Post by Carol Miller on Dec 17, 2012 15:49:13 GMT -7
Proposed Advocacy Organization Strategy for Responding to Federal Register
Carol Miller
Problems with the Federal Register Notice Itself
Premature release with old data.
The NPRM does not list the statutory history of frontier definitions and designations nor analyze the relationship among existing definitions and designations from the current as proposed.
Data used is 12 years old. The NPRM should have been held until current data was provided in order to assure informed comment.
This is a very serious matter and will not allow comments to be based on fact. Rather commenters are asked to trust the ORHP that actual implementation data will be something like what was provided.
This establishes a very bad precedent for future NPRM notices as it might institutionalize the use of old, possibly irrelevant data.
Disregard for the Public Input previously offered
Early in this five year process, ORHP held five regional meetings to gather public/stakeholder input. The National Center for Frontier Communities attended all of the meetings.
Despite a wide range of participants at these meeting, several requests were made at each:
Impact Analysis
Numerous requests were made that an impact analysis be developed to show how actual programs might be impacted by each of the possible designation variants, and as compared to current methods.
Reconsideration/Waiver
Every meeting had a detailed discussion of the critical importance of providing a process to allow local entities (state, tribes, etc) to provide additional information specific to local conditions to request designation. This was completely ignored and replaced with a top down, one-size-fits some process that is a huge setback to state offices of rural health, state executives, tribal entities, and communities that currently are already participating in various designations managed by HRSA such as HPSA, MUA, and BPHC sparsely populated status.
Interactions among statutory definitions and policy definitions and procedures.
I asked Steve Hirsch to explain slide 4 presented at the webinar which contained the factually inaccurate statement that: “There is no formal statutory definition of a frontier area.”
There are, in fact many, including two new ones in the ACA; frontier state (for enhanced Medicare payments) and frontier HPSA. Also the MIPPA Demonstration project on community health integration models in certain rural counties amended in the ACA. The oldest statutory language dates back to 1986 and continues intermittently from there. The Burdick Interdisciplinary training program also included a statutory definition.
Because the materials provided are inaccurate, the process is flawed and the process should be stopped at this point and re-published with current data and impact studies to allow informed comment at the time it is re-published.
Carol Miller
Problems with the Federal Register Notice Itself
Premature release with old data.
The NPRM does not list the statutory history of frontier definitions and designations nor analyze the relationship among existing definitions and designations from the current as proposed.
Data used is 12 years old. The NPRM should have been held until current data was provided in order to assure informed comment.
This is a very serious matter and will not allow comments to be based on fact. Rather commenters are asked to trust the ORHP that actual implementation data will be something like what was provided.
This establishes a very bad precedent for future NPRM notices as it might institutionalize the use of old, possibly irrelevant data.
Disregard for the Public Input previously offered
Early in this five year process, ORHP held five regional meetings to gather public/stakeholder input. The National Center for Frontier Communities attended all of the meetings.
Despite a wide range of participants at these meeting, several requests were made at each:
Impact Analysis
Numerous requests were made that an impact analysis be developed to show how actual programs might be impacted by each of the possible designation variants, and as compared to current methods.
Reconsideration/Waiver
Every meeting had a detailed discussion of the critical importance of providing a process to allow local entities (state, tribes, etc) to provide additional information specific to local conditions to request designation. This was completely ignored and replaced with a top down, one-size-fits some process that is a huge setback to state offices of rural health, state executives, tribal entities, and communities that currently are already participating in various designations managed by HRSA such as HPSA, MUA, and BPHC sparsely populated status.
Interactions among statutory definitions and policy definitions and procedures.
I asked Steve Hirsch to explain slide 4 presented at the webinar which contained the factually inaccurate statement that: “There is no formal statutory definition of a frontier area.”
There are, in fact many, including two new ones in the ACA; frontier state (for enhanced Medicare payments) and frontier HPSA. Also the MIPPA Demonstration project on community health integration models in certain rural counties amended in the ACA. The oldest statutory language dates back to 1986 and continues intermittently from there. The Burdick Interdisciplinary training program also included a statutory definition.
Because the materials provided are inaccurate, the process is flawed and the process should be stopped at this point and re-published with current data and impact studies to allow informed comment at the time it is re-published.