The Who and What of Health Disparities Statement

In November 2010, Secretary Kathleen Sebelius charged the Department of Health and Human Services (HHS) with developing a Department-wide action plan for reducing racial and ethnic health disparities. This HHS Disparities Action Plan was developed through a collaborative, Department-wide process that actively engaged all HHS agencies. The action plan emphasized approaches that are evidence-based and that would achieve large-scale impact. The action plan was to be operational across HHS immediately. The vision of the HHS Disparities Action Plan is: “A nation free of disparities in health and health care.”

The HHS Disparities Action Plan proposed a set of Secretarial priorities, pragmatic strategies, and high-impact actions to achieve Secretary Sebelius’s strategic goals for the Department. The five goals from the HHS Strategic Plan for Fiscal Years (FY) 2010-2015 provide the framework for the HHS Disparities Action Plan. They are:
I. Transform health care;
II. Strengthen the nation’s Health and Human Services infrastructure and workforce;
III. Advance the health, safety, and well-being of the American people;
IV. Advance scientific knowledge and innovation; and
V. Increase the efficiency, transparency, and accountability of HHS programs.

The fourth goal of advancing scientific knowledge and innovation was in response to a recent Institute of Medicine Subcommittee on Standardized Collection of Race/Ethnicity Data for Healthcare Quality report that emphasized that the inadequate data on race, ethnicity, and language lowers the likelihood of effective actions to address health disparities. The report also impressed how enhanced and standardized data on the race, ethnicity, and language spoken by patients and other users of the healthcare system would allow better understanding of the barriers faced by racial and ethnic minority populations.

In translating the secretarial policy to practice, HHS is improving the monitoring and collection of health data by race, ethnicity, sex, primary language, and disability status, and is planning for the collection of additional health data. These efforts are helping researchers, policy makers, health providers and advocates to identify and address health disparities afflicting vulnerable communities. Better data can help researchers understand and eliminate health disparities by helping to identify areas of need and intervene more appropriately.

In order to assess and heighten the impact of all HHS policies, programs, processes, and resource decisions to reduce health disparities, HHS leadership will assure that: (c) Program grantees, as applicable, will be required to submit health disparity impact statements as part of their grant applications.

In translating this policy into practice the Substance Abuse and Mental Health Services Administration (SAMHSA) expects grantees to utilize their data to (1) identify subpopulations (i.e., racial, ethnic, sexual/gender minority groups) vulnerable to disparities (2) develop a disparities impact statement and (3) implement strategies to decrease the differences in access, service use, and outcomes among subpopulations. These strategies should include the use of the National Standards for Culturally and Linguistically Appropriate Services (CLAS) in Health and Health Care. Hence the current Planning Grants for Expansion of the Comprehensive Community Mental Health Services for Children and their Families (Short Title: System of Care Expansion Planning Grants) have the requirement of submitting a health disparity impact statement.

SAMHSA’s focus is on differences in access, use, and outcomes in grant programs. The requirement for the Disparity Impact Strategy comes from SAMHSA’s strategic initiatives around data, outcomes, and quality.

Some of the Technical Changes to RFA – RFA language are for example:
Statement of Need:Discuss the relationship of your population of focus, including sub-populations, to the overall population in your geographic catchment area and identify sub-population disparities, if any, relating to access/use/outcomes of your provided services citing relevant data. Demonstrate an understanding of these populations consistent with the purpose of your program and intent of the RFA.

Implementation of DIS Statement & Action Plan: “Clearly state the unduplicated number of individuals you propose to serve (annually and over the entire project period) with grant funds, including the types and numbers of services to be provided and anticipated outcomes.” (including subpopulations as described in Section A.)

Performance Assessment & Data: “Describe the data driven process by which changes in sub-population disparities if any in access/use/outcomes of your provided services will be tracked and assessed. Describe how data will be used to manage the project and assure continuous quality improvement including consideration if any of access/use/outcomes disparities of identified sub-populations.”

Sources:

1. HHS Action Plan to Reduce Racial and Ethnic Health Disparities: A Nation Free of Disparities in Health and Health Care: http://minorityhealth.hhs.gov/npa/files/Plans/HHS/HHS_Plan_complete.pdf

2. The SAMHSA Behavioral Health Disparities Impact Statement and the TA Partnership Blueprint for Reducing Disparities/ Disproportionalities: http://cfs.cbcs.usf.edu/projects-research/_docs/20130924_BlueprintWebinarSlides.pdf