Thursday, June 23, 2016

Key Patient Matching Attributes Included in 2015 Health IT Certificaiton Criteria

We have previously previewed the development of best practice recommendations for 5 key patient matching attributes based on the 11 specific attributes recommended in the Office of the National Coordinator’s (ONC’s) 2014 report, “Patient Identification and Matching Final Report.”  See NAHAM News, "Considerations for developing data attribute standards for Patient Access" (3/21/2016). These ONC-identified attributes were also referenced in NAHAM’s Access Management Journal (Fall 2015), and we noted that they fit neatly in the following five main categories: Name Attributes, Date of Birth, Addresses, Phone Numbers, and Gender.

The ONC report includes two key findings, reflecting the recommendations of NAHAM as a stakeholder participant in the report’s development, worth pointing out here:

·        Standardized patient identifying attributes should be required in the relevant exchange transactions.

·        Certification criteria should be introduced that require certified EHR technology (CEHRT) to capture the data attributes that would be required in the standardized patient identifying attributes.

This is consistent with NAHAM’s Public Policy Statement: Patient Identity Integrity (October 2015) that calls for standardized data attributes. (See : "NAHAM Public Policy Statement on Patient Identity Integrity" (3/17/16), reiterating NAHAM’s call for standardized data attributes. This also reflects NAHAM’s statement on record to the ONC, which includes: “NAHAM supports the development of standards for data attributes in electronic systems, whether clinical or administrative, and enhanced common capabilities for all healthcare data systems to input standardized data.” (See the ONC's 2014 final report cited above.)

The ONC has since adopted these attributes, as well as the findings above, as part of the now effective 2015 Health IT certification criteria.  The new certification criteria are intended to improve patient matching through the adoption of the specific attributes captured in NAHAM's five key patient matching attributes.  The effort is focused on "transition of care" emphasizing the ability to retrieve and share patient healthcare information across different healthcare providers and systems.  As explained in the ONC's narrative for the 2015 certification criteria -

As a part of the “Create” portion of the “ToC” [Transition of Care] criterion in the 2015 Edition, we [the ONC] proposed to require a Health IT Module to be able to create a transition of care/referral summary that included a limited set of standardized data in order to improve the quality of the data that could potential be used for patient matching by a receiving system. The proposed standardized data included: First name, last name, maiden name, middle name (including middle initial), suffix, date of birth, place of birth, current address, historical address, phone number, and sex, with constrained specifications for some of the proposed standardized data.

Addressing the concern that some commenters had with the adoption of data sharing standards around these and other attributes, the ONC noted that the new Health IT Module will not impose wholesale changes to a hospital's or system's policies and procedures regarding patient matching -
We note that systems can continue to use their existing algorithms and patient matching protocols and that our proposed approach was not intended to conflict with any existing practice. We reiterate that the proposed data elements stem from the HITPC's [HIT Policy Committee's] and the HITSC's [HIT Standards Committee's] recommendations and findings from the 2013 ONC initiative on patient matching as described in the Proposed Rule (80 FR 16833-16834). 

The ONC also notes that more work remains to be done -
We continue to believe these recommendations represent a first step forward that is consensus-based. We agree that the proposal did not address data quality in the sense that it would improve the “source's” practices and procedures to collect highly accurate and precise data. However, we believe that including standards for the exchange of certain data elements could improve interoperability and provides an overall level of consistency around how the data are represented. We encourage ongoing stakeholder efforts focused on improving patient matching through better data quality processes and will continue to monitor and participate in these activities.

The new Health IT Module, intended to improve patient matching between sending and receiving systems, will include standardized data formats for the patient's name (with separate fields for first name, last name, previous name, middle name, and suffix), data of birth, address, phone number, and birth sex.

[The ONC] have finalized the requirement that Health IT Modules must be able of creating a transition of care/referral summary in accordance with just C-CDA [Consolidated Clinical Data Architecture] Release 2.1 as part of this certification criterion that includes the following data formatted to the associated standards/constraints where applicable:

·        First name
·        Last name
·        Previous name
·        Middle name (including middle initial)
·        Suffix
·        Date of birth—The year, month, and day of birth are required fields. Hour, minute, and second are optional fields; however, if hour, minute, and second are provided then the time zone offset must be included. If date of birth is unknown, the field should be marked as null.
·        Address
·        Phone number—Represent phone number (home, business, cell) in the ITU format specified in ITU-T E.123 and ITU-T E.164 which we are adopting at § 170.207(q)(1). If multiple phone numbers are present, all should be included.
·        Sex in accordance with the standard we are adopting at § 170.207(n)(1)

In subsequent issues of NAHAM News we will highlight each of these attributes as found in the 2015 certification criteria and NAHAM's recommended best practices associated with each one.  NAHAM's Public Policy and Government Relations Committee is developing recommended best practices for Patient Name, Date of Birth, Address, Phone Number, and Sex to address the capture of accurate data to enhance these efforts in standardization. 

Do you have any thoughts on these patient attributes, the standardization of each for purposes of patient transition of care between healthcare providers, or best practices to recommend for the intake of this information from the perspective of Patient Access.  Let us know!