On April 18, 2024, the Department of Health and Human Services’ (HHS’) Agency for Healthcare Research and Quality (AHRQ) issued the Digital Healthcare Equity Framework (the Framework) to guide users and stakeholders to consider equity throughout the entire lifecycle when implementing digital healthcare solutions. AHRQ also released a separate implementation guide (the Guide) to outline best practices and examples to implement the Framework. The Framework’s guiding principles provide a clear purpose for the Framework and development of its domains while the separate Guide provides actionable steps on how to implement the Framework.

Digital healthcare developers and vendors, health systems, health plans, and clinical providers should review the Framework and Guide to assess equity during each phase of the digital healthcare lifecycle for digital health technologies. Specifically, the Framework recommends that these stakeholders should consider the Framework’s principles and recommendations to address the accessibility, purpose, security, privacy features, usability, and safety concerns applying to digital solutions.

The Framework

According to AHRQ, although there are considerable opportunities for digital healthcare technologies, substantial disparities due to race, ethnicity, geographic location and socioeconomic status still exist in access to and utilization of healthcare services.  To advance digital health equity and ensure that disadvantaged communities are not left behind, the Framework has been designed to specify the aspects that need to be considered in this systematic and intentional approach to digital healthcare equity.

This consensus-based Framework was prepared by researchers at the Johns Hopkins University for AHRQ based on review of existing literature and interviews with technical experts. The Framework is designed as a tool to help users and other stakeholders intentionally consider equity during each phase of the digital healthcare lifecycle: 1) the planning and development phases (e.g., for digital healthcare developers and vendors); 2) the acquisition phase (e.g., for a health plan); and 3) the implementation/maintenance and monitoring/improvement/equity assessment phases (e.g., for health systems or provider practices). Additionally, the Framework addresses three domains, including Patient and Community Characteristics, Health System Characteristics, and Health Information Technology Characteristics, with eight subdomains.

The Framework outlines six principles:

  1. Ensure digital healthcare solutions that involve digital technologies ameliorate, not exacerbate, inequities;
  2. Represent equity through person-centeredness;
  3. Encourage inclusivity and participatory creation of digital healthcare solutions;
  4. Support effective implementation in diverse settings;
  5. Ensure specific attention to policy/regulatory relevance or impact of the proposed solutions; and
  6. Focus on impact and outcomes for patients, health systems, and communities.

The Guide

Published separately from the Framework, the Guide provides a step-by-step path for users, including digital healthcare developers and vendors, health systems, health plans, and clinical providers, who want to implement the Framework. The Guide includes general recommendations that organizations should adopt to start on the path toward equity in digital healthcare solutions, including focusing on organizational readiness (e.g., by performing an organization self-assessment); identifying an equity champion to help develop a business model and assess the economic sustainability and impact of the equity intentionality approach; developing a diverse workforce; ensuring that equity assessments and feedback loops are built in to processes related to healthcare solutions that involve digital technologies; and tracking equity as part of organizational metrics.

We have outlined specific recommendations in the below table.

Stakeholders (Digital Healthcare Lifecycle Stage)Recommendations
Digital Healthcare Developers and Vendors (Planning and Development Phases)Identify and engage potential users of the digital healthcare solution, particularly those in historically marginalized demographic groups, to ensure it will meet the needs of the intended audience.

Understand the cultural characteristics and beliefs of the communities for which a digital healthcare solution is proposed to identify potential barriers to using the proposed solution.

Consider the impact of the proposed solution on digital equity in access, quality, and continuity of care in distinct healthcare settings.

Assess whether the proposed solution serves as a facilitator (versus a barrier) to accessing and receiving high-quality care.

Assess the technical characteristics of the proposed solution and whether those meet the current needs of potential users.

Ensure that data are used equitably and transparently during the creation of a proposed solution and when a solution is capturing, generating, or transmitting data.
Health Systems, Health Plans, and Clinical Providers (Acquisition and Implementation/Maintenance Phases)Adopt a digital inclusion-informed strategy regarding the acquisition, implementation, and maintenance of healthcare solutions that involve digital technologies to reduce and eliminate barriers.

Consider a participatory and multisectoral collaboration for proper acquisition, implementation, and maintenance of healthcare solutions that involve digital technologies.

Consider the impact of the implemented solution on digital equity (access to and quality of care, and care continuity) across different types of health systems.

Adopt strategies that guarantee a new healthcare solution involving digital technologies serves as a facilitator and not as a barrier to accessing and receiving high-quality care.

Assess the technical characteristics of the solution and how those match the current needs of potential users.

Before acquiring a healthcare solution, consider how it was developed, where and how it will be implemented and maintained, and how it will use, produce, or transmit data.
Health Systems, Health Plans, and Clinical Providers (Monitoring/Improvement/Equity Assessment Phase)Identify the characteristics of the populations that are using a healthcare solution that involves digital technologies, and identify populations presently excluded, not benefiting, or not participating at the desired or same rates as others.

Use a participatory approach to collect input from affected community members about the healthcare solutions that involve digital technologies.

Consider the impact of the healthcare solution on digital equity (access to and quality of care, and care continuity) across different types of health systems.

Adopt strategies that guarantee a new healthcare solution that involves digital technologies serves as a facilitator, not a barrier, to accessing and receiving high-quality care.

Identify information sources and gaps in available data for a comprehensive monitoring, improvement, and equity assessment of digital technologies.

Takeaways

The AHRQ Framework and Guide provide helpful resources to support various stakeholders when developing and implementing digital health technologies. The Framework demonstrates HHS’ action to further encourage adoption of digital health technologies as well as the Administration’s government-wide goal to integrate health equity by design. For more information on the Framework, addressing equity in digital health technology and other digital health issues, please contact the professionals listed below, or your regular Crowell Health Solutions contact.


Photo of Jodi G. Daniel Jodi G. Daniel

Jodi Daniel is a partner in Crowell & Moring’s Health Care Group and a member of the group’s Steering Committee. She is also a director at C&M International (CMI), an international policy and regulatory affairs consulting firm affiliated with Crowell & Moring. She…

Jodi Daniel is a partner in Crowell & Moring’s Health Care Group and a member of the group’s Steering Committee. She is also a director at C&M International (CMI), an international policy and regulatory affairs consulting firm affiliated with Crowell & Moring. She leads the firm’s Digital Health Practice and provides strategic, legal, and policy advice to all types of health care and technology clients navigating the dynamic regulatory environment related to technology in the health care sector to help them achieve their business goals. Jodi is a contributor to the Uniform Law Commission Telehealth Committee, which drafts and proposes uniform state laws related to telehealth services, including the definition of telehealth, formation of the doctor-patient relationship via telehealth, creation of a registry for out-of-state physicians, insurance coverage and payment parity, and administrative barriers to entity formation.

Photo of Allison Kwon Allison Kwon

Allison Kwon supports Crowell Health Solutions, a strategic consulting firm affiliated with Crowell & Moring, to help clients pursue and deliver innovative alternatives to the traditional approaches of providing and paying for health care, including through digital health, health equity, and value-based health…

Allison Kwon supports Crowell Health Solutions, a strategic consulting firm affiliated with Crowell & Moring, to help clients pursue and deliver innovative alternatives to the traditional approaches of providing and paying for health care, including through digital health, health equity, and value-based health care. She is a health care policy consultant in the Washington, D.C. office.

Photo of Eunice Lalanne Eunice Lalanne

Eunice Lalanne supports Crowell Health Solutions, a strategic consulting firm affiliated with Crowell & Moring, to help clients pursue and deliver innovative alternatives to the traditional approaches of providing and paying for health care, including through digital health, health equity, and value-based health…

Eunice Lalanne supports Crowell Health Solutions, a strategic consulting firm affiliated with Crowell & Moring, to help clients pursue and deliver innovative alternatives to the traditional approaches of providing and paying for health care, including through digital health, health equity, and value-based health care. She is a health care policy consultant in the Washington, D.C. office.