Common use of Continuity of Operations Plan Clause in Contracts

Continuity of Operations Plan. Each HCC funded by the awardee must develop an HCC continuity of operations (COOP) plan that is informed by its members’ COOP plans and submit the plan to ASPR by the end of Budget Period 3 with annual progress reports. HCC COOP plans may be an annex to the HCC’s response plan or may take another form. Each HCC’s COOP plan should include, at a minimum:  Activation and response functions,  Multiple points of contact for each HCC member,  Orders of succession and delegations of authority for leadership continuity,  Immediate actions and assessments to be performed in case of disruptions,  Safety assessment and resource inventory to determine whether or not the HCC can continue to operate,  Redundant, replacement, or supplemental resources, including communication systems, and  Strategies and priorities for addressing disruptions to mission critical systems that include but not limited to electricity, water, and medical gases. Each HCC, in coordination with the awardee, should ensure that communication and coordination systems that are used for incident management are adequately secured, backed up, and have redundant power and server protections. More information about COOP planning can be found in Capability 3, Objective 2, Activities 1 and 2 of the 2017-2022 Health Care Preparedness and Response Capabilities.‌‌ Activity 5. Expedited Fiscal Procedures Are in Place for Ensuring Funding Reaches Impacted Public Health Departments, HCCs, and their Members during an Emergency Response Joint Requirements HPP and PHEP awardees must have expedited fiscal procedures that ensure the funding provided through the HPP and PHEP funding mechanisms reach the impacted communities in an expedited manner, especially during an emergency response. HPP and PHEP awardees must ensure that these systems are routinely tested. For the purposes of this FOA, fiscal preparedness is defined as the process of ensuring that fiscal and administrative authorities and practices that govern funding, procurement, contracting, hiring, and legal capabilities necessary to mitigate, respond to, and recover from public health emergencies can be accelerated, modified, streamlined, and accountably managed at all levels of government. The ultimate goal is to ensure that the funding reaches the impacted communities as quickly as possible to ensure that it has the greatest potential for a positive public health and health care impact. HPP and PHEP awardees must establish plans to effectively receive, obligate, and account for HPP and PHEP funds that are consistent with the purpose of the HPP and PHEP cooperative agreement. Plans must include the ability to move funding to the local level and to HCCs in a timely and effective manner. It is critical that as awardees apply resources to achieve the public health and health care preparedness and response capabilities, they also plan how they will address the additional fiscal and administrative challenges they may face during a public health emergency. To ensure that these potential challenges are addressed, response plans should include emergency authorities and expedited fiscal processes that would likely differ from the awardees’ standard procedures. As applicable, awardees should review incident action plans (IAPs), AARs/IPs, awardee capability self-assessment data, and JRAs when considering the actions taken or planned to overcome challenges and barriers within the scope of fiscal preparedness. HPP and PHEP awardees must work with their local public health jurisdictions and HCCs to ensure that fiscal processes are in place to move funds efficiently between awardees and local public health departments and HCC fiscal entities (where they exist). ASPR has established a benchmark for awardees to execute subaward for routine grants within 90 days of the beginning of the budget period See ASPR-CDC Evaluation and Performance Measurement Strategy section. At the time of application, HPP and PHEP awardees must identify whether their jurisdictions have:  Tested expedited procedures as identified in their plans for: o receiving emergency funds during a real incident or exercise and o reducing the cycle time for contracting and procurement during a real incident or exercise.  Implemented internal controls related to subrecipient monitoring and any negative audit findings resulting from suboptimal internal controls.  Tested emergency authorities and mechanisms as identified in their plans to reduce time for hiring or reassignment of staff (workforce surge). If they were tested, awardees must identify which procedures were tested and describe the average times for recruitment and hiring of staff in routine and emergency circumstances. PHEP Requirements/Recommendations PHEP awardees must document the time it takes to move funds from the state to local public health, both during emergencies and during routine grant administration. In addition to the application project narrative, which describes the standard fiscal operating procedures, PHEP awardees must develop and submit plans to CDC no later than September 30, 2018, that address the following components.‌‌ Fiscal Planning: alignment of the HPP-PHEP administrative processes to describe how funds will be managed between the two programs, including processes for:  Streamlining and consolidating contracting procedures; and  Tracking HPP and PHEP funds separately as, according to federal appropriations law and HHS grant guidance, HPP and PHEP funds must maintain their unique identity and must be used for their intended purposes.

Continuity of Operations Plan. Each HCC funded by the awardee must develop an HCC continuity of operations (COOP) plan that is informed by its members’ COOP plans and submit the plan to ASPR by the end of Budget Period 3 with annual progress reports. HCC COOP plans may be an annex to the HCC’s response plan or may take another form. Each HCC’s COOP plan should include, at a minimum:  • Activation and response functions,  • Multiple points of contact for each HCC member,  • Orders of succession and delegations of authority for leadership continuity,  • Immediate actions and assessments to be performed in case of disruptions,  • Safety assessment and resource inventory to determine whether or not the HCC can continue to operate,  • Redundant, replacement, or supplemental resources, including communication systems, and  • Strategies and priorities for addressing disruptions to mission critical systems that include but not limited to electricity, water, and medical gases. Each HCC, in coordination with the awardee, should ensure that communication and coordination systems that are used for incident management are adequately secured, backed up, and have redundant power and server protections. More information about COOP planning can be found in Capability 3, Objective 2, Activities 1 and 2 of the 2017-2022 Health Care Preparedness and Response Capabilities.‌‌ Activity 5. Expedited Fiscal Procedures Are in Place for Ensuring Funding Reaches Impacted Public Health Departments, HCCs, and their Members during an Emergency Response Joint Requirements HPP and PHEP awardees must have expedited fiscal procedures that ensure the funding provided through the HPP and PHEP funding mechanisms reach the impacted communities in an expedited manner, especially during an emergency response. HPP and PHEP awardees must ensure that these systems are routinely tested. For the purposes of this FOA, fiscal preparedness is defined as the process of ensuring that fiscal and administrative authorities and practices that govern funding, procurement, contracting, hiring, and legal capabilities necessary to mitigate, respond to, and recover from public health emergencies can be accelerated, modified, streamlined, and accountably managed at all levels of government. The ultimate goal is to ensure that the funding reaches the impacted communities as quickly as possible to ensure that it has the greatest potential for a positive public health and health care impact. HPP and PHEP awardees must establish plans to effectively receive, obligate, and account for HPP and PHEP funds that are consistent with the purpose of the HPP and PHEP cooperative agreement. Plans must include the ability to move funding to the local level and to HCCs in a timely and effective manner. It is critical that as awardees apply resources to achieve the public health and health care preparedness and response capabilities, they also plan how they will address the additional fiscal and administrative challenges they may face during a public health emergency. To ensure that these potential challenges are addressed, response plans should include emergency authorities and expedited fiscal processes that would likely differ from the awardees’ standard procedures. As applicable, awardees should review incident action plans (IAPs), AARs/IPs, awardee capability self-assessment data, and JRAs when considering the actions taken or planned to overcome challenges and barriers within the scope of fiscal preparedness. HPP and PHEP awardees must work with their local public health jurisdictions and HCCs to ensure that fiscal processes are in place to move funds efficiently between awardees and local public health departments and HCC fiscal entities (where they exist). ASPR has established a benchmark for awardees to execute subaward for routine grants within 90 days of the beginning of the budget period See ASPR-CDC Evaluation and Performance Measurement Strategy section. At the time of application, HPP and PHEP awardees must identify whether their jurisdictions have:  • Tested expedited procedures as identified in their plans for: o receiving emergency funds during a real incident or exercise and o reducing the cycle time for contracting and procurement during a real incident or exercise.  • Implemented internal controls related to subrecipient monitoring and any negative audit findings resulting from suboptimal internal controls.  • Tested emergency authorities and mechanisms as identified in their plans to reduce time for hiring or reassignment of staff (workforce surge). If they were tested, awardees must identify which procedures were tested and describe the average times for recruitment and hiring of staff in routine and emergency circumstances. PHEP Requirements/Recommendations PHEP awardees must document the time it takes to move funds from the state to local public health, both during emergencies and during routine grant administration. In addition to the application project narrative, which describes the standard fiscal operating procedures, PHEP awardees must develop and submit plans to CDC no later than September 30, 2018, that address the following components.‌‌ Fiscal Planning: alignment of the HPP-PHEP administrative processes to describe how funds will be managed between the two programs, including processes for:  • Streamlining and consolidating contracting procedures; and  • Tracking HPP and PHEP funds separately as, according to federal appropriations law and HHS grant guidance, HPP and PHEP funds must maintain their unique identity and must be used for their intended purposes.