CMMI: Data Critical to Developing Health Equity Quality Measures for Hospices in Value-Based Payment

Patient data collection is critical in how the U.S. Centers for Medicare & Medicaid Services (CMS) is developing health equity quality measures for hospices in value-based payment.

The Center for Medicare & Medicaid Innovation (CMMI) in 2022 announced a “strategy refresh” that included a renewed focus on health care equity in payment model design. Among other objectives, the strategy’s pillars included a focus on diversity, equity and inclusion.

One year after its launch, the agency has indicated that increased data collection and analysis will be crucial to evaluating health equity impacts and defining quality measures in future payment models.


“Collecting and analyzing data to monitor and evaluate CMS Innovation Center models is critical, and evaluation findings inform future model design,” the agency recently reported in the journal Health Affairs. “CMS relies upon data imputation to estimate beneficiaries’ demographic backgrounds and uses data proxies, such as dual eligibility for Medicare and Medicaid, to measure ‘underservedness.’ At the population level, these can be useful short-term approaches until we have sufficient self-reported ‘gold standard’ data that can support more robust analyses, including individual beneficiary-level analyses.”

CMMI’s strategy refresh was built on pillars such as aligning more patients with accountable care entities; integrated, person-centered care; health care affordability; and development of partnerships to achieve these aims.

Two models working to bridge health disparity gaps in hospice include the Medicare Advantage value-based insurance design (VBID) demonstration model and the Accountable Care Organization Realizing Equity, Access, and Community Health (ACO REACH) model.


Collecting and monitoring demographic patient data is an important piece of understanding the impacts of hospice providers’ diversity, equity and inclusion efforts within value-based payment, as well as other reimbursement systems, according to CMMI.

For instance, some changes are in flux for hospice providers participating in the VBID model. Beginning in July 2023, CMS will begin to collect detailed information from participating VBID plans about the supplemental benefits provided such as food, transportation and housing assistance.

Additionally, hospices participating in VBID are required to develop and submit health equity plans that both adequately define disparities among underserved populations and identify interventions around their unmet needs, the agency stipulated.

The data collection is an effort to “assess their use and effectiveness in improving care and outcomes,” CMMI indicated.

“Over time, such data will help enable us to better stratify and evaluate model outcomes for beneficiary populations defined by factors such as race, ethnicity, gender, geography, disability, sexual orientation, and gender identity,” CMMI stated.

In ACO REACH, for example, participating organizations are required to collect socio-demographic and health-related social needs data. The data can be instrumental in developing “leading indicators” within payment models that help pinpoint where the largest portions of underserved populations exist in a specific geographic area, the agency said.

Gathering this demographic data can be a challenge for some ACOs that lack organization-wide electronic health record systems, the agency indicated. As a result, CMMI is piloting payment mechanisms that will help facilitate data collection from ACO REACH participants by minimizing administrative burdens involved in claim reporting.

“These mechanisms represent both high-tech and low-tech solutions, ranging from data extraction from electronic medical records to manual data entry and submission of Excel files,” CMMI stated.

The rest of its health equity payment initiatives include a focus on addressing social determinants of health and psychosocial needs and increasing access to care for disabled and rural communities, among others.

CMMI has developed guidance for optimizing referral components involved in health screenings that address patients’ health-related social needs. Additionally, the agency is developing recommendations for measuring quality among underserved populations, particularly with regard to culturally competent care.

The agency is testing out the effectiveness of an implicit bias tool aimed at helping hospice providers identify and understand where areas of inequity might exist in their care delivery and organizational practices. If finalized, the tool could be embedded into future payment models, CMMI indicated.

The agency also indicated that some “exploratory work” is underway to develop new payment models and initiatives that will help identify priorities and opportunities to better support people with disabilities.

It is also exploring more options to better support providers facing financial pressures in rural communities that are impacting access and utilization to end-of-life care.

“Our equity ‘to-do’ list is ambitious but necessary if we are to ensure that our long-term transformational work equitably benefits all beneficiaries we serve,” the agency indicated in the report. “[CMMI] will continue to lead efforts that drive meaningful progress in advancing health equity today and in the years to come.”

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