CMS-10515_PaymentCollectionsOperationsContingencyPlanSupporting

Supporting Statement – Payment Collections Operations
Contingency Plan: Enrollment and Payment Data Template
A. Background
On March 23, 2010, the President signed into law H.R. 3590, the Patient Protection and
Affordable Care Act (the Affordable Care Act), Public Law 111-148. This law establishes
American Health Exchanges (Exchanges, or Marketplaces) where issuers may sell Qualified
Health Plans (QHPs) and where consumers may receive subsidies based on income to
purchase affordable health care. The statute requires the Department of Health and Human
Services (HHS) to operate Marketplaces in States that decline to establish their own. On
October 1, 2013, HHS began operating Marketplaces on behalf of enrollees in 35 states.
B Justification
1. Need and Legal Basis
Under sections 1401, 1411, and 1412 of the Affordable Care Act and 45 CFR part 155 subpart
D, an Exchange makes an advance determination of tax credit eligibility for individuals who
enroll in QHP coverage through the Exchange and seek financial assistance. Using information
available at the time of enrollment, the Exchange determines whether the individual meets the
income and other requirements for advance payments and the amount of the advance payments
that can be used to pay premiums. Advance payments are made periodically under section 1412
of the Affordable Care Act to the issuer of the QHP in which the individual enrolls. Section
1402 of the Affordable Care Act provides for the reduction of cost sharing for certain
individuals enrolled in a QHP through an Exchange, and section 1412 of the Affordable Care
Act provides for the advance payment of these reductions to issuers. The statute directs issuers
to reduce cost sharing for essential health benefits for individuals with household incomes
between 100 and 400 percent of the Federal poverty level (FPL) who are enrolled in a silver
level QHP through an individual market Exchange and are eligible for advance payments of the
premium tax credit.
As HHS’s enrollment and payment processing systems are not yet operational, HHS needs a
means of obtaining enrollment and payment information via an alternative collection tool—the
Enrollment and Payment Data template in order to be able to make payments to issuers on
behalf of eligible enrollees.
2. Purpose and Use of Information Collection
The data collection will be used by HHS to make payments or collect charges from issuers
under the following programs: advance payments of the premium tax credit, advanced costsharing reductions, and Marketplace user fees. The template was used to make payments in
January 2014 and will continue for a number of months thereafter, as may be required based on
HHS’s operational progress.
3. Use of Improved Information Technology and Burden Reduction

All information collected in the Enrollment and Payment Data template will be submitted
electronically via email using a password-protected Microsoft Excel-based spreadsheet. HHS
staff will analyze the data electronically and communicate with issuers and State-based
Marketplaces, if necessary, by email and telephone. A financial authority contact of the
issuer will submit a form electronically to HHS certifying that the information provided as of
the submission date is complete and accurate to the best of his or her knowledge.
4. Efforts to Identify Duplication and Use of Similar Information
This is a new program created under the Affordable Care Act and the information to be
collected has never been collected before by the federal government.
5. Impact on Small Businesses or Other Small Entities
No impact on small business.
6. Consequences of Collecting the Information Less Frequently
HHS makes payments and collects charges under these programs monthly. If HHS does not
collection this information on a monthly basis, HHS will be unable to calculate monthly
payment or charge for issuers providing health insurance to enrollees in Marketplace QHPs.
7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
No special circumstance.
8. Comments in Response to the Federal Register Notice/Outside Consultation
HHS alerted issuers and State-based Marketplaces to a payment process contingency plan at the
end of November 2013. On December 2, 2013, HHS held a webinar describing the step-bystep process that issuers would use to complete the template and the process for testing the
template prior to production. HHS posted the webinar training materials to www.regtap.info,
and provided additional technical support to issuers through webinars on December 9, 2013 and
December 11, 2013.
On December 4, 2013, issuers received an email from [email protected] that
included the test data template in a Microsoft Excel file along with detailed instructions for
populating the template. Approximately 400 issuers returned this template to HHS on
December 10. HHS tracked the unreturned templates to issuers that do not expect payments
because they are stand-alone dental plans or SHOP-only Marketplaces. A follow-up discussion
for users in advance of production of the actual template data described in this supporting
statement was held on December 16, 2013. Additional sessions in the technical support series,

“Marketplace Payment Processing User Group Series,” were conducted, as necessary, for
issuers that resubmitted templates at HHS’s request. HHS posts all Q&As from issuers during
training calls to www.regtap.info.
The 60-day Federal Register notice for this information collection published on January 31,
2014 (79 FR 5417). In response to our request for comment, CMS received one comment
suggesting that CMS define what a successful transition from the payment contingency plan to
the implementation of the HIX 820 entails. Appendix A addresses the commenters concern.
9. Explanation of any Payment/Gift to Respondents
Respondents will not receive any payments or gifts as a condition of complying with this
information collection request.
10. Assurance of Confidentiality Provided to Respondents
No personal information is being collected. While the enrollment and payment processing
systems would have collected enrollee-level information, this contingency process collects
information aggregated by QHP issuer. All information will be kept private to the extent
allowed by applicable laws/regulations.
11. Justification for Sensitive Questions
No sensitive information will be collected
12. Estimates of Annualized Burden Hours (Total Hours & Wages)
We estimate the burden associated with a one-time development of systems for all QHP issuers
expecting to receive payments, monthly input of enrollment and payment numbers,
aggregation of policy-level amounts to the QHP level, and electronic submission of data to
HHS. To complete the Enrollment and Payment Data template, each issuer will need to
collect, analyze, and aggregate QHP enrollee and payment information, read HHS instructions,
enter data into a Microsoft Excel-based template, and submit this template to HHS. This may
require a new information system or variation to an existing system. We estimate that it will
take two working days per issuer (16 hours per issuer, at a cost of $59.39 per hour, reflecting
fully loaded costs of a mid-level information system specialist) to develop the system. Once the
template is built, we estimate it will take 12 hours each month (by a payment operations
analyst at an hourly wage of $38.49) to enter current data for each month during which the
contingency payment process is in place and submit this data to HHS. Although we recognize
that some QHP issuers that do not expect to receive payments and are not required to pay user
fees, we broadly estimate that 575 QHP issuers will submit the Enrollment and Payment Data
template. We assume that the Enrollment and Payment Data template will be used for twelve
months, resulting in a burden of 160 hours and $6,493 per QHP issuer, or an aggregate of
92,000 hours and $3,733,475 for all QHP issuers.

We note that this template was used in January 2014, but we expect it to be replaced by the
HHS enrollment and payment processing systems later in 2014. We expect that HHS may
modify this template slightly to allow issuers to report enrollment and payment discrepancies
resulting from payments in January 2014. In this case, HHS would post the revised template
for public comment and OMB approval.
Along with the Enrollment and Payment Data template, a financial authority contact of the
issuer (i.e., CEO, CFO, or other authorized designee) submits a form electronically to HHS
certifying that the information provided as of the submission date is complete and accurate to
the best of his or her knowledge and will be the primary basis for the calculation of the payment
amount. The financial authority contact indicates the HIOS issuer IDs for which the certification
applies. We estimate that it will take a CEO or other designee approximately 10 minutes (at an
hourly wage rate of approximately $117) to complete this certification for each month that data
is submitted through the template. While a financial authority contact may complete one
certification that applies to multiple HIOS issuer IDs, we believe that most financial authority
contacts will complete one form that covers only one HIOS issuer ID, such that approximately
575 certification forms will be submitted for 575 QHP issuers for each month that data is
submitted through the template. Therefore, we estimate an aggregate burden of approximately
96 hours and $11,213 each month as a result of this payment data certification requirement. We
estimate an overall annual burden of 1,152 hours and $134,556 for all QHP issuers as a result of
this requirement.
12A. Estimated Annualized Burden Hours
Microsoft
Excel based
Template

QHP issuer

400

1

Average
Burden
hours per
Response
3

Enrollment and QHP issuer
Payment Data
template
(start-up)
Monthly data
QHP issuer
reports
Monthly Data
QHP issuer
Submission
Accuracy
Certification
Form
Total

575

1

16

9,200

575

12

12

82,800

575

12

0.17

1,173

575

26

Testing &
Development

Type of
Respondent

Number of
Number of
Respondents Responses per
Respondent

Total
Burden
Hours
1,200

94,373

12B. Cost Estimate for All Respondents Completing the Template
Type of
respondent

Number of
Respondents

Information
Systems
specialist
Senior Manager
Payment
Operations
Specialist
Chief Executive
or Designated
Financial
Authority
Contact
Total

575

Number of
Responses
per
Respondent
1

Average
Burden
Hours

575
575

13
13

6
12

575

12

0.17

13

Wage per
Hour
(including
fringe)
$59.39

Total Labor
Costs

$77
$38.49

$3,453,450
$3,452,553

$117

$137,241

$443,940

$7,487,184

1 This burden will be in effect only during the HHS contingency payment processing plan. Because we do not know
when the HHS permanent payment and collections system will be operational, we are estimating burden for 12 months in
2014, which is the full duration for which we are requesting approval.

13. Estimates of other Total Annual Cost Burden to Respondents or Record Keepers
/Capital Costs
There are no additional recordkeeping or capital costs.
14. Annualized Cost to Federal Government
The calculations for CCIIO employees’ hourly salary was obtained from the OPM website, with
an additional 35% to account for fringe benefits.
Task
Data Processing, Managerial Review, and Oversight
2 GS-12: 2 x $48.44 x 20 hours
1 GS-15: 2 x $80.06 x 4 hours
Total Costs to Government

Estimated Cost
$1,938
$640
$2,578

15. Explanation for Program Changes or Adjustments
This is a new data collection required by the Affordable Care Act.
16. Reason(s) Display of OMB Expiration Date is Inappropriate
Not applicable. We plan to include an OMB expiration date once assigned an OMB control
number.

17. Exceptions to Certification for Paperwork Reduction Act Submissions
There are no exceptions to the certification.
B. Collection of Information Employing Statistical Methods
Not applicable. The information collection does not employ statistical methods.