United States Department of Health & Human Services

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Webinar
Managing Administrative Preparedness Burdens on
State and Local Health Departments
September 20, 2012
Managing Administrative Preparedness Burdens on State
and Local Health Departments
• Administrative Preparedness
– “Ensuring that fiscal and administrative authorities and
practices that govern funding, procurement, contracting,
hiring, and legal capabilities necessary to mitigate, respond
to, and recover from public health emergencies can be
accelerated, modified, streamlined, and accountably
managed through all levels of government.”
Managing Administrative Preparedness Burdens on State
and Local Health Departments
• Casey Wright, ScM
– Senior Policy Analyst, Office of the Assistant
Secretary for Preparedness and Response (ASPR)
– Advises ASPR leadership on a variety of policy
portfolios including administrative preparedness,
national pandemic influenza strategies, and
Presidential Policy Directive 8: National Preparedness
implementation
Administrative Preparedness—
The Initiative
Administrative preparedness must be a core
capability of the nation’s preparedness system at all
levels of government.
Concept Drivers
Guiding Principles
 Non-Stafford Act responses such as
 Upfront investments can help
H1N1, Deepwater Horizon and the
Haiti Earthquake
 Administrative challenges
associated with funding
mechanisms such as PHER
 State and local government’s
increased need for expedited
funding
reduce our overall cost burden
 Policy and operational efficiencies
can expedite the funding process
during a response
 Administrative preparedness is a
long-term goal that should be
incorporated into operational
planning
ASPR: Resilient People. Healthy Communities. A Nation Prepared.
Challenges Exist Across the Funding
Distribution Channel
HHS is embarking on efforts to
address internal barriers
VISABILITY/
ACCOUNTABILITY
Potential Bottlenecks
TIME TO DISBURSE
FUNDS
Operational Barriers
ASPR: Resilient People. Healthy Communities. A Nation Prepared.
Administrative Preparedness—
Defined
Administrative Preparedness—
ensuring that fiscal and administrative
authorities and practices that govern
funding, procurement, contracting,
hiring, and legal capabilities
necessary to mitigate, respond and
recover from public health threats and
emergencies can be accelerated,
modified, streamlined and
accountably managed at all levels of
government.
GOALS
1. Expedite funding during a
response
2. Ensure the adequacy of funding
for response activities
3. Reduce the administrative burden
of the response
ASPR: Resilient People. Healthy Communities. A Nation Prepared.
Federal Activity
• Created a partnership among ASPR, CDC, ASTHO and
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•
NACCHO
Leveraged grant programs
Funded projects with ASTHO and NACCHO
ASPR: Resilient People. Healthy Communities. A Nation Prepared.
HHS Departmental Initiatives to
Improve Efficiency
• Developed new accounting structures to improve financial
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tracking of obligations for funds
Created Department-wide guidance on managing intradepartmental delegations of authority, with particular
focus on new reporting and reconciliation processes
Engaging Department-wide budget, finance, and program
office representatives in a dialogue to establish additional
processes and tools to expedite funding processes
Developing a plan to “operationalize” the decision making
process
ASPR: Resilient People. Healthy Communities. A Nation Prepared.
Goals
• Administrative preparedness is incorporated into all
preparedness planning activities
─ Generate efficiencies in day-to-day procedures that will aid
response activities
─ Develop “on-the-shelf” resources such as MOUs,
emergency contracts
─ Eliminate known and continual barriers
ASPR: Resilient People. Healthy Communities. A Nation Prepared.
Managing Administrative Preparedness Burdens on State
and Local Health Departments
• Sharon Sharpe, MBA
– Associate Director for Grants Management &
Compliance, DSLR
– Advises senior management, project officers
& awardees on federal laws & policies related
to administration of program grants &
cooperative agreements
• Administrative preparedness in the 2011 PHEP FOA
– Included authority to award contingent emergency supplemental
funding
• Eliminate need for additional FOA in future emergencies
• Reduce challenges caused by PAHPA such as matching and MSF
requirements
– Asked applicants to identify state and local administrative
response barriers and mitigating strategies
•
Most common Expedited Administrative Processes
• Special authorities due to official emergency declaration
• Use of Credit cards, field vouchers and/or cash
• Limited Emergency Hiring Authorities
• Most common Barrier to Activating Expedited Administrative
Processes
• Requires an official declaration to invoke
• Budget restrictions (authorities to hire, spend, etc.)
79%
24%
12%
79%
18%
...moving forward in 2012
• Refined awardee administrative preparedness
requirements in FOA 12-1201
– Description of legal authorities
– Receiving, allocating and spending emergency funds
– Legal processes that can minimize potential conflicts of Emergency Use
Authorizations (EUA)
– Formal Memorandums of Understanding or Agreement (MOU/MOA)
with FBI for joint investigations
– Protection of volunteers against tort liability and workers’ compensation
claims
• “Plan forward” submissions within the joint HPP/FOA
due 10/01/12
...moving forward in 2012-2013
• Use data to drive state and local public health
technical assistance
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–
–
–
“Plan forward” submission findings (10/01/12)
NACCHO/Harvard project findings
Future ASTHO project recommendations
Other available sources
• Advance state and local public health
preparedness capacity
Report
• Health Department Barriers to the Administration of Emergency
Preparedness Funds Granted by the Department of Health and
Human Services (DHHS)
– Collaborative partnership with ASTHO
– Harvard School of Public Health
– Joint Administrative Preparedness Workgroup
 Literature review summary
 Development and feedback on interview guide
– Report Goals:
1. Identify Administrative Preparedness Barriers and Challenges
2. Identify Considerations, Practices from the Field, and Promising
Solutions
Report Methodology
• Interviews with State and Local Public Health Officials
 79 total health officials representing 13 states & 36 localities
 Convenience sample: high frequency of emergency declarations,
governance structure, jurisdiction type, and population size
Content
• Report reflects both routine public health preparedness
funds (PHEP/HPP) and contingent emergency
supplemental funding (e.g., PHER)
• Report Structure:
• 5 domains: Accepting, Allocating, Spending,
Monitoring, and Reporting
• Analysis Categorization:
– Routine administrative operations, challenges,
considerations from the field, practices from the field
• Additional legal components:
– Emergency Use Authorizations, Volunteer Liability, FBI
Memorandum of Understanding
Select Barriers
• Timeframe/complexity of process
• Allocation formulas
• Accounting for decreasing funding levels, timelines, and program
sustainability
• Undeclared versus declared emergencies
• Unclear guidance
• Lack of standardized reporting system between states/locals
• Incongruence and perceived lack of correlation between reporting
metrics and the state of preparedness
• Lack of knowledge, awareness, and engagement in Emergency Use
Authorizations
• Disparate understanding of how liability issues affect the use of
volunteers
• Inconsistency in planning for emergencies that require both a public
health and criminal response
Select Potential Solutions
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Use of host agencies/fiscal intermediaries
Staff dedicated to administrative procedures
Multi-year contracts and longer grant cycles
Use of emergency declarations to expedite funds
Standardized criteria for allocation formula
Pooling resources regionally
Integrated reporting systems accessible at all levels of government
Standardized and pre-identified data sets for reporting
Greater state and local input in the development of EUAs
Clear guidance on volunteer protections
Formalized MOU with the FBI
Managing Administrative Preparedness Burdens on State
and Local Health Departments
• Gerrit Bakker
– Senior Director, Public Health Preparedness,
ASTHO
– 27 years with Colorado Department of Public
Health & Environment
• Deputy Director, Emergency Preparedness &
Response Division
• ESF-8 lead to state EOC
Purpose
Building on the environmental scan, ASTHO, in
conjunction with NACCHO, CDC, and ASPR,
developed actionable recommendations for state and
local public health officials to drive the creation of
resources and tools across the following domains:
• Leveraging Personnel Resources
• Developing Actionable Procedures and Policies
• Establishing New Tools
Report Methodology
• Identify common themes and important findings from the
Harvard report
• Conduct an environmental scan of existing reports from
national guidance documents
• Work with national partner organizations including:
National Association of State Budget Officers, National
Association of State Procurement Officials, National
Association of State Personnel Executives, the National
Governors Association, and the Joint Administrative
Preparedness Workgroup to develop recommendations
Environmental Scan Findings
• EMERGENCY PREPAREDNESS FOR STATE
PROCUREMENT OFFICIALS (NASPO, 2008): identifies
issues to consider before, during and after a catastrophic
event.
• STATE PERSPECTIVES ON THE USE OF FISCAL
INTERMEDIATRIES (ASTHO, 2009):
– A few state health agencies have used bona fide agent
arrangements; most have not.
– Contracting arrangements are viewed as the preferred fiscal
intermediary relationship.
– Some state administrative policies can act as structural barriers to
expanding the use of fiscal intermediary arrangements.
– States are uncertain about expanding the use of fiscal intermediary
arrangements.
Environmental Scan Findings
•
ASTHO H1N1 POLICY BARRIERS REPORT (2010)
– States noted several issues pertaining to employer policies and work
place protections.
– States observed that public health recommendation were not universally
supported by employers’ sick/administrative leave policies.
– States also encountered ongoing questions and concerns about
mandating vaccination for health care and other workers.
– There were issues with federal/state/local coordination.
•
NACCHO H1N1 POLICY REPORT (2010)
– Shorten and simplify the grant applications and contracting during
emergencies. LHD need a defined, predictable and larger share of
federal funds including Department of Homeland Security (DHS)
funding.
– There is a need for emergency hiring policies at all levels of
government.
– Just-in-time EUAs are difficult to understand, obtain, and implement.
– Public health preparedness and emergency legislation: A coordinated
emergency response is hindered by states that do not have a defined
declaration of emergency and specific state liability coverage for
volunteers.
Stakeholder Interview Findings
• NGA: Currently, there is no cataloged registry of
legislative and executive order powers; policy academies
and further development of MOUs were seen as
opportunities
• NASPO: There is a growing trend for states to create
different rules of engagement for different entities (i.e.,
higher ed., government agencies). This creates an “unlevel” playing field for states and suppliers and confusion
over what rules apply. It is difficult to convince policy
makers that one set of rules could streamline the
process.
Stakeholder Interview Findings
Continued
• ASTHO Chief Fiscal Officers: Recommended a designated
“Problem Solver” for each state and a “Green Light”
designation for provisional approval of applications.
• ASTHO Human Resources Directors:
– Level of involvement of HR directors varies from state to state, with
some having much involvement, while others have little involvement
because they are not run by a merit system.
– The administrative preparedness requirement on the FOA was
helpful in prompting one state to create a formal plan.
– It would be helpful for the federal government to release specific
guidance when a new funding stream is deployed, especially during
a response.
Recommendations for State/Local
Jurisdictions
• Pursue additional means to increase the use of host
agencies/fiscal intermediaries to expedite the distribution
and use public health funds.
• Develop and distribute model MOUs with partner
agencies (e.g., FBI, laboratories, transportation
agencies, etc.)
• Develop processes for the inclusion of a
financial/administrative staff member in the
preparedness unit of a health agency.
• Engage in the development process of new tools and
templates and checklists with administrative staff.
Recommendations for Further Investigation by
the Preparedness Community & Partner
Agencies /Associations
• Develop and distribute legislative language, waivers, and/or
templates for adoption by state and local jurisdictions to accelerate
administrative processes, such as executing contracts with vendors,
procurement of goods and services, and hiring full-time or temporary
employees, during a declared public health or state of emergency.
• Develop and distribute a checklist for use by grantees and locals to
prepare for application submission in advance of the release of the
Funding Opportunity Announcement (FOA).
• Develop and distribute executive authority model language and tools
to improve capabilities of health agency administrative leadership.
• Develop and distribute a fact sheet citing the current and relevant
information and resources on volunteer liability to be distributed both
in advance and during a public health emergency to state and local
health jurisdictions.
Recommendations for Further Investigation by
the Preparedness Community & Partner
Agencies /Associations
• Create and implement a cataloged registry of legislative and
executive order powers (with the Public Health Law Research
Center).
• In conjunction with the National Governors Association, develop and
implement an Administrative Preparedness Policy Academy pilot to
promote cooperation between agencies.
• Develop and implement cooperative contracting guidelines to bring
together states with similar needs to establish contracts with
suppliers.
• Recommend a set of common data elements for a single integrated
data entry system accessible at all levels of government.
• Develop a set of standardized procurement processes in conjunction
with the National Association of State Procurement Officials.
Managing Administrative Preparedness Burdens on State
and Local Health Departments
• Q&A
– Please enter your question in the chat box.
Managing Administrative Preparedness Burdens on State
and Local Health Departments
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