GAO-07-609, Emergency Management: Most School Districts Have Developed Emergency Management Plans, but Would Benefit from Additional Federal Guidance


This is the accessible text file for GAO report number GAO-07-609 
entitled 'Emergency Management: Most School Districts Have Developed 
Emergency Management Plans, but Would Benefit from Additional Federal 
Guidance' which was released on June 12, 2007. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as part 
of a longer term project to improve GAO products' accessibility. Every 
attempt has been made to maintain the structural and data integrity of 
the original printed product. Accessibility features, such as text 
descriptions of tables, consecutively numbered footnotes placed at the 
end of the file, and the text of agency comment letters, are provided 
but may not exactly duplicate the presentation or format of the printed 
version. The portable document format (PDF) file is an exact electronic 
replica of the printed version. We welcome your feedback. Please E-mail 
your comments regarding the contents or accessibility features of this 
document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

June 2007: 

Emergency Management: 

Most School Districts Have Developed Emergency Management Plans, but 
Would Benefit from Additional Federal Guidance: 

GAO-07-609: 

GAO Highlights: 

Highlights of GAO-07-609, a report to congressional requesters 

Why GAO Did This Study: 

Congress has raised concerns over emergency management in school 
districts, with a particular interest in how federal agencies provide 
assistance to school districts. GAO was asked to assess (1) the roles 
of federal and state governments and school districts in establishing 
requirements and providing resources to school districts for emergency 
management planning, (2) what school districts have done to plan and 
prepare for emergencies, and (3) the challenges, if any, school 
districts have experienced in planning for emergencies, and 
communicating and coordinating with first responders, parents, and 
students. To obtain this information, GAO interviewed federal 
officials, surveyed a stratified random sample of all public school 
districts, surveyed state education agencies and state administering 
agencies, conducted site visits to school districts, and reviewed 
relevant documents. 

What GAO Found: 

Although there are no federal laws requiring all school districts to 
have emergency management plans, most states and school districts 
reported having requirements for such planning, and federal and state 
governments and school districts provide financial and other resources. 
Thirty-two states reported having laws or other policies requiring 
school districts to have emergency management plans. The Departments of 
Education (Education) and Homeland Security (DHS) and state governments 
as well as school districts provide funding for emergency management 
planning in schools. DHS awards grants to states and local 
jurisdictions that may provide some of these funds to school districts 
and schools for emergency management planning. However, DHS program 
guidance for certain grants does not clearly identify school districts 
as entities to which state and local governments may disburse grant 
funds. Thus, states receiving DHS funding may not be aware that such 
funding could be allocated to school districts or schools. Most school 
districts have taken federally recommended steps to plan and prepare 
for emergencies, including the development of emergency management 
plans, but many plans do not include recommended practices. Based on 
GAO’s survey of school districts, most school districts, those with and 
without plans, have undertaken a variety of recommended practices to 
prepare for emergencies such as conducting school drills and exercises. 
In addition, based on GAO’s survey of school districts, an estimated 95 
percent of all school districts have written emergency management 
plans, but the content varies. While most school districts have 
procedures in their plans for staff roles and responsibilities, for 
example, school districts have not widely employed such procedures as, 
academic instruction via local radio or television, for continuing 
student education in the event of an extended school closure, such as 
might occur during a pandemic. Likewise, while many districts have 
procedures for special needs students, GAO found during site visits 
that some of these procedures may not fully ensure the safety of these 
students in an emergency. Finally, while most school districts practice 
their emergency management plans annually within the school community, 
GAO estimates that over one-quarter of school districts have never 
trained with any first responders and over two-thirds of school 
districts do not regularly train with community partners on how to 
implement their school district emergency management plans. Many school 
districts experience challenges in planning for emergencies, and some 
school districts face difficulties in communicating and coordinating 
with first responders and parents, but most do not have such challenges 
with students. Based on GAO’s survey of school districts, in many 
school districts officials struggle to balance priorities related to 
educating students and other administrative responsibilities with 
activities for emergency management and consider a lack of equipment, 
training for staff, and personnel with expertise in the area of 
emergency planning as challenges. In an estimated 39 percent of school 
districts with emergency management plans, officials experienced a lack 
of partnerships, limited time or funding to plan, or lack of 
interoperability between equipment used by school districts and first 
responders. In interviews, about half of the officials in the 27 school 
districts GAO visited reported difficulty in ensuring that parents 
received consistent information from the district during an emergency. 

What GAO Recommends: 

GAO is making several recommendations to DHS, Education, and HHS aimed 
at improving school district emergency management planning and 
preparation. Education and HHS generally agreed with GAO’s 
recommendations. DHS generally agreed with the intent of GAO’s 
recommendations. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-609]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Cornelia Ashby at (202) 
512-7215 or ashbyc@gao.gov or William O. Jenkins, Jr. at (202) 512-8757 
or jenkinsw@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Many States and School Districts Reported Having Requirements for 
Emergency Management Plans, and Federal and State Governments and 
School Districts Provide Resources for Emergency Management Planning: 

Most Districts Have Taken Steps to Prepare for Emergencies and 
Developed Written Plans, but Some Plans Do Not Address Recommended 
Practices: 

School Districts Report Challenges in Planning for Emergencies as Well 
as Difficulties in Communicating with First Responders and Parents, but 
No Challenges in Communicating with Students: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Survey of States: 

Survey of School Districts: 

Site Visits: 

Appendix II: Emergency Management Planning Requirements: 

Appendix III: Homeland Security Funding Provided to School Districts: 

Appendix IV: Guidance, Training, and Funding States Provided to School 
Districts: 

Appendix V: Comments from the Department of Homeland Security: 

Appendix VI: Comments from the Department of Education: 

Appendix VII: Comments from the Department of Health & Human Services: 

Appendix VIII: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Estimated Frequency of School Districts' Review of Schools' 
Emergency Management Plans: 

Table 2: Estimated Number of School Districts That States Reported 
Providing Homeland Security Funding during Fiscal Years 2003-2006: 

Table 3: Examples of Guidance, Training, and Equipment the Federal 
Government Provides to School Districts: 

Table 4: Selected Practices That Education, DHS, and HHS Recommend 
School Districts Take to Prepare for Emergencies: 

Table 5: Key Elements in Emergency Management Plan Templates by 
Percentage of School Districts with Written Emergency Management Plans: 

Table 6: Types of Security Enhancements School Districts Made Based on 
Vulnerability Assessments: 

Table 7: Activities School Districts Have Taken Responsibility for to 
Prepare for Emergencies: 

Table 8: Estimated Percentage of School Districts That Have Procedures 
for Communicating with Limited-English Proficient Parents and Students 
in Their Emergency Management Plans: 

Table 9: Percentage of School Districts That Use the Following 
Procedures for Students with Special Needs in the Event of an 
Emergency: 

Table 10: Types of Recovery Procedures Addressed in School Districts 
Written Emergency Management Plans: 

Table 11: Percentages of School Districts with Written Plans That 
Include Certain Types of Procedures to Continue Student Educational 
Instruction in the Event of an Extended School Closure: 

Table 12: Percentage of School Districts That Involve Stakeholders in 
the Development and Update of Written Emergency Management Plans: 

Table 13: Frequency of Updates to Emergency Management Plans: 

Table 14: Estimated Frequency of Training with Each Type of First 
Responder on How to Implement the School District Emergency Management 
Plan: 

Table 15: Description of the Population and Sample of Districts: 

Table 16: School Districts Interviewed or Visited during Site Visits: 

Table 17: States Reporting Selected Requirements for School Districts 
or Schools for Emergency Management Planning: 

Table 18: States That Reported Providing Homeland Security Funding 
Directly to School Districts: 

Table 19: States and the District of Columbia That Reported Provided 
Homeland Security Funding to School Districts through Local 
Jurisdictions during Fiscal Years 2003--2006: 

Table 20: States and the District of Columbia That Reported Providing 
Resources to School Districts to Assist in Emergency Management 
Planning: 

Figures: 

Figure 1: States That Reported Having Laws or Other Policies Requiring 
School Districts or Schools to Have Emergency Management Plans: 

Figure 2: Estimated Differences in Types of Security Enhancements Made 
by Urban and Rural Districts Based on Vulnerability Assessments: 

Figure 3: Estimated Differences in Types of Activities Undertaken by 
Urban and Rural Districts to Prepare for Emergencies: 

Figure 4: Estimated Percentages of Urban and Rural Districts' Multi- 
Hazard Emergency Management Plans That Include Specific Incidents: 

Abbreviations: 

CBSA: Core Based Statistical Area: 
CCD: Common Core Data: 
CDC: Centers for Disease Control and Prevention: 
CSA: Consolidated Statistical Area: 
DHS: Department of Homeland Security: 
Education: Department of Education: 
EMS: Emergency Medical Services: 
ERCM: Emergency Response and Crisis Management: 
FEMA: Federal Emergency Management Agency: 
HHS: Health and Human Services: 
ICS: Incident Command System: 
IDEA: Individuals with Disabilities Education Act: 
LEP: Limited-English Proficient: 
NIMS: National Incident Management System: 
NOAA: National Oceanic & Atmospheric Administration: 
SHSP: State Homeland Security Program: 
SRO: School Resource Officer: 
UASI: Urban Areas Security Initiative: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

June 12, 2007: 

The Honorable Joseph Lieberman: 
Chairman: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Bennie Thompson: 
Chairman: 
Committee on Homeland Security: 
House of Representatives: 

The Honorable Bob Etheridge: 
The Honorable Sheila Jackson-Lee: 
House of Representatives: 

Maintaining the safety and security of the over 49 million students in 
the nation's more than 17,000 public school districts has been a focus 
of federal, state, and local government for years. Federal and state 
governments and school districts have generally focused on crime in and 
around schools and violence among students. However, school districts 
must be prepared for a range of emergencies within and outside of 
school buildings. Events such as the terrorist attacks of September 11, 
2001, natural disasters such as Hurricanes Katrina and Rita in 2005, 
recent shootings by armed intruders in schools across the nation, and 
potential pandemics have heightened the awareness of the range of 
events for which schools should be prepared. In addition, environmental 
and other types of hazards can exist in areas near school districts. 
For example, school buildings can reside near nuclear plants, electric 
power plants, railways that transport hazardous materials, major 
airports, or major interstates. 

"Emergency management" refers to the range of efforts involved in 
building the capacity to prevent, protect against, respond to, and 
recover from an incident. Planning for such incidents vary by the type 
and scale of the incident. The federal government's role in emergency 
management is principally to support state and local activities and 
develop the federal capabilities to respond effectively when state and 
local governments require federal assistance. Some federal support 
comes in the form of guidance and recommendations. Because the federal 
government serves as a partner to all states, it is uniquely positioned 
to observe and evaluate the range of emergency management activities 
across states and local governments, including school districts, and 
disseminate information on recommended practices and successful 
strategies. In addition, the federal government, largely through the 
Department of Homeland Security (DHS), provides billions of dollars 
each year in grants and other forms of assistance to help state and 
local emergency managers and first responders (such as law enforcement, 
fire departments, and emergency medical services). Other agencies such 
as the Departments of Education (Education) and Health and Human 
Services (HHS) also play a part in supporting state and local emergency 
management activities with regard to education and public health, 
respectively. 

Emergency management for large-scale incidents generally requires 
partnerships among federal, state, and local governments, nongovernment 
organizations, and the private sector. For example, school districts 
may need the assistance of other organizations, including 
nongovernmental ones, in evacuating schools and finding shelter for 
students when an earthquake renders a school structurally unsafe. 

The Congress has raised concerns about whether school districts are 
prepared to address a range of emergencies, particularly acts of 
terrorism, and how three federal agencies--DHS, Education, and HHS-- 
provide assistance to school districts. In addition, the Congress has 
expressed an interest in getting a better understanding of whether 
school districts have emergency management plans that address the needs 
of students and parents who are classified as Limited-English 
Proficient (LEP), and students with special needs such as those with 
mental, physical, motor, developmental, or sensory impairments. 

In response to your request to examine the state of emergency 
management in the nation's school districts, this report addresses the 
following questions: (1) What are the roles of federal and state 
governments and school districts in establishing requirements and 
providing resources to school districts for emergency management 
planning? (2) What have school districts done to plan and prepare for 
emergencies? (3) What challenges, if any, have school districts 
experienced in planning for emergencies and communicating and 
coordinating with first responders, parents, and students? 

To obtain the information to address our research objectives, we 
conducted interviews, surveys, site visits to school districts, and 
reviews of relevant documents and laws identified through surveys and 
site visits. To determine the roles and requirements of federal and 
state governments and the types of resources provided to districts, we 
conducted interviews with officials with Education, HHS, and DHS and 
reviewed relevant federal laws. We also administered two surveys, one 
to state education agencies and one to state administering agencies 
(the state agencies to which DHS disburses emergency management 
funding[Footnote 1]) in all 50 states and the District of Columbia. We 
received responses from 49 of 51 state education agencies and from 40 
of 51 state administering agencies. In the survey to state 
administering agencies, we asked specifically about whether states or 
local governments provided school districts with federal funding from 
the State Homeland Security Program (SHSP), Urban Areas Security 
Initiative (UASI), and Citizen Corps grants.[Footnote 2] To better 
understand how school districts plan and prepare for emergencies, we 
administered a mail survey to a stratified random sample of school 
districts in the 50 states and the District of Columbia. We used the 
Department of Education's locale coding system in the Common Core Data 
(CCD) to identify urban and rural school districts. Locale codes are 
based on the specific conditions of schools and refer to very small 
geographic areas and circumstances, such as population density and 
size. Although several criteria are used by Education to classify 
school districts including the percentage of students located in 
particular locale codes (assigned to individual schools), generally, 
urban districts are located within "large" (equal to or greater than 
250,000 population) or "mid-sized" (less than 250,000 population) 
cities and rural districts are located in areas designated as rural by 
the Census Bureau. Appendix I includes a more detailed discussion of 
how urban and rural districts are defined in the CCD. We received 444 
of the 554 surveys we mailed to school districts for a response rate of 
80 percent, including responses from 24 of the 26 largest school 
districts in the country. Using a 95 percent confidence interval, all 
percentage estimates included in this report have a margin of error of 
plus or minus 10 percent or less, unless otherwise noted. We did not 
survey individual schools within school districts. To further 
understand the experiences districts have had in planning for 
emergencies and communicating and coordinating with first 
responders[Footnote 3], parents, and students, we visited selected 
districts in the states of Florida, Iowa, Massachusetts, North 
Carolina, Ohio, and Washington. We selected a geographically diverse 
group of states and school districts, some of which had been identified 
by national education associations as having implemented recommended 
practices in the area of emergency management, some that did and others 
that did not receive federal funding for emergency management, and we 
included both urban and rural districts. In total, we conducted semi- 
structured interviews, either in person or by telephone, with officials 
in 27 school districts. For more detailed information on our scope and 
methodology, see appendix I. Our work was conducted between April 2006 
and April 2007 in accordance with generally accepted government 
auditing standards. 

Results in Brief: 

Although there are no federal laws requiring all school districts to 
have emergency management plans, most states and school districts 
reported having requirements for such planning, and federal and state 
governments and school districts provide financial and other resources 
for such plans. Thirty-two states reported having laws or other 
policies requiring school districts to have emergency management plans. 
Based on our survey, we estimate that 85 percent of school districts 
have requirements for school emergency management planning. Education, 
DHS, and state governments as well as school districts provide funding 
for emergency management planning in schools. DHS awards grants to 
states and local jurisdictions that may provide some of these funds to 
school districts and schools for emergency management planning. 
However, DHS program guidance for the State Homeland Security Program, 
Urban Areas Security Initiative, and Citizen Corps grants does not 
clearly identify school districts as entities to which state and local 
governments may disburse grant funds; therefore, some states receiving 
DHS funding may be uncertain as to whether such funding can be 
allocated to school districts or schools. As a result, school districts 
in these states may not have the opportunity to benefit from this 
funding. Federal and state governments and school districts also assist 
school districts and schools in emergency management planning by 
providing other resources such as guidance, training, and equipment. 
However, in some instances, federal guidance does not include detailed 
information on how school districts can implement recommended 
practices. 

Most school districts have taken federally recommended steps to plan 
and prepare for emergencies including the development of emergency 
management plans; while the content of plans vary, many do not include 
recommended practices. Based on our survey of school districts, we 
found that most school districts, those with and without plans, have 
undertaken a variety of recommended practices to prepare for 
emergencies such as conducting inspections to identify potential 
vulnerabilities of school facilities and grounds and holding school 
drills and exercises. In addition, we estimate that 95 percent of all 
school districts have written emergency management plans. Nearly all of 
those plans address multiple hazards such as natural disasters, 
intruders, and bombs but few address pandemic influenza or radiological 
hazards. The content of school district plans varies significantly. 
While most school districts have outlined roles and responsibilities 
for staff in their plans, for example, over half of all school 
districts with emergency management plans have not employed procedures 
for continuing student education in the event of an extended school 
closure, such as might occur during a pandemic. Likewise, while many 
districts have procedures for special needs students, we found during 
our site visits that procedures vary in the extent to which they ensure 
the safety of special needs students in an emergency. A higher 
percentage of urban school districts' plans included procedures for 
special needs students and for communicating with Limited-English 
Proficient parents and students compared to rural districts. Fewer than 
half of all school districts have involved the local head of government 
and fewer than half involved the local public health agency in the 
development of their plans. While half of all school districts update 
their emergency management plans at least once a year, an estimated 10 
percent had never updated their plans. Finally, while most school 
districts practice their emergency management plans annually within the 
school community, we estimate that over one-quarter of school districts 
have never trained with first responders and over two-thirds of school 
districts do not regularly train with community partners on how to 
implement their school district emergency management plans. The reasons 
why school districts do not train with first responders or community 
partners are not readily apparent. 

Many school district officials said that they experience challenges in 
planning for emergencies and some school districts face difficulties in 
communicating and coordinating with first responders and parents, but 
most said that they do not experience challenges in communicating with 
students. Based on our survey of districts, we estimate that in 70 
percent of all school districts, officials struggle to balance 
priorities related to educating students and other administrative 
responsibilities with activities for emergency management. For example, 
in some of the districts we visited, administrators were reluctant to 
allocate teacher development training time to emergency management 
because of other training priorities. In an estimated 62 percent of all 
school districts, officials identified challenges stemming from a lack 
of equipment, training for staff, and personnel with expertise in the 
area of emergency planning. Officials noted that a lack of equipment 
and expertise can impact many aspects of emergency management, 
including planning for special needs students. For example, a school 
district official in Washington said that the district lacks equipment 
to evacuate special needs students from some school buildings and in 
some cases staff are unsure of how to operate the existing equipment. 
Officials also reported problems in communicating and coordinating with 
first responders and parents. In an estimated 39 percent of school 
districts with emergency management plans, officials experienced a lack 
of partnerships, limited time or funding to discuss planning with first 
responders, or lack of interoperability between equipment used by 
school districts and first responders. About half of the officials in 
the 27 school districts we interviewed reported difficulty in ensuring 
that parents received consistent information from the district during 
an emergency. Some of these officials also described problems in 
communicating emergency-related information to Limited-English 
Proficient parents. 

To address issues related to the emergency management of school 
districts, we recommend that (1) DHS clearly identify school districts 
as entities to which state and local governments may disburse grant 
funds in its program guidance for the State Homeland Security Program, 
Urban Areas Security Initiative, and Citizen Corps programs to ensure 
that states and local governments are aware that they can disburse 
funding to school districts and still meet funding requirements; (2) 
Education, in collaboration with DHS and HHS, provide guidance to 
school districts on successful procedures for sheltering and evacuating 
special needs students during emergencies; (3) Education collaborate 
with HHS to provide specific guidance to states and school districts on 
how to incorporate, in emergency management plans, procedures for the 
continuation of education in the event of extended school closures such 
as those that might occur in the case of a pandemic (such as pandemic 
influenza); and (4) DHS and Education identify the factors that prevent 
school districts, first responders, and community partners from 
training together, develop strategies for addressing those factors, and 
promote current efforts that can help school districts in this area. 

We provided copies of this report to DHS, Education, and HHS for review 
and comment. DHS generally agreed with the intent of our 
recommendations but suggested additional language regarding the need to 
promote the use of current resources in efforts to increase school 
district training with first responders and community partners, which 
we incorporated. DHS's comments are in appendix V. In its comments on 
the draft report, Education generally agreed with our recommendations. 
Education's comments are in appendix VI. Finally, HHS generally agreed 
with our recommendations and asked that we include HHS in our 
recommendation that federal agencies provide additional guidance 
related to special needs students, which we accepted. HHS's comments 
are in appendix VII. 

Background: 

Federal Role in Emergency Management: 

The Homeland Security Act of 2002 created DHS and consolidated most of 
the federal programs and agencies with responsibilities for emergency 
management into that agency.[Footnote 4] DHS serves as a federal 
partner to state and local governments in emergency 
management.[Footnote 5] DHS provides technical assistance and homeland 
security grant funding to states and local governments to enhance their 
emergency management efforts. States and local governments have the 
responsibility for spending DHS grant funds in accordance with DHS 
guidelines to meet local emergency management needs. In fiscal year 
2006, DHS awarded $1.7 billion to states, urban areas, and territories 
to prepare for and respond to terrorist attacks and other disasters. 
States and local governments may then provide a portion of this funding 
to a range of entities, as specified in DHS's program guidance. 

As we have noted in prior reports, emergency management requires 
coordinated planning and implementation by a variety of participants. 
Effective emergency management requires identifying the hazards for 
which it is necessary to be prepared (risk assessments); establishing 
clear roles and responsibilities that are effectively communicated and 
well understood; and developing, maintaining, and mobilizing needed 
capabilities, such as people, skills, and equipment.[Footnote 6] The 
plans and capabilities should be tested and assessed through realistic 
exercises that identify strengths and areas that need improvement, with 
any needed changes made to both plans and capabilities. 

The hazards that school districts may face will vary across the country 
depending upon the natural hazards to which their particular areas are 
prone and an assessment of other risks for which they need to be 
prepared, such as pandemic influenza or the discharge of hazardous 
substances from nearby chemical or nuclear plants. Similarly, who 
should be involved in emergency planning and response for schools, and 
the roles of the various participants will vary by type and size of the 
emergency incident. For large-scale emergencies, effective response is 
likely to involve all levels of government--federal, state, and local-
-nongovernment entities, such as the Red Cross, and the private sector. 

Funding of School Districts: 

The responsibility for funding K-12 education rests primarily with 
state and local governments. Approximately 90 percent of spending on 
education comes from state, local, and private funds. The federal 
government contributes approximately 8 to 10 percent. School districts 
are responsible for spending the funds in accordance with applicable 
federal, state, and local laws. However, the formulas states use to 
determine how to fund school districts and the actual amount of funding 
states and local governments spend on education can vary. 

Many States and School Districts Reported Having Requirements for 
Emergency Management Plans, and Federal and State Governments and 
School Districts Provide Resources for Emergency Management Planning: 

Although no federal laws exist requiring all school districts to have 
emergency management plans, most states and school districts reported 
having requirements for school emergency management planning, and 
federal and state governments and school districts provide financial 
and other resources for such planning. Education, DHS, and state 
governments as well as school districts provide funding for emergency 
management planning in schools. However, DHS program guidance does not 
clearly identify school districts as entities to which states and local 
governments may disburse grant funds. Not all states receiving DHS 
funding are aware that such funding could be disbursed to school 
districts. In addition to providing funding, federal and state 
governments and school districts assist school districts and schools in 
emergency management planning by providing other resources such as 
guidance, training, and equipment. 

Although No Federal Laws Exist Requiring Emergency Management Planning, 
the Majority of States and School Districts Have Requirements: 

Although there are no federal laws requiring all school districts to 
have emergency management plans, many states reported having laws or 
other policies that do so. Congress has not enacted any broadly 
applicable laws requiring all school districts to have emergency 
management plans, nor have federal agencies issued any regulations 
imposing such a requirement on all school districts. However, the No 
Child Left Behind Act of 2001 provides that local education agencies 
(LEAs or school districts) applying for subgrants under the Safe and 
Drug Free Schools and Communities Program include in their grant 
applications an assurance that either they or their schools have "a 
plan for keeping schools safe and drug-free that includes.a crisis 
management plan for responding to violent or traumatic incidents on 
school grounds."[Footnote 7] Thirty-two states reported having laws or 
other policies requiring school districts or schools to have a written 
emergency management plan (see fig. 1). 

Figure 1: States That Reported Having Laws or Other Policies Requiring 
School Districts or Schools to Have Emergency Management Plans: 

[See PDF for image] 

Source: GAO analysis of survey data; (Map) Map Resources. 

[End of figure] 

Several state laws identify a broad range of specific emergencies that 
schools or districts are required to address in their plans, while many 
other states do not identify particular kinds of crises or use more 
general language to refer to the kinds of emergencies that plans must 
incorporate. For example, districts in Indiana are required to develop 
plans that address, at a minimum, fire; natural disasters such as 
tornadoes, floods, and earthquakes; adverse weather conditions, such as 
winter storms or extreme heat; nuclear contamination from power plants 
or vehicle spills; exposure to chemicals from a variety of sources; and 
manmade occurrences, such as student disturbances, weapons, weapons of 
mass destruction, water or air supply contamination, and hostage and 
kidnapping incidents. In contrast, some states, such as Pennsylvania, 
South Dakota, and Texas, among others, do not identify any specific 
hazards in their planning requirements. 

State emergency planning requirements also vary in their degree of 
prescriptiveness regarding plan development and emergency preparedness. 
For example, a number of states, including Georgia and Ohio, require 
that schools or districts involve partners, such as first responders, 
other community leaders, parents, and teachers in the planning process. 
Likewise, some states, such as Illinois and Nevada, specifically 
require that plans be reviewed annually and updated as appropriate. 
Additionally, New Jersey and other states require districts and schools 
to provide relevant district and school officials with periodic 
training related to emergency plans. In comparison, the requirements of 
some states, such as Oregon and Washington, are less detailed. For more 
detailed information on state emergency planning requirements, see 
appendix II. 

Many of the school districts we surveyed also reported having emergency 
management planning requirements for schools. Based on our survey of 
school districts, we estimate that 85 percent of all districts require 
schools to have their own written emergency management plans. Of these 
districts, 88 percent require that school plans be submitted to them 
for review. However, the frequencies of these reviews vary (see table 
1). 

Table 1: Estimated Frequency of School Districts' Review of Schools' 
Emergency Management Plans: 

Frequency of school district review: At least once a year; 
Percentage estimate of school districts conducting review: 71. 

Frequency of school district review: At least once every 2 years; 
Percentage estimate of school districts conducting review: 7. 

Frequency of school district review: At least once every 3 years; 
Percentage estimate of school districts conducting review: 13. 

Frequency of school district review: Other; 
Percentage estimate of school districts conducting review: 5. 

Frequency of school district review: Do not review; 
Percentage estimate of school districts conducting review: 4. 

Source: GAO analysis of survey data. 

[End of table] 

Federal Agencies, State Governments, and School Districts Provide 
Funding for School Districts' Emergency Management Planning: 

Education provides funding to some school districts specifically for 
emergency management planning through its Emergency Response and Crisis 
Management (ERCM) Grant Program.[Footnote 8] Since fiscal year 2003, 
Education dispersed $130 million in such grants to over 400 of the over 
17,000[Footnote 9] school districts in the United States. These grant 
awards ranged from $68,875 to $1,365,087. For example, in fiscal year 
2004, Seattle Public Schools received an ERCM grant for $494,144 to 
train principals in using the Incident Command System (ICS)[Footnote 
10] and to establish Web-based training, among other things. In Tampa, 
Florida, a school district used a fiscal year 2006 ERCM grant of 
$487,424 to install a new radio system and sponsor faculty workshops on 
emergency response. Other uses reported by school districts we visited 
include establishing emergency management plans, installing equipment 
such as closed circuit televisions, training school administrative 
staff (such as principals) on the National Incident Management System 
(NIMS) and the ICS, and purchasing emergency backpacks for school 
nurses. 

DHS also provides funding to states and local jurisdictions for 
emergency management planning, and some of this funding can be provided 
to school districts or schools for emergency management planning. DHS 
officials told us that such funds are available through the State 
Homeland Security Program (SHSP), Urban Areas Security Initiative 
(UASI), and Citizen Corps grants. Five states--Florida, Hawaii, 
Michigan, Mississippi, and Wyoming--reported that they provided 
approximately $14 million in DHS funding directly to school districts 
in these states during fiscal years 2003-2006 (see table 2). Florida, 
for example, provided about $4.3 million in SHSP funds over a 2-year 
period to selected school districts for training, upgrading the 
districts' emergency communications, and controlling access to school 
facilities, as well as for conducting studies related to emergency 
management. In fiscal year 2003, Michigan provided $8.6 million in SHSP 
funds to 488 of its 801 school districts to conduct planning exercises 
in response to potential terrorist events. 

Table 2: Estimated Number of School Districts That States Reported 
Providing Homeland Security Funding during Fiscal Years 2003-2006: 

Fiscal year: 2006; 
Estimated number of school districts[A]: 72. 

Fiscal year: 2005; 
Estimated number of school districts[A]: 85. 

Fiscal year: 2004; 
Estimated number of school districts[A]: 70. 

Fiscal year: 2003; 
Estimated number of school districts[A]: 536. 

Source: GAO analysis of state administering agencies survey data. 

[A] States may have funded the same school districts over multiple 
years. 

[End of table] 

In addition, eight states and the District of Columbia reported that 
they provided DHS funding to local jurisdictions that then provided a 
portion of these funds to school districts or schools for emergency 
management planning.[Footnote 11] For example, South Dakota officials 
told us they awarded a portion of the state's fiscal year 2006 SHSP 
funds to South Dakota's local counties. These officials said that the 
counties then provided approximately $26,000 to 3 of the state's 176 
school districts for emergency management planning efforts. Although 
Oklahoma did not respond to our survey of state administering agencies, 
in February 2007, officials from its Office of Homeland Security issued 
a press release and confirmed to us that it provided $50,000 of DHS 
funding (SHSP) to five elementary schools to enhance those schools' 
physical security. They said that each school received a $10,000 grant 
to purchase equipment such as cameras, magnetometers, concrete 
barriers, identification systems, and two-way radios. For additional 
information on DHS funding that states or their local jurisdictions 
provided to school districts, see appendix III. 

Although DHS officials told us that some of its emergency planning 
grant programs, such as SHSP, UASI, and Citizen Corps allow for the use 
of funds at the district or school level, the department's program 
guidance does not clearly specify that school districts are among the 
entities to which state and local governments may disburse 
funds.[Footnote 12] As a result, some states may not be aware of their 
availability. For example, state officials in Alaska and Iowa told us 
they were not aware that DHS emergency planning grants could be used by 
school districts. School districts in these states do not have the 
opportunity to benefit from this funding. In Vermont, one official 
expressed the view that DHS program guidance is unclear on the 
permissible use of these funds. 

Eleven of the 49 states[Footnote 13] responding to surveys we sent to 
state education and state administering agencies reported providing 
state funding to school districts for emergency management planning 
(see app. IV for a listing of these states). For example, the 
Connecticut State Department of Education reported that its State 
Legislature provided $180,000 for emergency management training in its 
state. Of these funds, the state disbursed $30,000 to each of 
Connecticut's six education centers to train schools within its region, 
according to its Department of Education.[Footnote 14] To use this 
funding, the Connecticut State Department of Education reported that 
each education center was required to provide a minimum of three full- 
day workshops that were open to any school in its respective region. 
Hawaii also reported providing approximately $2.1 million to 62 of its 
285 schools[Footnote 15] to assist those schools in contracting for the 
services of School Safety Managers (mainly retired law enforcement 
officers) in developing school emergency response plans during fiscal 
years 2003-2005. 

In the absence of federal and state sources, schools have been relying 
on local school district funds for the emergency management planning 
that they have undertaken. Three school districts we visited reported 
that they provided funding for emergency management planning in 
schools. Officials from a school district in Ohio, Shaker Heights, said 
that school emergency management activities are funded from the school 
district's general fund. These school district officials told us they 
spent about $100,000, not including staff hours and pay, to undertake 
emergency management planning. To help prepare for an emergency, 
officials in Olmsted Falls, Ohio, said that the school district bought 
one automated external defibrillator[Footnote 16] for each of its 
buildings. Finally, officials from Sequim School District in Washington 
told us that they spent $70,000 from their general funds to install a 
camera system at one of the two elementary schools located in their 
district. 

Federal Agencies, State Governments, and School Districts also Provide 
Guidance, Training, and Equipment: 

The federal government also provides guidance, training, and equipment 
to school districts to assist in emergency management planning (see 
table 3). 

Table 3: Examples of Guidance, Training, and Equipment the Federal 
Government Provides to School Districts: 

Examples of Guidance: 
* Education publishes a guide for schools and communities titled 
Practical Information on Crisis Planning, which explains, among other 
things, how schools can prepare for an emergency; 
* Education created the Emergency Response and Crisis Management 
Technical Assistance Center to help school districts in emergency 
management planning. The center provides guidance to school districts 
through such activities as sharing examples of emergency management 
plans, assisting with training staff, and evaluating emergency 
management plans; 
* DHS created a Web site, How Schools Can Become More Disaster 
Resistant, that provides guidance for teachers and parents regarding 
how to prepare emergency management plans. The site also discusses 
identifying and mitigating hazards, developing response and coping 
plans, and implementing safety drills; 
* Education funded the development of the National Clearinghouse for 
Educational Facilities--Disaster Preparedness for Schools. This Web 
site provides a list of resources (links, books, and journal articles) 
regarding building or retrofitting schools to withstand natural 
disasters and terrorism, developing emergency preparedness plans, and 
using school buildings to shelter community members during emergencies; 
* The Secret Service, an agency within DHS, collaborated with Education 
in developing and publishing a Threat Assessment Guide for Schools. The 
guide was developed following the Columbine High School attack in April 
1999. Secret Service and Education jointly produced and disseminated a 
CD-ROM that served as a companion to this guide. 

Examples of Training: 
* The Federal Emergency Management Agency (FEMA), within DHS, offers 
online courses including one on emergency management planning for 
schools; 
* Education offers two 1-½ day Emergency Management for Schools 
training sessions that provide school personnel with critical training 
on emergency management issues, resources, and practices. Emphasis for 
these trainings is placed on emergency management plan development and 
enhancement within the framework of four phases of emergency 
management: prevention and mitigation, preparedness, response, and 
recovery. 

Examples of Equipment: 
* With funding from DHS and support from Education, the Department of 
Commerce's National Oceanic & Atmospheric Administration (NOAA) 
distributed 96,000 NOAA radios to almost all public schools in the 
United States in 2005 and 2006. These radios are intended to notify 
school officials of hazards in their area 24 hours a day/7 days a week, 
even when other means of communication are disabled.[A]. 

Source: Education, DHS, and HHS. 

[A] Schools receiving NOAA radios included schools in six states that, 
according to DHS, mandate that public schools have radios. These states 
are Washington, Tennessee, North Carolina, Maryland, Florida, and 
Mississippi. DHS told us that they have procedures in place to allow a 
school to request a radio if it did not receive one. DHS officials also 
told us that they plan to distribute NOAA radios to non-public schools 
(private, independent, parochial and other faith-based institutions), 
postsecondary education facilities, and district offices in 2007. 

[End of table] 

Education, DHS, and HHS have collaborated and developed recommended 
practices to assist in preparing for emergencies that can be applied to 
school districts.[Footnote 17] Some of these practices are shown in 
table 4. 

Table 4: Selected Practices That Education, DHS, and HHS Recommend 
School Districts Take to Prepare for Emergencies: 

Recommended practices: 
* Allocate time to emergency management planning; 
* Conduct an assessment of vulnerabilities; 
* Conduct regular drills; 
* Identify and acquire equipment to mitigate and respond to 
emergencies; 
* Identify a storage location and replenish emergency supplies on a 
regular basis; 
* Develop an emergency management plan and update the plan on a regular 
basis. In developing and updating this plan, school districts should: 
- Identify and address a range of events and hazards specific to the 
district or schools; 
- Develop roles and responsibilities and procedures for school 
community members; 
- Develop roles and responsibilities for first responders and community 
partners; 
- Develop procedures for communicating with key stakeholders such as 
parents and students, including those who are Limited-English 
Proficient; 
- Develop procedures for special needs students; 
- Develop procedures in the plan for recovering from an incident, 
including continuing student education during an extended school 
closure; 
- Determine lessons learned after an incident or training; 
- Develop multi-purpose manuals, with emergency management information, 
that can be tailored to meet individual school needs; 
* Include community partners such as local government and public health 
agencies in planning; 
* Coordinate the school district's emergency procedures with state and 
local governments; 
* Practice the emergency management plan with first responders and 
community partners on a regular basis. 

Source: GAO analysis of Education, DHS, and HHS guidance and training 
documents. 

[End of table] 

We have also recognized the importance of certain of these practices in 
our prior reports on emergency management.[Footnote 18] For example, a 
central component of all emergency management plans is defining the 
roles and responsibilities of all those with responsibilities for 
preparing to respond to an emergency. These roles should be clearly 
established, communicated, and understood. We have also emphasized the 
value of identifying the types of hazards for which school districts 
should be prepared as part of their emergency management efforts. These 
hazards will vary across the country; thus, it is appropriate that 
school emergency plans include hazards specific to their area. In 
addition, we have recognized the importance of realistic training 
exercises followed by a careful assessment of those exercises. Those 
with whom the school districts should coordinate and train will vary by 
the type and size of the emergency. For example, for a potential 
pandemic flu or other major infectious outbreak, planning and working 
with local health authorities and others is critical. Furthermore, 
"after action" reports that assess what went well and what did not go 
well following real emergency incidents or exercises, can also 
contribute to improving emergency management. 

The type of guidance available from the federal government on topics 
related to emergency management in schools varies significantly; in 
some instances federal agencies provide detailed instructions on how to 
implement recommended practices while in other instances, guidance is 
less detailed. For example, HHS and its Centers for Disease Control and 
Prevention (CDC) developed recommended practices with regard to 
pandemics and provides school districts with specific recommended steps 
for planning and coordination, infection control policies and 
procedures, and communications planning. While it also recommends that 
school districts plan for the continuity of student learning, its 
guidance does not provide specific recommended steps or examples of 
successful strategies. Rather, it broadly states that schools should 
develop scenarios involving short-and long-term school closures. 
Likewise, Education's guidance to school districts, through its 
recommended practices, clearly states that districts should incorporate 
procedures for special needs students in emergency management plans. 
However, Education does not provide guidance on or examples of what 
those procedures could be. 

In addition to the federal government, states provide guidance and 
training to school districts. Based on our survey of state 
administrative agencies and state education agencies, 47 states 
reported providing guidance and 37 states reported providing training. 
Some states also reported providing online resources that include 
guidance and training. (See app. IV for a listing of these states.) For 
example: 

* Guidance. South Dakota's Department of Education provides guidance on 
how to distribute food during a crisis or emergency event that may 
occur at schools. 

* Training. The Maryland Department of Education offers periodic 
workshops for school system points-of-contact for emergency planning on 
topics such as threat assessment and pandemic flu. 

* Online Resources. The Idaho Department of Education provides links on 
its Web site to FEMA's course on emergency planning for schools and 
Education's Emergency Response and Crisis Management Technical 
Assistance Center. 

Many of the school districts we surveyed also reported providing their 
schools with guidance to assist in emergency management planning. For 
example, based on our survey, we estimate that 73 percent of all school 
districts have an emergency management plan template that includes key 
elements schools should include in their plans (see table 5). 

Table 5: Key Elements in Emergency Management Plan Templates by 
Percentage of School Districts with Written Emergency Management Plans: 

Templates includes: School Campus Plan; 
Estimated percentage of school districts: 95. 

Templates includes: Potential use of school facilities; 
Estimated percentage of school districts: 93. 

Templates includes: School level emergency management team members; 
Estimated percentage of school districts: 94. 

Templates includes: Procedures for communication with law enforcement; 
Estimated percentage of school districts: 94. 

Templates includes: Procedures for contacting district-level incident 
response team; Estimated percentage of school districts: 92. 

Templates includes: ICS positions and staff; 
Estimated percentage of school districts: 76. 

Templates includes: Includes special needs student population; 
Estimated percentage of school districts: 67. 

Source: GAO analysis of survey data. 

[End of table] 

Most Districts Have Taken Steps to Prepare for Emergencies and 
Developed Written Plans, but Some Plans Do Not Address Recommended 
Practices: 

Almost all school districts have taken steps to prepare for 
emergencies, including developing written plans, but some plans lack 
key elements such as procedures for special needs students, plans for 
continued student education in the event of an extended closure, and 
procedures for training regularly with first responders. Most 
districts, those with and without plans, have undertaken a variety of 
federally-recommended activities, such as conducting vulnerability 
assessments and school drills and exercises, as well as additional 
activities to prepare for an emergency such as oversight and 
coordination with other entities. While most districts have written 
emergency management plans that address a range of hazards such as 
intruders, bombs, and natural disasters, the content of plans varies. 
Although most school districts have plans that include roles and 
responsibilities for staff, few have procedures for continuing student 
education in the event of an extended school closure. Many districts 
have procedures in their plans for special needs students, but these 
procedures vary in their ability to fully ensure the safety of these 
students during an emergency. Fewer than half of all school districts 
involved a representative from the local head of government and fewer 
than half involved the local public health agency in the development 
and updating of their emergency management plans. Finally, we estimate 
that over one-quarter of school districts with emergency management 
plans have never trained with first responders and over two-thirds of 
school districts do not regularly (i.e., at least once a year) train 
with community partners on how to implement their school plans. 

Most School Districts Have Undertaken Some Emergency Management 
Activities: 

Based on our survey of school districts, we estimate that 93 percent of 
all school districts conduct inspections of their school buildings and 
grounds to identify possible vulnerabilities in accordance with 
recommended practices. Of those school districts, 87 percent made 
security enhancements to their school facilities and grounds as a 
result of these inspections. (See table 6.) 

Table 6: Types of Security Enhancements School Districts Made Based on 
Vulnerability Assessments: 

Type of security enhancement implemented: Added or enhanced equipment 
to communicate with school employees; 
Estimated percentage of school districts: 85. 

Type of security enhancement implemented: Strengthened the perimeter 
security of school; 
Estimated percentage of school districts: 70. 

Type of security enhancement implemented: Made inventory changes such 
as removing hazardous materials; 
Estimated percentage of school districts: 69. 

Type of security enhancement implemented: Enhanced access controls; 
Estimated percentage of school districts: 68. 

Type of security enhancement implemented: Added or enhanced equipment 
to communicate with law enforcement, fire department, and emergency 
medical service officials; 
Estimated percentage of school districts: 41. 

Type of security enhancement implemented: Reduced number of portable 
classrooms; 
Estimated percentage of school districts: 10. 

Source: GAO analysis of survey data. 

[End of table] 

A higher percentage of urban school districts have made certain types 
of security enhancements to schools in their districts as a result of 
these assessments compared with rural school districts. (See fig. 2.) 

Figure 2: Estimated Differences in Types of Security Enhancements Made 
by Urban and Rural Districts Based on Vulnerability Assessments: 

[See PDF for image] 

Source; GAO analysis of survey data. 

Note: Margins of error for rural estimates do not exceed 11 percent. 

[End of figure] 

Based on our survey of school districts, an estimated 73 percent of all 
school districts regularly conduct some type of school drill or 
exercise, in alignment with recommended practices to prepare for 
emergency situations such as evacuations, lockdowns, and shelter-in- 
place. During our site visits, we learned that drills were tailored to 
the needs of the local community and varied by locality. For example, 
in Iowa state that is prone to tornados district officials said the 
state requires schools to practice tornado drills twice a year. In 
Washington state that is prone to earthquakes district officials stated 
they practice earthquake drills twice a year or more. 

Our survey of school districts revealed that an estimated 65 percent of 
all school districts have a storage location and replenish emergency 
supplies such as food, water, and first-aid supplies, as recommended. 
During our site visits, school district officials identified a variety 
of equipment, supplies, and storage for different types of emergencies. 
In Renton, Washington, officials reported storing backpacks in the 
classrooms that contain enough food, water, medical supplies, and 
flashlights, among other items, for a short-term emergency. For an 
extended emergency, each school has a supply of emergency gear that 
includes: a 2-to 3-day supply of water, thermal blankets, sanitation 
needs, and energy bars. Similarly, school district officials we visited 
in Des Moines, Iowa, stated they have two kits for different types of 
emergencies. The first kit, designed for school nurses to use in 
evacuations, is a duffel bag containing medical supplies such as: 
bandages, splints, face masks, and eye patches, as well as equipment 
such as: folding stretcher, blood pressure kit, stethoscope, and cold 
packs. The second kit, designed for custodians, is a garbage can that 
contains tools as well as supplies such as a broom, gloves, rope, 
water, and bleach, among other items. In contrast, in one Washington 
district the disaster kits contain communication equipment, but they do 
not include supplies of food or water. 

In addition to conducting vulnerability assessments, school drills, and 
maintaining emergency supplies, school districts took responsibility 
for a number of activities to prepare for emergencies at the district 
level. These activities can vary by locality depending on community 
needs and include oversight, coordination with other entities, and 
training. (See table 7.) For example, in Hardee County, Florida 
district that is frequently hit by hurricanes officials stated that the 
county designated the schools as shelters for the public and the school 
district provides staff, such as maintenance and food service 
personnel, to work at the schools as part of a negotiated arrangement. 
Officials in Pinellas County district that is frequently hit by 
tornados and hurricanes told us they have trained an on-site district 
level team that coordinates emergency response activities during an 
emergency or event. 

Table 7: Activities School Districts Have Taken Responsibility for to 
Prepare for Emergencies: 

Type of activity: Ensure school compliance with emergency preparedness 
requirements; 
Estimated percentage of school districts: 74. 

Type of activity: Negotiate arrangements for use of school buildings as 
temporary shelters; 
Estimated percentage of school districts: 72. 

Type of activity: Coordinate agreements with law enforcement, fire 
department, and emergency medical service officials; 
Estimated percentage of school districts: 68. 

Type of activity: Identify security personnel needs at schools; 
Estimated percentage of school districts: 65. 

Type of activity: Identify and train a district-level incident response 
team; 
Estimated percentage of school districts: 62. 

Source: GAO analysis of survey data. 

[End of table] 

As shown in figure 3, a higher percentage of urban districts took 
responsibility for certain types of activities to prepare for an 
emergency compared with rural districts. 

Figure 3: Estimated Differences in Types of Activities Undertaken by 
Urban and Rural Districts to Prepare for Emergencies: 

[See PDF for image] 

Source: GAO analysis of survey data. 

[A] Differences between urban and rural districts are not statistically 
significant. 

[End of figure] 

Most Districts Have Emergency Management Plans That Address Multiple 
Hazards, but the Content of Plans Varies Significantly: 

Most school districts have developed written emergency management plans 
that address multiple hazards. Based on our survey of school districts, 
we estimate that 95 percent of all school districts have written 
emergency management plans with no statistical difference between urban 
and rural districts.[Footnote 19] Of those school districts that have 
written emergency plans, nearly all (99.6 percent) address multiple 
hazards in accordance with recommended practices to prepare for 
emergencies. However, the specific hazards addressed by plans vary. 
Although most school district plans address emergency situations 
arising from intruders or hostages, bombs or bomb threats, and natural 
disasters, a smaller percentage of school districts address pandemic 
influenza, anthrax, or radiological hazards. A significantly higher 
percentage of urban districts address terrorism and anthrax, for 
example, compared to rural school districts.[Footnote 20] (See fig. 4.) 

Figure 4: Estimated Percentages of Urban and Rural Districts' Multi- 
Hazard Emergency Management Plans That Include Specific Incidents: 

[See PDF for image] 

Source: GAO analysis of survey data. 

[A] Differences between urban and rural districts are not statistically 
significant. 

[End of figure] 

In some instances, the hazards included in emergency plans are specific 
to local conditions which is to be expected. For example, school 
district officials we visited in Hillsborough, Florida, involved 
representatives from the airport in the development of their district 
plan because airport traffic was identified as a unique hazard in their 
local community. In Ashtabula, Ohio, district officials said their plan 
addresses evacuations due to chemical spills because they have a number 
of chemical plants in the community. 

The extent to which school districts emergency management plans are 
consistent with other recommended practices varies: 

Develop Roles and Responsibilities for School Community Members. Based 
on our survey, most districts have written roles and responsibilities 
in their plans for staff such as superintendents, building engineers or 
custodians, principals, teachers, and nurses. Among the plans we 
reviewed, some have more detailed instructions on roles and 
responsibilities than others. For example, school district officials we 
visited in Boston, Massachusetts, have a series of emergency management 
plans for different school community members that included district 
officials, school administrators, and teachers. The school district 
document (the Crisis Command Plan) describes the organizational 
framework and response resources that the district will use to manage 
major emergencies, while a document for school administrators describes 
procedures and resources for school-level incidents. In addition, the 
district issues a classroom emergency guide that outlines procedures 
for teachers to use during an emergency. In contrast, the district plan 
for a district in Iowa lists appropriate actions for specific types of 
emergencies but does not assign roles and responsibilities for their 
implementation. 

Develop Roles and Responsibilities for First Responders and Community 
Partners. Based on our survey, we estimate that 43 percent of school 
districts use the Incident Command System (ICS) established by DHS as 
part of the National Incident Management System (NIMS)[Footnote 21] to 
establish the roles and responsibilities of school district officials, 
local first responders, and community partners during an emergency, in 
accordance with recommended practices. A significantly higher 
percentage of urban school districtsó67 percent were responsible for 
ensuring that their emergency plans were in compliance with DHS's NIMS 
compared to rural school districtsó41 percent. 

Develop Procedures for Communicating with Key Stakeholders. Also 
central to district emergency plans is the inclusion of procedures for 
communicating with key stakeholders such as staff, parents, and 
students, including those who are LEP. Our survey suggests that roughly 
three-quarters of all school districts have not included written 
procedures in their plans for communicating with LEP parents and 
students, in accordance with federally recommended practices. A 
significantly higher percentage of urban school districts report 
including procedures for communicating with such parents and students 
in their plans compared to rural school districts. (See table 8.) This 
difference may, in part, be explained by the relatively fewer LEP 
parents and students in rural school districts. 

Table 8: Estimated Percentage of School Districts That Have Procedures 
for Communicating with Limited-English Proficient Parents and Students 
in Their Emergency Management Plans: 

Limited-English Proficient: Parents; 
All school districts: 27; 
Urban school districts: 59; 
Rural school districts: 18. 

Limited-English Proficient: Students; 
All school districts: 28; 
Urban school districts: 61; 
Rural school districts: 21. 

Source: GAO analysis of survey data. 

[End of table] 

Develop Procedures for Special Needs Students. Although HHS officials 
and some education organizations report that the number of special 
needs students in the schools is growing, our survey finds that an 
estimated 28 percent of school districts with emergency management 
plans do not have specific provisions for them in their emergency 
management plans. Although most school districts reported having 
procedures for special needs students, these procedures were not 
necessarily a part of the written plan. (See table 9.) However, 
Education's guidance recommends not only having procedures for special 
needs students but including these procedures in written emergency 
plans. Officials from two education associations said the lack of 
procedures in district plans for evacuating these students, was a 
significant concern.[Footnote 22] According to these officials, these 
students may be at increased risk during an emergency. During our site 
visits, several school officials who did not have provisions in their 
plans for special needs students said it was a school, not a district- 
level responsibility. District officials in Marshalltown, Iowa, for 
example, said special needs student procedures are the responsibility 
of local schools. However, they said that the district does provide a 
checklist for schools that includes provisions for special needs 
students during an emergency such as communicating to first responders 
the location of special needs students who cannot be evacuated due to 
mobility impairments. A significantly higher percentage of urban school 
districts (77 percent) included procedures for special needs students 
in their written plans compared to rural school districts (62 percent). 
This may be due, in part, to several reasons such as parents of special 
needs students selecting communities to live in based on a district's 
special needs resources or districts with low special needs student 
populations including procedures for these students in individualized 
education programs[Footnote 23] rather than the district plan. 

Table 9: Percentage of School Districts That Use the Following 
Procedures for Students with Special Needs in the Event of an 
Emergency: 

Procedures for special needs students in an emergency: Track the 
location of special needs students during the day; 
Estimated percentage of school districts: 74. 

Procedures for special needs students in an emergency: Identify list of 
district or school staff assigned to evacuate or shelter with special 
needs students during emergency; 
Estimated percentage of school districts: 72. 

Procedures for special needs students in an emergency: Provide devices 
for transporting special needs students to evacuation areas; 
Estimated percentage of school districts: 62. 

Source: GAO analysis of survey data. 

Note: Responses are not mutually exclusive. 

[End of table] 

Education officials told us that because there is no agreement among 
disability groups on what the best practices are for special needs 
students in an emergency, districts usually devise their own 
procedures.[Footnote 24] According to these officials, without the 
recommendation of experts, some of these procedures such as keeping 
special needs students in their classrooms during some emergencies may 
not ensure the students safety in an emergency. The variety of 
procedures was evident during our site visits when officials identified 
several procedures schools use to incorporate the needs of special 
needs students in their plans during an emergency. For example, school 
district officials in Pinellas County, Florida, stated that in order to 
evacuate special needs students during an emergency they use a buddy 
system, comprised of school staff, which the district updates annually. 
In contrast, officials in a Massachusetts school district said special 
needs students must remain in areas of refuge inside the school 
building until they are evacuated by first responders. 

Develop Procedures for Recovering from an Incident. Over half of all 
school districts with written emergency plans include procedures in 
their plans to assist with recovering from an incident, in accordance 
with recommended practices, such as by restoring district 
administrative functions and resuming transportation services. (See 
table 10.) 

Table 10: Types of Recovery Procedures Addressed in School Districts 
Written Emergency Management Plans: 

Type of recovery procedure: Providing on-site trauma teams; 
Estimated percentage of school districts: 64. 

Type of recovery procedure: Restoring district administrative 
functions; 
Estimated percentage of school districts: 55. 

Type of recovery procedure: Resuming transportation services; 
Estimated percentage of school districts: 53. 

Type of recovery procedure: Conducting damage assessments of school 
buildings and grounds; 
Estimated percentage of school districts: 53. 

Type of recovery procedure: Locating district employees after a crisis 
is over; 
Estimated percentage of school districts: 49. 

Source: GAO analysis of survey data. 

[End of table] 

Develop Procedures for the Continuation of Student Education. Few 
school districts' emergency plans contain procedures for continuing 
student education in the event of an extended school closure, such as a 
pandemic outbreak, although it is a federally recommended practice. 
Based on our survey, we estimate that 56 percent of school districts do 
not include any of the following procedures (see table 11) in their 
plans for the continuation of student education during an extended 
school closure. Without such procedures school districts may not be 
able to educate students during a school closure that could last from 
several days to a year or longer. Moreover, there was no statistical 
difference between the percentage of urban and rural school districts 
that include these procedures in their written plans. Some school 
districts we visited stated they do not have these procedures but are 
currently working on developing a continuity of student education plan 
with their community partners, and one district official said he would 
like guidance from the state on how to provide continued instruction to 
students during an extended school closure.[Footnote 25] 

Table 11: Percentages of School Districts with Written Plans That 
Include Certain Types of Procedures to Continue Student Educational 
Instruction in the Event of an Extended School Closure: 

Types of procedure to continue student educational instruction: 
Electronic or human telephone trees to communicate academic information 
to students; 
Estimated percentage of school districts with written plans that 
include procedure: 30. 

Types of procedure to continue student educational instruction: Web- 
based distance instruction; 
Estimated percentage of school districts with written plans that 
include procedure: 12. 

Types of procedure to continue student educational instruction: Mailed 
lessons and assignments; 
Estimated percentage of school districts with written plans that 
include procedure: 10. 

Types of procedure to continue student educational instruction: 
Academic instruction via local radio or television stations; 
Estimated percentage of school districts with written plans that 
include procedure: 7. 

Source: GAO analysis of survey data. 

Note: Responses are not mutually exclusive. 

[End of table] 

Determine Lessons Learned. Based on our survey of school districts, we 
estimate that 38 percent of districts have emergency management plans 
that contain procedures for reviewing lessons learned to analyze how 
well the plans worked in responding to a drill or emergency. Of the 
remaining school districts, 53 percent indicated they have procedures 
but those procedures are not included in their plans and 7 percent have 
no such procedures. 

Develop Multi-Purpose Manuals. Some school districts have multi-purpose 
manuals that contain various types of information such as roles and 
responsibilities for staff, descriptions of how to respond to different 
types of emergencies, as well as site specific information for 
individual schools to complete in order to tailor their plan. For 
example, in Lee County, North Carolina, the district manual contained a 
range of materials and documents for schools to use and complete such 
as floor plans, student and faculty rosters, bus routes, and evacuation 
routes as well as instructions on the location and handling of 
utilities, such as gas and water valves and electrical breaker panels 
in school buildings, including a place for photographs for their easy 
identification. The manual also identified different types of hazards 
and delineated administrator and teacher responsibilities for different 
types of emergencies. In contrast, one plan for a district in 
Washington consisted of a flipchart with contact information on whom to 
call during an emergency, and one plan for a district in Iowa consisted 
of actions to take for various hazards but did not outline which staff 
would be responsible for taking such actions. 

About Half of All Districts Involved Local Government, Public Health 
Agencies, and Other Partners in Developing and Updating Their Plans and 
Most Reported Not Practicing with First Responders: 

School districts differed in the extent to which they involve community 
partner stakeholders in the development and updating of their 
plans.[Footnote 26] Fewer than half of school districts with emergency 
management plans involve community partners such as the local head of 
government (43 percent) or the local public health agency (42 percent) 
when developing and updating their emergency management plans, as 
recommended by HHS.[Footnote 27] During our site visits and survey 
pretests, school district officials cited a number of reasons for this 
lack of involvement, including a general lack of coordination with 
local government on emergency management efforts. Officials cited 
several benefits in coordinating with local government entities 
including the opportunity to share information, take part in joint 
training exercises, and receive assistance with their emergency plans. 

While most school districts include at least one representative from 
the school and first responder community in the development and 
updating of their emergency management plans, fewer involve community 
partners. (See table 12.) According to written guidance provided by 
Education, those school districts that do not include community 
partners in the development and updating of their plans may limit their 
opportunity to exchange information with local officials, take 
advantage of local resources, and identify gaps in their plan. 

We estimate that one-third of all school districts (36 percent) have 
School Resource Officers (SRO) available at schools during school 
hours. An SRO[Footnote 28] is a fully sworn/commissioned law 
enforcement officer whose primary assignment is within the local 
schools.[Footnote 29] Of those school districts that have SROs, 73 
percent include procedures in their plan for involving SROs in the 
event of an emergency. During our site visits, school district 
officials cited several methods they use to involve SROs in preparing 
for emergencies such as including them as a stakeholder in the annual 
discussion to update the school-level crisis response manual including 
procedures for dealing with emergencies, among others. A significantly 
higher percentage of urban school districts had SROs available on 
school grounds during school hours compared to rural school districts. 
We estimate about 81 percent of urban school districts had SROs 
available at school campuses during school hours, compared to just 16 
percent of rural school districts. 

Table 12: Percentage of School Districts That Involve Stakeholders in 
the Development and Update of Written Emergency Management Plans: 

Community Partners. 

Stakeholder: Local head of government; 
Estimated percentage of school districts: 43. 

Stakeholder: Public health agency; 
Estimated percentage of school districts: 42. 

Stakeholder: American Red Cross; 
Estimated percentage of school districts: 30. 

First Responders. 

Stakeholder: Law enforcement; 
Estimated percentage of school districts: 89. 

Stakeholder: Fire department; 
Estimated percentage of school districts: 85. 

Stakeholder: Emergency Medical Services; 
Estimated percentage of school districts: 67. 

School Community. 

Stakeholder: Superintendent; 
Estimated percentage of school districts: 97. 

Stakeholder: Teachers; 
Estimated percentage of school districts: 91. 

Stakeholder: Building engineers; 
Estimated percentage of school districts: 83. 

Stakeholder: Nurses; 
Estimated percentage of school districts: 76. 

Stakeholder: SROs; 
Estimated percentage of school districts: 42. 

Source: GAO analysis of survey data. 

[End of table] 

More than half of all school districts with emergency management plans 
report regularly updating their emergency management plans in 
accordance with recommended practices. Specifically, we estimate that 
52 percent of all school districts with emergency plans update these 
plans at least once a year. However, 10 percent of all school districts 
had never updated their plans. (See table 13.) District officials cited 
several reasons for regularly updating their emergency management 
plans, including (1) construction modifications or renovations to 
school buildings, (2) changes to emergency contact information, (3) 
procedural changes such as new drills or evacuation routes, and (4) new 
legislative requirements, among others. However, some school district 
officials we visited had just recently completed their plans or 
reported that they had not made any changes to their plans, since they 
were first developed. According to guidance provided by Education, 
those school districts that do not regularly update their plans may 
risk having inaccurate and outdated information in their plans, which 
could lead to a delayed response during an emergency. 

Table 13: Frequency of Updates to Emergency Management Plans: 

Frequency of updates: At least once a year; Estimated percentage of 
school districts: 52. 

Frequency of updates: At least once every 2 years; 
Estimated percentage of school districts: 14. 

Frequency of updates: At least once every 3 or more years; 
Estimated percentage of school districts: 19. 

Frequency of updates: Have not updated the emergency management plan; 
Estimated percentage of school districts: 10. 

Frequency of updates: After an incident; 
Estimated percentage of school districts: 1. 

Source: GAO analysis of survey data. 

[End of table] 

The frequency with which districts updated their plans differed for 
urban and rural areas. A significantly higher percentage of urban 
school districts update their emergency management plans annually 
compared to rural districtsó69 percent versus 43 percent, respectively. 
Finally, as many as 13 percent of rural school districts have not 
updated their emergency plans at all, compared with 3 percent of urban 
school districts. 

Based on our survey of school districts, we estimate that 55 percent of 
school districts with written emergency management plans coordinate 
them with city or county emergency response plans. A significantly 
higher percentage of urban school districtsó78 percent coordinate their 
plans with the local government emergency response plans as compared to 
rural school districts (45 percent). For example, in one Ohio school 
district, officials told us that the school district plan is a 
component of the city plan in that the city will rely upon the district 
to make selected school buildings available for use as shelters, if 
needed in an evacuation. Likewise, officials in a district in Iowa said 
that the district plan is aligned with the county plan in that, during 
emergencies, the district's school buses will be used to evacuate 
persons from the downtown community. Similarly, in a school district in 
Massachusetts, officials said that, in coordination with the local 
board of health's plan, the district's plan includes the use of the 
school facilities as inoculation sites or quarantine facilities in the 
event of a large-scale pandemic. 

As previously discussed, most school districts identify roles and 
responsibilities for first responders and involve them in developing 
and updating their plans. However, based on our survey, we estimate 
that 27 percent of all school districts with emergency management plans 
have never trained with any first responders on how to implement the 
plans, in accordance with federally recommended practices. Furthermore, 
we estimate that about three-quarters of all school districts do not 
regularly train (i.e., at least once a year) with each type of first 
responder law enforcement, fire, or EMS on how to implement the school 
district plan. (See table 14.) The reasons why school districts are not 
training with first responders are not readily apparent. As we have 
previously reported, involving first responder groups in training and 
exercise programs can better familiarize and prepare first responders 
with their roles in an emergency as well as assess the effectiveness of 
a school or district's emergency plan.[Footnote 30] Without such 
training, school districts and their first responder partners may be at 
risk of not responding effectively during a school emergency. 

Table 14: Estimated Frequency of Training with Each Type of First 
Responder on How to Implement the School District Emergency Management 
Plan: 

Frequency of training: At least once a year; 
Law enforcement: Percentage: 33; 
Firefighters: Percentage: 31; 
Emergency Medical Services (EMS)[A]: Percentage: 25. 

Frequency of training: At least once every 2 years; 
Law enforcement: Percentage: 15; 
Firefighters: Percentage: 15; 
Emergency Medical Services (EMS)[A]: Percentage: 11. 

Frequency of training: At least once every 3 or more years; 
Law enforcement: Percentage: 19; 
Firefighters: Percentage: 19; 
Emergency Medical Services (EMS)[A]: Percentage: 17. 

Frequency of training: Never; 
Law enforcement: Percentage: 33; 
Firefighters: Percentage: 34; 
Emergency Medical Services (EMS)[A]: Percentage: 46. 

Source: GAO analysis of survey data. 

Notes: All responses are mutually exclusive. Due to rounding, 
percentages in each column may not sum to 100. 

[A] During our site visits some officials told us that their emergency 
medical service providers were part of the fire department, not a 
separate entity. 

[End of table] 

A significantly higher percentage of urban school districts annually 
train with law enforcement and firefighters on the school district 
emergency plan. We estimate that nearly half of urban districts 
annually train together with law enforcement (42 percent) and 
firefighters (43 percent) on the school district emergency plan, 
whereas less than one-quarter of rural school districts train annually 
with law enforcement (23 percent) and firefighters (23 percent). 

School districts report training with community partners' such as local 
public health and local government entities on activities to prepare 
for an emergency with similar frequency. Specifically, we estimate that 
29 percent of all school districts train with community partners. As 
with first responders, the reasons for the lack of training with 
community partners are not readily apparent. In our work on Hurricane 
Katrina, we reported that involving local community partners in 
exercise programs and training could help prepare community partners 
and enhance their understanding of their roles in an emergency as well 
as help assess the effectiveness of a school district's emergency 
plan.[Footnote 31] Without such training, school districts and their 
community partners may not fully understand their roles and 
responsibilities and could be at risk of not responding effectively 
during a school emergency. 

Training differed for urban and rural areas. A significantly higher 
percentage of urban school districts train with community partners on 
how to implement the school district plan compared to rural school 
districtsó45 percent versus 26 percent. 

Some school districts collaborate with community partners on other 
aspects of emergency preparedness. For example, one component of the 
Citizen Corps program--Community Emergency Response Teams--instructs 
citizens on how to respond to emergencies (e.g., first aid) and 
participants, in turn, provide instruction to others. An official with 
the Highlands County, Florida school district said that 50 school 
district employees have participated in a Community Emergency Response 
Teams program. Likewise, in Olmstead Falls, Ohio, school district 
officials have coordinated with the American Red Cross in conducting a 
pandemic immunization drill in school facilities. 

School Districts Report Challenges in Planning for Emergencies as Well 
as Difficulties in Communicating with First Responders and Parents, but 
No Challenges in Communicating with Students: 

In planning for emergencies, many school districts face challenges 
resulting from competing priorities, a lack of equipment, and limited 
expertise; some school districts experience difficulties in 
communicating and coordinating with first responders and parents, but 
most do not have such challenges with students. Within their own 
districts, officials struggle to balance activities related to 
educating their students with those related to recommended practices 
for emergency management. Officials also confront a shortage of 
equipment and expertise necessary for planning and responding to 
emergencies. In some cases, officials noted that it was particularly 
challenging to plan for special needs students in the absence of such 
equipment and expertise. Less prevalent among school districts were 
problems in communicating and coordinating with first responders and 
parents. 

Competing Priorities, Lack of Equipment, and Limited Expertise Are 
Obstacles to Implementing Recommended Practices in Emergency Management 
Planning: 

School district officials who responded to our survey reported 
difficulty in following the recommended practice of allocating time to 
emergency management planning, given the higher priority and competing 
demand on their time for educating students and carrying out other 
administrative responsibilities. Based on our survey of school 
districts, we estimate that in 70 percent of all districts, officials 
consider competing priorities to be a challenge to planning for 
emergencies. In at least two districts we visited, officials said that 
they have a limited number of staff development days[Footnote 32] and 
they want to use the time to train staff on instruction rather than 
emergency planning. For example, in one Florida district, officials 
noted that only two days a year were available for staff development, 
making it difficult to cover emergency planning as well as federal and 
state requirements for schools. Officials in a North Carolina district 
said although they had the instructors they needed, they forfeited some 
emergency planning activities after the allotted number of staff 
development days were cut short. 

In an estimated 62 percent of districts, officials cited a lack of 
equipment and expertise as impediments to emergency planning. In the 
course of our site visits, officials focused primarily on shortages of 
three types of equipment: equipment to control or monitor school 
grounds, such as locks on doors and surveillance equipment; equipment 
to evacuate or maintain a shelter-in-place for students and staff; and 
communications equipment, such as two-way radios and satellite phones. 
Officials in one Massachusetts school district reported that they do 
not have adequate locks on some of the doors to school buildings to 
implement a lockdown procedure, for example. Other districts lacked 
fencing for school grounds or surveillance cameras for school 
buildings. Officials also described a lack of sufficient equipment to 
maintain a shelter-in-place or evacuate students. Five of the 27 school 
districts we interviewed reported that they do not have generators to 
maintain power in school buildings. One superintendent in Washington 
noted that the district's only school building is located in a remote 
mountainous area that could be inaccessible in the event of an 
earthquake or heavy snowfall that blocked the few access roads in and 
out of the community. Yet, according to this superintendent, the 
district does not have a generator to supply electricity in the event 
of such an emergency. Although the officials in one Massachusetts 
school district did not report problems maintaining a shelter-in-place 
facility, they said the district did not have enough school buses to 
accommodate all of the students in the case of evacuation. Finally, 
school officials in the districts we visited discussed a lack of 
equipment to facilitate communication during emergencies. In one North 
Carolina district, officials said a lack of two-way radios for staff in 
the elementary schools hinders their ability to communicate with one 
another and with first responders during an emergency.[Footnote 33] 
Similarly, in one Washington school district, the superintendent told 
us the district does not have satellite two-way radios that are needed 
in case conventional cellular telephones do not operate under the 
severe weather conditions common to the remote and mountainous 
location. In a district in Iowa, officials reported a need to replace 
their aging two-way radios because the radios' signals cannot penetrate 
the walls of the school buildings. Officials in four additional 
districts stated that their districts need to update or maintain 
communication equipment. As demonstrated in these school districts, the 
lack of equipment prevents districts from implementing the procedures 
in their plans and hinders communication among district staff and with 
first responders during emergencies. 

In addition to not having sufficient equipment, school district 
officials we spoke with described a shortage of expertise in both 
planning for and managing emergencies. These officials said their 
districts lacked specialized personnel and training with which to 
develop needed expertise. One Washington state superintendent said he 
needed to provide those staff most likely to be present in an emergency 
with training on emergency management but would need additional funding 
to do so. District officials in 5 of the 27 districts noted that they 
do not having sufficient funding to hire full-time emergency management 
staff to provide such training or take responsibility for updating 
their district plans.[Footnote 34] Still, other officials described an 
unmet need for specific staff positions such as either an SRO or a 
school nurse to assist in planning for and responding to emergencies. 
According to officials in a North Carolina district, due to a shortage 
of funding, the district did not have SROs for the district's 
elementary schools. In this district, the SROs have a role in providing 
comments on the emergency plans of the schools to which they are 
assigned before those plans are submitted to the district for annual 
reviews. Similarly, officials in the Lee County district of North 
Carolina reported a shortage of school nurses, which they said could 
precipitate a medical crisis in an evacuation on days when a nurse is 
not available to distribute student medications or attend to those who 
may become ill. These officials noted that the lack of expertise makes 
it difficult to adequately plan for responding to emergencies. 

As previously discussed, school districts reported challenges in 
incorporating special needs students in emergency management planning. 
According to officials in about half (13 of 27) of the districts in 
which we conducted interviews, a lack of equipment or expertise poses 
challenges for districts--particularly in the area of evacuating 
special needs students. In one Massachusetts school district, while 
schools assign persons to special needs students for evacuations, 
officials reported that these persons or "buddies" are typically other 
students, rather than experienced personnel.[Footnote 35] The students 
may not always be in the same classes as the students to whom they are 
assigned or may be absent from school on the day of the emergency. An 
official in a Washington school district said that the district tracks 
the location of special needs students, but many of the district's 
schools do not have evacuation equipment (e.g., evacuation chairs used 
to transport disabled persons down a flight of stairs) to remove 
students from buildings and staff need more training on how to operate 
the existing equipment. Lee County, North Carolina, district officials 
reported that a shortage of nurses across the district has led to 
difficulties in meeting the medical needs of special needs students 
during evacuations, because nurses are the only staff permitted to 
physically remove medical supplies and distribute medicine. Because 
coordination with first responders often occurs at the district level, 
delegating responsibility for planning for special needs students to 
individual schools can result in a lack of information for first 
responders. In one school district in Ohio, a fire department official 
we interviewed was unaware that the schools in his area had assigned 
special aides to help evacuate special needs students. 

School district officials who reported challenges in planning for 
special needs students also identified challenges in adequately 
planning for temporarily disabled students (e.g., a student with a 
broken leg), maintaining a supply of surplus medical supplies for 
students with special needs, and ensuring the district maintains 
privacy standards related to the conditions of special needs students 
during emergencies. Finally, officials in three school districts stated 
that the districts' school buildings are not all in compliance with the 
Americans with Disabilities Act standards,[Footnote 36] thus limiting 
the district's ability to adequately plan for students with special 
needs. 

Some School Districts Reported Difficulty in Communicating and 
Coordinating with First Responders and Parents: 

Based on our survey of school districts, an estimated 39 percent of 
districts with emergency plans experience challenges in communicating 
and coordinating with local first responders.[Footnote 37] 
Specifically, these school districts experience a lack of partnerships 
with all or specific first responders, limited time or funding to 
collaborate with first responders on plans for emergencies, or a lack 
of interoperability between the equipment used by the school district 
and equipment used by first responders. 

The superintendent of a Washington school district said that law 
enforcement has not been responsive to the district's requests to 
participate in emergency drills, and, in addition to never having had a 
district wide drill with first responders, competition among city, 
county, and private first responders has made it difficult for the 
school district to know with which first responder entity it should 
coordinate. In another Washington district, the superintendent reported 
not having a local law enforcement entity in the community, but rather, 
a deputy from the county sheriff's department that drives through the 
local community twice a day. This superintendent said that based on an 
absence of a relationship with law enforcement, he assumed that his 
district was essentially "on its own" in responding to emergencies. 
According to guidance provided by Education, the lack of partnerships, 
as demonstrated in these school districts, can lead to an absence of 
training that prevents schools and first responders from understanding 
their roles and responsibilities during emergencies. 

Even when forming partnerships is not a problem, school districts may 
be unable to find sufficient time or funding to meet with first 
responders on issues related to emergency management planning. An 
official in the Chatham, North Carolina, district said that it is 
difficult to find a convenient time for both first responders and 
school district officials to meet and discuss the district's plan. 
According to an official in the Seattle school district, first 
responders for the district are more likely to meet with the school 
district when there are funds available to pay both first responders 
and district staff for such efforts. Officials in an Ohio district said 
that while first responders drill in school facilities over the 
weekends, the district does not have additional funding or staff to 
conduct these drills during school hours. 

Finally, officials we interviewed described a lack of interoperable 
equipment as a hindrance to communicating with first responders during 
emergencies. In 8 of the 27 districts in which we conducted interviews, 
officials said that the two-way radios or other equipment used in their 
school districts lacked interoperability with the radios used by first 
responders. Officials in an Iowa district said that the lack of 
interoperability among first responders[Footnote 38] impacts the 
district's ability to communicate during emergencies because the 
district shares a radio frequency with some first responders but not 
others. 

School Districts Have Methods to Communicate with Parents, but Face 
Challenges in Ensuring Parents Receive Consistent Information during 
Incidents: 

In keeping with recommended practices that call for school districts to 
have a way to contact parents of students enrolled in the district, all 
of the school districts we interviewed had ways of communicating 
emergency procedures to parents prior to (e.g., newsletters), during 
(e.g., media, telephone), and after an incident (e.g., letters). Eleven 
of these districts have a system that can send instant electronic and 
telephone messages to parents of students in the district. Despite 
these methods, 16 of the 27 districts we interviewed experience 
difficulties in implementing the recommended practice that school 
districts communicate clear, consistent, and appropriate information to 
parents regarding an emergency. For example, officials in a Florida 
school district said that with students' increased access to cellular 
telephones, parents often arrive on school grounds during an incident 
to pick up their children before the district has an opportunity to 
provide parents with information. Thus, according to these officials, 
the district experiences challenges in simultaneously maintaining 
control of both the emergency situation and access to school grounds by 
parents and others. Other districts discussed challenges in providing 
messages, during emergencies, with instructions to parents for 
reuniting with their children. Officials in the Boston school district 
said that having inaccurate telephone numbers for parents prevented the 
district from delivering messages to all parents during or after 
emergencies. Representatives of three education associations[Footnote 
39] also noted that school districts have much to do to ensure that 
their emergency management efforts diffuse confusion during emergencies 
and provide parents with consistent information. 

Based on our survey of school districts, an estimated 39 percent of all 
school districts provide translators to communicate with LEP parents 
during emergencies, but fewer--an estimated 23 percent of all 
districts--provide translations of emergency management materials. 
Officials in 8 of the 27 districts we interviewed discussed challenges 
in retaining bilingual staff to conduct translations of the districts' 
messages or in reaching parents who do not speak the languages or 
dialects the district translates. In Seattle, where the district 
provides translations of 10 of the 47 languages spoken in the schools, 
the official we interviewed said that staff often experience "burn out" 
due to their dual roles as interpreters and liaisons between the local 
community and school district. The problem in retaining bilingual staff 
was not related to the level of work required by interpreters in the 
Hardee County, Florida, school district, but with the district's 
inability to recruit qualified bilingual staff who also want to reside 
in the rural, hurricane-prone community. In two different districts, 
officials were unsure of whether the district's emergency messages 
reached parents who did not speak the translated languages provided by 
the school district. Officials in the Pinellas County school district 
said that they were unsure about the district's success in getting 
emergency management information to parents who speak 1 of the 107 
languages for which the district does not provide translations. 
Difficulties in accommodating dialects was also cited by an official of 
the Ashtabula, Ohio, school district because staff there have 
encountered problems ensuring the messages translated by telephone were 
understood due to the differences in dialects of Spanish spoken by some 
parents and the school officials providing the translated message. Our 
findings, while limited to the districts in which we conducted 
interviews, are consistent with the observations of some national 
education groups that have indicated that districts, in part due to 
limited funding, struggle to effectively communicate emergency-related 
information to this population of parents. 

While school districts experience a range of challenges in planning for 
emergencies and in communicating and coordinating with first responders 
and parents, officials in all but one of the districts in which we 
conducted interviews said that the district did not have problems 
communicating emergency procedures to students. While some of these 
officials did not provide reasons, as we previously reported, most 
districts regularly practice their emergency management plans with 
their students and staff. 

Conclusions: 

While emergency management is overwhelmingly a state and local 
responsibility, the federal government plays a critical role in 
disseminating information on best practices, providing guidance, and 
giving states flexibility to target federal funding to areas of 
greatest need. While all three federal agencies involved in emergency 
management planning for schools have provided some resources, 
additional access to federal resources would enhance the ability of 
school districts to plan and prepare for emergencies. Given the 
challenges many school districts face due to a lack of necessary 
equipment and expertise, they do not have the tools to support the 
plans they have in place and, therefore, school districts are left with 
gaps in their ability to fully prepare for emergencies. Making it clear 
to states and local governments that school districts are among the 
entities to which they may disburse certain grant funds they have 
received from DHS would be one way to diversify the available emergency 
management resources to which school districts have access. 

School districts have taken a number of important steps to plan for a 
range of emergencies, most notably developing emergency management 
plans; however, in many districts these plans or their implementation 
do not align with federally recommended practices. For example, because 
most districts' plans do not have procedures to ensure the continuity 
of education in the event of extended school closures, such as those 
caused by a pandemic or natural disasters, school districts, both urban 
and rural, are largely not prepared to continue their primary mission 
of educating students. Unless the federal government examines 
strategies for planning for on-going student instruction in the event 
of extended school closures and determines which of those strategies 
are successful, schools may not have the information they need to put 
in place a plan that will adequately prepare them for emergencies that 
require such a response. In addition, while most districts have 
procedures for special needs students in place, because there is no 
agreement on procedures school districts should use with such students, 
districts may employ less than optimal or even risky procedures for 
evacuating or sheltering these students in an emergency. Further, while 
the reasons are not readily apparent and can vary as to why school 
districts do not train with first responders and community partners, by 
not training together, school districts, first responders, and 
community partners may limit their ability to effectively respond to 
and mitigate the impact of emergencies when they occur. If the federal 
government had information on why school districts do not train with 
first responders and community partners, it would be better positioned 
to provide assistance to school districts that would enable them to 
train with first responders and community partners on a regular basis. 

Finally, our findings show that in some areas there are vast 
differences in how urban and rural districts prepare for emergencies 
and it appears that urban districts are taking more actions as 
suggested by recommended practices to prepare for incidents. It may not 
be possible for urban and rural school districts to plan equally given 
differences in geography, resources, expertise, and other demographics 
that may warrant different approaches. However, it is important that 
all districts include key procedures, cover the full range of incidents 
that could affect them, and practice their plans to prepare for 
emergencies because some incidents, such as natural disasters, may 
impact urban and rural districts alike. 

Recommendations for Executive Action: 

To help address the challenges school districts face in planning for 
emergencies, we recommend that the Secretary of DHS clarify that school 
districts are among those entities to which state and local governments 
may disburse grant funds received through the State Homeland Security 
Program, Urban Areas Security Initiative, and Citizens Corps grant 
programs. This should be done through its guidance for these programs 
so that states and local governments will know they can disburse these 
program funds to school districts. 

To address the lack of procedures for continuing student education in 
the event of an extended school closure, we recommend that the 
Secretary of Education collaborate with the Secretary of HHS in his 
role as head of the lead agency on pandemics, to examine and identify 
successful strategies for developing such procedures and provide 
guidance to school districts on how to include the resulting procedures 
for the continuation of student education in their emergency management 
plans. These agencies may consider providing specific suggestions for 
states and districts to work with state education agencies, health 
departments, and local community organizations in the process of 
developing these procedures. 

To help school districts shelter or evacuate students with special 
needs and temporarily disabled students in an emergency, we recommend 
that the Secretary of Education, in collaboration with the Secretaries 
of DHS and HHS, examine and identify successful procedures for 
sheltering and removing such students from school buildings and share 
these procedures with school districts. 

To promote training between school districts and first responders and 
between school districts and community partners on how to implement 
district emergency management plans, we recommend that the Secretaries 
of DHS and Education identify the factors that prevent school 
districts, first responders, and community partners from training 
together and develop strategies for addressing those factors. These 
strategies should include the continued use of any current resources 
that could facilitate joint training. DHS and Education should share 
the strategies with school districts, first responders, and community 
partners and encourage them to consider implementing the strategies as 
appropriate. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to DHS, Education, and HHS for 
review and comment. DHS provided written comments on May 16, 2007, 
which are presented in appendix V. In commenting on the draft report, 
DHS generally agreed with the intent of our first recommendation that 
it clarify that school districts are eligible entities to which states 
and local governments may disburse emergency management funding. While 
the department stated that it would continue to alert states and local 
governments of school districts' eligibility through such activities as 
site visits and workshops, it did not comment on whether it would 
modify its program guidelines. Taking the opportunity to remind states 
and local governments of school districts' eligibility in such one-on- 
one settings should help to increase awareness of school districts' 
eligibility. However, we continue to believe that DHS should explicitly 
include school districts in its program guidance, so that all state and 
local governments receiving homeland security funds would have access 
to guidance that provides a clear understanding of how to use the 
funding. DHS disagreed with the language in our fourth recommendation 
that the department collaborate with Education to identify and address 
the factors that prevent training among school districts, first 
responders, and community partners. DHS suggested that we modify the 
recommendation to acknowledge the need for DHS and Education to promote 
current resources in addressing these factors. We agree with DHS's 
suggestion and have revised the recommendation to recognize the need 
for DHS and Education to promote current resources. DHS also suggested 
that we include a discussion of the Citizen Corp Council in the report 
as a resource for collaboration among local governments, the private 
sector, and non-profit entities including school districts. We agree 
and have revised the report to include information on the Citizen Corp 
Council. 

Education provided written comments on May 7, 2007, which are included 
in appendix VI. Education agreed with all four of our recommendations, 
but expressed concern about our statement that there are no federal 
requirements for school districts to have emergency management plans, 
pointing to a requirement in the No Child Left Behind Act (NCLBA) 
relating to safe and drug-free schools. As we explain in the report, we 
did not consider plans required under NCLBA to be emergency management 
plans for purposes of our report because these plans are not required 
to address multiple hazards. While Education acknowledged that we had 
included this information in a footnote, it stated that the footnote 
appeared only once. We have revised the report to more prominently 
display this information. 

HHS provided written comments on our draft report on May 8, 2007, which 
are presented in appendix VII. HHS generally agreed with our 
recommendations. However, HHS requested that Education take the lead 
with respect to our second recommendation that both agencies provide 
guidance to school districts on the continuation of education during 
extended school closures because Education is responsible for leading 
federal efforts related to the education process. We discussed the 
issue with Education officials and they agreed to take the lead on this 
recommendation. Thus, we modified the recommendation accordingly. HHS 
also requested that we include it in our third recommendation to 
provide guidance on evacuating and sheltering special needs students 
because of the agency's expertise on special needs students. We agree 
and have modified the recommendation to include HHS. 

DHS, Education, and HHS also provided technical comments, which we 
incorporated where appropriate. 

We are sending copies of this report to the Secretaries of Education, 
DHS, HHS, and relevant congressional committees. We will also make 
copies available to others upon request. In addition, the report will 
be made available at no charge on GAO's Web site at http://www.gao.gov. 

Please contact us at (202) 512-7215 or (202) 512-8757 if you or your 
staff have any questions about this report. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. Major contributors are listed in appendix 
VI. 

Signed by: 

Cornelia M. Ashby, Director:
Education, Workforce and Income Security Issues: 

Signed by: 

William O. Jenkins, Jr., Director: 
Homeland Security and Justice Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

To obtain information on federal, state, and local roles and 
requirements for school districts, how school districts prepare and 
plan, and any challenges in doing so, we interviewed staff in the 
Departments of Education, Homeland Security, and Health and Human 
Services; conducted an e-mail survey of state education agencies and an 
e-mail survey of state administering agencies; and conducted a mail 
survey of school districts from a stratified random sample of public 
school districts. We also conducted site visits during which we 
interviewed district officials, security administrators, and other 
officials in 27 school districts in six states. We conducted our work 
from April 2006 through March 2007 in accordance with generally 
accepted government auditing standards. 

Survey of States: 

To better understand the role of states in how school districts prepare 
for emergencies, we designed and administered two surveys--one to state 
education agencies and a separate, but similar, one to state 
administering agencies--to all 50 states and the District of Columbia. 
The survey to state education agencies was conducted between August 
2006 and October 2006. The survey included questions about laws that 
require school districts to have emergency management plans, state 
funding provided to school districts, and any other resources provided 
to school districts. The survey of state administering agencies was 
conducted between November 2006 and January 2007. The survey also 
included questions about laws requiring school districts to have 
emergency management plans, state funding provided to school districts, 
and other resources. In this survey we specifically asked about whether 
the state allocated portions of the State Homeland Security Program 
(SHSP), Urban Areas Security Initiative (UASI), and Citizen Corps 
grants to school districts. In 19 states, there were no UASI funds 
provided and we did not ask about funding related to this program for 
those states. 

The practical difficulties of conducting any survey may introduce 
nonsampling errors, such as variations in how respondents interpret 
questions and their willingness to offer accurate responses. We took 
steps to minimize nonsampling errors, including pretesting draft 
instruments and following up on specific responses. Specifically, 
during survey development, we pretested draft instruments with various 
officials. For the survey to state administering agencies, we pretested 
with officials representing state administering agencies in California 
and Maryland in November 2006. In the pretests, we were generally 
interested in the clarity of the questions and the flow and layout of 
the survey. For example, we wanted to ensure definitions used in the 
surveys were clear and known to the respondents, categories provided in 
closed-ended questions were complete and exclusive, and the ordering of 
survey sections and the questions within each section was appropriate. 

We analyzed the requirements for schools and districts to have 
emergency management plans that were reported to us by states. In some 
cases, we determined that the laws or other requirements reported in 
these surveys did not constitute emergency management planning 
requirements for purposes of this report. Accordingly, these survey 
responses are not included in our analysis of state requirements. We 
did not conduct any independent legal research to identify state legal 
requirements in this area. 

Survey of School Districts: 

To obtain national-level information on school district management 
planning, we administered a mail survey to a stratified random sample 
of public school districts. The survey was conducted between September 
2006 and January 2007. To obtain the maximum number of responses to our 
survey, we sent a follow-up mailing with the full survey instrument to 
nonrespondents approximately 3 weeks after the initial mailing, and a 
reminder postcard to nonrespondents approximately 4 weeks after the 
initial mailing of the survey instrument. The survey included questions 
about whether school districts had emergency management plans, 
activities related to emergency management plans, characteristics of 
plans, district requirements of schools, and coordination with various 
persons in the school environment, local community, and first 
responders. 

Population: 

The target population of 14,432 districts consisted of public school 
districts in the 50 states and the District of Columbia with at least 
one school in each of their jurisdictions in the 2003-2004 school 
year.[Footnote 40] We used Education's Common Core of Data (CCD) Local 
Education Agency (School District) file for the 2003-2004 school year 
(version 1b) as the basis of defining our population. To define our 
sampling frame, we removed districts from the CCD that were not a 
component of a supervisory union; state and federally-operated 
institutions; other education agencies; had less than 1 student; were 
closed; run by the Department of Defense or Bureau of Indian Affairs; 
or located in American Samoa, Guam, Northern Marianas, Puerto Rico, or 
the Virgin Islands. On the basis of our review of these data, we 
determined this source to be adequate for the purposes of our work. 

Sample Design and Errors: 

The sample design for the mail survey was a stratified random sample of 
districts with two certainty strata containing all of the urban and 
urban fringe districts with over 100,000 students. We defined the 
strata classifications using the locale code in the CCD. We chose 
districts with the largest number of students with certainty because 
the total number of students in these districts makes up nearly 13 
percent of the total students in our universe. We also included four 
additional strata--urban, urban fringe, towns, and rural. Table 15 
provides a description of the universe and sample of districts. 

Table 15: Description of the Population and Sample of Districts: 

Stratum: Large urban; 
Population/universe: 12; 
Sample size: 12. 

Stratum: Large urban fringe; 
Population/universe: 14; 
Sample size: 14. 

Stratum: Urban; 
Population/universe: 860; 
Sample size: 125. 

Stratum: Urban fringe; 
Population/universe: 3,795; 
Sample size: 135. 

Stratum: Town; 
Population/universe: 1,785; 
Sample size: 132. 

Stratum: Rural; 
Population/universe: 7,966; 
Sample size: 136. 

Stratum: Total; 
Population/universe: 14,432; 
Sample size: 554. 

Source: GAO. 

[End of table] 

We used the metro-centric locale codes assigned to each district in the 
03-04 CCD to define urban and rural. We defined urban districts to be 
those districts within a central city of a Core Based Statistical Area 
or Consolidated Statistical Area (locale codes 1 and 2). Generally, 
those are considered to be a central city of a Core Based Statistical 
Area (CBSA) or Consolidated Statistical Area (CSA), with the city 
having a population greater than or equal to 250,000 (for locale code 
1) or a central city of a CBSA or CSA, with the city having a 
population less than 250,000 (for locale 2). Rural districts are any 
incorporated place, Census-designated place, or non-place territory and 
defined as rural by the Census Bureau (locale codes 7 and 8). These are 
generally defined as any incorporated place, Census-designated place, 
or non-place territory not within a CBSA or CSA of a large or mid-size 
city and defined as rural by the Census Bureau; and any incorporated 
place, Census-designated place, or non-place territory within a CBSA or 
CSA of a large or mid-size city and defined as rural by the Census 
Bureau. 

Because we surveyed a sample of districts, our results are estimates of 
a population of districts and thus are subject to sampling errors that 
are associated with samples of this size and type. Our confidence in 
the precision of the results from this sample is expressed in 95 
percent confidence intervals, which are expected to include the actual 
results in 95 percent of the samples of this type. We calculated 
confidence intervals for this sample based on methods that are 
appropriate for a stratified random sample. We determined that nine of 
the sampled districts were out of scope because they were not 
considered to be school districts. All estimates produced from the 
sample and presented in this report are for the estimated target 
population of 14,131 districts with at least one school in the 2003- 
2004 school year. All percentage estimates included in this report have 
margins of error of plus or minus 10 percentage points or less, unless 
otherwise noted. 

We took steps to minimize nonsampling errors that are not accounted for 
through statistical tests, like sampling errors. In developing the mail 
survey, we conducted several pretests of draft instruments. We 
pretested the survey instrument with district officials in six 
districts--Baltimore County, Maryland; Carbon County, Wyoming; Citrus 
County, Florida; Muleshoe Independent, Texas; Santa Fe Public Schools, 
New Mexico; and Vigo County, Indiana--between July 25, 2006, and August 
18, 2006. On the basis of the pretests, the draft survey instrument 
underwent some revisions. 

Response Rate: 

We received survey responses from 444, or 80 percent, of the 554 school 
districts in the sample. 

Site Visits: 

To understand emergency management planning at the local level, we 
conducted site visits and conducted interviews in six states between 
September 27, 2006, and November 15, 2006. The states we visited 
included Florida, Iowa, Massachusetts, North Carolina, Ohio, and 
Washington. In each state, to the extent possible, we visited or 
interviewed (by telephone) at least one district that corresponded to 
the strata in our survey of school districts. We selected states and 
school districts that included recommended practices, some that did and 
did not receive federal funding for emergency management, both urban 
and rural districts, and those representing geographic diversity. When 
viewed as a group, the states and school districts also provided 
variation across characteristics such as geographic location, district 
size, student populations, and the percentage of students with Limited- 
English proficiency or disabilities. We conducted a pretest of 
questions used in the site visits with the Alleghany County Public 
Schools district, in Maryland, on September 13, 2006. We used this 
interview to determine whether our interview questions were clear as 
well as to gauge the amount of time the interviews would take. 

In total, we interviewed officials in 27 school districts. Through our 
interviews with district officials, we collected information on the 
role of the school district in emergency management planning, state or 
local requirements, whether the district received federal, state, or 
local funding and guidance, and experiences in communicating and 
coordinating with first responders, parents, and students. Table 16 
indicates the school districts we visited during site visits or 
interviewed, the corresponding locale code, and other selected 
characteristics. 

Table 16: School Districts Interviewed or Visited during Site Visits: 

Florida. 

District: Pinellas County School District; 
Common Core of Data Locale Code: 2 (urban); 
Number of schools: 174; 
Number of students: 113,651; 
Number of students categorized as Limited-English Proficient (LEP): 
3,204. 

District: Hillsborough County School District; 
Common Core of Data Locale Code: 3 (urban fringe); 
Number of schools: 258; 
Number of students: 189,469; 
Number of students categorized as Limited-English Proficient (LEP): 
19,686. 

District: Hardee County School District; 
Common Core of Data Locale Code: 6 (town); 
Number of schools: 9; 
Number of students: 5,146; 
Number of students categorized as Limited-English Proficient (LEP): 
450. 

District: Highlands County School District; 
Common Core of Data Locale Code: 7 (rural); 
Number of schools: 18; 
Number of students: 12,049; 
Number of students categorized as Limited-English Proficient (LEP): 
517. 

Washington. 

District: Seattle School District; 
Common Core of Data Locale Code: 1 (urban); 
Number of schools: 111; 
Number of students: 46,746; 
Number of students categorized as Limited-English Proficient (LEP): 
5,752. 

District: Renton School District; 
Common Core of Data Locale Code: 2 (urban); 
Number of schools: 26; 
Number of students: 13,236; 
Number of students categorized as Limited- English Proficient (LEP): 
1,485. 

District: Sequim School District; 
Common Core of Data Locale Code: 6 (town); 
Number of schools: 5; 
Number of students: 2,950; 
Number of students categorized as Limited- English Proficient (LEP): 
48. 

District: Skykomish School District; 
Common Core of Data Locale Code: 8 (rural); 
Number of schools: 2; 
Number of students: 70; 
Number of students categorized as Limited-English Proficient (LEP): 2. 

District: Index School District; 
Common Core of Data Locale Code: 8 (rural); 
Number of schools: 1; 
Number of students: 30; 
Number of students categorized as Limited- English Proficient (LEP): 0. 

Iowa. 

District: Des Moines Independent Community School District; 
Common Core of Data Locale Code: 2 (urban); 
Number of schools: 72; 
Number of students: 32,194; 
Number of students categorized as Limited-English Proficient (LEP): 
3,502. 

District: West Des Moines Community School District; 
Common Core of Data Locale Code: 4 (urban fringe); 
Number of schools: 15; 
Number of students: 8,491; 
Number of students categorized as Limited-English Proficient (LEP): 
246. 

District: Marshalltown Community School District; 
Common Core of Data Locale Code: 5 (town);
Number of schools: 9; 
Number of students: 4,922; 
Number of students categorized as Limited-English Proficient (LEP): 
1,203. 

District: Bondurant-Farrar Community School District; 
Common Core of Data Locale Code: 8 (rural); 
Number of schools: 2; 
Number of students: 1,042; 
Number of students categorized as Limited-English Proficient (LEP): 0. 

Massachusetts. 

District: Boston Public Schools; 
Common Core of Data Locale Code: 1 (urban); 
Number of schools: 136; 
Number of students: 57,742; 
Number of students categorized as Limited-English Proficient (LEP): 
9,789. 

District: Holliston Public Schools[A]; 
Common Core of Data Locale Code: 3 (urban fringe); 
Number of schools: 4; 
Number of students: 3,035; 
Number of students categorized as Limited-English Proficient (LEP): 1. 

District: Hanover Public School District; 
Common Core of Data Locale Code: 3 (urban fringe); 
Number of schools: 5;
Number of students: 2,809; 
Number of students categorized as Limited-English Proficient (LEP): 2. 

District: Greenfield Public Schools; 
Common Core of Data Locale Code: 6 (town); 
Number of schools: 7; 
Number of students: 1948; 
Number of students categorized as Limited-English Proficient (LEP): 91. 

District: Mashpee Public School System; 
Common Core of Data Locale Code: 8 (rural); 
Number of schools: 3; 
Number of students: 2,108; 
Number of students categorized as Limited-English Proficient (LEP): 6. 

North Carolina. 

District: Durham City Schools; 
Common Core of Data Locale Code: 2 (urban); 
Number of schools: 45; 
Number of students: 30,955; 
Number of students categorized as Limited- English Proficient (LEP): 
2,925. 

District: Wake County Schools; 
Common Core of Data Locale Code: 3 (urban fringe); 
Number of schools: 132; 
Number of students: 114,568; 
Number of students categorized as Limited-English Proficient (LEP): 
6,777. 

District: Lee County Schools; 
Common Core of Data Locale Code: 6 (town); 
Number of schools: 12; 
Number of students: 9,242; 
Number of students categorized as Limited- English Proficient (LEP): 
1,104. 

District: Granville County Schools; 
Common Core of Data Locale Code: 7 (rural); 
Number of schools: 14; 
Number of students: 8,674; 
Number of students categorized as Limited-English Proficient (LEP): 
452. 

District: Chatham County Schools[A]; 
Common Core of Data Locale Code: 8 (rural); 
Number of schools: 15; 
Number of students: 7,404; 
Number of students categorized as Limited-English Proficient (LEP): 
1,004. 

Ohio. 

District: Cleveland Municipal Schools; 
Common Core of Data Locale Code: (1) urban; 
Number of schools: 122; 
Number of students: 64,670; 
Number of students categorized as Limited-English Proficient (LEP): 
3,119. 

District: Shaker Heights Schools; 
Common Core of Data Locale Code: 3 (urban fringe); 
Number of schools: 9; 
Number of students: 5,737; 
Number of students categorized as Limited-English Proficient (LEP): 79. 

District: Ashtabula Area City Schools[A]; 
Common Core of Data Locale Code: 6 (town);
Number of schools: 12; 
Number of students: 4,492; 
Number of students categorized as Limited-English Proficient (LEP): 
145. 

District: Olmsted Falls City Schools; 
Common Core of Data Locale Code: 8 (rural); 
Number of schools: 4; 
Number of students: 3,388; 
Number of students categorized as Limited-English Proficient (LEP): 12. 

Source: Common Core Data. 

[A] We interviewed these officials by telephone. 

[End of table] 

[End of section] 

Appendix II: Emergency Management Planning Requirements: 

Table 17: States Reporting Selected Requirements for School Districts 
or Schools for Emergency Management Planning: 

State[A]: Alabama; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Alaska; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
X[D]; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: X. 

State[A]: Arizona; State requirement for school districts or schools to 
have emergency management plans: X[E]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Arkansas; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: California; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: X; 
Planning requirements: First responders[B] involvement in the planning 
process: X[F]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Colorado; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Connecticut; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Delaware; 
State requirement for school districts or schools to have emergency 
management plans: X[E]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: District of Columbia; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Florida; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Georgia; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: X; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: X. 

State[A]: Hawaii; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Idaho; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Illinois; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X[G]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Indiana; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Iowa; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Kansas; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Kentucky; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Maine; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: X. 

State[A]: Maryland; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: X. 

State[A]: Massachusetts; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Michigan; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Minnesota; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: X; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: X. 

State[A]: Mississippi; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Missouri; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Montana; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Nebraska; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Nevada; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: X; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: X. 

State[A]: New Hampshire; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: New Jersey; 
State requirement for school districts or schools to have emergency 
management plans: X[E]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: X. 

State[A]: New Mexico; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: X; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: X. 

State[A]: New York; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: North Carolina; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: North Dakota; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Ohio; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: X; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Oklahoma; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Oregon; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Pennsylvania; 
State requirement for school districts or schools to have emergency 
management plans: X[E]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: X*. 

State[A]: Rhode Island; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: X; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: South Carolina; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: South Dakota; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Tennessee; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Texas; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Utah; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: X; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: X. 

State[A]: Vermont; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: X; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Virginia; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: X; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: X; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Washington; 
State requirement for school districts or schools to have emergency 
management plans: X[E]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Wisconsin; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: West Virginia; 
State requirement for school districts or schools to have emergency 
management plans: [Empty]; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: [Empty]; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Wyoming; 
State requirement for school districts or schools to have emergency 
management plans: X; 
Planning requirements: Specific hazards to be included in plans: 
[Empty]; 
Planning requirements: Review or update of plans by the school district 
or some other entity: [Empty]; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: X; 
Planning requirements: Parent involvement in the planning process: 
[Empty]; 
Planning requirements: First responders[B] involvement in the planning 
process: [Empty]; 
Planning requirements: Community partners[C] involvement in the 
planning process: [Empty]. 

State[A]: Total; 
State requirement for school districts or schools to have emergency 
management plans: 32; 
Planning requirements: Specific hazards to be included in plans: 18; 
Planning requirements: Review or update of plans by the school district 
or some other entity: 18; 
Planning requirements: Requirements pertaining to drills or other 
training for teachers and/or students: 21; 
Planning requirements: Parent involvement in the planning process: 9; 
Planning requirements: First responders[B] involvement in the planning 
process: 16; 
Planning requirements: Community partners[C] involvement in the 
planning process: 10. 

Source: GAO analysis of state education agencies' and state 
administering agencies' survey responses. 

[A] Neither Louisiana's SEA nor its SAA responded to our survey. 

[B] For purposes of this report, we define first responders to include 
fire, law enforcement, EMS, and state and local emergency management 
agencies. States may define this term differently. 

[C] For purposes of this report, we define community partners to 
include public health entities, mental health entities, local heads of 
government, transportation entities, hospitals, the Red Cross, the 
faith-based community, and the business community. States may define 
this term differently. 

[D] Schools are required to form crisis response teams that include, 
among others, a parent whose child attends the school. The emergency 
management plan must include the names of these team members and their 
specific job functions relating to a crisis. However, it is not clear 
what role, if any, parents play in developing the emergency management 
plan. 

[E] The state requirement specifies that the school or district level 
plan must satisfy certain minimum requirements developed by other 
entities, such as the state department of education. 

[F] Parents may become involved in the emergency preparedness plan 
development if the school site council, otherwise tasked with plan 
development, delegates planning responsibility to a school safety 
planning committee. 

[G] Although first responders are not required to be involved in the 
development of emergency management plans, districts are required to 
invite them to participate in the annual review process. 

[End of table] 

[End of section] 

Appendix III: Homeland Security Funding Provided to School Districts: 

Table 18: States That Reported Providing Homeland Security Funding 
Directly to School Districts: 

State: Hawaii; 
Type of DHS grant awarded to states and provided to school districts: 
State Homeland Security Program: X; 
Type of DHS grant awarded to states and provided to school districts: 
Urban Areas Security Initiative: [Empty]; 
Type of DHS grant awarded to states and provided to school districts: 
Citizen Corps: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2003: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2004: $110; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2005: $71; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2006: [Empty]. 

State: Florida; 
Type of DHS grant awarded to states and provided to school districts: 
State Homeland Security Program: X; 
Type of DHS grant awarded to states and provided to school districts: 
Urban Areas Security Initiative: [Empty]; 
Type of DHS grant awarded to states and provided to school districts: 
Citizen Corps: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2003: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2004: 120; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2005: 2,282; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2006: $2,000. 

State: Florida; 
Type of DHS grant awarded to states and provided to school districts: 
State Homeland Security Program: [Empty]; 
Type of DHS grant awarded to states and provided to school districts: 
Urban Areas Security Initiative: [Empty]; 
Type of DHS grant awarded to states and provided to school districts: 
Citizen Corps: X; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2003: $34; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2004: 36; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2005: 36; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2006: 46. 

State: Michigan; 
Type of DHS grant awarded to states and provided to school districts: 
State Homeland Security Program: X; 
Type of DHS grant awarded to states and provided to school districts: 
Urban Areas Security Initiative: [Empty]; 
Type of DHS grant awarded to states and provided to school districts: 
Citizen Corps: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2003: 8,600; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2004: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2005: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2006: [Empty]. 

State: Mississippi; 
Type of DHS grant awarded to states and provided to school districts: 
State Homeland Security Program: [Empty]; 
Type of DHS grant awarded to states and provided to school districts: 
Urban Areas Security Initiative: [Empty]; 
Type of DHS grant awarded to states and provided to school districts: 
Citizen Corps: X; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2003: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2004: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2005: 66; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2006: 60. 

State: Wyoming; 
Type of DHS grant awarded to states and provided to school districts: 
State Homeland Security Program: X; 
Type of DHS grant awarded to states and provided to school districts: 
Urban Areas Security Initiative: [Empty]; 
Type of DHS grant awarded to states and provided to school districts: 
Citizen Corps: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2003: 386; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2004: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2005: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2006: [Empty]. 

State: Total; 
Type of DHS grant awarded to states and provided to school districts: 
State Homeland Security Program: [Empty]; 
Type of DHS grant awarded to states and provided to school districts: 
Urban Areas Security Initiative: [Empty]; 
Type of DHS grant awarded to states and provided to school districts: 
Citizen Corps: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2003: $9,020; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2004: $266; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2005: $2,455; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2006: $2,106. 

State: Grand total; 
Type of DHS grant awarded to states and provided to school districts: 
State Homeland Security Program: [Empty]; 
Type of DHS grant awarded to states and provided to school districts: 
Urban Areas Security Initiative: [Empty]; 
Type of DHS grant awarded to states and provided to school districts: 
Citizen Corps: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2003: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2004: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2005: [Empty]; 
Amount of grant funding provided to school districts during fiscal 
years 2003--2006 (Dollars in thousands): Fiscal year 2006: $13,847. 

Source: GAO analysis of state administering agencies' survey data. 

[End of table] 

Table 19: States and the District of Columbia That Reported Provided 
Homeland Security Funding to School Districts through Local 
Jurisdictions during Fiscal Years 2003--2006: 

State: Alabama; 
Type of grant: State Homeland Security Program: X; 
Type of grant: Urban Areas Security Initiative: [Empty]; 
Type of grant: Citizen Corps: X. 

State: District of Columbia; 
Type of grant: State Homeland Security Program: [Empty]; 
Type of grant: Urban Areas Security Initiative: X; 
Type of grant: Citizen Corps: [Empty]. 

State: Hawaii[A]; 
Type of grant: State Homeland Security Program: [Empty]; 
Type of grant: Urban Areas Security Initiative: [Empty]; 
Type of grant: Citizen Corps: X. 

State: Minnesota; 
Type of grant: State Homeland Security Program: [Empty]; 
Type of grant: Urban Areas Security Initiative: X; 
Type of grant: Citizen Corps: [Empty]. 

State: Nevada; 
Type of grant: State Homeland Security Program: X; 
Type of grant: Urban Areas Security Initiative: X; 
Type of grant: Citizen Corps: X. 

State: New Jersey; 
Type of grant: State Homeland Security Program: X; 
Type of grant: Urban Areas Security Initiative: X; 
Type of grant: Citizen Corps: [Empty]. 

State: North Dakota; 
Type of grant: State Homeland Security Program: X; 
Type of grant: Urban Areas Security Initiative: [Empty]; 
Type of grant: Citizen Corps: [Empty]. 

State: Pennsylvania; 
Type of grant: State Homeland Security Program: [Empty]; 
Type of grant: Urban Areas Security Initiative: X; 
Type of grant: Citizen Corps: [Empty]. 

State: South Dakota; 
Type of grant: State Homeland Security Program: X; 
Type of grant: Urban Areas Security Initiative: [Empty]; 
Type of grant: Citizen Corps: [Empty]. 

State: Wyoming; 
Type of grant: State Homeland Security Program: [Empty]; 
Type of grant: Urban Areas Security Initiative: [Empty]; 
Type of grant: Citizen Corps: X. 

Source: GAO analysis of state administering agencies' survey data. 

[A] Hawaii distributed DHS funding to its state education agency, which 
then provided funding to public schools in its state. 

[End of table] 

[End of section] 

Appendix IV: Guidance, Training, and Funding States Provided to School 
Districts: 

Table 20: States and the District of Columbia That Reported Providing 
Resources to School Districts to Assist in Emergency Management 
Planning: 

State: Alabama; 
Guidance provided: X; 
Training provided: X; 
State funding provided: X. 

State: Alaska; 
Guidance provided: X; 
Training provided: [Empty]; 
State funding provided: X. 

State: Arizona; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Arkansas; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: California; 
Guidance provided: X; 
Training provided: X; 
State funding provided: X. 

State: Colorado; 
Guidance provided: X; 
Training provided: [Empty]; 
State funding provided: [Empty]. 

State: Connecticut; 
Guidance provided: X; 
Training provided: X; 
State funding provided: X. 

State: Delaware; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: District of Columbia; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Florida; 
Guidance provided: X; 
Training provided: [Empty]; 
State funding provided: [Empty]. 

State: Georgia; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Hawaii; 
Guidance provided: X; 
Training provided: [Empty]; 
State funding provided: X. 

State: Illinois; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Idaho[A]; 
Guidance provided: [Empty]; 
Training provided: [Empty]; 
State funding provided: [Empty]. 

State: Indiana; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Iowa; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Kansas; 
Guidance provided: X; 
Training provided: [Empty]; 
State funding provided: [Empty]. 

State: Kentucky; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Louisiana[B]; 
Guidance provided: [Empty]; 
Training provided: [Empty]; 
State funding provided: [Empty]. 

State: Maine; 
Guidance provided: X; 
Training provided: X; 
State funding provided: X. 

State: Maryland; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Massachusetts; 
Guidance provided: [Empty]; 
Training provided: X; 
State funding provided: [Empty]. 

State: Michigan; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Minnesota; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Mississippi; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Missouri; 
Guidance provided: X; 
Training provided: X; 
State funding provided: X. 

State: Montana; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Nebraska; 
Guidance provided: X; 
Training provided: [Empty]; 
State funding provided: [Empty]. 

State: Nevada; 
Guidance provided: X; 
Training provided: [Empty]; 
State funding provided: [Empty]. 

State: New Hampshire; 
Guidance provided: X; 
Training provided: X; 
State funding provided: X. 

State: New Jersey; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: New Mexico; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: New York; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: North Carolina; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: North Dakota; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Ohio; 
Guidance provided: X; 
Training provided: X; 
State funding provided: X. 

State: Oklahoma; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Oregon; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Pennsylvania; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Rhode Island; 
Guidance provided: X; 
Training provided: [Empty]; 
State funding provided: [Empty]. 

State: South Carolina; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: South Dakota; 
Guidance provided: X; 
Training provided: [Empty]; 
State funding provided: [Empty]. 

State: Tennessee; 
Guidance provided: X; 
Training provided: X; 
State funding provided: X. 

State: Texas; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Utah[C]; 
Guidance provided: [Empty]; 
Training provided: [Empty]; 
State funding provided: [Empty]. 

State: Vermont; 
Guidance provided: X; 
Training provided: X; 
State funding provided: X. 

State: Virginia; 
Guidance provided: X; 
Training provided: [Empty]; 
State funding provided: [Empty]. 

State: Washington; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: West Virginia; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Wisconsin; 
Guidance provided: X; 
Training provided: X; 
State funding provided: [Empty]. 

State: Wyoming; 
Guidance provided: X; 
Training provided: [Empty]; 
State funding provided: [Empty]. 

State: Total; 
Guidance provided: 47; 
Training provided: 37; 
State funding provided: 11. 

Source: GAO analysis of state administering and education agencies' 
survey data. 

[A] Idaho did not provide guidance, training, or state funding to 
school districts for emergency management planning. 

[B] Louisiana's state administering and education agencies did not 
respond to our surveys. 

[C] Utah did not provide guidance, training, or state funding to school 
districts for emergency management planning. 

[End of table] 

[End of section] 

Appendix V: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20528: 

May 15, 2007: 

Ms. Cornelia M. Ashby: 
Director: 
Education, Workforce and Income Security Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Mr. William O. Jenkins, Jr. 
Director: 
Homeland Security and Justice Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Ashby and Mr. Jenkins: 

Thank you for the opportunity to review and comment on the Government 
Accountability Office's (GAO's) draft report GAO-07-609 entitled 
Emergency Management: Most School Districts Have Emergency Management 
Plans, but Would Benefit from Additional Federal Guidance. 

The draft report addresses each of the three areas of inquiry, i. e., 
respective roles of Federal and State governments and school districts 
in establishing requirements and providing resources to school 
districts for emergency management planning; school districts' efforts 
to plan and prepare for emergencies; and challenges the school 
districts have experienced in planning for emergencies; and 
communicating and coordinating with first responders, parents, and 
students. 

The data collected from school districts and States are helpful in 
identifying gaps in emergency management capabilities. 

Regarding readiness activities, the report includes various activities 
under "planning" (planning, training, equipping, exercising, etc.) To 
help determine next steps, it would be useful to know the relative 
degree to which districts report that they engage in each activity. The 
report does not estimate relative gaps among various shortfalls, such 
as guidance/technical assistance, funding, training, and equipment. 
Such estimates would help prioritize and focus next steps to address 
shortfalls. GAO may wish to consider this as an area for future study. 

The report states that fewer than half of school districts with 
emergency management plans involve community partners in developing and 
updating such plans. The report does not include the local Citizen 
Corps Council as a readily-available resource for collaboration among 
local government, private sector, and non-profit entities that should 
also include local school districts. We recommend that this be added to 
the report. 

With respect to the draft report's recommendations, we concur with the 
first recommendation directed the Department and request that the 
second recommendation be reworded. The two recommendations for the 
Department are as follows: 

Recommendation 1: Clarify that school districts are among those 
entities to which state and local governments may disburse grant funds 
received through the State Homeland Security Program, Urban Areas 
Security Initiative, and Citizens Corps (sic) grant programs. 

Response: The Department of Homeland Security (DHS) will continue to re-
affirm that school districts and universities are eligible entities of 
DHS State Homeland Security Grant funds based on the definition of 
"local units of government" in the Conference Report accompanying the 
DHS Appropriations Act of FY 2007 and the States' applicable statutes. 
The Conference Report accompanying the DHS Appropriations Act of 2007 
provides a definition of what the term "local units of government" 
means. Specifically, a local unit of government is defined as "any 
county, city, village, town, district, borough, parish, port authority, 
transit authority, intercity rail provider, commuter rail system, 
freight rail provider, water district, regional planning commission, 
council of government, Indian tribe with jurisdiction over Indian 
country, authorized Tribal organization, Alaska Native village, 
independent authority, special district, or other political subdivision 
of any State." 

DHS will continue to clarify that school districts and universities are 
eligible recipients of DHS State Homeland Security Grant funds as it 
administers its preparedness grant programs. This clarification 
currently occurs and will be re-emphasized during site visits, 
monitoring visits, seminars, workshops, town hall meetings, etc. as 
well as during day-to-day interaction and collaboration with State and 
local customers. 

Recommendation 2: With the Department of Education, identify the 
factors that prevent school districts, first responders, and community 
partners from training together and develop strategies for addressing 
those factors. 

Response: Nonconcur as written. Recommend that this recommendation be 
revised to state: .the Secretaries of DHS and Education identify the 
factors that prevent school districts, first responders, and community 
partners from training together, and promote current resources (e.g., 
local Citizen Corps Councils) and the development of new strategies for 
addressing those factors. 

Thank you again for the opportunity to comment on this draft report and 
we look forward to working with you on future homeland security issues. 

Sincerely, 

Signed by: 

Steven J. Pecinovsky:
Director: 
Departmental GAO/OIG Liaison Office: 

[End of section] 

Appendix VI: Comments from the Department of Education: 

United States Department Of Education: 
Office Of Safe And Drug-Free Schools: 

May 7, 2007: 

Ms. Cornelia M. Ashby:
Director, Education, Workforce, and Income Security Issues: 
Mr. William O. Jenkins:
Director, Homeland Security and Justice Issues: 
Government Accountability Office: 
441 G Street, N.W. 
Washington, DC 20548: 

Dear Ms. Ashby and Mr. Jenkins: 

Thank you for sharing your proposed report, "Emergency Management: Most 
School Districts Have Emergency Plans, but Would Benefit from 
Additional Federal Guidance" (GAO-07-609), and offering us an 
opportunity to comment on the draft document. 

While we share your conclusion that schools and school districts face 
many challenges in planning effectively for emergencies and that more 
work needs to be done, we believe that the results of your recent 
survey include some very positive news. The vast majority of districts 
(about 95 percent) report having written emergency plans, and nearly 
all of those plans address multiple hazards. About 85 percent of school 
districts have developed specific requirements for school emergency 
planning, and many districts are taking the important steps of 
practicing their emergency management plans and reviewing and revising 
those plans at least annually. 

The draft report contained four recommendations for executive action. 

To help address the challenges school districts face in planning for 
emergencies, we recommend that the Secretary of DHS clarify that school 
districts are among those entities to which state and local governments 
may disburse grant funds received through the State Homeland Security 
Program, Urban Areas Security Initiative, and Citizen Corps grant 
programs. This should be done through its guidance for these programs 
so that states and local governments will know they can disburse these 
program funds to school districts. 

We support the recommendation. In working with schools and school 
districts around emergency management issues in the past several years, 
we have observed that schools may not routinely be part of local 
emergency management activities. The kind of guidance recommended by 
the draft could help encourage the inclusion of school districts in 
such efforts and increase their access to available funding to support 
important emergency management activities. 

To address the lack of procedures for continuing student education in 
the event of an extended school closure, we recommend that the 
Secretary of HHS, as the lead agency on pandemics, and the Secretary of 
Education examine and identify successful strategies for developing 
such procedures and provide guidance to school districts on how to 
include the resulting procedures for the continuation of student 
education in their emergency management plans. These agencies may 
consider providing specific suggestions for states and districts to 
work with state education agencies, health departments, and local 
community organizations in the process of developing these procedures. 

We agree with this recommendation. We believe that schools will play 
several critical roles in the event of an outbreak of pandemic 
influenza, including developing and implementing procedures for 
continuing student learning in the event of an extended school closure. 
We have already identified this issue as a priority. Since fiscal year 
2006, we have required grantees under our Emergency Response and Crisis 
Management (ERCM) grant program (which we have since renamed Readiness 
and Emergency Management for Schools, or "REMS") to develop a written 
plan designed to prepare the school district for a possible infectious 
disease outbreak, such as pandemic influenza. Plans must include 
disease surveillance, school closure decision-making processes, 
business continuity issues, and continuation of educational services. 

To help school districts shelter or evacuate students with special 
needs and temporarily disabled students in an emergency, we recommend 
that the Secretary of Education, in collaboration with the Secretary of 
DHS, examine and identify successful procedures for sheltering and 
removing such students from school buildings and share these procedures 
with school districts. 

We agree with this recommendation. Students and staff with special 
needs, as well as temporarily disabled students or staff, pose special 
challenges for emergency management planning, and those needs must be 
explicitly addressed in developing plans, and in practicing and 
updating those plans. Under the REMS program, we require that 
applicants demonstrate that they have taken into consideration the 
communication, transportation, and medical needs of individuals with 
disabilities within their school district. Some grant sites have made 
incorporating information about students and staff with special needs 
an important focus of their planning and implementation efforts. We 
have shared information about some of the strategies they have 
developed in our training activities. 

But our work with school districts has also taught us that the students 
and staff with special needs have a wide range of disabilities that 
require varied and specialized responses and planning actions. We look 
forward to working with the Secretary of DHS on developing and sharing 
procedures to shelter or evacuate students or staff with special needs 
from school buildings, and remain open to a broad range of approaches 
given the evolving nature of this field. 

To promote training between school districts and first responders and 
between school districts and community partners on how to implement 
district emergency management plans, we recommend that the Secretaries 
of DHS and Education identify the factors that prevent school 
districts, first responders, and community partners from training 
together and develop strategies for addressing those factors. DHS and 
Education should share the strategies with school districts, first 
responders, and community partners and encourage them to consider 
implementing the strategies as appropriate. 

We agree with this recommendation. The challenges that schools, first 
responders, and other community partners face in collaborating to 
develop, practice, and fine tune emergency management plans are 
significant. Using the experience of our REMS grantees, and working 
with DHS, we believe that we can identify some common barriers to this 
necessary collaboration, and identify strategies that have helped some 
communities increase the extent to which school emergency management 
activities, involving all of the necessary partners, are a shared 
responsibility. 

In addition to our responses to the report's recommendations, we would 
like to express concern about the impression, conveyed at the beginning 
of the "Highlights" section of the draft report and repeated throughout 
the draft, that there are no Federal laws requiring school districts to 
have emergency management plans. While we agree that the requirements 
in 20 U.S.C. Section 7114(d)(7)(D) do not require that such plans 
address multiple hazards, the provisions do require that schools 
districts participating in the Safe and Drug-Free Schools and 
Communities Act State Grants program (which includes most school 
districts in the country) submit an assurance that they have "a plan 
for keeping schools safe and drug-free that includes . a crisis 
management plan for responding to violent or traumatic incidents on 
school grounds." In a footnote on page nine, the draft report explains 
that you have made a distinction between the current Federal 
requirement to have a plan and a Federal requirement to have a plan 
that addresses multiple hazards. Your explanation appears only in this 
one footnote, and only after the original, arguably misleading 
statement has appeared several times in the draft report. We encourage 
you to revise your statement in each of the places it appears in the 
report. We offer the following language. 

"Although the No Child Left Behind Act of 2001 requires school 
districts participating in the Safe and Drug-Free Schools and 
Communities Act State Grants program to submit an assurance that they 
have a crisis management plan for responding to violent or traumatic 
incidents on school grounds, there are no federal laws requiring school 
districts to have emergency management plans that address multiple 
hazards." 

Under separate cover, we have transmitted some additional technical 
comments that we hope will be helpful to you as you finalize the draft 
report. 

Again, thank you for sharing the report with us and allowing us the 
opportunity to submit comments concerning your draft. I hope that you 
will let me know if we can provide any clarifying information about the 
comments and concerns contained in this letter, or assist in any other 
way as you finalize your report on this very important issue. 

Sincerely, 

Signed by: 

Deborah A. Price: 
Assistant Deputy Secretary: 

[End of section] 

Appendix VII: Comments from the Department of Health & Human Services: 

Department Of Health & Human Services: 
Office of the Assistant Secretary for Legislation: 
Washington, D.C. 20201: 

May 8 2007: 

Ms. Cornelia M. Ashby: 
Director, Education, Workforce, And Income Security Issues: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

Dear Ms. Ashby: 

Enclosed are the Department's comments on the U.S. Government 
Accountability Office's (GAO) draft report entitled, "Emergency 
Management: Most School Districts Have Emergency Management Plans, but 
Would Benefit from Additional Federal Guidance" (GAO-07-609). 

The Department appreciates the opportunity to review and comment on 
this draft before its publication. 

Sincerely, 

Signed by: 

Vincent J. Ventimiglia: 
Assistant Secretary for Legislation: 

General Comments Of The Department Of Health And Human Services (HHS) 
On The Government Accountability Office's (GAO) Draft Report Entitled: 
Emergency Management: Most School Districts Have Emergency Management 
Plans, But Would Benefit From Additional Federal Guidance (GAO 07-609): 

HHS Comment: 

"To address the lack of procedures for continuing student education in 
the event of an extended school closure, we recommend that the 
Secretary of HHS, as head of the lead agency on pandemics, and the 
Secretary of Education examine and identify successful strategies for 
developing such procedures and provide guidance to school districts on 
how to include the resulting procedures for the continuation of student 
education in their emergency management plans." 

HHS and Education work closely on issues related to pandemic influenza 
and school closures. While HHS provides leadership on health-related 
issues such as reducing disease transmission, Education leads 
activities related to the educational process, including continuation 
of education. Therefore, this recommendation should be rewritten to 
place Education as the lead, with support from HHS. 

It might be appropriate to include HHS in the recommendation on 
identifying successful procedures for helping students with special 
needs. CDC/NCBDDD would be able to provide expertise in this area. 

Technical Comments Of The Department Of Health And Human Services (HHS) 
On The Government Accountability Office's (GAO) Draft Report Entitled: 
Emergency Management: Most School Districts Have Emergency Management 
Plans, But Would Benefit From Additional Federal Guidance (GAO 07-609): 

Throughout the report there is reference to "special needs" individuals 
(students or the general population). It should be noted in the report 
that the disability community throughout the nation has been involved 
in reaching consensus on the definition of "special needs" for the 
pending National Response Plan (NRP) which is currently under revision. 

One consensus definition of special needs will help facilitate 
awareness and planning for special needs populations and hopefully 
result in Federal, State, and local agencies reaching out to those 
populations and including them as partners in emergency planning and 
response. Once the revised NRP is approved, it would be beneficial for 
the school districts to adopt the NRP "special needs" definition to 
ensure better awareness and preparedness in all communities and ensure 
consistency throughout the nation. 

[End of section] 

Appendix VIII: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Cornelia M. Ashby (202) 512-7215, ashbyc@gao.gov: 

William O. Jenkins, Jr. (202) 512-8757, jenkinswo@gao.gov: 

Acknowledgments: 

Kathryn Larin (Assistant Director), Debra Sebastian (Assistant 
Director), and Tahra Nichols (Analyst-in-Charge) managed all aspects of 
this assignment. Benjamin Jordan, Meaghan Marshall, and Kris Trueblood 
made significant contributions to this report. Krista Anderson, 
Jennifer Gregory, Lise Levie, and Paul Revesz also made contributions 
to this report. Sue Bernstein and Katherine Davis contributed to 
writing this report. Jim Ashley, Jean McSween, Amanda Miller, and Joan 
Vogel provided key technical support. Sheila McCoy provided legal 
support. 

FOOTNOTES 

[1] For purposes of this report, we use the term "emergency management 
funding" to describe emergency preparedness funding DHS provides to 
states. 

[2] Under its Homeland Security Grant Program, DHS provides a range of 
grants to states and local governments for emergency management. Based 
on our analysis and discussions with DHS officials, the State Homeland 
Security Program, Urban Areas Security Initiative, and Citizen Corps 
grants are the only grants for which states and local governments can 
disburse funds to school districts. The State Homeland Security Program 
provides funds to enhance the emergency preparedness of state and local 
governments. The Urban Areas Security Initiative grant is awarded to 
some states with high threat and high density urban areas that need 
planning, exercises, equipment, and training to respond to acts of 
terrorism. Citizen Corps funds are provided to states to promote 
volunteer efforts. 

[3] In both our site visits and our survey of school districts, we 
focused on the traditional definition of first responders--law 
enforcement, fire, and EMS. However, the Homeland Security Act, as 
amended, includes a broader definition of emergency response providers, 
including "Federal, State, and local governmental and nongovernmental 
emergency public safety, fire, law enforcement, emergency response, 
emergency medical (including hospital emergency facilities), and 
related personnel, agencies, and authorities." Homeland Security Act of 
2002, Pub. L. No. 107-296, § 2, (codified at 6 U.S.C. § 101(6)). 
Homeland Security Presidential Directive 8 defined the term "first 
responder" as "individuals who in the early stages of an incident are 
responsible for the protection and preservation of life, property, 
evidence, and the environment, including emergency response providers 
as defined in section 2 of the Homeland Security Act of 2002, as well 
as emergency management, public health, clinical care, public works, 
and other skilled support personnel (such as equipment operators) that 
provide immediate support services during prevention, response, and 
recovery operations." 

[4] Pub. L. No. 107-296. 

[5] The Robert T. Stafford Disaster Relief and Emergency Assistance 
Act, Pub. L. No. 100-707, provides the legal framework for this 
partnership. The Stafford Act is the principal federal statute 
governing federal disaster assistance and relief and primarily 
establishes the programs for and processes by which the federal 
government may provide major disaster and emergency assistance to 
states and local governments. The Stafford Act also provides emergency 
assistance to tribal nations, individuals and qualified private non- 
profit organizations. The Federal Emergency Management Agency (FEMA) is 
the principal federal agency responsible for implementing the Stafford 
Act. 

[6] GAO, Homeland Security: Preparing for and Responding to Disasters, 
GAO-07-395T (Washington, D.C.: Mar. 9, 2007); and, Catastrophic 
Disasters: Enhanced Leadership, Capabilities, and Accountability 
Controls Will Improve the Effectiveness of the Nation's Preparedness, 
Response, and Recovery System, GAO-06-618 (Washington, D.C.: Sept. 6, 
2006). 

[7] 20 U.S.C. § 7114(d)(7)(D). The plans required under the No Child 
Left Behind Act of 2001 are not required to address multiple hazards; 
therefore, for purposes of this report, we do not consider this to be a 
requirement for an emergency management plan. 

[8] The purpose of the ERCM grant program is to provide funds for local 
education agencies to improve and strengthen their emergency response 
plans. School districts receiving grant funds under this program may 
use them to develop improved plans that address all four phases of 
crisis response: prevention/mitigation, preparedness, response, and 
recovery. In April 2007, Education announced that it was renaming the 
ERCM grant as the Readiness and Emergency Management for Schools grant 
program (REMS) to reflect terminology used in the emergency management 
field. This notice also invited applications for grant funds, with 
Education estimating that $24 million will be available to applicants 
in amounts ranging from $100,000 to $500,000 per school district. In 
awarding grants, Education will give priority to districts that have 
not previously received an ERCM grant and that are located in a UASI 
jurisdiction. Applications must address, among other things, how 
districts will coordinate their efforts with law enforcement, public 
safety, public health, mental health, and local government entities, as 
well as how the applicant will address the needs of individuals with 
disabilities. Applicants must also agree to develop an infectious 
disease plan that includes plans for continuing education services. 72 
Fed. Reg. 17,139 (Apr. 6, 2007). 

[9] As reported by the states to the Department of Education and 
contained in the Common Core Data (CCD), there were over 17,000 school 
districts in the United States in school year 2003-04. This number 
includes school districts in Puerto Rico; four outlying areas (American 
Samoa, Guam, Northern Marianas, and the U.S. Virgin Islands); the 
Bureau of Indian Affairs and the Department of Defense, which were 
eligible for funds but we excluded from the sample for our survey of 
school districts. While Department of Defense schools are included in 
the CCD count of school districts, Education officials said that such 
schools are not eligible to receive funding under the ERCM/REMS grant 
program. 

[10] The Incident Command System is a standard incident management 
system to assist in managing all major incidents. The Incident Command 
System also prescribes interoperable communications systems and 
preparedness before an incident happens, including planning, training, 
and exercises. The Incident Command System was developed in the 1970s 
following a series of catastrophic fires. Researchers determined that 
response problems were more likely to result from inadequate management 
rather than from any other reason. The Incident Command System was 
designed so that responders from different jurisdictions and 
disciplines could work together better to respond to natural disasters 
and emergencies, including acts of terrorism. NIMS includes a unified 
approach to incident management: standard command and management 
structures, and emphasis on preparedness, mutual aid, and resource 
management. 

[11] A ninth state distributed DHS funding to its state education 
agency, which then provided the funding to public schools in its state. 

[12] DHS guidance for these grant programs provides that state 
administering agencies are the only agencies eligible to apply for 
funding and that they are responsible for disbursing grant funds to 
local units of government and other designated recipients. The guidance 
identifies a definition of "local unit of government" which includes 
"any county, city, village, town, district, borough, parish, port 
authority, transit authority, intercity rail provider, commuter rail 
system, freight rail provider, water district, regional planning 
commission, council of government, Indian tribe with jurisdiction over 
Indian country, authorized Tribal organization, Alaska Native village, 
independent authority, special district, or other political subdivision 
of any State." 

[13] We included the District of Columbia in our state education and 
state administering agency surveys. 

[14] Under Connecticut law, local boards of education, working in 
conjunction, are permitted to establish regional educational services 
centers, which provide programs and services to schools within their 
designated regions. Conn. Gen. Stat. § 10-66a. 

[15] There were 285 schools (1 school district) in Hawaii as reported 
by the state to the U.S. Department of Education. 

[16] An automated external defibrillator (AED) is a portable electronic 
device that diagnoses and treats cardiac arrest by re-establishing an 
effective heart rhythm. 

[17] Education, for example, also obtained input from state and local 
school and emergency management officials and associations in 
developing these recommended practices. 

[18] See GAO-07-395T and GAO-06-618. 

[19] Those school districts that did not have a written emergency 
management plan cited several reasons for the lack of such plans that 
included (1) no requirement to have a written plan, (2) inadequate 
resources for experienced personnel to develop emergency plans, and (3) 
schools, not the district, have individual plans. 

[20] The difference between two estimates is statistically significant 
if the probability that the observed or greater difference is due to 
chance alone is less than 5 percent (95 percent confidence level). 

[21] See footnote 10, page 13. 

[22] National Education Association and National Association of School 
Psychologists. 

[23] Each student identified as having a disability under the 
Individuals with Disabilities Education Act (IDEA) is required to have 
an Individualized Education Program. This document outlines the 
delivery of educational services and support for that student. While 
law dictates minimum requirements for the type of information included 
in the program, states and school districts have flexibility in 
including additional information in such programs. 

[24] At a national level, there is also a lack of agreement about a 
definition of special needs individuals for the purposes of emergency 
management. HHS officials noted that one definition of special needs 
individuals, currently being considered for the next revision of the 
National Response Plan, will help facilitate awareness and planning for 
special needs populations with regard to emergency management. 

[25] In at least one school district, Seattle, these plans are included 
in the district's Continuity of Operations Plan, which is separate from 
its emergency management plan. 

[26] In our survey, community partners included representatives from: 
public health, mental health, local head of government, transportation, 
hospitals, Red Cross, faith-based community, and the business 
community. 

[27] Twelve percent of school districts do not know whether public 
health agencies were included in the development and update of plans. 
Thirteen percent of districts do not know whether the local head of 
government was included in the development and update of plans. 

[28] This is how we defined an SRO in our survey. 

[29] Through its COPS (Community Oriented Policing in Schools) in 
Schools (CIS) program, the Department of Justice provides three-year 
grants that schools may use to hire SROs. The program was designed in 
part to provide assistance to law enforcement agencies to help combat 
violence and reduce the fear of crime in schools by deploying police 
officers as SROs. 

[30] See GAO-06-618. 

[31] See GAO-06-618. 

[32] Districts allocate staff development days to assist teachers and 
other staff with improving skills, provide training, and meet 
certification requirements, among other activities. 

[33] Two-way radios, commonly known as walkie-talkies, are radios that 
can alternate between receiving and transmitting messages. Cellular 
telephones and satellite telephones are also two-way radios but, unlike 
walkie-talkies, simultaneously receive and transmit messages. 

[34] Three districts, Hardee County, Florida; Ashtabula, Ohio; and 
Durham, North Carolina, reported needing a full-time staff person to 
train staff. Two districts, Olmsted Falls, Ohio, and Hanover, 
Massachusetts, reported needing a full-time staff person to update the 
district plan. 

[35] At the time of our visit, the school district used this practice 
for its special needs students. However, in a subsequent e-mail message 
a district official noted the district no longer uses students as 
buddies. 

[36] The Americans with Disabilities Act of 1990 and Section 504 of the 
Rehabilitation Act of 1973 generally require that school facilities be 
accessible to individuals with disabilities, although there is some 
variation in requirements depending on whether a building is new or 
existing. The ADA Accessibility Guidelines for Buildings and Facilities 
specify the technical requirements for accessibility and address such 
issues as the design of doorways, stairwells, elevators, and ramps. 

[37] Thirteen percent of school districts reported not knowing whether 
the district has challenges related to first responders. 

[38] GAO has reported on the range of issues associated with the lack 
of interoperability among first responders and the implications of 
these issues for emergency management. For a fuller discussion of these 
issues, see the following GAO reports: First Responders: Much Work 
Remains to Improve Communications Interoperability, GAO-07-301 
(Washington, D.C.: Apr. 2, 2007); Catastrophic Disasters: Enhanced 
Leadership, Capabilities, and Accountability Controls Will Improve the 
Effectiveness of the Nation's Preparedness, Response, and Recovery 
System, GAO-06-618 (Washington, D.C.: Sept. 6, 2006); and Homeland 
Security: Federal Leadership and Intergovernmental Cooperation Required 
to Achieve First Responder Interoperable Communications, GAO-04-740 
(Washington, D.C.: July 20, 2004). 

[39] National Education Association, American Association of School 
Administrators, and National Association of Secondary School 
Principals. 

[40] We arrived at our target population of 14,432 by eliminating 
certain types of school districts such as: local school districts that 
are not a component of a supervisory union, state-operated institutions 
charged, at least in part, with providing elementary and/or secondary 
instruction or services to a special-need population; federally 
operated institutions charged, at least in part, with providing 
elementary and/or secondary instruction or services to a special-need 
population, districts with less than one student or one school, 
agencies run by the Department of Defense or Bureau of Indian Affairs, 
and districts in U.S. territories. 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site (www.gao.gov). Each weekday, GAO posts 
newly released reports, testimony, and correspondence on its Web site. 
To have GAO e-mail you a list of newly posted products every afternoon, 
go to www.gao.gov and select "Subscribe to Updates." 

Order by Mail or Phone: 

The first copy of each printed report is free. Additional copies are $2 
each. A check or money order should be made out to the Superintendent 
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 
more copies mailed to a single address are discounted 25 percent. 
Orders should be sent to: 

U.S. Government Accountability Office 441 G Street NW, Room LM 
Washington, D.C. 20548: 

To order by Phone: Voice: (202) 512-6000 TDD: (202) 512-2537 Fax: (202) 
512-6061: 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm E-mail: fraudnet@gao.gov 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 U.S. 
Government Accountability Office, 441 G Street NW, Room 7125 
Washington, D.C. 20548: 

Public Affairs: 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800 
U.S. Government Accountability Office, 441 G Street NW, Room 7149 
Washington, D.C. 20548: