Justification for NonSubstantive Change

Page 3 of 3

Request for a Non-Substantive Change

to an Existing Approved Information Collection

(OMB Control No. 0938-1221)

I. Introduction

Why is CMS Requesting a Non-Substantive Change?

This non-substantive change request updates the information collection burdens associated with the 2023 Qualified Health Plan Enrollee Experience Survey (QHP Enrollee Survey) approved under OMB Control Number 0938-1221. The changes described in this request do not introduce new policy or any fundamental program changes.

Section 1311(c)(4) of the Patient Protection and Affordable Care Act requires health plans with more than 500 enrollees to administer the QHP Enrollee Survey. In recent years, there has been an increased number of QHP issuers offering plans through the Health Insurance Marketplace and State-Based Exchanges. Based on available enrollment data, CMS anticipates up to 350 reporting units may be required to administer the QHP Enrollee Survey. CMS is submitting this non-substantive change request to increase the number of burden hours associated with the 2023 QHP Enrollee Survey. CMS is also updating the estimated burden cost associated with the 2023 survey administration to reflect increased wages since the ICR was originally submitted.

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 is currently approved through November 30, 2023. The total current annual burden approved for this ICR is 16,516.7 hours, with an estimated 82,510 responses per year. This estimate was based on the assumption that 275 reporting units would be required to administer the survey; however, CMS anticipates that up to 350 reporting units may be required to administer the survey.

CMS will begin the process of submitting a request to renew this ICR later in 2022.

What are the changes that CMS is making?

CMS is seeking to increase the total burden hours associated with the 2023 QHP Enrollee Survey from 16,516.70 hours to 21,016.7 hours to reflect that up to 350 reporting units may be required to conduct the QHP Enrollee Survey.

III. Description of Burden Adjustments

CMS is requesting to increase the total burden hours associated with the 2023 survey administration by 4,500 hours. Below we include the revised burden tables from Supporting Statement A reflecting these changes.

Exhibit A1. Estimated Burden Hours for 2021-2023 Implementation of QHP Enrollee Survey 

Source	Number of Reporting Units/ Survey Vendors	Completes per Reporting Unit	Total Sample1	Burden Hours	Total Burden Hours
2021 Survey Respondents	275	300	82,500	0.2	16,500.00
2021 Survey Vendors	10	1	10	1.670	16.70
2021 TOTAL	285		82,510		16,516.70
2022 Survey Respondents	275	300	82,500	0.2	16,500.00
2022 Survey Vendors	10	1	10	1.670	16.70
2022 TOTAL	285		82,510		16,516.70
2023 Survey Respondents	350	300	105,000	0.2	21,000.00
2023 Survey Vendors	10	1	10	1.670	16.70
2023 TOTAL	360		105,010		21,016.70
3-year TOTAL	930		270,030		54,050.10

¹ Total Sample = Number of Reporting Units x Completes per Reporting Unit 

Exhibit A2. QHP Enrollee Survey Estimated Burden Costs

Source	Number of Respondents	Total Burden Hours	Average Hourly Wage Rate	Total Cost Burden
2021 Survey Respondents	82,500	16,500.00	$28.32	$467,280.00
2021 Survey Vendors	10	16.7	$34.22	$571.47
2021 TOTAL	82,510	16,516.70		$467,851.47
2022 Survey Respondents	82,500	16,500.00	$28.32	$467,280.00
2022 Survey Vendors	10	16.7	$34.22	$571.47
2022 TOTAL	82,510	16,516.70		$467,851.47
2023 Survey Respondents	105,000	21,000.00	$31.85	$594,720.00
2023 Survey Vendors	10	16.7	$38.51	$643.12
2023 TOTAL	105,010	21,016.70		$669,493.12