New Hospital Reporting Requirements for SDoH

CMS has implemented two measures under its Hospital Inpatient Quality Reporting program.

There is a lot of buzz in the Social Determinants of Health (SDoH) reporting and documenting world, and it is coming from all angles.

As reported recently in an article written by Erica Remer, MD, the final ruling for SDoH Z-codes is that they are continuing to evaluate their impact on MCC/CC capture and the Centers for Medicare & Medicaid Services (CMS) is continuing to recommend collection of these codes while they complete their analysis of impact, particularly the identification of Z59.0 homelessness (and its subcategories).

Additionally, CMS is finalizing the voluntary reporting for social drivers of health for 2023, which will be followed by mandatory reporting in 2024 with a payment determination to be in place by 2026.

CMS has implemented two measures under its Hospital Inpatient Quality Reporting program to collaborate with their 2023 ruling for Medicare Advantage plans to include Health Risk Assessments for their Special Needs Plans (SNP). The two measures that are being added are the Screening for Social Drivers of Health and the Screen Positive Rate for Social Drivers of Health. The measure is looking at the percentage of patients admitted to the hospital 18 or older that at the time of admission are screened for housing instability, transportation needs, utility difficulties, and interpersonal safety. This measure will look at two items: was the appropriate category of patients (inpatients 18 and older) screened in all five categories and which patients opted out of the screening or were unable to complete the screening during their stay.

To recap because this is a bit confusing. Hospitals in 2024 will have a mandated process to assess that they one offered an assessment on the five domains of social drivers of health and two that they complete the domains to collect and report this information. This will be submitted through Hospital Quality Reporting, but guess what coders, you can use it too!

CMS provides a tool that can be utilized called the Health-Related Social Needs Screening Tool (HRSN), (linked below). The tool is 26 questions, however for this reporting measure, only the first 10 questions are related to the five domains. Many of the other questions are already collected in the electronic medical record (EMR) during nursing admission documentation and/or case management initial assessments.   

For our listener survey, I would like to ask: Is your hospital or healthcare system working on implementing SDoH questions into your documentation processes? 

  • Yes
  • No
  • Unsure
  • Does Not Apply

The responses from the Monitor Monday listener survey may surprise you, and can be viewed here.

Programming Note: Listen to Tiffany Ferguson’s live reporting on the SDoH every Monday on Monitor Mondays at 10 Eastern.

References:

https://www.federalregister.gov/documents/2022/08/10/2022-16472/medicare-program-hospital-inpatient-prospective-payment-systems-for-acute-care-hospitals-and-the

https://innovation.cms.gov/files/worksheets/ahcm-screeningtool.pdf

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Tiffany Ferguson, LMSW, CMAC, ACM

Tiffany Ferguson is CEO of Phoenix Medical Management, Inc., the care management company. Tiffany serves on the ACPA Observation Subcommittee. Tiffany is a contributor to RACmonitor, Case Management Monthly, and commentator for Finally Friday. After practicing as a hospital social worker, she went on to serve as Director of Case Management and quickly assumed responsibilities in system level leadership roles for Health and Care Management and c-level responsibility for a large employed medical group. Tiffany received her MSW at UCLA. She is a licensed social worker, ACM, and CMAC certified.

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