Care Team Member(s)

AOTA Comment on Care Team Member identifier

The American Occupational Therapy Association (AOTA) supports data elements that capture the services of multiple care team members. AOTA encourages USCDI to consider other identifiers in addition to NPI, as many clinicians (such as therapy providers) may not utilize an individual NPI if they work for a facility.  Additionally, some clinicians who work under the supervision of other clinicians, such as occupational therapy assistants, bill under the supervisor NPI. License numbers may be an appropriate alternative; however, many clinicians have multiple licenses in different states with different numbers.  

USCDI 2022 Comments 9.22_0.pdf

ANI comments support NCSBN ID as Care Team Member Identifier

The NCSBN ID is a unique eight-digit number assigned to every nurse upon their first licensure with a board of nursing. It's the only unique nurse identifier and it allows concise communication among systems while still protecting a nurse's personal information. This ID is specific to nursing, and it is available for each of the more than 4 million nurses in practice today. Use of the NPI as the Care Team Member Identifier will not enable specific representation of nursing documentation among interoperable systems. NCSBN ID numbers are free to obtain and available exclusively through the Nursys system managed securely by NCSBN. The Nursing Knowledge: Big Data Science Policy and Advocacy Workgroup and the Alliance for Nursing Informatics (ANI) recommend the National Council of State Boards of Nursing (NCSBN) ID should be used by key stakeholders as a nurse identifier to help demonstrate the value of nursing through research, and enhance individual care and health outcomes via more comprehensive documentation in the EHR, ERP, and other technologies and systems. Additional information is available on the ANI website at https://www.allianceni.org/policy-position/unique-nurse-identifier  There are more than 4 million nurses 

NCPDP Comments on USCDI draft V3

NCPDP supports the use of provider NPI.

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.

Agree that this should be more general - Care team Identifier

NPI can be one type of identifier based on the need, but other identifiers for other care team members will be needed. The details on which and how should be left to a specific implementation guide.

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.