The Office of Management and Budget recently released a proposed rule which would eliminate 37% of Metropolitan Statistical Areas across the country, including Dubuque. It would replace them with a designation of “Micropolitan Statistical Area” essentially designating Dubuque and the surrounding area as a rural community. If this rule were to go into effect companies looking for a new location for their business or a place to expand would never see Dubuque. For site selectors, the first item on their list is an analysis of which MSA’s might be a good fit for their business. If Dubuque is downgraded, we will never be on that list.
Luckily, this designation has not been finalized. We need your help in stopping this harmful policy from going into effect. Please consider writing your own comment, focusing on the points below. You may also copy and paste the Chamber’s comment.
Talking points to focus on:
- As the nation comes out of a pandemic and economic crisis, the last thing we need to do is downgrade a third of the country’s population centers.
- The committee's reasoning is flawed. MSA’s are meant to designate which communities are metropolitan, not which communities have grown at the same rate as the country.
- There are outstanding questions including whether this rule will negatively impact Medicare reimbursement rates for affected communities; whether this will impact the federal budget by expanding program eligibility; whether the committees reasoning for the change is justified; and how will this impact ongoing longitudinal studies that utilize the MSA designation in their data sets.
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CHAMBER COMMENTS
Recommendation Concerning the Minimum Required Urban Area Population to Qualify a Metropolitan Statistical Area
I am writing to urge the OMB to reject this recommendation for the following reasons.
- It is first, important to note, that this recommended change is being proposed during a global pandemic and economic crisis. As the committee has noted, they did not consider funding or economic development impacts when devising these rules. However, it would be wrong to think such changes will not have an economic impact. To not conduct such an economic analysis shows how removed from reality this proposal is. On this basis alone, it should be put on hold for further study, if not rejected outright.
- The committee has stated that as population has grown (nearly 2.2 times greater than in 1950, when the policy was originally enacted), that the MSA standard has not kept pace with population growth. We believe this is a feature, not a bug. As cities grow, wages increase, development costs increase, and more city services are required. Whether it is 1950 or 2020, many of those costs are non-negotiable and increase over time. This is why a population of 50,000 as a threshold for an urban area to qualify for an MSA made sense in 1950 and continues to this day. Comparing the growth of the country’s population to the status of an individual community as metropolitan is like comparing apples to oranges.
- CDBG entitlement funds are distributed to cities based on whether communities are “Central cities of Metropolitan Statistical Areas (MSAs) or are other metropolitan cities with populations of at least 50,000”. Dubuque would not lose CDBG funding immediately, but it is clear that policymakers have utilized the threshold to determine 50,000 is the appropriate size for a city to receive these funds. With a change to the MSA standard, we would likely see population thresholds on future policy initiatives grow to 100,000 as policymakers begin consulting the new statistic – whether or not they cite the MSA standard as the reasoning behind it within the law.
- In addition to this, we believe the following questions must be answered before any policy change of this type moves forward.
- Will a change in designation from Metropolitan to Micropolitan cause a decrease in the Medicare labor cost reimbursement rate for providers in the impacted communities?
- What will be the impact on the federal budget, for expanding access to programs aimed at small communities to larger urbanized communities?
- How did the committee come to the conclusion that an area with 50,000 in population is not urban, but 100,000 is? We believe the comparison between national population growth and the status of a community as “metropolitan” is like comparing apples to oranges. Empirical proof should be necessary to prove this comparison leads to the conclusion recommended by the committee.
- What will be the impact on research, both private and public, that utilize MSA’s as a benchmark for a large community? Will long term data collection be negatively impacted by this change?
Without a full explanation and analysis of the above questions, as well as those raised in other comments, it would be irresponsible for the federal government to enact such a far-reaching rule. We urge the Office of Management and Budget to reject these proposed changes to MSA designation criteria.
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