*EOO 833*





                                                                                    RLP: 9/'30/74



                                          Area Desip;i-iati.on IssueE; & Pr(.-])Ie-i,.-,



                     Design@.ition  of  health  services  areas  will  be  an  important,   initial   step
                     in the implementation of the Health Rcsour(ies Planning (IIPP) program.
                     Several  major  issues  and  problems  have  been  identified  in   our   planning   and
                     preliminary  implementation  efforts   to   date   relative   to   area   designation
                     (AD).  Those  efforts  have  been  based  largely  upon  II.R.  16201@  and  the   draft
                     House,Comniittee report.

                            1. Only two objective AD requirement arc! legislatively mandated.
                               They relate to  population  and  S@lS@Als,  and  compliance  can  be.  readily
                               determined.  To  wiat  extent  do  we  want  to   effectively   limit   the
                               AD  requirements  to  these  and  all.ow  governs  wide   latitude   witiin
                               the dynamics at work within their own States, in waking designations?

                            2. Waivers  to  both  the  minimum  population  and  S."JSA  requirements,   arc
                               permitted. It  is  assumed  that  relatively  few  x@7aiv,-@.rs  should  be
                               granted.  To  what  extent,howevctr,  do  we  want  to  try   to   "influence"
                               the designations to be made by (@overno""4'through the criteria employed
                               in reviewing waiver requests, grantin- or denyin- there,  (1,C)r example,
                               we probably want to  discourse  governors  from,  chipping  fit,  exi@;tiii@,
                               areas that now have reasonably effective functioni-n- CIIP         or   other
                               agencies and meet the mandated requirericnts.)

                            3. Approval (or disapproval) of proposed designations, :Lncluding
                               waiver requests, is reserved to the Secretary.  Who should exercise
                       0       on his behalf the official- as oppose-          tic   effective    approval
                               authority?  (It  is  assumed  that  regional  offices  N.,,ill   work   the
                               principal responsibility for reviewing proposed designations,
                               and that their recommendations wil.1 be tanual'i-oLint  to  @ipproval  i.ri.
                               the great majority of instances.)

                            4. A small ad  hoc  revie@.7  panel  consisting  of  both  regional  (RC@)  and
                               central office (CO) Staff, has been sugoasted to handle exceptions.
                                                                             C,
                               What  should  constitute  an  exception?   For'   example,   all   requested
                               waivers, or only  those  where  RO  staff  and  CO  staff  diL@agl--ee;  any
                               designation that meets the population ai)-.' SL@ISA re-quireif'.,@ilts  but
                               which, for whatever reasons a RO recoj,-,mords disapproval?

                            5. Governors are required to suL)n-,.it  their  tiD  plans  wi.thiii  90  days
                               after  the  initial  notice  in  the  Federal  Re-ister  (F-.R);  and   the
                               Secretary in turn must publish  approved  desiciiations  -in  tiio--  I,',R
                               within 150 days of that noti-ce.       I,,7itl-iii @-hose. 60 days reviews @,ilust
                               take place.    Little tiioe will refrain after review t-.o (1) negotiate
                               substantive revisions required as a re-su--tt- (@f waiver re-quests
                               denied or other non---approval  actiofis  or  (2)  for  the  Scc---etary  to


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                          designate acceptable areas in lieu thereof.  Should a minimum
                          grace period of 30 or 60 days be permitted?  W4-th or without such
                          a grace period, who at the Federal level should be responsible
                          for designating areas when negotiations have-failed; and how should
                          this be done?