Policy
NASDOH's Recent Policy Activity

On this page, we share NASDOH’s policy engagements with the most recent activity summarized first. For information on recent federal efforts to address SDOH we are aware of, see HHS SDOH policy activity  and federal COVID-19 funding and flexibilities for SDOH-related programs.

NASDOH Sends Comments to the White House to Inform its National Strategy for Addressing Hunger, Nutrition, and Health.

Ahead of the September 2022 White House Conference on Hunger, Nutrition, and Health, NASDOH offered ideas based on members’ experiences providing services to address people’s social needs and SDOH as they relate to hunger, nutrition, and health. See NASDOH’s full comment letter here.

NASDOH Submits Comments on the (FY) 2023 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long‑Term Care Hospital (LTCH) Prospective Payment System (PPS) proposed rule.

NASDOH offered comments specifically on the Hospital Commitment to Health Equity measure, Screening for Social Drivers of Health measures, and two requests for information on reporting of SDOH diagnosis codes and using measurement and stratification tools to address health equity. See the full comments here.

 

NASDOH Sends CMS a Set of Proposed Principles for Developing a Learning Collaborative around Addressing Social Needs in Medicaid

NASDOH sent the set of proposed principles for addressing social needs and SDOH in future CMMI payment models to CMMI Director Dr. Dora Hughes. In the principles, NASDOH notes CMMI’s recent strategy refresh focusing on health equity and emphasizes that screening for and referring or providing services to beneficiaries with health-related social needs is a vital component of addressing equity. Therefore, NASDOH asserts that social needs considerations should be incorporated into all future CMMI payment models and offers principles for CMMI to consider.

NASDOH Submits Comments to the 2022 Request for Information (RFI) On Access to Care and Coverage in Medicaid and CHIP.

In the RFI response, NASDOH offered comments to CMS Administrator Chiquita Brooks LaSure underscoring that the RFI can inform a comprehensive access strategy for Medicaid and CHIP. NASDOH focused its response on five key questions in the RFI, which align with NASDOH’s previous recommendations on addressing social needs in the Medicaid program. NASDOH commented on access and eligibility requirements in Medicaid, care coordination and covering social care in Medicaid, and assessment of payment policies through the development of a Medicaid learning collaborative. See the full response here.

NASDOH Submits Comments on SDOH-related Provisions in the CMS Proposed Rule on Medicare Advantage and Medicare Part D plans for calendar year (CY) 2023.

NASDOH focused our comments on SDOH-related provisions, including the proposal to require all SNPs to include one or more standardized questions on the topics of housing stability, food security, and access to transportation as part of their health risk assessments (HRAs). See the full NASDOH letter here.

NASDOH Comments on the White House OSTP RFI on Strengthening Community Health through Digital Technologies.

NASDOH submitted comments to the White House Office of Science and Technology Policy (OSTP) request for information (RFI) on Strengthening Community Health through Technology. In the letter, NASDOH offered comments on the “digital health technologies” terminology, underscoring the importance of qualitative and quantitative data as well as data generated by the community. With examples from members, NASDOH outlined successful models of community health providers using digital health technology, raised barriers faced by organizations in community-based settings; and, reviewed trends in digital health technology use from the pandemic. See NASDOH’s comment letter here.

NASDOH Sends Comments on the Draft PREVENT Pandemics Act.

NASDOH wrote to Senator Murray (D-WA), Chair of the Senate HELP Committee, and Senator Burr (R-NC), Ranking Member of the Senate HELP Committee, offering comments on the draft legislation Prepare for and Response to Existing Viruses, Emerging New Threats, and Pandemics Act (PREVENT Pandemics Act). In the letter, NASDOH underscores the importance of addressing SDOH as part of preparing for and responding to future emergencies and comments on specific provisions related to SDOH. Check out the full letter here.

NASDOH Sends a Letter to the White House, HHS, CDC, and ONC Requesting Guidance on Modernizing Public Health Data Systems.

In the January 2022 letter, NASDOH urges HHS to issue guidance to states outlining how public health entities should modernize their data systems in light of lessons learned during the COVID-19 pandemic. Check out the full letter here.

NASDOH Responds to ASPE’s Report on “Building the Evidence Base for Social Determinants of Health Interventions”

In the 2021 letter, NASDOH offers support for the findings as well as the recommendations for potential HHS actions that can help build the overall evidence base for SDOH and follows with a set of recommended areas for emphasis. See the full response here.

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 Comments on Congressional SDOH Caucus Request for Information (RFI)

(2021)

NASDOH applauds Representative Cheri Bustos (D-IL), Representative Tom Cole (R-OK), Representative G.K. Butterfield (D-NC), and Representative Markwayne Mullin (R-OK) for launching the Congressional Social Determinants of Health (SDOH) Caucus in 2021 to explore opportunities to improve the impact of efforts to address SDOH with federal support. In the letter, NASDOH offers eight recommendations to the Congressional SDOH Caucus, outlines areas of opportunity for the caucus to promote a coordinated federal approach to investment in SDOH, reviews several SDOH-related legislative proposals that NASDOH supports, and details several NASDOH members’ examples of engaging in SDOH programs on the ground. Please see the full response here.

NASDOH Sends a Letter of Support to the Founding Members of the Congressional SDOH Caucus

NASDOH thanks Representatives Bustos, Cole, Butterfield, and Mullin for launching the Congressional Social Determinants of Health (SDOH) Caucus to explore opportunities to improve the impact of efforts to address SDOH with federal support.  NASDOH appreciates their leadership in bringing together members of Congress to coordinate across SDOH-related jurisdictions in order to improve health outcomes and optimize federal funding. Read the July, 2021 letter here.

NASDOH Sends a Letter in Support of the Black Maternal Health Momnibus Act of 2021 

NASDOH supports a package of bills intended to improve Black maternal health outcomes, including bills S.346 / H.R.959 – The Black Maternal Health Momnibus Act of 2021, which would direct multi-agency efforts to improve maternal health, particularly among racial and ethnic minority groups, veterans, and other vulnerable populations, and address issues of maternal health related to the COVID-19 pandemic. Read the July, 2021 letter here.

NASDOH Issues Letters of Support for SDOH-focused Legislation:

H.R. 379 and S. 104 – The Improving Social Determinants Act of 2021

Introduced by Rep. Nanette Diaz-Barragán (D-CA) and Senator Tina Smith (D-MN) 

NASDOH supports The Improving Social Determinants Act of 2021. The bill would authorize $50 million for CDC’s SDOH activities, including grants to state, local, territorial and tribal health agencies and organizations to address SDOH in target communities; grants to nonprofits and institutions of higher education to conduct research and provide technical assistance; data collection and analysis; and federal coordination.

H.R. 2503 – The Social Determinants Accelerator Act of 2021

Introduced by Reps. Cheri Bustos (D-IL), Jim McGovern (D-MA), Rom Cole (R-OK), Markwayne Mullin (R-OK)

NASDOH supports The Social Determinants Accelerator Act of 2021. The bill would direct the Secretary of HHS to establish an interagency council on social determinants of health and make $25 million available to state, local, and tribal governments to develop plans to target social determinants that are negatively impacting high need patients.

S. 509 – Leveraging Integrated Networks in Communities (LINC) to Address Social Needs Act of 2021

Introduced by Senators Dan Sullivan (R-AK) and Chris Murphy (D-CT)

NASDOH supports Leveraging Integrated Networks in Communities (LINC) to Address Social Needs Act of 2021. The bill would authorize $150 million to HHS to award competitive grants to States (working through public-private partnerships) to establish or enhance technology platforms to refer and connect people to food, housing, child development, job training, and transportation supports and services.

S. 674 – Public Health Infrastructure Saves Lives Act (PHISLA)

Introduced by Senator Patty Murray (D-WA)

NASDOH supports Public Health Infrastructure Saves Lives Act (PHISLA). The bill would establish a new core public health infrastructure program, specifically providing $4.5 billion in annual funding to bolster the nation’s efforts to fight the COVID-19 pandemic and strengthen its ability to respond to other public health challenges going forward.

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 Sends a Letter to Encourage Appropriated Federal Funding to Address SDOH and Support Multisector Partnerships

(2021)

In our 2021 letter to Ambassador Susan Rice (Director, Domestic Policy Council), Secretary Xavier Becerra, (U.S. Department of Health & Human Services), and Mr. Gene Sperling (American Rescue Plan Coordinator), NASDOH encouraged the federal government to take proactive steps to ensure that federal funding, such as that appropriated in the American Rescue Plan Act (ARPA) and other new funding initiatives, is prioritized toward long-term investment in public health, social determinants of health (SDOH), and equity. We included 5 recommendations and highlighted the opportunity to use funding to support multi-sector partnerships to advance SDOH.

NASDOH Comments on OMB Request for Information (RFI) on Advancing Equity for Underserved Communities

(2021)

NASDOH believes this RFI can yield important input into how federal policies and actions can equitably serve all eligible individuals and communities. Achieving equity and addressing adverse social determinants of health are interconnected aims, and we offer our perspective on how these goals can be accomplished through the administration of federal programs. Read the July, 2021 letter here.

NASDOH’s comments on the NPRM on modifying HIPAA Rules to Improve Coordinated Care

(2021)

NASDOH appreciates 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 and other third-party agencies that provide health-related services.

Please see here for NASDOH’s letter to HHS with recommendations on questions posed in the proposed rule related to adding a new subsection 164.506(c)(6) which would expressly permit covered entities to disclose PHI without obtaining a valid authorization from the individual to social service agencies, community-based organizations, HCBS providers, and other similar third parties that provide health-related services to specific individuals for individual-level care coordination and case management.

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 .