AAMC Comment Letter on HHS
Draft Strategic Plan
September 5, 2002
Office of Strategic Planning
Attention: Vijaya ChannahSorah
Department of Health and Human Services
Room 447-D Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, D.C.
Dear Sir or Madam:
The Association of American Medical Colleges appreciates
the efforts of the Department of Health and Human Services
to engage the public in a dialog on the goals, objectives,
and implementation strategies proposed in the draft revised
DHHS Strategic
Plan. The Strategic Plan has the potential to help focus
DHHS's investments of effort and resources, thus we consider
it an important exercise.
The AAMC represents the nation's 125 accredited medical schools,
nearly 400 major teaching hospitals and health care systems,
more than 105,000 faculty in 98 academic and scientific societies,
and the nation's 66,000 medical students and 97,000 residents.
As such, the Association has a vital interest in many of the
programs and services administered by the Department of Health
and Human Services.
A number of AAMC staff members participated in the stakeholder
meeting convened by the Department on August 29th. They shared
with the Department's staff many comments on the draft Strategic
Plan. We would like to use this opportunity to highlight just
a few of our concerns with the draft document.
The AAMC commends DHHS's Strategic Plan for expressing the
Department's commitment to improving health care for at-risk
populations, including racial and ethnic minorities. However,
in light of recent research, including the groundbreaking
Institute of Medicine report, Unequal Treatment: Confronting
Racial and Ethnic Disparities in Health Care, we feel that
the plan generally overlooks the critical importance of building
a diverse and culturally competent health professions workforce.
While this is partially addressed in Goal 4 (enhancing the
health science research enterprise), it is absent from Goal
1(reducing major threats to health), Goal 3 (increasing access
to sustained health for the nation's children and adults),
and Goal 5 (improving the quality of health care). For example,
Goal 3 includes objectives to expand the health-care safety
net (Objective 3.2) and eliminate racial and ethnic health
disparities (Objective 3.4). However, neither objective acknowledges
that culturally competent health providers representing the
nation's diverse populations are key to creating an effective
safety net, assuring access, and improving health outcomes.
Further, mechanisms to encourage diversity in the health care
workforce are rarely presented in the plan. Such mechanisms
include establishing education pipeline programs and expanding
funding for both front-end efforts, such as financial aid
for students, and back-end initiatives, such as minority faculty
recruitment and career development programs.
The AAMC, in collaboration with other professional groups,
is committed to preparing the nation's health system to respond
to a bioterrorist event. As such, we are a founding member
of the Partnership for Community Safety, a coalition of front-line
providers dedicated to strengthening community readiness to
respond to biological, chemical or nuclear terrorism or other
natural disasters. We are pleased that the strategic plan
highlights, in Objective 2.1, the need to build capacity to
respond to public health threats in a timely manner. We feel
an essential component of this goal is increasing hospital
capacity and improving the preparedness of the health care
workforce through training and education. Consequently, the
AAMC launched the initiative First Contact, First Response,
which is designed to ensure physician readiness to terrorism
by including specific educational experiences for medical
students, resident physicians, and practicing physicians at
our member medical schools. An expert panel met in May and
will present its recommendations on bioterrorism-related material
in the medical school curriculum in the next couple of months.
The Association recognizes the need for more information
regarding health care quality and costs. Objectives 3.3, 5.2,
and 5.3 demonstrate the Department's commitment to this area
by setting goals related to developing tools and "report
cards" regarding price and quality of care. Teaching
hospitals and academic physicians are committed to providing
high quality care to this nation's sickest and most complex
patients. As the Department seeks to develop price and quality
measurement and reporting systems, it will be important that
these systems address the complexity of the patient populations
treated by various providers and their associated costs of
care.
In Objective 3.2 (Expand the health care safety net), regarding
primary health care services for underserved populations,
there is the glaring omission of the Title VII and VIII health
professions programs, which are designed specifically to enhance
the size and quality of the health workforce that delivers
primary care services. These programs are an essential component
of the health care safety net and complement the Community
Health Centers and National Health Service Corps programs
by filling the pipeline with individuals who will provide
care to indigent and underserved populations. In addition,
these programs are essential to meet the goal outlined in
Objective 3.4 of eliminating racial and ethnic disparities,
as they are designed to diversify the health care workforce
by recruiting underrepresented minorities, a need not met
by any other federal program. The AAMC strongly supports these
programs that support the education and training of a variety
of health professionals, including primary care physicians
needed in underserved areas.
We strongly support Goal 4, "Enhance the capacity and
productivity of the Nation's health science and research enterprise."
However, the underlying objectives do not address the critical
role HHS plays in ensuring that adequate research capacity
exists at academic institutions, particularly medical schools
and teaching hospitals, to perform the research called for
in the plan. Recent advances in science, and the resulting
plethora of new scientific opportunities, have generated tremendous
demand for new facilities and sophisticated (and expensive)
instrumentation. The Department has a critical role to play
in ensuring that such research capacity needs are addressed
if a robust research environment is to be maintained.
We are very supportive of the inclusion, under Objective
4.5 of the Department's goal to "Promote the development
and use of valid accreditation for human subjects protection
programs." The AAMC was one of the founding organizations
of Association for the Accreditation of Human Research Protection
Programs (AAHRPP). AAHRPP offers accreditation to institutions
engaged in research involving human participants. It seeks
to both ensure compliance and to raise the bar in human research
protection by helping institutions reach performance standards
that surpass the threshold of state and federal requirements.
However, the entire process uses a voluntary, peer-driven
educational model. We urge the Department to include the important
modifier "voluntary" in its description of accreditation
programs.
The AAMC is committed to improving the quality of health
care services and reducing harm to patients that occurs as
a result of preventable medical errors, as outlined in Goal
5. We feel it is important to support the development of information
systems and new technology for clinical settings, but emphasize
the need for funding if hospitals are to implement these new
systems. An essential aspect of reducing errors, the reporting
system, will be ineffective if there are not guarantees that
the information reported is privileged. Without protections
for this data, individuals will be less likely to report adverse
events.
While the AAMC is supportive of streamlining DHHS's functions
as outlined in Objective 8.1, we remain concerned that the
consolidation of offices that interact with the public, such
as the public affairs and legislative offices, may only serve
to decrease their openness and accessibility. The AAMC has
excellent relationships with a number of agencies, including
the NIH, and would regret if the bureaucratic network that
can be present at the Department level stifled that rapport.
We ask that HHS consider the value of each agency's ability
to work first-hand with its many constituents.
The Association of American Medical Colleges appreciates
the opportunity to comment on the Department of Health and
Human Services' draft revised DHHS Strategic Plan. Please
feel free to contact us should you have any questions about
our comments or if we can be of further assistance.
Sincerely,
Jordan J. Cohen, M.D.
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