Comment Submitted by John Mark Hooker, Arkansas Department of Emergency Management

Comments for: NIMS Guideline for the Credentialing of Personnel, Draft November 21, 2008 Definition: For the purposes of NIMS, the term credentialing refers to information a person will present to the requesting jurisdiction—i.e., (1) identity, (2) qualification/affiliation, and (3) authorization for deployment. NIMS credentialing does not confer the authority or privilege to practice any profession. Only the receiving jurisdiction can extend that privilege or authority after evaluating the person’s information. (Page 4, 2nd Paragraph) 1. This document describes recommendations to States and local authorities for their consideration in adopting policies to enable credentialing and access control for responders and recovery personnel deployed to an incident area. These processes are said to be voluntary; however, the 2008 NIMS Compliance Objective 23, “Initiate the development of a State/Territory-wide credentialing system,” seemed to mandate the use of federal guidelines. To input anything other than an affirmative response required a corrective action. 2. The development process is at the jurisdictional level. Local jurisdictions and the States, respectively, are tasked with development of a credentialing system for their political boundary or area of control. 3. The “NIMS Credentialing Checklist,” found on page 7 lists functions and processes that make up credentialing. “Establish standards for the jobs and duties of emergency response officials from minimum through advanced levels or degrees of competency,” is the first action item in this checklist. If each "Jurisdiction" establishes standards, how will these be maintained beyond jurisdictional or State boundaries? (i.e. a Basic EMT in AR may have a skill set not equal to a Basic EMT in TN) 4. In Section 2, under General Guidance on page 9, jurisdictions are encouraged to “Establish a program for issuing credentials for interstate mutual aid.” Again, if credentialing standards are not developed at the national level they may not be equal from one State to another. 5. The guideline as a whole, gives broad recommendations but without specific standards interoperability cannot be ensured. Other concerns with this process include: a. Development of standards for machine readable technology b. Choice of technology: Smart Cards vs. RFID vs. other electronic media, and what are the interoperability challenges c. Validation and auditing processes at each level of government (How can I be confident that a credential from an out-of-state responder is current and valid?)