Response to Make Your Voice Heard: Promoting Efficiency and Equity Within CMS Programs RFI

Topic 3: Advancing Health Equity: Recommendations for how CMS can promote efficiency and advance health equity through our policies and programs.

Thank you for your work and your dedication to advancing health equity. CEO Action for Racial Equity (CEOARE) is a Fellowship of more than 100 signatory organizations that mobilizes a community of business leaders to identify, develop, and promote scalable and sustainable public policies and corporate engagement strategies that will address systemic racism and social injustice and improve societal well-being. We appreciate the opportunity to share comments on strategies to address health inequities.

As stated by the CDC: “Racism—both interpersonal and structural—negatively affects the mental and physical health of millions of people, preventing them from attaining their highest level of health, and consequently, affecting the health of our nation.”¹ That is why on April 8, 2021, the CDC declared racism a public health threat², in addition to more than 250 state and local leaders—including 50-plus health and public health entities³. CEOARE urges CMS to join the CDC by declaring racism a public health crisis.

Declaring racism a public health crisis is not just a matter of semantics. The elimination of health disparities cannot be achieved without first acknowledging the significant and detrimental impact structural racism contributes to health and social inequities, particularly for Black Americans. Consequently, CMS should make a commitment to address structural racism holistically, as it would any other public health crisis. Continuing to address structural racism one disparity at a time may only result in piecemeal results. Declaring racism a public health crisis can help to create sustainable strategies to drive resource allocation and actionable commitments to advance health equity, positively impacting larger numbers of people.

Here are two examples of how declaring racism a public health crisis has sparked action⁴:

On August 4, 2020, the Buncombe County Board in North Carolina unanimously approved a resolution that includes a commitment to assess and revise all portions of codified health regulations through a racial equity lens. That was followed by the adoption of a Racial Equity Action Plan in July 2021, developed by a workgroup tasked with creating timelines, performance measures, and a public dashboard to track progress⁵.

As part of Boston’s declaration on June 12, 2020, then-Mayor Martin Walsh directed approximately $3M in the FY21 Budget Resubmission to the Boston Public Health Commission for its work related to reducing racial health disparities.

Declaring racism a public health crisis can alert the 170M+ members covered by CMS programs,⁶ 1.9M CMS providers⁷, and 6K+ CMS federal employees⁸ that health inequities stemming from structural racism are unacceptable and will be redressed by CMS.

We thank CMS for considering declaring racism a public health crisis to help further advance health equity for Black Americans, who face disproportionate negative health outcomes⁹ and barriers to quality healthcare.¹⁰

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Citations

[1] “Racism and Health,” Centers for Disease Control and Prevention, last modified December 14, 2021, https://www.cdc.gov/healthequity/racism-disparities/index.html.
[2] “Media Statement from CDC Director Rochelle P. Walensky, MD, MPH, on Racism and Health,” Centers for Disease Control and Prevention, last modified April 8, 2021, https://www.cdc.gov/media/releases/2021/s0408-racism-health.html.
[3] “Racism Is a Public Health Crisis,” American Public Health Association, accessed September 24, 2022, https://www.apha.org/topics-and-issues/health-equity/racism-and-health/racism-declarations.
[4] “Racism as a Public Health Crisis: From Declaration to Action,” American Public Health Association, accessed October 27, 2022, https://endingracism.apha.org/.
[5] “Racial Equity Action Plan,” Buncombe County North Carolina (July 1, 2021),  https://www.buncombecounty.org/common/office-equity-human-rights/racial-equity-plan.pdf.
[6] CMS Framework for Health Equity, CMS.gov, Centers for Medicare & Medicaid Services, last modified October 28, 2022, https://www.cms.gov/about-cms/agency-information/omh/health-equity-programs/cms-framework-for-health-equity.
[7] “CMS Fast Facts,” Data.CMS.gov, Centers for Medicare & Medicaid Services, https://data.cms.gov/fact-sheet/cms-fast-facts.
[8] “Financial Report: Fiscal Year 2021,” Centers for Medicare & Medicaid Services (November 2021), https://www.cms.gov/files/document/cms-financial-report-fiscal-year-2021.pdf.
[9] “Profile: Black/African Americans,” Office of Minority Health, HHS, last modified October 12, 2021, https://www.minorityhealth.hhs.gov/omh/browse.aspx?lvl=3&lvlid=61.
[10] “Disparities in Health Care Quality Among Racial and Ethnic Minority Groups,” Agency for Healthcare Research and Quality, April 2011, https://www.ahrq.gov/sites/default/files/wysiwyg/research/findings/nhqrdr/nhqrdr10/minority.pdf.