As administrator of the Colorado All Payer Claims Database (CO APCD), CIVHC is required by statute to maintain the database and continually improve the quality and utility of the data. One of the most important ways CIVHC makes the data better and more useful is by updating the CO APCD Rule and Data Submission Guide (DSG) annually. This is done in collaboration with the Department of Health Care Policy and Financing (HCPF), Division of Insurance (DOI), and health insurance payers across the state.
CIVHC follows the HCPF Executive Rule Change Process to propose new data submission requirements and updates. This is how new data elements are added, clarified, or eliminated, and the CO APCD Rule (Colorado Regulation 1.200) gets updated accordingly. Each update CIVHC proposes is to ensure the data is as robust, comprehensive, accurate and usable as possible and provides the most benefit to Colorado. Generally, these updates include:
• Standardization or clarification of elements already being collected, and/or
• Addition of new elements that will further align CO APCD data submissions with the Common Data Layout (CDL) being used by APCDs throughout the nation
Each DSG update and Rule Change cycle takes place over a year. The CIVHC team starts looking toward changes to the next DSG early in the year, immediately after approval of changes proposed for the previous update. Throughout the summer and fall, CIVHC hosts 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 and HCPF present the final proposed changes in a rule change hearing that typically takes place in November.
The new DSG and the revised CO APCD Rule typically take effect in March of each year. The previous DSG remains active through June, with payers having a 120-day grace period from the effective date to prepare their systems and submit test files before formal submission of files later in the year. Payers’ first submission of files under the new DSG is required in July 2026.
DSG 17
DSG 17 was the latest to be approved and primarily emphasized updates to help improve standardization, clarity and consistency across submissions. Updates also focused on bringing the CO APCD into closer alignment with the CDL and streamlining data submissions to newly appointed data vendor Onpoint Health Data, set to take over CO APCD data processing and intake by July 2026.
While many updates focus on alignment and clarity, a few changes introduce new expectations for submitters. Highlights are outlined below.
Monthly Files Updates
DSG v17 includes several important clarifications and requirement changes related to claims data:
• Medical claims submissions must now include both paid and denied claims, clarifying expectations around completeness of reporting.
• The Denial Processed Date field is now required for all claims, including denied claims, improving visibility into claim adjudication timing.
The remainder of updates made to monthly files were made primarily to clarify reporting instructions and improve guidance across fields. These changes will not alter collection requirements but may affect how existing fields are populated.
Annual Files Updates
Updates to Annual Files focus primarily on formatting, alignment with the CDL, and changes to improve clarity and consistency in file submission. This includes a new requirement to submit annual test files for all applicable annual file types, with new timelines to support issue resolution before submission. The most significant additions are in the Alternative Payment Model (AM) files:
- Alternative Payment Model payment categories were expanded to allow reporting of payments not linked to quality.
- Updates were made to lookup tables and insurance product type lists, including the addition of Dual Eligible Special Needs Plan (D-SNP) codes.
These changes better reflect the range of payment arrangements currently in use.
CO APCD Rule
Updates to the CO APCD Rule were minimal and involved updating dates and titles to fall into alignment with DSG 17.
As payers prepare for changes under the latest DSG, CIVHC is already developing the next DSG update to identify which elements, insights, and data-collection enhancements will ensure the CO APCD remains a vital resource for improving health care and lowering costs for Coloradans.
If you have questions regarding any DSG changes or would like more information on completeness and availability of data, please contact info@civhc.org.
