CMS Seeks Information to Address the Health Equity Gap

May 3, 2021

In the fiscal year 2021 inpatient prospective payment system proposed rule, the Centers for Medicare & Medicaid Services (CMS) requests information on revising several CMS quality programs to improve the reporting of health disparities based on social risk factors and race and ethnicity. Significant inequities in health outcomes exist in the US, CMS reports, noting that poor access and lower quality of care are contributing factors. CMS notes that improving data collection to allow for better measurement and reporting on equity across its programs and policies would address this issue. The request for information (RFI) aligns with President Joe Biden’s January 2021 Executive Order Advancing Racial Equity and Support for Underserved Communities Through the Federal Government. CMS issued similar RFIs in the proposed rules for other Medicare prospective payment systems.

CMS seeks public comment on three potential expansions of the CMS Disparity Methods, which calculate the differences in outcomes among patient groups within and across hospitals. First, CMS is considering additional stratification of quality measure results by race, ethnicity, dual eligible status, disability status, LGBTQ+, and socioeconomic status. Specifically, CMS seeks information on a potential algorithm to indirectly estimate race and ethnicity to stratify quality measures, appropriate privacy safeguards, ways to address collection challenges, and recommendations for other types of data elements and quality measures to address disparities.

CMS is also considering collecting a standardized set of demographic data elements by hospital at the time of admission and using electronic data definitions to permit nationwide interoperable health information exchange. This could include expanding stratified reporting to additional social factors that currently have limited data accuracy such as language preferences. CMS is also seeking the experiences of users of certified health information technology regarding best practices for collection of demographic data elements, the value of the data, and potential challenges and benefits of collecting the data on a more granular level.

Finally, CMS is considering creating a Hospital Equity Score to synthesize results across multiple social risk factors and disparity measures. CMS seeks feedback around possible interventions that hospitals could institute to improve a low hospital equity score and how improved demographic data could assist with these efforts.

GNYHA will submit comments by the June 28 deadline and seeks input from members. GNYHA will host a webinar to cover the quality provisions of the proposed rule and the RFI. An Event Notice with the webinar’s date and registration information will be forthcoming.