10.6.6 Pandemic Plan Requirements

Manual Transmittal

March 11, 2020


(1) This transmits new IRM 10.6.6 Pandemic Plan Requirements, catalog number 71632Y.

Material Changes

(1) This is a new IRM

Effect on Other Documents

Part of IRM 10.6 Continuity Operations


IRM 10.6.6 applies to all Business Unit personnel responsible for planning and implementing any portion of the Pandemic Plan in response to any incident affecting IRS personnel, operations, or tax data.

Effective Date


Kevin Q. McIver
Deputy Human Capital Officer OS:HC

Program Scope and Objectives

  1. Since 2006, the Department of Homeland Security has required that all agencies create and maintain pandemic preparation.

  2. This IRM is to provide guidance to meet requirements from the Department of Homeland Security in preparing a Pandemic Plan for the IRS.


  1. Pandemics are worldwide epidemics affecting a large portion of the population across a large geographic area. Pandemics create the possibility of disruption of processes, movement, and general operations, even if the epidemiology is not severe.

  2. Examples of pandemics include:

    1. Bubonic Plague (542): 50 million people killed in Roman Empire;

    2. Bubonic Plague (1347): One-third of European population killed;

    3. Bubonic Plague (1855–1890): 12 million people killed in China and India;

    4. Influenza (1918) H1N1: Killed between 50 and 100 million worldwide;

    5. Influenza (2009) H1N1; Killed between 100,000 and 400,000 worldwide.

  3. The Internal Revenue Service is committed to having a comprehensive plan to address the ramifications of a pandemic influenza outbreak. It recognizes a pandemic influenza outbreak would potentially have significant human capital implications. IRS employees could be infected or exposed as could their families. IRS processes could be disrupted if the staff requirements are not met. Taxpayers could be impacted, both in process disruption and in areas of physical contact.


  1. The initial authority for Pandemic Response Plan was in the Federal Government Response Stages are available in the Implementation Plan for the National Strategy for Pandemic Influenza.

  2. Department of Labor also issued Accounting for the Needs of People with Disabilities.


  1. Responsibilities are divided between the Continuity Operations (SCR-CO:CO), Human Capital Worklife Programs (HC:WPB), Facilities Management and Security Services (FMSS), and each business unit (BU) where appropriate.

HCO Senior Commissioner’s Representatives-Continuity Operation Requirements
  1. The Senior Commissioner’s Representatives-Continuity Operations (SCR-CO:CO) will:

    1. Maintain the IRS Pandemic Plan in a central, secure, and accessible location;

    2. Solicit and incorporate updates every two years;

    3. Out of cycle, keep Pandemic Plan current with changing requirements from the Departments of Homeland Security, Health and Human Services, and any other agency;

    4. Out of cycle, keep Pandemic Plan current with other changing technologies and policies, such as Telework.

  2. SCR-CO will be responsible for all sections except Reporting Procedures (Annexes F and G), Human Capital (Section D), and IT Requirements (throughout document).

Facilities Management and Security Services Requirements
  1. Facilities Management and Security Services (FMSS) will:

    1. Maintain Annex F Campus Reporting Requirements;

    2. Maintain Annex G Non-Campus Reporting Requirements;

    3. Update Situational Awareness Management Center (SAMC) as appropriate;

    4. Direct control and restrictions as appropriate.

Human Capital Office Requirements
  1. The IRS Human Capital Officer is required to provide updates to Annex E, Infectious Disease Reporting Protocol; and Annex D, Human Capital Reference to Pandemic Health Issues.

  2. Health Information to be provided:

    1. Education;

    2. Assessments at FOH clinics;

    3. Reports to other agencies;

    4. Work Related Travel;

    5. Services covered under Federal Occupational Health (FOH) Contract.

  3. Other information which may be required:

    1. Telework;

    2. Leave;

    3. Leave Sharing Program;

    4. Work Schedules;

    5. Pay;

    6. Employee Assistance Program;

    7. Benefits;

    8. Hiring Policies;

    9. Labor Relations.

Information Technology Office Requirements
  1. The Information Technology Office is required to provide updates to ANNEX C: Pandemic Influenza – ITS’ Strategy for Preparedness

  2. This will cover:

    1. Contingency Planning;

    2. Operations;

    3. Telework;

    4. Personnel;

    5. IT Security;

    6. Supplies and Services.

Servicewide Continuity Plan Requirements
  1. Essential Functions: As with all continuity plans, Federal Continuity Directives-1 and 2 guide the identification of essential functions. Agency pandemic influenza plans should ensure continuity of Primary Mission Essential Functions (PMEFs) and Mission Essential Functions (MEFs) throughout a pandemic.

  2. Due to the extended duration of a pandemic, essential functions addressed within pandemic plans would also include functions that cannot be deferred for 12 weeks or more without impact to an agency’s mission.

  3. In addition, agency plans may address non-essential functions that could be deferred, but can be continued through Telework or otherwise modified operationally to keep employee(s) from being at risk while performing those functions (as with all essential functions).

  4. The functions (and supporting services) addressed within pandemic planning may be performed by Federal agency employees or contractors.

Program Reports

  1. There are no periodic reports for Pandemics.

  2. During a Pandemic event, status reports will be submitted to the IRS Commissioner and the Department of the Treasury (Treasury) on a schedule determined at that time.


  1. See IRM 10.6.1Introduction to Continuity Planning.


  1. See IRM 10.6.1Introduction to Continuity Planning.

Related Resources

  1. See Homeland Security Directive FCD 1 and 2.

  2. IRM 10.6.2Continuity Plan requirements.

Requirements of a Pandemic Plan

  1. The Pandemic Plan must contain the information necessary for IRS leadership to maintain operations during a significant reduction in staffing due to illness.

  2. The Pandemic Plan must also contain information for our oversight agencies (such as Department of Treasury).

Sections of a Pandemic Plan

  1. Plans and Procedures.

  2. Business Functions and Services.

  3. Devolution of Control and Direction/Delegation of Authority.

  4. Orders of Succession.

  5. Primary and Alternate Operating Facilities.

  6. Communications.

  7. Vital Records and Databases.

  8. Human Capital:

    1. General Human Capital;

    2. Employee-Labor Relations;

    3. Pay and Leave Policy;

    4. Staffing Policies;

    5. Telework and Information Technology Capabilities;

    6. Safety and Health of Employees and their Families.

  9. Test, Training, and Exercise.

  10. Reconstitution.


    These Pandemic Plan requirements overlap but do not completely track the requirements for a Continuity Plan.

Annexes of the Pandemic Plan

  1. Annex B - IRS Pandemic Decision Matrix - This is a high level tool for use by IRS decision makers and BU managers to guide pandemic planning, preparedness, and response activities. It provides a summary list of response actions and considerations that support meeting the objectives identified in the IRS Pandemic Plan. It also identifies factors that may limit the implementation of response actions. Coordinated by SCR-CO:CO.

  2. Annex C - Pandemic Influenza – Information Technology's (IT’s) Strategy for Preparedness. This annex covers issues related to keeping IRS' systems operational during times of reduced staffing during to Pandemics, and strategies for enabling employees to work without coming in contact with infectious disease (such as using Telework).

  3. Annex D - Human Capital Reference for Pandemic Health Issues - Guidance on the various human capital issues that are likely to arise in the event of a pandemic influenza outbreak. This annex is for managers for various procedures to follow when a pandemic is declared.

  4. Annex E - Infectious Disease Reporting Protocol. This outlines roles and responsibilities for reporting various issues to Federal, State, and Local governments. It is the responsibility of the Human Capital Office.

  5. Annex F - Campus Reporting Procedures. This is for managers and others when a pandemic situation starts in any of the campuses. This is the responsibility of FMSS.

  6. Annex G - Non-Campus Reporting Procedures. This is for managers and others when a pandemic situation starts in all non-campus offices. This is the responsibility of FMSS.

Certification Requirements

  1. Pandemic Plan Certification requirements differ from Continuity Preparation (See IRM 10.6.5Annual Certification Requirements).

  2. Homeland Security Council requires all agency heads to certify in writing that the agency is addressing the applicable elements of pandemic planning. Any certification from the IRS will be at the request of Treasury and included in their certification.