Justification for nonsubstantive change

May 18, 2020 CMS 10488; OMB Control No. 0938-1221

Request for a Non-Substantive Change to an Existing Approved Information Collection

I. Introduction

Why is CMS Requesting a Non-Substantive Change?

This non-substantive change request makes updates to the information collection burdens associated with the 2020 QHP Enrollee Experience Survey (QHP Enrollee Survey) for Plan Year 2021, approved under OMB Control Number 0938-1221 and is summarized herein. The non-substantive change described in this request does not introduce new policy or any fundamental program changes. This non-substantive change reduces burden for this year (2020) and is being submitted for approval by OMB as a result of the recent CMS decision to suspend data collection for the 2020 QHP Enrollee Survey for Plan Year 2021¹.

II. Description of Non-Substantive Changes

What is the current status of this ICR?

The Health Insurance Exchange Consumer Experience Survey Data Collection: QHP Enrollee Experience Survey (CMS-10488; OMB Control No. 0938-1221) is currently approved through September 30, 2020 and a routine three-year renewal is expected after completion of the Paperwork Reduction Act (PRA) public comment periods². The total current annual burden approved for this ICR is 18,772.5 hours, with an estimated 90,015 responses per year. CMS estimates a nominal reduction in burden based on the non-substantive change of discontinuing data collection in April 2020, as outlined in the COVID-19 Marketplace Quality Initiatives memo.

What are the changes that CMS is making?

CMS is making minor burden reduction non-substantive changes to the QHP Enrollee Survey to reflect the discontinuation of data announced on April 18, 2020. For the QHP Enrollee Survey, there is burden reduction related to approximately one month of data that would not be collected and routinely submitted in May 2020.

III. Description of Burden Adjustments

We have revised the Supporting Statement Part A burden tables accordingly for each ICR.

Based on the 2020 suspension of data collection described above, CMS estimates an annual burden hour reduction from an estimated 18,772.5 hour to 15,934.5 hours for the 2020 QHP Enrollee Survey which accounts for 85% of the original estimated 90,000 responses since the telephone phase of survey administration was not completed³;

Estimated Burden Hours for 2018-2020 Implementation of QHP Enrollee Survey

Source	Num. of Reporting Units	Completes per Reporting Unit	Total Sample1	Burden Hours	Total burden hours
2020 Survey Respondents	300	255	76,500	0.208	15,912
2020 Survey Vendors	15	1	15	1.5	22.5
2018 TOTAL	300		90,015		22,523
2019 TOTAL	300		90,015	0.208	18,772.5
2020 TOTAL	300		76,515		15,934.5
3-year TOTAL	900				57,230

¹ Total Sample = Num. of Reporting Units x Completes per Reporting Unit

QHP Enrollee Survey Estimated Burden Costs

Source	Number of Respondents	Total Burden Hours	Average Hourly Wage Rate	Total Cost Burden
2020 Survey Respondents	76,500	15,912	$26.00	$413,712.00 .
2020 Survey Vendors	15	22.5	$31.24	$702.90
2018 TOTAL	90,015	22,523		$585,702.90
2019 TOTAL	90,015	18,772.5		$488,202.90
2020 TOTAL	76,515	15,934.5		$414,414.90
3-Year TOTAL	256,530	57,207.5		$1,488,320.7

1 COVID-19 Marketplace Quality Initiatives memo available at https://www.cms.gov/files/document/covid-qrs-and-marketplace-quality-initiatives-memo-final.pdf

2 The ICR renewal is currently in process; the 60 day Federal Register Notice posted on March 24, 2020 at https://www.federalregister.gov/documents/2020/03/24/2020-06077/agency-information-collection-activities-proposed-collection-comment-request

3 We recommend 85% of the original annual estimates because in 2019, 20% of completed responses came from the telephone survey and 60% of reporting units had some telephone fielding prior to April 18^th.