HOMELAND SECURITY EXERCISE AND EVALUATION PROGRAM (HSEEP)

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N

ATIONAL

E

XERCISE

P

ROGRAM

H

OMELAND

S

ECURITY

E

XERCISE AND

E

VALUATION

P

ROGRAM

(HSEEP)

All National Exercise Program (NEP) exercises must be conducted in accordance with the Homeland Security Exercise and Evaluation Program (HSEEP) doctrine and requirements. The NEP HSEEP doctrine was developed with an awareness of the Department of Defense (DoD) exercise programs and strives to incorporate valuable features. The purpose of HSEEP is to provide common exercise policy and program guidance that constitutes a national standard for exercises. HSEEP includes consistent terminology that can be used by all exercise planners, regardless of the nature and composition of their sponsoring agency or organization. HSEEP provides tools to help exercise managers plan, conduct, and evaluate exercises to improve overall preparedness. HSEEP reflects lessons learned and best practices from existing exercise programs and can be adapted to the full spectrum of hazard scenarios and incidents (e.g., natural disasters, terrorism, technological disasters).

Summary of Findings

The Analysis of Federal Requirements Team conducted cooperative discussions with 20 States regarding their perceptions of HSEEP. The majority (90%) of the respondents believed HSEEP is a positive program and improves preparedness by increasing standardization, requiring train-ing, exercise critique, continuous improvement, and guidelines for evaluation and reporting. Each of the jurisdictions were asked to reply to a series of questions pertaining to reporting requirements, timeline requirements, grant guidance, grant approval process, resource require-ments, and program summary issues.

Reporting Requirements

Of the States surveyed, a little more than half responded that the frequency of the reporting requirements was not a concern. Those that believed they were a concern stated it was a significant problem when there were multiple exercises. They stated the requirements were too time-consuming, overly detailed, and lengthy. The majority of the States felt the entire reporting process should be scaled back and simplified. The majority felt the National Exercise Schedule (NEXS) is far too detailed and do not believe After-Action Reports (AARs) need to be completed for drills. Lastly, there is a genuine concern that much of the detail required by program guidelines is never used for any significant purpose.

Timeline Requirements

Twenty-five percent (25%) of the States reported the timelines were acceptable. The remaining 75% of the States did not answer the question or said the timeline requirements were not accept-able. States reported that staffing shortages at the State level and part-time staff at the local level make reporting in a timely manner difficult. They also cited there are too many elements that

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require reporting and documentation. Finally, they recommended more than 60 days be allowed for the development of the AARs. They recommend between 90 to 120 days be given for AARs.

Grant Guidance

Of the States answering this question, a narrow majority found the guidance not overly lengthy; however, some commented that it includes too much boilerplate information and that one volume with multiple stratified chapters would be preferable. HSEEP guidance is currently contained in four volumes, is more than 600 pages long, and is too complex to use effectively. A common theme from the States is a lack of consistency in the guidance. One State remarked that the “ideology is not consistent even if the methodology is.” States are concerned with the late issuance of guidance and that important HSEEP guidance often appears in Information Bulletins, which take effect immediately with little or no vetting by States.

Grant Approval Process

Six States (30%) indicated the grant approval process did not apply to HSEEP. One stated the HSEEP is not a grant, but use of HSEEP is a requirement in multiple grants.

Resource Requirements

The majority (17) of the States have identified a need for more personnel to administer the HSEEP program. Three States felt the staffing levels were sufficient to administer the program. No funding is tied to HSEEP as it is a requirement, not a grant program.

The average requirement for a full-scale exercise is 0.5 of a full-time equivalent (FTE) for each exercise. For States conducting multiple full-scale exercises in a year, this quickly adds up to more manpower than may be available. Some States commented that the HSEEP program is so complicated they must use contractors for regional and State-level exercises that they formerly planned, conducted, and evaluated themselves. They also find the program is labor-intensive in training personnel in the use of HSEEP standards. In addition, States believe they cannot justify the expenditure of funds for personnel to manage and administer the program and still run a viable exercise. Personnel are borrowed with minimal training products being produced because exercise support is not their primary responsibility.

Program Summary Issues

Ninety percent (90%) of the States believed HSEEP improves preparedness by increasing standardization, requiring training, exercise critique, continuous improvement, and guidelines for evaluation and reporting. The large majority (90%) of States said HSEEP supports their State Homeland Security Strategy by supporting training and exercises of critical missions and plans in their strategy. Some commented they felt pressured to make their strategy line up with the Federal guidance to the detriment of the focus on State hazards and risk. Two States also com-mented on the fact that the workload associated with understanding and administrating HSEEP discourages small and volunteer communities/departments from exercising—exactly the opposite

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and two others agreed, “…the exercise design and planning processes are too complicated, and the exercise reporting requirements are simply unfeasible for large numbers of jurisdictions.” There were a significant number of recommendations provided focused on addressing the issues raised above.

Program Requirements Impacting

State Emergency Management/Homeland Security Agencies

1. Reporting Requirements

a. Is the frequency of the reporting requirements a concern of the State?

Yes 8 No 12

Of the States surveyed, a little more than half responded that the frequency of the reporting requirements was not a concern. Those that felt they were a concern stated it was a real problem when there were multiple exercises. In that regard, one State had scheduled six full-scale exercises in the next 8 months. These States felt the requirements were too time-consuming, overly detailed, and lengthy.

b. Are there any unnecessary reporting requirements?

Yes 13 No 5 Unanswered 2

The majority of the States felt HSEEP requirements are too demanding and should be scaled back. They said some of the local authorities were questioning the value of the program when they measure the money involved with the time-consuming requirements. The majority felt NEXS is far too detailed and they do not like the requirement to fill out AARs for drills. Lastly, there is a genuine concern that a lot of the detail sought is never used for any significant purpose.

c. Are any of these reporting requirements covered in other Federal program requirements?

Yes 12 No 8

Those States that felt they were covered elsewhere cited the Centers for Disease Control and Prevention (CDC), Assistant Secretary for Preparedness and Response, DoD, Department of Transportation (DOT), Environmental Protection Agency (EPA), the National Guard; grants such as the Chemical Stockpile Emergency Preparedness Program; programs such as the National Incident Management System and Emergency Management Accreditation Program; and any agency that conducts exercises. They also made a point of the difficulty in coordinating private hospital exercises.

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d. Is the electronic reporting submittal process for this program a concern?

The assessment tool collected data in four categories:

• 20% of the respondents said it takes too long to input data. • 15% indicated they had system availability issues.

• 10% indicated they have lost data previously entered. • 15% have experienced the system timing out during use.

One State said NEXS should make reporting easier as it is further developed. Many concerns centered around the perception that DHS replaced FEMA’s 4-page report with HSEEP’s reporting requirements, which are more than 75 pages in length and are so detailed that many question their value and purpose. There are also concerns about the difficulty in obtaining passwords and the frequency that the exercise reporting system is not operational. Lastly, there is a feeling that the Corrective Action Plan (CAP) require-ment is too labor-intensive.

e. Suggested improvements.

Suggested improvements included the following:

• Consider going back to the original FEMA reporting system. • Have more training for NEXS.

• Make NEXS more user-friendly with a better password system and by allowing other agencies to use the system.

2. Timeline Requirements

a. Are timeline requirements acceptable for submitting the program application?

There is no application required for this program.

b. Are timeline requirements acceptable for Investment Justification plans?

Yes 3 No 1 Unanswered 4 N/A 12

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c. Are timeline requirements acceptable for financial reporting?

No specific financial report is required for HSEEP.

d. Are timeline requirements acceptable for program reporting?

Forty-five percent (45%) of the responding States reported the timelines were acceptable. The remaining 15 States did not answer the question or said the timeline requirements were not acceptable. The following comments were reported:

• Staffing shortages at the State level and part-time staff at the local level make reporting in a timely matter difficult.

• There are too many exercise elements that must be reported. • States need more than 60 days to prepare AARs.

e. Are there other timeline issues?

Other timeline issues reported on included the following: • NEXS is not always available for exercise reporting. • Timelines for reporting, in general, are not realistic. • There should not be a requirement to report on drills.

f. What recommended improvements do you have regarding the timeline requirements? Recommended improvements included the following:

• Provide additional funding for personnel if this current level of reporting is needed by the Federal Government.

• HSEEP should be promoted as a tool, not a mandate. • Provide additional time for AARs, from 90 to 120 days. • Reduce the volume of information required for the reports.

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3. Grant Guidance

a. Is the grant guidance too lengthy?

Of the States answering this question, a majority found the guidance not too lengthy. Two of these States, however, commented it is still filled with boilerplate information and that one volume with multiple stratified chapters would be preferable. States that agreed the guidance was too long commented it is voluminous with four volumes and 600 pages.

b. Is the grant guidance understandable?

The majority of States answering believed the guidance to be understandable. While a favorable response was noted from 35% of the responding States, one State asked if the guidance was doctrine or a set of best practices, while another said it was basically under-standable. One unfavorable State remarked that compliance is a moving target and most requirements are promulgated without warning in HSEEP new volumes or Information Bulletins.

c. Is the grant guidance consistent?

A common theme from the States is a lack of consistency in the guidance. One State remarked the “ideology is not consistent even if the methodology is.” Another State was critical of the process based on the use of the new Capabilities-Based Preparedness model while using the old emergency responder guidance methodology. They believe this caused wasted time, effort, and now must be accomplished with fewer resources.

d. Is the grant guidance timely?

Of the four questions posed to the States regarding grant guidance, the issue of timeliness was described as the most troublesome. States criticized the fact that Information

Bulletins are used as announcements and that program requirements took effect immediately. Even though the States knew the changes were going to take place, they were surprised the four HSEEP volumes were not published incrementally. Another critical comment reported was that there is no defined schedule corresponding to the grant performance period on which to base future requirements; rather, a random, ad hoc, ill-defined process without expected outcomes.

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e. Are there other grant guidance issues?

Other grant guidance issues included the following:

• There are too many gray areas that imply rather than clearly require certain actions and documentation.

• If the Federal Government expects States and local jurisdictions to follow four volumes of exercise requirements, funding should be supplied to ease such an administrative burden.

f. Any recommended changes for grant guidance improvement? Recommended changes to grant guidance included the following:

• Use FEMA Regional staff expertise to deliver technical assistance rather than various outside entities with varying levels of expertise.

• Regions should focus on their States and promote cross-training among the State exercise officers.

• HSEEP should be used as a tool and not a mandate.

• Reports should not be required unless it can be shown to be a benefit to the State. • Write the guidance clearer so it is not subject to much unnecessary interpretation. • Actual events should be allowed as exercise credits if documented.

• Allow easier access to NEXS and CAP Web sites. • Ensure all Federal agencies are using HSEEP. • Consolidate HSEEP into one volume.

4. Grant Approval Process

a. Do you have any concerns regarding the length of the grant approval process?

All but one State either said “No” or left the question unanswered. Six States indicated the grant approval process did not apply to HSEEP. One stated HSEEP is not a grant, but use of HSEEP is a requirement in multiple grant programs.

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b. If used, is the Peer Review an acceptable process?

Yes 2 No Unanswered 18

Eighteen of the States (90%) left the question about the acceptability of the Peer Review process unanswered.

c. Are there other grant approval process issues?

All of the States responded to the question of other grant approval process issues either with a “No,” “not applicable,” or left the question unanswered.

d. Do you have any recommended improvements to the grant approval process for the program?

None of the States recommended any improvements to the HSEEP grant approval process.

5. Resource Requirements

a. How many full-time equivalents (FTEs) are required to administer this program?

Table 9 represents a composite summary of data collected from 11 States (six small, three

medium, and two large) for the HSEEP program.

Table 9. Average FTE HSEEP Staff for 11 States for Program/Operations and M&A

Each State was asked the following three questions:

1. How many State staff are believed to be required to fully accomplish the objectives of the program? 2. How many State staff are currently assigned to program and operational duties?

3. How many State staff are currently assigned to accomplish M&A?

Small Population States (<3 million)

Medium Population States (3 to 10 million)

Large Population States

(>10 million) Total Staff Required Current Program Staff Current M&A Staff Shortage or Need Total Staff Required Current Program Staff Current M&A Staff Shortage or Need Total Staff Required Current Program Staff Current M&A Staff Shortage or Need Average FTE 8 3 0 5 7 1 0 6 17 2 1 14

HSEEP is not a grant and has no specific funding. All 11 States reported staff assigned to meet the current requirements of the HSEEP. Additionally, all States indicated the need for more staff to fully implement the program.

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b. Number of FTEs currently assigned to this program.

Table 10 represents a composite summary of data collected from nine States (two small,

four medium, and three large) for the HSEEP program.

Table 10. Average FTE HSEEP Staff for 9 States for M&A Staff Only

Each State was asked the following three questions:

1. How many State staff are believed to be required to solely manage and administer (M&A) the program? 2. How many State staff currently assigned to M&A are paid by State funds?

3. How many State staff currently assigned to M&A are federally funded by the grant M&A allocations?

Small Population States (<3 million)

Medium Population States (3 to 10 million)

Large Population States (>10 million) Total M&A Required Current State M&A Current Federal M&A Shortage or Need Total M&A Required Current State M&A Current Federal M&A Shortage or Need Total M&A Required Current State M&A Current Federal M&A Shortage or Need Average FTE 3.6 1.4 0.2 2 3 1.7 0 1.3 14 12.2 0.7 1.1

No Federal funding is specifically associated with HSEEP; therefore, its full

implementation will require some level of Management and Administrative (M&A) resources provided by the States. States are already committing on average 1 to 12 FTEs for HSEEP administration, and most States are reporting a need for additional personnel.

c. If the FTEs required to administer this program are less than the FTEs currently assigned, why is there a difference?

Several variables affect the difference between the number of FTEs assigned to the program and the number required. In those States that had a requirement for additional personnel, the primary reasons are noted below.

No funding is tied to HSEEP as it is a requirement, not a grant program.

The average requirement for a full-scale exercise is 0.5 FTE for each exercise. For States conducting multiple full-scale exercises in a year, this quickly adds up to more manpower than is available.

Many States have part-time emergency managers that do not have the capability to provide the reporting required under HSEEP.

The HSEEP program is so complicated that States are using contractors for regional and State-level exercises that the States formerly planned, conducted, and evaluated.

States cannot justify the expenditure of funds for personnel to manage and administer the program and still run a viable exercise. Borrowed personnel frequently tend to make minimal contributions.

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Some States cannot hire staff with available Federal funds because of State-imposed hiring caps. This results in money being available for temporary personnel/contractors, but not for hiring full-time personnel. Contractors are used to offset personnel requirements as they can be hired on a yearly contract and are not affected by State personnel caps.

d. Are additional non-personnel resources needed to accomplish this program?

Yes 10 No 10

Additional non-personnel resources are required for the successful accomplishment of the HSEEP program. These resources include the following:

• States need exercise design modeling programs tailored for all-hazards rather than just terrorism-based exercises.

• States have a need for computers and training to allow local jurisdictions to input HSEEP reporting requirements. This is especially important as reports must be filed electronically into NEXS and CAP systems.

• States need an increase in office supplies as exercise plans and reports generate many paper reports. Additionally, exercise material such as badges, desktop flags, banners, easels, and flip charts are required to conduct exercises.

• States would like HSEEP funding to hire qualified contractors having the capability to develop, design, conduct, and evaluate exercises.

• States have identified travel as a non-personnel requirement. To administer the program properly, additional travel funds to various local jurisdictions are needed to plan and conduct exercises.

• States require HSEEP funding for facility rental for exercises.

• States need HSEEP funding to cover backfill and overtime costs created by exercises. e. Other issues related to the personnel/resources for this program.

The States have identified other related issues that affect and are related to the program: • States need upgraded computers and data transfer tools at the local government

levels.

• The States find it is labor intensive to train personnel to use and report using HSEEP standards.

• The HSEEP has too broad of a scope for the resources available.

• The States need more full-time support. In many States, especially rural States, few of the local jurisdictions have the luxury of full-time emergency managers.

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• There have been dramatic cuts in Homeland Security Grant Program (HSGP) funding in the last 2 years. This translates to staff being reduced by a third or more. Knowledgeable, competent personnel are essential to mentor local responders during exercises.

f. Recommended improvements for the personnel/resources for this program. The States recommended several important considerations for the HSEEP program that could improve personnel and other resourcing:

• States feel personnel need to be eligible for funding to administer the HSEEP program.

• States would like a regional exercise representative to coordinate the FEMA exercise program, which then will allow the States to take advantage of the NEP.

6. Program Summary Issues

a. Does this program improve preparedness in your State?

Yes 18 No 2

The HSEEP improves preparedness by increasing standardization, requiring training, exercise critique, continuous improvement, and guidelines for evaluation and reporting. It supports seminars and exercises in each private sector functional area, which is new and significant. Readiness is improved by use of Improvement Plans/After-Action Reviews and CAPs. Checklists encourage evaluators to follow a standard and are valuable. It fosters continuous improvement.

One State commented that, as a program, it is redundant with requirements in HSGP and could be rolled into it.

Four States commented that the number of reported exercises is declining and there is motivation not to admit to conducting exercises because of the inherent workload required of staff if you do. This workload takes people away from other critical duties. They requested consideration for modifying the work and reporting required of small jurisdic-tions who exercise limited numbers of responders and equipment in small exercises. One State said, “The four volumes of HSEEP simply cannot be understood or imple-mented by smaller cities, counties, and emergency response organizations that lack a dedicated emergency management staff. At a time when local governments should be conducting more exercises to test plans…the number of exercises conducted…has declined dramatically since HSEEP was implemented.”

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b. Does this program support your State’s Homeland Security Strategy?

Yes 18 No 2

The large majority of States said HSEEP supports their State Strategy by supporting training and exercises of critical missions and plans in their strategy.

Two States said they felt pressured to make their strategy line up with the Federal guidance to the detriment of focusing on State hazards and risks.

Two States also commented on the fact that the workload associated with understanding and administrating HSEEP discourages small and volunteer communities/departments from exercising—exactly the opposite effect desired.

c. Does the program support the National Preparedness Goal?

Yes 19 No 1

The majority of States agreed the program supports the National Preparedness Goal. The Target Capabilities List, Universal Task List, training, and exercise programs all support goal achievement, replied one State.

One State again commented on the reduction in exercises related to workload associated with HSEEP.

d. Are there any program requirements or items related to this program not previously discussed?

Yes 9 No 11

The exercising of plans, the evaluating of exercises, and the developing of CAPs are universally seen as good and supportive of enhancing preparedness activities.

The HSEEP is seen as too broad and with too many requirements. As one State said, and two others agreed, “the exercise design and planning process is too complicated and the exercise reporting requirements are simply infeasible for large numbers of jurisdictions.” Another State said the program was being micromanaged and, since training and exercises come out of separate accounts, they are more difficult to manage. The Emergency

Management Performance Grant (EMPG) and HSEEP both support exercises; HSEEP could be combined with the EMPG. Again, the point was made by two States that drills should not be covered by the same administration and reporting requirements as major exercises. One asked what, if anything, was being done with all the AARs being collected.

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e. What recommendations for improvement does the State have for this program? The recommendations follow the comments above:

• Consolidate and simplify reporting requirements. Eliminate drills from the require-ments and develop a graduated scale to relieve small jurisdictions and departrequire-ments, especially volunteer departments, from some of the administration requirements. • Fund exercises and adequate numbers of staff to manage the program. Permit use of

funds for hurricane exercises for hurricane-prone States. • Increase the training and exercise support in regions.

• Offer exercise credit for response to actual events when documented, an AAR is con-ducted, and a CAP is developed and implemented.

• Use a single password for all programs. Once in the system, allow for movement to different sites and time for completion of entries. The CAP, while a good concept, is too manpower intensive.

• Check grant guidance and HSEEP for consistency.

f. Has the State identified any other requirements from Federal agencies other than DHS and FEMA that can be associated with or related to this program?

The Department of Health and Human Services through CDC has initiated significant exercise requirements that, of necessity, involve State and local organizations. HSEEP should have common requirements and tools with CDC. Exercises are routine for many Federal agency programs such as hazardous materials with EPA and DOT; radiological materials with the Nuclear Regulatory Commission, FEMA, DoD, and the Department of Energy; and port security exercises with the U.S. Coast Guard.

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HSEEP

P

ROGRAM

Y/N

C

OUNT

S

UMMARY

W

ORKSHEET

Summary Small States

(8 Sites Surveyed)

Medium States

(7 Sites Surveyed)

Large States

(5 Sites Surveyed)

# AFR Impact/Response (Template 3) Y/N Criteria Yes No N/A U Yes No N/A U Yes No N/A U Yes No N/A U

10. Reporting Requirements

A. Is the frequency of the reporting requirements a concern of the State? 8 12 0 3 5 0 4 3 0 1 4 0 C. Are there any unnecessary reporting requirements? 13 5 2 7 1 0 3 2 2 3 2 0 E. Are any of these reporting requirements covered in other Federal Program

requirements? 12 8 0 7 1 0 3 4 0 2 3 0 G. Is the electronic reporting submittal process for this program a concern? 12 5 3 6 1 1 2 3 2 4 1 0

11. Are Timeline Requirements acceptable for submitting:

A. The application for this program? 4 3 13 1 2 5 2 1 4 1 0 4 C. Investment Justification plan? 3 1 12 4 2 0 6 0 0 1 4 2 1 0 2 2 E. Financial reporting? 5 2 13 2 1 5 2 1 4 1 0 4 G. Program reporting? 5 6 9 2 4 2 2 1 4 1 1 3

12. Is the Grant Guidance:

A. Too lengthy? 5 7 8 1 4 3 1 2 4 3 1 1 C. Understandable? 7 5 8 3 2 3 3 0 4 1 3 1 E. Consistent? 4 8 8 1 4 3 1 2 4 2 2 1 G. Timely? 2 8 10 0 5 3 1 2 4 1 1 3

13. Grant Approval Process:

A. Do you have any concerns regarding the length of the Grant approval process? 1 8 11 0 5 3 0 3 4 1 0 4 C. Is used, is the Peer Review an acceptable process? 2 0 18 0 0 8 1 0 6 1 0 4

14. Resource Requirements:

E. Are additional non-personnel resources needed to accomplish this program? 10 10 0 5 3 0 3 4 0 2 3 0

15. Program Summary Issues:

A. Does this program improve preparedness in your State? 18 2 0 8 0 0 6 1 0 4 1 0 C. Does this program support your State’s Homeland Security Strategy? 18 2 0 8 0 0 6 1 0 4 1 0 E. Does this program support the National Preparedness Goal? 19 1 0 8 0 0 6 1 0 5 0 0 G. Are there any program requirements or items related to this program not

previously discussed? 9 11 0 3 5 0 3 4 0 3 2 0

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