Last year, the Centers for Medicare and Medicaid Services (CMS) released several rules to address Social Determinates of Health (SDOH) and we are seeing a similar focus this year, with several proposals included in the proposed payment rules released so far. Here’s what we have seen so far in the proposed rules addressing housing, SDOH screening standardization, and the environment.

Housing

In May 2023, the Biden Administration announced an inter-agency initiative to begin looking at ways to address homelessness and study the effects of housing stability on health. CMS is proposing, as part of the Inpatient Prospective Payment System (IPPS) proposed rule, to increase the severity designation of seven ICD-10 diagnosis codes describing inadequate housing and housing instability from “non-complication or comorbidity” to “complication or comorbidity.” Increasing the severity designation of a code generally results in higher reimbursement to reflect the increased costs hospitals face when caring for these patients.

Environment

Within IPPS, CMS is proposing a new mandatory payment model, which would have a voluntary Decarbonization and Resilience Initiative. The initiative marks the first time HHS proposes to collect data on health care greenhouse gas emissions and is meant to align with the HHS Health Sector Climate Pledge, which encourages health systems to cut their emissions by 50% by 2030 with the ultimate goal of net zero by 2050.

Standardizing SDOH Screening

Currently, CMS requires hospitals to screen patients on the domains below but does not require the use of specific questions or screening tools. CMS wants to standardize the reporting of SDOH screening data across the various payment systems’ quality reporting programs. To do that, the Agency is proposing in several rules (i.e. the Acute Inpatient, Inpatient Rehabilitation, and the Inpatient Psychiatric Prospective Payment Systems) for providers to use uniform screening questions included in the Accountable Health Communities HRSN Screening tool. Below are the specific proposals for each domain.

  • Living Situation: CMS believes information gathered from asking patients, “What is your living situation?” would help LTCH facilities in discharge planning and care transitioning.
  • Food Security: Patients would be asked about their food security over the past 12 months to help facilities identify patients who would be eligible for Supplemental Nutrition Assistance Program (SNAP) benefits.
  • Utilities: Patients would be asked if their utility companies threatened to shut off their utilities to help identify potential candidates for assistance programs such as the Low-Income Home Energy Assistance Program.
  • Transportation: Patients would be asked whether a lack of reliable transportation has inhibited their ability to access health care, or otherwise negatively impacted their day-to-day lives. LTCH facilities were first required to report this HRSN data beginning in 2022, but CMS is proposing to modify this measure so as to align with measures in other quality reporting programs.