The Department of Health and Human Service's Environmental Justice Index Constitutes Redlining
In early August, in conjunction with the recently-created Department of Health and Human Service’s (HHS) Office of Environmental Justice, the Centers for Disease Control (CDC) announced the release of the Environmental Justice Index (EJI). The EJI is intended to, CDC’s press release stated, “identify and map areas most at risk for the health impacts of environmental burden.” Absent reevaluating, the EJI will in effect constitute a form of redlining since it will put health insurance and other financial services further out of reach for moreover minority populations already suffering from an innumerable and unrelenting number of adverse health impacts resulting from both environmental and institutional racism.
“Too many communities . . . , particularly low-income . . . and communities of color,” the CDC statement correctly noted, “continue to bear the brunt of pollution.” Therefore, “placed-based EJ screening and mapping tools allow agencies and other entities,” the CDC stated, “to identify communities experiencing high environmental burden.” In addition to census-track level socio-economic and household information, the EJI will provide data concerning the prevalence of asthma, cancer, diabetes hypertension and poor mental health due in large part to EJI-reported levels of air pollution. The EJI will, the CDC states, help inform healthcare policymaking and identify necessary healthcare resources.
The EJI fact sheet also states data will serve more generally as “a representation of risk or exposure for a community, or a tool to tell whether individuals are at risk.” The CDC is exactly correct.
It is impossible imagine community and individual environmental risk data will not be used by health insurance plans as well as other insurance providers and underwriters along with auto, business, education and mortgage lenders, credit card, credit bureaus and related others to recalculate their products and fees. It is also difficult to imagine the other federal government agencies not using this data. For example, Social Security Administration for the purposes of projecting disability insurance claims and calculating lifespan data since research has shown life expectancy for residents living in in redlined communities is significantly lower.
One would have thought the CDC would have exercised caution since these types of tools can and do at least cause public blowback. For example, a week before the CDC’s announcement the Oregon Department of Forestry deleted from its website its Oregon Wildfire Risk Explorer, a statewide wildfire risk map that scored wildfire risk down to the tax lot and property level. Not surprisingly, Oregonians were, to be polite, upset high-risk scores would devalue their homes while causing their insurance rates to soar.
Census track level data concerning air and water quality, the location of toxic sites and transportation infrastructure, all EJI components, absolutely have a direct bearing on human health. The question is how best to use the information. An EJI is not it. One better way would be to include environmental determinants in patient or beneficiary health risk scores for the purposes of more accurately determining healthcare provider compensation. As is well documented, social, including environmental, determinants have far greater influence in determining individual and population health status.
If HHS is genuinely interested in advancing environmental justice and wants to begin to redress the fact its Office of Civil Rights has never addressed environmental racism (for example, read Josiah Rector’s recent work, Toxic Debt) they would do just that. To date, they have not despite, for example, recent research showing minority populations are disproportionately and continuously exposed to higher levels of 12 of 14 sources of fine particulate air pollution.
Absent reevaluating, the CDC’s effort just looks like more environmental injustice in action.