C. Data
1. NPS Data Structures
Proposed Provisions (§ 142.402)
In section IV. B. of the preamble of the May 7, 1998, proposed rule, ''Practice Addresses and Group/Organization Options,'' (63 FR 25336), we asked for public comment on some of the data structures that would be captured in the NPS for each health care provider.
Comments and Responses on NPS Data Structure Concepts
Below are the questions as posed in the May 7, 1998, proposed rule followed by a summary of the comments and our responses:
a. Should the NPS Capture Practice Addresses of Health Care Providers?
Comment:
Responding yes: Some commenters stated that they need to capture the multiple practice addresses of a health care provider for their business functions. They believe it would be best to do this once in the health care provider's NPS record, rather than in many local systems.
Responding no: A large majority of commenters stated that the NPS should not capture any practice addresses or should capture only one physical location address per NPI. Some of these commenters believed that each location where a health care provider practices needs to be identified, but they believed
locations should receive separate identifiers, rather than be captured as multiple addresses in the health care
provider's NPS record. Many other commenters noted that health care provider practice addresses change
frequently and that address information will be burdensome and expensive to maintain and will be unlikely to be maintained accurately at the national level. They believe that, if needed, it should be collected and maintained in local systems.
Response: The NPS will capture the mailing address and one physical location address for each health care
provider. Only one physical location address will be associated with each NPI. Practice addresses would be of limited use in the electronic matching of health care providers. The volatility of practice address information would make maintenance of the information burdensome and expensive. Collecting only one physical location address minimizes the burden of data collection and maintenance, while providing an address where the health care provider can be contacted in situations when a mailing address is insufficient. For example, a mailing address containing a Post Office box number cannot be used for mail delivery by other than the United States Postal Service.
b. Should the NPS Assign a Location Code to Each Practice Address in a Health Care Provider's Record?
Comment:
Responding yes: A small number of commenters recommended that the NPS assign location codes. Most of these commenters were health plans that need to identify all the practice addresses of a health care provider. They want to use location codes as pointers to these addresses in a health care provider's NPS record.
Responding no: A large majority of commenters stated that the NPS should collect only one physical location address of each health care provider and should not assign location codes. If only one physical location address is collected, there is no need to assign location codes to distinguish multiple practice addresses. Respondents noted several technical weaknesses of the proposed location code. They stated that the format of the location code would allow for a lifetime maximum of 900 location codes per health care provider, and this number may not be adequate for health care providers with many locations. The location code would not uniquely identify an address; different health care providers practicing at the same address would have different location codes for that address, resulting in complexity, rather than simplification, for business offices that maintain data for large numbers of health care providers.
Response: The combination of the NPI assignment strategy described earlier in this final rule and the data elements contained in the standard claim and equivalent encounter information transaction eliminate the need for location codes. The NPS will not establish location codes.
c. Should the NPS Link the NPI of a Organization Health Care Provider That Is a Group Practice to the NPIs of the Individual Health Care Providers Who Are Members of the Group?
Comment:
Responding yes: Some commenters responded that they need to be able to associate organization health care providers who are group practices with the individual members of the group. They believe this association can most efficiently be maintained once in the NPS, rather than in many local systems.
Responding no: A large majority of commenters noted that health care provider membership in groups changes frequently and that this information will be burdensome and expensive to maintain and will be unlikely to be maintained accurately at the national level. Some health plans recognize contractual arrangements that may not correspond to groups. Commenters believe that, if needed, membership in groups should be collected and maintained in local systems.
Response: We agree that the NPS should not link the NPI of an organization health care provider that is a group practice to the NPIs of individual health care providers who are members of the group. The large number of members of some groups and the frequent moves of individuals among groups would make national maintenance of group membership burdensome and expensive. Contractual arrangements would be impractical to maintain nationally and would most likely differ from health plan to health plan. Most organizations that need to know group membership and contractual arrangements prefer to maintain this information locally, so that they can ensure its accuracy for their business purposes.
d. Should the NPS Collect the Same Data for Organization and Group Health Care Providers?
Comment:
Responding yes: A large majority of commenters stated that a distinction between organization and group health care providers would be artificial and would serve no purpose.
Responding no: Some commenters stated that organization and group health care providers should be distinguished in the NPS. None of these commenters suggested different data that should be collected for a group health care provider, as opposed to an organization health care provider. We believe that most of these comments reflect a recommendation that group health care providers receive NPIs rather than a recommendation that different data be collected for group health care providers, as opposed to organization health care providers.
Response: No commenter suggested that different data be collected for a group practice than for an organization health care provider and a strong majority of commenters stated that the same data should be collected. We agree that the NPS should collect the same data for group and organization health care providers. Groups will be enumerated as organization health care providers.
Comments and Responses on NPS Data Structure Alternatives
In the May 7, 1998, proposed rule, we presented two alternatives for the structure of health care provider data in the NPS. Under ''Alternative 1,'' the NPS would capture multiple practice addresses. It would assign a location code for each practice address of an individual or group health care provider. Organization and group health care provider records would have different associated data in the NPS. Group health care providers could have individuals (such as physicians) listed as members of the group, and the NPS would link the NPIs of group health care providers to the NPIs of the individuals that make up the group. Under''Alternative 2,'' the NPS would collect the mailing address and one physical location address for a health care provider. It would not assign location codes. It would not collect different data for organization and group health care providers. It would not link the NPI of an organization to the NPIs of individuals or any other health care providers.
Comment: A majority of respondents preferred Alternative 2.
Response: The comments on the four preceding questions and on the two alternatives indicated a strong preference for Alternative 2. We agree with commenters that Alternative 2 will provide the data needed to identify the health care provider at the national level. We agree that the NPS record will be based on the data described in Alternative 2.
Final Provisions
In the ''Final Provisions'' portion of section II. A. 2. of this preamble,''Definition of a Health Care Provider,''
we describe the entities that will be eligible to receive NPIs. The data structures discussed below apply to every entity that is assigned an NPI. The mailing address and one practice address (physical location) will be collected by the NPS for each health care provider. One physical location address will be associated with each NPI.
Because only one physical location address will be collected per health care provider, location codes will not be necessary and, therefore, will not be established by the NPS.
Group practices often have many members, and individual health care providers often move from group to group. Maintenance of this information on a national level would be difficult and costly. Many health plans refer to collect and maintain this information themselves. Therefore, the NPS will not link the NPI of a group to the NPIs of individual health care providers who are members of that group. The NPS will collect the same data from group health care providers as it will collect from organization health care providers.
Group practices will be considered organization health care providers and will be enumerated as organization health care providers. We will design the NPS along the lines of Alternative 2 as presented in the May 7, 1998, proposed rule.