The Centers for Medicare & Medicaid Services (CMS) took a significant step towards advancing health equity with the finalization of Parts C and D Enrollment Guidance. This strategic move aligns with CMS’s ongoing commitment to prioritize health equity, a dedication outlined in its comprehensive strategic plan and Framework for Health Equity 2022–2032

The pursuit of health equity through effective policy implementation and program development is central to the CMS strategic vision, with the aim to eliminate avoidable disparities in health outcomes among underserved populations.

A Core Embrace of Data-Driven Insights 

The updates underscore the pivotal role of data collection to comprehend social risk factors, care experiences, and patient demographics (including race, ethnicity, language, gender identity, sexual orientation, and disability status). This data-centric approach is a cornerstone to enhance care quality and address the existing disparities in health outcomes.

Significant Focus on Data Collection 

The update is noteworthy in its inclusion of data collection on race and ethnicity, as mandated by 42 CFR 422.60. Even on an optional basis, the inclusion of race and ethnicity fields in enrollment forms promises to offer invaluable insights. This information is poised to guide policymakers to make informed decisions and craft targeted interventions aimed at mitigating health disparities prevalent among distinct racial and ethnic groups.

Evolution of the LINET Demonstration 

The evolution of the Limited Income Newly Eligible Transition (LINET) 42 CFR 423.34 demonstration is another instrumental aspect highlighted in the regulatory update. Originally initiated in 2010 as a time-bound initiative, it’s now set to become permanent on January 1, 2024. This program brings immediate and retroactive Part D coverage to eligible low-income beneficiaries without prescription drug coverage, with the overarching goal of widening access to essential healthcare services.

Holistic Approach to Health Equity 

The regulatory updates serve as a testament to CMS’s comprehensive strategy in tackling healthcare disparities. Aligned with CMS’s broader health equity objectives, these changes emphasize a multi-faceted approach to creating a more equitable healthcare landscape.

Commitment to Fairness and Inclusivity

The details in this regulatory update, as well as the 2024 MAPD final rule, reflect CMS’s dedication to its 2022-2032 Health Equity Framework. With a focus on multiple dimensions of health disparities, CMS continues to signal its commitment to advancing health equity and creating a healthcare environment that ensures fairness and inclusivity for all.

ATTAC Consulting Group is nationally recognized for expertise in regulatory interpretation, and the design and operation of effective compliance programs for government and commercial health plans. Contact us about how we can put the experience, quality and rigor of our advisory services and audits to work for your plan.