There are large gaps in data on health insurance products nationwide. Collecting information on health insurance has not historically been viewed as a “health system” function. It has been handled through insurance functions, largely at the state level, and there are many gaps associated with the federal ERISA preemption and with the rapidly evolving managed care marketplace, which has challenged regulators. Working with states, the NAIC has focused closely on the issues of interest here. Federal activity is focused in DOL, which has oversight for ERISA. Yet, the health policy and research community is also interested in this area, since it provides an enumeration set that is important for other kinds of data collection activities and basic structural information that currently is absent.
- Suggestion #1a. HHS should meet with NAIC staff and appropriate federal policy makers to discuss the status of ongoing activity and perceived strengths, limits, and needs.
- Suggestion #1b. An appropriate HHS role could be to help NAIC and DOL understand the needs of the health policy and research community for these kinds of data and what these needs imply for additional activity or priorities that may differ from the regulatory context. To support this role, HHS could convene an ad-hoc working session with staff from provider, health plan, purchaser, and the regulatory community to identify key concerns and issues.
- Suggestion #1c. Follow up this activity with the development of a discussion paper, which reviews the status of current activity in the regulatory arena and the key needs and issues from the perspective of the health policy and research community. Involve regulators in this process and use the document to encourage attention to important health industry, policy, and research needs as systems evolve.