Contracts
Review Managed Care and Vendor Agreements:
The law eliminates the "Quarterly Data Analysis Unit Report." If your contracts with HHSC or downstream providers tie performance incentives, penalties, or true-up periods to the release of this specific quarterly report, those clauses are now legally obsolete.
- Action: Amend contracts to reference the "Annual Data Analysis Unit Report" (due December 1).
Hiring/Training
Government Relations & Compliance Staff:
Teams must be retrained on the new legislative data cycle.
- Lobbying: You can no longer rely on an annual HHSC report to support legislative asks regarding IDD pilot programs or DSRIP transitions. These reports are now biennial (every two years).
- Audit Prep: The Data Analysis Unit now reports anomalies to the OIG annually (December 1) rather than quarterly. Prepare compliance teams for a potential spike in OIG audit initiations in Q1 of each year, following this consolidated data release.
Reporting & Record-Keeping
Internal Data Collection:
Because the state is stepping back from frequent public reporting, your organization must step up.
- Independent Benchmarking: You must generate your own internal data or commission independent studies to fill the 24-month gap between state reports, particularly for IDD System Redesign and Quality-Based Payment metrics.
- Data Requests: Anticipate that HHSC data requests to your organization may become less frequent but significantly more voluminous, as they will now cover a two-year lookback period rather than six months.
Fees & Costs
No direct fee changes.
- Hidden Cost: Potential increase in budget required for independent data analysis and Public Information Requests (PIRs) to obtain data previously provided proactively by the state.
