HLTH 8451 Week 8 RIA Baseline Specification Example

The World Without the Rule: A Baseline Specification for the Heat Refuge Analysis Covering Current Practice, State Requirements, Rising Heat and Voluntary Adoption

Student Name

Walden University

HLTH 8451: Public Policy Analysis

Instructor Name

Month Day, Year

The World Without the Rule: A Baseline Specification for the Heat Refuge Analysis Covering Current Practice, State Requirements, Rising Heat and Voluntary Adoption

The Standard

Circular A-4 instructs agencies to measure a rule's benefits and costs against a baseline that represents the best assessment of how the world would look without the rule (Office of Management and Budget, 2003). The baseline is not the world today, and it is not a world in which nothing changes. It is a forecast of what facilities, states and the climate would do over the analysis period if the federal government took no action. Every incremental effect estimated in Weeks 6 and 9 is measured against it, so an error here carries through the whole analysis. This specification sets the baseline before any benefit is estimated and labels every composite figure as composite.

Current Practice

Facilities that already keep residents cool on backup power gain nothing from the rule and cost nothing to bring into compliance. No national source reports how many there are. For this analysis, a composite survey of 600 certified facilities, stratified by size and region, is used. It finds that 38 percent maintain cooling on backup power for at least part of the building, enough to meet the refuge requirement. The share is higher among large facilities and those built or renovated recently. Facilities whose generators are sized only for life safety loads, such as lighting, alarms and medical equipment, are counted as not compliant even though they hold an emergency plan. Federal preparedness rules already oblige every facility to plan how it would keep temperatures safe without grid power (42 C.F.R. § 483.73), so the baseline assumes every facility has a plan; the question is whether it has the equipment.

State Requirements

Some states already require nursing homes to have generators or to maintain temperatures during outages. Florida's rule, adopted after the deaths following Hurricane Irma, requires an alternate power source that can hold a designated area no warmer than 81 degrees Fahrenheit for a minimum of 96 hours, allowing 30 square feet per resident (Florida Agency for Health Care Administration, 2018). Facilities in states with comparable rules would contribute little incremental benefit or cost, since they must comply with state law whether or not the federal rule is adopted. Counting their compliance as an effect of the federal rule would credit it with benefits that state rules already produce.

The composite assumes that, after removing facilities already counted under current practice, a further 9 percent of facilities nationally are in states whose requirements are at least as strict as the performance standard. They are removed from the incremental count. Facilities in states with weaker requirements, such as a generator without a temperature standard, remain in the count, with lower compliance costs reflecting equipment already in place.

Rising Heat Exposure

The hardest question is whether rising heat belongs in the baseline. It does. The Fifth National Climate Assessment reports that extreme heat events in the United States have become more frequent and intense and are projected to continue doing so (Crimmins et al., 2023). The assessment is used here for direction, not for figures, since its projections are not specific to power loss at nursing homes. Treating rising heat as a baseline change rather than a benefit of the rule means the rule is credited only with the difference it makes in the future that is expected. If heat exposure rises, the rule protects more residents than it would today, and that larger effect is properly part of its benefits. What the rule cannot be credited with is the rise in heat itself.

The composite baseline assumes that the annual probability of a facility losing power during a declared heat emergency rises from 2.0 percent at the start of the analysis period to 3.0 percent at its end, an average of 2.5 percent. Grid reliability is held at current levels apart from heat-driven demand; the Week 3 grid formulation is tested separately in Week 9.

Voluntary Adoption

Some facilities would install cooling on backup power without a federal rule, after a nearby outage, an insurer's request or a renovation. The rule should get no credit for them. Experience elsewhere suggests that mandates, rather than voluntary decisions, have driven most adoption: in Ontario, more than half of nursing homes still lacked air conditioning before the province announced a mandate in 2020 (Katz et al., 2026). The composite assumes that 8 percent of facilities would adopt voluntarily over the analysis period, concentrated among large facilities undergoing renovation. These facilities are removed from the incremental count from the year they are expected to adopt.

The Incremental Population

Combining the four sections, about 45 percent of certified facilities, or roughly 6,750 of 15,000, would change their equipment because of the rule. That is the population whose costs and benefits are estimated.

Table 1

Baseline Assumptions, Central and Alternative

Every number in the table is composite except where a regulation is cited.

The Alternative Baseline

A second baseline is specified for sensitivity analysis. It assumes no voluntary adoption and no change in heat exposure. It represents a static world in which only the rule causes change. Under it, more facilities are affected, but each is exposed less often. Comparing results under the two baselines will show whether the conclusion depends on the forecast of rising heat or on the assumption about voluntary adoption.

Conclusion

The baseline credits the rule with what it changes and nothing more. It removes facilities already compliant, those covered by state rules and those that would adopt anyway, and it treats rising heat as part of the world the rule will operate in. The two assumptions most open to challenge, the voluntary adoption share and the rate at which heat exposure rises, are the ones the alternative baseline varies.

References

Crimmins, A. R., Avery, C. W., Easterling, D. R., Kunkel, K. E., Stewart, B. C., & Maycock, T. K. (Eds.). (2023). Fifth National Climate Assessment. U.S. Global Change Research Program. https://doi.org/10.7930/NCA5.2023

Emergency preparedness, 42 C.F.R. § 483.73 (2024).

Florida Agency for Health Care Administration. (2018). Emergency environmental control for nursing homes (Fla. Admin. Code R. 59A-4.1265).

Katz, G. M., Brown, K. A., Giannakeas, V., & Stall, N. M. (2026). Air conditioning in nursing homes and mortality during extreme heat. JAMA Internal Medicine, 186(2), 243-251. https://doi.org/10.1001/jamainternmed.2025.6595

Office of Management and Budget. (2003). Circular A-4: Regulatory analysis. Executive Office of the President.