This approach is backward. It should not be the sole responsibility of health care clinicians to gather, manage and share these data with outside organizations. This will result in an unacceptable burden on clinicians and HCOs. A better approach would be to make the social service agencies and other similar organizations responsible for gathering, managing and sharing these assessments. These groups have the responsibility for directly acting on these data.

Clinicians should be recipients of SDOH assassments. Not all people with social risks seek healthcare services. The social agencies may know about them, but the healthcare system may not. Not all patients are willing to discuss social risks, and some my not tell the truth on survey instruments. Depending on clinician-collected data to tell the full story of SDOH in the population is inappropriate.

Further, each provider that a patient sees should not have to go through a duplicative effort to perform and manage the same SDOH assessmentsa. The data should be readily available to providers in all healthcare settings.

The US public health system has been building immunization registries for over 20 years. This is a better model for the management of SDOH screening data.

Existing Wording:

“This IG addresses the need to gather SDOH information in the context of clinical encounters and describes how to share SDOH information and other relevant information with outside organizations for the purpose of coordinating services and support to address SDOH related needs.”

(Comment 177 - imported by: Robert Dieterle)