CCH® Healthcare Compliance — 10/12/09

OIG: localities not fully prepared for pandemic influenza

An evaluation of ten selected localities revealed that they were not fully prepared for the distribution and dispensing of vaccine and antiviral drugs in response to an influenza pandemic. The Office of Inspector General (OIG) has identified and described eight broad components of vaccine and antiviral drug distribution and dispensing planning:

    Receiving and staging involves identifying locations where vaccines and antiviral drugs will be received and staged, and developing procedures necessary to deliver them to dispensing sites.

    Dispensing involves administering medications, identifying facilities at which dispensing will occur, and developing procedures to operate and staff these sites.

    Tracking involves managing vaccine and antiviral drug inventories by implementing inventory management systems at state or local stockpiles, receiving and staging locations, and dispensing sites.

    Vulnerable populations refer to groups, such as the homeless, prison inmates, and nursing home residents, which may not have access to traditional dispensing sites.

    Priority groups are typically defined by occupation or health status (e.g., health care personnel, pregnant women). While HHS has developed preliminary guidance regarding priority group definitions, states and localities are responsible for implementing this guidance appropriately.

    Security for vaccines and antiviral drugs involves protecting these medications at state or local stockpiles and receiving and staging locations through the point of dispensing.

    Storage involves ensuring that the proper environmental conditions are maintained at state or local stockpiles and receiving and staging locations until the medications are dispensed.

    Transportation involves moving the medications from state or local stockpiles and receiving and staging locations to dispensing sites.

Distribution and dispensing components. According to the OIG's study, the ten selected localities had not addressed most of the eight components and 89 preparedness items that measure the extent of preparedness within each of the eight components. None of the localities had started planning in all eight components. The selected localities' plans to distribute and dispense vaccines and antiviral drugs generally were not actionable. For instance, they did not estimate staffing needs, and when they did, they had not accounted for absenteeism rates in their estimates.

The selected localities moreover varied to the extent to which they addressed the distribution and dispensing components. While all the localities addressed at least one preparedness item in two or more of the components, no locality addressed at least one preparedness item in all eight components.

The selected localities addressed the highest percentage of preparedness items in the Receiving and Staging component and Dispensing component, and addressed the lowest percentage of preparedness items in the Security, Storage and Transportation components.

Exercises, After Action Reports, and Improvement Plans. The selected localities conducted exercises related to drug distribution and dispensing and, between September 2006 and July 2008, varied in the extent to which they exercised the components and the number of components tested.

However, nine localities did not create both After Action Reports and Improvement Plans for all of their exercises. After Action Reports typically include the exercise objectives, participant observations, and general recommendations to improve future performance. Improvement Plans identify specific corrective actions necessary to improve the plan, assign the actions to responsible parties, and establish target completion dates to incorporate the lessons learned during the exercise.

Collaboration with community partners. All selected localities collaborated with community partners, such as educational institutions, state or local emergency management agencies, and hospitals, to develop and exercise their plans to distribute and dispense vaccines and antiviral drugs during an influenza pandemic.

Recommendations. It was recommended that the Centers for Disease Control (CDC) work with states to:

    Improve local preparedness by: (1) determining why localities appear to be in the early stages of planning, and provide assistance to improve preparedness; (2) prioritizing the planning areas where states should focus pandemic influenza funding to improve local preparedness; and (3) placing special emphasis on ensuring localities develop actionable drug distribution and dispensing plans.

    Ensure that localities consistently create both After Action Reports and Improvement Plans to enhance their preparedness.

    Facilitate information sharing and collaboration about existing pandemic influenza planning and encourage the use of existing resources. For example, the CDC should encourage using the Lessons Learned Information Sharing Web site to share not only After Action Reports but also planning documents and promising practices.

The CDC agreed with the second and third recommendations, yet did not indicate whether it agreed with the first recommendation, although it stated it planned to use some of the suggested actions to address this recommendation.

Source: OIG Report, No. OEI-04-08-00260, Sept., 2009.

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