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Health Equity Strategy

The Innovation Center believes that equitable care is a key component of achieving high-quality care for beneficiaries and is therefore critical to the GUIDE Model’s success. CMS defines health equity as: “the attainment of the highest level of health for all people, where everyone has a fair and just opportunity to attain their optimal health regardless of race, ethnicity, disability, sexual orientation, gender identity, socioeconomic status, geography, preferred language, or other factors that affect access to care and health outcomes.”49 The term “underserved communities” refers to populations sharing a particular characteristic, as well as geographic communities, that have been systematically denied a full opportunity to participate in aspects of economic, social, and civic life.50

Along with the health equity adjustment to model payments, the new program track and infrastructure payment for safety net providers, the Referral and Coordination of Services and Supports domain in care delivery, and the requirement for care navigator training to include a cultural competency domain, the GUIDE Model has two additional model requirements which are designed to promote health equity:

  1. Health Equity Plan Requirement
  2. Health Equity Data Collection Requirement

Health Equity Plan Requirement

GUIDE Participants will be required to develop and implement a Health Equity Plan. The purpose of a Health Equity Plan is for each GUIDE Participant to identify disparities in outcomes in their patient populations and implement initiatives to measure and reduce these disparities over the course of the GUIDE Model.

On an annual basis, GUIDE Participants will be required to report on the progress of their Health Equity Plan as a section of the GUIDE Model’s care delivery reporting. The focus of health equity planning will be on improving quality of care for underserved beneficiaries and addressing health disparities. GUIDE Participants will be required to set goals and monitor progress over time, identifying and selecting evidence-based interventions for addressing health disparities and achieving equitable outcomes. The Innovation Center will provide a framework for Health Equity Plans, and will review, but not assess, plans submitted by GUIDE Participants.

The first Health Equity Plan will be due as part of the baseline care delivery reporting (see “Care Delivery” section for more information about reporting timeline). The first Health Equity Plan must focus specifically on beneficiary outreach and engagement as a precursor to more comprehensive annual Health Equity Plans. The goal of the first Health Equity Plan will be to encourage GUIDE Participants to develop and implement strategies to reach potentially eligible beneficiaries from historically underserved communities from the outset of the GUIDE Model.

GUIDE Participants will be required to prepare and submit comprehensive Health Equity Plans beginning in the second care delivery reporting period, at the start of GUIDE Participants’ second performance year, and update the plans annually thereafter.

Health Equity Plans may not propose or use actions that selectively target beneficiaries based on race, ethnicity, national origin, disability, religion, or sex. In addition, Health Equity Plans must comply with all applicable non-discrimination laws, including section 1557 of the Affordable Care Act, Title IX of the Education Amendments of 1972, Title VI of the Civil Rights Act of 1964, and Section 504 of the Rehabilitation Act. GUIDE Participants will be permitted to identify beneficiaries for health equity plan interventions based on other factors, including but not limited to medical history, health status, health needs, disability status, or income, provided the GUIDE Participant and other individuals or entities performing functions or services related to the Health Equity Plan comply with all applicable nondiscrimination laws and regulations.

Health Equity Data Collection Requirement

CMS will require all GUIDE Participants to collect and report certain beneficiary-reported sociodemographic data and health-related social needs (HRSN) data from their aligned beneficiaries willing to share this information. To avoid discouraging beneficiaries from accessing care from GUIDE Participants, beneficiaries are not required to share this data with their providers. GUIDE Participants are not required to report this data to CMS for any beneficiary who chooses not to disclose them.

HRSNs are used to describe individual-level social needs and are individual-level, adverse social conditions that negatively impact a person’s health or health care. Some GUIDE Participants may already be collecting HRSNs from their beneficiaries, but it is important that all GUIDE Participants collect this information to provide adequate services, plan for future interventions, and increase quality of care. HRSN collection and referrals will be part of the GUIDE Model’s broader care delivery requirements for comprehensive assessment and referral for social services and supports.

GUIDE Participants will be encouraged to use one of two preferred HRSN screening tools: