New York has recently enacted updates to Public Health Law § 2802-b, mandating a Health Equity Impact Assessment (HEIA) for any Certificate of Need (CON) application that entails substantial changes in ownership, services, or location. This new requirement aims to evaluate how proposed projects will affect access to healthcare in underserved communities, while also necessitating strategies to address identified disparities. Applicants are expected to identify specific equity barriers, such as transportation issues, language accessibility, and relevant demographic data that goes beyond traditional geographic considerations when defining service areas.
This initiative in New York mirrors similar actions taken by other states like Illinois, California, and Maine, which have also integrated equity factors into their approval processes. Even in regions without obligatory HEIA frameworks, healthcare providers and investors are increasingly being held accountable for demonstrating how their proposals will improve access to care, reflect community demographics, and minimize adverse effects.
During a recent program, several core strategies for implementing HEIAs were discussed:
1. **Integrate HEIA Early**: As part of the CON preparation, prioritize HEIA from the beginning rather than treating it as an afterthought.
2. **Utilize Comprehensive Data**: When defining service areas, leverage credible sources like claims data or census maps instead of relying solely on ZIP code familiarity.
3. **Craft Actionable Strategies**: If disparities in access to healthcare are uncovered, it’s essential to develop specific and actionable plans to address these gaps. Mere promises of future oversight are no longer adequate.
4. **Anticipate Beyond HEIA Mandates**: Providers should prepare to address equity considerations even in states that do not yet have HEIA regulations, as these reviews are becoming increasingly integrated into the overall risk assessment for healthcare proposals.
5. **Reevaluate Project Planning**: Health Equity Impact Assessments should be viewed similarly to financial diligence or community relations — integral components of project development rather than simply compliance tasks. A robust HEIA can facilitate progress on proposals, while a lackluster assessment could hinder them.
In summary, as healthcare systems aim to improve access and equity, these evolving requirements present an opportunity for organizations to proactively enhance the quality of care provided to all communities. Embracing these changes can lead to more informed decision-making and better health outcomes for underserved populations.