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After-Action Findings and COVID-19 Response Revealed Opportunities to Strengthen Preparedness (GAO-21-513)

Summary

A GAO report to congressional committees, GAO-21-513, dated August 2021, on biodefense. It states that the COVID-19 pandemic shows how catastrophic biological incidents can cause substantial loss of life and economic damage and require a whole-of-nation response. GAO reports that key federal agencies, including the Departments of Homeland Security, Defense, Health and Human Services, and Agriculture, developed a range of strategic, operational and tactical interagency response plans for nationally significant biological incidents. Its title states that after-action findings and the COVID-19 response revealed opportunities to strengthen preparedness.

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              United States Government Accountability Office
              Report to Congressional Committees




              BIODEFENSE
August 2021




              After-Action Findings
              and COVID-19
              Response Revealed
              Opportunities to
              Strengthen
              Preparedness




GAO-21-513
                                            August 2021

                                            BIODEFENSE
                                            After-Action Findings and COVID-19 Response
                                            Revealed Opportunities to Strengthen Preparedness
Highlights of GAO-21-513, a report to
congressional committees




Why GAO Did This Study                      What GAO Found
The COVID-19 pandemic shows how             Key federal agencies, including the Departments of Homeland Security (DHS),
catastrophic biological incidents can       Defense (DOD), Health and Human Services (HHS), and Agriculture (USDA),
cause substantial loss of life, economic    developed a range of interagency response plans to prepare for nationally
damage, and require a whole-of-nation       significant biological incidents. These strategic, operational, and tactical level
response involving multiple federal and     plans address responding to a broad spectrum of biological threats, including
nonfederal entities. The 2018 National      those that are intentional, accidental, or naturally occurring.
Biodefense Strategy outlines specific
goals and objectives to help prepare        DHS, DOD, HHS, and USDA conducted numerous interagency exercises to help
for and respond to such incidents.          prepare for and respond to a wide variety of biological incidents, such as anthrax
                                            attacks, influenza pandemics, and diseases affecting plants and animals.
The CARES Act includes a provision
                                            Specifically, GAO identified 74 interagency biological incident exercises
for GAO to conduct monitoring and
oversight of federal efforts to prepare
                                            conducted from calendar years 2009 through 2019.
for, respond to, and recover from
COVID-19. This report addresses: (1)        Number of Interagency Biological Incident Exercises Conducted, Calendar Years
interagency plans key federal agencies      2009 through 2019
developed, and exercises they
conducted, to help prepare for
biological incidents; and (2) the extent
to which exercises and real-world
incidents revealed opportunities to
better achieve National Biodefense
Strategy objectives.
GAO reviewed biological incident plans
and after-action reports from exercises
and real-world incidents from calendar
years 2009 through 2019, including a
non-generalizable sample of 19 reports
selected based on threat scenario and
other factors. GAO interviewed federal
and state officials to obtain their
perspectives on plans, exercises, and
the COVID-19 response.

What GAO Recommends
GAO is making four recommendations
each to DHS, DOD, HHS, and USDA,
including that the secretaries work         GAO’s analysis of after-action reports for selected interagency biological incident
through the Biodefense Steering             exercises and real-world incidents, as well as the COVID-19 response, identified
Committee to communicate exercise           long-standing biodefense challenges. GAO found that the nation lacked elements
priorities and conduct monitoring. The      necessary for preparing for nationally significant biological incidents, including a
departments generally concurred but in      process at the interagency level to assess and communicate priorities for
response to comments GAO modified           exercising capabilities. Further, it determined that agencies do not routinely work
the recommendations to reflect that the     together in monitoring results from exercises and real-world incidents to identify
secretaries work through the                patterns and root causes for systemic challenges. Assessing and communicating
Committee identified above.                 exercise priorities and routinely monitoring the results of the exercises and
                                            incidents will help ensure the nation is better prepared to respond to the next
For more information, view GAO-21-513 or    biological threat.
contact Chris Currie at (404) 679-1875 or
CurrieC@gao.gov.
                                                                                     United States Government Accountability Office
Contents


Letter                                                                                1
               Background                                                             7
               Agencies Developed Interagency Response Plans and Conducted
                  Biological Incident Exercises                                     16
               Interagency Exercises and Real-World Incidents Show
                  Opportunities to Better Implement the National Biodefense
                  Strategy                                                          30
               Conclusions                                                          50
               Recommendation for Executive Action                                  51
               Agency Comments and Our Evaluation                                   54

Appendix I     National Biodefense Strategy Preparedness and
               Response Categories                                                  59



Appendix II    National Preparedness Goal and Public Health Capabilities            62



Appendix III   Comments from the Department of Homeland Security                    66



Appendix IV    Comments from the Department of Defense                              70



Appendix V     Comments from the Department of Health and Human Services            73



Appendix VI    GAO Contact and Staff Acknowledgments                                77


Tables
               Table 1: National Biodefense Strategy Preparedness and
                       Response Objectives                                          12
               Table 2: Number of After-Action Report Areas for Improvement
                       with Interagency Implications, by Most Common National
                       Biodefense Strategy Objectives                               32
               Table 3: National Biodefense Strategy Preparedness and
                       Response Objectives                                          59


               Page i                                              GAO-21-513 Biodefense
Figures
          Figure 1: Federal Interagency Biological Incident Planning
                   Framework and Selected Response Plans, As Identified
                   By Agencies                                                     19
          Figure 2: Number of Interagency Biological Incident Exercises
                   Conducted, Calendar Years 2009 through 2019                     27
          Figure 3: Number of Interagency Biological Incident Exercises
                   Conducted from Calendar Years 2009 through 2019, by
                   Threat Scenario Category                                        28
          Figure 4: Participants in Interagency Biological Incident Exercises
                   Conducted from Calendar Years 2009 through 2019, by
                   Threat Scenario Category                                        30
          Figure 5: Supply Shipment during the COVID-19 Pandemic                   38
          Figure 6: Participants in a Biological Incident Exercise                 45
          Figure 7: National Preparedness Goal’s 32 Emergency
                   Management Core Capabilities by Mission Area                    63
          Figure 8: Public Health Emergency Preparedness and Response
                   Capabilities                                                    65




          Page ii                                                 GAO-21-513 Biodefense
Abbreviations

CDC                        Centers for Disease Control and Prevention
COVID-19                   Coronavirus Disease 2019
DHS                        Department of Homeland Security
DOD                        Department of Defense
FEMA                       Federal Emergency Management Agency
HHS                        Department of Health and Human Services
NDAA                       National Defense Authorization Act
NSPM-14                    National Security Presidential Memorandum-14
PanCAP                     Pandemic Crisis Action Plan
SARS                       Severe Acute Respiratory Syndrome
USDA                       U.S. Department of Agriculture




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Page iii                                                           GAO-21-513 Biodefense
                       Letter




441 G St. N.W.
Washington, DC 20548




                       August 4, 2021

                       Congressional Committees

                       The outbreak of the Coronavirus Disease 2019 (COVID-19) pandemic
                       demonstrates how catastrophic biological incidents have the potential to
                       cause substantial loss of life and sustained damage to the economy,
                       societal stability, and global security. 1 The National Biodefense Strategy,
                       issued in 2018, outlines specific goals and objectives designed to help the
                       nation prepare for and respond to nationally significant biological
                       incidents like the COVID-19 pandemic, as well as future incidents that
                       could be even more consequential. Throughout this report we use the
                       term “nationally significant biological incident” to distinguish more routine
                       public or animal health responses—such as localized or regional disease
                       outbreaks or foodborne illness—from incidents that have an unusual
                       impact on the nation. 2 Examples of nationally significant biological
                       incidents contemplated in this report include attacks on the homeland
                       using biological agents, emerging infectious outbreaks with pandemic
                       potential, and declared pandemics.

                       The Strategy brings together, for the first time under one strategic
                       umbrella, all the critical functions needed to prevent, detect, prepare for,




                       1As defined by the National Biodefense Strategy, biological incidents are: (1) any act of
                       biological warfare or terrorism; (2) a crime involving a biohazard; or (3) any natural or
                       accidental occurrence in which a biohazard harms humans, animals, plants, or the
                       environment.
                       2Individual federal agencies or established structures designed specifically for routine
                       incidents generally can respond using existing authorities and responsibilities. Conversely,
                       nationally significant biological incidents require extensive and sometimes unique
                       applications of federal authorities and resources, across multiple federal departments and
                       agencies, because of their scale or potential consequences (both economic and health).
                       An overlapping concept in the context of disease outbreaks and biological attacks is the
                       public health emergency. A public health emergency is a formal legal authority that the
                       Secretary of Health and Human Services can invoke to direct response resources toward
                       health-related emergencies. Apart from COVID-19 and the opioid crisis, nearly all
                       declared public health emergencies in the past decade have been for secondary health
                       effects resulting from climate or seismic disasters. Our definition of a nationally significant
                       biological incident does not generally include such secondary health effects, because they
                       tend to be more localized and can usually be addressed using existing authorities and
                       responsibilities.




                       Page 1                                                                GAO-21-513 Biodefense
respond to, and recover from such incidents regardless of their cause. 3
The nature of biological threats can be intentional, naturally occurring, or
accidental and can affect human, animal, and plant health. Several
federal agencies have responsibilities related to nationally significant
biological incidents and for implementing the Strategy. The National
Defense Authorization Act for Fiscal Year 2017 (NDAA) specifically
charged four federal departments with developing the Strategy: the
Departments of Homeland Security (DHS), Defense (DOD), Health and
Human Services (HHS), and Agriculture (USDA). 4

As we have previously reported, preparing for and responding to
nationally significant biological incidents requires a whole-of-nation,
multidisciplinary approach involving multiple federal agencies and
coordination with nonfederal entities. 5 The COVID-19 pandemic, for
example, has required an unprecedented use of multiple systems and
authorities established for both public health crises and natural disasters.
The nation’s biodefense capabilities consist of all efforts to counter
biological threats, reduce risks, and prepare for, respond to, and recover
from biological incidents that could have catastrophic consequences. 6
Activities undertaken to prepare for such incidents, regardless of size or
scale, include building and sustaining capabilities, developing interagency
plans, conducting exercises with multiple federal and nonfederal entities,
and developing after-action reports and lessons learned with
corresponding corrective actions. We have previously reported on a wide
range of biodefense-related efforts carried out by multiple federal




3See GAO, National Biodefense Strategy: Additional Efforts Would Enhance Likelihood of
Effective Implementation, GAO-20-273 (Washington, D.C.: Feb. 19, 2020).
4The National Defense Authorization Act for Fiscal Year 2017 (NDAA) called for the
development of a national biodefense strategy. See Pub. L. No. 114-328, § 1086, 130
Stat. 2000, 2423 (2016) (codified at 6 U.S.C. § 104).
5GAO-20-273. Nonfederal entities include state, local, tribal, and territorial entities, such
as state and local public health departments, as well as private sector and nonprofit
entities, such as hospitals and pharmaceutical companies.
6In the context of emergency management and related functions, a capability is the
combination of leadership and organization, planning, personnel, training, equipment and
systems, and assessment needed to successfully execute a particular mission.




Page 2                                                                 GAO-21-513 Biodefense
departments and agencies and on long-standing challenges to building
and maintaining the nation’s biological defense capabilities. 7

The CARES Act includes a provision for GAO to conduct monitoring and
oversight of federal agencies’ efforts to prepare for, respond to, and
recover from the COVID-19 pandemic. 8 GAO is to report on, among other
things, the pandemic’s effects on the health, economy, and public and
private institutions of the United States, including the federal
government’s public health and homeland security efforts. This report
addresses the following objectives:

1. What interagency plans have key federal agencies developed, and
   what exercises have they conducted, to help prepare for nationally
   significant biological incidents?
2. To what extent have past exercises and real-world incidents, including
   the COVID-19 response, revealed opportunities to better achieve the
   objectives of the National Biodefense Strategy?
To identify what interagency plans key agencies developed to help
prepare for nationally significant biological incidents, we asked officials
responsible for emergency preparedness planning from four key
agencies—DHS, DOD, HHS, and USDA—to identify any biological
incident plans their agencies contributed to from calendar years 2009
through March 2020. 9 We reviewed strategic, operational, and tactical
plans identified by the agencies to confirm whether they had both an
interagency and biological incident nexus. We analyzed the interagency
biological incident plans identified to obtain descriptive information on the
different layers of federal planning efforts and to determine the types of
biological threats covered. Specifically, we reviewed the 2018 National
Biodefense Strategy, the 2017 Biological Incident Annex to the Federal

7GAO, Biodefense: The Nation Faces Long-Standing Challenges Related to Defending
Against Biological Threats, GAO-19-635T (Washington, D.C.: June 26, 2019).
8Pub. L. No. 116-136, § 19010, 134 Stat. 281, 579-81 (2020). We regularly issue
government-wide reports on the federal response to COVID-19. For the latest report, see
GAO, COVID-19: Continued Attention Needed to Enhance Federal Preparedness,
Response, Service Delivery, and Program Integrity, GAO-21-551 (Washington, D.C.: July
19, 2021). Our next government-wide report will be issued in October 2021 and will be
available on GAO’s website at https://www.gao.gov/coronavirus.
9We selected these agencies because of their roles in biodefense, and the NDAA
requirement that they develop the National Biodefense Strategy. We selected this time
period to cover a range of federal planning efforts from the H1N1 outbreak in 2009
through the beginning of the COVID-19 pandemic.




Page 3                                                           GAO-21-513 Biodefense
Interagency Operational Plans, the National Food and Agriculture Annex,
and the 2018 Pandemic Crisis Action Plan, among others referenced in
this report. We further interviewed DHS, DOD, HHS, and USDA officials
to determine the process by which key agencies review and update
interagency biological incident plans. 10

To identify what interagency exercises these key federal agencies
conducted to help prepare for nationally significant biological incidents,
we obtained and reviewed documentation, such as after-action reports,
on interagency biological incident exercises in which DHS, DOD, HHS,
and USDA participated from calendar years 2009 through 2019. 11 We
catalogued descriptive information, such as the exercise date, threat
scenario exercised, types of exercise participants, and core capabilities
exercised. We also interviewed or provided written questions to DHS,
DOD, HHS, and USDA officials responsible for exercise efforts to obtain
additional details on exercises within our scope. 12

To address the extent to which past exercises and real-world incidents
revealed opportunities to better achieve the objectives of the National
Biodefense Strategy, we analyzed a non-generalizable, judgmental
sample of 19 after-action reports developed from calendar years 2009
through 2019. 13 The sample included 11 after-action reports produced for
exercises and eight after-action reports produced for real-world incidents.
To select the exercise after-action reports, we first categorized the threat
scenario of each exercise based on four categories, then stratified the
sample based on the proportion of exercises from each category to the
total number of exercises we identified to ensure a range of different


10While biological incidents can have global implications and require outreach and
coordination beyond our borders, this report focuses on domestic preparedness and
response efforts.
11We asked DHS, DOD, HHS, and USDA officials to identify interagency biological
incident exercises in which they participated and compared the lists of exercises we
received with exercise information obtained from DHS, DOD, and HHS for current and
prior GAO work.
12Because of agencies’ heavy involvement in COVID-19 response activities, we accepted
written responses in lieu of meeting early in the review.
13We selected this time period to cover a range of exercises and events from the H1N1
outbreak in 2009 through the time period immediately before the start of the COVID-19
pandemic. Beginning in 2020, agency efforts across the whole-of-government were
focused on responding to the pandemic.




Page 4                                                             GAO-21-513 Biodefense
scenarios. 14 We then selected after-action reports in each category based
on the number of federal agencies participating and the type of plan
exercised. 15 For real-world incidents, we selected and reviewed all of the
after-action reports agencies identified for the H1N1, Ebola, and Zika
incidents (a total of eight), because they were among the five incidents
declared a Public Health Emergency of International Concern from 2009
through 2019. 16 In addition, the H1N1 and Ebola incidents resulted the
highest numbers of fatalities. 17

In reviewing the 11 exercise and eight real-world incident after-action
reports, we identified over 500 findings with which to conduct further
analysis. We analyzed each finding from the 19 selected after-action
reports and determined whether the finding had interagency implications,
meaning that it involved activities undertaken by multiple federal
departments. We categorized findings with interagency implications into
one of the objectives from the preparedness or response goals of the
National Biodefense Strategy. 18 We then analyzed the results to identify
any patterns or common areas of findings across the exercises. The
results of our analysis are not generalizable to all biological incident after-
action reports; however they provide insight into common areas of
findings.



14The four categories included: (1) naturally occurring influenza incidents primarily
affecting human health (“Natural influenza”); (2) naturally occurring non-influenza incidents
primarily affecting human health (“Natural non-influenza”); (3) intentional incidents
primarily affecting human health (“Intentional”); and (4) incidents primarily affecting
animal/plant health (“Animal/plant”). We included four Natural influenza, two Natural non-
influenza, three Intentional, and two Animal/plant exercise after-action reports in our
sample.
15We selected exercises with the highest number of federal agencies participating as a
proxy for the exercises that are more likely to have findings with interagency implications.
We further considered whether the after-action reports provided sufficient detail for us to
capture and categorize findings.
16The two remaining incidents declared to be Public Health Emergencies of International
Concern from 2009 through 2019 were poliomyelitis (polio) (2014 to present) and the
Ebola outbreak in Democratic Republic of Congo (2018–2020). The COVID-19 pandemic
(2020 to present) was also declared a Public Health Emergency of International Concern.
17While fatalities from Zika infection were rare, the incident posed significant concerns for
birth defects (e.g., microcephaly) in children born to mothers infected with the virus.
18We summarized the objectives for readability and ease of reporting. For a list of these
objectives, see appendix I.




Page 5                                                                GAO-21-513 Biodefense
Because the COVID-19 response is ongoing, agencies had not yet
produced after-action reports at the time of our review. We therefore
reviewed documentation on initial federal response challenges, such as
the Federal Emergency Management Agency’s (FEMA) initial
assessment report. We also asked selected agency officials and
nonfederal entities—including health care and emergency management
associations, health care experts, and state officials—about any
challenges that emerged during the COVID-19 response and gaps in
preparedness for biological incidents. Specifically, we interviewed officials
from DHS, DOD, HHS, and USDA who were responsible for aspects of
the COVID-19 response as well as officials from six FEMA regions, and
officials from the departments of health and emergency preparedness
from 10 states. 19 We selected eight of these states to include a range of
COVID-19 case counts per capita and number of recent disaster
declarations. 20 We further selected these states to ensure regional
diversity and include both participants and non-participants in Crimson
Contagion—a 2019 large-scale influenza exercise—as well as a range in
level of public health and state preparedness. 21 In addition, we conducted
an interview with the National Emergency Management Association,
which offered perspectives of the association plus the individual
perspectives of two additional states. 22 While the results of these
interviews are not generalizable to all states, they provide a range of
perspectives on the topics in our review.

Once we identified and categorized findings from exercises and real-
world incidents, including the COVID-19 response, we then assessed
DHS, DOD, HHS, and USDA activities and documents against the
National Biodefense Strategy’s preparedness and response goals and
objectives. Additionally, we reviewed after-action reports to determine
whether past exercises focused on capabilities identified as challenges in
the COVID-19 response. We also assessed agency efforts against
Homeland Security Exercises and Evaluation Program guidance related
to exercising capabilities and after-action reports. Several components of


19HHS regional officials participated in two of our FEMA region interviews.


20The eight states are California, Colorado, Idaho, Massachusetts, Nebraska, New Jersey,
New Mexico, and South Carolina.
21The FEMA regions we interviewed represent six of these eight states and were selected
based on similar factors.
22The two additional states were Kansas and Iowa.




Page 6                                                              GAO-21-513 Biodefense
                    standards for internal control were also significant to this objective. 23
                    Specifically: (1) the control environment component and the related
                    principle that management should assign responsibility and delegate
                    authority; (2) the information and communication component and related
                    principle that management should communicate with external parties; and
                    (3) the monitoring component and related principle that management
                    should conduct ongoing monitoring and evaluations. We assessed DHS,
                    DOD, HHS, and USDA activities and documents related to National
                    Biodefense Strategy implementation against these components. We
                    further interviewed DHS, DOD, HHS, and USDA officials responsible for
                    implementing the National Biodefense Strategy to obtain their
                    perspectives on interagency efforts to achieve the Strategy’s objectives.

                    We conducted this performance audit from April 2020 to August 2021 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
Biological Threat   Understanding the vast and evolving biological threat landscape is a
Landscape           necessary step in effectively preparing for and responding to nationally
                    significant biological incidents. Our prior work assessing biodefense
                    activities has discussed a wide variety of biological threats facing the
                    nation, including infectious disease threats to humans and animals, crop
                    failure, threats of biological warfare and bioterrorism, and safety and
                    security lapses at facilities that house biological threat agents, among
                    others. 24

                    Biological threats can be unpredictable, as humans, animals, and plants
                    are vulnerable to a variety of naturally occurring infectious disease and
                    pest threats with potentially serious health, economic, and national
                    security implications. Urbanization, habitat encroachment, and increased

                    23GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
                    (Washington, D.C.: Sep. 10, 2014).
                    24Recent reports from which these examples were drawn include GAO-20-273 and GAO,
                    Biodefense: Federal Efforts to Develop Biological Threat Awareness, GAO-18-155
                    (Washington, D.C.: Oct. 11, 2017).




                    Page 7                                                         GAO-21-513 Biodefense
and faster travel, coupled with weaknesses in global health systems,
increase the risk of infectious diseases spreading rapidly across the
globe. This is evidenced by the rapid spread of COVID-19, which was first
reported in Wuhan, China on December 31, 2019, declared a public
health emergency in the United States by HHS on January 31, 2020, and
characterized as a pandemic by the World Health Organization on March
11, 2020.

Pandemic influenza also presents a constant threat to global public health
and exemplifies the susceptibility of humans to diseases with animal
origins. For example, a novel influenza A (H1N1) virus emerged in 2009
with a new combination of genes from swine, avian, and human influenza
viruses and led to a global pandemic. Other examples of zoonotic disease
threats—infectious diseases that are transmissible between animals and
humans—include the Ebola and Zika viruses, and coronaviruses such as
COVID-19.

Threats to agriculture can have serious economic consequences for the
nation. For example, from December 2014 through June 2015, an
outbreak of high pathogenicity avian influenza (known as HPAI) in the
United States led to the deaths of approximately 7.4 million turkeys and
43 million egg-laying chickens, either from the disease itself or from
depopulation efforts to contain the outbreak. HPAI was detected in
commercial premises, backyard flocks, wild captive birds, and/or wild
birds in 21 states. According to USDA, this outbreak was the most
significant animal health event in U.S. history, costing federal taxpayers
more $700 million and devastating affected agricultural businesses.

Additionally, extreme climate conditions, such as sustained drought and
heat waves can affect crops and livestock, and excess precipitation can
also increase flooding events and erosion, and decrease soil quality.
According to DHS, in addition to the direct impact of drought and heat
waves on the crops and livestock, these conditions may also render the
crops, the livestock, and even the population, more susceptible to disease
of either natural or intentional origin. Losses of livestock and crops from
the biological threats of disease, pests, or extreme climate conditions
could have significant effects on trade and the national economy.

The use of biological weapons or their proliferation by state or non-state
actors also presents a significant challenge to our national security, our
population, our agriculture, the economy, and the environment.
Additionally, in many countries around the world, pathogens are stored in
laboratories that lack appropriate biosecurity measures which increases


Page 8                                                  GAO-21-513 Biodefense
                          the risk that pathogens could be diverted by actors with intent to do harm,
                          such as terrorist organizations or lone wolves, or be accidentally released
                          from the facility.

Key Federal Agencies’     Effectively preparing for and responding to nationally significant biological
Planning and Exercising   incidents transcends what any one agency can achieve on its own and
                          requires a whole-of-community approach involving federal, state, local,
Responsibilities
                          tribal, territorial, and private sector involvement. As stated above, at the
                          federal level, DHS, DOD, HHS and USDA were the agencies tasked in
                          federal law with developing a national biodefense strategy. 25 Each has
                          key biodefense responsibilities from a homeland security and national
                          security perspective, including planning and exercising functions.

                          •   DHS. Within DHS, FEMA is the lead federal agency responsible for
                              disaster preparedness, response, and recovery. As such, FEMA
                              facilitates planning efforts for all hazards, including biological
                              incidents. FEMA also supports efforts to exercise capabilities
                              nationwide through the National Exercise Program—a two-year cycle
                              of exercises that examines and validates core capabilities. The
                              Program includes selected exercises involving federal, state, local,
                              territorial, tribal, and private sector partners that are aligned to a set of
                              strategic priorities. 26 The Countering Weapons of Mass Destruction
                              Office leads DHS efforts and coordinates with domestic and
                              international partners to safeguard the United States against
                              chemical, biological, radiation, nuclear, and health security threats.
                              This includes serving as the DHS lead for developing biodefense
                              strategy and policy, and coordinating the Department’s efforts to




                          25See Pub. L. No. 114-328, § 1086, 130 Stat.at 2423 (codified at 6 U.S.C. § 104). While
                          our report focuses on the four departments originally tasked with developing the National
                          Biodefense Strategy, a number of departments and agencies have responsibility for
                          implementing the Strategy, which we describe in the next section.
                          26These priorities are referred to as the Principals’ Strategic Priorities and are determined
                          by the Principals’ Committee of the National Security Council. The priorities are
                          determined by stakeholder input, data from reports such as the National Preparedness
                          Report and the Threat and Hazard Identification and Risk Assessment, and exercise and
                          real-world after-action reports, among other things.




                          Page 9                                                                GAO-21-513 Biodefense
    defend U.S. food, agriculture, and veterinary systems against
    terrorism and other high-consequence events. 27
•   DOD. DOD protects U.S. armed forces from biological threats
    worldwide. DOD is also responsible—subject to the availability of
    resources and the direction of the President or by approval of the
    Secretary of Defense—for providing support functions and
    supplementing civil authorities’ resources in response to public health
    and medical disasters. Within DOD, U.S. Northern Command
    provides strategic planning guidance for the department’s efforts to
    prepare for and respond to pandemic diseases, including influenza
    and other infectious diseases.
•   HHS. The Assistant Secretary for Preparedness and Response leads
    the nation’s medical and public health preparedness effort for
    responding to and recovering from disasters and public health
    emergencies, such as biological incidents. 28 This office is responsible
    for coordinating the federal public health and medical response to
    emergent threats and all-hazards incidents, and develops and
    conducts exercises focused on HHS preparedness issues, among
    other things. It also leads the Biodefense Coordination Team, which
    coordinates implementation of the National Biodefense Strategy. The
    Centers for Disease Control and Prevention (CDC) supports public
    health preparedness efforts to prevent, detect, and respond to new
    and emerging health threats. 29 Within the National Institutes of Health,
    the National Institute of Allergy and Infectious Diseases conducts and
    supports research to control and prevent infectious disease. The Food

27Additional DHS components also play a role in biodefense. For example, DHS’s Science
and Technology Directorate leads key efforts related to enhancing threat awareness with
a focus on bioterrorism; U.S. Customs and Border Protection plays a role in detecting
biological threats at the border; and the U.S. Coast Guard conduct ports and waterways
coastal security, search and rescue, and marine safety missions during a biological
incident.
28The Assistant Secretary for Preparedness and Response leads preparedness efforts
through planning and response; building federal emergency medical operational
capabilities; countermeasures research, advance development, and procurement; and
grants to strengthen the capabilities of hospitals and health care systems in public health
emergencies and medical disasters. Among other things, the office also maintains the
Strategic National Stockpile, a federal stockpile of vaccines, pharmaceuticals, and medical
supplies and devices designed to be available for rapid deployment in a public health
emergency.
29CDC provides scientific expertise and collaborates with state, local, and international
departments of health through the advancement of core public health functions such as
surveillance, epidemiology and assessment sciences, and laboratory science.




Page 10                                                             GAO-21-513 Biodefense
                              and Drug Administration is also responsible for emergency and crisis
                              response activities involving regulated products, such as intentional
                              acts of food supply adulteration. 30
                          •   USDA. USDA is the lead agency with responsibility to protect and
                              improve the health, quality, and marketability of our nation’s
                              agricultural products. Within USDA, the Animal and Plant Health
                              Inspection Service is responsible for working to prevent, control, or
                              eliminate harmful pests, pathogens, and diseases of animals and
                              plants. The Service consists of multiple component units with key
                              roles in biodefense including Veterinary Services and the Plant
                              Protection and Quarantine program. The Office of Homeland Security
                              leads the department’s security, preparedness and response efforts.
                              The Food Safety and Inspection Service is USDA’s public health
                              agency and promotes food defense and preparedness to respond to
                              acts of intentional food contamination. 31

National Biodefense       The National Biodefense Strategy, issued in September 2018, outlines a
Strategy’s Preparedness   whole-of-government approach intended to help the United States
                          actively and effectively assess, prevent, prepare for, respond to, and
and Response Goals
                          recover from all types of biological threats, whether they are natural,
                          accidental, or deliberate. The Strategy consists of five high-level goals
                          with associated objectives and sub-objectives designed to strengthen the
                          biodefense enterprise. 32 Two goals specifically address preparedness
                          and response actions needed to reduce or limit the effects of biological
                          incidents. For example, they outline key objectives to strengthen public
                          and veterinary health infrastructure as well as objectives designed to
                          coordinate response actions, such as ensuring risk-informed, accurate,
                          timely, and actionable public messaging during a response. Table 1
                          below summarizes the objectives under the Strategy’s preparedness and




                          30The Food and Drug Administration is also responsible for ensuring that medical
                          countermeasures—such as drugs, vaccines, and diagnostic tests—are safe, effective, and
                          secure. Additional HHS offices with a role in biodefense preparedness and response
                          include the Office of Global Affairs and the Office of National Security, among others.
                          31Food defense is the protection of food products from intentional contamination or
                          adulteration where there is an intent to cause public harm or economic disruption.
                          32The five goals include: (1) Enable risk awareness to inform decision making across the
                          biodefense enterprise; (2) Ensure capabilities to prevent bioincidents; (3) Ensure
                          preparedness to reduce the impacts of bioincidents; (4) Rapidly respond to limit the
                          impacts of bioincidents; and (5) Facilitate recovery to restore the community, the
                          economy, and the environment after a bioincident.




                          Page 11                                                            GAO-21-513 Biodefense
                                                              response goals. For additional information on each of the objectives, see
                                                              appendix I.

Table 1: National Biodefense Strategy Preparedness and Response Objectives

Preparedness
•   Support U.S. biodefense research, development, and investment
•   Ensure a strong public and veterinary health infrastructure
•   Develop, exercise, and update plans and capabilities
•   Develop, exercise, and update risk plans to support effective public messaging, enhance public trust, and promote consistent
    messaging
•   Improve diagnostic capabilities and enhance medical countermeasures
•   Enhance community mitigation measures development and capabilities
•   Enhance decontamination preparedness
•   Improve the ability for the federal government to collaborate with states and territories
•   Work with international governments to improve global preparedness
Response
•      Manage information
•      Coordinate response operations and resources
•      Conduct operations and investigations for intentional incidents
•      Provide effective public messaging
Source: GAO summary of National Biodefense Strategy information. | GAO-21-513



                                                              The Strategy is important because of the complexity and fragmentation
                                                              inherent in an enterprise mission like biodefense. For example, our prior
                                                              work identified the need for a strategy to help ensure efficiency and
                                                              effectiveness across the entire biodefense enterprise (including federal
                                                              agencies, nonfederal governments, and private/nonprofit entities) by
                                                              connecting strategic approaches and investment decisions across
                                                              disparate but interrelated functions within the biodefense enterprise. 33
                                                              These functions are (1) understanding and defining threats, (2) taking
                                                              action to prevent and protect against attacks and significant national and
                                                              international infectious disease outbreaks, (3) employing new and existing
                                                              techniques and technologies to more quickly detect biological events, and
                                                              (4) preparing to respond and recover.

                                                              National Security Presidential Memorandum-14 (NSPM-14)—issued at
                                                              the same time as the Strategy—provides a governance structure to guide
                                                              the Strategy’s implementation, coordinate federal biodefense activities,
                                                              33See GAO, Opportunities to Reduce Potential Duplication in Government Programs,
                                                              Save Tax Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar 1,
                                                              2011).




                                                              Page 12                                                       GAO-21-513 Biodefense
and assess the effectiveness with which its goals and objectives are
being met. NSPM-14 created the Biodefense Steering Committee, which
is chaired by the Secretary of HHS and includes the heads of federal
agencies with biodefense responsibilities or capabilities as members. It
also required the formation of a Biodefense Coordination Team. The
Team consists of staff from multiple agencies, and its purpose is to assist
the Committee in monitoring and coordinating implementation of the
Strategy. 34

NSPM-14 lays out, in broad strokes, a process to identify budget priorities
across federal biodefense efforts and to assess (1) how current resources
support the Strategy, (2) how existing programs and resources could
better align with the Strategy, and (3) how additional resources, if
available, could be applied to support the goals of the Strategy. This
process begins through a data call with participating agencies
documenting all biodefense programs, projects, and activities within their
purview in a biodefense memorandum. This information is then assessed
by the Biodefense Coordination Team and helps inform Joint Policy
Guidance for the president’s annual budget.

According to the Strategy, the Biodefense Steering Committee is
expected to reach beyond the federal government and engage with
nonfederal and nongovernmental entities, and to communicate
recommendations and feedback stemming from this outreach to agencies
in coordination with the annual budget cycle. NSPM-14 further states that
agencies are to coordinate and manage biodefense activities in support of
the broader biodefense enterprise, which includes federal, nonfederal,
nongovernmental, and international partners. This is consistent with our
past reporting that state and local resources are integral to supporting
national biodefense capabilities, such as biosurveillance, and should be
considered in federal planning efforts. 35




34As identified in its charter, Biodefense Coordination Team members include
representatives from: HHS, DOD, DHS, the Environmental Protection Agency, USDA, the
Department of Justice (including the Federal Bureau of Investigation), the Department of
Veterans Affairs, the Office of the Director of National Intelligence, the U.S. Agency for
International Development, and the Departments of State, Commerce, Energy, Treasury,
Interior, Transportation, and Labor.
35GAO, Biosurveillance: Nonfederal Capabilities Should Be Considered in Creating a
National Biosurveillance Strategy, GAO-12-55 (Washington, D.C.: Oct. 31, 2011).




Page 13                                                            GAO-21-513 Biodefense
The National                 Following Hurricane Katrina in 2005, the Post-Katrina Emergency
Preparedness Goal and        Management Reform Act of 2006 required FEMA to develop a national
                             preparedness system and assess preparedness capabilities to determine
Public Health Capabilities   the nation’s disaster preparedness. 36 The White House released
                             Presidential Policy Directive/PPD-8 on National Preparedness in March
                             2011. It directed the Secretary of Homeland Security to design a national
                             preparedness system to address the threats posing the greatest risk to
                             the security of the nation and issue various policy and planning
                             documents designed to strengthen national preparedness. Additionally, it
                             required the Secretary to develop a National Preparedness Goal that
                             identifies the core capabilities necessary to achieve preparedness. In
                             September 2011, DHS issued the National Preparedness Goal, which
                             identifies and defines 32 core capabilities for national preparedness
                             across five broad mission areas, which include but are not limited to
                             disaster and emergency response. 37 These capabilities apply to all
                             hazards and threats and are not incident specific. They form the
                             foundation for measuring overall national preparedness and assisting the
                             nation in allocating resources to fill identified preparedness gaps.
                             Examples of these capabilities include information sharing, community
                             resilience, logistics and supply chain management, mass care services,
                             and housing, among others. 38

                             Additionally, in 2011, CDC developed 15 public health-specific
                             capabilities as part of the Public Health Emergency Preparedness
                             program to advance the emergency preparedness and response capacity
                             of state and local public health systems. 39 CDC updated these capabilities
                             in 2018 to address emerging technologies and threats. 40 According to
                             CDC, these capabilities support the public health and medical
                             components of the 32 core capabilities specified in the National
                             Preparedness Goal. Examples of the public health capabilities include

                             366 U.S.C. §§ 744, 749.


                             37The five mission areas are: prevention, protection, mitigation, response, and recovery.


                             38The National Preparedness Goal identifies five functional areas or activities that
                             contribute to building each core capability: planning, organizing, equipping, training, and
                             exercising. This report focuses on two of these five areas: planning and exercising.
                             39The Public Health Emergency Preparedness program provides funding to build and
                             sustain public health preparedness and response capacity.
                             40U.S. Department of Health and Human Services, Centers for Disease Control and
                             Prevention, Public Health Emergency Preparedness and Response Capabilities: National
                             Standards for State, Local, Tribal, and Territorial Health (Atlanta, GA: October 2018).




                             Page 14                                                              GAO-21-513 Biodefense
                          medical countermeasure dispensing and administration, responder safety
                          and health, and mass care, among others. 41 For a complete list of
                          National Preparedness Goal and public health capabilities, see appendix
                          II.

Prior GAO Work on         Since 2009, we have identified broad, cross-cutting issues in leadership,
Biodefense and COVID-19   coordination, and collaboration that arise from fragmentation throughout
                          the complex interagency, intergovernmental, and intersectoral biodefense
                          enterprise. Our past work has identified a number of key challenges
                          related to the nation’s ability to detect and respond to biological incidents
                          that transcend what any one agency can address on its own. 42 Since
                          March 2011, we have reported that the biodefense enterprise would
                          benefit from institutionalized leadership with sufficient time, responsibility,
                          authority, and resources needed to promote efficiency and
                          accountability. 43 We further called for a national biodefense strategy and
                          focused leadership because addressing these issues is a difficult and
                          complex challenge that crosses mission areas, federal departments, and
                          sectors.

                          In February 2020, we reported that the National Biodefense Strategy and
                          its associated plans presented an opportunity to identify gaps and
                          consider enterprise-wide risk and resources for investment trade-off
                          decisions. We also reported on the early challenges agencies faced
                          implementing the National Biodefense Strategy. 44 Among other things, we
                          found that there was no documented methodology or guidance for how
                          data are to be analyzed to help the enterprise identify gaps and
                          opportunities to leverage resources, including no guidance on how
                          nonfederal capabilities are to be accounted for in the analysis.
                          Additionally, we found there were no clear, detailed processes, roles, and
                          responsibilities for joint decision-making, including how agencies will
                          identify opportunities to leverage resources or who will make and enforce
                          those decisions. We made recommendations on these and other

                          41Medical countermeasures include both pharmaceutical products, such as vaccines, and
                          non-pharmaceutical products, such as ventilators, diagnostic tests, and personal
                          protective equipment, that may be used to prevent, mitigate, or treat health effects from a
                          biological incident.
                          42GAO-19-635T.

                          43GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save Tax
                          Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar 1, 2011).
                          44GAO-20-273.




                          Page 15                                                             GAO-21-513 Biodefense
                       challenges to the Biodefense Coordination Team, which under NSPM-14
                       currently has responsibility for coordinating Strategy implementation. 45

                       Beginning in June 2020, we have issued a series of products in response
                       to CARES Act provisions requiring GAO to report on our ongoing
                       monitoring and oversight efforts related to the COVID-19 pandemic. 46 Our
                       reports examine key actions the federal government has taken to address
                       the COVID-19 pandemic and evolving lessons learned relevant to the
                       nation’s response to pandemics. Among other things, we reported on
                       medical supply chain shortages; the need for clarity on the federal
                       government’s plans for distributing and administering vaccines; and
                       inconsistencies on guidance for reopening schools. Overall, we identified
                       four evolving lessons learned: (1) establish clear goals and define roles
                       and responsibilities; (2) provide clear communication; (3) collect and
                       analyze adequate and reliable data to drive future decisions; and (4)
                       establish transparency and accountability mechanisms. We made 72
                       recommendations to federal agencies between June 2020 and March
                       2021 on these and other issues. We are monitoring ongoing efforts to
                       address these recommendations.

                       Key federal agencies developed a range of interagency response and
Agencies Developed     crisis action plans for biological incidents to provide strategic vision,
Interagency            describe operational coordination and incident command, and guide
                       tactical response decisions. Likewise, agencies conducted numerous
Response Plans and     interagency exercises since 2009 to help prepare for and respond to a
Conducted Biological
Incident Exercises
                       45HHS, which chairs the Biodefense Steering Committee, concurred with each of our
                       recommendations, and in April 2021 reported steps underway to address them. We
                       continue to monitor their efforts.
                       46See GAO, Opportunities to Improve Federal Response and Recovery Efforts,
                       GAO-20-625 (Washington, D.C.: June 25, 2020); GAO, COVID-19: Federal Efforts Could
                       be Strengthened by Timely and Concerted Actions, GAO-20-701 (Washington, D.C.: Sept.
                       21, 2020); GAO, COVID-19: Federal Efforts Accelerate Vaccine and Therapeutics
                       Development, But More Transparency Needed on Emergency Use Authorizations,
                       GAO-21-207 (Washington, D.C.: Nov. 17, 2020); GAO, COVID-19: Urgent Actions
                       Needed to Better Ensure an Effective Federal Response, GAO-21-191 (Washington, D.C.:
                       Nov. 30, 2020); GAO, COVID-19: Critical Vaccine Distribution, Supply Chain, Program
                       Integrity, and Other Challenges Require Focused Federal Attention, GAO-21-265
                       (Washington, D.C.: Jan. 28, 2021); and GAO, COVID-19: Sustained Federal Action Is
                       Crucial as Pandemic Enters Its Second Year, GAO-21-387 (Washington, D.C.: Mar. 31,
                       2021).




                       Page 16                                                         GAO-21-513 Biodefense
                             wide variety of biological incidents. 47 These planning and exercising
                             activities included participation from more than one federal agency and
                             leveraged frameworks used in all-hazards response, like the National
                             Response Framework. Interagency exercises also included nonfederal
                             participation.

Key federal agencies         To prepare for nationally significant biological incidents, key federal
developed interagency        agencies developed interagency response and crisis action plans
                             informed by national level strategies. These strategies and plans reflect a
response and crisis action
                             continuum along long-range strategic vision at the highest level, to
plans                        intermediate operational guidance (that describes how incident command
                             is to be coordinated and structured to ensure clear roles and
                             responsibilities for critical response functions), and finally, to tactical,
                             incident-specific guidance at the most immediate and concrete level.
                             DHS, DOD, HHS, and USDA officials identified national level strategy and
                             planning frameworks that create an architecture that informed the specific
                             biological incident response and crisis action plans the agencies
                             developed.

                             According to agency officials, high-level national security strategies—
                             specifically, the National Security Strategy and the Global Health Security
                             Strategy, provide some of the highest-level strategic visions that inform
                             their planning. Similarly, specific to nationally significant biological
                             incidents, the 2018 National Biodefense Strategy provides an overarching
                             strategic vision for how to achieve preparedness. Officials from two
                             agencies also noted that they relied on the National Strategy for
                             Pandemic Influenza to provide strategic and operational direction in the
                             initial COVID-19 response. 48

                             The National Security Strategy sets priorities to address a broad array of
                             threats to American interests, including biological threats. The Global
                             Health Security Strategy describes how the United States will enhance
                             the ability to prevent, detect, and respond to infectious disease threats
                             globally and domestically by working with other nations, international

                             47The scope of our work covers the ten year period from 2009 to March 2020 to reflect the
                             time between the last declared global pandemics.
                             48While the scope of our work covers 2009 to March 2020, two agencies identified the
                             2005 National Strategy for Pandemic Influenza as a key strategy document, maintaining
                             that despite its age, it has not been superseded and remains an important planning
                             document. Agencies also develop agency-specific response plans for biological incidents
                             that pertain to internal operations, such as ensuring the continuity of operations during a
                             biological incident. These plans are not reflected here, as our focus is interagency plans.




                             Page 17                                                             GAO-21-513 Biodefense
organizations, and nongovernmental stakeholders. The National
Biodefense Strategy is specific to preparing for and responding to
nationally significant biological threats regardless of their source; whereas
the National Strategy for Pandemic Influenza addresses national
coordination to prepare, detect, and respond to a pandemic.

Agencies engage in deliberate and incident-specific planning activities to
advance national preparedness, that are guided by a long range vision
and goals articulated in national level strategies. DHS developed a
layered planning architecture with its National Planning System, which
supports the National Preparedness Goal. This planning architecture
creates the strategic, operational, and tactical levels of planning and
planning integration. As described in DHS planning guidance, use of the
National Planning System promotes a unified approach to planning
through vertical and horizontal integration of plans across the whole
community, including federal and nonfederal entities. Because the
response to catastrophic incidents requires the capabilities of a wide
range of stakeholders, DHS planning guidance supports planning that
engages the whole community to developing response plans that
appropriately anticipate the necessary resources and authorities, and
identify the roles and responsibilities among partners for specific
incidents.

The biological incident response plans DHS, DOD, HHS and USDA
identified developing are nested within this planning architecture, as
described below. However, while agencies work together to develop
these plans, they may also interpret or use response plans in various
ways, meaning that along the continuum of strategy and plans, some
documents, such as the 2018 Pandemic Crisis Action Plan (PanCAP)
may provide both operational and tactical guidance, depending on the
context and the issues at hand. 49 We present the plans agencies
identified along a continuum below, recognizing that plans may straddle
more than one category (see figure 1).




49The PanCAP focuses on incidents generated by viral pathogens that have pandemic
potential.




Page 18                                                        GAO-21-513 Biodefense
Figure 1: Federal Interagency Biological Incident Planning Framework and Selected Response Plans, As Identified By
Agencies




                                        a
                                         Plans may straddle more than one category.
                                        b
                                         The suite of documents within the USDA Foreign Animal Disease Preparedness and Response Plan
                                        includes disease-specific response plans, strategies, and concept of operations.


                                        Strategic level. Strategic level planning allows stakeholders to identify a
                                        long-term vision and serves as a mechanism for unifying the efforts of
                                        multiple entities to support a comprehensive approach for addressing a
                                        particular issue or mission through agreed-upon governance, priorities,
                                        doctrine, and desired end-state. 50 At the strategic level, the National
                                        Response Framework—coordinated by DHS—is the nation’s highest level

                                        50DHS, National Planning System, February 2016.




                                        Page 19                                                              GAO-21-513 Biodefense
guidance for how to prepare for a response to any type of disaster,
regardless of the source of the hazard. The National Response
Framework provides foundational emergency management doctrine for
how the nation responds to all types of incidents. 51 This all-hazards
approach is designed to manage any type of disaster or emergency
response, regardless of scale, scope, and complexity, including biological
incidents. The National Response Framework sets the highest-level
planning framework and doctrine for how entities build, sustain, and
deliver response capabilities identified in the National Preparedness Goal.
The biological incident plans key agencies identified make specific
mention of their nexus to the National Response Framework.

Operational level. Planning efforts at the operational level may be
guided by the objectives or priorities in national-level strategies, like the
National Biodefense Strategy, and leverage guiding principles from
strategic level plans, but operational plans further articulate the roles,
responsibilities, and critical tasks among agencies that are needed for
response. 52 Biological incidents can affect the health of humans, animals,
plants, and the environment; occur internationally or domestically; and
may be intentional, accidental, or occur naturally, as in cases of infectious
disease spread. Given the variety of scenarios these events can prompt,
conducting deliberate planning at the operational level allows federal
agencies and their nonfederal stakeholders to familiarize themselves—for
example, through exercises for biological incidents—with which roles and
responsibilities and what authorities might be used in different scenarios.

Within the National Response Framework are the Federal Interagency
Operational Plans, which provide a federal concept of operations to
integrate and synchronize national-level capabilities, and cover
prevention, protection, mitigation, response, and recovery activities to
support all levels of government. 53 Specifically, the Response Federal
Interagency Operational Plan describes how the federal government
coordinates its efforts to save lives, protect property and the environment,

51National level strategies that inform further strategic planning also have goals and
objectives that cover international response efforts. However, we have focused attention
on the National Response Framework because this report focuses on domestic, whole-of-
nation response activities for biological incidents.
52DHS, National Planning System, February 2016.

53These plans also help federal departments and agencies develop and maintain
department-level operational plans.




Page 20                                                          GAO-21-513 Biodefense
stabilize communities, and meet basic human needs following an
emergency or disaster.

The response to certain types of threats or hazards may require unique
roles, responsibilities, resources, and concepts of operations that are not
addressed by the Response Federal Interagency Operational Plan. 54
Although the all-hazards approach of the National Response Framework
offers a foundation for the response and recovery function for biodefense,
the context in which federal agencies support response or recovery
functions is different for nationally significant biological events, and some
needs are wholly unique. Two specific incident annexes under the
National Response Framework identified by key agencies are designed to
address a variety of biological threats. They are the Biological Incident
Annex and National Food and Agriculture Incident Annex to the
Response and Recovery Federal Interagency Operational Plans. 55 These
annexes identify, among other things, the lead federal agency for various
types of incidents as well as funding and authorities to be leveraged for a
response.

Officials from DOD and DHS identified the Biological Incident Annex as
the primary interagency plan they use in response to biological events. As
part of the National Response Framework, these plans are designed to
be scalable, flexible, and adaptable to biological incidents, but are
fundamentally federal level planning documents, which focus on the
federal government’s ability to support nonfederal response efforts during
a biological incident.

The Biological Incident Annex and National Food and Agriculture Incident
Annex identify the lead federal agency for the response, depending on
the type of incident. For example, USDA is the lead federal agency for
incidents involving animal and plant agriculture, while HHS is the lead
federal agency for naturally occurring or intentional domestic incidents
affecting human health. According to the incident annexes, during




54DHS, National Response Framework, Fourth Edition, October 28, 2019.


55Other individualized incident annexes address the threats of power outage, cyber
incidents, oil/chemical incidents, nuclear/radiological incidents, terrorism, mass
evacuation, and impending space weather incidents.




Page 21                                                           GAO-21-513 Biodefense
complex incidents, FEMA may be called upon to provide supplemental
operational coordination support to the lead federal agency. 56

Finally, both incident annexes describe how the response to biological
incidents will remain dynamic throughout, as full information about the
incident may not be immediately available. For example, decisions during
a response will be based on incomplete information as the cause, origin,
transmission, and impact of the biological incident may take time to
uncover and may evolve as events progress. Both documents also
recognize that events could also have cascading effects, such as
economic consequences, or may generate public fear.

Tactical level. In a supporting role to the incident annexes and further
along the response planning continuum, DHS, DOD, HHS and USDA
identified an additional layer of interagency response planning that is
targeted to specific biological incidents. Tactical level planning may
include both pre-incident plans and real-time plans. Key agencies
identified the following as incident-specific response plans that represent
pre-incident tactical planning efforts: the 2018 PanCAP, the USDA
Foreign Animal Disease Preparedness and Response Plan, and the
USDA National Plant Health Emergency Management Framework. 57 The
2018 PanCAP operationalized the Biological Incident Annex to focus on
incidents generated by viral pathogens that have pandemic potential. The
USDA Foreign Animal Disease Preparedness and Response Plan further
operationalizes the National Food and Agriculture Incident Annex and
consists of a suite of response planning materials. 58 The USDA National
Plant Health Emergency Management Framework encompasses

56During the early COVID-19 response, FEMA provided more than supplemental support.
The FEMA Administrator was part of the Unified Coordination Group, the entity which
provided incident management of the entire response effort. FEMA, specifically, provided
logistics management support to address key supply chain shortages. FEMA, as of
January 21, 2021, has also been assisting vaccine distribution efforts in alignment with the
new administration’s response strategy.
57USDA also identified an interagency plan issued in 2019 on the proper handling and
disposal of potentially highly infectious waste. Agencies developed this plan in response to
challenges United States health care and waste management facilities experienced in
2014-2015 as a result of treating patients with Ebola virus disease. Ebola after-action
reports developed by both the CDC and the National Security Council identified problems
with unclear guidelines, processes, and communication plans with regard to hazardous
waste management.
58These materials include manuals on information management, standard operating
procedures, roles and coordination among federal and nonfederal agencies and private
industry, as well as disease-specific response plans and strategies that address activities
related to diagnosing, treating, controlling, and eradicating the specific disease.




Page 22                                                             GAO-21-513 Biodefense
                          guidance on preventing, preparing, responding, and recovering from
                          invasive pest introductions.

                          Officials from DHS, DOD, and HHS familiar with the planning processes
                          of their agencies, as well as those with expertise in preparing for
                          biological incidents, said that this type of pre-incident tactical planning
                          that addresses specific types of biological incidents is beneficial, in part,
                          because those plans immediately identify the key response partners
                          needed to address the crisis. According to the National Planning System,
                          tactical plans often outline the detailed actions necessary to accomplish
                          goals identified in an operational plan, such as the types of personnel or
                          equipment needed. In the biological incident context, this could mean
                          identifying needs for alternative care facilities or knowing how and when
                          to engage subject matter experts. For example, USDA personnel may be
                          needed during a response to determine which animal products or live
                          animals have the potential to introduce or spread a pandemic virus.

                          DHS and DOD officials said it is still important to recognize that each
                          biological incident will have unique characteristics, so even these pre-
                          incident tactical level plans may need to be further adapted to real-time
                          tactical plans during an event. However, these officials also said that
                          having pre-incident plans at this level allows also for opportunities to
                          exercise these plans in order to bring together all the key parties on a
                          more regular basis to discuss plan implementation and identify gaps.

Plans Have Evolved to     Federal agencies with responsibility for the range of plans in the National
Reflect Lessons Learned   Planning System architecture have revised and adapted them over the
                          years to reflect lessons learned from exercises and real-world events. For
and New Threats
                          example, the 2017 revision of the Biological Incident Annex incorporated
                          lessons learned from the H1N1 2009 pandemic, Ebola Virus Disease of
                          2013-2014, and Zika Virus Disease in 2015-2017. DHS officials stated
                          that the revision also drew from lessons learned from exercises focused
                          on aerosolized Anthrax attacks on large cities and the Severe Acute
                          Respiratory Syndrome (SARS) outbreak. According to DHS officials, the
                          Biological Incident Annex is currently undergoing another review and
                          revision. Officials stated this revision will incorporate lessons learned from
                          the ongoing COVID-19 pandemic, as well as lessons learned from the
                          2019 Crimson Contagion exercise, which exercised the planning




                          Page 23                                                  GAO-21-513 Biodefense
assumptions in both the Biological Incident Annex and the 2018
PanCAP. 59

According to FEMA officials and other federal agency officials we
interviewed, FEMA determines when to review and revise the plans that
fall under the National Response Framework, such as the Biological
Incident Annex. DHS officials noted that when planning any revision to
planning documents, they consider the following elements: (1) changes in
guidance from DHS leadership, (2) any new information that informs the
facts or assumptions underpinning planning efforts, and (3) past lessons
learned. Officials we spoke with from all four agencies described how
FEMA engages other federal agencies in its planning cycle, and officials
from the DHS Countering Weapons of Mass Destruction Office and HHS
said they are involved in the current revision of the Biological Incident
Annex. USDA officials also said that FEMA finalized updates to the
National Food and Agriculture Incident Annex—to which USDA
contributed—in 2020, and they provide input on other planning
documents when requested.

FEMA officials said they typically review the planning annexes on a two or
three year schedule, but not all are reviewed on that schedule. They said
that if an annex or plan has not been revised, that does not indicate a lack
of planning. For example, officials noted that in between the 2008 and
2017 versions of the Biological Incident Annex, agencies worked together
to develop other biological incident planning documents. Examples of
these plans include the 2013 PanCAP and interagency plans to address
the threat from Ebola, H7N9 avian influenza, and Middle-East Respiratory
Syndrome Coronavirus. 60




59The Crimson Contagion 2019 Functional Exercise, conducted August 13–16, 2019,
exercised the nation’s ability to respond to a large-scale outbreak of a novel avian
influenza virus (H7N9) strain, which quickly spreads via human to-human transmission
around the world and across the continental United States with high rates of morbidity and
mortality. The after-action report for the exercise identified a number of areas for
improvement related to planning and other response functions, including that the
organization of the federal government response when HHS is the lead federal agency
was not sufficiently outlined in the Biological Incident Annex or the 2018 PanCAP. As we
reported in June 2020, HHS officials told us they had not been able to address the
Crimson Contagion findings because they were busy responding to the COVID-19
pandemic. FEMA officials similarly told us that they were not able to implement solutions
before the pandemic response began. See GAO-20-625.
60According to FEMA officials, the 2013 PanCAP was revised in 2018.




Page 24                                                           GAO-21-513 Biodefense
In the early stages of the COVID-19 pandemic, agencies adapted the
2018 PanCAP, thereby creating a real-time tactical plan to address the
needs of the whole-of-nation response. The PanCAP Adapted U.S.
Government COVID-19 Response Plan (PanCAP Adapted), issued
March 13, 2020, was created to outline in real time the key federal
decisions, federal actions, and interagency coordination structures that
may be used during the COVID-19 pandemic. It was designed to
coordinate activities to limit the spread of COVID-19; to mitigate the effect
of illness, suffering, and death; and to sustain critical infrastructure and
key resources in the United States. Modifications made to adapt the 2018
PanCAP to the PanCAP Adapted for the COVID-19 response included:
(1) creating a White House Coronavirus Task Force to coordinate the
whole-of-government approach, (2) updating facts, assumptions, and
critical considerations unique to severe acute respiratory syndrome
coronavirus 2 (SARS-CoV-2, the virus that causes COVID-19), as it was
understood at the time, (3) expanding coordination structures for each
phase of the response, including options for HHS lead and FEMA lead
with the Unified Coordination Group, and (4) creating an Operations
Annex with detailed implementation guidance using a task force
construct. 61 According to DOD officials, response actions during the
COVID-19 pandemic continue to evolve to adapt to changing needs, but
the PanCAP Adapted has not been modified to reflect every evolution of
this dynamic event. 62

Officials said that they plan to revise the 2018 PanCAP in 2021 to
highlight existing COVID-19 response structures that have been

61The FEMA Administrator, the Assistant Secretary for Preparedness and Response at
HHS, and a CDC representative jointly lead the Unified Coordination Group for COVID-19,
which coordinates federal response and recovery operations. As we reported in June
2020, to address the multiple dimensions of the early pandemic response, eight
operational task forces brought together federal departments and agencies with the
relevant expertise, authorities, and capabilities necessary to address unmet needs.
Through these task forces, the National Response Coordination Center which is operated
out of FEMA and is the hub for coordinating actions and resources across federal
agencies, can use existing authorities, processes, resources, and funding for each of the
agencies that comprise each Emergency Support Function under the National Response
Framework to meet the needs of the response as they arise. See GAO-20-625. The
Unified Coordination Group is a key coordination structure identified in the Incident
Annexes mentioned above.
62DOD officials further stated that even the 2020 PanCAP Adapted, when it was released
in March 2020, reflected a single moment and understanding of the conditions at the time
and that agencies have continued to learn and adapt to the pandemic conditions to
execute response actions.




Page 25                                                           GAO-21-513 Biodefense
                       successful and shift the focus from short-term response to planning for
                       emerging infectious diseases with pandemic potential. Officials from all
                       four agencies described ongoing efforts to collect lessons learned from
                       the COVID-19 response which will be used when updating plans, such as
                       the PanCAP.

                       In addition to interagency planning efforts, as the pandemic continues to
                       unfold and changes in leadership have occurred, additional changes to
                       manage the COVID-19 response continue to be made. For example, in
                       January 2021, the new administration released a new National Strategy
                       for the COVID-19 Response and Pandemic Preparedness. This strategy
                       includes goals for addressing the pandemic and is intended to improve
                       the effectiveness of the response and improve public trust and
                       accountability. On January 20, 2021, the President issued an Executive
                       Order to reorganize the structure of the COVID-19 response. 63 DHS
                       officials said they take these types of policy changes into consideration
                       when updating response planning documents. However, because
                       updates to the BIA and PanCAP are not yet complete, it is not clear
                       whether or how these changes will be reflected.

Agencies Conducted     Key federal agencies have conducted numerous interagency exercises to
Numerous Interagency   prepare for biological incidents. Specifically, we identified 74 interagency
                       biological incident exercises conducted from calendar years 2009 through
Biological Incident    2019. 64 We defined “interagency” to mean participation from one of the
Exercises              federal departments in our scope (DHS, DOD, HHS, or USDA) and at
                       least one other federal department or agency. The exercises we identified
                       ranged from smaller tabletop exercises with a limited number of
                       participants exercising a biological incident scenario in one geographic
                       area, to full-scale functional exercises involving multiple federal and



                       63The Executive Order “established within the Executive Office of the President the
                       position of Coordinator of the COVID-19 Response and Counselor to the President
                       (COVID-19 Response Coordinator) and the position of Deputy Coordinator of the COVID-
                       19 Response. The COVID-19 Response Coordinator shall report directly to the President;
                       advise and assist the President and executive departments and agencies (agencies) in
                       responding to the COVID-19 pandemic; coordinate all elements of the COVID-19
                       response; and perform such duties as the President may otherwise direct.” Exec. Order
                       No. 13,987, 86 Fed. Reg. 7019 (Jan. 25, 2021).
                       64We identified these exercises through interviews with DHS, DOD, HHS, and USDA
                       officials and documentation provided by each agency, as well as by reviewing
                       documentation from current and prior GAO work.




                       Page 26                                                         GAO-21-513 Biodefense
nonfederal partners exercising widespread scenarios. 65 As shown in
figure 2, at least three exercises were conducted each calendar year
during this time period, and 2010 and 2014 saw the highest number, at 12
exercises each.

Figure 2: Number of Interagency Biological Incident Exercises Conducted, Calendar
Years 2009 through 2019




Note: We identified 74 biological incident exercises in which the Department of Homeland Security,
Defense, Health and Human Services, or Agriculture and at least one other federal department or
agency participated. The total includes 21 individual exercises that were conducted across five
separate exercise series. Exercises conducted as part of the same exercise series typically use the
same threat scenario. Specifically, the total includes three exercises conducted during the 2019
Crimson Contagion series, four conducted during the 2013–2014 Pandemic Accord series, 10
conducted during the 2009–2010 Anthrax Response Exercise Series, two conducted during Lightning
Rescue 2012, and two conducted during the 2015–2016 Palo Duro II series).


Of the 74 exercises our analysis identified, agencies provided information
on the specific threat scenario exercised for 71. From calendar years
2009 through 2019, agencies exercised a range of naturally occurring and
intentional threat scenarios, including threats primarily affecting human

65For example, a 2013 tabletop exercise we reviewed involved participants from two
federal agencies and one state; while a 2019 exercise included participants from 18
federal agencies and 12 states. We did not evaluate the design of the exercises we
identified.




Page 27                                                                  GAO-21-513 Biodefense
health, such as pandemic influenza and anthrax attacks, as well as
threats primarily affecting animal health, such as foot-and-mouth
disease. 66 As shown in figure 3, 22 of the 71 exercises included a
naturally occurring influenza threat scenario; 24 included an intentional
scenario; 13 included a naturally occurring non-influenza scenario; and 12
included threat scenarios affecting animal or plant health.

Figure 3: Number of Interagency Biological Incident Exercises Conducted from
Calendar Years 2009 through 2019, by Threat Scenario Category




Note: We identified 74 interagency biological incident exercises and agencies provided information on
the specific threat scenario exercised for 71 of the 74 exercises.




66Foot-and-mouth disease is a highly contagious viral disease that causes painful lesions
on the hooves and mouths of some livestock, making it difficult for them to stand or eat.
The disease generally does not infect humans and is not considered a public health or
food safety threat. However, it poses a significant economic threat to U.S. interests.




Page 28                                                                   GAO-21-513 Biodefense
For 42 of the 74 exercises, we were able to determine additional
descriptive information, such as participant information. 67 As shown in
figure 4, more than half of these 42 exercises included nonfederal
government participants, such as state, local, and tribal governments.
Nonfederal government participation in exercises is important because
the capabilities and resources needed to respond to a nationally
significant biological incident exist at all levels and should be taken into
account when assessing capability and preparedness gaps. 68 Similarly,
more than half of the 42 exercises also included nongovernmental
participants, such as hospitals, universities, and professional
associations. According to FEMA officials, the ongoing COVID-19
response has demonstrated the necessity of effectively integrating the
private sector into planning and response operations.




67We obtained detailed descriptive information on 42 of the 74 exercises our analysis
identified. Specifically, we obtained after-action reports or other documentation on 11 of
22 natural influenza, four of 13 natural non-influenza, 18 of 24 intentional human, and nine
of 12 animal/plant exercises. Agencies provided several reasons for the lack of an
exercise after-action report, including: (1) the agency did not develop a report; (2) no after-
action report records were found; and (3) the agency was not the release authority for the
after-action report and was unable to identify such authority.
68We have previously reported on the challenges in assessing state and local
preparedness for emergencies and natural disasters. See: GAO, Federal Emergency
Management Agency: Progress and Continuing Challenges in National Preparedness
Efforts, GAO-16-560T (Washington, D.C.: Apr. 12, 2016); GAO, National Preparedness:
FEMA Has Taken Steps to Strengthen Grant Management, But Challenges Remain in
Assessing Capabilities; GAO-18-512T (Washington, D.C.: Apr. 23, 2018); GAO, FEMA:
Strengthening Regional Coordination Could Enhance Preparedness Efforts, GAO-16-38
(Washington, D.C.: Feb. 4, 2016).




Page 29                                                               GAO-21-513 Biodefense
Figure 4: Participants in Interagency Biological Incident Exercises Conducted from Calendar Years 2009 through 2019, by
Threat Scenario Category




                                         Note: This graph represents participation across the interagency biological incident exercises we
                                         identified from 2009 through 2019 for which we obtained information on both the specific threat
                                         scenario and participants (42 of 74 total exercises identified). The dashed line and number above
                                         each threat scenario category represents the total number of exercises in that category for which we
                                         obtained detailed participant information. The bars represent the number of exercises each
                                         stakeholder group participated in out of the total for that category.


                                         Our analysis of after-action reports for selected interagency biological
Interagency                              incident exercises and real-world incidents, as well as findings from the
Exercises and Real-                      COVID-19 response, demonstrates that the biodefense enterprise has
                                         gaps in its capabilities-based approach to response planning. We
World Incidents Show                     identified common long-standing biodefense challenges in coordinating
Opportunities to                         response capabilities, managing information, and in overall planning and
                                         exercise efforts. Existing gaps in preparing for nationally significant
Better Implement the                     biological events limit the ability to implement the preparedness and
National Biodefense                      response goals of the National Biodefense Strategy. Specifically, we
                                         found the biodefense enterprise lacked elements necessary for preparing
Strategy                                 for nationally significant biological incidents, including:



                                         Page 30                                                                    GAO-21-513 Biodefense
                           •   a set of defined capabilities that account for the unique elements
                               specific to responding to nationally significant biological incidents;
                           •   a process at the interagency level for agencies to assess and
                               communicate priorities for exercising capabilities and consistently
                               reporting on those capabilities in after-action reviews; and
                           •   routine monitoring at the interagency level of exercises and real-world
                               incidents in order to evaluate lessons learned across the government,
                               identify patterns and possible root causes for systemic challenges,
                               and make recommendations to address these challenges.

Exercises and Real-World   Federal after-action reports from exercises and real-world biological
Incidents, Including       incidents, as well as challenges identified in the COVID-19 response,
                           highlight a number of common, long-standing challenges related to
COVID-19, Reveal
                           interagency biological incident preparedness and response efforts
Common, Long-standing      needed to achieve National Biodefense Strategy goals and objectives. 69
Biodefense Challenges      In analyzing our judgmental sample of 19 after-action reports developed
                           from calendar years 2009 through 2019, 70 we determined that the most
                           common interagency challenges, or areas for improvement, identified in
                           these reports correspond to three specific response and preparedness
                           objectives in the National Biodefense Strategy: (1) Coordinate response
                           operations and resources; (2) Manage information; and (3) Develop,
                           exercise, and update plans and capabilities (see table 2 below). These
                           areas for improvement spanned after-action reports across the 10-year
                           period we reviewed.




                           69We determined that a finding had interagency implications if the gap or challenge, or
                           strength, identified applied to activities undertaken by two or more federal agencies.
                           70Specifically, we selected a non-generalizable sample of exercise after-action reports and
                           stratified the sample by the common threat scenario categories shown in figure 3.




                           Page 31                                                             GAO-21-513 Biodefense
Table 2: Number of After-Action Report Areas for Improvement with Interagency Implications, by Most Common National
Biodefense Strategy Objectives

National Biodefense Strategy objective                                                                                                 Number of areas for improvement
Coordinate response operations and resources: Conduct federal response                                                                                                        54
operations in coordination with nonfederal actors to contain, control, and rapidly
mitigate the impacts of biothreats or bioincidents.
Manage information: Compile and share biothreat and bioincident information to                                                                                                52
enable decision-making and response operations across all levels of government and
with nongovernmental, private sector, and international entities.
Develop, exercise, and update plans and capabilities: Develop, exercise, and                                                                                                  22
update prevention, response, and recovery plans and capabilities.
Othera                                                                                                                                                                        27
Total                                                                                                                                                                         155
Source: GAO analysis of documentation from the Departments of Homeland Security (DHS), Defense (DOD), Health and Human Services (HHS), and Agriculture (USDA). | GAO-21-513

                                                              Note: This table includes findings from a stratified, non-generalizable, judgmental sample of 19
                                                              exercise and real-world event after-action reports developed by DHS, DOD, HHS, and USDA from
                                                              calendar years 2009 through 2019. We determined that a finding had interagency implications if the
                                                              gap or challenge, or strength, identified applied to activities undertaken by two or more federal
                                                              agencies.
                                                              a
                                                               Other areas for improvement include providing effective public messaging and working with
                                                              international governments to improve global preparedness, among others.


                                                              After-action reports we reviewed often identified strengths as well as
                                                              areas for improvement. Specifically, we identified a total of 70 strengths
                                                              with interagency implications in our sample. According to FEMA’s
                                                              continuous improvement guidance, in addition to sharing areas for
                                                              improvement, observations of strengths should also be shared on a
                                                              regular basis to promote successes and innovations across the
                                                              community.

                                                              In addition to areas for improvement in the after-action reports we
                                                              reviewed, we also identified challenges in the initial COVID-19 response.
                                                              Specifically, agency officials, health care associations, health care
                                                              experts, and selected state officials we interviewed identified a number of
                                                              similar challenges in the initial COVID-19 response and general gaps in
                                                              preparedness for biological incidents. In our prior 2020 and 2021 CARES
                                                              Act reports, we noted that federal agencies have demonstrated
                                                              extraordinary dedication and commitment in responding to the
                                                              unprecedented COVID-19 pandemic. We reported on extensive and
                                                              evolving efforts to respond to the pandemic, including through managing
                                                              the medical supply chain, increasing testing capacity; developing,
                                                              manufacturing, and distributing COVID-19 vaccines and therapeutics; and
                                                              collecting data on racial and ethnic disparities as they relate to COVID-19.
                                                              However, we also identified response challenges in these and other


                                                              Page 32                                                                                     GAO-21-513 Biodefense
areas. These COVID-19-specific challenges and gaps primarily
correspond to the same three response and preparedness objectives in
the National Biodefense Strategy that our after-action report analysis
identified as the most frequently cited areas for improvement. 71 The
following are examples of challenges identified in the after-action reports
we reviewed and in the COVID-19 response.

    Coordinate response operations and resources. Areas for
    improvement and challenges identified in this category included
    providing overall coordination among response partners, defining
    roles and responsibilities, and pursuing efforts to secure and distribute
    supplies, specifically medical countermeasures such as personal
    protective equipment and testing supplies. For example, CDC’s after-
    action report on the 2014 Ebola response found that CDC and the
    State Department experienced challenges coordinating responder
    health and safety procedures. The 2019 HHS Crimson Contagion
    after-action report found that federal partners lacked clarity on
    interagency roles and responsibilities during a pandemic, which led to
    confusion about who was leading various exercise response activities.
    Health care associations as well as officials from five of six FEMA
    regions and eight of 10 states we interviewed cited initial COVID-19
    response challenges related to coordination between emergency
    management and public health functions at both the federal and
    nonfederal level, particularly with regard to supplies. 72 In June and
    September 2020, we reported on challenges with the overall
    distribution, acquisition, and adequacy of supplies during the initial
    COVID-19 response, and we have continued to report on ongoing




71We did not review the status of any corrective actions associated with each of the
individual interagency findings or challenges identified. As such, agencies may have taken
action to address findings in the individual examples we provide below. Rather, we asked
agencies about overall actions taken to address the broad categories of challenges
identified.
72HHS regional officials also participated in two of the six interviews we conducted with
FEMA regions, including those that identified challenges with emergency management
and public health coordination. HHS and FEMA each operate 10 regional offices
nationwide.




Page 33                                                             GAO-21-513 Biodefense
    challenges as well as improvements in this area as the response
    evolves. 73
    Manage information. After-action reports identified both federal-to-
    nonfederal and nonfederal-to-federal information flow as challenges in
    this category. For example, a DHS report on a 2010 anthrax-attack
    exercise noted that state and local jurisdictions needed to be better
    aware of information requirements from each federal agency.
    Similarly, the 2019 HHS Crimson Contagion after-action report found
    that HHS’ regional staff lacked clear guidance on the distribution of
    information to state and local partners, and that states lacked clarity
    on which channels they should use to request information from and
    report information to federal partners throughout the response.
    Health care associations and experts and officials from five of six
    FEMA regions and all 10 states in our sample also identified
    information management challenges in the COVID-19 response.
    These challenges included inconsistent guidance from the federal
    government, lack of transparency regarding supplies available in the
    Strategic National Stockpile, 74 and data collection challenges.
    Additionally, in January 2021, we reported that the federal
    government did not have a process to help systematically define and
    ensure the collection of standardized data across the relevant federal
    agencies and related stakeholders to help respond to COVID-19. As a
    result, we reported that information collected and reported by states




73GAO-20-625 and GAO-20-701. Challenges related to supplies have been due in part to
a supply chain that was overwhelmed by the demands of the global pandemic. We
reported on numerous efforts by federal agencies to mitigate supply chain shortages and
also made recommendations related to remaining challenges, including that HHS and
FEMA clearly document roles and responsibilities for supply chain management functions
and develop and communicate plans to stakeholders for addressing remaining supply
chain shortages. HHS disagreed with these recommendations, noting, among other
things, the work that the department had done to manage the medical supply chain and
increase supply availability. We acknowledge those efforts, but continue to maintain that
our recommendations are warranted. In March 2021, we reported that, to address more
immediate supply needs, the President has called for action that is consistent with our
September 2020 recommendation that HHS—in coordination with FEMA—develop and
communicate plans to stakeholders outlining specific federal government actions that will
be taken to help mitigate supply gaps. See GAO-21-387.
74The Strategic National Stockpile is a federal stockpile of vaccines, pharmaceuticals, and
medical supplies and devices designed to be deployed to support the response to a public
health emergency.




Page 34                                                            GAO-21-513 Biodefense
    and other entities to the federal government is often incomplete and
    inconsistent. 75
    Develop, exercise, and update plans and capabilities.
    Preparedness related findings from after-action reports and the
    COVID-19 response include the need to improve capabilities, conduct
    exercises with a range of relevant participants, and improve overall
    planning. For example, a DOD report on a 2015 anthrax-attack
    exercise found a lack of surge capacity government-wide to respond
    to a biological attack. The report also identified the need for exercises
    to be conducted with a full range of federal, state, local, and regional
    partners to create a better understanding of response capabilities.
    Health care associations and experts, and officials from one FEMA
    region and three states we interviewed noted that there was a lack of
    a national plan or strategy for key COVID-19 response elements, such
    as a testing strategy or a plan for acquiring personal protective
    equipment, which exacerbated response problems. Additionally, as
    we reported in September 2020, representatives of state, local, and
    territorial health officials and health care providers we interviewed
    emphasized the need for the federal government to develop and
    share plans for the distribution and administration of COVID-19
    vaccines. 76 DHS officials stated that the pandemic exposed the need
    for more active engagement with the private sector in the face of the
    unique and complex challenges posed, particularly with regard to
    medical supplies.
In addition, our analysis of the COVID-19 response identified challenges
in two other National Biodefense Strategy categories that appeared less
75GAO-21-265. We recommended that HHS immediately establish an expert committee or
use an existing one to systematically review and inform the alignment of ongoing data
collection and reporting standards for key health indicators. HHS partially agreed with our
recommendation, noting that it would not be able to take action immediately because of
resource constraints and the ongoing response to the pandemic.
76GAO-20-701. We recommended that HHS, with the support of DOD, establish a time
frame for documenting and sharing a national plan for distributing and administering
COVID-19 vaccine, and among other things, outline an approach for how efforts would be
coordinated across federal agencies and nonfederal entities. DOD partially concurred,
while HHS neither agreed nor disagreed with our recommendation. In November 2020, we
reported that HHS and DOD had released initial planning documents. We are continuing
to monitor federal efforts related to vaccine implementation. In January 2021, we also
recommended that HHS develop a comprehensive COVID-19 national testing strategy.
See GAO-21-265. HHS partially agreed with our recommendation, but expressed concern
that developing a strategy would be overly burdensome during the pandemic. We maintain
that a comprehensive and public national strategy is an important and worthwhile
investment and can be done efficiently and flexibly, without imposing unnecessary burden.




Page 35                                                             GAO-21-513 Biodefense
frequently in the after-action report findings we reviewed: (1) Provide
effective public messaging, and (2) Ensure a strong public and veterinary
health infrastructure.

    Provide effective public messaging. We identified providing clear,
    consistent communication as an evolving lesson learned in our June
    and September 2020 reports. 77 Specifically, we reported that clear
    and consistent communication among all levels of government, with
    health care providers, and to the public is key during a nationwide
    emergency. Uncoordinated communication between the federal
    government and state and local jurisdictions, and with providers and
    the general public can contribute to confusion and frustration. We
    further reported on examples of inconsistent and conflicting
    information from the White House and federal public health officials;
    and noted that two public health experts we interviewed for the
    September 2020 report stated that confusing and conflicting
    communication from the federal government hindered response and
    recovery efforts. Officials from one state noted that public messaging
    from the federal government on supplies sent to states did not match
    what they actually received and caused confusion and frustration with
    regard to expectations and planning. Additionally, in November 2020,
    we reported that frequent changes in CDC COVID-19 testing
    guidelines, without transparent scientific rationale, raised the risk of
    creating confusion and eroding trust in federal partners. 78
    Ensure a strong public and veterinary health infrastructure. 79
    DHS officials and health care associations we interviewed noted that
    the lack of investments in public health infrastructure exacerbated
    challenges in the COVID-19 response. For example, DHS officials
    stated that public health investments have atrophied and that declines
    in resources and grants combined with hospitals and emergency

77GAO-20-625, GAO-20-701.


78GAO-21-191.


79The National Biodefense Strategy refers to both public and veterinary health in this
category. While interviews related to the COVID-19 response did not discuss veterinary
health, we have previously reported on challenges in this area. For example, in March
2019, we reported on challenges USDA might face in detecting and responding to an
outbreak of foot-and-mouth disease and made recommendations aimed at strengthening
preparedness activities, including prioritizing corrective actions from exercises. USDA
agreed with our recommendations. See GAO, Foot-and-Mouth Disease: USDA’s Efforts to
Prepare for a Potential Outbreak Could Be Strengthened, GAO-19-103 (Washington,
D.C.: Mar. 12, 2019).




Page 36                                                         GAO-21-513 Biodefense
    rooms closing in the years leading up to COVID-19 had negative
    national impacts on preparedness and response. As a result, officials
    noted that limited capabilities at the nonfederal level necessitated a
    more prominent federal response. In May 2018, we reported that,
    according to HHS officials, grant awards funded by annual
    appropriations are intended to establish and strengthen emergency
    preparedness and capacity building, but may not fully support the
    need for surge capacity that states and other jurisdictions require in
    order to respond to an infectious disease threat. 80 We further reported
    that HHS officials and nonfederal stakeholders noted that a funding
    mechanism to fund rapid response activities when additional support
    is needed would be beneficial and could help address timing
    challenges. 81
When asked what steps agencies had taken to address the long-standing
challenges identified in after-action reports, officials from DHS and USDA
pointed to the development of a number of strategic and operational
plans—such as the 2017 Biological Incident Annex, 2018 National
Biodefense Strategy, and 2018 PanCAP—that were designed to improve
interagency efforts. DHS officials cited FEMA and HHS co-locating staff at
the National Response Coordination Center during the COVID-19
response as an example of improved coordination. In that regard, officials
said there has been steady improvement in preparedness since the 2009
H1N1 outbreak because of the results of lessons learned from exercises
and real-world incidents.

Nevertheless, challenges identified in prior exercises and incidents
persisted during the COVID-19 response, and selected federal and
nonfederal partners we interviewed felt underprepared to respond to the
COVID-19 pandemic. As we discuss below, the challenges revealed
during the COVID-19 response and our analysis of after-action report
findings with interagency implications highlight opportunities to better
achieve the National Biodefense Strategy’s objectives across federal
agencies and with nonfederal entities they depend on for successful
response.




80GAO, Infectious Disease Threats: Funding and Performance of Key Preparedness and
Capacity-Building Programs, GAO-18-362 (Washington, D.C.: May 24, 2018).
81We did not make recommendations as part of this work, but for certain HHS grant
programs, this type of mechanism has been developed and was used to award funding for
the COVID-19 pandemic.




Page 37                                                        GAO-21-513 Biodefense
Federal Agencies Have        Agencies responsible for implementing the National Biodefense Strategy
Not Defined the Set of       have not defined the set of capabilities that account for the unique
                             elements specific to responding to nationally significant biological
Capabilities Needed to
                             incidents. The COVID-19 response illustrated that nationally significant
Drive Preparedness           biological incidents require unique capabilities and application of existing
Efforts under the Strategy   capabilities in novel and complex contexts. For example, FEMA officials
                             said that the COVID-19 response presented unique challenges, because
                             the pandemic affected the entire country simultaneously and posed
                             challenges for acquiring life-saving supplies in the face of global supply
                             chain shortages. Officials from DHS’s Countering Weapons of Mass
                             Destruction Office further stated that the pandemic revealed limitations of
                             a traditional emergency management response when an event is not
                             limited by time and geography—such as a wildfire or hurricane. Figure 5
                             below shows a supply shipment coordinated by the federal response
                             during the COVID-19 pandemic.

                             Figure 5: Supply Shipment during the COVID-19 Pandemic




                             Federal agencies have defined capabilities intended to address a wide
                             range of hazards, but these capabilities are not defined in a way that
                             provides sufficient context for nationally significant biological incidents. As
                             discussed in the background of this report, the federal government has


                             Page 38                                                   GAO-21-513 Biodefense
defined 32 all-hazards preparedness capabilities and 15 compatible
capabilities specific to public health preparedness. 82 However, the current
sets of capabilities, as defined and implemented, do not provide federal
and nonfederal entities with sufficient context and detail on how to apply
them for the unique circumstances associated with nationally significant
biological incidents. For example, standard capability components, such
as mutual aid agreements, that may help nonfederal entities address
supply shortages during a response to a routine event, are likely not
practical to employ during a catastrophic incident affecting the entire
nation. Throughout the COVID-19 pandemic, nonfederal entities
simultaneously faced the same resource shortages in terms of supplies
and, in many cases, care facility capacity.

FEMA’s initial review of the COVID-19 response demonstrated that
capabilities needed for nationally significant biological incidents were
underdeveloped. In its January 2021 assessment of its response activities
during the initial phase of the pandemic, FEMA recognized that its ability
to anticipate nonfederal requirements during the pandemic was affected
by an insufficient understanding of projected consequences and
capabilities of nonfederal partners. 83 The report further states that existing
federal preparedness efforts did not adequately anticipate the magnitude
of the national response to the COVID-19 pandemic. FEMA’s assessment
report provided an example of one of their efforts to assess nonfederal
preparedness efforts at a very high level—the Stakeholder Preparedness
Report, which relies on input from nonfederal stakeholders’ Threat and




82As discussed above, the 32 core capabilities apply across five broad mission areas:
prevention, protection, mitigation, response, and recovery. Some core capabilities fall
within a single mission area, while others apply to multiple or all mission areas. For
example, 11 of the 32 capabilities apply only to the response mission area, while an
additional four capabilities apply to both response and one or more other mission area.
See appendix II for a list of all 32 core capabilities and their corresponding mission
area(s). These capabilities are a critical and well-established framework to drive overall
national preparedness efforts that support the National Preparedness Goal and CDC’s
efforts to build public health capabilities at the nonfederal level. For example, FEMA and
CDC have used the sets of core capabilities as a key performance management tool in
measuring emergency preparedness and public health emergency preparedness and
response.
83U.S. Department of Homeland Security, Federal Emergency Management Agency,
Pandemic Response to Coronavirus Disease 2019 (COVID-19): Initial Assessment
Report, (Washington, D.C.: January 2021).




Page 39                                                             GAO-21-513 Biodefense
Hazard Identification and Risk Assessment. 84 According to the report, in
2019, only 25 states’ risk assessments included a pandemic among the
threats to which their communities are the most vulnerable. Additionally,
states and urban areas indicated that in a worst-case scenario, medical
care and life-sustaining goods delivery were two of the capabilities that
were furthest from the desired goal. In its assessment, FEMA also
recognized the important role of CDC’s preparedness efforts to help build
and strengthen nonfederal public health capabilities, but they also
described the need to better integrate preparedness efforts going forward,
based on the whole-of-nation response to COVID-19.

Additionally, in April 2021, we reported on challenges related to
communication and coordination capabilities that HHS faced in the
context of repatriation activities during the COVID-19 response. 85
Specifically we reported that HHS was not prepared for a repatriation
event in response to a pandemic, because the department and
component agencies had not exercised that scenario, including during the
2019 Crimson Contagion exercise, which was a multi-state, whole-of-
government exercise based on the spread of a novel influenza virus
starting in China. 86 For example, among other things, we found a lack of
clarity as to which agency was in charge when the first repatriation flight
from Wuhan, China, arrived at the quarantine facility, which caused
confusion among the HHS component agencies. The challenges HHS
experienced repatriating U.S. citizens from abroad have the potential to
cut across multiple National Preparedness Goal and CDC capabilities,
such as operational coordination, communication, or provision of public
health services.

The purpose of the National Biodefense Strategy is to help guide the
United States in assessing, preventing, detecting, preparing for,

84According to the FEMA report, states, territories, major urban areas, and tribes conduct
a Threat and Hazard Identification and Risk Assessment to model the consequences of
their most likely threats and hazards to better understand their risks and set targets for
preparedness capabilities, which are then assessed through the Stakeholder
Preparedness Report.
85GAO, COVID-19: HHS Should Clarify Agency Roles for Emergency Return of U.S.
Citizens during a Pandemic, GAO-21-334 (Washington, D.C., Apr 19, 2021). HHS agreed
to the two recommendations we made, and we continue to monitor HHS’s progress in
implementing them.
86The National Preparedness Goal highlights the important role exercises play in
preparedness as a means to evaluate capabilities.




Page 40                                                            GAO-21-513 Biodefense
responding to, and recovering from a biological incident. The Strategy
recognizes the importance of developing, implementing, and exercising
biodefense and health security capabilities and acknowledges that the
federal biodefense mission is contingent upon coordination with and the
success of the community response. Specifically, Goal 3 of the Strategy
urges responsible agencies to develop, exercise, and update prevention,
response, and recovery plans and capabilities. Further, the Strategy’s
implementation guidance says that officials responsible for implementing
the Strategy have a responsibility for helping to identify and address gaps
in capabilities and preparedness through an annual assessment of
biodefense activities against the Strategy’s goals. 87 This guidance, along
with the NDAA, also anticipated that the Strategy and its implementation
would need to be reassessed and revised on a regular basis, recognizing
that biological threats and the actions needed to best prepare and
respond to them are ever changing. 88

DHS, DOD, USDA, and HHS officials stated that initial efforts within the
Biodefense Coordination Team to implement the Strategy focused on
identifying overarching interagency priorities, and did not focus on
defining a set of key biodefense capabilities. Additionally, cases of
COVID-19 began to appear in the U.S. in late January 2020; therefore,
Biodefense Coordination Team member agencies lacked sufficient time to
fully implement the Strategy by the time COVID-19 was declared a
pandemic and necessitated an interagency response. The process
described by the agencies to identify biodefense priorities is meant to
identify critical needs across the federal biodefense enterprise and




87Over the past decade, our work has found that many of the resources that contribute to
the nation’s biodefense are largely owned by nonfederal entities and that effective
response to significant national biological incidents relies heavily on nonfederal resources
and capabilities. In February 2020, we recommended that the Secretary of HHS direct the
Biodefense Coordination Team to, among other things, document methods and guidance
that ensure nonfederal resources and capabilities are accounted for in the annual analysis
of the resources needed to support the nation’s biodefense. HHS concurred with the
recommendation, and we continue to monitor their efforts to address this. See,
GAO-20-273.
88See Presidential Memorandum on the Support for National Biodefense/National Security
Presidential Memorandum-14, White House (September 18, 2018). The NDAA requires
that the Strategy be reviewed and, as appropriate, revised biennially. Pub. L. No. 114-328,
§ 1086, 130 Stat. at 2423 (codified at 6 U.S.C. § 104).




Page 41                                                             GAO-21-513 Biodefense
                              subsequently drive federal agencies’ budget submissions. 89 As such, it is
                              an important part of effective and efficient implementation of the Strategy.
                              However, this process does not provide the kind of foundation for
                              advancing preparedness across federal and nonfederal response
                              partners through planning, exercising, and investing over time that a clear
                              and consistent articulation of the set of capabilities needed to fully
                              implement the Strategy could provide.

                              Defining the set of capabilities needed to prepare for and respond to
                              nationally significant biological incidents could not only help entities at all
                              levels identify and help address gaps in capabilities and preparedness,
                              but also serve as a means to measure preparedness for such events
                              across the nation. A clearer understanding of how to build, maintain, and
                              apply capabilities in the context of nationally significant biological
                              incidents should be consistent with the preparedness and response goals
                              for the National Biodefense Strategy. Defining the set of capabilities
                              needed to implement the goals of the Strategy is a key step in creating
                              plans that are threat-agnostic, adaptable to changing pathogen
                              characteristics, and scalable to address a whole-of-nation response.
                              Without defining the set of capabilities needed for nationally significant
                              biological incidents (which could include capabilities already identified in
                              the National Preparedness Goal and by CDC), the federal and nonfederal
                              agencies who play vital roles in responding to these incidents are without
                              a key source of information to drive effective and efficient preparedness.

The Biodefense Enterprise     There is no process at the interagency level for agencies to assess and
Lacks a Process and           communicate priorities for exercising capabilities that are specific to
                              nationally significant biological incidents. Additionally, our analysis found
Guidance to Assess and
                              that agencies do not consistently identify the capabilities exercised across
Communicate Exercise          after-action reports. Officials from DHS, DOD, and HHS acknowledge that
Priorities and Consistently   there is no formal process for assessing and communicating exercise
Track Findings                priorities at the interagency level. However, they said the Biodefense
                              Coordination Team has held initial preliminary discussions about priorities
                              and scenarios for exercising biological incidents. DHS, DOD, HHS, and
                              USDA officials also acknowledged that there was an opportunity for the
                              Biodefense Coordination Team, in its role as the working-level federal
                              interagency group implementing the National Biodefense Strategy, to help

                              89As part of this process, agency officials said the Biodefense Coordination Team
                              identified budget priorities for fiscal year 2021, including biosurveillance, medical
                              countermeasure development, and strengthening global health. These priority budget
                              areas were consistent with some of the areas identified in our analysis of after-action
                              reporting and COVID-19 challenges.




                              Page 42                                                             GAO-21-513 Biodefense
assess and set priorities for exercising capabilities specific to the unique
needs of nationally significant biological incidents. For example, an HHS
official noted that as the Biodefense Coordination Team further develops
and evolves, HHS expects its members will begin to discuss capabilities
that should be exercised for biological incidents and will communicate
those to interagency partners.

The response to the COVID-19 pandemic highlighted a disconnect
between preparedness activities and exercises conducted prior to the
pandemic and what was needed for an effective response. For example,
officials we interviewed from five of 10 states and one of six FEMA
regions said they felt underprepared to respond to the current pandemic,
in part due to its unprecedented complexity and scale. Officials from
these five states further commented that exercises were infrequently
designed to exercise large-scale logistics capabilities and other
challenges that arose during the COVID-19 response. For example,
officials from two states noted that past biological incident exercises did
not include scenarios that emphasized the significant role FEMA would
come to play in response to the COVID-19 pandemic. 90 Officials from one
state noted that no one had practiced responding to a long-duration event
with high unemployment rates and long-term economic consequences.
Officials from another state noted that it would be helpful to conduct an
exercise scenario in which there were severe supply shortages and a
vaccine was not available. Officials from two states further commented
that the COVID-19 response did not play out how they had exercised
public health emergencies in the past, particularly with regard to




90In March 2020, leadership for the overall response shifted from HHS to FEMA. HHS
officials noted that past exercises, such as the 2019 Crimson Contagion exercise,
assumed that because an influenza pandemic is not explicitly defined as a major disaster
under the Robert T. Stafford Disaster Relief and Emergency Assistance Act, FEMA would
not be the lead agency in a pandemic response. The 2019 Crimson Contagion after-action
report found that existing statutory authorities and policies tasking HHS to lead the federal
government’s response to an influenza pandemic were insufficient and policies were often
in conflict with one another, resulting in confusion among exercise participants. However,
as discussed above, agency officials did not have time to take corrective actions prior to
the COVID-19 outbreak.




Page 43                                                              GAO-21-513 Biodefense
requesting and receiving supplies through the Strategic National
Stockpile. 91

Additionally, our analysis of selected after-action reports shows that past
interagency biological incident exercises have not always focused on
capabilities identified as challenges in the COVID-19 response. 92 In
particular, evidence from the ongoing COVID-19 response indicates that
capabilities such as Supply Chain Integrity and Security and Logistics and
Supply Chain Management are especially necessary for responding to
large-scale biological incidents. For example, in 2020, we reported on
widespread challenges with the distribution, acquisition, and adequacy of
supplies during the initial COVID-19 response—including personal
protective equipment and testing supplies. 93 However, of the 28
interagency biological exercises we reviewed that included capabilities
information in their after-action reports, none identified Supply Chain
Integrity and Security as capabilities that were being exercised.
Additionally, only four individual exercises, and the exercises from one
exercise series, listed Logistics and Supply Chain Management as a
focus of the exercise. 94

After-action reports from these exercises identified a number of areas for
improvement related to the Logistics and Supply Chain Management
capability. For example, HHS identified supply chain-related challenges in

91The March 2020 PanCAP Adapted anticipated that states, tribes, and territories would
request federal assistance when requirements exceeded their capabilities to respond to
COVID-19. For the distribution of supplies, it focused on use of the Strategic National
Stockpile, which, at the outset of the COVID-19 pandemic was a critical resource to states
for needed and scarce medical supplies. However, as we reported in June 2020,
nationwide need for critical supplies to respond to COVID-19 quickly exceeded the
quantity of supplies contained in the national stockpile. When this condition became clear,
the federal government and its nonfederal partners had to employ numerous additional
avenues to meet supply needs. For additional information about the national stockpile’s
role in the response and efforts to modernize it, see GAO-21-387.
92We used examples from the COVID-19 response as a proxy for capabilities for nationally
significant biological events, as they have not yet been defined. As discussed above,
exercising is one of five functional areas FEMA has identified as key to building core
capabilities. FEMA officials noted the importance of training, another of the five functional
areas, and stated that exercises are most successful if training is provided in advance and
a common baseline knowledge is developed.
93GAO-20-625 and GAO-20-701.


94From December 2009 through October 2010, FEMA and DHS’ Office of Health Affairs
sponsored a series of anthrax response exercises in the FEMA regions. This series
exercised the Logistics and Supply Management capability, among others. We analyzed
after-action information for a total 42 exercises.




Page 44                                                             GAO-21-513 Biodefense
the after-action report for the 2019 Crimson Contagion exercise. The
report found that the supply chain for medical countermeasures (such as
personal protective equipment and ventilators) may not meet the demand
of a global pandemic. It also found that states participating in the exercise
experienced multiple challenges requesting resources from the federal
government due to a lack of standardized, well-understood, and properly
executed resource request processes. The after-action report contained a
number of recommendations to address these challenges; however, HHS
officials told us that they have not yet had time to address the
recommendations due to the COVID-19 pandemic response that began in
2020. Figure 6 below shows participants gathering for a biological
incident exercise—an important practice to enhance preparedness.

Figure 6: Participants in a Biological Incident Exercise




Our analysis further found that agencies did not consistently identify the
capabilities exercised across the after-action reports we reviewed.
Specifically, 28 of the 42 interagency biological incident exercises for
which we analyzed after-action reports clearly discussed assessing one
or more of the National Preparedness Goal core capabilities. 95 However,
the remaining 14 after-action reports did not identify the capabilities
exercised.


95The most frequently exercised core capabilities included the three that span all five
mission areas―”Operational Coordination” (27), “Public Information and Warning” (14),
and “Planning” (12)―as well as the “Public Health, Healthcare, and Emergency Medical
Services” (12) core capability from the Response mission area. Some exercise more than
one capability.




Page 45                                                          GAO-21-513 Biodefense
Homeland Security Exercise and Evaluation Program guidance provides
a set of fundamental principles for exercise programs across the whole
community and all mission areas, including that exercises should be
“capability-based and objective-driven.” The guidance notes that exercise
design and objectives, including the capabilities to be exercised, should
consider senior leader intent and guidance, as well as past findings from
exercises and real-world events, among other things. Applying Homeland
Security Exercise and Evaluation Program guidance at the interagency
level would involve the Biodefense Coordination Team assessing and
communicating updated priority capabilities for federal and nonfederal
response partners to exercise. This guidance also states that the after-
action reporting process can validate current capabilities already in place
and describe areas for improvement. Additionally, Standards for Internal
Control in the Federal Government states that management should
communicate quality information externally through reporting lines so that
external parties can help the entity achieve its objectives and address
related risks. 96

DHS, HHS, and DOD officials told us that, prior to the COVID-19
pandemic, it was challenging to build interest in and support for large-
scale biological incident exercises. Federal, state, and health care
association officials we spoke with also noted that it is important for
exercises to include a broad range of participants across multiple levels of
government, but that at the same time, it can be difficult to get response
partners to recognize the need to exercise high consequence, low
probability biological events such as the COVID-19 pandemic. For
example, officials from one state commented that, prior to the COVID-19
pandemic, some localities were reluctant to participate in biodefense
exercises because they thought it was a waste of time to exercise a
scenario that would never happen.

Additionally, as noted earlier in this report, agencies that make up the
Biodefense Coordination Team have been focused on responding to the
COVID-19 pandemic and have not had the opportunity to conduct
activities that would fully advance the preparedness goal of the National
Biodefense Strategy. Specifically, they have not yet had time to take
additional actions to assess and communicate exercise priorities, which
will be predicated on them first defining those capabilities to prioritize in




96GAO-14-704G.




Page 46                                                   GAO-21-513 Biodefense
                             exercises. Additionally, they have not had the opportunity to develop
                             exercise reporting guidance for interagency partners.

                             Without a process to assess and communicate exercise priorities and
                             guidance on reporting the key capabilities needed to respond to nationally
                             significant biological incidents, the Biodefense Coordination Team cannot
                             track progress over time and across the biodefense enterprise to help
                             ensure efficient and effective preparedness efforts. As a result, federal
                             and nonfederal response partners may remain underprepared in key
                             biodefense capability areas. Moreover, establishing a process for
                             assessing and communicating exercise priorities that are based on a
                             defined set of capabilities, would help stakeholders coalesce around the
                             biodefense mission that transcends, but is supported by, individual
                             agency missions. Additionally, guidance about how to report on the
                             unique aspects of capabilities needed for nationally significant biological
                             events could help partners across the enterprise—federal and
                             nonfederal—capture critical information in a consistent manner so that the
                             Biodefense Coordination Team can track findings across time and across
                             the enterprise.

Lack of Cross-               Our interviews with agency officials and our analysis of real-world after-
Government Review of         action reports revealed that agencies do not routinely work together to
                             monitor and review results from exercises and real-world events and
Exercises and Incidents
                             evaluate lessons learned across the government to identify patterns and
Limits Ability to Identify   possible root causes for systemic challenges. 97 According to FEMA
and Address Systemic         officials, through the National Exercise Program, FEMA facilitates
Challenges                   solicitation of interagency feedback and reviews after-action reports to
                             develop priorities for the next National Exercise Program 2-year cycle.
                             However, these officials further noted that analysis of after-action reports
                             submitted to the program do not reflect the comprehensive view of all
                             exercises conducted across the nation. The National Exercise Program is
                             only one line of effort to conduct exercises, meaning analysis done
                             through this effort does not encapsulate all exercise or real-world incident
                             findings in order to identify patterns of challenges related to the unique
                             aspects of nationally significant biological incidents. Officials at HHS,

                             97In February 2009, we recommended that the Secretaries of HHS, USDA, and the
                             Department of Interior coordinate with federal, state, and local agencies to periodically
                             review assessments following zoonotic disease outbreaks to identify common challenges
                             and strategies to address them. These recommendations were closed as not
                             implemented. See GAO, Veterinarian Workforce: Actions Are Needed to Ensure Sufficient
                             Capacity for Protecting Public and Animal Health, GAO-09-178 (Washington D.C.: Feb. 4,
                             2009).




                             Page 47                                                           GAO-21-513 Biodefense
which also organizes interagency biological incident exercises, further
noted that they do not have a process that would collect and analyze
exercise outcomes at multiple levels to drive future interagency biological
incident efforts.

As discussed above, our analysis of after-action reports for interagency
biological exercises and real-world events identified patterns of
challenges that existed before the COVID-19 pandemic. 98 Additionally,
our analysis of these after-action reports showed that approximately 44
percent (225 of 507) of the findings had interagency implications,
meaning that the gap or strength applied to activities undertaken by two
or more federal agencies. The response to COVID-19 continues to
demonstrate that a whole-of-nation response relies on multiple agencies
at all levels of government, as well as nongovernment sectors, to
coordinate in order to reduce morbidity and mortality, and to ensure
economic stability and national security.

Officials at DHS, DOD, HHS, and USDA also stated that ensuring
accountability for addressing these findings is a challenge and that in
addition to not having a mechanism to conduct cross government
analysis of findings, there is also no interagency mechanism to ensure
agencies implement corrective actions. For example, much like agencies’
responsibility for implementing the National Biodefense Strategy, heads
of agencies are responsible for holding their agencies accountable for
implementation of corrective actions. Officials from two associations
representing public health interests expressed concern that lessons
learned following exercises are not addressed and are not transferred
from one administration to another. Officials from DHS’ Countering
Weapons of Mass Destruction Office also recognized the challenge in
losing continuity of effort from one administration to the next, as each
administration sets its own priorities and must address emerging
challenges. They said those with institutional history—who work on these
issues across administrations—and those familiar with exercising
nationally significant biological incidents can use their knowledge to help
ensure that the best preparedness results in the best response.

Internal control standards state that management should establish and
operate monitoring activities to monitor the internal control system and


98We found that these same categories of challenges—such as coordinating response
operations and managing information—manifested during the COVID-19 response.




Page 48                                                        GAO-21-513 Biodefense
evaluate the results. 99 This can be achieved through ongoing monitoring,
separate evaluations, or a combination of the two to obtain reasonable
assurance of the operating effectiveness of the organization’s internal
controls over the assigned process. In the context of implementing the
National Biodefense Strategy, the Biodefense Steering Committee needs
information that allows it to identify gaps and areas for improvement to
ensure efficient and effective preparedness for nationally significant
biological incidents. Federal internal control standards also state that in
order to achieve the entity’s objectives, management should assign
responsibility and delegate authority to key roles. In this context, once
patterns and root causes are identified, the Biodefense Coordination
Team could also identify responsibility for addressing these causes
among interagency partners and ensure implementation actions are taken
or endorsed by the Biodefense Steering Committee. Federal internal
control standards further state that, in deciding what information is
required to achieve objectives, management should consider the needs of
both internal and external users and that management should externally
communicate necessary quality information in order to meet objectives.
Communicating the results of monitoring activities to key decision
makers—such as cabinet-level secretaries and administrators—allows
them to be informed of critical issues that may require their attention and
action.

While agency officials we interviewed described the development and
updating of biodefense-related response plans as an interagency activity,
as discussed above, this type of interagency engagement does not
extend to implementing corrective actions. Additionally, interagency
efforts to implement the National Biodefense Strategy have focused on
identifying budget priorities. Attention among Biodefense Coordination
Team agencies has been divided between these efforts as well as
responding to the daunting and specific challenges of the COVID-19
response. Further, officials from DHS’s Countering Weapons of Mass
Destruction Office described an organic process through exercise
development, rather than a consistent, formal process to look at the
results of exercises and identify gaps and lessons learned across the
government. These officials said that most health, medical, and biological
exercises cascade off each other, meaning when one exercise identifies a
problem, the next exercise will use that as a gap and try to address it. In
that regard, officials said there has been steady improvement in
preparedness because of the results of exercises. However, officials from

99GAO-14-704G.




Page 49                                                GAO-21-513 Biodefense
              DHS, DOD, HHS, and USDA recognized the value cross-agency analysis
              of after-action findings could provide and said the Biodefense
              Coordination Team, as the working-level group with responsibility for the
              National Biodefense Strategy, is well-positioned to be the entity that
              conducts analysis to identify patterns and root causes of longstanding
              problems.

              Institutionalized mechanisms to identify root causes of pervasive and
              recurrent issues and to provide structure and accountability to help
              ensure actions to address those causes would promote more effective
              and efficient preparedness over time and across organizational
              boundaries. Our analysis of findings regarding lessons learned during
              interagency biological incident exercises and real-world events identified
              longstanding challenges that existed before COVID-19. Taking steps to
              monitor and identify persistent issues at the interagency level—that would
              not otherwise be captured during individual agency reviews—could help
              further enhance the preparedness activities of the many different partners
              responsible for responding to nationally significant biological incidents.
              Further, assigning accountability for addressing root causes to these
              challenges at the interagency level could help ensure a more effective
              response to future incidents.

              The unprecedented scope and scale of the COVID-19 pandemic placed
Conclusions   into sharp focus the critical capabilities needed to execute a whole-of-
              nation response to a nationally significant biological incident. Capabilities
              such as global supply chain logistics, mass testing and vaccination, data
              integration and analysis, and communication among various levels of
              government and directly with the public reach beyond the mission space
              of a single agency and require federal and nonfederal agencies to work
              united during a response. Federal agencies have taken steps to identify
              both all-hazard and public health capabilities that could be used to
              support or execute a response to biological incidents, but do not fully
              address the unique characteristics and response needs for nationally
              significant biological incidents.

              The nature of biological incidents presents inherent and unique
              challenges, not only because of the fragmented nature of preparedness
              and response activities, but also because nationally significant biological
              incidents tend to be low-probability, yet high-consequence events. While
              executing large scale or complex scenarios that reflect the conditions and
              challenges the nation faced during the COVID-19 pandemic may come at
              a cost, so too will the repercussions of not effectively preparing for such
              events in the future. Preparation for nationally significant biological


              Page 50                                                  GAO-21-513 Biodefense
                     incidents like COVID-19 cannot afford to suffer from a lack of imagination.
                     We found that several key themes continued to emerge as areas for
                     improvement over the past ten years during exercises and real-world
                     events, and that those same issues manifested as challenges during the
                     COVID-19 response.

                     The ability to monitor and assess the outcomes of interagency biological
                     incident exercises and real-world events could be instrumental in
                     identifying persistent challenges and their root causes before they
                     become systemic, intractable problems. Identifying these issues could
                     also help agencies prioritize which capabilities need further development
                     or exercising. The Biodefense Steering Committee includes the heads of
                     federal agencies with biodefense responsibilities. The Biodefense
                     Coordination Team, which plays a key role in implementing the National
                     Biodefense Strategy in coordination with the Biodefense Steering
                     Committee, is uniquely positioned to carry out these types of analysis
                     activities, as it combines the expertise from federal agencies with
                     biodefense responsibilities. Once the Team defines the set of capabilities
                     required, establishing interagency exercise priorities around those
                     capabilities, ensuring consistent reporting of capabilities exercised, and
                     routinely monitoring and communicating the results of the exercises and
                     incidents will help ensure the nation is better positioned to respond to the
                     next biological threat.

                     We are making 16 recommendations to the Secretaries of Homeland
Recommendation for   Security, Defense, Health and Human Services, and Agriculture.
Executive Action
                     The Secretary of Homeland Security, should, with input from key
                     nonfederal partners, work through the Biodefense Steering Committee to
                     ensure that the Biodefense Coordination Team defines the set of
                     capabilities needed to prepare for and respond to nationally significant
                     biological incidents. (Recommendation 1)

                     The Secretary of Defense, should, with input from key nonfederal
                     partners, work through the Biodefense Steering Committee to ensure that
                     the Biodefense Coordination Team defines the set of capabilities needed
                     to prepare for and respond to nationally significant biological incidents.
                     (Recommendation 2)

                     The Secretary of Health and Human Services, should, with input from key
                     nonfederal partners, work through the Biodefense Steering Committee to
                     ensure that the Biodefense Coordination Team defines the set of



                     Page 51                                                  GAO-21-513 Biodefense
capabilities needed to prepare for and respond to nationally significant
biological incidents. (Recommendation 3)

The Secretary of Agriculture, should, with input from key nonfederal
partners, work through the Biodefense Steering Committee to ensure that
the Biodefense Coordination Team defines the set of capabilities needed
to prepare for and respond to nationally significant biological incidents.
(Recommendation 4)

The Secretary of Homeland Security should work through the Biodefense
Steering Committee to ensure that the Biodefense Coordination Team
establishes a process to periodically assess and communicate exercise
priorities among the capabilities they identify to support nationally
significant biological incidents. (Recommendation 5)

The Secretary of Defense should work through the Biodefense Steering
Committee to ensure that the Biodefense Coordination Team establishes
a process to periodically assess and communicate exercise priorities
among the capabilities they identify to support nationally significant
biological incidents. (Recommendation 6)

The Secretary of Health and Human Services should work through the
Biodefense Steering Committee to ensure that the Biodefense
Coordination Team establishes a process to periodically assess and
communicate exercise priorities among the capabilities they identify to
support nationally significant biological incidents. (Recommendation 7)

The Secretary of Agriculture should work through the Biodefense Steering
Committee to ensure that the Biodefense Coordination Team establishes
a process to periodically assess and communicate exercise priorities
among the capabilities they identify to support nationally significant
biological incidents. (Recommendation 8)

The Secretary of Homeland Security should work through the Biodefense
Steering Committee to ensure that the Biodefense Coordination Team
provides guidance for federal and nonfederal partners for how to report
on capabilities in after-action reports for exercises and real-world
incidents in a consistent manner. (Recommendation 9)

The Secretary of Defense should work through the Biodefense Steering
Committee to ensure that the Biodefense Coordination Team provides
guidance for federal and nonfederal partners for how to report on



Page 52                                                 GAO-21-513 Biodefense
capabilities in after-action reports for exercises and real-world incidents in
a consistent manner. (Recommendation 10)

The Secretary of Health and Human Services should work through the
Biodefense Steering Committee to ensure that the Biodefense
Coordination Team provides guidance for federal and nonfederal partners
for how to report on capabilities in after-action reports for exercises and
real-world incidents in a consistent manner. (Recommendation 11)

The Secretary of Agriculture should work through the Biodefense Steering
Committee to ensure that the Biodefense Coordination Team provides
guidance for federal and nonfederal partners for how to report on
capabilities in after-action reports for exercises and real-world incidents in
a consistent manner. (Recommendation 12)

The Secretary of Homeland Security should work through the Biodefense
Steering Committee to ensure that the Biodefense Coordination Team
routinely monitors the results of interagency biological exercises and real-
world incidents to identify patterns of challenges and potential root causes
of identified challenges, and reports these to the Biodefense Steering
Committee along with recommendations for addressing the root causes
that also identify the responsible agencies. (Recommendation 13)

The Secretary of Defense should work through the Biodefense Steering
Committee to ensure that the Biodefense Coordination Team routinely
monitors the results of interagency biological exercises and real-world
incidents to identify patterns of challenges and potential root causes of
identified challenges, and reports these to the Biodefense Steering
Committee along with recommendations for addressing the root causes
that also identify the responsible agencies. (Recommendation 14)

The Secretary of Health and Human Services should work through the
Biodefense Steering Committee to ensure that the Biodefense
Coordination Team routinely monitors the results of interagency biological
exercises and real-world incidents to identify patterns of challenges and
potential root causes of identified challenges, and reports these to the
Biodefense Steering Committee along with recommendations for
addressing the root causes that also identify the responsible agencies.
(Recommendation 15)

The Secretary of Agriculture should work through the Biodefense Steering
Committee to ensure that the Biodefense Coordination Team routinely
monitors the results of interagency biological exercises and real-world


Page 53                                                   GAO-21-513 Biodefense
                     incidents to identify patterns of challenges and potential root causes of
                     identified challenges, and reports these to the Biodefense Steering
                     Committee along with recommendations for addressing the root causes
                     that also identify the responsible agencies. (Recommendation 16)

                     We provided a draft of this report to DHS, DOD, HHS, and USDA for
Agency Comments      review and comment. In the draft report, we made a set of
and Our Evaluation   recommendations to the secretaries to work through the Biodefense
                     Coordination Team, which is the working level group established to help
                     with National Biodefense Strategy implementation. DHS, DOD, and
                     USDA suggested that the recommendations be directed instead through
                     the Biodefense Steering Committee. This Committee is the group of
                     secretary-level officials with responsibility for the Strategy and for
                     directing the work of the Biodefense Coordination Team. We agree with
                     the departments’ suggestion. Accordingly, we have made this change to
                     the recommendations.

                     In addition to the above comments, DHS, HHS, and USDA otherwise
                     stated they concurred with all four recommendations made to each
                     agency and provided technical comments, which we incorporated as
                     appropriate. DOD partially concurred with all four recommendations. The
                     written comments of DHS, DOD, and HHS are reproduced in appendices
                     III, IV, and V. USDA’s audit liaison provided comments via email.

                     In response to recommendations 1 through 4 to define a set of
                     capabilities needed to prepare for and respond to nationally significant
                     biological incidents, with key input from nonfederal partners, DHS, HHS,
                     and USDA concurred. In its partial concurrence, in addition to suggesting
                     that the recommendations be made through the Biodefense Steering
                     Committee, DOD expressed concerns about the appropriateness of the
                     Secretary of Defense’s role in gathering and assessing nonfederal input
                     and providing it to the Biodefense Coordination Team. In response, we
                     note that the intent of the sixteen recommendations we make in this
                     report—four each to the four agencies given responsibility for the National
                     Biodefense Strategy in statute—is to ensure that all four agencies work
                     as full partners leading this effort in the ways that are most appropriate to
                     their particular responsibilities, authorities, and resources.

                     The agencies also described actions they have taken or plan to take to
                     address recommendations 1 through 4. Specifically, DOD, HHS, and
                     USDA described Biodefense Coordination Team efforts to identify
                     capabilities necessary for advancing the goals and objectives of the
                     National Biodefense Strategy. Although none of these agencies specified


                     Page 54                                                  GAO-21-513 Biodefense
that the set of capabilities they described was to be the final set of
capabilities intended to form the foundation to prepare the nation for
future biologically significant incidents, they did indicate that work is
already underway. To fully address this recommendation, the agencies,
working through the Biodefense Coordination Team, will need to provide
a finalized set of capability descriptions and evidence of input from key
nonfederal partners.

In response to recommendations 5 through 8 to establish a process to
periodically assess and communicate exercise priorities, DHS, HHS, and
USDA concurred. DOD partially concurred. As with the other
recommendations, DHS, DOD, and USDA suggested that the
recommendation be made through the Biodefense Steering Committee.
DHS, HHS, and USDA also described avenues that the Biodefense
Coordination Team could use to help identify and communicate exercise
priorities. To fully address this recommendation, the agencies, working
through the Biodefense Coordination Team, will need to finalize a process
that includes a means for periodic assessment to prioritize among the
capabilities for exercises.

In response to recommendations 9 through 12 to provide guidance for
federal and nonfederal partners for how to report on capabilities in after-
action reports for exercises and real-world incidents in a consistent
manner, DHS, HHS, and USDA concurred. DOD partially concurred. In its
partial concurrence, DOD noted concerns about the appropriateness of
the Secretary of Defense’s role in leading efforts to standardize after-
action reporting for federal and nonfederal partners. As noted above, the
intent of the recommendation was for DOD to work with its interagency
partners in this effort. DHS and HHS also described mechanisms that
could be used for reporting capabilities in after-action reports. To fully
respond to this recommendation, the agencies, working through the
Biodefense Coordination Team, will need to provide guidance for
reporting on capabilities in after-action reports.

In response to recommendations 13 through 16 to routinely monitor the
results of interagency biological exercises and real-world incidents to
identify patterns of challenges and potential root causes of identified
challenges, and report these to the Biodefense Steering Committee along
with recommendations for addressing the root causes that also identify
responsible agencies, DHS, HHS, and USDA concurred. DOD partially
concurred. DHS and HHS also described ways in which the interagency
partners could communicate about challenges and their root causes. To
fully respond to this recommendation, the agencies, working through the


Page 55                                                GAO-21-513 Biodefense
Biodefense Coordination Team, will need to put in place the means to
routinely monitor incidents, to identify patterns of challenges and their root
causes, and to make recommendations to the Biodefense Steering
Committee for addressing those root causes.

We are sending copies of this report to the appropriate congressional
committees, the Secretary of Homeland Security, the Secretary of
Defense, the Secretary of Health and Human Services, the Secretary of
Agriculture, and other interested parties. In addition, the report is
available at no charge on the GAO website at https://www.gao.gov.

If you or your staff members have any questions about this report, please
contact Chris Currie at (404) 679-1875 or CurrieC@gao.gov. Contact
points for our Office of Congressional Relations and Public Affairs may be
found on the last page of this report. GAO staff who made key
contributors to this report are listed in appendix VI.




Chris P. Currie
Director, Homeland Security and Justice




Page 56                                                  GAO-21-513 Biodefense
List of Committees

The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate

The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate

The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate

The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Rosa L. DeLauro
Chairwoman
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives




Page 57                                               GAO-21-513 Biodefense
List of Committees Continued

The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives

The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives

The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives

The Honorable Richard Neal
Chair
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives




Page 58                                GAO-21-513 Biodefense
Appendix I: National Biodefense Strategy
                                            Appendix I: National Biodefense Strategy
                                            Preparedness and Response Categories



Preparedness and Response Categories

                                            The National Biodefense Strategy consists of five high-level goals
                                            intended to help enable the efficient assessment, prevention, preparation,
                                            response, and recovery from natural, accidental, or deliberate biological
                                            threats. Each goal has associated objectives and sub-objectives designed
                                            to strengthen the biodefense enterprise. Table 3 below describes the
                                            objectives under the Strategy’s preparedness and response goals.

Table 3: National Biodefense Strategy Preparedness and Response Objectives

National Biodefense Strategy               Description
objectives
Preparedness
Support U.S. biodefense research,          Ensure an innovative national science and technology base to support biodefense by:
development, and investment                •   enabling U.S.-led innovation through scientific, technical, and industrial bases; and
                                           •   integrating research and development into federal planning.
Ensure a strong public and veterinary      Ensure a strong public and veterinary health infrastructure by:
health infrastructure                      •   ensuring critical capacities and establishing capabilities to provide surge staffing,
                                               resources, and supplies; and
                                           •   modernizing public and veterinary laboratories so they have access to updated
                                               diagnostic tests, methods, equipment, and technologies.
Develop, exercise, and update              Develop, exercise, and update prevention, response, and recovery plans and capabilities.
plans and capabilities                     This includes:
                                           •   developing and exercising policies, plans, guidelines, and recommendations to
                                               support prevention, response, and recovery activities;
                                           •   ensuring that emergency funding mechanisms exist to support urgent responses to
                                               bioincidents;
                                           •   supporting the effective deployment of medical counter-measure stockpiles;
                                           •   supporting the provision of health care and the conduct of clinical research during
                                               bioincidents;
                                           •   supporting the continuity of operations; and
                                           •   supporting the provision of essential services, critical infrastructure, and long-term
                                               recovery.
Develop, exercise, and update risk plans   Develop, exercise, and update risk communication plans and promote consistent
to support effective public messaging,     messaging to inform key audiences, expedite response actions, and address public
enhance public trust, and promote          uncertainty and fear. This includes:
consistent messaging                       •   improving federal messaging coordination for biothreats and bioincidents;
                                           •   developing and exercising communications plans; and
                                           •   enhancing messaging partnerships with the private sector.
Improve diagnostic capabilities and        Enhance preparedness to save lives through medical countermeasures by:
enhance medical countermeasures            •  improving diagnostic capabilities; and
                                           •  enhancing the development, sustainment, and availability of medical counter-
                                              measures.




                                            Page 59                                                               GAO-21-513 Biodefense
                                       Appendix I: National Biodefense Strategy
                                       Preparedness and Response Categories




National Biodefense Strategy          Description
objectives
Enhance community mitigation          Enhance preparedness to limit the spread of disease through community mitigation
measures development and              measures. This includes:
capabilities                          •  developing and assessing the effectiveness of community mitigation measures to
                                         mitigate the impact of bioincidents; and
                                      •  establishing and promoting best practices for implementing such measures.
Enhance decontamination               Enhance preparedness to support decontamination by:
preparedness                          •  conducting research and developing verified technologies; and
                                      •  developing and exercising decontamination plans.
Improve the ability for the federal   Strengthen preparedness to operate and collaborate across the United States, including
government to collaborate with        U.S. territories by:
states and territories                •   establishing collaborative and resource sharing policies and operational frameworks.
Work with international               Strengthen international preparedness to support international response and recovery
governments to improve                capabilities. This includes:
global preparedness                   •   strengthening foreign governments and international organizations’ commitment to,
                                          preparedness for, and capacity to respond to bioincidents;
                                      •   enhancing international preparedness through medical countermeasures;
                                      •   enhancing international preparedness through community mitigation measures; and
                                      •   further developing, exercising, and updating plans for responding to and recovering
                                          from international bioincidents.
Response
Manage information                    Compile and share biothreat and bioincident information to enable decision-making and
                                      response operations across all levels of government and with non-governmental, private
                                      sector, and international entities. This includes:
                                      •   ensuring access to timely, accurate, and useful information;
                                      •   coordinating federal decision making to support response operations; and
                                      •   enhancing situational awareness through real-time information sharing.
Coordinate response operations        Conduct federal response operations in coordination with non-federal actors to contain,
and resources                         control, and rapidly mitigate the impacts of biothreats or bioincidents. This includes:
                                      •   ensuring appropriate oversight and coordination;
                                      •   deploying medical countermeasures and implementing community mitigation
                                          measures;
                                      •   conducting real-time research regarding threats and countermeasures;
                                      •   implementing and supporting response operations; and
                                      •   preserving the continuity of operations of the U.S. government and critical
                                          infrastructure.
Conduct operations and                Conduct operations and investigations, and use available tools to hold perpetrators
investigations for intentional        accountable. This includes:
incidents                             •   strengthening capacity and capabilities to conduct incident operations and
                                          investigations;
                                      •   conducting forensic examinations to support attribution of a biothreat or a bioincident;
                                          and
                                      •   providing technical and logistical support to international investigations.




                                       Page 60                                                              GAO-21-513 Biodefense
                                                              Appendix I: National Biodefense Strategy
                                                              Preparedness and Response Categories




 National Biodefense Strategy                               Description
 objectives
 Provide effective public                                   Execute risk-informed, accurate, timely, and actionable public messaging.
 messaging                                                  •   Deliver public messaging to facilitate public understanding and decision-making during
                                                                a bioincident, including by providing timely, regular, accessible, and coordinated
                                                                information and combating misinformation.
Source: GAO analysis of National Biodefense Strategy. | GAO-21-513




                                                              Page 61                                                          GAO-21-513 Biodefense
Appendix II: National Preparedness Goal
              Appendix II: National Preparedness Goal and
              Public Health Capabilities



and Public Health Capabilities

              National Preparedness Goal Capabilities

              The National Preparedness Goal identifies and defines 32 core
              capabilities across five broad mission areas. 1 These capabilities apply to
              all hazards and threats and are not incident specific. Further, they are
              intended to apply to the whole community, and are not specific to any one
              federal or nonfederal agency or organization. The core capabilities form
              the foundation for measuring overall national preparedness and assisting
              the nation in allocating resources to fill identified preparedness gaps. 2 As
              shown in figure 7 below, three of the 32 core capabilities affect all mission
              areas and are considered to be “crosscutting.”




              1The five mission areas are: prevention, protection, mitigation, response, and recovery.

              2The White House released Presidential Policy Directive 8 on National Preparedness in
              March 2011. It directed the Secretary of Homeland Security to design a national
              preparedness system to address the threats posing the greatest risk to the security of the
              nation and issue various policy and planning documents designed to strengthen national
              preparedness. Additionally, it required the Secretary to develop a National Preparedness
              Goal that identifies the core capabilities necessary to achieve preparedness.




              Page 62                                                            GAO-21-513 Biodefense
                                       Appendix II: National Preparedness Goal and
                                       Public Health Capabilities




Figure 7: National Preparedness Goal’s 32 Emergency Management Core Capabilities by Mission Area




                                       a
                                           Prevention: Preventing an imminent threat, or actual act of terrorism.
                                       b
                                        Protection: Protecting citizens, residents, visitors, and assets in a manner that allows interests,
                                       aspirations, and way of life to thrive.
                                       c
                                           Mitigation: Mitigating the loss of life and property by lessening the impact of future disasters.




                                       Page 63                                                                           GAO-21-513 Biodefense
Appendix II: National Preparedness Goal and
Public Health Capabilities




d
 Response: Responding quickly to save lives, protect property and the environment, and meet basic
human needs in the immediate aftermath of an incident.
e
 Recovery. Recovering through a focus on the timely restoration, strengthening, and revitalization of
infrastructure, housing, and a sustainable economy, as well as the health, social, cultural, historic,
and environment fabric of communities affected by an incident.


Public Health Capabilities

In 2011, the Centers for Disease Control and Prevention (CDC)
developed 15 public health-specific capabilities as part of the Public
Health Emergency Preparedness program. 3 CDC updated these
capabilities in 2018 to address emerging technologies and threats. 4 As
shown in figure 8 below, CDC’s capability standards are organized into
six domains and two tiers. According to CDC, Tier 1 capability standards
are intended to form the foundation for public health emergency
preparedness and response, while Tier 2 capability standards are cross-
cutting, and reliant on the establishment of Tier 1 capability standards in
collaboration with external partners and stakeholders.




3The Public Health Emergency Preparedness program provides funds to build and sustain
public health preparedness and response capacity.
4U.S. Department of Health and Human Services, Centers for Disease Control and
Prevention, Public Health Emergency Preparedness and Response Capabilities: National
Standards for State, Local, Tribal, and Territorial Health (Atlanta, GA: October 2018).




Page 64                                                                      GAO-21-513 Biodefense
                                       Appendix II: National Preparedness Goal and
                                       Public Health Capabilities




Figure 8: Public Health Emergency Preparedness and Response Capabilities




                                       Note: According to the Centers for Disease Control and Prevention, Tier 1 capability standards are
                                       intended to form the foundation for public health emergency preparedness and response, while Tier 2
                                       capability standards are cross-cutting, and reliant on the establishment of Tier 1 capability standards
                                       in collaboration with external partners and stakeholders.




                                       Page 65                                                                     GAO-21-513 Biodefense
Appendix III: Comments from the
             Appendix III: Comments from the Department
             of Homeland Security



Department of Homeland Security




             Page 66                                      GAO-21-513 Biodefense
Appendix III: Comments from the Department
of Homeland Security




Page 67                                      GAO-21-513 Biodefense
Appendix III: Comments from the Department
of Homeland Security




Page 68                                      GAO-21-513 Biodefense
Appendix III: Comments from the Department
of Homeland Security




Page 69                                      GAO-21-513 Biodefense
Appendix IV: Comments from the
             Appendix IV: Comments from the Department
             of Defense



Department of Defense




             Page 70                                     GAO-21-513 Biodefense
Appendix IV: Comments from the Department
of Defense




Page 71                                     GAO-21-513 Biodefense
Appendix IV: Comments from the Department
of Defense




Page 72                                     GAO-21-513 Biodefense
Appendix V: Comments from the Department
             Appendix V: Comments from the Department
             of Health and Human Services



of Health and Human Services




             Page 73                                    GAO-21-513 Biodefense
Appendix V: Comments from the Department
of Health and Human Services




Page 74                                    GAO-21-513 Biodefense
Appendix V: Comments from the Department
of Health and Human Services




Page 75                                    GAO-21-513 Biodefense
Appendix V: Comments from the Department
of Health and Human Services




Page 76                                    GAO-21-513 Biodefense
Appendix VI: GAO Contact and Staff
                  Appendix VI: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Chris P. Currie at (404) 679-1875 or CurrieC@gao.gov
GAO Contact
                  In additional to the contact named above, Kathryn Godfrey (Assistant
Staff             Director), Sarah Turpin (Analyst-in-Charge), Nasreen Badat, Benjamin
Acknowledgments   Crossley, Danielle Curet, David Dornisch, Tracey King, Susanna Kuebler,
                  and Andrew Stavisky made key contributions to this report.




(104292)
                               Page 77                                GAO-21-513 Biodefense
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