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Office updates on material change reviews and 2025 data collection timeline
Summary
Staff reported recent CMIR (Cost and Market Impact Review) filings and waivers and outlined the 2025 data submission timeline for alternative payment models and primary care spending, including a Sept. 1 data submission deadline for 2023 calendar‑year files.
The Office of California Health Care Affordability reported on activity under the material change/merger review program (CMIR) and summarized the 2025 timeline for data collections used to measure spending and alternative payment model adoption.
CMIR activity: The office reviewed notices and inquiries submitted after the statute took effect. From April through December staff received notices and determined 10 transactions (16 complete submissions) required review; eight submissions received waivers and the average time to issue a waiver has been 22 working days. Examples included transfers of skilled‑nursing facilities and practice acquisitions in multiple counties; several submissions remain under staff review. The office said it will publish filings that are complete and that parties may ask questions through OCA’s CMIR inbox (cmir@hca.ca.gov).
Data collection and timelines: Staff outlined proposed changes to the Healthcare Total Cost (THC) Data Submission Guide (version 2), now released for public comment. Key elements: • Alternative Payment Models (APMs): OCA will collect payment and membership data consistent with the expanded HCAI non‑claims data framework and aligned to HCP‑LAN adoption categories; OPMs linked to quality will be reported separately because those count toward adoption goals. • Primary care spending: OCA will collect claims and non‑claims primary‑care spending by market and payer using a defined “primary care code set” (provider taxonomies, services, and places of service). Staff will collect professional capitation allocations and specified behavioral‑health services delivered in primary‑care settings as part of primary‑care spending. • Calendar: draft regulations and Data Submission Guide 2 were released for comment; required submitters will register in May, may submit test files in June, prepare 2023 calendar‑year files in July–August, and file final data by Sept. 1, 2025. Staff plans a second baseline report to be published on or before June 1, 2026.
Why it matters: The CMIR program is the state’s principal way to surface market concentration and transaction risks for competition and affordability. The data collection timeline and guide shape the metrics OCA will use to measure sector and entity performance and to track progress on primary care investment and APM adoption goals.
