unusual circumstances under which an extension would be granted. However, the conference report states that those unusual circumstances, including "community involvement", are by no means limited to that which the report lists. Furthermore, the Secretary's perfunctory reference to the need for public involvement does not do justice to the importance of public involvement in the ultimate success of a regional plan. Nor does his letter demonstrate a legitimate effort on the part of H.E.W. to become familiar with the situation in Fairfield County. Will this misinterpretation of the legislative intent of the law also prevail when citizens are faced with the more serious questions such as decertifying local medical facilities. H.E.W. has requested this committee to grant H.S.A.'s the power to decertify and I think the committee should take a long look at the quality of the administration of existing statutes before granting further powers under Pub. L. 93-641.

Lest any of the committee members incorrectly believe that the public concern in Fairfield County, to which I refer, is merely the uninformed protestations of some local politician, let me recount for the record the following facts.

The HSP for Fairfield County was first released to the public on Dec. 19, 1977 with the vote for final approval scheduled for February 7. At each of the four public hearings held to consider the planJan. 25, 26, 27, and Feb. 2, 1978-well over 200 people attended. In fact, as mentioned in my letter to Mr. Califano, one meeting was closed because the number of attendees exceeded the legal capacity of the meeting hall. The groups in attendance represented diverse interests within the community, however, there was no question as to the commonality of their goal-an extension of time for meaningful public involvement in the plan. In addition to those attending the meetings, several groups in Fairfield County presented their criticism in well-documented written statements, which were submitted to the Southwestern Connecticut H.S.A. By way of example, a critique was submitted to the H.S.A. by the Stamford Area Commerce and Industry Association [see insert No. 3, p. 917].

Furthermore, Mr. Chairman, in response to the community's concerns, the governing board of the region's H.S.A. stated their willingness to participate in workshops in an effort to resolve any differences that might exist concerning the programs goals. Both the sponsors of the program and its critics were in contact with my office and the H.E.W. regional office in Boston. Clearly, a 90-day extension for public comment—which would have been obtained by a better understanding by H.E.W. of the criterian for that extension-would have insured a successful mandate for the regional health plan in Fairfield County. As it stands right now, Mr. Chairman, the public has been frustrated in their attempts to contribute and shape the program to their particular needs. They are concerned that H.E.W.'s apparent misinterpretation of the law as it pertains to extensions, may be an indication of future uncertainties that could result in the decertification of local medical facilities. They now view this well intended program as one more example of arbitrary, government intervention in their lives.

It is indeed an unfortunate situation. Hopefully it is one that this committee can rectify. I would urge the committee to review the provisions dealing not only with the laws regarding extensions of conditional designation, but with any provisions which might allow the public more meaningful participation in the development of their regional health plan. Furthermore, Mr. Chairman, I would urge the committee to scrutinize the potential for misinterpretation in any additional provisions to the law, especially those concerning decertification. Any further mandate to Pub. L. 93-641 must include clear and unmistakable guidelines for the implementation of its goals.

[Testimony resumes on p. 926.]

[The attachments referred to follow:]

I am writing you in behalf of hundreds of Fairfield County, Connecticut citizens who are interested, as I am, in implementing the most equitable and effective regional health systems plan possible. The concerned citizenry of our area is convinced that the only means by which to insure the implementation of an effective plan is through an extension of the program's deadline for the filing of an application for permanent designation. Your commitment to grant such an extension would allow a continuation of the overwhelming public interest in this program and would assure the public that its concern will not go unheeded.

Pursuant to Public Law 93-641 the Southwestern Connecticut Health Systems
Agency must submit an application for permanent designation on February
13th, to the Department of H.E.W.'s Region I office in Boston. In recent
weeks, upon completetion of its Health Systems Plan, the agency has con-
ducted three public hearings to illicit community comment on the proposal.
At each of these meetings several hundred concerned community residents
have been in attendance. In one instance, the attendance of over 500
people resulted in the cancellation of the meeting by the local fire
marshall's office. Represented at each of these gatherings have been
hospital administrators, consumer groups, industry and commerce executives,
anti-abortion groups, and members of the medical community. The commonality
of their concern belies the diversity of the groups interests and as such,
provides a clear indication that further opportunity for community involve-
ment is warranted. In fact, this relatively cohesive effort by so many
varied interests constitutes both the problem and the potential solution
for which I am requesting your assistance.

Since its publication, the proposed H.S.P. for the Southwestern Connecticut
region has been subject to a great deal of criticism. Despite the strength
of the complaints, however, I do not believe the program's critics wish the
elimination of the regional agency or its function. Rather, these
interested groups would like to continue their analysis of the program
and work with the H.S.A. to implement the best plan for our region.
Similarly, the governing board of our region's H.S.A. has expressed a
willingness to work with the public in meeting that goal. They are,

THIS STATIONERY PRINTED ON PAPER MADE WITH RECYCLED FIBERS

however, understandably concerned that requesting an extension of the public review period, instead of filing an application for permanent designation by February 13th, may result in the rejection of the extension request and thus result in the termination of the agency and its two-year effort.

With the gracious cooperation of Mr. Robert Watson, the regional director of H.E.W.'s Boston office, I have become familiar with the process for reviewing applications for extension. It is my understanding that an extension is granted if "unusual circumstances" prevent the effective completion of the program within the specified time period. Given the uncertainty of the determinants in that review process, I can readily understand the governing boards reluctance to file for an extension. However, the unprecedented public interest in the development of an H.S.P. for this region, and the willingness of all-concerned to cooperate in workshops and other mechanisms for an effective program, has convinced me that an extension is well deserved and should be requested. As is the case with many federal programs the success or failure of the National Health Planning and Resource Development Program will depend on public interest and cooperation. In this particular instance, the success of the program may well be decided by granting the public 90 more days to actively participate.

Your direct intervention in this matter, Mr. Secretary, is needed to assure the governing board that the product of their two year effort will not be jeopordized by the rejection of their 90-day extension request. The board will meet on February 7th to vote either for an application for extension or permanent designation. I would like at that time to be able to give them your written assurance that their extension request will be granted without the loss of the agency.

Furthermore, Mr. Secretary, the public's overwhelming interest in this important health program should not go unrecognized or unrewarded. Anytime the federal government can get as many people actively interested in a federally initiated effort, it should jump at the opportunity to allow the public's involvement to continue unhindered. Granting a 90-day extension for further community involvement in this matter will assure a successful mandate for the program. To deny such a request will certainly result in a lack of community cooperation and will discourage the residents of Fairfield County, Connecticut from further involving themselves in other federal initiatives.

I respectfully urge you, Mr. Secretary, to intervene in behalf of Fairfield County and grant an unqualified 90-day extension. As previously stated, I would like to present to the board, prior to their February 7th meeting, your written commitment for extending the necessary deadlines. I very much appreciate your kind assistance in this matter, and I await your positive reply.

Sincerely,

Stewart B. McKinney, M.C.

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