Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the Office of Preparedness Policy, Planning, and Analysis to improve its approach for developing a comprehensive assessment system by enhancing its project management plan to include milestone dates, an assessment of risk, and related mitigation strategies for (1) comprehensively collecting and reporting on disparate information sources, (2) developing quantifiable metrics for target capabilities that are to be used to collect and report preparedness information, and (3) reporting on the results of preparedness assessments to help inform homeland security resource allocation decisions.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Implemented

Comments: In response to our recommendation, the Federal Emergency Management Agency reported in September 2010 that the agency's efforts in implementing the comprehensive assessment system reflected its improved approach. Program officials provided an updated project plan that included milestone dates that included risk assessment and mitigation. As a result, this recommendation is closed as implemented.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by developing procedures for including "lessons learned" from real-world incidents in the Corrective Action Program system.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Open

Comments: According to the agency response in its 31 U.S. Code section 720 letter dated September 1, 2010, the Federal Emergency Management Agency's Remedial Action Management Program (RAMP) Implementation Plan will establish policies and procedures for documenting Federal corrective actions and lessons learned from exercises, real-world events and policy discussions. Pending completion of this action, this recommendation will remain open.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by revising the National Exercise Program Implementation Plan to require the use of FEMA's Corrective Action Program for all federal exercises that involve interagency testing of roles and responsibilities or require that federal agencies submit a report to FEMA on the status of their corrective actions resulting from such exercises.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Open

Comments: According to the agency response in its 31 U.S. Code section 720 letter, dated September 1, 2010, the Federal Emergency Management Agency's (FEMA) National Exercise Program Implementation Plan (NEP I-Plan) designates the Corrective Action Program as the mechanism for identifying and tracking corrective actions for exercises. It further states that Departments and Agencies -- as well as State, territorial, tribal, local governments and private sector entities -may submit issues to the Corrective Action Program through the web-based Corrective Action Program System. The NEP I-Plan requires all departments and agencies to maintain a Corrective Action Program that can generate input for, and track assignments from the Corrective Action Program for unclassified issues. FEMA is chairing a Federal Working Group, established in June 2010 to develop an implementation plan for the Remedial Action Management Program (RAMP). The RAMP Implementation Plan will establish policies and procedures for documenting Federal corrective actions and lessons learned from exercises, real-world events and policy discussions. This will all be coordinated with the NEP reform and revisions to exercise doctrine, including the HSEEP. This recommendation will remain open pending completion of these actions.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by developing internal control policies and procedures that validate the completeness and accuracy of data used to measure program performance. Such procedures could involve checking whether states and federal agencies are providing data and information needed to measure the performance of the program.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Open

Comments: According to the agency response in its 31 U.S. Code section 720 letter, dated September 1, 2010, the Federal Emergency Management Agency's (FEMA) National Preparedness Directorate/National Exercise Division (NPD/NED) is revising policies and procedures for the National Exercise Program (NEP) and the Homeland Security Exercise Evaluation Program (HSEEP). The revisions will address how FEMA will work with Federal agencies and States to confirm that they are providing data and information needed to measure program performance. NED will coordinate with NPD's National Preparedness Assessment Division (NPAD) on ways to improve the effectiveness of program evaluation for the NEP and HSEEP, as well as the value of exercise data for the Comprehensive Assessment System. This recommendation remains open pending completion of these actions.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by involving the National Council on Disability on committees involved in the design and execution of national level exercises, especially on issues related to populations with special needs.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Implemented

Comments: The Federal Emergency Management Agency (FEMA) reported in September 2010 that the agency has added the National Council on Disability to the invitee list for the annual National Exercise Program planning conferences, including National Level Exercises. According to FEMA, the National Exercise Division has begun collaborative discussions directly with the National Council on Disability and through the FEMA Office of Disability Integration and Coordination on how best to incorporate the unique life experiences of people with disabilities in the design and execution of exercises, including national level exercises.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by ensuring compliance by states that receive grant funds with HSEEP requirements by revising FEMA's grant monitoring guidance, for example by including a checklist of specific HSEEP requirements for state validation and certification.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Not Implemented

Comments: According to the agency response in its 31 U.S. Code section 720 letter, dated September 1, 2010, Federal Emergency Management Agency (FEMA) officials did not concur with this recommendation. They said the Homeland Security Exercise Evaluation Program (HSEEP) is a tool to assist State and local jurisdictions plan, conduct, and evaluate exercises. However, because of the emphasis on "HSEEP compliance" over the past several years, this resource has been perceived as unwieldy and often burdensome to stakeholders; detracting from the ultimate value of HSEEP. FEMA is working to identify all the various reporting requirements that are levied on state/local partners and to ultimately reduce and/or consolidate them so that FEMA is getting the information it requires in a manner that is least burdensome to stakeholders. This recommendation is closed as not implemented.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by collaborating with the Homeland Security Council to provide FEMA with the information it needs from past principal level exercises to enable it to conduct remedial action tracking and long-term trend analysis, as required by the Post-Katrina Act.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Implemented

Comments: The Federal Emergency Management Agency (FEMA) reported in September 2010 that the agency has obtained access to after action reports and from past Principal Level Exercises, noting that remedial action tracking is done at the National Security Staff level for most Cabinet level exercises and that FEMA is working with the National Security Staff of the Homeland Security Council to explore ways to gather data that may be used by key players that are responsible for assessments to conduct analysis of Principal Level Exercises, while protecting sensitive information. FEMA's response noted that long term trend analysis to identify comprehensive and supportable findings is important; there are individual findings that provide significant near-term value and lead to rapid corrective actions that significantly improve preparedness, noting that the findings are captured and reviewed for action and implementation by the National Security Staff and that FEMA is working with the staff to enhance the corrective action identification and tracking process. As a result, this recommendation is closed as implemented.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by collaborating with the Homeland Security Council to establish policies and procedures for documenting corrective actions from Principal Level Exercises that are consistent with Homeland Security Exercise and Evaluation Program (HSEEP) guidance and the implementation plan for the National Exercise Program.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Closed - Implemented

Comments: The Federal Emergency Management Agency (FEMA) reported in September 2010, that the agency has obtained access to after action reports and from past Principal Level Exercises, noting that remedial action tracking is done at the National Security Staff level for most Cabinet level exercises and that FEMA is working with the National Security Staff of the Homeland Security Council to explore ways to gather data that may be used by key players that are responsible for assessments to conduct analysis of Principal Level Exercises, while protecting sensitive information. FEMA's response noted that long term trend analysis to identify comprehensive and supportable findings is important; there are also individual findings that provide significant near-term value and lead to rapid corrective actions that significantly improve preparedness; findings are captured and reviewed for action and implementation by the National Security Staff and FEMA is working with the staff to enhance the corrective action identification and tracking process. As a result, this recommendation is closed as implemented.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Exercise Division to improve its implementation of statutory and program requirements by coordinating with the Department of Homeland Security to develop policies and procedures for issuing after-action reports for National Level Exercises (i.e., TOPOFF (top Officials 4 Exercise)) in 6 months or less, as required by the implementation plan for the National Exercise Program.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Open

Comments: According to the agency's response in its 31 U.S. Code section 720 letter, dated September 1, 2010, the Federal Emergency Management Agency has policies and procedures in place to meet the timelines delineated in the National Exercise Program (NEP) Implementation Plan (I-Plan) concerning issuing of After Action Reports (AARs) for National Level Exercises (NLEs). However, the concurrence process often produces delays in the issuance of the final report. The NEP Executive Steering Committee is reviewing NLE project guidance to better clarify roles and responsibilities in the final release process. This recommendation remains open.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the Disaster Operations Directorate and the National Preparedness Directorate to improve their approach to developing policies and plans that define roles and responsibilities and planning processes by developing a program management plan, in coordination with DHS and other federal entities, to ensure the completion of the key national preparedness policies and plans called for in legislation, presidential directives, and existing policy and doctrine, to define roles and responsibilities and planning processes, as well as to fully integrate such policies and plans into other elements of the national preparedness system. The program management plan, among other things, should (1) identify the specific schedule of activities that needs to be performed to complete, and identify dependencies among, all policy and planning development and integration activities; (2) identify the type and quantities of resources required to perform, and the schedule for completing, all policy and planning development and integration activities; (3) analyze activity sequences, durations (including the time required to partner and coordinate on an interagency basis with other federal entities), resource requirements, and schedule constraints to create and update the individual policy and plan development project schedules; and (4) control for changes to the project schedules precipitated by outside forces. When outstanding policies and plans are completed, FEMA should also integrate them into training and exercise efforts to ensure that roles and responsibilities are fully communicated and fully understood by emergency response stakeholders.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Open

Comments: According to the agency response in its 31 U.S. Code section 720 letter, dated September 1, 2010, the Federal Emergency Management Agency's (FEMA) National Preparedness Directorate (NPD) is in the process of revising its annual operating plan, which contains many of the program management elements called for in the recommendation. The revised operating plan will be a NPD strategic plan that effectively links the portfolios and resources of major NPD programmatic activities and includes specific goals, timelines, milestones and measurements of progress. The strategic plan will incorporate the elements identified in other influencing strategic documents, including the Quadrennial Homeland Security Review, Administrator's Intent, the FEMA Strategic Plan (currently being updated), the Community Preparedness Strategic Approach, the 2009 NPD Operating Plan, pertinent legislation and GAO/OIG recommendations. According to the letter, it is important to note that the advent of the new Presidential Policy Directive (PPD) on National Preparedness (i.e., revision to Homeland Security Presidential Directive-8) issued March 30, 2011, will significantly impact NPD's strategic/program management plans. NPD will conduct a comprehensive review with the intent to update the National Preparedness Guidelines and unify a strategic vision and mechanism for advancing national preparedness in accordance with the new PPD. This intent would include developing a program management plan that accompanies new Guidelines and integrates and synchronizes the desired outcomes of preparedness programs. This would include a schedule to identify and synchronize major preparedness program management activities, a clear delineation of roles and responsibilities, and specific supporting courses of action across each element of the preparedness cycle (e.g., plan, organize and equip, train, exercise, evaluate and improve). This update would describe the process for incorporating developments in policy, doctrine, and lessons learned into preparedness activities, as well as how exercises, evaluations, and assessments evaluate risks, capabilities, and needs, to advance national preparedness. Pending the update, this recommendation will remain open.

Recommendation: To ensure that key elements of the national preparedness system are developed in a timely and integrated fashion, the Administrator of the Federal Emergency Management Agency should direct the National Preparedness Directorate to take a more strategic approach to developing the national preparedness system by developing a strategic plan for implementing the national preparedness system that includes the key characteristics of a strategic plan, including coordination, integration, and implementation approaches.

Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

Status: Open

Comments: According to the agency response in its 31 U.S. Code section 720 letter, dated September 1, 2010, the Federal Emergency Management Agency's FEMA) National Preparedness Directorate (NPD) is developing a strategic plan based on other influencing strategic documents, including the Quadrennial Homeland Security Review, Administrator's Intent, the FEMA Strategic Plan, which is currently being revised, the Community Preparedness Strategic Approach, the 2009 NPD Operating Plan, GAO/OIG recommendations, the National Preparedness Presidential Policy Directive, Preparedness Task Force recommendations and legislation. Pending completion of this action, this recommendation remains open.