Comments & Letters

WASHINGTON, DC (November 17, 2023) – Aligning for Health, a leading advocacy coalition focused on improving health through improved coordination of services addressing health and social needs, applauds the White House for publishing the first ever U.S. Playbook to Address Social Determinants of Health. Aligning for Health has long advocated for a comprehensive national plan to address the social determinants of health, through both its engagement with the Administration and bipartisan legislation in Congress — and the playbook represents important progress toward this goal.

Aligning for Health appreciated the opportunity to work with the Administration in developing this pivotal shift in how the U.S. perceives and addresses the nexus of health care and social. We look forward to continuing to support the White House in the implementation of this plan.  Key shared priorities in the plan include (1) enabling appropriate data collection; (2) supporting flexible funding to support health and social need integration; and (3) supporting innovative organizations facilitating this work. The creation of an SDOH Data Working Group, guidance on improving health-related social needs (HRSNs), and integrating supports for underserved populations will advance progress towards better coordinated care and also drive evidence supporting the value of these interventions.

“The release of this Playbook and agency resources is the product of years of work to enhance the efficacy of our health system, improve cost savings for individuals and the federal government, and provide people with the care they deserve,” said Aligning for Health chair Krista Drobac. “We look forward to supporting the Administration to change how we collectively support the health and social needs of Americans at the federal, state, and local level.

Building on this historic announcement, Aligning for Health and RISE will be hosting the White House at the SDOH Policy Forum on December 5 and 6 in Washington, D.C. The conference will also feature bipartisan conversations on how new investments in social needs can increase the government’s return on investment in health and social service programs, as well as improve health outcomes for some of our most vulnerable patients.

Click here for our press release.

Aligning for Health submitted comments in response CMS’s recently proposed rule from CMS to add a Social Determinants of Health (SDOH) Risk Assessment to Medicare’s Annual Wellness Visit (AWV), which acts as a no-cost annual physician exam for beneficiaries. Pending the outcome of the SDOH Risk Assessment, CMS is also proposing partnerships with community-based organizations to provide Community Health Integration (CHI) and Principal Illness Navigation (PIN) services to beneficiaries.

“Aligning for Health strongly supports the addition of an SDOH Risk Assessment as an optional, additional element of the AWV. Identifying social needs as part of the AWV will allow a practitioner to concurrently evaluate all health and social needs and to work with the beneficiary, consistent with their goals and preferences, to develop a comprehensive plan of care to address any identified needs.”

“Aligning for Health applauds CMS for providing sustainable funding to better connect the health and social services sectors and ensure that funding can flow where the referrals are going to support CHI and PIN services. These investments to connect health care entities and social services organizations can help to reimburse CHWs and CBOs for their time and resources and understand the true cost of, and where such organizations are successful in, addressing basic needs.”

To read our comments, click here or see below:

On March 20, 2023, Aligning for Health submitted comments in response to the Senate HELP Committee Request for Information on the drivers of the current health care workforce shortage. The Committee is seeking feedback to identify bipartisan solutions to remedy the nation’s health care workforce shortages and develop these ideas into legislation.

Identifying and addressing social needs and alleviating the impacts of social determinants of health is critical to improving health outcomes and reducing disparities. Clinicians play a critical role in identifying and helping to develop care plans and make referrals to address social needs. However, clinicians need support in integrating screenings and referrals into workflows without adding burden, and in building relationships and partnerships with critical community connectors that are best suited to assist patients in meeting their social needs.

In our comments, we urge Congress to consider the vital role of community-based providers and entities in bridging gaps in the health care workforce and providing necessary services to address health-related social needs at the community level. Specifically, we provide recommendations around leveraging community health workers to support and enable care in communities, considerations for eligibility and enrollment supports for social safety net programs, and bolstering support for community-based organizations to address the health and social needs of communities.

To read our comments, click here or see below:

Aligning for Health submitted comments in response to the Request for Information regarding Accelerating the Adoption of Standards Related to Social Risk Factor Data within the recently proposed rule from CMS to advance interoperability and improve prior authorization processes. Through this RFI, CMS sought input on barriers to using industry standards and opportunities to accelerate the adoption of data collection standards related to social risk factor data, including exchange of information with community-based organizations.

Aligning for Health appreciates CMS’ continued efforts and commitment to ensuring providers and payers participating in federal health care programs can better understand and coordinate to address individuals’ health and social needs.

We applaud CMS and other federal partners’ focus on social risk factors and in identifying policies to address systemic drivers of health. We focus our comments on the importance of encouraging greater identification, documentation, and exchange of social risk and social needs data by removing barriers and by providing education and incentives for providers and payers. Beyond this, we encourage CMS to also expand incentives and ensure supports are in place for entities to provide access to and make referrals to available resources and to address identified social needs, as appropriate.

To read our comments, click here or see below:

Aligning for Health submitted comments in response to the CMS “Make Your Voice Heard: Promoting Efficiency and Equity Within CMS Programs” Request for Information (RFI).

Through this RFI, CMS is seeking to better understand individual and community-level burdens, health-related social needs, and opportunities for improvement that can reduce disparities and promote efficiency and innovation across our programs. CMS requested information related to strategies that successfully address drivers of health inequities, including opportunities to address social determinants of health and challenges underserved communities face in accessing comprehensive, quality care.

Aligning for Health supports many of the steps that the Biden-Harris Administration has taken to prioritize equity for all, including through initiatives to address social determinants of health. Our comments focused on questions posed in the RFI as it pertains to opportunities to better understand and address health-related social needs and to embed health equity into all CMS efforts, to include:

• The need for coordination across sectors to reduce siloes and and better coordinate health care and social services;
• Identifying and addressing social needs and disparities through improved data collection and standardization, screening for social needs, and assessment for if health-related social needs are being met;
• Addressing data sharing within federal health programs and ensuring community-based organizations have the capacity to assist with connecting individuals to resources to meet their needs; and other areas.

To read our comments, click here or see below:

On August 31, Aligning for Health submitted comments in response to the CMS request for information (RFI) on the Medicare Advantage program.

Aligning for Health supports many of the steps that the Biden-Harris Administration has taken to prioritize equity for all, including through initiatives to address social determinants of health (SDOH). In our response, we provide comments to the specific questions posed in the RFI as it pertains to opportunities to address social determinants of health to advance health equity within the Medicare Advantage program.

To view the full letter, click here or see below:

Aligning for Health submitted comments in response to the White House Office of Science and Technology Policy (OSTP) request for information on Strengthening Community Health Through Technology.

Digital health technologies – which the request for information defines as tools that improve health or enable better health care delivery by connecting people with other people, with data or with health information – are critical aspects of successful initiatives to address health and social needs.

As such, Aligning for Health provided feedback on questions related to the tools, training and infrastructure needs of community-based organizations to utilize digital health technologies, and to information about how digital health technologies have or could be used in community-based settings to achieve health equity.

To read our comments, click here or see below:

Aligning for Health submitted comments to the Healthy Future Task Force, Security Subcommittee on its recent request for information on pandemic preparedness, public health, and supply chains. The goal of the Healthy Future Task Force is to build on Republican health policy goals and craft patient-focused agendas for the future.

Specifically, Aligning for Health commented on questions related to addressing social determinants of health and maternal health as part of a broader public health strategy.

Generally, our comments fall into several themes –

• Reduce silos between existing efforts funded by governments and encourage more collaboration.
• Improve the screening and collection of social needs data to improve interventions and evaluate outcomes.
• Enhance coordination between government and non-government organizations working to address social needs through shared regional networks that support coordination, information sharing and referrals.

To read our comments, click here or see below:

Aligning for Health submitted comments in response to the proposal for Improving Experiences for Dually Eligible Individuals: Standardizing Housing, Food Insecurity, and Transportation Questions on Health Risk Assessments (§ 422.101) within the CMS Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs.

Aligning for Health supports CMS’ proposal to require Special Needs Plans (SNPs) to include one or more standardized questions on the topics of housing stability, food insecurity, and access to transportation as part of Health Risk Assessments. We believe that these questions will help SNPs gather the necessary information to inform the development and implementation of each enrollee’s comprehensive individualized plan of care. Further, information from social needs screenings should be used to connect enrollees to covered services or resources to help meet their needs, if consistent with the enrollee’s goals and preferences.

To read the letter, click here or see below:

Aligning for Health submitted comments in response to the CMS Advance Notice of Methodological Changes for CY2023 for Medicare Advantage Capitation Rates and Part C and Part D Payment Policies.

Aligning for Health was pleased to see CMS propose the following potential new measure concepts and methodological enhancements for future years in the Advance Notice and provided recommendations for CMS to consider in developing these concepts:

• Measure of Contracts’ Assessment of Beneficiary Needs (Part C), which would be developed by CMS and would assess whether a contract’s enrollees have had their health-related social needs assessed, using a standardized screening tool; and
• Screening and Referral to Services for Social Needs (Part C), which is being developed by NCQA and would assess screening for unmet needs and referral to intervention for those who screened positive.

To read the letter, click here or see below:

Aligning for Health submitted a letter of support to Reps. G.K. Butterfield (D-NC) and John Joyce (R-PA) for their bipartisan bill, the Care That’s Fair Act of 2021 (H.R. 4554). This bill seeks to empower states to utilize medical claims, clinical, and social data to address racial disparities, social determinants of health, and maternal and infant mortality.

The Care That’s Fair Act will provide states with the necessary resources to effectively measure Medicaid health care outcomes to better address critical health care needs for beneficiaries. As maternal mortality rates rise higher than most developed countries and disproportionately impact minority populations, our obesity rates continue to grow, and the proportion of Americans reporting fair or poor health continues to expand, this legislation comes at an important time. Aligning for Health agrees that empowering states to harness essential Medicaid claims and clinical data will help identify where social determinants and health disparities exist, which can then be leveraged into action to address these disparities at their root cause.

To read the full letter, click here.

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.

On Thursday, June 24, the House Energy & Commerce Committee, Health Subcommittee held a landmark legislative hearing entitled “Empowered By Data: Legislation to Advance Equity and Public Health.” The hearing featured 13 bills to advance health equity and public health, including the Social Determinants Accelerator Act of 2021 (H.R. 2503).

Today, Aligning for Health sent a letter to the leaders of the House Energy & Commerce Committee and Health Subcommittee, thanking them for their leadership in holding this hearing to discuss and consider important legislation related to social determinants of health.

As a coalition committed to improving health and wellbeing by addressing individual and community social needs, Aligning for Health also expressed support for the forward momentum towards passage of the Social Determinants Accelerator Act of 2021. Included in the letter is an updated endorsement list – which now totals well over 100 leading health and social services organizations who actively support passage of the legislation.

Aligning for Health urged the Subcommittee to consider and advance this important piece of legislation, which will empower communities across the country to work across sectors to share data, leverage available resources, foster partnerships, and coordinate care to drive improved and equitable outcomes.

To read the full letter, click here.

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If your organization would like to add its name to the full list of organizations supporting this bill, click here. A recording of the hearing can be found here, and a summary of the hearing can be found here. Aligning for Health also submitted a Statement for the Record, which can be found here.

Aligning for Health submitted comments to Senator Lamar Alexander’s call for ideas on how to make the health care system more resilient. Our response is featured below:

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