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Health &
Human Services Proposes Fundamental Changes in Primary
Care Shortage Designations
On
Feb. 29, the U.S. Department of Health and Human
Services (HHS) published proposed rules that would
fundamentally alter the methodology used for designating
primary care Health Professional Shortage Areas (HPSA)
and Medically Underserved Areas/Populations (MUA/P).
These designations are used to determine eligibility for
40 federal programs that create incentives for primary
care providers to practice in underserved areas. Some of
these incentives come through enhanced Medicaid
reimbursements, educational loan repayments for
providers, and Community Health Center funding.
In Washington State, losing
benefits that come with designation could be a harsh
blow for health care providers and their communities,
which are already underserved. Both Governor Gregoire
and Secretary Selecky are concerned about the impact of
the proposed HPSA methodology on primary care services.
Their comments are publicly available at the DOH
website:
http://www.doh.wa.gov/hsqa/ocrh/ .
It is broadly accepted that
the current designation criteria and methodology are
outdated. The rules were written in the 1970s, when the
National Health Service Corps (NHSC) was formed and the
first grant opportunities for Federally Qualified Health
Centers were made available. Since then, health care
delivery, as well as the requirements of communities,
has changed. While the proposed rules are improvements,
more is needed.
In their comments to the HHS,
both the Governor and the Secretary emphasize how
difficult it is to gauge the impact of the proposed
rules. First, the proposed methodology is complex.
Getting an accurate assessment of the number of shortage
designations that would be retained or lost is difficult
to do. It takes provider information at the local level,
nurse practitioners and physician assistants, as well as
physicians. This collection takes significant time and
resources.
There are also issues
related to the data used in the calculations,
specifically the multipliers, percentiles, and scores
used to generate the Index of Primary Care Underservice
score. Consequently the results of any impact analysis
should be taken as suggestive. While the Washington
State Department of Health predicts a loss of 13
designations previously covered by a HPSA/MUP, it
acknowledges that it is not possible to come up with an
exact number.
Second, significant
questions remain about the way the designations will be
used by the numerous programs whose funding decisions
rest on shortage designations. The proposed rules create
new multi-tiered designation levels as well as a “safety
net facility” designation. It is still not clear how
agencies will adopt and use the proposed rules for the
different types of designations.
Changes in how programs use
HPSA/MUP designations will directly affect the viability
of primary care services in our state. Over $150 million
dollars of federal and state resources per year are
linked to programs that use these designations.
The Department of Health,
together with local partners from federally qualified
health centers, rural health clinics, and hospitals, are
providing feedback and requesting changes on the
proposed rule. The comment period was extended a second
time to June 30. We hope that any final rule will be
improved and take to heart the comments that have been
submitted.
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