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Implementing No Surprises Act and Transparency Legislation with Human-Centered Design Research and Recommendations

We partnered with the Centers for Medicare & Medicaid Services Center for Consumer Information and Insurance Oversight to review their current systems and processes and provide recommendations to improve the public’s customer experience.

The Challenge: Identify Technical and Business Process Improvements to Support New Policy Changes

Client Name(s):
Centers for Medicare & Medicaid Services Center for Consumer Information and Insurance Oversight
Partner Name(s):
BlueLabs; Deeptree, Inc.
Delivery Date:
January 2023

The Centers for Medicare & Medicaid Services (CMS) Center for Consumer Information and Insurance Oversight (CCIIO) needed to evaluate their technical applications and processes to deliver a better customer experience as mandated by recent healthcare transparency legislation.

CMS is required to fulfill provisions in the No Surprises Act of 2020 and the Consolidated Appropriations Act of 2021 to help improve patient access to healthcare. To do this, CMS’s CCIIO division needed to build several technological interfaces to tie front-end web forms and portals to back-end customer relationship management systems (CRMs).

Team Coforma provided human-centered design, research, UX design, technical analyses, and recommendations across seven related workstreams to ensure improved experiences for both the public accessing these forms and portals and for government employees working to process data and provide timely services and resolutions.

Our Approach: Human-Centered Design Research and Technical Analysis

We paired human-centered design research with technical application analysis to deliver a set of recommendations to streamline and improve processes and systems for CMS stakeholders.

For the initial project, team Coforma conducted generative and evaluative research for seven CCIIO workstreams: Patient Provider Dispute Resolution (PPDR), Independent Dispute Resolution (IDR), Gag Clause, Air Ambulance (AA), Agent/Broker, Prescription Drug Data Collection (RxDC), and No Surprises Help Desk (NSHD). To ensure equitable research participation, we met with patients with varying levels of access to healthcare services, medical providers, and individuals from both large and small insurance agencies.

We convened with stakeholders to discuss and prioritize all related work within CCIIO, across projects and contractors. Then, we delivered our recommendations to increase data processing and transparency and improve access to patient services, along with a process to continue to focus on user needs in future work.

After the initial project, CCIIO wanted to apply human-centered design practices internally to understand the current state of their CRM tools, user needs and goals, and possible alternatives to their existing tech stack. For this work, team Coforma engaged with 65 business owners and CMS stakeholders across nine groups in three phases of research. The groups included a customer-facing help desk, individuals working with insurance issuers, policymakers, administrators, and contractors. From this, we delivered research reports, a technical whitepaper, and an editable evaluation framework that CCIIO could use to evaluate future CRM solutions.

Results: 258 Recommendations and Three Reports

Our team supplied prioritized development recommendations for public-facing websites and forms, as well as three robust reports detailing internal goals, opportunities, and an analysis of five CRM alternatives.

A graphic shows blue bold numbers in a 2 by 2 grid representing 73 user stories, 149 UX recommendations, 14 development prototypes, and 14 process flows

Recommendations for Public-Facing Digital Services

For the website and web forms project, Team Coforma delivered 73 user stories, 149 UX recommendations, 14 development prototypes, 14 process flows including journey maps, service blueprints, and user flows, and one cross-workstream user journey. These deliverables, along with key findings and recommendations, provide a pathway for streamlining and improving the data collection, submission, and compliance process for insurance companies, healthcare providers, and CMS stakeholders across workstreams.

An abstraction of user quotes from a research report is displayed in a grid pattern

Unearthing Major Goals

The initial report for the internal project outlined four major goals to improve user experience, streamline operations, determine governance and cost structures, and build a scalable, future-ready solution. The findings helped surface usability issues and short- and long-term paths forward to meet customer and user needs.

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Mapping Alternatives

The second report detailed service blueprints, generating user needs and opportunities to inform future CRM solutions. Opportunities from this report fed directly into an evaluation framework, which the team used to measure and score each CRM alternative approach for the final report.

An abstraction of an evaluation summary and framework in a green table format is displayed

Analyzing CRM Tool Stacks

The final report, presented as a whitepaper, detailed five alternative CRM tool stacks, considering cost, security, integration, accessibility, usability, and more, with a comprehensive design analysis of features and functionality. An executive summary provided condensed recommendations and links to guide readers to topics of interest, while the full report detailed 293 findings and 109 recommendations for improving the approach to CRM tools at CCIIO.

The team also shared supplemental materials with the final report: a cost model, an evaluation framework, a heuristics evaluation, and all findings surfaced through design research. As living documents that CCIIO can adjust for changing priorities, the cost model and evaluation framework can have a particularly long-lasting impact.

Project Team

  • EmmaEmma BosleyProject Manager
  • JaneJane Park StormResearch Lead
  • RickRick AllenContent Lead
  • ArdenArden KlemmerDelivery Lead
  • AnnAnn BuechnerContent Designer
  • JulieJulie PedtkeResearcher
  • DanielaDaniela JonesResearcher
  • NicholeNichole NicholasResearcher
  • AndrewAndrew BergeronUX Designer
  • KristinKristin Ouellette MuskatResearcher
  • JohannaJohanna OstrichProduct Designer
  • MalekMalek DeebCRM Specialist
  • CoformaCoforma StaffBusiness Strategist
  • AziriaAziria RodriguezResearcher
  • RosemaryRosemary RogersResearcher
  • KimberlyKimberly NunlistTechnical Writer


  • Google Suite, Microsoft 365 Online, and Box for project organization, trackers, note taking, planning, and presentations

  • Slack for continuous asynchronous communication

  • for biweekly status reports

  • Mural for planning, note taking, synthesis, workshops, and presentations

  • Calendly and Google Calendar for recruitment and participant interview scheduling

  • Adobe InDesign for report design

  • Dovetail for research data synthesis

  • Jira for user stories and UX recommendations

  • Confluence for task prioritization and management

  • Zoom for synchronous remote meetings with clients, collaborators, and user interviews

  • Guru for research knowledge sharing


  • Human-centered design research

  • User and stakeholder workshops, interviews, and subject-matter expert (SME) validation sessions

  • Usability testing

  • Survey of consumer touchpoints

  • Working sessions with business owners and the Application Development Organization

  • Scrum framework for agile delivery of project deliverables

  • Weekly touch base and monthly health checks