2023 MIPS IA_AHE_8: Create and Implement an Anti-Racism Plan

Activity ID


Activity Weighting


Subcategory Name

Achieving Health Equity

Activity Description

Create and implement an anti-racism plan using the CMS Disparities Impact Statement or other anti-racism planning tools. The plan should include a clinic-wide review of existing tools and policies, such as value statements or clinical practice guidelines, to ensure that they include and are aligned with a commitment to anti-racism and an understanding of race as a political and social construct, not a physiological one.

The plan should also identify ways in which issues and gaps identified in the review can be addressed and should include target goals and milestones for addressing prioritized issues and gaps. This may also include an assessment and drafting of an organization’s plan to prevent and address racism and/or improve language access and accessibility to ensure services are accessible and understandable for those seeking care. The MIPS eligible clinician or practice can also consider including in their plan ongoing training on anti-racism and/or other processes to support identifying explicit and implicit biases in patient care and addressing historic health inequities experienced by people of color. More information about elements of the CMS Disparities Impact Statement is detailed in the template and action plan document at https://www.cms.gov/About-CMS/Agency-Information/OMH/Downloads/Disparities-Impact-Statement-508-rev102018.pdf.


Begin to address inequities in health outcomes by creating and implementing an anti-racism plan.

Suggested Documentation

Evidence of a practice-wide review and implementation of an anti-racism plan. Please note that, although the CMS Disparities Statement does not mention racism, it can be effectively used to facilitate the completion of the requirements of this activity. Include all of the following elements:

1) Review – Documentation of a practice-wide review of existing tools and policies; AND
2) Assessment memo – Completion of an assessment memo summarizing the results of the above review; AND
3) Anti-Racism Plan –A new or updated anti-racism plan, which includes actions, intended outcomes, and timeline for completion for the eligible clinician’s practice; this plan must identify ways in which issues and gaps identified in the review can be addressed and should include target goals and milestones, and the eligible clinician or practice should also consider including training on anti-racism to support identifying explicit and implicit biases in patient care and addressing historic health inequities experienced by people of color; AND
4) Plan Implementation – Report with results from implementing the new or updated anti-racism plan.


A practice-wide review indicated that existing website and human-resources documents do not mention a commitment to anti-racism or an awareness of racism in medicine, and that, in a decision aid used in the practice, heart failure risk is estimated lower for individuals socially identified as Black than for patients socially identified as White, potentially making Black patients less likely to seek and/or receive needed care. The practice updated its website and human-resources materials to reflect its commitment to anti-racism, and stopped using the heart failure risk decision aid that was biased against patients identified as Black, as part of a comprehensive anti-racism plan the practice developed and implemented.



  • CMS (healthequityTA@cms.hhs.gov) offers Health Equity technical assistance to organizations that would like support improving equity, including those who are using the Disparities Impact Statement: https://www.cms.gov/About-CMS/Agency-Information/OMH/Downloads/Disparities-Impact-Statement-508-rev102018.pdf
  • This 2018 article by Camara Phyllis Jones that details launching a National Campaign Against Racism with three tasks: 1) naming racism; 2) asking “how is racism operating here?” and 3) organizing and strategizing to act and an Anti-Racism Collaborative. “Toward the science and practice of anti-racism: Launching a national campaign against racism”: www.doi.org//10.18865/ed.28.S1.231
  • A 2021 study by Hassen et. al. describes a scoping review conducted to identify existing anti-racism interventions in healthcare settings and synthesize the key findings, challenges and unintended consequences of this work. “Implementing Anti-Racism Interventions in Healthcare Settings: A Scoping Review”: https://www.mdpi.com/1660-4601/18/6/2993/htm
  • A 2020 Health Affairs article by Olayiwola et. al. describes the process of making anti-racism a core value in health care and the four pillars of an anti-racist action plan. “Making Anti-Racism A Core Value In Academic Medicine”: https://www.healthaffairs.org/do/10.1377/hblog20200820.931674/full/
  • A 2020 Health Affairs article by Legha describes the five core components to an anti

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