COVID-19 Vaccine Administration Preparedness

On September 16, the CDC released the COVID-19 Vaccination Program Interim Playbook for Jurisdiction Operations. This document lays out some fairly realistic expectations of jurisdictions (mostly states) in their distribution, administration, and tracking of COVID-19 vaccinations. That said, even though there continue to be many unknowns about the vaccines to be utilized, dosages, timetable of availability, and how and where vaccines will be delivered to states, there are reasonable assumptions that could be made and high probability strategies identified, which the CDC failed to do. Instead, as is a hallmark of many poor managers, they provided a punch list of considerably detailed demands but not the very essential information and parameters needed to support good planning. Information is everything.

Garbage in/garbage out is a pretty simple concept of utilizing poor or lacking information to inform a process, which will result in similar outputs. After reviewing New York State’s COVID-19 Vaccination Plan, that concept is fully demonstrated. Most sections of New York State’s plan are vague at best, saying what they will do but not how they will do it. They do identify some roles and responsibilities, but without delineating the boundaries between functionaries. For example: they will utilize pharmacies, local health departments, and state-run facilities, among others, to accomplish public vaccination. This is a solid and expected strategy, but the responsibilities for each are poorly defined for their own operations, much less how they will or won’t work together. Many concepts in the plan are vague at best, and even lacking more defined federal guidance, should have better detail. A big component of vaccination will be community delivery through local health departments, yet this is barely acknowledged. I would have expected this plan to provide guidance and outline preparedness requirements for local health departments, even if they were communicated separately. I acknowledge this is intended to be a strategic level plan, but it doesn’t seem to even consistently provide that measure of detail. I’m left with a lot of questions. And while it may be petty, the document itself is poorly written and published – I expect better from state government.

I’ve not looked at the plans of other states, but if this is indicative of the general state of things, the term ‘shit show’ is the phrase that comes to mind. While we will no doubt improve, there is a long way to go and I think jurisdictions will find themselves in a bind, being poorly prepared when they receive notice of an imminent delivery of vaccines with no detailed plan or assigned resources to get the job done. If anything, we have had plenty of time to prepare for vaccination efforts. There are clearly failures at all levels. While communication between and among federal, state, and local jurisdictions has certainly taken place beyond these documents, the standards and measures need to be more apparent.

We need to do better and be better. Reflecting a bit on the piece I wrote yesterday, we need to be thorough and imaginative in our preparedness efforts without excluding possibilities. Local jurisdictions must be prepared to support vaccinations in their communities. As I’ve written before, most health departments simply don’t have the capacity to do this. Jurisdictions need to engage with their health departments for the best guidance possible and work from that. An 80% solution now is better than a 20% solution later. As with any disaster, local communities are the first stakeholder and the last.

What are you seeing from your states? What do you think is missing in our overall efforts?

© 2020 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Speculation on the Upcoming Role of Local Governments in Pandemic Recovery

Last night I remotely facilitated a session with the senior leadership of a mid-sized city discussing multi-agency coordination, incident management, and other concepts, mostly within the context of the coronavirus pandemic.  We spoke at great lengths about the role of local government in this, especially when they do not have their own health department, and what expectations there might be of them in the future.  In this discussion I had the realization of a potential scenario that seems to hold a fair amount of probability, and it’s one that is grounded in prior practice.

A bit of a disclaimer up front.  My regular readers know that I usually avoid speculation.  In the wrong context, speculation can cause undue stress or unnecessary effort.  Obviously, that is not my goal.  My goal is, as is typical of most of my articles, to promote thought and discussion on preparedness activities which are grounded in reality.  As I’ve said to people many times over the past several weeks, it’s not too late to prepare.  There are still plenty of things that we need to be preparing for in the midst of our response, including contingency plans for other potential hazards, and obviously continued operational needs.  The best emergency managers think ahead.  What I’m writing is not a call to action, but rather a call to thought. 

When it comes to vaccination (once a vaccine is developed), it’s apparent that everyone will need to be vaccinated.  While there are some factors which will force us to deploy vaccines in phases, including the supply of vaccine and the need to provide for fragile and critical populations first, there will eventually come a time when the population at-large will need to be vaccinated.  Obviously, our public health system is not equipped to administer inoculations for everyone in every jurisdiction in a timely fashion.  As such, there will be considerable reliance on local governments and advanced EMS providers, among others, to make this happen. 

First off, addressing the use of advanced EMS providers – this is not without precedent.  Advanced EMTs and paramedics have been used for a while now to support public health in mass inoculation needs, which have included H1N1, Hepatitis A outbreaks, and other viruses.  I expect that we will see these personnel used again to support the eventual vaccination of the global population against Coronavirus.  Because of the sheer volume needed, it is probable that we will see other medical practitioners likewise engaged.  When the time comes, state health departments and state EMS agencies will need to develop or update (if they have them already) protocols and just-in-time training for personnel on the proper administration of the vaccine.  Agreements in regard to paid third-party EMS service providers will also need to be addressed.  Overall, EMS will be a significant and necessary augmentation of our public health system in this regard. 

So what’s the role of local government that I expect?  Most public health outbreaks we deal with are fairly localized, allowing public health officials to establish and manage vaccination points of distribution where they are needed.  In a ‘typical’ outbreak, they can mobilize the resources needed, supported by state health departments and mutual aid from other public health offices.  The activities for these points of distribution include the development of protocol and record keeping standards and mechanism, identifying the population, securing suitable facilities, equipping those facilities (tables, chairs, internet, privacy screens, etc.), notifying the public, coordinating with local officials for control of traffic and movement of people, delivery and administration of the vaccine, securing of sharps and biological waste, and clean up; among other things.  In the scope of the coronavirus outbreak our public health offices doesn’t have the resources to do all this for every jurisdiction.  I suspect that along with providing the serum and supplies to administer it, public health will only be able to establish standards and provide guidance, but I don’t think it’s unreasonable to expect that jurisdictions will be asked to provide significant support in the non-clinical aspects of setting up and managing these points of distribution. 

What does this mean for local governments?  As I’m not a government official nor do I have an ability to definitively see the future, I certainly would not advise local governments to engage in any detailed efforts now to prepare for this scenario unless they have been advised by a public health entity to do so.  That said, it may be wise to pull together some stakeholders and at least outline a framework for how this can be done.  I’m confident that at least some of what is identified will be of use in the future of this pandemic.  Some jurisdictions may have already developed plans for points of distribution, which will be a good reference, but will likely be found to have inadequacies given current information on planning assumptions, the increased role of local governments I predict, and sheer numbers to be vaccinated. 

Who else has considered this future need?  I’m interested in hearing from others about their thoughts on these possibilities. 

Be smart, stay safe, stay healthy, and make a difference. 

© 2020 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

Disaster Aid Approved for Houses of Worship

Earlier this year, FEMA expanded their Public Assistance program to include houses of worship.  As the FEMA news release linked here states, the Stafford Act allows FEMA to provide Public Assistance (PA) to certain private not for profit organizations to repair or replace facilities damaged or destroyed by a major disaster.  In a move that seems to underscore FEMA’s change in policy, the President signed a bill into law a few days ago making this policy decision permanent.  Both the policy and the bill back-dated impacts to include Hurricane Harvey.

This is a decision that I’m honestly torn on.  On one hand, houses of worship serve as community centers, shelters, and points of distribution in many communities.  Some (but not all) provide critical services for their communities during disasters.  Aside from the spiritual aspect, these are organizations that communities turn to in time of need.  In fact, there exist a number of faith-based organizations that support disaster response and recovery that do incredible work.  Faith-based organizations are a critical partner in communities, and across the nation and the world.  On the other hand, I’m not certain about the government’s responsibility to fund the rebuilding of houses of worship – most especially if they do not serve the purpose of an approved shelter, point of distribution, or other sanctioned disaster-related activity in a community’s disaster plan.

FEMA’s PA guidelines can be very stringent.  The reason for this is to ensure responsible expenditure of taxpayer dollars in helping communities to recover from disaster.  In work as a state employee and as a consultant I’ve sat in meetings with FEMA in the aftermath of disasters working to ensure that eligible applicants were submitting the appropriate paperwork for eligible projects and receiving everything afforded to them under FEMA policy and the Stafford Act.  This process is bureaucratic and, at times, contentious.   The burden of proof is on the applicant to prove that they are, in fact, eligible to receive recovery assistance, and each category of projects has very specific guidelines.

Given this, to ensure fair application of tax payer dollars, I expect to see guidelines in FEMA’s PA guidebook update that require certain conditions to be met for houses of worship to be eligible to receive PA assistance after a disaster.  These would include:

  • Being part of the community’s emergency operations plan for key activities such as sheltering, points of distribution, etc.
    • As with any facility identified for these key activities, I believe they should embrace practices of resilience. That includes having their own emergency operations and business continuity plans as well as a documented history of proactive disaster mitigation projects for their properties (these don’t have to be complex or expensive.  Generators, sump pumps, and preventative landscaping are reasonably simple and high impact)
  • Practices of non-discrimination, especially during times of disaster, to include providing for people of all faiths
  • The PA policy itself should not discriminate against any particular religion

I’m interested in hearing your thoughts on this topic.

© 2018 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC SM