Monday, March 30, 2020

You’re Doing It Wrong: What Changes In Medicaid And SNAP Reveal About The Trump Administration’s Investment In The Social Determinants Of Health

The Department of Health and Human Services (HHS) defines the social determinants of health as the “conditions in the environments in which people are born, live, learn, work, play, worship, and age that affect a wide range of health, functioning, and quality-of-life outcomes and risks.” The concept, which comes from the global public health field, is at its best when it is understood to encompass an individual’s social location—their race, ethnicity, sex, class, ability, orientation, culture, and how each of these identities impact them in their community context. It was created to identify and serve the most vulnerable among the world’s populations and to address the inequities that disproportionately impact their lives and their health. 
In step with the growing popularization of the term in US health policy, Trump administration health officials have frequently espoused a commitment to more fully address social determinants of health within federal health coverage programs. In execution, however, they have done so inequitably, seeking simultaneously to shrink and weaken health and safety-net programs that are best positioned to provide social determinant-related services to the beneficiaries who need them most. 
Select Progress On Social Determinants of Health 
Top HHS officials have spoken at length on efforts to better address beneficiaries’ social determinants of health. And, on the face of it, the Trump administration has made select progress on advancing these goals under limited demonstrations and for segments of enrollees under certain programs, which we outline below. 
Demonstration Programs
In November 2018, HHS Secretary Alex Azar delivered a speech on America’s social determinants of health, in which he highlighted increased focus on social determinants within demonstration programs run by the Center for Medicare and Medicaid Innovation (Innovation Center) created under the Affordable Care Act (ACA). Since that time, the Innovation Center has rolled out several integrated care models that include features designed to address the physical, behavioral, and social needs of at-risk populations (for example, the Integrated Care for Kids model, the Maternal Opioid Misuse model, and the Primary Care First model options, and so forth). Many of these models build on the progress and momentum achieved under the Innovation Center initiatives of the previous administration, such as the Accountable Health Communities Model
Medicare Advantage
Effective 2020, the Centers for Medicare and Medicaid Services (CMS) is offering new flexibilities for private Medicare Advantage plan sponsors to provide special supplemental benefits for chronically ill enrollees, including benefits “that are not primarily health related” and that may be tailored to enrollees based on individual needs. These new supplemental benefits can include: plan-sponsored housing or subsidies for rent or assisted living; subsidies for gas, electric, and other utilities; home meal delivery or reimbursement for food and fresh produce; transportation for non-medical needs, such as to the grocery store or the bank; social needs benefits, such as fitness club memberships, park passes, counseling, and more. 
Z Code Data
CMS also recently released a report on the largely untapped potential to capture standardized data on Medicare beneficiaries’ social determinants of health through the use of ICD-10 Z codes, which physicians can use to document non-primarily health-related “factors that influence health status and contact with health services.” The report finds that such factors are widely undercounted and recommends that standardized reporting on social determinants could improve clinicians’ abilities to improve beneficiary outcomes and control costs. 
The Broader Picture: Backsliding In Medicaid, SNAP, And The Social Safety Net 
Given the low-income and vulnerable population Medicaid serves, the program’s joint state and federal administration, and the unique flexibilities and authorities granted to states to design their own program features, the program is exceptionally well-positioned to address the social determinants of health. Indeed, many—if not all—states have used the flexible program features over the years in various ways to cover additional vulnerable populations, add additional benefits and services, or test innovative delivery reforms in ways that best serve their residents. 
The Medicaid program ought to be a primary focus of the administration’s aims to improve social determinants, but its Medicaid agenda reveals a distinct disconnect between how such benefits are being afforded to older Americans enrolled in private Medicare plans, for example, and what is afforded to low-income and marginalized communities on Medicaid. Rather than seeking to amplify, facilitate, or accelerate state innovation around the social determinants of health, the Trump administration has instead championed—often in ways that stretch the bounds of its legal authority—Medicaid reforms that increase barriers to care, leave fewer people enrolled, and that will likely strip billions of dollars from state budgets if fully implemented. 
Medicaid Work Requirements 
At the beginning of 2018, CMS issued guidance to states to implement work and “community engagement” requirements for able-bodied (expansion group) adults. Under the first-of-its-kind optional model, beneficiaries continually need to meet and report up to 80 hours of work or community engagement per month, or lose their health coverage entirely. To date, CMS has approved work requirement waivers in 10 states, three of which have been halted by legal challenges, while several other waivers are pending approval. In Arkansas, implementation of these requirements resulted in 18,000 people losing their Medicaid coverage before implementation was paused. 
In her roll-out speech, CMS Administrator Seema Verma invoked the concept of social determinants of health, citing that employment leads to a better quality of life and improved health outcomes. However, the lawsuits that have stopped the programs moving forward rest in part on the grounds that these programs did little to nothing to actually connect people to required employment; and furthermore, that CMS had no metrics nor monitoring requirements in place to determine if employment was acquired or if outcomes improved. 
Medicaid Block Grants 
More recently, we saw the unveiling of another long-sought overhaul to Medicaid. Oft recommended in the president’s congressional budget requests and under the effort to repeal the ACA in 2017, CMS has put forward a new waiver pathway for states to seek a block grant for a portion of their Medicaid population. Under the plan, states could opt to receive a capped federal contribution for any optional coverage group, including the Medicaid expansion population, and to waive certain optional and mandatory benefits and services. Critics of Medicaid block grants point to evidence that they would lead to state budget shortfalls in the face of economic downturns, growing populations, and rising health care costs. Such an arrangement would likely require significant budgetary adjustments that could lead to the scaling back of benefits and services for all enrollees or falling provider reimbursement rates, which ultimately threatens access. 
Medicaid Transportation Benefit 
Where CMS is freeing private plans in Medicare to begin paying for both medical and non-medical transportation, the administration has been “reexamining” Medicaid’s longstanding mandatory program requirement of states to provide non-emergency medical transportation (NEMT) when beneficiaries lack means of accessing medical services. The agency has already permitted several states to waive this requirement for expansion group adults; however, a pending regulatory proposal suggests that they may seek to erode NEMT requirements for a broader group of Medicaid-covered lives. 
Medicaid Financing And Access Monitoring 
Beneath the headline-grabbing optional waiver programs, the administration has also advanced complex rules that will have deep impacts on both expansion and traditional Medicaid eligibility groups in all states. The proposed Medicaid Fiscal Accountability Rule, or MFAR, would significantly alter the rules regarding how states can finance their share of supplemental payments, which typically are paid to hospitals and providers disproportionately serving vulnerable and low-income populations to make up for low Medicaid reimbursement rates. CMS estimated in its proposed rule that the changes could lead to $222 million in lost provider supplemental payments nationwide each year; however, the agency acknowledged that the exact impact of such changes are unknown. Analysis by Manatt Health pegs the cuts to program spending between $37 and $49 billion per year, with impacts likely varying widely from state to state. 
The Medicaid and CHIP Payment and Access Commission (MACPAC) urged CMS not to move forward with the proposed changes before fully assessing the potential impacts, which commissioners fear could reduce payments in ways that would jeopardize access to care for Medicaid enrollees. Of particular note, MACPAC advised that a careful review of the access implications of MFAR is especially important in light of CMS’s separate and prior proposal to rescind the requirement that states evaluate beneficiary access to care before reducing or restructuring Medicaid provider payments. 
SNAP Work Requirements And Other Reforms 
While CMS is encouraging spending on fresh produce and reliable meals for vulnerable beneficiaries in Medicare, the administration is simultaneously seeking numerous cuts and program changes that will impact the 44.2 million low-income people who receive benefits under the Supplemental Nutrition Assistance Program (SNAP), formerly known as food stamps. 
The Department of Agriculture (USDA) has finalized a rule that, if implemented in April 2020, will narrow the criteria by which states may exempt certain SNAP beneficiaries known as able-bodied adults without dependents (ABAWDs) from existing program work requirements. Hundreds of thousands of ABAWDs would newly be exposed to a three-month time limit on their SNAP benefits if they cannot maintain 80 hours per month of employment. 
Another recent proposal seeks to limit the “broad-based categorical eligibility” pathway, which currently allows households to be automatically eligible for SNAP benefits based on receipt of other low-income assistance benefits. A third proposal would regiment how standard utility allowances (SUAs) are calculated within a household’s SNAP benefit calculation. Again, where certain beneficiaries in private Medicare plans are newly eligible for subsidized utility reimbursements to bolster their health, the USDA’s SUA proposal for SNAP recipients will, in many cases, count their utility spending against them, resulting in approximately 8,000 households losing SNAP eligibility all together. Recent analysis by the Urban Institute estimated that the combined impact of these three rules together, had they been in effect in program year 2018, would have meant a decrease in benefit allotments of $4.2 billion, and the disenrollment of 3.7 million beneficiaries. 
Looking Ahead 
The growing attention paid to the social determinants of health by the nation’s top federal health agency is encouraging. However, if the concept of the social determinants of health is most aggressively brought to bear only where it is most likely to yield shared savings for providers and health systems, profit margins for managed care plans, or taxpayer savings, then it isn’t of much use to the people it was designed to describe and serve. Worse, if these more vulnerable groups are actively and simultaneously seeing their access to health services and social supports degraded and stripped away, then the department’s professed focus on the social determinants is disingenuous—mere lip service to the latest buzz word in health policy. 
The good news is that stakeholders across the health system are awakening to the importance of this mission, investing in community programs to address affordable housing, hunger, and transportation, and calling for a coordinated strategy to close the gap between health and social needs. Under the current administration, it will be up to these states, payers, health systems, and other stakeholders to ensure that the focus remains on meaningful improvements for all who need them most. In addition to targeted investments, those hoping to impact the social determinants must mobilize to protect and strengthen the existing social safety net and to push this administration and the next to leverage the federal programs that can make a difference for the largest number of people in need.

https://www.healthaffairs.org/do/10.1377/hblog20200319.952157/full/

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