HHS Seeks Input on Health Care System Resilience
On June 5, 2020, the Office of the Assistant Secretary for Health in the Department of Health and Human Services (HHS) issued a request for information (RFI) published in the Federal Register seeking comments from health care system stakeholders regarding the “resilience” of the U.S. health system post COVID-19. In May, members of the Saul Ewing Arnstein & Lehr Health Law group published their predictions for changes in the health care delivery system post COVID-19.
The RFI cites the most common definition of resilience as, “the capacity of health actors, institutions, and populations to prepare for and effectively respond to crises; maintain core functions when a crisis hits; and, informed by lessons learned during the crisis, reorganize if conditions require it.”
The RFI was published because HHS seeks a more comprehensive understanding of how stakeholders define resilience in their respective organizations and how they use data and analytic approaches to boost their resilience. HHS is seeking to “identify opportunities to strengthen the U.S. healthcare system, as a whole, through public-private partnerships in data sharing and comprehensive analytics.” The RFI notes, “Anecdotal reports and experiences from the frontlines, and emerging data, indicate that the COVID-19 response has consequentially resulted in limited access to routine and emergency healthcare services in many, if not most, communities.”
HHS is requesting comments on a range of topics, including:
- The most significant barriers to assessing, monitoring, and strengthening health system resilience;
- What scientific advances are needed to assess and address vulnerabilities in the health system during a pandemic;
- Policies and programs that can be improved to mitigate the risk of COVID-19;
- What data sources organizations use to assess the resilience of the health system and which demographic populations are covered by this data;
- Health conditions that can be used as indicators of healthcare availability, access, timeliness, and quality;
- The types of public-private partnerships used to assess and monitor health system resilience and population health outcomes; and
- Which private and public sectors HHS should engage with as part of these collaborative efforts.
This RFI suggests HHS may consider new policies resulting from the current public health emergency. Providing comments to this RFI to HHS is an opportunity to shape the future of the U.S. health care system policy making and potentially resource allocations so HHS can better address public health emergencies in the future. Comments in response to the RFI must be submitted by July 8, 2020.
Saul Ewing Arnstein & Lehr’s lawyers regularly assist health care institutions and groups and providers with regulatory and legal compliance issues and are available to assist health care providers, institutions, and companies who wish to submit comments to this RFI. If you have questions about this article or the RFI, please contact the authors.