The Department of Health Care Access and Information (HCAI) March HPD Program Quarterly Newsletter is designed to keep stakeholders informed on programmatic updates and ongoing stakeholder engagement.
2024 HPD Program Report to the Legislature
On March 01, 2024, HCAI submitted to the California State Legislature the 2024 HPD Program Legislative Report, which focuses specifically on the completeness and quality of data included in the initial five years of historical data that have been loaded in the HPD System.
The report includes the following findings and next steps for the program:
- California’s APCD was completed on time.
- The HPD System includes all the initially planned data types, sources, and time periods.
- The HPD System reflects approximately 82% of Californians and their healthcare services.
- Efforts to expand the HPD are already underway, including adding data from dental plans and insurers, capitation payments and other non-claims payment data.
- Increasing voluntary data from private self-funded arrangements provides the biggest opportunity to increase the content and generalizability of the HPD.
- Collecting data directly from providers and suppliers on a limited basis could prove useful but would add considerable cost and complexity to the operation of the HPD Program.
- Preliminary analyses of data quality indicate that the data quality in the HPD System is reflective of and consistent with administrative data used in healthcare operations, and there are opportunities for improvement, particularly for demographic data.
- HCAI’s strong partnership with the National Association of Health Data Organizations and influence on national standards has greatly benefited the HPD Program.
- The HPD Program’s public reporting and data release functions have been successful and continue to evolve.
- HCAI has previously made recommendations to state policymakers to fully fund the HPD Program long-term, included in a March 2023 report to the legislature.
See an executive summary of the report for more information.
Proposed Revisions to CMS Data Release Policies
The Centers for Medicare and Medicaid Services (CMS) is proposing to revise its policies for accessing its CMS Research Identifiable File, proposing such access only be fulfilled within the Chronic Conditions Warehouse Virtual Research Data Center, among other changes.
While there will be an exemption for state entities to continue to receive these data, and HCAI does not expect this change to impact the HPD Program, many in HCAI’s community of researchers have expressed concern with the new apparent direction. Notwithstanding such concerns, it is validating to HCAI that CMS is proposing to take an approach of maximizing personal privacy protections using a secure research enclave, emulating California’s “enclave-first” model.
In CMS revising its data access policies, there may be an opportunity for California to open discussions about CMS allowing HCAI to re-release Medicare Fee-for-Service data through its own secure research enclave – a request many HPD stakeholders have voiced.
Should you be planning to issue a response to the RFI, you may wish to note this in your response, which can stand alongside any other messages you may wish to send to CMS about the policy. Following is sample language you may wish to use.
Should CMS move forward with implementing policies that require the use of a secure research enclave, like the Chronic Conditions Warehouse Virtual Research Data Center, it should also recognize that states like California have implemented their own secure, online research data environments as part of their all-payer claims database programs. California’s APCD, the Healthcare Payments Data Program, has a secure research enclave that meets CMS’s security requirements for IT systems.
Allowing states like California to make the CMS Research Identifiable File, the source of state APCDs’ Medicare Fee-for-Service information, available alongside commercial, Medicaid, and Medicare Advantage data, would enable authorized researchers to conduct system-wide, all-payer research in a controlled environment. Such research can advance vital understanding of the American healthcare system, in benefit of CMS’s enrollees, and promote shared goals of protecting patient privacy and maximizing data security.
The deadline to submit comments to the RFI is May 15, 2024, extended from the original
March 29, 2024, deadline.
HPD Program Updates
Reporting Manual Updated
HPD Program has updated the HCAI Reporting Manual to version 2.1. It is available here. The Reporting Manual helps HCAI with its task of implementing California’s All-Payer Claims Database. Reporting Manual version 2.0 was updated to include the rollout of the Common Data Layout (CDL) Version 3.0.1 for the collection of claims data including: enrollment, cost, utilization, and provider data. Reporting Manual 2.1 includes additional guidance related to race and ethnicity reporting.
Public Reporting
HCAI has published two analytic reports to date and set its 2024 reporting priorities with the HPD Advisory Committee at its October 2023 meeting.
The three priorities for planned reports include:
- Social Drivers of Health
- Enhancement of the planned prescription drug cost report
- Hospital Costs
HCAI will also refresh the HPD Snapshot and HPD Measures reports with new data in 2024.
HCAI anticipates continuing to advance the accessibility and usefulness of HPD public reports as the database becomes more comprehensive and complete and HCAI builds its capacity over time.
HPD Program Dental Plan Registration and Data Collection for 2024
Dental plan and submitter registration are due on March 29, 2024. All information sent to Onpoint Health Data from dental submitters will be required to be in ACDP-CDL™ V3.0.1. This is the next step for data collection for HCAI and we are looking forward to applying the same analysis and review to dental that we have for medical and pharmacy data claims.
Dental submitters will be able to submit historical (test) files until July 31, 2024. This can happen before the March 29th deadline, but the plan must be registered with Onpoint before submitting the historical data.
Historical data for dental plans and submitters covers data collected from June 29, 2017, through December 31, 2021, and it must be submitted to the Onpoint Claims Data Manager (CDM) by October 31, 2024. Dental data for the period of January 01, 2022, through October 31, 2024, must be submitted to Onpoint CDM by February 01, 2025.
HPD System Monthly Data File Submissions
Effective February 17, 2024, health plans were required to transition to the All-Payer Claims Database-Common Data Layout (APCD-CDL™) Version 3.0.1 per California Code of Regulations Sections 97300 and 97340. The HPD Program continues to process ongoing monthly data file submissions from health plans and insurers and requests data submitters to submit earlier in the month whenever possible. Data submitters are encouraged to reach out to the HCAI team if there are any concerns with meeting the reporting deadline for HPD. HCAI greatly appreciates the efforts of all data submitters in their timely submissions and those that have adjusted their submission schedules accordingly to meet HCAI’s request.
HCAI continues to conduct ongoing and regular evaluation of data quality and completeness to support both public reporting and the release of non-public data.
Program Regulations
HCAI has been preparing the following two regulations packages for the HPD Program.
- HPD Program Data Release Regulations. The HPD Data Use, Access, and Release regulations first public comment period ended July 18, 2023. A second public comment period ended February 01, 2024.
- The proposed revisions are needed to effectuate the intent of the law by clarifying requirements that are necessary to allow the public and other state agencies to access and use HPD data for the benefit of Californians while protecting the privacy of Californians. The proposed revisions will also improve compliance with data application requirements, as well as improve overall program efficiency.
- Please refer to the HCAI Laws & Regulations website to review all rulemaking documents.
- HPD Program Non-Claims Payment Data Collection Regulations. The HPD is developing regulations to collect non-claims payment data from health plans and submitters. Non-claims payments are identified as information that mandatory submitters must provide to HPD as described in Health and Safety Code section 127673. The non-claims payment regulations are anticipated to be completed by early 2025. HCAI recently published a Non-Claims Payment Data Fact Sheet which provides additional information on non-claims payment data collection efforts, including a timeline of the regulation development process and a frequently asked questions section for health plans and submitters.
- As part of the regulation development process, HCAI sent a survey on January 23, 2024, to seek input from health plans and submitters on the business processes for submitting non-claims payment data files to HPD to better understand timeframes for submitting annual and monthly non-claims payment data files, test files, and historical files. Responses were due on February 9, 2024.
- HCAI also sent a survey on March 1, 2024, to seek input from health plans and submitters to estimate the economic impact for complying with HPD non-claims data collection. Responses were due on March 15, 2024.
Participation in National Workgroups
HCAI continues to participate in the APCD Council’s APCD-CDL™ Data Maintenance Request (DMR) workgroup. Additionally, work continues with the National Association of Health Data Organizations (NAHDO) and the APCD Council on development of a national standard data collection file format for collecting non-claims payment data is expected by summer 2024.
HPD Stakeholder Engagement
HPD Program Advisory Committee
The HPD Program Advisory Committee is comprised of health care stakeholders and experts to assist and advise the HCAI Director in formulating program policies regarding data collection, data management, data use, data access, and the development of public information to meet the goals of the HPD Program. The HPD Program Advisory Committee convenes quarterly, and below is information on the most recent and upcoming meetings.
Upcoming April Meeting
On April 25, 2024, HCAI is hosting the next HPD Advisory Committee Meeting from 9:00 a.m. to 12:30 p.m. The April HPD meeting will be held in a hybrid format where committee members and members of the public can attend in person, at the Sacramento office, or via Microsoft Teams. The upcoming meeting key topics include updates on milestones for data access, standard datasets and pricing, and updates on data collection. The meeting will also include updates since the January meeting on the recommendations to HCAI regarding the approaches for the use of HPD for public health purposes, and a vote on those recommendations. The agenda and all other meeting materials will be posted on the HPD Advisory Committee web page prior to the meeting.
Past Meeting
HCAI hosted the January Advisory Committee Meeting on January 25, 2024. The meeting provided initial discussion of draft recommendations to HCAI on approaches to maximize the use of HPD for public health purposes, and an update on the data quality and completeness report, which is due to the legislature by March 1, 2024.
HCAI also received further input on reporting on out-of-pocket medical costs using HPD data, a topic that is of interest to many stakeholders and is likely to be the focus of a future public report. Committee members advised HCAI to consider health equity and the impact on vulnerable populations when reporting on out-of-pocket costs.
Materials specific to the update on data quality and completeness report is available at the following link and all remaining meeting materials are available on the January HPD Advisory Committee Meeting web page.
HPD Data Release Committee
The Data Release Committee (DRC) is integral in supporting the implementation and administration of the HPD Program and advises HCAI on the release of HPD data. The HPD DRC convenes monthly, unless otherwise stated. Below is information on the most recent and upcoming meetings.
Upcoming April Meeting
The April 17, 2024, DRC Meeting has been cancelled.
Past Meetings
The January 17, 2024, meeting covered the adoption of the DRC Manual as well as a follow up on the pricing schedule discussion started at the November meeting. Previous DRC meeting materials are available on the HPD DRC web page under the “Meetings Archive” section.
At the March 20, 2024, meeting the DRC ratified the Board Manual with all members in attendance voting in the affirmative. The committee also had a robust discussion around sample data request use cases where committee members had an opportunity to think through the types of questions they would have when reviewing requests for non-public data.
HPD Submitter Group
The HPD Program Submitter Group provides a forum for HPD Data Submitters to receive the latest information on submission requirements, troubleshoot data submissions, and address any other technical issues related to data submission. These meetings are intended for entities required to submit or are supporting the submission of data to the HPD System. The HPD Submitter Group convenes quarterly, and below is information on the most recent and upcoming meetings.
Upcoming April Meeting
The second HPD Submitter Group meeting of 2024 will be held on April 11th.Anticipated topics are the status of production file submissions, a review of reporting manual changes, and an update to Non-Claims Payments.
The agenda and all other meeting materials will be posted on the HPD Program Submitters Group website prior to the meeting. Please register to attend the virtual meeting.
Past Meetings
The most recent HPD Program Submitter Group meeting was held on January 11, 2024, and focused on key program updates, production file submission status, data quality and completeness, and transition to the APCD-CDLTM version 3.0.1. View the presentation materials available at the HPD Submitter Group website here.
Other News
On the HPD Program Submitters Page, there is a section for trainings given by Onpoint Health Data, our partners in collecting submitter data. All the training PowerPoints are available on our webpage and there is a section for Frequently Asked Questions (FAQ’s) section. If you would like to view the training videos, please contact Onpoint here, and Onpoint will provide a link to a private YouTube account.
About the HPD Program
Assembly Bill 80 (Chapter 12, Statutes of 2020) provides HCAI the authority to establish the HPD Program. The HPD System is California’s All-Payer Claims Database, or APCD, and is intended to support greater health care cost transparency, inform policy decisions supporting quality health care, and reduce health care costs and disparities.
Watch the video below to learn more about the HPD Program. Also visit HCAI’s HPD Program website or email hpd@hcai.ca.gov for any questions. Subscribe to “Healthcare Payments Database News” to receive future newsletters if this newsletter was forwarded to you.
How does the HPD Collect and Report Data? Watch this video and share it with your colleagues!
HPD Program Careers
Are you interested in joining the HCAI Team? Click below to watch for job opportunities coming soon to support the HPD Program:
