A forced fit: Why HSEEP Is the Wrong Framework for Executive Crisis Leadership

HSEEP is the dominant framework for crisis exercise design across the public and private sectors, and at the operational level, it earns that position. It was not built for executive crisis training. Applied to the C-suite, a validation framework is being asked to do the work of a development one. This essay is about why that mismatch matters, and what executive crisis training should do instead.

This is the second article in Ground Truth, a five-part series from Jim Featherstone on the structural challenges of crisis and emergency management.

After more than thirty years in crisis and emergency management, I have watched many executive leadership teams go through exercises designed to prepare them for the worst day of their organization's life.

Most of those exercises are well-run. The objectives are documented. The injects arrive in sequence. The After-Action Reports get filed. By every standard the field uses to evaluate exercise quality, the sessions look successful.

And yet I keep noticing the same thing in the room.

The executives are working on the wrong problem.

Not because they do not understand the scenario. Because the exercise was designed to answer a question that is not actually the executive question.

In 2024, General Electric sold Crotonville, the leadership development center that trained executives for decades and inspired similar programs at IBM, 3M, and Boeing. Each of those companies has since closed or divested comparable facilities.

The verdict was widely understood: the standardized, centralized, compliance-driven model of leadership development had stopped keeping pace with the complexity executives actually face.

The field of crisis preparedness has not yet received that memo.

The Homeland Security Exercise and Evaluation Program, known across the field as HSEEP, remains the dominant framework for crisis exercise design across the public and private sectors. Its value is real. When applied to operational coordination, multi-agency response, and emergency operations centers, HSEEP is both effective and necessary.

But somewhere along the way, HSEEP migrated upward into executive and C-suite crisis training, where it was never designed to operate. The result is what one practitioner framework describes plainly: a polite executive version of an EOC drill.

The problem is not HSEEP. The problem is what happens when a compliance-driven validation framework is applied to a development challenge it was never built to address.

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Two Questions. Two Different Problems.

HSEEP answers one question, and it answers it well:

Can the organization perform the expected functions?

That is a critical question. It is not the question that executives need to practice answering.

The executive question is structurally different:

What should we do when our expectations no longer apply?

The first question can be evaluated against a known standard. The second cannot. The first assumes the problem is understood. The second begins by asking what the problem actually is.

These are not variations on a theme. They are different cognitive challenges that require different training environments.

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What HSEEP Was Built to Do

HSEEP emerged from federal homeland security efforts as a standardized methodology for managing terrorism-preparedness exercises. It is a capabilities-based program, designed to evaluate whether organizations can execute known, pre-defined functions against the Core Capabilities drawn from the National Preparedness Goal.

The HSEEP cycle, including the Concept and Objectives Meeting, the Initial Planning Meeting, the Master Scenario Events List, the After-Action Report, and the Improvement Plan, is a disciplined sequential process that produces consistency and accountability across jurisdictions.

Those are precisely the qualities you want when multiple agencies must coordinate a response, when federal grant compliance must be demonstrated, and when capability gaps must be documented for remediation.

HSEEP is well-suited to answering its question. It is the question itself that is wrong for the executive room.

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The Scripted Scenario Problem

HSEEP exercises are built on the premise that the problem is already understood and that success can be measured against a known set of criteria.

The scenario has a narrative arc. The injects flow in a controlled sequence. The Master Scenario Events List, or MSEL, has been engineered to elicit specific anticipated responses. The correct answer, in a meaningful sense, exists before the exercise begins.

This produces a predictable dynamic. Participants play to the objectives. They know, because the planning process has signaled it, which capabilities are being evaluated.

Researchers writing in Homeland Security Affairs put it directly: HSEEP exercises may not surface the failure modes that could significantly affect performance in a real incident, because the exercise design forecloses the possibility of those failure modes occurring.

At the operational level, that limitation is manageable. The known capabilities still need to be validated.

At the executive level, it is foundational. The failure modes that matter most for senior leaders are not logistical. They are cognitive and strategic: delayed decisions, over-centralization of authority, communication breakdowns, and the inability to weigh competing priorities under pressure. HSEEP exercises, by design, eliminate the conditions under which those failure modes would surface.

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Without Consequence, There Is No Development

In HSEEP exercises, there is no real financial exposure, no actual reputational damage, no regulatory consequence, and no board accountability. Decisions become theoretical.

And when decisions are theoretical, participants default to textbook responses. Not because they are incapable of better. Because the environment offers no incentive for risk or genuine judgment.

In Ground Truth 1, I described Gary Klein's research on Recognition-Primed Decision Making, the way experienced leaders match unfolding situations to patterns from past experience and mentally simulate outcomes under pressure. That capability does not develop in low-stakes environments.

The expert judgment executives need is built through repeated exposure to high-stakes, high-pressure decisions. Simulated compliance environments, however well-structured, do not build that muscle.

Operating in crisis is not difficult because new processes are required. It is difficult because employing intuition in high-stress environments becomes progressively harder.

Degraded intuition under pressure is not a gap that scenario familiarity can close.

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The Pull Toward Tactical Thinking

There is another failure mode I have watched repeatedly.

Executives placed in HSEEP-structured exercises consistently drift toward operational questions.

Resource deployment. Incident command structure. Field coordination. Status reporting.

These are the questions the exercise was designed to surface. Facilitators trained in the HSEEP methodology are oriented toward capability evaluation rather than strategic judgment development.

The result is that C-suite leaders end up doing a rebranded EOC drill. It looks like executive training. It is not.

Executive responsibilities sit above the operational layer. They include enterprise-level trade-offs, legal and regulatory exposure, communication posture, fiduciary integrity, and stakeholder confidence. The relevant facilitation prompt is not 'What action would you take?' It is 'What is the executive decision embedded in this?'

That question has to be asked precisely because the exercise structure is always pulling in the opposite direction. The need to constantly redirect is not a failure of facilitation. It is a symptom of a structural mismatch.

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Measuring the Wrong Things

HSEEP's evaluation methodology reflects its compliance-oriented origins. The standard participant feedback form solicits general preparedness assessments through a Likert scale. Research published in the Domestic Preparedness Journal concluded that the current HSEEP evaluation methodology may not yield sufficient data to accurately measure exercise effectiveness because feedback questions are limited, are not explicitly tied to objectives, and do not weight answers differently.

FEMA updated the HSEEP doctrine in 2020, but did not update the participant feedback form. The evaluation framework remains largely unchanged.

A purpose-built executive evaluation framework asks different questions. Time from trigger to executive quorum. Percentage of agenda items resulting in documented decisions. Time to approve the communication strategy. Qualitative evaluator ratings of leadership, clarity, and decisiveness.

And the question HSEEP cannot answer: did the lessons learned change governance policy, or only the training plan?

Organizations relying on HSEEP-driven After-Action Reports as evidence of executive readiness are measuring outputs rather than outcomes. They may not discover the gap until a real crisis makes it unmistakably clear.

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What Executive Crisis Training Should Actually Do

The field has produced both the critique and the alternative. The challenge is adoption.

A few principles should anchor the development of executive crisis.

Train judgment, not procedures. Executive sessions should develop the capacity to make good decisions in genuine ambiguity. That means scenarios with incomplete information, conflicting stakeholder demands, and no clear correct answer.

Surface stress responses before a crisis does. Fight, flight, and freeze each have distinct executive failure modes, namely rashness, over-consensus-seeking, and analysis paralysis. Effective training surfaces those patterns under controlled conditions. HSEEP exercises, which eliminate genuine pressure, cannot surface them at all.

Require consequence. Free-play simulations, adversarial red teaming, and board-level scenarios that incorporate media pressure, regulatory intervention, and investor response create the conditions for genuine executive judgment.

Maintain strategic altitude. Executive sessions require a different facilitation approach than HSEEP's controller-evaluator model. The facilitator needs firsthand executive experience, not just exercise certification.

Measure what matters. Decision quality, decision speed, strategic coherence, and evidence that insights changed governance policy. Not whether the After-Action Report was completed on schedule.

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A Valuable Framework in the Wrong Room

HSEEP is not a failed framework. Applied to the contexts for which it was designed, it remains indispensable.

The problem is what happens when a compliance-driven validation methodology is applied to a development challenge it was never built to address.

The Crotonville closure offered a verdict on one era of standardized leadership development. The emergency management field has the opportunity to draw the same lesson before a major crisis draws it for us.

The question is not whether organizations should exercise. They absolutely should.

The question is whether C-suite executives are being trained in a way that will actually prepare them to lead when the scenario goes off-script, the injects stop arriving, and the only thing standing between an organization and its worst outcome is the quality of the decision at the top of the room.

HSEEP cannot answer that question.

The sooner we design executive crisis training that can, the better.

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One Question for Senior Leaders

Look at the last crisis exercise your executive team participated in.

Now ask:

Did anyone in the room have to make a decision that was not anticipated by the scenario design?

If the answer is no, the exercise validated your operational capability. It did not develop your executive judgment.

Those are not the same thing.

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Key Takeaways

What is HSEEP designed to do? HSEEP, the Homeland Security Exercise and Evaluation Program, is a capabilities-based methodology for validating whether organizations can perform pre-defined functions against the Core Capabilities drawn from the National Preparedness Goal. It is the federal standard for operational and multi-agency exercise design, and within that scope it works.

Why isn't HSEEP appropriate for executive crisis training? HSEEP answers one question: can the organization perform expected functions? Executives need to practice a different question: what should we do when our expectations no longer apply? The first can be measured against a known standard. The second cannot. Applying a validation framework to a development challenge produces what one practitioner described as a polite executive version of an EOC drill.

What's the difference between validating capability and developing executive judgment? Validation confirms that known procedures can be executed. Development builds the cognitive capacity to act well in ambiguity. The first assumes the problem is understood; the second begins by asking what the problem actually is. These are different training environments with different facilitators, different scenario designs, and different evaluation criteria.

What should executive crisis training actually include? Five elements: scenarios with incomplete information and no clear correct answer; conditions that surface fight, flight, and freeze responses; consequence in the form of media pressure, regulatory intervention, or board exposure; facilitation by someone with firsthand executive experience; and evaluation against decision quality and governance change, not exercise completion.

How should executive crisis exercises be evaluated? Not by After-Action Report completion or Likert-scale feedback. By measurable executive outcomes: time from trigger to executive quorum, percentage of agenda items resulting in documented decisions, time to approve a communication strategy, and qualitative ratings of leadership clarity and decisiveness under pressure. And by whether insights changed governance policy, or only the training plan.

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For Further Reading

Ground Truth 1, The Disaster Always Has a Vote, introduces the cognitive framework underpinning this argument, Gary Klein's Recognition-Primed Decision Making,  through a first-person account of executive decision-making during the Palisades Fire debris removal operation.

Recognition-Primed Decision Making is a model developed by Gary Klein through research on fireground commanders that describes how experienced leaders, under pressure, rapidly match situations to patterns from past experience, mentally simulate outcomes, and act. Klein's book Sources of Power: How People Make Decisions (MIT Press, 1998) remains the most accessible introduction.

The Homeland Security Exercise and Evaluation Program doctrine itself, last updated by FEMA in January 2020, is available through FEMA's National Preparedness Toolkit. It is required reading for understanding both what HSEEP does well and the assumptions that limit it at the executive level.

For a parallel argument from the corporate leadership development world, see Rethinking Leader Development: Lessons from the Closure of General Electric's Crotonville, by David Livingston and Ryan Flynn, published by McChrystal Group in May 2024.

Written by James 'Jim' Featherstone, Executive Consultant – Emergency Management

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About James 'Jim' Featherstone

Jim is a seasoned public safety and emergency management leader with over 30 years of experience. He began his career with the Los Angeles Fire Department in 1986 and later served as Interim Fire Chief. He was appointed General Manager of the Los Angeles Emergency Management Department in 2007, leading citywide preparedness and resilience efforts until 2016.

After retiring, he served as Executive Director of the Los Angeles Homeland Security Advisory Council, advancing regional collaboration across Southern California. In 2025, he returned to public service at the Mayor's request to support Los Angeles' wildfire response and recovery efforts. Jim currently serves as an Executive Consultant in Emergency Management for Bent Ear Solutions and is the founder and owner of Themata Strategic.

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About Bent Ear Solutions

Bent Ear Solutions (BES)was built by and for emergency managers and helps government agencies and critical infrastructure organizations get more out of the technology and processes they already have.

Bent Ear Solutions specializes in operationalizing frameworks, plans, and policies through an organization's situational awareness dashboard, supporting comprehensive and accurate decision-making. This takes situational awareness to the next level by providing the specific policies, procedures, and actions required for each emergency when needed most.

Read the full Ground Truth series by Jim Featherstone