Signature Health Issues Public Comment on Health Resources & Services Administration Proposed Rule

WASHINGTON, July 27 -- Paula Anzlovar, board member of Signature Health Inc., Mentor, Ohio, has issued a public comment on the Health Resources and Services Administration proposed rule entitled "Proposed Rescission of Executive Order 13937; Access to Affordable Life-saving Medications". The comment was written on July 15, 2021, and posted on July 16, 2021:

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As a board member of Signature Health, Inc., I appreciate the opportunity to comment on the Proposed Rescission of the Final Rule implementing Executive Order 13937. Signature Health is a Federally Qualified Health Center that provides primary medical care and mental health and substance abuse services in six locations in northeast Ohio. Many communities they work in are medically underserved and in crisis so they strive to remove barriers and increase access to care to those in need, regardless of insurance status. In 2020 Signature Health served over 25,000 patients and worked closely with other agencies on regional quality improvement initiatives and the ongoing COVID-19 community wide response.

I strongly support the proposal to rescind the Final Rule, for the reasons listed below. These reasons closely mirror those outlined by the National Association for Community Health Centers (NACHC) in their written comments, and we refer you to NACHC's comments for a detailed discussion of each of topic.

1. Contrary to the purpose of the health center program -- and the implications of the Executive Order on which this Final Rule is based -- this regulation would actually reduce access to care for underserved populations, rather than expand it. This is because implementing the Final Rule would impose significant administrative burdens and costs on health centers, reducing the resources they have available to support critical services for all their patients - including those who use insulin and injectable epinephrine.

2. The Final Rule's definition of "low income" as persons below 350% Federal Poverty Guidelines (FPG) is inconsistent with every known Federal program, and this new definition significantly increases the administrative burden on health center staff and reduces the resources health centers devote to general patient care.

3. If implemented, the Final Rule would require health centers to divert critical resources away from vital COVID-19 pandemic response efforts across the country

4. If implemented as written, the positive impact of this regulation would be dramatically smaller than suggested in some public forums, and would be dwarfed by the resulting reduction in services that health centers could provide to their underserved patients.

In addition to urging you to rescind the Final Rule, we also urge the Administration to revoke the "Executive Order on Access to Affordable Lifesaving Medications" on which this Final Rule was based.

Thank you for your consideration of these comments. If you have any questions, please see NACHC's detailed comments or you can contact me via email at [email protected].

Sincerely,

Paula Anzlovar

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The proposed rule can be viewed at: https://www.regulations.gov/document/HRSA-2021-0003-0002

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