Flood of IRS’s Headquarters Building

On June 25, 2006, the IRS headquarters building suffered flooding during a  period of record rainfall and sustained extensive damage to its  infrastructure. In response to the flood and the closure of the building,  IRS headquarters officials reported activating several of the agency’s  emergency operations plans. Over 2,000 employees normally assigned to  the headquarters building were relocated to other facilities throughout the  Washington, D.C., metropolitan area. IRS Headquarters Emergency Operations Plans Partially Addressed Elements Outlined in Federal Guidance

The IRS headquarters emergency operations plans we reviewed  collectively addressed several of the general elements of guidance  identified in FPC 65. For example, the plans adequately identified the  people needed to continue performing essential functions and had  established procedures for activation. However, other elements were not  addressed or were addressed only in part. Specifically, IRS identified two  separate lists of essential functions—critical business processes and  essential functions for IRS leadership—within its plans but only prioritized  one of the lists. Furthermore, although the COOP plan outlined provisions  for tests, training, and exercises, neither the business resumption plans we  reviewed—from Criminal Investigation (CI), Wage and Investment (W&I),  and Chief Counsel—nor the Incident Management Plan outlined the need  to conduct such activities. While IRS’s Office of Physical Security and  Emergency Preparedness provided overall guidance to business units on  their business resumption plans, the guidance was inconsistent with the  federal guidance on several elements, including the preparation of  resources and facilities needed to support essential functions and  requirements for regular tests, training, and exercises. 2. The agency’s Incident Management Plan was particularly useful  in establishing clear lines of authority and communications, conditions  that we have previously reported to be critical to an effective emergency  response. Unit-level business resumption plans we reviewed contributed  to a lesser extent and the headquarters COOP plan was not activated  because of conditions particular to the 2006 flood. Specifically, damage to  the building was limited to the basement and subbasement levels, and  employees were able to enter the building to retrieve equipment and  assets. In addition, alternate work space was available for all employees  within a relatively short period, reducing the importance of identifying  critical personnel. Recommendations for Executive Action

To strengthen the ability of IRS to respond to the full range of potential  disruptions to essential operations, we are making two recommendations  to the Commissioner of Internal Revenue:    Revise IRS internal emergency planning guidance to fully reflect federal  guidance on the elements of a viable continuity capability, including the  identification and prioritization of essential functions; the preparation of  necessary resources and alternate facilities; and the regular completion of  tests, training, and exercises of continuity capabilities. Appendix I: Objectives, Scope, and Methodology

The objectives of this report were to    evaluate how the Internal Revenue Service’s (IRS) emergency operations  plans address federal guidance related to continuity planning and    evaluate the extent to which IRS emergency operations plans contributed  to the actions taken by IRS officials in response to the flood.
Why GAO Did This Study

On June 25, 2006, the Internal Revenue Service (IRS) headquarters building suffered flooding during a period of record rainfall and sustained extensive damage to its infrastructure. IRS officials ordered the closure of the building until December 2006 to allow for repairs to be completed. IRS headquarters officials reported activating several of the agency's emergency operations plans. Within 1 month of the flood, over 2,000 employees normally assigned to the headquarters building were relocated to other facilities throughout the Washington, D.C., metropolitan area. GAO was asked to report on (1) how IRS emergency operations plans address federal guidance related to continuity planning and (2) the extent to which IRS emergency operations plans contributed to the actions taken by IRS officials in response to the flood. To address these objectives, GAO analyzed federal continuity guidance, reviewed IRS emergency plans, and interviewed IRS officials.

What GAO Found

The IRS headquarters emergency operations plans that GAO reviewed--the headquarters Continuity of Operations (COOP) plan, Incident Management Plan, and three selected business resumption plans--collectively addressed several of the general elements identified within federal continuity guidance for all executive branch departments and agencies. For example, the plans adequately identified the people needed to continue performing essential functions. However, other elements were not addressed or were addressed only in part. Specifically, IRS had two separate lists of essential functions--critical business processes and essential functions for IRS leadership--within its plans, but prioritized only one of the lists. Furthermore, although the COOP plan outlined provisions for tests, training, and exercises, none of the other plans GAO reviewed outlined the need to conduct such activities. While IRS provided overall guidance to its business units on their business resumption plans, the guidance was inconsistent with the federal guidance on several elements, including the preparation of resources and facilities needed to support essential functions and requirements for regular tests, training, and exercises. The IRS Incident Management Plan was particularly useful in establishing clear lines of authority and communications in response to the flooding. Unit-level business resumption plans GAO reviewed contributed to a lesser extent, and the headquarters COOP plan was not activated because of conditions particular to the 2006 flood. Specifically, damage to the building was limited to the basement and subbasement levels, and employees were able to enter the building to retrieve equipment and assets. In addition, alternate work space was available for all employees within a relatively short period, reducing the importance of identifying critical personnel. While its plans helped guide IRS's response to the conditions that resulted from the flood, in more severe emergency events, conditions could be less favorable to recovery. Consequently, unless IRS fills in gaps in its guidance and plans, it lacks assurance that the agency is adequately prepared to respond to the full range of potential disruptions.