As the climate crisis intensifies, HHS refuses to do its part

In January I argued the Department of Health and Human Services (HHS) appeared uninterested in mitigating the healthcare industry’s massive carbon footprint. To appreciate how massive, if every nation emitted our healthcare system’s per capita rate of greenhouse gases (GHGs), the total would approximate the entire global carbon budget to limit warming to 1.5 degrees Celsius by 2030.

U.S. healthcare is the largest industry in the largest economy in the world; HHS should not be a cause of the climate-related health harms it reimburses the healthcare industry to alleviate. Having again failed to promulgate any regulations to mitigate industry hydrocarbons this year, and it being inconceivable to do so during the upcoming election year, HHS has in effect declared defeat.

It is mortifying to realize HHS refuses to address the fact that healthcare is a climate-destroying industry and consequently guilty of fossil fuel racism.  

This is literally true for the approximately 160 million current Medicare and Medicaid beneficiaries — those whose health and well-being HHS is responsible for protecting. The climate crisis can increase the severity of over half of known human pathogenic diseases. Because they are already compromised due to higher incidence rates of co-morbidities, Medicare seniors are at even greater risk related to arthropod-borne, food-borne and water-borne diseases.

Extreme heat episodes are particularly deadly. Over the past 20 years, heat-related mortality among seniors has increased 54 percent. Children, 36 percent of whom are Medicaid beneficiaries, are uniquely vulnerable. Fine respirable particles resulting from fossil fuel use are particularly harmful because children breathe more air than adults relative to their body weight. Research published last year concluded the health effects to the fetus, infant and child include preterm and low-weight birth, infant death, hypertension, kidney and lung disease, immune-system dysregulation, structural and functional changes to the brain and a constellation of behavioral health diagnoses.

This was not supposed to be.

Immediately upon taking office, the Biden administration issued two executive orders related to the “climate crisis.” The first directed all administrative departments to take any action to “reduce greenhouse gas emissions” and to “hold polluters accountable, including those who disproportionately harm communities of color and low-income communities.” The second announced the administration would take a “whole of government” approach because the “government must drive … [the] mitigation of climate pollution and climate-related risks in every sector of our economy.” It ordered HHS to create a climate change office to address “the impact of climate change on the health of the American people.”  

When HHS Secretary Xavier Becerra launched in August the Office of Climate Change and Health Equity (OCCHE), he promised to “use every tool at our disposal to address the climate crisis.” OCCHE immediately partnered with the National Academy of Medicine (NAM) to create an “action collaborative to decarbonize the healthcare industry. HHS also launched that month an Environmental Justice Index designed to calculate environmental burden, including substandard air quality resulting from fossil fuel combustion, that minoritized people disproportionately suffer.  

In 2022 the Centers for Medicare and Medicaid Services (CMS) responded via proposed regulatory rulemaking. For example, the agency’s 2023 proposed Affordable Care Act payment rule asked the public “what would incentivize [ACA health plans] to take action on decarbonization?” CMS’s proposed 2023 Medicare inpatient rule similarly asked “what incentives” including “payment” “might assist” hospitals and others “in taking more action on … emissions reduction.” CMS complimented these efforts by launching a related health equity initiative designed to reduce health disparities among minority populations in part by addressing “manmade disasters” including “climate change.”  

Though it amounted to virtue signaling, HHS Secretary Becerra also launched in 2022 a pledge initiative requesting healthcare organizations to commit to reducing their GHG emissions 50 percent by 2030 because, as the secretary stated, “every stakeholder group in America must step up, and collaboration across the public and private sector is key.”

This year, however, HHS called it quits.

This past March, Becerra failed to even mention healthcare’s GHG emissions in testimony before three congressional committees concerning HHS’s 2024 budget. While assessing the causes of disparities within CMS programming, the agency’s 40-page health equity data plan and the agency’s related March discussion failed to recognize the fact that climate crisis poses the greatest threat to health equity, as well as the fact that HHS programming is a significant contributor. Unlike last year’s proposed inpatient rule, this year’s proposed rule ignores the topic. CMS’s two proposed Medicaid rules, published in May, also ignore the topic, despite the fact that first sentence of both state they are intended to “better address health equity issues.”

During an April OCCHE/NAM action collaborative public meeting, CMS Director Liz Fowler could only note that the Innovation Center’s Medicare Advantage demonstration affords participating plans the option of offering undefined “climate change supports in the future.”

During the meeting, Jon Perlin, CEO of the Joint Commission, which certifies hospitals meet CMS performance standards, announced the commission was withdrawing proposed hospital accreditation sustainability standards. Though the standards also amounted to greenwashing and though it is altogether within hospitals’ financial interests to decarbonize, Perlin stated sustainability standards would be optional because hospitals responses were, to no one’s surprise, overwhelmingly critical.

The biosphere is rapidly destabilizing. Ocean heat content is at alarming record levels, the Northern Hemisphere’s summer disaster season is off to an early start made evident by heat waves worldwide, and a Canadian wildfire season that already is the worst ever recorded. Three recent publications in Nature concluded that 9 percent of the world’s population already lives outside the “human climate niche;” climate tipping points are being triggered substantially more rapidly than previously thought; and seven of eight life support earth system boundaries have already been crossed.

Yet, the world’s most powerful healthcare regulatory agency refuses to act.

David Introcaso, Ph.D., is an independent health care policy consultant specializing in climate crisis-related health care policy reform. He has conducted environmental and health care policy research for the U.S. Congress and the Department of Health and Human Services. He also is the creator and host of “The Healthcare Policy Podcast.”