AGD submitted comments to the Health Resources and Services Administration (HRSA) on September 18 regarding a Health Professional Shortage Area (HPSA) Scoring Criteria Request for Information (RFI). HRSA's designates geographic areas, population groups within geographic areas, and certain facilities as HPSAs under a specific discipline, one of which is dental health. 

After a HPSA is designated, it receives a score according to established criteria. The current scoring factors for a dental HPSA are population-to-provider ratio, poverty rate, travel distance/time to the nearest accessible source of care, and the availability of fluoridated water. A higher HPSA score is intended to demonstrate a greater level of need in the area, population, or facility subject to the designation. 

The HRSA RFI on scoring solicited feedback from stakeholders on the current criteria and on how they could potentially be revised in the future. AGD's comments offered numerous recommendations to HRSA, including:

• Evaluation of the utility and basis for the population-to-provider ratio scoring system
• Clarification of dental provider identification data sources used by State Primary Care Offices (PCO)
• Refinement of poverty rate criteria to better indicate underserved populations
• Elimination or overhaul of outdated travel distance/time to to the nearest accessible source of care criteria
• Support for maintaining fluoridated water availability factor
• A comprehensive review of the adequacy and relevance of the designation of HPSAs

Impact on General Dentistry: AGD appreciated the opportunity to provide feedback to HRSA on the HPSA scoring criteria and hopes that the review process will yield changes and extend to other aspects of the methodology used in administering HPSAs. AGD believes that the methodology by which a Dental HPSA is designated may be systemically flawed, which results in designations that are illogical and inconsistent with the actual level of access to dental care in affected communities.