Submitted by CDC_DSMH_WG on
CDC's support for CMS comment for USCDI v7
CDC supports CMS CCSQ recommendation for clarification to Facility Identifier's description by adding some examples of which IDentiers can be used.
Physical place of available services or resources.
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Facility Identifier
Description (*Please confirm or update this field for the new USCDI version*)
Sequence of characters representing a physical place of available services or resources. | ||||||||||||||||||||||||||||||||||||||||||
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Comment
Submitted by rdillaire on
CMS-CCSQ Requests Clarification on Facility Identifier
Recommendation: CMS CCSQ recommends further clarification to Facility Identifier’s description by including some examples, such as National Healthcare Safety Network (NHSN) Organization Identifier (OrgID).
Rationale: Including NHSN OrgID as an example will offer guidance on this data element’s use. Capturing this data is important for tracking patient safety outcomes associated with specific facilities and addresses. Additionally, it enables facilities within a given tax ID to be distinguishable from one another.
Submitted by rdillaire on
CMS-CCSQ Recommends clarification for Facility Identifier
Recommendation: CMS CCSQ recommends further clarification to Facility Identifier’s description by including some examples, such as National Healthcare Safety Network (NHSN) Organization Identifier (OrgID).
Submitted by pwilson@ncpdp.org on
NCPDP Comments on USCDI draft v5
NCPDP supports the use of the type 2 NPI and recommends this to be added to the data elements.
Submitted by yale-coredQMRoadmap on
CMS-CCSQ Support for Facility Identifier for USCDI v5
CMS-CCSQ is pleased to see that Facility Identifier data element was added to USCDI v4. However, we recommend that the Facility Identifier data element be limited to capturing an individual facility instead of an organization or health system (with multiple facilities). We also recommend the NHSN OrgID be added to the Facility Identifier data element in addition to existing standards to capture individual facilities. This recommendation is a slight change from the CMS-CDC recommendation for draft USCDI v4 where NHSN OrgID was recommended under the Organization/Hospital Identifier. Additional discussion amongst CMS and CDC concluded that NHSN OrgID can more adequately capture an individual hospital or individual facility and that the CCN, which is currently in the Facility Identifier data element, is more appropriate as an organizational identifier.
Submitted by pwilson@ncpdp.org on
NCPDP Comment
NCPDP supports the use of the Type 2 NPI and recommends this to be added to the data elements. NCPDP recommends adding the following NCPDP SCRIPT Standard v2017071, NCPDP Specialized Standard v2017071 and NCPDP Telecommunication Standard Version D.0 as “Applicable Standard(s)”.
Submitted by hantran on
CAP Comments on Facility Identifier
- Data Class: Facility Information
- Data Element: Facility Identifier
- CAP Comment: The College of American Pathologists (CAP) supports this data element and finds that this element can capture the necessary information about Laboratory Address and Location. The CAP recommends that this data element should include identifier information number for facilities. If the facility type is a medical laboratory then a CLIA number should be used to unambiguously identify the laboratory.
Submitted by CDC_DSMH_WG on
CDC's Consolidated Comment for USCDI v4
Shared priority for CDC, CMS, and ASPR (via all hazards work with CDC)
- Facility Identifier is necessary for measuring care delivered to inpatients and properly attributing that care. Facility identifier is critical for providing context for granular patient data and supports tracking data back to organizations, which ensures usability of interoperable clinical data. They can also support exchange of data between hospitals and post-acute care providers. All these activities are necessary for providing high quality care to patients, reducing healthcare inequities and disparities, and promoting interoperability and communication – all ONC stated priorities for the USCDI.
- Facility identifiers have been identified as a joint CMS-CDC priority that are critical elements for public health reporting, surveillance, and emergency response (also ONC stated priority for USCDI v4).
- CCN, PTAN, NPI, NHSN OrgID, and CLIA numbers are exchanged across the nation for CMS reporting to appropriately attribute outcomes and measure results. Organization identifiers are also used to support public health use cases, including electronic case reporting and emergency response activities proving applicability across multiple use cases. Accurate facility identifiers are essential to analyze facility level data and inform the allocation of resources such as therapeutics, supplies, staffing, and PPE to prepare for and respond to emergency events.
- Facility names and addresses can be duplicative, so unique facility identifiers are critical to link facility-level primary key to link HAI data collected in NHSN to facility-level COVID-19 hospitalization data collected through the Unified Hospital Data Surveillance System. Linking these data systems is crucial for understanding the impact of COVID-19 on patient safety and other healthcare measures
- The ISWG recommended this element for final USCDI v3, and received HITAC support, noting the need for an identifier combined with an assigning authority
- Additional use cases:
- COVID-19 hospital reporting
- All hazards reporting
- HAI
- Patient safety quality measurement and public health surveillance via NHSN
- Comments from NACCHO: NACCHO supports the inclusion of this data element; NACCHO recommends specifying which facility identifier should be used. Facilities could use multiple identifiers depending on the EHR system. A standard identifier should be used in this data element. Otherwise, an additional element should be added in Facility Information that indicates what identifier is used
- Comments from CSTE: CSTE agrees with CDC's recommendation for this data element.
Submitted by Svellanky on
CMS-CCSQ Support for Facility/Organization Identifier: USCDI v4
A facility, or organizational, identifier is critical for providing context for granular patient data and supports tracking data back to organizations—this type of contextual data element ensures usability of interoperable clinical data. Facility identifiers are used for billing, support data aggregation across sources, as well as attribution. They can also support exchange of data between hospitals and post-acute care providers. All of these activities are necessary for providing high quality care to patients, reducing healthcare inequities and disparities, and promoting interoperability and communication – all ONC stated priorities for the USCDI. Facility identifiers were also previously identified as a joint CMS-Centers for Disease Control and Prevention (CDC) priority as a critical element for public health reporting, surveillance and emergency response – an ONC stated priority for USCDI v4. For example, CDC and CMS rely on facility identifiers to measure the incidence of healthcare associated infections and other patient safety events in facilities, and to direct technical assistance and quality improvement support to underperforming facilities. Furthermore, the ISWG recommended this element for final USCDI v3, and received HITAC support, noting the need for an identifier combined with an assigning authority.
Maturity: This element is classified as Level 2 by ONC and continues to have strong standardization and be in wide use.
- Current standards:
- Health Level Seven International (HL7) Fast Healthcare Interoperability Resources (FHIR) US Core Implementation Guide (IG) STU3-STU5 based on FHIR R4, Organization Profile must support an identifier (https://www.hl7.org/fhir/us/core/StructureDefinition-us-core-organization.html)
- Organization Profile is included in the HL7 FHIR US Core Capability Statement: https://www.hl7.org/fhir/us/core/CapabilityStatement-us-core-server.html; data included in this profile must be able to be exchanged, including the Organization Identifier
Current uses, exchange, and use cases: CCN, PTAN, NPI, and CLIA numbers are exchanged across the nation for CMS reporting to appropriately attribute outcomes and measure results. They are used extensively for electronic clinical quality measure (eCQM) reporting, linking data sources for quality measurement, and for post-acute care reporting and payment purposes. Facility identifiers are also used extensively for electronic case reporting (eCR) and electronic lab reporting (ELR) and are critical for public health agencies ability to monitor the spread of reportable conditions. Exchange of organization identifiers supports facility-specific quality, prior authorization activities, and other assessments that are limited without this information. Additionally, there is active work underway to create an IG for healthcare directories (HL7.FHIR.US.DIRECTORY-EXCHANGE\Home - FHIR v4.0.1) as part of the FAST Da Vinci accelerator initiative, which includes the critical organization and provider identifiers necessary to appropriately use and attribute exchanged data. Among other purposes, organization identifiers are also used to support public health use cases, including electronic case reporting and emergency response activities. For instance, during the early COVID-19 pandemic phase, there was insufficient data tracking across organizations, further complicated by the need to track emergency response resources across individual facilities. Exchange of facility/organization identifiers can mitigate such delays in emergency response activities.
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Fig 1 The "Data Class" and "Data Element" dropdown menus allow users to specify the exact content they wish to comment on.
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Fig 4 The "File Upload" section permits users to attach supporting documentation that supplements their written comments.
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Fig 6 The review screen allows users to verify comment content and make any necessary modifications before final submission.
Submitted by rdillaire on
CMS-CCSQ Requests Clarification on Facility Identifier
Recommendation: CMS CCSQ recommends further clarification to Facility Identifier’s description by including some examples, such as National Healthcare Safety Network (NHSN) Organization Identifier (OrgID).
Rationale: Including NHSN OrgID as an example will offer guidance on this data element’s use. Capturing this data is important for tracking patient safety outcomes associated with specific facilities and addresses. Additionally, it enables facilities within a given tax ID to be distinguishable from one another.