NRF: Is ESF-8 Full of Holes?

The National Response Framework (NRF) includes a Base Plan, six support annexes, and fifteen Emergency Support Function (ESF) annexes. First published by the Federal Emergency Management Agency (FEMA) in 2008, it has evolved into today's fourth edition that aligns with the?National Preparedness Goal (NPG) , is better integrated with the private sector, implements community lifelines, and reallocates ESFs 5 and 14.

But, after 14 years, three revisions, and too many overly challenging public health and medical responses, ESF-8 has yet to feel the love from the planners at FEMA. It is time.

The procrastination could be because ESF-8 is highly complex, and the subject matter experts on FEMA's planning team have yet to fully appreciate the nuances between the many disciplines that must collaborate to fulfill the mission. Could it perhaps be that FEMA depends on the U.S. Department of Human Services (HHS) – the ESF-8 coordinating and primary agency – to send a note when they see disconnects between the NRF ESF-8 Annex and their internal response and recovery policies and plans? That might explain why the fourth edition of the NRF cut and pasted ESF-8 from the third edition.?

Before dissecting the neglected ESF-8, let's lay the foundation for what's possible by looking at the aggressive evolution of the NRF Base Plan.

The Base Plan

The NRF originated with the 1992 Federal Response Plan (FRP), an outflow of the Robert T. Stafford Disaster Relief and Emergency Assistance Act of 1988 (Stafford Act) . The FRP was focused solely on what federal agencies would hold specified responsibilities during federally supported disaster operations. It was a federal plan that applied only to federal agencies, not national guidance. So, to state and local emergency managers, it was a non-issue; it was just a "federal thing."?

That would change after the September 11th Terrorists Attacks, the subsequent enactment of the Homeland Security Act (HSA) of 2002 , and the issuance of Homeland Security Presidential Directive 5 (HSPD-5) . The mandate to FEMA was clear: consolidate "existing federal government emergency response plans into a single, coordinated national response plan." Further, the new plan would demonstrate an "all-discipline" and "all-hazards" approach in preparing for, responding to, and recovering from domestic incidents.

Consequently, the National Response Plan (NRP) replaced the FRP in December 2004, eight months before Hurricane Katrina landed on the Gulf Coast. The NRP introduced the fifteen ESFs to state and local governments, including ESF-8 – Public Health and Medical Services.

The sea change here for emergency managers was that the NRP dictated how state and local governments would request federal resources and how states would coordinate efforts between the local, state, and federal governments during federally declared disasters. In explaining the evolution, the NRF, First Edition, said this about the NRP: "The NRP broke new ground in integrating all levels of government in a common incident management framework."

Unlike the FRP, the NRP was more than a "federal thing."?

Eight months after its promulgation, in August 2005, the NRP imploded on national television. The landfall of Hurricane Katrina and associated failures of the levees protecting New Orleans caused unfathomable human suffering and loss of life, demonstrating that the federal, state and local governments' disaster operations needed to be in sync but were not. And the challenges were most apparent in the two human-facing ESFs: ESF-8 and ESF-6.

Did you know that emergency managers can only deliver on ESF-6 after mastering ESF-8? That's a story for another time.

The public nature of the "less than ideal" response – as President George W. Bush called it – led to much introspection in Katrina's aftermath from Congress and the White House about the federal government's role in disaster preparedness and response. Many questioned whether the deemphasis of FEMA and emergency management under the HSA and FEMA's apparent irrelevance in the Department of Homeland Security (DHS) were to blame.

Following numerous Katrina investigations and after-action reviews, the questions were straightforward: 1) Did FEMA need authorities and resources restored that were lost through the enactment of the HSA when the prevention-focused DHS assimilated them? 2) Does FEMA need to revisit the NRP and whether its failed implementation was foundational?

Fortunately, the answer to both questions was yes.

So, Congress again acted, passing the Post-Katrina Emergency Management Reform Act (PKEMRA) of 2006 , mandating that the FEMA develop a national preparedness system . It also required them to "complete, revise, and update, as necessary, a national preparedness goal ... to ensure the Nation's ability to prevent, respond to, recover from, and mitigate against natural disasters, acts of terrorism, and other man-made disasters."

On a parallel track with the PKEMRA, Congress also enacted the?Pandemic and All-Hazards Preparedness Act (PAHPA) ?that mandated the creation of the HHS Office of the?Assistant Secretary for Preparedness and Response (ASPR) ?lead ESF-8 preparedness, response, and recovery for the agency. In addition, ASPR assumed management of the?Hospital Preparedness Program (HPP) ?from the Health Resources and Services Administration (HRSA) and led the development of the?Health Care Preparedness and Response Capabilities (HCPR) .

Author's Note:?In 2022, ASPR was elevated from a Staff Division to an Operating Division in HHS, and its name changed to the Administration for Strategic Preparedness and Response.

In January 2008, the NRF, First Edition, was promulgated and FEMA incorporated the fifteen ESF annexes from the NRP with minimal edits. Their mindset was likely that federal agency authorities, roles, and responsibilities had stayed the same, so why fix what's not broken? Unfortunately, the aversion to revising the ESF annexes continues.

The NRF Base Plan was revised in 2013, 2016, and 2019 and has retained fifteen ESFs. Notwithstanding the Base Plan's evolution, other than?ESF-5 ?and?ESF-14 , the functional annexes have remained relatively unchanged since the promulgation of the second edition in 2013. This revision amended the ESF template and aligned agency activities with the NPG Core Capabilities.

Of the fifteen, ESF-8 is, arguably, the most tired.

The NRF Is Not…

Before digging into ESF-8, let's clarify that the NRF is not a law or regulation that state and local governments must follow. Instead, FEMA must use funding opportunities (fiscal federalism) to buy compliance. For example, to receive funds from the?Emergency Management Performance Grant (EMPG) ,?Homeland Security Grant Program (HSGP) , and other DHS programs, FEMA makes state adoption of NRF principles a condition of eligibility. Further, these funding opportunities require state EMAs to make adoption a condition of sub-grants to local governments.

Since state and local EMAs generally accept federal funding, the strategy has worked.

Understand also that the NRF adoption requirements accompany funding opportunities from other federal agencies. For example, the HHS-ASPR HPP cooperative agreement incorporates them. And the Centers for Disease Control and Prevention (CDC) Division of State and Local Readiness (DSLR)?Public Health Emergency Preparedness Program (PHEP) ?does as well.

Fortunately, as with state and local EMAs, the funding-induced compliance strategy has worked as designed to get state and local health departments on board with the NRF. This compliance is paramount because in most state and local emergency operations plans (EOPs), the health department is the ESF-8 primary agency, whether they title as such or not.

But, unfortunately, the strategy also needs to effectively influence the operations of the predominantly private sector health care and human services providers critical to much of the ESF-8 mission. And that's where things fall apart.

Emergency Support Function 8

In Part 2 , we'll dig into what confounds emergency managers about the ESF-8 Annex, and we'll dissect the fourth edition to compare it to what HHS-ASPR tells state health departments, health care coalitions (HCCs), and health care and human services providers to prepare for through the HCPR Capabilities . And we'll do the same with CDC-DSLR expectations for state and local health departments in the Public Health Emergency Preparedness and Response (PHEPR) Capabilities.

Ideally, the activities outlined in the NRF ESF-8 Annex would vertically and horizontally align with agency response plans at HHS-ASPR and CDC-DSLR and with state ESF-8 Annexes (Or whatever a state may title it). And the local ESF-8 Annex (Or whatever a jurisdiction may title it) would align with the state ESF-8 Annex. They rarely do.

So, how do we achieve this aligned preparedness utopia? Well, it starts with getting FEMA to bring the NRF ESF-8 Annex in alignment with what it is that HHS-ASPR and CDC-DSLR are seeking from their HPP and PHEP awardees.

Read Part 2 Here.

Do you need help connecting health, social, and human services providers with the emergency management system? It starts by finding an ESF-Wizard...