Congressional SDOH Caucus
Earlier this week was the deadline for comments on the Congressional Social Determinants of Health caucus’ Request for Information (RFI). This caucus is working on improving coordination between health and social services programs at the federal level and investing in evidence-based approaches to holistic well-being.
The questions in the RFI were wide ranging. While the summary of public comments isn’t yet posted, associations and non-profit organizations have been sharing their submissions:
Aligning for Health - Listed first because their comments provide a short list of relevant pending legislation (p. 8) that’s good to browse for examples of the types of legislation this caucus might facilitate. The American Hospital Association supports social and health care alignment through this organization.
One challenge that this work tackles is how to move back and forth from investing in broad structural changes to improve health (for example making nutritious foods an easy choice for everyone) and investing in holistic care for individuals (for example supporting a high level of engagement of health care teams for helping patients use diet to treat chronic conditions, you can see this in the comments in making audio-only telehealth / bundled telehealth services reimbursable). The comments, therefore, cover a wide range of topics.
The comments also address considerations in managing information and data - which are not a focus for their own sake, but have implications for outreach, providing higher quality treatment, and payment. The major health care practice associations did not agree on priorities. Some specific areas of disagreement include whether to look for standardized systems for screening & referring around SDOH first or simply support implementing any system in practices, investment in “closed loop” referrals to community organizations, and how soon to push for linking screening & referral to payer contracts.
There are risks in not investing in standardization early. For example, some forms of food insecurity screening miss a significant number of households - tying services to a positive screen in that situation can create a barrier to access. There is also a risk that, if every health care practice creates their own system, community partners will be faced with an array different systems to connect through - creating another set of barriers and administrative burden that takes away from services. Some previous reports on this topic that are referenced in the SDOH Caucus comments:
Office of the National Coordinator for Health IT - SDOH Reports & Projects
Leveraging Data on the Social Determinants of Health - Report to HHS (2019)
HIMSS (Healthcare Information and Management Systems Society) SDOH Report - If you want to know what the other reports are talking about when they say HL7 FHIR, this explains (it’s an interoperability thing)