Emergency Management: Improved Federal Coordination Could Better Assist K-12 Schools Prepare for Emergencies
Published: 2016-03-10T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The 2012 school shootings in Newtown, Connecticut and the 2013 tornado in Moore, Oklahoma stress the need for schools to prepare for emergencies to help protect the 50 million students in K-12 public schools. In 2007, GAO found that most districts developed emergency operations plans and GAO made recommendations to improve school emergency planning. In 2013, the President directed Education, DHS, HHS, and Justice to help schools with their plans. GAO was asked to report on these efforts.
This report examines (1) how federal agencies support school emergency management planning and the extent to which they coordinate efforts; (2) the extent to which states require and support efforts to plan for school emergencies; and (3) what districts have done to plan and prepare for school emergencies and challenges faced. GAO interviewed federal officials and surveyed relevant state agencies in all 50 states and the District of Columbia. GAO also surveyed a generalizable random sample of 573 districts (70 percent response rate), and visited 5 districts and 12 schools in 3 states selected to reflect diverse locations and characteristics.
section_title: What GAO Found
paragraphs: The Departments of Education (Education), Health and Human Services (HHS), Homeland Security (DHS), and Justice (Justice) support K-12 schools in preparing for emergencies with various resources, including training, technical assistance, and funding, but their efforts are not strategically coordinated. Since jointly issuing a Guide for Developing High-Quality School Emergency Operations Plans in 2013 in response to a presidential plan, individual agencies have continued to work on a range of emergency preparedness initiatives, sometimes collaboratively; however, with the guide completed and no strategic coordination of agency efforts particular to schools, federal agencies have taken a piecemeal approach to their efforts. GAO found gaps in coordination that suggest recent efforts are insufficient: not all relevant agencies and officials are included in collaborative efforts or are aware of related efforts and resources, and agencies are offering different interpretations of the same federal guidance—all of which risks wasting limited federal resources on duplicative, overlapping, or fragmented efforts. Education officials said that although agencies discussed the need to continue coordinating following the guide, the presidential plan did not designate a lead agency going forward, nor give any agency direct authority or responsibility over an interagency effort, or require agency participation. However, these officials said Education has general authority to collaborate with other federal agencies to maximize the efficiency and effectiveness of its programs and to serve as the lead agency, where warranted and agreed upon. Leading practices on federal interagency collaboration include identifying leadership, relevant participants, and resources, and agreeing on outcomes. Absent a well-coordinated effort, agencies will continue to determine their priorities individually, which may hinder assistance to schools.
In GAO's survey of 51 state educational agencies, 32 states reported that they require districts to have emergency operations plans, 34 reported they require schools to have plans, and almost all states reported providing training, technical assistance, or guidance to support districts in developing or implementing plans. GAO's survey also found that 32 states reported requiring districts to conduct emergency exercises, such as drills, and 40 states reported requiring individual schools to do so. In addition, many states reported allowing districts and schools to determine specific plan content, with fewer than half reporting that they required districts or states to review district or school plans.
GAO's generalizable survey of school districts estimates that most districts updated and practiced their emergency operations plans with first responders, but struggled to balance emergency planning with other priorities. GAO's survey results also found that most districts had plans addressing multiple hazards and emergency procedures, such as evacuation. However, GAO estimates about half of districts included procedures on continuing operations or recovering after an incident. GAO also found most districts conducted emergency exercises, such as fire drills, and about half did so annually with police and fire department officials. However, an estimated 59 percent of districts had difficulty balancing emergency planning with higher priorities, such as classroom instruction time.
section_title: What GAO Recommends
paragraphs: GAO recommends that Education convene its federal interagency partners to develop a strategic approach to interagency collaboration on school emergency preparedness, consistent with leading practices. Education agreed that such improved federal coordination will better assist schools in preparing for emergencies.

section_title: Letter
paragraphs: Events in recent years, notably the 2012 shootings at Sandy Hook  Elementary School in Newtown, Connecticut, and several instances  since, as well as the tornado in 2013 in Moore, Oklahoma, continue to  underscore the importance of school emergency management planning to  help protect the approximately 50 million children annually entrusted to  the nation’s K-12 public schools. It is important for school districts to be  prepared to confront a range of threats and hazards, from man-made to  natural. At the same time, many entities, including federal, state, and local  agencies, support school emergency management planning efforts  designed to prevent, respond to, and recover from an incident. We  previously reported on the status of school emergency preparedness in  2007 and found that while no federal laws required school districts to  have emergency operations plans in place, 32 states reported having  laws or other policies requiring them, and that an estimated 95 percent of  school districts nationwide had also developed emergency operations  plans.
In 2013, the Departments of Education (Education), Health and Human  Services (HHS), Homeland Security (DHS), including the Federal  Emergency Management Agency (FEMA), and Justice (Justice),including  the Federal Bureau of Investigation (FBI), jointly issued guidance for  schools to help them develop emergency operations plans in response to  a presidential call for action to increase school safety. Federal agencies  have also developed additional tools and administered new grant  programs aimed at helping schools prepare for emergencies. You asked  us to provide an update on the status of school emergency management  planning, given continued incidents that threaten the safety and security  of the nation’s children while in school.
This report examines (1) how federal agencies support school emergency  management planning and the extent to which they coordinate their  efforts, (2) the extent to which states require and support efforts to plan  for school emergencies, and (3) what school districts have done to plan  and prepare for emergencies and what challenges, if any, they have  faced.
To answer these questions, we used a variety of methodologies. To  address objective 1, we conducted interviews with officials from  Education, DHS, HHS, and Justice and with staff at the Office of  Management and Budget; and reviewed relevant federal documents. We  also reviewed leading practices on interagency collaboration to assess  the collaborative efforts of these agencies. To address objective 2, we  administered two web-based surveys to all 50 states and the District of  Columbia: one to state educational agencies and another to state  administrative agencies. We administered these surveys from April  through July 2015, and all state agencies responded for 100 percent  response rates. To address objective 3, we administered a third web- based survey to a stratified random sample of 573 school districts—the  results of which were nationally generalizable. We administered this  survey from April through July 2015, and 403 districts, or 70 percent of  the districts in our sample, responded to the survey. The district survey  estimates are subject to sampling error because they are based on a  random sample. All percentage estimates used in this report have 95  percent confidence intervals and margins of error of within +/-7  percentage points, unless otherwise noted. To address both objectives 2  and 3, we visited Massachusetts, Texas, and Washington, which we  selected because they represent geographic diversity and vary across  characteristics, such as type of federal funding received for emergency  preparedness as well as whether there was a state school safety center,  which provides training and guidance to enhance school safety and  security. Within these states, we interviewed state education officials as  well as officials from five school districts, selected to reflect a mix of  urban, suburban, and rural areas. In each district, we interviewed officials  from at least two schools of varying student ages. In one state, we also  interviewed officials from a charter school that received federal funding for  school emergency preparedness. Information obtained during these  interviews is not generalizable, but provides insight into school  emergency management planning at the state, district, and school level.
For more detailed information on our scope and methodology, see  appendix I.
We conducted this performance audit from October 2014 to March 2016  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
subsections: section_title: Federal Role in Emergency Management Planning for Districts and Schools
paragraphs: State and local laws and requirements continue to guide districts and  schools when planning for and managing emergencies. The federal  government’s role in school emergency management has been to support  state and local activities, by providing guidance, training, equipment, and  funding to help districts and schools respond to emergencies effectively.  DHS is responsible for most federal emergency management programs,  including some that allow funds to be used for school emergency  preparedness. In fiscal year 2015, DHS awarded $989 million to states,  urban areas, and territories to prepare for and respond to terrorist attacks  and other disasters.
Since our 2007 report, the federal government has taken additional steps  to help districts and schools plan for and manage emergencies. In  March 2011, the White House issued Presidential Policy Directive 8,  aimed at strengthening the security and resilience of the United States  through systematic preparation for the threats that pose the greatest risk  to the country’s security. It also directed DHS to develop, in coordination  with other federal agencies, a national preparedness goal that identifies  the core capabilities necessary for preparedness and a national  preparedness system to guide activities to achieve that goal.
In response to the directive, DHS released in September 2011 the  National Preparedness Goal that identified capabilities to prevent, protect  against, mitigate, respond to, and recover from threats and hazards.  The Goal defined success around these five mission areas, which occur  before, during, or after an incident (see fig. 1). The Goal recognized that  preparedness is a shared responsibility of the whole community, which  FEMA, as a component of DHS, notes includes schools, among others.  As stated in the Goal, threats and hazards may include acts of terrorism,  cyberattacks, pandemics, and catastrophic natural disasters.
In January 2013, following the shootings at Sandy Hook Elementary  School, the White House developed a plan, Now is the Time, to protect  children and communities from gun violence which called, in part, for all  schools to have comprehensive emergency operations plans (see fig.  2). This plan also directed Education, DHS, HHS, and Justice to release  a set of model, high-quality emergency operations plans for schools by  May 2013.
section_title: Federal Agencies Provide Resources to Support School Emergency Management Planning, but Some Resources Are Often Underutilized and Efforts Are Not Strategically Coordinated
subsections: section_title: Federal Agencies Provide Various Resources to Help Schools Prepare for Emergencies, but Most School Districts Reported Not Using Federal Guidance and Other Non- Financial Resources
paragraphs: Education, DHS, HHS, and Justice each provide assistance to school  districts and schools with preparing for emergencies. In response to the  President’s call for model, high-quality emergency operations plans for  schools, among other things, in his 2013 plan to reduce gun violence, the  federal agencies jointly developed a Guide for Developing High-Quality  School Emergency Operations Plans (Federal Guide)—the primary  federal resource designed to help schools develop, implement, and revise  their emergency operations plans. The Federal Guide, which identifies  key planning principles for developing school emergency operations  plans, states that it is considered informal guidance and schools and  school districts are not required to adopt it. These principles include  considering all threats and hazards and all settings and times, and call for  following a collaborative process when creating and revising a plan.
The Federal Guide suggests that schools use a six-step planning  process, similar to the process established by FEMA for state and local  emergency management planning, to develop, maintain, and revise their  emergency operations plans. According to Education officials, this  represents a shift in guidance from an emphasis on plan content to an  emphasis on the planning process (see fig. 3).
Education, DHS, HHS, and Justice also separately develop and provide  resources such as guidance, training, technical assistance, and funding,  in line with their respective missions, to help districts and schools prepare  for emergencies. These include resources that directly support  emergency operations plan development as well as those that more  generally can be used to enhance districts’ and schools’ ability to prevent,  protect against, mitigate, respond to, or recover from threats and hazards  (see table 1).
Despite the availability of resources from Education, DHS, HHS, and  Justice for school emergency preparedness, our nationally representative  survey of school districts found that an estimated 69 percent of districts  did not rely on non-financial resources from any of these agencies to  develop or implement their plans in recent years. Further, as shown in  figure 4, we estimate that about one-third of districts or fewer relied on  such resources from the agencies individually.
Our survey of school districts and visits to districts and schools suggest  that limited awareness of federal non-financial resources and reliance on  local resources may be factors in districts’ limited use of such federal  resources. For example, based on our survey, an estimated 37 percent of  districts are aware of the Federal Guide or related resources from the  REMS TA Center. Similarly, officials in 2 of the 12 schools we visited  were familiar with the Federal Guide, though it is targeted to schools. In  one school we visited, an official who was familiar with the Federal Guide  told us that it was not user-friendly given its length (e.g., 67 pages). In  addition, officials in two districts said they rely on their state for guidance,  rather than on the federal government directly, as, for example, some  federal standards and guidance may not be as tailored to them.  According to our survey of state educational agencies, 35 states,  representing a majority of school districts, provide the Federal Guide to  their districts to assist in developing or implementing emergency  operations plans. With this number of states doing so, it is unclear why  there is limited awareness of the Federal Guide by districts nationwide.
section_title: Federal Agency Collaboration to Support School Emergency Preparedness Is Ongoing, but Gaps Exist
paragraphs: Education, DHS, HHS, and Justice collaborate on a number of individual  agency initiatives to support district and school efforts to prepare for  emergencies. According to federal officials, following the significant  interagency collaboration required to produce the Federal Guide in 2013,  as facilitated by the Office of the Vice President and National Security  Council, Education has continued to collaborate with the agencies to  develop resources to facilitate use of the Federal Guide, including by  leading development of a related guide for school districts. Education and  the agencies also developed resources that, though not necessarily  explicitly prepared as an emergency preparedness resource, can be used  to assist schools with other aspects of emergency preparedness,  including prevention. For example, Education and Justice jointly  developed a school discipline resource package designed, in part, to  assist schools in creating safer environments, which can be an important  step for prevention. Federal agency officials also told us they collaborate  through various groups that address, to varying degrees, certain needs of  schools and school children. For example, several agencies participate in  the Comprehensive School Safety Initiative interagency working group,  and a federal interagency policy sub-committee on active shooters,  though this entity is not specific to schools and does not address the full  range of threats and hazards schools face. Some agencies are also  involved with the National Advisory Council on Children and Disasters.  However, none of these entities primarily focus on the needs of schools  for emergency management planning, which, given the presence of  young children, can differ significantly from those of other institutions.  Federal officials told us the partnerships that resulted from the Federal  Guide have been valuable: one official said federal interagency  collaboration is the best she has experienced in her 18 years with her  agency.
However, we identified gaps in recent federal agency coordination that  suggest these efforts are insufficient in fully addressing the needs of  schools. Insufficient coordination may compromise the ability of federal  agencies to effectively support district and school emergency  preparedness efforts, and risks hindering such planning to help protect  students and staff in emergencies. We found:
Not all relevant federal agencies are included in collaboration  efforts. Transportation Security Administration (TSA) officials said the  agency is not involved in federal interagency collaboration on school  emergency management planning, including with the REMS TA  Center, despite TSA having developed multiple resources on school  transportation security, and knowing through its Baseline Assessment  for Security Enhancement program that security for school bus  transportation is often left out of district planning. Additionally, TSA  officials told us they were also not involved in developing the Federal  Guide because they were unaware of the effort—even though DHS, of  which TSA is a part, was one of the agencies involved in developing  the Federal Guide. Due to their lack of involvement in federal  interagency efforts for school emergency management planning, other  federal agencies may be unaware of TSA resources and unable to  share TSA information with local stakeholders. Recognizing the  importance of addressing transportation in school emergency  management planning, the Federal Guide makes multiple references  to it. Moreover, the REMS TA Center has elaborated on the  importance of addressing transportation in planning, stating in  informal guidance that effective emergency operations plans must  include procedures for students and staff to follow during non- instructional times, including time when students are on a school bus.  Leading practices on interagency collaboration state that it is  important to ensure that all relevant participants have been included in  the collaborative effort.
Relevant agency officials are not always aware of each other’s  efforts and resources, including within their own agency.  Education and FEMA officials said they collaborate on various school  emergency management planning initiatives. For example, Education  officials said that FEMA was among its federal partners involved in  developing a REMS TA Center tool designed to help districts and  schools create and customize emergency operations plans, and the  head of FEMA’s Emergency Management Institute (EMI) told us that  staff provide such tools to their training participants. However, EMI  officials we spoke with who are responsible for training courses for  district and school staff on developing emergency operations plans  said they were unfamiliar with these tools, raising concerns about  communication and coordination within the agency. In another case, a  FEMA official responsible for the Office of Counterterrorism and  Security Preparedness, to whom we were referred by FEMA officials  we interviewed about issues of coordination with DHS, said his office  was not involved in the development of related guidance from DHS’  Office of Infrastructure Protection issued in April 2013 on developing a  comprehensive K-12 school security program, which discusses how to  develop an emergency operations plan. Further, the official  indicated that he was unaware of the DHS guidance until its release.
As a result, officials from DHS and FEMA were simultaneously  involved in developing multiple resources for K-12 schools—including  the Federal Guide, issued in June 2013—to prepare for emergencies  without sufficiently coordinating these efforts. In reviewing the DHS  guidance, we also found it makes no specific mention or reference to  FEMA’s six-step planning process—the process on which the Federal  Guide is based—though it includes a number of the same steps. Gaps  in effective coordination and communication within and across  agencies raise questions about the efficient use of resources, and the  extent to which these related resources may be overlapping,  duplicative, or fragmented. Officials from Education and FEMA told us  greater collaboration is needed and welcome, particularly in light of  limited resources. Leading practices state that the challenges posed  by continuing federal budget constraints call for agencies to work  together more closely to leverage limited resources to achieve their  missions.
Agencies that collaborate offer different interpretations of the  same federal guidance. Education and the FBI were partners,  among others, in producing the Federal Guide; but, since its  completion, these agencies now publicly offer different positions on  the Federal Guide’s Run, Hide, Fight model. This model describes—in  order of preference—the steps adults should take when confronted by  an active shooter (see sidebar). Specifically, an Education official said  in producing the Federal Guide the federal agencies agreed to  exclude students from involvement in the option of fighting an active  shooter and instead included language that focused solely on  adults. In contrast, an FBI official stated that the Federal Guide is  designed to allow each community to determine whether to discuss  with high school students the option of fighting, and set its own  standards on how to discuss the Run, Hide, Fight model with school- age children—views which have been reported publicly. The FBI  official also said the goal of the Federal Guide is not to develop a one- size-fits-all plan, but rather, to have district officials, principals,  teachers, parents, and local first responders decide what is best for  their community. The FBI official stated that, though student  involvement in the option of fighting is not included in the Federal  Guide, the FBI does not take a position on whether or not school  districts should teach children to consider the option of fighting. In  addition, the official told us the FBI’s position aligns with Federal  Guide and noted that adults should consider the option to fight and be  trained accordingly. Given that the Federal Guide explicitly refers only  to adults when discussing the fight portion of Run, Hide, Fight,  conflicting views from federal agencies may create confusion for  districts and schools in interpreting this aspect of the federal  recommendations. Leading practices on interagency collaboration  state that it is important to address the differences created by diverse  organizational cultures to enable a cohesive working relationship and  create the mutual trust required to enhance and sustain a  collaborative effort. Education and FBI officials told us they meet  regularly with other federal partners through a federal interagency  policy sub-committee on active shooters, facilitated by White House  staff; however, their collaboration through this mechanism—which is  not exclusively focused on school emergencies—has not yielded a  consistent federal message to the public about whether and how  students should be involved in Run, Hide, Fight.
In the absence of a well-coordinated strategy for school emergency  management planning efforts, federal agencies have taken a piecemeal  approach to these efforts, which contributes to the gaps we have  identified. Education officials said that, especially since the issuance of  the Federal Guide, federal agencies currently face challenges around  coordination, resulting in efforts that have developed organically and  incidentally and without a strategic focus. Specifically, with their limited  resources, agencies determine their priorities and initiatives—and the  resources devoted to them—on an individual agency basis; meanwhile,  the emergency management and safety needs of schools are numerous  and complex. Acknowledging the value of interagency collaborative  efforts, these Education officials also said that such efforts help avoid  duplicative and inconsistent efforts across agencies. While officials from  FEMA and Justice did not identify specific challenges with federal agency  coordination in this area, these agencies focus more generally on  emergency planning and not specifically on the needs of school districts  and school emergency management planning—the area in which  Education identified issues.
As efforts to develop the Federal Guide came to a close, Education  officials told us that the agencies discussed the need to continue to  coordinate federal school emergency preparedness efforts moving  forward. According to these officials, the presidential plan that required  development of the Federal Guide did not designate a lead agency going  forward or give any agency direct authority or responsibility to convene an  interagency working group or require the participation of other federal  agencies. However, they said that the Department of Education  Organization Act provides the agency the general authority to collaborate  with other federal agencies to maximize the efficiency and effectiveness  of its programs and, where warranted and agreed upon, to serve as the  lead agency in such collaborations. Importantly, Education officials also  stressed that the ability to successfully carry out such activities relies to a  large degree on other federal agencies’ cooperation as well. Staff from  the Office of Management and Budget (OMB)—the agency responsible  for, among other things, communicating the President’s directions to  Executive Branch officials regarding specific government-wide actions— told us that while they may become involved in federal interagency efforts  absent clear leadership, federal efforts around school emergency  preparedness are best handled by agencies and monitored by OMB  through, for example, review of administration policy.
The absence of an interagency body to coordinate related federal efforts  may hinder the ability of federal agencies to successfully address the  complex emergency management needs of schools. Leading practices  such as (1) identifying leadership for collaborative efforts; (2) defining and  agreeing to common outcomes, and assigning accountability for these  collaborative efforts; (3) identifying all relevant participants; and (4)  identifying necessary resources have been shown to improve the  likelihood of success for federal interagency efforts. Further, the  Government Performance and Results Act of 1993 (GPRA), as updated  by the GPRA Modernization Act of 2010, establishes a framework for a  crosscutting and integrated approach by agencies to focus on results and  improve government performance. This framework includes identifying  how an agency is working with other agencies to achieve its performance  goals, in that well-coordinated strategies can reduce potentially  duplicative, overlapping, and fragmented efforts.
section_title: Most States Reported Requiring Emergency Operations Plans and Exercises, and Providing Training or Other Support
subsections: section_title: Most States Reported Requiring District or School Emergency Operations Plans, and Many Also Allowed Districts and Schools to Determine Plan Specifics
paragraphs: According to our survey of state educational agencies in the 50 states  and the District of Columbia, 32 states reported requiring that districts  have emergency operations plans and 34 states reported requiring that  schools have plans, and 25 states reported requiring plans for both (see  fig. 5). Additionally, many states also allowed districts and schools to  determine the specific content of these plans. The states that reported  they have requirements for districts and/or schools represent about 88  percent of K-12 students nationwide. Thus, even though not all states  reported requiring plans, our district survey found an estimated 97  percent of districts nationwide had a plan, which can help schools plan for  potential emergencies as noted by the Guide for Developing High-Quality  School Emergency Operations Plans (Federal Guide).
Even though most states reported requiring districts and/or individual  schools to have plans, our state survey found that many do not set forth  specific requirements on plan content, and that the degree to which states  require plans to contain specific content varies widely. For example, as  shown in figure 6, 29 states reported requiring schools to address  lockdown procedures in their plans while 10 reported requiring school  plans to address continuity of operations. Similarly, 25 states reported  requiring district plans to address evacuation procedures while 9 reported  requiring district plans to address continuity of operations.
Our state survey also asked about requirements that district or individual  school plans address the needs of specific populations of students,  including those with disabilities, and found that fewer than half of states  reported having such requirements; however, our district survey shows  that most districts included these procedures in their plans. Specifically,  21 states reported requiring district or school plans to address the needs  of individuals with disabilities or special needs.  Separately, our district  survey shows that an estimated 69 percent of districts nationwide  reported having procedures in their district or school plans that support  the access and needs of the whole school community, including these  individuals. For example, in one of the elementary schools we visited, the  school calls for a “buddy system” to help each special needs student  evacuate during an emergency. The school’s plan also notes that special  equipment, such as lights or horns, might be required to alert students  with certain sensory disabilities during emergencies. In a similar trend,  according to our state survey, fewer than 10 states reported requiring  either districts or schools to address the needs of individuals with limited  English proficiency. Our district survey shows that an estimated 45  percent of districts had procedures in their district or school plans for  communicating with parents or students who are limited English  proficient.
Another example of an area where states allowed districts and schools to  determine the content of their plans is threats or hazards. According to  our state survey, fewer than half of states reported requiring districts or  individual schools to have plans that address certain specific threats or  hazards, such as active shooter, infectious diseases, or food safety, but  our district survey found that most districts have plans that do so.  However, for fires and natural disasters, our state survey shows that  about half or more of states reported requiring that plans address these  specific threats and hazards (see table 2).
section_title: More Than Half of States Reported Requiring That Districts or Schools Conduct Emergency Exercises, Particularly Fire Drills
paragraphs: According to our state survey, 32 states reported requiring that districts  conduct emergency exercises of their plans, such as drills, while 40  reported requiring that individual schools conduct them. The states that  reported having requirements for districts and/or schools to conduct  exercises represent about 83 percent of K-12 students nationwide. An  estimated 96 percent of districts or their schools conducted emergency  drills during school years 2012-13, 2013-14, and/or 2014-15, according to  our district survey. Our state survey found that district and school fire  drills were most frequently required, and active shooter drills significantly  less so (see fig. 7). While our survey did not ask why certain drills were  required more than others, Education officials told us that as part of  emergency management planning, schools need to assess the likelihood  of active shooter incidents, which present a smaller risk than other  emergencies.
section_title: Nearly All States Provided Support to Plan for Emergencies, and Fewer Than Half Reported Requiring States or Districts to Review Emergency Operations Plans
paragraphs: Based on our survey of 51 state educational agencies, nearly all states  provided training, technical assistance, or guidance to districts to assist in  developing or implementing emergency operations plans. In addition,  nine states provided state funds to districts in one or more fiscal years  2013 through 2015 and five of the nine provided funding in all three  years. Officials in one of the states we visited said their state offers  technical assistance and training to some districts and schools, and their  state educational agency website has links to state and federal resources  on planning for emergencies. In addition, two of the states we visited  have state school safety centers that provide technical assistance and  guidance to districts and schools (see sidebar).
As part of their efforts to provide districts with support for developing or  implementing plans, 47 state educational agencies collaborated with their  state emergency management agency, according to our state survey. In  addition, in the three states we visited, state officials discussed  collaboration among state agencies on school emergency management  planning. The state educational agency officials we met with in these  three states said they work with other state agencies on school  emergency management issues. For example, in one state we visited, the  state educational agency worked with the state departments of public  safety, and health and human services on a school safety and security  task force that set forth recommendations to districts and schools on  making schools safe without compromising educational goals.
State education officials we met with also cited challenges they face when  supporting district and school efforts to plan for emergencies. Officials in  two of the three states we visited said limited resources, staff, and funding  are challenges. More specifically, officials in one of these states said their  office does not have sufficient staff or resources to provide emergency  management planning assistance and training to schools on a wide scale.  In another state, officials told us that limited funding and staff hinder the  state’s ability to help districts and schools plan for emergencies.
Over half of states reported requiring districts or individual schools to  have plans, as noted above, and fewer than half of states reported  requiring that either district or school plans be reviewed at least every 2  years, according to our state survey. Similarly, fewer than half also  reported requiring that either districts or state educational agencies  review district or school plans. For those states that did report having  requirements to review plans, 24 states required that districts review their  own plans, and 24 states required that districts review school plans.  Further, an estimated 79 percent of districts that required their schools to  have plans also required their schools to submit these plans for district  review, according to our district survey.
section_title: Most Districts Reported Updating and Practicing Emergency Operations Plans with First Responders, but Struggled to Balance Emergency Planning with Other School Priorities
subsections: section_title: Most Districts Involved School Personnel and First Responders in Developing and Updating Their Emergency Operations Plans
paragraphs: Most school districts involved a wide range of community members,  particularly school personnel and first responders, when developing and  updating their emergency operations plans, according to our nationally  representative survey of school districts (see fig. 8).
Our prior work has shown similar levels of involvement with one notable  difference: engagement of school resource officers, who are sworn law  enforcement officers working in a school setting, increased from 42  percent in 2007 to 89 percent in 2015. Our district survey also found  that an estimated 92 percent of districts recently updated their plans.  Further, we estimate that almost all of the districts that require schools to  have plans also require schools to update and review those plans.
School and district officials at the sites we visited also noted that school  personnel and first responders were involved in their plan development.  Officials in all five districts we visited in three states told us they had staff  committed to emergency management planning. Further, officials at 9 of  the 12 schools we visited also said they had teams responsible for such  planning, many of which met regularly and included a variety of members.  Officials from two schools added that their parent-teacher associations  are supportive of emergency preparedness efforts and have provided  funding for emergency supplies.
These practices align with a recommendation in the Federal Guide,  specifically, that school emergency management planning not be done in  isolation. The Federal Guide also notes that such collaboration makes  more resources available and helps ensure the seamless integration of all  responders. Relatedly, we found that an estimated 68 percent of districts  incorporated their district plans into the broader community’s emergency  management system. For example, officials from one district we visited  said their school district is a part of the city’s emergency operations plan  and has responsibility for providing shelter during emergencies.
As part of developing and updating an emergency operations plan, the  Federal Guide recommends that districts and schools assess the risks  posed to them by specific threats and hazards. Based on our survey data,  we estimate that more than three-quarters of districts recently conducted  such assessments of their vulnerabilities (see fig. 9).
For example, officials from one district told us that they conduct an annual  safety assessment of each school. In doing so, they assess physical and  access control, such as fences and locks. Officials from another district  said assessments led to security enhancements, such as adding fences  to sports fields, panic buttons that connect office staff to emergency  officials, and software to run instant background checks.
section_title: Most Districts Reported Having Emergency Operations Plans That Address Threats and Hazards, While Half Did Not Include Certain Recovery Procedures
paragraphs: Our district survey found that most school districts had emergency  operations plans that address multiple threats and hazards, such as  intruders, fires, active shooters, natural disasters, and bomb threats (see  fig. 10). We also observed during visits to schools that a school’s  particular circumstances, such as location, affect the threats and hazards  they face. For example, officials from one school said their plan includes  not only common threats and hazards, such as fires, but also those  associated with facilities nearby, including an airport and chemical plant.
According to our survey, districts generally had plans that address most  of the emergency response procedures recommended in the Federal  Guide, such as evacuation and shelter-in-place (see fig. 11). For  example, we estimate that almost all districts had procedures in place for  evacuation, lockdown, and communication and warning. To illustrate,  officials from five schools we visited said they use an automated  messaging system to notify parents of an emergency.
In contrast, our district survey estimates that about half of districts  specified how they would maintain continuous operations or recover after  an incident. For example, officials we interviewed from one school said  that while their plan does not comprehensively address how they would  maintain continuous operations after an incident, it does specify some  aspects: if the school needed to close for an extended period, lessons  could continue via a web portal. It is not readily apparent why fewer  districts included these types of procedures in their plans. Education’s  REMS TA Center offers several resources on these topics such as an  online course for developing continuity of operations procedures, among  others.
The Federal Guide recommends that emergency operations plans  provide for the access and functional needs of the whole school  community, including persons with disabilities and people with limited  English proficiency, among others. As previously noted, our district survey  found that an estimated 69 percent of districts had plans with procedures  supporting persons with disabilities. An additional 22 percent of districts  also had such procedures outside of their plans. We also learned about  such procedures in some of the schools we visited. For example, officials  from one school said that they used specially colored markers on the  walls to guide a visually impaired student toward the exit. Officials from  another school told us that during fire drills students who are highly  reactive to loud noises such as a fire alarm are proactively given noise- reducing headphones. As noted earlier, our district survey estimated that  45 percent of districts had plans that address procedures for  communicating with students or parents who are limited English  proficient. An additional 26 percent of districts also reported having such  procedures outside of their plans. Our visits to schools revealed specific  examples. Officials from one school said teachers of students with limited  English proficiency walk through each step of a drill to ensure these  students understand. Regarding communication with parents who are  limited English proficient, officials from one school said they have a  contract with a language translation service to connect a school  administrator, translator, and parent via conference call, when necessary.
section_title: Most Districts Conducted Emergency Exercises and Many Did So Regularly with First Responders
paragraphs: Our survey estimated that most school districts recently completed a  variety of emergency exercises, such as drills and group discussions, and  many did so regularly with first responders (see fig. 12). According to the  survey, almost all districts conducted drills. Officials from four schools we  visited said they explain drill procedures to students in an age-appropriate  way, a practice recommended by the Federal Guide. For example,  officials at one school we visited said that during a lockdown drill  kindergarten teachers tell their students that a wild animal may be loose  in the building.
In contrast, our survey estimated that fewer districts completed functional  and full-scale exercises, which require a significant amount of planning,  time, and resources. For example, officials from one school district told us  they participated in a city-wide functional exercise that involved various  community partners, such as the public health department. They said the  8-hour session helped participants better understand their roles during an  emergency, for example, the responsibilities of school principals.
Districts that conducted drills, functional exercises, or full-scale exercises  did so for specific threats or for certain procedures. For example, our  survey found that almost all performed such exercises for fires and  lockdowns (see fig. 13). This aligns with our state survey findings that  many states reported requiring districts or schools to conduct such  exercises.
Our survey also found that fewer districts—an estimated 67 percent— conducted active shooter exercises. In the districts we visited, we heard  about some reasons for this. Officials from two districts said these  exercises can create anxiety within the school community, including  among parents. Officials from one of these districts noted the difficulty of  striking a balance between providing knowledge and inciting fear,  particularly at schools with younger children.
Based on our survey, we estimated that about half of districts practiced  their emergency exercises annually with law enforcement and fire  department officials (see fig. 14). Similar to the benefits cited in  developing plans with community involvement, officials from two schools  we visited told us that firefighters and police officers observe and provide  feedback on their drills. Officials from one school cited the advantages of  such interactions as strengthening community relationships as well as  providing first responders with helpful information in advance of an  emergency, such as a school’s layout. However, our survey estimated  that about a quarter of districts reported having never practiced with  emergency medical services or emergency management officials, and  about a third never practiced with public health officials.
Following such exercises, the Federal Guide recommends that officials  gather to evaluate how the process went, identify shortfalls, and  document lessons learned. We found examples of this at the schools we  visited. For example, officials from 7 of the 12 schools we visited said that  they debrief after drills to determine what lessons could be learned.  During our interviews with schools, we learned of such improvements. For  example, officials at one school realized teachers could not lock their  classroom doors without stepping into the hallway, potentially placing  them in harm’s way. Officials remedied the problem by placing a magnet  over the door’s locking mechanism which can be quickly removed to lock  the door in an emergency. Another school discovered that all teachers  need two-way radios during drills for effective communication.
section_title: Majority of Districts Reported Difficulty Balancing Emergency Management Planning with Other School Priorities
paragraphs: Based on our survey, an estimated 59 percent of districts reported  difficulty balancing emergency management planning with higher  priorities, such as instructional time. The survey also estimated that about  half of districts reported that these competing priorities made it difficult to  coordinate with community partners and organizations. Relatedly, it also  estimated that more than half of districts felt that they did not conduct  enough training because of limited time. Our visits to states and schools  revealed similar challenges. Officials from one state told us that district  and school staff had inadequate time for emergency management  planning. Similarly, officials from 6 of the 12 schools we visited reported  difficulty finding sufficient time to plan for emergencies, train staff, or  conduct drills, with several noting that such activities competed with other  school priorities. Officials from one school suggested additional  professional staff days were needed, but said that negotiating such days  can be difficult.
According to our survey, an estimated 49 percent of districts cited a lack  of staff expertise and an estimated 42 percent of districts reported  insufficient equipment as impediments to emergency management  planning. For example, officials from one state we visited said that  teachers are not trained in emergency management, such as on how to  conduct table top exercises. In addition, officials from several districts and  schools said obstacles to emergency preparedness can include schools’  physical aspects. For example, officials from one district said that schools  with portable classrooms cannot use their intercom system to announce  emergency drills, but rather must connect to those classrooms using a  phone line.
Further, officials from two of the three states we visited and from  Education said districts and schools have limited resources for  emergency management planning. As mentioned previously, our state  survey found that few states reported providing funding to help districts  develop or implement their plans. Federal Education officials echoed a  similar opinion stating that in an environment of constrained resources,  districts and schools tend to focus almost exclusively on response  activities, as opposed to the other four preparedness areas (prevention,  protection, mitigation, and recovery). They suggested that this could have  serious implications for schools and districts. For example, they said  some districts and schools do not conduct thorough assessments of their  risks and vulnerabilities and some school plans are not adequately  customized because they are overly reliant on district-provided plan  templates.
section_title: Conclusions
paragraphs: Confronting the range of threats and hazards to the nation’s 50 million  public school students necessitates careful and comprehensive  emergency management planning by school districts and schools. We  were encouraged to note that nearly all districts reported having  emergency operations plans and, as recommended in the 2013 Federal  Guide for school emergency planning, involve a range of school  personnel and community partners in developing and updating them,  recognizing the critical importance of collaborating with stakeholders both  within and outside the school community.
However, a majority of districts confront competing priorities with limited  resources, which could hamper emergency management planning efforts,  thus reinforcing the value of state and federal support. Education and  other federal agencies individually offer a breadth of resources that  districts and schools can use in their emergency planning. Although  individual agencies continue to work on a range of emergency  preparedness issues, and, in some cases, have continued to collaborate  with other agencies in doing so, current collaboration efforts are  insufficient to comprehensively address the complex and unique needs of  schools. For example, an existing federal interagency group on active  shooters was not created to address the range of threats and hazards  schools face, nor to be specific to schools’ needs, which, given the  presence of young children, can differ significantly from those of other  institutions. Moreover, in the absence of a well-coordinated federal  strategy for school emergency preparedness planning, federal agencies’  piecemeal approaches to school emergency management planning  contribute to the gaps we identified in timely, continued, and most  importantly, strategic coordination, and risk wasting limited federal  resources on efforts that may be overlapping, duplicative, or fragmented.
To help protect students entrusted to public schools from natural and  man-made threats and hazards, it remains critical for federal agencies to  address key considerations shown to improve the likelihood of success  for interagency collaboration on a well-coordinated federal strategy. The  Department of Education stated that it has the general authority to  collaborate with other federal agencies to maximize the efficiency and  effectiveness of its programs, and to serve as the lead agency in such  collaborations where warranted and agreed upon. Absent agreement on a  strategy consistent with leading collaboration practices, which include (1)  identifying leadership for the effort; (2) defining and agreeing to common  outcomes, and assigning accountability for these collaborative efforts; (3)  identifying all relevant participants; and (4) identifying necessary  resources; federal agencies may, over time, lose momentum and  undermine the progress that has already been made, and risk providing  support that is less effective than it otherwise could be.
section_title: Recommendation for Executive Action
paragraphs: Using its general authority to collaborate with other federal agencies, we  recommend that the Secretary of Education convene its federal  interagency partners to develop a strategic approach to interagency  collaboration on school emergency preparedness. This group could  include designees or delegates from the Secretaries of DHS, HHS, and  the Attorney General, including representatives from relevant agency  components, such as FEMA, TSA, and the FBI, and others as  appropriate, and should incorporate leading federal interagency  collaboration practices, for example, by: defining outcomes and assigning accountability, including all relevant participants, and  identifying necessary resources.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Departments of Education  (Education), Health and Human Services (HHS), Homeland Security  (DHS), and Justice (Justice) for review and comment. Education provided  written comments that are reproduced in appendix II. Education, DHS,  and Justice also provided technical comments, which we incorporated as  appropriate. HHS did not provide comments.
In written comments, Education stated that it shares the view outlined in  the report that improved federal coordination will better assist K-12  schools in preparing for emergencies, and noted that other federal  agencies, including especially FEMA, play a significant role in school  emergency preparedness. Additionally, Education cited the importance of  involving other relevant agencies in obtaining agreement on the  assignment of roles and responsibilities, including selecting a lead agency  charged with primary responsibility for coordinating federal emergency  preparedness assistance to K-12 schools. Given the roles of other  agencies, Education encouraged us to modify the recommendation that  was included in the draft that was provided to agencies for comment.  Specifically, in that draft we recommended that Education convene and  lead an interagency collaborative group on school emergency planning,  consistent with leading practices.
In light of Education’s response, which we agree is consistent with  leading practices on federal interagency collaboration that, among other  things, include identifying leadership for the collaborative mechanism and  all relevant participants, we modified the recommendation and report  accordingly. We believe that doing so will help increase the likelihood of  achieving a well-coordinated federal strategy in which all relevant federal  partners are identified, included, and invested—helping, ultimately, to  reduce the risk of wasting limited federal resources on efforts that may be  overlapping, duplicative, or fragmented.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the Secretaries of  Education, Health and Human Services, and Homeland Security, the  Attorney General, and other interested parties. In addition, the report will  be available at no charge on the GAO website at http://www.gao.gov.
If you or your staffs should have any questions about this report, please  contact me at (202) 512-7215 or nowickij@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. GAO staff who made key contributions to  this report are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report addressed the following questions: (1) how do federal  agencies support school emergency management planning and to what  extent do they coordinate their efforts; (2) to what extent do states require  and support efforts to plan for school emergencies; and (3) what have  school districts done to plan and prepare for emergencies and what  challenges, if any, have they faced?
In addressing these objectives, we conducted interviews with officials  from the Departments of Education, Homeland Security, Health and  Human Services, and Justice and with staff at the Office of Management  and Budget; and reviewed relevant federal documents, such as the Guide  for Developing High-Quality School Emergency Operations Plans. We  also reviewed leading practices on interagency collaboration to assess  the collaborative efforts of these agencies. We also deployed three web- based surveys: one to state educational agencies, another to state  administrative agencies, and a third to a stratified random sample of  school districts. We also conducted site visits during which we  interviewed state, district, and school officials in three states.
subsections: section_title: Surveys of States and Districts
paragraphs: To better understand the role of states in how school districts and schools  prepare for emergencies, we administered two web-based surveys—one  to state educational agencies and a separate one to state administrative  agencies—to all 50 states and the District of Columbia. We asked state  educational agencies about their requirements of and recommendations  for districts and schools regarding emergency management planning,  among other things. We asked state administrative agencies about  receipt and distribution of certain federal funds to districts or schools for  emergency management planning activities. We administered these  surveys from April through July 2015. For both surveys, all 51 state  agencies responded, resulting in response rates of 100 percent.
To better understand how districts and schools plan and prepare for  emergencies, we also administered a third web-based survey. We  obtained data from Education’s National Center for Education Statistics,  which maintains the Common Core of Data for public school districts, for  the 2012-13 school year, which was the most recent data available. We  originally selected a stratified random sample of 598 from a population of  16,284 school districts, with strata based on size and urban status, but  ultimately excluded 25 districts from our original population and sample  because they had closed, operated exclusively online, were located in a  juvenile detention center, or had fewer than 5 students, and thus were not  considered eligible for our survey.  This resulted in a sample of 573 from  the eligible population of 16,259 districts (see table 3).
We administered this survey to districts from April through July 2015 and  403 districts, or 70 percent of our sample, responded to the survey.  Because we followed a probability procedure based on random  selections, our sample is only one of a large number of samples that we  might have drawn. Since each sample could have provided different  estimates, we expressed our confidence in the precision of our particular  sample’s results as a 95 percent confidence interval (e.g., plus or minus 7  percentage points). This is the interval that would contain the actual  population value for 95 percent of the samples we could have drawn.  Unless otherwise noted, all percentage estimates in this report have  confidence intervals within plus or minus 7 percentage points. For other  estimates, the confidence intervals are presented along with the  estimates themselves. In the survey, we asked questions about the  emergency operations plans of districts and their schools, such as about  plan development and implementation, plan content, training and  resources, and challenges to emergency management planning.
The quality of both the state and district survey data can be affected by  nonsampling error, which includes, for example, variations in how  respondents interpret questions, respondents’ willingness to offer  accurate responses, nonresponse error (failing to collect data on  members of the sample or answers to individual questions from  respondents), and data collection and processing errors. To minimize  such error, we included the following steps in developing the survey and  in collecting and analyzing survey data. We pre-tested draft versions of  the instrument with state educational agency officials in four states, state  administrative agency officials in two states, and officials in four districts  to check the clarity of the questions and the flow and layout of the survey.  On the basis of the pretests, we made revisions to all three surveys.  Further, using a web-based survey and allowing state and district officials  to enter their responses into an electronic instrument created an  automatic record for each state and district and eliminated the errors  associated with a manual data entry process. To increase response rates,  we sent e-mails and placed phone calls to recipients of all three surveys.  We conducted a nonresponse bias analysis to assess the potential  difference in answers between those school districts that did participate in  the survey and those that did not. We determined components of the  sampling strata and school district size to be significantly associated with  the propensity to respond. We adjusted the sampling weights for these  characteristics using standard weighting class adjustments to  compensate for possible nonresponse errors and treat the respondent  analyses using the nonresponse adjusted weights as unbiased for the  population of eligible school districts. In addition, the programs used to  analyze the survey data were independently verified to ensure the  accuracy of this work.
section_title: Site Visits
paragraphs: To understand emergency management planning at the local level, we  conducted site visits in three states from February to May 2015. The  states we visited included Massachusetts, Texas, and Washington. We  selected states that represent geographic diversity and varied across  characteristics, such as type of federal funding for emergency  preparedness and whether there was a state school safety center, which  provides training and guidance to enhance school safety and security. In  each state, we interviewed state education officials, including staff from  state school safety centers, if applicable. Within these states, we also  interviewed officials from five school districts, which were selected to  reflect a mix of urban, suburban, and rural areas. In each district, we  interviewed officials from at least two schools of varying student ages. In  one state, we also interviewed officials from a charter school that was  independent of these five districts and received federal funding for school  emergency preparedness. In total, we interviewed officials from 12  schools. Information obtained during these interviews is not  generalizable, but provides insight into school emergency management  planning at the state, district, and school level.
We conducted this performance audit from October 2014 to March 2016  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: Comments from the Department of Education
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Kathryn Larin and Janet Mascia  (Assistant Directors), Avani Locke (Analyst-in-Charge), Teresa Heger,  Kathryn O’Dea Lamas, Sheila McCoy, Jean McSween, and James Rebbe  made significant contributions to this report. Also contributing to this  report were Susan Aschoff, Deborah Bland, Christopher Currie,  Christopher Keisling, Ruben Montes de Oca, Mimi Nguyen, Erin O’Brien,  William Reinsberg, Paul Schearf, Salvatore Sorbello, Sonya Vartivarian,  and Sarah Veale.