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14 HPSA Designations Withdrawn Across Michigan - Does the Change Affect Michigan Communities for Better or Worse?

According to Michigan’s Primary Care Office (PCO), there are 14 service areas in Michigan that lost their partial or full county HPSA designations in January 2024. 

What is a HPSA designation?

A Health Professional Shortage Area (HPSA) designation is a geographic area, population group, or healthcare facility that has been designated by the Health Resources and Services Administration (HRSA) as having a shortage of health professionals. The three categories of HPSAs are Primary Care, Dental Health, and Mental Health.

The three basic criteria for geographic and population group HPSA designations include:

1) Be a Rational Service Area (RSA): RSAs are geographic areas that represent how and where the population residing within that area “reasonably” seek certain health services” (CHWS, p.4) 

2) Analysis of Contiguous Areas: Primary care resources in contiguous areas must be overutilized, excessively distant, or otherwise inaccessible to the population of the rational service area

3) The ratio of population to providers within the service area must demonstrate a severe shortage of primary care, dental health or mental health providers to the area.

You can find current HPSA information by state/county, address, and/or facility type here.

How were these areas determined? 

Based on the 2021 National Shortage Designation Update, HRSA initially determined that over 60 HPSAs in Michigan should be proposed for withdrawal from their HPSA status. At that point in time, these HPSAs did not meet the federal criteria for reinstatement. 

HRSA uses provider data [National Provider Identifier (NPI)], mapping data [Environmental System Research Institute (ESRI)], demographic data (The Census Bureau), health-related data (CDC National Vital Statistics), and Federally Qualified Health Center/Look-Alike data (HRSA’s Uniform Data System) from their Shortage Designation Management System (SDMS) to make these determinations.

Michigan’s PCO, located within MDHHS, is responsible for updating and validating provider data annually, collaborating with partners like the Michigan Primary Care Association (MPCA) and the Michigan Center for Rural Health (MCRH) to ensure that provider data on the SDMS is accurate. For every service area proposed for withdrawal, it is imperative for the PCO to know if there are any new providers, if providers relocated, if providers retired, and if providers did not renew their licenses. Some areas were just a couple of providers away from becoming eligible for a HPSA designation again. 

Through the process of verifying and updating provider data, and submitting applications for the service areas that actually met the federal criteria, the PCO was able to reduce the number of HPSAs proposed for withdrawal from more than 60 to 14. 

Service areas with HPSAs in a PFW Status that lost their partial or full county HPSA designations in January 2024:

Primary Care HPSA (7)

Mental Health HPSA (3)

Dental Health HPSA (4)

Barry County

Barry County

Benzie County

Charlevoix County

St. Clair County

Cass County

Emmet County

Washtenaw County

Charlevoix County

Grand Traverse County

Shiawassee County

Lapeer County

Shiawassee County

St. Clair County

According to Miguelina Carela-Garcia, a specialist in charge of shortage designations at the Michigan PCO, “The HPSA designations in proposed for withdrawal status no longer meet the federal criteria and thresholds for the required population to provider ratios, low poverty level, or/and failed the contiguous areas analysis due to the distance and accessibility of providers in contiguous areas or neighboring counties.” 

What happens when service areas lose their HPSA designations?

When service areas lose their partial or full county HPSA designations, they lose the ability to benefit from federal programs. 

Federal programs that use HPSAs/shortage designations for resource distribution include:

  • National Health Service Corps (NHSC)

  • Nurse Corps

  • Indian Health Service (IHS) Loan Repayment Program

  • Centers for Medicare & Medicaid Services (CMS) HPSA Bonus Payment Program

  • Centers for Medicare & Medicaid Services (CMS) Rural Health Clinic Program

  • J-1 Visa Waiver 

These Michigan service areas also lose the ability for providers to participate in the Michigan State Loan Repayment Program (MSLRP). Additionally, providers who do not practice out of a community mental health authority (CMHA) or a public school-based system lose the ability to participate in the MI Kids Now Loan Repayment Program (MKN LRP), as providers practicing out of other public, non-profit agencies must practice within a HPSA to be eligible

These federal and state programs recruit and retain providers by providing incentives such as bonuses or loan repayment to students and providers who practice in these HPSAs. When a service area loses its HPSA designation, it disadvantages the healthcare facilities and the people living in them who need to access healthcare. 

Facilities that are affected by the withdrawal of its service area’s HPSA designation include but are not limited to: 

  • Local community mental health (CMH) facilities

  • Private practices

  • Local health departments

  • School-based health programs

  • Critical access hospitals

Facilities that are not affected by the withdrawal of its service area’s HPSA designation include:

  • Federally-Qualified Health Centers (FQHCs) and Look-Alikes 

  • Indian Health Facilities

  • IHS and Tribal Hospitals

  • Dual-funded Community Health Centers/Tribal Clinics

  • CMS-Certified Rural Health Clinics

These facilities are not affected because they are automatically designated as HPSAs based on statute or through regulation, no matter where they are located.

What does the Michigan Primary Care Office do to help areas that will lose their HPSA designations? 

The Michigan PCO wants others to know that HPSA removal and withdrawal are not permanent. They encourage providers in areas that were recently withdrawn or who are proposed for withdrawal to keep sending provider surveys for any provider updates. As soon as an area meets federal criteria, the PCO sends an application to HRSA, which then has up to 90 days to review the application and either approve or deny the area. 

The next national shortage designation update for all HPSAs is tentatively scheduled for fall 2024. 



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