The Office of Personnel Management (OPM) published a notice in the Federal Register on October 31, 2025, announcing a 30-day public comment period for the renewal of an existing information collection related to the Consumer Assessment of Healthcare Providers and Systems (CAHPS) Enrollee Survey. This survey, identified under OMB Control Number 3206-0274, collects feedback from federal employees and retirees about their healthcare experiences. The action stems from requirements under the Paperwork Reduction Act of 1995 (PRA), which mandates federal agencies to seek periodic approval for data collections to minimize public burden while ensuring practical utility. By renewing this collection, OPM aims to continue using CAHPS data to evaluate the performance of health plans under the Federal Employees Health Benefits (FEHB) program, a critical component of federal employee benefits that covers millions of workers and their families. This development underscores ongoing efforts to maintain transparency and quality in federal healthcare administration, potentially affecting plan accountability and enrollee satisfaction.
Background on CAHPS and FEHB Integration
The CAHPS survey is a standardized tool developed to measure patient experiences with healthcare providers and systems. It focuses on aspects like provider communication, access to services, and overall satisfaction, areas where consumers provide the most reliable insights. OPM integrates six specific CAHPS measures into its FEHB Plan Performance Assessment (PPA), a framework established to objectively evaluate health plan carriers. The PPA examines clinical quality, customer service, and resource use, combining these with traditional contract oversight to promote high-quality, affordable care.
This integration has roots in broader federal efforts to enhance accountability in employee benefits. The FEHB program, authorized under the Federal Employees Health Benefits Act of 1959, provides health insurance to about 8 million federal employees, retirees, and dependents through contracts with private carriers. OPM's use of CAHPS data began as part of initiatives to link performance metrics to carrier incentives, including profit adjustments. According to the notice, the PPA is directly tied to service charges or performance adjustments in FEHB contracts, creating financial motivations for carriers to improve based on survey results.
A prior 60-day notice was published on June 25, 2025, in the Federal Register (90 FR 27058), which elicited one public comment. The commenter suggested not delaying a national healthcare system after a claim denial experience, but OPM determined this input was outside the scope of the information collection request (ICR). This highlights how public feedback under the PRA can sometimes extend beyond the specific collection's parameters, yet agencies must focus on relevance to burden and utility.
Key Players and Legal Framework
OPM serves as the primary agency responsible for administering the FEHB program and overseeing this ICR. The Office of Management and Budget (OMB) plays a crucial role in reviewing and approving such collections under the PRA, which requires assessments of necessity, accuracy of burden estimates, and potential improvements in data quality. Public stakeholders, including federal employees, retirees, and other interested parties, are invited to comment, as outlined in 5 CFR part 1320.
The PRA itself, codified at 44 U.S.C. chapter 35, aims to reduce paperwork burdens on the public while ensuring agencies collect only essential information. OMB's specific interests, as noted in the Federal Register entry, include evaluating the collection's necessity for agency functions, the accuracy of burden estimates, ways to enhance information quality, and methods to minimize respondent burden through technology. For this ICR, OPM estimates 48,829 respondents annually, each taking about 15 minutes, resulting in 12,207 total burden hours. This calculation reflects the survey's targeted distribution to FEHB enrollees, including postal workers and retirees.
Relevant precedents include prior renewals of this OMB control number, which have consistently supported OPM's performance assessment goals without major revisions based on public input. Broader legal contexts involve judicial interpretations of the PRA, such as in cases like Center for Law and Education v. Department of Education (2005), where courts emphasized the need for agencies to justify collections' practical utility.
Implications and Perspectives
Short-term implications of this renewal include continued data collection that informs the PPA, potentially leading to immediate adjustments in carrier performance metrics for the upcoming FEHB open season. Enrollees benefit from greater transparency, as CAHPS results help them compare plans based on real experiences rather than just premiums or coverage details.
Long-term, sustained use of CAHPS could drive systemic improvements in federal healthcare quality, influencing how carriers prioritize patient-centered care. However, challenges arise in balancing data utility with respondent burden, especially if participation rates fluctuate or if technological shifts alter how surveys are administered.
Different perspectives exist on this process. From OPM's viewpoint, the survey is essential for fulfilling its mandate to ensure effective FEHB administration, as evidenced by its linkage to contract incentives. Carriers might see it as a tool for competitive improvement but also as an added layer of scrutiny. Enrollees and advocacy groups could view it positively for empowering consumer voices, though some might argue the 15-minute burden is understated or that survey questions overlook certain demographics, like retirees' unique needs. Critics of federal bureaucracy might question the overall efficiency of such collections under the PRA, pointing to the single out-of-scope comment as indicative of broader public frustrations with healthcare systems.
Forward-Looking Considerations
In summary, OPM's push to renew the CAHPS survey reinforces a data-driven approach to FEHB oversight, with public comments due by December 1, 2025. Potential next steps include OMB's review and possible approval, followed by implementation in annual assessments. Ongoing debates may center on refining survey methodologies to incorporate digital tools, addressing any emerging comments on burden reduction, or adapting to evolving healthcare policies. Challenges could involve ensuring high response rates amid privacy concerns or integrating CAHPS with other performance indicators. These elements highlight the dynamic nature of federal information collections in supporting accountable governance.