Final Response from Department
Ms. Debra Newman April 19, 2007
Office of the Budget Analyst
1390 Market Street Suite 1025
San Francisco, CA 94102
RE: Response to the Draft Board of Supervisor's Budget Analyst Report of April 2007- Status of Implementation of Recommendations
Introduction
We were happy to receive the most recent report from the Budget Analyst regarding the status of many of the items recommended by their office in their May 6, 2006 Management Audit. We have been working diligently to complete many of the thoughtful recommendations as reported by the Budget Analyst's office, and, as noted in their report, according to their analysis we have completed, substantially completed or significantly made progress on a total of 40 recommendations (or 88%) of the 65 recommendations with which we agreed, despite significant staff reductions. (There were seven recommendations we did not agree with). In addition, we have demonstrated we are in the planning stages for another 23 recommendations.
This process has been very helpful to our office and we have taken the recommendations very seriously. When the report was completed in May of 2006, we had a total of 23 FTE positions filled. We currently have a total of 17 FTE positions filled. While this loss of personnel, in combination with other factors, contributed to the delay in the Strategic Plan process, we are confident in the progress made to date by our vendor. The active participation and commitment in the development of this plan will require a great deal of time and effort on the part of our staff as well as members of other City department.
Since the Strategic Plan will not be completed in time to influence this budget submission, we are currently in the process of working with the Mayor's Budget staff to identify the number of positions sufficient to both complete the BOS audit recommendations and the substantial work required in several keys areas related to the preparedness, mitigation of disasters, effective logistical management and recovery in the FY 2007/2008 budget.
Other Significant Areas of Implementation
It is important to note our progress and to realize that while working on the recommendations made by the Budget Analyst, we were also working on additional critical activities towards mitigation, preparedness and recovery planning that were not mentioned in the report, but are essential to insuring the effectiveness of this office. Some initiatives in progress include: The Disaster Services Worker program in collaboration with DHR; becoming a Tsunami Ready City; continued work on development of a logistics planning roadmap including the use of Plan Ready tracking; participation in the SUASI process for the Bay Area; Community Disaster Planning in collaboration with DPH; development of alerting and emergency notification protocols; continued public outreach and education; Department Emergency Plans review; revision of the City Emergency Operations Plan; development and presentation of relevant workshops on subjects such as Operation Return, Caring for Special Needs Populations; Pet and Animal Issues, etc.; coordination with renovation of the City Emergency Operations Center; continued NIMS and ICS compliance training; coordination of the Disaster Council, Disaster Preparedness Coordinators, Homeland Security Steering Task Force and Homeland Security Executive Committee meetings; and others.
Other initiatives in various stages of development are: PIO training for emergencies; more organized and robust collaboration with the business community; liaison and training for schools; liaison with colleges and universities; development of agreements with taxis, bicycle messengers and other private transportation entities for disaster response in coordination with a comprehensive volunteer management program; recovery efforts in coordination with the recently drafted Community Safety Element plan; and others.
Following you will find some observations regarding noted areas of concern and areas of disagreement that our office makes to contribute to the context of your narratives and offers our perspective on each item.
Areas of Continued Concern
Recommendation 3.1: Senior Management of the Division of Emergency Services should conduct a robust strategic planning process. This process should include appropriate stakeholders, such as the Mayor and the members of the Board of Supervisors, leaders of City Departments, and private and non-profit organizations. The Division of Emergency Services should utilize any resources produced by previous administrations in carrying out this process. The strategic plan should address and prioritize planning, response, mitigation, and recovery activities based on the risk and capabilities assessment, as well as organizational goals and capacity. The Office of Emergency Services should review plans for other jurisdictions to help guide this process.
Recommendation 3.2: Senior management of the Division of Emergency Services should move forward with a thorough assessment of the City's emergency services capabilities. The Division of Emergency Services should use the identified gaps in capabilities to help prioritize efforts, such as training, within the strategic plan.
Our department, as recommended by the Budget Analyst's report, embraced the Strategic Planning process, and the process began in late September of 2006. As you remember, the department received a new director and deputy director in July 2006 and, once we had time to transition into our new positions, we began to work on this project in earnest. This transition was complicated by the reduction of a staff position that was assigned to SUASI chair/management activities. The reduction of this position moved all responsibilities for regional coordination management (not just meeting attendance) to one Executive Director during the height of the 2006 SUASI award process and beginning of the 2007 grant application process. This coupled with the additional supporting staff reductions placed huge demands on staff within a short period of time required to fulfill the recommendations and aggressively drive the labor intensive and complex San Francisco procurement processes. Realizing that the Strategic Planning process is the most significant undertaking of this department since 1989- we have placed the highest priority and value on the product. We know that it will define our mission and future of our City. We want to make sure that we get it right. One of the underlying themes of the original report was the identification of problems in communicating and working with other City departments. My office worked to ensure the participation of the main stakeholder departments in the review of the RFP and in the eventual selection process that resulted in ICF as our vendor. The end result is especially beneficial in a project of this magnitude where stake holder buy-in and participation is essential. On the other hand, this type of concentrated collaboration entails a significant output of time and resources to organize the vendor presentations on dates when all reviewers can attend. We narrowed it down to three vendors in October and requested an additional presentation from those three that occurred in early December, at which time we selected ICF as our contractor. Once selected, we began the required process to finalize the contract. This included: a review and approval by the Civil Service Commission; development of the actual contract; review of the contract by the vendor and subsequent negotiations; review by the City's risk manager; review by the City Attorney; final approval of the contract; collection and approval of the required Human Rights and insurance documents; signatures from ICF; signatures from DEM; and final approval from OCA. We are happy to report that ICF has been working with our office since March and is engaged in a preliminary comparative analysis with other emergency management agencies in large cities with similar demographics. Additionally, we have scheduled an all day major kick-off meeting with City departments and other stakeholder agencies for April 24, 2007.
Recommendation 3.3: Senior management of the Division of Emergency Services should establish appropriate performance measures. The Division of Emergency Services should seek help in this effort from the Controller's Office, as appropriate, as the City's lead agency for performance measure development. The Division of Emergency Services should use any existing tools, such as After Action Reports, as a foundation for these measures.
Recommendation 3.4: The Division of Emergency Services should participate in the SFstat process. As part of its participation, the Division of Emergency Services should establish performance measures to help hold other City Departments accountable for carrying out emergency preparedness activities.
We have developed a number of performance measures that we provided to the Controller's Office for consideration. At this point, our performance measures are related to our department, not to other departments. The original Budget Analyst report recommended that we be responsible for the performance of other City departments as it relates to disaster preparedness. While we do regularly discuss issues with those departments, we believe the department heads need to be engaged and accountable in this process. As noted in the current Budget Analyst report, we will be working very closely with other City departments on the Strategic Plan and one of the outcomes we hope to achieve, in collaboration with those City departments, are specific performance measures, that are outcome oriented, and that are specific by department to disaster preparedness.
As also noted in the Budget Analyst report, we have been invited to participate in the SFStat program and will do our best to provide information that is meaningful and truly measures our performance. We believe that this will become fully achievable when we complete the strategic plan process and adopt recommendations, along with other City departments
Recommendation 5.2: The Grants Division of the Office of Emergency Services should develop and follow clear financial policies and procedures to ensure expedited grant reimbursement for future expenditures. In doing so, the Grants Division of the Office of Emergency Services should claim reimbursement-eligible expenditures as frequently as possible, but at least more frequently than on a quarterly basis.
In June of 2006, as a result of this recommendation, our grants staff held a workshop and presented clear financial guidelines to the various departments that were receiving grant funding. We followed up with regular meetings and correspondence with department financial staff. These clear guidelines and the enhanced communication allowed us to work with the departments to insure that all required documentation was submitted to us so we could, in turn insure that all grants were fully expended and that all reimbursements were submitted to the State within proper time periods. Additionally, in October of 2006, we implemented corresponding project areas in FAMIS to assist us in more expeditious reconciliation of grants issued in 2005 and 2006.
As recognized in the Budget Analyst's report, in 2006 when we were managing nine grants, we submitted a total of 47 claims requesting and receiving reimbursement for a total of over 39 million dollars. For the first quarter of 2007 we have submitted 15 claims for reimbursement. Once departments have submitted all required documents, each reimbursement request takes approximately 40 hours to complete. We currently have three people assigned to our grants management staff and one person on loan from the Controller's office. At times, we have had additional staff from the Controller's office to assist us. Each of the reimbursement requests involves detailed reconciliation and tracking. To put the amount of work and the efficiency of that work into context, we need to recognize that reimbursement claims represent only a portion of work that is required in order to apply for, receive, organize, and process the grants. This does not even begin to account for the additional required reporting; monitoring visits and reports as well as audits.
With the award of the 2006 Homeland Security grants, we will not be providing advanced funding to individual departments as was previously the case. Instead we will be asking departments to follow clear financial guidelines to insure their reimbursement. The ability for us to claim reimbursement from the State more frequently will continue to be dependent upon the various departments' timely submission of required, complete documentation and adherence to those guidelines as well as the availability grant management staff. We will continue to work closely with departments to insure that we can all be successful together. We will be presenting workshops in early May to departments' financial staff to provide them with clear financial guidelines for the 2006 grants and introduce them to this change in procedure. In addition, we will continue to engage in the close contact and coordination that we have previously established.
While some of the grants have diminished in amount, we expect we will be tasked with new duties including administration of the Port Security Grant, assistance with the administration of the SUASI grants and expected involvement with the Public Safety Interoperable grant, of a substantial amount, for the regional radio project for the Bay Area SUASI .
Recommendation 6.10: The Division of Emergency Services should report on the status of functional, hazard-specific and City Department Emergency Plans during the annual Board of Supervisors State of the City's Disaster Preparedness Hearing.
Our office will be pleased to participate in this hearing whenever it is scheduled.
Recommendation 9.1: As required by the Mayor's January 9, 2004 Directive for Emergency Preparedness, the Division of Emergency Services should develop plans to mobilize key City departments such as Public Health, Human Services and Building Inspection for Phase II recovery of critical infrastructure and services.
We will be concentrating more on these issues in the next six months. We will be reviewing the strategy developed in the Community Safety Element Plan and working to incorporate it into our recovery plans. We anticipate hiring a contractor to work on Seismic Safety as well as Recovery in the next few months. In addition, the grant application for 2007 State Grant funding includes guidelines that will allow seismic safety evaluations and we will be seeking funding along those lines.
Recommendation 11.6: Following corrective action, City Departments tasked with making improvements should report back on their progress in a public forum so that all Departments can be aware of changes and improvements Citywide.
As noted in your report, this is occurring during the bi-monthly Disaster Preparedness Coordinators meetings. Our goal is to encourage improvement so besides using this formal, public method we first attempt to work with the appropriate department representatives.
Areas of Disagreement
Recommendation 1.3: The Disaster Council should review each City emergency plan, annex, mutual-aid agreement, or report and should determine which plan, annexes, agreements, and reports to forward to the Board of Supervisors for public hearing and implementation.
We do not believe that this recommendation represents a serious area of disagreement. While the letter of the law may make the process of the development and implementation of plans through the Disaster Council inefficient and cumbersome, the intent is being met through the Disaster Preparedness Coordinators and other department representatives of members of the Disaster Council attending regular meetings with our office and developing and implementing emergency plans. A review of section 7.4 of the Administrative Code does not call for the Disaster Council to review each City emergency plan, annex or report. It does call for the Disaster Council to develop plans and to then recommend for consideration and adoption by the Board of Supervisors such ordinances, resolutions and regulations necessary to implement such plans. The implementation of most plans does not require the use of ordinances, resolutions and/or regulations. That being said, we recognize that our office has been inconsistent in the use of the Disaster Council and has generally used the meetings as a forum to share information. We will be forming a task force in June, which will include a member of the City Attorney's office to explore whether or not we can insure compliance without compromising effectiveness or if and how to revise the Administrative Code to insure that the intent of the legislation remains while the execution or description of how that is achieved is adjusted to make the process more efficient and practical. The Homeland Security Executive Steering Committee will review the recommendation that comes out of the task force and, if a revision of the Administrative Code is recommended, will determine whether or not to go forward with proposed legislation.
Recommendation 5.3: The Grants Division of the Office of Emergency Services should implement policies and procedures for claiming advanced reimbursement on encumbered funds as appropriate.
We have reviewed the feasibility of this recommendation and do not agree that it is feasible at this time. We believe the situation has been accurately discussed in the Budget Analyst's report and that this recommendation should be modified.
Recommendation 8.5: The Division of Emergency Services should equip all Department Emergency Operations Centers with the emergency supplies necessary to meet the City's 72-hour personal preparedness standard. In doing so, the Division of Emergency Services should have a plan for care and shelter of response personnel that, at a minimum, meets the City's 72-hour personal preparedness standard.
Our department recognizes this issue as a main concern of the Logistics group, however as noted in the Budget Analyst's report, we do not have the resources to provide each department with these supplies. We have scheduled a team of logistics experts during the week of May 21st to meet with the logistic representatives from City departments to assess our logistics situation, including the one contained in this recommendation, and work with our stake holder departments to develop a concept of operations.
Recommendation 8.1: The Division of Emergency Services should work with City departments to develop outcome oriented performance measures that will measure City departments' abilities to implement response protocols.
Recommendation 10.3: The Division of Emergency Services should develop performance measures that evaluate emergency responders' ability to perform Federal target capabilities and identified local capabilities and should pre- and post-test training participants.
Recommendation 11.7: The Division of Emergency Services should develop a system, such as performance measures, for making City departments accountable for improvement. To increase accountability, the Division of Emergency Services should report on these performance measures during the annual Board of Supervisors State of Disaster Preparedness hearing.
The above three recommendations, along with the following three recommendations identified as areas of concern in your report, are all connected to the development and implementation of the Strategic Plan.
o Recommendation 3.1 Development of a Strategic Plan,
o Recommendation 3.3 Establishment of Appropriate Performance Measures, and,
o Recommendation 3.4 Participation in SFStat
We do not disagree that there needs to be an ability to evaluate and measure the performance of departments engaged in disaster planning and response, but we do believe that using the strategic plan to coordinate this process among City departments will result in a much better product and provide a system of accountability meets the intent of the recommendations 3.3, 3.4, 8.1, 10.3 and 11.7. We also recognize our duty to work closely with departments to achieve this goal.
Conclusion
We appreciate the time that you and members of your office spent with our staff in reviewing our current performance. We also appreciate your recognition that the efficiency, economy and effectiveness of the Division of Emergency Services has greatly improved since the completion of the Management Audit. Our staff continues to take your recommendations very seriously and is dedicated to providing the best product possible for the City and County of San Francisco.
Sincerely,
Laura Phillips
Executive Director