CMS Requirements for SDOH: What’s new in 2024? 

Beginning in January 2024, acute care hospitals participating in CMS payment programs are now required to submit health related social needs data. This is directly linked to the CMS Framework for Health Equity, 2022-2032 which outlined five priority initiatives.  

Priority 1: Expand the Collection, Reporting, and Analysis of Standardized Data 

CMS strives to improve our collection and use of comprehensive, interoperable, standardized individual-level demographic and SDOH data, including race, ethnicity, language, gender identity, sex, sexual orientation, disability status, and SDOH. By increasing our understanding of the needs of those we serve, including social risk factors and changes in communities’ needs over time, CMS can leverage quality improvement and other tools to ensure all individuals have access to equitable care and coverage. Read more.  

Prior to 2024, SDOH information was captured during an admission in the medical record by social workers and other clinicians to formulate a transition of care plan. However, SDOH was intermittently collected due to unclear coding rules.  With the new CMS requirements, data is now collected and reported via both clinician and physician documentation. 

While SDOH data collection is somewhat new to the acute care setting, Value-Based Care programs, such as accountable care organizations and physician practices participating in MIPS (Merit-Based Incentive Payment Programs) have been submitting Z codes on their populations for some time. SDOH-related Z codes ranging from Z55-Z65 are the ICD-10-CM diagnosis codes used to document SDOH data (e.g., housing, food insecurity, transportation, etc.) 

An estimated 20 percent of health outcomes are linked to medical care; the remaining 80 percent stem from socioeconomic, environmental, and behavioral factors referred to as drivers of health (DOH) (Magnan, 2017). These factors such as homelessness, food insecurity, and exposure to intimate partner violence (IPV)–are linked to poorer health, disproportionately impact communities of color, and have escalated due to COVID-19.  

Research demonstrates that 66 percent of physician practices are screening for one or more of the five DOH domains specified in this measure (Fraze et al., 2019). A 2022 survey by the Physicians Foundation found that 65 percent of U.S. physicians believe that implementing DOH quality measures is important to improve health outcomes and to ensure high-quality and cost-efficient care (Physicians Foundation, 2022). In a cross-sectional analysis of physicians who participated in the first year of the MIPS program, physicians caring for patients with increased social risk had significantly lower MIPS scores compared with other physicians (Khullar et al., 2020). Read more.  

“As the nation’s largest health insurer, the Centers for Medicare & Medicaid Services has a critical role to play in driving the next decade of health equity for people who are underserved. Our unwavering commitment to advancing health equity will help foster a health care system that benefits all for generations to come.” Dr. LaShawn McIver, Director, CMS Office of Minority Health. (CMS Framework for Health Equity 2022-2032) 

Case management and social worker SDOH documentation is key to meeting the CMS 2024 SDOH requirements but equally important is the knowledge and communication skills of nursing and other allied health professionals.  

Is your inpatient team up to date on the requirements and dynamics of Health-Related Social Needs (HRSN) and the Social Drivers of Health (SDOH)?  

Need an assessment by case management experts on current practice, staffing, model changes, or care continuum opportunities?  Contact ACUOCARE @ (501) 492 5555 or https://www.acuocare.com/