This year, thousands of individuals in Southern California were impacted by the Palisades Fire and Eaton Fire. The fires were the second and fourth most destructive in the state's history.1 In 2024, millions of individuals in the southeastern United States were impacted by Hurricanes Helene and Milton. These hurricanes made landfall less than two weeks apart, establishing a new record for the shortest interval between two significant hurricanes in Florida.2 The Southern California wildfires and Hurricanes Helene and Milton exemplify the pattern of increasingly severe and frequent natural disasters attributed to a changing climate. Such climate-related disasters have profound implications for healthcare systems, underscoring the necessity for coordinated efforts between federal and state governments to ensure the continuity of healthcare services and access to medical care. As a result of the Southern California wildfires, over 700 people were evacuated from nursing homes and other care facilities.3 In Florida alone, over 350 healthcare facilities were evacuated as a preventative measure against Hurricane Milton.4 Hundreds of other healthcare facilities throughout the region faced evacuations, closures, and damage as result of the hurricanes. Preparedness and swift response measures at all levels of government are essential to safeguard lives in the face of natural disasters.
Federal Level Response
For the affected areas to receive federal funding for disaster relief, governors must request assistance from the federal government. From there, the President can decide whether to grant, or not grant, supplemental assistance by issuing "major disaster" and "emergency" declarations under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (referred to as the Stafford Act – 42 U.S.C. 5721 et seq.).5 Emergency declarations can be made before or after the disasters occur and they trigger federal aid aimed at lessening or averting the threat of a catastrophic incident. Major disaster declarations are issued after catastrophes occur. These declarations authorize federal agencies, such as the Federal Emergency Management Agency (FEMA) and the Department of Health and Human Services (HHS), to provide supplemental recovery assistance at the state and local levels.
Following Former President Biden's emergency declarations for the Southern California Wildfires6 and Hurricanes Helene and Milton,7 HHS Secretary Xavier Becerra declared a Public Health Emergency (PHE) in affected states to address the public health impacts of these climate disasters.8 Declarations are retroactive to the start of the disaster and last for the duration of the emergency or 90 days. The declaration of a PHE is a critical step in enhancing healthcare response during natural disasters. The Declaration of PHEs allow HHS to access reserve funds to allow for a rapid response to immediate health needs. HHS can grant waivers and flexibilities for adapting healthcare regulations to meet emergency needs. For instance, there are certain requirements within the HIPAA Privacy Rule that are waived during a PHE, which allow patient information to be shared to assist in disaster relief efforts and to assist patients in receiving the care they need. During the Southern California Wildfires9 and Hurricanes Helene and Milton, the Centers of Medicare & Medicaid Services (CMS) also used blanket waivers to provide flexibilities for hospitals, long-term care facilities, skilled nursing facilities, hospice, telehealth providers and home health agencies.10 Payment systems also receive adjustments during a PHE. In response to the natural disasters, the Merit-Based Incentive Payment System (MIPS), which connects Medicare payments to a physician's performance, implemented the Automatic Extreme and Uncontrollable Circumstances (EUC) Policy to provide relief to clinicians in the designated affected counties.11,12 Physicians can request reweighting of performance categories if they encounter extreme circumstances outside of their control.
Through Former President Biden's emergency and major disaster declarations, those affected by the Southern California wildfires may receive a one-time $770 payment.13 In a press release on January 11, 2025, FEMA announced that former President Biden approved the 100% cost share for Public Assistance Categories A and B for 180 days. As a result, FEMA is able to fund 100% of the cost lifesaving and life sustaining activities the state and local governments take, including fire suppression efforts.14
In 2024, the Biden Administration approved more than $1.2 billion in direct FEMA assistance to survivors of Hurricanes Helene and Milton.15 Former President Biden approved major disaster declarations in six states – Georgia, North Carolina, South Carolina, Tennessee, Florida, and Virginia – affected by Helene and a major disaster declaration for Florida following Hurricane Milton. An additional $1.1 billion was allocated to FEMA for debris removal and emergency protective measures.16 FEMA personnel remained on the ground following the hurricanes to conduct damage assessments, coordinate with local officials, and help individuals apply for disaster assistance programs.
Federal agencies work in tandem with one another to ensure a rapid and comprehensive response following an emergency declaration. During natural disasters, HHS' Administration for Strategic Preparedness and Response (ASPR) works alongside FEMA to send first responders, medical equipment, and supplies into areas of need through coordination with state and local authorities.17
Effective state-level natural disaster response requires collaboration with federal agencies and local authorities. In California, Governor Gavin Newsom worked with the Trump Administration to support recovery and rebuilding efforts from the Southern California Wildfires as well as protect communities from potential mudslides.18 In the case of Hurricane Helene, Governor Roy Cooper of North Carolina declared a State of Emergency ahead of the hurricane to prepare for severe weather impacts.19 In response to this declaration, the North Carolina state government deployed equipment, personnel, and resources to support impacted communities. In Florida, Governor Ron DeSantis implemented state preparedness efforts for Hurricane Milton. As a part of these efforts, Florida's Agency for Health Care Administration (AHCA) made nearly 700 provider calls for Hurricane Milton preparation ahead of landfall.20 The AHCA found that 352 health care facilities in Florida reported evacuation. In the days prior to the hurricane's landfall, AHCA engaged in daily discussions with the Florida Hospital Association and Florida Healthcare Association to ensure that nursing homes, assisted living facilities, and hospitals were ready, and their needs were met in advance of the storm.21
Since the process of obtaining federal assistance in the wake of a natural disaster is at the sole discretion of the President of the United States, understanding the Trump Administration's previous disaster relief funding may serve as an indicator of the current Administration's spending plan. In 2017, Hurricane Maria caused widespread devastation in Puerto Rico, killing an estimated 3,000 people. The Trump Administration was found to have delayed a more than 20-billion-dollar hurricane relief package for Puerto Rico in a report from the Department of Housing and Urban Development.22 In contrast to Hurricane Maria, the Trump Administration rapidly approved a historic FEMA response for Texas following Hurricane Harvey.23 The Trump Administration's prior inconsistency in disaster relief may cause state and local level actors to be apprehensive about aid packages for future catastrophes. On January 24, 2025, the Trump Administration established the FEMA Review Council to advise on the existing ability of FEMA to capably and impartially address disasters occurring within the United States.24 The creation of this council comes after several remarks from members of the Trump Administration suggesting shifting the responsibility of disaster response to states. 25 Furthermore, on March 19, 2025, President Trump signed an Executive Order (EO) titled "Achieving Efficiency Through State and Local Preparedness."26 The EO aims at decentralizing disaster response management by empowering state and local governments, thereby reducing federal involvement. The EO mandates the creation of a National Resilience Strategy by the Assistant to the President for National Security Affairs and the Assistant to the President for Economic Policy, which will seek to streamline federal policies, reduce bureaucratic complexities, and promote efficiency. The Trump Administration's focus on improving government efficiency and cutting waste will continue to impact the country's natural disaster relief efforts. The steps taken by this administration are a significant shift from long-standing policies focused on disaster relief and its impact on healthcare industry participants. Our team will continue to monitor any updates that impact our clients and all healthcare entities.
Footnotes
1. How the Los Angeles Fires Compare to Historic Wildfires | Time
2. Hurricane Helene Milton | CWS
3. Doctors, Nurses Press Ahead as Wildfires Strain Los Angeles Health Care | California Healthline
5. FEMA's Disaster Declaration Process: A Primer
7. President Biden's emergency declaration
8. Determination that a Public Health Emergency Exists | Hurricane Helene – FL; Determination that a Public Health Emergency Exists As a Result of the Consequences of Hurricane Helene in Geogia; DETERMINATION THAT A PUBLIC HEALTH EMERGENCY EXISTS; DETERMINATION THAT A PUBLIC HEALTH EMERGENCY EXISTS; HHS Secretary Xavier Becerra Declares Public Health Emergency for Florida to Aid Health Care Response to Hurricane Milton | HHS.gov
10. Standard Waiver List for Hurricanes and Natural Disasters v. Sept 2021 (docx)
11. MIPS Extreme and Uncontrollable Circumstances (EUC) Exception
12. 2025-MIPS-Automatic-EUC-Policy.pdf
13. California Wildfire Victims May Receive a One-Time $770 payment. | CNBC
16. Id.
19. https://governor.nc.gov/executive-order-no-315/open
21. Id.
22. HUD OIG Final Report_2019SU008945I.pdf
23. Historic Disaster Response to Hurricane Harvey in Texas | FEMA.gov
24. Council To Assess The Federal Emergency Management Agency | WHITEHOUSE.gov
26. Achieving Efficiency Through State and Local Preparedness | WHITEHOUSE.gov
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