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October 18, 2022

CMS Seeks Provider and Stakeholder Feedback on First National Directory of Healthcare Providers and Services

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The US Centers for Medicare & Medicaid Services (CMS) released a Request for Information (RFI) seeking comments on the creation of a national directory of healthcare providers and services that would become a "centralized data hub" with information on providers and services throughout the country. The RFI is open for a 60-day public comment period ending December 6, 2022.

IN DEPTH


CMS is soliciting feedback on the creation of the first national directory of healthcare providers and services (NDH), which would contain information on healthcare providers and services across the country. CMS states that the NDH would improve and support interoperability throughout the healthcare sector for payers and providers while making it easier for patients to identify, compare and locate providers who meet their specific needs and preferences, such as those related to office accessibility, languages spoken or other data. CMS proposes that consolidating provider data into a single source would ultimately reduce the unnecessary burden placed on providers to maintain dozens of separate directories while improving access to care. The new system would be used in place of commercial payor directories and allow payers to update their own directories seamlessly from a single directory. CMS is proposing integrating the NDH with current CMS-maintained systems (i.e., NPPES, PECOS and Care Compare).

CMS requests stakeholder input on whether such a directory would improve patient choice and access to care by making it easier for patients to identify, locate and compare providers; and how creating a single, centralized system could reduce the burden of directory maintenance for payers and providers and promote information accuracy for patients. Further, the RFI asks for input on "the [directory] concept and potential benefits, provider types, entities and data elements that could be included to create value for the health care industry, the technical framework for a [directory], priorities for a possible phased implementation, and prerequisites and actions CMS should consider taking to address potential challenges and risks."

The RFI is open for a 60-day public comment period ending December 6, 2022.

KEY TAKEAWAYS

An NDH would be a marked shift from the current fragmented landscape of provider databases. Although such a shift may alleviate the stress experienced by patients who struggle to find up-to-date information about providers in their network and by providers that face redundant and burdensome reporting requirements to multiple databases, the database could create risks for providers.

Notably, there is a high likelihood that the information for the NDH would be pulled from CMS-maintained systems, such as NPPES, PECOS and Care Compare. The data currently maintained in those systems may be outdated or inaccurate, and could include information that providers may not want readily accessible in a public database. Further, in order to ensure accurate and current data in the NDH, CMS may employ enhanced validation efforts, which may be burdensome or disruptive to providers. CMS may also threaten or impose sanctions on providers who fail to report updated information in a timely manner or who report inaccurate or inconsistent information. Providers should consider these potential impacts when responding to the RFI.

Provider feedback to the RFI will help CMS gain a better understanding of the present scope of healthcare databases and assist CMS in identifying the potential benefits and drawbacks of creating a centralized data hub for healthcare providers.

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