Common use of Justification and Anticipated Results Clause in Contracts

Justification and Anticipated Results. A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, covering this and seven other “Marketplace” matching programs which CMS conducts with other Federal agencies. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs exceed $30.5 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs since the Marketplace matching programs are not intended to avoid or recover improper payments. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- effective. B. Other Supporting Justifications Although the cost benefit analysis does not demonstrate that this matching program is likely to be cost effective, the program is justified for other reasons, as explained in this section. The DIB therefore is requested to make a determination, in writing, that the cost benefit analysis is not required, in accordance with 5 U.S.C. § 552a(u)(4)(B), and to approve the agreement based on other factors. a. Certain Marketplace matching programs are required and are not discretionary. However, some Marketplace matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. The Marketplace matching programs’ eligibility determinations and MEC checks result in improved accuracy of consumer eligibility, which CMS anticipates will continue to produce expedited Eligibility Determinations while minimizing administrative burdens and achieve operational efficiencies. c. The matching programs provide a significant net benefit to the public by accurately determining eligibility for the APTC. d. An efficient eligibility and enrollment process contributes to greater numbers of consumers enrolling in Marketplace qualified health plans, resulting in a reduction of the uninsured population, therefore improving overall health care delivery. e. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a single, streamlined application process, the ACA effectively required use of computer matching to make eligibility determinations. Therefore, the optimal result is attained by limiting the cost by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was about $30.5 million ($30,563,340) per year. CMS’ analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACA. The Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.

Justification and Anticipated Results. A. Cost Benefit Analysis As required by § §552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1an Attachment, covering this and seven other “Marketplace” matching programs which CMS conducts with other Federal federal agencies. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs exceed are approximately $30.5 58.9 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs since because the Marketplace matching programs are not intended to avoid or recover improper payments. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- cost-effective. B. Other Supporting Justifications Although Even though the cost benefit analysis does Marketplace matching programs cannot demonstrate that this matching program is likely be demonstrated to be cost effectivecost- effective to conduct, ample justification exists in the program is justified for other reasonsCBA sections III (Benefits) and IV (Other Benefits and Mitigating Factors) to justify DIB approval of the matching programs. As required by the Privacy Act at 5 U.S.C. §552a(u)(4)(B), as explained in this section. The each party’s DIB therefore is requested to make a determinationdetermine, in writing, that the cost benefit analysis a CBA (i.e., a CBA demonstrating likely cost- effectiveness) is not requiredrequired (i.e., in accordance with 5 U.S.C. § 552a(u)(4)(B), and is not required to approve this matching program). The Privacy Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done. The intention is to provide Congress with information to help evaluate the effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate. Therefore, each party’s DIB is requested to approve this agreement based on other factors.justifications, which include the following: a. 1. Certain Marketplace matching programs are required and are not discretionary. However, some Marketplace matching programs are based on VHASSA’s permissive routine use disclosure authority, not a statutory obligation. b. 2. The Marketplace matching programs’ eligibility determinations and MEC minimum essential coverage checks result in improved accuracy of consumer eligibility, which CMS anticipates will continue to produce expedited Eligibility Determinations while minimizing administrative burdens and achieve operational efficiencies. c. 3. The matching programs provide a significant net benefit to the public by accurately determining eligibility for the APTC. d. 4. An efficient eligibility and enrollment process contributes to greater numbers of consumers enrolling in Marketplace qualified health plans, resulting in a reduction of the uninsured population, therefore improving overall health care delivery. e. 5. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is are no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a singleHowever, use of matching programs is effectively mandated by statute and regulation in other to provide for the streamlined application process, process required by Congress in section 1413 of the ACA effectively required use of computer matching to make eligibility determinationsPPACA. Therefore, the optimal result is attained by limiting the cost of conducting the matching programs by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was about $30.5 million ($30,563,340) per year. CMS’ analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACA. The Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.

Justification and Anticipated Results. A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, covering this and seven other “"Marketplace” " matching programs which CMS conducts with other Federal agencies. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs exceed are approximately $30.5 39 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs since because the Marketplace matching programs are not intended to avoid or recover improper payments. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- cost effective. B. Other Supporting Justifications Although the cost benefit analysis does not demonstrate that this matching program is likely to be cost effective, the program is justified for other reasons, as explained in this sectionJustifications 1. The DIB therefore is requested to make a determination, in writing, that the cost benefit analysis is not required, in accordance with 5 U.S.C. § 552a(u)(4)(B), and to approve the agreement based on other factors. a. Certain Marketplace matching programs are required have resulted in efficient and are not discretionary. However, some Marketplace matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. The Marketplace matching programs’ accurate consumer eligibility determinations and MEC checks result in improved accuracy of consumer eligibilitychecks, which and substantially reduce the administrative burden on CMS anticipates will continue to produce expedited Eligibility Determinations while minimizing administrative burdens and achieve operational efficienciesAEs. c. 2. The matching programs provide a significant net benefit to the public by allowing CMS and AEs to quickly and accurately determining determine consumer eligibility for the APTCQHPS and IAPs while minimizing consumer burden. d. 3. An efficient eligibility and enrollment process contributes to greater numbers of consumers enrolling in Marketplace qualified health plansQHPs, resulting in a reduction of the uninsured population, therefore improving overall health care delivery. e. 4. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s 's trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a single, streamlined application process, the ACA PPACA effectively required use of computer matching to make eligibility determinations. Therefore, the optimal cost-savings result is attained by limiting the cost costs of conducting the matching program to the extent possible, and by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was is about $30.5 39 million ($30,563,340) per year. CMS’ ' analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACAPPACA. The Privacy Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.

Justification and Anticipated Results. A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, covering this and seven other “"Marketplace” " matching programs which CMS conducts with other Federal agencies. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs exceed are approximately $30.5 39 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs since because the Marketplace matching programs are not intended to avoid or recover improper payments. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- cost effective. B. Other Supporting Justifications Although the cost benefit analysis does not demonstrate that this matching program is likely to be cost effective, the program is justified for other reasons, as explained in this section. The DIB Each P Data Integrity Board (DIB) therefore is requested to make a determination, in writing, that the cost benefit analysis is not required, in accordance with 5 U.S.C. § 552a(u)(4)(B), and to approve the agreement based on these other factors.supporting justifications: a. Certain 1. The Marketplace matching programs are required have resulted in efficient and are not discretionary. However, some Marketplace matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. The Marketplace matching programs’ accurate consumer eligibility determinations and MEC checks result in improved accuracy of consumer eligibilitychecks, which and substantially reduce the administrative burden on CMS anticipates will continue to produce expedited Eligibility Determinations while minimizing administrative burdens and achieve operational efficienciesAEs. c. 2. The matching programs provide a significant net benefit to the public by allowing CMS and AEs to quickly and accurately determining determine consumer eligibility for the APTCQHPS and IAPs while minimizing consumer burden. d. 3. An efficient eligibility and enrollment process contributes to greater numbers of consumers enrolling in Marketplace qualified health plansQHPs, resulting in a reduction of the uninsured population, therefore improving overall health care delivery. e. 4. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s 's trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a single, streamlined application process, the ACA PPACA effectively required use of computer matching to make eligibility determinations. Therefore, the optimal cost-savings result is attained by limiting the cost costs of conducting the matching program to the extent possible, and by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was is about $30.5 39 million ($30,563,340) per year. CMS’ ' analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACAPPACA. The Privacy Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.

Justification and Anticipated Results. Pursuant to the Privacy Act’s subsection 552a(o)(1)(B) requirement, the justification for the program and the anticipated results, including a specific estimate of any savings, is described below: A. Cost Benefit Analysis Requirements As required by § 552a(u)(4section 552a(u)(4)(A) of the Privacy Act, a cost benefit analysis (CBA) is was conducted, included as Attachment 1, covering this CMA with DHS and seven other mandatory “Marketplace” matching programs which CMS conducts with other Federal agencies. The CBA demonstrates that monetary costs to operate the all eight Marketplace matching programs exceed $30.5 million, but does not quantify direct governmental cost saving benefits sufficient to estimate whether they offset the costs since the Marketplace matching programs are not intended to avoid or recover improper paymentssuch costs. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- effectivecost-effective and does not provide a favorable benefit/cost ratio. However, other supporting justifications and mitigating factors to support approval of this CMA though is provided below in Section B. Further, OMB guidance provides that when a matching program is being renegotiated, which is being re-established, pursuant to OMB Circular A-108, the Privacy Act “does not require the showing of a favorable ratio for the match to be continued… The intention is to provide Congress with information to help evaluate the cost-effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.” See OMB Guidelines, 54 Fed. Reg. at 25828. B. Other Supporting Justifications Although Even though the cost benefit analysis does Marketplace matching programs are not demonstrate that this matching program is likely demonstrated to be cost cost-effective, ample justification exists in the program is justified for other reasonsCBA sections III (Benefits) and IV (Other Benefits and Mitigating Factors) to justify DIB approval of the matching programs, as explained in this sectionincluding the following: 1. The DIB therefore is requested to make a determination, in writing, that the cost benefit analysis is not required, in accordance with 5 U.S.C. § 552a(u)(4)(B), and to approve the agreement based on other factors. a. Certain Marketplace matching programs are required and are not discretionary. However, some Marketplace matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. 2. The Marketplace matching programs’ eligibility determinations and MEC Minimum Essential Coverage (MEC) checks result in improved accuracy of consumer eligibilityeligibility determinations, which CMS anticipates will continue to produce expedited Eligibility Determinations while minimizing administrative burdens and achieve operational efficiencies. c. 3. The matching programs provide a significant net benefit to the public by accurately determining eligibility for financial assistance (including the advance payment of the premium tax credit (APTC) and cost sharing reduction (CSR)). d. 4. An efficient eligibility and enrollment process contributes to greater numbers of consumers enrolling in Marketplace qualified health plans, resulting in a reduction of the uninsured population, therefore improving overall health care delivery. e. 5. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a single, streamlined application process, the ACA effectively required use of computer matching to make eligibility determinations. ThereforeIn sum, the optimal result in performing this matching program is attained by limiting the cost by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was about $30.5 million ($30,563,340) per year. CMS’ analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACA. The Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.

Justification and Anticipated Results. A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, covering this and seven other “"Marketplace” " matching programs which CMS conducts with other Federal agencies. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs exceed are approximately $30.5 58.9 million, but does not quantify direct governmental cost saving monetary benefits sufficient to estimate whether they offset the costs since the Marketplace matching programs are not intended to avoid or recover improper paymentssuch costs. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- effectivecost effective (i.e., does not show that the program is likely to pay for itself) and does not produce a favorable benefit-to-cost ratio. However, other supporting justifications and mitigating factors support approval of this CMA, as described below in Section B. OMB guidance provides that the Privacy Act "does not require the showing of a favorable ratio for the match to be continued”. The intention is to provide Congress with information to help evaluate the cost-effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.” See OMB Guidelines, 54 FR 25818 at 25828. B. Other Supporting Justifications Although the cost benefit analysis does not demonstrate that this the Marketplace matching program is programs are likely to be cost effective, ample justification exists in the program is justified for other reasons, as explained in this sectionCBA sections III (Benefits) and IV (Other Benefits and Mitigating Factors) to justify DIB approval of the matching programs. The DIB Each Party’s Data Integrity Board (DIB) therefore is requested to make a determinationdetermine, in writing, that the cost benefit analysis is not required, in accordance with 5 U.S.C. § 552a(u)(4)(B), and to approve the agreement based on these other factors.supporting justifications: a. 1. Certain Marketplace matching programs are required and (i.e., are based on a statutory obligation); not discretionarydiscretionary to conduct. 2. However, some The Marketplace matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. The Marketplace matching programs’ eligibility determinations improve the speed and MEC checks result in improved accuracy of consumer eligibility, which CMS anticipates will continue to produce expedited Eligibility Determinations eligibility determinations while minimizing administrative burdens and achieve achieving operational efficiencies. c. 3. The matching programs provide a significant net benefit to the public and consumers by accurately determining consumers’ eligibility for the APTCfinancial assistance (including APTC and CSRs). d. An 4. The efficient eligibility and enrollment process provided by the Marketplace matching programs contributes to greater numbers of consumers enrolling in Marketplace qualified health plans, resulting in a reduction of the uninsured population, therefore population and improving overall health care delivery. e. 5. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is are no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a singleHowever, use of matching programs is effectively mandated by statute and regulation in order to provide for the streamlined application process, process required by Congress in section 1413 of the ACA effectively required use of computer matching to make eligibility determinationsPPACA. Therefore, the optimal result is attained by limiting the cost of conducting the matching programs by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was about $30.5 million ($30,563,340) per year. CMS’ analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACA. The Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.

Justification and Anticipated Results. A. Cost Benefit Analysis As required by § by§ 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, covering this and seven other “"Marketplace” " matching programs which CMS conducts with other Federal agencies. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs exceed are approximately $30.5 58.9 million, but does not quantify direct governmental cost saving monetary benefits sufficient to estimate whether they offset the costs since the Marketplace matching programs are not intended to avoid or recover improper paymentssuch costs. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- effectivecost effective (i.e., does not show that the program is likely to pay for itself) and does not produce a favorable benefit-to-cost ratio. However, other supporting justifications and mitigating factors support approval of this CMA, as described below in Section B. 0MB guidance provides that the Privacy Act "does not require the showing of a favorable ratio for the match to be continued". The intention is to provide Congress with information to help evaluate the cost-effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate." See 0MB Guidelines, 54 FR 25818 at 25828. B. Other Supporting Justifications Although the cost benefit analysis does not demonstrate that this the Marketplace matching program is programs are likely to be cost effective, ample justification exists in the program is justified for other reasons, as explained in this sectionCBA sections III (Benefits) and IV (Other Benefits and Mitigating Factors) to justify DIB approval of the matching programs. The DIB Each Party's Data Integrity Board (DIB) therefore is requested to make a determinationdetermine, in writing, that the cost benefit analysis is not required, in accordance with 5 U.S.C. § 552a(u)(4)(B), and to approve the agreement based on these other factors.supporting justifications: a. 1. Certain Marketplace matching programs are required and (i.e., are based on a statutory obligation); not discretionarydiscretionary to conduct. 2. However, some The Marketplace matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. The Marketplace matching programs’ eligibility determinations improve the speed and MEC checks result in improved accuracy of consumer eligibility, which CMS anticipates will continue to produce expedited Eligibility Determinations eligibility determinations while minimizing administrative burdens and achieve achieving operational efficiencies.efficiencies.‌‌ c. 3. The matching programs provide a significant net benefit to the public and consumers by accurately determining consumers' eligibility for the APTCfinancial assistance (including APTC and CSRs). d. An 4. The efficient eligibility and enrollment process provided by the Marketplace matching programs contributes to greater numbers of consumers enrolling in Marketplace qualified health plans, resulting in a reduction of the uninsured population, therefore population and improving overall health care delivery. e. 5. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s 's trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is are no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a singleHowever, use of matching programs is effectively mandated by statute and regulation in order to provide for the streamlined application process, process required by Congress in section 1413 of the ACA effectively required use of computer matching to make eligibility determinationsPPACA. Therefore, the optimal result is attained by limiting the cost of conducting the matching programs by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was about $30.5 million ($30,563,340) per year. CMS’ analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACA. The Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.

Justification and Anticipated Results. A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, covering this matching program and seven other “"Marketplace” " matching programs which CMS conducts with other Federal agencies. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs exceed are approximately $30.5 39 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs since because the Marketplace matching programs are not intended to avoid or recover improper payments. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- cost effective. B. Other Supporting Justifications Although the cost benefit analysis does not demonstrate that this matching program is likely to be cost effective, the program is justified for other reasons, as explained in this section. The DIB Each Party’s Data Integrity Board (DIB) therefore is requested to waive the requirements of 5 U.S.C. § 552a(u)(4)(A) and make a determination, in writing, that the a cost benefit analysis demonstrating that the matching program is likely to be cost effective is not required, in accordance with 5 U.S.C. § 552a(u)(4)(B)) and OMB guidelines, and to approve the agreement based on these other factors.supporting justifications: a. Certain 1. The Marketplace matching programs are required have resulted in efficient and are not discretionary. However, some Marketplace matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. The Marketplace matching programs’ accurate consumer eligibility determinations and MEC checks result in improved accuracy of consumer eligibilitychecks, which and substantially reduce the administrative burden on CMS anticipates will continue to produce expedited Eligibility Determinations while minimizing administrative burdens and achieve operational efficienciesAEs. c. 2. The matching programs provide a significant net benefit to the public by allowing CMS and AEs to quickly and accurately determining determine consumer eligibility for the APTCQHPs and IAPs while minimizing consumer burden. d. 3. An efficient eligibility and enrollment process contributes to greater numbers of consumers enrolling in Marketplace qualified health plansQHPs, resulting in a reduction of the uninsured population, therefore improving overall health care delivery. e. 4. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s 's trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a single, streamlined application process, the ACA PPACA effectively required use of computer matching to make eligibility determinations. Therefore, the optimal cost-savings result is attained by limiting the cost costs of conducting the matching program to the extent possible, and by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was is about $30.5 39 million ($30,563,340) per year. CMS’ ' analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACAPPACA. The Privacy Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.

Justification and Anticipated Results. A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, covering this and seven other “Marketplace” matching programs which CMS conducts with other Federal agenciesagencies for the purpose of implementing Insurance Affordability Programs. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs exceed $30.5 million, million but does not quantify direct governmental cost saving benefits sufficient to estimate whether they offset the costs since the Marketplace matching programs are not intended to avoid or recover improper paymentssuch costs. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- effectivecost-effective and does not provide a favorable benefit/cost ratio. However, other supporting justifications and mitigating factors which support approval of this Agreement are provided below in Section B. Further, OMB guidance provides that when a matching program is being negotiated for re-establishment, pursuant to OMB Circular A-108, the Privacy Act “does not require the showing of a favorable ratio for the match to be continued. The intention is to provide Congress with information to help evaluate the cost-effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.” See OMB Guidelines, 54 Fed. Reg. at 25828. B. Other Supporting Justifications Although the cost benefit analysis does not demonstrate that this matching program is likely to be cost effective, the program is justified for other reasons, as explained in this section. The DIB therefore is requested to make a determination, in writing, that the cost benefit analysis is not required, in In accordance with 5 U.S.C. § 552a(u)(4)(B), the DIB may waive the requirements of a cost-benefit analysis if it determines in writing, in accordance with guidelines prescribed by the Director of the Office of Management and to approve the agreement based on other factorsBudget, that a cost-benefit analysis is not required. a. 1. Certain Marketplace matching programs (such as this matching program with IRS) are required and are not discretionary. However, some Marketplace other matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. 2. The Marketplace matching programs’ eligibility determinations and MEC checks result verification service results in improved accuracy of consumer eligibilityEligibility Determinations, which CMS anticipates will continue to produce expedited Eligibility Determinations while minimizing administrative burdens and achieve achieving operational efficiencies. c. 3. The matching programs provide a significant net benefit to the public by accurately determining eligibility for the APTCinsurance affordability programs. d. 4. An efficient eligibility and enrollment process contributes to greater numbers of consumers enrolling in Marketplace qualified health plansQHP coverage on the exchanges, resulting in a reduction of the uninsured population, therefore improving overall health care delivery. e. 5. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a single, streamlined application process, the ACA effectively required use of computer matching to make eligibility determinations. ThereforeIn sum, the optimal result is attained by limiting the cost by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was about $30.5 million ($30,563,340) per year. CMS’ analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACA. The Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.

Justification and Anticipated Results. A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, covering this and seven other “"Marketplace” " matching programs which CMS conducts with other Federal agencies. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs exceed are approximately $30.5 39 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs since because the Marketplace matching programs are not intended to avoid or recover improper payments. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- cost effective. B. Other Supporting Justifications Although the cost benefit analysis does not demonstrate that this matching program is likely to be cost effective, the program is justified for other reasons, as explained in this section. The DIB Each Party’s Data Integrity Board (DIB) therefore is requested to make a determination, in writing, that the cost benefit analysis is not required, in accordance with 5 U.S.C. § 552a(u)(4)(B), and to approve the agreement based on these other factors.supporting justifications: a. Certain 1. The Marketplace matching programs are required have resulted in efficient and are not discretionary. However, some Marketplace matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. The Marketplace matching programs’ accurate consumer eligibility determinations and MEC checks result in improved accuracy of consumer eligibilitychecks, which and substantially reduce the administrative burden on CMS anticipates will continue to produce expedited Eligibility Determinations while minimizing administrative burdens and achieve operational efficienciesAEs. c. 2. The matching programs provide a significant net benefit to the public by allowing CMS and AEs to quickly and accurately determining determine consumer eligibility for the APTCQHPS and IAPs while minimizing consumer burden. d. 3. An efficient eligibility and enrollment process contributes to greater numbers of consumers enrolling in Marketplace qualified health plansQHPs, resulting in a reduction of the uninsured population, therefore improving overall health care delivery. e. 4. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s 's trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a single, streamlined application process, the ACA PPACA effectively required use of computer matching to make eligibility determinations. Therefore, the optimal cost-savings result is attained by limiting the cost costs of conducting the matching program to the extent possible, and by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was is about $30.5 39 million ($30,563,340) per year. CMS’ ' analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACAPPACA. The Privacy Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.

Justification and Anticipated Results. As requested by 5 U.S.C. §552a(o)(1)(B), the justification for the program and the anticipated results, including a specific estimate of any savings, is described below: A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy ActRequirements In accordance with 5 U.S.C. §552a(u)(4)(A), a cost benefit analysis (CBA) is included as Attachment 1, covering . The CBA covers this CMA with DHS and seven other “Marketplace” matching programs which CMS conducts with other Federal agenciesfederal agencies and the AEs. The CBA demonstrates that monetary costs to operate the all eight Marketplace matching programs exceed $30.5 39 million, but does not quantify direct governmental cost saving benefits sufficient to estimate whether they offset the costs since the Marketplace matching programs are not intended to avoid or recover improper paymentssuch costs. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- effectiveeffective and does not provide a favorable benefit cost ratio. However, other supporting justifications and mitigating factors support approval of this CMA, as described below in Section B. OMB guidance provides that the Privacy Act "does not require the showing of a favorable ratio for the match to be continued. The intention is to provide Congress with information to help evaluate the cost-effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.” See OMB Guidelines, 54 FR 25818 at 25828. B. Other Supporting Justifications Although Even though the cost benefit analysis does Marketplace matching programs are not demonstrate that this matching program is likely demonstrated to be cost cost-effective, ample justification exists in the program is justified for other reasonsCBA sections III (Benefits) and IV (Other Benefits and Mitigating Factors) to justify DIB approval of the matching programs, as explained in this sectionincluding the following: 1. The DIB therefore is requested to make a determination, in writing, that the cost benefit analysis is not required, in accordance with 5 U.S.C. § 552a(u)(4)(B), and to approve the agreement based on other factors. a. Certain Marketplace matching programs are required and (i.e., are based on a statutory obligation); not discretionarydiscretionary to conduct. 2. However, some The Marketplace matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. The Marketplace matching programs’ eligibility determinations improve the speed and MEC checks result in improved accuracy of consumer eligibility, which CMS anticipates will continue to produce expedited Eligibility Determinations eligibility determinations while minimizing administrative burdens and achieve achieving operational efficiencies. c. 3. The matching programs provide a significant net benefit to the public and consumers by accurately determining consumers’ eligibility for the APTCfinancial assistance (including APTC and CSRs). d. An 4. The efficient eligibility and enrollment process provided by the Marketplace matching programs contributes to greater numbers of consumers enrolling in Marketplace qualified health plans, resulting in a reduction of the uninsured population, therefore population and improving overall health care delivery. e. 5. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a single, streamlined application process, the ACA PPACA effectively required use of computer matching to make eligibility determinations. Therefore, the optimal cost- savings result is attained by limiting the cost costs of conducting the matching program to the extent possible, and by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was is about $30.5 39 million ($30,563,340) per year. CMS’ analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACAPPACA. The Privacy Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.

Justification and Anticipated Results. A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, covering this matching program and seven other “"Marketplace” " matching programs which CMS conducts with other Federal agenciesagencies and the AEs. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs exceed are approximately $30.5 39 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs since because the Marketplace matching programs are not intended to avoid or recover improper payments. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- cost effective. B. Other Supporting Justifications Although the cost benefit analysis does not demonstrate that this matching program is likely to be cost effective, the program is justified for other reasons, as explained in this section. The DIB therefore is requested Parties request each Party’s Data Integrity Board (DIB) to make a determination, in writing, that the cost benefit analysis is not required, in accordance with 5 U.S.C. § 552a(u)(4)(B), and to approve the agreement based on these other factors.supporting justifications: a. Certain 1. The Marketplace matching programs are required have resulted in efficient and are not discretionary. However, some Marketplace matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. The Marketplace matching programs’ accurate consumer eligibility determinations and MEC checks result in improved accuracy of consumer eligibilitychecks, which and substantially reduce the administrative burden on CMS anticipates will continue to produce expedited Eligibility Determinations while minimizing administrative burdens and achieve operational efficienciesAEs. c. 2. The matching programs provide a significant net benefit to the public by allowing CMS and AEs to quickly and accurately determining determine consumer eligibility for the APTCQHPs and IAPs while minimizing consumer burden. d. 3. An efficient eligibility and enrollment process contributes to greater numbers of consumers enrolling in Marketplace qualified health plansQHPs, resulting in a reduction of the uninsured population, therefore improving overall health care delivery. e. 4. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s 's trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is are no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a single, streamlined application process, the ACA PPACA effectively required use of computer matching to make eligibility determinations. Therefore, the optimal cost-savings result is attained by limiting the cost costs of conducting the matching program to the extent possible, and by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was is about $30.5 39 million ($30,563,340) per year. CMS’ ' analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACAPPACA. The Privacy Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.

Justification and Anticipated Results. A. Cost Benefit Analysis As required by In accordance with 5 U.S.C. § 552a(u)(4) of the Privacy Act552a(u)(4)(A), a cost benefit analysis (CBA) is included as Attachment 1, covering . The CBA covers this and seven other “Marketplace” matching programs which CMS conducts with other Federal agenciesfederal agencies and the AEs. The CBA demonstrates that monetary costs to operate the all eight Marketplace matching programs exceed $30.5 million58.9 million per year, but does not quantify direct governmental cost saving monetary benefits sufficient to offset the costs since costs, because the Marketplace matching programs are not intended to avoid or recover improper payments. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- effective. However, other supporting justifications and mitigating factors support approval of this CMA, as described below. OMB guidance provides that the Privacy Act "does not require the showing of a favorable ratio for the match to be continued. The intention is to provide Congress with information to help evaluate the cost-effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.” See OMB Guidelines, 54 FR 25818 at 25828. B. Other Supporting Justifications Although Even though the cost benefit analysis does not demonstrate that this matching program is likely to be cost effective, the program is justified for other reasons, as explained in this section. The DIB therefore is requested to make a determination, in writing, that the cost benefit analysis is not required, in accordance with 5 U.S.C. § 552a(u)(4)(B), and to approve the agreement based on other factors. a. Certain Marketplace matching programs are required not demonstrated to be cost-effective, ample justification exists in the CBA sections III (Benefits) and are not discretionaryIV (Other Benefits and Mitigating Factors) to justify DIB approval of the matching programs, including the following: 1. However, some The Marketplace matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. The Marketplace matching programs’ have resulted in efficient and accurate consumer eligibility determinations and MEC checks result in improved accuracy of consumer eligibilitychecks, which and substantially reduce the administrative burden on CMS anticipates will continue to produce expedited Eligibility Determinations while minimizing administrative burdens and achieve operational efficienciesAEs. c. 2. The matching programs provide a significant net benefit to the public by allowing CMS and AEs to quickly and accurately determining determine consumer eligibility for the APTCQHPS and IAPs while minimizing consumer burden. d. 3. An efficient eligibility and enrollment process contributes to greater numbers of consumers enrolling in Marketplace qualified health plansQHPs, resulting in a reduction of the uninsured population, therefore improving overall health care delivery. e. 4. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s 's trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is are no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a single, streamlined application process, the ACA effectively required use of computer matching to make eligibility determinations. Therefore, PPACA the optimal cost-savings result is attained by limiting the cost costs of conducting the matching program to the extent possible, and by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was is about $30.5 58.9 million ($30,563,340) per year. CMS’ ' analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACA. The Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriatePPACA.

Justification and Anticipated Results. Pursuant to the Privacy Act’s subsection 552a(o)(1)(B) requirement, the justification for the program and the anticipated results, including a specific estimate of any savings, is described below: A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, 1 covering this and seven other “Marketplace” matching programs which CMS conducts with other Federal agencies. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs exceed $30.5 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs since the Marketplace matching programs are not intended to avoid or recover improper payments. The CBA, therefore, does not demonstrate that the matching program is likely to be cost- cost-effective. B. Other Supporting Justifications Although the cost benefit analysis does not demonstrate that this matching program is likely to be cost effective, the program is justified for other reasons, as explained in this section. The DIB Data Integrity Board therefore is requested to make a determination, in writing, that the a cost benefit analysis reflecting a cost- savings is not required, in accordance with 5 U.S.C. § 552a(u)(4)(B), and to approve the agreement based on the other factorsjustifications and mitigating factors stated below and in the CBA. a. 1. Certain Marketplace matching programs are required and are not discretionary. However, some Marketplace matching programs are based on VHA’s permissive routine use disclosure authority, not a statutory obligation. b. 2. The Marketplace matching programs’ eligibility determinations and MEC checks result in improved accuracy of consumer eligibilityeligibility determinations, which CMS anticipates will continue to produce expedited Eligibility Determinations while minimizing administrative burdens and achieve operational efficiencies. c. 3. The matching programs provide a significant net benefit to the public by accurately determining eligibility for financial assistance (including the APTCAPTC and CSR). d. 4. An efficient eligibility and enrollment process contributes to greater numbers of consumers enrolling in Marketplace qualified health plans, resulting in a reduction of the uninsured population, therefore improving overall health care delivery. e. 5. Continuing to use the current matching program structure, which is less costly than any alternative structure, is expected to increase the public’s trust in the participating agencies as stewards of taxpayer dollars. C. Specific Estimate of Any Savings There is no cost savings to conducting the Marketplace matching programs, as opposed to not conducting them. By requiring a single, streamlined application process, the ACA effectively required use of computer matching to make eligibility determinations. Therefore, the optimal result is attained by limiting the cost by using a matching program operational structure and technological process that is more efficient than any alternatives. CMS estimates that the cost of operating this computer match was about $30.5 million ($30,563,340) per year. CMS’ analysis suggests that the benefits of increased enrollment outweigh the costs given the increase in private insurance coverage through the ACA. The Privacy Act does not require the showing of a favorable ratio for the match to be continued, only that an analysis be done unless statutorily exempted excepted or waived by the DIB. The intention is to provide Congress with information to help evaluate the cost cost-effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.