nnn i Assogiete Director for Health November 4, 1974 Resources Planning, BHRD Acting Director Division of Regional Medical Programs Suggestions on Organizational Proposal for New Bureau to Administer Health Resource Planning Legislation A clear, precise functional statement is essential to the successful launching of a new organization. Once a unit is operating for sone time, responsibilities and organizational relationships become insti- tutionalized and the functional statement is forgotten. Because of this, there is a tendency to underestimate the importance of a esrefully written functional statement. A sound functinnal statement is needed initially to, 1. avoid or minimize turf problems; 2. ineure that responsibilities are assigned for all required and essential func tions ; 3. provide a basie for developing realistic staffing requirements ; 4&4. provide a basis for writing position descriptions related to sctual job and organizational responsi- bilities; 5. identify needs for coordination between units and for delegation of authority. After carefully reviewing the current functional statement for the proposed new Bureau and reviewing the comments of the EMP staff, I recoumend a complete rewrite. If the present document is allowed to stand, my experience tells me that the new Bureau will be beset with tetelly unnecessary jurisdictional fights, personnel grievances, staffing imbalances, and emergency, crash efforts to meet overlooked responsibilities. As you know, our Executive Steff discussions convinced me of the need for a separate Division to oversee the State's regulatory activities, and I recog- nize and appreciate that the present orgenizational proposal attempts to incorporate my ideas on evaluation and policy coordination. However, in ma 2 « muy view, the duties and responsibilities of the various units as described ia the funetionel statement, are incomplete and iusdequatily defined. Among other things, the statement contains overlapping respousibilicies. It ignores the functional responsibilities of Regiousl Offices. It amite impoctent functions (such as approval of State plans, awarding of grente end contracts, ammuel allocation of funds among the Regional Offices, management seni calica- iatten of formulas, required liaison with the Federel-State-lecal Data tem, ete.), oad, further, it fails to mmtion the Bureas's principal raison d'etre, financial) Support for pleaening and construction. 1 think ic wowld be a serious error to establish a new Bureau in such haste thet adequact etaff-werk is ignored. The functional statement, after all, is only the sQeend draft. The statement and orgentzetion chart were distri- buted to the Exeewtive Staff shortly before meeting, and it was discussed with little oppertuaity for pricr study and only the briefest periad for comment befere belag forwarded to Dr. Greene and others, While the current chart appears tw represent a generally workable orgenization, I cannct honestly endorss the functions] statement as presently written, and, there- fore, would ithe te suggest same modifications, i.e.: 1. Start owt with a general statement in plain English whee the Bureau does - (a) administers a program ef fineneial aseistance for State and lecal Health Pleaning through greats aff eentracts; (b>) provides support fer construction of health facilities through leans, loan guerantess, end grants; (c) nonitecs and supports Cente programs; and, (d) develope stantasde, guide- lines, and related, technical end other ace-finsncial assistance; 2. Drep the Section om, “Organizational Philosophy.” It adds nothing. Thea reference to a “flat” organization is vague and confusing, and the statement thet the Central Office steff will be emall is not supported either by the re- meinder of the fmetional statement or the suserous detailed requirements of the pending Bille; 3. Specify the functions to be performed by the Regione! Offices, end throughout the document note those functions that require priex consultation, concurrence, or approvals among ROe and Headquarters; 4&. Eliminate duplicative functions or cleerly distingaish between complewentery functions which, if not carefully defined, may seem to overlap. For example, the present draft refers to MIS or date functicoes in the description f Be Be be , . BO}>, 4 oF Bhp fe . 5. &. 7. Be 9. of five different units. Evaluation or legislative functions appear in the descriptions of six different offices, and training functions in two. Distinguish between related or complementary functions carried out by different offices by using more precise language to indicate relationships and types of coordination, f.e., "supervises » “Approves ; "Advises concerning ,” “Consults with on Pi "In conjunction with carries out art "Sub fect to prior consultation coes .7 Identify the locus of essential financial and related functions such as formula management, accounting, contract liaison, and financial policy; fake the Congressional correspondence function out of the Policy Coordination Office where it is inappropriate, and create (either within one of the Divisions or separately) # communications staff to manage not only correspondence but also production and distribution of publications as well. Numerous technical assistance documents will be required by Lew, and this implies a professional staff to handle editing, format, design, illustrations, printing, ete. Emphasize EEO throughout the document wherever appropriate. It is not sufficient just to have an ERO function in the Office of the Director. Each unit that deals with grantees or contractors should formally be charged with EEO responei~ bilities with respect to recipients of Federal funds aud with internal upwerd mobility, cereer development, wonen 's programs, ete.; Recognize in the organization chart and in the func tional statement that the Bureau relates to both the National Advisory Couned1 on Health Policy and the Federal Hospital Council, As a minimum, material relating to the Office of the Director should indicate that he consults with each of these Councils; Identify which Division will be responsible for data processing, advice on data management, and coordina tion of Bureau and other Federal data systems. At present, data functions are scattered throughout the proposed organisation. The different Divisions will require and use various data end ahould determine that data is collected, what reports are prepared, and how they are interpretec and uced, but expertlence indieates thet unless some kind of processing and coordinating unit is established, competing and duplicative data empires will flouwlieh; 1G, Icentify responsibilicy for functions that will be important im the initial stages of the program. Examples would be design and clearance of applications and other forms, establishment of review procedures, development of recuired regulations, development of terms and can» citilens for grants and contracts, procedures and ertteria for making required findings anc’ determinations, negotiation of conditional designation agreements for State and local agencies, ete, These kinds of activities imply fairly sub- stantial management analysis and contracting funetions for the first few years. Changes can be made later as workloads eniit. Some mention should aleo be made of the adminia~ tration of Section 314, Title VI and Title IX during the transitlonal period subsequent to enactment; ll. insure that the total organization, including the Regional Offices, is capable of carrying out all required and intended legislative responsibilities. Ower 40 specific requirements for reviews, approvals, determinations, development of materlals, ete., are emmerated in the House Bill f(exeluding the Hational Advisory Council on Yealth Policy and the Conttruction providions). Some organizational unit should be responsible for each legis- latively required funetion. TL know ic is always hard to go back to the drawing beard, but in thie case, i veally think it is necessary. Why rush now and be sorry later? Mr. Gardell and Iwill help in any way possible, and ~£ know that many of the RMP staff, particularly Mr. Baum, Mr. Teets, Mr. Ott, and Mrs. Silsbee, have ideas and experience that would be useful im thinking through another draft. I am confinced that devoting more time now to setting up a workable organization that covers all the bases in aceorcance with legislative requirements and expreesed Congressional intent will pay of £f in employee support and satis faction, crecitable Bureau performance, and benefit to the taxpayers. -5« I am sorry that my absence due to a back injury, in part, has delayed getting these comments to you sooner. In order to expedite matters, I an sending information copies to Dr. Greene and others who received your memorandyum of October 8, 1974, and to the Executive Staff. Herbert B. Pahl, Ph.D. cer Dr. Exdicete Dr. Margulies - Me. Zeiek Br. Whiteside Hr. Dyer Hr. Henson Executive Staff--Dr. Graning Dr. Lindsey KBaum:enk