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December 1, 2022
The Honorable Chiquita Brooks-LaSure
Administrator
Facilities for Medicare & Medicaid Companies
7500 Safety Blvd.
Baltimore, MD 21244
Re: CMS-0058-NC, Request for Info; Listing of Healthcare Suppliers & Companies, vol. 87, October 7, 2022
Expensive Administrator Brooks-LaSure:
On behalf of our almost 5,000 member hospitals, well being methods and different well being care organizations and our clinician companions — together with greater than 270,000 affiliated physicians, two million nurses, and different caregivers — and the 43,000 well being care leaders who belong to our skilled membership teams, the American Hospital Affiliation (AHA) appreciates the chance to supply feedback in response to the Facilities for Medicare & Medicaid Companies’ (CMS) Request for Info (RFI) relating to the institution of a nationwide listing of well being care suppliers and companies (NDH). As mentioned within the RFI, the NDH would function a publicly accessible centralized knowledge hub for well being care suppliers, amenities, and entity listing data. It’s envisioned that the NDH would assist sufferers navigate well being plan networks and facilitate well being data change and public well being knowledge reporting to advance fairness targets.
The AHA shares CMS’ targets to enhance affected person entry to supplier data and to facilitate well being data change and knowledge reporting. We recognize the dedication CMS has invested in striving to fulfill these goals. Nevertheless, we’re involved that including yet another supplier listing requirement won’t assist sufferers in accessing the knowledge they want about their care suppliers. In reality, including a further knowledge supply with out sufficiently addressing how or why it differs from the myriad supplier directories already in existence might additional complicate sufferers’ skill to entry correct data. In the meantime, such a requirement would add appreciable, duplicative burden on suppliers. Moreover, now we have vital reservations in regards to the present state of readiness of the important know-how wanted for a centralized knowledge hub such because the NDH. As such, whereas we assist CMS’ goals, we strongly encourage the company to chorus from transferring ahead with the NDH presently.
CMS suggests {that a} centralized knowledge hub such because the NDH might be used to help sufferers, suppliers and plans in numerous methods. These embody:
- to assist sufferers determine in-network and out-network suppliers and specialty companies;
- to assist sufferers and suppliers coordinate the No Surprises Act Good Religion Estimates;
- to assist suppliers and plans advance using digital prior authorization; and
- to assist scale back supplier reporting burden whereas streamlining program integrity compliance audits.
Whereas CMS asserts that the NDH would alleviate burden for suppliers, the company doesn’t adequately deal with how or why the NDH would enhance upon the myriad knowledge units that already acquire supplier data. Additional, CMS means that the NDH would exist alongside these different knowledge units and never substitute them. For instance, within the RFI, CMS describes two federal knowledge methods that acquire supplier data, specifically the Nationwide Plan and Supplier Enumeration System (NPPES), which provides the Nationwide Supplier Identifier (NPI) to well being care suppliers, and the Medicare Supplier Enrollment, Chain, and Possession System (PECOS), which suppliers and suppliers use to validate their Medicare enrollment and revalidation course of. As well as, CMS catalogs different supplier and well being plan reporting necessities inside CMS packages, akin to Medicare Benefit, Medicaid and Kids’s Well being Insurance coverage Program managed care plans, and the Market Certified Well being Plans. Nevertheless, within the RFI, CMS fails to completely acknowledge different sources of government-collected supplier data, akin to state licensing board knowledge, or knowledge collected by insurers and third-party directors of business and self-funded well being plans.
Suppliers already submit a major quantity of knowledge and data for numerous authorities and personal databases, and it’s unclear what the function of the NDH could be vis-à-vis these present knowledge units or whether or not this knowledge assortment would offset any of the others. As well as, CMS fails to completely deal with how the standard of the NDH knowledge could be an enchancment over these present knowledge methods which have, admittedly, been plagued with inaccuracies. The success of the NDH would depend upon suppliers submitting and validating data that meets the required knowledge submission requirements, together with verifying the accuracy of the info. And but, this is identical course of utilized by the numerous variations of supplier directories that exist as we speak.
Whereas CMS could also be hoping for improved know-how and knowledge requirements to help within the accuracy of the info, these instruments are removed from prepared. CMS factors to utilizing the HL7 Quick Healthcare Interoperability Sources (FHIR)-based Software Programming Interface (API) as the important thing to managing the supplier and facility listing data. Nevertheless, the Workplace of the Nationwide Well being Coordinator (ONC) and the Federal Well being Structure (FHA) have been working since 2016 to outline the underlying structure for a nationwide supplier listing utilizing FHIR however haven’t but accomplished their work. Because of this, CMS acknowledges that an API-enabled NDH stays conceptual and has but to be examined for broad-scale implementation.
The AHA firmly believes that CMS shouldn’t proceed with implementing an NDH till there’s better readability on the way it will slot in among the many different present supplier data knowledge units, particularly with respect to how sufferers will know when to depend on the NDH versus their well being plan’s supplier listing. We additionally urge that CMS first deal with how the NDH can scale back — not contribute to — supplier reporting burden and guarantee satisfactory testing and standardization relating to well being data and knowledge transmission.
Two latest examples of departmental and company requests for data underscore the necessity to rethink an aggressive implementation timeline for the NDH. In March, the AHA submitted public feedback on ONC’s RFI pertaining to the digital prior authorization requirements and implementation specs.1 In that letter, we commented that whereas we’re supportive of options to scale back prior authorization impacts on sufferers and suppliers, we advocate that ONC collaborate with CMS to pilot the applied sciences and requirements in well being care data change to make sure performance and stop pointless supplier burden.
In November, AHA submitted feedback to CMS relating to the RFI on the No Surprises Act Superior Rationalization of Advantages (AEOB) and Good Religion Estimates (GFE).2 In that letter, we commented that your complete FHIR-based API had not been sufficiently confirmed to be an answer to transmit AEOBs and GFE knowledge. We additional beneficial that CMS assess the diploma to which the FHIR-based API may be broadly adopted and applied by the various market individuals. Moreover, we urged that exact consideration ought to be paid to the small, rural, and different suppliers who might battle to implement new know-how. These identical feedback apply to the NDH RFI.
As well as, the NDH RFI doesn’t deal with how industrial well being plans or state governments would make the most of the NDH and their reporting obligations. Nor does the RFI deal with how the general public would entry the info. This lack of readability means that the NDH wouldn’t substitute present directories however would solely add to the burden already borne by suppliers. Whereas CMS asks if incentives could be acceptable to encourage supplier participation, we elevate issues that incentives can flip into penalties. We strongly urge that CMS doesn’t contemplate imposing incentives to grow to be a pathway to “compliance sticks” when the utility of the NDH has not been confirmed. We additionally encourage CMS to contemplate, in its place, adjustments that might be made to present reporting necessities somewhat than implementing a wholly new knowledge set, akin to together with the placement data of suppliers in NPI reporting. Lastly, we urge that CMS fastidiously contemplate how the NDH could also be used to advance well being fairness targets by knowledge assortment and guarantee alignment and standardization of approaches to amassing demographic and social danger knowledge so that each one stakeholders use constant definitions and requirements.3
Once more, we recognize CMS’ give attention to enhancing sufferers’ entry to correct details about their well being care suppliers; nonetheless, we urge that CMS fastidiously rethink this proposal given the shortage of readability round goals, want for additional consideration in regards to the extra burden it should place on suppliers, and the shortage of technological readiness. The AHA is happy to be a useful resource on these points and would welcome the chance to supply any extra data that will be useful to the company in its coverage improvement. Please be happy to contact me in case you have any questions or have a member of your crew contact Molly Collins Offner, AHA’s director of coverage improvement, at [email protected].
Sincerely,
/s/
Ashley Thompson
Senior Vice President
Public Coverage Evaluation and Improvement
- AHA Comments on Potential Rulemaking to Improve Electronic Prior Authorization Processes | AHA
- AHA’s Response to CMS’ RFI; Advanced Explanation of Benefits and Good Faith Estimate for Covered Individuals | AHA
- AHA Response to “Make Your Voice Heard” RFI – Promoting Equity and Efficiency in CMS Programs | AHA
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