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March 28, 2023
The Honorable Bernard Sanders, Chair
Committee on Health, Education, Labor and Pensions
United States Senate, Washington, DC 20510
The Honorable Bill Cassidy, MD, Ranking Member
Committee on Health, Education, Labor and Pensions
United States Senate, Washington, DC 20510
The Honorable Robert P. Casey, Jr., Member
Committee on Health, Education, Labor and Pensions
United States Senate, Washington, DC 20510
The Honorable Mitt Romney, Member
Committee on Health, Education, Labor and Pensions
United States Senate, Washington, DC 20510
RE: Pandemic and All-Hazards Preparedness Act (PAHPA) Reauthorization Priorities – Strategic Training of Specialized Occupational and Environmental Medicine Physicians
Dear Chair Sanders, Ranking Member Cassidy, and Senators Casey and Romney,
On behalf of the American College of Occupational and Environmental Medicine (ACOEM), I am writing to express strong support for your efforts to reauthorize the Pandemic and All-Hazards Preparedness Act (PAHPA) before the end of the fiscal year. The PAHPA’s core goal of improving the Nation’s public health and medical preparedness and response capabilities for emergencies, whether deliberate, accidental, or natural, is all the more salient given our shared experience in combatting the COVID-19 pandemic. We appreciate your work on this issue as we consider how to ensure that the impacts of future emergencies are mitigated to the greatest extent possible.
Founded in 1916, ACOEM is the Nation’s largest medical society dedicated to promoting employee health through preventive medicine, clinical care, research, and education. The College represents 4,000 physicians and other healthcare professionals specializing in occupational and environmental medicine (OEM) who are devoted to preventing and managing occupational injuries and exposures. OEM is the preventive medicine specialty that focuses on the health of workers, including the ability to perform work; the physical, chemical, biological, and social environments of the workplace; and the health outcomes of environmental exposures.
OEM physicians develop deep knowledge of various industries, establishing careers across a broad spectrum of sectors such as clinical care, corporate medicine, public health and regulatory sectors, academia, and research. This expertise empowers them to create policies and protocols that integrate the needs of employers and workers with guidance from NIOSH, OSHA, CDC, and other agencies. Throughout the COVID-19 Pandemic, many employers relied on OEM physicians’ unique training and expertise in return-to-work procedures, including those pertaining to epidemiology and testing procedures needed for addressing communicable diseases. In short, OEM providers can help employers get Americans back to work and keep them safe on the job during emergencies and beyond.
However, the pandemic exposed severe deficits in the U.S. public health infrastructure, with most of the workforce lacking appropriate support for workplace health and safety. The overwhelming majority of workers have no practical benefit from the expertise of OEM practitioners. Often, small and mid-sized companies lack expertise on these issues and are left to interpret complex guidance and regulations without any specialized support.
If our Nation’s employers and workers are expected to withstand and maintain essential operational capabilities and functions in the face of future emergencies, we need more OEM physicians at the ready to interpret and apply guidance and advisories from federal and state authorities in different occupational settings. We respectfully provide the following comments for your consideration in the context of PAHPA reauthorization deliberations.
Gaps in Current Activities & Capabilities
2.
Additionally, aside from currently authorized programs and activities, what gaps exist in HHS’ capabilities, and what types of activities or authorities are necessary for HHS to fulfill the intent of PAHPA and related laws?
There is a significant gap in HHS’ capability and authority to support the training and sustainment of specialized physicians, namely in the field of OEM. OEM physicians are a critical resource enabling organizations to respond rapidly and judiciously to emergent situations that may negatively affect their employees, the public, or operations.
This challenge is primarily due to a shortage of OEM physicians available to assist employers. As of 2022, there were only 3,068 Board certified OEM physicians in the U.S., with an average age of 61. This hurdle is exacerbated by a critical challenge in training new OEM physicians because, unlike most medical residency training programs, OEM programs do not routinely receive Medicare funding through CMS. Current funding through NIOSH, the VA, and HRSA falls short of total OEM training funding needs. Additionally, over time, funding inconsistency has driven the closure of OEM residency programs across the country. Unfortunately, due to the lack of funding, most OEM residency programs cannot fill their resident slots. In past academic years, OEM training programs were typically only able to fund around 50-60% of residency slots authorized by the Accreditation Council for Graduate Medical Education.
ACOEM would be happy to work with your staff to craft appropriate provisions to supplement existing statutes and authorize an evidence-based and strategic program to ensure an adequate supply of OEM physicians is available to support the U.S. workforce.
If you have any questions or need additional information, please contact Dane Farrell (
Dane@cascadeassociates.net), ACOEM’s Government Affairs Representative.
Thank you for your consideration, and we look forward to collaborating with the HELP Committee as it works toward PAHPA reauthorization.
Sincerely,
Douglas W. Martin, MD, FAADEP, FAAFP, FACOEM
President
American College of Occupational and Environmental Medicine (ACOEM)