United States Government Accountability Office GAO Report to Congressional Requesters May 2012 DISASTER ASSISTANCE WORKFORCE FEMA Could Enhance Human Capital Management and Training GAO-12-538 May 2012 DISASTER ASSISTANCE WORKFORCE FEMA Could Enhance Human Capital Management and Training Highlights of GAO-12-538, a report to congressional requesters Why GAO Did This Study What GAO Found Since fiscal year 2007 FEMA has The Federal Emergency Management Agency (FEMA) has taken steps to obligated $33 billion in disaster enhance its management of the Disaster Assistance Employee (DAE) program, assistance payments. FEMA relies such as through the establishment of a credentialing program, the FEMA heavily upon its cadre of DAEs, a Qualification System (FQS); however, management controls and training could reserve workforce who interact with be strengthened. For example, FEMA does not monitor how the regions disaster survivors. GAO was asked to implement DAE policies and how DAEs implement disaster policies across review the management and training of regions to ensure consistency. FEMA’s Administrator noted that due to DAEs. Specifically, this report differences in how regions operate, it is problematic to deploy someone based in addresses the extent to which (1) one region to another during a disaster. Establishing a mechanism to monitor FEMA has policies and procedures in both the regional implementation of DAE policies and procedures and DAE’s place to govern the DAE program; (2) FEMA’s human capital controls over implementation of disaster policies could help provide FEMA with reasonable the DAE workforce are consistent with assurance that disaster assistance is conducted in accordance with policy and internal control standards; and (3) implemented consistently. FEMA’s DAE training incorporates key FEMA’s human capital controls could be strengthened. FEMA’s regional DAE attributes of effective training and managers are responsible for hiring DAEs, but FEMA has not established hiring development programs. In addition, criteria and has limited salary criteria. By establishing standardized criteria for GAO describes FEMA’s initiative to making hiring and salary decisions, FEMA would be better positioned to hire transform the DAE program people with requisite skills and better ensure consistency across regions. announced in April 2012. GAO Likewise, FEMA’s performance appraisal system for DAEs is not consistent with reviewed management documents such as program-specific and human internal control standards. FEMA does not have criteria for supervisors to assign capital-related guidance, interviewed DAEs satisfactory or unsatisfactory ratings. Thirteen of 16 regional DAE FEMA officials, and conducted 16 managers GAO interviewed stated that the appraisal process could be improved, focus group sessions with DAEs in four such as implementing a rating scale instead of a pass/fail rating. FEMA officials selected joint field offices chosen to noted that performance management is a critical component in DAE supervision provide geographic dispersion, among and must be improved in fiscal year 2012. Establishing a more rigorous other factors. The results of the focus performance management system that includes criteria for given performance groups are not generalizable, but elements as well as guidance could help FEMA ensure that DAEs’ performance provide valuable insight into DAE appraisals more accurately reflect performance and provide needed information experiences. to managers. What GAO Recommends FEMA’s DAE training is not consistent with key attributes of effective training and development programs, such as a plan for training staff. FEMA does not have a GAO recommends, among other plan to ensure DAEs receive necessary training such as FQS requirements. things, that FEMA establish a Further, 13 of 16 regional DAE managers GAO spoke to said that they would like mechanism to monitor both its regions’ more opportunities for DAEs to receive training. A plan to ensure that all DAEs implementation of DAE policies and DAEs’ implementation of disaster have opportunities for training and completing FQS requirements with related policies; criteria for hiring and milestones would provide FEMA with a roadmap and ensure accountability for compensating DAEs; and a plan to qualifying DAEs under FQS. In addition, FEMA does not track how much of the train DAEs within a set time frame. Disaster Relief Fund is spent on training for DAEs. Developing a systematic DHS concurred with the process to track training costs could provide FEMA with information to help it recommendations. determine whether it is allocating its resources effectively. In an April 2012 memo, FEMA announced plans to transform the DAE program beginning in June 2012; however, this effort is still in the early stages and as a result, it is too soon to evaluate the effectiveness of FEMA’s planned actions. View GAO-12-538. For more information, contact William O. Jenkins at (202) 512-8757 or email@example.com. United States Government Accountability Office Contents Letter 1 Background 5 Opportunities Exist to Strengthen Policies and Procedures That Govern the DAE Program 12 FEMA Could Strengthen Human Capital Management Controls 20 FEMA’s DAE Training Is Not Consistent with Key Attributes of Effective Training and Development Programs 29 FEMA Announced Impending Transformation of DAE Program, but It Is Too Soon to Evaluate the Effectiveness of the Agency’s Planned Actions 33 Conclusions 34 Recommendations for Executive Action 35 Agency Comments and Our Evaluation 36 Appendix I Objectives, Scope, and Methodology 40 Appendix II Categories of Disaster Workforce Employees 44 Appendix III Cadre List and Descriptions 45 Appendix IV FEMA Organizational Chart—Highlight of Response Directorate’s Incident Workforce Management Office 51 Appendix V Disaster Assistance Employee Program Office Reorganization Timeline, April 2008 through May 2012 52 Appendix VI Incident Workforce Management Office Organizational Structure and Proposed Roles 53 Appendix VII FEMA Disaster Assistance Employee Pay Scale, Calendar Year 2011 54 Page i GAO-12-538 Disaster Assistance Employees Appendix VIII Comments from the Department of Homeland Security 55 Appendix IX GAO Contact and Staff Acknowledgments 58 Tables Table 1: FEMA Regional Office, Joint Field Office, and Emergency Management Agencies 42 Table 2: Cadre List and Descriptions 45 Figures Figure 1: Map of FEMA Regions and the Number of Disaster Declarations and Disaster Assistance Employees Per Region in 2011 9 Figure 2: Disaster Assistance Employee Performance Appraisal Elements 26 Page ii GAO-12-538 Disaster Assistance Employees Abbreviations CORE Cadre of On-Call Response/Recovery Employee CR Community Relations DAE Disaster Assistance Employee DFTO Disaster Field Training Office DHS Department of Homeland Security DRS Disaster Readiness and Support EMI Emergency Management Institute FCO Federal Coordinating Officer FEMA Federal Emergency Management Agency FQS FEMA Qualification System HR Human Resources HSIN Homeland Security Information Network IA Individual Assistance IWMO Incident Workforce Management Office JFO Joint Field Office OCCHCO Office of the Chief Component Human Capital Officer OCIO Office of the Chief Information Officer OIG Office of Inspector General OPPA Office of Program and Policy Analysis PA Public Assistance PFT Permanent Full Time TED Training, Exercise and Doctrine Office This is a work of the U.S. government and is not subject to copyright protection in the United States. The published product may be reproduced and distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately. Page iii GAO-12-538 Disaster Assistance Employees United States Government Accountability Office Washington, DC 20548 May 25, 2012 The Honorable Daniel K. Akaka Chairman Subcommittee on Oversight of Government Management, the Federal Workforce, and the District of Columbia United States Senate The Honorable Bennie G. Thompson Ranking Member Committee on Homeland Security House of Representatives The annual number of federal major disaster declarations has grown 44 percent from fiscal years 2007 to 2011. 1 Since fiscal year 2007, there have been 376 federal major disaster declarations in which the Federal Emergency Management Agency (FEMA) has obligated $33 billion in major disaster assistance payments. 2 FEMA is tasked with leading the nation in mitigating, responding to, and recovering from major disasters, both natural and manmade. To meet its mission, FEMA relies heavily upon its cadre of Disaster Assistance Employees (DAE), a reserve workforce that interacts with disaster survivors. 3 There were 9,981 DAEs, which comprised 57 percent of FEMA’s workforce, as of February 2012. 4 1 The number of major disasters increased each year, except for fiscal year 2009. FEMA has two main types of disaster declarations: major disaster declarations and emergency declarations. Major disaster declarations can be declared for any natural catastrophe, or regardless of cause, any fire, flood or explosion, in any part of the United States, that the President believes has caused damage of such severity and magnitude that warrants major disaster assistance to supplement the efforts and available resources of states, local governments, and disaster relief organizations. Emergency declarations can be declared for any occasion or instance when the President determines federal assistance is needed to supplement state and local efforts and capabilities to save lives and to protect property and public health and safety, or to lessen or avert the threat of a catastrophe in any part of the United States. 42 U.S.C. § 5122. 2 This includes obligations for Individual Assistance, Public Assistance, and Hazard Mitigation, only for Major Disaster declarations declared from fiscal years 2007 to 2011. 3 FEMA’s disaster workforce uses the cadre structure to identify employees who perform a specific operational program or function in support of agency-wide disaster operations. 4 We considered the FEMA workforce to include the following: DAEs, Cadre of On-Call Response/Recovery Employees (2,573), Temporary Full-Time (231) and Permanent Full- Time employees (4,784). Page 1 GAO-12-538 Disaster Assistance Employees DAEs support joint field office (JFO) leadership that administers FEMA’s disaster assistance programs, such as Individual Assistance (IA) and Public Assistance (PA). These programs provide financial assistance to individuals and local governments, respectively, after a disaster. We and others have identified challenges related to FEMA’s training and human capital management practices. For example, our prior work on FEMA’s human capital efforts identified shortages of staff with the right skills, abilities, experience, and training. Specifically, in 2007 we reported that FEMA needed data, plans, and systems to effectively manage resources for its day-to-day operations and recommended that FEMA establish training and development requirements and tracking systems to ensure that staff had the necessary training to carry out their day-to-day and disaster response functions. 5 The Department of Homeland Security (DHS) did not provide comments on GAO’s recommendations; however, in 2008 FEMA issued its Strategic Human Capital Plan, 2008-2012, intended to address this recommendation. Moreover, the DHS Office of Inspector General (OIG) reported that, in the aftermath of Hurricane Katrina in 2005, FEMA new hires did not receive adequate training during FEMA’s accelerated orientation process and FEMA did not have a central training records management system. 6 Further, the DHS OIG noted that the shortage of qualified staff for key positions responding to Hurricane Katrina negatively impacted the effectiveness of FEMA’s response and recovery operations. 7 FEMA has taken a number of steps to address recommendations made by us and the DHS OIG, but key recommendations remain unaddressed as discussed later in this report. You asked us to review FEMA’s management and training of DAEs. Specifically, this report addresses the following questions: 1. To what extent does FEMA have policies and procedures in place to govern the DAE program? 2. To what extent are FEMA’s human capital controls over the DAE workforce consistent with internal control standards? 5 GAO, Budget Issues: FEMA Needs Adequate Data, Plans, and Systems to Effectively Manage Resources for Day-to-Day Operations, GAO-07-139 (Washington, D.C.: Jan. 19, 2007). 6 Department of Homeland Security, Office of Inspector General, FEMA’s Preparedness for the Next Catastrophic Disaster-An Update, OIG-10-123 (September 2010). 7 OIG-10-123. Page 2 GAO-12-538 Disaster Assistance Employees 3. To what extent does FEMA’s DAE training incorporate key attributes of effective training and development programs? In addition, we describe FEMA’s initiative to transform the DAE program announced in April 2012 as it relates to the three questions above. To determine the extent to which FEMA has policies and procedures in place to govern the DAE program, and to determine the extent to which FEMA’s human capital controls over the DAE workforce are consistent with internal controls, we analyzed both program-specific and human capital-related guidance, policies, and procedures produced by FEMA headquarters and regional offices. We also compared FEMA’s human capital management controls with Standards for Internal Control in the Federal Government. 8 To determine the extent to which FEMA’s training of DAEs incorporates key attributes of effective federal training and development programs, we reviewed FEMA’s data from fiscal 2007 to 2011 on training requirements, the location and frequency of training courses, course schedules, and the amount of training funds used from the Disaster Relief Fund, which funds disaster assistance operations. We determined that the data were sufficiently reliable for the purposes of this report based on interviews with officials responsible for the data. We also reviewed policies and procedures on training requirements, FEMA’s learning management systems, JFO operations, and FEMA’s new credentialing program, the FEMA Qualification System (FQS). 9 In addition, we observed training 8 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999). Internal control is an integral component of an organization’s management that provides reasonable assurance that the following objectives are being achieved: effectiveness and efficiency of operations, reliability of financial reporting, and compliance with applicable laws and regulations. These standards, issued pursuant to the requirements of the Federal Managers’ Financial Integrity Act of 1982 (FMFIA), provide the overall framework for establishing and maintaining internal control in the federal government. Also pursuant to FMFIA, the Office of Management and Budget issued Circular A-123, revised December 21, 2004, to provide the specific requirements for assessing the reporting on internal controls. Internal control standards and the definition of internal control in Circular A-123 are based on GAO’s Standards for Internal Control in the Federal Government. 9 Credentialing involves the objective evaluation and documentation of an individual’s current certification, license, or degree; training and experience; and competence or proficiency to meet nationally accepted standards, provide particular services and/or functions, or perform specific tasks under specific conditions during an incident. Page 3 GAO-12-538 Disaster Assistance Employees attended by DAEs in a JFO. We compared FEMA’s DAE training efforts with key attributes of effective training and development programs to determine the extent to which they were aligned. 10 To address all three objectives, we reviewed previous DHS OIG reports, and a FEMA-sponsored study conducted by Booz Allen Hamilton on FEMA’s disaster workforce. 11 We interviewed officials from various FEMA offices at its headquarters, including the Incident Workforce Management Office (IWMO), Office of the Chief Component Human Capital Officer (OCCHCO), and the Emergency Management Institute. In addition to interviews with officials in FEMA headquarters, we conducted site visits to four FEMA regions. We selected these regions because they were geographically dispersed and had a JFO with both Individual Assistance (IA) and Public Assistance (PA) programs operating as of September 2011. 12 In each of these four regions, we interviewed the Regional Administrator and Regional Cadre Managers. In addition, we visited one JFO in each of the selected regions, where we interviewed the Federal Coordinating Officer and Branch Chiefs. While the information we obtained on these site visits is not generalizable, it provided important insights into the structure and management of the DAE program. To obtain the views of DAEs on issues related to all three of our objectives, we conducted 16 focus group sessions with a total of 125 DAEs across the four selected JFOs. These sessions involved facilitated small-group discussions designed to gain more in-depth information about issues that DAEs face. Each focus group involved 5 to 12 DAE participants. DAE participants were chosen by the management at each JFO. There were four types of focus groups based on DAE job titles: IA and PA supervisors, IA and PA non-supervisors, and supervisors and 10 GAO, Human Capital: A Guide for Assessing Strategic Training and Development Efforts for the Federal Government, GAO-04-546G (Washington, D.C.: March 2004). 11 The Booz Allen Hamilton report we reviewed was preliminary and FEMA could not locate the final report. FEMA stated that they are addressing the observations from this review. 12 Individual Assistance provides the necessary expenses and serious needs of disaster victims that cannot be met through insurance or low-interest Small Business Administration loans. FEMA provides temporary housing assistance to individuals whose homes are unlivable because of a disaster. Public Assistance provides aid to state government agencies; local governments; and private nonprofit organizations or institutions that provide certain services otherwise performed by a government agency. Page 4 GAO-12-538 Disaster Assistance Employees non-supervisors from other cadres other than IA and PA. Specifically, discussion topics included the hiring process, training, policies and procedures, including FQS, and communication by regional managers; however, not all focus group participants had observations about all topics discussed. While the results of the focus groups are not generalizable, the views we obtained from the focus groups provided us with valuable examples of DAE experiences. In addition, we conducted follow-up interviews with 16 regional cadre managers we previously interviewed during our site visits to obtain further perspectives from regional management on hiring, training, deployments, and policies and procedures. In addition, we reviewed FEMA’s April 2012 memorandum announcing the transformation of the DAE program, but did not assess its planned actions to transform the DAE program because the agency is in the early planning stages. For more information on our scope and methodology see appendix I. We conducted this performance audit from April 2011 through May 2012 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. Background FEMA’s Disaster The Robert T. Stafford Disaster Relief and Emergency Assistance Act of Assistance Authority and 1988 (Stafford Act) generally defines the federal government’s role during Declaration Process the response and recovery after a major disaster. It establishes the programs and processes through which the federal government provides disaster assistance to state and local governments, tribes, certain nonprofit organizations, and individuals. 13 FEMA has steady-state and emergency organizational structures. Under a steady-state when FEMA is not in active response to a disaster, FEMA employees conduct activities 13 42 U.S.C. § 5121 et seq. Page 5 GAO-12-538 Disaster Assistance Employees that “strengthen the Homeland Security Enterprise” 14 and perform functions that align with the Quadrennial Homeland Security Review (QHSR) goals 15, which include strengthening capacity to withstand hazards, and improving preparedness in all levels and segments of society. 16 However, when a disaster declaration is requested by a Governor and approved by the President, FEMA executes its emergency organizational structure as discussed below. The Stafford Act establishes the process for states to request a presidential major disaster declaration. 17 Once a declaration has been declared by the President, FEMA may provide disaster assistance pursuant to the authorities in the Stafford Act. In order to request that the President issue a major disaster declaration, a Governor submits a declaration request certifying that the damage requires resources beyond the state’s capability. The request must also include an estimate of the amount and severity of damage and losses and preliminary estimates of the types and amount of disaster assistance needed, among other things. 18 Once a disaster is declared, FEMA provides assistance primarily through one or more of the following three assistance programs: Individual Assistance, Public Assistance, and Hazard Mitigation. 19 Not all programs are activated for every disaster. The determination to activate a program is based on the needs identified during the assessment conducted as part of the declaration request. The Disaster Relief Fund is the major source of federal disaster recovery assistance when a disaster 14 The Homeland Security Enterprise is a partnership among DHS, other federal agencies, the public and private sectors, and communities across the country and around the world, who since 9/11 have worked to better mitigate and defend against dynamic threats, minimize risks, and maximize the ability to respond and recover from attacks and disasters of all kinds. 15 QHSR outlines a strategic framework to guide the activities of homeland security participants. It outlines a vision, specifies mission priorities, and outlines goals for each of the mission areas. 16 Homeland Security Studies and Analysis Institute: Federal Emergency Management Agency Workforce Baseline Assessment, Final Report, March 31, 2010. 17 42 U.S.C. § 5170. 18 44 C.F.R. § 206.36. 19 Hazard Mitigation provides additional funding to states to assist communities in implementing long-term measures to help reduce the potential risk of future damages to facilities. Page 6 GAO-12-538 Disaster Assistance Employees is declared. The Disaster Relief Fund is appropriated no-year funding which allows FEMA to direct, coordinate, manage and fund response and recovery efforts associated with domestic major disasters and emergencies. 20 FEMA’s Disaster Reserve Under the Stafford Act, FEMA has the authority to augment its permanent Workforce and full-time staff with temporary personnel when needed, without regard to Organizational Structure the appointment and compensation provisions governing Title 5 appointments of permanent full-time staff.21 Permanent full-time employees manage FEMA’s day-to-day activities, and a portion of these employees are expected to deploy when a disaster is declared. The DAE is one type of temporary, on-call employee. See appendix II for a detailed description of categories of disaster workforce employees. DAEs comprise the largest portion of the disaster workforce employed under FEMA’s emergency organizational structure. As of February 2012, there were 9,981 DAEs. DAEs are activated to perform disaster activities directly related to specific disasters, emergencies, projects, or activities of a non-continuous nature. 22 DAEs serve two-year appointments, are only paid when they are deployed (including per-diem), and do not receive any Federal benefits with the exception of sick leave, holiday pay, and administrative leave. They are assigned to one of 23 functional disaster cadres. For example, the Individual Assistance cadre provides referrals and guides individuals through the FEMA assistance process, while the Hazard Mitigation cadre assists in educating the public and local governments on methods to reduce the risk of loss of property and life from a future disaster. See appendix III for a description of each cadre and their primary duties. FEMA’s organizational structure is decentralized and comprised of headquarters and ten regional offices. FEMA’s Administrator, in accordance with the Post-Katrina Emergency Management Reform Act of 2006 (Post-Katrina Act), appoints a Regional Administrator to head each 20 No-year funds are available for obligation for an indefinite period of time. 21 42 U.S.C. § 5149(b)(1). Under the provisions of Title 5 governing appointments in competitive service, recruitment of candidates is based on merit where selection is made after a fair and open competition assuring equal opportunity. The candidates are selected based on an application, interview process, and/or examination. 22 FEMA Instruction 8600.1 Disaster Assistance Employee Program. Page 7 GAO-12-538 Disaster Assistance Employees regional office. 23 Regional Administrators—in partnership with state, local, tribal governments, and other nongovernmental organizations—provide emergency management within their respective geographical area. See appendix IV, FEMA’s organizational chart, and figure 1 for a map of FEMA’s regions. 23 6 U.S.C. § 317. Page 8 GAO-12-538 Disaster Assistance Employees Figure 1: Map of FEMA Regions and the Number of Disaster Declarations and Disaster Assistance Employees Per Region in 2011 JFOs are temporary FEMA offices established to respond to declared disasters. JFOs are led by Federal Coordinating Officers and an incident management team that coordinates the activities of the functional disaster cadres deployed for a particular disaster. Once a disaster is declared, FEMA is to deploy DAEs and other FEMA employees as needed, and is to use the Automated Deployment Database to track deployments, training, the initial disaster site location (duty station), as well as monitor overall cadre readiness. Page 9 GAO-12-538 Disaster Assistance Employees Each cadre has a national cadre manager based in headquarters in addition to a regional cadre manager, except for headquarters-based cadres such as the Comptroller and Alternative Dispute Resolution cadres. With respect to the management of DAEs, national and regional cadre managers are responsible for implementing recruitment, hiring, training, development and other administrative policies and procedures developed by the DAE program office. 24 Management of the DAE program has undergone structural changes over the last four years. See appendix V for a timeline of management changes. The Incident Workforce Management Office (IWMO) was established in June 2011, and is currently responsible for the operational elements of the DAE program. The office is organized into four functional units: Deployment, Readiness, FEMA Qualification System (FQS), and Cadre Coordination. See appendix VI for a description of its roles and responsibilities. FEMA Qualification FEMA is undertaking efforts to credential DAEs and the rest of its System and DAE Training workforce. Under the Post-Katrina Act, FEMA is responsible for developing standards for deployment capabilities including credentialing of personnel likely to respond to natural disasters, acts of terrorism, and other man-made disasters. 25 FQS is FEMA’s recent effort to credential all employees in incident management or support positions, including the 24 FEMA Instruction 8600.1 25 6 U.S.C. § 320. Page 10 GAO-12-538 Disaster Assistance Employees DAE workforce, and began development in July 2010. 26 According to FEMA, FQS is a performance-based system whereby employees are determined to be either in Trainee or Qualified status in one of 322 job titles, each of which has a related Position Task Book. Position Task Books outline required activities, tasks, and behaviors, and serve as a record for task completion. According to the Draft FQS Guide, under Trainee status employees meet minimum experience requirements outlined in Position Task Books. Employees can achieve qualified status, or certified, once they complete all the eligibility requirements in the Position Task Book outlined for the specified incident management or incident support positions. 27 FQS seeks to establish standardized position titles, improve job performance, and enable employees to pursue a specified career track. In June 2011, FEMA began the initial qualification determinations for DAEs and began notifying DAEs of their new job titles and status in December 2011. DAEs currently receive almost all of their mandatory and cadre-specific training while deployed to JFOs. Mandatory courses include courses such as Ethics, Sexual Harassment, and Computer Security. In addition to mandatory courses, there are cadre-specific courses offered by FEMA’s Emergency Management Institute. These courses are directly related to the DAE cadres. For example, DAEs in the Public Assistance Cadre have courses in cost estimates and public assistance eligibility. These courses can be delivered at the JFO, or can be taken at one of the Emergency Management Institute campuses; however, the majority of DAEs receive the courses at the JFO. 26 Incident management and support positions are categories of disaster-related work performed in the field, in FEMA Regional Offices, and at FEMA headquarters related to specific incidents. Specifically, incident management positions involve the delivery of federal assistance in the field, operations, and the direct control and employment of resources. The responsibilities of support positions include the deployment of national- level assets, support of national programs affected during the disaster, and support of incident operations. 27 FEMA will begin developing Position Task Books for incident support positions in 2012. Page 11 GAO-12-538 Disaster Assistance Employees FEMA has taken steps to enhance its management of the program, but Opportunities Exist to has not developed or updated policies and procedures that align with the Strengthen Policies day-to-day management of the DAE program. FEMA has not provided guidance for how regional cadre managers should undertake their duties and Procedures That in the management of DAEs. Furthermore, FEMA could better monitor Govern the DAE both its regions’ implementation of DAE policies and DAEs’ Program implementation of FEMA’s disaster policies and procedures in order to reduce the risk of inconsistent application. In addition, FEMA does not have policies and procedures for how it communicates with DAEs when they are not deployed. FEMA Has Not Yet FEMA has not yet developed guidance for cadre managers that outlines Provided Guidance to how they should manage DAEs in their cadre such as guidance for Cadre Managers Related to understanding and handling reserve pay and benefits, the deployment process, training procedures, and evaluation techniques. Specifically, 14 DAE Management of 16 regional cadre managers we interviewed said that they have not seen or are not aware of documented guidance for their duties as cadre manager such as hiring, training, and developing DAEs from headquarters, and 10 of 16 stated that having written guidance would be beneficial to their job. 28 For example, one regional cadre manager said that there are inconsistencies across regions with how cadre managers hire, train, and utilize their DAEs. Another cadre manager added that inconsistent hiring processes affect morale among DAEs. Instructions on how to manage are handed down from experienced colleagues, but are not documented for consistent use, according to another cadre manager. FEMA stated in 1999 that it planned to establish guidelines and requirements for cadre management functions and intended this guidance to be applied consistently at headquarters and in the regions, but this effort was not completed. 29 In 2008, FEMA officials drafted a cadre manager’s handbook; however, the handbook was not finalized or officially adopted across FEMA. The director of IWMO stated that he did not know why the cadre manager’s handbook had not been completed since 2008. In February 2012, during the course of our review, FEMA 28 Of the other 2 regional cadre managers, 1 said that he has not received guidance from headquarters, but has received guidance from the Individual Assistance national cadre manager. The other manager did not provide a response. Regarding the issue of whether having written guidance would be beneficial, the remaining 6 cadre managers did not mention this issue. 29 FEMA Director’s Policy No. 1-99. Page 12 GAO-12-538 Disaster Assistance Employees began its Disaster Workforce Transformation. 30 According to FEMA, this effort includes creating a National Disaster Reservist Program intended to overhaul the current DAE program and examine issues such as cadre management. Further, IWMO officials stated that in fiscal year 2012, they intend to develop a new cadre management handbook, revise FEMA DAE policy, conduct regularly scheduled meetings and conference calls with cadre managers, and conduct a national conference designed to educate cadre managers on their roles. However, FEMA does not have time frames or milestones for completing and disseminating cadre manager guidance as part of its Disaster Workforce Transformation and related activities. In the absence of cadre manager guidance, IWMO officials stated that FEMA Instruction 8600.1, issued in 1991, is the best source for information and guidance on the roles and responsibilities of cadre managers. The document outlines DAE policy for recruitment and hiring, reappointment, appraisals, and benefit eligibility. However, many of its sections are obsolete or inoperative. For example, FEMA Instruction 8600.1 states that the office directors are responsible for the recruitment, selection, training, use, and management of their DAE cadres. According to FEMA, the regional cadre managers currently have these responsibilities; however the 8600.1 policy is not updated to reflect this change in responsibility. In addition, 9 of 16 regional cadre managers we interviewed stated that FEMA Instruction 8600.1 was either outdated, in need of revision, or not applied consistently across the organization. 31 One regional cadre manager said that he would like anything from headquarters with respect to guidance, but all that he has seen is FEMA Instruction 8600.1, which is outdated. This manager added that it was unclear whether any steps have been taken to ensure that FEMA Instruction 8600.1 is applied consistently across regions. Another regional manager said when they have to give new hires a copy of FEMA Instruction 8600.1, they amend the document to reflect recent policy changes. 30 FEMA’s Disaster Workforce Transformation initiative is intended to improve how FEMA prepares, trains, informs, and engages its disaster workforce. 31 Of the remaining cadre managers we interviewed, 2 said that they were not sure whether FEMA Instruction 8600.1 was applied consistently across regions, and 5 did not mention the issue. Page 13 GAO-12-538 Disaster Assistance Employees A 2010 DHS OIG report recommended that FEMA review and update key DAE program benefit policies, procedures, and guidance to eliminate conflicts and inconsistencies between interim policies and permanent overall guidance. 32 In response to the IG’s report, FEMA officials stated that FEMA Instruction 8600.1 was under revision. In March 2012 during the course of our review, FEMA officials stated that the revision of FEMA Instruction 8600.1 has been placed on hold pending the results of FEMA’s fiscal year 2012 workforce transformation initiative to ensure all issues that result from the transformation effort are identified. According to standard practices for program management, an organization should develop a program schedule that establishes the timeline for program milestones and deliverables. 33 Given that FEMA has not completed previous efforts to create guidance for cadre managers, establishing time frames and milestones could help FEMA ensure accountability for completing and disseminating the cadre manager handbook and a revised FEMA Instruction 8600.1. FEMA Could Better FEMA’s decentralized structure allows for flexibility in responding to Monitor Implementation of disasters; however, FEMA does not monitor how the regions implement Policies and Procedures DAE policies, and how DAEs implement disaster policies and procedures. Without such a mechanism, it will be difficult for FEMA to provide assurance that both its regions and DAEs implement DAE policies and disaster policies and procedures consistently. For example, DAEs in focus groups we conducted and regional cadre managers we interviewed expressed concerns about the inconsistency across regions in interpreting FEMA policy. Specifically, they raised concerns about inconsistencies across regions or cadres in how supervisors interpret both DAE administrative policies and/or cadre-specific disaster policies. For example, one focus group participant said that although there are standard policies and procedures, each disaster is different, with different supervisors that interpret these policies differently. Another focus group participant reiterated this point, stating that the regions and cadres direct their DAEs on how to approach disaster tasks differently, which lead to inefficiencies in providing disaster assistance. Participants in the public assistance cadre, for example, raised concerns about the variability that 32 DHS-OIG, FEMA’s Management of Disaster Assistance Employee Deployment and Payroll Processes, OIG-10-115 (September 2010). 33 Project Management Institute, The Standard for Program Management, 2006. Page 14 GAO-12-538 Disaster Assistance Employees exists in how supervisors and managers interpret public assistance policy on documenting damage assessments, leading to differences in how well the worksheets are prepared. One participant stated that there are inconsistencies across regions when preparing the project worksheets used to document disaster damage and provide cost estimates and plans for repair. Specifically, this focus group participant stated that in certain regions DAEs are instructed to focus on the number of worksheets passed through the system. Although it is not referred to as a quota, the participant stated that if a DAE does not achieve this number, he or she will be sent home before completing his deployment. Conversely, in other regions, supervisors and other managers do not apply a goal for the number of worksheets to be completed and are concerned with quality rather than quantity. These variations can lead to inconsistencies in how the worksheets are completed. Another focus group participant stated that the inefficiencies and inconsistencies that run across the board were problematic adding that when determining eligibility for public assistance, sometimes things are made eligible in one state that are not eligible in another state. Moreover, a 2007 Booz Allen Hamilton preliminary report entitled Restructuring and Enhancement of the Intermittent Disaster Workforce System also identified inconsistencies in the application of policies and standard operating procedures across regions and cadres. 34 In March 2012 during the course of our review, FEMA officials stated that the agency intends to establish a centralized management structure responsible for the development of FEMA disaster assistance policies and procedures. FEMA policy states that headquarters is responsible for developing the agency’s policies and procedures for disaster assistance and the regional offices are responsible for the implementation of these policies and procedures. We recognize that FEMA’s decentralized structure allows for flexibility in handling disasters as each region can encounter different types of disasters and the regional structure can facilitate disaster assistance. In a February 2012 FEMA town hall meeting, FEMA’s Administrator acknowledged that there are inconsistencies across the FEMA regions, and noted that due to differences in how regions operate, it is problematic to deploy someone 34 Booz Allen Hamilton, Restructuring and Enhancement of the Intermittent Disaster Workforce System: Preliminary Findings Report (Herndon, Va.: Booz Allen Hamilton, 2007). The Booz Allen Hamilton report we reviewed was preliminary and FEMA could not locate the final report. FEMA stated that they are addressing the observations from this review. Page 15 GAO-12-538 Disaster Assistance Employees based in one region to another during a disaster. 35 Moreover, a regional cadre manager we interviewed cited inconsistency in policy application saying, “there is an ongoing problem of the right hand not knowing what the left hand is doing with respect to when policies are implemented or are in conflict with one another”. Without routinely monitoring how disaster policies and procedures are being implemented across regions by DAEs and how the regions implement DAE policies, FEMA lacks reasonable assurance that it is administering its disaster assistance consistently across regions in accordance with its mission. Standards for Internal Controls in the Federal Government call for an organization’s controls to be designed to assure that ongoing monitoring occurs in the course of normal operations and that it includes regular management and supervisory activities, comparisons and reconciliations. 36 Moreover, according to FEMA’s Capstone Doctrine, which describes FEMA’s mission, purpose, and defines the agency’s principles, FEMA advocates the practice of consistent decision making by those with authority to act. 37 Establishing a mechanism to ensure routine monitoring of the regional implementation of DAE policies and procedures, as well as how DAEs implement disaster policies, could help provide FEMA with reasonable assurance that disaster assistance is being implemented by DAEs in accordance with policy and consistently across regions. Opportunities Exist to FEMA does not have policies and procedures for how it will communicate Communicate Cadre- cadre-specific information to DAEs when not deployed. Most DAEs do not Specific Information More have access to cadre-specific information when not deployed, although FEMA has recently taken steps to increase communication. The majority Consistently with DAEs of the cadre-specific information for DAEs is housed on FEMA’s internal When Not Deployed website and is not accessible by DAEs when they are not deployed. This is because when DAEs are not deployed, they do not have access to their FEMA-issued equipment such as laptops, as well as their FEMA e-mail accounts. As a result, DAEs are not able to access information directly, including changes in policies and procedures that may occur while they 35 In February 2012, FEMA conducted a series of town hall meetings for all FEMA employees, including DAEs, in all 10 FEMA regions and headquarters. 36 GAO/AIMD-00-21.3.1. 37 The Federal Emergency Management Agency Publication 1, November 2010. Page 16 GAO-12-538 Disaster Assistance Employees are not deployed, and may not immediately be prepared to provide assistance to survivors during a disaster. Once DAEs are deployed to a disaster, they are typically provided equipment, such as laptops, and FEMA e-mail addresses, which are used to receive policy and procedural updates. However, DAEs in the focus groups we conducted raised concerns about their inability to access this type of information prior to being deployed to a disaster. For example, one focus group participant told us that it is difficult to keep up with changes as they happen when they are not deployed because they receive very little information when they are not deployed. Another focus group participant told us that they cannot access policy changes because they do not have access to information behind FEMA’s firewall. We also heard from one DAE that because she was not provided program information related to her job, it was difficult for her to feel comfortable representing FEMA to disaster victims without access to information such as materials related to applicant services. Thirteen of 16 regional cadre managers we interviewed said that they communicate policy and procedural updates to DAEs when they are not deployed via personal e-mail accounts, however, not all cadre managers believe that it is their responsibility to convey policy updates to their DAEs when they are not deployed. For example, one cadre manager who is responsible for 180 DAEs told us she believes that policy changes should come from FEMA headquarters and should be posted on FEMA.gov. Consequently, this cadre manager does not forward policy changes to personal e-mail accounts. According to another cadre manager, communicating policies and procedures to DAEs when they are not deployed is difficult because DAEs are completely disconnected from the mechanisms typically used to share information with FEMA staff during non-deployment. Further, he added that this proved to be a problem during disasters in 2010 where DAEs that had not been deployed for a while were unfamiliar with FEMA’s recent policy updates. The manager said this situation was problematic because management did not always have the time to walk these DAEs through policy changes. Ultimately, this lack of access to information among DAEs had an impact on DAE readiness because it extended their learning curve and potentially created delays in providing service in some cases. According to an official from FEMA’s Office of the Chief Information Officer, cadre managers have developed their own strategy for communicating with DAEs when they are not deployed. In addition, Page 17 GAO-12-538 Disaster Assistance Employees officials from IWMO told us that cadre managers are best suited to determine the precise information and content that will meet the needs of their respective cadre. Therefore, cadre managers are encouraged by IWMO to develop informative resource pages for their DAEs. For example, we found that the Hazard Mitigation cadre has developed a platform to communicate and share a vast array of resources with DAEs without access to FEMA’s internal website. Specifically, Hazard Mitigation’s disaster workforce resources are available on both FEMA’s internal website as well as the Hazard Mitigation Disaster Workforce portal on the Homeland Security Information Network (HSIN), which can be accessed via any Internet connection with a login and password. The portal provides resources for each of the different functional areas of Hazard Mitigation, including web links, contact information, tasks books, job aids, policies, publications, and training materials for the Hazard Mitigation workforce. However, as of March 2012, these tools were limited to the Hazard Mitigation Cadre. According to IWMO, other cadres, including Alternate Dispute Resolution, Community Relations, Individual Assistance, and Environmental & Historic Preservation have internal websites that contain programmatic policies and procedures. However, these sites are not readily available to DAEs who do not have access to FEMA’s internal website. In a budget-constrained environment, leveraging existing mechanisms can help agencies achieve efficiencies. While our prior work has identified issues with the HSIN platform, it could be used to provide DAEs greater access to FEMA resources. 38 According to FEMA’s Office of the Chief Information Officer, HSIN would be an 38 In April 2007, we reported that when coordinating efforts between HSIN and other state and local information-sharing initiatives, DHS did not fully adhere to key practices aimed at enhancing information sharing, collaboration, and avoiding duplication nor did it develop compatible policies, procedures, and other means to operate across organizational boundaries. We recommended, among other things, that DHS assess whether there are opportunities for HSIN to improve information sharing and avoid duplication of effort; and where there are opportunities, implement effective coordination and collaboration practices. DHS largely agreed with our recommendations and initiated actions to implement them including creating the HSIN Advisory Council—a HSIN user group composed of representatives from state, tribal, and local governments and the private sector—which met to discuss HSIN information-sharing activities and provided strategic- level recommendations. DHS also created the HSIN Mission Coordinating Committee—a user group composed of representatives from DHS’s components (e.g., the Office of Infrastructure Protection, the Coast Guard, and the Federal Emergency Management Agency)—to address their respective users’ requirements for HSIN. GAO, Information Technology: Numerous Federal Networks Used to Support Homeland Security Need to Be Better Coordinated with Key State and Local Information-Sharing Initiatives, GAO-07-455 (Washington, D.C.: Apr. 16, 2007). Page 18 GAO-12-538 Disaster Assistance Employees appropriate tool for DAEs to use to stay connected to FEMA because it would allow them access to pertinent information from anywhere and would not represent an additional cost to FEMA. Inconsistent access to information among non-deployed DAEs, in addition to inconsistent communication strategies with DAEs among regional cadre managers, may hinder FEMA’s mission of providing assistance to disaster survivors, by extending the amount of time it takes DAEs to familiarize themselves with the most current cadre-specific policies and procedures when they are deployed. However, FEMA has taken some steps to improve DAEs’ access to information when they are not deployed. For example, part of FEMA’s Disaster Workforce Transformation includes plans intended to increase communication to DAEs. FEMA stated that it plans to have consistent, two-way communication with DAEs even when they are not deployed. According to FEMA, this communication will include sending weekly e-mails about agency activities to each of the personal e-mail addresses it has on file for its entire workforce and developing a dedicated employee-focused website accessible to all of its employees. However, the employee- focused website contains a minimal amount of cadre-specific information. Since FEMA will rely on its cadres to provide their own content, the extent to which FEMA’s new centralized employee-focused website will include cadre-specific policies and procedures that DAEs need to perform their duties while deployed, such as those provided by the Hazard Mitigation cadre via its HSIN portal, is not clear. For example, as of March 2012, FEMA’s publicly available website for its employees included an Employee Information and Resource Center that houses general information such as travel policies, newsletters, and information related to the FEMA’s Disaster Workforce Transformation and FQS. Unlike the Hazard Mitigation portal on HSIN, FEMA’s employee website did not include cadre-specific information such as Concept of Operations documents that describe how specific cadre efforts are conducted in the pre- and post-disaster environment, or field office guides and Go Kits which contain cadre-specific guidance, which are resources that DAEs can access to better prepare themselves for future disasters while they are not deployed. As part of FEMA’s Disaster Workforce Transformation efforts, it developed an employee-focused website; however, according to FEMA, the new employee website was not intended to be a long-term solution, nor was it intended to replace FEMA’s internal website used to communicate with its workforce. FEMA has not developed a plan with milestones for how it will communicate not only general information but Page 19 GAO-12-538 Disaster Assistance Employees cadre-specific information to DAEs when they are not deployed. According to FEMA, the agency is examining other solutions that would allow the agency’s entire workforce to have access to all information, but a specific time frame has not been determined. According to standard practices for program management, an organization should develop a program schedule that establishes the timeline for program milestones and deliverables. 39 As FEMA implements its Disaster Workforce Transformation, developing a plan with time frames and milestones for how it will better communicate cadre-specific policies, procedures, and other information to DAEs when they are not deployed would provide FEMA with a roadmap to help ensure that it is providing DAEs the tools they need to be prepared for disaster deployments. FEMA has not established standardized hiring or salary criteria to help FEMA Could ensure that basic qualifications are met by prospective DAEs, and that Strengthen Human regional managers consistently determine initial DAE salaries and award promotions. Moreover, FEMA’s performance appraisal system for DAEs Capital Management does not adhere to internal control standards, which would help ensure Controls that managers have information to better inform performance management decisions. FEMA Has Not Established FEMA has not established standardized hiring criteria for prospective Standardized Hiring and DAEs, and FEMA headquarters provides limited guidance to regions on Salary Criteria for DAEs which to base DAE salary determinations. Hiring Criteria According to FEMA Instruction 8600.1 of 1991, the primary document outlining DAE program policies, regional cadre managers are responsible for the recruitment, selection, use, and management of their respective DAE cadres. Our review of policies and interviews with regional cadre managers as well as officials in FEMA headquarters indicate that DAEs are hired by regional cadre managers without being assessed against established criteria to determine their qualification for the position. Regional cadre managers make the initial hiring selection, and then send a hiring package with the individual’s qualifications and a proposed salary to the Office of the Chief Component Human Capital Officer (OCCHCO). OCCHCO officials stated that they then review the individual’s package to 39 Project Management Institute, The Standard for Program Management, 2006. Page 20 GAO-12-538 Disaster Assistance Employees verify that the selected individual is qualified for the position and that the proposed salary is appropriate based on experience and skills described in the individual’s resume. However, criteria used by OCCHCO officials in assessing the qualifications and pay of a DAE applicant are not documented; rather, OCCHCO officials stated that these decisions are based on general knowledge. An OCCHCO official who reviews the hiring package containing the applicant’s paperwork said that she believes that regional cadre managers do not always use the same criteria for evaluating qualifications and selecting a DAE candidate as the OCCHCO official uses in approving the proposal. In addition, a regional cadre manager from Hazard Mitigation said that the national cadre manager at headquarters provides guidance for hiring. In contrast, another regional manager said that there is no written guidance available, and that regional cadre managers are on their own in making hiring decisions. According to OCCHCO, the agency’s hiring criteria for DAEs is contained within FEMA Instruction 8600.1. 40 This policy states that “consideration should be given to the specific job functions, the qualifications required to perform those jobs, and Equal Employment Opportunity requirements.” However, the policy does not provide explicit information on the qualifications for different cadres or positions, such as the relevant experience, education, or skills. For example, there is no FEMA-wide guidance on the preferred skills and experience of prospective DAEs for a given position in the IA cadre or the PA cadre, which focus on different aspects of assistance, and thus, require different expertise. OCCHCO officials agreed that it would be useful to have a list of bulleted skills and qualifications that are desired by each cadre for making hiring decisions. An OCCHCO official who reviews hiring and salary recommendations said there is no specific guidance provided to regions related to hiring criteria, other than FEMA Instruction 8600.1, because they believe that the regions have competent people hiring DAEs. 40 In addition, FEMA officials stated that the Position Task Books created for the credentialing process prior to FQS are being used to provide guidance and direction to the regions regarding hiring DAEs. FEMA officials said that as the agency implements the FEMA Disaster Workforce Transformation, meetings will be held between OCCHCO, IWMO, and the cadre managers to discuss how the FQS Position Task Books will be used to determine qualifications and set salaries. However, as of April 2012 there was no written policy or guidance instructing the regions to use the Position Task Books for hiring purposes. Page 21 GAO-12-538 Disaster Assistance Employees The 2007 preliminary report by Booz Allen Hamilton on FEMA’s disaster workforce stated that the lack of standardization in recruitment standards, interviewing processes, and hiring practices led to a wide disparity in the qualifications of DAEs across the regions, which the report noted may impair FEMA’s ability to effectively respond to a disaster. 41 Moreover, one regional cadre manager said that morale is lowered when unqualified DAEs are hired, and another said that many DAEs complain that there is significant variation across regions in terms of the skills required for different positions. In addition, a DAE who participated in our focus group stated that if FEMA had asked the right questions, he would not have been hired, since he did not have the necessary technological skills to use the laptop, GPS, and digital camera that FEMA provided to him. Standards for Internal Controls in the Federal Government call for agencies to identify appropriate knowledge and skills needed for various jobs. According to FEMA, when FQS is implemented in 2012, position- specific training and position task requirements will be defined for each of the 322 positions to provide more specificity; however, FEMA could not provide details about how or if this will translate into better hiring criteria for prospective DAEs. 42 By standardizing hiring criteria, FEMA would be better positioned to hire people with the requisite skills and have reasonable assurance that hiring decisions are being made consistently across regions. Guidance for Salary In addition, FEMA headquarters provides limited guidance for regions to Determinations use to make DAE salary determinations. According to a FEMA official, in addition to FEMA Instruction 8600.1, the “Grant C. Peterson Memo” (Peterson Memo) of 1992 put forth guidance for pay levels and promotions. 43 This guidance outlines five pay grades (A through E), as well as the three levels within each pay grade and relates these pay grades to their approximate GS or GM federal grade level. 44 The 41 Booz Allen Hamilton, Preliminary Findings Report, 27. 42 FEMA could not provide details about how FQS will translate into better hiring criteria for prospective DAEs in addition to identifying the requisite training and skills needed by newly hired DAEs to become qualified under FQS. 43 See appendix VII for DAE pay scale. 44 The General Schedule (GS) system is a graded pay system established under the Classification Act of 1949. GM (General Manager) employees were formerly paid under the Performance Management and Recognition System (PMRS). GM employees are now paid under the GS system. Page 22 GAO-12-538 Disaster Assistance Employees Peterson Memo states that all DAEs will be given a tentative pay grade at the time of the initial appointment, and within 90 days a decision will be made as to whether or not that tentative grade is appropriate or should be changed to a different grade. The Peterson Memo lists position titles that would be assigned to Grades A through E, but it does not clarify how a DAE is to be assigned to one of the three levels within each grade. 45 In addition, the memo does not establish criteria on which to base initial salary decisions or reconsiderations within the 90-day window. An OCCHCO official stated that it is possible that cadre managers have developed their own criteria for placing DAE hires in certain pay categories. For example, the OCCHCO official noted that some cadre managers bring everyone in on a C-1 level (approximately $21/hour) until they are able to “learn about the organization,” a process which is not quantified or measured. We noted variation among regional cadre managers with respect to pay determinations, with some managers proposing pay according to the candidate’s experience, and others basing pay determinations solely on the job title. For example, six regional cadre managers said that pay determinations depend on the candidate’s experience, education, and background and one added that individuals with the same job title could be paid differently depending on their experience. In contrast, three different regional cadre managers said that pay is based on the job title or position the DAE is hired to fill; for example, one said that a data entry DAE would start in the A or B pay grade, while construction managers would be assigned to the C pay grade. Variation in salaries across regions and cadres can lower morale among DAEs who are deployed in multiple regions and notice DAEs that are paid more despite having less responsibility, according to two regional cadre managers. A senior FEMA official in a recent “town hall meeting” acknowledged that there have been issues with the pay and promotion system for DAEs for many years, and that leadership will be looking at the issue. In addition, the Assistant Administrator for Response said that there is currently no consistency with pay determinations or raises, and that changes to the pay system will be a part of FEMA’s Disaster Workforce Transformation. Additionally, 8 of 16 regional cadre managers we interviewed stated that they do not receive guidance or would like to 45 For example, the Peterson Memo states that a Data Entry Clerk is to be considered a Grade A; a Program Assistant (PA) is to be considered a Grade B; a PA Inspector is to be considered a Grade C; a Program Officer (IA) is to be considered a Grade D; and an Audit Manager is to be considered a Grade E. Page 23 GAO-12-538 Disaster Assistance Employees receive more guidance related to salary determinations, including the criteria used by headquarters. 46 FEMA headquarters could clarify what kind of professional experience gained prior to joining FEMA is considered relevant for different positions and cadres or to what extent disaster-specific responsibilities may factor into salary determinations. Ten of 16 regional cadre managers said that headquarters has previously denied pay determinations proposed by the region, and two of these regional cadre managers responded by asking the applicant to revise his or her resume and re-send it to headquarters. 47 One of these regional cadre managers noted that he did not know what headquarters was looking for when making decisions regarding whether to place a candidate in pay Grade B or C. During recent town hall meetings between agency leadership and employees, a FEMA official acknowledged that pay grade distribution and pay raise inconsistencies are an issue in the DAE program. The Assistant Administrator for Response noted that more than 90 percent of DAEs are in the C category or above, and as a result there are DAEs in higher pay grades performing work that should be done by lower-paid DAEs. According to FEMA officials, they will be looking into these issues as part of FEMA’s Disaster Workforce Transformation. In addition, FEMA officials noted that FQS will institutionalize pay determinations for DAEs based on job title, but as of March 2012, they could not provide details regarding this effort. Standards for Internal Control in the Federal Government state that good human capital policies and practices should include establishing appropriate practices for compensating and promoting personnel. We have reported that agencies may abide by these standards by basing compensation on achievements and performance. By establishing standardized criteria for making DAE salary and promotion determinations, FEMA could increase transparency around salary determinations and reduce unnecessary variation across regions. 46 Of the other 8 cadre managers, 3 had received some guidance related to salary determinations, and the remainder did not indicate whether or not they had received guidance. 47 Of the other 6 cadre managers, 3 said that they had not received any denials from headquarters and 3 did not mention whether they had received any denials or their response was inconclusive. Page 24 GAO-12-538 Disaster Assistance Employees Performance Appraisals FEMA’s performance appraisal system for DAEs is not consistent with for DAEs Do Not Adhere internal control standards, which would help ensure that managers have to Internal Control information to better inform performance management decisions. 48 Standards for Internal Control in the Federal Government state that Standards agencies should establish appropriate practices for evaluating, counseling, and disciplining personnel. 49 In addition, these standards state that effective management of an organization’s workforce include identifying appropriate knowledge and skills needed for various jobs and providing candid and constructive counseling, and performance appraisals. We have previously reported that agencies could adhere to these internal control standards through a number of actions, such as ensuring that: • promotions and compensation of employees are based on periodic performance appraisals; • employees are provided with appropriate feedback and given suggestions for improvement; or that • employment is terminated when performance is consistently below standards. 50 Performance appraisal systems are intended to provide agencies with information related to the effectiveness of employees and serve as a mechanism to identify and improve performance deficiencies. FEMA’s performance management system for DAEs is based on a performance appraisal form that is not consistent with internal control standards, which state that counseling should be candid and constructive. According to FEMA Instruction 8600.1, supervisors are required to complete a performance appraisal form for DAEs at the end of each DAE’s deployment. As shown in figure 2, all DAE reservists are rated on seven 48 According to FEMA, the DAE performance process is not an OPM-approved program. However, we have reported in GAO/AIMD-00-21.3.1 that implementing effective internal controls is a key factor in achieving agencies’ missions and program results. 49 GAO/AMID-00-21.3.1. 50 GAO, Internal Control Management and Evaluation Tool, GAO-01-1008G, August 2001. This is a guide that GAO produced to assist agencies in maintaining or implementing effective internal controls. This tool is not required to be used, but it is intended to provide a systematic and structured approach to assessing the internal control structure. Page 25 GAO-12-538 Disaster Assistance Employees elements, and supervisors are rated on an additional seven elements. 51 In addition, there is a narrative portion of the performance appraisal form where supervisors are required to include written comments. Figure 2: Disaster Assistance Employee Performance Appraisal Elements 51 FEMA Form 90-106, the Performance Appraisal for the Disaster Assistance Program, may be used to evaluate the performance of any FEMA employee deployed to a disaster, including Permanent Full-Time, Cadre of On-Call Response/Recover Employees and DAEs. Page 26 GAO-12-538 Disaster Assistance Employees For each element, a DAE may be given an “S” for Satisfactory, “U” for Unsatisfactory, or “N/A” if a supervisor had no opportunity to observe the DAE’s performance; these ratings are essentially a pass/fail system. However, it is unclear what constitutes successful completion of each element, and FEMA headquarters has not provided any written guidance to regions for assigning ratings. For example, FEMA lacks criteria that can be used to make the determination that a DAE should receive an S or a U for a given element. FEMA Instruction 8600.1 addresses what cadre managers should do with the appraisal form, but not specifically how to assign a rating and what content managers should include in the narrative portion. Eleven of 16 regional cadre managers we interviewed stated that DAEs are not given honest appraisals. 52 These regional cadre managers stated that ratings are not always an accurate reflection of performance because currently there is a conflict of interest because supervisors (who are also DAEs) must evaluate subordinate DAEs who could be their supervisors in the next deployment. According to the Director of IWMO, when FQS is implemented in fiscal year 2012, DAEs will continue to supervise other DAEs in the field. This official said that the qualification requirements under FQS will help ensure that the supervising DAEs have the professionalism to manage other DAEs. However, given the fact that DAEs may continue to serve at levels below the one for which they are qualified, the conflict of interest could continue. While we recognize that ensuring supervisors provide candid ratings can be challenging for agencies, strengthening the controls in place for developing performance ratings could help FEMA provide both managers and DAEs more meaningful performance information. In addition, the performance appraisal system could be more transparent by providing managers with additional information to use when making performance management decisions. For example, because the appraisal form usually provides little information to managers regarding a DAE’s performance during a disaster, one regional cadre manager noted that branch directors contact the regions and let them know of any problems with their cadre members. The manager added that instead of or in addition to reviewing the performance appraisal forms, supervisors and managers must make phone calls and send e-mails to give a picture of a DAE’s performance and areas for improvement. In addition, it is not clear 52 Of the other 4 regional cadre managers, 2 said that they had given unsatisfactory ratings or that ratings were honest, and 2 did not mention this issue. Page 27 GAO-12-538 Disaster Assistance Employees how performance appraisals are utilized in decisions related to reappointment, performance deficiencies, pay, and promotions for DAEs. FEMA headquarters has not provided guidance to regions to clarify these issues, according to 13 of 16 regional cadre managers and OCCHCO. 53 According to an IWMO official, the office previously known as Disaster Reserve Workforce Division had been actively involved in redesigning the performance appraisal process, including improving the appraisal form and maintenance of performance records. However, he said that when the office was revamped and realigned into IWMO, the effort languished. IWMO and OCCHCO officials noted in March 2012 that performance management is a critical component of the supervision of DAEs and stated that it must be improved in fiscal year 2012 during FEMA’s Disaster Workforce Transformation effort. However, FEMA does not currently have specific plans to revamp the performance appraisal system. 54 We have previously reported that one of the key practices for effective performance management is making meaningful distinctions in performance, including providing management with the objective and fact- based information it needs to recognize top performers and providing the necessary information and documentation to deal with poor performers. 55 Similarly, we have previously reported that performance appraisals should provide meaningful distinctions in performance for staff, which is difficult to accomplish with a pass/fail system. 56 We also reported that a limited number of performance categories may not provide managers with the information they need to reward top performers and address performance issues, as well as deprive staff of the feedback they need to improve. 57 In addition, 13 of 16 regional cadre managers stated that the 53 Of the other 3 regional cadre managers, 2 said that FEMA had provided guidance and 1 did not mention this issue. 54 According to FEMA, FQS will not replace performance appraisals, and the system being identified to support FQS does not store performance appraisal documentation. 55 GAO, Results-Oriented Cultures, Creating a Clear Linkage between Individual Performance and Organizational Success, GAO-03-488 (Washington, D.C.: Mar. 14, 2003). 56 GAO, Financial Regulators: Agencies Have Implemented Key Performance Management Practices, but Opportunities for Improvement Exist, GAO-07-678 (Washington, D.C.: June 18, 2007). 57 GAO, Veterans’ Benefits: Improvements Needed in VA’s Training and Performance Management Systems, GAO-08-1126T (Washington, D.C.: Sept.18, 2008). Page 28 GAO-12-538 Disaster Assistance Employees appraisal process could be improved in various ways, such as implementing a rating scale instead of a pass/fail rating. 58 Specifically, using multiple rating levels provides a useful framework for making distinctions in performance by allowing an agency to differentiate, at a minimum, between poor, acceptable, and outstanding performance. We have reported that two-level rating systems by definition will generally not provide meaningful distinctions in performance ratings, with possible exceptions for employees in entry-level or developmental bands. 59 Similarly, a 2007 preliminary report by Booz Allen Hamilton on the DAE program found that there was a lack of standardization and fairness in the performance review system, specifically that the system was not managed evenly and did not distinguish between levels of performance. 60 The report noted that an inadequate performance review system affects the development and assignment of DAEs, as well as their contribution to FEMA’s overall response to disasters. Taking steps to establish a more rigorous performance management system that addresses the weaknesses we identified could help provide FEMA with more information regarding how effectively DAEs are performing and a mechanism to identify and improve any performance deficiencies. By providing clear criteria and guidance for assigning ratings, as well as how the ratings are to be used, FEMA could help to ensure that DAEs’ performance appraisals better reflect actual performance and provide managers with information to better inform performance management decisions. FEMA’s DAE training is not consistent with key attributes of effective FEMA’s DAE Training training and development programs that could help to ensure that its Is Not Consistent with training and development investments are targeted strategically. FEMA does not have a plan to ensure that all DAEs receive required training Key Attributes of under FQS, which would ensure accountability for qualifying DAEs. In Effective Training and addition, FEMA does not track how much it spends on DAE training, Development which hinders FEMA’s ability to plan for future training. Programs 58 The other 3 regional cadre managers did not provide a response regarding how the performance appraisal process could be improved. 59 GAO-07-678. 60 Booz Allen Hamilton, Preliminary Findings Report, 7. Page 29 GAO-12-538 Disaster Assistance Employees FEMA Does Not Have a FEMA does not have a plan with time frames and milestones to ensure Plan to Ensure DAEs DAEs receive training, including required training for its new credentialing Receive Required Training program, FQS. FEMA provides the majority of its training to DAEs in the field during disasters. Under FQS, DAEs must complete required training and demonstrate successful performance in specific areas in order to be qualified in their job title. Therefore, DAEs’ career track will be aligned to their deployments, and subsequently tied to their opportunities to participate in field training. Regional cadre managers and DAEs we spoke with had concerns about the amount of training DAEs received during disasters as well as FEMA’s reliance upon on-the-job training for new DAEs due to limited training opportunities. Thirteen of 16 regional cadre managers said that they would like more opportunities for DAEs to receive training. 61 For example, one Human Resource cadre manager said that required training courses were not available the past year, and that some courses, such as those developed for human resource managers, had not been offered for 3 or 4 years. In addition, one DAE said that the amount of training they received was insufficient and added that it was a disservice to the applicants for FEMA assistance because DAEs may not know how to properly assist the public. Another DAE, who also holds a management position, told us that half of the DAEs deployed in Community Relations in his current disaster did not have any training other than on-the-job training. Furthermore, IWMO officials said some regions provide general pre-deployment orientation materials, such as instructions on completing certain administrative tasks; otherwise, it is up to the cadre manager to provide DAEs information pertinent to their assignment prior to their deployment. Therefore, the extent to which a DAE receives orientation depends on the cadre, the region, and the timing of deployments. Under FQS, DAEs will be assigned job titles, and each DAE will either be designated as a trainee or qualified for that job title. For a DAE to become qualified, they must complete required training and meet the minimum number of deployments and various deployment experiences. According to FEMA, approximately 20 percent of the current DAEs (2,005 of 9,981) are considered trainees and will need training and future deployments to become qualified. However, according to FEMA, as of March 2012, 136 courses were not available because they were being revised or not yet 61 None of the remaining 3 cadre managers provided a response concerning the topic of providing more opportunities for DAEs to receive training. Page 30 GAO-12-538 Disaster Assistance Employees developed. In addition, FEMA stated that of the 136 courses, 83 are in various stages of pilot testing and they have developed a schedule to revise or develop courses through the end of fiscal year 2012. Officials said that if a course will not be developed in the foreseeable future, exemptions can be made for the DAE to be fully qualified if they have completed the remaining requirements. According to key attributes for federal training programs, agencies should have agency planning documents such as training plans, and training and development design and evaluation documents, which focus on identifying targeted performance improvements and report on progress in achieving results. 62 As previously mentioned, successful organizations should also establish timelines for program milestones and deliverables. 63 According to FEMA officials, the agency has begun an initiative intended to identify the number of personnel, by position, needed to respond to and manage various incidents. It is also intended to determine the number of training courses they will need based on the number of open position task books. In fiscal year 2012 FEMA plans to implement this initiative as well as FQS in order to develop a plan to train DAEs, according to the agency. However, FEMA officials also said that qualifying all DAEs under FQS will depend on each DAE’s commitment to making themselves available for deployments and the level of disaster activity. DAEs are required to update their availability for deployments at least every 30 days, and must be available for deployments for at least 60 days a year. FEMA does not have a plan or time frames in place to ensure that all DAEs are qualified under FQS and receive required training; instead, FEMA is depending on DAEs to commit to be deployed. A plan with time frames and milestones for how and when it will train all of its DAEs will provide FEMA with a roadmap and ensure accountability for qualifying DAEs under FQS. Systematically Tracking FEMA does not track how much of the Disaster Relief Fund is spent on Training Cost Could Allow training for DAEs while deployed to JFOs. As a result, FEMA does not FEMA to Better Plan for have a comprehensive picture of costs and expenses, and other financial information related to training and development activities. All expenses Future Training Expenses incurred at a JFO, including training costs, are funded by the Disaster Relief Fund. Comptrollers at the JFO are responsible for approving and 62 GAO-04-546G. 63 Project Management Institute. Page 31 GAO-12-538 Disaster Assistance Employees monitoring all the funds used at a JFO; however, they are not required to track the training costs. The Disaster Field Training Operations cadre is responsible for developing a training plan based on the training needs of the DAEs deployed to a particular JFO. The training plan then must be approved by the Federal Coordinating Officer. FEMA’s Deputy Director for Field Operations said the plan does not include the costs associated with the recommended courses unless the training is being provided by a contractor. Costs associated with training—such as travel expenses, per diem for the instructors, and copy materials—are all included in the administrative costs of the JFO. FEMA’s Deputy Director for Field Operations further stated that there is no accounting code specific to training costs, therefore, the agency does not currently have the needed information to identify those costs specific to completed courses. The official added that FEMA maintains a few codes that have some relationship to training, such as a code for training-related office supplies and printing costs. The official noted that it may be possible to accumulate all of the training-related codes that are currently in existence and come up with an estimate of the total cost associated with training; however, this figure would not provide a complete picture of training costs. FEMA’s Disaster Readiness and Support account is part of the Disaster Relief Fund. It funds generalized, non-disaster specific initiatives such as training that provides disaster readiness and preparedness support across FEMA. In fiscal year 2011, the Disaster Readiness and Support account totaled $304.7 million, of which $9 million was dedicated to disaster-related training for all FEMA employees, including DAEs. Of the $9 million, $3 million of this is dedicated to pay for the salaries and benefits of DAEs while they are deployed solely for training. According to FEMA, the amount of the Disaster Readiness and Support account is determined by working with FEMA offices annually to review their requirements. A spend plan is created and then reviewed and approved by FEMA’s Deputy Administrator, DHS and the Office of Management and Budget before transmittal to Congress. Prior to fiscal year 2012, the Emergency Management Institute was responsible for managing the $9 million in disaster specific training funds. This responsibility is now with IWMO; however, according to IWMO officials, they are still coordinating their efforts with the Emergency Management Institute. According to the Emergency Management Institute, it cannot separate how much of the Disaster Readiness and Support account is spent on DAE training, except for the $3 million allocated for salaries and benefits. According to IWMO officials, in fiscal Page 32 GAO-12-538 Disaster Assistance Employees year 2013 they will begin funding the majority of training courses in JFOs using the Disaster Readiness and Support account rather than the more general Disaster Relief Fund. As of March 2012, the fiscal year 2012 spend plan and projected future costs had not been finalized. However, IWMO officials said that the proposed fiscal year 2012 budget for FQS is $7.8 million, which was based on the training budget of prior years’ training as well as future needs. According to key practices for training management, agencies should have accounting, financial, and performance reporting systems that produce credible, reliable and consistent data on agency activities, including training and development programs. 64 Since FEMA does not know how much money it historically has spent on training at the JFOs using the Disaster Relief Fund, it does not have a complete picture of the total cost to train DAEs both at the Emergency Management Institute and at the JFOs each year. Further, FEMA does not have reasonable assurances that the proposed fiscal year 2013 FQS budget is at an appropriate level to cover the total training costs. Without a systematic process to track training costs, FEMA does not have a complete picture of training, including its total costs. Developing a systematic process to track such training costs would provide FEMA with additional information to inform decisions about allocating future funding for training and assist it in doing so effectively. On April 17, 2012 FEMA announced plans to transform the DAE program. FEMA Announced Among the changes, FEMA will change the name to the FEMA Reservist Impending Program. According to FEMA, as of June 1, 2012, the agency will begin offering DAEs the opportunity to seek new appointments in the Reservist Transformation of Program by applying for specific incident management positions within DAE Program, but It FQS. The Reservists selected at the end of the application process will be Is Too Soon to assigned to nationally managed cadres, which will replace all regionally- based cadres by the end of 2012. FEMA announced that as of July 1, Evaluate the 2012, DAEs who transition to the Reservist Program before the end of Effectiveness of the 2012 will have their pay “grandfathered” into the new program and therefore be exempt from the new rules regarding having pay determined Agency’s Planned based on their FQS position. In addition, FEMA stated it will establish a Actions goal and policy to deploy all Reservists at least once per year with the length of the deployment depending on operational needs, which is intended to ensure that all Reservists have the current incident response 64 GAO-04-546G. Page 33 GAO-12-538 Disaster Assistance Employees experience and demonstrated performance required by FQS. Furthermore, FEMA stated that it will begin providing Reservists required FQS training by utilizing a portion of annual deployment days and allowing Reservists to complete some mandatory training from home. Moreover, FEMA announced that it would be issuing Reservists mobile communication and computing equipment upon their first deployment, to ensure that they are mission ready immediately upon checking into a disaster and that they have continuous access to the FEMA network and FEMA e-mail, if they choose, regardless of deployment status. These efforts, if implemented effectively should address a number of the challenges we identified with FEMA’s management of the DAE program. However, FEMA has not identified specifics to these broad plans that allowed us to evaluate the effectiveness of its planned actions. Therefore, it is too soon to determine whether the planned actions will be implemented as stated and whether they will fully address the problems we identified. FEMA relies heavily upon DAEs to respond to disasters. The agency has Conclusions taken steps to improve the program, such as establishment of a credentialing program, FQS, and a planned transformation of the DAE program; however, it is too soon to assess the extent to which these efforts will address the challenges we identified with FEMA’s management of the DAE program, the workforce, and training. For example, while FEMA intends to provide guidance to cadre managers, including a revised FEMA Instruction 8600.1 by the end of 2012, FEMA has experienced difficulty in the past in completing similar efforts, such as the 2008 cadre management handbook that was never finalized. Thus, establishing time frames for completing deliverables such as the revised FEMA Instruction 8600.1 and a cadre manager handbook for DAE management would help ensure accountability for completing initiatives. Furthermore, FEMA’s decentralized structure allows for flexibility; however, establishing a mechanism to ensure ongoing monitoring of regional implementation of DAE policies and procedures and DAEs’ implementation of FEMA’s disaster policies and procedures can assist management in ensuring that disaster assistance is conducted in accordance with policy and consistently applied across regions. In addition, establishing policies and procedures for how FEMA will communicate with DAEs and developing a plan with time frames and milestones for how it will better communicate policies and procedures and cadre-specific information to DAEs when not deployed would help ensure that it is providing DAEs with the tools they need to be prepared for disaster deployments. Page 34 GAO-12-538 Disaster Assistance Employees Further, FEMA’s human capital controls do not adhere to internal control standards for hiring, compensation, and performance appraisals. By standardizing criteria for hiring and salary determinations, FEMA would have greater assurance that DAEs have the necessary skills and qualifications, as well as ensure consistency across regions. In addition, taking steps to establish a more rigorous performance management system would provide FEMA with more information regarding how effectively DAEs are performing and provide a mechanism to identify and improve any performance deficiencies. Moreover, FEMA’s management of DAE training is not consistent with training key practices for planning and tracking training costs. Establishing a plan with milestones for training DAEs would provide FEMA with a roadmap to train its DAE workforce and ensure accountability for qualifying DAEs under FQS. Finally, developing a systematic process for capturing training costs would provide FEMA with additional information to inform its decisions about allocating future funding for training and assist it in doing so effectively. To help DHS improve the management of DAEs and build on some of the Recommendations for actions taken to date, we recommend that the Secretary of Homeland Executive Action Security direct the Administrator of FEMA to take the following seven actions: 1. Establish timelines for development and dissemination of DAE cadre management guidance and revisions to FEMA Instruction 8600.1; 2. Establish a mechanism to monitor both its regions’ implementation of DAE policies and procedures and DAEs’ implementation of FEMA’s disaster policies and procedures to ensure consistency. 3. Develop a plan with time frames and milestones for how it will better communicate policies and procedures and cadre-specific information to DAEs when they are not deployed; 4. Establish standardized criteria for hiring DAEs that include defined qualifications and skill sets to make hiring decisions and salary determinations; 5. Establish a more rigorous performance appraisal system that includes criteria and guidance to serve as a basis for performance ratings, as well as how ratings could be used, and a process to address performance deficiencies; 6. Establish a plan with milestones to ensure all DAEs have opportunities to participate in training and are qualified; and 7. Develop a systematic process to track training costs. Page 35 GAO-12-538 Disaster Assistance Employees We provided a draft of this report to DHS for comment. We received Agency Comments written comments from DHS on the draft report, which are summarized and Our Evaluation below and reproduced in full in appendix VIII. DHS concurred with the recommendations and indicated that FEMA has taken or is taking steps to address them. The actions DHS reported are important first steps; however, FEMA’s implementation plans do not fully address one of the seven recommendations, as discussed below. Moreover, insufficient detail is provided related to FEMA’s plans for three of the recommendations; thus it is not clear to what extent these plans will fully address the three recommendations. In regards to the first recommendation, that FEMA establish time frames for development and dissemination of DAE cadre management guidance and revisions to FEMA Instruction 8600.1, DHS agreed and stated that FEMA Instruction 8600.1, which is now called the FEMA Reservist Program Directive, was revised and, as of May 11, 2012, is in FEMA’s Office of the Chief Counsel for final review. Furthermore, DHS stated that the estimated timeline for approval and publishing of this instruction is June 1, 2012. In addition, DHS stated that the Cadre Manager’s Handbook, the FEMA Reservist Program Manual, the Reservist Pay Directive, and the Reservist Handbook are being developed with an estimated timeline for development, approval, and dissemination approximately 90 days after the signing of the FEMA Reservist Program Directive. It will be important that the FEMA Reservist Program Directive align with the planned Disaster Workforce Transformation. These actions, if implemented effectively, would address the intent of the recommendation. In reviewing the draft of the second recommendation that FEMA establish a mechanism to monitor disaster policies and procedures to ensure consistency, FEMA officials requested clarification, stating that the recommendation was too broad as it focused on FEMA’s disaster policies rather than DAEs. We agreed and modified the recommendation to more clearly state that FEMA should monitor how the regions implement DAE policies and procedures and how DAEs implement disaster policies and procedures. DHS agreed with our revised recommendation and discussed several actions it has taken or has underway to address the recommendation. Specifically, it stated that (1) in December 2011, the FEMA Administrator directed the agency to identify, review, and centrally post all agency doctrine, policies, and directives, (2) all documents were posted to their respective locations on April 13, 2012, and (3) the agency’s policies guiding DAEs are now available on the FEMA intranet. Moreover, FEMA stated that it has also established and is working to Page 36 GAO-12-538 Disaster Assistance Employees improve a number of mechanisms through which it validates compliance with the agency policies and standards. FEMA also stated that communication with reservists on disaster policies and procedures will be initiated from FEMA headquarters to ensure consistency. FEMA has taken actions to make policies and procedures readily available to reservists; however, FEMA did not provide details about the mechanisms it has established for its regions to monitor DAE policies and procedures or DAEs’ implementation of FEMA’s disaster policies. Thus, it is not clear to what extent these actions will fully address the recommendation. In regards to the third recommendation, that FEMA develop a plan with time frames and milestones for how it will better communicate policies and procedures and cadre-specific information to DAEs when they are not deployed, DHS agreed and stated that the FEMA Reservist Program Directive requires Headquarters, Regional, and National Cadre Management leadership to provide consistent two-way messaging to all Reservists, deployed or not, through e-mail, websites, webinars, and other outreach, and estimates that these efforts will be completed by September 30, 2012. However, DHS did not provide details on the types of information that it will be providing DAEs. Thus, it is not clear to what extent FEMA’s planned actions will fully address the recommendation. To fully meet the intent of the recommendation, FEMA needs to ensure that it is communicating both cadre-specific and administrative information to DAEs. In regards to the fourth recommendation, that FEMA establish standardized criteria for hiring DAEs that include defined qualifications and skill sets to make hiring decisions and salary determinations, DHS agreed and stated that the FEMA Qualification System (FQS) Position Task Books define specific qualifications and skills for each required position and will be the basis for establishing standardized criteria for hiring Reservists, including pay. Currently, Position Task Books are used to document and record tasks performed by the trainees, in order to become qualified under FQS. It will be important for FEMA to define skills and/or necessary experience applicants must have prior to being hired for each position, and how if at all, any prior experience will impact salary determinations. Without doing so, DHS will not fully address the intent of the recommendation. In regards to the fifth recommendation, that FEMA establish a more rigorous performance appraisal system that includes criteria and guidance to serve as a basis for performance ratings, as well as how ratings could be used, and a process to address performance Page 37 GAO-12-538 Disaster Assistance Employees deficiencies, DHS agreed. DHS stated that upon implementation of the FEMA Reservist Program Directive and the publishing of various supporting directives and handbooks, FEMA’s Incident Workforce Management Office will coordinate with FEMA’s Office of the Chief Component Human Capital Office to develop a more robust Reservist performance appraisal system that will, among other things, establish performance standards, identify successful task completion, and improve performance deficiencies. These actions, if implemented effectively, would address the intent of the recommendation. In regards to the sixth recommendation, that FEMA establish a plan with milestones to ensure all DAEs have opportunities to participate in training and are qualified, DHS agreed and stated that as part of the changes in the DAE program through the Disaster Reservist Program, FEMA will ensure that all DAEs have opportunities to participate in training and are qualified to serve in a primary disaster-specific job title on the basis of FEMA’s Force Structure requirements. Furthermore, FEMA plans to complete this by September 30, 2013. However, DHS did not provide details on how it plans to ensure that DAEs will become qualified by September 2013, including when it will complete the FEMA Force Structure which had not been finalized as of April 2012. It will be important for FEMA to develop intermediate milestones to provide a roadmap for how it will qualify its workforce. Thus, it is not clear to what extent FEMA’s plans will fully address the intent of the recommendation. In regards to the seventh recommendation, that FEMA develop a systematic process to track training costs, DHS agreed and stated that FEMA has combined all funding for FQS supportive training into a single account to ensure a process for tracking training costs, course offerings, and force structure requirements. DHS also stated that it will include all of this information in the Incident Qualification Certification System— intended to be the primary FQS tracking system—to track all FQS-related training costs. In addition, DHS stated that it should be completed by October 1, 2012. These actions, if implemented effectively, would address the intent of the recommendation. DHS also provided technical comments that we incorporated, where appropriate. As agreed with your offices, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date. At that time, we will send copies to the appropriate Page 38 GAO-12-538 Disaster Assistance Employees congressional committees, the Secretary of the Department of Homeland Security and the Administrator of the Federal Emergency Management Agency. The report will also be available at no charge on the GAO website at http://www.gao.gov. If you or your staff members have any questions about this report, please contact me at (202) 512-8777 or firstname.lastname@example.org. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made major contributions to this report are listed in appendix IX. William O. Jenkins, Director Homeland Security and Justice Issues Page 39 GAO-12-538 Disaster Assistance Employees Appendix I: Objectives, Scope, and Appendix I: Objectives, Scope, and Methodology Methodology The objectives of this report were to determine (1) to what extent does the Federal Emergency Management Agency (FEMA) have policies and procedures in place to govern the Disaster Assistance Employee (DAE) program; (2) to what extent are FEMA’s human capital controls over the DAE workforce consistent with internal control standards; and (3) to what extent does FEMA’s DAE training incorporate key attributes of effective training and development programs. In addition, we describe FEMA’s initiative to transform the DAE program announced in April 2012 as it relates to the three questions above. We addressed each objective by reviewing relevant FEMA documents. To determine the extent to which FEMA has policies and procedures in place to govern its DAE program; and to determine the extent to which FEMA’s human capital management controls over the DAE workforce are consistent with internal control standards, we analyzed relevant documents on FEMA’s organizational structure as well as both program- specific and human capital-related guidance, policies, and procedures produced by FEMA headquarters and regional offices. We also compared FEMA’s human capital controls with criteria in Standards for Internal Control in the Federal Government. 1 To determine the extent to which FEMA’s management of DAE training incorporates key attributes of effective training and development programs, we reviewed data on the following: training requirements, the location and frequency of training courses, course schedules, and the amount of funding dedicated to training from the Disaster Readiness and Support account (2009-2011) and the Disaster Relief Fund (2007-2011). 2 We determined that the data was sufficiently reliable for the purposes of this report based on interviews with responsible officials about the integrity and reliability of the data to include controls FEMA has in place. We also reviewed policies and procedures on training requirements, FEMA’s Learning Management Systems, Joint Field Office (JFO) operations, and FEMA’s new credentialing program, the FEMA Qualification System (FQS). In addition, we observed Public Assistance 1 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999). 2 The Fiscal Year 2010 Department of Homeland Security Appropriations Act required FEMA to submit a report of quarterly obligations of funds against the Disaster Readiness and Support (DRS). Page 40 GAO-12-538 Disaster Assistance Employees Appendix I: Objectives, Scope, and Methodology training attended by DAEs in a JFO. We compared FEMA’s management of DAE training with key attributes of effective training and development programs to determine the extent to which they are aligned. 3 To address all three objectives, we reviewed previous Department of Homeland Security Inspector General Reports, and a FEMA sponsored study conducted by Booz Allen Hamilton on FEMA’s disaster workforce. 4 We found the conclusions and recommendations drawn in each report to be sufficient based on the methodologies used. In addition, we conducted interviews with FEMA officials in headquarters and in the regions. We interviewed officials in the following offices in FEMA headquarters: Office of Response and Recovery, Incident Workforce Management Office (IWMO), Office of the Chief Component Human Capital Officer (OCCHCO), Emergency Management Institute, Office of Policy, Planning, and Analysis (OPPA), Field Based Operations, Training Exercise and Doctrine (TED), Office of the Chief Information Officer (OCIO) and national cadre managers. In addition to interviews with officials in FEMA headquarters, we conducted site visits to four FEMA regions. We selected regions that were geographically dispersed and had a Joint Field Office with Individual and Public Assistance programs operating as of September 2011. In each of the four selected regions, we interviewed the Regional Administrator and Regional Cadre Managers. In addition, we visited one JFO in each of the selected regions. In each selected JFO, we interviewed the Federal Coordinating Officer and Branch Chiefs from selected cadres. We focused our interviews on the following DAE cadres: (1) Individual Assistance (IA); (2) Public Assistance (PA); (3) Hazard Mitigation; (4) Disaster Field Training Operations; (5) Human Resources (HR); and (6) Community Relations. We focused on IA, PA, Hazard Mitigation, and CR because these cadres are responsible for administrating the disaster assistance program and interacting with the public. In addition, we chose HR and Disaster Field Training Operations because they are responsible for the management and training of DAEs. In addition, we interviewed officials from the state emergency management agency, for the state in which the JFO was located. Table 1 3 GAO, Human Capital: A Guide for Assessing Strategic Training and Development Efforts for the Federal Government: GAO-04-546G (Washington, D.C.: March 2004). 4 The Booz Allen Hamilton report was preliminary and FEMA could not locate the final report. FEMA stated that the report drew accurate conclusions and they are currently addressing the observations from the report. Page 41 GAO-12-538 Disaster Assistance Employees Appendix I: Objectives, Scope, and Methodology lists the FEMA regions, JFO locations, and State Emergency Management Agencies we visited. Table 1: FEMA Regional Office, Joint Field Office, and Emergency Management Agencies State Emergency FEMA Region JFO Location Management Agency Region 1, Boston, Springfield, Massachusetts Emergency Massachusetts Massachusetts Management Agency Region 4, Atlanta, Georgia Birmingham, Alabama Alabama Emergency Management Agency Region 7, Kansas City, Lincoln, Nebraska Nebraska Emergency Missouri Management Agency Region 8, Denver, Colorado Bismarck, North Dakota North Dakota Department of Emergency Services Source: GAO. To obtain the views of DAEs on issues related to all three of our objectives, we conducted 16 focus group sessions with a total of 125 DAEs at the four selected JFOs. These sessions involved structured small-group discussions designed to gain more in-depth information about issues DAEs face. Discussions were guided by a moderator who used a list of discussion topics to encourage participants to share their thoughts and experiences as DAEs. Specifically, discussion topics included the hiring process, training, policies and procedures, FQS and communication by regional managers; however, not all topics were discussed in each group. Each focus group involved 5 to 12 DAE participants. There were four types of focus groups based on job titles: IA and PA supervisors, IA and PA non-supervisors, and supervisors and non-supervisors from other cadres other than IA and PA. We completed written summaries of each focus group, and used content analysis software to categorize responses and identify common themes across the focus groups, using appropriate checks to ensure accuracy. The results of the focus groups are not generalizable. However, the views we obtained from them provided us with valuable examples of DAE experiences. In addition, to obtain further perspectives from regional management on hiring, training, deployments, policies and procedures and FQS, we conducted follow-up interviews with 16 regional cadre managers we interviewed during our site visits. In addition, we reviewed FEMA’s April 2012 memorandum announcing the transformation of the DAE program, but did not assess its planned actions to transform the DAE program because the agency is in the early planning stages. Page 42 GAO-12-538 Disaster Assistance Employees Appendix I: Objectives, Scope, and Methodology We conducted this performance audit from April 2011 through May 2012 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. Page 43 GAO-12-538 Disaster Assistance Employees Appendix II: Categories of Disaster Appendix II: Categories of Disaster Workforce Employees Workforce Employees Name Description Disaster assistance employee (DAE) Stafford Act federal employees who work on an on-call intermittent basis “forming the major a workforce for FEMA in times of emergency or disaster.” They are also known as reservists. DAEs are temporary personnel appointed and compensated without regard to the provisions of Title 5, United States Code, governing appointments in competitive service. They are activated in direct response to a disaster declaration to support the work of FEMA at the disaster site. FEMA appoints DAEs in 2-year cycles, as intermittent employees who are deployed as needed for emergencies and/or disasters. Cadre of on-call response/recovery Federal employees hired under the authority of the Stafford Act on a temporary full-time employees (CORE) basis for 2- and 4-year terms. These terms are renewable if there is ongoing disaster work and funding available. Similar to DAEs, COREs are temporary personnel appointed and compensated without regard to the provisions of Title 5, United States Code, governing appointments in competitive service. Temporary full-time (TFT) Temporary federal employees covered by Title 5 provisions. They do not have specified appointment periods. Federal Coordinating Officers (FCO) are included in this employment group. Permanent full-time (PFT) Permanent federal employees hired in accordance with Title 5, United States Code. Local hire Staff locally hired under the authority of the Stafford Act for an initial period of 120 days. This period of time is renewable. Local hires augment the reservist workforce. They are hired for positions that “do not require FEMA-specific expertise, or when limited advance b training or minimal on-the-job orientation or training is sufficient.” In certain instances local hires may convert to DAEs. Source: FEMA. a Terms of employment, http://www.fema.gov/about/career/terms.shtm. b OIG: FEMA’s Management of Disaster Assistance Employee Deployment and Payroll Processes, Appendix C Director’s Policy 1-99, March 1999. Page 44 GAO-12-538 Disaster Assistance Employees Appendix III: Cadre List and Descriptions Appendix III: Cadre List and Descriptions There are 23 functional disaster cadres excluding the Disaster Generalist Group, which was created to augment the External Affairs, Individual Assistance, and Public Assistance cadres and provide surge staff when required. Table 2: Cadre List and Descriptions Managing Headquarters Cadre organization Description Primary duties only Alternative Dispute Office of Chief Helps to foster collaborative • Provides services including Resolution (ADR) Counsel and effective disaster consultation, dispute resolution and √ operations. Seeks to quickly prevention, conflict resolution training, resolve situations that may and meeting facilitation. distract disaster assistance workers from carrying out their mission. Attorney Office of Chief Serves as the primary legal • Provides legal advice, instruction, and Counsel advisor to the FCO/Director communication. √ and senior staff. • Provides guidance and interpretation of FEMA statute and regulations. Community Office of External Provides outreach to • Provides field outreach to disaster Relations (CR) Affairs community-based victims and community leaders about organizations and disaster federal and state recovery programs. victims about federal and • Provides multilingual capabilities to state recovery programs. help reach out to communities that may not be in the traditional information chain. Comptroller Mission Serves as the Finance and • Advises the FCO and the Senior staff Support/Office of Administration Section Chief at JFO. √ Chief Financial at a Joint Field Office (JFO), • Manages the funding process to Officer National Response ensure timely and sufficient funding to Coordination Center execute Stafford Act Programs and (NRCC), or Regional cover administrative costs at their Response Coordination assigned JFO. Center (RRCC). Congressional Office of External Coordinates dialogue • Coordinates the exchange of Affairs Affairs between Federal efforts and information between DHS, FEMA, the Congressional Members of Congress, and their staff. delegation of the affected • Responds to congressional inquiries area. and casework. • Arranges site visits to help Members of Congress to understand the Federal/state/local response and recovery process. • Develops a Congressional Affairs strategy for outreach and incident- specific objectives. Page 45 GAO-12-538 Disaster Assistance Employees Appendix III: Cadre List and Descriptions Managing Headquarters Cadre organization Description Primary duties only Contracting/ Office of Chief Deployed to support JFO • Initiates acquisitions. Plans for source Acquisition Procurement operational acquisitions selection. √ Officer requirements. Can also • Prepares solicitation offers. Evaluates support disaster acquisition bids and proposals in accordance with operations requiring close- the terms and conditions for the out in an effort to return solicitation. funding to the Disaster Relief • Implements the contract and monitors Fund. contractor performance. Monitors payments to contractors. Disaster Field Emergency Delivers response and • Coordinates disaster training. Training Operations Management recovery program-related • Delivers a wide range of training- (DFTO) Institute training courses in a variety related services. of training venues. Supports • Assesses and evaluates the training the Training Unit within the needs of a JFO. Finance and Administrative Section at a JFO. Disaster Generalist Office of Response Supports Community • Establishes and maintains positive Group and Recovery Relations, Individual working relationships with the disaster- √ Assistance, and Public affected community by collecting and Assistance cadres during a disseminating disaster-related disaster declaration. materials. • Identifies and reports potential issues within the community. • Supplements other program areas as the scope of the disaster increases. Environmental/ Federal Insurance Ensures that FEMA’s • Preserves historic, cultural and natural Historical and Mitigation activities related to disaster aspects of national heritage. Preservation Administration response and recovery, • Supports activities that achieve a hazard mitigation, and balance between resource use and emergency preparedness development. comply with federal environmental and historic preservation law and executive orders. Equal Rights Office of Equal Possesses a background in • Civil Rights Resolution – works with Rights Equal Employment Community Relations, Public Affairs, √ Opportunity (EEO), Civil Human Services, and other Rights, human resource components to resolve Civil Rights management, conflict issues. resolution, and community • Provides advice and guidance to the organization. FCO on EEO and Civil Rights matters. • Assists FEMA employees, employment applicants, and managers to resolve problems quickly, guide supervisors through downsizing, and process complaints that cannot be resolved informally. Page 46 GAO-12-538 Disaster Assistance Employees Appendix III: Cadre List and Descriptions Managing Headquarters Cadre organization Description Primary duties only Federal Coordinating Office of Response Presidentially appointed. • Leads FEMA staff in field operations. Officer (FCO) and Recovery Ensures the integration of • Responsible for executing Stafford Act Federal emergency programs in a timely and cost effective management, resource manner. allocation, and the integration of Federal activities in coordination with State, tribal and local government requirements. Financial Office of Chief I Unit Leads, Funds Control • Manages the funding process. Management Financial Officer Specialists/Managers, and • Maintains the accounting records of Travel Specialist/Manager in the Disaster Declaration. the Cost Unit in the Finance • Assists FEMA personnel with and Administration Section. preparation of Travel Vouchers. Human Resources Office of the Chief Focuses on recruitment, • Handles recruitment, staffing, and (HR) Component Human management, and the payroll & time/attendance. Capital Officer direction of the people in the organization. Individual Assistance Office of Response Provides direct assistance to • Applicant Services: Program (IA) and Recovery individuals and families. Specialists perform registration intake, Members work at JFOs, referrals, and guide applicants through Disaster Recovery Centers the FEMA assistance process. (DRC), shelter facilities, and • Mass Care Specialists: support state, the National Processing local and tribal sheltering, feeding, and Services Centers. Supports commodities distribution operations in state Mass Care operations, coordination with Voluntary Agencies. administers funds to assist • Voluntary Agency Liaisons: transfer survivors to rebuild and information between the Voluntary recover, coordinates Agencies and the governmental assistance with Voluntary assistance organizations, and also Agencies, and supports provide applicant referrals, assistance direct housing operations. with special needs cases, and support for donations management. • Direct Housing Operations: Specialists support the installation of temporary housing units. Information Office of Chief Maintains all forms of data • Installs, tests, and sets up IT Technology (IT) Information Officer and telecommunications. communications equipment. • Acquires required equipment, supplies, or services. • Networks access capabilities for all personnel. • Maintains and repairs IT communications equipment. Page 47 GAO-12-538 Disaster Assistance Employees Appendix III: Cadre List and Descriptions Managing Headquarters Cadre organization Description Primary duties only Logistics Logistics Provides logistics capability • Develops, advises, and executes Management for the procurement and logistics support course of action for Directorate delivery of life-sustaining field operations. goods and services to an • Provides management of agency impacted population. personal property accountability. • Manages supply chain, warehouse, and transportation operation to source, order, transport, track, and distribute supplies, equipment, and services to support domestic emergencies. Long Term Office of Response Works with federal, state, • Helps communities identify long-term Community and Recovery and local governments as recovery plan. Recovery well as the nonprofit and • Helps communities identify and private sectors to enable coordinate resources and funding disaster-impacted sources for the implementation of the communities to identify LTCR projects, programs, and opportunities, creating initiatives. partnerships and maximizing resources for recovery. Mitigation Federal Insurance Identifies measures to • Identifies risk reduction opportunities. and Mitigation protect lives and prevent or • Educates the public and local Administration reduce the loss of property government officials in methods to from hazardous events. reduce future risks. • Promotes hazard mitigation community planning and project development that will result in sustainable community development. • Provides grants to fund hazard mitigation projects. • Assists communities in marketing the National Flood Insurance Program (NFIP). Operations (OPS) Office of Response Coordinates support to all • Develops and implements strategy and Recovery emergency management and tactics to carry out incident efforts and program objectives. implementation for • Organizes, assigns, and supervises Environmental and Historic response resources. Preservation, Mitigation, Public Assistance, and Individual Assistance. Page 48 GAO-12-538 Disaster Assistance Employees Appendix III: Cadre List and Descriptions Managing Headquarters Cadre organization Description Primary duties only Planning Office of Response Provides support to planning • Manages joint federal-state disaster and Recovery and information for disaster plan development. operations. • Oversees disaster information management such as situational awareness, record retention and dissemination and resource tracking. • Provides geospatial expertise in the development of Geospatial Information System data, graphical displays, remote sensing, and map production. • Facilitates meetings integral to incident action planning and operational decision making. Public Affairs Office of External Provides information to the • Establishes and maintains ongoing Affairs public that would help them relationships with the media to prepare for, prevent, promote the agency’s programs, respond to, and recover from goals, and core values. disasters. • Provides disaster survivors with timely and accurate information, and manage communication. Public Assistance Office of Response Authorized by the Stafford • Provides grant assistance for debris (PA) and Recovery Act. Provides supplemental removal, emergency protective financial assistance to state, measures and permanent restoration local and tribal governments of infrastructure. and certain private non-profit organizations for response and recovery activities resulting from a declared disaster. Safety Office of Chief Serves as technical advisor • Oversees safety and health activities Administrative to the Federal Coordinating throughout disaster operations for all Officer Officer (FCO) on FEMA employees and personnel in occupational safety and FEMA-managed facilities. health matters. • Provides safety and health training to all FEMA employees deployed to disaster operations. • Serves as a technical resource on occupational safety and health matters for the FCO. Page 49 GAO-12-538 Disaster Assistance Employees Appendix III: Cadre List and Descriptions Managing Headquarters Cadre organization Description Primary duties only Security Office of the Chief Maintains responsibility for • Serves as the Agency Technical Security Officer all internal security Representative for contract guard processes at disaster services, as well as conduct facility facilities and special event vulnerability assessments on all FEMA assignments. disaster facilities. • Serves as law enforcement liaison. • Conducts preliminary inquiries on criminal and administrative actions. • Conducts background status checks, complete fingerprinting, badge operations, and coordinate the installation of alarm and closed-circuit television equipment. Source: FEMA. Page 50 GAO-12-538 Disaster Assistance Employees Appendix IV: FEMA Organizational Chart— Appendix IV: FEMA Organizational Chart— Highlight of Response Directorate’s Incident Workforce Management Office Highlight of Response Directorate’s Incident Workforce Management Office Page 51 GAO-12-538 Disaster Assistance Employees Appendix V: Disaster Assistance Employee Appendix V: Disaster Assistance Employee Program Office Reorganization Timeline, April 2008 through May 2012 Program Office Reorganization Timeline, April 2008 through May 2012 Page 52 GAO-12-538 Disaster Assistance Employees Appendix VI: Incident Workforce Appendix VI: Incident Workforce Management Office Organizational Structure and Proposed Roles Management Office Organizational Structure and Proposed Roles Page 53 GAO-12-538 Disaster Assistance Employees Appendix VII: FEMA Disaster Assistance Appendix VII: FEMA Disaster Assistance Employee Pay Scale, Calendar Year 2011 Employee Pay Scale, Calendar Year 2011 Grade A B C D E Level 1 $23,555 $29,627 $44,887 $65,093 $77,408 Per hour $11.29 $14.20 $21.51 $31.19 $37.09 Overtime $16.94 $21.30 $32.27 $32.91 $37.09 Level 2 $25,162 $33,021 $49,436 $69,433 $82,567 Per hour $12.06 $15.82 $23.69 $33.27 $39.57 Overtime $18.09 $23.73 $32.91 $33.27 $39.57 Level 3 $27,361 $36,699 $54,313 $73,773 $87,728 Per hour $13.11 $17.58 $26.03 $35.35 $42.03 Overtime $19.67 $26.37 $32.91 $35.35 $42.03 Source: FEMA. Page 54 GAO-12-538 Disaster Assistance Employees Appendix VIII: Comments from the Appendix VIII: Comments from the Department of Homeland Security Department of Homeland Security Page 55 GAO-12-538 Disaster Assistance Employees Appendix VIII: Comments from the Department of Homeland Security Page 56 GAO-12-538 Disaster Assistance Employees Appendix VIII: Comments from the Department of Homeland Security Page 57 GAO-12-538 Disaster Assistance Employees Appendix IX: GAO Contact and Staff Appendix IX: GAO Contact and Staff Acknowledgments Acknowledgments William O. Jenkins, Jr. (202) 512- 8777 or email@example.com GAO Contact In addition to the contact named above, Leyla Kazaz, Assistant Director, Acknowledgments managed this assignment. Martene Bryan, Landis Lindsey, Lauren Membreno, Aku Pappoe and Michelle Su made significant contributions to the work. Cynthia Saunders assisted with design and methodology. Tracey King provided legal support and analysis. Linda Miller and Debbie Sebastian provided assistance in report preparation. Robert Robinson developed the report graphics. (440966) Page 58 GAO-12-538 Disaster Assistance Employees GAO’s Mission The Government Accountability Office, the audit, evaluation, and investigative arm of Congress, exists to support Congress in meeting its constitutional responsibilities and to help improve the performance and accountability of the federal government for the American people. GAO examines the use of public funds; evaluates federal programs and policies; and provides analyses, recommendations, and other assistance to help Congress make informed oversight, policy, and funding decisions. GAO’s commitment to good government is reflected in its core values of accountability, integrity, and reliability. The fastest and easiest way to obtain copies of GAO documents at no Obtaining Copies of cost is through GAO’s website (www.gao.gov). 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Disaster Assistance Workforce: FEMA Could Enhance Human Capital Management and Training
Published by the Government Accountability Office on 2012-05-25.
Below is a raw (and likely hideous) rendition of the original report. (PDF)