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Local Response to Rural Hospital Program: Analysis of Regulatory Comments

Sat, September 2, 12:00 to 1:30pm PDT (12:00 to 1:30pm PDT), LACC, 308B

Abstract

Nearly 15% of all Americans rely on rural hospitals, yet this care has grown increasingly fraught, with more than 100 of these facilities closed in the last decade. In response to these dynamics, federal policy has given rural hospitals a lifeline – as well as a “Sophie’s Choice.” These facilities can receive needed federal funds to keep their doors open, while also requiring them to end all inpatient care –fundamentally altering the state of rural health care provision.

Here, we analyze the local response to changes in federal policy. A key opportunity for the public to shape proposed rules is through submitting public comments. Prior extant literature has found that organized interests often overshadow individual comments and rural interests are often neglected. Yet, the proposed rule offers an opportunity to understand the role of rural communities in the commenting process. First, the new rule is a highly salient issue for rural populations, rather than more urban and suburban areas. The regulatory change would only effect the subset of hospitals that provide care in rural settings. Second, the vast majority of rural hospitals are independent – meaning that the larger business interests of health care are likely to be less engaged in this process.

Using content analysis methods and a combination of provisional and open-coding techniques, we have developed a coding instrument to capture the local response to the rule. Initial coding themes emerged from prior work related to the framing and rhetoric of federal policy, as well as generated from prior literature. We have expanded the codebook to reflect the nuances of arguments made in support and opposition to the rule. In addition to coding themes contained in comments, we also collect the stance, use of evidence and personal experience, and type of submitter (individual, provider, payor, membership in healthcare organization, membership in some other organization).

Our analysis highlights the different rhetorical and framing strategies available to rural populations in response to changing federal policy. As well as providing insight into the challenging position in which rural hospitals are placed due to shifts in federal policy.

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