NASDOH commends the Centers for Medicare and Medicaid Services (CMS) Center for Medicare and Medicaid Innovation (CMMI) for their efforts to improve the quality of care and health outcomes for Medicare beneficiaries. In particular, NASDOH is encouraged by the inclusion of social determinants of health in the Geographic Population Based Payment model, which provides direct contract entities (DCEs) the opportunity to assume total cost of care (TCOC) risk for Medicare fee-for-service beneficiaries in a specific geographic area. NASDOH drafted a response to CMS’s request for information (RFI) on Direct Contracting – Geographic Population-Based Payment Model Option. Our response offers several elements that we believe should be taken into consideration to help DCEs and community partners work together to accomplish the goals of the Geographic PBP model. Please read out comment letter here.

NASDOH appreciates the leadership from the U.S. Department of Health and Human Services (HHS) Secretary Alex Azar and the Center for Medicare & Medicaid Services (CMS) Administrator Seema Verma in highlighting the critical role that social determinants play in health. NASDOH encourages CMS to further encourage state Medicaid programs to address the social determinants of health without undermining its core purpose. Please see here a letter addressed to Administrator Verma that highlights NASDOH’s recommendations to accelerate the work of states and providers. In addition, NASDOH has developed a one-pager that highlights the importance, as well as the opportunities, of supporting state innovation and policies that address social determinants of health in the Medicaid environment (see one-pager here).

On November 14, 2018, Intermountain Healthcare and the Hatch Center for Civility and Solutions hosted a symposium titled The Root of the Issue: America’s Social Determinants of Health. Many health care leaders and policy makers attended the symposium to discuss the impact of “upstream” factors such as housing instability and chronic hunger on the health of people in Utah and across the nation. U.S. Secretary of Health and Human Services, Alex Azar, provided remarks on the ongoing Departmental policy efforts to address the social determinants of health (SDOH). NASDOH appreciates Secretary Azar’s remarks in a letter submitted in early December 2018 that highlights the Department’s efforts and commitment. Please click here to view the letter.

One of the largest problems on the journey to better address the social determinants of health is the fragmented coordination process between community-based organizations and health care entities. NASDOH submitted a letter on March 4th, 2019 to the Chief Data Officer (CDO) at the U.S. Department of Health and Human Services (HHS) that outlines several use cases and associated case studies. The letter is intended to inform the CDO on potential actions to promote transparency of, access to, aggregation of, and integration and sharing of, appropriate data and technology across sectors to assess and address social determinants of health at the individual and community level. Please click here to view the letter.

NASDOH is excited to see that the Centers for Medicare and Medicaid Services (CMS) has taken the approach in the 2020 Medicare Advantage Call Letter that would allow plans to “vary, or target, [Special Supplemental Benefits for the Chronically Ill] SSBCI as they relate to the individual enrollee’s specific medical condition and needs.” In response to the Draft Call Letter, NASDOH provided recommendations on two requests for comments around flexibility to determine what is a chronic condition that meets statutory standard and the limits of supplemental benefits for chronically ill enrollees. To view the letter, please click here.

NASDOH members recently met with the U.S. Department of Health and Human Services (HHS) Deputy Secretary to discuss federal statutory and regulatory barriers to implementing a value-based framework that sustains social determinants of health efforts and that addresses care for the whole person. In follow up to this conversation, NASDOH provided a letter that includes evidence for specific social determinants of health interventions that may deliver consistent return on investment (ROI). Please view the letter here.

The Bipartisan Budget Act of 2018 was signed into law on February 9, 2018. The Act includes Title VIII — Supporting Social Impact Partnerships to Pay for Results (SIPPRA) and was first introduced by Senator Todd Young (R-Ind.), but appears to have bipartisan support from Members of Congress. SIPPRA would fund social programs that achieve real results and redirect funds from ineffective programs to programs with demonstratable results. See the SIPPRA legislation here and a summary, including goals, social impact partnership requirements, process and governance, and funding aspects here.

NASDOH is grateful for the opportunity to provide our collective comments on how the Health Insurance Portability and Accountability Act (HIPAA) Rules could better promote coordinated and value-based health care, particularly as it relates to the ability of covered entities to disclose protected health information (PHI) to social service agencies. Please click here to view NASDOH’s comment letter.

NASDOH appreciates the Surgeon General for his efforts to highlight the importance of community health and vitality through his interest in soliciting comments on the upcoming Surgeon General’s Call to Action document, “Community Health and Prosperity.” NASDOH provides an overview of multi-sectoral alliance efforts to achieve similar goals, including several examples of local, successful efforts on the part of our members. Please click here to view.


CMS Call Letter: Reinterpretation of “Primarily Health Related” for Supplemental Benefits

HPMS Memo Primarily Health Related 4-27-18 (002)

CMS Call Letter: Reinterpretation of the Uniformity Requirement

HPMS Memo Uniformity Requirements 4-27-18