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Stakeholders Mixed On Usefulness Of HHS SDOH Data Collection Survey

March 16, 2021

HHS will survey providers on how they collect and use social determinants of health data in electronic health records, and while some say this is a positive step towards better patient care and benefit coordination, others worry there isn’t consensus about what SDOH data collection is reasonable.

“There is a growing recognition that by capturing and accessing SDOH data during the course of care, providers can more easily address non-clinical factors, such as food, housing, and transportation insecurities, which can have a profound impact on a person's overall health,” HHS said in its Paperwork Reduction Act notice on the survey, published last Thursday (March 11) in the Federal Register.

The SDOH project, announced last August, is aimed at studying and improving access to, exchange of and use of SDOH data in clinical notes. The project is run through the Office of the National Coordinator for Health Information Technology and seeks to collect information from providers on how they document and use SDOH information to treat patients or offer referrals. The project will also look at the challenges providers experience when using SDOH data; what types of data would be helpful to collect, share and use; methods that can or should be used for collecting and using SDOH data and more.

J.T. Lane, chief population health and innovation officer for the Association of State and Territory Health Officials, said this is a good time to be asking questions about how to make sure SDOH data collection is efficient and effective for providers, staff are trained on collection and authorities are clear about what providers should do with the data.

"It's a very good opportunity to have a conversation so that we can, again, address people's needs more comprehensively,” he said.

Vikram Bakhru, a practicing physician and the chief operating officer of ConsejoSano, said having SDOH information about his patients would help him tailor treatment to the individual.

"SDOH data will help us providers and the health system overall address the long-term goals of reducing disparities and achieving health equity,” Bakhru said.

Collecting SDOH data and including it in electronic health records could also help integrate public benefit programs, Lane said. Many families are eligible for both Medicaid and public nutrition programs like the Special Supplemental Nutrition Program for Women, Infants, and Children, he said. Sharing data electronically between a pediatrician and a WIC counselor, for example, could improve coordination and health outcomes.

"There's a lot of opportunity to talk, too, about how we can leverage data out of programs that represent social determinants as well to assist providers,” Lane said.

But Matt Salo, executive director of the National Association of Medicaid Directors, said meaningful integration will take enormous political will -- not just electronically shared data.

Salo said NAMD’s members generally think the idea of collecting SDOH data and putting it into electronic health records is a good idea. Still, there are questions about what kind of data should be collected and what’s reasonable to ask providers to collect, Salo said. At a certain point, the burden of getting the data becomes larger than the value that information provides.

"With the social determinants being so clearly a key part of the answer for so many folks in the Medicaid population ... on a very broad level, yeah, we’ve got to know more and you got to be able to collect more data,” Salo said. “But I think there's a very real concern about, okay, but what does that really mean?”

Salo added that he isn’t too optimistic that the HHS survey will answer questions about what SDOH data elements clinicians need to be collecting.

“It may get you an exhaustive list of what could be asked, but I don't know that it gets you any closer to the definitive and practical and pragmatic, much, much shorter list of things that are actionable,” he said.

On the other hand, Bakhru said he feels collecting as much SDOH data as possible would be ideal. In cases where that would place too much of a burden on clinicians and caregivers, at least data on food security, affordable housing, stable employment and transportation access should be collected, he said.

Initial comments on the survey are due May 10. -- Maya Goldman (mgoldman@iwpnews.com)