Health Care Closed Points of Dispensing

On This Page

Understanding Points of Dispensing
Planning for Health Care Closed Points of Dispensing
CDC Closed POD Planning Resources
NACCHO Closed POD Partnerships Program
Community Closed POD Resources
Legal Considerations for Closed PODS

Understanding Points of Dispensing

Points of dispensing (POD) are community locations at which state and local agencies dispense and administer medical countermeasures (MCMs) to the public. MCMs such as vaccines, antiviral drugs, antibiotics, antitoxins, and chemical antidotes are used to effectively prevent, mitigate, or treat adverse health effects of an intentional, accidental, or naturally occurring public health emergency.[1]

To aid in rapidly dispensing MCMs, the local public health department will plan on using two types of PODs, open and closed. Open PODs are typically located at public locations such as arenas, community centers, or schools. These locations are often operated by local public health agencies and are where they dispense or administer MCMs to the public. Closed PODs are sites staffed and managed by organizations and agencies (both public and private) to dispense MCMs only to their own populations while continuing operations during a public health emergency. Open and closed PODs can and should be used simultaneously.

To learn more about the concepts related to MCM dispensing see Medical Countermeasures (MCM) and Points of Dispensing (POD) Basics fact sheet.

Planning for Health Care Closed PODs

Engaging community health care partners to manage and operate closed PODs can augment public health operations and strengthen community preparedness. Local public health agencies can collaborate with health care facilities to engage them in closed POD planning. Health care organizations that function as closed PODs may provide medication to their staff, family, patients and residents. Doing so may help ensure that their workforce can continue operations during a public health emergency and reduce the population at open PODs.

The CDC video, Taking Care of Business, describes how organizations benefit from functioning as closed PODs.

Planning for closed PODs is similar across various types of organizations. The links below provide information and resources health care organizations may find useful while planning for closed PODs, as well as a primer on MCMs and closed PODs.

Considerations specific to health care agencies can be found in the First Steps in Planning for Closed Point of Dispensing Operations planning aid. The Becoming a Closed Point of Dispensing (POD) Partner fact sheet is designed to help health care leaders understand the benefits of having their organizations participate in jurisdictional closed POD programs.

The Closed Point of Dispensing (POD) Roles and Responsibilities fact sheet outlines public health and health care organizations’ roles in establishing health care closed PODs. A key point to remember is that planning for closed PODs is an ongoing process that requires ongoing commitment and engagement from both health care and public health agencies.

[1] 2016 Public Health Emergency Medical Countermeasures Enterprise (PHEMCE) Strategy and Implementation Plan. 2016. U.S. Department of Health and Human Services.

Click on the following tabs to access resources.

The Strategic National Stockpile (SNS) manages medical countermeasures at the federal level to support a response to a public health threat. If a state experiences a health threat, the governor can request SNS resources if state and local jurisdictions do not have the resources to meet the needs of the response. In coordination with the affected jurisdiction, the U.S. Department of Health and Human Services makes the decision whether to deploy SNS assets or other assistance to the affected state. The state will coordinate with local jurisdictions to distribute the MCMs from SNS to affected areas. For years, state and local officials have worked together to develop plans to receive and distribute MCMs. In many communities, health care organizations play a critical role in ensuring that MCMs reach the affected population.

The following resources developed by CDC and other federal agencies may be useful when developing a closed POD plan. Closed POD planning should be coordinated with local public health departments.

CDC
- Public Health Emergency Preparedness and Response Capabilities: National Standards for State, Local, Tribal, and Territorial Public Health
- Point of Dispensing Standards
Agency for Healthcare Research and Quality (AHRQ)
- Community-Based Mass Prophylaxis: A Planning Guide for Public Health Preparedness
Food and Drug Administration (FDA)
- Medical Countermeasures Initiative
Federal Emergency Management Agency (FEMA)
- IS-26: Guide to Points of Distribution

Additional information and tools related to closed POD planning can be found in CDC’s Online Technical Resource and Assistance Center (On-TRAC). In addition, On-TRAC provides peer-to-peer discussion boards where users can share best practices and lessons learned. Health care organizations can coordinate with local public health departments to access On-TRAC resources.

The National Association of County and City Health Officials (NACCHO) has materials available for download on its website. The materials are designed for businesses, faith-based and community-based organizations, colleges and universities, and federal agencies. This material aids them in partnering with their local health departments as closed PODs for mass dispensing of medical countermeasures (MCMs) to employees, family members, and clients. Documents are organized in three separate folders focused on training, planning, and response.

The training resources consist of a training plan and a sample just-in-time training presentation.
The planning resources consist of checklists and procedures to aid in planning for the activation and deactivation of a Closed POD operation.
The response resources consist of checklists and worksheets designed to aid in conducting closed POD operations.

The following resources were created by health departments across the country and may be useful when working on a closed point of dispensing (POD) plan.

Alabama Department of Public Health Closed Points of Dispensing Resources
Arizona, The University of Arizona Points of Dispensing Pocket Guide
California, Alameda County, POD Training
California, Orange County, Point of Dispensing Resources
Kansas Department of Health Standard Operating Guides
Minnesota Department of Health web page dedicated to Medical Countermeasures
Minnesota, Saint Paul-Ramsey County Public Health and Minneapolis Department of Health and Family Support Closed Point of Dispensing Guide
Minnesota, The University of Minnesota Center for Infectious Disease Research and Policy (CIDRAP) web page devoted to Public Health Best Practices related to Mass Dispensing
Minnesota, The University of Minnesota Closed POD (Point of Dispensing) Partnership Training
Missouri Department of Health and Senior Services web page on the Strategic National Stockpile
New Mexico Department of Health Point of Dispensing (POD) Operations Guide
New York State Department of Health POD Training
North Carolina, Mecklenburg County, Closed Point of Dispensing (POD) Toolkit
Ohio, Hamilton County, Closed POD Planning Kit for Mass Prophylaxis or Mass Inoculation
Ohio, Summit County, Closed POD Planning Workbook (see Resources-Links tab)
Ohio, Toledo-Lucas Health Department, Community Immunity Points of Dispensing Project
Cities Readiness Initiative (CRI) Northwest Mass Prophylaxis/Point of Dispensing (POD) Operations Field Training Guide
Oregon Public Health Division Mass Prophylaxis: Point of Dispensing (POD)/Field Operations Guide (FOG)

Do you know of a resource that is not listed? If so, please send an e-mail to healthcareprepared@cdc.gov.

Disclaimer: Web addresses of nonfederal organizations are provided solely as a service to readers. Provision of an address does not constitute an endorsement of this organization by CDC or the federal government, and none should be inferred. CDC is not responsible for the content of other organizations’ webpages.

The Public Readiness and Emergency Preparedness Act (PREP), Public Health Service Act (PHSA), and emergency use authorities, provide legal protections for individuals and organizations during public health emergencies. These laws facilitate public and private sector response to a public health threat by providing

Flexible powers for rapid response
Limits on responder liability
Shifts in situational standards of care and professional scopes of practice
Waivers on certain regulatory provisions

The Legal Issues for Healthcare Providers and Their Attorneys fact sheet introduces legal protections during public health emergencies.

The extent of these legal protections depends on the conditions associated with the declared emergency. Health care organizations should collaborate with local public health departments to identify, prioritize, or deconflict legal issues and produce solutions for training, mobilization, and demobilization of the closed POD. Helpful resources are listed below.

CDC Resources
- Hospital Legal Preparedness: Relevant Resources page provides resources to help hospitals incorporate legal issues into hospital emergency planning.
- Selected Federal Legal Authorities Pertinent to Public Health Emergencies outlines commonly cited federal legal authorities for reference by public health officials, legal counsel, and others.
- CDC, Public Health Management Corporation, and the Policy Surveillance Program’s Map of Emergency Suspension Powers provides a state-by-state breakdown of laws granting powers to governors to change statutes or regulations to manage emergencies.
Association of State and Territorial Health Officials (ASTHO) Legal Preparedness Series
- The Emergency Authority and Immunity Toolkit contains information about potential liabilities that may arise from emergency response activities, and reviews protections for individuals and entities.
- The Emergency Use Authorization Toolkit addresses federal laws allowing special uses for medicines and medical devices during an emergency[1].
- The Emergency Volunteer Toolkit provides resources and documents related to liability for volunteers during an emergency.
- The Public Health & Information Sharing Toolkit describes how public health agencies collect, use, and share information during emergencies.
- The Public Health & Schools Toolkit contains documents and resources related to public health activities conducted in schools. Some of these resources may be helpful for health care organizations.
- The Scope of Practice Toolkit addresses changing health care providers’ scope of practice during emergencies.
- ASTHO’s Pharmacy Legal Toolkit provides information relevant to pharmacies when responding to public health emergencies.
The Network for Public Health Law released an Issue Brief titled Legal Issues Relevant to Private Entities Serving as Closed Points of Dispensing (Closed PODS) in Emergencies. This issue brief addresses many issues private entities should consider when planning to become a closed POD[2].
The American Health Lawyers Association’s Section 1135 HIPAA Waiver Toolkit.

Disclaimer: Information available on this website that was not developed by the Centers for Disease Control and Prevention (CDC) does not necessarily represent any CDC policy, position, or endorsement of that information or of its sources. The information contained on this website is not legal advice; if you have questions about a specific law or its application, you should consult your legal counsel.

[1] This document was prepared prior to the passage of the Pandemic and All-Hazards Preparedness Reauthorization Act of 2013; for current information federal emergency use authorities, please see https://www.fda.gov/RegulatoryInformation/Guidances/ucm125127.htm.

[2] This document was prepared prior to the passage of the Pandemic and All-Hazards Preparedness Reauthorization Act of 2013; for current information federal emergency use authorities, please see https://www.fda.gov/RegulatoryInformation/Guidances/ucm125127.htm.