Prepare Now for Health Equity Requirements in the Pipeline

Health EquityBackground

Equity and disparity have been ongoing issues in healthcare for years. But it took the COVID-19 pandemic to bring it into the spotlight at a federal level as a quality-of-care concern. The Centers for Medicare and Medicaid Services (CMS) posted a Preliminary Medicare COVID-19 Data Snapshot in June 2020, which included a facts sheet of aggregate data and visuals from Medicare Fee-for-Service claims data, Medicare Advantage encounter data, and Medicare enrollment information. In early 2021, CMS reported at their virtual quality conference that aggregated from 2020 showed health inequities have become more pronounced as communities of color suffered disproportionate death and morbidity because of COVID-19. The CMS Office of Minority Health was highlighted throughout the conference, and many sessions focused on the issues of health disparity, equity, and access as a quality issue.

The pandemic data forced CMS action to establish reporting mechanisms in arenas that had been previously neglected, including nursing homes, dialysis facilities, and labs. The real-time data action approach contributed to lowering COVID-19 infection before vaccine development and availability. At that conference, CMS made clear that “the new normal” is health equity, and they planned to redouble their efforts to expand the health system to incorporate social science and implement stratifying measures to address health equity. CMS also included a request for information on home health and hospice proposed payment update rules for FY 2022 related to data collection regarding health equity.

Fast forward to 2022. On April 20, 2022, CMS previews its action plan to advance health equity as the first pillar of its core work. The CMS administrator called upon healthcare industry leaders to assist CMS and share best practices to address systemic inequities in the delivery of care. In May 2022, the CMS Office of Minority Health (OMH) released the CMS Framework for Health Equity to address health disparities. The framework contains five priority areas that CMS will use to design, implement, and operationalize policies and programs to support health for all people served by CMS programs by eliminating avoidable differences in health outcomes experienced by disadvantaged or under-served people. The OMH designed multiple initiatives to address and eliminate disparities in health care quality and access so that all CMS beneficiaries can achieve their highest level of health.

Current Activity

CMS sought to build on the comments received from the FY 2022 rules and included a request for information in FY 2023 home health and hospice proposed payment update rules to ask for feedback related to: “achieving equity in health care outcomes for patients by supporting providers in quality improvement activities to reduce health disparities, enabling beneficiaries to make more informed decisions, and promoting provider accountability for health care disparities.” There was also discussion in both rules about developing a composite structural measure concept that could include provider-reported data on organizational actions to address access of under-served populations to care.

CMS activity since 2020 demonstrates their commitment to closing the equity gap in provider quality programs and information in this fiscal year’s proposed payment rules is the forecast of quality requirements to come. Home health and hospice providers should seize the opportunity now to plan implementation of health equity initiatives in their current and future strategic plans. CMS has supplied enough information for providers to implement or further current health equity activity. Review the following request for information questions from CMS to set your compass towards improving health disparity and care quality for the patients and communities you serve.

  • What efforts does your organization employ to recruit staff, volunteers, and board members from diverse populations to represent and serve under-served populations?
  • How does your organization attempt to bridge any cultural gaps between your personnel and beneficiaries/clients? How does your organization measure whether this has an impact on health equity?
  • How does your organization currently identify barriers to access to care in your community or service area?
  • What are the barriers to collecting data related to disparities, SDOH, and equity? What steps does your organization take to address these barriers?
  • How does your organization collect self-reported demographic information such as information on race and ethnicity, disability, sexual orientation, gender identity, veteran status, socioeconomic status, and language preference?
  • How is your organization using collected information such as housing, food security, access to interpreter services, care giving status, and marital status to inform its health equity initiatives?