The First 100 Days: A Launch Plan for the Healthcare Clearing Commission
Pharmacist Write
Spoke 6

The First 100 Days: A Launch Plan for the Healthcare Clearing Commission

This isn’t a 10‑year dream; it’s a 100‑day plan. Assemble the founding circle, lock anchor partnerships, ship a working prototype exchange for insulins and outpatient imaging, and publish the Public Receipt on Day 100.

Why 100 Days

Big visions die in vague timelines. A 100‑day sprint forces focus: prove low‑cost clearing on two high‑variance domains (insulins, outpatient imaging), demonstrate open arbitration, and show that gratitude‑forward UX can coexist with rigor.

Day‑100 deliverable: a public, queryable receipt showing every transaction cleared, every anomaly caught, and the administrative cost—down to the cent.

Founding Circle (The “Who”)

  • Chief Ethicist (AI alignment): owns model audits, bias checks, model cards, red‑team drills.
  • Chief Actuary / Systems Engineer: corridor math, SRV layers, solvency targets, simulation harness.
  • Chief Public Advocate: community standards, transparency policy, member messaging, FOIA‑grade docs.
  • Chief Data Architect (FHIR + Ledger): Node schema, FHIR/X12/NCPDP mapping, conformance, security.

Supplement with 2–3 engineers (API & data), 1 compliance/SOC‑2 lead, and an arbitration coordinator.

Anchor Partnerships (The “Allies”)

  • Academic health‑economics lab: corridor research, bias audits, independent evaluation.
  • State employee plan or large self‑funded employer: pilot venue for insulin + imaging.
  • EHR / claims vendors: mapping support to FHIR/X12/NCPDP; test data plumbing.
  • Imaging center chains + independent pharmacies: high‑variance price domains with willing partners.

Prototype Exchange (The “Proof”)

Stand up a minimal but real clearing rail for insulins (retail/specialty) and outpatient imaging (MRI/CT).

Why these two?

  • High price variance: ample room to capture and document surplus.
  • Clear data structures: NDC/RxCUI for insulins; CPT/HCPCS for imaging; straightforward J‑codes.
  • Simple, explainable cost stacks: easy to show public “how the sausage is made.”

Cost stack we will publish (insulin example)

  • WAC or acquisition basis (contract/NADAC/340B, with provenance)
  • Distributor markup (where applicable)
  • Pharmacy dispense fee/margin
  • Admin fee (if medical route)
  • Final allowed price within corridor (e.g., reference ±15%)

For imaging, add site‑of‑care factor and equipment utilization where relevant.

Day 100: The Public Receipt (The “Symbol”)

An interactive, public page showing:

  • Every transaction cleared with a signed trace (hash) and de‑identified fields.
  • Variance vs. corridor; anomalies and their resolution path.
  • Exact infrastructure cost (e.g., 0.0009 × allowed = $X) and captured surplus buckets.
  • Thank‑You Economics: anonymized notes triggered by cost‑saving choices.

Timeline & Milestones

Days 1–30 · Form the Founding Circle
Hire core four; publish Node schema v0.1; corridor policy draft; governance charter v0.1.

Days 31–60 · Secure Anchor Partnerships
MOUs with plan + partners; data use & BAAs; sandbox with de‑identified claims; arbitration process v0.1.

Days 61–90 · Build the Prototype Exchange
UCL APIs (clear, dispute, corridor); insulin + imaging Nodes; pilot transactions; ethics red‑team; FWA rules v0.1.

Day 100 · Launch the Public Receipt
Go‑live report; open dashboards; publish model cards; fee disclosure; invite replication.

WorkstreamOwnerArtifacts (Day‑100)
UCL APIsData ArchitectPOST /claims/clear, POST /disputes, GET /nodes/{id}/corridor, signed traces
Corridor MathActuaryReference cost sources, float rules, exception logic, bias checks
SRV (pilot)ActuaryTrigger at ≥$50k; solvency target; contribution sketch; quarterly rebalance plan
ArbitrationCoordinatorPublic docket, SLA timers, published decisions
EthicsChief EthicistModel cards, drift monitor, red‑team report
Security/ComplianceCompliance LeadHIPAA risk assessment, SOC‑2 plan, DPIA

Risks & Mitigations

  • Data access lags: mitigate with de‑identified sandbox + synthetic data; parallel legal tracks.
  • Stakeholder pushback: publish fee schedule, conflict policy, and corridor math in plain English; invite observers (shadow seats).
  • Scope creep: two domains only; change‑control board; backlog the rest.
  • Model bias: pre‑launch ethics audit; publish residuals by demographic proxies; add exception pathways.

Practitioner Appendix: Technical Chops

A) Prototype Exchange: Insulins

  • Identifiers: RxCUI ↔ NDC set ↔ (if medical) HCPCS J‑code; device form (pen/vial).
  • Cost stack: acquisition (WAC/NADAC/contract) + distribution + dispense fee/margin + admin fee (if medical) + site‑of‑care factor → corridor‑checked allowed.
  • Member fairness: coinsurance applied to net; late rebates credit members.

B) Prototype Exchange: Outpatient Imaging

  • Identifiers: CPT; modality (MRI/CT); body part; contrast Y/N; site type.
  • Cost stack: technical + professional + facility; equipment utilization; site‑of‑care factor; corridor check.
  • Arbitration: outlier hospital price routes to docket; decision updates corridor next quarter.

C) Public Receipt – required fields

  • Node ID (de‑identified), date, site, allowed vs corridor, member share basis (net), signed hash, anomaly flags + resolution.
  • Infrastructure fee disclosed as basis points and dollars.

D) Security/Privacy

  • Minimum necessary fields; encryption at rest/in transit; audit logs; key rotation.
  • De‑identification for public artifacts; BAAs for partner data; DPIA published.

Next — Spoke 7: Our Safeguards & The Invitation

Need the governance details? Revisit Spoke 5: Governance & Ethics, or return to the HCC Hub.

Join the Founding Circle