Common Data Layout


NEW: Updated January 15, 2021: APCD-CDL™ DMR Requested Additions & Revisions

Updated November 10, 2020: APCD-CDL ™ DMR for Public Comment

The list of DMRs has been updated and the public comment period has been extended to December 4, 2020.

Updated October 7, 2020: APCD-CDL™ DMR for Public Comment


The number of states implementing All-Payer Claims Databases (APCDs) has increased steadily since 2007. With this growth, harmonization of state APCD collection has become increasingly important. The APCD Council has a long history of working with states and payers on these harmonization efforts, including drafting a common core set of APCD data elements in 2011.  A more detailed history of APCD Council harmonization efforts can be found here.

In May of 2016, the APCD Council began working with states, their vendors, and the payer community to develop a draft APCD- Common Data Layout (CDL) for state APCDs. In June 2017, this group completed a review of the first version of the APCD-CDL™. The first version of the APCD-CDL™ was made available on January 1, 2019.  To request a copy of the APCD-CDL™ please complete the request form and return to

Development of the Common Data Layout for State APCDs (APCD-CDL™)


The Supreme Court decision in Gobeille v. Liberty Mutual Insurance Company ruled that self-insured employers cannot be mandated to submit to state All-Payer Claims Database (APCD) systems. This led to states attempting to identify alternate approaches to data collection. Among these approaches is the possibility of working with the United States Department of Labor (DOL) to determine if the DOL can use its authority to facilitate data collection. There is an assumption that if DOL were to require data submission to state APCDs, DOL would need to be able to refer to a uniform data set that all plans would submit. To date, no decision has been made by the DOL.

APCD-CDL™ Development Process

In 2015, the Center for Healthcare Transparency (CHT) drafted a Model Data Submission Manual to support some of its work with Regional Data Intermediaries, which have business purposes that require administrative claims data, similar to APCDs. In an effort to standardize data collection for its Regional Data Intermediaries, CHT drafted a Model Data Submission Manual that incorporated references to the data standards maintained by National Council for Prescription Drug Programs (NCPDP) and ASC X12 Post Adjudicated Claims Data Reporting (PACDR). Given the historical experience with the development of the core set of data elements, the APCD Council worked with CHT in the process of reviewing this guide at the end of 2015. 

With permission from CHT, the CHT Model Data Submission Manual was reviewed by APCD states, their vendors and the majority of national payers and some regional payers in meetings facilitated by the APCD Council, to identify a CDL for APCD efforts that meet current needs of the states. States conducted the first review of the CHT Model Data Submission Manual in order to develop a CDL and considered the business needs for the data elements proposed, and the utility for analysis. Payers were invited to comment on the draft developed by the states, and from May 2016 through March 2017 have participated in weekly calls with states to review every proposed field in the CDL. This has resulted in the current APCD-CDL™. 

While the CDL defines the format for flat files submission, ASC x12 and NCPDP define the industry standards. More about those efforts, which are referenced in the APCD-CDL™, can be found here.

APCD-CDL™ Maintenance Process

In January 2019, the APCD Council called for volunteers to participate on an advisory committee to establish a process to maintain the APCD-CDL™. Made up of states, payers and vendors, the advisory committee collectively decided that the APCD-CDL™:

  • Will be updated every other year  to support a predictable timeframe
  • Anyone who has requested a copy of the APCD-CDL™ will be able to submit a request for a modification to the APCD-CDL™ within the timeframe described in the process below using a standard request form
  • Corrections to the APCD-CDL™ will be made on an as needed basis

Using the Data Maintenance Request (DMR) form, any organization that has requested a copy of the APCD-CDL™ can suggest a modifcation during the 18 months after the release of the most current version of the APCD-CDL™. The APCD Council recommends that individuals within an organization work together and submit a single DMR form on behalf of the entire organization rather than submitting multiple DMRs. 

At the end of the 18 months, all DMRs will be consolidated and posted to the APCD Council website for a 30 day comment period.  At the close of the comment period, the advisory committee, made of up of APCD Council staff and NAHDO members, will review all comments and make recommendations.  A summary of the final recommendations will be posted to the APCD Council website. APCD Council staff will make the recommended changes to the APCD-CDL™ and new version will be released at the start of the new two year period (e.g. January 1, 2021).

A webinar will be held to present the changes in the new version.

For more information about the maintenance process or to request a DMR Form, please email