Supporting Statement – Quality Standards
The Department of Health and Human Services (HHS) goals for improving access to high-quality, affordable care, and for supporting healthier people and communities, as described in the Meaningful Measures Initiative,1 continue to guide the establishment of quality standards for the Health Insurance Exchanges and for Qualified Health Plans (QHPs). HHS is requesting approval, by the Office of Management and Budget (OMB), for the revisions associated with Parts I, II, and III of this supporting statement. This supporting statement details the information collection associated with the following processes:
Implementation and reporting for the Quality Rating System (QRS),
Implementation and reporting for the QHP Enrollee Experience Survey (QHP Enrollee Survey),
Monitoring and appeals process for survey vendors, and
Patient safety reporting standards for QHP issuers.
The Patient Protection and Affordable Care Act establishes requirements to support the delivery of quality health care coverage for health insurance issuers offering QHPs in Exchanges.2
Section 1311(c)(3) of the Patient Protection and Affordable Care Act directs the Secretary to develop a system to rate QHPs on the basis of quality and price and requires Exchanges to display this quality rating information on their respective websites.
Section 1311(c)(4) of the Patient Protection and Affordable Care Act requires the Secretary to develop an enrollee satisfaction survey system to assess enrollee experience with each QHP (with more than 500 enrollees in the previous year) offered through an Exchange. Section 1311(h) requires QHPs to contract with certain hospitals that meet specific patient safety and health care quality standards beginning January 1, 2015.
This Information Collection Request (ICR) was approved under OMB Control Number 0938-1249 so that HHS may collect required information to implement the proposed quality standards outlined in Code of Federal Regulations (CFR) §156.1105, §156.1110, §156.1120, and §155.1125.
This collection of information is necessary to provide adequate and timely health care quality information for consumers, regulators, and Exchanges in the initial years of Exchange implementation. It is also necessary to collect information to appropriately monitor and provide a process for a survey vendor to appeal HHS’ decision to not approve a QHP Enrollee Survey vendor application.
We updated this information collection request to account for the associated burden of the refinements to the QRS program, including changes to the QRS measure set, data collection process, and number of QHPs participating in the QRS annually. In addition, we have accounted for the associated burden reduction due to refinements to the QHP Enrollee Survey questionnaire approved under OMB Control No. 0938-1221.3
We are requesting approval for this updated information collection request to extend past the current expiration date (August 31, 2022) for an additional three years (2022–2025).
The QRS quality measure data will be collected from QHP issuers on an annual basis so HHS can calculate scores and quality ratings for QHPs, as required by section 1311(c)(3) of the Patient Protection and Affordable Care Act. This quality rating information will be displayed on Exchange websites for consumers to have QHP rating information, including health care quality, health outcomes, consumer experience, accessibility of care, and affordability of care. This information is essential to inform consumer choices and to perform certain required functions of an Exchange (e.g., QHP certification). HHS will use the validated data that is submitted by QHP issuers to calculate scores and ratings based on a standardized methodology found in the annual QRS and QHP Enrollee Survey Technical Guidance.
The information collection associated with implementation and reporting for the QHP Enrollee Survey, as outlined in §156.1125, includes the collection, validation, and submission of QHP Enrollee Survey data on an annual basis. The QHP Enrollee Survey will provide member experience data, which is a fundamental aspect of measuring the overall quality of a QHP. The burden estimates and costs regarding survey respondents are already accounted for in the Federal Register Notice (FRN) dated August 10, 2020 and are approved under OMB Control No 0938-1221.4
The QHP Enrollee Survey information submitted to HHS will be used by HHS to calculate QHP Enrollee Survey scores and benchmarks to send to Exchanges and to QHPs. In addition, a subset of the QHP Enrollee Survey scores will be used as part of the quality ratings for QHPs.
HHS monitors approved survey vendors for ongoing compliance. HHS may require additional information from approved vendors be submitted as needed to verify continued compliance with standards listed in §156.1105(b)(1) through (11). HHS will use this information to determine whether vendors should remain on the approved list.
Vendors that were not approved by HHS have the opportunity to appeal HHS’s determination. The appeals process requires vendors who plan to appeal HHS’s decision to submit a completed Request for Appeal Form with new or additional information for each criterion not met and justification for why this information was not included in the vendor’s original Participation Form. HHS will use this information to make a final approval determination of whether or not to list the vendor as an HHS-approved QHP Enrollee Survey vendor.
HHS finalized amendments to QHP patient safety reporting standards in the Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2017 (81 FR 12203), March 2016. We finalized the documentation requirement in §156.1110(b) to require QHP issuers to collect and maintain information like a hospital attestation or a copy of the current agreement to partner with a Patient Safety Organization (PSO), a Hospital Engagement Network, or a Quality Improvement Organization.
This documentation should reflect implementation of PSO activities, such as PSOs and hospitals working together to collect, report, and analyze patient safety events, and to implement a comprehensive person-centered hospital discharge program that demonstrates compliance with the proposed requirements in §156.1110(a)(2)(i). Such documentation may also reflect implementation of a patient safety initiative to improve health care quality through the collection, management, and analysis of patient safety events that reduces all cause preventable harm, prevents hospital readmission, or improves care coordination to demonstrate compliance with the reasonable exception provision finalized in §156.1110(a)(2)(ii). An Exchange may request this information and may use the information as demonstration of compliance by QHP issuers with patient safety reporting standards outlined in §156.1110.
All information collected from QHP issuers for implementation and reporting of the QRS, QHP Enrollee Survey, and patient safety standards will be submitted electronically. HHS staff will analyze the data electronically and communicate with issuers and State-based Exchanges, if necessary, by email and telephone. Information collected from survey vendors regarding the monitoring and appeals process will be electronic as well.
The quality reporting standards and programs included in this supporting statement were established by the Patient Protection and Affordable Care Act. The information has never been collected by the Federal Government for purposes including: providing quality ratings and QHP Enrollee Survey results for QHPs, monitoring and conducting appeals processes for QHP Enrollee Survey vendors, and patient safety reporting by QHPs.
While certain quality measures are used in other CMS quality reporting programs, such as the Medicare Star Ratings, Medicaid Adult Core Measures, Initial Children’s Core Set, and Medicare Part C&D programs; the information for the QRS and QHP Enrollee Survey provides important data specific to the Exchange population – a new and evolving population separate from both Medicare and Medicaid.
No impact on small business.
If HHS does not collect the QRS and QHP Enrollee Survey information on an annual basis, HHS will be unable to calculate scores and ratings for QHPs as required by section 1311(c)(3) and (c)(4) of the Patient Protection and Affordable Care Act. In addition, HHS will be unable to send the appropriate QHP quality information to Exchanges for display on their websites as is also required. If HHS does not collect information to monitor QHP Enrollee Survey vendors, then there may be increased risk of noncompliance by vendors, which could impact the integrity of the QHP Enrollee Survey scores and the QRS ratings. Additionally, it is important that measure data is collected timely in order to reflect relevant information of the Exchange population as it continues to evolve.
Not applicable.
As required by 5 CFR 1320.8(d), CMS provided an opportunity for the public to comment for 60 days through publication of a Federal Register Notice (February 9, 2022 (87 FR 7457) and received one comment. The comment pertained to questions included in the QHP Enrollee Survey. While the QHP Enrollee Survey informs the QRS program, information pertaining to the QHP Enrollee Survey instrument is included in OMB Control Number 0938-1221.
Respondents will not receive payments or gifts for completion of this data collection.
No personal information will be collected. All information will be kept private to the extent allowed by applicable laws/regulations.
No sensitive information will be collected.
The burden estimate details the costs associated with QRS measure data collection, validation, and submission to CMS for a QHP issuer (issuer) operating in the Health Insurance Exchange. The estimate assumes 300 issuers, based on the number of issuers that have participated in the Marketplace Quality Initiatives programs annually, and covers the annual costs for an issuer over a three-year period (2022-2025). The estimate relies on the assumption that each issuer will report the QRS measure set only.
Though the QRS measure set consists of 36 measures, this burden estimate only considers the level of effort associated with 26 measures that specify data collection using administrative data sources and/or medical records. The burden estimate for survey respondents for the remaining 10 survey measures in the QRS measure set was accounted for in a separate Information Collection Request approved under OMB Control No. 0938-1221 related to the QHP Enrollee Experience Survey. See Exhibit 1 for the QRS measure set attributes considered in estimating the burden of QRS measure data collection. The original burden estimates were made based on the draft QRS measure set released in the FRN published November 3, 2013.5
CMS reviewed the assumptions and data inputs used to create the original QRS burden estimates. Since publication of the ICR, the QRS measure set was revised and published shortly after the issuance of the Final Rule.6 Subsequently, several additional changes to the measure set were made through the annual QRS Call Letter process.7 Additionally, beginning in 2019, CMS modified the QRS Measure Technical Specifications for the HEDIS measures, such that the hybrid data collection method is optional rather than a requirement as in previous years. Due to the changes in the QRS measure set, CMS revised the burden estimate to reflect the final 2022 QRS measure set. Exhibit 1 shows the change in key measure set attributes between the draft QRS measure set, the final 2015 beta test QRS measure set, the 2019 QRS measure set, and the current QRS measure set (2022 QRS).
Exhibit 1. QRS Measure Set Attributes Related to Data Collection
Attribute Description |
Draft QRS Measure Set |
Final 2015 QRS Beta Test Measure Set |
Current QRS Measure Set (2022 QRS) |
Subset of QRS Measures Accounted for In Burden Estimate |
29 |
31 |
26 |
Administrative Measures Measures that specify the use of claims or other administrative source data |
20 |
18 |
26 |
Hybrid Measures Where Unique Sample Is Optional Measures that specify the use of medical record data to supplement administrative data is an option |
9 |
10 |
7* |
Average # of Medical Records Reviewed for Each Hybrid Measure where a Unique Sample is Optional The number of medical records, on average, that an issuer reviews to determine measure compliance (as determined by the issuer) |
335 |
330 |
411 |
*Though there are seven hybrid measures in the current QRS measure set, the use of the hybrid data collection is optional for these measures. CMS burden calculations include the hybrid data collection option for these measures to account for QHP issuers that may choose to supplement administrative data.
CMS conducted interviews with issuers that had experience with performance measures data collection and other technical experts to confirm the data collection process and the associated burden. These estimates are based on similar reporting programs, and the data collection process has deviated only slightly from its original structure. The following data collection process steps served as the basis for estimating labor hours:
Preparation of IT Systems for Data Collection
Data Collection – Administrative Method
Data Collection – Medical Record Method
Data Aggregation and Quality Assurance
Data Validation
Data Submission
Previous estimates assumed that issuers would report QRS measure data to CMS by product type (HMO, POS, PPO, and/or EPO); thus, the estimates used a weighting factor to represent the workload for issuers with multiple product types to report hybrid measures. However, the additional burden created by reporting of multiple product types is negligible for data collected via the administrative method. Because all QRS measures can be reported via the administrative method, CMS removed this weighting factor.
Exhibit 2 includes the labor categories and wage rates used to derive the burden estimate. The categories are based on those cited by the Department of Labor, Bureau of Labor Statistics (BLS). A sample of issuers informed modifications to the function descriptions associated with each category so that they aligned more with data collection of performance measures. Wages are based on BLS wage statistics as of May 2020 (published in March 2021). The 75th percentile is used for hourly wages to generate a conservative burden estimate. This burden estimate represents the average, annual cost for an issuer over the 2022-2025 QRS reporting period.
Since wage data were taken from 2020 BLS reports (the most recent data available), the model includes a wage growth factor to account for the anticipated changes in total compensation. The wage growth factor was determined by averaging annual growth rates of total compensation between 2011 Quarter 1 to 2021 Quarter 1, as supplied by BLS. Additionally, CMS updated overhead and fringe benefits to 100% to calculate the total hourly wage rate based on OMB guidance.
Due to the decrease in overall measures by 6%, CMS revised the burden estimate accordingly. The revised annual labor hours and associated costs are reflected in Exhibit 2.
Exhibit 2. Labor Categories and Wage Rates
Labor Category |
Function |
Hourly Wage8 |
Hourly Wage Rate for Period 2022-20259 |
Total Hourly Wage Rate for Period 2022-202510 |
Formulate policies, manage daily operations, and plan the use of materials and human resources. |
$77.49 |
$86.09 |
$172.18 |
|
Modify and test code. Use statistical methods to organize, interpret, QA, and summarize data. |
$55.87 |
$62.09 |
$124.14 |
|
Project Management and Business Operations Specialist, Other |
Train reviewers. Review and over-read charts for quality assurance. |
$50.20 |
$55.77 |
$111.54 |
Review medical records for measure data collection. |
$44.99 |
$49.98 |
$99.97 |
|
Compile, process, review, and maintain medical records and patient information. |
$27.81 |
$30.90 |
$61.79 |
The estimated annual cost burden for issuers is based on an average of estimates provided by a sample of issuers. The sample was composed of issuers that have experience with collection of performance measure data, which represents the majority of issuers that will report QRS measures data. Each issuer estimated labor hours for each applicable labor category involved with the data collection process. Estimates assumed that issuers would follow usual practices of contracting with a third party for data validation and using existing program data submission tools with which they are familiar. Exhibit 3 displays the estimated annual cost burden for a single issuer and includes the labor hours per labor category (for internal staff).
Exhibit 3. Annual Estimated Cost Burden for One Issuer
|
Internal Staff |
Third-Party Validator |
||||
|
General and Operations Manager |
Computer Programmer |
Business Operations Specialist, Other |
Registered Nurse |
Medical Records and Health Information Analyst |
|
Total Hours by Labor Category |
182 |
296 |
128 |
48411 |
13712 |
|
Total Hourly Wage Rate |
$172.18 |
$124.14 |
$111.54 |
$99.97 |
$61.79 |
|
Subtotal Cost |
$31,337 |
$36,745 |
$14,277 |
$48,385 |
$8,465 |
$12,500 |
Total Cost |
$151,710 |
|
|
|
|
|
For one QHP issuer, the burden to collect and report data for the QRS is estimated to take approximately 1,227 hours and $151,710 each year. Therefore, the total annual hour and cost burden for 300 issuers is 368,100 hours and $45,513,000.
The estimated annual hour and cost burden for an issuer to collect, validate, and submit data for the QHP Enrollee Survey includes contracting with an HHS-approved QHP Enrollee Survey vendor, contracting with an auditor, generating the sampling frame data, reviewing survey materials, authorizing its contracted survey vendor, and signing off on the sampling frame data to be submitted to HHS.
The QHP Enrollee Survey is largely based on the Consumer Assessment of Healthcare Providers and Systems (CAHPS®) 5.0 Health Plan Survey, which the majority of issuers already have experience with. Therefore, the burden estimates are similar to established CAHPS survey estimates for health plans, such as those approved under OMB Control Number 0938-0732 (Medicare CAHPS surveys). It is estimated that an issuer takes an average of 50 hours a year for the QHP Enrollee Survey. For the estimated 300 QHP issuers, the total annual burden is 15,000 hours. As summarized in Exhibit 4, it is estimated that it costs an issuer $5,577 each year for a total annual cost of $1,673,100 for 300 issuers.13
Exhibit 4. Annual Estimated Hour and Cost Burden for QHP Issuers for the QHP Enrollee Survey
Issuer Activity |
Number of Respondents |
Hours per response |
Total Burden Hours |
Total Hourly Wage Rate for Period 2022 – 2025 (Business Operations Specialist, Other)14 |
Total Cost Burden |
Contracting with HHS-approved QHP Enrollee Survey vendor |
300 |
6 |
1800 |
$111.54 |
$200,722 |
Contracting with auditor |
300 |
6 |
1800 |
$111.54 |
$200,722 |
Generating sampling frame |
300 |
32 |
9600 |
$111.54 |
$1,070,784 |
Reviewing survey materials |
300 |
4 |
1200 |
$111.54 |
$133,848 |
Authorizing survey vendor and signing off on sampling frame data to be submitted |
300 |
2 |
600 |
$111.54 |
$66,924 |
Total |
|
50 |
15,000 |
|
$1,673,100 |
The estimated annual hour and cost burden for a survey vendor to provide information for HHS to determine continued compliance with approval criteria and QHP Enrollee Survey vendor minimum business requirements is approximately 12 hours and $1,338.48 for an estimated 12 vendors, as summarized in Exhibit 5. It is estimated that approximately two vendors may file an appeal each year, if not approved by HHS to be an QHP Enrollee Survey vendor. However, this is a conservative estimate as HHS has received only one appeal since 2016. The annual hour and cost burden for those two vendors filing an appeal is estimated to be two hours and $223.08. Therefore, the total annual estimated hour and cost burden for vendor monitoring and appeals is 14 hours and $1,561.56.
Exhibit 5. Annual Estimated Hour and Cost Burden for HHS Vendor Monitoring and Appeals
Vendor Activity |
Number of Respondents |
Hours per response |
Total Burden Hours |
Total Hourly Wage Rate for Period 2022 – 2025 (Business Operations Specialist, Other) |
Total Cost Burden |
Compliance with monitoring |
12 |
1 |
12 |
$111.54 |
$1,338.48 |
Filing an appeal |
2 |
1 |
2 |
$111.54 |
$223.08 |
Total |
14 |
|
14 |
|
$1,561.56 |
In the HHS 2017 Payment Notice final rule,15 we describe the information collection, recordkeeping, and disclosure requirements a QHP issuer must meet to demonstrate compliance with the patient safety standards outlined in §156.1110. The burden estimate associated with these standards includes the time and effort required for QHP issuers to maintain and submit information, such as a hospital attestation or a copy of the current agreement to partner with a PSO, a Hospital Engagement Network, or a Quality Improvement Organization, to the Exchange that demonstrates that each of its contracted hospitals with greater than 50 beds meets the patient safety standards in §156.1110(a)(2) for plan years beginning on or after January 1, 2017. We expect QHP issuers to already be collecting network provider information, which is accounted for in the Supporting Statement associated with OMB Control Number 0938-1156.
There is a wide range of numbers of relevant hospitals with greater than 50 beds across states, from only one in some states to more than 300 hospitals in other states. We estimate that a total of 300 QHP issuers, offering 15 plans as potential QHPs, would each take approximately an average of three hours to collect, maintain, and submit applicable hospital agreements or information as finalized in §156.1110 for their QHPs. At an hourly billing rate of $91.31, we estimate the total annual cost for a QHP issuer to be $273.93. Therefore, as summarized in Exhibit 6, we estimate the total annual cost and annual burden to be $82,179 and 900 hours.
Exhibit 6. Annual Estimated Hour and Cost Burden for QHP Issuer Patient Safety Reporting
Activity |
Number of Respondents |
Hours per response |
Total Burden Hours |
Average Hourly Wage Rate |
Total Cost Burden |
QHP issuers collect and maintain information such as applicable hospital agreements |
300 |
2 |
600 |
$91.31 |
$54,786 |
QHP issuers submit this data to HHS and an Exchange |
300 |
1 |
300 |
$91.31 |
$27,393 |
Total |
|
3 |
900 |
|
$82,179 |
We anticipate that capital costs would be incurred in the initial year(s) by issuers with limited experience in quality measure collection and submission as they develop their data collection systems and processes. These issuers will need to purchase and install software for QRS measure data collection. The anticipated cost for this purchase and installation is approximately $80,000.
These issuers would also incur an additional $10,000 cost for third-party validation since validators may initially set higher fees for these issuers, given the increased resources needed to validate new systems and processes. Capital costs also include annual third-party validation costs, which are estimated to be $12,500 for issuers. Issuers would also have to contract with a QHP Enrollee Survey vendor, which is estimated to be approximately $16,000 annually. We estimate that these vendor contracting costs are conservative since issuers already contract with survey vendors to administer other similar CAHPS surveys and may not have to contract with additional new vendors for the QHP Enrollee Survey.
We estimate that the operations, maintenance, and data collection costs associated with this information collection to the Federal Government include contract costs for the QRS measure collection and reporting, as well as the time and cost for one GS-13, one GS-14, and one GS-15 position for data processing, managerial review, and oversight, as summarized in Exhibit 7. The calculations for federal employees’ hourly salary are obtained from the OPM website, with an additional 100% to account for overhead and fringe benefits.
Exhibit 7. Summary of Annualized Cost for Information Collection to the Federal Government
Task |
Estimated Cost |
Data Processing, Managerial Review, and Oversight |
|
1 GS-13, Step 1: $76.16 X 20 hrs |
$1,523.20 |
1 GS-14, Step 1: $90.00 X 20 hrs |
$1,800.00 |
1 GS-15, Step 1: $105.86 X 5 hrs |
$528.30 |
QRS measure collection and reporting |
$649,927.52 |
QHP Enrollee Survey data collection |
Already accounted for in OMB Control #0938-1221 |
Total Costs to Government |
$653,779.02 |
This is an overall increase to the burden hour estimates approved in OMB Control Number 0938-1249. The modifications to the QRS and QHP Enrollee Survey and patient safety portions of this document, based on the past three years of implementation of the programs, would result in an annual estimate increase in burden hours of 67,000 hours.
QRS implementation and reporting increased by 64,100 hours [304,000-368,100 hours];
QHP Enrollee Survey implementation and reporting increased by 2,500 hours [12,500 to 15,000 hours];
Monitoring and appeals process for survey vendors remained the same [14 hours]
Patient safety collection and reporting increased by 400 burden hours for [500-900].
There is an estimated increase in cost burden of $2,913,719.48 for QHP issuers.
QRS implementation and reporting increased by $2,531,000 [$42,982,000-$45,513,000];
QHP Enrollee Survey implementation and reporting increased by $457,850 [$1,673,100-$1,215,250];
Monitoring and appeals for survey vendors increased by $200.48 [$1,561.56-$1,361.08]);
Patient safety data collection and reporting decreased in cost burden by $75,331 for [$157,510 - $82,179].
Using the data collected for the QRS, HHS intends to calculate ratings associated with the QRS according to a standard rating methodology. CMS displayed quality rating information during a QRS pilot test on HealthCare.gov for select states during the 2017, 2018, and 2019 plan years. Beginning with the 2020 plan year, CMS displayed the QHP quality rating information for all Exchanges that used the HealthCare.gov platform. SBEs whose consumers do not use HealthCare.gov were required to display QHP quality ratings for the 2020 plan year, but had some flexibility to customize the display of the QHP quality rating information. Additionally, SBEs and web-brokers that use direct enrollment to facilitate enrollments through the FFEs and SBE-FPs are directed to display QHP quality rating information on their respective websites.
The publication activities for the QHP Enrollee Survey are already addressed in the Supporting Statement associated with OMB Control No. #0938-1221. We do not intend to publish any data associated with the monitoring and appeals process for survey vendors and for QHP patient safety reporting standards.
There are no exceptions to the certification.
1 The CMS Meaningful Measures Initiative, launched in 2017, identifies the highest priorities for quality measurement and improvement. It involves assessing those core issues that are the most critical to providing high-quality care and improving individual outcomes. For additional information, please visit https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/QualityInitiativesGenInfo/CMS-Quality-Strategy.html.
2 The Exchanges are also referred to as the “Marketplace” or the “Marketplaces” within this document.
3 For 2022, the questionnaire will remain consistent with the 2021 questionnaire per non-substantive change request. Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2021; Notice Requirement for Non-Federal Governmental Plans, 85 FR 7088 (published February 6, 2020): https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202009-0938-018.
4 Agency Information Collection Activities: Submission for OMB Review; Comment Request; Notice, 85 FR 48255 (August 10, 2020). https://www.federalregister.gov/documents/2020/08/10/2020-17417/agency-information-collection-activities-submission-for-omb-review-comment-request
5 https://www.federalregister.gov/articles/2013/11/19/2013-27649/patient-protection-and-affordable-care-act-exchanges-and-qualified-health-plans-quality-rating
6 Patient Protection and Affordable Care Act; Exchange and Insurance Market Standards for 2015 and Beyond Final Rule, 79 FR 30352 (May 27, 2014).
7 Final 2017 Call Letter for the QRS and QHP Enrollee Survey, Final 2018 Call Letter for the QRS and QHP Enrollee Survey, Final 2019 Call Letter for the QRS and QHP Enrollee Survey, Final 2020 Call Letter for the QRS and QHP Enrollee Survey, and Final 2021 Call Letter for the QRS and QHP Enrollee Survey.
8 75th percentile is referenced. Data source: http://www.bls.gov/oes/current/oes_stru.htm
9 Hourly wage + wage growth factor of 2.66%. Wage growth factor data source: BLS 2011 Q1 to 2021 Q1 - http://www.bls.gov/ncs/ect/data.htm.
10 Hourly wage rate for period + overhead & fringe benefit rate of 100%. Overhead & fringe benefit data source: OMB.
11 The total hours estimate for registered nurses was calculated based on the assumption that, collectively, QHP issuers will elect to submit hybrid measures via the hybrid method for approximately 50% of the applicable measures.
12 The total hours estimate for medical records and health information analysts was calculated based on the assumption that, collectively, QHP issuers will elect to submit hybrid measures via the hybrid method for approximately 50% of the applicable measures.
13 100% overhead and fringe benefit rate is being used.
14 See Exhibit 2 for details on Total Hourly Wage Rate for Period 2019-2022
15 Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2017; Final Rule, 81 FR 12203 (March 8, 2016).
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Payment Collections Contingency Plan |
| Subject | Contingency Plan |
| Author | CMS` |
| File Modified | 0000-00-00 |
| File Created | 2022-06-16 |