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Consensus among HHS agencies on addressing social determinants of Health Through Better Data Capture, Interoperability

July 15, 2021Nancy Halstead, Vicki J. TankleNo CommentsLexologySocial Determinants of Health (SDOH),Interoperability

Over the last decade, members of the medical and public health communities around the world have widely studied and acknowledged the impact of social determinants of health (SDOH)—the conditions in the environments where people live, learn, work, play, and age—on a wide range of health, functioning, and quality-of-life-risks and outcomes.[1] In the past year or so, U.S. federal government policy has made a fundamental shift to align with this notion, focusing in part on better integration of health data and human services data to realize improved health outcomes that patients experience.

This policy shift is highlighted in the U.S. Department of Health & Human Services’ (HHS’) 2020-2025 Federal Health IT Strategic Plan, and is underscored in the Biden Administration’s American Rescue Plan and other policy recommendations that include ways to address SDOH, particularly in the wake of the COVID-19 pandemic. Through these policies and legislative initiatives, we have seen HHS agencies, such as the Office for Civil Rights (“OCR”), the agency that enforces HIPAA, the Office of the National Coordinator for Health Information Technology (“ONC”), the agency charged with coordination of nationwide efforts to implement and use the most advanced health information technology and the electronic exchange of health information, and others, signal that use and disclosure of patient information for certain treatment and health care operations activities, namely care coordination and management, to address SDOH is not only permissible but encouraged at both the individual-level and the population-level.

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: American Rescue Plan, Data, data capture, Federal Health IT Strategic Plan, HHS, Interoperability, Notice of Proposed Rulemaking, NPRM, OCR, ONC, SDOH, United States Core Data for Interoperability, USCDI, USCDI version 2

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