Emergency Preparedness: Agencies Need Coordinated Guidance on Incorporating Telework into Emergency and Continuity Planning
Published: 2011-07-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: When historic snowstorms forced lengthy closings of federal offices in the National Capital Region in 2010, thousands of employees continued to work from their homes, making clear the potential of telework in mitigating the effects of emergencies. GAO was asked to (1) describe the guidance lead agencies have issued pertaining to the use of telework during emergencies; (2) describe Office of Personnel Management (OPM) and other assessments related to agencies' incorporation of telework into emergency or continuity planning, and the extent to which the lead agencies have provided definitions and practices to support agency planning; and (3) assess the extent to which OPM and the Federal Emergency Management Agency (FEMA) coordinated with other agencies on recent guidance documents. To address these objectives, GAO reviewed relevant statutes, regulations, guidance documents, and OPM's telework survey methodology, and interviewed key officials of agencies providing telework and telework-related emergency guidance.
section_title: What GAO Found
paragraphs: OPM, the General Services Administration (GSA), FEMA, and the Federal Protective Service (FPS) offer a host of telework and telework-related emergency guidance. These lead agencies provide advice to other federal agencies through regulations, directives, guides, bulletins, and other documents. Several of these guidance documents have expanded significantly in recent years, broadening the scope of the topics that they address and describing broader responsibilities for the lead agencies. The Telework Enhancement Act of 2010 requires agencies to incorporate telework policies into their continuity of operations plans, but recent OPM reviews and other agency reports identify potential problems agencies may face in achieving this incorporation in various operational areas. GAO's review of the OPM, GSA, FEMA, and FPS governmentwide guidance on telework or telework-related emergency planning found that none of the documents provide a definition of what constitutes incorporating telework into continuity and emergency planning or a cohesive set of practices that agencies could use to achieve this type of incorporation. Additionally, this lack of a definition or description calls into question the reliability of the results of a survey OPM annually conducts to assess agencies' progress. In reviewing several lead-agency guidance documents, GAO found a number of practices, in areas such as information technology (IT) infrastructure and testing, that could help agencies incorporate telework in aspects of their continuity or emergency planning. However, because the practices are scattered among various documents principally concerned with other matters, it would be difficult for an agency to use these practices to help achieve telework incorporation and assess its progress. Both OPM and FEMA coordinated the development of their recent guidance. OPM updated its Washington, D.C., area dismissal and closure procedures to introduce "unscheduled telework," a new option for federal employees to telework when emergencies disrupt commuting. While developing these procedures, OPM officials reported coordinating with GSA, agency human-capital officials, FEMA, unions, and the Metropolitan Washington Council of Governments, among others. However, OPM and GSA did not work together to reach out to agency chief information officers regarding potential agency capacity limitations. Consequently, officials did not offer any governmentwide guidance on ways to address IT infrastructure limitations or provide direct assistance to agencies regarding the adequacy of their IT infrastructure. In February 2011, FEMA provided agencies with more-detailed guidance for developing continuity plans. According to FEMA officials, in 2010 they shared a draft of the guidance with the interagency community, including both continuity coordinators and continuity planners, and GSA.
section_title: What GAO Recommends
paragraphs: GAO recommends that OPM consult with other lead agencies to develop a definition and cohesive set of practices for incorporating telework into emergency and continuity planning; improve its related data collection; and establish an interagency coordination process for guidance. OPM concurred with GAO's recommendations.

section_title: Letter
paragraphs: Historic snowstorms forced the Office of Personnel Management (OPM)  to close federal executive agencies in the Washington, D.C., area for 4  consecutive days in February 2010. The closure resulted in a particularly  lengthy interruption in the government’s routine operations and hours of  employee productivity were lost. Despite being unable to commute to  their offices, thousands of federal employees continued to work, to some  degree, by teleworking from their homes, according to OPM estimates.  Drawing on this experience, the Director of OPM testified in March 2010  that telework was “the one effective and important tool that could make  the difference between shutting down federal government services and  continuing to operate with minimal interruption in emergency situations.”
While achieving widespread use of telework during emergencies could  enhance the federal government’s operational resilience and reduce the  costs of lost productivity, making use of telework during emergencies  governmentwide is not a simple undertaking. As we have previously  reported, implementing telework during normal conditions affects several  areas of consideration, such as human-capital policies and procedures,  information technology infrastructure (equipment, software, and security),  telecommunication infrastructure, and facility space utilization. In  addition, implementing the use of telework during an emergency situation  requires its incorporation into the unique requirements of emergency  planning and operations.
Three agencies have drawn on their respective areas of responsibility and  expertise to offer guidance to executive-branch agencies on how to  incorporate telework into routine and emergency operations. OPM  provides governmentwide human-capital policies, and within that context  has provided guidance to agencies on using telework during routine and  emergency operations. OPM has also provided technical assistance to  agencies on implementing their telework programs, such as through  reviewing their telework policies. The General Services Administration  (GSA) provides governmentwide guidance on the use of federal facilities  and the purchase of equipment, and has issued guidance regarding  facilities, technology, and workplaces to help promote telework. The  Federal Emergency Management Agency (FEMA) provides  governmentwide guidance on emergency preparedness, and within that  context, has offered guidance relating to the potential use of telework in  agency continuity of operations (COOP) plans and operations. In  addition to these three agencies, the Federal Protective Service (FPS)  provides governmentwide guidance that could influence the potential use  of telework during emergencies. FPS provides security at GSA-owned or  leased facilities and has issued guidance to agencies on developing plans  to keep building occupants safe during emergencies.
In response to your request to evaluate the role these lead agencies are  playing in providing guidance that promotes the use of telework during  emergencies, this report will (1) describe the guidance that OPM, GSA,  FEMA, and FPS have issued pertaining to the use of telework during  emergencies; (2) describe OPM and other assessments related to  agencies’ incorporation of telework into emergency or continuity planning,  and the extent to which the lead agencies have provided definitions and  practices to support agency planning; and (3) assess the extent to which  OPM and FEMA coordinated with other agencies on the development of  their recently released guidance documents pertaining to the use of  telework during emergencies.
To address these three objectives, we reviewed governmentwide  telework and emergency-related statutes. We also reviewed regulations  and guidance issued by OPM, GSA, FEMA, and FPS and conducted  interviews with key officials from each of these agencies regarding each  objective. We conducted additional data collection and analyses to  answer selected objectives. To assess the extent to which OPM’s recent  reviews of the agencies’ telework policies and programs addressed the  incorporation of telework into continuity plans, we reviewed OPM’s annual  telework survey and its 2010 evaluation of agency telework policies. We  compared the methodologies OPM used to generally accepted survey  and evaluation methodologies. To identify practices suggested by OPM,  GSA, FEMA, and FPS for incorporating telework into continuity or  emergency planning, we reviewed these agencies’ related  governmentwide regulations and guidance. We compared these practices  to practices that GAO previously suggested for the same purpose and  identified examples of practices suggested by OPM, GSA, FEMA, and  FPS that were similar to GAO-suggested practices.
We conducted this performance audit from February 2010 through July  2011 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: Legislation related to telework began to emerge from Congress in the  1990s. For example, beginning in 1992, Congress provided funding to  GSA to establish the first federal telework centers. Three years later,  Congress permanently authorized federal agencies to spend money to  install telephone lines and related equipment and pay monthly charges for  federal workers authorized to work at home, in accordance with OPM  guidelines. Within the legislation that evolved from 1992 through 2009,  the most significant congressional action was the enactment of Section  359 of Pub. L. No. 106-346 in October 2000. This section required each  executive-branch agency to establish a telework policy “under which  eligible employees of the agency may participate in telecommuting to the  maximum extent possible without diminished employee performance.” It  also directed OPM to provide that the law’s requirements were applied to  25 percent of the federal workforce by April 2001 and to an additional 25  percent of the federal workforce in each subsequent year, until 2004  when the law was to be applied to 100 percent of the federal workforce.
From 2005 through 2009, federal workforce participation in routine  telework has remained low. In calendar year 2009, according to OPM’s  latest survey of federal agency telework coordinators, less than 6 percent  of federal employees employed by the 79 agencies that responded to the  survey teleworked at least 1 day per month, while less than 4 percent of  the federal workforce employed by these agencies teleworked at least 1  day per week. The estimated percentage of employees teleworking at  least 1 day per month, relative to the number of the federal employees  employed by the agencies that responded to the survey, has remained  between 5 and 7 percent, since calendar year 2005.
The legislation for telework provided both OPM and GSA with leadership  roles in the implementation of telework in the federal government.  However, in 2003, we reported that the lack of coordination between  OPM and GSA had resulted in executive agencies receiving conflicting  messages on several telework-related topics, including emergency  closings of government offices. These conflicting messages had created  confusion for federal agencies in implementing their individual telework  programs. To provide federal agencies with consistent, inclusive,  unambiguous support and guidance related to telework, we  recommended that OPM and GSA better coordinate their efforts. In  response, OPM and GSA agreed later that year on a Memorandum of  Understanding (MOU). Under this MOU, OPM and GSA agreed to the  respective responsibilities listed in table 1.
The agencies also agreed in the MOU to continue to share draft telework  documents to ensure mutual concurrence.
Recently, Congress passed a framework for implementing a  comprehensive federal telework program. Congress passed the Telework  Enhancement Act of 2010 in November 2010, and the President signed  it into law in December 2010. The law requires each executive agency to  designate a telework managing officer, establish a telework policy, and  submit an annual report to the Chair and Vice Chair of the Chief Human  Capital Officers (CHCO) Council on the agency’s efforts to promote  telework. Under the act, OPM is to play a leading role in helping agencies  implement the new telework provisions. The law requires OPM to provide  policy and policy guidance for telework in several areas, including pay  and leave, agency closure, performance management, official worksite,  recruitment and retention, and accommodations for employees with  disabilities. In developing its telework policy and policy guidance, OPM is  to consult with FEMA, GSA, and the National Archives and Records  Administration (NARA) relative to their designated areas of policy  responsibility, as listed in table 2. NARA provides guidance to agencies  on ensuring the federal government’s essential records are, among other  things, secure and accessible to key federal personnel during  emergencies.
The Telework Enhancement Act also includes several provisions related  to the potential use of telework during emergencies. The law requires  agencies to incorporate telework into their COOP plans. OPM is to report  annually to Congress and provide its assessment of each agency’s  progress toward its goals, such as the effect of telework on emergency  readiness. Finally, the act requires the Director of OPM to research the  utilization of telework that identifies best practices and recommendations  for the federal government and review the outcomes associated with an  increase in telework. Agencies with jurisdiction over such matters as  energy consumption, urban transportation patterns, and planning the  dispersal of work during periods of emergency, shall work cooperatively  with the Director, as necessary, to carry out these research  responsibilities.
section_title: OPM, GSA, FEMA, and FPS Have Provided Agencies with Guidance Related to Using Telework during Emergencies
paragraphs: OPM, GSA, FEMA, and FPS offer a host of guidance on telework or  telework-related emergency planning. Several of these guidance  documents have expanded significantly in recent years, broadening the  scope of the topics that they address and describing broader  responsibilities for the lead agencies.
After Congress required agencies to establish a telework policy in 2000,  OPM provided several telework guidance documents to agencies. OPM’s  major telework guidance is contained in the Guide to Telework in the  Federal Government. According to Federal Continuity Directive 1 (FCD  1), OPM is also responsible for developing and promulgating personnel  guidance to support the operation of federal executive-branch agencies  during emergencies. OPM has also issued regulations providing uniform  instructions to agencies on making payments to employees evacuated  due to, among other reasons, natural disasters and pandemic health  crises. OPM also has the lead role, by mutual agreement with other  agencies in the region, in determining when to close federal offices and  dismiss employees in the Washington, D.C., area. According to OPM,  these procedures, referred to as the Dismissal Guide, ensure a  coordinated response to areawide disruptions, which is important given  the concentration of federal employees in this area. According to an OPM  official, its dismissal and closure procedures are updated annually. The  latest procedures were issued in December 2010. While these  procedures directly apply only to executive agencies in the Washington,  D.C. area, OPM officials explained that agency leaders in other regions of  the United States use OPM’s procedures as a model. In addition, OPM’s  guidance on managing human-capital resources during emergencies and  continuity events was included in FEMA’s directive to executive agencies  on developing and implementing continuity plans. Table 3 lists examples  of OPM guidance relating to the use of telework during various types of  emergencies, as provided in OPM and FEMA documents.
Since 2000, OPM has expanded the scope of its guidance on the use of  telework in the federal government. For example, the telework guidance  OPM issued in 2001 listed several topics agencies should address in their  telework policies. The current version of OPM’s guidance for routine  telework, the 2011 Telework Guide, provides guidance for managers and  employees on an array of topics, such as the telework agreement,  purchasing equipment, communications, and performance  management. This guide also provides advice on using telework during emergencies, continuity events, and pandemics. Compared to the 20 06  Telework Guide, the immediate predecessor to the 2011 Guide, the 2011  Guide added    a summary of the major sections of the Telework Enhancement Act;    the checklist items that OPM used to evaluate telework policies to  help agency officials assess and revise their policies;    guidance on pay, leave, and work-schedule flexibilities, including the  new option of unscheduled telework; and  telework and reasonable accommodations for employees with  disabilities.
During the same period, OPM expanded some of its emergency-related  pay and leave policies. For example, OPM broadened its regulations on  pay during an evacuation to include, in the event of a pandemic health  crisis, permission for agencies to order employees to work from home (or  an alternative location), regardless of whether they have a telework  agreement.
As the lead agency in the management of federal workplaces, GSA  provides governmentwide workplace guidance related to telework,  emergency planning, and continuity planning and operations. Under its  authority to provide guidance, assistance, and oversight on the  establishment and operation of alternative workplace arrangements, such  as telework, GSA has issued guidelines, through Federal Management  Regulation (FMR) Bulletins, on the use of information and  telecommunication technology to support telework and the  implementation and operation of alternative workplace arrangements, as  shown in table 4. GSA, under its responsibility to operate, maintain, and  protect the buildings and grounds it controls, also leads the federal  Occupant Emergency Program, which consists of short-term emergency- response programs for particular facilities. Under this program, each  agency or facility develops and maintains an occupant emergency plan  (OEP) which details the procedures for safeguarding lives and property,  such as evacuation or shelter-in-place, in response to a wide range of  emergencies. At the agency level, the OEP and the continuity plan are  the principal emergency-response plans. According to GSA’s regulations,  GSA approves OEPs for GSA-controlled facilities. Lastly, as described in  FCD 1, GSA is also responsible for assisting FEMA and other federal  agencies in continuity planning and operations. GSA’s ongoing  responsibilities include coordinating the provision of facilities to support  the continuity of the executive-branch agencies and providing data on  alternate facilities.
GSA issued regulations on telework in 2005. These regulations included  references to existing statutory provisions on telecommuting and OPM’s  2001 guidance regarding telework and telework centers. In these  regulations, GSA also described the statutory obligation of agencies to  consider whether the need for space could be met by alternative  workplace arrangements and offered to assist agencies with alternative  workplace arrangements. In 2006, GSA issued an FMR Bulletin that  provided significantly expanded guidance to agencies on using alternative  workplace arrangements. In addition to what had been stated in the  regulation, the bulletin provided detailed information on implementing  alternative work arrangements, such as teleworking and telework centers.  The bulletin addressed such topics as the agency’s provision of  equipment, payment of telework-related expenses, and factors to  consider in using alternative workplace arrangements, often with citations  to related federal regulations or other guidance. GSA issued another FMR  bulletin the following year that provided agencies with recommendations  on the type of information technology (IT), telecommunications, and  peripheral services and equipment, as well as security, needed to  adequately support telework. Like its predecessor, the bulletin also  provided citations to related federal regulations or guidance issued by  other federal agencies.
FEMA and FPS provide governmentwide guidance to federal agencies on  responding to emergencies. FEMA is responsible for leading the nation in  developing a national preparedness system, including serving as the  executive branch’s lead agent on matters concerning the continuity of  national operations. To help federal agencies develop continuity plans  and programs, FEMA offers direction in the FCD 1. According to this  directive, each federal agency has continuity responsibilities and certain  agencies have leadership responsibility for providing governmentwide  guidance or services. For instance, all federal agencies are responsible  for, among other things, developing plans to ensure the continuation of  their essential functions and incorporating continuity requirements into  their daily operations. Among other continuity guidance FEMA has  issued, FEMA has also provided agencies with a COOP plan template to  help them develop their plans. Both FEMA documents, listed in table 5,  include guidance relating to the potential use of telework.
FPS is authorized to protect the buildings, grounds, and property that are  under the control and custody of GSA, as well as the persons on the  property. Towards that end, FPS provided agencies with a guide,  template, and instructions on developing an OEP and guidelines on  responding to various emergency situations. The OEP guide refers to the  potential use of telework during emergencies. A GSA official indicated  that those federal agencies that have delegated authority to own and  operate their own, non-GSA facilities, are required to have their own  version of the OEP. He said that most of these agencies follow FPS’s  guidance in developing their OEPs.
As with some of the OPM and GSA guidance documents, the current  version of FEMA’s guidance on continuity planning, FCD 1, issued in  2008, has expanded since the original version was issued in 2004. For  example, in the 2008 version of FCD 1, the description of GSA’s  responsibilities included such additional duties as coordinating the  provision of executive-branch facilities to support continuity operations.  Similarly, the description of OPM’s additional responsibilities include  providing guidance to agencies on developing personnel policies that  address continuity plans and procedures, as well as alternate work  options, and coordinating continuity efforts before, during, and after an  emergency with the Federal Executive Boards (FEB). In addition, FEMA  broadened the scope of the guidance to include such topics as using risk  management to maximize an agency’s readiness, and aligning acquisition  and budgeting to support the continuity program.
section_title: Agencies May Need Assistance with Incorporating Telework into Emergency or Continuity Operations
subsections: section_title: Recent Reports Point Out Potential Problems with Incorporating Telework into Emergency or Continuity Operations in Various Operational Areas
paragraphs: Several recent reports from OPM, inspectors general, and GAO have  identified several examples of potential problems with incorporating  telework into emergency or routine operations at various agencies. These  examples identified problems in such operational areas as planning, IT,  personnel readiness, and program monitoring. For instance, in 2010 OPM  evaluated the telework policies of 72 executive-branch departments and  agencies to determine whether the policies provided a foundation for  effective telework programs. Each policy was evaluated against two  objectives: (1) whether the policy could be clearly understood and easily  used and (2) whether the policy included elements essential to the  development and support of an effective program, with respect to  program implementation, participant responsibilities, and program  operations. For each evaluation objective, OPM developed a checklist of  items that OPM evaluators used to assess the agencies’ telework  policies. One of the policy checklist questions asked the evaluators to  assess whether the telework policy “references agency emergency  policies (e.g., COOP and pandemic).” According to the report, OPM  evaluators scored 25 of the 73 agency telework policies (35 percent) as  not referencing the agencies’ emergency policies at all.
Other recent reports indicated potential problems in such operational  areas as IT, personnel, and program monitoring:  In 2010, we reported that federal wireless networks were  increasingly vulnerable to attack and that information on the  networks was vulnerable to unauthorized use and disclosure.  In 2009, on the basis of our review of a 2007 Department of  Homeland Security (DHS) report, we concluded that, in the event  of a protracted emergency where 40 percent or more of the  population was absent from school or work, residential users in  most locations in the United States, including federal teleworkers,  would likely experience congestion when attempting to use the  Internet.    While OPM’s Telework Guide indicates that the potential to use  telework during an emergency depends on agencies implementing  routine telework as broadly as possible, OPM’s latest telework  survey, as noted earlier, reported that less than 6 percent of  federal employees employed by the 79 agencies responding to  the 2009 survey teleworked at least 1 day per month.  In 2010, the Inspector General for the U.S. Nuclear Regulatory  Commission (NRC) reported that, as of October 2009, most of  NRC’s offices had not identified all of the individuals needed to  perform essential functions and high-priority tasks while  teleworking during a pandemic.    According to an OPM official, few agencies in the Washington,  D.C., area during the winter of 2011 were able to provide data on  employees’ use of telework during an emergency. In issuing its  Dismissal Procedures in December 2010, OPM requested that  agencies in this area provide data on the use of telework following  any OPM-announced dismissal or closure. However, by March  2011, OPM withdrew its request because, according to an OPM  official, few agencies in the area provided the requested data.
section_title: Current Governmentwide Guidance Does Not Provide a Definition or Set of Practices for Incorporating Telework into Continuity and Emergency Planning
paragraphs: Our review of the OPM, GSA, FEMA, and FPS governmentwide guidance  on telework and telework-related emergency planning found that none of  the documents provided a definition of what constitutes incorporating  telework into continuity and emergency planning or operations, or a  cohesive set of practices that agencies could use to achieve this type of  incorporation. Such practices would address the wide range of factors  that could affect the potential use of telework during emergency  operations such as planning, training, IT infrastructure (equipment,  software, and security), testing, facilities, data collection, and program  monitoring.
section_title: OPM’s Annual Telework Survey Does Not Define “Integration” of Telework into Emergency Plans
paragraphs: OPM, in partnership with GSA, has conducted an annual survey of the  executive-branch agencies since 2001 to ascertain the status of telework  and gauge agency progress in various aspects of their telework  programs, such as participation, policy, eligibility, cost savings, and  technology. Since 2002, OPM has used the survey results to prepare its  annual report to Congress on the status of telework in the federal  government.
Since 2004, the survey has asked agency telework coordinators about  whether telework had been integrated or incorporated into the agency’s  emergency or continuity plans, or both. In the latest survey, the 2009  Telework Survey, the question was worded as follows: “Telework has  been integrated into your agency emergency preparedness / COOP  plans.” The survey asks the coordinators to respond with either Yes or  No. A review of the responses to this question, for calendar years 2004  through 2009, shows that the number of agencies reporting they had  integrated telework into their emergency preparedness or continuity plans  increased from 27 of 78 agencies responding for calendar year 2005 (or  35 percent), to 57 of 79 agencies responding for calendar year 2009 (or  72 percent). OPM reported that the 2009 Telework survey results were an  example of an encouraging use of telework implementation practices.
However, OPM’s survey instrument does not describe what OPM means  by “integrating” telework into emergency or continuity planning and  operations. The survey does not provide a definition or citation to another  document. This is also the case for the 2004 through 2008 surveys. One  reference the telework coordinators might have turned to was OPM’s  2006 Telework Guide, the version in use at the time of the 2007 through  2009 surveys. However, the 2006 guide did not provide a definition or  describe a set of practices required to integrate telework into emergency  or continuity planning and operations, or refer to other federal guidance  containing such a definition or set of practices.
This lack of a definition or description calls into question the reliability of  the survey results for assessing agencies’ progress. As GAO has  previously indicated, survey questions should use unambiguous language  and concrete terms, and specify the conditions that the respondents are  to report on. Without a common understanding of what OPM means by  “integration,” the agency telework coordinators who responded to the  survey would have applied their own understanding of what integration  means. As a result, OPM officials could not describe what agencies  meant when they reported they had integrated telework into agency  emergency preparedness / COOP plans. The question is also vague in  that it does not define what it means by emergency preparedness plans  and seems to treat emergency preparedness plans the same as  continuity plans. As noted earlier, agencies may have several different  types of emergency preparedness plans. The question does not explain  whether the agency is to reply “Yes,” if telework has been “integrated” into  just one emergency preparedness plan, or only if telework has been  “integrated” into all of the emergency preparedness plans, as well as the  COOP plan. Lastly, the response choice of Yes or No does not permit the  coordinator to report interim progress, as would be possible if the  response choices reflected various stages of integration.
section_title: Taken Together, Practices Suggested by Four Agencies Could Help to Define the Set of Practices Needed to Incorporate Telework in Continuity and Emergency Plans
paragraphs: The Telework Enhancement Act of 2010 now requires that federal  agencies incorporate telework into their COOP plans. However, the act  itself does not define the standards for adequate incorporation.  Nevertheless, we found that three lead telework agencies and FPS have  provided some governmentwide guidance that could help agencies in  their efforts to incorporate telework into their continuity and emergency  plans and operations.
In reviewing several current OPM, GSA, FEMA, and FPS guidance  documents, we found a number of practices that could help agencies  incorporate telework into aspects of their continuity or emergency  planning. Appendix II provides a listing of practices that OPM, GSA,  FEMA, and FPS have suggested in various telework or emergency- related guidance documents. These practices address a variety of  operational areas, such as human capital, training, facilities, testing, and  technology infrastructure. However, it would be difficult for an agency to  use these practices to help achieve telework incorporation and assess  their progress. First, the practices are included in guidance documents  that are principally concerned with matters other than incorporating  telework into emergency plans. For example, as noted earlier, OPM’s  Dismissal Guide describes the announcements and procedures that  federal executive agencies in the Washington, D.C., area are to follow  when there are work disruptions in the region, but also reminds the  agencies that they have a responsibility to ensure that their equipment  and technical support have been tested, and their IT infrastructure can  support a large number of teleworkers simultaneously. However, the  guide does not provide a cross-reference to additional OPM or GSA  guidance that would help agencies use IT equipment and services to  support telework, or suggest consultation with the agencies’ chief  information officers (CIO). Moreover, according to their 2003 MOU, OPM  and GSA agreed to work together to help agencies use IT to support  telework and facilitate the CIOs involvement in related planning. Second,  these practices are scattered across a wide range of documents, so it is  difficult to be certain that agencies would consider all operational areas  required to fully incorporate telework into emergency or continuity  planning. For example, as illustrated in appendix II, OPM guidance  dealing with a range of human-capital topics, such as pay and leave and  human-resource flexibilities, also includes practices that could help  agencies incorporate telework into their continuity and emergency  planning. But without lead agency collaboration and consensus on a  comprehensive set of practices on incorporating telework into emergency  and continuity planning, agencies and OPM cannot be sure that each  agency has considered all of the relevant areas of its operations that may  need to be adapted to support teleworkers during an emergency.
It is also not unusual for a lead agency to draw practices, in whole or in  part, from other lead agencies’ guidance. While this helps the reader  become aware of the potential crosscutting implications of the guidance,  the description of these practices often does not provide a reference to  more-specific guidance available from the other lead agency, which would  also be helpful. For example, FEMA’s FCD 1 suggests repeatedly that  agencies consider using telework to support continuity operations, but  does not reference OPM or GSA telework guidance.
section_title: OPM and FEMA Coordinated Recently Issued Guidance with Some Stakeholders, but OPM Did Not Tap into the CIO Community
subsections: section_title: OPM and FEMA’s Recent Telework-Emergency Guidance Was Coordinated with Some Stakeholders
paragraphs: OPM and FEMA have both recently released updated guidance  pertaining to telework and emergency planning, and both agencies  reached out to some of their stakeholder communities. Following the  extended closings of federal agencies in the Washington, D.C., area  during the February 2010 snowstorms, OPM updated the Dismissal  Guide to introduce “unscheduled telework,” a new option for federal  employees to telework, to the extent possible, when severe weather  conditions or other circumstances disrupt commuting. OPM officials  believe this option will help maintain the productivity and resilience of the  federal workforce during periods of heavy snow accumulation, national  security events, and other regional emergencies and help ensure the  safety of employees. This new option had effects in areas of policy and  guidance, such as pay and leave, agency IT capacity, telework data  collection, and emergency operations. Although only applicable to  executive-branch agencies in the Washington, D.C., area, OPM officials  indicated that the guide also serves as a reference and model for  closures and dismissals due to snow and other emergencies in other  regions. The guide notes that FEBs coordinate similar dismissal or  closure procedures in other major metropolitan areas.
Officials from OPM’s Pay and Leave Office led the development of the  2010 Dismissal Guide. The OPM officials’ goal was to coordinate among  stakeholders and issue the guide before the arrival of winter storms.  According to these officials, they developed potential revisions and began  the process of coordination among many stakeholders on October 28,  2010, by briefing the deputy Chief Human Capital Officers (CHCO) on the  new concepts and asking for their reactions.
During November 2010, OPM officials continued to share concepts and  drafts, receive comments, and incorporate revisions to the draft guide.  During this period, they sought additional reviews of the draft guide from  agency human-capital officials. The Executive Director of the CHCO  Council distributed the draft for agency comment to the deputy CHCOs,  requesting that they share the draft with the points of contacts within their  agencies. In addition, OPM officials said they consulted with unions, the  Metropolitan Washington Council of Governments, and the FEMA Office  of National Capital Region Coordination, among others.
In December 2010, the OPM officials completed their stakeholder reviews  and OPM completed its internal clearance process to issue the guide.  They presented the new Guide to the CHCO Council members and the  White House staff on December 14 and held a media briefing on the new  guide when it was issued on December 15. On the same day, OPM  officials reported they also briefed the FEBs on the new guide.
FEMA also provided updated guidance in 2010 to agencies on developing  their continuity plans. In 2004 FEMA issued a template to help agencies  develop continuity plans. The template provided general guidance,  sample text, and a template containing all the elements of a viable  continuity plan. This enabled agencies to insert information from the  template into their continuity plans as they deemed appropriate. FEMA  began developing its latest version of the template in 2009. By May 2009,  FEMA National Continuity Programs (NCP) officials had developed the  updated template sufficiently to share an initial version of it with  departments and agencies to prepare for the 2009 continuity exercise  called Eagle Horizon.
FEMA NCP officials continued to update the template during 2010.  According to NCP officials, the template was discussed during  Interagency Continuity Working Group meetings and Continuity Advisory  Group meetings. In September and October 2010, NCP officials e- mailed more than 100 members of the interagency community, including  both continuity coordinators and continuity planners, requesting  comments on the updated template draft. In addition, NCP officials  provided the GSA Office of Emergency Response and Recovery, which  has responsibility for policy guidance on alternate continuity facilities,  the opportunity to review and comment on the template.
FEMA finalized the continuity template in February 2011 and posted it on  its website. The template provided agencies with more-detailed guidance  for each section of the plan, including proposed language, citations for  supporting authorities and a glossary of terms. This template included  guidance on the use of alternative facilities, including telework.
section_title: OPM and GSA Coordinated on the Dismissal Guide, but Did Not Involve the CIO Community
paragraphs: Although OPM officials shared drafts of the Dismissal Guide with other  federal agencies, including GSA, the coordination between OPM and  GSA did not involve working together to involve the agencies’ CIO  community. As noted earlier, to address coordination issues between  OPM and GSA, in 2003, the two agencies committed to an MOU. Under  the MOU, GSA agreed to develop innovative workplace policy and  guidance and to seek resolution to issues regarding IT support for  telework where concerns about home IT equipment continue to be a  barrier to the successful implementation of telework programs. OPM is to  work with GSA to reach appropriate groups of CIOs to facilitate their  greater involvement in agency long-term planning.
The Dismissal Guide noted that the new option of “unscheduled telework”  could occasion large numbers of employees teleworking simultaneously.  Consequently, the Dismissal Guide advised agencies that they should  ensure that their IT infrastructure was in place to support this. IT  infrastructure includes equipment, software, and security.
However, in 2009, we reported that 12 agencies, including GSA, as  indicated in table 6, had done some, little, or no testing of the ability of  their IT infrastructure to handle telework or similar arrangements during a  protracted emergency, such as a pandemic influenza.
Without adequate testing of IT infrastructure, agencies would not know  whether they could rely on unscheduled telework to sustain operations  during emergencies. Some agencies may have limited IT capacity to  support large numbers of employees attempting to telework  simultaneously, and might have to take steps to distribute system load  until the agency capacity is increased. For example, the Department of  Energy’s (DOE) Inspector General reported in 2010 that DOE’s COOP  plan estimates peak employee absenteeism during a pandemic event  could be as high as 40 percent, or approximately 3,000 employees at  DOE headquarters; however, DOE’s remote access server can only  accommodate 800 concurrent users. GSA’s last assessment of the  telework technology environment and the technologies required to  support 25 to 50 percent of the federal workforce teleworking was  conducted in 2006. At that time, GSA concluded, “In general most  organizations do not provide their teleworkers the same level of access to  agency applications, data, and technical support as their office workers,  which can hinder a teleworker’s ability to perform all job duties from their  telework site.”
Despite the importance of agency IT capacity to support telework during  emergencies, OPM and GSA did not work together, as outlined in their  MOU, to reach out to the CIO community regarding potential agency  capacity limitations. At the time of development of the new policy, each of  the OPM and GSA officials responsible for coordinating on the MOU did  not recognize the opportunity to involve the CIO community. The OPM  official thought the agency telework coordinators and CHCOs were aware  of the IT capacity issue and would consider this in implementing their  telework programs. The GSA official thought the policy was targeted to  the human-resources community and the technology issue would be  more effectively dealt with in a document directed to the IT community.  Consequently, GSA officials did not offer any governmentwide guidance  on ways to address infrastructure limitations or provide direct assistance  to agencies regarding the adequacy of their IT infrastructure. The senior  OPM official responsible for telework programs acknowledged that  consulting with the CIO Council prior to issuing the Dismissal Guide  would have been worthwhile. Going forward, coordination will become  even more important because the Telework Enhancement Act of 2010  requires OPM to consult with GSA on policy and policy guidance for  telework in the areas of telework technology and equipment.
section_title: Conclusions
paragraphs: The Telework Enhancement Act of 2010 requires agencies to incorporate  telework into their COOP plans. However, there is no governmentwide  definition or cohesive set of practices for incorporating telework into  COOP plans. Recent reports offered several examples of challenges  agencies may face in supporting the use of telework during emergencies  in such key areas as planning, IT, and personnel readiness. The absence  of a definition of what constitutes incorporation of telework into  emergency and continuity plans did not create these potential problems in  readiness. However, a definition accompanied by a set of practices that  acknowledged the broad range of operational areas affected by  incorporating telework into emergency preparedness might help agencies  identify, avoid, or address any operational problems. Such practices  would help agencies take the appropriate steps, measure their progress,  and know when they have achieved success. Some practices already in  OPM, GSA, FEMA, and FPS guidance documents could provide a  starting point.
The lack of a definition for incorporating telework into emergency and  continuity planning has also affected the reliability of recent OPM telework  survey results and assessment of agency progress. Since 2004, OPM  has used its annual survey of agency telework coordinators to report on  the status of agencies’ telework program and policies, including agencies’  incorporation of telework into emergency plans. However, problems with  OPM’s telework survey methodology, such as a lack of a definition for  incorporation or integration into continuity and emergency planning, and  vagueness in question construction, call into question the reliability of  reported results with respect to this issue. Without reliable data, OPM is  unable to assess the extent to which the federal government as a whole,  or an individual agency, is making progress on incorporating teleworking  into emergency planning and operations.
Over the years, governmentwide telework and emergency-related  guidance from OPM, GSA, FEMA, and FPS has broadened in scope to  include references to the potential use of telework during emergencies. In  addition, these guidance documents suggest practices drawn from other  lead agencies’ guidance. While these guidance features can heighten  agency officials’ awareness of the crosscutting considerations bearing on  the potential use of telework during emergencies, without lead-agency  collaboration and consensus on the crosscutting passages in the  guidance, coordination with a key policy area may be missed. In a recent  instance, while OPM coordinated with other agencies on its new  Dismissal Guide, the guide did not address important areas of agency IT  operations––despite the existence of an MOU between OPM and GSA  intended to improve interagency coordination specifically on this issue. In  developing future telework policy and policy guidance relating to  emergency and continuity planning and operations, OPM will need to  consult with agencies responsible for key policy areas, now including  NARA, to ensure all key policy areas are fully considered.
section_title: Recommendations for Executive Action
paragraphs: To enhance the potential use of telework during emergencies, we  recommend that the Director of OPM, in consultation with agencies  responsible for key policy areas specified under the Telework Act and  with other agencies providing governmentwide guidance on emergency  preparedness, such as FPS, take the following three actions:    Develop (1) a definition of what constitutes incorporating telework in  emergency and continuity plans and (2) a cohesive set of practices  that agencies should implement to achieve successful incorporation.    Revise OPM’s data-collection methodology to ensure agencies and  OPM report reliable results on the extent to which agencies have  incorporated telework into their emergency and continuity planning  and operations.    Establish an interagency coordination process among OPM, FEMA,  FPS, GSA, and NARA to ensure all major areas of agency operations  are considered when OPM issues new or updated guidance related to  using telework during emergencies.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Secretary of Homeland Security,  the Administrator of GSA, and the Director of OPM for review and  comment. The Director of OPM and the Director of the Departmental  GAO/OIG Liaison Office for DHS provided written comments, which we  have reprinted in appendixes III and IV. In summary, OPM concurred with  our recommendations and highlighted a number of actions the agency  has under way or plans to undertake in response. OPM and DHS also  provided technical comments, which we incorporated as appropriate.  GSA had no comments on the draft.
We are sending copies of this report to the congressional committees with  jurisdiction over DHS and GSA, and their activities; the Secretary of  Homeland Security; the Administrator of GSA; and the Director of Office  of Management and Budget. In addition, the report will be available at no  charge on the GAO website at http://www.gao.gov.
If you have any questions about this report, please contact me at (202)  512-6543 or steinhardtb@gao.gov. Key contributors to this report are  listed in appendix V. Contact points for our Offices of Congressional  Relations and Public Affairs may be found on the last page of this report.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report (1) describes the guidance that the Office of Personnel  Management (OPM), General Services Administration (GSA), Federal  Emergency Management Agency (FEMA), and Federal Protective  Service (FPS) have issued pertaining to the use of telework during  emergencies; (2) assesses the extent to which OPM’s recent reviews of  the agencies’ telework policies and programs address the incorporation of  telework into continuity plans, and the extent to which OPM, FEMA, GSA,  and FPS offer guidance on incorporating telework into emergency and  continuity planning; and (3) assesses the extent to which OPM and FEMA  coordinated with other agencies on the development of their recently  released guidance documents pertaining to the use of telework during  emergencies.
To address these three objectives, we reviewed governmentwide  telework and emergency-related statutes. We also reviewed regulations  issued by OPM and GSA, and related governmentwide guidance that  OPM, GSA, FEMA, and FPS had issued over the past 10 years. Lastly,  we conducted interviews with key officials from each of these agencies  regarding each objective. We conducted additional data collection and  analyses to answer selected objectives, as described below.
To assess the extent to which OPM’s recent reviews of the agencies’  telework policies and programs addressed the incorporation of telework  into continuity plans, we reviewed OPM’s annual telework survey and its  2010 evaluation of agency telework policies. We compared the survey  question relating to whether telework had been integrated into the  agency’s emergency preparedness / continuity of operations (COOP)  plans to generally accepted survey methodology. We also reviewed the  survey results for this question from the first year it was included in the  survey, in 2004, through the most recent survey, conducted in 2009. We  also compared OPM’s description of the methodology it used to evaluate  agency telework policies to GAO guidelines for developing and using  checklists. We also reviewed the cumulative scores that OPM evaluators  assigned to the checklist item—whether the telework policy “references  agency emergency policies (e.g., COOP and pandemic).” In addition to  reviewing OPM’s recent telework assessments, we reviewed recent GAO  and inspector general reports to identify examples of problems agencies  might be having with potentially using telework during emergencies.
To identify practices suggested by OPM, GSA, FEMA, and FPS for  incorporating telework into continuity or emergency planning, we  reviewed these agencies’ related governmentwide regulations and  guidance, and identified suggested practices for incorporating telework  into continuity or emergency planning. We compared these practices to  practices that GAO previously suggested for the same purpose and  identified examples of OPM, GSA, FEMA, and FPS suggested practices  that were similar to GAO-suggested practices.
We conducted this performance audit from February 2010 through July  2011 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
section_title: Appendix II: Examples of Practices Suggested to Federal Agencies for Incorporating Telework into Emergency and Continuity Planning and Operations
paragraphs: In reviewing several current guidance documents, we found that the  Office of Personnel Management (OPM), General Services Administration  (GSA), Federal Emergency Management Agency (FEMA), and Federal  Protective Service (FPS) have suggested to federal agencies, in various  telework or emergency-related guidance documents, several practices for  incorporating telework into various aspects of continuity or emergency  planning.
section_title: Appendix III: Comments from the Office of Personnel Management
section_title: Appendix IV: Comments from the Department of Homeland Security
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, William Doherty, Assistant  Director, and Patricia Farrell Donahue, analyst-in-charge, led the  development of this report. Sharon Hogan and Robert Gebhart made  significant contributions to this report. Gregory Wilmoth and Tom Beall  assisted with the design and methodology. Karin Fangman provided legal  counsel. Robert Love, Len Benning, and James Sweetman provided  technical assistance. William Trancucci verified the information in the  report.
section_title: Related GAO Products
paragraphs: Federal Work/Life Programs: Agencies Generally Satisfied with OPM  Assistance, but More Tracking and Information Sharing Needed.  GAO-11-137. Washington, D.C.: December 16, 2010.
Human Capital: Telework Programs Need Clear Goals and Reliable Data.  GAO-08-261T. Washington, D.C.: November 6, 2007.
Human Capital: Greater Focus on Results in Telework Programs Needed.  GAO-07-1002T. Washington, D.C.: June 12, 2007.
Continuity of Operations: Agencies Could Improve Planning for Telework  during Disruptions. GAO-06-740T. Washington, D.C.: May 11, 2006.
Continuity of Operations: Selected Agencies Could Improve Planning for  Use of Alternate Facilities and Telework during Disruptions. GAO-06-713.  Washington, D.C.: May 11, 2006.
Agency Telework Methodologies: Departments of Commerce, Justice,  State, the Small Business Administration, and the Securities and  Exchange Commission. GAO-05-1055R. Washington, D.C.: September  27, 2005.
Human Capital: Key Practices to Increasing Federal Telework.  GAO-04-950T. Washington, D.C.: July 8, 2004.
Facilities Location: Progress and Barriers in Selecting Rural Areas and  Using Telework. GAO-03-1110T. Washington, D.C.: September 4, 2003.
Human Capital: Further Guidance, Assistance, and Coordination Can  Improve Federal Telework Efforts. GAO-03-679. Washington, D.C.: July  18, 2003.