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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. 5


Low-Income Populations; Community Health Centers; Race and Ethnicity Data


In February 2008, the Health Resources and Services Administration (HRSA) proposed new regulations that would have modified and combined the Health Professional Shortage Area (HPSA) and Medically Underserved Area/Population (MUA/P) designation processes. The comment period was extended twice in response to the large volume of comments, through June 30th. On July 23rd, HRSA effectively withdrew the proposed rule, announcing that in light of its preliminary review of comments, the agency had elected to develop a new proposal. This Research Brief highlights some of the salient issues surrounding the proposed rule, based on an analysis of the public comments by researchers at the George Washington University School of Public Health and Health Services and the RCHN Community Health Foundation.

Of the total 725 comments filed, 205 comments were received prior to the end of the first comment period (April 29, 2008), while the majority - 520 - were received subsequent to the extension of the initial comment period. Analysis of the comments underscores that opposition was broad, particularly once the comment period was extended and commenters had the opportunity to offer specific analysis beyond a simple extension request. Seventy-eight percent of post-extension commenters specifically recommended that the regulation be withdrawn and/or recommended increased stakeholder involvement in the rulemaking.

Our review of the comments suggests that while redesigning the regulation, the agency should:

  • Consider engaging stakeholders through a more formal engagement process;
  • Provide a complete explanation of the policy effects of any proposed changes;
  • Develop specific approaches to designating communities experiencing medical underservice separately from communities that experience an actual shortage of primary health care professionals; and
  • Devise a provider shortage measure that reflects an appropriate standard of care.

Open Access