MDCH Comment on NPRM2 Final

May 23, 2008 Health Resources and Service Administration Department of Health and Human Services Attention: Ms. Andy Jordan 8C-26 Parklawn Building 5600 Fishers Lane Rockville, Maryland 20857 Subject: Michigan Department of Community Health Comments on the Health Resources and Service Administration Proposed Rule for Designation of Medically Underserved Populations and Health Professional Shortage Areas General Comments: The new criteria will affect the distribution of HPSA and MUA/P designated areas in Michigan. Federal estimates suggest that, although there will be a slightly different set of areas designated, the number of Michigan HPSAs designated under the new criteria will be no fewer than 81% of the current number. Similarly, 90% of the number of MUAs and MUPs currently designated will be designated under the new criteria. HRSA staff has indicated that these figures over-estimate the loss of designation number and population and that the percentages cited above are likely to be higher when local data is included in the analysis. Michigan Department of Community Health (MDCH) staff concur with these observations. MDCH staff conducted an analysis of each Michigan county and the prospect for geographic HPSA designation under the new criteria. This analysis estimates that 8 of 11 current full-county geographic HPSAs in Michigan will remain full-county geographic HPSAs under the new criteria. Additionally, eight counties that ...