Data Element

Comment

Care Team Member Name Data Element Comments

APTA thanks ONC for renaming this “care team member name” from the original “provider name.”

APTA asks further clarity on what care team member name is reported during certain scenarios involving physical therapy. We request that ONC clarify whether each care team member’s name should be identified in these circumstances, given that in many instances, a patient may be treated by several different members of the care team in one visit. For instance, both a physical therapist and physical therapist assistant may deliver health care services to a patient in an office or facility-based setting. Physical therapist assistants work under the direction and supervision of a physical therapist; for outpatient therapy Medicare claims, a CQ Modifier is appended to the claim to denote when services are furnished in whole or in part by the physical therapist assistant; however, the physical therapist is responsible for the delivery of services. In this instance, would only the physical therapist’s name be reported?

 

In another example, a physical therapist assistant may be the sole provider that delivered health care services on a date of service. However, the physical therapist assistant is working under the supervision of the physical therapist. So, would the physical therapist assistant’s’ name be reported, or would the supervising physical therapist’s name be reported, or would both the physical therapist and physical therapist assistant’s name be reported? In addition, support personnel may be involved in tasks that promote efficient operation of the physical therapist service being provided (such as a physical therapy aide). Would ONC require that name of each support personnel also be reported?

 

In the instance of care delivered in a facility-based setting, does ONC anticipate creating a separate data class specifically for such organizations? In a facility-based setting, only the facility’s name is provided; thus, if a patient is treated in a facility, such as a skilled nursing facility, would it be the facility’s name that is reported, or each individual clinician who provides health care or related services in that facility?

Care Team Member Data Element Comments

Due to the confusion that results from the data elements included within this data class, APTA asks ONC to confirm that care team member is applicable to the individual and not the organization. We also suggest that ONC significantly clarify this data element. For instance, questions arise that include:

  • Would care team member include a physical therapist assistant working under the supervision of a physical therapist?
  • Would care team member include support personnel working under the direction and supervision of a physical therapist?
  • If an interdisciplinary therapy team is involved in the patient’s care, would each clinician and support personnel be identified?
  • Would care team members include nonlicensed personnel or caregivers? If so, how would ONC expect them to be identified?

Full Names of Nurses (not advanced practice LIP)

Is it necessary to release the full name of a bedside nurse, who does not perform procedures that are uniquely billable or referable? Full name note attribution from this cohort does not yield any traceable continuity of care benefit as it does with billable and referable note authors.  Acute care nurses are concerned for their safety if releasing their full name routinely on all progress notes.  

Provider name should be a name, not an identifier

It is valuable to represent the name of care team members. This should not be considered a required "identifier." Suggest aligning with the FHIR HumanName data type. The material provided in this section seems to be a copy of the Provider Identifier section and would be appropriate in that section not here.

Also agree that in a care team this should be the Care Team Member Name.

Amend to Care Team Member Name

This data element may cause some confusion. We recommend that ONC revise this data element to “Care Team Member Name.”

Moreover, we request that ONC clarify whether each care team member’s name should be identified, given that in many instances, a patient may be treated by several different members of the care team in one visit. For instance, both a physical therapist and physical therapist assistant may deliver health care services to a patient in an office or facility-based setting. Physical therapist assistants work under the direction and supervision of a physical therapist; for outpatient therapy Medicare claims, a CQ Modifier is appended to the claim to denote when services are furnished in whole or in part by the physical therapist assistant; however, the physical therapist is responsible for the delivery of services. In this instance, would only the physical therapist’s name be reported?

In another example, a physical therapist assistant may be the sole provider that delivered health care services on a date of service. However, the physical therapist assistant is working under the supervision of the physical therapist. So, would the physical therapist assistant’s name be reported, or would the supervising physical therapist’s name be reported, or would both their names be reported? In addition, support personnel may be involved in tasks that promote efficient operation of the services being provided. Would ONC require that the name of each support personnel also be reported?

In the instance of care delivered in a facility-based setting, does ONC anticipate creating a separate data class specifically for such organizations? In a facility-based setting, only the facility’s name is provided; thus, if a patient is treated in a facility, such as a skilled nursing facility, would it be the facility’s name that is reported, or each individual clinician who provides health care or related services in that facility?

 

Limits to NPI

Can NPI be applied to all care team members, specifically those who do not have a specified clinical role?  For example, formal and informal caregivers who provide critical support and assistance at the individual's home? 

Separate fields for specific name elements

It seems odd that you would have a single name field here when you separate the name out into constituent elements under demographics. Further, having a single name field likely will lead to a lack of standardization in name format that will make the data less useful and less consistent across different users.

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