2021 HHS Annual Computer Matching Report

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

Names and positions of the members of the DIB
- Cheryl Campbell, Chairperson and Voting Member, Assistant Secretary for Administration
- Carol Maloney, Mandatory Voting Member, Executive Officer/Deputy Agency Chief FOIA Officer, Office of the Assistant Secretary for Public Affairs
- Christi A. Grimm, Mandatory Voting Member, Principal Deputy Inspector General
- Martha C. Craig, Non-voting Advisory Member, Assistant Deputy Associate General Counsel
Name and Contact Information of the DIB Secretary

Jacqlyn Smith-Simpson
200 Independence Ave., SW
Washington, D.C. 20201
Jacqlyn.Smith-Simpson@hhs.gov, (202) 795-7648
Any Changes in Membership or Structure of the DIB

N/A

B. Matching Agreements HHS Entered Into in 2021

CMA HHS #2101

Participant Agencies: HHS’s Centers for Medicare & Medicaid Services (CMS) is the recipient agency and State-Based Administering Entities (AE) is the non-federal/source agency.

Title: “The Disclosure of Insurance Affordability Programs Information Under the Patient Protection and Affordable Care Act”

Description: In this matching program, CMS provides to each AE, through the Data Services Hub (Hub), data from CMS’s HIX system of records, which CMS obtains from source federal agencies under other Marketplace-related matching programs for the AE to use in determining individuals’ eligibility for state health subsidy programs. CMS provides such data to an AE in response to identifying information the AE submits to CMS through the Hub about applicants, enrollees, and other relevant individuals. To avoid dual enrollments, each AE shares data under this agreement with CMS and other AEs, verifying whether the individuals are enrolled in or eligible for Medicaid or the Children’s Health Insurance Program (CHIP).

Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/cms-cma-2101.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. Yes, the disclosures made in the matching program continue to be justified.

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. Yes, a cost-benefit analysis was performed. The cost benefit analysis is a “Master” cost benefit analysis covering all Patient Protection and Affordable Care Act (PPACA) Marketplace related matching programs. Although the cost-benefit analysis does not demonstrate that this matching program is likely to be cost effective, the matching program is justified for other reasons; specifically:

With respect to costs, it results in a total estimated cost of about $39 million for agencies to conduct the Marketplace matching programs.
With respect to benefits, it explains that the Marketplace matching programs are not currently used to identify and recover improper payments and debts but instead are meant to maximize enrollments in qualified health plans; consequently, there are no quantified estimated improper payment-related benefits in key elements 3 and 4 to offset against the personnel and computer costs estimated in key elements 1 and 2.

The analysis describes other benefits and mitigating factors, including 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 #2102

Participant Agencies: HHS’s Centers for Medicare & Medicaid Services (CMS) is the recipient agency and the Department of Defense (DoD)/Defense Manpower Data Center (DMDC) is the source agency.

Title: “Verification of Minimum Essential Coverage under the ACA Program”

Description: The purpose of this matching program is to is to enable DoD to make data from its DEERS system of records available to CMS, for CMS and state Administering Entities (AEs) to use to verify whether individual applicants and enrollees who are applying for financial assistance to pay for private health insurance coverage are eligible for coverage under DoD’s TRICARE Health Care Program. TRICARE provides minimum essential coverage (MEC), and eligibility for such a plan generally precludes eligibility for financial assistance in paying for private coverage. CMS provides DoD with identifying data, submitted by AEs, about applicants and enrollees from CMS’ HIX system of records in order to receive match results from DoD.

Link posted in the Agency’s website: https://dpcld.defense.gov/Portals/49/Documents/Privacy/CMAs/CMA18_2021_Establish.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. Yes, the disclosures made for use in the matching program continue to be justified.

With respect to costs, it results in a total estimated cost of about $39 million for agencies to conduct the Marketplace matching programs.
With respect to benefits, it explains that the Marketplace matching programs are not currently used to identify and recover improper payments and debts but instead are meant to maximize enrollments in qualified health plans; consequently, there are no quantified estimated improper payment-related benefits in key elements 3 and 4 to offset against the personnel and computer costs estimated in key elements 1 and 2.

The analysis describes other benefits and mitigating factors, including 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 #2103

Participant Agencies: HHS’s Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and the Department of Veterans Affairs (VA)/Veterans Health Administration (VHA) is the source agency.

Title: "Verification of Eligibility for Minimum Essential Coverage under the Patient Protection and Affordable Care Act Through a Veterans Health Administration Plan"

Description: In this matching program, VHA provides CMS with match results from VHA’s 54VA10NB3 system of records to assist CMS and state-based administering entities (AE) in determining whether individuals who apply for financial assistance (i.e., insurance affordability programs, including advance payments of the premium tax credit and cost-sharing reductions) in paying for private health insurance coverage are eligible for a VHA health plan. VHA health plans provide minimum essential coverage; eligibility for such plans precludes eligibility for financial assistance to pay for private coverage. The VHA provides the match results to CMS for any applicant identified in a request submitted by an AE whose identifying data (provided from CMS’s HIX system of records) matches VHA records, but only to the extent that VHA is authorized to release information about that individual.

Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/cms-cma-2103.pdf

Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes.

With respect to costs, it results in a total estimated cost of about $39 million for agencies to conduct the Marketplace matching programs.
With respect to benefits, it explains that the Marketplace matching programs are not currently used to identify and recover improper payments and debts but instead are meant to maximize enrollments in qualified health plans; consequently, there are no quantified estimated improper payment-related benefits in key elements 3 and 4 to offset against the personnel and computer costs estimated in key elements 1 and 2.

The analysis describes other benefits and mitigating factors, including 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 #2104

Participant Agencies: HHS’s Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and the U.S. Office of Personnel Management (OPM) is the source agency.

Title: “Verification of Eligibility for Minimum Essential Coverage under the Patient Protection and Affordable Care Act through an Office of Personnel Management Health Benefit Plan”

Description: In this matching program, OPM provides CMS with monthly data files showing the dates when each active federal employee was eligible for coverage under an OPM health benefit plan, and an annual file indicating the lowest premium available to federal employees in 32 localities. CMS does not share data with OPM to receive this data. CMS and state Administering Entities (AEs) conduct matches against the OPM data to determine if an applicant or enrollee in private coverage under a Qualified Health Plan through the federally-facilitated exchange or a state-based exchange is eligible for an OPM health benefit plan, and therefore not eligible for financial assistance in paying for the private coverage. (Financial assistance includes advance payment of the premium tax credit or a cost sharing reduction.) OPM plans provide minimum essential coverage (MEC); to be eligible for financial assistance in paying for private coverage, an individual must not be eligible for another plan that provides MEC.

Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/cma-cms-opm-2104.pdf

Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes.

With respect to costs, it results in a total estimated cost of about $39 million for agencies to conduct the Marketplace matching programs.
With respect to benefits, it explains that the Marketplace matching programs are not currently used to identify and recover improper payments and debts but instead are meant to maximize enrollments in qualified health plans; consequently, there are no quantified estimated improper payment-related benefits in key elements 3 and 4 to offset against the personnel and computer costs estimated in key elements 1 and 2.

The analysis describes other benefits and mitigating factors, including 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 #2105

Participant Agencies: HHS’s Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and the Peace Corps is the source agency.

Title: “Verification of Eligibility for Minimum Essential Coverage under the Patient Protection and Affordable Care Act through a Peace Corps Health Benefit Plan”

Description: In this matching program, the Peace Corps provides CMS with updated bulk data files each day, Tuesdays through Saturdays, showing the dates when each Peace Corps volunteer was eligible for coverage under a Peace Corps health benefit plan. CMS does not share data with the Peace Corps to receive this data. CMS and State Administering Entities (AEs) conduct matches against the data to determine whether a Peace Corps volunteer or other relevant individual (e.g., household member) who applies for or is enrolled in private insurance coverage under a Qualified Health Plan through the federally-facilitated exchange or a state-based exchange is eligible for financial assistance in paying for the private coverage. (Financial assistance includes advance payment of the premium tax credit or a cost sharing reduction.) Peace Corps health benefit plans provide minimum essential coverage (MEC); for an individual to be eligible for financial assistance in paying for private coverage, the individual (among other factors) must not be eligible for another plan that provides MEC.

Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/cma-cms-pcorps-2105.pdf

Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes.

With respect to costs, it results in a total estimated cost of about $39 million for agencies to conduct the Marketplace matching programs.
With respect to benefits, it explains that the Marketplace matching programs are not currently used to identify and recover improper payments and debts but instead are meant to maximize enrollments in qualified health plans; consequently, there are no quantified estimated improper payment-related benefits in key elements 3 and 4 to offset against the personnel and computer costs estimated in key elements 1 and 2.

The analysis describes other benefits and mitigating factors, including 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 #2107

Participant Agencies: HHS’s Administration for Children and Families (ACF), Office of Child Support Enforcement (OCSE) is the source agency, and the Department of Housing and Urban Development (HUD) is the recipient agency.

Title: "Verification of Employment and Income and Analysis"

Description: This matching program is statutorily required under 42 U.S.C. § 653(j)(7), provided that it does not interfere with efficient operation of child support programs. In the matching program, HHS provides HUD with new hire, quarterly wage, and unemployment insurance information from OCSE’s National Directory of New Hires (NDNH) database, to enable HUD to verify the employment and income of individuals participating in certain rental assistance programs whose names and SSNs are provided to HHS by HUD. HUD also uses the data (with personal identifiers removed) to conduct analyses (i.e., quality control studies) of the participants’ employment and income reporting. Use of the NDNH data for those purposes helps HUD to detect and reduce overpayments of rental housing assistance resulting from tenants’ under-reporting of their income; miscalculation of subsidy amounts; and billing errors by housing providers/administrators.

Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/acf-hud-cma-2107.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. Findings from the HUD September 2021 performance report indicated that HUD’s use of NDNH information helped HUD to identify applicant and recipients of certain HUD programs who underreported or failed to report income information required for use in determining subsidy payments. This helped HUD by either reducing or preventing improper payments from occurring. This was supported by the three conclusions from the HUD-NDNH computer matching analysis: 1) There is a strong correlation between income data provided from NDNH and household-level income reported to HUD by its funding recipients. 2) HUD income data reported over time appears to change in relation to NDNH. 3) A relationship exists between changes in HUD subsidy amounts and the NDNH to HUD income data correlation. The NDNH appears to provide HUD with an important and useful data point for HUD’s income verification and is a necessary independent data point to prevent potential improper payments.

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. HUD provided a cost-benefit analysis which demonstrated that the cost (approximately $1.4 million) to access the NDNH is significantly less than the benefits. During FY2020 HUD identified over $7 billion in underreported income by rental recipients, which could have resulted in $411 million in overpayments to rental recipients were it not for the data matching with NDNH. With over $6 million in HUD personnel and computer costs this represented a return of over 68:1or $68 saved for every dollar spent.

CMA HHS #2108

Participant Agencies: HHS’s Centers for Medicare & Medicaid Services (CMS) is the source agency, and the Federal Communications Commission (FCC) is the recipient agency.

Title: "Disclosure of Information to Support Eligibility Determination for Participation in the Federal Lifeline Program"

Description: This matching program provides FCC with information from CMS’ T-MSIS system of records confirming whether applicants and subscribers identified in files submitted by FCC to CMS are eligible for Medicaid. FCC uses the match results as one indicator to determine if the individuals meet low-income eligibility requirements for the Lifeline program; the Emergency Broadband Benefit Program (EBBP) funded under the CARES Act (now known as the Affordable Connectivity Program (ACP)); any extension of or successor to EBBP (now ACP); the National Telecommunications and Information Administration’s Connecting Minority Communities Pilot Program; and any program in any COVID-19 related relief legislation that uses qualification for Lifeline as an eligibility criterion.

The Lifeline program provides a discount on phone service (voice and broadband service) to qualifying low-income consumers to ensure that all Americans have the opportunities and security that phone service brings, including ability to connect to jobs, family, and emergency services. EBBP reimburses participating broadband suppliers for discounted broadband service and connected devices provided to qualifying households. Lifeline and EBBP (now ACP) are administered by the Universal Service Administrative Company (USAC) as agent for FCC. Provisions of the CMA are made binding on USAC through a separate agreement between FCC and USAC.

Link posted in the Agency’s website: https://www.fcc.gov/sites/default/files/cma_between_fcc_and_cms_final.pdf

Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes.

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. Yes, a cost benefit analysis was performed by FCC and the results demonstrated that the matching program is likely to be cost effective. The analysis estimated that the cost to conduct the matching program for the initial 18-month term of the matching agreement would be $972,180 (consisting mostly of CMS computer and personnel costs which are reimbursed by FCC) and that the matching program avoided $70.8 million improper payments in FY 2019. It also estimated that using matching instead of a manual process saves FCC $13.6 million in costs.

CMA HHS #2109

Participant Agencies: HHS’s Centers for Medicare & Medicaid Services (CMS) is the source agency, and the Social Security Administration (SSA) is the recipient agency.

Title: “Disclosure of Nursing Care Facility Admission and Discharge Information”

Description: This matching program provides SSA with certain nursing care facility information from CMS’s Long-Term Care - Minimum Data Set system of records (LTC/MDS) affecting Supplemental Security Income (SSI) and Special Veterans Benefit (SVB) beneficiaries’ eligibility for benefits and amount of benefits under SSA’s SSI and SVB programs. On a monthly basis, SSA provides CMS with a finder file containing beneficiaries’ names, Social Security Numbers, and other data from SSA’s SSI and SVB system of records; and CMS provides SSA with a response file containing certain nursing care facility admission and discharge data for the beneficiaries identified in the finder file. The match results help SSA to identify, more quickly and cost-effectively than under a manual process, beneficiaries who failed to report admissions to skilled nursing facilities (which affects the amount of their SSI benefit) and SVB beneficiaries who failed to report residency in the United States (which disqualifies them for SVB). SSA uses the data to enforce eligibility requirements and reduce and recover SSI and SVB overpayments.

Link posted in the Agency’s website: https://www.ssa.gov/privacy/cma/03.09.21%20-%20FINAL%20-%20SSA%20CMS%20CMA%201076%20-%20CMS%20SSA%20Agency%20Representatives%20Signatures%20-SSA%20DIB%20Chair.pdf

Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes.

CMA HHS #2110

Participant Agencies: HHS’s Centers for Medicare & Medicaid Services (CMS) is the source agency, and the Department of Defense/Defense Manpower Data Center (DMPC) and Defense Health Agency (DHA) is the recipient agency.

Title: “Disclosure of Enrollment and Eligibility Information for Military Health System Beneficiaries Who Are Medicare Eligible”

Description: This matching program identifies Military Health System (MHS) TRICARE beneficiaries who become eligible for Medicare Part A (due to age or disability) so that DoD can comply with a statutory mandate to discontinue MHS benefits to such beneficiaries unless they enroll in Medicare Part B. Enrolling dual-eligible beneficiaries in Medicare Part B makes Part B the primary payer and TRICARE the secondary payer for claims. Under the matching program, DoD provides weekly finder files to CMS containing Social Security Numbers and other identifying data about all MHS beneficiaries from DoD’s Defense Enrollment Eligibility Reporting System (DEERS) system of records, and CMS provides DoD with each beneficiary’s Medicare Part B enrollment status and address from CMS’ Enrollment Data Base (EDB) system of records. DoD uses the match results to notify relevant MHS beneficiaries that, to maintain TRICARE eligibility, they must be enrolled in Medicare Part B (or provide documentation showing they aren’t entitled to Medicare); discontinue MHS benefits to dual-eligible individuals who don’t enroll in Part B; and correct erroneous information.

Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/cma-cms-dod-military-health-system-2110.pdf

Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes.

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. Yes, a cost benefit analysis was performed by DoD, which did not quantify improper payments avoided or recovered to offset the estimated $139,000 cost of conducting the matching program for the initial 18-month term of the agreement, so did not demonstrate that the matching program is likely to be cost effective. However, the analysis established that the matching program is justified based on cost savings; i.e., that the $139,000 cost to conduct the matching program is approximately $31 million less than the cost would be to compare data manually.

CMA HHS #2111

Participant Agencies: HHS’s Administration for Children and Families (ACF), Office of Child Support Enforcement (OCSE) is the source agency, and the State Agency Administering the Supplemental Nutrition Assistance Program (SNAP) is the non-federal/recipient agency.

Title: “Information Comparisons and Disclosures to Assist in Administering the Supplemental Nutrition Assistance Program”

Description: This matching program provides state SNAP agencies with certain wage data (i.e., “new hire,” “quarterly wage,” and “unemployment insurance” information) from HHS/ACF/OCSE’s National Directory of New Hires (NDNH) system of records about individuals who are adult applicants for and recipients of SNAP benefits. The state agencies use the data to establish or verify the individuals’ eligibility for SNAP benefits and to detect beneficiaries who are receiving SNAP benefits from more than one state, in order to reduce errors in payment amounts, avoid and recover improper payments, and maintain program integrity. The state agencies also use the information for the secondary purposes of updating applicants’ and recipients’ reported participation in work activities and updating their contact information and their employers’ contact information.

Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/acf-snap-cma-2111.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. After verification of previously unknown income, participating state SNAP agencies collectively reported closing or reducing benefits for 158,228 cases in FY2021. As a result, state SNAP agencies avoided approximately $40,288,853 million in improper payments to SNAP recipients with previously unknown earnings. The savings were attributed to employment and wage information derived from the SNAP-NDNH computer matching program; therefore, the disclosures made for use in the matching program continue to be justified.

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 cost benefit analysis was prepared by ACF/OCSE based on fiscal year (FY) 2019 data reported by 24 of 49 participating state agencies and FY 2020 data reported by 17 of 52 participating state agencies. It estimated that annual personnel and computer costs to conduct the matching program totaled approximately $13.3 million ($12.8 million each year for OCSE, and $490,818 in FY 2019 and $536,502 in FY 2020 for all state agencies combined), and that the matching program avoided improper payments totaling approximately $16 million in FY 2019 and $13.8 million in FY 2020, demonstrating that the matching program is likely to be cost effective.

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

N/A

2021 Department of Health and Human Services (HHS) Annual Computer Matching Report

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

B. Matching Agreements HHS Entered Into in 2021

CMA HHS #2101

CMA HHS #2102

CMA HHS #2103

CMA HHS #2104

CMA HHS #2105

CMA HHS #2107

CMA HHS #2108

CMA HHS #2109

CMA HHS #2110

CMA HHS #2111

C. Programs Where Cost/Benefit Analysis was waived

D. Matching Agreements the DIB Disapproved

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

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