by James C. Sherlock
I spent a lot of time at the national level working in the National Incident Management System (NIMS) on policy, training, exercises, communications and after-action analysis of operations including Katrina. I offer this essay as a primer with a goal to bolster citizens’ faith in that system as it relates to COVID-19. The foundations are in place.
The first principle to remember is that the city or county manager, mayor or county executive does not work for the Governor, and the Governor does not work for the President, so emergency response is based on cooperation, coordination, and common frameworks for action, not formal command and control.
The National Response Plan (NRP) is an application of the National Incident Management System (NIMS). The NIMS provides the doctrine, concepts, principles, terminology, and organizational processes needed for incident management and coordination at all levels. The NRP, using the framework of the NIMS, provides the coordinating structure and mechanisms for national-level policy and operational direction for Federal support to State, local, and tribal incident managers, federal-to-federal support and for exercising direct federal authorities and responsibilities as appropriate under the law.
The National Pandemic Flu Strategy[1], the National Strategy Implementation Plan[2] and the CMS Pandemic Influenza Operations and Response Plan[3] are active documents actively pursued.
There are thousands of professionals at the federal level for whom NRP, NIMS, and the pandemic flu documents are bibles. State and local government Departments of Health and providers, as you might expect, vary somewhat as to their own preparedness but share those frameworks. First responders, in my experience, know the NIMS like the backs of their hands.
States are funded by both the Federal Emergency Management Agency (FEMA) and the Centers for Disease Control and Prevention (CDC) every year to support emergency response training. Each of those agencies offers extensive online and in-residence training resources.
The Centers for Medicare and Medicaid Services (CMS) has published an Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers regulation that outlines four core elements which are applicable to all 17 provider types, with a degree of variation based on inpatient versus outpatient, long-term care versus non long-term care.
Four Core Elements of Emergency Preparedness (for Medicare and Medicaid Providers)[4]:
Risk Assessment and Emergency Planning (Include but not limited to):
- Hazards likely in geographic area
- Care-related emergencies
- Equipment and Power failures
- Interruption in Communications, including cyber attacks
- Loss of all/portion of facility
- Loss of all/portion of supplies
- Plan is to be reviewed and updated at least annually
Communication Plan
- Complies with Federal and State laws
- System to Contact Staff, including patients’ physicians, other necessary persons
- Well-coordinated within the facility, across health care providers, and with state and local public health departments and emergency management agencies.
Policies and Procedures
- Complies with Federal and State laws
Training and Testing
- Complies with Federal and State laws
- Maintain and at a minimum update annually
The inspections that certify Medicare providers check on the compliance of each with this regulation. The precautions that each facility and provider will make in the case of COVID-19 such as triage, isolation and treatment should be already in those plans and the associated training.
The private sector has a big role to play in keeping the providers, pharmacies and grocery stores supplied. My experience with the Katrina response was that they were superb in their roles without being asked.
The Food and Drug Administration (FDA) and the pharmaceutical and testing industries seem both proactive and fully engaged.
We can be assured that the current Commonwealth emergency response plans and the associated exercise and training regimen related to pandemic response are compliant with federal standards. None of us is in a position to compare Virginia preparedness qualitatively to that of other states or to assess city and county health department preparedness within the state. We will find that out in the event that the plans are executed.
All in all, though, citizens can be assured that the framework for an organized and effective response to COVID-19 are in place at all levels of government. The CDC and NIH are the best in the world at what they do. How the rest of the system works in operation will depend on the skills of our federal, state and local leaders and their health departments.
The citizen’s role is to comply in his/her individual activities and readiness with the guidelines and directives of the CDC, NIH, the FDA, the VDH and our local health authorities.
James C. Sherlock, a Virginia Beach resident, is a retired Navy Captain and a certified enterprise architect. As a private citizen, he has researched and written about the business of healthcare in Virginia.
https://www.cdc.gov/flu/pandemic-resources/pdf/pandemic-influenza-strategy-2005.pdf
[2] https://www.cdc.gov/flu/pandemic-resources/pdf/pandemic-influenza-implementation.pdf
[3] https://www.cms.gov/About-CMS/Agency-Information/H1N1/downloads/pandemicplan.pdf
[4] https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Core-EP-Rule-Elements
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