My original post on this bill generated some great discussion on Twitter and LinkedIn.
The actual bill text was finally posted on Congress’ bill tracking website.
My observations and comments:
- The short title of the bill suggests that the bill can be cited as the ‘EMS Act’.
Ugh. Really? Thanks Rep. Thompson for continuing to perpetuate confusion related to emergency management.
2. The bill provides, as an amendment to PKEMRA, a definition of local emergency management director: ‘An official designated at the local level to coordinate local disaster response, emergency planning, emergency preparedness, disaster recovery, disaster mitigation, and related activities on a full-time or part-time basis.’
While this is a necessary definition to include in the bill, I think that since the bill is focused on EMPG-funded local emergency management programs, it should specify those are the only local EM directors this applies to. Depending on how states administer and distribute EMPG funds locally, there are some states with many local emergency management programs that are not EMPG funded.
3. The bill provides, as an amendment to PKEMRA, a condition for eligibility of EMPG grant funds, that states ‘require local emergency management directors to successfully complete Federal Emergency Management Agency provided baseline emergency management training developed in accordance with the National Incident Management System not later than 1 year after the date of enactment of this subsection and recurrently at an interval determined by the Administrator to strengthen local emergency management capacity.’
So as mentioned in my original post, there is still no actual identification of what topics are to be addressed in the training. While it states ‘in accordance with NIMS’, that’s still not at all specific. I suppose to one extent, it’s good that politicians aren’t assuming they know what ‘baseline emergency management training’ looks like, and it also allows this would-be provision of an amended PKEMRA some longevity and flexibility to address changing needs. On the other hand, we still don’t know what the actual intent of this training is. Of course, we want emergency managers to be trained to a baseline. That’s certainly a good thing. Though as mentioned in my original post, many states have developed their own local emergency manager training programs. I assume that most of these state-developed training programs meet identified needs within the state, including specific state emergency management processes and operations which would not be included in any FEMA-developed training. Will states be allowed to substitute this training for the ‘FEMA-provided’ training indicated in this provision? If not, this will be an additional training requirement, which superficially isn’t a bad thing, but it is one more thing that emergency managers need to do – and not just once, but annually.
The provision doesn’t state the delivery modality of the training, so I suppose FEMA has the option of this training being independent study, in-person, live remote, or any hybridization of the above. While independent study is certainly the most convenient for everyone, we all know that it has limitations on learning taxonomies. That said, the language states ‘FEMA-provided’, not FEMA-conducted. Since other language in the bill indicates that States are to report to FEMA on compliance, it seems the intent is to have FEMA develop said training for state delivery (i.e. G courses). I suppose this can provide an opportunity for state training officers to amend the FEMA-developed course to include state-specific information without taking away from the material FEMA developed.
But with all that, what of other training initiatives out there, such as the FEMA Basic Academy? While there is no federally-driven grant requirement for the Basic Academy, the materials could be included within this. But with that, while I continue being a big advocate for training and see the value of the Basic Academy, the number of courses and duration of training could be a barrier – especially for part-time directors. And with the refresher requirement, there obviously can’t be an expectation for people to re-take the academy, so a separate refresher training would have to be developed and delivered.
As a former state training officer, there are a lot of possibilities, but also a lot of logistical issues to be addressed.
4. The bill does provide language to address gaps in compliance, with states being required to identify barriers of all local emergency management directors completing training and an approach to overcome those barriers with a timeline for compliance.
I really do appreciate accountability in laws and grants, and while this provision is a good start, there is no provision for a penalty, so it really has no teeth to it. To me, this seems very much like the NIMS training requirements that came about following HSPD-5, which initially had a lot of complication in tracking but devolved into a simple statement of compliance in EMPG reporting.
As mentioned, there was a lot of great discussion prompted by my last post. Most people agreed there were a lot of concerns absent seeing the bill itself. Now that we have, it still doesn’t really address most of those questions and concerns. There were some comments on the original post that at least this works to establish some kind of standard. I can only partially agree with that sentiment. The bill itself doesn’t define a standard at all. Let us be honest that this is not a standard for all emergency managers – it’s only for local emergency management directors funded by EMPG. Yes, that’s an important group, but it should not be confused with being a standard for the profession. Also, training should be based on an established standard; and generally speaking, training is not itself a standard.
Continued Thoughts on Training (for those who are interested)
Philosophically, there is a great opportunity here to develop a comprehensive baseline training course or program that includes elements of a lot of existing training as well as some new content, but that training, at least as developed by FEMA, can only address federal processes and fundamentals of emergency management from that perspective – it can’t speak to the unique approaches and nuances of each state, which means there is a critical component that would be missing from this training if the intent is for it to be truly ‘baseline’. I’d hope that whatever is developed provides room for states to incorporate locally specific information to make this training more worthwhile and valuable.
Will this be valuable, or will this become ‘one more thing’ for emergency managers to do? Will this be some pencil-whipped compliance item? While it leaves FEMA (and hopefully the emergency management community at large) to identifying what that standard will be (i.e. the content of the training), I expect that much of the EM community will want less instead of more. Again, as a former state training officer, I heard people complain every day about the duration of training and wanting to cut corners. I expect many current EMs will express this to be a waste of time for themselves, likely being shortsighted about the potential value to new personnel. That said, I’ll also suggest that if this is truly for local emergency management directors, these individuals should have the ‘baseline’ knowledge BEFORE being hired to the position of director – though we know that many, especially those who are current or retired fire and police who are often given these jobs actually know very little about emergency management beyond response.
The most comprehensive standard we have in emergency management is NFPA 1660, though I don’t feel that this, alone, is enough to provide the ‘baseline’ of training that local emergency management directors need as there are several other essential content areas, many covered by existing training. Also, while NFPA 1660 is a solid standard for emergency management and continuity programs, it doesn’t prescribe means and methods for the activities identified therein. That’s not a gap… that’s actually how standards should be developed which allows for innovation. So in figuring out what this ‘baseline’ training is to be, we also need to determine what the desired taxonomy is – what do we want them to know, to what extent, and what do we expect them to be able to do with that knowledge? (see my series of ICS Training Sucks articles for more discussion on Bloom’s Taxonomy and learning outcomes). If we want them to know how to do things, we need to provide implementation guidance for each area of NFPA 1660. Some of that we have, such as CPG 101 for emergency planning.
This is a rabbit I can chase for a long time down a lot of holes. If this bill passes, I’d love to be at the table with folks at EMI to help develop this.
© 2023 Timothy Riecker, CEDP