Americans don’t seem to agree on much when it comes to the Affordable Care Act, but according to a recent poll by the Kaiser Family Foundation, one thing they do seem to agree on in very large majorities is the need for more data about health insurance and how it’s working for consumers. Yet, while the insurance industry itself seems to recognize the importance of collecting and analyzing data, it’s not clear that our government regulators do.

Comments are due shortly on CCIIO’s proposed data collection under the ACA’s transparency rules. As consumer advocates and other stakeholders consider how to respond to CCIIO’s proposed approach, a report on how insurers are using so-called “Big Data” shows just how much data is already out there and how it’s being used.

According to an insurance industry news outlet, the Blue Cross Blue Shield Association (BCBSA), which represents 36 independent Blue Cross Blue Shield insurance companies, is launching a massive data collection effort designed to help employers, member health plans and their providers get a more “in-depth understanding” of their enrollee’s health care utilization. BCBSA’s data management system will collect claims? data from 2.3 billion procedures annually, representing more than 92% of physicians and 96% of hospitals nationwide. BCBSA estimates the data collection will cover one third of all Americans. That represents a lot of data from a significant share of stakeholders in our health care system, an enormous undertaking that a BCBSA representative said warranted an “unprecedented decision” to make the investment needed to get it done.

In stark contrast, CCIIO’s proposed data collection asks insurers offering Qualified Health Plans (QHP) in the marketplaces to provide URL links to insurer practices that affect consumers, including timeframes for drug exceptions and how the plan applies medical necessity, prior authorization and balance billing. So, for example, you can find out how your cost-sharing will apply if you go out of network for care, but you can’t find out how often enrollees in your plan are racking up costs for out-of-network care, which may be a useful indicator of how adequate the network is. You can also get insurer-level enrollment data, but you can’t see if your particular plan has high enrollment (let alone anything about whether a large number of people have disenrolled from the plan, which might also be interesting and useful information to have).

If this doesn’t sound like a lot, CCIIO agrees. The required estimate for time and money required of insurers to comply with the proposed reporting requirement is just 34 hours per year for each QHP issuer (22 hours per year after the first year), and just $2,154.46 per year in staff costs to comply. While we don’t have an estimate for the BCBSA investment in its Big Data effort, it’s likely it is far greater than what they’ll have to spend to comply with CCIIO’s data collection requirement.

CHIR experts recently released a study that mapped out a more ambitious approach to implementing the ACA transparency provisions – one that would arm state and federal regulators with the data they need to oversee their markets and undertake evidence-based policymaking that responds to consumers’ need to access affordable, high quality health care. We envision an approach that would harness the very same Big Data BCBSA is undertaking to collect and which would apply, as the ACA requires, to all health plans, including employer plans and other non-marketplace coverage, in addition to QHPs. Instead, federal regulators are proposing to take only a baby step forward on greater transparency.

Comments on the proposed information collection are due October 13^th, so there’s still time to weigh in if you have thoughts on the matter.