Transcript PROPOSED NEW METHODOLOGY FOR IDENTIFYING …

Panel Presentation
Shortage Area Designations
Larry Allen, Center for Rural Health
Elizabeth Cobb, KY Hospital Association
Steve Salt, KY Department for Public Health
ORIGIN OF SHORTAGE
DESIGNATIONS

Health Professional Shortage Area
• National Health Service Corps (NHSC) was
•
•
•
created in 1971
NHSC need determination process was
expanded in 1978 to include poverty, infant
mortality rate or birthrate and access barrier
measures
This expanded methodology is the current
HPSA designation methodology
Required to be reviewed every three years
ORIGIN OF SHORTAGE
DESIGNATIONS

Medically Underserved Areas or
Populations (MUA/P)
• MUA/P process was developed in 1975 to
•
•
create grant opportunities for Community Health
Centers (CHCs)
MUA/P process uses similar measures as the
HPSA but also includes % 65 years and older
MUA/Ps have no review requirement –
DESIGNATION FOR LIFE!
DESIGNATION REQUIREMENTS FOR
CERTAIN FEDERAL PROGRAMS
Shortage Designation
Option
National
Health
Service
Corps
Primary Care HPSA
X
Dental Care HPSA
X
Mental Health HPSA
X
Geographic HPSA
X
Population HPSA
X
Facility HPSA
X
Federally
Qualified
Health
Center
Program
CMS
Medicare
Incentive
Payment
CMS Rural
Health Clinic
Program
J-1 Visa
Waiver
X
X
X
X
X
X
X
X
X
X
Exceptional MUP
X
X
Medically Underserved
Area
X
X
Medically Underserved
Population
X
X
State Governor’s Certified
Shortage Area
X
HPSA DESIGNATION PROCESS



Calculate the population to provider ratio
•
Must meet threshold of 3500:1
Consider contiguous areas
•
•
Identify on the map the boundaries and population
center of the proposed service area
Evaluate each area to determine the availability of
resources
If area meets ratio requirement AND you can
rule out service availability in all contiguous
areas, a recommendation is made to HRSA
for designation
Recent Policy Changes
HRSA Policy
Recent Changes
• HRSA Proposed Changes in 1998 and
2008 – Never made final
• ACA 0f 2010 requires changes to the
shortage area designation methodology
• Negotiated Rule Making Process (June 2011)
• If no consensus, Secretary to publish an
Interim Final Rule for new methodology (June
2012)
“Negotiated Rulemaking”

What is it?
• Statutory basis: Negotiated Rulemaking Act of 1996
encouraged the use of negotiation to determine
complicated regulations and directed agencies and
negotiated rulemaking committees to “use consensus
to the maximum extent possible consistent with law.”
8
“Negotiated Rulemaking”

Who was involved?
• Secretary Kathleen Sebelius made appointments
summer 2010
• Criteria for selection :
•
•
•
•
28 experts representing
Community Health Centers, rural health clinics and health care
practitioners,
Representatives of special populations with unique health care
needs,
Technical experts in the area of research in health care access and
statistical methods
State Offices of Rural Health and Primary Care
• Role of DHHS/HRSA: One representative on the
NRMC – Ed Salsberg, support staff in regular
attendance
9
Timeline and Progress of the
Negotiated Rulemaking
•
•




Secretary Sebelius appointed members
July 2010
First meeting – September 2010
Completion by July 1 and then…
Extension granted
Final meeting – October 2011 (14 month
process)
Final Report to Secretary October 31, 2011
10
Sub-committees and Work
Groups
Tackling the content areas:
– Measuring “underservice”
• Population and providers for “P2P” – Population to
Provider Ratios
– Counting providers, deciding on “back outs”
– Population counts and age/sex adjustments, other
issues
• Health Status
• Barriers
• Ability to Pay
– Updating “rational service area” definition
– Considering Data Sources and Validity
11
Notable Concern: “Yo-Yo
Effect”

Need to exclude federally supported
providers from the provider to population
count:
• NHSC
• SLRP
• FQHC
• RCH
Next Steps
•
•
•
•
Report submitted to the Secretary 10/31/2011
“Interim Final Rule” to be posted….
Comments – will be accepted -- but HRSA does
not have to change the Interim Final Rule
Those organizations and entities represented by
Committee members will not comment adversely
on sections on which there was consensus, but
may comment on areas on which there was not
consensus
13
Concerns and Advocacy Efforts

Concerned future changes will be similar to previous
proposal by HRSA which would have adversely
impacted Kentucky

Need a more pro-active effort to influence the
process

Need to educate lawmakers and others on the
impact to Kentucky
PCO Designation Role
• Designated by HRSA to evaluate at state
•
•
•
•
level
HPSAs required to be reviewed every 3 years
Methodology and data sources required by
HRSA
Activities to ensure accuracy
Work with stakeholders to exhaust all efforts
Policy On Publication in FR



Proposed for withdrawal, not published
in Federal Register
Some availability of designation benefits
November 2011, began publishing
regularly
Published Withdrawal in Nov. 3,
2011 Federal Register

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Anderson
Barren
Breathitt
Clark
Cumberland
Daviess
Fayette
Fleming
Greenup
Johnson








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
Laurel
Lawrence
Marion
Perry
Shelby
Trimble
Warren
Webster
Whitley
Hickman
HPSAs to be
Updated`
PCO Due Date
OSD 90 Day
Review
HPSA Find Update
FR Notice
FR Publish
2008
Sept. 30, 2012
Oct. 30, 2012
November
June 1, 2013
July 1, 2013




(1) On (or about) Sept., 25, the PCO will send an e-mail
recommending a County HPSA be withdrawn because the Population
to Provider Criteria was not met.
(2) In mid-October HRSA will prepare the list of P’s (Proposed for
Withdrawals) and N’s (No information forthcoming from the PCO
=Proposed for Withdrawal). This list will be shared with the PCO’s to
double check the information is correct.
(3) In November, HRSA will check the list of HPSAs Proposed for
Withdrawal against the list of NHSC individual and site applications.
(HRSA will not impact pending NHSC matches-vacancies by a change
in HPSA status).
(4) In November, the HPSAFIND (HRSA website) status will be
changed to Proposed Withdrawal.
HPSA Federal Register Notice
Update Schedule
HPSAs to be
Updated
PCO Due Date
OSD 90 Day Review
HPSA Find Update
FR Notice
FR Publish
2008
Sept. 30, 2012
Oct. 30, 2012
November
June 1, 2013
July 1, 2013
2009
March 30, 2013
June 30, 2013
July
June 1, 2014
July 1, 2014
2010
December 31, 2013
March 30, 2014
June 1, 2014
June 1, 2014
July 1, 2014
Data Sources

American Community Survey –
• large national survey
• uses continuous measurement methods to
•
produce detailed population estimates each
year
Current survey information from period 20062010
2011-2012 HPSA Activity
Adair 2012-5
Bath 2012-12
Nicholas -Withdrawn
Bracken ????
Caldwell – PW
Clay 2011-13
Elliott 2011-9
Green – PW
Hart – PW
Jefferson 2011-8
Larue 2011-11
Lewis 2012-8
Logan 2012-11
Madison – PW
Marion 2011-10
Meade ????
Metcalfe 2012-16
Breckinridge 2012-15
Carter 2011-6
Crittenden 2012-11
Estill – PW
Harlan (partial) 2012-16
Jackson 2012-14
Knox 2012-11
Leslie 2012-14
Livingston – Withdrawn
Lyon 2012-6
Magoffin 2011-11
McLean 2012-10
Menifee 2011-13
Muhlenberg - PW
Ohio 2012-9
Robertson 2011-14
Russell 2012-5
Todd 2012-13
Washington 2011-11
Wayne 2012-11
Wolfe - PW
Recent Trends


Overview of gains and losses for
2011-2012
Sample designation profiles
HPSA Determination: Hart
Items
Criteria
Value
Result
Valid Rational Service Area
Yes
No
Does Not Pass
Designation Population
< 250000
17684
Pass
Pop/FTE Ratio
>= 3500:1
5053:1
Pass
200% of Poverty
None
50.21%
Pass
Overall Contig Area Availability
No
Yes
Does Not Pass
HPSA Determination
Does Not Qualify
HPSA Determination – Hart 2
Type
Criteria Value
Scoring Table Value
Weighted Value
Population/Provider Ratio
5053:1
4
8
Poverty Percent
23.5
2
2
Low Birthweight Rate
7
1
Infant Mortality Rate Per 1000 Births
6
0
Travel Time (Minutes)
0
0
Travel Distance (Miles)
0
0
1
0
HPSA Greatest Need Scoring
11
HPSA Degree of Shortage
2
Physician Short
1.553
UnderServed
10684
HPSA Determination – Hart 3
CA
CA
Name
SBarre
1210
0113 n
79
Coun
ty
HPSA
Name
Sig
HPSA
InExcessi
Other
Pop/
SocioAvailabl
Over
100%
Categor
accessib
vely
Access Provider
e CA
Utilized
Pov
Economi
y
le
Distant
Barriers Ratio
c Diff
Contiguous Areas
NON
Yes
E
No
No
No
No
No
200%
Pov
Travel
Mile
1381:
18.73 42.65 4.4
1
Travel
Time
(Mins)
Travel
Mode
6.6
Priva
te
HPSA Determination: Wolfe County
Scoring Table Value
Weighted
Value
Type
Criteria Value
Population/Provider Ratio
2399:1
0
0
Poverty Percent
42.2
4
4
Low Birthweight Rate
10
3
Infant Mortality Rate Per
1000 Births
11
1
Travel Time (Minutes)
0
0
3
0
Travel Distance (Miles)
0
HPSA Greatest Need Scoring
0
7
HPSA Degree of Shortage
Physician Short
-0.601
UnderServed
1196
Panel Questions?