United States Government Accountability Office

GAO-15-20

EMERGENCY 

PREPAREDNESS

Opportunities Exist to 

Strengthen 

Interagency 

Assessments and 

Accountability for 

Closing Capability 

Gaps

December 2014

Report to Congressional Requesters

Revised December 9, 2015, to correct a formatting error 

on page 28.
United States Government Accountability Office

Highlights of GAO-15-20, a report to 

congressional requesters

December 2014

EMERGENCY PREPAREDNESS

Opportunities Exist to Strengthen Interagency 

Assessments and Accountability for Closing Capability 

Gaps 

Why GAO Did This Study

No-notice catastrophic disasters pose 

one of the greatest challenges to 

national emergency preparedness. 

ESFs are federal interagency 

coordinating structures that group 

capabilities into functional areas most 

frequently needed in a national 

response. GAO was asked to review 

federal preparedness to respond to nonotice catastrophic disasters, such as 

IND attacks and major earthquakes. 

This report assesses the extent to 

which opportunities exist to enhance 

(1) assessment of ESF preparedness

and (2) management oversight of the 

closure of federal capability gaps 

identified in selected exercises, realworld incidents, and other 

assessments. GAO reviewed relevant 

laws, directives, strategies, and plans; 

analyzed recommended corrective 

actions from national-level exercises 

and other interagency assessments; 

reviewed documents and interviewed 

officials from five federal departments 

key to disaster response (Defense, 

Energy, Health and Human Services, 

Homeland Security, and Justice); and

compared current processes against 

internal control standards and leading 

program management practices. 

What GAO Recommends

GAO recommends that FEMA—in 

collaboration with other federal 

agencies—(1) issue supplemental 

guidance to ESF coordinators detailing

minimum standards for activities and 

product deliverables necessary to 

demonstrate ESF preparedness, (2) 

regularly report on the status of 

corrective actions identified through 

prior national-level exercises and realworld disasters, and (3) develop and 

issue detailed program management

information to better enable 

management oversight of the DHS IND 

Strategy’s recommended actions. DHS

concurred with the recommendations

and identified related actions the 

department is taking to address them.

What GAO Found

The departments that coordinate federal emergency support functions (ESF), in 

preparation for national disaster response, carry out their responsibilities in 

various ways, but the Secretary of Homeland Security’s ability to assess ESF 

preparedness could be enhanced. ESF coordinators conduct a range of 

coordination, planning, and capability assessment activities. All 10 ESF 

coordinators across the five departments in GAO’s review reported coordinating

with stakeholders and developing at least one ESF planning document. However, 

the ESF Leadership Group and the group’s chair, the Federal Emergency 

Management Agency (FEMA)—a component of the Department of Homeland 

Security (DHS)—have not worked with other federal departments to issue 

supplemental guidance detailing expectations for the minimum standards for 

activities and product deliverables necessary to demonstrate ESF preparedness.

In the absence of such guidance, GAO found that ESF coordinators are 

inconsistently carrying out their emergency response preparedness activities. 

DHS and FEMA have responsibility for assessing federal emergency 

preparedness. Issuing supplemental guidance detailing expectations for ESF 

coordinators would better enable DHS and FEMA to assess the status of ESF 

response preparedness. 

Federal departments have identified emergency response capability gaps

through national-level exercises, real-world incidents, and other assessments, 

but opportunities exist to help close the gaps by enhancing management 

oversight in two areas:

• First, federal departments are responsible for implementing their own 

recommended corrective actions from national-level exercises and realworld disasters, such as Hurricane Sandy, but the status of federal 

interagency implementation of these actions is not comprehensively 

collected by or reported to DHS or FEMA. As a result, DHS’s and 

FEMA’s ability to assess and report on the nation’s overall preparedness 

is hampered. 

• Second, FEMA leads interagency efforts to identify and propose actions 

to address capability gaps in the nation’s preparedness to respond to 

improvised nuclear device (IND) attacks, but its implementation plan 

lacks key program management details. Specifically, FEMA’s March 

2012 IND Implementation Plan proposed over 300 recommended actions

to help close gaps identified in the April 2010 DHS IND Strategy. The 

September 2013 annual revision to the plan contained summary 

information on the status of some of the recommended actions, but did 

not contain detailed program management information—such as specific 

timeframes, milestones, and estimated resources required to close any 

given capability gap—which is needed to better enable ongoing 

management oversight of gap closure efforts. 

Regular reporting on the status of corrective actions identified in national-level 

exercises and real-world major disasters, as well as detailed program 

management information for management oversight of the status of

recommended actions in the IND Implementation Plan, would enhance 

interagency accountability for closing identified capability gaps and better enable

DHS and FEMA to assess the status of federal interagency preparedness efforts. 

View GAO-15-20. For more information, 

contact Chris P. Currie at (404) 679-1875 or 

curriec@gao.gov. 
Page i GAO-15-20 Emergency Preparedness 

Letter 1 

Background 5

ESF Coordinators Conduct Their Oversight Responsibilities in 

Various Ways, but Opportunities Exist to Strengthen the 

Assessment of ESF Preparedness 13

Federal Departments Identified Corrective Actions to Address 

Capability Gaps, but Management Oversight of Implementation

Status Could Be Improved 21

Conclusions 38

Recommendations for Executive Action 39

Agency Comments and Our Evaluation 40

Appendix I Objectives, Scope, and Methodology 43

Appendix II Examples of Coordination Activities, Planning Documents, 

and Capability Assessments Identified by National Response

Framework (NRF) Emergency Support Function (ESF) 

Coordinators 51

Appendix III Corrective Actions Not Yet Closed for National Level 

Exercises 2010 and 2011, as of November 2014 60

Appendix IV Corrective Actions Developed after Hurricane Sandy 

Not Yet Closed, as of November 2014 63

Appendix V Improvised Nuclear Device (IND) Program Interagency 

Working Groups’ Activities and Projects 69

Appendix VI Comments from the Department of Homeland Security 74

Contents
Page ii GAO-15-20 Emergency Preparedness 

Appendix VII GAO Contact and Staff Acknowledgments 77

Related GAO Products 78

Tables

Table 1: List of Emergency Support Functions (ESF) and their 

Assigned Coordinators 8

Table 2: Status of Corrective Actions from National-Level 

Exercises (NLE) 2010 and 2011 for the Five Departments, 

as of November 2014 23

Table 3: Status of Corrective Actions from Hurricane Sandy for 

Five Departments, as of November 2014 30

Table 4: Improvised Nuclear Device (IND) Interagency Working 

Group Focus Areas and Assigned Capability Gaps as 

Described in the IND Implementation Plan 34

Table 5: Departments and Key Components in GAO’s Review 44

Table 6: List of Emergency Support Functions (ESF) and their 

Assigned Coordinators 47

Table 7: Corrective Actions Not Yet Closed from National Level 

Exercise 2010, as of November 2014 61

Table 8: Corrective Actions Not Yet Closed from National Level 

Exercise 2011, as of November 2014 62

Table 9: Corrective Actions Developed after Hurricane Sandy Not 

Yet Closed, as of November 2014 63

Table 10: Summary of Capability Gaps and Recommended 

Actions Pursued as identified in the September 2013 

IND Implementation Plan 70

Figure

Figure 1: Number of Emergency Support Function (ESF) 

Coordinators Conducting Selected Activities to Oversee 

ESF Preparedness 14
Page iii GAO-15-20 Emergency Preparedness 

Abbreviations

CAPS Corrective Action Program System

DHS Department of Homeland Security

DOD Department of Defense

DOE Department of Energy

DOJ Department of Justice

ESF emergency support function

FEMA Federal Emergency Management Agency

HHS Department of Health and Human Services

IND improvised nuclear device

NLE national level exercise

NRF National Response Framework

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Page 1 GAO-15-20 Emergency Preparedness

441 G St. N.W.

Washington, DC 20548

December 4, 2014

Congressional Requesters:

No-notice catastrophic disasters pose one of the greatest challenges to 

national emergency preparedness, whether caused by manmade attacks 

or natural events. For example, nuclear detonation from a successful 

improvised nuclear device (IND) attack in a U.S. city would cause 

enormous loss of life and property and severe damage to an affected 

area’s economic viability.1 Similarly, natural disasters such as a major 

earthquake can occur with little to no advanced warning and also 

potentially cause massive loss of life and property. For example, federal 

emergency response planning estimates on the consequences of a 

catastrophic earthquake along known fault lines in the central United 

States include impacts to multiple states and more specifically project 

over 75,000 casualties (injured and fatalities), more than 380,000 

displaced from their homes and communities, at least 330,000 buildings 

moderately or severely damaged, and direct economic losses surpassing 

$200 billion.2

The National Response Framework (NRF) states that the Secretary of 

Homeland Security is to ensure that overall federal preparedness actions 

are unified, complete, and synchronized to prevent unfilled gaps or seams 

in the federal government’s efforts to respond to all hazards. Such 

hazards include IND attacks and catastrophic earthquakes.3

 

1

The White House, National Security Strategy (Washington, D.C.: May 2010). 

Further, the 

NRF identifies 14 emergency support functions (ESF) that serve as the 

federal government’s primary coordinating structure for building, 

sustaining, and delivering response capabilities. The ESFs are organized 

2

Mid-America Earthquake Center, Impact of Earthquakes on the Central USA (Urbana, Ill: 

September 2008). 

3

DHS, National Response Framework (Washington, D.C.: May 2013). One Government 

Performance and Results Act performance metric for the Federal Emergency 

Management Agency’s (FEMA) Response Directorate is the goal of achieving a unified, 

complete, and synchronized federal response to emergencies. FEMA established for this 

goal a target of executing100 percent of needed response actions to stabilize an 

incident—including no-notice catastrophic disasters—within 72 hours. These actions are 

defined as those functions that must be initiated immediately in order to ensure the best 

outcomes for survivors.
 

Page 2 GAO-15-20 Emergency Preparedness

by specific functional areas for the most frequently needed capabilities 

during an emergency—including communications, medical services, and 

search and rescue—and are designed to coordinate the provision of 

related assets and services by federal departments and agencies.

To assess preparedness to respond to no-notice catastrophic disasters, 

the National Preparedness System calls for federal departments and 

agencies to identify potential capability gaps, such as through exercises 

and real-world incidents, and to develop corrective actions to help close 

these gaps.4 The National Exercise Program—an interagency program 

managed by the Federal Emergency Management Agency (FEMA), a 

component of the Department of Homeland Security (DHS)—serves as a 

means of assessing interagency preparedness and identifying corrective 

actions through national-level exercises (NLE).5

Congressional requesters asked us to review federal preparedness to 

respond to no-notice catastrophic disasters. This report assesses the 

extent to which opportunities exist to strengthen

Similarly, federal 

departments and agencies also identify corrective actions following 

responses to real-world incidents, such as the federal response to 

Hurricane Sandy in October 2012. Finally, federal departments and 

agencies may identify capability gaps by conducting capability gap 

analyses, which compare the capabilities needed for an effective 

response (i.e., capability requirements) against those available.

 

4

The White House released Presidential Policy Directive 8 on National Preparedness in 

March 2011. It directed the Secretary of Homeland Security to design a national 

preparedness system to address the threats posing the greatest risk to the security of the 

nation and issue various policy and planning documents designed to enhance national 

preparedness. In November 2011, the Department of Homeland Security (DHS) published 

the National Preparedness System, which describes activities for developing emergency 

preparedness capabilities, and has worked through FEMA to implement the system. The 

White House, Presidential Policy Directive 8 on National Preparedness (Washington, 

D.C.: Mar. 30, 2011). DHS, National Preparedness System (Washington, D.C.: November 

2011). Corrective actions are the concrete, actionable steps assigned to responsible 

entities that are intended to resolve gaps and shortcomings experienced during exercises 

and real-world incidents. Federal departments and agencies use varying terminology—

e.g., recommended actions, recommended courses of action, etc.—to describe the 

actions developed to address such gaps. For the purposes of this report, we refer to such 

actions collectively as corrective actions. 

5

The Post-Katrina Emergency Management Reform Act of 2006 requires FEMA to carry 

out a national exercise program and conduct periodic national exercises. 6 U.S.C. § 

748(b). In 2014, FEMA began labeling what had previously been termed “national-level 

exercises” as “capstone exercises.” 
 

Page 3 GAO-15-20 Emergency Preparedness

1. the assessment of ESF preparedness, and

2. management oversight of the status of implementation of federal 

capability gaps identified in national-level exercises, real-world 

incidents, and other gap assessments.

For the purposes of this report, we selected two no-notice catastrophic 

scenarios and five federal departments for our review. IND attacks and 

major earthquakes represent one man-made scenario and one naturally 

occurring scenario, respectively, and are among the scenarios the federal 

government uses to plan for no-notice catastrophic incidents. We 

selected the five federal departments—the Departments of Defense 

(DOD), Energy (DOE), Health and Human Services (HHS), DHS, and 

Justice (DOJ)—because, among other things, they represent federal 

entities with significant responsibilities for responding to IND attacks and 

major earthquakes and each department coordinates 1 or more of the 14 

ESFs. To address our report objectives, we reviewed relevant laws and 

presidential directives, all-hazards and incident-specific interagency 

strategies and plans, as well as relevant assessments of federal 

preparedness. We also interviewed department and agency officials on 

their roles and responsibilities for emergency response, coordination of 

ESF preparedness, and management oversight of the status of 

implementation of corrective actions to close capability gaps identified in 

national-level exercises, real-world incidents, and other gap assessments.

In addition, to identify the extent to which opportunities, if any, exist to 

enhance the assessment of ESF preparedness, we gathered and 

analyzed information on the 10 ESFs that were coordinated by one of the 

five departments in our review.6

 

6

The following ESFs are included in our review because they are coordinated by one of 

the five departments: DOD–Public Works and Engineering; DOE–Energy; HHS–Public 

Health and Medical Services; DHS–Communications; Information and Planning; Mass 

Care, Emergency Assistance, Temporary Housing, and Human Services; Logistics; 

Search and Rescue; and External Affairs; and DOJ–Public Safety and Security. For more 

information on the ESFs and their coordinators, including those coordinated by 

departments outside the scope of our review, see app. I. 

We compared current federal efforts to 

monitor ESF preparedness against, among others, requirements in the 

Post-Katrina Emergency Management Reform Act of 2006 (Post-Katrina 

Act) and Standards for Internal Control in the Federal Government, as 

well as best practices we have previously identified for interagency 
 

Page 4 GAO-15-20 Emergency Preparedness

coordination.7 To identify potential opportunities to enhance the 

management oversight of the status of implementation of corrective 

actions to close federal response capability gaps, we gathered and 

analyzed after-action reports from two relevant national-level exercises, 

one real-world incident, and other relevant assessments.8 To determine 

the status of corrective actions from NLE 2010, NLE 2011, and Hurricane 

Sandy, we reviewed interagency and departmental documents that 

identified and provided status updates on corrective actions for these 

events. To assess the reliability of this information, we gathered 

information from agency officials knowledgeable about how corrective 

actions from NLEs and real-world incidents are tracked within their 

respective departments or agencies.9 To identify other scenario-specific 

capability gap assessments conducted on federal emergency response to 

IND attacks and major earthquakes, we interviewed agency officials to 

determine the extent to which such assessments had been conducted. 

We identified one relevant interagency assessment—the April 2010 DHS 

Strategy for Improving the National Response and Recovery from an IND 

Attack (DHS IND Strategy).10

 

7

We compared efforts to assess ESF preparedness to, among other things, requirements 

in the Post-Katrina Act on assessing federal preparedness to respond to disasters and 

federal internal control standards for monitoring the execution of management’s intent. 

GAO, Standards for Internal Control in the Federal Government, 

We reviewed the March 2012 and 

September 2013 iterations of the IND Response and Recovery 

Capability-Based Implementation Plan (IND Implementation Plan), which 

GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1, 1999); Results-Oriented Government: Practices That Can Help 

Enhance and Sustain Collaboration among Federal Agencies, GAO-06-15 (Washington, 

D.C.: Oct. 21, 2005); Catastrophic Disasters: Enhanced Leadership, Capabilities, and 

Accountability Controls Will Improve the Effectiveness of the Nation’s Preparedness, 

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

8

We selected NLE 2010 and NLE 2011 for our review because these two NLEs assessed 

federal preparedness to respond to an IND attack and a major earthquake, respectively—

the only NLEs to do so since establishment of the National Exercise Program in 2007. We 

selected the federal response to Hurricane Sandy in 2012 for review because the incident 

represented the most recent, large-scale real-world disaster and involved all five 

departments within our scope. While Hurricane Sandy was a disaster with advanced 

notice (unlike the two scenarios in our review), we believe that it provides valuable insights 

and lessons learned to improve federal response efforts to all kinds of catastrophic 

incidents.

9

We did not independently verify the accuracy of the status of corrective actions as 

reported to us by agency officials. However, we determined the information to be 

sufficiently reliable for the purpose of describing the reported status of corrective actions 

from the two NLEs and Hurricane Sandy at the five departments in our review. 

10We determined at the time of our review, and agency officials confirmed, that a federal 

capability gap assessment similar to the DHS IND Strategy had not been conducted for 

federal response to major earthquakes. 
 

Page 5 GAO-15-20 Emergency Preparedness

describe recommended actions to address IND response capability gaps 

identified in the DHS IND Strategy, as well as the status of efforts to close 

those gaps.11 We compared current federal management oversight of 

efforts to monitor and track the closure of capability gaps identified 

through NLE 2010, NLE 2011, the response to Hurricane Sandy, and the 

DHS IND Strategy against, among others, requirements in the PostKatrina Act and leading practices for internal control and program 

management, specifically Standards for Internal Control in the Federal 

Government and The Standard for Program Management.12

Additional detail on the scope and methodology of our review is contained 

in appendix I.

We conducted this performance audit from September 2013 to December

2014 in accordance with generally accepted government auditing 

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

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

 

11We did not independently verify the accuracy of the status of recommended actions as 

reported to us by agency officials. However, we determined the information we gathered 

to be sufficiently reliable for the purpose of describing the status of implementation of 

recommended actions. 

12We compared efforts to monitor and track the closure of identified capability gaps 

against, among other things, requirements in the Post-Katrina Act on assessing federal 

preparedness to respond to disasters, federal internal control standards for monitoring the 

execution of management’s intent, and program management standards for overseeing 

the implementation of complex efforts. GAO/AIMD-00-21.3.1. Project Management 

Institute, The Standard for Program Management, third edition (Newton Square, Pa.: 

2013). 

Background
 

Page 6 GAO-15-20 Emergency Preparedness

DHS and FEMA, in coordination with other federal departments and 

agencies, are responsible for assessing federal emergency 

preparedness. Homeland Security Presidential Directive 5 on 

Management of Domestic Incidents identifies the Secretary of Homeland 

Security as the principal federal official for domestic incident 

management.13 Presidential Policy Directive 8 on National Preparedness

assigned to the Secretary of Homeland Security responsibility for 

coordinating preparedness efforts among federal executive branch 

departments and agencies.14 According to the NRF, the Secretary is to 

ensure that overall federal preparedness actions are unified, complete, 

and synchronized to prevent unfilled gaps or seams in the federal 

government’s efforts.15 Following the federal response to Hurricane 

Katrina in 2005, Congress passed the Post-Katrina Act in October 2006.16

The act enhanced FEMA’s responsibilities and its autonomy within DHS, 

required FEMA to establish a national preparedness system, and 

assigned FEMA responsibility for assessing the nation’s overall 

preparedness. The Post-Katrina Act also identifies the Administrator of 

FEMA as the principal adviser to the President and the Secretary of 

Homeland Security regarding emergency management.17 The FEMA 

Administrator’s duties include preparation for, protection against, 

response to, and recovery from all hazards, including IND attacks and 

major earthquakes.

 

13The White House, Homeland Security Presidential Directive 5 on Management of 

Domestic Incidents (Washington, D.C.: Feb. 28, 2003). 

14Presidential Policy Directive 8 on National Preparedness updated and replaced the 

former Homeland Security Presidential Directive 8 on the same topic, which identified the 

same responsibility for the Secretary of Homeland Security. The White House, 

Presidential Policy Directive 8 on National Preparedness (Washington, D.C.: Mar. 30, 

2011). 

15The NRF notes that guidance contained in the NRF is not intended to alter or impede the 

ability of any federal government department or agency to carry out its authorities or meet 

its responsibilities under applicable laws, executive orders, and directives

16The Post-Katrina Act was enacted as Title VI of the Department of Homeland Security 

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

176 U.S.C. § 313(c)(4). 

National Preparedness Goal and System

Presidential Policy Directive 8 directed the 

Secretary of Homeland Security to develop a 

national preparedness goal and design a 

national preparedness system to address the

greatest risks to the nation. The National 

Preparedness Goal, issued in September 

2011, defines the core capabilities necessary 

for emergency response to specific types of 

incidents, including acts of terrorism and 

natural disasters. The National Preparedness 

System was issued in November 2011 and is 

intended to guide activities to achieve the 

national preparedness goal. Specifically, it 

provides guidance on the planning, 

organization, equipment, training, and 

exercises needed to develop and maintain 

domestic emergency response capabilities. 

The figure below shows the system’s 

feedback cycle.

Source: GAO analysis of Department of 

Homeland Security documents (text and 

graphic). | GAO-15-20

Roles of the Secretary of 

Homeland Security and 

Administrator of FEMA
 

Page 7 GAO-15-20 Emergency Preparedness

The NRF is a guide to how the nation responds to disasters and 

emergencies of all types and describes the principles, roles and 

responsibilities, and coordinating structures for delivering the core 

capabilities required to save lives, protect property and the environment, 

stabilize communities, and meet basic human needs following an 

incident. The NRF includes various annexes, including those on ESFs, 

the federal government’s primary coordinating structure for building, 

sustaining, and delivering response core capabilities.18 The ESF annexes 

are organized by specific functional areas most frequently needed in a 

national response and designed to bring together the capabilities of 

various federal departments and agencies. Each ESF comprises a federal 

department or agency that has been designated as the ESF coordinator, 

along with a number of primary and support agencies.19 Table 1 lists the 

14 ESFs and their assigned coordinators.20

 

18The NRF incident-specific annexes include the Catastrophic Incident and 

Nuclear/Radiological Incident Annexes. An incident-specific annex has not been 

developed for response to major earthquakes. Each ESF supports at least 1 of the 14 

response core capabilities that are defined by the National Preparedness Goal as the 

capabilities necessary to save lives, protect property and the environment, and meet basic 

human needs after an incident has occurred. The National Preparedness Goal also 

assigns qualitative capability targets, or expected levels of performance, to each core 

capability. The response core capabilities are planning, public information and warning, 

operational coordination, critical transportation, environmental response/health and safety, 

fatality management services, infrastructure systems, mass care services, mass search 

and rescue operations, on-scene security and protection, operational communications, 

public and private services and resources, public health and medical services, and 

situational assessment. 

19According to the NRF, ESF primary agencies have significant authorities, roles, 

resources, and capabilities for a particular function within an ESF, and ESF support 

agencies have specific capabilities or resources that support primary agencies in 

executing the mission of the ESF. 

20The NRF lists 15 ESFs. One ESF—Long-Term Community Recovery (ESF #14)—was 

superseded by issuance of the September 2011 National Disaster Recovery Framework.

As a result, for the purposes of this report, we refer to the 14 ESFs that remain active.

National Response 

Framework and 

Emergency Support 

Functions
 

Page 8 GAO-15-20 Emergency Preparedness

Table 1: List of Emergency Support Functions (ESF) and their Assigned Coordinators

ESF ESF coordinator

Transportation (ESF #1) Department of Transportation

Communications (ESF #2) Department of Homeland Security (DHS)/National Communications System

Public Works and Engineering (ESF #3) Department of Defense/U.S. Army Corps of Engineers

Firefighting (ESF #4) Department of Agriculture/U.S. Forest Service and DHS/Federal Emergency 

Management Agency (FEMA )/U.S. Fire Administration

Information and Planning (ESF #5) DHS/FEMA

Mass Care, Emergency Assistance, Temporary 

Housing, and Human Services (ESF #6)

DHS/FEMA a

Logistics (ESF #7) General Services Administration and DHS/FEMA

Public Health and Medical Services 

(ESF #8)

Department of Health and Human Services

Search and Rescue (ESF #9) DHS/FEMA

Oil and Hazardous Materials Response (ESF #10) Environmental Protection Agency

Agriculture and Natural Resources 

(ESF #11)

Department of Agriculture

Energy (ESF #12) Department of Energy

Public Safety and Security (ESF #13) Department of Justice/Bureau of Alcohol, Tobacco, Firearms and Explosives

Long-Term Community Recovery 

(ESF #14)

Not applicable—superseded by the National Disaster Recovery Framework

Source: GAO analysis of the National Response Framework. | GAO-15-20

a

In this report, we refer to ESF #6 as the Mass Care ESF.

ESF coordinators are responsible, per the NRF, for overseeing the 

preparedness activities of their ESF and coordinating with the ESFs’ 

primary and support agencies. The NRF describes four broad 

responsibilities for ESF coordinators:

• maintaining contact with ESF primary and support agencies through 

conference calls, meetings, training activities, and exercises;

• coordinating efforts with corresponding private sector, 

nongovernmental organization, and federal partners;

• ensuring the ESF is engaged in appropriate planning and 

preparedness activities; and
 

Page 9 GAO-15-20 Emergency Preparedness

• monitoring the ESF’s progress in meeting the targets of the core 

capabilities it supports.

For example, DHS and its agencies—such as FEMA—have responsibility 

for coordinating 7 of the 14 ESFs. FEMA also chairs the ESF Leadership 

Group, which is composed of the federal departments and agencies that 

are designated as ESF coordinators. The ESF Leadership Group exists to 

coordinate responsibilities, resolve interagency operational and 

preparedness issues, and provide planning guidance and oversight for 

developing interagency response plans and activities.21

 

21The ESF Leadership Group also comprises the federal departments and agencies that 

coordinate other NRF annexes, including the incident-specific annexes. According to the 

ESF Leadership Group’s charter, the group’s responsibilities include identifying 

operational preparedness and planning priorities to be addressed, developing and 

maintaining federal interagency operational plans, and providing planning assistance and 

oversight through all phases of interagency response planning. 
 

Page 10 GAO-15-20 Emergency Preparedness

The National Exercise Program serves to assess interagency 

preparedness and identify corrective actions needed to close gaps in 

required emergency response capabilities.22 FEMA’s National Exercise 

Division manages the design and execution of NLEs, including the 

development of interagency after-action reports and the related 

improvement plans that identify specific corrective actions. Participating 

federal departments and agencies are to track the status of 

implementation of their assigned corrective actions following NLEs.23

Starting in calendar year 2013, the National Exercise Program 

established a biennial exercise cycle for NLEs.24 The first NLE under this 

new cycle occurred in March 2014 and FEMA officials stated that they are 

beginning to plan for the next NLE, which is to occur in calendar 2016.25

 

22The Post-Katrina Act requires FEMA to carry out a national exercise program and 

conduct periodic national exercises. 6 U.S.C. § 748(b). 

23Intradepartmental after-action reports may also be developed by specific offices or 

components within a given federal department. Generally, the related improvement plans 

and corrective actions from such reports are designed to address tactical or operational 

issues within the given department. FEMA, National Exercise Program Implementation 

Plan (Washington, D.C.: June 12, 2012). 

24Under an earlier iteration of the National Exercise Program Base Plan, NLEs were to 

occur annually. In 2014, FEMA began labeling what had previously been termed “nationallevel exercises” as “capstone exercises.” 

25In March 2014, FEMA conducted an NLE (now termed “capstone exercise”) based on a 

catastrophic Alaska earthquake scenario. However, because FEMA’s evaluation of this 

exercise was ongoing at the time of our review, and corrective actions had not yet been 

issued, this exercise was not included within the scope of this review. 

National-Level Exercise (NLE) 2010

NLE 2010 was a 2-day exercise conducted in 

May 2010 that concentrated on response and 

recovery from an improvised nuclear device 

attack in the United States. In the exercise’s 

scenario, a terrorist group developed and 

detonated a 4.5-kiloton device in a midwestern 

U.S. city. In the exercise, the detonation 

resulted in the destruction of hundreds of 

heavy structures and homes, 65,000 people 

killed, 21,000 injured, and highly radioactive 

fallout.

Source: GAO analysis of Federal Emergency 

Management Agency documents (text and 

photo). | GAO-15-20

Capability Assessment 

through National-Level 

Exercises, Real-World 

Incidents, and Other Gap 

Analyses
 

Page 11 GAO-15-20 Emergency Preparedness

In addition, interagency and intradepartmental after-action reports 

developed in the wake of major disasters, such as Hurricane Sandy in 

October 2012, also provide a means of assessing federal preparedness 

and identifying corrective actions needed to close capability gaps. For 

example, the National Security Council convened the Sandy After-Action 

Review Team in December 2012.26 The team was charged with 

identifying challenges experienced during the federal response to 

Hurricane Sandy that required cross-agency attention and development 

of related corrective actions.

 

26The National Security Council is the President’s principal forum for considering national 

security and foreign policy matters with his senior national security advisers and cabinet 

officials, and the National Security Council Staff are the staff that assist the council. The 

council is chaired by the President and its regular attendees and advisers (both statutory 

and nonstatutory) include the Vice President; the Secretaries of State, Treasury, and 

Defense; the Chairman of the Joint Chiefs of Staff; the Director of National Intelligence; 

and the Assistant to the President for National Security Affairs. The heads of other 

executive departments and agencies are invited to attend meetings of the council when 

appropriate.

National Level Exercise (NLE) 2011

NLE 2011 was a 4-day exercise conducted in 

May 2011 that concentrated on response to a 

catastrophic earthquake. The NLE 2011 

scenario involved a magnitude 7.7 earthquake 

in the New Madrid Seismic Zone, which is a 

major fault line impacting eight states in the 

southern and midwestern United States. In 

the exercise, the earthquake and aftershocks 

resulted in thousands of casualties and major 

damage and destruction throughout the 

central United States.

Note: The Modified Mercalli Intensity Scale 

measures the effect of an earthquake on the 

earth’s surface, and is measured from I to XII, 

with XII being the most intense. For example, 

for an earthquake with a Modified Mercalli 

Intensity of IX (orange in the figure above), 

some buildings may have shifted off of their 

foundations and others would have 

considerable damage, including partial 

collapses, fallen chimneys, broken windows, 

and overturned furniture

Source: GAO analysis of Federal Emergency 

Management Agency and U.S. Geological 

Survey documents (text and graphic). | 

GAO-15-20 
 

Page 12 GAO-15-20 Emergency Preparedness

In December 2008, the Deputy Secretary of Homeland Security assigned 

FEMA as the departmental lead for coordinating and improving federal 

capabilities associated with responding to and recovering from a terrorist 

IND attack. The DHS IND Strategy was issued in April 2010 and 

describes capabilities needed to respond to and recover from an IND 

incident and identified national gaps in these capabilities. The March 

2012 and September 2013 iterations of the IND Implementation Plan 

described recommended actions to address IND response capability gaps 

identified in the DHS IND Strategy, and the 2013 iteration also included 

the status of efforts to close those gaps.

Hurricane Sandy

Hurricane Sandy was the second-largest 

Atlantic Ocean storm to hit the United States 

on record (after Hurricane Katrina in 2005), 

affecting the East Coast from Florida to 

Maine, and states as far west as the Great 

Lakes. Making landfall as a post-tropical 

cyclone in southern New Jersey on October 

29, 2012, the hurricane severely affected the 

densely populated New York and New Jersey 

areas with heavy rains, strong winds, and 

record storm surges. The storm’s effects were 

extensive, leaving more than 8.5 million 

customers without power, causing severe 

flooding, and contributing to acute fuel 

shortages in parts of New York and New 

Jersey. The storm damaged or destroyed 

hundreds of thousands of homes, caused 

tens of billions of dollars in damage, and 

claimed the lives of at least 162 people 

domestically.

Source: GAO analysis of National Security 

Council documents, White House (photo). | 

GAO-15-20. Damage of New Jersey's barrier 

beaches.
 

Page 13 GAO-15-20 Emergency Preparedness

ESF coordinators have taken various approaches to carry out their 

responsibilities under the NRF to oversee the preparedness activities of 

their assigned ESFs. However, opportunities exist to strengthen the 

assessment of ESF preparedness as FEMA—in coordination with other 

federal departments and agencies through the ESF Leadership Group—

has not yet issued supplemental guidance to ESF coordinators detailing 

minimum standards for activities and product deliverables to demonstrate 

their ESFs’ overall emergency response preparedness. In addition to the 

ESF coordinator’s oversight responsibilities as defined in the NRF, the 

NRF also states that all ESFs are to support the planning core capability 

that, in part, entails establishing capability requirements, cataloging 

current capabilities, and conducting capability gap analyses. This core 

capability definition helps to identify the types of activities that ESF 

coordinators may pursue to engage—per the NRF—in appropriate 

planning and preparedness activities for their ESF. Planning helps to 

explain how federal departments and agencies are to provide the right 

resources at the right time—through, for example, ESFs—to support 

local, state, tribal, territorial, and insular area government response 

operations.

We found that ESF coordinators conduct a variety of coordination, 

planning, and capability assessment activities to oversee the 

preparedness of their ESFs based on each coordinator’s interpretation of 

what is appropriate. Information provided to us by the 10 ESF 

coordinators on their range of activities is summarized in figure 1 and 

below.27

 

27We requested information on coordination, planning, and capability assessment 

activities from 10 of the 14 ESF coordinators because the assigned coordinator for each of 

the 10 is one of the federal departments within the scope of our review (DOD, DOE, HHS, 

DHS, and DOJ). We did not assess the quality or the sufficiency of the activities reported. 

For more information on the 14 ESF coordinators, see app. I, table 6. 

ESF Coordinators 

Conduct Their 

Oversight 

Responsibilities in 

Various Ways, but 

Opportunities Exist to 

Strengthen the 

Assessment of ESF 

Preparedness
 

Page 14 GAO-15-20 Emergency Preparedness

Figure 1: Number of Emergency Support Function (ESF) Coordinators Conducting 

Selected Activities to Oversee ESF Preparedness

• Coordination. All 10 ESF coordinators identified at least one 

nonemergency activity through which they coordinate with their ESFs’ 

primary and support agencies. These coordination activities included 

conference calls, in-person meetings, trainings, and exercises, among 

others, and varied in how frequently they occur. For additional details 

on the 10 ESFs’ coordination activities, see appendix II.

• Planning. All 10 ESF coordinators identified at least one planning 

document—in addition to the information contained in the NRF’s ESF 

annexes—that they had developed for their ESFs to further define the 

roles, responsibilities, policies, and procedures for their ESFs’ 

coordination and execution. The coordinators cited various types of 

planning documents, including concepts of operations, operational 

plans, standard operating procedures, and manuals. For additional 

details on the 10 ESFs’ planning documents, see appendix II.

• Capabilities. ESF coordinators provided varied responses regarding 

whether they had established capability requirements for their ESFs, 

cataloged currently available ESF capabilities, or conducted capability 

gap analyses of currently available capabilities against capability 

requirements for their ESFs. For additional details on the 10 ESFs’ 

capability requirements, catalogs, and gap analyses, see appendix II.
 

Page 15 GAO-15-20 Emergency Preparedness

• Established capability requirements.

• Five of the 10 ESF coordinators identified quantified capability 

requirements for their ESFs.

• Three of these 5 coordinators identified capability 

requirements that were limited in scope to their department 

or agency and did not include requirements for the ESF’s 

primary and support agencies. For example, the Public 

Safety and Security coordinator (DOJ) established a 

baseline staffing requirement that each DOJ law 

enforcement component is to be ready to provide, if 

requested, to support the ESF’s operations.

• In contrast, 2 of the 5 ESF coordinators identified capability 

requirements that applied to both the coordinator’s 

department or agency and the ESF’s primary and support 

agencies. For example, the Mass Care coordinator 

(DHS/FEMA) established sheltering and feeding 

requirements that apply both to DHS (including FEMA) and 

to the ESF’s primary and support agencies.28

• The remaining 5 of the 10 coordinators did not identify having 

established quantified capability requirements for their ESFs. 

For example, the Energy coordinator (DOE) stated that the 

department did not have the authority to establish such 

requirements, as the ESF’s support agencies instead develop 

their own capability requirements based upon their individual 

missions and statutory authorities.

• Cataloged available capabilities.

• Three of the 10 ESF coordinators reported having developed a 

catalog or listing of quantified currently available capabilities 

for executing their assigned ESFs, and the Public Health and 

Medical Services coordinator (HHS) told us that such a catalog 

or listing was in development.

 

28The Mass Care ESF developed guidance that includes planning factors for its primary 

and support agencies to determine what types of capabilities will be required to execute 

the ESF’s mission after an incident—for example, what percentage of the population will 

seek emergency shelter inside the affected geographic area. This guidance identifies an 

ESF primary or support agency as a “service provider” to deliver the required capability; 

for example, DOD’s Defense Logistics Agency is responsible for providing tents, camping 

kits, equipment, and supplies.
 

Page 16 GAO-15-20 Emergency Preparedness

• Two of the 3 coordinators who cataloged available 

capabilities—Mass Care (DHS/FEMA) and Logistics 

(DHS/FEMA)—quantified capabilities for their own 

department or agency as well as for other primary and 

support agencies for their ESFs.

• The third coordinator, Public Works and Engineering 

(DOD), only cataloged DOD capabilities.

• The remaining 7 of the 10 ESF coordinators did not identify a 

catalog or listing of quantified currently available capabilities 

for their ESFs. For example, the Search and Rescue 

coordinator (DHS/FEMA) stated that the unique nature of 

search and rescue operations made it impossible to catalog 

capabilities currently available to execute the ESF’s mission.

• Conducted capability gap analyses.

• Four of the 10 ESF coordinators identified assessments that 

analyzed the gap between the ESF’s currently available 

capabilities and those that the ESF coordinator had identified 

as required.

• Two of the 4 coordinators conducted capability gap 

analyses that also included their ESFs’ primary and 

support agencies. For example, the Mass Care coordinator 

(DHS/FEMA) assessed in April 2014 whether the ESF’s 

primary and support agencies’ available resources were 

sufficient to be considered “mission ready.” 

• In contrast, 2 of the 4 coordinators that reported having 

conducted capability gap analyses—Public Works and 

Engineering (DOD) and Public Safety and Security 

(DOJ)—limited their assessments to whether there were 

gaps in resources specific to the coordinator’s agency.

• The remaining 6 of the 10 ESF coordinators did not identify 

assessments conducted to analyze capability gaps for 

executing their assigned ESFs, but the coordinators for 

Information and Planning (DHS/FEMA) and Public Health and 

Medical Services (HHS) said that efforts to identify capability 

gaps were in progress.
 

Page 17 GAO-15-20 Emergency Preparedness

The importance of assessing the preparedness of ESFs to provide 

emergency response in advance of responding to a real-world disaster 

was underscored by lessons learned from the federal response to 

Hurricane Sandy. The National Security Council’s Hurricane Sandy afteraction report highlighted challenges in ESF preparedness to respond to 

the incident despite considerable warning time before the hurricane made 

landfall—advance notice that will not exist in the event of a no-notice 

catastrophic disaster.29

• During the Hurricane Sandy federal response, the Energy coordinator 

(DOE) experienced significant challenges in attempting to coordinate 

response capabilities among its ESF’s primary and support agencies. 

According to FEMA officials, the problems experienced by the Energy 

ESF were due, in part, to a lack of communication and collaboration 

between the ESF coordinator and the ESF’s other agencies. The 

officials stated that had the ESF coordinator more effectively 

coordinated with the ESF primary and support agencies in advance of 

the hurricane, it would have been able to rely on a range of sources to 

help reestablish power to affected communities; however, the 

coordinator initially relied only on DOE capabilities, and these limited 

capabilities were quickly overwhelmed by the incident. These 

challenges with the execution of the Energy ESF led the President to 

establish an ad hoc Energy Restoration Task Force as a temporary 

work-around to coordinate efforts to restore power and address fuel 

The federal response revealed that not all ESFs 

operated effectively and that similar challenges could be experienced by 

ESFs during future disasters. One specific challenge cited by the report 

was that some ESF coordinators had adopted an intradepartmental 

approach to response operations rather than an integrated, 

interdepartmental approach that included all of the ESF’s departments 

and agencies, as prescribed by the NRF. As a result, not all ESF 

coordinators were able to fully draw upon or understand the capabilities 

and associated authorities of other departments and agencies, a fact that 

diminished the federal government’s unity of effort during the response. 

For example:

 

29National Security Council, The Federal Response to Hurricane Sandy After-Action 

Report (Washington, D.C.: June 1, 2013).
 

Page 18 GAO-15-20 Emergency Preparedness

shortages.30 According to DOE officials, DOE has taken actions to 

address challenges it experienced during Hurricane Sandy. For 

example, DOE established a permanent DOE Energy Restoration 

Team that includes private sector stakeholders who may be quickly 

contacted before, during, and after an event to assess the status of 

private sector current conditions and requirements for restoration of 

energy infrastructure.

• On the basis of a request from the Public Safety and Security 

coordinator (DOJ) to support operations, eight agencies provided 

federal law enforcement officers to help secure critical assets, guard 

fuel convoys, and perform other protective duties during the Hurricane 

Sandy federal response.31

The after-action report also called for the ESF Leadership Group to 

undertake a scenario-based capability analysis in order to identify current 

capabilities to meet ESF missions as well as related capability shortfalls.

However, according to the after-action 

report, these agencies decided independently whether or not to 

respond to the ESF coordinator’s request, how many officers they 

would supply to support each mission, and how quickly and for how 

long the officers would deploy. This agency-centric approach to 

responding to requests for assistance caused uncertainty and delays 

in meeting operational requirements. The report concluded that ESFs 

should make better use of ESF primary and support agencies’ 

capabilities, which includes clearly understanding their capabilities, 

authorities, and limitations.

32

 

30The National Security Council’s Hurricane Sandy after-action report recommended the 

following corrective action: “As a pilot, the Energy ESF, working with DHS, the National 

Business Emergency Operations Center, and relevant government and sector 

coordinating councils, should develop a comprehensive, systematic way to track and 

identify issues involving fuel processing and delivery. An interim solution should be 

operational by June 1, 2013.” According to DOE officials, the development of this pilot was 

ongoing as of August 2014 and its implementation would rely on the involvement of both 

public and private sector organizations.

31According to the NRF, the Public Safety and Security ESF is responsible for coordinating 

the integration of public safety and security capabilities and resources to support the full 

range of incident management activities. Functions include but are not limited to facility 

and resource security; security planning and technical resource assistance; public safety 

and security support; and support to access, traffic, and crowd control. 

32The National Security Council’s Hurricane Sandy after-action report recommended the 

following corrective action: “The ESF Leadership Group should undertake a scenariobased capability analysis in order to identify current capabilities to meet ESF missions as 

well as shortfalls. The ESFs should develop solutions and short-term work-arounds to 

address identified shortfalls, working in concert with non-Federal partners. The ESF 

Leadership Group should submit the analysis and short-term solutions to the National 

Security Staff by August 15, 2013.” 
 

Page 19 GAO-15-20 Emergency Preparedness

In response, in July 2013 the ESF Leadership Group asked each ESF to 

conduct a hurricane scenario-based capability analysis to identify any

gaps in its ability to deliver the core capabilities described in each ESF’s 

annex to the NRF. Nine of the 10 ESF coordinators within the scope of 

our review produced capability gap analyses that were qualitative in 

nature.33

Federal departments and agencies that serve as ESF coordinators 

oversee their ESFs’ preparedness activities in various ways, as stated 

earlier, in part because the ESF Leadership Group and the group’s chair, 

FEMA, have not issued guidance—supplemental to the NRF—to 

coordinators detailing with greater specificity the minimum standards for 

activities and product deliverables to demonstrate their ESFs’ overall 

response preparedness.34

 

33The coordinator for the 10th ESF, Search and Rescue, produced a capability gap 

analysis that compared quantified capability requirements against currently available 

capabilities. 

Apart from general descriptions of ESF 

coordinator responsibilities, the NRF does not include additional guidance 

or direction on how coordinators are to carry out their responsibilities. For 

example, the NRF does not provide guidance on (1) what amount or 

quality of contact between ESF coordinators and ESF primary and 

support agencies is necessary to demonstrate that sufficient coordination 

is ongoing; (2) what constitutes appropriate planning and preparedness 

activities, or what plans should be developed and activities engaged in to 

demonstrate that sufficient planning and activity has been completed or is 

underway; and (3) how ESF coordinators are to support the planning 

response core capability—which, in part, entails determining capability 

requirements for their ESFs, cataloging current capabilities, and 

conducting capability gap analyses—to demonstrate that the given ESF is 

34Minimum standards for coordination activities could include establishing guidance that 

ESF coordinators hold a given number of ESF-specific conferences, trainings, or 

exercises for the ESFs’ primary and support agencies within a given fiscal year. Minimum 

standards for product deliverables could include establishing guidance that ESF 

coordinators develop operational plans or standard operating procedures for their ESFs, 

as well as quantify the ESFs’ capability requirements and catalog currently available 

capabilities against said requirements.
 

Page 20 GAO-15-20 Emergency Preparedness

sufficiently prepared. Detailed guidance has also not been provided in 

other documents implementing the National Preparedness System.

35

FEMA officials told us that such guidance would be helpful to clarify what 

activities and product deliverables, at a minimum, ESF coordinators 

should engage in and develop to demonstrate effective ESF coordination. 

Further, FEMA officials told us that they prefer that ESF-specific 

expectations on minimum activities and product deliverables be 

established, as such expectations would in turn better enable FEMA to 

assess the status of ESF preparedness by comparing ESF coordinator 

activities against established expectations. For example, one potential 

ESF minimum activity expectation cited by FEMA officials could be 

whether the ESF coordinator held at least an annual ESF coordination 

conference for the ESF’s primary and support agencies in order establish 

and strengthen communication among the given ESF’s partners. FEMA 

officials stated that they have not yet issued supplemental guidance to 

ESF coordinators because they have not been required to do so and 

because they do not believe FEMA has the statutory authority to direct 

other departments or agencies to implement such guidance once issued.

However, responsibility for assessing federal emergency response 

preparedness—including for the ESFs under the NRF—is delegated by 

law and presidential directive to the Secretary of Homeland Security and 

the Administrator of FEMA. We recognize that FEMA’s authority is 

generally to coordinate, guide, and support—rather than direct—other 

departments and agencies in conducting the national preparedness 

activities delegated to them through the NRF, and that collaboration 

between FEMA and other departments and agencies is an essential 

element of these efforts. However, FEMA’s charge to lead national 

preparedness activities and assess the nation’s overall preparedness, as 

outlined in the Post-Katrina Act, provides it with the opportunity to work 

with other federal departments and agencies through the ESF Leadership 

Group to provide more detailed guidance to ESF coordinators than has 

been provided to date. Such additional guidance, setting expectations for 

 

35The NRF includes 14 ESF annexes that contain general descriptions of actions to be 

taken by the ESFs’ primary and support agencies to execute the given annex’s described 

emergency support function. However, the ESF annexes do not provide any additional 

guidance to ESF coordinators on how they are to carry out their coordinator 

responsibilities. FEMA issued the Response Federal Interagency Operational Plan for the 

NRF in July 2014; according to FEMA officials, it includes information directing each ESF 

to deliver services, supplies, and resources during the different phases of response. 

However, while the document identifies specific tasks ESFs are to take, this document 

does not provide any additional guidance on how all ESF coordinators are to execute their 

responsibilities to oversee ESF preparedness.
 

Page 21 GAO-15-20 Emergency Preparedness

coordinators on minimum standards for activities and product deliverables 

to demonstrate their ESFs’ preparedness, would better enable the 

Secretary and the Administrator to assess ESF preparedness by 

comparing actual ESF coordinator activities and deliverables produced 

against established expectations. We have previously reported that 

interagency coordination can be enhanced by clearly defining roles and 

responsibilities—such as minimum expectations for ESF coordinators—

and that clearly defining and communicating expectations for leadership 

roles and responsibilities in advance of catastrophic disasters is essential 

to better ensuring effective emergency response when such disasters 

occur.36 Existing guidance to ESF coordinators on their ESF oversight 

role identifies broad responsibilities, but does not establish minimal 

expectations for coordination activities and product deliverables. More 

specific expectations would provide a basis for the Secretary’s and 

Administrator’s assessment of current ESF preparedness that does not 

currently exist.

 

36GAO-06-15 and GAO-06-618. See also GAO, Homeland Defense: DOD Needs to Take 

Actions to Enhance Interagency Coordination for Its Homeland Defense and Civil Support 

Missions, GAO-10-364 (Washington D.C.: Mar. 30, 2010).

Federal Departments 

Identified Corrective 

Actions to Address 

Capability Gaps, but 

Management 

Oversight of 

Implementation Status 

Could Be Improved
 

Page 22 GAO-15-20 Emergency Preparedness

The federal departments that participated in NLEs monitor the status of 

their corrective actions; however they do not report this information to 

DHS or FEMA, nor does DHS or FEMA comprehensively collect this 

information from the departments. As a result, DHS and FEMA cannot 

provide a comprehensive picture of the status of national preparedness in 

its reporting, as called for by Presidential Policy Directive 8. 

NLE 2010 assessed federal preparedness to respond to an IND attack, 

and FEMA’s interagency after-action report identified 121 corrective 

actions, 104 of which were directed to one of the five departments in our 

review.37 NLE 2011 assessed federal preparedness to respond to a major 

earthquake, among other things, and FEMA’s interagency after-action 

report highlighted areas for improvement—such as the need to increase 

familiarization with earthquake response plans at the state, regional, and 

national levels—for federal departments and agencies to develop their 

own corrective actions in their own after-action reports. The five 

departments in our review identified 75 actions that they had planned to 

take to address the capability gaps identified in the interagency afteraction report. As of November 2014, nearly all of the corrective actions 

from NLEs 2010 and 2011 have been closed to date, as shown in table 

2.38

 

37The 17 remaining corrective actions were assigned to the following federal entities that 

were outside the scope of this review: 2 to the Small Business Administration, 1 to the 

Occupational Health and Safety Administration, 3 to the Department of Agriculture, 1 to 

the Department of Housing and Urban Development, and 10 to the White House. 

38The Post-Katrina Act requires FEMA to establish a program to conduct remedial action 

tracking and long-term trend analyses. See 6 U.S.C. § 750. Our report will generally refer 

to “corrective action tracking” rather than “remedial action tracking,” as used in the statute. 

For the purposes of this report, a closed corrective action includes actions that have been 

implemented, actions that were overtaken by other events and as a result were no longer 

applicable, and actions the department declined to implement for other reasons. Data 

fields in the Corrective Action Program System (CAPS) in which corrective action officers 

are to describe why an action was being closed did not consistently contain detailed 

enough information for GAO to determine if the action was closed because action had 

been taken or for another reason. For information on the corrective actions from NLE 2010 

and NLE 2011 that remain open at each department, as well as the departments’ plans to 

address these actions, see app. III.

National-Level Exercise 2010 Corrective 

Action Example 

Department: Defense (DOD)

Capability gap: The issue of National Guard 

troops being federalized and defederalized 

resulted in extensive senior leader debate and 

consultation during the exercise.

Corrective action: Convene a roundtable 

discussion with key interagency stakeholders 

to inform senior leaders regarding the 

employment, command and control, and unity 

of effort for the deployment of National Guard 

forces in this situation.

Status: Closed

Action taken: DOD officials reported that the 

department led a series of working sessions 

from June 2011 to July 2013 to examine this 

issue, and as a result, issued a formal DOD 

instruction in July 2013 on the use of the 

National Guard for defense support to civilian 

authorities for natural and manmade 

disasters.

Source: GAO analysis of Federal Emergency 

Management Agency and DOD documents, 

DOD (photo). | GAO-15-20

Federal Departments 

Monitor the 

Implementation of 

Corrective Actions from 

National-Level Exercises 

to Address Capability 

Gaps, but Could Benefit 

from Comprehensive 

Status Reporting
 

Page 23 GAO-15-20 Emergency Preparedness

Table 2: Status of Corrective Actions from National-Level Exercises (NLE) 2010 and 

2011 for the Five Departments, as of November 2014 

Department

Number of closed 

corrective 

actions/total 

Method of monitoring the implementation

of corrective actions from NLEs

NLE 2010 NLE 2011

Defense (DOD) 2/4 27/29 According to DOD officials, the department 

monitors the status of corrective actions from 

NLEs in the DOD Joint Lessons Learned 

Information System.

DOD’s system does not interface with the 

Federal Emergency Management Agency’s 

(FEMA) Corrective Action Program System 

(CAPS) and DOD officials stated that they 

do not use CAPS to monitor or provide 

information updates on the status of these 

corrective actions.

a

Energy (DOE)

b

No 

corrective 

actions

8/8 According to DOE officials, the department 

does not monitor the status of corrective 

actions from NLEs in a DOE data system. 

Instead, corrective actions assigned to DOE 

are monitored in an ad hoc manner by senior 

DOE staff responsible for overseeing DOE’s 

emergency response activities.

DOE officials stated that they do not use 

CAPS to monitor or provide information 

updates on the status of these corrective 

actions.

Health and 

Human 

Services (HHS)

c

3/3 22/22 According to HHS officials, the department 

monitors the status of corrective actions from 

NLEs using an internal-to-HHS Internetbased data management system that is 

updated by an HHS corrective action 

working group.

HHS also updated the status of the 

corrective actions assigned to the 

department in CAPS for NLE 2010 on an 

ongoing and as-needed basis until these 3 

corrective actions were closed.d

Homeland 

Security (DHS)

 

90/94 14/14 According to FEMA officials, the agency 

monitors the status of corrective actions from 

NLEs for DHS and its components in CAPS.

FEMA officials send quarterly emails to 

corrective action officers at DHS 

components to remind them to update the 

status of their component’s assigned 

corrective actions in CAPS.

National-Level Exercise 2010 Corrective 

Action Example 

Department: Homeland Security (DHS)

Capability gap: Exercise participants noted 

that fire departments across the country, 

unlike law enforcement agencies, had no 

common method of communication with one 

another.

Corrective action: Examine methods to 

connect fire departments, a vital first 

responder group.

Status: Open

Plans to address: According to DHS, the 

Office of Emergency Communications 

continues to reach out and engage state and 

local stakeholders to ensure interoperable 

emergency communications are addressed in 

the DHS National Emergency 

Communications Plan. This effort helps to 

improve communications and integration of 

local police and fire departments in response 

to natural and manmade disasters.

Source: GAO analysis of Federal Emergency 

Management Agency (FEMA) and DHS 

documents, FEMA (photo). | GAO-15-20
 

Page 24 GAO-15-20 Emergency Preparedness

Justice (DOJ) 3/3 2/2 According to DOJ officials, the department 

does not monitor the status of corrective 

actions from NLEs in a DOJ system. Instead, 

the department monitors the status of these 

corrective actions for DOJ and its 

components through DOJ’s Emergency 

Preparedness Committee, which meets on a 

monthly basis and assigns corrective actions 

to DOJ components following NLEs.

DOJ officials stated that they do not use 

CAPS to monitor or provide information 

updates on the status of these corrective 

actions. 

National-Level Exercise 2011 Corrective 

Action Example 

Department: Health and Human Services 

(HHS)

Capability gap: While exercise participants 

recognized the importance of understanding 

the benefits of social media outlets outside of 

the traditional television and radio community 

during a disaster, HHS lacked a policy or 

procedure on how to utilize information 

gained through social media.

Corrective action: Continue to foster the 

awareness of social media capabilities but 

develop HHS standards, policies, and 

procedures for their use.

Status: Closed

Action taken: According to HHS officials, the 

department developed standard operating 

procedures specifically on the use of social 

media and will reevaluate in the future to 

ensure that the procedures remain relevant 

to evolving social media

Source: GAO analysis of Federal Emergency 

Management Agency (FEMA) and 

Department of Homeland Security

documents, FEMA (photo). | GAO-15-20 

Source: GAO analysis of information provided by DOD, DOE, DOJ, DHS, and HHS. | GAO-15-20

a

According to DOD officials, DOD’s Joint Lessons Learned Information System is a knowledge 

management system and the department's centralized repository for capturing data for development 

and institutionalization of DOD lessons learned. The system is used to collect observations and best 

practices identified during exercises, real-world disasters, as well as daily operations. The system’s 

process entails recording observations, vetting these observations to identify associated issues, 

then evaluating and verifying resolutions to the identified issues. Upon resolution, these issues are 

officially designated as DOD lessons learned. DOD officials stated that the system is accessible and 

shared among some of DOD’s federal interagency partners, including DHS, FEMA, and HHS. 

b

CAPS is the database that DHS and FEMA use to monitor the status of their corrective actions 

from NLEs. According to FEMA officials, other departments and agencies may also use the system 

to monitor the status of their corrective actions.

c

Within DOE, the National Nuclear Security Administration’s Office of Emergency Response formally 

tracks lessons learned from radiological emergency responses and exercises. According to DOE 

officials, observations and findings are rolled up into lessons learned from which corrective actions 

are developed. These corrective actions are prioritized and funded according to their importance. 

Regularly scheduled meetings track the progress of these corrective actions.

d

HHS did not update the status of its corrective actions for NLE 2011 in CAPS, as it had done for 

NLE 2010, because FEMA did not catalog corrective actions for NLE 2011 in CAPS for departments 

outside of DHS. 
 

Page 25 GAO-15-20 Emergency Preparedness

To enhance FEMA’s ability to assess the extent to which corrective 

actions have been implemented and describe strengths and weaknesses 

in the nation’s preparedness capabilities, we recommended in April 2009 

that FEMA either (1) revise the National Exercise Program to require the 

use of FEMA’s Corrective Action Program System (CAPS), the database 

that DHS and FEMA use to monitor the status of their corrective actions 

from NLEs, or (2) require that federal agencies submit a report to FEMA 

on the status of their corrective actions resulting from such exercises.39 In 

June 2012, FEMA issued an updated implementation plan for the 

National Exercise Program that states that all federal-level corrective 

actions developed from NLEs are to be tracked through CAPS from 

identification through implementation. According to FEMA officials, the 

agency assists in this process by initially inputting the corrective actions 

into CAPS following an NLE. However, as shown in table 2, we found 

that, other than DHS, only HHS updated the status of its assigned 

corrective actions in CAPS, and FEMA officials noted that the agency 

does not have authority to compel other departments and agencies to 

update the status of their corrective actions in the system. Officials from 

DOD, DOE, and DOJ told us they do not use CAPS because they instead 

prefer to use their own internal corrective action monitoring systems or 

processes. Thus, while FEMA took actions to enhance its ability to 

monitor corrective actions in CAPS, other federal departments that 

participate in NLEs do not report this information to DHS or FEMA. As a 

result, FEMA has not yet been able to assess the extent to which NLE 

corrective actions have been implemented across the federal government 

and, ultimately, describe strengths and weaknesses in the nation’s 

preparedness capabilities.

 

39In April 2009, we reported that although the Post-Katrina Act did not give FEMA the 

authority to compel other federal entities to comply with the objectives of the National 

Exercise Program, the act placed responsibility for implementing the National Exercise 

Program on FEMA, in coordination with other appropriate federal entities. Further, we 

reported that it was incumbent on FEMA to coordinate with other federal entities to better 

ensure that FEMA obtains the information it needs to meet its statutory responsibility to 

track corrective actions. However, the implementation plan for the National Exercise 

Program at that time did not require federal departments and agencies to report corrective 

action information to FEMA. See GAO, National Preparedness: FEMA Has Made 

Progress, but Needs to Complete and Integrate Planning, Exercise, and Assessment 

Efforts, GAO-09-369 (Washington, D.C.: Apr. 30, 2009). 
 

Page 26 GAO-15-20 Emergency Preparedness

FEMA could more comprehensively report on the nation’s overall 

preparedness if it had information on the status of implementation of 

corrective actions identified through the NLEs. Specifically, in March 

2011, the White House issued Presidential Policy Directive 8 on National 

Preparedness, which called for FEMA to lead the development of a 

comprehensive approach to assessing national preparedness as well as 

to develop an annual national preparedness report.40 To develop the 

annual National Preparedness Report, FEMA contacts other federal 

departments and agencies requesting information on, among other 

things, strengths and areas for improvement identified following exercises 

over the prior year, which may include both NLEs as well as exercises 

conducted internally at a given department or agency.41 However, the 

agency does not request information on the status of corrective actions to 

be implemented by other federal departments and agencies arising from 

such exercises because, according to FEMA officials, the National 

Preparedness Report is written for a national audience and contains 

limited detail on any given federal department or agency. In response to 

FEMA’s request for information when preparing the March 2014 National 

Preparedness Report, FEMA officials stated that other federal 

departments and agencies provided anecdotal examples of ongoing 

efforts and accomplishments achieved to improve national preparedness. 

However, Presidential Policy Directive 8 calls for the National 

Preparedness Report to describe the progress made toward meeting the 

National Preparedness Goal.

42

 

40The Post-Katrina Act also required FEMA to develop a comprehensive assessment 

system and annual federal preparedness reports. 6 U.S.C. §§ 749, 752. 

Anecdotal examples provided by other 

federal departments and agencies, while illustrative, do not provide a 

comprehensive description of the progress made in closing capability 

gaps identified through prior NLEs. The status of implementation of

corrective actions to close these known gaps is an integral component in 

describing the overall status of national preparedness.

41According to the March 2014 National Preparedness Report, FEMA collected and 

reviewed over 1,000 data and information sources from federal, state, local, tribal, 

territorial, private sector, and nongovernmental entities, among others, to develop the 

report. For example, the report used the results of a self-assessment process that states 

and territories completed in 2013, including Threat and Hazard Identification Risk 

Assessment and State Preparedness Report submissions that states and territories are 

required to complete in order to receive preparedness grant funding. 

42The National Preparedness Goal, called for by Presidential Policy Directive 8 and issued 

in September 2011, defines the core capabilities necessary for emergency response to 

specific types of incidents, including acts of terrorism and natural disasters. 

National-Level Exercise 2011 Corrective 

Action Example 

Department: Defense (DOD)

Capability gap: During the exercise, DOD 

officials noted the need to have a mapping 

product capable of providing the commander 

with a picture of significant interagency 

activities, but noted that agency partners did 

not use a standard common operating picture 

product.

Corrective action: Develop a tool to reside on 

the Non-Classified Internet Protocol Router 

network portal for use by all battle cells and 

directorates to allow internal and external 

data sharing with interagency partners, the 

private sector, and nongovernmental 

organizations.

Status: Open

Plans to address: According to DOD officials, 

this action developed into two issues—

information sharing via the Situational 

Awareness Geospatial Enterprise (SAGE)

and operationalizing SAGE information for 

assessments and decisions—both of which 

are being addressed by a relevant working 

group.

Source: GAO analysis of DOD documents 

(text and photo). | GAO-15-20
 

Page 27 GAO-15-20 Emergency Preparedness

According to FEMA officials, the National Security Council is responsible 

for monitoring the overall implementation of corrective actions across the 

federal interagency. Specifically, the council is responsible for overseeing 

the progress of corrective action implementation from NLEs for all federal 

departments and agencies to ensure priority issues are assigned and 

completed within a specific timeframe.43 FEMA officials stated that the

council occasionally tasks relevant departments and agencies with 

providing an update on the status of their corrective actions from NLEs. 

On such occasions, FEMA provided this information for DHS and its 

components, while other federal departments and agencies provided the 

status of their corrective actions directly to the council.44

According to FEMA officials, the agency does not request information on 

the status of corrective actions from NLEs for other departments from the 

National Security Council because it does not have the responsibility to 

do so.45

 

43FEMA, National Exercise Program Base Plan (Washington, D.C.: March 18, 2011). 

However, in order to have a comprehensive picture of the 

progress made toward meeting the National Preparedness Goal, the 

Secretary of Homeland Security—through FEMA—would benefit from 

comprehensive and up-to-date information on the extent to which 

capability gaps identified through NLEs have been addressed. While the 

departments in our review reported that nearly all of the outstanding 

corrective actions from NLE 2010 and NLE 2011 have been closed as of 

August 2014, FEMA plans to conduct future NLEs on a biennial and 

ongoing basis and information on the implementation of corrective actions 

identified through these future exercises will be important to providing a 

more complete picture of the nation’s preparedness. Thus, collecting 

information on the status of corrective actions from NLEs across the 

federal government would better position the Secretary of Homeland 

44According to FEMA officials, updates on the status of corrective actions provided to the 

council by other federal departments and agencies are subsequently forwarded to FEMA 

by the council for FEMA’s situational awareness.

45While FEMA does not monitor the status of NLE corrective action implementation 

beyond DHS and its components, FEMA officials noted that the agency seeks to increase 

interagency awareness of open NLE corrective actions by providing monthly updates to 

the interagency National Exercise Program Exercise Implementation Committee, which 

includes senior representatives from federal departments and agencies, on the status of 

corrective actions from prior NLEs as displayed in CAPS. However, because we found 

that the other federal departments and agencies within the scope of our review generally 

do not use CAPS, this information is not comprehensive or up to date. According to FEMA 

officials, FEMA reminds other departments and agencies at the monthly committee 

meeting of their responsibility to update the status of their assigned corrective actions in 

CAPS. FEMA officials stated that they also offer the departments and agencies the option 

to provide status updates through other means, such as email. 
 

Page 28 GAO-15-20 Emergency Preparedness

Security—through FEMA— to comprehensively describe the status of 

national preparedness in its annual reporting.

Following real-world emergency incidents, such as the federal response 

to Hurricane Sandy in October 2012, federal departments and agencies 

at times develop after-action reports that identify corrective actions to 

address observed federal capability gaps and subsequently monitor the 

status of their corrective actions; however they do not report to FEMA or 

DHS on the status of these actions, nor does DHS or FEMA collect this 

information from the departments. As a result, DHS and FEMA cannot 

provide a comprehensive picture of the status of national preparedness in 

its reporting, as called for by Presidential Policy Directive 8. 

Departments Monitor the 

Implementation of 

Corrective Actions from 

Real-World Incidents, but 

DHS Could Benefit from 

Comprehensive Status 

Reporting
 

Page 29 GAO-15-20 Emergency Preparedness

The five departments we reviewed all identified capability gaps and 

developed associated corrective actions following the federal 

government’s response to Hurricane Sandy, and they are each 

monitoring the status of their assigned actions through their own internal 

systems or processes. As shown in table 3, more than half (63 out of 102) 

of the corrective actions identified by the five departments or their 

components based on their response to Hurricane Sandy have been 

closed as of November 2014.46 In addition, as shown in table 3, DOD, 

DOE, DOJ, and HHS used the same processes to monitor the status of 

corrective actions they developed in response to Hurricane Sandy as they 

did for the corrective actions they developed in response to prior NLEs, 

as previously discussed. In contrast, FEMA uses a different process, 

monitoring the status of its corrective actions through an intra-agency 

working group and an internal-to-FEMA data-sharing repository.47 None 

of the five departments used CAPS to monitor corrective actions from 

Hurricane Sandy or otherwise report this information to DHS or FEMA, 

nor did FEMA request or receive information from the other departments 

on their status.

 

46For information on the corrective actions from Hurricane Sandy that remain open at each 

department, as well as their plans to address these actions, see app. IV. 

47In April 2009, we recommended that FEMA develop procedures for including lessons 

learned from real-world incidents in CAPS. This recommendation focused on corrective 

actions identified internally at FEMA. FEMA issued a management directive on the 

Lessons Learned/Continuous Improvement Program in February 2013. According to the 

directive, all corrective actions identified for assignment and tracking based on lessons 

learned (including from real-world incidents) that are beyond the capability of a given 

FEMA component to resolve or that are of significant interest to FEMA management are to 

be presented to the FEMA Continuous Improvement Working Group and should be 

submitted for inclusion in CAPS. The issuance of this directive met the intent of our 

recommendation. See GAO-09-369. While the management directive encourages FEMA’s 

components to use CAPS, they may use other processes as necessary. For corrective 

actions from Hurricane Sandy, FEMA reported using an internal-to-FEMA data-sharing 

repository to monitor their status. 

Hurricane Sandy Corrective Action 

Example 

Department: Justice (DOJ)

Capability gap: The regional law enforcement 

coordinators and field coordinators of the 

Public Safety and Security emergency support 

function (ESF) deployed to the field during 

Hurricane Sandy did not have the supplies 

necessary to perform their mission

Corrective action: Develop a deployment kit to 

be sent with regional law enforcement 

coordinators and field coordinators during all 

Public Safety and Security ESF deployments.

Status: Closed

Action taken: Standardized deployment gear 

and clothing were provided to all deployable 

Public Safety and Security ESF personnel.

Further, each region was provided a 

“deployment kit,” and extra deployment kits 

are maintained at the Public Safety and 

Security ESF headquarters.

Source: GAO analysis of DOJ documents, 

Federal Emergency Management Agency 

(photo). | GAO-15-20
 

Page 30 GAO-15-20 Emergency Preparedness

Table 3: Status of Corrective Actions from Hurricane Sandy for Five Departments, as of November 2014

Department and relevant 

component

Number of closed 

corrective actions/total

Method of monitoring the implementation

of corrective actions from Hurricane Sandy

Defense (DOD)

• Northern Command 

(NORTHCOM)

8/10

a

According to DOD officials, the department monitors the status of 

corrective actions from real-world incidents in the DOD Joint Lessons 

Learned Information System. DOD’s system does not interface with 

FEMA’s Corrective Action Program System (CAPS) and DOD officials 

stated that they do not use CAPS to monitor or provide information 

updates on the status of these corrective actions.

Energy (DOE)

b

• Office of Electricity Delivery 

and Energy Reliability

7/9

c

According to DOE officials, the department does not monitor the status 

of corrective actions from real-world incidents in a formal DOE data 

system. Instead, corrective actions assigned to DOE are monitored in 

an ad hoc manner by senior DOE staff responsible for overseeing 

DOE’s emergency response activities. DOE officials stated that they 

do not use CAPS to monitor or provide information updates on the 

status of these corrective actions.

Health and Human 

Services (HHS)

22/44 According to HHS officials, the department monitors the status of 

corrective actions from real-world incidents using an internal-to-HHS 

Internet-based data management system that is updated by an HHS 

corrective action working group. However, HHS does not update or 

otherwise use CAPS to monitor the status its corrective actions from 

real-world incidents, in part because FEMA does not catalog corrective 

actions in CAPS for other departments for real-world incidents as it 

does for national-level exercises. 

Homeland Security (DHS)

• Federal Emergency 

Management Agency (FEMA)

5/14 According to FEMA officials, FEMA monitors the status of corrective 

actions from Hurricane Sandy through its Continuous Improvement 

Working Group and an internal-to-FEMA data-sharing repository. 

Unlike with corrective actions from NLEs, FEMA does not require that 

corrective actions from real-world incidents are tracked in CAPS. While 

FEMA’s offices are encouraged to use CAPS, they may use other 

processes as necessary.

Justice (DOJ)

• Bureau of Alcohol, Tobacco, 

Firearms and Explosives 

(ATF)

21/25

d

According to DOJ officials, the department does not monitor the status 

of corrective actions from real-world incidents in a formal DOJ system. 

Instead, the department monitors the status of these corrective actions 

for DOJ and its components through DOJ’s Emergency Preparedness 

Committee, which meets on a monthly basis and assigns corrective 

actions to DOJ components following NLEs. DOJ officials stated that 

they do not use CAPS to monitor or provide information updates on 

the status of these corrective actions.

Source: GAO analysis of information provided by DOD, DOE, DOJ, DHS, and HHS. | GAO-15-20
 

Page 31 GAO-15-20 Emergency Preparedness

Source: GAO analysis of information provided by DOD, DOE, DOJ, DHS, and HHS. | GAO-15-20

a

NORTHCOM is the DOD component primarily responsible for defense support to civilian authorities 

in the continental United States and Alaska, among other areas.

b

CAPS is the database that DHS and FEMA use to monitor the status of their corrective actions from 

NLEs. According to FEMA officials, other departments and agencies may also use the system to 

monitor the status of their corrective actions.

c

DOE’s Office of Electricity Delivery and Energy Reliability is the coordinator of the ESF on Energy, 

which provided situational assessments of the electricity, oil, and natural gas sectors, among other 

kinds of support, to assist with the response to Hurricane Sandy.

d

ATF is the coordinator of the ESF on Public Safety and Security, which coordinated the deployment 

of federal law enforcement officers, among other kinds of support to assist with the response to 

Hurricane Sandy.

In addition to the after-action reports developed by each department 

following Hurricane Sandy, the National Security Council’s Hurricane 

Sandy after-action report recommended 17 corrective actions, most of 

which were assigned to the council, FEMA, or the ESF Leadership Group. 

However, FEMA officials stated that these corrective actions were not 

formally assigned by the National Security Council to FEMA or others for 

implementation and closure. FEMA officials stated that although they are 

not officially monitoring the status of these actions, the agency meets 

regularly with ESF coordinators to discuss issues identified in the report, 

among other things, as the chair of the ESF Leadership Group.

In addition to requesting information related to strengths and areas for 

improvement identified following exercises for development of the 

National Preparedness Report, FEMA also requests information for the 

report on strengths and areas for improvement identified following the 

federal response to recent real-world incidents over the prior year. 

According to FEMA officials, in response to this request, other federal 

departments and agencies provided anecdotal examples of ongoing 

efforts and accomplishments to improve national preparedness, including 

examples of progress made to address areas for improvement identified 

during Hurricane Sandy. However, as with NLEs and other exercises, 

FEMA does not request information from other departments and agencies 

on the status of their corrective actions identified following real-world 

incidents because, according to FEMA officials, the National 

Preparedness Report is written for a national audience and contains 

limited detail on any given federal department or agency. Presidential 

Policy Directive 8 calls for the National Preparedness Report to describe 

the progress made toward meeting the National Preparedness Goal. 

Anecdotal examples provided by other federal departments and agencies, 

while illustrative, do not provide a comprehensive description of the 

Hurricane Sandy Corrective Action 

Example 

Department: Energy (DOE)

Capability gap: Situational awareness of fuel 

supplies was inadequate and better 

communication of power restoration 

timeframes was needed.

Corrective action: Leverage technology to 

improve response and communications, 

including working with public and private 

sector responders to identify effective 

communication and response technologies, 

as well as processes and opportunities for 

technology solutions to improve information 

sharing.

Status: Closed

Plans to address: According to DOE, the 

department is addressing this action through 

a visualization and modeling platform that will 

allow DOE staff to geospatially map energy 

assets and systems and tie together a variety 

of data sources into one platform.

Source: GAO analysis of DOE documents 

(text and photo). | GAO-15-20
 

Page 32 GAO-15-20 Emergency Preparedness

progress made in closing capability gaps identified through prior realworld disasters. The status of implementation of corrective actions to 

close these known gaps is an integral component in describing the overall 

status of national preparedness.

As discussed, FEMA is not aware of the full range of information on 

capability gaps identified by other federal departments and agencies 

during this and other real-world incidents. According to FEMA officials, 

the agency does not collect information on the status of corrective actions 

from other departments because it does not have the responsibility to do 

so. However, in order to have a comprehensive picture of the progress 

made toward meeting the National Preparedness Goal, the Secretary of 

Homeland Security—through FEMA—would benefit from comprehensive 

and up-to-date information on the extent to which capability gaps 

identified through real-world disasters have been addressed. While the 

implementation of corrective actions is the responsibility of the 

departments and agencies to which those actions are assigned, 

information on the status of corrective actions identified through realworld disasters is important for providing a more complete picture of the 

nation’s preparedness. Thus, collecting information on the status of these 

corrective actions across the federal government would better position the 

Secretary of Homeland Security—through FEMA—to comprehensively 

describe the status of national preparedness in its annual reporting.
 

Page 33 GAO-15-20 Emergency Preparedness

FEMA issued the IND Implementation Plan in March 2012 to document 

proposed corrective actions to address IND response capability gaps for 

federal emergency response identified in the April 2010 DHS IND 

Strategy. However, the plan does not capture key program management 

information—including, among other things, estimates of completion 

dates, interim timeframes and milestones, and funding and resource 

requirements—which hinders management’s ability to monitor the status 

of the identified corrective actions.48 Specifically, five interagency working

groups composed of subject matter experts from federal departments and 

agencies as well as stakeholders from state and local emergency 

management organizations, academic institutions, and research centers 

identified over 300 proposed corrective actions in the IND Implementation 

Plan needed to close the 136 capability gaps identified in the DHS IND 

Strategy.

49 DHS designated FEMA’s Response Directorate’s Chemical, 

Biological, Radiological, Nuclear, and High Explosives Office to lead 

monitoring the status of efforts to close capability gaps identified in the 

DHS IND Strategy and coordinating the five interagency working groups 

that are responsible for closing the identified gaps. Table 4 describes the 

focus areas for each of the working groups as well as the number of 

capability gaps identified in the DHS IND Strategy for which the working 

groups were assigned lead responsibility.

 

48DHS, DHS Strategy for Improving the National Response and Recovery from an IND 

Attack (Washington, D.C.: April 2010); FEMA, Improvised Nuclear Device Response and 

Recovery Capability-Based Implementation Plan (Washington, D.C.: March 2012). 

49The DHS IND Strategy aligns the 136 identified capability gaps to seven overarching 

objectives that must be achieved in order to effectively respond to and recover from an 

IND attack: (1) manage the response, (2) characterize the incident, (3) mass evacuation 

and in-place protection, (4) medical triage, (5) provide casualty and evacuee care, (6) 

stabilize and control impacted area, and (7) perform site recovery and restore essential 

functions.

FEMA Developed a Plan 

to Address IND Response 

Capability Gaps, but the 

Agency Could Benefit from 

Adopting Leading 

Practices for Program 

Management

Improvised Nuclear Device (IND) Capability 

Gap and Corrective Action Example

Working group: Medical and Public Health

Capability gap: There is a need for greater 

access to U.S. Food and Drug Administrationapproved medical countermeasures for 

treating radiation effects in the wake of an IND 

detonation. Medical countermeasures include 

vaccines, drugs, and diagnostics to treat 

medical conditions such as radiation 

poisoning that can occur in the wake of an 

IND detonation.

Corrective action: Pursue research and 

development of new and predeploying 

existing countermeasures for such treatment.

Progress: The September 2013 IND 

Implementation Plan reported that completion 

of this action will take 5 to 10 years.

Source: GAO analysis of Federal Emergency 

Management Agency documents, U.S. Food 

and Drug Administration (graphic). | 

GAO-15-20
 

Page 34 GAO-15-20 Emergency Preparedness

Table 4: Improvised Nuclear Device (IND) Interagency Working Group Focus Areas 

and Assigned Capability Gaps as Described in the IND Implementation Plan

Working group Description

Response • Focuses on gaps related to incident response and 

command capabilities required to effectively respond to an 

IND detonation from the first few minutes after the blast to 

approximately a month after the incident.

• Assigned lead responsibility for 61 of 136 identified 

capability gaps. 

Recovery • Focuses on capability gaps related to post-IND detonation 

cleanup and decontamination of affected areas.

• Assigned lead responsibility for 18 of 136 identified 

capability gaps.

Medical and Public 

Health

• Focuses on gaps related to medical response capabilities 

required to effectively respond to post-IND detonation, 

including medical triage, treatment, training for first 

responders and healthcare providers, patient tracking, 

clinical laboratory surge, and emergency responder and 

evacuee safety.

• Assigned lead responsibility for 52 of 136 identified 

capability gaps.

Communications and 

Public Messaging

• Focuses on capability gaps related to disseminating public 

information and communications post-IND detonation for 

both emergency responders and the public, and provides 

related support to the other working groups as needed.

• Assigned lead responsibility for 5 of 136 identified 

capability gaps. 

Scientific Support • Provides scientific and technical input for the activities of 

all the working groups.

• Assigned lead responsibility for none of the 136 identified 

capability gaps.

Source: GAO analysis of Federal Emergency Management Agency documents. | GAO-15-20

Improvised Nuclear Device (IND) Capability 

Gap and Corrective Action Example

Working group: Response

Capability gap: Emergency shelters proximate 

to an IND detonation may not open following 

the incident because of public perceptions 

about the potential dangers posed by low 

levels of radioactive contamination.

Corrective action: Develop a white paper for 

Federal Emergency Management Agency 

(FEMA) officials that addresses, among other 

things, challenges related to decontaminating 

people and animals in need of shelter.

Progress: The September 2013 IND 

Implementation Plan reported that this action 

was 75 percent complete.

Source: GAO analysis of FEMA documents 

(text and photo). | GAO-15-20 
 

Page 35 GAO-15-20 Emergency Preparedness

In September 2013, FEMA issued its first annual update to the IND 

Implementation Plan to describe progress made to address the highestpriority capability gaps previously identified in the DHS IND Strategy.

50

Specifically, the updated IND Implementation Plan identified ongoing 

actions of the working groups to close 14 of the 136 capability gaps 

identified in the DHS IND Strategy, noting that few, if any, gaps had been 

completely closed.51

Our analysis of the September 2013 IND Implementation Plan found that 

the plan provided only general information on ongoing activities to 

address previously identified capability gaps. It did not identify detailed 

program management information. For example, for the 14 prioritized 

capability gaps with ongoing activities described in the plan, the plan did 

not describe specific estimated target completion dates nor interim 

timeframes and milestones toward completion, but instead described 

projects in terms of their relative degree of completion (e.g., 25 percent 

complete), general estimated timeframes (e.g., 5 to 10 years to 

Further, the plan also identified an additional 31 

high-priority capability gaps with associated corrective actions that had 

not yet been initiated. Finally, the plan also noted that the interagency 

working groups were to review all 136 previously identified capability gaps 

and corresponding corrective actions—removing existing or adding new 

gaps and associated actions as necessary—prior to issuance of the next 

iteration of the annual update to the IND Implementation Plan in 2015.

 

50FEMA, Improvised Nuclear Device Response and Recovery Capability-Based 

Implementation Plan, Revision 1 (Washington, D.C.: September 2013). According to 

FEMA officials, each working group determined which gaps it would prioritize for closure, 

drawing from the subset of capability gaps assigned to the given working group in the 

March 2012 version of the IND Implementation Plan. 

51At the time of the September 2013 update to the IND Implementation Plan, the Recovery 

Working Group reported that it was in the process of conducting a needs assessment to 

determine what activities to take to address the assigned actions, and the group did not 

identify any ongoing activities to address capability gaps. For additional details on the five 

interagency working groups’ ongoing activities to address the 14 identified capability gaps 

with projects underway as of September 2013, see app. V. While few gaps have been 

completely closed, FEMA officials noted that the agency has taken a number of actions to 

improve the federal response to an IND attack since October 2013. For example, 

according to FEMA officials these actions include, but are not limited to, conducting IND 

attack exercises in two cities, developing regional IND response plans, and developing an 

appendix to the Response Federal Interagency Operational Plan on responding to nuclear 

and radiological incidents and attacks, including an IND attack, which is expected to be 

completed by the end of calendar year 2014. 

Improvised Nuclear Device (IND) Capability 

Gap and Corrective Action Example

Working group: Recovery

Capability gap: Recovery personnel must be 

able to minimize radioactive waste volume 

and reduce the public's radiation exposure to 

scientifically defendable and safe levels. 

Corrective action: Develop technologies for 

containment of the radiological or nuclear 

contaminants as well as guidance on how 

they should be applied to various urban 

areas, including critical infrastructure.

Progress: The September 2013 IND 

Implementation Plan reported that this was a 

high-priority capability gap for which there was 

no currently identified program or project.

Source: GAO analysis of Federal Emergency 

Management Agency documents, Department 

of Homeland Security (photo). | GAO-15-20
 

Page 36 GAO-15-20 Emergency Preparedness

complete), or as being ongoing without additional detail.52 Further, with 

regard to funding, none of the activities for the 14 gaps identified specific 

funding or resource requirements to complete these activities.53

The IND Implementation Plan contains limited information on the five 

working groups’ ongoing activities, in part because FEMA has not 

requested the information. According to FEMA officials, detailed program 

management information is maintained by the interagency working 

groups and the relevant departments or agencies funding the activities of 

a given working group. FEMA officials stated during the course of our 

review that, as of August 2014, they had initiated the process of 

developing a multiyear program management plan for executing the IND 

Implementation Plan. The program management plan will supersede the 

existing IND Implementation Plan and be updated on a quarterly basis, 

according to FEMA officials. However, the officials stated that they were 

in the early stages of developing this new program management plan and 

were unable to identify specific elements that the plan will contain when 

finalized, including whether it would include estimated completion dates, 

interim timeframes and milestones, and estimates of funding and 

resource requirements.

As a 

result, the IND Implementation Plan as written does not enable DHS and 

FEMA management to know, among other things, when a given capability 

gap will be closed or what interim milestones should exist on its way to 

closure, what detailed actions are necessary by which federal actors and 

in what sequence, or how much it will cost to close the given gap.

54

 

52For the 14 capability gaps described in the plan, their status of completion was variably 

and inconsistently reported. Specifically, activities for 5 of the gaps were described in 

terms of their relative degree of completion (e.g., 25 to 75 percent complete); activities for 

2 of the gaps were described in terms of their general estimated timeframe for completion 

(i.e., 1 to 5 and 5 to 10 years to complete, respectively); activities for 6 of the gaps were 

described as ongoing without additional detail; and activities for 1 of the gaps did not 

provide information on the status of completion because FEMA was reevaluating whether 

the corrective actions were within its scope of responsibilities. For more details, see 

app.V. 

53For the 14 capability gaps described in the plan, activities for 11 of the gaps were 

reported as being funded by FEMA and 3 of the gaps were reported as being jointly 

funded by DOD and HHS, but funding requirements were not specified. 

54FEMA officials stated that the program management plan under development at the time 

of our review was in the early stages of drafting and was therefore not available for us to 

review. According to FEMA officials as of August 2014, the draft program management 

plan was scheduled to be completed by the end of calendar year 2014 and was intended 

to cover IND Implementation Plan activities through fiscal year 2018. 

Improvised Nuclear Device (IND) Capability 

Gap and Corrective Action Example

Working group: Communications and Public 

Messaging

Capability gap: Public communications systems 

exist but are inadequate for large-scope 

incidents, such as an IND detonation. Local 

information sources need to establish initial 

communications with, among, and between the 

affected population and response forces, 

government, and media.

Corrective action: Develop a public 

communications strategy to provide awareness 

of safety and security actions in the vicinity of 

the blast area and in the overall federally 

declared disaster area.

Progress: The September 2013 IND 

Implementation Plan reported that this action 

was ongoing, but did not provide a specific date 

the action was to be completed.

Source: GAO analysis of FEMA documents 

(text and photo). | GAO-15-20
 

Page 37 GAO-15-20 Emergency Preparedness

As a leading practice to better enable management oversight for 

monitoring the implementation of a specific program and its related 

projects, The Standard for Program Management calls for the 

development of detailed program management information that should 

include, among other things, estimated completion dates, interim 

timeframes and milestones, and estimates of funding and resource 

requirements to accomplish the program’s intended ends.55 Such 

program management information is designed to assist management in 

assessing the status of efforts related to the program and its associated 

projects, identifying potential funding or resource shortfalls, and ensuring 

that resources are properly allocated based on management’s priorities. 

Without such information, the IND Implementation Plan as currently 

written cannot on its own provide reasonable assurance to the Secretary 

of Homeland Security that FEMA’s efforts to coordinate implementation of 

the DHS IND Strategy will be achieved in an effective or efficient manner. 

Although FEMA officials stated that they plan to develop a multiyear 

program management plan in the future for implementation of the DHS 

IND Strategy, such an effort was in the preliminary stages of development 

at the time of our review and officials were unable to describe the extent 

to which the intended plan may include detailed program management 

information. Including such information would better enable FEMA 

management to assess the extent of progress made toward executing the

DHS IND Strategy against estimated completion dates, interim 

timeframes and milestones, and funding and resources requirements. 

Developing and regularly updating detailed program management plan 

information for execution of the DHS IND Strategy would better enable 

officials in FEMA’s Chemical, Biological, Radiological, Nuclear, and High 

Explosives Office and by extension, the Secretary of Homeland Security 

to perform necessary management oversight for monitoring 

implementation of the corrective actions to close the 136 identified IND 

response capability gaps.

 

55The Project Management Institute, The Standard for Program Management, third 

edition.

Improvised Nuclear Device (IND) Capability 

Gap and Corrective Action Example

Working group: Scientific Support

Capability gap: The current plume modeling 

capability uses input assumptions derived 

from empirical data from two surface 

detonations in a nonurban environment, which 

may lead to uncertain results when dealing 

with an IND detonation in an urban 

environment. 

Corrective action: Improve model input 

assumptions for an urban environment to 

account for, among other things, fireball 

temperature in an urban environment and 

particle size distribution for asphalt, concrete, 

and other urban materials.

Progress: The September 2013 IND 

Implementation Plan reported that this was a 

high priority capability gap for which there was 

no currently identified program or project.

Source: GAO analysis of Federal Emergency 

Management Agency documents, Department 

of Energy (photo). | GAO-15-20
 

Page 38 GAO-15-20 Emergency Preparedness

No-notice catastrophic disasters, including IND attacks and major 

earthquakes, have the potential to cause enormous loss of life and 

property. National emergency preparedness activities, including the 

effective coordination of ESFs under the NRF and closure of capability 

gaps identified through national-level exercises, real-world disasters, and

other assessments are means to better ensure the strength and resiliency 

of the United States in the face of such threats. Given the Secretary of 

Homeland Security’s assigned responsibility to ensure that overall federal 

preparedness actions are unified, complete, and synchronized to prevent 

unfilled gaps or seams in the federal government’s efforts to respond to 

all hazards, it is essential that the Secretary have accurate and up-to-date 

information on the readiness of interagency efforts—including through 

ESFs—to respond to major disasters, and knowledge that identified 

capability gaps are being addressed and closed in a timely manner. 

However, the Secretary cannot fulfill this responsibility without the 

collaborative interagency efforts of the other federal departments and 

agencies that share responsibilities under the NRF to assess their 

capabilities and close gaps. While the federal government has made 

significant progress in implementing elements of the national 

preparedness system, opportunities continue to exist to enhance 

interagency assessment and accountability efforts to close identified 

capability gaps. Establishing supplemental guidance to define minimum 

standards of performance for ESF coordination will better enable the 

Secretary to know that the coordinators have engaged in an appropriate 

level of planning and preparedness activities to provide reasonable 

assurance that any given ESF is ready to respond. Regular and 

comprehensive reporting to the Secretary on the status of implementation 

of corrective actions designed to address capability gaps previously 

identified through national-level exercises and major real-world disasters 

will better enable the Secretary to know that lessons were learned and 

corrective actions implemented in timely manner by responsible federal 

departments and agencies. Finally, ensuring that robust program 

management information has been developed for executing the closure of 

capability gaps identified in the DHS IND Strategy will better enable the 

Secretary to know that such gaps are being addressed effectively and 

efficiently. These modest process and procedural improvements will 

serve to better ensure that the Secretary is able to establish and build the 

unified, complete, and synchronized national preparedness system that is 

envisioned by national preparedness policy and doctrine.

Conclusions
 

Page 39 GAO-15-20 Emergency Preparedness

To enhance DHS’s and FEMA’s ability to assess ESF preparedness, we 

recommend that the Secretary of Homeland Security direct the 

Administrator of FEMA—in coordination and collaboration with other 

federal departments and agencies through the ESF Leadership Group—

to issue supplemental guidance to ESF coordinators that details minimum 

standards for activities and product deliverables necessary to 

demonstrate ESF preparedness. This guidance should include minimum 

expectations on how ESF coordinators are to demonstrate (1) that 

coordination with ESF primary and support agencies is sufficient, (2) that 

planning and preparedness activities are appropriate, and (3) whether 

required capabilities are available to effectively and efficiently respond to 

a disaster.

To enhance the Secretary of Homeland Security’s ability to assess 

national preparedness and provide management oversight of federal 

interagency efforts to close previously identified capability gaps, we 

recommend that the Secretary of Homeland Security direct the 

Administrator of FEMA—in coordination and collaboration with the 

National Security Council Staff and other federal departments and 

agencies—to collect information on and regularly report to the Secretary 

the status of federal interagency implementation of corrective actions 

identified (1) through prior national-level exercises and (2) following realworld incidents, specifically major disasters.

To better enable the Secretary of Homeland Security to ensure that 

capability gaps identified in the DHS IND Strategy are addressed in an 

effective and efficient manner, we recommend that the Secretary of 

Homeland Security direct the Administrator of FEMA—in coordination and 

collaboration with other federal departments and agencies—to develop 

detailed program management information, consistent with leading 

practices discussed in this report, for federal interagency closure of the 

capability gaps identified in the DHS IND Strategy. This information 

should include, among other things, detailed estimates of completion 

dates for initiated activities, interim timeframes and milestones for 

monitoring and tracking progress, and necessary funding and resource 

requirements.

Recommendations for 

Executive Action
 

Page 40 GAO-15-20 Emergency Preparedness

We provided a draft of this report to DHS, DOD, DOE, DOJ, HHS, and the 

National Security Council Staff for their review and comment. DHS 

provided written comments, which are reproduced in appendix VI. DOD, 

DOE, DOJ, HHS, and the National Security Staff did not provide written 

comments. In its comments, DHS concurred with our three

recommendations for the department and described actions under way or 

planned to address them by June 30, 2015. In its overall comments, DHS 

stated that FEMA recognizes the need to continue to improve national 

capabilities to respond to disasters, including through implementation of 

the recommendations raised in this report. DHS, DOD, DOE, DOJ, and 

HHS also provided technical comments, which we incorporated as 

appropriate.

With regard to our first recommendation, for FEMA to issue supplemental 

guidance to ESF coordinators that details minimum standards for 

activities and product deliverables necessary to demonstrate ESF 

preparedness, DHS concurred. DHS stated that FEMA—in coordination 

and collaboration with other federal departments and agencies through 

the ESF Leadership Group—will issue the recommended supplemental 

guidance to ESF coordinators to enhance interagency coordination. DHS 

provided an estimated completion date of June 30, 2015 for issuance of 

the supplemental guidance. This action, if fully implemented, should 

address the intent of the recommendation.

With regard to our second recommendation, for FEMA to collect 

information on and regularly report to the Secretary of Homeland Security 

the status of federal interagency implementation of corrective actions 

identified (1) through prior national-level exercises and (2) following realworld incidents, specifically major disasters, DHS concurred. DHS stated 

that FEMA recognizes the need to better position the Secretary to 

comprehensively monitor the status of national preparedness through 

regular reporting on the implementation of outstanding corrective actions 

across the federal interagency. In response to technical comments 

received from FEMA regarding their concern that the original wording of 

our draft recommendation could potentially have been perceived to imply 

that FEMA had the statutory authority to compel other federal 

departments and agencies to provide such information, we modified the 

recommendation’s phrasing. Our revision was designed to make clear 

that such information collection is a shared responsibility between FEMA 

and other departments and agencies and that coordination and 

collaboration among all stakeholders is required to achieve the 

recommendation’s intent. DHS provided an estimated completion date of 

June 30, 2015 for issuance of the initial corrective action status report to 

the Secretary of Homeland Security, a report that is to be issued quarterly 

Agency Comments 

and Our Evaluation
 

Page 41 GAO-15-20 Emergency Preparedness

thereafter. This action, if fully implemented, should address the intent of 

the recommendation.

With regard to our third recommendation, for FEMA to develop detailed 

program management information—consistent with leading practices 

discussed in this report—for federal interagency closure of the capability 

gaps identified in the DHS IND Strategy, DHS concurred. DHS stated that 

FEMA has begun developing a detailed program management 

information system for tracking the closure of capability gaps indentified in 

the DHS IND Strategy. This system is to include detailed estimates of 

completion dates for initiated activities, interim timeframes and milestones 

for monitoring progress, and identification of necessary funding and 

resource requirements. DHS also noted that while FEMA is unable to 

compel other federal departments or agencies to participate in such 

efforts or provide FEMA with requested information, FEMA will continue 

to coordinate and collaborate with other involved federal entities in order 

to monitor closure of the capability gaps identified in the DHS IND 

Strategy. DHS provided an estimated completion date of April 30, 2015 

for finalization of the detailed program management information system. 

This action, if fully implemented, should address the intent of the 

recommendation.

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

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

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

congressional committees, the Secretaries of Homeland Security, 

Defense, Energy, Health and Human Services, and the Attorney General

of the United States. In addition, the report will be available at no charge 

on the GAO website at http://www.gao.gov. 

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

me at (404) 679-1875 or at CurrieC@gao.gov. Contact points for our 

Office of Congressional Relations and Office of Public Affairs can be 

found on the last page of this report. Other major contributors to this 

report are listed in appendix VII. 

Chris P. Currie

Director

Homeland Security and Justice
 

Page 42 GAO-15-20 Emergency Preparedness

List of Requesters

The Honorable Thomas R. Carper

Chairman

The Honorable Tom Coburn, M.D.

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Mark Begich

Chairman

Subcommittee on Emergency Management, Intergovernmental Relations, 

and the District of Columbia

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Michael T. McCaul

Chairman

Committee on Homeland Security

House of Representatives

The Honorable Robert P. Casey, Jr.

United States Senate

The Honorable Susan M. Collins

United States Senate
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-15-20 Emergency Preparedness

GAO was asked to review federal preparedness to respond to no-notice 

catastrophic incidents. This report assesses the extent to which 

opportunities exist, if any, to enhance

1. the assessment of National Response Framework (NRF) emergency 

support function (ESF) preparedness, and

2. management oversight of the status of implementation of federal 

capability gaps identified in national-level exercises, real-world 

incidents, and other gap assessments.

Incident type: Because there are many types of no-notice catastrophic 

incidents to which the federal government would respond, we selected 

two scenarios for the scope of our review: one scenario that is manmade—improvised nuclear device (IND) attacks—and one scenario that 

is naturally occurring—major earthquakes. We selected these scenarios 

because they represent the two key scenarios the Federal Emergency 

Management Agency (FEMA) uses to plan for no-notice catastrophic 

incidents.1 This review does not address the efforts of federal agencies to 

ensure their own organization’s continuity of operations, which includes 

planning to ensure that that essential government services are not 

interrupted during and after emergencies.2

Departments and components: Our review covered five federal 

departments—the Departments of Defense (DOD), Energy (DOE), Health 

and Human Services (HHS), Homeland Security (DHS), and Justice 

(DOJ). We selected these departments because they represent the key 

federal departments with responsibilities for responding to IND attacks 

and major earthquakes as described in the National Response 

Framework and its annexes. Further, these departments also served as 

coordinators for 1 or more of the 14 ESFs and participated in national-

 

1

For the purposes of planning for catastrophic incidents, such as when developing the 

Federal Interagency Operational Plan for Response, FEMA officials stated that they use 

three major types of disasters to develop planning factors. Two of these events—an IND 

attack and a major earthquake—are no-notice, while the third—a Category 5 hurricane—is 

an event with notice. All three events are based on scenarios described in the April 2005 

National Planning Scenarios, which were created for use in national, federal, state, and 

local preparedness activities. 

2

For a prior GAO report on this topic, see Continuity of Operations: Selected Agencies 

Tested Various Capabilities during 2006 Governmentwide Exercise, GAO-08-185 (Nov. 

19, 2007). 

Appendix I: Objectives, Scope, and 

Methodology

Objectives

Scope
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-15-20 Emergency Preparedness

level exercises (NLE) and other interagency capability gap assessments 

in the scope of our review.3

Table 5: Departments and Key Components in GAO’s Review

Within these five departments, we collected 

documentation and interviewed officials from various components that 

departmental officials identified as playing a key role at the department for 

responding to IND attacks and major earthquakes. These key 

components are summarized in table 5.

Department Components in GAO’s review

Summary of role for responding to improvised nuclear device (IND) 

attacks and major earthquakes

Defense (DOD) U.S. Northern Command 

(NORTHCOM)

NORTHCOM was established in October 2002 to provide command and 

control of DOD’s homeland defense efforts and to coordinate defense 

support of civil authorities in the continental United States and Alaska. 

U.S. Army Corps of Engineers 

(USACE) 

USACE is assigned as the coordinating agency for emergency support 

function (ESF) on Public Works and Engineering, which the corps does 

by coordinating federal public works and engineering-related support and 

providing technical assistance, engineering expertise, and construction 

management.

Energy (DOE) Office of Electricity Delivery and

Energy Reliability (OE)

OE leads DOE’s efforts to ensure a resilient, reliable, and flexible 

electricity system. OE accomplishes this mission through research, 

partnerships, modeling, and emergency preparedness. OE is the 

coordinating agency for the ESF on Energy.

National Nuclear Security 

Administration (NNSA)

NNSA would lead the early federal interagency response to characterize 

the nature and dispersal of radioactive material in the event of an IND 

attack.

Health and Human 

Services (HHS)

Office of the Assistant Secretary 

for Preparedness and Response 

(ASPR) 

ASPR serves as the lead HHS office responsible for all federal public 

health and medical response to public health emergencies and incidents 

covered by the National Response Framework. According to agency 

officials, responsibility for coordinating the ESF on Public Health and 

Medical Services has been delegated by HHS to ASPR.

Centers for Disease Control and 

Prevention (CDC)

According to CDC officials, in the event of a major disaster, CDC would

play a key role in deploying response teams and assets from the 

Strategic National Stockpile. The stockpile has large quantities of 

medicine and medical supplies if local supplies run out, including medical 

countermeasures to treat radiation sickness.

 

3

There was originally a 15th ESF on long-term community recovery, which was 

superseded by the issuance of the National Disaster Recovery Framework in September 

2011.
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-15-20 Emergency Preparedness

Homeland Security 

(DHS)

Federal Emergency Management 

Agency (FEMA)

FEMA has responsibility to reduce the loss of life and property and 

protect the nation from all hazards, including IND attacks and major 

earthquakes. FEMA has a leadership role to coordinate the overall 

federal response to these attacks in close coordination with many other 

federal agencies and departments. FEMA is the coordinator for five 

ESFs.

National Protection and 

Programs Directorate (NPPD)

a

NPPD leads the national effort to protect and enhance the resilience of 

the nation’s physical and cyber infrastructure. Further, the Office of 

Cybersecurity and Communications within NPPD is the coordinator for 

the ESF on Communications.

Justice (DOJ) Federal Bureau of Investigation 

(FBI) 

The FBI is the lead federal investigative entity for acts of terrorism, 

including IND attacks. According to FBI officials, while FBI officials may 

be present on scene following an IND attack, their activities would be 

focused on investigating the attack.b

Bureau of Alcohol, Tobacco, 

Firearms and Explosives (ATF)

 

ATF is a federal law enforcement agency responsible for investigating 

federal laws related to firearms, explosives, arson, alcohol, and tobacco. 

Under the National Response Framework, ATF is the coordinator for the 

ESF on Public Safety and Security. 

Source: GAO analysis of DOD, DOE, HHS, DHS, and DOJ documents. | GAO-15-20

a

FEMA is the coordinator for five of the ESFs: Firefighting (coordinated jointly with the Department of 

Agriculture’s U.S. Forest Service); Information and Planning; Mass Care, Emergency Assistance, 

Temporary Housing, and Human Services; Logistics (coordinated jointly with the General Services 

Administration); and Search and Rescue.

b

FBI officials also noted that the FBI does not have consequence management responsibilities under 

the National Preparedness Goal’s response mission area, but the agency does have responsibilities 

within the prevention mission area. The FBI leads and coordinates on-scene law enforcement and 

associated investigative and intelligence activities related to potential imminent terrorist threats, 

according to officials.

We reviewed relevant laws and presidential directives, such as the 

Homeland Security Act of 2002, the Post-Katrina Emergency 

Management Reform Act of 2006 (Post-Katrina Act), and Presidential 

Policy Directive 8 on National Preparedness. We also reviewed relevant 

all-hazards and incident-specific interagency strategies and plans, 

including: the NRF and its annexes on ESFs, catastrophic incidents, and 

nuclear incidents; the Response Federal Interagency Operational Plan 

that supports the NRF; and the DHS Strategy for Improving the National 

Response and Recovery from an IND Attack (DHS IND Strategy). We 

also reviewed relevant assessments of federal preparedness, including 

the 2013 and 2014 National Preparedness Reports and the October 2013 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-15-20 Emergency Preparedness

Emergency Support Function Report.

4

To identify opportunities to enhance the assessment of ESF 

preparedness, we gathered information and documentation from agency 

officials for the 10 ESFs that were coordinated by one of the departments 

in our review. The 10 ESFs within the scope of our review are identified in 

table 6. Specifically, we gathered information and supporting 

documentation from these ESFs on the coordination, planning, and 

capability assessment activities they are conducting to oversee the 

preparedness of their ESFs. We requested information on these types of 

activities because such activities are consistent with the NRF’s 

description of ESF coordinator responsibilities and the National 

Preparedness Goal’s description of the planning response core capability. 

We also compared FEMA’s current efforts to assess the activities of the 

ESF coordinators against descriptions of roles and responsibilities in the 

NRF and requirements in the Post-Katrina Act, as well as against 

standards in Standards for Internal Control in the Federal Government 

and leading practices for federal interagency coordination and 

collaboration we have identified in our prior work.

Further, we interviewed 

department and component officials on their responsibilities for 

responding to IND attacks and major earthquakes, as well as FEMA 

officials on their agency’s management oversight of ESFs and the closure 

of federal capability gaps identified in national-level exercises, real-world 

incidents, and other gap assessments.

5

 

4

For example, see Department of Homeland Security, National Preparedness Report

(Washington, D.C.: Mar. 30, 2014). See also FEMA, Emergency Support Function: Fiscal 

Year 2008 Report to Congress (Washington, D.C.: Oct. 24, 2013). According to this 

report, the document was compiled pursuant to a requirement in the Joint Explanatory 

Statement and Senate Report 110-84 that accompany the FY 2008 DHS Appropriations 

Act (P.L. 110-161). 

5

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

(Washington, D.C.: Nov. 1, 1999); Results-Oriented Government: Practices That Can Help 

Enhance and Sustain Collaboration among Federal Agencies, GAO-06-15 (Washington, 

D.C.: Oct. 21, 2005); and Catastrophic Disasters: Enhanced Leadership, Capabilities, and 

Accountability Controls Will Improve the Effectiveness of the Nation’s Preparedness, 

Response, and Recovery System, GAO-06-618 (Washington, D.C.: Sep. 6, 2006).
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-15-20 Emergency Preparedness

Table 6: List of Emergency Support Functions (ESF) and their Assigned Coordinators

ESF ESF coordinator(s) Reviewed by GAO

Transportation

(ESF #1)

• Department of Transportation

Communications

(ESF #2)

• Department of Homeland Security (DHS)/National Protection 

and Programs Directorate/Cybersecurity and Communications

X 

Public Works and Engineering

(ESF #3)

• Department of Defense/U.S. Army Corps of Engineers X 

Firefighting

(ESF #4)

• Department of Agriculture/U.S. Forest Service

• DHS/Federal Emergency Management Agency (FEMA)/U.S. 

Fire Administrationa

Information and Planning

(ESF #5)

• DHS/FEMA X 

Mass Care, Emergency Assistance, 

Temporary Housing, and Human Services

(ESF #6)

• DHS/FEMA X 

Logistics

(ESF #7)

• General Services Administration

• DHS/FEMA

X 

Public Health and Medical Services

(ESF #8)

• Department of Health and Human Services X 

Search and Rescue (ESF #9) • DHS/FEMA X 

Oil and Hazardous Materials Response 

(ESF #10)

• Environmental Protection Agency

Agriculture and Natural Resources

(ESF #11)

• Department of Agriculture

Energy

(ESF #12)

• Department of Energy X 

Public Safety and Security

(ESF #13)

• Department of Justice/Bureau of Alcohol, Tobacco, Firearms, 

and Explosives

X 

Long-Term Community Recovery

(ESF #14)

• Not applicable—superseded by the National Disaster 

Recovery Framework

External Affairs

(ESF #15)

• DHS X 

Source: GAO analysis of the National Response Framework. | GAO-15-20

a

The Firefighting ESF is jointly coordinated by the Department of Agriculture’s Forest Service and 

FEMA’s Fire Administration. However, FEMA officials stated that FEMA’s role is limited to 

coordinating with state, territorial, tribal, and insular agencies and local fire departments specifically to 

expand their firefighting capacity; in contrast, the Forest Service coordinates with all stakeholders—

including federal departments and agencies—on issues related to all aspects of fire response 

activities and represents ESF #4 on the ESF Leadership Group. Therefore, because the Department 

of Agriculture was not within the scope of our review, the Firefighting ESF was likewise not selected 

for review.
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-15-20 Emergency Preparedness

To identify opportunities to enhance management oversight of the closure 

of federal capability gaps, we identified and reviewed reports related to 

relevant national-level exercises, real-world incidents, and other 

assessments based on the scope of our review. For NLEs, we selected 

NLE 2010 and NLE 2011 for review because these exercises represent 

the only two NLEs conducted since the development of the National 

Exercise Program in 2007 that assessed federal preparedness to respond 

to an IND attack or a major earthquake.6 NLE 2010 was a 2-day 

operations-based exercise conducted in May 2010 that concentrated on 

response and recovery from an IND attack in the United States. NLE 

2011 was a 4-day functional exercise conducted in May 2011 that 

concentrated on response to a major earthquake in the New Madrid 

Seismic Zone—a major fault line impacting eight states in the southern 

and midwestern United States. For real-world incidents, we selected the 

federal response to Hurricane Sandy in autumn 2012 for review because 

the incident represented the most recent large-scale disaster that 

involved all five departments within the scope of our review.7

To determine the status of corrective actions from NLE 2010, NLE 2011, 

and Hurricane Sandy, we reviewed interagency and departmental afteraction reports, improvement plans, and other documents that identified 

and provided status updates on corrective actions for the five 

While 

Hurricane Sandy was a disaster with advance notice (unlike IND attacks 

or earthquakes), we believe that it provides valuable insights and lessons 

learned to improve federal response to other major disasters, including 

catastrophic incidents.

 

6

In March 2014, FEMA conducted an NLE (now replaced by the term “capstone exercise”) 

on a simulated catastrophic earthquake in Alaska. However, because evaluation of this

exercise to identify needed corrective actions was ongoing at the time of our review, we 

did not include this exercise within the scope of our review. According to FEMA officials, 

an after-action report on the exercise is expected to be published in autumn 2014. 

7

We also considered the March 2011 earthquake and resulting tsunami and partial nuclear 

meltdown in Fukushima, Japan as another potential real-world incident that identified 

federal capability gaps. However, on the basis of our review of relevant after-action 

reports and interviews with agency officials, we determined that the gaps identified from 

this incident were largely focused on areas outside the scope of this review, such as 

nuclear power plant safety. 
Appendix I: Objectives, Scope, and 

Methodology

Page 49 GAO-15-20 Emergency Preparedness

departments in our review.8 To assess the reliability of this information, 

we interviewed and gathered information from agency officials 

knowledgeable about how information on the status of corrective actions 

from NLEs and real-world incidents is tracked within their department or 

component. Further, where applicable, we reviewed documentation and 

procedures related to databases that store information on the status of 

corrective actions at the departments in our review, such as the 

Corrective Action Program System (CAPS) database—in which FEMA 

catalogs and tracks the status of corrective actions from NLEs for DHS—

and DOD’s Joint Lesson Learned Information System. Although we did 

not independently verify the accuracy of the recorded status of 

implementation of corrective actions, we found the information we 

gathered reliable for the purpose of describing the status of corrective 

actions from NLEs and real-world incidents as reported by the five 

departments in our review.9

To identify other capability gap assessments relevant to federal response 

to IND attacks and major earthquakes, we interviewed officials from the 

five departments within the scope of our review to gather information on 

the extent to which such assessments had been conducted. Through this 

effort, we identified one capability gap assessment for responding to IND 

attacks. Specifically, we reviewed the April 2010 DHS IND Strategy, 

which identifies qualitative capability gaps for responding to an IND 

 

8

While the interagency after-action report for NLE 2010 identified corrective actions for all 

departments and agencies that participated in the exercise, the interagency after-action 

report for NLE 2011 highlighted areas for improvement and each department and agency 

that participated in the exercise was to develop its own corrective actions. Therefore, we 

identified corrective actions from NLE 2011 by obtaining from the departments in our 

review copies of departmental after-action reports and other documentation that identified 

these actions. 

9

A closed corrective action includes actions that have been implemented, actions that are 

no longer applicable, and actions the department declined to implement for other reasons. 

For example, one of the corrective actions from NLE 2010 was for FEMA to prepare a 

matrix to determine the benefits, risks, and consequences of changing the Homeland 

Security Advisory System level following an IND detonation in a major metropolitan area. 

The action became obsolete after the National Terrorism Advisory System replaced the 

Homeland Security Advisory System. While FEMA officials provided some examples of 

corrective actions being closed in the manner described above, data fields in CAPS in 

which correction action officers are to describe why an action was closed did not

consistently contain detailed enough information for GAO to determine if the action was 

closed because action was taken or for another reason. 
Appendix I: Objectives, Scope, and 

Methodology

Page 50 GAO-15-20 Emergency Preparedness

attack.10

Finally, we compared FEMA’s current management oversight efforts 

related to closure of capability gaps identified in NLEs, real-world 

incidents, and other gap assessments against descriptions of roles and 

responsibilities in the NRF and requirements in the Post-Katrina Act, as 

well as against leading practices for internal control and program 

management, specifically Standards for Internal Control in the Federal 

Government and The Standard for Program Management.

We also reviewed the March 2012 and September 2013 

iterations of the IND Response and Recovery Capability-Based 

Implementation Plan (IND Implementation Plan), which describe 

corrective actions to address IND response capability gaps identified in 

the DHS IND Strategy, as well as the status of progress made to close 

the identified gaps. To assess the reliability of information on progress 

made to address IND capability gaps as reported in the IND 

Implementation Plan, we interviewed and gathered information from 

officials in FEMA’s Chemical, Biological, Radiological, Nuclear, and 

Explosives Office who are responsible for management oversight of 

efforts to close these gaps and coordinating the five interagency working 

groups that help develop and implement the corrective actions. Although 

we did not independently verify the accuracy of the recorded status of 

implementation of the actions, we found the information we gathered 

reliable for the purpose of describing the progress made toward 

addressing the identified capability gaps.

11

We conducted this performance audit from September 2013 to December

2014 in accordance with generally accepted government auditing 

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

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

 

10Officials at the five departments within the scope of our review did not identify any gap 

assessments, similar to the DHS IND Strategy, that had been conducted relevant to 

federal response to major earthquakes.

11GAO/AIMD-00-21.3.1 and Project Management Institute, The Standard for Program 

Management, third edition (Newton Square, Pa.: 2013). 
Appendix II: Examples of Coordination 

Activities, Planning Documents, and Capability 

Assessments Identified by National Response 

Framework (NRF) Emergency Support 

Function (ESF) Coordinators

Page 51 GAO-15-20 Emergency Preparedness

ESF coordinators within the scope of this review provided GAO the 

following examples, among others, on

• their coordination activities with their ESF primary and support 

agencies,

• planning documents they have developed for the coordination and 

execution of their ESF’s mission, and

• assessments of currently available ESF resources against ESF 

capability requirements to identify related capability gaps.1

ESF #2 Communications–Department of Homeland Security 

(DHS)/National Communication System

Coordination Activities:

• weekly conference calls

• annual exercise

Planning Documents:

• concept of operations describing the ESF’s mission, key concepts, 

organization and staffing, roles, and operations and support concepts2

 

1

The NRF is a guide to how the nation responds to disasters and emergencies of all types 

and describes the principles, roles and responsibilities, and coordinating structures for 

delivering the core capabilities required to save lives, protect property and the 

environment, restore communities, and meet basic human needs following an incident.

The framework includes various annexes, including on ESFs, the federal government’s 

primary coordinating structure for building, sustaining, and delivering response core 

capabilities. Organized by specific functional areas most frequently needed in a national 

response, ESFs are designed to bring together the capabilities of various federal 

departments and agencies. 

2

Department of Homeland Security, Emergency Support Function #2 Communications: 

Concept of Operations (Washington, D.C.: Feb. 29, 2012).

Appendix II: Examples of Coordination Activities, 

Planning Documents, and Capability 

Assessments Identified by National Response 

Framework (NRF) Emergency Support Function 

(ESF) Coordinators
Appendix II: Examples of Coordination 

Activities, Planning Documents, and Capability 

Assessments Identified by National Response 

Framework (NRF) Emergency Support 

Function (ESF) Coordinators

Page 52 GAO-15-20 Emergency Preparedness

Capabilities Assessments:

• capability requirements not developed for ESF #2

• catalog of currently available capabilities not developed

• capability gap analyses include an analysis of likely communications 

shortfalls during an improvised nuclear device (IND) attack or major 

earthquake, but this analysis does not analyze gaps between 

available capabilities and required capabilities before an incident

ESF #3 Public Works and Engineering–Department of Defense 

(DOD)/U.S. Army Corps of Engineers

Coordination Activities:

• annual seminars

• workshops following major disasters or other incidents to identify 

lessons learned

Planning Documents:

• operational orders and plans for all-hazards incidents

• operational plans for specific earthquake scenarios

• standard operating procedures for response teams3

Capability Assessments:

• quantified ESF #3 capability requirements specific to the U.S. Army 

Corps of Engineers

 

3

For example, U.S. Army Corps of Engineers, Operation Order 2014-11,U.S. Army Corps 

of Engineers Response to All Hazards Events (Washington, D.C: May 30, 2014); Pacific 

Ocean Division Operation Order 13-02, All Hazards Regional Readiness and Contingency 

Response Operations Plan (Fort Shafter, Hawaii: Jan. 10, 2014); Operations Plan 2010-

70, U.S. Army Corps of Engineers Response to a Catastrophic Earthquake in the New 

Madrid Seismic Zone (Washington, D.C.: Dec. 21, 2010); Operations Plan 2014-16, U.S. 

Army Corps of Engineers Response to an Earthquake in the Cascadia Subduction Zone

(Washington, D.C.: Feb. 26, 2014); and U.S. Army Corps of Engineers Planning and 

Response Team: Infrastructure Assessment Standard Operating Procedures

(Washington, D.C.: Mar. 2012). 
Appendix II: Examples of Coordination 

Activities, Planning Documents, and Capability 

Assessments Identified by National Response 

Framework (NRF) Emergency Support 

Function (ESF) Coordinators

Page 53 GAO-15-20 Emergency Preparedness

• quantified available capabilities—such as the number and type of 

emergency response teams—specific to the U.S. Army Corps of 

Engineers

• capability gaps identified and prioritized for closure, through 

workshops identified above, specific to the U.S. Army Corps of 

Engineers

ESF #5 Information and Planning–DHS/Federal Emergency 

Management Agency (FEMA)

Coordination Activities:

• drill, working group meeting, and other exercises

Planning Documents:

• FEMA national and regional incident support manuals, which describe 

how FEMA national and regional staff—through the National 

Response Coordinating Center and Regional Response Coordinating 

Centers—support FEMA incident operations4

Capability Assessments:

• qualitative capability requirements identified by reference to relevant 

core capabilities required by the National Preparedness Goal5

• qualitative available capabilities cataloged as outlined in the ESF #5 

annex to the NRF6

• capability gap analysis for ESF #5 under development, according to 

FEMA officials

 

4

Federal Emergency Management Agency, National Incident Support Manual, Change 1 

(Washington, D.C.: January 2013); Regional Incident Support Manual (Washington D.C.: 

January 2013).

5

Department of Homeland Security, National Preparedness Goal, first edition

(Washington, D.C.: September 2011). 

6

Department of Homeland Security, National Response Framework, Emergency Support 

Function #5 Information and Planning Annex (Washington D.C.: May 2013). 
Appendix II: Examples of Coordination 

Activities, Planning Documents, and Capability 

Assessments Identified by National Response 

Framework (NRF) Emergency Support 

Function (ESF) Coordinators

Page 54 GAO-15-20 Emergency Preparedness

ESF #6 Mass Care, Emergency Assistance, Temporary Housing, 

Human Services–DHS/FEMA

Coordination Activities:

• conference calls

• webinars and training courses for mass care and emergency 

assistance practitioners

• annual mass care exercise

• national conferences

Planning Documents:

• appendix to the NRF’s Response Federal Interagency Operational 

Plan describing the delivery of mass care services such as hydration, 

feeding, and sheltering, as well as support for reunifying families7

Capability Assessments:

• established quantified capability requirements, such as sheltering and 

feeding requirements, for primary and support agencies8

• identified primary and support agencies’ available capabilities related 

to, for example, providing sheltering, feeding, and other services

• in April 2014, assessed whether these currently available capabilities 

were sufficient to be considered “mission ready” 

ESF #7 Logistics–DHS/FEMA

Coordination Activities:

• biweekly conference calls

 

7

Department of Homeland Security, Response Federal Interagency Operational Plan 

(Washington, D.C.: July 2014). 

8

ESF #6 developed guidance that includes planning factors for its primary and support 

agencies to determine what types of capabilities—for example, what percentage of the 

population will seek emergency shelter inside an affected geographic area—are required 

to execute the ESF #6 mission after an incident. This guidance identifies an ESF #6 

“service provider” to deliver each required capability; for example, DOD’s Defense 

Logistics Agency is responsible for providing tents, camping kits, equipment, and supplies.
Appendix II: Examples of Coordination 

Activities, Planning Documents, and Capability 

Assessments Identified by National Response 

Framework (NRF) Emergency Support 

Function (ESF) Coordinators

Page 55 GAO-15-20 Emergency Preparedness

• annual summit with ESF partners

• training course on logistics for interagency partners

Planning Documents:

• operations manual to describe how FEMA and its partners are to 

provide logistics support during domestic emergencies9

Capability Assessments:

• identified qualitative capability requirements in an annex to the NRF’s 

Response Federal Interagency Operational Plan

• quantified certain available capabilities at ESF primary and support 

agencies—such as meals and water—in the 10 FEMA regions

• capability gap assessment specific to ESF #7 not yet performed

ESF #8 Public Health and Medical Services–Department of Health 

and Human Services

Coordination Activities:

• does not conduct ESF-specific preparedness coordination because of 

a lack of funding, according to HHS officials

• does coordinate with its ESF primary and support agencies during 

FEMA- and state-sponsored preparedness activities

Planning Documents:

• draft plan for all-hazards response

• draft annexes for IND attacks and earthquake response

• concepts of operations for medical response teams10

 

9

Federal Emergency Management Agency, Logistics Management Operations Manual

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

10For example, Department of Health and Human Services, National Disaster Medical 

System—Disaster Mortuary Operational Response Team Concept of Operations

(Washington, D.C.: May 2012); National Veterinary Response Team Concept of 

Operations (Washington D.C.: November 2011). 
Appendix II: Examples of Coordination 

Activities, Planning Documents, and Capability 

Assessments Identified by National Response 

Framework (NRF) Emergency Support 

Function (ESF) Coordinators

Page 56 GAO-15-20 Emergency Preparedness

Capability Assessments:

• quantified ESF #8-specific capability requirements for primary and 

support agencies for responding to certain incidents—such as an 

earthquake in the New Madrid Seismic Zone and a hurricane in the 

Gulf of Mexico

• catalog of currently available capabilities under development

• assessment of capability gaps under development

ESF #9 Search and Rescue–DHS/FEMA

Coordination Activities:

• nonemergency coordination takes place formally through the National 

Search and Rescue Committee, which meets three or four times 

annually11

Planning Documents:

• concept of operations for the national urban search and rescue 

system 

• field operations guide for the national urban search and rescue 

system12

Capability Assessments:

• capability requirements specific to DHS/FEMA for responding to an 

earthquake in the New Madrid Seismic Zone

• catalog of national search and rescue capabilities not yet developed

 

11The National Search and Rescue Committee was established in 1973 as a standing 

interagency group to oversee the United States National Search and Rescue Plan and to 

act as a coordinating forum for national search and rescue matters. The committee serves 

as the primary coordinating forum within the federal government for the conduct and 

support of civil search and rescue operations covered by the National Search and Rescue 

Plan and for matters relating to national civil search and rescue policies and positions. 

12Federal Emergency Management Agency, Response Concept of Operations Annex to 

the National Urban Search and Rescue Response System Operations Manual

(Washington, D.C.: April 2012); National Urban Search and Rescue Response System 

Field Operations Guide (Washington, D.C.: September 2003).
Appendix II: Examples of Coordination 

Activities, Planning Documents, and Capability 

Assessments Identified by National Response 

Framework (NRF) Emergency Support 

Function (ESF) Coordinators

Page 57 GAO-15-20 Emergency Preparedness

• capability gap analysis for national search and rescue capabilities not 

yet developed

ESF #12 Energy–Department of Energy

Coordination Activities:

• meetings of several energy councils, including the Energy 

Government Coordinating Council, which includes stakeholders from 

all levels of government—federal, state, local, tribal, and territorial—

that are involved with the energy sector

Planning Documents:

• operational plan for emergency response activities related to energy 

disruption

• operations guide for emergency response activities related to energy 

disruption13

Capability Assessments:

• the coordinator stated that it did not have the authority to establish 

capability requirements for ESF #12 primary and support agencies

• ESF #12 support agencies develop their own capability requirements 

based upon their individual missions and statutory authorities, 

according to the coordinator

• qualitative listing of available capabilities for all-hazards response 

listed in the ESF #12 annex to the NRF14

• individual primary and support agencies catalog their own capabilities, 

according to the coordinator

• the coordinator stated that it did not have the authority to conduct a 

capability gap analysis for ESF #12 other than for the Department of 

 

13Department of Energy, Infrastructure Security and Energy Restoration Emergency 

Response Organization Plan, Version 7 (Washington, D.C.: Dec. 6, 2010); Infrastructure 

Security and Energy Restoration Emergency Response Organization Operations Guide 

(Washington, D.C.: October 2012). 

14Department of Homeland Security, National Response Framework, Emergency Support 

Function #12 Energy Annex (Washington, D.C.: May 2013).
Appendix II: Examples of Coordination 

Activities, Planning Documents, and Capability 

Assessments Identified by National Response 

Framework (NRF) Emergency Support 

Function (ESF) Coordinators

Page 58 GAO-15-20 Emergency Preparedness

Energy, and no capability gap assessments have been performed to 

date

ESF #13 Public Safety and Security–Department of Justice 

(DOJ)/Bureau of Alcohol, Tobacco, Firearms and Explosives

Coordination Activities:

• semiannual meetings are held with representatives from over 80 

federal law enforcement departments and agencies

• regular outreach meetings are conducted with individual law 

enforcement and emergency management partners

Planning Documents:

• concept of operations15

Capability Assessments:

• baseline staffing requirement established for components of DOJ

• catalog of capabilities not established

• capability gap assessment conducted specifically for DOJ for ESF #13 

role

ESF #15 External Affairs–DHS

Coordination Activities:

• conference calls prior to hurricane season and other events

• tabletop exercises

Planning Documents:

• standard operating procedures16

 

15Department of Justice, Emergency Support Function #13 National Concept of 

Operations Plan (Washington, D.C.: May 30, 2013). 
Appendix II: Examples of Coordination 

Activities, Planning Documents, and Capability 

Assessments Identified by National Response 

Framework (NRF) Emergency Support 

Function (ESF) Coordinators

Page 59 GAO-15-20 Emergency Preparedness

Capability Assessments:

• qualitative required actions and staffing outlined in ESF #15 planning 

document

• qualitative descriptions of available capabilities identified in 

prescripted mission assignments17

• tabletop exercise used to assess ESF #15 capability gaps

 

16Department of Homeland Security, Emergency Support Function #15: Standard 

Operating Procedures (Washington, D.C.: Aug. 30, 2013). 

17Prescripted mission assignments are draft work orders—established in advance of a 

disaster and then modified to meet the needs of a specific incident—issued by FEMA to 

another federal agency to request disaster response support.
Appendix III: Corrective Actions Not Yet 

Closed for National Level Exercises 2010 and 

2011, as of November 2014

Page 60 GAO-15-20 Emergency Preparedness

This appendix provides additional information on corrective actions 

developed in response to National Level Exercise (NLE) 2010 and NLE 

2011, which tested the nation’s ability to respond to an improvised 

nuclear device (IND) attack and a major earthquake, respectively. The 

Federal Emergency Management Agency’s (FEMA) interagency afteraction report for NLE 2010 identified 104 corrective actions for the 

Departments of Defense, Energy, Health and Human Services, Homeland 

Security, and Justice. According to information provided by officials from 

these departments, 98 of 104 corrective actions have been closed as of 

November 2014.1 For NLE 2011, FEMA’s interagency after-action report 

highlighted areas for improvement—such as the need to increase 

familiarization with earthquake response plans at the state, regional, and 

national levels—for federal departments and agencies to develop their 

own corrective actions in their own after-action reports. The five 

departments in our review identified 75 actions that they had planned to 

take to address the capability gaps identified in the interagency afteraction report. According to information provided by officials from these 

departments, as of November 2014, 73 of 75 corrective actions have 

been closed. The corrective actions that remain open from NLE 2010 and 

NLE 2011, and departmental comments on efforts being taken to address 

these actions, are described in tables 7 and 8.

 

1

For the purposes of this report, closed corrective actions include actions that have been 

implemented, actions that were overtaken by other events and as a result were no longer 

applicable, and actions the department declined to implement for other reasons. For 

example, one of the corrective actions from NLE 2010 was for FEMA to prepare a matrix 

to determine the benefits, risks, and consequences of raising and lowering the Homeland 

Security Advisory System level following an improvised nuclear device attack in a major 

metropolitan area. However, the action became obsolete after the National Terrorism 

Advisory System replaced the Homeland Security Advisory System level, and thus the 

action was closed in the Corrective Action Program System (CAPS) by FEMA officials. 

While FEMA officials provided limited examples of corrective actions being closed in the 

manner described above, CAPS data fields did not consistently contain detailed enough 

information for GAO to determine whether a given corrective action was closed because 

the action had been implemented or whether it was closed for other reasons.

Appendix III: Corrective Actions Not Yet 

Closed for National Level Exercises 2010 

and 2011, as of November 2014
Appendix III: Corrective Actions Not Yet 

Closed for National Level Exercises 2010 and 

2011, as of November 2014

Page 61 GAO-15-20 Emergency Preparedness

Table 7: Corrective Actions Not Yet Closed from National Level Exercise 2010, as of November 2014

Department Open corrective action Departmental comments

Department of 

Defense (DOD)

Review and refine plans and protocols for 

federalizing a state’s National Guard and returning it 

to the state’s command and control under the interim 

Federal Interagency Improvised Nuclear Device 

Concept of Operations Plan

According to DOD officials, there is no formal 

interagency mechanism to address this action and the 

department has not acted on the issue to date. 

a

DOD Establish and maintain programs to familiarize 

national leaders and response planners with tailored 

defense support for civil authorities military 

capabilities and the unique circumstances that would 

require their urgent deployment and response

According to DOD officials, there is no formal 

interagency mechanism to address this action and the 

department has not acted on this issue to date.

Department of 

Homeland Security 

(DHS)

Federal Emergency 

Management Agency 

(FEMA) 

Develop and improve appropriate plans and 

protocols to ensure timely access to U.S. and state 

courts during a catastrophic incident

According to FEMA officials, the scale and complexity 

of this corrective action resulted in the issue being 

elevated from FEMA’s Response and Recovery 

Directorate to FEMA’s Continuous Improvement 

Working Group for consideration.b

DHS

The group assigned 

the corrective action to FEMA’s Office of the Chief 

Counsel, which was reviewing related requirements for 

implementation of the action at the time of our review. 

FEMA 

Identify the relevant federal and state permitting and 

approval authorities necessary in a postcatastrophic 

incident restoration scenario and coordinate with 

those authorities to develop plans to expeditiously 

address permitting requirements for infrastructure 

restoration in accordance with applicable statutes 

and regulations

According to FEMA officials, the scale and complexity 

of this corrective action resulted in the issue being 

elevated from FEMA’s Response and Recovery 

Directorate to FEMA’s Continuous Improvement 

Working Group for consideration. The group assigned 

the corrective action to FEMA’s Office of the Chief 

Counsel, which was reviewing related requirements for 

implementation of the action at the time of our review. 

DHS

National Protection 

Programs Directorate 

(NPPD) 

Examine methods to enhance interoperable 

communications with fire departments

According to DHS officials, NPPD’s Office of 

Emergency Communications continues to engage 

state and local stakeholders to ensure interoperable 

emergency communications are addressed through 

the DHS National Emergency Communications Plan. 

DHS

Office of Policy

Determine ways to encourage design measures for 

resiliency in postincident construction and repairs

According to DHS officials, the department completed 

a related resiliency pilot project and was drafting the 

associated after-action report, as of September 2014. 

Upon completing this after action report, the officials 

stated that they intended to close the action. 

Source: GAO analysis of DOD and DHS documents. | GAO-15-20

Notes: The list of not yet closed corrective actions does not include those actions assigned to the 

White House or to federal departments outside of the scope of our review. Departments use varying 

terminology to describe the actions designed to address issues identified through national-level 

exercises. For example, DHS and FEMA refer to these actions as corrective actions, while DOD 

refers to these actions as recommendations. For the purposes of this report, we refer such actions 

collectively as corrective actions.

a

The interim Improvised Nuclear Device Concept of Operations Plan was a plan developed in 

response to Homeland Security Presidential Directive-8, Annex I.

b

FEMA’s Lessons Learned/Continuous Improvement Program identifies issues or capability gaps 

from training, exercises, real-world events, readiness assessments, or steady-state operations and 

resolves these issues through the implementation of corrective actions. Those actions that are 

beyond the resolution capability of FEMA components or are of significant interest to FEMA 
Appendix III: Corrective Actions Not Yet 

Closed for National Level Exercises 2010 and 

2011, as of November 2014

Page 62 GAO-15-20 Emergency Preparedness

leadership are elevated to FEMA’s Continuous Improvement Working Group, which is responsible for 

developing, assigning, and tracking such actions across the agency.

Table 8: Corrective Actions Not Yet Closed from National Level Exercise 2011, as of November 2014

Department Open corrective action Departmental comments

Department of Defense 

(DOD)

Develop a common operating picture tool to reside 

on the nonclassified Internet network portal 

This action has evolved into two related efforts—

information sharing via the Situational Awareness 

Geospatial Enterprisea 

DOD

and operationalizing it for 

conducting assessments and providing decision 

support, both of which are being reviewed by DOD’s 

Corrective Action Program Working Group.

Establish a collaboration forum of interagency 

partners 

This issue is being reviewed by the U.S. Northern 

Command to determine an approach for resolution. 

Source: GAO analysis of DOD and HHS documents. | GAO-15-20

Notes: Departments use varying terminology to describe the actions designed to address issues 

identified through national-level exercises. For example, DHS and the Federal Emergency 

Management Agency refer to these actions as corrective actions, while DOD refers to these actions 

as recommendations. For the purposes of this report, we refer to such actions collectively as 

corrective actions.

a

The Situational Awareness Geospatial Enterprise system is a technological tool that provides the 

U.S. Northern Command and other DOD components with rapid, easy access to detailed physical 

infrastructure data for a given geographical area.
Appendix IV: Corrective Actions Developed 

after Hurricane Sandy Not Yet Closed, as of 

November 2014

Page 63 GAO-15-20 Emergency Preparedness

Following the federal response to Hurricane Sandy in autumn 2012, the 

Departments of Defense, Energy, Health and Human Services, Homeland 

Security, and Justice developed intradepartmental after-action reports 

that identified capability gaps and associated corrective actions. 

According to information provided by officials from these departments, 

102 corrective actions were developed across the five departments, and 

63 of the 102 actions have been closed as of November 2014.1

Table 9: Corrective Actions Developed after Hurricane Sandy Not Yet Closed, as of November 2014

The 

remaining open corrective actions, and efforts being taken to address 

these actions, are described in table 9.

Department Corrective action Departmental comments

Department of Defense 

(DOD)

Northern Command 

(NORTHCOM)

Better utilize the role of the U.S. Marine 

Corps Service Emergency Preparedness 

Liaison Officer

According to DOD officials, a subject matter expert has 

addressed this issue and is awaiting a “confirming 

event” before the action will be considered closed. 

DOD

a

NORTHCOM

Improve access to Reserve Component 

forces

According to DOD officials, a subject matter expert has 

addressed this issue, and is awaiting a “confirming 

event” a before the action will be considered closed. 

Department of Energy 

(DOE)

Leverage technology to improve response 

and communications. b According to DOE officials, the department is 

addressing this action through the use of Environment 

for Analysis of Geo-Located Energy Information, a 

system that allows DOE staff to geospatially map 

energy assets and systems and tie together a variety of 

data sources into one visualization platform. 

 

1

Corrective actions are the concrete, actionable steps assigned to responsible entities that 

are intended to resolve gaps and shortcomings experienced during exercises and realworld incidents. Federal departments and agencies use varying terminology—e.g., 

recommended actions, recommended courses of action, etc.—to describe the actions 

developed to address such gaps. For the purposes of this report, we refer to such actions 

collectively as corrective actions. 

Appendix IV: Corrective Actions Developed 

after Hurricane Sandy Not Yet Closed, as of 

November 2014
Appendix IV: Corrective Actions Developed 

after Hurricane Sandy Not Yet Closed, as of 

November 2014

Page 64 GAO-15-20 Emergency Preparedness

DOE Develop a better understanding of how DOE 

can use the Defense Production Act, 

including to obtain critical supplies, and 

determine what advantages and 

disadvantages exist for energy sector 

partners when the act is used.

According to DOE officials, the department last used the 

act for an energy-related emergency during the Clinton 

administration, although the act has been discussed 

with energy sector entities more recently. Other 

agencies, including DOD and the Federal Emergency 

Management Agency (FEMA), routinely use the act as 

part of their standard operating procedures and in 

fulfillment of their mission but it is an authority that can 

be perceived as controversial. Its use for an energy 

emergency by DOE’s Office of Electricity Delivery and 

Energy Reliability requires concurrence by the DOE 

General Counsel and in some circumstances the 

Secretary of Commerce. As part of the effort to address 

this action, DOE held an in-depth training session on 

the act in July 2014 for sector and interagency partners.

Department of Health and 

Human Services (HHS)

Establish a policy on the approved uses of 

mobile devices/phones during a deployment

According to HHS officials, the department is 

developing new and assessing the applicability of 

existing guidance. 

HHS Establish a policy on the use of all forms of 

social media

According to HHS officials, the department is 

developing new and assessing the applicability of 

existing guidance. 

HHS Improve the integration of planning and 

response activities

According to HHS officials, the department is 

conducting a strategic review of existing planning 

functions as well as response requirements. 

HHS Review the requirements and procedures 

for convening the Disaster Leadership 

Group

According to HHS officials, the department is reviewing 

standard operating procedures.

HHS Create a single national health and medical 

common operating picture system

According to HHS officials, the department is reviewing 

standard operating procedures, terminology, and 

existing guidelines. 

HHS Establish a comprehensive list of pertinent 

participants for all coordinating meetings

According to HHS officials, the department is reviewing 

policies and standard operating procedures. 

HHS Establish a training program to ensure 

personnel are aware of roles and 

responsibilities within the Incident 

Command System c

According to HHS officials, the department is 

standardizing trainings, terminology, and guidance. 

HHS Establish a fixed mobilization location to 

support deployment and ensure all 

personnel are familiar with policies

According to HHS officials, the department is reviewing 

the existing concept of operations and supporting 

policies. 

HHS Develop consistent procedures to support 

accountability of resources for response and 

recovery personal

According to HHS officials, the department is 

developing policies and guidance. 

HHS Standardize systems to support staff 

deployment including travel, billing, and 

deployment

According to HHS officials, the department is reviewing 

terminology, procedures, and current systems.

HHS Establish a consistent format for reporting 

information to senior departmental 

leadership

According to HHS officials, the department is 

establishing a template for reports and briefings. 

HHS Enhance trainings to support greater 

familiarity with communication capabilities

According to HHS officials, trainings are ongoing.
Appendix IV: Corrective Actions Developed 

after Hurricane Sandy Not Yet Closed, as of 

November 2014

Page 65 GAO-15-20 Emergency Preparedness

HHS Investigate alternative methods and 

procedures to capture patients within the 

Electronic Medical Record system

According to HHS officials, the department is reviewing 

the current system, capabilities, standard operating 

procedures, and alternative data collection methods. 

HHS Establish an Electronic Medical Records 

system training program for staff, including 

hands-on practice and instruction

According to HHS officials, trainings are ongoing. 

HHS Define “patient encounter” and ensure 

consistency across missions and disasters

According to HHS officials, the department is revising 

terminology and standard operating procedures. 

HHS Ensure responders suffering from severe 

mental health issues in theater receive 

priority care

According to HHS officials, the department is revising 

standard operating procedures, position descriptions, 

and supporting medical screening policies and 

procedures. 

HHS Develop procedures to support 

predeploying teams when possible (e.g. 

before hurricanes make landfall, major 

snowstorms, etc.)

According to HHS officials, the department is reviewing 

and revising the standard operating procedures. 

HHS Develop a memorandum of understanding 

with the Office of the Inspector General, and 

Bureau of Alcohol, Tobacco, Firearms and 

Explosives (ATF) to resolve gaps in force 

protection

According to HHS officials, discussions are ongoing with 

the Office of the Inspector General, ATF, and the HHS 

Office of the Assistant Secretary for Preparedness and 

Response.

HHS Establish procedures to ensure adequate 

transportation, transfer, and care of patients 

is provided

According to HHS officials, trainings are ongoing.

HHS Develop operational policies to formalize 

positions with the Emergency Management 

Group to ensure the Incident Response 

Command Team is positioned to issue 

decisions based on ground truth

According to HHS officials, the department is finalizing a 

document that will identify formal Emergency 

Management Group positions and the roles, 

responsibilities, and authorities for each. 

HHS Utilize the mobilization processing concept 

of operations to ensure team members have 

essential tools before deployment

According to HHS officials, the mobilization processing 

document is in the final stages of approval for 

implementation. However, HHS officials noted that 

mobilization processing has been successfully utilized 

for events and responses since Hurricane Sandy. 

HHS Enhance coordination and communication 

to support deployed officers for the Division 

of Commissioned Corps Personnel and 

Readiness

According to HHS officials, the Office of the Assistant 

Secretary for Preparedness and Response does not 

have the ability to monitor Commissioned Corps 

Personnel and Readiness actions as the division does 

not participate in the Corrective Actions Program 

Working Group and is part of the Office of the Assistant 

Secretary for Health.

Department of Homeland 

Security (DHS)

FEMA 

Ensure continuity of operations According to FEMA officials, the agency is developing 

and exercising flexible, scalable, and tiered continuity of 

operations plans. The FEMA headquarters continuity of 

operations plan was signed on January 12, 2014 and 

the national-level exercise of 2014 was conducted as 

planned. 

DHS

FEMA 

Meet survivors’ needs during initial 

interactions

According to FEMA officials, the agency is updating 

policies regarding its Individual Assistance program. 
Appendix IV: Corrective Actions Developed 

after Hurricane Sandy Not Yet Closed, as of 

November 2014

Page 66 GAO-15-20 Emergency Preparedness

DHS

FEMA 

Coordinate among states, localities, and 

tribes

According to FEMA officials, the agency is expanding its

capacity to coordinate with tribal nations. FEMA 

established the Tribal Integration Group, which will 

ensure that the agency meets requirements to regularly 

consult with and consider tribal governments in program 

and policy development. 

DHS

FEMA 

Refine the mission assignment process According to FEMA officials, the agency is refining the 

mission assignment process to ensure the ability to task 

federal agencies effectively for recovery-related 

missions. FEMA solicited input widely from across 

program areas, leadership, and FEMA regions, as well 

as the Recovery Support Functions Leadership Group. 

FEMA is reviewing updated mission assignment forms 

and guidance to address tasking needs of other federal 

agencies. 

DHS

FEMA 

Reduce the complexity of the Public 

Assistance program

According to FEMA officials, the agency is updating 

policies and procedures regarding its public assistance 

program. FEMA has also released guidance for two 

public assistance pilot programs authorized by the 

Sandy Recovery Improvement Act of 2013, which are 

currently underway.

DHS

d

FEMA 

Integrate federal senior leader coordination 

and communications into response and 

recovery operations, and coordinate 

emergency support functions and recovery 

support functions to support disaster 

response 

According to FEMA officials, the agency is evaluating 

the option of appointing liaisons to senior federal 

officials to facilitate greater coordination and 

communication during Level 1 incidents. FEMA is also 

reviewing doctrine and policy and developing possible 

courses of action and milestones.e

DHS

 

FEMA 

Mobilize the FEMA workforce for disaster 

response

According to FEMA officials, the agency is clarifying and 

automating procedures for deploying permanent fulltime and Cadre of On-Call Response/Recovery 

Employment personnel. FEMA Administrator Craig 

Fugate signed the deployment guidance and directive 

on January 29, 2014. 

DHS

FEMA 

Use planning and analysis to drive 

operational decision making

According to FEMA officials, the agency is conducting 

mission analysis of future planning to determine desired 

capabilities and a plan to achieve those capabilities.

FEMA has applied draft Future Planning Standard 

Operating Procedures to project impacts of recent 

events including the threat of avian influenza A (H7N9), 

pandemic influenza, Middle East respiratory syndrome 

coronvirus (MERS CoV), all potential tropical cyclones 

during the 2013 season, and Colorado flooding. 

DHS

FEMA 

Implement incident management structures According to FEMA officials, the agency is developing 

recommendations regarding forward deployment of 

FEMA senior officials and their relationship with Federal 

Coordinating Officials and the National Response 

Coordination Center. FEMA is also reviewing doctrine 

and policy and developing courses of action and 

milestones. 
Appendix IV: Corrective Actions Developed 

after Hurricane Sandy Not Yet Closed, as of 

November 2014

Page 67 GAO-15-20 Emergency Preparedness

Department of Justice (DOJ)

Bureau of Alcohol, 

Tobacco, Firearms and 

Explosives (ATF)

Improve the functionality of the Public 

Safety and Security Emergency Support 

Function (ESF) National Coordination 

Center.

According to DOJ officials, the Public Safety and 

Security ESF is attempting to accelerate the building of 

the center, is working with federal law enforcement 

partners to increase staffing of the center during ESF 

activations, adopted the Law Enforcement Online Virtual 

Command Center to increase the center management 

of information during ESF activations, and revised the 

National Operations and Coordination Standard 

Operating Procedures Annex to incorporate best 

practices identified during the Hurricane Sandy 

activation. DOJ officials stated that building of the 

National Coordination Center is to commence in 

December 2014 with an anticipated completion date of 

April 2015. 

DOJ

ATF

Investigate the feasibility of deploying a 

group of Public Safety and Security ESF 

resources to a forward staging area with 

supporting elements from a single 

prescripted mission assignment, and then 

assigning specific missions.

According to DOJ officials, this corrective action will be 

fulfilled through the completion of a related corrective 

action to improve the overall functionality of the National 

Coordination Center. DOJ officials stated that the 

referenced prescripted mission assignment was 

developed and approved by FEMA in August 2013.

DOJ

ATF

Examine the feasibility of developing an 

independent logistical capability that will be 

able to meet the needs of any Public Safety 

and Security ESF deployment.

According to DOJ officials, a logistical working group 

formed to address Public Safety and Security ESF 

deployment logistics determined that the ESF should 

develop its own deployment logistics capability 

consisting of a deployment logistics officer and a fulltime deployment logistics contractor. These personnel 

are in place and exploring options related to logistical 

support.

DOJ

ATF

Adequately staff the National Coordination 

Center and provide liaison personnel to the 

FEMA National Response and Coordination 

Center.

According to DOJ officials, the Public Safety and 

Security ESF is working with federal law enforcement 

partners to enhance staffing at the National 

Coordination Center when the ESF is activated, which 

will enable the national coordinator to assign permanent 

ESF staff to FEMA’s National Response and 

Coordination Center. 

Source: GAO analysis of DOD, DOE, HHS, DHS, and DOJ documents. | GAO-15-20

a

According to DOD officials, “confirming event” is any event or exercise during which DOD officials 

are able to demonstrate the steps taken to address the corrective action and verify that the action has 

been closed.

b

There were 25 corrective actions in the DOE intradepartmental Hurricane Sandy after-action report 

developed by DOE’s Office of Electricity Delivery and Energy Reliability. However, DOE officials 

stated that, based upon feedback provided by interagency participants, 16 of these actions were 

assigned to entities other than DOE for resolution, such as states or private sector stakeholders, and 

therefore DOE is not tracking the status of implementation for these 16 actions. Because DOE was 

not assigned responsibility for implementing these corrective actions, these 16 actions were not 

included in this report.

c

According to HHS, the Incident Command System provides guidance for how to organize assets to 

respond to an incident and processes to manage the response through its successive stages. The 

core concepts of the Incident Command System are common terminology, integrated 

communications, modular organization, unified command structure, a manageable span of control for 

supervisory-level personnel, consolidated action plans, comprehensive resource management, and 

predesignated facilities where expected critical incident-related functions will occur.

d

See Pub. L. No. 113-2, 127 Stat. 39.
Appendix IV: Corrective Actions Developed 

after Hurricane Sandy Not Yet Closed, as of 

November 2014

Page 68 GAO-15-20 Emergency Preparedness

e

FEMA defines Level 1 incidents as those incidents in which available assets designed and put in 

place for the response are overwhelmed or broken at the local, regional or national level; require an 

extreme amount of federal assistance for response and recovery efforts for which the capabilities do 

not exist at any level of government; require extraordinary coordination among federal, state, tribal, 

and local entities because of massive levels and breadth of damage, severe impact, or multistate 

scope; and require the significant involvement of FEMA, the activation of all primary ESF agencies, 

and the deployment of initial response resources to support requirements of the affected state.
Appendix V: Improvised Nuclear Device (IND) 

Program Interagency Working Groups’ 

Activities and Projects

Page 69 GAO-15-20 Emergency Preparedness

In March 2012, the Federal Emergency Management Agency (FEMA) 

issued the IND Response and Recovery Capability-Based 

Implementation Plan (IND Implementation Plan), which identified 

corrective actions to address IND attack emergency response capability 

gaps that had previously been identified in the April 2010 DHS

[Department of Homeland Security] Strategy for Improving the National 

Response and Recovery from an IND Attack (DHS IND Strategy).

1 In 

September 2013, an updated version of the IND Implementation Plan was 

issued to provide information on progress made to address the identified 

gaps.2 The IND Implementation Plan recommended actions that were 

developed by five interagency working groups composed of subject 

matter experts from federal agencies, state and local emergency 

management organizations, academic institutions, research centers, and 

nongovernmental organizations. According to FEMA officials, in addition 

to developing the recommended actions, the working groups monitor their 

implementation. Table 10 summarizes the capability gaps, their status, 

and related ongoing recommended actions as reported in the latest 

iteration of the IND Implementation Plan.

 

1

DHS, DHS Strategy for Improving the National Response and Recovery from an IND 

Attack (Washington, D.C.: April 2010); FEMA, Improvised Nuclear Device Response and 

Recovery Capability-Based Implementation Plan (Washington, D.C.: March 2012). 

2

FEMA, Improvised Nuclear Device Response and Recovery Capability-Based 

Implementation Plan, Revision 1 (Washington, D.C.: September 2013). 

Appendix V: Improvised Nuclear Device 

(IND) Program Interagency Working Groups’ 

Activities and Projects
Appendix V: Improvised Nuclear Device (IND) 

Program Interagency Working Groups’ 

Activities and Projects

Page 70 GAO-15-20 Emergency Preparedness

Table 10: Summary of Capability Gaps and Recommended Actions Pursued as identified in the September 2013 IND 

Implementation Plan

Working group

Capability gap and

reported status

Recommended actions pursued

to address capability gap

Response The complex all-hazards issues involved in an 

improvised nuclear device (IND) incident will be an 

extreme management challenge. The 2010 

Deepwater Horizon Gulf of Mexico oil spill caused 

members of the response community to question 

whether the Incident Command System as written 

could handle these complexities.

Status–25% complete

a

• Develop a document to address dividing the incident 

into manageable organizational elements

• Develop a document that would outline the required 

number of incident management teams that are needed 

to ensure a successful response

• Create an incident action plan template and then 

demonstrate its use with estimating resources for a 

single geographic sector of a simulated IND incident

Emergency response officials need the ability to 

receive, interpret, and exchange nuclear 

information among themselves and with decision 

makers following an IND detonation.

Status–75% complete

• Develop position description and qualifications for 

subject matter expert assistance to first responders and 

key leaders

• Develop a comprehensive inventory of resources 

available to an IND response

Because public perception of the dangers of very 

low level radioactive contamination, refugees may 

be denied access to shelters and basic human 

needs. In addition, this same perception of danger 

will also make it unlikely that many shelters will 

even be allowed to open within a reasonable 

proximity to the incident.

Status–75% complete

• Develop a document to address problem areas in 

decontaminating the affected populations, pets, and 

other animals

• Develop a document to address the problem of the 

overwhelming number of people and animals in need of 

assistance after the detonation of an IND 

Household pets, service animals and livestock will 

be an extreme management challenge if not 

addressed within emergency plans. The goal is to 

identify and provide scientifically valid operational 

processes, adequate staffing, resources and 

facilities to manage animals.

Status–50% complete

• Develop an animal demographics estimation guidance 

document

• Develop a timeline for animal response missions 

document

• Develop a document to determine training/qualifications 

for each mission area

• Develop a document pertaining to just-in-time training 

for volunteers

• Compile current bibliography of scientific articles and 

other references pertaining to management of animals 

in nuclear or radiological incidents 

Medical and 

Public Health

Radiation dose assessment capabilities for the 

evaluation of large numbers of potentially affected 

individuals are needed to ensure optimal use of 

limited medical resources and to systematically 

perform triage.

Status–the recommended actions will take 1-5 

years to complete

• Research and develop novel methods or systems to 

conduct radiation biodosimetry applicable in mass 

casualty situations

• Develop rapid, high-throughput methods to assess 

radiation dose and laboratory networks for surge 

capacity 
Appendix V: Improvised Nuclear Device (IND) 

Program Interagency Working Groups’ 

Activities and Projects

Page 71 GAO-15-20 Emergency Preparedness

First responders and first receivers need proper 

baseline education and just-in-time training to 

appropriately evaluate and manage casualties

Status–actions are ongoing 

• Create just-in-time training for the provision of 

information on key immediate actions for the medical 

response to an IND detonation

• Coordinate with professional societies and national 

associations to improve visibility of currently available 

educational resources

• Develop essential baseline educational curriculum for 

first responders, medical providers, and emergency 

support function (ESF) #8 stakeholdersb

Greater access to medical countermeasures with a 

Food and Drug Administration-approved indication 

for prevention, mitigation, and treatment of acute 

radiation syndrome is needed.

 

Status–the recommended actions will take 5-10 

years to complete

• Develop logistical and operational plans for optimized 

use of medical countermeasures at all levels of the 

response

• Expand approved indications for currently available 

countermeasures to include acute radiation syndrome

• Research and develop novel countermeasures with 

Food and Drug Administration-approved prevention, 

mitigation and treatment of acute radiation syndrome

Communications 

and Public 

Messaging

Public communications systems exist but are 

inadequate for large-scope incidents, such as an 

IND detonation. Local information sources need to 

establish initial communications with, among, and 

between the affected population and response 

forces, government, and media.

Status–ongoing

• Develop a strategy for implementing communications 

training specific to an IND response

• Develop a public communications strategy to provide 

awareness of safety and security actions in the vicinity 

of the blast area and in the overall federally declared 

disaster area

• Develop a website and tools to broadcast sustained 

lifesaving messages using existing social networking 

sources and text-based communications devices 

First responders are marginally aware, and the 

public is largely unaware and generally unprepared 

to execute effective protective and response 

actions following an IND incident.

Status–ongoing 

• Create, test, and exercise public information on 

sheltering, evacuation, decontamination, reentry and 

cleanup, along with guidance to effectively execute 

shelter-in-place or other protective and response 

actions following an IND incident

• Identify and engage nontraditional federal partners, 

such as spokespeople and corporate 

disaster/contingency operations planners for enhanced 

private and public sector coordination

• Use non-English-language outreach, faith-based, and 

volunteer organizations to help transmit information 

between the affected population and local response 

forces, government and media following an IND 

detonation 
Appendix V: Improvised Nuclear Device (IND) 

Program Interagency Working Groups’ 

Activities and Projects

Page 72 GAO-15-20 Emergency Preparedness

Need systems and methods to provide the public 

with information on lifesaving and protective 

measures after an IND detonation.

Status–ongoing

• Develop a system to disseminate information for the 

population in the affected and nearby areas that can be 

used to address critical needs, such as family 

reunification tools, decontamination locations, and 

evacuation routes

• Further develop, distribute, and inform local populations 

about Communicating in the Immediate Aftermath 

messaging document so that the public is able to 

effectively self-protect in the days following an IND 

detonation

• Reestablish communications in affected communities to 

allow the population to communicate 

c 

Scientific 

Support

First responders, emergency managers, and other 

public officials may lack the ability to communicate 

post-IND.

Status–study 95% complete. 

• Improve understanding of whether and how federal, 

state, and local response will be hampered by loss of 

communications 

Emergency planners lack clear and concise 

guidance for shelter, evacuation, reentry, 

reoccupation, and cleanup.

Status–ongoing, four cities completed

• Model Urban Areas Security Initiative (UASI) cities (1 in 

each of the 10 FEMA regions) to produce a key 

planning document to be used to support the 

development of local, state, and regional response and 

recovery plans

The general public lacks awareness of the actions 

necessary to survive a nuclear incident.

d 

Status–ongoing

• Develop and test a prototype “serious gaming” platform 

to provide a motivating, enriching, and engaging 

educational preparedness medium 

The United States needs a scientifically sound 

technique to compare and incorporate data and 

predictions from different sources after an IND 

incident.

Status–ongoing

• Implement Rad Responder, a web-based data input and 

output framework

Source : GAO analysis of Federal Emergency Management Agency documents | GAO-15-20

e 

a

The Incident Command System is a management system designed to enable effective and efficient 

domestic incident management by integrating a combination of facilities, equipment, personnel, 

procedures, and communications operating within a common organizational structure, designed to 

enable effective and efficient domestic incident management. It is used to organize both near-term 

and long-term field-level operations for a broad spectrum of emergencies, from small to complex 

incidents, both natural and manmade. The Incident Command System is used by all levels of 

government—federal, state, local, and tribal—as well as by many private sector and 

nongovernmental organizations.

b

Emergency support functions are, according to the National Response Framework, the federal 

government’s primary coordinating structure for building, sustaining, and delivering response core 

capabilities. ESF #8, one of the 14 ESFs, is the coordinating structure for building, sustaining, and 

delivering response core capabilities specifically related to public health and medical services.

c

Communicating in the Immediate Aftermath is a document developed as a resource for emergency 

responders and federal, state, and local officials communicating with the public and the media 

immediately following an IND attack in the United States. An interagency group of communications 

and radiation technical experts developed the messages in this document, which include key 

messages for the affected community and the nation, and anticipated questions and answers for 

distribution to the public. Federal Emergency Management Agency, Improvised Nuclear Device 

Response and Recovery: Communicating in the Immediate Aftermath (Washington, DC: June 2013)

d

The Urban Areas Security Initiative is a Department of Homeland Security grant program that 

provides federal assistance to address the unique needs of high-threat, high-density urban areas, and 

assists them in building an enhanced and sustainable capacity to prevent, protect against, respond 

to, and recover from acts of terrorism.
Appendix V: Improvised Nuclear Device (IND) 

Program Interagency Working Groups’ 

Activities and Projects

Page 73 GAO-15-20 Emergency Preparedness

e

Rad Responder is a FEMA web-based tool to facilitate coordination across all levels of government 

through the rapid collection and organization of the data that are needed to characterize the IND 

incident and support lifesaving decisions (e.g., through modeling of the size and direction of the 

plume containing radioactive materials).
Appendix VI: Comments from the Department 

of Homeland Security

Page 74 GAO-15-20 Emergency Preparedness

Appendix VI: Comments from the 

Department of Homeland Security
Appendix VI: Comments from the Department 

of Homeland Security

Page 75 GAO-15-20 Emergency Preparedness
Appendix VI: Comments from the Department 

of Homeland Security

Page 76 GAO-15-20 Emergency Preparedness
Appendix VII: GAO Contact and Staff 

Acknowledgments

Page 77 GAO-15-20 Emergency Preparedness

Chris P. Currie, (404) 679-1875 or CurrieC@gao.gov

In addition to the contact named above, Chris Keisling (Assistant 

Director), David Alexander, Jerry Ambroise, Katherine Davis, Susan Hsu, 

Tracey King, David Lysy, Amanda Miller, Linda Miller, Erin O’Brien, Geoff 

Peck, Laurani Singh, and Kristen Timko made key contributions to this 

report. 

Appendix VII: GAO Contact and Staff 

Acknowledgments

GAO Contact:

Staff 

Acknowledgments:

(441184)
Related GAO Products

Page 78 GAO-15-20 Emergency Preparedness

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For more information on related GAO products, see:

http://www.gao.gov/key_issues/disaster_management/issue_summary. 
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