A New NIMS Challenge: Train to Compliance, or Train for Competence?

There is a new challenge facing local, tribal, and state governments as they continue their efforts to achieve compliance with the federal government’s NIMS (National Incident Management System) guidelines.  Actually, the problem is not really a “new” one, but one that has dogged the nation’s first-responder community for many years.  More recently the challenge has been felt by a broader level of professionals – including the “emergency response provider” segment of the NIMS-affected community. This is not surprising, because, as the definition of emergency response provider has greatly expanded the target audience, the problem has been amplified.  Nonetheless, the basic NIMS doctrine has provided a viable framework, particularly in the context of its Command and Management component, for training personnel to appropriate levels on knowledge, skills, and abilities (KSAs), especially as related to job performance in an organized IMS (incident (or event) management system). The problem, therefore, from the manager’s viewpoint, is simply this: “Do we train to compliance, or do we train for competence?”

In that context, the NIMS challenge that has grown so rapidly in recent years is yet another manifestation of the age-old problem of “So much to do, so little time [in which] to do it.” The problem is enlarged significantly in the homeland-security field, of course, by the closely related problem of obtaining the funds needed to pay for all of the training required.

In addition, there is a parallel challenge facing today’s decision makers – namely, finding the time and the means (i.e., money) to train all of the personnel who should receive the training while simultaneously maintaining the expected service levels those personnel were hired or recruited to provide.  All of these complicating factors are compounded, of course, by the threat of having current preparedness funds withheld or denied for failure to adequately meet the NIMS compliance criteria.

Ill-Advised Short Cuts and Evasive Maneuvers

Unfortunately, because of these and other factors, there are several indications that a substantial number of emergency response providers are now looking for and taking short-cuts to meet the federal NIMS compliance and funding eligibility criteria.  More specifically, several (maybe more than several) organizations and individuals have been finding new (and some not-so-new) ways to circumvent the intent of the NIMS policy statement as well as the NIMS compliance guidelines.  Sadly, some jurisdictions and organizations have been allowing staff to take on-line tests without having completed the training associated with and/or required for those tests.  In various cases, a wide range of “creative solutions” have been employed. A few examples:  (a) A student who passes the test gives the “correct” answers to others; (b) A communal answer key is circulated “suggesting” the correct answers; and (c) One student actually takes the on-line test for others. These and other situations that might be mentioned might technically help an organization meet the NIMS compliance requirements, but they do not generate competency.

In addition, recognizing not only the pressures to meet compliance standards but also the temptation that these pressures create, certain commercial vendors have started to market “training tools guaranteed to assure NIMS compliance” in unbelievably short periods of time – and, not so coincidentally, for remarkably high prices.  One advertisement recently noted that, by purchasing one approximately 27-minute video program (available in DVD or VHS), the viewer would have all of the information needed to successfully complete tests for at least three fairly difficult NIMS courses.  Another commercial venture offers room training that in eight hours or less will enable the student to satisfy the training requirements for three other courses – provided, of course, that the agency for which the student works assumes the validation liability. One can only suggest, “Let the Buyer Beware.”

However, the initial challenge remains the same: Should a state or other jurisdiction try to train for competence or merely train to compliance? Like virtually all of its partner states (as well as numerous local and tribal entities), the Commonwealth of Virginia is confronting this challenge in a number of ways. The Virginia Department of Fire Programs (VDFP), to cite but one example, has chosen to “Train for Competence.” The department’s perspective has not been universally embraced, of course. However, realizing that its constituents are held to a high level of performance expectation, VDFP has determined that it is unacceptable to simply “train to compliance.”  Classroom training in all NIMS and ICS (Incident Command System) curricula is strongly recommended by the department. 

The Determining Factor: Demonstrable Competence

A number of factors were considered in determining the direction VDFP has adopted for its NIMS and ICS training programs. The net effect has been positive, as indicated by the following:

First:  Students are “strongly encouraged” to participate in room training to meet their NIMS and ICS training requirements.  The classroom environment provides direct input and feedback and generally results in better and more lasting understanding.  (Although not completely discounting the importance of accessibility of the on-line training programs, VDFP instructors consistently note that many students entering ICS training are, at best, only minimally familiar with the basics of ICS if they have participated only in on-line training.)

Second:  VDFP endorses the requirement for teaching basic ICS courses in a minimum of 20 hours; the optimal time, though, would be 22-24 hours.  More advanced ICS training should be taught in not less than 12-14 hours. The agency has experimented with supposedly “compressed” and/or “condensed” delivery methods of training, but the instructional strategies for these alternative training methods have been largely unsuccessful.

In addition to supporting fundamental training programs that are consistent with the NIMS priorities and criteria, VDFP has undertaken several other initiatives.  It is too early to determine if any or all of those initiatives will be successful, but early indications are that they will be both popular and productive. Following are two examples:

(1) Development of a stand-alone “ICS Planning and Forms” class.  This class, based upon adaptation of a National Fire Academy (NFA) planning course, is a one-day “upgrade” or refresher in the primary components of the ICS planning process – including such topics as the Tactics Meeting, Preparing for the Planning Meeting, the Planning Meeting, and the Operational Period Briefing (Shift Briefing).  Using a progressive process of forms development and use, the individual student is taken through the key elements of the planning process with practical development of the forms needed in each step. The class culminates in a critiqued delivery of an operational period briefing. Although still in the “pilot” testing phase, the student responses have been extremely strong to date, eliciting such comments as “This course covered stuff we never got in the [basic] ICS-300 when we took it.”  The primary purpose of this course is to augment or “upgrade” the minimal training often provided in ICS-300 classes intended only to “check the box” in the ICS planning process.

(2) Expanded deployment of the National Fire Academy course, Command and General Staff Functions in the Incident Command System (CGSFICS), as a means to develop local, regional, and eventually statewide capabilities toward the creation of Mobile Incident Support Teams (MISTs) capable of establishing or reinforcing local incident management efforts.  This effort is an excellent example of the familiar “walk before you run” principle.  The desired initial outcome is to develop a cadre of individuals who possess a sound understanding of command and general staff functions and also have the ability to establish (or fill in for) an incident command structure anywhere in the Commonwealth – if and as needed.   Specific attention is being paid to regional MIST development.  The eventual outcome hoped for is the development of cadres of 25 to 30 or more individuals within each of the Commonwealth’s seven Homeland Security Regions.  Most localities in Virginia will not have the personnel resources immediately available to establish their own IMT or MIST for sustained operations (two weeks or longer) without relief.  Recognizing that, when a significant event occurs, one region may be severely stressed, a MIST from a neighboring (or further) region could be mobilized – if needed and requested – to support the stricken area during the immediate aftermath of a major incident.  Similarly, members from several MIST groups could be assembled in a task-force construct to provide large-scale and/or longer-duration support for incident management functions.

Here it should be noted that the MIST concept does not supplant or discount the IMT concept. In Virginia, very few localities will have the personnel resources needed to support full-scale development of Type 3 or above IMT capabilities – especially for deployment outside their assigned jurisdictional boundaries. The VDFP strategy is to meet this challenge by developing a broad-based capability in which enough individual responders will have had the training and practice needed to staff several different key positions and therefore could be assembled in a flexible manner when and if the need arises. By developing these “just in case” staff groups from around the state, the potential of being able to mobilize a sufficient number of appropriately qualified personnel in a timely manner is significantly increased. To date, approximately 120 individuals have completed the VDFP-sponsored training required for this class. VDFP believes it has the core components for developing and maintaining MIST capabilities, but also acknowledges the need for further work as described next.

(3) Development of annual (or more frequent) practical review training periods in the form of a program entitled, “Command and General Staff Functions – Practical Evolutions” (CGSF-PE).  This program is designed to complement the training provided in various ICS and CGSFICS courses as well as the ICS Planning and Forms classes through an intense real-time sequence of planning exercise steps under conditions as close as possible to “real-life” working situations.  Participants must form their own MIST (or IMT) for a simulated scenario for at least one full operational period (12 hours), prepare an appropriate plan for the next operational period, and carry out a “shift change” briefing for an incoming MIST/IMT.  A special feature of this program is that it can be extended for an indefinite number of “shifts” – depending, of course, on the number of participants, the time available, and the funding provided. (The program has been highly successful, but is currently limited by funding constraints.)

To summarize: The NIMS concept for developing a national incident management capability is both necessary and achievable.  NIMS compliance is one step, but only one, in the process of developing that capability.  The most important step falls on the lower-level jurisdiction, and specifically involves accepting the responsibility to develop competence.  In other words, simply training to achieve compliance will not suffice. Training to develop and sustain competence is essential.