News on Nondiscrimination and Reducing Health Disparities
In September, the Department of Health and Human Services (HHS), Office for Civil Rights (OCR) released for public comment a proposed rule on Nondiscrimination in Health Programs and Activities. Community Catalyst submitted comments and recommendations focused on strengthening the application and scope of the proposed rule in terms of language access, disability and sex discrimination, nondiscrimination in health insurance and compliance and enforcement through robust data collection.
On the health disparities front, HHS released an Implementation Progress Report on its Action Plan to Reduce Racial and Ethnic Health Disparities. The HHS Disparities Action Plan is a federal commitment to reducing, and eventually eliminating, disparities in health and health care. The report provides an overview of the priorities and goals that make up the strategic plan and also describes some of the major actions and activities that agencies have undertaken to implement the plan since its original publication in April 2011.
Prevention Institute Report on Health Equity Metrics
A new report released by Prevention Institute and commissioned by the Robert Wood Johnson Foundation, provides a framework for understanding how disparities in health outcomes are produced and how health equity can be achieved, particularly by addressing the determinants of health. Measuring What Works to Achieve Health Equity: Metrics for the Determinants of Health lays out the determinants of health – structural drivers, community determinants and health care – that must be improved to achieve health equity. It also describes the methods and criteria that Prevention Institute applied to identify health equity metrics. Finally, the paper delineates a set of metrics that could reflect progress toward achieving health equity.
Monthly Update on Dual Eligible Demonstration Enrollment
The weekly Health Management Associates (HMA) newsletter focuses on the dual eligible demonstration projects, and specifically on enrollment. As of October 2015, there are over 372,000 people enrolled in the those demonstrations using a fully capitated financial approach. That represents about 30 percent of the potential enrollment of 1.2 million across the ten states using the capitated model (Rhode Island has yet to begin enrollment). Over half of the individuals enrolled in these demonstrations are members of publicly-traded plans, with 42 percent of enrollees in non-publicly traded plans. HMA’s enrollment numbers do not include dual eligibles enrolled in the managed fee-for-service demonstrations in Colorado and Washington State.
CMS Soliciting Comments on Discharge Planning and Quality Rating Strategy
The Centers for Medicare and Medicaid Services (CMS) released for public comment a proposed rule providing revisions to requirements for discharge planning for hospitals and home health agencies. This proposed rule would revise the discharge planning requirements that hospitals, including long-term care hospitals, inpatient rehabilitation facilities, critical access hospitals and home health agencies must meet to participate in the Medicare and Medicaid programs. The proposed rule would also implement the discharge planning requirements of the Improving Medicare Post-Acute Care Transformation Act of 2014. Comments are due January 4, 2016.
The Medicare-Medicaid Coordination Office (MMCO) within CMS is also seeking comment from Medicare-Medicaid Plans (MMPs) and other stakeholders to inform the development of a star rating system for MMPs under the Financial Alignment Initiative. While a fully mature star rating system will not be in place during the testing of the Medicare-Medicaid capitated financial alignment model, CMS is working to prepare for the potential future expansion of the capitated financial alignment model, though not officially proposing to expand the capitated model demonstration at this time. The MMCO strategy paper states, “The MMP star rating system should also be robust enough to serve as a potential basis for quality-based payments for plans that would promote value-based payment systems, improved care coordination, and enhanced population health, as envisioned by the Secretary.”