NEXT GENERATION 

911

National 911 Program 

Could Strengthen 

Efforts to Assist States

Report to Congressional Requesters

January 2018

GAO-18-252
United States Government Accountability Office

Highlights of GAO-18-252, a report to 

congressional requesters

January 2018

NEXT GENERATION 911

National 911 Program Could Strengthen Efforts to 

Assist States

What GAO Found

The National Highway Traffic Safety Administration’s (NHTSA) National 911 

Program’s most recent national survey on Next Generation 911 (NG911) 

implementation indicated that about half of states were in some phase of 

transition to NG911 in 2015, but that state and local progress varied. Specifically, 

10 states reported that all 911 authorities in their state processed calls using 

NG911 systems; however, 18 states reported having no state or local NG911 

transition plans in place—which may indicate these states were in the early 

phases of planning for the transition to NG911 or had not yet begun. GAO spoke 

with state and local 911 officials in 9 states, which were in various phases of 

implementing NG911, and found that none of the 9 selected states were

accepting images, audio files, or video. State and local 911 officials identified a 

number of challenges to implementing NG911. Such challenges are related to 

funding, evolving technology and operations, and governance. For example, 

officials in 3 states said that the current funding they collect from telephone 

service subscribers may not be sufficient to support NG911’s transition costs 

while simultaneously funding the operation of existing 911 systems. 

Federal agencies—including NHTSA, the National Telecommunications and 

Information Administration, the Federal Communications Commission, and the 

U.S. Department of Homeland Security—have responsibilities to support NG911 

implementation, such as through coordinating activities and administering grants, 

and are taking actions to assist state and local entities in addressing challenges 

to NG911’s implementation. Such actions include developing resources, offering 

technical assistance, and convening stakeholders to explore emerging NG911

issues. For example, as the lead entity for coordinating federal NG911 efforts, 

NHTSA’s National 911 Program is developing resources on NG911 topics, such 

as federal funding and governance structures. While the National 911 Program is 

taking steps to facilitate the state and local transition to NG911, the program 

lacks specific performance goals and measures to assess its progress. Without 

such goals and measures, it is not clear to what extent the program is effectively 

achieving its mission.

In 2018, the National 911 Program plans to establish an interagency initiative 

tasked with creating a National NG911 Roadmap. This roadmap is intended to

identify next steps for the federal government in supporting the creation of a 

national, interconnected NG911 system. While the National 911 Program is 

taking steps to develop a list of national-level tasks as part of its roadmap 

initiative, the program does not have a plan to identify: (1) roles or 

responsibilities for federal entities to carry out these tasks or (2) how the program 

plans to achieve the roadmap’s objectives. Collaborating with the appropriate 

federal agencies to determine federal roles and responsibilities to carry out the 

roadmap’s national-level tasks could reduce barriers to agencies effectively 

working together to achieve those tasks. Furthermore, developing an 

implementation plan that details how the roadmap’s tasks will be achieved would 

place the National 911 Program in a better position to effectively lead 

View GAO-18-252. For more information, interagency efforts to implement NG911 nationwide. contact Mark Goldstein at (202) 512-2834 or 

goldsteinm@gao.gov.

Why GAO Did This Study

Each year, millions of Americans call 

911 for help during emergencies. 

However, the nation’s legacy 911 

system relies on aging infrastructure 

that is not designed to accommodate 

modern communications technologies.

As a result, states and localities are 

upgrading to NG911, which offers

improved capabilities, such as the 

ability to process images, audio files,

and video. While deploying NG911 is 

the responsibility of state and local 

entities, federal agencies also support 

implementation, led by NHTSA’s 

National 911 Program, which facilitates

collaboration among federal, state, and 

local 911 stakeholders. 

GAO was asked to review NG911 

implementation nationwide. This report 

examines: (1) state and local progress

and challenges in implementing 

NG911 and (2) federal actions to 

address challenges and planned next 

steps. GAO reviewed relevant statutes,

regulations, and federal agency reports

and plans. GAO also analyzed 

NHTSA’s survey data on state 911 

implementation for calendar year 2015, 

the most recent year for which data 

were available, and interviewed federal

officials, state and local officials from 

nine states (selected to represent 

different regions and various phases of 

NG911 implementation), and officials 

from industry and advocacy groups.

What GAO Recommends

GAO recommends that NHTSA’s

National 911 Program develop 

performance goals and measures and, 

for the National NG911 Roadmap,

determine agencies’ roles and 

responsibilities and develop an 

implementation plan. NHTSA agreed 

with GAO’s recommendations.
Page i GAO-18-252 Next Generation 911

Letter 1

Background 5

States and Localities Have Reported Varied Progress in 

Implementing NG911 and Identified Funding, Technology, and 

Governance Challenges 12

Federal Agencies Are Addressing NG911 Implementation 

Challenges, but the National 911 Program Lacks Measurable 

Goals and Next Steps for the NG911 Roadmap Initiative 18

Conclusions 24

Recommendations for Executive Action 25

Agency Comments 25

Appendix I Objectives, Scope, and Methodology 27

Appendix II Selected Federal Actions since 2013 to Address State and Local 

Challenges in Implementing Next Generation 911 (NG911), as of 

October 2017 30

Appendix III Comments from the U.S. Department of Transportation 32

Appendix IV GAO Contact and Staff Acknowledgments 33

Table

Table 1: Selected Federal Agencies’ Requirements Related to 

Next Generation 911 (NG911) 11

Figure

Figure 1: Overview of 911 Communications and Dispatch Process 7

Contents
Page ii GAO-18-252 Next Generation 911

Abbreviations

2012 Act Next Generation 911 Advancement Act of 2012 

DHS Department of Homeland Security 

FCC Federal Communications Commission

FirstNet First Responder Network Authority

IP Internet Protocol

NG911 Next Generation 911 

NHTSA National Highway Traffic Safety Administration 

NTIA National Telecommunications and Information 

Administration 

Office of EMS Office of Emergency Medical Services 

RFP request for proposal 

VoIP Voice over Internet Protocol

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product 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.
Page 1 GAO-18-252 Next Generation 911

441 G St. N.W.

Washington, DC 20548

January 31, 2018

The Honorable Mike Doyle

Ranking Member

Subcommittee on Communications and Technology

Committee on Energy and Commerce

House of Representatives

The Honorable Anna G. Eshoo

House of Representatives

The Honorable Norma Torres

House of Representatives

Each year, millions of Americans call 911 for help during emergencies. 

According to the National Emergency Number Association, approximately 

240 million calls are made to 911 in the United States each year, with 

over 80 percent of these calls made from wireless devices.1 However, the 

nation’s legacy 911 systems rely on aging infrastructure that is not 

designed to accommodate modern communications technologies. As a 

result, states and localities—the primary providers of 911 services 

through approximately 6,000 call centers nationwide—are working to 

upgrade their 911 systems to the next generation of services, commonly 

known as Next Generation 911 (NG911). Benefits of NG911 systems 

include improved capabilities to communicate with callers, increased 

resiliency of 911 operations, and enhanced information sharing among 

911 call centers and first responders. Call centers using NG911 will be 

able to receive voice calls and accept various forms of data, such as text 

messages, images, video, and vehicle crash data. Such information can 

help to facilitate quick and accurate dispatch of emergency responders 

(such as police, firefighters, and ambulance crews) and can be beneficial 

in situations where a 911 caller is unable to speak.2

The transition to NG911 includes replacing the existing legacy 911 

networks—which carry voice calls and limited data—with NG911 systems 

 1

The National Emergency Number Association is a nonprofit organization focused on 911 

policy, standards development, technology, operations, and education. 

2

According to consumer groups, other benefits of NG911 are enhanced communications 

options and accessibility to emergency services for individuals in the deaf and hard-ofhearing community who may use alternatives to traditional telephones for communication.

Letter
Page 2 GAO-18-252 Next Generation 911

that use Internet Protocol (IP)-based technology. As we have previously 

reported, modernizing communications networks can improve customers’

access and services.3 The Federal Communications Commission (FCC) 

notes that as legacy infrastructure is retired, the transition period in which 

multiple technologies may be used simultaneously raises potential 

challenges for 911 services. To assist states and localities in this 

transition, the Next Generation 911 Advancement Act of 2012 (2012 Act) 

outlined federal agencies’ roles and responsibilities related to NG911.4

The 2012 Act required the National Highway Traffic Safety Administration 

(NHTSA) within the U.S. Department of Transportation and the National 

Telecommunications and Information Administration (NTIA) within the 

U.S. Department of Commerce to create a national program to improve 

coordination and communication among federal, state, and local 

stakeholders. This initiative is known as the National 911 Program, which 

serves as the federal point of coordination for activities among 911 

stakeholders and leads the national effort to eventually connect 

approximately 6,000 independently operated 911 call centers into an 

interconnected, nationwide NG911 system. The 2012 Act also required 

FCC—which has regulatory authority over telecommunications carriers—

to issue specific recommendations to support the NG911 transition, 

among other responsibilities. In addition, the 2012 Act required the U.S. 

Department of Homeland Security (DHS)—which has responsibilities 

related to ensuring the security and interoperability of emergency 

communications nationwide—to work with FCC, NHTSA, and NTIA on 

specific NG911 activities.

You asked us to review the status of implementation of NG911 

nationwide. This report examines: (1) progress states and localities are 

making to implement NG911 and the challenges they have faced and (2) 

 3

More specifically, we reported that according to the Federal Communications 

Commission, modernizing communications networks can dramatically reduce network 

costs and broaden access to new technologies, allowing telecommunications carriers to 

serve customers with increased efficiencies that can lead to improved and innovative 

product offerings and lower prices. The IP transition, however, is a gradual shift; thus, it 

will take many years to complete and has no specific end date. See GAO, Internet 

Protocol Transition: FCC Should Strengthen Its Data Collection Efforts to Assess the 

Transition’s Effects, GAO-16-167 (Washington, D.C.: Dec. 16, 2015).

4

While the 2012 Act outlines federal agencies’ roles and responsibilities related to NG911 

implementation, there is no federal requirement that states transition to NG911 services. 

See Next Generation 9-1-1 Advancement Act of 2012, Pub. L. No. 112-96, 126 Stat. 237 

(2012) (codified at 47 U.S.C. 942 §§ 1471-1473).
Page 3 GAO-18-252 Next Generation 911

how federal agencies have addressed state and local implementation 

challenges and planned next steps.5

To address these objectives, we analyzed survey data provided by 

NHTSA’s National 911 Program on the status of statewide 911 systems 

for calendar year 2015, the most recent year for which data were 

available.6 We also reviewed FCC’s data on state collection and 

distribution of 911 fees and charges for calendar year 2015.7 According to 

our review of the survey data, relevant documentation, and conversations 

with staff responsible for the data, we determined that the data were 

sufficiently reliable to generally describe states’ progress in implementing 

NG911 and to provide background on 911 fee collection and costs.

We also selected a non-generalizable sample of 10 states for case 

studies, based upon a variety of factors, including variation in geographic 

location, reported progress in implementing NG911, number of annual 

 5

Federal departments may also operate 911 call centers, such as on military bases and in 

national parks, according to federal agency officials. DHS officials reported that they are 

working to determine the number of federally-funded 911 call centers and that, in some 

cases, federal call centers may provide 911 services for surrounding communities. Call 

centers owned and operated by the federal government are not included in the scope of 

this review.

6

More specifically, we analyzed the most recent state-provided data from calendar year 

2015 related to planning and implementation of NG911 at the state and local levels. 

NHTSA’s National 911 Program collects these data annually by surveying states during a

given calendar year on activities from the previous year. Thus the data we obtained from 

NHTSA were released in 2016 and represent progress from 2015. According to the 

National 911 Program, these data can be used to characterize the status of statewide 911 

systems and measure progress in implementing advanced 911 systems. See NHTSA, 

2016 National 911 Progress Report, National 911 Program (Washington, D.C.: December 

2016). 

7

FCC surveys states annually on states’ collection and use of 911 fees. FCC is required to 

report to Congress on the identity of states, territories, or political subdivisions (such as 

counties or localities) that collect taxes, fees, or other charges for emergency 

communications. This reporting includes the amount of those revenues used for purposes 

other than the ones specified in the state’s method of funding 911—also known as 911 fee 

diversion. See FCC, Eighth Annual Report to Congress on State Collection and 

Distribution of 911 and Enhanced 911 Fees and Charges for the Period January 1, 2015 

to December 31, 2015 (Washington, D.C.: Dec. 30, 2016).
Page 4 GAO-18-252 Next Generation 911

911 calls, and whether states diverted 911 fees to other uses.8 We 

requested interviews with and documentation from state and local 911 

officials from the 10 selected states about NG911 implementation 

progress, challenges, federal actions, and any additional assistance 

needed. We obtained documentation from and interviewed officials from 

nine states; one of the selected states did not respond to our requests.9

While not generalizable to all states, the information obtained from our 

case studies provides examples of broader issues faced by states and 

localities in managing the transition to NG911.

In addition to our case study work, we reviewed relevant statutes, 

regulations, our prior reports, and documentation of federal agency 

actions and plans. We also interviewed officials from federal agencies, 

including NHTSA, NTIA, FCC, and DHS, and officials from national 

associations representing emergency-response-technology companies, 

wireless and wireline phone carriers, emergency-communications entities, 

and consumer groups. We identified guidance on leading practices for 

performance management,10 and reviewed interagency collaboration 

practices from our prior work.11 We also applied relevant federal 

standards for internal control that are key to helping agencies better 

achieve their missions and desired program results.12 We assessed 

NHTSA’s efforts to set goals and achieve desired results for the National 

911 Program using these standards, this guidance, and selected 

 8

We have previously reported that when states collect funds for 911 purposes and then 

use those revenues for other purposes, there is a risk of confusing stakeholders and 

members of the public who pay these fees and undermining the credibility of 911 fees. 

See GAO, 911 Services: Most States Used 911 Funds for Intended Purposes, but FCC 

Could Improve Its Reporting on States’ Use of Funds, GAO-13-376 (Washington, D.C.: 

Apr. 18, 2013).

9

We interviewed officials from California, Maine, Maryland, Minnesota, New Hampshire, 

North Dakota, South Dakota, Vermont, and Virginia. We contacted 911 officials in Nevada 

but did not receive responses. 

10GAO, Agencies’ Strategic Plans Under GPRA: Key Questions to Facilitate 

Congressional Review, GAO/GGD-10.1.16 (Washington, D.C.: May 1997) and GAO, 

Managing for Results: Critical Issues for Improving Federal Agencies’ Strategic Plans, 

GAO/GGD-97-180 (Washington, D.C.: Sept.16, 1997). 

11GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012).

12GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).
Page 5 GAO-18-252 Next Generation 911

collaboration practices from our prior work.13 A more detailed summary of 

our scope and methodology appears in appendix I.

We conducted our work from January 2017 to January 2018 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.

As we have previously reported, 911 services have evolved from basic 

911—which provided Americans with a universally recognized emergency 

number—to Enhanced 911 which also routes calls to the appropriate call 

center and provides information about the caller’s location and a call back 

number.14 NG911 represents the next evolution in 911 services by using 

IP-based technology to deliver and process 911 traffic. Under NG911, call 

centers will continue to receive voice calls and location information, but 

will also be able to accommodate emergency communications from the 

range of technologies in use today. In addition, NG911 systems provide 

call centers with enhanced capabilities to route and transfer calls and 

data, which could improve call centers’ abilities to handle overflow calls 

and increase information sharing with first responders.

 13We considered key collaboration practices identified in GAO-12-1022 and selected 

practices that were most relevant to NHTSA’s planned collaboration activities.

14GAO, 911 Services: Most States Used 911 Funds for Intended Purposes, but FCC 

Could Improve Its Reporting on States’ Use of Funds, GAO-13-376 (Washington, D.C.: 

Apr. 18, 2013). For previous related reports, see GAO, Telecommunications: States’

Collection and Use of Funds for Wireless Enhanced 911 Services, GAO-06-338 

(Washington, D.C.: Mar. 10, 2006) and Telecommunications: Uneven Implementation of 

Wireless Enhanced 911 Raises Prospect of Piecemeal Availability for Years to Come, 

GAO-04-55 (Washington, D.C.: Nov. 7, 2003). 

Background
Page 6 GAO-18-252 Next Generation 911

Generally speaking, 911 communications begin when a caller dials 911 

using a landline, wireless, or Voice over Internet Protocol (VoIP)15

system.16 Once a 911 caller places an emergency call, a communications 

provider receives and routes the call to the appropriate call center, along 

with the caller’s phone number and location (i.e., street address for a 

landline caller, approximate geographic location for a wireless caller, and 

the subscriber’s address for VoIP).17 Calls and data may be routed to 911 

call centers using legacy methods (i.e., routing calls across traditional 

telephone networks) or NG911 methods (i.e., routing calls and other data 

through IP-networks). Once the call reaches a call center, trained call 

takers and dispatchers determine the nature of the emergency and 

dispatch first responders, typically using a variety of equipment and 

systems, including call handling systems, mapping programs, and 

computer aided dispatch.18 Figure 1 illustrates the 911 communications 

and dispatch process.

 15VoIP is the routing of voice conversations over the Internet or any other IP-network.

16More specifically, according to FCC, 911 communications generally originate on an 

originating service provider’s network where the caller is located, such as a landline 

telephone network, a wireless network, or an over-the-top communications service 

operating over another network.

17According to FCC, the architecture of 911 networks, both legacy and NG911, can 

include multiple entities, each providing one or more links in a chain of connectivity. These 

entities include several distinct types of communications providers, including originating 

service providers (as previously mentioned), incumbent local exchange carriers, system 

service providers, subcontractors and vendors that provide additional technical 

capabilities, and 911 call centers and emergency authorities themselves to the extent that 

they provide 911 network components. See In the Matters of 911 Governance and 

Accountability and Improving 911 Reliability, Policy Statement and Notice of Proposed 

Rulemaking, 29 FCC Rcd 14208 (2014).

18We have previously reported that first responders often have difficulty communicating 

among agencies because existing emergency communications systems lack 

interoperability. The Middle Class Tax Relief and Job Creation Act of 2012 created the 

First Responder Network Authority (FirstNet) within NTIA, and required the agency to 

establish a nationwide, interoperable public-safety broadband network, which is expected 

to foster greater interoperability between NG911-enabled call centers and first responders 

using FirstNet’s network. In June 2017 we reported that FirstNet was working to establish 

the network, but faced various challenges to ensure the network’s reliability, security, and 

interoperability. See GAO, Public Safety Broadband Network: FirstNet Has Made 

Progress Establishing the Network, but Should Address Stakeholder Concerns and 

Workforce Planning, GAO-17-569 (Washington, D.C.: June 20, 2017).

911 Communications 

Process
Page 7 GAO-18-252 Next Generation 911

Figure 1: Overview of 911 Communications and Dispatch Process

As illustrated in figure 1, NG911 systems use IP-networks capable of 

carrying voice plus large amounts of data.19 These emergency-services 

networks are typically deployed at the state or regional level with multiple 

call centers connecting to the network.20 However, the existence of an IPnetwork alone does not constitute an NG911 system. As defined by 

standards developed by the emergency communications community, an 

NG911 system should have the capability to, among other things:

• provide a secure environment for emergency communications;

• acquire and integrate additional data for routing and answering calls;

 19An NG911 system is comprised of hardware, software, data, and operating policies, 

according to the National Emergency Number Association.

20Emergency services IP-networks—also known as ESInets—are managed, multipurpose 

networks that support public-safety communications services and use broadband 

technology capable of carrying voice plus large amounts of data using Internet Protocols 

and standards. These networks are typically deployed at the state or regional level and 

operate under contracts with call centers or through state or local government agencies.
Page 8 GAO-18-252 Next Generation 911

• process all types of emergency calls, including multimedia messages; 

and

• transfer calls with added data to other call centers or first 

responders.21

While NG911 systems must possess certain capabilities, it is important to 

note that states and localities may make decisions about which 

capabilities they intend to use to best meet their needs. In addition, states 

and localities have the authority to make decisions about what NG911 

equipment, systems, and vendors to use; thus, the configurations of these 

systems vary.

According to a panel of experts convened by the National 911 Program,

the transition to NG911 may require a variety of technical and operational 

changes to current 911 systems and processes.22 For example, technical 

changes can include upgrades to networks or installing new hardware or 

software in 911 call centers. Operational changes can include the need 

for additional training or the development of new policies and procedures 

(e.g., new procedures for processing or storing multimedia). These 

technical and operational changes may also have effects on 911 funding 

and state and local governance structures, which we will discuss in more 

detail later in this report.

According to an FCC advisory body that examined NG911 systems 

architecture in 2016, while NG911 systems are implemented in a variety 

of ways at the state or local level, NG911 implementation can occur 

gradually and in phases.23 According to this model, NG911 

implementation occurs on a continuum that begins with legacy 911 

systems and ends with a fully deployed NG911 national end-state where 

all individual 911 call centers nationwide would be connected. The NG911 

 21Emergency communications associations play an important role in developing standards 

and operational procedures for NG911 architecture and implementation. The National 

Emergency Number Association, for example, aims to improve 911 through research, 

standards development, training, education, outreach, and advocacy. This association has 

developed a widely accepted standard for NG911 requirements and architecture, 

according to FCC.

22See NHTSA, Blue Ribbon Panel on 911 Funding: Report to the National 911 Program

(Washington, D.C.: December 2013).

23FCC, Task Force on Optimal Public Safety Answering Point Architecture, Working 

Group 2, Phase II Supplemental Report: NG9-1-1 Readiness Scorecard (Dec. 2, 2016).

NG911 Implementation
Page 9 GAO-18-252 Next Generation 911

implementation model identifies activities that take place as part of the 

NG911 transition, many of which occur concurrently, such as:

• planning (e.g., conducting feasibility studies, preparing databases, 

establishing governance models);

• acquiring, testing, and implementing NG911 system elements (e.g., 

establishing an emergency-services IP-network, location-based call 

routing, processing multimedia);

• connecting call centers within a jurisdiction (i.e., jurisdictional endstate in which all call centers are fully NG911 operational, supported 

by agreements, policies, and procedures); and

• connecting NG911 systems nationwide (i.e., national end-state in 

which all call centers in the nation are fully NG911 operational, 

supported by agreements, policies, and procedures).

In addition, because 911 services provide an essential function, the 

implementation of NG911 generally involves using both the legacy 

system and the NG911 system simultaneously for a period of time, 

according to the FCC advisory body, to ensure 911 services are not 

disrupted as new system elements are tested and implemented.

Deploying and operating 911 is the responsibility of 911 authorities at the 

state and local level. As we have previously reported, all 50 states and 

the District of Columbia collect—or have authorized local entities to 

collect—funding for 911 from telephone service subscribers, and methods 

within each state for collecting funds vary.24 FCC, as required by statute, 

reports to Congress annually on the states’ collection and distribution of 

911 fees and charges.25 There are approximately 6,000 call centers 

nationwide that process 911 calls, often at the county or city level, and 

 24GAO-13-376. 

25FCC has been publishing an annual report on state collection and distribution of 911 

fees and charges since 2009, as required by the New and Emerging Technologies 911 

Improvement Act of 2008. As part of that report, FCC also includes collection and 

distribution of 911 fees and charges of United States territories. Pub. L. No. 110-238, § 

101(2)(f)(2), 122 Stat. 2620 (2008). For more information, see FCC, Eighth Annual Report 

to Congress on State Collection and Distribution of 911 and Enhanced 911 Fees and 

Charges for the Period January 1, 2015 to December 31, 2015 (Washington, D.C.: Dec. 

30, 2016). 

State and Local Roles
Page 10 GAO-18-252 Next Generation 911

these centers can vary greatly in size and technical sophistication.26 The 

state and local governance structures that oversee 911 operations also 

vary by location. For example, we previously reported that some states 

collect fees or charges for 911 and administer a statewide 911 program.27

Other states authorize local entities to collect fees or charges for 911 and 

administer 911 programs at the local level. Still other states use a 

combination of these approaches. According to a panel of experts 

convened by the National 911 Program, historically, 911 authority has 

been coordinated and maintained locally with no requirement to 

coordinate with other jurisdictions.28 However, the transition to NG911 

enables connection of 911 systems. Thus, as previously mentioned, the 

NG911 transition may require technological and operational changes, as 

well as changes to 911 policies and governance responsibilities for states 

and localities.

While deploying and operating 911 is the responsibility of entities at the 

state and local level, federal agencies—including NHTSA, NTIA, FCC, 

and DHS—have responsibilities to support state and local 

implementation, including through facilitating coordination of activities 

among 911 stakeholders and administering federal grants,29 for example:

• NHTSA houses the National 911 Program as part of its Office of 

Emergency Medical Services (Office of EMS) to provide national 

leadership and coordination for the NG911 transition throughout the 

United States, as previously mentioned. According to NHTSA, the 

fiscal year 2017 budget for the National 911 Program was $2.74 

 26As we have previously reported, call centers within a state vary in size and technical 

sophistication. For example, some large urban call centers may have dozens of call takers 

and split functions of call taking and dispatching emergency responders, such as police, 

firefighters, and ambulance crews. Smaller call centers may be staffed by only two or 

three call takers who also handle dispatch. In some rural areas, the call centers may be 

the sheriff’s office. GAO-13-376.

27GAO-13-376. 

28NHTSA, Blue Ribbon Panel on 911 Funding: Report to the National 911 Program

(Washington, D.C.: December 2013). 

29In addition, as previously mentioned, federal departments may also operate 911 call 

centers, such as on military bases and in national parks, according to federal agency 

officials. Call centers owned and operated by the federal government are not included in 

the scope of this review. 

Federal Roles
Page 11 GAO-18-252 Next Generation 911

million.30 Among other activities, which we will discuss later in this 

report, the National 911 Program surveys states on progress 

implementing NG911 and reports this survey data annually.31

• FCC issues orders and regulations for 911 service providers on topics 

relevant to NG911, such as 911 reliability, location accuracy, and textto-911. FCC also sponsors advisory bodies comprised of government 

and industry experts that study relevant topics and provide 

recommendations related to NG911, such as the Task Force on 

Optimal Public Safety Answering Point Architecture and the 

Communications, Security, Reliability, and Interoperability Council.

While there are no federally mandated time frames for implementing 

NG911, the Next Generation 911 Advancement Act of 2012 requires 

specific actions of some federal agencies as outlined in table 1, below.

Table 1: Selected Federal Agencies’ Requirements Related to Next Generation 911 (NG911) 

Federal agency Selected requirements 

National Highway Traffic 

Safety Administration 

(NHTSA)

• Required by the Next Generation 911 Advancement Act of 2012a (2012 Act) to work in 

coordination with NTIA to: (1) establish an Implementation Coordination Office to facilitate 

coordination and communication between federal, state, and local entities; (2) develop regulations 

prescribing the criteria for grant selection and provide grants to eligible entities, including states, 

for 911 implementation (including NG911); and (3) prepare a report for Congress that analyzes 

and determines detailed costs for NG911 implementation, in consultation with FCC and DHS. 

National Telecommunications 

and Information 

Administration (NTIA)

• Required by the 2012 Act to work in coordination with NHTSA to: (1) establish an Implementation 

Coordination Office; (2) issue regulations and provide grants to states for 911 implementation 

(including NG911); and (3) prepare and submit a cost study for Congress, all as described in 

more detail above.

Federal Communications 

Commission (FCC)b

• Required by the 2012 Act to provide recommendations to Congress on the legal and statutory 

framework needed for the NG911 transition, in coordination with NHTSA, NTIA, and DHS, among 

other requirements.

U.S. Department of 

Homeland Security (DHS)c

• Required by 2012 Act to coordinate with NHTSA to prepare and submit a cost study for Congress, 

as described above. 

Source: GAO analysis of the Next Generation 911 Advancement Act of 2012. | GAO-18-252

a

Pub. L. No. 112-96, 126 Stat. 237 (2012).

b

FCC regulates interstate and international communications by radio, television, wire, satellite, and 

cable throughout the United States. Communications Act of 1934, Pub. L. No. 73-416, § 2, 48 Stat. 

 30More specifically, according to NHTSA’s 2018 Budget Estimates, the annualized 

continuing resolution for the National 911 Program for fiscal year 2017 was $2.74 million. 

According to program officials, the National 911 Program has one full-time staff member 

and leverages partnerships with other organizations and contractors to carry out some of 

the office’s activities. 

31See NHTSA, 2016 National 911 Progress Report, National 911 Program (Washington, 

D.C.: December 2016). 
Page 12 GAO-18-252 Next Generation 911

1064 (1934), as amended by Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56 

(1996) (codified as amended at 47 U.S.C. § 151).

c

DHS is responsible for leading, integrating, and coordinating the implementation of efforts to protect 

the nation’s cyber-reliant critical infrastructures.

In addition, according to the National 911 Program, as states and 

localities continue to implement NG911, and begin to explore 

interconnection with other states’ 911 systems, federal agencies may 

need to take steps to help ensure state NG911 networks are 

interoperable and connected. We will discuss actions taken by federal 

agencies to assist states and localities to implement NG911 later in this 

report.

According to NHTSA’s most recent national survey, state and local 

progress implementing NG911 varies, and about half of all states 

reported being in some phase of transition to NG911 in 2015.32 While a 

few states are well into statewide implementation, NHTSA officials told us 

that no state had completely implemented all NG911 functions.

Additionally, as of the fall of 2017, none of the selected states we spoke 

with were processing multimedia—such as images or audio/video 

recordings—through their 911 systems due to concerns related to 

privacy, liability, and the ability to store and manage these types of data, 

among other things. The national survey data, based on responses from 

45 states, measured the extent to which NG911 planning and acquisition 

of NG911 equipment and services were occurring, and the extent to 

 32NHTSA, 2016 National 911 Progress Report, National 911 Program (Washington, D.C.: 

December 2016). The data used in the December 2016 report are from calendar year 

2015, the most recent data available during this review. 

States and Localities 

Have Reported Varied 

Progress in 

Implementing NG911 

and Identified 

Funding, Technology, 

and Governance

Challenges

Reported Progress among 

States Varies in 

Implementing Next 

Generation 911
Page 13 GAO-18-252 Next Generation 911

which basic NG911 functions were operational at the state and local 

levels in 2015.33

Planning: This measure includes state and local NG911 plans for 

governance, funding, system components, and operations. In this context, 

system components refer to an emergency services IP-based network, 

NG911 software, system and information security, and databases, among 

other things, according to NHTSA’s survey. In total, 25 of 45 states 

reported having a state or at least one local NG911 plan in place; 

conversely, 18 states reported having no NG911 plan in place at either 

the state or local level—which may indicate they are in the early stages of 

planning for the NG911 transition or have not yet begun the transition to 

NG911.34

Acquisition: These measures identify states or local entities that have 

defined their NG911 needs and awarded contracts, and then installed and 

tested acquired NG911 components and services. Twenty-four states 

reported awarding at least one contract at the state or local level for 

NG911 components and services. Twenty-three states reported having 

installed and tested NG911 components and services at either the state 

or local level.35

NG911 services: This is a measure of 911 authorities that have some 

basic, functioning NG911 infrastructure in place.36 In total, 21 states 

reported having some level of basic NG911 services in place at the state 

or local level. Of these 21 states, 10 reported that all 911 authorities 

within the state were using NG911 technology to process emergency 

calls. Another 7 of these states reported that 25 percent or less of their 

 33As part of the National 911 Program’s data collection effort, 50 states, the District of 

Columbia, and 6 U.S. territories were asked to provide 911-related data. For the purposes 

of reporting on these data, states, territories, and the District of Columbia are all referred 

to as “states.” A total of 45 states provided data for calendar year 2015.

34Two states reported not knowing the status of state and local planning.

35Two states reported awarding contracts but did not report having installed and tested 

NG911 systems yet. In addition, one state reported having installed and tested a system, 

but reported “unknown” to the extent contracts were awarded.

36This does not necessarily mean that all NG911 core services are in place. For example, 

NHTSA’s survey did not measure: (1) a 911 authority’s ability to route calls based on a 

specific geographic location, (2) a system’s ability to process multimedia, or (3) 

establishment of interoperability with neighboring authorities’ systems.
Page 14 GAO-18-252 Next Generation 911

state’s 911 authorities were using NG911 technology to process 

emergency calls.

Federal officials, industry stakeholders, and state and local 911 officials 

we interviewed from nine states identified a number of challenges to 

implementing NG911, including challenges related to funding, evolving 

technology and operations, and governance.37

Funding: State and local officials in four of nine selected states identified 

insufficient funding as one of the challenges they face in implementing 

NG911.38 Additionally, FCC, NHTSA, and industry reports noted that state 

and local financing strategies are generally insufficient to fully implement 

NG911.39 Specifically, these reports note that the need to provide new 

capital for NG911 implementation while simultaneously funding legacy 

operational costs during the transition can strain state and local funding.

• Limited funding: Officials in three states told us that their current 

funding may not be able to support the upfront costs of infrastructure 

and equipment acquisitions associated with the transition to NG911. 

Further, officials said they will need to simultaneously fund both the 

new NG911 and legacy 911 systems currently in operation until the 

NG911 systems are fully operational. To address these challenges, a 

Minnesota official told us about how the state leveraged economies of 

scale to reduce overall costs through cost sharing between multiple 

call centers and of call centers consolidating operations from 114 to 

104 call centers. Additionally, a Virginia official told us that to cover 

the upfront costs of transitioning to NG911, the state plans to borrow 

 37It is important to note that while each local and state 911 authority may have discussed 

challenges unique to its respective situations, the challenges identified in this report are in 

part limited to those that were mentioned by more than one authority. Therefore, not every 

one of the selected states experienced these challenges, nor are these challenges meant 

to be generalizable to all of the states.

38As previously mentioned, we interviewed officials from California, Maine, Maryland, 

Minnesota, New Hampshire, North Dakota, South Dakota, Vermont, and Virginia. We 

attempted to contact 911 officials in Nevada but did not receive responses.

39FCC, Task Force on Optimal Public Safety Answering Point Architecture, Adopted Final 

Report (January 2016); NHTSA, Blue Ribbon Panel on 911 Funding: Report to the 

National 911 Program (Washington, D.C.: December 2013); and Industry Council for 

Emergency Response Technologies, The Status of NG911 Deployment in the United 

States (January 2015).

Officials Identified State 

and Local Funding, 

Technology, and 

Governance Challenges to 

Implementing NG911
Page 15 GAO-18-252 Next Generation 911

from the state treasury and then repay the treasury with future-year 

fee collections.

• Fee diversion: Diversion of fees intended for 911 costs to non-911 

activities may affect a state’s or locality’s ability to cover NG911 

transition costs and necessitate identifying alternative funding 

sources. The FCC’s 2016 annual report on 911 fees indicates that for 

calendar year 2015, all but two of the states that responded to FCC’s 

911 fee survey affirmed that their state or jurisdiction collects fees 

from phone users to support or implement 911 services.40 State and 

local authorities also determine how these 911 fees can be used.41

FCC’s report also indicated that eight states and Puerto Rico reported 

diverting a total of more than $220 million (or approximately 8.4 

percent) of 911 fees collected to non-911 purposes. Some of these 

diverted funds were directed to other public safety programs, and 

others were diverted to either non-public safety or unspecified 

purposes. According to one state official, had it not been for 911 fees 

being diverted to non-911 purposes, funding would have been 

sufficient to cover the NG911 transition without having to go to the 

state legislature for additional funding. However, officials in the other 

eight selected states told us that either fee diversion was not an issue 

in their state or that the diversion of funds had not affected their 

state’s ability to implement NG911.

Evolving technology and operations: Officials in eight states told us 

that the retirement of legacy infrastructure and the transition to IP-based 

systems introduces new technical and operational challenges for call 

centers and states, as well as for equipment and service providers.

• Interoperability: Officials in three selected states mentioned that 

connecting to neighboring networks—whether within or between 

states—could pose challenges. For example, officials mentioned that 

states and localities may have obtained different equipment, software 

 40FCC’s 911 fee survey is separate from NHTSA’s NG911 implementation survey. As 

previously mentioned, FCC collects data and reports to Congress annually on state 

collection and use of 911 fees. Forty-seven states, the District of Columbia, American 

Samoa, Puerto Rico, and the U.S. Virgin Islands provided responses to this particular 

question from FCC’s survey. Three states—Missouri, Nevada, and Wyoming—did not 

respond to this question. For additional information, see FCC, Eighth Annual Report to 

Congress on State Collection and Distribution of 911 and Enhanced 911 Fees and 

Charges for the Period January 1, 2015 to December 31, 2015 (Washington, D.C.: Dec. 

30, 2016).

41Although FCC collects data from states on the collection and use of 911 data, it has no 

authority to determine how state and local 911 fees are spent.
Page 16 GAO-18-252 Next Generation 911

applications, or service providers – all of which can make 

interconnections difficult. Officials in Maine and New Hampshire told 

us that differences in service providers can also be a challenge to 

seamlessly connecting to neighboring systems. In an instance where 

two states (Minnesota and North Dakota) have worked to connect 

their 911 systems, both states used the same service provider, which 

officials said allowed for fewer barriers to connection.

• Cyber risks: Officials in three states told us that the transition from a 

traditional system that only transmits voice traffic to an IP-based 

system that transmits voice and data traffic has significantly increased 

the risk of a cyber-attack. This can be a challenge because managing 

cyber risks is a new and evolving role for state and local 911 

authorities. Approaching the transition to NG911 without managing 

these risks could result in disrupted or disabled call center operations 

and ultimately a delayed response to an emergency situation.

• Multimedia: Officials in three states mentioned potential 

implementation challenges related to accepting and processing 

multimedia such as audio recordings, images, and videos. More 

specifically, one official said they did not have procedures to manage 

or store these multimedia files once received. In addition, another 

official raised privacy and liability concerns.

• Call routing: One of the core services of an NG911 system is the 

ability to have calls routed to the appropriate call center based on a 

wireless caller’s physical location, instead of the location of the 

cellular tower that receives and transmits the call. An FCC-sponsored 

working group reported that there are several options for achieving 

this and each option has unique positive and negative aspects.42 One 

challenge officials in two states noted was that rather than a single, 

nationwide approach to routing these calls, state and local 911 

authorities would need to work individually with the wireless carriers to 

determine how to best implement location-based call routing.

Governance: FCC has noted that transitioning to NG911 will likely result 

in new roles and levels of coordination between state 911 authorities, 

local 911 authorities, 911 call centers, and 911 service providers. Further, 

relationships among authorities at the state and local level may change 

as states work to interconnect NG911 systems. State and local officials 

 42FCC, Communications Security, Reliability and Interoperability Council V, Working 

Group 1, Evolving 911 Services, Final Report – Task 2: 911 Location-Based Routing

(September 2016). 
Page 17 GAO-18-252 Next Generation 911

noted that these types of governance challenges can apply in a variety of 

situations, including within or between states.

• Evolving roles: As previously mentioned, 911 governance structures 

vary among states. These varying governance structures may pose 

different challenges. For example, some states have a centralized 

structure in which a single government agency is responsible for 

statewide 911 system’s administration and policy. Officials in two 

states told us that although they faced challenges transitioning to 

NG911, their states’ centralized 911 structure eased the transition in 

their states because there was uniformity in policy and technology, 

among other things, coming from a single statewide authority. In other 

states, 911 systems are primarily a local responsibility and organized 

with decentralized authorities and resources. In these instances, there 

may be specific challenges related to transitioning to an 

interconnected NG911 system. Such challenges may include the 

need for increased levels of coordination among numerous 

jurisdictions with potentially disparate organizational structures, levels 

of funding, and priorities. An official also noted that there are 

governance challenges related to connecting states and evolving 

relationships between 911 authorities and service providers.

• Informing decision makers: One of the challenges identified by 

officials in two states is differing levels of experience and 

understanding by state and local officials as to what NG911 priorities 

should be for timely implementation. To help with this understanding, 

the federal government is making efforts to educate state and local 

authorities on how to facilitate policymaker understanding as well as 

provide regular updates to stakeholders on recent NG911 

developments. We discuss some of these efforts later in this report.
Page 18 GAO-18-252 Next Generation 911

While state and local entities have the primary responsibility for 

implementing NG911 technology and services, federal agencies are 

taking actions to assist state and local 911 entities to address NG911 

implementation challenges. Actions taken include developing resources, 

offering technical assistance, and convening stakeholders. More

specifically, we identified selected activities that were taken by NHTSA, 

NTIA, FCC, and DHS that address some of the funding, technology, and 

governance challenges raised by state and local 911 stakeholders, for 

example:

• Cost study: NHTSA’s National 911 Program and NTIA, in 

consultation with FCC and DHS, plan to issue a study of the range of 

costs for 911 call centers and service providers to implement NG911 

systems.43 According to NHTSA officials, the cost study will present a 

nationwide view, rather than a state-by-state view, on the progress of 

NG911 implementation and its associated costs.

• Grant program: NHTSA and NTIA are preparing to jointly administer 

a $115 million grant program to improve 911 services, including the 

 43As previously mentioned, the 2012 Act required NHTSA and NTIA, in consultation with 

FCC and DHS, to submit a report to Congress that determines detailed costs for specific 

NG911 service requirements and specifications. The 2012 Act specifies the purpose of the 

report as serving as a resource for Congress as it considers creating a coordinated, longterm funding mechanism for the deployment and operation, accessibility, application 

development, equipment procurement, and training of personnel for NG911 services. 

NHTSA officials said they received the study from their selected contractors in September 

2017, which was under review as of the time of our analysis. 

Federal Agencies Are 

Addressing NG911 

Implementation 

Challenges, but the 

National 911 Program 

Lacks Measurable 

Goals and Next Steps 

for the NG911 

Roadmap Initiative

Federal Agencies Are 

Taking Actions to Address 

NG911 Implementation 

Challenges
Page 19 GAO-18-252 Next Generation 911

adoption and operation of NG911 services.44 In September 2017, 

NHTSA and NTIA issued a notice of proposed rulemaking outlining 

implementing regulations for the grant program.45 NHTSA and NTIA 

expect to award the grants in 2018.

• Technology standards: The National 911 Program issued an annual 

guide in 2017 that stressed the importance of using open technology 

standards for NG911 services. The guide provides a list of standards 

that have been recently updated and an analysis that identifies 

whether existing standards fully address NG911 processes and 

protocols.46

• Cybersecurity guides: DHS issued a guide in 2016 that identified 

cybersecurity risks for NG911 and risk mitigation strategies.47

According to DHS officials, the National 911 Program provided input 

on this guide. In addition, an advisory body tasked by FCC to examine 

911 call-centers’ architecture issued a report in 2016 that provided a 

cybersecurity self-assessment tool for call centers and guidance on 

cybersecurity strategies.48

• Governance plans: To address challenges related to the evolving 

roles for state and local 911 authorities, the National 911 Program 

issued a guide in 2016 that provided practices for states to consider 

when interconnecting NG911 networks, and DHS issued a guide in 

2015 for emergency communications officials for establishing, 

 4447 U.S.C. § 942(b)(1).

45The notice of proposed rulemaking included a request for comments due November 6, 

2017. As previously mentioned, the 2012 Act required NHTSA and NTIA to administer this 

grant program. In 2016, approximately $115 million from spectrum auction proceeds were 

deposited into the Public Safety Trust Fund and made available to NTIA and NHTSA for 

the grant program. 

46NHTSA, National 911 Program, Next Generation 911 (NG911) Standards Identification 

and Review (Washington, D.C.: March 2017).

47DHS, Office of Emergency Communications, Cyber Risks to Next Generation 911

(2016).

48FCC, Task Force on Optimal Public Safety Answering Point Architecture, Adopted Final 

Report (January 2016). Additional information on cybersecurity planning for NG911 can be 

found in FCC, Task Force on Optimal Public Safety Answering Point Architecture, 

Working Group 1, Optimal Cybersecurity Approach for PSAPs, Supplemental Report

(December 2016).
Page 20 GAO-18-252 Next Generation 911

assessing, and updating their governance structures.49 In addition, an 

FCC advisory body issued a report in 2016 that identified NG911 

governance approaches, issues, and recommendations for states, 

localities, and call centers to consider when planning for the 

deployment of NG911.50

In addition to federal agency efforts to assist the state and local 911 

community, the National 911 Program is in the early stages of 

establishing an interagency initiative to create a National NG911 

Roadmap. As part of this initiative, the National 911 Program plans to 

convene the 911 stakeholder community to identify tasks that need to be 

completed at the national level by the federal government and other 

public and private-sector organizations to support the creation of a 

national, interconnected NG911 system. Additional details regarding this 

planned activity are described in further detail later in this report. For 

additional information on federal actions to address state and local 

NG911 challenges, see appendix II.

As the lead entity for coordinating federal NG911 activities, the National 

911 Program has taken a variety of actions to assist the state and local 

911 community, in collaboration with other federal agencies. However, 

the program lacks goals and performance measures to assess whether 

these activities are achieving desired results. National 911 Program 

officials stated that they initiate program activities based on feedback 

received from the 911 community. In addition, officials said the program’s 

activities fall within the tasks established in the Next Generation 911 

Advancement Act of 2012. However, the National 911 Program does not 

have a means to assess its progress toward meeting its responsibilities 

established in the 2012 Act. National 911 Program officials said the Office 

of EMS—the office within NHTSA in which the program is housed—has a 

strategic plan, but it is outdated and does not contain specific goals or 

performance measures related to 911 or NG911 implementation. Officials 

 49NHTSA, National 911 Program, Next Generation 911 (NG9-1-1) Interstate Playbook: 

Implementing State-to-State 9-1-1 Connectivity (Washington, D.C.: October 2016) and 

DHS, Emergency Communications Governance Guide for State, Local, Tribal, and 

Territorial Officials (September 2015). 

50FCC, Task Force on Optimal Public Safety Answering Point Architecture, Adopted Final 

Report (January 2016). Additional information on governance planning for NG911 can be 

found in FCC, Task Force on Optimal Public Safety Answering Point Architecture, 

Working Group 2, Phase II Supplemental Report: NG9-1-1 Readiness Scorecard

(December 2016). 

National 911 Program 

Lacks Goals and 

Performance Measures
Page 21 GAO-18-252 Next Generation 911

said the Office of EMS has held preliminary discussions to begin updating 

its strategic plan by January 2019 and plans to include goals and 

performance measures related to 911 and NG911 services. Office of 

EMS officials told us the Office of EMS strategic plan will be jointly 

developed with the National 911 Program. However the Office of EMS 

had not yet developed a draft strategic plan during the time of our review.

Federal internal control standards call for management to clearly define 

objectives in order to achieve desired results. According to these 

standards, an entity determines its mission, establishes specific 

measurable objectives, and formulates plans to achieve its objectives. 

These standards state that management sets objectives in order to meet 

the entity’s mission, strategic plan, and goals and requirements of 

applicable laws and regulations.51 In addition, our work on leading 

practices for managing for results indicated that an agency’s strategic 

goals should also explain what results are expected from the agency and 

when to expect those results.52 Further, these goals form a basis for an 

entity to identify strategies to fulfill its mission and improve its operations 

to support the achievement of that mission.53

As the lead entity for coordinating federal NG911 efforts, the National 911 

Program faces a complex and challenging task of assisting the 911 

community while the nation’s 911 systems undergo a major 

transformation. However, without specific goals and related performance 

measures, the National 911 Program is unable to assess how well its 

activities are achieving results in relation to its responsibilities identified in 

the 2012 Act. As the National 911 Program and the Office of EMS 

consider creating a strategic plan, ensuring that the plan includes specific 

goals and related measures for the National 911 Program would help 

officials better understand whether the program’s activities are effectively 

assisting states and localities in transitioning to a fully integrated national 

NG911 system, and help identify any programmatic changes that might 

be needed.

 51GAO-14-704G.

52GAO/GGD-10.1.16.

53GAO/GGD-97-180.
Page 22 GAO-18-252 Next Generation 911

As previously mentioned, the National 911 Program is in the early stages 

of establishing an interagency initiative to create a National NG911 

Roadmap. This initiative will convene the 911 stakeholder community to 

identify national-level tasks that need to be completed by federal 

agencies and other organizations to realize a national, interconnected 

NG911 system. According to the National 911 Program, a list of the 

national-level tasks needed to advance NG911 implementation 

nationwide has not been created to date. In addition, state officials we 

spoke with said there are certain issues related to interoperability and 

cybersecurity that federal agencies need to address before states can 

connect their respective state NG911 systems. To address these issues, 

NHTSA’s National 911 Program issued a request for proposal (RFP) in 

August 2017 for managing the roadmap development process and 

awarded a contract in September 2017.54 While the National 911 Program 

is taking steps to develop a National NG911 Roadmap, the program does 

not have a plan to identify: (1) roles or responsibilities for federal entities 

to carry out national-level tasks or (2) how the program plans to achieve 

the roadmap’s objectives.

NHTSA’s NG911 roadmap RFP specifies that by identifying a list of 

national-level tasks that are developed and adopted by the 911 

stakeholder community, the roadmap could serve as a blueprint to carry 

out these tasks and thereby ensure the interoperability of the nation’s 

NG911 system. However, the National 911 Program does not have plans 

for the entities participating in the development of the roadmap to be 

assigned roles and responsibilities for executing the roadmap’s nationallevel tasks. National 911 Program officials told us the National 911 

Program does not plan to assign roles and responsibilities because 

NHTSA does not have the authority to require or assign tasks for other 

entities. Additionally, program officials view the simultaneous identification 

of tasks and assignments of responsibility for those tasks as a risk to 

facilitating a candid and productive discussion with entities participating in 

the roadmap initiative. However, officials stated it may be appropriate for 

agencies participating in the roadmap initiative to perform specific tasks 

 54According to the roadmap’s RFP, as states begin to explore interconnection with other 

states’ 911 systems, certain tasks should be completed in order to achieve a nationwide 

system where all states’ NG911 networks are interoperable and connected. The RFP 

specifies that the contractor will be required to conduct a public comment process, 

convene a steering group of 911 experts, and gather input from federal and private sector 

entities on the content of the roadmap, and deliver a final roadmap to NHTSA. 

National 911 Program 

Lacks Plans to Identify 

Roles and Responsibilities 

for the NG911 Roadmap 

Initiative and an 

Implementation Plan to 

Achieve Objectives

Clarifying Roles and 

Responsibilities
Page 23 GAO-18-252 Next Generation 911

after the roadmap is finalized. We have previously examined interagency 

collaborative mechanisms and identified certain key issues for federal 

agencies to consider when using these mechanisms to achieve results.55

Our prior work has found that following leading collaboration practices, 

such as clarifying roles and responsibilities of agencies engaged in 

collaboration, can enhance and sustain collaboration among agencies 

and provide an understanding of who will do what in support of meeting 

the aims of the collaborative group.56

As stated above, the RFP specifies that a roadmap developed by and 

adopted by 911 stakeholders could serve as a blueprint to carry out the 

roadmap’s tasks. Securing the commitment of agencies to assigned roles 

could help organize the collaborative group’s joint and individual efforts 

and thereby better facilitate decision making. As we have previously 

found, a lack of clarity on the roles and responsibilities of agencies 

participating in an interagency effort—such as the execution of the 

roadmap’s tasks—may limit agencies’ abilities to effectively achieve 

shared objectives.57 Given the complexity of the task and the number of 

agencies that could be involved, following selected leading collaboration 

practices for the roadmap initiative—particularly with regard to 

collaborating with roadmap stakeholders to clarify their roles and 

responsibilities (whether during the creation of the task list or 

afterwards)—could reduce barriers to agencies effectively working 

together to achieve the national-level tasks.

While clarifying the roles and responsibilities of roadmap stakeholders for 

the execution of the roadmap’s tasks is an important collaborative step, 

the National 911 Program has additional responsibilities as the lead entity 

for the initiative. However, National 911 Program officials are unable to 

clearly articulate how the program will proceed following the completion of 

the roadmap. National 911 Program officials said without knowing the 

contents of the roadmap, it would be premature to specify how the 

roadmap’s national-level tasks would be completed. Officials stated that 

once the roadmap is completed, possible next steps may include 

 55GAO-12-1022.

56For example, other key practices include defining and articulating short and long-term 

outcomes and ensuring relevant participants are included in the process. For more 

information on examples, see GAO-12-1022.

57GAO, Emergency Communications: Effectiveness of the Post-Katrina Interagency 

Coordination Group Could be Enhanced, GAO-16-681 (Washington, D.C.: July 14, 2016).

Developing an Implementation 

Plan to Achieve Objectives
Page 24 GAO-18-252 Next Generation 911

identification of timelines, deadlines, and a mechanism for tracking 

progress, among other things, but officials stated that these steps are not 

required in the roadmap RFP. As stated above, federal internal control 

standards call for management to clearly define objectives in specific 

terms. According to these standards, management defines what is to be 

achieved, who is to achieve it, how it will be achieved, and the time 

frames for achievement.58

Without a clear plan for how the National 911 Program would take next 

steps to support the implementation of the roadmap’s objectives and 

tasks, the National 911 Program may not be prepared to take effective 

action once the roadmap is completed. We have previously found that 

having an implementation plan can assist agencies to better focus and 

prioritize goals and objectives, and align planned activities.59 Once the 

roadmap is completed, developing an implementation plan that details 

what is to be achieved and how it will be accomplished will place the 

National 911 Program in a better position moving forward to support the 

completion of the national-level tasks.

The current 911 system is undergoing a historic transition. With no federal 

requirement that states transition to NG911 services, federal leadership is 

critical to addressing interoperability challenges and promoting the goal of 

an interconnected national system. As the lead federal entity for fostering 

coordination and collaboration among federal, state, and local 911 

authorities, the National 911 Program plays a critical role in coordinating 

NG911 implementation efforts to improve the nation’s 911 services. 

However, this program—in collaboration with other federal agencies—

faces a complex and challenging task to help move approximately 6,000 

independent 911 call centers toward an interconnected national NG911 

system. In addition, given that the NG911 transition is still in its early 

stages and is an ongoing effort, it is difficult to assess the effectiveness of 

various federal actions to assist states and localities in the transition. In 

light of these challenges, without specific goals and related measures to 

assess effectiveness, the National 911 Program may be hindered in 

determining whether it is making progress towards its stated mission. 

 58GAO-14-704G. 

59GAO, DOD Biometrics and Forensics: Progress Made in Establishing Long-term 

Deployable Capabilities, but Further Actions Are Needed, GAO-17-580 (Washington, 

D.C.: Aug. 7, 2017).

Conclusions
Page 25 GAO-18-252 Next Generation 911

Through the roadmap initiative, the National 911 Program has taken 

important first steps in identifying the need for actions at the national 

level, in order to fully realize the desired end-state of a national, 

interconnected NG911 system. However, while identifying needed next 

steps is essential, equally important to the collaborative effort’s success is

(1) defining and agreeing on the roles and responsibilities of the entities 

best suited to undertake these actions, and (2) developing plans for how 

the National 911 Program will support implementation to achieve the 

roadmap’s objectives. If taken, these actions could help further NG911 

implementation nationwide and help the National 911 Program and 

federal agencies in assisting states and localities to improve these 

lifesaving services.

We are making the following three recommendations to the Administrator 

of NHTSA regarding the National 911 Program:

• develop specific program goals and performance measures related to 

NG911 implementation. (Recommendation 1)

• in collaboration with the appropriate federal agencies, determine roles 

and responsibilities of federal agencies participating in the National 

NG911 Roadmap initiative in order to carry out the national-level tasks 

over which each agency has jurisdiction. (Recommendation 2)

• develop an implementation plan to support the completion of the 

National NG911 Roadmap’s national-level tasks. (Recommendation 

3)

We provided a draft of this report to the Departments of Transportation, 

Commerce, and Homeland Security and FCC for their review and 

comment. In its comments, reproduced in appendix III, the Department of 

Transportation agreed with the recommendations. The Departments of 

Transportation and Homeland Security also provided technical 

comments, which we incorporated as appropriate. The Department of 

Commerce and FCC had no comments.

Recommendations for 

Executive Action

Agency Comments
Page 26 GAO-18-252 Next Generation 911

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Secretary of the Department 

of Transportation, the Secretary of the Department of Commerce, the 

Secretary of the Department of Homeland Security, the Managing 

Director of the FCC, and other interested parties. In addition, the report 

will be available at no charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-2834 or goldsteinm@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Staff who made key contributions to this report 

are listed in appendix IV.

Mark L. Goldstein

Director, Physical Infrastructure Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 27 GAO-18-252 Next Generation 911

Our objectives were to examine (1) progress states and localities are 

making to implement Next Generation 911 (NG911) and the challenges 

they have faced and (2) how federal agencies have addressed state and 

local implementation challenges and planned next steps.

To describe state and local progress in implementing NG911 and 

background information on fee collection and costs, we analyzed select 

survey data elements from the 2016 National 911 Progress Report1 and 

the Eighth Annual Report to Congress on State Collection and 

Distribution of 911 and Enhanced 911 Fees and Charges,

2 maintained by 

the National Highway Traffic Safety Administration (NHTSA) and the 

Federal Communications Commission (FCC) respectively. More 

specifically, we analyzed the most recent state-provided data (from 

calendar year 2015) related to the planning and implementation of NG911 

at the state and local levels, as well as NG911 cost and 911-related 

revenue data. We assessed the reliability of these data by reviewing 

relevant documents and discussing data elements with staff responsible 

for collecting and analyzing the data. We also conducted our own testing 

to check the consistency of the data. We found the data from both 

sources to be sufficiently reliable for our purposes to describe states’

progress in implementing NG911 and provide background on 911 fee 

collection and costs. While these data provide the best nationwide picture 

of NG911 implementation and fee collection, and are reliable for our 

purposes, there are some limitations on how the data can be used. Since 

we did not validate the state-reported responses, our findings based on 

these data are limited to what states reported. Additionally, regarding the 

2016 National 911 Progress Report data, there are limitations to (1) 

making comparisons between states because states have different 

approaches to implementing NG911 and (2) ascertaining year-over-year 

 1

These data consist of survey data collected annually by NHTSA’s National 911 Program. 

According to the National 911 Program, these data can be used to characterize the status 

of statewide 911 systems and measure progress in implementing advanced 911 systems. 

See NHTSA, 2016 National 911 Progress Report, National 911 Program (Washington, 

D.C.: December 2016). 

2

These data consist of survey data collected annually by FCC on state collection and use 

of 911 fees. FCC is required to report to Congress on the identity of states, territories, or 

political subdivisions (such as counties or localities) that collect taxes, fees, or other 

charges for emergency communications. This reporting includes the amount of those 

revenues used for purposes other than the ones specified in the state’s method of funding 

911—also known as 911 fee diversion. See FCC, Eighth Annual Report to Congress on 

State Collection and Distribution of 911 and Enhanced 911 Fees and Charges for the 

Period January 1, 2015 to December 31, 2015 (Washington, D.C.: Dec. 30, 2016). 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 28 GAO-18-252 Next Generation 911

progress because reporting is voluntary and states’ response rates can 

vary year to year.

To describe implementation challenges that states and local authorities 

may be encountering, we selected a non-generalizable sample of 10 

states as case studies, based upon a variety of factors, including reported 

progress in implementing NG911, statewide planning and coordination, 

reported number of annual 911 calls, whether states diverted 911 fees to 

other uses, and variation in geographic location. We selected these 

states, in part, based on their responses to the two aforementioned 

surveys. Based on the aforementioned criteria, we selected the following 

states to include as case studies: California, Maine, Maryland, Minnesota, 

Nevada, New Hampshire, North Dakota, South Dakota, Vermont, and 

Virginia. We reviewed documents and interviewed state officials from all 

of these states except Nevada about NG911 implementation progress, 

challenges, federal actions, and any additional assistance needed. We 

contacted 911 officials in Nevada but did not receive responses. We also 

interviewed local officials in four of the selected states. While not 

generalizable to all states, the information obtained from our case studies 

provides examples of broader issues faced by states and localities in 

managing the NG911 transition.

To determine how federal agencies have addressed state and local 

implementation challenges and planned next steps, we reviewed relevant 

statutes, regulations, and documentation of federal agency actions and 

plans, and our prior reports. We also interviewed officials from federal 

agencies, including NHTSA, the National Telecommunications and 

Information Administration (NTIA), FCC, and the U.S. Department of 

Homeland Security (DHS), about federal actions taken and plans for next 

steps. To understand planning activities undertaken by NHTSA’s National 

911 Program, and its planned project to develop a National NG911 

Roadmap, we reviewed the National 911 Program’s internal planning 

documents, the program’s request for proposal to develop a national 

roadmap, the program’s written responses to our questions, and 

interviewed National 911 Program officials. In addition, we interviewed 

officials from national associations representing emergency-responsetechnology companies, wireless and wireline phone carriers, emergencycommunications entities, and groups representing deaf and hard-ofhearing consumers to gain their perspectives on federal actions taken 

and next steps. We assessed the National 911 Program’s strategicplanning activities against leading practices for performance management 
Appendix I: Objectives, Scope, and 

Methodology

Page 29 GAO-18-252 Next Generation 911

found in our prior work on strategic planning and goal setting and federal 

internal control standards.3 We assessed the National 911 Program’s 

planned activities for the national roadmap project against federal internal 

control standards and selected key practices to enhance interagency 

collaboration identified in our prior work.4

We conducted our work from January 2017 to January 2018 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.

 3

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014); Agencies’ Strategic Plans Under GPRA: Key 

Questions to Facilitate Congressional Review, GAO/GGD-10.1.16 (Washington, D.C.: 

May 1997); and Managing for Results: Critical Issues for Improving Federal Agencies’

Strategic Plans, GAO/GGD-97-180 (Washington, D.C.: Sept. 16, 1997).

4

GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012).
Appendix II: Selected Federal Actions since 

2013 to Address State and Local Challenges in 

Implementing Next Generation 911 (NG911), as 

of October 2017

Page 30 GAO-18-252 Next Generation 911

Challenges Description of challenge Federal actions

Funding State and local funding may 

not be sufficient to support 

costs associated with 

transitioning to NG911 

equipment and infrastructure. 

Grant resources: The National Highway Traffic Safety Administration’s 

(NHTSA) National 911 Program issued on its website a list clarifying which of 

the fiscal year 2016 emergency-communications grants may be used for 

NG911 services. Program officials said they developed this list in collaboration 

with the Department of Homeland Security (DHS).

Cost study: NHTSA’s National 911 Program and the National 

Telecommunications and Information Administration (NTIA), in consultation 

with the Federal Communications Commission (FCC) and DHS, plan to issue 

a study of the range of costs for 911 call centers and service providers to 

implement NG911 systems and on the nationwide progress of implementing 

NG911 services.

Grant program: NHTSA and NTIA are preparing to jointly administer a $115 

million grant program to improve 911 services, including the adoption and 

operation of NG911 services. NHTSA and NTIA expect to award the grants in 

2018.

Funding mechanisms: An advisory body tasked by FCC issued a reporta in 

2016 that identified common costs and funding mechanisms for 911 officials to 

consider. The report also introduced a 911 funding sustainment model 

designed for use by 911 officials to calculate their financial needs to support a 

transition to NG911 implementation. 

Evolving technology 

and operations

Transitioning from legacy 

infrastructure to Internet 

Protocol-based systems 

presents technical and 

operational challenges such 

as interoperability and 

cybersecurity risks. 

Guides on technology standards and procurement practices: In 2017, 

NHTSA’s National 911 Program issued an annual guideb on emergencycommunications technology standards that stressed the importance of using 

open technology standards for NG911 services. The National 911 Program 

issued another guidec in 2016 that provides information on procuring goods 

and services related to NG911 such as practices for call centers to consider 

when developing their request for proposals and contracts.

Examining emerging technology issues: In 2017, FCC tasked a publicprivate advisory council to recommend how FCC can promote the NG911 

transition, enhance the reliability of NG911, and mitigate the threat of 911 

outages. Prior to that tasking, the FCC advisory council issued a reportd in 

2016 that explored location-based routing issues and discussed transition

considerations from legacy 911 to NG911.

NG911 cybersecurity guide and technical assistance: DHS, with input from 

NHTSA’s National 911 Program according to DHS officials, issued a guidee in 

2016 that identifies cybersecurity risks for NG911 and risk mitigation 

strategies. In addition, DHS provides NG911 technical assistance for states 

seeking assistance with strategic planning and technology integration. In a 

separate effort, an advisory body tasked by FCC to examine 911 call center 

architecture issued a reportf

in 2016 that provides a cybersecurity selfassessment tool for call centers and guidance on cybersecurity strategies. 

Appendix II: Selected Federal Actions since 

2013 to Address State and Local Challenges 

in Implementing Next Generation 911 

(NG911), as of October 2017
Appendix II: Selected Federal Actions since

2013 to Address State and Local Challenges in 

Implementing Next Generation 911 (NG911), as 

of October 2017

Page 31 GAO-18-252 Next Generation 911

Challenges Description of challenge Federal actions

Governance States may face a range of 

challenges related to 

evolving roles for state and 

local 911 authorities that 

could hinder NG911 

implementation.

Guides on state and legislative planning: NHTSA’s National 911 Program 

issued guides on state 911 planningg and legislative issues to consider for 

NG911h and awarded a contract in September 2017 to update those guides. In 

2016, the National 911 Program issued a guidei based on the experiences of 

Iowa, Minnesota, North Dakota, and South Dakota that identifies practices to 

consider for states interconnecting NG911 networks across state lines.

Exploring NG911 governance implementation issues: In 2016, an advisory 

body tasked by FCC issued a reportjthat identifies NG911 governance 

approaches, issues, and recommendations for states, localities, and call 

centers to consider when planning for the deployment of NG911. In 2013, FCC 

also issued a reportk that details recommendations to Congress for 

transitioning from legacy 911 to NG911 networks.

Guide on emergency communications governance structures: In 2015, 

DHS and the National Council of Statewide Interoperability Coordinators 

issued a guidel

that provides characteristics of effective governance 

approaches and best practices for officials to establish, assess, and update 

their governance structures.

Source: GAO analysis of NHTSA, NTIA, FCC, and DHS information. | GAO-18-252

a

FCC, Task Force on Optimal Public Safety Answering Point Architecture, Working Group 3 Report: 

Funding Sustainment Model (December 2016).

b

Department of Transportation, NHTSA, National 911 Program, Next Generation 911 (NG911) 

Standards Identification and Review (Washington, D.C.: March 2017).

c

Department of Transportation, NHTSA, National 911 Program, Next Generation 911 Procurement 

Guidance (Washington, D.C.: October 2016).

d

FCC, Communications Security, Reliability and Interoperability Council V, Working Group 1, Evolving 

911 Services, Final Report – Task 2: 911 Location-Based Routing (September 2016).

e

DHS, Office of Emergency Communications, Cyber Risks to Next Generation 911 (2016).

f

FCC, Task Force on Optimal Public Safety Answering Point Architecture, Adopted Final Report

(January 2016). Additional information on cybersecurity planning for NG911 can be found in FCC, 

Task Force on Optimal Public Safety Answering Point Architecture, Working Group 1, Optimal 

Cybersecurity Approach for PSAPs, Supplemental Report (December 2016).

g

Department of Transportation, NHTSA, Model State 911 Plan (February 2013).

h

Department of Transportation, NHTSA, Guidelines for State NG9-1-1 Legislative Language 

(November 2012).

i

Department of Transportation, NHTSA, National 911 Program, Next Generation 911 (NG9-1-1) 

Interstate Playbook: Implementing State-to-State 9-1-1 Connectivity (Washington, D.C.: October 

2016).

j

FCC, Task Force on Optimal Public Safety Answering Point Architecture, Adopted Final Report

(January 2016). Additional information on governance planning for NG911 can be found in FCC, Task 

Force on Optimal Public Safety Answering Point Architecture, Working Group 2, Phase II 

Supplemental Report: NG9-1-1 Readiness Scorecard (December 2016).

k

FCC, Legal and Regulatory Framework for Next Generation 911 Services, Report to Congress and 

Recommendations (February 2013).

l

DHS, Emergency Communications Governance Guide for State, Local, Tribal, and Territorial Officials

(September 2015).
Appendix III: Comments from the U.S. 

Department of Transportation

Page 32 GAO-18-252 Next Generation 911

Appendix III: Comments from the U.S. 

Department of Transportation
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 33 GAO-18-252 Next Generation 911

Mark L. Goldstein, (202) 512-2834 or GoldsteinM@gao.gov

In addition to the contact named above, Andrew Huddleston (Assistant 

Director), Jean Cook (Analyst in Charge), Camilo Flores, Steven 

Rabinowitz, Malika Rice, Kelly L. Rubin, Michael Sweet, Hai Tran, Marika 

Van Laan, and Michelle Weathers made key contributions to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101301)
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 website (http://www.gao.gov). Each weekday afternoon, GAO 

posts on its website newly released reports, testimony, and correspondence. To 

have GAO e-mail you a list of newly posted products, go to http://www.gao.gov

and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of production and 

distribution and depends on the number of pages in the publication and whether 

the publication is printed in color or black and white. Pricing and ordering 

information is posted on GAO’s website, http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537.

Orders may be paid for using American Express, Discover Card, MasterCard, 

Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, LinkedIn, Twitter, and YouTube.

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts.

Visit GAO on the web at www.gao.gov and read The Watchblog.

Contact:

Website: http://www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

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

Orice Williams Brown, Managing Director, WilliamsO@gao.gov, (202) 512-4400, 

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

Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

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

Washington, DC 20548

James-Christian Blockwood, Managing Director, spel@gao.gov, (202) 512-4707

U.S. Government Accountability Office, 441 G Street NW, Room 7814, 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Strategic Planning and 

External Liaison

Please Print on Recycled Paper.