The Centers for Medicare and Medicaid Services launched the Framework for Health Equity in April, seeking to refresh its approach to addressing the needs of underserved communities.
The Framework is the agency’s plan to address the inequality of experiences, benefits and opportunities of underserved communities. The Framework is an update of CMS’s previous plan, and the Framework is designed to instill equity considerations into all of the agency’s programs, not just Medicare, but including Medicaid, CHIP, and the Health Insurance Marketplace. It is a more comprehensive ten-year approach.
As the nation’s largest health insurance provider, facilitating health care and coverage for more than 170 million people, CMS’s work will undoubtedly have an impact on the nation’s entire health care system. In an effort to target “underserved communities,” CMS paints with a wide range of brushes to address the concerns of people with disabilities as well as members of racial and ethnic communities. To do. Member of the LGBTQ+ community. Individuals with limited English proficiency. members of rural communities; and those otherwise experiencing the adverse effects of persistent poverty and inequality.
This framework addresses CMS’ ability to ascertain whether and to what extent CMS’ programs and policies “perpetuate or exacerbate systemic barriers to opportunity and benefit” among underserved communities. designed to enhance the
Framework implementation
CMS plans to implement that framework by addressing five stated priorities.
The first is to expand the collection and use of data collection from historically underserved communities. Second, he assesses CMS programs for the causes of inequality and addresses policies and practices that may contribute to inequality. The third is to build the “collective capacity” of healthcare institutions and workforces to reduce inequality. Second, promote language access, health literacy and culturally adapted services to reduce the burden of disparities in these areas on health outcomes. And finally, health care organizations and providers will increase the accessibility of services so that 1 in 4 of her American adults with some form of disability is covered.
CMS recognizes the scope and achievements of current programs and the agency’s intention to expand some aspects of these programs to support its 10-year plan to “Achieve Health Equity and End Inequalities.” outlined the planned implementation by highlighting the Agencies have already begun implementing plans to achieve their priorities.
CMS recently announced the availability of grants to support the design and testing of interventions that may reduce disparities in underserved communities. He has also released a fact sheet listing some of the most pressing barriers to health equity and identifying his CMS resources to help address those barriers.
This framework is a positive first step towards addressing an important need. But the devil is in the details.
The framework describes how some of the current programs affect program implementation, but how the CMS addresses some of the significant hurdles that the plan might face in implementation. does not provide enough information to fully analyze how to address
data privacy
for example, This framework relies on collecting new and more types of data to power many of the current programs in CMS. However, adding new data elements introduces additional privacy concerns. CMS should be proactive.
External parties responsible for collecting this additional data must ensure that they comply with patient privacy laws and that all data collected is protected from compromise. Healthcare providers must also ensure compliance with all federal and state privacy laws that require written consent from patients before releasing patient health information to other people or organizations.
Failure to obtain proper consent or adequately protect information from potential breaches can inadvertently expose providers and external stakeholders to liability.
Review of subscription/compensation conditions
Another option to address health equity and disparity issues discussed in the Framework is CMS, stating that “organizations must meet in order to initiate and continue participation in Medicare and Medicaid programs.” to check the conditions.
CMS anticipates that these efforts will help identify and remove potential barriers to registration and access to CMS benefits and services by underserved communities. No further discussion, Or an example of the kind of change that might be suggested.
Healthcare providers must meet the requirements to participate in Medicare and Medicaid programs. This condition sets standards for quality concerns and beneficiary protection.
It is imperative that proposed changes consider not only their potential impact on improving health equity, but also their impact on organizations. Healthcare organizations are so poorly informed in the framework of what will happen that they may be ill-prepared to respond.
Insufficient guidance provided by CMS
CMS provided a detailed framework to preview many of the programs it plans to expand or redirect to meet its goals of achieving health equity and closing inequalities, but there are some solutions we may consider. does not provide sufficient guidance to determine how some of the I don’t.
Health care organizations can use their own internal programs to address health equity issues, share their experiences and help the CMS shape the details of the framework so that they can be on the “what”. You can prepare.
In the next iteration of guidance on the CMS framework, the initiative’s legal framework will be developed to enable providers to assess the potential impact of proposed solutions and better assist CMS in achieving its key goals. and provide more detailed information on administrative impact.
Until then, healthcare organizations and providers seeking to partner with CMS in their efforts to improve health equity and reduce health disparities will find their way without a map.
This article does not necessarily reflect the opinions of The Bureau of National Affairs, Inc., publishers of Bloomberg Law and Bloomberg Tax, or their owners.
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Janelle Alleyne He is a health law and litigation attorney at Baker, Donelson, Bearman, Caldwell & Berkowitz PC in Atlanta. She specializes in medical regulation and compliance, and complex tort litigation.
Stephanie Jones Doyle He is a health attorney at Baker, Donelson, Bearman, Caldwell & Berkowitz PC in Washington, DC. We represent clients on a variety of healthcare regulatory and compliance issues, with a focus on post-acute and long-term care. provider.
