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MEMOR ANDUM DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
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FROM

SUBJECT:

GF Public Health Service

Mr. Eugene Rubel DATE: July 26, 1974
Director, Comprehensive Health Planning a,
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Regional Health Administrator ”
Public Health Service, Region I

Comments on Proposed Tasks for Implementing HRP Legislation

Members of the Regional Office staff have reviewed the work plan
material distributed at the recent CHP Meeting in Rockville. We
have identified a number of concerns that are implicit in the
subject documents, which, in my opinion, require intensive
exploration and discussion at the Regional Health Administrator
level.

These concerns fall into the following categories:

1. The lack of real Regional Office participation in most
of the key activities indicates an apparent change of
philosophy in relation to the whole HEW concept of
decentralization.

2. The Work Plan does not appear to take into consideration
the potential impact on MBO activities already developed by the
Regional Offices and the major adjustments that will be re-
quired to facilitate any Regional Office role in the proposed
Work Plan. In addition, the Work Plan activities are not
necessarily consistent with priorities that have been
developed under MBO for each Regional Office.

3. The issue of "delegation of authority" and its relation-
ship to decentralization should be explored in great detail
as it has in my opinion a strong pearing on the different
roles to be assumed by Central Office and Regional Office
staff. ,

The following references are offered as comments on specific items in the
Work Plan document:

ADMINISTRATIVE MATTERS
Task 1 -- Our concern in regard to budget development, staff requirements,
etc. was expressed in a memorandum from Dr. William J. Beck, Director,
Division of Resource Development, to Mr. Kelly, Comprehensive Health Planning
Service, Rockville, Maryland, dated July 23, 1974.
Page 2 - Mr. Rubel

Task 2 - Those subsections of this task that identify joint CO/RO
efforts need considerable interpretation and clarification. I am
particularly concerned that Item C calls for no Regional Office
role in the development of alternative organizational structures.
Item E does not address itself to the need for input from Audit
Agencies (GAO/HEW). Recent audits by these groups indicate
dissatisfaction with the lack of specific forms and process to
denote accountability. In addition, the role of General Services
Administration under A-102 is not taken into consideration. I
was also concerned that there is no expressed role for the Regional
Office in the development and participation of an overall program
guide (Item F). ,

DESIGNATION OF GEOGRAPHIC AREAS

An overriding issue in the designation of geographical areas is the role
and responsibility to be assumed by Central Office, the Office of the
Regional Director and the Office of the Regional Health Administrator.
This is of particular concern when you consider the fact that the
Governor's Office in each State will have a major role in determining
geographical boundaries for HSA's within the State.

Task 2 of this section calls for the preparation of materials for
training sessions. No Regional Office input is identified and I

feel that the Regional Office should play a very positive role in the
development of this material. Task 4, Delegation of Authority, calls
for “discussions and decisions" under Regional Offite role. This

is vague and needs to be clarified. Assuming that funding authority
will rest with the Regional Health Administrators the extent of this
delegation of authority must be thoroughly explored.

Item VII - Training Sessions - calls for Regional Office to be
participants. It is crucial that the Regional Offices have input
into the development of proposed training sessions.

Item VIII - Technical Assistance to individual states is identified
as a joint Central Office/Regional Office effort. In this area I
believe it is necessary to spell out who will assume specific respons-
ibilities and in what areas. In addition, I question why this would
be any different than the 1122 process initiated last year. The
Regional Office assumed the responsibility for technical assistance to
individual states with input from Central Office as necessary.

~

 

 
Page 3 - Mr. Rubel

Item IX - Action of Waivers related to the whole issue of delegation
of authority, approval authority, and funding authority. Any decision
on this particular task would be directly related to the decisions

on these other items.

Item X - Action on Governor's Designation has to be spelled out more
clearly from the point of view of concerns identified in Item IX.

TOTAL MANAGEMENT MONITORING SYSTEM

In reviewing this section many questions can be raised in terms of .
relationship of the proposed Monitoring System involving ‘substantial
input and personnel requirements from Central Office, Regional Office
and outside consultants. What is the relationship of this system

to other systems being planned or in operation within Public Health
Service? How does the proposed system relate to Agency Program
Reporting System (APRS)?

AGENCY SELECTION

This entire section and each of the tasks identified is in need of
extensive discussion in order to specifically clarify the roles of

Central Office and Regional Office staff in this critical area. The
specific role for each unit will be directly related to the determinations
made on several points raised above.

REGULATORY ACTIVITIES

The same issue of clarification as a Regional Office role comes up
once again in the areas of regulatory activities. It is apparent
from the document that the vast majority of this activity related to
review. and comment and does not identify any substantive role that
related to the decision-making responsibility of the Regional Office
in regard to regulatory activities

The above constitutes an overall review and highlights some of my
major concerns. It is apparent that the basic issue relating to

these activities must be explored in great detail in order to success-
fully achieve the implementation of the proposed legislation.

I would be pleased to assist in any way possible in resolving these

' issues.
Golde Wte |

Gertrude T. Hunter, M.D.
Regional Health Administrator