First off, I certainly must acknowledge that it’s been a while since I’ve posted. I’m fortunate to have been and continue to be extremely busy managing and growing my firm, with a ton of great clients and projects around the country. I appreciate those who have reached out in the past couple of months expressing how much they have missed my blog posts. Fear not! There is plenty more to come.

I felt this post was rather timely to get out as I just heard about The Emergency Management Support Act (HR 3626), which amends the Post-Katrina Emergency Management Reform Act (PKEMRA) of 2006. This bill seeks to, among other items, set training requirements for local emergency managers. The bill was just introduced yesterday and has been referred to the House Committee on Transportation and Infrastructure.

As of the authoring of this post, the full language of the bill is not yet available on Congress.gov, though a summary is available here. In the summary, there are three components identified:

1. Direct States, through the Emergency Management Performance Grant (EMPG), to require local emergency management directors to complete emergency management training within one year after the enactment of the bill
2. Require local emergency management directors to complete recurrent training with certifications to be submitted to FEMA annually
3. Require FEMA to report to Congress on compliance with this Act

My commentary:

Superficially, this proposal makes sense. We want emergency managers to be trained, right? Before I even get into the three components, I want to look at the premise of the bill.

The summary points to the 2017 Hurricane Season FEMA After-Action Report (AAR) as the driving force behind the bill, citing an actually rather obscure comment on the twelfth page of the report that states “pre-disaster training and exercises proved to be critical in Florida’s ability to efficiently execute mutual aid agreements”. This quote is pretty isolated within the report, with the context of that particular section being gaps in Threat and Hazard Identification and Risk Assessment (THIRA) data. In fact, none of the recommendations for that section of the AAR mention anything about training, though you could stretch to a possible connection of an obscure mention of the creation of ‘preparedness products’. Second, the AAR quote’s specific mention of the execution of mutual aid agreements may or may not be a very niche topic, depending on how it’s being defined. Unfortunately, there is nothing in the AAR that provides any citation or context to this line. It makes me wonder why this one line is so specifically being referenced as it clearly was not a major point of the AAR.

Now, let’s get into the three components. For the first, requiring states to require local emergency management directors to complete emergency management training. OK, but on what topics? To what level of proficiency? There are no specifics provided. A multitude of state emergency management offices have created training requirements for local emergency managers which range from a single training course to several. Many are even tied to local EMPG allocations. It’s certainly an effective practice, but I still question this bill establishing an ill-defined requirement.

The second component requires recurrent training, with certifications to be submitted to FEMA annually. This little statement is loaded with landmines. Again, I must ask the question – recurrent training on what topics? My second comment is the use of the term ‘certifications’. I have an entire post on the significant difference between certificate and certification. Is this second component calling now for not just training but a certification? That’s a very different thing. And most certifications do not require annual refresher training, though they do often require some kind of continuing education. My last comment on this component is about the submission of said ‘certifications’ to FEMA annually. This is not something FEMA is set up to receive and manage. While they have a learning management system or content management system that works behind the scenes of their independent study program and also tracks completions of other courses delivered by their Emergency Management Institute (and other partner programs), they do not track third party training for emergency managers across the nation. It could be that the ‘certification’ they refer to here is an attestation by state emergency management offices that local emergency management directors are meeting training requirements. If such is the case, this would certainly be easier and could be accomplished within state EMPG reporting back to FEMA.

As with most legislation in emergency management (and I imagine other technical fields), this is ill informed and ill constructed (though I say this only from seeing the summary and not the bill itself). While the intentions are good, this could cause states to have to restructure their established training requirements for local emergency management directors, and, depending on the mechanism for receiving and managing this information, could put an unnecessary administrative burden on FEMA. I really do wish lawmakers would rely more on subject matter experts to identify needs for and crafting of legislation instead of the good idea fairy.

Thanks, as always, for reading.

TR

Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®