Advancing health equity

CMS's new framework and the role of standardized data collection

Kerry Quealy Son, MSN, FNP-BC,
Kerry Quealy Son, MSN, FNP-BC,
Director of Clinical Innovation
June 10, 2024

The Centers for Medicare and Medicaid Services (CMS) recently unveiled a new framework for Health Equity. According to CMS, health equity means achieving the highest level of health for all individuals, ensuring everyone has a fair chance to attain their optimal health independent of factors such as race, ethnicity, disability, socioeconomic status, preferred language, and other elements that are known to impact access to care and health outcomes. The new framework aims to guide all CMS programs, emphasizing the importance of addressing and eliminating avoidable inequalities.

The framework identifies five priority areas that will inform CMS's efforts over the next decade, emphasizing specific areas where CMS can implement these priorities effectively. Of these, Priority #1 is of particular significance in the realm of health technology. Titled "Expanding the Collection, Reporting, and Analysis of Standardized Data," this priority acknowledges the importance of digital information and interoperability. But what exactly does it entail?

First, it is important to understand the current state of data collection for social determinants. Historically, data on social determinants of health (SDOH) has been collected in various non-standardized ways, which makes analysis very challenging. For example, a care manager employed by a local physician group may conduct a visit with a patient and screen for a variety of social needs, and then document this as a progress note in their EMR. Another care manager, employed by the health plan, may conduct the same type of assessment and document the information for risk adjustment purposes in the health plan's system of record for CMS audits. This non-standardized approach allows for critical information regarding social status for patients to be easily lost or missed. However, the new priority outlined by CMS offers hope for improved data collection around SDOH, with significant implications. Standardizing data collection on patients' social risk factors such as housing status, food access, and employment enables a better understanding of needs, and facilitates connecting patients with appropriate resources.

One tangible application of this priority is evident in the use of Z codes at the provider level. Z codes are billing codes utilized to capture a patient's social status. While clinicians recognize the importance of these factors for patients' health, documenting such codes is often not a priority as they are mostly not reimbursable. However, starting in 2024, CMS is mandating that hospitals would screen for five social determinants of health and document for reimbursement using an approved ICD-10 Z code. CMS offers guidance on how hospitals can screen for these SDOH metrics, typically involving care management teams who conduct SDOH assessments for each patient and inform medical providers of unmet needs.

In summary, CMS's new framework for Health Equity marks a significant step forward in addressing disparities in healthcare access and outcomes. By prioritizing the collection, reporting, and analysis of standardized data, CMS aims to better understand and address social determinants of health, ultimately improving patient outcomes. The mandate for hospitals to screen for social determinants and use Z codes in a standardized manner underscores the importance of integrating social factors into healthcare delivery. Moving forward, this framework presents an opportunity for healthcare providers to not only identify patients' social needs but also to connect them with appropriate resources, fostering a more equitable healthcare system for all.

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