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National Practitioner Data Bank Issues Draft Revised Guidebook

As explained in the message below, the National Practitioner Data Bank has issued its long-awaited proposed revisions to the NPDB Guidebook, available here and attached for your convenience. Because Katten partner Michael R. Callahan is a member of the NPDB Executive Committee as a representative of the American Health Lawyers Association, we received the attached draft directly. The AHLA has formed a Data Bank Work Group composed of attorneys for the purpose of reviewing and submitting comments to the NPDB as per their instructions. Because other members of the Executive Committee include representatives from the AHA, the AMA, NAMSS and other organizations we expect that they will be submitting comments as well.

We encourage you to review the draft and submit your comments by January 10, 2014. You may receive a similar notice or request from your professional membership association.

It is not yet clear when the Guidebook will be published in final form. This will depend on whether further revisions are made in response to the comments received. The final version will then need to be internally vetted and approved before it will be issued to the public. We will keep you posted on developments.

Dear Executive Committee Members and Alternates:

The NPDB Guidebook was recently revised. The new Guidebook incorporates legislative and regulatory changes adopted since its last edition, including the merger of the NPDB with the Healthcare Integrity and Protection Data Bank. The revised document offers Data Bank users more and clearer examples of when and how to report and query, more useful tables explaining Data Bank policies, and live links to statutes, regulations, and the Data Bank website.

As discussed at the November 14, 2013, NPDB Executive Committee meeting, please find attached the draft NPDB Guidebook for review and comment. The Data Bank also is making the draft Guidebook available to the public for comment to help ensure the clarity of the revised content. We are notifying the public of the opportunity to comment on the draft Guidebook through directions on the Data Bank website, and – in response to concerns expressed at the Executive Committee meeting – we expect to publish notice of the draft’s availability in the Federal Register.

Comments may be submitted from November 22, 2013, through at least January 10, 2014. The comment period may be extended if needed. We will let you know of any extensions by email.

All comments will be collected electronically at NPDBPolicy@hrsa.gov. When submitting your remarks, the Data Bank requests that you:

  • Prepare your comments as an email document or a separate word processing attachment;
  • Identify yourself by name and organization, if applicable;
  • Reference the page number(s) each comment addresses;
  • Ensure comments are specific and relate to the clarity of the NPDB Guidebook’s content, because regulatory or statutory concerns are beyond the scope of this comment process; and
  • Address your remarks to Ms. Ernia Hughes, Acting Director of the Division of Practitioner Data Banks.

We appreciate your input and look forward to providing the Data Bank community with a more comprehensive and resourceful Guidebook.


Ernia Hughes
Acting Director
Division of Practitioner Data Banks
Bureau of Health Professions
Health Resources and Services Administration
U.S. Department of Health and Human Services

©2020 Katten Muchin Rosenman LLPNational Law Review, Volume III, Number 330


About this Author

Michael R. Callahan, Health Care Legal Specialist, Katten Muchin Law Firm

Michael R. Callahan assists hospital, health system and medical staff clients on a variety of health care legal issues related to accountable care organizations (ACOs), patient safety organizations (PSOs), health care antitrust issues, Health Insurance Portability and Accountability Act (HIPAA) and regulatory compliance, and accreditation matters.

Michael's peers regard him as "one of the top guys in Chicago for credentialing—he's got a wealth of experience," while clients describe him as "informed, professional and extremely helpful' and 'would...

Laura Keidan Martin, Health care law Legal Specialist, Katten Muchin law firm

Laura Keidan Martin is the national head of the firm’s Health Care practice and a member of the firm’s Board of Directors. She counsels health care industry participants including health systems, life sciences companies, national ancillary service providers, management companies, managed care organizations and private equity funds, helping them structure their affiliations, mergers, acquisitions, joint ventures, marketing practices and physician compensation arrangements to meet state and federal regulatory requirements. Laura regularly assists clients with government and internal investigations arising from Anti-Kickback Statute, Stark Act, billing/coding and False Claims Act allegations and advises on compliance with corporate integrity and deferred prosecution agreements. She also serves as lead counsel on complex transactions, often involving multiple parties and creative deal structures.

Laura’s antitrust practice covers the high-tech and manufacturing industries in addition to health care. She helps clients structure their operations, acquisitions and joint venture arrangements to minimize antitrust risk and provides representation in pre-merger reviews before the Federal Trade Commission and the Department of Justice.