Eric Fontana:
Hi. My name is Eric Fontana. I'm the Vice President of Client Solutions with Optum Life Sciences. I devoted the last 15 years of my career to serving hospital and health system leaders with Advisory Board and Optum. A lot of that work involved teasing apart data to help understand the impact of hospital inpatient and outpatient regulations, revenue cycle, and margin performance. I'm here on Radio Advisory to give you my take on the 2023 proposed rule, and I'd like to share my thoughts with you. Nowadays, I spend much of my professional time helping life science organizations, large and small, advance their mission of innovation through the provision of real world data, or as health systems more commonly call it, just data. I'll apologize in advance for my erroneous pronunciation of the word, data. Apparently, I've been saying it wrong for the best part of 40 years. You'll just have to bear with me on that one.

Eric Fontana:
I'm not going to pretend that the mere mention of the CMS proposed IPPs rule each year doesn't provoke a sympathetic nervous system response, akin to encountering an unsociable tiger snake in long grass as an eight year old. Nevertheless, I bravely skimmed the highlights of this year's 2023 proposal during some recent downtime. To me, the single most interesting aspect of the proposal was CMS's provision for hospitals to complete a five domain health equity attestation. Now, data nerds will rejoice at domain two. That's a data collection condition that would require providers to attest that their organization is capturing social determinant of health measures, including entering them as structured elements into an EHR. On the surface, a simple attestation may seem relatively low-impact, no big deal. However, such a provision is potentially more important than some may think. To me, the proposal has a similar aroma to hospital quality measures circa 2007 to 2009.

Eric Fontana:
Back then, pay for performance was a pipe dream. Merely reporting quality measures was a massive step forward. When pay for reporting finally came about, the industry initially sputtered its way through numerous metric additions, subtractions, and revisions, but eventually hit its stride into a relatively robust set of measures 10-plus years later, measures that have been pivotal to advancing some important quality based research over the years. So, with that historical precedent in mind, the health equity domain proposal provides, at least to me, a clearer path to a vastly more scaled, dynamic, and standardized set of social determinants of health data than exists today. That would be a veritable game changer for researchers, [inaudible] real world data, of course, and subsequently, patients and providers in years to come.

Eric Fontana:
While such a proposal is unlikely to satiate the industry appetite for better visibility into social determinants overnight, if finalized, CMS's proposal will lay some important groundwork that should eventually ripple through to commercial and Medicare Advantage patient data. I'm also hopeful that CMS's experience evolving quality measures means we're in somewhat of an evolutionary express lane this time around. That's a pretty cool development for researchers who should be delighted with this direction. For what it's worth, that's a much more soothing thought than a chance encounter with a fairly venomous territorial reptile.