Policy
NASDOH Policy Activity
Medicare

NASDOH’s Comments on the Contract Year (CY) 2021 and 2022 Medicare Advantage (MA) and Part D Proposed Rule

(2020)

NASDOH continues to be appreciative of CMS’s commitment to ensuring that MA plans have flexibility to offer Special Supplemental Benefits for the Chronically Ill (SSBCI) that meet the unique, nonuniform needs of their plan populations, including providing coverage of benefits that are not primarily health related and that address the SDOH. In its comment letter, NASDOH supported CMS’ efforts to codify SSBCI policies on “not primarily health related” benefits previously outlined, to expand its list of eligible chronic conditions for SSBCI benefits, and provides flexibility around the Medical Loss Ratio.

To view the letter, please click here.

NASDOH’s Comments on the 2020 Medicare Advantage Call Letter

(2019)

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.

Please read our comment letter here.

 

CMS Resources regarding the CY 2019 Call Letter

Medicaid

NASDOH’s recommendations to Medicaid to accelerate the work of states and providers

(2019)

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.

NASDOH ONE-PAGER: Supporting State Innovation in Medicaid: Policies for Addressing Social Determinants of Health

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).

Center for Medicare and Medicaid Innovation

NASDOH’s Response to the Direct Contracting – Geographic Population-Based Payment Model Option RFI

(2019)

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 our comment letter here.

Congress

NASDOH Comment Letter to the U.S. House of Representatives Committee on Ways and Means and the Rural and Underserved Communities Health Task Force RFI

(2019)

NASDOH was encouraged by the inclusion of the social determinants of health in the Committee and Task Force’s approach to improving health outcomes in rural or underserved communities. In our comment letter we provided responses to specific questions related to the social determinant of health and provided links to additional resources that might be useful to the Committee and the Task Force. We look forward to the opportunity to engage in further dialogue on these issues and welcome any questions or request for additional information.

Please read our comment letter here.

Other HHS

NASDOH’s comments on the OIG’s proposed rule addressing safe harbor protections under the Federal antikickback statute

(2019)

NASDOH commended HHS for addressing the social determinants of health (SDOH) in the Regulatory Sprint to Coordinated Care. We were pleased to provide comments on the Office of Inspector General (OIG)’s proposed rule to revise the safe harbor protections under the Federal antikickback statute. We believe that inclusion of safe harbors that have the potential to protect interventions to address the social determinants of health from violations under the Federal anti-kickback statute is an important next step.

Please see our full comments in the letter here.

NASDOH’s Response to the HHS Chief Technology Officer’s PreventionX RFI

(2019)

NASDOH commends the Office of the Chief Technology Officer (CTO) for his efforts to catalyze the shift towards a value-based health care system focused on rewarding and improving patient outcomes and scaling and deployment of effective prevention strategies in the social and economic environment. We appreciated the opportunity to provide comments on the PreventionX RFI and provided a multi-sectoral perspective on the importance of addressing social determinants of health as part of chronic disease prevention strategy, and to support transformation to value-based care.

Please read our comment letter here.

NASDOH’s Letter to the HHS Chief Data Officer

(2019)

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’s Letter to HHS describing the ROI of SDOH Interventions

(2019)

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.

NASDOH’s Letter to Office of Civil Rights on Modifying HIPAA to improve Care Coordination

(2019)

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’s comments on the Surgeon General’s “Community Health and Prosperity” document

(2018)

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.

NASDOH thank you letter: The Root of the Issue: America’s Social Determinants of Health: Intermountain Healthcare and Hatch Center for Civility and Solutions 2018 symposium

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 see the comment letter here .