DRAFTDR Leveraging Health Information Technology for Health Insurance Exchange Financial Management, Monitoring and Evaluation Report 2 Patricia MacTaggart, MBA, MMA The George Washington University School of Public Health and Health Services Department of Health Policy February 10, 2013 Submitted to the State Health Access Data Assistance Center, University of Minnesota School of Public Health, under subcontract to SHADAC. “Assessing State Administrative Data.” Funded by the U.S. Department of Health and Human Services Assistant Secretary for Planning and Evaluation (ASPE) (HHSP23320100024WI/HHSP23337001T) DRAFT FOR STATE INPUT Draft Table of Contents 1. 2. 3. 4. 5. 6. 7. Introduction ............................................................................................................... 3 Member, Qualified Health Plan and Health Insurance Exchange Financial Data Elements….………………………………………………………………………………………………………….…….4 Member, Qualified Health Plan and Health Insurance Exchange Financial Data Sources………………………………………………………………………………………………………………………6 Dashboard Capability for State Management and Reporting if Data Elements and IT Infrastructure Included ………………………………………………………………………………………………6 Vendor and Contractor Language……………………………………….………………………………………8 Standards and Data Elements …..…………………………………………….….……………………….…...9 Process and Challenges……………………………………………………………………………….…………...10 Exhibit Exhibit 1: Financial Questions for States that Align with Initial Core Questions…………………………….7 Attachments A. B. C. D. E. F. Data Elements Needed for Financial Reporting ………………………………………………………..11 IT Interfaces to Data Sources for Financial and Cost Operations and Reporting. ……...12 Member…………………………………………………………………………………………………………………..14 Qualified Health Plan..................................................................................................19 Health Insurance Exchange………………………………………………………………………….……….....22 Checklist for Health Insurance Exchange Data for Financial Monitoring and Reporting……………………………………………………………………………………………………………….…24 2 Leveraging Health Information Technology for Health Insurance Exchange Financial Management, Monitoring and Evaluation Report 2 1. Introduction States and Health Insurance Exchanges (HIXs) must: (1) address implementation and operational costs; (2) manage expenditures for administrative functions, consumer education and engagement, and payments to issuers, and (3) track and report on trends at the macro and micro level. In order to manage the HIX in compliance with the Accountable Care Acti, as well as monitor the results of the activities of the HIX, the involved Qualified Health Plans (QHPs) and issuers, information technology (IT) support is required to address (1) adequate accounting capability and protocols, policies and procedures; (2) identification of compliance issues, such as medical loss ratio; (3) banking and wire transfer functions; (4) cash management and payment authorization; (5) administrative budget and actual/variance reporting protocols, and (6) internal financial controls and state/federal reporting. One of the prerequisites for accurate reporting and analysis is the establishment of a solid baseline, requiring the IT infrastructure, data sources and data specifications to be determined as early in the process as possible. In addition, financial impacts have distinct, significant federal and state implications, which demand documentation of initial and ongoing resource requirements. The resource needs of the HIX have different cost impacts dependent on timing as the federal government takes more responsibility for initial funding (100% for IT through a grant process), while the state must deal with ongoing fiscal viability. Utilization of federal dollars is a critical consideration for states. Financial Data and Information Technology (IT) Essentials: This policy brief seeks to present opportunities for states to learn from key leading states that are immensely varied in process and policy, Minnesota, Oklahoma, Alabama, New York, Vermont and California the issues and opportunities for efficient and effective collection and use of required Affordable Care Act (ACA) HIX administrative and financial data for financial management and reporting. This policy brief provides procurement and vendor language for consideration for financial reporting elements, specific detailed functional specifications that addresses data definitions, data structure, data sources and interface specifications, collection period (e.g. monthly, quarterly, annual), and considerations related to interpreting the financial and cost information. Mandated financial reporting requirements, new data sources (RS/Treasury Dept.) and newly designed IT infrastructure create the parameters for discussion. The goal is to address these 3 components in requests for proposal (RFPs) and contract specifications so that duplicative purchasing is avoided and opportunities to standardize and leverage across projects are maximized. This can be achieved through an alignment of federal, standardized technology infrastructure specifications, data definitions, privacy and security (access, authorization and authentication) requirements, and business rules. States should consider aligning with federal, standardized technology infrastructure specifications, data definitions, privacy and security (access, authorization and authentication) requirements, and business rules. HIXs must have the financial management infrastructure necessary to support the execution of financial controls and audit function for all activities, receipts and expenditures, as well as generate the appropriate reports. Enrollment and financial reports must be kept in synch and all required reports to CMS must be sent in the format specified by the Centers for Medicare & Medicaid Services (CMS). In addition, HIXs are subject to annual audits, oversight from the Government Accountability Office (GAO), Department Treasury reporting requirements related to data on individuals determined to be eligible for the premium tax credit, and reporting requirements for specific information to employers. Each of these activities makes the collection, retention, transmission and management of accurate financial and administrative data critical. This project is intended for states considering development and implementation of an ACA HIX. It is intended as information only and as part of a larger project being conducted for the Assistant Secretary of Planning and Evaluation (ASPE) by the SHADAC, in assessing the data needs for monitoring and evaluation of the ACAii and by providing technical assistance to leading states on the implementation of health reform, funded by the Robert Wood Johnson Foundation (RWJF). The following report and recommendations represents a distillation of the best current thinking by leading states in the development of Health Insurance Exchanges. 2. Member, Qualified Health Plan and Health Insurance Exchange Financial Data Elements Financial Management and Data Collection: Financial management and data collection requirements for states under the ACA relate to four specific areas: (1) appropriate use of federal and state funds to support the verification of eligibility; (2) rating, financial requirement determinations, and management, including payment and oversight, of certification of the qualified health plans (QHPs); (3) financial activities of the Financial Management Data Collection areas that States need to address: Enrollees QHPs HIX Medicaid 4 Health Insurance Exchange (HIX) (annual operating costs and amounts lost to fraud, abuse and waste), and (4) assurance of coordination and utilization of Medicaid funding through Medicaid income eligibility.iii A state’s HIX must have a process for billing, collection, and account management and financial controls and determine exception processing consistent with federal regulations and guidance. The HIX must also have financial metrics (such as variance from budget), a defined algorithm for plan ranking, claims acceptance and storage capability, claims analytics and reporting tools, and a financial payment and reporting system. These processes and capabilities produce data that can be utilized for reporting and monitoring. A state’s HIX must publish the costs and fees associated with operating the organization, including the average cost of licensing, required regulatory fees and payments to operate the Exchange, Exchange administrative costs, and an accounting of money lost to fraud, waste, and abuse. Within the HIX system, the state must retain the data necessary to assure financial and operations oversights of the Qualified Health Plans (QHP), including certification, carrier management, user fee collection and management, enrollment and financial transactions. The data collected for oversight will then be available for required reporting to the federal government and to other stakeholders. Financial Data Elements: Data elements that could be available for the creation of a standardized reporting approach based on the four key areas identified above are listed in Attachment A. For the information to be available for operations, oversight and reporting, the financial data must be (1) collected from identified data sources, (2) leveraged where collected for other purposes (data previously collected by regulatory agency), (3) appropriately linked and defined, and (4) supported through an IT infrastructure where the IT specifications accommodate the data requirements. States need to consider alignment of financial data for federal reporting for Federal Financial Participation (FFP) with financial data used for ongoing monitoring and other purposes.. Attachments B-D provide the core data elements that states may want to consider for financial ongoing management and federal/state external reporting for monitoring and evaluation. The attachments address (1) data content (elements and definitions), (2) format (structure, element type, source) and (3) interfaces related to the individual enrolled into coverage through the HIX (referred to as “member”), the QHPs, including Medicaid/CHIP managed care entities, and the HIX. These data elements will need to be utilized by the HIX as well as the QHPs and potentially their network providers. 5 3. Member, Qualified Health Plan and Health Insurance Exchange Financial Data Sources Financial Data Source Variables: Variables that affect state options in designing a financial reporting/monitoring system include things like the internal back office administrative infrastructure within the HIX, the availability of a state all payer claims data base, if there is or is not a state tax system to use as a data source, what financial information is collected at the QHP regulatory agency, and where Medicaid eligibility will be processed. States must understand the structures, content, timelines and update periodicity of the data. For example, how and by whom the HIX handles premium aggregation and billing, carrier payments, eligibility and enrollment processing and reconciliation of employers, QHPs, and enrollees will affect what data is collected and retained through internal IT systems rather than accessed through interfaces with other IT systems. Variables that affect financial data analysis that must be considered include: (1) QHP and Medicaid use of managed care (encounter data as a data source and limitations resulting from sub-capitations where encounter data is not available); (2) consistency in the use of Medicaid and QHP data sources (Medicaid expenditures include both state and federal share but not all data sources include both the state and federal share and Medicaid, QHP and HIX expenditures include “administrative” and managed care costs as well as “claims” costs but some payments made outside of the claims processing system may not be included in the data source); (3) pre and post 2014 financial analyses that include children must address the inclusion/exclusion of CHIP financial data, and (4) consistency in how the HIX defines and treats QHP and HIX administrative expenditures. States need to establish a hierarchy for financial data sources based on accuracy, timeliness and efficiencies in order to determine which data will be used for purposes of payment, financial reporting and analysis. Required Financial Data Sources: States are required to use a federal data hub and existing State databases to the maximum extent feasible for income and financial reporting and operations. Attachment B identifies potential financial data source interfaces for states to consider and the data elements that can be obtained through the interfaces. 4. Dashboard Capability for State Management and Reporting if Data Elements and IT Infrastructure Included For states, the “day one” functionalities are the priority. Included in that priority is the capacity to manage, which requires the ability to transform data into actionable information in near real-time and present it in an efficient, easily understandable “dashboard”. Health Insurance Exchanges must 6 collect and verify financial, eligibility and quality data on individuals, families, employers, QHPs and issuersiv, which become data elements accessible for use in a dashboard. There are multiple financial questions that can be answered with these data elements. States should consider federal financial reporting requirements, build off existing state financial management and accountability tools, comply with all provisions of the Affordable Care Act and federal grant terms, comply with state specific auditing requirements, and support and monitor Exchange consumer services, including premium payments, subsidies and health plan payments. In addition to the federally required financial information, alignment of financial information with core enrollment, retention, premium subsidy and QHP information will allow states to link activities and utilization with costs. Exhibit 1: Financials related to Individuals Enrolled through Health Insurance Exchange States should consider a core, initial set of standardized financial questions for collection to meet reporting and management purposes across states to assure comparability and answer critical “day one” questions. Financial Questions for States that Align with Initial Core Questions Premium payment and tax credit cost for individuals that successfully enrolled in private individual health insurance through the Health Insurance Exchange. Premium payment and tax credit cost for individuals that successfully enrolled in private group insurance through SHOP. Number and cost of individuals that successfully enroll in Medicaid. Number and cost of individuals that successfully enroll in CHIP. Premium payment and tax credit cost for individual that successfully enrolled in Basic Health Plan, if offered. Number of individuals that successfully enrolled in a QHP, which QHP, and Premium payments for those individuals. Distribution of private market exchange members by actuarial value: Bronze, Silver, Gold, Platinum, Catastrophic. Distribution and costs of private market exchange members exchange members by deductible level. Cost information on use of navigator for applicants. Cost information by characteristics of exchange members: age, gender, geographic location. How many people have their application rejected without their eligibility status identified (e.g., information was missing at their application)? Financials Related to Retention and Transitions Premium and tax credit information on the people enrolling in the program in a given month who are truly new to insurance affordability programs (i.e., they did not churn or transfer)? 7 Exhibit 1: Financial Questions for States that Align with Initial Core Questions between Programs Premium Subsidy Number and cost of individuals that receive a premium subsidy by various subsidy levels. Qualified Plans Number of plans offered through Exchange and number of plans per level. Number and premium cost of plans that offer only the essential benefits. This is just the beginning of a list that each state will need to create to assure that the actual reports that are required and/or desired are programmed into the system as an automated function. The state will need the capacity to fully utilize the data from the systems and conduct, interpret and report data analyses and results. 5. Vendor and Contractor Language The translation of the data elements and data source interface specifications into RFP and contract language requires consideration of federal funding requirements, such as MITA and the “Seven Conditions and Standards”, and privacy and security safeguards, including a requirement that information systems containing tax return information comply with taxpayer privacy and safeguards. Determining what is within scope and what is outside of scope of a Health Insurance Exchange contract has initial cost implications and ongoing operational consequences. In general, the Health Insurance Exchange must comply with ACA, particularly Section 1561, Medicaid guidance and regulations related to reporting requirements, and core requirements outlined in their approved Level 1 Exchange Establishment Grant. Reports: RFPs and contracts must require a technology platform that can produce the financial data and reports for relevant agencies and stakeholders which are needed to support performance management, provide public transparency, evaluate progress, make improvements, assure program integrity, allow for policy analysis, and comply with federal and state reporting requirements (federal audit and oversight, quality control initiatives, (PERM), and appropriate use of federal funding). The IT structure should guarantee that financial data collected for operations and auditing is integrated into the reporting apparatus so it can be fully utilized for oversight and evaluation. Reporting capabilities must be able to connect and integrate data from multiple sources, maximize automation, and assure personally-identifiable information is protected. Considerations when determining report capabilities include: (1) the potential limitations by vendors on the number of reports that can be requested (initial pricing will be dependent on report requirements but limitations will add to ongoing costs), (2) the ability to integrate 8 encounter data (inclusion but separate identification within reports), (3) the assurance of the integrity of the data, especially with the conversation of data (such as ICD-9 to ICD-10), (4) the capability to merge or associate data where appropriate (individuals denied tax credits due to the eligibility for Medicaid linked to individuals approved for Medicaid), (5) the capacity to store and process external data, allow for querying by authorized users, archive inactive files, and validate data for completeness, (6) the specified response time requirements for ad-hoc or offcycle reports, and (7) the limitations on creating, supporting and accepting interfaces with needed data sources. States should consider when integrating data from multiple sources into the IT infrastructure, business processes and quality performance metrics interfaces with the appropriate data sources and the capacity to collect, retain and integrate the data with internal data sources. Identity Management-Individual, Provider, Entity: Accurate financial reporting is dependent on the use of a standardized, common set of individual, provider and entity identifiers or a standardized methodology to determine the required demographic data fields for matching. This data could include but is not limited to name, date of birth, address and sex. In addition, many current health care eligibility, claims, program integrity, financial management and/or insurance systems do not have the capacity to capture, track and link an expansive set of attributes across programs. Health Insurance Exchanges need not create another identifier to States should consider a cross-walk to the HIE, Medicaid, etc. States can leverage the standardized, common set EMPI or the algorithm that establishes the identity using multiple of individual, provider and demographic attributes that have already been established for entity identifiers or a Medicaid and/or the HIE. States can also build upon the required standardized methodology provider level National Patient Identifier (NPI) using State/State for identity management. Designated HIE provider directories. Re-using an already established ID avoids cross-walk requirements and allows the state to utilize the validations that have already been completed through the previous processes. 6. Standards and Data Elements For financial reporting, a starting place is the federal financial reporting definitions and specifications already established for Medicaid reporting to CMS through the CMS-37 and CMS64. In addition, the Medicaid Statistical Information System (MSIS) data, which was designed to provide CMS with a detailed national database of program information to support a broad range of analytic and user needs, is already transmitted from states to the federal government, has defined data specifications and cross-walk clarifications, includes eligibility and paid claims 9 personal information on Medicaid members and addresses payment and encounters. The CMS specifications for MSIS definev terms, identify responsibilities, and describe the record layouts. Established standards include the HIPAA 834 Transaction (Enrollment) Standards (http://www/wpc-edi.com), race and ethnicity (OMB standards), preferred language (ISO 6391:2002), preliminary determination of cause of death (ICD-10-CM), and encounter diagnoses (ICD-10-CM). 7. Process and Challenges Process: Documents created by the Office of the National Coordinator (ONC) and CMS CCIO for states were reviewed, along with documents created by leading states for their HIX, HIE, MMIS (MITA) and Medicaid eligibility expansions. Telephone interviews with states that were further along in their process were completed in July to validate the translation of monitoring strategy concepts into actualization and identify feasibility considerations and/or limitations. Enhanced federal funding opportunities and requirements, policy guidance provided by CMS regarding timeline flexibility and limitations, new IT development (service oriented architecture, federal and state data verification functionality, business rules engine, business intelligence and reporting) as well as expanding current efforts (identify management), and state human, IT and financial resource constraints were considered. If Medicaid funding is utilized, requirements necessitate compliance with the Seven Standards and Conditions and the Medicaid Information Technology Framework (MITA). In addition, the activities must be included in the State Medicaid Health IT Plan (SMHP), appropriate Advance Planning Document(s) (APD(s)) must be submitted, and quarterly CMS-37 and CMS-64 reporting must be adjusted. IT specifications must also be addressed in relationship to the state’s need for state and provider infrastructure. Challenges: Modularity, flexibility and standardization are even critical RFP and vendor contract requirements as states need to specify vendor requirements in RFPs and contracts “now”; yet, significant policy decisions at the federal and state level and guidance at the federal level is currently in process. Future decisions in those area will affect “how” data is collected (sources, location of the data sources and the interface requirements) but the “what” will remain. A checklist for states to consider related to financial data follows in Attachment E. 10 Attachment A: Data Elements Needed for Financial Reporting Area 1. Verification Eligibility: Member Information of 1. Certification of Qualified Health Plan (QHP) 2. Health Insurance Exchange 3. Medicaid Elements Member/Taxpayer: Identification, Demographics/Household Composition, Income and Eligibility and/or Enrollment Change of Circumstances Premium Tax Credit: total amount, amount of advance payments, collection of advance payment overpayments (Billing/Collection) Individual Coverage ( Period and Level), Premium (Cost Calculator) and Cost Sharing QHP: Identification, Geographic Area (QHP and Network), Financials, (Licensing Costs/Regulatory Fees), Rating Practices (Use of Tobacco, Family Tiers), Medical Loss Ratio, Financials by QHP Product Claims: Payment Policies and Practices, Denials by Provider Type and Out of Network Payments Tax Credits by Individual: Accuracy, Receipt and Correctness of Tax Credits, including Advance Payments Expenditures and Administrative Costs, including Consumer Education and Engagement, Payment to Issuers and Internal Operational Costs (variance from budget) Financial, Operations and Performance “Activities”, including Program Integrity (monies lost to waste, fraud and abuse), accounting, financial analysis and banking functionalities (banking functions will have data on amount transferred, date transferred and to whom transferred) All Federal Reporting Medicaid Data: T-MSIS and CMS Financial Reporting (CMS-64 and CMS-37), including Encounter Data. 11 Attachment B: IT Interfaces to Data Sources for Financial and Cost Operations and Reporting Interfaces to Data Sources CMS Data Services Hub: IRS/Treasury Dept. CMS Data Services Hub: Social Security CMS Data Services Hub: VA Medicaid and CHIP Eligibility Systems MMIS – T-MSIS Internal HIX: Member and Navigator/ Authorized Representative Potential Data Elements Provided Internal HIX: Issuer and QHP Internal HIX: Management “Activities” and Costs Internal HIX: SHOP Coverage Taxpayer Identification and Tax Credit: Payment, Amount, Date of Cessation (as applicable), Advance Payments, and Exemption Status Individual Identifier (Program Specific), Tax Information and Disability Income and Disability Individual, Provider and Entity Identification: Program Specific Individual, Provider and Entity Identifier: Program Specific Individual: Demographics (detail affected by age of system), Family Size and Income (based on Medicaid Basis of Eligibility -MAGI and non-MAGI methodology), Household Composition, Disability (if coded as basis of Medicaid eligibility) Individual, Provider and Entity Identifier: Program Specific Medicaid MCO/Health Plan Information: Co-payments, Cost Sharing, and Claims Payment Policies/Practices (dependent on what is transferred from MCO to MMIS) Claims Denials by Provider Type: MMIS for FFS and MMIS Encounter Data for MCOs Medicaid/CHIP Member: appeals and outcomes (if in MMIS system) Demographics, including Smoking Status if collected for rate calculations Individual/Family, Taxpayer, Navigator and Authorized Representative: Identification (program specific) Individual Taxpayer/Family: Income (MAGI methodology), Period and Level of Coverage by Individual by QHP, Payments (premium, cost sharing), Reported Change of Circumstances Affecting Eligibility and/or Enrollment Premium Tax Credit: Total Amount, Advanced Payments, Accuracy/Receipt/Correctness (internal system) Employer of Individual: Initial and at Time of Change, including Name and Date (if required on application/redetermination) Provider, Issuer and QHP by Issuer: Identification (program specific) Issuers: Payments to Issuers through Banking and Wire Transfer Functions and Payment Authorization Systems QHP Coverage and Payment (if not collected by insurance/health plan regulatory agency): Level of Coverage, Claims Payment Policies and Practices, Rating Practices, Cost Sharing, Out of Network Payments, Enrollment/Disenrollment and Claims Denials by Provider Type and Provider Network (provider and location) QHP Quality and Financial Oversight (if not collected by insurance/health plan regulatory agency): Medical Loss Ratio Coverage, Expenditures, Financials and Appeals HIX Program Integrity Management “Activities”: Monies Lost to Waste, Fraud and Abuse HIX Financial and Other Management “Activities”: Operations (administrative budget, account management, billing and collection systems, and cost calculator infrastructure), Performance (actual/variance reporting system) and Plan (claims acceptance and storage capability) vi HIX Internal Costs: Administrative, Consumer Education and Engagement Costs Eligibility of Small Business and their Employees Received Tax Credit and Payment Amount 12 Interfaces to Data Sources State Insurance and HP Regulatory Agency Potential Data Elements Provided QHP: Entity Identification (program specific) Level of coverage, Licensing Costs and Regulatory Fees, Financials, Expenditures and Cost Sharing by Plan within QHP Product, Claims Payment Policies/Practices and Rating Practices (if reporting is a regulatory requirement) and Enrollment/Disenrollment Data Other State Specific Systems: Illustrative Veterans and Other Federal Matches (Public Assistance Reporting System (PARIS)) Individual, Provider and Entity: Identification (program specific for state tax, workman’s compensation, Health Information Exchange (HIE), driver’s License: E-Address through Provider and Entity Directory: Health Information Exchange 13 Attachment C: Membervii viii ix x xi Data Elements Member Management: Individual Identifier Member Management: Date of Birth Member Management: Date of Death Data Definitions/ Codes Data Source Individual unique personal identification number that is assigned by the State (Master Individual Index: to standardize and convert data between multiple systems state should consider creating a Master Individual Index for the HIX and public programs. Format: Month, Day, Century, Year = Age (Specifications required by Data Services Hub will be the required specifications to assure interoperability and avoid need for conversion.) Format: Month, Day, Century, Year (Specifications required by Data Services Hub will be the required specifications to assure interoperability and avoid need for conversion.) Member Management: Address Street City State Zip Code County Code Enrollment and Eligibility Management: Income Format: (County Code will exist if application includes County, individual is on another public program that tracks county, or IT infrastructure has programmed capability to convert address and zip code through mapping to county and convert county into state established county code). Member Management: Gender Format: M = male F = female U = unknown Eligibility and Enrollment Management: Citizenship or Immigration Modified Adjusted Methodology Gross Income State Established based on name on Application/Enrollment Form linked to coding methodology of state. Interfaces/ Dependencies Linked to name and “family” defined below. Linked to other Public Programs if possible. Application/Enrollment Form (primary source) Data Services Social Security Vital Record & Passport (secondary source) Vital Records & State Driver’s License (in some states) Data Services Hub: Social Security Notification by Employer or Family/Interested Party (primary source) Vital Records Death Certificate- Vital Records (primary and/or secondary source) Application/Enrollment Form (primary source) Social Security, IRS/Treasury, State Tax System, Unemployment, Other Public Programs (secondary source) Application/Enrollment Form (primary source) Tax Return and Current Paystubs (non-electronic secondary source) Application/Enrollment Form (primary source) State Public Program System Public Programs (WIC, FS, Medicaid/CHIP, etc.) State Driver’s License: Dept. of Motor Vehicles Data Services Hub: IRS/Treasury Dept. Unemployment, Internal HIX Gender = declared sex of individual (Additional Issue: coding for unborn) Citizen (Y/N) Immigration Status: dependent on coding from application/enrollment form Hub: Federal Agencies (secondary source) Application/Enrollment Form (primary source) Data Services Hub Federal Agencies (secondary source) 14 Data Elements Status Eligibility and Enrollment: Date Individual Enrollment Eligibility and Enrollment: Data Definitions/ Codes Date Individual Enrolled = date individual eligible for coverage through HIX = no earlier than month of application = no later than month of application approved Format: 2 digit century, 2 digit year, 2 digit month, 2 digit date State specific definition Incarceration status Data Source Interfaces/ Dependencies System generated when approved based on business rules (primary source). Internal HIX Application/Enrollment if on the Enrollment Form (primary source) Internal HIX and Potential of other State systems (dependent on state) State Dependent: Criminal Justice System, Medicaid (secondary source) Member Management: Race/ Ethnicity Eligibility and Enrollment: American Indian/Native American status Ethnicity Options: Not of Hispanic, Latino/a, or Spanish origin Mexican, Mexican American, Chicano Puerto Rican Cuban another Hispanic, Latino, Spanish origin Application/Enrollment Form (primary source) Data Services Hub: Social Security, IRS/TREASURY DEPT. Social Security, IRS/Treasure Dept. Unemployment, State Tax System, Other Public Programs (secondary source) Race Options: White Black or African American American Indian or Alaska Native Asian (Asian Indian, Chinese, Filipino, Japanese, Korean, Vietnamese, Other Asian) Native Hawaiian or Other Pacific Islander (Native Hawaiian, Guamanian or Chamorro, Samoan or Other Pacific Islander) OMB Race/Ethnicity coded Application/Enrollment if on the Enrollment Form (Consistent with Member Management: (primary source) Race/Ethnicity but may have on application Social Security, further information as to Tribe) IRS/Treasury Dept., Unemployment, State Tax Data Services Hub: Social Security, IRS/Treasury Dept. Indian Nations 15 Data Elements Eligibility and Enrollment Management: Individual Risk Score Member Management: Smoking Status Data Definitions/ Codes Risk Score: Enrollment Date Disenrollment Date Available if determination of individual risk score is a part of process, collected and retained as part of application/enrollment. Current Smoker, Previous but not current, Never, No Response Data Source System, Other Public Programs, Tribal Records (secondary source) If established and retained at HIX, it is available in the system for linkage at disenrollment. System must automate linkage (primary source). Application/Enrollment if on the Enrollment Form (primary source) (No standardized coding) Member Management: Interpreter Services Required Eligibility and Enrollment Management: Family Size Members by Age Eligibility and Enrollment Management: Eligible for Publicly Funded Program Eligibility and Y for yes N for no Age = Data of Birth linked to individual linked to family (Age will provide data source for impact of insurance coverage for older children). Medicare-Part A, B, C, D Medicare-Medicaid Full Dual QMBs, SLMBs, QIs and QDWIs Medicare Status Unknown Medicaid Only: Children, Pregnant Women, Parents, New Adult Group, Disabled by Medicaid category of Disability, Elderly, Foster Care, HCBWS Members by category of disability, Breast and Cervical Cancer, Medicaid Premium Subsidy CHIP Individual receiving tax credit and amount Internal HIX QHPs, Issuers, Medicaid Internal HIX QHP, Issuer, Medicaid (secondary source) Application/Enrollment if on the Enrollment Form (primary source) Default – if no response indicated N for no Size = MAGI Methodology (Policy Dependent: if Pregnant Women, SSI or CHIP child in household family size state much determine how to handle) Interfaces/ Dependencies Federal & Other State Agencies (possible secondary source) Application/Enrollment Form (primary source) Tax Return source) (secondary Application/Enrollment Form (primary source) Medicare and Medicaid (secondary source) Internal HIX Potentially Services Hub Data Internal HIX Data Services Hub: IRS/Treasury Dept. Internal HIX Data Services Hub: CMS, Social Security State Medicaid Eligibility System HIX Computation (primary Internal HIX 16 Data Elements Enrollment Management: Tax Credit Amount Eligibility and Enrollment Management: Enrollment into Private Plan Member Management: Premium Tax Credit Eligibility and Enrollment Management: Employment Status Insured/Uninsu red status Employer: initial and at time of change Eligibility and Enrollment Management: Exemption Status Data Definitions/ Codes Data Source Interfaces/ Dependencies source) Bronze, Silver, Gold, Platinum, Catastrophic Level by Individual Tax Return (secondary source) HIX Computation (primary source) Data Services Hub: IRS/Treasury Dept. Internal HIX Issuer/QHP QHP Name by Individual Amount $ per individual/family Date of cessation as applicable Insured through Employer: Y = Yes and name issuer, name of employer and date of employment by employed person Employed at time of Application: F= Full Time, P = Part Time, N = Not Employed If F or P, then indicate I = Insured and unstructured data element of name Employed at time of Change: F= Full Time, P = Part Time, N = Not Employed If F or P, then indicate I = Insured and unstructured data element of name Exempt (Y or N) and if Y indicate R (Religious) F (Financial) Member Management: Taxpayer Identification No (TIN) TIN as reported to IRS Member Management: Coverage Issuer/QHP (secondary source) HIX Computation (primary source) IRS/Treasury Dept. (secondary source) HIX Computation (primary source) Other State Agencies: Workman’s Compensation, State Tax New Hire Income & Health Insurance Benefits Internal HIX Internal HIX: Linked to application date for data of change. Data Services Hub: New Hire Income & Health Insurance Benefits Application/Enrollment Form (primary source) Data Services Hub: IRS/Treasury Dept. HIX Administrative and IRS/Treasury (secondary source) Tax (primary course) Internal HIX HIX Administrative, State Tax and Medicaid (secondary source) Period of Coverage: Date range with open and end date by individual Level of coverage: by individual Data Services Hub: IRS/Treasury Dept. HIX Administrative (primary source) Issuer/QHP, State Insurance /Regulatory Agency dependent on state (secondary source) Data Services Hub: IRS/ Treasury Dept. Internal HIX and MMIS Internal HIX Issuer/QHP and Other State Agencies: Potentially the State Insurance/Regulatory 17 Data Elements Data Definitions/ Codes Member Management: Premium Member specific pricing Premium by individual by period of coverage Member Management: Cost sharing QHP by individual: Copayments by service by amount Deductible by coverage year by individual by family by total amount Member Management/ Program Integrity: Advanced Payments Eligibility and Enrollment Management: Insurance status at time of enrollment Linkage of individual to family for family deductibles By coverage year, by quarter advanced payment rolling to a total annual advanced payment Link to total eligible tax credit to determine number who took advanced payments and number of individuals overpaid during year. Link to collections/repayments of overpayments to determine “lost monies” due to advanced payments By individual: Insured at time of enrollment Uninsured at time of enrollment If uninsured, date of last insurance coverage If uninsured, last coverage source by private/Medicaid/CHIP and by health plan Data Source HIX Calculation (primary source) Issuer/QHP, State Insurance /Regulatory Agency (secondary source) HIX Administrative (primary source) QHP/Issuer source) (secondary IRS/TREASURY (primary source) DEPT. HIX Administrative(primary source) Application/Enrollment Form (primary source) Medicaid and Application (primary source) CHIP Forms Interfaces/ Dependencies Internal HIX Issuer/QHP and Other State Agencies: Potentially State Insurance/Regulatory HIX Internal QHP/Issuer (secondary source) HIX Internal Data Hub: IRS/Treasury Dept. HIX Internal Medicaid and CHIP Eligibility Systems HIX Administrative (secondary source) Link HIX enrollment to last coverage to address churn, seamless transitions, gaps in coverage and long-term departures. 18 Attachment D: Qualified Health Planxii xiii xiv xv xvi Data Elements QHP Product Issuer Identification QHP Product Identification of Plan within QHP Product Payer Member QHP for for Plan Management: Coverage/ Benefits by Plan within QHP Products Data Definitions/ Codes Issuer identifier = Issuer Name: Federal HIX standard alignment Issuer Address: Federal HIX standard alignment and/or Health Insurance Regulatory Agency alignment Plan = product of issuer by Name & Type: Exchange HMO, Exchange point of service (POS), Exchange PPO, Medicaid, Medicare Advantage Geographic Area: county Level: Bronze, Silver, Gold, Platinum, Catastrophic, Dental Only Indication if “benchmark” plan: no standard code Other: State specific, such as potentially Division of Insurance (DOI) Rating Information and Tiers Medicaid CHIP Medicare Employer/Group Individual HIX Data Source Health Insurance Regulatory Agency (primary source) HIX Internal HIX Administrative (secondary source) Health Insurance Regulatory Agency (primary source) Health Insurance Regulatory System HIX Internal HIX Administrative (secondary source) All Payer Claims Database (APCD) State Data Analytics Contractor (SDAC) Health Insurance Regulatory Agency (primary source) HIX Administrative, Medicaid and CHIP (secondary source) The package of benefits that an issuer offers Health Insurance that is reported to state regulators in an Regulatory Agency insurance filing. (primary source) Services Definition = Medicaid definition of services, while package of services included are defined by state option of “benchmark” comparison. For example, hospitalization – inpatient hospital payments as defined by CMS 64. Interfaces/ Dependencies Health Insurance Regulatory System HIX Administrative, Medicaid/CHIP/All Payer Claims (APCD), Issuer (secondary source) Health Insurance Regulatory System HIX Internal & Medicaid/CHIP/All Payer Claims Database (APCD) Health Insurance Regulatory Data Base HIX Internal Medicaid/CHIP/All Payer Claims Database (APCD) Issuer Data Base Need to cross walk ambulatory patient services to Medicaid Services for inclusion/exclusion and determine for comparison role of rebates in determining comparisons related to pharmaceutical. 10 Minimum Categories (use CMS 37/64 coding): ambulatory patient services; emergency services; hospitalization; maternity and newborn care; mental health and substance use disorder services, including behavioral health treatment; prescription drugs; rehabilitative and habilitative services and devices; laboratory services; preventive and Issue: Medicaid service 19 Data Elements Data Definitions/ Codes Data Source wellness services and chronic disease more management; and pediatric services, including segmentation oral and vision care. Interfaces/ Dependencies discreet By Category of Service: Limits (funding and life Issue: Encounter data (if time. required – but mandatory for Medicaid – use coding Prescription Drugs: formulary and limitations for CMS 37/64 and/or MSIS and include adjudication May include optional benefits available for an and encounter payment additional premium as well as benefits that are history information) legally considered riders but are not optional for consumers (‘‘mandatory riders’’), if those Need to determine “dental” benefits are part of the most commonly definition in commercial purchased set of benefits within the product by and cross-walk to Medicaid enrollment) and a particular cost sharing option definition. (not including premium rates or premium quotes). Care Management: Treatment Limitations by plan within QHP Product Need to define for reporting and comparison issues such as supplemental payments, DSH, Medical Education. Quantitative Limits Based on: frequency of treatment days of coverage other similar limits on the scope and duration of treatment, such as physical therapy to 10 visits/year Operations Management: Claims Denial by Provider Type by plan within QHP Product Claims Denial by Provider Type by plan within QHP Product Contract Management: Cost Sharing by plan within QHP Product Cost Sharing by plan within QHP Product Copayments by services Deductible by services Out-of-Network Payment by services Issuer/QHP and Health Insurance Regulatory (primary source) Health Insurance Regulatory & Issuer/QHP Data Bases HIX Administrative and Medicaid/CHIP/All Payer (secondary source) HIX Administrative Data (primary source) HIX Internal and Medicaid/CHIP/All Payer Claims Database Issuer/QHP Data Base HIX Internal Medicaid/CHIP/All Payer Claims Database and Potentially State Data Analytics Contractor (secondary source) HIX Administrative Data, QHP/Issuer Data Base and Health Insurance Regulatory (primary source) Medicaid/CHIP/All Payer Claims Database (secondary source) Medicaid (MSIS)/ CHIP/All Payer Claims Database Issuer/QHP Data Base HIX Internal Medicaid/CHIP/All Payer Claims Database and Potentially State Regulatory (state dependent) 20 Data Elements Eligibility and Enrollment: Provider Appeals Data Definitions/ Codes Provider Appeals by Provider Type Provider Type (CMS 64-37 or Medicare) Appeal Category: State Determined Data Source State Provider (primary source) Appeals HIX Administrative (secondary source) Performance Management: QHP Network Providers Operations Management: Small Business Health Options Program (SHOP) By Network Provider: Credentialing Name Primary Location If Multiple Location: Each Location Services: CMS 37/64 Data Definition Key Contact Personnel Essential Community Providers (ECPs) Status Specialty NPI Optional: Link to Geographic Information System to validate locations and adequacy Employer: Name/ID Number of Employees Receiving tax credit or not receiving tax credit Did -Did not previously offer health insurance benefits Defined Financial Contribution If defined benefit plan: name and if open to employees by employer Premium Tax Credits QHP/Issuer source) (primary Department of Insurance and/or Health Plan Regulatory Agency (primary source) HIX Administrative(secondary source) QHP/Issuer source) Interfaces/ Dependencies State Provider Appeals System (may be Medicaid or other system) HIX Internal HIE Master Provider Director Other State Agencies: Insurance/Health Plan Regulatory Agency QHP/Issuer Provider Enrollment System (primary HIE Master Provider Director Department of Insurance and/or Health Plan Regulatory Agency (primary source) Other State Agencies: Insurance/Health Plan Regulatory Agency HIX Administrative(secondary source) QHP/Issuer Provider Enrollment System Group Market Issuers Name By Employer, Covered Lives 21 Attachment E: Health Insurance Exchangexvii xviii xix xx xxi Data Elements Data Definitions/ Codes Operations Management: Validation of Tax Credits, including advance payments: Accuracy Receipt Correctness Eligibility and Enrollment Management: Number of people who used “Assister” and cost Validation of Tax Credits (Final) Accuracy/Correctness (number correctly calculated first time – number adjustments made per reporting year) Receipt (audit system validation of payment issue – see financial management) Validation of Tax Credit Advance Payments: Accuracy/Correctness number correctly calculated first time number collections made at end of year and amount of variance from advance and actual number of additional payments made beyond advance payments and variance) Receipt (audit system validation of payment issue – see financial management) Number of people who used “Assister”: Navigator and cost Broker and cost Neither/None: accessed HIX through web Eligibility and Error Rate = of initial determination, % error Enrollment: Accuracy identified during audit review and $ value of of initial decisions error cases based on audit reviews “Initial” data from initial determination. Operations Management: Tax Audit review data: from audit (unknown whether data source will be electronic) Tax Credits to Employers: Employer ID Data Source Interfaces/ Dependencies HIX Internal Administrative HIX (primary source) IRS (secondary source) Data only available if asked on application-self reported and retained in HIX Administrative (primary). If navigator system tracks navigator by member and “broker” interface reports by member, it might be possible to calculate this information. State specific. HIX Calculation (state specific) of audit change versus initial if audit review data available electronically and linked. (primary) Data Hub: IRS/ Treasury Dept. HIX Internal Possibly Navigator IT and “Broker” interface. (See data source comment). HIX Internal HIX Audit Review System. HIX Administrative HIX Internal (primary source) 22 Data Elements Data Definitions/ Codes Credits to Employers Operations Management: Charged by Exchange Operations Management: Expenditures Administrative Functions Fees the for Program Integrity Management: Monies Lost to Waste, Fraud and Abuse Financial Management: Payments to Issuers Received Grant: Federal Tax Credit Range Previously provided health insurance Did not previously provided health insurance QHP by Employer Fees charged QHP by the Exchange for User/Licensing Amount/month Assessment/subscriber fee included in premium/month Administrative Functions by: Management of SHOP Management of QHP Internal management of HIX Enrollment and Education activities Program Integrity Marketing Financial Activities IT/Systems Activities Quality Oversight No standardized categories or definitions – one way to address is “cost centers” and/or consider reporting by staff and contractor categories Audit Recoveries by category: Waste, including billing errors Fraud and Abuse Premium Payments Level 1 Grant 2nd Level 1 Grant Level 2 Grant Data Source Interfaces/ Dependencies State Regulatory State Regulatory Authority Dept. and Department of Revenue (secondary State Department source) of Revenue/Taxes HIX Administrative HIX Internal (primary source) HIX Administrative (primary source) HIX Internal HIX Administrative (primary source) HIX Internal HIX Administrative Banking and Wire Transfer Systems Cash Management Systems Payment Systems: Accounting Systems: Billing, Collection, and Account Management Systems. HIX Administrative (primary source) but may not be electronic or in system HIX Internal HIX Internal tracked electronically) 23 (if Attachment F: Checklist for HIX Data for Financial Monitoring and Reporting Elements Does the state understand the HIX financial data requirements related to the activities of the Health Insurance Exchange? Has the state identified the availability of needed financial data sources, including federal sources, state sources, health plans, etc.? How will the state access these data sources? What is provided by the federal Data Services Hub vs. state sources? Has the state started dialogue with all entities, especially non-health sources, such as state Departments of Revenue? Does the state require the HIX vendor to obtain the required data elements related to the financial activities of the Health Insurance Exchange? Is the HIX vendor required to leverage data collected for other purposes (audit trail information as a data source for reporting) for purposes of financial monitoring and reporting? Do the HIX vendor requirements align with federal, standardized technology infrastructure specifications, data definitions, privacy and security (access, authorization and authentication) requirements, and business rules? Does the state define which financial data elements are linked and require the HIX vendor to appropriately link them? Do the HIX IT infrastructure specifications accommodate the financial data requirements? Has the state included in the QHP contract requirements those financial data elements that will need to be utilized by the QHPs, and potentially their network providers, as well as the HIX? Has the state addressed which data source is the primary data “truth” in the event there is conflicting data? Has state specified to the HIX vendor the required data source interfaces and data elements and specifications for each data source? Has the state defined for the HIX vendor which data sources are to be used for what and when in order to assure access to whichever data source provides the most efficient, accurate and timely data elements when there is more than one option available to the state? Has the state addressed in the HIX vendor contract how the HIX vendor must integrate other data into the IT infrastructure, business processes and quality performance metrics, including, interfaces with the appropriate data sources and capacity to collect, retain and integrate the data with internal data sources? In translating the financial data elements and data source interface specifications into RFP and contract language, has the state clearly defined what is within scope and what is outside of scope of an HIX contract related to financial data elements and interfaces? Does the state require a technology platform that can produce the financial data and reports which are needed and support reporting capabilities that connect and integrate data from multiple sources? Does the state require the HIX vendor to respond in a stated amount of time to ad-hoc or offcycle reports? Will the state require the HIX vendor to leverage the EMPI or the algorithm that establish the identity using multiple demographic attributes that have already been established for Medicaid and/or the HIE? Has the state specified to the HIX vendor modularity, flexibility and standardization requirements? Has the state gained assurances from the vendor that they can accommodate changing guidelines and standards? Has the state reused standard contract language relative to working with vendors and federal government, etc. to expedite processes and mitigate risk/cost? 24 i ACA, Public Law 111-148 § 1313 Blewett, Lynn A., Pari McGarraugh and Karen Soderberg. “Draft Preliminary Report: Data Needs for Evaluation of the Affordable Care Act.” State Health Access Data Assistance Center (SHADAC), University of Minnesota, School of Public Health. Submitted to the U.S. Department of Health and Human Services Assistant Secretary for Planning and Evaluation (ASPE) July 21, 2012. (Solicitation Number 11-233-SOL-00530) iii iii Blewett, Lynn A., Pari McGarraugh and Karen Soderberg. “Draft Preliminary Report: Data Needs for Evaluation of the Affordable Care Act.” State Health Access Data Assistance Center (SHADAC), University of Minnesota, School of Public Health. Submitted to the U.S. Department of Health and Human Services Assistant Secretary for Planning and Evaluation (ASPE) July 21, 2012. (Solicitation Number 11-233-SOL-00530) iv Federal Exchange Program System Data Services Hub Statement of Work, http://www.nescies.org/sites/www.nescies.org/files/HHS%20-%20Hub%20Statement%20of%20Work%20.pdf v http://www.cms.hhs.gov/MSIS/ vi Draft Part 1 Chapter 4 business Process Model 3.0, MITA, http://www.cms.gov/Research-Statistics-Data-andSystems/Computer-Data-and-Systems/MedicaidInfoTechArch/index.html?redirect=/MedicaidInfoTechArch/, reviewed 7/15/12 vii Bipartisan Policy Center (June 2012) Challenges and Strategies for Accurately Matching Patients to Their Health Care Data. Washington, D.C.: Bipartisan Policy Center. Retrieved from http://bipartisanpolicy.org/sites/default/files/BPC%20HIT%20Issue%20Brief%20on%20Patient%20Matching.pdf viii viiiReducing Health Disparities with Improved Data Collection: New Refined Data Standards for Race, Ethnicity, Sex, Primary Language, and Disability Status, http://minorityhealth.hhs.gov/templates/content.aspx?lvl=2&lvlid=208&id=9227#Race ix Minnesota RFP, Minnesota Department of Commerce Health Benefit Exchange, http://mn.gov/commerce/insurance/images/ExchOutreachRFP2-12.pdf, reviewed 7/21/12 x CALIFORNIA OCIO OFFICE, DRAFT FOR DISCUSSION, VERSION 14, DECEMBER 7, 2010 Health Care One Stop, Transforming California Health Care Interoperability – Interfaces – Information The Time to Start is Now, IT Infrastructure Operational Roadmap to meet Federal Mandates and Fully Utilized Federal Options, George Washington University for CA CIO Office, 12/07/2010, xi Massachusetts Health Insurance Exchange Contract, xii Bipartisan Policy Center (June 2012) Challenges and Strategies for Accurately Matching Patients to Their Health Care Data. Washington, D.C.: Bipartisan Policy Center. Retrieved from http://bipartisanpolicy.org/sites/default/files/BPC%20HIT%20Issue%20Brief%20on%20Patient%20Matching.pdf xiii xiiiReducing Health Disparities with Improved Data Collection: New Refined Data Standards for Race, Ethnicity, Sex, Primary Language, and Disability Status, http://minorityhealth.hhs.gov/templates/content.aspx?lvl=2&lvlid=208&id=9227#Race xiv Minnesota RFP, Minnesota Department of Commerce Health Benefit Exchange, http://mn.gov/commerce/insurance/images/ExchOutreachRFP2-12.pdf, reviewed 7/21/12 xv Health Care One Stop, Transforming California Health Care Interoperability – Interfaces – Information The Time to Start is Now, IT Infrastructure Operational Roadmap to meet Federal Mandates and Fully Utilized Federal Options, George Washington University for CA CIO Office, 12/07/2010, xvi Massachusetts Health Insurance Exchange Contract, xvii Bipartisan Policy Center (June 2012) Challenges and Strategies for Accurately Matching Patients to Their Health Care Data. Washington, D.C.: Bipartisan Policy Center. Retrieved from http://bipartisanpolicy.org/sites/default/files/BPC%20HIT%20Issue%20Brief%20on%20Patient%20Matching.pdf xviii xviiiReducing Health Disparities with Improved Data Collection: New Refined Data Standards for Race, Ethnicity, Sex, Primary Language, and Disability Status, http://minorityhealth.hhs.gov/templates/content.aspx?lvl=2&lvlid=208&id=9227#Race xix Minnesota RFP, Minnesota Department of Commerce Health Benefit Exchange, http://mn.gov/commerce/insurance/images/ExchOutreachRFP2-12.pdf, reviewed 7/21/12 xx CALIFORNIA OCIO OFFICE, DRAFT FOR DISCUSSION, VERSION 14, DECEMBER 7, 2010 Health Care One Stop, ii Transforming California Health Care Interoperability – Interfaces – Information The Time to Start is Now, IT Infrastructure Operational Roadmap to meet Federal Mandates and Fully Utilized Federal Options, George Washington University for CA CIO Office, 12/07/2010, xxi Massachusetts Health Insurance Exchange Contract, 25