United States Government Accountability Office

GAO Report to Congressional Committees

 

CATASTROPHIC 

DISASTERS 

Enhanced Leadership, 

Capabilities, and 

Accountability 

Controls Will Improve 

the Effectiveness of 

the Nation’s 

Preparedness, 

Response, and 

Recovery System

September 2006 

GAO-06-618 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 2006

CATASTROPHIC DISASTERS 

Enhanced Leadership, Capabilities, and 

Accountability Controls Will Improve the 

Effectiveness of the Nation’s 

Preparedness, Response, and Recovery 

System 

Highlights of GAO-06-618, a report to 

congressional committees 

Hurricane Katrina was the largest, 

most destructive natural disaster in 

our nation’s history. The problems

experienced in responding to 

Katrina resulted in a number of

investigations—by congressional 

committees, the White House 

Homeland Security Council, and 

others--regarding the preparations 

for and response to Katrina. GAO 

assisted the congressional 

investigations and, under the 

Comptroller General’s authority, 

initiated a number of Katrinarelated reviews. In March 2006

testimony, GAO provided its 

preliminary observations to 

Congress. 

The purpose of this report is to 

summarize what went well and 

why, what did not go well and why, 

and what changes are needed to

improve the nation’s readiness to 

respond to a catastrophic disaster;

and to identify selected issues 

associated with the Gulf Coast’s

recovery. This report is based on 

GAO’s prior work on catastrophic 

disasters, including Hurricane 

Andrew in 1992, the over 30 GAO

reports completed to date on

Hurricanes Katrina and Rita, 

ongoing GAO work, and other 

Hurricane Katrina reviews and 

lessons learned. 

What GAO Recommends

This report includes six 

recommendations to the Secretary 

of Homeland Security with which

DHS generally agreed, describing

actions taken to implement them. 

The report also includes a matter 

for congressional consideration. 

Hurricane Katrina was a catastrophic disaster whose scope and destruction 

severely tested all levels of governments in the affected areas and the nation 

as a whole. It almost immediately overwhelmed state and local first 

responders, and the response required outside action and support from 

many sources. The heroic efforts by many saved thousands of lives. The 

federal government, many states, local governments, plus nonprofit and 

private sector organizations provided substantial personnel and resources to 

assist in the response, but these proved insufficient to meet the immediate 

challenges posed by Hurricane Katrina’s effects. 

The three basic elements in preparing for, responding to and recovering 

from any catastrophic disaster are (1) leadership; (2) capabilities; and 

(3) accountability. Leadership in the form of legal authorities, roles and 

responsibilities, and lines of authority at all levels of government must be 

clearly defined, effectively communicated, and well understood in order to 

facilitate rapid and effective decision making. DHS has made revisions to the 

National Response Plan designed to further clarify federal roles and 

responsibilities, but their effect has not yet been tested in an actual disaster. 

Developing the capabilities needed for catastrophic disasters should be part 

of an overall national effort designed to integrate and define what needs to 

be done, where, by whom, and how well. Ensuring needed capabilities are 

ready requires effective planning and coordination, plus robust training and 

exercises in which the capabilities are realistically tested, problems 

identified, and subsequently addressed in partnership with federal, state, 

local, and nongovernmental stakeholders. In addition, integrating an allhazards risk management framework into decision making is central to 

assessing catastrophic disaster risks and guiding the development of 

national capabilities to prevent or mitigate where possible and respond to 

such risks. DHS has announced a number of actions to improve readiness 

and response for catastrophic disasters, but there is little information 

available on the extent to which these changes are operational.

Accountability controls and mechanisms ensure that resources are used 

appropriately for valid purposes. Following a catastrophic disaster, decisionmakers face a tension between the demand for rapid response and recovery 

assistance—including assistance to victims—and implementing appropriate 

controls and accountability mechanisms. Our work and that of others found, 

for example, the processes for confirming disaster victims’ eligibility for 

assistance were insufficient and resulted in millions of dollars in

questionable payments to fraudulent claimants. Also, some contracts had 

insufficient provisions to ensure that prices were fair and reasonable. DHS 

has reported that it has taken steps to address some of the concerns, 

including working to complete more contracts for key services in advance of

a disaster and improving its ability to verify individual claimant eligibility for 

disaster benefits and assistance. 

www.gao.gov/cgi-bin/getrpt?GAO-06-618. 

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact William O.

Jenkins, Jr. at (202) 512-8757 or

jenkinswo@gao.gov. 
Contents 

Letter 1

Results in Brief 5 

Background 10

Leadership Is Critical for Preparing for, Responding to, and

Recovering from Catastrophic Disasters 19 

Enhanced Capabilities for Catastrophic Response and Recovery 

Are Needed 36 

Balance Needed between Quick Provision of Assistance and 

Ensuring Accountability to Protect against Waste, Fraud, and 

Abuse 71

Long-Term Recovery and Rebuilding Efforts Raise Issues for 

Congress to Consider 84 

Conclusions 96

Recommendations 98

Agency Comments 101 

GAO Contacts 103 

Appendix I Summary of Key Open GAO Recommendations on 

Catastrophic Disasters 105 

Appendix II Comments from the Department of Homeland 

Security 121 

Appendix III Comments from the Small Business Administration 133 

Appendix IV GAO Contact and Staff Acknowledgments 136 

Related GAO Products 137 

Page i GAO-06-618 Catastrophic Disasters
Tables 

Table 1: Findings in Reports by Congress and the Administration 18 

Table 2: Implementation of White House Homeland Security 

Council Recommendations for the 2006 Hurricane Season: 

Recommendations Related to Leadership Issues 33 

Table 3: Implementation of White House Homeland Security 

Council Recommendations for the 2006 Hurricane Season: 

Recommendations Related to Regarding Capabilities 66 

Table 4: Key Open Recommendations Made Prior to Hurricanes 

Katrina and Ritaaa 105

Table 5: Recent Open Recommendations Made in the Aftermath of 

Hurricanes Katrina and Ritaa 109

Table 6: New GAO Recommendations Formalized in this Report 120 

Page ii GAO-06-618 Catastrophic Disasters
Abbreviations 

DCMS Disaster Credit Management System 

DOD Department of Defense 

DHS Department of Homeland Security 

ESF Emergency Support Function 

FCO Federal Coordinating Officer 

FEMA Federal Emergency Management Agency 

HHS Health and Human Services 

HSPD Homeland Security Presidential Directive 

IHP Individuals and Households Program 

JFO Joint Field Office 

NDMS National Disaster Medical System 

NFC National Finance Center 

NFIP National Flood Insurance Program 

NIMS National Incident Management System 

NOAA National Oceanographic and Atmospheric Administration 

NRP National Response Plan 

PFO Principal Federal Officer

SBA Small Business Administration 

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

reproduce this material separately. 

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

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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 iii GAO-06-618 Catastrophic Disasters
United States Government Accountability Office

Washington, DC 20548 

September 6, 2006 

The Honorable Susan M. Collins 

Chairman 

The Honorable Joseph I. Lieberman 

Ranking Minority Member 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Susan M. Collins 

Chairman 

The Honorable Joseph I. Lieberman 

Ranking Minority Member 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Peter T. King 

Chairman 

The Honorable Bennie G. Thompson

Ranking Minority Member 

Committee on Homeland Security 

House of Representatives 

The Honorable Peter T. King 

Chairman 

The Honorable Bennie G. Thompson

Ranking Minority Member 

Committee on Homeland Security 

House of Representatives 

The Honorable Tom Davis 

Chairman 

The Honorable Henry A. Waxman 

Ranking Minority Member 

Committee on Government Reform 

House of Representatives 

The Honorable Tom Davis 

Chairman 

The Honorable Henry A. Waxman 

Ranking Minority Member 

Committee on Government Reform 

House of Representatives 

Just over 1 year ago, Hurricane Katrina made final landfall in coastal 

Louisiana and Mississippi, and its destructive force extended to the 

western Alabama coast. Hurricane Katrina was the worst natural disaster 

in our nation’s history in geographic scope, the extent and severity of its

destruction and damage, and the number of persons displaced from their 

homes. Hurricane Katrina and the following Hurricanes Rita and Wilma—

also among the most powerful hurricanes in the nation’s history—

graphically illustrated the limitations at that time of the nation’s readiness 

and ability to respond effectively to a catastrophic disaster—that is, a 

disaster whose effects almost immediately overwhelm the response 

capacities of affected state and local first responders and require outside 

action and support from the federal government and other entities. 

Reports by the House Select Bipartisan Committee to Investigate the

Just over 1 year ago, Hurricane Katrina made final landfall in coastal 

Louisiana and Mississippi, and its destructive force extended to the 

western Alabama coast. Hurricane Katrina was the worst natural disaster 

in our nation’s history in geographic scope, the extent and severity of its

destruction and damage, and the number of persons displaced from their 

homes. Hurricane Katrina and the following Hurricanes Rita and Wilma—

also among the most powerful hurricanes in the nation’s history—

graphically illustrated the limitations at that time of the nation’s readiness 

and ability to respond effectively to a catastrophic disaster—that is, a 

disaster whose effects almost immediately overwhelm the response 

capacities of affected state and local first responders and require outside 

action and support from the federal government and other entities. 

Reports by the House Select Bipartisan Committee to Investigate the

Page 1 GAO-06-618 Catastrophic D tastrophic Disasters
Preparation for and Response to Hurricane Katrina,1

 the Senate Homeland 

Security and Governmental Affairs Committee,2

 the White House 

Homeland Security Council,3

 the Department of Homeland Security (DHS) 

Inspector General,4

 and DHS and the Federal Emergency Management 

Agency (FEMA)5

 have all identified a variety of failures and some strengths 

in the preparations for, response to, and initial recovery from Hurricane 

Katrina. Collectively, these reports, along with GAO’s various reports and 

testimonies, have chronicled the strengths and weaknesses of federal, 

state, local, and nongovernmental efforts, and offered a number of specific 

recommendations for improving the nation’s ability to effectively prepare

for and respond to catastrophic disasters. Legislation to reorganize the 

federal government’s emergency response responsibilities has been 

introduced in both the House and the Senate and the administration has 

undertaken several efforts to address disaster management weaknesses 

identified in the aftermath of the 2005 hurricane season. 

The 2005 hurricane season was particularly active, and the National 

Oceanographic and Atmospheric Administration (NOAA) estimated that 

there was a 75-percent probability of another active hurricane season in 

2006 (the hurricane season runs from June 1st through November 30th 

each year). However, NOAA reminds us that hurricane-spawned 

catastrophic disasters can occur even in years with near-normal or belownormal levels of activity. The nation’s second most destructive hurricane—

Andrew in 1992—occurred during a season with otherwise below normal 

activity. Moreover, the nation must be prepared to respond to and recover

from a wide range of other disasters that may occur at any time of year 

and could be the result of nature or human action, such as a possible 

influenza pandemic or terrorist attack. 

 1

A Failure of Initiative: Final Report of the House Select Bipartisan Committee to 

Investigate the Preparation for And Response to Hurricane Katrina (Washington, D.C.:

Feb. 15, 2006). 

2

Hurricane Katrina: A Nation Still Unprepared (Washington, D.C.: May 2006). 

3

The Federal Response to Hurricane Katrina: Lessons Learned (Washington, D.C.:

Feb. 23, 2006). 

4

A Performance Review of FEMA’s Disaster Management Activities in Response to 

Hurricane Katrina, OIG-06-32 (Washington, D.C.: Mar. 31, 2006). 

5

DHS/FEMA Initial Response Hotwash: Hurricane Katrina in Louisiana, DR-1603-LA 

(Baton Rouge, La.: Feb. 13, 2006). 

Page 2 GAO-06-618 Catastrophic Disasters
In a March 2006 testimony,6

 we provided our preliminary observations 

regarding the preparedness for, response to, and recovery from Hurricanes 

Katrina and Rita. We noted that the key issues were in many ways very 

reminiscent of the issues identified in the wake of Hurricane Andrew in 

19927

 and fell into three broad, interrelated categories: (1) leadership, 

including clearly defined roles and responsibilities of all key participants;

(2) building and sustaining effective capabilities through coordinated 

planning, training, and exercises; and (3) maintaining accountability for 

the use of resources while providing assistance and resources as quickly 

as possible. The overall objective of this work was (1) to provide Congress 

with a summary of what went well and why, what did not go well and why, 

and what specific changes are needed to improve this nation’s emergency 

preparedness, response, and recovery system; and (2) identify selected 

issues associated with the Gulf Coast’s recovery. Following the themes 

from our prior work, this report discusses the major findings from our 

recent and ongoing work on the aftermath of Hurricane Katrina and 

relevant findings from Congress and the administration with respect to 

(1) the actions of government agencies during Hurricane Katrina that 

made positive contributions to the response and recovery and those that 

were less positive; (2) catastrophic disaster leadership roles and 

responsibilities; (3) capabilities to prepare for, respond to, and recover 

from catastrophic disasters; (4) recognizing the tension between the need

for timely action and the need for appropriate controls and accountability 

mechanisms; and (5) selected longer-term recovery issues, including the

rebuilding effort along the Gulf Coast. 

This report is based on our work on Hurricanes Katrina and Rita and our

visits to the areas most affected by Hurricanes Katrina and Rita—Alabama, 

Louisiana, Mississippi, and Texas. We interviewed various officials, 

including senior federal officials, the governors of Alabama, Louisiana, 

Mississippi, and Texas, and the mayor of New Orleans. We also analyzed

information from the various involved federal agencies, such as FEMA and 

the Department of Defense (DOD) and the federal audit community; state 

organizations including state emergency management agencies; National 

Guard officials in the states, state agencies and state auditors; local 

officials; and representatives from nongovernmental agencies. We also 

 6

GAO, Hurricane Katrina: GAO’s Preliminary Observations Regarding Preparedness, 

Response, and Recovery, GAO-06-442T (Washington, D.C.: Mar. 8, 2006). 

7

GAO, Disaster Management: Improving the Nation’s Response to Catastrophic 

Disasters, GAO/RCED-93-186 (Washington, D.C.: July 23, 1993).

Page 3 GAO-06-618 Catastrophic Disasters
have studied the findings in reports issued by Congress, DHS/FEMA, 

DHS’s Office of Inspector General, and the White House Homeland 

Security Council. 

In addition, we have an extensive body of work on prior catastrophic 

disasters. For example, we drew upon several past reviews in 1993, 

examining the federal response to Hurricane Andrew. We also conducted 

extensive work following the events of September 11, 2001,8

 and on 

tsunami preparedness and recovery issues.9

 Our reports focused on 

improving the immediate response to catastrophic disasters that raise 

unique challenges, and we made various recommendations within this 

context, many of which continue to apply and help form the basis of our 

views today, including the issue of FEMA’s future organizational 

placement. In the months following Hurricane Katrina, we provided 

support to congressional investigations of the preparedness for and 

response to Hurricane Katrina and have issued reports on such topics as 

the military’s role in catastrophic disasters;10 contracting practices for 

response and recovery activities;11 the evacuation of hospitals, nursing 

homes and other vulnerable populations;12 charitable assistance and the 

 8

GAO, Disaster Assistance: Information on FEMA’s Post 9/11 Public Assistance to the

New York City Area, GAO-03-926 (Washington, D.C.: Aug. 29, 2003); and GAO, September 

11: Overview of Federal Disaster Assistance to the New York City Area, GAO-04-72 

(Washington, D.C.: Oct. 31, 2003). 

9

GAO, U.S. Tsunami Preparedness: Federal and State Partners Collaborate to Help

Communities Reduce Potential Impacts, but Significant Challenges Remain, GAO-06-519 

(Washington, D.C.: June 5, 2006); and Foreign Assistance: USAID Has Begun Tsunami

Reconstruction in Indonesia and Sri Lanka, but Key Projects May Exceed Initial Cost 

and Schedule Estimates, GAO-06-488 (Washington, D.C.: Apr. 14, 2006). 

10GAO, Hurricane Katrina: Better Plans and Exercises Needed to Guide the Military’s

Response to Catastrophic Natural Disasters, GAO-06-643 (Washington, D.C.: May 15, 

2006). 

11See GAO, Agency Management of Contractors Responding to Hurricanes Katrina and

Rita, GAO-06-461R (Washington, D.C.: Mar. 16, 2006); Hurricane Katrina: Planning for 

and Management of Federal Disaster Recovery Contracts, GAO-06-622T (Washington,

D.C.: Apr. 10, 2006); and Hurricane Katrina: Improving Federal Contracting Practices in

Disaster Recovery Operations, GAO-06-714T (Washington, D.C.: May 4, 2006). 

12See GAO, Disaster Preparedness: Preliminary Observations on the Evacuation of 

Hospitals and Nursing Homes Due to Hurricanes, GAO-06-443R (Washington, D.C.: Feb. 

16, 2006); and Disaster Preparedness: Preliminary Observations on the Evacuation of 

Vulnerable Populations due to Hurricanes and Other Disasters, GAO-790T (Washington, 

D.C.: May 18, 2006); Disaster Preparedness: Limitations in Federal Evacuation 

Assistance for Health Facilities Should be Addressed, GAO-06-826 (Washington, D.C.: 

July 20, 2006). 

Page 4 GAO-06-618 Catastrophic Disasters
coordination between FEMA and the Red Cross;13 ensuring the appropriate

use and accountability for international assistance;14 and issues associated 

with guarding against fraud in the provision of expedited assistance to 

disaster victims.15 To date we have published over 30 GAO reports and 

testimonies on Hurricane Katrina-related matters. We will continue to 

focus on ways to improve the nation’s readiness and capacity to respond 

to catastrophic disasters as well as issues associated with the long-term 

recovery of the Gulf Coast region, including housing, health care, levee

reconstruction, and economic recovery. 

We conducted our work from September 2005 through August 2006, in 

accordance with generally accepted government auditing standards. 

While much of the publicity regarding Hurricane Katrina has focused on 

what did not go well in connection with the governments’ activities, there 

are notable exceptions. For example, the National Weather Service and 

the National Hurricane Center provided accurate forecasts of the time and

location of Hurricane Katrina’s landfall, accompanied by warnings of the

hurricane’s potential destructive force. Dedicated and heroic efforts by 

many, including local first responders, hospital personnel, the U.S. Coast 

Guard, the National Guard, active duty military troops, and volunteers 

saved thousands of lives. Federal agencies such as the Postal Service, the 

Social Security Administration, the National Finance Center, the Forest 

Service, and the Internal Revenue Service demonstrated their flexibility 

and adaptability, responding to Katrina's challenges. Many states sent 

supplies, first responders, National Guard personnel, and other resources 

to assist the areas hardest hit by the disasters. Many charitable, faith-based 

and private sector organizations supplemented governmental efforts 

providing food and shelter for thousands. Despite these efforts, various 

reports and our own work on the 2005 catastrophic disasters suggest that

Results in Brief 

 13See GAO, Hurricanes Katrina and Rita: Provision of Charitable Assistance, 

GAO-06-297T (Washington, D.C.: Dec. 13, 2005); and Hurricanes Katrina and Rita : 

Coordination between FEMA and Red Cross Should Be Improved for the 2006 Hurricane

Season, GAO-06-712 (Washington, D.C.: June 8, 2006). 

14GAO, Hurricane Katrina: Comprehensive Procedures Are Needed to Ensure 

Appropriate Use of and Accountability for International Assistance, GAO-06-460 

(Washington, D.C.: Apr. 6, 2006). 

15GAO, Expedited Assistance for Victims of Hurricanes Katrina and Rita: FEMA’s

Control Weaknesses Exposed the Government to Significant Fraud and Abuse,

GAO-06-655 (Washington, D.C.: June 16, 2006).

Page 5 GAO-06-618 Catastrophic Disasters
the substantial human, financial, and technological resources and 

capabilities marshaled by governments at all levels were inadequate to 

meet the immediate challenges posed by the disaster's unprecedented 

geographic scope, degree of damage, and the resulting number of 

hurricane victims who had to be relocated. 

In preparing for, responding to, and recovering from any catastrophic 

disaster, the legal authorities, roles and responsibilities, and lines of 

authority at all levels of government must be clearly defined, effectively 

communicated, and well understood in order to facilitate rapid and 

effective decision making. The experience of Hurricane Katrina showed 

the need to improve leadership at all levels of government in order to 

better respond to a catastrophic disaster. For example, there were 

problems experienced with roles and responsibilities under the National 

Response Plan (NRP),16 and ambiguities concerning what constituted an 

incident of national significance to trigger the NRP as well as what 

constituted a catastrophic incident to trigger the proactive response of the 

NRP’s Catastrophic Incident Annex. On May 25, 2006, DHS released 

changes to the NRP regarding leadership issues, such as which situations

require secretarial leadership; the process for declaring incidents of 

national significance; and the scope of the NRP and its Catastrophic 

Incident Annex. The revised NRP clearly states that the Secretary of 

Homeland Security, who reports directly to the President, is responsible 

for declaring and managing incidents of national significance, including 

catastrophic incidents. DHS has not yet published the final supplement to 

the Catastrophic Incident Annex, which is intended to provide more detail 

for implementing the annex. Until the supplement is final and distributed, 

agencies that have responsibilities under the supplement cannot complete 

the implementation plans and agreements needed to make the annex and 

supplement fully operational. The White House Homeland Security 

Council report included 44 recommendations that were intended to be 

implemented quickly, of which 18 are focused on improving and clarifying

the legal authorities, roles and responsibilities, and lines of authority. DHS 

has provided limited information on the status of its implementation of the 

White House recommendations, although it has reported actions taken on

some issues raised in the White House Homeland Security Council report 

and in other critiques. For example, DHS has designated principal federal

 16The National Response Plan is the basis for how federal departments and agencies are to

work together with state, local, and tribal governments and the private sector in managing

domestic incidents. 

Page 6 GAO-06-618 Catastrophic Disasters
officials and federal coordinating officers for regions and states at-risk of 

hurricanes and further described their respective roles in coordinating 

disaster response—a source of some confusion in the federal response to 

Hurricane Katrina. However, the changes may not have fully resolved the 

leadership issues with regard to the roles of the principal federal officer 

and federal coordinating officer. While the Secretary of Homeland Security 

may avoid conflicts by appointing a single individual to serve in both 

positions in non-terrorist incidents, confusion may persist if the Secretary 

of Homeland Security does not exercise this discretion to do so. 

Furthermore, this discretion does not exist for terrorist incidents, and the 

revised NRP does not specifically provide a rationale for this limitation. 

Congress also has raised concerns that FEMA’s performance problems 

exhibited during the hurricane response may stem from its organizational 

placement and its budgetary relationship within DHS. As we stated in our

March 8 and May 9, 2006, testimonies, organizational changes alone, while 

potentially important, will not be enough to adequately address the 

underlying systemic conditions that resulted in FEMA’s performance 

problems during the last hurricane season. In our view, a number of other 

factors may be ultimately more important to FEMA’s success in 

responding to and recovering from future disasters, including catastrophic 

disasters, than its organizational placement. We have identified several 

factors that Congress should consider as it deliberates FEMA’s 

organizational placement: (1) mission relevancy, (2) similarity of goals and 

objectives, (3) the ability to leverage the effectiveness of other agencies, 

and (4) gains through consolidation. 

As stated earlier, numerous reports and our own work suggest that the 

substantial resources and capabilities marshaled by state, local, and 

federal governments and nongovernmental organizations were insufficient 

to meet the immediate challenges posed by the unprecedented degree of 

damage and the resulting number of hurricane victims caused by 

Hurricanes Katrina and Rita. Developing the capabilities needed for 

catastrophic disasters should be part of an overall national preparedness 

effort that is designed to integrate and define what needs to be done, 

where, based on what standards, how it should be done, and how well it 

should be done. The nation’s experience with Hurricanes Katrina and Rita

reinforces some of the questions surrounding the adequacy of capabilities 

in the context of a catastrophic disaster—particularly in the areas of 

(1) situational assessment and awareness; (2) emergency communications; 

(3) evacuations; (4) search and rescue; (5) logistics; and (6) mass care and 

sheltering. Ensuring that needed capabilities such as these are available 

requires effective planning and coordination, as well as training and 

exercises in which the capabilities are realistically tested and problems 

Page 7 GAO-06-618 Catastrophic Disasters
identified and subsequently addressed in partnership with other federal, 

state, and local stakeholders, as capabilities are built upon the appropriate 

combination of people, skills, processes, and assets. In addition, ongoing 

work is still needed by DHS to address FEMA’s human resource 

challenges. Finally, as we stated in our March 2006 testimony, the use of a

risk management methodology—integrating systematic concern for risk 

into the normal cycle of agency decision making and implementation—

should be central to assessing the risk for catastrophic disasters, guiding 

the development of national capabilities and the expertise that can be used 

to respond effectively to catastrophic disasters. 

Although controls and accountability mechanisms help to ensure that 

resources are used appropriately, during a catastrophic disaster decisionmakers struggle with the tension between implementing controls and 

accountability mechanisms and the demand for rapid response and 

recovery assistance. On one hand, our work found many examples where 

quick action could not occur due to procedures that required extensive, 

time-consuming processes, delaying the delivery of vital supplies and 

other assistance. On the other hand, we also found examples where 

FEMA’s processes under assistance programs to disaster victims left the 

federal government vulnerable to fraud and the abuse of expedited 

assistance payments. We estimate that through February 2006, FEMA 

made about $600 million to $1.4 billion in improper and potentially 

fraudulent payments to applicants who used invalid information to apply 

for expedited cash assistance. DHS and FEMA have reported a number of 

actions that are to be in effect for the hurricane season so that federal 

recovery programs will have more capacity to rapidly handle a 

catastrophic incident but also provide accountability. Examples include 

significantly increasing the quantity of pre-positioned supplies, such as 

food, ice, and water; placing global positioning systems on supply trucks 

to track their location and better manage the delivery of supplies; an 

enhanced phone system for victim assistance applications that can handle 

up to 200,000 calls per day; and improved computer systems and processes 

for verifying the eligibility of those applying for assistance. Effective 

implementation of these and other planned improvements will be critical 

to achieving their intended outcomes. Finally, catastrophic disasters not 

only require a different magnitude of capabilities and resources for 

effective response, they may also require more flexible policies and 

operating procedures. In a catastrophe, streamlining, simplifying, and 

expediting decision making should quickly replace “business as usual” and 

the unquestioned following of long-standing policies and operating 

procedures used in normal situations for providing relief to disaster 

victims. At the same time, controls and accountability mechanisms must 

Page 8 GAO-06-618 Catastrophic Disasters
be sufficient to provide the documentation needed for expense 

reimbursement and reasonable assurance that resources have been used 

legally and for the purposes intended. 

The federal government also will be a major partner in the longer-term 

recovery and rebuilding of individuals and communities along the Gulf 

Coast. Among the areas requiring federal attention are (1) assessing the 

environmental hazards created by the storms; (2) rebuilding and 

strengthening the levees; (3) providing assistance to school districts that 

have enrolled large numbers of evacuee children; and (4) building the 

capacity to address demand in multiple victims assistance programs such 

as financial assistance or loans for repair and replacement of housing and 

the rebuilding of businesses. 

This report summarizes recommendations we have made in our work, 

some following Hurricane Andrew in 1992 and others in the aftermath of 

Hurricanes Katrina and Rita. We are also updating and formalizing several

recommendations initially presented in our March 8, 2006, testimony. 

Specifically, we are recommending that DHS (1) rigorously re-test, train, 

and exercise its recent clarification of the roles, responsibilities, and lines

of authority for all levels of leadership, implementing changes needed to 

remedy identified coordination problems; (2) direct that the NRP base 

plan and its supporting Catastrophic Incident Annex be supported by more 

robust and detailed operational implementation plans; (3) provide 

guidance and direction for federal, state, and local planning, training, and 

exercises to ensure such activities fully support preparedness, response, 

and recovery responsibilities at a jurisdictional and regional basis; (4) take 

a lead in monitoring federal agencies’ efforts to prepare to meet their 

responsibilities under the NRP and the interim National Preparedness 

Goal; (5) use a risk management approach in deciding whether and how to 

invest finite resources in specific capabilities for a catastrophic disaster; 

and (6) provide guidance on advanced procurement practices and 

procedures for those federal agencies with roles and responsibilities under 

the NRP so that these agencies can better manage disaster-related 

procurement, and establish an assessment process to monitor agencies’ 

continuous planning efforts for their disaster-related procurement needs

and the maintenance of capabilities. We are also recommending that 

Congress give federal agencies explicit authority to take actions to prepare 

for all types of catastrophic disasters when there is warning. We also offer 

some factors that Congress may wish to consider as it carries out its 

oversight and legislative responsibilities with regard to national 

preparedness and the recovery of the Gulf Coast region. 

Page 9 GAO-06-618 Catastrophic Disasters
We provided a draft of this report to DHS for review and comment. On 

August 28, 2006, DHS provided official written comments that generally

concurred with our recommendations and described an array of actions it

has taken, has underway, or planned to implement them. The full text of 

DHS' comments is included in appendix II. We also provided relevant 

sections of the draft report to various federal departments and agencies 

including the departments of Agriculture, Education, Health and Human 

Services, Housing and Urban Development, Labor, and State, as well as the 

Small Business Administration, Environmental Protection Agency, and 

Social Security Administration. All but two either stated they had no 

comments or generally agreed with the sections that addressed their areas

of responsibility. The Department of Labor noted that it had reached

agreement with FEMA on coordination for disaster worker safety issues. 

SBA's comments basically reiterated its comments on our July 28, 2006

report on its disaster assistance, to which we responded in that report. 

Hurricanes Katrina and Rita left more than 1,500 dead, affected over 

90,000 square miles, caused more than $80 billion in damage, and forced 

mass evacuations from five states along the Gulf Coast, according to DHS. 

An estimated 600,000 households were displaced from affected areas and 

50,000 to 100,000 households remained in temporary housing 6 months 

later. As a result, 44 states and the District of Columbia received hundreds 

of thousands of evacuees, providing them with care and shelter over an 

extended period. These events tested the nation’s ability to respond to 

catastrophic events and demonstrated the importance of ensuring the 

effectiveness of federal, state, and local emergency response plans and the 

ability to quickly synchronize intergovernmental efforts. This catastrophic 

disaster provided a sobering picture of the overwhelming strains on 

disaster response and recovery capacities if there are back-to-back 

catastrophic disasters in the same area. 

Background 

Significant local, state, and federal resources were mobilized to respond to 

the Hurricane Katrina disaster, along with significant participation from 

charitable and private-sector organizations. Among federal agencies, the 

National Weather Service and its National Hurricane Center were 

proactive and vigilant, accurately predicted and tracked the size, scale, 

and path of Hurricane Katrina, and regularly contacted local, state and 

federal leaders to apprise them of the situation. The Coast Guard, National 

Guard, and state and local responders acted quickly to implement search 

and rescue efforts that saved thousands of stranded and desperate victims. 

The National Guard and the active military also played a major role in 

saving lives, providing food and shelter, and transporting victims who 

Page 10 GAO-06-618 Catastrophic Disasters
needed immediate medical care. Federal agencies such as the Postal 

Service, Social Security Administration, National Finance Center, Forest 

Service, and Internal Revenue Service demonstrated their flexibility in 

performing needed activities and services, and responding in the face of 

many challenges. However, the capabilities of several federal, state, and

local agencies were clearly overwhelmed. As events unfolded in the 

immediate aftermath and ensuing days after Hurricane Katrina’s final 

landfall, responders at all levels of government—many victims 

themselves—encountered significant breakdowns in vital areas such as 

emergency communications as well as obtaining and deploying essential 

supplies and equipment.

Stafford Act Is the 

Principal Federal Statute 

on Federal Disaster 

Assistance to States and 

Localities

There are several federal legislative and executive provisions that support 

preparation for and response to emergency situations. The Robert T. 

Stafford Disaster Relief and Emergency Assistance Act (the Stafford Act)17

primarily establishes the programs and processes for the federal 

government to provide major disaster and emergency assistance to states, 

local governments, tribal nations, individuals, and qualified private 

nonprofit organizations. Upon a governor’s request, the President can

declare an “emergency” or a “major disaster” under the Stafford Act, 

which triggers specific types of federal relief. The Stafford Act defines an 

emergency as any occasion or instance for which, in the determination of 

the President, federal assistance is needed to supplement state and local 

efforts and capabilities to save lives and to protect property and public 

health and safety, or to lessen or avert the threat of a catastrophe in any 

part of the United States. Under an emergency declaration, the federal

government has authority to engage in various emergency response 

activities, such as debris removal, temporary housing assistance, and the 

distribution of medicine, food, and other consumables. The Stafford Act 

places a $5 million limit on federal emergency assistance, but the 

President may exceed the limit, followed by a report to Congress. 

The Stafford Act defines a “major disaster” as any natural catastrophe or, 

regardless of cause, any fire, flood, or explosion, in any part of the United 

States, which the President determines causes damage of sufficient 

severity and magnitude to warrant major disaster assistance under the 

Stafford Act to supplement the efforts and available resources of states, 

local governments, and disaster relief organizations in alleviating damage, 

 1742 U.S.C. §§ 5121-5206. 

Page 11 GAO-06-618 Catastrophic Disasters
loss, hardship, or suffering. Under a major disaster declaration, the federal 

government has the authority to engage in the same activities authorized 

under an emergency declaration, but without the $5 million ceiling. In 

addition, major disaster assistance includes a variety of assistance not

available in the context of an emergency declaration. For example, in a 

major disaster, the federal government may provide unemployment 

assistance, food coupons to low-income households, and repair, 

restoration and replacement of certain damaged facilities, among other 

things. 

For Hurricane Katrina, the President issued emergency declarations under 

the Stafford Act for Louisiana on August 27, 2005, and Mississippi and 

Alabama on August 28, 2005. The President made major disaster 

declarations for Florida on August 28, 2005, and Louisiana, Mississippi, 

and Alabama on August 29, 2005, the same day that Hurricane Katrina 

made final landfall in Plaquemines Parish, Louisiana at 6:10 a.m. and about 

4 hours later at the Louisiana/Mississippi border. 

Federal Disaster 

Assistance and Relief Is to 

Be Administered by FEMA 

under the Stafford Act 

FEMA, within DHS, has responsibility for administering the provisions of 

the Stafford Act, the principal federal statute governing federal disaster 

assistance and relief. FEMA was an independent agency from 1979 until 

2003 and was a cabinet-level agency from 1996 to 2003. FEMA became part

of the newly formed DHS in March 2003. Prior to FEMA’s creation in 1979, 

federal disaster response and recovery was managed by an agency within 

the Department of Housing and Urban Development (HUD). The 1960s and 

early 1970s brought massive disasters requiring major federal response 

and recovery operations by the Federal Disaster Assistance 

Administration, the department within HUD responsible at that time for 

disaster response and recovery. Hurricane Carla struck in 1962, Hurricane 

Betsy in 1965, Hurricane Camille in 1969, and Hurricane Agnes in 1972. A 

major earthquake hit Alaska in 1964, and the San Fernando earthquake 

rocked Southern California in 1971. To respond to national concern 

regarding these events, Congress passed the 1974 Disaster Relief Act that

established the process of presidential disaster declarations. However, 

emergency and disaster activities were still fragmented. Many parallel 

programs and policies existed at the state and local level, compounding 

the complexity of federal disaster relief efforts. In 1979, President Carter 

issued an executive order that merged many of the separate disasterrelated responsibilities into a new, independent Federal Emergency 

Management Agency. Among other agencies, FEMA absorbed the Federal 

Insurance Administration, the National Fire Prevention and Control 

Administration, the National Weather Service Community Preparedness 

Page 12 GAO-06-618 Catastrophic Disasters
Program, the Federal Preparedness Agency of the General Services 

Administration, and the Federal Disaster Assistance Administration 

activities from HUD. Civil defense responsibilities were also transferred to 

the new agency from the Defense Department’s Defense Civil 

Preparedness Agency. 

Interstate Disaster 

Assistance was also 

Provided through the 

Emergency Management 

Assistance Compact 

In addition to resources provided by the federal government, states 

affected by a catastrophic disaster can also turn to other states for 

assistance in obtaining needed surge capacity—the ability to draw on 

additional resources, such as personnel and equipment, needed to respond 

to and recover from the incident. One way of sharing personnel and 

equipment across state lines is through the use of an interstate compact 

that provides a legal and administrative framework for such emergency 

requests. Following the devastation of Hurricane Andrew in 1992, the 

Southern Governors’ Association, along with the Virginia Department of 

Emergency Services, formed the Southern Regional Emergency 

Management Assistance Compact (SREMAC) in August 1993. In 1995, 

SREMAC opened membership to any state or territory, becoming the 

Emergency Management Assistance Compact (EMAC), approved by

Congress in 1996.

18 As of September 2005, EMAC included all 50 states, the 

District of Columbia, Puerto Rico, and the U.S. Virgin Islands and has been 

activated during a variety of emergency events including hurricanes, 

floods, wildfires, and the September 11 terrorist attacks. Administered by 

the National Emergency Management Association (NEMA),19 the compact 

establishes a structure for requesting and deploying assistance, 

reimbursing states that provide assistance, and conferring liability and 

workers’ compensation protection. EMAC was not designed to supplant 

federal support nor does it obligate member states to provide resources to 

another state. 

The deployment of resources through EMAC in response to Hurricanes 

Katrina, Rita, and Wilma was by far the largest use of state-to-state mutual 

assistance in U.S. history. According to EMAC, as of March 24, 2006, 

Louisiana and Mississippi had made almost 1,900 requests for assistance 

resulting in the deployment of 61,450 civilian and National Guard 

personnel. 

 18Pub. L. No. 104-321, 110 Stat. 3877 (1996). 

19 The National Emergency Management Association is a non-partisan, non-profit 501(c)(3)

association affiliated with The Council of State Governments. 

Page 13 GAO-06-618 Catastrophic Disasters
The Homeland Security Act of 200220 required the newly established DHS 

to develop a comprehensive National Incident Management System 

(NIMS). NIMS is intended to provide a consistent framework for incident

management at all jurisdictional levels regardless of the cause, size, or 

complexity of the situation and to define the roles and responsibilities of 

federal, state, and local governments, and various first responder 

disciplines at each level during an emergency event. NIMS established the 

Incident Command System as a standard incident management 

organization with five functional areas—command, operations, planning,

logistics, and finance and administration—for management of all major 

incidents. It also prescribes interoperable communications systems and 

preparedness before an incident happens, including planning, training, and 

exercises. 

The Homeland Security 

Act Requires a 

Comprehensive Approach 

to Disaster Preparation 

and Response 

The Homeland Security Act of 2002 also required DHS to consolidate 

existing federal government emergency response plans into a single, 

integrated and coordinated national response plan. In December 2004, 

DHS issued the National Response Plan (NRP), intended to be an alldiscipline, all-hazards plan establishing a single, comprehensive 

framework for the management of domestic incidents where federal 

involvement is necessary. The NRP does not apply to the majority of 

incidents occurring each year that are handled by local jurisdictions or 

agencies through established authorities and existing plans under the 

planning assumption that incidents are typically managed at the lowest 

possible geographic, organizational, and jurisdictional level. Rather, the 

NRP is applicable to incidents that go beyond the state and local level and 

require a coordinated federal response. The NRP, operating within the 

framework of NIMS, provides the structure and mechanisms for nationallevel policy and operational direction for domestic incident management. 

The NRP also includes a Catastrophic Incident Annex, which describes an 

accelerated, proactive national response to catastrophic incidents. A draft 

of a more detailed and operationally specific Catastrophic Incident 

Supplement for the NRP’s Catastrophic Incident Annex had not been 

approved at the time of Hurricane Katrina, although the NRP’s 120-day 

schedule for implementing the supplement had passed. Once finalized, the 

supplement, as supported by agency-level implementation agreements and 

plans, is to serve as the operational framework for implementing the 

Catastrophic Incident Annex for all types of catastrophes. 

 20Pub. L. No. 107-296, 116 Stat. 2135 (2002). 

Page 14 GAO-06-618 Catastrophic Disasters
Capabilities—the ability to carry out specific tasks under particular 

conditions with desired results—are built upon the appropriate 

combination of people, skills, processes, and assets. Catastrophic disasters 

place particularly wide-ranging demands on emergency response 

capabilities. By their very nature, catastrophic disasters involve 

extraordinary levels of mass casualties, damage, or disruption that are 

likely to immediately overwhelm state and local responders. For noncatastrophic disasters, the federal government has historically been in a 

support and assist role, providing resources and other assistance to enable

state and local governments to carry out their responsibilities. However, 

for catastrophic disasters that can overwhelm the ability of state and local 

and voluntary agencies to adequately provide victims with essential 

services, the federal government generally plays a more central role—

providing selected resources where they are needed or likely to be needed.

As we noted in our 1993 report following Hurricane Andrew, where there 

is warning of a catastrophic disaster, federal agencies need to mobilize 

resources and deploy personnel before the disaster strikes so that the 

federal government is ready and able to act quickly to assist the affected 

areas. However, current law—in particular the Stafford Act—does not 

explicitly authorize such pre-declaration activities. 

DHS Policies and Plans 

Have Identified a Strategy 

for Building and Sustaining 

Preparedness, Response, 

and Recovery Capabilities 

Developing the capabilities needed for large-scale disasters is part of an 

overall national preparedness effort that should integrate and define what

needs to be done, where, based on what standards, how it should be done,

and how well it should be done. Along with the NRP and NIMS, DHS has 

developed the National Preparedness Goal, as required by Homeland 

Security Presidential Directive 8 (HSPD-8). Considered as a group, these 

three documents are intended to guide investments in emergency 

preparedness and response capabilities. The NRP describes what needs to 

be done in response to an emergency incident, the NIMS describes how to 

manage what needs to be done, and the National Preparedness Goal 

describes how well it should be done.

The interim National Preparedness Goal is particularly important for 

determining what capabilities are needed, especially for a catastrophic 

disaster. The December 2005 draft National Preparedness Goal defines 

both the 37 major capabilities that first responders should possess to 

prevent, protect from, respond to, and recover from a wide range of 

incidents and the most critical tasks associated with these capabilities. 

An inability to effectively perform these critical tasks would, by definition, 

have a detrimental impact on effective protection, prevention, response, 

and recovery capabilities. Since September 11, 2001, the federal 

government has awarded almost $14 billion in grants and assistance to 

Page 15 GAO-06-618 Catastrophic Disasters
state and local governments to assist in building emergency management 

capabilities. 

Federal Government Is a 

Major Partner in LongTerm Recovery 

Because of the widespread physical and economic damage to the Gulf 

Coast, there are numerous examples of the federal government playing a 

major role in support of state and local recovery efforts. Debris removal 

and repairs to the region’s public infrastructure and residential and 

commercial properties are proceeding, to a significant extent, from federal 

funding designated for the area and much remains to be done. The U.S. 

Army Corps of Engineers is reconstructing the New Orleans levee system 

to fix those parts of the system that failed during Hurricane Katrina. The 

federal role in rebuilding will be particularly important for transportation 

and health infrastructures and federal facilities. 

Our prior work has identified state efforts underway to develop long-term 

rebuilding strategies. In Louisiana, the governor and the mayor of New 

Orleans have charged different groups with guiding various aspects of the

rebuilding efforts. In Mississippi, the Governor’s Commission on Recovery, 

Rebuilding and Renewal was formed to develop a strategy for rebuilding 

the affected areas of Mississippi. On November 1, 2005, the President 

issued Executive Order 13390, which directed the creation of a central

figure in the administration’s efforts to support the Gulf Coast recovery 

and rebuilding phases.21 Specifically, the President directed the Secretary 

of Homeland Security to establish within the department the position of 

Coordinator of Federal Support for the Recovery and Rebuilding of the 

Gulf Coast region. The federal coordinator is responsible for developing

principles and goals, leading the development of federal recovery 

activities, and monitoring the implementation of designated federal 

support. The coordinator also serves as the focal point for managing 

information flow, requests for actions, and discussions with Congress, 

state and local governments, the private sector, and community leaders. 

 21“Establishment of a Coordinator of Federal Support for the Recovery and Rebuilding of 

the Gulf Coast Region,” Exec. Order No. 13390, 70 Fed. Reg. 67327 (2005). 

Page 16 GAO-06-618 Catastrophic Disasters
Beginning in February 2006, several reports from Congress and the 

administration have explored the events surrounding Hurricane Katrina 

and chronicled many weaknesses and some strengths of the preparation 

and response efforts, providing observations and recommendations to 

improve national preparedness for and response to catastrophic disasters. 

Table 1 contains the resulting reports and a brief description of their 

findings. 

Congress and the 

Administration Have 

Engaged in Numerous 

Efforts to Identify and 

Recommend 

Improvements to 

Catastrophic Disaster 

Preparedness, Response, 

and Recovery 

Page 17 GAO-06-618 Catastrophic Disasters
Table 1: Findings in Reports by Congress and the Administration 

Title and author Major findings 

DHS/FEMA Initial Response Hotwash: Hurricane 

Katrina in Louisiana (February 13, 2006) 

Source: FEMA 

Found improvements needed in areas of communications and interoperability; 

FEMA staffing; unified command; logistics and staging; and operating procedures. 

Recommendations for FEMA included: work to strengthen emergency 

management capability at state and local levels; review emergency management 

architecture for response and recovery operations; train, equip, and staff response 

teams; improve the financial management of disasters; improve leadership and 

management; establish command authority in the Joint Field Office (JFO); and 

continue catastrophic planning with federal, state, and local governments.

A Failure of Initiative: Final Report of the House 

Select Bipartisan Committee to Investigate the 

Preparation for and Response to Hurricane

Katrina (February 15, 2006) 

Source: House of Representatives 

House Select Bipartisan Committee

Identified 14 major findings including: critical elements of the NRP were executed 

late, ineffectively or not at all; there was massive communications damage; 

command and control was impaired at all levels, delaying relief; and the military 

played an invaluable role but coordination was lacking, among others. No

recommendations provided. 

The Federal Response to Hurricane Katrina: 

Lessons Learned (February 23, 2006) 

Source: White House Homeland Security 

Council 

Identified 17 critical challenges including National Preparedness, Integrated Use of 

Military Capabilities, Communications, Logistics and Evacuation, Search and

Rescue, Public Safety and Security, Public Health and Medical Support, Human 

Services, Mass Care and Housing, Public Communications, Critical Infrastructure 

and Impact Assessment, Environmental Hazards and Debris Removal, Foreign 

Assistance, Non-Governmental Aid, Training, Exercises, and Lessons Learned, 

Professional Development and Education, Citizen and Community Preparedness. 

Identified 125 recommendations for DHS, DOD, and other federal departments 

and agencies, including 44 that were to be implemented by June 1, 2006. 

A Performance Review of FEMA’s Disaster 

Management Activities in Response to Hurricane 

Katrina (March 31, 2006) 

Source: Department of Homeland Security’s 

Office of Inspector General 

Found FEMA adapted to new response plans with difficulty; FEMA provided record 

levels of support but needs to improve delivery structure; and FEMA needs to 

improve readiness. Identified 38 recommendations. 

Hurricane Katrina: A Nation Still Unprepared: 

Report of the Committee on Homeland Security 

and Governmental Affairs (May 2006) 

Source: U.S. Senate Committee on Homeland

Security and Governmental Affairs 

Found differing roles at different levels of government affected the response; longterm and short-term warnings went unheeded; preparation proved insufficient; 

response at all levels of government was unacceptable; long-term factors 

contributed to poor response; and waste, fraud and abuses were identified. Report 

identified seven foundational recommendations based on identified systemic 

weaknesses and challenges.

Source: GAO analysis of executive branch and congressional reports. 

Page 18 GAO-06-618 Catastrophic Disasters
Our March 2006 testimony, along with the House, Senate, White House 

Homeland Security Council, and DHS reports on the preparation for and 

response to Hurricane Katrina discussed the vital importance of federal, 

state, and local leadership, including clearly defined and well understood 

roles and responsibilities. All the various critiques of Hurricane Katrina 

concluded that leadership at all levels of government should be improved. 

In preparing for, responding to, and recovering from any catastrophic 

disaster, the legal authorities, roles and responsibilities, and lines of 

authority for the preparation and response at all levels of government 

must be clearly defined, effectively communicated, and well understood in 

order to facilitate rapid and effective decision making. For example, 

during Hurricane Katrina, separate roles specified in the NRP and in the 

Stafford Act resulted in leadership uncertainty and may have slowed the 

response, and some of the NRP’s provisions were unclear and may have 

hindered the federal government’s ability to guide a more proactive 

response. DHS has reported taking a number of actions to address 

leadership issues raised in the various Hurricane Katrina reports, 

particularly making revisions to the NRP to clarify roles, responsibilities, 

and lines of authority. Another leadership issue raised in the aftermath of 

the disaster was whether the organizational placement of FEMA is 

appropriate for its mission. 

Our March 2006 testimony, and other reports issued on the preparation for 

and response to Hurricanes Katrina and Rita, have all identified the 

importance of improved leadership and clearly defined and well 

understood roles, responsibilities, and lines of authority at all levels of 

government, especially in times of a catastrophe. In the response to 

Hurricane Katrina there was confusion regarding roles and responsibilities 

under the NRP. This included uncertainty concerning the roles of the 

Secretary of Homeland Security, the Principal Federal Officer (PFO), and 

the Federal Coordinating Officer (FCO), under the NRP. 

Leadership Is Critical 

for Preparing for,

Responding to, and 

Recovering from 

Catastrophic 

Disasters 

Communicating and 

Clearly Defining 

Leadership Roles, 

Responsibilities, and Lines 

of Authority in Advance of 

Catastrophic Disasters Is 

Essential to Effective 

Response 

At the time of Hurricane Katrina, there were three key roles in the 

management of a catastrophic disaster. First, with the passage and 

subsequent implementation of the Homeland Security Act of 2002, the 

Secretary of Homeland Security became the cabinet-level focal point for 

response to natural and man-made crises (such as major disasters and 

terrorist incidents) requiring a coordinated response and developing a 

single, coordinated national response plan for such crises and incidents.

We view this as a strategic role to coordinate federal activities and policy 

from a national standpoint and be directly responsible and accountable to

the President, which is consistent with recommendations we made in 

Page 19 GAO-06-618 Catastrophic Disasters
1993. The revised NRP clearly states that the Secretary of Homeland 

Security, who reports directly to the President, is responsible for declaring 

and managing incidents of national significance, including catastrophic 

incidents. 

The response to Hurricane Katrina identified unresolved issues regarding

lines of authority with respect to the Secretary of Homeland Security and

the FEMA Director, as well as the key officials reporting to them, the PFO 

to the secretary and the FCO to the FEMA Director. For example, in 

response to Katrina, the Secretary of Homeland Security initially 

designated the head of FEMA as the PFO, who appointed separate FCOs 

for Alabama, Louisiana, and Mississippi. It was not, however, clear who 

was responsible for coordinating the overall federal effort at a strategic 

level. Our fieldwork indicated that the lack of clarity in leadership roles 

and responsibilities resulted in disjointed efforts of many federal agencies 

involved in the response, a myriad of approaches and processes for 

requesting and providing assistance, and confusion about who should be 

advised of requests and what resources would be provided within specific 

time frames. The House Select Committee also found difficulties with 

roles and responsibilities, including federal officials’ unfamiliarity with 

their roles and responsibilities under the NRP and NIMS. Likewise, the 

White House Homeland Security Council made numerous 

recommendations, including giving the PFO the same authority as an FCO

to execute responsibilities and coordinate federal response assets. 

According to the White House Homeland Security Council report, giving

the PFO this authority could be accomplished without a change to the 

Stafford Act by simply designating the PFO as an FCO. 

In our March 8, 2006, testimony, we recommended that DHS clarify and

communicate the roles of the secretary, the PFO, and the FCO, consistent 

with the provisions of the Homeland Security Act and the Stafford Act. In 

May 2006, DHS revised the NRP to state that the Secretary of Homeland 

Security may choose to combine the roles of the PFO and FCO in a single 

individual to help ensure synchronized federal coordination for incidents 

other than terrorist incidents.22 In instances where a single PFO/FCO has 

been appointed, the revised NRP states that deputy FCOs will be 

designated for the affected states to support the PFO/FCO. In addition, 

 22The NRP revisions include a Quick Reference Guide that provides a condensed, 23-page

overview of the NRP as modified. 

Page 20 GAO-06-618 Catastrophic Disasters
DHS has pre-designated regional officials who will be PFOs and FCOs in 

the event of an incident of national significance.

The NRP revisions may not fully resolve the leadership issues with respect 

to the PFO and FCO roles. While the secretary may avoid conflicts by 

appointing a single individual to serve as PFO and FCO in non-terrorist 

incidents, confusion may persist if the secretary does not exercise this 

discretion. Furthermore, this discretion does not exist for terrorist 

incidents that may result in a Stafford Act declaration. In a terrorist-caused 

incident, the PFO and FCO roles cannot be combined in a single 

individual, as might be the case in a natural disaster. The revised NRP does 

not specifically provide a rationale for this limitation, although a terrorist 

incident would involve law enforcement and criminal investigation 

activities that the PFO must coordinate with the Attorney General’s 

representative, the FBI Special Agent-in-Charge. Nevertheless, it is not 

clear whether, and to what extent, the PFO’s roles and responsibilities 

might conflict with those of the FCO in a terrorist incident resulting in a 

Stafford Act declaration. Given the persistent confusion about the NRP 

regarding key federal leadership roles and responsibilities in a 

catastrophic disaster, we are recommending that the Secretary of 

Homeland Security rigorously re-test, train, and exercise its recent 

clarification of the roles, responsibilities, and the lines of authority for all 

levels of leadership, implementing changes needed to remedy identified

coordination problems. 

New GAO recommendation to DHS to re-test, train and exercise its recent 

clarification of leadership roles 

DHS should rigorously re-test, train, and exercise its recent clarification of the roles, 

responsibilities, and lines of authority for all levels of leadership, implementing changes 

needed to remedy identified coordination problems. 

For more detailed information about our recommendations, see appendix I. 

Page 21 GAO-06-618 Catastrophic Disasters
We identified an ambiguity in the NRP’s triggering mechanisms that 

existed at the time Hurricane Katrina hit the Gulf Coast—i.e., what actions

were necessary to activate the NRP. The NRP distinguished between 

incidents that required DHS coordination and those that did not. Only 

those requiring DHS coordination, termed “incidents of national 

significance,” triggered activation of the NRP. However, it was not clear 

whether the Secretary of Homeland Security needed to make a formal 

declaration of such an incident to trigger the NRP or whether such an 

incident was automatically triggered by one of four criteria contained in 

Homeland Security Presidential Directive-5 (HSPD-5).23 In our March 2006 

testimony, we recommended that DHS clarify in the NRP whether the 

Secretary of Homeland Security must formally declare an incident of 

national significance to activate the NRP and, if not, whether the secretary 

must take any specific actions when the President, in effect, activates the

NRP by declaring a Stafford Act emergency or major disaster. 

Provisions of the NRP 

Regarding Incidents of 

National Significance Were 

Not Clear at the Time of 

Hurricane Katrina, and 

Revisions Potentially Raise 

New Issues 

The May 25, 2006, revisions to the NRP make clear that the Secretary of 

Homeland Security must formally declare an incident of national 

significance.

24 The four factors stated in HSPD-5 continue to be primary 

criteria for such a declaration, but the revised NRP states that the 

Secretary of Homeland Security is not limited to these criteria and may 

consider other factors in deciding whether to declare an incident of 

national significance. According to the revisions, the key is whether the 

incident is of such severity, magnitude, or complexity that it requires the 

Secretary of Homeland Security to manage the federal response. 

While clarifying the declarations process for incidents of national 

significance, the revised NRP potentially raises new implementation 

issues. First, the May 2006 revisions of the NRP state that the NRP is 

“always in effect,” but it is not clear what this means operationally. 

Previously, the NRP only applied to incidents of national significance, 

 23The HSPD-5 criteria are: (1) a federal department or agency acting under its own 

authority has requested the assistance of the Secretary of Homeland Security; (2) the

resources of state and local authorities are overwhelmed and federal assistance has been

requested by the appropriate state and local authorities, for example, under the Stafford

Act; (3) more than one federal department or agency has become substantially involved in 

responding to an incident; or (4) the Secretary of Homeland Security has been directed by 

the President to assume responsibility for managing a domestic incident. 

24According to the Catastrophic Incident Annex, all catastrophic incidents are Incidents of

National Significance. Implementation of the annex requires a separate catastrophic 

incident designation by the Secretary of Homeland Security.

Page 22 GAO-06-618 Catastrophic Disasters
which were defined as those incidents requiring DHS coordination. Under 

the revised NRP, incidents of national significance are not simply those 

incidents requiring DHS coordination, but those that must be managed 

directly by the Secretary of Homeland Security. While the revised NRP 

makes clear that incidents of national significance must be declared by 

and managed by the Secretary of Homeland Security, the revised NRP also 

applies to incidents of lesser severity that may nevertheless require some 

federal involvement. According to the revised NRP, such incidents are to 

be managed by the federal department or agency with jurisdictional 

authority based on a scaled and flexible implementation of the NRP. There 

is no declarations process for incidents of lesser severity and there are no 

specific plans detailing how agencies are to address such incidents. In the 

absence of any implementation plans or a specific declaration or 

designation process, leadership issues may arise in responding to issues of 

lesser severity. 

Proactive Response 

Provisions of the NRP’s 

Catastrophic Incident 

Annex Were Unclear at the 

Time of Hurricane Katrina, 

and Implementation Issues 

Remain 

The NRP’s Catastrophic Incident Annex also was a source of considerable

criticism after Hurricane Katrina. Under the NRP, a catastrophic incident 

is any natural or manmade incident (including terrorism) that results in 

extraordinary levels of mass casualties, damage, or disruption severely 

affecting the population, infrastructure, environment, economy, national 

morale, and/or government functions. A catastrophic incident could result 

in sustained national impacts over a prolonged period of time; almost 

immediately exceeds resources normally available to state, local, tribal,

and private-sector authorities in the impacted area; and significantly 

interrupts governmental operations and emergency services to such an 

extent that national security could be threatened. The annex describes an 

accelerated, proactive national response to catastrophic incidents and 

establishes protocols to pre-identify and rapidly deploy essential resources 

expected to be urgently needed. At the time of Hurricane Katrina, a draft 

supplement to the annex would have limited the annex’s scope to nonotice or short-notice catastrophic incidents, not incidents that may 

evolve or mature to catastrophic magnitude, which could be the case with

strengthening hurricanes. Importantly, and consistent with a prior GAO 

recommendation, the revised NRP does not include this limitation. While 

stating that the catastrophic incident annex is primarily designed to 

address no-notice or short-notice catastrophic incidents that defy advance 

planning and resource pre-positioning, the revised NRP states that 

projected catastrophic incidents (e.g., hurricanes) are also covered by the 

annex. In the event there is time to assess the requirements and plan for a

catastrophic event, the proactive federal response and pre-positioning of 

assets is to be tailored to address the specific situation. 

Page 23 GAO-06-618 Catastrophic Disasters
A proactive approach to catastrophic disasters when there is warning is 

consistent with recommendations we made in 1993 following Hurricane 

Andrew.25 FEMA generally agreed with our findings and recommendations 

and had begun taking actions to address them. We noted that some of the 

improvements necessary in the overall federal response were outside of 

FEMA’s control, such as Presidential action to strengthen leadership for 

the federal response by designating a key White House or cabinet-level 

official to oversee the federal government’s overall preparedness and 

response activities for catastrophic disasters. In 1996, FEMA became a 

cabinet agency whose director reported directly to the President, 

consistent with our 1993 recommendation to the President. 

The Homeland Security Act of 2002 made FEMA a part of DHS in March 

2003, with its director reporting to the Secretary of Homeland Security. As 

a result of the new national response framework brought about by the 

Homeland Security Act, HSPD-5 and the NRP, the Secretary of Homeland 

Security became the cabinet-level focal point for emergency preparedness

and response, and the principal Federal official for domestic incident 

management. The role assigned to the secretary through this framework is 

consistent with our 1993 recommendation. However, the experience of

Katrina revealed some of the same problems that led to our 1993 

recommendation, including a lack of clarity with regard to federal 

leadership roles and responsibilities for the response. For example, the 

secretary promptly designated the Director of FEMA as PFO under the 

NRP, whose responsibilities included serving as the secretary’s personal 

representative on the scene, providing situational awareness, and 

coordinating the federal response. However, as noted in subsequent 

testimony and congressional reports, problems arose with regard to the 

FEMA Director’s reporting relationship with the secretary and the White 

House during the response, and it was unclear who was directly 

accountable to the President for the overall federal strategic coordination 

and management of the incident. The Secretary of Homeland Security did 

not perform this role, and the Director of FEMA was not in a position to 

effectively perform this role. As noted above, the revised NRP addresses 

this issue with respect to incidents of national significance, by requiring 

the Secretary of Homeland Security to declare such incidents, including 

those deemed catastrophic, and to manage the federal response following 

 25 See GAO, Disaster Management: Improving the Nation’s Response to Catastrophic 

Disasters, GAO/RCED-93-186 (Washington, D.C.: July 23, 1993); and Disaster Management: 

Recent Disasters Demonstrate the Need to Improve the Nation’s Response Strategy, 

GAO/T-RCED-93-46 (Washington, D.C.: May 25, 1993). 

Page 24 GAO-06-618 Catastrophic Disasters
such a declaration. Maintaining at the secretary level the strategic role,

described earlier, of coordinating federal activities and policy from a 

national standpoint, and being directly responsible and accountable to the 

President, is critical to ensuring an efficient federal response and vital 

presidential leadership during a catastrophic disaster. These 

responsibilities should be performed by the secretary and not delegated to

the PFO or FCO in such circumstances. 

We continue to believe that our other 1993 recommendations still apply in

terms of improving the nation’s response to catastrophic disasters. For 

example, the NRP’s catastrophic incident annex needs to be supported 

with more robust and detailed operational implementation plans. In 

addition, we are renewing our recommendation that Congress should 

consider giving federal agencies explicit authority to take actions to 

prepare for catastrophic disasters when there is warning. In 1993 we found 

that federal response time could be reduced by encouraging agencies to do 

as much advance preparation as possible prior to a disaster declaration.

When there is early warning, as there is for hurricanes, DOD and other 

federal agencies need to mobilize resources and deploy personnel before 

the catastrophe strikes. However, current law—in particular, the Stafford

Act—does not explicitly authorize such pre-declaration activities. 

Therefore, federal agencies may fail to undertake advance preparation, 

because of uncertainty over whether FEMA will request their assistance 

and whether costs incurred before a disaster declaration will ultimately be 

reimbursed by FEMA. 

New GAO matter for congressional consideration

Congress should give federal agencies explicit authority to take actions to prepare for 

catastrophic disasters when there is warning.

For more detailed information about our recommendations, see appendix I. 

Our review of the NRP and its catastrophic incident annex—as well as 

lessons from Hurricane Katrina—demonstrate the need for DHS and other 

federal agencies to develop robust and detailed operational plans to 

implement the catastrophic incident annex and its supplement in 

preparation for and response to future catastrophic disasters. DHS has not 

yet released the supplement to the catastrophic incident annex, more than 

a year after Katrina and its original target date. The catastrophic incident 

supplement is intended as the more operationally specific companion to 

the catastrophic incident annex. For example, the September 2005 draft 

Page 25 GAO-06-618 Catastrophic Disasters
supplement includes operations to be carried out by local, state, and 

federal responders; detailed execution schedules and implementation 

strategies; functional capability overviews (such as coverage for 

transportation support); and key responsibilities of federal departments 

and agencies. Until DHS finalizes and distributes the supplement, neither 

DHS nor other federal agencies that have responsibilities under the 

supplement can finalize the detailed implementation plans required to 

make the NRP fully operational for catastrophic disasters. Therefore, as 

noted in our March testimony, we are recommending that DHS direct that

the NRP base plan and its Catastrophic Incident Annex be supported by 

more robust and detailed operational implementation plans, particularly 

the Catastrophic Incident Supplement to the NRP. Such operational plans 

should, for example, further define and leverage those military capabilities 

that might be needed in a catastrophic disaster.26

New GAO recommendation to DHS for detailed and robust implementation plans

for the NRP 

DHS should direct that the NRP base plan and its Catastrophic Incident Annex be 

supported by more robust and detailed operational implementation plans, particularly the 

Catastrophic Incident Supplement to the NRP. Such operational plans should, for 

example, further define and leverage those military capabilities that might be needed in a

catastrophic disaster. 

For more detailed information about our recommendations, see appendix I. 

Federal Coordination 

Issues with the NRP Have 

Not Been Fully Addressed 

by Recent Revisions 

Our ongoing Hurricane Katrina-related work has identified other examples

of possible implementation issues within the NRP related to coordination

within and across federal government entities. These involve coordination

issues for search and rescue, the military response, worker safety and the 

role and responsibilities of the Red Cross. First, the NRP did not fully 

address search and rescue missions. While tens of thousands of people 

were rescued through the efforts of the military, civilian government, and 

private rescuers, the lack of clarity in search and rescue plans led to 

operations that, according to aviation officials, were not as efficient as 

 26GAO, Hurricane Katrina: GAO’s Preliminary Observations Regarding Preparedness, 

Response, and Recovery, GAO-06-442T (Washington, D.C.: Mar. 8, 2006). 

Page 26 GAO-06-618 Catastrophic Disasters
they should have been. Under the National Search and Rescue Plan27 the 

Coast Guard ordinarily had responsibility for providing or arranging 

maritime search and rescue services, and the Air Force ordinarily had 

responsibility for providing or arranging non-maritime search and rescue. 

The plan also called on DOD to support civil search and rescue, and it 

stated that DOD and Coast Guard commands should provide their facilities 

for civil search and rescue to the fullest extent practicable. While the NRP 

acknowledged the existence of the National Search and Rescue Plan, the 

NRP did not specifically address how the Coast Guard and the Air Force 

organizational responsibilities in the National Search and Rescue Plan 

coincided with the NRP’s urban search and rescue annex. In addition, the 

National Search and Rescue Plan had not been updated to reflect the NRP. 

As a result of the lack of clear search and rescue guidance, the aviation

portion of military search and rescue operations was not fully integrated 

with the helicopter search and rescue operations of the Coast Guard and 

other rescuers. Moreover, no one had the total picture of the missions that 

had been resourced and the missions that still needed to be performed 

during the response to Hurricane Katrina. 

Second, the military mounted a massive response to Hurricane Katrina 

that saved many lives and greatly assisted recovery efforts. However, the 

NRP made little distinction between the military response to smaller, 

regional disasters and the military response to large-scale, catastrophic 

natural disasters even though past disasters had shown that the military 

tends to play a much larger role in catastrophes. We found a lack of 

understanding within the military and among federal, state, and local 

responders as to the types of assistance and capabilities that DOD might 

provide in the event of a catastrophe—for example, timely damage 

assessments or communications capabilities—the timing of this 

assistance, and the respective contributions of the active-duty and 

National Guard forces. For example, neither the NRP, DHS, nor DOD had 

fully identified the military’s extensive reconnaissance assets or 

communications capabilities that could be brought to bear in a

catastrophe. In the absence of this planning, some of the military’s 

available assets were never requested or proactively deployed. 

 27The National Search and Rescue Plan (1999) provides an overall plan for coordination of 

search and rescue operations, the effective use of all available resources, mutual 

assistance, and efforts to improve such cooperation and services. The goal of the plan is to 

integrate available resources that can be used for search and rescue into a cooperative 

network for greater protection of life and property and to ensure greater efficiency and 

economy. 

Page 27 GAO-06-618 Catastrophic Disasters
To improve the military response to catastrophic disasters, we have 

recommended that the Secretary of Defense (1) provide proposed 

revisions of the NRP to DHS that addresses the proactive functions the 

military is expected to make during a catastrophic incident, and 

(2) establish milestones and expedite the development of detailed plans 

and exercises to fully account for the unique capabilities and support that 

the military is likely to provide to civil authorities in response to the full 

range of domestic disasters, including catastrophic disasters. Furthermore, 

the plans and exercises should specifically address the use of 

reconnaissance, communications, and search and rescue capabilities; 

integration of active component and National Guard and Reserve forces;

and the role the military might be expected to play in logistics.28 DOD 

should direct the National Guard Bureau to work with state governors to 

develop and maintain a list of the types of capabilities the National Guard 

will likely provide in response to domestic natural disasters. DOD 

commented on our recommendations, partially concurring with each of 

them: DOD said that proactive military functions can be identified in all 

15 major disaster scenarios and said it is working with the Department of 

Homeland Security to revise the NRP. While DOD stated that the long-term 

focus of the U.S. government should be to develop more robust domestic 

disaster capabilities within the Department of Homeland Security, it 

acknowledged that DOD will need to assume a more robust response role 

in the interim period, when other responders lack the resources and 

expertise to handle a particular disaster. DOD also listed a number of 

steps it is taking to improve its disaster response planning and exercises. It 

also said that consistent with its Strategy for Homeland Defense and Civil 

Support the active component should complement, but not duplicate, the 

National Guard’s likely role as an early responder. DOD said that logistics 

planning and execution are the clear responsibility of FEMA and 

individual states, and DOD would remain ready in a supporting role. 

However, we continue to believe that DOD should plan and prepare to 

assume additional emergency support function responsibilities during 

catastrophic disasters when other responders may be overwhelmed. 

 28GAO-06-643. 

Page 28 GAO-06-618 Catastrophic Disasters
Recent GAO recommendations to DOD improve the 

military’s response to catastrophic natural disasters DOD response 

DOD should provide proposed revisions of the NRP to 

DHS that address the proactive functions the military is 

expected to perform during a catastrophic incident. 

DOD is working with DHS to 

revise the NRP and 

acknowledged that DOD will 

need to assume a more 

robust response role when 

other responders lack the 

resources and expertise to 

handle a particular disaster. 

DOD should establish milestones and expedite the 

development of detailed plans and exercises that address 

specifically the use of various military resources and 

role(s) the military might be expected to play in order to 

fully account for the unique capabilities and support that 

the military is likely to provide to civil authorities in 

response to the full range of domestic disasters, including 

catastrophic disasters. Plans and exercise should address 

the use of (1) reconnaissance, communication and search 

and rescue capabilities; (2) active and reserve forces; and 

(3) possible logistics role for the military. 

DOD detailed a number of 

actions it is taking to 

enhance its disaster planning 

and exercises.

DOD should direct the National Guard Bureau to work 

with state governors to develop and maintain a list of 

types of capabilities the National Guard will likely provide 

in response to domestic natural disasters. 

DOD partially concurred with 

this recommendation. DOD 

was developing scalable 

capability packages. 

For more detailed information about our recommendations, see appendix I.

Third, our ongoing work examining worker safety issues has found that 

the Department of Labor’s Occupational Safety and Health Administration

(OSHA) and FEMA officials disagreed about which agency was 

responsible for ensuring the safety and health of response and recovery 

workers. OSHA and FEMA disagreed over who had the leadership role as

the Safety and Health Coordinator at the Joint Field Office in each state 

and in the field. This lack of clarity about each other’s roles and 

procedures resulted in delayed implementation of the NRP’s Worker 

Safety and Health Support Annex. Following a review of the draft of this 

report, OSHA reported that their agency and FEMA have worked together 

to develop procedures for role of the Safety and Health Coordinator in the 

Joint Field Office and for the NRP’s Worker Safety and Health Support 

Annex. 

Lastly, the Red Cross and FEMA also had differing views about their roles 

and responsibilities under Emergency Support Function-6 (ESF-6) of the 

NRP, which hampered efforts to coordinate federal mass care assistance. 

The two organizations differed in their understanding of the role of the 

ESF-6 coordinator, according to a key FEMA official tasked with providing 

strategic vision and leading efforts to coordinate federal mass care, 

Page 29 GAO-06-618 Catastrophic Disasters
housing, and human services assistance. This difference in expectations 

about the role of the ESF-6 coordinator created tension between FEMA 

and the Red Cross and affected the organizations’ working relationship. 

Additionally, Red Cross staffing policies, which directed staff and 

volunteers to rotate every 2 to 3 weeks and the absence of a

comprehensive FEMA system to track Red Cross requests for assistance 

also hindered the Red Cross and FEMA’s working relationship during 

hurricane relief efforts. Red Cross and FEMA officials have stated they are 

working to clarify future roles and responsibilities. 

To clarify roles and responsibilities within ESF-6 for the 2006 hurricane 

season, and to help ensure that FEMA’s resource tracking system will 

meet the needs of those requesting FEMA assistance, we have

recommended that the Secretary of DHS should direct FEMA to work with 

the Red Cross as soon as possible to reach agreement on the operating 

procedures that they will both use in the event of an incident of national 

significance and ensure that FEMA obtains input from the Red Cross as it 

develops a resource tracking system. DHS did not provide a response to 

our recommendations, noting that FEMA was actively preparing for the 

hurricane season. We have also recommended that the Chief Executive 

Officer of the Red Cross implement ESF-6 staffing strategies that better 

facilitate the development of working relationships and retain institutional 

knowledge.29 

The Red Cross endorsed and is taking actions, as applicable, to address, 

two of our recommendations. For example, the Red Cross said it has been

working closely with FEMA in recent months to develop and finalize a 

memorandum of understanding that outlines areas of mutual support and 

cooperation with respect to response and recovery in presidentiallydeclared disasters and emergencies. Overall, the Red Cross agreed with 

our conclusion that coordination between FEMA and the Red Cross could 

be improved for the 2006 hurricane season. With respect to our 

recommendation about staffing strategies, the Red Cross said that it is in 

the process of hiring ESF-6 reservists who will be deployed for extended 

periods of time to perform Red Cross ESF-6 mass care functions at the 

federal level. 

 29GAO, Hurricanes Katrina and Rita: Coordination between FEMA and the Red Cross 

Should Be Improved for the 2006 Hurricane Season, GAO-06-712 (Washington, D.C.: 

June 8, 2006). 

Page 30 GAO-06-618 Catastrophic Disasters
Recent GAO recommendations to

improve FEMA and Red Cross

coordination DHS and Red Cross response

DHS should direct FEMA to work with the 

Red Cross as soon as possible to reach 

agreement on the operating procedures that 

they will both use in the event of an incident 

of national significance. 

DHS should ensure that FEMA obtains input

from the Red Cross as it develops a 

resource tracking system. 

The Red Cross commented that it has 

been working closely with FEMA in recent 

months to develop and finalize a 

memorandum of understanding that 

outlines areas of mutual support and 

cooperation with respect to response and 

recovery in presidentially-declared 

disasters and emergencies. 

The Chief Executive Officer of the Red 

Cross should implement ESF-6 staffing 

strategies that better facilitate the 

development of working relationships and 

retain institutional knowledge. 

The Red Cross said that it is in the process 

of hiring ESF-6 reservists who will be 

deployed for extended periods of time to 

perform Red Cross ESF-6 mass care 

functions at the federal level. 

For more detailed information about our recommendations, see appendix I. 

DHS Reported Taking 

Some Actions to Improve 

Leadership in Response to 

Findings in Congress’ and 

the Administration’s 

Reviews 

In addition to changes to the NRP, DHS has reported taking other actions 

to improve DHS leadership during major disasters. In July 2006, Secretary 

of Homeland Security Chertoff sent letters to the governors of Alabama, 

Louisiana, and Mississippi identifying the PFO and FCO for their 

respective states with the purpose of permitting coordinated, collaborative 

federal, state, pre-disaster planning and communications. Each of these 

letters differed somewhat in content, but generally summarized the 

agreements on DHS’s assistance for each state, including pre-positioned 

supplies and equipment and identified key federal and state roles and 

responsibilities in the event of a catastrophic event. Each letter also 

emphasized that evacuation “is fundamentally a state and local

responsibility.” Similar letters were also sent to the chief executive of all 

the states and territories, according to DHS. 

DHS has also reported taking other actions to improve DHS leadership

during major disasters through communications such as press releases, 

speeches by top officials, and congressional testimonies by the Secretary 

of Homeland Security, the Undersecretary for Preparedness, the recently 

confirmed Undersecretary for Federal Emergency Management (who is 

also the FEMA Director), and FEMA’s Director of Operations. These 

reported actions include improvements to national preparedness and 

integrating the use of the military’s capabilities. Table 2 lists the White 

House Homeland Security Council recommendations regarding leadership, 

with the White House Homeland Security Council report’s “critical action” 

recommendations. According to DHS officials, they were to have 

implemented 11 recommendations that the White House Homeland 

Page 31 GAO-06-618 Catastrophic Disasters
Security Council said were essential for the 2006 hurricane season. 

However, DHS has not provided us with the documentation needed to

verify these actions. DHS officials have stated that they have put a more 

experienced senior leadership team in place at FEMA and created a 

National Operations Center to improve coordination and situational 

awareness. 

Page 32 GAO-06-618 Catastrophic Disasters
Table 2: Implementation of White House Homeland Security Council Recommendations for the 2006 Hurricane Season: 

Recommendations Related to Leadership Issues 

Recommendation related to leadership 

Primary agency(ies) 

responsible for

implementation 

Supporting agency(ies)

responsible for

implementation 

Critical Action Recommendation: Ensure co-location of relevant 

federal, state, and local decision-makers, including leaders of state 

National Guards, to enhance unity of effort. 

Department of Homeland

Security 

All federal agencies 

Critical Action Recommendation: For events preceded by warning, 

ensure preparations to pre-position a fully resourced and integrated 

interagency Federal Joint Field Office (JFO) to coordinate and, if 

necessary, direct federal support to the disaster. 

Department of Homeland

Security 

Office of Management and 

Budget, Department of 

Defense 

Critical Action Recommendation: Co-locate a single Department of 

Defense point of contact at the JFO and current FEMA regional 

offices to enhance coordination of military resources supporting the 

response. 

Department of Defense, 

Department of Homeland

Security 

N/A 

Critical Action Recommendation: Identify and develop rosters of 

federal, state, and local government personnel who are prepared to 

assist in disaster relief. 

Department of Homeland

Security 

All federal agencies 

Critical Action Recommendation: Enhance ongoing review of state 

evacuation plans and incorporate planning for continuity-ofgovernment to ensure continuation of essential and emergency 

services. 

Department of Homeland

Security 

Homeland Security Council

Establish an interagency team of senior planners with appropriate 

emergency management experience to conduct a comprehensive, 

90-day review of the NRP and the NIMS. 

Department of Homeland

Security 

All federal agencies 

Revise the NRP to address situations that render state and local 

governments incapable of an effective response. 

Department of Homeland

Security 

All federal agencies 

PFO should have the authority to execute responsibilities and 

coordinate federal response assets. 

Department of Homeland

Security 

N/A 

Establish National Information Requirements and a National 

Information Reporting Chain. 

Department of Homeland

Security 

All federal agencies 

Establish the Disaster Response Group. Homeland Security Council Members of the Homeland

Security Council 

Develop recommendations for revision of the NRP to delineate the 

circumstances, objectives, and limitations of when DOD might 

temporarily assume the lead for the federal response to a 

catastrophic incident. 

Department of Homeland

Security, Department of 

Defense 

N/A 

Revise the Immediate Response Authority policy to allow 

commanders, in appropriate circumstances, to exercise this 

authority even without a request from local officials. 

Department of Defense N/A 

Establish standards for “pushing” the pre-positioning of federal 

assets to states and locals, in the case of an imminent catastrophe. 

Department of Homeland

Security 

All federal agencies 

Source: GAO analysis of DHS and Homeland Security Council data

Note: N/A = not applicable 

Page 33 GAO-06-618 Catastrophic Disasters
FEMA’s performance problems in responding to Hurricane Katrina have 

been well documented in the several reports. In addition to the problems 

related to roles and responsibilities and lines of authority previously 

discussed, the House Select Committee noted that (1) senior officials were 

ill prepared due to their lack of experience and knowledge of the required 

roles and responsibilities prescribed by the NRP; (2) having lost a number 

of top disaster specialists, senior leaders, and other experienced personnel 

since 2002, DHS and FEMA lacked adequately trained and experienced 

staff for the Katrina response; and (3) FEMA’s logistics systems were 

unable to support large-scale logistical challenges. There is concern 

among members of Congress that the causes of FEMA’s response and 

recovery problems may stem from FEMA’s organizational placement and 

its budgetary relationship within DHS. 

As a Result of FEMA’s

Performance during 

Hurricane Katrina,

Questions Have Been 

Raised about Its 

Organizational Placement 

Different approaches have been suggested for addressing FEMA’s 

performance problems in responding to Hurricane Katrina. The White 

House Homeland Security Council report’s recommendations covered 

areas such as improving DHS expertise and experience, development of a 

national crisis communications system, and development of DHS regions 

that are fully staffed, trained, and equipped to manage and coordinate all 

preparedness activities and any emergency that may require a substantial

federal response. There are some proposals in Congress that would keep

FEMA within DHS, but statutorily reorganize the agency’s responsibilities 

and lines of authority. Other proposals would remove FEMA from DHS 

and reconstitute it as an independent agency, much as it was prior to the 

creation of DHS. As we stated in our March 8 and May 9, 2006, testimonies, 

organizational changes alone, while potentially important, are not enough

to adequately address the underlying systemic conditions that resulted in 

FEMA’s performance problems. In our view, a number of factors may be 

ultimately more important to FEMA’s success in responding to and 

recovering from future disasters than its organizational placement. 

Conditions underlying FEMA’s performance during Hurricane Katrina 

involved the experience and training of DHS or FEMA leadership; the 

clarity of FEMA’s mission and related responsibilities and authorities to 

achieve mission performance expectations; the adequacy of its human, 

financial, and technological resources; and the effectiveness of planning,

exercises, and related partnerships. These issues must be addressed 

whether or not FEMA remains in DHS. For example, we believe that the

position of FEMA Director and other key FEMA leadership and managerial 

positions could benefit from having statutory professional qualifications

requirements. In addition, Congress should consider a term appointment 

for the FEMA Director and other selected positions. 

Page 34 GAO-06-618 Catastrophic Disasters
If an organizational change remains under consideration, our past work 

could be helpful. Before the formation of DHS in 2003, we testified before

the House Select Committee on Homeland Security that reorganizations of 

government agencies frequently encounter start-up problems and 

unanticipated consequences, are unlikely to fully overcome obstacles and

challenges, and may require additional modifications in the future.30 Some 

considerations from our prior work that are relevant to FEMA’s 

organizational placement include. 

• Mission Relevancy: Is homeland security a major part of the agency

or program mission? Is it the primary mission of the agency or

program? 

• Similar Goal and Objectives: Does the agency or program being 

considered share primary goals and objectives with the other

components and programs in the department as a whole? 

• Leverage Effectiveness: Does the agency or program under 

consideration create synergy and help to leverage the effectiveness 

of other agencies and programs within the department as a whole? 

• Gains through Consolidation: Does the agency or program being 

considered improve the efficiency and effectiveness of homeland 

security missions through eliminating duplications and overlaps, 

closing gaps, and aligning or merging common roles and 

responsibilities? 

In addition, the dispersion of responsibility for preparedness and response 

across more than one federal agency was a problem we identified during 

the formation of DHS. When Congress created DHS, it separated FEMA’s 

responsibilities for preparedness and response activities into two DHS 

directorates. Responsibility for preparedness for terrorism disasters was 

placed in the department’s Border and Transportation Security 

Directorate, which included FEMA’s Office of National Preparedness. 

Other types of FEMA disaster preparedness and response efforts were 

transferred to the department’s Emergency Preparedness and Response 

Directorate, which included FEMA. In January 2003, we observed that this

organizational arrangement would challenge FEMA in ensuring the 

effective coordination of preparedness and response efforts and 

 30GAO, Homeland Security: Critical Design and Implementation Issues GAO-02-957T 

(Washington, D.C.: July 17, 2002). 

Page 35 GAO-06-618 Catastrophic Disasters
enhancing the provision and management of disaster assistance for 

efficient and effective response. A division of responsibility remains under 

the recent DHS reorganization resulting from Secretary Chertoff’s Second

Stage Review. Preparedness efforts—including planning, training, 

exercising, and funding—are consolidated into a Preparedness 

Directorate, while FEMA maintains responsibility for response and 

recovery missions and reports directly to the Secretary of Homeland 

Security.31 Secretary Chertoff has stated that the reorganization would 

refocus FEMA on its historic mission of response and recovery. 

Legislation has been introduced in both the House and Senate that would

reorganize the emergency management structure of the federal 

government. Two of the bills, for example, would amend the Homeland 

Security Act to create a new emergency management organization within 

DHS that would combine FEMA and the Preparedness Directorate.32

Developing the capabilities needed for large-scale disasters is part of an 

overall national preparedness effort that is designed to integrate and 

define what needs to be done, where, based on what standards, how it 

should be done, and how well it should be done. The nation’s experience 

with Hurricane Katrina reinforces some of the concerns surrounding the 

adequacy of the nation’s capabilities in the context of a catastrophic 

disaster—particularly for capabilities such as the assessment of the 

disaster’s effects, communications, logistics of supplies and services, and

mass care and sheltering of victims. Ensuring that needed capabilities are 

available requires effective planning and coordination and training and 

exercises whereby capabilities are realistically tested, and problems are 

identified and subsequently addressed across all stakeholders. DHS has 

reported taking some actions to improve capabilities in response to 

findings in Congress’ and the administration’s reviews. However, ongoing 

work is still needed by DHS to address FEMA’s significant human resource 

challenges (e.g., a large number of open positions, skill gaps, and 

succession planning challenges). Finally, risk management principles can 

be applied as part of the development of capabilities to guide federal, 

Enhanced Capabilities 

for Catastrophic 

Response and 

Recovery Are Needed 

 31As a result of the Secretary’s Second Stage Review, the Director of FEMA also became the

Undersecretary of Emergency Management. 

32See United States Emergency Management Authority Act of 2006, S. 3595, 109th Cong. 

§ 504 (2006); National Emergency Management Reform and Enhancement Act of 2006, 

H.R. 5351, 109th Cong. § 502(b) (2006). 

Page 36 GAO-06-618 Catastrophic Disasters
state, and local decision making by thinking about risk systematically 

within the normal cycle of development and implementation at all levels.

Capabilities Were Not 

Adequate for a 

Catastrophic Disaster 

The various reports and our own work on FEMA’s performance before,

during, and after Hurricane Katrina suggest that FEMA’s human, financial, 

and technological resources and capabilities were insufficient to meet the 

challenges posed by the unprecedented degree of damage and the 

resulting number of hurricane victims. For example, the Senate’s report 

concluded that FEMA did not have the resources to fulfill the mission and 

respond effectively in a catastrophic event and recommended that DHS 

develop the national capabilities—especially adequate surge capacity—it 

needs to respond to catastrophic disasters, ensuring it has sufficient fulltime staff, response teams, contracting personnel, and adequately trained

and sufficiently staffed reserve corps to ramp up capabilities, when 

needed. The Senate report also identified the need for DHS to complete 

and/or adopt technology and information management systems to 

effectively manage catastrophic disaster-related activities. The report 

concluded that resources are needed for staffing and preparation of 

regional strike teams, better development of a trained cadre of reservists, 

and the development of new logistics capabilities. FEMA’s assessment of 

its initial response concluded that the agency needed to lead an audit of

current staffing capability and workforce demands for staff in a severe or

catastrophic event and determine the number of personnel available to 

serve in each position or unit for such an event. Their assessment also 

concluded that FEMA needs to develop a communications suite that 

operates independently of normal communications infrastructure and is 

able to be moved into disaster locations. Similarly, the White House 

Homeland Security Council report identified the need for each homeland 

security region to have access to the resources, equipment, and personnel 

needed to establish a self-sufficient, temporary Joint Field Office to direct 

response and recovery efforts anywhere within the region. 

In developing its lessons learned from Hurricane Katrina, the White House 

Homeland Security Council has recommended that future preparedness of 

the federal, state, and local authorities should be based on the risk, 

capabilities, and needs structure of the National Preparedness Goal. More 

specifically, the White House Homeland Security Council recommended 

that the National Preparedness Goal and its target capabilities list should 

be used, for example, in (1) defining required capabilities and what levels 

of those capabilities are needed, including those within the purview of the 

federal government; (2) developing mutual aid agreements and compacts 

Page 37 GAO-06-618 Catastrophic Disasters
informed by the National Preparedness Goal’s requirements; and 

(3) developing strategies to meet required levels of capabilities that 

prioritize investments on the basis of risk. 

Developing the capabilities needed for large-scale disasters is part of an 

overall national preparedness effort that is designed to integrate and 

define what needs to be done, where, based on what standards, how it 

should be done, and how well it should be done. The NRP defines 

“preparedness” as the “range of deliberate, critical tasks and activities 

necessary to build, sustain, and improve the operational capability to 

prevent, protect against, respond to, and recover from domestic incidents. 

Preparedness is a continuous process involving efforts at all levels of 

government and between government and private-sector and

nongovernmental organizations to identify threats, determine 

vulnerabilities, and identify required resources.” In our earlier work on the 

National Preparedness Goal, we observed that if properly planned and 

executed, the goal and its related products, such as program 

implementation plans and requirements, may help guide the development 

of realistic budget and resource plans for an all-hazards national 

preparedness program.33 However, questions remain regarding what 

should be expected in terms of the expanded capabilities and mutual aid 

needed from other jurisdictions to meet the demands of a catastrophic 

disaster. The nation’s experience with Hurricane Katrina reinforces some 

of the questions surrounding the adequacy of capabilities in the context of 

a catastrophic disaster—particularly in the areas of (1) situational 

assessment and awareness, (2) emergency communications, 

(3) evacuations, (4) search and rescue, (5) logistics, and (6) mass care 

and sheltering. 

Situational assessment and awareness activities are a critical capability 

common across all phases of an incident (i.e., preparedness, response, and 

recovery), to immediately estimate services needed by communities and 

disaster victims. The NRP notes that following a disaster, state and local 

governments are responsible for conducting initial damage assessments, 

but it also notes that state and local officials could be overwhelmed in a 

catastrophe. Our prior work has pointed out that the NRP does not specify 

the proactive means or capabilities the federal government should use to 

conduct damage assessments and gain situational awareness when the 

Situational Assessment and 

Awareness 

 33 GAO, Homeland Security: DHS' Efforts to Enhance First Responders’ All-Hazards 

Capabilities Continue to Evolve, GAO-05-652 (Washington, D.C.: July 11, 2005). 

Page 38 GAO-06-618 Catastrophic Disasters
responsible state and local officials are overwhelmed. For example, the 

military has significant assets to provide situational assessment and 

awareness, and although some of its capabilities were employed during 

Hurricane Katrina, there had been no advance planning among federal,

state, and local responders as to how DOD might support this capability in 

the event of a catastrophic disaster. As a result, response efforts were 

hampered by the federal government’s failure to fully use its available 

assets to conduct timely, comprehensive damage assessments in Louisiana 

and Mississippi. In 1993, we also identified the failure to quickly assess 

damage and gain situational awareness as a problem during Hurricane 

Andrew in 1992.34 We recommended then that FEMA improve its 

catastrophic disaster response capability by using existing authority to 

aggressively respond to catastrophic disasters, assessing the extent of 

damage, and then advising state and local officials of identified needs and 

the federal resources available to address them. 

Our analysis shows that neither the NRP nor DOD’s functional plan 

specifically called for the proactive use of the military’s extensive 

reconnaissance assets as part of a proactive response to catastrophic 

incidents. About 4 days after Katrina’s landfall the military began providing 

imagery data from some of its reconnaissance assets to its forces and 

civilian agencies, although some information was classified due to its 

source and could not be shared directly with civilian agencies. Also, some 

agencies were not able to access some of the available information 

because the data files were too large to download. A National Guard 

Hurricane Katrina after-action review reported that the adjutants general 

in Mississippi and Louisiana required real-time imagery that the military 

community should have been able to provide, but did not. Because state 

and local officials were overwhelmed and the military’s extensive 

reconnaissance capabilities were not effectively leveraged, responders 

began organizing and deploying without fully understanding the extent of 

the damage or the required assistance. In contrast, DOD officials told us 

that almost immediately after Hurricane Rita struck Louisiana and Texas 

in September 2005, considerable assets were made available to assess 

damage, primarily because of lessons learned from Hurricane Katrina. 

 34See GAO, Disaster Management: Improving the Nation’s Response to Catastrophic 

Disasters, GAO-93-186 (Washington, D.C.: July 23, 1993); and Disaster Management: 

Recent Disasters Demonstrate the Need to Improve the Nation’s Response Strategy, 

GAO-93-46 (Washington, D.C.: May 25, 1993). 

Page 39 GAO-06-618 Catastrophic Disasters
To improve the military response to catastrophic disasters, we have 

recommended that the Secretary of Defense establish milestones and 

expedite the development of detailed plans and exercises to fully account 

for the unique capabilities and support that the military is likely to provide 

to civil authorities in response to the full range of domestic disasters, 

including catastrophes; and that the plans and exercises should 

specifically address the use of reconnaissance capabilities.35 In May 2006, 

the Assistant Secretary of Defense for Homeland Defense testified that 

U.S. Northern Command was developing a reconnaissance annex to its 

Defense Support to Civil Authorities Contingency Plan and had tested the 

annex’s concepts during an 11-day exercise in May 2006. 

Recent GAO recommendations to DOD 

to improve the military response to 

catastrophic disasters DOD response 

DOD establish milestones and expedite the 

development of detailed plans and 

exercises capabilities and support to civil 

authorities in response to the full range of 

domestic disasters, including catastrophes; 

the plans and exercises should specifically 

address the use of reconnaissance 

capabilities. 

U.S. Northern Command was developing a 

reconnaissance annex to its Defense 

Support to Civil Authorities Contingency 

Plan and had tested the annex’s concepts 

during an 11-day exercise in May 2006. 

For more detailed information about our recommendations, see appendix I. 

Emergency communications is a critical capability common across all 

phases of an incident. Agencies communications systems during a 

catastrophic disaster must first be operable, with sufficient 

communications to meet everyday internal and emergency communication 

requirements. Once operable, they then should have communications 

interoperability whereby public safety agencies (e.g., police, fire, 

emergency medical services, etc.) and service agencies (e.g., public works, 

transportation, and hospitals) can communicate within and across 

agencies and jurisdictions in real time as needed. Hurricane Katrina 

caused significant damage to the communication infrastructure in 

Louisiana and Mississippi, which further contributed to a lack of 

situational awareness for military and civilian officials. Hurricane Katrina 

destroyed or severely degraded many commercial landline and cellular 

telephone systems. In addition, emergency radio systems usage exceeded

their capacity, making it difficult to establish necessary connections 

Emergency Communications 

 35GAO-06-643. 

Page 40 GAO-06-618 Catastrophic Disasters
between officials and responders at the local, state, and federal levels, and 

to implement other capabilities. For example, even when local officials 

were able to conduct damage assessments, the lack of communications 

assets caused delays in transmitting the results of the assessments. As a 

result, it was difficult for officials to share situational awareness. 

The military, other government agencies, and public companies all have 

extensive communications assets and capabilities, but DHS has 

responsibility for coordinating communications for disaster response 

operations under the NRP. Our work has found, however, that neither 

DHS nor DOD fully identified the extensive military communication 

capabilities that could be leveraged as part of a proactive federal response 

to catastrophic disasters.36 For example, although DOD’s emergency 

response plan addressed internal military communications requirements, 

DOD did not address the communication requirements of communities 

affected by a catastrophic natural disaster, and it did not address 

coordination with civilian responders. As previously noted, we have made 

recommendations to the Secretary of Defense to develop detailed plans 

and exercises regarding the unique capabilities and support, such as 

communications capabilities, that the military is likely to provide to civil 

authorities.37 In May 2006, the Assistant Secretary of Defense for Homeland 

Defense testified that DOD had taken a number of steps to increase 

communications capabilities in regions affected by disasters. These 

include authorizing the Command of U.S. Northern Command to deploy 

communications capabilities and develop pre-scripted requests for 

assistance for deployable communications options. 

 36GAO-06-643. 

37Typically, military equipment cannot communicate with civilian police, fire, and 

emergency medical systems unless it is augmented with specialized equipment. During

Hurricane Katrina, the military and civilian agencies deployed mobile communication vans 

that were able to connect different communications systems that are normally 

incompatible. 

Page 41 GAO-06-618 Catastrophic Disasters
Recent GAO recommendations to DOD 

improve federal leadership and

cooperation in communications DOD response 

DOD should develop detailed plans and 

exercises regarding the unique capabilities 

and support, such as communications 

capabilities, that the military is likely to 

provide to civil authorities. 

DOD has taken a number of steps to 

increase communications capabilities in 

regions affected by disasters. These 

include authorizing the Command of U.S. 

Northern Command to deploy 

communications capabilities and develop 

pre-scripted requests for assistance for 

deployable communications options. 

For more detailed information about our recommendations, see appendix I. 

Our prior work on interoperable communications identified problem 

definition, performance goals and standards, and defining the roles of 

federal, state, local government and other entities as the three principal 

challenges to achieving effective interoperable communications for first 

responders. The single greatest barrier to addressing the decades-old 

problems of interoperable communications has been the lack of effective, 

collaborative, interdisciplinary, and intergovernmental planning. Our 2004 

recommendations called for DHS to: (1) work with the Federal 

Communications Commission (FCC) to develop a nationwide database of

interoperable communications frequencies and a common nomenclature 

so that first responders from different disciplines and jurisdictions can 

quickly identify shared frequencies when arriving at the scene of an 

incident; (2) establish interoperability requirements whose achievement 

can be measured; and (3) encourage states through DHS grants to 

establish statewide bodies that will develop a comprehensive statewide 

interoperable communications plan and condition the purchase of new 

equipment on the adoption of such a plan.38 DHS responded that it was 

developing a nationwide database of interoperable public safety 

communications frequencies and also said it planned to work on a 

common nomenclature across public safety disciplines and jurisdictions. 

DHS also said it is developing a methodology to establish a national 

baseline of public safety communication and interoperability capabilities 

with input from the public safety community. On June 16, 2006, the FCC 

published a Notice of Proposed Rulemaking to address and implement the 

recommendations of an independent panel that reviewed the impact of 

Hurricane Katrina on communications networks. The FCC identified 

 38GAO, Homeland Security: Federal Leadership and Intergovernmental Cooperation 

Required to Achieve First Responder Interoperable Communications, GAO-04-740 

(Washington, D.C.: July 20, 2004). 

Page 42 GAO-06-618 Catastrophic Disasters
18 actions that the Commission can take in conjunction with the private 

sector and state and local governments, and other federal departments, to 

promote heightened readiness and preparedness, and effective and 

efficient response and recovery efforts.39

By definition, a catastrophic disaster like Hurricane Katrina will impact a 

large geographic area, necessitating the evacuation of people—including 

vulnerable populations, such as hospital patients, nursing home residents, 

and transportation-disadvantaged populations who were not in such 

facilities. Although state and local governments can order evacuations, 

health care facilities can be exempt from these orders. Hospital and 

nursing home administrators often face challenges related to evacuations 

caused by hurricanes, including deciding whether to evacuate and 

obtaining transportation. Nursing home administrators must locate 

receiving facilities that can accommodate residents who may need a place 

to live for a long period of time. If a hospital or nursing home does decide 

to evacuate, contractors providing transportation for hospitals and nursing 

homes could be unable to provide enough vehicles during a major disaster 

because local demand for transportation could exceed supply. 

Evacuations 

We have conducted work related to the evacuation of special needs 

populations in the aftermath of Hurricane Katrina. The National Disaster 

Medical System (NDMS) is the primary federal program that supports the 

evacuation of patients in need of hospital care during disasters such as 

hurricanes. We found that the program has two limitations in its design 

that constrain its assistance to state and local governments with patient 

evacuation. The first limitation is that NDMS evacuation efforts begin at a 

mobilization center, such as an airport, and do not include short-distance 

transportation assets, such as ambulances or helicopters, to move patients 

out of health care facilities to mobilization centers. Even during a 

catastrophe when state and local government capabilities are almost 

immediately overwhelmed, short-distance transportation remains a state 

and local responsibility.40 The second limitation is that NDMS supports the 

evacuation of patients needing hospital care; the program was not 

 39Federal Communications Commission, Notice of Proposed Rulemaking, FCC-06-83 

(Washington, D.C.: June 19, 2006). 

40The September 2005 draft Catastrophic Incident Supplement to the NRP is intended to be 

used with the Catastrophic Incident Annex when a catastrophic incident almost 

immediately overwhelms the capabilities of state and local governments. The draft 

supplement does not describe what, if any, role the federal government is to play in

coordinating with state and local authorities for this kind of transportation. 

Page 43 GAO-06-618 Catastrophic Disasters
designed nor is it currently configured to move people who do not require 

hospitalization, such as nursing home residents, which remains a state and 

local responsibility. 

NDMS supplemented state and local emergency response capabilities with 

federal resources and services and helped evacuate about 2,900 people 

during recent hurricanes, including Hurricane Katrina. According to 

program officials the program was actually designed to evacuate and 

transport hospital patients starting from a federally-designated 

mobilization center, although NDMS supported evacuation efforts during 

Hurricane Katrina that included nursing home residents. NDMS officials 

explained that the program does not have agreements with nursing homes 

that could receive evacuated nursing home residents or appropriate 

transportation such as special buses that could transport them. 

To address limitations in how the federal government provides assistance 

with the evacuation of health care facilities, we have recommended that

the Secretary of Homeland Security clearly delineate how the federal 

government will assist state and local governments with the movement of 

patients and residents out of hospitals and nursing homes to a 

mobilization center where NDMS transportation begins; and in

consultation with the other NDMS federal partners—the Secretaries of 

Defense, Health and Human Services, and Veterans Affairs—clearly 

delineate how to address the needs of nursing home residents during 

evacuations, including the arrangements necessary to relocate these 

residents.41 DHS said it would take the recommendation under advisement 

as it reviews the National Response Plan, confirming that the federal 

government becomes involved in evacuations only when the capabilities of 

state and local governments are overwhelmed. 

 41GAO, Disaster Evacuations: Limitation in Federal Assistance to Health Facilities for 

Transportation Should Be Addressed, GAO-06-826 (Washington, D.C.: July 20, 2006).

Page 44 GAO-06-618 Catastrophic Disasters
Recent GAO recommendations to DHS 

to improve federal assistance for health

facility and nursing home disaster 

evacuations DHS response

DHS should clearly delineate how the 

federal government will assist state and 

local governments with the movement of 

patients and residents out of hospitals and 

nursing homes to a mobilization center 

where NDMS transportation begins. 

DHS said it would take the 

recommendation under advisement as it 

reviews the NRP and stated that all NDMS 

federal partners are currently reviewing a 

memorandum of agreement with a view 

towards working with state and local 

partners to delineate and clarify roles and 

responsibilities. 

DHS should in consultation with the other 

NDMS federal partners—the Secretaries of 

Defense, Health and Human Services, and 

Veterans Affairs—clearly delineate how to 

address the needs of nursing home 

residents during evacuations, including the 

arrangements necessary to relocate these 

residents. 

For more detailed information about our recommendations, see appendix I. 

We conducted work examining the nation’s efforts to protect children 

after the Gulf Coast hurricanes and identified evacuation challenges for 

this population.42 Thousands of children were reported missing to the 

National Center for Missing and Exploited Children, which utilized its 

trained investigators to help locate missing children after the evacuation.

43

Officials from this center stated that both the American Red Cross and 

FEMA had some information on the location of children in their databases; 

however, they said it was difficult to obtain this information because of 

privacy concerns. These officials told us that standing agreements for data 

sharing among organizations tracking missing children, the Red Cross, and 

FEMA could help locate missing persons more quickly. Regarding foster 

children, Louisiana child welfare officials told us it was difficult to contact

foster parents who had evacuated because the emergency contact 

 42GAO, Lessons Learned for Protecting and Educating Children after the Gulf Coast 

Hurricanes, GAO-06-680R (Washington, D.C.: May 11, 2006).

43We observed that while the reasons children were separated from their families are not 

fully understood, in many cases children were evacuated separately from parents and sent 

to different shelters. All of the instances of children reported missing to the National 

Center for Missing and Exploited Children were resolved by March 2006. All of the children

reported missing were not necessarily unaccompanied or in harm’s way; some who were

safe were probably reported as missing because non-guardians (such as neighbors) could 

report a child as missing. 

Page 45 GAO-06-618 Catastrophic Disasters
information for them was limited and located in case records that was 

inaccessible for weeks following the storm. They said updated emergency 

contact information for foster parents and automated case file systems 

could help locate and serve foster children more quickly. Also, child 

welfare officials told us that having an adequate number of trained staff 

present during large-scale evacuations can help ensure that families stay 

together. 

Search and rescue is the capability to coordinate and conduct urban 

search and rescue response efforts for all hazards. Urban search and 

rescue response efforts require a seamless transition from finding 

stranded people, rescuing them, and transporting them to safe shelter, 

which may call on the additional skills and resources of responders, along 

with support from other emergency support functions such as public 

safety. Capabilities also can include accessing, medically stabilizing, and 

extricating victims trapped in damaged or collapsed structures. The U. S.

Coast Guard, state and local agencies, and military assets rescued 

thousands in the aftermath of Hurricane Katrina. Almost 6,000 Coast 

Guard personnel from throughout the country conducted one of the 

largest search and rescue missions in its history as part of an even larger 

multi-agency, multi-level search and rescue effort, according to the White 

House Homeland Security Council report. The Coast Guard retrieved more 

than 33,000 people along the Gulf Coast, including more than 12,000 by air, 

and 11,000 by surface, plus 9,403 evacuated from hospitals. Almost onethird of the Coast Guard’s entire fleet was dedicated to rescue efforts, 

according to the White House Homeland Security Council report. 

Search and Rescue 

Search and rescue capabilities must also include ensuring the safety of 

first responders. For example, following Hurricane Katrina’s landfall, 

Coast Guard rescue swimmers involved in the helicopter-based rescues 

told us that safety and security became a concern as time passed and 

individuals became frustrated because they had no food or water. In some 

instances, tensions among survivors became heated when rescue 

swimmers prioritized the rescues of children, women, and the elderly over 

able-bodied men. For boat operations, officials explained that they dealt 

with security challenges by deploying Coast Guard security teams with the 

rescue personnel to provide armed security coverage for both Coast Guard 

personnel and FEMA urban search and rescue teams. 

In addition, although tens of thousands of people were rescued after 

Hurricane Katrina through the efforts of military, civil government, and 

private rescuers, the lack of clarity in search and rescue plans led to 

operations that were not as efficient as they should have been. As we 

Page 46 GAO-06-618 Catastrophic Disasters
noted in our discussion of leadership, the NRP at that time addressed only 

part of the search and rescue mission, and the National Search and Rescue 

Plan had not been updated to reflect the NRP. According to Louisiana 

National Guard officials, they worked with the Coast Guard to coordinate 

aviation operations, but the aviation search and rescue efforts that were 

being directed from two different command sites were not integrated. For

example, some military aircraft received their direction from a military 

task force at the Superdome, while others received their direction from 

the Coast Guard or the Joint Task Force that was in command of the 

active troops on the ground. According to military officials, better 

integration of search and rescue efforts could reduce duplications of effort 

for search and rescue aircraft. As previously noted, GAO has made 

recommendations to the Secretary of Defense to improve planning for the 

search and rescue support that the military is likely to provide to civil 

authorities.44

Our work and that of others indicates that logistics systems—the 

capability to identify, dispatch, mobilize, and demobilize and to accurately 

track and record available critical resources throughout all incident 

management phases—-were often totally overwhelmed by Hurricane 

Katrina. Critical resources apparently were not available, properly 

distributed, or provided in a timely manner. The result was duplication of

deliveries, lost supplies, or supplies never being ordered. Reviews of 

acquisition efforts indicated that while these efforts were noteworthy 

given the scope of Hurricane Katrina, agencies needed additional 

capabilities to (1) adequately anticipate requirements for needed goods 

and services; (2) clearly communicate responsibilities across agencies and 

jurisdictions; and (3) deploy sufficient numbers of personnel to provide 

contractor oversight. For example, a factor that affected the military 

response was the large and unanticipated logistics role it was asked to 

assume. Under the NRP, FEMA is responsible for coordinating logistics 

during disaster response efforts, but during Hurricane Katrina, FEMA 

quickly became overwhelmed, in part because it lacked the people, 

processes, and technology to maintain visibility—from order through final 

delivery—of the supplies and commodities it had ordered. As a result of 

FEMA’s lack of visibility over the meals that were in transit, DOD had to 

airlift 1.7 million meals to Mississippi to respond to a request from the 

Adjutant General of Mississippi, who was concerned that food supplies 

were nearly exhausted. 

Logistics 

 44GAO-06-643. 

Page 47 GAO-06-618 Catastrophic Disasters
Similarly, our work examining the coordination between FEMA and the 

Red Cross to provide relief to disaster victims found that FEMA did not 

have a comprehensive system to track requests for assistance it received

from the Red Cross on behalf of voluntary organizations and state and 

local governments for items such as water, food, and cots. The absence of

such a system created more work for the Red Cross and slowed the 

delivery of relief services. The Red Cross was only able to follow up on 

these requests informally—a process that took time and was often 

ineffective. FEMA officials were often unable to provide the Red Cross 

with accurate information regarding FEMA’s ability to fulfill a request or 

when expected items would be delivered, causing many requests to go 

unfilled or be filled too late to be of use. The unreliability of FEMA’s 

supply systems required the Red Cross to try to follow up on requests 

through other informal channels—a process the Red Cross reported as 

being inefficient and only marginally effective. Other voluntary 

organizations also told us that in many cases the unreliability of FEMA’s 

supply systems hindered their attempts to provide mass care services, and, 

as a result, they had to scale back on their service provision.

In contrast, response efforts benefited from the logistical support of the 

U.S. Forest Service. As the White House Homeland Security Council 

reported in February 2006, about 3,000 members of the Forest Service also

deployed to the region to support response efforts. Forest Service 

personnel in Mississippi, Louisiana, Florida, and Alabama established 

support camps, provided aviation assistance, and transported needed 

supplies to relief workers. The base camps they established were capable

of supporting 1,000 emergency responders at each site. According to the 

Forest Service, nearly 2,760 Forest Service employees nationwide were 

called upon to provide assistance by using their incident management 

abilities to help manage evacuation centers and base camps, provide 

logistical support, clear roadways, and operate mobilization centers and 

trailer staging areas. They also helped navigate the federal procurement 

system and successfully obtained needed emergency response supplies, 

the White House Homeland Security Council noted. Forest Services’ 

incident management teams helped to supply more than 600,000 people 

with 2.7 million meals, 4 million gallons of water, and 40 million pounds of 

ice. One Forest Service region sent nearly 470 people, including various 

types of interagency responder teams, buying teams, and other services in

the relief effort, according to the Forest Service.

This emergency support function includes the non-medical mass care, 

housing, and human services needs of individuals and families. Mass care 

is the capability to provide immediate shelter, feeding centers, basic first 

Mass Care, Housing, and 

Human Services 

Page 48 GAO-06-618 Catastrophic Disasters
aid, and bulk distribution of needed items and related services to affected

persons. Charities and government agencies that provide human services, 

supported by federal resources, helped meet the mass care needs of the 

hundreds of thousands of evacuees. 

Recognizing the historically large role of charities in responding to 

disasters, DHS collaborated with the American Red Cross in the 

development of the NRP and gave it considerable responsibilities. In 

addition, the NRP establishes a separate support annex that defines the 

capability to effectively manage and deploy volunteers and unsolicited 

donations. Federal and charitable organization officials we spoke to 

indicated that because of the catastrophic nature of the storms, in some 

cases volunteers and donations were not well integrated into response and 

recovery activities. 

Charities have taken steps to improve coordination of relief efforts since 

September 11, 2001. These efforts have included sharing information about 

relief services through daily conference calls and the use of electronic 

databases. Additionally, charities coordinated service delivery to meet the 

needs of evacuees. For example, the Red Cross did not work in areas that 

might become flooded or in structures that could be compromised by 

strong winds. During our visits to the Gulf Coast region in October 2005,

we observed that in areas where the Red Cross did not provide services, 

the Salvation Army and smaller organizations—often local churches—

were able to meet many of the charitable needs of hard-to-reach 

communities. Despite these efforts, charities faced some challenges in 

coordinating service delivery. For example, some charities reported that 

the electronic database created to share information about services 

provided to evacuees was still in its developmental stage and, therefore, 

not ready to be activated on such a large scale. Some concerns were also 

raised about smaller charities’ abilities to provide adequate disaster relief 

services. Additionally, some Gulf Coast areas did not have sufficient 

shelter facilities, in part because the Red Cross had in effect “shelter 

protection policies” to promote evacuation of low-lying areas, which 

prohibited the placement of shelters in areas prone to high winds, storm 

surge, and flooding—causing some of the most severely affected areas to 

be without sheltering facilities. In addition, some shelters were accessible 

to the general population only during limited daylight hours.

In addition to immediate food and shelter, individuals may need help 

replacing Social Security checks, obtaining food stamps or other basic 

federal support benefits and services. Our preliminary work indicated that 

a number of federal and state programs provided assistance and services 

Page 49 GAO-06-618 Catastrophic Disasters
to eligible individuals and families before the catastrophic disaster. 

Significant ongoing assistance after the catastrophic disaster has also been 

required. Such basic federal support programs as food stamps, social 

security, unemployment insurance, and income assistance played an 

important role in the immediate response to those displaced or otherwise 

affected by Hurricane Katrina. To ensure delivery of benefits, and in some 

cases, to address the sharp rise in new applications, these programs set up 

operations in shelters, disaster recovery centers, other sites, and some 

programs served an unprecedented number of people in their offices that 

serve the public. For example, Hurricane Katrina disrupted mail delivery 

of monthly social security checks, leaving many social security recipients

without key income support. However, the Social Security Administration 

had procedures in place to provide emergency payments and, with about 

1,300 offices nationwide, had the capability to quickly deploy staff and 

equipment from other offices to address the increased workload. 

Individuals affected by Hurricane Katrina also overwhelmed the state of 

Louisiana’s food stamp, welfare, and unemployment offices. State and 

local officials we visited said they struggled to find equipment and supplies 

to handle the increase and to obtain other help such as security for crowd 

control. Louisiana—overwhelmed in its efforts to issue unemployment 

checks to evacuees without stable addresses—rushed to implement a 

debit card payment system and encountered some challenges doing so. 

The debit card payment systems the states of Alabama, Louisiana, and 

Mississippi had in place for income assistance and food stamps allowed 

them to continue benefit payments that were uninterrupted when 

beneficiaries relocated. In addition, over 2 million families received food 

assistance through the U.S. Department of Agriculture’s Disaster Food 

Stamp Program. 

Effective Capabilities 

Development Requires 

Adequate Planning, 

Coordination, Training, 

and Exercises 

Capabilities are built upon the appropriate combination of people, skills, 

processes, and assets. Ensuring that needed capabilities are available 

requires effective planning and coordination and training and exercises in

which the capabilities are realistically tested, problems identified and 

lessons learned, and subsequently addressed in partnership with other 

federal, state, and local stakeholders. 

As we identified in our March 2006 testimony, the ability of the nation to

prepare for, respond to, and recover from catastrophic disasters can be 

enhanced through strong advance planning, both within and among 

responder organizations. By their very nature, catastrophic disasters 

involve extraordinary levels of mass casualties, damage, or disruption that 

likely will immediately overwhelm state and local responders, 

Planning and Coordination 

Page 50 GAO-06-618 Catastrophic Disasters
circumstances that make sound planning for catastrophic events all the 

more crucial. Identifying, obtaining, and pre-positioning adequate 

quantities of key supplies, such as food, ice, water, and blankets, and 

delivering those supplies quickly when and where needed is an important 

component of planning. Another example is the previously discussed 

planning challenges states and localities face in preparing for and carrying

out the evacuation of transportation-disadvantaged populations, such as 

the elderly or persons with disabilities, during a disaster. Our work in this 

area has noted challenges in identifying these populations, determining 

their needs, and providing for and coordinating their transportation. Some 

emergency management officials told us they did not yet have a good 

understanding of the size, location, and composition of the transportationdisadvantaged in their communities. However, we have also observed 

efforts in some locations to address the evacuation needs of the 

transportation-disadvantaged by encouraging citizens to voluntarily 

register with their local emergency management agency, integrating social

service providers into emergency planning, and other measures. 

In some cases, sound advance planning contributed to a more effective 

response during Hurricane Katrina. For example: 

Examples of Good Planning 

• U. S. Coast Guard–The Coast Guard was able to mitigate some of 

the communication shortfalls it experienced, in part because of its 

planning assumption that “communications systems could be 

heavily damaged or destroyed” during a natural disaster. This 

assumption prompted Coast Guard officials to build into their 

contingency plans approaches that were not reliant on 

communication systems and that allowed personnel to act

independently or with limited guidance from commanding officers. 

As a result of the contingency plan, personnel in charge of the 

assets knew their mission prior to the storm and did not need to 

communicate any further with district command to fulfill their 

operation. In addition, as planned, the Coast Guard pre-placed 

communication equipment before the storm. Members of the Coast 

Guard Auxiliary were notified prior to the hurricane’s landfall and 

provided communication capabilities after the storm passed, which 

according to Coast Guard officials, was critical to conducting

search and rescue operations. 

• National Finance Center—Planning for continuity of operations 

enabled the National Finance Center (NFC) in New Orleans paid 

more than half a million federal workers on time while Hurricane 

Katrina was bearing down, then made subsequent payrolls—NFC’s 

Page 51 GAO-06-618 Catastrophic Disasters
largest ever—without any delays. According to officials, NFC had 

gone through various diverse scenarios in disaster recovery 

planning and exercises as part of its preparedness for just such an 

event. There was a structured timeline for reviewing the continuity 

of operations plan every year, beginning with continuity of 

operations plan requirements and business impact analysis at the 

unit level. A NFC official said that key NFC staff members worked 

the weekend before landfall at the New Orleans facility to complete 

payroll processing for federal employees, then shut down 

operations and deployed to backup locations before the hurricane 

hit New Orleans. NFC backup data was trucked out of the New 

Orleans facility. When Hurricane Katrina made landfall in Louisiana 

shortly after 6 a.m. on Monday, August 29, 2005 NFC had already 

sent an advance deployment team to its backup sites in 

Philadelphia, Pennsylvania and Grand Prairie, Texas. That same 

night, the trucks arrived at an alternate processing facility outside 

Philadelphia. The backup tapes also enabled the New Orleans NFC 

staff restore many operations within 2 days of the devastation.

Within a 50-hour period, NFC had the data center recovered and 

began catch-up processing to bring applications up to current state. 

• Social Security Administration---The Social Security 

Administration had enhanced planning and pre-established 

procedures in place to provide immediate emergency payments to 

the significant number of beneficiaries who evacuated and did not 

receive their monthly checks. With these procedures in place, the 

Social Security Administration had the capability to deploy staff 

and equipment from its 1,300 offices across the nation to address 

the increased workload. 

• Department of Defense—The White House Homeland Security 

Council’s report also identified DOD’s preparedness efforts for the 

2005 hurricane season. DOD approved a standing order to prepare 

and organize for severe weather disaster operations, which was 

based on prior assistance for hurricane recovery operations. This 

order expedited the pre-positioning of senior military 

representatives known as Defense Coordinating Officers, to act as 

liaisons with other governmental organizations in the projected 

disaster area prior to an event. The order also authorized the use of 

DOD installations as logistical staging areas for FEMA. The military 

also took steps to proactively respond as Katrina strengthened in 

the Gulf of Mexico, and it published warning and planning orders 

and was positioned to respond with both National Guard and 

federal forces by the time Katrina made landfall on August 29, 2005. 

Page 52 GAO-06-618 Catastrophic Disasters
• U.S. Postal Service—The Postal Service was relatively wellprepared for the aftermath of Hurricane Katrina. While the 

hurricane damaged some 500 post offices, the Postal Service was 

able to establish limited services just days after the disaster. As 

early as August 26, 2005, USPS was anticipating a landfall in the 

Gulf Coast and was diverting some mail from processing plants in 

that region to minimize the effects of potential disruption to its 

processing capabilities. By the time the storm passed on August 30, 

some 500 postal facilities in Alabama, Mississippi, and Louisiana 

had been damaged and were incapable of providing delivery 

service. On September 1, 2005, the Postal Service set up temporary 

centers for the pickup of checks in Mississippi, Louisiana, and 

Alabama. In New Orleans proper, two post offices were designated 

as Social Security check pickup points for a short period of time. 

Reconstituting regular mail delivery in the areas affected by

Hurricane Katrina was a priority. For those now displaced from 

their homes, the Postal Service says that it can provide relatively 

efficient delivery service if customers submit a change of address 

form in person, by toll-free telephone, or on the Internet. The 

Postal Service now has the capability, through innovations in 

sorting technology, to intercept mail at its original sorting point 

that is addressed to an address that has changed, and re-route the 

mail to a new address. Thus, it can avoid the cost and delay of 

physically transporting mail to the former delivery post office for 

flagging and forwarding under a local change of address request. 

• Internal Revenue Service—The Internal Revenue Service (IRS) 

worked in coordination with FEMA to address the human services 

needs of individuals and families. The IRS began staffing Disaster 

Assistance Centers in more than a dozen states. The IRS 

assigned nearly 5,000 employees to augment the FEMA hurricane 

victim registration effort and established its own dedicated toll-free 

disaster number and a special section of their internet web site, 

according to the Treasury Department. IRS employees were taking 

calls seven days a week over two shifts to help people with the 

process of registering with FEMA to obtain benefits, answering 

approximately 950,000 registration calls for FEMA and filling 

orders for over 291,000 Disaster Relief Kits. Through February 2, 

2006, they answered more than 100,000 calls on the special IRS tollfree line for affected taxpayers. In addition, the IRS issued filing 

and payment relief guidelines, launched a special toll-free disaster 

hotline, and created a Hurricane Katrina disaster link at 

Page 53 GAO-06-618 Catastrophic Disasters
www.irs.gov web site to expedite the processing of transcript and 

tax return requests. 

• DHS Nationwide Plan Review: State and Local Catastrophic

Disaster Planning—In the aftermath of Hurricane Katrina, DHS 

has responded to the need to ascertain the status of the nation’s 

emergency preparedness planning, as identified both by Congress 

and the President. On September 15, 2005, the President ordered 

DHS to undertake an immediate review, in cooperation with local 

counterparts, of emergency plans in every major city in America. In 

addition, the Safe, Accountable, Flexible, Efficient Transportation 

Equity Act: A Legacy for Users required the Secretary of 

Transportation and the Secretary of Homeland Security to jointly 

review and assess federal and state evacuation plans for 

catastrophic hurricanes impacting the Gulf Coast Region.45 Finally, 

in the conference report to the Department of Homeland Security 

Fiscal Year 2006 Appropriations Act, the conferees directed DHS to 

report on the status of catastrophic planning, including mass 

evacuation planning, in all 50 states and the 75 largest urban 

areas.46 In response, DHS developed the Nationwide Plan Review in 

coordination with the Department of Transportation and support 

from the Department of Defense. 

The Nationwide Plan Review included two phases. In Phase 1, 

released in February 2006, all states and urban areas submitted 

self-assessments of their emergency operations plans, focusing on 

their adequacy and feasibility to manage the consequences of a 

catastrophic event.47 In Phase 2, released in June 2006, DHS 

employed peer review teams to visit states and urban areas, where 

these teams reviewed and validated the self-assessments, and 

helped determine requirements for federal planning assistance. 

Examples Where Planning and 

Coordination Should Be 

Improved 

 45Pub. L. No. 109-59, 119 Stat. 1144, 1934 (2005). 

46H.R. Rep. No. 109-241, at 68 (2006). 

47As used in the Nationwide Review Plan, the term “state” refers to any state of the United 

States, the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, 

Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, and any

possession of the United States. The term “urban areas” refers to the 55 Fiscal Year 2005 

Urban Areas Security Initiative program grantees; and the 20 major cities selected for the

Nationwide Plan Review by DHS were based on a DHS analysis of 2004 population, risk,

and need. 

Page 54 GAO-06-618 Catastrophic Disasters
At the conclusion of each visit, the peer review team completed a 

comprehensive report and submitted it to DHS. 

The June 2006, DHS Phase 2 report found that current catastrophic 

planning is unsystematic, not linked within a national planning

system, and the status of plans and planning gives grounds for 

significant national concern. The report found a systemic problem 

of outmoded planning processes, products, and tools, which all 

contribute to inadequate catastrophic planning. DHS found that 

emergency operations rely on plans that are created in isolation, 

insufficiently detailed, and not subject to adequate review. The 

report identified 15 findings specific to state and urban area 

planning, and 24 findings specific to the federal government’s role 

and efforts to support catastrophic disaster planning. DHS 

concluded that the result of these systemic planning problems 

translates to uneven performance and repeated and costly 

operational miscues, and critical response time lost to correct the 

misperceptions of federal, state, and local responders about their 

roles, responsibilities, and actions. 

DHS’s findings call for a fundamental modernization of the nation’s 

planning processes. According to its report, planning 

modernization must be managed as a single program with 

established funding. Further, according to DHS, the goal of the 

modernization program must be to establish a networked, 

collaborative national planning system that satisfies planners’ 

information needs; provides procedures and tools to accomplish 

pre-incident plan synchronization; allows faster development or 

revision of existing plans; and provides flexible options that 

accommodate the diverse hazards and threats. However, DHS 

states that the next phase that needs to be addressed is the 

development of an implementation strategy to begin to address the 

40 findings in the White House Homeland Security Council report 

in a rational way. Such an implementation strategy can prioritize 

remedial actions based on a risk management model that considers 

threats, vulnerabilities, and consequences. 

• Department of Defense—Our recent report on DOD and the 

National Guard’s planning for and response to Hurricane Katrina 

illustrates an example of the need for coordinated planning in

advance of a disaster. While multiple agencies support each 

“Emergency Support Function” in the NRP, DOD does not have the 

primary responsibility for any emergency support function, as 

Page 55 GAO-06-618 Catastrophic Disasters
DOD’s role is primarily that of a support agency. We found that 

pre-Katrina plans involving the military were inadequate in several 

ways. Neither the NRP nor DOD’s disaster plans incorporate 

lessons learned from past catastrophes to fully delineate the 

military capabilities needed to respond to a catastrophic disaster.48

DOD is aware of disaster response problems described in this 

report and is beginning to take actions to address the lessons 

learned from Hurricane Katrina and to prepare for the next 

catastrophic event. DOD has been conducting its own reviews and 

is also examining the lessons and recommendations in reports 

from a White House review panel, congressional oversight 

committees, and other sources. We noted that DOD is taking some 

actions to address catastrophic disaster response problems. For 

example, DOD officials stated that it is currently updating its 

emergency response plan and intends to use a contingency plan 

rather than a less detailed functional plan to guide its military 

support to civil authority missions. DOD also has an organizational 

realignment underway that gives a single Army organization that is 

responsible for domestic disaster response and will be capable of 

deploying within 18 hours as joint task forces for catastrophes 

anywhere in the United States. 

• FEMA—Enhancing planning and coordination efforts may also 

benefit other federal agencies’ efforts to provide response and 

recovery services. For example, our observations of the Individuals 

and Households Program (IHP), which provides housing and other 

financial assistance to disaster victims, suggest that FEMA’s 

program planning was reactive and ad hoc, with IHP procedures 

differing from disaster area to disaster area. Our work examining 

the IHP program indicated that FEMA lacked final plans, policies, 

and procedures that specifically addressed the types of unique 

challenges the agency could expect to face in catastrophic 

circumstances. In commenting on a draft of our report, FEMA 

officials said they had previously identified the need to develop 

plans to expand its disaster registration intake and applicant 

assistance process and to temporarily relocate victims to outside 

the area after a catastrophic disaster. However, they said the

$20 million to address these requirements and others that were 

requested and provided in the FY 2005 Disaster Supplemental 

appropriation were not available for commitment until days before 

 48GAO-06-643. 

Page 56 GAO-06-618 Catastrophic Disasters
Katrina made landfall. They also said that their planning efforts 

were significantly slowed by staff commitments to the 2004 and 

2005 hurricane seasons. One of the consequences of this lack of 

planning for catastrophic disasters was that FEMA’s systems and 

processes for verifying applicant eligibility for IHP assistance were 

overwhelmed, resulting in payments made to thousands of 

ineligible applicants.49 FEMA officials said that these problems 

more directly reflected a failure of system capacity that could not 

be overcome by any amount of planning. Nonetheless, if FEMA had 

developed and implemented a plan for an expandable disaster 

registration intake and applicant assistance process after 

identifying the need for such a plan, systems and processes for 

verifying applicant eligibility for IHP assistance would have been 

better prepared to manage the unprecedented volume of requests 

and reduce the number of payments made to ineligible applicants. 

In addition, FEMA did not have sufficient pre-positioned supplies, 

equipment, and services (e.g., debris removal) contracts in place 

prior to Katrina to meet the demand during the response, 

particularly for needs such as temporary housing and public 

buildings. The experience of Katrina highlighted the need for better 

logistics planning and the need for contracts to be in place prior to 

the disaster that could be activated to lean forward and provide 

surge capacity for critical supplies and services. For example, 

because FEMA had not planned for a catastrophic disaster such as 

Katrina, FEMA spent funds for temporary housing that were hardly 

used. In addition, because FEMA did not inform the Corps of 

Engineers prior to Katrina that the Corps would be responsible for 

acquiring portable classrooms, the Corps lacked sufficient 

knowledge of the market for this commodity to obtain the best 

deal for the government. In these and other instances, better 

planning could have avoided some unnecessary costs. 

• Small Business Administration—In another example, SBA 

needs enhanced strategic planning to ensure its ability to provide 

timely loans, as our ongoing work in this area indicates. As the

primary federal lender to disaster victims SBA’s disaster loan 

program provides loans to businesses, homeowners, and renters to 

rebuild and replace uninsured or underinsured property damaged 

by a disaster. However, as more fully described in our recently

 49 GAO-06-403T. 

Page 57 GAO-06-618 Catastrophic Disasters
issued report, several factors affected SBA’s ability to provide 

timely disaster assistance to victims of the Gulf Coast hurricanes, 

including the large volume of applications that SBA processed.50

For example, SBA planned the maximum user capacity for its new 

Disaster Credit Management System (DCMS) based solely on its 

experience during the 1994 Northridge earthquake—the single 

largest disaster SBA had previously faced—and other historical 

data. SBA did not consider information available from catastrophe 

risk models and disaster simulations, such as the likelihood and 

severity of damages from potential natural disasters, to help 

predict the volume of applications that might be expected from 

such events. SBA’s limited planning contributed to insufficient 

DCMS user capacity, thus restricting the number of staff that could 

access DCMS and process applications in a timely manner. SBA 

also did not completely stress test DCMS before implementation 

and received the incorrect computer hardware from its contractor, 

which reduced user capacity and contributed to the system 

instability, outages, and slow response times initially experienced 

by SBA staff. As a result of these and other factors, SBA faced

significant delays and backlogs in processing loan applications. 

Going forward, SBA may be able to process disaster loans more 

efficiently by implementing an Internet-based application feature. 

In order to provide more timely disaster assistance in the future, 

we recommended that the Administrator of SBA direct the Office 

of Disaster Assistance to take the following four actions: 

(1) reassess DCMS’s maximum user capacity and related loan

processing resource needs based on such things as lessons learned 

from the Gulf Coast hurricanes, a review of information available 

from catastrophe risk modeling firms and disaster simulations, and 

related cost considerations; (2) conduct complete stress testing to 

ensure that DCMS can function as planned for maximum user

capacity levels; (3) improve management controls over assessing 

contractor performance through inspections of all equipment 

purchased or leased to support DCMS; and (4) expedite plans to 

resume business processing reengineering efforts to analyze the 

disaster loan process and identify ways to more efficiently process 

loan applications, including an evaluation of the feasibility of

implementing a secure Internet-based application feature for home 

 50 GAO, Small Business Administration: Actions Needed to Provide More Timely Disaster

Assistance, GAO-06-860 (Washington, D.C.: July 28, 2006). 

Page 58 GAO-06-618 Catastrophic Disasters
loan applicants. SBA disagreed with some of our findings but 

generally agreed with these recommendations. 

Recent GAO recommendations to SBA 

to provide more timely disaster 

assistance in the future SBA response

SBA should reassess the Disaster Credit 

Management System’s (DCMS) maximum 

user capacity and related loan processing 

resource needs based on such things as 

lessons learned from the Gulf Coast 

hurricanes, a review of information available 

from catastrophe risk modeling firms and 

disaster simulations, and related cost 

considerations.

Conduct complete stress testing to ensure 

that DCMS can function at planned for 

maximum user capacity levels. 

Improve management controls over 

assessing contractor performance through 

inspections of all equipment purchased or 

leased to support DCMS. 

Expedite plans to resume business 

processing reengineering efforts to analyze 

the disaster loan process and identify ways 

to more efficiently process loan applications

including an evaluation of the feasibility of 

implementing a secure Internet-based 

application feature for home loan 

applicants. 

SBA disagreed with some of our findings 

but generally agreed with these 

recommendations. 

For more detailed information about our recommendations, see appendix I. 

In addition our preliminary analysis from an ongoing review 

indicates that SBA’s overall planning efforts for providing timely 

recovery assistance in response to large scaled disasters appears to 

be insufficient and may have contributed to the delays in providing 

affordable disaster assistance to victims in the Gulf Coast Region. 

For example, at the time of the Gulf Coast hurricanes, SBA lacked 

a comprehensive, documented plan for providing timely disaster 

recovery assistance. Disaster recovery experts have told us that 

such a plan would address various aspects of SBA’s response 

including staffing capacity, telecommunication needs and other 

logistical support, as well as coordination with federal, state, and 

local entities in providing appropriate disaster recovery assistance. 

In addition, SBA did not have any full-time staff responsible for 

planning its disaster recovery activities. Rather, SBA relied 

Page 59 GAO-06-618 Catastrophic Disasters
extensively on the experience and knowledge of its field office

staff to determine its response needs and carry out SBA’s role. SBA 

officials stated that it recently started developing a response plan; 

however, it was unclear when this plan would be completed and 

implemented. We plan to complete our review of these issues and 

issue a report later this year.

• Child Welfare—Findings from our recent work and from other 

agency “after action” reports point to the need to improve current 

plans and strengthen related agreements and understandings of 

expectations between governments and other organizations that 

will be responders in the event of a future catastrophe. Our work 

has identified areas where prior to an incident, obstacles can be 

identified and agreements to address them reached between 

agencies, levels of governments, and private and nongovernmental 

organizations. Our recent work examining Louisiana’s child welfare 

system’s response to the disaster and education system identified 

lessons learned by the state’s child welfare officials, including the 

need for state disaster plans to include evacuation information and 

instructions for social workers and their foster parents. In a recent 

national survey, child welfare officials in 20 states and the District 

of Columbia reported that they had a written child welfare disaster 

plan.51 Of these, 13 states reported that their plan addressed 

identifying children under state care who may be dispersed after a 

disaster, and 14 reported that their plan addressed continuing 

services for children under state care who may be dispersed. Child 

welfare agencies could also benefit from standing data-sharing 

agreements that would speed efforts to locate displaced children in 

the event of the type of evacuation witnessed prior to and after 

Katrina’s landfall.52 Louisiana child welfare officials told us that, 

during the response to Hurricane Katrina, they had to sign a 

memorandum of understanding for sharing information with the 

American Red Cross, but by the time the memorandum was 

finalized and approved the demand had abated, and the Red Cross 

had closed its shelters. 

 51We surveyed 50 states, the District of Columbia, and Puerto Rico; 20 states and the 

District of Columbia reported that they had a written plan, 17 states and Puerto Rico 

reported they did not have a written plan, and 11 states did not respond to the disaster 

planning questions in our survey. 

52GAO, Federal Action Needed to Ensure States Have Plans to Safeguard Children in the 

Child Welfare System Displaced by Disasters. GAO-06-944 (Washington, DC.: July 28, 2006).

Page 60 GAO-06-618 Catastrophic Disasters
To better assist states in developing child welfare disaster plans, 

we recommended to the Secretary of Health and Human Services 

that child welfare disaster planning guidance should address the 

dispersion of children and families within and across state lines. 

This guidance should include information on (1) preserving child 

welfare records, (2) identifying children who may be dispersed, 

(3) identifying new child welfare cases and providing services, 

(4) coordinating services and sharing information with other 

states, and (5) placing children from other states. We also 

recommended that the secretary develop and provide training on 

child welfare disaster planning to all states. HHS responded by

stating that it has taken action to update the guidance and provide 

training to states and will encourage them to develop and submit 

disaster plans for review. Finally, to ensure continuity of services 

within or across state lines for the children under state care, we 

have recommended that Congress should consider requiring that 

states develop and submit child welfare disaster plans for HHS 

review.

Recent GAO recommendations to DHHS 

and the Congress to safeguard children in

states’ child welfare systems HHS responses

DHHS should ensure that the department’s 

child welfare disaster planning guidance 

address the dispersion of children and families

within and across state lines, and develop and 

provide training on child welfare disaster 

planning to all states. 

HHS has taken action to update the 

guidance and provide training to states 

and will encourage them to develop and 

submit disaster plans for review.

To ensure continuity of services within or 

across state lines for the children under state

care, Congress should consider requiring that

states develop and submit child welfare 

disaster plans for HHS review. 

For more detailed information about our recommendations, see appendix I. 

Clear roles and coordinated planning are necessary, but not sufficient by 

themselves to ensure effective disaster management. It is important to test 

the plans and participants’ operational understanding of their roles and 

responsibilities through robust training and exercise programs. Training 

and exercising are designed to test emergency management plans and 

increase the level of understanding of those roles and responsibilities on 

the part of officials, contrasting catastrophic versus non-catastrophic 

disasters. Involving key federal, state, and local leaders—including elected 

leaders—in robust training and exercise programs can better familiarize 

Training and Exercises 

Page 61 GAO-06-618 Catastrophic Disasters
and prepare leaders with their roles in a catastrophic disaster. DHS has 

taken the lead to establish and maintain a comprehensive training and 

exercise program and standards to meet the national preparedness goal, as 

required by Homeland Security Presidential Directive 8 (HSPD-8). For 

example, the 15 national planning scenarios developed by DHS and the 

Homeland Security Council provide the basis for disaster exercises 

throughout the nation. 

In our previous work on Hurricanes Andrew and Hugo,53 we identified the 

need for the federal government to upgrade training and exercises for 

state and local governments specifically geared towards catastrophic 

disaster response. Hurricane Katrina demonstrated the potential benefits 

of applying lessons learned from training exercises and experiences with 

actual hurricanes, as well as the dangers of ignoring them. During our 

fieldwork, we found examples of how an incomplete understanding of 

NRP and NIMS roles and responsibilities could lead to misunderstandings, 

problems, and delays. In Louisiana, for example, some city officials were 

unclear about federal roles. In Mississippi, we were told that county and

city officials were not implementing NIMS because they did not 

understand its provisions. 

Our recent review of DOD’s preparedness and response to Hurricane 

Katrina reported that inadequate exercises prior to Hurricane Katrina 

created a lack of understanding within the military and among federal, 

state, and local responders as to the types of assistance and capabilities, 

the timing of assistance, and the contributions that the military might 

provide. We noted that DOD is likely to contribute substantial support to 

state and local authorities, including search and rescue assets, evacuation 

assistance, provision of supplies, damage assessment assets, and possibly 

helping to ensure public safety. However, we found that few exercises led 

by DHS or DOD focused on catastrophic natural disasters and none called 

for a major deployment of DOD capabilities. 

In the aftermath of Hurricane Katrina, we have made several

recommendations designed to build the capabilities to respond to and 

recover from catastrophic disasters. To ensure that agencies are 

adequately prepared to continue performing essential functions following 

 53See GAO, Disaster Assistance: DOD’s Support for Hurricanes Andrew and Iniki and 

Typhoon Omar, GAO/NSIAD-93-180 (Washington, D.C.: June 18, 1993); and Disaster 

Assistance: Federal, State, and Local Responses to Natural Disasters Need Improvement,

GAO/RCED-91-43 (Washington, D.C.: Mar. 6, 1991). 

Page 62 GAO-06-618 Catastrophic Disasters
an emergency, we recommended to DHS that it improve the assessment 

and oversight of agency continuity planning and develop guidance on

telework in such planning.54 DHS partially agreed and stated that FEMA 

will be conducting assessments in conjunction with its upcoming 

interagency exercise. To improve the military response to catastrophic 

disasters, as previously noted, we recently called for improving military 

plans and exercises and resolving response problems associated with 

damage assessment, communication, search and rescue, and logistics 

issues.55 We noted that DOD is taking steps to improve its future response, 

including expanding its training programs to accommodate planners from 

other agencies and to improve its disaster response planning and 

exercises. Also as first noted in our March 8, 2006, testimony, we are 

recommending that documents such as the NRP and the catastrophic 

incident annex be supported and supplemented by more detailed and 

robust operational implementation plans. Such operational plans should, 

for example, further define and leverage any military capabilities as might 

be needed in a catastrophic disaster. 

Recent GAO recommendations to DHS to 

improve federal continuity of operations DHS responses

DHS should conduct an assessment of 

agency continuity of operations plans. 

FEMA will be conducting assessments in 

conjunction with its upcoming interagency 

exercise. 

DHS should develop a methodology for 

assessing agency continuity of operations 

plans. 

DHS stated it had a methodology, but 

GAO believes it will not fully ensure 

emergency preparedness. 

DHS should establish a timeline for 

developing agency guidance for telework. 

FEMA will coordinate with OPM to develop 

further telework guidance. 

For more detailed information about our recommendations, see appendix I. 

Finally, as initially presented in our March 8, 2006, testimony, we are 

recommending that DHS should provide guidance and direction for 

federal, state, and local planning, training, and exercises to ensure such 

activities fully support preparedness, response, and recovery 

responsibilities at a jurisdictional and regional basis. This should also 

include the application of lessons learned from actual catastrophes and 

other disasters. 

 54GAO, 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). 

55GAO-06-643. 

Page 63 GAO-06-618 Catastrophic Disasters
New GAO recommendations to DHS improve federal, state, and local training and

exercises 

DHS should provide guidance and direction for federal, state, and local planning, 

training, and exercises to ensure such activities fully support preparedness, response, 

and recovery responsibilities at a jurisdictional and regional basis. This should also 

include the application of lessons learned from actual catastrophes and other disasters. 

For more detailed information about our recommendations, see appendix I. 

In addition, we observed in our earlier work on the National Preparedness 

Goal that if properly planned and executed, the goal and its related 

products, such as program implementation plans and requirements, may 

help guide the development of realistic budget and resource plans for an 

all-hazards national preparedness program.56 However, questions remain 

regarding what should be expected in terms of basic capabilities for most 

disasters compared to the expanded capabilities and mutual aid needed 

from other jurisdictions to meet the demands of a catastrophic disaster. 

Consequently, we recommend that DHS take the lead in monitoring 

federal agencies’ efforts to meet their responsibilities under the NRP and 

the interim National Preparedness Goal, including the development, 

testing, and exercising of agency operational plans to implement their 

responsibilities under the NRP, NIMS, and the National Preparedness 

Goal. 

New GAO recommendations to DHS monitor federal agencies’ efforts to meet their 

responsibilities under the NRP 

DHS should take the lead in monitoring federal agencies’ efforts to meet their 

responsibilities under the NRP and the interim National Preparedness Goal, including the 

development, testing, and exercising of agency operational plans to implement their 

responsibilities under the NRP, NIMS, and the National Preparedness Goal. 

For more detailed information about our recommendations, see appendix I. 

DHS Reported Taking 

Some Actions to Improve 

Capabilities in Response to 

Findings in Congress’ and 

the Administration’s 

Reviews 

DHS and the administration have engaged in an effort to respond to the 

White House Homeland Security Council’s study of lessons learned about

capabilities from Hurricane Katrina. The White House Homeland Security 

Council’s report originally identified 125 recommendations to improve 

future disaster preparedness, response, and recovery capabilities. As table 

3 shows, 27 recommendations that were to be implemented prior to June 

1, 2006, are focused on improving capabilities. However, DHS has not 

 56 GAO-05-652. 

Page 64 GAO-06-618 Catastrophic Disasters
provided information to support the actions it has reported taking to 

implement these 27 recommendations, including which actions have 

resulted in changes in operational readiness and capabilities. 

Page 65 GAO-06-618 Catastrophic Disasters
Table 3: Implementation of White House Homeland Security Council Recommendations for the 2006 Hurricane Season: 

Recommendations Related to Regarding Capabilities 

Recommendation related to capabilities 

(“Critical Action” recommendations are noted) 

Primary agency(ies) 

responsible for

implementation 

Supporting agency(ies)

responsible for

implementation 

Critical Action Recommendation: Establish rapid deployable

communications as well as institute a structure for consolidated 

federal operational reporting to the Department of Homeland

Security to ensure situational awareness 

Department of Homeland

Security 

Department of Defense, 

Department of Commerce, 

Federal Communications 

Commission 

Critical Action Recommendation: Encourage states to pre-contract 

with service providers for key disaster relief efforts, such as debris 

removal and the provision of critical commodities. 

Department of Homeland

Security 

Department of Justice, Office of 

Management and Budget 

Critical Action Recommendation: Designate locations throughout 

the country for receiving, staging, moving, and integrating federal 

disaster relief personnel and assets to ensure the most effective 

employment. 

Department of Homeland

Security 

All federal agencies 

Critical Action Recommendation: Update and utilize the national 

Emergency Alert System in order to provide the general public with 

advanced notification of and instruction for disasters and 

emergencies. 

Department of Homeland

Security 

Department of Defense, 

Department of Commerce, 

Federal Communications 

Commission, Department of 

Health and Human Services 

Critical Action Recommendation: Enhance the mechanism for 

providing federal funds to states for preparations upon warning of 

an imminent emergency. 

Department of Homeland

Security 

Office of Management & Budget, 

Department of Treasury, 

Homeland Security Council

Establish a National Information and Knowledge Management 

System. 

Department of Homeland

Security 

All federal agencies 

Establish a National Reporting System. Department of Homeland

Security 

All federal agencies 

Promote future preparedness of the federal, state, and local

authorities based on the risk, capabilities and needs structure of 

the National Preparedness Goal. 

Department of Homeland

Security 

All federal agencies 

Establish standard that each Homeland Security Region must be 

able to establish a self-sufficient, initial JFO anywhere within the 

region. 

Department of Homeland

Security 

All federal agencies 

Complete the review of National Security and Emergency 

Preparedness (NS/EP) communications policy by April 30, 2006. 

Department of Homeland

Security 

All federal agencies 

Organize an interagency group to begin the development of a 

national emergency communications strategy. An interim strategy 

to be completed May 31, 2006, should provide sufficient guidance 

and direction to address the deficiencies identified in the Hurricane 

Katrina response. 

Homeland Security Council,

Office of Science and 

Technology Policy 

All federal agencies 

Establish and maintain a deployable communications capability to 

quickly gain and retain situational awareness when responding to 

catastrophic incidents. 

Department of Homeland

Security 

N/A 

Establish a Chief Logistics Officer to oversee all logistics 

operations across multiple support functions. 

Department of Homeland

Security 

N/A 

Page 66 GAO-06-618 Catastrophic Disasters
Recommendation related to capabilities 

(“Critical Action” recommendations are noted) 

Primary agency(ies) 

responsible for

implementation 

Supporting agency(ies)

responsible for

implementation 

Streamline procedures for issuing mission assignments to other 

departments and agencies. These mission assignments will be 

identified in advance of an emergency so that logisticians can 

operationalize assets and provide resource support rapidly. In 

addition, other departments and agencies should establish 

procedures for promptly executing mission assignments. 

Department of Homeland

Security 

All federal agencies 

Designate DOT as the primary federal agency responsible for 

developing the federal government’s capability to conduct mass 

evacuations when disasters overwhelm state and local 

governments. DOT should, in coordination with HHS, DOD, 

Veterans Affairs, DHS, and the American Red Cross (ARC) plan, 

train, and conduct exercises for the timely evacuation of patients 

and transportation of medical supplies and personnel. 

Department of Transportation All federal agencies 

Evaluate (in coordination with the Department of Transportation) all 

state evacuation plans as well as the evacuation plans of the 75 

largest urban areas. 

Department of Homeland

Security 

Department of Transportation

Develop the capability to surge federal law enforcement resources 

in the immediate aftermath of a disaster. 

Department of Justice All federal agencies 

DOJ and DHS should each develop, in coordination with the other, 

the capability to rapidly deploy a contingent of federal law 

enforcement officers to prevent and respond to civil disorder. 

Department of Justice, 

Department of Homeland

Security 

All federal agencies 

Develop a unified and strengthened public health and medical 

command for federal disaster response. 

Department of Health and 

Human Services 

All Emergency Support Function 

(ESF)-8 Agencies 

Establish a rapidly-deployable public affairs teams, able to operate 

self-sufficiently, in austere conditions. These teams should be 

established across all federal departments and agencies with key 

Homeland Security responsibilities. 

Department of Homeland

Security 

All federal agencies 

Establish an integrated public alert and warning system in 

coordination with all relevant departments and agencies. 

Department of Homeland

Security 

All federal agencies 

Review, revise, and finalize the Interim NIPP within 90 days. Department of Homeland

Security 

All federal agencies 

Form an Impact Assessment Working Group to provide an overall 

economic impact assessment of major disasters, including the 

Departments of Homeland Security, Treasury, Commerce, Energy 

(Energy Information Administration), and Labor as well as the 

President’s Council of Economic Advisors. 

National Economic Council Department of Homeland

Security, Treasury, Commerce, 

Energy ,Labor, President’s 

Council of Economic Advisors

Establish an office with responsibility for integrating nongovernmental and other volunteer resources into federal, state, 

and local emergency response plans and mutual aid agreements. 

Further, DHS should establish a distinct organizational element to 

assist faith-based organizations. 

Department of Homeland

Security 

N/A 

Conduct state and local officials training and exercises. Department of Homeland

Security 

All federal agencies 

Establish a National Exercise and Evaluation Program (NEEP). Department of Homeland

Security 

All federal agencies 

Page 67 GAO-06-618 Catastrophic Disasters
Recommendation related to capabilities 

(“Critical Action” recommendations are noted) 

Primary agency(ies) 

responsible for

implementation 

Supporting agency(ies)

responsible for

implementation 

Develop the capability to rapidly activate a JTF-State for 

contingencies. 

Department of Defense N/A 

Provide training, technical, and other assistance in support of other 

departments’ and agencies’ homeland security professional 

development programs. 

Department of Homeland

Security 

All federal agencies 

Source: GAO analysis of DHS and Homeland Security Council data.

Note: N/A = not applicable. 

Additional Work Is Needed 

to Address FEMA’s Human 

Resource Challenges 

The various reports and our own work on FEMA’s performance before,

during, and after Hurricane Katrina suggest that FEMA’s human resources 

were insufficient to meet the challenges posed by the unprecedented 

degree of damage and the resulting number of hurricane victims. The 

Senate’s report concluded that FEMA did not have the resources 

necessary to fulfill the mission and respond effectively in a catastrophic 

event and recommended that DHS develop the national capabilities—

especially surge capacity—it needs to respond to catastrophic disasters, 

ensuring it has sufficient full-time staff and the support, such as 

contracting personnel and adequately trained and sufficiently staffed 

reserve corps, to ramp up capabilities, as needed. FEMA’s initial response 

assessment concluded that the agency needed to lead an audit of current 

staffing capability and workforce demands for staff in a severe or 

catastrophic event and determine the number of personnel available to 

serve in each position or unit for such an event. 

As stated during the March 8, 2006 hearing, strategic national leadership is 

provided by the Secretary of Homeland Security, who is to act as a focal

point for natural and manmade crises and emergency planning under the 

provisions of the Homeland Security Act. We stated our belief that other 

strategic national leadership positions such as the Undersecretary for 

Federal Emergency Management (who is also the Director of FEMA) and 

other key leadership and managerial positions within FEMA and DHS 

could benefit from having statutory, professional qualifications 

requirements. In addition, Congress could consider a term appointment for 

the Undersecretary for Federal Emergency Management and selected 

other positions within DHS. 

To improve the staffing level of its permanent full-time employees, on 

February 22, 2006, FEMA announced a hiring initiative to fill identified 

vacancies and attain a 95 percent staffing level in 95 days. The identified

vacancies are based on the positions FEMA had already allocated but not 

Page 68 GAO-06-618 Catastrophic Disasters
staffed; however, the current allocation of positions has not been validated

in a strategic workforce planning process. This staffing effort was to be 

completed before the hurricane season that began on June 1. However, the 

hiring initiative did not meet this target. Although FEMA was able to 

increase its staffing level from 76.5 percent to 81.6 percent between 

February 22 and May 29, the agency did not reach a staffing level of 

95 percent. In June, a FEMA Human Resources official told us that while 

Human Resources was working toward reaching the 95 percent staffing 

goal in August, the agency has not established a “hard” deadline because 

of the priority FEMA gives to life-saving and life-sustaining operations in 

emergencies that could significantly slow or suspend other operations. 

Although not part of the 95-percent staffing effort, a related effort to fill 

Senior Executive Service vacancies has not made similar progress, 

decreasing from 74 percent to 61 percent between February 22 and May 

29. According to FEMA officials, they expected that the time required to 

fill Senior Executive Service positions would be greater than the time 

required to fill other positions. In addition, the number of FEMA Senior 

Executive Service positions has increased since February 22, thus FEMA’s

level of Senior Executive Service staffing on May 29 was less than at the

beginning of the period. Finally, as of May 29, FEMA had six Senior 

Executive Service positions that, although not vacant, had incumbents 

who were in an “acting” capacity. 

Building Capabilities for 

Catastrophic Disasters 

Calls for a Risk 

Management Approach 

In earlier work that included an examination of the draft National 

Preparedness Goal, we observed that if properly planned and executed, 

the goal and its related products, such as program implementation plans 

and requirements, may help guide the development of realistic budget and 

resource plans for an all-hazards national preparedness program. 

However, questions remain regarding what should be expected in terms of 

basic capabilities for most disasters compared to the expanded 

capabilities and mutual aid needed from other jurisdictions to meet the 

demands of a catastrophic disaster.57

Risk management can be central to assessing needs and resources in the 

event of future catastrophic disasters. A decision-making process using 

risk-management principles can guide the development of federal 

capabilities and the expertise that can be used to respond effectively to 

 57 GAO, Homeland Security: DHS’s Efforts to Enhance First Responders’ All-Hazards 

Capabilities Continue to Evolve, GAO-05-652 (Washington, D.C.: July 11, 2005). 

Page 69 GAO-06-618 Catastrophic Disasters
catastrophic disasters. The goal of risk management is to integrate 

systematic concern for risk into the normal cycle of agency decision 

making and implementation. In the aftermath of Hurricane Katrina, we 

identified the need for a risk management decision-making approach to 

develop the nation’s capabilities and expertise to respond to a 

catastrophic disaster. Given the likely costs, Congress may wish to 

consider the use of a risk-management framework as it carries out its 

oversight and legislative responsibilities with regard to national 

preparedness and the recovery. 

Our risk management framework calls for risk assessment based on three 

components of risk—threat, vulnerability, and criticality (i.e., the severity 

of the consequences of an incident). Using the information gathered 

through risk assessment, agencies can then: (1) assess the likelihood that 

an adverse event will occur whether caused by nature or man; (2) identify 

and select among alternatives to reduce the vulnerability to such an event;

and (3) take actions that might reduce the consequences of one or more 

potential adverse events should they occur. This is a continuous process 

and should consider all hazards. Our risk management framework calls for 

links between risk-mitigation strategies, strategic goals, and plans and 

budgets. The framework also calls for an assessment of the value and risks 

of various courses of action as a tool for setting priorities and allocating 

resources, and the use of performance measures to assess outcomes and 

adjust future actions as needed. 

Building and sustaining needed capabilities should be based on a risk 

assessment that would identify the vulnerabilities of communities or 

regions to potential disasters of various magnitudes and causes and how 

they should be addressed within available resources and with contingency 

planning. Periodic assessments of all hazards should determine if plans 

remain viable, actual capabilities match planned capabilities, and the 

contingency plans are appropriate. Because different states and areas face

different risks, not every state or area should be expected to have the 

same capability to prepare for a catastrophic disaster. In our previous 

work examining the draft National Preparedness Goal, we observed that 

DHS’s assessment and reporting implementation plan, intended to 

accurately identify the status of capabilities at the state, regional, and local 

levels, is vital for establishing a baseline and providing an ongoing 

feedback loop upon which preparedness decisions at multiple levels of 

government can be based. Assessment of catastrophic disaster planning 

and capability needs will be a critical piece. As a result, we recommend 

that DHS use an all-hazards, risk management approach in deciding 

Page 70 GAO-06-618 Catastrophic Disasters
whether and how to invest federal resources in specific capabilities for a 

catastrophic disaster. 

New GAO recommendation to DHS to use a risk management approach

Given that resources are finite, DHS should use a risk management approach in 

deciding whether and how to invest in specific capabilities for a catastrophic disaster. 

For more detailed information about our recommendations, see appendix I. 

Effective controls and accountability mechanisms for the use of resources 

during a catastrophic disaster are essential to ensure that resources are 

used appropriately, but there is a tension between normal controls and 

accountability procedures and the need to deliver assistance 

expeditiously. As we stated in February 2006, the inspectors general of the 

various federal departments have been conducting much of the detailed 

Hurricane Katrina-related work on fraud, waste, and abuse in individual 

federal programs.58 In the wake of Hurricane Katrina, contracts were let 

quickly with little competition, funds were spent for temporary housing 

that was never used, and hundreds of millions of dollars might have been 

provided to ineligible persons for cash assistance because of an inability to

verify their social security numbers or other information. Our work, and 

that of the DHS Inspector General and others across the audit community, 

have identified a number of problems that have resulted in inadequate

accountability for the use of resources during and after Hurricane Katrina, 

including (1) contracting problems; (2) accounting for and managing

international assistance that was offered; (3) tracking and managing food, 

water, and ice deliveries; and (4) screening fraudulent applications for 

assistance. These problems might have been avoided if there had been 

better planning for delivering assistance during catastrophic disasters. 

Balance Needed 

between Quick 

Provision of 

Assistance and 

Ensuring 

Accountability to 

Protect against Waste, 

Fraud, and Abuse 

 58GAO, Statement by Comptroller General David M. Walker on GAO’s Preliminary 

Observations Regarding Preparedness and Response to Hurricanes Katrina and Rita, 

GAO-06-365R. (Washington: D.C.: Feb. 1, 2006). 

Page 71 GAO-06-618 Catastrophic Disasters
Ensuring accountability during a catastrophic disaster requires the 

appropriate people, processes, and technology to, among other things, 

qualify benefit applicants; report and account for contracts awarded (in 

advance of or after the event) for such things as debris removal, temporary 

shelter, feeding, and medical care for disaster victims; and documenting 

reimbursable expenses, such as first responder overtime. Of necessity, 

initial response efforts focus on the immediate, urgent tasks of search and 

rescue and services such as medical care and food and shelter for those 

displaced by the disaster. In any major disaster there is the difficult task of

putting in place controls and accountability mechanisms that reduce the 

potential for waste, fraud, and abuse but are flexible enough to provide 

assistance and resources quickly. 

Catastrophic Disaster 

Controls and 

Accountability 

Mechanisms Should Be 

Flexible to Address the 

Urgent Need for Delivery 

of Assistance 

To date, Congress has appropriated approximately $88 billion of federal 

support through emergency supplemental appropriations to federal 

agencies for hurricane disaster relief and recovery efforts related to the 

2005 hurricanes. 59 For Stafford Act activities, Congress makes 

appropriations to the Disaster Relief Fund, which FEMA administers. The 

Stafford Act, the principal federal disaster assistance statute, authorizes 

three general types of major disaster assistance: (1) public assistance 

grants to state and local governments and certain private nonprofit 

organizations, (2) hazard mitigation grant programs, and (3) individual 

assistance programs. For example, in the individual assistance area, FEMA 

may provide direct assistance (temporary housing units) and financial 

assistance (grant funding for temporary housing and other disaster-related 

needs) to disaster victims through IHP. FEMA had provided about 

$5.6 billon in IHP benefits as of April 2006. 

As we stated in our March 8, 2006, testimony, catastrophic disasters not 

only require a different magnitude of capabilities and resources for 

effective response, but they may also require more flexible policies and 

operating procedures. In a catastrophe, streamlining, simplifying, and 

expediting decision making should quickly replace “business as usual” and 

 59Four emergency supplemental appropriations acts account for the approximately 

$88 billion in hurricane relief. See Emergency Supplemental Appropriations Act to Meet 

Immediate Needs Arising From the Consequences of Hurricane Katrina, 2005, Pub. L. 

No. 109-61, 119 Stat. 1988 (2005); Second Emergency Supplemental Appropriations Act to 

Meet Immediate Needs Arising From the Consequences of Hurricane Katrina, 2005, Pub. L. 

No. 109-62, 119 Stat. 1990 (2005); Emergency Supplemental Appropriations to Address 

Hurricanes in the Gulf of Mexico, Pub. L. No. 109-148, div. B, title I, 119 Stat. 2680, 2745 

(2005); and Further Hurricane Disaster Relief and Recovery, Pub. L. No. 109-234, title II, 

120 Stat. 418, 443 (2006). 

Page 72 GAO-06-618 Catastrophic Disasters
the unquestioned following of long-standing policies and operating 

procedures used in normal situations for providing relief to disaster 

victims. When there is a catastrophic disaster, temporarily suspending 

certain rules and regulations may be necessary in order to expedite relief

and recovery of the affected area, even if such a suspension requires 

legislation. The key is to recognize when flexibility is needed to meet 

response and recovery needs in a catastrophic disaster. Across our work 

we have discovered many examples where quick action could not occur as 

agencies followed procedures that required extensive, time-consuming 

processes, delaying the delivery of vital supplies and other assistance. In 

other cases, urgent need was used to bypass standard procedures without 

better outcomes. Processes and controls must be sufficient to provide the 

documentation needed for expense reimbursement and reasonable 

assurance that resources have been used legally and for the purposes 

intended. 

As we saw in the aftermath of Hurricane Katrina, the lack of internal 

controls and other accountability mechanisms established prior to the 

disaster can result in delay, uncertainty, and wasted or misdirected 

resources. The aftermath of a catastrophic disaster is not the time to 

determine what rules and procedures to suspend or streamline. It is 

important that essential accountability mechanisms be designed and ready 

to implement prior to the event, just as an incident management structure 

should be understood and ready to implement prior to an event. 

Decentralization of responsibilities enhances the challenge of assuring that 

controls and accountability mechanisms are being followed. 

Hurricane Katrina 

Highlighted Several 

Contracting Deficiencies 

The government’s response to Hurricanes Katrina and Rita depended 

heavily on contractors to deliver ice, water, and food supplies; patch 

rooftops; and provide housing to displaced residents and temporary 

facilities to local government agencies. Audits by the inspectors general at 

several agencies, along with the major Hurricane Katrina “after action” 

reports, identified deficiencies in the award and execution of many of the 

individual contracts. From a broader perspective, our past work has 

shown that, to ensure successful acquisition outcomes in any 

environment, certain critical success factors must be in place: sound 

acquisition planning, good business arrangements, and effective contract 

monitoring and oversight. To do so, decision makers and acquisition 

personnel need sufficient knowledge and clearly defined and

communicated roles and responsibilities. We identified deficiencies under 

each of the critical success factors. 

Page 73 GAO-06-618 Catastrophic Disasters
Our work on contracting issues following Hurricane Katrina indicates that

some key federal agencies involved in responding to the disaster did not 

have adequate acquisition plans for carrying out their assigned

responsibilities. For example, while contracts for some items were in 

place prior to the storm, FEMA did not adequately anticipate needs for 

such services as providing temporary housing and public buildings. Better 

planning for requirements could have avoided some costs, such as the 

$3 million FEMA spent for 4,000 base camp beds that were never used. 

Another example was the government’s approach to acquiring refrigerated 

truck services. During the 2005 hurricane season, the U. S. Army Corps of 

Engineers (Corps), the Department of Transportation, and FEMA had 

contracts with three separate contractors for refrigerated truck services.60

We did not find a coordinated plan for obtaining these services. By not 

taking a coordinated approach, the agencies may have missed 

opportunities to make the most cost-effective use of their contracts. For 

example, the government obtained selected refrigerated truck services 

using an existing contract with Department of Transportation at an 

average price over 60 percent higher than the price FEMA paid for similar 

services. 

Acquisition planning 

Having good business arrangements requires that agencies have sufficient

knowledge about the goods and services available in the market to satisfy 

their requirements, as well as the ability to translate that knowledge into 

sound business decisions in using their contracts. We found instances 

where insufficient knowledge of the market or unsound ordering practices 

led to excessive or wasteful expenditures. 

Business arrangements 

In one case, FEMA tasked the Corps with acquiring temporary classrooms 

for Mississippi within a very short time frame. To meet the requirement, 

the Corps placed a non-competitive order for the classrooms under an 

existing agreement for portable buildings. Because the Corps had not been

formally assigned this task prior to Katrina’s landfall, contracting officials 

lacked sufficient knowledge of the industry and information about 

suppliers, inventories, and prices that would have been useful in 

negotiating a good deal.61 The business arrangement the Corps used 

 60One contractor provided ice production and transport services, another provided cold

storage and transport services, and a third contractor provided a variety of transportation 

services, including refrigerated trucks. 

61GAO, Hurricane Katrina: Army Corps of Engineers Contract for Mississippi 

Classrooms, GAO-06-454 (Washington D.C.: May 1, 2006). 

Page 74 GAO-06-618 Catastrophic Disasters
involved layers of subcontractors: the Corps purchased 45 portable 

buildings from a contractor, who in turn purchased the 45 buildings from a 

distributor, who in turn purchased them from another distributor, who had 

purchased the 45 buildings from the manufacturer. Each subcontractor 

added an additional fee, resulting in the Corps agreeing to a price that was 

63 percent higher than the manufacturer’s price. 

Another example involved the process for ordering and delivering ice. 

According to Corps officials, FEMA ordered at least double the amount of

ice required, resulting in an oversupply of ice and a lack of distribution 

sites available to handle the volume ordered. One FEMA official working

at the local level told us that to ensure that he would receive an adequate 

amount of ice for first few days, he doubled his initial orders. He said that

he kept ordering more ice because headquarters did not provide timely 

notification of when his shipments would arrive. At the end of hurricane 

season 2005, FEMA had over 2,000 truckloads of excess ice, which costs 

the government over $500,000 per month for storage and additional 

transportation costs. The Senate report on Katrina noted that when 

Hurricane Katrina hit, and FEMA realized the scope of the temporary 

housing needs, the agency began buying all of the travel trailers it could 

find. Unfortunately, FEMA purchased approximately $900 million worth of 

manufactured homes and modular homes that could not be used because 

FEMA’s own regulations do not allow for these types of homes to be 

placed in flood plains. Further, some of the homes purchased did not fit 

FEMA’s size standards. However, FEMA seemingly had no plans for how 

the homes would be used when the purchases were made. 

Effective monitoring—to ensure that goods and services are delivered in

accordance with the agreed upon schedule, cost, quality, and quantity 

provisions in the contract—relies on having sufficient numbers of trained 

and properly-deployed personnel to oversee contractor performance. Our 

work indicated that the number of monitoring staff available was not 

always sufficient, nor were they effectively deployed to provide sufficient 

oversight. For example, on FEMA’s contracts for installing temporary 

housing in four states, only 17 of the 27 technical monitors necessary to 

oversee contractor performance had been assigned at the time of our 

review. In another case, Corps officials told us that progress in the 

temporary roof program was slowed due to the lack of sufficient monitors. 

Contract Monitoring and 

Oversight 

Deployment practices did not always provide for appropriate notification 

of responsibilities or overlap of rotating contracting personnel, thus 

making knowledge transfer and continuity of contract management 

operations difficult. For example, for four of the contracts we reviewed, 

Page 75 GAO-06-618 Catastrophic Disasters
officials were either unaware or not notified by FEMA of their oversight 

responsibilities. The lack of overlap between oversight personnel for a 

large temporary housing contract left the most recent contract 

administrator with no knowledge or documentation of who had authorized 

the contractor to perform certain activities or why the activities were 

being performed. 

We identified a number of emergency response practices in the public and 

private sectors that provide insight into how the federal government can 

better manage its disaster-related procurements. These practices include

Practices to Help Ensure 

Successful Acquisition

Outcomes 

• developing knowledge of contractor capabilities and prices by 

identifying available commodities and services and establishing vendor 

relationships before they are needed, 

• establishing a scalable operations plan to adjust the level of capacity

required to effectively respond to the need, 

• formally assigning and communicating disaster-related responsibilities, 

with joint training for government and contractor personnel, and 

• providing sufficient numbers of field-level contracting staff with the 

authority needed to meet mission requirements. 

We found a positive example of acquisition practices used during the 

response to Katrina in our recent review of the Coast Guard’s response 

and recovery missions.62 Under the NRP, the Coast Guard is the co-lead 

agency along with the Environmental Protection Agency for Emergency 

Support Function 10: Oil and Hazardous Materials Response along coastal 

areas. Prior to Hurricane Katrina, the Coast Guard had basic ordering 

agreements with fixed prices and other pre-established terms and 

conditions with private companies to facilitate a rapid response. These 

agreements were be used to respond to oil spills, for acquiring the use of 

equipment for vessel salvage and for the use of helicopters. According to 

Coast Guard officials, they have used basic ordering agreements for this 

particular mission since the early 1990s, and have extensive knowledge of

the market for these particular goods and services. Although we have not 

conducted a thorough evaluation of the Coast Guard’s Marine 

Environmental Protection clean-up efforts, these agreements contributed 

 62 GAO, Coast Guard: Observations on the Preparation, Response, and Recovery Missions 

Related to Hurricane Katrina, GAO-06-903 (Washington D.C.: July 31, 2006). 

Page 76 GAO-06-618 Catastrophic Disasters
to the successful cost control of the marine environmental pollution 

response after Hurricane Katrina, according to Coast Guard officials. 

To help ensure successful acquisition outcomes, we recommend that DHS 

provide guidance on advance procurement practices and procedures for 

those federal agencies with roles and responsibilities under the NRP, so 

that these agencies can better manage disaster-related procurements. 

These practices should be in advance of disasters, ongoing and 

continuous, and include (1) developing knowledge of contractor 

capabilities, and available commodities, services, and prices, as well as 

developing pre-established vendor relationships, on a competitive basis 

whenever feasible; (2) establishing scalable operations plans to adjust the 

level of capacity needed to respond; (3) formally assigning and 

communicating disaster-related responsibilities and, where feasible, 

incorporating necessary training; and (4) providing sufficient numbers of 

field-level contracting staff to meet mission requirements. DHS should also 

establish an assessment process to monitor agencies’ continuous planning 

efforts for their disaster-related procurement needs and the maintenance 

of capabilities.

New GAO recommendations to DHS improve advanced procurement practices and

procedures 

DHS should provide guidance on advance procurement practices and procedures for 

those federal agencies with roles and responsibilities under the NRP, so that these 

agencies can better manage disaster-related procurements. These practices should be 

in advance of disasters, ongoing and continuous, and include (1) developing knowledge 

of contractor capabilities, and available commodities, services and prices as well as 

developing pre-established vendor relationships, on a competitive basis whenever 

feasible; (2) establishing scalable operations plans to adjust the level of capacity needed

to respond; (3) formally assigning and communicating disaster-related responsibilities 

and, where feasible, incorporating necessary training; and (4) providing sufficient 

numbers of field-level contracting staff to meet mission requirements. DHS should also 

establish an assessment process to monitor agencies’ continuous planning efforts for 

their disaster related procurement needs and the maintenance of capabilities. 

For more detailed information about our recommendations, see appendix I. 

Lack of Controls Limited 

Accountability in the 

Receipt and Distribution of 

International Assistance 

Federal agencies involved in managing international assistance were not 

prepared to coordinate, receive, distribute, or account for the assistance.

The NRP establishes the Department of State as the coordinator of all 

offers of international assistance. As part of its Stafford Act 

responsibilities, FEMA has authority to accept the assistance and 

Page 77 GAO-06-618 Catastrophic Disasters
coordinate its distribution.63 Agency officials involved in the cash and inkind assistance during Hurricane Katrina told us the agencies were not 

prepared to accept international assistance for use in the United States, 

because the U.S. government had not received such substantial amounts of 

international disaster assistance before. Therefore, they told us that they 

developed ad hoc processes to accept, receive, and distribute the cash and 

in-kind assistance. Understandably, not all of these ad hoc processes 

contained controls to support full accountability. For example, we 

recently reported that no agency tracked and confirmed that the 

assistance arrived at its destinations.64 Also, we found that lack of 

procedures, inadequate information up front about the donations, and 

insufficient coordination resulted in the U.S. government agreeing to 

receive food and medical items that were unsuitable for use in the United

States and entailed storage costs of about $80,000. DOD’s lack of internal 

guidance regarding the State Department’s coordinating process resulted 

in some foreign military donations that arrived without State Department, 

FEMA, or DOD oversight. 

In the aftermath of Katrina, we recommended that DHS and DOD, in 

consultation with the Department of State, establish within the NRP—or 

other appropriate plans—clearly delineated policies and procedures for 

the acceptance, receipt, and distribution of international assistance to 

improve the policies, procedures, planning, and oversight of international

cash and in-kind donations to the U.S. government in response to 

disasters. DOD and DHS generally agreed with our recommendations. DHS 

noted that, in some cases, actions were already underway to address the 

recommendations. 

 6342 U.S.C. § 5201(b). 

64GAO, Hurricane Katrina: Comprehensive Policies and Procedures Are Needed to 

Ensure Appropriate Use of and Accountability for International Assistance, GAO-06-460

(Washington D.C.: Apr. 6, 2006). 

Page 78 GAO-06-618 Catastrophic Disasters
Recent GAO recommendations to DHS 

and DOD to improve accountability for 

international assistance DOD and DHS responses 

DHS and DOD, in consultation with the 

Department of State, should establish 

within the NRP—or other appropriate 

plans—clearly delineated policies and 

procedures for the acceptance, receipt, and 

distribution of international assistance. 

DOD and DHS generally agreed with our 

recommendations. DHS noted that, in 

some cases, actions were already 

underway. 

For more detailed information about our recommendations, see appendix I. 

Control Weaknesses in 

Individual Assistance 

Payments Resulted in 

Fraud and Abuse 

When responding to the needs of the victims of a catastrophic disaster, 

FEMA must balance controls and accountability mechanisms with the 

immediate need to deliver resources and assistance in an environment 

where the agency’s initial response efforts must focus on life-saving and

life-sustaining tasks. Nonetheless, our work has identified flaws in the 

programs designed to assist disaster victims, which would leave the 

federal government vulnerable to fraud and abuse of individual assistance

payments. 

As mentioned earlier, FEMA provides direct assistance—such as 

temporary housing units—and financial assistance—such as grant funding

for temporary housing and other disaster-related expenses—to disaster 

victims through IHP. Under IHP, FEMA may provide disaster assistance to

individuals and households who have uninsured (or underinsured) needs 

that cannot be met through other means. IHP assistance is limited to 

18 months.65 The maximum amount of financial assistance available is 

adjusted annually for inflation and was capped at $27,200 in 2006. IHP 

provides assistance to cover certain expenses not covered by insurance or 

which individuals or households cannot cover with their own resources. 

Because IHP benefits are statutorily capped, the program may not cover 

all losses to damaged property or restore such property to its condition 

before the disaster.66 To receive assistance, applicants must qualify for 

benefits through a process implemented primarily by FEMA contractors 

and temporary disaster employees in a network of permanent and 

 65FEMA may extend this 18-month limit if it determines that, due to extraordinary 

circumstances, an extension would be in the public interest. 44 C.F.R. § 206.110(e). 

66The maximum of IHP assistance is statutorily capped at $25,000, adjusted annually to

reflect changes in the Consumer Price Index. 42 U.S.C § 5174(h). In 2005, the maximum 

was $26,200. 

Page 79 GAO-06-618 Catastrophic Disasters
temporary field offices. The benefits provided to disaster victims of 

hurricanes in 2005 far surpassed the number of registrants, beneficiaries, 

and the dollar value amount of benefits provided under the program for 

named hurricane disasters in 2003 and 2004 combined. 

Under the IHP, disaster victims in declared counties must first register and 

apply for assistance with FEMA, by phone, in person at a disaster recovery 

center, or over the Internet. FEMA does not provide monetary assistance 

to any individual without first receiving an application from and taking 

steps to validate the eligibility of that individual based on the application. 

For some IHP benefits, applicants above a certain income threshold must 

first apply to the SBA for disaster loan assistance.67

Many of the challenges FEMA faced after Hurricane Katrina stemmed from 

the magnitude of the disaster, including the number of victims who were 

displaced from their homes, and related issues in planning, trained staff, 

and limitations for implementation of the program. As we have reported, 

FEMA’s processes for validating eligibility in the wake of Hurricane 

Katrina were partially successful. Our work, however, has identified 

significant flaws in the process for disaster victim applications that leave 

the federal government vulnerable to fraud and abuse of individual 

assistance payments.68

We estimate that through February 2006, FEMA made about 16 percent, or 

$1 billion, in improper and potentially fraudulent payments to applicants 

who used invalid information to apply for disaster assistance. Based on 

our statistical sample, we are 95-percent confident that the range of 

improper and potentially fraudulent payments is from $600 million to 

$1.4 billion. In our assessment of whether a payment was improper and 

potentially fraudulent, we did not test for other evidence of impropriety or 

potential fraud, such as insurance fraud and bogus damage claims. This 

means our review potentially understates the magnitude of improper 

payments made. Examples of fraud and abuse include payments to 

applicants who used post office boxes, United Parcel Service stores, and 

cemeteries as their damaged property addresses. In one case, FEMA paid 

 67Loans from the Small Business Administration are considered to be the primary means of 

disaster assistance for disaster victims who have the financial ability to repay such loans.

68GAO, Expedited Assistance for Victims of Hurricanes Katrina and Rita: FEMA’s

Control Weaknesses Exposed the Government to Significant Fraud and Abuse,

GAO-06-403T (Washington, D.C.: Feb. 13, 2006). 

Page 80 GAO-06-618 Catastrophic Disasters
nearly $6,000 to our applicant who submitted a vacant lot as a damaged 

address.69

For Internet applications, limited automated controls were in place to 

verify an applicant’s identity. However, we found no independent 

verification of the identity of applicants who applied for disaster 

assistance over the telephone. To demonstrate the vulnerability inherent 

in the call-in applications, we used falsified identities, bogus addresses, 

and fabricated disaster stories to register for IHP and found that we were 

able to obtain $2,000 expedited assistance checks from FEMA through 

these means.70 As we previously testified, FEMA continued to provide our 

undercover operations with additional disaster-related assistance 

payments even after FEMA received indications from various sources that 

our applications may have been bogus.

71 Other control weaknesses 

included the lack of any validation of damaged property addresses for 

both Internet and telephone registrations. Our work in this area revealed

that thousands of applicants misused social security numbers—i.e., used 

social security numbers that were never issued or belonged to deceased or 

other individuals. Our case study investigations of several hundred 

applications also revealed the use of bogus damaged property addresses. 

For example, our visits to over 200 of the case study damaged properties 

in Texas and Louisiana showed that at least 80 of these properties were 

bogus—including vacant lots and nonexistent apartments. We found that 

FEMA also made duplicate expedited assistance payments to about 

5,000 of the nearly 11,000 debit card recipients—once through the 

distribution of debit cards and again by check or electronic funds transfer. 

We found that although debit cards were used predominantly to obtain 

cash, food, clothing, and personal necessities, a small number were used 

for adult entertainment, bail bond services, and weapons purchase, which 

do not appear to be items or services that are essential to satisfy disasterrelated needs. 

 69GAO, Hurricanes Katrina and Rita: Improper and Potentially Fraudulent Individual 

Assistance Payments Estimated to Be between $600 Million and $1.4 Billion, 

GAO-06-844T (Washington, D.C.: June 14, 2006). 

70Expedited Assistance—a component of the IHP program during Hurricanes Katrina and

Rita—took the form of $2,000 payments to disaster victims to help with the immediate, 

emergency needs for food, shelter, clothing, and personal necessities. 

71 GAO-06-844T. 

Page 81 GAO-06-618 Catastrophic Disasters
To reduce waste, fraud and abuse in expedited assistance for disaster 

victims, we have recommended that the Secretary of Homeland Security 

direct the Undersecretary for Federal Emergency Management to take six 

actions to address the weaknesses we identified in the administration of 

IHP: (1) establish an identity verification process for IHP registrants 

applying via both the Internet and telephone; (2) develop procedures to 

improve the existing review process of duplicate registrations containing 

the exact same social security number (SSN); (3) establish an address 

verification process for IHP registrants applying via both the Internet and 

telephone; (4) explore entering into an agreement with other agencies to 

periodically authenticate information contained in IHP registrations; 

(5) establish procedures to collect duplicate expedited assistance 

payments or to offset these amounts against future payments; and 

(6) ensure that any future distribution of IHP debit cards includes 

instructions on their proper use.72

DHS and FEMA concurred fully with four of our six recommendations, 

and partially concurred with the remaining two recommendations. FEMA 

and DHS stated that they have already taken actions to address some of 

these recommendations. These actions include instituting an Internet 

application process that will prevent all duplicate applications from the 

Internet, and conducting data sharing tests with the Social Security 

Administration. In addition, DHS and FEMA stated that, starting in June 

2006, all registration addresses (including those provided through phone-in 

applications) will be subjected to an online verification during the 

application process. While these are steps in the right direction, we will 

follow up on whether the actions taken fully address our 

recommendations. Going forward it will be important for FEMA to 

establish effective controls to prevent fraudulent and improper payments

before they occur, because fraud prevention is a far more effective control 

than detecting improper and potentially fraudulent payments after they are 

made. Our experience with organizations that rely on a process that 

attempts to detect improper and potentially fraudulent payments after 

they are made is that the organization recovers only a fraction of the 

payments that should not have been made. 

 72 GAO, Expedited Assistance for Victims of Hurricanes Katrina and Rita: FEMA’s

Control Weaknesses Exposed the Government to Significant Fraud and Abuse,

GAO-06-655 (Washington, D.C.: June 16, 2006).

Page 82 GAO-06-618 Catastrophic Disasters
Recent GAO recommendations to DHS 

to reduce waste fraud and abuse in the 

Individuals and Households Program DHS’s responses 

Establish an identity verification process for 

IHP registrants applying via both the 

Internet and telephone.

Develop procedures to improve the existing

review process of duplicate registrations 

containing the exact same SSN.

Establish an address verification process 

for IHP registrants applying via both the 

Internet and telephone.

Explore entering into an agreement with 

other agencies to periodically authenticate 

information contained in IHP registrations.

Establish procedures to collect duplicate 

expedited assistance payments or to offset 

these amounts against future payments.

Ensure that any future distribution of IHP 

debit cards includes instructions on their 

proper use. 

FEMA and DHS stated that they have 

already taken actions to address some of 

these recommendations, including 

instituting an Internet application process 

that will prevent all duplicate registrations 

from the Internet, and conducting data 

sharing tests with the Social Security 

Administration. In addition, DHS and FEMA 

stated that, starting in June 2006, all 

registration addresses (including those 

provided through phone-in applications) will 

be subjected to an online verification during

the registration process. While these are 

steps in the right direction, we will follow up 

on whether the actions taken fully address 

our recommendations. 

For more detailed information about our recommendations, see appendix I.

DHS has also reported taking a number of other actions and initiatives 

designed to improve timeliness and accountability in providing goods and 

services to the affected areas and their victims. However, because DHS did 

not provide us documentation to verify these actions and initiatives, we 

could not determine their status, including the extent to which they are 

operational. According to DHS, their current efforts are designed to 

enhance the debris removal guidance, processes and policies to, in part, 

ensure consistent cost-sharing for federal contracting (through the Corps) 

and local government contracting. FEMA has also announced a number of 

customer service improvement efforts so federal recovery programs will 

have the capacity to handle a catastrophic incident. These include 

(1) doubling FEMA’s registration capacity to 200,000 per day;

(2) instituting a pilot project for deployable Mobile Registration Intake 

Centers; (3) enhancing identity verification during registration; 

(4) increasing the daily home inspection capacity of FEMA contracted 

firms from 7,000 per day to 20,000; and (5) updating its policies to improve 

and quicken determination of applicant eligibility for FEMA’s IHP program 

along with determining eligibility for any expedited assistance available 

under the program. 

Page 83 GAO-06-618 Catastrophic Disasters
The federal government will be a major partner in the longer-term 

rebuilding of the Gulf Coast because of the widespread damage and 

economic impact. Rebuilding raises issues concerning the need for 

consensus on what rebuilding should be done, where and based on what 

standards, who will pay for what, and what oversight is needed to ensure 

federal funds are spent for their intended purposes. In addition, federal 

programs will face financial difficulties in responding to the long-term 

needs, and there is uncertainty concerning the impact of catastrophic 

disasters on the availability and affordability of insurance. Among the 

issues that will require federal attention include (1) assessing the 

environmental hazards created by the storms; (2) rebuilding and 

strengthening the levees; (3) providing assistance to school districts that 

have enrolled large numbers of evacuee children; (4) continuing to provide 

assistance for temporary housing, and (5) assuring the financial soundness 

of the National Flood Insurance Program. Finally, our March 2006 

testimony identified guidelines that may enhance federal financial 

assistance’s performance in the restoration of the Gulf Coast. 

State and local officials will have the lead on determining the future needs 

of the Gulf Coast. However, a number of federal agencies have 

responsibilities related to the long-term recovery. The recovery should be 

guided by careful planning that balances the need for speedy economic 

recovery with actions that reduce the impact of future storms, such as 

elevating structures located in areas at highest risk of damage from future 

flooding. In Louisiana and Mississippi, several efforts are underway to 

implement long-term rebuilding strategies. The actions of state, local, and

federal governments, individuals, and nongovernmental entities will affect

the speed and nature of the region’s recovery.

Long-Term Recovery 

and Rebuilding 

Efforts Raise Issues 

for Congress to 

Consider 

Long-Term Recovery Is a 

Shared Responsibility and 

a Number of Federal 

Agencies Will Play a Role 

in Addressing Multiple 

Recovery-Related Issues 

Our March 2006 testimony identified a number of issues that will require 

the attention of the Administration and Congress. Among those issues 

include the rebuilding the region’s transportation, health infrastructures 

and federal facilities, and the availability and affordability of insurance 

coverage. We also have ongoing work examining other issues that will 

require federal attention, including (1) assessing the environmental 

hazards created by the storms; (2) rebuilding and strengthening the levees; 

(3) providing assistance to school districts that have enrolled large 

numbers of evacuee children; (4) continuing to provide assistance for 

temporary housing; and (5) assuring the financial soundness of the 

National Flood Insurance Program. 

Page 84 GAO-06-618 Catastrophic Disasters
Immediately following Katrina, areas along the Gulf Coast faced a number

of environmental challenges associated with oil and hazardous material 

releases resulting from the storm. EPA and federal and state partners 

continue to monitor air, water, and sediment for potential chemicals of 

concern such as heavy metals including lead and arsenic; polycyclic 

aromatic hydrocarbons; pesticides; and diesel and oil range organics and 

have jointly issued public reports with CDC that provide 

recommendations on steps individuals can take to limit potential 

exposure. EPA is also continuing to provide support to Louisiana and 

Mississippi in assessing drinking water and wastewater infrastructure. 

Following initial assessments of drinking water and wastewater impacts 

in Louisiana and Mississippi at the request of the states, FEMA, and the 

Corps, Louisiana requested additional EPA assistance in conducting 

needs assessments of repairs at drinking water systems in the state. These 

facilities are now largely operational, but distribution systems are still 

being repaired, leaving some areas without service. Through its Office of 

Recovery and Removal, Mississippi is reviewing wastewater and drinking

water needs, and EPA has offered to assist, if needed. While EPA has 

largely completed its response to hazardous material releases, which has 

included responding to spills at industrial facilities and collecting 

orphaned chemical drums and tanks, the agency continues to oversee 

cleanup of a million-gallon oil spill at a Murphy oil facility in St. Bernard 

Parish, Louisiana. Finally, EPA continues to assist in hazardous debris 

removal by coordinating recycling efforts for damaged refrigerators and 

electronic goods, removing and safely disposing of thousands of 

household hazardous waste containers such as paint cans and propane 

tanks, and working with the Army Corps of Engineers and local agencies 

to remove CFCs and other refrigerants from abandoned appliances that 

are harmful to the environment. 

Assessing Environmental 

Hazards Involves the 

Environmental Protection 

Agency 

Areas along the Gulf Coast are also facing environmental challenges as 

they begin long-term rebuilding efforts. Large-scale demolition efforts now 

underway along the Gulf Coast create the potential for release of asbestos

and other hazardous pollutants. EPA has noted that the number of houses 

requiring demolition, the sheer volume of debris, and limited landfill space 

available to accept contaminated debris raise a number of environmental 

concerns. In addition to EPA’s continued role in assisting the Corps and 

local agencies with the removal of hazardous household waste and 

appliances, EPA also has a role in ensuring that debris containing asbestos

and other pollutants is removed and disposed of appropriately. At the 

request of the Louisiana and Mississippi Departments of Environmental 

Quality, EPA has provided some flexibility regarding regulated asbestos 

materials from homes to facilitate demolition activities in the state of 

Louisiana and in six counties in Mississippi. This flexibility still requires 

Page 85 GAO-06-618 Catastrophic Disasters
appropriate practices to ensure protection of public health and the 

environment. Efforts to reduce the volume of debris by grinding and 

burning certain types of debris also present environmental challenges, as 

these activities have the potential to release hazardous air pollutants. EPA 

continues to work with Louisiana to determine if these practices are 

appropriate. Continued monitoring will be necessary to minimize the 

environmental risks associated with demolition and debris removal 

activities. We are evaluating environmental challenges facing the Gulf 

Coast, including EPA’s oversight of federal asbestos requirements, in an 

ongoing review of the agency’s role in hurricane response. 

We also examined and monitored the Corps plans to repair 169 miles of 

levees and floodwalls damaged by Hurricane Katrina to pre-storm 

conditions. Completion of these repairs was planned for June 1, 2006, the 

start of the 2006 hurricane season. On June 1, 2006, the Corps announced 

that 100 percent of pre-hurricane levels of protection had been restored 

although some construction contracts were not yet completed. In 

instances where the Corps could not complete permanent repairs by June 

1, 2006, it made interim repairs and developed emergency procedures to 

protect against flooding in the event of a hurricane. 

Rebuilding and Strengthening 

the Levees Involves the U.S. 

Army Corps of Engineers 

After completing these repairs, the Corps planned to (1) repair all pumps, 

motors and pumping stations by about March 2007; (2) restore sections of 

existing hurricane protection projects that have settled over time to their 

original design elevations; and (3) complete construction of incomplete 

portions of five previously authorized hurricane and flood control projects 

by September 2007. The Corps also planned to undertake further work to 

restore, construct, and enhance hurricane protection for southeastern 

Louisiana by 2010. For example, in April 2006, FEMA released advisory 

flood elevations for New Orleans and the surrounding area based on a one 

percent annual chance of flooding, also called a 100-year flood. In 

response, the Corps is revising its plans and cost estimates to raise the 

height of levees and floodwalls to provide the area with a 100-year level of 

protection. 

Since September 2005, the Congress has appropriated more than $7 billion 

to the Corps for portions of this work and additional appropriations are 

expected. Our ongoing work indicates, however, that the Corps does not 

have a comprehensive strategy and implementation plan to integrate and 

manage this work and is currently revising its cost estimates for most 

system enhancements. Instead, the Corps appears to be following a 

piecemeal approach, similar to its past practice of building projects 

Page 86 GAO-06-618 Catastrophic Disasters
without giving sufficient attention to the interrelationships between 

projects or fully considering whether they will provide an integrated level 

of hurricane protection for the region. We plan to continue our 

examination of the Corps’ plans and efforts, and to issue a report on this 

work later this year. 

State and local education officials faced challenges in restarting schools 

and educating displaced students. Hundreds of thousands of students, 

from kindergarten to the 12th grade, were displaced by the hurricanes. In 

addition, Louisiana officials said that 29 schools were destroyed and about 

half of the state’s schools were damaged, and Mississippi officials said that 

16 schools were destroyed and over half of the state’s districts reported 

some damage. Districts in areas directly affected by the storms and those 

that enrolled displaced students faced financial challenges. For example, 

local property tax revenue—a key funding source for schools—may be 

undercut in areas with property damage, and state funding for schools 

may also be undercut from the effects of the storms. The large number of 

displaced students in some districts led to a strain on classroom space, 

books, teachers, school buses and drivers, and counseling services. 

Congress initially appropriated a total of approximately $1.4 billion under 

the Restart and Emergency Impact Aid programs to help reopen 

elementary and secondary schools and serve displaced students;73

Congress subsequently appropriated an additional $235 million under the 

Emergency Impact Aid program for serving displaced students.74 Federal 

assistance for displaced students must be obligated by September 30, 2006, 

and must be used only for expenses incurred during the 2005-2006 school 

year; yet, state officials reported that a large number of displaced students

are likely to remain in their new districts for longer than a year. 

Despite Federal Assistance, 

States and School Districts 

Face Continuing Challenges 

Regarding Funding and 

Displaced Students 

In addition, state and district officials expressed the need for flexibility in 

meeting the requirements of the No Child Left Behind Act of 2001. Upon 

request of the affected states, the U.S. Department of Education quickly 

granted some flexibility regarding certain No Child Left Behind Act 

requirements. State officials were also concerned about the effect of 

displaced students on their No Child Left Behind Act academic 

accountability results. As of June 1, 2006, Education had granted several 

states flexibility with regard to how schools are accountable for the 

 73 Pub. L. No. 109-148.

74 Pub. L. No. 109-234.

Page 87 GAO-06-618 Catastrophic Disasters
academic achievement of displaced students for the 2005-2006 school year. 

Although some states received flexibility in how schools are accountable 

for academic achievement, schools were still responsible for ensuring that 

displaced students participated in 2005-2006 academic assessments. State 

and local school officials could promote continuity of operations after 

large-scale emergencies by developing plans that include locating 

displaced employees and working closely with other local officials to 

focus resources on reopening schools. The reopening of schools is vital for 

community recovery. Also, federal regulatory flexibility in reporting and 

other requirements can allow states and districts to focus on rebuilding. 

Our ongoing work on the recovery of the Gulf Coast has identified several 

issues regarding temporary housing that will require federal attention. 

These issues generally relate to the question of how long the federal 

government should provide disaster housing assistance to victims of 

Hurricanes Katrina and Rita under FEMA and HUD administered 

programs. Typically, FEMA’s IHP provides temporary housing.75 IHP 

requires an assessment of eligibility before it can provide housing 

assistance.76 According to FEMA officials, in order to house the large 

number of displaced residents quickly, FEMA used its authority under 

Section 403 of the Stafford Act to allow states to provide temporary 

housing for evacuees of Hurricane Katrina. Section 403 of the Stafford Act 

authorizes the agency to provide assistance essential to meeting 

immediate threats to life and property resulting from a major disaster, 

including emergency shelter. By using this authority, FEMA allowed states 

to house evacuees without assessing eligibility. According to FEMA, 

approximately 60,000 households received temporary housing under this 

authority. In early 2006, FEMA began determining the eligibility of those it 

is assisting under Section 403 to transition to IHP. In March 2006, FEMA 

announced that it would no longer provide temporary housing benefits 

Duration of Housing Assistance 

for Victims of Hurricanes 

Katrina and Rita Will Require 

Federal Attention 

 75 Section 408 of the Stafford Act. 

76 Eligibility requirements for receiving assistance under IHP include demonstrating that an 

applicant’s pre-disaster residence is located in the declared disaster area; that damage to 

the property was not covered by insurance; and that the applicant is unable to return to

their pre-disaster home due to damage caused by the disaster. 

Page 88 GAO-06-618 Catastrophic Disasters
under Section 403 as of May 31, 2006.77 Households deemed ineligible 

because they do not meet the IHP eligibility criteria will no longer receive 

housing assistance from FEMA, potentially leaving thousands of people 

without housing if they are unable to obtain other housing assistance. For 

example, FEMA officials estimate that approximately 20 percent of the 

45,000 households in Texas receiving assistance under Section 403 

authority will be ineligible for assistance under IHP. 

Victims who receive assistance under FEMA’s IHP are eligible to receive 

temporary housing assistance generally up to 18 monthsafter the date of 

the disaster declaration. FEMA reported that as of April 2006, it had 

approved temporary housing assistance for more than 825,000 households 

displaced by Hurricanes Katrina and Rita. Although some FEMA officials 

told us that many victims of Hurricanes Katrina and Rita will require 

housing assistance beyond this limit, it is unclear who will provide it. 

According to a FEMA official assigned to Louisiana, state and local 

governments are not currently capable of providing housing assistance 

after the FEMA assistance ends. FEMA may extend this assistance beyond 

the 18 month period if it determines that due to extraordinary 

circumstances an extension would be in the public interest. 

For victims of Hurricane Katrina who resided in public or other HUDassisted housing units damaged or destroyed by the storm, HUD initially 

provided assistance through its Katrina Disaster Housing Assistance 

Program. According to HUD, it assisted approximately 15,000 families 

through this program. In December 2005, Congress appropriated 

$390 million for temporary rental voucher assistance for victims of 

Hurricanes Katrina and Rita. 78 Subsequently, HUD established a new 

program—the Disaster Voucher Program—and in February 2006 began

transitioning those from the previous program to the new program. Under 

the Disaster Voucher Program, households received a housing voucher 

 77 FEMA announced certain exceptions to the May 31 deadline. In particular, FEMA stated 

that it planned to make every effort to notify states of the IHP eligibility status of evacuees 

before April 15. If this notification occurred after April 15, states could request additional 

time to provide eligible and ineligible evacuees with a 30-day lease termination notice. 

Specifically, states could receive up to 15 additional days for eligible evacuees, and up to 30

additional days for ineligible evacuees. Also, for ineligible evacuees, the state would be 

reimbursed for contractual lease termination costs associated with leases that require

greater than 30 days notice. FEMA subsequently extended the May 31 deadline to June 30

for 11 jurisdictions. FEMA further extended the deadline for one of these jurisdictions—

Houston, Texas—until September 30th

. 

78 The Department of Defense Appropriations Act, 2006 (P.L. 109-148). 

Page 89 GAO-06-618 Catastrophic Disasters
that covers 100 percent of the rent for up to 18 months. According to HUD 

guidance, a family is eligible to reoccupy its previously-occupied public or 

assisted housing unit if and when it becomes available. However, HUD has 

not yet issued guidance on what housing assistance will be available to 

displaced residents whose units are not going to be available by the time 

the assistance ends or those with permanently damaged units79. Moreover, 

as a result of the hurricanes, the housing shortage is even more acute in

the affected areas, including public and assisted housing. For example, 

some residents resided in public housing units that the storms damaged or

destroyed. HUD plans to demolish some of its severely damaged public 

housing stock in New Orleans and other areas affected by the hurricanes. 

In response to the hurricanes, HUD’s Federal Housing Administration also 

issued a 90-day moratorium on foreclosures for all FHA-insured loans on 

properties located in areas affected by Hurricanes Katrina and Rita. HUD 

subsequently extended the moratorium on foreclosures twice for areas 

eligible for FEMA’s Individual Assistance, because it found that due to 

magnitude of the storm damage, lenders and borrowers may still need 

additional time to develop and finalize plans for home repair and 

resumption of mortgage payments. According to HUD, the last moratorium

on foreclosures was extended to August 31, 2006. In addition to the 

moratoriums, HUD issued guidance instructing lenders servicing FHAinsured mortgage loans not to report hurricane related delinquencies to 

credit bureaus, not to charge late fees, and to expand their efforts to 

contact displaced borrowers. Furthermore, HUD offered special mortgage

assistance to borrowers in eligible areas who could not maintain mortgage 

payments due to hurricane related property damage, curtailment of 

income or increased living expenses. Under this initiative, HUD may make 

payments to lenders on behalf of borrowers for up to 12 months worth of

mortgage payments (principal, interest, taxes, and insurance). This special 

mortgage assistance is available to eligible borrowers through May 31, 

2007. Borrowers are not required to repay HUD until the FHA-insured first 

mortgage is paid in full. It is unclear, however, what additional assistance

lenders and servicers of FHA-insured single-family mortgages may provide

and what impact this may have on borrowers and FHA as the guarantor of 

these mortgages. 

 79 Under the Disaster Voucher Program, funding must be obligated by September 30, 2007.

Unless expressly renewed or extended by law, assistance may not continue beyond the

time the obligated funds are expended. 

Page 90 GAO-06-618 Catastrophic Disasters
We plan to continue our examination of the federal role in providing 

housing assistance in response to Hurricanes Katrina and Rita, and to

issue a report on this work by the end of this year. 

Although homeowner insurance policies typically cover damage and 

losses from fire or theft and often from wind-driven rain, they do not cover 

flood damage because private insurance companies are largely unwilling 

to bear the economic risks associated with the potentially catastrophic 

impact of flooding, including damage from storm surges. To provide some 

insurance protection for flood victims, as well as incentives for 

communities to adopt and enforce floodplain management regulations to 

reduce future flood damage, Congress established the National Flood 

Insurance Program (NFIP) in 1968.

80 Homeowners with mortgages from 

federally regulated lenders on property in communities identified to be in

special high-risk flood hazard areas are required to purchase flood 

insurance on their dwellings for, at minimum, the amount of the 

outstanding mortgage. Optional, lower-cost coverage is also available 

under the NFIP to protect homes in areas of low to moderate risk. The 

NFIP provides insurance protection of up to $250,000 for homes and up to 

$100,000 for personal property.81 As of December 2005, the NFIP had about 

4.8 million policies in force. About 3 million (62 percent) of the policies 

were for properties in the five states impacted by Hurricanes Katrina and 

Rita—Alabama, Florida, Louisiana, Mississippi, and Texas. 

Questions Raised about 

FEMA’s National Flood 

Insurance Program Structure 

and Long-Term Solvency 

The NFIP was created in part to reduce taxpayer funded payments to 

owners of flood-damaged properties by having payments for such damage 

paid through flood insurance policyholder premiums. The claims from

Hurricanes Katrina and Rita required unprecedented borrowing from the 

Treasury of $18.5 billion at the time of our January 2006 testimony, raising 

anew questions about its structure and long-term solvency.82 The 

program’s financial resources are insufficient to meet future expected 

losses, in part because policy subsidies and repetitive loss properties have

contributed to continuing losses to the program. Specifically, the program 

 80The National Flood Insurance Act of 1968. The act, as amended, is codified at 42 U.S.C. §§ 

4001 to 4129. 

81NFIP coverage is also available for other structures such as apartment buildings, schools, 

churches, businesses and condominium associations, but the coverage terms differ in 

various respects from homeowners’ coverage. 

82 GAO, Federal Emergency Management Agency: Challenges for the National Flood

Insurance Program, GAO-06-335T (Washington, D.C.: Jan. 25, 2006). 

Page 91 GAO-06-618 Catastrophic Disasters
is not actuarially sound because a high proportion of insurance properties 

are subsidized—about 26 percent at the time of FEMA’s 2004 review. 

Policy holders for these properties, built before flood plain regulations 

were established in their communities, pay premiums that represent about

35 to 40 percent of the true risk premium. In January 2006, FEMA 

estimated the program had a shortfall of $750 million in annual premium 

income because of policy subsidies. 

The portion of subsidized polices that most adversely impact the 

program’s financial solvency are about 49,000 repetitive loss properties (as 

of March 2004) for which two or more claims of $1,000 or more have been

paid in a 10-year period. Although these properties make up only about 

1 percent of the properties insured under the NFIP, they account for 25 to

30 percent of all claims losses. As of March 2004, nearly half of all 

nationwide repetitive loss property insurance payments had been made in 

Louisiana, Texas, and Florida. These properties accounted for about 

$4.6 billion in claims payments from 1978 to March 2004. A significant 

number of repetitive loss properties were affected by Hurricanes Katrina 

and Rita, and a FEMA management official predicted that the inventory of 

repetitive loss properties would increase as a result of damage from the 

two storms. 

As part of its flood plain management strategy, NFIP policies encourage 

states and local communities to elevate or remove damaged properties 

from the flood plain. In addition to paying claims for flood damage, NFIP 

policies pay up to $30,000 for the cost of complying with mitigation actions 

required under state or local floodplain management laws or ordinances, 

such as elevating, moving, or demolishing the damaged structures. This 

increased cost of compliance (ICC) coverage is available under the NFIP’s

standard flood insurance policy for properties that suffer substantial 

damage, including repetitive loss properties.83 In an upcoming revision to 

the standard flood insurance policy, FEMA plans to make permanent the 

increase in time to complete work and receive an ICC payment. It is too 

early in the recovery process to determine the impact of the mitigation 

actions on the national inventory of repetitive loss properties. 

For all these reasons, and others described in our March 2006 testimony, 

we have placed the NFIP on our list of high-risk government programs. In 

 83The NFIP standard flood insurance policy considers a property substantially damaged if 

the cost of repairing it exceeds 50 percent of its market value at the time of the flood. 

Page 92 GAO-06-618 Catastrophic Disasters
2004 we made recommendations to FEMA on strategies to better ensure 

that FEMA’s map modernization achieves the intended benefits of 

improved flood mitigation, increased flood insurance participation, and

improved multi-hazard mitigation and risk management capabilities.84 DHS 

and FEMA generally agreed with our recommendations. FEMA said that it

planned to refine existing standards, in coordination with stakeholders, to

ensure consistent data collection and analysis for all communities 

commensurate with their flood risk; that it would continue to collaborate 

with stakeholder groups to develop an effective strategy to include states 

and communities with varying levels of capabilities and resources; and 

that it planned to refine performance measures for this map modernization 

objective to make them more useful and quantifiable. In 2005, we 

recommended that FEMA use a statistically valid method to select claims 

for quality review because its existing sampling and internal controls did 

not provide management with the information needed to have reasonable

assurance that program objectives are being achieved. We also 

recommended that FEMA set target dates for implementing the provisions

of the Flood Insurance Reform Act of 2004.85 FEMA said its existing 

sampling method was sufficient for the purposes for which it was used and 

that it was working diligently to implement the requirements of the 2004 

reform act.86 

 84GAO, Flood Map Modernization: Program Strategy Shows Promise, but Challenges

Remain, GAO-04-417 (Washington, D.C.: Mar. 31, 2004). 

85GAO, Federal Emergency Management Agency: Improvements Needed to Enhance 

Oversight and Management of the National Flood Insurance Program, GAO-06-119

(Washington, D.C.: Oct. 18, 2005). 

86In response to the Flood Insurance Reform Act of 2004, FEMA recently published an

interim final rule establishing a regulatory appeals process for flood insurance claimants.

National Flood Insurance Program; Appeal of Decisions Relating to Flood Insurance 

Claims, 71 Fed. Reg. 30294 (2006). 

Page 93 GAO-06-618 Catastrophic Disasters
Recent GAO recommendations to DHS 

to enhance oversight and management

of NFIP DHS responses

Flood Map Modernization 2004 

FEMA should ensure that its map 

modernization achieves the intended 

benefits of improved flood mitigation, 

increased flood insurance participation, and 

improved multi-hazard mitigation and risk 

management capabilities. 

FEMA said that it planned to refine existing 

standards, in coordination with

stakeholders, to ensure consistent data 

collection and analysis for all communities 

commensurate with their flood risk; that it 

would continue to collaborate with 

stakeholder groups to develop an effective 

strategy to include states and communities 

with varying levels of capabilities and 

resources; and that it planned to refine 

performance measures for this map 

modernization objective to make them 

more useful and quantifiable. 

National Flood Insurance Program 2005 

FEMA should use a statistically valid 

method to select claims for quality review

because existing sampling and internal 

controls did not provide management with 

the information needed to have reasonable 

assurance that program objectives are 

being achieved.

FEMA said its existing sampling method

was sufficient for the purposes for which it 

was used. 

FEMA should set target dates for 

implementing the provisions of the Flood 

Insurance Reform Act of 2004. 

FEMA responded that it was working

diligently to implement the requirements of 

the 2004 reform. 

For more detailed information about our recommendations, see appendix I.

A Framework to Enhance 

Federal Financial 

Assistance’s Performance 

in the Restoration of the 

Gulf Coast 

Finally, in our March 8 testimony, we identified an accountability and 

performance framework from relevant GAO past work that may be 

considered regarding the provision of federal financial assistance for the 

restoration of the Gulf Coast:87

• Identify the scope of the problem. For example, does the problem 

reflect broader industry wide or regional economic conditions? For 

the Gulf Coast, this would involve financial and economic analyses, 

perhaps utilizing current studies of prior conditions and the 

ongoing progress of recovery and rebuilding. 

 87GAO, Guidelines for Rescuing Large Failing Firms and Municipalities, 

GAO/GGD-84-34 (Washington, D.C.: Mar. 29, 1984). 

Page 94 GAO-06-618 Catastrophic Disasters
• Clearly establish the effect of the problem on the national

interest—such as whether federal involvement is needed because 

the problem presents potentially large economy wide or regional 

consequences. For example, in the Gulf Coast, Congress should 

consider whether the proposed rebuilding plans are reasonable and 

the involvement of state and local governments and the private 

sector will not, on their own, provide necessary capital. 

• Establish clear, concise, and consistent legislative goals and 

objectives associated with the response. For example, in the Gulf 

Coast, building on the President’s decision to appoint a Coordinator 

of Federal Support for the Recovery and Rebuilding of the Gulf 

Coast region, Congress should ensure that the goals of all aspects 

of federal involvement are clear, measurable, and agreed-upon by 

all participants. 

• Protect the government’s financial interest. In the Gulf Coast, for 

example, controls might be put in place so there is review of the 

most important financial and operating plans that rely on federal 

investments. 

In terms of protecting the government’s financial interest, our ongoing 

work in this area found that there is no one agency or central collection

point that exists to compile and report on how the emergency 

supplemental appropriations funds provided to 23 different federal 

agencies are being spent. Without a framework and mechanisms in place 

to collect and consolidate information from these agencies on a periodic 

basis, it will be difficult for decision makers to determine how much 

federal funding has been spent and by whom, whether more may be 

needed, or whether too much has been provided. The ability to separately 

track and report on these funds is important to help ensure better 

accountability and clearly identify the status of funding provided in direct

response to these hurricanes at both the individual federal agency level as 

well as the government wide level. Also, it is important to provide 

transparency so that hurricane victims, affected states, as well as 

American taxpayers, know how these funds are being spent. We will issue 

a report later this year that addresses the federal government’s ability to 

track and report on the hurricane relief funds received. 

Page 95 GAO-06-618 Catastrophic Disasters
Since September 11, 2001, the federal government has awarded billions of 

dollars in grants and assistance to state and local governments to assist in 

strengthening emergency management capabilities. DHS has developed 

several key policy documents, including the NRP, NIMS, and the interim 

National Preparedness Goal to guide federal, state, and local efforts. The 

aftermath of the 2005 hurricane season resulted in a reassessment of the 

federal role in preparing for and responding to catastrophic events. The 

studies and reports of the past year—by Congress, the White House 

Homeland Security Council, the DHS-IG, DHS and FEMA, GAO, and 

others—have provided a number of insights into the strengths and 

limitations of the nation’s capacity to respond to catastrophic disasters 

and resulted in a number of recommendations for strengthening that 

capacity. Collectively, these studies and reports paint a complex mosaic of 

the challenges that the nation—federal, state, local, and tribal

governments, nongovernmental entities, the private sector, and individual 

citizens—faces in preparing for, responding to, and recovering from 

catastrophic disasters. In addition to the reports issued to date, there are 

numerous ongoing analyses of various facets of the nation’s preparedness 

and response efforts before and after Hurricane Katrina. 

Conclusions 

Improving the nation’s ability to prepare, respond, and recover from 

catastrophic disasters will take three critical inputs: (1) leaders and 

professionals with the right knowledge, skills, and experience; (2) plans 

and guidance that detail what needs to be done, by whom, how, and how 

well; and finally (3) clear criteria and expectations that are clearly 

communicated, well understood, and result in appropriate, coordinated 

actions from all levels of government, their emergency planners and 

responders, and the nonprofit and private-sector organizations that will be 

providing support. This requires the development of thoughtful strategic 

planning and assessment, along with developing and sustaining needed 

skills and assets. Effective training and exercises based on realistic 

scenarios is a key component of building and maintaining needed skills 

and capabilities. As we noted in past GAO work, overall federal assistance

has not been guided by a clear, risk-based strategic plan that would 

provide a basis for realistic budgeting and resource planning.88 Ultimately, 

the federal government must determine how much it will cost to develop 

and maintain these needed capabilities and what the federal government 

can afford to pay. Other levels of government face a similar challenge. 

 88 GAO, Homeland Security: DHS’ Effort to Enhance First Responders’ All-Hazards 

Capabilities Continue to Evolve, GAO-04-652 (Washington, D.C.: July 11, 2005). 

Page 96 GAO-06-618 Catastrophic Disasters
DHS and its partners and stakeholders—governmental and

nongovernmental, public and private—face the challenge of working 

together to coordinate preparedness activities and formulate realistic 

budgets and resource plans to share these costs and support and sustain 

implementation of an efficient and effective all-hazards national 

preparedness program. 

Catastrophic disasters are unique in their scope and the magnitude of their 

effects. In preparing for any disaster, but particularly catastrophic 

disasters, it is essential to have in place through contracts, prepositioning 

of key supplies, and other means the needed surge capacity to respond 

quickly and effectively to the destruction and dislocation that results from 

the catastrophe. In moving forward, one critical challenge will be 

determining if the initial and long-term efforts to implement specific 

initiatives will truly close the identified gaps in the nation’s capacity to 

prepare for, respond to, and recover from catastrophic disasters. Sound 

recommendations and initiatives must be effectively implemented to 

achieve the intended improvements. Currently, there is little available 

information on the operational readiness of many of the reforms and 

actions DHS has announced in recent months. The first real test of these 

actions will come with the next major hurricane or other major disaster. 

DHS has conducted some exercises in recent weeks, but there is little 

available information on the results of those exercises. In addition, some 

of the reforms, such as revisions to the NRP, may have clarified some 

issues, such as the role of the Secretary of Homeland Security in declaring

incidents of national significance, while potentially raising new issues, 

such as how the NRP, which DHS now states is in effect at all times, would 

be operationalized in incidents of lesser severity. While the scope of the 

NRP has broadened, DHS and other federal agencies may be without a 

road map for dealing with incidents of lesser severity until they 

supplement the NRP with detailed, scalable operational plans. Likewise, 

DHS and other federal agencies may be without a road map in responding 

to catastrophic incidents until they supplement the NRP’s catastrophic 

incident annex with the detailed operational plans envisioned by the NRP.

To be effective, the NRP must be supported by robust operational plans 

for implementing its provisions. 

Page 97 GAO-06-618 Catastrophic Disasters
Appropriate controls and accountability mechanisms for the use of 

resources during a catastrophic disaster are essential to ensure that the 

resources are used appropriately, but there is always a tension between 

normal controls and accountability mechanisms and the need to deliver 

assistance expeditiously, especially when responders and governments are 

providing life-saving and life-sustaining services in a time-critical 

environment. DHS and state and local governments all face a significant 

challenge in ensuring that relief payments and services are only sent to 

valid registrants while also distributing those relief payments and services

as fast as possible. Thus, all levels of governments must further develop

and strengthen controls to ensure accountability, because—as FEMA has 

learned from prior experience—pursuing collection activities after 

disaster relief payments have been made is costly, time-consuming, and 

ineffective. Upfront controls are all the more crucial given the estimated 

billions of dollars in erroneous or excessive payments related to 

Hurricanes Katrina and Rita. 

Finally, given the magnitude of Hurricane Katrina’s devastation of the 

physical and economic infrastructure in the Gulf Coast—both public and

private sector—rebuilding is likely to take years, if not decades, to 

complete. As a result, all levels of government will have a critical role in 

the effort, not just the federal government and not solely or even primarily 

through FEMA’s post-disaster recovery and mitigation funding. Some 

communities were so totally devastated that they almost face rebuilding 

their communities from the ground up. These long-term recovery and 

rebuilding efforts offer an opportunity to mitigate the potential impact of 

future hurricanes, and employ both direct governmental funding and 

forms of fiscal and monetary support from the banking and insurance 

industries. In light of how long this effort may take, GAO will continue to 

examine current recovery issues and long-term rebuilding activities. 

In this report we are making several new recommendations updating and 

formalizing several recommendations first posed in our March 8, 2006,

testimony on preliminary observations regarding preparedness, response, 

and recovery; and one new recommendation on advance procurement 

practices and procedures: 

Recommendations 

Page 98 GAO-06-618 Catastrophic Disasters
• Rigorously re-test, train, and exercise its recent clarification of the 

roles, responsibilities, and lines of authority for all levels of leadership, 

implementing changes needed to remedy identified coordination 

problems. 

Recommendations for 

Executive Action 

• Direct that the NRP base plan and its Catastrophic Incident Annex be 

supported by more robust and detailed operational implementation 

plans, particularly the Catastrophic Incident Supplement to the NRP. 

Such operational plans should, for example, further define and leverage 

those military capabilities that might be needed in a catastrophic 

disaster. 

• Provide guidance and direction for federal, state, and local planning, 

training, and exercises to ensure such activities fully support 

preparedness, response, and recovery responsibilities at a 

jurisdictional and regional basis. This should also include the 

application of lessons learned from actual catastrophic and other 

disasters. 

• Take the lead in monitoring federal agencies’ efforts to meet their 

responsibilities under the NRP and the interim National Preparedness 

Goal, including the development, testing, and exercising of agency 

operational plans to implement their responsibilities under the NRP, 

NIMS, and the interim National Preparedness Goal. 

• Given that resources are finite, apply an all-hazards, risk management 

approach in deciding whether and how to invest in specific capabilities 

for a catastrophic disaster.

• Provide guidance on advance procurement practices and procedures 

for those federal agencies with roles and responsibilities under the 

NRP, so that these agencies can better manage disaster-related

procurements, such as food, shelter, and debris removal. These 

practices should be in advance of disasters, ongoing and continuous, 

and include (1) developing knowledge of contractor capabilities and 

available commodities, services and prices as well as developing preestablished vendor relationships, on a competitive basis whenever 

feasible; (2) establishing scalable operations plans to adjust the level of 

capacity needed to respond; (3) formally assigning and communicating 

disaster-related responsibilities and, where feasible, incorporating 

necessary training; and (4) providing sufficient numbers of field-level 

contracting staff to meet mission requirements. DHS should also 

establish an assessment process to monitor agencies’ continuous 

Page 99 GAO-06-618 Catastrophic Disasters
planning efforts for their disaster-related procurement needs and the 

maintenance of capabilities.

Matters for Congressional 

Consideration 

Reaffirming a recommendation we made following Hurricane Andrew, we 

recommend that Congress: 

• Give federal agencies explicit authority to take actions to prepare for 

catastrophic disasters when there is warning. 

We also offer some analytical frameworks and factors that Congress may 

wish to consider in carrying out its oversight and legislative 

responsibilities with regard to national preparedness and the recovery of 

the Gulf Coast region: 

• Use a risk management framework to assist in its oversight and 

legislative decision-making regarding the nation’s capacity to respond 

to catastrophic disasters. 

• If Congress is considering a change in FEMA’s organizational 

placement, it should consider (1) whether factors such as the 

qualifications, experience, and training of the leadership and the 

adequacy of resources led to its performance difficulties; (2) criteria 

such as mission relevancy, similar goals, and objectives (present and 

future); (3) leveraging the effectiveness of other agencies and programs 

or the new department as a whole; and (4) gains in efficiency and 

effectiveness through eliminating duplications and overlaps.

• If Congress is considering a change in the qualifications of the 

Undersecretary for Federal Emergency Management, it should 

consider establishing statutory professional qualifications for the 

Undersecretary and other selected key positions within DHS and term 

appointments for the Undersecretary and selected other positions. 

• Consider the four conditions that we suggested in 1984, as a framework 

of ideas about how to structure future financial assistance programs 

and what program requirements to include to achieve Congressional 

goals and objectives while minimizing the risk of financial loss to the 

government. These guidelines are a useful framework for developing 

assistance programs for the Gulf Coast restoration: 

• The scope of the problem should be identified, such as if the 

problem reflects broader industry wide or regional economic 

conditions. For the Gulf Coast, this would involve financial and 

Page 100 GAO-06-618 Catastrophic Disasters
economic analyses, perhaps utilizing current studies of prior 

conditions and the ongoing progress of recovery and rebuilding. 

• The effect of the problem on the national interest should be clearly 

established, for example, whether the problem presents potentially 

large economy wide or regional consequences. For example, in the 

Gulf Coast, Congress should consider the costs of municipal and 

corporate collapse and the challenges associated with providing 

assistance. 

• The legislative goals and objectives associated with the response 

should be clear, concise, and consistent. For example, in the Gulf 

Coast, goals and objectives for rebuilding should be clearly stated, 

working with the state and local groups already tasked with 

recovery planning and with the Administration’s Coordinator of 

Federal Support for the Recovery and Rebuilding of the Gulf Coast 

region. 

• Lastly, the government’s financial interest should be protected. In 

the Gulf Coast, controls might be put in place so that the most 

important financial and operating plans will be reviewed. 

This report also identifies the major findings, conclusions, and 

74 recommendations and matters for congressional consideration from 

our prior and ongoing work on catastrophic disasters. Appendix I 

summarizes 24 key GAO recommendations identified in work prior to 

Hurricane Katrina. These 24 prior recommendations were not adopted or

in effect when Hurricane Katrina hit the Gulf Coast and remain listed by 

GAO as open recommendations, that is, recommendations not fully 

implemented. We continue to believe that, for the most part, these 

recommendations are still viable. In addition, appendix I lists 43 GAO 

recommendations from GAO reports in the aftermath of Hurricanes 

Katrina and Rita, and 7 new recommendations formalized in this report. 

We provided a draft of this report to DHS for review and comment, and 

also provided relevant sections of the draft report to various federal 

departments and agencies including the departments of Agriculture, 

Education, HHS, HUD, Labor, and State, as well as SBA, EPA and Social 

Security Administration. The Departments of State and HHS said they had 

no comments on our draft. The Department of Agriculture’s Food and 

Nutrition Service, the Department of Education, EPA, HUD, and the Social 

Security Administration provided additional technical comments that we 

Agency Comments 

Page 101 GAO-06-618 Catastrophic Disasters
incorporated, and the Social Security Administration also stated that they

were pleased to be included in the report as an example of good planning. 

DHS provided written comments on August 28, 2006, signed by the 

Undersecretary for Federal Emergency Management and the 

Undersecretary for Preparedness. DHS’s comments are reproduced in full 

in appendix II. DHS also provided technical comments that we 

incorporated as appropriate. DHS generally concurred with the six new 

recommendations in our draft report and described an array of actions it 

has taken, has underway, or planned to implement those 

recommendations. DHS also described actions it has taken to address the 

expansion of search and rescue capabilities; the supply pre-positioning 

and tracking of emergency supplies, such as food, ice, and water; FEMA 

staffing; and the acceptance and management of international donations 

for disaster response and relief. 

If effectively implemented, the actions that DHS described should 

basically address the problems that we described in the draft report. 

However, as we noted in our report, the NRP revisions may not fully 

resolve the leadership issues with respect to the PFO and FCO roles and 

questions remain with regard to how the NRP, which now states it is in 

effect at all times would be operationalized in incidents of severity less 

than the incidents of national significance that are to be managed by the 

Secretary of Homeland Security. Because we did not have time to evaluate

DHS' actions completed to date, we cannot reach any conclusions 

regarding the extent to which those actions are fully operational and have

improved disaster preparedness and response capabilities. 

In commenting on our recommendations, DHS stated that planning for 

patient evacuation out of hospitals and nursing homes is being 

coordinated by HHS, as Coordinating Agency for the NRP’s Emergency 

Support Function 8. We understand that responding to our recent 

recommendation of planning for patient evacuation out of hospitals and 

nursing homes will involve coordination among various agencies, 

including HHS, and addressed our recommendations to DHS because it is

responsible for the NRP, the Catastrophic Incident Annex and its 

Supplement, and the activation of NDMS.89 

 89 GAO, Limitations in Federal Evacuation Assistance for Health Facilities Should be 

Addressed, GAO-06-826 (Washington, D.C.: July 20, 2006). 

Page 102 GAO-06-618 Catastrophic Disasters
On August 14, 2006, we received written comments from the Department 

of Labor who stated that our report correctly points out that OSHA and 

FEMA had experienced difficulties in agreeing on roles and procedures. 

OSHA has reported that their agency and FEMA have worked together to 

develop procedures for role of the Safety and Health Coordinator in the 

Joint Field Office and for the NRP’s Worker Safety and Health Support 

Annex. 

SBA’s Associate Administrator for Disaster Assistance provided written 

comments on August 14, 2006, on a draft of the SBA segment of this 

report. SBA’s comments basically reiterate the comments it made on our 

earlier report 90 and are reproduced in full in appendix III. SBA stated that 

more emphasis should have been given to its improvement efforts and the 

benefits of DCMS compared with its previous system and stated its 

concerns regarding the use of catastrophe risk model data in determining 

the user requirements of DCMS. It was not within the scope of our work to 

conduct a comparative analysis of DCMS and SBA's previous system, but 

we recognized some of the benefits the agency realized by adopting DCMS. 

We continue to believe that catastrophe risk modeling firms provide 

critical information, such as the likelihood and severity of damages from 

potential catastrophes. Combined with other elements of a comprehensive 

planning process, such information would have been useful in planning the 

maximum user capacity of DCMS. If SBA had considered this information, 

it may have expanded the maximum user requirement for DCMS and been

better prepared to reduce the backlog of loan applications. 

We are sending copies of this report to the appropriate congressional 

committees; the Secretary of Homeland Security; the Director, Office of 

Management and Budget; and other interested parties. In addition, this 

report will be available at no charge on the GAO Web site at 

http://www.gao.gov. 

GAO Contacts 

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this report. For further 

information about this report, please contact William Jenkins, Jr, Director, 

GAO Homeland Security and Justice Issues Team, at (202)-512-8757 or at 

 90 GAO, Small Business Administration: Actions Needed to Provide More Timely

Assistance, GAO-06-860 (Washington, D.C.: July 28, 2006) 

Page 103 GAO-06-618 Catastrophic Disasters
jenkinswo@gao.gov. GAO staff who were major contributors to this report 

are listed in appendix IV.

Sincerely yours, 

David M. Walker 

Comptroller General 

of the United States 

Page 104 GAO-06-618 Catastrophic Disasters
Appendix I: Summary of Key Open GAO 

Recommendations on Catastrophic Disasters

The following three tables show GAO’s recommendations on dealing with 

catastrophic disasters made before Hurricane Katrina, in the aftermath of 

Katrina, and new recommendations formalized in this report. The tables 

also show the agency response to each recommendation. 

Recommendations are given in chronological order in each table, with the 

most recent recommendations listed first. 

Table 4: Key Open Recommendations Made Prior to Hurricanes Katrina and Ritaa

Title and GAO product 

number Summary of recommendations Agency response 

Reserve Forces: Actions 

Needed to Better Prepare 

the National Guard for 

Future Overseas and 

Domestic Missions, 

GAO-05-21

Recommendations to the Secretary of Defense: 

To improve the Army and the Air National Guard’s 

preparedness to perform homeland security missions, the 

Secretary of Defense should:

• Assess how support for current operations will affect the 

readiness of non-deployed Army National Guard forces 

for future overseas and domestic missions. 

• Specify how the Army plans to restructure and provide 

the Guard resources—personnel, equipment, and 

training—consistent with its 21st century role. 

• Establish the full range of the National Guard’s homeland 

missions, including those led by DOD and those 

conducted in support of civilian authorities. 

• Identify the National Guard’s capabilities to perform these 

missions and any shortfalls in personnel, equipment, and 

training needed to perform these missions successfully. 

• Develop a plan to manage the risk associated with the 

declining readiness of non-deployed Army National 

Guard forces, including identifying funding for any 

personnel and equipment required to mitigate 

unacceptable levels of risk. 

• Establish readiness standards and measures for the 

Guard’s homeland security missions so that the 

readiness for these missions can be systematically 

measured and accurately reported. 

The department generally agreed with

our recommendations and cited actions it 

was taking to implement them. DOD 

partially agreed with our recommendation 

that DOD develop plans to manage the 

risk associated with the declining 

readiness of non-deployed Army National 

Guard forces. We agreed that the Army 

Campaign Plan is a significant step in 

planning to address National Guard 

readiness problems because it identifies 

goals and objectives and assigns 

responsibilities for actions to plan for 

transforming its forces. However, we 

believed the Army Campaign Plan did not 

fully meet the intent of our 

recommendation because it lacked 

specificity about how the Army would 

address the readiness of non-deployed

Army National Guard forces in the near 

term and how all Guard units will be

converted to the modular design. DOD 

concurred with our recommendation to 

establish the full range of the National 

Guard’s homeland missions, to identify 

the capabilities needed to perform those 

missions and develop a plan to address 

any shortfalls, and to establish readiness 

standards and measures for the Guard’s 

homeland security missions. However, in

its comments, DOD said it would take a 

different approach to accomplishing the 

tasks than we recommended. We believe 

the approach DOD proposes meets the 

intent of our recommendation, and we 

have modified the wording of our 

recommendation to reflect the proposed 

change in organizational responsibilities. 

Appendix I: Summary of Key Open GAO 

Recommendations on Catastrophic Disasters 

Page 105 GAO-06-618 Catastrophic Disasters
Appendix I: Summary of Key Open GAO 

Recommendations on Catastrophic Disasters

Title and GAO product 

number Summary of recommendations Agency response 

Homeland Security: Federal 

Leadership and 

Intergovernmental 

Cooperation Required to 

Achieve First Responder 

Interoperable 

Communications, 

GAO-04-740

Recommendations to the Secretary of Homeland Security: 

To address a fundamental barrier to successfully 

addressing the decades-old problems of interoperable

communications—the lack of effective, collaborative, 

interdisciplinary, and intergovernmental planning, the 

Secretary of Homeland Security should: 

• Work with the Federal Communications Commission and 

the National Telecommunications and Information 

Agency to develop a nationwide database of 

interoperable communications frequencies and a 

common nomenclature for those frequencies and 

establish clear timeframes to complete both efforts. 

• Establish interoperability requirements whose 

achievement can be measured. 

• Through grant guidance, encourage states to establish a 

single statewide body that will develop a comprehensive 

statewide interoperable communications plan. 

• Require that federal grant funding of new equipment shall 

be approved only upon certification by the statewide 

body that such grants conform with the statewide 

interoperability plan. 

• In conjunction with the Director of OMB, review the 

interoperability mission and functions now performed by 

Wireless Public Safety Interoperable Communications 

Program and establish these functions as a long-term 

program with adequate coordination authority and 

funding.

DHS said that it was developing a 

nationwide database of interoperable 

public safety communications frequencies 

and also said it planned to work on a 

common nomenclature across public 

safety disciplines and jurisdictions. With 

respect to our second recommendation, 

DHS said it would develop a methodology 

to establish a national baseline of public 

safety communication and interoperability 

capabilities with input from the public 

safety community. However, the DHS 

letter did not directly address our 

recommendation about encouraging 

states to create statewide bodies for 

interoperable communications that would 

establish statewide interoperability plans 

for federal, state, and local 

communications systems in all frequency 

bands.

Homeland Security: 

Management of First 

Responder Grants in the 

National Capital Region

Reflects the Need for 

Coordinated Planning and 

Performance Goals, 

GAO-04-433

Recommendations to the Secretary of Homeland Security: 

To help ensure that emergency preparedness grants and 

associated funds are managed in a way that maximizes 

their effectiveness, the secretary should: 

• Work with the National Capital Region jurisdictions to 

develop a coordinated strategic plan to establish goals 

and priorities for enhancing first responder capacities that 

can be used to guide the use of federal emergency 

preparedness funds. 

• Monitor the plan’s implementation to ensure that funds 

are used in a way that promotes effective expenditures 

that are not unnecessarily duplicative. 

• Identify and address gaps in emergency preparedness 

and evaluate the effectiveness of expenditures in 

meeting those needs by adapting standards and 

preparedness guidelines. 

DHS generally agreed with our

recommendations but also stated that 

National Capital Region jurisdictions had 

worked cooperatively together to identify 

opportunities for synergies and lay a 

foundation for meeting the challenges 

noted in the report. DHS agreed that 

there is a need to continue to improve 

preparedness by developing more 

specific and improved preparedness 

standards, clearer performance goals, 

and an improved method for tracking 

regional initiatives. However, DHS and 

GAO disagreed about oversight roles and 

responsibilities. 

Page 106 GAO-06-618 Catastrophic Disasters
Appendix I: Summary of Key Open GAO 

Recommendations on Catastrophic Disasters

Title and GAO product 

number Summary of recommendations Agency response 

Flood Map Modernization: 

Program Strategy Shows 

Promise, but Challenges 

Remain, 

GAO-04-417 

Recommendations to the Secretary of Homeland Security: 

To help ensure that FEMA’s map modernization achieves 

the intended benefits of improved flood mitigation, 

increased flood insurance participation, and improved multihazard mitigation and risk management capabilities through 

the production of more accurate and accessible flood maps 

the Secretary of Homeland Security should direct the 

Undersecretary of Emergency Preparedness and Response 

to take the following four actions: 

• Develop and implement data standards that will enable 

FEMA, its contractor, and its state and local partners to 

identify and use consistent data collection and analysis 

methods for communities with similar risk. 

• Develop and implement strategies for partnering with 

state and local entities with varying levels of capabilities 

and resources.

• Ensure that it has the staff capacity to effectively 

implement the nationwide mapping contract and the 

overall map modernization program. 

• Develop and implement useful performance measures 

that define FEMA’ s progress in increasing stakeholders’

awareness and use of the new maps, including improved

mitigation efforts and increased participation rates in 

purchasing flood insurance.

DHS and FEMA generally agreed with

our recommendations. FEMA said that it 

planned to refine existing standards, in 

coordination with stakeholders, to ensure 

consistent data collection and analysis for 

all communities commensurate with their 

flood risk; that it would continue to 

collaborate with stakeholder groups to 

develop an effective strategy to include 

states and communities with varying 

levels of capabilities and resources; that it 

had begun planning to ensure that 

additional staffing needs are met; and 

that it planned to refine performance 

measures for this map modernization 

objective to make them more useful and 

quantifiable.

Continuity of Operations: 

Improved Planning Needed 

to Ensure Delivery of 

Essential Government 

Services, 

GAO-04-160

Recommendations to the Secretary of Homeland Security: 

To enhance the ability of the executive branch to continue 

to provide essential services during emergencies, the 

secretary should: 

• Direct the Undersecretary of Preparedness to take steps 

to improve the oversight of continuity of operations 

planning by ensuring that agencies correct the 

deficiencies in individual continuity of operations plans 

identified here, as well as those identified in previous 

assessments. 

• Conduct assessments of agency continuity plans that 

include independent verification of agency-provided 

information, as well as an assessment of the essential 

functions identified and their interdependencies with 

other activities.

DHS agreed that better continuity of 

operations planning is needed to ensure 

delivery of essential services and that 

FEMA could do more to improve 

continuity of operations planning and has 

begun to correct the identified

deficiencies. DHS has since reported to 

GAO that it had taken several actions to 

improve agency continuity of operations 

plans, including conducting an

interagency exercise in 2004 and 

providing training to more than 350 

continuity of operations planning 

managers at 65 agencies. In addition, 

DHS officials reported that after it fully 

deploys a Readiness Reporting System 

to track agency compliance with FEMA 

guidance, agencies will be required to 

periodically report to FEMA on their 

compliance. DHS reports that its 

Readiness Reporting System will be used 

to assist it in assessing agency 

contingency plans using information 

provided by the agencies. Agencies will 

then be required to provide periodic 

updates on their level of compliance with 

FEMA guidance.

Page 107 GAO-06-618 Catastrophic Disasters
Appendix I: Summary of Key Open GAO 

Recommendations on Catastrophic Disasters

Title and GAO product 

number Summary of recommendations Agency response 

Disaster Management: 

Recent Disasters 

Demonstrate the Need to 

Improve the Nation’s 

Response Strategy, 

GAO/T-RCED-93-46; 

Disaster Management: 

Improving the Nation’s 

Response to Catastrophic 

Disasters, 

GAO/RCED-93-186; and 

Disaster Assistance: DOD’s 

Support for Hurricanes 

Andrew and Iniki and 

Typhoon Omar, 

NSIAD-93-180

In 1993, in response to Hurricane Andrew, we conducted 

several reviews and made recommendations regarding the

unique challenges involved in responding to catastrophic 

disasters. 

Recommendations to FEMA: 

• FEMA should improve its catastrophic disaster response 

capability by using existing authority to aggressively 

respond to catastrophic disasters, assessing the extent 

of damage, and then actively advising state and local 

officials of identified needs and the federal resources 

available to address them, as well as the extent to which 

DOD resources will be needed to supplement those of 

the Red Cross in meeting mass care needs. 

• FEMA should enhance the capacity of state and local 

governments to respond to catastrophic disasters by (a) 

continuing to give them increasing flexibility to match 

grant funding with individual response needs, (b) 

upgrading training and exercises for catastrophic disaster 

response, and (c) assessing each state’s preparedness 

for catastrophic disaster response. 

Matters for Congressional Consideration: 

Congress should consider 

• Giving FEMA and other federal agencies explicit 

authority to take actions to prepare for catastrophic 

disasters when there is warning. 

• Removing statutory restrictions on DOD’s authority to 

activate Reserve units for catastrophic disaster relief. 

FEMA generally agreed with our findings 

and recommendations and had begun 

taking actions to address them. These 

included a proposal in FEMA’s fiscal year 

1994 budget request to restructure in a 

manner it felt came close to our 

recommendation that FEMA form a 

disaster unit. In addition, FEMA told us it 

would revise and update its training and 

exercises on the basis of the lessons 

learned from recent catastrophic 

disasters; developing methods to better 

determine state and local preparedness 

for disaster response; and seeking 

clarified legislative authority when a 

catastrophic disaster is predicted. 

At the time we said FEMA’s recent 

initiatives are a good start toward 

improving its response to future 

catastrophic disasters. However, we 

noted that some of the improvements 

necessary in the overall federal response 

are outside of FEMA’s control.

Presidential action is needed to 

strengthen leadership for the federal

response by designating a key White 

House official to oversee preparedness 

and response activities. Furthermore, 

legislative action is needed to improve all 

federal agencies’ preparedness when 

there is warning of a disaster and to allow 

DOD to activate Reserve units for 

catastrophic disaster relief. 

However, FEMA’s mission, placement, 

and all-hazards approach have been reconfigured several times and the 

recommendations to FEMA have 

remained open. We did subsequently 

closed our matters for congressional 

consideration when it appeared Congress 

would not take any action on the 

removing restrictions on Reserve 

activations, and when it considered

legislation for giving agencies explicit 

authority to prepare for pending

catastrophic disaster. However, given the 

failures witnessed in Hurricane Katrina 

and the new threat of terrorism we are 

reopening these recommendations to 

Congress.

Source: GAO analysis 

a

An open recommendation is one that the agency has not fully implemented. 

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Table 5: Recent Open Recommendations Made in the Aftermath of Hurricanes Katrina and Ritaa

Title and GAO product 

number Summary of recommendations Agency response 

Federal Action Needed to 

Ensure States Have Plans to 

Safeguard Children in the Child

Welfare System Displaced by

Disasters, GAO-06-944

Recommendations to the Secretary of Health and Human 

Services: 

To better assist states in developing child welfare disaster 

plans, we are recommending that the Secretary of Health 

and Human Services 

• Ensure that the department’s child welfare disaster 

planning guidance address the dispersion of children 

and families within and across state lines. This

guidance should include information on 

• preserving child welfare records, identifying children 

who may be dispersed, 

• identifying new child welfare cases and providing 

services, 

• coordinating services and sharing information with 

other states, and placing children from other states. 

• Develop and provide training on child welfare disaster 

planning to all states. 

Recommendations to Congress: 

To ensure continuity of services within or across state 

lines for the children under state care, Congress should 

consider requiring that states develop and submit child 

welfare disaster plans for HHS review. 

Regarding our recommendations that 

HHS ensure that the department’s 

guidance and training to states on child 

welfare disaster planning address the 

dispersion of children and families, the 

Administration for Children and Families 

stated that it has taken action to update 

the guidance and provide training to 

states and will encourage them to 

develop and submit disaster plans for 

review. 

SMALL BUSINESS 

ADMINISTRATION: ACTIONS 

NEEDED TO PROVIDE MORE 

TIMELY DISASTER 

ASSISTANCE, GAO-06-860

In order to provide more timely disaster assistance in the 

future, we recommend that the Administrator of SBA 

direct its Office of Disaster Assistance to take the 

following four actions: 

• Reassess the Disaster Credit Management System 

(DCMS) maximum user capacity and related loan 

processing resource needs based on such things as 

lessons learned from the Gulf Coast hurricanes, a 

review of information available from catastrophe risk 

modeling firms and disaster simulations, and related

cost considerations. 

• Conduct complete stress testing to ensure that DCMS 

can function at planned for maximum user capacity 

levels. 

• Improve management controls over assessing 

contractor performance through inspections of all 

equipment purchased or leased to support DCMS. 

• Expedite plans to resume business processing 

reengineering efforts to analyze the disaster loan 

process and identify ways to more efficiently process 

loan applications, including an evaluation of the 

feasibility of implementing a secure Internet-based

application feature for home loan applicants. 

SBA stated that it generally agreed with

our recommendations and intended to 

improve the delivery of the Disaster Loan 

Program for events of all sizes. However, 

SBA disagreed with some of the findings 

and conclusions in our draft report. 

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Title and GAO product number Summary of recommendations Agency response 

Disaster Evacuations: 

Limitation in Federal 

Assistance to Health Facilities 

for Transportation Should be 

Addressed, GAO-06-826

Recommendations to the Secretary of Homeland 

Security: 

To address limitations in how the federal government 

provides assistance with the evacuation of health care 

facilities, we recommend that the Secretary of Homeland 

Security take the following two actions: 

• Clearly delineate how the federal government will 

assist state and local governments with the movement 

of patients’ and residents out of hospitals and nursing 

homes to a mobilization center where National 

Disaster Medical System (NDMS) transportation 

begins. 

• In consultation with the other NDMS federal partners—

the Secretaries of Defense, Health and Human 

Services, and Veterans Affairs—clearly delineate how 

to address the needs of nursing home residents during 

evacuations, including the arrangements necessary to 

relocate these residents. 

DHS stated that it will take our

recommendations under advisement as it 

reviews the National Response Plan. 

According to DHS, all of the NDMS 

federal partners are currently reviewing 

the NDMS memorandum of agreement 

with a view towards working with state 

and local partners to alter, delineate, and 

otherwise clarify roles and responsibilities 

as appropriate. However, we noted that, 

as stated in the draft report, neither 

NDMS documents, the NRP, nor the draft 

Catastrophic Incident Supplement to the 

NRP—to be used in cases when the 

capabilities of state and local 

governments are almost immediately 

overwhelmed—describe the federal role 

in coordinating with state and local 

authorities during hospital and nursing

home evacuations. We also noted that 

reliance on state and local resources was 

inadequate when multiple facilities in a 

community had to evacuate 

simultaneously. 

DOD disagreed with our conclusions 

concerning the federal role in short 

distance transportation and the 

successful evacuation of nursing home 

residents during Hurricane Rita. 

However, during a catastrophic incident, 

the capabilities of state and local 

governments may almost immediately 

become overwhelmed. As we stated 

above in our response to DHS’s 

comments, the federal role in these 

situations has not been described. 

Second, Our draft report did describe 

NDMS’s evacuation of people, including 

nursing home residents. However, we 

also noted that the NDMS after-action 

report on hurricanes Katrina and Rita 

states that NDMS was not optimally 

prepared to manage the nursing home 

requirements of evacuees who did not 

require hospitalization. For this reason, 

we believe that explicit consideration of 

the needs of nursing home residents is 

warranted. 

HHS and Veterans Affairs concurred with 

our recommendations. 

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Continuity of Operations: 

Selected Agencies Could 

Improve Planning for Use of 

Alternate Facilities and 

Telework during Disruptions, 

GAO-06-713

Recommendations to the Secretary of Homeland 

Security: 

To improve the assessment and oversight of agency 

continuity planning and developing guidance on including 

telework in such planning, and to ensure that agencies 

are adequately prepared to continue performing essential 

functions following an emergency, the Secretary of 

Homeland Security should direct the Undersecretary for 

Federal Emergency Management to: 

• Before the upcoming interagency exercise, conduct an 

assessment of the continuity of operations 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 

continuity of operations plan assessments that 

independently evaluates executive branch agencies’ 

compliance with Federal Preparedness Circular (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 timeline 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 continuity of 

operations event. 

DHS partially agreed and stated that 

FEMA would be conducting assessments 

of the six agencies in conjunction with its 

upcoming interagency exercise. 

DHS stated 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 government 

wide exercise planned for June 2006, 

and (3) a plan for an expanded

comprehensive department and agency 

assessment program. DHS stated that 

the agency’s efforts are constrained by 

resources, and that additional resources 

are required to support the large number 

of federal offices and facilities that could 

benefit from recurring continuity of 

operations planning assessments. 

While these steps outline an overall 

approach to assessing agency plans, 

they do not constitute a methodology for 

assessing agency compliance with FPC 

65. Without such a methodology, the 

agency will have limited assurance that 

agencies have taken the necessary steps 

to prepare for an emergency.

In responding to our recommendation on 

developing guidance on agencies’ use of 

telework, DHS partially agreed and stated

that FEMA will coordinate with OPM in 

the development of a timeline for further 

telework guidance. 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.

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number Summary of recommendations Agency response 

Hurricanes Katrina and Rita: 

Coordination between FEMA 

and the Red Cross Should Be 

Improved for the 2006 

Hurricane Season, 

GAO-06-712 

Recommendations to the Secretary of Homeland 

Security: 

To clarify roles and responsibilities within ESF-6 for the 

2006 hurricane season and to help ensure that FEMA’s 

resource tracking system will meet the needs of those 

requesting FEMA assistance, the Secretary of DHS 

should 

• Direct FEMA to work with the Interim President and 

Chief Executive Officer of the Red Cross as soon as 

possible to reach agreement on the operating

procedures that they will both use in the event of an 

incident of national significance. Given the lack of 

progress FEMA and the Red Cross have made thus 

far in reaching agreement on the operating procedures 

and that the new hurricane season is beginning, they 

may wish to use mediation to speed the agreement. 

Direct FEMA to ensure that it obtains input from the Red 

Cross as it develops a resource tracking system. 

• Recommendations to the Interim President and Chief 

Executive Officer of the Red Cross: 

• Implement ESF-6 staffing strategies that better 

facilitate the development of working relationships and 

retain institutional knowledge. 

DHS did not provide a response to our 

recommendations, noting that FEMA was 

actively preparing for the hurricane 

season. 

Overall, the Red Cross agreed with our 

conclusion that coordination between 

FEMA and the Red Cross could be 

improved for the 2006 hurricane season. 

The Red Cross also highlighted actions 

under way with respect to our first two 

recommendations. With respect to our 

recommendation about staffing 

strategies, the Red Cross said that it is in 

the process of hiring ESF-6 reservists 

who will be deployed for extended 

periods of time to perform Red Cross 

ESF-6 mass care functions at the federal 

level.

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Expedited Assistance for 

Victims of Hurricanes 

Katrina and Rita: FEMA’s 

Control Weaknesses 

Exposed the Government 

to Significant Fraud and 

Abuse, GAO-06-655

Recommendations to the Secretary of Homeland Security: 

That the Secretary of Homeland Security directs 

Undersecretary for Federal Emergency Management to take 

six actions to address the weaknesses we identified in the 

administration of Individuals and Households Program (IHP). 

• Establish an identity verification process for IHP 

registrants applying via both the Internet and telephone, to 

provide reasonable assurance that disaster assistance 

payments are made only to qualified individuals. Within 

this process 

• establish detailed criteria for registration and provide 

clear instructions to registrants on the identification 

information required, 

• create a field within the registration that asks registrants 

to provide their name exactly as it appears on their 

social security card in order to prevent name and social 

security number (SSN) mismatches, 

• fully field test the identity verification process prior to 

implementation,

• ensure that call center employees give real-time 

feedback to registrants on whether their identities have 

been validated, and 

• establish a process that uses alternative means of 

identity verification to expeditiously handle legitimate 

applicants that are rejected by identity verification 

controls. 

• Develop procedures to improve the existing review 

process of duplicate registrations containing the exact 

same SSN and to identify the reasons why registrations 

flagged as invalid or as potential duplicates have been 

overridden and approved for payment. 

• Establish an address verification process for IHP 

registrants applying via both the Internet and telephone, to 

provide reasonable assurance that disaster assistance 

payments are made only to qualified individuals. Within 

this process 

• create a uniform method to input street names and 

numbers and apartment numbers into the registration, 

• institute procedures to check IHP registration damaged 

addresses against publicly available address databases 

so that payments are not made based on bogus 

property addresses, 

• fully field test the address verification process prior to 

implementation,

• ensure that call center employees can give real time 

feedback to registrants on whether addresses have 

been validated, and 

• establish a process that uses alternative means of 

address verification to expeditiously handle legitimate 

applicants that are rejected by address verification 

controls. 

DHS and FEMA concurred fully with four of 

our six recommendations, and partially 

concurred with the remaining two 

recommendations. FEMA and DHS 

concurred fully that FEMA (1) improve 

procedures to review registrations 

containing the same SSNs and other 

duplicate information; (2) subject all 

registration addresses to verification during 

the registration process; (3) explore 

entering into agreements with other 

agencies, such as the Social Security 

Administration, to periodically authenticate 

IHP information; and (4) issue proper 

instructions to any future debit card 

recipients. FEMA and DHS stated that they 

have already taken actions to address 

these recommendations. These actions 

include instituting an Internet application 

process that will prevent all duplicate 

registrations from the Internet, 

implementing procedures so that call 

centers will no longer accept duplicate 

registrations with the same SSN in the 

same disaster, and conducting conference 

calls and conducting data sharing tests 

with the Social Security Administration. In 

addition, DHS and FEMA stated that, 

starting in June 2006, all registration 

addresses (even phone-in) will be 

subjected to an online verification during

the registration process. While these are 

steps in the right direction, we will follow up 

on whether the actions taken fully address 

our recommendations. 

FEMA and DHS partially concurred with 

our recommendation concerning duplicate 

payments. FEMA and DHS took exception 

with our categorization of some payments 

as being potential duplicates, and with our 

assessment that they should initiate 

actions to collect duplicate Expedited 

Assistance payments. However, for all our 

case study examples, we conducted 

further investigative work to confirm that 

the payments were made to actual 

duplicates, not covered by the separated

household policy, and were therefore 

improper payments. As for initiating actions 

to collect duplicate payments, DHS and 

FEMA stated that they had processed for 

recoupment nearly all the payments they 

believed were duplicates as of April 1, 

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• Explore entering into an agreement with other agencies, 

such as the Social Security Administration, to periodically 

authenticate information contained in IHP registrations. 

• Establish procedures to collect duplicate expedited 

assistance payments or to offset these amounts against 

future payments. Such duplicate payments include 

• the payments made to IHP recipients who improperly 

received the $2,000 debit cards and an additional 

$2,000 Expedited Assistance check or Electronic Funds 

Transfer, and 

• the thousands of duplicate Expedited Assistance 

payments made to the same IHP registration number. 

• Ensure that any future distribution of IHP debit cards 

includes instructions on the proper use of IHP funds, 

similar to those instructions provided to IHP check and 

Electronic Funds Transfer recipients, to prevent improper 

usage. 

2006. While we have not assessed the 

effectiveness of FEMA’s recoupment 

process, we continue to believe that FEMA 

should attempt to recoup as many dollars 

of improper payments as possible, 

including those duplicate payments that we 

identified that FEMA questioned. 

Going forward it will be important for FEMA 

to establish effective controls to prevent 

fraudulent and improper payments before 

they occur, because fraud prevention is a 

far more effective control than detecting 

improper and potentially fraudulent 

payments after they are made. Our 

experience with organizations that rely on 

a process that attempts to detect improper 

and potentially fraudulent payments after 

they are made is that the organization 

recovers only a fraction of the payments 

that should not have been made. 

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Hurricane Katrina: Better 

Plans and Exercises 

Needed to Guide the 

Military’s Response to 

Catastrophic Natural 

Disasters, GAO-06-643

Recommendations to the Secretary of Defense: 

To improve the military response to catastrophic disasters, 

the Secretary of Defense should 

• Provide proposed revisions of the NRP to the Secretary of 

the Department of Homeland Security that addresses the 

proactive functions the military is expected to make during 

a catastrophic incident. 

• Establish milestones and expedite the development of 

detailed plans and exercises to fully account for the 

unique capabilities and support that the military is likely to 

provide to civil authorities in response to the full range of 

domestic disasters, including catastrophes. The plans and 

exercises should specifically address the 

• use of reconnaissance capabilities to assess damage, 

• use of communications capabilities to facilitate support 

to civil authorities, 

• integration of active component and National Guard 

and Reserve forces, 

• use of search and rescue capabilities and the military’s 

role in search and rescue, and 

• role the military might be expected to play in logistics. 

• Direct the Chief of the National Guard Bureau to work with 

the state governors and adjutants general to develop and 

maintain a list of the types of capabilities the National 

Guard will likely provide in response to domestic natural 

disasters under state-to-state mutual assistance 

agreements along with the associated units that could 

provide these capabilities. This information should be 

made available to the Northern Command, U.S. Joint 

Forces Command, and other organizations with federal 

military support to civil authority planning responsibilities. 

• Establish milestones and identify the types of scalable 

federal military capabilities and the units that could 

provide those capabilities in response to the full range of 

domestic disasters and catastrophes covered by DOD’s 

defense support to civil authorities’ plans. 

Matters for Congressional Consideration: 

In a 1993 report we suggested that Congress consider 

removing the statutory restriction on DOD’s authority to 

involuntarily activate Reserve units for catastrophic disaster 

relief. In view of the significant military downsizing that has 

occurred since we first raised this matter and the need to 

actively engage the total force in order to meet missions at 

home and abroad, we continue to believe that Congress 

should consider lifting or modifying the mobilization 

restriction—10 U.S.C. §12304 (c)(1)—that limits reserve 

component participation in catastrophic natural disasters.

DOD commented on our four 

recommendations, partially concurring with

each of them. With respect to our first 

recommendation—to revise the NRP to 

fully address the proactive functions that 

the military will be expected to perform 

during a catastrophic incident—DOD said 

that proactive military functions can be 

identified in all 15 major disaster scenarios 

and said it is working with the Department 

of Homeland Security to revise the NRP. 

While DOD stated that the long-term focus 

of the U.S. government should be to 

develop more robust domestic disaster 

capabilities within the Department of 

Homeland Security, it acknowledged that 

DOD will need to assume a more robust 

response role in the interim period and 

when other responders lack the resources 

and expertise to handle a particular 

disaster. 

With respect to our second 

recommendation that concerned the 

development of detailed plans and 

exercises, DOD listed a number of steps it 

is taking to improve its disaster response 

planning and exercises and said that 

consistent with its Strategy for Homeland 

Defense and Civil Support the active 

component should complement, but not 

duplicate, the National Guard’s likely role 

as an early responder. On June 27, 2006, 

the Assistant Secretary of Defense for 

Homeland Defense sent DOD’s final 

response, listing some recently-completed

exercises as well as steps that DOD was 

taking to enhance interagency planning 

efforts. 

DOD also partially concurred with our third 

recommendation—that the Chief of the 

National Guard Bureau work with the state 

governors and adjutants general to develop 

and maintain a list of the types of 

capabilities the National Guard will likely 

provide in response to domestic natural 

disasters under state-to-state mutual 

assistance agreements. 

Finally, DOD partially concurred with our 

recommendation that it identify the types of 

scalable federal military capabilities and 

units that will provide those capabilities in

response to the full range of domestic 

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disasters and catastrophes. In its final 

response to our report, DOD stated it had 

analyzed potential gaps between state and 

other federal agency response, and had 

developed 18 pre-scripted mission 

assignments to address DOD support to 

FEMA, and had validated these 

assignments during an exercise. DOD also 

reported that it had developed scalable 

capability packages in conjunctions with 

U.S. Northern Command’s contingency 

plan for defense support to civil authorities, 

and it was staffing forces to accelerate 

force/capabilities necessary to support a 

catastrophic event.

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U.S. Tsunami 

Preparedness: Federal 

and State Partners 

Collaborate to Help 

Communities Reduce 

Potential Impacts, but 

Significant Challenges 

Remain, GAO-06-519

Recommendations to the Secretary of Commerce: 

To help improve national tsunami preparedness, the 

Secretary of Commerce should direct the National 

Oceanographic and Atmospheric Administration (NOAA) 

Administrator to take the following six actions 

• Work with the FEMA Director and the United States 

Geological Survey (USGS) Director to create

standardized tsunami loss estimation software to help 

communities determine the potential impact of tsunamis 

and identify appropriate mitigation actions. 

• Reduce the number of tsunami warning false alarms by 

(1) completing the planned expansion of tsunami 

detection stations; (2) reexamining NWS rules dictating 

when a warning will be issued and to which areas; (3) 

establishing a routine process for other federal and state 

experts to formally review and comment on the centers’

use of seismic data; and (4) setting performance goals to 

guide improvements. 

• Work with the states to conduct periodic end-to-end tests 

of the tsunami warning system, including NOAA Weather 

Radio and the Emergency Alert System, to ensure the 

system will function as intended during a tsunami 

emergency. 

• Evaluate the Tsunami Ready program to determine what 

barriers, if any, exist to participation and what

modifications are needed to encourage more high-risk 

communities to participate. 

• Evaluate the National Tsunami Hazard Mitigation 

Program to determine what has worked well in the past 

and what high priority activities remain to be completed 

and to help inform strategic planning efforts. 

• Develop comprehensive risk-based strategic plans for the 

Tsunami Program and National Tsunami Hazard 

Mitigation Program that consider input from states and 

federal partners and include metrics for measuring 

progress toward achieving program goals. 

Commerce, representing NOAA, concurred 

with all six recommendations. However, in 

NOAA suggested a revision to one of the 

recommendations with which we disagree. 

In response to our recommendation that 

NOAA evaluate the Tsunami Ready 

program to determine what barriers, if any, 

exist to participation and what modifications 

are needed to encourage more high-risk 

communities to participate, NOAA 

suggested changing the recommendation’s 

focus from “high-risk” to “at-risk” 

communities. According to NOAA all U.S. 

coastal communities should be prepared 

for a tsunami no matter how rare. While we 

agree that preparing all U.S. coastal 

communities for a tsunami may be a 

laudable long-term goal, given the agency’s 

limited resources, it may be an unrealistic 

goal in the short-term. Therefore, we 

believe that NOAA should use a risk-based 

approach and target initial participation in 

the Tsunami-Ready program to those 

communities that face the greatest risk. 

Homeland Security, representing FEMA, 

commented on one of the six 

recommendations and indicated that while 

it concurred with the recommendation, that 

NOAA work with FEMA and USGS to 

create standardized tsunami loss 

estimation software, it was concerned that 

FEMA did not have the funding or the staff 

resources to pursue such a request and 

that such a request from NOAA would have 

to address these resource needs. 

The Department of the Interior commented 

that the report was a thorough, wellresearched examination of the nation’s 

tsunami warning system and that it 

correctly recognizes the need for close 

collaboration at the federal, state, and local 

levels to have an effective tsunami warning 

system. Interior also said that it supports 

the need for a risk-based approach to 

prioritizing federal investments in this 

system and is actively collaborating with

NOAA to provide the hazard assessments 

necessary for such an approach. 

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Hurricane Katrina: 

Comprehensive Policies 

and Procedures Are 

Needed to Ensure 

Appropriate Use of and 

Accountability for 

International Assistance, 

GAO-06-460

Recommendations to the Secretary of Homeland Security: 

To help ensure that the cognizant agencies fulfill their 

responsibility to account for and effectively manage foreign

donations and maintain adequate internal controls over 

government resources, the Secretary of Homeland Security, 

in consultation with the Secretary, Department of State, 

should: 

• Establish within the NRP—or other appropriate plans—

clearly delineated policies and procedures for the 

acceptance, receipt, and distribution of international 

assistance. 

• Incorporate the following actions and procedures into their 

guidance: 

• Develop policies, procedures, and plans to help ensure 

international cash donations for disaster relief and 

assistance are accepted and used appropriately as 

needed, 

• Place international cash donations in an account that 

would pay interest while decisions are pending on their 

use to maintain the purchasing power of those 

donations, 

• Maintain oversight of foreign donated in-kind assets by 

tracking them from receipt to disbursement, to 

reasonably ensure that assistance is delivered where it 

is intended, and

• Establish plans for the acceptance of foreign-donated 

items that include coordinating with regulatory 

agencies, such as US Department of Agriculture and 

Food and Drug Administration, in advance, in order to 

prevent the acceptance of items that are prohibited

from distribution in the United States regardless of 

waivers that might be established to expedite the 

importing of foreign assistance; these plans should 

also include Department of State obtaining information 

on acceptable or unacceptable items in order to 

communicate to the international community what is 

needed or what can not be accepted. 

Recommendations to the Secretary of Defense: 

The Secretary of Defense, in consultation with the 

Secretaries of State and Homeland Security, should: 

• Establish within the NRP—or other appropriate plans—

clearly delineated policies and procedures to ensure that 

foreign military offers of assistance for domestic disasters 

are coordinated through the Department of State to 

ensure they are properly accepted and safeguarded and 

used as intended. 

Develop and issue internal DOD guidance to commanders

on the agreed-upon process to coordinate assistance 

through Department of State.

DOD and DHS generally agreed with our 

recommendations. DHS noted that, in 

some cases, actions were already 

underway to address the 

recommendations. Both made suggestions 

to clarify the wording, and we adjusted the 

recommendations based on their 

suggestions.

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Federal Emergency 

Management Agency: 

Improvements Needed to 

Enhance Oversight and 

Management of the 

National Flood Insurance 

Program, GAO-06-119; 

Future Financial Stability 

of the National Flood 

Insurance Program, GAO06-174T; and Oversight 

and Management of the 

National Flood Insurance 

Program, GAO-06-183T

Recommendations to the Secretary of Homeland Security: 

To improve FEMA’s oversight and management of the NFIP 

and make it more actuarially sound, we recommend that the 

Secretary of the Department of Homeland Security direct 

the Undersecretary for Emergency Preparedness and 

Response to: 

• Use a methodologically valid approach to draw

statistically representative samples of claims for 

underwriting and claims portions of operational reviews 

and for quality assurance re-inspections of claims by 

general adjusters. 

• Develop documented plans with milestones for 

implementing requirements of the Flood Insurance 

Reform Act of 2004 to provide policyholders with a flood 

insurance claims handbook that meets statutory 

requirements, to establish a regulatory appeals process, 

and to ensure that insurance agents meet minimum NFIP 

education and training requirements.

FEMA offered comments principally in 

three areas: (1) its disappointment that we 

had not directly addressed the issue of 

whether Congress intended the flood 

insurance program to restore damaged 

property to its pre-flood condition; (2) its 

view that the method of choosing its 

sample for operational reviews was 

appropriate and that its financial and 

internal controls are wide-ranging and 

include processes that we did not address; 

and (3) its view that contrary to the 

impression given in our draft report, FEMA 

has worked diligently to implement the 

requirements of the Flood Insurance 

Reform Act of 2004. 

We responded that (1) we believed that we 

have addressed the issue of congressional 

intent consistent with our statutory mandate 

by explaining the statutory and regulatory 

provisions that affect both dollar ceilings 

and other coverage limitations; (2) FEMA’s 

sampling and internal controls still did not 

provide management with the information

needed to assess the overall performance 

of companies, the overall accuracy of the 

underwriting of NFIP policies and the 

adjustment of claims—information that 

FEMA needs to have reasonable 

assurance that program objectives are 

being achieved; and (3) we described 

several actions FEMA had taken in its 

efforts to comply with the act, while noting 

that it had not fully implemented the act’s 

requirements.

Source: GAO analysis.

a

An open recommendation is one that the agency has not fully implemented. 

Page 119 GAO-06-618 Catastrophic Disasters
Appendix I: Summary of Key Open GAO 

Recommendations on Catastrophic Disasters

Table 6: New GAO Recommendations Formalized in this Report 

We are making several additional recommendations regarding preparedness, response, and recovery: 

Recommendations to the Secretary of Homeland Security: 

The Secretary should: 

• Rigorously re-test, train, and exercise its recent clarification of the roles, responsibilities, and lines of authority for all levels of 

leadership, implementing changes needed to remedy identified coordination problems. 

• Direct that the NRP base plan and its Catastrophic Incident Annex be supported by more robust and detailed operational

implementation plans, particularly the Catastrophic Incident Supplement to the NRP. Such operational plans should, for example,

further define and leverage those military capabilities that might be needed in a catastrophic disaster.

• Provide guidance and direction for federal, state, and local planning, training, and exercises to ensure such activities fully support 

preparedness, response, and recovery responsibilities at a jurisdictional and regional basis. This should also include the 

application of lessons learned from actual catastrophic and other disasters. 

• Take the lead in monitoring federal agencies’ efforts to meet their responsibilities under the NRP and the interim National 

Preparedness Goal, including the development, testing, and exercising of agency operational plans to implement their

responsibilities under the NRP, NIMS, and the National Preparedness Goal. 

• Given that resources are finite, apply an all-hazards risk management approach in deciding whether and how to invest in specific 

capabilities for a catastrophic disaster. 

• Provide guidance on advance procurement practices and procedures for those federal agencies with roles and responsibilities 

under the NRP, so that these agencies can better manage disaster-related procurements. These practices should be in advance 

of disasters, ongoing and continuous, and include (1) developing knowledge of contractor capabilities, and available 

commodities, services and prices as well as developing pre-established vendor relationships, on a competitive basis whenever 

feasible; (2) establishing scalable operations plans to adjust the level of capacity needed to respond; (3) formally assigning and 

communicating disaster-related responsibilities and, where feasible, incorporating necessary training; and (4) providing sufficient 

numbers of field-level contracting staff to meet mission requirements. DHS should also establish an assessment process to 

monitor agencies’ continuous planning efforts for their disaster related procurement needs and the maintenance of capabilities.

Matter for Congressional Consideration: 

• We again recommend, as we did in 1993 in the aftermath of Hurricane Andrew, that Congress give federal agencies explicit 

authority to take actions to prepare for catastrophic disasters when there is warning. 

Source: GAO analysis.

Page 120 GAO-06-618 Catastrophic Disasters
Appendix II: Comments from the Department Appendix II: Comments from the Department of Homeland Security

of Homeland Security 

Page 121 GAO-06-618 Catastrophic Disasters
Appendix II: Comments from the Department 

of Homeland Security

Page 122 GAO-06-618 Catastrophic Disasters
Appendix II: Comments from the Department 

of Homeland Security

Page 123 GAO-06-618 Catastrophic Disasters
Appendix II: Comments from the Department 

of Homeland Security

Page 124 GAO-06-618 Catastrophic Disasters
Appendix II: Comments from the Department 

of Homeland Security

Page 125 GAO-06-618 Catastrophic Disasters
Appendix II: Comments from the Department 

of Homeland Security

Page 126 GAO-06-618 Catastrophic Disasters
Appendix II: Comments from the Department 

of Homeland Security

Page 127 GAO-06-618 Catastrophic Disasters
Appendix II: Comments from the Department 

of Homeland Security

Page 128 GAO-06-618 Catastrophic Disasters
Appendix II: Comments from the Department 

of Homeland Security

Page 129 GAO-06-618 Catastrophic Disasters
Appendix II: Comments from the Department 

of Homeland Security

Page 130 GAO-06-618 Catastrophic Disasters
Appendix II: Comments from the Department 

of Homeland Security

Page 131 GAO-06-618 Catastrophic Disasters
Appendix II: Comments from the Department 

of Homeland Security

Page 132 GAO-06-618 Catastrophic Disasters
Appendix III: Comments from the Small Appendix III: Comments from the Small Business Administration 

Business Administration 

Page 133 GAO-06-618 Catastrophic Disasters
Appendix III: Comments from the Small 

Business Administration 

Page 134 GAO-06-618 Catastrophic Disasters
Appendix III: Comments from the Small 

Business Administration 

Page 135 GAO-06-618 Catastrophic Disasters
Appendix IV: 

A

GAO Contact and Staff 

cknowledgments 

Page 136 GAO-06-618

Appendix IV: GAO Contact and Staff 

Acknowledgments 

Norman Rabkin, Managing Director, GAO Homeland Security and Justice 

Issues Team, (202)-512-8777 (rabkinn@gao.gov) 

In addition to the contact named above the following individuals from 

GAO’s Homeland Security and Justice Team also made contributions to 

this report: William O. Jenkins Jr., Director; Sharon Caudle, Assistant 

Director; John Vocino, Analyst-In-Charge; Daniel Rodriguez; Kathryn 

Godfrey; and Christine Davis, GAO Office of General Counsel. 

GAO Contact 

Acknowledgments 

Catastrophic Disasters
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Page 137 GAO-06-618 Catastrophic Disasters
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Page 138 GAO-06-618 Catastrophic Disasters
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Page 139 GAO-06-618 Catastrophic Disasters
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Page 140 GAO-06-618 Catastrophic Disasters
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(440504) Page 141 GAO-06-618 Catastrophic Disasters
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