However, FEMA officials have not maintained a record of changes to systems 
requirements nor have they developed an up to date NEMIS requirements 
document.  One EP&R CIO staffer said that they have limited funding; when 
the budget gets pressed, it is always the  overhead  or administrative 
activities, such as updating requirements documentation, which are bypassed.   
Alternatives Analysis Needed  
Office of Management and Budget Circular A 130 encourages agencies to 
consider various options for providing automated systems to meet their 
mission needs.  However, by not taking the time to fully define and document 
systems requirements, it has been difficult for FEMA to evaluate viable 
alternatives to the highly complex, custom designed systems that it relies upon 
to support disaster response and recovery operations.  Because these systems 
have carried FEMA through its responsibilities over the years, senior IT 
officials said that they have made little effort to evaluate off the shelf 
products to determine if there is a simpler, commercially available, and 
possibly more effective IT alternative.  FEMA's Business Year 2006 business 
case submission to the Office of Management and Budget for NEMIS 
improvements also indicates a lack of alternatives analysis. 
Members of the EP&R CIO office speculated that off the shelf products 
would likely not meet their needs during peak emergency operations.  For 
example, according to a recent business case for the next generation of 
NEMIS, there is no plan to perform an analysis of alternative off the shelf 
products or other department systems.  The NEMIS requirements document is 
not up to date, and user input to those requirements has been limited.  NEMIS 
is a tool that stretches across multiple business functions; only by having a 
complete set of documented system requirements for each of these functions 
will the EP&R CIO be able to determine if alternative products can or cannot 
fulfill requirements. 
In addition, officials in one state agency increasingly have become aware that 
the federal government cannot compete with the private industry on 
developing systems.  According to this state agency, private industry is 
developing multiple systems to support emergency management operations.  
However, because federal systems do not always use the most up to date 
technology, it is becoming more difficult for state agencies to share 
information with the custom designed federal systems as states upgrade their 
own off the shelf systems. 
Emergency Preparedness and Response Could Better Integrate Information Technology  
with Incident Response and Recovery 
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