Quarter 4 2020, Volume 8 Issue 4

Creating and Implementing a Continuity of Operations Plan (COOP)

Continuity of Operations Plans (COOPs) are designed to assist Housing Counseling Agencies (HCAs) in safely navigating and maintaining functionality during an emergency. An agency may encounter a variety of emergency situations that cause disruption to their operations, including pandemics, natural disasters, power outages, terrorist attacks, and many others.

To best prepare for these situations, HUD encourages HCAs to develop both an Emergency Response Plan and a COOP. These plans should be updated regularly.

The Emergency Response Plan is the initial action plan which enables agencies to:

  • Evaluate the safety of staff and clients
  • Consider the possible effects that disaster situations may have on their agency’s business practices
  • Coordinate with federal, state, and local emergency response systems

Once an agency stabilizes immediately following an emergency, the COOP is implemented. It is important for HCAs to regularly train their staff on the COOP to establish a seamless transition if unforeseen circumstances arise.

There are two types of COOPs – a Full-Length COOP and an Abridged COOP. A Full-Length COOP is recommended for HCAs with more than 15 staff members, whereas an Abridged COOP is recommended for smaller agencies. Each version of the COOP has four phases:

  • The COOP Introduction covers the continuity objectives of the HCA. Each HCA’s objectives may vary. The overarching goal is to maintain as much functionality as possible, while minimizing risks to staff and clients and protecting personal information, records, and documentation. The introduction also outlines the scope of the plan: the essential functions of the HCA, resources for individuals who are responsible for maintaining agency functions, and the preparation steps necessary to carry out these functions.
  • The COOP Preparation section outlines designated roles and responsibilities for staff members, the potential for alternate temporary facility locations, an emergency staffing plan, and a teleworking policy if the emergency requires extended remote work.
  • When an emergency occurs, the designated leader of the COOP will begin the COOP Activation process. This involves establishing clear lines of communication, which will vary among staff members. This section also outlines procedures for HCAs to acquire necessary personnel, equipment, and supplies to maintain functionality throughout the emergency period.
  • The final phase of the COOP is to Resume Regular Operations once the emergency has passed, and staff can return to a workspace with safe conditions. This phase consists of documenting any physical damages to the agency and preparing insurance claims to cover those damages. This phase also includes accounting for any staffing gaps and evaluating the agency’s ability to implement its housing counseling work plan. HCAs incapable of carrying out their housing counseling work plan must submit a temporary inactive request to HUD or their HUD Intermediary in writing.

OHC Disaster Recovery Toolkit screenshot

To read more about how housing counseling agencies can prepare for and recover from disasters, visit the Housing Counseling Disaster Recovery Toolkit.

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