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Initial Assessment Report Key Findings and Recommendations

Organized into five subject matter areas, the Initial Assessment Report identifies 32 key findings and 57 recommendations to improve existing and future responses to pandemic incidents.

Download the Initial Assessment Report to see the full listings of findings and recommendations, or see below for an overview of top findings and recommendations.

Coordinating Structures and Policy

FEMA leveraged existing federal policies and structures in non-typical ways to effectively respond to the unprecedented nature and scope of COVID-19.

This response involved close coordination with the U.S. Department of Health and Human Services (HHS), the creation of operational task forces, the establishment of a national-level Unified Coordination Group (UCG), extensive coordination with the White House Coronavirus Task Force (WHTF) and an expanded process for messaging approval and distribution.

Key Finding

The global scope of the pandemic outstripped assumptions made in existing policies, plans and procedures, which did not account for FEMA taking a lead agency role during a pandemic; this affected the agency's ability to coordinate an effective response.

  • The 2018 Pandemic Crisis Action Plan (PanCAP) identified HHS as the lead federal agency (LFA). The PanCAP-Adapted (PanCAP-A), which was finalized by FEMA and HHS in March 2020, also identified HHS as the LFA for the COVID-19 response, with support from FEMA for coordination.
  • On March 13, 2020, the President announced that HHS would serve as the LFA.
  • On March 18, 2020, the President and Vice President informed the FEMA Administrator that FEMA would be leading the response.

Recommendation

Clarify FEMA’s authorities during a federal response to a pandemic and refine FEMA’s role in such national-level incidents. Assess and revise national-level doctrine to ensure that it provides clarity and specifics about FEMA’s role and authorities during incidents where there is a response by the entire federal government. This includes establishing a funding plan to clarify which agencies are financially responsible for which aspects of a response.

Key Finding

The operational task forces successfully managed lines of effort for COVID-19 operations; however, FEMA faced challenges integrating task forces into the existing National Response Coordination Center (NRCC) structure.

  • On March 19, 2020, the operational task forces, stood up by HHS, were transferred to FEMA.
  • There were coordination challenges integrating the task forces into the NRCC structure.

Recommendation

Promote the National Incident Management System/Incident Command System (NIMS/ICS) use throughout other federal agencies and SLTT partners to help facilitate better integration into future efforts.

Key Finding

FEMA Office of External Affairs was able to establish the National Joint Information Center with U.S. Department of Health and Human Services (HHS) and other federal partners; however, the lack of clarity about FEMA’s and the Unified Coordination Group (UCG)’s role created confusion around the external messaging clearance process designed for this response.

  • FEMA assumed oversight of public messaging when it became the lead agency.
  • FEMA’s message approval process was modified to accommodate the White House’s role, which was complex due to coordination with the 40 departments and agencies involved in the operations.

Recommendation

Revise ESF-15 SOP and PanCAP to include clear messaging approval and distribution procedures when there are multiple federal agencies under the decision-making role of the White House. ESF-15 SOP revisions should include defining set lines of authority for the review and final clearance of each product type—FEMA internal and external documents—with appropriate branding for external documents.

Resources

At the outbreak of the COVID-19 pandemic, resources were insufficient to meet national demands. The healthcare sector was most affected, with global shortages of personal protective equipment (PPE) and testing kits. FEMA procured and managed unfamiliar resources and adapted to shortfalls.

Key Finding

FEMA addressed resource shortages with new analytical tools and collaboration with the private sector to make data-driven allocation decisions.

  • Analytical products like the Resource Allocation Tool showed the importance of data in emergency management.
  • FEMA’s Resource Allocation Tool incorporated private sector supply data, health data, Resource Request Forms (RRFs), historical supply information, and frequency of requests to better allocate and distribute resources.

Recommendation

Develop a coordinated strategy for data-driven operations. FEMA should learn from the approaches and methodologies developed to identify their broader application to other disaster and catastrophic scenarios.

 

Key Finding

The National Response Coordination Center structure (NRCC) coordinated the national mobilization and distribution of billions of dollars’ worth of PPE and other resources, but the lack of an initial centralized system to integrate non-FEMA resources supporting mission requirements affected visibility of the resources shipped and the estimated delivery dates for state, local, tribal and territorial (SLTT) partners.

  • FEMA and its partners delivered more than 800 million items across the U.S. as of September 25, 2020.
  • FEMA executed unprecedented mission assignments to support SLTT requirements, but the pandemic revealed insufficient policies for handling the complexity of operations.

Recommendation

Assess resource coordination and distribution operations at the headquarters and regional levels to revise and refine plans and ensure integration with SLTT partners. Nationally, FEMA should identify practices that should be incorporated for future operations.

Key Finding

FEMA coordinated with private sector partners to expand domestic manufacturing of scarce resources but lacked a consistent strategy across the operation for involving the private sector, which resulted in inconsistent communication, guidance and direction.

Recommendation

Articulate a long-term strategy for engaging the private sector and coordinating across headquarters, the regions and the field in future disaster responses. The strategy should be consistent with ESF-14 and build on the lessons learned from the pandemic.

Key Finding

Project Airbridge expedited essential supplies from the global market to domestic supply chains to respond to shortages. The deficit revealed limitations in FEMA’s identification of mission critical resources and understanding of the related complexities and interdependences in the end-to-end supply chain.

Project Airbridge reduced the transit time between manufacturer and customer from 30–45 days via ocean freight to about five days. Over a span of 92 days, Project Airbridge delivered roughly 1.73 billion units of PPE and medical supplies.

Recommendation

Build capability for monitoring and understanding business and industry supply chains and develop plans for aligning the resource management required for national catastrophic events to build greater pre-incident insight and inform awareness of gaps or trends that require mitigation.

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Supporting State, Local, Tribal and Territorial Partners

The COVID-19 response operations were locally executed, state/tribe managed and federally supported. FEMA’s established operational relationships provided an effective national framework for the federal government to serve and support state, local, tribal and territorial (SLTT) partners.

Key Finding

FEMA Integration Teams (FITs) and Incident Management Assistance Teams—Advance (IMAT-As) provided valuable planning and resource coordination support to SLTT partners.

  • FIT and IMAT members answered inquiries, connected partners to FEMA stakeholders and also supported SLTT partners responding to other natural disasters during COVID-19.
  • However, issues with staffing, training, deployment and systems access impeded some teams’ ability to support SLTT authorities as effectively as they could have.

Recommendation

Continue the rollout and resourcing of FITs—including embedding FITs within all states and territories—ensuring the full rollout of multiple FITs for each state and territory and consider how FITs can be used to support tribal partners. Regions may also want to consider cross-training with IMAT positions to increase flexibility in the event of another multi-regional emergency.

Key Finding

Relationships between tribal nations and FEMA differed across regions, which led to variation in response efforts in an already unprecedented event.

  • There were 91 COVID-19 tribal nation recipient agreements, 172 sub-recipient agreements under state declarations and one major disaster declaration for the Seminole Tribe of Florida.

Recommendation

Develop a tribal nation engagement strategy, supported by consistent staffing and training, that includes the desired outcomes and resources required to appropriately support the tribal nations, with flexibility for regional application.

Key Finding

The federal government expedited funding to state, local, tribal and territorial (SLTT) partners, deferring the determination of funding sources that led to varying, and often unclear, cost-share requirements at the time those resources were provided.

  • In addition to FEMA’s Disaster Relief Fund, funding streams from multiple HHS agencies and four supplemental appropriations bills were applicable to COVID-19 expenditures.
  • As a result, compliance was complicated and confusing. The regions worked closely with SLTT partners to move toward resolution of funding stream confusion.

Recommendation

Continue developing and expanding roadmaps, searchable libraries and comprehensive funding matrices, complete with respective cost-sharing schemes, to allow SLTTs to determine the best approach to cost recovery, while helping FEMA staff provide guidance and support effectively like those produced during the COVID-19 operations.

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Preparedness and Information Analysis

Federal pandemic planning did not account for the large-scale interagency operations, resource shortages and integrated federal approach to supporting state, local, tribal and territorial (SLTT) partners required to respond to this pandemic.

Although current pandemic plans identify information requirements, they lack the specificity and guidance to establish data collection and reporting mechanisms for effective decision-making.

Key Finding

Federal plans did not envision FEMA leading the federal response for national pandemic operations, and neither headquarters nor the regions had current, comprehensive plans for a leading role, limiting the efficiency of applying the agency’s operational capability.

Recommendation

The agency should review, revise and develop plans for headquarters and regions, commensurate to the roles, that account for learning from the COVID-19 operations.

Key Finding

Without refined data requirements, independent approaches to data collection and analysis increased the number of requests to FEMA regions and SLTT and private sector partners.

Recommendation

Develop an implementation plan for improved data application to disaster operations that considers non-governmental data management and applications and allocate resources to pursue identified courses of action to improve data-driven operations. Examine the planning approach to data management and analytics based on preparedness-driven requirements and lessons learned from past disasters. FEMA should assess existing data systems, analysis and products for their usability and effectiveness in informing and guiding senior leadership decision-making before, during and after disasters.

Key Finding

FEMA’s current situational awareness reporting products limit data sharing and data-driven decision-making.

Recommendation

Develop an agency intelligence unit that works across the enterprise at headquarters and in the regions in preparedness and operations to gather data, analyze information, build tools and advise leadership.

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Organizational Resilience

The COVID-19 pandemic directly challenged FEMA’s ability to maintain its organizational resilience as it faced anticipated and unanticipated disruptions to its internal operations and supporting mission requirements. Agency leadership took several actions to preserve the workforce and ensure continuity of programs and staffing in this complex environment, requiring exceptional cross-agency collaborations.

The pandemic also presented unique challenges to FEMA’s processes, including how guidance was messaged, decisions were made and programs were delivered, all while sustaining critical agency operations. It forced the agency to enable a virtual workforce and identify new strategies for using technology. COVID-19 also affected how the agency protected its people, from preventing the spread of the virus in its workplaces to addressing the workforce’s emotional and physical health.

Key Finding

Even though FEMA did not activate its Continuity of Operations (COOP) plan, the agency leveraged its Pandemic Annex and continuity tactics for workforce protection; however, using continuity nomenclature in agency messaging caused confusion about how programs and resources should be prioritized.

Recommendation

Identify a FEMA component or office responsible for analyzing steady-state programmatic work and recommending a process for FEMA leadership to prioritize agency activities when the COOP plan is not activated and the effects do not require only conducting Mission Essential Functions, but the steady-state resources must be adjusted to support significant operational response or recovery requirements.

Key Finding

Through a shift in resources and workforce innovation, FEMA was largely able to adapt, deliver programs and carry out the mission while operating in the COVID-19 environment.

Recommendation

Institutionalize successful program and policy adaptations and build implementation plans to ensure efficiencies are not lost in the return to steady-state agency operations.

Key Finding

FEMA implemented and enhanced protective measures over time to protect the health and safety of the workforce; however, the agency experienced challenges implementing and ensuring compliance with these measures nationwide.

Recommendation

Develop a comprehensive agency-wide strategy and guidance for workforce protection.

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