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Association Submits Feedback on Disparity Methods

In a Nov. 30 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals expressed concerns about two disparity methods developed to report readmission rates among patients with social risk factors.

The letter responds to a CMS request for feedback on the methods, which compare 30-day readmission rates for pneumonia by race and among patients dually eligible for Medicare and Medicaid.

In its comments, America’s Essential Hospitals urged CMS to:

  • continue its work to identify and eliminate disparities in care by engaging all stakeholders, particularly those that disproportionately serve patients with social risk factors;
  • ensure that any methodology used to highlight disparities in quality of care account for differences among hospitals, as well as social risk factors, beyond dual eligibility and race, that might affect health outcomes;
  • continue to refine its methodology for reporting disparities to improve the usefulness to hospitals, resolve data lag issues, and ensure future reporting is accurate and meaningful;
  • refrain from publicly reporting disparity scores to avoid misleading or confusing consumers as they make individualized care choices; and
  • give hospitals flexibility to shape their quality improvement programs to best and most efficiently serve the needs of their patients

CMS extended the deadline for comment submission to Dec. 14. Comments should be emailed to

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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