CMS Releases New Measures to Address Social Determinants of Health

By KAITLIN A. NUCCI
On January 7, 2020, CMS published a State Health Official letter to provide guidance in the adoption of policies to address social determinants of health in both Medicaid and Children’s Health Insurance Program (CHIP). The reasoning behind such strategy stems from the fact that even though the United States spends more money than almost any other country in the world on healthcare, the United States is often is outperformed on key health indicators such as life expectancy, reducing chronic heart disease, and maternal and infant mortality rates. This is due to a range of social, environmental and economic factors that have major influences on health, sometimes even more influence than the delivery of healthcare services.

This letter provides the guidance needed for states to use existing flexibilities under federal law and regulations to address social determinants of health and the adverse outcomes that are often associated with these factors. States are encouraged to enact programs and/or provide benefits that can in the long term reduce the cost of caring for high-risk populations.

Through this guidance, CMS acknowledges that social determinants of health, such as access to nutritious food, accessible housing, education, and meaningful employment, can play an integral role in an individual’s health. By spending money on providing access to the necessities of daily living, the Medicaid and CHIP programs will be able to save money in the long term and properly address health disparities for a broad range of populations, including individuals with disabilities, pregnant and postpartum women, children and youth, individuals with mental or substance abuse disorders, individuals living with HIV/AIDS, individuals living in rural communities, individuals experiencing homelessness, individuals from racial or ethnic minority populations, and individuals with limited English proficiency.

The social determinants of health affect utilization, health outcomes and disparities. The COVID-19 pandemic has demonstrated these issues, as counties with high poverty rates and crowded housing units were more likely to become hotpots for the virus. This means those facing income and housing insecurity were more at risk of contracting the virus. Even more, with schools moving online, children from low-income families were stripped of their access to school-provided food assistance, counselling services, and much more.

This letter explains that, under federal law, states have the opportunity to design ways to cover services to address the social determinants of health within a variety of categories, including housing-related services and supports, non-medical transportation, home-delivered meals, educational services, employment, community integration and social support, and case management. The letter provides an in-depth description of what services fall into these categories and how states can provide these services while still following parameters set by law. Importantly, these services must be for the benefit of Medicaid-eligible individuals only, and not for general utility.

Because of the statutory and regulatory requirements already in place, the Medicaid and CHIP programs, which cover over 76 million low-income Americans, are uniquely positioned to address social determinants of health, and simultaneously commit to increasing both health incomes and the cost-effectiveness of health care services for Medicaid and CHIP beneficiaries. CMS has stated that it is committed to addressing social determinants of health across all of its programs.

For additional information or assistance regarding the information in this article, or any other health professional issue, contact Kaitlin A. Nucci, Esq., at Wachler & Associates at (248) 544-0888.