The Centers for Medicare & Medicaid Services’ (CMS) Office of Mental Health report CMS Framework for Health Equity 2022 and 2032 states that health equity is defined by the attainment of the highest level of health for all people, where everyone has a fair and just opportunity to attain their optimal health regardless of race, ethnicity, disability, sexual orientation, gender identity, socioeconomic status, geography, preferred language, or other factors that affect access to care and health outcomes. The report additionally states, in order to attain the highest level of health for all people, we must give our focused and ongoing attention to address avoidable inequalities and eliminate health and health care disparities.
This CMS framework aligns with the Healthy People 2030 framework. According to Healthy People 2030, social determinants of health (SDOH) are the conditions in the environments where people are born, live, learn, work, play, worship, and age that affect a wide range of health, functioning, and quality-of-life outcomes and risks. Globally, social determinants of health are important in the health equity discussion.
At the September 2023 Health Equity Conference, a key takeaway in the Post Conference Report stated proper data collection and analysis can improve access to care and increase health equity across different sectors, and expanding data tracking to include SDOH and SOGI data can help address health disparities.
MDS and SDOH
Why are we discussing these CMS and HHS topics of health equity and social determinants of health? In the skilled nursing home setting, as of October 1, 2023, we are now collecting data via the minimum data set (MDS) that addresses social determinants of health.
The data elements of the MDS that have been identified as standardized patient assessment data (SPADES) and SDOH are:
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- A1005 Ethnicity
- A 1010 Race
- A1110 Language
- A1250 Transportation (from NACHC©)
- B1300 Health Literacy
- D0700 Social Isolation
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By integrating these SDOHs into the MDS, CMS will be able to further evaluate for quality and completeness.
IMPACT OF INACCURATE DATA
Facilities continue to face hurdles implementing these new or improved data elements. These SDOH data elements vary in steps for assessment, contributing to the difficulty of accuracy in completion. The immediate effect of inaccurate completion of the SDOH data elements could lead to inaccurate care planning, discharge planning along with the facility’s final validation report containing warnings/errors.
Additionally, the impact of inaccurate and incomplete data collection may not be immediately seen. For example, future reimbursement may be affected by dashing in specific SDOHs – as referenced in the SNFQRP FY 2025 annual payment update – as data is being collected as of October 1, 2023.
What Should We Be Doing Now?
Let’s take a step back and review a few practices that may assist with completing accurate data elements of the MDS.
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- Ensure the MDS team has reviewed and been trained on the October 2023 changes – and understands the implications of inaccurate coding.
- Identify the appropriate team member(s) to complete the data element(s).
- Provide the time and resources for the assigned team member to complete the assigned data element(s).
- Develop a plan to audit for accuracy and completeness.
- Devise a monitoring program and put it in place.
- Set up a schedule to review at the QAPI/QAA meeting.
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Works Cited
- CMS Framework for Health Equity 2022–2032
- Healthy People 2030
- 2023 CMS Health Equity Conference: Post Conference Report
- The Path Forward: Improving Data to Advance Health Equity Solutions