By Karin Hicks, J.D.
OIG review of selected health care coalitions finds that expansion of membership to include ancillary member type entities did not necessarily fill gaps in preparedness or response.
The Office of Inspector General (OIG) reviewed a sample of health care coalitions (HCCs) and their corresponding hospital preparedness program (HPP) awardees. The results of the review are presented in this report to provide a glimpse into the progress and ongoing challenges of the organizations tasked with preparing for public health emergencies. The HCCs sampled were found to have expanded their membership to comply with new preparedness guidelines set forth in 2017. Despite achieving compliance with the new guidelines, the HCCs reported challenges associated with expansion of their coalitions. To aid in HCC’s preparations for a community emergency response, the OIG report provides four recommendations to the agency in charge of U.S. emergency preparedness, the HHS’ Office of the Assistant Secretary for Preparedness and Response (ASPR) (OIG Report, OEI-04-18-00800, April 2020).
Background. ASPR is the agency that is responsible for public-health aspects of U.S. preparedness, response, and recovery. In that role, ASPR oversees the HPP, which in turn funds HCCs through cooperative agreements with State, territorial, and metropolitan organizations. In 2017, the 2017–2022 Hospital Preparedness Program (HPP)—Public Health Emergency Preparedness (PHEP) Cooperative Agreement (2017 Cooperative Agreement) was implemented which required HPPs to fund the newly-conceived HCCs.
The HCCs were tasked with coordinating and incentivizing entities to work together to prepare for a whole community response. These coalitions are member-led and are composed of health and other response entities that work together in emergency situations. The 2017 Cooperative Agreement required that each HCC include four core entity types: (1) hospitals; (2) public health agencies; (3) emergency medical services; and (4) emergency management organizations. The Agreement also requires HCCs to diversify membership beyond the four core entity types. The HCCs are permitted to admit any other entity type as a non-core member.
OIG Review. The OIG conducted a thorough review of 20 HCCs and their corresponding HPP awardees. The HCCs were chosen from a pool of 476 HCCs at the time of data collection. The review involved interviews, surveys, and document examination from each HCC and HPP awardee from November 2018 to January 2019.
Findings. The OIG found that 19 of the 20 sampled HCCs expanded their membership in compliance with 2017 guidelines. Most of these HCCs report that the membership expansion was driven by the addition of non-core entity types. Further, these HCCs relate that their members take part in HCC activities that benefit whole community emergency preparedness.
Despite this positive growth, the OIG review also revealed that expansion presents challenges for the coalitions. The HCCs reported non-strategic expansion without regard to the community’s actual needs. That is, the HCCs admitted members without concern for how the new member would fit in the emergency preparedness plan. Further, many HCCs reported concentrating their limited resources on developmental activities for these new ancillary members which ultimately reduced available resources available for other HCC priorities. Finally, the sampled HCCs expressed concerns about their ability to continue to incentivize core members’ participation in HCC activities. For example, several HCCs describe the challenge of incentivizing participation when emergency medical providers must conduct HCC activities alongside their other professional priorities.
Recommendations. The OIG report provided recommendations to ASPR. Specifically, the OIG states that ASPR should (1) provide guidance for HCCs’ membership to ensure comprehensive coverage of their communities’ gaps in preparedness and response; (2) continue to work with CMS to help health care entities comply with the CMS emergency preparedness Conditions of Participation; (3) identify new ways to incentivize core members’ participation; (4) clarify the flexibility available in meeting requirements. In a response letter to the OIG, ASPR concurred with all four recommendations.
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