NACHW Response to CMS Medicare Advantage program and Medicare Part B Payment for Services Involving Community Health Workers (CHWs)

NACHW has responded to an RFI (Request For Information) from the Centers for Medicare & Medicaid on the Medicare Advantage program (CMS-4203-NC) and Medicare Part B Payment for Services Involving Community Health Workers (CHWs) (CMS-1770-P).

NACHW has responded with recommendations that are informed by the experiences and input of our CHW
members who are employed across sectors, including clinical, behavioral health, social, and community-based organizations (CBOs). We apply an equity and social justice lens by prioritizing the lived experience of CHWs, rather than limiting our focus to “evidence” or “best practices” gathered from research interventions in well-resourced environments.

We believe the following recommendations are applicable across CMS:

1. Adopt the full APHA CHW definition and C3 scope of practice.
2. Promote equitable payment and pay CHWs for their lived experience.
3. Embrace CHW-driven evaluation and consult the National CHW Common
   Indicators (CI) Project2.
4. Eliminate funding barriers for CBOs that employ CHWs.

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