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Selected Health Care Coalitions Increased Involvement in Whole Community Preparedness But Face Developmental Challenges Following New Requirements in 2017


Health care coalitions (HCCs) help prepare their community health care systems to respond to public health emergencies, such as natural disasters. HCCs are member-led and are composed of health care entities and other response entities that voluntarily work together to coordinate an emergency response. ASPR supports HCCs through the Hospital Preparedness Program (HPP). The HPP funds awardees (e.g., States) to create HCCs, oversee HCCs, and fund HCC activities. In 2017, the HPP required HCCs to include four core member types (hospitals, public health, emergency medical services, and emergency management) and other diverse, ancillary member types (e.g., long-term-care facilities, home health agencies) that are critical to addressing the unique preparedness needs of HCCs' respective communities. Additionally, the Centers for Medicare & Medicaid Services (CMS) suggested that health care entities join HCCs as one way to meet Medicare's emergency preparedness Conditions of Participation, with which CMS required compliance starting November 2017.

This is not a review of the Federal, State, or local government response to the coronavirus disease 2019 (COVID-19) public health emergency.


We selected a purposive sample of 20 HCCs and the corresponding 20 HPP awardees that received 2017 HPP funding. We conducted interviews, administered surveys, and collected documentation from each HCC and HPP awardee. We analyzed responses and documentation to determine the extent to which HCCs expanded their membership; to identify HCC benefits and challenges for coordinating with members; and to determine the extent to which ASPR requirements and guidance facilitate HCCs' and HPP awardees' ability to increase whole community preparedness.


Nearly all 20 HCCs in our review have expanded their membership since ASPR and CMS implemented new preparedness requirements. According to most of these HCCs, this expansion was driven primarily by new diverse types of entities seeking to meet the CMS emergency preparedness Conditions of Participation. Further, all selected HCCs reported that their members take part in HCC activities that benefit whole community emergency preparedness.

However, HCCs also reported that expanded membership presents challenges. For example, some HCCs reported adding new ancillary members in ways that were not strategic. Further, many HCCs reported concentrating their limited resources on developmental activities for these new ancillary members, thereby lessening resources available for other HCC priorities. Moreover, HCCs expressed concerns about their ability to continue to incentivize core members' participation in HCC activities.

Additionally, while HCCs and HPP awardees generally found ASPR guidance beneficial, we found that some HPP requirements and ASPR guidance are not clear. Specifically, unclear requirements and guidance included (1) how an HCC should strategically grow membership, and (2) the flexibility that ASPR allows in meeting HPP membership and other requirements. This lack of clarity contributes to HCCs' challenges and may limit HCCs' ability to prepare for a whole community response to a range of public health emergencies, including emerging infectious diseases.


To further improve HCCs' preparedness for a whole community emergency response, ASPR should (1) clarify guidance that HCCs' membership should ensure strategic, comprehensive coverage of their communities' gaps in preparedness and response; (2) continue to work with CMS to help health care entities comply with the CMS emergency preparedness Conditions of Participation; (3) identify ways to incentivize core members' participation; and (4) clarify to HPP awardees the flexibility available in meeting requirements. ASPR concurred with all four recommendations.