AAMC Comment Letter to HRSA
on Waiver of Matching Requirements for Faculty Loan Repayment
Program
August 27, 2002
Ms. Lorraine Evans
Division of Health Careers Diversity and Development
U.S. Department of Health and Human Services
Room 8 -34, Parklawn Building
5600 Fishers Lane
Rockville, MD 20857
Dear Ms. Evans:
The Association of American Medical Colleges (AAMC) appreciates
the invitation to provide input as the Health Resources and
Services Administration (HRSA) revisits the criteria for waivers
of the institutional matching requirements under the Faculty
Loan Repayment Program (FLRP). The AAMC represents the nation's
125 accredited medical schools, nearly 400 major teaching
hospitals and health care systems, 98 academic and scientific
societies representing more than 105,000 faculty members,
and the nation's 164,000 medical students and residents.
The AAMC supports FLRP's goal of attracting and retaining
health professions faculty from disadvantaged backgrounds.
Despite limited resources, we believe that the program presents
a meaningful approach to increasing diversity in academic
medicine and the health professions workforce. As a result,
we strongly support the program and continuation of the matching
funds waiver for schools.
With respect to implementing waivers for the institutional
matching requirement, the AAMC applauds HRSA's intention
to continue to review requests on a case-by-case basis. This
flexible approach is especially important in these
economically challenging times, when medical institutions are operating
under tight fiscal constraints with little surplus cash to meet a host
of competing priorities that include addressing disparities in health
care treatment and outcomes. As a result, even without a reduction in
resources from one year to the next, a medical school or affiliated clinical
site can experience "undue financial hardship" by not having discretionary
revenues available to dedicate to matching funds for FLRP.
For instance, clinical campuses affiliated with medical
schools that consist of partnerships with
local hospitals and community health centers necessarily direct resources
to safety-net programs. Because of limited revenues, it is difficult
for such sites to expand the number of faculty members who have expertise
in specialties needed by underserved populations. Programs like FLRP
offer meaningful incentives that help build the health care provider
base for these communities. As a result, the AAMC recommends that HRSA
guidelines take into account the type and location of the service in
which a faculty member applying for FLRP funds is engaged. Examples include
faculty members who treat underserved populations and train medical students
at disproportionate share hospitals, Indian reservations, maternal-child
health clinics, children's hospitals, federally funded health centers
and look-alikes. Also, the documentation requirements for waiving the
matching funds for training in these settings should include alternatives
to having institutions demonstrate a reduction
in revenues or other funding.
The AAMC looks forward to reviewing and commenting on HRSA's
draft criteria before final guidance is published. In addition,
we encourage HRSA officials to meet with representatives from
the health care disciplines before final guidance is published
to avoid promulgating waiver requirements that have unintended
harmful effects on populations with limited access to health
care and on otherwise eligible faculty members. Please contact
Ruth Beer Bletzinger of my staff, <rbletzinger@aamc.org>
(202) 828-0585, with any questions.
Thank you for your consideration.
Sincerely,
Jordan J. Cohen, M.D.
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