Build the claims, payment & data systems

Months 0–18, then continuous · UHA Chief Information Officer; MACs; U.S. Digital ServiceDiscuss this step

Every concrete action this step requires, who is responsible, and when it happens relative to enactment.

#	Action	Owner	When	Trade-off
1.3.1	Inventory Medicare's Fiscal Intermediary Shared System (FISS), Multi-Carrier System (MCS), Common Working File (CWF), and the DME system; decide extend-vs-replace for each.	UHA CIO	Month 0–3	Extending Medicare's legacy systems is faster than a rebuild but carries decades-old technical debt.
1.3.2	Expand MAC capacity: re-compete MAC contracts for 10 regions sized to the full population.	UHA	Month 3–12	Re-competing MAC contracts brings in capacity but risks disruption if new contractors underperform.
1.3.3	Add claim types: dental (ADA CDT codes), vision, hearing, and home- and community-based services.	UHA / MACs	Month 3–15	Adding dental and vision claim types extends coverage but requires new coding standards most Medicare contractors haven't processed.
1.3.4	Build a real-time eligibility API so any provider can check coverage in under 1 second (replacing 270/271 transactions with hundreds of payers).	USDS / UHA	Month 3–12	A real-time eligibility API removes front-desk verification but creates a single point of failure for every check-in in the country.
1.3.5	Build hospital global-budget payment rails: bi-weekly fixed payments plus encounter data submission for quality and planning.	UHA	Month 6–15	Fixed bi-weekly hospital payments stabilize cash flow but weaken the claims-level detail used to catch errors.
1.3.6	Run parallel testing: process 3 months of real Medicare claims through the new system and compare.	UHA / independent verifier	Month 12–17	Three months of parallel testing reduces launch risk but delays go-live if problems appear.
1.3.7	Set up a load-test and go/no-go gate with an independent verification contractor (lesson from HealthCare.gov).	UHA / GAO observer	Month 15–18	An independent go/no-go gate prevents a HealthCare.gov-style failure but may postpone coverage politically promised for a date.
1.3.8	Retire payer-specific claim edits: one national set of coding edits (NCCI) published openly.	UHA	Month 18	One public set of coding edits ends payer-specific denials but makes the edits a target for providers seeking to game them.