Oct 7 -- The Centers for Medicare & Medicaid Services (CMS), Health and Human Services (HHS) solicits public comments on establishing a National Directory of Healthcare Providers & Services (NDH) that could serve as a “centralized data hub” for healthcare provider, facility, and entity directory information nationwide. Comments must be received at one of the addresses provided below, no later than 5 p.m. on December 6, 2022.
Healthcare directories that contain aggregated information about healthcare providers, facilities, and other entities involved in patient care are crucial resources for consumers and the healthcare industry. Contemporary and comprehensive directories can support a variety of use cases, such as helping consumers choose a provider, comparing health plan networks, auditing network adequacy, and coordinating patients' care.
Today, consumers use provider directories and online searches more than any other resource (such as word-of-mouth or physician referrals) to research healthcare providers. In a 2020 consumer preference report, a majority of the consumers surveyed indicated that the online availability of accurate directory information (address, insurance, specialty, hours, etc.) has affected their decisions when choosing a doctor.
Although these are important resources, the fragmentation of current provider directories requires inefficient, redundant reporting from providers. Directories often contain inaccurate information, rarely support interoperable data exchange or public health reporting, and are overall costly to the healthcare industry. According to one estimate from a provider survey completed in 2019 by the Council for Affordable Quality Healthcare (CAQH), physician practices collectively spend $2.76 billion annually on directory maintenance, which is equivalent to approximately $998.84 per month per practice, or one staff member workday per week.
The CAQH estimated that transitioning directory data collection to a single streamlined platform could save the average physician practice an estimated $4,746 annually, or an approximated $1.1 billion in collective annual savings across the nation. Directory maintenance costs for physician practices vary based on many factors including practice size, the number of payers with which they are contracted, number of practice locations, and importantly, how often and timely they verify or update their information in directories. Furthermore, providers reported that they must submit directory information in various ways, including by fax, credentialing software, provider management and enrollment software, phone, and physical mail. This disjointed system results in barriers to patient care, administrative burden on providers and their staff, and increased cost for the entire healthcare industry.
One driver of inaccuracy is the varying frequencies and levels of detail at which different directories require information. Some track directory information at the practice level, and others include directory information for each physical location. Without processes or internal audits for data accuracy, different practice staff may provide inconsistent information across directories. Administrative complexity and unclear accountability for data accuracy also contributes to data quality and accuracy challenges. Even when payers have legal obligations to maintain an accurate directory, as discussed in section II. of this document, they generally must rely on providers to update the information within their directories and are left with few options if a provider does not do so in a timely manner. This also puts a burden on provider staff, who must update their directory information for an average of 20 different payers per practice.
We believe that CMS may have an opportunity to alleviate some of these burdens and improve the state of provider directories through a CMS-developed and maintained, Application Programming Interface (API)-enabled, national directory. A National Directory of Healthcare Providers & Services (NDH) could serve as a “centralized data hub” for directory and digital contact information containing the most accurate, up-to-date, and validated (that is, data that is verified by CMS against primary sources) data in a publicly accessible index.
An NDH could both streamline existing data across CMS systems and publish information in an easier-to-use format than is available today. More useful public data could help patients find providers, facilitate interoperable provider data exchange, and help payers improve the accuracy of their own directories. We use the term “centralized data hub” to describe the practice of aggregating data from many existing systems into a single location, which is a best practice within any industry, including healthcare. Establishing a “centralized data hub” breaks down technological barriers between various data sets and allows other databases to reference the source of the information without duplicating data. This aggregation and standardization of data could help avoid errors and inaccuracies in directories that reference data in an NDH. CMS could use an NDH as a mechanism to collect and maintain directory information in a standardized, interoperable, and sharable format that allows widespread access while maintaining privacy and security protocols to safeguard access to sensitive information.
To align with national standards for interoperability, an NDH could be built on the standards established by the Office of the National Coordinator for Health Information Technology (ONC) at 45 CFR part 170, subpart B. Specifically, an NDH could use HL7® Fast Healthcare Interoperability Resources (FHIR®) APIs, the latest standard for which is codified at 45 CFR 170.215(a)(1), to enable data exchange. FHIR is a standard for exchanging healthcare information electronically that enables rapid and efficient data transactions through an API.
Systems with different data architecture can use FHIR APIs to exchange health data in a consistent manner, which gives providers, payers, and other relevant entities a fast and secure way to send and receive healthcare data. FHIR is a widely adopted standard that we already require for specific types of health data exchange. We expect ONC to periodically update the standards at 45 CFR part 170, subpart B through notice and comment rulemaking, and an NDH could use the most up-to-date standards, as appropriate.
ONC and the Federal Health Architecture (FHA), a former federal agency collaboration created to enhance interoperability among federal health information technology (IT) systems, developed the Validated Healthcare Directory (VHDir) FHIR Implementation Guide (IG), which describes the technical design considerations for collecting, validating, verifying, and exchanging data from a central source of provider data using FHIR standards. That IG is currently a “standard for trial use,” meaning it has been deemed “ready to implement” by the sponsoring work group, but there has not yet been significant implementation experience. Testing and development processes are ongoing toward establishing the IG as a normative standard through the American National Standards Institute (ANSI)-approved process. CMS will continue to monitor and work with the appropriate standards development organizations on this effort.
Previous healthcare directory technical efforts, described in section II. of this document, have identified CMS as the appropriate owner of a validated directory, such as an NDH.
We agree that CMS, with collaborative input from industry and federal partners, is positioned to develop an NDH in a manner that serves all stakeholders, builds and maintains trust in the data, advances public health goals, improves data exchange, streamlines administrative processes, and promotes interoperability.
Through this RFI, we seek input on the current state of healthcare provider directories and steps that we could or should take if CMS concludes that adequate legal authority exists to establish an NDH and proceeds to do so.
We believe a modern healthcare provider directory should serve multiple purposes for end users. In addition to helping patients locate providers that meet their individual needs and preferences, a modern healthcare directory should enable healthcare providers, payers, and others involved in patient care to identify one another's digital contact information, also referred to as digital endpoints, for interoperable electronic data exchange. We are collecting feedback from the public regarding the topics and questions in the discussion that follows. We pose questions throughout this document; a response to every question is not required in order to submit comments.
Press release: https://www.cms.gov/newsroom/press-releases/cms-asks-public-input-establishing-first-national-directory-health-care-providers-and-services