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Opportunity to Respond to AHRQ's Climate and Health RFI (October 31st)
I wrote this to call attention to the Agency for Healthcare Research and Quality's (AHRQ's) first ever solicitation regarding the agency, finally, addressing the climate crisis. Please review and moreover please forward your comments to AHRQ - that are due December 13th.
Over the past several decades federal healthcare policy makers, aided and abetted by the healthcare industry, have ignored the climate crisis. Because the US is historically the largest emitter of greenhouse gases at 25%, US climate nihilism largely explains why today all life on earth is exposed to irreversible harm for the foreseeable future. Though AHRQ, or AHCPR, should have addressed the climate crisis 30 years ago, on October 13 the agency posted a one-page RFI titled, “AHRQ’s Role in Climate Change and Environmental Justice.” Considering the late date, the RFI’s publication is heartbreaking. Simultaneously, however, it is impossible to overstate the opportunity the RFI presents for the healthcare industry.
Current State of Federal Climate-Crisis Programming
First, it is important to note the US healthcare industry’s carbon footprint accounts for 550 metric tons of carbon equivalent emissions, or 8.5% of total annual US carbon emissions. The health harm caused by the industry’s emissions is commensurate with upwards of 98,000 US deaths annually and three times this number globally. If US healthcare was its own country, it would rank 13th worldwide in carbon emissions.
On balance, the federal government today is nowhere regarding climate crisis-related health policy. Among other realities if you search CMS’s website for “climate change” you get zero results. This is true in part because despite the all-of-government rhetoric about addressing racial equity, CMS made no mention of the disproportionate effects the climate crisis is having on minority communities in its ubiquitous use of health equity RFIs in this year’s rulemaking. Like COVID, the climate crisis, in effect environmental racism, significantly worsens health inequality. Nevertheless, the HHS Office of Civil Rights has also done nothing to protect Medicare and Medicaid beneficiaries right to a healthy environment. This assumes they have this right since in 2020 the 9th Circuit ruled in the Juliana case that Americans do not have a constitutional right to a survivable climate.
NIH’s interest in the climate crisis has been only slightly better. Between 2013 and 2020 NIH spent a cipher of its budget, 0.55%, on climate change and climate related exposures and conditions. MedPAC and MACPAC, both with broad authority to recommend Medicare and Medicaid policy improvements, have never discussed the issue. Neither has PCORI. As for related others, healthcare foundations, for example the Commonwealth Fund, Kellogg and RWFJ with $20 billion in total endowment funds, ignore the topic. As have many health research journals and media outlets. When two hundred health journals throughout the world recently called on world leaders to address climate crisis-caused catastrophic harm, Health Affairs and JAMA were not among them. Health Services Research has never published a single related article and Kaiser Health News, Politico Pulse and related others are indifferent. As for clinician involvement, a recent survey found 41% said they lacked subject knowledge expertise to communicate with the public. This is in part due in part to the fact that only 15% of medical schools include climate crisis health effects in their curriculum.
Addressing the Problem
The only ongoing HHS program addressing the climate crisis is the CDC’s Climate and Health Program that currently funds just eight states to improve their climate resiliency. Leaving aside the considerable financial challenged associated with successfully building resiliency, recognizing the need for more expansive programming HHS announced in late August it was standing up the Office of Climate Change and Health Equity (OCCHE). One month later, the National Academy of Medicine publicly launched an action collaborative, co-chaired by OCCHE, to decarbonize the healthcare sector and to strengthen the sector’s sustainability and resilience. To support these efforts, AHRQ has now followed up with its RFI.
Again, AHRQ’s RFI presents a significant opportunity for the healthcare industry. The RFI requests comments on 11 questions regarding climate-related health effects including: what role should AHRQ play in identifying, gathering and disseminating climate-related health risks and impacts; what are the most pressing health care-related research and actions AHRQ should address; and, what role should AHRQ play in developing related practice improvement resources and education and training tools. Comments in response to AHRQ’s RFI are due December 13.