CMS and SDOH Screening Update
In December we posted an update on CMS considering systems to address health-related social needs as part of health care quality measurement. The measure would look at SDOH screening that covers issues of food insecurity, housing instability, transportation problems, utility help needs and interpersonal safety.
In late January, the National Quality Forum (NQF) met to consider the proposed measures for the Merit-Based Incentive Payment System (MIPS) and Inpatient Quality Reporting System (IQR). NQF provides input to HHS on quality measures. The questions put out for public comment to inform their final recommendation were:
How would adding this measure add value? How would the measure improve patient outcomes?
Do the benefits of the measure outweigh the burden of data collection or reporting?
For what purpose are you using the measure (e.g., QI, certification/recognition, regulatory/accreditation, payment, public reporting, disease surveillance)?
Are there implementation challenges?
On February 1st, NQF released their recommendations. They conditionally supported addition of the health-related social needs screening measure. The report noted that this measure is an important first step in addressing these needs. It also raised some concerns about the measure:
Support is contingent on review of reliability and validity.
Concern that the goal of incorporating SDOH into quality measures is for health care systems to help patients bridge to social and community support systems to address health-related social needs. A measure of screening alone does not reflect whether this connection occurred. Screening alone doesn’t even measure whether an individual patient agrees that they need assistance.
Concern that health care providers not be punished for a high percentage of positive screens compared to other providers (CMS clarified that this was not the intent).
Concern that the public may misinterpret the measure, for example by penalizing providers who are serving populations with a high level of social risk factors.
The 2021-2022 year review cycle was the first to incorporate a dedicated Health Equity advisory group and the full report on recommendations will be published in early March.
In January, CMS released a proposed rule that considered screening for social risks within Medicare Advantage Special Needs Plans. This rule also drew from the results of the Accountable Health Communities model and their Health-Related Social Needs screening system. However, the context is quite different. The MA Plans that are the focus of this proposed rule already have a regulatory structure with care plan requirements and addressing social needs. So, the question here is truly one of whether there should be a standardized screening system - not a chicken or egg question around requiring social risk screening first or response systems first (or neither, or both). This more closely matches the AHC approach, which included risk screening and addressing the results as an integrated goal.