FPC 65 also determined that COOP planning is  based first on the identification of essential functions—that is, those  functions that enable agencies to provide vital services, exercise civil  authority, maintain safety, and sustain the economy during an emergency. Although FPC 65 gives no specific criteria for identifying essential  functions, a logical starting point for this process would be to consider  programs that had been previously identified as important. These agency-identified essential  functions varied in number and scope. The number of functions identified  in each plan ranged from 3 to 399. For example, a number of essential  functions were of clear importance, such as   “ensuring uninterrupted command, control, and leadership of the   “protecting critical facilities, systems, equipment and records”; and  “continuing to pay the government’s obligations.”
Other identified functions appeared vague or of questionable importance:   “provide speeches and articles for the Secretary and Deputy Secretary”;  “schedule all activities of the Secretary”; and   “review fiscal and programmatic integrity and efficiency of  Departmental activities.”
In contrast to the examples just given, agencies did not list among their  essential functions 20 of the 38 “high-impact” programs identified during  the Y2K effort at the agencies we reviewed. FEMA is developing a test and training program for COOP  activities, but it has not yet conducted an interagency exercise to test the  feasibility of these planned activities. However, none of  these plans addressed all the guidance in FPC 65. Essential Functions

Although most agency plans identified at least one essential function, less  than half the COOP plans fully addressed other FPC 65 guidance related to  essential functions, such as prioritizing the functions or identifying  interdependencies among them (see table 2). If alternate facilities are not provided or are  inadequate, agency operations may not be able to continue in an  emergency. In 1999, FEMA assessed compliance with the elements of FPC 65  through a self-reported survey of agency COOP officials, supplemented  by interviews. Conclusions

While most of the federal agencies we reviewed had developed COOP  plans, three agencies did not have documented plans as of October 2002. To ensure that agencies can continue operations in emergencies and are  prepared for the governmentwide exercise planned for May 2004, we  recommend that the Secretary of Homeland Security direct the Under  Secretary for Emergency Preparedness and Response to take steps to  ensure that agencies that do not have COOP plans develop them by May  1, 2004. We further recommend that the Secretary direct the Under Secretary to  take steps to improve the oversight of COOP planning by   ensuring that agencies correct the deficiencies in individual COOP plans  identified here, as well as those identified in previous assessments, and  conducting assessments of agency continuity plans that include  independent verification of agency-provided information, as well as an  assessment of the essential functions identified and their  interdependencies with other activities. We also interviewed agency officials who were  responsible for developing each of the 34 continuity of operations (COOP)  plans (comprising the 20 plans for the largest civilian departments and  agencies and the 14 plans covering components with high-impact  programs); obtained and analyzed COOP guidance issued by the Federal  Emergency Management Agency (FEMA) and documents describing its  efforts to provide oversight and assessments of federal COOP planning  efforts; and conducted interviews with FEMA officials to clarify the  activities described in these documents.
Why GAO Did This Study

To ensure that essential government services are available in emergencies--such as terrorist attacks, severe weather, or building-level emergencies-- federal agencies are required to develop continuity of operations (COOP) plans. Responsibility for formulating guidance on these plans and for assessing executive branch COOP capabilities lies with the Federal Emergency Management Agency (FEMA), under the Department of Homeland Security. FEMA guidance, Federal Preparedness Circular (FPC) 65 (July 1999), provides elements of a viable COOP capability, including the requirement that agencies identify their essential functions. GAO was asked to determine the extent to which (1) major civilian executive branch agencies have identified their essential functions and (2) these agencies' COOP plans follow FEMA guidance.

What GAO Found

From an assessment of 34 COOP plans against FEMA guidance, GAO found that most agencies' plans identified at least one function as essential. However, the functions identified in each plan varied widely in number-- ranging from 3 to 399--and included functions that appeared to be of secondary importance, while at the same time omitting programs that had been previously defined as high-impact programs. (Examples of these highimpact programs are Medicare, food stamps, and border inspections.) For example, one department included "provide speeches and articles for the Secretary and Deputy Secretary," among its essential functions, but did not include 9 of 10 high-impact programs for which it is responsible. Several factors contributed to these shortcomings: FPC 65 did not provide specific criteria for identifying essential functions; FEMA did not review the essential functions identified when it assessed COOP planning; and it did not conduct tests or exercises to confirm that the essential functions were correctly identified. Unless agencies' essential functions are correctly and completely identified, their COOP plans may not effectively ensure that the most vital government services can be maintained in an emergency. Although all but three of the agencies reviewed had developed and documented some of the elements of a viable COOP plan, none of the agencies could demonstrate that they were following all the guidance in FPC 65. There is a wide variation in the number of agencies that addressed various elements identified in the guidance. A contributing cause for the deficiencies in agency COOP plans is the level of FEMA oversight. In 1999, FEMA conducted an assessment of agency compliance with FPC 65, but it has not conducted oversight that is sufficiently regular and extensive to ensure that agencies correct the deficiencies identified. Because the resulting COOP plans do not include all the elements of a viable plan as defined by FPC 65, agency efforts to provide services during an emergency could be impaired.