The 2019 Hospital Preparedness Program (HPP) Funding Opportunity Announcement (FOA) revealed several changes that will certainly have an impact on how healthcare coalitions and state departments of health operate. In addition to the operational impacts, some funding stream impacts may also be seen such, as fiduciary agencies moving to, and in in some cases away from, hospital associations or coalitions. Some of the noteworthy changes are:
Designate 1 Full Time Employee per coalition
The one Full Time Employee (FTE) per coalition rule is quite an interesting one. This rule not only requires the equivalent of 1 FTE, but the position must include a combination of program management and medical direction. The FOA also allows for that FTE allotment to be a documented charitable donation from a healthcare organization in lieu of funding the position out of the grant funding. While I do believe there will be instances of charitable medical direction, the funding of a full-time program manager will be necessary with the additional requirements included in this FOA. As states are completing the FOA process, we have heard of a few different ways that this requirement will be met. Some states which have smaller grant allocations are consolidating coalitions in order to reduce the number of FTEs that will need to be funded. Other states with well-established programs who already have dedicated program managers in each coalition are simply adding a single medical director that will be shared among all the coalitions. In addition to these staffing number changes, we are also seeing changes to who will staff these positions in response to the direct cost cap.
Recipient-level direct cost cap
The Recipient-level direct cost cap in this FOA starts at 18% of the total grant allotment and reduces annually to 15% in year five. The direct-level costs consist of the salaries and fringe costs (benefits, vacation, etc.) associated with an employee of the agency receiving the award. As previously stated, some states who have recipient employed program managers, are consolidating their coalitions in order to get their direct costs in line with the cap. In other states where the program managers were recipient employed, we have heard of outsourcing of those positions via state hospital associations or private contractors. Both actions will help control the recipient-level direct costs. There are some states who have opted to retain their current recipient-level staffed model and hope to receive a direct cost cap waiver.
Identification and reporting of Pre-Event, Post-Event and Special-Event Essential Elements of Information (EEI)
The introduction of the requirement to identify and report on Pre-Event, Post-Event and Special-Event Essential Elements of Information (EEI) sounds familiar doesn’t it? The recently removed mandatory collection of HAvBED data would be an EEI ASPR might have a desire for you to collect. Unlike HAvBED, which required the use of the EDXL-HAV data protocol, there has been no common data format identified as part of the EEI requirement. This will certainly cause issue as we move forward with the collection and sharing of these data elements. The collection during the early years of this requirement will likely send us back to the sending, receiving and manual aggregation of excel spreadsheets. One would hope that the next FOA includes a requirement that all systems funded by federal funds MUST be fully interoperable using EDXL standards thus removing any issue with proprietary data sets. This would be the first step in bring healthcare emergency and disaster response on par with the requirements seen in public safety. The seamless collection and sharing of these EEIs between systems, commercial or homegrown, will be the key to making this data useable and truly have an impact of disaster response.
In conclusion, even though individual hospitals are no longer getting direct funding, I would ensure that you are well versed in the new FOA and its impact to your facilities. The value of participating in coalition activity to your organizations will certainly be impacted by changes made within the coalitions and the state policies regarding funding allocation. Only time will tell how these changes truly impact healthcare preparedness in the country.