Aligning for Health submitted comments and recommendations in response to the Request for Information (RFI) published by the White House Office of Management and Budget (OMB), entitled “Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government.”

The purpose of this RFI was to seek input from a broad array of stakeholders on available methods, approaches, and tools that could assist OMB in identifying effective methods for assessing whether agency policies and actions equitably serve all eligible individuals and communities, particularly those that are currently and historically underserved. Aligning for Health was pleased to provide comment in response to several of the questions posed in the RFI, highlighted below:

Equity Assessments and Strategies

As OMB notes in the Request for Information, advancing equity will require federal agencies to implement new approaches to assess whether policy and programs are effective in advancing equity. As part of this effort, we believe that it is important for agencies such as the Centers for Medicare and Medicaid Services (CMS), within the U.S. Department of Health and Human Services (HHS), to improve the collection and reporting of standardized social needs data and encourage cross-sector coordination and data sharing across organizations in the health and social service sectors.

Comprehensively documenting social risk and social needs data and promoting greater exchange of such data will ensure payers and providers delivering health and non-health care to individuals have a more comprehensive view of the factors affecting an individuals’ wellbeing as well as the disparities contributing to health inequities. However, collecting social needs and risk factor data has proven to be a continuous challenge. Such data is not always routinely or systematically collected across the health care system and often is not collected in a standardized way, making it difficult to integrate into health records, to share across coordinated entities, or to use for purposes of risk adjustment.

Aligning for Health recommends OMB work with the HHS, and CMS, to encourage and incentivize greater identification, documentation, and exchange of social risk and social needs data across its programs by removing barriers and by providing education and incentives.

Moreover, the siloed way in which health care, public health, and social services are paid for and administered has limited cross-sector coordination and data sharing across organizations in the health and social service sectors. Breaking down the siloes and incentivizing connectivity and coordination between programs and systems will help to ensure that they are most effective in improving health and wellbeing. Statewide or regional efforts to connect health care organizations and CBOs for purposes of electronic referrals, outcomes tracking, electronic resource directories, and care coordination help to bridge some of these gaps.

Aligning for Health recommends OMB work with HHS to continue to promote, and with Congress to catalyze, further development of such statewide or regional, integrated networks.

Barrier and Burden Reduction

Improving coordination of federal programs and services is critical to removing certain barriers faced by individuals in accessing needed benefits and services. States, local governments, health care providers, payers, social services providers, community-based organizations (CBOs), and others are increasingly seeking to partner to better coordinate care and services.

However, one of the greatest challenges to high-impact interventions is the difficulty in navigating and coordinating fragmented and complex programs aimed at addressing health care needs, food insecurity, housing instability, workforce supports, and transportation reliability, among others. In particular, the siloed funding, data systems, and administration of many of these programs at the state and local, and nongovernmental levels create barriers to effective coordination and partnership.

Aligning for Health recommends OMB work with agencies to create, to the extent possible under current law, opportunities for states and local governments to develop strategies to improve cross-sector coordination of programs and services. Additionally, we support the President’s fiscal year 2022 funding request to increase funding for the CDC’s Social Determinants of Health program from $3 million to $153 million. Finally, we encourage OMB to consider advancing policies and strategies that would help to coordinate eligibility and enrollment processes for cross-sector programs.

Procurement and Contracting

OMB’s Request for Information notes that federal agencies should assess opportunities to invest in underserved individuals and communities, including by promoting business diversity and resiliency and by providing opportunities for underserved individuals and communities. As federal, state and local government agencies continue to invest in cross-sector strategies to address both health and social needs of individuals and to advance equity, many have sought to leverage blending and braiding of program and operational funding.

Aligning for Health supports additional flexibility for braiding and blending of programmatic funding, where appropriate, to support innovative, integrated program designs. Moreover, it is important for federal agencies to consider ways to ensure that downstream uses of federal funding maximize competitive contracting or participation opportunities for underserved communities, or business and entities representing underserved populations.

To read the full comment letter, click here.