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Federal Register / Vol. 86, No. 147 / Wednesday, August 4, 2021 / Rules and Regulations
Multiple commenters expressed concern about the patient and familys perception of the organization if given a data collection questionnaire upon admission, noting that they may think the organization is more focused on data collection rather than care.
Other commenters noted the importance of closing the health equity gap through measurement of demographic characteristics. A
commenter suggested that agencies leverage the role of nurses in identifying sociodemographic factors and barriers to health equity. Another commenter supported this method, noting that although this may add another step to data collection processes, it would be valuable in addressing health equity gaps. To reduce possible workload burden on organizations that are new to this process, a commenter recommended a staggered approach to data collection, suggesting CMS require providers and facilities to collect data on age and sex by the end of 2022, race and ethnicity by the end of 2023, etc., with the goal of at least 80 percent data completeness with 80 percent accuracy.
In addition, commenters suggested reducing burden by adopting standardized screening tools to collect this information, such as ICDZ-codes, which in practice would allow patients to be referred to resources and initiatives when appropriate. Several commenters encouraged collection of comprehensive social determinants of health and demographic information in addition to race and ethnicity, such as disability, sexual orientation, and primary language. Several commenters provided feedback on the potential use of an indirect estimation algorithm when race and ethnicity are missing/
incorrect, and emphasized the sensitivity of demographic information and recommended that CMS use caution when using estimates from the algorithm, including assessing for potential bias, reporting the results of indirect estimation alongside direct selfreport at the organizational level for comparison, and establishing a timeline to transition to entirely directly collected data. Commenters also advised that CMS be transparent with beneficiaries and explain why data are being collected and the plans to use these data. A commenter noted that information technology infrastructure should be established in advance to ensure that this information is being used and exchanged appropriately.
We appreciate all of the comments and interest in this topic. We believe that this input is very valuable in the continuing development of the CMS
health equity quality measurement
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efforts. We will continue to take all concerns, comments, and suggestions into account for future development and expansion of our health equity quality measurement efforts.
Potential Creation of a Facility Equity Score To Synthesize Results Across Multiple Social Risk Factors The possible creation and confidential reporting of a Facility Equity Score to synthesize results across multiple social risk factors and disparity measures.
Interventions facilities could institute to improve a low facility equity score and how improved demographic data could assist with these efforts.
We received comments on these topics.
Comments: Commenters generally supported ongoing thoughtful investigation into best practices for measuring health equity.
Many commenters expressed concerns about the potential Facility Equity Score. Commenters argued that the current approach used to generate the composite score may not lead to aggregate results, which would not be actionable for many facilities.
Commenters also raised concerns about risk adjustment, limitations in stratification variables, and the appropriateness of the current measure set. A commenter noted that although they support thoughtful efforts to categorize performance, the HESS has been established only as a proof of concept and will require considerable time and resources to produce a valid and actionable measure. The same commenter also noted that HESS
scoring was only feasible for less than one-half of Medicare Advantage MA
plans and as such, may not be practical for many smaller facilities, or facilities whose enrolled populations differ in social risk factor distribution patterns compared to typical MA plans.
Commenters generally did not support use of the Facility Equity Score in public reporting or payment incentive programs, suggesting that it is imperative to first understand any unintended consequences prior to implementation. More specifically, several commenters gave the example of facilities failing to raise the quality of care for at-risk patients while appearing to achieve greater equity due to lower quality of care for patients that are not at risk. A commenter stated the belief that CMS should begin their initiative to improve health equity by using structural health equity measures.
Commenters also raised concerns about use of dual-eligibility as a social risk factor due to variations in state-level
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eligibility for Medicaid, making national comparisons, or benchmarking of facility scores unreliable. Additionally, commenters who expressed data reliability concerns recommended that CMS focus its resources on improving standardized data collection and reporting procedures for sociodemographic data before moving forward with a Facility Equity Score.
We appreciate all of the comments and interest in this topic. We believe that this input is very valuable in the continuing development of the CMS
health equity quality measurement efforts. We will continue to take all concerns, comments, and suggestions into account for future development and expansion of our health equity quality measurement efforts.
We also received comments on the general topic of health equity in the IPFQR Program.
Comments: Many commenters expressed overall support of CMS goals to advance health equity. There were some comments regarding the need to further extend and specify the definition of equity provided in the proposed rule.
Commenters also noted that equity initiatives should be based on existing disparities and population health goals, be mindful of the needs of the communities served, and work to bridge hospitals with post-acute and community-based providers. Several commenters encouraged CMS to be mindful about whether collection of additional quality measures and standardized patient assessment elements might increase provider burden. Several commenters noted support for consideration of a measure of organizational commitment to health equity, outlining how infrastructure supports delivery of equitable care. A
commenter noted the importance of focusing programming on inequities in vaccine-preventable illness. Another commenter noted that CMS may expand their view of equity beyond quality reporting to payment and coverage policies.
We appreciate all of the comments and interest in this topic. We believe that this input is very valuable in the continuing development of the CMS
health equity quality measurement efforts. We will continue to take all concerns, comments, and suggestions into account for future development and expansion of our health equity quality measurement efforts.
E. Measure Adoption We strive to put consumers and caregivers first, ensuring they are empowered to make decisions about their own healthcare along with their
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