2025 Data Collection Memo
January 30, 2025
As the new federal administration begins implementing its policy goals, there are many open questions about how these policies may impact collection and reporting of patient data. MSHIELD faculty and staff are staying informed of these updates and will continue to be a source of information and support to CQIs in their efforts to collect the best data possible for making informed decisions about quality improvement for patients in Michigan.
How do the current executive orders impact collection of race and ethnicity data?
At this point, there are no changes to the federal guidelines for collecting race and ethnicity data. The revised OMB guidance continues to inform MSHIELD’s best practices for the CQIs and to health systems across the state. This aligns with the Michigan Department of Health and Human Services plan to revise data collection guidelines for state programs, which is independent of the federal guidance. The 2025 P4P measure supported by BCBSM helps set goals for health care systems in the state to move toward a standard of data collection. These P4P goals are still active for 2025.
How do the executive orders impact the collection of sexual orientation and gender identity (SOGI) data?
Prior to the executive orders, there were no federal requirements for the collection of SOGI data, but guidance about best practices for patient care has been suggested by a number of organizations, including MSHIELD. At this time, we are not aware of any ban on collecting this data for non-federal hospitals or health systems, but we do anticipate that federal standards for reporting data may change to only include sex assigned at birth.
How do we address questions from health systems about changes in federal policies?
It is understandable that there may be questions and concerns raised by health systems and other entities within our state. If CQIs receive feedback or questions about the recommendations that MSHIELD has shared, it would be helpful to collect any relevant information, such as whether the health system received conflicting guidance, feedback from patients or staff, or faced other roadblocks to implementing data collection standards.
Please reach out to Matthias Kirch at kirchm@med.umich.edu with any questions or feedback. We realize that there may be changes to policies on a national and local level in the next months and years, and we will help you navigate these.