Description (*Please confirm or update this field for the new USCDI version*)
Sequence of characters used to uniquely refer to a member of the care team.
Examples include but are not limited to National Provider Identifier (NPI) and National Council of State Boards of Nursing Identifier (NCSBN ID).
Submitted By: Al Taylor
/ ONC
Data Element Information
Use Case Description(s)
Use Case Description
Collection of data related to a provider of health care or related services is associated with attribution and documentation of care, quality of care and safety reporting, financial information, consultation and referral, and discovery of services that may be needed for future care. Documentation of provider information can be performed automatically or require manual intervention to associate it with a past, current or future episode of care.
Elements of this class are required for federal and other financial claims and reporting programs.
Estimate the breadth of applicability of the use case(s) for this data element
Virtually all documentation of the provision of care involves identifying characteristics of the person responsible for delivery of that care.
Healthcare Aims
Improving patient experience of care (quality and/or satisfaction)
Improving the health of populations
Improving provider experience of care
Maturity of Use and Technical Specifications for Data Element
This data element has been used at scale between multiple different production environments to support the majority of anticipated stakeholders
Extent of exchange
5 or more. This data element has been tested at scale between multiple different production environments to support the majority of anticipated stakeholders.
Potential Challenges
Restrictions on Standardization (e.g. proprietary code)
Feedback requested
Restrictions on Use (e.g. licensing, user fees)
Feedback requested
Privacy and Security Concerns
No concerns unique to these data elements
Estimate of Overall Burden
This data class and these elements are routinely used for many purposes in healthcare and related activities
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.
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
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.
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:
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).
Individual health care professional is responsible for the care of the patient (private practice/office-based setting) (and is the billing clinician).
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.
Paid caregiver.
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.
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.
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:
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)
Individual health care professional who is responsible for the care of the patient (private practice/office-based setting) (and is the billing clinician)
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
Paid caregiver
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.
The "Optional Background Text / Cover Letter" field provides space for additional context or introductory information related to your comment.
If you wish to provide context, explanation, or an introduction to your comment, enter this information in the field labeled "Optional Background Text / Cover Letter." This is entirely optional and is most useful when submitting multiple related comments or when additional background would help reviewers understand your feedback.
If you are only commenting on a single data class or element, you may leave this field blank.
2. Select the Data Class
To specify which data class your comment addresses:
In the "Data Class" drop-down menu, select the appropriate data class you want to comment on.
If you are providing a general comment that is not specific to a data element, select "General" from the options. Comments with this designation will be displayed on the USCDI landing page.
Note that the Data Class field will automatically populate based on your current location in the platform:
If you are on a data class page, the field will be set to that specific data class
If you are on a data element page, the corresponding data class will be pre-selected
3. Select the Data Element
To specify which data element your comment addresses:
In the "Data Element" drop-down menu, select the specific data element you want to comment on.
The drop-down menu will display only the elements available under the data class you selected in the previous step.
You can use the search function within the drop-down to quickly locate a specific data element.
If you are commenting on the data class itself rather than a specific element, you may leave this field blank.
Note: Comments on a specific data element will appear on the respective data element page, while comments on a data class (without a specific element selected) will appear on the landing page for that data class.
Fig 1 The "Data Class" and "Data Element" dropdown menus allow users to specify the exact content they wish to comment on.
4. Optional: Propose New Data Class or Element
If you cannot find the appropriate data class or element for your comment:
Instead of clicking the "Comment On An Existing Data Class Or Element" button, click the adjacent button labeled "Propose a New Data Class or Data Element."
This will redirect you to the ONDEC (ONC New Data Element and Class) Submission System.
In the ONDEC system, follow the provided instructions to submit your proposal for a new data class or element.
Once your proposal is submitted through ONDEC, it will be reviewed separately from the commenting process.
Fig 2 The "Propose a New Data Class or Data Element" button redirects users to the ONDEC Submission System for proposing new data elements not currently available in the system.
5. Complete the Comment Form
Fill out the required fields in the comment form:
Subject: Enter a brief, descriptive title that summarizes your comment. This helps reviewers quickly understand the nature of your feedback.
Comment: In this field, provide the full details of your comment or feedback. Be as clear and specific as possible about your suggestions, concerns, or observations. Include any relevant details that support your position.
6. Optional: Add Additional Comments
If you need to comment on multiple data classes or elements:
After completing your first comment, click the link labeled "Comment on another data element" at the bottom of the form.
A new comment section will appear, allowing you to enter details for your additional comment.
For each additional comment, you must select the appropriate data class and data element from the drop-down menus.
Complete the Subject and Comment fields for your additional comment.
Repeat this process for each additional comment you wish to submit.
Fig 3 The "Comment on another data element" link enables users to create multiple comments addressing different elements within a single submission.
7. Optional: Upload Supporting Files
The platform allows you to upload supporting documentation to enhance your comment:
Locate the "File Upload" section at the bottom of the comment form.
Click to upload any files (such as PDFs or documents) that provide additional context, evidence, or clarification for your comment.
Important: If you have already entered your comments using the form fields, there is no need to upload duplicate content in PDF format. The file upload feature is intended for supplementary materials only. Please avoid uploading files that contain the same information already provided in your comment text.
Fig 4 The "File Upload" section permits users to attach supporting documentation that supplements their written comments.
8. Optional: Save and Exit
If you need to pause your work and return to complete your comment later:
Click the "Save and Exit" button at the bottom of the form.
Your comment will be saved as a draft that you can access and complete later.
When you return to the platform, you will see a red triangle with an exclamation mark next to the “Return to saved Comment” button, indicating that you have saved comments in draft status.
Click this button to continue working on your draft.
You will be taken to a review page where you can:
Select "Submit Comment" to officially submit your feedback.
Click "Edit" to return to the comment form and make changes
Select "Discard Draft" to delete the saved draft and start fresh
Fig 5 A red triangle with exclamation mark indicator appears next to the “Return to saved Comment” button when draft comments are saved in the system.
9. Review and Submit
Once you have completed your comment:
Click the "Review and Submit" button at the bottom of the form.
This will take you to a review screen displaying your comment(s) in full.
Review all information for accuracy and completeness.
On this review screen, you have three options:
Click "Submit Comment" to officially submit your feedback
Click "Edit" to return to the comment form and make changes
Click "Discard Draft" to delete the comment and start fresh
The review screen also includes a "Print" button that allows you to create a printed copy of your comments for your records.
If you choose to submit, your comment will be recorded in the system and made available for review by the appropriate stakeholders.
Fig 6 The review screen allows users to verify comment content and make any necessary modifications before final submission.
Submitted by cgrote@aota.org on
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