Health Equity Emphasized in the 2022 Medicare Advantage Readiness Checklist: Are You Ready?

It’s easy to forget that sweeping industry changes don’t always come with flashy headlines and “shock and awe” policy announcements. (Want proof? Just think about self-driving cars, which arrived after many, many years of small enhancements and refinements that built upon each other—until VOILA! The self-driving car came to market!)

We’ve known and talked for years about the need to get better, smarter, and more focused on truly improving health equity. The truth is, it’s a really tough nut to crack—and one that short meetings, email dialogues, and one-off “quick projects” are simply inadequate to solve.

Regulatory push for improved health equity from Medicare Advantage plans in 2022

By escalating information regarding “alignment with Executive Order 13985” to page 1 of the 2022 CMS Medicare Advantage Readiness Checklist, the Biden administration very emphatically and clearly reminds us that advancing racial equity and supporting underserved communities is a key priority in the coming years. This comes despite the unfortunate reality that most Medicare Advantage (MA) plans only know the race and ethnicity of ~50% of their members.

With most of the low-hanging fruit long gone, improving clinical quality, health outcomes, and member experience to improve Star Ratings will undoubtedly require change. MA plans need to get more serious about understanding, diagnosing, and actually solving for the problems faced by the underserved, often under-resourced, and almost always “under-accessed” communities in their service area.

And as NCQA phases race and ethnicity stratification into HEDIS® quality measurements—and is formally encouraging federal action to improve data collection—the framework for transparency, accountability, and ultimately compliance is evolving and providing a stronger directive for this focus.

How can MA plans prepare for prioritizing health equity?

Because CMS can request policies and procedures evidencing a plan’s readiness with all major areas in the Readiness Checklist at any time, here are a few ways you can make sure you are ready:

• Ensure your analytics, processes, policies and procedures, and Stars/quality projects adequately prevent, detect, and correct disparities in sensitive topics such as gender identity, race, disability, literacy, ethnicity, and language preferences. Confirm that your plan’s approach is well-documented, being followed by your vendors and FDRs, and will stand up to a CMS audit.
• Increase efforts to resolve longstanding information gaps regarding race and ethnicity data by adding data collection efforts to all member interactions in alignment with NCQA standards.
• Leverage Star measure accountability as the foundation for transparency and accountability to both identify and remedy performance disparities in clinical areas and/or issues CMS has defined as the most important to our shared pursuit of the Triple Aim.
• Incorporate HR, Community Relations, and Compliance teams into health equity improvement efforts to help staff get and stay comfortable discussing sensitive topics, as well as secure and improve meaningful connections with providers and local partners to support these efforts. Most employees shy away from these issues not because they don’t want to address them, but because they are often unsure what words to use and/or how to frame discussions in a way that is both legal and interpersonally comfortable. This is an area where “continuing education” truly never ends and where success will truly take a village.

With these initiatives in place, you’ll be ready for a fulfilling 2022 as we #MakeHealthEquityReal in MA! Our team has extensive experience assessing and improving health equity within Star Ratings and quality programs. If you need help, email me at melissa.smith@healthmine.com for more information.