CMS moves towards guidance on health equity and climate change

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The CMS outlined potential guidance on issues like health care fairness and climate change in its final rule for hospital patient payments last week as the federal government tightens its oversight of health care on social issues.

In the report, the CMS released feedback it received after seeking public comment when it proposed the rule in April.

The comments on climate change and health equity come as organizations like the American Medical Association released policy proposals this year aimed at championing environmental justice and supporting workplaces that encourage the wearing of cultural headwear and natural hairstyles.

Climate change

In its final rule, the agency outlined the effects of climate change on patients and hospitals, citing a consensus statement signed by more than 200 medical journals and calling climate change “the greatest threat to global public health in the world.” century to come”.

The plan comes as climate change has become a growing priority for federal health agencies.

Last year, HHS announced the creation of the new Office of Climate Change and Health Equity, which rolled out emissions requirements for hospitals and committed to working with local hospital networks. .

In its proposed rule, the CMS asked for input on how to maintain “uninterrupted operations serving patients” due to climate threats and catastrophic weather events and implored the wider healthcare industry to consider the amount of greenhouse gas emissions emitted by healthcare facilities. He also sought input on how he and HHS could better prepare for climate disasters and pointed out that climate change disproportionately affects underserved patient populations.

Commentators “uniformly embraced” the establishment of climate initiatives, according to the rule, adding that the vast majority of comments encouraged CMS to provide funding to organizations to engage in climate change initiatives. . Some have suggested a value-based purchasing program as a potential format for engaging organizations.

Other commentators highlighted the importance of analyzing the impact of climate change on patients and engaging with climate advocacy groups.

Although commenters for this section have not been named, some medical organizations have made their comments public. The Association of American Medical Colleges released its comments, stressing that the organization supports a collective approach to developing solutions to climate change.

Similarly, the American Hospital Association, in its 81-page proposed rule commentary, stressed that there is no “one size fits all” approach to meeting climate goals and said that while some of its hospital members are far along their own path to sustainability goals, some are “in the infancy of their work in this space, while others have yet to begin”.

In addition, the AHA reiterated its “serious concerns” that the CMS lacks the legal authority to impose weather restrictions on hospitals, adding that if the agency attempts to impose requirements, it must “explain in detail its statutory and constitutional authority to do so”.

Health Equity Reports

The CMS also sought comments on how to measure “significant and persistent inequalities in health care outcomes” in addition to the principles for reporting disparity outcomes.

Health inequalities have been increasingly important for the Biden administration. Hours after being sworn in, the president signed an executive order directing more than 90 federal agencies, including HHS, to advance racial equity initiatives.

Both CMS and HHS have inequity reporting tools, including CMS’s Medicare Disparity Mapping Tool and a Stratified Disparity Methods Reporting Tool.

However, the agency said it intends to start confidentially reporting stratified equity outcomes – measured by social risk factors, demographic and other variables – with the aim of “highlighting highlights potential gaps in care between patient groups,” and plans to expand its measurement of disparity. initiatives.

CMS asked for feedback on updated reporting methods and the best ways to screen for social and demographic risk factors, adding that measuring and reporting on disparities was a “cornerstone” of health equity.

And, though he was primarily seeking commentary on health disparities, commentators shared their thoughts and fears about how equity measures might impact physicians and hospital systems.

Some commentators have said that health equity measures could lead to performance competition and “games” between health care entities without improving patient care.

Other comments regarding ratings or measures of equity between providers were mildly controversial.

The majority of commentators were not in favor of rankings and percentiles for measuring health equity, the report noted, and it received mixed feedback on a ranking “threshold” approach, meaning that hospitals would be ranked against a national benchmark or threshold.

Comments were mixed on whether the measure of public reporting disparity for providers was appropriate, although the agency noted that it supported confidential reporting of disparities for a short time, with some noting that data could lead to perpetuated stereotypes about the type of care provided by hospitals or providers. to “certain groups of patients”.

Commenters also suggested that the CMS work to improve the use of SDOH-Z codes for discrepancy reporting. Z-codes are a special subgroup of codes that allow practitioners to generally report “factors influencing health status and contact with health services”. They can identify a range of issues, including education, housing, employment and literacy.

In its comments, the AHA noted that it supports health equity initiatives, but urged CMS to hold equity accountable for organizations in a way that promotes “collaboration, not collaboration.” Competition” and to consider reviewing the data it has already collected before developing new reporting criteria. .

In addition, the AAMC has expressed support for the targeted development of the in-hospital method for confidential reporting, health-related social needs assessment and more.

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