CMS Action Plan Calls for Health Equity Alignment

Common threads are emerging across CMS, its programs, and the private sector.

CMS' new action plan to advance health equity suggests what industry analysts have been predicting: that health equity will be a shared mandate, with specific steps to drive alignment and collaboration across the public and private sector.

In a press release about the action plan, CMS Administrator Chiquita Brooks-LaSure stated: "Health equity will be embedded within the DNA of CMS and serve as the lens through which we view all of our work."

Per the release, CMS' equity work will span all its Centers and Offices and includes nine actions:

• Reduce gaps in access, quality, and outcomes
   
• Ensure services are culturally and linguistically appropriate
   
• Increase Medicare, Medicaid/CHIP, and Marketplace enrollment
   
• Grow data collection and standardization, particularly related to health equity
   
• Support providers who care for the underserved
   
• Help underserved communities implement and be accountable for programs
   
• Use screening and subsequent data to identify and address needs
   
• Design CMS programs to be successful and executable
   
• Strive to provide the best and safest care

Linkage to CMMI

The CMS action plan follows the strategy refresh that one of its agencies, the Center for Medicare and Medicaid Innovation (CMMI), announced in October 2021. CMS and CMMI common objectives include equity, innovation, and partnership. CMS' other Strategic Pillars are Expand Access, Protect Programs, and Foster Excellence. Unique CMMI objectives include Drive Accountable Care and Address Affordability, which are further supported by ACO REACH, its recently announced and reimagined accountable care model.

Sean Creighton, managing director of revenue at Avalere, has noted: "There is a more refined relationship between the two [CMS and CMMI] due to new issues—equity—and more collaboration around innovation." Commenting on CMS' "surprising level of focus on health equity proposals," Creighton notes the operational and revenue effects for which private insurers must continue to plan.

Convening for better equity

As part of its press release, CMS stated that it will convene "healthcare facilities, insurance companies, state officials and providers" this summer as the agency seeks input from private and public stakeholders.

These requests have included equity design feedback in CMS' 2023 Notice of Benefit and Payment Parameters (NBPP) rule. NBPP included proposals that Marketplace plans support in general while noting the many components—data, measures—that need time to sort.

These proposals fall in line with the agency's intent to "lean on [the] private sector to address costs, disparities." CMS' Brooks-LaSure expressed this intention at the J.P Morgan Health Care Conference in January, adding: "Our role with the private sector is really partnering and trying to align goals."

In its strategy refresh lessons learned, CMMI acknowledged the need to streamline programs given that many stakeholders participate in diverse models. Collectively, the CMS and CMMI announcements—and the need of the public and private sectors to execute at scale—may prove a powerful common lever as health equity strategy evolves.

As Brooks-LaSure adds: "We can't achieve our health system goals until everyone can attain the highest level of health."