CMS has included a Request for Information (RFI) about measuring social determinants of health (SDOH) in all their proposed rules this year. Although the RFIs vary depending on the specific Medicare program/rule, the consistent elements are seeking input on how to measure SDOHs and how to capture when patients screen positively for any of these factors.
C-TAC usually comments on major Medicare proposed rules in regard to their effect on those living with serious illnesses and we have consistently commented on the importance of measuring SDOHs. We’ve also suggested going further to ensure that programs go beyond just noting when screening is positive to ultimately making them responsible for referring patients to appropriate social services and even confirming that their needs were subsequently met by those services. We have also advocated for broadening the SDOH assessments to include family caregivers since their needs can affect the patient’s health as well.
Here are examples of the kinds of comments we’ve submitted regarding SDOH measurement:
Proposed CY2023 Hospital Inpatient Rule Quality Reporting (IQR) Program– Here are our comments on the new health equity measures being submitted:
- Screening for Social Drivers of Health– We agree that assessing social drivers of health is very important, both to improve care for those with serious illness and to reduce health disparities. Our suggestion is that such screening is comprehensive enough to identify all the key social drivers, including the needs of family caregivers, since caregiver burden can prompt an emergency department visit or hospitalization and is, therefore, also health-related. We appreciate the need to balance comprehensive screening with potential burdens to the beneficiary and provider and would encourage you to study the key social drivers to be screened.
- Screen Positive Rate for Social Drivers of Health– We support this measure as it does little good to screen for social drivers of health if these drivers are not captured and then, hopefully, addressed. We would ask that you consider eventually requiring referrals to ensure that identified beneficiaries are linked with needed services. It is insufficient, for instance, to just document that those in need of home-delivered food were identified as such but then not to have referred them or ensured that they got food delivered and so didn’t go hungry.
Proposed CY 2023 SNF Rule– Overarching Principles for Measuring Equity and Healthcare Quality Disparities across CMS Quality Programs
We support the framework and principles proposed to measure equity and disparities in the SNF program and have two suggestions regarding new Measures Related to Health Equity:
Equity population measures– Data does not exist, nor is it required, to show SNF providers how their efforts at enrollment compare to the demographics of their service area. We suggest, therefore, that CMS provide the data to enable SNFs to track how closely their enrollment, and the enrollment from all SNFs serving the area, align with the demographics of their service area so as to identify any gaps to be addressed in future beneficiary enrollment/engagement efforts. Eventually, persistent, and substantial disparities would become a quality deficiency.
- Broader social risk factor assessment– We believe that assessing health-related social risk needs is important, both to improve care for those with serious illness and to reduce health disparities. Our suggestion is that any such assessment is comprehensive enough to identify all the key social risk factors, including the needs of family caregivers, since caregiver burden can prompt an emergency department visit or hospitalization and is, therefore, also health-related. We appreciate the need to balance comprehensive assessment with potential burdens to the beneficiary and SNF provider and would encourage you to study the key social risk factors that need to be assessed. In addition, of course, assessment is never enough. The SNF program must also have a pattern of adequate and timely referral and a feedback loop as to whether the services were provided and whether they met the need.
