Automated Plan Payment System
Date signed: 11/5/2024
| PIA Questions | PIA Answers |
|---|---|
OPDIV: | CMS |
PIA Unique Identifier: | P-9220941-496715 |
Name: | Automated Plan Payment System |
The subject of this PIA is which of the following? | Major Application |
Identify the Enterprise Performance Lifecycle Phase of the system. | Operate |
Is this a FISMA-Reportable system? | Yes |
Does the system include a Website or online application available to and for the use of the general public? | No |
Identify the operator: | Contractor |
Is this a new or existing system? | Existing |
Does the system have Security Authorization (SA)? | Yes |
Date of Security Authorization | 9/11/2024 |
Indicate the following reason(s) for updating this PIA. Choose from the following options. | PIA Validation (PIA Refresh/Annual Review) |
Describe in further detail any changes to the system that have occurred since the last PIA. | APPS physical location migrated to AWS. ARS controls updated to 5.1. |
Describe the purpose of the system | Automated Plan Payment System (APPS) computes interim and monthly payments to the plans that provide medical services and prescription drugs to Medicare beneficiaries. APPS tracks and collects User Fees; Coverage Gap Discount invoices and demonstration quality withhold payments. APPS processes files for the annual Part D Reconciliations and re-openings. Monthly/interim payment files are created for the Healthcare Integrated General Ledger Accounting System (HIGLAS) so that plans can be paid. According to E-Government Act of 2002, the OMB and HHS policy, HIGLAS maintains its own PIA information. APPS also creates payment reports for the plans. |
Describe the type of information the system will collect, maintain (store), or share. (Subsequent questions will identify if this information is PII and ask about the specific data elements) | APPS collects and stores banking information (Bank name/address, Employer identification number, account number, routing number) from plans, Part C/D payment data summarized at the contract level from the Medicare advantage and prescription drug system (MARx) and plan type, contract number and payment status from the health plan management system (HPMS). This data is used to produce the monthly payment file for HIGLAS to send to Treasury. According to E-Government Act of 2002, the OMB and HHS policy, MARx and HPMS maintains its own PIA information. APPS users must log into APPs through Access Manager with a user ID and password. Access Manager maintains the CMS user email address, name and phone numbers. |
Provide an overview of the system and describe the information it will collect, maintain (store), or share, either permanently or temporarily. | The APPS application provides the Centers for Medicare & Medicaid Services (CMS) with a mechanism for consolidating capitated payments from the Medicare Advantage Prescription Drug (MARx) system and ensuring that the Managed Care organizations (MCO) are paid every month. The application stores input data from several systems and provides interfaces through which CMS personnel review, update and refine the final payments due to the MCOs. APPS stores payment information at the plan level (not at the beneficiary level) to process monthly plan payments and to create plan reports and the file to HIGLAS. There is no beneficiary PII collected, stored or processed by APPS. APPS collects/stores the following information. APPS receives its financial data from MARx on a monthly basis. The MARx system sends one file of all of the prospective payments due to the plans and another file containing all of the retroactive adjustments that took place during the payment period. Periodically the Payment Reconciliation System (PRS) supplies Part D drug payment data at the contract level to APPS that adjusts previous Part D payments already made to the MCOs. The HPMS data are comprised of information about the MCO. It contains both current and historical data including, among other things, the payment status, plan name, plan type and other pertinent information about the MCO. These are critical for the monthly payment processing of APPS. APPS users (about 39 internal users) are exclusively CMS personnel located at CMS headquarters. All access to the application is behind the firewall and through access manager. No user has the capability to access the application from the internet, however, a user ID and password are collected in order to gain system access. The APPS Application Administrator regularly use PII to retrieve system records including using the user ID, last name, and/or first name of CMS employees and contractors, who were/are users of Automated Plan Payment System. The data is stored permanently in the APPS databases and is shared with plans via monthly payment reports and with HIGLAS via the monthly payment file. The only purpose for this data is to compute accurate payments for active plans. |
Does the system collect, maintain, use or share PII? | Yes |
Indicate the type of PII that the system will collect or maintain. |
|
Indicate the categories of individuals about whom PII is collected, maintained or shared. | Employees |
How many individuals' PII in the system? | <100 |
For what primary purpose is the PII used? | To allow user access to the application and account maintenance. The user role assigned with the user ID defines the data that can be accessed. |
Describe the secondary uses for which the PII will be used (e.g. testing, training or research) | There are no secondary uses. |
Describe the function of the SSN. | N/A |
Cite the legal authority to use the SSN. | N/A |
Identify legal authorities governing information use and disclosure specific to the system and program. | 42 Code of Federal Regulations 423.401(Medicare Prescription Drug Improvement and Modernization Act); 5 U.S.C 301, Departmental Regulations |
Are records on the system retrieved by one or more PII data elements? | Yes |
Identify the number and title of the Privacy Act System of Records (SORN) that is being used to cover the system or identify if a SORN is being developed. | 09-70-0538 Individuals Authorized Access to Centers for Medicare and Medicaid Services Computer Services (IACS) |
Identify the sources of PII in the system: Directly from an individual about whom the information pertains | Online |
Identify the sources of PII in the system: Government Sources | Within the OPDIV |
Identify the sources of PII in the system: Non-Government Sources | Other - Members of the APPS Maintenance direct contractor team. |
Identify the OMB information collection approval number and expiration date | N/A - the only PII is the information needed to allow authorized users to access the application. |
Is the PII shared with other organizations? | No |
Describe the process in place to notify individuals that their personal information will be collected. If no prior notice is given, explain the reason. | Before users are allowed to logon to APPS, they are prompted to select either "I accept" or "Decline" the terms and conditions for access to the application. The "I Accept" button notifies the user that their PII (CMS user ID/password, work email and work telephone number) is being collected and used.
|
Is the submission of the PII by individuals voluntary or mandatory? | Voluntary |
Describe the method for individuals to opt-out of the collection or use of their PII. If there is no option to object to the information collection, provide a reason. | If users need to access APPS, there is no "opt-out" method. The users agree to the use of their information by selecting the "I Accept" button prior to each time that they log on. If they select "Decline", they cannot log on to APPS. |
Describe the process to notify and obtain consent from the individuals whose PII is in the system when major changes occur to the system (e.g., disclosure and/or data uses have changes since the notice at the time of original collection). Alternatively, describe why they cannot be notified or have their consent obtained. | It is highly unlikely that the use of the user access information would change. It is only used during the login process. If this usage changed, the process would be to notify the users via their CMS e-mail addresses. Follow-ups using the CMS phone numbers would occur if needed. |
Describe the process in place to resolve an individual's concerns when they believe their PII has been inappropriately obtained, used, or disclosed, or that the PII is inaccurate. If no process exists, explain why not. | Since user credentials are collected in the Enterprise User Administration (EUA) system before being stored in APPS the EUA team would be responsible for breach reporting and resolution. The process is for the information system security officer (ISSO) of APPS to report the incident to EUA and they would direct the remedial action. According to E-Government Act of 2002, the OMB and HHS policy, EUA maintains its own PIA information.
|
Describe the process in place for periodic reviews of PII contained in the system to ensure the data's integrity, availability, accuracy and relevancy. If no processes are in place, explain why not. | In order to maintain the integrity, availability, accuracy, and relevancy of the PII stored within the database, the System Administrator, semi-annually, performs a crosswalk between the EUA listing of individuals with the user job code and APPS' listing of active users. Any anomalies (i.e. name change, or mismatch) is addressed and resolved by contacting the user, and modifying their user data, or by removing their access to APPS, if no longer required under their current job description. Under this process, outdated, unnecessary, irrelevant, and inaccurate PII is identified and deleted from APPS. The PII is available as needed and is sufficient (minimum required) for the purposes needed. The PII fields are locked and cannot be changed; The process to ensure that individuals who provide or modify PII cannot repudiate that action is done within the source (EUA) system. The process to ensure PII is available when needed is by having nightly updates run between the EUA systems and APPS; the process to ensure that PII is sufficiently accurate for the purposes needed is ensured when the nightly updates are sync. Users can at any time, request that their PII (access) be deleted, by contacting their CMS Access Administrator (CAA), who in turn, would take the corresponding action via EUA.
|
Identify who will have access to the PII in the system and the reason why they require access. |
|
Describe the procedures in place to determine which system users (administrators, developers, contractors, etc.) may access PII. | In the APPs, the only PII is user access information. APPS uses role-based access and separation of duties policies to assign roles. Based on this, the only application role assigned to maintain user access records is the application administrator; of which there are 2. No other application roles can view/update user credential information. |
Describe the methods in place to allow those with access to PII to only access the minimum amount of information necessary to perform their job. | There are about 39 CMS users of APPS but the function to view and update user access information is limited to 2 individuals. No other application roles can access this PII data. Three quarters of the users can only request plan payment reports. The other quarter have various update capabilities depending on their job duties and assigned roles. These activities do not involve PII. |
Identifying training and awareness provided to personnel (system owners, managers, operators, contractors and/or program managers) using the system to make them aware of their responsibilities for protecting the information being collected and maintained. | CMS provides security awareness and privacy training that all CMS users are required to complete at least annually. The application administrators who are the only individuals/roles that allow access to the PII are information system security officers (ISSOs) who are required to attend additional role-based access training classes throughout the year. |
Describe training system users receive (above and beyond general security and privacy awareness training) | The APPS application administrators attend role-based, privacy, security safeguards and other related training offered periodically during the year by the security office and office of technology solutions. |
Do contracts include Federal Acquisition Regulation and other appropriate clauses ensuring adherence to privacy provisions and practices? | Yes |
Describe the process and guidelines in place with regard to the retention and destruction of PII. Cite specific records retention schedules. | If an APPS user needs to be removed; the APPS job codes are deleted from their user profile in EUA. When this occurs, an e-mail is created. The application administrators inactivate the User's PII (CMS user's ID, name, work email address and work telephone number) in APPS. This information is retained as inactive indefinitely by the application. Auditors request this information at the annual security controls assessment and the chief financial officer (CFO) audit. This information is only retained for the purpose of an application audit trail and is destroyed when no longer needed or when business ceases per DAA-GRS-2013-0006-0003. |
Describe, briefly but with specificity, how the PII will be secured in the system using administrative, technical, and physical controls. | Physical controls such as the security of the physical plant, which include such items as providing long term power supply, emergency lighting, and fire protection are under the purview of AWS. This includes physical access, which no APPS user has. Technical controls are in place and govern by AWS. Equipment ordering/testing and has responsibility for the EUA system (management of user accounts), which defines the privileges for each user of the information system(s); Information Security and Privacy Group coordinates compliance with security controls and the artifacts that document compliance by each application; and General Support System manages, among others, telecommunications, remote access, and transmission confidentiality. As the physical and technological aspects Administrative control: APPS enforces role-based security; users can only access data allowed for their role. All application roles are reviewed monthly by an ISSO for appropriate access. Access, or a change in Roles, can occur based on these reviews. |