The COVID-19 pandemic exposed many systemic problems across the globe, but none more acutely than health disparities in the U.S. healthcare system. The Centers for Medicare & Medicaid Services (CMS) Innovation Center is tackling this disparity head on, with goals to incorporate elements in their health care models that specifically address health equity. The most advanced of these models is the Accountable Care Organization (ACO) Realizing Equity, Access, and Community Health (REACH) program. This refocused and redesigned total cost of care model is designed with three major pillars aiming to reduce health disparities in the traditional Medicare beneficiary populations they serve.
As set forth in their Strategy Refresh, the Innovation Center is committed to including health equity in all its models. For ACO REACH, each ACO must collect certain social determinants of health (SDOH) data for the beneficiaries aligned to the ACO. Participant Providers in the ACO must choose between three standardize collection data tools to fulfill this requirement. The survey asks questions surrounding financial strain, employment, education, substance abuse, and mental health. Providers will also gather data on race, ethnicity, language, sexual orientation, and gender identity. ACOs collecting and reporting this data can use it to identify and target underserved communities experiencing provider shortages, food and housing insecurities, or other social needs.
Secondly, ACOs are required to create a Health Equity Plan or HEP. The HEP is the Innovation Center’s first comprehensive requirement to help ACOs identify health disparities and address the issues. The HEP will be a living document, one that changes as providers and ACOs learn more about the population they serve. Most plans will require additional editing and refinement as more data is captured and care gaps are identified. ACOs are charged with identifying one health disparity experienced by at least one underserved community and working to correct that over the course of the next four years.
Finally, the Innovation Center realizes that the work around health equity and disparities is intensive, usually requiring extra resources. To offset some of that cost, CMS will identify the underserved population using a composite score that incorporates the Area Deprivation Index or ADI as well as Dual Medicaid Status. The ADI is publicly available data that measures down to the census block. For each beneficiary considered in the highest decile, equating to the most underserved population, CMS will increase the ACO’s benchmark (or target spending) by $30 per beneficiary per month. For those ACOs with beneficiaries lower than 5 deciles, CMS will decrease the ACO’s benchmark $6 per beneficiary per month. This assumes that it takes fewer dollars to take care of fewer sick patients.
These three pillars: social determinants of health data collection, the Health Equity Plan, and the benchmark adjustment are a starting point for addressing these issues, but there is much more work to be done. Affecting care in these communities is more than data points and plans; it takes real people making a real difference in the lives of individuals. So, let’s get to work.
The statements contained in this document are solely those of the authors and do not necessarily reflect the views or policies of CMS. The authors assume responsibility for the accuracy and completeness of the information contained in this document.
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