By Sean Miskell

As the Affordable Care Act has been successful in its efforts to expand coverage to millions of Americans, the attention of policymakers, advocates, and families will increasingly turn to the value of this coverage and the nature of the choices available to those looking for insurance in the marketplace. The more data we have to inform these choices, the better. However there is still a great deal of information that is not reported by either insurers or state health insurance marketplaces. This week, we joined with other national health policy organizations to urge the Centers for Medicare & Medicaid Services (CMS) to go further than their proposed data reporting requirements for insurers.

What CMS is asking from insurers

CMS’s proposed requirements apply to insurers selling Qualified Health Plans (QHPs) through the federally facilitated and supported marketplaces and would take effect beginning in 2016. Nearly one million children are enrolled in QHPs to date, making Marketplace coverage an increasingly important component of children’s coverage and helping to bring the rate of uninsured kids to historic lows at just 6 percent in 2014.

While the proposed requirements are a step in the right direction, our colleagues at the Center on Health Insurance Reforms rightly note that they are but a baby step that explicitly require very little of effort from insurers. A more comprehensive approach is needed to ensure that the data informs both policy and consumer choice.

Our letter to CMS proposes ways in which this reporting might be more robust to meaningfully inform the decisions of both policymakers and families looking for high quality, affordable health coverage. Briefly, our suggestions include:

• There is currently no proposed timeline for when issuers will report additional metrics not addressed in the current proposed requirements. CMS should adopt a specific timeline for required reporting of data for non-Marketplace plans so that insurers and other stakeholders can adequately plan for and expect specific data in the future.

• The proposed requirements only call for issuer-level enrollment numbers. Disaggregated, plan-level enrollment data that includes information on income, geographic location (state), and demographic information (race/ethnicity) would be much more useful to consumers surveying the options available to them and would allow stakeholders to locate and understand patterns in consumer behavior.

• Insurers should also report plan-level disenrollment data would also help shed light on how consumers are experiencing different plans, paid and unpaid claims data by age and income, with diagnosis and service codes as well as how cost-sharing rules are applied for in-network care versus out-of-network.

• CMS should ensure that this data is presented and summarized in a way that is understandable for consumers. Though the proposal requires insurers to provide links to plan documents, consumers will benefit most if they have access to the actual documents as well as a summary that is either approved or provided by CMS.

Why we want more

The way in which this data is used is just as important as what is provided in the first place. Towards these ends, we pushed back against CMS’s statement that the agency “does not intend to use the information submitted in this PRA package for oversight purposes.” There is not no doubt that the rationale behind the Affordable Care Act’s reporting requirements was for both the public and policymakers to gain insight on how insurance is working for people based on how their plans are designed and administered. The agency should review reported data for patterns and identify trends that warrant further investigation. CMS should also delineate the specific enforcement mechanisms it will implement should issuers not comply with these important reporting and transparency requirements.

Finally, Say Ahhh! readers certainly know that the Children’s Health Insurance Program (CHIP) is only funded by Congress through 2017. During this relatively short window before lawmakers will have to once again choose whether to extend funding for CHIP, it is important to understand the nature of the options available to children in families with low and moderate incomes currently covered by CHIP. Though CCF has found that families often face higher out of pocket costs QHPs available in the Marketplace compared with CHIP, not enough is known about the experience of children with marketplace coverage. Without comprehensive, accurate, and timely data about the experience that children have under this coverage, it is difficult to answer the policy questions raised by the potential end of the CHIP program in 2017.