CMS National Healthcare Directory RFI Blog Series: Provider Response
By Justin Sims
In November, CMS published a Request for Information (RFI) asking the industry whether they should build a National Directory of Healthcare Providers and Services (NDH).
This series of articles summarizes feedback from different segments of the healthcare industry—our second post focuses on responses from healthcare providers and their associations, for whom directory challenges are a daily headache.
Talk about opposite ends of the spectrum! In our first blog about the CMS RFI, we overwhelmingly noted that payers want a centralized provider directory. They support penalties on providers that don’t maintain their information. And they want “safe harbor” from penalties when they rely on data from that centralized hub.
Healthcare providers, and the associations that support them, saw things differently—except for one significant but unique group.
All four fully integrated health systems that responded (Cleveland Clinic, Mayo Clinic, UPenn Health System, and Intermountain Healthcare) supported the initiative. Not only were they all for a centralized hub, but they were also willing to take responsibility for maintaining the data for their employed physicians. But that should be relatively easy for them since the vast majority of their physicians practice only for their organization. This would make collating the data more straightforward, and they have large IT organizations to automate the process.
Most of the other respondents, while supportive of the goals of an NDH, were more skeptical about whether CMS could pull it off. They noted numerous considerations, were generally concerned that this could become another administrative burden and were dead-set against provider penalties.
Of primary concern was whether this would increase or reduce the amount of work they have to do in updating directories. Several pointed out that a typical provider currently has to update NPPES, PECOS, CAQH, State systems, and an average of 20 payer directories. Utopia would be that they have to update data in one place, but only some believed this was practical.
How would organizations outside CMS’s regulatory purview (such as commercial health plans) be compelled to drop their information requests and use the centralized hub?
How would a centralized directory support all of the unique needs of payers and stop them from writing the obligation to provide additional information into their provider contracts?
Why would this centralized system be any more accurate than other centralized systems like PECOS? As the American Medical Association pointed out, “24-36% of location data erodes each year,” so updates become the primary challenge.
Then there were some less obvious points raised in the provider comments:
Physicians in certain specialties (like OBGYNs and those involved in family planning) had safety concerns about a public directory
Physicians that welcome LGBTQ+ patients or advertised particular languages (like Arabic) were concerned about being exposed to abuse
Providers and their staff generally don’t know and understand what some of the requested information is - like “digital endpoints”
Physicians frequently work for multiple organizations, so how should updates be handled and what happens when information from different organizations conflicts?
Of course, physicians are problem solvers, so they also made many recommendations. Here are some that were frequently mentioned:
Legislation should be pursued to give CMS the authority to require participation by payers and providers alike, such that this directory would become a single source of truth
As a first step, CMS should consolidate enrollment in, and data from, other government systems (including Medicare, Medicaid, and State Licensing systems)
CMS should leverage and support existing industry initiatives vs. build something new
The complexity of organization affiliations means that CMS should set a standard for defining organizations and what constitutes an affiliation
Health technology vendors are in the strongest position to structure, submit and consume directory data and therefore, CMS should use its influence on them to participate in any solution
And finally, on the subject of incentives and penalties, most welcomed neither. Providers already have too many “incentives” to juggle, and history has shown that an incentive one year becomes a “compliance stick” the next.
We’d love your feedback —send us an email anytime.
Justin
