If ASPR has its way with Congress, there will only be 36 eligible awardees for Hospital Preparedness Program funding. Nineteen states will be out under a "risk-based" approach that limits awards to only those states and local jurisdictions ASPR has 'scientifically' determined have the highest risk. And before those states that appear to have avoided the axe get too giddy, know that ASPR expects you to compete with academic medical centers, state and local hospital associations... for the opportunity to administer the HPP cooperative agreement.

The Center for Medicare and Medicaid Services (CMS) has issued an advanced copy of interpretive guidelines and survey procedures for the new emergency preparedness rule. The 72 page document is a near final draft necessary to guide providers and suppliers in meeting the new emergency preparedness Conditions of Participation and Conditions of Coverage that become enforceable November 15, 2017.

The 2017-2018 Funding Opportunity Announcement (FOA) that contains the Hospital Preparedness Program (HPP) and Public Health Emergency Preparedness Program (PHEP) cooperative agreements dedicates six pages to funding restrictions that limit how awardees can spend their funds. That's five more pages of restrictions than were in the 2016-2017 FOA. But, are all funding restrictions required to be passed through by awardees to healthcare coalitions and local health departments in their sub-grants? Well, it depends whom you ask. And that's a problem!

In an unprecedented move, the Assistant Secretary for Preparedness and Response (ASPR) has issued a directive that authorizes healthcare coalitions to use Hospital Preparedness Program (HPP) funds to legally establish nonprofit entities. The authorization gives healthcare coalition leaders the financial latitude to move away from reliance on fiscal sponsors, opening the door to sustainability strategies.

The Center for Medicare and Medicaid Services (CMS) is warning healthcare providers and suppliers subject to the new Emergency Preparedness Rule that they must meet the requirements of the training and testing program by the implementation date, November 15, 2017. And hiring a consultant cannot alone address the challenges of meeting the requiements.

In 2011, the Illinois Department of Public Health forfeited hundreds of thousands of dollars worth of Hospital Preparedness Program funded mobile medical assets to its fiscal sponsor for the Illinois Medical Emergency Response Team (IMERT). The forfeiture was caused by a few simple missteps, repeated each year for a decade, whereby the State had delivered sub grants to a nonprofit fiscal sponsor for the fiduciary agent for IMERT.

So what does this have to do with today's emerging healthcare coalitions? Well, survival!

Cracks in the foundation are beginning to surface – the foundation for healthcare and medical readiness that is. And neither the Assistant Secretary for Preparedness and Response (ASPR) nor the National Healthcare Coalition Preparedness Conference (NHCPC) are equipped to shore up the shaky foundation beneath rapidly evolving healthcare coalitions.

The Center for Medicare and Medicaid Services (CMS) is warning healthcare providers and suppliers subject to the new Emergency Preparedness Rule that they must meet the requirements of the training and testing program by the implementation date, November 15, 2017. And hiring a consultant cannot alone address the challenges of meeting the requiements.