Organization

CMS-CCSQ Support for Org./Hospital Identifier for USCDI v5

CMS-CCSQ recommends this data element be moved up to Level 2 from Level 0. We also recommend ONC move CCN from Facility Identifier into the Organization/Hospital Identifier data element, as the CCN identifies organizations and hospital systems, rather than individual facilities. The recommendation is also supported by the Interoperability Standards Work Group (ISWG) and Health Information Technology Advisory Committee (HITAC) recommendations on both the Draft USCDI v3 (April 13, 2022) and Draft USCDI v4 (April 12, 2023). An organizational/hospital 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. They can also support exchange of data between hospitals and post-acute care providers. CMS encourages ONC to consider the advancement of the Organization/Hospital Identifier data element as a complementary data element to Facility Identifier as both are ultimately necessary to support efficient direction of quality improvement efforts and public health. Coupling the facility with an Organization Identifier that is unique to a specific location provides additional information that the providers, payers, and public health need to optimally track and respond to identifiable care quality, patient safety, and health outcomes issues. This remains a joint CMS and Centers for Disease Control and Prevention (CDC) recommendation, with some recent discussions and slight updates from our previous recommendations to USCDI on how to provide a necessary distinction between larger organizations and individual facilities that is currently not being captured in the USCDI. We no longer recommend the NHSN OrgID be added to the Organization/Hospital Identifier data element, but rather the NHSN OrgID be utilized in the Facility Identifier data element, which we discuss in further detail under the Facility Identifier data element. CMS specifically prioritizes exchange of CMS Certification Number (CCN), Provider Transaction Number (PTAN), National Provider Identifier (NPI), and Clinical Laboratory Improvement Amendments (CLIA) number as organization identifiers. These identifiers 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. Among other purposes, organization identifiers are also used to support public health use cases, including electronic case reporting and emergency response activities.

Cntd. CMS-CCSQ Support for Organization Identifier for USCDI v4

CMS encourages ONC to consider the advancement of the Organization Identifier, like the NHSN OrgID, as a complementary data element to Facility Identifier as both are ultimately necessary to support efficient direction of quality improvement efforts and public health. Coupling the facility with an Organization ID that is unique to a specific location provides additional information that the providers, payers, and public health need to optimally track and respond to identifiable care quality, patient safety, and health outcomes issues. We are recommending reclassifying this data element to Level 2 for addition to future versions of USCDI. CMS may also additionally recommend moving the CCN from the currently proposed Facility Information data class to the Organization data class if the Organization/Hospital Identifier data element is supported in version 5.

CMS-CCSQ Support for Organization Identifier for USCDI v4

An 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 standards:
  • Health Level Seven International (HL7) Fast Healthcare Interoperability Resources (FHIR) US Core Implementation Guide (IG) STU3-STU5 based on FHIR R4, Organization Profile must support an identifier (https://www.hl7.org/fhir/us/core/StructureDefinition-us-core-organization.html)
  • Organization Profile is included in the HL7 FHIR US Core Capability Statement: https://www.hl7.org/fhir/us/core/CapabilityStatement-us-core-server.html; data included in this profile must be able to be exchanged, including the Organization Identifier

Current uses, exchange, and use cases: CCN and PTAN 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 organization identifiers can mitigate such delays in emergency response activities.

CMS-CCSQ Support for Organization Identifier for USCDI v3

CMS-CCSQ recommends inclusion of Organization/Hospital Identifier in USCDI V3 to enable exchange of CMS Certification number (CCN) and Provider Transaction number (PTAN)—unique identifiers for a healthcare organization.

Rationale: Identifiers are critical for tracking and linking where patients receive care and for managing public health reporting and emergency response. Many nationally used organization/hospital identifiers support this, including CCN and PTAN. We recommend the addition of organization/hospital identifier to USCDI version 3, which will allow for exchange of CCN, PTAN, and other organization identifiers that may meet other use cases. All hospitals in the US are assigned a CCN and exchange this information regularly, and all Medicare providers are assigned a PTAN. The CCN verifies Medicare/Medicaid certification for survey and certification, assessment-related activities, and communications. The CCN represents physically distinct care settings even when these settings share a common tax ID number. Exchange of these identifiers supports facility-specific quality, prior authorization activities, and other assessments that are limited without this information.

Maturity:

• Current standards:
  • HL7 FHIR US Core Implementation Guide STU3 and STU4 based on FHIR R4, Organization Profile must support an identifier (https://www.hl7.org/fhir/us/core/StructureDefinition-us-core-organization.html )
  • Organization Profile is included in the HL7 FHIR US Core Capability Statement: https://www.hl7.org/fhir/us/core/CapabilityStatement-us-core-server.html; data included in this profile must be able to be exchanged, including the Organization Identifier
• Current uses, exchange, and use cases: CCN and PTAN are exchanged across the nation for CMS reporting.  Exchange of these identifiers supports facility-specific quality, prior authorization activities, and other assessments that are limited without this information.