Lessons Learned from
DHS’ Employee COVID-19
Vaccination Initiative
May 10, 2022
OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Washington, DC 20528 / www.oig.dhs.gov
0D\
MEMORANDUM FOR: Alejandro N. Mayorkas
Secretary
Department of Homeland Security
FROM: Joseph V. Cuffari, Ph.D.
Digitally signed by
JOSEPH V
JOSEPH V CUFFARI
Inspector General
Date: 2022.05.10
CUFFARI
09:00:59 -04'00'
SUBJECT: Lessons Learned from DHS’ Employee COVID-19
Vaccination Initiative
Attached for your information is our final report, Lessons Learned from DHS’
Employee COVID-19 Vaccination Initiative. We incorporated the formal
comments from DHS in the final report.
The report contains one recommendation to improve DHS’ ability to identify
essential employees, when necessary, in future operations. Your office
concurred with the recommendation. Based on information provided in your
response to the draft report, we consider the recommendation resolved and
open. Once your office has fully implemented the recommendation, please
submit a formal close out letter to us within 30 days so we may close the
recommendation. The letter should be accompanied by evidence of completion
of agreed upon corrective actions. Please send your response or closure
requests to [email protected].
Consistent with our responsibility under the Inspector General Act, we will
provide copies of our report to congressional committees with oversight and
appropriation responsibility over the Department of Homeland Security. We
will post the report on our website for public dissemination.
Please call me with any questions, or your staff may contact Thomas Kait,
Deputy Inspector General for the Office of Inspections and Evaluations, at
(202) 981-6000.
Attachment
DHS OIG HIGHLIGHTS
Lessons Learned from DHS’ Employee COVID-19
Vaccination Initiative
May 10, 2022
Why We
Did This
Evaluation
On December 18, 2020,
DHS partnered with the
Veterans Health
Administration to vaccinate
certain eligible DHS
employees against COVID-
19. We evaluated how
DHS determined employee
status for placement into
priority distribution groups
for vaccination. Also, we
examined how DHS
planned to triage and
distribute available vaccine
inventory and how DHS
executed its plan.
What We
Recommend
We make one
recommendation to
improve DHS’ ability to
identify essential
employees, when
necessary, in future
emergency situations.
For Further Information:
Contact our Office of Public Affairs at
(202) 981-6000, or email us at
What We Found
In advance of Federal approval for emergency use of the
Coronavirus Disease of 2019 (COVID-19) vaccine, DHS
prepared to coordinate employee vaccinations by tasking
its components to identify eligible personnel in health care
and frontline occupations in accordance with Centers for
Disease Control and Prevention guidelines. DHS acted
swiftly to identify employees in vaccination priority groups,
but provided minimal guidance to components, resulting in
inconsistent responses across the Department as to which
types of employees were deemed eligible. DHS only
partially committed staff resources and delayed
establishing a comprehensive, full-time task force to
manage the effort. Also, at times, DHS’ communications to
its employees were inconsistent or unclear, causing
confusion among some employees. DHS successfully
vaccinated some employees, but missing and erroneous
personnel data in DHS systems used to facilitate
vaccinations contributed to DHS falling short of reaching
its vaccination goals.
This report identifies areas of consideration for DHS to
better prepare for future emergencies and pandemics. We
make one recommendation to improve DHS’ ability to
identify essential employees, when necessary, in future
emergency situations. Also, DHS should consider
improving its preparedness by developing incident
response protocols that include a plan for establishing and
staffing an incident response team. To foster trust among
its workforce, DHS should strive to communicate directly
and consistently with personnel during future initiatives.
Finally, DHS should consider devising and implementing a
methodology for conducting oversight of employee data.
DHS Response
DHS concurred with the recommendation. We included a
copy of DHS’ response in Appendix B.
www.oig.dhs.gov OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Table of Contents
Background .................................................................................................... 3
Results of Inspection....................................................................................... 4
DHS Acted Swiftly to Identify Eligible Employees, but Limited Guidance
for Components Resulted in Inconsistencies .......................................... 5
DHS Was Slow to Establish a Comprehensive Task Force to Manage
Vaccinations for Eligible Employees ....................................................... 7
DHS Communications to the Workforce Were Misleading and Unclear ... 9
Missing and Erroneous Personnel Data in DHS Systems Hampered DHS’
Ability to Meet Its Employee Vaccination Goal...................................... 13
Conclusion.................................................................................................... 15
Recommendation .......................................................................................... 15
Management Comments and OIG Analysis ................................................... 15
Appendixes
Appendix A: Objective, Scope, and Methodology ................................. 17
Appendix C: Timeline of Events and Milestones Associated with DHS
Appendix D: Comparison of DHS OIG Areas of Consideration and
Appendix E: Office of Inspections & Evaluations Major Contributors to
Appendix B: DHS Comments to the Draft Report ................................. 18
Employee Vaccination Initiative ........................................................... 21
Operation VOW After-Action Report Key Findings ................................ 23
This Report ....................................................................................... 24
Appendix E: Report Distribution .......................................................... 25
Abbreviations
CBP U.S. Customs and Border Protection
CDC Centers for Disease Control and Prevention
CMO Chief Medical Officer
COVID-19 Coronavirus Disease 2019
CWMD Countering Weapons of Mass Destruction Office
EUA Emergency Use Authorization
FEMA Federal Emergency Management Agency
www.oig.dhs.gov 1 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
GAO Government Accountability Office
LOE line of effort
MCO mission critical occupation
MOU memorandum of understanding
OCHCO Office of the Chief Human Capital Officer
TSA Transportation Security Administration
VOW Vaccinate Our Workforce
VA Veterans Affairs
VHA Veterans Health Administration
www.oig.dhs.gov 2 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Background
On March 11, 2020, the World Health Organization declared the coronavirus
disease 2019 (COVID-19) a pandemic due to the rapid spread and severity of
the disease. The Centers for Disease Control and Prevention (CDC)
collaborated with other Federal agencies to develop and implement a national
vaccination program, with the interim version “playbook” issued on October 29,
2020.
1
This playbook established recommendations for determining population
groups for initial COVID-19 vaccination distribution. Recommendations
included placing health care personnel in vaccination priority group 1a, and
placing non-health care, frontline, essential workers, such as those in law
enforcement and national security roles, in priority group 1b. On December
11, 2020, the U.S. Food and Drug Administration (FDA) approved the use of
the first COVID-19 vaccine (the vaccine), manufactured by Pfizer BioNTech,
through its Emergency Use Authorization (EUA) authority,
2
with subsequent
EUA approvals issued on December 18, 2020, and February 27, 2021, for the
vaccine from two additional manufacturers.
Department of Homeland Security headquarters and some of its components
employ first responder health care personnel and frontline essential workers,
including those responsible for law enforcement and national security
missions. For example, United States Coast Guard Office of Health Services
and U.S. Immigration and Customs Enforcement (ICE) Health Service Corps
employ health care personnel such as nurses and doctors, and U.S. Customs
and Border Protection (CBP) and United States Secret Service employ frontline
essential employees in the law enforcement field such as Border Patrol agents
and special agents. Prior to the EUA, while the vaccine was still under
development, DHS anticipated the need to coordinate vaccinations for some
employees. To prepare for vaccinating these employees against COVID-19,
DHS asked its components to use the CDC recommendations to determine
which employees to place in priority groups 1a and 1b.
DHS did not directly receive an allocation of vaccine inventory for its
employees. DHS partnered with the Veterans Health Administration (VHA),
which has an established healthcare infrastructure, to make the vaccine
available to DHS personnel in priority groups 1a and 1b. On December 18,
2020, citing DHS’ mission of securing the Homeland, DHS and VHA entered a
memorandum of understanding (MOU) to offer the vaccine to eligible DHS
1
Centers for Disease Control and Prevention, COVID-19 Vaccination Program Interim
Operational Guidance Jurisdiction Operations, Version 2.0, Oct. 29, 2020.
2
During public health emergencies, the FDA can use its EUA authority to allow the use of
unapproved medical products, or unapproved uses of approved medical products, to diagnose,
treat, or prevent serious or life-threatening diseases when certain criteria are met, including
that there are no adequate, approved, and available alternatives.
www.oig.dhs.gov 3 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
employees on a voluntary basis. DHS Office of the Chief Human Capital Officer
(OCHCO) guidance noted the frontline mission critical employees would receive
the vaccine “as soon as possible after they are prioritized.”
3
Pursuant to the
MOU, VHA would vaccinate only eligible DHS employees in priority groups 1a
and 1b, as it was not an agreement for a total workforce vaccination program.
Also, the MOU was to remain in effect until the vaccine was widely available
from health care providers and the Nation’s supply was “robust and stable.”
4
On January 6, 2021, VHA began providing the vaccine to eligible DHS
employees.
5
DHS set goals to facilitate the first dose
6
of the vaccine for 80
percent of eligible, opted-in employees by May 1, 2021, and the full
vaccination
7
of 80 percent of all DHS employees, regardless of priority group
status, by August 31, 2021.
8
We evaluated how DHS determined employee status for placement into vaccine
distribution groups. Also, we examined how DHS planned to triage and
distribute available vaccine inventory and evaluated how DHS executed its
plan. The DHS-VHA MOU concluded on June 30, 2021, effectively ending the
vaccination phase of the DHS employee vaccination initiative.
9
The initiative
then transitioned from actively coordinating vaccines to only collecting data to
track employee vaccination status. This report presents lessons learned from
DHS’ employee vaccination initiative and areas of consideration for DHS to
better prepare for future pandemics. It also makes one recommendation to
improve DHS’ ability to identify essential employees, when necessary, in future
emergency situations.
Results of Inspection
In advance of the vaccine EUA, DHS prepared to coordinate employee
vaccinations by tasking its components with identifying eligible health care and
frontline, mission-essential personnel in accordance with CDC guidelines.
3
Email from OCHCO with subject line, “Update 17 (Limited COVID-19 Employee Vaccination
Program) from the Chief Human Capital Officer,” to all DHS employees, Dec. 17, 2020.
4
Memorandum of Understanding between the Veterans Health Administration, Department of
Veterans Affairs and The Undersecretary for Management, Department of Homeland Security
Regarding COVID-19 Priority Vaccination, Dec. 18, 2020.
5
See Appendix C for a timeline of associated events and significant dates, preceding and
during DHS employee vaccination efforts.
6
COVID-19 vaccines produced by Pfizer and Moderna require two doses, 21 and 28 days apart,
respectively. The Johnson & Johnson vaccine is a one-dose vaccine.
7
An individual is considered fully vaccinated 2 weeks after receiving the second dose of the
Pfizer or Moderna vaccine, or 2 weeks after receiving the Johnson & Johnson one-dose vaccine.
8
DHS Vaccination Task Force Weekly Meeting Notes, Mar. 2, 2021, and Mar. 16, 2021;
provided by DHS.
9
On Apr. 19, 2021, the White House announced anyone age 16 or older was eligible to receive
the COVID-19 vaccine. The easing of eligibility restrictions increased opportunities for all DHS
employees to receive the vaccine from public providers.
www.oig.dhs.gov 4 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
DHS acted swiftly to identify employees in vaccination priority groups, but did
not rely on its existing policies and provided minimal guidance to components,
resulting in inconsistent responses across the Department as to which types of
employees were deemed eligible. DHS only partially committed staff resources
and delayed establishing a comprehensive, full-time task force to manage the
effort. Also, at times, DHS’ communications to its employees were inconsistent
or unclear, causing confusion among some employees. DHS successfully
vaccinated some employees, but missing and erroneous personnel data in DHS
systems used to facilitate vaccinations contributed to DHS falling short of
reaching its goals.
This report highlights lessons learned from the DHS employee vaccination
initiative that may inform future DHS preparedness efforts. We make one
recommendation to improve DHS’ ability to identify essential employees, when
necessary, in future emergency situations. Also, DHS should consider
improving its preparedness by developing incident response protocols that
include a plan for establishing and staffing an incident response team. To
foster trust among its workforce, DHS should strive to communicate directly
and consistently with personnel during future initiatives. Finally, DHS should
consider devising and implementing a methodology for conducting oversight of
employee data.
DHS Acted Swiftly to Identify Eligible Employees, but Limited
Guidance for Components Resulted in Inconsistencies
Anticipated limited availability of vaccine doses required DHS to identify and
prioritize vaccination for mission critical employees DHS planned a phased
approach for vaccine distribution with the ability to adjust as vaccine doses
became available, moving from targeted to broader populations. On October 1,
2020, more than 2 months prior to the first COVID-19 vaccine EUA issuance,
DHS tasked components via email, informed by CDC recommendations, to
identify their mission critical employees
10
to plan for priority distribution of the
vaccine.
DHS policy defines mission-critical personnel as essential employees occupying
positions and performing functions maintained under all circumstances for the
safety and security of the Nation and its citizens.
11
Mission-critical
occupations (MCO) are those that most directly affect mission achievement,
and priority MCOs are those with the greatest impact to the Department’s goals
and objectives. The critical nature of these positions is included in official
position descriptions, and mission-critical employees report to duty regardless
10
The request for information excluded contractors.
11
DHS Directive 250-05, Revision 00, signed as of Jul. 30, 2012.
www.oig.dhs.gov 5 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
of emergency circumstances. DHS OCHCO maintains lists of series codes, by
component, deemed mission-critical by component leaders and reviewed and
approved by the OCHCO. Although DHS had existing definitions of mission-
critical personnel, it did not use the definitions or provide standard criteria to
help components determine which employees were eligible for the vaccine
distribution priority groups. Specifically, DHS did not direct components to
use the established and approved mission-critical series code list and did not
supply guidance to components on how to identify eligible employees as part of
the October 1 tasking. Instead, DHS asked components to provide information
about employees considered “operational highest risk mission-critical location
dependent,”
12
including:
x total number of “operational highest risk mission critical location
dependent employees;”
x numerical breakdown of these employees by duty location ZIP code; and
x list of all occupational series appearing in the total.
13 14
DHS expected components to use their discretion to determine employee
eligibility because they best understand their unique missions and needs.
Further, DHS provided no oversight to ensure the 1a and 1b priority group lists
were valid
15
and relied solely on the components to ensure the employees met
the priority list criteria.
As a result, the component responses varied as to which job series were
considered eligible for placement in priority groups. For example, three
components
16
and DHS Office of General Counsel included series code 0905 -
Attorney in their 1b eligibility list, even though the DHS-established MCO list
only specifies attorneys as mission-critical for ICE and CBP. In addition, the
Federal Emergency Management Agency (FEMA), citing differences in type of
12
In the Oct. 1, 2020 email tasking components to identify eligible employees, DHS defined
“mission critical location dependent” as employees in positions who are unable to telework and
are required to be physically present with greater exposure to those with possible COVID-19,
and who have a nexus to national security. DHS also specified employees required for
continuity of government should only be considered for priority groups if they were unable to
telework.
13
The Oct. 1, 2020 DHS email to components included an attached spreadsheet template with
instructions directing components to provide the information in this bulleted list.
14
On Nov. 24, 2020, DHS emailed components requesting additional information such as
names and email addresses for those employees included in the total number and included a
template for components to provide identifying information for DHS employees in health care
positions.
15
DHS OCHCO cross-referenced submitted data against National Finance Center personnel
records to ensure submissions were Federal employees and validated submitted email
addresses for accuracy, then requested that components correct any discrepancies.
16
Cybersecurity & Infrastructure Security Agency, ICE, and Federal Law Enforcement Training
Centers.
www.oig.dhs.gov 6 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
employee deployed per disaster, was unable to fully satisfy the request for
information because it could not submit series codes for more than 22,000
employees in priority groups 1a and 1b. After providing an initial list of eligible
employees, some components later submitted email justifications for adding
contractors, students, and other DHS employees. DHS and its components
identified more than 166,000 (or 69 percent, an approximate total of DHS
employees)
17
eligible employees in priority groups 1a and 1b.
18
One
vaccination initiative staff member stated that too many employees were in the
priority groups and noted it was because no one in DHS wanted to say no to
including employees. To avoid these inconsistencies, DHS could have relied on
the already established MCO and priority MCO lists for guidance when tasking
components to provide names of eligible employees.
DHS Was Slow to Establish a Comprehensive Task Force to
Manage Vaccinations for Eligible Employees
Although DHS understood it would be a large-scale effort to coordinate
vaccinations for the more than 166,000 eligible employees identified, DHS
initially dedicated limited staff to the initiative. Between October and
December 2020, DHS employee vaccination efforts relied primarily on DHS
headquarters and Countering Weapons of Mass Destruction Office (CWMD)
employees. Realizing the need to accelerate the vaccination program, DHS
engaged FEMA to recruit and activate a full-time team to ensure success of
ensuing vaccination efforts. On January 25, 2021, then-Acting DHS Secretary,
David Pekoske, introduced a new vaccination task force, Operation Vaccinate
Our Workforce (VOW), led by the DHS Chief Medical Officer (CMO).
19
DHS’
goals for the vaccine initiative included:
x 80 percent of eligible DHS employees opt-in or -out via ServiceNow
20
by
March 8, 2021;
x 80 percent of eligible, opted-in DHS employees receive their first vaccine
dose by May 1, 2021; and
17
DHS employs approximately 240,000 people.
18
During the DHS employee vaccine initiative, eligible employees could opt out of receiving the
vaccine from VHA. On September 9, 2021, after the DHS employee vaccination initiative
ended, Executive Order 14043 mandated all Federal employees be fully vaccinated by Nov. 22,
2021, unless they received an exemption for religious or medical reasons. However, on Jan.
21, 2022, a Texas Federal judge issued a nationwide injunction halting the requirement.
19
Email from Office of the Secretary with subject line, “Message from Acting Secretary David
Pekoske on DHS Workforce Vaccinations” to all DHS employees, Jan. 25, 2021.
20
DHS headquarters and components use ServiceNow, a software platform, for tasks such as
creating service requests, reporting technical issues, managing agency taskers, tracking and
automating business processes, and generating reports. Operation VOW used ServiceNow to
communicate with eligible employees, allowing them to opt in or out of receiving a vaccination
through VHA and to record vaccination status.
www.oig.dhs.gov 7 OIG-22-42
x
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
80 percent of approximately 240,000 DHS employees, regardless of
1a/1b status, be fully vaccinated by August 31, 2021.
Operation VOW consisted of four “lines of effort” (LOE),
21
each with a role
designed to advance DHS’ vaccination goals. Figure 1 lists the desired outcome
for each LOE.
Figure 1. Desired End States for Operation VOW LOEs
Engagement LOE
All employees who opted to receive a
vaccine are scheduled at a VA facility
or are vaccinated from an alternate
source.
Fixed Sites LOE
All employees who opted to receive a
vaccine and are in the 200 mile
radius from a VA facility are
vaccinated by existing VA facilities.
Vaccination Events LOE
All opportunities for employee
vaccination events have been
realized.
Vaccination Deserts LOE
All employees who opted to receive a
vaccine and are outside of the 200
mile radius from a VA facility have
received a vaccine.
Operation VOW LOE Desired End States
Source: DHS OIG analysis of DHS-provided information
Operation VOW staff we interviewed described the vaccine initiative as a
dynamic situation, with one noting “there appeared to be no plan” and stating
“DHS was flying the airplane and building it at the same time.” DHS provided
us with a draft of the Operation VOW Integrated Strategic Plan but did not
provide a finalized version.
Although the COVID-19 vaccine rollout was a dynamic situation, DHS knew in
October 2020 of its intent to vaccinate some employees, yet waited until
January 2021 to enlist FEMA, the DHS component best-equipped to respond to
the demand for a rapid response infrastructure. Operation VOW staff shared
the frustration that the vaccination efforts would have been more successful
had DHS established a comprehensive task force as soon as leaders knew the
Department would be coordinating vaccines for some employees. By
developing emergency response protocols, including guidelines for establishing
21
Operation VOW Incident Command Structure Form 207, Organizational Chart Command and
General Staff; current as of Mar. 3, 2021.
www.oig.dhs.gov 8 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
and staffing an incident response team, DHS may avoid delays in future
initiatives like Operation VOW.
Area of Consideration: DHS Should Strengthen Its Ability to Manage
Initiatives Related to Health and Safety of Employees
Multiple staff members described how DHS needed to develop a plan and be
prepared to enact it before the next emergency or pandemic occurs. DHS
should consider outlining policy and procedures for a public health and
medical working group poised to coordinate large-scale, multi-component
efforts like the employee vaccination initiative. As one staffer told us, DHS
should have a plan on the shelf, ready to dust off and implement at a moment’s
notice. DHS OIG issued a similar recommendation in a December 2020
report
22
that states DHS should assign responsibility and delegate authority to
an office or individual for oversight and management of DHS and component
pandemic plans, including review, approval, and updating of those plans.
Although that recommendation, when closed, will ensure continued oversight
of department-wide pandemic planning, DHS should further consider
advancing preparedness by establishing the staffing plan for an emergency
response force before it is needed. DHS appeared to recognize the need to
increase preparedness in its Operation VOW after-action report, by identifying
a centralized working group to provide coordination on cross-component
workforce efforts as a future consideration.
23
DHS Communications to the Workforce Were Misleading and
Unclear
At times, DHS communications, both to the entire workforce and to those in
the priority eligibility groups were misleading and unclear. As a result of
unclear guidance from DHS, components experienced communication
challenges when coordinating with VHA. Also, unclear directions to
components and incomplete communications to VA points of contact may have
caused some eligible employees to miss vaccination opportunities.
DHS Made Misleading Statements about Who Would Receive the Vaccine
The DHS-VHA MOU stated the agreement was not intended as a program to
vaccinate the entire DHS workforce. Moreover, multiple Operation VOW staff
members told us they clearly understood Operation VOW was only to facilitate
22
Ineffective Implementation of Corrective Actions Diminishes DHS’ Oversight of Its Pandemic
Planning, OIG 21-14, Dec. 21, 2020. DHS concurred with Recommendation 3 of the report
noted above, and the recommendation remains open and resolved.
23
See Appendix D for a comparison of DHS OIG areas of consideration and Operation VOW
executive summary areas for future consideration.
www.oig.dhs.gov 9 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
vaccines for employees in priority groups 1a and 1b. Regardless, throughout
the employee vaccination initiative, DHS emails and videos contained
misleading statements about which employees would receive vaccinations. On
numerous occasions, DHS leadership directly stated or suggested Operation
VOW would first facilitate vaccines for 1a and 1b priority group employees and
would later facilitate vaccines for other employees.
24
Messages to the DHS
workforce containing misleading statements included:
x A January 25, 2021 email to the DHS workforce from then-Acting DHS
Secretary announced the newly established Operation VOW and outlined
a plan to accelerate the administration of vaccines across the DHS
workforce. The communication conveyed Operation VOW would make
COVID-19 vaccines available to DHS employees more quickly and stated
“all DHS personnel who want a vaccine will be in the pipeline to receive
one” although the priority was the 1a and 1b employee populations.
x In a February 8, 2021 video message, the DHS CMO introduced
Operation VOW and stated, “For those that fall outside of the phase
1a/1b designation, know that as we continue to work our way through
these phases, we're not forgetting about you.” The CMO went on to
describe how vaccines may be accessible at a local pharmacy or
vaccination hub “by the time DHS gets to you.”
x During the March 25, 2021 virtual Town Hall meeting, the moderator
asked the DHS Secretary a question submitted by a DHS employee
regarding whether there were plans to offer the vaccine to the entire
workforce and not just frontline employees. The DHS Secretary replied,
“Yes. The goal is to vaccinate the entire workforce. We’ll focus on our
frontline personnel. A lot of frontline personnel interact with the
American public. They work in congress [sic] settings. The public health
imperative prioritizes them, and we will cascade from there.”
According to an Operation VOW staff member, the use of phrases such as “all
DHS personnel who want a vaccination” and “we're not forgetting about you”
were used in messages to the workforce to ensure ineligible employees would
not question, “What about me?” An Operation VOW official described how DHS
would eventually strategize about facilitating vaccines for the 1c DHS employee
population, but increased vaccine eligibility and availability supplanted the
24
Operation VOW officials noted that “facilitating vaccines” could also refer to other activities,
such as encouraging employees to get vaccinated on their own, assisting employees in
overcoming vaccine hesitancy, and educating employees on how to find vaccines through
VaccineFinder.org and the Federal Retail Pharmacy Program.
www.oig.dhs.gov 10 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
need to do so. Regardless, every staff member we asked told us Operation
VOW was never intended to facilitate vaccines for any DHS employees other
than those in the 1a and 1b.
Communication Issues Persisted throughout the DHS Employee
Vaccination Initiative
Operation VOW staff members discussed experiencing communication
challenges “from the top, down” and described how the communication issues
caused problems in various areas of the DHS employee vaccination initiative.
We identified examples of poor communication from the early stages of the
initiative, when components were identifying eligible employees, as well as later
in the process when the VA facility representatives attempted to schedule
appointments with eligible DHS employees.
On December 23, 2020, DHS began using ServiceNow to send DHS priority
group 1a employees email invitations to register for the DHS vaccination
program. By January 4, 2021, 20,000 employees from group 1a opted-in,
1,000 opted out, and the invitation was extended to 38,000 group 1b
employees. Although the VHA began vaccinations for DHS employees on
January 6, 2021, at that time components were still attempting to provide
details and account for approximately 140,000 employees to ensure only
national security, mission critical, and frontline personnel were included. One
staff member described these early communication efforts as “absolute chaos.”
Eligible employees had trouble registering through ServiceNow and scheduling
vaccine appointments with the VA. We reviewed multiple emails in which
users informed staff of problems such as no link or broken links to access the
site for opting in to receive a vaccination. We also reviewed instances in which
employees questioned why they were waiting long periods of time for VA to
schedule their vaccination. Conversely, VA facility representatives may have
had difficulty reaching DHS employees. Operation VOW meeting minutes from
January 2021 describe how components were to inform employees the VA
facility representatives would not leave a voicemail when attempting to
schedule vaccine appointments. Employees were required to answer the phone
and, if applicable, update settings to allow unknown callers.
25
This
information was shared with component representatives responsible for
communicating it to employees, but not directly with employees, which may
have caused some employees to miss the opportunity to schedule a vaccination
appointment with their nearest VA facility. Operation VOW stood up a
helpdesk as part of the vaccination initiative and, as of March 7, 2021, had
answered 2,071 calls and responded to 3,755 emails from employees
25
Some phones have settings allowing the user to automatically ignore calls from unknown
numbers or send those calls directly to voicemail.
www.oig.dhs.gov 11 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
requesting assistance.
Another example highlighting confusing communication was a February 2021
email thread between a Transportation Security Administration (TSA)
representative and a VA point of contact describing TSA’s uncertainty about an
upcoming vaccination event. DHS provided the date, times, and instructions
for an upcoming vaccination event at a local VA facility, but only to a subset of
eligible TSA employees in that area. A TSA representative discovered the
mistake, realizing some eligible employees had not received the notification.
The TSA representative inquired with the VA point of contact who noted she
had previously received and answered multiple inquiries regarding this same
issue. The TSA representative confirmed the VA location representative had,
indeed, contacted every name on the list provided to the VA by DHS but did not
determine why some eligible employees were not notified of the event by DHS.
The correspondence exemplified what Operation VOW staff described as issues
with DHS communications to employees about eligibility for vaccination events.
By not clearly communicating with both employees and VA location points of
contact, DHS may have caused some employees to miss vaccination
opportunities.
Finally, DHS did not clearly explain that eligible employees who opted in were
expected to update their vaccination status in ServiceNow after becoming fully
vaccinated. None of the policy documents associated with the vaccination
initiative specified it was the follow-on responsibility of eligible employees, after
receiving their second dose, to update their vaccination status in ServiceNow.
It was not until the Addendum to Policy Directive 066-14, Expansion of the
COVID-19 Emergency Use Authorization Vaccine Plan, was issued on February
16, 2021, that the additional information requirement was implied in the
sentence, “Operation VOW will also develop an electronic means to collect
vaccination status for all DHS employees.” At that time, Operation VOW
relaunched ServiceNow to enable a streamlined interface to better capture and
use data provided by priority group employees. After the March 26, 2021
deadline for DHS eligible employee registration in ServiceNow, messaging
shifted from an operational focus of getting “shots in arms” to an engagement
focus of getting employees to update their vaccination status.
26
26
Two examples of the messaging shift include a March 26 announcement from the CMO on
DHS Connect informing employees that, beginning on March 27, they would only be able to
access ServiceNow to update vaccination status and a March 31 message from DHS leadership
on DHS Connect asking 1a and 1b employees to please continue to update vaccination status
in ServiceNow.
www.oig.dhs.gov 12 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Area of Consideration: DHS Should Ensure Its Communications to the
Workforce during Emergency Situations Are Clear and Consistent
When managing an emergency response effort like the employee vaccination
initiative, DHS should ensure it has a robust communication strategy. One
staff member suggested DHS should have stated clear expectations early to
help mitigate communication issues and prevent the loss of trust and
apprehension to tell the truth among components. Although some
communication hiccups could be expected in a dynamic situation such as this,
communication missteps like those described risk harming relationships with
partners and losing employee trust and buy-in. In the future, DHS should
consider dedicating the resources necessary to ensure consistent, accurate
communications with employees and partners. DHS may have recognized this
area as needing improvement, as it included “build a structured
communication strategy for DHS-wide health and safety” in its after-action
report as a future consideration.
Missing and Erroneous Personnel Data in DHS Systems
Hampered DHS’ Ability to Meet Its Employee Vaccination Goal
Operation VOW set a goal to facilitate the first dose of the vaccine for 80
percent of opted-in, eligible employees by May 1, 2021, but only about 29
percent reported receiving the first dose at a VA medical center by that date.
27
Challenges in gathering employee data and achieving data accuracy once they
obtained the information complicated DHS’ vaccination efforts. After tasking
components to gather data to inform the total number of vaccines needed for
VHA to administer to DHS eligible employees, it was determined in several
instances that components sent data with missing or erroneous information,
resulting in scheduling delays in ServiceNow.
Within DHS, components use different systems to manage personnel data,
such as names, email addresses, and home addresses. As described in a 2016
Government Accountability Office (GAO) report, oversight and governance of
this employee data has been a longstanding challenge for DHS.
28
Specifically,
GAO found that DHS made little progress implementing Human Resources
Investment Technology, a multi-year effort intended to consolidate and
modernize more than 200 payroll and personnel systems used across the
Department.
27
As of May 1, 73,239 employees had opted in through ServiceNow and 28,140 (29% of DHS’
80% target goal) reported having received the first dose through VOW.
28
Oversight of Neglected Human Resources Information Technology Investment Is Needed, GAO-
16-253, Feb. 2016.
www.oig.dhs.gov 13 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
One TSA employee described manually researching more than 600 missing
email addresses to ensure TSA was submitting data that was as complete and
accurate as possible. Based on our discussions with Operation VOW staff, it is
unlikely that other components took the same steps as TSA to ensure the 1a
and 1b personnel data was complete and accurate. Operation VOW staff
described the data provided by the components as fraught with errors such as
missing information and incorrect email addresses. Initially, DHS staff worked
with components to obtain accurate data, but eventually Operation VOW
established a team solely dedicated to manually fixing data errors, a process
one staff member described as time consuming and cumbersome.
Staff we interviewed also described how erroneous data caused the VHA to
open vaccination sites slowly. One staff member told us that VHA had
complete authority on which sites to open and when, and DHS could only
request that a site be made available to DHS employees. Data errors delayed
these openings in some instances as VHA relied on the Department’s ability to
provide accurate employee data and was hesitant to open sites to vaccinate
DHS employees. An Operation VOW staff member stated, “if OVOW had NOT
experienced these communication issues, they would have been able to achieve
goals and executed programs sooner, more timely and efficiently.”
Of the 166,145 employees in priority groups 1a and 1b, 96,367 (58 percent)
opted in through ServiceNow to receive the vaccine. DHS set a goal to facilitate
administration of the first dose of the vaccine to 80 percent (77,094) of 1a and
1b, opted-in employees by May 1, 2021. DHS fell short of its goal when only 37
percent (28,140) of the priority group 1a and 1b, opted-in employees had
received their first dose by May 1. DHS had also set a goal to fully vaccinate 80
percent of all DHS employees by August 31, 2021, but the DHS-VHA MOU
concluded on June 30, 2021. By this point, anyone age 16 or older was eligible
to receive the vaccine and could do so through public providers. The initiative
then transitioned from facilitating vaccine administration to tracking employee
vaccination status.
Area of Consideration: DHS Should Exercise Oversight of Employee Data
and Provide Components with Guidelines for Establishing Consistent Data
DHS should consider, devise, and implement a methodology for conducting
oversight of employee data. At a minimum, DHS should provide components
with guidance on formatting certain fields, such as email address, to maintain
consistency across the Department. DHS recognized the need to mature the
www.oig.dhs.gov 14 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
DHS workforce data in the after-action report. It is critical to capitalize on this
lesson learned from Operation VOW to succeed in future, similar operations.
Conclusion
OIG recognizes DHS efforts to vaccinate its priority group 1a and 1b employee
populations. Officials described how Operation VOW staff overcame challenges
such as managing data from multiple systems and varying levels of
commitment from detailed staff. Although Operation VOW has ended, there
are lessons to be learned from this effort as DHS will undoubtedly face
situations again in which it needs to act quickly and decisively to identify and
interact with certain groups of employees across its components. DHS should
establish reliable emergency protocols and should strive to communicate
directly and consistently with all members of the workforce during emergency
response. The Department must also be able to rely on its components to
provide accurate and consistent employee data, but to do so, DHS should
develop criteria for that data.
Recommendation
We recommend the DHS OCHCO designate, direct, and oversee component
representatives to maintain rosters of essential employees in each category
defined by existing DHS policy.
Management Comments and OIG Analysis
DHS concurred with the recommendation and described corrective actions.
Appendix B contains DHS’ management comments in their entirety. We also
received technical comments on the draft report and revised the report as
appropriate. We consider the recommendation resolved and open.
A summary of DHS’ response and our analysis follows.
Recommendation: We recommend the DHS OCHCO designate, direct, and
oversee component representatives to maintain rosters of essential employees
in each category defined by existing DHS policy.
DHS Response to Recommendation: Concur. The Department currently has
a policy in place that addresses the intent of the recommendation. Specifically,
DHS Directive 250-05, “Designation of Essential and Exempt Personnel,” dated
July 11, 2012, establishes the policy for (1) designating essential personnel to
ensure continuity of DHS operations and services and (2) component
identification of essential personnel and notification of said designation and its
www.oig.dhs.gov 15 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
requirements. Accordingly, components can generate rosters of employees in
these categories depending on the nature of the incident and resulting
operational priority.
The COVID-19 emergency use authorization vaccination initiative was unique.
DHS was not seeking to vaccinate all mission critical or essential personnel, or
personnel in any of the listed, defined categories. Instead, DHS sought to
vaccinate essential personnel who, because of their duties, would interact with
the public and thus require protection. The DHS Chief Human Capital Officer
will consider whether additional guidance is necessary based on the further
review of findings in this report. Estimated Completion Date: September 30,
2022.
OIG Analysis of DHS Comments
We consider these actions responsive to the recommendation, which is resolved
and open. We will close it when we receive documentation showing DHS has
designated, directed, and is conducting oversight of component representatives
to maintain rosters of essential employees in each category defined by existing
DHS policy.
www.oig.dhs.gov 16 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Appendix A
Objective, Scope, and Methodology
The DHS Office of Inspector General was established by the Homeland Security
Act of 2002 (Public Law 107ï296) by amendment to the Inspector General Act of
1978.
We conducted this review to:
x evaluate how DHS determined employee status for placement into
vaccine distribution priority groups;
x determine how DHS, in conjunction with VHA, planned to triage and
distribute available vaccine inventory and vaccinate frontline,
mission-critical DHS staff; and
x evaluate how DHS executed its plan.
To achieve our objectives, we conducted interviews with Operation VOW staff
members from various components, and we reviewed and analyzed meeting
minutes, relevant emails, employee vaccination statistics, and multimedia
messaging directed to the DHS workforce via the intranet, DHS Connect.
We also reviewed relevant background information, including directives,
guidance, policies, and written communications related the COVID-19 vaccine,
vaccination plan, determination of prioritized employees, and vaccine
administration by the VHA. Given the inherent risks associated with on-site
inspection during the COVID-19 pandemic, we performed our work remotely.
We conducted this review between February and July 2021 under the authority
of the Inspector General Act of 1978, as amended, and according to the Quality
Standards for Inspection and Evaluation issued by the Council of the Inspectors
General on Integrity and Efficiency.
www.oig.dhs.gov 17 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Appendix D
Comparison of DHS OIG Areas of Consideration and Operation
VOW After-Action Report Key Findings
Comparison Table
Areas of Consideration for DHS to
Address the Findings in this Report
Key Findings for Future Considerations
from the DHS OVOW Executive Summary
1 Develop incident response
protocols that include a plan for
establishing and staffing an
incident response team.
Build a centralized working group to
provide coordination on cross-component
workforce efforts.
2 Strive to communicate directly and
consistently with personnel during
future initiatives.
Build a structured communication
strategy for DHS-wide health and safety.
3 Consider, devise, and implement a
methodology for conducting
oversight of employee data.
Developing a strategy for maturing the
DHS workforce data infrastructure.
www.oig.dhs.gov 23 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Appendix E
Inspections and Evaluations Major Contributors to This Report
John Shiffer, Chief Inspector
Jennifer Berry, Lead Inspector
Jasmin Hammad, Senior Inspector
Ronald Hunter, Senior Inspector
Brittany Scott, Independent Referencer
www.oig.dhs.gov 24 OIG-22-42
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Appendix F
Report Distribution
Department of Homeland Security
Secretary
Deputy Secretary
Chief of Staff
Deputy Chiefs of Staff
General Counsel
Executive Secretary
Director, GAO/OIG Liaison Office
Under Secretary, Office of Strategy, Policy, and Plans
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
Office of Management and Budget
Chief, Homeland Security Branch
DHS OIG Budget Examiner
Congress
Congressional Oversight and Appropriations Committees
www.oig.dhs.gov 25 OIG-22-42
Additional Information and Copies
To view this and any of our other reports, please visit our website at:
www.oig.dhs.gov.
For further information or questions, please contact Office of Inspector General
Public Affairs at: [email protected].
Follow us on Twitter at: @dhsoig.
OIG Hotline
To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click
on the red "Hotline" tab. If you cannot access our website, call our hotline at
(800) 323-8603, fax our hotline at (202) 254-4297, or write to us at:
Department of Homeland Security
Office of Inspector General, Mail Stop 0305
Attention: Hotline
245 Murray Drive, SW
Washington, DC 20528-0305
