Maternity Care Health Professional Target Area Criteria Request for Information (RFI)

Action: Request for Information: Maternity Care Health Professional Target Area Criteria
Summary: The Health Resources and Services Administration (HRSA) seeks public input and feedback to inform policy considerations related to the establishment of criteria for Maternity Care Health Professional Target Areas, as described in this Request for Information (RFI), and to solicit additional ideas and suggestions from the public related to these topic areas.
Date: 5/21/2020

I. Overview of this RFI

HRSA is responsible for the implementation of requirements contained in the Improving Access to Maternity Care Act (P.L. 115-320; Public Health Service Act, Section 332(k)). These requirements include:

(1) the establishment of criteria for “maternity care health professional target areas” (MCTAs), that identify geographic areas within primary care health professional shortage areas (HPSAs) that have a shortage of maternity care health professionals;

(2) the identification of MCTAs using the criteria established by HRSA;

(3) the distribution of maternity care health professionals using the newly-identified MCTAs; and

(4) the collection and publication of data comparing the availability and need for maternity care health services in HPSAs and in areas within such HPSAs. 

Current plans for implementation interpret the Act’s reference to “areas within such HPSAs” as a reference to MCTAs; subsequently the collection and publication of data components will follow the development of MCTA criteria and MCTA identification.

HRSA’s shortage designation activities are authorized by section 332 of the Public Health Service Act, 42 U.S.C. § 254e. Under this authority, HRSA designates geographic areas, population groups within geographic areas, and certain facilities as HPSAs. Per statute and regulation, HRSA assesses three types of HPSAs by discipline: primary care, dental health, and mental health. After a HPSA is designated, it receives a score according to established criteria. Higher scores generally indicate greater levels of need. Scores for primary care range from 0-25. As of December 31, 2019, there were 7,655 primary care HPSAs in the United States.

While several federal programs now use HPSAs to determine eligibility or competitiveness for federal resources, HPSAs were originally developed to distribute National Health Service Corps (NHSC) providers to areas and facilities with the greatest need. Since its inception in 1972, the NHSC has worked to support qualified health care providers dedicated to working in underserved communities in urban, rural, and tribal areas. The NHSC provides loan repayment awards to eligible health providers, as well as scholarships to students, in return for commitments to serve in NHSC-approved sites located in HPSAs. Prior to the passage of the Improving Access to Maternity Care Act, eligible NHSC maternity care providers were distributed using primary care HPSA scores. Once MCTAs are identified, maternity care providers receiving NHSC awards will be distributed using the MCTAs. Per statutory requirements, MCTAs will be identified within primary care HPSAs (i.e., not in dental or mental health HPSAs or in currently non-designated areas).

HRSA recognizes the vital role that NHSC providers play in making health services available in communities in need. In an effort to solicit broad feedback in its implementation of the requirements of the Improving Access to Maternity Care Act (and in accordance with statutory requirements), HRSA has issued this RFI to request input on the development of criteria that will then be used to identify the MCTAs. While HRSA welcomes input from all stakeholders and parties with an interest in our mission, we specifically seek input from those with knowledge of public health strategies to improve maternal health and health care delivery, including, but not limited to, relevant provider organizations, medical societies, organizations representing medical facilities, or other organizations with expertise in maternity care.

II. Solicitation of Feedback

HRSA is seeking input from the public on considerations that may inform HRSA decisions regarding the criteria for and identification of MCTAs. 

The requirements of P.L. 115-320 are incorporated in section 332 of the Public Health Service Act. These note that MCTAs will only be identified in areas within existing HPSAs1, and that the Improving Access to Maternity Care Act does not extend eligibility for NHSC awards to new provider types2. As a result, only maternity care providers who are currently eligible to receive NHSC awards will be distributed using the MCTAs. Furthermore, the requirements define the term “full scope maternity care” as health services provided during labor care, birthing, prenatal care, and postpartum care3

Whenever possible, respondents are asked to draw their responses from objective, empirical, and actionable evidence and to cite this evidence within their responses; bearing in mind the applicable standards set forth in law, regulations, and policy described below. Please note that HRSA will not respond to proposals to expand NHSC eligibility to new provider types, nor will HRSA consider including non-eligible providers in population-to-provider ratio counts, as these parameters are explicitly set by statute. HRSA may or may not choose to contact individual responders. Such communications would only serve to further clarify written responses.

HRSA welcomes feedback on the areas of consideration outlined below, as well as more general feedback or suggestions.

III. Development of Criteria for MCTAs

1. Providers and Populations

Specific suggestions for how HRSA should consider which providers and populations to incorporate into MCTA criteria. See Section 332(k) of the Public Health Service (PHS) Act.

Areas of Consideration for Public Input Relevant Statutory, Regulatory, and Policy References
A. Whether to include a population-to-provider ratio. Health Professional Shortage Area (HPSA) designation and scoring criteria currently use population-to-provider ratios, as required by law. The PHS Act does not require such a determination for MCTAs, which must be located within existing HPSAs. Section 332(b)(1) of the Public Health Service Act.
B. Which Populations to include. If population counts are included or population-to-provider ratios continue to be used in HPSA scoring, several different population subsets could be incorporated.  

C. Which Maternity Care Health Providers to include. If provider counts are included, different provider types could be incorporated. HRSA is seeking input from stakeholders as to which provider types should be included in the criteria for MCTA identification. Additionally, HRSA seeks recommendations for how to count providers (e.g., recommendations noting how many FTE each provider type should count as).

The following primary care provider types are currently eligible for NHSC awards:

Primary Care Disciplines Eligible for NHSC Awards and Eligible Specialties:

  • Allopathic physicians (MDs) and Osteopathic physicians (DOs)
    Specialties include:
    • Family Medicine
    • General Internal Medicine
    • General Pediatrics
    • Obstetrics/Gynecology
    • Geriatrics
  • Physician Assistants (PAs) and Nurse Practitioners (NPs)
    Specialties include:
    • Adult
    • Family
    • Pediatric
    • Women’s Health
    • Geriatrics
  • Certified Nurse-Midwives (CNMs)
    Specialties include:
    • N/A

Any recommendations should cite data that are publicly available, frequently updated, and specific to the county or census-tract level.

Section 332(k)(1) of the PHS Act; Section 332(k)(6)(B) of the PHS Act

FY 2020 National Health Service Corps Loan Repayment Program Application and Program Guidance – New Awards.

2. Data Points

Specific suggestions for which data points HRSA should consider incorporating into MCTA criteria are listed below, although this is not an exhaustive list. Respondents are asked to consider attributes of potential data sources these points could be drawn from (see section 3 below). Such data points may include, but are not limited to, severe maternal morbidity data, maternal mortality data, women’s health indicators (e.g., gestational diabetes, preeclampsia, preconception health, etc.), demographic data (e.g., race, educational attainment, income, etc.), provider data, economic data (e.g., poverty rates), infant mortality data, or other relevant data points (e.g., social determinants of health). In suggesting data points, please provide input on the extent to which proposed data points reflect relative need for maternity care services.

Areas of Consideration for Public Input

  1. Severe Maternal Morbidity & Maternal Mortality 
  2. Women’s Health Indicators (e.g., rates of gestational diabetes, preeclampsia, preconception health, etc.)
  3. Demographic data (e.g., race, rates of educational attainment, income, age ranges or other relevant population data, etc.)
  4. Provider data 
  5. Economic data (e.g., poverty rates)
  6. Infant health indicators (e.g., rates of prematurity, mortality, low birth weight, etc.)
  7. Other relevant data points (e.g., social determinants of health)

3. Data Sources

HRSA seeks input as to which data sources to use to ensure equitability and transparency in MCTA identification. While many sources of data are available for shortage designation in general, HRSA is open to using any additional data sources that will help fulfill the statutory mandate to distribute resources and providers to the areas of the greatest need. In proposing data sources, respondents should consider the following:

Areas of Consideration for Public Input

  1. Universality. To what extent are the proposed data sources available for all 50 states, as well as U.S. territories, and collected in the same manner?
  2. Accessibility. To what extent are proposed data sources free and available to the public?
  3. Reliability. To what extent are proposed data reviewable and published by reliable sources?
  4. Specificity. To what extent are proposed data sources available at the county, sub-county, and/or census tract level?
  5. Current and up-to-date. To what extent are proposed data sources current, and how frequently are they updated?

IV. Submitting Feedback

Respondents must provide responses to this RFI via email to RFIComments@hrsa.gov and you must reference “Maternity Care Health Professional Target Area Criteria RFI” in the subject line. Please include organization name, state, and partners (if applicable) in the body of the email. Your response should note the specific RFI question your comment addresses. If you provide comments to more than one question, please identify the specific RFI question each comment addresses. Information obtained as a result of this RFI may be used by the Government for program planning on a non-attribution basis. Respondents should not include any information that might be considered proprietary or confidential. HRSA is not obligated to respond to or directly address individual feedback. Comments will be received through 7:30 p.m. ET on 9/18/2020.

V. Note to Commenters

This RFI is issued solely for information and planning purposes; it does not constitute a Request for Proposal, applications, proposal abstracts, or quotations. This RFI does not commit the Government to contract for any supplies or services or make a grant or cooperative agreement award or take any other official action. Further, HRSA is not seeking proposals through this RFI and will not accept unsolicited proposals.

HRSA is not obligated to summarize or publish a response to feedback received, or to respond to questions about the policy issues raised in this RFI. Responders are advised that the U.S. Government will not pay for any information or administrative costs incurred in response to this RFI; all costs associated with responding to this RFI will be solely at the interested party’s expense. Not responding to this RFI does not preclude participation in any future procurement or program, if conducted. It is the responsibility of the potential responders to monitor this RFI announcement for additional information pertaining to this request.

Public Health Service Act, Section 332(k)(6)(A); (42 USC § 254e(k)(6)(A)).
2 Public Health Service Act, Section 332(k)(6)(B); (42 USC §254e(k)(6)(B)).
3 Public Health Service Act, Section 332(k)(5); (42 USC §254e(k)(5)).

Date Last Reviewed:  May 2020