Data Element

Information from the submission form

Organization/Hospital Identifier
Description
Unique identifier for a healthcare organization (i.e. CCN, NPI)

Comment

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 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:

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