United States Government Accountability Office

GAO Report to the Chairman, Committee on 

Government Reform, House of 

Representatives 

CONTINUITY OF 

OPERATIONS 

Selected Agencies 

Could Improve 

Planning for Use of 

Alternate Facilities 

and Telework during 

Disruptions 

May 2006 

 

GAO-06-713 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

May 2006

CONTINUITY OF OPERATIONS

Selected Agencies Could Improve 

Planning for Use of Alternate Facilities 

and Telework during Disruptions 

Highlights of GAO-06-713, a report to the 

Chairman, Committee on Government 

Reform, House of Representatives

To ensure that essential 

government services are available

in emergencies, federal agencies

are required to develop continuity

of operations (COOP) plans. The 

Federal Emergency Management 

Agency (FEMA), within the 

Department of Homeland Security

(DHS), is responsible for 

overseeing and assessing the status 

of COOP capabilities of federal 

executive branch agencies. It has

developed guidance stating that

agency COOP plans must designate

alternate facilities and prepare

personnel for unannounced

relocation to these facilities. The

guidance also states that agencies 

should consider the use of 

telework in their continuity plans. 

GAO was asked to follow up on its 

previous work on COOP planning

and determine, among other things,

to what extent (1) 6 selected

agencies prepared their alternate

facilities and (2) 23 major agencies

made preparations necessary to

effectively use telework in 

emergency situations. 

What GAO Recommends

GAO is making recommendations 

to DHS aimed at improving the 

assessment and oversight of agency 

continuity planning and developing

guidance on including telework in

such planning. In commenting on a 

draft of this report, DHS partially

agreed with GAO’s 

recommendations and described

actions to implement them. 

All six agencies GAO reviewed took steps to prepare their alternate facilities 

for use in emergencies. However, none of the agencies followed all of 

FEMA’s guidance. For example, none conducted all the applicable tests and 

exercises, such as annual exercises that involve moving COOP personnel to 

alternate facilities. Further, agencies did not fully identify the resources 

necessary to support their essential functions, which reduces assurance that 

their facilities are adequately prepared. 

Although individual agencies are ultimately responsible for preparing their 

plans and alternate facilities, FEMA’s limited efforts to oversee and assess 

agency COOP capabilities contributed to agencies’ incomplete compliance 

with its guidance. According to an official from the Department of Homeland 

Security, FEMA recently developed a schedule of oversight activities that 

includes conducting assessments of agency continuity plans starting in July 

2006. However, the assessment’s methodology is not yet finalized. If FEMA 

does not develop an assessment methodology that effectively evaluates 

agencies’ compliance, it will have limited assurance that agencies have taken 

the steps necessary to ensure that they will be able to perform essential

government operations following a disruption. 

Although agencies are not required to use telework in continuity planning, 

9 of the 23 agencies surveyed reported plans for essential team members to 

telework during a COOP event, compared with 3 in GAO’s previous survey. 

However, few documented that they made the necessary preparations to 

effectively use telework during such an event (see table). For example, only

one agency documented that it had notified its team members of their 

expectation to telework during a COOP event. The lack of specific guidance

on preparations for telework during such an event contributed to the low 

levels of preparation that agencies reported. If agencies do not make 

adequate preparations, they may not be able to use telework effectively to 

ensure the continuity of their essential functions in emergencies.

Agency Responses to Selected Questions on Telework in COOP Plans 

Question Year Yes Yes (no doca) No

2005 3 6 14 Are any of the agency’s essential team members expected 

to telework in a COOP event? 

2004b 1 2 19

Wer 2005 1 10 12 e staff informed of their responsibility to telework during 

a COOP event? 

2004 1 3 18

Has the 2005 0 14 9 agency ensured that it has adequate technological 

capacity for staff to telework during a COOP event? 

2004 0 5 17

Will the agenc 2005 3 11 9 y provide technological assistance to staff 

during a COOP event? 

2004 0 5 17

Has the agency tested the ability of staff to telework during a 

COOP event? 2005 3 7 13

2004 0 2 20

Source: GAO.

a Agencies responded positively but did not provide adequate documentation in support. b In 2004, one agency did not respond, resulting in a total of 22 responses. 

www.gao.gov/cgi-bin/getrpt?GAO-06-713.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Linda Koontz at

(202) 512-6240 or koontzl@gao.gov. 
Contents 

Letter 1

Recommendations for Executive Action 5

Agency Comments and Our Evaluation 5 

Appendix I Unclassified Version of April 13, 2006, Briefing to 

Staff of the House Committee on Government 

Reform 8

Appendix II Comments from the Department of Homeland 

Security 64

Abbreviations 

COOP continuity of operations 

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency 

FPC Federal Preparedness Circular 

OPM Office of Personnel Management 

PDD Presidential Decision Directive 

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

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 

Page i GAO-06-713 Continuity of Operations
United States Government Accountability Office

Washington, DC 20548 

May 11, 2006

The Honorable Tom Davis 

Chairman 

Committee on Government Reform 

House of Representatives 

Dear Mr. Chairman: 

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

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

emergencies. Federal agencies are required by Presidential Decision 

Directive (PDD) 67 to develop plans for ensuring the continuity of such 

services in emergency situations. This directive also designated the 

Federal Emergency Management Agency (FEMA) as lead agent for 

executive branch continuity of operations (COOP) planning, which 

includes the responsibility for formulating guidance on such planning and 

for assessing the status of executive branch COOP capabilities. 1

In response, FEMA issued COOP guidance to agencies in July 1999: 

Federal Preparedness Circular (FPC) 65. The circular states that, in order 

to have a viable COOP capability, agencies should identify their essential 

functions, which then provide the basis for subsequent planning steps. The 

circular further states that agencies must designate alternate facilities as 

part of their continuity plans and prepare their personnel for the 

possibility of unannounced relocation of essential functions to these 

facilities. 

In June 2004, FEMA released an updated version of FPC 65, providing 

additional guidance to agencies on each of the topics covered in the 

original guidance, including an annex on alternate facilities. According to 

the guidance, an agency must identify an alternate facility that provides 

sufficient space for relocated personnel to perform essential agency

functions during a COOP event. The guidance also directs agencies to 

identify the levels of staff and resources required at the alternate facility to

support the performance of these functions. The identification of staff and 

 1

Although the 2004 version of FPC 65 refers to FEMA as the “lead agent” for federal 

executive branch continuity efforts, the 1999 version used the term “executive agent.” 

Page 1 GAO-06-713 Continuity of Operations
resources—including equipment, critical information systems and data, 

and vital records—establishes the preparation requirements for an 

alternate facility. For example, in order for an agency to determine that it 

has an adequate number of computers present at the alternate facility, it 

must first establish how many are required to support personnel in the 

performance of essential functions. Once critical resources are identified,

pre-positioning them is necessary to preparing an alternate facility. 

The 2004 version of FPC 65 also states that agencies should consider 

telework (also known as work-at-home or flexiplace) as an option in their 

COOP planning. Although FPC 65 does not require agency plans to 

incorporate telework, using this option can allow employees to contribute

to the performance of agency essential functions without having to 

physically relocate to an alternate operating facility. As we reported in 

April 2004, telework is an important and viable option for federal agencies

in continuity planning and implementation efforts, especially as the 

duration of an emergency event is extended.2

 We recommended in that 

report that the Secretary of Homeland Security direct the Under Secretary 

for Emergency Preparedness and Response to complete efforts to revise 

federal COOP guidance to more fully address human capital 

considerations by incorporating six organizational actions, the scope of 

which included telework. 

In 2002 and 2004, we reviewed the extent to which agency COOP plans 

complied with FEMA’s continuity guidance at the request of the Chairman, 

House Committee on Government Reform. In both reviews, we reported 

that agency plans did not generally comply with FEMA’s guidance. In 2004, 

we also surveyed agencies to determine how they planned to use telework 

during COOP events and reported that, although agencies were not 

required to address telework in their continuity plans, 2 of the 22 

responding agencies did so in the plans that were in place on May 1, 2004.3

For the current review, as agreed with the committee, our objectives were

to determine to what extent agencies have 

 2

GAO, Human Capital: Opportunities to Improve Federal Continuity Planning

Guidance, GAO-04-384 (Washington, D.C.: Apr. 20, 2004).

3

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

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

Apr. 28, 2005); and Continuity of Operations: Agency Plans Have Improved, but Better 

Oversight Could Assist Agencies in Preparing for Emergencies, GAO-05-619T 

(Washington, D.C.: Apr. 28, 2005). 

Page 2 GAO-06-713 Continuity of Operations
• prepared alternate facilities where they can perform their essential 

functions in emergencies and 

• made preparations necessary to effectively use telework in emergency

situations. 

To achieve our first objective, we obtained and reviewed headquarters 

contingency plans from 23 of the largest civilian departments and agencies

to identify the population of alternate facilities; verified alternate facilities 

information with each agency; and selected, from the population of 

alternate facilities, six alternate facilities illustrating variations in several 

attributes, including agency budget size, distance from respective primary 

work facility, and facility type. For the selected alternate facilities, we 

evaluated compliance with FPC 65 criteria by analyzing agency COOP 

plans and other documentation and by visiting alternate facilities. Finally, 

we obtained and analyzed FEMA’s COOP guidance and documents 

describing its efforts to provide oversight and assessments of federal 

planning efforts, and conducted interviews with FEMA officials to clarify 

the activities described in these documents. 

For our second objective, we reviewed prior GAO work on telework to 

determine key practices for the development of an effective telework 

program; developed a series of questions regarding agency plans and 

preparations to use telework during a COOP event; surveyed agency

officials responsible for continuity planning at 23 of the largest civilian 

departments and agencies to determine to what extent key telework 

practices were used in making continuity preparations; reviewed 

supporting documentation submitted by agency officials to support their 

responses; and created tables that compared this year’s survey responses 

with those from our previous survey in 2004. 

We conducted our review between July 2005 and February 2006 in the 

Washington, D.C., area and at several agency alternate facilities in 

accordance with generally accepted government auditing standards. 

On April 13, we provided your office with a classified briefing on the 

results of this review. The purpose of this letter is to provide you with the 

unclassified material from our briefing. (See app. I.) 

In summary, all six agencies we reviewed had identified alternate facilities 

and took steps to prepare their alternate facilities for use in emergencies. 

For example, most agencies documented plans and procedures related to 

these facilities, including site preparation and activation plans. However, 

Page 3 GAO-06-713 Continuity of Operations
none of the agencies followed all of FEMA’s guidance. For example, none 

conducted all of the applicable tests and exercises outlined in FPC 65, 

including annual exercises that incorporate the deliberate and preplanned 

movement of COOP personnel to the agencies’ alternate facilities. Further, 

agencies did not fully identify the levels of resources necessary to support 

their essential functions (e.g., the number of computers to support the 

performance of essential functions), creating a lack of assurance that the 

agencies’ facilities are adequately prepared. 

Although each agency is responsible for developing a viable COOP plan 

and ensuring that its alternate facilities are adequately prepared, FEMA’s 

limited efforts to oversee and assess agency COOP capabilities 

contributed to the agencies’ lack of compliance with all of the FPC 65 

guidance. For example, FEMA has continued to rely on agency-reported 

information as the basis for its assessments. In addition, two planned 

oversight efforts—a readiness reporting system operated by FEMA and a 

review of agency essential functions by the White House—have been 

delayed. 

According to an official from the Department of Homeland Security 

(DHS)—the parent agency of FEMA—FEMA plans to expand its oversight 

activities to include the evaluation and assessment of individual agency

COOP capabilities. As part of the methodology for an upcoming 

interagency exercise, known as Forward Challenge 06, FEMA officials 

anticipate using independent observers to evaluate agency plans and their 

implementation during the exercise. In addition, officials plan to conduct

individual agency COOP assessments starting in July 2006. However, 

details regarding the assessment’s methodology have yet to be finalized. If 

FEMA does not develop an assessment methodology that evaluates 

agencies’ compliance with FPC 65—including the extent to which agencies

(1) identify essential functions; (2) identify the levels of staff and 

resources required at their alternate facilities; and (3) plan, conduct, and 

document the necessary tests and exercises at the appropriate scope and 

frequency—it will have limited assurance that agencies have taken the 

steps necessary to ensure that they will be able to perform essential 

government operations following a disruption. 

Finally, more agencies reported plans for essential team members to 

telework during a COOP event than in our previous survey, but few 

documented that they made the necessary preparations to effectively use 

telework during an emergency. Nine of the 23 agencies reported that some 

of their essential team members are expected to telework during such an

event. However, only 1 agency documented that it had communicated this

Page 4 GAO-06-713 Continuity of Operations
expectation to its emergency team members. In addition, only 3 of the 23 

agencies documented testing the ability of staff to telework during a COOP 

event. 

The lack of specific guidance on the steps that agencies should take to 

ensure that they are fully prepared to use telework during a COOP event 

contributed to the low levels of preparation that agencies reported. FEMA 

recently disseminated guidance to agencies regarding the incorporation of 

pandemic influenza considerations into COOP planning. However, while 

the guidance does suggest the use of telework during such an event, it 

does not address the steps agencies should take when preparing to use 

telework during a COOP event. If agencies do not make adequate 

preparations, they may not be able to use telework effectively to ensure 

the continuity of their essential functions in emergencies. 

To ensure that agencies are adequately prepared to continue performing 

essential functions following an emergency, we recommend that the 

Secretary of Homeland Security direct the FEMA Director to improve the 

oversight of agency COOP planning by taking the following three actions:

• Before the upcoming interagency exercise, conduct an assessment of the 

COOP plans of the six agencies whose alternate facilities were included in

our review and report any deficiencies to the head of the agency for 

correction.

• Develop a methodology for individual agency COOP assessments that 

independently evaluates executive branch agencies’ compliance with FPC 

65, including the extent to which agencies (1) identify essential functions; 

(2) identify the levels of staff and resources required at their alternate 

facilities; and (3) plan, conduct, and document the necessary tests and 

exercises at the appropriate scope and frequency. The methodology 

should include a mechanism for reporting any deficiencies to the head of 

the agency for correction. 

• Establish a time line for developing, in consultation with the Office of 

Personnel Management (OPM), guidance on the steps that agencies should 

take to adequately prepare for the use of telework during a COOP event. 

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

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

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

Page 5 GAO-06-713 Continuity of Operations
comments are reproduced in app. II.) In commenting on the report, the 

Director stated that DHS partially agreed with our recommendations. 

In commenting on oversight of COOP planning, the Director wrote that 

PDD 67 directed that an interagency advisory group shall provide 

coordination, oversight, and management for COOP-related activities of 

executive branch agencies. He added that although FEMA is designated as

chair of this group, participating agency coordinators are designated with 

the authority to represent and commit their agencies in COOP-related 

matters. However, as we point out in our report, according to FPC 65, the 

presidential directive also established FEMA as the lead agency for 

executive branch continuity planning. Included in this responsibility is the 

specific requirement for FEMA to oversee and assess the status of COOP 

capabilities of executive branch agencies. 

In responding to our first recommendation, the Director stated that DHS 

partially agreed and that FEMA will be conducting assessments of the six 

agencies in conjunction with its upcoming interagency exercise. 

Regarding our recommendation on developing an assessment 

methodology, the Director wrote that FEMA currently has an assessment 

program and a methodology that includes (1) a self-assessment tool to 

assist senior leaders in performing internal assessments, (2) the 

governmentwide exercise planned for June 2006, and (3) a plan for an 

expanded comprehensive department and agency assessment program. He 

added that FEMA plans to continually refine this methodology and expand

the program through additional funding and resources. In addition, the 

Director stated that the agency’s efforts are constrained by resources. He 

stated that to improve the readiness of the federal government’s COOP 

program, additional resources are required to support the large number of

federal offices and facilities that could benefit from recurring COOP 

assessments. 

However, while these steps outline an overall approach to assessing 

agency plans, they do not constitute a methodology for assessing agency 

compliance with FPC 65—including the extent to which agencies (1) 

identify essential functions; (2) identify levels of staff and resources 

required at their alternate facilities; and (3) plan, conduct, and document 

the necessary tests and exercise at the appropriate scope and frequency, 

as we have recommended. Without such a methodology, the agency will 

have limited assurance that agencies have taken the necessary steps to 

prepare for an emergency. While we did not review the adequacy of 

FEMA’s resources for conducting oversight of agency planning, DHS 

Page 6 GAO-06-713 Continuity of Operations
should review how FEMA prioritizes its currently available funding for 

COOP activities and to the extent it agrees that additional funding is 

needed, pursue justifying increases.

In responding to our recommendation on developing guidance on 

agencies’ use of telework, the Director partially agreed and stated that 

FEMA will coordinate with OPM in the development of a timeline for 

further telework guidance. In addition, he stated that both FEMA and OPM 

have provided guidance on the use of telework. However, as stated in our 

report, present guidance does not address the preparations agencies 

should make for using telework during emergencies and it is unclear 

whether and when FEMA will release such guidance. 

The Director also included technical comments that we have addressed, as

appropriate.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Homeland Security, and the Director of the 

Office of Personnel Management, and will make copies available to others

on request. In addition, the report will be available at no charge on the 

GAO Web site at http://www.gao.gov. 

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

at (202) 512-6240 or koontzl@gao.gov. Key contributions to this report 

were made by James R. Sweetman Jr., Assistant Director; Barbara Collier; 

Nick Marinos; and Kim Zelonis. 

Sincerely yours, 

Linda D. Koontz 

Director, Information Management Issues 

Page 7 GAO-06-713 Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House Appendix I: Unclassified V Committee on Government Reform ersion of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

1

Continuity of Operations: Selected Agencies Could Improve 

Planning for Use of Alternate Facilities and Telework During 

Disruptions

Briefing for the Staff of the

Committee on Government Reform,

House of Representatives

April 13, 2006

Page 8 GAO-06-713 Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 9 GAO-06-713

2

Outline of Briefing

Introduction

Objectives, Scope, and Methodology

Results in Brief

Background

Results

• Alternate Facilities Compliance

• Telework

Conclusions

Recommendations

Agency Comments and Our Evaluation

Attachment 1: Agencies Participating in Telework Survey

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 10 GAO-06-713

3

Introduction

Federal operations and facilities have been disrupted by a range of events, including 

• the terrorist attacks on September 11, 2001, and at Oklahoma City;

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

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

headquarters.

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

services. Prudent management, therefore, requires that federal agencies develop plans for 

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

continuity of operations (COOP) plans. These plans lay out an agency’s approach to

maintaining services, ensuring proper authority for government actions, and protecting vital 

assets. 

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 11 GAO-06-713

4

Introduction

In October 1998, Presidential Decision Directive (PDD) 67 identified the Federal Emergency

Management Agency (FEMA) as the executive agent for federal COOP planning across the

federal executive branch.

FEMA’s responsibilities include

• formulating guidance for agencies to use in developing viable plans,

• coordinating interagency exercises and facilitating interagency coordination as

appropriate, and

• overseeing and assessing the status of COOP capabilities across the executive branch.

In July 1999, FEMA first issued Federal Preparedness Circular (FPC) 65. FPC 65 is

guidance to the federal executive branch for use in developing viable and executable 

contingency plans that facilitate the performance of essential functions during any

emergency. Some of the elements of a viable continuity of operations capability, according to

the guidance, include the identification of essential functions; provision for alternate facilities;

provision of interoperable communications; availability of vital records; and conduct of

regular tests, training, and exercises.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 12 GAO-06-713

5

Introduction

FEMA released an updated version of FPC 65 in June 2004, providing additional guidance to 

agencies on each of the topics covered in the original guidance, including an annex on 

alternate facilities. The annex states that all agencies must designate alternate operating 

facilities as part of their COOP plans and prepare their personnel for the possibility of an

unannounced relocation to these facilities. When agencies identify and prepare their 

alternate facilities, they should consider a number of items, including geographical location of

the facility, the availability of necessary logistics and infrastructure, and the safety and 

security of relocated personnel, in an effort to ensure that essential operations can be

performed during an emergency.

Telework can allow employees to contribute to the performance of agency essential 

functions without having to physically relocate to an alternate operating facility. Although the 

2004 version of FPC 65 does not require agencies to use telework (also known as work-athome or flexiplace) as an element of their COOP planning, it states that agencies should 

consider telework as an option. According to the Office of Personnel Management’s (OPM) 

guidance on Washington, D.C., area closures, one of the major benefits of a telework

program is the ability of employees to continue working at their alternative work sites during 

a disruption to operations.

1 In recognition of the growing importance of teleworkers to the 

continuity of agency operations, OPM states that agencies may require personnel to telework

when the agency is closed.

1 OPM, Washington, DC, Area Dismissal or Closure Procedures (Washington, D.C.: November 2005). 

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 13 GAO-06-713

6

Objectives, Scope, and Methodology

Objectives

In 2002 and 2004, we reviewed agency COOP plan compliance with FEMA’s guidance at the 

request of the Chairman, House Committee on Government Reform. In both reviews we

reported that agency plans did not generally comply with FEMA’s guidance. In 2004, we also

conducted a survey of agency planned use of telework during COOP events and reported 

that, although not required to do so, 2 of the 22 responding agencies addressed telework in

the continuity plans that were in place on May 1, 2004.

For the current review, as agreed with the Committee, our objectives were to determine to

what extent agencies have

• prepared alternate facilities where they can perform their essential functions in

emergencies and 

• made preparations necessary to effectively use telework in emergency situations.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 14 GAO-06-713

7

Objectives, Scope, and Methodology

To assess the preparation of agency alternate facilities, we

• obtained and reviewed headquarters contingency plans from 23 of the largest civilian 

departments and agencies to identify the population of alternate facilities; 

• verified alternate facilities information with each agency;

• selected, from the population of alternate facilities, six alternate facilities illustrating 

variations in several attributes, including agency budget size, distance from respective

primary work facility, and facility type;1

• for the selected alternate facilities, evaluated compliance with FPC 65 guidance through 

analysis of agency COOP plans, other documentation, and through observation during 

alternate facility visits; and

• obtained and analyzed FEMA’s COOP guidance and documents describing its efforts to

provide oversight and assessments of federal planning efforts, and conducted interviews

with FEMA officials to clarify the activities described in these documents. 

1 Because of the method of selection for the six alternate facilities we reviewed, we cannot conclude that our results represent 

any larger group of alternate facilities. However, the six facilities we reviewed illustrate some of the ways in which agencies

comply with FPC 65 guidance related to alternate facility identification and preparation.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 15 GAO-06-713

8

Objectives, Scope, and Methodology

For each of the six selected agency alternate facilities, we assessed compliance with FPC 65

guidance using questions based on the guidance. These questions address topics related to

the preparation of an alternate operating facility:

• site selection;

• facility plans and procedures;

• employee health, safety, security, and emotional well-being;

• space;

• equipment;

• vital records;

• voice and data communications; and

• tests and exercises.

These eight areas are our categorization of topics covered in the FEMA guidance on 

alternate facilities. Each topic area included two to seven questions.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 16 GAO-06-713

9

Objectives, Scope, and Methodology

We used the following steps to evaluate each agency alternate facility’s compliance and 

assign answers to each of the questions:

• Documents were reviewed and compared independently by two analysts. A third analyst

reviewed documentation where the initial two could not reach consensus.

• Initial assessments were shared with each agency during structured interviews.

• Agency officials had the opportunity to provide additional documentation to demonstrate

compliance.

• Analysts then visited alternate facilities to measure compliance with agency plans and 

continuity guidance (e.g., identify the pre-positioning of equipment at the facilities).

• Any supplemental information provided by the agencies was again reviewed by multiple

analysts.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 17 GAO-06-713

10

Objectives, Scope, and Methodology

Based on the agency contingency plans, other related documents, and physical observation 

during facility visits, we used content analysis to assign answers to the FPC 65-based

questions. Answers were assigned as follows:

• yes (compliant with all of the guidance related to that question), 

• no (not compliant with any of the guidance related to that question),

• partial (compliant with some, but not all of the guidance).

Based on this analysis, we created tables that summarized the results of the six

assessments. In some cases, agencies had not established clear requirements (for example,

they did not fully identify the necessary equipment, vital records, or number of personnel

needed to perform essential functions from their alternate facilities). In those cases, we were 

unable to determine compliance; these are indicated by footnotes in our summary tables.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 18 GAO-06-713

11

Objectives, Scope, and Methodology

To accomplish our objective on the use of telework, we

• reviewed prior GAO work on telework1 to determine key practices for the development of

an effective telework program;

• developed a series of questions regarding agency plans to use telework during a COOP

event;

• surveyed agency officials responsible for continuity planning at 23 of the largest civilian 

departments and agencies2 to determine to what extent telework key practices were

used in making continuity preparations;

• reviewed supporting documentation submitted by agency officials to support their 

responses; and

• created tables that compared this year’s survey responses with those from our previous

survey in 2004.3

We conducted our review between July 2005 and February 2006 in the Washington, D.C.,

area and at several agency alternate facilities, in accordance with generally accepted 

government auditing standards.

1 GAO, Human Capital: Further Guidance, Assistance, and Coordination Can Improve Federal Telework Efforts, GAO-03-679

(Washington, D.C.: July 18, 2003).

2 The 23 agencies that participated in the survey are listed in attachment 1. 3 GAO, Continuity of Operations: Agency Plans Have Improved, but Better Oversight Could Assist Agencies in Preparing for 

Emergencies, GAO-05-577 (Washington, D.C.: Apr. 28, 2005).

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 19 GAO-06-713

12

Results in Brief: Objective 1

All six agencies we reviewed took steps to prepare their alternate facilities for use in

emergencies. For example, most agencies documented plans and procedures related to

these facilities, including site preparation and activation plans. However, none of the 

agencies followed all of FEMA’s guidance. For example, none conducted all the applicable 

tests and exercises required by FPC 65, including annual exercises that incorporate the 

deliberate and preplanned movement of COOP personnel to an alternate facility. Further,

agencies did not fully identify the levels of resources necessary to support their essential 

functions, creating a lack of assurance that their facilities are adequately prepared. 

While individual agencies are responsible for developing a viable COOP plan and ensuring 

that their alternate facilities are adequately prepared, FEMA’s limited efforts to oversee and

assess agency COOP capabilities contributed to agencies’ lack of compliance with all of the 

FPC 65 guidance. For example, FEMA has continued to rely on agency-reported information 

as the basis for its assessments. In addition, two planned oversight efforts—a readiness

reporting system operated by FEMA and a review of agency essential functions by the White

House—have been delayed. 

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Results in Brief: Objective 1

FEMA recently developed a schedule of COOP oversight activities that includes conducting 

individual agency COOP assessments starting in July 2006. However, details regarding the

assessment’s methodology have yet to be finalized. If FEMA does not develop an 

assessment methodology that evaluates agencies’ compliance with FPC 65—including the

extent to which agencies (1) identify essential functions, (2) identify the levels of staff and 

resources required at their alternate facilities, and (3) plan, conduct, and document the 

necessary tests and exercises at the appropriate scope and frequency—it will lack

assurance that agencies have taken the steps necessary to ensure that they will be able to

perform essential government operations following a disruption.

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Results in Brief: Objective 2

More agencies reported plans for essential team members to telework during a COOP event

than in our previous survey, but few documented that they made the necessary preparations

to effectively use telework during an emergency. While FPC 65 does not require agencies to

telework during a COOP event, it does state that they should consider the use of telework in 

their continuity plans and procedures. All of the 23 agencies that we surveyed indicated that

they considered telework as an option during COOP planning. In addition:

• 9 of the 23 agencies reported that some of their COOP essential team members are 

expected to telework during a COOP event. However, only 1 agency documented that it 

had notified its team members of their expectation to telework during a COOP event.

• None of the 23 agencies demonstrated that they can ensure adequate technological 

capacity to allow designated personnel to telework during a COOP event.

• Only 3 of the 23 agencies documented testing the ability of staff to telework during a

COOP event. 

The lack of specific guidance from FEMA on the preparations necessary to ensure an

effective telework program contributed to the low levels of preparation that agencies

reported. If agencies do not make adequate preparations, they may not be able to use 

telework effectively to ensure the continuity of their essential functions in emergencies.

Continuity of Operations
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Results in Brief

Recommendations and Agency Comments

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

the assessment and oversight of agency continuity planning and developing guidance on 

including telework in such planning.

In written comments provided on a draft of this briefing, the Director of the Department of

Homeland Security’s GAO/OIG Liaison Office commented that departments and agencies 

are responsible for their own COOP plans. We agree and we clarified the briefing to reflect

this point. The Director also commented on recent actions FEMA has taken to fulfill its

responsibilities for executive branch continuity planning. The Director’s comments, however,

did not address FEMA’s responsibility to oversee and assess the status of COOP capability

across the federal executive branch, which is outlined in FPC 65. Finally, the Director 

identified recent guidance related to telework. However, none of the guidance addresses the 

preparations agencies should take to use telework effectively during an emergency.

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Background

Guidance

In 1988, Executive Order 12656 established policy for preparedness to address emergencies

that affect national security, including technological emergencies and natural disasters. The 

order identified the National Security Council as the agency responsible for developing and 

administering a national security emergency preparedness policy, with the assistance of

FEMA.

In October 1998, according to FEMA officials, PDD 67 established a requirement that

agencies have COOP plans in place by October 1999. It identified FEMA as the executive 

agent for federal COOP planning across the federal executive branch, responsible for 

formulating guidance for agencies to use in developing viable plans, coordinating interagency

exercises and facilitating interagency coordination as appropriate, and overseeing and 

assessing the status of COOP capabilities across the executive branch. FEMA's Office of

National Security Coordination executes these COOP responsibilities.

In July 1999, FEMA issued FPC 65 to assist agencies in meeting the deadline established by

the directive. The guidance stated that COOP planning should address any emergency or 

situation that could disrupt normal operations, including localized emergencies; thus, it 

extended the scope of the required planning beyond the national emergencies described in 

the Executive Order. The guidance included topic areas such as plans and procedures;

identification of essential functions; delegations of authority; orders of succession; alternate 

facilities; interoperable communications; vital records and databases; and tests, training, and 

exercises. In June 2004, FEMA released an updated version of FPC 65, providing additional 

guidance to agencies on each of the topics covered in the original guidance.

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Background

Guidance

FPC 65 states that agencies must identify essential functions and develop plans that ensure 

that these functions will resume within 12 hours of COOP activation and continue for up to 30 

days. The guidance states that the identification and prioritization of essential functions are 

prerequisites for continuity planning because these establish the parameters that drive the 

agency’s efforts in all other planning areas.

Furthermore, the guidance states that an agency must identify an alternate facility that

provides sufficient space for relocated personnel to perform agency essential functions. The 

guidance also directs agencies to identify the levels of staff and resources required at the 

alternate facility to support the performance of these functions. The identification of staff and

resources—including equipment, critical information systems and data, and vital records—

establishes the preparation requirements for an alternate facility. For example, in order for an 

agency to determine that it has an adequate number of computers present at the alternate 

facility, it must first establish how many are required to support personnel in the performance

of essential functions. Once critical resources are identified, pre-positioning them is

necessary to preparing an alternate facility.

The guidance requires agencies to review their alternate facilities for suitability and 

functionality. Tests and exercises allow specific aspects of COOP plans, procedures, and

facilities to be assessed, validated, or identified for subsequent correction. Periodic testing 

also ensures that equipment and procedures are maintained in a constant state of readiness.

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Background

Guidance

The guidance states that an agency must select an alternate facility and develop site

preparation and activation plans that provide the agency with the capability to perform its 

essential functions within 12 hours of COOP activation. The following bullets categorize key 

areas identified in FPC 65 that an agency must consider when selecting and preparing its 

alternate facility:

• Site selection. Before an agency selects a location for its alternate facility, it should

perform an all-hazard risk assessment for each facility considered to determine, among 

other things, any natural hazards that may affect the facility and the ability to secure the 

facility against crime, sabotage, and terrorist attacks. When selecting a location, an

agency should consider access to essential resources—such as food, water, and fuel—

from the alternate facility. Finally, the agency should be able to run emergency power at 

the facility.

• Facility plans and procedures. An agency must have detailed site preparation and 

activation plans in order to achieve full operational capability within 12 hours of

notification. An agency must have plans (1) for notifying its alternate facility upon COOP

activation of plans to relocate, (2) for reception and in processing of COOP personnel 

upon arrival, and (3) to address housing for the relocated personnel.

• Employee health, safety, security, and emotional well-being. An agency must

provide consideration for the health, safety, and emotional well-being of its relocating 

COOP personnel, and ensure that physical security at the alternate facility meets all

requirements established by annual threat assessments and physical security surveys.

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Background

Guidance

• Space. An agency should ensure that space at its alternate facility is adequate for 

supporting the number of relocating COOP personnel identified in the agency’s staffing 

plans.

• Equipment. An agency should identify the critical resources—including information 

technology (IT) and telecommunications equipment—needed to perform essential 

functions. An agency must pre-position critical resources at its alternate facility and have

procedures for ordering equipment not already in place.

• Vital records. Agency personnel must have access to electronic and hard-copy vital 

records and databases needed to perform the agency’s essential functions from the 

alternate facility. In order for an agency to establish access requirements for vital records

and databases at the alternate facility, it must develop a vital records inventory with

location and access information for each vital record.

• Voice and data communications. An agency must have redundant communications

providing the capability to communicate with key contacts, including agency staff, critical 

customers, and the public. It must also provide access to a local area network, electronic

vital records, critical information systems and data, and internal and external e-mail and

archives.

• Tests and exercises. An agency must conduct and document tests and exercises of its

COOP plans and procedures to ensure that, among other things, requirements at the

alternate facility are adequate for performing essential functions.

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Background

Previous GAO Reports

We previously reported on federal agency headquarters contingency plans in place in May

2004 at the request of the Chairman, House Committee on Government Reform.

1 At that

time, we determined that agencies had made progress in improving compliance with FPC 65,

but significant weaknesses remained. For example, only 3 out of the 45 agency COOP plans

we reviewed documented that their alternate facilities could provide previously identified 

equipment and space for COOP personnel responsible for performing essential functions. In

addition, only 8 out of 45 COOP plans we reviewed adequately documented that the 

agencies could provide interoperable communications from their alternate facilities with

internal and external organizations, critical customers, and the public.

During our previous reviews of agency COOP plans, we reported that insufficient oversight

by FEMA contributed to agencies’ lack of compliance with the continuity guidance.

Specifically, we noted that FEMA had not conducted an assessment of agency contingency

plans since 1999. In response, FEMA officials reported that they were developing a 

readiness reporting system—a system used to collect data from agencies on the readiness

of their continuity plans that would evaluate compliance with the guidance—which was to be 

completed in March 2005. The system was expected to be operational and certified by

October 2005, at which time there would be seven locations (including two FEMA locations)

using the system.

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

Emergencies, GAO-05-577 (Washington, D.C.: Apr. 28, 2005) and Continuity of Operations: Agency Plans Have Improved, 

but Better Oversight Could Assist Agencies in Preparing for Emergencies, GAO-05-619T (Washington, D.C.: Apr. 28, 2005).

Continuity of Operations
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Background

Telework

Telework, also referred to as telecommuting or flexiplace, has gained widespread attention 

over the past decade in both the public and private sectors as a human capital flexibility that

offers a variety of potential benefits to employers, employees, and society. In a 2003 report

to Congress on the status of telework in the federal government, the Director of OPM

described telework as “an invaluable management tool which not only allows employees 

greater flexibility to balance their personal and professional duties, but also allows both 

management and employees to cope with the uncertainties of potential disruptions in the 

workplace, including terrorist threats.”1 The 2005 OPM report on telework notes the 

importance of telework in responding flexibly to emergency situations, as demonstrated in

the wake of the devastation caused by Hurricane Katrina, when telework served as a tool to

help alleviate the issues caused by steeply rising fuel prices nationwide.2

1 OPM, Report to the Congress: The Status of Telework in the Federal Government (Washington, D.C.: January 2003). 2 OPM, Report to the Congress: The Status of Telework in the Federal Government (Washington, D.C.: 2005).

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Background

Telework

According to OPM’s guidance on Washington, D.C., area closures, one of the major benefits

of a telework program is the ability of employees to continue working at their alternative work

sites during a disruption to operations.

1 In recognition of the growing importance of

teleworkers to the continuity of agency operations, OPM states that agencies may require 

personnel to telework when the agency is closed. According to OPM guidance, telework

enabled employees to continue working after being displaced during events such as the 

terrorist attacks and subsequent anthrax problems of 2001.2

In November 2005, the White House issued a national strategy to address the threat of

pandemic influenza.

3 The strategy states that social distancing measures may be 

appropriate public health interventions for infection control and containment during a 

pandemic outbreak. Telework is an example of social distancing. The strategy requires

federal departments and agencies to develop and exercise preparedness and response

plans that take into account the potential impact of a pandemic on the federal workforce. It

also tasks the Department of Homeland Security (DHS)—the parent department of FEMA—

with developing plans to implement the strategy in regard to domestic incident management 

and federal coordination.

1 OPM, Washington, DC, Area Dismissal or Closure Procedures (Washington, D.C.: November 2005). 2 OPM, Telework: A Management Priority, A Guide for Managers, Supervisors, and Telework Coordinators (Washington, 

D.C.: May 2003). 3 Homeland Security Council, National Strategy for Pandemic Influenza (Washington, D.C.: Nov. 1, 2005).

Continuity of Operations
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Background

Telework

As we reported in April 2004, telework is an important and viable option for federal agencies

in COOP planning and implementation efforts, especially as the duration of an emergency

event is extended.1 In a July 2003 report, we defined 25 key telework practices for

implementation of successful federal telework programs.

2

In our April 2005 report on continuity of operations, we reported that although agencies were

not required to use telework in their continuity plans, 1 of the 21 agency continuity plans in

place on May 1, 2004, documented the agency’s intention to address some essential 

functions through telework.

3 In addition, 10 agencies reported that they intended to use 

telework following a COOP event, but those intentions were not documented in their 

continuity plans. The plans reviewed were created before the issuance of FEMA’s revised

continuity planning guidance, which includes the recommendation that agencies consider 

options such as work-at-home and virtual offices when establishing continuity plans.

1 GAO, Human Capital: Opportunities to Improve Federal Continuity Planning Guidance, GAO-04-384 (Washington, D.C.: Apr. 

20, 2004). 2 GAO, Human Capital: Further Guidance, Assistance, and Coordination Can Improve Federal Telework Efforts, GAO-03-679

(Washington, D.C.: July 18, 2003).

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

Emergencies, GAO-05-577 (Washington, D.C.: Apr. 28, 2005).

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Objective 1: Alternate Facilities Compliance

All six agencies we reviewed took steps to prepare their alternate facilities using practices

identified in the FPC 65 guidance. Agency use of these practices, which fall into the eight 

topic areas presented earlier, are presented in the following slides.

Among the eight areas, the extent to which agencies performed the practices varied. For 

example, most agencies documented plans and procedures related to their alternate 

facilities, including site preparation and activation plans. In contrast, none conducted all the 

applicable tests and exercises required by FPC 65, including annual exercises that

incorporate the deliberate and preplanned movement of COOP personnel to an alternate 

facility. Furthermore, agencies did not fully identify the levels of resources necessary to

support their essential functions.

Although individual agencies are responsible for developing a viable COOP plan and 

ensuring that their alternate facilities are adequately prepared, FEMA’s limited efforts in 

overseeing and assessing agency COOP capabilities contributed to agencies’ lack of

compliance with all of the FPC 65 guidance.

Continuity of Operations
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Committee on Government Reform 

Page 32 GAO-06-713

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Objective 1: Alternate Facilities Compliance

Site Selection

Site Selection

FPC 65 states that agencies must identify and prepare alternate facilities as part of their

COOP plans. The guidance requires that if the selected facility is not owned or leased by the 

agency, a signed memorandum of agreement/understanding (MOA/MOU) must be prepared 

with the owner or occupant of the facility and reviewed annually. Furthermore, agencies

should consider access from the alternate facility to essential resources—such as food, 

water, fuel, medical facilities, and municipal services. Agencies should also have the ability to

run emergency power at their alternate facilities. When selecting their alternate facilities,

agencies should perform an all-hazard risk assessment for any facility considered for COOP

use. This assessment should consist of an analysis that includes identification of all natural 

hazards that may affect each facility.

All six agencies identified their alternate facilities, and the one agency that shares its 

alternate facility with its owners had a documented MOA. Most agencies considered access

to essential resources and had the ability to run emergency power. However, only one of the

agencies documented that it had performed the required all-hazard risk assessments when 

selecting the identified alternate facilities. If an agency does not conduct an all-hazard risk

assessment before selecting a facility, it may select a site that is unduly susceptible to

(1) natural hazards; (2) accidents, such as releases of hazardous materials; (3) crime,

sabotage, and terrorist attacks; or (4) inadequate capabilities of on-site and/or local first

responders to accommodate the needs of the relocating agency.

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Objective 1: Alternate Facilities Compliance

Site Selection

Site Selection: Responses by Question

4 1 0 1a

Does the agency have the ability to run emergency power 

at the alternate facility to allow essential functions and

operations to continue?

5 1 0 0

Did the agency consider access to essential resources

such as food, water, fuel, medical facilities, and municipal

services from the alternate facility?

1 0 0 5

If an alternate facility is not owned or leased by the

agency, does the agency have a signed Memorandum of

Agreement/Understanding (MOA/MOU)?

1 2 3 0 Did the agency perform an all-hazard risk assessment for 

the alternate facility?

0

N/A

6 0 0

Does the agency identify an alternate facility as a part of

its COOP plan?

Question Yes Partial No

Source: GAO analysis of agency alternate facilities and continuity planning documents.

a One agency documented that it would relocate to its alternate facility selected for this assessment only if the building is 

operational; otherwise it would relocate to one of its other alternate facilities.

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Objective 1: Alternate Facilities Compliance

Facility Plans and Procedures

Facility Plans and Procedures

FPC 65 states that agencies must have detailed site preparation and activation plans in 

order to achieve full operational capability within 12 hours of notification. Additionally, the 

agency must plan for notifying the alternate facility upon COOP activation and provide 

instructions to COOP personnel for relocating to its alternate facility. Furthermore, an

agency must have plans for in-processing of COOP personnel upon arrival at the alternate 

facility and plans to address the housing of COOP personnel, if applicable.

Most agencies documented site preparation and activation plans and procedures, 

documented plans to notify their alternate facilities upon COOP activation, and provided

instructions for relocating to their alternate facilities. Most agencies also documented plans

for reception and in-processing of COOP personnel. Three agencies reported that housing 

plans were not applicable because their alternate facilities were at a commutable distance

for COOP personnel. Of the other three agencies, two documented plans to address

housing for the relocated employees.

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Objective 1: Alternate Facilities Compliance

Facility Plans and Procedures

Facility Plans and Procedures: Responses by Question

4 2 0 0 Does the agency have procedures for the reception and 

in-processing of personnel at the alternate facility?

2 1 0 3 Does the agency have a plan to address housing for 

COOP personnel, if applicable?

5 1 0 0 Does the agency provide instructions for relocating to

alternate facilities?

5 0 1 0 Does the agency have a plan for notifying alternate 

facilities at the time of COOP activation?

5 1 0 0

Does the agency have a site preparation and activation

plan pre-positioned at the alternate facility?

Question Yes Partial No N/A

Source: GAO analysis of agency alternate facilities and continuity planning documents.

Continuity of Operations
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Objective 1: Alternate Facilities Compliance

Employee Health, Safety, Emotional Well-being, and Security

Employee Health, Safety, Emotional Well-being, and Security

FPC 65 states that alternate facilities must provide consideration for the health, safety, 

emotional well-being, and security of relocated employees. The guidance calls for

agencies to have sufficient personnel and technology to provide perimeter and access

control, internal security functions, and surveillance of the facility. Physical security at the

alternate facility must meet the requirements established by annual threat assessments

and physical security surveys by the agency’s security office, the Federal Protective

Service, or a qualified contractor. 

All six agencies provided consideration for the health and safety of relocated COOP

personnel. For example, one agency’s alternate facility provided medical support on site

while another was equipped with first aid supplies. In addition, the six agencies provided 

consideration for the emotional well-being of relocated COOP personnel. For example, 

one agency’s facility included an employee assistance program office staffed with

counselors, while another provided a recreation area for off-shift relaxation.

At all six agency alternate facilities that we visited, physical access to the facilities was 

controlled through the use of guards, identification badges, or entry devices such as key

cards. Three agencies documented that they had conducted all of the required physical 

security surveys and threat assessments. If an agency does not conduct the necessary

physical security assessments and surveys, it may be unaware of vulnerabilities at its

alternate facility and, therefore, unable to address them.

Continuity of Operations
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Objective 1: Alternate Facilities Compliance

Employee Health, Safety, Emotional Well-being, and Security

Employee Health, Safety, Emotional Well-being, and Security: Responses by Question

6 0 0 0

Is access to facilities controlled through the use of guards, 

identification badges, or entry devices such as key cards

or biometrics?

6 0 0 0 Does the agency provide consideration for the health and 

safety of relocated COOP personnel?

6 0 0 0 Does the agency provide consideration for the emotional

well-being of relocated COOP personnel?

0

N/A

3 3 0

Does the agency provide physical security that meets all

requirements established by annual threat assessments

and physical security surveys?

Question Yes Partial No

Source: GAO analysis of agency alternate facilities and continuity planning documents.

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Objective 1: Alternate Facilities Compliance

Space

Alternate Facility Space

FPC 65 requires agencies to establish staffing requirements needed to perform essential

functions within 12 hours of COOP activation and for up to 30 days. In addition, the 

guidance states that agencies must ensure that alternate facilities have enough space to

accommodate the maximum number of relocating personnel they require.

All six agencies identified the maximum number of COOP personnel that could relocate to

their alternate facilities. Four of those agencies provided adequate space to accommodate 

the maximum number of staff indicated in their staffing plans. The other two agencies did 

not provide enough space at their alternate facilities to accommodate all of the relocating 

COOP personnel. Officials from those two agencies stated that the number of COOP

personnel simultaneously relocating to their facilities would be less than the maximum 

number of personnel identified, although they were unable to provide documentation to

support this.

If agencies do not establish clear staffing requirements for their alternate facilities, the

allocated space at the facilities may be insufficient to accommodate COOP personnel 

needed to perform agency essential functions.

Continuity of Operations
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Objective 1: Alternate Facilities Compliance

Space

Alternate Facility Space: Responses by Question

4 2 0 0

Does the agency identify sufficient space at the alternate 

facility to accommodate the number of personnel 

identified to relocate there?

6 0 0 0

Does the agency identify the maximum number of

personnel that could relocate to the alternate facility?

Yes Partial No N/A Question

Source: GAO analysis of agency alternate facilities and continuity planning documents.

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Objective 1: Alternate Facilities Compliance

Equipment

Equipment

FPC 65 requires that agencies identify the critical resources—including IT and 

telecommunications equipment—needed to perform essential functions. Agencies must

pre-position critical resources at the alternate facility to ensure the availability of services.

In addition, agencies should (1) have procedures for ordering equipment and supplies not

already in place at the alternate facility and (2) annually review their lists of resources

required to perform essential functions and update them as necessary.

All six agencies identified types of equipment they would need to perform essential 

functions at their alternate facilities, but four agencies did not identify both types and

quantities. For example, one agency required computers at its facility but did not specify

how many. Because of the unclear requirements for the four agencies, we were unable to

determine whether all necessary resources were pre-positioned at their facilities. In

addition, four agencies had procedures for ordering equipment and supplies, and one

agency demonstrated that it annually reviewed its lists of equipment. If an agency does

not identify equipment requirements for the alternate facility, it cannot be assured that the 

current level of resources present at its alternate facility is adequate for performing the 

essential functions.

Continuity of Operations
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Objective 1: Alternate Facilities Compliance

Equipment

Equipment: Responses by Question

2 3 1 0 Does the agency identify the office supplies needed to

perform essential functions?

2 — — — Has the agency pre-positioned equipment, as identified, at 

the alternate facility?a

4 2 0 0 Does the agency have procedures for ordering equipment 

and supplies not already in place at the alternate facility?

1 0 5 0

Does the agency annually review its lists of equipment 

required to perform essential functions and update them

as necessary? 

2 4 0 0

Does the agency establish requirements for equipment 

(including IT and telecommunications hardware) needed

to perform essential functions?

Question Yes Partial No N/A

a 4 of the 6 agencies did not document specific requirements for pre-positioned equipment, so we could not assess their 

compliance for this question.

Source: GAO analysis of agency alternate facilities and continuity planning documents.

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Objective 1: Alternate Facilities Compliance

Vital Records

Vital Records

FPC 65 states that agency personnel must have access to electronic and hard-copy vital 

records and databases needed to perform their essential functions from the agency alternate

facility. In order for an agency to establish access requirements for vital records and

databases at the alternate facility, it must develop a vital records inventory with location and

access information for each vital record. The guidance also states that an agency must

develop and maintain a vital records plan packet that includes—among other items—agency

contact information, lists of records recovery experts and vendors, and its vital records 

inventory.

One of the six agencies maintained an inventory that included location and access

information for each vital record and database required to perform essential functions at the 

alternate facility. For the remaining five agencies, which lacked complete inventories, we

could not fully assess whether the necessary electronic and hard copy vital records would be 

available at the facilities. Furthermore, only one out of the six agencies had a complete vital

records plan packet at its alternate facility. If an agency does not maintain a complete

inventory of the vital records and databases needed to perform essential functions, it will be 

unable to determine whether the records necessary for performing agency essential 

functions will be available at the alternate facility.

Continuity of Operations
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Objective 1: Alternate Facilities Compliance

Vital Records

Vital Records: Responses by Question

1 5 0 0

Does the agency establish requirements for vital records 

and databases needed to support its essential functions 

in an inventory that includes location and access 

information?

1 — — —

Does the agency provide the capability to access its 

classified and unclassified vital records and databases

from the alternate facility?a

0

0

N/A

2 1 3

Does the agency provide the procedures for moving nonpre-positioned vital records from the primary to the 

alternate facility in event of COOP activation?

Does the agency have a vital records plan packet? 1 4 1

Yes Partial No Question

a 5 of the 6 agencies did not adequately document requirements for vital records and databases, so we could not assess their 

compliance for this question.

Source: GAO analysis of agency alternate facilities and continuity planning documents.

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Objective 1: Alternate Facilities Compliance

Vital Records

Vital Records: Responses by Question (continued)

0

0

0

N/A

3 0 3 Does the agency identify individuals that can assist with 

recovery from potential records damage?

1 0 5 Did the agency conduct a risk assessment for its vital

records?

2 3 1

Does the agency outline procedures for updating vital

records to ensure that they always contain the most 

current information?

Yes Partial No Question

Source: GAO analysis of agency alternate facilities and continuity planning documents.

Continuity of Operations
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2006, Briefing to Staff of the House 

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38

Objective 1: Alternate Facilities Compliance

Voice and Data Communications

Voice and Data Communications

The success of agency operations at an alternate facility depends on the availability of voice 

and data communication methods. FPC 65 states that an agency must have redundant

communications systems at its alternate facility. Furthermore, an agency must have the

ability to communicate with key contacts, including (1) agency staff—such as COOP

personnel, agency leadership, and other employees operating from different locations—and 

(2) external entities, such as the FEMA Operations Center, the Homeland Security

Operations Center, critical customers, and the public. The guidance also states that an

agency must be able to access from its alternate facility its critical information systems and

data, a local area network, and internal and external e-mail and archives.

Continuity of Operations
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2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 46 GAO-06-713

39

Objective 1: Alternate Facilities Compliance

Voice and Data Communications

Although most agencies provided redundant emergency communications methods at their 

alternate facilities, four agencies did not fully document procedures for how they would 

communicate with key internal and external entities using these methods. For example, two 

agencies provided information on how to contact others but did not have clear procedures

demonstrating how they would receive incoming communications at their alternate facilities. 

In addition, three out of the six agencies did not specifically document the data and critical

information systems needed for essential functions. For example, one agency identified a 

general need for access to file servers, but did not identify the specific critical information 

systems and data within the servers. As a result, we were unable to determine whether all 

necessary systems and data would be accessible from the alternate facilities. Most agencies 

provided access to a local area network, and two provided access to internal and external email and archives.

If the ability to communicate with internal and external entities is limited, essential agency

operations may also be limited. Furthermore, if agencies do not identify the critical

information systems and data needed to perform essential functions, they cannot ensure that

personnel will be able to access the information resources necessary to perform these 

functions at the alternate facility.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 47 GAO-06-713

40

Objective 1: Alternate Facilities Compliance

Voice and Data Communications

Voice and Data Communications: Responses by Question

3 2 1 0

Does the agency establish requirements for data and 

critical information systems needed to conduct essential

functions and support activities?

— 1 2 — Does the agency provide access to critical information

systems and data within 12 hours of COOP activation?a

4 2 0 0 Does the agency provide access to a local area network 

within 12 hours of COOP activation?

2 2 2 0 Does the agency provide access to internal and external

e-mail and archives within 12 hours of COOP activation?

5 1 0 0

Does the agency provide redundant communications 

systems for use in COOP implementation within 12 hours 

of COOP activation and sustained for up to 30 days?

0

N/A

2 4 0

Does the agency provide communications capabilities at 

the alternate facility of sufficient quantity and mode/media

to effectively interface with key contacts?

Question Yes Partial No

Source: GAO analysis of agency alternate facilities and continuity planning documents.

a 3 of the 6 agencies did not adequately document requirements for critical information systems and data, so we could not 

assess their compliance for this question.

Continuity of Operations
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Committee on Government Reform 

Page 48 GAO-06-713

41

Objective 1: Alternate Facilities Compliance

Tests and Exercises

Tests and Exercises

Tests and exercises of continuity of operations capabilities are essential to demonstrate and

improve an agency’s ability to execute its COOP plans and procedures. FPC 65 provides for 

multiple test and exercise requirements that directly impact the preparedness of agency

alternate facilities, including (1) annual exercises that incorporate the deliberate and

preplanned movement of the COOP personnel to an alternate facility; (2) quarterly validation 

of internal and external communications capabilities at an alternate facility; and (3) tests to

ensure that vital records and data to support essential functions are sufficient, complete,

current, and available at an alternate facility.

None of the agencies documented that they conducted all of the required tests and exercises 

related to the preparation of alternate facilities that are required by FPC 65, including 

annually testing primary backup infrastructure systems and services at the alternate facilities.

If an agency does not plan, conduct, and document the necessary tests and exercises of its

COOP plans and procedures, it will be unable to ensure that (1) agency personnel are 

familiar with alert, notification, and deployment procedures; (2) resource requirements at the 

alternate facility are adequate for performing essential functions; and (3) any deficiencies in 

their plans and procedures are identified and corrected.

Continuity of Operations
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2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 49 GAO-06-713

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Objective 1: Alternate Facilities Compliance

Tests and Exercises

Tests and Exercises: Responses by Question

0 2 4 0 Does the agency test to ensure that vital records and data

are sufficient, complete, current, and available?

0 2 4 0

Does the agency test annually its primary and backup 

infrastructure systems and services at its alternate facility

(e.g., power, water, fuel)?

0 5 1 0

Does the agency conduct annual exercises that 

incorporate the deliberate and preplanned movement of

the COOP personnel to an alternate facility?

0

0

N/A

0 4 2

Has the agency documented the quarterly validation of its 

internal and external communications capabilities at its

alternate facility?

3 0 3 Does the agency annually test/exercise its required

physical security capabilities?

Question Yes Partial No

Source: GAO analysis of agency alternate facilities and continuity planning documents.

Continuity of Operations
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2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 50 GAO-06-713

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Objective 1: Alternate Facilities Compliance

Readiness Reporting System

Although individual agencies are responsible for developing a viable COOP plan and 

ensuring that their alternate facilities are adequately prepared, FEMA’s limited efforts in 

overseeing and assessing agency COOP capabilities contributed to agencies’ lack of

compliance with all of the FPC 65 guidance. For example, FEMA has continued to rely on 

agency-reported information as the basis for its assessments. According to DHS comments

on a draft of this briefing, FEMA uses its Forward Challenge series of interagency COOP

exercises, which occur every 2 years, as its external assessment for all executive branch

agencies. However, participating agencies completed assessments of their own COOP 

capabilities during the most recent exercise. In addition, FEMA collects COOP readiness 

status reports from agencies and provides consolidated reports to White House and DHS

officials.

During our previous reviews of agency COOP plans in 2002 and 2004, we raised similar 

concerns. In response, FEMA officials reported that the agency was developing a readiness

reporting system to assist it in assessing agency plans. FEMA officials reported that the 

online system was to be completed in March 2005 and to be operational and certified by

October 2005.

However, FEMA recently terminated testing and development of its readiness reporting 

system, citing design issues and stating that the system could not be implemented at the 

required scale. According to Office of National Security Coordination officials, an internal 

working group was established to develop system requirements and a new statement of

work, although no time line has been established for development of a new system.

Continuity of Operations
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2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 51 GAO-06-713

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Objective 1: Alternate Facilities Compliance

Interagency Tests and Exercises

FEMA officials previously identified the agency’s coordination of interagency COOP

exercises as an effort that helps in ensuring the COOP readiness and capabilities of

executive branch agencies. According to officials from the Office of National Security

Coordination, the agency coordinated Determined Challenge, an interagency table-top 

exercise conducted in November 2005 that included participants from 46 departments and

agencies. FEMA also continues its planning efforts for Forward Challenge 06, its upcoming 

interagency exercise in June 2006. Officials stated that about 60 departments and agencies

will participate in the exercise from their alternate facilities. Officials anticipate using

independent observers to evaluate agency plans and their implementation during the 

exercise.

Although participation in FEMA’s interagency exercises can help agencies to assess and 

validate their COOP plans and procedures, it does not ensure that agencies meet all FPC 65

requirements for tests and exercises. For example, the guidance calls for agency exercises

to incorporate the movement of COOP personnel to their alternate operating facilities, and 

for these exercises to be conducted annually. However, FEMA coordinates such exercises

only every 2 years.

1

1 Forward Challenge 06 and its predecessor, Forward Challenge 04, are examples of exercises that can incorporate the 

movement of COOP personnel to agency alternate facilities.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 52 GAO-06-713

45

Objective 1: Alternate Facilities Compliance

Essential Function Review

We previously reported that the White House initiated an effort—in coordination with

FEMA—to identify and validate the mission essential functions of executive branch agencies.

In a memorandum issued on January 10, 2005, the Assistant to the President for Homeland 

Security initiated the process, stating that once identified, mission essential functions would 

serve as key continuity planning factors for agencies’ determination of the appropriate level 

of staffing, communications, and facilities. Initial plans were to use the validated functions to

support, among other things, the development of new continuity policy and to develop and 

implement improved requirements.

However, officials from FEMA’s Office of National Security Coordination stated that oversight

efforts to review agency essential functions were postponed until the council develops and 

releases further continuity policy. One official stated that the council informally reviewed 

essential functions for four agencies before the postponement, but did not provide formal 

written comments or revisions of essential functions to the agencies. No time line has been 

set for resuming the essential function review. 

Identification of essential functions is crucial to the development of continuity plans and 

preparation of alternate facilities. Thus, until essential functions are reviewed and validated 

against consistent criteria, FEMA and the Homeland Security Council will lack assurance that

agencies have made adequate preparations for alternate facilities, including provisions for 

necessary resources and staffing levels.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 53 GAO-06-713

46

Objective 1: Alternate Facilities Compliance

FEMA COOP Oversight Plan

In his comments on a draft of this briefing, the Director of the Department of Homeland 

Security’s GAO/OIG Liaison Office stated that FEMA has plans to expand its COOP

oversight activities to include the evaluation and assessment of individual agency COOP

capabilities. He added that, as part of the methodology for the upcoming interagency

exercise, Forward Challenge 06, agency COOP plans will be externally evaluated before the 

exercise. In addition, officials plan to conduct individual agency COOP assessments starting

in July 2006. These assessments will include the evaluation of, among other things, agency

COOP plans and procedures; essential functions; alternate facilities; and tests, training, and

exercises. FEMA officials plan to conduct two agency assessments per month, with

assessment reports to be provided beginning in late August 2006. However, according to an 

Office of National Security Coordination official, details regarding the assessment’s 

methodology have yet to be finalized.

Conducting assessments of agency COOP capabilities can help agencies validate their plans

and procedures and identify any deficiencies for correction. However, if FEMA does not

develop a methodology for individual agency COOP assessments that evaluates agencies’ 

compliance with FPC 65—including the extent to which they (1) identify essential functions,

(2) identify the levels of staff and resources required at their alternate facilities, and (3) plan,

conduct, and document the necessary tests and exercises at the appropriate scope and 

frequency—it will lack assurance that agencies have taken the steps necessary to ensure 

that they will be able to perform essential government operations following a disruption.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 54 GAO-06-713

47

Objective 2: Telework

More agencies reported plans for essential team members to telework during a COOP event

than in our previous survey, but few documented that they had made the necessary

preparations to effectively use telework during an emergency. Although FPC 65 does not

require agencies to use telework during a COOP event, it does state that they should 

consider the use of telework in their continuity plans and procedures. All of the 23 agencies 

that we surveyed indicated that they considered telework as an option during COOP

planning. In addition:

• Nine of the 23 agencies reported that some of their COOP essential team members are 

expected to telework during a COOP event. However, only one agency documented that

it had notified its team members of their expectation to telework during a COOP event.

• None of the 23 agencies demonstrated that they can ensure adequate technological 

capacity to allow designated personnel to telework during a COOP event.

• Only 3 of the 23 agencies documented testing the ability of staff to telework during a

COOP event. 

Reasons cited for not planning to use telework during a COOP event included (1) the need to

access classified information—which is not permitted outside of secured areas—in order to

perform agency essential functions and (2) a lack of funding for the necessary equipment

acquisition and network modifications.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 55 GAO-06-713

48

Objective 2: Telework

Telework Practices

Source: Analysis of agency responses to GAO questions.

a Agencies provided a positive response but did not provide adequate documentation to support their response. b In 2004, one agency did not respond, resulting in a total of 22 responses for that year versus 23 responses for 2005.

Was the agency’s telework coordinator involved in COOP 2005 1 14 8

planning? 2004 0 6 16

Does the agency coordinate its COOP and telework planning 2005 4 13 6

processes? 2004 0 5 17

2004 2 1 19

2005 12 3 8

Does the COOP plan specifically address telework?

2004 1 2 19

2005 2 6 15

If yes, does the policy specifically address COOP events? 

2004b 19 3 0

2005 22 1 0

Does the agency have a telework policy?

No

Yesa

Year Yes (no doc) Question

Telework: Responses by Question

The following tables summarize the most recent agency responses to questions on the use 

of telework in responding to disruptions to operations. For comparison, we also provide 

responses from the survey we conducted in 2004.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 56 GAO-06-713

49

Objective 2: Telework

Telework Practices

Telework: Responses by Question (cont’d)

Has the agency tested the ability of staff to telework during 2005 3 7 13

a COOP event? 2004 0 2 20

Did the agency train staff how to telework during a COOP 2005 0 13 10

event? 2004 0 3 19

Has the agency ensured that it has adequate technological 2005 0 14 9

capacity for staff to telework during a COOP event? 2004 0 5 17

Will the agency provide technological assistance to staff 2005 3 11 9

during a COOP event? 2004 0 5 17

2004 1 3 18

Were staff informed of their responsibility to telework 2005 1 10 12

during a COOP event?

2004 1 2 19

Are any of the COOP essential team members expected to 2005 3 6 14

telework in a COOP event?

No

Yesa

Question Year Yes (no doc)

Source: Analysis of agency responses to GAO questions.

a Agencies provided a positive response but did not provide adequate documentation to support their response.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 57 GAO-06-713

50

Objective 2: Telework

Telework Practices

Telework: Responses by Question (cont’d)

Source: Analysis of agency responses to GAO questions.

a Agencies provided a positive response but did not provide adequate documentation to support their response.

Did the agency train staff how to telework during a COOP 2005 0 4 19

event? 2004 0 1 21

Has the agency tested the ability of staff to telework during 2005 0 4 19

a COOP event? 2004 0 3 19

2004 0 5 17

Will the agency provide technological assistance to staff 2005 0 7 16

during a COOP event?

2004 0 7 15

Has the agency ensured that it has adequate technological 2005 0 8 15

capacity for staff to telework during a COOP event?

2004 0 3 19

Were staff informed of their responsibility to telework 2005 1 5 17

during a COOP event?

2004 0 7 15

Are any personnel not designated essential for COOP 2005 0 11 12

purposes expected to telework during an emergency?

No

Yesa

Question Year Yes (no doc)

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 58 GAO-06-713

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Objective 2: Telework

Telework Guidance

No guidance addresses the steps that agencies should take to ensure that they are fully

prepared to use telework during a COOP event. When we reported the results of our 2004 

survey, we recommended that the Secretary of Homeland Security direct the Under 

Secretary for Emergency Preparedness and Response to develop, in consultation with OPM,

guidance on the steps that agencies should take to adequately prepare for the use of

telework during a COOP event. However, to date, no such guidance has been created nor 

has a time line been established for its creation.

FEMA recently disseminated guidance to agencies regarding the incorporation of pandemic

influenza considerations into COOP planning. While the guidance does suggest the use of

telework during such an event, it does not address the steps agencies should take when 

preparing to use telework during an emergency.

Without guidance on what constitutes adequate preparation, including tests and training,

agencies are unlikely to take all the steps necessary to ensure that employees will be able to 

effectively use telework to perform essential functions during any COOP event, including an

influenza pandemic.

Continuity of Operations
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Committee on Government Reform 

Page 59 GAO-06-713

52

Conclusions

All six agencies we reviewed took steps to prepare their alternate facilities for use in

emergencies. However, none of the agencies followed all of FEMA’s guidance. For example,

none conducted all the applicable tests and exercises required by FPC 65, including annual

exercises that incorporate the deliberate and preplanned movement of COOP personnel to

an alternate facility. Furthermore, agencies did not fully identify the levels of resources 

necessary to support their essential functions, creating a lack of assurance that their facilities 

are adequately prepared to support agency essential functions.

Although individual agencies are responsible for developing viable COOP capabilities,

FEMA’s limited oversight contributed to the lack of agency compliance with all of the FPC 65 

guidance for alternate facilities. FEMA recently announced plans to expand its assessments

of individual agency COOP plans, but has not yet determined how these new assessments 

will take place. If FEMA does not conduct timely assessments of the plans developed by the 

six agencies included in our review, it will lack assurance that those agencies are fully

prepared to use the upcoming interagency exercise to demonstrate their readiness. Also,

until FEMA conducts independent assessments of all agencies’ compliance with FPC 65—

including the extent to which agencies (1) identify essential functions, (2) identify the levels of

staff and resources required at their alternate facilities, and (3) plan, conduct, and document

the necessary tests and exercises at the appropriate scope and frequency—it will lack

assurance that agencies have taken the steps necessary to ensure that they will be able to

perform essential government operations following a disruption.

Continuity of Operations
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Committee on Government Reform 

Page 60 GAO-06-713

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Conclusions

After the 2004 version of FPC 65 was issued, which included a requirement to consider the

use of telework, more agencies than in our previous survey reported plans to use telework to 

some extent during COOP events. However, although some of these agencies reported 

making related preparations, the general lack of documentation to support their responses 

indicates that few are likely to have fully implemented the telework preparations that we have

previously found to be effective. Although FEMA recently provided additional guidance on the

use of telework, it did not address the steps agencies should take to prepare to use telework

during an emergency event, nor has a time line been established for when such guidance

may be written. Without guidance on what constitutes adequate preparation for using 

telework during an emergency situation, it will be difficult for agencies to identify and perform 

the necessary steps to ensure that their teleworking staff will be able to perform essential 

functions during a COOP event.

Continuity of Operations
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2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 61 GAO-06-713

54

Recommendations for Executive Action

To ensure that agencies are adequately prepared to continue performing essential functions

following an emergency, we recommend that the Secretary of Homeland Security direct the 

FEMA Director to improve the oversight of agency COOP planning by taking the following 

actions:

• Before the upcoming interagency exercise, conduct an assessment of the COOP plans of

the six agencies whose alternate facilities were included in our review and report any

deficiencies found to the head of the agency for correction.

• Develop a methodology for individual agency COOP assessments that independently 

evaluates executive branch agencies’ compliance with FPC 65, including the extent to

which agencies (1) identify essential functions; (2) identify the levels of staff and

resources required at their alternate facilities; and (3) plan, conduct, and document the 

necessary tests and exercises at the appropriate scope and frequency. The methodology

should include a mechanism for reporting any deficiencies found to the head of the

agency for correction.

• Establish a time line for developing, in consultation with OPM, guidance on the steps that

agencies should take to adequately prepare for the use of telework during a COOP event.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 62 GAO-06-713

55

Agency Comments and Our Evaluation

In written comments provided on a draft of this briefing, the Director of the Department of

Homeland Security’s GAO/OIG Liaison Office stated that continuity planning is the 

responsibility of individual departments and agencies. We agree and we clarified our draft to

more clearly identify the responsibility of agencies for their own continuity planning. The

Director also identified actions that FEMA had taken to fulfill its responsibilities for

coordination, guidance and advice, support, and periodic assessment of agency continuity

planning. However, the list of responsibilities provided by the Director excludes the 

responsibility to oversee and assess the status of COOP capability across the federal

executive branch, which is outlined in FPC 65. We revised our briefing to emphasize our 

conclusion that FEMA’s ongoing reliance on self-reported information from the departments

and agencies constitutes a limited level of oversight that contributes to the lack of full

compliance with FEMA’s continuity planning guidance.

The Director also identified recently published guidance on telework, as well as FEMA’s

guidance to agencies regarding continuity considerations for pandemic influenza. We 

updated our briefing to include these recent developments. However, neither the guidance

issued by FEMA nor the additional telework guidance addresses the preparations necessary

for agencies to ensure that they are prepared to use telework following a COOP event.

Continuity of Operations
Appendix I: Unclassified Version of April 13, 

2006, Briefing to Staff of the House 

Committee on Government Reform 

Page 63 GAO-06-713

56

Attachment 1: Agencies Participating in Telework Survey

Department of Agriculture

Department of Commerce

Department of Education

Department of Energy

Department of Health and Human Services

Department of Homeland Security

Department of Housing and Urban Development

Department of Justice

Department of Labor

Department of State

Department of the Interior

Department of the Treasury

Department of Transportation

Department of Veterans Affairs

Agency for International Development

Environmental Protection Agency

General Services Administration

National Aeronautics and Space Administration

National Science Foundation

Nuclear Regulatory Commission

Office of Personnel Management

Small Business Administration

Social Security Administration

Continuity of Operations
Appendix II: Comments from the Department Appendix II: Comments from the Department of Homeland Security

of Homeland Security 

Page 64 GAO-06-713 Continuity of Operations
Appendix II: Comments from the Department 

of Homeland Security

Page 65 GAO-06-713 Continuity of Operations
Appendix II: Comments from the Department 

of Homeland Security

Page 66 GAO-06-713 Continuity of Operations
Appendix II: Comments from the Department 

of Homeland Security

(310759) Page 67 GAO-06-713 Continuity of Operations
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