As summer approaches, parts of the United States are already experiencing heightened wildfire activity. Fires forced evacuations in parts of Florida and Georgia in April, and the National Interagency Fire Center predicts continued above-normal fire potential along the Southeast Atlantic coast and across Florida through June. June 1 also marks the beginning of the Atlantic hurricane season. While early forecasts suggest a relatively moderate season—with 12 to 13 named storms, six expected to become hurricanes—recent history shows that seasonal risks can shift rapidly.

Preparing for these risks requires ongoing planning by hospitals and healthcare providers. This includes identifying contingencies, stress-testing protocols, and reassessing plans as new threats emerge. Natural disasters can disrupt supply chains, compromise power and communications systems, force evacuations, and drive surges in patient volume, even as staff face personal losses.

Yet even the most thorough planning has its limits, and each disaster produces new lessons. After Hurricane Harvey devastated the Houston region in 2017, Darrell Pile, chief executive of the Southeast Texas Regional Advisory Council, told The Washington Post that the storm “challenged every plan we’ve written, every resource, every piece of inventory … it just was unimaginable.”

The impact of a major disaster extends well beyond the images that capture public attention. When primary care practices close or relocate, patients with chronic and acute needs migrate to remaining facilities, placing additional pressure on hospitals operating under emergency conditions. Pharmacies facing damaged inventory, broken supply chains, and overwhelmed staff may be forced to ration medications, creating gaps in care.

A secondary surge in demand for behavioral health services may emerge weeks or months after the event and can further strain already depleted systems. These cascading effects underscore a central challenge of preparedness: the ripple effects are often as consequential as the initial event and harder to anticipate.

Vulnerabilities are not limited to immediate disaster zones. As Applied Policy noted in its white paper on strengthening domestic production of healthcare products, disruptions to manufacturing and distribution can have national implications, particularly when production is concentrated in a limited number of facilities or regions. After Hurricane Maria in 2017, damage to pharmaceutical manufacturing in Puerto Rico contributed to shortages of essential products such as IV fluids. More recently, flooding at a major U.S. manufacturing facility disrupted a significant share of domestic IV solution production, with shortages persisting for months after the event.

Federal Resources and Preparedness Requirements

The Administration for Strategic Preparedness and Response (ASPR), part of the U.S. Department of Health and Human Services, is one of several federal entities supporting healthcare providers in disaster planning and response. ASPR advances preparedness through programs and technical resources focused on sustaining operations under crisis conditions and leads federal public health and medical response coordination under Emergency Support Function #8.

Through the Hospital Preparedness Program (HPP), ASPR supports state and regional healthcare coalitions that bring together hospitals, public health agencies, emergency management officials, and other partners to plan for and respond to emergencies. These coalitions coordinate evacuation planning, resource sharing, surge capacity, and continuity of operations, and can facilitate real-time coordination of beds, staff, and supplies during an incident. ASPR also maintains the Technical Resources, Assistance Center, and Information Exchange (TRACIE), which provides planning tools, after-action reports, and operational guidance across challenges such as utility failures, patient evacuation, and supply chain disruption.

Planning is not optional. Since November 2017, Medicare- and Medicaid-participating providers and suppliers have been required to comply with emergency preparedness requirements established by the Centers for Medicare & Medicaid Services. The rule requires an all-hazards emergency plan supported by policies and procedures, a communication plan, and training and testing. Requirements vary by provider type, but the framework applies broadly, making preparedness a condition of participation in Medicare and Medicaid.

Recent CMS survey findings underscore that gaps often emerge in predictable areas: incomplete training and testing, insufficient risk assessments, and limited planning for basic subsistence needs such as power, water, and medical supplies.

Beyond preparedness requirements and technical assistance, hospitals may also draw on federal disaster relief programs following a declared emergency. FEMA Public Assistance, available after a presidential disaster declaration, can provide reimbursement for eligible costs associated with emergency response and infrastructure recovery.

Ethical and Workforce Dimensions

The ethical dimensions of disaster response are significant. The American Medical Association’s Code of Medical Ethics affirms that physicians have an obligation to provide urgent care during disasters, even in the face of elevated risk. At the same time, it recognizes a countervailing responsibility: clinicians must weigh immediate demands against their ability to continue providing care over time. The physician workforce is not unlimited.

Effective response also depends on a broader workforce than is often assumed. While public attention centers on clinicians, hospitals rely on a wide array of personnel to sustain operations.

In a survey of radiation oncology providers following California wildfires between 2017 and 2022, 29% reported staffing shortages as workers faced the same disruptions as their communities.

Instrument sterilization technicians ensure surgical tools are safe. Laboratory staff process diagnostic tests. IT teams maintain electronic systems. Environmental services staff manage sanitation and infection control under challenging conditions. Without these roles, clinical care can quickly become impossible.

Preparedness planning that focuses narrowly on clinical surge capacity may underestimate how quickly these supporting functions can become points of failure. A power outage affects not just lighting but critical equipment and systems. A shortage in environmental services can compromise infection control across an entire facility. Effective preparedness requires accounting for all operational dependencies.

Recognizing that rigid regulatory requirements can compound these challenges, federal policy includes mechanisms for flexibility when standard frameworks become unworkable.

After the Crisis: Regulatory Flexibility

As Applied Policy has previously reported, the transition from preparedness to response often involves federal waivers that provide regulatory flexibility during emergencies. Under Section 1135 of the Social Security Act, the U.S. Department of Health and Human Services may issue waivers following a declared emergency, allowing providers to adjust operations in response to disrupted conditions. These waivers require both a presidential emergency declaration and a public health emergency declaration by HHS.

Waivers may be retroactive depending on applicable guidance and can address requirements related to patient transfers, provider enrollment, and certain conditions of participation, enabling continued access to care when standard frameworks are not fully workable.

The effectiveness of these flexibilities depends on timely identification of applicable blanket waivers and, where necessary, the submission of well-supported requests for case-specific waivers. Providers that are able to navigate these processes efficiently—whether through internal expertise or with support from experienced advisors—are generally better positioned to maintain continuity of care during rapidly evolving conditions.

If your organization requires assistance in applying for an individual 1135 waiver to address unique challenges in care delivery during a PHE, please contact a member of Applied Policy’s healthcare services team.