FEDERAL 

EMERGENCY 

MANAGEMENT 

AGENCY

Strengthening 

Regional Coordination 

Could Enhance 

Preparedness Efforts

Report to Congressional Requesters

February 2016

GAO-16-38

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-38, a report to 

congressional requesters

February 2016

FEDERAL EMERGENCY MANAGEMENT 

AGENCY

Strengthening Regional Coordination Could Enhance 

Preparedness Efforts

Why GAO Did This Study

DHS’s FEMA is responsible for

coordinating with state, local, and tribal 

governments to prepare for disasters. 

Specifically, FEMA provides 

preparedness grants to states and 

localities, and works to implement the 

National Incident Management System 

nationwide, among other things. 

GAO was asked to review FEMA’s 

efforts to enhance coordination for 

regional preparedness. This report 

addresses the extent to which FEMA

and regional offices have (1) 

addressed preparedness grant 

management coordination challenges,

(2) established a system to assess 

NIMS implementation, and (3) 

collaborated with RAC stakeholders. 

GAO analyzed FEMA documentation 

on grant management, NIMS 

evaluation, and RACs. GAO surveyed 

RAC members, visited 4 regional 

offices selected for their geographic 

representation, spoke with state 

emergency management officials from 

10 states, and interviewed FEMA 

officials. The site visits cannot be 

generalized but provided insights.

What GAO Recommends

GAO recommended, among other 

things, that FEMA develop a plan for 

addressing long-standing coordination 

challenges with grant management, 

review after action reports to assess 

NIMS implementation, and improve 

coordination with RACs. Although DHS 

did not concur with the grants 

management recommendation, GAO 

continues to believe challenges 

documented in the report support the 

recommendation. DHS concurred with 

the other 4 recommendations and 

described the actions they planned to 

take in response.

What GAO Found

GAO found that the Department of Homeland Security’s (DHS) Federal 

Emergency Management Agency (FEMA) has taken some steps, but has not 

fully addressed, preparedness grant management coordination challenges 

between headquarters and its regions. For several preparedness grant 

programs, FEMA headquarters and regions share management and monitoring 

responsibilities. Assessments by FEMA and others since 2009 have 

recommended that FEMA regions manage and monitor preparedness grants to 

avoid confusion and duplication and strengthen coordination with state and local 

grantees. However, in 2012 FEMA changed course and decided to continue 

sharing grant management between headquarters and regions. Since then, 

FEMA officials said they are taking steps to address coordination challenges that 

exist in this structure. However, GAO found that challenges continue to exist. For 

example, states and FEMA regional officials told GAO that FEMA headquarters 

and regions did not always coordinate monitoring visits and provided inconsistent 

guidance to grantees. Further, while FEMA officials identified some steps to 

address the challenges, FEMA lacks a plan with time frames and goals for 

addressing them. Doing so will better enable FEMA to effectively address the 

long-standing challenges in managing preparedness grants. 

FEMA uses states’ self-assessments to determine if states have implemented

the National Incident Management System (NIMS), as required, but does not

assess NIMS implementation using the results of preparedness exercises. NIMS 

is a comprehensive, national approach to incident management and provides a 

framework to enable all levels of government and the private sector to work 

together to prepare for, prevent, respond to, and recover from incidents. Although 

states generally report high levels of NIMS implementation, officials from all four 

FEMA regional offices and 9 of 10 states GAO spoke with said that the NIMS 

self-assessments are perfunctory and do not measure whether, or how well, 

NIMS is being implemented. FEMA officials said they do not verify states’ selfreported NIMS implementation information because of the scope and breadth of 

the information. All of the FEMA regions and 8 states said the best way to assess 

NIMS implementation is to review states’ performance in after-action reports 

following exercises and real-world events. However FEMA officials do not review

these reports to assess NIMS implementation. Doing so could allow FEMA to 

better assess NIMS implementation and identify areas for improvement. 

All 10 FEMA regions established Regional Advisory Councils (RAC) to provide 

advice on emergency management issues specific to the region, and about 90 

percent of RAC members reported in a GAO survey that meetings are useful for

collaborating with their FEMA regional office. However, some regions do not 

routinely meet with their RACs, and some do not consistently report back to RAC 

members on the status of their recommendations to FEMA. By more routinely

obtaining input from RAC members and by providing timely feedback on 

recommendations, FEMA regional offices could better ensure they are 

coordinating with key stakeholders and identifying areas for strengthening

preparedness. View GAO-16-38. For more information, 

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

curriec@gao.gov.
Page i GAO-16-38 FEMA Regional Coordination

Letter 1

Background 5

GPD Lacks a Plan to Address Long-standing Challenges in 

Coordinating Preparedness Grants between FEMA 

Headquarters and Regions 11

FEMA Could Have Better Visibility into NIMS Implementation by 

Using the Results of Preparedness Exercises 17

Additional Opportunities Exist for FEMA Regional Offices to 

Enhance Collaboration with Regional Advisory Council 

Members 25

Conclusions 33

Recommendations for Executive Action 34

Agency Comments and Our Evaluation 35

Appendix I Objectives, Scope, and Methodology 41

Appendix II Results of GAO Survey of Federal Emergency Management Agency 

(FEMA) Regional Advisory Council Members 46

Appendix III National Incident Management System (NIMS) Implementation Questions 

Asked of States and Territories in the Unified Reporting Tool 67

Appendix IV Comments from the Department of Homeland Security 70

Appendix V GAO Contact and Staff Acknowledgments 74

Figures

Figure 1: Federal Emergency Management Agency’s 10 Regions 

and Their Member States and Territories 10

Figure 2: Number of RAC Meetings in Each FEMA Region by 

Year for 2007-August 2015 27

Contents
Page ii GAO-16-38 FEMA Regional Coordination

Abbreviations:

AAR after-action report

DHS Department of Homeland Security

DLSGP Driver’s License Security Grant Program 

EMPG Emergency Management Performance Grant 

EOC Emergency Operations Center 

FEMA Federal Emergency Management Agency

FPC federal preparedness coordinator

FY fiscal year

GPD Grant Programs Directorate

HSEEP Homeland Security Exercise and Evaluation 

Program

HSPD-5 Homeland Security Presidential Directive-5 

ICS Incident Command System 

NAC National Advisory Council

NAPA National Academy of Public Administration

NEP National Exercise Program 

NIC National Integration Center 

NIMS National Incident Management System 

NIMSCAST National Incident Management System Compliance 

Assistance Support Tool

OIG Office of Inspector General 

OMB Office of Management and Budget 

OPPA Office of Policy and Program Analysis

Post-Katrina Act Post-Katrina Emergency Management Reform Act 

of 2006

RAC Regional Advisory Council

RIG Regional Implementation of Grants

SPR State Preparedness Report

THIRA Threat and Hazard Identification and Risk 

Assessment

URT Unified Reporting Tool

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Page 1 GAO-16-38 FEMA Regional Coordination

441 G St. N.W.

Washington, DC 20548

February 4, 2016

Congressional Requesters

The Federal Emergency Management Agency (FEMA), within the 

Department of Homeland Security (DHS), through its 10 regional offices 

is responsible for coordinating government-wide disaster response efforts 

and delivery of all of FEMA’s programs and activities to state, tribal, and 

local partners; nongovernmental organizations; and citizens across the 56 

states and territories.1 According to FEMA, disaster response begins and 

ends with the affected FEMA regional office in the lead, and regional 

FEMA personnel have central roles throughout the life cycle of an 

incident.

2 We previously reported how regional coordination efforts of 

state and local stakeholders can enhance preparedness.3

FEMA regions coordinate with state and local stakeholders in various 

ways in order to strengthen national preparedness to prevent and 

respond to domestic terrorist attacks, major disasters, and other 

emergencies. For example, from fiscal years 2002 through 2015, DHS 

awarded over $40 billion to state, local, tribal and territorial grant 

recipients in preparedness grants to strengthen national preparedness 

capabilities, and FEMA’s regional offices are responsible for financial

management and, for selected programs, programmatic management of 

these grants. The regional offices also work directly with states, tribes, 

and territories to implement the National Incident Management System 

(NIMS), a standardized approach to guide emergency responders at all 

levels of government and the private sector to coordinate efforts to 

respond to incidents and save lives and property.4 All states and 

territories must agree to adopt and implement NIMS and certify their 

 1

In addition to the 50 states and the District of Columbia, the 5 territories included in 

FEMA regions are: the Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam, 

American Samoa, and the Commonwealth of the Northern Mariana Islands.

2

FEMA, Incident Management and Support Keystone, (Washington, D.C.: Jan. 2011).

3

GAO, Homeland Security: Effective Regional Coordination Can Enhance Emergency 

Preparedness, GAO-04-1009 (Washington, D.C.: Sept. 14, 2004).

4

According to FEMA officials, local jurisdictions are directed to their state, territorial, or 

tribal emergency management agency for guidance on NIMS implementation. 

Letter
Page 2 GAO-16-38 FEMA Regional Coordination

compliance with NIMS as a requirement to receive preparedness grant 

funding from FEMA.5 To enhance coordination with regional stakeholders, 

regional offices convene Regional Advisory Councils (RAC) to obtain 

insight into emergency management issues at the state and local levels.

The Post-Katrina Emergency Management Reform Act of 2006 (PostKatrina Act) was enacted to address various shortcomings in the national 

response, including federal, state, and local preparedness capabilities, 

identified in FEMA’s preparation for and response to Hurricane Katrina.6

The Post-Katrina Act included several requirements that address FEMA’s 

regional coordination with state, local, and tribal governments. For 

example, the Post-Katrina Act called for the establishment of regional 

offices that would work with state, local, and tribal governments to ensure 

effective, coordinated, and integrated regional preparedness, among 

other things.7 As part of this effort and to address grant management 

coordination challenges between headquarters and the regions, FEMA 

developed plans to transfer grant management functions from 

headquarters to the FEMA regions (regionalization). The Post-Katrina Act 

also mandated that FEMA establish a comprehensive system to assess 

compliance with NIMS, among other things,8 and required that each 

FEMA regional office establish a RAC with members from state, local and 

tribal stakeholders to advise regional administrators in each of FEMA’s 10 

regional offices on emergency management issues specific to their 

regions.9

You requested that we review FEMA’s efforts to enhance coordination for 

regional preparedness. This report assesses the extent to which FEMA 

 5

Pursuant to the Homeland Security Presidential Directive-5 (HSPD-5), all federal 

departments and agencies shall make adoption of NIMS a requirement, to the extent 

permitted by law, for providing federal preparedness assistance through grants, contracts, 

and other activities.

6

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

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

the Post-Katrina Act became effective upon enactment, October 4, 2006, with the 

exception of certain organizational changes related to FEMA, most of which took effect on 

March 31, 2007.

7

6 U.S.C. § 317(c)(2)(A).

8

6 U.S.C. § 749 (c)(1).

9

6 U.S.C. § 317(c). 
Page 3 GAO-16-38 FEMA Regional Coordination

headquarters and regional offices have (1) addressed grant management 

coordination challenges between headquarters and the regions, (2) 

established a comprehensive system to assess NIMS implementation, 

and (3) collaborated with RAC members.

To address the first objective, we gathered and reviewed relevant 

documentation, such as FEMA assessments of grant management by the 

Grant Programs Directorate (GPD), FEMA’s previous delegations of grant 

management responsibilities to regional offices, agency task force reports 

on advantages and disadvantages of regionalization, FEMA headquarters 

and regional office grant management roles and responsibilities, FEMA 

documentation on regionalization pilot programs, and other memoranda 

and internal documents. We also reviewed prior GAO reports on regional 

preparedness, grant management, and consolidation of management 

functions.10 In addition, we interviewed FEMA’s Director of the 

Preparedness Grants Division within GPD and other senior GPD officials 

to discuss programmatic grant management as well as previous FEMA 

assessments of the impact of moving management responsibilities to 

FEMA regional offices. We also interviewed grant management officials 

from 4 FEMA regional offices to discuss financial grant management and 

coordination of monitoring activities with GPD. These offices were 

selected in order to provide a mix of geographic locations and whether 

the regional office had been selected to participate in FEMA grant 

management pilot programs. Similarly, we interviewed officials from 9 

states in the 4 FEMA regions to discuss grant management within the 

states as well as interactions with FEMA grant management officials. 

These states were selected to reflect a diversity of experiences from 

FEMA regions we chose. While the information gained from these 

interviews cannot be generalized across all states, it provides useful 

insights into the nature of FEMA GPD and regional coordination with 

states with regard to grant management.

To address the second objective, we reviewed NIMS-related documents 

such as the NIMS Doctrine, NIMS Compliance Guidance, NIMS 

 10GAO, FEMA Has Made Progress in Managing Regionalization of Preparedness Grants,

GAO-11-732R (Washington, D.C.: July 29, 2011); Homeland Security: DHS Needs Better 

Project Information and Coordination among Four Overlapping Grant Programs,

GAO-12-303 (Washington, D.C.: Feb. 28, 2012); and Homeland Security: Effective 

Regional Coordination Can Enhance Emergency Preparedness, GAO-04-1009 

(Washington, D. C.: Sept. 15, 2004).
Page 4 GAO-16-38 FEMA Regional Coordination

implementation reports, and results of the NIMS implementation 

questions in the Unified Reporting Tool (URT). We also reviewed 

documents on the Homeland Security Exercise and Evaluation Program 

(HSEEP)11 and on preparedness grants requirements. We compared 

FEMA’s efforts in NIMS implementation and verification with Homeland 

Security Presidential Directive-5 (HSPD-5) and with language in OMB’s 

Circular No. A-11, regarding data validation and verification.

12 We 

interviewed officials at FEMA’s National Preparedness Directorate, which 

includes the National Integration Center (NIC)—the office responsible for 

coordinating and enabling NIMS implementation to discuss the NIC’s 

efforts in implementing NIMS. To discuss NIMS implementation efforts at 

the regional and state levels, interactions between regional and state 

officials, and mechanisms for verifying how well NIMS is being 

implemented, we also interviewed officials from the 4 FEMA regional 

offices and 9 states mentioned above. In addition, because of the 

recommendation of officials in several regional offices and states, we 

interviewed an official from a 10th state from within the selected FEMA 

regions. While the information gained from these interviews cannot be 

generalized across all regions and states, it provided useful insights into 

the various efforts in implementing NIMS. Additionally, we analyzed all 35 

full-scale exercise after-action reports (AAR) that FEMA received for 

exercises conducted during fiscal year 2014 in the 4 regions we visited. 

The purpose of the analysis was to determine if they could be used to 

assess the level of participants’ implementation of NIMS. While the 

results of these exercises are not generalizable to the country as a whole, 

they do provide useful insights into their possible use to assess NIMS 

implementation.

To address the third objective—to assess regional offices’ collaboration 

with RAC members—we interviewed officials at FEMA headquarters with 

responsibilities for regional operations and regional office officials from 

the 4 regions we visited. We also reviewed FEMA and DHS Office of

Inspector General (OIG) reports with information and findings relevant to 

RACs. In addition, we contacted FEMA RAC liaisons from all 10 regions 

by e-mail to obtain information about their RACs and RAC members. We 

 11HSEEP provides a set of guiding principles for exercise program management, design 

and development, conduct, evaluation, and improvement planning.

12OMB, Circular No. A-11, Preparation, Submission, and Execution of the Budget

(Washington, D.C.: Aug. 3, 2012).
Page 5 GAO-16-38 FEMA Regional Coordination

attended two RAC meetings in two regions that took place during the 

early part of our review, and obtained documentation of agendas and 

other relevant materials for the RACs in all 10 FEMA regions. In addition, 

we conducted a self-administered web-based survey from May 27 

through June 29, 2015 of 110 RAC members FEMA identified as active 

from all 10 regions and 77 responded, for a response rate of 70 percent.13

For further information on our survey, see appendix I; for the survey 

questions and results, see appendix II. We also used information 

obtained from interviews with FEMA headquarters and regional office 

officials involved in communicating and collaborating with RACs. Further 

details on our objectives, scope, and methodology are contained in 

appendix I.

We conducted this performance audit from October 2014 to February

2016 in accordance with generally accepted government auditing 

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

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

FEMA preparedness grant management is composed of different financial 

and programmatic management functions. FEMA created GPD in April 

2007, to consolidate oversight of all FEMA grants. GPD, in FEMA 

headquarters, provides subject matter expertise in response to regional 

office and stakeholder inquiries; develops grant guidance; and delivers 

policy, training, and systems and data analysis. The 10 FEMA regions are 

responsible for financial monitoring, implementing corrective action plans, 

as well as other follow-up activities with grantees. Financial management 

functions include monitoring grantee expenditures, amending financial 

terms of grants, and closing out grants.14 Program management includes 

 13Three respondents answered an initial screening question that they were no longer 

members of the RAC in their region, which left a total of 74 respondents with usable 

questionnaires.

14Cash management analysis includes review of grantee-submitted quarterly Federal 

Financial Reports following grant program specifications.

Background

Preparedness Grant 

Management
Page 6 GAO-16-38 FEMA Regional Coordination

developing grant application packages creating program standards, and 

monitoring grantee activities to ensure alignment with homeland security 

strategies.

FEMA’s regional offices have program management responsibility for 

various legacy programs primarily because they managed those 

programs prior to the establishment of GPD. The largest of these legacy 

programs is the Emergency Management Performance Grant (EMPG), 

which provided over $350 million in fiscal year 2015 to assist local, tribal, 

territorial, and state governments in enhancing and sustaining all-hazards 

emergency management capabilities. GPD has management 

responsibility for the Homeland Security Grant Program,15 which provides 

more than $1 billion annually to help strengthen the nation against risks 

associated with acts of terrorism and other catastrophic events.16

FEMA works with state and local stakeholders to implement NIMS, a 

comprehensive, national approach to incident management that is 

applicable at all jurisdictional levels and across functional disciplines and 

the full spectrum of potential incidents, hazards, and impacts, regardless 

of size, location, or complexity. DHS established NIMS in 2004 to improve 

coordination and cooperation between public and private entities in a 

variety of incident management activities and provide a common standard 

for overall incident management.17 NIMS implementation consists of 

training,

18 using a standardized way of defining and categorizing 

 15The Homeland Security Grant Program includes Urban Area Security Initiative grants, 

the State Homeland Security Grant program, and Operation Stonegarden.

16GPD also manages the Assistance to Firefighters Grant Program, the Port Security 

Grant Program, the Transit Security Grant Program, the Tribal Homeland Security Grant 

Program, and the Nonprofit Security Grant Program.

17DHS issued NIMS guidance in March 2004 in response to Homeland Security 

Presidential Directive (HSPD)-5: Management of Domestic Incidents, and issued an 

updated version in 2008.

18NIMS training is intended for all personnel who are directly involved in emergency 

management and response. This includes all emergency services-related disciplines such 

as Emergency Medical Services, hospitals, public health, fire service, law enforcement, 

public works/utilities, skilled support personnel, and other emergency management 

response, support and volunteer personnel. This training is intended to aid people who do 

not usually work together or even know each other to seamlessly respond to and recover 

from a disaster either natural or man-made.

National Incident 

Management System
Page 7 GAO-16-38 FEMA Regional Coordination

emergency resources known as resource typing,

19 and incorporating a 

standardized organizational emergency response structure called the 

Incident Command System into emergency management plans, policies 

and procedures, among other things.20 States, tribes, and local 

jurisdictions are required to adopt and self-assess their level of NIMS 

implementation, and certify their compliance and report it to FEMA 

through the URT in order to receive preparedness grant funding from 

FEMA.21 Additionally, states receiving preparedness grants are required 

to develop and maintain an exercise program consistent to the degree 

practical with HSEEP in support of the National Exercise Program.22

HSEEP exercises identify exercise objectives and align them to FEMA’s 

32 “core capabilities” for evaluation during the exercise. In order to report 

on the required exercises, states receiving preparedness grants are 

required to prepare after-action reports—evaluations of performance—on

core capabilities assessed in the exercise, and to submit those to FEMA.

FEMA established the NIC in 2004. The NIC, a division of FEMA’s 

National Preparedness Directorate, is responsible for the ongoing 

management and maintenance of NIMS, including developing guidance 

to define and categorize the resources and job position qualifications 

requested, deployed, and used in incidents. Specifically, the NIC is to 

coordinate with state and local stakeholders to develop national 

standards, guidelines, and protocols for incident management.

 19Resource typing is defining and categorizing, by capability, the resources requested, 

deployed, and used in incidents. Resource typing definitions establish a common 

language and defines a resource’s (for equipment, teams, and units) minimum 

capabilities. NIMS resource typing definitions serve as the common language for the 

mobilization of resources.

20The Incident Command System is a management system designed to enable effective 

and efficient domestic incident management by integrating a combination of facilities, 

equipment, personnel, procedures, and communications operating within a common 

organizational structure. 

21HSPD-5 states: “Beginning in Fiscal Year 2005, Federal departments and agencies shall 

make adoption of the NIMS a requirement, to the extent permitted by law, for providing 

Federal preparedness assistance through grants, contracts, or other activities. The 

Secretary shall develop standards and guidelines for determining whether a State or local 

entity has adopted the NIMS.”

22Department of Homeland Security Notice of Funding Opportunity: Fiscal Year 2015 

Emergency Management Performance Grant Program.
Page 8 GAO-16-38 FEMA Regional Coordination

In 2008, FEMA established new regional positions for federal 

preparedness coordinators (FPC), who direct and coordinate the activities 

of each regional national preparedness division to ensure regional 

implementation of national preparedness programs, policies, goals, and 

objectives. FPCs are to evaluate preparedness program activities to 

assess their effectiveness; changes in risk or capability; and the 

performance of preparedness program activities including after-action 

reports, training evaluations, lessons learned, and corrective actions. For 

example, FPCs are responsible for monitoring NIMS compliance and 

implementation, in addition to other national preparedness initiatives. 

Further, FPCs are to proactively engage stakeholders and acquire an 

understanding of their preparedness efforts and also assist in the 

planning, design, execution, and evaluation of federal, state, local, and 

regional exercises. FEMA regional NIMS coordinators act as subject 

matter experts regarding NIMS for the local, state, territorial, and tribal 

nation governments within their FEMA regions, as well as for the FEMA 

regional administrator and staff.

The Post-Katrina Act requires that each FEMA regional administrator 

establish a RAC with members from state, local, and tribal entities to 

provide advice on emergency management issues specific to the 

region.23 While the Post-Katrina Act does not specify how many members 

a RAC should have, the law states that a state, local, or tribal government 

located within the geographic area served by the regional office may 

nominate officials, including emergency managers, to serve as members. 

Each of the 10 FEMA regional offices established a RAC after the PostKatrina Act was enacted in 2006. In August 2011, FEMA developed a 

RAC charter template that each of the regional offices voluntarily 

adopted; the charters require that RACs meet twice annually in order to 

 236 U.S.C. § 317(e). The Post-Katrina Act also calls for the RACs to identify any 

geographic, demographic, or other characteristics peculiar to any state, local, or tribal 

government within that region that might make preparedness, protection, response, 

recovery, or mitigation more complicated or difficult. In addition, the RACs are to advise 

the regional administrator about weaknesses or deficiencies in preparedness, protection, 

response, recovery, and mitigation for state, local, and tribal government within the region 

of which the RAC is aware.

Regional Advisory 

Councils
Page 9 GAO-16-38 FEMA Regional Coordination

provide the types of advice on emergency preparedness in their regions 

to the FEMA regional administrators listed in the Post-Katrina Act.24

In addition to the RACs, the Post-Katrina Act also required that FEMA 

establish the National Advisory Council (NAC) to ensure effective and 

ongoing coordination of federal preparedness efforts, among other 

things.25 The NAC advises the FEMA Administrator on all aspects of 

emergency management, and incorporates state, local, and tribal 

governments; nonprofit; and private sector input in the development and 

revision of the National Preparedness Goal, the National Preparedness 

System, the National Incident Management System, and other related 

plans and strategies.

FEMA’s 10 regional offices are the principal conduit for delivery of 

preparedness programs and activities to state, tribal, and local partners; 

non-governmental organizations; the private sector; and citizens. Such 

preparedness activities include, among other things, stakeholder 

coordination and information sharing, consulting, planning support, 

capability assessments and reporting, exercise performance and 

evaluation, and internal and external training. Figure 1 shows FEMA’s 10 

regions and the states and territories that compose each region (the 

District of Columbia is in Region III).

 24The RACs may add language or make other changes to the general template, such as 

with regard to the term length of service for RAC members. In 1 region, the RAC added 

language to the template to specify the number of RAC members to be appointed from 

separate levels of government and occupations.

253 U.S.C. § 318.
Page 10 GAO-16-38 FEMA Regional Coordination

Figure 1: Federal Emergency Management Agency’s 10 Regions and Their Member States and Territories
Page 11 GAO-16-38 FEMA Regional Coordination

Currently FEMA uses a hybrid management model for preparedness 

grant programs, with shared responsibilities between headquarters and 

the regions.26 In October 2009, in response to a congressional request, 

the National Academy of Public Administration (NAPA) conducted a study 

and recommended that FEMA transfer all preparedness grant authorities 

to its regional offices.27 Similarly, in May 2010, FEMA’s Office of Policy 

and Program Analysis (OPPA) reported that FEMA’s hybrid grants 

management model created significant inconsistencies in managing 

preparedness grants, and recommended that programmatic management 

functions for preparedness grants should be transferred to the regional 

offices.28 In September 2010, GPD’s Regional Implementation of Grants 

(RIG) task force also reported that programmatic grant management 

functions for grants should be moved to the 10 regional offices, because 

of considerations of customer service, efficiency, people, processes, and 

 26In the hybrid management model, FEMA headquarters has responsibility for grant 

management functions such as budget review, award approval, and site visits, whereas 

FEMA regions have responsibility for financial monitoring, cash management analysis, 

and audit resolution.

27National Academy of Public Administration, FEMA’S Integration of Preparedness and 

Development of Robust Regional Offices, An Independent Assessment for the U.S. 

Congress and the Federal Emergency Management Agency (Washington, D.C.: Oct. 

2009). 

28According to FEMA, OPPA supports the Administrator in agency-wide management 

efforts and “fosters strategic coherence; ensures availability of critical resources; leads 

Agency policy, strategy, and innovation; provides objective analysis; drives strategy, 

budget, execution, performance integration and accountability.”

GPD Lacks a Plan to 

Address Longstanding Challenges 

in Coordinating 

Preparedness Grants 

between FEMA 

Headquarters and 

Regions

Past Assessments 

Supported Moving Grant 

Management Functions to 

the Regions to Address 

Oversight and 

Coordination Problems, 

but FEMA Decided Not to 

Change Its Approach
Page 12 GAO-16-38 FEMA Regional Coordination

systems.29 In July 2011, we reported that GPD’s efforts to regionalize 

management responsibilities for preparedness grants were consistent 

with internal control standards.30 On the basis of the results of our review 

of FEMA’s plans and efforts to regionalize grant management functions, 

we did not make recommendations at that time.

FEMA’s Deputy Administrator for Protection and National Preparedness, 

in consultation with FEMA’s Administrator, decided in early 2012 against 

pursuing further regionalization of grant management functions, according 

to FEMA’s Assistant Administrator for Grant Programs. The Assistant 

Administrator said their decision was based on, among other things, 

estimates that the costs of regionalization would be greater than the 

annual savings identified in the earlier OPPA study and FEMA 

management’s belief that risks associated with the change, such as 

inconsistent program implementation across the regions, outweighed the 

potential benefits. As a result, FEMA continues to use its hybrid 

management model for preparedness grant programs, with shared 

responsibilities between headquarters and the regions.

Long-standing challenges associated with the separation of management 

functions under the hybrid model of grant management, including the lack 

of coordination of grant-monitoring visits, and coordination and 

implementation of guidance provided by headquarters officials to state 

officials, continue to create challenges.

In 2010, GPD’s RIG task force report cited examples of how 

programmatic and financial monitoring visits, conducted by FEMA GPD 

 29FEMA, Regional Implementation of Grants Task Force Workshop Outcomes,

(Washington, D.C.: Sept. 2, 2010). The Regional Implementation of Grants task force 

composed of FEMA officials in headquarters and regional offices as well as state, local, 

and port grantees assessed advantages and disadvantages of management functions 

located in FEMA headquarters or the regions based on resources, training, and 

processes.

30GAO, FEMA Has Made Progress in Managing Regionalization of Preparedness Grants,

GAO-11-732R, (Washington, D.C.: July 29, 2011). We reported, for example, that FEMA 

established a task force as an oversight and evaluation mechanism and developed an 

implementation plan, which includes a phased approach to piloting and delegating specific 

grants administration functions for preparedness grants to the regions and delineates an 

approach, including roles and responsibilities, for key implementation activities such as 

training and communications.

FEMA Regional Offices 

and Grantees Identified 

Challenges with FEMA’s 

Hybrid Management 

Model
Page 13 GAO-16-38 FEMA Regional Coordination

staff and regional offices respectively, occurred independently of one 

another and were disruptive to the state emergency management 

agency’s day-to-day operations.31 In response to the lack of coordination 

in monitoring site visits, GPD’s Deputy Assistant Administrator sent a 

memorandum to staff in 2011 citing concerns that it had become 

“apparent GPD HQ staff continue to do program monitoring visits without 

proper notification to the regional offices” and directing that headquarters 

personnel conduct all monitoring visits in conjunction with regional staff, 

changing the dates of any planned headquarters visits to accommodate 

regional staff schedules. While the memorandum called for disciplinary 

action against any GPD personnel who did not follow the directive, GPD 

officials did not identify any instances where disciplinary action had been 

taken.

We also found challenges in the coordination of site visits. Officials in 3 of 

9 states we talked with on grants issues stated that monitoring visits from 

FEMA GPD and the regional offices do not appear to be well coordinated. 

For example, officials in 1 state said that in September 2014, GPD and 

regional grants staff conducted site visits during the same week; however, 

neither the GPD staff nor the regional staff knew that the other was 

conducting a monitoring visit that week. The state officials stated that they 

had to leave one monitoring meeting early to go to another monitoring 

meeting by a different group of grant management staff. Similarly, 

regional grants officials in 2 of the 4 regions we visited said in 2015 that 

they may or may not receive information on monitoring activities 

undertaken by GPD officials, depending on who is conducting the 

monitoring activities. A grant official in 1 region we visited stated that GPD 

conducted a site monitoring visit as recently as September 2015, but did 

not inform regional staff of this visit. Regional grants management officials 

in all 4 regions we visited stated that not having the results of 

programmatic monitoring creates challenges in financial monitoring. For 

example, financial monitoring may identify a significant drawdown of grant 

funds; however, without program information, regions cannot determine if 

this corresponds to significant progress in program implementation.

Further, challenges related to coordination and implementation of 

guidance provided by GPD (headquarters) officials, FEMA regional 

officials, and state officials has been a long-standing problem. For 

 31FEMA, Regional Implementation of Grants Task Force Workshop Outcomes.
Page 14 GAO-16-38 FEMA Regional Coordination

example, in 2009, NAPA identified regional challenges associated with 

assessment activities including grant monitoring, noting that FEMA 

regional and headquarters units “need to reduce burden on states and 

ensure assessments-requirements are coordinated among FEMA 

divisions and the federal sector” and that new documents from FEMA 

headquarters “typically have a short review and comment period, and 

adherence is often required prior to finalization.”32 Similarly, the May 2010 

RIG Task Force Report noted that “the timeliness of communication and 

information distribution with the grantee community needs to be 

improved” and the need to “formally establish regional liaisons to support 

the consistent prioritization of communication within GPD and with 

grantees.”33

We found that these issues related to coordinating guidance provided by 

headquarters officials to state officials continue to create challenges. 

Officials from all 4 FEMA regions we visited said that GPD officials had 

provided guidance to state grantees that contradicted guidance given by 

the regional staff. Further, officials in 2 of the 4 regional offices we visited 

stated that incorrect guidance given by GPD officials to state grantees 

resulted in deficiencies during financial monitoring conducted by regional 

grants personnel. Specifically, according to FEMA grant management 

officials in 1 region, a grantee, at the advice of GPD officials, shifted funds 

from one grant program into other grant programs, but regional grants 

personnel later found, as part of their financial monitoring, that this was a 

violation of regulations and required that the funding be returned. 

Similarly, FEMA grant officials in another region stated that a new grantee 

that received transit grants drew down the entire grant amount soon after 

the grant was awarded, which is a violation of FEMA grant management 

regulations. Regional officials asked the grantee to return the funds; 

however, the grantee stated that GPD officials had told him he could draw 

down these funds. Regional officials added that had the grantee not 

returned the funds, the next step would have been to do an official 

collection; however, regional offices do not have the authority to do this 

because the grant program is managed from FEMA headquarters by 

GPD. Officials from 3 of the 9 states we visited told us that they had 

received contradictory information from regional staff and GPD staff 

regarding the management of grant programs.

 32National Academy of Public Administration, (Washington, D.C.: Oct. 2009). 

33Regional Implementation of Grants Task Force Workshop Outcomes.
Page 15 GAO-16-38 FEMA Regional Coordination

GPD officials agreed that there were continuing opportunities to improve 

coordination and communications in their management of preparedness 

grants and said that FEMA had taken steps during the course of our 

review to facilitate coordination and communication. For example, GPD 

officials said that they had taken steps to improve coordination of site 

visits and that, beginning in fiscal year 2013, GPD made integrated 

financial and programmatic monitoring a priority, and incorporated this 

into its monitoring plans. According to FEMA’s fiscal year 2014 grants 

monitoring plan, GPD officials are to contact regional grant staff when 

monitoring activities are initiated and document this interaction. GPD 

officials did not provide any documentation that such coordination had 

occurred. Nonetheless, they identified two joint GPD and regional office 

monitoring visits that took place during the summer of 2015 (at the 

request of the regions).

GPD officials also noted that, in a February 2015 meeting with regional 

officials, GPD and the regional offices agreed to the following:

• elevate grant-related issues to regional administrators and to the 

Assistant Administrator for Grant Programs,

• provide regional grants staff visibility on programmatic grant reviews 

performed by GPD staff,

• conduct desk reviews in coordination with the regions and provide 

copies of the final reports to the regional offices,

• provide GPD’s annual monitoring plan to the regional offices and 

conduct joint monitoring of the same states for programmatic and 

financial issues when possible,

• provide quarterly analytical reports of grant-monitoring-related issues 

to all regional offices, and

• schedule regular calls between GPD management and regional 

grants division directors.

These most recent efforts to improve coordination of preparedness grant 

management functions are not significantly different from the historical 

efforts GPD has taken. For example, GPD cited monthly coordination 

calls between GPD and the regional offices as a coordinating effort meant 

to address challenges we identified. However, FEMA also cited these 

calls as a coordination mechanism in 2012 and noted that these calls had 

been a recurring effort since 2008. Similarly, providing copies of GPD’s 
Page 16 GAO-16-38 FEMA Regional Coordination

annual monitoring plan and copies of reviews performed by GPD do not 

appear to have resolved the underlying challenges associated with GPD’s 

hybrid grants management model.

GPD officials also said they intend to look at FEMA’s overall grants 

monitoring efforts to see what can be done to improve the program for 

fiscal years 2016 and beyond, including risk assessments, general 

assessments, on-site desk reviews, reports with real-time data and 

metrics, and corrective action plans. However, FEMA has not developed 

a plan with time frames, goals, metrics, or milestones for how and when it 

will address long-standing coordination challenges associated with the 

existing hybrid grants management model identified in previous FEMA 

assessments and in our review. According to FEMA’s Assistant 

Administrator, GPD has involved the regions in performance measure 

development since September 2011 and has communicated the 

measures and results to the regions. These performance measures 

include, among other things, percentage of preparedness grant funds 

monitored and percentage of grants award determined to be low risk. 

However, these performance measures do not address the deficiencies in 

coordination identified in our review.

According to effective program management practices, specific goals and 

objectives should be conceptualized, defined, and documented in the 

planning process, along with the appropriate steps, time frames, and 

milestones needed to achieve those results.34 Given the longstanding 

coordination challenges, establishing a plan with time frames, goals, 

metrics, and milestones could help FEMA headquarters and regional 

offices address these challenges.

 34Project Management Institute, Inc., A Guide to the Project Management Body of 

Knowledge.
Page 17 GAO-16-38 FEMA Regional Coordination

The NIC uses a self-assessment tool to determine if all states and 

territories have adopted and implemented NIMS elements into their 

emergency response planning and training. The NIC relies on a selfassessment tool, as the Post-Katrina Act requires that FEMA develop an 

assessment system to determine compliance with NIMS but does not 

require that FEMA physically verify compliance. Since 2005, all 56 states 

and territories have been required to meet NIMS compliance and 

implementation requirements to be eligible to receive federal 

preparedness grants. The NIC began using the latest version of its tool 

for states to submit self-assessments—the URT—in 2013.35 In the URT 

spreadsheet, states and territories fill in responses to a series of 

questions aimed at determining the level of NIMS implementation.36

Generally, states and territories gather this information from their 

subjurisdictions and consolidate the information at a state level to report 

to FEMA.37 (For a list of questions, see app. III.)

 35Prior to 2013, FEMA used a web-based self-assessment instrument called the National 

Incident Management System Compliance Assistance Support Tool (NIMSCAST). 

According to FEMA officials, FEMA stopped using NIMSCAST in 2012 because of 

technical challenges and budget constraints. 

36FEMA also uses the URT to collect states’ Threat and Hazard Identification and Risk 

Assessments (THIRA) and the State Preparedness Reports (SPR). FEMA added NIMS 

compliance questions to the SPR section of the tool in 2014. FEMA started with 10 NIMS 

implementation assessment questions in the URT in fiscal year 2013 and increased the 

number to 16 questions in fiscal year 2015.

37A subjurisdiction is a geographical subdivision of a jurisdiction that provides input on its 

local threats/hazards and capability levels to its parent jurisdiction. The subjurisdictional 

level varies from one state to another. For example, some states use counties as 

subjurisdictions, but may also include tribes or large urban areas as subjurisdictions. 

FEMA Could Have 

Better Visibility into 

NIMS Implementation 

by Using the Results 

of Preparedness 

Exercises

The NIC Relies on States’

Self-assessments to 

Determine NIMS 

Implementation
Page 18 GAO-16-38 FEMA Regional Coordination

Although states generally report high levels of NIMS implementation in 

their URTs, officials from all four FEMA regional offices we spoke with 

and from 9 of the 10 states we spoke with said that the NIMS selfassessments are perfunctory and do not necessarily measure whether, or 

how well, NIMS is being implemented. For example, in fiscal year 2013, 

100 percent of the states and territories reported having “formally 

adopted” NIMS, and incorporated NIMS principles and concepts into 

training and exercises.38 Similarly, in fiscal year 2014, states and 

territories reported that 93 percent of their subjurisdictions had formally 

adopted NIMS, about 91 percent had incorporated NIMS concepts and 

principles into training, and about 93 percent incorporated NIMS into 

exercises.39 FEMA regional and state officials we spoke with said there is 

an incentive to report compliance with NIMS regardless of the actual 

status of implementation since it is a requirement for receiving 

preparedness grants. According to preparedness grant guidance, there is 

no requirement for states to verify NIMS compliance or implementation at 

the subjurisdiction level. However, of the states we spoke with on NIMS 

implementation, 1 had implemented its own NIMS compliance check 

program. Specifically, a state emergency management official in 1 state 

we spoke with said that his state has initiated its own reviews of NIMS 

implementation and found that some reporting of full NIMS 

implementation by subjurisdictions were questionable. For example, in 

one subjurisdiction, state officials found the following:

• The subjurisdiction could not produce training records to show that 

emergency management personnel had received NIMS training.

• The requirement to incorporate NIMS principles into the 

subjurisdiction’s emergency operations plans had not been 

completed.

 38To formally adopt NIMS means that a state, territory, tribe, or local entity has established 

legislation, executive orders, resolutions, ordinances, or other formal action to adopt the 

NIMS.

39The percentage of states reporting adoption of NIMS and incorporation into training and 

exercises in fiscal year 2014 is lower because FEMA changed the questions in 2014 to 

focus on implementation of NIMS on the subjurisdiction level rather than the overall state 

or territory level. 

Federal Emergency Management Agency 

(FEMA) identified six National Incident 

Management System (NIMS) elements that 

should be incorporated into training and 

exercises. These are

1. interoperable and compatible 

communications, technology, and 

information management;

2. resource management, typing, and 

credentialing;

3. mutual aid or assistance agreements;

4. Incident Command System;

5. multiagency coordination systems; and

6. public information.

Source: FEMA Unified Reporting Tool.  GAO-16-38
Page 19 GAO-16-38 FEMA Regional Coordination

• There were no records of exercises or corrective action plans 

available to identify if NIMS had been incorporated into the 

subjurisdiction’s exercise program.

While this particular example cannot be generalized to other states, it 

shows that in some cases, subjurisdictions within one state with a NIMS 

compliance check program are reporting levels of NIMS implementation 

that may not fully reflect the status of local NIMS efforts.

Officials from all 4 regional offices and from 8 of the 10 states we spoke 

with said that the best way to assess how well NIMS has been 

implemented is by assessing states’ performance in preparedness 

exercises and real-world events. They all agreed that if NIMS principles 

have been well implemented, responses to disasters will be more 

effective because the objective of NIMS is to ensure that all levels of 

government across the nation work together efficiently and effectively 

using a single, national approach to an incident. Further, according to the 

NIMS doctrine, using a comprehensive national approach improves the 

effectiveness of emergency management personnel’s responses to the 

full spectrum of potential incidents and hazard scenarios, including 

natural hazards, terrorist activities, and other manmade disasters. To 

capture information on states’ performance during preparedness 

exercises and real-world events, states generally develop after-action 

reports. The EMPG grant program, under which all states and territories 

receive funding, specifically requires participants to develop and maintain 

an exercise program, consistent to the degree practical with HSEEP in 

support of the National Exercise Program,40 and to conduct preparedness 

exercises and submit AARs that evaluate the state or territory’s 

performance during the exercises based on one or more core 

capabilities.41 Under HSEEP—which provides a common approach to 

designing, developing, conducting, and evaluating exercises—planners 

 40The purpose of the program is to design, coordinate, conduct, and evaluate exercises 

that test the United States’ ability to perform missions and functions that prevent, protect 

against, respond to, recover from, and mitigate all hazards. 

41All states receive annual Emergency Management Performance Grants that require that 

states conduct at least five exercises annually and submit AARs to FEMA. Generally, 

exercises are structured to test one or more core capability. According to HSEEP 

guidance, an AAR should include an overview of performance related to each exercise 

objective and associated core capabilities, while highlighting strengths and areas for 

improvement.

Existing Assessments 

after Exercises and RealWorld Events Provide a 

Means of Further 

Assessing States’ Selfreporting on NIMS 

Implementation
Page 20 GAO-16-38 FEMA Regional Coordination

identify exercise objectives and align them to core capabilities.42 In some 

cases, the exercise objectives test one or more of the NIMS elements 

identified by FEMA that should be incorporated into training. As such, 

exercises could also allow for identifying areas of needed improvement in 

NIMS implementation, one of the legislative bases for establishing the 

National Exercise Program.

43

FEMA regional officials we spoke with stated that some of FEMA’s 

national core capabilities are good proxies for how well NIMS is being 

implemented, and that AARs—which states submit to the National 

Exercise Division—can provide insight into the level of NIMS 

implementation when certain of these core capabilities are assessed.44

NIC officials stated if an exercise objective includes testing an element of 

NIMS, then it is possible to assess NIMS implementation. For example, 

evaluating a state’s performance related to the core capability of 

operational coordination could include as an exercise objective to 

evaluate the command and control of an incident according to NIMS 

principles.45 Similarly, the core capability for operational communications 

could provide an assessment related to the NIMS elements for 

interoperability of compatible communications, technology, and 

information management.46

 42Exercise objectives are distinct outcomes that an organization wishes to achieve during 

an exercise and should be specific, measurable, achievable, relevant, and time-bound. 

According to the HSEEP guidance, aligning exercise objectives to a common set of 

capabilities enables systematic tracking of progress over the course of exercise programs 

and cycles, standardized exercise data collection to inform preparedness assessments, 

and fulfillment of grant or funding-specific reporting requirements. 

43The National Exercise Program was established by 6 U.S.C. § 748(b)(1) in order to, 

among other things, test and evaluate NIMS.

44The core capabilities are the 32 distinct critical elements needed to achieve the National 

Preparedness Goal. The capabilities include, among others, planning, operational 

coordination, cybersecurity, critical transportation, and fatality management services.

45Operational coordination is the capability to establish and maintain a unified and 

coordinated operational structure and process that appropriately integrates all critical 

stakeholders and supports the execution of core capabilities. The 2014 and 2015 URT 

used the NIMS implementation questions as an assessment of operational coordination 

for the State Preparedness Report. 

46Operational communication is the capability to ensure the capacity for timely 

communications in support of security, situational awareness, and operations by any and 

all means available, among and between affected communities in the impact area and all 

response forces. 
Page 21 GAO-16-38 FEMA Regional Coordination

We analyzed AARs for 35 full-scale exercises that were conducted in 

fiscal year 2014 in 4 FEMA regions, 33 of which assessed at least one, if 

not two or all three, of the core capabilities we identified as proxies for 

NIMS elements—operational coordination, operational communication, 

and public information and warning.47 Of the 35 reports we reviewed, 30 

assessed operational coordination, 22 assessed operational 

communication, and 12 assessed public information and warning. 

Generally, for the capabilities assessed, the AARs identified strengths as 

well as issues and challenges in performing related activities and tasks.48

Specifically, 24 of the 30 exercises that assessed operational 

coordination, 21 of the 22 exercises that assessed operational 

communication, and 8 of the 12 exercises that assessed public 

information and warning identified areas for improvement with those 

capabilities. While exercises are meant to assess the ability to meet 

exercise objectives by documenting strengths, areas for improvement, 

core capability performance, and corrective actions in an AAR, some of 

the AARs documented problems with NIMS-related exercise objectives, 

indicating that there is room for improvement in NIMS implementation. 

For example, four of the AARs found that an Incident Command System 

(ICS) was not established among responding agencies, even though 

NIMS calls for using such a structure. Similarly, another AAR concluded 

that responding staff were unfamiliar with their position-specific roles and 

responsibilities, even though NIMS calls for emergency management and 

response personnel to have a clear understanding of their roles and 

responsibilities. The report noted that the staff displayed difficulty in 

monitoring, gathering, receiving, organizing, and sharing incident 

information—all activities that implementation of NIMS is designed to 

facilitate. Another exercise evaluating operational communication found 

that there was no communication among the different law enforcement 

agencies and officers during the exercise. These examples demonstrate 

 47Public information and warning is the capability to deliver coordinated, prompt, reliable, 

and actionable information to the whole community through the use of clear, consistent, 

accessible, and culturally and linguistically appropriate methods to effectively relay 

information regarding any threat or hazard and, as appropriate, the actions being taken 

and the assistance being made available. While we used these three core capabilities for 

the purposes of our analysis, there are other core capabilities that could provide 

information on NIMS implementation. For example, according to NIC officials, some NIMS 

elements could be addressed through the core capability of situational awareness. 

48According to FEMA, exercises are designed to provide an objective assessment of gaps 

and shortfalls within plans, policies, and procedures to address areas for improvement 

prior to a real-world incident.
Page 22 GAO-16-38 FEMA Regional Coordination

that AARs can provide a basis for FEMA to develop a more 

comprehensive and sophisticated understanding of states’ NIMS 

implementation, and suggests that there is room for improvement in NIMS 

implementation for some jurisdictions.

NIC officials said they do not verify the self-reported NIMS 

implementation information that states submit because of the scope and 

breadth of the information. However, in reviewing AARs to help inform 

FEMA’s understanding of NIMS implementation, FEMA regional office 

staff could be in a better position to assess how well states have actually 

implemented NIMS, as regional staff have more direct responsibilities 

related to states’ NIMS implementation. Specifically, FPCs—who lead 

regional efforts to implement the National Preparedness System across 

the federal, state, tribal, and local jurisdictional levels—are responsible for 

monitoring NIMS compliance and implementation. FPCs are also 

responsible for assisting in planning, design, execution, and evaluation of 

exercises. In addition, each regional office has a NIMS coordinator who is 

responsible for working with states to provide NIMS information and 

technical assistance to support, facilitate, and enhance their 

implementation of NIMS. One FPC stated that officials in his region 

review state AARs within the region to identify needed corrective actions 

that could be taken by states. Similarly, one regional NIMS coordinator 

developed a checklist to perform NIMS implementation state monitoring 

visits and said he visits 2 states each year in his region to ask questions 

about implementation of various NIMS principles and provide assistance. 

However, while some of these officials have taken independent steps to 

assess some level of NIMS implementation, the regional offices we spoke 

with do not systematically assess states’ level of NIMS implementation 

by, for example, reviewing AARs because there are no policies or 

procedures that call for these activities. Specifically, while states are to 

submit AARs to FEMA’s National Exercises Division,49 and to the regional 

EMPG Program Manager, as a requirement for receiving EMPG grants, 

FPCs and NIMS coordinators are not required to review them to provide 

validation of the NIC’s NIMS implementation assessment.

FEMA regional office officials we spoke with, along with several state 

emergency management officials, agreed that assessing NIMS 

implementation using AARs could provide FEMA a way to further assess 

 49FEMA’s National Exercise Division oversees the National Exercise Program. 
Page 23 GAO-16-38 FEMA Regional Coordination

and elaborate on the information states and territories currently provide. 

For example, the National Exercise Division, another division within the 

National Preparedness Directorate, conducted an assessment of NIMS in 

2013 by reviewing AARs and found that failures in NIMS performance 

were predominantly due to failures in implementation of NIMS. The report 

recommended, among other things, that the agency modify existing 

training and exercises to allow responders to integrate NIMS concepts 

and improve assessments of the ICS (as a component of NIMS 

performance) by incorporating relevant principles as criteria of 

performance.50 According to a NIC official, FEMA has been working on 

the recommendations and expects to implement the actions when FEMA 

releases an update to the NIMS doctrine. Finally, while the National 

Exercises Division did assess NIMS implementation issues in 2013 by 

analyzing AARs, regional offices and the NIC do not systematically or 

regularly assess NIMS implementation. Using AARs to systematically 

assess NIMS implementation over time could allow the regions and the 

NIC to identify recurring issues in jurisdictions.

HSPD-5 calls for FEMA to (1) establish a mechanism for ensuring 

ongoing management and maintenance of the NIMS, including regular 

consultation with other federal departments and agencies and with state 

and local governments, and (2) develop standards and guidelines for 

determining whether a state or local entity has adopted NIMS. In addition, 

OMB Circular No. A-11 states that data limitations can lead to bad 

decisions resulting in lower performance or inaccurate performance 

assessments, and data limitations can include imprecise measurement 

and recordings, incomplete data, and inconsistencies in data collection 

procedures. Consistent verification and validation of performance data 

support the general accuracy and reliability of performance information, 

reduce the risk of inaccurate performance data, and provide a sufficient 

level of confidence to Congress and the public that the information 

presented is credible as appropriate to its intended use.51 As we have 

previously reported, FEMA’s reliance on self-reported data from states 

and lack of verification for FEMA preparedness grants has presented 

 50FEMA, National Exercise Division Incident Command System and National Incident 

Management System Assessment Report, (Washington, D.C.: Sept. 13, 2013).

51OMB Circular No. A-11, Preparation, Submission, and Execution of the Budget

(Washington, D.C.: Aug. 3, 2012). The circular also states that agencies should have costeffective verification and validation techniques in place to ensure the completeness and 

reliability of reported performance data.
Page 24 GAO-16-38 FEMA Regional Coordination

reliability concerns.52 While AARs are also self-reported, they use a 

narrative format that includes analyses of the various aspects of actions 

following an exercise or actual event. State officials from two states we 

spoke with said that they review AARs within their state in order to 

evaluate NIMS implementation. For example, officials from one state said 

they use AARs to identify gaps in NIMS implementation so they can align 

resources to support better implementation. This is because exercises 

enable stakeholders to identify both capability gaps and areas for 

improvement. Further, the purpose of exercises is to provide a low-risk 

environment to test capabilities, familiarize personnel with roles and 

responsibilities, and foster meaningful interaction and communication 

across organizations. As such, evaluating AARs could provide an 

additional opportunity to look for areas of NIMS implementation that could 

be improved.

According to NIC officials, they meet the requirements of HSPD-5 through 

ongoing discussions with NIMS stakeholders, including state emergency 

managers, to ensure ongoing management and maintenance of NIMS, 

and by obtaining self-assessment information provided by states on NIMS 

implementation in the URT that provides standards and guidelines. 

Additionally, in order to meet the requirements of HSPD-5, in 2006 the 

NIC developed implementation guidance through the NIMS Compliance 

Objectives and Metrics for states and territories, tribal nations, and local 

governments, which was last updated in 2010.53 However, NIC officials 

said that, given the large number of states and their jurisdictions that have 

adopted NIMS, any efforts to validate the information states provide on 

their implementation efforts would be prohibitively difficult and costly. 

While verifying each state and jurisdiction’s self-reported information may 

 52GAO, Grants Performance: Justice and FEMA Collect Performance Data for Selected 

Grants, but Action Needed to Validate FEMA Performance Data, GAO-13-552 

(Washington, D.C.: June 24, 2013). In this report, we found that in two FEMA 

preparedness grants programs, grant recipients provided self-reported performance data 

and FEMA had no process to validate program data. We recommended that FEMA ensure 

that there are consistent procedures in place at the program office and regional levels to 

promote verification and validation of grant performance data that allow the agency to 

attest to the reliability of grant data. As of October 2015, FEMA is still working on 

addressing this recommendation. 

53The NIMS Compliance Objectives and Metrics documents provide a detailed list of 

NIMS compliance objectives by NIMS components. States, territories, tribal nations, and 

local governments can still access the guidance through FEMA’s website; however, there 

is no requirement to use this implementation guidance. 
Page 25 GAO-16-38 FEMA Regional Coordination

not be feasible, states are already required to develop AARs under the 

EPMG program, which could provide a source in addition to the URT by 

which FEMA could assess progress made on implementation of NIMS, as 

the 2013 assessment by the National Exercise Division demonstrates. 

States are already required to develop AARs following their preparedness 

exercises, based on grant program requirements. Moreover, FEMA’s 

regional offices have multiple positions with responsibilities for NIMS 

implementation, as well as preparedness exercises. Therefore, 

developing policies and procedures for regional office staff to review and 

assess information on states’ NIMS implementation, gleaned through a 

review of exercise AARs, would not only help FPCs and NIMS 

coordinators better meet their responsibilities for supporting and 

enhancing regional preparedness, but also provide the NIC a means, in 

addition to the URT, to further evaluate states’ self-reported assessments 

of NIMS implementation.

As described earlier, the Post-Katrina Act required that each FEMA 

region establish a Regional Advisory Council (RAC) in order to provide 

the types of advice on emergency preparedness in their regions listed in 

the Post-Katrina Act to the FEMA regional administrators.54 RAC 

members who responded to our survey reported that they found RAC 

meetings to be a useful collaborative experience, allowing them to obtain 

good information, have interactions with other RAC members and FEMA 

 546 U.S.C. § 317(e).

Additional 

Opportunities Exist 

for FEMA Regional 

Offices to Enhance 

Collaboration with 

Regional Advisory 

Council Members

RAC Members and 

Liaisons View RAC 

Meetings as Useful and 

Well Run
Page 26 GAO-16-38 FEMA Regional Coordination

officials, and to offer advice to FEMA on regional emergency-related 

issues. For example:

• About 90 percent said that the RAC meetings were moderately or very 

effective in providing information on how to make the region better 

prepared for emergencies; the information communicated at RAC

meetings was moderately or very effective (89 percent); coordination 

between the RAC and the regional office was moderately or very 

effective (89 percent); the quality of the communications from their 

FEMA regional office was good or excellent (91 percent); their 

regional office was effective in asking members about their concerns 

or suggestions about emergency preparedness issues in their region 

(93 percent); and their participation was encouraged (93 percent).

• About 81 percent said that the meetings provide a useful forum in 

which to offer advice to FEMA on regional emergency-related issues; 

most said that they likely would serve another term, if invited (81 

percent); the overall preparedness of the region increased moderately 

or greatly as a result of RAC meetings (69 percent); and, in general, 

the meetings were well run, on time, on topic, and relevant to regional 

emergency-related issues (89 percent).

Many of those FEMA regional offices that convene RAC meetings (see 

below for a discussion of the variations in the occurrence of meetings) 

prepare and send out agendas in advance of the meetings and 

collaboratively involve RAC members in planning. Conducting early 

outreach to participants and stakeholders to identify shared interests is an 

effective collaborative implementation approach identified in GAO’s 

Implementation Approaches Used to Enhance Collaboration in 

Interagency Groups.55 RAC members who responded to our survey 

reported that they appreciated the information provided to prepare them 

for the RAC meetings. For example, 96 percent reported that they were 

notified in advance about the meetings, 86 percent stated that the 

agendas provided information necessary for preparing for the RAC 

meetings, and 79 percent believed that distributing the minutes after the 

meeting was a moderately or very effective approach.

 55GAO, Managing for Results: Implementation Approaches Used to Enhance 

Collaboration in Interagency Groups, GAO-14-220 (Washington, D.C.: Feb. 14, 2014). In 

this report, we identified specific implementation approaches that interagency groups use 

to overcome common challenges when collaborating.
Page 27 GAO-16-38 FEMA Regional Coordination

Although the RAC charters adopted by each of the 10 regions require that 

their RACs meet twice annually, some RACs have not met routinely in 

recent years to collaborate with FEMA regional officials to provide advice 

and input from regional stakeholders. The DHS Inspector General 

reviewed the FEMA Region IX Office in 2012 and the Region V Office in 

2015 and concluded that because the RACs in those regions had not met 

for a period of years, FEMA’s regional offices could be “missing 

opportunities to identify and remediate weaknesses or deficiencies in 

preparedness, protection, response, recovery, and mitigation activities.”56

Figure 2 summarizes the number of RAC meetings in each region since 

2007 through August 2015 (including both in-person meetings and 

meetings conducted as interactive webinars).

Figure 2: Number of RAC Meetings in Each FEMA Region by Year for 2007-August 

2015

Note: Meetings for 2015 are for those that occurred through August 3, 2015. Several regions reported 

that they were planning additional RAC meetings later in calendar year 2015. For example, Region IV 

had a RAC meeting in November 2015.

 56DHS Office of Inspector General (OIG), Inspection of FEMA’s Regional Offices—Region 

IX, OIG-12-43 (Washington, D.C.: Feb. 24, 2012); and Inspection of FEMA’s Regional 

Offices—Region V, OIG-15-120 (Washington, D.C.: Aug. 7, 2015). 

Some FEMA Regions Do 

Not Routinely Meet with 

RACs to Collaborate on 

Emergency Preparedness
Page 28 GAO-16-38 FEMA Regional Coordination

One region cited the fact that they did not have funds to reimburse RAC 

members for travel expenses, and another cited travel costs as a problem 

for RAC members in a region as geographically large as theirs. Another 

region stated that while they paid for the travel expenses, this necessarily 

had to come from their available funds and that therefore, it meant having 

less for other potential needs.

In our survey of RAC members, respondents cited several reasons why 

they did not attend RAC meetings. For example, 68 percent of 

respondents cited scheduling commitments and conflicts, 26 percent cited 

insufficient or no funding for travel, and 11 percent said that the meeting 

locations were inconvenient. Some RAC members said that their RAC 

should definitely or probably meet more frequently (41 percent), while 

others did not (30 percent said “probably” or “definitely not” and 23 

percent said they were unsure or had no opinion). In open-ended 

comments on RAC meetings attended by RAC members, 6 RAC 

members stated that they would prefer having more in-person meetings 

versus teleconferences or videoconferences.

FEMA Region V, in which the RAC did not meet for several years, took 

steps starting in August 2014 to address a lack of interest from the 

majority of the members. For example, regional officials invited RAC 

members to other regional meetings with other federal agencies—a 

process used by some other regions. In 2015, the regional office resumed 

having RAC meetings, with one taking place in mid-January with 11 of 12

members attending. According to the regional RAC liaison, the high 

attendance was the result of the regional administrator having personally 

reached out to the individuals who had been recommended for RAC 

membership and inviting them to participate. He said this individualized 

communication with each person on the team helped to instill interest and 

motivate involvement in the meeting, in the view of the liaison, and that 

the personal involvement of the regional administrator makes the RAC 

more effective.

The Post-Katrina Act requires FEMA regional offices to establish RACs in 

order to provide input to each regional administrator on regional 

emergency management issues by identifying any geographic, 

demographic, or other characteristics peculiar to any state, local, or tribal 

government within the region that might make preparedness, protection, 

response, recovery, or mitigation more complicated or difficult, among 

other things. Additionally, GAO’s Key Considerations for Implementing 

Interagency Collaborative Mechanisms identified meetings that bring 

stakeholders together as an effective collaborative practice, noting 
Page 29 GAO-16-38 FEMA Regional Coordination

particularly that such relationship-building is vital in responding to 

disasters.57

By routinely obtaining input from RAC members—whether through inperson meetings or via remote connection or other means—FEMA 

regional offices could better ensure they are identifying geographic, 

demographic, or other issues within the region to enhance emergency 

preparedness. Additionally, for those FEMA regional offices that face 

participation challenges, assessing the reasons for these barriers and 

identifying targeted solutions, such as consistently offering remote 

participation, or, as used by one region, direct communication from the 

regional administrator to RAC members, could better ensure they are 

able to obtain such input from the RACs effectively and on a regular 

basis.

RAC members who responded to our survey generally indicated that 

FEMA regions were responsive to their suggestions.

• Seventy-five percent of the RAC members said that they had made 

suggestions concerning issues related to emergency management at 

RAC meetings or between RAC meetings; 79 percent stated that their 

overall sense that FEMA was listening to their concerns increased 

moderately or greatly during the time on which they had served on 

their RAC; and 74 percent stated that FEMA was acting to address 

their concerns.

• Sixty-seven percent of the respondents said FEMA had taken action 

to a moderate, great, or very great extent in response to suggestions 

made by RAC members.58

FEMA RAC liaisons we contacted by e-mail reported having taken action 

in response to RAC member suggestions. Specifically, 9 of the 10 FEMA 

 57GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012). In this 

report, we identified the mechanisms that the federal government uses to lead and 

implement interagency collaboration, as well as issues to consider when implementing 

these mechanisms.

58Seven percent of the respondents said that actions had been taken to a little or some 

extent; 22 percent said they had no opinion or basis on which to judge, and 4 percent said 

no advice or suggestions had been made to the regional office during their time on the 

RAC.

FEMA Regional Offices 

Are Responsive to RAC 

Suggestions but Do Not 

Regularly Provide 

Feedback on Their 

Recommendations
Page 30 GAO-16-38 FEMA Regional Coordination

RAC liaisons reported that input from their RACs had either led to 

changes in specific FEMA policies or led to generally better informing 

FEMA about members’ concerns.59 For example, at the suggestion of 

their RACs, regional offices created a regional training and exercise 

coordination website to share information; forwarded a suggestion from a 

RAC to revise FEMA national policy to include ice storms as a 

reimbursable emergency;60 and developed and distributed monthly 

preparedness themes to help synchronize federal, state, and local 

officials’ focus on common topics, among other things.

Although some FEMA regional offices have incorporated various 

recommendations made by RAC members, 50 percent of the 

respondents in our survey of RAC members said that FEMA should 

provide more detailed feedback to them on suggestions or advice they 

made at RAC meetings.61 Of the 10 regional offices, 7 reported that they 

tracked outcomes of RAC efforts; 3 said they posted suggestions on 

FEMA’s internal website (which is not accessible to non-FEMA 

employees, including RAC members), and 4 said they used e-mail to 

forward meeting notes to RAC members.62 One RAC member from our 

survey commented on the need for a tracking system for the status and 

resolution of issues raised, and another RAC member commented on the 

need for better follow-up on recommendations. Developing a mechanism, 

such as a Listserve or a dedicated website, to periodically notify all RAC 

members in all 10 regions about the status of suggestions made by RACs 

to regional administrators or to FEMA could help FEMA keep RAC 

 59We did not determine how many suggestions had been made since RACs were 

established in 2007 or how many of these suggestions were implemented, or to what 

extent. As discussed below, such suggestions are not systematically tracked by either the 

regional offices or by FEMA headquarters.

60According to the Region VI RAC liaison, the issue was raised sometime in early 2014 

and discussed at the September 2014 RAC meeting, at which time it was forwarded to 

FEMA for consideration. As of September 2015, the policy had not been changed and the 

region had not heard back from FEMA headquarters with regard to the proposed change. 

FEMA officials noted that changing national policy is not a quick process and must be 

reviewed by multiple levels within the agency.

61Thirty percent said they were unsure or had no opinion on whether FEMA should 

provide more detailed feedback to RAC members on suggestions or advice they made at 

RAC meetings, and 19 percent said they did not see this as needed.

62Regions III, VI, and VIII said that they regularly reported back to RAC members by email on the status of suggestions as a way of keeping them up to date.
Page 31 GAO-16-38 FEMA Regional Coordination

members aware of the status of their recommendations and thereby 

address the concerns of those who wanted more detailed feedback.

In March 2014, FEMA’s NAC identified the need for FEMA to re-examine 

the outcomes of its existing regional committees and councils, including 

the RACs. Reporting the outcomes of RACs’ suggestions to the NAC 

could help FEMA address this identified need. The NAC’s 

recommendation to FEMA also reflects the key considerations for 

implementing interagency collaborative mechanisms found in GAO’s 

Implementation Approaches Used to Enhance Collaboration in 

Interagency Groups.

63 As the report stated, many of the meaningful 

results that the federal government seeks to achieve, such as national 

preparedness, require the coordinated efforts of more than one federal 

agency, level of government, or sector. Implementation approaches for 

interagency collaborative mechanisms include developing a plan to 

communicate outcomes and track progress, and developing methods to 

report on the group’s progress that are open and transparent. As noted 

previously, while some regions have taken steps to track outcomes of 

RAC efforts, none of the regional offices has a process for regularly 

providing feedback on the status of recommendations. Providing 

feedback to RAC members on their suggestions could enhance FEMA 

regional offices’ collaboration with their RACs.

The NAC, established by the Post-Katrina Act, incorporates state, local, 

and tribal governments, nonprofit, and private sector input with regard to 

improving emergency preparedness and response to natural and 

manmade emergencies.64 Although almost two-thirds of RAC members 

who responded to our survey said they believed their concerns were 

communicated by FEMA to the NAC, some RAC members commented 

that they wanted more feedback on the NAC’s responses to suggestions. 

However, FEMA has not established policies and procedures to 

communicate RACs’ regional concerns directly to their national-level 

counterparts on the NAC, as proposed in 2011. Almost two-thirds of 

 63GAO-14-220.

64The NAC consists of 35 members, appointed by the FEMA Administrator, who are, to 

the extent practicable, geographically diverse and who represent a substantive crosssection of officials, emergency managers, and emergency response providers from state, 

local, and tribal governments; the private sector; and nongovernmental organizations.

Although Many RAC 

Members Say Their 

Concerns Are 

Communicated to the 

NAC, Others Want More 

Feedback on Responses 

to Suggestions
Page 32 GAO-16-38 FEMA Regional Coordination

respondents said FEMA was (very or moderately) effective in 

communicating RAC concerns and issues to the NAC. However, in open 

ended comments, six RAC members stated they that would like to receive 

more information about the NAC and what it was addressing.

In September 2010, a FEMA local, state, tribal, and federal task force for 

improving national emergency preparedness recommended that 

communications between the RACs and the NAC be more robust.65

Specifically, the task force recommended that RACs receive policy 

information briefings directly from the NAC and provide input directly to 

the NAC in order to provide local, state, tribal, and territorial officials with 

influence across stages of the preparedness policy process and to create 

an informational exchange between the NAC and the RACs to make 

local, state, tribal, and territorial officials fuller partners in the 

preparedness policy process.66

In June 2011, FEMA responded to the recommendation from the task 

force with an implementation plan, stating that, by November 24, 2011, it 

would revise its policies and procedures to systematically link the RACs 

to each other, the NAC, and FEMA headquarters, to help RACs influence 

national emergency management policy. FEMA officials said they held a 

meeting of all the RAC regional liaisons in August 2011 to propose 

options to create a “NAC-RAC interface,” among other things. However, 

they did not identify any additional subsequent actions they had taken to 

implement the plan. For example, although FEMA stated that the August 

2011 RAC liaison meeting had resulted in adding a “RAC Report Out” by 

a regional administrator as a standing agenda item for the NAC meetings, 

none of the NAC meeting agendas for any NAC meeting between August 

2011 and September 2015 showed “RAC Report Out” as an agenda 

item.67 In addition, our review of the minutes for all the NAC meetings 

held between August 2011 and September 2015 found only an 

 65The task force consisted of local, state, tribal, and territorial government representatives 

convened by FEMA in response to the conference report accompanying the Department 

of Homeland Security Appropriations Act, 2010. H.R. Rep. 111-298, at 102 (Conf. Rep.). 

66Local, State, Tribal, and Federal Preparedness Task Force (convened by FEMA), 

Perspective on Preparedness: Taking Stock Since 9/11: Report to Congress of the Local, 

State, Tribal, and Federal Preparedness Task Force (Washington, D.C.: Sept. 2010).

67NAC meeting notes are not available on-line for meetings prior to 2012.
Page 33 GAO-16-38 FEMA Regional Coordination

occasional mention of issues of concern to RACs reported on by FEMA 

regional administrators or others present.

Officials from FEMA’s Office of Regional Operations said that individual 

RACs can transmit their concerns to the NAC, such as by letter or 

through FEMA. The FEMA Office of the NAC provided a detailed 

summary of the status of recommendations made by the NAC to FEMA 

since 2008 to NAC members at the September 2015 NAC meeting. 

However, this summary did not include the status of recommendations or 

suggestions or communications made by RACs to the NAC. As such, 

these processes do not appear to provide a systematic way in which to 

ensure that issues raised in RAC meetings are consistently brought to the 

attention of the NAC for its consideration or to provide a consistent 

feedback mechanism for RAC members.

In November 2015, FEMA’s Office of the NAC said that although it is 

precluded from establishing a formal mechanism between the RACs and 

the NAC,68 it is working with FEMA’s Office of Regional Operations to 

informally enhance coordination between the NAC and the RACs, such 

as distributing NAC recommendation memoranda with the RACs for 

informational purposes. Establishing policies and procedures, as 

suggested by FEMA’s task force and 2011 implementation plan, to 

enhance coordination and communication between the RACs and the 

NAC could create greater opportunities for regional insights about 

preparedness to inform national preparedness policies and a two-way 

informational exchange between the NAC and the RACs to make local, 

state, tribal, and territorial officials fuller partners in the preparedness 

policy process.

Because of the key role FEMA’s regional offices play in national disaster 

preparedness efforts, effective regional coordination and collaboration 

between FEMA headquarters, FEMA regions, and state and local 

stakeholders is essential. Multiple external and internal assessments and 

our work have identified challenges, such as lack of coordination in grantmonitoring visits and inconsistent guidance, in FEMA’s grant 

management. These challenges continue to hamper the effectiveness of 

interactions between FEMA and state officials in implementing the 

 68See Pub. L. No. 92-463, 86 Stat. 770 (1972).

Conclusions
Page 34 GAO-16-38 FEMA Regional Coordination

preparedness grants program. A plan with time frames, goals, metrics, 

and milestones for addressing these challenges would better enable GPD 

officials to monitor and improve their efforts to resolve long-standing 

problems in coordination of monitoring activities and the consistency of 

guidance given to state grantees. Regarding oversight of FEMA’s efforts 

to implement the national system for managing incidents, there are 

opportunities to access more sophisticated and comprehensive 

information using FEMA regional staff to better assess NIMS 

implementation. Further, using AARs that are already required to be 

developed and submitted could provide a better opportunity to assess 

NIMS implementation, including areas of success as well as areas where 

improvement is needed. However, without policies and procedures that 

call for systematically evaluating these reports, regional offices and the 

NIC are missing a key opportunity to better assess national NIMS 

implementation, which could enhance regional preparedness. Finally, 

FEMA regional offices could more consistently and systematically take 

steps to fully leverage RACs that can provide important inputs to national 

preparedness efforts. For example, by ensuring that RACs provide 

feedback to RAC members on the status of their recommendations, 

FEMA could enhance RACs’ collaborative efforts and satisfaction of RAC 

members. Similarly, by enhancing RACs’ connectivity with the NAC, 

FEMA could increase the potential value of regional coordination and 

collaboration and the resulting contributions to regional preparedness 

efforts.

To promote more effective grant management coordination, the Secretary 

of Homeland Security should direct the FEMA Administrator to develop a

plan with time frames, goals, metrics and milestones detailing how GPD 

intends to resolve longstanding challenges associated with its existing 

hybrid grants management model, which divides responsibilities between 

regional and headquarters staff.

To enable more sophisticated and comprehensive awareness of states’

NIMS implementation, the Secretary of Homeland Security should direct 

the FEMA Administrator to develop policies and procedures for regional 

staff to review AARs from preparedness exercises within their region, and 

headquarters staff to review these evaluations in order to have a better 

understanding of NIMS implementation.

To enhance the value of RACs, the Secretary of Homeland Security 

should direct the FEMA Administrator to take the following three actions:

Recommendations for 

Executive Action
Page 35 GAO-16-38 FEMA Regional Coordination

1. Ensure that all regional offices routinely obtain input—whether in 

person, by teleconference or by other remote connection—from their 

RAC members on ways to enhance overall emergency preparedness 

in their regions. In cases where RAC member participation is low, 

regional offices should assess and identify targeted solutions for 

increasing member participation, such as offering remote participation 

or alternative forums;

2. Develop a mechanism to update RAC members on the status of 

recommendations made by RACs to FEMA; and

3. Establish processes for enhanced coordination and communication 

between the RACs and the NAC.

We provided a draft of this report to DHS for comment. DHS provided 

technical comments, which we incorporated as appropriate. On January 

15, 2016, DHS also provided written comments, reproduced in full in 

appendix IV. DHS concurred with four of our recommendations and did 

not concur with one. 

DHS did not concur with our first recommendation that the Secretary of 

Homeland Security direct the FEMA administrator to develop a plan with 

time frames, goals, metrics, and milestones detailing how GPD intends to 

resolve longstanding challenges associated with its existing hybrid grants 

management model. In its comments, DHS stated that it disagreed with 

GAO’s characterization of longstanding challenges in managing 

preparedness grants. As we stated in the report, multiple assessments 

dating back to 2009 have reported challenges with the hybrid model that 

splits management of preparedness grants between FEMA’s 

headquarters and regional offices. As also noted in the report, officials 

from 4 FEMA regional offices and officials from 3 states within those 

regions provided numerous examples of a lack of coordination between 

headquarters and regional staff in managing preparedness grants, 

including instances that took place in 2014 and as recently as September 

2015. Based on our review of the past assessments and the audit work 

we performed, we believe that these long-standing challenges have yet to 

be resolved. 

In its written comments, DHS also stated that FEMA already empowers 

its ten regions to coordinate and communicate with headquarters and 

other regional offices to facilitate working relationships. While FEMA has 

taken various actions since 2008 to improve coordination related to 

preparedness grants—some actions as recent as February 2015—these 

steps have not resolved these challenges, as described in the report. 

Agency Comments 

and Our Evaluation
Page 36 GAO-16-38 FEMA Regional Coordination

When we spoke with GPD officials in September 2015, they agreed that 

there were continuing opportunities to improve coordination and 

communications in their management of preparedness grants. Therefore, 

we continue to believe that FEMA would benefit from a more strategic 

approach that a plan, with time frames, goals, metrics, and milestones 

detailing how officials intend to resolve longstanding challenges 

associated with the existing hybrid model, could provide. 

DHS also expressed concern about the wording of our recommendation 

and how the recommendation, as worded, could be closed.69 Specifically, 

DHS stated that FEMA is not aware of nor did the recommendation 

provide any specific criteria that could be used to gauge the success of 

any proposed plan. While we recommended that DHS develop a plan with 

time frames, goals, metrics, and milestones for resolving its longstanding 

coordination challenges, we did not prescribe specific actions to address 

these challenges. However, our work across the federal government has 

identified implementation approaches used to enhance collaboration that 

could inform GPD officials’ efforts to clearly define short-term and longterm outcomes and track and monitor their progress.70 Nevertheless, 

FEMA could implement this recommendation by developing a plan and 

we believe that doing so would address the intent of this 

recommendation.

Regarding our second recommendation that the Secretary of Homeland 

Security direct the FEMA Administrator to develop policies and 

procedures for regional staff to review AARs from preparedness 

exercises within their region, and headquarters staff to review these 

evaluations in order to have a better understanding of NIMS 

implementation, DHS concurred and said it recognizes that joint efforts by 

regional and headquarters staff are essential to enable more 

sophisticated and comprehensive awareness of NIMS implementation. 

However, DHS expressed concerns about overstating the value of AARs 

 69GAO closes a recommendation when actions that satisfy the intent of the 

recommendation have been taken, when it is no longer valid because circumstances have 

changed, or implementation cannot reasonably be expected. 

70GAO, Managing for Results: Implementation Approaches Used to Enhance 

Collaboration in Interagency Groups, GAO-14-220 (Washington, D.C.: Feb. 14, 2014). 

While these practices were based on our review of collaboration across federal agencies, 

we believe they could inform GPD’s efforts to enhance collaboration with grants 

management staff in FEMA’s regional offices. 
Page 37 GAO-16-38 FEMA Regional Coordination

as a means to improve understanding of NIMS implementation. 

Specifically, DHS stated that FEMA does not agree that the “best way to 

assess how well NIMS has been implemented is by assessing states’ 

performance in preparedness exercises and real-world events.” As noted 

in the report, most all of the officials we spoke with believed that the 

current method of determining NIMS implementation—states selfcertification via the URT—was not an effective method of determining 

NIMS implementation, and officials in all of the FEMA regions and 8 of the 

states we interviewed said that looking at how effectively a jurisdiction 

responds during an exercise or real world event is the best way to assess 

NIMS implementation. DHS also stated that the extent to which a 

jurisdiction has implemented NIMS is nuanced and therefore impossible 

to assess accurately from an AAR. The report does not suggest that 

reviewing AARs would give a comprehensive and definitive assessment 

of NIMS implementation but rather that it could provide FEMA an 

additional way to assess and elaborate on the information states currently 

provide. In fact, FEMA used AARs to conduct an assessment of NIMS in 

2013, which resulted in some recommendations to help improve NIMS 

implementation. Finally, as we have previously reported, the Post-Katrina 

Act requires FEMA to carry out the National Exercise Program.71 The Act 

established the Program, among other things, as a means for FEMA to 

test and evaluate NIMS implementation efforts.72 As a result, we continue 

to believe that AARs, an essential part of the National Exercise Program, 

are an important part of FEMA’s efforts to assess NIMS implementation 

and we added a reference to this requirement to our final report. DHS did 

not identify any specific steps to address this recommendation but said 

that the National Preparedness Directorate would work with regional 

NIMS coordinators and the states to explore options during calendar year 

2016, with potential changes to be implemented in calendar year 2017. 

In its written comments, DHS concurred with our third, fourth, and fifth 

recommendations related to enhancing the value of RACs. Specifically, 

regarding the third recommendation that the Secretary of Homeland 

Security direct the FEMA administrator to ensure that regional offices 

routinely obtain input from their RAC members, DHS concurred and 

 71GAO, National Preparedness: FEMA Has Made Progress, but Needs to Complete and 

Integrate Planning, Exercise, and Assessment Efforts, GAO-09-369 (Washington, D.C.: 

Apr. 30, 2009).

72The National Exercise Program was established by 6 U.S.C. § 748(b)(1) in order to, 

among other things, test and evaluate NIMS.
Page 38 GAO-16-38 FEMA Regional Coordination

stated that the regions will conduct two meetings a year with their RAC 

members; that a RAC coordinator within each region will be responsible 

for the oversight of these meetings; and that open dialogue will be 

encouraged between RAC members and the regions, with each region 

establishing a RAC coordinator to facilitate this communication. If 

implemented as planned, these actions should help address the intent of 

the recommendation to ensure that regional offices routinely obtain input 

from their RAC. 

Regarding the fourth recommendation that the Secretary of Homeland 

Security direct the FEMA administrator to develop a mechanism to update 

RAC members on the status of recommendations made by RACs to 

FEMA, DHS concurred and stated that it will build into each RAC meeting 

a briefing by regional personnel on the status of recommendations, if any, 

made during the previous meeting. The regional administrator or RAC 

coordinator within the region will be responsible for the brief. Additionally, 

if RAC members are not satisfied with the implementation of RAC 

recommendations, it will be expected that the regional office will provide 

information on why a specific recommendation was not adopted or why 

implementation is delayed. DHS further stated that each region may have 

its own method of dispensing updates to its RAC members between 

meetings, including monthly email updates, posting on their website, or 

informational calls. If implemented as planned, these actions should help 

address the intent of the recommendation to update RAC members on 

the status of its recommendations to FEMA.

Regarding our fifth recommendation that the Secretary of Homeland 

Security direct the FEMA administrator to establish processes for 

enhanced coordination and communication between the RACs and the 

NAC, DHS concurred and stated that regional administrators will continue 

to attend NAC meetings and provide FEMA regional updates that include 

RAC activities with the regions. Moreover, regional coordinators will 

ensure that RAC members are aware of any NAC meeting occurring in 

their own region, and that the RAC sharepoint site will be used as a 

platform to update RAC coordinators on impending NAC meetings to 

share with their RAC members. If implemented as planned, these actions 

should help address the intent of the recommendation to establish 

processes for enhanced coordination and communication between the 

RACs and the NAC.
Page 39 GAO-16-38 FEMA Regional Coordination

We are sending copies of this report to Secretary of Homeland Security, 

appropriate congressional committees, and other interested parties. This 

report is also available at no charge on GAO’s website at 

http://www.gao.gov.

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

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

Office of Congressional Relations and Office of Public Affairs can be 

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

report are listed in appendix V.

Chris P. Currie

Director, Homeland Security and Justice
Page 40 GAO-16-38 FEMA Regional Coordination

List of Requesters

The Honorable Ron Johnson

Chairman

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Michael McCaul

Chairman

The Honorable Bennie Thompson

Ranking Member

Committee on Homeland Security

House of Representatives

The Honorable Martha McSally

Chairman

The Honorable Donald M. Payne, Jr.

Ranking Member

Subcommittee on Emergency Preparedness, Response, and 

Communications

Committee on Homeland Security

House of Representatives

The Honorable Susan Brooks

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-16-38 FEMA Regional Coordination

The objectives of this study were to assess the extent to which the 

Federal Emergency Management Agency (FEMA) headquarters and 

regional offices have (1) addressed grant management coordination 

challenges between headquarters and the regions; (2) established a 

comprehensive system to assess National Incident Management System 

(NIMS) implementation; and (3) collaborated with Regional Advisory 

Council (RAC) members.

To address the first objective, we gathered and reviewed relevant 

documentation, such as FEMA assessments of grants managed by Grant 

Programs Directorate (GPD), FEMA’s previous delegations of grant 

management responsibilities to regional offices, agency task force reports 

on advantages and disadvantages of regionalization, FEMA headquarters 

and regional office grant management roles and responsibilities, FEMA 

documentation on regionalization pilot programs, and other memoranda 

and internal documents. We also reviewed prior GAO reports on regional 

preparedness, grant management, and consolidation of management 

functions.1 We interviewed FEMA’s Director of the Preparedness Grants 

Division within GPD and other senior GPD officials to discuss 

programmatic grant management as well as previous FEMA assessments 

of the impact of moving management responsibilities to FEMA regional 

offices. We also interviewed grant management officials from 4 FEMA 

regional offices—Regions III, IV, VI, and IX—to discuss financial grant 

management and coordination of monitoring activities with GPD. These 

offices were selected in order to provide a mix of geographic locations, 

types of disasters typically experienced, and whether the regional office 

had been selected to participate in FEMA grant management pilot 

programs. Similarly, we interviewed officials from 9 states or territories 

(Arkansas, California, Florida, Georgia, Louisiana, Nevada, Texas, 

Virginia, and Washington, D.C.) from the 4 FEMA regions to discuss grant 

management within the states as well as interactions with FEMA grant 

management officials. These states were selected to reflect a diversity of 

experiences within the 4 FEMA regions we chose. While the information 

gained from these interviews cannot be generalized across all states, it 

 1

GAO, FEMA Has Made Progress in Managing Regionalization of Preparedness Grants,

GAO-11-732R (Washington, D.C.: July 29, 2011); Homeland Security: DHS Needs Better 

Project Information and Coordination among Four Overlapping Grant Programs,

GAO-12-303 (Washington, D.C.: Feb. 28, 2012); and Homeland Security: Effective 

Regional Coordination Can Enhance Emergency Preparedness, GAO-04-1009 

(Washington, D. C.: Sept. 15, 2004).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-16-38 FEMA Regional Coordination

provides useful insights into the nature of FEMA GPD and regional 

coordination with states with regard to grant management.

To address the second objective, we reviewed NIMS-related documents 

such as the NIMS Doctrine, NIMS Compliance Guidance, NIMS 

implementation reports, and results of the NIMS implementation 

questions in the Unified Reporting Tool (URT). We also reviewed 

documents on the Homeland Security Exercise and Evaluation Program 

(HSEEP) and on preparedness grants requirements. We compared 

FEMA’s efforts in NIMS implementation and verification with Homeland 

Security Presidential Directive-5 and Office of Management and Budget 

(OMB) Circular No. A-11, regarding data validation and verification.

2 We 

interviewed officials at FEMA’s National Preparedness Directorate, which 

includes the National Integration Center (NIC)—the office responsible for 

NIMS implementation—to discuss the NIC’s efforts in implementing 

NIMS. To discuss NIMS implementation efforts at the regional and state 

levels, interactions between regional and state officials, and mecha nisms 

for verifying how well NIMS is being implemented, we also interviewed 

officials from the 4 FEMA regional offices and the 9 states or territories 

mentioned above. In addition, because of the recommendations of 

officials in several regional offices and states, we interviewed an official 

from a 10th state (Oklahoma) from within the selected FEMA regions. 

Again, while the information gained from these interviews cannot be 

generalized across all states, it provided useful insights into the various 

efforts in implementing NIMS. Additionally, we analyzed all 35 full-scale 

exercise after-action reports (AAR) that FEMA received for exercises 

conducted during fiscal year 2014 and in the 4 regions we visited. We 

used the AARs as they provide qualitative analysis of outcomes of 

exercises, which are conducted in order to identify capability gaps and 

areas for improvement. The purpose of the analysis was to determine if 

they could be used to assess the level of participants’ implementation of 

NIMS. We did this by developing a crosswalk that linked the six NIMS 

elements listed in the URT, and that states should incorporate into 

exercises, to a core capability—the unit by which exercises are evaluated. 

In developing this crosswalk, we found three core capabilities that we 

used as proxies for the six NIMS elements that are to be incorporated into 

exercises—operational coordination, operational communication, and 

 2

OMB, Circular No. A-11, Preparation, Submission, and Execution of the Budget

(Washington, D.C.: Aug. 3, 2012).
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-16-38 FEMA Regional Coordination

public information and warning.3 While aspects of NIMS implementation 

could be gleaned from other core capabilities, for the purposes of this 

analysis we used the three core capabilities identified through our 

crosswalk. Of the 35 reports we analyzed, 33 assessed at least one, if not 

two or all three, of the core capabilities we identified as proxies. In those 

reports where one or more of the core capabilities were addressed, we 

looked to see if there were issues associated with those core capabilities, 

and the nature and extent of the issues, by reviewing various sections of 

the reports. For the core capability of operational coordination, we also 

looked at the exercise objectives to see if they aligned with some element 

of NIMS components. If an AAR reported that the core capability that we 

assessed either was performed with some challenges, was performed 

with major challenges, or was unable to be performed, we included it in 

our count of a capability that encountered some issues. From this we 

could glean the extent to which various NIMS elements are working well 

and those that still have room for improvement. While results of these 

exercises are not generalizable to the country as a whole, they do provide 

useful insights into NIMS implementation in some areas.

To address the third objective, we interviewed FEMA headquarters and 

regional office officials and analyzed FEMA and Department of Homeland 

Security (DHS) Office of Inspector General (OIG) reports with information 

and findings relevant to RACs. We attended two RAC meetings in 2

regions that took place during the early part of our review, and obtained 

documentation of agendas and other relevant materials for RAC meetings 

that occurred between 2007 and 2014 for the RACs in all 10 FEMA 

regions. We also reviewed agendas and meeting minutes for NAC 

meetings that took place between August 2011 and September 2015. We 

reviewed relevant federal laws and regulations, federal internal controls 

standards, and leading practices for program management.

To identify the extent to which RAC members view their RAC experiences 

as effective in conveying their concerns to FEMA, we conducted a selfadministered, web-based questionnaire survey of RAC members of each 

FEMA region’s RAC; FEMA’s 10 regional offices identified an initial 

 3

We also determined that operational coordination was a good proxy for NIMS 

implementation, as the 2014 and 2015 Unified Reporting Tool uses the NIMS 

implementation questions as an assessment of operational coordination for the State 

Preparedness Report.
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-16-38 FEMA Regional Coordination

population of 133 active RAC members.4 (See app. II for a copy of the 

survey questionnaire and the results.)

Using e-mail addresses provided by each of the FEMA regions for their 

RAC members (which included the RAC members’ names and, in most 

cases, their place of work or other occupational identifier), we e-mailed 

each RAC member a link to a secure survey website, along with a unique 

identifier and password to control access to each member’s 

questionnaire. Most survey questions were closed-ended, in which RAC 

members selected from a list of possible responses. To obtain additional 

narrative and supporting context, survey respondents were given 

opportunities to provide additional open-ended comments throughout the 

survey.

The survey began on May 27, 2015, and data collection ended on June 

29, 2015. We e-mailed the survey link to 126 of the RAC members 

identified by FEMA regional offices. Of these 126 e-mail contacts, e-mails 

to 14 were initially undeliverable and 2 were e-mails for FEMA employees 

who had been incorrectly listed as RAC members (FEMA employees 

cannot be RAC members). Of the 14 non-FEMA RAC members, we 

determined that 12 were no longer RAC members. Of the remaining 2, 

one informed us that she had only recently been appointed to a RAC and 

had not attended any RAC meetings, and the other told us in a follow-up 

telephone call that he had not been a RAC member for at least 4 years. 

On the basis of this information about RAC membership status, we 

defined all 16 cases as ineligible and excluded them from the survey 

population. Of the 110 contacted that were still presumed to be eligible 

members, 77 responded to the survey, resulting in a 70 percent response 

rate. Of the 77 respondents, 3 answered an initial screening question 

stating that they were not currently members of the RAC in their region, 

which left a total of 74 respondents whose responses were usable for our 

analysis of the rest of the questions. During the course of survey data 

collection, we sent periodic reminder e-mails to all nonrespondents to 

encourage participation in the survey. We also conducted tailored followups by e-mail or telephone with selected nonrespondents, for example, 

those only partially completing their questionnaires.

 4

Through a transcription error, we omitted 7 persons of 13 who were identified as active 

members from the Region IV RAC. We therefore excluded these RAC members from our 

survey population. 
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-16-38 FEMA Regional Coordination

Because our survey was designed to include the entire population of RAC 

members, our results are not subject to sampling error. However, the 

practical difficulties of conducting any questionnaire survey may introduce 

a variety of non-sampling errors. For example, differences in how a 

particular question is interpreted, the sources of information available to 

respondents, or the types of people who do not respond to the survey or 

a particular question can introduce error into survey results. We included 

steps in the survey design, data collection, and analysis stages to 

minimize these types of non-sampling errors. To minimize measurement 

error and nonresponse error, we designed draft questionnaires in 

collaboration with GAO survey specialists. We conducted pretests by 

telephone with three RAC members from three regions. On the basis of 

survey specialist input and these pretests, we made revisions to 

questionnaire drafts as necessary to reduce the likelihood of 

measurement and nonresponse errors (the types of nonresponse 

associated with the perceived burden, lack of question clarity or relevance 

to the respondent). In addition, our analysts answered respondent 

questions and resolved difficulties that respondents had in completing our 

questionnaire. We asked open-ended comment questions at various 

points in the questionnaire to allow respondents to explain or provide 

context for their answers, which helped inform and corroborate our 

interpretation and analysis of the survey results. We examined survey 

results to identify and remediate any inconsistencies or other indications 

of response error. Finally, we made multiple follow-up contacts with nonrespondents throughout data collection to reduce nonresponse. To 

minimize the possibility of data processing error, a second data analyst 

independently verified the accuracy of all computer analyses. In addition, 

RAC members made their responses directly into an automated web 

survey instrument, preventing errors associated with manual data entry of 

written answers.

We conducted our work from October 2014 to February 2016 in 

accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 46 GAO-16-38 FEMA Regional Coordination

Below is the text of the survey as it was sent to Regional Advisory Council 

(RAC) members. Following the cover page, the questions are shown, 

along with the results in percentages. Narrative answers to open-ended 

text questions are not displayed to prevent the identification of individual 

respondents. Percentages may not always sum to 100 percent because 

of rounding of decimal figures.

Note: Seventy-seven individuals responded to the survey. Three individuals indicated in question 1 

that they were no longer RAC members, and as such did not answer questions 2-27 as instructed in 

the survey. Seventy-four RAC members were directed to answer questions 2-27, although in a few 

cases individual questions were not answered

Appendix II: Results of GAO Survey of 

Federal Emergency Management Agency 

(FEMA) Regional Advisory Council Members
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 47 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 48 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 49 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 50 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 51 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 52 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 53 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 54 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 55 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 56 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 57 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 58 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 59 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 60 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 61 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 62 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 63 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 64 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 65 GAO-16-38 FEMA Regional Coordination
Appendix II: Results of GAO Survey of Federal 

Emergency Management Agency (FEMA) 

Regional Advisory Council Members

Page 66 GAO-16-38 FEMA Regional Coordination
Appendix III: National Incident Management 

System (NIMS) Implementation Questions 

Asked of States and Territories in the Unified 

Reporting Tool

Page 67 GAO-16-38 FEMA Regional Coordination

Appendix III: National Incident Management 

System (NIMS) Implementation Questions 

Asked of States and Territories in the Unified 

Reporting Tool
Appendix III: National Incident Management 

System (NIMS) Implementation Questions 

Asked of States and Territories in the Unified 

Reporting Tool

Page 68 GAO-16-38 FEMA Regional Coordination
Appendix III: National Incident Management 

System (NIMS) Implementation Questions 

Asked of States and Territories in the Unified 

Reporting Tool

Page 69 GAO-16-38 FEMA Regional Coordination
Appendix IV: Comments from the Department 

of Homeland Security

Page 70 GAO-16-38 FEMA Regional Coordination

Appendix IV: Comments from the 

Department of Homeland Security
Appendix IV: Comments from the Department 

of Homeland Security

Page 71 GAO-16-38 FEMA Regional Coordination
Appendix IV: Comments from the Department 

of Homeland Security

Page 72 GAO-16-38 FEMA Regional Coordination
Appendix IV: Comments from the Department 

of Homeland Security

Page 73 GAO-16-38 FEMA Regional Coordination
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 74 GAO-16-38 FEMA Regional Coordination

Chris P. Currie, (404) 679-1875 or CurrieC@gao.gov

In addition to the contact named above, Chris Keisling (Assistant 

Director), David Alexander, Chuck Bausell, David Dornisch, Eric 

Hauswirth, Susan Hsu, Valerie Kasindi, Stuart Kaufman, Tracey King, 

Marvin McGill, Carl Ramirez, Robert Rivas, and Jonathan Tumin made 

key contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(441258)
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