Description (*Please confirm or update this field for the new USCDI version*)
Sequence of characters representing a physical place of available services or resources.
Submitted By: Keith W. Boone
/ Audacious Inquiry
Data Element Information
Data Element Description
An identifier which uniquely identifies this facility.
Use Case Description(s)
Use Case Description
Facility level data is associated with laboratory tests (the testing facility), and health care provider locations, including hospitals, ambulatory providers, long-term and post acute care, and pharmacy providers.
Location data is used to support reporting of data for public health and emergency response (e.g., situation awareness reporting).
See https://build.fhir.org/ig/HL7/fhir-saner/ for details (note that (minus) - is a legal character in URLs, had to use a bit.ly link to get past validation errors in URL)
Estimate the breadth of applicability of the use case(s) for this data element
Hospitals in the US (Approximately 7000), Laboratories (260,000), pharmacies (88,000), ambulatory physicians (260,000).
5 or more. This data element has been tested at scale between multiple different production environments to support the majority of anticipated stakeholders.
Restrictions on Standardization (e.g. proprietary code)
None
Restrictions on Use (e.g. licensing, user fees)
None
Privacy and Security Concerns
Locations associated with Critical Access Hospitals, and single provider facilities may constitute PHI (in geographic locations with limited populations) and/or Individual Identifiable Information (e.g., for HCPs working from a combined home/office facility).
Estimate of Overall Burden
Most electronic systems provide the capacity to store location and organization information. Many EHRs already provide access to the Location resource via READ operations, some (e.g., Epic, AthentaHealth) provide search capabilities as well. This information is routinely communicated in HL7 V2 Messages, CDA Documents and some FHIR API transactions. To address gaps, implementers would need to modify interfaces (e.g., for CDA or HL7 V2), or add an endpoint. Estimated effort (based on past experience building EHR systems) is about one two-week sprint to implement the capability by a developer.
Other Implementation Challenges
Standards for location identifier may need flexibility depending on use of Location for reportiong, as there are a number of distinct location identifier systems which may be necessary for different reporting use cases. For example, CDC/NHSN assigns identifiers for HAI reporting, CLIA assigns identifiers to laboratories, CMS provides location identifiers, et cetera.
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.
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.
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.
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).
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.
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)”.
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.
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.
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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 2 The "Propose a New Data Class or Data Element" button redirects users to the ONDEC Submission System for proposing new data elements not currently available in the system.
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Fig 3 The "Comment on another data element" link enables users to create multiple comments addressing different elements within a single submission.
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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 5 A red triangle with exclamation mark indicator appears next to the “Return to saved Comment” button when draft comments are saved in the system.
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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 Enhancing 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.