The AAMC Nov. 29 submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the agency’s request for information regarding Hospital Outcome Measurement for Patients with Social Risk Factors.
In its letter, the AAMC applauds CMS for taking the initiative to develop a methodological foundation for quality measurement that can contribute to the narrowing of heath and health care inequities. However, the AAMC strongly urges CMS to rethink its current strategy as the proposed methods and selected risk factors could undermine the ability to isolate true disparities in care quality.
To help CMS advance its disparities measurement efforts to ensure maximum impact for patients and communities, the AAMC made the following recommendations:
Move beyond a methodological strategy grounded in what is currently “feasible” and toward an “accurate and actionable” strategy that takes a more comprehensive and holistic approach to social risk factor selection. While the proposed reliance on dual eligibility status (DE) as a proxy for all social risk factors is currently possible, DE is correlated with patient and community-level risk factors that impact health care outcomes regardless of care quality.
Abandon any plans for “Black/not-Black” comparisons as the statistical mixing of socially advantaged and disadvantaged groups in the “not-Black” category will hide any quality inequities experienced by black Americans.
- Consider how to incentivize health care equity through its measurement programs, as opposed to an exclusive focus on disparity narrowing. CMS may need to incentivize hospitals and providers to invest in the development of the workforce, data infrastructure, and multisector partnerships required to create equitable opportunities for health and health care.
Furthermore, the AAMC also outlined a potential national research and measurement agenda which can help transition from a DE-based methodology to one which maximizes quality measurement’s role in minimizing health care inequities.
Comments are due to CMS by Dec. 14.