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

ASPR: Resilient People. Healthy Communities. A Nation Prepared.

Administrative Preparedness—The Initiative

Administrative preparedness must be a core capability of the nation’s preparedness system at all levels of government.

Concept Drivers

Non-Stafford Act responses such as 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

Concept Drivers

Non-Stafford Act responses such as 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

Guiding Principles

Upfront investments can help 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

Guiding Principles

Upfront investments can help 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.

VISABILITY/ACCOUNTABILITY

TIME TO DISBURSEFUNDS

Congress

HHS

States

Locals

Challenges Exist Across the Funding Distribution Channel

HHS Agency

grants/

contracts

EXOP

Operational Barriers

Potential Bottlenecks

HHS is embarking on efforts to address internal barriers grants/

contracts

grants/

contracts

ASPR: Resilient People. Healthy Communities. A Nation Prepared.

Administrative Preparedness—Defined

GOALS

1. Expedite funding during a response

2. Ensure the adequacy of funding for response activities

3. Reduce the administrative burden of the response

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.

ASPR: Resilient People. Healthy Communities. A Nation Prepared.

• Created a partnership among ASPR, CDC, ASTHO and NACCHO

• Leveraged grant programs

• Funded projects with ASTHO and NACCHO

Federal Activity

ASPR: Resilient People. Healthy Communities. A Nation Prepared.

HHS Departmental Initiatives to Improve Efficiency

• Developed new accounting structures to improve financial tracking of obligations for funds

• Created Department-wide guidance on managing intra-departmental 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.

• 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

Goals

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 79%• Use of Credit cards, field vouchers and/or cash 24%• Limited Emergency Hiring Authorities 12%

• Most common Barrier to Activating Expedited Administrative Processes

• Requires an official declaration to invoke 79%• Budget restrictions (authorities to hire, spend, etc.) 18%

• 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

• Use data to drive state and local public health technical assistance – “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

...moving forward in 2012-2013

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

• 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 “un-level” 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

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Managing Administrative Preparedness Burdens on State and Local Health Departments

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