Issued by: Centers for Medicare & Medicaid Services (CMS)

Issue Date: November 14, 2014

Program Area: Distributed Data Collection (DDC) for RA Including HCRP/EDGE Server

Question: What is the definition of a Third-Party Administrator (TPA)? Are there additional steps necessary for registration when using a TPA?

Answer: A TPA-hosted EDGE server request must be submitted in cases where a third party contractor purchases and provisions a server on behalf of an issuer. In other words, the designations of TPA-hosted and issuer-hosted must be based on the organization that has primary ownership of a server (i.e., the organization that owns the physical server or has a contract with a virtual server provider). An issuer-hosted request may be submitted in cases where an issuer owns the server, but grants contractors user access to the server to perform tasks related to EDGE server operations. In cases where an issuer has granted their contractors access to the Health Insurance Oversight System (HIOS) as an issuer user (i.e., a TPA or other contractor user is able to log into HIOS as an issuer user), TPAs must still set-up HIOS accounts for their own organizations and register in HIOS as an EDGE TPA (TPAs may not submit an issuer-hosted EDGE server request on behalf of an issuer even if the TPA is currently registered as an issuer user in HIOS). The Centers for Medicare & Medicaid Services (CMS) requires all issuers and TPAs to sign an EDGE Server License Agreement for all TPA hosted servers. Thus, TPAs must be appropriately identified in EDGE server requests.

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