Data related to an individual’s insurance coverage for health care.

Data Element

Medicare Patient Identifier
Description

Medicare Beneficiary Identifiers (MBI) used to uniquely identify Medicare patients.

Comment

CMS-CCSQ Supports Medicare Patient Identifier for USCDI v6

Recommendation 1: CMS CCSQ recommends advancing the Medicare Patient Identifier element to Level 2 and inclusion of the Coverage Period, Group Name, Payer Name, Plan Name, and Medicare Patient Identifier data elements in final USCDI v6.

Rationale: Inclusion of these common health insurance data elements for nationwide interoperability is essential for such use cases as value-based care, including affordability for lower-income individuals, and enabling patients to determine costs and affordability up front. This Health Insurance Information data class is associated with the overall primary and secondary coverage for the individual. In some cases, it may be different from the benefit used for a particular encounter or claim (e.g., worker's comp benefits). While these data elements are already included in the latest Fast Healthcare Interoperability Resources (FHIR) US Core and Consolidated Clinical Document Architecture (CDA) implementation guides (IGs) referenced in the Health, Data, Technology, and Interoperability-1 Final Rules (HTI-1), the implementation community can benefit from more clarity on how to consistently populate these fields—in particular Payer Name and Group Name—as there is variation between what a typical insurance card shows versus what is best used on real-time eligibility (RTE) queries with health plans.

 

Recommendation 2: CMS CCSQ recommends renaming and aligning Medicare Patient Identifier (MPI) with CMS’s naming and use of Medicare Beneficiary Identifier (MBI).

CSTE Comment - v6

CSTE supports inclusion of this data element in USCDI V6. Please see previously submitted CSTE comments for additional recommendations.

CSTE Comment - v5

This is one type of patient identifier and there are others which could all be subsumed under Patient Identifier, Patient Identifier type and Patient Identifier Assigning Authority.

CDC's Comment for draft USCDI v5

CDC supports the inclusion of this data element in USCDI v5 as it is an element that may be necessary for calculation of our digital quality metrics from FHIR data.

CDC's Consolidated Comment for USCDI v4

  • CDC continues to support inclusion of this data element in USCDIv5.
  • NAACCR Comment:  This data element will be helpful for linkages for public health use and is part of NAACCR standard.

Unified Comment from CDC

  • NOTE - This comment supports the promotion of the Data Class Patient Demographics - Data Element Identifier to USCDI V3 as well as the additional Data Element of Identifier System, including the allowance of multiple instances of Identifier/ Identifier System per patient. We believe that this will allow needed flexibility to accommodate use and exchange of the variety of patient identifiers in current use in the US. An example of this approaches is: Identifier: 1A10B23CD45, Identifier System: http://hl7.org/fhir/sid/us-mbi. If ONC does not choose to incorporate this approach (Identifier + Identifier System) in USCDI V3, we recommend allowing for the following Patient Demographic Data Class Data Elements in USCDI V3: Medicare Patient Identifier, Medical Record Number and Social Security Number.
     
  • General Comment: We suggest changing this data element name from Medicare Patient Identifier to Medicare Beneficiary Identifier because that is what CMS and the Social Security Administration, as well as many health care industry stakeholders call it. (see: https://www.cms.gov/Medicare/New-Medicare-Card)
     
  • Additional Use Cases: The MedMorph Public Health Use Cases of Health Care Surveys and Cancer Registry Reporting are use cases that use Medicare Patient Identifier as an important patient identifier for internal registry and external to registry linking and patient or registrant identification or matching purposes. Links to Use Case Project Pages: https://www.cdc.gov/csels/phio/making-ehr-data-more-available.html, https://www.cdc.gov/nchs/dhcs/nhcs_registry_landing.htm, https://www.cdc.gov/cancer/npcr/
     
  • Additional Applicable Standards: HL7 CDA ® Release 2 Implementation Guide: Reporting to Public Health Cancer Registries from Ambulatory Healthcare Providers, Release 1, DSTU Release 1.1 – US Realm: https://www.hl7.org/implement/standards/product_brief.cfm?product_id=398.
     
  • HL7 CDA® R2 Implementation Guide: National Health Care Surveys (NHCS), R1 STU Release 3 - US Realm: https://www.hl7.org/implement/standards/product_brief.cfm?product_id=385
     
  • HL7 FHIR® US Core Implementation Guide STU3 Release 3.1.1: https://www.hl7.org/fhir/us/core/index.html
     
  • CSTE supports inclusion of this measure into USCDI v3

Response to Comment on Medicare Patient Identifier

Specific Identifier(s) or general Identifier?
MedMorph supports the addition of Medicare Patient Identifier (level 2), but is concerned with having a general Identifier element (level 2) as well as Medical Record Number (Level 1) and Patient Social Security Number (level 1). What is the intention of Identifier - is it a placeholder for a national identifier of some sort for a patient?  We recommend that USCDI either take a general approach with Identifier Type, Identifier System, and Identifier Value OR be specific with Medical Record Number, Medicare Patient Identifier and Social Security Number elements (and remove the Identifier element).

CMS's intent with the Medicare Patient Identifier data element submission was to specifically recommend inclusion of the Medicare Beneficiary Identifier (MBI) for Medicare beneficiaries, as this ID is currently well defined and captured. 

Specific Identifier(s) or general Identifier?

MedMorph supports the addition of Medicare Patient Identifier (level 2), but is concerned with having a general Identifier element (level 2) as well as Medical Record Number (Level 1) and Patient Social Security Number (level 1). What is the intention of Identifier - is it a placeholder for a national identifier of some sort for a patient?  We recommend that USCDI either take a general approach with Identifier Type, Identifier System, and Identifier Value OR be specific with Medical Record Number, Medicare Patient Identifier and Social Security Number elements (and remove the Identifier element).

Recommendations for Updated Submission

We've reviewed and submitted feedback on the submission we've put forward for Patient Medicare Number, and we believe the information provided differs from the submission here, which has been referenced when told we submitted a duplicate. We believe our submission should be revisited as it differs in some areas to the submission seen here.

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