BMA in the News
June 12, 2019

Advocates Ask For Social Determinants Support, EHR Restructuring

Beneficiary advocates called on CMS to provide more support for plans to tackle social determinants of health, including information on funding streams and support for community partners in working with Medicare Advantage plans to provide services, with one group saying that harmonizing social determinants data with electronic health records remains a challenge.

Allyson Schwartz, CEO and president of the Better Medicare Alliance and former member of the U.S. House of Representatives, praised new supplemental benefits available to MA plans during an Alliance for Health Policy event Tuesday (June 11). She said plans are now better positioned to tailor benefits to tackle social determinants of health.

The final 2020 MA and Part D call letter allows MA plans to offer new supplement benefits for the chronically ill. That new policy follows the previous year’s call letter, which allowed MA plans to offer limited supplemental benefits. The Bipartisan Budget Act of 2018 loosened uniformity requirements, allowing MA plans to vary benefits based on the individual enrollee’s needs as well as allowing plans to offer non-primarily health-related supplemental benefits to chronically ill enrollees in 2020. In May, CMS clarified that these new benefits may tackle social determinants of health, but social determinants may not the sole reason for determining a benefit.

The final call letter also contained guidance to plans on contracting with community-based organizations to provide supplemental benefits.

Schwartz called on the federal government to create an office specifically for coordinating Medicare and Medicaid plans to tackle social determinants of health. She also said that once new supplemental benefits for MA plans get underway, CMS should evaluate best practices by plans on how to work with community partners.

She also said community organizations would benefit from guidance from CMS on how to negotiate contracts with insurance plans and suggested that the CMS innovation lab could help.

Schwartz also told lobbyists to inform members of Congress about evidence of good health outcomes achieved through tackling social determinants. “Is it helping [patients] manage their condition and live healthier lives?” she asked, adding that this is a question lobbyists should answer when bringing their concerns to members.

Dora Hughes, associate research professor at George Washington University, also called on CMS to clarify how social determinants could be paid for.

Providers and plans earlier this month asked CMS for funding to tackle social determinants of health within a new Center for Medicare & Medicaid Innovation primary care demo for Medicare fee-for-service beneficiaries. The groups said that while they support tackling social determinants, finding the funding to do so is an obstacle. They asked for a direct funding stream from CMS.

CMS was unable to offer an answer by press time on whether the agency plans to offer guidance to community-based organizations on how to contract with health plans, or whether CMS will provide guidance on funding streams or highlight best practices to tackling social determinants.

Jamo Rubin, founder and chief executive officer of TAVHealth, called for a structural change to electronic health records to assist with tackling social determinants of health. He said one challenge is finding places to store data on social needs. He said electronic health records do not have places to record that kind of data even though a vast amount of data on social needs exists.

“If somebody is hungry and you feed them, that’s a data point,” he said. However, Shantanu Agrawal, president and chief executive officer of the National Quality Forum, noted that restructuring electronic health records would be costly. He also said providers may not be aware of the questions to ask to gather data on social needs.

In a Health Affairs blog post in March, Douglas Olson, Benjamin Oldfield and Sofia Morales Navarro said that harmonizing documentation of social determinants of health data is critical to tackling them. Olson, Oldfield and Navarro cited three specific barriers hindering health care institutions from focusing more on social determinants: a lack of standardized screening tools in EHRs, an overreliance on clinical providers to screen for social determinants, and a lack of standardized health codes between social determinants and diagnostic codes for documentation.

The authors offered their own code, but called on CMS, community health centers, CMMI, payers and others “already providing leadership in this space” to offer guidance on aligning code implementation with alternative payment methodologies. — Chelsea Cirruzzo (

Sign Up for Policy Alerts

Sign up to receive exclusive updates on Medicare Advantage policy.