CMS Considers SDOH Screening
[See also the update on this topic posted Feb 4, 2022]
The Centers for Medicare & Medicaid Services (CMS) is considering new requirements for social determinants of health (SDOH) screening for two Medicare programs. The following excerpt from a recent Commonwealth Fund blog post summarizes the significance:
In May 2021, in response to CMS’ annual invitation for new measures, the Physicians Foundation, which is directed by 21 state and county medical societies across the country, submitted the first-ever measures focused on screening patients for food insecurity, housing instability, transportation, utility needs, and interpersonal safety, including intimate partner violence. These measures have been used in more than 600 clinical practices via the Innovation Center’s Accountable Health Communities model and have been subject to rigorous and independent validation. CMS accepted them to its “measures under consideration” list, making them the first to address DoH out of nearly 3,000 total quality measures accepted for consideration in the past decade.
If approved, these measures would apply to two key Medicare programs — the merit-based Incentive Payment System and the Hospital Inpatient Quality Reporting Program — and provide a crucial foundation for comparable measures for the Medicaid Adult and Child Core Measure Set and guidance for states in their efforts to standardize DoH data.
The Accountable Health Communities screen cited above will be familiar to Vermont practices using the SBINS screen from the Blueprint for Health, as SBINS incorporates those measures.
The Physicians Foundation proposal puts into action a question raised this fall by the Congressional SDOH Caucus on standardizing screening tools nationally. A summary of that request for comments can be found here.
One impact of CMS adopting this proposal could be resolution to a lingering debate over which should come first - the screening or the programs to address needs being screened for? There are several reasons why screening might be the answer. The core AHC screening areas correspond to core referral areas covered by 2-1-1 systems and were chosen based on the social risks for which resources are most often available. Some groups argue that, given that starting point, adding a screening requirement that draws attention to the level of need will galvanize action where resources need to be more robust. And the most frequently cited argument for starting with the screens is that they provide insight into program gaps based directly on patients' self-reported needs. Regardless of service programs available to directly address SDOH, these factors do impact health care access and patients' ability to complete treatments, so need to be considered as part of patient health plans. If the data collection is standardized then this helps not only individual organizations choose priority areas for action, but can also roll up to inform state- and national-level policy.
For more information on the landscape of food insecurity screening in Vermont, see this October update.