5 Key Health Equity Impact Assessment Components

New York enacted legislation last year requiring healthcare providers to contract with a third-party, referred to as an independent entity, to define if and how some proposed projects will impact health equity. Hospitals, ambulatory surgery centers and other facilities must now, for many projects, provide a Health Equity Impact Assessment conducted by an independent entity as part of their Certificate of Need application.

To help your organization complete these new requirements, we've highlighted five essential HEIA components. Read on for a distilled HEIA summary. Plus, learn how experienced assessment partners can facilitate successful expansion, amplify the community’s voice and improve health equity. 

Health Equity Impact Assessment requirements

Effective June 22, 2023, hospitals, ASCs and other Article 28 facilities in New York state must submit HEIA documentation with their CON applications. For projects requiring an HEIA, providers’ contracted independent entities must use the DOH’s HEIA template to describe:

• the project’s scope and impact;
• how the organization will mitigate health inequities for medically underserved populations; and
• how the organization will monitor and disseminate information about their projects.

One of the purposes of the HEIA is to identify health inequalities and disparities. From there, organizations can address public health issues in their CON applications, further advancing health equity and improving health.

The state’s goal is to better shape healthcare delivery to advance equity and achieve the highest level of health across the state, specifically:

• achieving health equity across underserved populations;
• removing potential discriminatory practices/barriers; and
• positively affecting the health of communities that need it most.

Use these HEIA five fast facts to get the full overview of the guidelines.

Your step-by-step HEIA guide

1.   Scoping

Independent entities must use state-defined HEIA Data Tables to identify populations impacted by the provider’s CON. These data must:

• capture the impacted service area;
• include the impacted demographics, e.g., employment, education, transportation; and
• identify medically underserved populations.

Data on medically underserved populations include age; income; race, gender and sexual orientation; disabilities and other medical vulnerabilities; and other socioeconomic factors, such as immigration and insurance coverage status. These data can be difficult to collect and maintain. The regulation requires the independent entity to obtain and interpret these data to prevent the likelihood of introducing bias into the assessment.

Additionally, within the HEIA, an independent entity must identify how a CON project will impact every medically underserved population identified. It should also explain how the population used services before and will use services after the project.

2.   Potential impacts

Section 400.26, Title 10 New York Codes, Rules and Regulations, requires CON applicants to identify whether and how a facility’s proposed project will impact healthcare access and service delivery, particularly for medically underserved groups.

On behalf of hospitals, ASCs and other Article 28 facilities, independent entities must identify how the project will affect access to care. They also must identify overall equity and disparities across all underserved populations. Examples include impacts on indigent care, transportation and mobility.

DOH also requests answers to the following questions:

• Were stakeholders engaged?
• If so, which ones and did these include local health departments?
• How was the community informed of the HEIA and its impacts?

This helps describe community engagement around the project. In each case, the HEIA must describe the independent entity’s role in the process.

3.   Mitigation

CON applicants must use evidence-based approaches to mitigate project impacts and amplify positive outcomes. HEIA requirements here span engagement and communication with non-English speakers, those with impairments and all medically underserved groups that the project will impact. If feedback identifies better mitigation strategies, state law requires that the HEIA include them.

4.   Monitoring

A provider’s CON impact mitigation strategies must be put into practice. In their HEIAs, facilities must document how they will monitor their project’s impacts on affected populations. DOH requires providers to identify new and existing strategies to minimize negative effects based on HEIA findings. Monitoring and mitigation steps are two more areas where the independent entity can provide invaluable objective input.

5.   Dissemination

According to the state, the public posting of documents goes as follows:

“When an HEIA is filed with a CON application, the applicant must provide a full version of the application and a version with proposed redactions. The applicant is required to post the redacted CON application and the HEIA on its website within one week of acknowledgement by the NYSDOH, and until a decision on the application is rendered by the Public Health and Health Planning Council or the Commissioner of NYSDOH. The Department will also publicly post the redacted CON application and the HEIA on the NYSE-CON system within one week of the filing.”

Key takeaways: Providers must post their redacted CON application and HEIA publicly within one week of acknowledgment by DOH. DOH will also post the redacted documents publicly within one week of the filing.

Turn to a partner you already trust

DataGen is an HEIA analytics subcontractor of Chartis, an experienced independent entity. DataGen already provides analytics-first support to hospitals and health systems across New York and the U.S. Contact us today for a free HEIA consultation and learn how we can support your health equity efforts every step of the way.