United States Government Accountability Office

GAO Report to Congressional Requesters

EMERGENCY 

MANAGEMENT 

Most School Districts 

Have Developed 

Emergency 

Management Plans, 

but Would Benefit 

from Additional 

Federal Guidance 

June 2007 

 

GAO-07-609 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

June 2007

EMERGENCY MANAGEMENT 

Most School Districts Have Developed 

Emergency Management Plans, but 

Would Benefit from Additional Federal 

Guidance 

Highlights of GAO-07-609, a report to 

congressional requesters 

Congress has raised concerns over 

emergency management in school

districts, with a particular interest

in how federal agencies provide 

assistance to school districts. GAO 

was asked to assess (1) the roles of 

federal and state governments and 

school districts in establishing 

requirements and providing 

resources to school districts for

emergency management planning, 

(2) what school districts have done 

to plan and prepare for 

emergencies, and (3) the 

challenges, if any, school districts 

have experienced in planning for

emergencies, and communicating

and coordinating with first 

responders, parents, and students.

To obtain this information, GAO 

interviewed federal officials, 

surveyed a stratified random 

sample of all public school 

districts, surveyed state education 

agencies and state administering 

agencies, conducted site visits to

school districts, and reviewed 

relevant documents. 

What GAO Recommends

GAO is making several

recommendations to DHS, 

Education, and HHS aimed at 

improving school district emergency

management planning and

preparation. Education and HHS 

generally agreed with GAO’s

recommendations. DHS generally

agreed with the intent of GAO’s 

recommendations.

Although there are no federal laws requiring all school districts to have

emergency management plans, most states and school districts reported having 

requirements for such planning, and federal and state governments and school 

districts provide financial and other resources. Thirty-two states reported having 

laws or other policies requiring school districts to have emergency management

plans. The Departments of Education (Education) and Homeland Security (DHS)

and state governments as well as school districts provide funding for emergency 

management planning in schools. DHS awards grants to states and local 

jurisdictions that may provide some of these funds to school districts and 

schools for emergency management planning. However, DHS program guidance 

for certain grants does not clearly identify school districts as entities to which 

state and local governments may disburse grant funds. Thus, states receiving 

DHS funding may not be aware that such funding could be allocated to school 

districts or schools. 

Most school districts have taken federally recommended steps to plan and

prepare for emergencies, including the development of emergency management 

plans, but many plans do not include recommended practices. Based on GAO’s 

survey of school districts, most school districts, those with and without plans, 

have undertaken a variety of recommended practices to prepare for emergencies 

such as conducting school drills and exercises. In addition, based on GAO’s 

survey of school districts, an estimated 95 percent of all school districts have 

written emergency management plans, but the content varies. While most school

districts have procedures in their plans for staff roles and responsibilities, for 

example, school districts have not widely employed such procedures as, 

academic instruction via local radio or television, for continuing student 

education in the event of an extended school closure, such as might occur

during a pandemic. Likewise, while many districts have procedures for special 

needs students, GAO found during site visits that some of these procedures may 

not fully ensure the safety of these students in an emergency. Finally, while most 

school districts practice their emergency management plans annually within the 

school community, GAO estimates that over one-quarter of school districts have

never trained with any first responders and over two-thirds of school districts do

not regularly train with community partners on how to implement their school 

district emergency management plans. 

Many school districts experience challenges in planning for emergencies, and 

some school districts face difficulties in communicating and coordinating with

first responders and parents, but most do not have such challenges with

students. Based on GAO’s survey of school districts, in many school districts 

officials struggle to balance priorities related to educating students and other

administrative responsibilities with activities for emergency management and 

consider a lack of equipment, training for staff, and personnel with expertise in

the area of emergency planning as challenges. In an estimated 39 percent of

school districts with emergency management plans, officials experienced a lack 

of partnerships, limited time or funding to plan, or lack of interoperability 

between equipment used by school districts and first responders. In interviews, 

about half of the officials in the 27 school districts GAO visited reported 

difficulty in ensuring that parents received consistent information from the 

district during an emergency.

www.gao.gov/cgi-bin/getrpt?GAO-07-609.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Cornelia Ashby 

at (202) 512-7215 or ashbyc@gao.gov or

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

jenkinsw@gao.gov. 
Contents 

Letter 1

Results in Brief 4

Background 7

Many States and School Districts Reported Having Requirements 

for Emergency Management Plans, and Federal and State 

Governments and School Districts Provide Resources for 

Emergency Management Planning 9 

Most Districts Have Taken Steps to Prepare for Emergencies and 

Developed Written Plans, but Some Plans Do Not Address 

Recommended Practices 21 

School Districts Report Challenges in Planning for Emergencies as 

Well as Difficulties in Communicating with First Responders and 

Parents, but No Challenges in Communicating with Students 39 

Conclusions 46

Recommendations for Executive Action 47 

Agency Comments and Our Evaluation 48 

Appendix I Scope and Methodology 51 

Survey of States 51 

Survey of School Districts 52 

Site Visits 54 

Appendix II Emergency Management Planning Requirements 57 

Appendix III Homeland Security Funding Provided to 

School Districts 60 

Appendix IV Guidance, Training, and Funding States Provided to 

School Districts 61 

Appendix V Comments from the Department of Homeland 

Security 63 

Page i GAO-07-609 Emergency Management
Appendix VI Comments from the Department of Education 66 

Appendix VII Comments from the Department of Health & 

Human Services 70 

Appendix VIII GAO Contacts and Staff Acknowledgments 73 

Tables 

Table 1: Estimated Frequency of School Districts’ Review of 

Schools’ Emergency Management Plans 12

Table 2: Estimated Number of School Districts That States 

Reported Providing Homeland Security Funding during 

Fiscal Years 2003–2006 14

Table 3: Examples of Guidance, Training, and Equipment the 

Federal Government Provides to School Districts 17

Table 4: Selected Practices That Education, DHS, and HHS 

Recommend School Districts Take to Prepare for 

Emergencies 18

Table 5: Key Elements in Emergency Management Plan Templates 

by Percentage of School Districts with Written Emergency 

Management Plans 20

Table 6: Types of Security Enhancements School Districts Made 

Based on Vulnerability Assessments 22

Table 7: Activities School Districts Have Taken Responsibility for 

to Prepare for Emergencies 25

Table 8: Estimated Percentage of School Districts That Have

Procedures for Communicating with Limited-English 

Proficient Parents and Students in Their Emergency 

Management Plans 29

Table 9: Percentage of School Districts That Use the Following 

Procedures for Students with Special Needs in the Event 

of an Emergency 30

Table 10: Types of Recovery Procedures Addressed in School 

Districts Written Emergency Management Plans 31 

Page ii GAO-07-609 Emergency Management
Table 11: Percentages of School Districts with Written Plans That 

Include Certain Types of Procedures to Continue Student 

Educational Instruction in the Event of an Extended 

School Closure 32

Table 12: Percentage of School Districts That Involve Stakeholders 

in the Development and Update of Written Emergency 

Management Plans 35

Table 13: Frequency of Updates to Emergency Management Plans 36

Table 14: Estimated Frequency of Training with Each Type of First 

Responder on How to Implement the School District 

Emergency Management Plan 37

Table 15: Description of the Population and Sample of Districts 53

Table 16: School Districts Interviewed or Visited during Site Visits 55

Table 17: States Reporting Selected Requirements for School 

Districts or Schools for Emergency Management Planning 57

Table 18: States That Reported Providing Homeland Security 

Funding Directly to School Districts 60

Table 19: States and the District of Columbia That Reported 

Provided Homeland Security Funding to School Districts 

through Local Jurisdictions during Fiscal Years 2003—

2006 60

Table 20: States and the District of Columbia That Reported 

Providing Resources to School Districts to Assist in 

Emergency Management Planning 61

Figures 

Figure 1: States That Reported Having Laws or Other Policies 

Requiring School Districts or Schools to Have Emergency 

Management Plans 11 

Figure 2: Estimated Differences in Types of Security 

Enhancements Made by Urban and Rural Districts Based 

on Vulnerability Assessments 23 

Figure 3: Estimated Differences in Types of Activities Undertaken 

by Urban and Rural Districts to Prepare for Emergencies 26 

Figure 4: Estimated Percentages of Urban and Rural Districts’ 

Multi-Hazard Emergency Management Plans That Include 

Specific Incidents 27 

Page iii GAO-07-609 Emergency Management
Abbreviations 

CBSA Core Based Statistical Area 

CCD Common Core Data 

CDC Centers for Disease Control and Prevention 

CSA Consolidated Statistical Area 

DHS Department of Homeland Security 

Education Department of Education 

EMS Emergency Medical Services 

ERCM Emergency Response and Crisis Management 

FEMA Federal Emergency Management Agency 

HHS Health and Human Services 

ICS Incident Command System 

IDEA Individuals with Disabilities Education Act 

LEP Limited-English Proficient 

NIMS National Incident Management System 

NOAA National Oceanic & Atmospheric Administration

SHSP State Homeland Security Program 

SRO School Resource Officer

UASI Urban Areas Security Initiative 

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Page iv GAO-07-609 Emergency Management
United States Government Accountability Office

Washington, DC 20548 

 

June 12, 2007 

The Honorable Joseph Lieberman 

Chairman 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Joseph Lieberman 

Chairman 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Bennie Thompson 

Chairman 

Committee on Homeland Security 

House of Representatives 

The Honorable Bennie Thompson 

Chairman 

Committee on Homeland Security 

House of Representatives 

The Honorable Bob Etheridge 

The Honorable Sheila Jackson-Lee 

House of Representatives 

Maintaining the safety and security of the over 49 million students in the 

nation’s more than 17,000 public school districts has been a focus of 

federal, state, and local government for years. Federal and state 

governments and school districts have generally focused on crime in and 

around schools and violence among students. However, school districts 

must be prepared for a range of emergencies within and outside of school 

buildings. Events such as the terrorist attacks of September 11, 2001, 

natural disasters such as Hurricanes Katrina and Rita in 2005, recent 

shootings by armed intruders in schools across the nation, and potential 

pandemics have heightened the awareness of the range of events for 

which schools should be prepared. In addition, environmental and other 

types of hazards can exist in areas near school districts. For example, 

school buildings can reside near nuclear plants, electric power plants, 

railways that transport hazardous materials, major airports, or major 

interstates. 

Maintaining the safety and security of the over 49 million students in the 

nation’s more than 17,000 public school districts has been a focus of 

federal, state, and local government for years. Federal and state 

governments and school districts have generally focused on crime in and 

around schools and violence among students. However, school districts 

must be prepared for a range of emergencies within and outside of school 

buildings. Events such as the terrorist attacks of September 11, 2001, 

natural disasters such as Hurricanes Katrina and Rita in 2005, recent 

shootings by armed intruders in schools across the nation, and potential 

pandemics have heightened the awareness of the range of events for 

which schools should be prepared. In addition, environmental and other 

types of hazards can exist in areas near school districts. For example, 

school buildings can reside near nuclear plants, electric power plants, 

railways that transport hazardous materials, major airports, or major 

interstates. 

“Emergency management” refers to the range of efforts involved in 

building the capacity to prevent, protect against, respond to, and recover 

from an incident. Planning for such incidents vary by the type and scale of 

the incident. The federal government’s role in emergency management is 

principally to support state and local activities and develop the federal 

capabilities to respond effectively when state and local governments 

require federal assistance. Some federal support comes in the form of 

guidance and recommendations. Because the federal government serves 

as a partner to all states, it is uniquely positioned to observe and evaluate 

the range of emergency management activities across states and local

“Emergency management” refers to the range of efforts involved in 

building the capacity to prevent, protect against, respond to, and recover 

from an incident. Planning for such incidents vary by the type and scale of 

the incident. The federal government’s role in emergency management is 

principally to support state and local activities and develop the federal 

capabilities to respond effectively when state and local governments 

require federal assistance. Some federal support comes in the form of 

guidance and recommendations. Because the federal government serves 

as a partner to all states, it is uniquely positioned to observe and evaluate 

the range of emergency management activities across states and local

Page 1 GAO-07-609 Emergency Management
governments, including school districts, and disseminate information on 

recommended practices and successful strategies. In addition, the federal 

government, largely through the Department of Homeland Security (DHS), 

provides billions of dollars each year in grants and other forms of 

assistance to help state and local emergency managers and first 

responders (such as law enforcement, fire departments, and emergency 

medical services). Other agencies such as the Departments of Education 

(Education) and Health and Human Services (HHS) also play a part in 

supporting state and local emergency management activities with regard 

to education and public health, respectively. 

Emergency management for large-scale incidents generally requires 

partnerships among federal, state, and local governments, nongovernment 

organizations, and the private sector. For example, school districts may 

need the assistance of other organizations, including nongovernmental 

ones, in evacuating schools and finding shelter for students when an 

earthquake renders a school structurally unsafe. 

The Congress has raised concerns about whether school districts are 

prepared to address a range of emergencies, particularly acts of terrorism,

and how three federal agencies—DHS, Education, and HHS—provide 

assistance to school districts. In addition, the Congress has expressed an 

interest in getting a better understanding of whether school districts have 

emergency management plans that address the needs of students and 

parents who are classified as Limited-English Proficient (LEP), and 

students with special needs such as those with mental, physical, motor, 

developmental, or sensory impairments. 

In response to your request to examine the state of emergency 

management in the nation’s school districts, this report addresses the 

following questions: (1) What are the roles of federal and state 

governments and school districts in establishing requirements and 

providing resources to school districts for emergency management 

planning? (2) What have school districts done to plan and prepare for 

emergencies? (3) What challenges, if any, have school districts 

experienced in planning for emergencies and communicating and 

coordinating with first responders, parents, and students? 

To obtain the information to address our research objectives, we 

conducted interviews, surveys, site visits to school districts, and reviews 

of relevant documents and laws identified through surveys and site visits. 

To determine the roles and requirements of federal and state governments 

and the types of resources provided to districts, we conducted interviews

Page 2 GAO-07-609 Emergency Management
with officials with Education, HHS, and DHS and reviewed relevant

federal laws. We also administered two surveys, one to state education 

agencies and one to state administering agencies (the state agencies to 

which DHS disburses emergency management funding1

) in all 50 states 

and the District of Columbia. We received responses from 49 of 51 state 

education agencies and from 40 of 51 state administering agencies. In the 

survey to state administering agencies, we asked specifically about 

whether states or local governments provided school districts with federal 

funding from the State Homeland Security Program (SHSP), Urban Areas 

Security Initiative (UASI), and Citizen Corps grants.2

 To better understand 

how school districts plan and prepare for emergencies, we administered a 

mail survey to a stratified random sample of school districts in the 50 

states and the District of Columbia. We used the Department of 

Education’s locale coding system in the Common Core Data (CCD) to 

identify urban and rural school districts. Locale codes are based on the 

specific conditions of schools and refer to very small geographic areas and 

circumstances, such as population density and size. Although several 

criteria are used by Education to classify school districts including the 

percentage of students located in particular locale codes (assigned to 

individual schools), generally, urban districts are located within “large” 

(equal to or greater than 250,000 population) or “mid-sized” (less than 

250,000 population) cities and rural districts are located in areas 

designated as rural by the Census Bureau. Appendix I includes a more 

detailed discussion of how urban and rural districts are defined in the 

CCD. We received 444 of the 554 surveys we mailed to school districts for 

a response rate of 80 percent, including responses from 24 of the 26 largest 

school districts in the country. Using a 95 percent confidence interval, all 

percentage estimates included in this report have a margin of error of plus 

or minus 10 percent or less, unless otherwise noted. We did not survey 

individual schools within school districts. To further understand the 

experiences districts have had in planning for emergencies and 

 1

For purposes of this report, we use the term “emergency management funding” to describe 

emergency preparedness funding DHS provides to states. 

2

Under its Homeland Security Grant Program, DHS provides a range of grants to states and 

local governments for emergency management. Based on our analysis and discussions with

DHS officials, the State Homeland Security Program, Urban Areas Security Initiative, and 

Citizen Corps grants are the only grants for which states and local governments can 

disburse funds to school districts. The State Homeland Security Program provides funds to 

enhance the emergency preparedness of state and local governments. The Urban Areas 

Security Initiative grant is awarded to some states with high threat and high density urban 

areas that need planning, exercises, equipment, and training to respond to acts of 

terrorism. Citizen Corps funds are provided to states to promote volunteer efforts. 

Page 3 GAO-07-609 Emergency Management
communicating and coordinating with first responders3

, parents, and 

students, we visited selected districts in the states of Florida, Iowa, 

Massachusetts, North Carolina, Ohio, and Washington. We selected a 

geographically diverse group of states and school districts, some of which 

had been identified by national education associations as having 

implemented recommended practices in the area of emergency

management, some that did and others that did not receive federal funding

for emergency management, and we included both urban and rural 

districts. In total, we conducted semi-structured interviews, either in 

person or by telephone, with officials in 27 school districts. For more 

detailed information on our scope and methodology, see appendix I. Our 

work was conducted between April 2006 and April 2007 in accordance 

with generally accepted government auditing standards. 

Although there are no federal laws requiring all school districts to have 

emergency management plans, most states and school districts reported 

having requirements for such planning, and federal and state governments

and school districts provide financial and other resources for such plans. 

Thirty-two states reported having laws or other policies requiring school 

districts to have emergency management plans. Based on our survey, we 

estimate that 85 percent of school districts have requirements for school 

emergency management planning. Education, DHS, and state governments 

as well as school districts provide funding for emergency management 

planning in schools. DHS awards grants to states and local jurisdictions 

that may provide some of these funds to school districts and schools for 

emergency management planning. However, DHS program guidance for 

the State Homeland Security Program, Urban Areas Security Initiative, and 

Citizen Corps grants does not clearly identify school districts as entities to

Results in Brief 

 3

In both our site visits and our survey of school districts, we focused on the traditional 

definition of first responders—law enforcement, fire, and EMS. However, the Homeland 

Security Act, as amended, includes a broader definition of emergency response providers,

including “Federal, State, and local governmental and nongovernmental emergency public 

safety, fire, law enforcement, emergency response, emergency medical (including hospital 

emergency facilities), and related personnel, agencies, and authorities.” Homeland Security

Act of 2002, Pub. L. No. 107-296, § 2, (codified at 6 U.S.C. § 101(6)). Homeland Security 

Presidential Directive 8 defined the term “first responder” as “individuals who in the early 

stages of an incident are responsible for the protection and preservation of life, property, 

evidence, and the environment, including emergency response providers as defined in

section 2 of the Homeland Security Act of 2002, as well as emergency management, public 

health, clinical care, public works, and other skilled support personnel (such as equipment

operators) that provide immediate support services during prevention, response, and 

recovery operations.”

Page 4 GAO-07-609 Emergency Management
which state and local governments may disburse grant funds; therefore, 

some states receiving DHS funding may be uncertain as to whether such 

funding can be allocated to school districts or schools. As a result, school 

districts in these states may not have the opportunity to benefit from this 

funding. Federal and state governments and school districts also assist 

school districts and schools in emergency management planning by 

providing other resources such as guidance, training, and equipment. 

However, in some instances, federal guidance does not include detailed 

information on how school districts can implement recommended 

practices. 

Most school districts have taken federally recommended steps to plan and 

prepare for emergencies including the development of emergency 

management plans; while the content of plans vary, many do not include 

recommended practices. Based on our survey of school districts, we found 

that most school districts, those with and without plans, have undertaken 

a variety of recommended practices to prepare for emergencies such as 

conducting inspections to identify potential vulnerabilities of school 

facilities and grounds and holding school drills and exercises. In addition, 

we estimate that 95 percent of all school districts have written emergency 

management plans. Nearly all of those plans address multiple hazards such 

as natural disasters, intruders, and bombs but few address pandemic 

influenza or radiological hazards. The content of school district plans 

varies significantly. While most school districts have outlined roles and 

responsibilities for staff in their plans, for example, over half of all school

districts with emergency management plans have not employed 

procedures for continuing student education in the event of an extended

school closure, such as might occur during a pandemic. Likewise, while 

many districts have procedures for special needs students, we found 

during our site visits that procedures vary in the extent to which they 

ensure the safety of special needs students in an emergency. A higher 

percentage of urban school districts’ plans included procedures for special 

needs students and for communicating with Limited-English Proficient 

parents and students compared to rural districts. Fewer than half of all

school districts have involved the local head of government and fewer 

than half involved the local public health agency in the development of 

their plans. While half of all school districts update their emergency 

management plans at least once a year, an estimated 10 percent had never

updated their plans. Finally, while most school districts practice their 

emergency management plans annually within the school community, we 

estimate that over one-quarter of school districts have never trained with 

first responders and over two-thirds of school districts do not regularly 

train with community partners on how to implement their school district 

Page 5 GAO-07-609 Emergency Management
emergency management plans. The reasons why school districts do not 

train with first responders or community partners are not readily apparent. 

Many school district officials said that they experience challenges in 

planning for emergencies and some school districts face difficulties in 

communicating and coordinating with first responders and parents, but 

most said that they do not experience challenges in communicating with 

students. Based on our survey of districts, we estimate that in 70 percent 

of all school districts, officials struggle to balance priorities related to 

educating students and other administrative responsibilities with activities 

for emergency management. For example, in some of the districts we 

visited, administrators were reluctant to allocate teacher development 

training time to emergency management because of other training 

priorities. In an estimated 62 percent of all school districts, officials 

identified challenges stemming from a lack of equipment, training for staff, 

and personnel with expertise in the area of emergency planning. Officials 

noted that a lack of equipment and expertise can impact many aspects of 

emergency management, including planning for special needs students. 

For example, a school district official in Washington said that the district 

lacks equipment to evacuate special needs students from some school 

buildings and in some cases staff are unsure of how to operate the existing 

equipment. Officials also reported problems in communicating and 

coordinating with first responders and parents. In an estimated 39 percent

of school districts with emergency management plans, officials 

experienced a lack of partnerships, limited time or funding to discuss 

planning with first responders, or lack of interoperability between 

equipment used by school districts and first responders. About half of the 

officials in the 27 school districts we interviewed reported difficulty in 

ensuring that parents received consistent information from the district 

during an emergency. Some of these officials also described problems in 

communicating emergency-related information to Limited-English 

Proficient parents. 

To address issues related to the emergency management of school 

districts, we recommend that (1) DHS clearly identify school districts as 

entities to which state and local governments may disburse grant funds in 

its program guidance for the State Homeland Security Program, Urban 

Areas Security Initiative, and Citizen Corps programs to ensure that states 

and local governments are aware that they can disburse funding to school

districts and still meet funding requirements; (2) Education, in

collaboration with DHS and HHS, provide guidance to school districts on 

successful procedures for sheltering and evacuating special needs 

students during emergencies; (3) Education collaborate with HHS to 

Page 6 GAO-07-609 Emergency Management
provide specific guidance to states and school districts on how to 

incorporate, in emergency management plans, procedures for the 

continuation of education in the event of extended school closures such as 

those that might occur in the case of a pandemic (such as pandemic 

influenza); and (4) DHS and Education identify the factors that prevent 

school districts, first responders, and community partners from training 

together, develop strategies for addressing those factors, and promote 

current efforts that can help school districts in this area. 

We provided copies of this report to DHS, Education, and HHS for review 

and comment. DHS generally agreed with the intent of our 

recommendations but suggested additional language regarding the need to 

promote the use of current resources in efforts to increase school district 

training with first responders and community partners, which we 

incorporated. DHS’s comments are in appendix V. In its comments on the 

draft report, Education generally agreed with our recommendations. 

Education’s comments are in appendix VI. Finally, HHS generally agreed 

with our recommendations and asked that we include HHS in our 

recommendation that federal agencies provide additional guidance related 

to special needs students, which we accepted. HHS’s comments are in 

appendix VII. 

The Homeland Security Act of 2002 created DHS and consolidated most of 

the federal programs and agencies with responsibilities for emergency 

management into that agency.4

 DHS serves as a federal partner to state and 

local governments in emergency management.5

 DHS provides technical 

assistance and homeland security grant funding to states and local 

governments to enhance their emergency management efforts. States and

Background 

Federal Role in Emergency 

Management 

 4

Pub. L. No. 107-296. 

5

The Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. No. 100-707, 

provides the legal framework for this partnership. The Stafford Act is the principal federal

statute governing federal disaster assistance and relief and primarily establishes the 

programs for and processes by which the federal government may provide major disaster 

and emergency assistance to states and local governments. The Stafford Act also provides 

emergency assistance to tribal nations, individuals and qualified private non-profit 

organizations. The Federal Emergency Management Agency (FEMA) is the principal

federal agency responsible for implementing the Stafford Act. 

Page 7 GAO-07-609 Emergency Management
local governments have the responsibility for spending DHS grant funds in 

accordance with DHS guidelines to meet local emergency management 

needs. In fiscal year 2006, DHS awarded $1.7 billion to states, urban areas, 

and territories to prepare for and respond to terrorist attacks and other 

disasters. States and local governments may then provide a portion of this 

funding to a range of entities, as specified in DHS’s program guidance. 

As we have noted in prior reports, emergency management requires 

coordinated planning and implementation by a variety of participants. 

Effective emergency management requires identifying the hazards for 

which it is necessary to be prepared (risk assessments); establishing clear 

roles and responsibilities that are effectively communicated and well 

understood; and developing, maintaining, and mobilizing needed 

capabilities, such as people, skills, and equipment.6

 The plans and 

capabilities should be tested and assessed through realistic exercises that

identify strengths and areas that need improvement, with any needed 

changes made to both plans and capabilities. 

The hazards that school districts may face will vary across the country 

depending upon the natural hazards to which their particular areas are 

prone and an assessment of other risks for which they need to be 

prepared, such as pandemic influenza or the discharge of hazardous 

substances from nearby chemical or nuclear plants. Similarly, who should 

be involved in emergency planning and response for schools, and the roles 

of the various participants will vary by type and size of the emergency 

incident. For large-scale emergencies, effective response is likely to 

involve all levels of government—federal, state, and local—

nongovernment entities, such as the Red Cross, and the private sector. 

Funding of School

Districts 

The responsibility for funding K-12 education rests primarily with state 

and local governments. Approximately 90 percent of spending on 

education comes from state, local, and private funds. The federal 

government contributes approximately 8 to 10 percent. School districts 

are responsible for spending the funds in accordance with applicable 

federal, state, and local laws. However, the formulas states use to 

 6

GAO, Homeland Security: Preparing for and Responding to Disasters, GAO-07-395T 

(Washington, D.C.: Mar. 9, 2007); and, Catastrophic Disasters: Enhanced Leadership, 

Capabilities, and Accountability Controls Will Improve the Effectiveness of the Nation’s

Preparedness, Response, and Recovery System, GAO-06-618 (Washington, D.C.: Sept. 6,

2006). 

Page 8 GAO-07-609 Emergency Management
determine how to fund school districts and the actual amount of funding 

states and local governments spend on education can vary. 

Although no federal laws exist requiring all school districts to have 

emergency management plans, most states and school districts reported 

having requirements for school emergency management planning, and

federal and state governments and school districts provide financial and 

other resources for such planning. Education, DHS, and state governments 

as well as school districts provide funding for emergency management 

planning in schools. However, DHS program guidance does not clearly 

identify school districts as entities to which states and local governments 

may disburse grant funds. Not all states receiving DHS funding are aware 

that such funding could be disbursed to school districts. In addition to 

providing funding, federal and state governments and school districts 

assist school districts and schools in emergency management planning by

providing other resources such as guidance, training, and equipment. 

Although there are no federal laws requiring all school districts to have 

emergency management plans, many states reported having laws or other 

policies that do so. Congress has not enacted any broadly applicable laws 

requiring all school districts to have emergency management plans, nor 

have federal agencies issued any regulations imposing such a requirement 

on all school districts. However, the No Child Left Behind Act of 2001 

provides that local education agencies (LEAs or school districts) applying 

for subgrants under the Safe and Drug Free Schools and Communities 

Program include in their grant applications an assurance that either they

or their schools have “a plan for keeping schools safe and drug-free that 

includes...a crisis management plan for responding to violent or traumatic 

incidents on school grounds.” 7 Thirty-two states reported having laws or 

Many States and 

School Districts 

Reported Having 

Requirements for 

Emergency 

Management Plans, 

and Federal and State 

Governments and 

School Districts 

Provide Resources for 

Emergency 

Management Planning 

Although No Federal Laws 

Exist Requiring 

Emergency Management 

Planning, the Majority of 

States and School Districts 

Have Requirements 

 7

20 U.S.C. § 7114(d)(7)(D). The plans required under the No Child Left Behind Act of 2001

are not required to address multiple hazards; therefore, for purposes of this report, we do

not consider this to be a requirement for an emergency management plan. 

Page 9 GAO-07-609 Emergency Management
other policies requiring school districts or schools to have a written 

emergency management plan (see fig. 1). 

Page 10 GAO-07-609 Emergency Management
Figure 1: States That Reported Having Laws or Other Policies Requiring School Districts or Schools to Have Emergency

Management Plans

R.I.

N.J.

Del.

Md.

D.C.

Vt.

Ariz.

Calif.

Ga.

Ill. Ind.

Maine

Mass.

N.Mex.

N.Y.

Oreg.

Pa.

Tex.

Fla.

Miss.

Ohio

Okla.

S.Dak.

Wyo.

Alaska

Wash.

Nev.

Utah

Colo.

Minn.

Va.

S.C.

Tenn.

Source: GAO analysis of survey data; (Map) Map Resources.

States reporting requirements for districts or schools to have emergency management plans.

Hawaii

Several state laws identify a broad range of specific emergencies that 

schools or districts are required to address in their plans, while many 

other states do not identify particular kinds of crises or use more general

language to refer to the kinds of emergencies that plans must incorporate. 

For example, districts in Indiana are required to develop plans that 

address, at a minimum, fire; natural disasters such as tornadoes, floods, 

and earthquakes; adverse weather conditions, such as winter storms or 

Page 11 GAO-07-609 Emergency Management
extreme heat; nuclear contamination from power plants or vehicle spills; 

exposure to chemicals from a variety of sources; and manmade 

occurrences, such as student disturbances, weapons, weapons of mass 

destruction, water or air supply contamination, and hostage and 

kidnapping incidents. In contrast, some states, such as Pennsylvania, 

South Dakota, and Texas, among others, do not identify any specific 

hazards in their planning requirements. 

State emergency planning requirements also vary in their degree of 

prescriptiveness regarding plan development and emergency 

preparedness. For example, a number of states, including Georgia and 

Ohio, require that schools or districts involve partners, such as first 

responders, other community leaders, parents, and teachers in the 

planning process. Likewise, some states, such as Illinois and Nevada, 

specifically require that plans be reviewed annually and updated as 

appropriate. Additionally, New Jersey and other states require districts 

and schools to provide relevant district and school officials with periodic 

training related to emergency plans. In comparison, the requirements of 

some states, such as Oregon and Washington, are less detailed. For more 

detailed information on state emergency planning requirements, see 

appendix II.

Many of the school districts we surveyed also reported having emergency 

management planning requirements for schools. Based on our survey of 

school districts, we estimate that 85 percent of all districts require schools 

to have their own written emergency management plans. Of these districts, 

88 percent require that school plans be submitted to them for review. 

However, the frequencies of these reviews vary (see table 1).

Table 1: Estimated Frequency of School Districts’ Review of Schools’ Emergency

Management Plans

Frequency of school district review 

Percentage estimate of school 

districts conducting review

At least once a year 71

At least once every 2 years 7

At least once every 3 years 13

Other 5

Do not review 4

Source: GAO analysis of survey data. 

Page 12 GAO-07-609 Emergency Management
Federal Agencies, State 

Governments, and School 

Districts Provide Funding 

for School Districts’ 

Emergency Management 

Planning 

Education provides funding to some school districts specifically for 

emergency management planning through its Emergency Response and

Crisis Management (ERCM) Grant Program.8

 Since fiscal year 2003, 

Education dispersed $130 million in such grants to over 400 of the over 

17,0009

 school districts in the United States. These grant awards ranged 

from $68,875 to $1,365,087. For example, in fiscal year 2004, Seattle Public 

Schools received an ERCM grant for $494,144 to train principals in using 

the Incident Command System (ICS)10 and to establish Web-based training, 

among other things. In Tampa, Florida, a school district used a fiscal year 

2006 ERCM grant of $487,424 to install a new radio system and sponsor 

faculty workshops on emergency response. Other uses reported by school

districts we visited include establishing emergency management plans, 

 8

The purpose of the ERCM grant program is to provide funds for local education agencies 

to improve and strengthen their emergency response plans. School districts receiving grant

funds under this program may use them to develop improved plans that address all four 

phases of crisis response: prevention/mitigation, preparedness, response, and recovery. In

April 2007, Education announced that it was renaming the ERCM grant as the Readiness 

and Emergency Management for Schools grant program (REMS) to reflect terminology

used in the emergency management field. This notice also invited applications for grant

funds, with Education estimating that $24 million will be available to applicants in amounts 

ranging from $100,000 to $500,000 per school district. In awarding grants, Education will 

give priority to districts that have not previously received an ERCM grant and that are

located in a UASI jurisdiction. Applications must address, among other things, how

districts will coordinate their efforts with law enforcement, public safety, public health, 

mental health, and local government entities, as well as how the applicant will address the 

needs of individuals with disabilities. Applicants must also agree to develop an infectious 

disease plan that includes plans for continuing education services. 72 Fed. Reg. 17,139

(Apr. 6, 2007). 

9

As reported by the states to the Department of Education and contained in the Common 

Core Data (CCD), there were over 17,000 school districts in the United States in school

year 2003-04. This number includes school districts in Puerto Rico; four outlying areas 

(American Samoa, Guam, Northern Marianas, and the U.S. Virgin Islands); the Bureau of 

Indian Affairs and the Department of Defense, which were eligible for funds but we 

excluded from the sample for our survey of school districts. While Department of Defense 

schools are included in the CCD count of school districts, Education officials said that such 

schools are not eligible to receive funding under the ERCM/REMS grant program. 

10The Incident Command System is a standard incident management system to assist in

managing all major incidents. The Incident Command System also prescribes interoperable 

communications systems and preparedness before an incident happens, including planning, 

training, and exercises. The Incident Command System was developed in the 1970s

following a series of catastrophic fires. Researchers determined that response problems 

were more likely to result from inadequate management rather than from any other reason. 

The Incident Command System was designed so that responders from different 

jurisdictions and disciplines could work together better to respond to natural disasters and

emergencies, including acts of terrorism. NIMS includes a unified approach to incident

management: standard command and management structures, and emphasis on 

preparedness, mutual aid, and resource management. 

Page 13 GAO-07-609 Emergency Management
installing equipment such as closed circuit televisions, training school 

administrative staff (such as principals) on the National Incident 

Management System (NIMS) and the ICS, and purchasing emergency 

backpacks for school nurses. 

DHS also provides funding to states and local jurisdictions for emergency 

management planning, and some of this funding can be provided to school 

districts or schools for emergency management planning. DHS officials 

told us that such funds are available through the State Homeland Security 

Program (SHSP), Urban Areas Security Initiative (UASI), and Citizen 

Corps grants. Five states—Florida, Hawaii, Michigan, Mississippi, and 

Wyoming—reported that they provided approximately $14 million in DHS 

funding directly to school districts in these states during fiscal years 

2003–2006 (see table 2). Florida, for example, provided about $4.3 million 

in SHSP funds over a 2-year period to selected school districts for training, 

upgrading the districts’ emergency communications, and controlling 

access to school facilities, as well as for conducting studies related to 

emergency management. In fiscal year 2003, Michigan provided 

$8.6 million in SHSP funds to 488 of its 801 school districts to conduct 

planning exercises in response to potential terrorist events. 

Table 2: Estimated Number of School Districts That States Reported Providing

Homeland Security Funding during Fiscal Years 2003–2006 

Fiscal year Estimated number of school districtsa

2006 72

2005 85

2004 70

2003 536

Source: GAO analysis of state administering agencies survey data.

a

States may have funded the same school districts over multiple years. 

In addition, eight states and the District of Columbia reported that they 

provided DHS funding to local jurisdictions that then provided a portion of 

these funds to school districts or schools for emergency management 

planning.11 For example, South Dakota officials told us they awarded a 

portion of the state’s fiscal year 2006 SHSP funds to South Dakota’s local

 11A ninth state distributed DHS funding to its state education agency, which then provided 

the funding to public schools in its state. 

Page 14 GAO-07-609 Emergency Management
counties. These officials said that the counties then provided 

approximately $26,000 to 3 of the state’s 176 school districts for 

emergency management planning efforts. Although Oklahoma did not 

respond to our survey of state administering agencies, in February 2007, 

officials from its Office of Homeland Security issued a press release and

confirmed to us that it provided $50,000 of DHS funding (SHSP) to five 

elementary schools to enhance those schools’ physical security. They said 

that each school received a $10,000 grant to purchase equipment such as 

cameras, magnetometers, concrete barriers, identification systems, and 

two-way radios. For additional information on DHS funding that states or 

their local jurisdictions provided to school districts, see appendix III. 

Although DHS officials told us that some of its emergency planning grant 

programs, such as SHSP, UASI, and Citizen Corps allow for the use of 

funds at the district or school level, the department’s program guidance 

does not clearly specify that school districts are among the entities to 

which state and local governments may disburse funds.12 As a result, some 

states may not be aware of their availability. For example, state officials in 

Alaska and Iowa told us they were not aware that DHS emergency 

planning grants could be used by school districts. School districts in these 

states do not have the opportunity to benefit from this funding. In 

Vermont, one official expressed the view that DHS program guidance is 

unclear on the permissible use of these funds. 

Eleven of the 49 states13 responding to surveys we sent to state education 

and state administering agencies reported providing state funding to 

school districts for emergency management planning (see app. IV for a 

listing of these states). For example, the Connecticut State Department of 

Education reported that its State Legislature provided $180,000 for 

emergency management training in its state. Of these funds, the state 

disbursed $30,000 to each of Connecticut’s six education centers to train 

 12DHS guidance for these grant programs provides that state administering agencies are the

only agencies eligible to apply for funding and that they are responsible for disbursing 

grant funds to local units of government and other designated recipients. The guidance

identifies a definition of "local unit of government" which includes "any county, city, village, 

town, district, borough, parish, port authority, transit authority, intercity rail provider, 

commuter rail system, freight rail provider, water district, regional planning commission, 

council of government, Indian tribe with jurisdiction over Indian country, authorized Tribal

organization, Alaska Native village, independent authority, special district, or other

political subdivision of any State.” 

13We included the District of Columbia in our state education and state administering 

agency surveys. 

Page 15 GAO-07-609 Emergency Management
schools within its region, according to its Department of Education.14 To 

use this funding, the Connecticut State Department of Education reported 

that each education center was required to provide a minimum of three 

full-day workshops that were open to any school in its respective region. 

Hawaii also reported providing approximately $2.1 million to 62 of its 

285 schools15 to assist those schools in contracting for the services of 

School Safety Managers (mainly retired law enforcement officers) in 

developing school emergency response plans during fiscal years 

2003-2005. 

In the absence of federal and state sources, schools have been relying on 

local school district funds for the emergency management planning that

they have undertaken. Three school districts we visited reported that they 

provided funding for emergency management planning in schools. 

Officials from a school district in Ohio, Shaker Heights, said that school 

emergency management activities are funded from the school district’s 

general fund. These school district officials told us they spent about 

$100,000, not including staff hours and pay, to undertake emergency 

management planning. To help prepare for an emergency, officials in 

Olmsted Falls, Ohio, said that the school district bought one automated 

external defibrillator16 for each of its buildings. Finally, officials from 

Sequim School District in Washington told us that they spent $70,000 from

their general funds to install a camera system at one of the two elementary 

schools located in their district. 

Federal Agencies, State 

Governments, and School 

Districts also Provide 

Guidance, Training, and 

Equipment 

The federal government also provides guidance, training, and equipment to

school districts to assist in emergency management planning (see table 3).

 14Under Connecticut law, local boards of education, working in conjunction, are permitted 

to establish regional educational services centers, which provide programs and services to

schools within their designated regions. Conn. Gen. Stat. § 10-66a. 

15There were 285 schools (1 school district) in Hawaii as reported by the state to the U.S.

Department of Education.

16An automated external defibrillator (AED) is a portable electronic device that diagnoses 

and treats cardiac arrest by re-establishing an effective heart rhythm.

Page 16 GAO-07-609 Emergency Management
Table 3: Examples of Guidance, Training, and Equipment the Federal Government

Provides to School Districts

Examples of Guidance

• Education publishes a guide for schools and communities titled Practical 

Information on Crisis Planning, which explains, among other things, how schools 

can prepare for an emergency.

• Education created the Emergency Response and Crisis Management Technical

Assistance Center to help school districts in emergency management planning. 

The center provides guidance to school districts through such activities as sharing 

examples of emergency management plans, assisting with training staff, and 

evaluating emergency management plans. 

• DHS created a Web site, How Schools Can Become More Disaster Resistant, that 

provides guidance for teachers and parents regarding how to prepare emergency 

management plans. The site also discusses identifying and mitigating hazards, 

developing response and coping plans, and implementing safety drills. 

• Education funded the development of the National Clearinghouse for Educational 

Facilities—Disaster Preparedness for Schools. This Web site provides a list of 

resources (links, books, and journal articles) regarding building or retrofitting 

schools to withstand natural disasters and terrorism, developing emergency 

preparedness plans, and using school buildings to shelter community members 

during emergencies. 

• The Secret Service, an agency within DHS, collaborated with Education in 

developing and publishing a Threat Assessment Guide for Schools. The guide was 

developed following the Columbine High School attack in April 1999. Secret 

Service and Education jointly produced and disseminated a CD-ROM that served 

as a companion to this guide.

Examples of Training 

• The Federal Emergency Management Agency (FEMA), within DHS, offers online 

courses including one on emergency management planning for schools. 

• Education offers two 1-1⁄2 day Emergency Management for Schools training 

sessions that provide school personnel with critical training on emergency 

management issues, resources, and practices. Emphasis for these trainings is 

placed on emergency management plan development and enhancement within the 

framework of four phases of emergency management: prevention and mitigation, 

preparedness, response, and recovery. 

Examples of Equipment 

• With funding from DHS and support from Education, the Department of 

Commerce’s National Oceanic & Atmospheric Administration (NOAA) distributed 

96,000 NOAA radios to almost all public schools in the United States in 2005 and 

2006. These radios are intended to notify school officials of hazards in their area 24 

hours a day/7 days a week, even when other means of communication are 

disabled.a

 

Source: Education, DHS, and HHS. 

a

Schools receiving NOAA radios included schools in six states that, according to DHS, mandate that 

public schools have radios. These states are Washington, Tennessee, North Carolina, Maryland, 

Florida, and Mississippi. DHS told us that they have procedures in place to allow a school to request 

a radio if it did not receive one. DHS officials also told us that they plan to distribute NOAA radios to 

non-public schools (private, independent, parochial and other faith-based institutions), postsecondary 

education facilities, and district offices in 2007. 

Page 17 GAO-07-609 Emergency Management
Education, DHS, and HHS have collaborated and developed recommended 

practices to assist in preparing for emergencies that can be applied to 

school districts.17 Some of these practices are shown in table 4. 

Table 4: Selected Practices That Education, DHS, and HHS Recommend School

Districts Take to Prepare for Emergencies

Recommended practices 

• Allocate time to emergency management planning. 

• Conduct an assessment of vulnerabilities. 

• Conduct regular drills. 

• Identify and acquire equipment to mitigate and respond to emergencies. 

• Identify a storage location and replenish emergency supplies on a regular basis. 

• Develop an emergency management plan and update the plan on a regular basis. 

In developing and updating this plan, school districts should: 

• Identify and address a range of events and hazards specific to the district or 

schools. 

• Develop roles and responsibilities and procedures for school community 

members. 

• Develop roles and responsibilities for first responders and community partners. 

• Develop procedures for communicating with key stakeholders such as parents 

and students, including those who are Limited-English Proficient. 

• Develop procedures for special needs students. 

• Develop procedures in the plan for recovering from an incident, including 

continuing student education during an extended school closure. 

• Determine lessons learned after an incident or training. 

• Develop multi-purpose manuals, with emergency management information, that 

can be tailored to meet individual school needs. 

• Include community partners such as local government and public health agencies 

in planning. 

• Coordinate the school district’s emergency procedures with state and local 

governments. 

• Practice the emergency management plan with first responders and community 

partners on a regular basis. 

Source: GAO analysis of Education, DHS, and HHS guidance and training documents.

We have also recognized the importance of certain of these practices in 

our prior reports on emergency management.18 For example, a central 

component of all emergency management plans is defining the roles and

 17Education, for example, also obtained input from state and local school and emergency 

management officials and associations in developing these recommended practices. 

18See GAO-07-395T and GAO-06-618. 

Page 18 GAO-07-609 Emergency Management
responsibilities of all those with responsibilities for preparing to respond 

to an emergency. These roles should be clearly established, 

communicated, and understood. We have also emphasized the value of 

identifying the types of hazards for which school districts should be 

prepared as part of their emergency management efforts. These hazards 

will vary across the country; thus, it is appropriate that school emergency 

plans include hazards specific to their area. In addition, we have 

recognized the importance of realistic training exercises followed by a 

careful assessment of those exercises. Those with whom the school 

districts should coordinate and train will vary by the type and size of the 

emergency. For example, for a potential pandemic flu or other major 

infectious outbreak, planning and working with local health authorities 

and others is critical. Furthermore, “after action” reports that assess what 

went well and what did not go well following real emergency incidents or 

exercises, can also contribute to improving emergency management. 

The type of guidance available from the federal government on topics 

related to emergency management in schools varies significantly; in some 

instances federal agencies provide detailed instructions on how to 

implement recommended practices while in other instances, guidance is 

less detailed. For example, HHS and its Centers for Disease Control and 

Prevention (CDC) developed recommended practices with regard to 

pandemics and provides school districts with specific recommended steps 

for planning and coordination, infection control policies and procedures, 

and communications planning. While it also recommends that school 

districts plan for the continuity of student learning, its guidance does not

provide specific recommended steps or examples of successful strategies. 

Rather, it broadly states that schools should develop scenarios involving 

short- and long-term school closures. Likewise, Education’s guidance to

school districts, through its recommended practices, clearly states that 

districts should incorporate procedures for special needs students in 

emergency management plans. However, Education does not provide 

guidance on or examples of what those procedures could be.

In addition to the federal government, states provide guidance and training 

to school districts. Based on our survey of state administrative agencies 

and state education agencies, 47 states reported providing guidance and 

37 states reported providing training. Some states also reported providing 

online resources that include guidance and training. (See app. IV for a 

listing of these states.) For example:

Page 19 GAO-07-609 Emergency Management
• Guidance. South Dakota’s Department of Education provides 

guidance on how to distribute food during a crisis or emergency 

event that may occur at schools. 

• Training. The Maryland Department of Education offers periodic 

workshops for school system points-of-contact for emergency 

planning on topics such as threat assessment and pandemic flu. 

• Online Resources. The Idaho Department of Education provides 

links on its Web site to FEMA’s course on emergency planning for 

schools and Education’s Emergency Response and Crisis 

Management Technical Assistance Center. 

Many of the school districts we surveyed also reported providing their 

schools with guidance to assist in emergency management planning. For 

example, based on our survey, we estimate that 73 percent of all school 

districts have an emergency management plan template that includes key

elements schools should include in their plans (see table 5).

Table 5: Key Elements in Emergency Management Plan Templates by Percentage of

School Districts with Written Emergency Management Plans

Templates includes 

Estimated 

percentage of

school districts

School Campus Plan 95

Potential use of school facilities 93

School level emergency management team members 94

Procedures for communication with law enforcement 94

Procedures for contacting district-level incident response team 92

ICS positions and staff 76

Includes special needs student population 67

Source: GAO analysis of survey data. 

Page 20 GAO-07-609 Emergency Management
Almost all school districts have taken steps to prepare for emergencies, 

including developing written plans, but some plans lack key elements such 

as procedures for special needs students, plans for continued student 

education in the event of an extended closure, and procedures for training 

regularly with first responders. Most districts, those with and without 

plans, have undertaken a variety of federally-recommended activities, such 

as conducting vulnerability assessments and school drills and exercises, as 

well as additional activities to prepare for an emergency such as oversight 

and coordination with other entities. While most districts have written 

emergency management plans that address a range of hazards such as 

intruders, bombs, and natural disasters, the content of plans varies. 

Although most school districts have plans that include roles and 

responsibilities for staff, few have procedures for continuing student 

education in the event of an extended school closure. Many districts have 

procedures in their plans for special needs students, but these procedures 

vary in their ability to fully ensure the safety of these students during an 

emergency. Fewer than half of all school districts involved a 

representative from the local head of government and fewer than half 

involved the local public health agency in the development and updating of

their emergency management plans. Finally, we estimate that over onequarter of school districts with emergency management plans have never

trained with first responders and over two-thirds of school districts do not 

regularly (i.e., at least once a year) train with community partners on how 

to implement their school plans. 

Based on our survey of school districts, we estimate that 93 percent of all 

school districts conduct inspections of their school buildings and grounds

to identify possible vulnerabilities in accordance with recommended 

practices. Of those school districts, 87 percent made security 

enhancements to their school facilities and grounds as a result of these 

inspections. (See table 6.) 

Most Districts Have 

Taken Steps to 

Prepare for 

Emergencies and 

Developed Written 

Plans, but Some Plans 

Do Not Address 

Recommended 

Practices 

Most School Districts Have 

Undertaken Some 

Emergency Management 

Activities

Page 21 GAO-07-609 Emergency Management
Table 6: Types of Security Enhancements School Districts Made Based on 

Vulnerability Assessments 

Type of security enhancement implemented

Estimated 

percentage of

school districts

Added or enhanced equipment to communicate with school

employees 

85

Strengthened the perimeter security of school 70

Made inventory changes such as removing hazardous materials 69

Enhanced access controls 68

Added or enhanced equipment to communicate with law 

enforcement, fire department, and emergency medical service 

officials 

41

Reduced number of portable classrooms 10

Source: GAO analysis of survey data. 

A higher percentage of urban school districts have made certain types of 

security enhancements to schools in their districts as a result of these 

assessments compared with rural school districts. (See fig. 2.) 

Page 22 GAO-07-609 Emergency Management
Figure 2: Estimated Differences in Types of Security Enhancements Made by Urban

and Rural Districts Based on Vulnerability Assessments 

0

10

20

30

40

50

60

70

80

90

100

 Equipment to

communicate

with first

responders

Enhanced access

controls

Strengthened

perimeter security

of school

Percentage

Source: GAO analysis of survey data.

Type of security enhancement

Urban

Rural

87

81

59

62 62

35

Note: Margins of error for rural estimates do not exceed 11 percent.

Based on our survey of school districts, an estimated 73 percent of all 

school districts regularly conduct some type of school drill or exercise, in

alignment with recommended practices to prepare for emergency 

situations such as evacuations, lockdowns, and shelter-in-place. During 

our site visits, we learned that drills were tailored to the needs of the local 

community and varied by locality. For example, in Iowa—a state that is 

prone to tornados—district officials said the state requires schools to 

practice tornado drills twice a year. In Washington—a state that is prone 

to earthquakes—district officials stated they practice earthquake drills 

twice a year or more. 

Our survey of school districts revealed that an estimated 65 percent of all 

school districts have a storage location and replenish emergency supplies

such as food, water, and first-aid supplies, as recommended. During our 

site visits, school district officials identified a variety of equipment, 

Page 23 GAO-07-609 Emergency Management
supplies, and storage for different types of emergencies. In Renton, 

Washington, officials reported storing backpacks in the classrooms that 

contain enough food, water, medical supplies, and flashlights, among other 

items, for a short-term emergency. For an extended emergency, each 

school has a supply of emergency gear that includes: a 2- to 3-day supply 

of water, thermal blankets, sanitation needs, and energy bars. Similarly, 

school district officials we visited in Des Moines, Iowa, stated they have 

two kits for different types of emergencies. The first kit, designed for 

school nurses to use in evacuations, is a duffel bag containing medical 

supplies such as: bandages, splints, face masks, and eye patches, as well as

equipment such as: folding stretcher, blood pressure kit, stethoscope, and 

cold packs. The second kit, designed for custodians, is a garbage can that

contains tools as well as supplies such as a broom, gloves, rope, water, 

and bleach, among other items. In contrast, in one Washington district the 

disaster kits contain communication equipment, but they do not include 

supplies of food or water. 

In addition to conducting vulnerability assessments, school drills, and 

maintaining emergency supplies, school districts took responsibility for a 

number of activities to prepare for emergencies at the district level. These 

activities can vary by locality depending on community needs and include 

oversight, coordination with other entities, and training. (See table 7.) For 

example, in Hardee County, Florida—a district that is frequently hit by 

hurricanes—officials stated that the county designated the schools as 

shelters for the public and the school district provides staff, such as 

maintenance and food service personnel, to work at the schools as part of 

a negotiated arrangement. Officials in Pinellas County—a district that is 

frequently hit by tornados and hurricanes—told us they have trained an 

on-site district level team that coordinates emergency response activities 

during an emergency or event. 

Page 24 GAO-07-609 Emergency Management
Table 7: Activities School Districts Have Taken Responsibility for to Prepare for 

Emergencies

Type of activity

Estimated 

percentage of

school districts

Ensure school compliance with emergency preparedness 

requirements 

74

Negotiate arrangements for use of school buildings as temporary 

shelters 

72

Coordinate agreements with law enforcement, fire department, and 

emergency medical service officials 

68

Identify security personnel needs at schools 65

Identify and train a district-level incident response team 62

Source: GAO analysis of survey data. 

As shown in figure 3, a higher percentage of urban districts took 

responsibility for certain types of activities to prepare for an emergency 

compared with rural districts. 

Page 25 GAO-07-609 Emergency Management
Figure 3: Estimated Differences in Types of Activities Undertaken by Urban and

Rural Districts to Prepare for Emergencies 

0

10

20

30

40

50

60

70

80

90

100

Coordinate

agreements

with first

respondersa

 Negotiate

arrangements

for use of school

buildings as

shelters

 Train a district

level incident

response team

 Identify school

security personnel

needs

 Ensure school

compliance with

emergency

preparedness

requirements

Percentage

Source: GAO analysis of survey data.

Type of activity

Urban

Rural

88 87 86

67

81

63

74

61

57 55

a

Differences between urban and rural districts are not statistically significant. 

Most Districts Have 

Emergency Management 

Plans That Address 

Multiple Hazards, but the 

Content of Plans Varies 

Significantly 

Most school districts have developed written emergency management 

plans that address multiple hazards. Based on our survey of school 

districts, we estimate that 95 percent of all school districts have written 

emergency management plans with no statistical difference between urban 

and rural districts.19 Of those school districts that have written emergency 

plans, nearly all (99.6 percent) address multiple hazards in accordance 

with recommended practices to prepare for emergencies. However, the 

specific hazards addressed by plans vary. Although most school district 

 19Those school districts that did not have a written emergency management plan cited 

several reasons for the lack of such plans that included (1) no requirement to have a 

written plan, (2) inadequate resources for experienced personnel to develop emergency

plans, and (3) schools, not the district, have individual plans.

Page 26 GAO-07-609 Emergency Management
plans address emergency situations arising from intruders or hostages, 

bombs or bomb threats, and natural disasters, a smaller percentage of 

school districts address pandemic influenza, anthrax, or radiological 

hazards. A significantly higher percentage of urban districts address 

terrorism and anthrax, for example, compared to rural school districts.20

(See fig. 4.) 

Figure 4: Estimated Percentages of Urban and Rural Districts’ Multi-Hazard Emergency Management Plans That Include 

Specific Incidents 

0

10

20

30

40

50

60

70

80

90

100

Pandemic

influenza

Natural Terrorism Radiological Anthrax

disastersa

Bombs or

bomb threatsa

Intruder/

hostagea

Percentage

Type of incident

Source: GAO analysis of survey data.

Urban

Rural

99 98 100 98 98

95

86

70

60

29

57

26

52

36

a

Differences between urban and rural districts are not statistically significant. 

In some instances, the hazards included in emergency plans are specific to 

local conditions which is to be expected. For example, school district 

officials we visited in Hillsborough, Florida, involved representatives from

the airport in the development of their district plan because airport traffic 

was identified as a unique hazard in their local community. In Ashtabula,

 20The difference between two estimates is statistically significant if the probability that the

observed or greater difference is due to chance alone is less than 5 percent (95 percent

confidence level). 

Page 27 GAO-07-609 Emergency Management
Ohio, district officials said their plan addresses evacuations due to 

chemical spills because they have a number of chemical plants in the 

community. 

The extent to which school districts’ emergency management plans are 

consistent with other recommended practices varies: 

Develop Roles and Responsibilities for School Community 

Members. Based on our survey, most districts have written roles and 

responsibilities in their plans for staff such as superintendents, building 

engineers or custodians, principals, teachers, and nurses. Among the plans 

we reviewed, some have more detailed instructions on roles and 

responsibilities than others. For example, school district officials we 

visited in Boston, Massachusetts, have a series of emergency management 

plans for different school community members that included district 

officials, school administrators, and teachers. The school district 

document (the Crisis Command Plan) describes the organizational 

framework and response resources that the district will use to manage 

major emergencies, while a document for school administrators describes 

procedures and resources for school-level incidents. In addition, the 

district issues a classroom emergency guide that outlines procedures for 

teachers to use during an emergency. In contrast, the district plan for a 

district in Iowa lists appropriate actions for specific types of emergencies 

but does not assign roles and responsibilities for their implementation. 

Develop Roles and Responsibilities for First Responders and 

Community Partners. Based on our survey, we estimate that 43 percent 

of school districts use the Incident Command System (ICS)—established 

by DHS as part of the National Incident Management System (NIMS)21—to 

establish the roles and responsibilities of school district officials, local 

first responders, and community partners during an emergency, in 

accordance with recommended practices. A significantly higher 

percentage of urban school districts—67 percent—were responsible for 

ensuring that their emergency plans were in compliance with DHS’s NIMS 

compared to rural school districts—41 percent. 

Develop Procedures for Communicating with Key Stakeholders.

Also central to district emergency plans is the inclusion of procedures for 

communicating with key stakeholders such as staff, parents, and students, 

 21See footnote 10, page 13. 

Page 28 GAO-07-609 Emergency Management
including those who are LEP. Our survey suggests that roughly threequarters of all school districts have not included written procedures in 

their plans for communicating with LEP parents and students, in 

accordance with federally recommended practices. A significantly higher 

percentage of urban school districts report including procedures for 

communicating with such parents and students in their plans compared to 

rural school districts. (See table 8.) This difference may, in part, be 

explained by the relatively fewer LEP parents and students in rural school 

districts. 

Table 8: Estimated Percentage of School Districts That Have Procedures for 

Communicating with Limited-English Proficient Parents and Students in Their 

Emergency Management Plans 

Limited-English 

Proficient All school districts

Urban school 

districts 

Rural school 

districts 

Parents 27 59 18

Students 28 61 21

Source: GAO analysis of survey data. 

Develop Procedures for Special Needs Students. Although HHS 

officials and some education organizations report that the number of 

special needs students in the schools is growing, our survey finds that an 

estimated 28 percent of school districts with emergency management 

plans do not have specific provisions for them in their emergency 

management plans. Although most school districts reported having 

procedures for special needs students, these procedures were not 

necessarily a part of the written plan. (See table 9.) However, Education’s 

guidance recommends not only having procedures for special needs 

students but including these procedures in written emergency plans. 

Officials from two education associations said the lack of procedures in 

district plans for evacuating these students, was a significant concern.22

According to these officials, these students may be at increased risk during

an emergency. During our site visits, several school officials who did not 

have provisions in their plans for special needs students said it was a 

school, not a district-level responsibility. District officials in Marshalltown, 

Iowa, for example, said special needs student procedures are the 

responsibility of local schools. However, they said that the district does 

provide a checklist for schools that includes provisions for special needs

 22National Education Association and National Association of School Psychologists. 

Page 29 GAO-07-609 Emergency Management
students during an emergency such as communicating to first responders 

the location of special needs students who cannot be evacuated due to 

mobility impairments. A significantly higher percentage of urban school 

districts (77 percent) included procedures for special needs students in 

their written plans compared to rural school districts (62 percent). This 

may be due, in part, to several reasons such as parents of special needs 

students selecting communities to live in based on a district’s special 

needs resources or districts with low special needs student populations 

including procedures for these students in individualized education 

programs23 rather than the district plan. 

Table 9: Percentage of School Districts That Use the Following Procedures for 

Students with Special Needs in the Event of an Emergency 

Procedures for special needs students in an emergency

Estimated 

percentage

of school

districts

Track the location of special needs students during the day 74

Identify list of district or school staff assigned to evacuate or shelter with 

special needs students during emergency 

72

Provide devices for transporting special needs students to evacuation 

areas 

62 

Source: GAO analysis of survey data. 

Note: Responses are not mutually exclusive. 

Education officials told us that because there is no agreement among 

disability groups on what the best practices are for special needs students 

in an emergency, districts usually devise their own procedures.24

According to these officials, without the recommendation of experts, some 

of these procedures such as keeping special needs students in their 

 23Each student identified as having a disability under the Individuals with Disabilities 

Education Act (IDEA) is required to have an Individualized Education Program. This 

document outlines the delivery of educational services and support for that student. While 

law dictates minimum requirements for the type of information included in the program,

states and school districts have flexibility in including additional information in such

programs. 

24At a national level, there is also a lack of agreement about a definition of special needs

individuals for the purposes of emergency management. HHS officials noted that one 

definition of special needs individuals, currently being considered for the next revision of 

the National Response Plan, will help facilitate awareness and planning for special needs 

populations with regard to emergency management. 

Page 30 GAO-07-609 Emergency Management
classrooms during some emergencies may not ensure the students safety 

in an emergency. The variety of procedures was evident during our site 

visits when officials identified several procedures schools use to 

incorporate the needs of special needs students in their plans during an 

emergency. For example, school district officials in Pinellas County, 

Florida, stated that in order to evacuate special needs students during an 

emergency they use a buddy system, comprised of school staff, which the 

district updates annually. In contrast, officials in a Massachusetts school 

district said special needs students must remain in areas of refuge inside 

the school building until they are evacuated by first responders. 

Develop Procedures for Recovering from an Incident. Over half of all 

school districts with written emergency plans include procedures in their 

plans to assist with recovering from an incident, in accordance with 

recommended practices, such as by restoring district administrative 

functions and resuming transportation services. (See table 10.)

Table 10: Types of Recovery Procedures Addressed in School Districts Written 

Emergency Management Plans 

Type of recovery procedure

Estimated 

percentage of

school districts

Providing on-site trauma teams 64

Restoring district administrative functions 55

Resuming transportation services 53

Conducting damage assessments of school buildings and grounds 53

Locating district employees after a crisis is over 49

Source: GAO analysis of survey data. 

Develop Procedures for the Continuation of Student Education. 

Few school districts’ emergency plans contain procedures for continuing 

student education in the event of an extended school closure, such as a 

pandemic outbreak, although it is a federally recommended practice. 

Based on our survey, we estimate that 56 percent of school districts do not 

include any of the following procedures (see table 11) in their plans for the 

continuation of student education during an extended school closure. 

Without such procedures school districts may not be able to educate 

students during a school closure that could last from several days to a year

or longer. Moreover, there was no statistical difference between the 

percentage of urban and rural school districts that include these 

procedures in their written plans. Some school districts we visited stated 

Page 31 GAO-07-609 Emergency Management
they do not have these procedures but are currently working on 

developing a continuity of student education plan with their community 

partners, and one district official said he would like guidance from the 

state on how to provide continued instruction to students during an 

extended school closure.25

Table 11: Percentages of School Districts with Written Plans That Include Certain 

Types of Procedures to Continue Student Educational Instruction in the Event of an

Extended School Closure

Types of procedure to continue student educational instruction 

Estimated 

percentage

of school

districts with

written plans

that include 

procedure

Electronic or human telephone trees to communicate academic 

information to students 

 30

Web-based distance instruction 12

Mailed lessons and assignments 10

Academic instruction via local radio or television stations 7

Source: GAO analysis of survey data. 

Note: Responses are not mutually exclusive. 

Determine Lessons Learned. Based on our survey of school districts, 

we estimate that 38 percent of districts have emergency management 

plans that contain procedures for reviewing lessons learned to analyze 

how well the plans worked in responding to a drill or emergency. Of the 

remaining school districts, 53 percent indicated they have procedures but 

those procedures are not included in their plans and 7 percent have no 

such procedures. 

Develop Multi-Purpose Manuals. Some school districts have multipurpose manuals that contain various types of information such as roles 

and responsibilities for staff, descriptions of how to respond to different 

types of emergencies, as well as site specific information for individual 

schools to complete in order to tailor their plan. For example, in Lee 

County, North Carolina, the district manual contained a range of materials 

 25In at least one school district, Seattle, these plans are included in the district’s Continuity 

of Operations Plan, which is separate from its emergency management plan. 

Page 32 GAO-07-609 Emergency Management
and documents for schools to use and complete such as floor plans, 

student and faculty rosters, bus routes, and evacuation routes as well as 

instructions on the location and handling of utilities, such as gas and water 

valves and electrical breaker panels in school buildings, including a place 

for photographs for their easy identification. The manual also identified 

different types of hazards and delineated administrator and teacher 

responsibilities for different types of emergencies. In contrast, one plan for 

a district in Washington consisted of a flipchart with contact information 

on whom to call during an emergency, and one plan for a district in Iowa 

consisted of actions to take for various hazards but did not outline which

staff would be responsible for taking such actions. 

About Half of All Districts 

Involved Local 

Government, Public Health 

Agencies, and Other 

Partners in Developing and 

Updating Their Plans and 

Most Reported Not 

Practicing with First 

Responders 

School districts differed in the extent to which they involve community 

partner stakeholders in the development and updating of their plans.26

Fewer than half of school districts with emergency management plans 

involve community partners such as the local head of government 

(43 percent) or the local public health agency (42 percent) when 

developing and updating their emergency management plans, as 

recommended by HHS.27 During our site visits and survey pretests, school 

district officials cited a number of reasons for this lack of involvement, 

including a general lack of coordination with local government on 

emergency management efforts. Officials cited several benefits in 

coordinating with local government entities including the opportunity to 

share information, take part in joint training exercises, and receive

assistance with their emergency plans. 

While most school districts include at least one representative from the 

school and first responder community in the development and updating of

their emergency management plans, fewer involve community partners. 

(See table 12.) According to written guidance provided by Education, 

those school districts that do not include community partners in the 

development and updating of their plans may limit their opportunity to 

 26In our survey, community partners included representatives from: public health, mental

health, local head of government, transportation, hospitals, Red Cross, faith-based 

community, and the business community. 

27Twelve percent of school districts do not know whether public health agencies were 

included in the development and update of plans. Thirteen percent of districts do not know

whether the local head of government was included in the development and update of 

plans.

Page 33 GAO-07-609 Emergency Management
exchange information with local officials, take advantage of local 

resources, and identify gaps in their plan. 

We estimate that one-third of all school districts (36 percent) have School

Resource Officers (SRO) available at schools during school hours. An 

SRO28 is a fully sworn/commissioned law enforcement officer whose 

primary assignment is within the local schools.29 Of those school districts 

that have SROs, 73 percent include procedures in their plan for involving 

SROs in the event of an emergency. During our site visits, school district 

officials cited several methods they use to involve SROs in preparing for 

emergencies such as including them as a stakeholder in the annual 

discussion to update the school-level crisis response manual including 

procedures for dealing with emergencies, among others. A significantly 

higher percentage of urban school districts had SROs available on school 

grounds during school hours compared to rural school districts. We 

estimate about 81 percent of urban school districts had SROs available at 

school campuses during school hours, compared to just 16 percent of rural 

school districts. 

 28This is how we defined an SRO in our survey.

29Through its COPS (Community Oriented Policing in Schools) in Schools (CIS) program,

the Department of Justice provides three-year grants that schools may use to hire SROs. 

The program was designed in part to provide assistance to law enforcement agencies to 

help combat violence and reduce the fear of crime in schools by deploying police officers

as SROs. 

Page 34 GAO-07-609 Emergency Management
Table 12: Percentage of School Districts That Involve Stakeholders in the 

Development and Update of Written Emergency Management Plans 

Stakeholder Estimated percentage of school districts

Community Partners 

Local head of government 43

Public health agency 42

American Red Cross 30

First Responders 

Law enforcement 89

Fire department 85

Emergency Medical Services 67

School Community

Superintendent 97

Teachers 91

Building engineers 83

Nurses 76

SROs 42

Source: GAO analysis of survey data. 

More than half of all school districts with emergency management plans 

report regularly updating their emergency management plans in 

accordance with recommended practices. Specifically, we estimate that 

52 percent of all school districts with emergency plans update these plans 

at least once a year. However, 10 percent of all school districts had never 

updated their plans. (See table 13.) District officials cited several reasons 

for regularly updating their emergency management plans, including 

(1) construction modifications or renovations to school buildings, 

(2) changes to emergency contact information, (3) procedural changes 

such as new drills or evacuation routes, and (4) new legislative 

requirements, among others. However, some school district officials we 

visited had just recently completed their plans or reported that they had 

not made any changes to their plans, since they were first developed. 

According to guidance provided by Education, those school districts that 

do not regularly update their plans may risk having inaccurate and 

outdated information in their plans, which could lead to a delayed 

response during an emergency. 

Page 35 GAO-07-609 Emergency Management
Table 13: Frequency of Updates to Emergency Management Plans 

Frequency of updates 

Estimated percentage 

of school districts

At least once a year 52

At least once every 2 years 14

At least once every 3 or more years 19

Have not updated the emergency management plan 10

After an incident 1

Source: GAO analysis of survey data. 

The frequency with which districts updated their plans differed for urban 

and rural areas. A significantly higher percentage of urban school districts 

update their emergency management plans annually compared to rural 

districts—69 percent versus 43 percent, respectively. Finally, as many as 

13 percent of rural school districts have not updated their emergency 

plans at all, compared with 3 percent of urban school districts. 

Based on our survey of school districts, we estimate that 55 percent of 

school districts with written emergency management plans coordinate 

them with city or county emergency response plans. A significantly higher 

percentage of urban school districts—78 percent—coordinate their plans

with the local government emergency response plans as compared to rural 

school districts (45 percent). For example, in one Ohio school district, 

officials told us that the school district plan is a component of the city plan

in that the city will rely upon the district to make selected school buildings 

available for use as shelters, if needed in an evacuation. Likewise, officials 

in a district in Iowa said that the district plan is aligned with the county 

plan in that, during emergencies, the district’s school buses will be used to 

evacuate persons from the downtown community. Similarly, in a school 

district in Massachusetts, officials said that, in coordination with the local 

board of health’s plan, the district’s plan includes the use of the school 

facilities as inoculation sites or quarantine facilities in the event of a largescale pandemic. 

As previously discussed, most school districts identify roles and 

responsibilities for first responders and involve them in developing and 

updating their plans. However, based on our survey, we estimate that 

27 percent of all school districts with emergency management plans have 

never trained with any first responders on how to implement the plans, in 

accordance with federally recommended practices. Furthermore, we 

estimate that about three-quarters of all school districts do not regularly 

Page 36 GAO-07-609 Emergency Management
train (i.e., at least once a year) with each type of first responder—law 

enforcement, fire, or EMS—on how to implement the school district plan.

(See table 14.) The reasons why school districts are not training with first 

responders are not readily apparent. As we have previously reported, 

involving first responder groups in training and exercise programs can 

better familiarize and prepare first responders with their roles in an 

emergency as well as assess the effectiveness of a school or district’s 

emergency plan.30 Without such training, school districts and their first 

responder partners may be at risk of not responding effectively during a 

school emergency. 

Table 14: Estimated Frequency of Training with Each Type of First Responder on 

How to Implement the School District Emergency Management Plan

Law 

enforcement Firefighters

Emergency

Medical 

Services (EMS)

a

Frequency of training Percentage Percentage Percentage

At least once a year 33 31 25

At least once every 2 years 15 15 11

At least once every 3 or more years 19 19 17

Never 33 34 46

Source: GAO analysis of survey data. 

Notes: All responses are mutually exclusive. Due to rounding, percentages in each column may not 

sum to 100. 

a

During our site visits some officials told us that their emergency medical service providers were part 

of the fire department, not a separate entity. 

A significantly higher percentage of urban school districts annually train 

with law enforcement and firefighters on the school district emergency 

plan. We estimate that nearly half of urban districts annually train together 

with law enforcement (42 percent) and firefighters (43 percent) on the 

school district emergency plan, whereas less than one-quarter of rural 

school districts train annually with law enforcement (23 percent) and 

firefighters (23 percent). 

School districts report training with community partners—such as local 

public health and local government entities—on activities to prepare for 

an emergency with similar frequency. Specifically, we estimate that 

 30See GAO-06-618. 

Page 37 GAO-07-609 Emergency Management
29 percent of all school districts train with community partners. As with 

first responders, the reasons for the lack of training with community 

partners are not readily apparent. In our work on Hurricane Katrina, we 

reported that involving local community partners in exercise programs 

and training could help prepare community partners and enhance their 

understanding of their roles in an emergency as well as help assess the 

effectiveness of a school district’s emergency plan.31 Without such training, 

school districts and their community partners may not fully understand 

their roles and responsibilities and could be at risk of not responding 

effectively during a school emergency. 

Training differed for urban and rural areas. A significantly higher 

percentage of urban school districts train with community partners on 

how to implement the school district plan compared to rural school 

districts—45 percent versus 26 percent. 

Some school districts collaborate with community partners on other 

aspects of emergency preparedness. For example, one component of the 

Citizen Corps program—Community Emergency Response Teams—

instructs citizens on how to respond to emergencies (e.g., first aid) and 

participants, in turn, provide instruction to others. An official with the 

Highlands County, Florida school district said that 50 school district 

employees have participated in a Community Emergency Response Teams 

program. Likewise, in Olmstead Falls, Ohio, school district officials have 

coordinated with the American Red Cross in conducting a pandemic 

immunization drill in school facilities.

 31See GAO-06-618. 

Page 38 GAO-07-609 Emergency Management
In planning for emergencies, many school districts face challenges 

resulting from competing priorities, a lack of equipment, and limited 

expertise; some school districts experience difficulties in communicating 

and coordinating with first responders and parents, but most do not have 

such challenges with students. Within their own districts, officials struggle 

to balance activities related to educating their students with those related

to recommended practices for emergency management. Officials also 

confront a shortage of equipment and expertise necessary for planning 

and responding to emergencies. In some cases, officials noted that it was 

particularly challenging to plan for special needs students in the absence 

of such equipment and expertise. Less prevalent among school districts 

were problems in communicating and coordinating with first responders 

and parents.

School district officials who responded to our survey reported difficulty in 

following the recommended practice of allocating time to emergency

management planning, given the higher priority and competing demand on 

their time for educating students and carrying out other administrative 

responsibilities. Based on our survey of school districts, we estimate that 

in 70 percent of all districts, officials consider competing priorities to be a 

challenge to planning for emergencies. In at least two districts we visited, 

officials said that they have a limited number of staff development days32

and they want to use the time to train staff on instruction rather than 

emergency planning. For example, in one Florida district, officials noted 

that only two days a year were available for staff development, making it

difficult to cover emergency planning as well as federal and state 

requirements for schools. Officials in a North Carolina district said 

although they had the instructors they needed, they forfeited some 

emergency planning activities after the allotted number of staff 

development days were cut short. 

School Districts 

Report Challenges in 

Planning for 

Emergencies as Well 

as Difficulties in 

Communicating with 

First Responders and 

Parents, but No 

Challenges in 

Communicating with 

Students 

Competing Priorities, Lack 

of Equipment, and Limited 

Expertise Are Obstacles to 

Implementing 

Recommended Practices 

in Emergency Management 

Planning 

In an estimated 62 percent of districts, officials cited a lack of equipment 

and expertise as impediments to emergency planning. In the course of our 

site visits, officials focused primarily on shortages of three types of 

equipment: equipment to control or monitor school grounds, such as locks 

 32Districts allocate staff development days to assist teachers and other staff with improving 

skills, provide training, and meet certification requirements, among other activities. 

Page 39 GAO-07-609 Emergency Management
on doors and surveillance equipment; equipment to evacuate or maintain a 

shelter-in-place for students and staff; and communications equipment, 

such as two-way radios and satellite phones. Officials in one 

Massachusetts school district reported that they do not have adequate 

locks on some of the doors to school buildings to implement a lockdown

procedure, for example. Other districts lacked fencing for school grounds 

or surveillance cameras for school buildings. Officials also described a 

lack of sufficient equipment to maintain a shelter-in-place or evacuate 

students. Five of the 27 school districts we interviewed reported that they 

do not have generators to maintain power in school buildings. One 

superintendent in Washington noted that the district’s only school building 

is located in a remote mountainous area that could be inaccessible in the 

event of an earthquake or heavy snowfall that blocked the few access 

roads in and out of the community. Yet, according to this superintendent, 

the district does not have a generator to supply electricity in the event of 

such an emergency. Although the officials in one Massachusetts school 

district did not report problems maintaining a shelter-in-place facility, they 

said the district did not have enough school buses to accommodate all of 

the students in the case of evacuation. Finally, school officials in the 

districts we visited discussed a lack of equipment to facilitate 

communication during emergencies. In one North Carolina district, 

officials said a lack of two-way radios for staff in the elementary schools 

hinders their ability to communicate with one another and with first 

responders during an emergency.33 Similarly, in one Washington school 

district, the superintendent told us the district does not have satellite twoway radios that are needed in case conventional cellular telephones do not 

operate under the severe weather conditions common to the remote and 

mountainous location. In a district in Iowa, officials reported a need to 

replace their aging two-way radios because the radios’ signals cannot 

penetrate the walls of the school buildings. Officials in four additional 

districts stated that their districts need to update or maintain 

communication equipment. As demonstrated in these school districts, the 

lack of equipment prevents districts from implementing the procedures in 

their plans and hinders communication among district staff and with first 

responders during emergencies. 

 33Two-way radios, commonly known as walkie-talkies, are radios that can alternate 

between receiving and transmitting messages. Cellular telephones and satellite telephones 

are also two-way radios but, unlike walkie-talkies, simultaneously receive and transmit 

messages. 

Page 40 GAO-07-609 Emergency Management
In addition to not having sufficient equipment, school district officials we 

spoke with described a shortage of expertise in both planning for and 

managing emergencies. These officials said their districts lacked 

specialized personnel and training with which to develop needed 

expertise. One Washington state superintendent said he needed to provide 

those staff most likely to be present in an emergency with training on 

emergency management but would need additional funding to do so. 

District officials in 5 of the 27 districts noted that they do not having 

sufficient funding to hire full-time emergency management staff to provide 

such training or take responsibility for updating their district plans.34 Still, 

other officials described an unmet need for specific staff positions such as 

either an SRO or a school nurse to assist in planning for and responding to

emergencies. According to officials in a North Carolina district, due to a 

shortage of funding, the district did not have SROs for the district’s 

elementary schools. In this district, the SROs have a role in providing 

comments on the emergency plans of the schools to which they are 

assigned before those plans are submitted to the district for annual 

reviews. Similarly, officials in the Lee County district of North Carolina 

reported a shortage of school nurses, which they said could precipitate a 

medical crisis in an evacuation on days when a nurse is not available to 

distribute student medications or attend to those who may become ill. 

These officials noted that the lack of expertise makes it difficult to 

adequately plan for responding to emergencies. 

As previously discussed, school districts reported challenges in

incorporating special needs students in emergency management planning. 

According to officials in about half (13 of 27) of the districts in which we 

conducted interviews, a lack of equipment or expertise poses challenges 

for districts—particularly in the area of evacuating special needs students. 

In one Massachusetts school district, while schools assign persons to 

special needs students for evacuations, officials reported that these 

persons or “buddies” are typically other students, rather than experienced 

personnel.35 The students may not always be in the same classes as the 

students to whom they are assigned or may be absent from school on the 

 34Three districts, Hardee County, Florida; Ashtabula, Ohio; and Durham, North Carolina, 

reported needing a full-time staff person to train staff. Two districts, Olmsted Falls, Ohio, 

and Hanover, Massachusetts, reported needing a full-time staff person to update the district 

plan. 

35At the time of our visit, the school district used this practice for its special needs students. 

However, in a subsequent e-mail message a district official noted the district no longer uses

students as buddies. 

Page 41 GAO-07-609 Emergency Management
day of the emergency. An official in a Washington school district said that

the district tracks the location of special needs students, but many of the 

district’s schools do not have evacuation equipment (e.g., evacuation 

chairs used to transport disabled persons down a flight of stairs) to 

remove students from buildings and staff need more training on how to 

operate the existing equipment. Lee County, North Carolina, district 

officials reported that a shortage of nurses across the district has led to 

difficulties in meeting the medical needs of special needs students during 

evacuations, because nurses are the only staff permitted to physically 

remove medical supplies and distribute medicine. Because coordination 

with first responders often occurs at the district level, delegating 

responsibility for planning for special needs students to individual schools 

can result in a lack of information for first responders. In one school 

district in Ohio, a fire department official we interviewed was unaware 

that the schools in his area had assigned special aides to help evacuate 

special needs students. 

School district officials who reported challenges in planning for special 

needs students also identified challenges in adequately planning for 

temporarily disabled students (e.g., a student with a broken leg), 

maintaining a supply of surplus medical supplies for students with special 

needs, and ensuring the district maintains privacy standards related to the 

conditions of special needs students during emergencies. Finally, officials 

in three school districts stated that the districts’ school buildings are not 

all in compliance with the Americans with Disabilities Act standards,36 thus 

limiting the district’s ability to adequately plan for students with special 

needs. 

 36The Americans with Disabilities Act of 1990 and Section 504 of the Rehabilitation Act of

1973 generally require that school facilities be accessible to individuals with disabilities, 

although there is some variation in requirements depending on whether a building is new

or existing. The ADA Accessibility Guidelines for Buildings and Facilities specify the 

technical requirements for accessibility and address such issues as the design of doorways,

stairwells, elevators, and ramps. 

Page 42 GAO-07-609 Emergency Management
Some School Districts 

Reported Difficulty in 

Communicating and 

Coordinating with First 

Responders and Parents 

Based on our survey of school districts, an estimated 39 percent of 

districts with emergency plans experience challenges in communicating 

and coordinating with local first responders.37 Specifically, these school 

districts experience a lack of partnerships with all or specific first 

responders, limited time or funding to collaborate with first responders on 

plans for emergencies, or a lack of interoperability between the equipment 

used by the school district and equipment used by first responders. 

The superintendent of a Washington school district said that law 

enforcement has not been responsive to the district’s requests to 

participate in emergency drills, and, in addition to never having had a 

district wide drill with first responders, competition among city, county, 

and private first responders has made it difficult for the school district to 

know with which first responder entity it should coordinate. In another 

Washington district, the superintendent reported not having a local law 

enforcement entity in the community, but rather, a deputy from the county 

sheriff’s department that drives through the local community twice a day. 

This superintendent said that based on an absence of a relationship with 

law enforcement, he assumed that his district was essentially “on its own” 

in responding to emergencies. According to guidance provided by 

Education, the lack of partnerships, as demonstrated in these school 

districts, can lead to an absence of training that prevents schools and first 

responders from understanding their roles and responsibilities during 

emergencies. 

Even when forming partnerships is not a problem, school districts may be 

unable to find sufficient time or funding to meet with first responders on 

issues related to emergency management planning. An official in the 

Chatham, North Carolina, district said that it is difficult to find a 

convenient time for both first responders and school district officials to 

meet and discuss the district’s plan. According to an official in the Seattle 

school district, first responders for the district are more likely to meet 

with the school district when there are funds available to pay both first 

responders and district staff for such efforts. Officials in an Ohio district 

said that while first responders drill in school facilities over the weekends,

the district does not have additional funding or staff to conduct these drills 

during school hours. 

 37Thirteen percent of school districts reported not knowing whether the district has 

challenges related to first responders. 

Page 43 GAO-07-609 Emergency Management
Finally, officials we interviewed described a lack of interoperable 

equipment as a hindrance to communicating with first responders during 

emergencies. In 8 of the 27 districts in which we conducted interviews, 

officials said that the two-way radios or other equipment used in their 

school districts lacked interoperability with the radios used by first 

responders. Officials in an Iowa district said that the lack of 

interoperability among first responders38 impacts the district’s ability to 

communicate during emergencies because the district shares a radio 

frequency with some first responders but not others. 

School Districts Have 

Methods to Communicate 

with Parents, but Face 

Challenges in Ensuring 

Parents Receive 

Consistent Information 

during Incidents 

In keeping with recommended practices that call for school districts to 

have a way to contact parents of students enrolled in the district, all of the

school districts we interviewed had ways of communicating emergency 

procedures to parents prior to (e.g., newsletters), during (e.g., media, 

telephone), and after an incident (e.g., letters). Eleven of these districts 

have a system that can send instant electronic and telephone messages to 

parents of students in the district. Despite these methods, 16 of the 

27 districts we interviewed experience difficulties in implementing the

recommended practice that school districts communicate clear, 

consistent, and appropriate information to parents regarding an 

emergency. For example, officials in a Florida school district said that 

with students’ increased access to cellular telephones, parents often arrive 

on school grounds during an incident to pick up their children before the 

district has an opportunity to provide parents with information. Thus, 

according to these officials, the district experiences challenges in 

simultaneously maintaining control of both the emergency situation and 

access to school grounds by parents and others. Other districts discussed 

challenges in providing messages, during emergencies, with instructions to 

parents for reuniting with their children. Officials in the Boston school 

district said that having inaccurate telephone numbers for parents 

prevented the district from delivering messages to all parents during or 

 38GAO has reported on the range of issues associated with the lack of interoperability 

among first responders and the implications of these issues for emergency management. 

For a fuller discussion of these issues, see the following GAO reports: First Responders:

Much Work Remains to Improve Communications Interoperability, GAO-07-301 

(Washington, D.C.: Apr. 2, 2007); Catastrophic Disasters: Enhanced Leadership, 

Capabilities, and Accountability Controls Will Improve the Effectiveness of the Nation’s

Preparedness, Response, and Recovery System, GAO-06-618 (Washington, D.C.: Sept. 6,

2006); and Homeland Security: Federal Leadership and Intergovernmental Cooperation 

Required to Achieve First Responder Interoperable Communications, GAO-04-740 

(Washington, D.C.: July 20, 2004). 

Page 44 GAO-07-609 Emergency Management
after emergencies. Representatives of three education associations39 also 

noted that school districts have much to do to ensure that their emergency 

management efforts diffuse confusion during emergencies and provide 

parents with consistent information. 

Based on our survey of school districts, an estimated 39 percent of all 

school districts provide translators to communicate with LEP parents 

during emergencies, but fewer—an estimated 23 percent of all districts—

provide translations of emergency management materials. Officials in 

8 of the 27 districts we interviewed discussed challenges in retaining 

bilingual staff to conduct translations of the districts’ messages or in 

reaching parents who do not speak the languages or dialects the district 

translates. In Seattle, where the district provides translations of 10 of the 

47 languages spoken in the schools, the official we interviewed said that 

staff often experience “burn out” due to their dual roles as interpreters and 

liaisons between the local community and school district. The problem in 

retaining bilingual staff was not related to the level of work required by 

interpreters in the Hardee County, Florida, school district, but with the 

district’s inability to recruit qualified bilingual staff who also want to 

reside in the rural, hurricane-prone community. In two different districts, 

officials were unsure of whether the district’s emergency messages 

reached parents who did not speak the translated languages provided by 

the school district. Officials in the Pinellas County school district said that

they were unsure about the district’s success in getting emergency 

management information to parents who speak 1 of the 107 languages for 

which the district does not provide translations. Difficulties in 

accommodating dialects was also cited by an official of the Ashtabula, 

Ohio, school district because staff there have encountered problems 

ensuring the messages translated by telephone were understood due to the 

differences in dialects of Spanish spoken by some parents and the school 

officials providing the translated message. Our findings, while limited to 

the districts in which we conducted interviews, are consistent with the 

observations of some national education groups that have indicated that 

districts, in part due to limited funding, struggle to effectively 

communicate emergency-related information to this population of parents. 

While school districts experience a range of challenges in planning for 

emergencies and in communicating and coordinating with first responders 

 39National Education Association, American Association of School Administrators, and

National Association of Secondary School Principals. 

Page 45 GAO-07-609 Emergency Management
and parents, officials in all but one of the districts in which we conducted

interviews said that the district did not have problems communicating 

emergency procedures to students. While some of these officials did not

provide reasons, as we previously reported, most districts regularly 

practice their emergency management plans with their students and staff. 

While emergency management is overwhelmingly a state and local 

responsibility, the federal government plays a critical role in disseminating 

information on best practices, providing guidance, and giving states 

flexibility to target federal funding to areas of greatest need. While all 

three federal agencies involved in emergency management planning for 

schools have provided some resources, additional access to federal 

resources would enhance the ability of school districts to plan and prepare 

for emergencies. Given the challenges many school districts face due to a 

lack of necessary equipment and expertise, they do not have the tools to 

support the plans they have in place and, therefore, school districts are left 

with gaps in their ability to fully prepare for emergencies. Making it clear 

to states and local governments that school districts are among the entities 

to which they may disburse certain grant funds they have received from 

DHS would be one way to diversify the available emergency management 

resources to which school districts have access. 

Conclusions 

School districts have taken a number of important steps to plan for a range 

of emergencies, most notably developing emergency management plans; 

however, in many districts these plans or their implementation do not 

align with federally recommended practices. For example, because most 

districts’ plans do not have procedures to ensure the continuity of 

education in the event of extended school closures, such as those caused 

by a pandemic or natural disasters, school districts, both urban and rural, 

are largely not prepared to continue their primary mission of educating 

students. Unless the federal government examines strategies for planning 

for on-going student instruction in the event of extended school closures 

and determines which of those strategies are successful, schools may not 

have the information they need to put in place a plan that will adequately

prepare them for emergencies that require such a response. In addition, 

while most districts have procedures for special needs students in place,

because there is no agreement on procedures school districts should use 

with such students, districts may employ less than optimal or even risky 

procedures for evacuating or sheltering these students in an emergency. 

Further, while the reasons are not readily apparent and can vary as to why 

school districts do not train with first responders and community partners, 

by not training together, school districts, first responders, and community 

Page 46 GAO-07-609 Emergency Management
partners may limit their ability to effectively respond to and mitigate the 

impact of emergencies when they occur. If the federal government had 

information on why school districts do not train with first responders and

community partners, it would be better positioned to provide assistance to 

school districts that would enable them to train with first responders and

community partners on a regular basis. 

Finally, our findings show that in some areas there are vast differences in

how urban and rural districts prepare for emergencies and it appears that

urban districts are taking more actions as suggested by recommended 

practices to prepare for incidents. It may not be possible for urban and 

rural school districts to plan equally given differences in geography, 

resources, expertise, and other demographics that may warrant different

approaches. However, it is important that all districts include key 

procedures, cover the full range of incidents that could affect them, and 

practice their plans to prepare for emergencies because some incidents, 

such as natural disasters, may impact urban and rural districts alike. 

To help address the challenges school districts face in planning for 

emergencies, we recommend that the Secretary of DHS clarify that school 

districts are among those entities to which state and local governments 

may disburse grant funds received through the State Homeland Security 

Program, Urban Areas Security Initiative, and Citizens Corps grant 

programs. This should be done through its guidance for these programs so

that states and local governments will know they can disburse these 

program funds to school districts. 

Recommendations for 

Executive Action 

To address the lack of procedures for continuing student education in the 

event of an extended school closure, we recommend that the Secretary of 

Education collaborate with the Secretary of HHS in his role as head of the 

lead agency on pandemics, to examine and identify successful strategies 

for developing such procedures and provide guidance to school districts 

on how to include the resulting procedures for the continuation of student 

education in their emergency management plans. These agencies may 

consider providing specific suggestions for states and districts to work 

with state education agencies, health departments, and local community 

organizations in the process of developing these procedures. 

To help school districts shelter or evacuate students with special needs 

and temporarily disabled students in an emergency, we recommend that 

the Secretary of Education, in collaboration with the Secretaries of DHS 

and HHS, examine and identify successful procedures for sheltering and

Page 47 GAO-07-609 Emergency Management
removing such students from school buildings and share these procedures 

with school districts. 

To promote training between school districts and first responders and 

between school districts and community partners on how to implement 

district emergency management plans, we recommend that the Secretaries 

of DHS and Education identify the factors that prevent school districts, 

first responders, and community partners from training together and 

develop strategies for addressing those factors. These strategies should 

include the continued use of any current resources that could facilitate 

joint training. DHS and Education should share the strategies with school 

districts, first responders, and community partners and encourage them to

consider implementing the strategies as appropriate. 

We provided a draft of this report to DHS, Education, and HHS for review 

and comment. DHS provided written comments on May 16, 2007, which 

are presented in appendix V. In commenting on the draft report, DHS 

generally agreed with the intent of our first recommendation that it clarify 

that school districts are eligible entities to which states and local 

governments may disburse emergency management funding. While the 

department stated that it would continue to alert states and local 

governments of school districts’ eligibility through such activities as site 

visits and workshops, it did not comment on whether it would modify its 

program guidelines. Taking the opportunity to remind states and local

governments of school districts’ eligibility in such one-on-one settings 

should help to increase awareness of school districts’ eligibility. However, 

we continue to believe that DHS should explicitly include school districts 

in its program guidance, so that all state and local governments receiving 

homeland security funds would have access to guidance that provides a 

clear understanding of how to use the funding. DHS disagreed with the 

language in our fourth recommendation that the department collaborate 

with Education to identify and address the factors that prevent training 

among school districts, first responders, and community partners. DHS 

suggested that we modify the recommendation to acknowledge the need

for DHS and Education to promote current resources in addressing these 

factors. We agree with DHS’s suggestion and have revised the 

recommendation to recognize the need for DHS and Education to promote 

current resources. DHS also suggested that we include a discussion of the 

Citizen Corp Council in the report as a resource for collaboration among 

local governments, the private sector, and non-profit entities including 

school districts. We agree and have revised the report to include 

information on the Citizen Corp Council. 

Agency Comments 

and Our Evaluation 

Page 48 GAO-07-609 Emergency Management
Education provided written comments on May 7, 2007, which are included

in appendix VI. Education agreed with all four of our recommendations, 

but expressed concern about our statement that there are no federal 

requirements for school districts to have emergency management plans, 

pointing to a requirement in the No Child Left Behind Act (NCLBA) 

relating to safe and drug-free schools. As we explain in the report, we did 

not consider plans required under NCLBA to be emergency management 

plans for purposes of our report because these plans are not required to 

address multiple hazards. While Education acknowledged that we had 

included this information in a footnote, it stated that the footnote 

appeared only once. We have revised the report to more prominently 

display this information. 

HHS provided written comments on our draft report on May 8, 2007, which 

are presented in appendix VII. HHS generally agreed with our 

recommendations. However, HHS requested that Education take the lead 

with respect to our second recommendation that both agencies provide 

guidance to school districts on the continuation of education during 

extended school closures because Education is responsible for leading 

federal efforts related to the education process. We discussed the issue 

with Education officials and they agreed to take the lead on this 

recommendation. Thus, we modified the recommendation accordingly. 

HHS also requested that we include it in our third recommendation to 

provide guidance on evacuating and sheltering special needs students 

because of the agency’s expertise on special needs students. We agree and 

have modified the recommendation to include HHS. 

DHS, Education, and HHS also provided technical comments, which we 

incorporated where appropriate. 

We are sending copies of this report to the Secretaries of Education, DHS,

HHS, and relevant congressional committees. We will also make copies 

available to others upon request. In addition, the report will be made 

available at no charge on GAO’s Web site at http://www.gao.gov. 

Page 49 GAO-07-609 Emergency Management
Please contact us at (202) 512-7215 or (202) 512-8757 if you or your staff 

have any questions about this report. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Major contributors are listed in appendix VI. 

Cornelia M. Ashby, Director 

Education, Workforce and Income Security Issues

William O. Jenkins, Jr., Director 

Homeland Security and Justice Issues 

Page 50 GAO-07-609 Emergency Management
Appendix I: Scope and Methodology 

Page 51 GAO-07-609

Appendix I: Scope and Methodology 

To obtain information on federal, state, and local roles and requirements 

for school districts, how school districts prepare and plan, and any 

challenges in doing so, we interviewed staff in the Departments of 

Education, Homeland Security, and Health and Human Services; 

conducted an e-mail survey of state education agencies and an e-mail 

survey of state administering agencies; and conducted a mail survey of 

school districts from a stratified random sample of public school districts. 

We also conducted site visits during which we interviewed district 

officials, security administrators, and other officials in 27 school districts 

in six states. We conducted our work from April 2006 through March 2007 

in accordance with generally accepted government auditing standards. 

To better understand the role of states in how school districts prepare for 

emergencies, we designed and administered two surveys—one to state 

education agencies and a separate, but similar, one to state administering 

agencies—to all 50 states and the District of Columbia. The survey to state 

education agencies was conducted between August 2006 and October 

2006. The survey included questions about laws that require school 

districts to have emergency management plans, state funding provided to 

school districts, and any other resources provided to school districts. The 

survey of state administering agencies was conducted between November 

2006 and January 2007. The survey also included questions about laws 

requiring school districts to have emergency management plans, state 

funding provided to school districts, and other resources. In this survey we 

specifically asked about whether the state allocated portions of the State 

Homeland Security Program (SHSP), Urban Areas Security Initiative 

(UASI), and Citizen Corps grants to school districts. In 19 states, there 

were no UASI funds provided and we did not ask about funding related to

this program for those states. 

Survey of States 

The practical difficulties of conducting any survey may introduce 

nonsampling errors, such as variations in how respondents interpret 

questions and their willingness to offer accurate responses. We took steps 

to minimize nonsampling errors, including pretesting draft instruments 

and following up on specific responses. Specifically, during survey 

development, we pretested draft instruments with various officials. For 

the survey to state administering agencies, we pretested with officials 

representing state administering agencies in California and Maryland in 

November 2006. In the pretests, we were generally interested in the clarity 

of the questions and the flow and layout of the survey. For example, we 

wanted to ensure definitions used in the surveys were clear and known to 

the respondents, categories provided in closed-ended questions were 

Emergency Management
Appendix I: Scope and Methodology 

complete and exclusive, and the ordering of survey sections and the 

questions within each section was appropriate. 

We analyzed the requirements for schools and districts to have emergency 

management plans that were reported to us by states. In some cases, we 

determined that the laws or other requirements reported in these surveys

did not constitute emergency management planning requirements for 

purposes of this report. Accordingly, these survey responses are not 

included in our analysis of state requirements. We did not conduct any 

independent legal research to identify state legal requirements in this area. 

To obtain national-level information on school district management 

planning, we administered a mail survey to a stratified random sample of 

public school districts. The survey was conducted between September 

2006 and January 2007. To obtain the maximum number of responses to 

our survey, we sent a follow-up mailing with the full survey instrument to 

nonrespondents approximately 3 weeks after the initial mailing, and a 

reminder postcard to nonrespondents approximately 4 weeks after the 

initial mailing of the survey instrument. The survey included questions 

about whether school districts had emergency management plans, 

activities related to emergency management plans, characteristics of 

plans, district requirements of schools, and coordination with various 

persons in the school environment, local community, and first responders. 

The target population of 14,432 districts consisted of public school 

districts in the 50 states and the District of Columbia with at least one 

school in each of their jurisdictions in the 2003-2004 school year.1

 We used 

Education’s Common Core of Data (CCD) Local Education Agency 

(School District) file for the 2003-2004 school year (version 1b) as the 

basis of defining our population. To define our sampling frame, we 

removed districts from the CCD that were not a component of a 

supervisory union; state and federally-operated institutions; other 

Survey of School 

Districts 

Population 

 1

We arrived at our target population of 14,432 by eliminating certain types of school 

districts such as: local school districts that are not a component of a supervisory union,

state-operated institutions charged, at least in part, with providing elementary and/or 

secondary instruction or services to a special-need population; federally operated 

institutions charged, at least in part, with providing elementary and/or secondary 

instruction or services to a special-need population, districts with less than one student or

one school, agencies run by the Department of Defense or Bureau of Indian Affairs, and 

districts in U.S. territories. 

Page 52 GAO-07-609 Emergency Management
Appendix I: Scope and Methodology 

education agencies; had less than 1 student; were closed; run by the 

Department of Defense or Bureau of Indian Affairs; or located in American 

Samoa, Guam, Northern Marianas, Puerto Rico, or the Virgin Islands. On 

the basis of our review of these data, we determined this source to be 

adequate for the purposes of our work. 

Sample Design and Errors The sample design for the mail survey was a stratified random sample of 

districts with two certainty strata containing all of the urban and urban 

fringe districts with over 100,000 students. We defined the strata 

classifications using the locale code in the CCD. We chose districts with 

the largest number of students with certainty because the total number of 

students in these districts makes up nearly 13 percent of the total students 

in our universe. We also included four additional strata—urban, urban 

fringe, towns, and rural. Table 15 provides a description of the universe 

and sample of districts. 

Table 15: Description of the Population and Sample of Districts

Stratum Population/universe Sample size

Large urban 12 12

Large urban fringe 14 14

Urban 860 125

Urban fringe 3,795 135

Town 1,785 132

Rural 7,966 136

Total 14,432 554

Source: GAO.

We used the metro-centric locale codes assigned to each district in the 

03-04 CCD to define urban and rural. We defined urban districts to be 

those districts within a central city of a Core Based Statistical Area or 

Consolidated Statistical Area (locale codes 1 and 2). Generally, those are 

considered to be a central city of a Core Based Statistical Area (CBSA) or 

Consolidated Statistical Area (CSA), with the city having a population 

greater than or equal to 250,000 (for locale code 1) or a central city of a 

CBSA or CSA, with the city having a population less than 250,000 (for 

locale 2). Rural districts are any incorporated place, Census-designated 

place, or non-place territory and defined as rural by the Census Bureau 

(locale codes 7 and 8). These are generally defined as any incorporated 

place, Census-designated place, or non-place territory not within a CBSA 

Page 53 GAO-07-609 Emergency Management
Appendix I: Scope and Methodology 

or CSA of a large or mid-size city and defined as rural by the Census 

Bureau; and any incorporated place, Census-designated place, or nonplace territory within a CBSA or CSA of a large or mid-size city and 

defined as rural by the Census Bureau. 

Because we surveyed a sample of districts, our results are estimates of a 

population of districts and thus are subject to sampling errors that are 

associated with samples of this size and type. Our confidence in the 

precision of the results from this sample is expressed in 95 percent 

confidence intervals, which are expected to include the actual results in 

95 percent of the samples of this type. We calculated confidence intervals 

for this sample based on methods that are appropriate for a stratified 

random sample. We determined that nine of the sampled districts were out 

of scope because they were not considered to be school districts. All 

estimates produced from the sample and presented in this report are for 

the estimated target population of 14,131 districts with at least one school 

in the 2003-2004 school year. All percentage estimates included in this 

report have margins of error of plus or minus 10 percentage points or less, 

unless otherwise noted. 

We took steps to minimize nonsampling errors that are not accounted for 

through statistical tests, like sampling errors. In developing the mail 

survey, we conducted several pretests of draft instruments. We pretested 

the survey instrument with district officials in six districts—Baltimore 

County, Maryland; Carbon County, Wyoming; Citrus County, Florida; 

Muleshoe Independent, Texas; Santa Fe Public Schools, New Mexico; and 

Vigo County, Indiana—between July 25, 2006, and August 18, 2006. On the 

basis of the pretests, the draft survey instrument underwent some 

revisions. 

We received survey responses from 444, or 80 percent, of the 554 school

districts in the sample. 

To understand emergency management planning at the local level, we 

conducted site visits and conducted interviews in six states between 

September 27, 2006, and November 15, 2006. The states we visited 

included Florida, Iowa, Massachusetts, North Carolina, Ohio, and 

Washington. In each state, to the extent possible, we visited or interviewed 

(by telephone) at least one district that corresponded to the strata in our 

survey of school districts. We selected states and school districts that 

included recommended practices, some that did and did not receive

Response Rate 

Site Visits 

Page 54 GAO-07-609 Emergency Management
Appendix I: Scope and Methodology 

federal funding for emergency management, both urban and rural districts, 

and those representing geographic diversity. When viewed as a group, the 

states and school districts also provided variation across characteristics 

such as geographic location, district size, student populations, and the 

percentage of students with Limited-English proficiency or disabilities. We 

conducted a pretest of questions used in the site visits with the Alleghany 

County Public Schools district, in Maryland, on September 13, 2006. We 

used this interview to determine whether our interview questions were 

clear as well as to gauge the amount of time the interviews would take. 

In total, we interviewed officials in 27 school districts. Through our 

interviews with district officials, we collected information on the role of 

the school district in emergency management planning, state or local 

requirements, whether the district received federal, state, or local funding

and guidance, and experiences in communicating and coordinating with 

first responders, parents, and students. Table 16 indicates the school 

districts we visited during site visits or interviewed, the corresponding 

locale code, and other selected characteristics. 

Table 16: School Districts Interviewed or Visited during Site Visits 

District

Common 

Core of Data 

Locale Code

Number 

of schools

Number 

of students

Number of 

students

categorized as

Limited-English 

Proficient (LEP)

Florida

Pinellas County School District 2 (urban) 174 113,651 3,204

Hillsborough County School District 3 (urban fringe) 258 189,469 19,686

Hardee County School District 6 (town) 9 5,146 450

Highlands County School District 7 (rural) 18 12,049 517 

Washington

Seattle School District 1 (urban) 111 46,746 5,752

Renton School District 2 (urban) 26 13,236 1,485 

Sequim School District 6 (town) 5 2,950 48 

Skykomish School District 8 (rural) 2 70 2

Index School District 8 (rural) 1 30 0

Page 55 GAO-07-609 Emergency Management
Appendix I: Scope and Methodology 

District

Common 

Core of Data 

Locale Code

Number 

of schools

Number 

of students

Number of 

students

categorized as

Limited-English 

Proficient (LEP)

Iowa

Des Moines Independent Community School District 2 (urban) 72 32,194 3,502

West Des Moines Community School District 4 (urban fringe) 15 8,491 246

Marshalltown Community School District 5 (town) 9 4,922 1,203

Bondurant-Farrar Community School District 8 (rural) 2 1,042 0

Massachusetts

Boston Public Schools 1 (urban) 136 57,742 9,789

Holliston Public Schoolsa3 (urban fringe) 4 3,035 1

Hanover Public School District 3 (urban fringe) 5 2,809 2

Greenfield Public Schools 6 (town) 7 1948 91

Mashpee Public School System 8 (rural) 3 2,108 6

North Carolina 

Durham City Schools 2 (urban) 45 30,955 2,925

Wake County Schools 3 (urban fringe) 132 114,568 6,777

Lee County Schools 6 (town) 12 9,242 1,104

Granville County Schools 7 (rural) 14 8,674 452

Chatham County Schoolsa8 (rural) 15 7,404 1,004

Ohio 

Cleveland Municipal Schools (1) urban 122 64,670 3,119

Shaker Heights Schools 3 (urban fringe) 9 5,737 79

Ashtabula Area City Schoolsa6 (town) 12 4,492 145

Olmsted Falls City Schools 8 (rural) 4 3,388 12

Source: Common Core Data. 

a

We interviewed these officials by telephone. 

Page 56 GAO-07-609 Emergency Management
Appendix II: Emergency Management 

Planning Requirements 

Table 17: States Reporting Selected Requirements for School Districts or Schools for Emergency Management Planning 

Planning requirements 

Statea

State 

requirement for 

school districts

or schools to

have emergency 

management 

plans 

Specific 

hazards to

be included

in plans 

Review or

update of 

plans by the 

school 

district or

some other 

entity 

Requirements

pertaining to

drills or other 

training for

teachers 

and/or

students

Parent 

involvement 

in the 

planning 

process 

First 

respondersb

involvement 

in the 

planning 

process 

Community 

partnersc 

involvement 

in the 

planning 

process 

Alabama

Alaska X X X X XdX X

Arizona XeX

Arkansas

California X X X X Xf

Colorado X X

Connecticut

Delaware XeX X

District of Columbia

Florida X X X

Georgia X X X X X X

Hawaii

Idaho

Illinois X X XgX

Indiana X X X X

Iowa

Kansas

Kentucky

Maine X X X X X

Maryland X X X X X

Massachusetts X X X X X

Michigan

Minnesota X X X X X

Mississippi X X

Missouri

Montana

Nebraska

Nevada X X X X X X X

New Hampshire

New Jersey XeX X X X

Appendix II: Emergency Management 

Planning Requirements 

Page 57 GAO-07-609 Emergency Management
Appendix II: Emergency Management 

Planning Requirements 

Planning requirements 

Statea

State 

requirement for 

school districts

or schools to

have emergency 

management 

plans 

Specific 

hazards to

be included

in plans 

Review or

update of 

plans by the 

school 

district or

some other 

entity 

Requirements

pertaining to

drills or other 

training for

teachers 

and/or

students

Parent 

involvement 

in the 

planning 

process 

First 

respondersb

involvement 

in the 

planning 

process 

Community 

partnersc 

involvement 

in the 

planning 

process 

New Mexico X X X X

New York X X X X X

North Carolina

North Dakota

Ohio X X X X X

Oklahoma X X

Oregon X X

Pennsylvania XeX X X*

Rhode Island X X X X X X

South Carolina X X X

South Dakota X X

Tennessee X X

Texas X X

Utah X X X X X X X

Vermont X X X

Virginia X X X X

Washington Xe

Wisconsin

West Virginia

Wyoming X X

Total 32 18 18 21 9 16 10

Source: GAO analysis of state education agencies’ and state administering agencies’ survey responses. 

a

Neither Louisiana’s SEA nor its SAA responded to our survey. 

b

For purposes of this report, we define first responders to include fire, law enforcement, EMS, and 

state and local emergency management agencies. States may define this term differently. 

c

For purposes of this report, we define community partners to include public health entities, mental 

health entities, local heads of government, transportation entities, hospitals, the Red Cross, the faithbased community, and the business community. States may define this term differently. 

d

Schools are required to form crisis response teams that include, among others, a parent whose child 

attends the school. The emergency management plan must include the names of these team

members and their specific job functions relating to a crisis. However, it is not clear what role, if any, 

parents play in developing the emergency management plan. 

e

The state requirement specifies that the school or district level plan must satisfy certain minimum 

requirements developed by other entities, such as the state department of education. 

Page 58 GAO-07-609 Emergency Management
Appendix II: Emergency Management 

Planning Requirements 

f

Parents may become involved in the emergency preparedness plan development if the school site 

council, otherwise tasked with plan development, delegates planning responsibility to a school safety 

planning committee. 

g

Although first responders are not required to be involved in the development of emergency 

management plans, districts are required to invite them to participate in the annual review process. 

Page 59 GAO-07-609 Emergency Management
Appendix III: Homeland Security Funding Appendix III: Homeland Security Funding Provided to School Districts 

Provided to School Districts 

Table 18: States That Reported Providing Homeland Security Funding Directly to School Districts 

Type of DHS grant awarded to states 

and provided to school districts

Amount of grant funding provided to 

school districts during 

fiscal years 2003—2006 (Dollars in thousands) 

State 

State 

Homeland 

Security 

Program 

Urban Areas 

Security 

Initiative Citizen Corps

Fiscal 

year 2003

Fiscal 

year 2004 

Fiscal 

year 2005

Fiscal 

year 2006

Hawaii X $110 $71

Florida X 120 2,282 $2,000

X $34 36 36 46

Michigan X 8,600

Mississippi X 66 60

Wyoming X 386

Total $9,020 $266 $2,455 $2,106

Grand total $13,847

Source: GAO analysis of state administering agencies’ survey data.

Table 19: States and the District of Columbia That Reported Provided Homeland

Security Funding to School Districts through Local Jurisdictions during Fiscal 

Years 2003—2006 

Type of grant

State 

State Homeland

Security Program 

Urban Areas 

Security Initiative Citizen Corps 

Alabama X X

District of Columbia X 

HawaiiaX

Minnesota X

Nevada X X X

New Jersey X X 

North Dakota X 

Pennsylvania X

South Dakota X 

Wyoming X

Source: GAO analysis of state administering agencies’ survey data.

a

Hawaii distributed DHS funding to its state education agency, which then provided funding to public 

schools in its state. 

Page 60 GAO-07-609 Emergency Management
Appendix IV: Guidance, Training, and Funding 

States Provided to School Districts 

Table 20: States and the District of Columbia That Reported Providing Resources to

School Districts to Assist in Emergency Management Planning 

State 

Guidance 

provided

Training 

provided

State funding

provided

Alabama X X X

Alaska X X

Arizona X X

Arkansas X X

California X X X

Colorado X

Connecticut X X X

Delaware X X

District of Columbia X X 

Florida X

Georgia X X

Hawaii X X

Illinois X X

Idahoa

Indiana X X

Iowa X X

Kansas X

Kentucky X X

Louisianab

Maine X X X

Maryland X X

Massachusetts X

Michigan X X

Minnesota X X

Mississippi X X

Missouri X X X

Montana X X

Nebraska X

Nevada X

New Hampshire X X X

New Jersey X X 

New Mexico X X 

New York X X 

North Carolina X X 

Appendix IV: Guidance, Training, and 

Funding States Provided to School Districts 

Page 61 GAO-07-609 Emergency Management
Appendix IV: Guidance, Training, and Funding 

States Provided to School Districts 

State 

Guidance 

provided

Training 

provided

State funding

provided

North Dakota X X 

Ohio X X X

Oklahoma X X

Oregon X X

Pennsylvania X X

Rhode Island X 

South Carolina X X 

South Dakota X 

Tennessee X X X

Texas X X

Utahc

Vermont X X X

Virginia X

Washington X X

West Virginia X X 

Wisconsin X X

Wyoming X

Total 47 37 11

Source: GAO analysis of state administering and education agencies’ survey data. 

a

Idaho did not provide guidance, training, or state funding to school districts for emergency 

management planning. 

b

Louisiana’s state administering and education agencies did not respond to our surveys. 

c

Utah did not provide guidance, training, or state funding to school districts for emergency 

management planning. 

Page 62 GAO-07-609 Emergency Management
Appendix V: Comments from the Department Appendix V of Homeland Security : Comments from the Department 

of Homeland Security 

Page 63 GAO-07-609 Emergency Management
Appendix V: Comments from the Department 

of Homeland Security

Page 64 GAO-07-609 Emergency Management
Appendix V: Comments from the Department 

of Homeland Security

Page 65 GAO-07-609 Emergency Management
Appendix VI: Comments from the Department Appendix VI: Comments from the of Education 

Department of Education 

Page 66 GAO-07-609 Emergency Management
Appendix VI: Comments from the Department 

of Education 

Page 67 GAO-07-609 Emergency Management
Appendix VI: Comments from the Department 

of Education 

Page 68 GAO-07-609 Emergency Management
Appendix VI: Comments from the Department 

of Education 

Page 69 GAO-07-609 Emergency Management
Appendix VII: Comments from the Appendix VII: Comments from the Department of Health & Human Services 

Department of Health & Human Services 

Page 70 GAO-07-609 Emergency Management
Appendix VII: Comments from the 

Department of Health & Human Services 

Page 71 GAO-07-609 Emergency Management
Appendix VII: Comments from the 

Department of Health & Human Services 

Page 72 GAO-07-609 Emergency Management
Appendix VIII: 

A

GAO Contacts and Staff 

cknowledgments 

Page 73 GAO-07-609

Appendix VIII: GAO Contacts and Staff 

Acknowledgments 

Cornelia M. Ashby (202) 512-7215, ashbyc@gao.gov 

William O. Jenkins, Jr. (202) 512-8757, jenkinswo@gao.gov 

Kathryn Larin (Assistant Director), Debra Sebastian (Assistant Director), 

and Tahra Nichols (Analyst-in-Charge) managed all aspects of this 

assignment. Benjamin Jordan, Meaghan Marshall, and Kris Trueblood 

made significant contributions to this report. Krista Anderson, Jennifer 

Gregory, Lise Levie, and Paul Revesz also made contributions to this 

report. Sue Bernstein and Katherine Davis contributed to writing this 

report. Jim Ashley, Jean McSween, Amanda Miller, and Joan Vogel 

provided key technical support. Sheila McCoy provided legal support. 

Emergency Management

GAO Contacts 

Acknowledgments 

(130575) 
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