veto of national guidelines promulgated by the Secretary of HEW. The Federation's primary concerns with the initial process in developing proposed national guidelines include: (1) The "in the closet" method by which they were developed and the timing of their distribution by the Department: The law specifically requires the Secretary to "consult with, and solicit recommendations and comments from the health systems state health planning and development agencies. agencies Statewide health coordinating councils associations and specialty societies, representing medical and other health care providers, and the National Council on Health Planning and Development The date the first proposed guidelines were published in the FEDERAL REGISTER, September 23, 1977, was coincidently the first meeting of the fully constituted National Health Planning Council, whose members were furnished copies of the proposals concurrent with distribution to the public. Failure of the Secretary to appoint the Council earlier and to consult with them certainly makes suspect the dedication of the Secretary to carry out the intent of Congress with respect to the development of such guidelines. (2) The inflexibility of the proposed guidelines on local Health Systems Agencies: Health Systems Plans must "be consistent with" the guidelines "where they establish goals and set forth plans not in excess of the level set forth in the guidelines where that level is stated as a maximum, or not less than the level set forth in the guidelines where that level is stated as a minimum except where specific exceptions are provided in the guidelines." Failure to comply would result in disapproval of the Health System Plan and ultimate loss of status and operating funds for the health planning agency. An illustration of both the inflexibility of the proposed guidelines and the misuse of findings of research by HEW concerns the 4.0 beds per 1,000 requirement. The major study was that done by the Institute of Medicine, National Academy of Science, Washington, D. C., entitled "Controlling the Supply of Hospital Beds" and dated October 1976. The following is quoted from Page ix of the study: to "The committee recommends that a national 26-219 O 78 pt. 29 (3) The use of specific quantitative guidelines and formulas: The Federation reiterates its position that whenever specific numbers and formulas are included in guidelines, that such standards should be considered and adapted to the conditions and unique needs of the local areas. To mandate conformance without permitting local consideration and adaptation imposes federal control, which as we interpret the statute and understand the intent of Congress, was not intended. For these reasons we urge modification of P. L. 93-641 to require Health Systems Agencies to take into account the national guidelines, but that Congress repeal the requirement that health systems plans "be consistent with" national guidelines. The process for determining needed local health resources established by P. L. 93-641 must be given a reasonable opportunity for success and that requires federal assistance, but without bureaucratic roadblocks. HSAS are still in the developmental state and consequently they are particularly vulnerable to federal pressures and proposals for substantial expansion of their responsibilities. We urge amendments to P. L. 93-641 which will help HSAS meet the responsibilities already assigned to them in a fair and equitable process and we caution against expansion of their duties or illusions about unlimited cost savings without sacrificing quality of health care. We advocate strengthening the capability of the local health system agencies by assuring that full financial support is provided by federally appropriated . funds, as authorized in the law. This would permit the agency to attract experienced, qualified and professionally trained staff personnel, able to understand the economic, financial, and administrative complexities of providing health services and institutional health care within the availability of health manpower and health facilities resources. We support a three year extension of the Health Planning Act and offer the following comments on the proposed Health Planning Act Amendments of 1978, contained in H. R. 10460. Revision of National Guidelines Section 201 of H. R. 10460 requires the Secre tary to review the goals and standards established for health planning on an annual basis. We recommend that this requirement be changed to direct revision of the goals and standards at least once every two years. would assure a more deliberative process with greater "prior consultation" with state and local planning This authorities, industry groups, and the National Council on Health Planning and Development. We endorse the requirement that revised national goals and standards be based on plans developed at the state and area-wide levels. Contributions to HSAs We oppose Section 208 which would permit HSAS to accept financial support from insurers. Other provisions of H. R. 10460 take great pains to guard against conflicts of interest and we believe funding of HSAs should be accomplished without involving those who are part of the local decision making process. We would oppose provider contributions to HSAS for similar reasons. Membership Requirements We endorse those provisions of Section 209 which require inclusion on HSA governing bodies of elected officials and others broadly representative of the area. We urge expansion of this section to require inclusion of hospital representatives broadly representative of institutions in the area. The expertise of those knowledgeable in hospital administration is a necessary resource for governing board representation on a body charged with major responsibilities for making decisions on appropriate capital expenditures by hospitals. Hospital representation on an HSA executive committee should also be required. |