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Expanding Data Sources Available to APCDs: What Congress Can Do

The Senate’s Health Care Transparency Initiative recently asked stakeholders for feedback. In a brief series of posts, I’ll be sharing Freedman HealthCare’s recommendations to the group, which focused on strategies to maximize the opportunity of APCDs and alleviate barriers to the broad sharing of actionable health care data.

Our first series of recommendations addresses expanding data sources available to APCDs. Currently, multiple data sources are unavailable to states and non-profits for collection purposes. These include price and quality data for federal employees, active service members and veterans, civilian military employees or those served by Indian Health Services. Additionally, since the 2016 SCOTUS Gobeille decision, state-mandated APCDs cannot require collection of data for most commercially-insured individuals. Thus, they have essentially lost access to the data of over half of the commercially-insured population.

FHC recommendations to address these gaps included:

  • Mandate submission of self-insured data: Congress should amend the Employee Retirement Income Security Act (ERISA) to permit mandated state collection of self-insured plans’ data. Adoption of a nationally standardized dataset would reduce the costs to insurers and states, and help rapidly expand the use of MPCDs. A second option is to authorize creation of a federal MPCD/data collection program whereby the Department of Labor creates a centralized data collection structure.


  • Ensure that payers provide detail on all payments: As payers move away from fee-for-service toward value-based reimbursement, the “traditional” claims data must be augmented with information about alternative payment models. Augmented data collection strategies will be needed. The Oregon Health Authority’s alternative payment methods data collection process was developed in collaboration with data submitters and offers a template for how other states and data collectors might approach collecting this data.

Read the full FHC letter here.


Health Care Price Transparency Initiative: Our Response
The Coming Digital Transformation of Healthcare