Human Capital: Opportunities to Improve Federal Continuity Planning Guidance
Released: 2004-04-20T00:00:00

Letter

Background

The policy of the U.S. government is to have in place a comprehensive and effective program to ensure continuity of essential federal functions under all circumstances. COOP planning is an effort conducted by individual agencies to fulfill that policy and assure that the capability exists to continue essential agency functions across a wide range of potential emergencies. COOP has been closely associated with continuity of government programs, which are meant to ensure the survival of our constitutional form of government. COOP was first conceived during the Cold War to ensure that the U.S. government would be able to continue to function in case of a nuclear war. However, in the wake of the demise of the Soviet Union and the reduced threat of nuclear attack in the early 1990s, COOP planning languished.

Following the World Trade Center bombing in 1993 and the Oklahoma City bombing in 1995, COOP as a program was given renewed attention based on the recognition of emerging threats and the need to continue essential functions of the federal government in an all-hazards environment, which includes acts of nature, accidents, technological emergencies, and incidents related to military or terrorist attacks. A series of Presidential Decision Directives (PDD) was issued that began to link programs for terrorism, critical infrastructure protection, and COOP. In addition, as we approached the turn of the century, federal agencies also dealt with the Year 2000 computer problem by developing business continuity and contingency plans to ensure program delivery in the event of a technology failure or malfunction. Federal COOP efforts have evolved by building upon the planning for each of these events that focused on protecting critical infrastructure, both physical systems and cyber-based systems. The events of September 11, 2001, highlighted in dramatic fashion the vulnerabilities agencies face in each of these areas and focused new attention on the effects such events have on agencies’ most important assets—their people, or human capital.

FEMA, the General Services Administration (GSA), and OPM are the three agencies that have the most direct impact on individual agency efforts to develop viable COOP capabilities. PDD 67, which outlined individual agency responsibilities for COOP, identified FEMA as the executive agent for federal COOP planning. As executive agent, FEMA has the responsibility for formulating guidance, facilitating interagency coordination, and assessing the status of COOP capability across the federal executive branch. PDD 67 also required GSA to work with FEMA in providing COOP training for federal agencies and to assist agencies in acquiring alternate facilities. In addition, the Federal Management Regulation requires GSA to lead federal Occupant Emergency Program (OEP) efforts, which are short-term emergency response programs that establish procedures for safeguarding lives and property during emergencies in particular facilities. As the President’s agent and advisor for human capital matters, OPM has been actively involved in federal emergency preparedness efforts. OPM has issued a series of emergency preparedness guides for federal managers, employees, and their families; issued a number of memorandums relating to planning, preparedness, and the flexibilities available to agencies in emergency situations; and held emergency planning and preparedness forums to help agencies select emergency personnel. In addition, FEMA, GSA, and OPM collaborate to implement the Federal Workforce Release Decision and Notification Protocol when emergency situations occur in the Washington, D.C., area.

Human Capital Considerations Are Relevant to Continuity Planning and Implementation Efforts

The current literature indicates, and experts that we consulted confirmed, that the immediate response to a crisis should give priority to securing the safety of all employees and addressing the needs of employees who perform or directly support essential operations. For example, the standard for emergency management and business continuity, which was developed by the National Fire Protection Association and endorsed by FEMA, recommends that organizations include the following priorities in their continuity program: ensuring the safety and health of employees, establishing critical functions and processes, and identifying essential representatives.

Consequently, the experts said that these priorities have received most of the human capital attention in continuity efforts for both the private and public sectors, including federal agencies. Appropriately, organizations focus on minimizing the loss of life and injuries, which is key to all other recovery efforts. Such efforts commonly include first aid training, evacuation plans and drills, and dismissal policies. Organizations also focus on identifying the core group of employees that will establish and maintain essential operations as dictated by an organization’s mission. Organizations, for example, commonly identify leadership structures to manage crisis response. Even so, experts noted that organizations vary widely in their effectiveness in addressing these priorities.

The continuity process, however, extends beyond the goals of life safety and the performance of essential operations. The experts identified a number of human capital considerations beyond these goals that are not well addressed. For example, the priorities discussed above do not address human capital considerations for employees who are not involved in providing essential functions. Such employees would be associated with efforts to fully resume all other operations and represent the majority of an organization.

The experts identified two principles that should guide actions to more fully address human capital considerations applicable to all continuity planning and implementation efforts. The first is recognizing and remaining sensitive to employees’ personal needs during emergencies when shaping the appropriate organizational expectations of employees. The emergency event that activates continuity plans may also cause emergency events in the personal lives of individual employees. Similar to an organization placing its highest priority on the safety and well-being of its employees, employees may have high-priority responsibilities to others. These personal responsibilities may limit employees’ ability to contribute to mission accomplishment until these other obligations are satisfied.

The second principle experts identified is maximizing the contributions of all employees, whether in providing essential operations or resuming full services. This should be done within the limits of an employee’s ability to contribute given the situation, as described in principle one, and within the limits of the organization to use those contributions effectively. According to the experts, the experience of organizations during emergencies has been that employees remain motivated to contribute to organizational results, which is increasingly felt the longer the emergency continues. Enabling employees to contribute promotes more effective delivery of essential operations and more rapid resumption of full operations. In addition, in extreme disruptions of employees’ personal circumstances, providing purposeful activities helps avoid the debilitating affects of a disruption on employees, including job-related anxiety and post–traumatic stress disorder.

The experts we interviewed also identified six organizational actions to enhance continuity planning and implementation efforts, listed in figure 1.

Each of these actions is described in more detail below.

Our past work has shown that the demonstrated commitment of top leaders is perhaps the single most important element of successful change management and transformation efforts. Effective continuity efforts have the visible support and commitment of their organization’s top leadership. According to the experts, traditional continuity planning focuses on the operations side of recovery and often overlooks human capital considerations. As such, it is important for top leadership to ensure that the appropriate balance is achieved in considering physical infrastructure, technology, and human capital. In providing leadership prior to the emergency, leaders demonstrate their commitment to human capital by establishing plans that value the organization’s intention to manage employees with sensitivity to their individual circumstances, recover essential operations on a priority basis, and resume other operations as quickly as possible.

Organizational leaders show commitment to continuity planning by allocating resources and setting policies that effectively meet the organization’s continuity needs. The experts told us that committed leaders provide sufficient funding and staff to conduct planning and preparation efforts effectively. While the resources needed vary from location to location within an organization, the experts said that organizations should have enough resources available to develop effective plans, test critical systems, train all staff, and conduct simulation exercises. Committed top leadership also ensures that clear policies and procedures are in place for all aspects of continuity to ensure that quick and effective decisions are made during times of emergencies. Those policies and procedures should be fair, shared with employees and their representatives in advance of an emergency, and able to be consistently applied to all employees. Experts and union leaders we met with agree that the cooperation and input from all components within the organization, including employees and their representatives, is important in developing these policies.

Following a disruption to normal operations, top leadership sets the direction and pace of organizational recovery. According to the experts, top leadership sets direction by providing the legitimate and identifiable voice of the organization for employees to rally around during tumultuous times. An expert from Marsh & McLennan Companies, Inc., a company that lost over 350 people in the World Trade Center on September 11, 2001, noted that in the aftermath of an emergency there is a fundamental need for a strong, visible leader to provide constant reassurance. The expert added that “employees need to know that someone is in control, even if the leaders do not know all the answers.” In addition, top leaders set the pace of organizational recovery by providing leadership to both the management team leading recovery of essential operations and the management team leading the resumption of all other operations.

As we have previously reported, effective organizations integrate human capital approaches as strategies for accomplishing their mission and programmatic goals. According to the experts, strategic decisions made to improve day-to-day operations, including human capital approaches, and those made to build continuity readiness are not exclusive of one another and may have synergies. For example, early in 2001, GAO made the business decision to supply all of its analysts with laptop computers for financial reasons and to provide employees with flexibility in carrying out their work. That business decision, however, also contributed to our ability to quickly adapt to unforeseeable circumstances in October 2001. In response to the release of anthrax bacteria on Capitol Hill, we opened our doors to the 435 members of the House of Representatives and selected members of their staffs. Over 1,000 GAO employees were immediately able to make use of their laptops to work from alternate locations. Consequently, we minimized the disruption to our operations and assisted the House of Representatives in continuing its operations. To take advantage of such synergies, the experts said that decisions regarding continuity efforts should be integrated with broader business decision making.

The integration of continuity planning with broader decision making helps to ensure that the direction of all efforts is consistent and provides mutual benefits. In a limited resource environment, consideration of how continuity investments benefit other program efforts also helps to strengthen the business case for human capital investments that are meant to improve continuity capabilities, day-to-day operations, or both.

The importance of communication cannot be overstated. According to the experts, two-way communication with employees, their representatives, and other stakeholders is key to building relationships and partnerships that can facilitate organizational recovery efforts. We have also previously reported that communication is most effective when done early, clearly, often, and is downward, upward, and lateral. According to a senior National Treasury Employees Union (NTEU) official, the union was able to capitalize on ongoing two-way communications with the Internal Revenue Service’s (IRS) regional leadership to provide members with information following the September 11, 2001, attacks. For example, during the recovery efforts, the union provided supplementary channels for communicating with employees, including daily joint messages from the IRS Regional Director and the NTEU Chapter President. In addition, when the local New York office reopened on September 20, 2001, both the NTEU National President and the IRS Commissioner greeted employees at the door. From the union’s perspective, communication efforts such as these helped to provide reassurance and support as well as to maintain employee trust.

According to experts, roles, responsibilities, and performance expectations must be communicated to all employees, and their representatives, prior to a disruption to promote the efficient and effective use of all of an organization’s human capital assets. Early communication enables employees to assess and communicate to the organization any personal circumstances that may limit their ability to carry out those roles. The experts and union officials whom we spoke with agreed that in some cases, more formal communication vehicles, such as memorandums of understanding or addenda to collective bargaining agreements, may be necessary to negotiate changes or clarify roles and responsibilities in continuity plans.

Because effective emergency two-way communication depends greatly on technology, alternate and redundant communication infrastructures are necessary. In addition to technological vulnerabilities that can render different methods of communication useless, people frequently do not remain tied to the contact number or location listed in emergency records. To address these challenges, Macy’s West, for example, has built an alternate emergency communication system that serves as an employee message retrieval system. The system, which is based outside of the region in case the local phone networks are overloaded, allows (1) the leadership of Macy’s West to leave messages with instructions for employees, (2) family members to leave messages for employees, and (3) employees to leave messages for their loved ones.

Our past work has shown that organizations should consider making targeted investments in human capital approaches, such as training and development. According to the experts, training and development programs related to continuity efforts can help to raise awareness among all employees. The Social Security Administration (SSA), for example, has developed a video-training course to provide an overview of COOP, which includes an introduction from the Commissioner explaining why COOP is so important, a discussion of SSA’s critical workloads and how they would be processed during a disruption, and references to federal guides and information. The experts noted that less formal approaches, such as continuity planning awareness weeks, could also help to raise awareness.

Our recent work has indicated that training and development programs build skills and competencies that enable employees to fill new roles and work in different ways, which helps to build organizational flexibility. According to experts, the training and development goals for employees assigned to the team that performs essential operations differ from those for the employees assigned to the team that is responsible for resuming all other organizational operations. The goal for the team that performs essential operations is to achieve “critical depth,” which occurs when an adequate number of employees are available to staff each critical function, in the event that a member of the team expected to perform that function is unavailable. Organizations can build critical depth in various ways, including using exercises that simulate an emergency to train backup employees alongside employees who have primary responsibility for an essential operation, or allowing backup employees to perform the operation while the primary employees oversee and critique their performance. In addition, critical depth can be built through succession planning. To be effective for this purpose, however, the scope of succession planning is extended to recognize that there is no time to develop successors in an emergency and incrementally increase levels of authority as an individual matures in a position. Therefore, organizations may have to plan to use predecessors to a position, including retirees, as successors.

With regard to the team that is responsible for resuming all other organizational operations, experts said that the training and development goal is to build sufficient breadth to enable members to contribute to resumption efforts in a variety of ways. For example, development programs requiring employees to rotate within an organization to learn a variety of positions, potentially at a variety of locations, contribute to critical breadth. We have previously reported that developmental assignments place employees in new roles or unfamiliar job environments in order to strengthen skills and competencies and broaden their experience.

Effective training and development initiatives also help to foster a culture that is characterized by flexible employees who are empowered to make effective decisions independently. According to experts, such a culture is often critical to agency recovery and resumption efforts. Experts from Marsh & McLennan Companies, Inc., reported that effective decision- making abilities could be developed through formal training about the parameters in which employees are empowered to make decisions and on- the-job experiences demonstrating how employees can exercise authority in making decisions that manage, rather than avoid, risk and are focused on achieving results.

The events of September 11, 2001, give ample evidence of the dedication and flexibility of federal, state, and local government employees in providing services to the American public. Disruption of normal operations challenges an organization to use this dedication and flexibility to its advantage, especially with regard to employees associated with the resumption of all operations that are not considered essential. According to the experts, organizations may use approaches such as telework and geographic dispersion, which includes regional structure, to increase the ways in which employees may contribute. As OPM guidance has underscored and presenters at a recent conference held by the International Telework Association and Council noted, telework is an important and viable option for federal agencies in COOP planning and implementation efforts, especially as the duration of the emergency event is extended. However, to make effective use of telework, experts told us that organizations should identify those employees who are expected to telework during a disruption and communicate that expectation to them in advance. In addition, organizations should provide teleworkers with adequate support in terms of tools, training, and guidance. Geographic dispersion can also provide a way for employees associated with resumption activities to continue their normal functions albeit at or through other locations. For example, SSA recognizes that its field structure enables the agency to make use of both multiple locations and telework in providing its employees ways to contribute because most field functions can be transferred fairly easily from one location to another in the same region or performed remotely with laptop computers. Based on these efforts, SSA does not envision a scenario in which its field employees would not contribute to their normal functions for more than 72 hours.

Employees demonstrate their flexibility by a willingness to contribute to the organization in roles that may be unusual. According to the experts, flexible employees contribute as best they can usually in the following sequence: (1) providing support to the team performing essential operations, if needed; (2) continuing to contribute to their normal mission- related functions; (3) performing an alternate contribution for their organization; or if none of these can be accomplished, (4) volunteering in their communities as a direct form of public service. Federal employees may have additional opportunities to contribute to not only their own agencies’ operations but also other agencies’ operations in serving the American people. In addition, a recent memorandum from OPM recognizes the value of federal employees contributing to the general public through community volunteer service in the range of alternative contributions.

Employees associated with providing essential operations may be working under unusual pressures for extended periods of time, and organizations need to consider ways to sustain these efforts. The experts recommend that if the circumstances of the emergency continue long enough to raise concerns about burnout, organizations consider providing opportunities for working in shifts; rotating assignments among team members; providing relief through the use of qualified employees associated with resumption activities; reemploying retirees; or utilizing employees from stakeholder or networked organizations, such as suppliers or contractors.

According to the experts, the ability of organizations to match staffing requirements with available skills and abilities could be enhanced through various initiatives, such as job banks, skill profile databases, and pre- arranged partnerships with other organizations or community service organizations. For example, job banks that detail additional jobs that may be required during an emergency but are not considered essential could allow employees to preselect alternate contributions that they would be able to perform. In the federal government, agencies could establish their own job banks; form interagency partnerships that link the potential needs of several agencies; and create a cache for volunteer opportunities, possibly tied to the Citizen Corps. Organizations with databases that collect employee knowledge, skills, and abilities (KSA)—even those KSAs outside the scope of an employee’s normal functions—may complement the job banks by allowing organizations to match available KSAs with the unmet needs of the organization.

An evaluation process that explicitly identifies and disseminates lessons learned during disruptions, or simulations of disruptions, promotes learning among all of an organization’s human capital assets and helps to improve organizational performance. An organization that is committed to learning has an inclusive and supportive process and a framework designed prior to a disruption to gather important data. According to experts, organizations committed to learning will ensure that those employees who are key to the recovery and resumption efforts are involved in the formal evaluation process in a timely manner and will seek the input from as many other employees as possible. Such an inclusive environment will enable the organization to discover valuable lessons learned by employees in unusual circumstances. In addition, conducting evaluations in a “no- blame,” nonattribution atmosphere and taking organizational ownership of any problems that might be identified increases the openness with which participants are willing to share their experiences. To encourage such an environment, FEMA officials told us that the agency’s Office of National Security Coordination has recently implemented a reporting system that allows any employee to identify lessons learned anonymously during an emergency, instead of waiting for the formal review process.

Our past work has shown that human capital approaches are best designed and implemented based on data-driven decisions. According to experts, having a framework prior to a disruption helps to gather data important to evaluating the effectiveness of human capital approaches during a disruption. Some measures that they suggested include number of employees contributing to mission-related outcomes each day; degree of contribution (e.g., part time or full time); location of employee when contributing (e.g., at alternate facility or home); type of contribution (e.g., performing same function, performing an alternate function within the department, working with another department, or volunteering); or obstacles to contribution (e.g., organizational or personal).

Once identified, it is important for the lessons learned during the evaluation to be made explicit and then widely disseminated. According to experts, the manner and formality of documentation and dissemination, however, depend on the situation or needs of the organization (e.g., after- action reports, detailed analyses, executive summaries, video tapes, CDs, or Web-based reports). There are unique opportunities in the federal government for agencies to share explicit lessons learned both internally and with other federal agencies and stakeholders. For example, following the September 11, 2001, attacks, senior Department of Housing and Urban Development officials asked the New York Acting Regional Director to recount her experiences and lessons learned in front of a video camera. The accounts were edited down into a 30-minute video entitled Thinking the Unthinkable: Preparing for Disaster. That video has been used within the department as a training aid and has been shared with over 50 federal agencies with the help of the Washington, D.C.–based interagency COOP Working Group (CWG) and the FEBs in cities across the United States. In Canada, Emergency Management Alberta (EMA) employs a centralized Disruption Incident Reporting System for all government agencies, which is accessible via the Internet, to obtain timely and accurate reporting of all disruptions and “most importantly, ensure lessons learned can be documented for follow-up.” EMA has also created a Lessons Learned Warehouse Web site to share continuity lessons learned in all aspects of crisis management.

FEMA and OPM Have Exhibited Leadership in Addressing Human Capital Considerations Relevant to COOP

As we stated earlier, the human capital considerations related to life safety and the needs of personnel performing essential operations have largely been addressed in continuity efforts. In the federal government, FEMA has issued guidance that has addressed these considerations and has recognized the opportunity to more fully address human capital considerations in its guidance. In addition, OPM has issued federal emergency preparedness guidance relevant to COOP that also addresses these considerations and is working with FEMA to more fully address human capital considerations in federal guidance.

FEMA Issued Guidance That Addresses Human Capital Considerations, but Recognizes Opportunity to Do More

As executive agent for federal COOP planning, FEMA issued FPC 65 in July 1999 as the primary guidance for agencies developing viable COOP plans. According to FPC 65, the purpose of COOP planning is to facilitate the performance of agency essential functions for up to 30 days during any emergency or situation that may disrupt normal operations. The five objectives of a viable COOP plan listed in FPC 65 are (1) ensuring the continuous performance of an agency’s essential functions during an emergency; (2) protecting essential facilities, equipment, records, and other assets; (3) reducing or mitigating disruptions to operations; (4) reducing loss of life, minimizing damage and losses; and (5) achieving a timely and orderly recovery from an emergency and resumption of full service to customers.

The guidance subsequently limits a COOP event to one that significantly affects the facilities of an organization and requires the establishment of essential operations at an alternate location. Therefore, as FEMA recognizes, the guidance does not apply to significant disruptions that leave facilities intact, such as a severe acute respiratory syndrome (SARS) outbreak that could lead a large number of employees to avoid congested areas, including their workplaces. Although a people-only event such as SARS would significantly disrupt normal operations, the current COOP guidance would not apply because facilities would remain available. FPC 65 also indicates that the guidance is for use at all levels and locations of federal agencies. FEMA officials acknowledge, however, that the priority of COOP planning to date has been focused on agency headquarters located in the Washington, D.C., area.

Given the purpose of COOP and the nature of its objectives, the human capital considerations FEMA included in the guidance primarily relate to life safety for all employees and addressing the needs of employees performing essential operations. For example, the guidance states that one of the objectives of COOP is “reducing loss of life, minimizing damage and losses.” It also refers to the legal requirement that each agency develop a viable OEP, which is a short-term emergency response program that establishes procedures for safeguarding lives and property during emergencies in particular facilities. FPC 65 more broadly defines life safety by including a statement related to the need to consider the health and emotional well-being of employees on the essential operations team. Also, with respect to employees who perform essential functions, the guidance directs agencies to designate an emergency team, delegate authority, establish orders of succession, develop communication plans, develop training programs, and provide for accountability.

FEMA officials we spoke with recognized that there is a need to go beyond the human capital considerations that have already been addressed within federal COOP guidance in order to achieve the full range of COOP objectives. Specifically, FEMA officials agreed that it was particularly important to deal with the human capital considerations inherent to the resumption activities needed to fully recover from an emergency. To that end, FEMA has taken several steps to more fully address these considerations. FEMA has worked with a subcommittee of the interagency CWG—a Washington, D.C.–based group that meets monthly to discuss issues related to COOP—to rewrite the federal COOP guidance. The agency has requested OPM’s assistance in incorporating these considerations into the new federal COOP guidance. FEMA has also worked in cooperation with us as we developed this report. As a result, FEMA officials told us that the draft guidance would include an augmented discussion of human capital considerations.

OPM Has Also Exhibited Leadership in Addressing Human Capital Considerations Related to Emergency Preparedness

OPM has also recognized the value of human capital in COOP and other emergency preparedness efforts. In a memorandum to the heads of executive departments and agencies, for example, the Director of OPM stated that “the American people expect us to continue essential government services without undue interruption, no matter the contingency, and Federal agencies must have the human resources to accomplish their missions, even under the most extreme of circumstances.” To this end, OPM has established the Emergency Preparedness subcommittee of the Chief Human Capital Officers Council that is tasked with recommending policy changes, legislative changes, or other strategies for moving the issue forward. In addition, OPM has initiated several efforts to help agencies address human capital considerations in emergency preparedness related to life safety and the needs of personnel performing essential operations, as well as to recognize the role that employee organizations and unions could play in supporting those efforts. These initiatives are important first steps; however, they do not fully address human capital considerations related to the resumption of all agency operations that are not considered essential.

With regard to providing for the safety of all employees, OPM has issued four preparedness guides to educate federal employees, managers, and their families on how to protect themselves from a potential biological, chemical, or radiological release, whether accidental or intentional. The guides also spell out the responsibilities of the federal government and individual agencies to protect employees in the event of an emergency. In addition to the guides, OPM has addressed safety issues by revising the Washington, D.C., area emergency dismissal protocols for federal employees and contractors, in conjunction with FEMA and GSA; issuing memorandums to all agency heads detailing the “minimum obligations” agencies have to secure the safety of federal workers; issuing two emergency preparedness surveys through which federal agencies could report on their progress in ensuring the safety of their employees; and highlighting the role that Employee Assistance Programs can play in responding to employee needs in emergency situations.

Related to providing for the needs of employees performing or supporting essential operations, OPM has led two forums focusing on emergency employee designations and the flexibilities that are available to agencies in emergency situations. OPM has also issued a series of memorandums outlining the existing human resource management flexibilities that agencies might employ in emergency situations. Other human capital flexibilities that are available to agencies in nonemergency situations, such as telecommuting, job sharing, and flexible scheduling, might provide additional assistance during emergency situations and are detailed in OPM’s handbook, Human Resources Flexibilities and Authorities in the Federal Government. (See app. II for a list of human resource flexibilities that agencies may use to respond to emergency situations.)

In addition to initiating efforts to address several human capital considerations, OPM has highlighted the need to work with and through employee organizations and unions in developing and executing emergency management strategies. For example, OPM has held meetings with federal labor union leaders and employee associations to discuss relevant employee safety issues and has specifically encouraged agencies to work with and share information on preparedness efforts with applicable employee organizations and unions. Senior union officials whom we spoke with from the American Federation of Government Employees and NTEU agreed that it is important for unions to be involved throughout COOP planning and implementation efforts. These officials also stated that unions could be resources for agencies in communicating with employees, both before and during an emergency, as well as in engaging employees in recovery and resumption efforts.

FEBs Have Opportunities to Coordinate Regional Emergency Planning Efforts, Including COOP, in Major Metropolitan Areas

Although FEMA heads the interagency CWG to help coordinate COOP efforts in the Washington, D.C., area, the efforts of this group do not apply to the over 80 percent of federal employees who work outside of this area. While not specifically tasked with coordinating COOP efforts, FEBs are generally responsible for improving coordination among federal activities and programs in major metropolitan areas outside of Washington, D.C. Under the direction of OPM, FEBs support and promote national initiatives of the President and the administration and respond to the local needs of federal agencies and the community. OPM officials have recognized that FEBs can add value to regional emergency preparedness efforts, including COOP, as vehicles for communication, coordination, and capacity building. To make use of these capabilities, OPM has provided FEBs with relevant emergency preparedness materials, encouraged FEBs to focus on preparedness issues in their regions, requested that FEBs test their emergency communication plans, and encouraged FEBs to inform OPM of any emergency-related events affecting federal employees in the regions.

The FEBs that we visited are already playing active roles in regional emergency preparedness and COOP efforts. For example, the Chicago FEB has established committees to deal with Disaster Recovery Planning and Emergency Release; surveyed its member agencies to determine the status of COOP planning in the region; sponsored a series of seminars, in conjunction with GSA and FEMA, on topics related to COOP, sheltering in place, and national security; participated in regional exercises, such as TOPOFF 2; and sponsored a COOP exercise to provide agencies with a forum for validating their COOP plans, policies, and procedures. The Cleveland FEB has established an emergency preparedness committee to promote awareness and preparation, developed an Employee Emergency Contingency Handbook that provides basic actions to respond to emergencies that may be encountered by federal employees, and helped to make training available to all federal agencies. The Philadelphia FEB has held several COOP workshops for agencies and regularly shares relevant information with agency officials via e-mail. In addition, these FEBs play a role in developing and activating dismissal and closure procedures for federal agencies located in their particular regions.

Although both OPM officials and the FEB officials whom we spoke with recognized that FEBs can add value in coordinating emergency preparedness efforts, including COOP, and that such a role is a natural outgrowth of general FEB activities, a specific role and responsibilities have not been defined. In addition, the current structure in which FEBs operate results in differing capacities of FEBs across the nation. For example, each agency’s participation in FEB activities is voluntary. Consequently, FEBs can only make recommendations to agencies, without the ability to require agency compliance. Also, FEBs rely on host agencies for funding, which results in variable funding and staffing from year to year and across FEBs. OPM has recognized that the roles and capacities of FEBs vary across the nation and has established an internal working group to study the strengths and weaknesses of FEBs and develop recommendations for improving their capacity to coordinate in regions outside of Washington, D.C. According to OPM, such efforts in regard to local emergency preparedness and response will include improving dissemination of information and facilitation of COOP training and tabletop exercises; addressing the implications for strategic human capital management in continuing the operations of the federal government (e.g., alternate work schedules, remote work sites, and telecommuting capabilities); and developing strategies to better leverage the network of FEBs to help departments and agencies implement their initiatives.

Conclusions

More fully addressing human capital considerations in emergency preparedness guidance, including COOP, could improve agency response capabilities to large-scale COOP emergencies or situations; could help minimize the impact of more common, yet less catastrophic disruptions (e.g., snowstorms and short-term power outages); and is consistent with building a more flexible workforce, which would enhance ongoing efforts across the federal government to create more responsive human capital management systems. As FEMA works to update its federal COOP guidance and OPM continues to issue emergency preparedness guidance relevant to COOP, several areas require attention to more fully address human capital considerations relevant to COOP.

By limiting COOP to situations that necessitate moving to an alternate facility, agencies are left without guidance for situations in which an agency’s physical infrastructure is unharmed, but its employees are unavailable or unable to come to work for an extended period of time. While facilities and technology would not be affected by such situations, the unavailability of people to contribute to mission-related outcomes could cause a significant disruption to normal operations.

Emergency guidance, including COOP, generally does not extend beyond consideration of life safety and the needs of employees performing essential operations. Therefore, the guidance excludes most agency employees—those who would be associated with resuming all other operations.

FEBs are uniquely situated to improve coordination of emergency preparedness efforts, including COOP, in areas outside of Washington, D.C. However, the context in which FEBs currently operate, including the lack of a clearly defined role in emergency preparedness efforts, including COOP, and varying capacities among FEBs, could lead to inconsistent levels of preparedness across the nation.

Recommendations for Executive Action

We recommend that the Secretary of Homeland Security direct the Under Secretary for Emergency Preparedness and Response to take the following two actions: Expand the definition of a COOP event in federal guidance to recognize that severe emergencies requiring COOP implementation can include people-only events.

Complete efforts to revise federal COOP guidance to more fully address human capital considerations by incorporating the six organizational actions identified in this report.

We recommend that the Director of OPM take the following two actions: Develop and provide additional emergency preparedness guidance to more fully address human capital considerations by incorporating the six organizational actions identified in this report.

Determine the desired role for FEBs to play in improving coordination of emergency preparedness efforts, including COOP, and identify and address FEB capacity issues to meet that role. It would be appropriate for FEBs to be formally incorporated into federal emergency preparedness guidance, including COOP guidance, for areas outside of Washington, D.C.

Agency Comments and Our Evaluation

We provided the Secretary of Homeland Security and the Director of OPM a draft of this report for review and comment. We received written comments from the Under Secretary of Emergency Preparedness and Response on behalf of FEMA and the Department of Homeland Security, which are reprinted in appendix III. In his comments, the Under Secretary stated that the draft accurately addressed human capital considerations relevant to COOP guidance and coordination and noted that DHS and FEMA will continue to work with OPM and other federal partners to improve the federal government’s COOP plan by incorporating our recommendations in its federal COOP guidance. In addition, he stated that FEMA would expand its efforts with its regional offices and FEBs to improve coordination of COOP programs at the regional level.

The Director of OPM also provided written comments, which are reprinted in appendix IV. In her comments, the Director noted her appreciation for our acknowledgement of the agency’s leadership role in addressing human capital considerations relevant to COOP planning. However, the Director of OPM stated that the agency has already carried out our recommendation to more fully address human capital considerations in emergency preparedness guidance, including COOP, by incorporating the key actions identified in the report. The Director provided numerous examples of actions OPM has taken to support emergency preparedness efforts, all of which she noted were influenced by the agency’s human capital framework. In addition, the Director also attached an enclosure to the agency comments that contain examples of OPM’s internal COOP-related efforts that she believes would be helpful to federal agencies.

Most of the examples of emergency preparedness guidance that the Director of OPM provided were included in the draft report and deal largely with the human capital considerations related to life safety and the needs of personnel performing essential operations. While such initiatives are important first steps, there remain opportunities to improve OPM’s emergency preparedness guidance to include a fuller range of human capital considerations, particularly related to the resumption of all agency operations that are not considered essential. As such, our assessment of OPM’s guidance and our recommendation for the agency to develop and provide additional emergency preparedness guidance that incorporates the key actions identified in the report remain unchanged.

With regard to our second recommendation for OPM to determine the desired role of FEBs in improving coordination of emergency preparedness efforts, including COOP, and address any resulting capacity issues, the Director of OPM stated that the leadership role the agency plays with respect to FEBs was not sufficiently developed in the report and she provided examples of OPM’s support for the FEB’s efforts. Most of the supporting examples that the Director provided were included in the draft report. Moreover, the additional examples generally do not address our larger point that the role of FEBs in coordinating emergency preparedness efforts, including COOP, needs to be clearly defined. As such, we maintain our conclusion that the context in which FEBs currently operate, including the lack of a clearly defined role in emergency preparedness efforts and the varying capacities among FEBs, could lead to inconsistent levels of preparedness across the nation.

The Director of OPM suggested several clarifications to the report, which we considered and incorporated where appropriate. For example, she suggested both technical and substantive changes to a footnote describing Federal Executive Associations (FEA) and Federal Executive Councils (FEC). While we made technical changes in response to these comments, our work does not allow us to categorically exclude all FEAs and FECs as viable options for the coordination of emergency preparedness activities, as the Director suggested in her response. Instead, we recognize that any guidance provided to FEBs would likely be beneficial to FEAs and FECs despite their differences. The Director also provided additional details describing OPM’s internal working group that is studying the strengths and weaknesses of FEBs, and we have incorporated these details into the report.

We are sending copies of this report to the Ranking Minority Member, Subcommittee on Oversight of Government Management, the Federal Workforce, and the District of Columbia, Senate Committee on Governmental Affairs; the Chairman and Ranking Minority Member, House Committee on Government Reform; the Chairman and Ranking Minority Member, Subcommittee on Homeland Security, House Committee on Appropriations; the Chairman and Ranking Minority Member, Subcommittee on National Security, Emerging Threats, and International Relations, House Committee on Government Reform; and other interested congressional parties. We will also send copies to the Secretary of Homeland Security, the Under Secretary of Emergency Preparedness and Response and the Director of OPM. This report will also be available at no charge on the GAO Web site at http://www.gao.gov.

If you or your staff have any questions concerning this report, please contact me or William Doherty on (202) 512-6806. Key contributors to this report include Kevin J. Conway, Tiffany Tanner, Thomas Beall, Amy Choi, Amy Rosewarne, John Smale, and Michael Volpe.

Objectives, Scope, and Methodology

The objectives of this report were to identify the human capital considerations that are relevant to federal agencies’ continuity planning and implementation efforts; describe the continuity of operations (COOP) guidance provided by the Federal Emergency Management Agency (FEMA) and emergency preparedness guidance and activities of the Office of Personnel Management (OPM) to address human capital considerations relevant to COOP; and describe the role Federal Executive Boards (FEB) play, relevant to COOP, in coordinating efforts outside of the Washington, D.C., area.

To address human capital considerations that are relevant to continuity planning and implementation efforts, we reviewed relevant literature, such as industry journals, federal guidance, and codes of standards on disaster/emergency management and continuity programs. Because the available literature was limited in its attention to human capital, we based our work primarily on semistructured interviews with experts from private sector businesses, federal government agencies, and public institutions. We first reviewed industry journals, magazines, and Web sites; queried state and international auditors; attended a national business continuity conference; and sought input from the National Academy of Public Administration (NAPA), the Private Sector Council (PSC), and FEMA to identify individuals or organizations with the relevant knowledge needed to address our first objective. We selected individuals or organizations that had one or more of the following characteristics: (1) experience responding to, recovering from, and resuming business activities following an emergency, from which human capital lessons may have been drawn; (2) experience incorporating human capital considerations into their organization’s continuity planning efforts; (3) specific human capital expertise that could be applied to continuity planning and implementation efforts; and (4) specific continuity expertise that is broad enough to identify those critical areas that require human capital attention. When an organization was selected, we then contacted the organization to identify the specific individuals who had the relevant expertise.

On the basis of these characteristics and the input from NAPA, PSC, and FEMA, we selected organizations or individuals within organizations to obtain a diversity of views from both the public and private sector. Individuals from a total of 15 organizations, in addition to FEMA, provided their expertise in addressing our objective. The organizations include five federal agencies—the Centers for Disease Control and Prevention, the Department of Housing and Urban Development, the Department of Veterans Affairs, the General Services Administration, and the Social Security Administration; five private sector businesses—the Gillette Company, Lockheed Martin Corporation, Macy’s West, Marsh & McLennan Companies, Inc., and Science Applications International Corporation; and five public institutions—the Business Continuity Institute, the Disaster Recovery Institute International, Emergency Management Alberta (Canada), Clark-Atlanta University, and the University of Tasmania (Australia).

We then conducted three cycles of work to identify the human capital considerations that are relevant to continuity, with each subsequent cycle building upon the information gathered in previous cycles. We adopted this approach because our initial conversations with experts indicated that a common perspective of the continuity process could help structure and focus our subsequent interviews with experts about the relevant human capital considerations. Cycle one involved conducting semistructured interviews with experts from FEMA and 5 of the 15 organizations. We asked each to describe a view of the entire continuity process from a human capital perspective. We used those descriptions to synthesize a framework that we then shared with each of the first cycle experts for comment. The experts generally agreed with the content of the framework and agreed that it would be useful in focusing subsequent interviews about human capital considerations. In the second cycle, we used this framework as a reference when conducting in-depth, semistructured interviews with experts from all 15 organizations and FEMA about the human capital considerations relevant to continuity. For the third cycle, we held a 1-day working group, in cooperation with FEMA, to more fully discuss the human capital considerations previously identified in cycles one and two. The interactive nature of the working group, which included a cross-section of the experts and additional representatives from GAO, helped to ensure that we had adequately captured the key considerations relevant to continuity. As a final check, we provided all of the experts with a summary document that included the statements used throughout this report and attributed to the experts. We asked the experts to review the statements for fundamental disagreement or fatal flaws. Almost all experts responded and generally agreed with our treatment of these issues.

To supplement information we received in the three cycles, we held additional interviews with officials from OPM; representatives from the Chicago, Cleveland, and Philadelphia FEBs; and representatives from the National Treasury Employees Union (NTEU) and the American Federation of Government Employees (AFGE). We spoke with representatives of the FEBs because the FEBs’ role as coordinative bodies in regions across the nation gives them a unique view of federal emergency preparedness efforts outside of the Washington, D.C., area. We spoke with representatives from NTEU and AFGE because unions can play a key role in addressing human capital considerations.

To describe the COOP guidance provided by FEMA and emergency preparedness guidance and activities of OPM to address human capital considerations relevant to COOP, we interviewed officials from both agencies. In addition, we reviewed and analyzed relevant documents. For example, we reviewed Federal Preparedness Circular 65, the primary guidance for federal executive branch COOP, to identify the human capital considerations that are included in federal COOP guidance. We also reviewed OPM publications, including four emergency preparedness guides and a series of memorandums that list available agency flexibilities in times of emergencies.

To describe the role FEBs play, relevant to COOP, in coordinating efforts outside of the Washington, D.C., area, we held interviews with officials from OPM with responsibility for FEBs nationwide and representatives from the three FEBs discussed above.

We conducted our work from February 2003 through December 2003 in accordance with generally accepted government auditing standards.

Emergency Human Capital Flexibilities Listed in OPM Emergency Memorandums

OPM has issued a series of memorandums outlining the existing human resources management flexibilities that executive departments and agencies might employ in emergency situations with and without OPM approval. Other human capital flexibilities and programs, such as those detailed in OPM’s handbook, Human Resources Flexibilities and Authorities in the Federal Government, that are available to agencies in nonemergency situations may also provide additional assistance in responding to and recovering from COOP emergencies. For additional information on these flexibilities, OPM has advised that agency chief human capital officers, human resources (HR) directors, or both should contact their assigned OPM human capital officer. Employees are advised to contact their agency HR offices for assistance.

A compilation of the emergency flexibilities outlined by OPM in its emergency guidance memorandums appears below.

Leave

Excused Absence

Agencies have the discretion, without OPM approval, to grant excused absence to employees who are prevented from reporting to work because of an emergency. The authority to grant excused absence also applies to employees who are needed for emergency law enforcement, relief, or recovery efforts authorized by federal, state, or local officials having appropriate jurisdiction and whose participation in such activities has been approved by the employing agency. Military leave under 5 U.S.C. § 6323(b) is appropriate for federal employee members of the National Guard or Reserves who are called up to assist in an emergency.

Emergency Leave Transfer Program

Subject to approval by the President, OPM may establish an emergency leave transfer program, which is separate from the federal leave-sharing program, to assist employees affected by an emergency or major disaster. Under 5 U.S.C. § 6391, the emergency leave transfer program would permit employees in an executive agency to donate unused annual leave for transfer to employees of the same or other agencies who have been adversely affected by an emergency and who need additional time off work without having to use their own paid leave. If agencies believe there is a need to establish an emergency leave transfer program to assist employees affected by an emergency, they are to contact their OPM human capital officer.

Pay

Premium Pay for Employees Performing Emergency Overtime Work

In certain emergency or mission-critical situations, agencies have the discretion, without OPM approval, to apply an annual premium pay cap instead of a biweekly premium pay cap, subject to the conditions set forth in 5 U.S.C. § 5547(b) and 5 C.F.R. § 550.106. In this regard, the agency head, his or her designee, or OPM may determine that an emergency exists. Agencies have the discretion, without OPM approval, to apply an annual cap to certain types of premium pay for any pay period for (1) employees performing work in connection with an emergency, including work performed in the aftermath of such an emergency, or (2) employees performing work critical to the mission of the agency. Such employees may receive premium pay under these conditions only to the extent that the aggregate of basic pay and premium pay for the calendar year does not exceed the greater of the annual rate for (1) General Schedule (GS)–15 step 10 (including any applicable special salary rate or locality rate of pay, or (2) level V of the Executive Schedule.

Furlough

In some emergency situations, agencies have the discretion, without OPM approval, to furlough employees, that is, to place them in a temporary status without duties and pay for nondisciplinary reasons. Under 5 C.F.R. § 752.404(d)(2), agencies are relieved of the requirement to provide employees advanced notice and an opportunity to respond when the furlough is based on “unforeseeable circumstances,” such as a sudden breakdown in equipment, an act of nature, or a sudden emergency requiring the agency to immediately curtail activities.

Benefits

Workers’ Compensation Benefits

Workers’ compensation benefits are available when federal employees are injured or killed while on duty. The Department of Labor may establish special procedures to provide direct assistance to affected employees and their families.

Expedited Processing of Retirement and Life Insurance Benefits

To assist agencies in responding to employee needs during and after an emergency situation, OPM may establish special expedited arrangements for processing disability retirement applications; survivor benefits; and payments under the Federal Employees Group Life Insurance Program, currently administered by the Metropolitan Life Insurance Company.

Death Gratuity

Under Section 651 of Pub. L. No. 104-208 (Omnibus Consolidated Appropriations Act, 1997), 5 U.S.C. § 8133 note, agencies have the authority, without OPM approval, to pay up to $10,000 to the personal representative of a civilian employee who dies in the line of duty.

Telework

Agencies have the discretion, without OPM approval, to approve telecommuting arrangements and alternative work sites to accommodate emergency situations. According to OPM, one of the major benefits of the telework program is the ability of telework employees to continue working at their alternative work sites during a disruption to operations. In recognition of the growing importance of teleworkers in the continuity of agency operations, OPM states that agencies may wish to modify their current policies concerning teleworkers and emergency closures. Agencies may also wish to require that some or all of their teleworkers continue to work at their alternative work sites on their telework day during emergency situations when the agency is closed. Although agencies would not have to designate a teleworker as an emergency employee, OPM states that any requirement that a telework employee continue to work if the agency closes on his or her telework day should be included in the employee's formal or informal telework agreement.

Emergency Hiring Flexibilities

Emergency Critical Hiring

Under 5 C.F.R. § 213.3102(i)(2), agencies have the discretion, without OPM approval, to fill positions for which an emergency or critical hiring need exists; however, initial excepted appointments under this authority may not exceed 30 days and may be extended only for an additional 30 days. Such an extension may be made only if the appointee’s continued employment would be essential to the agency’s operations.

Under 5 C.F.R. § 213.3102(i)(3), OPM may also grant agencies the authority to temporarily appoint individuals to the excepted service in positions for which OPM has determined that examination is impracticable (e.g., because of the time involved). For example, in the aftermath of the September 11, 2001, attacks, OPM granted agencies authority to fill positions affected by or that needed to deal with the attacks for up to 1 year, and later extended that authority.

When OPM grants agencies the authority to appoint individuals under 5 C.F.R. § 213.3102, agencies, not OPM, are responsible for establishing the qualifications that an individual must have to fill the position. In addition, in accordance with 5 C.F.R. pt. 330, agencies are not required to comply with the regulations regarding the Career Transition Assistance Plan (CTAP), Reemployment Priority List (RPL), and Interagency CTAP (ICTAP) because these regulations do not apply to excepted appointments.

Agencies have the discretion, without OPM approval, to use the authority granted by OPM under 5 C.F.R. § 213.3102 to fill senior-level positions, as well as positions at lower levels. Under appropriate circumstances, OPM may also authorize agencies to use a senior-level position allocation to appoint an individual under this section (5 C.F.R. § 319.104).

Direct-Hire Authority

Agencies have the authority to appoint candidates directly when OPM determines there is a critical hiring need, or a shortage of candidates, for particular occupations, grades (or equivalent), geographic locations, or some combination of the three. This authority can be governmentwide or limited to one or more specific agencies depending on the circumstances.

OPM has granted governmentwide direct-hire authority for GS-0602 Medical Officers, GS-0610 and GS-0620 Nurses, GS-0647 Diagnostic Radiologic Technicians, and GS-0660 Pharmacists, at all grade levels and all locations, and for GS-2210 Information Technology Specialists (Information Security) positions at GS-9 and above, at all locations, in support of governmentwide efforts to carry out the requirements of the Government Information Security Reform Act and the Federal Information Security Management Act. OPM also approved a direct-hire authority that permits agencies to immediately appoint individuals with fluency in Arabic or other Middle Eastern languages to positions in support of the reconstruction efforts in Iraq.

Agencies have the discretion, without OPM approval, to give individuals in the categories, occupations and specialties, and grades listed above competitive service career, career-conditional, term, temporary, emergency indefinite, or overseas limited appointments, as appropriate. In all cases, agencies must adhere to public notice requirements in 5 U.S.C. §§ 3327 and 3330 and ICTAP requirements.

If agencies believe they have one or more occupations for which an agency- specific direct-hire authority may be appropriate in support of emergency relief and recovery efforts, they are to contact their OPM human capital officer.

Senior Executive Service Limited Emergency Appointments

To meet a bona fide, unanticipated, urgent need, agencies have the authority under 5 C.F.R. § 317.601 to make Senior Executive Service limited emergency appointments of career employees, without OPM approval. OPM approval is required to appoint individuals who are not current career employees and OPM cannot delegate this authority; however, OPM will process such requests on a priority basis and will also consider temporary position allocations for agencies that identify the need as essential to deal with the emergency.

Reemploying Retirees

Agencies have the discretion, without OPM approval, to employ retirees to deal with an emergency, to replace employees called to active duty military service, or both. Agencies may immediately offer reemployment to retirees under any applicable appointing authority. However, generally, dual compensation restrictions (e.g., 5 U.S.C. §§ 8344 and 8468) require agencies to reduce the pay of a federal civil service retiree by the amount of his or her annuity. For details, see the CSRS and FERS Handbook for Personnel and Payroll Offices, Chapter 100 – Reemployed Annuitants.

OPM may waive these dual compensation restrictions and, upon request, may also delegate such authority to an agency head or designee to deal with emergency staffing requirements. See 5 C.F.R. pt. 553 for details. Dual compensation waivers cannot be approved retroactively. However, according to OPM guidance, annuitants who agree to work under salary offset pending a dual compensation waiver may be recognized for their special service by the agency through an individual cash award.

Reemploying Voluntary Separation Incentive Payment Recipients

Ordinarily, employees who resign or retire upon acceptance of a voluntary separation incentive payment (VSIP) (or buyout) can be reemployed only if they agree to repay the amount of that payment. However, upon agency’s request, OPM may waive the repayment requirement if the individual’s reemployment is necessary to deal with the emergency situation. (See 5 C.F.R. § 576.203(a)(1).) Persons being considered for VSIP repayment waivers must be the only qualified applicants available for the positions and possess expertise and special qualifications to replace persons lost or otherwise unavailable. Waivers may be limited by the agency’s specific statutory VSIP authority.

Other Emergency Hiring Flexibilities

Under 5 C.F.R. pt. 300, subpart E, agencies have the discretion, without OPM approval, to contract with private sector temporary employment firms for services to meet their emergency staffing needs. These contracts may be for 120 days and may be extended for an additional 120 days, subject to displaced employee procedures.

Agencies have the discretion, without OPM approval, to make competitive service appointments of 120 days or less without regard to CTAP, ICTAP, or RPL eligibles. These programs do not apply to such appointments. See 5 C.F.R., pt. 330, Subparts F and G for CTAP/ICTAP conditions and 5 C.F.R. § 330.207(d) for RPL conditions.

Agencies have the discretion, without OPM approval, to appoint current and former employees from RPL to temporary, term, or permanent competitive service appointments. Conversely, agencies may make exceptions to the RPL provisions to appoint others under 5 C.F.R. 330.207(d).

Comments from the Federal Emergency Management Agency

Comments from the Office of Personnel Management

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