HHS proposes new greenhouse gas emission reporting requirement

The Centers for Medicare and Medicaid Services (CMS) is proposing to collect data on hospital greenhouse gas emissions for the first time. Here’s why this effort could be helpful for transparency and accountability on climate change, and some ways the initiative could go further.

Why this matters

From extreme heat to disease spread to malnutrition, the health effects of climate change are numerous, leading to hundreds of thousands of deaths worldwide every year. Additionally, the most serious harms from climate change disproportionately affect communities of color and other socially vulnerable populations, making this a major health equity issue.

Ironically, hospitals that were created to improve community health may be contributing to health problems through their emissions. Currently, the healthcare industry contributes about 8.5% of greenhouse gas emissions in the US, and emissions increased by 6% from 2010-2018. Hospitals are some of the largest healthcare institutions in the US, making up one third of all healthcare spending and an estimated 36% of greenhouse gas emissions. Clearly there is great need for action to reduce emissions from healthcare institutions.

What’s in the decarbonization initiative?

CMS’ proposed “Decarbonization and Resilience Initiative” could be a helpful step forward. The initiative would ask participating hospitals to report metrics around organizational commitment to sustainability, building energy use, and greenhouse gas emissions. These include whether the organization has an executive sustainability team, reporting of electricity and natural gas use, reporting of greenhouse gas emissions, and commitment to emissions reduction goals related to transportation and use of anesthetic gas.

Source: Centers for Medicare and Medicaid Services, 2024

Reporting from hospitals would include their “Energy Star” scores and underlying data, which are already collected by the Environmental Protection Agency (EPA). This is encouraging, because as we found out when we tried to collect this data for hospitals, the availability of the data is inconsistent. The EPA only publicly reports the top-performing Energy Star hospitals, and only a handful of state and local governments require hospitals to publicly report this data.

In exchange for reporting on these metrics, CMS will offer participating hospitals technical assistance and guidance on how to measure and report emissions, conduct a greenhouse gas audit, and other activities to improve sustainability.

Where we could go further

The Decarbonization and Resilience Initiative is a good step in the right direction, but it’s a small step. Here’s why:

  1. The initiative is voluntary, which limits the number of hospitals that will likely participate;
  2. It’s unclear whether the information hospitals provide will be publicly available. In regards to the availability of the data, the CMS website says that TEAM participants who opt in “may receive CMS recognition for their participation in the Initiative, and potentially their performance, on a public-facing CMS website.”
  3. The initiative doesn’t require reporting on Scope 3 emissions. CMS would require hospitals to report direct greenhouse gas emissions from sources they own (known as Scope 1 emissions), and emissions stemming from electricity consumed (Scope 2). But they don’t require reporting on other indirect greenhouse gas emissions (Scope 3), even though this type accounts for 82% of all emissions in healthcare.

What’s the impact?

Some public health experts say this initiative is a positive step forward, even if it is a relatively small step. Dr. Emily Senay, Associate Professor in the Department of Environmental Medicine and Public Health at the Icahn School of Medicine at Mount Sinai, said that this initiative is good news, because it signals that CMS is willing to enter the climate space. The initiative shows that “CMS hears and understands that carbon associated with healthcare activities is something we need to know about and measure,” Dr. Senay told the Lown Institute. It’s also a warning for hospitals that they may need to be ready to report on these metrics in the future. “What’s voluntary now may not always be voluntary,” said Dr. Senay.

However, others are more skeptical that the initiative will have much of an impact. David Introcaso, a climate-related healthcare policy consultant, said the CMS proposal is “a regulatory illusion intended to accomplish nothing.” Currently hospitals can choose to report these metrics already, but most do not. He pointed out that CMS could just ask the EPA for Energy Star scores, rather than waiting for hospitals to report them.

But one thing public health experts agree on is that more is coming down the line. The Securities and Exchange Commission (SEC) recently finalized its climate disclosure rule, which will require for-profit companies to report on their emissions and other climate-related risks, how they plan to mitigate these risks, and multiple other data points. Although the rule is currently being litigated, it’s only a matter of time before climate reporting becomes required for nonprofit hospitals as well.