Over the past few months, Congress and the Department of Health and Human Services (HHS) have issued a wave of new health care-related requests for information (RFIs). These RFIs come at a time when the country is shifting to address deficiencies in the health care system COVID helped to expose.

CMS’ latest Physician Fee Schedule (PFS) proposed rule includes a health equity adjustment to quality performance, suggesting the federal agency recognizes inequities exist among ACOs serving safety-net populations, but is it the right approach?