Overview
Title
Agency Information Collection Activities: Submission for OMB Review; Comment Request
Agencies
ELI5 AI
The Centers for Medicare & Medicaid Services want to know what people think about their plan to gather information, which helps them do their job better, and everyone can share their thoughts until February 8, 2021.
Summary AI
The Centers for Medicare & Medicaid Services (CMS) is inviting public comments on their plan to gather information from the public, as required by the Paperwork Reduction Act of 1995. This notice provides an opportunity for people to comment on the estimated burden and the necessity of collecting this information for effectively carrying out the agency's responsibilities. One specific collection relates to the QECP Annual Report Workbook, which involves qualified entities submitting annual reports to CMS about Medicare claims data usage. Comments must be submitted by February 8, 2021, and further details are available on CMS’s website or by contacting their office.
Abstract
The Centers for Medicare & Medicaid Services (CMS) is announcing an opportunity for the public to comment on CMS' intention to collect information from the public. Under the Paperwork Reduction Act of 1995 (PRA), federal agencies are required to publish notice in the Federal Register concerning each proposed collection of information, including each proposed extension or reinstatement of an existing collection of information, and to allow a second opportunity for public comment on the notice. Interested persons are invited to send comments regarding the burden estimate or any other aspect of this collection of information, including the necessity and utility of the proposed information collection for the proper performance of the agency's functions, the accuracy of the estimated burden, ways to enhance the quality, utility, and clarity of the information to be collected, and the use of automated collection techniques or other forms of information technology to minimize the information collection burden.
Keywords AI
Sources
AnalysisAI
The document under discussion is a notice from the Centers for Medicare & Medicaid Services (CMS), part of the U.S. Department of Health and Human Services. It describes an opportunity for the public to comment on CMS's plan to collect information, a requirement established by the Paperwork Reduction Act of 1995. The Paperwork Reduction Act mandates that federal agencies publish notices about any proposed collection of information and offer the public an opportunity to comment. This notice specifically relates to CMS obtaining feedback on their civil process concerning the gathering of data, including comments about the burden this information collection might impose on entities.
General Summary
The notice invites public commentary on CMS's intention to continue collecting particular data, particularly relating to Medicare claims data usage through the QECP Annual Report Workbook. The document specifies a deadline for submitting comments by February 8, 2021. It is seeking feedback not just on estimated burdens but also on the necessity and utility of this information to ensure efficient agency function.
Significant Issues and Concerns
There are several important concerns highlighted in the document:
Burden Estimate Calculation: The document mentions a total annual burden of 3,450 hours but does not specify how this figure was derived. This lack of transparency in calculation could hinder thoughtful commentary from the public as stakeholders may struggle to evaluate the accuracy of this estimation.
Agreements and Privacy: While the document briefly mentions agreements like the QE DUA, it misses detail on their specific purposes, potentially leaving stakeholders uncertain about the requirements and implications of entering such agreements. Further, the lack of explicit detail on the privacy and security measures employed to protect sensitive data is concerning since confidential beneficiary data is involved.
Understanding for General Audience: The notice may not be easily understandable for the general public due to the introduction of technical terms and references to specific legislation, such as the ACA, MACRA, and QECP, without providing adequate context or definitions.
Qualified Entity: There is ambiguity regarding what exactly qualifies an entity to access Medicare claims data. This lack of clarity could create confusion among stakeholders evaluating whether they meet the criteria.
Impact on the Public
The public broadly may not feel an immediate impact from this notice, yet it relates to how information is managed and protected by the government. Specifically, the notice is important for transparency and allows public participation in governmental processes, aligning with democratic practices.
Impact on Specific Stakeholders
For entities categorized as "qualified," this notice certainly holds significance. They need to conform to various requirements, including annual submissions, data agreements, and compliance with privacy standards. While this may present additional work, it aligns with broader objectives for data transparency and accountability. There could be positive impacts for these entities if the public feedback leads to a more streamlined or less burdensome process for data submission.
Conversely, without clarity in some terms and calculations, there may be concerns about the complexity of compliance and understanding the regulatory environment. These hurdles might result in hesitance or errors in submissions, risking penalties or reduced participation in beneficial programs like those under ACA or MACRA.
In summary, while this notice is part of routine governmental processes ensuring oversight and public engagement, a lack of detail in specific areas may challenge stakeholders, highlighting a need for clearer communication and explanation from CMS.
Issues
• The document does not specify how the estimated burden of 3,450 total annual hours was calculated, which could make it difficult to assess whether this estimation is accurate or reasonable.
• The distinction between different types of agreements (QE DUA or non-public analyses agreement) is only briefly mentioned and may benefit from greater clarity about their specific purposes and implications.
• While the document mentions privacy and security requirements, it lacks detail on the specific measures that will be employed to protect individually identifiable beneficiary information.
• The document uses some technical terms and references to legislation (e.g., ACA, MACRA, QECP) without providing definitions or context, which might hinder understanding for those not familiar with these terms.
• There is a lack of clarity on what constitutes a 'qualified entity' and the criteria that will be used to evaluate whether an entity meets this qualification.