Health Professional Shortage Designation Process Position Statement

I. ASTHO Supports a Transparent, Equitable, and a Scientifically-Based Health Professional Shortage Designation Process.

The Association of State and Territorial Health Officials (ASTHO) supports state and territorial health agencies’ efforts to improve access to care through the designation process conducted by state primary care offices.

II. Within This Context , ASTHO and the State Primary Care Offices Recommend the following for a Health Professional Shortage Designation Process¹

• Transparency: The new method must be well-defined, straight-forward, and unambiguous.
• Cost neutrality:  The new method must be budget neutral or fully funded by the federal government to support state primary care offices. The new method must also address the cost of human resource requirements to implement this method and/or provide estimates of these costs as funding recommendations to the Federal government.
• Science-based: The new method must be based on scientifically-recognized, replicable methods and research-based correlates of access to and utilization of care.
• Flexibility: The new method must be able to recognize and accommodate the access-to-care challenges experienced in rural versus urban areas so that the system is valid for both types of areas.
• Validity: The new method must be logically sound in addition to being substantiated by data- driven evidence.
• Acceptable performance: The new method must fairly and consistently identify vulnerable populations and communities who experience health disparities and access barriers to primary health care.
• Reliability: The minimum data requirements of the new method must be for data that are available for all states and jurisdictions so that the method is consistently implemented across jurisdictions.
• Non-Geographic-Based Designations: The new method must recognize that certain populations at high-risk for underservice may not be geographically clustered.  Facilities that serve these populations should have opportunities to qualify for designation based on the proportions of the recognized populations the facilities serve rather than on the geographically-tied HPSA in which those populations reside.

III. Background: Improving Access to Care

ASTHO’s members are primarily responsible for ensuring the health of the residents in their states and territories. This includes ensuring access to health care via state-wide health and health care planning, workforce recruitment and retention activities and particularly the data collection and analysis for areas recommended to HRSA to be given one of these designations. ASTHO recognizes the importance of these designations and of the states’ role in contributing to these designations. Forty-seven of our 51 members conduct designation processes within the state health agency.² They are objective measures of outstanding health care need for a given area. ASTHO also acknowledges the need to update these measures using current techniques, measures and data sources in order to designate areas that meet today’s criteria in order to highlight areas in need of resources to improve access to health care. Every state primary care office, funded by the Health Resources and Services Administration, uses the current MUA and HPSA designation process. According to a 2007 survey of state health agencies, 47 of our 51 members house a primary care office and or a state office of rural health. ASTHO has an established primary care office training and technical assistance program, funded by HRSA, to support the primary care offices in conducting this essential work. This funded work includes coordination among state public health programs and other state activities related to primary care delivery. ASTHO’s activities include but are not limited to support of a primary care office affinity group, development of an orientation manual, a survey of state primary care offices and their functions, webinars for training, mentorship program and links to ASTHO’s health reform efforts.

ASTHO suggests that the highest priority for the Negotiated Rulemaking Committee is to ensure that the designations remain objective measures of health care need. State health agencies are neutral conveners and brokers with a mission to improve population health. ASTHO is concerned about the proposed high number of stakeholders who have a financial interest in the designation rules and therefore may be less objective in their recommendations.  Rather than influencing the objective measure in favor of a particular constituency, these interested parties should seek to amend the rules that link these designations to their funding streams.

Approval History:

ASTHO Position Statements relate to specific issues that are time sensitive, narrowly defined, or are a further development or interpretation of ASTHO policy. Statements are developed and reviewed by appropriate Policy Committees and approved by the ASTHO Executive Committee. Position Statements are not voted on by the full ASTHO membership.

Committee Review and Approval

Board of Director’s Review and Approval March 11, 2011.

Policy expires on March 2014

These recommendations are addressed to HRSA.

For further information about this Position Statement, please contact ASTHO Primary Care Policy staff at 202-371-9090.

Notes

1. Based on Band of 16 Comments to HRSA during NPRM 2
2. ASTHO 2007 Member Survey