7 Challenges, Opportunities for All-Payer Claims Databases

APCD Challenges

The three challenges that the report outlined spanned a broad scope of issues from data gaps to funding insecurities.

First, there are key populations of Americans that are excluded from APCDs, leaving policymakers without APCD data on approximately a third of state residents.

Plans that are generally included in APCDs are individual market plans, Medicaid, and Medicare Advantage plans. Fee-for-service Medicare data is sometimes included. But Federal Employee Health Benefit (FEHB) Program Plans and Veterans Health Administration (VHA) plans are typically excluded as well as data for most self-insured and federally-managed plans.

The second problem that APCDs face concerns the data collection process. Data collection standards and access criteria vary widely across states. There are no overarching, national requirements for APCD designs or protocols.

The lack of uniformity can create significant challenges for states and healthcare stakeholders who are trying to leverage the data to make broad-range decisions.

Third, funding for these efforts is a noticeable barrier. Most APCD agencies are funded through states’ general funds. As a result, their budgets shift annually, restricting their long-term planning capabilities.

APCD Opportunities

These challenges may be frustrating for state APCD agency leaders, health plans, and other healthcare stakeholders, but they are accompanied by four opportunities.

One highly visible opportunity is to expand APCDs across the 32 states and the District of Columbia that currently do not have APCDs.

The lack of APCDs in these states creates a number of issues, particularly when trying to leverage APCD data to assess national and cross-state trends. States that have APCDs are clustered in the Northeast, mid-Atlantic, and Pacific coast, which means that there are entire regions of the country where APCD analyses cannot apply.

To expand the presence of APCDs, policymakers could establish a fixed federal funding stream to support the maintenance of health data organizations. Additionally, states and federal agencies can work toward lowering APCD operating expenses. Cross-state data collection could assist in this effort.

As APCDs extend into more states, the report mentioned that a nonprofit could set up an opportunity for relevant parties, including federal and state industry leaders, to meet and establish technical and data privacy standards. Nonprofits could also support the effort to improve APCD presence by helping communicate the need for APCDs to policymakers and regulators.

In addition to expanding the presence of APCDs nationwide, states may seek to fill data gaps and expand the data to which they have access.

The inability to access ERISA-preempted self-insured plans’ data is one of the biggest data gaps that APCDs face. If an APCD could house this type of data, it would expand that state’s ability to analyze its employer-sponsored health insurance market.

The Department of Labor (DOL), along with the Department of Health and Human Services (HHS), could implement a national APCD data standard for self-insured data, the report suggested. Policymakers and healthcare leaders could use the APCD Council’s common data layout (CDL) as a foundation for this effort.

Other ideas for extending APCD sources to encompass self-insured data included allowing DOL to require self-insured employers to report their data to state or national APCDs, eliminating payers and third-party administrators from setting fees for submitting data to APCDs, and establishing federal-state terms of data collection.

States and federal agencies should also consider improving federal data collection through a centralized clearinghouse and bolster state APCD data collection by incorporating non-claims-based payments and demographic data.

The third opportunity is to align states’ APCD activities such as data standardization, harmonization of data curation, privacy and security protections, following data access requirements, supporting analytics resources, and using analytic methodologies.

The fourth and final opportunity is to address financial and workforce gaps.

The report recommended establishing better funding support. State and federal leaders could accomplish this by securing federal financial support, channeling APCD operating expenses into analytics instead of data collection, protecting health data organizations’ funding, and other strategies.

APCD agencies should ensure that their workforce is mission-driven. States may need to rethink their health data organization structure. They should focus on attracting strong talent by offering flexibility, allowing cross-training and upskilling, rewarding strong performance, and emphasizing clear goals and purpose.