Oct 28 -- The Centers for Medicare & Medicaid Services (CMS) is announcing an opportunity for the public to comment on CMS' intention to collect CMS-10825: List of Screening Instruments for Housing Stability, Food Security, and Transportation Questions on Health Risk Assessments (HRAs). Comments must be received by December 27, 2022.
Our Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs Final rule (May 9, 2022; 87 FR 27704) (CMS-4192-F, RIN 0938-AU30) (hereinafter referred to as the May 2022 final rule) finalizes regulations related to Medicare Advantage (MA) dual eligible special needs plans (D-SNPs) and other special needs plans (SNPs). This information collection request is for the new regulation at 42 CFR 422.101(f)(1)(i) requiring that all MA SNP health risk assessments (HRAs) include at least one question from a list of screening instruments specified by CMS in sub-regulatory guidance on each of three domains (housing stability, food security, and access to transportation) beginning in CY 2024. This new requirement will help better identify the risk factors that may inhibit enrollees from accessing care and achieving optimal health outcomes and independence and enable MA SNPs to take these risk factors into account in enrollee individualized care plans. This information collection request provides the list of CMS-specified Social Determinants of Health (SDOH) screening instruments available for SNPs to meet the new requirement.
Section 1859(f)(5)(A)(ii)(I) of the Social Security Act (hereinafter referred to as the Act) requires each SNP to conduct an initial assessment and an annual reassessment of the individual’s physical, psychosocial, and functional needs. We previously codified this requirement at § 422.101(f (1)(i) as a required component of the SNP’s model of care. In current practice, we allow each SNP to develop its own HRA, as long as it meets the statutory and regulatory requirements. We amend § 422.101(f)(1)(i) to require that all SNPs (chronic condition special needs plans, D-SNPs, and institutional special needs plans) include one or more questions on the topics of housing stability, food security, and access to transportation as part of their HRAs.
MA organizations with SNPs would use the information collected from an enrollee answers to questions in the HRA to help identify risk factors that may inhibit the enrollee from accessing care and achieving optimal health outcomes. At this time, CMS will not collect or analyze the information gathered from enrollees by MA organizations under this information collection request.
As described in section II.A.4. of the May 2022 final rule, we are requiring that SNPs to include one or more questions from a list of screening instruments specified by CMS in sub-regulatory guidance on housing stability, food security, and access to transportation in their HRAs. SNPs will also have the option to use any State-required Medicaid screening instruments that include questions on these domains. This rule will result in SNPs having a more complete picture of the risk factors that may inhibit beneficiaries from accessing care and achieving optimal health outcomes and independence. Due to the current requirement at § 422.101(f) that the HRA include an assessment of the individual’s physical, psychosocial, and functional needs, we believe, and public comments on the May 2022 final rule confirmed, that many SNPs are already including questions in their HRA tools related to housing stability, food security, and access to transportation, and many such questions are drawn from the types of validated and widely-used screening instruments that we will specify in sub-regulatory guidance. Therefore, many SNPs will not need to revise their HRA tools. If a SNP is not already asking these questions, we do not predict the addition of questions on these three topics would lengthen the time to administer a typical HRA.
CMS Special Needs Plans https://www.cms.gov/Medicare/Health-Plans/SpecialNeedsPlans
Draft guidance and supporting statement: https://www.cms.gov/regulations-and-guidancelegislationpaperworkreductionactof1995pra-listing/cms-10825