Physical place of available services or resources.

Data Element

Facility Identifier
Description (*Please confirm or update this field for the new USCDI version*)

Sequence of characters representing a physical place of available services or resources.

Comment

CDC-CMS Joint Priority Data Element for USCDI v4

We support the CMS comment ‘CMS-CCSQ Support for Facility/Organization Identifier: USCDIv3’ on 2022-03-22 that Facility/Organization Identifiers are critical component of EHR for providing high quality care to patients, reducing disparities, SDOH data analysis, promoting interoperability and data aggregation. HIPAA requires that health care providers have standard NPI that identify them on all standard transactions.  We recommend adding the ‘Facility/Organization Identifiers’ to USCDI data classes. We suggest the following definition of this data class: ‘Facility/Organization Identifiers in EHRs are standardized codes, names and other attributes that provide a unique data pointer to a healthcare facility/organization where patient’s care has occurred.’ 

We found a similar concept description in the Level 2 under the ‘Facility Level Data’. Because a potential ambiguity of the ‘Facility Level Data’ term (i.e., it could mean aggregate level facility data rather than unique identifiers) we strongly suggest replacing it with proposed by CMS title ‘Facility/Organization Identifiers’. Based on the recent experience in management of the COVID-19 EHRs and ONC requirements on EHR aggregation and reporting data for situational awareness, we propose that the following data elements and associated vocabulary standards should be included into the Facility/Organization Identifiers data class:

  1. Organization/Facility name, LOINC 76469-6
  2. Organization/Facility Email address, LOINC 90054-8
  3. Organization/Facility Phone number, LOINC 90053-0
  4. Organization/Facility Address, LOINC 90052-2
  5. Organization/Facility ZIP code , LOINC 76695-6
  6. National Provider ID (NPI), LOINC 45952-9
  7. CCN (CMS Certification Number), LOINC 69417-4


Additional applicable standards and additional specifications:

  1. FHIR DSTU2, 3 and 4, CDA Release 2.0, HL7 V2 PL Data Type https://bit.ly/FHIRLocation,
  2. Resource Profile: FHIR 5.0.1 - STU5 Release US, US Core Location Profile  https://open.epic.com/Interface/FHIR#Location
  3. FHIR 4.3.0: R4B – STU, Resource Organization - Detailed Descriptions     https://hl7.org/fhir/organization-definitions.html
  4. HHS.gov. Health Information Privacy. Other Administrative Simplification Rules. https://www.hhs.gov/hipaa/for-professionals/other-administration-simplification-rules/index.html



This element is also shared priority for both CDC and CMS as outlined in the joint support letter

CDC-CMS Joint Priority Data Element

 Both CDC and CMS support inclusion of this element in v3. More details are provided in the joint letter sent to ONC. 

CMS-CCSQ Support for Facility/Organization Identifier: USCDIv3

Identifiers are critical for billing, linking billing/clinical EHRs, supporting data aggregation across data sources and reducing burden, as well as attribution and tracking of data. All of these activities are necessary for providing high quality care to patients, reducing disparities, promoting interoperability and communicating across silos. Facility identifiers are also critical for public health reporting and tracking, an ONC stated priority for USCDI version 3.

CMS specifically prioritizes exchange of CMS Certification number (CCN), Provider Transaction number (PTAN), and National Provider Identifier (NPI)—unique identifiers for a healthcare organization.

Maturity:

  • Current standards:
  • Current uses, exchange, and use cases: CCN, PTAN, and NPI are exchanged across the nation for CMS reporting to appropriately attribute outcomes and measure results.  Exchange of these identifiers supports facility-specific quality, prior authorization activities, and other assessments that are limited without this information.

Unified Comment from CDC

  • General Comment: 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 pairs per patient (approach 1). 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: 333224444, Identifier System: http://hl7.org/fhir/sid/us-ssn.
     
  • If ONC does not choose to incorporate approach 1, (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. (approach 2) We believe that allowing for both approaches would be confusing, so we recommend choosing one or the other.
     
  • Additional Use Case: This is a standard data (FIN or NPI) item used by central cancer registries in all states according to the North American Association of Central Cancer Registries (NAACCR) standard. Data received through data exchange from medical facilities (e.g., laboratories, hospitals, physician EHRs, etc.) to central cancer registries for CDC and NCI’s national cancer surveillance systems, as required by law.  
     
  • CSTE supports inclusion of this measure into USCDI v3: Very useful for this information to be captured in some way and then subsequently used in reporting to PH.

NCPDP Comment

NCPDP SCRIPT transactions uses the NPI type 2 and proprietary Facility ID values. NCPDP request these values be added to Draft Version 2.

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