2020 HHS Annual Computer Matching Report

A.  Current Composition of the HHS Data Integrity Board (DIB)

B.  Matching Agreements HHS Entered Into in 2020

• CMA HHS #2001

  Participant Agencies: HHS’ Administration for Children and Families (ACF), Office of Child Support Enforcement (OCSE) is the source agency, and each State Agency Administering the Unemployment Compensation Program (also referred to as State Workforce Agency or “SWA”) is the non-federal/recipient agency.
  
  Title: “Verification of Unemployment Compensation (UC) Program Eligibility”
  
  Description: This matching program assists each SWA in administering the Unemployment Compensation (UC) benefits program, by providing it with new hire and quarterly wage information from OCSE’s National Directory of New Hires (NDNH) about UC benefit applicants and recipients, to use to establish or verify the individuals’ eligibility for UC benefits and continuing compliance with statutory and regulatory requirements of the UC program.
  
  Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/acf-uc-cma-2001.pdf  
  
  Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes.
  
  Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified. All disclosures continue to be justified, based on the last cost benefit analysis (CBA) prepared, described below.
  
  Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective. A CBA was conducted by the Department of Labor (DOL), which oversees the UC program, based on data provided by 51 of the 53 participating SWAs. The CBA demonstrates that, in FY 2018, the combined cost for all the SWAs to participate in the matching program was $1.9 million and that, due to use of NDNH data, SWAs collectively reported $53.6 million in established overpayments and $48.4 million in overpayments prevented and recovered.

• CMA HHS #2002

  Participant Agencies: HHS’ Administration for Children and Families (ACF), Office of Child Support Enforcement (OCSE) is the source agency, and State Agency Administering the Temporary Assistance for Needy Families (TANF) Program is the non-federal/recipient agency.
  
  Title: “Verification of State Temporary Assistance for Needy Families Program (TANF) Eligibility”
  
  Description: This matching program assists each state agency in administering the TANF program, by providing the state agency with new hire, quarterly wage, and unemployment insurance information from OCSE’s National Directory of New Hires (NDNH) pertaining to individuals who are adult applicants for, or recipients of, assistance under the TANF program.  The state agency uses the NDNH data to establish or verify the individuals’ eligibility for TANF benefits, reduce payment errors, and maintain program integrity. The state agency may also use the NDNH information for updating the individuals’ reported participation in work activities and updating contact information maintained by the state agency about the individuals and their employers.
  
  Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/acf-tanf-cma-2002.pdf
  
  Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes.  
  
  Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified. All disclosures continue to be justified, based on the last cost benefit analysis (CBA) prepared, described below.  
  
  Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective. ACF’s Office of Family Assistance (OFA), which oversees the TANF program, provided performance outcomes derived from data provided by six of the eight state agencies participating in the matching program in FY 2018, which was used in performing a CBA. The CBA demonstrates that, in FY 2018, the combined cost for all eight state agencies to participate in the matching program was $241,863, but that they collectively avoided approximately $1,058,525 in improper payments to TANF recipients with previously unknown earnings.

• CMA HHS #2003

  Participant Agencies: HHS’ Administration for Children and Families (ACF), Office of Child Support Enforcement (OCSE) is the source agency, and Social Security Administration (SSA) is the recipient agency.
  
  Title: "Verification of Eligibility for Extra Help (Low Income Subsidy) Under the Medicare Part D Prescription Drug Program"
  
  Description: This matching program assists SSA in administering the Extra Help program, by providing SSA with quarterly wage (QW) and unemployment insurance (UI) information from OCSE’s National Directory of New Hires (NDNH) about individuals who apply for or are receiving low-income subsidy assistance (extra help) under the Medicare Part D prescription drug program. SSA uses the NDNH information in determining the individuals’ eligibility for the extra help.
  
  Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/acf-ssa-cma-2003.pdf   
  
  Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes. 
  
  Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified. All disclosures continue to be justified, based on costs SSA saves by using the matching program (an automated process) instead of a manual process to obtain the NDNH data (see below).
  
  Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective. SSA performed a CBA for this agreement, based on FY 2018 data, which does not include any avoided or recovered improper payments as benefits to offset against the estimated $903,500 cost of conducting the matching program, so does not demonstrate that the matching program is likely to be cost effective. The HHS Data Integrity Board (DIB) approved the matching program based other supporting justifications stated in the CBA, i.e., $15,909,954 in cost savings to SSA from using the matching program (an automated process) instead of a more costly manual process to obtain the NDNH data.

• CMA HHS #2004

  Participant Agencies: HHS’ Centers for Medicare & Medicaid Services (CMS) is the source agency, and the Department of Treasury’s Bureau of Fiscal Services is the recipient agency.
  
  Title: “Do Not Pay Initiative”
  
  Description: This matching program provides CMS with information from Treasury’s Do Not Pay Working System to assist CMS in identifying providers and suppliers who are ineligible to be enrolled in and bill Medicare, and should not be entrusted with patient care, because they are reflected in Treasury’s Do Not Pay Working System as ineligible to receive federal payments and awards..  The results of the matching program enable CMS to promptly suspend or revoke disqualified providers’ and suppliers’ Medicare billing privileges, avoid or recover improper payments made to them, and enhance patient safety.
  
  Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/cms-irs-do-not-pay-cma-2004-508.pdf   
  
  Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes. 
  
  Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified. All disclosures continue to be justified, based on the monetary and non-monetary benefits of conducting the program, described below.
  
  Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.
  A CBA was performed, which does not quantify amounts of improper payments avoided or recovered to offset the costs of conducting the matching program, so does not demonstrate that the matching program is likely to be cost effective.  However, the CBA describes the following benefits that justify conducting the matching program:

  • Monetary Benefits: 
    Using Treasury’s Do Not Pay Working system under a single matching agreement with Fiscal Service avoids the need to manually compare files or to execute separate matching agreements with multiple agencies. CMS’ costs to detect disqualified providers and suppliers using those alternative methods would be significantly greater than the costs of conducting this matching program; those significantly greater costs are avoided by the matching program.
    
    The matching program enables CMS to detect unqualified providers and suppliers and suspend or revoke their Medicare billing privileges sooner than would be possible using alternative methods. This not only avoids future payments that would be improper, but reduces the incidence of malpractice cases and those attendant costs.
  • Non-Monetary Benefits:
    Non-monetary benefits are of greater importance to the CMS mission, and include increased patient safety, reduced reputational risk, and prevention of malpractice. Patient safety is of utmost importance to the CMS mission and its importance cannot be measured in dollars.

• CMA HHS #2007

  Participant Agencies: HHS’ Administration for Children and Families (ACF) is the source agency, and Social Security Administration (SSA) is the recipient agency.
  
  Title: “Title II-Office of Child Support Enforcement Quarterly Match”
  
  Description: This matching program assists SSA in administering the Title II Disability Insurance (DI) program, by providing SSA with quarterly wage data (and, if legally required, unemployment insurance data) about DI applicants and recipients (clients), from OCSE’s National Directory of New Hires (NDNH). SSA uses the data to identify clients who are working and earning wages, so that SSA can make correct DI entitlement determinations, calculate correct DI payment amounts, and avoid and recover DI overpayments.
  
  Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/acf-ssa-cma-2007.pdf   
  
  Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes.
  
  Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified. All disclosures continue to be justified, based on the last cost benefit analysis (CBA) prepared, described below.
  
  Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.
  SSA performed a cost-benefit analysis which demonstrates,  $19,155,311 in costs and $240,775,680 in avoided overpayments for 42,157 cases measured in FY 2018, of which 264 cases were determined to have an overpayment which would have continued undetected for eight months without the matching program, resulting in a favorable benefit-to-cost ratio of 12.6:1.

• CMA HHS #2008

  Participant Agencies: HHS’ Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and the Social Security Administration (SSA) is the source agency.
  
  Title: "Determining Enrollment or Eligibility for Insurance Affordability Programs Under the Patient Protection and Affordable Care Act"
  
  Description: This matching program enables CMS to compare Health Insurance Exchanges (HIX) Program data about Qualified Health Plan applicants and enrollees (and other individuals seeking eligibility determinations through the Exchanges) to SSA data, to confirm the individuals’ 1) identity and citizenship, 2) status as deceased or imprisoned, and 3) Title II disability benefit quarters of coverage and monthly and annual income, for the purpose of determining the individuals’ eligibility to enroll in a Qualified Health Plan through an Exchange established under the Patient Protection and Affordable Care Act (PPACA) and eligibility for Insurance Affordability Programs and  certifications of exemption from the shared responsibility payment; and for the purpose of making eligibility redeterminations and renewal decisions, including appeal determinations.
  
  Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/cms-ssa-cma-2008.pdf
  
  Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes. 
  
  Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified. All disclosures continue to be justified, as non-discretionary under the PPACA (i.e., as necessary in order to provide a single, streamlined application process that will maximizes enrollments in Qualified Health Plans under the PPACA). 
  
  Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective. A CBA was prepared which covers all eight PPACA Marketplace matching programs. The CBA reflects that the matching programs do not avoid or recover improper payments with which to recoup the cost to conduct them, so does not demonstrate that the matching programs are likely to be cost effective. The CBA demonstrates a total estimated cost of approximately $39 million for agencies to conduct the eight Marketplace matching programs, and describes the following justifications:

  • Because the PPACA mandated a single, streamlined application process, the matching programs are not discretionary but must be conducted even if not cost-effective to conduct.
  • The existing matching structure, which is a choice, continues to be effective in providing accurate determinations and maximizing enrollments and continues to be less costly than an alternative structure that CMS could have adopted (which would have required each AE to enter into separate matching agreements with each source agency).
  • Maximizing enrollments in qualified health plans results in coverage which (depending on usage) provides cost savings for enrollees (consumers) that outweigh their cost to apply for and maintain the coverage.

• CMA HHS #2010

  Participant Agencies: HHS’ Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and the Department of Homeland Security’s United States Citizenship and Immigration Services (USCIS) is the source agency.
  
  Title: "Verification of United States Citizenship and Immigration Status Data for Eligibility Determinations"
  
  Description: This matching program provides CMS’ Health Insurance Exchanges (HIX) Program with immigrant, nonimmigrant, and naturalized or derived citizen status information from USCIS’s SAVE program about Qualified Health Plan applicants and enrollees (and other individuals seeking eligibility determinations through the Exchanges), for the purpose of  assisting CMS and State Administering Entities in determining the individuals’ eligibility to enroll in a Qualified Health Plan through an Exchange established under the Patient Protection and Affordable Care Act (PPACA) or eligibility for Insurance Affordability Program or for one or more exemptions.
  
  Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/cms-cma-2010.pdf
  
  Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes. 
  
  Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified. All disclosures continue to be justified, as non-discretionary under the PPACA (i.e., as necessary in order to provide a single, streamlined application process that will maximizes enrollments in Qualified Health Plans under the PPACA). 
  
  Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective. A CBA was prepared which covers all eight PPACA Marketplace matching programs. The CBA reflects that the matching programs do not avoid or recover improper payments with which to recoup the cost to conduct them, so does not demonstrate that the matching programs are likely to be cost effective. The CBA demonstrates a total estimated cost of approximately $39 million for agencies to conduct the eight Marketplace matching programs, and describes the following justifications:

  • Because the PPACA mandated a single, streamlined application process, the matching programs are not discretionary but must be conducted even if not cost-effective to conduct.
  • The existing matching structure, which is a choice, continues to be effective in providing accurate determinations and maximizing enrollments and continues to be less costly than an alternative structure that CMS could have adopted (which would have required each AE to enter into separate matching agreements with each source agency).
  • Maximizing enrollments in qualified health plans results in coverage which (depending on usage) provides cost savings for enrollees (consumers) that outweigh their cost to apply for and maintain the coverage.

C.  Programs Where Cost/Benefit Analysis was waived

N/A

D.  Matching Agreements the DIB Disapproved

N/A

E.  Any Violations of Matching Agreements that Have Been Alleged or Identified

Yes.  The Department of Health and Human Services (HHS) has identified one violation that involved the continuation of matching activities following the expiration of the matching agreement.  Upon identification of the violation, the relevant HHS component immediately ceased matching activities with the participating agency.  Corrective action to re-establish the following lapsed matching agreement is underway and expected to be completed later this year.  Discussions between the participating agencies about other appropriate remedial actions are ongoing. 

• CMA HHS #1603 (Expired 10/1/2018)

  Participant Agencies: HHS’ Centers for Medicare & Medicaid Services (CMS) is the source agency, and the Department of Defense/Defense Manpower Data Center (DMDC) is the recipient agency.
  
  Title: "Disclosure of Enrollment and Eligibility Information for Military Health System Beneficiaries Who are Medicare Eligible"
  
  Description: This matching program enables the DMDC to identify Military Health System (MHS) beneficiaries who are eligible for TRICARE and become entitled to enroll in Medicare Part A and aren’t enrolled in Medicare Part B (to switch them from TRICARE to Medicare Part A) and individuals who are eligible for and have opted to be covered under Medicare Part B (i.e., to use Part B as primary payer and TRICARE as secondary payer), so that DMDC can comply with a statutory mandate to discontinue MHS benefits to beneficiaries who become eligible for Medicare Part A unless they enroll in Medicare Part B.