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March 23, 2022 See the Health Care Payments Data Program Quarterly Newsletter for March 2022  

The newsletter keeps stakeholders informed on programmatic updates to the HPD program.

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Overview

AB 80 (Chapter 12, Statutes of 2020) provides HCAI the authority to establish the Health Care Payments Data Program (HPD), often referred to as an All Payer Claims Database or APCD. This enabling legislation expands the mandate provided by AB 1810 (Chapter 34, Statutes of 2018), which  included a one-time appropriation for HCAI to develop and administer the program and required HCAI to convene a Review Committee of stakeholders and experts to advise the department on the establishment, implementation, sustainability, and ongoing administration of the HPD Program. The Review Committee’s recommendations were included in a report submitted to the California Legislature on March 9, 2020.

The information from the HPD System is intended to support greater health care cost transparency and will be used to inform policy decisions regarding the provision of quality health care, and to reduce health care costs and disparities. It is also intended for the information to be used to develop innovative approaches, services, and programs that may have the potential to deliver health care that is both cost effective and responsive to the needs of all Californians.

HPD Program Goals

The HPD Program has developed the following goals, based on the legislative intent outlined in the authorizing statute.

  • Provide public benefit for Californians and the state while protecting individual privacy.
  • Increase transparency about health care costs, utilization, quality, and equity.
  • Inform policy decisions on topics including the provision of quality health care, improving public health, reducing disparities, advancing health coverage, reducing health care costs, and oversight of the health care system and health care companies.
  • Support the development of approaches, services and programs that deliver health care that is cost effective, responsive to the needs of Californians, and recognizes the diversity of California and impacts of social determinants of health.
  • Support a sustainable health care system and more equitable access to affordable and quality health care for all.

Laws and Regulations

Health and Safety Code, Division 107, Part 2, Section 8.5 provides HCAI the authority to implement the HPD Program.

The Department of Health Care Access and Information (HCAI) is statutorily required to establish and administer the Health Care Payments Data Program (HPD) to collect health care data from health care plans, health insurers, government agencies and others (Health and Safety Code Section 127671.1).  HCAI is required to adopt emergency regulations to implement HPD by December 31, 2021.

The HPD  emergency regulations have been approved by the Office of Administrative Law (OAL) on December 20, 2021 and are now effective.

Text of the approved HPD emergency regulations.

Resources

The following are resources for the Healthcare Payments Data Program:

Healthcare Payments Data (HPD) Program Frequently Asked Questions

1. How will the HPD Program contribute to improving California’s healthcare system?

In gathering, integrating, and organizing information about how health plans and insurers pay for care, the HPD Program offers an unprecedented opportunity to address health care costs and drive improvement in California’s healthcare system. The HPD System can provide visibility into how California spends $300 billion on health care annually; streamline and improve California’s ability to monitor health system performance through more complete and standardized data; and enable a better, lower-cost approach to planning and evaluating programs and improvement initiatives. The variety and volume of data the HPD System will collect and link to will increase over time, as will the complexity of supported analyses.

2. When will the HPD Program go live? 

Chapter 8.5 (commencing with Section 127671) of Part 2 of Division 107 of the Health and Safety Code requires the HPD System to be substantially complete by July 2023. HCAI’s implementation plan outlines the key milestones, including finalizing data specifications (2020), contracting for data collection (2021), limited data collection and initial data quality and evaluation activities (2022), and completion of the database technical infrastructure and initial production of analytic reports (2023). 

HCAI adopted emergency regulations effective December 20, 2021, related to key aspects of data collection, including plan size threshold for submitters, frequency of submission, and content, file formats, and timeline for submission. Additional regulations related to key aspects of data management, access, and release will be part of the normal rulemaking process and adopted by December 20, 2023.

3. What data will the HPD System collect?

Like other All Payer Claims Databases (APCDs), the HPD System will rely primarily on administrative data: claims and encounters generated by transactions among payers and providers on behalf of insured individuals. To maximize its utility and value for California policymakers and others interested in improving California’s healthcare system, the HPD Program’s database will aim to be as comprehensive as possible—including medical, pharmacy, and dental services.  Given the importance of managed care in California’s market, the HPD System, when fully developed, will also plan to collect information about non-claims payments including capitation and alternative payment models (e.g., shared savings for accountable care organizations). 

4. What format will be used to collect the data?

The HPD Program is adopting a national standard created by the APCD Council, the APCD Common Data LayoutTM (APCD-CDLTM), for commercial submitters and for Medi-Cal claim and encounter data. A standardized format will reduce burden for data submitters, particularly health plans and insurers that submit data to multiple state APCDs.

5. Who will submit data to the HPD System? 

APCDs collect claim and encounter data from healthcare payers such as health plans and insurers. The HPD Program anticipates collecting healthcare data for 30 to 34 million Californians, sourced from: the Department of Health Care Services (DHCS) for Medi-Cal members; the Centers for Medicare & Medicaid Services (CMS) for Medicare fee-for-service members; and health plans and insurers for those with employer-based, individual, or Medicare Advantage coverage. Private, self-insured companies interested in reducing costs and improving system performance will be encouraged to participate in the HPD Program on a voluntary basis.

6. What about private self-insured companies and Taft-Hartley trusts?

In March 2016, the U.S. Supreme Court ruled that states cannot require self-insured employer plans regulated under the federal Employment Retirement Income Security Act of 1974 (ERISA) to submit data to a state APCD. The decision, Gobeille v. Liberty Mutual, resulted from a lawsuit by a self-insured employer that challenged Vermont’s right to require the employer’s third-party administrator to submit claim data to the state APCD. The Supreme Court found that ERISA preempted Vermont’s ability to compel the submission of claim data for self-insured employers. The decision does not apply to governmental plans that cover public employees because such plans are exempt from ERISA. Accordingly, self-insured health benefit programs for state employees and other public workers (including state, county, and municipal employees and retirees; and public school teachers and retirees) can be included as mandatory submitters to the HPD System. 

While private self-insured employers and Taft-Hartley trusts (collectively bargained labor-management agreements) cannot be compelled to contribute data to the HPD System, many health benefit programs are increasingly concerned about the continued escalation of health care costs and are interested in using analytics based on APCDs to contribute to the development of solutions.

HCAI has the authority, at its discretion, to accept data voluntarily submitted to the HPD System, including data from hospitals, clinics, and clinicians with an independent scope of practice who submit claims electronically, and ERISA self-insured plans. 

7. How will HCAI engage stakeholders on the HPD Program?

HCAI convened an advisory committee of stakeholders to provide guidance on the HPD Program, composed of between nine and 11 healthcare members along with non-voting ex officio membership of the HCAI director, the director of the DHCS, and the executive director of Covered California (or their representatives). HCAI will also convene a data release committee to advise on requests for access to non-public data. Other committees and workgroups, such as those representing data submitters and data users, will provide input and insights essential to the HPD System’s effective functioning. The HPD Program will leverage HCAI’s experience working with stakeholders on data initiatives, producing analytics and information for policymakers and the public, and handling data requests from outside organizations.

8. Will the HPD System include data from other sources?

Other data sources can enhance the ability of the HPD System to answer important questions that cannot be addressed with claim and encounter data alone. HCAI will ensure that the HPD System can map to other datasets, including public health datasets on morbidity and mortality and data regarding the social determinants of health. The HPD statute requires that the advisory committee make recommendations to HCAI by July 2024 regarding how state public health data functions may be integrated into the HPD system.  

9. Who will be able to access HPD data?

The public will benefit from insights gleaned from HPD data through reports, visualizations, and other data products that HCAI will release on its website and through the California Health and Human Services Agency’s Open Data Portal. In addition, HCAI will establish a process through which data requestors can apply for access to more detailed, non-public data.

10. How will access to non – public data be handled?

HCAI, with the advice of the advisory committee and the data release committee, will develop policies and practices for data access and release, including data aggregation and the protection of individual confidentiality, privacy, and security. Individual patient-level data will be exempt from the disclosure requirements of the California Public Records Act.  

11. How will the HPD program ensure data privacy, confidentiality, and security?

Chapter 8.5 (commencing with Section 127671) of Part 2 of Division 107 of the Health and Safety Code establishes strong privacy and security standards for the HPD System, including ensuring that the privacy, security, and confidentiality of consumers’ individually identifiable health information is protected consistent with state and federal privacy laws. Additionally, California has long led the nation in developing robust privacy and security standards to protect personal information, particularly when it comes to information regarding individual health status. Consistent with this history and philosophy, a core principle is that the HPD System is established primarily to learn and provide information about healthcare systems and populations, not individual patients.

12. What is HCAI’s plan for reporting HPD data publicly? 

HPD is statutorily required to produce publicly available data products which protect patient and consumer privacy. To this end, HPD has adopted the following public reporting principles: 

  • Protecting Patient Privacy: This will be achieved by protecting patient-level data from reidentification with prohibitions on publishing direct identifiers.  HPD will follow guidelines such as CHHSA and HIPAA safe harbor.  
  • Informing Policy and Practice: HPD will generate information that is accurate, meaningful, relevant, actionable, and as comprehensive as possible.  In addition, HPD will consider the needs of diverse audience and design public information products that meet those needs, and ways to mitigate the risk of anticompetitive behavior when publicly reporting data. 
  • Engaging Stakeholders in the Process: HPD will incorporate stakeholder perspectives into priority-setting for public reporting, and when appropriate, preview the results with affected stakeholders prior to publication.  
  • Adopting Methods to Ensure Credibility: This will be implemented by using methods that can be supported by the data and techniques which produce reliable and stable results over time, while acknowledging the limitations of data collected for other purposes (primarily billing).  In addition, HPD will use best practices when creating comparisons, including factors such as appropriate sample sizes, meaningful variation, risk adjustments, and statistical validity.  
  • Aligning with Existing Efforts: When available and appropriate, HPD will use industry accepted standardized measures while considering measurement efforts underway in California and nationally.  Lastly, HPD will coordinate with other relevant state agencies in this process.  
  • Providing Information to Support User Understanding: HPD will include information about data sources, methodology, and limitations with public information products.  To the extent possible, HPD will use language that is understandable to diverse audiences.

13. What is the budget and funding source for the HPD Program?

The HPD System will be a statewide resource and will require investment to build and operate. HCAI was appropriated $60 million in General Fund monies from the 2018-2019 Budget Act (Chapter 23, Statutes of 2019) to fund the implementation and operation of the HPD program.

Upon exhaustion of the $60 million allocation, HCAI will utilize a multi-faceted approach to fund the program including partnering with DHCS to maximize federal financial participation from the Medicaid program and charging data user fees. The Department may also accept funding from foundations not affiliated with or controlled by a healthcare entity. HCAI will need to develop a long-term funding mechanism to sustain the program. By March 1, 2023 HCAI will submit a report to the Legislature on recommendations for funding options for the program.

14. How is the HPD Program different from health information exchange?

Electronic health information exchange allows healthcare providers, including doctors, nurses, and pharmacists, to appropriately access and securely share a patient’s medical information to improve patient care. Some health information exchange organizations (HIOs) also provide enhanced services such as longitudinal patient records, event notifications, analytics, and public health and/or clinical quality measure reporting. Whereas HIOs enable the real-time, transactional exchange of patient clinical data for care coordination among providers, the HPD will collect administrative data (claims and encounters) from health plans for retrospective analyses of California’s healthcare system. The healthcare payments data are intended to support cost transparency efforts as well as to inform policy decisions regarding the provision of health care and reduce healthcare costs and disparities. 

HPD Program Advisory Committee

Pursuant Chapter 8.5 of Part 2 of Division 107 of the Health and Safety Code (HSC), §127671 et seq. HCAI is required to convene a California Health Care Payments Data (HPD) Program Advisory Committee comprised of health care stakeholders and experts to assist and advise the HCAI Director in formulating program policies regarding data collection, management, use, access, and development of public information to meet the goals of the HPD Program. The committee does not have decision-making authority related to the administration of the database but will serve as a forum for stakeholder and public engagement on policy decisions, while fostering accountability and transparency.

Additional information and upcoming Advisory Committee activities can be found in the HPD Program Advisory Committee webpage. 

HPD Program Data Submitters

The enabling legislation identifies the following entities as mandatory submitters to the HPD:  

  • Health care service plans, including a specialized health care service plan. 
  • Insurers licensed to provide health insurance, as defined in Section 106 of the Insurance Code. 
  • Self-insured plans subject to Section 1349.2, or a state entity, city, county, or other political subdivision of the state, or a public joint labor management trust that offers self-insured or multiemployer-insured plans that pay for or reimburse any part of the cost of health care services. 
  • The State Department of Health Care Services, for those enrolled in Medi-Cal and other insurance affordability programs, whether enrolled in Medi-Cal managed care, fee-for-service Medi-Cal, or any other payment arrangement. 
  • The legislation also specifies additional voluntary submitters, who can opt-in to submit their data to the HPD System.

Upcoming Activities

The Fact Sheet includes anticipated program activities from January 2022 through December 2023.  

Read the full January 2022 Fact Sheet

2022 – JANUARY TO JULY 

  • Begin registration for plans and submitters
  • Begin limited data collection and perform initial data quality and evaluation activities
  • Discuss data access and release process with HPD Advisory Committee

2022 – JULY TO DECEMBER 

  • Continue limited data collection and perform initial data quality and evaluation activities
  • Finalize database technology solution for data collection
  • Discuss options for funding options for the HPD
  • Program with the Advisory Committee

2023 – JANUARY TO JUNE 

  • Submit report to the Legislature with recommendations for funding options for the
  • Continue data quality and evaluation activities
  • Finalize data collection and complete database technical infrastructure
  • Convene Data Release Committee

2023 – JULY TO DECEMBER 

  • Begin producing initial analytic reports from the database.
  • Complete rulemaking to establish final program regulations

Contact

To receive regular informational updates about the program, subscribe to the HPD mailing list.  

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Contact HPD at hpd@hcai.ca.gov with any questions.