FEMA Thinktank - Or Is It?!?

On September 8, 2021, the International Association of Emergency Managers (IAEM) and NPLI at Harvard sponsored a "think tank" conversation with FEMA Administrator Criswell.

There is no way of knowing, as an attendee, how many people were in attendance for the session. Nor is there any way of knowing how many actual questions were submitted in the Q&A function on Zoom.

We learned that the Administrator came in to the position with 3 priorities (equity, climate change, and FEMA personnel); we learned that FEMA intends to have their strategic plan published by the end of the calendar year; we learned that there is nearly 5 BILLION DOLLARS available in Mitigation grant funding (that is notoriously difficult for small, local jurisdictions to access); and we learned that the FEMA mission creep that we have seen speed up in it's progression will likely continue to spread into many other Federal areas of concern. FEMA appears to be moving into the be all, end all coordinating agency.

Although it may sound as if I do, I don't actually have a concern with that. Provided it is accomplished WELL and not as the work has been done in the past (FEMA = Fix Everything My A$$ was a local slogan from the 2005 hurricane season - I know, I bought the t-shirt while deployed in TX).

What concerns me, is that which we DIDN'T HEAR. Again, I don't know how many questions were asked. But I asked 2 that I think are of extreme import to the ENTIRE NATION. And neither were addressed. And for the last 15 minutes, there were really NO questions addressed.

So, here are those 2 questions:

1. "Rather than fighting the challenge to get Federal agencies to work together to understand their role in an incident, how about getting the regulatory agencies to DECONFLICT the requirements that local organization must follow? For instance, CDC, CMS, and OSHA have all put out new regs for healthcare that are not deconflicted. And, their regulations are written specifically for COVID rather than the broader concept of All-Hazards planning that could be conducted for ALL infectious disease outbreaks." (asked 31 minutes into the session)
2. Paraphrasing: we (the audience and in reference to a comment by the Administrator) understand that the damages caused by current disasters are increasing in frequency and cost. Will FEMA be working with legislators to enact a FEDERAL regulation that requires the nation and territories to follow the International Building Code? (asked 41 minutes into the session)

Here is why I find it disheartening that neither question was answered:

• There are MUCH SMARTER people than I who have worked on both of these issues in the past, and some continue now.
• These are SIMPLE solutions to help immediately improve preparedness for incidents that will SURELY occur again.
• There was an awful lot of time spent talking about FEMA staff, how hard working they are, how tired they are, how dedicated they are, how they just keep responding and responding and responding to disasters. We get it. We are tired, too!

But FEMA statistics have SHOWN that for every $1.00 spent in preparedness, we net $4.00 savings in response - AND - for every $1.00 spent in mitigation, we net $7.00 savings in response!

To just do some simple, dirty math (which someone will certainly 'pipe up' to correct me on) that means that if we are spending $1,000,000,000 on Ida response, had we spent 145,000,000 2 years ago, we wouldn't be spending anything right now!

Theoretically only - there are obviously response costs in every incident. But if we put $100,000,000 into BUILDING CODE UPDATES AND ENFORCEMENT, we could SAVE $700,000,000 dollars in recovery costs! If I told you that when you get a new roof for your house at a quoted cost of $10,000, that if you spend another $1,000 to have it built to FEMA standards for WIND RESISTANCE, that you would not have an insurance claim every few years for missing shingles and water damage in your home and the loss of your sleeping arrangements for a few days and the permanent loss of your children's childhood and your family photos, wouldn't you spend that extra money to preserve your life and family?!?

Want more info on building codes and preparedness? Follow the International Code Council at https://www.iccsafe.org/ on their Facebook or LinkedIn pages.

So, let us turn to the issue of conflicting regulations.

During Hurricane Ida, 7 local nursing homes moved their residents into a "warehouse". While sheltered there, conditions worsened and a number of residents died. All 7 of those nursing homes have had their license to operate a business revoked by the State of Louisiana and the CMS billing license revoked.

On the surface, this may seem like a clear-cut case of elder abuse and a lack of planning and preparedness.

But I can tell you from my experience working the COVID response since the first regional EOC meeting when we activated the healthcare coalition on March 20, 2020 that the entire healthcare industry is stretched to the limit and ready to implode. The BEST and most effective administrators and managers and clinicians struggle every day to have enough staff show up for their shifts to be within the bounds of the laws for minimum staffing and license type (CNA, LCSW, LPN, MA, CNA, etc) and for the type of license of the facility (SNF, CILA, DD, Group, hospice, home health, etc.). One of my member facilities just hired a Director of Nursing last month - they had been without one for the entire COVID response!

In addition to the current struggles that they have, FEMA training for healthcare facilities specifies that they should have a plan to move their resident/patients to "alternate care sites" or "facilities of opportunity" in a disaster. There is a laundry list of potential sites but here are just a few of the sites in the training participant manual that I have open on my desk right now: "aircraft hangars, community/recreation centers, convention facilities, fairgrounds, meeting halls, sport facilities/stadiums, trailer/tents, and "other"". This Alternate Care Site Selection Matrix was developed by the Agency for Healthcare Research and Quality (AHRQ).

Additionally, The Joint Commission identifies "facilities of opportunity" as nonmedical buildings which, because of their size and proximity, can be adapted.

So, with a potentially catastrophic shortage of personnel, multiple facilities that I am responsible for, a facility of opportunity that I control and have ownership of, and a record-breaking storm bearing down, might I have made the same or similar decision?

You Bet I Might!

And any great Administrator is going to want me on their jury. Because I KNOW their struggle is real. And I understand that EVERY DAY people who are in the best facilities die. And I believe I can see through any smoke screen of "preparedness" that is self-serving rather than community serving.

While I understand that the community at large wants this guy's head on a platter, I can tell you that anyone who is still working in non-hospital healthcare after COVID is a SAINT and they deserve our support, not our anger. (and in some cases, some retraining!)

Did some individuals lose their life while they were relocated?

Yes; can we say that they would have survived their medical conditions in a licensed facility with no infrastructure and short-staffing following a hurricane - NO.

Were the conditions likely unbearable?

Yes; have you ever worked in a congregate care setting after a hurricane with no infrastructure and been comfortable - NO. Neither have I and I deployed to FOUR hurricanes in 2004 alone.

Is it possible that these staff are human beings who were trying to do the very best thing possible to protect their charges under duress - Yes. And I sincerely hope that FEMA and every other oversight and regulatory agency take this opportunity to look in the "mirror" and see where they could have improved the preparedness, response, and recovery for this incident. Providing training and guidance that state one concept and then allowing people to be thrown under the "bus" post-incident in unconscionable.

I know for a fact that in my state, our non-hospital healthcare settings have been left to fend for themselves throughout the COVID response. I sincerely hope that if you have a loved one who is aging, and you can't keep them in your home with you (as I am for my 97 year old mother-in-law - she's getting a perm in home this afternoon - YAY!), then you had best take a look at how you can more effectively support our healthcare community. Because they are walking a fine, moving, conflicting line of do as I say but not as I say or do. And we CAN NOT AFFORD TO LOSE THEM.