Minnesota All Payer Claims Database
Employer Resources FAQ

Employer Resources

Benefits of Data Submission

Employer Dashboard

Currently, Minnesota self-funded employers are not well represented in data; just 40% of the private market is currently covered in these important and valuable data. To change this, Minnesota policymakers have passed legislation that requires TPAs to permit self-funded employers the choice to participate in the MN APCD, to opt-in to data collection.

Questions can be directed to the MN APCD. Visit the MN APCD Contact Information page for more information.

MDH is making available a range of data products, with different vintages. The recency of data depends on the lag in the data submission schedule. Generally, data on the commercial market and Minnesota’s Medicaid program, Medical Assistance, have a three-month claims run-out. MDH seeks to update data files and dashboards pertaining to these payers within three-to-four months following claims run-out.

Data—including claims from Medicare payers, particularly if they extend to prescription drug claims—have lags due to Medicare processes.

Currently, the Self-funded Employer Dashboard contains data through quarter three of 2024 through quarter two of 2025. MDH expects to update the dashboard quarterly.

The Minnesota’s Legislature’s initiative to offer self-funded employers the opportunity to blend their claims data with the MN APCD to generate valuable insights as they negotiate health benefit plans is aimed at employers covered by the Employer Retirement Income Security Act (ERISA). ERISA is a federal law that, among other things, establishes limits on (or preempts) state oversight over health benefit plans. Recent updates to Minnesota law explicitly state it is the self-funded employer’s choice to elect whether or not to blend their data with the MN APCD, not that of third party administrators.

Administrators of non‑ERISA covered self‑funded plans—essentially public, self-funded employers, including city and county governments, school districts, and the State Employee Group Insurance Program—are already statutorily required to submit data for these employers. The opt‑in provision is therefore not relevant to these employers; however, employers may request clarity from your TPA whether data are, in fact, passed-through or engage with MDH via email at Health.APCD@state.mn.us.

Whether or not to notify employees is not explicitly addressed in the law that establishes the notification requirement. As such, it is an employer’s choice. However, the data that reaches MDH is fully de-identified and re-identification is strictly prohibited. MDH has provisions in place to prevent re-identification. Furthermore, health insurance carriers do not currently and are not required to notify members or employees covered by fully insured plans. Moreover, members were not notified prior to 2016 when ERISA-covered self-funded employers did submit data.

Yes. When the Legislature created the opt‑in opportunity under Minnesota Statutes 2025, section 62U.04, it required TPAs to inform their self‑funded employer clients that this option exists. This notification was paired with background and explanatory information which can also be found on the MN APCD's Employer Resources page.

Material to be used by TPAs to inform employers of their new opportunity to participate in the MN APCD was sent to contacts at all Minnesota-licensed TPAs. Additional TPA staff wishing to receive these materials may contact the MN APCD team at Health.APCD@state.mn.us. 

This contact information is also available on the MN APCD Contact Information page.

Yes. Annually, TPAs are being provided with a suite of resources from MDH and a fact sheet explaining the law employer authority, and relevant context. TPAs can request these materials from the MN APCD by emailing Health.APCD@state.mn.us.

MDH has already made available a number of Employer Resources that can be of value to employers as they negotiate benefit contracts. However, opting into the MN APCD by submitting employer data allows for stronger, more representative data and opens the possibility of customized analyses or benchmarking. The MN APCD team envisions working directly with employers to determine which data elements, data files, or analyses are most valuable and how best to deliver insights. For more information and progress updates to the MN APCD Data Sets and Custom Reports, please subscribe to HEP's GovDelivery email list

Opting into the MN APCD is intended to be a simple, easy process for ERISA-covered self-funded employers. MDH does not charge any fees to employers or TPAs related to data submission. Similarly, TPAs, most of which already submit data to the MN APCD, should experience very limited, one-time effort to pass through data. Employers facing barriers are encouraged to contact the MN APCD team at Health.APCD@state.mn.us  to discuss concerns and options.

No, absolutely not. The statute explicitly protects employer identity, whether employers opt-in or choose not to. Only aggregate counts and claim volumes are reported.

As noted, blending employer data with other data in the MN APCD offers important direct and indirect benefits at a time when healthcare prices are rising, employers struggle to design benefit plans that present value to their employees, and employees, nevertheless, struggle to afford needed care and prescription drugs. Still, MDH understands employers may have urgent priorities that conflict with more closely engaging with benefit design decisions or prefer to learn more before opting-in. MDH strongly encourages these employers to monitor the ongoing implementation of this effort and stay connected to answer open questions.

As a statewide system, the MN APCD complies with the Minnesota Government Data Practices Act by protecting patient data through a layered security approach that combines strict encryption, isolated network infrastructure, and highly controlled data access. As required by statute, data in the MN APCD is de-identified as described under the Code of Federal Regulations, title 45, section 164.514. This means information that could be used to identify an individual is removed, or otherwise protected, before the data can be used or shared.

• Data Encryption and De-identification
  • Pre-submission encryption: Before encounter and billing records are submitted, all patient identifying information is converted into unreadable code using industry-standard algorithms, such as the Advanced Encryption Standard (AES-256) developed by the National Institute of Standards and Technology (NIST).
  • No direct patient identifiers: Only pre-encrypted, de-identified values enter the system, meaning names, Social Security numbers, and direct addresses are never received or stored.
• Technical and Physical Infrastructure
  • Physical isolation of data: The database is housed on data systems that are entirely isolated and disconnected from the public internet, preventing outside discovery or cyberattacks. 
  • Movement restriction: Safeguards built into the hardware and software environments prevent data analysts from downloading or removing detailed information from the secure network.
• Access Controls and Oversight
  • Role-based clearance: System access is restricted to MDH personnel who have completed specific training and received explicit clearance.
  • Minimum necessary use: Authorized users are granted access only to the minimum data required to complete their approved research tasks.
  • Vetted public releases: Publicly shared data is limited to aggregate summary tables, known as Public Use Files (PUFs), which are heavily filtered to ensure no individual person or provider can be identified.

New initiatives are required to fully align with data protections laid out above. This is governed by state law and rigorous alignment with best practices.

Currently, the only authorized users of the MN APCD are MDH staff or vendor partners with whom MDH works to conduct required or needed analyses. The Minnesota Legislature has determined that targeted additional use of the data would produce valuable further insights into the challenges in healthcare related to costs, access, quality, and affordability. 

While the details of the data access expansion are currently being finalized, following safeguards will be in place to ensure current best practices will remain in place:

• Only projects that can demonstrate a public benefit to Minnesota will be approved.
• Approved users must enter into legally binding data use agreements that, among other provisions, govern data security and protections.
• Data users will be required to operate exclusively in the MDH approved data enclave that is engineered with the needed data protection.

Data in the MN APCD is submitted monthly. As noted above, data availability for reporting will vary based on the use case, population, and data completeness (claim runout). MDH produces complete data extracts to be used for downstream reporting and analytic initiatives on a quarterly basis.

As noted, considerable summary and benchmarking data is already available online. In addition, MDH releases MN APCD data in a number of ways:

• MN APCD Public Use Files: Formatted in spreadsheets and freely available for immediate download. PUFs include summary data from the 
  MN APCD with aggregated records that prevent the identification of individual members, providers, and health plans. Data from the MN APCD can be analyzed based on geography and healthcare services to understand variations in healthcare costs, quality, utilization, and outcomes.
• Customized data submission and analyses for employers: MDH envisions working with employers that opt to blend their data with the MN APCD on developing custom analyses and data products beyond what already exists.

• Additional data may be requested through the above-mentioned data access expansion process. Data products include standard data files, limited data files, and customized data files, which are expected to be made available in 2027.

  • Standard Data Set – A pre-built data file, based on annual files, with nearly all de-identified claim-level information that can be released. This large data set is ideal for data requesters with analytic expertise and need comprehensive healthcare claims data for their research.

  • Limited Use Data Set – A customized data set that includes claim-level information with Protected Health Information (PHI) as allowed under HIPAA. Tailored to meet specific research needs, this large data set is best suited for experienced users working with complex data to support research, healthcare operations, or public health initiatives.

  • Custom Data Set – A smaller, de-identified data set tailored to data requestors needing a limited, focused data set.

  • Custom Report – A topic-specific report produced by MDH that includes aggregated records to protect individual identifiers. This option is ideal for data requestors with limited time or analytic resources who want answers to specific questions while minimizing data sharing risks.

MDH anticipates data covering dental claims and non-claims-based payment—which are payments made outside of the claims stream under value-based arrangements and to incentivize quality and population health outcomes—will become available in 2027.

The MN APCD was established to support transparency and inform understanding of healthcare markets. Transparency alone does not guarantee cost reduction, but the data enables employers, policymakers, and payers to move toward actionable insights and, ultimately, towards transformation. At a health system level, this may require legislative action in response to emerging evidence around waste and inefficiency in the healthcare system and sustainability of growth in provider prices. As this takes time, the intent of engagement with employers is to facilitate real-time change in the available information so that employers, as key purchasers, can drive transformation data-driven benefit design decisions.

• Informing telehealth policy changes and evaluating their effects during and after COVID‑19. 
• Supporting the creation and monitoring the implementation of Minnesota’s insulin emergency program by analyzing insulin pricing and cost exposure. 
• Analyzing hospital price variation and market dynamics to illustrate inefficiencies and lack of transparency in procedure pricing in hospitals.
• Contributing analyses to evaluating proposed mandated benefits (Minnesota Statutes, section 62J.26). 
• Quantifying chronic disease prevalence and related spending in Minnesota, as well as spending drivers across provider and services. 
• Conducting cost and market impact analysis. 
• Ad hoc analyses of focused areas healthcare utilization, prices, and/or spending in Minnesota to inform policy development.

While these examples my not have directly contributed to controlling healthcare price levels and growth, they are helping to shape initiatives that could, including through the Prescription Drug Advisory Board (PDAB) and the Center for Healthcare Affordability. To learn more, please visit the MN APCD Publications page.