GAO-20-685T, COVID 19: FEMA's Role in the Response and Related Challenges

Report — GAO-20-685T, COVID 19: FEMA's Role in the Response and Related Challenges, dated 2020-07-14, issued by Government Accountability Office.

Full text

COVID 19
FEMA’s Role in the
Response and Related
Challenges
Statement of Chris P. Currie, Director,
Homeland Security and Justice

Before the Subcommittee on Oversight,
Management, and Accountability, and the
Subcommittee on Emergency Preparedness,
Response, and Recovery, Committee on
Homeland Security, House of
Representatives
For Release on Delivery
Expected at 12:00 p.m. ET
Tuesday, July 14, 2020
GAO-20-685T

United States Government Accountability Office

 United States Government Accountability Office

Highlights of GAO-20-685T, a testimony
before the Subcommittee on Oversight,
Management, and Accountability, and the
Subcommittee on Emergency Preparedness,
Response, and Recovery, Committee on
Homeland Security, House of Representatives

July 14, 2020
COVID-19
FEMA’s Role in the Response and Related Challenges
What GAO Found
The Federal Emergency Management Agency (FEMA) Administrator, together
with key officials from the Department of Health and Human Services, is
responsible for managing the whole-of-nation COVID-19 pandemic response. As
a primary agency responsible for managing the response, FEMA has worked in
coordination with other federal agencies to increase the availability of supplies for
COVID-19—including distributing supplies to states and others through Project
Air Bridge in an effort to expedite distribution. FEMA’s contract obligations in
response to COVID-19 totaled about $1.6 billion as of May 31, 2020, with
obligations for goods such as surgical gowns and N95 masks accounting for $1.4
billion, or 86 percent of that total.
GAO’s recent report on the COVID-19 pandemic response and past work on
other disasters has identified potential challenges FEMA faces in responding to
the pandemic and any future nationally significant biological incidents. These
challenges may be further complicated by the recent rise in COVID-19 cases and
additional expected case increases in the fall.
•
Contracting. In December 2018, GAO found inconsistencies in how FEMA
coordinated and communicated with states and localities on advance
contracts—those that are established prior to disasters and are typically
needed to quickly provide goods and services. GAO made recommendations
to improve FEMA’s efforts and it is taking actions to address this issue.
•
Medical supply acquisition and distribution. In June 2020, GAO reported
on concerns about the distribution, acquisition, and adequacy of supplies
from the Strategic National Stockpile and other sources. GAO will continue to
monitor these issues through ongoing and future work.
•
Deploying disaster workforce. In May 2020, GAO reported on staffing
shortages and other workforce challenges FEMA faced in recent disasters.
The large number of declared COVID-19 disasters coupled with hurricane
and wildfire seasons adds other potential challenges. GAO made
recommendations designed to enhance the information FEMA officials have
to manage the workforce, which FEMA agreed to implement.
•
After-action reporting. Analyzing lessons from the COVID-19 pandemic
response may help FEMA and other agencies take corrective action for the
remainder of this response and for potential future biological incidents. In
May 2020, however, GAO reported that FEMA had not consistently
completed prior after-action reports. FEMA agreed to implement
recommendations designed to improve after-action reporting.
•
Interagency planning for biological incidents, In June 2020, GAO
reported that the National Biodefense Strategy sets goals and objectives to
help the nation prepare for and rapidly respond to biological incidents to
minimize their effect and could drive interagency preparedness efforts.
However, implementation was in early stages at the start of the pandemic,
and in February 2020 GAO made recommendations designed to address key
implementation challenges, including clarifying roles and responsibilities. As
shown in the COVID-19 response, FEMA’s role in these efforts will be critical.
GAO will continue to monitor preparedness and strategy implementation.
View GAO-20-685T. For more information,
contact Chris Currie at (404) 679-1875 or
curriec@gao.gov.
Why GAO Did This Study
The COVID-19 pandemic shows how
biological threats have the potential to
cause loss of life and sustained
damage to the economy, societal
stability, and global security. During the
pandemic, 57 major disaster
declarations were simultaneously
issued for all U.S. states, the District of
Columbia, and U.S. territories—the first
time in history this has occurred.
FEMA had obligated about $5.8 billion
for the response as of May 31, 2020.
This statement addresses (1) FEMA’s
role in managing the COVID-19
pandemic, including efforts to acquire
and distribute critical medical supplies,
as well as (2) potential challenges for
this and other biological incident
responses. This statement is based on
products GAO issued from August
2003 to June 2020, as well as ongoing
efforts to monitor contract obligations.
For these products, GAO reviewed
relevant presidential directives,
statutes, regulations, policies, strategic
plans, other reports, as well as federal
procurement data; and interviewed
federal and state officials, among
others.
GAO provided a copy of new contract
obligation information in this statement
to the Department of Homeland
Security for review.
What GAO Recommends
GAO made many recommendations
in prior reports designed to address
facets of many of the challenges
discussed in this statement. Federal
agencies have not fully implemented
all of these but, in many cases, have
taken steps. GAO will continue to
monitor these efforts.

Letter

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Chairwoman Torres Small, Chairman Payne, Ranking Member
Crenshaw, Ranking Member King, and Members of the Subcommittees:
I am pleased to be here today to discuss our work on the Federal
Emergency Management Agency’s (FEMA) roles and responsibilities
during the response to the Coronavirus Disease 2019 (COVID-19)
pandemic.1 While the COVID-19 pandemic continues to unfold and
present new challenges, it also demonstrates how biological threats have
the potential to cause catastrophic loss of life and sustained damage to
the economy, societal stability, and global security. We recently issued
our first comprehensive look at the overall government response to the
COVID-19 pandemic, in which we reported on the multiple federal efforts
to help address the health effects and the spillover effects of the
pandemic on the economy.2 As of July 6, 2020, there were over 2.8
million reported COVID-19 cases and over 129,000 reported deaths in the
United States, according to the Centers for Disease Control and
Prevention (CDC). In addition, from March 21 to May 30, 2020, there was
an increase of over 42 million unemployed Americans and an overall
downturn in the U.S. economy. The operational response to the pandemic
has required support from all of the nation’s existing systems and
structures designed to help manage the response to both public health
emergencies and natural disasters across multiple federal departments.
To help the nation prepare for disasters regardless of origin, the
Department of Homeland Security (DHS) issued The National Response
Framework, which describes how the federal government, states and
localities, and other public and private sector institutions should respond
to disasters.3 For example, state, local, tribal, and territorial governments

1COVID-19 is a strain of coronavirus to which the public does not have immunity. It was
first reported on December 31, 2019, in Wuhan, China. On January 31, 2020, the
Secretary of Health and Human Services declared a public health emergency for the
United States, retroactive to January 27. On March 13, 2020, the President declared
COVID-19 a national emergency under the National Emergencies Act.
2GAO, COVID-19: Opportunities to Improve Federal Response and Recovery Efforts,
GAO-20-625 (Washington, D.C: June 25, 2020).
3Presidential Policy Directive-8 National Preparedness (PPD-8) establishes a national
preparedness system made of an integrated set of guidance, programs, and processes
designed to strengthen the security and resilience of the United States through systematic
preparation for the natural and human-caused threats that pose the greatest risk. This
system breaks preparedness activities into five different lines of effort—prevention,
protection, mitigation, response, and recovery—each of which requires a separate
planning framework.
Letter

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are to play the lead roles in disaster response and recovery. Federal
agencies can become involved in responding to a disaster, such as when
the President declares a major disaster in response to a request by the
governor of a state or territory or by the chief executive of a tribal
government, pursuant to the Robert T. Stafford Disaster Relief and
Emergency Assistance Act (Stafford Act).4 Such a request is based on a
finding that the disaster is of such severity and magnitude that effective
response is beyond the capabilities of the state and the affected local
governments and that federal assistance is necessary. A Stafford Act
declaration is a key mechanism by which the federal government
becomes involved in funding and coordinating response and recovery
activities. For example, FEMA uses mission assignments and the Public
Assistance and Individual Assistance programs to support response
efforts and obligated $5.8 billion for COVID-19 as of May 31, 2020.5
During the COVID-19 pandemic, 57 major disaster declarations have
been issued simultaneously for all U.S. states, the District of Columbia,
and U.S. territories—the first time in history this has occurred.6
In May 2020, we reported that the 2017 and 2018 hurricanes, wildfires,
and other recent disasters highlight the challenges that all levels of
government face in preparing for and responding effectively to
disasters—in terms of both immediate response and long-term recovery
efforts. Our prior work has identified FEMA’s challenges in preparing for,
responding to, and recovering from major disasters and also highlighted
the need to ensure transparency for tracking federal contracting

442 U.S.C. § 5170.
5Mission Assignments are work orders FEMA issues that direct another federal agency to
utilize its authorities and the resources granted to it under federal law to provide direct
assistance to state, local, tribal, and territorial governments. The Public Assistance
program provides assistance to state, tribal, territorial, and local governments. For
example, for the COVID-related declarations, states can use FEMA’s Public Assistance
program grant funding for actions that lessen the immediate threat to public health and
safety, like standing up emergency medical facilities. In addition, FEMA’s Individual
Assistance program, which provides assistance to help individuals and households
recover following a disaster, can also reinforce state and local services provided to help
individuals cope with the pandemic, such as for crisis counseling.
6Major disaster declarations include all 50 states, the District of Columbia, five territories,
and the Seminole Tribe of Florida. In addition, 32 tribal entities are working directly with
FEMA under the March 13, 2020, nationwide emergency declaration.

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obligations for major disasters through proper accounting mechanisms.7
In its 2017 Hurricane Season After-Action Report, FEMA acknowledged
that the agency must better prepare for sequential, complex disasters and
address logistical challenges that may complicate efforts to deploy
resources to remote areas.8 As the nation continues to battle the ongoing
pandemic, a recent spike in case numbers, and additional expected
increases in the fall, it also must maintain nimbleness to address other
likely concurrent disasters, such as hurricanes and wildfires, that will rely
on some of the same response capabilities currently being used to
address the pandemic, including FEMA’s workforce.
My testimony today highlights key findings from our recent prior work on
(1) FEMA’s role in managing the response to the COVID-19 pandemic,
including efforts to acquire and distribute critical medical supplies, and (2)
what our prior work suggests about potential challenges going forward for
this and any other responses to nationally significant biological incidents.9
The statement is based on our prior work issued from August 2003
through June 2020 on various preparedness and response issues,
including those for biological threats, as well as our ongoing efforts to
monitor contract obligations.
To conduct our prior work, we reviewed relevant presidential directives,
statutes, regulations, policies, strategic plans, and other reports; and
interviewed federal and state officials, among others. More information on
our scope and methodology can be found in each of the reports cited
throughout this statement. As part of our work on FEMA’s contract
obligations and use of Defense Production Act authorities in response to
COVID-19, we reviewed DHS and FEMA guidance and information, and

7GAO, National Preparedness: Additional Actions Needed to Address Gaps in the
Nation’s Emergency Management Capabilities, GAO-20-297 (Washington, D.C.: May 4,
2020); and GAO, 2017 Disaster Contracting: Actions Needed to Improve the Use of Post-
Disaster Contracts to Support Response and Recovery, GAO-19-281 (Washington, D.C.:
Apr. 24, 2019).
8Federal Emergency Management Agency, 2017 Hurricane Season After-Action Report
(Washington, D.C.: July 12, 2018).
9According to the 2018 National Biodefense Strategy, a “biological incident” is (1) any act
of biological warfare or terrorism; (2) a crime involving a biological agent or biologically
active substance; or (3) any natural or accidental occurrence in which a biological agent or
biologically active substance harms humans, animals, plants, or the environment. By
“nationally significant,” we mean biological incidents that have the potential for
catastrophic consequences, such as the potential to affect a large portion of the United
States or the potential for catastrophic economic consequences.

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Federal Procurement Data System-Next Generation data through May
31, 2020.10 We identified contract actions and associated obligations
related to COVID-19 using the National Interest Action code, as well as
the contract description. We assessed the reliability of federal
procurement data by reviewing existing information about the Federal
Procurement Data System-Next Generation and the data it collects—
specifically, the data dictionary and data validation rules—and performing
electronic testing. We determined that the data were sufficiently reliable
for the purposes of describing FEMA’s reported contract obligations in
response to COVID-19.
The work upon which this statement is based was conducted 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.
Leadership of the whole-of-nation response. As part of the
interagency group with responsibility for leading the whole-of-nation
response and the federal official responsible for the operations of the
National Response Coordination Center (NRCC),11 the FEMA
Administrator has a key role in managing the COVID-19 response. This
includes responding to states’ needs for critical medical supplies.12
According to the FEMA Administrator’s June 2020 testimony before the
Senate Committee on Homeland Security and Government Affairs, on
March 19, under the direction of the White House Coronavirus Task
Force, FEMA moved from playing a supporting role in assisting the U.S.
Department of Health and Human Services (HHS), which was designated
as the initial lead federal agency for the response, to directing it.
As with any emergency or major disaster requiring a coordinated federal
response, the NRCC serves as the interagency coordination hub for
response actions and resources for the COVID-19 pandemic response.

10For the purposes of this statement, “contract obligations” means obligations on contracts
that are subject to the Federal Acquisition Regulation, and does not include, for example,
grants, cooperative agreements, loans, other transactions for research, real property
leases, or requisitions from federal stock.
11The NRCC is a multiagency coordination center located within FEMA headquarters.
12GAO-20-625.
FEMA’s Role in
Managing the
COVID-19 Response

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According to FEMA officials, to help lead the response, the Administrator
activated the NRCC to the highest level—which includes full staffing of all
key interagency functions—on March 19. The NRCC can bring to bear
the existing authorities, processes, resources, and funding that the
various federal agencies can offer to meet response needs.
The Unified Coordination Group—made up of the FEMA Administrator,
the HHS Assistant Secretary for Preparedness and Response, and a
CDC representative—has responsibility for operational command,
leadership, and decision-making for the COVID-19 pandemic response.
The three leaders are partners in operational decision-making for the
response and provide input to the White House Coronavirus Task Force.
According to FEMA and HHS officials involved in the response and
operational documents used in response coordination, FEMA, the
Assistant Secretary, and CDC have complementary roles that correspond
to their missions and expertise. The FEMA Administrator, for example,
focuses on directing nationwide operational needs—such as the logistics
of moving material, supplies, and personnel to meet emergent needs and
tracking the delivery of these supplies. We are conducting ongoing work
reviewing FEMA’s actions in response to the pandemic under the Stafford
Act, including any challenges FEMA faces in coordinating and providing
resources to states and tribal entities.
Efforts to acquire and distribute critical medical supplies. FEMA has
relied on various mechanisms to procure needed goods and services. As
part of the federal response to the pandemic, FEMA has worked in
coordination with HHS and the Department of Defense (DOD) to increase
the availability of supplies for COVID-19—including purchasing and
distributing supplies to states and others. As part of the response led out
of the NRCC, eight task forces, representing different functional lines of
effort, provide operational guidance and secure resources to coordinate
the whole-of-government response. We reported in June 2020, that,
according to FEMA officials, these task forces bring together federal
departments and agencies with the relevant expertise, authorities, and
capabilities necessary to address unmet needs.13 One of these is the
Supply Chain Task Force, which is led jointly by detailees from DOD and
FEMA and has the objective of maximizing the nationwide availability of
mission-essential protective and lifesaving resources and equipment
based on need.

13GAO-20-625.

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According to FEMA officials, the Supply Chain Joint Task Force’s efforts
have largely been led by FEMA’s Office of the Chief Procurement Officer
to address limited supplies of personal protective equipment, ventilators,
and other needed resources.14 FEMA has used various contracting
mechanisms to support its efforts.
Based on preliminary observations from our ongoing review of
government-wide contract obligations, FEMA’s contract obligations in
response to COVID-19 totaled about $1.6 billion as of May 31, 2020, with
obligations for goods accounting for $1.4 billion, or 86 percent of that
total. Our preliminary analysis of contract obligations reported in the
Federal Procurement Data System-Next Generation indicates that over
three-quarters of FEMA’s obligations on goods were reported as medical
and surgical equipment, such as reusable surgical gowns and N95
respirators or masks for medical professionals. See figure 1 for the top
categories of goods and services FEMA procured.
Figure 1: Top Products and Services Procured through the Federal Emergency
Management Agency’s Federal Contracts in Response to COVID-19, as of May 31,
2020

14In May 2020, FEMA officials told us that HHS, FEMA, and the Supply Chain Task Force
would be transitioning some of the procurement responsibilities previously led by FEMA to
DOD.

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Our preliminary analysis also found that about $1.4 billion of FEMA’s
contract obligations were awarded on new contracts, compared to
preexisting contracts established before the pandemic.15 We plan to issue
future products focused on agencies’ planning and management of
contracts awarded in response to the pandemic, including a report later
this month that will describe, among other things, key characteristics of
federal contracting obligations awarded in response to COVID-19.
In addition to contracting for goods and services, we further reported in
June 2020 that, as part of the Supply Chain Task Force, FEMA has also
been involved in the delivery of personal protective equipment and
supplies through Project Air Bridge.16 This effort—developed in
coordination with six large medical supply distributors—was intended to
reduce the time it takes to receive needed supplies from overseas
manufacturers. According to FEMA, the agency pays for the air
transportation of supplies from overseas to the United States, 50 percent
of which are distributed to areas of need based on CDC data. The
medical suppliers distribute the remaining 50 percent through their normal
commercial networks, although, according to FEMA officials, the federal
government has purchased some of these supplies to provide to the
states. In mid-June, FEMA reported that the Unified Coordination Group
is phasing out Project Air Bridge, now that the supply chain for personal
protective equipment has stabilized across the United States.
Use of Defense Production Act authorities. Based on preliminary
observations of our ongoing work on the use of the Defense Production
Act, FEMA has used Defense Production Act Title I authority to place
priority ratings on orders of personal protective equipment in response to

15New contract obligations include obligations on new definitive contracts (as reported in
the Federal Procurement Data System-Next Generation), purchase orders, indefinite
delivery vehicles, and blanket purchase agreements awarded after February 4, 2020—the
date of the first contract obligations in response to COVID-19—and all associated orders,
calls, and modifications to these awards. Preexisting contract obligations include
obligations on orders, calls, and modifications to definitive contracts, purchase orders,
indefinite delivery vehicles, and blanket purchase agreements awarded prior to February
4, 2020. A definitive contract means any contract that must be reported in the Federal
Procurement Data System-Next Generation other than an indefinite delivery vehicle. This
definition is only relevant for Federal Procurement Data System-Next Generation
reporting.
16GAO-20-625.

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COVID-19.17 Specifically, FEMA officials told us they placed priority
ratings on three orders from 3M and received about 49 million N95
respirators from April 12, 2020, through May 20, 2020. According to DHS
Acquisition Alert Notice 20-13, DHS components must seek authorization
by the Unified Coordination Group and the White House Task Force
before placing a priority rating on a contract for COVID-19. Our ongoing
work will further examine FEMA’s role in procuring and distributing critical
goods and how federal agencies used authority under the Defense
Production Act to obtain needed supplies.
Our prior work and the nature of this response suggest issues that may
present challenges for FEMA as this response continues and for any
future incidents. Monitoring known challenges and incorporating lessons
learned from the early phases of the COVID-19 response will provide
critical information to inform improvement efforts for the ongoing
response. Moreover, as the federal government continues to take
necessary steps to protect the American public during the ongoing
pandemic, we must not lose sight of the next potential threat. Our work
had identified challenges, and in many cases made recommendations,
that may be relevant for FEMA. Among these are challenges related to
(1) contracting, (2) medical supply acquisition and distribution during the
pandemic, (3) deploying the disaster workforce, (4) after-action reporting,
(5) interagency planning for nationally significant biological incidents, and
(6) building and assessing nonfederal capabilities for such incidents.
Contracting. Our prior work has identified coordination challenges
between FEMA, other federal agencies, and states and localities related
to the use of contracts following the 2017 disasters. In April 2019, we
found that FEMA’s guidance lacked details on how FEMA and other
federal agencies should coordinate contracting considerations as part of
mission assignments.18 We recommended that FEMA revise its mission
assignment policy and guidance to better incorporate consideration of
contracting needs and to ensure clear communication of coordination
responsibilities related to contracting. FEMA concurred with the
recommendation and stated it would work with other federal agencies to

17According to DHS guidance on the Federal Priorities and Allocations System, a contract
or order containing a priority rating requires the contractor (and the contractor’s supply
chain) to provide preferential treatment to fulfil the delivery requirements of the rated
contract or order. Department of Homeland Security, Office of the Chief Procurement
Officer, Federal Priorities and Allocations System: A Guide for Placing Priority Ratings on
Contracts and Orders (Washington, D.C.: March 2020).
18GAO-19-281.
Potential Challenges
in This and Future
Responses

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develop mission assignment tools, training, and guidance to address
these issues.
We have also identified challenges with FEMA’s coordination and
communication with states and localities over the use of advance
contracts. In December 2018, we found inconsistencies in how FEMA
was coordinating with states and localities and the information FEMA
used to communicate with states and localities on advance contracts.19
We recommended that FEMA provide specific guidance to its contracting
officers to perform outreach to states and localities to encourage and
guide them on the use and establishment of advance contracts, and
communicate information on available advance contracts. FEMA
concurred with our recommendations and has taken some steps to
update its guidance and improve communication. Effective coordination
between FEMA and its federal, state, and local partners helps ensure that
stakeholders have the tools needed to facilitate their emergency response
efforts.
Moreover, our prior work has noted that agencies, including FEMA, can
leverage contracts awarded in advance of a disaster to rapidly and cost-
effectively mobilize resources and that these contracts can help preclude
the need to procure critical goods and services noncompetitively.20 In
December 2018, we recommended that FEMA update its advance
contract strategy to clearly define the objectives of advance contracts,
how they contribute to FEMA’s disaster response operations, and how
they should be prioritized in relation to new, post-disaster contract
awards. FEMA concurred with this recommendation and has taken some
steps to provide additional guidance on the use of advance contracts, but
its actions are still in progress. Our future work will examine contracting
lessons learned related to planning for future public health emergencies.
Medical supply acquisition and distribution during the pandemic. In
June 2020, we reported on concerns about the distribution, acquisition,
and adequacy of supplies from the Strategic National Stockpile and other

19GAO, 2017 Disaster Contracting: Action Needed to Better Ensure More Effective Use
and Management of Advance Contracts, GAO-19-93 (Washington, D.C.: Dec. 6, 2018).
20GAO-19-93.

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sources.21 For example, in April 2020, the National Governors
Association—whose membership comprises state governors, territories,
and commonwealths—noted in a memorandum to governors’ offices that
governors individually and through the association had called for
improved coordination in the federal response to enable states to obtain
critical supplies.22
The National Governors Association further noted that a more
coordinated federal role would help states to obtain personal protective
equipment, ventilators, and other critical supplies to protect responders
and save lives without competition between states and with the federal
government. Similarly, the governors of Colorado and Michigan testified
before the House Committee on Energy and Commerce in June 2020 that
coordination of supplies between the federal government and states
needed to be improved. We previously raised concerns about supply
gaps. Specifically, in 2003, we reported that urban hospitals lacked the
necessary equipment, such as personal protective equipment, to respond
to a large influx of patients experiencing respiratory problems caused by a
bioterrorism event.23 Such an event would require a similar response to
the naturally occurring COVID-19 outbreak.
Officials from the HHS Assistant Secretary for Preparedness and
Response’s office and FEMA officials told us that they did not consider
the views of the National Governors Association to be representative or
reflective of the entire response effort. Moreover, HHS officials noted that
many state stockpiles were inadequate and that public reporting provides
examples where governors and mayors made unnecessarily large
demands for federal resources. FEMA officials also noted that states
overestimated their needs for supplies, such as ventilators. Although we
requested information on the Strategic National Stockpile inventory prior
to the pandemic—such as the types and amounts of supplies that states

21GAO-20-625. The Strategic National Stockpile, which is overseen by the HHS Assistant
Secretary for Preparedness and Response, is the largest federal repository of critical
medical supplies. When FEMA was designated as the lead federal agency for the
pandemic response, responsibility for allocation, distribution, and procurement of supplies
shifted from HHS to the Supply Chain Task Force.
22National Governors Association, Governor Actions to Address PPE and Ventilator
Shortages (Washington, D.C.: Apr. 13, 2020), available at https://www.nga.org/wp-
content/uploads/2020/04/NGA-Medical-Equipment-Memo.pdf.
23GAO, Hospital Preparedness: Most Urban Hospitals Have Emergency Plans but Lack
Certain Capacities for Bioterrorism Response, GAO-03-924 (Washington, D.C.: Aug. 6,
2003).

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requested, as well as what the Assistant Secretary and FEMA distributed
from the stockpile in response to states’ requests—HHS and FEMA had
not yet provided this information as of June 12, 2020. We plan to continue
to seek this information from the agencies.
In addition to the statements made by the National Governors
Association, in June 2020, a National Emergency Management
Association official testified before the Senate Committee on Homeland
Security and Government Affairs about the challenges states faced
accessing the Strategic National Stockpile. These challenges included
limited visibility into the availability of supplies and a failure to receive
items needed in a sufficient quantity or useable condition. For example,
some states reported receiving supplies that were past a functional
expiration date. In addition, this official noted that states reported
problems with receiving supplies from other sources intended to fill the
gap in the stockpile, such as long delivery times (e.g., 46 days for a
shipment of surgical gowns for one state), shipments sent to the wrong
locations, and supplies ordered that never arrived.
We are conducting a comprehensive body of work on the Strategic
National Stockpile in response to the Pandemic and All-Hazards
Preparedness and Advancing Innovation Act of 2019 and the CARES
Act.24 As part of this work, we plan to review progress made in
restructuring the stockpile based on lessons learned from recent
pandemics, an effort the administration announced on May 14, 2020.
Further, we also plan to examine the alignment of supplies in the
stockpile with threat risks; coordination and communication with states,
territories, localities, and tribes; and actions taken, if any, to mitigate
supply gaps. We are also examining the role that FEMA played in
distributing supplies in conjunction with HHS and others and how federal
agencies used authority under the Defense Production Act to obtain
needed supplies.
Deploying disaster workforce. FEMA may face challenges in its ability
to deploy its workforce in response to other disasters in addition to
COVID-19. In May 2020, we reported that FEMA faced staffing shortages
during the 2017 and 2018 disaster seasons, 2 years that were particularly

24Pandemic and All-Hazards Preparedness and Advancing Innovation Act of 2019, Pub.
L. No. 116-22, § 403(a)(5), 133 Stat. 905, 946-47; CARES Act, Pub. L. No. 116-136, §
19010, 134 Stat. 281, 579-81 (2020).

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challenging due to the number and severity of disasters experienced.25
We further reported that FEMA’s qualification and deployment processes
did not provide reliable and complete staffing information to field officials
to ensure effective use of the deployed workforce. We made
recommendations on this issue, among others, which FEMA agreed to
implement.
Our prior work has also found that FEMA’s ability to plan and manage
contracts during a disaster is also complicated by persistent acquisition
workforce challenges, including attrition and staffing shortages. In April
2019, we found that FEMA had identified workforce shortages as a
challenge but had not assessed its contracting workforce needs since at
least 2014.26 We recommended that FEMA assess its workforce needs to
address these shortcomings and develop a plan, including time lines.
FEMA concurred with the recommendation and has taken some steps to
address it.
The large number of declared disasters for the COVID-19 pandemic and
the lack of disaster management experience in this area add additional
layers of complexity to FEMA’s response. Therefore, it is critical that
FEMA give leaders and managers in the field information to help them
respond flexibly and effectively. While continuing to respond to the
pandemic, FEMA and the federal government must also be prepared to
respond when the next disaster inevitably strikes. We will continue to
monitor federal efforts to respond to the pandemic—including FEMA’s
role in coordinating response and recovery efforts nationwide and federal
efforts to prepare for large-scale biological events—as well as challenges
FEMA and other federal agencies face in ensuring that they are able to
respond to major disasters and emergencies effectively and equitably.
FEMA after-action reporting. FEMA policy requires that after-action
reviews be conducted after presidentially declared major disasters to
identify strengths, areas for improvement, and potential best practices of
response and recovery efforts. However, we reported in May 2020 that,
as of January 2020, FEMA had completed after-action reviews for only 29
percent of disasters since January 2017.27 Further, we reported that

25GAO, FEMA Disaster Workforce: Actions Needed to Address Deployment and Staff
Development Challenges, GAO-20-360 (Washington, D.C.: May 4, 2020).
26GAO-19-281.
27GAO-20-297.

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GAO-20-685T
FEMA lacks a formal mechanism for documenting and sharing best
practices, lessons learned, and corrective actions nationwide.
Information collected and reported following a pandemic can inform
responses to future public health emergencies. Furthermore, the National
Response Framework specifies that evaluation and continual process
improvement are cornerstones of effective preparedness. Ensuring that
FEMA and all other agencies participating in the COVID-19 response are
consistently identifying best practices and areas of improvement will be
critical to mounting an effective response now and in the future. In May
2020, we recommended that FEMA prioritize the completion of after-
action reviews, document lessons learned at the headquarters level, and
develop guidance for sharing such reviews with external stakeholders,
when appropriate. DHS concurred with our recommendations and stated
that it is taking steps to address them, including by implementing a new
system for tracking best practices and lessons learned, among other
things.
Interagency planning for nationally significant biological events.
Since 2011, we have called for a more strategic approach to guiding the
systematic identification of risks, assessing resources needed to address
those risks, and prioritizing and allocating investments across the
biodefense enterprise.28 In September 2018, the White House issued the
National Biodefense Strategy (Strategy) and characterized it as a new
direction to protect the nation against biological threats. At the same time,
the President issued the Presidential Memorandum on the Support for
National Biodefense/National Security Presidential Memorandum-14
(NSPM-14), which details a governance structure and implementation
process to achieve the Strategy’s goals. For example, it established two
governing bodies: the Biodefense Steering Committee—chaired by the
Secretary of HHS—and the Biodefense Coordination Team, to support
the efforts of the Steering Committee. In our February 2020 report, we
found that the Strategy and associated plans bring together all the key
elements of federal biodefense capabilities, which presents an

28GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save
Tax Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar. 1,
2011).The biodefense enterprise is the whole combination of systems at every level of
government and the private sector that contribute to protecting the nation and its citizens
from potentially catastrophic effects of a biological event. It is composed of a complex
collection of federal, state, local, tribal, territorial, and private resources, programs, and
initiatives designed for different purposes and dedicated to mitigating both natural and
intentional risks.

Page 14
GAO-20-685T
opportunity to identify gaps and consider enterprise-wide risk and
resources for investment trade-off decisions.29
In February 2020, we reported that the Strategy and its associated plans
bring together the efforts of federal agencies with significant biodefense
roles, responsibilities, and resources to address intentional, accidental,
and naturally occurring threats and is an important step toward the kind of
enterprise-wide strategic decision-making we have called for. In June
2020, we also reported that the Strategy sets goals and objectives to help
the nation prepare for and rapidly respond to biological incidents to
minimize their effect. As such, implementing the strategy could help the
federal government prepare for nationally significant events like the
COVID-19 pandemic.
However, as we reported in February 2020, the Strategy efforts underway
represented a start to a process and a cultural shift that may take years to
fully develop. Given the timing of the COVID-19 pandemic, the Strategy
had not had time to drive change in response planning and other
biodefense functions, and we identified multiple challenges that could
affect the Strategy’s implementation, including challenges in adapting to
new procedures, a lack of clarity in roles and responsibilities for joint
decision making, and a lack of defined resources to sustain ongoing
efforts. We made recommendations to the Secretary of Health and
Human Services, as the agency responsible for coordinating interagency
strategy efforts to address these implementation challenges. HHS agreed
to implement these recommendations. Given the experience of the
COVID-19 response, FEMA’s role and contribution to ongoing
interagency planning efforts for nationally significant biological incidents
will be critical. We have ongoing work on preparedness for and response
to COVID-19 and other such nationally significant events and expect to
report in early 2021.
Building and assessing capabilities. In our February 2020 review of
the National Biodefense Strategy, we reported that the initial federal effort
to collect information on all biodefense-related programs, projects, and
activities focused on existing federal activities and did not include a
complete assessment of biodefense capabilities at the nonfederal level ̶
capabilities needed to achieve the goals and objectives outlined in the
Strategy. We recommended that HHS take steps to ensure that

29GAO, National Biodefense Strategy: Additional Efforts Would Enhance Likelihood of
Effective Implementation, GAO-20-273 (Washington, D.C.: Feb. 19, 2020).

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GAO-20-685T
nonfederal resources and capabilities are accounted for in the analysis of
the nation’s biodefense efforts. HHS agreed and described steps it is
taking to address this recommendation.
Capabilities at the nonfederal level are critical for supporting key functions
in biological incident response, and building them has been an ongoing
challenge, as our prior work demonstrates. According to federal, state,
and local officials, early detection of potentially serious disease
indications nearly always occurs first at the local level, making the
capabilities of personnel, training, systems, and equipment that support
detection at the state and local level a cornerstone of our nation’s
biodefense posture.30 In June 2019, we testified that establishing and
sustaining biosurveillance capabilities can be difficult for a myriad of
reasons.31 For example, maintaining expertise in a rapidly changing field
is difficult, as is the challenge of accurately recognizing the signs and
symptoms of rare or emerging diseases.32 Additionally, we reported in
October 2011 that funding targeted for specific diseases does not allow
for a focus on a broad range of causes of morbidity and mortality, and
federal officials have said that the disease-specific nature of funding is a
challenge to states’ ability to invest in core biosurveillance capabilities.33
As we testified in June 2019, implementation of the National Biodefense
Strategy offers the opportunity to design new approaches to identifying
and building a core set of capabilities for emerging infectious diseases.
However, implementation efforts are ongoing and it is yet to be
determined how, if at all, implementation efforts will address this
longstanding challenge.

30GAO, Biosurveillance: Nonfederal Capabilities Should Be Considered in Creating a
National Biosurveillance Strategy, GAO-12-55 (Washington, D.C.: Oct. 31, 2011).
31GAO, Biodefense: The Nation Faces Longstanding Challenges Related to Defending
Against Biological Threats, GAO-19-635T (Washington, D.C.: June 26, 2019).
Biosurveillance, as defined by the July 2012 National Strategy for Biosurveillance, is the
ongoing process of gathering, integrating, interpreting, and communicating essential
information related to all-hazards threats or disease activity affecting human, animal, or
plant health, for the purpose of (1) achieving early detection and warning, (2) contributing
to overall situational awareness of the health aspects of the incident, and (3) enabling
better decision-making at all levels.
32GAO, Biosurveillance: Efforts to Develop a National Biosurveillance Capability Need a
National Strategy and a Designated Leader, GAO-10-645 (Washington, D.C.: June 30,
2010).
33GAO-12-55.

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GAO-20-685T
In our prior work in March 2011, we also recommended that FEMA
complete a national preparedness assessment of capability gaps at each
level of government based on tiered, capability-specific performance
objectives to enable prioritization of grant funding.34 However, as of
March 2020, this recommendation has not been implemented.
In summary, the response to the COVID-19 pandemic has relied on both
public health and emergency management capabilities, which are often
governed by different authorities and directed by different agencies at the
federal and nonfederal level. As the government looks to the future and
takes steps to plan, prepare, and respond to future biological incidents of
national concern, addressing the recommendations we have made to
better address capability gaps can help better position the nation for what
comes next. We are planning upcoming work on federal efforts at DHS
and HHS to support building nonfederal capabilities to respond to and
recover from nationally significant biological incidents.
Chairwoman Torres Small, Chairman Payne, Ranking Member
Crenshaw, Ranking Member King, and Members of the Subcommittees,
this concludes my prepared statement. I would be happy to respond to
any questions you may have at this time.
If you or your staff have any questions concerning this testimony, please
contact Christopher P. Currie at (404) 679-1875, CurrieC@gao.gov.
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this statement. Individuals
making key contributions to this statement include Kathryn Godfrey
(Assistant Director), Sarah Turpin (Analyst-in-Charge), Danielle Curet,
Michele Fejfar, Eric Hauswirth, Tracey King, Susanna Kuebler, Janet
McKelvey, Marie Mak, Amanda Miller, Jan Montgomery, and Meghan
Perez. Key contributors for the previous work that this testimony is based
on are listed in each product.

34GAO-11-318SP.

GAO Contact and
Staff
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