Federal Panel Issues Guidance on Submitting Self-Insured Health Plan Data to State APCDs

November 2, 2021


Elizabeth (Izzy) Montgomery, MPA
Policy Analyst

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On October 20, the federal State All Payer Claims Database Advisory Committee (SAPCDAC) released a report outlining recommendations on the voluntary submission of self-insured health plan data to state all-payer claims databases (APCDs). An APCD is a large-scale database that systematically collects healthcare data from a variety of payer sources. Arkansas has an APCD, a key component of the Arkansas Healthcare Transparency Initiative Act of 2015, which brought greater transparency to Arkansas’s healthcare system. ACHI is the administrator of the Arkansas APCD, with oversight from the Arkansas Insurance Department.

The Arkansas Healthcare Transparency Initiative requires the collection of medical, dental, and pharmacy claims as well as other key information from health and dental insurance plans, Medicaid, Medicare, the Arkansas Workers’ Compensation Commission, third-party administrators, and other entities. However, a 2016 Supreme Court ruling determined that states cannot require self-insured employers to submit claims data, only permitting submission on a voluntary basis.

As part of the congressional response to the court’s ruling, SAPCDAC was established in 2021 under  Section 735 of the Employee Retirement Income Security Act, as amended by section 115(b) of the No Surprises Act, part of the Consolidated Appropriations Act of 2021. SAPCDAC was charged with advising the secretary of labor on a standardized reporting format for self-funded health plans to voluntarily submit data to state APCDs, along with developing guidance on how states can work to collect this information. Reporting guidance covers medical, pharmacy, dental, member eligibility, and provider files collected from both private and public payers.

SAPCDAC was also charged with submitting a final report summarizing recommendations. The panel’s recommendations, summarized below, advise the secretary of labor on what guidance is needed to provide to states regarding processes for collecting APCD data in a standardized reporting format.

Standardized data layout:

  • Recommendation 1: Utilize the APCD common data layout (APCD-CDL) as the basis for a standard reporting format for submitting self-funded plan data to APCDs. The APCD-CDL is a uniform data layout that provides consistency for data submission and reflects the data elements needed by various state APCDs.
  • Recommendation 2: Work collaboratively with states to capture non-claims payments and other important variables needed for cost and utilization analyses.
  • Recommendation 3: Create a detailed data dictionary for elements included in the APCD-CDL data layout.

Data submission:

  • Recommendation 4: In the near term, state methods for data collection should become aligned and implemented in a way that mirrors the existing common state methods for APCD data collection.
  • Recommendation 5: The Department of Labor (DOL), working with APCD stakeholders, should identify an ongoing process where states can periodically evaluate current, alternative, or new standards for data submission, along with methods for quality assurance.
  • Recommendation 6: States should, to the extent possible, collect data on a uniform monthly timeline.

Data privacy, security, and release:

  • Recommendation 7: Existing state APCDs should maintain, and newly established state APCDs should develop and implement, rigorous privacy and security protections for the health information they receive, maintain, and release. The focus of protections should be to ensure the identities of individual patients are kept secure.
  • Recommendation 8: State APCDs should develop an infrastructure and implement a process that is adequately resourced for timely data release to approved data requesters.
  • Recommendation 9: States should explore establishing a secure, privacy-protective, multi-state data aggregation and dissemination model that would permit wider use of the data.

Voluntary data submission:

  • Recommendation 10: The labor secretary, in partnership with the Health and Human Services (HHS) secretary, should clarify and emphasize the public policy and business interests of having self-funded plans submit data to state APCDs.
  • Recommendation 11: DOL should simplify self-funded plan participation in APCD data submission by establishing an effective and streamlined process for self-insured plans to opt in for data submission by creating a standardized opt-in process.

Additional recommendations:

  • Recommendation 12: DOL should encourage employees and unions that sponsor self-insured plans to assess what (if any) changes to data submission processes could increase/enhance self-funded plan participation in APCDs.
  • Recommendation 13: Development of a committee or roundtable focused on state APCDs to fully address issues beyond the scope of SAPCDAC’s charge, with support from DOL staff.
  • Recommendation 14: The secretaries of labor and HHS should work with states, plan sponsors, health plans, and other stakeholders to encourage the submission of race, ethnicity, gender, and other key data elements to help address health inequities.

The Consolidated Appropriations Act also included federal funding of up to $2.5 million for each state to either launch a new APCD or improve an existing APCD. HHS will launch a grant program later this year.

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