data that CMS should collect. Under this authorization, CMS’s Office of Minority Health is working to incorporate data standards related to LGBT health into the agency’s data collection efforts. He also noted that CMS oversees the Medicare and Medicaid Electronic Health Records (EHRs) Incentives Program that provides incentives to providers for the meaningful use of EHRs. The standards for meaningful use of electronic health records are being released in stages. In August 2012, CMS issued its final regulations for the second of three states of the meaningful use incentive program.

During the public comment period for the Stage 2 meaningful use regulations, there was overall public support for including LGBT data as part of the overall demographic objective, with the majority of the comments supporting an optional versus required criteria. There was concern, Tagalicod noted, over the sensitive nature of collecting this information and over widespread collection by administrative staff. And a significant number of comments questioned the clinical benefit of collecting the information.

In the end, the final Stage 2 rule did not include the collection of LGBT data, as there was concern over the lack of consensus on definitions and on the standards for structured data entry for gender identity and sexual orientation. In addition, there was concern about the applicability to all of the various eligible professionals, eligible hospitals, and so-called Critical Access Hospitals regarding their scope of practice. Going forward, said Tagalicod, CMS needs to settle on a usable structured data definition and the terms used in that definition. It also needs to develop a way to integrate that data into a data collection system that incentivizes the use of those data and does not merely set off a wave of box checking. The goal should be better care and better health, at a lower cost, without endangering the patient or negatively impacting the quality of that care.


The mission of the Health Resources and Services Administration (HRSA), said Sylvia Fisher, is “to improve health and achieve health equity through access to quality services, a skilled health workforce, and innovative programs.” She noted that HRSA is committed to addressing the health care needs of LGBT communities. Accordingly, data collection and program policies are continuously reviewed to ensure that HRSA programs address LGBT health care disparities to the fullest extent possible. As a result of these reviews, the agency revised its funding applications to state explicitly that all LGBT populations are a service population of focus. Language was also included specifying that community health

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