public comments

February 28, 2013

Health Resources Services Administration
Reports Clearance Officer, Room 10–29,
Park lawn Building, 5600 Fishers Lane,
Rockville, MD 20857
Subject: [FR Doc. 2012–31399 Medicare Rural Hospital Flexibility Grant Program Performance
Measure Determination.
To Whom It May Concern:
The National Organization of State Offices of Rural Health (NOSORH) is pleased to have the
opportunity to respond to the Health Resources and Services Administration comment request
regarding information collection for the Medicare Rural Hospital Flexibility Grant Program
Performance Measure Determination.
NOSORH is the national non-profit membership organization of the fifty State Offices of Rural
Health (SORH). Our mission is to promote the capacity of State Offices of Rural Health to
improve health care in rural America through leadership development, education, and
partnerships. The SORH are anchors of rural health activity throughout the nation and have
responsibility for information dissemination, coordination, data collection and technical
assistance to support rural communities. There are 45 Medicare Rural Hospital Flexibility
Grantees; most are State Offices of Rural Health or are contracted by the State Office of Rural
Health.
In response to the request for comment the NOSORH Board of Directors (23 SORH) reviewed
the federal register notice and voted that NOSORH should file a response to the call for
comments from HRSA to ensure the voice of the SORH on this important issue. Please note
that in preparing these comments we requested the data collection plans and draft instruments
as directed in the first paragraph of the federal register notice, but have been informed that the
draft instrument and plans are not available. The comments below are provided on the four
key areas for which information has been requested, without benefit of any knowledge of the
data collection plans or draft instruments.

NATIONAL ORGANIZATION OF STATE OFFICES OF RURAL HEALTH
 44648 Mound Road, #114  Sterling Heights, MI 48314-1322 
 Phone: 586-739-9940  Fax: 586-739-9941  www.nosorh.org 

The necessity and utility of the proposed information collection for the proper
performance of the agency’s functions
NOSORH strongly supports appropriate reporting requirements to obtain a
measure of the accomplishment of the FLEX program major aims. Reporting
requirements for FLEX grantees should only include data that are unique to the
measurement of the grantees’ objectives, and data which cannot be captured
from other data sources. The measurement of the federal Office of Rural Health
Policy’s “agency functions” should include an analysis of data sets reported
directly by CAH. Data from the MBQIP reporting could be used for some
measure of the overall program performance.
The accuracy of the estimated burden
NOSORH lauds any future effort by HRSA to keep the reporting requirement
burden at 6 hours or less for this program. Anecdotal information provided by
SORH indicates that during the 2012-13 grant year, the time required to develop,
acquire, validate, verify and disclose the required data exceeds the 6 hours cited
in the federal register notice. Some SORH report the need to staff this effort
with a .50 FTE position or more. Without a copy of the proposed instrument it is
impossible to cite a more realistic estimated burden. NOSORH is poised to help
the Office of Rural Health Policy to assess a more accurate estimate of the
reporting burden when more details about proposed measures become
available.
Ways to enhance the quality, utility, and clarity of the information to be collected
In order to ensure that the data reported to measure the effectiveness of FLEX
grantee interventions, it is essential that FLEX grantees be engaged in the
planning and development of standards for measurement. HRSA should tap the
expertise and knowledge of SORH, the Technical Assistance Service Center and
NOSORH. SORH insight is needed to establish standards of measurement which
will not be a burden, will provide management the necessary information to
monitor the accomplishment of objectives and to evaluate the impact of the
program activities in the future. NOSORH provides SORH with a web-based
performance measure tool (TruServe) for their use in tracking all SORH activity.
Approximately 70% of FLEX grantees currently utilize this web-based
performance measurement tool to collect measures of some of their program
activities. An analysis of measures voluntary input to TruServe may provide a
starting point from which future measures could be identified and tested.
The use of automated collection techniques or other forms of information technology
The use of automated collection techniques must be fostered in order to
document the collective impact of the FLEX program. Any requirements for the
use of automated collection tools should ensure no additional burden of
reporting.

NATIONAL ORGANIZATION OF STATE OFFICES OF RURAL HEALTH
 44648 Mound Road, #114  Sterling Heights, MI 48314-1322 
 Phone: 586-739-9940  Fax: 586-739-9941  www.nosorh.org 

NOSORH appreciates the opportunity to offer our comments early in the process of identifying
meaningful measures of the FLEX grant program. We are committed to ensuring the impact of
the FLEX program is quantified in a meaningful way and look forward to future work with HRSA.
For clarification, additional comment or questions, please don’t hesitate to contact me by email
at any time teryle@nosorh.org.
Sincerely,
Teryl E. Eisinger, MA
Director

NATIONAL ORGANIZATION OF STATE OFFICES OF RURAL HEALTH
 44648 Mound Road, #114  Sterling Heights, MI 48314-1322 
 Phone: 586-739-9940  Fax: 586-739-9941  www.nosorh.org 