JUN 25 1997
The Honorable Donna E. Shalala
Secretary of Health and Human Services
200
Independence Avenue , S.W.
Washington, D.C. 20201
Dear Secretary Shalala:
On behalf of the National Committee on Vital and Health Statistics (NCVHS), I am pleased to forward to you our recommendations relating to the first of the health data standards being proposed for adoption in accordance with the administrative simplification provisions of the Health Insurance Portability and Accountability Act of 1996 (HIPAA). HIPAA outlines a new approach to the adoption of data standards to support electronic data interchange in the health industry in the United States, in a framework that protects the privacy and security of health information. The law assigns to you the responsibility for adopting such standards by February 1998. It also asks you to provide detailed recommendations to Congress with respect to the privacy of individually identifiable health information by next August. The NCVHS is very pleased to provide support, advice and consultation to you in this effort.
To assist in carrying out our advisory responsibilities to you, the NCVHS, in collaboration with HHS, has held a number of public hearings to obtain input and advice from throughout the health industry, State government, and the research and public health communities. The first of the health data standards to be proposed for adoption is the unique identifier for health providers, which HHS has had under development for some time and which we understand is planned for Federal Register publication in July for review and comment.
The NCVHS has been briefed on the proposal for the National Provider Identifier (NPI), and we offer our strong support. The proposal includes an eight digit alphanumeric identifier that would be assigned to all providers, along with essential identifying information. The identifier includes a check digit and contains no embedded intelligence. We recommend that HHS proceed to publish the proposal for public comment without delay. While public comments are likely on the technical details of the number and the optimal approach to enumeration, we have found broad support for the proposal in general and urge you to proceed.
The Committee did identify one concern that we bring to your attention. The NPI, like all of the subsequent standards to be adopted, should be conceived of as a generic industry-wide standard and it should not contain any requirements that are specific to individual programs -- government programs or otherwise. It is our understanding that information about HHS Inspector General sanctions against providers is being considered as part of the NPI system.
We believe that this approach undermines the principle of a generic industry-wide standard and makes the successful implementation of the first standard needlessly difficult and controversial. While we are supportive of HHS efforts to prevent and detect health care fraud and abuse, we strongly recommend against the inclusion of sanctions information as part of the NPI system itself. The OIG provider sanctions information is already public, and it can be further publicized in other ways. We do agree that the use of the NPI to facilitate access to health care fraud and abuse information in other data systems is both appropriate and consistent with the intent of the statute.
We appreciate your national leadership in health data standards, electronic data interchange and privacy, and we are privileged to work with you on these issues.
Sincerely,
/s/
Don E. Detmer, M.D.
Chairman