The Physicians Foundation appreciates the opportunity to comment on the Centers for Medicare and Medicaid Services (CMS) on the Medicare Advantage Advance Notice (CMS-2024-0006) for calendar year 2025. 

The Physicians Foundation, compromising physicians from 21 state and county medical societies across

the country, practicing in urban, suburban, and rural areas, and representing a diversity of medical

specialties was the measure developer of the initial Social Drivers of Health (SDOH) measures. These measures have been proposed or enacted by CMS in 10 federal quality and payment programs and were referenced in the November 2023 U.S. Playbook to Address Social Determinants of Health. As detailed in the playbook, we commend CMS’s efforts of “increasing screening of common SDOH as part of annual Health Risk Assessments, improving quality measures, and updating payment models” as well as their efforts to “align measures across programs.”

We are excited to see the continued momentum for screening and navigation for health-related social need – and note opportunities for CMS to continue to ensure measure alignment to reduce the burden on physicians and patients – and submit the following public comments for your consideration: 

• Addition of Social Need Screening and Intervention Measure to the display page for the 2025 Star Ratings

We strongly support CMS’s inclusion of the Social Need Screening and Intervention (SNS-E) measure, developed by the National Committee for Quality Assurance (NCQA), in the display page for the 2025 Star Ratings. As CMS notes, “this measure is part of the Universal Foundation and [their] efforts to align measures across programs.” In addition, as CMS explained in its 2023 Advance Notice, the SNS-E measure supports the regulatory requirement that MA plans have arrangements that include “programs for coordination of plan services with community and social services” and would also “help contracts better serve at-risk beneficiaries, improving quality of care and outcomes for these beneficiaries.” 

• Weighting of SNS-E measure after the display period

We further encourage CMS to rapidly establish the SNS-E measure as a triple-weighted Star measure, like other intermediate outcome Star measures.  The systematic health-related social needs screening required by this measure is essential to ensure that health plans are accountable for both identifying members with the greatest social risk and ensuring those members secure an appropriate intervention, including relevant SDOH supplemental benefits, connections to community resources, and/or enrollment in SNAP, WIC, LIHEAP, and other programs.

• Inclusion of a utilities insecurity domain in the SNS-E measure

We support NCQA’s proposed inclusion of utilities insecurity screening and intervention rate to the SNS-E measure for measurement year 2026. As CMS indicates, the “utility insecurity addition to NCQA’s measure aligns with CMS’s Addressing Social Needs measure under development, which currently includes a utilities indicator. The addition also aligns with evidence found of high utility insecurity and the association between utility insecurity and health outcomes.” (pg. 130) This represents a critical step to improve measure alignment with CMS’s “Screening for Social Drivers of Health Measure” now enacted or proposed in 10 federal programs – including its priority SDOH domains of food, housing, transportation, utilities, and interpersonal safety included in those measures – and its ICD-10-CM Z Codes. 

• Inclusion of an Interpersonal Violence/Safety Domain in the SNS-E Measure

We also urge CMS to request that NCQA to include interpersonal/violence safety as a fifth domain given the strong evidence base CMS has previously provided (see the Hospital Inpatient Quality Reporting Program Final Rule, pg. 49203) for doing so. As CMS has stated, “interpersonal safety affects individuals across the lifespan, from birth to old age, and is directly linked to mental and physical health” and “is directly associated with injury, psychological distress, and death in all age groups.” As with the addition of the utility insecurity domain, inclusion of interpersonal safety/violence would ensure alignment across measures and its ICD-10-CM Z Codes.