The specific person(s) who participate or are expected to participate in the care team.

Data Element

Additional Information

Care Team Member Identifier

Comment

Amend to Care Team Member Identifier

As recommended elsewhere, we recommend that ONC amend this data element to “Care Team Member Identifier.” Moreover, we recommend that ONC confirm that “provider” is in reference only to an individual, i.e., a care team member, and not an organization, such as a hospital or skilled nursing facility. It must be made clear that the “provider” (i.e., care team member) is an individual clinician who may work in a facility and deliver services. ONC must keep in mind that not all care team members have an “identifier,” or the identifier may differ, and as such, we suggest that this data element be optional. In addition, ONC must clarify “what” an identifier is; for instance, the billing NPI; the provider ID number assigned by the payer; an identifier assigned by the organization; etc. A NPI might not be applicable to some care team members and therefore, other options for “identifier” are necessary. For instance, clinicians who are cash-based and do not bill third-party payers may not have a NPI; also, clinicians who work in facility-based settings (hospitals, SNFs, home health agencies, rehab agencies) may not have a NPI because their services are billed under the facility NPI. Another example where a health care professional may not have a NPI is for those individuals who work under the supervision of another clinician and whose services are billed under the supervisor’s NPI (such as a physical therapist assistant who works under the supervision of the physical therapist). ONC should consider providing a list of examples (not all-inclusive) of identifiers that could be reported and standardized. ONC also should consider affording guidance on potential identifiers for each individual based on the role they play in care delivery:
  1. Care team: Numerous health care professionals involved in patient care in facility-based setting (such as physical therapist, occupational therapist, speech-language pathologist, RN, and social worker)
  2. Individual health care professional who is responsible for the care of the patient (private practice/office-based setting) (and is the billing clinician)
  3. Health care professional that is key part of care team but isn’t ultimately responsible for the care of the patient, such as physical therapist assistant or CNA
  4. Paid caregiver
  5. Family member
Finally, in the instance of care delivered in a facility-based setting, does ONC anticipate creating a separate data class specifically for such organizations? As noted above, in a facility-based setting, the facility’s NPI is used for billing and the clinician’s NPI is not reported/does not appear on the claim.

Care Team Member Identifier Element Comments

APTA thanks ONC for renaming this “care team member identifier” from the original “provider identifier,” and also for clarifying that “care team member” is a specific person(s) who participate or are expected to participate in the care team. APTA appreciates that ONC clarified what the “care team member identifier” means in part: https://www.healthit.gov/isa/taxonomy/term/1291/uscdi-v2#uscdi-proposal-mode-uscdi-data-element-page-display. More importantly, ONC must clarify “what” an identifier is; for instance, the billing NPI; the provider ID number assigned by the payer; an identifier assigned by the organization; etc. An NPI might not be applicable to some care team members and other options for “identifier” are necessary. ONC must keep in mind that not all care team members have an “identifier,” or the identifier may differ, and as such, we suggest that this data element be optional. For instance, clinicians who are cash-based and do not bill third-party payers may not have an NPI; also, clinicians who work in facility-based settings (hospitals, SNFs, home health agencies, rehab agencies) may not have an NPI because their services are billed under the facility NPI. Another example where a health care professional may not have an NPI is for those individuals who work under the supervision of another clinician and whose services are billed under the supervisor’s NPI (such as a physical therapist assistant who works under the supervision of the physical therapist). ONC should consider providing a list of examples (not all-inclusive) of identifiers that could be reported and standardized. ONC also should consider affording guidance on potential identifiers for each individual based on the role they play in care delivery:
  1. Care team: Numerous health care professionals involved in patient care in facility-based setting (such as physical therapist, occupational therapist, speech-language pathologist, RN, and social worker).
  2. Individual health care professional is responsible for the care of the patient (private practice/office-based setting) (and is the billing clinician).
  3. Health care professional that is part of care team but isn’t ultimately responsible for the care of the patient, such as physical therapist assistant or CNA.
  4. Paid caregiver.
  5. Family member.
Finally, 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, the facility’s NPI is used for billing and the clinician’s NPI is not reported/does not appear on the claim.

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