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OKA staff revise DSG 3.0 after public comment, keep attestation 'penalty of perjury'
Summary
Office staff summarized public comments on the proposed Total Healthcare Expenditure Data Submission Guide (DSG 3.0) and announced revisions: removal of a direct MLR submission requirement, clarification on optional Medicare Advantage benefits, separation of self‑insured reporting, extended file remediation to 10 business days, and retention of a penalty‑of‑perjury attestation.
The California Healthcare Affordability Board (OKA) staff on March 25 presented revisions to the proposed Total Healthcare Expenditure Data Submission Guide (DSG 3.0) after a public comment period that closed Jan. 30.
Assistant Deputy Director CJ Howard said staff received three written comment letters and summarized where OKA will change the draft rules and where it will not. On a notable point of contention, Howard said OKA will not remove attestation language that requires a signer to certify submissions “under penalty of perjury under the laws of the state of California,” citing consistency with existing reporting programs and the need for good‑faith representations.
Margaret Brandt, assistant deputy director, described a set of technical changes staff will make to clarify reporting for alternative payment models (APMs), primary care and behavioral health files, and the treatment of pharmacy rebate estimates when pharmacy benefits are carved out. OKA will separate self‑insured from fully insured commercial spending in the statewide total medical expense file and added guidance to limit proprietary contract disclosures while requiring reasonable estimates when necessary.
Staff also agreed to several procedural concessions requested by commenters: the time for file remediation and resubmission will be extended to 10 business days; automated field‑level validations remain documented in the DSG and manual cross‑file validations will be performed after all files are received; and substantive mid‑year changes will continue to go through formal public rulemaking. Final drafts will be posted after the meeting and sent to the Office of Administrative Law in early April 2026, OKA said.
Public commenters at the meeting urged additional clarity on how the DSG will be used in enforcement and asked that hospitals and labor representatives have the ability to review the data OKA uses. Health Access California and the California Hospital Association both urged careful treatment of behavioral health spending definitions and payer category assignments; the California Nurses Association and SEIU emphasized the policy uses of any administrative‑spending adjustments.
OKA staff said they will post revised DSG materials on the HAI website and open annual data‑submitter registration in May, with technical workgroups planned through the spring.
The board did not vote on the DSG text at the meeting. Staff said they will return to the board with final drafts and supplemental materials as part of the formal rulemaking timeline.
