DHS Pandemic Planning 

Needs Better Oversight, 

Training, and Execution
 

October 12, 2016 

OIG-17-02 
 

 

 

DHS OIG HIGHLIGHTS 

DHS Pandemic Planning

 Needs Better Oversight, Training, and Execution 

October 12, 2016 

Why We Did 

This Audit 

This review is the third in 

a series of audits on the 

Department of Homeland 

Security’s pandemic 

preparedness and 

response. This audit 

focused on whether the 

Department had adequate 

preparedness plans to 

continue its essential 

missions during a 

pandemic. 

What We 

Recommend 

We made seven 

recommendations to 

address the planning 

efforts made by DHS and 

its components to ensure 

continued operations 

during a pandemic. These 

recommendations, when 

implemented, should 

improve the efficiency and 

effectiveness of the 

program. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 254-4100, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

The Department has taken steps to develop a Departmental 

Pandemic Workforce Protection Plan intended to protect the 

workforce during a pandemic event. In addition, as a result 

of our previous audit recommendations, the Department 

has created an integrated logistics support plan for personal 

protective equipment. 

However, DHS cannot be assured that its preparedness 

plans can be executed effectively during a pandemic event. 

The Department did not always provide clear guidance or 

sufficient oversight to ensure components: 

x completed and finalized their pandemic plans; 

x verified pandemic training requirements were 

included in their plans; 

x identified the personal protective equipment needed 

for a pandemic response; and 

x met exercise and reporting requirements. 

Without such plan, the eight components may not be fully 

prepared to continue mission essential functions during a 

pandemic event. 

DHS Response 

The Department concurred with all seven recommendations 

and has initiated corrective actions that should improve the 

planning process in order to protect its employees during a 

pandemic event. We consider all seven recommendations 

resolved and open. 

www.oig.dhs.gov OIG-17-02 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington, DC 20528 / www.oig.dhs.gov 


October 12, 2016 


MEMORANDUM FOR: The Honorable Alejandro N. Mayorkas 

Deputy Secretary 

Department of Homeland Security 

Dr. Kathryn Brinsfield 

Assistant Secretary and Chief Medical Officer 

Office of Health Affairs 

FROM: John Roth ~X'-"'­ Inspector G~~ral 

SUBJECT: DHS Pandemic Planning Needs Better Oversight, 

Training, and Execution 

Attached for your information is our final report, DHS Pandemic Planning Needs 

Better Oversight, Training, and Execution. We have incorporated the formal 

comments from DHS components and offices. 

The report contains seven recommendations aimed at improving planning for 

pandemic preparedness. Your office concurred with all seven 

recommendations. Based on information provided in your response to the draft 

report, we consider all seven recommendations resolved and open. Once your 

office has fully implemented the recommendations, please submit a formal 

closeout letter to us within 30 days so that we may close the recommendations. 

The memorandum should be accompanied by evidence of completion of agreedupon corrective actions. 

Please send your response or closure request to 

OIGAuditsFollowup@oig.dhs.gov. 

Consistent with our responsibility under the Inspector General Act, we will 

provide copies of our report to congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will 

post the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact Maureen Duddy, 

Deputy Assistant Inspector General for Audits, at (617) 565-8723. 

Attachment 
 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

Background .................................................................................................... 1 

Results of Audit .............................................................................................. 2 

Components’ Pandemic Plans Did Not Meet All Department 

Requirements ........................................................................................ 2 

DHS Pandemic Personal Protective Equipment Planning Guidance and 

Oversight Needs Improvement................................................................ 6 

DHS Pandemic Reporting and Exercising Requirements Needs 

Additional Oversight .............................................................................. 7 

Recommendations ......................................................................................... 11 

Appendixes 

Appendix A: Objective, Scope, and Methodology .................................. 16 

Appendix B: DHS Comments to the Draft Report ................................. 18 

Appendix C: Office of Audits Major Contributors to This Report ........... 23 

Appendix D: Report Distribution .......................................................... 24 

Abbreviations 

CBP U.S. Customs and Border Protection 

CY calendar year 

ICE U.S. Immigration and Customs Enforcement
 

ILSP Integrated Logistics Support Plan
 

NPPD National Protection and Programs Directorate 

OIG Office of Inspector General 

OPS Office of Operations Coordination and Planning 

POD points of dispensing 

PPE personal protective equipment 

PWPP Pandemic Workforce Protection Plan 

TSA Transportation Security Administration 

USCIS U.S. Citizenship and Immigration Services
 

www.oig.dhs.gov OIG-17-02 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

This audit is the third in a series related to the Department of Homeland 

Security’s pandemic preparedness and response. We previously reported1 on 

the Department’s management of pandemic supplies as well as its 

implementation of enhanced screening measures in response to an Ebola 

outbreak. We conducted this audit to determine whether the Department has 

implemented adequate preparedness plans to continue mission essential 

functions during a pandemic. 

In 2009, the Department began planning for pandemics in response to an 

influenza outbreak and issued a pandemic plan for the DHS workforce. In April 

2013, the DHS Secretary directed the Department to update and expand its 

plan to include potential pandemic events and emerging infectious diseases. 

The Department issued its Pandemic Workforce Protection Plan (PWPP) in 

November 2013 to better prepare components to maintain essential functions 

during a pandemic event or in the wake of an emerging infectious disease. The 

PWPP required components to develop or update their own pandemic plans to 

enable mission readiness and the protection of DHS personnel. 

The PWPP required components to submit their plans to the Department by 

January 2014. To assist components in meeting PWPP requirements, three 

departmental offices were responsible for reviewing component plans: the Office 

of Operations Coordination and Planning (OPS), the Management Directorate, 

and the Office of Health Affairs. 

The Department provided guidance on: 

x workplace protective measures; 

x pandemic training and how to identify, maintain, and distribute 

pandemic supplies, such as personal protective equipment (PPE) and 

medication; 

x points of dispensing (POD) for either antiviral medication in a pandemic 

response or antibiotic medication in an anthrax incident; and 

x POD operations including exercises and reporting requirements. 

To manage DHS’ procurement and maintenance of PPE across its components, 

the Department issued supplemental guidance, the Integrated Logistics 

1 OIG-14-129 - DHS Has Not Effectively Managed Pandemic Personal Protective Equipment and 

Antiviral Medical Countermeasures, August 2014; and OIG-16-18 - DHS’ Ebola Response 

Needs Better Coordination, Training, and Execution, January 2016. 

www.oig.dhs.gov 1 OIG-17-02 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Support Plan (ILSP), in July 2015. This guidance established instructions to 

support and manage PPE. The ILSP required components to use risk 

assessments for determining the type and quantities of protection needed 

during a pandemic. Components were to use all of the guidance provided to 

improve their pandemic preparedness. 

Results of Audit 

The Department cannot be assured that its preparedness plans can be 

executed effectively during a pandemic event. The Department did not always 

provide clear guidance or sufficient oversight to ensure components: 

x completed and finalized pandemic planning efforts; 

x verified pandemic training requirements were included in all component 

plans; 

x identified PPE supplies needed for pandemic response; and 

x met POD exercise and reporting requirements. 

Components’ Pandemic Plans Did Not Meet All Department 

Requirements 

The Department’s PWPP required components to update or develop their 

pandemic plans and evaluate workplace protective measures. However, DHS 

did not ensure that the eight components reviewed had final approved plans 

that met all requirements. Without such plans, the eight components may not 

be fully prepared to continue mission essential functions during a pandemic 

event. 

The Department did not adequately oversee the planning process and fully 

review the eight components’ pandemic plans to ensure the plans met all the 

PWPP requirements. Senior officials at two of the components did not approve 

their own pandemic plan. Further, we found the Department did not ensure 

the eight components that we reviewed had final, approved plans. DHS did not 

complete a final review and provide approval of the eight components’ plans we 

tested (see table 1). 

www.oig.dhs.gov 2 OIG-17-02 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 1: Component PWPP Review Status as of March 2016 

Component Initial Review 

by OPS 

Approved by 

Component 

Senior Official 

Final 

Approval by 

OPS 

U.S. Customs and Border 

Protection Yes No No 

United States Coast Guard Yes Yes No 

Federal Emergency 

Management Agency Yes Yes No 

U.S. Immigration and 

Customs Enforcement Yes Yes No 

National Protection and 

Programs Directorate Yes Yes No 

United States Secret Service Yes Yes No 

Transportation Security 

Administration Yes Yes No 

U.S. Citizenship and 

Immigration Services Yes No No 

Source: Office of Inspector General (OIG) analysis of data provided by the Department and each 

component. 

The Department established OPS as the office responsible for reviewing 

component pandemic plans. After OPS’ initial review, components were to 

resubmit revised plans to OPS. However, the office responsible for reviewing 

pandemic plans changed, and the Department did not perform oversight 

continuously during this change. For about a year, it was unclear which office, 

if any, was responsible for conducting PWPP oversight. 

Among the requirements in the PWPP, components had to consider three types 

of workplace protective measures: 

x Administrative controls reduce employees exposure through training, 

telework, shift changes, and social distancing; 

x Engineering controls include ventilation, mechanical, and structural 

changes used to place a barrier between a worker and a hazard; and 

x	 PPE limits exposure by providing an immediate barrier between the 

employee and the hazard. PPE includes respirators, protective clothing, 

and gloves. 

The Department has not ensured the eight components we reviewed evaluated 

and incorporated workplace controls needed to protect its personnel. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

For example, we found: 

x	 The United States Secret Service: 

o	 addressed engineering controls in its headquarters pandemic plan, 

but did not ensure similar controls were addressed at field office 

locations; 

o	 did not assess administrative controls, including the telework 

capabilities of its workforce, and did not know which employees 

have the technology to telework; and 

o	 did not determine the quantity of pandemic PPE needed for 

employees located within its field offices. 

x	 U.S. Customs and Border Patrol addressed engineering controls in its 

draft headquarters pandemic plan; however, it has not ensured field 

office locations have addressed engineering controls. 

x	 U.S. Immigration and Customs Enforcement (ICE) did not complete the 

required risk assessment to evaluate the need for PPE controls and their 

applicability for specific employees during a pandemic. 

x	 The United States Coast Guard did not complete the required risk 

assessment to determine the quantity of pandemic PPE necessary for 

employees. 

The Department considers PPE (see figure 1) as the least effective protective 

control. According to its guidance, engineering controls (see figure 2) and 

administrative controls (see figure 3) have the greatest impact on minimizing 

exposure to pandemic risks. 

www.oig.dhs.gov 4 OIG-17-02 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 5 OIG-17-02 

Figure 1: Examples of Personal Protective Equipment 

Figure 2: Ex

Source: DHS OIG Source: DHS Science and Technology 

amples of Engineering Controls 

Source: Occupational Health and Safety Administration 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 6 OIG-17-02 

Figure 3: Example of Telework as an Administrative Control 

Source: Washington State Department of Transportation 

Pandemic Readiness Training 

The Department did not develop clear requirements for pandemic readiness 

training. The DHS PWPP requires components to train and exercise staff and 

senior leadership on pandemic readiness at least annually. However, the 

Department did not provide details on applicable trainings or the frequency 

needed to meet this requirement. As a result, seven of the components we 

reviewed did not always include the necessary details in their plans on how 

pandemic training requirements would be met, such as applicable trainings, 

methods for providing training, and how often pandemic training was required. 

DHS Pandemic Personal Protective Equipment Planning 

Guidance and Oversight Needs Improvement

The Department did not establish sufficient oversight or provide clear 

instruction on the number of days for which components should maintain a 

supply of PPE for pandemic response. The PWPP required components to keep 

sufficient PPE on hand until the supplies can be received. It, along with the 

ILSP, required components to determine the time it takes to order and receive 

replenishment supplies. However, the Department did not establish a deadline 

for meeting these requirements. 

We found three components — the Coast Guard, ICE, and the Secret Service — 

did not determine their pandemic PPE requirements. Additionally, ICE, U.S. 

Citizenship and Immigration Services (USCIS), and the Secret Service either 

could not identify their pandemic PPE stockpile or were unaware of whether 

local offices had pandemic PPE available on site. 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

The ILSP contained several requirements for maintaining pandemic PPE 

supplies; specifically: 

x Components with a pandemic PPE requirement are encouraged not to 

store PPE, but rather use a just-in-time2 approach. 

x Components with operational requirements for PPE are encouraged to 

maintain a supply based upon lead times for replenishment. 

x Delivery time for pandemic supplies is not to exceed 14 days. 

x Components with both operational and pandemic3 PPE requirements are 

encouraged to maintain enough pandemic supplies to provide protection 

for 5 operational days. 

The ILSP recommendations for stockpiling may not have been clear to 

components that identified a pandemic PPE need. The Federal Emergency 

Management Agency and USCIS determined they would not maintain PPE for 

pandemic purposes and, if needed, will order them using a just-in-time 

method, as recommended by the ILSP. While the Transportation Security 

Administration (TSA) planned to maintain a 2-day supply, U.S. Customs and 

Border Protection (CBP) and the National Protection and Programs Directorate 

(NPPD) identified a pandemic PPE supply that significantly exceeded the 

maximum lead time of 14 days. Specifically, CBP maintained a 60-day 

stockpile, and NPPD had a 90-day stockpile requirement. 

Without clear guidance and proper oversight, the Department cannot ensure 

components have the necessary amounts of PPE to protect their personnel 

during the initial stages of a pandemic response. The Department has initiated 

corrective actions to address these concerns. The Department reported it was 

revising its supplemental guidance and has drafted implementation 

instructions. These changes will clarify how PPE will be procured and 

managed. 

DHS Pandemic Reporting and Exercising Requirements Need 

Additional Oversight 

The Department did not provide clear guidance or oversight on how 

components were to report required POD information and execute exercises. 

2 Just-in-time is an inventory strategy used to increase efficiency and decrease waste by 

receiving goods only as they are needed in the operations process, thereby reducing inventory 

costs. 

3 PPE is required by some DHS employees to perform everyday operational activities that 

support the DHS mission. PPE is also used to support and sustain the safety of DHS 

employees during a pandemic event. 

www.oig.dhs.gov 7 OIG-17-02 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Consequently, the components did not always complete reporting requirements 

for POD locations or conduct exercises. Without sufficient guidance and 

oversight, the Department cannot ensure its employees are prepared to 

dispense medication, as needed, to protect its workforce during a pandemic. 

Reporting Requirements for Points of Dispensing 

The Department required all component POD locations to exercise PODs (see 

figure 4) at least annually, preferably twice per year. To ensure components 

completed POD exercises, the Department requested components submit 

quarterly updates. These reports allow the Department to track personnel 

coverage, ensure components conducted required exercises, and identify areas 

for improvement. However, the Department did not provide clear instructions 

on how to report this information on a quarterly basis. 

Figure 4: POD Exercise 

Source: Federal Emergency Management Agency 

We determined the Department did not ensure components completed and 

submitted these quarterly reports. Although the Department provided 

components with a reporting template, it was missing some required items. As 

a result, the Department could not accurately determine what percentage of its 

personnel had access to PODs or ensure components were adequately prepared 

to dispense medication during a pandemic. 

We reviewed the POD quarterly reports of eight components for calendar years 

(CY) 2014 and 2015. We determined none of these components submitted 

www.oig.dhs.gov 8 OIG-17-02 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

complete reports and two components, NPPD and USCIS, did not submit any 

reports in CY 2015. This occurred because the Department did not provide 

components with clear instructions on how to report POD information on a 

quarterly basis. 

Most components submitted information on POD locations and reported 

whether exercises were conducted. However, components did not include 

information required for assessing the personnel covered by POD locations. 

Specifically, components using the department-provided template or 

component-developed report did not always include the following items: 

• number of employees and those in its care and custody who are covered 

by component PODs; 

• percentage of their workforce that has access to PODs; 

• POD policy or procedure updates; 

• after-action reports for POD exercises; 

• number of component PODs exercised in the past 12 months; and 

• identification of any PODs that have not been exercised in the past 12 

months. 

Without receiving complete quarterly reports, the Department and components 

cannot fully assess their preparedness and response capabilities. In addition, 

the Department cannot identify areas for improvement without reviewing afteraction reports of POD exercises. During the audit, a Program Manager stated 

the Department was aware that the reporting requirements were not being met 

and indicated these requirements would be revised. 

POD Exercise Requirement 

Components did not always complete annual exercises for POD locations as 

required by the Department’s plan. Although most components reported the 

locations that completed POD exercises for CYs 2014 and 2015, the 

Department did not verify the accuracy of this information. As a result, the 

Department may not be able to accurately assess its POD capabilities. Based 

on the component reports, two of the eight components reviewed met the 

annual POD exercise requirement, while four substantially met the 

requirement, and two did not meet the requirement. See table 2 for the 

reported number of required POD exercises completed for CYs 2014 and 2015. 

www.oig.dhs.gov 9 OIG-17-02 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 2: POD Exercises Completed and Reviewed for CY 2014-2015 

Component Exercises 

Required 

Exercises 

Reported 

Complete 

Reported 

Completion 

Rate 

Exercises 

Reviewed by 

OIG 

Exercises 

Supported with 

Documentation 

Exercise 

Accuracy Rate 

Based on 

Supporting 

Documentation 

CBP 135 132 98% 20 4 20% 

Coast Guard 80 77 96% 20 19 95% 

Federal 

Emergency 

Management 

Agency 

34 32 94% 20 15 75% 

ICE 

NPPD 

TSA 

USCIS 

Secret Service 

51 

75 

906 

6 

22 

51 

8 

896 

6 

1 

100% 

11% 

99% 

100% 

5% 

20 

8 

90 

6 

1 

14 

8 

46 

6 

1 

70% 

100% 

51% 

100% 

100% 

Source: OIG analysis of data provided by each component 

As illustrated in table 2, five of the eight components did not maintain 

supporting documentation, including after-action reports, to demonstrate 

exercises were completed. In addition, CBP did not complete all exercises as 

reported, and TSA missed completing one. 

Additional concerns identified during the audit included: one of the eight 

components we reviewed did not have an adequate number of POD locations to 

ensure sufficient personnel coverage, and another completed exercises just for 

its field locations. Specifically, USCIS’ 4 POD locations were inadequate to 

cover its personnel at its more than 100 nationwide offices. In CY 2015, NPPD 

did not conduct exercises for all of its 42 POD locations; rather, it conducted 

just 4 regional exercises. 

The Department and components cannot fully assess their preparedness and 

response capabilities or identify areas for improvement without completing 

POD exercises and reviewing after-action reports to determine whether future 

improvements are needed. 

Conclusion 

The Department left components to develop pandemic plans without continued 

guidance and oversight to ensure those plans were fully developed and 

approved. Specifically, the Department was responsible for providing oversight 

to ensure components developed plans, assessed and implemented protective 

www.oig.dhs.gov 10 OIG-17-02 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

measures, conducted pandemic readiness training, and properly exercised and 

reported on PODs. However, the Department did not verify components met all 

of these requirements. Maintaining oversight to ensure components have 

adequately planned and prepared for pandemics is critical to allowing 

components to maintain their mission essential functions when a pandemic 

occurs. As a result, the department cannot be assured that its preparedness 

plans can be effectively executed during a pandemic event. 

Recommendations 

We recommend that the Deputy Secretary of DHS: 

Recommendation 1: Designate an office responsible for conducting oversight 

of component pandemic plans, including review and approval of those plans. 

Recommendation 2: Update the Department’s Pandemic Workforce Protection 

Plan to clarify pandemic readiness training requirements. 

Recommendation 3: Issue implementation guidance, including deadlines, for 

components to execute the Integrated Logistics Support Plan. 

Recommendation 4: Establish oversight to ensure component compliance 

with the Integrated Logistics Support Plan. 

Recommendation 5: Establish clear and consistent guidance on timeframes 

for which components should maintain pandemic personal protection 

equipment. 

Recommendation 6: Ensure the Department develops an oversight plan to 

ensure components are completing points of dispensing exercises and 

submitting complete points of dispensing reports. 

Recommendation 7: Provide guidance on submitting required points of 

dispensing reports and update the quarterly reporting template to include all 

required items. 

Management Comments and OIG Analysis 

In its response to our draft report, the Department concurred with all seven of 

our recommendations. The Department indicated that our report identified 

many of the same issues the Department is already addressing as part of its 

ongoing efforts to improve pandemic preparedness. 

www.oig.dhs.gov 11 OIG-17-02 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendation 1: Designate an office responsible for conducting oversight 

of component pandemic plans, including review and approval of those plans. 

DHS Response: Concur. The DHS Pandemic Workforce Protection Plan (PWPP) 

is currently undergoing significant revisions and will be republished as the 

“DHS Pandemic and Emerging Infectious Disease (PEID) Plan.” The PEID 

Steering Committee (PEID-SC), co-chaired by executives from the Management 

Directorate (MGMT) and Office of Health Affairs (OHA), is overseeing this effort. 

The co-chairs of the PEID-SC will establish a team to review and approve 

component PEID plans. The team will comprise participants in the current 

Core Planning Team (CPT) that developed the basic changes to the PEID. Team 

members will represent the major PEID Plan areas of expertise (OHA, 

Occupational Safety and Health, Chief Readiness Support Officer (CRSO), etc.) 

and will review the areas they are responsible for, as determined beforehand by 

the PEID-SC. The PEID-SC co-chairs will be the executive authority for plan 

reviews and will oversee the team's actions. This process will be repeated each 

time the components’ pandemic plans or the PEID Plan is formally updated. 

Estimated Completion Date (ECD): December 31, 2016. 

OIG Analysis: The Department’s response addresses the intent of the 

recommendation. This recommendation is resolved and will remain open until 

the Department provides the document that outlines responsibilities and 

specifies the process for reviewing and approving component PEID plans to 

include a feedback loop for changes made in response to the Department’s 

review. 

Recommendation 2: Update the Department’s Pandemic Workforce Protection 

Plan to clarify pandemic readiness training requirements. 

DHS Response: Concur. The current departmental update and revision to the 

PEID Plan includes specific training requirements (personal protective 

equipment, POD, etc.) and a new concept of operations that requires training 

and exercises as a major activity during each phase of a PEID response, 

including steady state readiness activities. Subsequent to publication of this 

new plan, the PEID-SC will request component PEID Plans and ancillary 

documents, including a pandemic training plan for review by a team of subject 

matter experts. The team will evaluate submittals on matters regarding the 

quality and completeness of the training plans. If component training plans are 

deficient, components will be tasked with improving them to meet common 

quality standards for effective instructional design. This process will be 

repeated each time the pandemic plan or PEID Plan is formally updated. ECD: 

March 31, 2017. 

www.oig.dhs.gov 12 OIG-17-02 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

OIG Analysis: The Department’s response addresses the intent of the 

recommendation. This recommendation is resolved and will remain open until 

the Department provides the updated PEID Plan and provides a copy of the 

results review of component training plans. 

Recommendation 3: Issue implementation guidance, including deadlines, for 

components to execute the Integrated Logistics Support Plan. 

DHS Response: Concur. The “Pandemic Integrated Logistics Support Plan” 

(ILSP) was approved by the DHS CRSO in July 2015. The implementation 

direction and guidance on its application will be in the updated PEID Plan, 

which is in final review. The ILSP identifies and describes specific logistics 

guidance, practices, and methodologies to standardize the general process for 

all DHS components to follow when supporting the operational personal 

protective equipment and pandemic personal protective equipment needs, to 

include planning, procurement, acquisition, managing, and maintaining 

personal protective equipment. This guidance was distributed to all 

components logistics points of contact involved in its development. They will 

adapt their processes to adhere to this plan no later than December 31, 2016. 

Quarterly reports, which are generated from the Department's Sunflower Asset 

Management System (SAMS) through the Consolidated Asset Portfolio & 

Sustainability Information System, will demonstrate component compliance. 

ECD: December 31, 2016. 

OIG Analysis: The Department’s response addresses the intent of the 

recommendation. This recommendation is resolved and will remain open until 

the Department provides the updated PEID Plan along with documentation 

that the December 31, 2016, deadline was communicated to all components. 

Recommendation 4: Establish oversight to ensure component compliance 

with the Integrated Logistics Support Plan. 

DHS Response: Concur. Program supportability and sustainment is managed 

though the DHS strategic sourced contracts by the DHS MGMT Office of 

Procurement, Strategic Sourcing, and MGMT CRSO’s Office of Assets and 

Logistics. CRSO has direct oversight of pandemic personal protective 

equipment inventory and is responsible for reviewing quarterly reports to 

monitor procurement activities under the mandatory DHS personal protective 

equipment strategic sourcing contracts and ensuring that components use 

these mandatory sources. ECD: December 31, 2016. 

OIG Analysis: The Department’s response addresses the intent of the 

recommendation. This recommendation is resolved and will remain open until 

www.oig.dhs.gov 13 OIG-17-02 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

the Department provides documentation of the responsibility for oversight of 

component compliance with the Integrated Logistics Support Plan along with a 

copy of the most recent quarterly report. 

Recommendation 5: Establish clear and consistent guidance for timeframes 

that components should maintain pandemic personal protection equipment. 

DHS Response: Concur. The timeframes that components should maintain 

pandemic personal protection equipment are guided by the ILSP, see Appendix 

4, “DHS PPE Rotational Stock Guidance.” Components are responsible for 

ensuring that the level of on-hand inventory maintained aligns with the 

demand and can be rotated in such a way that there is minimal waste in place. 

Furthermore, components must ensure any personal protective equipment 

designated for the purposes of pandemic protection is transferred to 

operational inventory within one year prior to the manufacturer's expiration 

date. Should a component not have an operational need for the equipment, 

that equipment stock must be offered to other components at least 180 days 

prior to the manufacturer's expiration date. The ILSP guidance also references 

existing guidance on the management of personal protective equipment, as 

personal property assets, under Management Directive 119-03, “Personal 

Property Management Program.” The updated PCID Plan, which is in final 

review, will direct implementation of the ILSP guidance. ECD: December 31, 

2016. 

OIG Analysis: The Department’s response addresses the intent of the 

recommendation. This recommendation is resolved and will remain open until 

the Department provides the updated PEID Plan directing implementation of 

the ILSP guidance. 

Recommendation 6: Ensure the Department develops an oversight plan to 

ensure components are completing points of dispensing exercises and 

submitting complete points of dispensing reports. 

DHS Response: Concur. OHA has adopted SAMS as its solution to catalog, 

manage, and track MCM data. The system also provides the capability to 

capture and report POD exercise status and information for each POD location. 

OHA is providing each component, directorate, and office MCM POD locations 

with tailored instruction on how to input the required information into the 

SAMS POD exercise module. In-person SAMS POD exercise module training for 

component MCM points of contact (POC) is underway and expected to be 

complete by early calendar year 2017. Exercise status reports, by POD location 

and component, are available to OHA and MGMT POCs on a continuous basis. 

Quarterly POD exercise status reports will be submitted by the DHS MCM 

www.oig.dhs.gov 14 OIG-17-02 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Program to MGMT's EP, which is responsible for oversight and management of 

POD training and exercise compliance, in accordance with DHS Directive 010-

02, section VI.B.5.e, VI.C. l, and VI.C.3. OHA is responsible for MCM policy, 

procedures, and training guidance and MGMT's EP is responsible for ensuring 

and reporting on training and exercise compliance. This information has been 

shared across the Department via monthly DHS MCM Working Group meetings 

hosted by OHA. ECD: February 28, 2017. 

OIG Analysis: The Department’s response addresses the intent of the 

recommendation. This recommendation is resolved and will remain open until 

the Department provides documentation that MGMT's EP is reporting on 

training and exercise compliance. 

Recommendation 7: Provide guidance on submitting required points of 

dispensing reports and update the quarterly reporting template to include all 

required items. 

DHS Response: Concur. OHA has provided MCM Program POCs in all DHS 

components, directorates, and offices with guidance for implementing and 

updating POD logistics and exercise information in the SAMS MCM materials 

module. This module includes fields for each required MCM POD data point. 

Component MCM POCs are responsible for updating their organization’s POD 

information in the SAMS MCM materials module, to include exercise 

information and after-action reports. Local users will be able to query this 

information and the status of their PODs at any time. OHA (and soon, MGMT) 

MCM POCs will be able to query POD information, including the number of 

component PODs exercised in the past 12 months, and will be able to identify 

any PODs that have not been exercised in the past 12 months, at the local, 

component, and Department levels, any time, to assess POD readiness. OHA 

will provide a quarterly SAMS generated POD status report to MGMT EP. This 

information has been shared across the Department via monthly DHS MCM 

Working Group meetings hosted by OHA. ECD: February 28, 2017. 

OIG Analysis: The Department’s response addresses the intent of the 

recommendation. This recommendation is resolved and will remain open until 

the Department provides documentation that implementation guidance was 

provided to all responsible POCs, including a copy of the implementation 

guidance, and documentation of the component requirements to update their 

organization’s POD information. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objective, Scope, and Methodology 

The DHS Office of Inspector General was established by the Homeland Security 

Act of 2002 (Public Law 107−296) by amendment to the Inspector General Act of 

1978. This is one of a series of audit, inspection, and special reports prepared 

as part of our oversight responsibilities to promote economy, efficiency, and 

effectiveness within the Department. 

The objective of our review was to determine whether DHS had implemented 

adequate preparedness plans to continue mission essential functions during a 

pandemic. To achieve our objective, we reviewed applicable Federal laws, 

regulations, and guidance. In addition, we reviewed applicable departmental 

policies and procedures for pandemic planning and identified the specific 

requirements. 

We interviewed officials within OPS, the Management Directorate, and the 

Office of Health Affairs to determine the Department’s pandemic planning 

efforts and oversight of components’ development and implementation of their 

pandemic plans. To determine the adequacy of pandemic plans, we reviewed 

plans for 8 of DHS’ 24 components that were judgmentally selected based on 

size of component. Those components were: CBP, the Coast Guard, the Federal 

Emergency Management Agency, ICE, NPPD, the Secret Service, TSA, and 

USCIS. We interviewed officials at these components and conducted site visits 

to local offices at CBP, the Coast Guard, and TSA. 

This audit was done concurrently with the OIG-16-18 DHS' Ebola Response 

Needs Better Coordination, Training, and Execution audit. Site visits were 

selected to ensure coverage for both audits. Specifically, we met with CBP and 

TSA at the following domestic airport locations: 

x John F. Kennedy International Airport, Jamaica, NY; 

x Washington-Dulles International Airport, Dulles, VA; 

x Newark Liberty International Airport, Newark, NJ; 

x Chicago O’Hare International Airport, Chicago, IL; 

x Hartsfield-Jackson Atlanta International Airport, Atlanta, GA; 

x Miami International Airport, Miami, FL; 

x Los Angeles International Airport, Los Angeles, CA; and 

x San Francisco International Airport, San Francisco, CA. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We met with CBP and the Coast Guard at the following seaport locations: 

x New Orleans, LA; 

x Houston, TX; and 

x Corpus Christi, TX. 

In addition, we met with CBP at the following locations: 

x Champlain, NY Area Port; 

x Montreal Trudeau International Airport, Dorval, Quebec, Canada; and 

x Toronto Pearson International Airport, Toronto, Ontario, Canada. 

We also selected a sample of component field locations to determine whether 

those locations completed POD exercises, as required. From our universe of 

1,309 exercises for the 8 components reviewed, we randomly selected a sample 

of 10 POD locations for each component, or in the cases of larger components, 

we reviewed 10 percent of their POD locations, whichever was larger. For 

components with fewer than 10 POD locations, 100 percent were selected. For 

each site selected we reviewed supporting documentation to determine whether 

reported information was accurate. We determined significant discrepancies 

between what was reported as completed and what was supported. This testing 

was performed to assess and validate the reliability of the data provided on 

POD exercises. We determined that this data was inaccurate for five of the 

eight components we reviewed as we have detailed in this report. 

We conducted this performance audit between November 2014 and April 2016 

pursuant to the Inspector General Act of 1978, as amended, and according to 

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 upon our 

audit objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based upon our audit objectives. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

DHS Comments to the Draft Report 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Office of Audits Major Contributors to This Report 

Brooke Bebow, Director 

Stephanie Christian, Audit Manager 

Ruth Gonzalez, Auditor-in-Charge 

Gary Crownover, Program Analyst 

Megan McNulty, Program Analyst 

Matthew Noll, Program Analyst 

Sabrina Paul, Program Analyst 

Melissa Woolson Prunchak, Program Analyst 

Kevin Dolloson, Communications Analyst 

Andrew Herman, Referencer 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

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ADDITIONAL INFORMATION AND COPIES 

To view this and any of our other reports, please visit our website at: www.oig.dhs.gov. 

For further information or questions, please contact Office of Inspector General Public Affairs 

at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. Follow us on Twitter at: @dhsoig. 

OIG HOTLINE 

To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click on the red 

"Hotline" tab. If you cannot access our website, call our hotline at (800) 323-8603, fax our 

hotline at (202) 254-4297, or write to us at: 

Department of Homeland Security 

Office of Inspector General, Mail Stop 0305 

Attention: Hotline 

245 Murray Drive, SW 

Washington, DC 20528-0305