Proposed Rule Offers Opportunity to Help Advance Maternal Health Equity

We can’t improve what we don’t measure. That’s why it is important for all who want to improve maternal and child health to take a look at a proposed rule now up for comment that provides an important opportunity to increase transparency and accountability for the quality of care delivered through Medicaid and CHIP. The rule requires states to report on the Child Core Set and behavioral health quality measures in the Adult Core Set and to disaggregate some of the data by race, ethnicity and other factors. The comment period is open through October 21.

The rule is especially important for improving the quality of maternity care. Medicaid covers more than 40% of births nationally, including more than two-thirds of Black and American Indian and Alaska Native (AIAN) births, groups that experience higher rates of pregnancy-related mortality and morbidity as compared to White individuals.  As the nation faces an ongoing maternal mortality crisis that disproportionately affects Black women, getting clear data is the first step to understanding specific challenges and where states must improve.

Some background on the Core Set may be helpful here, and my colleague Tricia Brooks wrote a helpful blog explaining some of the basics. States report three sets of health care quality measures—the Child Core Set, the Adult Core Set, and the Health Home Core Set—to CMS each year. Based on the recommendations of an expert panel, the Secretary chooses the annual set of measures, which provide a comprehensive look at the quality of care delivered to the millions of people enrolled in Medicaid and CHIP. More recently, CMS has also created a Maternity Core Set, with measures from both the adult and child sets, to highlight several key metrics related to perinatal health, including timeliness of prenatal care and access to contraception for teens and adults.

Reporting on these measures has been voluntary for states. This makes it very difficult to track state performance over time or to compare states with one another to identify policies and practices that are working and those that are in serious need of improvement. In addition, the measures that states do report are not broken down by race, ethnicity, or any other demographic factors, which makes it impossible to identify health disparities.

However, in 2018, Congress required that beginning with the annual report in FY 2024, all states report (1) all Child Core Set measures, (2) all behavioral health measures included in the Adult Core Set, and (3) all Health Home Core Set measures.  States have to use a standardized format so that the information in the reports can be compared.

The NPRM implements these requirements, and the comment period is an important opportunity to improve transparency and accountability for the quality of health care delivered to people enrolled in Medicaid and CHIP, particularly for the millions of pregnant people and infants who are served in these programs each year.

There are several maternal health metrics within the Child Core Set, including timeliness of prenatal care, rates of low-risk cesarean deliveries and contraceptive care, all of which would provide valuable insight on whether pregnant and postpartum people are receiving critical healthcare services. The required behavioral health metrics in the Adult Core Set also include several metrics important for the health of women of reproductive age, including antidepressant medication management, initiation of alcohol or substance use disorder treatment, and medical assistance with smoking or tobacco cessation.

Seeing how well states are performing on these metrics, and seeing where there are disparities by race, ethnicity, gender, geography and other demographic factors would be a significant step forward in understanding the ongoing healthcare crisis and identifying where more work is needed.

Ensuring that all states report the required measures on time and with detailed, disaggregated data will promote health equity and usher in improvements to the quality of care provided by Medicaid and CHIP as envisioned by Congress when it passed these laws.

[Individuals interested in submitting comments to CMS can do so through the Why My Care Counts portal on or before October 21.]

Maggie Clark is a former staff member at the Georgetown University McCourt School of Public Policy’s Center for Children and Families.