About the Minnesota All Payer Claims Database

The MN APCD collects and integrates the following data from private and public payers: 

• Medical claims 
• Dental claims 
• Pharmacy claims 
• Eligibility files 
• Provider files 
• Encounter data, including contracted prices and non-claims-based payments to healthcare providers 

Data are submitted by: 

• Commercial health plan companies 
• Dental organizations 
• Third Party Administrators (TPAs) 
• Pharmacy Benefit Managers (PBMs) 
• Minnesota Healthcare Programs 
• Medicare 

Health plan companies, TPAs, PBMs, and dental organizations are required to submit encounter data, data on contracted prices, and non-claims-based payment information. 

Data oversight and authority

Minnesota Statutes, section 62U.04 directs the commissioner of health to collect and maintain the MN APCD. The Health Economics Program of MDH operationalizes all MN APCD-related functions, including expanding data access and use. 

Scope of the database

The MN APCD: 

• Includes data from 2009 to the present 
• Represents more than 100 data submitters 
• Receives an average of 190 million medical claims and 57 million prescription drug claims each year 

How the data are generated

The data comes from bills sent by providers to payers for payment. These bills are usually sent electronically and list the services provided, their costs, and the payments made. Standard codes are used to describe everything from hospital stays and office visits, to lab tests and medical equipment. Patients receive similar information in an Explanation of Benefits (EOB) after the insurance company determines what they will pay. 

Data submission requirements

Minnesota Administrative Rules, chapter 4653, provide guidance on data submission. Companies with less than $3,000,000 in annual medical claims and/or $300,000 in annual pharmacy claims are exempt from MN APCD data submission requirements. 

Data privacy and security

Protecting privacy is our top priority. As a statewide repository, the MN APCD is subject to the Minnesota Government Data Practices Act. This act—and the data classification in Minnesota Statutes, section 62U.04—defines protections for individuals and their data that are collected in government systems, allows for the preparation of summary data, and describes response requirements in case of data breaches. 

Protecting individual privacy in the MN APCD is a critical priority for MDH. Data submitters remove all identifying patient information—such as members' names and birth dates—by converting data into unrecognizable strings of letters and numbers (encrypted) that cannot be decoded or reversed. Industry standard encryption algorithms are used, ensuring data users—including MDH staff and other analysts—cannot decrypt the submitted data. As a result, individual patients and providers are not identifiable in the MN APCD data. 

The data is also physically and technically locked down with: 

• Secure Environment: Information is stored on secure servers not discoverable from the internet with multiple overlapping software controls and regularly audited for compliance. 
• Layered Approval and Access: Access is strictly limited to a small number of authorized staff who are blocked from removing any detailed information from the secure environment. 
• Policy Controls: Strict administrative rules and legal data use agreements govern how data is handled, ensuring that only the minimum amount of information necessary is used and that all staff follow rigorous privacy standards. 

Data limitations

Based on a Supreme Court decision from 2016, self-insured group insurance plans governed by the Employee Retirement Income Security Act (ERISA) cannot be compelled to participate in healthcare claims data collection.

This had resulted in a loss of commercial claims, now representing about 40% of the commercially insured population in Minnesota. Self-insured employers are encouraged to opt-in to have their TPA voluntarily submit data (Opt-in and Registration Requirements) to the MN APCD on their behalf.  

In addition to limits about commercial claims, the MN APCD does not collect healthcare claims from patients within the Indian Health System, the Veterans Service Administration, Workers Compensation, the Federal Employee Health Benefit Plan, Tricare. The MN APCD also does not hold data about healthcare for the uninsured. 

History of the MN APCD

Minnesota was one of the first states to create an All-Payer Claims Database 
(MN APCD). It began as part of a 2008 bipartisan health reform law signed by Governor Tim Pawlenty. The goal was to make healthcare costs and quality more transparent while expanding insurance coverage and supporting public health.  

The database was originally built for a specific state requirement called “provider peer grouping,” which compared doctors and clinics to see who provided the best value. While this specific program is no longer used, the MN APCD has evolved into a vital tool for much broader research. 

Today, MDH uses this data to: 

• Study health trends: Research variations in healthcare costs, quality, and disease burden across the state. 
• Inform lawmakers: Create legislative and public reports on healthcare spending and affordability. 
• Support public research: Release Public Use Files (PUFs) and dashboards so that outside researchers can analyze healthcare services without seeing any personal patient information. 
• Manage data requests: Provide a formal process for organizations to request specific data sets for approved studies. 

Timeline of the MN APCD