June 2006, 

 7

 Our report will refer to individual DHS components such as FEMA where the component 

has a defined, specific authority or can be identified as being specifically responsible for a 

particular action or decision. Otherwise, any reference to DHS will refer to DHS as a whole 

unless clearly specified otherwise. 

8

 U.S. House of Representatives, House Select Bipartisan Committee to Investigate the 

Preparation for and Response to Hurricane Katrina, A Failure of Initiative: Final Report 

of the House Select Bipartisan Committee to Investigate the Preparation for And 

Response to Hurricane Katrina (Washington, D.C.: Feb. 15, 2006). 

9

 U.S. Senate Committee on Homeland Security and Governmental Affairs, Hurricane 

Katrina: A Nation Still Unprepared (Washington, D.C.: May 2006). 

10 White House Homeland Security Council, The Federal Response to Hurricane Katrina: 

Lessons Learned (Washington, D.C.: Feb. 23, 2006). 

11 Department of Homeland Security Office of Inspector General, A Performance Review of 

FEMA’s Disaster Management Activities in Response to Hurricane Katrina, OIG-06-32 

(Washington, D.C.: Mar. 31, 2006). 

12 Federal Emergency Management Agency, DHS/FEMA Initial Response Hotwash: 

Hurricane Katrina in Louisiana, DR-1603-LA (Feb. 13, 2006). 
Page 8 GAO-08-768 FEMA's National Response Framework 

Congress passed the Emergency Supplemental Appropriations Act for 

Defense, the Global War on Terror, and Hurricane Recovery, 2006.13 In the 

conference report accompanying this act, the conferrees recommended 

that FEMA apply $3 million of its Preparedness, Mitigation, Response, and 

Recovery appropriation to immediately review and revise the 2004 Plan as 

well as its companion document, the National Incident Management 

System, which provides standard command and management structures 

that apply to response activities.14

On October 4, 2006, the Post-Katrina Act was enacted. This act, among 

other things, made certain organizational changes within DHS to 

consolidate emergency preparedness and emergency response functions 

within FEMA, required that DHS maintain FEMA as a distinct entity within 

the department, and designated the FEMA Administrator—the new title of 

the official who will lead the agency—as the principal advisor to the 

President, the Homeland Security Council, and the Secretary for all 

matters relating to emergency management. Most of the organizational 

changes, such as the transfer of various functions from DHS’s Directorate 

of Preparedness to FEMA, became effective as of March 31, 2007. Others, 

such as the increase in the organizational autonomy for FEMA and the 

establishment of the National Integration Center, became effective upon 

enactment. The Post-Katrina Act specified that the FEMA Administrator, 

acting through the Center, “shall ensure ongoing management and 

maintenance of the...National Response Plan,” including periodic review 

and revision. The Post-Katrina Act also directed the Secretary to establish 

a National Advisory Council (NAC) by December 2006 to, among other 

things, incorporate state, local, and tribal government and private sector 

input in the development and revision of the 2004 Plan. As established by 

the Post-Katrina Act, the NAC is intended to be an ongoing advisory 

council that draws upon individuals with a broad body of expertise and 

geographic and substantive diversity. The Act requires the NAC to advise 

the Administrator on a variety of emergency management issues across 

the national preparedness spectrum, including the 2004 Plan. 

In January 2008, DHS issued the 2008 NRF, the product of the revision of 

the 2004 Plan. The NRF became effective in March 2008 and retained the 

basic structure of the 2004 Plan. For example, like the 2004 Plan, the 

NRF’s core document describes the doctrine that guides national response 

 13 Pub. L. No. 109-234, 120 Stat. 418 (2006). 

14 H.R. Conf. Rep. No. 109-494, at 118 (2006). 
Page 9 GAO-08-768 FEMA's National Response Framework 

actions and the roles and responsibilities of officials and entities involved 

in response efforts. Further, the NRF also includes Emergency Support 

and Incident Annexes. However, in contrast to the 2004 Plan, FEMA plans 

to include four partner guides to the NRF that describe key roles and 

actions for local, tribal, state, federal and private sector entities involved in 

response activities. 

While DHS included non-federal stakeholders at the initial and final stages 

in the process of revising the December 2004 Plan, it did not collaborate 

with them as fully as planned in its revision work plan or as required by 

the Post-Katrina Act. DHS based the work plan, which was approved by a 

White House Homeland Security Council–chaired policy committee, on a 

section in the 2004 Plan that provided procedural guidance for managing 

revisions of the document. DHS managed the initial stages of the revision 

process according to the work plan. However, DHS deviated from its work 

plan after the first draft was completed in April 2007. Instead of widely 

disseminating the first draft to all stakeholders, including non-federal 

stakeholders, for comment and modification, DHS retained the draft to 

make modifications that it felt were necessary and conducted an internal, 

federal review of the draft for a 5-month period. DHS delayed the release 

of the April 2007 draft and provided limited communication to state and 

local stakeholders on the status of the review until after releasing the draft 

for public comment in September 2007. In addition, DHS did not manage 

the revision process in accordance with the Post-Katrina Act’s provision 

that DHS establish FEMA’s NAC by December 2006 and incorporate the 

NAC’s non-federal input into the revision. 

DHS Did Not 

Collaborate with NonFederal Stakeholders 

As Fully As Planned 

or Required in 

Developing the NRF 
Page 10 GAO-08-768 FEMA's National Response Framework 

Hurricane Katrina hit the Gulf Coast in August 2005 and the nation’s 

response prompted DHS to revise the 2004 Plan. In May 2006, DHS issued 

an official Notice of Change15 to the 2004 Plan to incorporate lessons 

learned from the response to hurricanes Katrina, Wilma, and Rita as well 

as to incorporate organizational changes within DHS. This Notice of 

Change—which was distributed to all signatories16 of the 2004 Plan, DHS 

headquarters and regional offices, and state emergency management and 

homeland security offices—noted that DHS intended to initiate a 

comprehensive stakeholder review of the 2004 Plan in the fall of 2006. 

Accordingly, DHS developed a work plan to manage the revision of the 

2004 Plan that established (1) the issues that were to be the focus of the 

revision process, (2) the entities to be created to implement the process 

and the tasks involved, and (3) a timeline for completing the revision 

process and issuing the final document. DHS based its work plan for 

revising the 2004 Plan on guidance found in the Plan itself. Anticipating 

that modifications or updates would arise when needed, the 2004 Plan 

included a section specifying how DHS would conduct interim changes 

and full revisions, listing the time frames and circumstances—within the 

first year and every 4 years, or more frequently if the Secretary deems 

necessary, to incorporate new presidential directives, legislative changes, 

and procedural changes based on lessons learned from exercises and 

actual events. The Domestic Readiness Group, an interagency group that 

coordinates preparedness and response policy and is chaired by staff of 

the White House Homeland Security Council, approved DHS’s work plan 

in September 2006. For the revision process, the Domestic Readiness 

Group was to provide strategic policy coordination, be a mechanism for 

vetting the revision at the federal level, and was to resolve conflicting 

policy issues. 

 15 According to the December 2004 National Response Plan, a Notice of Change for 

updates to the Plan must specify the date, number, subject, purpose, background, and 

action required and provide the change language on one or more numbered and dated 

insert pages that would replace the modified pages in the Plan. Once published, the 

modifications were to be considered part of the Plan for operational purposes pending a 

formal revision and reissuance of the entire document. 

16 There were 32 signatories to the 2004 National Response Plan—the heads of 15 federal 

departments, plus the Central Intelligence Agency, Environmental Protection Agency, FBI, 

Federal Communications Commission, General Services Administration, NASA, National 

Transportation Safety Board, Nuclear Regulatory Commission, Office of Personnel 

Management, Small Business Administration, Social Security Administration, Tennessee 

Valley Authority, U.S. Agency for International Development, U.S. Postal Service, American 

Red Cross, Corporation for National and Community Service, and National Voluntary 

Organizations Active in Disaster. 

DHS Created a Work Plan 

to Revise the 2004 

National Response Plan, 

Specifying Revision Issues, 

Entities and Tasks, and a 

Time Line for Completing 

the Revision 
Page 11 GAO-08-768 FEMA's National Response Framework 

The work plan contained an initial list of 14 revision issues. According to 

FEMA officials, they compiled these issues by reviewing Hurricane Katrina 

after-action and lessons-learned reports from the White House, Congress, 

GAO, and the DHS Inspector General and identifying common issues that 

were raised in multiple reports. According to the work plan, DHS was to 

conduct meetings with selected stakeholders to review the initial list and 

identify other issues to be considered during the revision process. The 

result of these meetings was to be a finalized list of revision issues that 

would serve as the starting point for revising the 2004 Plan. 

Based on the 2004 Plan, DHS created three entities to facilitate the 

revision process: the Steering Committee, the Writing Team, and 12 Work 

Groups.17 DHS provided a copy of the approved work plan to all 

participants. The Steering Committee was to conduct the day-to-day 

management and oversight of the 2004 Plan revision process, which 

included managing the Work Groups and overseeing the Writing Team. 

The work plan assigned overall management of the 2004 Plan rewrite to 

the Writing Team, which was to assign issues to the Work Groups and 

track the Work Groups’ progress on resolving the assigned issues. The 

Work Groups, which were chaired by designated co-leaders, were to 

examine the issues received from the Writing Team and determine if 

existing language in the 2004 Plan adequately addressed the issues. If the 

Work Groups determined that current language in the 2004 Plan did not 

adequately address the issue, they were required to provide 

recommendations to the Writing Team on how the issues should be 

addressed. Figure 2 shows the relationship between the entities involved 

in the revision process. 

 17 The work plan also established a fourth entity, the Interagency Task Force. The work 

plan primarily charged the Task Force with resolving conflicts in preparedness and 

response policy before these conflicts were presented to the Domestic Readiness Group 

for resolution. 
Page 12 GAO-08-768 FEMA's National Response Framework 

Figure 2: Relationship among Entities within the September 2006 Revision Work Plan 

a

The work plan referred to the FEMA Administrator by his former title, which was the Under Secretary 

for Federal Emergency Management. 

b

Most of the DHS preparedness functions became part of FEMA as part of the Post-Katrina Act, and 

the transfer of these responsibilities became effective on March 31, 2007. 

The revision schedule in the work plan was to begin in December 2006 

with a goal to complete the revision process by June 2007. As a first step in 

the plan, the Writing Team was to provide the Work Groups with writing 

assignments. Once the Work Groups completed their writing assignments, 

the Writing Team was to review their recommendations and submit a draft 

of the revised NRF to the Steering Committee for its review and approval. 

The Steering Committee was to release the first draft of the revised NRF 

for stakeholder comment by the end of January 2007 with an approximate 

30-day review period. According to the work plan, the Steering Committee, 

Writing Team, and Work Groups would review comments on this first 

Secretary of Homeland Security

Overall responsibility for 2004 Plan Revision

● FEMA Administratora

● National Integration Center 

Steering Committee

● Day-to-day management and oversight of the revision process

● Management of the Work Groups and oversight of the Writing Team 

Work Groups

● Examined writing issues to determine if existing language in

 document was adequate

● If existing language deemed inadequate, provided recommended

 changes to Writing Team

Writing Team

● Overall management of the rewrite

● Assigned and tracked writing issues to Work Groups

Homeland Security Council Chaired

 Domestic Readiness Group

● Provide strategic policy coordination

● Mechanism for vetting the revision at the federal level 

● Resolve conflicting policy issues

Source: GAO analysis of DHS data.

● Undersecretary for Preparednessb
Page 13 GAO-08-768 FEMA's National Response Framework 

draft, make any needed modifications, and release a second draft at the 

end of March 2007 for the final of two 30-day comment periods. Per the 

work plan, these two comment periods would ensure wide dissemination 

of the product to all stakeholders, including federal agencies, state and 

local governments, and major professional associations. The work plan 

schedule also included a 2-month internal, federal review process to take 

place beginning in May 2007, after which DHS would provide the final 

draft for approval to the Domestic Readiness Group and the signatories of 

the 2004 Plan, with the final issuance of the revised 2004 Plan targeted for 

June 2007. See figure 3 for the proposed timeline for the revision process. 

Figure 3: DHS’s Revision Process as Planned by Its September 2006 Work Plan and as Required by the October 2006 PostKatrina Act 

DHS included non-federal stakeholders in the early stages of the 2004 Plan 

revision process in accordance with the work plan. For example, in 

October 2006, DHS hosted a meeting with approximately 90 non-federal 

stakeholders where DHS sought feedback on the 14 revision issues from 

participants using structured breakout groups. At this meeting, FEMA 

reported that non-federal stakeholders identified the need for 

enhancements to the 2004 Plan to further describe coordination processes 

with the private sector and volunteer organizations. DHS held a similar 

meeting with federal stakeholders in November 2006. According to DHS, it 

DHS Included Non-Federal 

Stakeholders at the 

Beginning of the Revision 

Process 

Publish 

revised plan

Approved

revision 

work plan

Start 

revision

process

Release 

second draft to 

stakeholders

Establish

NAC

Hold 

stakeholder 

meetings

Post-Katrina

Act enacted

Release 

first draft to 

stakeholders

Conduct internal 

federal review 

2006 2007 2008

Sept. Oct. Nov. Dec. Jan. Feb. Mar. Apr. May June July Aug. Sept. Oct. Nov. Dec. Jan.

Source: GAO analysis of DHS data, and the Post-Katrina Act.
Page 14 GAO-08-768 FEMA's National Response Framework 

modified the scope of some of the 14 revision issues and added three 

additional issues. (See app. II for a listing of the 17 revision issues.) 

DHS assigned non-federal stakeholders to serve as members of the 

Steering Committee and the Work Groups. Although the work plan called 

for the engagement of all levels of stakeholders in the revision process and 

described the Steering Committee and Work Groups, it did not specify the 

composition of the Work Groups but stated that one non-federal 

stakeholder would serve on the Steering Committee. In the spirit of the 

plan, DHS selected non-federal officials to serve on the Steering 

Committee and Work Groups. Of the 32 members on the Steering 

Committee, six members or 19 percent were non-federal officials, 

including representatives from state and local government emergency 

management associations as well as a local fire department and police 

associations. According to a FEMA official, the Steering Committee, led by 

FEMA and DHS co-chairs, generally met on a weekly basis via 

teleconferences throughout the revision process. 

Of the approximately 710 members who served on the 12 Work Groups, 

224 officials, or 32 percent, were non-federal officials, including 3 of the 27 

Work Group co-leaders.18 These non-federal officials included 

representatives from state and local emergency management agencies and 

tribal governments as well as officials from the fire, law enforcement, and 

public health sector. See figure 4 for the composition of the 12 Work 

Groups members by level of government, nongovernmental organization, 

and private sector. See appendix III for a listing of the 12 Work Groups and 

a table showing the occupational demographics of the non-federal 

stakeholders who served on the Work Group. 

 18 Some Work Groups had one leader and others had two or three co-leaders. 
Page 15 GAO-08-768 FEMA's National Response Framework 

Figure 4: Composition of the 710 Members of the 12 Work Groups by Federal, State, 

Local, and Tribal Government, Nongovernmental Organization, and Private Sector 

Note: There was some uncertainty in the exact total number of Work Group members due to 

duplication and lack of identifying information in the data FEMA provided. However, because the 

inclusion of non-federal stakeholders is the focus of this report, we took steps to correctly determine 

the total number and composition of the non-federal Work Group members. 

The Writing Team, which consisted of 11 federal officials and private 

contractors for administrative support, did not include any non-federal 

stakeholders. DHS stated that they invited one non-federal stakeholder to 

be on the team but that they were not successful in their attempts to 

secure that person. 

The 12 Work Groups met in January and February 2007. During that time, 

and in accordance with the work plan, the Work Groups met to address 

the issues assigned to them by the Writing Team. Most Work Groups 

addressed their issues by submitting recommended language changes to 

the 2004 Plan, which generally consisted of inserting new language or 

clarifying existing language. The Work Groups supported a recommended 

language change by providing the rationale for such a change. For 

example, the Writing Team tasked the Roles and Responsibilities Work 

Group with clarifying and strengthening the role of state governments in 

the 2004 Plan. One recommended language change suggested by this Work 

Group was to describe the state government’s role in the coordination of 

resources through the Emergency Management Assistance Compact, an 

5%

9%

68%

5%

11% Nongovernmental organization

- 79 members

Federal government - approximately 486 

members

State government - 67 members

Local government - 35 members

Private sector - 34 members

Tribal government - 9 members

Source: GAO analysis of DHS data.
Page 16 GAO-08-768 FEMA's National Response Framework 

interstate mutual aid compact that provides a legal structure through 

which affected states may request assistance from other states during a 

disaster.19

All Work Group recommendations were due to the Writing Team by the 

middle of February 2007. Although the work plan provided for the Work 

Groups’ continued involvement after submitting their recommendations, 

this did not occur. 

On March 13, 2007, DHS officials e-mailed stakeholders that the release of 

the first revision draft for the first 30-day comment period was being 

delayed. According to the message, DHS still planned to release the draft 

within the next several weeks and issue a final document by June 1, 2007. 

The message noted that once an updated timeline was approved, DHS 

would share the dates with the stakeholders. 

According to FEMA officials, the first draft of the revised 2004 Plan was 

completed in April 2007 and incorporated many of the Work Groups’ 

recommendations. However, rather than sending this first draft to 

stakeholders for comment, DHS conducted its internal, federal review of 

the draft document for approximately 5 months until September 2007. 

FEMA officials said that DHS did not release this April 2007 draft for 

comment because the draft required further modifications DHS considered 

necessary. An April 11, 2007, notice subsequently posted on DHS’s Web 

site described the status of the process and its plans to further revise the 

draft for comment. 

“As the NRP revision process unfolded, it became apparent that some important issues 

were more complex than we originally thought and require national-level policy decisions. 

We also came to the realization that creating a more user-friendly document that clearly 

addressed the roles and responsibilities of stakeholders and incident management 

structures would require substantial format changes to the NRP... An updated timeline has 

not been determined but we will share one with you quickly.” 

FEMA officials said that the length of time for the review and approval 

process, about 3 months longer than planned, was unpredictable and that 

it took longer than they had expected. DHS did not modify or update the 

 19 GAO reported on this state-level compact in GAO, Emergency Management Assistance 

Compact: Enhancing EMAC’s Collaborative and Administrative Capacity Should 

Improve National Disaster Response, GAO-07-854 (Washington, D.C.: June 29, 2007). 

DHS Departed from the Work 

Plan by Conducting an Internal 

Federal Review Rather Than 

Providing a Draft to NonFederal Stakeholders for 

Comment 
Page 17 GAO-08-768 FEMA's National Response Framework 

work plan to reflect this deviation from the approved revision process or 

propose how the revision process would now be completed. 

Certain non-federal stakeholders we interviewed who served on the 

Steering Committee and as co-leaders on the Work Groups reported 

receiving occasional or no communication from DHS on the decision not 

to release the first draft for comment or how the revision process would 

be completed during this internal, federal review process. FEMA’s Deputy 

Administrator acknowledged that the federal government should have 

done a better job in communicating the status of the draft and the revision 

process to non-federal stakeholders while the document was undergoing 

the internal, federal review. 

During this internal, federal review, DHS and FEMA officials continued to 

revise the April 2007 draft. For example, FEMA officials said that they 

added a chapter to explain the need for all levels of government to plan for 

preparedness and response actions and additional language to clarify the 

role of state and local governments during disaster response. At this point 

in the process, around August 2007, DHS’s Office of the Deputy Secretary20

decided to release a revised draft just to the Steering Committee and the 

Domestic Readiness Group for comment. Writing Team officials assumed 

that the Deputy Secretary would make the final decision on whether to 

incorporate the comments received while staff from his office would be 

responsible for completing any further edits. A draft of this document, 

dated July 2007, was leaked to the press in August 2007. 

During a September 11, 2007, hearing before the House Transportation and 

Infrastructure Committee,21 officials representing state and local 

emergency management associations expressed their concerns that the 

July 2007 leaked draft had changed significantly from the April 2007 draft. 

The government affairs committee chair of the International Association 

 20 The DHS Deputy Secretary at the time resigned from his position in October 2007. 

21 Readiness in the Post-Katrina and Post-9/11 World, Hearing of U.S. House 

Representatives, Committee on Transportation and Infrastructure, Subcommittee on 

Economic Development, Public Buildings, and Emergency Management, Sept. 11, 2007. The 

purpose of this hearing was to explore the process for revising the 2004 National Response 

Plan. 
Page 18 GAO-08-768 FEMA's National Response Framework 

of Emergency Managers22 testified, “The document we saw bore no 

resemblance to what we had discussed so extensively with FEMA and 

other stakeholders in the December 2006 through February 2007 timeline.” 

Additionally, the National Emergency Management Association23

representative, who served on the Steering Committee, expressed his 

concern that its association had been effectively shut out of the process, 

testifying that the collaborative process in rewriting the 2004 Plan “broke 

down...with no stakeholder input, working group involvement, or steering 

committee visibility.” 

After the approximate 5-month internal, federal review period, DHS 

released a draft of the newly renamed National Response Framework for 

public comment on September 10, 2007. However, as we stated earlier, the 

original work plan called for DHS to provide stakeholders with two 30-day 

public comment periods before the internal, federal review; after the 

review, DHS was to publish the revised document without further 

comment by stakeholders. The public comment period starting on 

September 10 allowed for both federal and non-federal stakeholders to 

provide their reactions to the changes made during the internal federal 

review process. FEMA officials said they conducted this unplanned public 

comment period to address the work plan’s requirement that the draft 

NRF be widely disseminated for all stakeholders to review. FEMA 

provided a 40-day public comment period for the NRF core document. 

FEMA received 3,318 comments on the core NRF. 24

The Writing Team led the adjudication—review, analysis, and resolution—

of the comments received during the public comment period. The Writing 

 22 The International Association of Emergency Managers is a non-profit educational 

organization of emergency managers and disaster response professionals from all levels of 

government, as well as the military, the private sector and volunteer organizations in 58 

countries, with the mission to serve its members by providing information, networking and 

professional opportunities, and to advance the emergency management profession. 

23 The National Emergency Management Association is a nonprofit, nonpartisan association 

of emergency management and homeland security professionals with a mission to provide 

national leadership and expertise in comprehensive emergency management; serve as a 

vital emergency management information and assistance resource; and advance 

continuous improvement in emergency management through strategic partnerships, 

innovative programs, and collaborative policy positions. 

24 FEMA also released NRF’s supplemental materials—including the Emergency Support 

Function Annexes, the Support Annexes, and the Incident Annexes—for a 30-day public 

comment period and received 2,385 comments on these documents. See appendix II for 

descriptions of these NRF supplemental materials. 

After the Internal, Federal 

Review, DHS Provided All 

Stakeholders an Opportunity to 

Comment before Final 

Publication and Considered All 

Comments in Finalizing the 

New Framework 
Page 19 GAO-08-768 FEMA's National Response Framework 

Team examined each comment, made an initial disposition 

recommendation—accepted, modified, rejected, or noted—and forwarded 

that recommendation to the FEMA leadership and the Domestic Readiness 

Group for review. In addition, FEMA posted a spreadsheet on 

www.regulations.gov that included, among other things, the comments 

made by non-federal stakeholders and the final disposition FEMA assigned 

to each of those comments. This allowed these stakeholders to see how 

FEMA did or did not incorporate their comments into the final NRF 

document. The Work Groups and Steering Committee, both of which 

contained non-federal stakeholders, were not involved in adjudicating the 

public comments, although this was called for by the work plan. A FEMA 

official said that the agency tried to recruit a non-federal stakeholder to 

serve on the Writing Team, but that its efforts were unsuccessful. 

The Post-Katrina Act required the DHS Secretary to establish a National 

Advisory Council (NAC) by December 2006 to advise the FEMA 

Administrator on all aspects of emergency management. Among its 

specific responsibilities, the NAC was to incorporate input from state, 

local, and tribal governments as well as the private sector in the revision of 

the 2004 Plan. The Act stated that the membership of the NAC should 

represent a geographic and substantive cross-section of officials, 

emergency managers, and emergency response providers, such as law 

enforcement, fire service, health scientists, and elected officials. However, 

DHS did not incorporate the NAC by amending its approved September 

2006 work plan for revising the 2004 Plan or establish the NAC in time for 

the Council to incorporate non-federal stakeholder input into the revision 

of the 2004 Plan, as directed by the October 2006 Post-Katrina Act. 

According to a FEMA official, DHS did not amend the work plan to 

incorporate the NAC because of the uncertainty surrounding the time it 

would take to establish the NAC. The official said FEMA expected that 

establishing the NAC would take more time than the Post-Katrina Act 

allowed because FEMA wanted to ensure that the NAC’s membership 

complied with the requirements contained in the Post-Katrina Act while 

also providing adequate time to announce the NAC’s creation, solicit 

applications for membership, and review and select applicants for 

membership. FEMA announced the membership of the NAC in June 2007, 

6 months after the Post-Katrina Act deadline, and the NAC did not hold its 

inaugural meeting until October 22, 2007, the last day of the public 

comment period for the base NRF. According to the FEMA Administrator, 

it was more important for the agency to invest the time needed to review 

hundreds of applications and create a high quality body of advisors than to 

DHS’s Establishment of the 

National Advisory Council 

Did Not Meet Post-Katrina 

Act Deadlines, Which Also 

Limited Collaboration with 

Non-Federal Stakeholders 
Page 20 GAO-08-768 FEMA's National Response Framework 

rush the process to meet the 60-day statutory deadline for establishing the 

NAC. 

As a result, the NAC’s only involvement in the NRF revision process 

occurred when FEMA provided it with a copy of a draft in December 2007, 

2 months after the public comment period closed. According to the NAC 

chairman, the NAC gathered and consolidated comments from individual 

members and provided these comments to the FEMA Administrator 

approximately one month before FEMA published the NRF in January 

2008.25 The chairman noted that these comments were from individual 

members and did not reflect the official comments of the NAC as a whole. 

For the next NRF revision, the chairman stated that he expected the NAC 

to be actively involved with FEMA throughout the entire revision process. 

For example, he suggested that the NAC could have a role in the 

adjudication of public comments by representing non-federal stakeholders 

during the adjudication process to ensure FEMA is aware of issues that are 

critically important to state and local governments. The NAC is currently 

exploring its role in reviewing and implementing the 2008 NRF. For 

example, at the NAC’s February 2008 meeting the NAC Chairman 

approved a standing committee on the NRF that may focus on actions that 

can help FEMA implement and train stakeholders on the NRF. While the 

NAC filed a charter on February 6, 2007, the charter reflects the NAC’s 

broad array of statutory responsibilities, but does not detail any specific 

responsibilities the NAC would undertake relative to the NRF revision 

process. See figure 5 for a comparison of DHS’s actual revision process 

with its proposed process. 

 25 NAC submitted comments by using the form that FEMA asked the public to use when 

submitting comments on www.regulations.gov. 
Page 21 GAO-08-768 FEMA's National Response Framework 

Figure 5: DHS’s Actual Revision Process Compared with Its Proposed Process 

The late establishment of the NAC also hindered FEMA from fully 

collaborating with non-federal stakeholders who were involved in the 

revision process established by the approved work plan. In particular, two 

non-federal Steering Committee members stated that after the August 2007 

leak of the draft NRF, FEMA stopped sharing drafts with non-federal 

officials. FEMA officials said that the reason for this decision was because 

DHS’S ACTUAL REVISION PROCESS

Approved

revision 

work plan

Started 

revision

process

Conducted 

internal federal 

review of first draft 

Publish 

revised plan

Released first 

draft for public

comments

Published 

NRF 

Produced first draft 

but did not release 

to stakeholders

Held 

stakeholder 

meetings

Post-Katrina

Act enacted 

Announced

NAC membership

Congressional

hearing on 

revision process

Adjudicated 

public comments

NAC reviewed 

a draft NRF

Approved

revision 

work plan

Start 

revision

process

Release 

second draft to 

stakeholders

Establish

NAC

Hold 

stakeholder 

meetings

Post-Katrina

Act enacted

Release 

first draft to 

stakeholders

Conduct internal 

federal review 

DHS’S REVISION PROCESS BY WORK PLAN AND POST-KATRINA ACT 

2006 2007 2008

Sept. Oct. Nov. Dec. Jan. Feb. Mar. Apr. May June July Aug. Sept. Oct. Nov. Dec. Jan.

Source: GAO analysis of DHS data, and the Post-Katrina Act.
Page 22 GAO-08-768 FEMA's National Response Framework 

FEMA had yet to establish the NAC, its official advisory committee. FEMA 

officials said that the absence of an official advisory committee raised 

fairness concerns about which members of the non-federal community 

should be allowed to provide input before the public comment period. As a 

result, FEMA stopped sharing pre-decisional drafts with non-federal 

members of the Steering Committee because FEMA did not plan to 

provide the same opportunity to other non-federal stakeholders until the 

public comment period. 

While FEMA has recognized the importance of partnering with non-federal 

stakeholders to achieve the nation’s emergency management goals, both in 

congressional testimonies as well as in its January 2008 strategic plan, 

FEMA has not yet developed guidance and procedures for how future 

revisions of the NRF will be managed or how the newly established 

National Advisory Council will be integrated into the revision process in 

accordance with the Post-Katrina Act. Standards for Internal Control in 

the Federal Government state that management guidance, policies, and 

procedures are an integral part of any agency’s planning for, and 

achieving, effective results.26 Developing such policies and procedures for 

how the NRF will be revised in the future and how FEMA will integrate the 

NAC and other non-federal stakeholders in the process is essential for 

helping to ensure that FEMA attains its goal of partnering with nonfederal 

stakeholders to help achieve the nation’s emergency management goals. 

 26 GAO, GAO/AIMD-00-21.3.1. 

FEMA and the PostKatrina Act Have 

Recognized the 

Importance of 

Including Non-Federal 

Stakeholders in 

Developing National 

Response Doctrine, 

but FEMA Lacks 

Guidance and 

Procedures for Future 

NRF Revisions 
Page 23 GAO-08-768 FEMA's National Response Framework 

FEMA has recognized the importance of including the input of non-federal 

stakeholders to help achieve the nation’s emergency management goals. 

For example, in November 2006, the FEMA Administrator outlined his 

vision for a “New FEMA,”27 asserting FEMA’s dedication to partnering with 

all states and the private sector because of FEMA’s reliance on its partners 

to accomplish the national emergency response objectives. More recently, 

in congressional testimonies the FEMA Administrator has reaffirmed the 

need for FEMA to partner with both federal and non-federal 

stakeholders.28 In addition, one objective in FEMA’s Strategic Plan for 

2008-2013 is to engage public and private stakeholders in developing and 

communicating clear national doctrine and policy.29 To achieve this 

objective, the Strategic Plan identifies the need to engage stakeholders 

early and often in the process of developing national doctrine. This is in 

accordance with internal control standards for the federal government 

that state that information should be communicated to those who need it 

and in a form and within a time frame that enables them to carry out their 

responsibility for an agency to achieve its objectives.30 For example, 

management should ensure there are adequate means of communicating 

with and obtaining information from external stakeholders who may have 

a significant impact on the agency’s achieving its goals. In October 2005, 

we also reported that frequent communication among collaborating 

organizations and stakeholders is a means to facilitate working across 

boundaries, prevent misunderstanding, and achieve agency objectives.31

Frequent communication is one of a number of practices that enhance and 

sustain collaboration. 

 27 Federal Emergency Management Agency, Director Paulison Lays Out Vision for “New 

FEMA,” Press Release FNF-06-019 (November 2006). 

28 “Reforming FEMA: Are We Making Progress?” R. David Paulison statement for the record 

before the United States House of Representatives, House Homeland Security Committee, 

Subcommittee on Emergency Communications, Preparedness, and Response and 

Subcommittee on Management, Investigations, and Oversight, February 28, 2007; and “The 

2007 Hurricane Season: Are We Prepared?” R. David Paulison Oral Statement Before the 

United States House of Representatives, House Homeland Security Committee, 

Subcommittee on Emergency Communications, Preparedness, and Response, May 15, 2007. 

29Federal Emergency Management Agency, FEMA Strategic Plan Fiscal Years 2008-2013: 

The Nation’s Preeminent Emergency Management and Preparedness Agency, FEMA P422 (January 2008). 

30 GAO, GAO/AIMD-00-21.3.1. 

31 GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: October 2005). 

FEMA and the PostKatrina Act Stress 

Partnership and 

Communication with NonFederal Stakeholders in 

Achieving the Nation’s 

Emergency Management 

Goals 
Page 24 GAO-08-768 FEMA's National Response Framework 

Recognizing the importance of collaboration, the Post-Katrina Act requires 

that the FEMA Administrator partner with non-federal stakeholders from 

state, local, and tribal governments, the private sector, and 

nongovernmental organizations to build a national system of emergency 

management that can effectively and efficiently utilize the full measure of 

the nation’s resources to respond to all disasters, including catastrophic 

incidents, and acts of terrorism.32 Specifically, the Post-Katrina Act directs 

the FEMA Administrator, through the National Integration Center, to 

periodically review and revise the National Response Plan and any 

successor to such plan and, as discussed above, to establish the NAC to 

incorporate non-federal stakeholder input in the revision and development 

of the Plan, among other things. The Post-Katrina Act further directs the 

FEMA Administrator to appoint council members who represent a 

geographic and substantive cross section of officials, emergency 

managers, and emergency response providers from the non-federal 

community. 

The FEMA Administrator’s statements, the agency’s latest strategic plan, 

and the Post-Katrina Act also reflect a key precept related to government 

performance and results—that stakeholders can have a significant effect 

in determining whether a federal agency’s program or action will succeed 

or fail, and as such, stakeholders need to be involved in major planning 

efforts conducted by the agency.33 Such involvement is important to help 

agencies ensure that their efforts and resources are targeted at the highest 

priorities and is particularly important in instances where federal agencies 

face a complex political environment, such as emergency management in 

which FEMA’s successes depend on the actions of non-federal partners at 

the state and local levels. 

 32 The Post-Katrina Act, Pub. L. No. 109-295, § 611, 120 Stat. 1355, 1396-1397 (amending the 

Homeland Security Act, § 503(b)(2)(B). 

33 GAO, Executive Guide: Implementing the Government Performance and Results Act, 

GAO/GGD-96-118 (Washington, D.C.: June 1996). 
Page 25 GAO-08-768 FEMA's National Response Framework 

While FEMA officials and the National Response Framework

acknowledge that the NRF will need to be revised in the future, FEMA has 

not developed guidance or policies on how it will manage future revisions 

or described how the NAC will be incorporated into the next NRF revision 

process. FEMA officials said that the agency has not yet developed 

guidance and procedures for any future NRF revisions because of the need 

to focus federal resources on creating training materials to assist all 

stakeholders in implementing the current NRF in anticipation of the 

pending 2008 hurricane season. As mentioned earlier in this report, the 

2004 Plan included a section specifying the circumstances, such as lessons 

learned from exercises and actual events, and time frames under which it 

would need to be reviewed and revised. This section is in accordance with 

the federal internal control standard of monitoring operations to assess 

the quality of performance over time and ensure that the findings of 

reviews and evaluations are resolved. The 2008 NRF, while it states that it 

merits periodic review and revision, does not contain such language 

regarding the circumstances and time frames for its review and revision. In 

addition, FEMA officials said that the process established for the last 

revision (the 2006-approved work plan) would not be applicable for any 

future revisions because it did not consider the role of the NAC. The NAC 

has also not yet determined how it would like to be involved in the next 

NRF revision process. The NAC’s charter, approved in February 2007, does 

not provide specific procedures on how it is to be involved and, according 

to the chairman, the NAC’s NRF subcommittee expects to focus its efforts 

on helping FEMA train non-federal stakeholders. 

Having such guidance and procedures in place is an important internal 

control, and we have identified this need for other agencies in similar 

circumstances to FEMA’s management of future NRF revisions. As we 

discussed earlier in this report, control activities—such as guidance, 

policies, and procedures—are an integral part of an agency’s planning for 

and achieving effective results.34 In addition, while internal controls should 

be flexible to meet an agency’s needs, they should also be clearly 

documented, readily available, and properly maintained. We have also 

previously reported on the need to include state and local jurisdictions in 

the development of national response plans because they are key 

stakeholders and would be on the front lines if an incident occurs. 

 34 GAO, GAO/AIMD-00-21.3.1. 

FEMA Has Not Yet 

Developed Guidance and 

Procedures for Managing 

Future Revisions or 

Integrating the National 

Advisory Council into the 

Revision Process 
Page 26 GAO-08-768 FEMA's National Response Framework 

• In April 2008, we reported on the need for the Department of Defense’s 

Northern Command to collaborate and communicate with non-federal 

stakeholders and establish a process to guide such collaboration in 

accessing information on state emergency response plans and capabilities, 

noting that the absence of effective collaboration could impede 

intergovernmental planning for catastrophic incidents and overall 

coordination.35 Specifically, we reported that federal officials involved the 

states only minimally in the development of the Department of Defense’s 

major homeland defense and civil support plans and that defense officials 

were generally not familiar with state emergency response plans and 

capabilities and had not established a process for gaining access to this 

information. We also reported that each agency’s roles and responsibilities 

for planning for homeland defense and civil support during a catastrophic 

disaster were not clearly defined. We recommended, among other things, 

that the Department of Defense develop a thorough process to guide its 

coordination with the states. The department generally agreed with the 

recommendation and stated that it was coordinating with DHS to develop 

synchronized plans of integrated federal, state, and local operational 

capabilities to affect a coordinated national response. It is essential for 

both the Department of Defense and DHS to have such guidance in place, 

as both DHS’s National Response Framework and the Northern 

Command’s Concept of Operations emphasize coordination with nonfederal stakeholders in order to prevent, prepare for, respond to, and 

recover from catastrophic natural and manmade disasters. 

• In August 2007, we reported on the administration’s approach to preparing 

for a pandemic influenza by issuing, among other things, a National 

Strategy for Pandemic Influenza (Strategy) in November 2005, and a 

National Strategy for Pandemic Influenza Implementation Plan (Plan) 

in May 2006.36 We reported, among other things, that state and local 

jurisdictions were not directly involved in developing the Strategy and 

Plan. Neither the Strategy nor Plan described the involvement of key 

stakeholders, such as state, local, and tribal entities, in their development, 

even though these stakeholders would be on the front lines in a pandemic 

and the Plan identifies actions they should complete. Officials told us that 

 35 GAO, Homeland Defense: Steps Have Been Taken to Improve U.S. Northern Command’s 

Coordination with States and National Guard Bureau, but Gaps Remain, GAO-08-252 

(Washington, D.C.: Apr. 16, 2008). 

36 GAO, Influenza Pandemic: Further Efforts are Needed to Ensure Clearer Federal 

Leadership Roles and Effective National Strategy, GAO-07-781 (Washington, D.C.: Aug. 14, 

2007). See also GAO, Influenza Pandemic: Opportunities Exist to Clarify Federal 

Leadership Roles and Responsibilities and Improve Pandemic Planning, GAO-07-1257T 

(Washington, D.C.: Sept. 26, 2007). 
Page 27 GAO-08-768 FEMA's National Response Framework 

while the drafters of the Plan were generally aware of their concerns, 

state, local, and tribal entities were not directly involved in reviewing and 

commenting on the Plan. We concluded that opportunities existed to 

improve the usefulness of the Plan because it was viewed as an evolving 

document and was intended to be updated on a regular basis to reflect 

ongoing policy decisions as well as improvements in domestic 

preparedness. However, time frames or mechanisms for updating the Plan 

were undefined. We recommended that the White House Homeland 

Security Council establish a specific process and time frame for updating 

the Plan and that the update process should involve key non-federal 

stakeholders and incorporate lessons learned from exercises and other 

sources, but the Homeland Security Council did not provide comments on 

this recommendation. 

Without similar policies and procedures documenting the circumstances 

and time frames under which it would review and revise the NRF and its 

process for collaborating with non-federal stakeholders, FEMA cannot 

ensure that future revision processes will be conducted in accordance 

with management’s directives. 

All disasters occur locally, and the initial post-disaster response is local. 

However, large-scale disasters usually exceed local response capabilities. 

Effective preparation and response for major and catastrophic disasters 

require well-planned and well-coordinated actions among all those who 

would have a role in the response to such disasters. The 2008 NRF is a 

guide for the myriad of entities and personnel involved in response efforts 

at all levels. The NRF recognizes the need for collaboration among these 

stakeholders to collectively respond to and recover from all disasters, 

particularly catastrophic disasters such as Hurricane Katrina, regardless of 

their cause. 

To help ensure that the NRF meets the needs of all stakeholders who have 

a role in its effective implementation, it is essential that DHS fully 

collaborate with non-federal stakeholders in its development and revision. 

DHS initially involved non-federal stakeholders in the revision of the 2004 

Plan but omitted a key step in its work plan by not obtaining and 

incorporating their comments on the first full draft. Instead, DHS 

undertook a closed, internal federal review of the draft that lasted about 5 

months with little communication with the non-federal partners. The 

result was a breach of trust with DHS’s non-federal partners in the drafting 

process. 

Conclusions 
Page 28 GAO-08-768 FEMA's National Response Framework 

The Post-Katrina Act gives responsibility for maintaining and updating the 

NRF to FEMA and charges the Administrator’s National Advisory Council 

with incorporating non-federal stakeholder input into the NRF’s 

development and revision. Established too late to fulfill this role in the 

creation of the current NRF, the NAC is now functioning, and it is 

important that there be compatible policies and procedures for how the 

NAC will fulfill its statutory charge. 

Contrary to effective government internal control and management 

principles, FEMA has not yet developed policies and procedures for 

guiding future revisions of the NRF, including specifying the conditions 

and time frames under which FEMA would review and revise the NRF and 

how FEMA will involve the NAC and collaborate with other non-federal 

stakeholders. Especially in view of a new administration, non-federal 

stakeholder participation and ownership is essential in any revision of the 

NRF, and the lessons learned from the process for revising the 2004 Plan 

will apply in the future to FEMA’s and DHS’s efforts to develop and revise 

other national plans and policies that make up the national preparedness 

system. While the NRF is published by DHS, it belongs to the nation’s 

emergency response community that is collectively responsible for 

effectively implementing the NRF’s provisions should another catastrophic 

disaster like Hurricane Katrina occur. 

We recommend that the FEMA Administrator develop and disseminate 

policies and procedures that describe (1) the circumstances and time 

frames under which the next NRF revision will occur and (2) how FEMA 

will conduct the next NRF revision, including how its National Advisory 

Council and other non-federal stakeholders—state, local, and tribal 

governments; the private sector; and nongovernmental organizations—will 

be integrated into the revision process and the methods for 

communicating with these stakeholders. 

We requested comments on a draft of this report from DHS and FEMA. 

They concurred with our recommendations and had no other comments. 

We are sending copies of this report to the Secretary of Homeland 

Security, FEMA Administrator, and interested congressional committees. 

We will also provide copies to others on request. If you or your staff have 

any questions about this report or wish to discuss the matter further, 

please contact me at (202) 512-8777 or jenkinswo@gao.gov. Contact points 

for our Offices of Congressional Relations and Public Affairs may be found 

Recommendation for 

Executive Action 

Agency Comments 
Page 29 GAO-08-768 FEMA's National Response Framework 

on the last page of this report. See appendix IV for a list of key 

contributors to this report. 

William O. Jenkins, Jr. 

Director, Homeland Security and Justice Issues 
Appendix I: Scope and Methodology 

Page 30 GAO-08-768 FEMA's National Response Framework 

This report addresses the following questions: (1) To what extent did the 

Department of Homeland Security (DHS) collaborate with non-federal 

stakeholders in revising and updating the December 2004 National 

Response Plan into the January 2008 National Response Framework

(NRF)? (2) To what extent has FEMA developed policies and procedures 

for managing future revisions of the NRF? 

To address these questions, we interviewed DHS, FEMA, and non-federal 

stakeholders who were directly involved in the revision and update of the 

2004 Plan into the 2008 NRF, and we reviewed DHS and FEMA documents 

on the revision process. Because there were over 700 federal and nonfederal officials who participated in the Steering Committee and Work 

Groups, we interviewed those who held key positions. The FEMA officials 

and non-federal stakeholders we interviewed held key positions in the 

revision process, such as the FEMA Administrator and Deputy 

Administrator and the two FEMA co-chairs of the Steering Committee. The 

non-federal stakeholders we interviewed included four of the five nonfederal officials who served as Steering Committee members and all three 

of the non-federal officials who served as co-leaders of Work Groups; 

these non-federal stakeholders also held positions in state, county, and 

city governments and non-governmental organizations. 

To determine the extent to which DHS collaborated with non-federal 

stakeholders, we first determined the revision process that DHS had 

planned to follow to revise the 2004 Plan. We reviewed DHS’s September 

2006 revision work plan that had been approved by the Domestic 

Readiness Group of White House’s Homeland Security Council and 

interviewed FEMA and non-federal officials who served in key positions in 

the revision process. We also reviewed applicable statutes, primarily the 

October 2006 Post-Katrina Emergency Management Reform Act, for 

statutory requirements related to the revision process. To determine what 

happened during the revision process and the extent to which DHS 

involved non-federal stakeholders in that process, we interviewed FEMA 

officials and non-federal stakeholders who served in key positions in the 

revision process and the chairman of FEMA’s National Advisory Council 

(NAC). Further, we reviewed DHS documentation citing the roles provided 

to non-federal stakeholders in the revision process and explaining how the 

actual revision process was conducted, FEMA documentation on the 

process and time frames related to the NAC’s establishment, NAC 

documentation regarding its role in the revision process, and 

congressional testimony from non-federal stakeholders on how DHS 

conducted and included them in the revision process. To determine the 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 31 GAO-08-768 FEMA's National Response Framework 

extent to which FEMA had policies and procedures in place for future 

revisions of the NRF, we interviewed FEMA officials. 

The non-federal officials we interviewed represented state and local levels 

of government, emergency management associations, and other nonfederal entities. While the statements and views of the stakeholders we 

interviewed are not generalizable to the some 230 non-federal 

stakeholders involved in the revision process, we chose to speak to them 

because of their assigned key roles. 

There is some uncertainty in our determination of the total number of nonfederal members in the 12 Work Groups, and thus the total number of 

Work Group members, due to duplication or the lack of adequate 

information identifying a member as federal in the data provided by 

FEMA. However, because DHS’s inclusion of non-federal members in the 

revision process is the focus of this report, we took steps to correctly 

determine the number and composition of the 224 non-federal members. 

Based on our analysis of FEMA’s data for federal members, we believe the 

total of 486 federal members is a reasonable approximation, and therefore, 

the grand total of 710 Work Group members is also a reasonable 

approximation.
Appendix II: The 17 Key Revision Issues That 

DHS Identified for the 2004 National 

Response Plan 

Page 32 GAO-08-768 FEMA's National Response Framework 

In the 2004 National Response Plan revision work plan approved by the 

Domestic Readiness Group, a White House Homeland Security Council–

chaired policy committee, in September 2006, DHS identified 14 key issues 

that it wanted the revision process to address. According to FEMA 

officials, these issues were compiled by reviewing Hurricane Katrina afteraction and lessons-learned reports from the White House, Congress, GAO, 

and DHS’s Inspector General and identifying common issues that were 

raised in multiple reports. The work plan directed DHS to conduct 

meetings with stakeholders to review the initial list and identify other 

issues to be considered during the revision process. These issues were to 

serve as the starting point from which the 2004 Plan revision would be 

conducted. DHS held meetings with non-federal stakeholder and federal 

stakeholders in October and November 2006 respectively. After these 

meetings, DHS identified three additional revision issues to its initial list 

contained in the approved work plan. The 17 key revision issues are listed 

below—the 3 issues added after the stakeholder meetings are indicated 

with a note. 

The revision issues are categorized by whether they were to be addressed 

in either the 2004 Plan base document or its annexes. The 2004 Plan 

comprised four major components: the Base Plan, Emergency Support 

Function Annexes, Support Annexes, and Incident Annexes. The Base 

Plan provided an overview of the structure and processes comprising a 

national approach to domestic response actions. The 15 Emergency 

Support Function Annexes detailed the missions, policies, structures, and 

responsibilities of federal agencies for coordinating resource and 

programmatic support, such as mass care and shelter, to states, tribes, and 

other federal agencies or other jurisdictions and entities. The nine Support 

Annexes provided guidance and described the functional processes and 

administrative requirements necessary to ensure the 2004 Plan’s efficient 

and effective implementation. The seven Incident Annexes addressed 

contingency or hazard situations requiring specialized application of the 

2004 Plan, such as biological, catastrophic, and nuclear/radiological 

incidents. 

The key revision issues identified for the 2004 National Response Plan

base document were 

• clarify roles and responsibilities of key structures, and positions, and 

levels of government; 

• strengthen role of states and private sector; 

Appendix II: The 17 Key Revision Issues That 

DHS Identified for the 2004 National 

Response Plan
Appendix II: The 17 Key Revision Issues That 

DHS Identified for the 2004 National 

Response Plan 

Page 33 GAO-08-768 FEMA's National Response Framework 

• integrate National Incident Management System concepts, principles, 

terminology, systems, and organizational processes into the revised 

National Response Plan; 

• review Joint Field Office structure and operations, to include Unified 

Command; and 

• incorporate proactive planning for incidents that render state and local 

governments incapable of an effective response. 

The key revision issues identified for the annexes to the 2004 National 

Response Plan base document were 

• examine all existing National Response Plan annexes and proposed new 

annexes, 

• strengthen External Affairs and Public Affairs Annexes; 

• review logistics management issues,1

• examine evacuation and sheltering issues,2

• ensure the integration of all search and rescue assets, 

• review the scope of public safety and security missions, 

• incorporate companion animal issues, 

• improve process for identifying and accepting donated goods and the 

integration of volunteers, 

• clarify international support mechanisms, 

• ensure consistency with National Emergency Communication Strategy, 

• refine the Catastrophic Incident Supplement to include the review of a 

possible increased Department of Defense responsibility, and 

• review federal incident management plans and determine their 

appropriate linkage to the National Response Plan.

3

 1

. This issue was added after DHS presented the initial 14 key revision issues identified in 

the work plan at stakeholder meetings with non-federal and federal stakeholders in 

October and November 2006. 

2

 See footnote 1. 

3

 See footnote 1. 
Appendix III: The 12 Work Groups DHS 

Established during the Revision Process and 

Their Composition 

Page 34 GAO-08-768 FEMA's National Response Framework 

The 2004 National Response Plan revision work plan approved by the 

Domestic Readiness Group in September 2006 directed DHS to establish 

Work Groups to rewrite portions of the 2004 Plan. While the work plan did 

not specify the number of Work Groups that should be established, DHS 

formed 12 Work Groups that were co-led by federal officials or a 

combination of federal and non-federal officials. The 12 Work Groups 

were 

• Catastrophic Planning, 

• Communications, 

• Companion Animals, 

• Evacuations and Sheltering (co-led by non-federal stakeholder), 

• Functions, 

• Incident Management and Coordination, 

• International Support, 

• National Incident Management System, 

• Roles and Responsibilities (co-led by non-federal stakeholder), 

• Special Needs, 

• Training and Implementation, and 

• Volunteer and Donation Management (co-led by non-federal stakeholder). 

Of the 709 members who served on the 12 Work Groups, 224 officials, or 

32 percent, were non-federal. These non-federal stakeholders included 

representatives from state, tribal, and local government as well as the 

private sector and nongovernmental organizations. Further, the nonfederal stakeholders came from various occupational sectors. See table 1 

for a description of these 224 non-federal stakeholders. 

Appendix III: The 12 Work Groups DHS 

Established during the Revision Process and 

Their Composition 
Appendix III: The 12 Work Groups DHS 

Established during the Revision Process and 

Their Composition 

Page 35 GAO-08-768 FEMA's National Response Framework 

Table 1: The 224 Non-Federal Stakeholders Who Participated in the Revision Work Groups by Occupational Sector and by 

Level of Government, Nongovernmental Organization, and Private Sector 

Level of government 

Occupational sectora Local Tribal State

Nongovernmental 

organization 

Private 

sector Total

Animal, plant and foodb 2 - 5 12 2 21

Critical infrastructurec 1 - - 3 11 15

Disaster assistance servicesd - - - 24 - 24

Elected government officials - 1 - - - 1

Emergency management and homeland securitye 7 7 40 8 4 66

Emergency medical providers and health sectorf 5 - 8 9 - 22

Fire and search and rescue 4 - - 3 - 7

General businessg - - - - 12 12

General governmenth 3 - - - - 3

Logistics and transportationi 1 - 1 2 3 7

Military and national security relatedj - - 3 - 2 5

Police and corrections 10 - 3 2 - 15

Special needs populationsk 1 - - 7 - 8

Standards and accreditation bodies - - - - - 0

Volunteerism and voluntary organizationsl - - 7 8 - 15

Unidentifiedm 1 1 - 1 - 3

Total non-federal stakeholders 35 9 67 79 34 224

Source: GAO analysis of FEMA data. 

a

We developed this list of occupational sectors based on our analysis and categorization of the 

entities these 224 non-federal stakeholders represented. 

b

Includes agriculture, animal control, animal health & welfare, food production and security, and 

veterinary associations. 

c

Includes communications, cybersecurity, information technology, public works, and water. 

d

Includes emergency food support, Red Cross, and religion-based assistance services. 

e

Includes business continuity, contingency planning, crisis management, and risk analysis. 

f

Includes emergency medical technicians, health officials, pharmacists and physicians associations; 

health departments and systems; and medical aviation. 

g

Includes Chambers of Commerce, commodities trading, general consulting firms, public relations, 

and trade associations. 

h

Includes cities association, city managers association, and city officials. 

i

Includes package delivery services, revenue collection, supply-chain management, and mass transit. 

j

Includes civilian air patrol, military affairs, and a national security related business association. 

k

Includes children, disabilities, and low income housing. 
Appendix III: The 12 Work Groups DHS 

Established during the Revision Process and 

Their Composition 

Page 36 GAO-08-768 FEMA's National Response Framework 

l

Includes national, state, and local agencies that coordinate individual volunteers or coordinate 

voluntary organizations. 

m

Unidentified means that we were able to determine the non-federal stakeholder’s level of 

government, nongovernmental organization, or the private sector, but we could not determine the 

stakeholder’s occupational sector. We excluded one unidentified non-federal stakeholder from this 

table for whom we could neither determine the individual’s occupational sector nor level of 

government, a nongovernmental organization, or the private sector. 
Appendix IV: GAO Contact and Staff 

Acknowledgments 

Page 37 GAO-08-768 FEMA's National Response Framework 

William O. Jenkins, Jr., (202) 512-8777 or jenkinswo@gao.gov 

The following teams and individuals made key contributions to this report: 

Pille Anvelt, Patrick Bernard, Sam Hinojosa, Christopher Keisling, David 

Lysy, Sally Williamson, and Candice Wright, Homeland Security & Justice 

Team; Michele Fejfar, Applied Research & Methods; and Christine Davis, 

Jan Montgomery, and Janet Temko, General Counsel. 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Acknowledgments 

(440657) 
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