PREVENT Pandemics Act Duke-Margolis Proposal Comments

February 4, 2022
MEMORANDUM

FROM: The Robert J. Margolis, MD, Center for Health Policy at Duke University (Duke-Margolis Center)
RE: Proposals in the PREVENT Pandemics Act discussion draft

The Duke-Margolis Center applauds your effort to move forward a critical set of pandemic preparedness and response measures in the Prepare for and Respond to Existing Viruses, Emerging New Threats, and Pandemics Act (PREVENT Pandemics Act). The discussion draft contains a number of important proposals focused not only on near-term needs associated with overcoming the current COVID-19 pandemic, but also longer-term review and analysis of our collective shortcomings during COVID-19 so that we are far better prepared to respond decisively to future potential public health emergencies. Consequently, we encourage you and your colleagues to move swiftly toward deliberation and passage of the PREVENT Pandemics Act.

At the same time, we encourage a broader view of public health and pandemic preparedness by more completely incorporating the critical role of public-private collaboration and by leveraging private health care system capabilities to truly enable a robust public-private response to a future health emergency. The preparedness and disaster response apparatus the United States needs for future health emergencies must include concerted links between public health and private sector actors in order to fully support the health care systems, emergency responders, primary care providers, and community organizations that are critical to our response but that have faced challenges in coordination and support under wave after wave of COVID-19 variants. Our response must sufficiently invest in data modernization programs and information exchange linkages, supported by aligned incentives, so that decision makers in all sectors can respond together to the health emergency in real time. It must make use of drastically improved manufacturing capabilities and supply chains that can move from a “warm base” footing to increased production and distribution as needs on the ground evolve over time. It must reflect the shift in our health care policies toward greater support for prevention, early diagnosis, and community-based management.

Reforms that leverage the growing capabilities of health care providers, manufacturers and distributors, and community-based organizations will enable a more complete and timely response to head off serious complications and hospitalizations. These reforms are aligned with other policy initiatives already underway not just for emergency surges, for example around building robust supply chains that avoid drug shortages and health care systems that are better at protecting and promoting population health and equity.

For these reasons, it is very important that the Task Force proposed in Sec. 101 is adequately resourced and staffed, with a sufficiently broad scope so that its findings and recommendations can build upon the PREVENT Pandemic Act’s proposals to achieve the ultimate goal of bringing the Federal government, state and local authorities, and our extensive private health care system together in a new public health and disaster response infrastructure. The Task Force is therefore a cornerstone provision in PREVENT’s ultimate aims. The team at Duke-Margolis looks forward to sharing our COVID-19 related work and experiences with the Task Force once it is established and begins lines of inquiry.

Building on these general comments, we also include here a number of proposed revisions, refinements, or additions to other proposals found throughout PREVENT. These suggestions are based on two years of work focused on COVID-19 response policies, vaccine and therapeutic development, testing strategies, and health sector resilience, including more than 50 white papers, policy briefs, and commentaries; multiple Congressional testimonies; and over 20 public events. These comments are also reflective of collaborative work undertaken with the Healthcare Leadership Council and dozens of partner organizations and experts to issue the February 2021 report “National Dialogue For Healthcare Innovation: Framework for Private-Public Collaboration on Disaster Preparedness and Response.” The report outlines critical challenges and potential solutions for improving data and evidence generation, strengthening innovation and supply chain readiness, and innovating care delivery approaches to address sustained health emergencies.

We look forward to continued collaboration with your teams over the coming weeks as you advance the PREVENT Pandemics Act’s proposals. Please do not hesitate to reach out should you have questions or wish to discuss any of these comments further.

Sincerely,

Duke-Margolis Center for Health Policy