The Iowa Department of Human Services “cannot ensure the accuracy, completeness, or reliability” of data released to the public about any programs administered by Iowa Medicaid Enterprise, including the managed-care system for some 600,000 Iowans on Medicaid.

When responding to all requests for information about Medicaid or related programs, the DHS also warns users that “there may be errors, omissions, or inaccuracies in the data provided.” Leading Iowa Senate Democrats were unaware of the disclaimer, which they described as “odd,” “troubling,” and “unacceptable.”

I was surprised to read the following paragraph near the end of a letter the DHS sent to Associated Press reporter Barbara Rodriguez on April 30.

The data provided by the Iowa Department of Human Services (DHS) in response to your request is provided “as is.” DHS cannot ensure the accuracy, completeness, or reliability of the data. The encounter validation process is not yet complete and a one percent (1%) error rate has not yet been achieved. Users accept the quality of the data they receive and acknowledge that there may be errors, omissions, or inaccuracies in the data provided. Further, DHS is not responsible for the user’s interpretation, misinterpretation, use or misuse of the data. DHS does not warrant that the data meets the user’s needs or expectations.

Rodriguez had requested statistics about Iowa’s new State Family Planning Program. The official numbers showed “a marked decline in patients and participating health care providers” since the program launched in July 2017 (more details here).

I sought further comment: Is it Iowa DHS policy generally to provide information to the public or news organizations without vouching for its “accuracy, completeness, or reliability”? Should Iowans assume other figures released by the department are not accurate, complete, or reliable? Or was there something specific about the family planning program that made it hard to compile a data set without “errors, omissions, or inaccuracies”?

Public information officer Matt Highland responded by e-mail this morning,

This is a disclaimer that we now send with all IME [Iowa Medicaid Enterprise] data requests. Often encounter data, enrollment numbers, etc., can change within the same day. When publishing data we make sure to share specific caveats such as the data being point in time, that not all claims for a period are in, etc. This disclaimer is something that was created in consultation with the AG [Attorney General’s office] to address these concerns.

But Rodriguez had asked about the family planning program, I countered. Highland explained that while that program “is not part of Medicaid, it is administered through Iowa Medicaid Enterprise. This disclaimer is sent with all IME data requests […].”

Because the human services attorney was unavailable today, I have not been able to confirm whether the Attorney General’s office signed off on such broad language distancing the DHS from data provided about Medicaid-related programs. There are other ways to communicate that some numbers can fluctuate. Indeed, the letter to Rodriguez noted just below one table, “Please note that the enrollment data was gathered at a specific point in time and should be considered a ‘snapshot’ of the program activity. The numbers given may vary slightly from the enrollment number as of the 1st of each month.”

Instead of giving the agency a pass on possible “errors, omissions, or inaccuracies” in data provided, wouldn’t it make more sense for the DHS to clarify, “These figures were accurate and complete as of [date and time accessed] but may have changed subsequently”?

After reading the DHS response to my inquiry, Senate Minority Leader Janet Petersen told Bleeding Heartland,

Governor Reynolds needs to explain why her Administration feels it’s necessary to put such a disclaimer on responses to data requests. How does she expect Iowa taxpayers to have any faith in the information her Administration is providing? It is especially troubling that the disclaimer is attached to information about the Republicans’ State Family Planning Program. Republicans assured Iowans their new program would expand access to family planning services – and it has not delivered. In fact, it has done the opposite. Iowa taxpayers deserve unbiased, accurate information.

Senator Pam Jochum, a vocal critic of the Medicaid privatization policy, commented, “It appears that DHS does not want to be held accountable for the information they provide to the public. Unacceptable.”

Senator Rob Hogg found the disclaimer “odd,” adding, “Iowans in general, and legislators in particular, rely on state government data all the time. This is further evidence that the state is not meeting its obligations for human services.”

I am seeking comment from the governor and will update this post as needed with further political reaction or details from the Attorney General’s office.

UPDATE: Communications director Lynn Hicks confirmed that the Attorney General’s office “advised DHS on the wording.” He could not be more specific about the advice “because of attorney-client privilege.”

Jon Neiderbach, who spent 15 years working for the DHS, told me that the agency “has in the past told legislators, legislative staff, and the public that they didn’t have confidence in specific elements of data contained in regularly disseminated reports.” However, “A general disclaimer like this is way inappropriate and undermines confidence in all DHS data. If there are concerns about specific data elements those should be shared and solutions listed (with a timeline). Note that the specific instance involves a new program that should have had the collection of quality data built-in from its inception.”