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Understanding Tom Frieden’s Proposed HDO

September 4, 2020

In a May column (here), I talked about a proposal to create a Health Defense Operations (HDO) fund. The gist of the article was that such a fund might provide a way to break an impasse over the budget cap for Non-Defense Discretionary (NDD) for FY 21.

What was lost in that budget-oriented column was a fuller explanation of what the HDO is and how it might affect FDA funding.

The HDO fund is modeled on the Overseas Contingency Operations (OCO) fund, which already exists and is off-budget. The OCO pays for war-related costs (and some other defense needs) that are beyond what can be paid for in the on-budget DOD appropriation. The premise of the OCO was that you can’t fight wars with monies that are dependent on budget cycles. You have to bear the cost of what is needed to win and you can’t say: no more bullets until October arrives with next year’s funds.

The concept of HDO is parallel to OCO — our nation is fighting a war against bioterrorism and agri-terrorism, as well as newly-emergent infectious diseases. HDO needs to be off-budget so our the efforts don’t slacken waiting for the next fiscal year and the monies cannot be repurposed for programs other than health defense. Of course, battling newly-emergent infectious diseases seems far more urgent than it did 10 months ago.

The HDO fund was brought up at a Labor-HHS appropriation subcommittee hearing in testimony by Thomas Frieden, former head of CDC, and is backed by a number of former health leaders (more information available here). Subcommittee Ranking Member Cole joined Democrats in expressing interest in HDO, creating the possibility of bipartisan support.

As described here, the HDO proposal would take $13 billion worth of existing programs in FY 20 (the base) and add about $11 billion more to those programs in FY 21, creating an annual HDO of about $24 billion in off-budget funds. All of FDA’s FY 20 food safety budget ($1.425 billion) would go into the HDO. For FY 21, that amount would increase by $625 million to just a tad above $2 billion. FDA’s medical products programs were not part of the HDO as proposed by Dr. Frieden.

Including food safety as part of health defense makes sense, but it’s hard to understand the omission of FDA’s vaccines and medical countermeasure programs (among others).

Thanks to Research!America, I was able to get some clarification. At one of their webinars, Dr. Frieden acknowledged that more of FDA would probably need to be included. At another webinar, Representative Cole recognized FDA as needing consideration if the HDO concept were to advance.

If HDO interests you, let me know what you think.

Editorial Note: The Analysis and Commentary section is written by Steven Grossman, Deputy Executive Director of the Alliance for a Stronger FDA.

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