Department of Homeland Security 

Office of Inspector General 

FEMA’s Implementation of 
 

Recommendations from Top Officials 4 
 

OIG-10-121 September 2010 
Office ofInspector Gel/eraf 

U.S. Department of Homeland Security 

Washington, DC 20528 

Homeland 

Security 

Preface 

The Department of Homeland Security (DHS) Office ofInspector General (OIG) was 

established by the Homeland Security Act of2002 (Public Law 107-296) by amendment 

to the Inspector General Act of 1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report addresses the extent to which the Federal Emergency Management Agency 

incorporated corrective actions from Top Officials 4 into National Level Exercise 2009. 

It is based on interviews with employees and officials of relevant agencies and 

institutions, direct observations, and a review of applicable documents. 

The recommendation herein has been developed to the best knowledge available to our 

office, and has been discussed in draft with those responsible for implementation. We 

trust this report will result in more effective, efficient, and economical operations. We 

express our appreciation to all of those who contributed to the preparation of this report. 

C-UQVV\\­

Carlton I. Mann 

Assistant Inspector General for Inspections 

3 
Table of Contents/Abbreviations 

Executive Summary.............................................................................................................1
 


Background..........................................................................................................................2 
 

Results of Review ................................................................................................................4 
 

All TOPOFF 4 Corrective Actions Were Not Relevant for NLE 2009.........................4 
 

Barriers Exist That Hinder the Effectiveness of a Corrective Action Program.............8 
 

Recommendation ...........................................................................................................9 
 

Management Comments and OIG Analysis ................................................................10 
 

Appendices 

Appendix A: Purpose, Scope, and Methodology.......................................................11 
 

Appendix B: Management Comments to the Draft Report.......................................12 
 

Appendix C: Major Contributors to this Report........................................................14 
 

Appendix D: Report Distribution ..............................................................................15 
 

Abbreviations 

AAR After Action Report 
 

CAP Corrective Action Program
 

DHS Department of Homeland Security 
 

ESC Executive Steering Committee 
 

FEMA Federal Emergency Management Agency 
 

HSC Homeland Security Council 
 

HSPD Homeland Security Presidential Directive 
 

NED National Exercise Division 
 

NEP National Exercise Program
 

NLE National Level Exercise
 

NPD National Preparedness Directorate 
 

POC Point of Contact 
 

Sub-PCC Sub-Policy Coordination Committee 
 

TOPOFF Top Officials 
 
OIG 
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

National level exercises, formerly designated as Top Officials exercises, 

are designed to reinforce the nation’s capability to prepare for, prevent, 

respond to, and recover from large-scale terrorist attacks or natural 

disasters. These exercises test high-level government officials’ response 

to simulated attacks and disasters and identify corrective actions resulting 

from problems discovered during these exercises. Our review examined 

how the Federal Emergency Management Agency, which coordinates the 

federal government's role in disaster-related activities, incorporated 

corrective actions identified in Top Officials 4 into National Level 

Exercise 2009. 

The Federal Emergency Management Agency developed a centralized 

Corrective Action Program to address deficiencies identified during 

national level exercises. The agency documented 54 corrective actions in 

Top Officials 4, ten of which were relevant to and incorporated into the 

planning and execution of National Level Exercise 2009. 

While the Federal Emergency Management Agency is responsible for 

inputting information into a corrective action database, tracking these 

corrective actions rests exclusively with participating federal entities. This 

barrier hinders the effectiveness of the Corrective Action Program as the 

Federal Emergency Management Agency has no enforcement authority to 

direct compliance with corrective action implementation. 

We are recommending that the Federal Emergency Management Agency, 

in collaboration with the Exercise and Evaluation Sub-Interagency Policy 

Committee and the National Exercise Program Executive Steering 

Committee, develop reporting regulations for oversight of corrective 

action implementation. The Federal Emergency Management Agency 

agreed with the importance of an oversight system and collaborative 

efforts to include the Exercise and Evaluation Sub-Interagency Policy 

Committee. As an alternative to our recommendation for corrective action 

oversight through federal regulation, we accepted their suggestion to 

develop a mechanism to strengthen corrective action progress in 

collaboration with the White House. 

. 

FEMA’s Implementation of Recommendations from Top Officials 4 

 Page 1 
Background 

House Report 110-862 requires that we review changes made by 

the Department of Homeland Security (DHS) as a result of 

problems identified through Top Officials (TOPOFF) 4, and make 

recommendations for any further improvements needed.1 To 

satisfy this requirement, we examined the extent to which 

corrective actions identified in TOPOFF 4 were incorporated into 

the planning and execution of DHS’ National Level Exercise 

(NLE) 2009. 

The Homeland Security Act (HSA) of 2002 assigned DHS primary 

responsibility to prepare for and sustain the United States’ 

capability to reduce vulnerabilities associated with acts of 

terrorism. The DHS Secretary is responsible for coordinating 

federal operations to prepare for, respond to and recover from 

terrorist attacks, major disasters, and other emergencies. 

In February 2003, the President issued Homeland Security 

Presidential Directive (HSPD) 5, Management of Domestic 

Incidents, which identifies steps for improved coordination among 

all levels of government in response to terrorist attacks, major 

disasters and other emergencies. In December 2003, the President 

issued HSPD 8, National Preparedness, which describes how 

federal departments and agencies will prepare for such responses. 

In coordination with other federal departments, agencies, state and 

local governments, and private sector entities, HSPD 8 directed 

DHS to establish a national program to conduct homeland security 

preparedness-related exercises that could be evaluated to determine 

the country’s ability to handle man-made or natural disasters. 

The Executive Steering Committee (ESC) coordinates 

departmental and agency roles and responsibilities, and reports to 

the Exercise and Evaluation Sub-Interagency Policy Committee 

(Sub-IPC). The Sub-IPC recommends exercise priorities, goals, 

objectives, schedules, and corrective action issues to the Homeland 

Security Council (HSC) Deputies Committee, which is composed 

of deputy cabinet secretaries of the relevant federal agencies. 

Within DHS, the Federal Emergency Management Agency 

(FEMA) coordinates the federal government's role in all domestic 

disaster- related activities. In April 2007, FEMA established the 

 

1 Top Officials exercises were designated as National Level Exercises beginning in Fiscal Year 2009. 

FEMA’s Implementation of Recommendations from Top Officials 4 

 Page 2
 

 

•	 Prevent Mission: Actions taken to avoid an incident or 

intervene to stop an incident from occurring. 

•	 Protect Mission: Reduce the likelihood of attack on assets or 

systems and limit the impact should an attack occur. 

•	 Respond Mission: Implement immediate actions to save lives, 

protect property, and meet basic human needs. 

 

National Preparedness Directorate (NPD) to oversee the 

coordination and development of strategies necessary to prepare 

for terrorist incidents and natural disasters. As part of this mission, 

NPD provides policy and planning guidance that builds prevention, 

protection, response, and recovery capabilities among all levels of 

federal, state and local governments.2 

Within NPD, the National Exercise Division (NED) established the 

National Exercise Program (NEP) to improve the delivery and 

organization involved with planning for, developing and executing 

preparedness-related national level exercises for the federal 

government. NEP is the primary tool for assessing the country’s 

ability to prevent, protect, respond to and recover from 

catastrophic events. National level exercises are conducted to test 

and identify planning and resource gaps in existing strategies, 

policies and procedures. 

A White House memorandum entitled, “National Exercise 

Program,” identified by many observers as the NEP charter, 

requires a corrective action process to ensure lessons from 

exercises are either sustained or improved as appropriate. To 

facilitate a corrective action process, FEMA developed a 

Corrective Action Program (CAP) to address preparedness 

deficiencies identified during exercises, policy discussions, and 

real-world events and refers issues to departments and agencies for 

priority and remedial action. Specifically, the CAP identifies, 

assigns, and tracks corrective actions. FEMA’s NPD serves as the 

responsible agent for the CAP, and provides administrative and 

technical support to other federal departments and agencies. 

National level exercises have four homeland security mission 

areas: prevent, protect, respond, and recover. 

2 After TOPOFF 4 and NLE 09 exercises, a fifth mission area – mitigation – was added to the homeland 

security mission areas. Mitigation is the effort to reduce loss of life and property by lessening the impact of 

disasters. 

FEMA’s Implementation of Recommendations from Top Officials 4 

 Page 3
 
•	 Recover Mission: Develop, coordinate, and execute serviceand site-restoration plans and reconstitute government 

operations and services through individual, private-sector, 

nongovernmental, and public assistance programs. 

National level exercises are categorized into four tiers. These tiers 

reflect the priority for federal participation, with Tier I as the 

highest and Tier IV as the lowest, and are assigned based on their 

alignment with federal government-wide strategic and policy 

priorities. 

As stated in the NEP Implementation Plan, a national level 

exercise is the single annual operations-based NEP Tier I exercise 

focused on White House-directed, U.S. government-wide strategy 

and policy-related issues that require the participation of all 

appropriate department and agency principals. There are 5 NEP 

Tier I exercises annually. TOPOFF 4 and NLE 2009 were both 

Tier I exercises. Tier II exercises are focused on strategy and 

policy issues supported by all appropriate departments and 

agencies. Tier III exercises focus on operational, tactical, or 

organization-specific objectives not requiring broad interagency 

headquarters-level involvement to achieve objectives. Tier IV 

exercises include state, territorial, local, or tribal governments and 

private sector entities as the primary training audience or subject of 

evaluation. 

Results of Review 

All TOPOFF 4 Corrective Actions Were Not Relevant for NLE 

2009 

As part of the National Exercise Program (NEP), emergency preparedness 

exercises attempt to build an integrated, interagency federal, state, 

territorial, local, and private sector capability to prevent terrorist attacks, 

and respond to and recover from any terrorist attack or major disaster. 

The first in a series of national preparedness exercises, TOPOFF 2000, 

simulated biological attacks in Colorado and New Hampshire. TOPOFF 2 

simulated a radiological dispersal device detonation and an outbreak of 

pneumonic plague. The exercise included pre-exercise intelligence play, a 

cyber-attack, and credible terrorism threats against other locations. 

TOPOFF 3 was a large-scale, multipoint terrorist attack using biological 

and chemical weapons. TOPOFF 4 simulated a radiological dispersal 

device detonation near a power plant. 

FEMA’s Implementation of Recommendations from Top Officials 4 

 Page 4
 
 

During the planning and conduct of NLE 2009, interagency planners were 

also engaged in planning NLE 2010, NLE 2011, and multiple Tier I and 

Tier II exercises. With these multiple events and associated planning 

meetings, concerns were expressed regarding the viability planning, 

evaluating, and incorporating lessons learned in the annual national level 

exercise. 

FEMA officials stated that for NLE 2009, planners recognized that 

TOPOFF 4 and previous national level exercises focused almost 

exclusively on response operations and law enforcement, with insufficient 

emphasis placed on prevention and intelligence activities. Therefore, 

incorporating corrective actions into subsequent exercises may not be 

relevant in most cases since they do not want to test the same capabilities 

each year. FEMA officials concluded that it would be more beneficial to 

alternate the type of threat each year to incorporate pre- and post-incident 

exercises. As a result, this would better ensure that each of the homeland 

security mission areas was tested over time. 

In preparation for NLE 2009, exercise planners agreed that a primary area 

of concern should be securing the southwest border and preventing 

terrorists from entering and attacking the United States. Because of these 

priorities, NLE 2009 focused exclusively on terrorism prevention and 

protection, as opposed to incident response and recovery, which resulted 

in different issues and objectives between TOPOFF 4 and NLE 2009. 

Exercise planners concluded that NLE 2009, as a prevention-focused 

exercise, would continue to accomplish national preparedness goals and 

objectives because of the emphasis placed on intelligence and information 

sharing that occurs in all national level exercises. 

NLE 2009 was the first major exercise exclusively dedicated to terrorism 

prevention and protection. Specifically, this exercise focused on 

preventing an adversary’s entry into the country through air, border, and 

maritime security and protecting various infrastructures and information 

through various alert and notification systems. Unlike past national level 

exercises, NLE 2009 did not have an incident response and recovery 

component, but highlighted intelligence and information sharing. 

During the planning process for NLE 2009, FEMA officials reviewed past 

exercise improvement plans to determine (1) specific deficiencies 

requiring further examination, and (2) compatibility with the overall 

terrorism prevention focus for NLE 2009. TOPOFF 4 exercise simulated 

a bomb explosion that involved responding to radiological dispersal 

device attacks. The TOPOFF 4 Improvement Plan identified 54 corrective 

actions, of which 12 pertained to radiological events, 19 pertained to 

FEMA’s Implementation of Recommendations from Top Officials 4 

 Page 5
 
recovery, 12 pertained to response, one was considered outside of 

TOPOFF 4’s scope, and ten pertained to terrorism and prevention 

protection. 

The TOPOFF 4 corrective actions incorporated into NLE 2009 were 

identified during the exercise planning phase as actions to be validated 

during the functional prevention exercise. The corrective actions include 

Emergency Operations Center management, on-site incident management, 

and public information and warning. The TOPOFF 4 corrective actions 

incorporated into NLE 2009 are listed below. 

1.	 Incorporate national scenario-based guidance into regional planning, 

training, and exercise programs such as the Regional Interagency 

Steering Committee (RISC) or the Regional Assistance Committee 

(RAC). 

2.	 Consider the use of virtual tools (such as web conferencing and chat 

rooms) to supplement National Incident Communications Conference 

Line (NICCL) calls. 

3.	 Evaluate smart practices and suggestions on information management 

identified in the After Action Report (AAR). 

4.	 Investigate information technology solutions that support e-mail 

distribution lists that can be easily modified. 

5.	 Consider mechanisms to promote cross-jurisdictional coordination by 

public affairs officials. 

6.	 Develop and promulgate written Strategic Communication Planning 

guidance; establish and exercise interagency strategic communication 

team to address national themes, effects, tasks, international 

engagement strategy, and processes and procedures. 

7.	 Review and align meeting and reporting schedules. 

8.	 Consider scope, attendance, and classification level of senior 

leadership meetings, as well as procedures for capturing and 

disseminating discussions, decisions, and taskings. 

9.	 Review and update policy documents to clarify the purpose, roles, and 

responsibilities for various private sector nongovernmental 

organizations (NGO). 

FEMA’s Implementation of Recommendations from Top Officials 4 

 Page 6
 
10. Articulate and institutionalize a process for private sector and NGO 

engagement in national-level exercises, including authority for 

planning, programming, and budgeting for national and venue working 

groups. 

FEMA officials provided the following rationale for TOPOFF 4 corrective 

actions that were incorporated in NLE 2009: 

Corrective Action 1 

This corrective action relates to the On-Site Incident Management 

capability. This capability provides the means to accomplish a mission 

and achieve desired outcomes by performing critical tasks, under specified 

conditions, to target levels of performance. 

Corrective Actions 2, 3, 4, 5 and 6 

Although the focus of NLE 2009 was intelligence and information 

sharing, the exercise provided an opportunity to validate TOPOFF 4 

corrective actions related to Public Information and Warning. 

Specifically, the exercise included interagency communication protocols 

to ensure that accurate and credible law enforcement and intelligence 

information was provided to the public. Electronic message transmissions 

and scheduled teleconferences among national, state, local and private 

sector participants facilitated information exchange. In addition, virtual 

tools, such as web conferencing and chat rooms, were a primary source of 

communication throughout the exercise. 

Corrective Actions 7 and 8 

These corrective actions relate to the Emergency Operations Center 

Management capability, and were incorporated in both the planning and 

conduct of NLE 2009. The DHS Secretary, White House staff, and other 

senior federal leaders participated in the exercise and related discussions. 

Corrective Actions 9 and 10 

These corrective actions relate to the Emergency Operations Center 

Management capability. Non-government agencies, as well as critical 

infrastructure facilities, participated in NLE 2009, with the National Joint 

Information Center serving as a focal point for coordinated and timely 

release of incident-related information to the public and media. 

All TOPOFF 4 corrective actions were not incorporated into NLE 2009 

since FEMA officials concluded that it is beneficial to alternate the type of 

FEMA’s Implementation of Recommendations from Top Officials 4 

 Page 7
 
threats and related capabilities that are exercised. However, FEMA 

officials said that other federal departments and agencies have planned or 

conducted exercises related to corrective action scenarios from TOPOFF 

4, as described in the following examples: 

•	 The Department of Energy sponsored Empire 09, a three phase 

exercise which focused on a radiological dispersal device detonation in 

an urban environment. This provided an opportunity for response 

agencies to focus on Federal Radiological Monitoring and Assessment 

Center integration, responsibilities, and reporting. 

•	 The Environmental Protection Agency sponsored Liberty RadEX 

2010, which focused on long-term recovery from a radiological 

dispersal device detonation. This exercise provided an opportunity for 

participants to focus on recovery issues. 

Barriers Exist That Hinder the Effectiveness of a Corrective 

Action Program 

A major component of exercise evaluation is the After Action Conference 

which provides an opportunity for entities that participated in an exercise 

to exchange feedback and make necessary changes to an After Action 

Report/Improvement Plan. As part of the After Action Conference, 

corrective actions are assigned to a responsible person or agency. 

The NEP Implementation Plan requires the establishment of a corrective 

action program, administered by DHS, to provide a government-wide 

process for identifying, assigning, and tracking remediation of interagency 

issues identified through exercises. Specifically, each participating 

department and agency is required to maintain a system for (1) identifying 

issues to be remedied, (2) making assignments to resolve the issues, and 

(3) tracking progress on issue resolution. The NEP Implementation Plan 

further requires that departments and agencies identify points of contact 

(POC) to oversee the implementation of corrective action plans, and 

update the CAP System on progress made towards implementing 

corrective actions. 

FEMA’s CAP System enables federal entities to access and track 

improvement plans from a single location, and ensures that lessons from 

exercises are either sustained or improved, as appropriate. However, we 

identified challenges that reduce the effectiveness of the CAP process. 

FEMA’s Implementation of Recommendations from Top Officials 4 

 Page 8
 
Even though each participating agency or department is responsible for 

tracking and implementing corrective actions, we determined that not all 

agencies and departments that participated in national level exercises have 

assigned a POC to oversee corrective action implementation, and update 

the CAP System. FEMA managers explained that more emphasis was 

placed on the actual operation of the exercises, and less emphasis on 

corrective actions needed to resolve consequence management issues 

identified during the exercises. FEMA officials added that even when a 

POC is assigned to monitor corrective actions, if that person leaves the 

department or agency, a replacement POC is often not assigned to follow 

through on corrective actions. 

FEMA is responsible for inputting initial corrective action data from 

national level exercises into the CAP System. However, tracking and 

implementing these corrective actions rests exclusively within the 

discretion of each participating agency or department, with FEMA having 

no enforcement authority. In addition, we identified no explicit statutory 

or executive authority that directs federal agencies to comply with 

corrective action implementation requirements outlined under the NEP 

Implementation Plan. 

A common framework for corrective action follow-up is necessary to 

ensure lessons from exercises are either sustained or improved, as 

appropriate. In the absence of statutory or executive requirements for 

participation in a corrective action process by all national level exercise 

participants, there is reduced assurance that needed improvements 

identified during exercises will be monitored, tracked, and implemented, 

as appropriate. 

Recommendation 

We recommend that the Director, Office of Policy and Program 

Analysis: 

Recommendation #1: Develop and implement reporting 

regulations for federal departments and agencies to assign POCs to 

oversee corrective action implementation, and update the CAP 

System on a consistent basis. This may require collaboration with 

the Exercise and Evaluation Sub-Interagency Policy Committee 

and the NEP Executive Steering Committee. 

FEMA’s Implementation of Recommendations from Top Officials 4 

 Page 9
 

Management Comments and OIG Analysis 

We evaluated FEMA’s written comments and have made changes to 

the report where we deemed appropriate. Below is FEMA’s written 

response to our recommendation and our analysis of the response. A 

copy of FEMA’s response, in its entirety, appears in Appendix B. 

FEMA Response: With regard to the recommendation, we concur 

with the importance of an oversight system and collaborative 

efforts to include the Exercise and Evaluation Sub-Interagency 

Policy Committee. We do not concur that development and 

implementation should be promulgated through a federal 

regulation, but suggest that FEMA work collaboratively with the 

White House to develop a mechanism, such as a White House 

Directive, to strengthen the process of the corrective action 

progress to include (1) making assignments to resolve issues, (2) 

tracking progress on issues resolution, and (3) identifying POCs to 

oversee the implementation of corrective action plans. As a side 

note, we are making strides regarding incorporating corrective 

actions into National Exercise Program objectives. We believe the 

revision of the National Exercise Program (currently underway) 

will standardize exercise doctrine and the corrective action process 

and strengthen the good conduct of departments and agencies 

participating in the National Exercise Program. 

OIG Evaluation: As an alternative to our recommendation for 

corrective action oversight through federal regulation, we accept 

FEMA’s suggestion to collaborate with the White House in 

developing a mechanism to strengthen corrective action progress. 

The recommendation will remain unresolved and open pending 

our receipt and review of the specific mechanism that will be 

developed to satisfy the intent of this recommendation. 

FEMA’s Implementation of Recommendations from Top Officials 4 

 Page 10
 

Appendix A 

Purpose, Scope, and Methodology 

House Report 110-862, Department of Homeland Security 

Appropriations Bill, 2009, requires that we review changes made 

by the Federal Emergency Management Agency as a result of 

problems identified through TOPOFF 4, and make 

recommendations for any further improvements that may be 

needed. Pursuant to this requirement, we determined how the 

corrective actions identified in the TOPOFF 4 exercise series were 

incorporated into the planning and execution of NLE 2009. 

We observed NLE 2009 activities from July 27 through July 31, 

2009, and attended the After Action Conference in February 2010. 

An overview of NLE 2009 results were incorporated into an After 

Action Report. FEMA officials provided us with a draft of this 

report in February 2010. As such, we continued our fieldwork 

from March to May 2010, and interviewed FEMA top officials 

responsible for the design and execution of national level 

exercises. We analyzed relevant laws, policy documents, and 

records concerning the evolution and ongoing priorities of these 

exercises. 

This review was conducted under the authority of the Inspector 

General Act of 1978, as amended, and according to the Quality 

Standards for Inspections, issued by the Council of the Inspectors 

General on Integrity and Efficiency. 

FEMA’s Implementation of Recommendations from Top Officials 4 
 

Page 11
 

l_'" 1 "-... "Ilm_,,~S«w'~)'

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~~"0"'FEMA

SEP 1 20lI

MEMORANDUM FOR: Carlton I. MIlM

Assist:,"t Ill5peaor Go:n..",.1 _ Inspections

Office of Inspector General

FROM: David J. KaufmanfJ'f.--

Director

Offiec of Poliq and Pro;ram Analysis

SUBJECT: Commen15 on OIG Draft Rcpon, FE-AlA's ImplcmCnlOlion

ofRCCJOmmc"da/lonsfrom Top Officials 4

Thank you for the opportunity to re,·icw and comment on thc Office of Inspector

Go:ncral's (OIG's) 5ubje<;1 draft audit report. Asttt<: Federal Emt...l.ocncy Management

AgCl1cy (FEMA) works toward refining its programs, ttt<: OIG's independent analysis of

program perfonnanec greatly benefits our ability to continlKlusly improve our activities.

We find the report properly identifics barriers that hinder the em.'Ct;"encss ofthe C\lrTent

Concclive Action Program with regard to National Lc,·cl E"creiSC$ (Nl..Es). In addition

to providing comments on thc findings and recommendation. wc would like to clarify one

area r"garding the corrective :.etions rclated to NLE 09. The 10 cotTttti,'c actions wt.-re

nOI radiological incident rcslX>nsc aClions as indicated in the report. but rather thcse

correcti,'c aClions wt.'I"C idcntified during thc NLE 09 planning phase as actions to be

validated during the functional prevention c"ereise. These includc Emergcncy Operations

Ccnter (EOC) managelllcm. on_sile incidcnt management. and public infomllltion and

warning. In addition. we find the subtitlc ofthe Results i1\ Rcvicw sc<:tio1\ docs not

aecurntcly reflect the summary oontcms and rc<.:ollllllend the subtitle be ch:mged from ,1I/

TOPOPF 4 Concc/in: Actio".' Were Not f"c0"lXJ/"Olelllmo Nt!:: }()O'lto ,11/ TOPOFF 4

COffcCti"c Actiolls Were No/ Rele,","'/ fOf Nt!:: }()(W Finally. we would recommend a

footnote be addcd to the section pertaining to homeland st.-curity missiun areas (page 2) to

indicate thai since TOPOFF 4 and NLE 09. a fitlh mission urea _mitigation - hns bt.'C1\

added.

Appendix B 

Management Comments to the Draft Report 

FEMA’s Implementation of Recommendations from Top Officials 4 
 

Page 12
 

Page 2

With regard to the recommendation, we concur with the importance of an oversight

system and collaborative efforts to include the Exercise and Evaluation Sub-Interagency

Policy Committee. We do not concur that development and implementation should be

promulgated through a federal regulation, but suggest that FEMA work collaboTatively

with the White House to develop a mechanism, such as a White House Directive, to

strengthen the process ofthe corrective aClion progress to include (I) making

assignments to resolve issues, (2) tracking progress on issues resolution, and (3)

identifying points of contacts (POCs) to oversee the implementation of corrective action

plans. As a side nole, we are making strides regarding incorporating corrective actions

into National Exercise Program objectives. We believe the revision ofthe National

Exercise Program, which is currently underway, will standardize exercise doctrine and

the corrective action process and strengthen the good conduct of department and agencies

participating in the National Exercise Program.

Thank you again for the opportunity to comment on this draft report and we look forward

to working with you on other issues as we both strive to improve FEMA.

Appendix B 

Management Comments to the Draft Report 

FEMA’s Implementation of Recommendations from Top Officials 4 

 Page 13
 

Appendix C 

Major Contributors 

Deborah Outten-Mills, Chief Inspector 

Jacqueline Simms, Senior Inspector 

FEMA’s Implementation of Recommendations from Top Officials 4 
 

Page 14
 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Policy 

Deputy Chief of Staff 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Administrator, FEMA 

DHS Audit Liaison 

FEMA Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

FEMA’s Implementation of Recommendations from Top Officials 4 
 

Page 15
 

ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.