The Trump administration announced various executive orders and actions, including attempts to eliminate, pause and limit grant funding that impacted multiple sectors, including education, healthcare, and social services. In the face of these efforts, organizations must respond effectively and efficiently. One structured way to manage these challenges is through the use of an Incident Command System (ICS).

ICS is a standardized, hierarchical framework designed for incident management. While it is traditionally used in emergency response (many organizations activated their ICS to respond to the COVID-19 pandemic, for example), its principles apply well to handling other complex organizational challenges, such as adapting to the rapidly shifting policy environment. ICS provides a coordinated response strategy that enhances communication, accountability, and resource management. One of the advantages of ICS is that it can expand and shrink as needed.

Implementing ICS for Policy and Financial Challenges

1. Establish an Incident Commander (IC)

The IC is responsible for the overall response to the emergent environment (e.g., executive orders, funding restrictions and other limitations). This individual should have a deep understanding of the policy landscape and the ability to coordinate stakeholders efficiently. This will most likely be somebody in the Executive Leadership role, although not necessarily the Chief Executive.

Moreover, an organization may also want to establish the following “command staff” positions:

• Public Information Officer (PIO): Manages communication related to the executive orders, financial blocks, and grant funding limitations. This is largely a public relations role.
• Safety Officer (SO): Responsible for identifying and mitigating any risks associated with the organization’s response, eg., monitoring psychological and emotional well-being among employees, ensure workplace safety in time of resource limitations, working with legal and compliance to not expose the organization to liability or regulatory violations.
• Liaison Officer (LO): Serves as the primary point of contact between the organization and external entities, such as government agencies, associations, advocacy groups, and funding partners to coordinate efforts.

2. Form Key Sections for Response Management

ICS divides responsibilities into functional sections:

• Operations Section: Manages immediate actions, such as analyzing funding reductions, adjusting workflows based on new financial strategies, and ensuring compliance with any new regulations and guidance.
• Planning Section: Forecasts potential impacts, develops response strategies, and prepares alternative funding models.
• Logistics Section: Ensures necessary resources—financial, personnel, or informational—are allocated effectively to respond to policy shifts.
• Finance/Administration Section: Tracks budgetary changes, ensures legal compliance, and documents all financial adjustments.

3. Develop an Incident Action Plan (IAP)

An IAP outlines specific objectives and actions to mitigate challenges and updated new policies and guidance. The plan should include:

• A detailed assessment of policy impacts.
• Strategic funding alternatives (g., private grants, state funding, or partnerships).
• Legal and advocacy steps to challenge restrictive policies, if necessary.
• Communication strategies to inform stakeholders and employees about changes.

4. Establish a Unified Command (UC) if Needed

A Unified Command structure allows organizations a joint front and shared decision-making. This ensures a cohesive response across different entities affected by the same executive orders. An example of such strategy would be coordinating with a state or a national association for joint decision-making.

5. Conduct Regular Briefings and Evaluations

Continuous assessment of the situation is crucial. There is a lot of rapidly changing information all around. ICS promotes regular briefings to update leadership, stakeholders, and employees, ensuring everyone is aligned with the response strategy and the latest updates.

By using ICS principles, organizations can navigate uncertainty, optimize resource management, and maintain continuity in their essential services. As policy landscapes continue to evolve, adopting a structured response strategy like ICS will be crucial for resilience and long-term sustainability.

For questions concerning managing shifting policies with the Incident Command System, please contact Compliance & Risk Management Services Manager Alexander S. Lipovtsev and Partner Dianne K. Pledgie.