CDT submitted comments in response to a Request for Information (RFI) issued by the Centers for Medicare & Medicaid Services (CMS), on the development and implementation of a comprehensive access strategy for Medicaid and the Children’s Health Insurance Program (CHIP). Appropriate and timely data sharing can play an important role in better serving individuals and ensuring that benefits determinations are based on necessary, complete, and accurate data. However, there must be procedures and limits around how and when individuals’ data is shared to preserve the privacy of applicants and beneficiaries and to increase the likelihood of successful data sharing that is trusted by communities.
Our comments highlight data sharing practices that help individuals access and maintain benefits while also protecting beneficiaries’ privacy. Specifically, we recommend that CMS and their state partners embrace responsible and equitable data governance practices. To do so, CMS should support state agencies and issue guidance focused on:
- Adopting robust data governance practices and policies,
- Engaging communities meaningfully and ensuring transparency around data sharing, and
- Mitigating the risks of automated benefits determination.