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  • Writer's pictureSean Libby

CMS Publishes Final Rule Mandating Special Needs Plans Screen for Certain SDoH Barriers

Updated: Jan 25, 2023

On May 9th CMS published its Final Rule for the Medicare 2023 Contract Year. In it, CMS took a significant step toward helping vulnerable Medicare members receive the help they need.

CMS addressed a series of comments and questions from its proposed rule to require Special Needs Plans (SNPs) to include questions regarding social risk factors in Health Risk Assessments (HRAs). Specifically, CMS had proposed that SNPs add sections gathering information regarding housing stability, food insecurity, and access to transportation.

This proposal reflected the broad understanding that “…many dually eligible individuals contend with multiple social risk factors such as food insecurity, homelessness, lack of access to transportation, and low levels of health literacy.” In the final rule, CMS cemented the requirement that SNPs include questions about these specific Social Determinants of Health (SDoH) barriers in their Health Risk Assessments.

“Building on CMS's experience with other programs and model tests, and with broad support from public commenters, we are finalizing a requirement that all SNPs include one or more questions from a list of screening instruments specified in sub-regulatory guidance on housing stability, food security, and access to transportation as part of their health risk assessments (HRAs).

The primary stated purpose of this requirement is to allow SNPs to incorporate this information into the overall plan of care for members:

“We posited that requiring SNPs to include standardized questions about social risk factors would be appropriate in light of the impact these factors may have on health care and outcomes for the enrollees in these plans and that access to this information would better enable SNPs to design and implement effective models of care.”

Of note, CMS is not yet publishing one specific set of questions, instead requiring “…SNPs to include one or more questions from a list of screening instruments specified by CMS in sub-regulatory guidance.” An example of these screening instruments is the “The Accountable Health Communities Health-Related Social Needs Screening Tool.”

This is a significant step forward in understanding the impact of SDoH barriers and helping at-risk people live their healthiest lives. To address an SDoH barrier a caring advocate must first uncover the challenge and work with the member to find a solution.

At BeneLynk, we applaud CMS moving to require the gathering of this information. We are encouraged by this direction as it shows CMS’s understanding of the need for SNPs to help address SDoH. As an example of how to incorporate SDoH barriers into the member’s plan of care CMS states that “a SNP could demonstrate this in several ways, consistent with its MOC [Model of Care], including making referrals to appropriate community partners.”

BeneLynk works on behalf of Dual Special Needs Plans (DSNP) members throughout the country, advocating for members to access the social program benefits they need to live their healthiest lives. We lead with help by asking members about their challenges and how we can be of assistance. We then document barriers systematically using Zcodes and surface solutions all in one dynamic conversation.

We also receive referrals to address SDoH barriers as a direct result of challenges uncovered during a Health Risk Assessment. This may mean helping a member apply for Supplemental Nutrition Assistance Program (SNAP) benefits or helping a dual enrolled senior with a Medicaid renewal. It might mean helping a veteran get access to a free transportation program or linking a disabled individual with housing assistance. We’re proud to do this work on behalf of DSNP members in every state in the nation. We know that helping members to overcome these fundamental barriers is one of the most impactful services a SNP can provide.

About the Author

Sean Libby has been an advocate for seniors, people with disabilities, veterans, and individuals with low income for over 19 years. At BeneLynk, we are committed to helping managed care plans to deliver superior Social Determinant of Health solutions to their members. We are always looking to learn more and would like to hear your ideas on how best to assist members in need. Drop us a note at

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