AAMC Second Comment Letter
to HRSA on Waiver of Matching Requirements for Faculty Loan
Repayment Program
October 31, 2002
Ms. Lorraine Evans
Division of Health Careers Diversity and Development
U.S. Department of Health and Human Services
Room 8-34, Parklawn Building
Rockville, Maryland 20857
Dear Ms. Evans:
Thank you for inviting the Association of American Medical
Colleges (AAMC) to comment on draft guidelines for how the
U.S. Department of Health and Human Services (HHS) proposes
to grant 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.
We also appreciate HHS's fiduciary responsibility to the program.
Having reviewed the draft guidelines, the AAMC suggests a
few changes to assure FLRP's effectiveness without compromising
the program's fiscal integrity.
The AAMC recommends explicitly stating in the guidelines
that requests for waivers will be assessed on a case-by-case
basis and that HHS will consider, as appropriate, other types
of documentation than those listed as examples. This approach
would be consistent with Dr. Lopez's May 1, 2002 letter in
which he states that decisions for waivers would continue
to be made case by case.
The AAMC also recommends that schools be allowed to demonstrate
financial hardship by demonstrating "…consistent
budget cuts over the past two to three years, reduced earnings
on endowments, or unexpected expenditures that would reduce
any extra funding the institution might have available."
The language in the draft guidelines uses the word "and,"
which indicates that schools would have to meet all three
conditions simultaneously. Any one of these circumstances
should be sufficient to demonstrate financial hardship.
The AAMC also supports consideration of other circumstances
that might create financial hardship for an institution independent
of budget cuts, reduced revenues, or unexpected expenditures.
For example, nontraditional medical education venues, such
as community health centers affiliated with teaching programs,
may not have patient-care revenues, state support, or federal
support sufficient to cover the institutional matches. These
entities might operate from year to year with limited resources
to meet their basic missions and, as a result, are unable
to budget or obtain funds for FLRP institutional matches.
Thank you for considering these comments. If you have any
questions, please contact Ruth Beer Bletzinger of my staff
(rbletzinger@aamc.org; 202-828-0585).
Sincerely,
Jordan J. Cohen, M.D.
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