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HSPD21: Countermeasure Distribution

November 13, 2007

pillsThis post is one in a series examining the recently-released Homeland Security Presidential Directive 21: Public Health and Medical Preparedness. Previous posts can be found here: Initial Reactions, Biosurveillance.

Countermeasure distribution is something we’ve written about before here. The idea behind countermeasure distribution is that it’s basically the health “response.” After an event (be it natural or man-made) that adversely affects the health of a large population, either through infectious agent or or a similiarly unhealthy agent, it is the job of health officials to distribute medications of members of the affected populace, if that’s appropriate. Basically, if anthrax is spread over a city, it is the job of the city to give those impacted antibiotics such as Cipro or doxycycline; in a pandemic influenza scenario, those same folks would be tasked with giving out an anti-viral medications or flu shots. This seems to be the thing most exercised by Health Departments across the country, whether they be on the state, county or local level. I have a theory as to why that is – basically, that’s where the money is. There has to be some oversight for bioterrorism planning funds given to municipalities, and my belief is that continued funding is contingent on passing some sort of countermeasure distribution plan review.

This part of the directive is, as John Bowen notes, where I consider this plan to be completely undo-able. This section is full of deadlines dependent on things like:

… [P]rovide minimum operational plans…

…[U]tilizes current cooperative programs and engages Federal, State, local government, and private sector entities…

…[A]ssist State, local governments, and regional entities in tailoring templates to fit differing geographic sizes, population densities, and demographics, and other unique or specific local needs

And here’s the kicker:

[W]ithin 270 days after the date of this directive, (i) publish an initial template or templates meeting the requirements above, including basic testing of component distribution mechanisms and modeling of template systems to predict performance in large-scale implementation[.]

Now, I think that’s tough. But there are two more sub-tasks that should be completed by that 270-day deadline as well!

(ii) establish standards and performance measures for State and local government countermeasure distribution systems, including demonstration of specific capabilities in tactical exercises in accordance with the National Exercise Program [ed. note: huh?], and (iii) establish a process to gather performance data from State and local participants on a regular basis to assess readiness[.]

Oh, that’s all? Not really, there’s five more deadlines in this section. I don’t, however, want to continue harping on that one point. I think I’ve made my point that the deadlines are quite ridiculous. But what about the substance? Well, simply put, I love it.

The federal government should absolutely be the go-to place for countermeasure distribution plans. Somebody from HHS should be able to go into any health department that asks with a binder full of plans and be ready to help mold them to fit existing plans and local situations. Using these templates as a baseline, the feds should be able to develop measurements and minimum standards that can be compared and contrasted across the country. I do know that some sort of measurement is done due to Cities Readiness Initiative funding, but it’s my understanding thats no more than a series of questions on different facets of what’s supposed to be an already existing plan. Basically, no help to smaller burghs that will have to deal with non-flashy non-terror disasters. Paragraph 24 says that the federal government should develop plans to help supplement and complement State and local distribution capacity. In the event that the State and locals can’t handle it, these plans should detail how the feds will step and fill in the gaps.

As for the Strategic National Stockpile (SNS), the Directive notes that acquisition for the stockpile should be transparent and risk-informed (read: no sweetheart deals for anti-alien attack meds). Some would say that having the stockpile be properly risk-informed means they should have more anti-virals (for pandemic influenza) than antibiotics (for bioterrorism), but that’s a discussion that should be had out in the open. The stockpile is to be reviewed annually in case of developing situations or outdated materiel.

As for out in the open, the Directive also, um, directs that HHS should start to share information regarding the contents of the SNS with folks who need to know. Planners can’t really plan to respond if they don’t know what they’ll be getting.

The final point made in Paragraph 27 is on coordination. The feds are directed to start coordinating resources between the various national stockpiles (ed. note: how many are there?), and with international stockpiles for sharing should the need arise. This one I’m a bit wary on. I think that coordination is a great idea, in theory. In practice, though, I worry that the SNS could be raided by our friends in the military, leaving nothing for us peons with a runny nose and no guns. I have no reason to believe that, but hey, it could happen.

To sum, I think this is a good section. I’m just amazed at the timelines set forth. Of all the things I mentioned above, the latest all of this should get done is 270 days after the Directive. I’m definitely a cheerleader in all of this, I just worry that in an effort to get these things done by the due dates, corners will get cut, completeness will not be realized, and it could be done better. I, as usual, hope that I’m wrong.

Picture credit: rodrigo senna

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