MassHealth issues landmark requirement on decarbonization of Massachusetts hospitals

MassHealth recently issued a bulletin requiring acute inpatient hospitals participating in MassHealth to report third-party validated greenhouse gas emissions. Read here key deadlines and what you need to do to assure your hospital is in compliance.

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What the regulatory development means

Massachusetts will be among the first states to require hospitals to report their greenhouse gas emissions. This isn't just another checkbox - it's a fundamental development in how healthcare facilities will be expected to track and manage their environmental impact. MassHealth Acute Inpatient Hospital Bulletin 198 makes emissions reporting mandatory for all acute care hospitals receiving Medicaid funds, starting in 2025.

The good news? Boston-area hospitals have already shown this is doable by cutting their emissions by 22% over the past decade – something DNV has played a role in. This new requirement creates a level playing field where all acute care hospitals will measure their environmental impact in the same way, making it easier to compare progress and share successful strategies. Think of it as creating a common language for sustainability in healthcare - one that will help Massachusetts reach its goal of net zero emissions by 2050. 

What it means for your hospital

Your hospital will be called upon to track two types of emissions: direct emissions (Scope 1) from things like on-site fuel burning and hospital vehicles, and indirect emissions (Scope 2) from purchased electricity and energy. This means setting up new systems to collect data, creating reporting procedures, and hiring an approved third party to verify your numbers. 

While there will be some upfront costs for monitoring systems and verification services, many hospitals find these investments pay off through energy savings. Being environmentally responsible is increasingly important to patients and staff with benefits to health, making this an opportunity to strengthen your hospital's reputation while complying with new requirements. 

What you need to do

Start by setting up a system to track all your emissions - from energy use of buildings to anesthetic gases. You'll need to pick a qualified validator from MassHealth's approved list to verify your reported performance. This validator must be independent and hold specific credentials listed in the bulletin. 

Make sure your tracking methods follow recognized standards like the Greenhouse Gas Protocol. While this might sound complex, many hospitals have successfully implemented similar systems. The key is starting early and being thorough in your data collection. 

Timeline overview

The clock is ticking with two major deadlines:

✓ By January 31, 2025, you must submit your chosen validator to MassHealth for approval. Need more time? You can request a one-month extension, but that request must also be in by January 31.

✓ Your first complete emissions report is due June 30, 2025. This report must include all your Scope 1 and 2 emissions, verified by your approved validator.

These aren’t suggested dates - they’re firm requirements tied to your MassHealth participation.

For hospitals in Cambridge, there’s extra urgency since you’ll need to be net-zero by 2035, while Boston facilities have until 2050 to reach the target.

Where you can get help

Don't tackle this alone. Start with approved validators who understand healthcare facilities - they're listed in the MassHealth bulletin 198 and are recognized for their technical expertise by respected organizations like ANSI National Accreditation Board, ASHRAE and the U.S. Green Building Council.

Consider DNV as a strong partner as it brings dual expertise as both a leading healthcare accrediting organization (AO) while also separately being a global leader in decarbonization. Our experience helping large networks of hospitals and complex facilities achieve sustainability goals makes us uniquely qualified to guide hospitals through this transition. 

Organizations like Health Care Without Harm and the Boston Green Ribbon Commission also have valuable experience helping hospitals reduce emissions. Your utility companies can help with energy data and efficiency programs. Look to success stories like Boston Medical Center and Mass General Brigham for practical examples. 

Risks beyond non-compliance

Ignoring these requirements puts your MassHealth participation at risk - it's that simple. Hospitals that delay action often face higher costs when they're forced to catch up quickly. Your reputation could suffer as patients and staff increasingly care about environmental responsibility for the benefit of everyone’s health. 

The longer you wait, the harder and more expensive it becomes to meet these requirements. Remember: this isn't just about checking boxes - it's about positioning your hospital for long-term success in a rapidly changing healthcare landscape where environmental responsibility is becoming as important as clinical excellence. 

 

 

1/27/2025 1:44:00 PM