As administrator of the Colorado All Payer Claims Database (CO APCD), CIVHC is required by statute not only to maintain the database, but to continually improve the quality and utility of the CO APCD. One of the most essential activities to enhancement of the CO APCD is the annual updating of the CO APCD Rule and Data Submission Guide (DSG) in collaboration with the Department of Health Care Policy and Financing (HCPF), Division of Insurance (DOI), and health insurance payers across the state.

Annual updates to the Rule and DSG following the HCPF Executive Rule Change Process allow CIVHC to propose new data submission requirements to ensure the data is as robust, comprehensive, accurate, and usable as possible to provide the most benefit to Colorado.

Through the update process, new data elements are added, clarified, or eliminated as needed while the language of the CO APCD Rule (Colorado Regulation 1.200) is updated in accordance. Generally, these updates include:

  • standardization or clarification of elements already being collected,
  • addition of new elements that will either further align CO APCD data submissions with the Common Data Layout (CDL) being used by APCDs throughout the nation, or
  • increase its ability to support and inform efforts to improve health care for Coloradans.

Each DSG update and Rule Change cycle takes place over a year. The CIVHC team started looking toward changes to DSG 14 in early 2022, immediately after approval of changes proposed for DSG 13. Throughout the summer and fall, CIVHC hosted several calls with payers to describe the proposed changes, answer questions, and receive feedback. After multiple drafts, payer feedback calls, comment periods, and virtual public review meetings, CIVHC presented the final proposed changes to HCPF in November 2022 and received approval in December.

DSG 14 and the revised CO APCD Rule will take effect on March 1, 2023. DSG 13 will remain active until May 2023, with payers having a 120-day grace period from the effective date to prepare their systems and submit test files before formal collection of files later this year. Payers’ first submissions of files under DSG 14 will be required in June 2023.

DSG 14

DSG 13 introduced several notable updates to file collection, including the addition of two new annual files related to collection of information on prescription drugs. CIVHC collaborated with payers through the last year as they worked to integrate these reporting enhancements into their systems, and the process is still ongoing to ensure timely, accurate submission of these files. To allow payers and the CIVHC intake team to maintain efforts on verifying quality in the newly-required annual files and data elements, changes under DSG 14 were minimal.

Updates under DSG 14 are primarily clarifications and corrections to data elements to improve the quality of submissions. However, there are still some notable additions.

Membership Eligibility Updates

The most significant additions to the Membership Eligibility Files Are:

  • Addition of a Regional Accountability Entity (RAE) Indicator – A RAE is an organization under Colorado’s Medicaid program responsible for coordinating care, ensuring access, and identifying strategies to improve care. An indicator identifying these organizations is important to enable analysis of Colorado’s Medicaid program.
  • Addition of a Health Insurance Oversight System (HIOS) Plan ID – Identifier of new Qualified Health Care Plans (QHP) approved by Centers for Medicare & Medicaid Services (CMS). This is an important addition in support of HB21-1232, and will enable CIVHC to analyze data related to plans that are implemented in response to the Standardized Health Benefit Plan Colorado Option which requires payers to provide an approved standard health benefit plan.

Other updates to Membership Eligibility files are clarifications of required data elements.

Annual Files Updates

The most significant additions to the annual files are in the Alternative Payment Model (AM) files:

  • Addition of a Payer Code field – Identifies the billing entity responsible for billing patients for services to improve analysis capabilities.
  • Addition of a RAE Indicator

Other updates to annual files are clarifications of required data elements and formatting adjustments.


Updates to the CO APCD Rule were minimal and simply involved updating dates and titles to fall into alignment with DSG 14.

As payers work to prepare for changes under DSG 14, CIVHC is already working to develop DSG 15 in anticipation of what elements, insights, and data collection enhancements will keep the CO APCD at the forefront of claims analysis.

If you have questions regarding DSG 14 or would like more information on completeness and availability of data, please contact