By Tara Gibson - July 15, 2020
Answering the question what are vulnerable populations is complicated due to the use of different terminologies, frequently-changing definitions, and at-risk individuals having different needs in different circumstances.
Planning for the needs of vulnerable populations as mandated by the CDC's National Standards for State, Local, Tribal, and Territorial Public Health, the National Health Security Strategy (NHSS) and the Pandemic and All-Hazards Preparedness and Advancing Innovation (PAHPAI) Act 2019 requires public health agencies to identify vulnerable populations, establish their needs, and determine how those needs can be best met in a number of different circumstances.
However, when it comes to identifying vulnerable populations, what are vulnerable populations? Different agencies not only use different terminologies (i.e. vulnerable, at-risk, having access or functional needs, or - rarely these days - having special needs), but also define vulnerable populations differently. It is also the case that definitions of vulnerable populations frequently change.
For example, the definition of vulnerable individuals in NHSS and PAHPAI differs from the CMIST-based definition of vulnerable individuals (Communication, Medical Care, Independence, Supervision, and Transportation) used in the National Standards for State, Local, Tribal, and Territorial Public Health, the previous National Health Security Strategy from 2015 to 2018, and in the National Response Framework (NFR) on which most public health agencies' definitions are based:
Access and functional needs refer to persons who may have additional needs before, during, and after an incident in functional areas, including but not limited to maintaining health, independence, communication, transportation, support, services, self-determination, and medical care. Individuals in need of additional response assistance may include those who have disabilities, live in institutionalized settings, are older adults, are children, are from diverse cultures, have limited English proficiency or are non-English speaking, or are transportation disadvantaged.
To further complicate the issue, other public health agencies expand this definition. The Department of Health and Human Services includes pregnant women, chronic medical disorders, and pharmacological dependency in its criteria for what are vulnerable populations; while the Association of State and Territorial Health Officials also includes economically disadvantaged citizens and individuals lacking a support system. The CDC expands the CMIST-based definition the most to include:
This is also a complicated question to answer because not only could a considerable percentage of the population be considered vulnerable under one or more of the definitions, but conditions change (i.e. pregnancy is not permanent), and what may make an individual vulnerable in one circumstance may not apply in another - for example transportation for oxygen tanks is an important consideration during an evacuation order, but not when a stay-at-home order is in force.
One solution would be for public health agencies to synchronize vulnerable population databases with healthcare databases; but while it is possible for some public health agencies to extract some data from healthcare databases under the Health Insurance Portability and Accountability Act (HIPAA), the amount of data extracted would be insufficient to serve its purpose. Furthermore, the issue exists of how public health agencies could later share data without patient authorization in the event of an emergency.
Some state and local public health authorities have overcome HIPAA restrictions by building vulnerable population databases using data from non-HIPAA Covered Entities (i.e. faith-based organizations) or by encouraging HIPAA Covered Entities to obtain authorization from patients for their protected health information to be shared. While this results in more complete databases, vulnerable individuals who are not part of an established support system tend to be overlooked. It is also the case that some state and local public health authorities have had to limit inclusion criteria for vulnerable populations in order to manage their databases.
These types of limited vulnerable population databases have multiple issues. Not only does the inclusion criteria limit their effectiveness, some eligible individuals are reluctant to register due to data privacy concerns, and some jurisdictions maintain details of vulnerable individuals on paper or on Access or Excel databases - making it virtually impossible to search data to address access and functional needs by circumstance, or to share data with other public health agencies in the same or in neighboring areas.
A summary of the issues discussed so far illustrates the difficulties state and local public health agencies have to overcome in order to protect vulnerable populations:
In addition to some eligible individuals being reluctant to register on a vulnerable needs database due to data privacy concerns, some are also reluctant to register because of self-identifying their vulnerabilities. For some vulnerable members of the community - or their families or carers - this is hard to do emotionally, and it could result in large segments of the at-risk population deliberately avoiding a service intended to help them when they are unable to help themselves.
The solution to this issue is to not market the database as a vulnerable needs database, but rather as an online secure emergency assistance service similar to the trusted Smart911 service provided in many parts of the country. The Smart911 service invites all individuals - regardless of whether they are vulnerable or not - to create safety profiles in which medical conditions can be recorded, as can mobility issues and other information that would be important for first responders to know in an emergency.
The database can be configured to include questions that relate to individuals with functional and access needs, or to include a checkbox which lists the different types of emergency assistance available in different types of emergency scenarios. This will enable public health agencies to segment the database according to medical condition or assistance required in order to identify the level of assistance required by vulnerable members of the community in different scenarios.
As part of the Smart911 service, users can also sign up to receive alerts from the National Weather Service and local public safety agencies. These can be received via SMS text - or, if the user downloads the Smart911 app - via push notifications. State and local public health agencies can use this capability to send targeted messages to specific groups of individuals before emergencies occur, or during/after emergencies to check on their wellbeing and enquire whether they require any further assistance.
Other benefits of using a service similar to Smart911 to comply with the CDC's National Standards, NHSS, and PAHPAI include:
To find out more about implementing a service similar to the Smart911 service to act as a vulnerable population database, do not hesitate to get in touch.
Tara is a Marketing Coordinator on the Rave Mobile Safety marketing team. She loves writing about all things K-12, State & Local, Higher Ed, Corporate, and Healthcare, and manages the Rave social media channels. When she's not working, she's taking care of her smiley, shoe eating, Instagram-famous fur baby, Enzo!
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