The Center for Medicare and Medicaid Services (CMS) recently announced a Request for Information (RFI) on a “National Directory of Healthcare Providers and Services” (NDH). DirectTrust supports CMS’s National Directory RFI effort and will provide feedback as part of the process.
The Directory Challenge
We’d like to think we have a pretty unique perspective on the challenge of deploying a national directory. As we are well aware from hosting our own national Directory of aggregated Direct addresses, maintaining a Directory is tough. Compiling information from numerous sources in a standard manner can be difficult. However, the benefits of national directories far outweigh the challenges. An accurate and accessible directory certainly helps aid in the timely location and identification of healthcare providers. Even more so, a strong directory helps in the expeditious exchange of health information to best serve patients.
CMS already has much of the structure of a national directory in NPPES providing a central location for National Provider ID (NPI) lookup. As the press release announcing the CMS National RFI Directory outlines, CMS added additional NPPES fields for “digital endpoints” in 2018. CMS requires providers to publish their digital contact information in NPPES or they will be listed quarterly “Wall of Shame”. The last report (July 2022 for Q2 2022 data) included over one million rows of data. Certainly, there is a challenge getting various types of provider data and addresses in one place. As shared in the RFI, NPPES, and the several other directories which have been deployed by federal agencies were not intended as directories per se. The national directory is not intended to replace these, but instead, will provide for a single access point for all of the information that they contain.
As the nation’s largest healthcare payer and as a leader in national healthcare initiatives, CMS is interested in public comment on how they can best be the centralized hub for this information. While other directories exist (like DirectTrust), many of them are specialized – there isn’t one centralized repository. CMS could fill this gap, but they need stakeholder feedback.
Our Experience – The Directory Improvement Initiative
As the maintaining entity of the DirectTrust Aggregated Directory, we’ve seen firsthand the challenges of directory updates and accessibility. It’s why we set out on our own Directory Improvement Initiative, which you can learn more about here. This effort includes new development and a re-architecture to utilize the same standard that the National Directory intends to use as a starting point. But the overarching goal of the work is to improve the quality of the data in the directory – a continuous improvement project we are making a long-term commitment to. Most recently, we identified four key fields that if updated across the Directory would have significant impact on quality improvement.
Improving our Directory is not necessarily a “quick fix” – it’s intentional, well thought out, and includes multiple phases. It feels as if CMS is taking this same approach, considering how users of a national directory will find the information they need. For us, the Directory Improvement Initiative spans the course of several years, including defined “eras”. If you’re interested in learning more about our Directory improvement efforts, sign up here for more information.
DirectTrust Supports a National Directory
We’re on Team Interop at DirectTrust – we support initiatives that make health information exchange easier. A National Directory certainly aids in the timely flow of health information, better serving patients and providers. As the custodian of the Direct Standard™ and Direct Secure Messaging, we know that a national Directory helps Direct exchange happen. We don’t envision that CMS’s National Directory will replace the DirectTrust Aggregated Directory, rather, we envision a closer collaborative relationship.
As an example of such a collaboration, as part of the Directory Improvement Initiative, we’re implementing validation checks against NPPES. For each Aggregated Directory entry that contains an individual or organization NPI, our validation engine compares provider names, specialty codes, organization names, addresses, and faxes to what NPPES has associated with that NPI. When an Aggregated Directory entry doesn’t contain an NPI, we attempt to find one in NPPES using the entry’s other demographic data. The results of these comparison queries are reported in detail to the submitter of the Aggregated Directory entry. Ideally, these validation reports will drive improved data quality in both of our databases. Many entries in our Aggregated Directory do not contain an NPI when there should be, and many providers are missing their digital endpoint (Direct Address) in NPPES. In the future, it’s possible we form even more of a relationship with CMS.
Centralizing provider data points like addresses has numerous benefits. With CMS’s expertise in NPI and some existing infrastructure in place, we support their national directory efforts.
Opportunities to Weigh In
DirectTrust is actively reaching out to our membership and some of our strategic partners for involvement in our public comment to CMS on the National Directory RFI.
If you are interested in submitting your own response, read the CMS National Directory RFI and submit your formal comment here.