GAO: Federal agencies lack adequate continuity plans

Federal civilian departments and agencies do not have comprehensive plans for continuing operations during a crisis, increasing the risk that the most vital government programs and services may not be provided in an emergency, according to a new General Accounting Office report.

The watchdog agency found that 23 of the largest federal civilian agencies do not have adequate continuity of operations plans as required by the Federal Emergency Management Agency. All but three of the agencies reviewed had developed and documented some elements of a COOP, but none provided documentation sufficient to show it was following the guidance of a 1999 FEMA circular on the subject. GAO reviewed contingency plans in place at the agencies as of Oct. 1, 2002.

"[The] plans that were in place exhibited weaknesses in the form of widely varying determinations about what functions are essential, and inconsistent compliance with guidance that defines a viable COOP capability," auditors noted in the report (GAO-04-160). "The weaknesses that we identified could cause the agencies to experience difficulties in delivering key services to citizens in the aftermath of an emergency."

Under a 1998 presidential directive, federal agencies are required to have plans to ensure the continuity of services in emergency situations. FEMA is designated as the agency responsible for issuing guidance and reviewing agencies' plans. GAO noted that "the lack of compliance shown by many COOP plans can be largely attributed to FEMA's limited guidance and oversight of executive branch COOP planning."

GAO auditors reviewed a total of 34 COOP plans in their investigation. Of those, 29 included at least one essential function. Those identified in the plans varied widely, however, and included functions that appeared to be of secondary importance, GAO said. At the same time, the plans omitted many programs that the Office of Management and Budget had previously identified as having a high impact on the public. Additionally, 19 plans did not assess interdependencies among federal agencies.

"Improper identification of essential functions can have a negative impact on the entire COOP plan, because other aspects of the plan are designed around supporting these functions," the report said. "If an agency fails to identify a function as essential, it will not make the necessary arrangements to perform that function.

The report recommended that the Department of Homeland Security take steps to ensure agencies have plans in place and improve FEMA's oversight of existing plans. Michael Brown, DHS undersecretary for emergency preparedness and response, agreed with GAO's recommendations. But Brown also contended that the federal government could provide services in an emergency.

The report noted that FEMA plans to develop additional guidance and conduct a governmentwide exercise. "Without better oversight, agencies are likely to continue to base their COOP plans on ill-defined assumptions that may limit the utility of the resulting plans," the report said.

FEMA officials told GAO that they plan to improve oversight by providing more detailed guidance and developing a system to collect data from agencies on their COOP readiness.

In response to the report, the House Government Reform Committee announced Monday that it will hold an oversight hearing on the government's COOP program. Committee Chairman Tom Davis, R-Va., said the report "paints a disturbing picture of a federal government that may not be able to remain fully functional in the event of a severe natural disaster, terrorist attack or other emergency."

"I am very concerned that, in the year 2004, the federal government still has major shortcomings in identifying agencies' essential functions and developing plans to carry those functions out in the event of a natural or man-made disaster," Davis said. "In the last few years in Washington we have seen enough events, both big and small, interrupt government operations to know the importance of continuity of operations plans."

According to Davis, COOP should identify an agency's essential functions, plans and procedures for carrying out those functions; order of succession to fill key positions in an emergency; delegations of authority, including the legal basis for officials to make decisions in emergencies; alternate facilities to support operations; redundant emergency communications; and vital records. In addition, tests, training and exercises should occur regularly.