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Tracking CMMI’s Shift to Health Equity

Health equity is the latest focus of the Center for Medicare and Medicaid Innovation (CMMI), which was launched a decade ago to develop and test health care payment models with the goal of saving money for Medicare.  This push for health equity goes back to the very beginning of the Biden administration when he first issued an executive order (EO) on advancing health equity in January 2021.  What steps has CMMI taken to push for health equity since then, and how will CMMI pull it off?

CMMI’s shift to health equity kicked off in October 2021, when the center released a white paper announcing a “strategic refresh” that would judge the success of its models not just on whether they save money but also whether they improve health equity.  Of note, the white paper found that only six models of the more than 50 models CMMI currently has generated substantial savings for Medicare.

CMMI followed-up this strategic refresh in February 2022 when it launched the Accountable Care Organization (ACO) Realizing Equity, Access, and Community Health (REACH) Model, a redesign of the Global and Professional Direct Contracting (GPDC) Model.  A key feature of the ACO REACH model is a requirement for model participants to develop a health equity plan that identifies underserved communities and outlines initiatives to reduce health disparities within their beneficiary populations.

The ACO REACH Model won’t be the last CMMI model to make health equity a cornerstone.  In March 2022, CMMI Director Liz Fowler said creating a health equity plan will  likely be a requirement for future innovation center models.

CMMI took another bold step on health equity in March 2022 when Chief Medical Officer Dora Lynn Hughes announced in a Health Affairs blog post that the innovation center has added “Advancing Health Equity” as one its five strategic objectives.  In the blog post, Hughes outlines ways CMMI intends to achieve this new objective:

  • Developing new models and updating existing models to promote and incentivize health equity, as demonstrated by the ACO REACH Model.
  • Increasing the participation of safety net providers to ensure models reach underserved communities.
  • Increasing collection and analysis of equity data, primarily by coordinating with other offices in the Department of Health and Human Services (HHS).
  • Monitoring and evaluating models for health equity impact by analyzing beneficiary experience and equity assessments.

Can CMMI pull off its health equity goals?  After all, only a fraction of the center’s 50 models achieved the goal of saving Medicare money, which makes the center’s capability to tack on and carry out another goal seem overly ambitious.

Fortunately, CMMI has a plan.  In her blog post, Hughes stated that the center will have to collaborate with offices and agencies across HHS, particularly those focused on social determinants of health like food, housing, and transportation.  Outside of the government, Hughes said CMMI is already meeting with groups that have not previously engaged with the center, like community-based organizations and patient advocacy groups, and that CMMI is hosting roundtable discussions on health equity to help inform its work.

On top of this, the Centers for Medicare and Medicaid Services (CMS) is working hard to advance health care interoperability, which CMS Administrator Chiquita Brooks-LaSure said in March 2022 is essential to addressing the “inequities in our health care system.”  Better data collection is one of the four ways CMMI hopes it will achieve its health equity goal, and Brooks-La Sure recently announced that CMS will soon publish a rule on health data exchange.  While CMMI’s success at creating models that reduce Medicare costs may be limited at best, the center has laid out some specific actions it hopes to take to achieve its new goal, increasing the odds this goal can become reality.

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Are US Hospitals At Risk of Russian Cyberattacks?

The alarm is sounding for cybersecurity attacks.  In late February, the Cybersecurity and Infrastructure Security Agency (CISA) issued a rare warning that the Russian government could launch cyberattacks against the US economy – including the health care sector.  One month later, President Joe Biden publicly warned that Russian cyberattacks are “coming.”  Given these warnings, how worried should hospitals be?

The threat explained: Russia is no stranger to deploying cyberattacks.  In the days leading up to  Russia’s invasion of Ukraine on February 24, 2022, a series of Russian cyberattacks temporarily shut down websites for some Ukrainian banks and deleted data at multiple Ukrainian government agencies.  Since then, US government officials have expressed concern that Russia is preparing to launch cyberattacks against the US in retaliation for heavy sanctions levied against the Kremlin in response to the invasion of Ukraine.  However, the federal government has yet to offer any evidence of an anticipated specific cyberattack.

Cyberattacks aren’t new to the health care industry.  In 2017, Russian-backed hackers launched a destructive malware called “NotPetya” initially targeted at Ukrainian interests that went on to infect several US-based health care stakeholders like Merck Pharmaceuticals and Heritage Valley Health System.  During the COVID-19 pandemic, the number of cyberattacks against US hospitals surged, with an estimated 50 million people in the US  had their sensitive health data breached in 2021.  According to a survey of information technology professionals, in 2020 more than a third of health care organizations reported that they were  hit by ransomware attacks, which is when hackers use encryption to hold a victim’s information at ransom.

Unfortunately, the health care sector is attractive target for cyberattackers.  Hospitals dealing with ransomware attacks are often pressured to pay hackers because they otherwise wouldn’t be able to operate.  And while some hospitals have invested in security-monitoring capabilities and new software over the past few years, most health care organizations have meager cybersecurity budgets and remain vulnerable to attacks.  Compounding these vulnerabilities is the COVID-19 pandemic, which has overwhelmed hospitals with patients and strained hospitals’ budget, leaving fewer resources available for cybersecurity.

Congress and the Biden administration has proposed some steps to shore up the nation’s cybersecurity.  The Build Back Better Act (BBBA) included more than $500 million in cybersecurity funding, and President Biden’s Fiscal Year (FY) 2023 budget request calls for $11 billion in new cybersecurity spending.  Most recently, Sens. Jacky Rosen (D-NV) and Bill Cassidy (R-LA) introduced a bill to improve the health care industry’s cyber-defenses by requiring CISA to partner with the Department of Health and Human Services (HHS).  However, next steps for these proposals aren’t exactly promising – the BBBA is stalled in its current format, the president’s budget request is generally considered a wish list, and the cybersecurity bill has yet to add any cosponsors since its introduction on March 23.

Absent action from the federal government, there are steps hospitals can take to boost their defense against cyberattacks, as outlined in an American Hospital Association (AHA) advisory notice on the CISA warning.

  • Increase network monitoring for unusual activity.
  • Flag all inbound and outbound traffic from Ukraine and the surrounding area.
  • Implement four-to-six-week business continuing plans, with an emphasis on all internal and third-party mission-critical clinical and operational services and technology.
  • Check networks for redundancy, resilience, and security and create multiple data back-ups.

There is a chance that Russian hackers will leave the US health care system alone.  While Russia has certainly become more belligerent in cyberspace over the last decade, cyberattacks against Ukraine have been more limited than intelligence and defense experts have anticipated.  In fact, some experts say Russia’s cyber-forces may actually be overhyped and in a state of disarray – similar to Russia’s armed forces.

But hospitals can’t rely on hope to stay safe from hackers.  If the experience of the last few years says anything, it’s that the health care system isn’t immune to cyberattacks, and that stakeholders would do best to prepare for the worst.

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What Happened, What You Missed: March 28-April 1

BA.2 Omicron Subvariant Now Dominant in US

The BA.2 Omicron subvariant now accounts for more than 54% of new COVID-19 cases in the US, according to data released on Tuesday by the Centers for Disease Control and Prevention (CDC).   While the BA.2 subvariant is considered to be at least 30% more transmissible than the original Omicron strain, there is no data to indicate that it’s more severe.  The rise of the BA.2 strain comes as the Biden administration continues to press Congress for at least $22.5 billion in additional COVID-19 funding to prepare the health care system for a potential surge in new case numbers.  While COVID-19 hospitalizations are at their lowest level since the start of the pandemic, infections are ticking upwards in 13 states.

Adults Over Age 50 Now Eligible for Second Booster Shots

On Tuesday, the Food and Drug Administration (FDA) and CDC authorized second booster shots of mRNA vaccines for people over the age of 50 at least four months after their first booster.  The federal agencies also authorized third booster doses for people aged 12 and older who are immunocompromised.  Federal officials opted to authorize the additional boosters to shore up protection for vulnerable Americans ahead of a potential late spring-early summer wave as increasing evidence points to waning immunity from previous vaccine doses.  However, data on whether an additional booster provides stronger protection remains scant.  On Wednesday, President Joe Biden publicly received his second booster dose and urged Congress to provide billions of dollars in additional COVID-19 funds to ensure the administration has enough money to purchase second booster doses for all Americans.

Biden’s Budget Request Stresses Pandemic Preparedness

Preparing for the next pandemic and shoring up the nation’s biodefense strategy are key components of President Biden’s Fiscal Year (FY) 2023 budget request for the Department of Health and Human Services (HHS), which was released on Monday.  Within the $127 billion request for HHS, the administration is asking for $28 billion to boost pandemic preparedness, $12.1 billion to develops tests and treatments for biological threats, and $500 million to bolster safety inspections at nursing homes.  The budget request also asks Congress to provide hundreds of millions of dollars to address other public health crises like the opioid epidemic, health disparities, and domestic violence.

Lawmakers Pay Tribute to Late Rep. Don Young in Capitol

Members of Congress from both parties gathered on Tuesday to pay their respects to the late Rep. Don Young (R-AK), who died on March 18 at age 88.  Young’s eulogy featured remarks from Speaker Nancy Pelosi (D-CA), Republican Leader Kevin McCarthy (R-CA), and a performance of “Amazing Grace” by the US Army Chorus.  First elected to Congress in 1973, Young was known for his colorful personality and played a key role in advancing infrastructure projects and protecting Alaska’s natural resources.  Young was the Republican Party’s longest-serving member of Congress in history, and he was the last serving member who was first elected during the Nixon administration.  The late congressman is survived by his wife, Anne, and two daughters, Joni and Dawn.

ICYMI: DC Welcomes Reese Witherspoon

Earlier this week, Academy-Award winning actor and producer Reese Witherspoon appeared at a Women’s History Month reception honoring women artists at Vice President Kamala Harris’s residence.  While in town, Witherspoon visited a few shops on M Street NW in Georgetown and the National Portrait Gallery, which notably includes a portrait of John Witherspoon – a signer of the Declaration of Independence who is also a direct ancestor of the actress.

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Will Hill Staffers Unionize?

Hill staffers say they’ve had enough.  Long hours, low pay, and cases of emotional and physical abuse are driving more and more congressional staffers to form the Congressional Workers Union with the hope of delivering better working conditions and higher pay.  But forming a union on the Hill is easier said than done, and staffers hoping for better working conditions in their current roles might have to wait for some time.

Why unionize?  The cost of living in the Washington, DC area is notoriously high, with the average rent for a studio apartment in the District going for $1,891.  Finding the money to cover high rent can be hard – 13% of Washington-based staff (about 1,200) make less than $42,610 each, which is the average salary needed to cover basic essentials like rent and groceries in DC.   On top of that, staffers face sub-par working conditions that have been regularly documented in the Instagram account @dear_white_staffers, which details stories anonymously of poor treatment by members and staff, harassment, burnout, and more.  Given all these pain points, it’s no surprise that turnover among House staff is at its highest level in 20 years.

High turnover among Hill staffers has negative implications outside of Congress.  For one, it’s bad news for advocates because it gives them fewer opportunities to develop meaningful relationships that help them advance their cause.  Additionally, an ever-changing staff makeup deprives Congress of the institutional knowledge and policy expertise it needs to pass legislation that impacts the American people.  By boosting pay and improving working conditions, congressional staff might be compelled to stick around the Hill longer – allowing them to forge deeper bonds with advocates, and more strongly familiarize themselves on the issues important to them and develop legislation that works better for most Americans.

Unfortunately for staffers, there are a lot of challenges to forming a union on the Hill.  These include:

  • Legal issues.  Congress is exempt from federal labor laws that protect most US employees’ labor-organizing activities.  Absent any legal protections, staff are reluctant to publicly push for a union because it could lead to them being fired or blacklisted.
  • Partisan problems.  In general, Democrats have supported staff efforts to unionize, while Republicans do not.  During a March 2 congressional hearing on a bill to allow staff to collectively bargain, GOP members said unionization efforts were “impractical,” would add to “even more dysfunction in Washington,” and amounted to a “solution in search of a problem.”  Outside of the hearing, Sen. John Cornyn (R-TX) has referred to unionization as a “terrible idea,” and Sen. Mitt Romney (R-UT) said giving staff the ability to organize is “nuts.” But it’s not just Republicans who stand in the way – Democrats who are generally pro-worker and pro-union could be at risk for allegations of hypocrisy if they fail to support their own staff’s organizing efforts.
  • Operational considerations.  Congressional offices aren’t like normal businesses that can raise salaries and boost benefits based on market conditions.  Instead, each office is provided a yearly allowance that covers a range of expenses, like staff pay, travel funds, and mail.  Unfortunately, these allowances don’t provide much flexibility on staffers’ salaries.  While the Fiscal Year (FY) 2022 omnibus appropriations bill did boost the yearly allowance for House offices by 21%, this doesn’t guarantee House staffers will see higher pay as a result.  More so, each congressional offices operates independently, which means a unionized congressional staff would essentially involve hundreds of individual unions throughout the Hill.  Additionally, there’s a chance majority and minority staffers on each committee could try to organize separately, adding to the number of potential unions.

What’s next?  Rep. Andy Levin (D-MI) introduced a resolution that would remove the exemption barring staffers working for individual members, committees and leadership offices to form a union.  To date, Levin’s resolution has garnered 165 cosponsors, all Democrats.  While this resolution would only apply to the House, Sen. Sherrod Brown (D-OH) has signaled interested in introducing a resolution for the Senate side.

Beyond this, next steps are unclear.  Levin’s resolution will require approval from both the House Committee on Administration and House Committee on Education and Labor, and even then, the measure needs the support of 61 additional Democrats before it can secure the 217 votes needed to pass the House.  On top of this, the resolution has some technical issues that will take a few weeks to address.  And while Levin’s resolution would face at least attainable odds of passing in the Democratically controlled House, any Senate resolution on collective bargaining would have little chance of garnering the 60 votes needed to override a filibuster.  No Republican senators have endorsed efforts to unionize, and Sen. Joe Manchin (D-WV) has voiced some skepticism about staffers forming unions.

However, Hill staffers are undeterred in their efforts to advocate for the ability to form unions.  As long as low pay and poor working conditions continue to be a fact of life for employees of congressional offices, staffers will continue to voice for changes to allow them to organize – even if the realization of those changes may be a long way off.

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Will We Need More Booster Shots?

People will only need annual COVID-19 booster shots after getting their third vaccine dose, according to a top Food and Drug Administration (FDA) official at the 2022 Innovation in Regulatory Science Summit in January 2022.  Since then, however, mounting evidence over waning immunity plus the potential of a new wave of COVID-19 are feeding calls for people to get their fourth vaccine doses sooner rather than later.  Does that mean Americans can expect to get a second booster shot in the coming months?

First, some Americans are already able to get a second booster shot.  According to guidance from the Centers for Disease Control and Prevention (CDC), people ages 12 years and older who are moderately or severely immunocompromised should receive a total of four mRNA vaccine doses.  This includes transplant patients and those undergoing chemotherapy for cancer.

Drug manufacturers are already asking for approval on second boosters for additional populations.  In mid-March, Pfizer and Moderna submitted applications to the FDA for an emergency use authorization (EUA) for a second booster dose of their respective COVID-19 vaccines.  While Pfizer is specifically seeking an EUA for adults over age 65, Moderna is requesting an EUA for anyone over 18 years of age.

The submission of both applications came just days after Pfizer CEO Albert Bourla said a fourth vaccine dose will probably be needed for everyone.

  • One reason for this is mounting data that shows protection acquired from a third COVID-19 vaccine dose wanes over time.  According to CDC data, a booster shot’s effectiveness in protecting against hospitalization dropped from 91% to 78% between August 2021 and January 2022 – a timeframe that includes both the Delta and Omicron variants.
  • Another reason for a fourth shot is a need to protect Americans ahead of a new wave of COVID-19 cases.  In recent weeks, a new Omicron subvariant known as BA.2 has driven an increase in cases across Europe, which many experts say could foreshadow an increase in cases in the US within the coming weeks.  Although BA.2 is roughly 30% more transmissible than the original Omicron strain, it does not appear to be more severe or lead to more hospitalizations.  While overall COVID-19 case numbers are still trending downward in the US, 10 states have reported an increase in case numbers over the last 14 days.

Due to these concerns over waning immunity and growing case numbers, nearly a dozen countries including Australia, Belgium, Denmark, Israel, Poland, Sweden, and the United Kingdom have already begun offering fourth doses, albeit eligibility is limited to seniors and medically vulnerable people in most cases.  Additionally, reports suggest the FDA could authorize second boosters for all adults over age 50 as soon as March 29.  However, that doesn’t necessarily mean the government will follow suit in recommending a fourth mRNA vaccine dose to every individual age 12 and up who’s already cleared to get a third dose anytime soon, as a couple issues stand in the way.  These include:

  • Regulatory approval.  The FDA’s vaccine advisory committee will meet on April 6 to discuss the need for additional COVID-19 booster shots.  However, the advisory panel will NOT be reviewing any EUA applications from Pfizer or Moderna or taking a vote on recommendations – instead, the committee will discuss the timing and populations for additional doses in the coming months.  The April 6 agenda is a sign of the federal government’s cautious approach to boosters, which means it might take some time for federal regulators to sign off on additional doses, especially for the broader population.  In September 2021, for instance, a CDC advisory panel declined to recommend third doses for people who work in “high-risk” settings like health care practitioners and teachers – a decision which was ultimately overruled by CDC Director Rochelle Walensky.
  • Data.  Even though a number of countries have already cleared fourth shots for certain populations, the jury’s still out on whether a second booster will make a difference for non-elderly adults who are not considered medically vulnerable.  Preliminary results from a study involving 154 health care workers in Israel found that a fourth mRNA dose is only “partially effective” in protecting against the Omicron variant.  Without any strong evidence of the effectiveness of a fourth shot, US regulators are likely to continue to take a cautious approach on recommending additional boosters for the broader population.
  • Funding.  Lawmakers dropped $15 billion in additional COVID-19 funding from the Fiscal Year (FY) 2022 omnibus appropriations bill, and so far, congressional leaders are locked in a stalemate on passing separate legislation on additional COVID-19 support.  Without additional funding, Biden administration officials have warned that they won’t have enough money to purchase a potential fourth vaccine dose for even 70% of all Americans.  And barring additional funding, the federal government will no longer be able to cover the cost of vaccinations for uninsured people starting on April 5, which means uninsured immunocompromised Americans may not be able to afford a booster if they need one.

Ultimately, the trajectory of the COVID-19 pandemic may ultimately inform whether additional boosters are necessary for Americans, and in turn, whether Congress decides to allocate enough money to pay for additional vaccine doses.  While White House Chief Medical Advisor Anthony Fauci has acknowledged that the BA.2 subvariant is likely to cause cases to rise in the UShe doesn’t anticipate new cases will culminate in a major surge that results in high levels of hospitalizations.

Indeed, a good portion of the US population has acquired some degree of immunity through infection, vaccination, or both over the last two years of the pandemic, which could protect Americas from the worst consequences if case numbers continue to rise over the next few weeks.  However, if hospitalizations suddenly spike across multiple populations, it may be too late for the federal government to act swiftly on additional boosters.

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