Response to comment document

Transparency in Coverage Summary of 60-day Comments
Category
Timing

Comments Summary
Align data collection with similar collection efforts

Scope of data
collection

Reporting requirements should not require a
duplicative process for issuers

Data on claims
denials

Do not collect or display information on claims
denials at this time

Clarify guidance for reporting claims

Develop common definitions to ensure the data
collected are consistent similar data collections
CMS should not add new claims appeals reporting
requirement

Resolution
As proposed in the supporting statement, CMS will work
to align with other reporting requirements.
CMS seeks to minimize duplicate efforts wherever
possible by aligning the data submission with the QHP
certification process in future collections, as well as
continuing to align with other entities that may require
issuers to submit similar data.
In our initial phased in approach, we only collected
claims denial and internal and external appeals figures.
At this time we believe that expanding this data
collection element to be useful to consumers.
CMS will identify what additional guidance is needed to
support issuer’s submission of claims data in the issuer
instruction manual.
CMS will add common definitions to the data collection
process.
At this time, CMS has not proposed any new
requirements for issuers to report on appeals that was not
already implemented in the previous collection. The
existing reporting requirement include: the number of
claims received; the number of claims denied; the
number of internal appeals filed and overturned; and the
number of external appeals filed and overturned.