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Saturday, December 10, 2022

HHS Needs to Better Communicate Requirements for Personnel Reassignment During Public Health Emergencies

States have reported not having sufficient personnel to assist in public health emergencies under the Pandemic and All-Hazards Preparedness Reauthorization Act of 2013 (PAHPRA) which authorized the Department of Health and Human Services (HHS) to allow states and tribes to temporarily reassign personnel funded in whole or in part by HHS programs to aid in public health emergency response, according to a new Government Accountability Office audit report.

HHS provides funding to state, local and territorial entities to help them prepare for and respond to public health emergencies, such as influenza pandemics and other threats.

HSS’s Office of the Assistant Secretary for Preparedness and Response (ASPR) has primary federal responsibility for overseeing medical and public health preparedness and response and coordinating the reassignment of personnel in a public health emergency. ASPR has developed processes to review and approve states’ and tribes’ requests for personnel reassignment. Should ASPR receive a request for personnel reassignment, it would convene relevant officials from the HHS agencies and offices from which states were requesting reassignment, with the goal of the agencies and offices considering requests and ASPR communicating reassignment decisions within four days.

“However,” GAO reported, “ASPR’s efforts to communicate these processes to the HHS agencies and offices that administer programs eligible for personnel reassignment have been limited.”

GAO found the program officials—personnel responsible for day-to-day administration of programs eligible for reassignment—from two HHS agencies … that they were generally unaware of the reassignment authority, ASPR’s processes and time frames for reviewing and approving requests or the program officials’ expected role in approving requests.”

GAO said, ASPR officials said that the office did not conduct targeted outreach to HHS agencies and offices to inform them of its processes, requirements or expectations, noting that these entities should be aware of them through other channels, such as during the vetting of guidance on the use of the reassignment authority through HHS. However, officials from one agency said program officials are typically not directly involved in the vetting process.”

“Conducting outreach to HHS agencies and offices on ASPR’s reassignment requests, review processes and time frames would be consistent with federal internal control standards for information and communication, and would improve HHS agencies’ and offices’ awareness of expected roles, thereby preventing potential delays in decision making in the event of a public health emergency,” GAO stated.

Continuing, GAO said, “ASPR has assigned responsibility for reviewing after-action reports to HHS agencies and offices—an expectation program officials were also unaware of—and does not plan to conduct its own evaluations of the reports. HHS requires states and tribes that use the authority to submit after-action reports containing information on how the reassignment assisted their emergency response. In assigning report review responsibility to HHS agencies and offices, ASPR officials said the HHS agencies and offices will be better able to identify the effect of the reassignments on their programs and take corrective actions as needed.”

However, GAO determined that, “ASPR’s approach does not address the need to comprehensively assess the impact of reassignment on emergency response across HHS. Conducting its own evaluations of the after-action reports would be consistent with the federal internal control standard for monitoring, and would allow ASPR to determine whether the reassignment authority provides helpful resources for states’ public health emergency response, as well as assess the effect of the authority across all participating HHS agencies and offices.”

GAO said, “PAHPRA included a provision for GAO to examine the impact of the reassignment authority. However, the authority has not yet been used. Therefore, this report examines the processes HHS has in place to review states’ and tribes’ requests for temporary reassignment and evaluate the after-action reports states and tribes are to submit after they have used the authority.”

GAO recommended that a “HHS direct ASPR to conduct outreach to HHS agencies and offices to inform them of ASPR’s processes, expectations and requirements for the reassignment authority; and develop a plan to evaluate after-action reports to assess the authority’s impact on emergency response and medical surge.”

HHS agreed with both recommendations and provided information on how ASPR plans to implement them, GAO said.

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