|Two things - the need to gain some concept-of-operations understanding of optimal conditions for CMG implementation, and a good deal of puzzlement as to the source of generalized inertia at the local level - have led me, reluctantly although not quite kicking and screaming, to conduct my own mini-review and investigation of the institutional structures behind the US government's pandemic plans, and the bigger picture framework of where panflu stands in the grand strategic workings of the USG.
Boy, I have to tell you I had no idea what I was letting myself in for! In the past week, I have gone through not less than a couple of thousand pages of documents, some in great detail, others skimmed at whatever speed I could drag my over-stuffed brain along without totally losing it, and I believe I have barely scratched the surface!
I need to make a disclaimer right up front, that this is only my very preliminary understanding, based solely on what I can find on the internet. Having been unsuccessful in securing help from anyone, I'm sure somewhere down the road I'm going to find my writing to be full of errors and my opinions misguided. That said, since when have you known me to let ignorance stop me from making observations anyhow, right? LOL!
The other thing that I want to make clear before I start, is that there is no hidden agenda or outcome in my writing this, except as an attempt for all of us to explore some pretty important issues, many of which probably have no clear answers or solutions, but nevertheless still need to be brought to the public's attention if only for our education.
In addition, I'm mindful of the absolute need on this forum to steer clear of partisan politics, so if in the process of this exploration I/we come across issues that inevitably will have political undertones, I would like to suggest that it is enough that we go no further than just noting that these issues exist, and focus our attention instead on the implications for pandemic preparedness and planning, and how we might circumvent problems that we manage to identify.
This first diary is going to be entirely descriptive, my intention being to provide some understanding of the historical background behind the Federal disasters response and assistance to State and local entities, and how evolving expectations have put us at a crucial turning point where the old relationships are no longer sufficient but new ones have yet to take root. Part 2 will explore more fully the implications for current policy, with specific examples and hopefully leading to some lessons to take away to be used as appropriate.
To begin at the beginning, we have to take a look at the founding of the country.
"The powers delegated by the proposed Constitution to the federal government, are few and defined. Those which are to remain in the State governments are numerous and indefinite." The Federalist No. 45.As we have noted previously on this forum, preparing for and responding to disasters have always been not just the responsibility but the domain of State and local government, the Feds having no right to intervene even to assist a State except at the request of the governor. Over the course of the 20th century, the federal government became increasingly involved in disaster responses as requested by states, so much so that it has become more-or-less the expectation that in any large scale disaster, some federal assistance will be forthcoming. Nevertheless, the principle that State and local resources need to be utilized first before federal assistance can be requested was reiterated firmly by various administrations, notably Truman in 1952 and Nixon in 73.
The main legislation providing for federal disaster response is the Stafford Act, which establishes a mechanism for state governors to request assistance from the Feds when they are overwhelmed. It authorizes the President to declare disasters/emergencies and to appoint a Federal Coordinating Officer (FCO) who is responsible for coordinating the delivery of resources from other agencies and entities and generally to administer disaster relief, as requested by the State.
The important points to note here are that:
- the states have to identify what they need and make specific requests
- the FCO (and FEMA, after it was formed in 1978) is not the operational provider of federal support. Rather FEMA coordinates the response and resources provided by other federal agencies.
- such aid is delivered to the State who is then responsible for distributing it locally to those in need. There is no mechanism for FEMA to directly administer aid on the ground.
This 'pull' system, ie States drawing resources from the feds as needed, works for most situations when state and local governments are sufficiently functional, but broke down completely in the case of Katrina, when there was basically no functioning government on the ground for this mechanism to work.
Even before Katrina, however, after 911, there was increasing recognition that in more severe or catastrophic scenarios there is a need for the feds to take a more proactive stance. The Homeland Security Act of 2002 established the Department of Homeland Security, and the day before DHS opened for business, President Bush issued Homeland Security Presidential Directive (HSPD) 5, which, among other things, tasked the secretary of DHS to develop
- a National Response Plan (NRP) - to "integrate Federal Government domestic prevention, preparedness, response, and recovery plans into one all-discipline, all-hazards plan.", and
- a National Incident Management System (NIMS) - to "provide a consistent nationwide approach for Federal, State, and local governments to work effectively and efficiently together" and to "provide for interoperability and compatibility among Federal, State, and local capabilities,".
The NRP was written and adopted in December 2004, although at 400+ pages, with 150+ acronyms, and written in the worst of 'bureaucrat-ese', it is so convoluted as to be almost impenetrable in some places. There were major flaws which became painfully clear after Katrina. It has been under review since, with the most recent draft version (somewhat mysteriously called National response 'framework' instead of plan) being apparently leaked earlier this month. Nevertheless, it IS in force, and there are some basic components and considerations that are relevant to pandemic planning:
- The NRP is the overarching 'mother of all plans', and the primary mechanism for coordination of federal responses, including in a pandemic. Thus, the NSPI (National stategy for pandemic influenza) Implementation Plan is more-or-less an extension of the NRP in the context of a pandemic.
- According to the NRP, the Secretary of DHS is responsible for coordination of the overall federal disaster response.
- The NRP defines 15 different Emergency Support Functions (ESP) to be headed by different agencies. ESF#8 is the main one we are concerned with, where the HHS is designated the lead agency for delivering public health and medical responses in an emergency.
- The NRP is triggered when there is a 'Incident of National Significance' - which according to the NSPI will immediately be declared by the Secy of DHS at WHO phase 4. This declaration, among other things, triggers the various ESFs which will become operational according to need.
- In addition, the NRP also contains a series of 'Incident Annexes' which address incidents that require specialized application of the NRP. Under 'Biological Incident Annex' which contains pandemic influenza as one scenario, the HHS is designated the coordinating agency, but DHS still retains the overall coordinating role under the overarching NRP structure.
- There is also provision for catastrophic scenarios in the 'Catastrophic Incident Annex' (NRP-CIA) which provides a mechanism for an 'accelerated, proactive national response to a catastrophic incident', basically switching to a 'forward-leaning' 'push' instead of 'pull' system of operations.
- Unfortunately, even though various parts of the NRP was operational during Katrina, the NRP-CIA portion had not been operationalized, so the Katrina response was basically still based on the old 'pull' approach.
Finally, let's turn to the NIMS, and note a few points here:
- One big issue that the NIMS seeks to address is the lack of interoperability between different parts of the federal government as well as state and local responders, the consequence of which was painfully demonstrated in the loss of 300+ firemen in the World Trade Center due to incompatible communication systems.
- It has as its core the Incident Command System (ICS) which describes a structure that is scalable and can be adopted by all federal, local, and non-government entities involved in disaster response.
- Starting in 2005, all parts of the US government are obliged to make their operational plans gradually NIMS compliant as part of the conditions attached to funding.
- The initial phases involved self-certification, but starting 2007 and even more so in 2008, they are moving into metrics-based assessments.
- FEMA offers various training programs which are required as part of compliance.
Having gone through all that, we are now ready to look at how pandemic plans at the national, state, and local level relate to each other and to the NRP and NIMS, and the implications arising from these relationships. To whet your appetite for part 2, I'm going to put up this chart from the CDC operational plans. I can't count how many charts I've looked at in the past few days, but I believe this particular one, although still not completely representative of the whole picture (nothing is, it's too complicated!) manages to capture the relationships brilliantly! I will explain and discuss this in part 2, particularly in relation to the challenges to implementation, and lessons to be learnt.
After writing this diary, I found a draft updated version of the National Response Plan, now re-named National Response Framework. There are major changes, so some of the points that I made earlier may no longer be valid. Please see part 2 here http://www.newfluwik...
Other parts in this series are here:
Part II : The 'Born-Again' National Response Framework.
Part III : Why 'All Hazards'?.
Part IV : Is the US Government in danger of being swamped by a "PLANdemic"?.
Part V : Pandemic Preparedness 101 : Who IS In Charge?.
Part VI : The Missing Piece.