On
February 27, 2007, the Health Resources
and Services Administration (HRSA) made
the draft Program Information Notice
(PIN), “Emergency Management Program
Expectations,” available for public
comment on HRSA's Web site. The purpose
of the PIN is to provide guidance on
emergency management expectations for
health centers to assist them in planning
and preparing for future emergencies.
Comments were due to HRSA by April 13,
2007.
Comments
were received from 31 organizations
and/or individuals regarding the draft
PIN. After review and careful consideration
of all comments received, HRSA amended
the PIN to incorporate certain recommendations
from the public. The final PIN reflects
these changes.
The
purpose of this document is to summarize
the major comments received and convey
the agency's response, including any
corresponding changes made to the PIN.
Where comments did not result in a revision
to the PIN, explanations are provided.
Issue:
Purpose of the PIN
Comments
Most commenters supported
the publication of this guidance stating
that there is a need to clarify the
expectations and roles of health centers
around emergency management. A number
of the comments suggested the use of
common terminology pertaining to emergency
management. A majority of the comments
also indicated that the PIN did not
identify additional funds or resources
to assist in covering the expenses associated
with meeting the expectations identified
in the PIN. A number of organizations
and individuals asked whether there
was a timeframe in which health centers
should have these expectations in place.
HRSA Response
HRSA has published
the final Health Center Emergency Management
Program Expectations PIN with the goal
of providing the clarifications requested.
As part of their ongoing grant awards,
health centers are expected to incorporate
emergency management activities into
their existing risk management standards,
practices, and processes. To assist
health centers in providing emergency
medical care and/or to assure the continuity
of essential primary health care services
during/after an emergency, HRSA through
its cooperative agreements with national
and state organizations will provide
additional technical assistance resources
and training on emergency management
for health centers.
Issue:
Applicability
Comments
A number of commenters
suggested that the PIN lacked distinction
of emergency management expectations
between large and small health centers
as well as for new start health centers.
Some commenters expressed concerns that
there should be special considerations
for homeless and migrant health centers.
HRSA Response
HRSA recognizes that
a health center’s size, location, resources,
target population, etc., may determine
how it plans and implements an emergency
management strategy that is relevant
and appropriate for its situation. The
final PIN provides health centers with
general emergency management program
expectations that can be adjusted based
on each health center’s established
role in the local response and its unique
circumstances. The final PIN is applicable
to all section 330 funded health centers
(including new starts) and Federally
Qualified Health Center (FQHC) Look-Alikes.
The expectations presented in the final
PIN are flexible enough to accommodate
health centers serving diverse populations
and includes general considerations
for special populations.
Issue:
Use of technical terms
Comments
A number commenters
suggested that HRSA rewrite this section
in plain English to reduce the use of
technical jargon. In addition, commenters
suggested that the terms and entities
discussed in the background section
be clarified to establish their relevance
and relationship to a health center’s
EMP. Commenters further suggested that
the PIN be amended to reflect that coordination
in emergency planning is beneficial
not only to national incidents but to
local or regional incidents as well.
HRSA Response
Much of the terminology
regarding the national emergency management
documents and resources as used in the
draft PIN may have been unfamiliar to
health centers. The background section
in the final PIN provides further clarification
of these terms and introduces health
centers to the Federal and national
framework for emergency management and
how this is relevant to the development
and implementation of a health center’s
EMP. In the final PIN, HRSA has also
provided a definitions section and a
list of website addresses to many of
the key national Federal resources for
emergency management.
Issue:
Components of the emergency management
plan
Comments
Most of the commenters
requested further clarification of the
specific activities health centers should
include in an EMP and the terms used
in relation to the EMP expectations.
HRSA Response
A health center’s size,
location, resources, target population,
etc., are several of the factors that
a health center should consider when
developing and implementing an emergency
management strategy that is relevant
and appropriate for its situation. The
EMP should be a reflection of the unique
characteristics and circumstances of
the health center, but it should also
clearly document a process that corresponds
to, at a minimum, the following: geographic
location; size and complexity of its
facility and operations; number of staff;
types of hazards most likely to occur
(as identified by conducting a hazard
vulnerability analysis); current local/regional/State
emergency management plans; resources
available in the community; and the
health center’s role in its community
in the event of an emergency.
A health center should
include those activities in its EMP
that are most appropriate for the center.
For instance, a health center should
only include decontamination tents or
isolation rooms in its EMP if these
resources are readily accessible and
available either directly to the grantee
or as part of the local/regional/State
emergency management plan that includes
a defined role for the health center
in utilizing these emergency resources.
HRSA has also revised
this section of the final PIN to ensure
that the terms used have been clearly
defined and that each health center
is not expected to include all the elements
listed in their EMP but rather, that
each health center should develop and
implement an EMP that is most appropriate
for its circumstances which may include
some or all of the elements listed.
Issue:
Testing and evaluation
Comments
A number of commenters
requested clarification regarding emergency
management drills and exercises.
HRSA Response
In general, there are
four phases of emergency management:
mitigation, preparedness, responses,
and recovery. Testing and evaluation
of the EMP are classified as emergency
management preparedness activities.
Training is another preparedness activity
in which health centers should be continually
and actively engaged. Testing and evaluation
can take different forms—from table
top drills, functional exercises, to
full-scale exercises. Regardless of
which methods a health center selects,
the goal should be the same: to evaluate
and identify what works and what doesn’t.
The final PIN has been
amended to reflect that the frequency
and methods of testing and evaluation
should be determined as appropriate
by the health center but should at least
be conducted on an annual basis.
Issue:
NIMS compliance requirements
Comments
Many commenters noted
that the draft guidance did not discuss
NIMS compliance requirements or a timeframe
for health centers to become compliant.
HRSA Response
HRSA strongly encourages
health centers (i) to understand the
National
Incident Management System (NIMS)
and National Response
Plan (NRP) framework, (ii) to use
the Incident Command System (ICS)
in context of their emergency management
strategy, and (iii) move toward full
NIMS compliance. Compliance with NIMS
is required for certain programs receiving
Federal funding and, while it is not
a requirement for health centers at
this time, compliance with NIMS is strongly
encouraged as it provides valuable information
for emergency management planning and
implementation. Health centers should
visit the Department of Homeland Security’s
web site training.fema.gov for training information
and resources. There are a number of
Federal resources online that are available
free of charge; these resources are
listed in the final PIN in Section VI.
Issue:
Personal and family response plan
Comments
A few commenters noted
that the draft guidance lacked a discussion
of the importance of personal and family
planning and preparedness.
HRSA Response
HRSA has revised the
PIN to include the following statement
on personal and family emergency planning
and preparedness:
Individuals impacted
by emergencies often experience significant
emotional stress. The health center’s
EMP should address the behavioral needs
of both patients and staff and identify
additional resources for providing those
services. The plan should also help
staff prepare their families for emergencies—if
staff are prepared at home, they are
more likely to carry out vital responsibilities
and duties at work in the health center.
Issue:
Expectations for Special Populations
Comments
A number of commenters
indicated that additional clarification
was needed around how the proposed expectations
relate to health centers serving special
populations (i.e., homeless persons
and migrant and seasonal farmworkers
and their families).
HRSA Response
The expectations outlined
in the final PIN are flexible enough
to apply to ALL health centers
funded under the Health Center Program
and to FQHC Look-Alikes, regardless
of their target populations. As discussed
above, all health centers, including
migrant health centers, health care
for the homeless centers, and public
housing primary care programs, should
engage in emergency management activities
that are most appropriate for its size,
location, resources, target population,
etc.
Issue:
Command and control
Comments
A number of commenters
indicated that the EMP should address
command and control.
HRSA Response
The final PIN includes
and clarifies command and control in
the context of a health center’s EMP.
Issue:
Reporting protocols between HRSA and
health centers
Comments
A number of commenters
suggested that the draft PIN lacked
clarity regarding the expectations for
health center reporting of data and
information during and after an emergency.
Further, a number of commenters requested
clarification in terms of which data
elements health centers will be expected
to report and to whom.
HRSA Response
HRSA has revised the
final PIN to note that it will attempt
to contact each affected organization
in the event of an emergency to request
general information. Exact requests
may vary. Generally, HRSA expects it
will ask health centers for information
on operating status, impact on the delivery
of health care, or infrastructure needs.
Issue:
Cash reserves
Comments
A few commenters requested
clarification on maintaining cash reserves.
HRSA Response
The purpose of incorporating
emergency management considerations
in the health center’s business plan
is to reduce and/or minimize potential
adverse impacts brought about by an
emergency. Health centers should consider
this as good business strategy to ensure
that it can safely and quickly stabilize
operations and finances in the wake
of an emergency. HRSA has included more
discussion on maintaining financial
viability in the final PIN.
Issue:
Terrorism risk insurance
Comments
One commenter suggested
that the expectations should include
information related to the Terrorism
Risk Insurance Act of 2002, effective
November 26, 2002. This law indicates
that health centers are entitled to
insurance coverage for losses arising
out of acts of terrorism, as defined
in the Act. Covered losses caused by
acts of terrorism will be partially
reimbursed by the United States government
under a formula established by Federal
law (the US government pays 90% of covered
terrorism losses exceeding the statutorily
established deductible paid by the insurance
company providing the coverage).
HRSA Response
Organizations interested
in finding out more information on this
subject should contact the Department
of Homeland Security.
Issue:
Protection of medical records
Comments
A few commenters requested
additional clarification for the treatment
of medical records and privacy concerns
in the event of an emergency.
HRSA Response
The
Department of Health and Human Services
has a number of resources available
to provide guidelines
on privacy during emergencies.
Issue:
FTCA Coverage for Health Centers
Comments
A few commenters requested
additional clarification of FTCA coverage
for deemed health centers responding
to emergencies.
HRSA Response
HRSA has developed
and issued PIN 2007-16, “Federal Tort Claims Act (FTCA) Coverage
for Health Center Program Grantees Responding
to Emergencies” to provide
further clarification of FTCA coverage
for deemed health centers during emergencies.
