AHA Asks CMS to Halt National Healthcare Provider Directory Operation

The American Hospital Association (AHA) detailed several concerns and requested that CMS not proceed with the proposed national healthcare provider directory, the trade group said in a public comment on the pitch.

Earlier this month, CMS published an RFI on establishing the first national directory of healthcare providers and services (NDH) that could serve as a data hub for healthcare providers, facilities, and entities nationwide.

Although patients already use provider directories to locate and research healthcare providers, the fragmentation of current provider directories leads to inaccurate reporting.

CMS said the NDH would help patients navigate health plan networks and facilitate health information exchange and public health data reporting to advance equity goals.

While AHA agreed with advancing patient access to provider information, the hospital group showed apprehension about the additional provider directory requirements associated with the NDH.

CMS stated that the NDH would not replace but exist in conjunction with other data sets, including the National Plan and Provider Enumeration System (NPPES) and the Medicare Provider Enrollment, Chain, and Ownership System (PECOS).

Alongside these data sets, CMS holds 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.

In the letter, AHA cited uncertainty regarding how the proposed NDH differed from the myriad of existing provider directories.

“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 other,” AHA wrote. “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.”

CMS said that the NDH provides an opportunity to alleviate provider burdens and improve the state of provider directories.

At present, the success of the NDH would be contingent on provider reporting and submitting information to required data submission standards, a similar process used by the many existing provider directories, AHA stated.

Contrary to the intent of the NDH, AHA said additional reporting requirements would add a substantial duplicative burden on providers.

“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,” AMA affirmed. “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.”

AHA also voiced reservations concerning the readiness of essential technology needed for the NDH.

In the RFI, CMS mentioned leveraging the HL7 Fast Healthcare Interoperability Resources (FHIR)-based Application Programming Interface (API) to facilitate data exchange. However, API-enabled NDH remains conceptual and has not been tested for broad-scale implementation, AHA wrote.

Finally, AHA advised CMS to consider implementing health equity goals through demographic data collection, ensuring the NDH provides definitions and health equity standards.

“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,” the letter stated. “The AHA is pleased to be a resource on these issues and would welcome the opportunity to provide any additional information that would be helpful to the agency in its policy development.”