By Lambert Strether of Corrente
“Let’s just make sure it’s not a third-world experience.” –Henry Chao, HHS, of the ObamaCare Federal Exchange
UPDATE “Credit Reporting Agency Hired to Verify Incomes for Insurance Subsidies” — and lambert scooped the world at Naked Capitalism. The Times, 2013-07-17:
The Obama administration has hired a credit reporting agency to help verify the incomes of people who apply for federal subsidies to buy insurance under the new health care law.
The company, Equifax Workforce Solutions, a unit of Equifax Inc., will provide information that is more current than what is available on federal income tax returns.
So the other shoe drops: Income verification by the IRS got triaged on July 5; and Obama just privatized the function; yet another market state solution. You read it here first on 2013-05-12; the context is the change from the 21-page ObamaCare application form to the 3-page form, with new wording added to the 3-page form:
It looks like young Ezra (and, to be fair, everybody else) missed a major policy change in Obama’s shift to the new, shorter (for individuals*), final version of the basic application for ObamaCare.** [The form now reads:]
We’ll check your answers using information in our electronic databases and databases from the Internal Revenue Service (IRS), Social Security, the Department of Homeland Security, . If the information doesn’t match, we may ask you to send us proof.
[H]ere’s the bottom line: You fill out the ObamaCare form under penalty of perjury. And “if the information doesn’t match” “we may ask you to send us proof.” So, if you play “the match game” [with dirty data from Equifax] and lose, you could be facing a perjury charge driven by credit reporting data (or payday lending data, or utility data, or….). Data that you may not know about, that may well be false, that might even be about somebody else, and for which the burden is on you, personally, to correct, which is extremely difficult and costly to do.
Check out the post for lots of detail, and screen shots of the changed form.
I know gloating is so unattractive, but it’s nice to see that an English major’s old-fashioned close reading of the ObamaCare application form, plus a realistic
dose of cynicism and paranoia assessment of the administration’s capabilities, can yield a good outcome, and well before the very well-paid access journalists, too.
Will the state Exchanges launch on time? Even if the Exchanges (now also called “marketplaces”) will only cover 7 million of the 56 million uninsured in 2014, this answer to this question is still important to some; and the political fortunes of the Democratic nomenklatura are not necessarily their first concern.
[T]his implementation issue is not a trivial thing. Many, many, many people are counting on it. They expect to have access to health insurance and for that health insurance to give them access to actual health care. I repeat: This is not trivial. It is not a game.
The answer given by administration officials is “Yes!” Just this week:
“The marketplaces [note plural; she includes all the states] will be ready,” Health and Human Services spokeswoman Joanne Peters said Thursday in a typical statement. “We are on schedule with the testing that began in October 2012. Any discussion to the contrary is pure speculation.”
In fact, there’s not even a Plan B. HHS Secretary Kathleen Sebelius, back on April 12:
“No,” Sebelius said when asked whether there’s a backup plan in case that deadline slips. “We are determined and on track to meet the Oct. 1 deadline.”
But then they can’t say anything else, can they? Given that Obama nailed his colors to the mast of the October 1 launch date in his April 30 presser: “We will implement it.” So, no matter what, we can expect — the ObamaCare rollout being, after all, an off-year employment opportunity for campaign operatives — a ribbon cutting ceremony, a public relations campaign, happy “consumers,” parades, ponies, rainbows, and so forth. Maybe even cute videos and some apps! Something’s going to go up at healthcare.gov, no matter what and come what may. But what? How, at this point, do we verify any of the claims the administration is making? I mean, some of us need to know whether we’re going to be mandated to spend thousands of dollars or not! Even if employers did catch a break and won’t have to.
If ObamaCare were a multibillion fighter plane I’d expect fly-bys, glamour shots of pilots and cockpits, YouTubes of aeronautical maneuvers, and plenty of breathless stenography in the fan press. Even if the aircraft was years late, over budget, and not up to spec! But from ObamaCare, none of that. It’s a remarkably secretive program:
It’s still unclear just how ready these digital systems will be on Day One and how much is already being done to mitigate the inevitable glitches. The administration has remained tight-lipped about the operational details. That has frustrated states and insurers, both of which need to connect to the new under-construction system. “From where I sit, it’s hard to monitor their progress on the data hub, because it is a black box until it either works or doesn’t work,” says Dan Mendelson, CEO of Avalere Health and a former official at the Office of Management and Budget.
I continue to be puzzled by the way the Obama administration is developing the federally run Exchanges in the 35 states in which they will have to run them. …. [W]hy all of the secrecy? … Last week Washington was abuzz with detailed reports in the Washington Post about how personal phone and computer records are being monitored by the federal government. It’s notable that more is now known about that national security enterprise than exactly where HHS is on “ObamaCare” implementation! Why is the implementation of “ObamaCare” by the Obama administration a top-secret enterprise?
The Exchanges are software, so let’s talk about testing. Testing is, one hears, in process as of July 12:
States and health plans [can they not be named?] have begun testing some data Exchange with the federal hub. But states have been testing “clean” data, meaning that every name is spelled perfectly and every Social Security number is entered correctly. Ultimately [that is, in 81 days], the data hub will need to identify people and their information even with typos and errors.
[Rebecca Pearce, executive director of the Maryland Insurance Exchange, told the audience at a recent Gorman Health Group forum outside Washington, D.C.:] “ to have actually connected to the Federal Data Services Hub live during the FDDR [Final Detailed Design Review]. I can tell you that all of the 18 state-based Exchanges must be in some sort of test phase with CMS on the Federal data hub. And that is definitely happening.” The demo included verification of Social Security numbers, citizenship and eligibility for advance premium tax credits.
The Maryland test apparently took place May 30:
Last week, I received my weekly email update from the Maryland health insurance Exchange:
Maryland Health Connection completed its Final Detailed Design Review (FDDR) live system demo on Thursday, May 30. The FDDR is a federal stage-gate required of all state-based Exchanges. Maryland Health Connection successfully demonstrated end-to-end enrollment of a split family scenario including user log in, eligibility determination, real-time data verification through the Federal Data Services Hub, enrollment into plans, payment and file generation to be sent to an insurance carrier. This major information technology milestone received high marks by federal partners. We will continue with development of Maryland Health Connection over the next several weeks and begin user acceptance testing in July.
So what the heck is a Final Detailed Design Review? The Google yields one hit besides dupes of the above quote: The RFP for the Nebraska Exchange:
1. CMS ENTERPRISE LIFE CYCLE ARTIFACTS
The project will comply with CMS’ Enterprise Life Cycle requirements by ensuring that the deliverables and artifacts associated with CMS reviews are prepared and available to the Exchange at least three (3) weeks prior to each of these reviews. For reviews that have already occurred (such as the Planning Review and Design Review), the Exchange will require the contractor to review the artifacts and make appropriate updates to reflect the contractor’s solution and methodologies.
a. Project Reviews
b. Architecture Review (AR)
c. Project Baseline Review (PBR)
d. Preliminary Design Review (PDR)
e. Detailed Design Review (DDR)
g. Pre-Operational Readiness Review (PORR)
h. Operational Readiness Review (ORR)
In a perfect world, I’d use the names of those “life cycle artifacts” as search terms to find [PDF, no doubt, ick] status reports for all the other states with their own Exchanges, but it’s very late. (Enterprising readers?) Here, however, is the [PDF of a PowerPoint deck, double ick] status report from the Massachusetts Health Connector (“HIX”). Remember RomneyCare? Of course you do. From the Board of Directors Meeting, May 9, 2013:
• The HIX-IES project recently completed the Federal Detailed Design Review (FDDR) which comprises a comprehensive IT systems and infrastructure review, including the following areas:
–Detailed system design specifications
–Business rules and use cases
–Data, interface and integration design
–Privacy and security
• Key upcoming Federal milestones
–Pre-operational Readiness Review (Optional) –TBD, likely August
–Operational Readiness Review (Required) –TBD, likely September
OK, so there we have a timeline. But now get this slide:
At this stage, the team continues to aim for a of the Exchange on October 1st, with ACA-required core functions available to our customers
–, testing and stabilization of the system will continue throughout 2014
• However, we are mindful that there is in our timeline. While the project team is working at maximum capacity, we continue to anticipate risks and uncertainties, both internal and external, that will expose us to additional pressure
Let’s look at that slide more closely. Does anybody remember the great designer Edward Tufte’s brilliant demolition of the slides NASA’s engineers used in the Columbia Disaster? Here’s Tufte’s key insight in PowerPoint Does Rocket Science:
As the bullet points march on, the seemingly reassuring headline fades away. Lower-level bullets at the end of the slide undermine the executive summary. … The format reflects a common conceptual error in analytic design: Information architectures mimic the hierarchical structure of large bureaucracies pitching the information. Conway’s law again [q.v.].
We see the exact same pattern here: For the Directors (and for CMS (HHS (Sebelius (Obama)))) the key point is “successful launch.” For the project manager, “Further development.” For the cube dweller down at the bottom of the food chain, “zero ‘wiggle room’.” (At this point we are reminded of the programmers of the Connecticut Exchange working nights and weekends after Obama changed the application form.)
And yet the Massachusetts Health Connector has had a working, fully implemented Exchange since 2006, for seven years. Even they are finding “risks and uncertainties” in moving through Pre-operational Readiness Review to Operational Readiness Review to launch in 145 days (May 9 to October 1, 2013). So, surely states that have never launched an Exchange at all must feel even greater levels of concern?
And now let’s return to Maryland. Remember what the Exchanges are supposed to do:
Building the Exchanges has proven a heavy lift. To make them work, the federal government needs not only a consumer-facing website and call centers stocked with customer-service representatives in 34 states but also a brand-new, complex IT structure to make the system work across the country. The law says that when an applicant enters her information online, various federal agencies must , citizenship status, residency, and eligibility for Medicaid. The portal must also connect to the Veterans Administration, the Defense Department, the Office of Personnel Management, and the Peace Corps. Plus, it needs to communicate with every health plan selling insurance in each state.
And let’s repeat what the Maryland Exchange is said to have done, when successfully completing its Final Detailed Design Review:
Maryland Health Connection successfully demonstrated end-to-end enrollment of a split family scenario including user log in, , real-time data verification through the Federal Data Services Hub, enrollment into plans, payment and file generation to be sent to an insurance carrier.
Alrighty then. Maryland is the only state to have connected to the Federal Data Services Hub and that is reported to have successfully performed “eligibility determination,” which includes income validation, in real time, just as advertised.
But if Maryland’s income validation FDDR on May 30 was indeed successful, then why did Obama triage income validation on July 6?
- Was the Maryland FDDR really not successful?
- Did the Maryland FDDR merely test the Federal Hub API with fake data? And now it turns out the Hub can’t deliver real data?
- Are Maryland (and Massachusetts? and Washington?) still the “only” states to have reached the FDDR stage in the CMS Enterprise Life Cycle?
- And what about California? Surely, if the huge, Democratic, Hispanic “battleground” state’s Exchange had passed its FDDR, victory would be in Obama’s grasp?
- Or (as some on the right think, reinforced by Howard Dean) is this all a cunning [Kenyan Socialist] plot to encourage people to join the Exchanges by making fraudulent attestations about their now unverified income?
I don’t know. But I do know this: When the project lead (project manager (department head (CEO))) start triaging requirements, that’s a sign of a project that’s out of control:
“I think that the administration right now is in a triage mode. Seriously, they do not have the resources to implement all of the provisions on time,” Washington and Lee University law professor Timothy Jost, a supporter of the ACA, testified Wednesday at a House Ways and Means Committee hearing on the delay in employer penalties.
And, as I keep saying, LBJ implemented Medicare for all over-65s in a year, back in the day when crewcut guys in white shirts wearing skinny ties shoveled punch cards into the ravening maws of giant steam-powered mainframes. Of course, Medicare has a very simple single payer systems architecture: Over 65, bang, done, let’s go deliver some health care. LBJ didn’t need to engineer a cluster**** of rentier-driven complexity to keep the sucking mandibles of the health insurance companies firmly planted in our unprotesting flesh. ObamaCare’s “wicked” implementation problems are one and all a consequence of a “market state”-style policy choice by the political class that ignored proven health care successes in favor of rental extraction.
At this point, Serco, Obama’s July 4 pick to administer to the ObamaCare rollout starts to look a lot like the backup plan Sebelius said didn’t exist:
White House officials say that in many cases federal and state computers will be able to verify a consumer’s income and citizenship status and determine eligibility in a matter of minutes [huh? That’s not “real time”!]. But contract documents indicate that federal officials still expect that [not 7 million?] .
Because if the Exchanges go belly up, good old-fashioned paper has passed the test of time. I’d say “Pass the popcorn!” if so many people wouldn’t suffer.
 Time for this hoary old chestnut: “Program testing can be used to show the presence of bugs, but never to show their absence!”
 We know the problems with dirty big data from looking at the issue of false positives in NSA’s surveillance programs.
 “I can tell you?” What kind of language is that? It’s like Obama’s “insider threat” program got applied at HHS, besides DOD.
 I hate the Beltway insider phrase “heavy lift” with the hatred of a million burning suns. Try working in an Amazon warehouse. That’s a heavy lift.
 Washington is also reported to have done testing. From July 14:
Michael Marchand, spokesman for Washington’s Health Benefit Exchange, said the state’s online marketplace had conducted frequent tests with the federal data hub, which had worked well so far.
But “worked well so far” doesn’t tell us where Washington state is in terms of Lifecycle Artifacts, which is the key question for determining whether they are on time.
 Hat tip Katiebird for this insight. And I don’t care that “progressives” and Obots say that income validation really wasn’t all that important. If it wasn’t important, it would never have been a requirement!
 I’m seeing an FDDR completion date of 3/1 in what looks like a Covered California Grant Proposal. That’s all I can find. Readers?
 Let’s face it: The Republicans would have no problem with RomneyCare if Romney were President. And ObamaCare is RomneyCare. Howard Dean: “Barack Obama’s health care bill is nothing new. Mitt Romney signed one just like it four years before.”