Dear Secretary Becerra and Director Walensky:
Thank you for your ongoing efforts to end the pandemic. We write regarding your agency's
implementation of the American Rescue Plan Act of 2021's Title II, Subtitle F, Section 2501 --
funding for public health workforce (Section 2501), and the integral role the Department of
Health and Human Services (HHS) and the Centers for Disease Control and Prevention (CDC)
will play in using "$7,660,000,000
to carry out activities related to establishing, expanding,
and sustaining a public health workforce
" Additionally, Title XI, Section 11001(a)(1)(G) --
Indian Health Service, public health workforce (Section 11001) provides $240,000,000 for the
Indian Health Service (IHS) to conduct similar activities in indigenous communities. We were
proud to work with Congressional leadership to ensure that Sections 2501 and 11001 were
aligned as closely as possible to S. 32 of the 117th Congress -- Health Force, Resilience Force,
and Jobs to Fight COVID-19 Act (Health Force), but we recognize that restrictions in the Budget
Reconciliation process did not afford the precision and detail required of a legislative and
programmatic endeavor on this scale. Therefore, as you implement such sections of the
American Rescue Plan Act of 2021 and work to deliver on the public health jobs promise made
by President Biden, we respectfully request your consideration of the Congressional intent of
Health Force, and its commitment to health equity, sustainability, and the creation of new
careers in health for underserved communities.
The national COVID-19 vaccination and surveillance challenge, existing public health needs,
and a growing urgency to address racial health disparities have underscored the necessity for the
Health Force; the purpose of which is to recruit, train, and employ a standing workforce of
Americans to respond to the COVID--19 pandemic in their communities, provide capacity for
ongoing and future public health care needs, and build skills for new workers to enter the public
health and health care workforce. This public health jobs program is inspired by the Depressionera Works Progress Administration which similarly tapped thousands of job seekers to help the
nation recover from a sharp economic downturn. Health Force members would be recruited from
and hired to work in their local communities, ensuring cultural competence and creating local
jobs. They would perform vital tasks like vaccine outreach in the near term, and in the long-term
they would build our public health capacity by improving baseline health outcomes and reducing
need for costly care, especially for low-income and underserved communities.
As you work to implement Sections 2501 and 11001 of the American Rescue Plan Act of 2021,
we respectfully request your consideration of the following policies:
Organization and Administration
We respectfully recommend that the Health Force be organized and administered by the
Secretary of Health and Human Services (HHS) which, in accordance with Sections 2501 and
11001, would include awarding grants, contracts, or entering into cooperative agreements for the
recruitment, hiring, training, managing, administration, and organization of the Health Force to
States, localities, territories, Indian Tribes, Tribal organizations, urban Indian health
organizations, health service providers to Tribes, or Native Hawaiian health organizations (the
"Funded Entities"). In addition, we recommend that CDC ensure that State, county, local health
departments, agencies, and community-based organizations, including community health centers
and clinics, receive funding from Funded Entities or directly from the CDC for the recruitment,
hiring, training, managing, administration, and organization of the Force, as appropriate.
Funding Allocations
We respectfully recommend the inclusion of a funding allocation formula aligned with S. 32 --
Health Force that provides guarantees of equitable funding for all types and sizes of funded
entities.
We recommend a formula funding allocation that ensures:
Of funding awarded to States and territories, 60% would be awarded proportional to
population size, 20% would be awarded according to burden of disease and disability,
and 20% would be awarded based on the number of jobs lost over the preceding 12
months in each State or territory as a proportion of all jobs lost nationally during that
timeframe.
Of funding awarded to States and territories, at least 40% would be allocated for State
health departments and at least 40% would be allocated for county and other local
health departments within the State.
Of funding awarded to Tribes through IHS, 80% would be awarded proportional to
population size and 20% would be awarded according to burden of preventable
disease and disability.
As authorized by the CDC already, Funded Entities may make subawards to local partners,
including community health centers, labor organizations, labor-management partnerships, and
other community-based and nonprofit organizations.
We also recommend making efforts to make clear that these funds would be used to supplement,
not supplant any existing funding for Indian Tribes, Tribal organizations, urban Indian health
organizations, health service providers to Tribes, Native Hawaiian health organizations, States,
territories, State health departments, county and other local health departments.
We also recommend that these funds be awarded on an up-front grant basis, not as a
reimbursement, particularly for any funds to be passed through to community-based
organizations.
Focal Communities
We respectfully recommend a "Focal Communities" definition that would be used to prioritize
Health Force funding and activities. Funded Entities would dedicate a substantial proportion of
Health Force members and resources to addressing the needs of focal communities. To be
designated as a focal community, a community would:
● Bear a disproportionate burden of disease; or
● Be identified as a "most vulnerable" community according to the CDC's Social
Vulnerability Index; or
● Be identified as a "high poverty" area, which includes census tracts with poverty rates of
25 percent or higher, as defined by the Workforce Innovation and Opportunity Act; or
● Be identified as a "high unemployment" area, which includes census tracts with
unemployment 150 percent or higher than the national unemployment rate, as determined
by the Bureau of Labor Statistics based on the most recent data on the total unemployed,
the U-6 unemployment measure or similar measure, available on the date of enactment of
this Act; or
● Be designated as a Health Professional Shortage Area, Medically Underserved Area, or
Medically Underserved Population; or
● Communities with limited English language proficiency, determined at the discretion of
State, county, or local health departments.
Service
We respectfully request consideration of minimum service requirements for Health Force, such
as ensuring membership is not restricted based on education or citizenship status. The Health
Force would support recruitment efforts for personnel who are from or reside in the locality in
which they would serve, including efforts to recruit among "focal communities" as well as
dislocated workers, individuals with barriers to employment, veterans, new entrants in the
workforce, underemployed or furloughed workers, graduates and students from Historically
Black Colleges and Universities, Tribal Colleges and Universities, Hispanic Serving Institutions,
and historically marginalized populations. We request that you consider working with state labor
offices to share information about Health Force opportunities with individuals applying for or
receiving unemployment benefits.
Hiring Preference
We respectfully request that you consider giving hiring preference to individuals who are
dislocated workers, individuals with barriers to employment, veterans, new entrants in the
workforce, underemployed or furloughed workers, or community-based nonprofit,
paraprofessionals in harm reduction and similar fields, or public health or health care
professionals, from focal communities as described above, or unemployed or underemployed
individuals. We recommend that first priority be given to previous employees of Funded Entities or subawardees who were recently furloughed, laid off, subject to a reduction in force, on leave,
or have recall rights.
We respectfully request that to the extent feasible, Health Force members be recruited from and
serve in their home communities and that they be physically co-located with health departments
or other eligible organizations. According to local needs, Health Force members could be
physically co-located with local public health, health care, and community-based organizations,
including community health centers, as determined appropriate by funded entities.
Training
We respectfully request the consideration of a robust and specialized job training for Health
Force members, including those described in Sections 2301 and 11001 and the following:
● Training: We recommend that within 90 days, your office identify and, as necessary,
develop evidence-informed training resource packages to provide a baseline set of
knowledge and skills necessary to conduct the full complement of Health Force activities
described in S. 32 -- Health Force and in Sections 2301 and 11001. Funded Entities could
determine which members would be provided with additional training.
● Specialized Training: We recommend that your office elect to establish divisions of
Health Force members who receive specialized, comprehensive training.
● Requirements: We recommend that the training program:
o Be adaptable by Funded Entities to meet local needs;
o Be implemented as quickly as possible;
o Be distance-based eLearning accessible by smartphone and other devices;
o Include refresher training and regular and frequent intervals;
o Incorporate components on personal safety and health privacy and ethics;
o Leverage existing training and certification programs.
● Miscellaneous: We recommend that when deemed necessary, your office:
o Recommend training that includes face-to-face interaction;
o Collaborate with a variety of organizations to develop and implement training;
o Develop training and communications materials in multiple languages, as defined
by the Affordable Care Act's Section 1557.
● Payment: We recommend that individuals be paid for each hour they spend in training.
● Career Growth: We strongly recommend that Funded Entities support Health Force
members' career growth, including by providing disaster relief employment, additional
training activities, and additional opportunities for Health Force members to maintain
employment after the COVID--19 public health emergency has concluded.
Health Force Member Compensation
We respectfully request that members of the Health Force be full-time and paid directly by
funded entities and their subawardees using funds provided by the CDC and IHS. We
recommend that all Health Force members, including supervisors, be paid not less than the
higher of 1) a $15 an hour wage or 2) the prevailing wage rate for the applicable area and
occupation in accordance with the Service Contract Act. We also recommend that all Health
Force members, including supervisors, receive prevailing benefits in accordance with the Service
Contract Act. We recommend working with the Department of Labor to issue a nonstandard wage determination, subject to periodic revision. We also recommend working with the
Department of Labor to establish minimum wages and fringe benefits for each class of Health
Force members in accordance with the prevailing rates for those positions or, where a collectivebargaining agreement is in effect, in accordance with the rates provided for in the agreement. We
recommend that Health Force member compensation include health, retirement, and paid family
and medical leave benefits. In addition, we recommend making clear that these labor standards
are a minimum standard, and states retain the discretion to impose higher labor standards.
Supplies and Equipment
We respectfully request that Funded Entities be provided all necessary supplies and equipment
for Force Members, and that funded entities may use awarded funds to pay for such supplies and
equipment.
Activities to Respond to the COVID--19 Pandemic
Section 2501 details that this funding "
shall be used for the recruiting, hiring, and training of
individuals-- to serve as case investigators, contact tracers, social support specialists,
community health workers, public health nurses, disease intervention specialists,
epidemiologists, program managers, laboratory personnel, informaticians, communication and
policy experts, and any other positions as may be required to prevent, prepare for, and respond to
COVID--19
"
We also respectfully recommend that, for the duration of the COVID-19 Public Health
Emergency and future public health emergencies, Health Force members be trained and
employed to:
● When available, support the administration of diagnostic, serologic, or other COVID--19
tests and vaccinations;
● Provide support that addresses social, economic, behavioral and preventive health needs
for individuals affected by COVID-19, including those who are asked to voluntarily
isolate or quarantine; and
● Carry out or assist with other activities as determined appropriate by funded entities.
We also recommend that the specific naming of community health workers, social support
specialists, and case investigators in Section 2501 be backed by guidance to ensure these
essential community-based roles are in alignment with best practices for their specific roles.
Activities Post-Emergency
We respectfully and strongly recommend that, after the COVID-19 Public Health Emergency
concludes, Health Force members be trained and employed to continue carrying out and assisting
with relevant emergency activities, and also:
● Carry out or assist with "emergency" activities described above and elsewhere in this
letter;
● Provide support services, including but not limited to:
o Expanding public health information sharing, including by sharing public health
messages with community members and organizations; Helping community members address social, economic, behavioral health, and
preventive health needs using evidence-informed models and in accordance with
existing standards;
o Sharing community-based information with State, local, and Tribal health
departments to inform and improve health programming, especially for hard-toreach communities; and
o Promote linkages to other Federal, State, and local health and social programs.
● Carry out or assist with other activities as determined appropriate by the Director of CDC
and/or funded entities.
Coordination and Collaboration
We respectfully recommend that your office facilitate coordination and collaboration between
the Health Force and other national public health services programs, including the Public Health
Service and Medical Reserve Corps, as well as the Federal Emergency Management Agency's
Resilience Force. We also respectfully request consideration of the convening of a stakeholder
advisory group comprised of the leadership of: other national health service programs; other
relevant Federal offices and agencies; and leaders representing funded entities. We suggest the
group meet yearly to provide guidance for the programmatic success and longevity of the Health
Force and that such guidance be codified in an annual report of recommendations and evidenceinformed practices to be shared publicly.
We also respectfully request guidance to Funded Entities that would ensure coordination and, as
appropriate, collaboration between the Health Force and local public health, health care, and
community-based organizations, to ensure complementarity and further strengthen the local
public health response. We also respectfully request consideration of guidance for each Funded
Entity on the convening of their own stakeholder advisory group comprised of community
leaders, health officials, labor organizations, local advocates, individuals directly impacted by
COVID-19 and other key stakeholders to meet on a regular, recurring basis to provide formal
guidance, including priority setting and funding guidance, for the programmatic success and
longevity of the Health Force. We also respectfully request consideration of guidance making
clear that funded entities may enter into agreements or compacts for cooperative effort and
mutual assistance.
Monitoring
We recommend that your office develop a performance monitoring template for Funded Entities
to adapt and use. The template would require the reporting of the number of Health Force
members hired, the role hired into, and the demographic characteristics of Health Force
members. Funded entities would share these data with CDC on a regular, recurring basis and
these data would be made publicly available.
Learning and Adaptation
We respectfully request that your office, in consultation with the Advisory Group and local
advisory groups, develop a learning and evaluation component to identify successful components
of local activities that may be replicated, to identify opportunities for continuing education and
career advancement for Health Force members, to evaluate the degree to which the Health Force created a pathway to longer-term public health and health care careers among Health Force
members, and to identify how the Force impacted the health knowledge, behaviors, and
outcomes of the community members served. Results of this learning would be made publicly
available.
Reporting
We respectfully recommend that within 180 days after the end of each fiscal year, your office
would submit to Congress a report which would contain--
● A description of the progress made in accomplishing the objectives of the Health Force;
● A summary of the use of funds during the preceding fiscal year;
● A description of the application of the funding formula;
● Demographic information about the Health Force, including race/ethnicity, sexual
orientation, gender identity, and disability demographics.
● The number of individuals recruited, hired, and retained;
● The number of Health Force members who transition to other public health roles;
● The number of Health Force member who were unemployed prior to being hired;
● The number of Health Force members who continue to be employed within 6 months and
1 year of hire and within 6 months and 1 year of the conclusion of the COVID-19 public
health emergency;
● Any information on the outcomes and impact of Health Force on health and employment.
Financial Reporting
We respectfully recommend that within 45 days of the CDC receiving public health workforce
funds from the American Rescue Plan Act, and every 60 days thereafter for the first 12 months
after such date, the Director would submit to Congress a report describing awards made, funding
obligated, and expenditures to date. We recommend that the report provide details on the
application of the funding allocation formula specified in this letter and in S. 32 -- Health Force
of the 117th Congress, including the amount awarded to each funded entity.
Sustaining the Public Health Workforce
We respectfully request that the CDC discourage the use of precarious, contingent employment
practices and instead encourage long-term employment where practical to address the long-term
public health impacts of COVID-19. The American Rescue Plan Act of 2021 and S. 32 -- Health
Force both include language that makes clear the intent for these roles to be sustained, and any
agency guidance or regulation should ensure this principle throughout.
Additional sections of the American Rescue Plan Act of 2021, such as those pertaining to vaccine
administration in Section 2301 and those pertaining to community health centers in Section 2601,
are written broadly enough to enable hiring of public health workers similar to Health Force
members. We recommend that American Rescue Plan Act of 2021 funding from other sections
being used for hiring public and community health workers also adhere to the recommendations
and principles described in this letter. We recognize that you, the CDC, and your partners are tasked with the unprecedented challenge
of "
establishing, expanding, and sustaining a public health workforce" for which the United
States is long overdue. Our Congressional coalition stands ready to collaborate with you and
your team. We will work tirelessly to provide the resources and support necessary to accomplish
this ambitious, necessary goal of a public health workforce to end this pandemic and prepare us
for all future health challenges. We are grateful for all that you and the CDC have already done,
and we look forward to working together to establish, expand, and sustain a Health Force.