CMS-10449 SS Quality- (508) 8-14-12

CMS-10449 SS Quality- (508) 8-14-12.docx

Recognized Accrediting Entities Data Collection (45 CFR part 156.275)

OMB: 0938-1176

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Supporting Statement – Part A

Supporting Statement for Recognized Accrediting Entities Data Collection


A. Background

On March 23, 2010, the President signed into law the Patient Protection and Affordable Care Act (P.L. 111-148). On March 30, 2010, the Health Care and Education Reconciliation Act of 2010 (P.L. 111-152) was signed into law. The two laws are collectively referred to as the Affordable Care Act. The Affordable Care Act implements various policies that will make health insurance coverage more accessible to consumers. New competitive private health insurance markets (“Exchanges”) will give millions of Americans and small businesses access to affordable, quality insurance options. Exchanges will help individuals and small employers shop for, select, and enroll in private health plans that fit their needs at competitive prices. By providing a place for one-stop shopping, Exchanges will make purchasing health insurance easier and more transparent, and will put greater control and more choice in the hands of individuals and small businesses.

Section 1301 of the Affordable Care Act (ACA) requires that all qualified health plans (QHPs) be accredited by an accrediting entity that is recognized by the Secretary of Health and Human Services.

In order to recognize accrediting entities for the purposes of certification of QHPs, HHS will require the accrediting entities to submit documentation to HHS to demonstrate that they meet the conditions for recognition. HHS also requires that the accrediting entities provide certain data elements to the Exchanges once issuers authorize the release of their accreditation survey data to the Exchange. 45 CFR 156.275 requires a QHP issuer to authorize the accrediting entity that accredits the QHP Issuer to release to the Exchange its most recent accreditation survey data.

B. Justification


1. Need and Legal Basis


The final rule that was released on July 20, 2012 establishes a process for recognizing accrediting entities for the purposes of implementing section 1311(c)(1)(D)(i) of the Affordable Care Act. In order for a health plan to be certified as a QHP and operate in an Exchange, it must be accredited by an accrediting entity that has been recognized by the Secretary of Health and Human Services. The final rule establishes the first phase of a two-phased process for recognition of accrediting entities. In this first phase, the National Committee for Quality Assurance (NCQA) and URAC have been recognized as accrediting entities on an interim basis, subject to fulfilling the documentation requirements in § 156.275(c)(4). This information collection is necessary to ensure that the recognized accrediting entities meet the proposed conditions. In addition, the final rule requires that the accrediting entities provide accreditation survey data elements, including accreditation status, accreditation score, accreditation expiration date,
clinical quality measure results and adult and child CAHPS measure survey results to the Exchanges once these data are released by the issuers. Issuers will also need to provide their Health Insurance Oversight System (HIOS) issuer identifier to the accrediting entities so that their accreditation data can be linked to other issuer data in the Exchange system. This collection is necessary in order for Exchanges to verify that the QHPs being offered in their Exchange meet the accreditation requirement and are high quality plans.




2. Information Users

The information will be used by:

1. HHS to ensure that the accrediting entities meet the conditions for recognition of accrediting entities established in the final rule; and

2. Exchanges to verify that QHP issuers meet the accreditation requirement for certification and to ensure that the QHPs are high quality plans.

3. Use of Information Technology

The accrediting entities have the opportunity to submit their documentation to HHS electronically as well as to electronically transmit the accreditation survey data elements to the Exchange. Issuers should be able to electronically submit their HIOS ID to the accrediting entities.


4. Duplication of Efforts


There is no duplication of efforts. This is a new data collection.


5. Small Businesses


No small businesses will be impacted by this collection of information. Accrediting entities are the only entities impacted and do not meet the criteria to qualify as small businesses.


6. Less Frequent Collection

If the data are not collected, HHS would not be equipped to ensure that the accrediting entities meet the conditions for recognition of accrediting entities established in the final rule. In addition, if the data were not collected Exchanges would not have the opportunity to verify that QHP issuers meet the accreditation requirement for certification and to ensure that the QHPs are high quality plans.

7. Special Circumstances


There are no special circumstances associated with this data collection.

8. Federal Register/Outside Consultation

This is a new collection.  As required by the Paperwork Reduction Act of 1995 (44 U.S.C.2506 (c)(2)(A)), the Center for Consumer Information and Insurance Oversight (CCIIO) published this information collection review (ICR) concurrently with publication of the notice of proposed rulemaking (NPRM) and requested public comment by August 1, 2012, on the information collection requirements specified in the
Data Collection to Support Standards Related to Essential Health Benefits; Recognition of Entities for the Accreditation of Qualified Health Plans; Accreditation Requirement in the Federally-facilitated Exchange PRA, (OMB Control No. 0938-NEW).  No public comments were received regarding this ICR. In addition, both recognized accrediting entities who submitted comments on the NPRM did not state anything regarding the information collection burden and requirements.


9. Payments/Gifts to Respondents


No payments or gifts were made to any respondents.


10. Confidentiality

None of the information being collected is proprietary or personally identifiable information.

11. Sensitive Questions


No sensitive questions are asked in this data collection.


12. Burden Estimates (Hours & Wages)

Burden on Accrediting Entities

The burden is on NCQA and URAC to submit documentation to HHS and also to provide data from the accreditation survey to the Exchange.

As stated in section 156.275(c)(5), HHS requires that NCQA and URAC provide documentation on their current accreditation standards and requirements, processes and measure specifications for performance measures to demonstrate that each entity meets the proposed conditions for recognition. Recognized accrediting entities will also need to submit any proposed changes or updates to the accreditation standards and requirements, processes, and measure specifications 60 days prior to implementation. HHS expects that these proposed changes would happen annually. The burden associated with meeting this requirement includes the time and effort needed by the accrediting entity to compile the documentation and submit the information electronically to HHS.  The only associated costs are labor costs.

In addition, HHS is requiring that the accrediting entities submit accreditation survey data elements to the Exchanges. The burden associated with meeting this requirement includes the time and effort to collect the HIOS ID from issuers, organize the data to fill the templates provided by every Exchange (we are assuming 51 State-based Exchanges) and submitting the data to every Exchange on a monthly basis as these data are updated.


Data Element

# of Employees Needed

Cost of Reporting

Burden Hours

Cost of Reporting (per response)

# of Responses per Respondent (per year)

Total Burden Hours (per year)

Total Burden Costs (per year)

Documentation








Compilation/
Submission of documentation

1

$55.00

2

$110.00

1

2

$110.00

SUBTOTAL



2

$110.00

1

2

$110.00

Data Sharing








Collect HIOS ID from Issuers

1

$55.00

17

$940.00

1

17

$940.00

Organize Data Feed to Exchange

1

$55.00

255

$14,025

1

255

$14,025

Submit Data to Exchange

1

$55.00

51

$2,805

12

612

$33,660

SUBTOTAL



323

$17,770

14

884

$48,625


Below is the total estimate of the annual burden across the two accrediting entities that are subject to the reporting requirements of this rule.



Data Element

# of Respondents

Total Number of Responses (all Respondents

Total Number of Hours

Total Burden Cost (per year)

Documentation

2

2

4

$220.00

Data Sharing

2

28

1,768

$97,250

TOTAL


30

1772

$97,470


13. Capital Costs


There are no anticipated capital costs associated with this data collection.


14. Cost to Federal Government


There are no additional costs to the Federal government.

15. Changes to Burden


This is a new data collection resulting in an increase of 1772 annual burden hours.


16. Publication/Tabulation Dates


There is no publication associated with this data collection.

17. Expiration Date


The expiration date will be displayed.


18. Certification Statement

There are no exceptions to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

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