INFLUENZA 

PANDEMIC 

Agencies Report 

Progress in Plans to 

Protect Federal 

Workers but Oversight 

Could Be Improved 

Report to the Subcommittee on Oversight of 

Government Management, the Federal 

Workforce, and the District of Columbia, 

Committee on Homeland Security and 

Governmental Affairs, United States Senate 

July 2012 

GAO-12-748 

United States Government Accountability Office

GAO 
United States Government Accountability Office 

Highlights of GAO-12-748, a report to the 

Subcommittee on Oversight of Government 

Management, the Federal Workforce, and the 

District of Columbia, Committee on Homeland 

Security and Governmental Affairs, United 

States Senate

July 2012

INFLUENZA PANDEMIC

Agencies Report Progress in Plans to Protect 

Federal Workers but Oversight Could be Improved

Why GAO Did This Study

Federal agencies must plan to protect 

federal workers essential to ensuring the 

continuity of the country’s critical 

operations in the event of a pandemic.

GAO reported in 2009 that agencies had 

made uneven progress in developing 

operational influenza pandemic plans 

and some agencies were not close to 

having plans. In addition, there was no 

real mechanism to monitor agencies’

progress. 

GAO was asked to (1) determine what 

progress federal agencies report they 

have made since GAO’s 2009 report and 

identify challenges federal agencies 

report they face in protecting their 

workforce during an influenza pandemic, 

and (2) determine the extent to which 

oversight of agencies’ progress is being 

conducted and how the oversight 

information is being used. 

GAO surveyed the 24 agencies covered 

by the Chief Financial Officers Act of 

1990, conducted a follow-up case study 

review, and interviewed agency officials 

responsible for providing guidance to 

other federal agencies in planning for an 

influenza pandemic. 

What GAO Recommends

GAO recommends that DHS provide 

additional oversight of agencies’ 

pandemic preparedness and help focus 

attention on areas of uneven progress 

reported in GAO’s survey by directing

FEMA to include in its biennial 

assessments of agencies’ continuity 

capabilities consideration of agencies’ 

progress in assessing exposure risk 

levels of occupational exposure, 

identifying appropriate protective 

measures, and establishing operational 

plans to provide such protections for 

federal workers during an influenza 

pandemic. DHS concurred with the 

recommendation.

What GAO Found

In 2012, federal agencies reported they had made progress in planning to protect 

their federal employees during an influenza pandemic. For example: 

• Twenty-three of 24 federal agencies reported they had completed 

influenza pandemic plans that address the operational approach they 

would use to protect their employees in the event of an influenza 

pandemic. In 2009, 20 agencies reported completing such plans. 

• All 24 agencies reported that, to reduce employees’ risk of exposure to 

influenza, they developed policies or procedures such as telework and 

avoiding all unnecessary travel. In the 2009 survey, 22 agencies 

reported developing the former policy and 18 the latter. 

• All of the agencies reported that they planned for the distribution of 

hygiene supplies to protect employees whose duties require them to 

work onsite during an influenza pandemic. In 2009, 18 agencies reported 

taking this planning step. 

However, the agencies reported uneven status in some key areas suggesting 

some additional oversight is needed. For example, only nine agencies reported 

they have classified all or most jobs for onsite mission essential functions by 

exposure risk level. Additional oversight could help in ensuring that, by 

classifying jobs by exposure risk level, agencies have appropriate measures in 

place to protect those employees who must carry out mission essential functions 

that cannot be performed remotely during an influenza pandemic.

There is limited oversight of agencies’ progress to protect their employees during 

a pandemic. In 2008, the Homeland Security Council required agencies to certify 

their pandemic planning status, but according to agencies’ officials, has not done 

so since then. As in 2009, GAO interviewed four agencies—Department of 

Health and Human Services, Department of Homeland Security (DHS), 

Department of Labor, and Office of Personnel Management. Each of these 

agencies is responsible for providing influenza pandemic continuity of operations 

guidance, which includes elements such as planning, personnel protection, or 

workplace options to federal departments and agencies. DHS and the Federal 

Emergency Management Agency (FEMA) reported they conduct biennial 

assessments of department and agency continuity capabilities and report the 

results to the President through the National Continuity Coordinator. However, 

this assessment does not include planning elements specific to influenza 

pandemic planning, such as whether federal workers’ influenza pandemic risk 

assessments are regularly updated and whether agencies have planned to 

provide protective measures to mitigate exposure risks. Including such 

information in the biennial assessment process could provide monitoring, 

evaluation, and reporting of progress and help focus attention on those areas in 

which reported progress is uneven.

View GAO-12-748. For more information, 

contact Stanley Czerwinski at (202) 512-9110 

or czerwinskis@gao.gov
Page i GAO-12-748 Influenza Pandemic

Letter 1 

Background 4

Agencies Reported Progress in Planning to Protect Employees 

during an Influenza Pandemic 6

Agencies’ Plans and Progress to Protect Federal Workers During 

an Influenza Pandemic Receive Limited Oversight 29

Conclusions 33

Recommendation For Executive Action 34

Agency Comments 34

Appendix I Chief Financial Officers Act Agencies 36

Appendix II List of Agencies and Selected Components 37

Appendix III Objectives, Scope, and Methodology 38

Appendix IV Comments from the Department of Homeland Security 40

Appendix V GAO Contact and Staff Acknowledgments 42

Related GAO Products 43

Table

Table 1: List of Agencies with Selected Components 15

Figures

Figure 1: Agencies Reported Progress in Completing Influenza 

Pandemic Plans 7

Contents
Page ii GAO-12-748 Influenza Pandemic

Figure 2: All Agencies Reported Plans to Protect Federal Workers 

through Use of Social Distancing Strategies and Hygiene 

Supplies 9

Figure 3: Agencies Reported Progress Employing Additional 

Protective Strategies 10

Figure 4: All Agencies Reported Progress in Making Human Capital 

Information Available to Employees 11

Figure 5: Agencies Reported Testing Various Information 

Technology and Telecommunications Capabilities 12

Figure 6: Majority of Agencies Reported Requiring Components to 

Complete Influenza Pandemic Plans 14

Figure 7: Selected Components’ Influenza Pandemic Planning 

Efforts 16

Figure 8: Agencies Reported Using Various Social Distancing 

Strategies to Avoid Situations that Increase Workers’ Risk 

of Exposure for Selected Components 17

Figure 9: Selected Components’ Facility-Level Influenza Pandemic 

Plans 18

Figure 10: Use of Various Social Distancing Strategies in FacilityLevel Influenza Pandemic Plans 19

Figure 11: Agencies Reported Identification of Onsite Mission 

Essential Functions and Determination and Notification 

of Employees Tasked With Such Functions 20

Figure 12: Agencies Reported Uneven Status in Classifying Jobs by 

Exposure Risk Level for Onsite Mission Essential 

Functions 22

Figure 13: Many Agencies Reported Classifying Jobs by Exposure 

Risk Level for Selected Component’s Onsite Mission 

Essential Functions 23

Figure 14: Most Frequently Reported Challenges in Planning for 

Federal Worker Protection for an Influenza Pandemic 24

Abbreviations 

ATO Air Traffic Organization

CDC Centers for Disease Control and Prevention

CFO Act Chief Financial Officers Act of 1990

Commerce Department of Commerce

COOP continuity of operations

DHS Department of Homeland Security
Page iii GAO-12-748 Influenza Pandemic

DOD Department of Defense

DOE Department of Energy

DOT Department of Transportation

Education Department of Education

EPA Environmental Protection Agency

evaluation tool Continuity Evaluation Tool

FAA Federal Aviation Administration

FEMA Federal Emergency Management Agency

GSA General Services Administration

HHS Department of Health and Human Services

HSC Homeland Security Council

HUD Department of Housing and Urban Development

Implementation Plan National Strategy for Pandemic Influenza 

Implementation Plan 

IT information technology

Key Elements Key Elements of Departmental Pandemic Influenza 

Operational Plans

Labor Department of Labor

NASA National Aeronautics and Space Administration 

NCC National Continuity Coordinator

NOAA National Oceanic and Atmospheric Administration

NRC Nuclear Regulatory Commission

NRF National Response Framework

NRR Office of Nuclear Reactor Regulation

NSC National Security Council

NSF National Science Foundation

NSS National Security Staff

OPM Office of Personnel Management

OSHA Occupational Safety and Health Administration

SARS Severe Acute Respiratory Syndrome

SBA Small Business Administration

SSA Social Security Administration

State Department of State

Treasury Department of the Treasury

USAID U.S. Agency for International Development

USDA Department of Agriculture

VA Department of Veterans Affairs
Page iv GAO-12-748 Influenza Pandemic

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Page 1 GAO-12-748 Influenza Pandemic

United States Government Accountability Office

Washington, DC 20548

July 25, 2012

The Honorable Daniel K. Akaka

Chairman

The Honorable Ron Johnson

Ranking Member

Subcommittee on Oversight of Government Management, the Federal 

Workforce, and the

 District of Columbia

Committee on Homeland Security and Governmental Affairs

United States Senate

During an influenza pandemic many federal employees will be able to 

perform their agencies’

1 mission essential functions2 remotely through 

telework arrangements, but other federal employees, such as air traffic 

controllers, will have to work at assigned locations where there will be an

increased chance of infection due to proximity to others. Anxiety and 

concern over working during an influenza pandemic could reduce the 

number of critical federal employees available to work. For example, 

researchers who studied the attitudes of emergency pre-hospital medical 

care providers concluded that absenteeism could significantly impair the 

community’s frontline medical response.3

 

1

Throughout this report, we use “agencies” to refer to all parts of cabinet-level 

departments (e.g., Department of Transportation) or independent agencies (e.g., 

Environmental Protection Agency), including headquarters-level components, operational 

components, and field-based entities. 

Among the reported lessons 

learned from the 2003 outbreak of Severe Acute Respiratory Syndrome 

(SARS) in Toronto was that although health care workers have a duty to 

2

According to the Department of Homeland Security’s Federal Continuity Directive 1, 

mission essential functions are described as the limited set of agency-level government 

functions that must be continued throughout, or resumed rapidly after, a disruption of 

normal activities. Mission essential functions are those functions that enable an 

organization to provide vital services, exercise civil authority, maintain the safety of the 

general public, and sustain the industrial and economic base during disruption of normal 

operations. 

3

C. Irvin, L. Cindrich, W. Patterson, and A. Southall, “Survey of Hospital Healthcare 

Personnel Response during a Potential Avian Influenza: Will They Come to Work?” 

Prehospital and Disaster Medicine, vol. 23, no.4 (2008): 328-335. F. Archer, M. Coory, K.

Jamrozik, H. Kelly, S. Raven, V. Tippett, and K. Watt, “Anticipated Behaviors of 

Emergency Prehospital Medical Care Providers during an Influenza Pandemic.” 

Prehospital and Disaster Medicine, vol. 25, no.1 (2010): 20-25.

 
 

Page 2 GAO-12-748 Influenza Pandemic

provide care, institutions have a reciprocal duty to support health care 

workers so they can do their jobs as effectively and safely as possible.4

The Homeland Security Council’s (HSC)5 2006 National Strategy for 

Pandemic Influenza Implementation Plan (Implementation Plan)6 required 

federal agencies to develop operational influenza pandemic plans that 

provide for the health and safety of their employees and ensure the 

agency will be able to maintain its essential functions and services in the 

face of significant and sustained absenteeism. According to the 

Implementation Plan, an operational influenza pandemic plan should 

articulate the manner in which the department, including its components,7

plans to discharge its responsibilities to support the federal efforts in 

fighting an influenza pandemic; address the operational approach to 

employee safety and continuity of operations; and describe how the 

department plans to communicate with its stakeholders. The challenges 

that agencies must address include (1) identification of onsite mission 

essential functions that must be continued and those employees who 

must perform them and (2) implementation of workforce strategies and 

measures to protect those employees who must continue such functions. 

We reported in 2009 that agencies’ progress was uneven in influenza 

pandemic planning and some agencies were not close to having 

operational influenza pandemic plans.8

 

4

S. Benatar, M. Bernstein, A. Daar, B. Dickens, S. MacRae, R. Shaul, P. Singer, R. 

Upshur, and L. Wright, “Ethics and SARS: lessons from Toronto.” BMJ, vol. 327 (2003): 

1342-1344.

We also reported that the Federal 

5

The HSC was established pursuant to Executive Order 13228, on October 8, 2001, for 

purposes of advising and assisting the President with respect to all aspects of homeland 

security and serving as a mechanism for ensuring (1) coordination of homeland securityrelated activities of executive departments and agencies and (2) effective development 

and implementation of homeland security policies. Congress subsequently established the 

HSC for the purpose of more effectively coordinating the policies and functions of the 

federal government relating to homeland security. See Homeland Security Act of 2002, 

Pub. L. No. 107-296 (Nov. 25, 2002), 6 U.S.C. § 491 and § 494. 

6

HSC, National Strategy for Pandemic Influenza Implementation Plan (Washington, D.C.: 

May 2006). 

7

Components refer to subordinate entities of departments such as component agencies, 

field or regional offices, or other operating divisions. For example, the Federal Aviation 

Administration is a component of the Department of Transportation. 

8

GAO, Influenza Pandemic: Increased Agency Accountability Could Help Protect Federal 

Employees Serving the Public in the Event of a Pandemic, GAO-09-404 (Washington, 

D.C.: June 12, 2009).
 

Page 3 GAO-12-748 Influenza Pandemic

Aviation Administration (FAA) faced unique challenges protecting air 

traffic controllers who must perform essential onsite functions during an 

influenza pandemic.

In June 2009, we reported that there was no mechanism in place to 

monitor and report on agencies’ progress in developing influenza 

pandemic plans to protect their workforce and recommended that the

HSC request that the Department of Homeland Security (DHS) monitor 

and report to the Executive Office of the President on the readiness of 

agencies to continue their operations while protecting their employees in 

the event of a pandemic. The HSC noted that it would give serious 

consideration to our report findings and recommendations, and DHS said 

the report findings and recommendations would contribute to its efforts to 

ensure that government entities are well prepared for what may come 

next. Given the importance of agencies’ ability to continue operations 

while protecting their employees in the event of an influenza pandemic, 

you asked us to (1) determine what progress federal agencies report they 

have made since our 2009 report and identify challenges federal 

agencies report they face in protecting their workforce during an influenza 

pandemic; and (2) determine the extent to which oversight of agencies’ 

progress was being conducted and how the oversight information is being 

used.

To address these objectives, we surveyed the 24 agencies covered by 

the Chief Financial Officers Act of 1990 (CFO Act) to determine whether 

they made progress in their preparedness to protect their workforce since 

our 2009 survey and to identify challenges they faced in planning for 

protection of their workers. All 24 CFO Act agencies completed the 

survey for a response rate of 100 percent. In addition, to better 

understand the extent to which influenza pandemic planning had filtered 

down to the component and facility levels, we also gathered data from 

these levels in our 2012 survey. In our 2009 survey, 15 of 24 agencies 

provided examples of key component-level mission essential functions 

that could not be performed remotely during an influenza pandemic. 

Using those examples, we selected a component from each of these 15 

agencies for our 2012 survey and surveyed the agencies to determine 

whether they had made plans at lower organizational levels to protect 

their employees whose onsite presence was necessary in order to carry 

out mission essential functions. In addition to these surveys, we 

conducted follow-up work to assess FAA’s progress in addressing the 

unique challenges we highlighted in our 2009 report regarding protection 

for air traffic controllers who must perform onsite mission essential 

functions during an influenza pandemic. Further, we analyzed 
 

Page 4 GAO-12-748 Influenza Pandemic

documentation of oversight activities and interviewed officials from the 

Department of Health and Human Services (HHS), DHS, Federal 

Emergency Management Agency (FEMA), Department of Labor’s (Labor) 

Occupational Safety and Health Administration (OSHA), and the Office of 

Personnel Management (OPM), who were tasked with providing 

guidance, policy, or influenza pandemic related expertise to other federal 

agencies in planning for an influenza pandemic. Lastly, we reviewed the 

Implementation Plan, National Response Framework (NRF),9

We conducted this performance audit from July 2011 through July 2012 in 

accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. Detailed information on our 

scope and methodology appears in appendix III.

our prior 

work assessing influenza, and other relevant literature to help inform our 

analyses.

The federal government employed over 4.3 million federal employees 

throughout the United States and abroad in 2010.10

In the event of any emergency, federal employees responsible for their 

agencies’ mission essential functions will be expected to continue them in 

order to sustain agency operations. Unlike incidents that are discretely 

bounded in space or time (e.g., most natural or man-made disasters), an 

influenza pandemic is not a singular event, but is likely to come in waves, 

each lasting weeks or months, and pass through communities of all sizes 

Federal employees 

perform functions across a multitude of sectors, from those vital to the 

long-term well-being of the country—such as environmental protection, 

intelligence, social work, and financial services—to those directly charged 

with aspects of public safety—including corrections, airport and aviation 

safety, medical services, border protection, and agricultural safety.

 

9

DHS, National Response Framework (Washington, D.C.: January 2008). 

10OPM, “Historical Federal Workforce Tables: Total Government Employment Since 

1962,” accessed July 17, 2012, 

http://www.opm.gov/feddata/HistoricalTables/TotalGovernmentSince1962.asp. 

Background 
 

Page 5 GAO-12-748 Influenza Pandemic

across the nation and the world simultaneously, as we have witnessed 

with the 2009 H1N1 influenza pandemic. While a pandemic will not 

directly damage physical infrastructure such as power lines or computer 

systems, it threatens the operation of critical systems by potentially 

removing the essential personnel needed to operate them from the 

workplace for weeks or months because of illness, the need to care for 

family members who are sick, or fear of becoming infected.

In response to concerns that the emergence of H5N1 avian influenza (or 

bird flu) in Asia in 2003 would mutate and result in a human influenza 

pandemic, the President and his HSC issued two planning documents. 

Issued in November 2005, the National Strategy for Pandemic Influenza11

To help federal agencies plan for and respond to an influenza pandemic, 

the HSC issued the Key Elements of Departmental Pandemic Influenza 

Operational Plans (Key Elements),

provides a high-level overview of the approach that the federal 

government will take to prepare for and respond to an influenza

pandemic. The Implementation Plan issued in May 2006 lays out the 

broad implementation requirements and responsibilities among the 

appropriate federal agencies, including that agencies have operational 

influenza pandemic plans that address the protection of federal 

employees, and clearly defines expectations of nonfederal entities.

12 a checklist for federal agencies to 

use in planning their influenza pandemic preparedness. The checklist 

includes elements covering plans and procedures, essential functions and 

services, safety and health for their employees, communications, human 

capital, and information technology (IT) capabilities. The Key Elements 

also reference Federal Continuity Directives 1 and 2, which guide the 

identification of mission essential functions,13

 

11HSC, National Strategy for Pandemic Influenza (Washington, D.C.: November 2005). 

and instructs agencies to 

include functions that cannot be deferred for 12 weeks or more without 

12HSC, Key Elements of Departmental Pandemic Influenza Operational Plans

(Washington, D.C.: August 2008).

13In February 2008, the Secretary of Homeland Security released two federal continuity 

directives: Federal Continuity Directive 1 provides direction for the development of 

continuity plans and programs for the federal executive branch, and Federal Continuity 

Directive 2 provides additional guidance for agencies in identifying their mission essential 

functions. 
 

Page 6 GAO-12-748 Influenza Pandemic

impact to an agency’s mission and nonessential functions that can be 

suspended temporarily during an influenza pandemic.

We reported in June 2009 that the HSC requested that federal agencies 

certify to the council that they were addressing applicable elements of the 

Key Elements checklist in December 2006 and October 2008.14 Because 

the certification process, as implemented, did not provide for monitoring 

and reporting as envisioned in the Implementation Plan, we 

recommended in our June 2009 report that the HSC request that the 

Secretary of Homeland Security monitor and report to the Executive 

Office of the President on the readiness of agencies to continue their 

operations while protecting their employees in the event of an influenza 

pandemic. In commenting on our report, the Acting Executive Secretary 

of the HSC noted that the report made useful points regarding 

opportunities for enhanced monitoring and reporting within the executive 

branch concerning agencies’ progress in developing plans to protect their 

workforce. The official also noted that the council would give serious and 

careful consideration to the report findings and recommendations. We will 

discuss HSC and DHS’s efforts in more detail later in the report.

 

14GAO-09-404. 

Agencies Reported 

Progress in Planning 

to Protect Employees 

during an Influenza 

Pandemic 
 

Page 7 GAO-12-748 Influenza Pandemic

As shown in figure 1, almost all of the agencies we surveyed—or an 

increase of three agencies since 2009—reported in 2012 that they have 

completed influenza pandemic plans15

Figure 1: Agencies Reported Progress in Completing Influenza Pandemic Plans

that address the operational 

approach for how they would protect their federal employees in the event 

of an influenza pandemic. HHS reported that while they will continue to 

work towards a final document, they recognize the need for continuous 

improvement and incorporation of lessons learned. They describe the 

draft influenza pandemic plan as a “living document” that allows for 

continuous updates. Because of that, they do not have a target date for 

when a final plan will be completed. Additionally, HHS is supporting a 

series of research studies on the effectiveness of respirators or surgical 

masks to prevent influenza infection and to better understand their role in 

workforce protection. HHS reports that pandemic planning is an ongoing 

process that is shaped by lessons learned in the field as well as 

improvements in the medical and scientific research base.

In addition, 20 agencies reported that their influenza pandemic plans 

addressed how they would protect federal employees who maintained 

mission essential functions that could not be performed remotely during 

an influenza pandemic. Of the four remaining agencies, three of them—

including the Department of Education (Education), General Services 

 

15For purposes of our survey, we defined “pandemic plan” as any document that 

contained information related to an influenza pandemic. Specifically, a pandemic plan 

could be a standalone plan or part of a broader plan (e.g. annex to an all-hazards plan or 

continuity of operations (COOP) plan). 

Additional Agencies 

Reported Completing 

Influenza Pandemic Plans 

to Protect Their Federal 

Workers
 

Page 8 GAO-12-748 Influenza Pandemic

Administration (GSA), and Small Business Administration (SBA)—

reported all of their mission essential functions could be performed 

remotely, and the U.S. Agency for International Development (USAID) 

reported that its plan was being updated to include this information.

According to OSHA guidance on protecting workers, the best strategy to 

reduce the risk of becoming infected with influenza during an influenza 

pandemic is to avoid crowded settings and other situations that increase 

the risk of exposure to someone who may be infected. If it is absolutely 

necessary to be in a crowded setting, the time spent in a crowd should be 

as short as possible. Some basic hygiene and social distancing16

precautions, such as encouraging employees to wash their hands or use 

a hand sanitizer after they cough, sneeze, or blow their noses, can be 

implemented in every workplace.17

 

16OSHA defines social distancing as reducing the frequency, proximity, and duration of 

contact between people to reduce the chances of spreading influenza pandemic from 

person-to-person. 

Figure 2 shows progress agencies 

reported to have made incorporating various protective strategies since 

2009. Specifically, all of the agencies reported that they developed 

policies or procedures consistent with this strategy such as telework and 

avoiding all unnecessary travel. They have also planned for the 

distribution of hygiene supplies to protect employees whose duties 

require their presence at an assigned workplace during an influenza 

pandemic.

17OSHA, Guidance on Preparing Workplaces for an Influenza Pandemic, OSHA 3327-02N 

2007. 

Agencies Reported 

Progress Incorporating 

Protective Strategies into 

Their Influenza Pandemic 

Plans
 

Page 9 GAO-12-748 Influenza Pandemic

Figure 2: All Agencies Reported Plans to Protect Federal Workers through Use of Social Distancing Strategies and Hygiene 

Supplies

Moreover, as shown in figure 3, agencies reported an increase over 2009 

in a variety of other actions that could reduce the risk of exposure for 

federal workers, including the use of flexible schedules to reduce the 

number of employees who must be at work at one time or in one specific 

location and implementing pandemic influenza-specific office protocols 

such as no-handshake policies. However, not all of these actions may be 

applicable to all workplace settings.
 

Page 10 GAO-12-748 Influenza Pandemic

Figure 3: Agencies Reported Progress Employing Additional Protective Strategies
 

Page 11 GAO-12-748 Influenza Pandemic

According to Federal Continuity Directive 1, agencies must implement a 

process to communicate human capital guidance for emergencies, such 

as pay, leave, staffing, and other human resources flexibilities, to 

employees to ensure continuity of mission essential functions during an 

emergency. Given the potential severity of an influenza pandemic, it is 

important that employees understand the policies and requirements of 

their agencies and the alternatives, such as telework, that may be 

available to them.

While a majority of agencies surveyed in 2009 reported they had made 

information available to employees on how human capital policies and 

flexibilities would change in the event of an influenza pandemic, figure 4 

shows that all surveyed agencies reported in 2012 that they have made 

such information available to their employees.

Figure 4: All Agencies Reported Progress in Making Human Capital Information Available to Employees 

All Surveyed Agencies 

Reported Providing 

Human Capital 

Information to Employees
 

Page 12 GAO-12-748 Influenza Pandemic

As noted earlier, all of the agencies reported that they developed policies 

or procedures for using telework in the event of an influenza pandemic. In 

our 2012 survey, we asked agencies if they had tested the various modes 

of IT and telecommunications capabilities to ensure that they would be 

capable of handling employees working remotely during an influenza 

pandemic. As shown in figure 5, almost all of the agencies reported to 

have tested e-mail, teleconferencing, intranet access, and access to vital 

records or files. Desktop videoconferencing was the least tested mode 

because a majority of federal agencies reported that they did not have 

such capabilities.

Figure 5: Agencies Reported Testing Various IT and Telecommunications Capabilities

Almost All Agencies 

Reported Testing IT 

Capabilities for Handling 

Telework during an 

Influenza Pandemic
 

Page 13 GAO-12-748 Influenza Pandemic

We previously reported that it is important to recognize that agency 

influenza pandemic plans will continue to be revised and improved with 

additional time and information regarding influenza pandemic 

preparedness.18 One recent event that prompted agencies to consider 

such revisions to their plans was the 2009 H1N1 influenza pandemic, 

which was the first human influenza pandemic in more than 4 decades.19

Three agencies—the Department of Defense (DOD), Department of 

Veterans Affairs (VA), and National Science Foundation (NSF)—reported 

that they were planning to update their plans to include lessons learned 

from the 2009 H1N1 influenza pandemic during 2012 and 2013. In 

contrast, the Department of Agriculture (USDA), Department of 

Commerce (Commerce), SBA, and USAID, concluded that they did not 

have lessons learned from the 2009 H1N1 influenza pandemic 

Seventeen agencies reported in 2012 that they updated their influenza 

pandemic plan to include lessons learned from the pandemic. The 

Department of Energy (DOE), for example, reported that it had revised its 

plan to recommend that precautions and safeguards be based on the 

local prevalence of influenza at a specific DOE site rather than applying 

assumptions used for its headquarters location. HHS reported that 

following the first wave in the spring of 2009 and in anticipation of the 

second wave in the fall of 2009, HHS’s Assistant Secretary for 

Administration convened a human capital task force to provide real-time 

solutions for key workforce related issues, including identification of 

departmental preparedness requirements and institutionalization of 

process and procedures. HHS also reported that after the 2009 H1N1 

influenza pandemic, it had incorporated lessons learned that the task 

force identified as areas for improvement related to human capital into its 

draft influenza pandemic plan’s human capital management and 

workforce protection annex. The areas where HHS has emphasized 

process improvement include the identification of mission critical 

employees that could work remotely and prompt communication of HHS’s 

recommended actions for workforce protection and human capital plans 

to supervisors and employees.

 

18GAO-09-404. 

19In response to the global spread of the H1N1 influenza virus, the United Nations’ World 

Health Organization declared the first human influenza pandemic in more than 4 decades 

on June 11, 2009. Prior to this declaration, H1N1 influenza had spread across the United 

States after first being detected in California in April 2009. The World Health Organization 

officially declared that the H1N1 pandemic was over in August 2010. 

Many Agencies Reported 

Plans to Incorporate H1N1 

Lessons Learned Into 

Influenza Pandemic Plans
 

Page 14 GAO-12-748 Influenza Pandemic

specifically related to workforce protection that warranted an update to 

their influenza pandemic plans.

We reported in June 2009 that because the primary threat to continuity of 

operations during an influenza pandemic is the threat to employee health, 

agencies’ plans to protect their workforce need to be operational at the 

facility level.20 In addition, we reported that filtering influenza pandemic 

plans down to individual facilities and making them operational presented 

challenges for the agencies.21

A majority of agencies continued to report that they require pandemic 

plans at the component level, as shown in figure 6. Four agencies 

reported they did not require component level plans. The Department of 

Housing and Urban Development (HUD), OPM, and NSF reported in both 

2009 and 2012 that they did not require their components to complete 

influenza pandemic plans. Although USAID reported in 2009 that it 

required its components to complete plans, the agency reported in 2012 

that it uses a consolidated plan.

Figure 6: Majority of Agencies Reported Requiring Components to Complete Influenza Pandemic Plans

 

20Facility refers to third-level entities subordinate to components such as service centers, 

inspection stations, and medical centers and clinics. 

21GAO-09-404. 

Majority of Agencies 

Reported Various Influenza 

Pandemic Planning 

Activities at Component 

and Facility Levels
 

Page 15 GAO-12-748 Influenza Pandemic

To better understand the extent to which influenza pandemic planning 

had filtered down to the component and facility levels, we included 

questions about these levels in our 2012 survey. For our 2012 survey, we 

selected one component from each of the 15 agencies who had provided 

examples of their key component-level mission essential functions that 

could not be performed remotely during an influenza pandemic in our 

2009 survey, as shown in table 1.

Table 1: List of Agencies with Selected Components

Agency Selected component

Department of Agriculture Food Safety and Inspection Service

Department of Commerce National Oceanic and Atmospheric Administration

Department of Energy National Nuclear Security Administration

Department of Health and Human Services National Institutes of Health

Department of Homeland Security Customs and Border Protection 

Department of Justice Federal Bureau of Prisons

Department of Labor Office of Workers’ Compensation Programs

Department of State Under Secretary for Management

Department of Transportation Federal Aviation Administration 

Department of the Treasury U.S. Mint

Department of Veterans Affairs National Cemetery Administration

Environmental Protection Agency Region 10

National Aeronautics and Space Administration Lyndon B. Johnson Space Center

Nuclear Regulatory Commission Office of Nuclear Reactor Regulation

Social Security Administration Office of the Deputy Commissioner, Operations

Source: GAO.

Figure 7 shows a high number of these agencies reported a broad level of 

activity in influenza pandemic planning for their selected components. 

Fourteen agencies reported that they have completed influenza pandemic 

plans that address how federal workers would be protected in the event of 

an influenza pandemic for their selected component and VA reported that 

its selected component, National Cemetery Administration, is covered 

under its departmental influenza pandemic plan and consequently does 

not need a separate component plan.
 

Page 16 GAO-12-748 Influenza Pandemic

Figure 7: Selected Components’ Influenza Pandemic Planning Efforts

Of the 14 agencies with selected components that have plans, all but one 

reported they have addressed how employees who have onsite mission 

essential functions would be protected in the event of an influenza 

pandemic. The remaining agency, the Nuclear Regulatory Commission 

(NRC), reported that this was not applicable for its selected component, 

the Office of Nuclear Reactor Regulation (NRR), because NRR plans to 

perform all its mission essential functions remotely.

Further, 12 agencies with selected components reported they had 

incorporated lessons learned from the 2009 H1N1 influenza pandemic in 

their pandemic plans. Of the remaining two agencies with selected 

components that have plans, the Department of Transportation (DOT) 

reported that it has not yet incorporated lessons learned for its selected 

component, FAA, but is planning to incorporate them by the fall of 2012. 

In addition, Commerce reported that it does not plan on updating the 

National Oceanic and Atmospheric Administration’s (NOAA) influenza 

pandemic plan to include lessons learned from the 2009 H1N1 influenza 

pandemic because there were no lessons specifically related to workforce 

protection that warranted a change. However, Commerce reported that 

NOAA will be reviewing its pandemic plan in late 2012.

The 14 agencies with selected components that have plans reported that 

all of the components included five of eight social distancing strategies to 

help reduce the risk of exposure for their employees, as shown in figure 

8. As we mentioned earlier, avoiding crowded settings is one of the best 
 

Page 17 GAO-12-748 Influenza Pandemic

ways to prevent infection during an influenza pandemic. However, not all 

of these actions may be applicable to all workplace settings.

Figure 8: Agencies Reported Using Various Social Distancing Strategies to Avoid Situations that Increase Workers’ Risk of 

Exposure for Selected Components

Figure 9 shows agency responses to our 2012 survey regarding influenza 

pandemic plans at the facility level.22

 

22Agencies reported a wide range of facilities for their selected component, including 

airport and seaport terminals, land border ports of entry, overseas U.S. embassies and 

consulates, and national cemeteries.

Eight of the 15 agencies that have 

selected components have also required their facilities to complete 

influenza pandemic plans. The remaining seven agencies—Department 

of the Treasury (Treasury), HHS, Labor, National Aeronautics and Space 

Administration (NASA), NRC, Social Security Administration (SSA), and 

USDA—reported that they have not required facility-level plans for the 

components we had selected for a variety of reasons. For example, HHS, 

Labor, and Treasury reported they did not require their selected 

component’s facilities to complete separate influenza pandemic plans 
 

Page 18 GAO-12-748 Influenza Pandemic

because they are covered under the component’s plan, while NASA and 

NRC reported that it was not applicable because they have no facilities 

for the components we had selected. For example, NRC reported that 

NRR does not have facilities because it is located inside the main NRC 

headquarters complex.

Figure 9: Selected Components’ Facility-Level Influenza Pandemic Plans

All of the eight agencies requiring components’ facilities plans reported 

that these plans addressed how employees with onsite mission essential 

functions would be protected during an influenza pandemic. In addition, 

five of these eight agencies—DOE, Department of Justice, DOT, 

Environmental Protection Agency (EPA), and Department of State 

(State)—reported that all of their selected components’ facilities plans 

addressed how employees would be protected in the event of an 

influenza pandemic. Of the remaining three, DHS reported that half or 

more of Customs and Border Protection’s facilities addressed worker 

protection in their plans and Commerce and VA reported that some, but 

less than half, of their selected components’ facilities have done so.

The use of various social distancing strategies reported in facilities’ 

pandemic plans is highlighted in figure 10. As the figure shows, all eight 

of the agencies whose components’ facilities were required to complete 

influenza pandemic plans also reported that their facility-level plans 

included social distancing strategies, such as implementing pandemic 

influenza-specific office protocols, restricting meetings and gatherings, 

and avoiding all unnecessary travel.
 

Page 19 GAO-12-748 Influenza Pandemic

Figure 10: Use of Various Social Distancing Strategies in Facility-Level Influenza Pandemic Plans

Employees who must work onsite during an influenza pandemic will face 

varying levels of exposure risk. The level of risk depends, in part, on 

whether or not they will be in close proximity to people potentially infected 

with the influenza pandemic virus. OSHA has given guidance on steps 

employers can take to reduce the risk of exposure to influenza pandemic 

in their workplace.23

 

23OSHA, Guidance on Preparing Workplaces for an Influenza Pandemic. 

For example, an agency could make changes to the 

work environment to reduce workplace hazards, such as installing sneeze 

guards between customers and employees to provide a barrier to 

transmission of the influenza virus. Additionally, an agency could provide 

personal protective equipment, such as surgical masks and N-95 

respirators, to employees which, if used correctly, can help prevent some 

exposures. The steps that agencies could take to plan for appropriate 

employee protections include determining the number of employees they 

Many Agencies Reported 

Identification of Onsite 

Mission Essential 

Functions but Less than 

Half Reported Determining 

and Notifying Employees 

Tasked with Such 

Functions 
 

Page 20 GAO-12-748 Influenza Pandemic

may need to protect, notifying those employees that may be expected to 

work, and classifying jobs by exposure risk level.

However, as figure 11 shows, although many of the agencies have 

identified mission essential functions that cannot be performed remotely, 

less than half have determined the number of employees that are tasked 

with performing onsite mission essential functions and notified the 

employees that they would be expected to work onsite during an 

influenza pandemic. Labor reported using a methodology of determining 

occupational risk exposure and telework designations by position rather 

than by function and is not represented in figure11. Through this 

methodology, Labor does not identify mission essential functions that 

cannot be continued through telework in the event of an influenza 

pandemic but does determine the number of its employees who perform

mission essential functions that cannot be continued through telework.

Labor reports that the notification of employees is a responsibility of its 

component agencies and the extent to which this has been completed is 

not known at the department level.

Figure 11: Agencies Reported Identification of Onsite Mission Essential Functions and Determination and Notification of 

Employees Tasked With Such Functions

Note: This figure includes only 20 of 24 agencies. Of the remaining four agencies, Education, GSA, 

and SBA reported they could perform all of their mission essential functions remotely and Labor 

reported that it determines occupational risk exposure and telework designations by position rather 

than by mission essential function.

Seventeen agencies reported that they have identified which mission 

essential functions could not be performed remotely while EPA, HUD, and 

USAID reported that they were still in the process of determining them.
 

Page 21 GAO-12-748 Influenza Pandemic

Ten of 17 agencies have determined the number of employees that would 

perform mission essential functions in the event of an influenza 

pandemic. The remaining seven agencies that have identified onsite 

mission essential functions reported that they have not yet determined the 

number of employees that must perform such functions in the event of an 

influenza pandemic. For example, SSA reported that it has not 

determined which jobs could be performed remotely because the 

agency’s telework policy has not been ratified in its labor contract.

Of the 10 agencies that have determined the number of employees that 

cannot work remotely, all of them reported that they had also notified all 

or most of their employees who may be expected to continue operations 

during an influenza pandemic, an increase of 1 agency over 2009.

As we reported in June 2009, agencies should prepare employees for the 

risks of performing onsite mission essential functions.24 A key step in 

making these determinations is to classify jobs by exposure risk level for 

mission essential functions that cannot be performed remotely. As figure 

12 shows, of the 21 agencies reporting jobs associated with mission 

essential functions that cannot be performed remotely, although 9 

agencies reported that they have classified all or most of their jobs by 

exposure risk level, 8 agencies reported having classified few or none. As 

noted earlier, Education, GSA, and SBA reported that all of their mission 

essential functions could be performed remotely.

 

24GAO-09-404. 
 

Page 22 GAO-12-748 Influenza Pandemic

Figure 12: Agencies Reported Uneven Status in Classifying Jobs by Exposure Risk Level for Onsite Mission Essential 

Functions

Note: This table does not include all 24 agencies because three of them reported they could perform 

all of their mission essential functions remotely.

Figure 13 shows that many agencies reported to have classified jobs that 

have onsite mission essential functions by exposure risk level for their 

selected component. Nine of the 14 agencies that have a selected 

component with onsite mission essential functions reported that they have 

classified all or most of their jobs by exposure risk level and only two 

agencies have classified a few or none. However, when compared to 

figure 12, agencies reported classifying jobs at the component level with 

onsite mission essential functions by exposure risk level to a greater 

degree than at the agency level.
 

Page 23 GAO-12-748 Influenza Pandemic

Figure 13: Many Agencies Reported Classifying Jobs by Exposure Risk Level for Selected Component’s Onsite Mission 

Essential Functions 

Note: This table does not include all 15 agencies with selected components because NRC reported 

that all of NRR’s jobs could be performed remotely.

Twelve agencies and 11 selected components that completed or nearly 

completed the exposure risk classification also reported that they have

specified the appropriate protection measures and could implement them, 

if instructed, to either a great extent or to some extent for those 

employees that cannot work remotely during an influenza pandemic.

With the exception of DOD and Labor, 22 agencies identified various 

challenges in our 2012 survey that they faced in planning how to protect 

their workforce during an influenza pandemic. The top three challenges 

agencies most frequently cited, as shown in figure 14, were related to (1) 

medical countermeasures, such as antivirals and vaccines;25

 

25Medical countermeasures for use during an influenza pandemic may include vaccines, 

antiviral drugs, personal respirators, and influenza diagnostic tests. Vaccine, considered 

the first line of defense against influenza, is used to stimulate the production of an immune 

system response to protect the body from disease. Antiviral drugs are medications that 

can prevent or reduce the severity of a viral infection, such as influenza.

(2) 

information sharing; and (3) implementing various social distancing 

strategies.

Agencies Highlighted 

Various Challenges in 

Planning for an Influenza 

Pandemic
 

Page 24 GAO-12-748 Influenza Pandemic

Figure 14: Most Frequently Reported Challenges in Planning for Federal Worker Protection for an Influenza Pandemic 

Note: Two of the 24 agencies did not identify any challenges.

Almost half of the agencies, or 11, reported that understanding what 

actions they should take to procure, prioritize, and distribute vaccines and 

antivirals for their employees was a challenge. Specifically, some of these 

challenges included the lack of guidance related to policies and 

procedures for allocating and distributing vaccines and antivirals for their 

employees and how they should plan for nonfederal employees. For 

example, State reported that it had faced challenges because vaccines 

were not readily available during the 2009 H1N1 influenza pandemic for 

the approximately 50,000 employees and accompanying family members 

who work in embassies and consulates overseas. During the 2009 H1N1 

influenza pandemic, State received a rationed shipment of vaccines for 2 

percent of its workforce, which encompassed both domestic-based and 

international-based employees. The initial shipments were sent to State 

offices in Baghdad and Kabul; other diplomatic posts had to wait for later 

shipments. As we had reported in June 2011 on lessons learned from the 

2009 H1N1 influenza pandemic, the H1N1 vaccine was not widely 

available when expected or when demand was highest in October 2009. 

By the time the H1N1 vaccine was widely available in late December 

2009, the peak of H1N1 influenza activity had passed and many 

individuals were no longer as interested in getting vaccinated.26

 

26GAO, Influenza Pandemic: Lessons from the H1N1 Pandemic Should Be Incorporated 

into Future Planning, 

Further, 

DOT reported that there is a need for governmentwide guidance or 

GAO-11-632 (Washington, D.C.: June 27, 2011). 
 

Page 25 GAO-12-748 Influenza Pandemic

authority clarifying what federal agencies can legally do to protect onsite 

contractors who work closely with federal employees.

Unlike the allocation and distribution of seasonal influenza vaccines, the 

allocation and distribution of influenza pandemic vaccines are managed 

by the federal government. For example, during the 2009 H1N1 

pandemic, the federal government determined that HHS would manage 

the allotment of the H1N1 vaccine. However, the federal agencies each 

make a decision whether or not to procure antivirals for their employees. 

Nevertheless, agencies still reported challenges. HHS reported that it 

issues nationwide guidance on the use of antivirals which informs the 

plans of employers who have chosen to stockpile these drugs, including 

federal agencies. However, HHS noted that it is an agency decision 

whether to purchase and distribute antivirals. HHS officials also 

acknowledged the lack of an approved process for internal HHS 

distribution of antivirals for its employees as a challenge, but noted they 

are evaluating lessons learned from the 2009 H1N1 influenza pandemic 

regarding this issue and will incorporate them into future influenza 

pandemic planning. Further, DOT reported that it had not planned for 

procuring antiviral medications for prophylaxis27

Tied with medical countermeasures, 11 agencies cited challenges related 

to information sharing among federal agencies and also with their 

employees. For example, DOT and USDA reported they had not obtained 

post-H1N1 information regarding governmentwide lessons learned or 

best practices related to workforce protection issues that could be 

incorporated into their pandemic plans to help plan for future influenza 

pandemics. According to DHS’s NRF, federal agencies should 

incorporate lessons learned from real-life incidents, such as an influenza 

pandemic, to make improvements in further strengthening their capability 

to respond to future emergencies.

because there is no 

requirement or reimbursement for federal agencies to do so; and SBA 

reported that stockpiling antivirals and prioritizing distribution of antivirals 

for its workforce, including who and when, were challenges.

28

 

27Prophylactic use of medications is providing the medicine before an individual is 

diagnosed to help prevent or reduce the severity of a virus.

The NRF specifies that evaluation 

28Issued by DHS in January 2008, the NRF is the doctrine that guides how federal, state, 

local, and tribal governments, along with nongovernmental and private sector entities, will 

collectively respond to and recover from all-hazards, including catastrophic disasters such 

as Hurricane Katrina. 
 

Page 26 GAO-12-748 Influenza Pandemic

and continual process improvement are cornerstones of effective 

preparedness. We had previously recommended in June 2011 that the 

HSC should work with HHS, DHS, and other federal agencies to 

incorporate lessons learned from the 2009 H1N1 pandemic in addition to 

the lessons we identified, which included sharing relevant findings of 

agencies’ after-action reports with key stakeholders, in planning for future 

pandemics.29

As noted earlier, agencies reported that there were challenges with 

communicating pandemic-related information to their employees. USDA,

for example, reported that it was challenging to provide recurring 

pandemic-related information to ensure new employees were cognizant 

of its pandemic plans and guidance. In addition, HUD reported that 

providing real-time information to its employees could be a challenge, 

based on its experience with the 2009 H1N1 influenza pandemic. Further, 

HHS reported that it recognized that during the 2009 H1N1 influenza 

pandemic, its internal communication plans for workplace protection and 

human capital planning were delayed or inadequate. To address this 

shortfall, HHS’s Centers for Disease Control and Prevention (CDC) and 

OPM published a communications toolkit during the 2009 H1N1 influenza 

pandemic in October 2009 for the federal workforce that included 

communications resources and guidance for federal employees and 

supervisors to use.30 Our internal control standards for the federal 

government establish the need for relevant, reliable, and timely 

communications. According to these standards, effective communications 

should occur with information flowing down, across, and up the 

organization as well as with external stakeholders that may have a 

significant impact in meeting agency objectives.31

Eight agencies reported that implementing various social distancing 

strategies, such as telework, workspace configuration, and IT capabilities, 

Information sharing 

prior to and during an emergency, such as an influenza pandemic, is 

important to ensure the continuity of agencies’ operations and mission 

essential functions.

 

29GAO-11-632. 

30HHS, CDC, and OPM, Preparing for the Flu: A Communications Toolkit for the Federal 

Workforce (Oct. 1, 2009). 

31GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). 
 

Page 27 GAO-12-748 Influenza Pandemic

was a challenge. Although we pointed out earlier that all 24 agencies 

reported that they planned to use telework as a means to protect their 

employees in the event of an influenza pandemic, several agencies 

reported that it may be a challenge to implement the measure. NASA, for 

instance, reported that because of the high level of commitment of its 

employees to assure mission success, educating and encouraging its 

workforce to use various social distancing recommendations, such as 

teleworking from home, canceling meetings, and not reporting to work 

when sick, was a challenge. In addition, NSF reported that it did not know 

whether all of its employees had internet capabilities in their homes to 

carry out work tasks remotely, while SBA reported that it was challenging 

to encourage all staff to become telework-enabled—such as having the 

appropriate capabilities at home to be able to work remotely. With respect 

to workspace configuration, DHS reported the difficulty of reconfiguring 

workspace to protect employees who must perform classified work in a 

sensitive compartmented information facility. Such facilities present 

similar social distancing challenges for air traffic controllers who work in 

close capacity in air route traffic control centers, which we will discuss 

next.

We reported in 2009 that FAA pandemic plans to protect air traffic 

controllers were not ready for implementation and also highlighted various 

challenges in protecting air traffic controllers who had to perform onsite 

mission essential functions during an influenza pandemic. We followed up 

with FAA officials on the extent of their progress on four specific issues.

First, since our 2009 report, FAA has ensured that its facilities developed 

plans to protect air traffic controllers during an influenza pandemic. In 

2009, we reported that the Air Traffic Organization (ATO), FAA’s line of 

business responsible for air traffic controllers’ services, had not directed 

facilities, such as its air route traffic control centers, to develop pandemicspecific plans. ATO directed its facilities 3 months after our report was 

issued to develop contingency staffing plans to mitigate the probable 

impact of an influenza pandemic and also instructed its facilities on 

immediate preparedness steps at the facility level.32

 

32The memorandum to ATO Senior Leadership from the Senior Vice President, 

Operations, on the subject of Immediate Preparedness Steps at the Facility and Office 

Level to Counter the Threat of Pandemic Influenza, Including the 2009 H1N1 Influenza 

Virus was issued on September 23, 2009.

For example, ATO 

Pandemic Plans to Protect 

Air Traffic Controllers 

Have Progressed, but 

Social Distancing Remains 

an Intractable Challenge
 

Page 28 GAO-12-748 Influenza Pandemic

facility managers were instructed to identify employees who were eligible 

and willing to telework, ensure that the appropriate employees complete 

the FAA telework program, and identify the minimum cadre of employees, 

by position, who would need to telework during an influenza pandemic 

outbreak to sustain mission essential services.

Second, FAA augmented its agencywide pandemic plan with a workplace 

protection policy. In 2010, FAA updated ATO’s draft pandemic plan with 

detailed protective measures for its workforce, including air traffic 

controllers.33

Third, FAA has addressed issues related to medication. At the time of our 

report in 2009, the Office of Aerospace Medicine had not finalized its 

policy on the preventative use of the flu medication Tamiflu by on-duty 

controllers. FAA regulations on medication for air traffic controllers are 

strict because certain medications may impair air traffic controllers’ 

performance. The Office of Aerospace Medicine revised and finalized its 

policy in 2009 regarding the use of Tamiflu for preventative use by onduty controllers.

For example, FAA added information to the plan about 

sanitizers that are safe to use on air traffic control equipment. At the time 

of our report in 2009, FAA had not yet certified a sanitizer to be used to 

sanitize the equipment. It was important for FAA to certify a sanitizer 

because many sanitizers are caustic and could corrode sensitive 

equipment necessary for flight safety. ATO’s plan now states employees 

should regularly cleanse shared equipment using certified disinfectant or 

cleaning agents. Additional measures call for employees to take a 

pandemic awareness course, cover coughs, and wash their hands 

frequently, which are consistent with CDC’s guidance. FAA reported the 

plan has been distributed as guidance to managers and supervisors and 

remains in draft status as it is a “living document.” 

34

 

33FAA, Air Traffic Organization: Implementation Plan for Sustaining Essential Government 

Services During an Influenza Pandemic (Jan. 5, 2010).

FAA will allow air traffic controllers to continue to work if 

they have been prescribed antiviral medications by either a public health 

authority or their personal physicians, if no side effects from the 

medications are evident, and if they are operating normally on the job.

34FAA, Use of Anti-Influenza Medication by FAA Employees Performing Safety-Related 

Duties (Oct. 8, 2009).
 

Page 29 GAO-12-748 Influenza Pandemic

Finally, FAA was not able to resolve social distancing challenges. CDC 

recommends maintaining 6 feet of separation during an influenza 

pandemic, but this is not possible for air traffic controllers because they 

work in close quarters. According to FAA officials, they considered having 

air traffic controllers use personal protective equipment, but concluded 

that N-95 respirators or surgical masks impede the clear verbal 

communications necessary to maintain aviation safety. At the time of our 

report in 2009, FAA had just received the results of a feasibility study for 

the use of a powered air purifying respirator. The study findings 

suggested that if FAA used the technology, it would need to address 

many potential problems including noise, visibility, and comfort. At this 

time, FAA officials state they have not identified a technical solution to 

equip controllers with a practical protective piece of equipment that will 

mitigate the risk of working in close quarters while supporting adequate 

communications necessary for safety. The FAA official responsible for 

ATO’s pandemic planning stated social distancing challenges appear 

intractable with the current technology, although FAA will continue to seek 

opportunities to mitigate potential exposure to influenza. For the present, 

this includes being vigilant in implementing hygiene measures in their 

workspaces and exploring other mitigation controls such as technological 

advances that reduce transmissibility.

Federal Continuity Directive 1 requires federal executive agency heads to 

evaluate program readiness to ensure the adequacy and capability of 

continuity plans and programs. In addition, the agency head must submit 

an annual report to the National Continuity Coordinator (NCC) to certify 

the agency has this capability. As previously discussed, all agencies 

reported having completed influenza pandemic agency plans.

Under the HSC’s Implementation Plan, DHS was charged with, among 

other things, monitoring and reporting to the President on the readiness of 

departments and agencies to continue their operations while protecting 

their workers during an influenza pandemic. However, DHS officials said 

the HSC informed them in late 2006 or early 2007 that they were not 

required to report on these responsibilities. Rather, the HSC requested 

that agencies certify to the council that their plans addressed the 

applicable elements of a pandemic checklist in 2006 and again in 2008. 

However, according to two agencies’ officials, the HSC has not asked 

agencies to certify their plans since then. As we reported in 2011, the 

National Security Staff (NSS), who supports the HSC, is coordinating a 

larger effort to transition national preparedness from a dependence on 

fixed plans for specific threats to an approach based on a variety of 

Agencies’ Plans and 

Progress to Protect 

Federal Workers 

during an Influenza 

Pandemic Receive 

Limited Oversight
 

Page 30 GAO-12-748 Influenza Pandemic

hazards, or an all-hazards approach in accordance with Presidential 

Policy Directive 8.35,36,37We submitted a request for information and 

asked to meet with the relevant NSS subject matter experts regarding 

oversight of agencies’ preparedness to protect workers during a 

pandemic. An NSS official advised that the NSS would not be able to 

provide responsive information because these issues are currently being 

addressed through the Presidential Policy Directive 1 process.38

As we did in 2009, we interviewed four agencies to which the 

Implementation Plan assigns responsibilities related to pandemic 

Officials 

at two agencies we spoke with informed us that the NSS has reconvened 

the Pandemic Preparedness Sub-Interagency Policy Coordination 

Committee to primarily address domestic pandemic preparedness efforts, 

with a focus on coordination between departments and agencies. In the 

absence of any information from the HSC, it is not possible to determine 

what, if anything, it is doing to oversee federal agency pandemic 

planning. Regarding the 2009 recommendation we made to the HSC, 

DHS officials told us that the HSC has not requested the Secretary of 

Homeland Security to monitor and report to the President on the 

readiness of agencies to continue their operations while protecting their 

employees in the event of a pandemic.

 

35GAO-11-632. 

36On May 26, 2009, the President established the NSS, under the direction of the National 

Security Advisor, to integrate White House staff supporting national security and 

homeland security. The President stated that the NSS would support the HSC, and that 

the HSC would be maintained as the principal venue for interagency deliberations on 

issues that affect the security of the homeland, such as pandemic influenza. See 

Statement by the President on the White House Organization for Homeland Security and 

Terrorism, accessed July 17, 2012, 

http://www.whitehouse.gov/the_press_office/Statement-by-the-President-on-the-WhiteHouse-Organization-for-Homeland-Security-and-Counterterrorism. 

37Issued in March 30, 2011 by the President, the Presidential Policy Directive 8 

documents that the Secretary of Homeland Security is responsible for coordinating the 

domestic all-hazards preparedness efforts of all executive departments and agencies and 

for developing the national preparedness goal.

38Issued in February 2009 by the President, the Presidential Policy Directive 1 documents 

the organization of the National Security Council (NSC), which is the principal forum for 

consideration of national security policy issues requiring presidential determination. The 

NSC is the President's principal means for coordinating executive departments and 

agencies in the development and implementation of national security policy. Management 

of development and implementation of national security policies by multiple agencies of 

the U.S. government shall be accomplished by the NSC Interagency Policy Committees.
 

Page 31 GAO-12-748 Influenza Pandemic

preparedness. The four agencies we selected are responsible for 

providing guidance, policy, or influenza pandemic-related expertise to 

other agencies. Each of these agencies is responsible for providing 

influenza pandemic continuity of operations (COOP) guidance, which 

includes elements such as COOP planning, personnel protection, or 

workplace options for federal departments and agencies.

• Labor’s OSHA is responsible for promoting the safety and health of 

workers, including communication of information related to an 

influenza pandemic to workers and employers.39

• HHS is responsible for the overall coordination of the public health 

and medical emergency response during an influenza pandemic. HHS 

communicates information related to an influenza pandemic, ensures 

provision of essential human services, implements measures to limit 

the spread of influenza, provides recommendations related to the use, 

distribution, and allocation of influenza countermeasures, and to the 

provision of care in mass casualty settings.40

• OPM, in coordination with DHS, HHS, DOD, and Labor, provides 

guidance to federal departments and agencies on human capital 

management41

• DHS coordinates the overall domestic federal response during an 

influenza pandemic, including implementing policies that facilitate 

compliance with recommended social distancing measures, 

developing a common operating picture for all federal agencies, and 

ensuring the integrity of the nation’s infrastructure.

and COOP planning criteria related to an influenza 

pandemic.

 

39OSHA issued Guidance on Preparing Workplaces for an Influenza Pandemic in 2007 for 

employers and employees, to help identify risk levels in workplace settings and 

appropriate control measures that include good hygiene, cough etiquette, social 

distancing, the use of personal protective equipment and staying home from work when ill.

40HHS’s H1N1 Compendium, designed to be utilized by healthcare providers and 

practitioners, provides guidance on the interventions for H1N1 in the emergency and “first 

care” provider infrastructure throughout the United States. The compendium provides 

specific recommendations, consultation, and guidance on various matters, including: 

hospital best practices, hospital intervention trigger points for pandemic responses, H1N1 

intervention guidance, screening guidelines, and equipment/supply recommendations. 

For example, CDC provides additional guidance by audience and updates based on 

lessons learned.

41The U.S. government website, accessed July 17, 2012, http://www.flu.gov contains 

information for federal employees, human resources practitioners, and managers on 

human capital policies in effect during an influenza pandemic such as flexible work 

arrangements, health benefits, and leave and pay flexibilities.
 

Page 32 GAO-12-748 Influenza Pandemic

DHS does not conduct oversight of agencies’ plans as originally 

envisioned in the Implementation Plan, and DHS officials responsible for 

coordinating organizational roles and responsibilities related to these 

responsibilities confirmed that DHS does not specifically provide oversight 

of agencies’ influenza pandemic plans. But these officials told us that 

DHS is the federal lead agency for coordinating overall continuity 

operations.42 In this capacity, DHS coordinates the assessment of 

agencies’ continuity activities and programs. The DHS Secretary provides 

biennial assessments of department and agency continuity capabilities 

and reports the results to the President, through the NCC, and to agency 

heads as required by Federal Continuity Directive 1.43

FEMA officials responsible for the national continuity program noted that 

while agencies are responsible for their preparedness, and FEMA does 

not assess the efficacy of overall agency pandemic preparedness, 

FEMA’s biennial assessment process does assess whether agencies’ 

continuity plans address some of the unique considerations of an 

influenza pandemic. FEMA collects agency information for the 

assessment through continuity exercises and the Continuity Evaluation 

Tool (evaluation tool), a comprehensive survey covering 14 elements of 

continuity programs, plans, and procedures for all-hazards, including a 

pandemic threat. In addition to reporting to the NCC, FEMA also 

compares the results of multiple biennial continuity assessments to 

identify government trends in overall continuity preparedness. The 

evaluation tool asks whether agencies’ communications capabilities will 

allow them to continue operations for all types of emergencies, including 

influenza pandemics. The evaluation tool also asks if agencies have 

given full consideration to social distancing strategies, such as telework.

Because the evaluation tool which FEMA uses to evaluate agencies’ 

continuity plans is based on an all-hazards approach, it does not include 

the planning elements identified in the Key Elements checklist that 

agencies specifically use for pandemic planning. Consequently, the 

evaluation tool, for example, does not include pandemic preparednessrelated questions such as whether federal workers’ influenza pandemic 

 

42Within DHS, FEMA is responsible for preparing and implementing the plans and 

programs of the federal government for the continuity of operations pursuant to 6 U.S.C. § 

314.

43DHS released the Federal Continuity Directive 1 in February 2008 to provide direction 

for the development of continuity plans and programs for the federal executive branch.
 

Page 33 GAO-12-748 Influenza Pandemic

risk assessments are regularly updated and whether agencies have 

planned to provide protective measures to mitigate exposure risks.

Our follow-up survey of the 24 CFO Act agencies showed that significant 

progress has been made in many areas since we last reported on this 

issue in 2009. In particular, almost all or most of the agencies, selected 

components, and their facilities have completed pandemic plans that 

address how they would protect employees that were associated with 

mission essential functions that could not be performed remotely. In 

addition, almost half of the agencies reported to have determined the 

number of employees that would have to perform mission essential 

functions and also notified the employees that they were expected to 

continue these operations during an influenza pandemic. However, the 

agencies also reported uneven status in some key areas suggesting 

some oversight targeted to bring attention to these areas is needed. For 

example, only nine agencies reported that they have classified all or most 

jobs for onsite mission essential functions by exposure risk level. Given 

the continued threat of an influenza pandemic, it is important that 

agencies have operational pandemic plans that identify appropriate 

workforce strategies to protect employees while ensuring mission 

essential functions continue. Adequate oversight could help in ensuring 

that, by classifying jobs by exposure risk level, agencies have appropriate 

measures in place to protect those employees who must carry out 

mission essential functions that cannot be performed remotely during an 

influenza pandemic.

Agencies reported several challenges in planning for federal worker 

protection in the event of an influenza pandemic. Sharing of information 

among agencies is related to some of these challenges. The Pandemic 

Preparedness Sub-Interagency Policy Coordination Committee meetings 

led by the NSS may provide a venue and opportunity to identify agencies’ 

needs and improve coordination to address gaps the agencies perceive in 

guidance and pandemic-related information needs.

FAA has made progress in three of the four areas related to protecting air 

traffic controllers we highlighted as challenges in 2009. However, FAA 

has not yet found a viable way to address how onsite air traffic 

controllers, who work in close proximity to each other, could be separated 

during an influenza pandemic. Further, FAA has not yet identified 

personal protective equipment alternatives for use by air traffic controllers 

who must report to work during an influenza pandemic. These issues will 

Conclusions 
 

Page 34 GAO-12-748 Influenza Pandemic

continue to be challenges for which FAA may not be able to find viable 

solutions.

FEMA’s biennial assessment of agencies’ continuity capabilities does not 

consider agency responses to significant influenza pandemic-related 

questions regarding protection of federal workers. Such questions may 

include whether jobs have been classified by exposure risk level and 

whether appropriate protective measures have been identified and will be 

available as needed for their employees. While agencies have reported in 

2012 they have made significant progress in planning for protecting 

workers during an influenza pandemic, additional oversight targeted to 

those areas in which reported progress is uneven could help focus 

attention on those areas. The existing biennial assessment process 

provides an opportunity to provide monitoring, evaluation and reporting on 

protecting federal workers during an influenza pandemic.

To provide additional oversight of agencies’ progress in their 

preparedness to protect workers, help focus attention on areas of uneven 

progress reported in our survey, and build upon the efforts FEMA has 

underway, we recommend that the Secretary of Homeland Security direct 

the Administrator of FEMA to include in its biennial assessments of 

agencies’ continuity capabilities consideration of agencies’ progress in 

assessing exposure risk levels, identifying appropriate protective 

measures, and establishing operational plans to provide such protections.

We provided the Secretary of Homeland Security with a draft of this report 

for review and comment. In written comments, the Director of the 

Departmental GAO-Office of the Inspector General Liaison Office 

concurred with the recommendation and stated that DHS is committed to 

ensuring COOP programs continue to focus on all-hazards, including 

pandemic planning, in an evolving environment. As part of this 

commitment, FEMA reviews its Continuity Evaluation Tool on a regular 

basis and will update it to provide specific attention to pandemic planning 

within the context of all-hazard planning, including assessing the risk of 

pandemic impacts to specific functions, identifying protective measures 

for employees performing those functions, and planning for providing 

protection, as appropriate. Technical comments were also provided, 

which we incorporated. DHS’s comments are reprinted in appendix IV.

Recommendation For 

Executive Action

Agency Comments
 

Page 35 GAO-12-748 Influenza Pandemic

As agreed with your office, unless you publicly announce the contents of

this report earlier, we plan no further distribution until 30 days from the 

report date. We are sending copies of this report to the Department of 

Homeland Security; relevant congressional committees; and other 

interested parties. The report also is available at no charge on the GAO 

website at http://www.gao.gov. 

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

contact me at (202) 512-9110 or czerwinskis@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix V.

Stanley J. Czerwinski

Director, Strategic Issues
Appendix I: Chief Financial Officers Act 

Agencies

Page 36 GAO-12-748 Influenza Pandemic

• Department of Agriculture

• Department of Commerce

• Department of Defense

• Department of Education

• Department of Energy

• Department of Health and Human Services

• Department of Homeland Security

• Department of Housing and Urban Development

• Department of the Interior

• Department of Justice

• Department of Labor

• Department of State

• Department of Transportation

• Department of the Treasury

• Department of Veterans Affairs

• Environmental Protection Agency

• General Services Administration

• National Aeronautics and Space Administration

• National Science Foundation

• Nuclear Regulatory Commission

• Office of Personnel Management

• Small Business Administration

• Social Security Administration

• U.S. Agency for International Development

Appendix I: Chief Financial Officers Act 

Agencies
Appendix II: List of Agencies and Selected 

Components

Page 37 GAO-12-748 Influenza Pandemic

Agency Selected component

Department of Agriculture Food Safety and Inspection Service

Department of Commerce National Oceanic and Atmospheric Administration

Department of Energy National Nuclear Security Administration

Department of Health and Human Services National Institutes of Health

Department of Homeland Security Customs and Border Protection

Department of Justice Federal Bureau of Prisons

Department of Labor Office of Workers’ Compensation Programs

Department of State Under Secretary for Management

Department of Transportation Federal Aviation Administration

Department of the Treasury U.S. Mint

Department of Veterans Affairs National Cemetery Administration

Environmental Protection Agency Region 10

National Aeronautics and Space Administration Lyndon B. Johnson Space Center

Nuclear Regulatory Commission Office of the Nuclear Reactor Regulation

Social Security Administration Office of the Deputy Commissioner, Operations

Source: GAO. 

Appendix II: List of Agencies and Selected 

Components 
Appendix III: Objectives, Scope, and 

Methodology

Page 38 GAO-12-748 Influenza Pandemic

The objectives of this report were to (1) determine what progress federal 

agencies report they have made since our 2009 report and identify 

challenges federal agencies report they face in protecting their workforce 

during an influenza pandemic, and (2) determine the extent to which 

oversight of agencies’ progress was being conducted and how the 

oversight information is being used.

To address the first objective, we developed and administered a webbased survey of the 24 agencies covered by the Chief Financial Officers 

Act of 1990 (CFO Act) to determine to what extent they had made 

progress in their preparedness to protect their workforce for an influenza 

pandemic since our 2009 survey and to identify challenges they faced in 

planning for protection of their workers. We developed the survey 

questions based on guidelines for worker protection from the Homeland

Security Council (HSC), Department of Health and Human Services 

(HHS), Federal Emergency Management Agency (FEMA), Occupational 

Safety and Health Administration (OSHA), and Office of Personnel 

Management (OPM), and we also used some of the survey questions we 

asked in 2009. The survey included questions related to (1) pandemic 

plans, (2) mission essential functions that could not be continued through 

telework during an influenza pandemic, (3) assessment of levels of 

exposure risk, (4) measures planned to protect workers who would not be 

able to work remotely, (5) social distancing strategies, (6) testing of 

information technology and telecommunications capabilities, (7) 

communication of human capital pandemic policies, (8) oversight of 

pandemic planning, and (9) challenges in planning for worker protection.

To better understand the extent to which influenza pandemic planning 

had filtered down to the component and facility levels, we also gathered 

data from these levels in our 2012 survey. In our 2009 survey, 15 of 24 

agencies provided examples of some of the key component-level mission 

essential functions that could not be performed remotely during an 

influenza pandemic. Using those examples, we selected a component 

from each of these 15 agencies for our 2012 survey and surveyed the 

agencies to determine whether they had made plans at lower 

organizational levels to protect their employees whose onsite presence 

was necessary in order to carry out mission essential functions.

Prior to disseminating our web-based survey, we conducted a series of 

pretests from November 16 through November 21, 2011, with three 

agencies to further refine our questions, clarify any ambiguous portions of 

the survey, and identify potentially biased questions. Upon completion of 

the pretests and development of the final survey questions and format, 

Appendix III: Objectives, Scope, and 

Methodology 
Appendix III: Objectives, Scope, and 

Methodology

Page 39 GAO-12-748 Influenza Pandemic

we sent an announcement of the upcoming survey to the 24 CFO Act 

agencies on December 12, 2011. These agencies were notified that the 

survey was available online on December 14, 2011. We sent reminder email messages to nonrespondents on January 3, 2012, and January 9, 

2012. The survey was available online until January 13, 2012, and the 

results were confirmed or updated through June 2012. All 24 CFO Act 

agencies completed the survey for a response rate of 100 percent.

Furthermore, we reviewed the National Strategy for Pandemic Influenza 

Implementation Plan, National Response Framework, our prior work 

assessing influenza, and other relevant literature. We defined mission 

essential functions based on the Department of Homeland Security’s 

(DHS) Federal Continuity Directive 1 as those functions that enable an 

organization to provide vital services, exercise civil authority, maintain the 

safety of the general public, and sustain the industrial and economic base 

during disruption of normal operations. The scope of our work did not 

include an independent evaluation of the effectiveness of the workforce 

protection measures recommended by federal lead pandemic agencies.

In addition to the survey, we conducted follow-up work to determine 

whether the Federal Aviation Administration had made progress in 

addressing the unique challenges we highlighted in our 2009 report 

regarding protection for air traffic controllers who must perform onsite 

mission essential functions during an influenza pandemic. We reviewed 

agency and component pandemic plans and conducted interviews with 

agency officials.

To address the second objective, we analyzed documentation of 

oversight activities and our prior work, and conducted interviews with 

officials from DHS, HHS, FEMA, OPM, and OSHA, who were tasked with 

providing guidance, policy, or influenza pandemic related expertise to 

other federal agencies in planning for an influenza pandemic.

We conducted this performance audit from July 2011 through July 2012 in 

accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix IV: Comments from the Department 

of Homeland Security

Page 40 GAO-12-748 Influenza Pandemic

Appendix IV: Comments from the 

Department of Homeland Security
Appendix IV: Comments from the Department 

of Homeland Security

Page 41 GAO-12-748 Influenza Pandemic
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 42 GAO-12-748 Influenza Pandemic

Stanley J. Czerwinski, (202) 512-9110 or czerwinskis@gao.gov

In addition to the contact named above, William J. Doherty, Assistant 

Director; Maya Chakko; David Dornisch; Karin Fangman; Robert Gebhart; 

Stuart Kaufman; Ruben Montes de Oca; Patricia Norris; Susan Sato; and 

Andrew Stavisky made major contributions to this report. Ellen Grady and 

Judith Kordahl verified the information in the report.

Appendix V: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 
Related GAO Products

Page 43 GAO-12-748 Influenza Pandemic

Influenza Pandemic: Lessons from the H1N1 Pandemic Should Be 

Incorporated into Future Planning. GAO-11-632. Washington, D.C.: June 

27, 2011.

Influenza Vaccine: Federal Investments in Alternative Technologies and 

Challenges to Development and Licensure. GAO-11-435. Washington, 

D.C.: June 27, 2011.

Disaster Response: Criteria for Developing and Validating Effective 

Response Plans. GAO-10-969T. Washington, D.C.: September 22, 2010.

Influenza Pandemic: Monitoring and Assessing the Status of the National 

Pandemic Implementation Plan Needs Improvement. GAO-10-73. 

Washington, D.C.: November 24, 2009.

Influenza Pandemic: Gaps in Pandemic Planning and Preparedness 

Need to Be Addressed. GAO-09-909T. Washington, D.C.: July 29, 2009.

Influenza Pandemic: Increased Agency Accountability Could Help Protect 

Federal Employees Serving the Public in the Event of a Pandemic. 

GAO-09-404. Washington, D.C.: June 12, 2009.

Influenza Pandemic: Continued Focus on the Nation’s Planning and 

Preparedness Efforts Remains Essential. GAO-09-760T. Washington, 

D.C.: June 3, 2009.

Influenza Pandemic: Sustaining Focus on the Nation’s Planning and 

Preparedness Efforts. GAO-09-334. Washington, D.C.: February 26, 

2009.

Influenza Pandemic: HHS Needs to Continue Its Actions and Finalize 

Guidance for Pharmaceutical Interventions. GAO-08-671. Washington, 

D.C.: September 30, 2008.

Influenza Pandemic: Efforts Under Way to Address Constraints on Using 

Antivirals and Vaccines to Forestall a Pandemic. GAO-08-92. 

Washington, D.C.: December 21, 2007.

Influenza Vaccine: Issues Related to Production, Distribution, and Public 

Health Messages. GAO-08-27. Washington, D.C.: October 31, 2007.

Related GAO Products
Related GAO Products

Page 44 GAO-12-748 Influenza Pandemic

Influenza Pandemic: Further Efforts Are Needed to Ensure Clearer 

Federal Leadership Roles and an Effective National Strategy. 

GAO-07-781. Washington, D.C.: August 14, 2007.

Influenza Pandemic: Efforts to Forestall Onset Are Under Way; Identifying 

Countries at Greatest Risk Entails Challenges. GAO-07-604. Washington, 

D.C.: June 20, 2007.

Influenza Pandemic: Applying Lessons Learned from the 2004–05 

Influenza Vaccine Shortage. GAO-06-221T. Washington, D.C.: November 

4, 2005.

Influenza Vaccine: Shortages in 2004–05 Season Underscore Need for 

Better Preparation. GAO-05-984. Washington, D.C.: September 30, 2005.

Influenza Pandemic: Challenges in Preparedness and Response. 

GAO-05-863T. Washington, D.C.: June 30, 2005.

Influenza Pandemic: Challenges Remain in Preparedness. 

GAO-05-760T. Washington, D.C.: May 26, 2005.

(450909)
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