Training Quality Content

TQC develops and stores training material for the CSRs to learn about Medicare and the ACA/ FFM programs. Training materials also include instructions for the CSRs on how to utilize the National Government Services (NGS) Next Generation Desktop (NGD) and other customer service tools such as Medicare Plan Finder for handling beneficiary and consumer inquiries. These are separate CMS systems that are not part of TQC and maintain their own PIAs for the security of the information contained within those information systems. 

The TQC system has four applications that are part of the system: Content Manager (CM), Learning Management System (LMS), Contact Recording (CR) and Agent Feedback (AF). 

The CSRs log into the TQC system with a username and password. Similarly, system users and administrators utilize a userID and password to access the system for system support activities. 

The TQC CM application contains the training material and content scripts about the Medicare and ACA benefits and ‘how to’ or ‘where to’ access information on the websites. The training and content scripts are informational reference material for CSRs to use when assisting consumers with questions about Medicare and/ or the ACA/FFM programs 

The TQC LMS Application contains CSR employee data about each CSR and includes the CSR’s learning history. CSR training is provided both as instructor led and e-learning. 

In the TQC CR application, the consumer/ beneficiary to CSR telephone interaction is recorded. Consumers that talk to a CSR may provide their name and phone number but it is not used in the TQC system directly. The telephone calls are voice-recorded for quality purposes. Quality Analysts review these interactions and create evaluations. These quality customer interaction evaluations contain data about the CSR and a summary of the telephone inquiry. 

In the TQC AF Application, agent feedback data from NGD is loaded and categorized for analysis and reporting.

The TQC system contains or collects the following types of information to support training and auditing needs and requirements. TQC, CCO, and CMS can reference collected data in support of continuous improvements to training, knowledge, and ultimately, subscriber experience. The information is used to ensure CSRs are receiving correct, accurate, and timely training in order to provide the best customer experience possible. CMS and the CCO will have ongoing access to aged data (through reporting) to analyze issues.

The TQC CM Medicare and ACA benefits training material is informational reference material. The content scripts provide suggested responses and dialogue for conversations with customers. The current version of the training material and script content is maintained indefinitely. 

The CSR employee data in the TQC LMS Application information includes name, work email address, job code, employee status (date of hire and terminated date, if applicable), employee type, supervisor name, and NGD ID. The NGD ID is transmitted from daily feeds and stored in the database. Employee data is not purged but the NGD ID is purged from the CSR's records who are no longer with the CCO. Additionally, CSR learning history is captured, tracked and stored such as: courses taken, time to complete a module, exam results and feedback provided. Learning history data currently is not purged. CSR training is provided both as instructor led and e-learning. CSR employee data and learning history are shared with the CCO and CMS in the form of reports. 

In the TQC CR application, the consumer/ beneficiary and CSR telephone interaction is recorded. All phone calls and 10 to 20% of the screens are recorded and stored for review by TQC and CCO Quality Analysts. The screen recordings are stored for 90 days and voice recordings are stored for one year but select recordings maybe used for training and retained indefinitely. Consumer caller information may contain name and phone number. Consumers that talk to a CSR may provide their name and phone number but it is not used in the TQC system directly. The telephone calls are voice-recorded for quality purposes and therefore, caller information may be retained but it is not utilized by TQC.

Quality Analysts review these interactions and create evaluations. These quality customer interaction evaluations contain data such as the CSR name, CCO site, Automatic Number Identification (ANI), CSR UserID (NGD ID), Quality Analyst name, contact reason summary and scores. This data is retained for a minimum of one year and is shared with the CCO and CMS in the form of Quality Call Monitoring (QCM) scorecards. Additionally, extracts of this evaluation data are provided to the CMS National Database Warehouse (NDW). The NDW maintains its own PIA for the information contained in it. 

In the TQC AF Application, agent feedback data from NGD is loaded and categorized for analysis and reporting. The agent feedback data contains data such as CSR UserID, ANI and CSR feedback comments. This data is shared with CMS in the form of analytics reports.

The TQC system users (CSRs, Quality Analysts, Trainers and system support/infrastructure staff) are CMS employees and direct contractors and utilize a UserID and password to access the TQC system.

• Name
• E-Mail Address
• Phone Numbers
• Employment Status
• Other - User ID, Password, employment information – evaluations, feedback.

• Employees
• Public Citizens

The CSR PII is used to identify a CSR to assign/provide the appropriate training, conduct performance evaluations and provide feedback applicable to that CSR. 

The Beneficiary/Consumer PII data is used by the TQC and CCO Quality Analysts to analyze, evaluate and report on CSR consumer/beneficiary interactions in order to provide recommendations for improvement.

09-70-0560 HIX (Health Insurance Exchange Program) 10/23/2013

09-70-0535 1-800 Medicare Choice, 2/26/2008

The TQC system does not notify the system support staff users that personal information is collected. That notification is part of the normal employment and onboarding process because it is required of employment. 

CMS beneficiaries that call for information are notified with a pre-recorded message stating that the call will be recorded.

For TQC system users there is no method to opt-out of the collection of PII because it a requirement of employment.

There is not an opt-out option for beneficiaries when providing their PII because it is not required for the purpose of TQC. CMS beneficiaries that call for information are notified with a pre-recorded message stating that the call will be recorded.

There is no process in place to directly notify the beneficiaries should major changes occur to the system. If there was a major change affecting the PII in the system, then the SORNs that apply to TQC would be updated and are available for the general public’s access. 

Staff that support the TQC application are notified of any major changes that happen in the system that requires additional PII from their supervisor.

• Users: Some users, who are not administrators, have access to PII. For example, the Quality Analyst role has access to PII in the Training Records for the purpose of grading/rating/monitoring a CSR’s training. The Supervisor role has access to PII of the users that report to them for employment related activity.
• Administrators: LMS Administrators possess access to PII to correct requested data corrections and ensure content deployment gets to the right individuals.
• Developers: Developers possess access to perform system maintenance & data loads. The data loads include the HR feed data containing Job position; Contact Call Center Site; user credentials (login ID); required job training and training results. Access to this information is necessary to troubleshoot data imports/exports
• Contractors: CMS direct contractors in their roles as users, administrators and developers will have access to PII based on those roles. 

The TQC system(s) follow the Centers for Medicare and Medicaid Services' (CMS) Acceptable Risk Safeguards

(ARS) 3.1 for specific security controls guidance.

The TQC system and supporting infrastructure is housed in a CMS accredited datacenter. Entry is controlled by Physical Access Cards and facility personnel who limit access to individuals who have a legitimate business or technical need to enter the facility.

Administrative controls implemented for the TQC system include role-based access, training of personnel and regular account review, which includes disabling accounts.

The technical controls in place include network firewalls, two-factor authentication and encryption of information.