NASH Lauds Creation of Congressional Social Determinants of Health Caucus

In a letter to the new Congressional Social Determinants of Health Caucus, the National Alliance of Safety-Net Hospitals expressed its appreciation for the group’s creation and said it would like to work in partnership with the caucus to identify health inequities and help develop ways to address them.

NASH noted that private safety-net hospitals “…have been working for years to address social determinants of health that lead to health inequities,” doing so at times as part of government programs but also on their own in response to the needs of their communities.  In the letter NASH recommended several steps Congress can take to address social determinants of health and pointed to its own response to the caucus’s recent request for information on the challenges stakeholders and Congress face when working to identify and address social determinants of health.

Go here to see NASH’s letter to the Congressional Social Determinants of Health Caucus.

Federal Health Policy Update for Tuesday, September 21

The following is the latest health policy news from the federal government as of 2:45 p.m. on Tuesday, September 21.  Some of the language used below is taken directly from government documents.

NASH Advocacy

  • NASH has submitted formal comments to CMS on the agency’s proposed outpatient prospective payment system regulation for calendar year 2022.  Writing from the perspective of private community safety-net hospitals, NASH addresses proposals and request for information about health equity, the section 340B prescription drug discount program, hospital price transparency requirements, proposed changes in Medicare’s inpatient-only procedures list, and the extension of provider flexibilities introduced in response to the COVID-19 public health emergency.  See NASH’s comment letter here.
  • In July the newly formed Congressional Social Determinants of Health Caucus invited stakeholders to respond to a series of questions designed to help the caucus learn more about social determinants of health and what Congress might do to address them more effectively.  Go here to read NASH’s response to the caucus’s questionnaire.

Provider Relief Fund

  • HHS has updated its Provider Relief Fund reporting portal’s frequently asked questions.  Find the updated FAQ here.
  • HHS has published a Provider Relief Fund reporting portal user guide.  Find the guide here.

The White House

Department of Health and Human Services


  • The federal government has responded to recent increases in COVID-19 cases by assuming control of the distribution of monoclonal antibodies used to treat the virus.  Learn more from the announcement of this new approach.  Federal officials also explain the new policy, why they are pursuing it, and how it will work in this video of a web event.

Health Policy News

  • HHS has extended the open enrollment period for people seeking health insurance on the federally facilitated marketplace and has extended the scope of services provided by navigators for that marketplace.  The department also has authorized state marketplaces to set their own open enrollment dates.  Learn more from this HHS news release.
  • HHS and its Health Resources and Services Administration (HRSA) have awarded $48 million to 271 HRSA-supported health centers in 26 states, Puerto Rico, and the District of Columbia to expand HIV prevention and treatment, outreach, and care coordination services.  To learn more about the awards, how the money will be used, and the award recipients, see this HHS announcement.
  • HHS and HRSA have awarded $350 million in grants to every state to support safe pregnancies and healthy babies.  Funding will be used expand home visiting services to families most in need, increase access to doulas, address health disparities in infant deaths, and improve data reporting on maternal mortality.  The money is being awarded through the Maternal, Infant, Early Childhood Home Visiting Program, the Healthy Start Initiative, and the State Systems Developmental Initiative.  To learn more about how HHS intends for the money to be spent, how much money is being allocated through these programs, and how much money individual recipients will receive, see this HHS announcement.
  • HRSA has announced the availability of funding to support continued access to comprehensive, culturally competent, high-quality primary health care services for communities and populations currently served by its Health Center Program.  Eligible organizations include domestic public or non-profit private entities that propose to serve an announced service area and its associated population(s) to ensure continued access to affordable, quality primary health care services.  Learn more from this HRSA announcement.

Centers for Medicare & Medicaid Services


Health Policy News

  • The latest edition of the CMS online publication MLN Connects includes Medicare’s quarterly provider quality compliance newsletter and information about annual HPSA updates, flu vaccine payment allowances, updated clinical lab fees, and more.  Find the September 16 edition of MLN Connects here.
  • CMS has posted a pre-publication version of a final rule that sets forth revised 2022 user fee rates for issuers offering qualified health plans (QHPs) through Federally-facilitated Exchanges and State-based Exchanges on the federal platform; repeals separate billing requirements related to the collection of separate payments for the portion of QHP premiums attributable to coverage for certain abortion services; expands the annual open enrollment period and Navigator duties; implements a new monthly special enrollment period for qualified individuals or enrollees, or the dependents of a qualified individual or enrollee, who are eligible for advance payments of the premium tax credit (APTC) and whose household income does not exceed 150 percent of the federal poverty level, available during periods of time during which APTC benefits are available such that certain applicable taxpayers’ applicable percentage is set at zero, such as during tax years 2021 and 2022 under the section 9661 of the American Rescue Plan Act of 2021; repeals the recent establishment of a Direct Enrollment option for Exchanges; and modifies regulations and policies related to section 1332 waivers.  Find the document here.
  • CMS has published three FAQs that explain that the agency will not take enforcement action against certain payers for the payer-to-payer data exchange provision of the May 2020 Interoperability and Patient Access final rule until future rulemaking is finalized.  CMS’s decision to exercise enforcement discretion for the payer-to-payer policy until future rulemaking occurs does not affect any other existing regulatory requirements and implementation timelines outlined in the final rule.  Go here to see the announcement and find links to the FAQs.
  • CMS has proposed repealing the Medicare Coverage of Innovative Technology and Definition of ‘”Reasonable and Necessary” final rule, which was published on January 14, 2021 and is scheduled to take effect on December 15.  The repealed rule was a response to concerns that breakthrough technologies were not being made available to the Medicare population in a timely manner but CMS now believes more care must be taken before authorizing the use of such technologies for Medicare patients.  Find the proposed rule here.
  • CMS has published its Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF-PAI) Quarterly Q&As December 2020 document so inpatient rehabilitation facility (IRF) providers have the benefit of clarifications to existing guidance.
  • CMS has published the Long-Term-Care Hospital (LTCH) CARE Data Set Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 document so LTCH providers have the benefit of the clarifications to existing guidance.
  • CMS has awarded $15 million in planning grants to 20 states to support expanding community-based mobile crisis intervention services for Medicaid beneficiaries.  Learn more about the services the grants will underwrite and find a list of grant recipients in this CMS announcement.

Centers for Disease Control and Prevention

Food and Drug Administration

  • The FDA has revised its emergency use authorization (EUA) for the monoclonal antibodies bamlanivimab and etesevimab, administered together, to include emergency use as post-exposure prophylaxis (prevention) for COVID-19 in adults and pediatric patients (12 years of age and older weighing at least 40 kg) who are at high risk for progression to severe COVID-19, including hospitalization or death.  In this revision of the EUA, bamlanivimab and etesevimab, administered together, are authorized for use after exposure to the virus and are not authorized for pre-exposure prophylaxis to prevent COVID-19 before being exposed to the COVID-10 virus.  Learn more from the FDA announcement, the revised EUA, and this fact sheet for providers.
  • The FDA has updated its enforcement policy for masks, barrier face coverings, face shields, surgical masks, and respirators during the COVID-19 public health emergency.  Find the updated policy here.

National Institutes of Health

  • The NIH has awarded $470 million to build a national study population of diverse research volunteers and support large-scale studies on the long-term effects of COVID-19.  Learn more from this NIH news release.

Stakeholder Events

MACPAC – September meetings – September 23 and 24

The Medicaid and CHIP Payment and Access Commission (MACPAC) will hold its scheduled September meeting of commissioners on Thursday, September 23 and Friday, 24 to discuss federal Medicaid and CHIP policies.  The meetings will be held virtually.  Find the meeting agenda here and go here to register to view the sessions.

CDC – Evaluating and Supporting Patients Presenting With Fatigue Following COVID-19 – September 30

The CDC will hold a webinar on evaluating and supporting patients who present with fatigue following treatment for COVID-19.  The webinar will be held on Thursday, September 30 at 2:00 p.m. (eastern).  For further information on the subjects the webinar will cover, those who will be participating in the event, and how to join the webinar, go here.

FDA – Workshop Addressing Response to the Opioid Crisis – October 13

The FDA will hold a workshop titled “Reconsidering Mandatory Opioid Prescriber Education Through a Risk Evaluation and Mitigation Strategy (REMS)” to give stakeholders an opportunity to provide input on aspects of the current opioid crisis that could be mitigated in a measurable way by requiring mandatory prescriber education as part of a REMS effort.  The public workshop will be held on October 13 from 1 p.m. to 5 p.m. (eastern) and October 14 from 1 p.m. to 4:00 p.m.  For information about participating in the workshop or submitting comments or materials, see this Federal Register notice.


NASH Unveils 2021 Advocacy Agenda

NASH has introduced its 2021 agenda.

In the coming year, NASH will:

  • Work to ensure that private safety-net hospitals receive the federal resources and regulatory assistance they need to help their low-income, medically underserved communities through the COVID-19 crisis.
  • Advocate the development and implementation of laws, regulations, and programs that enhance the ability of private safety-net hospitals to serve their communities more effectively.
  • Pursue enhanced access to Medicaid and to affordable, high-quality health insurance.
  • Urge Congress and the administration to work with safety-net hospitals and do more to address the social determinants of health to bring about health equity and better health outcomes in diverse and underserved communities.

To see NASH’s complete 2021 advocacy agenda, go here.

Feds Give States Direction on Addressing Social Determinants of Health

Federal laws, regulations, and programs offer numerous tools to states seeking to address social determinants of health through their Medicaid and Children’s Health Insurance Program (CHIP).  Now, Centers for Medicare & Medicaid Services has written to state Medicaid directors outlining those tools.

In the 51-page letter, CMS notes that

Many Medicaid and CHIP beneficiaries may face challenges related to SDOH [social determinants of health], including but not limited to access to nutritious food, affordable and accessible housing, convenient and efficient transportation, safe neighborhoods, strong social connections, quality education, and opportunities for meaningful employment.  There is a growing body of evidence that indicates that these challenges can lead to poorer health outcomes for beneficiaries and higher health costs for Medicaid and CHIP programs and can exacerbate health disparities for a broad range of populations…

In the letter, CMS describes:

  • Overarching principles CMS expects states to adhere to in their Medicaid and CHIP programs when offering services and supports that address social determinants of health.
  • Services and supports that are commonly covered in Medicaid and CHIP programs to address social determinants of health.
  • Federal authorities and other opportunities under Medicaid and CHIP that states can use to address social determinants of health.

The letter does not introduce new opportunities or flexibilities under Medicaid and CHIP for addressing social determinants of health. Instead, it focuses on helping states identify existing tools, regulations, and programs they can use to facilitate their efforts to address social determinants of health in their individual Medicaid and CHIP programs.

Learn more from the CMS letter “Opportunities in Medicaid and CHIP to Address Social Determinants of Health.”

Azar: More Value-Based Care Coming

Medicare may add more value-based care initiatives and alternative payment models to those it already operates, Health and Human Services Secretary Alex Azar suggested at a recent event in Washington, D.C.

During his remarks, Azar spoke about population health benefits, global budgeting for Medicare patients, more primary care programs, and new models that address kidney care and opioid use and hinted at future efforts that address social determinants of health.

Learn more about Azar’s remarks about Medicare value-based purchasing and alternative payment models and other current federal health policy matters in the Healthcare Dive article “HHS chief keeps focus on alternative payment models.”

Can Medicare Feed its Way Out of Some Readmissions?

Feeding some Medicare patients after they are discharged from the hospital could reduce readmissions and save taxpayers millions, a new study has concluded.

According to the new Bipartisan Policy Center report Next Steps in Chronic Care:  Expanding Innovative Medicare Benefits, providing a limited number of free meals to certain Medicare patients could eliminate nearly 10,000 readmissions a year and save more than $57 million.

Participating patients would be those with more than one of a limited number of chronic medical conditions and the meals would be for one week only.  According to the report, more than 575,000 Medicare beneficiaries would be eligible to participate in such a program, with their meals costing $101 million a year, or $176 a person for one week, but the nearly 10,000 Medicare readmissions that would be prevented would reduce Medicare spending more than $158 million a year.

Such a program, if implemented, would be yet another approach to addressing the social determinants of health in many communities.

Such a program would undoubtedly benefit the low-income communities most private safety-net hospitals serve because food insecurity is one of many social determinants of health that challenge the health of the residents of those communities.

Learn more about how such an approach would work and whom it would serve in the Bipartisan Policy Center report Next Steps in Chronic Care:  Expanding Innovative Medicare Benefits.

New Bill Would Address Social Determinants of Health

The federal government would provide funding to help address social determinants of health within Medicaid populations under a new bill introduced in the House of Representatives last week.

According to a legislative summary prepared by one of the bipartisan bill’s sponsors,

Economic and social conditions have a powerful impact on our health and wellness. Stable housing, reliable transportation and access to healthy foods are all factors that can make a difference in the prevention and management of many health conditions like diabetes, asthma and heart disease. Known as social determinants of health, a focus on these non-medical factors can improve health outcomes and wellbeing. States are increasingly looking to deploy social determinants of health interventions to manage costs and improve health outcomes within their Medicaid programs. However, one of the greatest challenges to high-impact interventions is the difficulty in navigating and coordinating fragmented and complex programs aimed at addressing healthcare needs, food insecurity, housing instability, workforce supports, and transportation reliability, among others.

To address these challenges, the bill would

help states and communities devise strategies to better leverage existing programs and authorities to improve the health and well-being of those participating in Medicaid. The legislation will provide planning grants and technical assistance to state, local and Tribal governments to help them devise innovative, evidence-based approaches to coordinate services and improve outcomes and cost-effectiveness.

Such legislation could be especially beneficial to the communities served by private safety-net hospitals, which generally can be found in low-income communities whose residents’ health is often shaped in large part by social determinants of health.

Learn more about the Social Determinants Accelerator Act by reading a summary of the bill’s key provisions and an FAQ on the bill.

The Role of Medicaid in Addressing Social Determinants of Health

Medicaid can play a major role in addressing the social determinants of health.

Or so argues a recent post on the Health Affairs Blog.

According to the post, social determinants of health – income, education, decent housing, access to food, and more – significantly influence the health and well-being of individuals – including low-income individuals who have adequate access to quality health care.  Medicaid, the post maintains, can play a major role in addressing social determinants of health.

The post outlines the role state Medicaid programs can play in addressing social determinants of health; describes tools for such action such as section 1115 Medicaid demonstration waivers; offers examples of efforts currently under way in some states; and presents suggestions for steps the federal government can take to facilitate such efforts.

Addressing social determinants of health is an especially important issue for private safety-net hospitals because they care for so many more Medicaid-covered low-income patients than the typical American hospital.

Learn more from the Health Affairs Blog post “For An Option To Address Social Determinants Of Health, Look To Medicaid.”


Tackling Social Determinants of Health

Two states are working to address social determinants of health through their Medicaid programs.

In California and Oregon, the state Medicaid programs are using care coordination and funding from multiple sources, including traditional Medicaid funding, alternative payment approaches, and savings from care coordination to provide services such as housing, food, and legal assistance while also building the capacity of health care and community groups to support such efforts.  Both states obtained federal Medicaid waivers to enable them to expend Medicaid resources on non-Medicaid-covered services.

Learn more about how California and Oregon are using their Medicaid programs to address social determinants of health in the Health Affairs report “Medicaid Investments To Address Social Needs In Oregon And California.”

Medicare Advantage Permitted to Address Non-medical Needs

Starting in 2020, Medicare Advantage plans will be permitted to provide non-medical benefits to their chronically ill members.

As described in the Centers for Medicare & Medicaid Services’ “final call letter’ for 2020,

MA [Medicare Advantage] plans are not prohibited from offering an item or service that can be expected to improve or maintain the health or overall function of an enrollee only while the enrollee is using it.  In other words, the statute does not require that the maintenance or improvement expected from an SSBCI [special supplemental benefits for the chronically ill] result in a permanent change in an enrollee’s condition.  Items and services may include, but are not limited to:  meals furnished to the enrollee beyond a limited basis, transportation for non-medical needs, pest control, air quality equipment and services, and benefits to address social needs, so long as such items and services have a reasonable expectation of improving or maintaining the health or overall function of an individual as it relates to their chronic condition or illness.

The CMS final call letter offers permission to Medicare Advantage plans to offer such services; it does not require them to do so.

Such a policy change could be highly beneficial to many of the low-income patients served by private safety-net hospitals, which have long sought help with addressing the social determinants of health that often bring patients to them but limit their ability to recover from their illnesses and injuries.

Learn more from the Commonwealth Fund report “New Medicare Advantage Benefits Offer Social Services to People with Chronic Illness” and see CMS’s “Announcement of Calendar Year (CY) 2020 Medicare Advantage Capitation Rates and Medicare Advantage and Part D Payment Policies and Final Call Letter.”