CMS to Implement Appropriate Use Criteria for Advanced Imaging Services

The Centers for Medicare and Medicaid Services (CMS) will soon implement new imaging requirements through an Appropriate Use Criteria for Advanced Imaging Services to reduce inappropriate or incorrect imaging orders. CMS will begin to implement these criteria in 2020 as a voluntary compliance year and will require full compliance beginning in 2021. These criteria may significantly affect the imaging-servicing process at healthcare facilities that order or deliver imaging services, thereby affecting medical access professionals.

A few quick basics about this AUC:

• CMS is trying to curb inappropriate and/or incorrect imaging orders to help reach a diagnosis.
• To enforce these new stipulations, CMS will require the rendering provider to prove on the claim he/she submits that the ordering provider consulted a clinical-decision support system, which grades the effectiveness of the potentially ordered test, to determine if it’s the best test for that individual.
• The rendering provider would document this transaction by including a Decision Support Number on the claim.

Many questions and challenges are currently unanswered and this will undoubtedly only increase as the full implementation date gets closer. Many hospital groups have expressed concerns regarding the logistical feasibility of this requirement, and the burden it will have on the current system. 

NAHAM’s Policy Development and Government Relations Committee is working to provide the NAHAM membership education, resources, and support around this rule this year and next to ensure you are as equipped as possible to implement and facilitate this AUC. Visit the NAHAM website to find more information about AUC and the other issues the committee is tracking.  

Look for more information about educational webinars, guidance documents, and additional news from NAHAM’s Policy Development and Government Relations Committee within the coming months. As always, you’re welcome to contact the PD & GR Committee with questions or requests for more information by emailing Molly Giammarco, NAHAM’s Senior Manager for Government Relations.

Congress Facing Pressure to Pass Telehealth Bill for Senior Care

We are sharing the following article on the proposed federal RUSH (Reducing Unnecessary Senior Hospitalizations) Act in our blog because we expect that if/when it becomes law, there will be an impact on Patient Access and our hospitals.  Reducing “unnecessary” hospitalizations will help reduce re-admission rates and emergency department visits for Medicare patients from skilled nursing facilities.  A plus for us.  However, we also anticipate that there will be some additional work to create the administrative framework to document and bill for telemedicine services.

Stay tuned for more information as it comes to this.

Congress Facing Pressure to Pass Telehealth Bill for Senior Care
Connected care advocates are pressuring Congress to pass the RUSH Act, which aims to increase telehealth and telemedicine services in senior care facilities.

By: Eric Wicklund

Connected care advocates are lobbying Congress to pass the Reducing Unnecessary Senior Hospitalizations (RUSH) Act of 2018, which aims to reduce rehospitalizations at qualified skilled nursing facilities by giving them more incentives to use telemedicine and telehealth to improve patient care.

And they want it done soon.

Among those pushing for passage of the bill is Health IT Now. The broad-based coalition fired off a letter to lawmakers last week following the Centers for Medicare & Medicaid Services' release of a report on the use of telehealth in Medicare.

"In this report, CMS makes the case for passage of the bipartisan, Health IT Now-endorsed RUSH Act better than we ever could ourselves," Joel White, the group's executive director, said in the letter. "Now, the agency should put its findings into action by joining us in calling for swift passage of this sorely needed legislation during the current 'lame-duck' session." 

Read the full article here.

- The NAHAM Policy Development and Government Relations Committee

NAHAM Launches Monitoring Program for Key Patient Access Regulatory Issues

NAHAM’s Policy Development and Government Relations (PD & GR) Committee has identified and will actively monitor nine regulatory issues that impact the daily workflow of Patient Access.  Most are regulatory items required specifically by the Centers for Medicare and Medicaid Services (CMS):

•         the Important Message from Medicare (IM)
•          the Medical Outpatient Observation Notice (MOON)
•          the Advance Beneficiary Notice of Noncoverage (ABN)
•          the Emergency Medical Treatment & Labor Act (EMTALA) requirements
•         Medicare Secondary Payer (MSP)
•          CMS documentation requirements for Administrative Gender.  T

The Committee is also monitoring

•          501(r) Pricing Transparency
•          HIPAA privacy rules

Visit the NAHAM Key Issues Management Page on the NAHAM website. Membership is not required to view the page.  Each issue is briefly explained and source material is provided through outside sources and NAHAM toolkits. The NAHAM toolkits include best practices and guidance documents relating to CMS surveys, Joint Commission surveys, and positive patient identification.  NAHAM Toolkits are available on the NAHAM website as a members-only benefit.

To highlight the Medical Outpatient Observation Notice (MOON), the Key Issues Management Page includes a brief description that Hospitals and CAHs are required to provide the MOON to Medicare beneficiaries (including Medicare Advantage health plan enrollees) informing them that they are outpatients receiving observation services and are not inpatients of the hospital.  The description also includes background information that the MOON is mandated by the Federal Notice of Observation Treatment and Implication for Care Eligibility Act (NOTICE Act), passed on August 6, 2015. This law amended Section 1866(a)(1) of the Social Security Act by adding new subparagraph (Y) that requires hospitals and CAHs to provide written notification and an oral explanation of such notification to individuals receiving observation services as outpatients for more than 24 hours.

Resources posted on the webpage include a link to Form CMS-10611, a link to CMS’s Frequently Asked Questions for the MOON, and instructions for the use and completion of the MOON.  There is a link to section 400 of Chapter 30 of the CMS Claims Processing Manual where full instructions on the MOON’s use, execution, and delivery are included.  There is also a link to the basic CMS landing page for the MOON and a link to NAHAM’s CMS Survey Toolkit which includes an entry for “Regulations and Guidance: Medical Outpatient Observation Notice (MOON).

In addition to this resource, the PD&GR Committee will respond to questions and host discussions on NAHAM’s Access Forum for regulatory issues.  Members are encouraged to subscribe to the Regulatory Issue forum and post their questions about these and other regulatory issues here. The Regulatory Issues Forum is open to both members and non-members.  

New Medicare Cards Are On Their Way; Mailings for 20 States, the District of Columbia, and 3 Territories Already Complete

CMS is well underway with its program of mailing out the new Medicare Cards.  You can find the updated mailing strategy here (https://www.cms.gov/Medicare/New-Medicare-Card/NMC-Mailing-Strategy.pdf). 

The mailing strategy is based on waves of mailing in clusters of states, with waves 1, 2 and 3 completed. It’s important to note that these waves of new card mailing are for currently eligible beneficiaries, those already in possession of the old card version.  Newly eligible beneficiaries began receiving their new cards as of April of this year.  

The first three waves targeted existing beneficiaries in the following states, the District of Columbia, and territories (listed in alphabetical order, not in order of the first three waves): Alaska, American Samoa, Arkansas, California, Delaware, District of Columbia, Guam, Hawaii, Illinois, Indiana, Iowa, Kansas, Maryland, Minnesota, Nebraska, North Dakota, Northern Mariana Islands, Oklahoma, Oregon, Pennsylvania, South Dakota, Virginia, West Virginia, and Wisconsin.

Patients from these states who have not received their new card should go to their MyMedicare.gov account (or to create an account if they don’t already have one), or call 1-800-MEDICARE (1-800-633-4227).

As a healthcare provider, there is a way to check on the status of a patient’s card AND find their new MBI. Find out how here (https://www.cms.gov/Medicare/New-Medicare-Card/Providers/Getting-MBIs.html). 

You can also share CMS’s “Still Waiting for Your New Card?” found here (https://www.cms.gov/Medicare/New-Medicare-Card/Outreach-and-Education/Tear-Off-for-After-Card-Mailing-Ends.pdf).

Wave 4, targeting Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, and Vermont, started in July.  Wave 5, targeting Alabama, Florida, Georgia, North Carolina, and South Carolina, started in August.  

Waves 6 and 7 are scheduled for sometime after August for the states of Arizona, Colorado, Idaho, Montana, Nevada, New Mexico, Utah, Washington, and Wyoming (Wave 6) and Kentucky, Louisiana, Mississippi, Missouri, Ohio, Puerto Rico, Tennessee, and Virgin Islands (Wave 7).

There is also an online map that tracks the mailing waves found here (https://www.medicare.gov/NewCard/).

Remind your patients that just because their neighbor or others known to them have received their new cards, the fact that they haven’t yet is no reason for alarm.  Again, if your patient lives in one of the states in Waves 1, 2 or 3 and haven’t received their new card, they should contact Medicare.  If they live in a Wave 4 or 5 state and haven’t yet received their new card, be patient.

Several things to remember (and to remind your patients):

1. The patient’s new card will automatically come to the patient.  The patient doesn’t need to do anything as long as their address is updated with the Social Security Administration. Patients can confirm that by visiting their account (or creating one) at My Social Security Account at https://www.ssa.gov/myaccount/. 

2. Once the beneficiary gets their new Medicare card, they should destroy their old Medicare card, and they should start using their new card right away.

3.  Look out for scams.  Medicare will never call the beneficiary and ask them to give personal or private information as a prerequisite to receiving their new Medicare number and card.  If someone asks for their information, for money, or threatens to cancel health benefits if they don’t share their personal information, hang up and call Medicare at 1-800-MEDICARE (1-800-633-4227).

As a reminder, the new cards will no longer have the beneficiary’s Social Security Number or the beneficiary’s gender. The new Medicare numbers are a randomly generated, unique combination of numbers and letters.  There is no significance in the order or these numbers and letters. You should begin using the new MBIs as soon as possible. CMS will officially transition to MBI numbers only in January, 2020.  

Are You Ready for the New Medicare Cards?

Medicare is rolling out new cards and MBI numbers, and Patient Access professionals must be prepared to answer questions

Check out the NAHAM webinar 'Are You Ready for the New Medicare Cards' for tips and tricks for your organization.  

The Centers for Medicare and Medicaid Services (CMS) began issuing new Medicare cards in April 2018. Medicare beneficiaries will receive their cards in the mail between April 1, 2018 and April 1, 2019. The new Medicare cards are necessary because the 2015 law, the Medicare Access and CHIP Reauthorization Act, requires CMS to remove Social Security numbers from Medicare cards by April 2019. The move is seen as a way to guard against identity theft; specifically, it is seen as a way to better protect private healthcare and financial information as well as federal healthcare benefits and service payments.

Replacing the Social Security number (the SSN-based Health Insurance Claim Number, or HICN) will be a new Medicare Beneficiary Identifier (MBI). Each beneficiary will be assigned a unique MBI, and it will appear on the new Medicare cards for existing beneficiaries and all new enrollees going forward.

A transition period began April 1, 2018 and will run through December 31, 2019; during this period, providers may use either the SSN-based HICN or the new MBI for purposes of data exchange. Starting January 1, 2020, providers will be required to submit claims using MBIs, no matter the date of service. CMS has developed a secure look-up tool for providers to find the new number at the point-of-service, and when a provider checks a beneficiary’s eligibility, the CMS HIPPA Eligibility Transaction System (HETS) will return a message indicating if CMS has mailed a new card to the beneficiary. CMS has also issued some detailed information on appeals, adjustments and span-date claims.

The new MBI will clearly look different from the Social Security number and two-character Beneficiary Identification Code on the old cards. The MBI will be 11 characters in length, solely made up of numbers and uppercase letters (no special characters). Each MBI is unique and randomly generated, and the characters and sequence are “non-intelligent,” meaning they don’t have any hidden or special meaning. There is a sequence protocol in that certain positions of the 11-character MBI will only have numeric or alphabetic characters, and two positions may have either numbers or letters. Positions 2, 5, 8 and 9 will always be alphabetic. See the CMS webpage: Understanding the Medicare Beneficiary Identifier (MBI) Format [insert link: https://www.cms.gov/Medicare/New-Medicare-Card/Understanding-the-MBI.pdf], for more information.

The new card will have the beneficiary name, the new Medicare Beneficiary Identifier, coverage and coverage dates. These element names will be in both English and Spanish. The gender and signature line found on the old Medicare card will not appear on the new card. All cards will be printed on white paper.

Once issued, beneficiaries and providers may begin using the new MBI immediately. For more information, see the CMS webpage: What do the new Medicare cards mean for partners and employers? [insert link: https://www.cms.gov/Medicare/New-Medicare-Card/Partners-and-Employers/Partners-and-employers.html]

Mailings will include the new card and a letter with instructions for the beneficiary. Distribution of cards will be random, so there is no relationship between mailing and geographic regions.

A September 2017 CMS survey found “extremely low awareness” of the planned changes among beneficiaries. When told of the changes, the survey found most see this as a positive change and had no major concerns. CMS is including education during its 2017 open enrollment and will be sending providers information on how they can help during the first quarter of 2018. CMS is also planning an aggressive social media campaign.

CMS advises providers to check with their solution vendors to make sure they have received instructions about the secure provider look-up tool, and that they are aware of all system changes. CMS also asks providers to display posters and place “tear-off” pads in offices and waiting rooms — all of which may be found and ordered online. Providers should also periodically check the Medicare Learning Network [insert link: https://www.cms.gov/medicare/new-medicare-card/nmc-home.html] for more information.  

Providers will be involved in educating patients, and CMS provides a number of resources to use when talking to patients about their new Medicare cards. Here are some of the points CMS emphasizes in these materials to tell patients:

1.      Right now patients should make sure their mailing addresses are up to date with the Social Security Administration. CMS will use that address to send a new Medicare card. They can check and update online through your “my Social Security” account [insert link: https://www.ssa.gov/myaccount/] or by phone 1-800-772-1213 (TTY: 1-800-325-0778).

2.      Patients may not get the new Medicare card right away. Mailing out new cards to all beneficiaries will take time. They will only need to call Medicare if they don’t receive their card by April 2019.

3.      Patients should be wary of anyone who contacts them about their new Medicare cards. Medicare will never ask someone to give them personal or private information for a new card or number. CMS is planning a “Guard Your Card” campaign starting in late summer of 2018.

4.      Even though they are getting a new Medicare card and number, a patient’s Social Security number remains the same. They just won’t be using it relative to their Medicare benefits.

5.      Once they receive a new Medicare card, patients should check the name and other information to make sure it is correct. The new card will not change their current coverage or benefits. If everything is in order, they should destroy the old card and start using their new card.

6.      Patients must remember to bring their new Medicare card. Doctors and other healthcare providers will ask for it when they need care. If they forget their new card, doctors or other healthcare providers may be able to look it up online.

7.      Patients should guard their new card and new identification number (the MBI) just as they did their old card and Social Security number. They should only give their card and MBI to doctors, pharmacists and other healthcare providers, their insurers or people they trust to work with Medicare on their behalf.

8.      Their new card will be paper. It will be easier for providers to use and copy and they can print your own replacement card if need be.

Is Your Address Up to Date?

This should become the most common question you ask Medicare beneficiaries. Not the first thing you’d think of when talking to patients about the new Medicare cards that will start appearing this spring, but providers will play an important role in educating patients about the new cards and the new Medicare Beneficiary Identifiers. One important thing for the Medicare beneficiary to do is to make sure their mailing address is up-to-date with the Social Security Administration because CMS will use the address they have on file with Social Security; new cards started mailing out on April 1, 2018 and will continue through April 1, 2019.

Be Vigilant Against Identity Theft

Beneficiaries should know not to share their new Medicare number with anyone other than their healthcare providers, their insurers or trusted healthcare advocates with Medicare. Medicare will never ask someone to give them personal or private information just so they can get their new card or number. Don’t fall for phone scams!

The Joint Commission issues Quick Safety 42: Identifying human trafficking victims

 The Joint Commission issued a safety alert on identifying human trafficking victims on June 18 (see Quick Safety 42: Identifying human trafficking victims). The first paragraph is an attention-getter:

The United States is one of the largest markets and destinations for human trafficking victims in the world. If staff at your health care organization have not yet encountered a human trafficking victim, very likely they will. Knowing how to identify victims of human trafficking, when to involve law enforcement, and what community resources are available to help the individual is important information for all health care professionals.

The alert notes over 40,000 reports of human trafficking in the U.S. over the 10-year period 2007-2017, with the largest number of reports coming from California, Texas, Florida, Ohio and New York, and asserts that “Human trafficking is the fastest growing criminal industry in the world and is the second-largest source of income for organized crime.”

Part of the problem is one of recognition and the challenge seems to be both identifying and knowing how best to help victims.  Most victims or their families have been threatened with harm if they reveal their exploitation, in some cases the victim may not realize his or her rights in the host country, and often times the victim has bonded with his or her exploiter, a condition known as “trauma bonding”.  In addition to fear of physical harm, victims also keep silent due to shame or fear of being humiliated.

The alert provides a technical definition of human trafficking, citing the United Nations Protocol to Prevent and Suppress and Punish Trafficking in Persons, Especially Women and Children and a U.S. law, the Victims of Trafficking and Violence Prevention Act.  But perhaps more helpful, it identifies “at-risk” or the most vulnerable populations for human trafficking which include children involved in foster care, runaway and homeless youth, Native Americans, LGBTQ individuals, undocumented immigrants, among others.  Also particularly useful, the alert highlights health care problems most that may trigger a cause for concern.

So to repeat the stance of The Joint Commission: “Knowing how to identify victims of human trafficking, when to involve law enforcement and what community resources are available to help the individual is important information for all health care professionals.”  The alert provides some metrics for recognizing signs of human trafficking and guidance for when human trafficking is suspected.

In terms of recognizing signs of human trafficking, there are poor mental health or abnormal behavior (such as appearing fearful, avoiding eye contact and refusing treatment) and poor physical health (such as appearing malnourished or signs of physical abuse).  Other signs include not being in control of personal identification, not be allowed to speak for themselves, and inconsistencies in his or her story).

Regarding when human trafficking is suspected, The Joint Commission notes that every situation will be unique and that “it is important to use a victim-centered response.”  While not every victim will be ready to seek help, the Commission notes that “if a victim is a minor (under 18 years of age), the provider is legally obligated to contact Child Protective Services.”  Responses will also depend on whether human trafficking is suspected or if the patient has disclosed that he or she has been trafficked.  The Joint Commission offers options for each of these situations.  For example, the alert notes that if the patient indicates he or she has been trafficked “in situations of immediate, life-threatening  danger,” the provider should follow “institutional policies for reporting to law enforcement.”  Other “safety actions” recommended include providing the patient with options for services, reporting and resources and if your organization has a social worker – “utilize them”. 

What role could Patient Access personnel be expected to play?  Most likely Patient Access would become aware in the Emergency Department – so personnel could be exposed to the common signs and at-risk groups identified in The Joint Commission’s alert to increase general awareness.  Institutional protocols would govern who in the organization would be engaged once human trafficking is suspected or confirmed.  Patient Access personnel should know who to contact within the hospital so appropriate action can be taken. 

As Martin Muratore, CHAM stated, “The role would be interdisciplinary. If and when Patient Access became aware, they would need to ensure that proper notifications were made.  As with all crime and for victims of abuse, any person who has contact with the patient should immediately report to police and social services or the social work department of the organization.”  Muratore notes that in most cases it will be an actual health care provider in the clinical situation who first becomes aware of the abuse or trafficking. Brenda Sauer, RN, MA, CHAM, FHAM agrees: “The Patient Access professional should be able to identify and then report through their usual channels if they suspect abuse.  This is usually  telling a clinician or social worker of their suspicions.”  And Nancy Farrington, CHAM, FHAM confirms that it is most likely going to be a clinician who is in the best position to detect abuse, but that Emergency Department Patient Access may be in a position to notice signs and that reporting to clinicians or social workers is the appropriate response. “Patient Access staff may become aware of these situations, especially in the Emergency Department. I would not expect Patient Access staff to report suspicions to outside agencies but rather to follow internal protocols to have providers, clinicians, social workers, etc. make an assessment and take action.”

The Joint Commission’s alert is worth a read and provides some actionable and educational material for staff.  Awareness and response will clearly involve multiple disciplines in the organization and emphasizing internal protocols in addition to the information provided in the alert is a good place to start.

NAHAM Suggests Best Practices for Joint Commission Proposal Regarding the Use of Distinct Naming Conventions for Newborns

The Joint Commission has developed a new element of performance to be added to the National Patient Safety Goal NPSG.01.01.01 applicable to hospitals and critical access hospitals that provide obstetric services, specifically labor and delivery, nursery care, and/or NICU services.  The proposed NPSG.01.01.01, EP 3 requires the use of a distinct naming convention for positive patient identification for newborns:

For newborn patients: Use distinct naming systems methods for accurate patient identification.

Note: Examples of methods to prevent misidentification include the following:

 — Distinct naming systems using the mother’s first and last names and the newborn’s gender (for example, Smith, Judy Baby Girl or Smith, Judy Baby Girl A and Smith, Judy Baby Girl B for multiples).

— Standardized practices for identification banding (for example, two body-site identification and barcoding).

— Establish communication tools among staff (for example, checking for two patient identifiers prior to medical record entries and visually alerting staff with signage nothing newborns with similar names).

— Utilize a second person prior to high-risk procedures for positive identification purposes. This could be a second medical professional or approved family member to verify patient name or medical record number.

 

The associated rationale for the proposal is to the point, with the last sentence seemingly a conclusion many in Patient Access will already have arrived at in an effort to ensure positive patient identity in the bold new world of portable electronic records:

Newborns are at higher risk of misidentification due to their inability to speak and lack of distinguishable features. In addition to well-known misidentification errors such as wrong patient/wrong procedure, misidentification has also resulted in feeding a mother’s expressed breastmilk to the wrong newborn, which poses a risk of passing bodily fluids and potential pathogens to the newborn. A reliable identification system among all providers is necessary to prevent error.

In fact, NAHAM has long supported the general rationale and principle of NPSG.01.01.01 requiring at least two patient identifiers in the clinical setting; in fact, NAHAM has advocated for the development and implementation of robust patient identity integrity programs for use throughout healthcare facilities, recognizing that hospital registration is the front line for ensuring the patient is positively identified, matched with existing healthcare records, and directed to the appropriate clinical setting.  NAHAM-recognized best practices include multiple patient identifiers to achieve this goal, and NAHAM’s 2016 publication of its Best Practice Recommendations for the Collection of Key Patient Data Attributes seeks to drive an across the board adoption of practices focusing on five essential data points for patients: names, address(es), phone number(s), date of birth, and gender.  Working with the Office of the National Coordinator for Healthcare IT (ONC), NAHAM offered its Best Practice Recommendations emphasizing that data integrity through robust collection and recording protocols plays an essential role in patient care and identification in the clinical setting.  Acknowledging the importance of registration in positive patient identification, the ONC developed the Registrar Playbook based on NAHAM’s data collection recommendations. 

Positive patient identity includes the need for consistent naming conventions throughout all healthcare settings, and this has become increasingly important given the great diversity in the U.S. population and cultural and ethnic influences on family names, given names, and preferred names. 

Of interest to Patient Access, the new element of performance, “Use distinct naming systems methods for accurate patient identification,” offers the following example using the mother’s first and last names and the newborn’s gender as a compliant naming convention: “Smith, Judy Baby Girl,” or in the case of multiple births: “Smith, Judy Baby Girl A” and “Smith, Judy Baby Girl B.”

This convention or other very similar ones are generally employed in hospitals today, recognizing, as has the Commission, that the use of nondistinct naming conventions have been associated with increased risks of wrong-patient errors, and recognizing the unique circumstances involved with newborns.  The Commission has also provided previous guidance regarding the use of temporary names that are not distinct enough to address the risks of misidentification.  See, Temporary names put newborns at risk. Quick Safety – Issue 17 (The Joint Commission: October 2015).

The Commission’s proposal seems to provide flexibility for each hospital to adopt its own specific naming convention for newborns so long as it is distinct, is used consistently, and includes at a minimum the elements included in the Commission’s example noted above.  This allows a hospital to ensure that compliance with proposed NPSG.01.01.01, EP 3 will be appropriately linked to its current systems and its larger set of protocols associated with patient records and data integrity.  That’s important, even recognizing the long-term goal of the adoption of common patient data collection protocols, including naming conventions, across all healthcare settings.

At least until such time as all hospitals are using common data collection protocols and all IT systems in use can support specific data fields, this flexibility allows hospitals to adopt even more robust practices from which new best practices may emerge.  In the case of a naming convention for newborns that will support NPSG.01.01.01, EP 3, there is the potential for space limitations for characters on a newborn’s identification band, bracelet, specimen labels, and in some electronic systems.  Using the format of mother’s last name – mother’s first name – the word “Baby” followed by the newborn’s gender and birth order (when applicable) (e.g., “Smith, Judy Baby Girl A”) risks losing essential identification information when the mother has a name with over a certain number of characters.  Hyphenated last names, as well as lengthy names based on cultural and ethnic norms, are a reality that can and should be taken into consideration.

To address the space limitations noted above, NAHAM has suggested not using the word “Baby” in the naming convention for newborns and using a different order for the key identification information: mother’s last name – newborn’s gender – newborn’s birth order – mother’s given name.  For example –

“Dougherty, Girl A Mary Elizabeth” and “Dougherty, Girl B Mary Elizabeth”

“Vaidaynathen, Girl A Gowriprabha” and “Vaidaynathen, Girl B Gowriprabha”

“Penobscott-Smith, Girl A Penelope” and “Penobscott-Smith, Girl B Penelope”

These, as examples of an alternative distinct naming convention to positively identify newborns, should be consistent with proposed NPSG.01.01.01, EP 3, and will ensure that the newborn’s gender and birth order are not at risk of being “dropped” as the final characters in the newborn’s identification by banding,  labeling, and other systems.  This order ensures the mother’s last name and all or a portion of the mother’s first name will be captured.

Compare the more commonly used convention and the emerging practice introduced above (where the underlined characters risk being “dropped” because the number of characters exceeds, in these examples, 25) –

Dougherty, Girl A Mary Elizabeth

Dougherty, Mary Elizabeth Baby Girl A

Dougherty, Girl B Mary Elizabeth

Dougherty, Mary Elizabeth Baby Girl A

Vaidaynathen, Girl A Gowriprabha

Vaidaynathen, Gowriprabha, Baby Girl A

Vaidaynathen, Girl B Gowriprabha

Vaidaynathen, Gowriprabha, Baby Girl A

Penobscott-Smith, Girl A Penelope

Penobscott-Smith, Penelope, Baby Girl A

Penobscott-Smith, Girl B Penelope

Penobscott-Smith, Penelope, Baby Girl B

Given the important role of identification banding and labeling of specimens and medicines in the clinical setting, NAHAM sees an opportunity for hospitals to ensure that their systems for banding and labeling be able to capture the most important identification information for newborns, recognizing that the mother’s first and last names may cause the entire naming convention to exceed the available spaces on bands, bracelets, and labels.