DHS’s federal leadership role and responsibilities for emergency preparedness as defined in law and executive order are broad and challenging. To increase homeland security following the September 11, 2001, terrorist attacks on the United States, President Bush issued the National Strategy for Homeland Security in July 2002, and signed the Homeland Security Act in November 2002 creating DHS. The act centralized the leadership of many homeland security activities under a single federal department and, accordingly, DHS has the dominant role in implementing the strategy. As we noted in our review of DHS’s mission and management functions, the National Strategy for Homeland Security underscores the importance for DHS of partnering and coordination. For example, 33 of the strategy’s 43 initiatives are required to be implemented by 3 or more federal agencies. If these entities do not effectively coordinate their implementation activities, they may waste resources by creating ineffective and incompatible pieces of a larger security program. In addition, more than 20 Homeland Security Presidential Directives (HSPDs) define DHS’s and other federal agencies’ roles in leading efforts to prepare for and respond to disasters, emergencies, and potential terrorist threats. Directives that focus on DHS’s leadership role and responsibilities for homeland security include HSPD-5 and HSPD-8 which are summarized below: Homeland Security Presidential Directive-5 (HSPD-5), issued on February 28, 2003, identifies the Secretary of Homeland Security as the principal federal official for domestic incident management and directs him to coordinate the federal government’s resources utilized in response to or recovery from terrorist attacks, major disasters, or other emergencies. The Secretary of DHS, as the principal federal official, is to provide standardized, quantitative reports to the Assistant to the President for Homeland Security on the readiness and preparedness of the nation—at all levels of government—to prevent, prepare for, respond to, and recover from domestic incidents and develop and administer a National Response Plan (NRP). To facilitate this role, HSPD-5 directs the heads of all federal departments and agencies to assist and support the Secretary in the development and maintenance of the NRP. (The plan was recently revised and is now called the National Response Framework. Homeland Security Presidential Directive-8 (HSPD-8), issued in December 2003, called for a new national preparedness goal and performance measures, standards for preparedness assessments and strategies, as well as a system for assessing the nation’s overall preparedness. According to the HSPD, the Secretary is the principal federal official for coordinating the implementation of all-hazards preparedness in the United States. In cooperation with other federal departments and agencies, the Secretary coordinates the preparedness of federal response assets. In addition, the Secretary, in coordination with other appropriate federal civilian departments and agencies, is to develop and maintain a federal response capability inventory that includes the performance parameters of the capability, the time (days or hours) within which the capability can be brought to bear on an incident, and the readiness of such capability to respond to domestic incidents. Last year, the President issued an annex to HSPD-8 intended to establish a standard and comprehensive approach to national planning and ensure consistent planning across the federal government. After the hurricane season of 2005, Congress passed the Post-Katrina Emergency Management Reform Act of 2006, that, among other things, made organizational changes within DHS to consolidate emergency preparedness and emergency response functions within FEMA. Most of the organizational changes, such as the transfer of various functions from DHS’s Directorate of Preparedness to FEMA, became effective as of March 31, 2007. According to the act, the primary mission of FEMA is to: “reduce the loss of life and property and protect the Nation from all hazards, including natural disasters, acts of terrorism, and other man-made disasters, by leading and supporting the Nation in a risk-based, comprehensive emergency management system of preparedness, protection, response, recovery, and mitigation.” The act kept FEMA within DHS and enhanced FEMA’s responsibilities and its autonomy within DHS. As a result of the Post-Katrina Act, FEMA is the DHS component now charged with leading and supporting the nation in a risk- based, comprehensive emergency management system of preparedness, protection, response, recovery, and mitigation. DHS has taken action to define national roles and responsibilities and capabilities for preparedness and response which are reflected in several key policy documents: the National Response Framework, (what should be done and by whom); the National Incident Management System (NIMS) (how it should be done), and the National Performance Guidelines (how well it should be done). To implement requirements of the Homeland Security Act of 2002 and HSPDs 5 and 8, DHS issued initial versions of these documents in 2004 (NIMS and the National Response Plan) and 2005 (National Preparedness Goal) and has developed and issued revisions intended to improve and enhance these national-level policies. Most recently, the National Response Framework (NRF), the successor to the National Response Plan, became effective in March 2008; it describes the doctrine that guides national response actions and the roles and responsibilities of officials and entities involved in response efforts. The NRF also includes a Catastrophic Incident Annex, which describes an accelerated, proactive national response to catastrophic incidents, as well as a Supplement to the Catastrophic Incident Annex—both designed to further clarify federal roles and responsibilities and relationships among federal, state and local governments and responders. Together, these documents are intended to provide a comprehensive structure, guidance, and performance goals for developing and maintaining an effective national preparedness and response system. Because there are a range of federal and nonfederal stakeholders with important responsibilities for emergency preparedness and response, it is important that FEMA and DHS include these stakeholders in its development and revisions of national policies and guidelines. Today we are issuing a report on the process DHS used to revise the NRF, including how DHS integrated key stakeholders. DHS included non-federal stakeholders in the revision process during the initial months when issues were identified and draft segments written, and during the final months when there was broad opportunity to comment on the draft that DHS had produced. However, DHS deviated from the work plan it established for the revision process that envisioned the incorporation of stakeholder views throughout the process and did not provide the first full revision draft to non-federal stakeholders for their comments and suggestions before conducting a closed, internal federal review of the draft. DHS’s approach was also not in accordance with the Post-Katrina Act’s requirement that DHS establish a National Advisory Council (NAC) to incorporate non-federal input into the revision process. Although the NAC was to be established within 60 days of the Act (i.e., December 4, 2006), FEMA, which assumed responsibility for selecting members, did not name NAC members until June 2007 because of the additional time needed to review hundreds of applications and select a high quality body of advisors, according to the FEMA Administrator. The NAC’s first meeting took place in October 2007 after DHS issued the revised plan for public comment. We are recommending that, as FEMA begins to implement and eventually review the 2008 National Response Framework, the Administrator develop and disseminate policies and procedures describing the conditions and time frames under which the next NRF revision will occur and how FEMA will conduct the next NRF revision. These policies and procedures should clearly describe how FEMA will integrate all stakeholders, including the NAC and other non-federal stakeholders, into the revision process and the methods for communicating to these stakeholders. FEMA agreed with our recommendation. The importance of involving stakeholders, both federal and non-federal, was underscored in our review of The National Strategy for Pandemic Influenza (National Pandemic Strategy) and The Implementation Plan for the National Strategy for Pandemic Influenza (National Pandemic Implementation Plan) which were issued in November 2005 and May 2006 respectively, by the President and his Homeland Security Council. Key non-federal stakeholders, such as state and local governments, were not directly involved in developing the National Pandemic Strategy and Implementation Plan, even though these stakeholders are expected to be the primary responders to an influenza pandemic. While DHS collaborated with the Department of Health and Human Services (HHS) and other federal agencies in developing the National Pandemic Strategy and Implementation Plan, we found that there are numerous shared leadership roles and responsibilities, leaving uncertainty about how the federal government would lead preparations for and response to a pandemic. Although the DHS Secretary is to lead overall non-medical support and response actions and the HHS Secretary is to lead the public health and medical response, the plan does not clearly address these simultaneous responsibilities or how these roles are to work together, particularly over an extended period and at multiple locations across the country. In addition to the two Secretaries, we observed that the FEMA Administrator is now the principal domestic emergency management advisor to the President, the Homeland Security Council, and the DHS Secretary, pursuant to the Post-Katrina Act, adding further complexity to the leadership structure in the case of an influenza pandemic. Most of these leadership roles and responsibilities have not been tested under pandemic scenarios, leaving it unclear how they will work. We therefore recommended that DHS and HHS work together to develop and conduct rigorous testing, training, and exercises for pandemic influenza to ensure that federal leadership roles are clearly defined and understood and that leaders are able to effectively execute shared responsibilities to address emerging challenges, and ensure these roles are clearly understood by all key stakeholders. We also recommended that, in updating the National Pandemic Implementation Plan, the process should involve key non- federal stakeholders. DHS and HHS agreed with our recommendations, and said that they were taking or planned to take actions to implement our recommendations. As we noted in our report on the preparation for and response to Hurricane Katrina issued in September 2006, clearly defined and understood roles and responsibilities are essential for an effective, coordinated response to a catastrophic disaster.