Readers of NAHAM News will know of the current prohibition on federal funding for the development of a unique patient identifier.
Here’s a very brief history. In 1993 President Clinton proposed a health plan that included the issuance of health security cards to all Americans certifying their right to medical care, putting in place the concept of a unique patient identifier. While the first term Clinton healthcare reform proposal was not successful, in 1996 Congress passed the Health Insurance Portability and Accountability Act of 1996 (HIPAA). HIPAA included administrative simplification provisions that required HHS to “adopt national standards for electronic health care transactions” and “a standard unique health identifier for each individual, employer, health plan, and health care provider for use in the health care system”.
In 1998, Congress passed Public Law 105-277 (an omnibus appropriations act for fiscal year 1999) that prohibited HHS from spending any funds to “promulgate or adopt any final standard…providing for, or providing for the assignment of, a unique health identifier for an individual…until legislation is enacted specifically approving the standard [Title V, Section 516 of PL 105-277].” Despite numerous calls for further work towards a unique patient identifier, including the 2008 Rand Corporation report, identifying the associated potential administrative cost savings and safety benefits, Congress has maintained this prohibition.
With this congressional prohibition, HHS has since adopted unique identifiers for employers, health care providers, and is now in the process of adopting a unique health plan identifier, but has not adopted a standard unique identifier for individuals.
Now for what may be a modest breakthrough allowing some HHS engagement on patient matching, even if not by way of developing a unique patient identifier. In its report accompanying the upcoming fiscal year 2017 appropriations bill for the Department of Health and Human Services (referred each year to as the Labor-HHS bill because it funds the Departments of Labor and Health and Human Services, among other smaller federal agencies), the House Appropriations Committee included the following language:
Unique Patient Health Identifier.—The Committee is aware that one of the most significant challenges inhibiting the safe and secure electronic exchange of health information is the lack of a consistent patient data matching strategy. With the passage of the HITECH Act, a clear mandate was placed on the Nation’s healthcare community to adopt electronic health records and health exchange capability. Although the Committee continues to carry a prohibition against HHS using funds to promulgate or adopt any final standard providing for the assignment of a unique health identifier for an individual until such activity is authorized, the Committee notes that this limitation does not prohibit HHS from examining the issues around patient matching. Accordingly, the Committee encourages the Secretary, acting through the Office of the National Coordinator for Health Information Technology and CMS, to provide technical assistance to private-sector led initiatives to develop a coordinated national strategy that will promote patient safety by accurately identifying patients to their health information.
The language attempts to clarify this long-standing prohibition by noting that “this limitation does not prohibit HHS from examining the issues around patient matching”. If recognized by the Department of Health and Human Services, this represents a very positive step forward. The operative language that HHS will hopefully take up is the Committee’s encouragement that HHS, in coordination with the ONC (Office of the National Coordinator for Health Information Technology) and CMS, “provide technical assistance to private-sector led initiatives to develop a coordinated national strategy that will promote patient safety by accurately identifying patients to their health information”.
It remains to be seen what impact this language may have on further work on the development of a unique patient identifier. There are other steps that might also be taken in the meantime. The application of a unique patient identifier is consistent with NAHAM’s Public Policy Statement: Patient Identity Integrity (October 2015), restated below.
Patient Identity Integrity requires additional standardized data attributes in the absence of the universally adopted unique patient identifier.
The National Association for Healthcare Access Management (NAHAM) recognizes and supports patient safety as a national health priority. Patient identification errors through the registration process can delay patient care and increase the potential for patient harm. Long term downstream effects include increased financial liability, diminished reputation, and decreased physician and employee loyalty. Patient identity integrity (PII) ensures that healthcare access professionals identify and accurately match the right patient with his or her complete medical record, every time, in every provider setting. Ensuring the right patient, right record, every time, is the first critical step in providing patient care.
PII processes should be prioritized and standardized to include: principles that guide practice, policies and procedures, training and competency validation, standard scripting, defining acceptable forms of identification, naming conventions, search guidelines and algorithms, banding verification, establishing response guidelines for difficult situations, measuring and tracking duplicate records, and rapid response and resolution to errors.
NAHAM recognizes that current patient identification and matching procedures vary throughout the country. Using two patient identifiers with a combination of secondary identifiers is standard and compliant practice. Achieving the goal of eliminating patient identification errors nationally will require a unique patient identifier and/or a standardization of data capture as well as a standardized combination of data attributes that support Patient Identity Integrity.
Readers of NAHAM News will also know that in the meantime, NAHAM is developing a set of recommended best practices around standardized patient data attributes identified in the ONC’s 2015 Health IT Certification Criteria. Read NAHAM News: Key Patient Matching Attributes Included in 2015 Health IT Certification Criteria (6/23/2016).