Sequence of characters representing a physical place of available services or resources.
Submitted By: Keith W. Boone
/ Audacious Inquiry
Data Element Information
Use Case Description(s)
Use Case Description
Facility level data is associated with laboratory tests (the testing facility), and health care provider locations, including hospitals, ambulatory providers, long-term and post acute care, and pharmacy providers.
Location data is used to support reporting of data for public health and emergency response (e.g., situation awareness reporting).
See https://build.fhir.org/ig/HL7/fhir-saner/ for details (note that (minus) - is a legal character in URLs, had to use a bit.ly link to get past validation errors in URL)
Estimate the breadth of applicability of the use case(s) for this data element
Hospitals in the US (Approximately 7000), Laboratories (260,000), pharmacies (88,000), ambulatory physicians (260,000).
5 or more. This data element has been tested at scale between multiple different production environments to support the majority of anticipated stakeholders.
Restrictions on Standardization (e.g. proprietary code)
None
Restrictions on Use (e.g. licensing, user fees)
None
Privacy and Security Concerns
Locations associated with Critical Access Hospitals, and single provider facilities may constitute PHI (in geographic locations with limited populations) and/or Individual Identifiable Information (e.g., for HCPs working from a combined home/office facility).
Estimate of Overall Burden
Most electronic systems provide the capacity to store location and organization information. Many EHRs already provide access to the Location resource via READ operations, some (e.g., Epic, AthentaHealth) provide search capabilities as well. This information is routinely communicated in HL7 V2 Messages, CDA Documents and some FHIR API transactions. To address gaps, implementers would need to modify interfaces (e.g., for CDA or HL7 V2), or add an endpoint. Estimated effort (based on past experience building EHR systems) is about one two-week sprint to implement the capability by a developer.
Other Implementation Challenges
Standards for location identifier may need flexibility depending on use of Location for reportiong, as there are a number of distinct location identifier systems which may be necessary for different reporting use cases. For example, CDC/NHSN assigns identifiers for HAI reporting, CLIA assigns identifiers to laboratories, CMS provides location identifiers, et cetera.
CMS-CCSQ is pleased to see that Facility Identifier data element was added to USCDI v4. However, we recommend that the Facility Identifier data element be limited to capturing an individual facility instead of an organization or health system (with multiple facilities). We also recommend the NHSN OrgID be added to the Facility Identifier data element in addition to existing standards to capture individual facilities. This recommendation is a slight change from the CMS-CDC recommendation for draft USCDI v4 where NHSN OrgID was recommended under the Organization/Hospital Identifier. Additional discussion amongst CMS and CDC concluded that NHSN OrgID can more adequately capture an individual hospital or individual facility and that the CCN, which is currently in the Facility Identifier data element, is more appropriate as an organizational identifier.
NCPDP supports the use of the Type 2 NPI and recommends this to be added to the data elements. NCPDP recommends adding the following NCPDP SCRIPT Standard v2017071, NCPDP Specialized Standard v2017071 and NCPDP Telecommunication Standard Version D.0 as “Applicable Standard(s)”.
CAP Comment: The College of American Pathologists (CAP) supports this data element and finds that this element can capture the necessary information about Laboratory Address and Location. The CAP recommends that this data element should include identifier information number for facilities. If the facility type is a medical laboratory then a CLIA number should be used to unambiguously identify the laboratory.
Shared priority for CDC, CMS, and ASPR (via all hazards work with CDC)
Facility Identifier is necessary for measuring care delivered to inpatients and properly attributing that care. Facility identifier is critical for providing context for granular patient data and supports tracking data back to organizations, which ensures usability of interoperable clinical data. They can also support exchange of data between hospitals and post-acute care providers. All these activities are necessary for providing high quality care to patients, reducing healthcare inequities and disparities, and promoting interoperability and communication – all ONC stated priorities for the USCDI.
Facility identifiers have been identified as a joint CMS-CDC priority that are critical elements for public health reporting, surveillance, and emergency response (also ONC stated priority for USCDI v4).
CCN, PTAN, NPI, NHSN OrgID, and CLIA numbers are exchanged across the nation for CMS reporting to appropriately attribute outcomes and measure results. Organization identifiers are also used to support public health use cases, including electronic case reporting and emergency response activities proving applicability across multiple use cases. Accurate facility identifiers are essential to analyze facility level data and inform the allocation of resources such as therapeutics, supplies, staffing, and PPE to prepare for and respond to emergency events.
Facility names and addresses can be duplicative, so unique facility identifiers are critical to link facility-level primary key to link HAI data collected in NHSN to facility-level COVID-19 hospitalization data collected through the Unified Hospital Data Surveillance System. Linking these data systems is crucial for understanding the impact of COVID-19 on patient safety and other healthcare measures
The ISWG recommended this element for final USCDI v3, and received HITAC support, noting the need for an identifier combined with an assigning authority
Additional use cases:
COVID-19 hospital reporting
All hazards reporting
HAI
Patient safety quality measurement and public health surveillance via NHSN
Comments from NACCHO: NACCHO supports the inclusion of this data element; NACCHO recommends specifying which facility identifier should be used. Facilities could use multiple identifiers depending on the EHR system. A standard identifier should be used in this data element. Otherwise, an additional element should be added in Facility Information that indicates what identifier is used
Comments from CSTE: CSTE agrees with CDC's recommendation for this data element.
A facility, or organizational, identifier is critical for providing context for granular patient data and supports tracking data back to organizations—this type of contextual data element ensures usability of interoperable clinical data. Facility identifiers are used for billing, support data aggregation across sources, as well as attribution. They can also support exchange of data between hospitals and post-acute care providers. All of these activities are necessary for providing high quality care to patients, reducing healthcare inequities and disparities, and promoting interoperability and communication – all ONC stated priorities for the USCDI. Facility identifiers were also previously identified as a joint CMS-Centers for Disease Control and Prevention (CDC) priority as a critical element for public health reporting, surveillance and emergency response – an ONC stated priority for USCDI v4. For example, CDC and CMS rely on facility identifiers to measure the incidence of healthcare associated infections and other patient safety events in facilities, and to direct technical assistance and quality improvement support to underperforming facilities. Furthermore, the ISWG recommended this element for final USCDI v3, and received HITAC support, noting the need for an identifier combined with an assigning authority.
Maturity: This element is classified as Level 2 by ONC and continues to have strong standardization and be in wide use.
Current uses, exchange, and use cases: CCN, PTAN, NPI, and CLIA numbers are exchanged across the nation for CMS reporting to appropriately attribute outcomes and measure results. They are used extensively for electronic clinical quality measure (eCQM) reporting, linking data sources for quality measurement, and for post-acute care reporting and payment purposes. Facility identifiers are also used extensively for electronic case reporting (eCR) and electronic lab reporting (ELR) and are critical for public health agencies ability to monitor the spread of reportable conditions. Exchange of organization identifiers supports facility-specific quality, prior authorization activities, and other assessments that are limited without this information. Additionally, there is active work underway to create an IG for healthcare directories (HL7.FHIR.US.DIRECTORY-EXCHANGE\Home - FHIR v4.0.1) as part of the FAST Da Vinci accelerator initiative, which includes the critical organization and provider identifiers necessary to appropriately use and attribute exchanged data. Among other purposes, organization identifiers are also used to support public health use cases, including electronic case reporting and emergency response activities. For instance, during the early COVID-19 pandemic phase, there was insufficient data tracking across organizations, further complicated by the need to track emergency response resources across individual facilities. Exchange of facility/organization identifiers can mitigate such delays in emergency response activities.
We support the CMS comment ‘CMS-CCSQ Support for Facility/Organization Identifier: USCDIv3’ on 2022-03-22 that Facility/Organization Identifiers are critical component of EHR for providing high quality care to patients, reducing disparities, SDOH data analysis, promoting interoperability and data aggregation. HIPAA requires that health care providers have standard NPI that identify them on all standard transactions. We recommend adding the ‘Facility/Organization Identifiers’ to USCDI data classes. We suggest the following definition of this data class: ‘Facility/Organization Identifiers in EHRs are standardized codes, names and other attributes that provide a unique data pointer to a healthcare facility/organization where patient’s care has occurred.’
We found a similar concept description in the Level 2 under the ‘Facility Level Data’. Because a potential ambiguity of the ‘Facility Level Data’ term (i.e., it could mean aggregate level facility data rather than unique identifiers) we strongly suggest replacing it with proposed by CMS title ‘Facility/Organization Identifiers’. Based on the recent experience in management of the COVID-19 EHRs and ONC requirements on EHR aggregation and reporting data for situational awareness, we propose that the following data elements and associated vocabulary standards should be included into the Facility/Organization Identifiers data class:
HHS.gov. Health Information Privacy. Other Administrative Simplification Rules. https://www.hhs.gov/hipaa/for-professionals/other-administration-simplification-rules/index.html
This element is also shared priority for both CDC and CMS as outlined in the joint support letter
Identifiers are critical for billing, linking billing/clinical EHRs, supporting data aggregation across data sources and reducing burden, as well as attribution and tracking of data. All of these activities are necessary for providing high quality care to patients, reducing disparities, promoting interoperability and communicating across silos. Facility identifiers are also critical for public health reporting and tracking, an ONC stated priority for USCDI version 3.
CMS specifically prioritizes exchange of CMS Certification number (CCN), Provider Transaction number (PTAN), and National Provider Identifier (NPI)—unique identifiers for a healthcare organization.
Current uses, exchange, and use cases: CCN, PTAN, and NPI are exchanged across the nation for CMS reporting to appropriately attribute outcomes and measure results. Exchange of these identifiers supports facility-specific quality, prior authorization activities, and other assessments that are limited without this information.
Submitted by pwilson@ncpdp.org on
NCPDP Comments on USCDI draft v5
NCPDP supports the use of the type 2 NPI and recommends this to be added to the data elements.