Members of PCG Health’s Health Innovation Policy Information Technology (HIPIT) center of excellence have been keeping an eye on Gobeille vs Liberty Mutual Insurance Company given its direct impact on All-Payer Claims Databases (APCD), which many PCG state clients rely on to gather data necessary to analyze data on health care services and impact rising health care costs. At issue in the case was whether Vermont (and, by extension, other states) can compel self-insured employers governed by the Federal Employee Retirement Income Security Act of 1973 (ERISA) to submit their health care claims data. Given the large portion of insured individuals enrolled in self-insured plans, the loss of this data would leave huge gaps in APCDs.
After being dismissed by the US District Court for the District of Vermont – a decision that was overturned by the Second Circuit Court of Appeals – the Supreme Court accepted the case last summer. Last week, the Court held that ERISA does preempt the Vermont requirement that self-insured employers submit claims data to the state’s Advanced Premium Tax Credits (APTC).
This summary outlines the case, the decision and potential alternatives for ensuring the comprehensiveness of APCDs.