Skip to main content

Qualified Health Plan Enrollee Experience Survey

Privacy Impact Assessment (PIA) published by CMS as an Operating Division of the U.S. Department of Health and Human Services

Date signed: 1/25/2023

PIA Information for Qualified Health Plan Enrollee Experience Survey
PIA QuestionsPIA Answers
OPDIV:CMS
PIA Unique Identifier:P-8271749-032873
Name:Qualified Health Plan Enrollee Experience Survey
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?Yes
Identify the operator:Contractor
Is this a new or existing system?New
Does the system have Security Authorization (SA)?Yes
Date of Security Authorization2/23/2023
Describe the purpose of the system

The Qualified Health Plan (QHP) Enrollee Experience Survey (EES) exists in response to Section 1311(c)(4) of the Patient Protection and Affordable Care Act (PPACA). The Act requires the United States Department of Health and Human Services Secretary to develop an enrollee satisfaction survey system that assesses consumer experience with QHPs offered through a Health Insurance Exchange. It also requires public display of information by each Marketplace to allow individuals to assess enrollee experience among comparable plans. 

The goals of the survey are to provide comparable and useful information to consumers about the quality of health care services and enrollee experience with QHPs offered through the Exchanges, facilitate oversight of QHP issuer compliance with quality reporting standards, and provide actionable information that QHP issuers can use to improve quality and performance. This webpage provides Vendor Applicants, Conditionally Approved Vendors, Approved Vendors, and Public Use File Users with a multipurpose interface to support survey data submissions.

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)

The type of information to be collected and maintained includes:

Contact Us Page - Name, e-mail address

Vendor - vendor name, address, point of contact name, point of contact e-mail address, point of contact phone number, and username 

System Administrators - User Account Name, Device Identifier (IP number),  and events logged.

The QHP website/application utilizes and inherits CMS' Identity Management (IDM) system for identity management and authentication for the protection of PII data. IDM is leveraged by CMS business applications used across CMS. Users of all business applications that integrate with IDM can use a single set of user credentials to access any integrated application. The CMS IDM incorporates Multi-factor Authentication (MFA) into user authentication. MFA is an authentication method that requires the user to provide two or more verification factors to gain access to the QHP website/application. This includes the user providing account username, password and a six-digest code delivered by text message to a mobile device. 

Provide an overview of the system and describe the information it will collect, maintain (store), or share, either permanently or temporarily.

Section 1311(c) of the Patient Protection and Affordable Care Act (PPACA) directs the Secretary of the Department of Health & Human Services (HHS) to establish an enrollee satisfaction survey to assess enrollee satisfaction with each QHP offered through the Health Insurance Exchanges (Exchanges) (also known to consumers as Health Insurance Marketplaces) and Small Business Health Options Program (SHOP) with more than 500 enrollees in the prior year. Additionally, Section 1311(c) of the PPACA directs the Secretary to develop a quality rating for each QHP offered through an Exchange. Based on this authority, CMS issued a regulation in May 2014 to establish standards and requirements related to QHP issuer data collection and public reporting of quality rating information in every Exchange.

As a condition of certification and participation in the Exchanges, CMS requires that QHP issuers submit QHP Enrollee Survey response data and Quality Rating System (QRS) clinical measure data for their respective QHPs offered through an Exchange in accordance with CMS guidelines. Exchanges are also required to display QHP quality rating information on their respective websites. 

The goals of the QRS and the QHP Enrollee Survey are to:

  • Provide comparable and useful information to consumers about the quality of health care services and enrollee experience with QHPs offered through the Exchanges
  • Facilitate oversight of QHP issuer compliance with quality reporting standards set forth in the PPACA and implementing regulations, and
  • Provide actionable information that QHP issuers can use to improve quality and performance.
  • CMS aligned federal quality reporting standards for QHP issuers with other federal and state quality reporting program standards, as well as with the Meaningful Measures Initiative, aimed at identifying the highest priority areas for quality measurement and quality improvement in order to assess core quality of care issues that are most vital to advancing the agency’s work to improve patient outcomes. States have the flexibility to build upon the federal quality reporting standards for QHP issuers by setting additional standards that reflect state priorities and population-based needs. 

QHP issuers that offered coverage through an Exchange in the prior year are required to submit third-party validated QRS clinical measure data and QHP Enrollee Survey response data to CMS as a condition of certification.

The QHP Enrollee Survey is the only survey used to measure the experience of the enrollee population in the Exchanges. While the survey utilizes questions from the Consumer Assessment of Healthcare Providers and Systems (CAHPS®), modifications and new questions were designed specifically for use with the enrollee population. 

Consistent with other CAHPS instruments, the QHP Enrollee Survey uses a six-month reference period. The survey assesses enrollee experience with a QHP offered through an Exchange on the topics presented in Exhibit 6. Measures derived from a subset of survey questions are included in the QRS measure set and accompanying ratings. For a crosswalk that maps each QHP Enrollee Survey item question source and relevant QRS measure.
QHP Enrollee Survey Topics

•    Access to Care*
•    Access to Information*
•    Care Coordination*
•    Cultural Competence
•    Doctor Communication
•    Enrollee Experience with Cost
•    Plan Administration*
•    Prevention*
* Survey questions within this topic are included in QRS measure set.

QHP EES web application provides a centralized web site that will allow the different user types the ability to understand what the QHP EES program is, details on how prospective survey vendors can apply to become an approved vendor and approved vendors the ability to login and submit the survey results they have collected.  It will also include functionality that will allow the QHP EES team to manage submissions and manage the meta data of the web application.

The QHP ESS web application has a user centric design and is architected using serverless technologies in Amazon Web Services (AWS).

The Vendor and Issuer User Account names are used to retrieve their respective PII maintained within the QHP website.

The information collected and maintained for System Administrators include their User Account Name, Device Identifier (IP number), actions and events conducted in support of QHP. 

The QHP website/application utilizes and inherits CMS' Identity Management (IDM) system for identity management and authentication for the protection of PII data. IDM is leveraged by CMS business applications used across CMS. Users of all business applications that integrate with IDM can use a single set of user credentials to access any integrated application.  The CMS IDM incorporates Multi-factor Authentication (MFA) into user authentication.  MFA is an authentication method that requires the user to provide two or more verification factors to gain access to the QHP website/application.   This includes the user providing account username, password and a six-digest code delivered by text message to a mobile device. 

 

 

Does the system collect, maintain, use or share PII?Yes
Indicate the type of PII that the system will collect or maintain.
  • Name
  • E-Mail Address
  • Phone Numbers
  • Mailing Address
  • Device Identifiers
  • Other - User account name
Indicate the categories of individuals about whom PII is collected, maintained or shared.Vendors/Suppliers/Contractors
How many individuals' PII in the system?100-499
For what primary purpose is the PII used?The PII primary purpose is to authenticate Vendors accessing the website.   
Describe the secondary uses for which the PII will be used (e.g. testing, training or research)The secondary use of PII is to identify Vendors who use the system, and to be able to search Vendor records.
Describe the function of the SSN.Not Applicable.  The SSN is not collected or used.
Cite the legal authority to use the SSN.Not applicable.  The SSN is not collected or used.
Identify legal authorities​ governing information use and disclosure specific to the system and program.Authority for maintenance, collection and disclosure of information is given under sections 2719, 2723 and 2761 of the Public Health Service Act and section 1321(c) of the Affordable Care Act. 
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.09-70-0560 Health Insurance Exchanges (HIX) Program
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
  • Other - Not applicable. PII is not from a Government source.
Identify the sources of PII in the system: Non-Government Sources
  • Private Sector
  • Other - Vendors
Identify the OMB information collection approval number and expiration dateOMB 039-1187, expires 06/30/2025
Is the PII shared with other organizations?Yes
Identify with whom the PII is shared or disclosed and for what purpose.
  • Private Sector: QHP Survey Vendors will collect, and thus have immediate access to, PII for the QHP issuers. The QHP Issuers will have access to the PII after data collection for quality improvement purposes. The intent of the program is to collect quality of care data from beneficiaries to focus issuers’ quality improvement programs. The PII will support those efforts.
Describe any agreements in place that authorizes the information sharing or disclosure (e.g. Computer Matching Agreement, Memorandum of Understanding (MOU), or Information Sharing Agreement (ISA)).Not applicable.  There are no agreements in place.
Describe the procedures for accounting for disclosuresQHP ESS does not collect PII from the general public.  Vendors accessing the QHP ESS website are presented with a "warning banner" when logging into the system providing consent once the banner is acknowledged by continuing to website.
Describe the process in place to notify individuals that their personal information will be collected. If no prior notice is given, explain the reason.QHP ESS does not collect PII from the general public.  
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.QHP ESS does not collect PII from the general public.  Vendors cannot opt-out of providing their names, address, e-mail address and usernames as this data is required to create user their user accounts to access the system.
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.QHP ESS does not collect PII from the general public.  Vendors would be notified by e-mail of any major changes or data use occurring to the system.
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.QHP ESS does not collect PII from the general public.  Vendors who believe their PII was obtained, used or disclosed inappropriately or incorrect can use the e-mail address on website home page to contact QHP ESS.
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.Processes for data integrity, availability, and accuracy are both automated and performed manually by QHP ESS database administrators.  Periodic reviews of information collected in the system, including vendor PII, are performed at regular intervals.  Data accuracy and relevancy are reviewed and validated by Data Quality Analyst on an ongoing basis as part of the work performed by QHP ESS.   
Identify who will have access to the PII in the system and the reason why they require access.
  • Users: Users will only have access to their specific PII
  • Administrators: Administrators require access to Vendor PII to maintain and control access to the website.
  • Contractors: Contractors are direct and fulfill the roles of administrator and require access to PII to fulfill their contract responsibilities.
Describe the procedures in place to determine which system users (administrators, developers, contractors, etc.) may access PII.The administrative procedures in place to determine which system users may access PII are authentication and authorization rules that give specific permissions to each role.  The role-based access is based on the principle of "least privilege" where users are given 'need to know' and 'need to access' permissions. All user roles for the system are documented in the QHP ESS System Security Plan.
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.The system controls in place for access to PII include role-based access permissions, and limits on the PII that is displayed so that only the minimum amount of PII is visible to users. Users are assigned different roles corresponding to different levels of access to data as well as the ability to perform specific actions (e.g., read, update, delete).
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.All QHP ESS personnel undergo corporate and project-specific training at time of hire and annually thereafter. This training includes security and privacy awareness training with content specific to the protection of PII. QHP ESS personnel must also complete project-specific training before starting work on the project or receiving access to additional roles within QHP ESS. In addition, all personnel must sign agreements to acknowledge awareness of their responsibilities to protect this information.
Describe training system users receive (above and beyond general security and privacy awareness training)QHP ESS personnel must complete additional project-specific training before starting work on the project. Training courses provided by the agency or contractor include content about correct use of QHP ESS as well as how to
conduct case analysis and other project activities performed using the system.
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.

PII within QHP ESS is maintained as long as needed to support providing information to consumers about the quality of health care services and enrollee experience the Health Insurance Exchanges.

QHP operates in accordance with National Archives and Records Administration (NARA) General Records Schedule DAA-GRS-2013-0002.

As required by regulation, HHS must ask NARA for a variance when not following the retention periods outlined by these schedules (36 CFR 1228.40(c)). 

Describe, briefly but with specificity, how the PII will be secured in the system using administrative, technical, and physical controls.

PII is secured in the system using administrative, technical, and physical controls, in accordance with policies and regulations detailed in the CMS Information Security Acceptable Risk Safeguards-Minimum Security
Requirements (ARS). 

Administrative controls include role-based permissions to access Center for Consumer Information and Oversight (CCIIO) Customer Relations Management System (CCRMS) web pages and applications, request and authentication through the CMS Enterprise Identity Management (EIDM) system, periodic review of users and deletion of non-active accounts, security and network policies and procedures as well as security and privacy training regarding securing PII.

Technical controls include role-based access, inactivity timeout, multi-factor authentication. data encrypted at rest, data encrypted while being transmitted electronically, network firewall, anti-virus/malware prevention, intrusion detection/prevention technologies, centralized event log monitoring and event alerts. CCRMS, being hosted in the cloud inherit physical security controls from the Federal Risk and Authorization Management Program (FedRAMP) Salesforce Cloud and Amazon Web
Services Cloud.

Identify the publicly-available URL:

https://qhpsurvey.cms.gov 

This URL and website will not be available until 3/1/2023 after the ATO has been received.

 

Does the website have a posted privacy notice?Yes
Is the privacy policy available in a machine-readable format?Yes
Does the website use web measurement and customization technology?No
Does the website have any information or pages directed at children under the age of thirteen?No
Does the website contain links to non-federal government website external to HHS?No