a

GAO

United States Government Accountability Office

Report to the Ranking Member, 

Committee on Oversight and Government 

Reform, House of Representatives

November 2007 CONTINUITY OF 

OPERATIONS

Selected Agencies 

Tested Various 

Capabilities during 

2006 Governmentwide 

Exercise

GAO-08-185
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

November 2007

CONTINUITY OF OPERATIONS 

Selected Agencies Tested Various Capabilities during

2006 Governmentwide Exercise 

Highlights of GAO-08-185, a report to the 

Ranking Member, Committee on 

Oversight and Government Reform, 

House of Representatives

To ensure the availability of 

essential government services in 

emergencies, federal agencies are 

required to develop continuity of 

operations (COOP) plans. The 

Federal Emergency Management 

Agency (FEMA), under the 

Department of Homeland Security

(DHS), is responsible for 

disseminating guidance to federal 

agencies on developing plans, as 

well as conducting governmentwide exercises every other year to

assess federal continuity readiness. 

In June 2006, FEMA conducted an

exercise called Forward Challenge 

06, to allow agencies to activate

COOP plans, deploy essential 

personnel to alternate facilities, 

and perform essential functions. 

GAO was asked to describe the

extent to which agencies tested

continuity plans and procedures, 

personnel, and resources during 

the June 2006 exercise. To do this, 

GAO selected the eight civilian 

agencies with significant 

responsibilities during national 

disasters, analyzed agency exercise 

documentation, and interviewed 

officials to determine which test

and exercise activities each agency

included in its participation. 

What GAO Recommends

GAO recommends that FEMA 

require agencies participating in 

future governmentwide exercises

to document the specific test and 

exercise activities conducted. In 

commenting on a draft of this

report, DHS agreed with GAO’s 

recommendation and stated that it 

intends to refine its assessment 

program and improve the level of 

evaluation documentation. 

During Forward Challenge 06, the eight agencies GAO reviewed performed 

various test and exercise activities related to COOP plans and procedures, 

personnel, and resources. In many cases, agencies provided documentation to 

substantiate the specific test and exercise activities performed. However, in 

other cases, agencies reported conducting such activities but did not provide 

supporting documentation. Finally, agencies also reported not testing or 

exercising certain capabilities during the exercise. In these cases,

participating agencies may have addressed these capabilities in other tests 

and exercises conducted during the year, which were outside the scope of 

GAO’s review. The table below presents a summary of the extent to which 

agencies conducted various test and exercise activities during the 

governmentwide exercise. 

Agencies’ inability to substantiate many of the test and exercise activities that 

they reported performing during Forward Challenge 06 was due in part to the 

absence of specific guidance on what should be documented in such 

exercises. While FEMA directed participating agencies to document issues

and requirements for corrective action, significant findings, and important 

observations during the Forward Challenge 06 exercise, it did not require

participating agencies to document the specific activities from their test and 

exercise programs that they conducted during the exercise. Without adequate 

records of what has been tested during a major governmentwide exercise, 

agencies lack assurance that they have adequately tested their continuity 

capabilities at the frequency outlined in FEMA guidance, which may limit their 

ability to fully evaluate their readiness to respond to a disruption. In addition, 

adequate records can reduce the potential negative impact of turnover in key 

personnel due to attrition or change in administration, and strengthen agency 

internal control capabilities. 

Agency Testing and Exercising of COOP Plans and Procedures, Personnel, and Resources

Category Test and exercise activities

Tested and 

documented 

Tested but not

documented 

Not tested 

during exercisea

Plans and Essential Functions 4 4 0 

Procedures Activation and Notification:

Activation 4 3 1

Notification—COOP Personnel 3 4 1

Notification—Non-COOP Personnel 1 5 2

Notification—Alternate Facility 2 2 4

Notification—FEMA Operations Center 6 1 1 

Debriefing 8 0 0

Personnel COOP Personnel Participation 5 3 0 

Resources Interoperable Communications:

Communications Capabilities 8 0 0

Communication with Internal Contacts 6 2 0 

Communication with External Contacts 4 4 0 

Vital Records 6 2 0

Backup Power 1 1 6

Source: GAO.

a

Participating agencies may have addressed these capabilities in other tests and exercises conducted

during the year, which were outside the scope of GAO’s review. 

To view the full product, including the scope 

and methodology, click on GAO-08-185. 

For more information, contact Linda Koontz at

(202) 512-6240 or koontzl@gao.gov. 
Page i GAO-08-185 Continuity of Operations

Contents

Letter 1

Recommendation for Executive Action 3

Agency Comments and Our Evaluation 3

Appendixes

Appendix I: October 4, 2007, Briefing to Staff of the Ranking Member, 

House Committee on Oversight and Government Reform 6

Appendix II: Comments from the Department of Homeland Security 62

Abbreviations

COOP continuity of operations 

DHS Department of Homeland Security

FEMA Federal Emergency Management Agency

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

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Page 1 GAO-08-185 Continuity of Operations

United States Government Accountability Office

Washington, D.C. 20548

A

November 19, 2007 Letr

The Honorable Tom Davis

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

Dear Mr. Davis,

As you know, essential government services can be interrupted by a range 

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

emergencies. To ensure that these services are available in emergencies, 

federal agencies are required to develop continuity of operations (COOP) 

plans. The Federal Emergency Management Agency (FEMA), under the 

Department of Homeland Security (DHS), is responsible for disseminating 

guidance to federal agencies on developing COOP plans as well as 

conducting governmentwide exercises every other year as an assessment 

of federal continuity readiness. In June 2006, FEMA conducted an exercise, 

called Forward Challenge 06, designed to allow agencies to activate their 

plans, deploy essential personnel to alternate facilities, and perform 

essential functions.

We previously reported on COOP test, training, and exercise requirements 

at your request,1

 and determined that agency plans did not generally 

comply with FEMA’s guidance. We reported that although a 

governmentwide continuity exercise hosted by FEMA in May 2004 helped 

agencies comply with test, training, and exercise requirements, few 

agencies had documented that they conducted internal tests, training, and 

exercises at the recommended frequency.

You requested that we evaluate agency participation in Forward Challenge 

06. Specifically, we agreed to describe the extent to which selected 

agencies tested their continuity plans and procedures, personnel, and

1

GAO, Continuity of Operations: Agency Plans Have Improved, but Better Oversight 

Could Assist Agencies in Preparing for Emergencies, GAO-05-577 (Washington, D.C.:

Apr. 28, 2005), and Continuity of Operations: Selected Agencies Could Improve Planning 

for Use of Alternate Facilities and Telework during Disruptions, GAO-06-713 (Washington, 

D.C.: May 11, 2006).
Page 2 GAO-08-185 Continuity of Operations

resources during the governmentwide exercise. For purposes of our 

review, we selected eight civilian agencies because of their significant 

responsibilities under the National Response Plan, which outlines the roles 

of federal agencies in response to national disasters. Specifically, these 

eight agencies were designated as coordinators of emergency support 

functions and as such, have responsibilities for coordinating federal 

interagency support to states and other federal agencies during 

emergencies of national significance. For example, DHS is responsible for 

coordinating urban search and rescue efforts.2

To address our objective, we obtained and reviewed documentation 

regarding test and exercise activities during Forward Challenge 06 from the 

selected agencies. We analyzed the documentation and interviewed agency 

officials to determine which of the test and exercise activities each agency 

included in its participation in Forward Challenge 06.

We conducted our review from May 2006 through September 2007 in 

accordance with generally accepted government auditing standards. The 

extended period of time for our analysis was due to a delay in receiving 

documentation from DHS. First, 2 days before the exercise, we were 

informed by DHS that we would not be able to observe agencies’ 

participation, despite a previous agreement to do so. Subsequently, we 

requested documentation on agencies’ participation. As we testified in 

April 2007, this documentation was not provided until March of this year.3

Based on our review of the documentation, we were able to address the 

objective.

On October 4, 2007, we provided your office with a briefing on the results 

of this review. This report provides the briefing slides to you and officially 

transmits our recommendation to the Secretary of Homeland Security. The 

slides from the briefing are included as appendix I.

In summary, we determined that during Forward Challenge 06, the eight 

agencies performed various test and exercise activities related to COOP 

plans and procedures, personnel, and resources. In many cases, agencies 

provided documentation to substantiate the specific test and exercise 

2

DHS, National Response Plan (Washington, D.C.: December 2004).

3

GAO, Department of Homeland Security: Observations on GAO Access to Information on 

Programs and Activities, GAO-07-700T (Washington, D.C.: Apr. 25, 2007).
Page 3 GAO-08-185 Continuity of Operations

activities performed. However, in other cases, agencies reported 

conducting such activities but did not provide supporting documentation. 

Finally, agencies also reported not testing or exercising certain capabilities 

during the exercise. In these cases, participating agencies may have 

addressed these capabilities in other tests and exercises conducted during 

the year, which were outside the scope of our review.

Agencies’ inability to substantiate many of the test and exercise activities 

that they reported performing during Forward Challenge 06 was due in part 

to the absence of specific guidance on what should be documented in such 

exercises. While FEMA directed participating agencies to document issues 

and requirements for corrective action, significant findings, and important 

observations during the Forward Challenge 06 exercise, it did not require 

participating agencies to document the specific activities from their test 

and exercise programs that they conducted during the exercise. Without 

adequate records of what has been tested during a major governmentwide 

exercise, agencies lack assurance that they have adequately tested their 

continuity capabilities at the frequency outlined in FEMA guidance, which 

may limit their ability to fully evaluate their readiness to respond to a 

disruption. In addition, adequate records can reduce the potential negative 

impact of turnover in key personnel due to attrition or change in 

administration, and strengthen agency internal control capabilities.

Recommendation for 

Executive Action

To better assist agencies in assessing their readiness to respond to 

disruptions, we recommend that the Secretary of Homeland Security direct 

the FEMA Director to require agencies participating in future 

governmentwide exercises to document the specific test and exercise 

activities conducted.

Agency Comments and 

Our Evaluation

We received written comments on a draft of our report from the Director of 

the Department of Homeland Security’s GAO/OIG Liaison office. (These 

comments are reproduced in app. II) In commenting on the report, the 

Director stated that the department agreed with our recommendation. In 

addition, the Director stated that the department had already complied 

with the recommendation during Forward Challenge 06, citing the general
Page 4 GAO-08-185 Continuity of Operations

guidance provided in Federal Preparedness Circular 654 as well as 

evaluations compiled by internal and external evaluators during the 

exercise. The Director stated further that the level of documentation was 

higher than we reported as demonstrated by external evaluations that he 

said did not meet GAO audit standards.

We disagree that FEMA provided adequate guidance on documentation and 

that the level of documentation was higher than we reported. While the 

guidance provided general direction to agencies to document their test, 

training, and exercise programs, it did not specify that agencies were to 

document the extent to which each essential function and supporting 

capability was tested during this exercise. In addition, we considered the 

results of the exercise evaluations in our analysis; but in many cases, these 

evaluations did not specify which essential functions and supporting 

capabilities were tested during the exercise. The value of such 

documentation is not to meet GAO audit standards, as the Director asserts. 

Instead, as noted in our briefing, agencies need to fully document their 

exercise activities to ensure that they are following FEMA guidance, to 

mitigate the effects of potential staff turnover, and to ensure appropriate 

internal controls. Nevertheless, the Director stated that FEMA intends to 

refine its assessment program, giving specific attention to improving the 

level of evaluation documentation. The Director also included technical 

comments that we have addressed, as appropriate.

As agreed with your staff, unless you publicly announce its contents earlier, 

we plan no further distribution of this report until 30 days after its date. At 

that time, we will send copies of this report to the Secretary of Homeland 

Security, and other interested parties. This report will also be available at 

no charge on the GAO Web site at http://www.gao.gov.

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

at (202) 512-6240 or koontzl@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page

4

Federal Preparedness Circular 65 is guidance to the federal executive branch for use in 

developing viable and executable contingency plans that facilitate the performance of 

essential functions during any emergency.
Page 5 GAO-08-185 Continuity of Operations

of this report. Key contributions to this report were made by James R. 

Sweetman, Jr., Assistant Director; Lorne Cammack; Alma Cole; Barbara 

Collier; Matthew Grote; Sairah Ijaz; Nick Marinos; Morgan Walts; and Kim 

Zelonis.

Sincerely yours,

Linda D. Koontz 

Director, Information Management Issues
Page 6 GAO-08-185 Continuity of Operations

Appendix I

October 4, 2007, Briefing to Staff of the Apendxies

Ranking Member, House Committee on 

Oversight and Government Reform ApendxiI

Continuity of Operations: Selected Agencies Tested Various

Capabilities During 2006 Governmentwide Exercise

Briefing for the Staff of the 

Ranking Member 

Committee on Oversight and Government Reform 

House of Representatives 

October 4, 2007 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 7 GAO-08-185 Continuity of Operations

2

 

Outline of Briefing 

Introduction

Objective, Scope, and Methodology

Results in Brief

Background

Agencies Tested Various Capabilities

x Plans and Procedures

x Personnel

x Resources

Conclusions

Recommendation

Agency Comments and our Evaluation 

Attachment 1: Agencies Reviewed

Attachments 2 to 9: Individual Agency Results 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 8 GAO-08-185 Continuity of Operations

3

 

Introduction

Events in recent years have underscored the need for federal agencies to be prepared to respond 

effectively to a variety of emergency situations. Specifically, federal operations and facilities have 

been disrupted by a range of events, including

x the terrorist attacks on September 11, 2001, and at Oklahoma City on April 19, 1995; 

x severe weather events, such as hurricanes Katrina, Rita, and Wilma in 2005; and 

x building-level events, such as asbestos contamination at the Department of the Interior’s 

headquarters.

Such disruptions, particularly if prolonged, can lead to interruptions in essential government services. 

Prudent management, therefore, requires that federal agencies develop plans for ensuring the 

continuity of such services in emergency situations. These are referred to as continuity of operations 

(COOP) plans. These plans lay out an agency’s approach to maintaining services, ensuring proper 

authority for government actions, and protecting vital assets. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 9 GAO-08-185 Continuity of Operations

4

 

Introduction

Presidential Decision Directive 67 established the Federal Emergency Management Agency (FEMA) 

as the lead agency for COOP planning across the executive branch. FEMA's Federal Preparedness 

Circular (FPC) 65 provides guidance to federal agencies on developing COOP plans and carrying 

out test, training, and exercise programs to ensure their effectiveness. The guidance states that 

agencies are to test and exercise plans and procedures, personnel, and resources at specific 

frequencies during each year. These tests and exercises should include the following capabilities: 

Plans and Procedures. Each agency is to exercise the capability to continue its essential

functions—those functions that enable it to provide vital services, exercise civil authority, maintain 

safety, and sustain the economy during an emergency—on an annual basis. In addition, each 

agency should test its continuity plan’s activation and notification procedures on a quarterly basis, 

including notifying COOP personnel (that is, staff needed to perform essential functions, as 

designated by the agency), non-COOP agency employees, the alternate facility, and the FEMA 

Operations Center.1

 For each exercise performed, a debriefing should be conducted for participants 

to identify weaknesses in plans and procedures and recommend plan revisions. 

Personnel. Each agency should conduct an annual exercise that involves the movement of COOP 

personnel to the agency alternate facility2

 to ensure the agency’s ability to perform essential functions 

during an emergency. 

1

 The FEMA Operations Center is responsible for, among other things, facilitating information sharing between FEMA and non-FEMA 

entities, and providing a status of on-going incidents, responses or potential events, during an emergency. 

2

 An alternate facility provides a physical location from which to conduct essential functions if the agency’s usual facilities are

unavailable.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 10 GAO-08-185 Continuity of Operations

5

 

Introduction

Resources. Each agency should conduct tests of resources required to perform essential functions. 

These tests should include quarterly tests of its communications capabilities, such as secure and 

non-secure voice, video, fax, and data connectivity, Internet access, and email; as well as annual 

exercises of its ability to communicate with internal and external key contacts. Each agency should 

also test access to vital records and critical information systems (electronic and hard-copy records 

and information systems needed to support essential functions) semi-annually, and backup power 

annually.

FPC 65 further requires FEMA to conduct a governmentwide continuity exercise every other year as 

a tool to assess and validate federal continuity readiness. In June 2006, FEMA conducted Forward 

Challenge 06, a governmentwide continuity exercise designed to allow agencies to activate their 

COOP plans, deploy essential personnel to alternate facilities, and perform essential functions as a 

means of assessing their mission readiness. FEMA guidance for this exercise required agencies to 

respond appropriately to the exercise scenarios using their existing plans. Agencies also had the 

option to test additional capabilities or address internal scenarios if they did not interfere with the 

overall exercise or the activities of other agencies.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 11 GAO-08-185 Continuity of Operations

6

 

Objective, Scope, and Methodology 

As agreed with your office, our objective was to describe the extent to which selected agencies 

tested their continuity plans and procedures, personnel, and resources during the Forward Challenge 

06 governmentwide exercise.

For purposes of our review, we selected eight civilian agencies because of their significant 

responsibilities under the National Response Plan, which outlines the roles of federal agencies in 

response to national disasters.3

 Specifically, these eight agencies were designated as coordinators of 

emergency support functions and as such, have responsibilities for coordinating federal interagency 

support to states and other federal agencies during emergencies of national significance. For 

example, DHS is responsible for coordinating urban search and rescue efforts. The eight selected 

agencies and their respective responsibilities for emergency support functions are listed in 

attachment 1. 

3

 DHS, National Response Plan (Washington, D.C.: December 2004). 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 12 GAO-08-185 Continuity of Operations

7

 

Objective, Scope, and Methodology 

To address our objective, we obtained and reviewed documentation regarding test and exercise 

activities during Forward Challenge 06 from the agencies. Documentation included internal and 

external agency after action reports and results of external evaluations conducted during the 

exercise. We analyzed the documentation to determine which of the test and exercise activities each 

agency included in its participation in Forward Challenge 06 and interviewed officials about gaps in 

their documentation. We then created summary tables outlining activities that were supported by 

documentation (identified as “tested and documented”), and activities that agencies reported as 

having conducted during the exercise but for which they did not provide documentation (identified as 

“tested but not documented”). 

We did not identify and assess other tests and exercises that agencies may have conducted during 

the year and thus, did not assess their compliance with the requirements in FPC 65. As a result, we 

are providing only a description of the capabilities tested during Forward Challenge 06. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 13 GAO-08-185 Continuity of Operations

8

 

Objective, Scope, and Methodology 

We conducted our review from May 2006 through September 2007 in accordance with generally 

accepted government auditing standards. The extended period of time for our analysis is due to a 

delay in receiving documentation from DHS. First, we were informed by DHS two days before the 

exercise that we would not be able to observe agencies’ participation, despite a previous agreement 

to do so. Subsequently, we requested documentation on agencies’ participation. As we testified in 

April 2007, this documentation was not provided until March of this year.4

 Based on our review of the 

documentation, we were able to address the objective. 

4

 GAO, Department of Homeland Security: Observations on GAO Access to Information on Programs and Activities, GAO-07-700T 

(Washington, D.C.: Apr. 25, 2007). 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 14 GAO-08-185 Continuity of Operations

9

 

Results in Brief 

During Forward Challenge 06, the eight agencies performed various test and exercise activities 

related to COOP plans and procedures, personnel, and resources. In many cases, agencies 

provided documentation to substantiate the specific test and exercise activities performed. However, 

in other cases, agencies reported conducting such activities but did not provide supporting 

documentation. Finally, agencies also reported not testing or exercising certain capabilities during 

the exercise. In these cases, participating agencies may have addressed these capabilities in other 

tests and exercises conducted during the year, which were outside the scope of our review. The 

following table presents a summary of the extent to which agencies conducted various test and 

exercise activities during the governmentwide exercise.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 15 GAO-08-185 Continuity of Operations

10

 

Results in Brief 

 Agency Testing and Exercising of COOP Plans and Procedures, Personnel, and Resources 

Category Test and exercise activities 

Tested and 

documented 

Tested but not 

documented 

Not tested 

during exercise5

Plans and Essential Functions 4 4 0

Procedures Activation and Notification:

 

 

Activation 4 3 1

Notification—COOP Personnel 3 4 1

Notification—Non-COOP Personnel 1 5 2

Notification—Alternate Facility 2 2 4 

Notification—FEMA Operations Center 6 1 1

 Debriefing 8 0 0

Personnel COOP Personnel Participation 5 3 0

Resources Interoperable Communications:

Communications Capabilities 8 0 0 

Communication with Internal Contacts 6 2 0

Communication with External Contacts 4 4 0

Vital Records 6 2 0 

Backup Power 1 1 6 

5

 Participating agencies may have addressed these capabilities in other tests and exercises conducted during the year, which were

outside the scope of our review. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 16 GAO-08-185 Continuity of Operations

11

 

Results in Brief 

While FEMA directed participating agencies to document issues and requirements for corrective 

action, significant findings, and important observations during the Forward Challenge 06 exercise, it 

did not require participating agencies to document the specific activities from their test and exercise 

programs that they conducted during the exercise. The absence of specific guidance on what 

agencies should document contributed to the lack of documentation to support many of the test and 

exercise activities agencies described undertaking during Forward Challenge 06. Without adequate 

records of what has been tested during a major governmentwide exercise, agencies lack assurance 

that they have adequately tested their continuity capabilities at the frequency outlined in FEMA 

guidance, which may limit their ability to fully evaluate their readiness to respond to a disruption. In 

addition, adequate records can reduce the potential negative impact of turnover in key personnel due 

to attrition or change in administration, and strengthen agency internal control capabilities.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 17 GAO-08-185 Continuity of Operations

12

 

Results in Brief 

Recommendation and Agency Comments 

We are making a recommendation to the Secretary of Homeland Security aimed at improving the 

ability for agencies to fully assess their readiness to respond to disruptions by documenting the 

specific test and exercise activities they conduct during future governmentwide exercises.

In written comments on a draft of this briefing, the Director of the Department of Homeland Security’s 

GAO/OIG Liaison office stated that the Department agreed with our recommendation but has already 

provided adequate guidance on documentation requirements. Among other things, the Director also 

stated that that the level of documentation was higher than we reported as demonstrated by external 

evaluations that the Director said did not meet GAO audit standards. We disagree that FEMA 

provided adequate guidance on documentation and that the level of documentation was higher than 

we reported. FEMA’s guidance did not specify that agencies were to document the extent to which 

each essential function and supporting capability was tested. Similarly, the results of the evaluations 

did not document the extent to which agencies tested these functions and capabilities. The value of 

such documentation is not to meet GAO audit standards, as the Director asserts. Instead, as 

described in our briefing, agencies need to fully document their exercise activities to ensure that they 

are following FEMA guidance, mitigate the effects of potential staff turnover, and ensure appropriate 

internal controls. Nevertheless, the Director stated that FEMA intends to refine its assessment 

program, giving specific attention to improving the level of evaluation documentation. In addition, the 

Director provided technical comments, which we incorporated as appropriate. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 18 GAO-08-185 Continuity of Operations

13

 

Background

Guidance

Testing and exercising continuity capabilities are essential to demonstrating, assessing, and 

improving the ability of agencies to execute their COOP plans. Tests and exercises serve to assess, 

validate, or identify for subsequent correction specific aspects of COOP plans, procedures, and 

resources. FPC 65 outlines various tests and exercises of continuity capabilities (including plans and 

procedures, personnel, and resources) that agencies are to conduct throughout the year; they are 

not required to perform these activities during a governmentwide exercise. These activities include 

the following:

Plans and Procedures 

x Essential functions. On an annual basis, agency personnel must exercise the agency’s 

capability to continue its essential functions.

x Activation and notification. In order to ensure proper activation of COOP plans, agencies 

must have a decision-making process for activating their plans, as well as procedures for 

notifying personnel designated as being on the COOP team (COOP personnel), non-COOP 

agency employees, the alternate facility, and the FEMA Operations Center. The guidance 

calls for each agency to test such procedures on a quarterly basis.

x Debriefing. For each exercise performed by an agency, a comprehensive debriefing for 

participants should be conducted to identify systemic weaknesses in plans and procedures 

and recommend COOP plan revisions. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 19 GAO-08-185 Continuity of Operations

14

 

Background

Guidance

Personnel

x COOP personnel participation. Each agency should conduct an annual exercise that 

involves the movement of COOP personnel to the agency alternate facility to ensure the 

agency’s ability to perform essential functions during an emergency. 

Resources

x Interoperable communications. Each agency should conduct quarterly tests of its 

communications capabilities and annually exercise its ability to communicate with internal 

and external key contacts. 

x Vital records and critical information systems.6

 Each agency should perform semi-annual 

tests of plans for the recovery of vital records and critical information systems at alternate 

facilities.

x Backup power. Each agency should ensure that its alternate facility has the ability to run 

emergency power to allow essential functions to continue in any environment. The guidance 

states that such infrastructure systems are to be tested on an annual basis. 

6

 FPC 65 states that agency personnel must have access to and be able to use electronic and hard-copy records and information 

systems needed to perform their essential functions. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 20 GAO-08-185 Continuity of Operations

15

 

Background

Forward Challenge 06

FPC 65 requires FEMA to conduct a governmentwide exercise every other year as a tool to assess 

and validate federal continuity readiness. From June 19 to 22, 2006, FEMA conducted Forward 

Challenge 06, a governmentwide continuity exercise designed to allow agencies to activate their 

COOP plans, deploy essential personnel to alternate facilities, and perform essential functions as a 

means of assessing their mission readiness. FEMA guidance for this exercise required agencies to 

respond appropriately to the exercise scenarios using their existing plans. Agencies also had the 

option to test additional capabilities or address internal scenarios if they did not interfere with the 

overall exercise or the activities of other agencies. 

The scenario for the exercise involved the simulation of agency continuity response to heightened 

alert conditions involving weapons of mass destruction within the United States. During the exercise, 

each participating agency’s activities were observed by an official from another agency. These 

external evaluators provided the agency they observed with a checklist indicating which activities it 

included during its participation in the exercise. Forward Challenge 06 was conducted as a 

component of TOPOFF 4, a national homeland security preparedness exercise sponsored by DHS 

designed to, among other things, exercise the national ability to prevent, respond to, and recover 

from a weapon of mass destruction incident. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 21 GAO-08-185 Continuity of Operations

16

 

Background

Previous GAO Reports 

We previously reported on COOP test, training, and exercise requirements at the request of the 

Chairman, House Committee on Government Reform,7

 and determined that agency plans did not 

generally comply with FEMA’s guidance regarding tests, training, and exercises. We reported that 

although a governmentwide COOP exercise hosted by FEMA in May 2004 helped agencies comply 

with test, training, and exercise requirements, few agencies had documented that they conducted 

internal tests, training, and exercises at the recommended frequency. We recommended that FEMA 

develop a methodology for individual COOP assessments that independently evaluates executive 

branch agencies’ compliance with FPC 65, including the extent to which agencies plan, conduct, and 

document the necessary tests and exercises at the appropriate scope and frequency. 

In response to this recommendation, before Forward Challenge 06 FEMA coordinated independent 

evaluations of participating agency COOP plans in an effort to review the extent to which elements of 

a viable COOP capability were addressed. These assessments included a review of whether agency 

plans called for test, training, and exercise activities at the frequencies outlined in FEMA’s guidance. 

FEMA included the results of these assessments in the individual agency after-action reports it 

prepared following the governmentwide exercise. 

7

 GAO, Continuity of Operations: Agency Plans Have Improved, but Better Oversight Could Assist Agencies in Preparing for 

Emergencies, GAO-05-577 (Washington, D.C.: Apr. 28, 2005), and Continuity of Operations: Selected Agencies Could Improve 

Planning for Use of Alternate Facilities and Telework during Disruptions, GAO-06-713 (Washington, D.C.: May 11, 2006). 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 22 GAO-08-185 Continuity of Operations

17

 

Background

2008 Continuity Exercise 

FEMA is currently planning for a governmentwide continuity exercise for 2008. According to FEMA 

officials, the continuity exercise will take place over 3 days in late April 2008 and will include 

objectives similar to those of Forward Challenge 06.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 23 GAO-08-185 Continuity of Operations

18

 

Agencies Tested Various Capabilities 

During Forward Challenge 06, the eight agencies performed various test and exercise activities 

related to COOP plans and procedures, personnel, and resources. In many cases, agencies 

provided documentation to substantiate the specific test and exercise activities performed. However, 

in other cases, agencies reported conducting such activities but did not provide supporting 

documentation. Finally, agencies also reported not testing or exercising certain capabilities during 

the exercise. In these cases, participating agencies may have addressed these capabilities in other 

test and exercises conducted during the year, which were outside the scope of our review. The 

following slides summarize the test and exercise activities agencies conducted during the 

governmentwide exercise. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 24 GAO-08-185 Continuity of Operations

19

 

Agencies Tested Various Capabilities 

Plans and Procedures

Essential Functions

Essential functions are those functions that enable agencies to provide vital services, exercise civil 

authority, maintain the safety and well being of the general populace, and sustain the 

industrial/economic base in an emergency.

x Four of the agencies performed at least one essential function during the exercise. Some of 

the essential functions performed included ensuring command and control of the organization 

and providing information to the public. 

x The remaining four agencies reported exercising their essential functions but did not provide 

documentation substantiating which essential functions were exercised. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 25 GAO-08-185 Continuity of Operations

20

 

Agencies Tested Various Capabilities 

Plans and Procedures

Activation and Notification Procedures

Each agency develops a decision process for determining when to activate its COOP plans and 

procedures and, following activation, must notify appropriate points of contact: COOP and nonCOOP employees, its alternate facility, and the FEMA Operations Center. 

Activation

x Four agencies exercised activation procedures. For example, three agencies activated their 

plans as result of a change in exercise threat level conditions. 

x Of the remaining four agencies, three reported exercising their activation procedures, but did 

not provide documentation substantiating the reported activity. 

Notification—COOP Personnel 

x Three agencies exercised notification procedures for COOP personnel. For example, one 

agency used an automated notification system to contact personnel by phone and email 

upon COOP activation. 

x Of the remaining five agencies, four reported exercising the notification of their COOP 

personnel, but did not provide documentation substantiating the reported activity. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 26 GAO-08-185 Continuity of Operations

21

 

Agencies Tested Various Capabilities 

Plans and Procedures

Activation and Notification Procedures (continued)

Notification—Non-COOP Personnel 

x One agency exercised notification procedures for non-COOP personnel by sending a mass 

e-mail notifying nonessential personnel of the exercise and activation of its COOP plan.

x Of the remaining seven agencies, five reported exercising the notification of their non-COOP 

personnel, but did not provide documentation substantiating the reported activity. 

Notification—Alternate Facility 

x Two agencies exercised notification procedures for their alternate facilities by notifying 

personnel present at the alternate facility of COOP activation, triggering preparations. 

x Of the remaining six agencies, two reported exercising the notification of their alternate 

facility, but did not provide documentation substantiating the reported activity. 

Notification—FEMA Operations Center 

x Six agencies exercised notification procedures for the FEMA Operations Center. For 

example, one agency notified FEMA of COOP activation by e-mail one morning during the 

exercise.

x Of the remaining two agencies, one reported exercising the notification of the FEMA 

Operations Center, but did not provide documentation substantiating the reported activity. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 27 GAO-08-185 Continuity of Operations

22

 

Agencies Tested Various Capabilities 

Plans and Procedures

Comprehensive Debriefing

A comprehensive debriefing after agency COOP exercises allows participants to identify systemic 

weaknesses in plans and procedures and recommend plan revisions.

x All eight agencies identified strengths in their continuity capabilities and areas for 

improvement using questionnaires completed by participants or meetings with participants 

following the exercise. Each of the agencies outlined their results in bullets identifying the top 

three strengths and top three areas for improvement. For example, strengths identified by the 

agencies included conducting essential functions and the performance of alternate facility 

support staff; areas for improvement included notification procedures and communication 

with external contacts. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 28 GAO-08-185 Continuity of Operations

23

 

Agencies Tested Various Capabilities 

Personnel

COOP Personnel Participation

COOP personnel are agency officials assigned responsibility to report to an alternate site, as 

required, to perform agency essential functions. 

x Five agencies moved COOP personnel to alternate facilities to participate in the exercise. For 

example, one agency participated with 13 percent of its COOP personnel, while another 

agency participated with 89 percent. 

x The remaining three agencies reported exercising with their COOP personnel, but did not 

provide documentation substantiating the extent of COOP personnel participating in the 

exercise.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 29 GAO-08-185 Continuity of Operations

24

 

Agencies Tested Various Capabilities 

Resources

Interoperable Communications

The success of agency operations at an alternate facility depends on available and redundant 

communications with internal organizations, other agencies, critical customers, and the public. 

Communications Capabilities 

x All eight agencies tested communications capabilities during the exercise. Equipment tested 

by the agencies included secure video teleconference, phone, e-mail, and an online 

emergency collaboration system.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 30 GAO-08-185 Continuity of Operations

25

 

Agencies Tested Various Capabilities 

Resources

Interoperable Communications (continued)

Communication with Internal Contacts 

x Six agencies exercised communication with internal contacts, such as field offices, during the 

exercise.

x The remaining two agencies reported exercising communication with internal contacts, but 

did not provide documentation substantiating the reported contacts. 

Communication with External Contacts 

x In addition, four agencies exercised communication with external contacts, such as the White 

House.

x The remaining four agencies reported exercising communication with external contacts, but 

did not provide documentation substantiating the reported contacts. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 31 GAO-08-185 Continuity of Operations

26

 

Agencies Tested Various Capabilities 

Resources

Vital Records and Critical Information Systems

Vital records are electronic and hardcopy documents, references, records and information systems 

needed to support essential functions during an emergency.

x Six agencies tested access to vital records during the exercise. 

x The remaining two agencies reported testing access to vital records but neither provided 

documentation substantiating the reported activities.

Emergency Backup Power

Emergency backup power ensures that an agency’s alternate facility can allow essential functions to 

continue in any environment.

x One agency’s primary power source unintentionally went out during the exercise, triggering 

the use of backup power for several hours. 

x Of the remaining seven agencies, one agency reported testing its backup power, but did not 

provide documentation substantiating the reported test. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 32 GAO-08-185 Continuity of Operations

27

 

Agencies Tested Various Capabilities 

FEMA Provided Limited Guidance on Documentation 

FEMA published and disseminated an exercise plan prior to the start of Forward Challenge 06, 

outlining information regarding the scope and methodology of the exercise as well as the 

responsibilities of officials from participating agencies. Within the plan, FEMA stated that participating 

agency officials were to document issues and requirements for corrective action, significant findings 

and important observations during the Forward Challenge 06 exercise. In response, each agency we 

reviewed documented the main strengths and weaknesses of its exercise participation. 

In contrast, FEMA did not direct participating agencies to document the specific activities from their 

test and exercise programs that they conducted during Forward Challenge 06. The absence of 

guidance in this area contributed to the lack of documentation to support many of the test and 

exercise activities agencies described undertaking during Forward Challenge 06. Without adequate 

records of what has been tested during a major governmentwide exercise, agencies lack assurance 

that they have adequately tested their continuity capabilities at the frequency outlined in FEMA 

guidance, which, in turn, can limit the agencies’ assurance that the procedures, people, and 

resources they need to respond to a disruption will be available when needed. Developing and 

maintaining such documentation can also reduce the potential negative impact of turnover in key 

personnel—for example, turnover caused by attrition or a change in administration—by providing 

new staff with information regarding the status of their agency’s test and exercise program and 

overall continuity capability. Finally, such documentation can strengthen an agency’s internal control 

capability, by ensuring that relevant, reliable, and timely information is available for management 

decision-making and for external reporting purposes such as congressional oversight. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 33 GAO-08-185 Continuity of Operations

28

 

Conclusions

Agencies took advantage of the opportunity to test a number of their continuity capabilities during 

FEMA’s Forward Challenge 06 governmentwide exercise. The strengths and weaknesses each 

agency identified as a result of its participation can provide the basis for improvements in their 

continuity programs. However, in many cases, agencies reported conducting test and exercise 

activities but had not documented their efforts, due in part to FEMA’s guidance not requiring them to 

do so. Without adequate records of what has been tested during a major governmentwide exercise, 

agencies may lack assurance that they have adequately tested their continuity capabilities at the 

frequency outlined in FEMA guidance, which may limit their ability to fully evaluate their readiness to 

respond to a disruption. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 34 GAO-08-185 Continuity of Operations

29

 

Recommendation

To better assist agencies in assessing their readiness to respond to disruptions, we recommend that 

the Secretary of Homeland Security direct the FEMA Director to require agencies participating in 

future governmentwide exercises to document the specific test and exercise activities conducted.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 35 GAO-08-185 Continuity of Operations

30

 

Agency Comments and Our Evaluation 

In written comments on a draft of this briefing, the Director of the Department of Homeland Security’s 

GAO/OIG Liaison office stated that the Department agreed with our recommendation. In addition, the 

Director stated that the Department had already complied with the recommendation during Forward 

Challenge 06, citing the general guidance provided in FPC 65 as well as evaluations compiled by 

internal and external evaluators during the exercise. The Director stated further that the level of 

documentation was higher than we reported as demonstrated by external evaluations that he said 

did not meet GAO audit standards. Finally, the Director stated, with respect to our assertion that 

FEMA did not specify which aspect of an agency’s test and exercise program should be included in 

the exercise, that FEMA provided guidance to departments and agencies for the overarching 

objectives of the exercise.

We disagree that FEMA provided adequate guidance on documentation and that the level of 

documentation was higher than we reported. While the guidance provided general direction to 

agencies to document their test, training, and exercise programs, it did not specify that agencies 

were to document the extent to which each essential function and supporting capability was tested.

In addition, we considered the results of the exercise evaluations in our analysis, but in many cases 

these evaluations did not specify which essential functions and supporting capabilities were tested 

during the exercise. The value of such documentation is not to meet GAO audit standards, as the 

Director asserts. Instead, as noted in our briefing, agencies need to fully document their exercise 

activities to ensure that they are following FEMA guidance, to mitigate the effects of potential staff 

turnover, and to ensure appropriate internal controls. Nevertheless, the Director stated that FEMA 

intends to refine its assessment program, giving specific attention to improving the level of evaluation 

documentation.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 36 GAO-08-185 Continuity of Operations

31

 

Agency Comments and Our Evaluation 

Regarding the Director’s statement that FEMA provided guidance to departments and agencies 

through the exercise objectives and FPC 65, we agree that FEMA provided guidance that required 

agencies to respond to exercise scenarios using their continuity plans. As a result, we have revised 

the introduction and background sections of the briefing to clarify the scope of FEMA’s guidance. 

The Director also provided technical comments, which we incorporated as appropriate. [The 

Director’s comments are reproduced as appendix II]. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 37 GAO-08-185 Continuity of Operations

32

Attachment 1 

Agencies Reviewed 

The National Response Plan designates the following eight civilian agencies as coordinators of 

emergency support functions identified to provide support to states and other federal entities during 

national disasters. 

Agency/Coordinator Emergency Support Function Responsibilities 

Department of Agriculture Firefighting; Agriculture and Natural Resources 

Department of Energy Energy

Department of Health and Human 

Services

Public Health and Medical Services 

Department of Homeland Security

Communications; Emergency Management; Mass Care, Housing, and 

Human Services; Urban Search and Rescue; Public Safety and Security; 

Long-Term Community Recovery and Mitigation; and External Affairs 

Department of Justice Public Safety and Security 

Department of Transportation Transportation

Environmental Protection Agency Oil and Hazardous Materials Response 

General Services Administration Resource Support 

Source: DHS, National Response Plan (Washington, D.C.: December 2004).
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 38 GAO-08-185 Continuity of Operations

33

 

Attachment 2 

U. S. Department of Agriculture 

U.S. Department of Agriculture (USDA) 

Forward Challenge 06 Test and Exercise Activities 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

USDA Action

Plans and Procedures 

1. Essential Functions X Exercised all 43 of its essential functions during the exercise.

2. Activation and Notification Procedures 

a. Activation 

Procedures X Exercised its COOP activation procedures one morning during the exercise.

b. COOP Personnel 

Notification X Reported exercising the notification of its COOP personnel but did not provide documentation substantiating this activity.

c. Non-COOP 

Personnel

Notification

X

Reported exercising the notification of its non-COOP 

personnel, but did not provide documentation substantiating 

this activity.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 39 GAO-08-185 Continuity of Operations

34

 

Attachment 2 

U. S. Department of Agriculture 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

USDA Action

2. Activation and Notification Procedures (continued) 

d. Alternate Facility 

Notification X

Did not exercise the notification of its alternate facility during 

the exercise. According to USDA officials, personnel deployed 

to the alternate facility prior to the exercise. 

e. FEMA Operations 

Center Notification X

Exercised the notification of the FEMA Operations Center one 

morning during the exercise.

3. Debriefing X Conducted a debriefing identifying strengths and areas of 

improvement from the exercise. 

Personnel

4. COOP Personnel 

Participation X Exercised with 67 of its 75 COOP personnel. This is an 89 percent participation rate. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 40 GAO-08-185 Continuity of Operations

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Attachment 2 

U. S. Department of Agriculture 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

USDA Action

Resources

5. Interoperable Communications 

a. Communications 

Capabilities X Tested multiple forms of communication capabilities, including telephone, fax, and e-mail. 

b. Communication 

with Internal 

Contacts

X

Exercised communication with internal entities, including the 

Animal and Plant Health Inspection Service. 

c. Communication 

with External 

Contacts

X

Exercised communication with external contacts, including the 

White House. 

6. Vital Records 

X Tested access to vital records pre-positioned at the alternate 

facility.

7. Backup Power 

X

Reported that the backup power at its alternate facility was 

tested during the exercise by the facility’s host, but did not 

provide documentation substantiating this testing. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 41 GAO-08-185 Continuity of Operations

36

 

Attachment 3 

Department of Energy 

Department of Energy (DOE) 

Forward Challenge 06 Test and Exercise Activities 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

DOE Action

Plans and Procedures 

1. Essential Functions

X

Reported exercising its essential functions but did not provide 

documentation substantiating which essential functions were 

performed during the exercise.

2. Activation and Notification Procedures 

a. Activation 

Procedures X Exercised its COOP activation procedures one morning during the exercise.

b. COOP Personnel 

Notification X Reported exercising the notification of its COOP personnel but did not provide documentation substantiating this activity. 

c. Non-COOP 

Personnel

Notification X

Reported exercising the notification of its non-COOP personnel 

but did not provide documentation substantiating this activity. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 42 GAO-08-185 Continuity of Operations

37

 

Attachment 3 

Department of Energy 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

DOE Action

2. Activation and Notification Procedures (continued) 

d. Alternate Facility 

Notification X Did not exercise the notification of its alternate facility. 

e. FEMA Operations 

Center Notification X Exercised notification of the FEMA Operations Center one morning during the exercise. 

3. Debriefing 

X

Used questionnaires completed by exercise participants that 

identified main strengths and areas for improvement. 

Personnel

4. COOP Personnel 

Participation X

Reported exercising with over 220 personnel during the course 

of the exercise, but did not provide documentation 

substantiating a level of participation by COOP personnel. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 43 GAO-08-185 Continuity of Operations

38

 

Attachment 3 

Department of Energy 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

DOE Action

Resources

5. Interoperable Communications 

a. Communications 

Capabilities X Tested communications capabilities, including satellite phones and secure video teleconferencing. 

b. Communication 

with Internal 

Contacts

X

Exercised communication with internal contacts, including 

agency personnel using a web-based communication tool. 

c. Communication 

with External 

Contacts

X

Exercised communication with external contacts, including 

other agencies such as the Nuclear Regulatory Commission. 

6. Vital Records 

X Tested access to vital records during the exercise. 

7. Backup Power X Did not test backup power during the exercise.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 44 GAO-08-185 Continuity of Operations

39

 

Attachment 4 

Department of Health and Human Services 

Department of Health and Human Services (HHS) 

Forward Challenge 06 Test and Exercise Activities 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

HHS Action

Plans and Procedures 

1. Essential Functions X Exercised one of its essential functions during the exercise.

2. Notification Procedures 

a. Activation 

Procedures X Reported exercising activation procedures but did not provide documentation substantiating this activity.

b. COOP Personnel 

Notification X

Reported exercising notification procedures for COOP 

personnel but did not provide documentation substantiating this 

activity.

c. Non-COOP 

Personnel

Notification

X

Reported exercising non-COOP personnel notification 

procedures, but did not provide documentation substantiating 

this activity.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 45 GAO-08-185 Continuity of Operations

40

 

Attachment 4 

Department of Health and Human Services 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

HHS Action

2. Activation and Notification Procedures (continued) 

d. Alternate Facility 

Notification X

Reported exercising notification procedures for the alternate 

facility but did not provide documentation substantiating this 

activity.

e. FEMA Operations 

Center X Exercised the notification of the FEMA Operations Center during the exercise.

3. Debriefing

X

Conducted a debriefing and provided a summary list of 

strengths and areas for improvement. 

Personnel

4. COOP Personnel 

Participation X Deployed 105 COOP personnel for the exercise.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 46 GAO-08-185 Continuity of Operations

41

 

Attachment 4 

Department of Health and Human Services 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

HHS Action

Resources

5. Interoperable Communications 

a. Communications 

Capabilities X Tested several communications capabilities, including telephone and fax.

b. Communication 

with Internal 

Contacts

X

Exercised communication with internal entities, such as the 

Centers for Disease Control and Prevention.

c. Communication 

with External 

Contacts

X

Exercised communication with external contacts, such as the 

Homeland Security Operations Center.

6. Vital Records X Tested access to vital records during the exercise. 

7. Backup Power 

X

Did not test backup power during the exercise. HHS reported 

that backup power is tested on a monthly basis at the alternate 

facility.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 47 GAO-08-185 Continuity of Operations

42

 

Attachment 5 

Department of Homeland Security 

Department of Homeland Security (DHS) 

Forward Challenge 06 Test and Exercise Activities 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

DHS Action

Plans and Procedures 

1. Essential Functions X Reported exercising its essential functions, but did not provide 

documentation substantiating this activity.

2. Activation and Notification Procedures 

a. Activation 

Procedures X Reported exercising its activation procedures, but did not provide documentation substantiating this activity. 

b. COOP Personnel 

Notification X Exercised the notification of its COOP personnel. 

c. Non-COOP 

Personnel

Notification X

Reported that DHS headquarters COOP team personnel 

provided notification and individual instructions to non-COOP 

personnel within their respective organizations. DHS did not 

provide documentation substantiating this activity. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 48 GAO-08-185 Continuity of Operations

43

 

Attachment 5 

Department of Homeland Security 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

DHS Action

2. Activation and Notification Procedures (continued) 

d. Alternate Facility 

Notification X Exercised the notification of its alternate facility. 

e. FEMA Operations 

Center Notification X

Reported exercising the notification of the FEMA Operations 

Center, but did not provide documentation substantiating this 

activity.

3. Debriefing 

X

Conducted a debriefing identifying strengths and areas of 

improvement from the exercise. 

Personnel

4. COOP Personnel 

Participation X

Exercised with 24 of its 184 COOP personnel. This is a 13 

percent participation rate. DHS officials stated that additional 

COOP personnel participated in the exercise, but did not sign 

in.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 49 GAO-08-185 Continuity of Operations

44

 

Attachment 5 

Department of Homeland Security 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

DHS Action

Resources

5. Interoperable Communications 

a. Communications 

Capabilities X Tested its communications capabilities, including secure video teleconferencing.

b. Communication 

with Internal 

Contacts

X

Reported exercising communication with internal contacts as it 

exercised essential functions, but did not provide 

documentation substantiating the communication. 

c. Communication 

with External 

Contacts

X

Reported exercising communication with external contacts as it 

exercised essential functions, but did not provide 

documentation substantiating the communication. 

6. Vital Records X Reported testing access to its vital records, but did not provide 

documentation substantiating this testing. 

7. Backup Power 

X

Did not test its backup power during the exercise. DHS 

reported that the host of the alternate facility conducts regular 

tests of the backup power. 
Appendix I

October 4, 2007, Briefing to Staff of the 

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Oversight and Government Reform

Page 50 GAO-08-185 Continuity of Operations

45

 

Attachment 6 

Department of Justice 

Department of Justice (DOJ) 

Forward Challenge 06 Test and Exercise Activities 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

DOJ Action

Plans and Procedures 

1. Essential Functions 

X

Reported exercising its essential functions as if conducting a 

usual work day but did not provide documentation 

substantiating which essential functions were performed.

2. Activation and Notification Procedures 

a. Activation 

Procedures X Reported that exercising activation procedures was not part of the agency’s exercise plan. 

b. COOP Personnel 

Notification X Reported that exercising notification procedures was not part of the agency’s exercise plan. 

c. Non-COOP 

Personnel

Notification

X

Reported that exercising notification procedures was not part of 

the agency’s exercise plan. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 51 GAO-08-185 Continuity of Operations

46

 

Attachment 6 

Department of Justice 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

DOJ Action

2. Activation and Notification Procedures (continued) 

d. Alternate Facility 

Notification X Reported that exercising notification procedures was not part of the agency’s exercise plan. 

e. FEMA Operations 

Center Notification X Reported that exercising notification procedures was not part of the agency’s exercise plan. 

3. Debriefing 

X

Conducted a debriefing and provided a summary list of 

strengths and areas for improvement. 

Personnel

4. COOP Personnel 

Participation X Reported exercising with COOP personnel but did not provide documentation substantiating this activity.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 52 GAO-08-185 Continuity of Operations

47

 

Attachment 6 

Department of Justice 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

DOJ Action

Resources

5. Interoperable Communications 

a. Communications 

Capabilities X Tested multiple communication capabilities including cell phones, and a secure radio system.

b. Communication 

with Internal 

Contacts

X

Exercised communication with internal entities, including the 

U.S. Marshals Service. 

c. Communication 

with External 

Contacts

X

Reported exercising communication with external contacts as it 

exercised essential functions, but did not provide 

documentation substantiating the communication. 

6. Vital Records 

X Tested access to vital records during the exercise.

7. Backup Power 

X

Did not test its backup power capabilities during the exercise. 

DOJ stated that the alternate facility’s backup power is tested 

regularly by the site host. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 53 GAO-08-185 Continuity of Operations

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Attachment 7 

Department of Transportation 

Department of Transportation (DOT) 

Forward Challenge 06 Test and Exercise Activities 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

DOT Action

Plans and Procedures 

1. Essential Functions 

X

Reported exercising its essential functions, but did not provide 

documentation substantiating which functions were performed 

during the exercise.

2. Activation and Notification Procedures 

a. Activation 

Procedures X Reported exercising its activation procedures, but did not provide documentation substantiating this activity.

b. COOP Personnel 

Notification X

Reported notifying 90 percent of its COOP personnel through 

its alert system, but did not provide documentation 

substantiating the notification.

c. Non-COOP 

Personnel

Notification

X

Did not test the notification of its non-COOP personnel during 

the exercise. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 54 GAO-08-185 Continuity of Operations

49

 

Attachment 7 

Department of Transportation 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

DOT Action

2. Activation and Notification Procedures (continued) 

d. Alternate Facility 

Notification X

Did not exercise the notification of its alternate facility. DOT 

officials reported that the notification of the alternate facility was 

not applicable to the exercise because the facility managers 

were the leaders of the exercise.

e. FEMA Operations 

Center Notification X Exercised the notification of the FEMA Operations Center during the exercise.

3. Debriefing 

X

Conducted a debriefing identifying strengths and areas of 

improvement from the exercise.

Personnel

4. COOP Personnel 

Participation X

Reported that it exercised with 90 percent of its COOP 

personnel, but did not provide documentation substantiating 

this level of participation.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 55 GAO-08-185 Continuity of Operations

50

 

Attachment 7 

Department of Transportation 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

DOT Action

Resources

5. Interoperable Communications 

a. Communications 

Capabilities X Tested its communications capabilities. 

b. Communication 

with Internal 

Contacts

X

Reported exercising communication with internal contacts but 

did not provide documentation substantiating this 

communication.

c. Communication 

with External 

Contacts

X

Reported exercising communication with external contacts but 

did not provide documentation substantiating this 

communication.

6. Vital Records X Reported testing access to its vital records, but did not provide 

documentation substantiating the testing. 

7. Backup Power 

X

Did not test its backup power during the exercise. According to 

DOT officials, testing backup power is the responsibility of the 

host of the alternate facility. 
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 56 GAO-08-185 Continuity of Operations

51

 

Attachment 8 

Environmental Protection Agency 

Environmental Protection Agency (EPA) 

Forward Challenge 06 Test and Exercise Activities 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

EPA Action

Plans and Procedures 

1. Essential Functions X Exercised seven of its eight essential functions during the 

exercise.

2. Activation and Notification Procedures 

a. Activation 

Procedures X Exercised its COOP activation procedures.

b. COOP Personnel 

Notification X Exercised the notification of its COOP personnel by telephone and e-mail.

c. Non-COOP 

Personnel

Notification

X

Exercised notification of its non-COOP personnel by sending 

an e-mail out to all EPA employees during the exercise.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 57 GAO-08-185 Continuity of Operations

52

 

Attachment 8 

Environmental Protection Agency 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

EPA Action

2. Activation and Notification Procedures (continued) 

d. Alternate Facility 

Notification X Exercised the notification of its alternate facility by notifying personnel at the facility prior to COOP personnel deployment. 

e. FEMA Operations 

Center Notification X Exercised the notification of the FEMA Operations Center.

3. Debriefing 

X

Used questionnaires completed by exercise participants to 

identify main strengths and areas for improvement.

Personnel

4. COOP Personnel 

Participation X Exercised with 77 of its 109 COOP personnel. This is a 71 percent participation rate.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 58 GAO-08-185 Continuity of Operations

53

 

Attachment 8 

Environmental Protection Agency 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

EPA Action

Resources

5. Interoperable Communications 

a. Communications 

Capabilities X Tested its communications capabilities, including secure fax.

b. Communication 

with Internal 

Contacts

X

Exercised communication with internal contacts, including 

agency field offices.

c. Communication 

with External 

Contacts

X

Exercised communication with external contacts, including the 

Nuclear Regulatory Commission.

6. Vital Records 

X Tested access to vital records during the exercise.

7. Backup Power 

X

Tested its backup power capabilities when its primary power 

source unintentionally went out, triggering the use of backup 

power for several hours.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 59 GAO-08-185 Continuity of Operations

54

 

Attachment 9 

General Services Administration 

General Services Administration (GSA) 

Forward Challenge 06 Test and Exercise Activities 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

GSA Action

Plans and Procedures 

1. Essential Functions X Exercised all six of its essential functions.

2. Activation and Notification Procedures 

a. Activation 

Procedures X Exercised its activation procedures on one morning of the exercise.

b. COOP Personnel 

Notification X Exercised the notification of its COOP personnel through an email sent on one morning of the exercise.

c. Non-COOP 

Personnel

Notification

X

Reported exercising the notification of its non-COOP personnel 

but did not provide documentation substantiating this activity.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 60 GAO-08-185 Continuity of Operations

55

 

Attachment 9 

General Services Administration 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

GSA Action

2. Activation and Notification Procedures (continued) 

d. Alternate Facility 

Notification X

Reported exercising the notification of its alternate facility 

personnel but did not provide documentation substantiating this 

activity.

e. FEMA Operations 

Center Notification X Exercised the notification of the FEMA Operations Center on one morning of the exercise.

3. Debriefing 

X

Used questionnaires completed by exercise participants to 

identify main strengths and areas for improvement.

Personnel

4. COOP Personnel 

Participation X Exercised with 92 of its 153 COOP personnel. This is a 60 percent participation rate.
Appendix I

October 4, 2007, Briefing to Staff of the 

Ranking Member, House Committee on 

Oversight and Government Reform

Page 61 GAO-08-185 Continuity of Operations

56

 

Attachment 9 

General Services Administration 

Test and Exercise 

Activity

Tested and 

Documented

Tested but Not 

Documented

Not Tested 

GSA Action

Resources

5. Interoperable Communications 

a. Communications 

Capabilities X Tested multiple forms of communication capabilities, including cell phones and email.

b. Communication 

with Internal 

Contacts

X

Exercised communication with internal contacts, including nonCOOP personnel.

c. Communication 

with External 

Contacts

X

Reported exercising communication with external contacts, but 

did not provide documentation substantiating this 

communication.

6. Vital Records 

X Tested access to vital records during the exercise.

7. Backup Power X Did not test its backup power during the exercise. 
Page 62 GAO-08-185 Continuity of Operations

Appendix II

Comments from the Department of Homeland 

Security ApendxiI

(
Appendix II

Comments from the Department of Homeland 

Security

Page 63 GAO-08-185 Continuity of Operations

(

(310798)
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