By Tiffany Ferguson, LMSW, CMAC, ACM
In a significant policy reversal, the Centers for Medicare & Medicaid Services (CMS) has proposed significant changes that would roll back many of the Social Determinants of Health (SDoH) and equity-related reporting requirements previously embedded into quality programs across acute and post-acute settings. Announced late on April 11th, the FY 2026 IPPS and LTCH proposed rule signals CMS's alignment with Executive Order 14192, "Unleashing American Prosperity Through Deregulation" which prioritizes administrative simplification and cost reductions. For case managers, social workers, and population health teams who have invested in building workflows around SDoH screening, this proposal represents a disruptive shift.
CMS is proposing to remove four key measures from the Hospital Inpatient Quality Reporting (IQR) Program starting with the CY 2024 reporting period (impacting FY 2026 payments):
- Hospital Commitment to Health Equity – A structural measure assessing hospital-level leadership and community engagement in advancing equity.
- COVID-19 Vaccination Coverage Among Healthcare Personnel – Once vital for post-pandemic accountability.
- Screening for Social Drivers of Health – Designed to standardize the identification of patient challenges in housing, food, transportation, utilities, and personal safety.
- Screen Positive Rate for Social Drivers of Health – Quantified how often patients responded to the screening questions.
In post-acute settings, the rollback is just as pronounced. CMS is proposing to remove four SDoH Standardized Patient Assessment Data Elements (SPADEs) from both the IRF-PAI and LTCH instruments by FY 2028, eliminating data fields for:
- Living Situation (R0310)
- Food (R0320A and R0320B)
- Utilities (R0330)
These elements were implemented to enhance discharge planning and guide resource connections for medically and socially complex patients. Their removal would not only unwind much of this work but also create inconsistency across the care continuum.
For professionals on the frontlines of case management, this rollback raises some concerns. Many hospitals have embedded SDoH screening into admission assessments, transitional and care planning, and care coordination protocols. Removing these measures without offering transition guidance will create some ethical considerations. While CMS cites "burden" as a rationale, the social needs of patients remain unchanged. SDoH risk factors continue to influence readmissions, care plan adherence, and health outcomes, whether they're federally mandated for tracking. It is understood that these measures are clunky, however they did provide tangible data to drive equity-informed interventions, community partnerships, and funding justifications.
In place of concrete SDoH metrics, CMS issued a Request for Information (RFI) titled "Consideration for Future Years in the Hospital IQR Program: Well-Being and Nutrition." This suggests a pivot from health equity, and SDoH, towards a general focus on overall well-being, and nutritional practices. It is unclear how this framing will capture the broader social risk profile hospitals have worked to measure.
Public comment on the proposed rule is open. Now is the time for hospital case managers, social workers, and leaders in care management to weigh in. Our field has long advocated for the visibility of social risk factors in shaping outcomes, reimbursement, and quality measures.
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Bio: Tiffany Ferguson, MSW, ACM, CMAC is CEO of Phoenix Medical Management, Inc. Tiffany serves as an adjunct professor at Northern Arizona University, Department of Social Work, and on the American College of Physician Advisors (ACPA) Observation Committee. Tiffany is co-author of The Hospital Guide to Contemporary Case Management through HcPro. She is a contributor for RACmonitor and Case Management Monthly; she also serves on the editorial board for CMSAToday and Care Management. She is a weekly correspondent on SDoH for the news podcast Talk Ten Tuesday. After practicing as a hospital social worker, she went on to serve as Director of Case Management and quickly assumed responsibilities in system level leadership roles in Health & Care Management, which includes CM, UR, CDI, HIM, and coding. She has held C-level responsibility for a large employed medical group which included value-based arrangements and outpatient care management. Tiffany is a graduate of Northern Arizona University and received her MSW at UCLA.