Supporting Statement – Payment Collections Operations Contingency Plan: Enrollment and Payment Data Template (CMS- 10515/OMB control number: 0938-1217)
The initial approved information collection request proposed to collect enrollment and payment data from Exchange issuers manually via a template. This request proposes to update our collection because of technology enhancements which significantly decrease the cost to collect data manually by 84% (from nearly $1.8 million from 2018 to 2020, to approximately
$276,000 annually).
Beginning in 2014, the U.S. Department of Health and Human Services (HHS) used a manual payment process as a means of obtaining enrollment and payment information via an alternative collection tool—the Enrollment and Payment Data template—to be able to make payments to issuers on behalf of eligible enrollees. The manual payment process required Health Insurance Exchange issuers to self-report enrollment and payment amount requests on a monthly basis, along with adjustments to prior months’ requests, through a manual submission process.
Beginning in October 2017, the HHS discontinued making any adjustments to cost sharing reductions to issuers.
In January 2016, the HHS implemented an automated payment approach, called policy-based payments (PBPs) to determine an issuer’s advance payment using enrollment and payment data in the Federally-facilitated Exchange (FFE). As of April 2016, all FFE and State-based Exchange using the Federal Platform (SBE-FP) issuers have fully transitioned to the PBP process. As of 2021, one State Exchange issuer continues to use the manual payment process, but HHS anticipates this to end in 2021. Additionally, issuers in states transitioning from FFE or SBE-FP to State Exchanges will need to send enrollment and payment data manually via a template for a few months as they work to transition to the PBP process. Therefore, we are proposing to renew this data collection only for the one issuer that has not moved to the PBP process as well as for issuers in states that are transitioning to State Exchanges. Since we estimate that 50 issuers will be required to use this methodology to transmit information via a manual system (the Enrollment and Payment Data template), this revision will result in an estimated 84% overall reduction in burden for issuers.
On March 23, 2010, the President signed into law H.R. 3590, the Patient Protection and Affordable Care Act (ACA), Public Law 111-148. This law establishes American Health Exchanges (Exchanges) 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 HHS to operate Exchanges in states that decline to establish their own. On October 1, 2013, the HHS began operating Exchanges on behalf of enrollees in 35 states. As of January 1, 2021, 30 states utilize the FFE, 6 states operate as SBE-FPs, and 15 states have State Exchanges.
Under sections 1401, 1411, and 1412 of the ACA 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 ACA to the issuer of the QHP in which the individual enrolls. Section 1402 of the ACA provides for the reduction of cost sharing for certain individuals enrolled in a QHP through an Exchange. 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 of October 2017, Congress has not appropriated money for cost sharing reductions and HHS has discontinued making any adjustments to cost sharing reductions to issuers.
Until January 2016, the HHS collected data required to meet these statutory requirements via the Enrollment and Payment Data template in which issuers submitted data. HHS now has an automated system (PBP) that does not require issuer data submission for FFE and SBE-FP issuers. We still, however, expect issuers in states transitioning to State Exchanges to send enrollment and payment data via this manual system to ensure their transition is complete.
The data collection will be used by the HHS to make payments or collect charges from State Exchange issuers under the following programs: advance payments of the premium tax credit and Exchange user fees. The Enrollment and Payment Data template was used to make payments to FFE issuers in January 2014 and will continue through December 2021, as may be required based on HHS’s operational progress. The Enrollment and Payment Data template will be used for issuers in transitioning State Exchanges for a few months during the transition year.
As stated above, the HHS has introduced an automated system (PBP) for most issuers. For the remaining issuers, all information collected in the Enrollment and Payment Data template will be submitted electronically via an electronic file transfer. HHS staff will analyze the data electronically and communicate with issuers and State Exchanges, if necessary, by email and telephone. A financial authority contact of the issuer will submit a form electronically to the HHS certifying that the information provided as of the submission date is complete and accurate to the best of his or her knowledge.
This is a program created under the ACA and the information to be collected is being collected by the federal government when other collections options are not available.
No impact on small businesses.
HHS makes payments and collects charges under these programs monthly. If HHS does not collect this information on a monthly basis, HHS will be unable to calculate monthly payment or charge for issuers providing health insurance to enrollees in Exchange QHPs. For issuers in transitioning State Exchanges, this data collection will ensure that the PBP payments and charges received from the State Exchanges are accurate as they undergo the transition.
A 60-day notice published in the Federal Register on November 22, 2021 (86 FR 66313). One comment was received. While the comment is appreciated, it was outside of the context of this data collection. The 30-day FR Notice published April 25, 2022 (87 FR 24308). No additional outside consultation was sought.
Respondents will not receive any payments or gifts as a condition of complying with this information collection request.
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.
No sensitive information will be collected.
Salaries for the positions cited in the labor category of the burden charts were taken from the May 2020 National Occupational Employment and Wage Estimate from the Bureau of Labor Statistics (BLS) (https://www.bls.gov/oes/current/oes_nat.htm#00-0000). Wage rates (published in May 2021) include a 100% increase to account for fringe benefits.
State Exchange issuers that use the manual payment process will continue to report data via the same Enrollment and Payment Data template. Because the template has already been built, we are removing estimates of the burden associated with developing it. Additionally, as of October 2017, because of the discontinuation of cost sharing reductions payments from HHS, the cost sharing field in the dataset is no longer required to be submitted and may be left blank. As HHS works with State Exchange issuers to transition to the automated PBP process, we anticipate that it will take State Exchange issuers six months to test their automated systems. We estimate this data collection will take 10 hours each month (by a payment
operations research analyst at an hourly wage of $88.74 which accounts for 100% fringe benefits) to enter current data for each month during which the contingency payment process is in place and submit this data to HHS. We broadly estimate that 50 State Exchange QHP issuers will submit the Enrollment and Payment Data template each year. We assume that the Enrollment and Payment Data template will be used for six months, resulting in a burden of 60 hours and $5,324.40 per SBE QHP issuer, or an aggregate of 3,000 hours and $266,220 for all State Exchange QHP issuers each year.
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 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 $190.24 which accounts for 100% fringe benefits) 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 IDs, we believe that most financial authority contacts will complete one form (within the workbook) that covers only one HIOS ID, such that approximately 6 certification forms will be submitted for 50 State Exchange QHP issuers annually through the Enrollment and Payment Data template. Therefore, we estimate an aggregate burden of 4 hours and 15 minutes and $808.52 each month as a result of this payment data certification requirement.
We estimate an overall annual burden of 51 hours and $9,702.24 for all QHP issuers as a result of this requirement.
12A. Estimated Annualized Burden Hours
Microsoft Excel- based Template |
Type of Respondent |
Number of Respondents |
Number of Responses per Respondent |
Average Burden hours per Response |
Total Burden Hours |
Monthly data reports |
SBE QHP issuer |
50 |
6 |
10 |
3,000 |
Monthly Data Submission Accuracy Certification Form |
SBE QHP issuer |
50 |
6 |
0.17 |
51 |
Total |
|
|
|
|
3,051 hours |
12B. Cost Estimate for All Respondents Completing the Template
Type of respondent |
Number of Respondents |
Number of Responses per Respondent |
Average Burden Hours |
Wage per Hour (including 100% fringe benefits) |
Total Labor Costs |
Operations Research Analyst |
50 |
6 |
10 |
$88.74 |
$266,220 |
50 |
6 |
0.17 |
$190.24 |
$9,702.24 |
|
Total |
|
|
|
|
$275,922.24 |
There are no additional recordkeeping or capital costs.
The calculations for CCIIO employees’ hourly salary was obtained from the OPM website, with an additional 100% to account for fringe benefits.
Task |
Estimated Cost |
Data Processing, Managerial Review, and Oversight |
|
2 GS-12: 2 x $83.56 x 20 hours |
$3,342.40 |
1 GS-15:1 x $138.12 x 4 hours |
$552.48 |
Total Costs to Government |
$3,894.88 |
The burden hours have decreased by 7,002 hours (10,053 hours to 3,051 hours). In January 2016, HHS implemented an automated payment approach (PBP), to determine an issuer’s advance payment using enrollment and payment data in the FFE. As of April 2016, all FFE and SBE-FP issuers have fully transitioned to the PBP process. In 2014, we estimated 575 issuers would be required to use a manual methodology to transmit enrollment and payment data, but since we have fully transitioned all FFE and SBE-FP issuers to the automated payment approach (PBPs), we now estimate that only 50 issuers will be required to use the manual method (the Enrollment and Payment Data template) annually to transmit information via a manual system. Additionally, issuers will not be required to establish new systems to complete their enrollment and payment forms because their systems have already been established by the State Exchange and the forms are not changing. Additionally, as of October 2017, because of the discontinuation of cost sharing reductions, the cost sharing field in the dataset is no longer required to be submitted and may be left blank. Finally, we expect this burden estimate to apply annually as FFE and SBE-FP states transition to State Exchanges.
The data collected will not be made public.
The expiration date will be displayed on the first page (top right-hand corner) of each instrument. There are no changes to the data instruments.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Payment Collection Operations |
| Subject | Payment Collections |
| Author | CMS |
| File Modified | 0000-00-00 |
| File Created | 2022-04-29 |