Written by: Jesse Sears

The National Incident Management System (NIMS) established by FEMA in 2004 includes the utilization of a standardized approach to managing critical incidents through the use of the Incident Command System (ICS). Essentially NIMS and the associated ICS were developed to assist agencies in managing resources, command and coordination functions, and improve communication and information sharing. Fast forward several years and many funding opportunities are tied to the incorporation of NIMS and ICS thanks to federal agencies including the Department of Homeland Security, the Department of Health and Human Services, and the Department of Education. Understandably so, considering the principles contained within were developed utilizing proven methods and lessons learned from disaster failures.

The guiding principles within NIMS are founded on flexibility, standardization, and unity of effort. All great things. When it comes to emergency operations ICS, with its military-like structure and top-down approach to incident management, has become the gold-standard. This is the precedent even though most agencies lack the girth to ever fully activate and fill all of the roles and responsibilities. There is no question these guiding principles allow emergencies to be managed in a more effective manner, specifically when multiple agencies need to come together. ICS, remember, was developed so that when different agencies come together, they can do so under a standardized language and structure aimed at reducing insufficient management.

Unfortunately, this structure and language is anything but common knowledge. Conforming to this standard is the only way the principles actually become standardized.

An attempt to conform to the standard has resulted in individual agencies having emergency operational processes, plans, and organizational structures that are copied from federal templates rather than developed with the critical thinking mindset it takes to operationalize them. When a plan is developed without the operational capacity to carry it out, it becomes nothing more than a paperweight of what we said we were going to do, but not what we actually did.

This results in the infamous “just check the box” that frequently is associated with large government initiatives. This compliance on paper with its lack of cultural incorporation becomes an ineffective coping mechanism for emergency management theory. Sadly, universities are no exception.

Help forums recently have shown that many universities are seeking solutions for how to revamp their emergency operations structures after identifying a significant gap between what the plans dictated the operational structure would look like and what it actually did look like during the COVID response.

To be clear, this was not a COVID-specific problem. COVID just amplified the existing issues, thanks to its significant institutional impact involving all aspects of university operations.

Instead of relying on the formalities of plans and the standardized approach to incident management as so heavily emphasized by federal partners, one-by-one universities structured emergency operation teams in an ICS-like way thus guiding decision-making, developing situational assessments, and dividing up actionable tasks aimed at protecting the campus communities. It was absolutely incredible and a huge lift for schools all around the country to completely flip their day-to-day operations while still preserving learning.

Successful universities find ways to set themselves apart from competitors rather than conforming to industry standards, but this isn’t the main reason why higher education institutions are not easily conforming to NIMS and ICS. Universities instead have a unique set of challenges that prevent it from being an easy task.

ICS Challenge 1: Institutional impact

• The challenges for incorporating ICS are entwined with something that most government entities do not have to worry about: institutional impact. Decision-making is much easier for those agencies that will continue to operate even if they have glaring failures.
• Protecting the brand: the ability for an institution to set itself apart from competitors while driving student enrollment, research capacity, and future donors is vital to mission protection. Image and reputation are consistently at the forefront, even when responding to emergencies.
• Potentially conflicting operational objectives: institutions, even state institutions, receive a significant amount of their funding through athletics, donors, and paying students, creating a significant balancing act for operational objectives due to competing priorities.

ICS Challenge 2: Turnover and staffing

• According to new research from Higher Education Publications, Inc., between 2018 and 2021, turnover rates for administrator level positions averaged 34%.

• During the pandemic, approximately 570,000 higher education jobs were lost and the likelihood that colleges and universities are going to avoid what has been coined the Post-pandemic Turnover Tsunami is slim.
• Turnover is one of the biggest challenges for those overseeing emergency operation teams. If you are constantly in the mode of training new team members, it is impossible to focus on those things effective incident management teams need: advanced application through training and exercises.
• Another major challenge in school settings is the constant of being understaffed and underfunded. Individuals tasked with safety or compliance issues often get tasked with a large umbrella of responsibilities without the manpower or funding to carry them out.

ICS Challenge 3:  Critical incident planning is tricky

• Normal operations in higher education are highly collaborative, making conforming to a top-down decision-making approach extremely uncomfortable and too brash for the existing culture. The desire to be inclusive consistently trumps fast decision-making.
• Disasters are filled with management problems, and you know what universities and colleges have an abundance of? Managers. Universities are divided into divisions, departments, and units… all with their own set of leadership who conduct and plan for their unique operations. This often results in a setting where operationally speaking areas are siloed. Essentially, university personnel are already divided into lanes, making it extremely difficult to conform to the lanes of ICS.
• The types of emergencies and critical incidents that face a university are broad in scope resulting in the need for different leaders within the organization to be involved in the response. It is easy to be in charge when, for example, law enforcement responds to a law enforcement incident, but how effective is that same law enforcement official when responding to a water main break inside a building? Essentially, only having a few individuals trained as incident commanders could lead to catastrophic breakdowns in the knowledge necessary to effectively respond to the situation.
• Areas of focus for critical incident planning are vastly different, require different players, and create competing priorities. These areas are often highly specialized with a varying degree of needs. One cannot do the planning for the other thanks to complexity and, let’s face it, ownership rights.

ICS Challenge 4: ‘Common’ terminology and complexity

• NIMS and the ICS are not filled with common terminology. In fact, there are classes upon classes that individuals take to be able to “speak the language.” This is the opposite of common terminology.
• Applying NIMS and ICS is actually very complicated, it is especially difficult to try to teach individuals these concepts who do not care. Emergency managers are forced to rely on tools like Just In Time Training and finally open up plans that have been sitting on the shelves collecting dust.
• Two words – acronyms and forms. Oh the irony to develop training centered around interoperability and unity of effort only to devote a great portion to understanding the acronyms. Equally as frustrating is the awkward and unworkable ICS forms. Most of the boxes never actually get filled out, making a fully printed incident action plan lengthy and daunting.

Despite ongoing challenges to Institutions of higher education, it is important for compliance and unity in response to figure out how to make ICS work for them rather than asking the university to work for ICS. There are several opportunities to accomplish this.

Opportunity 1: Ensure decision makers are part of operational capacity

• Nothing stalls effective emergency response more than the inability to make a timely decision. Operationally speaking, someone with the right amount of training, experience, and gut instinct can make a decision that ultimately improves incident response. Unfortunately, having the right skill set doesn’t make a difference if the individual in the incident commander position does not have the operational authority to do so. To overcome this, ensuring an organization has multiple people trained to be incident commanders is essential to the process. The incident commander position should flex, depending on what level of decision-making is necessary. Remember: “incident commander” is more than a title. It must have authority.

• Under many incident management team structures, the policy group is not part of the emergency operations center. However, for large-scale emergencies, members of the policy group, or as we call it, administrative council, should be included. Again, this allows for fast decision making when one decision has an impact on more than one university pillar and ensures that those at the highest level of the university are part of the solution. It also allows for collaboration without slowing down the process by needing to set up separate meetings. When administrative level positions are included in the emergency operations response, this tends to lead to stronger support during blue sky operations by building unity and trust.
• Try utilizing a command text to share information during all emergencies with the administrative team. Even if your response isn’t large enough to need an advisory board, senior leadership will appreciate knowing what is going on as soon as possible. This does take some planning by setting up a special group within whatever emergency notification system you use. By doing so when an incident occurs, a specialized message can be developed that is geared toward these individuals specifically. Command texts should be used to share critical information, provide status updates, and call the group to assemble as needed. More than anything, it saves precious time while keeping the leadership team informed.
• Include the chief compliance officer as a member of the command staff. More frequently than not, university leadership are going to want to know what legal has to say, so include them often and quickly to speed up the decision-making process.

Opportunity 2: Consider setting response teams utilizing a department-like structure

• Turnover is something we are never going to get around. However, the more your emergency response structures and associated positions look like your day-to-day operations, the less training will need to be provided. This leads to less stress and a diminished need to rely on Just-In-Time Training during activation.
• Overlay your university’s structure with that of your ICS or emergency operations center (EOC) structure. This will help to visualize which critical areas of your university are currently not represented. For example, failing to incorporate key components of your operation like university advancement or athletics could lead to trouble down the road as these are both critical areas for ensuring a university has the funding and support to carry out its mission.
• A major advantage to working for a university during a large-scale emergency is that we are a large enough organization that we rarely need to ask for much help. Universities have an abundance of resources, subject matter experts, their own legal council, public information personnel, and the logistical and financial capabilities to carry out some major undertakings. Use this to your advantage.

Opportunity 3: Consider rethinking the operations and planning sections

• Before someone calls the ICS police, consider that in a university setting, most areas do their own planning and their own operations on a day-to-day basis. Different areas may use different systems and mechanisms, depending on the nature of their responsibilities and what they need to accomplish. As mentioned earlier, areas are often siloed, already in predetermined lanes, and have a dedicated manager. Think operational planning section.
• Divide the operational planning section into pillars of focus including campus safety, infrastructure, and human services. This will allow smaller teams to naturally form based on their scope of responsibility and priority of response.
• Considering putting key planning responsibilities under the role of the EOC manager. This individual likely has the knowledge and abilities to oversee situational reports, documentation, maps, and obtain subject matter expertise when needed.

Opportunity 4: Develop a robust emergency management program

• Quality plans and processes for emergency preparedness and response activities require an investment in a program dedicated to emergency management. A robust emergency management team helps better prepare the university for disasters while providing for leadership during and after the emergency has occurred.
• Emergency management provides for the much-needed coordination activities with outside agencies prior to a disaster. This allows for critical relationships to be developed, deficiencies in capabilities to be lessened through partnerships, and emergencies to be approached proactively.
• Emergency management is frequently able to help the university identify funding opportunities to lessen the impact of the disaster and get extra funding from state and federal partners after the disaster has occurred.
• Bottom line, hire a talented emergency manager. Allow them to evaluate how to best incorporate principles of NIMS and ICS so it becomes part of the university’s culture. Give them the tools to provide training and exercises aimed at identifying vulnerabilities and enhancing response capabilities.

At the end of the day, institutions of higher education have an abundance of resources providing for the ability to respond to most emergencies without the need for outside agency assistance, which makes the need to apply command and coordination functions according to strict NIMS and ICS standards less significant. This does not negate the need for a vetted system that can systematically approach emergencies.

Due to the large scope of response capabilities and the number of events that occur on campus, universities need to have excellent intra-agency coordination. This requires the use of a standardized approach, even if it is ICS-like rather than ICS exact. It needs to also just not be on paper.

Individuals must be given opportunities to practice through training and exercise opportunities. Try incorporating the process into campus events as well. This is a great opportunity that many universities already have outside of exercises to refine the process through lessons learned. It’s these actions that can help build a culture around systematically approaching disasters.

Jessy Sears is director of emergency management and public safety at Idaho State University. 

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