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2018 Department of Health and Human Services (HHS) Annual Computer Matching Report








  
  
    

  
      





A. Current Composition of the HHS Data Integrity Board (DIB)

**Names and positions of the members of the DIB**
	Scott W. Rowell, Chairperson and Voting Member, Assistant Secretary for Administration
	Kim Hutchinson, Mandatory Voting Member, Executive Officer/Deputy Agency Chief FOIA Officer
	Daniel R. Levinson, Mandatory Voting Member, Inspector General
	Martha C. Craig, Non-voting Advisory Member, Assistant Deputy Associate General Counsel
	**Name and Contact Information of the DIB Secretary**
	Jacqlyn Smith-Simpson
	200 Independence Ave., SW
	Washington, D.C. 20201Jacqlyn.Smith-Simpson@hhs.gov, (202) 795-7648
	**Any Changes in Membership or Structure of the DIB**
	N/A

B. Matching Agreements HHS Entered Into in 2018

CMA HHS #1801**Participant Agencies:** HHS/Administration for Children and Families/Office of Child Support Enforcement (OCSE) is the source agency, and Social Security Administration (SSA) is the recipient agency.

**Title:** "Title II - Office of Child Support Enforcement Quarterly Match"

**Description:** Quarterly batch matches are conducted, comparing an SSA finder file containing identifying data about Disability Insurance (DI) clients to quarterly wage information (and, if legally required, unemployment insurance information ) in OCSE's National Directory of New Hires (NDNH) database, to identify DI applicants and clients who are working and earning wages, so that SSA can make correct DI entitlement determinations, calculate correct DI payment amounts, and avoid and recover DI overpayments.

**Link posted in the Agency's website:** https://www.hhs.gov/sites/default/files/cma-1801-betw-ssa-and-acf.pdf

**Please provide an account of whether the agency has fully adhered to the terms of the matching agreement.**

By signing the CMA, the Social Security Administration agreed to fully adhere to the terms and conditions of the Title II Quarterly Match-NDNH computer matching program.

**Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified.**

A cost benefit analysis (CBA) was prepared by SSA and added to the agreement, which is based on FY 2016 data and confirms that all disclosures continue to be justified because the match results are effective in supporting program administration and reducing overpayments. A caveat was added to this agreement, stating that unemployment insurance information will be provided by OCSE and used by SSA "only if SSA is legally required to use it" for the purposes set forth in the agreement.

**Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.**

A CBA was prepared by SSA, based on FY 2016 data. It estimates that the matching program is effective in preventing improper payments approximately 7 months sooner than would be possible without the matching program, which reduces the amount of improper payments to recover so that approximately 85% are recovered. For FY 2016, this matching operation resulted in an estimated overall savings of about $10,314,768, and the total costs were approximately $343,828, resulting in a favorable benefit-to-cost ratio of 30:1; therefore, we recommended continuing this matching program.

CMA HHS #1803**Participant Agencies:** HHS/Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and Social Security Administration (SSA) is the source agency.

**Title:** "Determining Enrollment or Eligibility for Insurance Affordability Programs under the Patient Protection and Affordable Care Act"

**Description:** CMS provides finder files to SSA, in real time and in batch matches, containing identifying information about individual applicants and enrollees (and, in some cases, other relevant individuals, such as household members) for purposes of obtaining SSA data needed to determine the individuals' eligibility for enrollment in a Qualified Health Plan (QHP) through a federally-facilitated or state-based health insurance exchange established under the Affordable Care Act (ACA) and for Insurance Affordability Programs and Certifications of Exemption, and to make eligibility Redetermination and Renewal decisions, including appeal determinations. CMS and state-based administering agencies use the SSA data to confirm an individual's identity, citizenship, status as deceased or imprisoned, Title II disability benefit quarters of coverage (QC), and monthly and annual income, which is necessary to authenticate identity, determine eligibility, and determine the amount of an advance payment of the premium tax credit (APTC) or cost sharing reduction (CSR) as required by the Affordable Care Act. Some of these checks apply only to applicants, not other relevant individuals.

**Link posted in the Agency's website:** https://www.hhs.gov/sites/default/files/cms-matching-agreement-1803.pdf

**Please provide an account of whether the agency has fully adhered to the terms of the matching agreement.**

The parties have conducted the matching program without change and in compliance with the terms of the agreement.

**Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified.**

All disclosures continue to be justified, because the data is necessary to produce accurate and prompt eligibility determinations, and has proven effective in producing such determinations, as required to achieve the benefit intended by the ACA, which is maximizing enrollments in qualified health plans.

**Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.**

A cost benefit analysis (CBA) was performed by CMS, covering this and seven other "Marketplace" matching programs which CMS conducts with other federal source agencies and state-based administering entities. The CBA demonstrates that monetary costs to conduct the eight Marketplace matching programs exceed $30.5 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs, because the Marketplace matching programs are not intended to avoid or recover improper payments (the benefit they provide is maximizing enrollments in qualified health plans and reducing the uninsured population, which improves overall health care delivery).

Although the CBA does not demonstrate that the Marketplace matching programs are likely to be cost-effective to conduct, it includes other justifications which supported continuing the matching programs. The CBA mentions that computer matching is necessary to provide the single, streamlined application process required by the ACA; it examined the existing matching structure and determined it is less costly than an alternative structure that CMS could have adopted; it measured the time it takes for an individual to complete the application process and described how the application is being further improved to shorten that time burden for consumers; and it confirmed that the matching programs are effective in providing accurate and prompt eligibility determinations.

CMA HHS #1805**Participant Agencies:** HHS/Centers for Medicare & Medicaid Services (CMS) is the source agency, and State-Based Administering Entities (AE) are recipient agencies.

**Title:** "The Disclosure of Insurance Affordability Programs Information under the Patient Protection and Affordable Care Act"

**Description:** In this matching program, CMS provides state-based administering entities with certain data that CMS receives from source federal agencies under other Marketplace matching programs, to assist the state entities in verifying applicant information as required by the Affordable Care Act to determine the applicants' eligibility for enrollment in applicable state health subsidy programs, including exemption from the requirement to maintain minimum essential coverage or from the individual responsibility payment. In addition, to avoid dual enrollment, certain data is shared in this matching program between CMS and the state entities and among the state entities, to verify whether applicants and enrollees are currently eligible for or enrolled in a Medicaid/CHIP program.

**Link posted in the Agency's website:** https://www.hhs.gov/sites/default/files/cms-matching-agreement-1805.pdf

**Please provide an account of whether the agency has fully adhered to the terms of the matching agreement.**

The parties have conducted the matching program without change and in compliance with the terms of the agreement.

**Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified.**

All disclosures of the records used in this matching program continue to be justified.

**Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.**

A cost benefit analysis (CBA) was performed by CMS, covering this and seven other "Marketplace" matching programs which CMS conducts with other federal source agencies and state-based administering entities. The CBA demonstrates that monetary costs to conduct the eight Marketplace matching programs exceed $30.5 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs, because the Marketplace matching programs are not intended to avoid or recover improper payments (the benefit they provide is maximizing enrollments in qualified health plans and reducing the uninsured population, which improves overall health care delivery).

Although the CBA does not demonstrate that the Marketplace matching programs are likely to be cost-effective to conduct, it includes other justifications which supported continuing the matching programs. The CBA mentions that computer matching is necessary to provide the single, streamlined application process required by the ACA; it examined the existing matching structure and determined it is less costly than an alternative structure that CMS could have adopted; it measured the time it takes for an individual to complete the application process and described how the application is being further improved to shorten that time burden for consumers; and it confirmed that the matching programs are effective in providing accurate and prompt eligibility determinations.

CMA HHS #1806**Participant Agency:** HHS/Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and DoD/Defense Manpower Data Center (DMDC) is the source agency.

**Title:** "Verification of Minimum Essential Coverage under the ACA Program"

**Description:** In this matching program, DoD provides data when requested by CMS and state-based administering entities, which verifies whether an individual who is applying for or is enrolled in private health insurance coverage through a federally-facilitated or state-based health insurance exchange established under the Affordable Care Act (ACA) is eligible for coverage under a DoD health benefits plan (i.e., TRICARE), and the dates that the individual was eligible for such coverage. DoD health benefit plans provide minimum essential coverage, and eligibility for such plans usually precludes eligibility for financial assistance in paying for private coverage.

**Link posted in the Agency's website:** https://www.hhs.gov/sites/default/files/cma-1806.pdf

**Please provide an account of whether the agency has fully adhered to the terms of the matching agreement.**

The parties have conducted the matching program without change and in compliance with the terms of the agreement.

**Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified.**

All disclosures of the records used in this matching program continue to be justified.

**Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.**

A cost benefit analysis (CBA) was performed by CMS, covering this and seven other "Marketplace" matching programs which CMS conducts with other federal source agencies and state-based administering entities. The CBA demonstrates that monetary costs to conduct the eight Marketplace matching programs exceed $30.5 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs, because the Marketplace matching programs are not intended to avoid or recover improper payments (the benefit they provide is maximizing enrollments in qualified health plans and reducing the uninsured population, which improves overall health care delivery).

Although the CBA does not demonstrate that the Marketplace matching programs are likely to be cost-effective to conduct, it includes other justifications which supported continuing the matching programs. The CBA mentions that computer matching is necessary to provide the single, streamlined application process required by the ACA; it examined the existing matching structure and determined it is less costly than an alternative structure that CMS could have adopted; it measured the time it takes for an individual to complete the application process and described how the application is being further improved to shorten that time burden for consumers; and it confirmed that the matching programs are effective in providing accurate and prompt eligibility determinations.

CMA HHS #1807**Participant Agency:** HHS/Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and Department of Veterans Affairs (VA)/Veterans Health Administration (VHA) is the source agency.

**Title:** "Verification of Minimum Essential Coverage for an ACA Program through a VHA Health Benefit Plan"

**Description:** In this matching program, VHA provides data, when requested by CMS, for use by CMS and state-based administering entities, which verifies whether an individual who is applying for or is enrolled in private health insurance coverage through a federally-facilitated or state-based health insurance exchange established under the Affordable Care Act (ACA) is eligible for coverage under a VHA health benefits plan. VHA health benefit plans provide minimum essential coverage, and eligibility for such plans usually precludes eligibility for financial assistance in paying for private coverage. VHA provides this data to CMS about any individual identified in a request submitted by a state-based administering entity whose data matches VHA records, but only to the extent that VHA is authorized to release information about that individual.

**Link posted in the Agency's website:** https://www.hhs.gov/sites/default/files/cms-matching-agreement-1807.pdf

**Please provide an account of whether the agency has fully adhered to the terms of the matching agreement.**

The parties have conducted the matching program without change and in compliance with the terms of the agreement.

**Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified.**

All disclosures of the records used in this matching program continue to be justified.

**Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.**

A cost benefit analysis (CBA) was performed by CMS, covering this and seven other "Marketplace" matching programs which CMS conducts with other federal source agencies and state-based administering entities. The CBA demonstrates that monetary costs to conduct the eight Marketplace matching programs exceed $30.5 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs, because the Marketplace matching programs are not intended to avoid or recover improper payments (the benefit they provide is maximizing enrollments in qualified health plans and reducing the uninsured population, which improves overall health care delivery).

Although the CBA does not demonstrate that the Marketplace matching programs are likely to be cost-effective to conduct, it includes other justifications which supported continuing the matching programs. The CBA mentions that computer matching is necessary to provide the single, streamlined application process required by the ACA; it examined the existing matching structure and determined it is less costly than an alternative structure that CMS could have adopted; it measured the time it takes for an individual to complete the application process and described how the application is being further improved to shorten that time burden for consumers; and it confirmed that the matching programs are effective in providing accurate and prompt eligibility determinations.

CMA HHS #1808**Participant Agency:** HHS/Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and Department of Treasury/Internal Revenue Service (IRS) is the source agency.

**Title:** "Verification of Household Income and Family Size for Insurance Affordability Programs and Exemptions"

**Description:** This matching program provides CMS with IRS return information, upon request, which CMS and state-based administering entities use to verify household income and family size for applicants and enrollees receiving (1) initial determinations of eligibility to enroll in a qualified health plan (including the Medicaid/Children's Health Insurance Program (CHIP) and a state's basic health program) through a federally-facilitated or state-based health insurance exchange established under the Affordable Care Act (ACA) and for insurance affordability programs (including advance payments of the premium tax credit and cost sharing reductions) and certificates of exemption; and (2) subsequent eligibility redetermination and renewal decisions, including appeal decisions. To obtain the return information, CMS provides IRS with the relevant taxpayer's name, social security number, and relationship to the applicant(s) or enrollee(s) (i.e., primary, spouse, or dependent).

**Link posted in the Agency's website:** https://www.hhs.gov/sites/default/files/cms-irs-aca-cms-1808.pdf

**Please provide an account of whether the agency has fully adhered to the terms of the matching agreement.**

The parties have conducted the matching program without change and in compliance with the terms of the agreement.

**Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified.**

All disclosures of the records used in this matching program continue to be justified.

**Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.**

A cost benefit analysis (CBA) was performed by CMS, covering this and seven other "Marketplace" matching programs which CMS conducts with other federal source agencies and state-based administering entities. The CBA demonstrates that monetary costs to conduct the eight Marketplace matching programs exceed $30.5 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs, because the Marketplace matching programs are not intended to avoid or recover improper payments (the benefit they provide is maximizing enrollments in qualified health plans and reducing the uninsured population, which improves overall health care delivery).

Although the CBA does not demonstrate that the Marketplace matching programs are likely to be cost-effective to conduct, it includes other justifications which supported continuing the matching programs. The CBA mentions that computer matching is necessary to provide the single, streamlined application process required by the ACA; it examined the existing matching structure and determined it is less costly than an alternative structure that CMS could have adopted; it measured the time it takes for an individual to complete the application process and described how the application is being further improved to shorten that time burden for consumers; and it confirmed that the matching programs are effective in providing accurate and prompt eligibility determinations.

CMA HHS #1809**Participant Agency:** HHS/Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and the Department of Homeland Security (DHS)/United States Citizenship and Immigration Services (USCIS) is the source agency.

**Title:** "Verification of United States Citizenship and Immigration Status Data for Eligibility Determinations"

**Description:** This matching program provides CMS with USCIS data, including immigrant, nonimmigrant, and naturalized or derived citizenship status information, about individual applicants and enrollees identified in finder files submitted to USCIS by CMS. The USCIS data indicates whether an applicant or enrollee is lawfully present, a qualified non-citizen, or a naturalized or derived citizen, and whether the five-year waiting period for many non-citizens applies and has been met. CMS and state-based administering entities use the USCIS data to determine the individual's eligibility for enrollment in a qualified health plan through a federally-facilitated or state-based health insurance exchange established under the Affordable Care Act (ACA) and for insurance affordability programs and certificates of exemption, and to make eligibility redetermination and renewal decisions, including appeal determinations.

**Link posted in the Agency's website:** https://www.hhs.gov/sites/default/files/CMA-1809.pdf

**Please provide an account of whether the agency has fully adhered to the terms of the matching agreement.**

The parties have conducted the matching program without change and in compliance with the terms of the agreement. By signing the CMA, CMS has fully adhered to the terms of the matching program.

**Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified.**

All disclosures of the records used in this matching program continue to be justified.

**Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.**

A cost benefit analysis (CBA) was performed by CMS, covering this and seven other "Marketplace" matching programs which CMS conducts with other federal source agencies and state-based administering entities. The CBA demonstrates that monetary costs to conduct the eight Marketplace matching programs exceed $30.5 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs, because the Marketplace matching programs are not intended to avoid or recover improper payments (the benefit they provide is maximizing enrollments in qualified health plans and reducing the uninsured population, which improves overall health care delivery).

Although the CBA does not demonstrate that the Marketplace matching programs are likely to be cost-effective to conduct, it includes other justifications which supported continuing the matching programs. The CBA mentions that computer matching is necessary to provide the single, streamlined application process required by the ACA; it examined the existing matching structure and determined it is less costly than an alternative structure that CMS could have adopted; it measured the time it takes for an individual to complete the application process and described how the application is being further improved to shorten that time burden for consumers; and it confirmed that the matching programs are effective in providing accurate and prompt eligibility determinations.

CMA HHS #1810**Participant Agency:** HHS/Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and Office of Personnel Management (OPM) is the source agency.

**Title:** "Verification of Eligibility for Minimum Essential Coverage for an ACA Program through an OPM Health Benefit Program"

**Description:** In this matching program, OPM provides data to CMS on a monthly basis which identifies each active federal employee who is enrolled in or eligible for coverage under an OPM health benefit plan. The data is used by CMS and state-based administering entities, to verify whether an individual who is applying for or is enrolled in private health insurance coverage through a federally-facilitated or state-based health insurance exchange established under the Affordable Care Act (ACA) is eligible for coverage under a OPM health benefits plan. OPM health benefit plans provide minimum essential coverage, and eligibility for such plans usually precludes eligibility for financial assistance in paying for private coverage.

**Link posted in the Agency's website:** https://www.hhs.gov/sites/default/files/cma-1810.pdf

**Please provide an account of whether the agency has fully adhered to the terms of the matching agreement.**

The parties have conducted the matching program without change and in compliance with the terms of the agreement.

**Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified.**

All disclosures of the records used in this matching program continue to be justified.

**Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.**

A cost benefit analysis (CBA) was performed by CMS, covering this and seven other "Marketplace" matching programs which CMS conducts with other federal source agencies and state-based administering entities. The CBA demonstrates that monetary costs to conduct the eight Marketplace matching programs exceed $30.5 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs, because the Marketplace matching programs are not intended to avoid or recover improper payments (the benefit they provide is maximizing enrollments in qualified health plans and reducing the uninsured population, which improves overall health care delivery).

Although the CBA does not demonstrate that the Marketplace matching programs are likely to be cost-effective to conduct, it includes other justifications which supported continuing the matching programs. The CBA mentions that computer matching is necessary to provide the single, streamlined application process required by the ACA; it examined the existing matching structure and determined it is less costly than an alternative structure that CMS could have adopted; it measured the time it takes for an individual to complete the application process and described how the application is being further improved to shorten that time burden for consumers; and it confirmed that the matching programs are effective in providing accurate and prompt eligibility determinations.

CMA HHS #1811**Participant Agency:** HHS/Centers for Medicare & Medicaid Services (CMS) is the recipient agency, and the Peace Corps is the source agency.

**Title:** "Verification of Minimum Essential Coverage under an ACA Program"

**Description:** In this matching program, Peace Corps provides data to CMS in a bulk file each Tuesday through Saturday which identifies all Peace Corps volunteers (all active volunteers, and all who left service within the prior three months) and the dates when each volunteer was eligible for coverage under a Peace Corps health benefits plan. The data is used by CMS and state administering entities, to verify whether an individual who is applying for or is enrolled in private health insurance coverage through a federally-facilitated or state-based health insurance exchange established under the Affordable Care Act (ACA) is eligible for coverage under a Peace Corps health benefits plan. Peace Corps health benefit plans provide minimum essential coverage, and eligibility for such plans usually precludes eligibility for financial assistance in paying for private coverage.

**Link posted in the Agency's website:** https://www.hhs.gov/sites/default/files/cms-1811.pdf

**Please provide an account of whether the agency has fully adhered to the terms of the matching agreement.**

The parties have conducted the matching program without change and in compliance with the terms of the agreement. By signing the CMA, CMS has fully adhered to the terms of the matching program.

**Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified.**

All disclosures of the records use in this matching program continue to be justified.

**Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.**

A cost benefit analysis (CBA) was performed by CMS, covering this and seven other "Marketplace" matching programs which CMS conducts with other federal source agencies and state-based administering entities. The CBA demonstrates that monetary costs to conduct the eight Marketplace matching programs exceed $30.5 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs, because the Marketplace matching programs are not intended to avoid or recover improper payments (the benefit they provide is maximizing enrollments in qualified health plans and reducing the uninsured population, which improves overall health care delivery).

Although the CBA does not demonstrate that the Marketplace matching programs are likely to be cost-effective to conduct, it includes other justifications which supported continuing the matching programs. The CBA mentions that computer matching is necessary to provide the single, streamlined application process required by the ACA; it examined the existing matching structure and determined it is less costly than an alternative structure that CMS could have adopted; it measured the time it takes for an individual to complete the application process and described how the application is being further improved to shorten that time burden for consumers; and it confirmed that the matching programs are effective in providing accurate and prompt eligibility determinations.

CMA HHS #1812**Participant Agency:** HHS/Centers for Medicare & Medicaid Services (CMS) is the source agency, and Social Security Administration (SSA) is the recipient agency.

**Title:** "Disclosure of Nursing Care Facility Admission Information and Discharge Information"

**Description:** In this matching program, CMS provides SSA with nursing care facility admission and discharge data about individual recipients of Supplemental Security Income (SSI) payments whose identifying information is in monthly finder files SSA provides to CMS, when the individuals' identifying information matches data in CMS's Long-Term Care Minimum Data Set. The data enables SSA to identify, more quickly and cost-effectively than would be possible under a manual process, beneficiaries who failed to report admissions to skilled nursing facilities and SVB beneficiaries who failed to report residency in the United States, which affects the individuals' eligibility for and amount of benefits under the SSI and Special Veterans Benefit (SVB) programs. The match results help SSA enforce eligibility requirements and reduce and recover SSI and SVB overpayments.

**Link posted in the Agency's website:** https://www.hhs.gov/sites/default/files/cms-ssa-cma-1812.pdf

**Please provide an account of whether the agency has fully adhered to the terms of the matching agreement.**

The parties have conducted the matching program without change and in compliance with the terms of the agreement. By signing the CMA, CMS has fully adhered to the terms of the matching program.

**Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified.**

All disclosures of the records used in this matching program continue to be justified.

**Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.**

Yes, an updated cost benefit analysis (CBA) was performed by SSA based on FY 2016 data, which reflects a favorable benefit-to-cost ratio of 4.26:1 (this is, however, less favorable than the 7.37:1 ratio estimated in the last CBA, which was based on FY 2014 data). SSA's estimated costs for the matching program in FY 2016 were $24,787,959. The estimated benefits in FY 2016 totaled $105,653,136 for cases in which corrections resulted in a decrease in the monthly payment amount (i.e., avoidance of future overpayments) and/or the recovery of detected overpayments and continues to be based on the assumption that, without this matching program, the overpayments would have continued for 8 additional months.

CMA HHS #1814**Participant Agency:** HHS/Administration for Children and Families/Office of Child Support Enforcement (OCSE) is the recipient agency, and Department of Housing and Urban Development (HUD) is the source agency.

**Title:** "Verification of Employment and Income and Analysis"

**Description:** In this matching program, OCSE provides HUD with new hire, quarterly wage, and unemployment insurance information from OCSE's National Directory of New Hires (NDNH) database, about participants in certain HUD rental assistance programs whose names and Social Security Numbers (SSNs) are in monthly or quarterly finder files and match name/SSN combinations in NDNH. HUD uses the NDNH data to verify the employment and income information the participants report to HUD and, with identifiers removed, may use the data to conduct quality control studies of participant reporting. The match results are intended to help HUD detect and reduce overpayments of rental housing assistance caused by tenants' under-reporting of their income, or by HUD's miscalculation of subsidy amounts or by housing provider/administrator billing errors.

**Link posted in the Agency's website:** https://www.hhs.gov/sites/default/files/cma-1814-betw-hud-and-acf.pdf

**Please provide an account of whether the agency has fully adhered to the terms of the matching agreement.**

The parties have conducted the matching program without change and in compliance with the terms of the agreement. The Department of Housing and Urban Development (HUD) has fully adhered to the terms and conditions of the matching agreement.

**Please provide an account of whether all disclosures of agency records for use in the matching program continue to be justified.**

All disclosures of the records used in the matching program continue to be justified. One quality control study (the HUD QC Study) is no longer conducted, so the matching agreement no longer reflects that HUD will provide an annual input file to OCSE to obtain NDNH data for that study. A HUD FY 2017 performance report indicates: 1.) There is a strong correlation between income data provided from NDNH and household-level income reported to HUD by its funding recipients. 2.) HUD income data reported over time appears to change in relation to NDNH. 3.) A relationship exists between changes in HUD subsidy amounts and the NDNH to HUD income correlation. The NDNH appears to provide HUD with an important and useful data point for HUD's income verification and is a necessary independent data to prevent potential improper payments.

**Please indicate whether a cost-benefit analysis was performed, the results of the cost-benefit analysis, and an explanation of why the agency proceeded with any matching program for which the results of the cost-benefit analysis did not demonstrate that the program is likely to be cost effective.**

HUD prepared an updated cost benefit analysis based on FY 2017 data. The analysis states that the matching program detected over $2.3 billion in underreported income by tenants, which could have resulted in $300 million in overpayments if the matching program had not detected the underreported income; and that the matching program cost approximately $2.7 million to conduct. This results in a favorable benefit-to-cost ratio of 100:1. The analysis also estimates that HUD's use of the NDNH data received in this matching program saved an estimated $207,801,995 to public housing assistance agency-administered HUD rental housing programs.

C. Programs Where Cost/Benefit Analysis was waived

N/A

D. Matching Agreements the DIB Disapproved

N/A

E. Any Violations of Matching Agreements that Have Been Alleged or Identified

N/A

                    
  


Content created by Freedom of Information Act (FOIA) Division Content last reviewed July 6, 2021 Back to top
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