TEL. This month I’m going to veer out of my comfort zone into an area I don’t think I’ve ever written about – financial institutions. Don’t worry, I’m going to link it back to one of my favorite topics, the social determinants of health (#sdoh) – and even the patient-centered medical home neighborhood (PCMH-N).
The impetus for this column is Michigan’s new (September 2021) Financial Exploitation Prevention Act which, according to the Attorney General’s press release, “…requires financial institutions to develop and implement policies, training, and procedures for identifying and reporting the exploitation of their customers. It also allows financial institutions to freeze customer transactions or assets under certain circumstances; provides immunity from criminal, civil, or administrative liability to financial institutions for actions taken in good faith under the Act; and provides for the powers and duties of certain governmental officers and entities to enforce the Act.”
This Act has the backing of not only health and human service and anti-crime organizations, but of many financial institutions and their advocacy groups. Until now, Michigan financial institutions had very little recourse to counter what they suspected was fraudulent activity from unscrupulous individuals or groups who preyed on the elderly and other vulnerable people. If the affected person didn’t have a family member or other trusted person as a signer on their bank account, the financial institutions were extremely limited in taking meaningful action beyond notifying the police or contacting a family member to report their suspicions.
Here’s where the social determinants of health come in, though. As financial institutions develop their policies for identifying and reporting the financially vulnerable, what will they do with the information? It’s one thing to spot a case of likely exploitation, but quite another to do something about it. Is that really the best role and responsibility of a financial institution? It seems like a daunting task to me; perhaps akin to a physicians organization setting up bank accounts for patients at a primary care practice.
Factors that encompass the social determinants of health include access to quality health care, education, employment/income, transportation, nutrition and exercise, family and social networks, housing, and environmental considerations such as air and water quality. Financial institutions are not in position to undertake a comprehensive review of the social determinant of health that may have led their customers to a place where they are being financially exploited. I’m hoping that, if not already in the works, there are state agencies or community organizations skilled in these areas that plan to assist in the process of protecting the vulnerable and removing them, to the degree possible, from the situation that introduced the financial abuse. In the meantime, there’s a newer tool out there that may help the families of financially vulnerable individuals – and the financial institutions who serve them.
Many whole-person health practices already use a patient questionnaire, such as PRAPARE, to determine what role the social determinants of health play in helping or hindering someone from reaching their optimal health and well-being. Our organization not only uses such questionnaires but is now participating in a pilot project (funded by the Michigan Health Endowment Fund) with the Wayne State University Institute of Gerontology, led by Dr. Peter Lichtenberg, that looks at the financial health of the elderly. Called The Older Adult Nest Egg, the long-term project works with healthcare professionals, care managers, family and friends,
and older individuals themselves to prevent financial exploitation and reduce its impact using training, survey tools, and self-reporting assessments.
With the combination of new safeguards for preventing elder financial abuse at the financial institution level and clinical interventions with programs like The Older Adult Nest Egg, we are seeing the intersection of positive responses from different professions that consider and address #sdoh in whole-person health. And this crossover is an important example of why an examination of social determinants of health from multiple angles and disciplines is always worth our time. It’s also a reflection on the power of the patient-centered medical home neighborhood to affect change.