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January 28, 2008 Claire Burman Dear Claire: This letter responds to the 1st Notice publication of proposed rules to amend 77 Ill. Adm. Code 1100 that was published in the Illinois Register on December 14, 2007. The amendments reflect changes to the Act mandated pursuant to P.A. 95-0005 related to time horizons for population projections and the use of a 50% migration factor for medical/surgical and pediatric services. In addition, changes are proposed related to how travel times are evaluated. IHA’s comments focus on new definitions, travel time standards, and the future evaluation of migration factors and occupancy targets. The remainder of this memorandum will address our specific comments. Section 1100.220 Definitions A new definition has been added for "Fertility Rate." Your proposed definition says that this means "determinations by IDPH of population fertility that is based upon resident birth data for an area." This is a very general definition. If the definition is this general, I question why a definition is needed at all. Since there are standard definitions for fertility rate that have been developed by epidemiologists and that are commonly used in the public health community, I would suggest that a definition that is commonly accepted be used. For example, on the web site of the Centers for Disease Control, fertility rate is defined as "the total number of live births, regardless of the age of mother, per 1,000 women of reproductive age, 15 – 44 years." Having a standard definition based on a national standard will help applicants assess their own data and compare it to other communities. A definition of "Patient Migration" has also been incorporated. There appears to be an internal inconsistency in the definition. The broad definition of "Patient Migration" says that this means the number of patients who reside in a planning area and receive services in another planning area. The definition goes on to clarify that this really means out-migration since in-migration means the number of residents form outside the planning area who receive services within it. As a result, the term "Patient Migration" seems to have no meaning. I would suggest that this definition would be simpler if in-migration or out-migration were segregated, or if the general definition of patient migration simply referred to the movement of patients either in or out of a planning area for services. A new definition has also been added for "Population Estimates." While the definition says that population estimates should be based on birth and death records and other inputs, it does not cite the most important underlying data source – census data. Census data is more that simply another input. The new definition of "Population Projections" requires that these be based upon State of Illinois population projections, as available. While the State’s data are valuable, these rules should not preclude the use of other data that are accepted by planners in both health care and other industries, and that may enable more sophisticated analyses. IDPH would still have the opportunity to approve another data source, but the rules should not automatically reject the use of other data. Section 1100.510 Introduction, Formula Components, Planning Area Development Policies, and Normal Travel Time Determinations With respect to normal travel time (Sec. 1100.510(d)), we appreciate the fact that additional flexibility is being codified for MapQuest travel times. This should ameliorate some of the problems applicants have had using MapQuest data. We also recognize that no single data source will ever be completely accurate. Therefore, we would suggest that other mapping software available on the internet should also be acceptable. We also appreciate that independent travel studies will now be accepted. While any travel time study can be questioned, this will allow the Board to have more information so they can make the best judgments on application decisions. Section 1100.520 Medical-Surgical and Pediatric Care First, I question why the title to this section is being changed so that it no longer reflects the term of art, category of service. Beyond that we recognize your statutory obligations to look at longer time frames for population projections and to use migration factors that are at least 50% for medical-surgical and pediatric services. These changes should be implemented consistent with the statute. We would also suggest that the IHFPB take a longer perspective and evaluate with current, accepted, and sophisticated data sources, how planning areas are delineated and whether migration factors are the best mechanism to determine need. Other industries may have models that the IHFPB could incorporate into its thinking. In addition to these specific comments, we note that this rulemaking also addresses other categories of service (primarily re-organizing language). We would suggest that further changes are needed based on meetings you have held on rules re-development. One of our main concerns relates to occupancy targets. These should be adjusted based on more current utilization patterns, the trend towards single occupancy rooms and other factors. I urge you to move forward with these changes in a future rulemaking in order to make your regulations more consistent with how inpatient care is delivered in 2008. If you should have any questions regarding my comments, I would be happy to respond to them. Sincerely, Ann Guild | |
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