On behalf of the Association of Asian Pacific Community Health Organizations (AAPCHO), the Asian & Pacific Islander American Health Forum (APIAHF), and Out of Many One (OMO), we are pleased to respond to the above-cited notice from the Health Resources and Services Administration (HRSA) within the Department of Health and Human Services (DHHS) soliciting comments on HRSA’s intent to establish a Negotiated Rulemaking Committee under a Federal Advisory Committee Act (FACA) in order to establish a comprehensive methodology and criteria for the designation of Designation of Medically Underserved Populations (MUPs) and Primary Care Health Professions Shortage Areas (HPSAs).
AAPCHO is a national organization representing 27 community health organizations that primarily serve Asian Americans, Native Hawaiians, and other Pacific Islanders (AA&NHOPIs), particularly the medically underserved including a majority living under poverty level and who are limited English Proficient (LEP). AAPCHO members, predominantly community health centers, serve over 350,000 patients annually, providing health care for underserved AA&NHOPIs across the nation, its territories and freely associated states. APIAHF influences policy, mobilizes communities, and strengthens programs and organizations to improve the health of AA&NHOPIs. APIAHF is recognized as a leading voice for health policy on behalf of Asian Americans(AAs) and in support of Native Hawaiians and Pacific Islanders (NHOPIs) in the U.S. and its jurisdictions. OMO is a national multicultural advocacy coalition committed to achieve health parity for people of color. OMO’s membership is comprised of organizations representing the five OMB categories for the major racial and ethnic health groups that experience health disparities in the United States.
We appreciate HRSA’s efforts in developing a more coordinated MUP and HPSA designation methodology and procedure. Further, we strongly support utilizing the NRM process to develop the designation methodology and procedure. However, we have some concerns regarding the procedure outlined in the Notice. We believe there is room for modification to ensure that the unique needs of many underserved minority populations served by CHCs are considered and make the following recommendations:
To read more, download our comments below.
NRC Submission Final 6-10-10 Comment and Nomination (124.6 KiB, 461 hits)
