The Undoing of SDoH Reporting

Editors Note: This article was originally published on ICD10monitor, April 15, 2025

In a sweeping policy shift, the Centers for Medicare & Medicaid Services (CMS) has proposed significant rollbacks to Social Determinants of Health (SDoH) and equity-related reporting requirements across the Inpatient Prospective Payment System (IPPS), Inpatient Rehabilitation Facility (IRF), and Long-Term Care Hospital (LTCH) settings.

Released on Friday April 11 at 5pm EST, drastic changes were introduced. Per the CMS email brief, the fiscal year (FY) 2026 proposed rules reflect the CMS alignment with Executive Order 14192, “Unleashing American Prosperity Through Deregulation,” which prioritizes the reduction of administrative burden and private-sector compliance costs.

Under the FY 2026 IPPS proposed rule, CMS has announced its intent to remove four key measures from the Hospital Inpatient Quality Reporting (IQR) Program beginning with the Calendar Year (CY) 2024 reporting period/FY 2026 payment determination:

1. Hospital Commitment to Health Equity – This was a structural measure to evaluate a hospital’s leadership, training, data collection, and community partnerships to advance health equity.
2. COVID-19 Vaccination Coverage Among Healthcare Personnel – This measure captured frontline worker vaccination rates and was considered a critical post-pandemic accountability tool.
3. Screening for Social Drivers of Health – Introduced to assess whether hospitals are actively identifying patient challenges related to housing, food, transportation, and utilities.
4. Screen Positive Rate for Social Drivers of Health – A complementary measure to quantify the proportion of patients screening positive for social needs.

The elimination of these measures marks a notable retreat from the CMS prior emphasis on collecting actionable data to address health disparities and improve care planning based on non-medical risk factors.

CMS is also proposing similar rollbacks in post-acute care settings through changes to the IRF and LTCH Quality Reporting Programs (QRPs), which currently require standardized data collection on patients’ social needs.

In IRFs, CMS proposes to eliminate four SDoH Standardized Patient Assessment Data Elements (SPADEs) from the IRF-Patient Assessment Instrument (PAI), effective in FY 2028. These include data fields for living situation, food, and utilities. These elements were designed to inform discharge planning and improve care coordination for medically and socially complex patients. Under the proposed ruling, however, these will no longer be required fields.

In LTCHs, CMS proposes parallel removals. Beginning in FY 2028, LTCHs will no longer be required to report living situation (R0310), the two items for Food (R0320A and R0320B), and the one item regarding utilities (R0330).

These proposed changes, while framed as efforts to reduce provider burden, represent a broader retreat from embedding SDoH and health equity into federal quality and payment programs. The argument listed in the FY 2025 IPPS ruling, discusses the burden of training, data collection, and patients’ answering these same questions across multiple healthcare facilities.  However, since FY 2026 was the payment determination period, it is unclear if any benefit will be awarded to all the health systems that have been actively collecting this data and have ingrained this into daily workflows. 

Instead of SDoH, CMS is requesting ‘Consideration for Future Years in the Hospital IQR program- request for information (RFI): Well-Being and Nutrition’.

CMS’s regulatory realignment signifies the growing tension between administrative simplification and the drive for more equitable, data-informed care delivery. At this time, it does not appear that the SDoH z-codes have been adjusted, however the link provided in the proposed ruling to review coding changes appears to not be working.

Although it is clear that hospitals and health systems did have increased burden with the SDoH questions, removal of these requirements does not eliminate the presence of SDoH risk factors and its impact on patient health outcomes.

Public comment is open regarding the proposed ruling. Source:
CMS FY 2026 IPPS and LTCH Proposed Rule Fact Sheet