AHA Letter to CMS on Establishment of a National Directory of Health Care Providers and Services (NDH)

AHA Letter to CMS on Establishment of a National Directory of Health Care Providers and Services (NDH)Re: CMS-0058-NC, Request for Information; Directory of Healthcare Providers & Services, vol. 87, October 7, 2022

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations and our clinician partners — including more than 270,000 affiliated physicians, two million nurses, and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to provide comments in response to the Centers for Medicare & Medicaid Services’ (CMS) Request for Information (RFI) regarding the establishment of a national directory of health care providers and services (NDH). As discussed in the RFI, the NDH would serve as a publicly accessible centralized data hub for health care providers, facilities, and entity directory information. It is envisioned that the NDH would help patients navigate health plan networks and facilitate health information exchange and public health data reporting to advance equity goals.

The AHA shares CMS’ goals to improve patient access to provider information and to facilitate health information exchange and data reporting. We appreciate the commitment CMS has invested in striving to meet these objectives. However, we are concerned that adding one more provider directory requirement will not support patients in accessing the information they need about their care providers. In fact, adding an additional data source without sufficiently addressing how or why it differs from the myriad provider directories already in existence could further complicate patients’ ability to access accurate information. Meanwhile, such a requirement would add considerable, duplicative burden on providers. Additionally, we have significant reservations about the current state of readiness of the essential technology needed for a centralized data hub such as the NDH. As such, while we support CMS’ objectives, we strongly encourage the agency to refrain from moving forward with the NDH at this time.

CMS suggests that a centralized data hub such as the NDH could be used to assist patients, providers and plans in a number of ways. These include:

While CMS asserts that the NDH would alleviate burden for providers, the agency does not adequately address how or why the NDH would improve upon the myriad data sets that already collect provider information. Further, CMS suggests that the NDH would exist alongside these other data sets and not replace them. For example, in the RFI, CMS describes two federal data systems that collect provider information, namely the National Plan and Provider Enumeration System (NPPES), which supplies the National Provider Identifier (NPI) to health care providers, and the Medicare Provider Enrollment, Chain, and Ownership System (PECOS), which providers and suppliers use to validate their Medicare enrollment and revalidation process. In addition, CMS catalogs other provider and health plan reporting requirements within CMS programs, such as Medicare Advantage, Medicaid and Children’s Health Insurance Program managed care plans, and the Marketplace Qualified Health Plans. However, in the RFI, CMS fails to fully recognize other sources of government-collected provider information, such as state licensing board data, or data collected by insurers and third-party administrators of commercial and self-funded health plans.

Providers already submit a significant amount of data and information for various government and private databases, and it is unclear what the role of the NDH would be vis-à-vis these existing data sets or whether this data collection would offset any of the others. In addition, CMS fails to fully address how the quality of the NDH data would be an improvement over these existing data systems which have, admittedly, been plagued with inaccuracies. The success of the NDH would depend on providers submitting and validating information that meets the required data submission standards, including verifying the accuracy of the data. And yet, this is the same process used by the many versions of provider directories that exist today.

While CMS may be hoping for improved technology and data standards to assist in the accuracy of the data, those tools are far from ready. CMS points to using the HL7 Fast Healthcare Interoperability Resources (FHIR)-based Application Programming Interface (API) as the key to managing the provider and facility directory information. However, the Office of the National Health Coordinator (ONC) and the Federal Health Architecture (FHA) have been working since 2016 to define the underlying architecture for a national provider directory using FHIR but have not yet completed their work. As a result, CMS acknowledges that an API-enabled NDH remains conceptual and has yet to be tested for broad-scale implementation.

The AHA firmly believes that CMS should not proceed with implementing an NDH until there is greater clarity on how it will fit in among the other existing provider information data sets, especially with respect to how patients will know when to rely on the NDH versus their health plan’s provider directory. We also urge that CMS first address how the NDH can reduce — not contribute to — provider reporting burden and ensure adequate testing and standardization regarding health information and data transmission.Again, we appreciate CMS’ focus on improving patients’ access to accurate information about their health care providers; however, we urge that CMS carefully reconsider this proposal given the lack of clarity around objectives, need for further consideration about the additional burden it will place on providers, and the lack of technological readiness.