The Biden Administration has announced its intention to make health equity and reducing racial disparities a central feature of its policy agenda issuing an Executive Order on day one instructing federal agencies to promote equity in multiple ways. Section 9 of this Executive Order noted that many federal datasets were not disaggregated by race/ethnicity/gender/disability etc., and established an Equitable Data Working Group. Recently, the Office of Management and Budget (OMB) issued a “Request for Information” asking external parties to send public comments on a range of topics such as using data to promote equitable policymaking, reducing barriers that contribute to inequities in program access, and identifying strategies to reach underserved communities.
Comments were due on July 6th, and Georgetown CCF submitted a list of ten things that the Centers for Medicare and Medicaid Services should do. While OMB’s request was broader, we decided to focus our comments on the areas we know best – in particular Medicaid and CHIP.
As we noted in our comments, while the majority of people enrolled in Medicaid are White, Medicaid disproportionately covers children and adults of color—including 34.4 percent of American Indian and Alaska Native individuals, 32.9 percent of Black individuals, and 30 percent of Hispanic individuals.1 In order to reduce disparities in access and outcomes in the health care system and promote equity, Medicaid must be central to and at the leading edge of efforts by federal and state policymakers.
You can read our comments in their entirety here, but I will share a few toplines. One bucket of CCF recommendations highlighted the need for an aggressive effort to disaggregate Medicaid data or simply collect it by race/ethnicity on things such as Medicaid enrollment, quality indicators, managed care plan performance, etc. Disaggregated data needs to be collected on an ongoing basis in Medicaid and CHIP, where it is often sorely lacking, as well as when specific situations arise – like the end of the public health emergency which has the potential to result in millions of people losing their Medicaid coverage after the disenrollment freeze is lifted.
A second bucket of our recommendations focuses on the way CMS makes Medicaid and CHIP policy – through State Medicaid Director (SMD) and State Health Official (SHO) letters; state plan amendments (SPA), and through Section 1115 demonstration (or waiver) policy. For each of these policy mechanisms, we suggest that CMS includes an “equity assessment” which can be used to ensure that future Medicaid state policy actions reduce health inequities and disparities rather than promote them – as we saw with the Trump Administration’s efforts to promote work requirements that in some states would have squarely targeted Black women with coverage losses.
To state the obvious, there is so much work for the Biden Administration to do in this space.
1 https://www.kff.org/medicaid/state-indicator/nonelderly-medicaid-rate-by-raceethnicity/?currentTimeframe=0&sortModel=%7B%22colId%22:%22Location%22,%22sort%22:%22asc%22%7D
