National Update of Auto- HPSA Scores

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National Update of Auto- HPSA Scores November 1, 2018 Colleen Meiman, Senior Policy Advisor These slides are available for download on the NACHC Shortage Designation webpage (Click on this link, or google NACHC (Click the above link, Shortage google Designation) NACHC Shortage Designation) These slides are available for download on the NACHC Shortage Designation webpage

Agenda Auto-HPSA 101: What they are & why they matter to FQHCs What HRSA is doing, and why What do these new scores mean? Q&A

Key Takeaways 1. The upcoming changes may impact some health centers NHSC eligibility, but not their 330 funding. 2. HRSA has been working for 5 years to modernize and standardize how all HPSAs are calculated. 3. HRSA has largely accepted NACHC/ FQHCs recommendations re: updates to the auto-hpsa process. 4. The scores that health centers will receive soon are only preliminary estimates and could change before being finalized. 5. Scores should be finalized in late spring 2019, and effective starting in the 2020 NHSC application cycle. 6. The national update of all auto-hpsa scores could cause significant reshuffling of which FQHCs are eligible for NHSC providers. 7. Many preliminary scores could be very different from current scores for a variety of reasons, including: the current scores are very old; the PCO has yet to update the provider data in their area; or HRSA s move to standardized data sets and decision rules.

Auto-HPSA 101 What They Are, and How They Matter to Health Centers

What are HPSAs? Stands for Health Professional Shortage Area Term created by Congress in the 1970s as a way for the Federal government to identify, and target resources, to areas with a shortage of health professionals. There are many types of HPSAs vary based on the target population being targeted and the type of care HRSA s Bureau of Health Workforce (BHW) is responsible for administering the HPSA program. To the Feds determine how to allocate scarce resources, all HPSAs are given a score, with higher scores indicating greater need.

HPSAs vs. MUAs, MUPs, NFA, etc. The Federal government has multiple systems for determining shortages of health professionals. Different systems are used for different purposes: HPSAs National Health Service Corps, etc. MUAs, MUPs (Medically Underserved Areas and Medically Underserved Populations)- required for FQHC/ 330 eligibility Need for Assistance worksheet Used in SAC applications. (May soon be replaced by SANAM.) Today Today we we are are discussing discussing only only changes changes to to HPSAs HPSAs so the impact will be largely by limited to the NHSC so 330 eligibility and SAC competitions will not be impacted.

Programs that Use HPSAs National Health Service Corps (NHSC) NURSE Corps (Primary Care and Mental Health HPSAs only) Medicare HPSA Bonus Program Does not apply to FQHCs to because we are not reimbursed under the fee schedule. Score doesn t matter J-1 Visa eligibility (but being in a MUA or MUP also provides eligibility)

Types of HPSAs A shortage of: Primary Care Mental Health providers in a: Dental Health Geographic Area Population Group Facility

9 Automatically Designated Facility HPSAs The following facility types are for automatic HPSA designation (aka auto-hpsas): Health Centers both grantees and look-alikes Tribally-Run Clinics Urban Indian Organizations Dual-Funded Tribal Health Centers Federally-Run Indian Health Service Clinics Rural Health Clinics meeting NHSC site requirements

FQHCs can have multiple HPSA scores A FQHC can have up to three HPSA scores for each type of care -- a geographic, population, and auto (aka facility) score. Generally, the auto-hpsa score is the highest so the one that NHSC eligibility is based on. All scores are calculated using formulas that have been set in regulation for years. HRSA has made at least three major attempts to update these formulas, without success.

HPSA Scoring Formulas HPSA scores are based on a variety of criteria and range from 0 to 25 in the case of Primary Care and Mental Health, and 0 to 26 in the case of Dental Health. No changes are being proposed to these formulas. Primary Care 0-25 Population-to- Provider Ratio Point Value Double Weighted % of Population at 100% Federal Poverty Level Point Value Infant Health Index Point Value (Based on IMR or LBW Rate) Travel Time to Nearest Source of Care Point Values HPSA Score (out of 25) Mental Health 0-25 Population-to- Provider Ratio Point Value % of Population at 100% Federal Poverty Level Point Value Alcohol Abuse Prevalence Point Value Substance Abuse Prevalence Point Value Elderly Ratio Point Value Youth Ratio Point Value Travel Time to Nearest Source of Care Point Values HPSA Score (out of 25) Dental Health 0-26 Population-to- Provider Ratio Point Value Double Weighted % of Population at 100% Federal Poverty Level Point Value Double Weighted Water Fluoridation Status Point Value Travel Time to Nearest Source of Care Point Values HPSA Score (out of 26)

HPSA Scoring Calculations Primary Care Dental Health Mental Health Criteria Max Pts Awarded Multiplier Total Points Possible Max Pts Awarded Multiplier Total Points Possible Max Pts Awarded Population:Provider Ratio 5 x 2 = 10 5 x 2 = 10 7 % of Population below FPL 5 x 1 = 5 5 x 2 = 10 5 Travel distance/time to NSC 5 x 1 = 5 5 x 1 = 5 5 Infant Mortality Rate or Low Birth Weight 5 X 1 = 5 Water Fluoridation 1 x1 = 1 Ratio of children under 18 to adults 18-64 Ratio of adults 65 and older to adults 18-64 Substance abuse prevalence 1 Alcohol abuse prevalence 1 Max Score: = 25 = 26 = 25 3 3 The Shortage Designation Modernization Project utilizes the existing HPSA scoring criteria. No changes to the criteria have been made. 12

What is HRSA Doing, and Why?

Initiated in 2013 Shortage Designation Modernization Project HRSA s stated goals are to increase: Transparency Efficiency Parity and Consistency Compliance with statutory requirements Without changing the underlying formulas used to calculate scores

SMDP Goals & Action Steps Automate the scoring system. Create a paper trail to justify every score. Establish consistent business rules. Update scores as often as required by statute. To the extent possible, rely on data that: Already exists (e.g., Census, UDS) Is available nationally Is as recent as possible The Big Data Challenge: Two of the largest scoring criteria rely on data about nearby providers who accept Medicaid or sliding fee patients. There is no national data set for this. So HRSA charged PCOs with collecting this data, and entering it into the HPSA database.

Progress to Date All geographic and population HPSAs were updated last winter, based on the new data sets, clarified rules, etc. HRSA has hoped to have auto-hpsas updated by now, but met major resistance when they rolled out plans in Summer 2016, around proposals such as: Measuring patient poverty using Census data for all persons living within 30-minute travel distance, rather than UDS Scoring health centers at the site-level rather than organizational level.

HRSA s Auto-HPSA Workgroup In response to pushback, HRSA established an auto-hpsa workgroup that included NACHC, PCAs, health centers, and other auto-hpsa providers. NACHC formed its own informal workgroup to advise the health center reps on the Workgroup. Major thanks to Aleks Kladnitsky, Tess Kuenning, Greg Nycz, Shelly Phillips, and all the other participants in both workgroups. HRSA accepted almost all of our recommendations. Still concerned that it s premature to issue preliminary scores. the

What s HRSA Doing Now? About two weeks ago, HRSA sent PCOs preliminary estimates for all updated auto-hpsa scores for their state, and well as info on the underlying data. Last week, HRSA sent each PCAs the preliminary estimates for all their health centers. Any day, health centers will start receive the first set of preliminary estimates for their updated auto-hpsa scores.

What Do These New Scores Mean?

These Score are NOT Final The scores that health centers receive in November are not final they are only preliminary estimates. Many scores are expected to change as state Primary Care Offices (PCOs) continue to update the provider data that underlies them. HRSA will send health centers several more estimates of their updated scores between now and when they are finalized in late spring 2019.

Final Updated Scores Health centers will receive their finalized updated auto-hpsa scores by late spring 2019. Between now and then, they will receive several more preliminary scores from HRSA. These scores may differ from the preliminary score received in November 2018, particularly as PCOs submit additional data to HRSA. HRSA plans to publish the final scores in Federal Register in the summer 2019. the The updated scores will be used starting with the 2020 NHSC application cycles.

Changes between now and final? Between now and when the scores are finalized, many health centers scores could change. For example: As PCOs submit more provider data, some health centers will see their scores drop. PCOs or health centers may identify errors in the data which, if corrected, could cause the scores to change.

Large scores changes? If your preliminary estimate looks very different from your current score, there are several possible reasons: Your scores haven t been updated recently. Many FQHCs scores date back to 2002 or 2003. Your PCO hasn t yet updated the provider data in your area. Your current score was based on a decision or data set that is being replaced with one that can be consistently applied nationally.

Reshuffling NHSC Eligibility NACHC has not seen a national impact analysis of the updated scores. However, we still expect that there could be significant reshuffling of NHSC eligibility when the auto- HPSA scores are updated.

What score is needed for NHSC? Could the eligibility thresholds for getting a NHSC provider change when all the auto-hpsa scores are updated nationally? Quite possibly. In recent years, only HPSA with a score of 16 or above have been eligible to receive a NHSC loan repayers, and only those with an 18 or above could receive a NHSC Scholar. It is quite possible (but not guaranteed) that these cut-off scores will change when auto-hpsa scores are updated.

Current NHSC Providers? What happens to the NHSC participants currently at my health center if my score drops below the eligibility threshold? Current NHSC participants may complete their service obligation at their current site. They may also be awarded continuations. The change in score will only impact current participants should they wish to transfer sites.

For More Information NACHC has a set of FAQs, and a background policy memo, on Shortage Designation webpage General information is available on the HRSA Shortage Designation Modernization Project webpage. HRSA will be holding two webinars -- Tuesday 11/6 from 3:00 5:00 ET, and Thursday 11/15 from 4:00 5:30 ET to discuss auto-hpsa updates. Log-in information is available here.

Questions? Please either: enter questions in the Chat Box, or click on the raise your hand button and I will open your line. cmeiman@nachc.org

Key Takeaways 1. The upcoming changes may impact some health centers NHSC eligibility, but not their 330 funding. 2. HRSA has been working for 5 years to modernize and standardize how all HPSAs are calculated. 3. HRSA has largely accepted NACHC/ FQHCs recommendations re: updates to the auto-hpsa process. 4. The scores that health centers will receive soon are only preliminary estimates and could change before being finalized. 5. Scores should be finalized in late spring 2019, and effective starting in the 2020 NHSC application cycle. 6. The national update of all auto-hpsa scores could cause significant reshuffling of which FQHCs are eligible for NHSC providers. 7. Many preliminary scores could be very different from current scores for a variety of reasons, including: the current scores are very old; the PCO has yet to update the provider data in their area; or HRSA s move to standardized data sets and decision rules.