Since passage of the state budget in 2013, the State of Connecticut has been collecting health data under a program called the All Payer Claims Database (APCD), a massive compendium of medical claims and costs meant to allow consumers, hospitals, insurers, researchers, lawmakers, and state agencies to access that data, gain insights into Connecticut’s healthcare landscape, and help lower the cost of healthcare in the state.

The APCD grew out of the Affordable Care Act under President Barack Obama’s administration, which encouraged healthcare transparency and offered funding to help state officials develop healthcare claim databases. Connecticut received $6.5 million to create the APCD, which was originally housed under the purview of Connecticut’s health insurance exchange where it largely sat dormant until it was transferred to the Office of Health Strategy (OHS) shortly after the agency’s creation in 2018. Under the purview of OHS, the APCD has been getting more attention from researchers, hospitals, and private entities. 

Containing over two billion claims, the APCD is big, complex, and expensive to maintain, but whether the database is living up to expectations depends on who you ask; some healthcare industry insiders interviewed by Inside Investigator, largely on background, say there are barriers to access, the data isn’t robust, and that the state is significantly behind in its ability to accurately collect data. OHS officials, conversely, claim Connecticut’s APCD is one of the best, most thorough, and most accessible databases in the country.

According to the legislation passed in 2013, the APCD is meant to, “provide health care consumers in the state with information concerning the cost and quality of health care services that allows such consumers to make economically sound and medically appropriate health care decisions;” and, “make data in the all-payer claims database available to any state agency, insurer, employer, health care provider, consumer of health care services or researcher for the purpose of allowing such person or entity to review such data as it relates to health care utilization, costs or quality of health care services.” 

“I think it’s timely and super important to be calling the question on the utility of the APCD and whether we’re maximizing the public benefit of having an APCD,” said Mark Schaefer, Vice President, System Innovation and Financing, for the Connecticut Hospital Association (CHA). “I know how expensive it is to manage a high functioning APCD, but I also recognize the extraordinary value the APCD can provide that is really available nowhere else in terms of a comprehensive view of all paid claims.”

“Connecticut’s All Payer Claims Database does not have a credible body of data,” said healthcare consultant Jeffrey Hogan of Upside Health Advisors in Farmington. “It’s also veritably impossible to navigate for an employer and to gain insights.”

The idea behind collecting this kind of data for use in the healthcare industry is that more data allows more analysis to find gaps in coverage, expand access to care, understand and compare current costs for services across different providers, and “develop health care reform efforts that are designed to address spiraling health care costs,” according to a 2010 overview prepared for lawmakers.

Obviously, healthcare costs have continued to rise, sometimes at an alarming rate. It is a trend that has led to various proposals at the state capitol ranging from a public health plan to allowing association health plans, both of which succumbed to political infighting. 

Hoping that data is the key to helping reduce costs, the state of Connecticut, through OHS, uses a variety of different data. OHS sets annual healthcare cost growth benchmarks; it manages the state’s Certificate of Need process that approves or rejects significant changes by medical providers, and created dashboards by which consumers can estimate their medical costs.

All of it, to one extent or another, uses the data contained in the APCD. Therefore, the quality and analysis of the data can greatly affect conclusions reached by the state agency charged with lowering healthcare costs in the state and maintaining a regulatory hand over medical providers and insurance companies.

And, of course, maintaining these massive datasets is expensive, possibly adding to healthcare costs because the majority of OHS’s budget is derived from $100 million in fees levied on insurance companies, who then pass on those costs to consumers. 

OHS spends roughly 84 percent of its budget on outside contractors to manage all this data. The contract to operate Connecticut’s health information exchange, known as CONNIE, is the largest single contract at $7.8 million for 2025; the APCD is the second largest at nearly $1.1 million for 2025. If one adds in the healthcare benchmark data and analysis, there is another $900,000 in contracts between two companies.

The problem, according to some in the healthcare industry, is that the data between the APCD, the benchmarks, and the dashboards doesn’t match or work together in any comprehensive manner that would ultimately prove useful for providers, insurers, and consumers. Secondly, those who are granted access to the data – which requires going before a committee – are then left to their own devices to interpret and analyze the data, a prospect that can be difficult even for those in the healthcare industry employing data analysts with big budgets.

Those interviewed often pointed to surrounding states like Massachusetts, which analyzes the data itself so that it is understandable, offering insights for both the state and for stakeholders; and Maine, which they claim has more robust data and a better-functioning website that makes comparing the cost of procedures for the average citizen easier and more accurate.

These opinions, however, are certainly not shared by officials at OHS, who make the complete opposite assertion that Connecticut’s APCD “is one of the most comprehensive and transparent sources of health cost data in the nation,” according to OHS Health Information Technology Officer Sumit Sajnani.

“With over 2.2 billion claims from Medicare, Medicaid, and commercial insurers, it provides an unmatched view of healthcare costs, utilizations, and access,” Sajnani wrote in a response to Inside Investigator’s questions. “The CT APCD has been nationally recognized by the National Association of Health Data Organizations for its innovation and accessibility.”

But the difference in perception of the APCD between those working in the commercial and medical industry and those in OHS could not be farther apart.

“Long story short, there’s been a lot invested in this All-Payer Claims Database, and it’s not functional for any of the stakeholders involved, both because they haven’t been encouraged to participate and because the existing infrastructure has not been improved to be sufficiently usable for the stakeholders,” Hogan said.

A Lack of Data?

One of the easiest to understand issues with the APCD is a lack of data, according to those interviewed. Currently, the APCD collects data for Medicaid, Medicare Advantage, Medicare fee-for-service, the State of Connecticut health plan, and for fully-insured, large group plans.

What the data lacks, however, is claims for self-insured plans, which comprise the largest group of consumers in the state, and to which more and more employers have been turning to avoid the cumbersome and costly small group plans regulated by the state, and the fully insured market with its expensive mandates tied to the Affordable Care Act. 

According to the Connecticut Healthcare Advocate, 50 percent of plans in Connecticut are self-funded plans; others in the industry, however, have posited the percentage of self-funded plans at 74 percent. Because such a large cohort of payers are not contributing information to the APCD, it can heavily skew the data of who pays how much and where. 

The exception is the state of Connecticut itself; the state employee health plan, along with its Partnership Plan 2.0, which allows municipalities to participate in the state healthcare plan, is a self-funded plan, and contributes data to the APCD. 

There are several reasons self-funded plans are not included in the APCD; for one, the state cannot compel employers to turn over their claims data under a 2016 ruling by the United States Supreme Court. 

Liberty Mutual, which self-funds its employee insurance plan, challenged Vermont’s efforts to require them to submit their claims data to Vermont’s APCD, according to American Progress. In Gobeille v. Liberty Mutual, the Supreme Court determined that self-funded plans were covered under ERISA, which pre-empted state statutes. 

“Ideally, all-payer claims databases contain enough data to allow policymakers and private health care payers to consider quality, utilization, and cost trends across the entire health care system. Too often, these groups must use fragmented data sets that might be incomplete and not representative of the broader population,” wrote Maura Calsyn of American Progress. “Without the data from these [self-funded] plans, APCDs will be at best less comprehensive and less useful; at worst, they will be potentially misleading.”

Leaving out a large set of payers in the state means the APCD lacks the robustness necessary to truly understand the market; one industry leader claimed in an interview that the APCD is “significantly under-representative and not really indicative of what’s happening in the state,” and therefore does not contain enough information to understand the commercial market. 

Sajnani, however, says the vast majority of people in Connecticut are part of the database – 86 percent of covered lives and 40 percent of self-insured plans covered under ERISA. Those self-insured plans include the state of Connecticut, municipalities, and those employers who have opted to contribute to the database. In total, he says, the APCD represents claims from 64 percent of the population.

Could it be better? Perhaps. While Maine saw a decline of self-funded plans submitting data to their APCD in the wake of the Gobeille decision, a 2017 analysis found that 84 percent of self-funded plans continued to submit data; methodology notes from January of 2025 state that “some of the largest self-funded ERISA plans submit data to MHDO on a voluntary basis.” 

And while a lack of data could potentially skew analysis results, Sajnani says research shows little difference between the self-insured plans and those that contribute to the APCD.

“No APCD in the country contains 100 percent of their state’s self-insured claims data,” Sajnani wrote. “Research demonstrates no evidence that self-insured plans differ systematically from fully insured plans in terms of benefit design, price or claim denial rates. Regardless, the CT APCD is one of the most comprehensive health data sets in the country.”

Although the APCD collects Medicaid and Medicare claims data, they are not allowed to release that information per the agency’s agreement with the federal government. While OHS can use the Medicaid and Medicare numbers for their own purposes, that information is not included as part of an APCD data release; a separate request for that information must be made to the federal government. So an organization or company going through the trouble of getting APCD data will end up with a dataset that includes only 40 percent of self-funded plans, and no federal claims.

Employers can opt in to contributing data — OHS currently provides an opt-in form for employers to submit their data to the APCD on their website — but some in the business world bristle at the idea of submitting their claims to Connecticut’s APCD or to OHS, in general. 

In 2025, House Bill 7115 would have mandated that claim administrators for self-funded plans provide an opt-in form to employers to submit their data to OHS for their Health Care Cost Growth Benchmark Program. Failure to provide the form would result in a penalty for the payer.

Testimony submitted by former OHS Commissioner Dierdre Gifford indicated that in 2024, Anthem “unilaterally decided to withhold data on the self-insured lives from its Benchmark Data submission.”

“Anthem informed OHS of its belief that self-insured data is precluded from mandatory submission to state cost growth benchmark programs and that they concluded that they only need to report on fully-insured lives,” Gifford wrote. “Yet, Anthem’s decision to withhold self-insured data leaves the employers they represent with no voice. Further, if insurers withhold some or all of the aggregate data, the integrity of the Cost Growth Benchmark could be at risk.” 

While the bill only required a form to be provided, the Connecticut Business and Industry Association (CBIA) and the Connecticut Association of Health Plans opposed the bill.

CBIA Policy Associate Grace Brangwynne submitted written testimony to the Insurance and Real Estate Committee saying such a law would essentially establish a list of employers who either opt-in or opt-out, while Susan Halpin of the Association of Health Plans argued that it, “effectively places payers in the position of having to report on their clients’ decisions, despite employers having the legal right to make those choices.” 

Since the state can’t compel employers to turn over claims data, the possibility also exists that the state could work together with the business community by addressing some of their concerns and perhaps showing the potential benefit of a robust data set that could potentially help them lower their costs if it is used in the right way.

One change that might sweeten the pot would be releasing those employers from liability if the state system experiences a data leak, as has happened in the past. Currently, employers could still potentially be held liable for a breach at the state level. Secondly, employers want to be assured the state will comply with ERISA requirements because the claims data they collect is subject to ERISA regulations.

“Right out of the gate there wasn’t enough involvement of key users, limited stakeholder engagement in the creation of the thing,” Hogan said. “So, we have very, very few employers contributing to the plan. In other states, there’s tremendous contributions.”

“A Square Peg in a Round Hole”

The data contained in the APCD isn’t for everybody. 

While in statute the database is meant to provide employers, insurers, providers and consumers with information to make the best and most economical decisions regarding healthcare, the reality is that in order to access the information, one must go through a seven-step process, including appearing before a committee to make one’s case to receive the data, then shell out tens of thousands of dollars in fees. After all that, one must have the ability to make sense of the data.

The APCD Data Release Committee is comprised of “at least nine” members, including representatives from various state government departments, representatives from the medical and insurance industry, and consumer advocates. Their role is to “review and approve or deny data release applications,” and “assess the potential impact of the release of data on Connecticut residents, including for disparate impact by race, ethnicity, language, sex, gender identity, disability status or other factors.”

The APCD data is deidentified to comply with privacy laws, but applicants do have to state their case as to what the data will be used for and how it could benefit the community. Following an executive session, the committee will either approve or deny the application or grant only part of the request, and can put stipulations on how the data is used through a data use agreement. 

Applications and approvals for data releases since 2018 have ranged from UConn Health and Connecticut hospital systems to university researchers and Planned Parenthood, according to a review of meeting minutes.

While the initial data requests appeared to come hard and heavy during the initial 2018 and 2019 period, they appear to have slowed in the following years, according to a review of meeting minutes dating back to 2018. Three data release applications were approved in 2021; two releases in 2022; and one release in 2023, according to meeting minutes. In 2023, the committee only held four meetings, and the rest of the scheduled monthly meetings were cancelled. 

According to the latest minutes from 2024 and 2025, however, the number of data requests and approvals has ticked up, with seven Connecticut hospital systems obtaining the data for their mandated community benefit analyses, along with one university researcher.

The data doesn’t come free, however, and its price tag, combined with additional restrictions or requirements as to how the data can be used, may dissuade some companies from making use of it. 

The OHS provides a fee schedule for the data, showing that, at most, for a commercial entity to get all medical claims would cost $12,000. Sajnani states that this is one of the lowest fee rates in the country, noting the rates in Massachusetts and Rhode Island are upward of $40,000. OHS offers discounted rates for nonprofits and state agencies.

According to those interviewed by Inside Investigator, however, to get usable data requires more than just the medical claims; it would also require pharmacy claims and member eligibility, at least, which would put the fees at $20,000. When accounting for the need to refresh the data, it can add an additional $10,000. Furthermore, those companies or organizations must destroy the data after a set period and reapply if they want to get new numbers, repeating the process all over again.

The fees go to support the costs of maintaining the database and extracting the information requested by the applicant, but those fees have not met budgetary expectations, according to state open records. 

In 2023, the estimated budget revenue from APCD user fees was $894,207, but the actual revenue was zero; in 2024, OHS budgeted for $1.3 million in fees but collected only $685,719; in 2025, they budgeted for $1.4 million, but collected zero. So far, in 2026, there is no listed fee revenue despite a budget estimate of $1.4 million. Naturally, the lack of expected fee revenue eats into OHS’s budget.

Although costly, those interviewed by Inside Investigator indicated the committee often requires some form of research to be produced by the applicant, such as producing a research paper, which not only adds to their costs, but also must be made public. 

Essentially, they argue, such a requirement means they have to pay for the data, do all the work analyzing it, and then post it publicly, allowing their competitors to benefit from their work. Similarly, they claim the data is not permitted to be used for market research, which could lead to increased competition and potentially lower prices – something OHS officials officially say they want for the healthcare industry.

“CT APCD data is utilized for research and for other types of analyses, including cost driver analyses intended to inform strategies to lower healthcare costs and improve population health,” Sujnani wrote. “Connecticut’s hospitals use APCD data to inform community health needs assessments, community health implementation plans and community benefit reporting.”

The state’s hospitals do use the APCD to fulfill their reporting requirements to the state – it’s why there were so many data requests by hospital systems in 2025 – but it wasn’t so easy getting access to the level of data they needed to fulfill those reporting requirements. The CHA had to push for legislation in 2022 to grant them greater access to APCD data to conduct their Community Health Needs Assessment. 

The hospitals needed to get workable data that included a limited dataset that included zip codes instead of a completely deidentified dataset so hospitals could evaluate health impacts and disparities by community, while still meeting the provisions of federal privacy laws. Essentially, it is difficult to determine the needs of a community if you don’t have zip codes.

“These aren’t research projects so it’s like a square peg in a round hole,” Schaefer said of the Community Health Needs Assessment. “You don’t have to take any special measures if you’re giving fully deidentified data and that’s easier to administer and that makes nobody nervous about confidentiality, privacy and security, which we care a great deal about. It also means you’re substantially undermining the ability to use this data to generate insights to improve care delivery or access. So, we had to have special legislation passed so we could get this more fully formed limited data set.”

While deidentifying the data ensures privacy and security, Schaefer says the APCD Committee has defaulted to the most conservative metric, which ultimately detracts from the APCD’s usefulness. He believes OHS could offer limited datasets while still complying with HIPAA and not risk personal information.

“The bottom line is, we had to develop a statutory workaround because the APCD, as constructed, would not enable the work of community health,” Schaefer said. “We’re just one instance of a use case that is not an option (for others) in Connecticut because they’re so careful about these safeguards that they, frankly, are limiting the ability for the APCD to justify its expense.”

Just two years after the legislation allowing Connecticut hospitals greater access to APCD data for their reporting requirements, OHS tried to roll back the statute. Senate Bill 242 would have reverted to the original APCD deidentified data for hospitals and would not excuse hospitals from not meeting their community benefit reporting requirements if they did not receive the data. OHS Commissioner Dierdre Gifford argued it was necessary to safeguard privacy. 

The CHA, however, opposed the legislation and, in their written testimony, described the multi-year negotiations between OHS and CHA to create “a mechanism” by which the hospitals could receive a limited data set from the APCD, only to have OHS try to roll back that change the first year the hospitals had access to it.

“The mechanism is overly complicated but arguably meets the legislative mandate on OHS—a mandate to which OHS agreed and that OHS accepted after the 2021 discussions with CHA and legislative leadership,” the CHA offered in written testimony. “Despite the fact that this year is the first time hospitals have the opportunity to access these data, let alone design and perform the complex analytics necessary to make the data useful in satisfying the increased reporting obligations, OHS is seeking to eliminate its obligations to provide access to the data as a condition of the state reporting.”

While the bill passed out of committee, it was never taken up by the General Assembly. 

Provided one agrees to the limitations of the data user authorization agreements, an applicant must then figure out what to do with the data once they have it, something that can prove quite daunting. The CHA, even with a better dataset that is typically provided to applicants, described the mechanism as “overly complicated,” it doesn’t appear the state has made it any easier since the APCD’s inception. 

“It’s almost like it got put on a shelf for years,” Hogan said. 

Hogan points out that part of the enabling legislation includes “assessing and reporting” on the data, and the ability to contract with an outside contractor to analyze the data, but claims that neither is being done. Instead, the limited data source is used to inform various initiatives, and approved applicants receive a data dump that they must then wade through to try to draw any conclusions from.

He points to Massachusetts and the creation of the Mass Health Policy Commission (MHPC), which uses the data from its APCD to discover gaps in coverage and costs. For instance, the MHPC used data from their APCD to find that out-of-pocket costs for those in the commercial insurance market had increased 29 percent between 2019 and 2023, and was able to determine what services those expenses went toward, and the distribution of deductible, copay, and coinsurance spending.

“The APCD was designed to get as much data as possible from sources and create insights which can be used for public policy and, in the commercial markets, for purchasers of healthcare to figure out what things cost, where they would get good quality and how they should design their own health plans,” Hogan said. “Simply stated, we never did that.”

Massachusetts, with double the population of Connecticut and a bigger budget, essentially does much of their APCD work in-house, hiring the kinds of analysts who can make sense of the information and put it out to the public in understandable formats. Connecticut could do that, but it would mean hiring a lot of expensive employees.

While the MHPC’s roughly $12 million budget is similar to OHS, the independent state agency known as the Center for Health Information and Analysis (CHIA) that actually houses the APCD has a budget of roughly $33 million. Essentially, CHIA supplies the data and analytics and then the MHPC uses that information to conduct more market-driven research and make policy recommendations.

And while Connecticut could likely not muster a comparable budget for OHS, Schaefer believes the APCD data could be made more user friendly to include training for new users, ongoing technical assistance, and providing the logic and algorithms necessary to create certain outcomes and providing control tables so users can test the validity of their analyses.

“Massachusetts has very well-developed data modeling capabilities that rely a great deal on their APCD,” Schaefer said. “I think we would do well to look at Massachusetts and other states as examples.”

So, What is the Data Used For?

So, how does Connecticut use the data in the APCD? It’s a question that many Inside Investigator spoke with did not have a good answer for, but the data appears to largely be used by OHS for their various analyses on healthcare costs – some of which are disputed by those in the insurance and medical industries – and for consumer dashboards meant to allow users to compare costs for services at multiple in-state providers.

“In fiscal year 2025, OHS performed 20 data analyses utilizing APCD data to support [Certificate of Need] decision-making, Healthcare Benchmark Initiative implementation, healthcare price transparency and containment policy, and legislative activities,” Sajnani wrote.

OHS’s healthcare benchmark initiative, whereby a panel of experts examines insurance claims data and reaches projections about how much healthcare costs should increase on average over the next five years, establishes goals to limit the growth of healthcare costs. If those benchmarks are exceeded, insurance companies and providers essentially must come to the capitol to explain themselves. 

It is a practice Connecticut borrowed from Massachusetts and first instituted in Connecticut under Gov. Ned Lamont through a January 2020 executive order. It was later codified in legislation, but thus far has had little effect in reducing healthcare costs. 

Instead, actual costs have blown through the benchmarks; the 2023 cost growth benchmark was 2.9 percent, but the actual cost increase was 7.9 percent. OHS’s own contractor wrote that the effort to contain costs did not appear to be working. 

When OHS came out with new benchmarks for the years 2025 through 2030 that were even lower than the previous benchmarks, CHA balked, and criticized the underlying methodology used for the benchmarks; “Hospitals and others who submitted testimony have repeatedly raised concerns about the state’s flawed benchmark methodology, deficiencies in OHS’s data reporting process, and premature implementation of enforcement mechanisms contained in the recommendations for 2026-2030.”

While Connecticut’s benchmarks have been wildly off the mark, Massachusetts has been much closer in their estimates. According to the Massachusetts Health Policy Commission’s 2024 report, the state’s cost growth benchmark of 3.1 percent between 2017 and 2022 was exceeded only by .9 percent, and the state then readjusted its benchmark to 3.6 percent.

Connecticut, on the other hand, despite exceeding the benchmarks over the previous three years, set the benchmarks from 2025 to 2030 even lower at 2.8 percent every year.

According to Sanjani, the APCD also provides information for OHS when considering Certificate of Need (CON) applications whereby medical providers must seek permission from the state to expand or reduce services.

“APCD data informs the CON decision-making process, providing price analyses to determine if proposed services offer prices within market range,” Sajnani wrote. “This type of analysis helps the CON program limit unaffordable price increases and avoid unnecessary duplication of services, which can lead to excess capacity and higher costs.”

Lastly, and likely most relevant to consumers, the APCD supplies the information for various dashboards created by OHS whereby individuals can compare the costs of various medical procedures across different providers and are “designed to be accessible and user-friendly,” and “provide insight into the cost, utilization and quality of healthcare in Connecticut.”

These dashboards include the APCD snapshot, which “provides an overview of the data available in the Connecticut APCD,” the Healthcare Cost Estimator, the newly-released Behavioral Health Dashboard, the CT Affordability Index, and in the near future a Health Equity Dashboard that will provide “healthcare outcomes by towns, subpopulations and socioeconomic characteristics to gauge the risk of vulnerability to the poor outcomes.”

The dashboards offer specifics that are likely not available to applicants seeking to obtain APCD data, including statistics related to age of claimants, location, gender, race – practically everything an average consumer or researcher or journalist might want to know, but it is not the hard data that healthcare analysts would need to answer their questions, and both Hogan and Schaefer say the dashboards are inaccurate.

“The dashboards are not helpful,” Hogan said. “A dashboard is only showing you insights into the data that is in a database. The database doesn’t have credible information, so you can use a dashboard all day long, but it doesn’t tell you anything because you don’t have enough credible data on cost and quality and other types of things to give you insights that are usable.”

Mark Schaefer says OHS reached out to the CHA to solicit feedback on their cost estimator tool, and the results were not great.

“We did some testing to see how it would characterize professional fees and hospital fees, and the estimations we believe were so profoundly outside the bounds of reasonable that we think it could be misleading or worse,” Schaefer said. “If you’re a consumer, how are they going to know in that estimation tool what your deductible is, what your cost sharing is associated with any particular visit – which is plan specific, product specific – and what fee schedule would be applicable?”

Hogan points to CompareMaine.org, which is also a dashboard but allows for much more specific data that can “breakout” one’s exact circumstance, including what insurance company a consumer uses allowing for more competition between providers that could help lower costs.

“It creates healthy competition in the state in a transparent fashion; people know, a health system knows their cost and quality is going to be included in this thing and they’re concerned about it,” Hogan said. “In Connecticut, we don’t have that. All we have is opacity around cost and quality.”

According to CompareMaine.org, their dashboard does not include Medicaid or Medicare because they are publicly funded and could therefore “distort” the data. Instead, Maine’s cost estimator relies exclusively on commercial payer data which they review with the commercial payers to ensure accuracy. This, they say, allows them to estimate the average cost of a procedure at a given location within 10 percent.

Sajnani says, however, the dashboards utilizing Connecticut’s APCD are an accurate resource for consumers, but does caution – as does Schaefer – that the most accurate cost estimate is going to come from one’s insurance provider. 

“The dashboards accurately reflect healthcare costs as submitted by insurers, Medicaid and Medicare; that is, amount insurers paid for the claim (paid claims) plus member out of pocket costs (deductible, copay and coinsurance),” Sajnani wrote. “Each patient’s out of pocket cost depends on the type of insurance plan. The amounts in the dashboards are the average across plans.” 

“Consumers should always check with their insurer to correctly estimate their out-of-pocket costs, details about specific deductibles, network restrictions and other plan details before accessing care,” he continued.

“It’s an Amazing Resource We’ve Set Up”

The APCD is, above all else, a resource. How that resource is used and by whom determines whether it is an effective resource, and there appear to be wildly different perceptions between OHS and those in the medical and insurance industries as to whether it is being used effectively; like all things, there is always room for improvement.

“It’s an amazing resource that we’ve set up,” Schaefer said, “but there are barriers to access and there are things we believe the state could do to make it easier and more efficient for users to access the data.”

“Compared to other states, Connecticut has one of the more robust and accessible APCDs. Some states lack Medicare data or do not offer public-facing dashboards; Connecticut does both,” Sajnani said. “Connecticut’s model has been recognized nationally, including awards for innovation, and continues to serve as an example of how an APCD can empower patients, purchasers, and inform healthcare policy.”

Whether Connecticut’s APCD is best in the country or the worst or just somewhere in between, more data from self-insured plans could help alleviate some of the concerns about the APCD’s quality, alleviating some of the data use requirements, and creating more user-friendliness for those who access the hard data could lead to better utilization. For one, the state could offer liability assurances for businesses; second, OHS could offer more tools to help analysts navigate a data set that contains, as Sumit Sajnani indicated, 2.2 billion claims.

Writing in 2018, Maura Calsyn of American Progress, wrote that one of the short-term solutions to the Gobeille decision was to encourage employers with self-funded plans through making it easier to submit data, and easier to access data.

“One obstacle to data submission is administrative burden; therefore, uniform data submission standards across states with APCDs could encourage participation,” Calsyn wrote. “Second, states or the federal government could also help self-funded plans and their third-party administrators offset the costs of submitting data or offer them a reduced fee when they try to access data from an APCD.”

Used the right way, the APCD can provide valuable information. For example, the data could determine that there is a high number of people with diabetes in a particular area but are visiting endocrinologists in other areas thus requiring a lot of travel. A medical provider could see that information and possibly establish a practice closer to that patient population.

However, that could involve using limited data, rather than completely deidentified data, and such uses could constitute market strategy rather than “pure research.” It is something that Schaefer believes is “a limitation that bears review.”

“Should we revisit how we set those guardrails early on?” Schaefer said. “What you needed to provide assurances at the launch may be different than five years out. It may be the time to reassess whether we’re getting a value relative to the cost that we can and should. I believe there should be an examination of the full range of uses that could be supported, and which do we want to support, and which don’t we want to support, and for what reasons.”

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