CareSet Responds to Federal RFI for new National Directory of Healthcare Providers & Services: Calls for Agile Open Source Project.
CareSet Submits Eight Technical Strategies to help improve the National Directory of Healthcare Providers & Services (NDH).
The federal government recently asked the public for input on a new “National Directory of Healthcare Providers & Services (NDH) that could serve as a ‘centralized data hub’ for healthcare provider, facility, and entity directory information nationwide”. CareSet provided technical strategies in response to the RFI, and called for NDH to be an agile open source project to allow for public governance.?
The COVID crisis revealed how critical it is to have a reliable national provider directory resource. The National Plan and Provider Enumeration System (NPPES), along with other existing provider directories, failed to provide an actionable hospital list to the White House for the COVID crisis. Having an accurate provider directory would have helped the federal government more quickly understand where COVID relief support was needed.?
NPPES data is the most relied-upon national provider directory, and it is used in countless ways by healthcare providers, plans, researchers, companies, and government agencies. CareSet’s research and commercial work also relies on NPPES, as we combine its data with Medicare claims data to map patient diagnoses, demographics, medical procedures, and hospital charges. As new therapeutics are produced, bringing them to the right population requires our map of the healthcare system to be built on accurate data.?
Unfortunately, NPPES has glaring issues with data accuracy and transparency - and implementing a new system will not fix this fundamental issue.? This is an old problem, and CMS has been aware of the underlying issue since at least 2013.?
Imagine that you are a daycare owner with a bus. You use this bus to take kids on field trips. Like most kids, keeping the bus clean and orderly is not their first priority. Over time, the bus begins to accumulate filth. Instead of correcting the problem and implementing cleanliness rules – you go out and buy a new bus. But it doesn't take long for the bus to begin facing the same problems as the old one. If a new system is proposed to fix a problem without the proper rules in place, it is destined to end up like the old one.
In addition, there are several provider directories in our healthcare system that can have both overlapping and distinct purposes. This multiplicity of directories for interoperability, insurance coverage, and credentialing are often filled with inaccurate and useless data. They fail in their purpose to paint a clear picture of the healthcare system, and also require many hours of duplicative entry from providers. The work Centers for Medicare and Medicaid Services (CMS) is doing to improve this situation will impact every patient who lives in or seeks treatment in the United States, and has the potential to create a safer and better organized healthcare system.
This is why CareSet has provided comments to this RFI, along with other members of the community, including providers, patients, payers, health tech vendors, state and local government, health information exchanges, and healthcare trade associations.
In its comments CareSet emphasizes that CMS must first understand and face the challenges with NPPES before it can successfully make a new provider directory, with the following key points provided below:
1. ? ? ? Clear Leadership – from the outside, it is unclear who at CMS is responsible for the quality of data in provider directories. This responsibility should be bestowed upon one person who reports directly to the CMS CTO.
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2. ? ? ? Data Validation – the validation of provider data should be an ongoing process with public accountability.
3. ? ? ? Data Transparency – data should not be withheld from public view unless it is truly private information. All data should be open by default.
4. ? ? ? Accept and Reward Data Quality Feedback – the directory needs to include mechanisms to report incorrect data and triage data repair requests.
5. ? ? ? Improve Data Entry UX and Enforce Data Update Responsibilities – provider information should be gathered passively wherever possible, reducing manual work for individual providers with data entry UX as a priority. There should also be disincentives in place by CMS for providers who do not maintain accurate information.
6. ? ? ? Fully Support the Directory Functions – the directory should avoid half-measures for the functions that it provides users, and decide what it will support and what it will not support. If data gathering is a goal, it should be fully validated, support a given use case, and be functional.
7. ? ? ? Support Provider Affiliation – the directory should gather and publish group affiliation and provider-organization hierarchy data.
8. ? ? ? Run the New Directory as an Agile Open Source Project. The traditional NPPES system was created using a closed-style waterfall process. However, using an Open Source hosting organization allows for public governance of the directory.
Additional comments to the RIF were received from providers, patients, payers, health tech vendors and consulting, state and local government, health information networks/exchanges, and other associations. Based on Defacto Health’s summarization of the comments (over 600 responses were received), it was clear that all of the segments were in agreement on the objectives of increasing transparency for patients and reducing provider burden – but most are skeptical about the directory’s ability to achieve it. There was also a consensus that many segments wonder whether CMS has the authority to make the directory a true one-stop shop for all lines of business for provider data.
As CMS reviews and considers all of the comments received from the RFI – CareSet will continue to provide updates and considerations on the new directory.