a

GAO

United States General Accounting Office

Report to the Chairman, Subcommittee 

on Oversight of Government 

Management, the Federal Workforce, and 

the District of Columbia, Committee on 

Governmental Affairs, U.S. Senate

April 2004 HUMAN CAPITAL

Opportunities to 

Improve Federal 

Continuity Planning 

Guidance

GAO-04-384
www.gao.gov/cgi-bin/getrpt?GAO-04-384.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact J. Christopher 

Mihm at 202-512-6806 or mihmj@gao.gov. 

Highlights of GAO-04-384, a report to the 

Chairman, Subcommittee on Oversight of 

Government Management, the Federal 

Workforce, and the District of Columbia, 

Committee on Governmental Affairs, U.S. 

Senate 

April 2004

HUMAN CAPITAL

Opportunities to Improve Federal 

Continuity Planning Guidance 

According to recognized experts from the private and public sectors, 

continuity efforts should give priority to the immediate aftermath of a 

crisis—securing the safety of all employees and addressing the needs of 

employees who perform essential operations. However, experts noted that 

additional human capital considerations, especially those associated with 

the majority of an organization’s employees who would be needed to resume 

all other operations, are also crucial and have not been well developed by 

many public and private sector organizations. To more fully address human 

capital considerations, experts identified two human capital principles that 

should guide all continuity efforts—demonstrating sensitivity to individual 

employee needs and maximizing the contributions of all employees—and six 

key organizational actions designed to enhance continuity efforts. 

Key Organizational Actions to Enhance Continuity Efforts 

Demonstrate top 

leadership commitment 

• Instill an approach to continuity planning that includes human 

capital considerations 

• Allocate resources and set policies 

• Set direction and pace of recovery 

Seek opportunities for 

synergy 

• Integrate continuity efforts with broader decision making 

• Consider how continuity investments benefit other program efforts 

Maintain effective 

communication 

• Build relationships through two-way communication 

• Establish roles, responsibilities, and expectations 

• Develop redundant communication vehicles 

Target investments in 

training and 

development 

• Raise awareness of continuity efforts 

• Build skills and competencies to increase flexibility 

• Foster a culture that values flexible employees who are 

empowered to make effective decisions 

Leverage the flexibility 

of human capital 

• Enable employees associated with resumption activities to 

contribute to mission results in alternate assignments 

• Sustain the contribution of employees associated with essential 

operations 

• Maintain organizational knowledge of staffing requirements and 

availability 

Build process to identify 

and share lessons 

• Create a learning environment 

• Make learning explicit and shared 

Source: GAO. 

FEMA and OPM have exhibited leadership in addressing human capital 

considerations relevant to COOP, but opportunities to improve exist. For 

example, while both agencies have issued guidance that addresses securing 

the safety of all employees and responding to the needs of personnel 

performing essential operations, neither agency’s guidance addresses human 

capital considerations related to resuming broader agency operations. 

Although not specifically tasked with coordinating emergency preparedness 

efforts, including COOP, FEBs are uniquely positioned to do so, given their 

general responsibility for improving coordination among federal activities in 

areas outside of Washington, D.C. While some FEBs already play an active 

role in coordinating such efforts, the current context in which FEBs operate, 

including the lack of a clearly defined role and varying capacities among 

FEBs, could lead to inconsistent levels of preparedness across the nation. 

Federal agencies must have the 

capacity to serve the public during 

disruptions to normal operations. 

This depends, in part, on continuity 

efforts that help agencies marshal, 

manage, and maintain their most 

important asset—their people, or 

human capital. GAO identified the 

human capital considerations 

relevant to federal continuity 

efforts; described efforts by the 

Federal Emergency Management 

Agency (FEMA) and the Office of 

Personnel Management (OPM) to 

address these considerations 

relevant to continuity of operations 

(COOP); and described the role 

Federal Executive Boards (FEB) 

play in coordinating such efforts 

outside Washington, D.C. 

GAO recommends that FEMA and 

OPM more fully address human 

capital considerations in 

emergency preparedness guidance, 

including COOP, by incorporating 

key actions identified in this report. 

GAO also recommends that OPM 

clearly define the role FEBs play in 

improving emergency preparedness 

coordination and address any 

resulting capacity issues. FEMA 

agreed to implement our 

recommendations. OPM said its 

guidance already incorporates the 

key actions and highlighted its 

leadership role with respect to 

FEBs. GAO maintains that OPM 

has opportunities to address a 

fuller range of human capital 

considerations related to resuming 

broader agency operations and to 

clearly define the role of FEBs. 
Page i GAO-04-384 Human Capital

Contents

Letter 1

Results in Brief 3

Background 6

Human Capital Considerations Are Relevant to Continuity Planning 

and Implementation Efforts 8

FEMA and OPM Have Exhibited Leadership in Addressing Human 

Capital Considerations Relevant to COOP 20

FEBs Have Opportunities to Coordinate Regional Emergency 

Planning Efforts, Including COOP, in Major Metropolitan 

Areas 24

Conclusions 26

Recommendations for Executive Action 26

Agency Comments and Our Evaluation 27

Appendixes

Appendix I: Objectives, Scope, and Methodology 30

Appendix II: Emergency Human Capital Flexibilities Listed in OPM 

Emergency Memorandums 33

Leave 33

Pay 34

Benefits 35

Telework 35

Emergency Hiring Flexibilities 36

Appendix III: Comments from the Federal Emergency Management 

Agency 40

Appendix IV: Comments from the Office of Personnel Management 41

Table Table 1: Key Organizational Actions to Enhance Continuity 

Efforts 4

Figure Figure 1: Six Organizational Actions to Enhance Continuity 

Efforts 10
Contents

Page ii GAO-04-384 Human Capital

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

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

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

reproduce this material separately.

Abbreviations

AFGE American Federation of Government Employees

COOP continuity of operations

CTAP Career Transition Assistance Plan

CWG COOP Working Group

DHS Department of Homeland Security

EMA Emergency Management Alberta

FEB Federal Executive Board

FEMA Federal Emergency Management Agency

FPC Federal Preparedness Circular

GS General Schedule

GSA General Services Administration

HR human resources

ICTAP Interagency CTAP

IRS Internal Revenue Service

KSA knowledge, skills, and abilities

NAPA National Academy of Public Administration

NTEU National Treasury Employees Union

OEP Occupant Emergency Program

OPM Office of Personnel Management

PDD Presidential Decision Directive

PSC Private Sector Council

RPL Reemployment Priority List

SARS severe acute respiratory syndrome

SSA Social Security Administration

VSIP voluntary separation incentive payment
Page 1 GAO-04-384 Human Capital

United States General Accounting Office

Washington, D.C. 20548

A

April 20, 2004 Letr

The Honorable George V. Voinovich

Chairman, Subcommittee on Oversight of Government Management, 

the Federal Workforce, and the District of Columbia

Committee on Governmental Affairs

United States Senate

Dear Mr. Chairman:

The events of September 11, 2001, vividly demonstrated how important it 

is, both symbolically and functionally, for federal government agencies to 

continue to serve the American public during any emergency or situation 

that may disrupt normal operations. Yet terrorist-related incidents are only 

one in a broad spectrum of emergencies that can disrupt an agency’s 

normal operations. Agencies need a high level of preparedness to deal with 

the full range of emergencies, including man-made disasters, whether 

intentional or not; acts of nature, such as hurricanes, earthquakes, or 

disease; and technological emergencies, including cyber-attacks or 

computer viruses. 

Continuity of operations (COOP) efforts are a comprehensive set of steps 

agencies must undertake to help ensure that they can continuously provide 

essential operations and resume full services to the American public in the 

face of long-term, severe emergencies requiring agencies to occupy 

alternate facilities.1

 This capacity to serve the public during any type of 

disruption to normal operations depends, in part, on the ability of federal 

agencies to marshal, manage, and maintain their most important asset—

their people, or human capital. The planning efforts that help agencies 

build the capacity to effectively implement COOP may also help agencies 

more effectively implement basic emergency preparedness procedures in 

dealing with less severe disruptions to normal operations. 

In response to your request that we identify the human capital 

considerations in COOP emergencies, this report (1) identifies the human 

capital considerations that are relevant to federal agencies’ continuity 

1

 The House Committee on Government Reform also asked us to review agency 

headquarters COOP plans. We reported on that review in U.S. General Accounting Office, 

Continuity of Operations: Improved Planning Needed to Ensure Delivery of Essential 

Services, GAO-04-160 (Washington, D.C.: Feb. 27, 2004). 
Page 2 GAO-04-384 Human Capital

planning and implementation efforts; (2) describes the COOP guidance 

provided by the Federal Emergency Management Agency (FEMA)2

 and 

emergency preparedness guidance and activities of the Office of Personnel 

Management (OPM) to address human capital considerations relevant to 

COOP; and (3) describes the role Federal Executive Boards (FEB) play, 

relevant to COOP, in coordinating efforts outside the Washington, D.C., 

area.

To address human capital considerations that are relevant to continuity 

planning and implementation efforts, we reviewed relevant literature, such 

as industry journals, federal guidance, and codes of standards on 

disaster/emergency management and continuity programs. Because the 

available literature was limited in its attention to human capital, we 

conducted semistructured interviews and held a 1-day interactive working 

session with experts from the private sector, federal agencies, and other 

public sector organizations. With input from the National Academy of 

Public Administration, the Private Sector Council, and FEMA, the experts 

were selected based on their experience and knowledge of human capital 

or emergency management as it relates to continuity. 

Individuals from a total of 15 organizations, in addition to FEMA, provided 

their expertise. The organizations included five federal agencies—the 

Centers for Disease Control and Prevention, the Department of Housing 

and Urban Development, the Department of Veterans Affairs, the General 

Services Administration, and the Social Security Administration; five 

private sector businesses—the Gillette Company, Lockheed Martin 

Corporation, Macy’s West, Marsh & McLennan Companies, Inc., and 

Science Applications International Corporation; and five public 

institutions—the Business Continuity Institute, the Disaster Recovery 

Institute International, Emergency Management Alberta (Canada), ClarkAtlanta University, and the University of Tasmania (Australia). We 

supplemented the information from the expert panel by interviewing 

officials from OPM, representatives from FEBs, and representatives from 

federal employee unions. 

To describe the COOP guidance issued by FEMA and the emergency 

preparedness guidance and activities of OPM, we interviewed officials 

from both agencies and analyzed relevant documents, including Federal 

2

 In March 2003, FEMA became a part of the Department of Homeland Security within the 

Directorate of Emergency Preparedness and Response. 
Page 3 GAO-04-384 Human Capital

Preparedness Circular (FPC) 65, which is the primary federal COOP 

guidance, and a series of emergency preparedness memorandums issued 

by the Director of OPM. To describe the role FEBs play in coordinating 

federal efforts relevant to COOP, we interviewed officials from OPM and 

the Chicago, Cleveland, and Philadelphia FEBs.

Our review was conducted from February through December 2003 in 

accordance with generally accepted government auditing standards. 

Appendix I provides additional information on our scope and methodology. 

Results in Brief According to experts from private sector businesses, federal agencies, and 

other public sector organizations with knowledge of human capital or 

continuity planning, continuity planning efforts should and do give priority 

to the immediate aftermath of a crisis—securing the safety of all employees 

and addressing the needs of employees who perform or directly support 

essential operations. However, the experts also note that other human 

capital considerations, especially those associated with the efforts of an 

organization to resume all other operations, are also crucial and often have 

not been well developed. Given that the majority of employees would be 

associated with resumption efforts rather than essential operations, 

considering this segment of the organization is an important part of 

continuity planning. The experts we contacted identified two key human 

capital principles that should guide all continuity efforts: demonstrate 

sensitivity to individual employee needs and maximize the contributions of 

all employees to mission results. 

The experts also identified six organizational actions, which are listed in 

table 1, to enhance continuity efforts by addressing additional human 

capital considerations that are relevant to continuity. 
Page 4 GAO-04-384 Human Capital

Table 1: Key Organizational Actions to Enhance Continuity Efforts

Source: GAO.

In the federal government, FEMA, as executive agent for COOP, and OPM, 

as the President’s agent and advisor for human capital matters, have 

exhibited leadership in addressing human capital considerations relevant 

to COOP. For example, FEMA issued FPC 65, which is the primary 

guidance for federal agencies to use in developing a viable COOP 

capability, to address significant disruptions requiring relocation to an 

alternate facility. However, the guidance does not recognize significant 

disruptions that do not require relocation to an alternate facility. Regarding 

human capital considerations, this guidance directly addresses the need to 

secure the safety of all employees and respond to the needs of personnel 

performing or supporting essential operations. OPM has similarly 

addressed these primary considerations through several initiatives, 

including establishing the Emergency Preparedness subcommittee of the 

Chief Human Capital Officers Council, releasing emergency guides for 

federal employees and managers, and issuing a series of memorandums 

Demonstrate top 

leadership commitment

• Instill an approach to continuity planning that includes human 

capital considerations

• Allocate resources and set policies

• Set direction and pace of recovery

Seek opportunities for 

synergy

• Integrate continuity efforts with broader decision making

• Consider how continuity investments benefit other program 

efforts

Maintain effective 

communication

• Build relationships through two-way communication

• Establish roles, responsibilities, and expectations

• Develop redundant communication vehicles

Target investments in 

training and 

development 

• Raise awareness of continuity efforts

• Build skills and competencies to increase flexibility

• Foster a culture that values flexible employees who are 

empowered to make effective decisions

Leverage the flexibility 

of human capital

• Enable employees associated with resumption activities to 

contribute to mission results in alternate assignments

• Sustain the contribution of employees associated with 

essential operations

• Maintain organizational knowledge of staffing requirements 

and availability

Build process to identify 

and share lessons

• Create a learning environment

• Make learning explicit and shared
Page 5 GAO-04-384 Human Capital

outlining the existing human resource management flexibilities that 

agencies might employ in emergency situations. However, neither FEMA’s 

nor OPM’s guidance to date has adequately addressed the human capital 

considerations related to the resumption of agency operations that are not 

considered essential. Recognizing this, they are working together, as well 

as with other federal partners, to more fully address the considerations 

inherent in these resumption activities. One expected outcome of this 

partnership is an updated and augmented federal COOP guidance that will 

more fully address human capital considerations, particularly those 

regarding employees who will be involved with broader resumption efforts. 

Although not specifically tasked with coordinating COOP efforts, FEBs are 

generally responsible for improving coordination among federal activities 

in areas outside of Washington, D.C. Officials at OPM, which provides 

direction to FEBs, have recognized that the boards can add value to 

regional emergency preparedness efforts, including COOP, as vehicles for 

communication, coordination, and capacity building. The FEBs that we 

visited in Chicago, Cleveland, and Philadelphia are already playing active 

roles in emergency preparedness and COOP efforts by holding COOP 

training seminars, creating emergency preparedness committees, and 

developing and activating emergency dismissal and closure procedures. 

However, the lack of a specific role and defined responsibilities for FEBs 

with regard to emergency preparedness efforts, including COOP, as well as 

a funding structure that results in differing capacities among FEBs, may 

lead to inconsistent levels of preparedness across the nation. 

Given the importance of human capital in maintaining essential functions 

and resuming full operations during an emergency, we recommend that the 

Secretary of Homeland Security direct the Under Secretary of Emergency 

Preparedness and Response to expand the definition of a COOP event to 

recognize severe disruptions that do not affect facilities and complete 

efforts to revise federal COOP guidance to more fully address human 

capital considerations by incorporating the six actions identified in this 

report. We also recommend that the Director of OPM more fully address 

human capital considerations in emergency preparedness guidance by 

incorporating the six actions identified in this report; and determine the 

appropriate role for FEBs in coordinating emergency preparedness efforts, 

including COOP, and address resulting capacity issues. 

On March 10, 2004, we provided a draft of this report to the Secretary of 

Homeland Security and the Director of OPM. We received written 

comments from the Under Secretary of Emergency Preparedness and 
Page 6 GAO-04-384 Human Capital

Response on behalf of the Department of Homeland Security (DHS) and 

FEMA and from the Director of OPM. In his comments, which are 

reprinted in appendix III, the Under Secretary agreed that the report 

addresses the human capital considerations that are relevant to COOP 

guidance and coordination. He added that DHS and FEMA would 

incorporate our recommendations in federal COOP guidance, work jointly 

with OPM and other federal partners to improve the federal government’s 

COOP program, and expand the agency’s efforts to improve coordination of 

COOP program efforts at the regional level. 

In her comments, which are reprinted in appendix IV, the Director of OPM 

said the agency has already carried out our recommendation to more fully 

address human capital considerations in emergency preparedness 

guidance, including COOP, by incorporating the key actions identified in 

the report. Most of the supporting examples provided by OPM were 

included in the draft report and deal largely with human capital 

considerations related to life safety and the needs of personnel performing 

essential operations. While such initiatives are important first steps, there 

remain opportunities to improve OPM’s emergency preparedness guidance 

to include a fuller range of human capital considerations. As such, our 

recommendation to develop additional emergency preparedness guidance 

that incorporates the key actions identified in the report remains 

unchanged. The Director also stated that the leadership role that OPM 

plays with respect to FEBs was not sufficiently developed in the report. 

Most of the supporting examples that the Director provided were included 

in the draft report. Moreover, the additional examples generally do not 

address our larger point that the role of FEBs in coordinating emergency 

preparedness efforts, including COOP, needs to be clearly defined. As 

such, we maintain our conclusion that the context in which FEBs currently 

operate, including the lack of a clearly defined role in emergency 

preparedness efforts and the varying capacities among FEBs, could lead to 

inconsistent levels of preparedness across the nation. The Director of OPM 

also suggested several clarifications to the report. We considered these 

suggestions and made changes to the report where appropriate. 

Background The policy of the U.S. government is to have in place a comprehensive and 

effective program to ensure continuity of essential federal functions under
Page 7 GAO-04-384 Human Capital

all circumstances.3 COOP planning is an effort conducted by individual 

agencies to fulfill that policy and assure that the capability exists to 

continue essential agency functions across a wide range of potential 

emergencies. COOP has been closely associated with continuity of 

government programs, which are meant to ensure the survival of our 

constitutional form of government. COOP was first conceived during the 

Cold War to ensure that the U.S. government would be able to continue to 

function in case of a nuclear war. However, in the wake of the demise of 

the Soviet Union and the reduced threat of nuclear attack in the early 

1990s, COOP planning languished.

Following the World Trade Center bombing in 1993 and the Oklahoma City 

bombing in 1995, COOP as a program was given renewed attention based 

on the recognition of emerging threats and the need to continue essential 

functions of the federal government in an all-hazards environment, which 

includes acts of nature, accidents, technological emergencies, and 

incidents related to military or terrorist attacks. A series of Presidential 

Decision Directives (PDD) was issued that began to link programs for 

terrorism, critical infrastructure protection, and COOP.4

 In addition, as we 

approached the turn of the century, federal agencies also dealt with the 

Year 2000 computer problem by developing business continuity and 

contingency plans to ensure program delivery in the event of a technology 

failure or malfunction. Federal COOP efforts have evolved by building 

upon the planning for each of these events that focused on protecting 

critical infrastructure, both physical systems and cyber-based systems. The 

events of September 11, 2001, highlighted in dramatic fashion the 

vulnerabilities agencies face in each of these areas and focused new 

attention on the effects such events have on agencies’ most important 

assets—their people, or human capital.

FEMA, the General Services Administration (GSA), and OPM are the three 

agencies that have the most direct impact on individual agency efforts to 

develop viable COOP capabilities. PDD 67, which outlined individual 

3

 U.S. Federal Emergency Management Agency, Federal Preparedness Circular 65

(Washington, D.C: July 26, 1999), 2.

4

 See PDD 62, Protection Against Unconventional Threats to the Homeland and Americans 

Overseas, dated May 22, 1998; PDD 63, Critical Infrastructure Protection (CIP), dated 

May 22, 1998, which has been superseded by Homeland Security Presidential Directive 7, 

Critical Infrastructure Identification, Prioritization, and Protection, dated December 17, 

2003; and PDD 67, Enduring Constitutional Government and Continuity of Operations, dated 

October 21, 1998.
Page 8 GAO-04-384 Human Capital

agency responsibilities for COOP, identified FEMA as the executive agent 

for federal COOP planning. As executive agent, FEMA has the 

responsibility for formulating guidance, facilitating interagency 

coordination, and assessing the status of COOP capability across the 

federal executive branch. PDD 67 also required GSA to work with FEMA in 

providing COOP training for federal agencies and to assist agencies in 

acquiring alternate facilities. In addition, the Federal Management 

Regulation requires GSA to lead federal Occupant Emergency Program 

(OEP) efforts, which are short-term emergency response programs that 

establish procedures for safeguarding lives and property during 

emergencies in particular facilities.5

 As the President’s agent and advisor 

for human capital matters, OPM has been actively involved in federal 

emergency preparedness efforts. OPM has issued a series of emergency 

preparedness guides for federal managers, employees, and their families; 

issued a number of memorandums relating to planning, preparedness, and 

the flexibilities available to agencies in emergency situations; and held 

emergency planning and preparedness forums to help agencies select 

emergency personnel. In addition, FEMA, GSA, and OPM collaborate to 

implement the Federal Workforce Release Decision and Notification 

Protocol when emergency situations occur in the Washington, D.C., area. 

Human Capital 

Considerations Are 

Relevant to Continuity 

Planning and 

Implementation Efforts

The current literature indicates, and experts that we consulted confirmed, 

that the immediate response to a crisis should give priority to securing the 

safety of all employees and addressing the needs of employees who 

perform or directly support essential operations. For example, the 

standard for emergency management and business continuity, which was 

developed by the National Fire Protection Association and endorsed by 

FEMA, recommends that organizations include the following priorities in 

their continuity program: ensuring the safety and health of employees, 

5

 As the lead agency for federal OEP efforts, GSA issued the Occupant Emergency Program 

Guide in March 2002. This guidance defines an occupant emergency, details the roles of 

GSA and individual agencies with regard to OEP, and provides step-by-step guidance for 

agencies to use in carrying out their responsibilities for the program. An occupant 

emergency is defined as an event that may require evacuation of occupied space or 

relocation to a safer area. Under OEP, agencies are required to establish an occupancy 

emergency plan designated official, an occupancy emergency plan, and an occupancy 

emergency organization. GSA’s responsibilities include helping agencies to establish and 

maintain the plans and organizations, offering policy guidance about the program, ensuring 

proper administration of the program, reviewing agencies’ plans and organizations annually, 

and helping to train employees and others for emergencies.
Page 9 GAO-04-384 Human Capital

establishing critical functions and processes, and identifying essential 

representatives.6

Consequently, the experts said that these priorities have received most of 

the human capital attention in continuity efforts for both the private and 

public sectors, including federal agencies. Appropriately, organizations 

focus on minimizing the loss of life and injuries, which is key to all other 

recovery efforts. Such efforts commonly include first aid training, 

evacuation plans and drills, and dismissal policies. Organizations also 

focus on identifying the core group of employees that will establish and 

maintain essential operations as dictated by an organization’s mission. 

Organizations, for example, commonly identify leadership structures to 

manage crisis response. Even so, experts noted that organizations vary 

widely in their effectiveness in addressing these priorities. 

The continuity process, however, extends beyond the goals of life safety 

and the performance of essential operations. The experts identified a 

number of human capital considerations beyond these goals that are not 

well addressed. For example, the priorities discussed above do not address 

human capital considerations for employees who are not involved in 

providing essential functions. Such employees would be associated with 

efforts to fully resume all other operations and represent the majority of an 

organization.

The experts identified two principles that should guide actions to more 

fully address human capital considerations applicable to all continuity 

planning and implementation efforts. The first is recognizing and 

remaining sensitive to employees’ personal needs during emergencies 

when shaping the appropriate organizational expectations of employees. 

The emergency event that activates continuity plans may also cause 

emergency events in the personal lives of individual employees. Similar to 

an organization placing its highest priority on the safety and well-being of 

its employees, employees may have high-priority responsibilities to others. 

These personal responsibilities may limit employees’ ability to contribute 

to mission accomplishment until these other obligations are satisfied. 

The second principle experts identified is maximizing the contributions of 

all employees, whether in providing essential operations or resuming full 

6

 National Fire Protection Association, NFPA 1600: Standard on Disaster/Emergency 

Management and Business Continuity Programs (Quincy, Mass.: February 2000).
Page 10 GAO-04-384 Human Capital

services. This should be done within the limits of an employee’s ability to 

contribute given the situation, as described in principle one, and within the 

limits of the organization to use those contributions effectively. According 

to the experts, the experience of organizations during emergencies has 

been that employees remain motivated to contribute to organizational 

results, which is increasingly felt the longer the emergency continues. 

Enabling employees to contribute promotes more effective delivery of 

essential operations and more rapid resumption of full operations. In 

addition, in extreme disruptions of employees’ personal circumstances, 

providing purposeful activities helps avoid the debilitating affects of a 

disruption on employees, including job-related anxiety and post–traumatic 

stress disorder.

The experts we interviewed also identified six organizational actions to 

enhance continuity planning and implementation efforts, listed in figure 1.

Figure 1: Six Organizational Actions to Enhance Continuity Efforts

Build process to identify

and share lessons

Seek opportunities

for synergy

Demonstrate top

leadership commitment

Leverage the flexibility

of human capital

Target investments 

in training and 

development

Maintain effective 

communication

Enhancing continuity efforts

Source: GAO.
Page 11 GAO-04-384 Human Capital

Each of these actions is described in more detail below.

Our past work has shown that the demonstrated commitment of top 

leaders is perhaps the single most important element of successful change 

management and transformation efforts.7

 Effective continuity efforts have 

the visible support and commitment of their organization’s top leadership. 

According to the experts, traditional continuity planning focuses on the 

operations side of recovery and often overlooks human capital 

considerations. As such, it is important for top leadership to ensure that 

the appropriate balance is achieved in considering physical infrastructure, 

technology, and human capital. In providing leadership prior to the 

emergency, leaders demonstrate their commitment to human capital by 

establishing plans that value the organization’s intention to manage 

employees with sensitivity to their individual circumstances, recover 

essential operations on a priority basis, and resume other operations as 

quickly as possible. 

Organizational leaders show commitment to continuity planning by 

allocating resources and setting policies that effectively meet the 

organization’s continuity needs. The experts told us that committed 

leaders provide sufficient funding and staff to conduct planning and 

preparation efforts effectively. While the resources needed vary from 

location to location within an organization, the experts said that 

organizations should have enough resources available to develop effective 

plans, test critical systems, train all staff, and conduct simulation exercises. 

Committed top leadership also ensures that clear policies and procedures 

are in place for all aspects of continuity to ensure that quick and effective 

decisions are made during times of emergencies. Those policies and 

Demonstrate top leadership commitment

• Instill an approach to continuity planning that includes human capital considerations

• Allocate resources and set policies

• Set direction and pace of recovery

7

 See, for example, U.S. General Accounting Office: Results-Oriented Cultures: 

Implementation Steps to Assist Mergers and Organizational Transformations, GAO-03-

669 (Washington, D.C.: July 2, 2003); Highlights of a GAO Forum: Mergers and 

Transformation: Lessons Learned for a Department of Homeland Security and Other 

Federal Agencies, GAO-03-293SP (Washington, D.C.: Nov. 14, 2002); A Model of Strategic 

Human Capital Management, GAO-02-373SP (Washington, D.C.: Mar. 15, 2002); and 

Management Reform: Elements of Successful Improvement Initiatives, GAO/T-GGD-00-26

(Washington, D.C.: Oct. 15, 1999).
Page 12 GAO-04-384 Human Capital

procedures should be fair, shared with employees and their representatives 

in advance of an emergency, and able to be consistently applied to all 

employees. Experts and union leaders we met with agree that the 

cooperation and input from all components within the organization, 

including employees and their representatives, is important in developing 

these policies.

Following a disruption to normal operations, top leadership sets the 

direction and pace of organizational recovery. According to the experts, 

top leadership sets direction by providing the legitimate and identifiable 

voice of the organization for employees to rally around during tumultuous 

times. An expert from Marsh & McLennan Companies, Inc., a company that 

lost over 350 people in the World Trade Center on September 11, 2001, 

noted that in the aftermath of an emergency there is a fundamental need for 

a strong, visible leader to provide constant reassurance. The expert added 

that “employees need to know that someone is in control, even if the 

leaders do not know all the answers.” In addition, top leaders set the pace 

of organizational recovery by providing leadership to both the management 

team leading recovery of essential operations and the management team 

leading the resumption of all other operations. 

As we have previously reported, effective organizations integrate human 

capital approaches as strategies for accomplishing their mission and 

programmatic goals.8

 According to the experts, strategic decisions made to 

improve day-to-day operations, including human capital approaches, and 

those made to build continuity readiness are not exclusive of one another 

and may have synergies. For example, early in 2001, GAO made the 

business decision to supply all of its analysts with laptop computers for 

financial reasons and to provide employees with flexibility in carrying out 

their work. That business decision, however, also contributed to our ability 

to quickly adapt to unforeseeable circumstances in October 2001. In 

response to the release of anthrax bacteria on Capitol Hill, we opened our 

doors to the 435 members of the House of Representatives and selected 

Seek opportunities for synergy

• Integrate continuity efforts with broader decision making

• Consider how continuity investments benefit other program efforts

8

 See, for example, U.S. General Accounting Office, High-Risk Series: Strategic Human 

Capital Management, GAO-03-120 (Washington, D.C.: January 2003); GAO-03-669; GAO-03-

293SP; and GAO-02-373SP.
Page 13 GAO-04-384 Human Capital

members of their staffs. Over 1,000 GAO employees were immediately able 

to make use of their laptops to work from alternate locations. 

Consequently, we minimized the disruption to our operations and assisted 

the House of Representatives in continuing its operations. To take 

advantage of such synergies, the experts said that decisions regarding 

continuity efforts should be integrated with broader business decision 

making. 

The integration of continuity planning with broader decision making helps 

to ensure that the direction of all efforts is consistent and provides mutual 

benefits. In a limited resource environment, consideration of how 

continuity investments benefit other program efforts also helps to 

strengthen the business case for human capital investments that are meant 

to improve continuity capabilities, day-to-day operations, or both.

The importance of communication cannot be overstated. According to the 

experts, two-way communication with employees, their representatives, 

and other stakeholders is key to building relationships and partnerships 

that can facilitate organizational recovery efforts. We have also previously 

reported that communication is most effective when done early, clearly, 

often, and is downward, upward, and lateral.9

 According to a senior 

National Treasury Employees Union (NTEU) official, the union was able to 

capitalize on ongoing two-way communications with the Internal Revenue 

Service’s (IRS) regional leadership to provide members with information 

following the September 11, 2001, attacks. For example, during the 

recovery efforts, the union provided supplementary channels for 

communicating with employees, including daily joint messages from the 

IRS Regional Director and the NTEU Chapter President. In addition, when 

the local New York office reopened on September 20, 2001, both the NTEU 

National President and the IRS Commissioner greeted employees at the 

door. From the union’s perspective, communication efforts such as these 

helped to provide reassurance and support as well as to maintain employee 

trust.

Maintain effective communication

• Build relationships through two-way communication

• Establish roles, responsibilities, and expectations

• Develop redundant communication vehicles

9 GAO-03-669 and GAO-03-293SP.
Page 14 GAO-04-384 Human Capital

According to experts, roles, responsibilities, and performance expectations 

must be communicated to all employees, and their representatives, prior to 

a disruption to promote the efficient and effective use of all of an 

organization’s human capital assets. Early communication enables 

employees to assess and communicate to the organization any personal 

circumstances that may limit their ability to carry out those roles. The 

experts and union officials whom we spoke with agreed that in some cases, 

more formal communication vehicles, such as memorandums of 

understanding or addenda to collective bargaining agreements, may be 

necessary to negotiate changes or clarify roles and responsibilities in 

continuity plans.

Because effective emergency two-way communication depends greatly on 

technology, alternate and redundant communication infrastructures are 

necessary. In addition to technological vulnerabilities that can render 

different methods of communication useless, people frequently do not 

remain tied to the contact number or location listed in emergency records. 

To address these challenges, Macy’s West, for example, has built an 

alternate emergency communication system that serves as an employee 

message retrieval system. The system, which is based outside of the region 

in case the local phone networks are overloaded, allows (1) the leadership 

of Macy’s West to leave messages with instructions for employees,

(2) family members to leave messages for employees, and (3) employees to 

leave messages for their loved ones.

Our past work has shown that organizations should consider making 

targeted investments in human capital approaches, such as training and 

development.10 According to the experts, training and development 

programs related to continuity efforts can help to raise awareness among 

all employees. The Social Security Administration (SSA), for example, has 

developed a video-training course to provide an overview of COOP, which 

includes an introduction from the Commissioner explaining why COOP is 

so important, a discussion of SSA’s critical workloads and how they would 

Target investments in training and development 

• Raise awareness of continuity efforts

• Build skills and competencies to increase flexibility

• Foster a culture that values flexible employees who are empowered to make effective 

decisions

10 GAO-02-373SP.
Page 15 GAO-04-384 Human Capital

be processed during a disruption, and references to federal guides and 

information. The experts noted that less formal approaches, such as 

continuity planning awareness weeks, could also help to raise awareness. 

Our recent work has indicated that training and development programs 

build skills and competencies that enable employees to fill new roles and 

work in different ways, which helps to build organizational flexibility.11 

According to experts, the training and development goals for employees 

assigned to the team that performs essential operations differ from those 

for the employees assigned to the team that is responsible for resuming all 

other organizational operations. The goal for the team that performs 

essential operations is to achieve “critical depth,” which occurs when an 

adequate number of employees are available to staff each critical function, 

in the event that a member of the team expected to perform that function is 

unavailable. Organizations can build critical depth in various ways, 

including using exercises that simulate an emergency to train backup 

employees alongside employees who have primary responsibility for an 

essential operation, or allowing backup employees to perform the 

operation while the primary employees oversee and critique their 

performance. In addition, critical depth can be built through succession 

planning. To be effective for this purpose, however, the scope of 

succession planning is extended to recognize that there is no time to 

develop successors in an emergency and incrementally increase levels of 

authority as an individual matures in a position. Therefore, organizations 

may have to plan to use predecessors to a position, including retirees, as 

successors. 

With regard to the team that is responsible for resuming all other 

organizational operations, experts said that the training and development 

goal is to build sufficient breadth to enable members to contribute to 

resumption efforts in a variety of ways. For example, development 

programs requiring employees to rotate within an organization to learn a 

variety of positions, potentially at a variety of locations, contribute to 

11 We have identified eight core characteristics of a strategic training and development 

process that can help make a training and development program effective and strategically 

focused on achieving results. These characteristics are strategic alignment; leadership 

commitment and communication; stakeholder involvement; accountability and recognition; 

effective resource allocation; partnerships and learning from others; data quality assurance; 

and continuous performance improvement. For more information on these characteristics, 

see U.S. General Accounting Office, Human Capital: A Guide for Assessing Strategic 

Training and Development Efforts in the Federal Government, GAO-04-546G (Washington, 

D.C.: March 2003).
Page 16 GAO-04-384 Human Capital

critical breadth. We have previously reported that developmental 

assignments place employees in new roles or unfamiliar job environments 

in order to strengthen skills and competencies and broaden their 

experience.12

Effective training and development initiatives also help to foster a culture 

that is characterized by flexible employees who are empowered to make 

effective decisions independently. According to experts, such a culture is 

often critical to agency recovery and resumption efforts. Experts from 

Marsh & McLennan Companies, Inc., reported that effective decisionmaking abilities could be developed through formal training about the 

parameters in which employees are empowered to make decisions and onthe-job experiences demonstrating how employees can exercise authority 

in making decisions that manage, rather than avoid, risk and are focused on 

achieving results. 

The events of September 11, 2001, give ample evidence of the dedication 

and flexibility of federal, state, and local government employees in 

providing services to the American public. Disruption of normal 

operations challenges an organization to use this dedication and flexibility 

to its advantage, especially with regard to employees associated with the 

resumption of all operations that are not considered essential. According 

to the experts, organizations may use approaches such as telework and 

geographic dispersion, which includes regional structure, to increase the 

ways in which employees may contribute. As OPM guidance has 

underscored and presenters at a recent conference held by the 

International Telework Association and Council noted, telework is an 

important and viable option for federal agencies in COOP planning and 

implementation efforts, especially as the duration of the emergency event 

12 U.S. General Accounting Office, Human Capital: Insights for U.S. Agencies from Other 

Countries’ Succession Planning and Management Initiatives, GAO-03-914 (Washington, 

D.C.: Sept. 15, 2003).

Leverage the flexibility of human capital 

• Enable employees associated with resumption activities to contribute to mission 

results in alternate assignments 

• Sustain the contribution of employees associated with essential operations

• Maintain organizational knowledge of staffing requirements and availability 
Page 17 GAO-04-384 Human Capital

is extended.13 However, to make effective use of telework, experts told us 

that organizations should identify those employees who are expected to 

telework during a disruption and communicate that expectation to them in 

advance. In addition, organizations should provide teleworkers with 

adequate support in terms of tools, training, and guidance. 14 Geographic 

dispersion can also provide a way for employees associated with 

resumption activities to continue their normal functions albeit at or 

through other locations. For example, SSA recognizes that its field 

structure enables the agency to make use of both multiple locations and 

telework in providing its employees ways to contribute because most field 

functions can be transferred fairly easily from one location to another in 

the same region or performed remotely with laptop computers. Based on 

these efforts, SSA does not envision a scenario in which its field employees 

would not contribute to their normal functions for more than 72 hours.

Employees demonstrate their flexibility by a willingness to contribute to 

the organization in roles that may be unusual. According to the experts, 

flexible employees contribute as best they can usually in the following 

sequence: (1) providing support to the team performing essential 

operations, if needed; (2) continuing to contribute to their normal missionrelated functions; (3) performing an alternate contribution for their 

organization; or if none of these can be accomplished, (4) volunteering in 

their communities as a direct form of public service. Federal employees 

may have additional opportunities to contribute to not only their own 

agencies’ operations but also other agencies’ operations in serving the 

American people. In addition, a recent memorandum from OPM recognizes 

the value of federal employees contributing to the general public through 

community volunteer service in the range of alternative contributions.15

13 See, for example, U.S. Office of Personnel Management, “Memorandum for Heads of 

Executive Departments and Agencies: Washington, DC, Area Dismissal or Closure 

Procedures,” December 4, 2003, and “Memorandum for Heads of Executive Departments 

and Agencies: Level Orange Emergency Human Resources Management (HRM) 

Authorities,” March 17, 2003.

14 Our previous work has also identified 25 key practices for implementation of successful 

federal telework programs. See U.S. General Accounting Office, Human Capital: Further 

Guidance, Assistance, and Coordination Can Improve Federal Telework Efforts, GAO-03-

679 (Washington, D.C.: July 18, 2003).

15 U.S. Office of Personnel Management, “Memorandum for Heads of Executive 

Departments and Agencies: Subject: Widespread Power Outage,” August 15, 2003.
Page 18 GAO-04-384 Human Capital

Employees associated with providing essential operations may be working 

under unusual pressures for extended periods of time, and organizations 

need to consider ways to sustain these efforts. The experts recommend 

that if the circumstances of the emergency continue long enough to raise 

concerns about burnout, organizations consider providing opportunities 

for working in shifts; rotating assignments among team members; 

providing relief through the use of qualified employees associated with 

resumption activities; reemploying retirees; or utilizing employees from 

stakeholder or networked organizations, such as suppliers or contractors. 

According to the experts, the ability of organizations to match staffing 

requirements with available skills and abilities could be enhanced through 

various initiatives, such as job banks, skill profile databases, and prearranged partnerships with other organizations or community service 

organizations. For example, job banks that detail additional jobs that may 

be required during an emergency but are not considered essential could 

allow employees to preselect alternate contributions that they would be 

able to perform. In the federal government, agencies could establish their 

own job banks; form interagency partnerships that link the potential needs 

of several agencies; and create a cache for volunteer opportunities, 

possibly tied to the Citizen Corps.16 Organizations with databases that 

collect employee knowledge, skills, and abilities (KSA)—even those KSAs 

outside the scope of an employee’s normal functions—may complement 

the job banks by allowing organizations to match available KSAs with the 

unmet needs of the organization.

An evaluation process that explicitly identifies and disseminates lessons 

learned during disruptions, or simulations of disruptions, promotes 

16 President Bush created the Citizen Corps in January 2002, as a component of the USA 

Freedom Corps, to help coordinate volunteer activities that will make communities safer, 

stronger, and better prepared to respond to any emergency situation. This mission is carried 

out through a national network of Citizen Corps Councils that build on community strengths 

to implement the program and carry out a local strategy. FEMA coordinates the program 

nationally. In this capacity, FEMA works closely with key stakeholders, including other 

federal entities, state and local governments, first responders, emergency managers, and the 

volunteer community. More information can be found at www.citizencorps.gov or by calling 

1-877-USA-CORPS.

Build process to identify and share lessons 

• Create a learning environment

• Make learning explicit and shared
Page 19 GAO-04-384 Human Capital

learning among all of an organization’s human capital assets and helps to 

improve organizational performance. An organization that is committed to 

learning has an inclusive and supportive process and a framework designed 

prior to a disruption to gather important data. According to experts, 

organizations committed to learning will ensure that those employees who 

are key to the recovery and resumption efforts are involved in the formal 

evaluation process in a timely manner and will seek the input from as many 

other employees as possible. Such an inclusive environment will enable 

the organization to discover valuable lessons learned by employees in 

unusual circumstances. In addition, conducting evaluations in a “noblame,” nonattribution atmosphere and taking organizational ownership of 

any problems that might be identified increases the openness with which 

participants are willing to share their experiences. To encourage such an 

environment, FEMA officials told us that the agency’s Office of National 

Security Coordination has recently implemented a reporting system that 

allows any employee to identify lessons learned anonymously during an 

emergency, instead of waiting for the formal review process.

Our past work has shown that human capital approaches are best designed 

and implemented based on data-driven decisions.17 According to experts, 

having a framework prior to a disruption helps to gather data important to 

evaluating the effectiveness of human capital approaches during a 

disruption. Some measures that they suggested include number of 

employees contributing to mission-related outcomes each day; degree of 

contribution (e.g., part time or full time); location of employee when 

contributing (e.g., at alternate facility or home); type of contribution (e.g., 

performing same function, performing an alternate function within the 

department, working with another department, or volunteering); or 

obstacles to contribution (e.g., organizational or personal).

Once identified, it is important for the lessons learned during the 

evaluation to be made explicit and then widely disseminated. According to 

experts, the manner and formality of documentation and dissemination, 

however, depend on the situation or needs of the organization (e.g., afteraction reports, detailed analyses, executive summaries, video tapes, CDs, 

or Web-based reports). There are unique opportunities in the federal 

government for agencies to share explicit lessons learned both internally 

and with other federal agencies and stakeholders. For example, following 

the September 11, 2001, attacks, senior Department of Housing and Urban 

17 GAO-02-373SP.
Page 20 GAO-04-384 Human Capital

Development officials asked the New York Acting Regional Director to 

recount her experiences and lessons learned in front of a video camera. 

The accounts were edited down into a 30-minute video entitled Thinking 

the Unthinkable: Preparing for Disaster. That video has been used within 

the department as a training aid and has been shared with over 50 federal 

agencies with the help of the Washington, D.C.–based interagency COOP 

Working Group (CWG) and the FEBs in cities across the United States. In 

Canada, Emergency Management Alberta (EMA) employs a centralized 

Disruption Incident Reporting System for all government agencies, which 

is accessible via the Internet, to obtain timely and accurate reporting of all 

disruptions and “most importantly, ensure lessons learned can be 

documented for follow-up.” 18 EMA has also created a Lessons Learned 

Warehouse Web site to share continuity lessons learned in all aspects of 

crisis management.19 

FEMA and OPM Have 

Exhibited Leadership 

in Addressing Human 

Capital Considerations 

Relevant to COOP

As we stated earlier, the human capital considerations related to life safety 

and the needs of personnel performing essential operations have largely 

been addressed in continuity efforts. In the federal government, FEMA has 

issued guidance that has addressed these considerations and has 

recognized the opportunity to more fully address human capital 

considerations in its guidance. In addition, OPM has issued federal 

emergency preparedness guidance relevant to COOP that also addresses 

these considerations and is working with FEMA to more fully address 

human capital considerations in federal guidance. 

FEMA Issued Guidance 

That Addresses Human 

Capital Considerations, but 

Recognizes Opportunity to 

Do More

As executive agent for federal COOP planning, FEMA issued FPC 65 in July 

1999 as the primary guidance for agencies developing viable COOP plans. 

According to FPC 65, the purpose of COOP planning is to facilitate the 

performance of agency essential functions for up to 30 days during any 

emergency or situation that may disrupt normal operations. The five 

objectives of a viable COOP plan listed in FPC 65 are (1) ensuring the 

continuous performance of an agency’s essential functions during an 

emergency; (2) protecting essential facilities, equipment, records, and 

18 Emergency Management Alberta, “Disruption Incident Reporting System,”

www.municipalaffairs.gov.ab.ca/ema/BRP/DIRS.cfm (downloaded Feb. 19, 2004). 

19 Emergency Management Alberta, “Welcome to the Lessons Learned Warehouse,”

www.municipalaffairs.gov.ab.ca/ema/BRP/Welcome.cfm (downloaded Feb. 19, 2004). 
Page 21 GAO-04-384 Human Capital

other assets; (3) reducing or mitigating disruptions to operations; 

(4) reducing loss of life, minimizing damage and losses; and (5) achieving a 

timely and orderly recovery from an emergency and resumption of full 

service to customers. 

The guidance subsequently limits a COOP event to one that significantly 

affects the facilities of an organization and requires the establishment of 

essential operations at an alternate location. Therefore, as FEMA 

recognizes, the guidance does not apply to significant disruptions that 

leave facilities intact, such as a severe acute respiratory syndrome (SARS) 

outbreak that could lead a large number of employees to avoid congested 

areas, including their workplaces. Although a people-only event such as 

SARS would significantly disrupt normal operations, the current COOP 

guidance would not apply because facilities would remain available. FPC 

65 also indicates that the guidance is for use at all levels and locations of 

federal agencies. FEMA officials acknowledge, however, that the priority 

of COOP planning to date has been focused on agency headquarters 

located in the Washington, D.C., area.

Given the purpose of COOP and the nature of its objectives, the human 

capital considerations FEMA included in the guidance primarily relate to 

life safety for all employees and addressing the needs of employees 

performing essential operations. For example, the guidance states that one 

of the objectives of COOP is “reducing loss of life, minimizing damage and 

losses.” It also refers to the legal requirement that each agency develop a 

viable OEP, which is a short-term emergency response program that 

establishes procedures for safeguarding lives and property during 

emergencies in particular facilities.20 FPC 65 more broadly defines life 

safety by including a statement related to the need to consider the health 

and emotional well-being of employees on the essential operations team. 

Also, with respect to employees who perform essential functions, the 

guidance directs agencies to designate an emergency team, delegate 

authority, establish orders of succession, develop communication plans, 

develop training programs, and provide for accountability. 

FEMA officials we spoke with recognized that there is a need to go beyond 

the human capital considerations that have already been addressed within 

federal COOP guidance in order to achieve the full range of COOP 

20 41 C.F.R. §§ 102-74.230 – 102-74.260 and U.S. General Services Administration, Occupant 

Emergency Program Guide (Washington, D.C.: March 2002).
Page 22 GAO-04-384 Human Capital

objectives. Specifically, FEMA officials agreed that it was particularly 

important to deal with the human capital considerations inherent to the 

resumption activities needed to fully recover from an emergency. To that 

end, FEMA has taken several steps to more fully address these 

considerations. FEMA has worked with a subcommittee of the interagency 

CWG—a Washington, D.C.–based group that meets monthly to discuss 

issues related to COOP—to rewrite the federal COOP guidance. The 

agency has requested OPM’s assistance in incorporating these 

considerations into the new federal COOP guidance. FEMA has also 

worked in cooperation with us as we developed this report. As a result, 

FEMA officials told us that the draft guidance would include an augmented 

discussion of human capital considerations. 

OPM Has Also Exhibited 

Leadership in Addressing 

Human Capital 

Considerations Related to 

Emergency Preparedness

OPM has also recognized the value of human capital in COOP and other 

emergency preparedness efforts. In a memorandum to the heads of 

executive departments and agencies, for example, the Director of OPM 

stated that “the American people expect us to continue essential 

government services without undue interruption, no matter the 

contingency, and Federal agencies must have the human resources to 

accomplish their missions, even under the most extreme of 

circumstances.”21 To this end, OPM has established the Emergency 

Preparedness subcommittee of the Chief Human Capital Officers Council 

that is tasked with recommending policy changes, legislative changes, or 

other strategies for moving the issue forward. In addition, OPM has 

initiated several efforts to help agencies address human capital 

considerations in emergency preparedness related to life safety and the 

needs of personnel performing essential operations, as well as to recognize 

the role that employee organizations and unions could play in supporting 

those efforts. These initiatives are important first steps; however, they do 

not fully address human capital considerations related to the resumption of 

all agency operations that are not considered essential.

With regard to providing for the safety of all employees, OPM has issued 

four preparedness guides to educate federal employees, managers, and 

their families on how to protect themselves from a potential biological, 

21 U.S. Office of Personnel Management, “Memorandum to Heads of Executive Departments 

and Agencies: Level Orange Emergency Human Resources Management (HRM) 

Authorities,” March 17, 2003.
Page 23 GAO-04-384 Human Capital

chemical, or radiological release, whether accidental or intentional.22 The 

guides also spell out the responsibilities of the federal government and 

individual agencies to protect employees in the event of an emergency. In 

addition to the guides, OPM has addressed safety issues by revising the 

Washington, D.C., area emergency dismissal protocols for federal 

employees and contractors, in conjunction with FEMA and GSA; issuing 

memorandums to all agency heads detailing the “minimum obligations” 

agencies have to secure the safety of federal workers; issuing two 

emergency preparedness surveys through which federal agencies could 

report on their progress in ensuring the safety of their employees; and 

highlighting the role that Employee Assistance Programs can play in 

responding to employee needs in emergency situations. 

Related to providing for the needs of employees performing or supporting 

essential operations, OPM has led two forums focusing on emergency 

employee designations and the flexibilities that are available to agencies in 

emergency situations. OPM has also issued a series of memorandums 

outlining the existing human resource management flexibilities that 

agencies might employ in emergency situations.23 Other human capital 

flexibilities that are available to agencies in nonemergency situations, such 

as telecommuting, job sharing, and flexible scheduling, might provide 

additional assistance during emergency situations and are detailed in 

OPM’s handbook, Human Resources Flexibilities and Authorities in the 

Federal Government. (See app. II for a list of human resource flexibilities 

that agencies may use to respond to emergency situations.)

In addition to initiating efforts to address several human capital 

considerations, OPM has highlighted the need to work with and through 

employee organizations and unions in developing and executing emergency 

management strategies. For example, OPM has held meetings with federal 

22 The four guides are entitled A Federal Employee’s Emergency Guide, Federal 

Manager’s/Decision Maker’s Emergency Guide, A Federal Employee’s Family 

Preparedness Guide, and A Federal Employee’s Family Preparedness Guide (For the 

Washington, D.C. Area). 

23 See U.S. Office of Personnel Management, “Memorandum for Heads of Departments and 

Agencies: Wildfires in California,” October 27, 2003; “Memorandum for Heads of 

Departments and Agencies: Hurricane Isabel,” September 19, 2003; and “Memorandum for 

Heads of Executive Departments and Agencies: Level Orange Emergency Human Resources 

Management (HRM) Authorities,” March 17, 2003. See also U.S. Office of Personnel 

Management, Human Resources Flexibilities and Authorities in the Federal Government

(Washington, DC: July 25, 2001).
Page 24 GAO-04-384 Human Capital

labor union leaders and employee associations to discuss relevant 

employee safety issues and has specifically encouraged agencies to work 

with and share information on preparedness efforts with applicable 

employee organizations and unions. Senior union officials whom we spoke 

with from the American Federation of Government Employees and NTEU 

agreed that it is important for unions to be involved throughout COOP 

planning and implementation efforts. These officials also stated that 

unions could be resources for agencies in communicating with employees, 

both before and during an emergency, as well as in engaging employees in 

recovery and resumption efforts.

FEBs Have 

Opportunities to 

Coordinate Regional 

Emergency Planning 

Efforts, Including 

COOP, in Major 

Metropolitan Areas

Although FEMA heads the interagency CWG to help coordinate COOP 

efforts in the Washington, D.C., area, the efforts of this group do not apply 

to the over 80 percent of federal employees who work outside of this area. 

While not specifically tasked with coordinating COOP efforts, FEBs are 

generally responsible for improving coordination among federal activities 

and programs in major metropolitan areas outside of Washington, D.C.24 

Under the direction of OPM, FEBs support and promote national initiatives 

of the President and the administration and respond to the local needs of 

federal agencies and the community. OPM officials have recognized that 

FEBs can add value to regional emergency preparedness efforts, including 

COOP, as vehicles for communication, coordination, and capacity building. 

To make use of these capabilities, OPM has provided FEBs with relevant 

emergency preparedness materials, encouraged FEBs to focus on 

preparedness issues in their regions, requested that FEBs test their 

emergency communication plans, and encouraged FEBs to inform OPM of 

any emergency-related events affecting federal employees in the regions. 

The FEBs that we visited are already playing active roles in regional 

emergency preparedness and COOP efforts. For example, the Chicago 

FEB has established committees to deal with Disaster Recovery Planning 

and Emergency Release; surveyed its member agencies to determine the 

24 Although this section focuses on FEBs, much of the discussion could also apply to Federal 

Executive Associations (FEA) and Federal Executive Councils (FEC) that are located in 

cities where FEBs do not exist. FEAs and FECs have purposes and objectives similar to 

FEBs although they do not function within the same formal set of parameters as FEBs (e.g., 

they are not officially established by Presidential Memorandum, nor do they receive policy 

direction or guidance from OPM). FEAs and FECs also do not have permanent status and, 

according to OPM, often disband and regroup depending on the local commitment of agency 

members.
Page 25 GAO-04-384 Human Capital

status of COOP planning in the region; sponsored a series of seminars, in 

conjunction with GSA and FEMA, on topics related to COOP, sheltering in 

place, and national security; participated in regional exercises, such as 

TOPOFF 2;25 and sponsored a COOP exercise to provide agencies with a 

forum for validating their COOP plans, policies, and procedures. The 

Cleveland FEB has established an emergency preparedness committee to 

promote awareness and preparation, developed an Employee Emergency 

Contingency Handbook that provides basic actions to respond to 

emergencies that may be encountered by federal employees, and helped to 

make training available to all federal agencies. The Philadelphia FEB has 

held several COOP workshops for agencies and regularly shares relevant 

information with agency officials via e-mail. In addition, these FEBs play a 

role in developing and activating dismissal and closure procedures for 

federal agencies located in their particular regions. 

Although both OPM officials and the FEB officials whom we spoke with 

recognized that FEBs can add value in coordinating emergency 

preparedness efforts, including COOP, and that such a role is a natural 

outgrowth of general FEB activities, a specific role and responsibilities 

have not been defined. In addition, the current structure in which FEBs 

operate results in differing capacities of FEBs across the nation. For 

example, each agency’s participation in FEB activities is voluntary. 

Consequently, FEBs can only make recommendations to agencies, without 

the ability to require agency compliance. Also, FEBs rely on host agencies 

for funding, which results in variable funding and staffing from year to year 

and across FEBs. OPM has recognized that the roles and capacities of 

FEBs vary across the nation and has established an internal working group 

to study the strengths and weaknesses of FEBs and develop 

recommendations for improving their capacity to coordinate in regions 

outside of Washington, D.C. According to OPM, such efforts in regard to 

local emergency preparedness and response will include improving 

dissemination of information and facilitation of COOP training and tabletop 

exercises; addressing the implications for strategic human capital 

management in continuing the operations of the federal government (e.g., 

alternate work schedules, remote work sites, and telecommuting 

25 TOPOFF 2 was conducted from May 12 through May 16, 2003, and involved top 

government officials from federal, state, local, and Canadian participants in a full-scale 

exercise that assessed how responders, leaders, and other authorities would react to the 

simulated release of weapons of mass destruction in two U.S. cities, Seattle and Chicago. 
Page 26 GAO-04-384 Human Capital

capabilities); and developing strategies to better leverage the network of 

FEBs to help departments and agencies implement their initiatives. 

Conclusions More fully addressing human capital considerations in emergency 

preparedness guidance, including COOP, could improve agency response 

capabilities to large-scale COOP emergencies or situations; could help 

minimize the impact of more common, yet less catastrophic disruptions 

(e.g., snowstorms and short-term power outages); and is consistent with 

building a more flexible workforce, which would enhance ongoing efforts 

across the federal government to create more responsive human capital 

management systems. As FEMA works to update its federal COOP 

guidance and OPM continues to issue emergency preparedness guidance 

relevant to COOP, several areas require attention to more fully address 

human capital considerations relevant to COOP. 

By limiting COOP to situations that necessitate moving to an alternate 

facility, agencies are left without guidance for situations in which an 

agency’s physical infrastructure is unharmed, but its employees are 

unavailable or unable to come to work for an extended period of time. 

While facilities and technology would not be affected by such situations, 

the unavailability of people to contribute to mission-related outcomes 

could cause a significant disruption to normal operations. 

Emergency guidance, including COOP, generally does not extend beyond 

consideration of life safety and the needs of employees performing 

essential operations. Therefore, the guidance excludes most agency 

employees—those who would be associated with resuming all other 

operations.

FEBs are uniquely situated to improve coordination of emergency 

preparedness efforts, including COOP, in areas outside of Washington, D.C. 

However, the context in which FEBs currently operate, including the lack 

of a clearly defined role in emergency preparedness efforts, including 

COOP, and varying capacities among FEBs, could lead to inconsistent 

levels of preparedness across the nation. 

Recommendations for 

Executive Action

We recommend that the Secretary of Homeland Security direct the Under 

Secretary for Emergency Preparedness and Response to take the following 

two actions:
Page 27 GAO-04-384 Human Capital

• Expand the definition of a COOP event in federal guidance to recognize 

that severe emergencies requiring COOP implementation can include 

people-only events.

• Complete efforts to revise federal COOP guidance to more fully address 

human capital considerations by incorporating the six organizational 

actions identified in this report. 

We recommend that the Director of OPM take the following two actions:

• Develop and provide additional emergency preparedness guidance to 

more fully address human capital considerations by incorporating the 

six organizational actions identified in this report.

• Determine the desired role for FEBs to play in improving coordination 

of emergency preparedness efforts, including COOP, and identify and 

address FEB capacity issues to meet that role. It would be appropriate 

for FEBs to be formally incorporated into federal emergency 

preparedness guidance, including COOP guidance, for areas outside of 

Washington, D.C. 

Agency Comments and 

Our Evaluation

We provided the Secretary of Homeland Security and the Director of OPM a 

draft of this report for review and comment. We received written 

comments from the Under Secretary of Emergency Preparedness and 

Response on behalf of FEMA and the Department of Homeland Security, 

which are reprinted in appendix III. In his comments, the Under Secretary 

stated that the draft accurately addressed human capital considerations 

relevant to COOP guidance and coordination and noted that DHS and 

FEMA will continue to work with OPM and other federal partners to 

improve the federal government’s COOP plan by incorporating our 

recommendations in its federal COOP guidance. In addition, he stated that 

FEMA would expand its efforts with its regional offices and FEBs to 

improve coordination of COOP programs at the regional level.

The Director of OPM also provided written comments, which are reprinted 

in appendix IV. In her comments, the Director noted her appreciation for 

our acknowledgement of the agency’s leadership role in addressing human 

capital considerations relevant to COOP planning. However, the Director 

of OPM stated that the agency has already carried out our recommendation 

to more fully address human capital considerations in emergency 

preparedness guidance, including COOP, by incorporating the key actions 
Page 28 GAO-04-384 Human Capital

identified in the report. The Director provided numerous examples of 

actions OPM has taken to support emergency preparedness efforts, all of 

which she noted were influenced by the agency’s human capital 

framework. In addition, the Director also attached an enclosure to the 

agency comments that contain examples of OPM’s internal COOP-related 

efforts that she believes would be helpful to federal agencies. 

Most of the examples of emergency preparedness guidance that the 

Director of OPM provided were included in the draft report and deal largely 

with the human capital considerations related to life safety and the needs 

of personnel performing essential operations. While such initiatives are 

important first steps, there remain opportunities to improve OPM’s 

emergency preparedness guidance to include a fuller range of human 

capital considerations, particularly related to the resumption of all agency 

operations that are not considered essential. As such, our assessment of 

OPM’s guidance and our recommendation for the agency to develop and 

provide additional emergency preparedness guidance that incorporates the 

key actions identified in the report remain unchanged. 

With regard to our second recommendation for OPM to determine the 

desired role of FEBs in improving coordination of emergency preparedness 

efforts, including COOP, and address any resulting capacity issues, the 

Director of OPM stated that the leadership role the agency plays with 

respect to FEBs was not sufficiently developed in the report and she 

provided examples of OPM’s support for the FEB’s efforts. Most of the 

supporting examples that the Director provided were included in the draft 

report. Moreover, the additional examples generally do not address our 

larger point that the role of FEBs in coordinating emergency preparedness 

efforts, including COOP, needs to be clearly defined. As such, we maintain 

our conclusion that the context in which FEBs currently operate, including 

the lack of a clearly defined role in emergency preparedness efforts and the 

varying capacities among FEBs, could lead to inconsistent levels of 

preparedness across the nation. 

The Director of OPM suggested several clarifications to the report, which 

we considered and incorporated where appropriate. For example, she 

suggested both technical and substantive changes to a footnote describing 

Federal Executive Associations (FEA) and Federal Executive Councils 

(FEC). While we made technical changes in response to these comments, 

our work does not allow us to categorically exclude all FEAs and FECs as 

viable options for the coordination of emergency preparedness activities, 

as the Director suggested in her response. Instead, we recognize that any 
Page 29 GAO-04-384 Human Capital

guidance provided to FEBs would likely be beneficial to FEAs and FECs 

despite their differences. The Director also provided additional details 

describing OPM’s internal working group that is studying the strengths and 

weaknesses of FEBs, and we have incorporated these details into the 

report. 

We are sending copies of this report to the Ranking Minority Member, 

Subcommittee on Oversight of Government Management, the Federal 

Workforce, and the District of Columbia, Senate Committee on 

Governmental Affairs; the Chairman and Ranking Minority Member, House 

Committee on Government Reform; the Chairman and Ranking Minority 

Member, Subcommittee on Homeland Security, House Committee on 

Appropriations; the Chairman and Ranking Minority Member, 

Subcommittee on National Security, Emerging Threats, and International 

Relations, House Committee on Government Reform; and other interested 

congressional parties. We will also send copies to the Secretary of 

Homeland Security, the Under Secretary of Emergency Preparedness and 

Response and the Director of OPM. This report will also be available at no 

charge on the GAO Web site at http://www.gao.gov.

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

contact me or William Doherty on (202) 512-6806. Key contributors to this 

report include Kevin J. Conway, Tiffany Tanner, Thomas Beall, Amy Choi, 

Amy Rosewarne, John Smale, and Michael Volpe.

Sincerely yours,

J. Christopher Mihm

Managing Director, Strategic Issues
Page 30 GAO-04-384 Human Capital

Appendix I

Objectives, Scope, and Methodology ApApenednxidexiIs

The objectives of this report were to

• identify the human capital considerations that are relevant to federal 

agencies’ continuity planning and implementation efforts; 

• describe the continuity of operations (COOP) guidance provided by the 

Federal Emergency Management Agency (FEMA) and emergency 

preparedness guidance and activities of the Office of Personnel 

Management (OPM) to address human capital considerations relevant 

to COOP; and

• describe the role Federal Executive Boards (FEB) play, relevant to 

COOP, in coordinating efforts outside of the Washington, D.C., area.

To address human capital considerations that are relevant to continuity 

planning and implementation efforts, we reviewed relevant literature, such 

as industry journals, federal guidance, and codes of standards on 

disaster/emergency management and continuity programs. Because the 

available literature was limited in its attention to human capital, we based 

our work primarily on semistructured interviews with experts from private 

sector businesses, federal government agencies, and public institutions. 

We first reviewed industry journals, magazines, and Web sites; queried state 

and international auditors; attended a national business continuity 

conference; and sought input from the National Academy of Public 

Administration (NAPA), the Private Sector Council (PSC), and FEMA to 

identify individuals or organizations with the relevant knowledge needed to 

address our first objective. We selected individuals or organizations that 

had one or more of the following characteristics: (1) experience 

responding to, recovering from, and resuming business activities following 

an emergency, from which human capital lessons may have been drawn; 

(2) experience incorporating human capital considerations into their 

organization’s continuity planning efforts; (3) specific human capital 

expertise that could be applied to continuity planning and implementation 

efforts; and (4) specific continuity expertise that is broad enough to 

identify those critical areas that require human capital attention. When an 

organization was selected, we then contacted the organization to identify 

the specific individuals who had the relevant expertise. 

On the basis of these characteristics and the input from NAPA, PSC, and 

FEMA, we selected organizations or individuals within organizations to 

obtain a diversity of views from both the public and private sector. 

Individuals from a total of 15 organizations, in addition to FEMA, provided 
Appendix I

Objectives, Scope, and Methodology

Page 31 GAO-04-384 Human Capital

their expertise in addressing our objective. The organizations include five 

federal agencies—the Centers for Disease Control and Prevention, the 

Department of Housing and Urban Development, the Department of 

Veterans Affairs, the General Services Administration, and the Social 

Security Administration; five private sector businesses—the Gillette 

Company, Lockheed Martin Corporation, Macy’s West, Marsh & McLennan 

Companies, Inc., and Science Applications International Corporation; and 

five public institutions—the Business Continuity Institute, the Disaster 

Recovery Institute International, Emergency Management Alberta 

(Canada), Clark-Atlanta University, and the University of Tasmania 

(Australia). 

We then conducted three cycles of work to identify the human capital 

considerations that are relevant to continuity, with each subsequent cycle 

building upon the information gathered in previous cycles. We adopted this 

approach because our initial conversations with experts indicated that a 

common perspective of the continuity process could help structure and 

focus our subsequent interviews with experts about the relevant human 

capital considerations. Cycle one involved conducting semistructured 

interviews with experts from FEMA and 5 of the 15 organizations.1

 We 

asked each to describe a view of the entire continuity process from a 

human capital perspective. We used those descriptions to synthesize a 

framework that we then shared with each of the first cycle experts for 

comment. The experts generally agreed with the content of the framework 

and agreed that it would be useful in focusing subsequent interviews about 

human capital considerations. In the second cycle, we used this 

framework as a reference when conducting in-depth, semistructured 

interviews with experts from all 15 organizations and FEMA about the 

human capital considerations relevant to continuity. For the third cycle, 

we held a 1-day working group, in cooperation with FEMA, to more fully 

discuss the human capital considerations previously identified in cycles 

one and two. The interactive nature of the working group, which included 

a cross-section of the experts and additional representatives from GAO,2

1

 The cycle one participants were FEMA, the Department of Housing and Urban 

Development, the Gillette Company, Lockheed Martin Corporation, the Business Continuity 

Institute, and Clark-Atlanta University.

2

 The working group participants were from FEMA, the Department of Housing and Urban 

Development, the Social Security Administration, Lockheed Martin Corporation, Marsh & 

McLennan Companies, Inc., Science Applications International Corporation, and the 

Disaster Recovery Institute International, as well as representatives from GAO.
Appendix I

Objectives, Scope, and Methodology

Page 32 GAO-04-384 Human Capital

helped to ensure that we had adequately captured the key considerations 

relevant to continuity. As a final check, we provided all of the experts with 

a summary document that included the statements used throughout this 

report and attributed to the experts. We asked the experts to review the 

statements for fundamental disagreement or fatal flaws. Almost all experts 

responded and generally agreed with our treatment of these issues. 

To supplement information we received in the three cycles, we held 

additional interviews with officials from OPM; representatives from the 

Chicago, Cleveland, and Philadelphia FEBs; and representatives from the 

National Treasury Employees Union (NTEU) and the American Federation 

of Government Employees (AFGE). We spoke with representatives of the 

FEBs because the FEBs’ role as coordinative bodies in regions across the 

nation gives them a unique view of federal emergency preparedness efforts 

outside of the Washington, D.C., area. We spoke with representatives from 

NTEU and AFGE because unions can play a key role in addressing human 

capital considerations.

To describe the COOP guidance provided by FEMA and emergency 

preparedness guidance and activities of OPM to address human capital 

considerations relevant to COOP, we interviewed officials from both 

agencies. In addition, we reviewed and analyzed relevant documents. For 

example, we reviewed Federal Preparedness Circular 65, the primary 

guidance for federal executive branch COOP, to identify the human capital 

considerations that are included in federal COOP guidance. We also 

reviewed OPM publications, including four emergency preparedness 

guides and a series of memorandums that list available agency flexibilities 

in times of emergencies. 

To describe the role FEBs play, relevant to COOP, in coordinating efforts 

outside of the Washington, D.C., area, we held interviews with officials 

from OPM with responsibility for FEBs nationwide and representatives 

from the three FEBs discussed above. 

We conducted our work from February 2003 through December 2003 in 

accordance with generally accepted government auditing standards.
Page 33 GAO-04-384 Human Capital

Appendix II

Emergency Human Capital Flexibilities Listed 

in OPM Emergency Memorandums ApendxiI

OPM has issued a series of memorandums outlining the existing human 

resources management flexibilities that executive departments and 

agencies might employ in emergency situations with and without OPM 

approval.1

 Other human capital flexibilities and programs, such as those 

detailed in OPM’s handbook, Human Resources Flexibilities and 

Authorities in the Federal Government,

2

 that are available to agencies in 

nonemergency situations may also provide additional assistance in 

responding to and recovering from COOP emergencies. For additional 

information on these flexibilities, OPM has advised that agency chief 

human capital officers, human resources (HR) directors, or both should 

contact their assigned OPM human capital officer. Employees are advised 

to contact their agency HR offices for assistance. 

A compilation of the emergency flexibilities outlined by OPM in its 

emergency guidance memorandums appears below. 

Leave

Excused Absence Agencies have the discretion, without OPM approval, to grant excused 

absence to employees who are prevented from reporting to work because 

of an emergency. The authority to grant excused absence also applies to 

employees who are needed for emergency law enforcement, relief, or 

recovery efforts authorized by federal, state, or local officials having 

appropriate jurisdiction and whose participation in such activities has been 

approved by the employing agency. Military leave under 5 U.S.C. § 6323(b) 

is appropriate for federal employee members of the National Guard or 

Reserves who are called up to assist in an emergency.3

1

 See U.S. Office of Personnel Management, “Memorandum for Heads of Departments and 

Agencies: Wildfires in California,” October 27, 2003; “Memorandum for Heads of 

Departments and Agencies: Hurricane Isabel,” September 19, 2003; and “Memorandum for 

Heads of Executive Departments and Agencies: Level Orange Emergency Human Resources 

Management (HRM) Authorities,” March 17, 2003.

2

 U.S. Office of Personnel Management, Human Resources Flexibilities and Authorities in 

the Federal Government (Washington, D.C.: July 25, 2001).

3

 According to 5 U.S.C. § 6323(b), military leave is not to exceed 22 workdays.
Appendix II

Emergency Human Capital Flexibilities 

Listed in OPM Emergency Memorandums

Page 34 GAO-04-384 Human Capital

Emergency Leave Transfer 

Program

Subject to approval by the President, OPM may establish an emergency 

leave transfer program, which is separate from the federal leave-sharing 

program, to assist employees affected by an emergency or major disaster. 

Under 5 U.S.C. § 6391, the emergency leave transfer program would permit 

employees in an executive agency to donate unused annual leave for 

transfer to employees of the same or other agencies who have been 

adversely affected by an emergency and who need additional time off work 

without having to use their own paid leave. If agencies believe there is a 

need to establish an emergency leave transfer program to assist employees 

affected by an emergency, they are to contact their OPM human capital 

officer.

Pay

Premium Pay for Employees 

Performing Emergency 

Overtime Work

In certain emergency or mission-critical situations, agencies have the 

discretion, without OPM approval, to apply an annual premium pay cap 

instead of a biweekly premium pay cap, subject to the conditions set forth 

in 5 U.S.C. § 5547(b) and 5 C.F.R. § 550.106. In this regard, the agency head, 

his or her designee, or OPM may determine that an emergency exists. 

Agencies have the discretion, without OPM approval, to apply an annual 

cap to certain types of premium pay for any pay period for (1) employees 

performing work in connection with an emergency, including work 

performed in the aftermath of such an emergency, or (2) employees 

performing work critical to the mission of the agency. Such employees 

may receive premium pay under these conditions only to the extent that the 

aggregate of basic pay and premium pay for the calendar year does not 

exceed the greater of the annual rate for (1) General Schedule (GS)–15 step 

10 (including any applicable special salary rate or locality rate of pay, or 

(2) level V of the Executive Schedule.

Furlough In some emergency situations, agencies have the discretion, without OPM 

approval, to furlough employees, that is, to place them in a temporary 

status without duties and pay for nondisciplinary reasons. Under 5 

C.F.R. § 752.404(d)(2), agencies are relieved of the requirement to provide 

employees advanced notice and an opportunity to respond when the 

furlough is based on “unforeseeable circumstances,” such as a sudden 
Appendix II

Emergency Human Capital Flexibilities 

Listed in OPM Emergency Memorandums

Page 35 GAO-04-384 Human Capital

breakdown in equipment, an act of nature, or a sudden emergency 

requiring the agency to immediately curtail activities.

Benefits

Workers’ Compensation 

Benefits

Workers’ compensation benefits are available when federal employees are 

injured or killed while on duty. The Department of Labor may establish 

special procedures to provide direct assistance to affected employees and 

their families.

Expedited Processing of 

Retirement and Life 

Insurance Benefits

To assist agencies in responding to employee needs during and after an 

emergency situation, OPM may establish special expedited arrangements 

for processing disability retirement applications; survivor benefits; and 

payments under the Federal Employees Group Life Insurance Program, 

currently administered by the Metropolitan Life Insurance Company. 

Death Gratuity Under Section 651 of Pub. L. No. 104-208 (Omnibus Consolidated 

Appropriations Act, 1997), 5 U.S.C. § 8133 note, agencies have the authority, 

without OPM approval, to pay up to $10,000 to the personal representative 

of a civilian employee who dies in the line of duty.

Telework Agencies have the discretion, without OPM approval, to approve 

telecommuting arrangements and alternative work sites to accommodate 

emergency situations. According to OPM, one of the major benefits of the 

telework program is the ability of telework employees to continue working 

at their alternative work sites during a disruption to operations. In 

recognition of the growing importance of teleworkers in the continuity of 

agency operations, OPM states that agencies may wish to modify their 

current policies concerning teleworkers and emergency closures. 

Agencies may also wish to require that some or all of their teleworkers 

continue to work at their alternative work sites on their telework day 

during emergency situations when the agency is closed. Although agencies

would not have to designate a teleworker as an emergency employee, OPM 

states that any requirement that a telework employee continue to work if 
Appendix II

Emergency Human Capital Flexibilities 

Listed in OPM Emergency Memorandums

Page 36 GAO-04-384 Human Capital

the agency closes on his or her telework day should be included in the 

employee's formal or informal telework agreement.

Emergency Hiring 

Flexibilities

Emergency Critical Hiring Under 5 C.F.R. § 213.3102(i)(2), agencies have the discretion, without OPM 

approval, to fill positions for which an emergency or critical hiring need 

exists; however, initial excepted appointments under this authority may not 

exceed 30 days and may be extended only for an additional 30 days. Such 

an extension may be made only if the appointee’s continued employment 

would be essential to the agency’s operations.

Under 5 C.F.R. § 213.3102(i)(3), OPM may also grant agencies the authority 

to temporarily appoint individuals to the excepted service in positions for 

which OPM has determined that examination is impracticable (e.g., 

because of the time involved). For example, in the aftermath of the 

September 11, 2001, attacks, OPM granted agencies authority to fill 

positions affected by or that needed to deal with the attacks for up to 1 

year, and later extended that authority.

When OPM grants agencies the authority to appoint individuals under 5 

C.F.R. § 213.3102, agencies, not OPM, are responsible for establishing the 

qualifications that an individual must have to fill the position. In addition, 

in accordance with 5 C.F.R. pt. 330, agencies are not required to comply 

with the regulations regarding the Career Transition Assistance Plan 

(CTAP), Reemployment Priority List (RPL), and Interagency CTAP (ICTAP) 

because these regulations do not apply to excepted appointments.

Agencies have the discretion, without OPM approval, to use the authority 

granted by OPM under 5 C.F.R. § 213.3102 to fill senior-level positions, as 

well as positions at lower levels. Under appropriate circumstances, OPM 

may also authorize agencies to use a senior-level position allocation to 

appoint an individual under this section (5 C.F.R. § 319.104).

Direct-Hire Authority Agencies have the authority to appoint candidates directly when OPM 

determines there is a critical hiring need, or a shortage of candidates, for 
Appendix II

Emergency Human Capital Flexibilities 

Listed in OPM Emergency Memorandums

Page 37 GAO-04-384 Human Capital

particular occupations, grades (or equivalent), geographic locations, or 

some combination of the three. This authority can be governmentwide or 

limited to one or more specific agencies depending on the circumstances.

OPM has granted governmentwide direct-hire authority for GS-0602 

Medical Officers, GS-0610 and GS-0620 Nurses, GS-0647 Diagnostic 

Radiologic Technicians, and GS-0660 Pharmacists, at all grade levels and all 

locations, and for GS-2210 Information Technology Specialists 

(Information Security) positions at GS-9 and above, at all locations, in 

support of governmentwide efforts to carry out the requirements of the 

Government Information Security Reform Act and the Federal Information 

Security Management Act. OPM also approved a direct-hire authority that 

permits agencies to immediately appoint individuals with fluency in Arabic 

or other Middle Eastern languages to positions in support of the 

reconstruction efforts in Iraq. 

Agencies have the discretion, without OPM approval, to give individuals in 

the categories, occupations and specialties, and grades listed above 

competitive service career, career-conditional, term, temporary, emergency 

indefinite, or overseas limited appointments, as appropriate. In all cases, 

agencies must adhere to public notice requirements in 5 U.S.C. §§ 3327 and 

3330 and ICTAP requirements.

If agencies believe they have one or more occupations for which an agencyspecific direct-hire authority may be appropriate in support of emergency 

relief and recovery efforts, they are to contact their OPM human capital 

officer.

Senior Executive Service 

Limited Emergency 

Appointments

To meet a bona fide, unanticipated, urgent need, agencies have the 

authority under 5 C.F.R. § 317.601 to make Senior Executive Service limited 

emergency appointments of career employees, without OPM approval. 

OPM approval is required to appoint individuals who are not current career 

employees and OPM cannot delegate this authority; however, OPM will 

process such requests on a priority basis and will also consider temporary 

position allocations for agencies that identify the need as essential to deal 

with the emergency.

Reemploying Retirees Agencies have the discretion, without OPM approval, to employ retirees to 

deal with an emergency, to replace employees called to active duty military 

service, or both. Agencies may immediately offer reemployment to retirees 
Appendix II

Emergency Human Capital Flexibilities 

Listed in OPM Emergency Memorandums

Page 38 GAO-04-384 Human Capital

under any applicable appointing authority. However, generally, dual 

compensation restrictions (e.g., 5 U.S.C. §§ 8344 and 8468) require agencies 

to reduce the pay of a federal civil service retiree by the amount of his or 

her annuity. For details, see the CSRS and FERS Handbook for Personnel 

and Payroll Offices, Chapter 100 – Reemployed Annuitants.

OPM may waive these dual compensation restrictions and, upon request, 

may also delegate such authority to an agency head or designee to deal 

with emergency staffing requirements. See 5 C.F.R. pt. 553 for details. Dual 

compensation waivers cannot be approved retroactively. However, 

according to OPM guidance, annuitants who agree to work under salary 

offset pending a dual compensation waiver may be recognized for their 

special service by the agency through an individual cash award.

Reemploying Voluntary 

Separation Incentive 

Payment Recipients

Ordinarily, employees who resign or retire upon acceptance of a voluntary 

separation incentive payment (VSIP) (or buyout) can be reemployed only if 

they agree to repay the amount of that payment. However, upon agency’s 

request, OPM may waive the repayment requirement if the individual’s 

reemployment is necessary to deal with the emergency situation. (See 5 

C.F.R. § 576.203(a)(1).) Persons being considered for VSIP repayment 

waivers must be the only qualified applicants available for the positions 

and possess expertise and special qualifications to replace persons lost or 

otherwise unavailable. Waivers may be limited by the agency’s specific 

statutory VSIP authority.

Other Emergency Hiring 

Flexibilities

Under 5 C.F.R. pt. 300, subpart E, agencies have the discretion, without 

OPM approval, to contract with private sector temporary employment 

firms for services to meet their emergency staffing needs. These contracts 

may be for 120 days and may be extended for an additional 120 days, 

subject to displaced employee procedures.

Agencies have the discretion, without OPM approval, to make competitive 

service appointments of 120 days or less without regard to CTAP, ICTAP, or 

RPL eligibles. These programs do not apply to such appointments. See 5 

C.F.R., pt. 330, Subparts F and G for CTAP/ICTAP conditions and 5 C.F.R. § 

330.207(d) for RPL conditions.

Agencies have the discretion, without OPM approval, to appoint current 

and former employees from RPL to temporary, term, or permanent 

competitive service appointments. Conversely, agencies may make 
Appendix II

Emergency Human Capital Flexibilities 

Listed in OPM Emergency Memorandums

Page 39 GAO-04-384 Human Capital

exceptions to the RPL provisions to appoint others under 5 C.F.R. 

330.207(d).
Page 40 GAO-04-384 Human Capital

Appendix III

Comments from the Federal Emergency 

Management Agency ApendxiI
Page 41 GAO-04-384 Human Capital

Appendix IV

Comments from the Office of Personnel 

Management ApendxiIV
Appendix IV

Comments from the Office of Personnel 

Management

Page 42 GAO-04-384 Human Capital
Appendix IV

Comments from the Office of Personnel 

Management

Page 43 GAO-04-384 Human Capital
Appendix IV

Comments from the Office of Personnel 

Management

Page 44 GAO-04-384 Human Capital
Appendix IV

Comments from the Office of Personnel 

Management

Page 45 GAO-04-384 Human Capital
Appendix IV

Comments from the Office of Personnel 

Management

Page 46 GAO-04-384 Human Capital
Appendix IV

Comments from the Office of Personnel 

Management

Page 47 GAO-04-384 Human Capital
Appendix IV

Comments from the Office of Personnel 

Management

Page 48 GAO-04-384 Human Capital
Appendix IV

Comments from the Office of Personnel 

Management

Page 49 GAO-04-384 Human Capital
Appendix IV

Comments from the Office of Personnel 

Management

Page 50 GAO-04-384 Human Capital
Appendix IV

Comments from the Office of Personnel 

Management

Page 51 GAO-04-384 Human Capital
Appendix IV

Comments from the Office of Personnel 

Management

Page 52 GAO-04-384 Human Capital
Appendix IV

Comments from the Office of Personnel 

Management

(450177) Page 53 GAO-04-384 Human Capital
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