COMMUNITY BASED EDUCATIONAL PROGRAMS

1. Review Committee;
2. Guides for Review;

3. General Counsel's Opinion of
April 14, 1972.
COMMUNITY BASED EDUCATION PROGRAMS

Special Review Committee:

Dr. Perry, Chairman Dr. Hess

Mrs. Wyckoff Mr. Hilton

Miss Anderson Dr. Popma, Consultant
Miss Kerr

-

Headed by Dr. Veronica Conley, RMPS Staff
Il.

IIl.

IV.

REGIONAL MEDICAL PROGRAMS SERVICE
GUIDES FOR REVIEW OF
COMMUNITY BASED MANPOWER PROGRAM PROPOSALS

APPLICATION ESSENTIALS

Proposal is requesting funding in excess of $50,000.
Proposal has approval of the Regional Advisory Group.

Proposal includes review and comment of the appropriate CHP
agency, if not, explanation is given.

The area to be served is clearly defined and comprises a
medical trade area.

Names of all institutions and agencies involved.

DOCUMENTATION OF NEED

A. What.sources of data have been used for planning to determine
needs for health services? Do these include:

1. Number and characteristics of the population to be served.

2. Numbers, distribution, and utilization of health manpower
providing services. '

3. Numbers and kinds of institutions, agencies, both private
and public, providing health manpower, education and training
opportunities; numbers and nature of their training programs.

OBJECTIVES

A. Objectives are stated in clear and measurable terms.

B. Objectives relate to the RMPS concept of the community based
manpower programs.

PLANNING

A. The proposal is not in competition with similar efforts within
the same geographical area.

B. Identification of the accredited education institutions, health

care provider institutions and community health care and planning
interests committed to the advancement of the program.
LV. PLANNING (continued)

Cc.

D.

Identification of the potential membership of a Coordinating/
Governing Body group.

There is a plan for evaluating the developmental process.

An implementation scheme has been developed and appropriate
sources of funding to support each phase has been identified.

-V. ORGANIZATION AND DEVELOPMENT

A.

The Coordinating/Governing Body has been formed, its function
formalized, and an administrative structure planned for
management purposes.

1. For established Bodies, by-laws are attached.

Such a Coordinating/Governing Body is proposed.

1. Draft by-laws are attached if available.

The Coordinating/Governing Body represents a consortium of:

s
1. At least one fully accredited institution of higher learning.

2. Principal. health care provider groups or institutions,
including appropriate clinical resources.

3. Consumer interests.
4. Health professional societies.

Evidence is provided of the degree of commitment of participating
educational institutions, health service institutions, and
other appropriate groups.

VI. OPERATIONAL

A.

The operational phase of the proposal describes which of the
following activities are to be undertaken in the current period.

1. Setting of priorities based upon continuous appraisal of
the relationship between community health service needs and
production of health manpower.

2. Designing education for both traditional and new health
occupations to meet the particular health service needs
ef the area.
VI. OPERATIONAL (continued)

3.

4/7/72

Provision of basic and continuing education with appropriate
clinical experience, and in-service training for health
manpower.

Providing educational experiences that will develop strong
interest and commitment to an interdisciplinary health care

delivery approach.

Recruitment, training, and placement of local residents in
health careers related to manpower needs.

Provision for health education and information services for
patients and the general public.

Studies of current licensure and related manpower issues.

Other.

1
oe

@™

FROM

SUBJECT:

 

Mr. Raymond D. Cotton Office of the General Counsel
Executive Director

ffice of Assistant Secretary Date:

for Health and Scientific Affairs APR1 4 972

|
Sidney Edelman
Assistant General Counsel
for Public Lealth

Area Health Education Centers=eSupport under section 910,
PHS Act

.

You informally requested our views with regard to the availe-
ability of section 910, PiS Act, as a source of authority for funding
so-called Area Health Education Centers (AHEC's). We understand
that such funding would in general be on a contract, rather than
grant, basis. The purpose of auch centers, as described in the
attached undated excerpt from an unidentified document, would be

to

"provide educational opportunities for students
to enter health careers in communities where
students do not have ready access to such
opportunities, ‘They will prepare Cuese students
to provide health services in communities and
regions that are underserved so that services
appropriate to the health needs of the comunity
or region will be available to those who need
them. ‘The centers will recruit students, offer
educational and training programs for initial
entry into health occupations, for retraining

of health personnel and for continuing education
so that those in the health occupations and
professions may retain and prove their competence
to provide safe and effective health services
needed in the area."

The prinary goal of ANEC's is described as being "eo provide
educational opportunity for individuals who vould othervise tend
to be excluded from training or education in the health field."

 

if:

os
 

ir, Raymond Me Cotton 7 2

{ . .

We think that section 910 contains certain restrictions which
may limit its utility as a vehicle for supporting in full training
activities of the scope of those described above, Section 910(a) (4)
authorizes the Secretary to make grants and contracts for

"development of training specifically related to

the prevention, diaznosis, or treatment of any

of the diseases taserced to in paragrann (2)

{heart disease, cancer, stroke, kidney Giscase,

or other related diseases], or to the rehabilitation
of persons suffering from any of such clseases3 a
and for continuing programs of such training were
shortage of trained personnel would othervise limit
application of knowledge end skills important to

the control of any of such diseases” (Euphasie added).

  

The scope of section 910(a)(4) is thus limited in the most™

specific terns to the Title iA diseases. While the scope and

ture of the training for the stated purposes is essentlally
fer determination by tha Service in the exercise of sound
ptofessional judguent, the operation of the proposed AHEC' gs
would, it appears, cover the full range of haaltherelated
training, and vould not apparently be "snacifically related" to
the specified diseases or purposas a8 required by the statute.

Section 910(c} contains no such catezorical disease linitation.

It does, however, limit the training authority of the Secretary

to those activities which are "designed to navimize the

utilization of manpower in the delivery of health services."

This language is obviously somewhat anbiguous. The legislative
history of P.L. 91°515 (uhich added the provision) is, moreover,

of little help in determining what was intended by it. Oa its

face, however, we suggest that gection 910(c} vas not intended
to serve as authority for the training of entire new cadres

of health and allied health professional personnel; rather, the
language "maximize the utilization of manpower" seeas to contemplate
making more effective and improving the skills of available

health personnel. This mignt, for example, include training to
expand the responsibilities and skills of certain types of health
personnel, or to enable physicians to nake more extensive use

ity
 

Mr. Raymond D. Cotton | 3

of allicd health professionals, or to enable health aduinistratore
to utilize personnel more effectently2/ Tt would not, in our
view, include recruitment end training of students for ‘EnitLal
entry into health occupations."

In this rezard, ve might point out that Congress has recently
enacted the Comprehensive Mealth Manpover Training Act of 1971
(P.L. 92¢157) and the turse Training Act of 1971 G@.L, 9298155).
Those Act amended Title VII and VIIL, respectively of the PHS
Act, considerably broadening and increasing Federal support
of training for health professions and nursing personnel. In
addition, Part GC of Title VIZ contains a rember of sinilar programs
for the production of allied health professions persomel. The
existence of that lesislation, which appears to provide specific
authority for all of the types of activity contemplated for Allic's,
would in our view cast furcher doubt on the availability of section
910 for support of any training programs not clearly authorized

thereby.

We emphasize that the conclusions expressed above are intended
to apply only to Alm0's of the typd deseribed in the attached
docuncat, and may not apply with equal force to ANEC's of more
limited scope. For example, a training program whosesole purpose
4s to “naxinize the utilization of manpower" in health services
delivery, and which does not involve the training of students
for initigl entry into health occupations, would clearly be
supportable under section 910(c).

_ his will confirm our earlier advice given to you in the form
of a draft memorandum dated March 3, 1972.

Attachment.

 

1/ in this connection we note that the Senate Appropriations .
Comaittea in its report on the 1972 Appropriation Act (?.L. 92=-
80, in discussing the availability of medical corpsment
in HEDIEC and LEDEX programs, urged their training as
physician assistants “through the Regional Medical Program

and the NIH health manpower program." (Emphasis supplied.)

ee

8. Rept. 92-316, Pe 6.

Prepared by: GH DNYOUNG, gmb, 4/13/72
cc: Dr. Margulies
Dr. Pahl |