oversight

Report 2007-012- AMR - Evaluation of EEOC Field Office Continuity of Operations

Published by the Equal Employment Opportunity Commission, Office of Inspector General on 2008-03-27.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

OIG-07-12-AMR           Evaluation of EEOC Field Office Continuity of Operations


EXECUTIVE SUMMARY
Planning for recovery from a disaster is commonly recognized as an essential component in the
management of risk. Continuity of operations (COOP) planning refers to the efforts of an
organization, such as a branch of government, department, or office, to ensure that the capability
exists to continue essential operations in the aftermath of a comprehensive array of potential
operational interruptions. We define a COOP event as a weather, geological, or other type of event
that keeps employees away from the central office for an extended period of time.

The Equal Employment Opportunity Commission (EEOC) experienced major events disrupting
continuity of operations at two of its field offices (New York after September 11, 2001, and New
Orleans after Hurricane Katrina in 2005). The recovery and reconstitution of these two field offices
occurred thanks to the tireless efforts of a number of headquarters and field office staff, rather than
to prudent strategy and planning.

Currently, the development of COOP plans and strategy is the responsibility of each
Agency field office director. The Office of Inspector General (OIG) finds that the lack of
headquarters oversight, as well as the lack of an Agency executive identified as a senior
accountable official, as required by the National Continuity Policy, prevents EEOC from
assisting in field office COOP planning and testing.

The current field office plans address only 4 COOP plan elements (essential functions,
order of succession, delegations of authority, and alternate facilities) of the 11
recommended by the Federal Emergency Management Agency (FEMA).

We also conclude the following:

    1. Without complete and viable COOP plans for each field office, EEOC’s ability to
       provide continuity of operations and continued mission-critical services (receiving
       new discrimination complaints, investigating previously submitted discrimination
       complaints, providing mediation services, etc.) to its stakeholders is seriously
       jeopardized.

    2. In the case of a COOP event, if access to paper case-file documentation is
       restricted, the Agency’s ability to maintain productivity is greatly hindered.

    3. In the case of a COOP event, mission-critical information that is not backed up
       onto a network drive may not be accessible or may be lost permanently.

Therefore, OIG recommends to the Chief Operating Officer the following actions:

    1. Appoint a senior accountable officer for COOP, whose primary responsibility is
       to assist field offices with the development, implementation, and updating of
       COOP plans to ensure the adequacy of the plans.




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The newly appointed senior accountable officer should also:

    2. Direct field office directors to prepare COOP plans and activities to ensure that
       field offices are adequately prepared for a COOP event. The preparation of the
       plans must meet the requirements defined in the National Continuity Policy, as
       well as other FEMA requirements.

    3. Ensure that all field office staff take the Continuity of Operations (COOP)
       Awareness Course offered by FEMA. This free online course will provide staff
       basic COOP information.

    4. Develop and implement policy and procedures instructing field office staff to
       store all mission-critical electronic files on Agency-managed network drives.

OIG also suggests that the Office of Field Programs, Office of Federal Operations, and
Office of Information Technology develop an Agencywide strategy to save critical
documents in an electronic format so that field offices can access or restore information
from alternate locations in case of a COOP event.

Agency comments on the draft report are included in their entirety as Appendix B.
Generally, management agreed with the facts in the report and OIG’s findings,
conclusions, and recommendations. In addition some suggestions were offered to further
improve the COOP process. We acknowledge minor changes to the final report for
clarification purposes.




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1.0     INTRODUCTION

1.1     Background

Planning for recovery from a disaster is commonly recognized as an essential component
in the management of risk. Annually, nearly one in five businesses suffers a major
disruption of operations or services. A disruption of service can be caused by a weather,
geological, or other type of event that results in employees not having access to the
central office for an extended period of time. Because continuity planning is a means of
ensuring that essential functions of business survive such disruptions, it is crucial for any
business or organization to plan for loss or denial of access to key assets or resources.

Continuity of operations (COOP) planning refers to the efforts of an organization, such as
a branch of government, department, or office, to ensure that the capability exists to
continue essential operations in the aftermath of a comprehensive array of potential
operational interruptions. COOP plans are not the same as Occupant Emergency Plans.1

On May 9, 2007, President George W. Bush issued National Security Presidential
Directive (NSPD) 51, which is also identified as Homeland Security Presidential
Directive (HSPD) 20, National Continuity Policy.2 The directive updates longstanding
continuity directives designed to ensure that governing entities are able to recover from a
wide range of potential operational interruptions. The National Continuity Policy states
that heads of executive departments and agencies shall execute their respective
department or agency COOP plans in response to a localized emergency and shall plan,
program, conduct, and support annual tests for continuity capabilities.

According to interviews with senior officials in the Office of Field Programs and the
Chief Financial Officer, each field office director is required to annually update his or her
office’s COOP plan. Field office COOP plans include the following:
    • Leadership contact names and numbers
    • Emergency directory and calling tree
    • Alternate sites
    • Essential functions
    • Resources needed
    • Reference to documents concerning order of succession and delegation of
        authority
    • External directory
    • Specialized telephone/fax/e-mail directory



1
  The Occupant Emergency Plan (OEP) is a set of procedures to protect life and property under
defined emergency conditions.
2
  NSPD 51/HSPD 20 revokes Presidential Decision Directive (PDD) 67, Enduring Constitutional
Government and Continuity of Government Operations, which was issued by the Clinton
Administration on October 21, 1998.

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Each district office is required to update the COOP appendices for its district, including
area and local offices. District offices are responsible for maintaining the accuracy of the
plans. Subsequent updates should be submitted to the inSite (EEOC’s intranet)
coordinators in the Office of Field Programs.


1.2     Objective, Scope, and Methodology

1.2.1   Objective

The primary objective of this review is to determine whether EEOC’s 51 field offices
have developed, implemented, and tested their individual COOP plans in accordance with
the National Continuity Policy. Addressing this objective will enable OIG to determine
whether all field offices have adequately developed COOP plans that will enable them to
reconstitute and resume customer service in a timely, efficient, and effective manner.

The COOP plan designed and developed by each field office should address the measures
by which Agency field offices can ensure that they are able to provide effective mission-
essential functions after an unexpected emergency or disaster.

1.2.2   Scope and Methodology

The scope of this review focuses on activities relating to EEOC’s field office COOP
planning and execution, including the following:
    • Field office COOP strategy, planning, and execution
    • EEOC strategy for, and management of, field office COOP planning

In order to assess the viability of the Agency’s field office COOP plans, we used the
following approaches:
    • Held discussions with COOP experts to gain perspective on evaluating COOP
       strategy, planning, and activities
    • Reviewed copies of EEOC’s field office COOP plans to establish a baseline
       regarding the field office COOP strategy and planning
    • Surveyed field office directors regarding COOP plans and management
    • Interviewed individuals in headquarters responsible for Agency COOP policies
       and field office COOP oversight
    • Visited the New York and New Orleans field offices to evaluate the viability of
       their COOP plans and to obtain input (interviews, focus groups, and data) from
       managers and staff

This assessment was conducted in accordance with generally accepted government
auditing standards, as published in the Comptroller General’s Government Auditing
Standards of July 2007. The fieldwork took place from June 2007 through October 2007.




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2.0     FINDINGS AND CONCLUSIONS

2.1     COOP Management – Structure, Functions, and Perspective

2.1.1   Structure

The recovery and reconstitution of the New York and New Orleans field offices occurred
through the tireless efforts of a number of headquarters and field office staff, rather than
through the execution of prudent strategy and planning.

Our review of headquarters’ COOP-related policies and procedures determined that
EEOC has no centralized managerial structure regarding Agency COOP coordination and
oversight. According to the National Continuity Policy, heads of executive departments
and agencies must appoint a senior accountable official, at the assistant secretary level, as
the continuity coordinator for the department or agency.

2.1.2   Functions

The Office of Field Programs (OFP) coordinates operational planning support services
for field offices and provides advice and assistance to support OFP managers in the
development and implementation of effective planning activities. The Office of the Chief
Financial Officer (OCFO), Central Services Division, plans, establishes, directs, controls,
and implements Agency policies, procedures, and standards governing all aspects of the
following functional areas: real and personal property management; transportation, travel,
and fleet management; mail management; records management; printing and
reproduction services; space design; and physical security, safety, and emergency
planning.

2.1.3   Perspective

Currently, the development of COOP plans and strategy is the responsibility of each
Agency field office director. However, both the EEOC’s OFP and the OCFO state that it
is not their responsibility to provide oversight or guidance to field offices concerning
COOP planning. A senior official in OFP stated that it does not conduct a formal review
of field office COOP plans that are submitted for posting on the Agency’s intranet, inSite.

OFP, the Office of the Chair, and other headquarters offices aided in the reconstitution
efforts of the New York and New Orleans field offices after the September 11, 2001,
attack and Hurricane Katrina in 2005. According to OFP officials, these reconstitutions
were engineered without thought of using any type of COOP plan and occurred through
the use of ad hoc committees convened to assist in specific reconstitution areas. OFP
officials also stated that the Agency learned valuable lessons regarding office recovery
and reconstitution; however, this information was never captured into any one
informational document (such as a COOP plan or standard operational procedures) that
could be used as a guide by other field offices during a COOP event.



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2.1.4 Conclusions

a. The lack of headquarters oversight prevents EEOC from adequately supporting field
office COOP planning and testing.

b. There is no senior Agency official responsible for COOP planning. A senior
accountable official, at a level equivalent to an assistant secretary, reports to the National
Continuity Coordinator.3 While field office directors should be involved in the
development and execution of COOP plans for their respective offices, the Agency is
required by the National Continuity Policy to identify an individual to serve as a senior
accountable official for the Agency regarding COOP planning.


2.2     Comparison and Analysis of Existing Plans to Applicable Standards

2.2.1   FEMA Standards

According to FEMA, a viable COOP plan should contain the below-mentioned 11
elements. The current field office COOP plans addressed only 4 of the FEMA-
recommended elements (essential functions, order of succession, delegations of authority,
and alternate facilities) and failed to address the other 7 recommended elements. We
identified three documents on the Agency’s intranet that related to COOP. The first
document, Continuity of Operations Plan, contained no practical instructions regarding
what actions field offices should perform during a COOP event. The second document,
entitled Continuity of Operations Plan: Appendices A–E and Emergency Directories,
contains few details regarding COOP planning or specific plans regarding COOP
(weather, geological, or other) events. The third document, which is entitled Continuity
of Operations Plan: Appendices – EEOC Headquarters, Appendices A–E and Emergency
Directories, contains information regarding headquarters COOP.

FEMA states that an effective COOP plan should include 11 elements. The table below
shows that EEOC adheres to 4 elements.




3
 A National Continuity Coordinator is a federal official who reports directly to the president and
establishes a continuity policy coordination committee to develop policies, a continuity advisory
group to implement programs and an interagency board to validate primary mission-essential
functions) on all continuity matters.

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                        EEOC Adherence to COOP Plan Elements

 COOP Element             Description                                                         EEOC Adherence
                          Functions that enable the Federal government to provide vital       Yes
 Essential Functions      services, exercise civil authority, maintain the safety and well-
                          being of the general populace, and sustain the industrial and
                          economic base in an emergency situation
 Alternate Facilities     Facilities used to carry out mission-essential functions in a       Yes
                          COOP situation if the agency’s primary facility is unavailable
 Order of Succession      Provisions for the assumption of senior agency offices during an    Yes
                          emergency in the event that any of those officials are
                          unavailable to execute their legal duties
 Delegations of           Predetermined statements that specify who is authorized to act      Yes
 Authority                on behalf of agency leadership for specific purposes
 Devolution               Capability to transfer statutory authority and responsibility for   No
                          mission-essential functions from an agency’s primary operating
                          staff and facilities to other employees and facilities, and to
                          sustain operational capability for an extended period
 Vital Records            Electronic and hard-copy records needed to support mission-         No
                          essential functions during a COOP situation
 Interoperable            Alternate communications that provide the capability to perform     No
 Communications           essential functions until normal operations can be resumed
 Test, Training, and      Measures to ensure that an agency’s COOP program can                No
 Exercises                implement the COOP plan and support mission-essential
                          functions during an emergency situation
 Reconstitution           Process by which an agency transitions from COOP                    No
                          implementation to resumption of normal operations
 Human Capital            Plans and actions to respond to threats that employees are most     No
                          likely to face during COOP activation, such as dismissal
                          procedures, agency guidelines for communicating to employees,
                          and staffing flexibilities, such as telework
 Plans and Procedures     Plans and procedures to be developed and documented so that         No
                          agency personnel will know what to do in an emergency
                          situation (Plans and procedures are required for the three phases
                          of COOP implementation: activation, relocation, and
                          reconstitution.)

2.2.2    Pandemic Influenza

Our review of the field office COOP plans determined that the current plans do not
address pandemic influenza as required by the Implementation Plan for the National
Strategy for Pandemic Influenza. Pandemic influenza is a global outbreak of disease that
occurs when a new influenza virus appears or “emerges” in the human population, causes
serious illness, and spreads easily from person to person worldwide.

The Implementation Plan for the National Strategy for Pandemic Influenza requires
Federal departments and agencies to develop operational plans addressing: (1) protection
of employees, (2) maintenance of essential functions and services, (3) support for the
Federal response, and (4) communication with stakeholders about pandemic planning and
response.



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In fiscal year 2007, EEOC hired Excalibur Associates, Inc., to provide expertise and
technical editing of content to update the Agency’s COOP plan and create a COOP
pandemic template for EEOC headquarters and field offices. The primary goal of the
draft document developed by Excalibur Associates, Inc., entitled EEOC COOP Pandemic
Template, dated December 18, 2007, is to facilitate COOP preparedness, activation,
implementation, and reconstitution following a pandemic influenza outbreak.

The template provides the framework for EEOC district and other offices to further
develop comprehensive pandemic annexes to the existing EEOC COOP plans. According
to Excalibur Associates, Inc, Federal interagency planning guidance requires the
development of a COOP pandemic annex and states that the annex neither replaces nor
supersedes the current approved EEOC headquarters COOP plan; rather, it supplements
it, bridging the gap in the traditional all-hazards COOP planning of Federal Preparedness
Circular (FPC) 65.

Our review did not cover in detail pandemic influenza or assess the template completed
by Excalibur Associates, Inc., for accuracy or completeness as it relates to policy
described in FPC 65, or the Implementation Plan for the National Strategy for Pandemic
Influenza. However, we note that the template and annex discuss pandemic influenza for
both headquarters and field offices, and discuss pandemic influenza planning in terms of
the 11 elements of a viable COOP plan as described by FEMA.

2.2.3   Conclusions

Overall, current field office COOP plans do not discuss pandemic influenza planning.
However, once the EEOC COOP pandemic template is finalized and incorporated into
the field office COOP plans, the template should provide the Agency with an appropriate
level of assurance regarding: (1) the protection of employees, (2) maintenance of
essential functions and services, (3) support for the Federal response, and (4)
communication with stakeholders about pandemic planning and response.


2.3     Field Office Experience – Survey Results

Our survey of EEOC field offices (92 percent response rate) shows that while COOP
planning is widely regarded as important, most offices have not taken the necessary steps
to produce a detailed COOP plan or to systematically test COOP plans. For a statistical
summary of the responses to each survey question, see Appendix A.

Some offices do not have any staff with COOP training, making adequate COOP
preparation problematic. Several survey responses suggested that more headquarters
attention to COOP would be helpful. Many offices improve their COOP efforts by
working with other entities. Field offices reported working with Federal, state, and other
entities, such as the U.S. Corps of Engineers. For example, one office will participate
with its local Federal Executive Board in a pandemic influenza exercise, and another
office participated in a government regional COOP exercise.

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2.3.1   COOP Events and Understanding of COOP Planning

Twenty-three percent of field offices reported experiencing a COOP event in the last six
years. Most of the events were weather related. Los Angeles reported one COOP event in
each of the three categories, weather, geological, and other. COOP awareness and
concern among office directors is strong, with virtually all office directors reporting that
COOP planning is very important or important.

Only 42 percent of office directors reported receiving basic COOP training. Some
directors who had not taken COOP training reported taking COOP-related training, such
as emergency management (18 percent). Several office directors reported taking multiple
training courses. Most offices reported that additional staff had received training. Forty-
four percent of the training was COOP awareness.

Survey results show that some offices do not understand or distinguish between
emergencies and COOP events. Twenty-six percent of respondents stated that their
offices tested COOP plans. However, some of the examples cited were for emergencies,
not COOP events. Waiting until an event occurs is insufficient as a testing mechanism.
One survey respondent stated, “It would be better to discover discrepancies in our plan
during a non-emergency scenario than in an actual crisis situation.”

2.3.2   Conclusions

Without complete and viable COOP plans for each field office, EEOC’s ability
to provide continuity of operations and continued mission-critical services (receiving new
discrimination complaints, investigating previously submitted discrimination complaints,
providing mediation services, etc.) to its stakeholders is seriously jeopardized.


2.4     Field Office Results – New York and New Orleans

The New York and New Orleans offices experienced severe COOP events in 2001 and
2005, respectively. Each office recovered essential operations and reconstituted full
operations due to strong individual and group efforts by field and headquarters staff.

COOP plans were not used during the COOP events in New York and New Orleans.
Given the overall lack of Federal experience and activity regarding COOP in 2001, this
was an understandable shortcoming for EEOC. By 2005 (Hurricane Katrina/Rita),
however, adequate time had passed for EEOC to prepare and position itself to implement
a field office COOP plan. The lack of attention to COOP resulted in inadequate planning.
For example, critical human resource decisions were made in an ad hoc manner because
guidance and procedures were not in place.

OIG staff visited New Orleans and New York to determine how the experiences of these
field offices could assist EEOC in improving field office COOP planning and related



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activities. We found that both offices have made significant strides in preparing for
another COOP event. However, much remains to be accomplished in the following areas:
    • COOP communication, training, and testing
    • COOP planning
    • Information technology
    • The written COOP plan


2.4.1   New York

2.4.1.1 Recovery and reconstitution

On September 11, 2001, the New York District Office (NYDO) was completely
destroyed, including all paper files and all electronic data that had not been saved and
stored at a remote location. NYDO management made great efforts to contact and
communicate with staff in the days following the attack. Because planning for such an
event had not taken place, there was not an effective method to quickly contact staff.

NYDO managers worked closely with headquarters to meet the social needs of the
NYDO staff. For example, close coordination ensured that paychecks were not
interrupted and that counseling (short and long term) and information on a variety of
issues were provided. NYDO staff believe, overall, that headquarters responded quickly
and responsibly to the COOP event.

Headquarters and NYDO staff then worked in a dedicated manner to resume essential
NYDO operations, such as intake and internal and external communication. Initially, a
small number of staff worked in the EEOC’s Newark office and others teleworked, while
New York and headquarters management promptly began searching for and then securing
temporary workspace in New York City.

2.4.1.2 Status of COOP efforts

Since reconstitution and recovery, NYDO has made significant efforts to improve its
COOP program, but much work remains to be done in the following areas:
   • COOP communication, training, and testing
   • COOP planning

COOP communication, training, and testing: NYDO staff believe that getting in touch
with staff and meeting other communication needs are critical after COOP events, and
need improvement. After the September 11 disaster, contact information for all staff has
been updated, but management stated that access to updated information needs
improvement.

Staff, including some managers, do not distinguish between COOP and other emergency
situations (such as shelter in place) and do not know very much about COOP. Staff and
management agree that testing of COOP/emergency procedures would be useful.

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Most managers and staff have had no formal COOP training. Managers and staff believe
training to be important. For example, one manager believes most investigators do not
have basic COOP knowledge and recommends that all employees receive COOP training.
Basic CCOP training is available free of charge at www.fema.gov.

COOP planning: NYDO is working with the local Federal Executive Board4 (FEB) on
COOP issues, and at least two managers appear knowledgeable in this area. The NYDO
Director reports that the FEB is aggressive in New York, thereby helping COOP planning
efforts. The Director believes it is important to be fully involved with FEB COOP efforts.

After the September 11 event, NYDO provided all staff with emergency kits. However,
not all staff were kept current with supplies and information related to COOP (e.g., new
staff are not provided with emergency kits).

2.4.1.3 Conclusions

According to interview and focus group results, most staff and managers believe that
COOP preparation is very important and want better-informed and trained staff.

2.4.2   New Orleans

2.4.2.1 Recovery and reconstitution

On August 29, 2005, Hurricane Katrina struck New Orleans, forcing EEOC to abandon
its New Orleans office. The building in which the office was housed sustained damage
that made it necessary to obtain temporary space. Many paper files were left in the office
and were recovered later. Many EEOC staff lost their homes or had to leave their homes
for an extended period of time. Twelve of the 53 staff did not return to New Orleans. At
the time of OIG’s interview, the office had 35 staff.

Prior to Hurricane Katrina, the New Orleans office maintained a COOP Plan on file with
the Agency. However, because of lessons learned from Hurricane Katrina, New Orleans
is developing a new COOP plan. While, the official COOP plan does not include many
of the elements of a viable COOP plan, including Pandemic Influenza planning, the new
draft plan (which as of this report is still under review by New Orleans staff) does address
the following:

    •   Types of events: hurricane, pandemic influenza, catastrophic occurrence
    •   How to secure information and information systems
    •   Alternate worksites
    •   Continuing operations

4
 Located outside Washington, D.C., in 28 cities with a large Federal presence, the Federal
Executive Boards (FEBs) are interagency coordinating groups designed to strengthen Federal
management practices, improve intergovernmental relations, and participate as a unified Federal
force in local civic affairs.

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    •   Communications
    •   Office devolution

The draft plan does not, however, fully address all elements of a viable COOP plan as
prescribed by FEMA.

As with the NYDO September 11, 2001, disaster, headquarters and field staff, without
adequate preparation, worked diligently to recover. New Orleans and headquarters staff
obtained temporary workspace and later obtained permanent space. Until conditions in
and around New Orleans improved, many New Orleans staff, including the Director,
worked at other field offices but were unable to work on New Orleans cases. Much of the
New Orleans casework could not be performed because staff were unable to access paper
files.

Using the experience from the NYDO COOP event, though not having translated it into
formal COOP plans, headquarters staff worked with New Orleans management to ensure
that the social needs of New Orleans staff were met. For example, paychecks and
payment for other expenses were sent to employees, even those who moved out of the
area. Overall, New Orleans management and staff believe that headquarters and New
Orleans office management responded well to the event. For example, headquarters
personnel were helpful in locating New Orleans Field Office (NOFO) staff and in
establishing the EEOC CARES (Co-workers Aiding Recovery through Encouragement
and Support) program.

However, staff reported that some parts of the recovery process did not work well. For
example, staff stated that there appeared to be pressure to get staff back behind desks,
even if there was no work for them or conditions greatly hampered operations. Staff
reported problems with the temporary space and initially with the new permanent space.
For example, the size of the room and the technology at the temporary workspace
prevented efficient operations.

Staff cited the following efforts as successful immediately following Katrina:
    • The community Web site
    • The Katrina phone tree
    • Per diem and travel claim processes
    • Communication with headquarters and New Orleans Director K. Hill

2.4.2.2 Status of COOP efforts

Our analysis, as well as the ideas of New Orleans management and staff, identified the
following areas that need work:
    • COOP communication, training, and testing
    • COOP planning




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COOP communication, training, and testing: The consensus of the New Orleans staff we
met with was that they were not well informed on the NOFO COOP plans. They agreed
that it is important to be informed. Similarly, they agreed that testing is important.
Examples cited during the focus group include evaluation plans, how to manage laptops,
securing files, and backing up information.

COOP planning: Staff and management agreed on the vital nature of having updated
contact information for all staff. NOFO has an emergency contact sheet with information
for all employees. Before Katrina, some staff were reluctant to provide that information.
Since Katrina, the Director reports 100 percent cooperation.

The NOFO Director sits on the Federal Executive Board (FEB) in New Orleans. He
stated that the FEB is tasking agencies to perform COOP planning (post Katrina). The
NOFO Director also stated that the FEB has also been good at coordinating Federal
efforts in the aftermath of Katrina.

2.4.2.3 Conclusions

OIG agrees with the management and staff of New Orleans that the COOP plan needs to
be more detailed, tailored to the office, and made available to all the staff.


2.5     Technology

2.5.1   Field Office Discussion

New York and New Orleans managers and staff informed us of issues relating to
technology.5 These include how field offices strive to access and recover the information
necessary to perform mission-critical functions while located in an alternate facility.

According to staff in both New Orleans and New York, a major issue continues to be the
inability to access paper documents in order to perform critical Agency mission–related
functions. In New York, all work files were destroyed. In New Orleans, access to files
was not possible for an extended period of time.

Also, according to focus group participants and supervisors, many individuals maintain
most of their work files on their computers’ hard drives. Events in both New York and
New Orleans showed the importance of employees being able to access Agency resources
in order to maintain productivity.



5
 This review did not include an analysis of the Agency’s information technology (IT) COOP plan in
accordance with National Institute of Standards and Technology Special Publication 800-34, Contingency
Planning Guide for Information Technology Systems. We interviewed the Agency’s Acting Chief
Information Officer, and she informed us that the Agency’s IT COOP plan focuses on the Agency’s six
major information and general support systems.

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2.5.2   Conclusions

a. In the case of a COOP event, if access to paper case-file documentation is prevented or
otherwise restricted, the Agency’s ability to maintain productivity is greatly hindered.

b. In the case of a COOP event, mission-critical information that is not backed up onto a
network drive may not be accessible or may be lost permanently.




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3.0      RECOMMENDATIONS

The following recommendations are offered to improve COOP planning in EEOC field
offices.

OIG recommends that the Agency’s Chief Operating Officer take the following actions:

      1. Appoint a senior accountable officer for COOP, whose primary responsibility is
         to assist field offices with the development, implementation, and updating of
         COOP plans to ensure the adequacy of the plans.

The newly appointed senior accountable officer should also:

      2. Direct field office directors to prepare COOP plans and activities to ensure that
         field offices are adequately prepared for a COOP event. The preparation of the
         plans must meet the requirements defined in the National Continuity Policy, as
         well as other FEMA requirements.

      3. Ensure that all field office staff take the Continuity of Operations (COOP)
         Awareness Course offered by FEMA. This free online course will provide staff
         basic COOP information.

      4. Develop and implement policy and procedures instructing field office staff to
         store all mission-critical electronic files on Agency-managed network drives.

      OIG also suggests that the Office of Field Programs, Office of Federal Operations,
      and Office of Information Technology develop an Agencywide strategy to save
      critical documents in an electronic format so that field offices can access or restore
      information from alternate locations in case of a COOP event.


3.1      Management Comments

Agency comments on the draft report are included in their entirety as Appendix B.
Generally, management agreed with the facts in the report and OIG’s findings,
conclusions, and recommendations. In addition some suggestions were offered to further
improve the COOP process. We acknowledge minor changes to the final report for
clarification purposes.




EEOC Office of Inspector General                  15                                March 27, 2008
OIG-07-12-AMR           Evaluation of EEOC Field Office Continuity of Operations


Audit Follow-Up
The Office of Management and Budget issued Circular Number A-50, Audit Follow-Up,
to ensure that corrective action on audit findings and recommendations proceed as rapidly
as possible. EEOC Order 192.002, Audit Follow-Up Program, implements Circular
Number A-50 and requires that for resolved recommendations, a corrective action work
plan should be submitted within 30 days of the final evaluation report date describing
specific tasks and indicating the completion dates necessary to implement audit
recommendations. Circular Number A-50 requires prompt resolution and corrective
action on audit recommendations. Resolutions should be made within six months of final
report issuance.




EEOC Office of Inspector General                 16                                March 27, 2008