TX-APCD Frequently Asked Questions

A: No. The law itself does not grant a small plan exception. However, after receiving feedback on the APCD regulations, TDI permits a one-year extension for small health insurers. Specifically, at 28 Texas Administrative Code 21.5405, the regulation states: “(c) A payor with fewer than 10,000 covered lives in plans that are subject to reporting under this subchapter as of December 31 of the previous year must begin reporting no later than 12 months after the dates otherwise required, as specified by the Center, consistent with subsection (a) of this section [which describes historic and monthly claims submission]. The payor must register with the Center to document the payor's eligibility for this extension.”

Small payors should also be aware that the 12-month extension does not modify the requirement that, when the extension expires, the historical dataset that must be submitted spans from “January 1, 2019, to the most recent monthly reporting period.” See 28 Texas Administrative Code §21.5405(b)(2).

A: The first day a payor may register is October 10, 2022 and registration must occur no later than November 10, 2022. Payors must then register each year by January 1 beginning in 2024.

A: A payor is required to submit the test data after registration and prior to the actual submission of monthly or historical data. In other words, a payor must test prior to submission of monthly or historical data. The failure to test before the compliance dates for data submission may result in a payor being out of compliance with the regulations.

A: There are no required test submission scenarios in the rule. That being said, we would like to test with at least 3 to 6 months of historical data, from the years specified in the rule; prefer at least two sequential months from the same year. The testing period is not only for the benefit of the submitters, but also so that the TX-APCD can validate its intake process. As such, we expect there to be feedback and negotiation during the testing phase.

A: Under the regulations at 28 TAC §21.5405 (b)(2), required submitters must provide “historical data from January 1, 2019, to the most recent reporting period”. In other words, the historical datafile begins January 1, 2019 and ends at the first monthly data submission.

A: The Technical Guide is currently in progress and is scheduled to be completed on or before October 10, 2022, which is the first day the Texas All-Payor Claims Database (TX-APCD) is open for registration.

A: In section 2.0 Data Quality which begins on page 17 of the Data Submission Guide (DSG), it indicates, “If any of these validations fail, the entire package will be rejected, and the submitter will need to resubmit the entire package”.

A: We would direct you to the applicability provision at 21.5401(b). There is a particular reference in (b)(21) for “a Medicare Advantage Plan providing health benefits under Medicare Part C as defined in 42 USC §1395w-21, et seq.;”. We note that specialized MA plans for special needs individuals are referenced in that section of the United States Code.

A: We would direct you to the applicability provision at 28 § TAC 21.5401, which “identifies the types of health plans that are subject to the requirements to produce all-payor claims data files”. Payors should note that section refers out to several chapters of the Insurance Code and those sections must be reviewed for a full understanding of who is included and excluded from submission.

A: Eligibility of exceptions and extensions cannot be determined until after registration is processed. Currently, registration with the TX-APCD is not open. Per the notice of the timeline for payors to submit registration, published on July 11, 2022, “Payors must register with the TX-APCD after October 10, 2022, but no later than November 10, 2022”. Therefore, registration submissions will not be processed until that time.

A: We encourage you to visit our website at https://go.uth.edu/txapcd and click on the “notifications” tab to check for updates.

Also, there is a check box on the Registration Form that can be selected under Contact Information if you wish to receive system notifications.

A: The Coverage Estimates section of the Registration Form is applicable to all claims and should be filled out for each entity being registered.

A: The amount entered for that field should be the total amount paid.

A: This field should have been labeled as “Required” (the similar field is “Required” in both the Medical and Dental claim files). We intend to make this change in the next version of the CDL prior to the required data submission date and urge submitters to treat this field as required. Doing so will be greatly appreciated and avoid submitter re-work when the next CDL is adopted.

A: Yes, if it is easier for your organization to submit data sets by line of business, please make note of it during the registration process so the request can be set up accordingly in the submissions portal.

A: Three classes of researchers can access the TX-APCD:

1. An organization engaging in public interest that the delivery of health care in this state that is
   exempt from federal income tax under Section 501(a), Internal Revenue Code of 1986;
2. An institution of higher education engaged in public interest research related to the delivery of
   health care in the state; or
3.  A health care provider in this state engaging in efforts to improve the quality and cost of health
   care.

A: Maybe. The Center for Health Care Data might be able to perform the research for your agency or
organization. Please contact us to see if that is possible.

A: Yes, the TX-APCD law does not permit the identification of providers, health plans, health benefit
plan issuer, or patients.

A: No. The TX-APCD law does not permit research that has, in part, a commercial purpose.

A: Yes, the TX-APCD requires all research to produce an IRB determination letter.

A: Not at this time.