By Maddie Mason, Senior Associate, Policy  

On June 28, the National Health Council (NHC) submitted our comments to the Centers for Medicare and Medicaid Services (CMS) in response to their Hospital Inpatient Prospective Payment System (IPPS) for Acute Care Hospitals and Long-Term Care Prospective Payment System and Fiscal Year 2022 Request for Information (RFI). This RFI is part of CMS’ efforts to close the health equity gap in CMS hospital quality programs. We share CMS’ goal to improve health equity and eliminate disparities and were pleased to provide feedback on the IPPS rule. 

In our comments, we specifically focused on the following areas: 

1. Demographic Data Collection Improvement 
2. Future Potential Stratification of Quality-Measure Results by Race and Ethnicity 
3. Potential Creation of a Health Equity Score to Synthesize Results Across Multiple Social Risks Factors 

Demographic Data Collection Improvement 

In the RFI, CMS raises questions regarding the creation of an effective data collection system that captures sufficient data that limits bias and the burden on beneficiaries responsible for reporting demographic information. The NHC recommends CMS move quickly to produce a system that will: 

• Engage patients in the process; 
• Remove bias when possible; 
• Collect comprehensive and consistent data; 
• Ensure data interoperability; 
• Educate patients on data usage; 
• Protect patient privacy and security; and  
• Build on existing resources. 

The NHC supports CMS’ proposal to begin collecting a minimum set of data elements by hospitals at the time of admission. This will ensure a consistent approach will be in place, but we urge that education level, income level, and location of residence be included as part of the minimum set.  

Future Potential Stratification of Quality-Measure Results by Race and Ethnicity 

CMS states “self-reported race and ethnicity data are the gold standard for classifying an individual according to race and ethnicity.” The NHC agrees with this sentiment because a self-reporting system allows for the most authentic identity data to be reported. We encourage CMS to work to achieve an effective self-reporting system. Although an algorithmic approach to estimate race and ethnicity can be more functional and allow quick access to information, it is innately limited and can lead to flawed assumptions about a person’s race and ethnicity.  

Potential Creation of a Health Equity Score to Synthesize Results Across Multiple Social Risks Factors 

The NHC supports the creation of a health equity score for hospitals, as it could be a vital resource for hospitals and communities to address health equity. To ensure this effort is successful, we recommend that the score be: 

• Built upon solid and consistent data; 
• Consider which elements are within the hospital’s control to impact; and 
• Include appropriate safeguards to ensure that a score is a valid, useful tool before developing any payment incentives based on score. 

Additionally, the NHC urges CMS to include a composite malnutrition quality measure in the Inpatient Quality Reporting Program.  

For more information, please read our full comment letter here.