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George Washington University, School of Public Health and Health Services, Department of Health Policy


Geiger Gibson/RCHN Community Health Foundation Research Collaborative Policy Research Brief No. 3


Community Health Centers; Health Reform; Health Homes


In April of 2008, we issued a research brief which analyzed the impact on various federal programs of a February 29, 2008 Notice of Proposed Rulemaking (NPRM) regarding the designation of Medically Underserved Populations and Health Professional Shortage Areas. Among its findings, the report estimated that resources for one-third of community health center sites would be jeopardized by this rule change because they could not attain a sufficiently high priority status, even under the newly-proposed, higher-scoring Tier 2 methodology. On May 1, 2008, we issued a revision in response to an April 21, 2008 clarification notice from the Health Resources and Services Administration (HRSA).

Since that time, in informal communication with state Primary Care Offices HRSA has further clarified a statement contained in its April 21st notice to assert that health center grantees can retain their tiered-based designation status at the grantee level if any single grantee site is located in a medically underserved area. Assuming for the moment that – despite the provisions of the February 29th NPRM – HRSA did, in fact, intend this "any site" policy to apply at the health center grantee level, we joined with the Robert Graham Center to re-examine the impact of the rule at the grantee level, using the tiered methodology published in the NPRM and linking each grantee to all its sites.

Our latest analysis shows that 31 percent of health center grantees would still not qualify for Tier 2 designation, even if 'any site' can confer MUA status. At present, about 18 percent of grantees with one or more sites in a MUA/P designated area would no longer meet Tier 2 qualifications under the proposed rules, even with the assumption that 'any site' counts.

An additional 13 percent of health center grantees do not have any sites located in a MUA/P designated area and thus would still not qualify under the Tier 2 methodology. Interestingly, health centers with fewer sites are less likely to be designated under the 'any site' assumption and are disadvantaged under this approach – we found that 54 percent of solo-site grantees may lose their designation, compared to just 15 percent of those with 11 or more sites.

Open Access