Audit Services Update: Emergency Management has made some progress toward improving emergency planning and response for people with disabilities

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This is a one-year follow-up to our 2021 audit of Portland Bureau of Emergency Management, in which we made seven recommendations to improve the City’s emergency planning and response for people with disabilities.
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In our 2021 report, Emergency Management: Pandemic highlights City’s long-standing neglect of people with disabilities, we made seven recommendations to Portland Bureau of Emergency Management to improve the City’s emergency planning and response for people with disabilities. One year later, the Bureau had not implemented two recommendations, was working to implement four recommendations, and fully implemented one recommendation.

Two recommendations not implemented

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We recommended that Emergency Management:

Hire or designate staff to cultivate Americans with Disabilities Act expertise and compliance and ensure they have the authority and resources needed to carry out their duties.

As of February 2023, Emergency Management did not have an employee with capacity to serve as an expert on the Act. The Bureau requested funding to hire a new staff member to focus on compliance and disability inclusion, but City Council did not fund the request. Emergency Management said it intends to continue seeking resources for this role. 

Use the authority of the Disaster Policy Council and Emergency Management Steering Committee to ensure that citywide emergency management planning and response complies with the Americans with Disabilities Act; and in coordination with City Council, formalize a disability advisor role for both oversight bodies.

Emergency Management has not implemented this recommendation. Staff noted that the Disaster Policy Council has not met since the audit was published. The Bureau is leading efforts to reform the group and reported that disability equity will be a consideration in the new structure. The Emergency Management Steering Committee has discussed some issues related to the Americans with Disabilities Act, but has primarily focused on other topics.

Staff also noted that Emergency Management’s new Director and citywide Charter reform may impact how emergency bureaus work together and are held accountable for complying with the Act.

Four recommendations in process

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We recommended that Emergency Management:

Lead work with other bureaus and partner agencies to reevaluate the Additional Needs Registry and determine whether the registry should be discontinued.

Emergency Management convened a meeting with City and County representatives in May 2022 to assess the Additional Needs Registry. The group decided to stop updating the registry pending further evaluation. Since then, progress has stalled due to staff turnover. The Bureau said it is re-hiring a lead for the project and remains committed to working on the registry when they regain capacity.

Develop a plan with performance measures and milestones for achieving compliance with the Americans with Disabilities Act in emergency management.

Emergency Management hired a consultant to conduct a Bureau-wide assessment. Emergency Management said the Americans with Disabilities Act will be a component of the assessment, and that it plans to use the assessment to inform future strategic planning and budgeting.

Emergency Management also received one-time funding for additional consulting services to support disability equity planning for emergency response. The Bureau intends to use these funds to train staff on the Act, create outreach materials, and update one of the five emergency plans we identified as outdated. The Bureau is developing a scope of work for these services and expects to issue the contract in 2023. Staff said they hope to partner with a disability rights organization on this effort.  

Ensure that its staff understand how to meet guidelines listed in ADA Best Practices Tool Kit for State and Local Government.

Emergency Management expects to contract with a consultant in 2023 to deliver Americans with Disabilities Act training to staff.

Take responsibility for coordinating emergency preparedness outreach to people with disabilities on behalf of the City and develop a strategy that includes long-term and short-term goals for emergency preparedness education and outreach to people with disabilities.

Emergency Management said it is committed to ensuring that its emergency preparedness outreach is inclusive of people with disabilities. The Bureau is re-developing its outreach strategy and plans to work with a consultant to produce updated community outreach materials that center people with disabilities. Emergency Management also received funding to award grants to community-based organizations that build disaster resilience, including groups serving people with disabilities. 

One recommendation implemented

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We recommended that Emergency Management:

Formalize the inclusion of a disability advisor in the Emergency Coordination Center command structure and operating procedures. The disability advisor should have Americans with Disabilities Act and emergency management expertise and the authority needed to address disability concerns.

When we issued our 2021 audit,Emergency Management had established an Equity Officer position in the Emergency Coordination Center for the COVID-19 pandemic and included an Equity Officer as part of the command structure on the Center’s organization chart. Positioning the Equity Officer in the command structure gives them an opportunity to participate in incident planning and decision-making.

Since the audit, the Bureau has taken additional steps to formalize the inclusion of Equity Officers in Center operations and ensure that they have appropriate expertise. For example, an updated emergency operations plan includes Equity Officers as members of the Center’s command staff and requires the Office of Equity and Human Rights to designate employees to serve as Equity Officers when the Center is activated. Emergency Management also developed position descriptions for Equity Officers that require the positions to be filled by equity professionals that have expertise in mobility or language access needs and emergency management training. In summer 2022, Equity Officers were invited to join a planning team to assess medical equipment needs at shelters and inform future Center activations.

Continued attention in this area is important to ensure that the City is prepared to meet the needs of people with disabilities in the event of an emergency.

Visit our original 2021 audit report and recommendations

Visit our online dashboard to track the status of recommendations from other reports