Hospital Association Wants Major Changes in DHS Threat Matrix

The American Hospital Association sent comments dated July 11 to the Department of Homeland Security seeking significant changes in the Homeland Security Advisory System (HSAS) for Healthcare and the Public Health Sector as it was updated on Feb. 25, 2008. James Bentley, Ph.D., AHA senior vice president of Strategy Policy Planning, wrote that a conference call with hospital association preparedness staff from around the country identified several concerns with the updated guidance. He said the listed items are "unrealistic" and expressed concern that the potential actions listed could become a requirement for federal grants or be used by courts to assess negligence.

When then-DHS Secretary Tom Ridge unveiled HSAS in March 2002, it contained five Threat Conditions: Green (low), Blue (guarded), Yellow (elevated), Orange (high), and Red (severe). The updated document identifies Yellow as the "baseline," implying that Green or Blue threat levels will not exist. "If five levels have now become three, the base or Yellow level needs to be much less comprehensive and less detailed," Bentley wrote, adding, "The threat levels and suggested actions listed in the document are not consistent with state-specified levels or recommended actions of the HavBED [the National Hospital Available Beds for Emergencies and Disasters System] requirements. It is important to harmonize the document or to acknowledge that state level actions have precedence in a tiered National Response Framework that identifies local and state emergency operations as the first two tiers."

Bentley said the document should provide for local or regional threat levels and would impose extraordinary costs by calling for background checks on all employees, which he said could undermine current offender rehabilitation programs that use hospitals as employers. The document also "fails to recognize that maintaining open access to the hospital for patients, visitors, and caregivers is a critical success factor in their operation," Bentley wrote. "The access controls components are unacceptable and need to be reconsidered and reduced."

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