Thoughts on CMMI’s Transforming Maternal Health (TMaH)

I am thrilled to see the innovations coming out of CMS/CMMI associated with true, Whole Person Care (WPC). CMMI’s Transforming Maternal Health (TMaH) focuses on the interconnectedness of a woman's pre and postpartum physical, mental, and social well-being, rather than treating isolated symptoms or conditions. While WPC has gained recognition and momentum in the traditional medical community, it has primarily been focused on individuals who have complex medical issues (Diabetes, Congestive Heart Failure, COPD) coupled with a behavioral health and/or substance use disorder (BH/SUD). That focus has now expanded into Maternal Health, not a moment too soon.

And let us not forget a critical approach to a child’s own mental health and wellbeing.  Addressing a Mom’s own needs, Maternal Health is one of the best forms of prevention. 

An often-overlooked population when discussing WPC has been women who are pregnant or postpartum.  TMaH focuses on these women, aimed to improve outcomes, reduce healthcare disparities and lower the medical spend.  As part of TMaH, integrated clinical practice patterns and operational workflows will be developed amongst community providers and care teams, along with testing alternative payment models.  Key pillars in this work are building the operational infrastructure, improving access to care and expanding the care delivery workforce; adding midwives, doulas, perinatal community health workers (CHWs) in delivery of culturally driven care.  For WPC and alternative payment models to be implemented successfully, communities must improve their data collection and information sharing amongst all providers and other social service organizations.  

CMMI has awarded 15 states up to $17 million dollars each, distributed over a span of 10 years.  During this time the states have a 3-year Pre Implementation phase and a 7-year period to execute fully.  Additional elements in the model include addressing Quality Improvement and Safety, as well as:

• customizing care plans based on medical, behavioral, and social needs

• routine screening for mental health, substance use, and health-related social needs (HRSNs) and

• leveraging telehealth and home monitoring for high-risk pregnancies.

A critical aspect to delivering on WPC lies in improving states’ outdated data collection methods and improving the gaps in information-sharing among providers, Community Based Organizations (CBOs), and other agencies.  And while states are expected to enhance data collection, exchange, and linkage through improvements in electronic health records and health information exchanges, many of the 15 awardees have yet to exchange any BH/SUD data.   The opportunity to advance this area of data exchange has finally come, but it will take a great deal of stakeholder education, engagement, business process re-design and “myth-busting” as it relates to the privacy and security safeguards BH/SUD data has been associated with. 

To date there are limited examples where BH/SUD data is being made interoperable, yet there are platforms in most communities that are fully capable of doing so.  Technology advancements are out there and the true effort to make WPC happen within each community in determining how to fully execute on a strategy.  These initial planning years will include strategizing on how to leverage existing coalitions and build upon current resources and technology innovation.  Yet, the last mile of interoperability is still ahead for most of the 15 states,  how to bridge the WPC gap through BH/SUD data exchange. 

Having been part of communities and states who have successfully exchanged BH/SUD data, I can confidently say solutioning exists.  I would strongly encourage TMaH leaders to begin planning for this essential component now.  New 42 CFR Part 2 privacy rules for exchanging SUD data will go into effect in 2026.  These changes will require extensive education and TA to ensure practitioners and operational staff are both informed and properly using newly compliant forms and the technology associated. 

The TMaH interoperability project workstreams will likely result in a “peeling back the onion” phenomenon where unexpected findings come to light and barriers must be busted along the way.  With that in mind, it’s important to note that the 3 years of planning for this system transformation can go by really fast.