BCHC comments on the PAHPA reauthorization discussion draft

July 2023

Public Health Emergency Preparedness program

BCHC supports the reauthorization of the PHEP program and the inclusion of pandemic response planning as a PHEP grantee responsibility to reflect the need to plan for pandemics beyond influenza. BCHC also recommends:

PHEP be reauthorized at $1 billion, which would take into account inflation since the program began and align it with the intended buying power from its 2002 creation of $1.08 billion.
Congress request a GAO examining how states determine the appropriate portion of PHEP awards for local health departments and make recommendations on how federal PHEP funds can be more efficiently used to support system wide preparedness.

Improving medical readiness and response capabilities

BCHC supports the reauthorization of the HPP program. The draft creates an additional criterion (C) for eligibility for healthcare preparedness cooperative agreements and grants. It is unclear whether this additional criterion, as drafted, would prevent state and local public health departments from administering healthcare preparedness cooperative agreements and coordinating preparedness efforts with healthcare partners in the jurisdiction. It is critical that the role of public health in the healthcare preparedness enterprise not be diminished. BCHC also recommends:

HPP be reauthorized at $500 million – the amount grantees received twenty years ago in FY2003. HPP has been cut by more than 50% over the last 20 years and remains stretched due to prolonged emergency responses, increased preparedness and response requirements, and annual discretionary funding not keeping pace with inflation.

Enhancing domestic wastewater surveillance for pathogen detection

Our members have embraced this important disease detection tool working in collaboration with their local water authorities. The discussion draft does not include an authorized funding amount for this program. It is critical that sufficient authorization level be provided to the Wastewater Surveillance System program to realize an effective, nationwide system, and that this authorization is in addition to the existing Epidemiology and Laboratory Capacity (ELC) funding authorization; not a component thereof. As to reporting requirements, we would encourage that CDC consult with local health departments on the data to be collected across jurisdictions, what data are publicly available and by whom they are made available.

Medical countermeasures (MCM) for viral threats with pandemic potential

BCHC supports the authorization of MCM development for viral threats with pandemic potential. It is important that there is dedicated funding for BARDA to carry this out. BCHC recomends:

Amending the language in F (ii) to add an additional subsection to say threats that—“include priority virus families and other viral pathogens with a significant potential to cause a pandemic.” This will ensure that BARDA is able to engage in MCM development for unknown viruses with pandemic potential and not just those that consistently exit or continually circulate.

Public Health Emergency Medical Countermeasures Enterprise (PHEMC)

BCHC lauds the inclusion of language to allow information sharing with state, local and tribal public health departments. BCHC recommends:

A permanent seat for state, local and tribal public health officials who are responsible for the last mile, getting lifesaving medications to people who need them. Adding a permanent seat on the PHEMCE and will ensure this critical perspective is included in decision-making related to the SNS products and distribution plans from the beginning. The PHEMCE strategy and implementation should also require that local and state health departments be involved in all phases of the MCMs enterprise including in initial investment; research and development of vaccines, medicines, diagnostics, and equipment for responding to emerging public health threats; and distribution and dispensing of countermeasures.

Pilot program for public health data availability

BCHC appreciate the inclusion of the public health data pilot program as a first step in strengthening public health data availability. However, BCHC urges the inclusion of the Improving Data Accessibility Through Advancements in Public Health Act or Improving DATA in Public Health Act (H.R. 3791) that promotes coordination between federal agencies to share critical public health data used to prepare for and respond to public health emergencies.

Temporary reassignment of State and local personnel during a public health emergency

BCHC supports reauthorizing temporary reassignment of federally funded staff in the event of an emergency. BCHC also recommends:

Modifying the provision to provide flexibility so local health departments and federal agencies may also issue and receive temporary reassignments. We recommend changing the language to enable PHEP Directors to be allowed to submit the request on behalf of the jurisdictions directly to ASPR, not via an elected official. We recommend that the PHEP Director of a state/local health department should be able to submit this request, which would shift decision making power to professionals managing the crisis.
Directing HHS to work with its agencies to establish a “one-stop shop” for state, local and tribal health departments to submit emergency reassignment requests. Health departments should not need to repeat the entire process each time the public health agency renews an employee.

Public Health Workforce and Infrastructure

While the PAHPA reauthorization draft contains many critical provisions, the discussion draft does not provide sufficient support to rebuild and expand the nation’s public health and health care workforces. Along with the ongoing shortage of healthcare workers, persistent cuts to public health funding over the past decade have drastically shrunk the local public health workforce, contributing to a national crisis. BCHC highlights the importance of authorizing and investing in the governmental public health workforce and infrastructure that is critical to being response ready for everyday public health challenges and the next large-scale public health emergency. The Public Health Infrastructure Saves Lives Act (S.1995) would establish a Core Public Health Infrastructure Program at the Centers for Disease Control and Prevention (CDC), awarding grants to state, local, tribal and territorial health departments to ensure they have the tools, workforce, and systems in place to address existing and emerging health threats and reduce health disparities. BCHC also recommends:

Increases funding authorization levels for existing public health and healthcare workforce loan repayment programs.
Further investments in critical public health workforce development programs, particularly at CDC, including: Epidemiology Investigation Service (EIS), Career Epidemiology Field Officer (CEFO) program, Laboratory Leadership Service, Public Health Informatics Scholarship, Public Health Associate Program (PHAP) and Preparedness Field Assignee Program (PFA).

Adult Vaccine Program

A comprehensive vaccine infrastructure is needed to immunize all Americans against infectious disease threats. PAHPA should authorize a Vaccines for Adults program, which would support access to Advisory Committee on Immunization practices (ACIP)-recommended routine and outbreak vaccines at no cost. While the existing National Vaccine Program or 317 is a critical support mechanism, it is not sufficiently funded to support vaccination for all uninsured and underinsured adults. Even with the improvements in access to adult vaccines in Medicare Part D, Medicaid, and CHIP, there are still significant gaps in coverage and infrastructure for adults that leave Americans vulnerable to vaccine-preventable diseases, both routine and emergent.

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