Mandating Public Health Emergency Preparedness: Analysis of the CMS Rule

Public health emergency preparedness is an area of growing policy concern with the emergence of new threats. The Centers for Medicare and Medicaid Services issued a proposed rule in 2013 laying out mandates that hospitals and other facilities would have to meet in order to receive federal funding. Hundreds of comments were submitted in response to the rule, which was finalized in 2016. The following study employs content analysis and interpretive policy analysis to investigate the reaction to rule as it was proposed. In doing so, we will consider the different values, beliefs, and feelings regarding the rule that were expressed in public comments submitted in response to it. Along with those aspects, we will also consider the political, economic, and social implications of the proposed rule as expressed in the public comments. These methods will be used to address whether the selected comments represent different coalitions in regard to the CMS rule and if different coalitions represent different themes in their comments. The study will also consider whether the notice-and-comment process, in this instance, is in line with the advocacy coalition framework and whether there were clear winners in the process.