HHS announcement on physician shortage areas: good news or same old, same old?

A list of geographic areas, population groups, and facilities that have been designated as health professional shortage areas (HPSAs) as of May 29, 2015, was made available by HHS on the Health Resources and Services Administration (HRSA) website (Notice, 80 FR 37637). This information, which includes primary care, mental health, and dental HPSAs, is made public annually pursuant to section 332 of the Public Health Services Act (PHSA) (42 U.S.C. § 254(e)). The publication of the updated lists brings up many questions regarding the current state of HPSAs, what this means for the pending physician shortage, and how the implementation of the Patient Protection and Affordable Care Act (ACA) (P.L. 111-148) affects these issues.

HPSA designation

Section 332 provides that the Secretary of HHS must designate HPSAs based on certain criteria. Specifically, this provision states that HPSAs are urban and rural geographic areas that have: (1)  a shortage of health professionals; (2) shortages serving certain population groups; or (3) facilities with shortages. Further, the list of HPSAs is to be reviewed on a yearly basis and to be updated as necessary. Entities that are located in areas designated as HPSAs are eligible for certain perks, including residency training program grants administered by the HRSA Bureau of Health Workforce (BHW) and increased Medicare reimbursement.

Stats

According to the HRSA data warehouse,  “the “main impact of the [recent HPSA list] publication will be to officially withdraw those HPSAs that have been in ‘proposed for withdrawal’ status since the last [HPSA] publication on June 27, 2013. HPSAs that have been placed in ‘proposed for withdrawal’ status since May 23, 2014 will remain in that status until the publication of the next [HPSA] notice.” Further, according to the warehouse, statistics were updated as of July 1, 2015. However, compared to numbers posted on the HRSA website from June 19, 2014, the meaning behind the newly released numbers is unclear at best. For instance, the 2014 data shows that “there are currently approximately 6,100 designated primary care HPSAs…4,900 dental HPSAs… [and] 4,000 mental health HPSAs.” The newly released 2015 data states that there are: 1) 6,176 designated primary care HPSAs; 2) 5,064 dental HPSAs; and 3) 4,155 mental health HPSAs.

Physician shortage issues

The 2014 numbers and newly released 2015 designations appear to be approximately the same, yet the continued existence of these numbers of designated HPSAs, especially in the area of primary care and mental health, might be telling in and of itself. Thus, the question is raised, to what extent are the numbers of HPSAs indicative of a nation-wide physician shortage? A report released early in 2015 by the Kaiser Family Foundation (KFF) highlighted that 58 million Americans “reside in geographic areas or belong to population groups,” which are considered HPSAs. Furthermore, the KFF report predicted that the demand for primary care services would rise over the next five years.

HPSAs and the ACA

In that light, the next pressing question in this discussion becomes, to what extent does the ACA affect HPSAs and the physician shortage? According to the KFF report, the extent to which the ACA has reduced the shortage of primary care services is limited. “The demand for primary care is projected to rise over the next five years, due largely to population growth and aging, and to a smaller extent, to expanded health insurance.” However, the ACA does include provisions to incentivize physician practice in HRSAs. As we previously reported on the WK Law & Health blog, ACA provisions offer those HRSA primary care physicians bonus payments under the Medicare program as well as grants to entities in HRSAs that operate certain nurse practitioner training programs.

As the ACA provisions continue to be implemented, will the HRSA numbers remain or will the ACA provisions eventually reduce the numbers of HRSAs?