Content created by Freedom of Information Act (FOIA) Division
A. Current Composition of the HHS Data Integrity Board (DIB)
- Names and positions of the members of the DIB
- Cheryl Campbell, Acting Chairperson and Voting Member, Acting Assistant Secretary for Administration
- Carol Maloney, Mandatory Voting Member, Executive Officer/Deputy Agency Chief FOIA Officer (carries out Privacy Act responsibilities for the HHS SAOP)
- 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, DC 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 2022
- CMA HHS #2201
Participant Agencies: HHS’ Centers for Medicare & Medicaid Services (CMS) is the source agency, and the Department of Veterans Affairs' Veterans Health Administration (VHA) is the recipient agency.
Title: “Disclosure of Information to Support the Veteran Affairs' Seek to Prevent Fraud, Waste, and Abuse Initiative”
Description: This matching program provides VHA with information from CMS’s PECOS and NPPES systems of records about revoked Medicare providers/suppliers whose identifying information matches identifying information about providers/suppliers participating in VA health care programs. The match results include the reasons for the Medicare revocations (such as, improper patient care or fraudulent billing practices). The matching program enables VHA to leverage, instead of duplicating, the costly process CMS uses to screen out unsuitable Medicare providers/suppliers, so that VHA can efficiently identify and revoke or take other appropriate action against those who are unsuitable VHA providers/suppliers.
Link posted in the Agency’s website: https://www.oprm.va.gov/docs/CMA/VA_CMS_CMA_508.pdf
Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes, CMS has fully adhered to the terms of the matching agreement.
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.
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 VHA, and the results demonstrated that the program is likely to be cost effective.
- CMA HHS #2202
Participant Agencies: HHS’ Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and the Department of the Treasury’s Internal Revenue Service (IRS) is the source agency.
Title: “Verification of Household Income and Family Size for Insurance Affordability Programs and Exemptions”
Description: This matching program enables IRS to provide certain taxreturn information (household income and family size) to CMS, for use by CMS and state Administering Entities (AEs) in verifying the household income and family size information provided by applicants receiving Affordable Care Act-related eligibility determinations. AEs include the federally-facilitated Exchange (FFE), state-based Exchanges (SBEs), State Basic Health Programs (BHPs), and approved state Medicaid or Children’s Health Insurance Program (CHIP) agencies.
Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/cms-cma-2202.pdf
Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes, CMS has fully adhered to the terms of the matching agreement.
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.
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 (CBA) was performed by CMS, which is a “Master” cost benefit analysis covering all Patient Protection and Affordable Care Act (PPACA) Marketplace related matching programs. Because the goal of the matching programs is to maximize enrollments in qualified health plans to reduce the uninsured population, not to avoid or recover improper payments, the CBA does not result in favorable benefit/cost ratio. The CBA examines how efficiently the matching programs are structured to limit costs and concludes that the existing structure remains more efficient (less costly) than any alternatives.
- CMA HHS #2203
Participant Agencies: HHS’ Administration for Children and Families (ACF)/Office of Child Support Enforcement (OCSE) is the source agency, and the Social Security Administration (SSA) is the recipient agency.
Title: "SSI-OCSE Quarterly Match Agreement” and “Online Query for SSI, Disability Insurance, & Ticket-to-Work Agreement"
Description: In this matching program, ACF/OCSE provides SSA with (1) the results of quarterly batch matches comparing quarterly SSA finder files of data (name and/or Social Security Number) about Disability Insurance (DI) and supplemental Security Income (SSI) clients to quarterly wage and unemployment files in ACF/OCSE’s National Directory of New Hires (NDNH) system of records, and (2) daily online access to new hire, quarterly wage, and unemployment insurance files in NDNH. The NDNH data assists SSA in (1) establishing or verifying eligibility or payment amounts, or both under the SSI program; (2) establishing or verifying eligibility or continuing entitlement under the DI program; and (3) administering the Ticket programs. These activities include overpayment avoidance and recovery for all three programs. SSA evaluates the cost-benefits, including programmatic and operational impact, which NDNH data has on SSA programs and operations.
Link posted in the Agency’s website: https://www.ssa.gov/privacy/cma/CMA%201074%20(Re-establishment)%20-%20Final%20Signed%20Agreement%20.pdf
Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes, ACF/OCSE has fully adhered to the terms of the matching agreement.
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.
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 SSA, which reflected a favorable estimated benefit-to-cost ratio of 3.74:1. The analysis showed that, in FY2021, SSA used NDNH data to identify 282,224 individuals receiving potential overpayments in Supplemental Security Income (SSI), and 145,805 individuals receiving potential overpayments in Unemployment Insurance (UI), which enabled SSA to save program funds by preventing erroneous future monthly benefit payments to those individuals.
- CMA HHS #2204
Participant Agencies: HHS’ Centers for Medicare & Medicaid Services (CMS) is the source agency, and the Social Security Administration (SSA) is the recipient agency.
Title: “Disclosure of Medicare Non-Utilization Information (Ages 90 and Above)”
Description: In this matching program, SSA provides annual finder files to CMS containing identifying information about SSA Title II beneficiaries aged 90 years and above, and CMS returns match results to SSA identifying any of the beneficiaries whose Medicare records have been inactive for three or more years and indicating which of those beneficiaries are associated with private health insurance, veteran’s health insurance, Tricare insurance, or an HMO or live in a nursing home. Non-utilization of Medicare benefits is an indicator of possible fraud, i.e., of Title II claims submitted for a beneficiary who may be deceased or otherwise ineligible. SSA uses the match results to select and prioritize cases to review to determine beneficiaries’ continued eligibility for Title II benefits and to refer cases of suspected fraud to its Office of Inspector General for investigation.
Link posted in the Agency’s website: https://www.ssa.gov/privacy/cma/CMA%201094%20Fully%20Signed%20-%20(2022).pdf
Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes, CMS has fully adhered to the terms of the matching agreement.
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.
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 SSA. The analysis yielded a favorable benefit-to-cost ratio of 7.97:1, demonstrating that the program is likely to be cost effective.
- CMA HHS #2205
Participant Agencies: HHS’s Administration for Children and Families (ACF)/Office of Child Support Enforcement (OCSE) is the source agency, and each participating state agency administering the Unemployment Compensation Program is a non-federal agency.
Title: “Administration of Unemployment Compensation Program”
Description: In this matching program, ACF/OCSE gives each participating state agency new hire and quarterly wage information from ACF/OCSE’s National Directory of New Hires (NDNH) system of records, on a weekly basis, pertaining to individual applicants for or recipients of unemployment compensation (UC) benefits whose names and Social Security Numbers have been transmitted to OCSE by the state agency. The state agency uses the NDNH comparison results to establish or verify the individuals’ eligibility for benefits or continuing compliance with statutory and regulatory requirements governing the UC program.
Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/uc-matching-agreement.pdf
Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes, ACF/OCSE has fully adhered to the terms of the matching agreement.
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.
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 the Department of Labor (DOL), which demonstrated that the matching program was likely to be cost-effective. It reflected an estimated net benefit of $201.32 million in avoided and recovered overpayments in FY21 as a result of using NDNH data combined with state SDNH data, of which $134 million was attributed to NDNH data.
- CMA HHS #2206
Participant Agencies: HHS’s Administration for Children and Families (ACF), Office of Child Support Enforcement (OCSE) is the source agency, and each participating state agency administering the Temporary Assistance for Needy Families (TANF) Program is a non-federal agency.
Title: "Verification of State TANF Eligibility"
Description: This matching program provides each participating state agency (of which there were eight in FY21) with new hire, quarterly wage, and unemployment insurance information from ACF/OCSE’s National Directory of New Hires (NDNH) system of records corresponding to names and Social Security numbers in state agency files about adult applicants for and recipients of assistance under the TANF program. The state agency uses the match results to establish or verify applicants’ and recipients’ eligibility for assistance under the TANF program and for the additional purposes of updating applicants’ and recipients’ work activity information and contact information and updating their employers’ contact information.
Link posted in the Agency’s website: https://www.hhs.gov/sites/default/files/tanf-matching-agreement.pdf
Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes, ACF/OCSE has fully adhered to the terms of the matching agreement.
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.
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 ACF/OCSE based on information reported by seven of the eight state agencies that participated in the matching program in FY21. The analysis demonstrated that the matching program was likely to be cost-effective.
- CMA HHS #2207
Participant Agencies: HHS’s Administration for Children and Families (ACF)/Office of Child Support Enforcement (OCSE) is the source agency, and the Social Security Administration (SSA) is the recipient agency.
Title: "Verification of Eligibility for Extra Help (Low Income Subsidy) under the Medicare Part D Prescription Drug Coverage Program"
Description: In this matching program, SSA provides names and Social Security Numbers of Extra Help Program applicants/beneficiaries to OCSE on a daily basis, which OCSE uses to provide quarterly wage and unemployment insurance information about the applicants/beneficiaries to SSA from ACF/OCSE’s National Directory of New Hires (NDNH) system of records. The NDNH information assists SSA in determining new applicants’ and existing beneficiaries’ eligibility for low-income subsidy assistance (i.e., extra help) under the Medicare prescription drug plan and in administering the Extra Help program.
Link posted in the Agency’s website: https://www.ssa.gov/privacy/cma/Final_Prescription_Drug_Match_CMA_1306_executed_081722.pdf
Please provide an account of whether the agency has fully adhered to the terms of the matching agreement. Yes, ACF/OCSE has fully adhered to the terms of the matching agreement.
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.
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 SSA; however, because this matching program doesn’t avoid or recover improper payments, there were no benefits in Key Elements 3 and 4 to offset the costs in Key Elements 1 and 2, so the analysis arguably didn’t demonstrate that the matching program is likely to be cost effective. The matching agreement stated other justifications which were sufficient to support DIB approval; i.e., that matching is less costly for SSA than using a manual process to obtain the NDNH data, that the NDNH data improves the accuracy of SSA’s Extra Help eligibility determinations and redeterminations, and that matching against NDNH data results in a faster and less burdensome enrollment process for beneficiaries.
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