Agency Continuity of Operations Plans do not include all
the elements of a viable plan as defined by the Federal
Emergency Management Authority, something that could lead
to even greater difficulties during an emergency, the
General Accounting Office has said.
It said the functions identified in the COOP plans of 34
agencies as “essential,” vary widely in number, ranging
from 3 to 399, and include many non-essential functions
such as speechwriting, while at the same time omitting
programs that had been previously defined as high-impact
such as food stamps.
One problem is that FEMA’s guidance, FPC 65, does not
provide specific criteria for identifying essential
functions, nor did FEMA review the essential functions
identified during COOP planning, or conduct tests or
exercises to confirm that the essential functions were
correctly identified, said GAO.
It said none of the agencies it looked at could demonstrate
it was following FEMA guidance in its entirety, something
GAO attributed to a lack of FEMA oversight.