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. Since May of 2016, The APCD Council has been working with states, their vendors, and the payer community to develop a draft Common Data Layout (CDL) for State APCDs. As of June 2017, the group has completed a review and a final draft is forthcoming. While the process has not been determined, states and payers have agreed to review and make any necessary updates to the CDL on an annual basis.
Development of the Draft Common Data Layout for State APCDs
The Supreme Court decision in Gobeille v. Liberty Mutual Insurance Company ruled that self-insured employers cannot be mandated to submit to state APCD systems. This ruling emphasized the need for standardization of state-to-state APCD data collection, and indicated that the United States Department of Labor (DOL) has purview of the reporting requirements for self-funded health plans. In 2016, DOL issued a Notice of Proposed Rulemaking (NPRM) which provided a unique opportunity for states to provide comment about issues resulting from the Gobeille decision, and propose an approach to self-insured data collection under DOL’s authority for data collection. The APCD Council and the National Academy of State Health Policy (NASHP) submitted comments that included a proposal recommending that DOL require payers to submit data to state APCDs under a pilot cooperative agreement, using a standardized data layout. To date no decision has been made by the DOL, but states and payers agree that the need for APCD standardization remains.
The CDL is a reflection of that commitment, and culmination of nine months of work and expertise from 14 states and many vendors and payers. The CDL will reduce plan reporting burden and improve comparability of the data across states.
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 NCPDP and PACDR guides, as well as updates and additions to the core set of data elements developed by the APCD Council in 2011. Given the historical experience with the development of the core set of data elements and other standardization efforts, 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 representatives from national and regional payers in meetings facilitated by the APCD Council. The goal was to identify a CDL for APCD efforts that meet current needs of the states and aligned with the capacity of the payers.
States conducted the first review of the CHT Model Data Submission Manual and agreed that it could serve as the foundation for the Common Data Layout. During the process, states considered the business needs for the data elements proposed, the likelihood that payers collect and retain data elements in adjudication systems, and whether the data elements would be useful for analysis. Payers were invited to discuss and comment on the draft developed by the states. Since the summer of 2016, payers and states have participated in weekly calls to review every proposed data element in the CDL.
History of APCD Standards Development
2009 - Meetings with AHIP and AHRQ
2015 - Common Data Layout (CDL) Process Begins with APCD Council and partners
A more detailed history of APCD Council harmonization efforts can be found here.