[Infowarrior] - Another National Strategy to Implement

[Richard Forno]

(c/o MM)

Another National Strategy to Implement
Filed under: Biosecurity — by Alan Wolfe on August 14, 2012
http://www.hlswatch.com/2012/08/14/another-national-strategy-to-implement/

Without much fanfare at all, the White House released a “National Strategy for Biosurveillance” on July 31, 2012, promising to “unify national effort around a common purpose and establish new ways of thinking about providing information to enable better decisionmaking [sic].”

Unfortunately,  this strategy lacks clear ways and means that would allow for a coordinated national biosurveillance effort. Rather than leveraging the “whole of government” approach and implementing an oversight process that has broad authorities, this strategy avoids directing roles and responsibilities that are necessary to avoid duplication of effort and power struggles over who is supposed to be in charge of this overall program.

This is not a new issue.

After the 2005 avian influenza flu scare, Congress directed the Department of Homeland Security (DHS) in 2007 to stand up a National Biosurveillance Integration Center (NBIC). So DHS obediently complied, with a plan to stand up the NBIC in 2008 and have it fully operational in 2009.

Its responsibilities included rapidly identifying and tracking biological events; integrating and analyzing data from various environmental and clinical sources; disseminating alerts and appropriate information; and overseeing the development of interagency coordination through a National Biosurveillance Integration System (NBIS).

DHS’s Office of Health Affairs stood up NBIS in 2004, an IT system that relied on open source information and added some intelligence and threat analysis.

In 2007, the White House released HSPD-21, “Public Health and Medical Preparedness,” tasking the Department of Health and Human Services (DHHS) to“establish an operational national epidemiologic surveillance system for human health, with international connectivity where appropriate” that included working with the Federal, State, and local surveillance systems (where they existed) for public health purposes.

DHHS has oversight of the Centers for Disease Control and Prevention, which of course has a long history of monitoring and tracking disease outbreaks that might affect human or animal health.

In 2008, DoD created an Armed Forces Health Surveillance Center to be a global health surveillance proponent for its deployed forces.

The Government Accountability Office (GAO) immediately criticized the DHS plan in this 2008 report. It stated  “Threats of bioterrorism, such as anthrax attacks and high-profile disease outbreaks, have drawn attention to the need for systems that provide early detection and warning about biological threats, known as biosurveillance systems.” DHS had not, from the GAO’s point of view, taken the necessary steps to plan and budget its NBIC and would not meet the statutory requirement to be operational by September 30, 2008. DHS had not formalized information sharing agreements with outside agencies (such as the Departments of Defense, Agriculture, Health and Human Services, Interior, State, and Transportation), and of course, Project BioWatch has to feed into the NBIC.

Project BioWatch is hardly a “national” system with only 30-odd sites in U.S. metropolitan areas, but it is part of the overall data collection effort.

The GAO returned in 2010 to report that there did not appear to be a comprehensive national biosurveillance strategy that clearly identified the USG objectives or a focal point with responsibility, authority, and funding to lead the effort. In particular, the GAO noted that the NBIC had not been fully successful in collaborating with its Federal, state and local partners, because (surprise) those agencies had basically stonewalled NBIC, citing excuses such as lack of funds, lack of authorities, and so on.

The Presidential Decision Directive-2, “National Strategy to Counter Biological Threats,” which was released in December 2009, called for a national biosurveillance capability, as did the DHHS National Health Security Strategy. The lack of clarity on roles and responsibilities, joint strategies, policies, and procedures for operating across agency boundaries had limited NBIC’s ability to do what it had been chartered to do – maintain situational awareness of biological threats across the nation and effectively communicate to decision-makers what the current state of biological threats were.

So the National Security Staff has responded to the GAO recommendation after about two years of discussions and reviews.  With the White House’s release of this (yet another) national strategy, surely the roles and responsibilities of the various USG agencies involved will be clarified.

Except … they aren’t.

The strategy does detail four core functions of the national biosurveillance enterprise, to include scanning and discerning the environment; integrating and identifying essential information; alerting and informing decision-makers; and forecasting and advising on the impacts of biological disease outbreaks.

But this is hardly startling stuff. Everybody gets the goodness of a concept proposing an “all-nation” system that saves lives by providing actionable and timely information on biological threats.

What may be less well understood and not fully recognized is the startling scope of this effort. Biosurveillance does not, as a layperson might expect, involve the collection and analysis of only biological threats (both natural and man-made), but rather all hazards – chemical and radiological incidents and accidents included – that might affect the health of the biosphere (humans, animals, and crops). This is a huge task, and one might wonder if any one agency could hope to integrate and make sense of this data, even if all the Federal agencies cooperated with DHS’s NBIC as they’ve been directed.

But that’s all going to be addressed in 120 days, when a “strategic implementation plan” will lay out the roles and responsibilities, specific actions and activity scope, and perhaps most importantly, a mechanism for evaluating progress toward specific goals within those four core functions.

It’s doubtful there will be any additional funds for this effort (given budget realities), but the developers of this strategy are optimistically calling for “new thinking and revised methodologies” that will enable this enterprise to work and to allow those timely decisions to save lives and reduce the impact of whatever threats this biosurveillance enterprise takes on.

My personal concern is that the deliberate inclusion of tracking bioterrorism incidents and naturally-occurring biological disease outbreaks, in addition to chemical and radiological incidents and accidents, is simply too much to handle. It’s information overload. The focus of this enterprise ought to have been kept to natural disease outbreaks, which is certainly where the legitimate concerns originated. There is no appreciable threat of terrorist misuse of the life sciences today; rather, the insider threat caused by the creation of hundreds of biological laboratories, in response to numerous DHS and DHHS grants, may be the greater threat source.

The USG has this bad habit of trying to develop optimal strategies that attempt to eliminate risk and prevent incidents by controlling the threat, rather than focusing on the more achievable mitigation and resilience measures that might be implemented at the State and local level.

I am even less confident that a single office will get the authority to convince the three major players, DHS, DHHS, and DoD, to play nicely –  specifically, to standardize their biosurveillance information and release it in a timely fashion so that these decision-makers can be informed.

A more likely outcome will be the jockeying of political appointees to create new authorities and to obtain additional funding for an effort that remains poorly scoped and poorly overseen.

But hey, let’s come back in four months and see if that “strategic implementation plan” is out. Maybe we’ll see some realistic direction and achievable goals and objectives in that document. And maybe we’ll see an effective interagency approach that employs a “whole of government” concept, with a program that is both resourced and executable within the next year.

But I’m not counting on it.

 

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