CMS-10433 - QHP PRA Supporting Statement A

Supporting Statement for Continuation of Data Collection to Support QHP
Certification and other Financial Management and Exchange Operations
(OMB Control No. 0938-1187, Expiration Date 6/30/2018)

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
(ACA). The ACA establishes new competitive private health insurance markets called Affordable
Insurance Exchanges (Exchanges), or Marketplaces, which give millions of Americans and small
businesses access to affordable, quality insurance options. By providing a place for one-stop shopping,
Exchanges make purchasing health insurance easier and more transparent, and put greater control and
more choice in the hands of individuals and small businesses. Additionally, reinsurance, risk corridors,
and risk adjustment programs provide market stabilization to lower costly premiums associated with
individual and small business coverage.
As directed by the rule Establishment of Exchanges and Qualified Health Plans; Exchange Standards for
Employers (77 FR 18310) (Exchange rule), each Exchange will assume responsibilities related to the
certification and offering of Qualified Health Plans (QHPs). To offer insurance through an Exchange, a
health insurance issuer must have its health plans certified as QHPs by the Exchange. A QHP must meet
certain minimum certification standards, such as network adequacy, inclusion of Essential Community
Providers (ECPs), and non-discrimination. The Exchange is responsible for ensuring that QHPs meet
these minimum certification standards as described in the Exchange rule under 45 CFR 155 and 156,
based on the ACA, as well as other standards determined by the Exchange.
Issuers can offer individual and small group market plans outside of the Exchanges that are not QHPs.
Such plans are referred to in this document as “non-Exchange.” The reinsurance and risk adjustment
programs outlined by the ACA, detailed in the rule Standards for Reinsurance, Risk Corridors, and Risk
Adjustment (77 FR 17220), have general information reporting requirements that apply to QHPs offered
through the Exchanges and non-Exchange plans in the outside market. For the reinsurance program,
administrative information is used to identify all entities required to contribute to the reinsurance program
by state. In addition, non-Exchange plan information such as plan type and location is used to identify
non-grandfathered individual market plans eligible by state for reinsurance payments. For the risk
adjustment program, administrative information is used to identify all non-grandfathered small group and
individual market non-Exchange plan offerings eligible for the program. Risk adjustment also requires
select data such as rating area, rating factors, and actuarial value (AV) level, to perform calculation of
payments and charges.
On March 13, 2013, the Office of Management and Budget (OMB) granted approval to the data collection
Initial Plan Data Collection to Support QHP Certification and other Financial Management and
Exchange Operations (OMB Control Number 0938-1187). CMS revised this data collection twice since
that date, and OMB most recently approved the second revision on June 30, 2015. This certification is
valid for three years and expires on June 30, 2018. This Information Collection Request (ICR) serves as a
formal request for the renewal of the data collection clearance. It also includes the request for revisions to
previously approved data collection instruments. Based on changing needs of the Exchanges, revisions to
this data collection will be applicable for 2017 certification and beyond. The 60-day comment period
ended on October 2, 2015, and CMS received seven comments. Revisions are now proposed through the
publication of a 30-day Federal Register notice for public comment. Several of these instruments will be
used for 2017 QHP certification, in conjunction with some of the instruments that were previously
approved under this information collection last year. We intend to use the instruments in this information
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collection for the 2017 certification process and beyond and believe that providing these instruments now
will give issuers and other stakeholders more opportunity to familiarize themselves with the instruments
before releasing the 2017 application. While we intend to use these instruments in 2017, we may propose
further revisions to this data collection in the future as necessary, including for 2017, and also reserve the
ability to use the instruments that were previously approved in 2014. Additionally, there are some
collections that we do not intend to implement until 2018 or beyond.

A.1

Circumstances Making the Collection of Information Necessary

QHP Information Collection: Certification and Standards
An Exchange certifies, recertifies and decertifies QHPs. The ACA authorizes QHP certification as well as
other operational standards for the Exchange in following sections: 1301- 1304, 1311-1312, 1321-1322,
1324, 1334, 1401-1402, 1411 and 1412. Standards for QHP issuers are codified at 45 CFR parts 155 and
156.
An Exchange needs to collect data from issuers as part of QHP certification and recertification, and to
monitor compliance with QHP certification standards on an ongoing basis. QHP issuer and plan data also
supports additional operational activities, including the calculation of each individual’s advance payment
of the premium tax credit (APTC), the display of plan information on the Exchange website, and
managing the ongoing relationships between QHP issuers and the Exchange. Feedback about the QHP
certification and recertification process is collected from issuers in an effort to improve the efficiency and
effectiveness of data collection. Much of the information collected for QHP certification purposes
supports these operational activities on an ongoing basis.
Stand-Alone Dental Plan Information Collection
Section 1311 of the Affordable Care Act and 45 CFR 155.1065 direct each Exchange to permit issuers to
offer limited scope dental benefits as stand-alone dental plans or in conjunction with a QHP. All
reasonably applicable QHP certification requirements apply to stand-alone dental plans offered in an
Exchange, and dental issuers are required to complete the same application as all other QHPs. However,
dental issuers will only be required to complete applicable data elements such as: Licensure and Good
Standing; Network Adequacy; Essential Community Providers; and Actuarial Value. An Exchange needs
to collect data from dental issuers in order to certify and recertify stand-alone dental plans, and to monitor
ongoing compliance with applicable QHP certification standards. This data allows the Exchange to
understand the difference between an estimated and actual rate or to calculate the portion of an
individual’s premium tax credit allocated to a stand-alone dental plan, and display plan and premium
information for these plans.
Necessary Data for QHP Certification
The data collected for QHP certification, recertification, ongoing QHP oversight, financial management,
and eligibility and enrollment functions (including HealthCare.gov) are reflected in the categories
identified below and in the attached appendices. This data is also used to support other Exchange business
functions such as determinations of the second-lowest-cost-silver plan, payments for cost-sharing
reductions (CSRs), APTCs, and the display of information on HealthCare.gov. The data collection
requirements apply to stand-alone dental plans as applicable and discussed in template instructions that
accompany the release of the final templates annually. CMS also seeks approval to collect issuers’ logos;
data to support and apply state-specific laws and requirements, such as premium payment method
requirements, premium payment grace period non-APTC requirements, dependent age limits, fraud
definitions and termination data parameters, and state provisions that allow consumers to have a “free
look” at coverage documents and cancel coverage within a specified time frame for a full refund of
premium; and other information as needed to support QHP certification. CMS also collects information
from Small Business Health Options Program (SHOP) QHP issuers on whether they will allow plan year
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rates to be established based on composite (or average) rates of employees and dependents at the time of
initial application. CMS collects information from SHOP QHP and dental issuers on whether benefits are
based on a plan year or calendar year.
CMS will collect the following data to support these functions. The QHP certification templates are
provided in Appendices A-K. For each appendix, file names marked “508” represent the 508 compliant
template version. Thus, for Appendices A-K, there are two versions of each template. In addition to the
templates, see Appendix L, QHP Certification Instrument Screenshots, for the screenshots of all the data
collection instruments, which includes notations for those instruments with revisions. CMS seeks
comment on the instrument changes reflected in Appendices A-K.
A.1a: Issuer Application Data
• Issuer Administrative Data Elements: Basic information required to identify issuers and the
Exchange markets they intend to serve, and to facilitate communications with and payment to
issuers. The data elements may include issuer contact information and banking information.
• Network Adequacy/Essential Community Provider (NA/ECP) Data Elements: This new
template combines the former Network Adequacy and Essential Community Provider templates,
which were two separate templates. The content captured in the combined template is largely the
same as what was captured in the two previous templates. CMS seeks to create efficiencies through
combining the templates. Number of participating Essential Community Providers participating in
an issuer's provider network or other documentation necessary to demonstrate that that an issuer has
an adequate range of ECPs for the intended service areas. CMS proposes capturing the number of
practitioners with whom the issuer has contracted to identify more than one provider at a single
facility.
The documentation demonstrates compliance with network adequacy standards. CMS proposes
capturing what tier the specific facility and provider belongs to and the cost information for the
corresponding tier, if applicable.
• Accreditation Data Elements: If applicable, an issuer must provide certain data elements about
accreditation conducted by any recognized accrediting entity, including URAC, the National
Committee for Quality Assurance (NCQA), or the Accreditation Association for Ambulatory
Health Care (AAAHC). Issuer must also authorize the release of accreditation survey data to an
Exchange.
• Network ID and Provider Directory URL Data Elements: Network ID numbers identifying each
provider network for purposes of plan-to-network mapping and specific URLs associated with the
provider directory for each plan.
• State Licensure Documentation: Documentation necessary to demonstrate that an issuer is
licensed and has authority to sell all applicable products in all states in which it intends to offer a
QHP.
• Documentation of Good Standing: Documentation necessary to demonstrate that an issuer is in
compliance with all applicable state solvency requirements and other relevant state regulatory
requirements.
• Provider File: Information detailing the QHP issuer’s provider network, including information
such as provider name, county, and type.
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• Supporting Documentation: Additional documentation required by the Exchange for oversight
purposes such as a compliance plan including an organization chart.
• Attestations: Attestations regarding compliance with applicable regulation.
A.1b: Benefit and Service Area Data
• High-level Plan Data: Basic plan- level information for plans and products including information
necessary for in-network and out-of-network deductibles and maximum out-of-pocket cost by
benefit category.
• Benefits and Associated Cost Sharing and Limits: Data necessary to describe benefits offered by
a plan including covered services, co-payments, coinsurance, tiers, intervals, and limits. CMS
proposes capturing whether each plan has a particular cost sharing design, benchmark plan type,
and information about whether a certain number of mental health, substance abuse, or specialist
visits are subject to different cost sharing. In addition, CMS proposes capturing the Essential Health
Benefit (EHB) category for each service and capturing visit and service limitations for EHB. CMS
also proposes capturing a plan marketing name for each variant, capturing additional Summary of
Benefits and Coverage (SBC) scenarios, collecting cost share and limitations for Mental
Health/Substance Use office visits, and collecting cost share information for Emergency Mental
Health and Substance Use services.
• Summary of Benefits and Coverage Data Reporting Requirements: Data elements from the
Summary of Benefits and Coverage scenarios for display on the Exchange website.
• Formulary Information including Tiers and Classes: Formulary information including RxNorm
Concept Unique Identifiers (RxCUIs), pricing tiers, co-insurance, co-payment information, drugs
included in the formulary, formulary version number, and its effective date. CMS proposes
capturing quantity limits, fill limits and pharmacy restrictions for each RxCUI listed, as well as
Over-the-Counter (OTC) step therapy protocol.
• Service Area: Information identifying a plan’s geographic service area.
• Additional Supporting Documentation: Additional documentation required by the Exchange such
as discrimination/cost sharing outlier justifications. Information to support the completion of the
Mental Health Parity review may be required for submission by the issuer in the future.
A.1c: Rating Tables and Issuer Business Rules Data

CMS does not propose changes to these data.
• Premium Rating Information and Business Rules: Rating tables, factors and business rules
required to perform rate review, populate the premium calculator and perform calculations for risk
adjustment. Information will include collecting secondary eligibility criteria, such as grandchild,
adult child, disabled dependent, spouse, and life partner.
• Partial Month Premium Calculation Rule: Rules and/or formulas to support the calculation of
partial month premiums.

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The following information will be collected for QHP certification and the burden is defined, as
applicable, in Rate Increase Disclosure and Review Requirements (45 CFR Part 154), OMB Control
Number CMS – 10379. CMS does not propose changes to these data.
• Rate Review Data Elements: Financial information by market and product necessary for rate
review and the evaluation of CSR payments. This could include: base period claims experience,
projected period medical trend factors, and projected period administrative factors.
• EHB and Additional Coverage Data including Allocation of Premium Information: Data
required to determine the allocation of premiums for EHB and those services offered in excess of
EHB.
• CSR Advance Payments and Justification: Data to support the payments for CSRs. The
information will also support the variations in AV levels for CSR silver plan variations.
• Actuarial Memorandum: Actuarial narrative and certification required for the review of rates for
rate review, premium allocation for APTCs, and CSR payment.
Non-Exchange Plan Information Collection: Reinsurance and Risk Adjustment
Section 1341 of the ACA provides that each state will establish a transitional reinsurance program to help
stabilize premiums for coverage in the individual market from 2014 through 2016. Section 1343 provides
that each state will establish a permanent program of risk adjustment for all non-grandfathered plans in
the individual and small group markets. If a state chooses not to actively participate in reinsurance and/or
risk adjustment, CMS will be responsible for implementation. The requirements for issuers with plan
offerings outside of the Exchanges are codified at 45 CFR 153.
Reinsurance Reporting Requirements for non-Exchange Plans
The temporary reinsurance program will reduce the uncertainty of insurance risk in the individual market
by making payments for high-cost enrollees. Health insurance issuers and self-insured group plans are
required to remit contributions on behalf of certain enrollees in certain major medical coverage, and thus
are collectively referred to as “contributing entities.” Self-insured group health plans may remit their
reinsurance contributions through a third party administrator or an administrative services only contractor.
Non-grandfathered individual market plans are eligible to request and receive payments.
CMS will collect all contributions under the uniform reinsurance contribution rate, regardless of whether
a state is operating a reinsurance program. CMS will operate reinsurance payment functions for a state
when the state defers operating of the program to CMS.
In order to effectively identify and contact “contributing entities” and third party administrators (and
administrative services only contractors) administrative information, such as name, location, and contact
for company, is needed. In addition, in order to identify eligible plans for reinsurance payments, planlevel information is needed for non-grandfathered, non-Exchange plan offerings in the individual market.
Risk Adjustment Reporting Requirements for Non-Exchange Plans
The permanent risk adjustment program provides payments to health insurance issuers that
disproportionately attract high-risk populations (such as those with chronic conditions), thereby reducing
the incentives for issuers to avoid higher-risk enrollees. Under this program, funds are transferred from
issuers with lower risk enrollees to issuers with higher risk enrollees.

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A “risk adjustment covered plan” includes most health insurance plans offered in the individual or small
group market. The exceptions are grandfathered health plans, group health insurance coverage described
in 45 CFR 146.145(c), individual health insurance coverage described in 45 CFR 148.220, and any other
plan determined not to be a risk adjustment covered plan in the applicable Federally-certified risk
adjustment methodology. States, or CMS on behalf of a state, will require basic identifying information
about all risk adjustment covered plans, whether or not they are QHPs.
Necessary Data for Reinsurance and Risk Adjustment Operations
Frequency of collection and types of information to be collected is determined by CMS.
A.1d: Transitional Reinsurance and Risk Adjustment Operations Data
CMS does not propose any changes to these data. (See Appendix M, RI RA Programs and Payment Ops
Data Requirements.) CMS finalized changes Data necessary for reinsurance and risk adjustment
operations include:

• Administrative Data Elements: Basic information required to facilitate communications regarding
reinsurance contributions and payments, risk adjustment charges and payments, and other financial
program payments. The data elements may include issuer contact information and banking
information.
• EDGE Server Registration and Provisioning Data Elements: Data elements related to EDGE
Server registration activities, including applicable attestations and agreements, and provisioning of
the Amazon Web Services (AWS) EDGE Server and the Issuer On-Premise EDGE server.
• State Licensure Data Elements: Documentation necessary to demonstrate that an issuer is
licensed and has authority to sell all applicable products in all states in which they intend to offer
plan.

• Plan Level and Additional Coverage Data Entities: Plan information to include market
participation, plan type, and basic plan characteristics such as location.
Data for risk adjustment operations includes:
•

Premium Rating Information and Business Rules: Factors, rating areas and business rules
required to perform calculations for risk adjustment.

A.2 Purpose and Use of Information Collection
The Exchange collects plan- and issuer-level data from issuers to facilitate the certification and
recertification of QHPs, Exchange operations, other Federal operations, QHP oversight, and ongoing
market analysis. All of this data is leveraged across multiple business areas in the Exchange to facilitate
other operational tasks such as plan comparisons on the insurance portal and various payment activities,
such as determination of the second lowest cost silver plan, APTCs, or risk adjustment.
In addition, CMS will collect organizational and plan-level data from issuers, self-insured group health
plans and third party administrators (and administrative services only contractors). The data will include
administrative data, financial data, and rate and benefit data. This data will be used to remit payments and
to operate the premium stabilization programs.

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A.3 Use of Information Technology and Burden Reduction
CMS has and continues to engage with states, issuers, and the National Association of Insurance
Commissioners (NAIC) in the effort to develop data standards for QHP certification, reinsurance, risk
adjustment, and other plan management activities that would make reporting to the Exchanges more
streamlined for issuers across the country, and allow them to submit information in a manner that is
standardized to the greatest extent possible.

A.4 Efforts to Identify Duplication and Use of Similar Information
CMS will make every effort to reduce the burden on issuers and reuse the information that is collected
under the various provisions of the ACA. As such, data obtained under other authorized collections
implementing provisions of the ACA will be utilized to meet some Exchange requirements, for example
in Rate Increase Disclosure and Review Requirements (45 CFR Part 154), OMB Control Number CMS –
10379. CMS will make every effort to avoid duplication of data collections with these other efforts. CMS
is developing an integrated modular collection instrument and database system to support these various
needs.

A.5 Impact on Small Businesses or Other Small Entities
Small businesses are not significantly affected by this collection.

A.6 Consequences of Collecting the Information Less Frequently
QHPs will be certified utilizing an annual certification process. The year two and three burden estimates
include estimates for recertification, as noted in section A.12 below. We will continue to reassess the
certification and recertification burden and make every effort to minimize burden as much as possible in
the future.
Non-Exchange plans that are reinsurance-eligible plans, reinsurance contributing entities, or risk
adjustment covered plans must submit data for the purposes of facilitating program operations. This
information is submitted once annually and then updated when applicable throughout the year.

A.7 Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
Issuers submitting in the SHOP Exchange have the option to submit formulary, rate and benefit
information more frequently; therefore, additional submissions may be necessary.

A.8 Comments in Response to the Federal Register Notice and Efforts to Consult Outside
Agency
The goal of this data collection is to inform the QHP certification and recertification process, as well as
non-Exchange plan reporting requirements needed for the reinsurance and risk adjustment programs. CMS
has also continued to receive extensive feedback from key stakeholders. This included discussions, such
as webinars and user groups calls with the NAIC, states, issuer associations, and issuers on the data
elements and collection. It is the goal of CMS and stakeholders to identify shared data points and improve
the validity of data. CMS will continue to work with states to minimize any required document
submission to streamline and reduce duplication.
The 60-day Federal Register Notice was published on August 3, 2105 on pages 45979-45980. Seven
responses were received. The comments included questioning the inclusion of various new data elements
on the templates and requesting the rewording of questions for clarity. For the complete list of comments
and responses, see Appendix N, QHP Certification 60-Day Comment Summary Responses.

A.9 Explanation of any Payment of Gift to Respondents
There are no payments or gifts to respondents.
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A.10 Assurance of Confidentiality Provided to Respondents
Information collected for plan management, reinsurance and risk adjustment contains proprietary
information, trade secret, commercial and/or financial information. Therefore it is privileged, private to
the extent permitted by law, and protected from disclosure.
These data are protected from disclosure under Exemption 4 of the Freedom of Information Act (FOIA).
Exemption 4 is provided below and is part of the HHA FOIA implementation regulation (45 CFR 5.65)
available at http://www.hhs.gov/foia/45cfr5.html#Subf.

A.11 Justification for Sensitive Questions
No sensitive questions are asked in this PRA package.

A.12 Estimates of Hour Burden Including Annualized Hourly Costs
The burden associated with this data collection can be attributed to QHP issuers, non-Exchange plan
issuers, larger group issuers, self-insured, third party-administrators, and states. We developed these
burden estimates based off CMS’s experience collecting similar categories of data from issuers in the
Medicare Advantage and Prescription Drug Benefit Programs, Federal Rate Review Program, and
Healthcare.gov reporting, and based on experience with QHP certification to date. The burden for each of
these entities was considered when developing these burden estimates. We have modified the burden
estimates that were approved in the package on April 16, 2014. The revised figures reflect projections
based on actual experience since receiving the initial approval. We have included information on the
original year one, two, and three estimates in footnotes.
Burden for QHP Issuers: QHP Certification 1
The burden on issuers for the QHP certification (including issuer application, rate and benefit submission,
and formulary submission) per year is estimated to be 88,200burden hours, or 196 hours per issuer. This
estimate is based on an assumed 450 issuers each offering 20 plans. The burden estimate includes data
required for QHP certification, risk adjustment, and reinsurance. We have adjusted the burden to account
for feedback on the certification and recertification process. We have further revised these estimates, in
terms of the number of issuers. We estimate 450 issuers will incur costs for QHP certification, risk
adjustment, and reinsurance. We developed this number based upon the number of applications received
from issuers for the 2016 plan year in addition to the expectation that additional issuers will apply in
future years.
Table 1. Burden for QHP Issuers: QHP Certification

Year

Number of Issuers Hours Per Issuer Total Hours Total Burden Cost Per
Issuer
450

196

88,200

$15,092

450

196

88,200

$15,092

Four
Five

1

In the previous package for this data collection, as approved April 16, 2014, for year one, two, and three we
estimated a total of 475 issuers and a total of 147 hours per issuer, for a total burden of $11,319 per issuer and
69,825 hours across all issuers.

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Six

450

196

$15,092
88,200

Burden for Stand-Alone Dental Issuers: QHP Certification 2
The burden on stand-alone dental issuers for the QHP certification each year is estimated to be 20,000
total burden hours, or 80 hours per issuer. It is estimated that 250 issuers offering 3 plans each will
participate in an Exchange or go through the certification process to offer an Exchange-certified SADP
off the Exchange. The number of issuers is based on the number of applications for 2016 and the increase
in hours accounts for a better estimate based on actual experience, and takes into account off-Exchange
SADPs, which will have less burden. At an hourly billing rate of $77, the total cost was estimated to be
$6,160 per issuer. The estimates also include recertification for SADP issuers.
Table 2. Burden for Stand-Alone Dental Issuers: QHP Certification

Year

Number of Issuers Hours Per Issuer Total Hours Total Burden Cost Per
Issuer

Four

250

80

20,000

$6,160

Five

250

80

20,000

$6,160

Six

250

80

20,000

$6,160

Burden for Non-QHP Issuers and QHP Issuers (for plans outside the Exchange) Offering Plans in
the Individual and Small Group Market: Reinsurance and Risk Adjustment 3
All issuers in the individual and small group market are required to submit reference data, to include but
not be limited to administrative information about the issuer and its non-QHP offerings, AV levels for
those plans, which will be used for the reinsurance and risk adjustment programs. It is estimated there are
2,400 issuers in the individual and small group market that will not be offering any QHPs through an
Exchange. The total estimated burden for the submission for these issuers is 7,800 hours or 3.25 hours per
issuer at a cost of $250 per issuer per year.
Table 3. Burden for Non-QHP Issuers and QHP Issuers Offering Plans in the Individual and Small
Group Market: Reinsurance and Risk Adjustment

Year

Number of Issuers Hours Per Issuer Total Hours Total Burden Cost Per
Issuer

2

In the previous package for this data collection, as approved April 16, 2014, we estimated the total year-one, two,
and three cost to be $3,080 per issuer for a total of 40 hours per issuer and estimated that 500 issuers would
participate.
3
In the previous package for this data collection, as approved April 16, 2014, we estimated the total year-one, two,
and three cost to be $231 per issuer for a total of 3 hours per issuer.

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Four

2,400

3.25

7,800

$250

Five

2,400

3.25

7,800

$250

Six

2,400

3.25

7,800

$250

Burden for Large Group Issuers, and Self- Insured Group Plans and Third-Party
Administrators: Reinsurance 4
Some issuers in the large group market, self-insured group plans, and third-party administrators on behalf
of either will be required to submit administrative information for reinsurance contributions. It is
estimated that 23,800 entities are eligible reinsurance contributors. The total estimated burden for this
submission is 119,000 or 5 hours per entity, at a cost of $385 per entity.
Table 4. Burden for Large Group Issuers, and Self- Insured Group Plans and Third-Party
Administrators: Reinsurance

Year

Number of Entities Hours Per Entity Total Hours Total Burden Cost Per
Entity

Four

23,800

5

119,000

$385

Five 23,800

5

119,000

$385

Six

5

119,000

$385

23,800

Burden for States: State-based Exchanges and Partnership States 5
CMS projects that all states that have received any type of Exchange grant funding (Planning, Innovator,
Level 1, or Level 2 Establishment) from CMS will pursue a State Partnership or a State-based Exchange.
Those states who are engaged with CMS as a State Partner will have an identical Plan Management
burden as those operating a State-based Exchange since they will be performing all of the Plan
Management activities, including QHP certification. It is assumed that the majority of states in Statebased Exchanges and Partnerships will continue to leverage their existing systems that are used by the
state departments of insurance. We have also taken into consideration the fact that there can be variation
in what the states do from year to year. The state will have a burden of 3 hours to submit data to the
Federal government for a total burden of $231 per state per year.
Table 5. Burden for States: State-based Exchanges and Partnership States

4

In the original package for this data collection, as approved March 13, 2013, we estimated the total year-one cost
to be $1,155, because we estimated a total of 15 hours per entity, which included startup hours.
5
In the original package for this data collection, as approved March 13, 2013, we estimated the total year-one cost
to be $20,157 per year, because we estimated a one-time $20,000 expense for system upgrades.

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Year

Number of States Hours Per State Total Hours Total Burden Cost Per
State

Four

51

3

153

$231

Five

51

3

153

$231

Six

51

3

153

$231

A.13 Estimate of Other Total Annual Cost Burden to Respondent or Record keepers
There is no capital cost associated with this collection effort.

A.14 Annualized Cost to Federal Government
We estimate that the operations and maintenance costs for the data collection tool will be $204,880.00 on
an annual basis and an additional 485 burden hours for data collection support for a cost of $22,580.90,
for a total cost of $227,460.90 per year.

A.15 Explanation for Program Changes or Adjustments
Since finalizing this PRA package and receiving an OMB control number, we have updated the burden on
QHP, SADP, non-QHP, and State issuers in our calculations as noted above in section A.12. Currently,
this data collection is approved for 317,875 hours. With this ICR, the total annualized hour burden is
approximately 235,153 hours. The change in burden is due to the lack of start-up hours that were a part of
the previously approved clearance as well as adjustments to the data collection instruments.

A.16 Plans for Tabulation and Publication and Project Time Schedule
The information collection from issuers is anticipated under this request to occur in the first quarter of
2016.

A.17 Display of Expiration Date of OMB Approval
CMS has no objections to displaying the expiration date.

A.18 Exceptions to Certification for Paperwork Reduction Act Submissions
There are no exceptions requested for this submission.

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