A few days ago I had a bit of discussion with others on Twitter in regard to who actually has a need for ICS 400 training. I think a lot of people are taking the ICS 400 (Advanced ICS for Command and General Staff) course for the wrong reasons. While I’d never dissuade anyone from learning above and beyond what is required, we also, as a general statement, can’t be packing course offerings with people who don’t actually need the training. There is also an organizational expense to sending people to training, and the return on that investment decreases when they don’t need it and won’t apply it. Overall, if you are a new reader, I have a lot of thoughts on why our approach to ICS Training Sucks, which can be found here.

Before we dig any deeper into the topic, let’s have a common understanding of what is covered in the ICS 400 course. The course objectives identified in the National Preparedness Course Catalog for some reason differ from those actually included in the current 2019 version of the course, so instead I’ll list the major topics covered by the two-day course:

• Incident Complex
• Dividing into multiple incidents
• Expanding the Planning Capability
• Adding a second Operations or Logistics Section
• Placement options for the Intel/Investigations function
• Area Command
• Multi-Agency Coordination
• Emergency Operations Centers
• Emergency Support Functions

For this discussion, it’s also important to reference the NIMS Training Program document, released in the summer of 2020. This document states many times over that it includes training recommendations and that the authority having jurisdiction (AHJ) determines which personnel are to take which courses. This document indicates the ICS 400 is recommended for:

1. ICS personnel in leadership/supervisor roles
2. IMT command, section, branch, division, or group leaders preparing for complex incidents

Note that while #1 above seems to fully capture anyone in a leadership/supervisor role, the document also says that IMT unit, strike team, resource team, or task force leaders preparing for complex incidents do NOT need the training. I’d say this certainly conflicts with #1 above.

With that information provided, let’s talk about who really needs to take the ICS 400 from a practical, functional perspective. First of all, looking at recommendation #1 above, that’s a ridiculously broad statement, which includes personnel that don’t need to have knowledge of the course topics. The second recommendation, specific to IMTs, I’ll agree is reasonably accurate.

Having managed a state training program and taught many dozen deliveries of the ICS 400 course, I’ll tell you that the vast majority of people taking the course don’t need to be in it. I’d suggest that some deliveries may have had absolutely no one that actually needed it, while most had a scant few. Much of this perspective comes from a relative determination of need of personnel that fit within recommendation #1 above. Just because someone may be an incident commander or a member of command and general staff, doesn’t necessarily mean they need to take ICS 400. It’s very likely that through their entire career all of the incidents they respond to and participate in the management of can be organized using standard ICS approaches.

Interface with an EOC does not mean you need to take ICS 400. There is, in fact, a better course for that, aptly named ‘ICS/EOC Interface’. More people need to take this course than the ICS 400. I’m also aware that some jurisdictions require ICS 400 for their EOC staff. The ICS 400 course doesn’t teach you how to function in or manage an EOC. Again, the ICS/EOC Interface course is the better solution, along with whatever custom EOC training is developed (note that none of the FEMA EOC courses will actually teach you how to manage or work in YOUR EOC). If you feel that people in your EOC need to know about some of the concepts within the ICS 400, such as Multi-Agency Coordination or Area Command, simply include the appropriate content in your EOC training. To be honest, I can tell most EOC personnel what they need to know about an Area Command in about three minutes. They don’t need to sit through a two-day course to learn what they need to know.

Cutting to who does need it (aside from IMT personnel), personnel who would be a member of Command and General Staff for a very large and complex incident (certainly a Type I incident, and MAYBE certain Type 2 incidents) are the candidates. Yes, I understand that any jurisdiction can make an argument for their fire chief or police chief, for example, being the IC for an incident of this size and complexity, though let’s consider this in a relative and realistic sense. Most incidents of this size and complexity are likely to span multiple jurisdictions. Particularly in a home rule state, that fire chief or police chief is typically only going to be in charge of that portion of the incident within their legal borders. Although that incident may be a Type I incident taken as a whole, it will likely be managed in large part by a higher AHJ, which may use some of the concepts outlined in the ICS 400. While local government is still responsible for managing the portion of the incident within their borders, they are much less likely to utilize any of the ICS 400 concepts themselves. Along a similar line of thought, most jurisdictions don’t have hazards that, if they become incidents, would be of such size or complexity within their jurisdiction that would require use of these concepts. This leaves larger, more populous jurisdictions generally having a greater need for this level of training.

At some point, every state and UASI was required, as part of their NIMS implementation, to develop a NIMS training plan. Most of the plans I’ve seen further perpetuate the idea that so many people must have ICS 400 training. As part of this, many states require that anyone holding the position of fire chief must have ICS 400. Considering my argument in the paragraphs above, you can see why this is tremendously unnecessary. We must also consider erosion of knowledge over time. As people do not use the knowledge, skills, and abilities they have learned, that knowledge erodes. This is highly likely with the concepts of ICS 400.

A lot of states and other jurisdictions need to take a more realistic look at who really needs ICS 400 training. I’d also like to see some clarification on the matter in FEMA’s NIMS Training Guidance. It’s not about making this training elite or restricting access, but it is about decreasing the perceived and artificially inflated demand for the course.

What’s your jurisdiction’s take on ICS 400 training?

© 2021 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®