By Lee Spangler
Executive Director, TX-APCD

Introduction

The Texas All Payor Claims Database (TX-APCD) is an initiative intended to increase transparency in health care, support research, and inform policy decisions. Administered by the Center for Health Care Data at the UTHealth Houston School of Public Health, the TX-APCD compiles extensive medical, pharmacy, dental, eligibility, and provider data from health-benefit plan payors. By bringing together data on care utilization, delivery, and cost patterns across Texas, the TX-APCD serves as a vital resource for policymakers, researchers, and public-health professionals who seek to improve the quality, affordability, and accessibility of health care in the state.

Understanding the TX-APCD

The TX-APCD and the Center for Health Care Data are not part of the health-care delivery system. Neither provides treatment, creates medical records, or engages in billing or claims adjudication. Instead, The Center and TX-APCD operate as neutral data stewards whose function is to collect, organize, and analyze health-care claims information in a standardized, secure format.

The term “All Payor Claims Database” (APCD) is used intentionally and is not a misnomer. An APCD is a data repository that receives data from as many payors as state law allows. “Nationwide, approximately 25 states currently operate or are developing mandatory APCDs — a reflection of the growing importance of comprehensive health-care data infrastructure.”

However, federal law and a United States Supreme Court decision places limits on state authority. Under the Employee Retirement Income Security Act (ERISA), states cannot compel self-funded employer health-benefit plans to report their data to an APCD. Consequently, while the TX-APCD includes commercial insurers, Medicare Advantage plans, Medicaid managed-care organizations, and dental and behavioral-health plans, participation by self-funded plans remains voluntary. Federal programs such as the Veterans Health Administration and the Indian Health Service are likewise beyond state regulation and therefore, that data is not in the database. And, just as important to note, the provision of care, such as charity care or care for the uninsured that does not generate a claim to a third-party payor is also absent from the database.

Despite these exclusions, the TX-APCD is a robust and comprehensive dataset. From 2019 through the present, it has captured health-care information for more than 20.8 million Texans. In 2023 alone, it included approximately 13.4 million individuals covered by commercial and Medicare Advantage plans, and 4.8 million by Medicaid. The Center also has information on 2.6 million Texans in Medicare Fee-for-Service through a CMS program (which has slightly differing requirements from the TX-APCD) for researchers be interested in that separate dataset.

Purpose

The TX-APCD serves multiple complementary purposes. As briefly mentioned earlier, it enhances transparency in the cost and quality of care; supports evidence-based policymaking by offering lawmakers a clearer view of utilization and spending; enables qualified researchers to identify opportunities for improving population health and reducing costs; and empowers the public by providing access to meaningful, comprehensible information about Texas’s health-care system.

Contents of the Database

The TX-APCD receives multiple categories of data. Monthly submissions from payors include medical, pharmacy, and dental claims, along with eligibility and provider files. Medical claims capture diagnostic and procedural information, provider details, and payment amounts. Pharmacy claims document prescription fills, drug classifications, dosages, and dispensing information. Dental claims record procedures and services related to oral health.

Eligibility files identify who is covered under a plan for each month, while provider files list the practitioners and facilities that deliver or contract for care. These files use standardized coding conventions — such as ICD-10 for diagnoses, CPT/HCPCS for procedures, and DRG codes for inpatient services — along with national provider identifiers and financial details, such as the provider’s billed charge and the payor allowed amount. Payors were required to submit historical data dating back to January 1, 2019, and now continue submitting new data on a monthly basis.

The Common Data Layout (CDL)

At the heart of the TX-APCD’s data-submission process lies the Common Data Layout (CDL), a standardized specification that defines the structure, content, and formatting of every file that payors must submit. The CDL was developed through collaboration between the APCD Council, which created the APCD-CDL, and many state APCD members, to promote uniform data collection across states.

The CDL provides a detailed framework for data fields, permissible values, file formats, and transmission protocols. It establishes standardized layouts for the eligibility, medical, pharmacy, dental, and provider files submitted by payors, and it introduces a consistent header and trailer structure that allows automated validation of each submission.

The CDL plays an essential role in harmonizing data received from multiple payors. By enforcing uniform definitions and file structures, it reduces duplication and inconsistency, simplifies data ingestion, and, most importantly, ensures that information can be compared and analyzed across insurers. It also provides a mechanism for version control and periodic updates, requiring payors to transition to new CDL versions within defined time frames. As a result, the CDL ensures that Texas’s data submissions remain interoperable with national standards and analytically reliable over time.

Limitations of the Data

While the TX-APCD is a powerful analytic tool, it does have certain limitations. The database does not contain clinical information such as laboratory results, imaging values, or patient vital signs. Demographic information such as race and ethnicity is also often incomplete or absent, as payors seldom collect this information in their regular administrative processes. Relationships within households — for example, connections between spouses or dependent children — are also not consistently documented across all plans.

The TX-APCD also lacks financial information about insurance premium payments and uncovered out-of-pocket spending on over-the-counter medications or unclaimed prescriptions, since those transactions never appear on claims forms. Nonetheless, the TX-APCD offers a very comprehensive view into health-care transactions occurring in Texas.

Restricted Access for Research and Public Use

Access to TX-APCD data is governed by statute and strict data-use protocols. Two types of entities may obtain data for research: the Center for Health Care Data itself and Qualified Research Entities (QREs). A QRE may be a federally tax-exempt organization under Section 501(c)(3) engaged in public-interest health-care research; an institution of higher education conducting such research; or a licensed Texas health-care provider engaged in efforts to improve quality and reduce costs.

Researchers requesting data must design their projects carefully. Each request must define a target population, articulate inclusion and exclusion criteria, specify relevant outcomes or events, and determine appropriate time frames for analysis. Because claims data can be voluminous and complex, investigators must thoughtfully select the diagnostic, procedural, and pharmaceutical codes needed for their work. The Center provides some guidance on data structure and access procedures but relies on researchers’ subject-matter expertise to design their project and interpret the data responsibly and accurately. If a researcher or stakeholder prefers, the Center may engage in research on their behalf through a service contract.

In addition to restricted research access, the TX-APCD is developing a public access portal to produce “statewide, regional, and GeoZip consumer reports available through [a] public access portal.” Through this interface, to be developed next year, users will be able to explore statewide and regional reports addressing costs, utilization, quality, outcomes, and access to care.

To date, access to the TX-APCD has been limited to the Center for Health Care Data’s internal team, which has used the database to validate its structure and develop analytic tools. However, the TX-APCD is entering an exciting new phase. Beginning in January 2026, the CHCD will start accepting applications from QREs seeking access to the database. Approved entities will have access to the data in March 2026, marking a major milestone in making this resource available for public-interest research. 

The funding provided by the Texas Legislature in 2025 was critical to sustaining and expanding the TX-APCD’s operations. These resources enable the Center to maintain a highly skilled team of statisticians, data architects, and database administrators, ensuring the integrity and usability of the data. Legislative support also covers essential infrastructure, including hardware for the database and licenses for specialized software and intellectual property, such as the American Medical Association’s CPT codes and the American Dental Association’s CDT codes. Without this funding, the APCD could not meet its statutory obligations, such as the development of the public access portal, or deliver the robust analytic capabilities that policymakers and researchers expect of us at the CHCD.

Conclusion

The Texas All Payor Claims Database represents a transformative effort to use administrative data for the public good. By aggregating claims and eligibility records from diverse payors into a single, standardized system, it enables unprecedented insight into health-care utilization, cost, and access across the state. The Common Data Layout ensures that these data are consistent, comparable, and analytically sound. Although the TX-APCD does not capture every element of care, its scope and structure make it one of the most valuable tools for advancing evidence-based health-care policy, supporting population-health research, and promoting transparency in Texas.

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