Project Updates – Health and Human Services

  • Wednesday
    February 15th,
    2012

    Comments to the Virginia Board of Health on Access to Health Care

    Recently, women’s health has been a topic of national news. It’s also made headlines in Virginia where the state government has taken steps that could effectively shutter many women’s health clinics.

    But they may have veered off track legally.

    Twenty-two clinics that perform five or more first-trimester abortions per month have been reclassified as hospitals, subjecting them to a host of new rules and requirements and putting them under threat of closure. These clinics provide a range of health care services including cancer screenings, vaccinations, blood work and regular physical check-ups from people who might not otherwise be able to afford care.

    This reclassification would require clinics to overhaul their buildings’ layouts to increase operating room and hallway sizes. Construction would force them to close until they could secure new facilities.

    But there is a legal problem: before implementing this regulation, the state government failed to take into account the costs and benefits and offered no possible alternatives—both are required by state law before the rule becomes permanent.

    We submitted comments today to the Virginia Board of Health urging them to conduct a robust cost-benefit analysis before the rule becomes permanent next year. If they fail to do so, they will be subject to legal challenges.

    Issue(s): Health and Human Services   Type: Public Comments

  • Wednesday
    January 18th,
    2012

    Letter to HUD on Homelessness

    The Dept. of Housing and Urban Development has issued two proposals that would significantly alter the way the government handles homelessness and institute major improvements to the agency’s work; Policy Integrity recently submitted a letter on both.

    One proposal, named the Emergency Solutions Grant (ESG) program, would shift the focus of government programs away from providing short-term emergency housing toward providing long-term homelessness prevention. The other proposal would improve HUD’s Homeless Management Information Systems (HMIS) and related procedures for collecting and tracking data related to homelessness.

    The letter guides HUD in evaluating the performance of its restructured ESG program, with an eye toward sponsoring the collection and analysis of relevant data at the local and national levels. Our recommendations include using evidence-based decision-making to evaluate ESG grants and funded programs, in line with the requirements of the Homeless Emergency Assistance and Rapid Transition to Housing Act of 2009 (HEARTH Act), under which both proposals are being promulgated.

    HUD is modifying the HMIS regulations in order to require the collection of new information; this update will help ensure that HMIS is the central repository for all information about homeless individuals who participate in a “continuum of care,” meaning that they receive various types of public aid related to their housing, such as rental assistance along with other social services. The letter recommends that HUD modify the regulations to providing additional encouragement guidance for local data collection and to requiring the collection of both pre-intervention and post-intervention data in order to better monitor the long-term effects of ESG funded programs.

    Furthermore, the regulations should be modified to enhance the ability of localities to link up their databases and to share information with researchers; this is necessary so that researches do not need to rely solely on self-reporting by clients of homelessness prevention programs for data collection. HUD should also implement standards for national data collection to facilitate nationwide research on homelessness prevention and to provide a more user-friendly and information-rich framework for analysis—as it stands, current regulations require to obtain HMIS data from individual local studies.

    Issue(s): Health and Human Services   Type: Letters

  • Wednesday
    July 6th,
    2011

    Letter to HHS on Proposed Transparency Reporting Rule

    Policy Integrity submitted a letter today to the Department of Health and Human Services on its upcoming Transparency Reporting rule, mandated by the Affordable Care Act of 2010. The rule would develop uniform disclosure standards for group health plans and health insurance issuers, requiring them to provide consumers with new, more detailed information on likely co-pays for particular plans or treatments; providers would also have to provide consumers with a document that summarizes benefits and explains coverage clearly in four pages or less.

    To maximize benefits to insurance shoppers, HHS should establish a clear and easily comprehensible disclosure format free of overly technical language and extraneous information. This will help insure that readers do not skip over important information.

    HHS should also tailor its rule for consumers, using cues to steer people away from bad decisions. For example, HHS could require that common medical problems be presented up front with statistics on their occurrence depending on age and other risk factors to compensate for the fact that individuals tend to underestimate risks to their lives and health.

    Additional benefits of the proposed rule include making it possible for regulators to use the disclosure information to facilitate industry monitoring, and creating a more robust market in which plans and providers could be forced to compete on both price and quality once more informed consumers are able to judge policies on both rubrics.

    Issue(s): Health and Human Services  

  • Monday
    June 20th,
    2011

    Letter to HUD on Proposed Homeownership Education Counseling Standards

    Policy Integrity submitted a letter today to the Department of Housing and Urban Development (HUD) on its proposal to adopt the National Industry Standards for Homeownership Education Counseling as mandatory, industry-wide requirements. The new regulations would primarily function as a government-certified labeling program, comparable in some respects to the USDA’s National Organic Program or EPA’s Energy Star program. The standards represent a significant effort on part of the homeownership counseling industry to ensure quality and consistency nationwide and, by using them as a template, HUD has a head start on crafting regulations that could provide significant benefits to individuals and families looking to navigate the complex process of buying and financing a home.

    One area of concern, however, is language in the agency’s proposal suggesting that it plans to incorporate the industry standards “by reference” into its regulation. While making the standards mandatory could result in more competent and knowledgeable counselors for consumers, HUD must nevertheless do more than simply adopt wholesale standards that were set by the industry. Instead, HUD should conduct a more in-depth analysis of each standard, assessing whether there is indeed a need for it in the market, and whether it should be modified before becoming part of the regulation. All major costs and benefits should be taken into account, possibly using break-even analysis on individual provisions in cases where data is limited.

    Key components of the regulation should be informed by evidence-based decision-making, as HUD should collect evidence on what works in homeownership education or sufficiently analogous fields and use that evidence to set standards. Alternative regulatory approaches should also be considered, such as requiring counselors to pass stringent exams. Also, the issue of enforcement should be considered when creating the new rules, and refine the language of the original standards with an eye toward facilitating enforcement. In order to be responsive to changes in the mortgage industry and to the needs of prospective and current homeowners, HUD should also pay particular attention to the need for flexibility in this rulemaking, and incorporate into the rule a plan for regular program evaluation.

    Issue(s): Health and Human Services  

  • Monday
    April 4th,
    2011

    Public Comments on Proposed PREA Standards

    Today, Policy Integrity submitted comments to the Department of Justice (“DOJ”)on its notice of proposed national standards to detect, prevent, and reduce the incidence of sexual abuse in the nation’s prisons. The proposal implements the Prison Rape Elimination Act of 2003 (“PREA”), which created the National Prison Rape Elimination Commission to study of the impacts of sexual assault in the United States; standards ultimately suggested by the Commission inform much of the DOJ’s proposed rule.

    Our comments recommend that in adhering to its statutory mandate to not exceed “substantial costs” while promoting the goals of PREA, the DOJ should cleave to an interpretation of the word “substantial” that takes adequate account of both the potential compliance costs and the benefits – short and long-term – of implementing the proposed standards. Also, the Department should conduct a re-examination of its proposed video monitoring, auditing, and immigration facility standards to assess the costs and benefits of adopting various intermediate policy alternatives in these areas.

    Finally, the Department’s rejection of the Commission’s Supplemental Standards for Facilities with Immigrant Detainees and ICE Family Facilities is not supported by any economic analysis. Rather, it is likely that applying some of the PREA standards to immigration facilities would be economically justified. Department should conduct analyze the costs and benefits of adopting discrete aspects of the Commission’s recommendations for these additional facilities.

    Issue(s): Health and Human Services