January 29, 2023

Volume XIII, Number 29

Advertisement

January 27, 2023

Subscribe to Latest Legal News and Analysis

January 26, 2023

Subscribe to Latest Legal News and Analysis
Advertisement

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

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.

© 2023 McDermott Will & EmeryNational Law Review, Volume XII, Number 295
Advertisement
Advertisement
Advertisement

About this Author

Emily J. Cook, McDermott Will Emery Law Firm, Health Care Attorney
Partner

Emily J. Cook is an associate in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Los Angeles office.  She focuses her practice on Medicare provider certification, reimbursement and regulatory compliance.

310-284-6113
Monica Wallace regulatory counseling lawyer McDermott Will Emery Law Firm
Associate

Monica A. Wallace is an associate in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Chicago office.  She focuses her practice on complex regulatory and transactional counseling to health care organizations such as health systems, hospitals, physician groups, integrated delivery systems, durable medical equipment prosthetics and orthotics suppliers, home health agencies, and other health care providers. Monica’s regulatory practice focuses on the Anti-Kickback and Stark laws; Medicare and Medicaid reimbursement and billing; legal assessments and compliance...

312-984-7757
Carole M. Becker Healthcare lawyer Mcdermott
Associate

Carole M. Becker’s practice focuses on regulatory and transactional health care and life sciences matters. She conducts due diligence to support traditional and non-traditional health care clients as they grow and innovate within the sector.  During law school, Carole served as the executive managing editor for the Journal of Law & Public Policy.

+1 305 329 4484
Associate

Vincent Leahey focuses his practice on regulatory and transactional matters in the healthcare industry.

While in law school, Vincent was senior research editor for the Florida Law Review.

305-507-2316
Advertisement
Advertisement
Advertisement