Continuity of Operations: Agencies Could Improve Planning for Telework during Disruptions
Published: 2006-05-11T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: To ensure that essential government services are available in emergencies, federal agencies are required to develop continuity of operations (COOP) plans. The Federal Emergency Management Agency (FEMA), within the Department of Homeland Security (DHS), is responsible for providing guidance to agencies on developing such plans. Its guidance states that in their continuity planning, agencies should consider the use of telework--that is, work performed at an employee's home or at a work location other than a traditional office. The Office of Personnel Management (OPM) recently reported that 43 agencies have identified staff eligible to telework, and that more than 140,000 federal employees used telework in 2004. OPM also reported that many government operations can be carried out in emergencies using telework. For example, telework appears to be an effective strategy for responding to a pandemic--a global outbreak of disease that spreads easily from person to person and causes serious illness and death worldwide. In previous work, GAO identified steps that agencies should take to effectively use telework during an emergency. GAO was asked to testify on how agencies are addressing the use of telework in their continuity planning, which is among the topics discussed in a report being released today (GAO-06-713).
section_title: What GAO Found
paragraphs: Although agencies are not required to use telework in continuity planning, 9 of the 23 agencies surveyed reported plans for essential team members to telework during a COOP event, compared to 3 in GAO's previous survey. However, few documented that they made the necessary preparations to effectively use telework during such an event. For example, only 1 agency documented that it had communicated this expectation to its emergency team members. One reason for the low levels of preparations reported is that FEMA has not provided specific guidance on preparations needed to use telework during emergencies. Recently, FEMA disseminated guidance to agencies on incorporating pandemic influenza considerations into COOP planning. Although this guidance suggests the use of telework during such an event, it does not address the steps agencies should take when preparing to use telework during an emergency. Without specific guidance, agencies are unlikely to adequately prepare their telework capabilities for use during a COOP event. In addition, inadequate preparations could limit the ability of nonessential employees to contribute to agency missions during extended emergencies, including pandemic influenza. In its report released today, GAO recommends, among other things, that FEMA establish a time line for developing, in consultation with the OPM, guidance on preparations needed for using telework during a COOP event. In commenting on a draft of the report, DHS partially agreed with GAO's recommendation and stated that FEMA will coordinate with OPM in developing a time line for further telework guidance. DHS also stated that both FEMA and OPM have provided telework guidance. However, as GAO's report stated, present guidance does not address the preparations federal agencies should make for using telework during emergencies. On May 3 the White House announced the release of an Implementation Plan in support of the National Strategy for Pandemic Influenza. This plan calls on OPM to work with DHS and other agencies to revise existing telework guidance and issue new guidance on human capital planning and COOP. The plan establishes an expectation that these actions will be completed within 3 months. If the forthcoming guidance does not require agencies to make necessary preparations for telework, agencies are unlikely to take all the steps necessary to ensure that employees will be able to effectively use telework to perform essential functions in extended emergencies, such as a pandemic influenza.

section_title: Letter
paragraphs: I appreciate the opportunity to participate in the Committee’s  hearing on pandemic influenza and continuity of operations (COOP)  planning. As you know, essential government services can be  interrupted by a range of events, including terrorist attacks, severe  weather, building-level emergencies, and public health emergencies,  such as pandemic influenza. The federal government requires  agencies to develop plans for ensuring the continuity of essential  services during such emergencies. To assist agencies, the Federal  Emergency Management Agency (FEMA), within the Department of  Homeland Security (DHS), which is responsible for managing  federal response and recovery efforts following any national  incident, has issued guidance that defines the elements of a viable  COOP capability.
A potentially useful option for continuity planning is telework (in  which work is performed at an employee’s home or at a work  location other than a traditional office); this alternative has gained  widespread attention over the past decade in both the public and  private sectors as a human capital flexibility that offers a variety of  potential benefits to employers, employees, and society. In a  December 2005 report to Congress, the Office of Personnel  Management (OPM) indicated that 43 of the 82 federal agencies it  surveyed had employees eligible to telework during 2004, and more  than 140,000 federal employees used telework that year.
OPM also reported that there is a symbiotic relationship between  COOP and telework because many government functions that must  be carried out in emergencies can be accomplished using telework.  Similarly, we reported in April 2004 that telework is an important  and viable option for federal agencies in continuity planning and  implementation efforts, especially as the duration of an emergency  event is extended. This option appears particularly appropriate in  the case of pandemic influenza, which occurs when an influenza  virus causes an outbreak of disease that spreads easily from person  to person and results in serious illness worldwide. Experts believe  that the effects of a pandemic could come in waves that last for  weeks or even months, in which time absentee rates could reach 40  percent during peak periods due to illness, the need to care for  family members, and fear of infection. Recent executive branch  guidance states that social distancing measures, such as telework,  may be appropriate public health interventions for infection control  and containment during a pandemic outbreak.
GAO recognizes the importance of telework and continuity planning  and is striving to lead by example on these issues. For example,  during certain emergencies, our current telework policy allows me  to approve telework for all employees in an affected area to  promote continuity of operations. We are also completing a  supplement to our COOP plan that addresses preparations specific  to a pandemic, and are coordinating our continuity planning efforts  with those of other legislative branch agencies.
As you requested, I will discuss how agencies are addressing the use  of telework in their continuity planning, based on work described in  a report that we are issuing today. In earlier work, we identified  steps agencies that should take to effectively use telework during an  emergency, and we surveyed agency officials responsible for  continuity planning at 23 major agencies. For this report, we  repeated this survey to obtain updated information on the extent to  which key telework practices were used in making continuity  preparations. We reviewed documentation submitted by agency  officials to support their survey responses and compared these  responses to those from our earlier work; we briefed your staff on  the results of our work on April 13, 2006. This work was conducted  in accordance with generally accepted government auditing  standards.
subsections: section_title: Background
paragraphs: Federal operations and facilities have been disrupted by a range of  events, including the terrorist attacks on September 11, 2001; the  Oklahoma City bombing; localized shutdowns due to severe weather  conditions, such as hurricanes Katrina, Rita, and Wilma in 2005; and  building-level events, such as asbestos contamination at the  Department of the Interior’s headquarters. In addition, federal  operations could be significantly disrupted by people-only events,  such as an outbreak of severe acute respiratory illness (SARS). Such  disruptions, particularly if prolonged, can lead to interruptions in  essential government services. Prudent management, therefore,  requires that federal agencies develop plans for dealing with  emergency situations, including maintaining services, ensuring  proper authority for government actions, and protecting vital assets.
Until relatively recently, continuity planning was generally the  responsibility of individual agencies. In October 1998, Presidential  Decision Directive (PDD) 67 identified FEMA—which is responsible  for leading the effort to prepare the nation for all hazards and  managing federal response and recovery efforts following any  national incident—as the lead agent for federal COOP planning  across the federal executive branch. FEMA’s responsibilities include  ●  formulating guidance for agencies to use in developing viable plans;  ●  coordinating interagency exercises and facilitating interagency  coordination, as appropriate; and  ●  overseeing and assessing the status of COOP capabilities across the  executive branch.
In July 1999, FEMA issued the first version of Federal Preparedness  Circular (FPC) 65, its guidance to the federal executive branch on  developing viable and executable contingency plans that facilitate  the performance of essential functions during any emergency. FPC  65 applies to all federal executive branch departments and agencies  at all levels, including locations outside Washington, D.C. FEMA  released an updated version of FPC 65 in June 2004, providing  additional guidance to agencies on each of the topics covered in the  original guidance.
In partial response to a recommendation we made in April 2004, the  2004 version of FPC 65 also included new guidance on human  capital considerations for COOP events. For example, the guidance  instructed agencies to consider telework—also referred to as  telecommuting or flexiplace—as an option in their continuity  planning.
Telework has gained widespread attention over the past decade in  both the public and private sectors as a human capital flexibility that  offers a variety of potential benefits to employers, employees, and  society. In a 2003 report to Congress on the status of telework in the  federal government, the Director of OPM described telework as “an  invaluable management tool which not only allows employees  greater flexibility to balance their personal and professional duties,  but also allows both management and employees to cope with the  uncertainties of potential disruptions in the workplace, including  terrorist threats.” A 2005 OPM report on telework notes the  importance of telework in responding flexibly to emergency  situations, as demonstrated in the wake of the devastation caused  by Hurricane Katrina, when telework served as a tool to help  alleviate the issues caused by steeply rising fuel prices nationwide.
In 2004, we surveyed major federal agencies at your request to  determine how they planned to use telework during COOP events.
We reported that, although agencies were not required to use  telework in their COOP plans, 1 of the 21 agency continuity plans in  place on May 1, 2004, documented plans to address some essential  functions through telework. In addition, 10 agencies reported that  they intended to use telework following a COOP event, even though  those intentions were not documented in their continuity plans.
The focus on using telework in continuity planning has been  heightened in response to the threat of pandemic influenza. In  November 2005, the White House issued a national strategy to  address this threat, which states that social distancing measures,  such as telework, may be appropriate public health interventions for  infection control and containment during a pandemic outbreak. The  strategy requires federal departments and agencies to develop and  exercise preparedness and response plans that take into account the  potential impact of a pandemic on the federal workforce. It also  tasks DHS—the parent department of FEMA—with developing  plans to implement the strategy in regard to domestic incident  management and federal coordination. In May 2006, the White  House issued an implementation plan in support of the pandemic  strategy. This plan outlines the responsibilities of various agencies  and establishes time lines for future actions.
section_title: Few Agencies Demonstrated That They Had Adequately Prepared to Use Telework in a COOP Event
paragraphs: Although more agencies reported plans for essential team members  to telework during a COOP event than in our 2004 survey, few  documented that they had made the necessary preparations to  effectively use telework during an emergency. While FPC 65 does  not require agencies to use telework during a COOP event, it does  state that they should consider the use of telework in their  continuity plans and procedures. All of the 23 agencies that we  surveyed indicated that they considered telework as an option  during COOP planning, and 15 addressed telework in their COOP  plans (see table 1). For agencies that did not plan to use telework  during a COOP event, reasons cited by agency officials for this  decision included (1) the need to access classified information— which is not permitted outside of secured areas—in order to  perform agency essential functions and (2) a lack of funding for the  necessary equipment acquisition and network modifications.
The agencies that did plan to use telework in emergencies did not  consistently demonstrate that they were prepared to do so. We  previously identified steps agencies should take to effectively use  telework during an emergency. These include preparations to  ensure that staff has adequate technological capacity, assistance,  and training. Table 1 provides examples of gaps in agencies’  preparations, such as the following:  ●  Nine of the 23 agencies reported that some of their COOP essential  team members are expected to telework during a COOP event.  However, only one agency documented that it had notified its team  members that they were expected to telework during such an event.  ●  None of the 23 agencies demonstrated that it could ensure adequate  technological capacity to allow designated personnel to telework  during a COOP event.
No guidance addresses the steps that agencies should take to ensure  that they are fully prepared to use telework during a COOP event.  When we reported the results of our 2004 survey, we recommended  that the Secretary of Homeland Security direct the Under Secretary  for Emergency Preparedness and Response to develop, in  consultation with OPM, guidance on the steps that agencies should  take to adequately prepare for the use of telework during a COOP  event. However, to date, no such guidance has been created.
In March 2006, FEMA disseminated guidance to agencies regarding  the incorporation of pandemic influenza considerations into COOP  planning. The guidance states that the dynamic nature of a  pandemic influenza requires that the federal government take a  nontraditional approach to continuity planning and readiness. It  suggests the use of telework during such an event. According to the  guidance, agencies should consider which essential functions and  services can be conducted from a remote location (e.g., home) using  telework. However, the guidance does not address the steps  agencies should take when preparing to use telework during an  emergency. For example, although the guidance states that agencies  should consider testing, training, and exercising of social distancing  techniques, including telework, it does not address other necessary  preparations, such as informing designated staff of the expectation  to telework or providing them with adequate technical resources  and support.
Earlier this month, after we briefed your staff, the White House  released an Implementation Plan in support of the National Strategy  for Pandemic Influenza. This plan calls on OPM to work with DHS  and other agencies to revise existing telework guidance and issue  new guidance on human capital planning and COOP. The plan  establishes an expectation that these actions will be completed  within 3 months.
If the forthcoming guidance from DHS and other responsible  agencies does not require agencies to make the necessary  preparations for telework, agencies are unlikely to take all the steps  necessary to ensure that employees will be able to effectively use  telework to perform essential functions during any COOP event. In  addition, inadequate preparations could limit the ability of  nonessential employees to contribute to agency missions during  extended emergencies, including a pandemic influenza scenario.
In summary, Mr. Chairman, although more agencies reported plans  for essential team members to telework during a COOP event than  in our previous survey, few documented that they had made the  necessary preparations to effectively use telework during an  emergency. In addition, agencies lack guidance on what these  necessary preparations are. Although FEMA’s recent telework  guidance does not address the steps agencies should take to prepare  to use telework during an emergency event, new guidance on  telework and COOP is expected to be released later this year. If the  new guidance does not specify the steps agencies need to take to  adequately prepare their telework capabilities for use during an  emergency situation, it will be difficult for agencies to make  adequate preparations to ensure that their teleworking staff will be  able to perform essential functions during a COOP event.
In our report, we made recommendations aimed at helping to ensure  that agencies are adequately prepared to perform essential functions  following an emergency. Among other things, we recommended that  the Secretary of Homeland Security direct the FEMA Director to  establish a time line for developing, in consultation with OPM,  guidance on the steps that agencies should take to adequately  prepare for the use of telework during a COOP event.
In commenting on a draft of the report, the Director of DHS’s  Liaison Office partially agreed with this recommendation and stated  that FEMA will coordinate with OPM in the development of a time  line for further telework guidance. In addition, he stated that both  FEMA and OPM have provided guidance on the use of telework.  However, as stated in our report, present guidance does not address  the preparations agencies should make for using telework during  emergencies.
With the release of the White House’s Implementation Plan  regarding pandemic influenza, a time line has now been established  for the issuance of revised guidance on telework; however, unless  the forthcoming guidance addresses the necessary preparations,  agencies may not be able to use telework effectively to ensure the  continuity of their essential functions.
Mr. Chairman, this concludes my statement. I would be pleased to  respond to any questions that you or other members of the  Committee may have at this time.
section_title: Contacts and Acknowledgements
paragraphs: For information about this testimony, please contact Linda D.  Koontz at (202) 512-6240 or at koontzl@gao.gov. Key contributions  to this testimony were made by James R. Sweetman, Jr., Assistant  Director; Barbara Collier; Sairah Ijaz; Nick Marinos; and Kim  Zelonis.
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