Comments on State All Payer Claims Databases Advisory Committee Recommendations

This document is about the American Society of Plastic Surgeons providing comments and recommendations to the State All Payer Claims Databases Advisory Committee on the issue of ERISA plan data submission to state APCDs. The comments address the legal limitations on states mandating ERISA plan participation, and suggest ways to acknowledge the sufficiency or insufficiency of ERISA data in state APCDs, as well as methodologies to adjust APCD data to address ERISA plan non-compliance. The overall goal is to ensure state APCDs can fulfill their intended role under the No Surprises Act without ERISA plans having veto power over the data included.