~ An important message from our colleagues at the HELEN Network ~

helen

Urgent: Add your perspective to public comments as deadlines are looming!

Dear HELEN Members,

In light of last week’s administrative and legislative challenges impacting health equity, the HELEN team would like to remind everyone about the opportunities that exist to make our collective voices heard in the coming weeks. In addition to the President's fiscal year 2018 budget that proposes major organizational changes that could drastically impact health equity, we are also monitoring two other potential policies that could have a devastating impact: the new draft U.S. Department of Health Human Services (HHS) strategic plan and the new proposed change in direction of the Center for Medicare and Medicaid Innovation (CMMI).

On September 27, the HHS published its Request for Comments on the Draft Department Strategic Plan for Fiscal Years 2018 – 2022 with a deadline of October 27, 2017. On September 19, the administrator for the Centers for Medicare and Medicaid Services (CMS), Seema Verma, published an op-ed in the Wall Street Journal announcing a Request for Information seeking comments on the future direction of CMMI with a deadline of 11:59 p.m. EST, November 20, 2017. Along with the significant reductions to funding for HHS, these two requests for comment provide us with yet another opportunity to elevate our concerns about the prioritization of health equity in federal health policy.

The new draft HHS Strategic Plan scrubbed the vast majority of health equity provisions by negating references to health equity and the health disparities among minority groups such as racial and ethnic, individuals with disabilities, LGBT, and many others. This Strategic Plan is provided as part of the strategic planning process to ensure that Agency stakeholders are given an opportunity to comment on this plan. Therefore, as health equity leaders, it is incumbent upon us to utilize this comment period and continue to advance health equity-related policies. Please alert any and all interested parties about the fast approaching October 27, 2017 deadline to submit comments by either email, fax at (202) 690-5882, or mail to the following address:

     U.S. Department of Health and Human Services
     Office of the Assistant Secretary for Planning and Evaluation, Strategic Planning Team
     Attn: Strategic Plan Comments
     200 Independence Avenue, SW
     Room 415F
     Washington, DC 20201

In an equally concerning move, changes to CMMI could have a deleterious impact if we do not offer ideas for prioritizing models that promote health equity. As detailed on the CMMI website, this informal Request for Information is seeking feedback on a new direction to promote patient-centered care and test market-driven reforms that empower beneficiaries as consumers, provide price transparency, increase choices and competition to drive quality, reduce costs, and improve outcomes. It is quintessential that we impress upon our federal policy makers, the importance of ensuring that any new direction CMMI takes includes caring for those portions of our population that experience the greatest disparities in health status, care, and treatment. The Innovation Center is interested in testing models in 8 specific focus areas:

     1. Increased participation in Advanced Alternative Payment Models (APMs)
     2. Consumer-Directed Care & Market-Based Innovation Models
     3. Physician Specialty Models
     4. Prescription Drug Models
     5. Medicare Advantage (MA) Innovation Models
     6. State-Based and Local Innovation, including Medicaid-focused Models
     7. Mental and Behavioral Health Models
     8. Program Integrity

If you, your organization, or any individual or entity within your network has expertise in any of the above areas, please submit comments online or by email before 11:59 p.m. EST, on November 20, 2017. The HELEN team is currently reviewing and analyzing the proposed new direction of CMMI and we will also be submitting comments.

As diverse leaders of health equity throughout the country, we want to hear from you. Do you have a specific concern or suggestion for either comment period? Is there a particular health equity provision you believe should be strengthened? Do you see a concern that could jeopardize a vulnerable population group? Let us know! As you and your organizations review the proposed changes, please send us your thoughts and concerns so that we may incorporate your views into our public comments.

We look forward to receiving your input and continuing to work with you in advancing health equity.

 

Sincerely,

 

The HELEN Team

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