United States Government Accountability Office

GAO Testimony

Before the Committee on Government 

Reform, House of Representatives 

CONTINUITY OF 

OPERATIONS 

For Release on Delivery 

Expected at 10:00 a.m. EDT 

Thursday, May 11, 2006

Agencies Could Improve 

Planning for Telework 

during Disruptions 

Statement of David M. Walker 

Comptroller General of the United States 

GAO-06-740T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

May 11, 2006

CONTINUITY OF OPERATIONS 

Agencies Could Improve Planning for 

Highlights of GAO-06-740T, a testimony Telework during Disruptions 

before the 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 providing

guidance to agencies on developing

such plans. Its guidance states that

in their continuity planning, 

agencies should consider the use of

telework—that is, work performed

at an employee’s home or at a work 

location other than a traditional 

office. The Office of Personnel

Management (OPM) recently

reported that 43 agencies have

identified staff eligible to telework, 

and that more than 140,000 federal 

employees used telework in 2004. 

OPM also reported that many 

government operations can be

carried out in emergencies using 

telework. For example, telework

appears to be an effective strategy

for responding to a pandemic—a 

global outbreak of disease that 

spreads easily from person to

person and causes serious illness 

and death worldwide. In previous 

work, GAO identified steps that 

agencies should take to effectively 

use telework during an emergency. 

GAO was asked to testify on how 

agencies are addressing the use of

telework in their continuity 

planning, which is among the 

topics discussed in a report being 

released today (GAO-06-713). 

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 to 3 in GAO’s previous survey. 

However, few documented that they made the necessary preparations to 

effectively use telework during such an event. For example, only 1 agency

documented that it had communicated this expectation to its emergency 

team members. One reason for the low levels of preparations reported is that 

FEMA has not provided specific guidance on preparations needed to use 

telework during emergencies. 

Recently, FEMA disseminated guidance to agencies on incorporating 

pandemic influenza considerations into COOP planning. Although this 

guidance suggests 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 specific guidance, agencies are unlikely to 

adequately prepare their telework capabilities for use during a COOP event. 

In addition, inadequate preparations could limit the ability of nonessential 

employees to contribute to agency missions during extended emergencies, 

including pandemic influenza. 

In its report released today, GAO recommends, among other things, that 

FEMA establish a time line for developing, in consultation with the OPM, 

guidance on preparations needed for using telework during a COOP event. In

commenting on a draft of the report, DHS partially agreed with GAO’s 

recommendation and stated that FEMA will coordinate with OPM in 

developing a time line for further telework guidance. DHS also stated that 

both FEMA and OPM have provided telework guidance. However, as GAO’s 

report stated, present guidance does not address the preparations federal

agencies should make for using telework during emergencies. 

On May 3 the White House announced the release of an Implementation Plan 

in support of the National Strategy for Pandemic Influenza. This plan calls 

on OPM to work with DHS and other agencies to revise existing telework 

guidance and issue new guidance on human capital planning and COOP. The 

plan establishes an expectation that these actions will be completed within 3 

months. If the forthcoming guidance does not require agencies to make 

necessary preparations for telework, agencies are unlikely to take all the 

steps necessary to ensure that employees will be able to effectively use 

telework to perform essential functions in extended emergencies, such as a

pandemic influenza. 

www.gao.gov/cgi-bin/getrpt?GAO-06-740T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Linda D. 

Koontz at (202) 512-6240 or

koontzl@gao.gov. 
Mr. Chairman and Members of the Committee: 

I appreciate the opportunity to participate in the Committee’s 

hearing on pandemic influenza and continuity of operations (COOP) 

planning. As you know, essential government services can be 

interrupted by a range of events, including terrorist attacks, severe 

weather, building-level emergencies, and public health emergencies, 

such as pandemic influenza. The federal government requires 

agencies to develop plans for ensuring the continuity of essential 

services during such emergencies. To assist agencies, the Federal 

Emergency Management Agency (FEMA), within the Department of 

Homeland Security (DHS), which is responsible for managing 

federal response and recovery efforts following any national 

incident, has issued guidance that defines the elements of a viable 

COOP capability. 

A potentially useful option for continuity planning is telework (in 

which work is performed at an employee’s home or at a work 

location other than a traditional office); this alternative 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 

December 2005 report to Congress, the Office of Personnel 

Management (OPM) indicated that 43 of the 82 federal agencies it 

surveyed had employees eligible to telework during 2004, and more 

than 140,000 federal employees used telework that year.1

OPM also reported that there is a symbiotic relationship between 

COOP and telework because many government functions that must 

be carried out in emergencies can be accomplished using telework.

Similarly, we reported in April 2004 that 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

 This option appears particularly appropriate in 

 1

 OPM, The Status of Telework in the Federal Government 2005 (Washington, D.C.: Dec.

2005) 

2

 GAO, Human Capital: Opportunities to Improve Federal Continuity Planning

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

Page 1 GAO-06-740T
the case of pandemic influenza, which occurs when an influenza 

virus causes an outbreak of disease that spreads easily from person 

to person and results in serious illness worldwide. Experts believe 

that the effects of a pandemic could come in waves that last for 

weeks or even months, in which time absentee rates could reach 40 

percent during peak periods due to illness, the need to care for 

family members, and fear of infection. Recent executive branch

guidance states that social distancing measures, such as telework, 

may be appropriate public health interventions for infection control 

and containment during a pandemic outbreak. 

GAO recognizes the importance of telework and continuity planning 

and is striving to lead by example on these issues. For example, 

during certain emergencies, our current telework policy allows me 

to approve telework for all employees in an affected area to 

promote continuity of operations. We are also completing a 

supplement to our COOP plan that addresses preparations specific 

to a pandemic, and are coordinating our continuity planning efforts 

with those of other legislative branch agencies. 

As you requested, I will discuss how agencies are addressing the use 

of telework in their continuity planning, based on work described in 

a report that we are issuing today.3

 In earlier work, we identified 

steps agencies that should take to effectively use telework during an 

emergency, and we surveyed agency officials responsible for 

continuity planning at 23 major agencies.4

 For this report, we 

repeated this survey to obtain updated information on the extent to 

which key telework practices were used in making continuity 

preparations. We reviewed documentation submitted by agency 

officials to support their survey responses and compared these 

responses to those from our earlier work; we briefed your staff on

the results of our work on April 13, 2006. This work was conducted 

 3

 GAO, Continuity of Operations: Selected Agencies Could Improve Planning for Use of

Alternate Facilities and Telework during Disruptions, GAO-06-713 (Washington, D.C.: 

May 11, 2006). 

4

 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). 

Page 2 GAO-06-740T
in accordance with generally accepted government auditing 

standards. 

Results in Brief 

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 a COOP event. However, 

only one agency documented that it had notified its team members 

of the expectation that they would telework during such an event. 

● None of the 23 agencies demonstrated that it could ensure adequate 

technological capacity to allow designated personnel to telework 

during an emergency. 

● Only 3 of the 23 agencies documented testing the ability of staff to 

telework during an emergency. 

FEMA’s guidance on COOP planning does not include specific 

information on preparations to use telework during emergencies; 

the absence of such specific guidance contributed to the low levels 

of preparations that agencies reported. Recently, FEMA 

disseminated additional guidance to agencies regarding the 

incorporation of pandemic influenza considerations into COOP 

planning. Although this guidance suggests 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. 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, including pandemic influenza events.

In our report, we recommended, among other things, that FEMA 

establish a time line for developing, in consultation with OPM, 

guidance on preparations needed for using telework during a COOP 

event. In commenting on a draft of this report, DHS partially agreed

Page 3 GAO-06-740T
with our recommendation and stated that FEMA will coordinate 

with OPM in the development of a time line for telework guidance. 

Background 

Federal operations and facilities have been disrupted by a range of 

events, including the terrorist attacks on September 11, 2001; the 

Oklahoma City bombing; localized shutdowns due to severe weather 

conditions, 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. In addition, federal 

operations could be significantly disrupted by people-only events, 

such as an outbreak of severe acute respiratory illness (SARS). Such 

disruptions, particularly if prolonged, can lead to interruptions in 

essential government services. Prudent management, therefore, 

requires that federal agencies develop plans for dealing with 

emergency situations, including maintaining services, ensuring 

proper authority for government actions, and protecting vital assets. 

Until relatively recently, continuity planning was generally the 

responsibility of individual agencies. In October 1998, Presidential 

Decision Directive (PDD) 67 identified FEMA—which is responsible 

for leading the effort to prepare the nation for all hazards and 

managing federal response and recovery efforts following any 

national incident—as the lead 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 issued the first version of Federal Preparedness 

Circular (FPC) 65, its guidance to the federal executive branch on 

developing viable and executable contingency plans that facilitate 

the performance of essential functions during any emergency. FPC 

65 applies to all federal executive branch departments and agencies 

Page 4 GAO-06-740T
at all levels, including locations outside Washington, D.C. 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. 

In partial response to a recommendation we made in April 2004, the 

2004 version of FPC 65 also included new guidance on human 

capital considerations for COOP events.5

 For example, the guidance 

instructed agencies to consider telework—also referred to as 

telecommuting or flexiplace—as an option in their continuity 

planning. 

Telework 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.”6

 A 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.7

In 2004, we surveyed major federal agencies at your request to 

determine how they planned to use telework during COOP events.8

 5

 GAO, Human Capital: Opportunities to Improve Federal Continuity Planning

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

6

 OPM, Report to the Congress: The Status of Telework in the Federal Government

(Washington, D.C.: Jan. 2003). 

7

 OPM, Report to the Congress: The Status of Telework in the Federal Government

(Washington, D.C.: Dec. 2005).

8

 The plans that we reviewed in 2004 were created before the issuance of FEMA’s revised 

FPC 65, which instructs agencies to consider the use of telework in their continuity 

planning. 

Page 5 GAO-06-740T
We reported that, although agencies were not required to use 

telework in their COOP plans, 1 of the 21 agency continuity plans in 

place on May 1, 2004, documented plans to address some essential 

functions through telework. In addition, 10 agencies reported that 

they intended to use telework following a COOP event, even though 

those intentions were not documented in their continuity plans. 

The focus on using telework in continuity planning has been 

heightened in response to the threat of pandemic influenza. In 

November 2005, the White House issued a national strategy to 

address this threat, which states that social distancing measures, 

such as telework, may be appropriate public health interventions for 

infection control and containment during a pandemic outbreak. 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 DHS—the parent department of FEMA—with developing 

plans to implement the strategy in regard to domestic incident 

management and federal coordination. In May 2006, the White 

House issued an implementation plan in support of the pandemic 

strategy. This plan outlines the responsibilities of various agencies 

and establishes time lines for future actions. 

Few Agencies Demonstrated That They Had Adequately Prepared to 

Use Telework in a COOP Event 

Although more agencies reported plans for essential team members 

to telework during a COOP event than in our 2004 survey, few 

documented that they had made the necessary preparations to 

effectively use telework during an emergency. While 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, and 15 addressed telework in their COOP 

plans (see table 1). For agencies that did not plan to use telework 

during a COOP event, reasons cited by agency officials for this 

decision included (1) the need to access classified information—

Page 6 GAO-06-740T
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. 

Table 1: Agency Responses to Selected Questions on Telework in COOP Plans 

Question Year Yes

Yes (no

doca) No

Does the agency’s COOP plan specifically address telework? 2005 12 3 8

2004b

2 1 19

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

telework in a COOP event? 2004 1 2 19

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

COOP event? 2004 1 3 18

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

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

COOP event? 2004 0 2 20

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. 

The agencies that did plan to use telework in emergencies did not 

consistently demonstrate that they were prepared to do so. We 

previously identified steps agencies should take to effectively use 

telework during an emergency. These include preparations to 

ensure that staff has adequate technological capacity, assistance, 

and training.

9

 Table 1 provides examples of gaps in agencies’ 

preparations, such as the following: 

● 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 that they were expected to telework during such an event. 

 9

 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). 

Page 7 GAO-06-740T
● None of the 23 agencies demonstrated that it could ensure adequate 

technological capacity to allow designated personnel to telework 

during a COOP event. 

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. 

In March 2006, FEMA disseminated guidance to agencies regarding

the incorporation of pandemic influenza considerations into COOP 

planning. The guidance states that the dynamic nature of a 

pandemic influenza requires that the federal government take a 

nontraditional approach to continuity planning and readiness. It 

suggests the use of telework during such an event. According to the 

guidance, agencies should consider which essential functions and 

services can be conducted from a remote location (e.g., home) using 

telework. However, the guidance does not address the steps 

agencies should take when preparing to use telework during an 

emergency. For example, although the guidance states that agencies 

should consider testing, training, and exercising of social distancing 

techniques, including telework, it does not address other necessary 

preparations, such as informing designated staff of the expectation 

to telework or providing them with adequate technical resources 

and support. 

Earlier this month, after we briefed your staff, the White House 

released an Implementation Plan in support of the National Strategy 

for Pandemic Influenza. This plan calls on OPM to work with DHS 

and other agencies to revise existing telework guidance and issue 

new guidance on human capital planning and COOP. The plan 

establishes an expectation that these actions will be completed 

within 3 months. 

If the forthcoming guidance from DHS and other responsible 

agencies does not require agencies to make the necessary 

Page 8 GAO-06-740T
preparations for telework, 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. In 

addition, inadequate preparations could limit the ability of 

nonessential employees to contribute to agency missions during 

extended emergencies, including a pandemic influenza scenario. 

In summary, Mr. Chairman, although more agencies reported plans 

for essential team members to telework during a COOP event than 

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

necessary preparations to effectively use telework during an 

emergency. In addition, agencies lack guidance on what these 

necessary preparations are. Although FEMA’s recent telework 

guidance does not address the steps agencies should take to prepare 

to use telework during an emergency event, new guidance on 

telework and COOP is expected to be released later this year. If the 

new guidance does not specify the steps agencies need to take to 

adequately prepare their telework capabilities for use during an 

emergency situation, it will be difficult for agencies to make 

adequate preparations to ensure that their teleworking staff will be 

able to perform essential functions during a COOP event. 

In our report, we made recommendations aimed at helping to ensure 

that agencies are adequately prepared to perform essential functions 

following an emergency. Among other things, we recommended that 

the Secretary of Homeland Security direct the FEMA Director to 

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. 

In commenting on a draft of the report, the Director of DHS’s 

Liaison Office partially agreed with this recommendation and stated 

that FEMA will coordinate with OPM in the development of a time 

line 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. 

Page 9 GAO-06-740T
With the release of the White House’s Implementation Plan 

regarding pandemic influenza, a time line has now been established

for the issuance of revised guidance on telework; however, unless 

the forthcoming guidance addresses the necessary preparations, 

agencies may not be able to use telework effectively to ensure the 

continuity of their essential functions. 

Mr. Chairman, this concludes my statement. I would be pleased to 

respond to any questions that you or other members of the 

Committee may have at this time.

Contacts and Acknowledgements 

For information about this testimony, please contact Linda D. 

Koontz at (202) 512-6240 or at koontzl@gao.gov. Key contributions 

to this testimony were made by James R. Sweetman, Jr., Assistant 

Director; Barbara Collier; Sairah Ijaz; Nick Marinos; and Kim 

Zelonis. 

(310762) Page 10 GAO-06-740T
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