CMS National Healthcare Directory RFI Blog Series: Health Plan Response
By Justin Sims
CMS is taking the issue of provider data seriously. In November, they published a Request for Information (RFI) asking for industry feedback on the need and potential scope of a National Directory of Healthcare Providers and Services (NDH) and received over 600 responses. The responses indicate overwhelming support for CMS’s attention to this significant industry challenge.
This series of blog articles summarizes industry feedback about the CMS NDH—beginning with comments from Health Plans.
You might have heard a distant groan when the directory RFI was published. That was the sound of health plans anticipating yet another set of regulations focused on provider data.
Health plans are the stakeholder group that is the most regulated and the most financially invested in provider data. For the past few years, they have been in a mad dash to comply with three regulations related to this topic: the No Surprises Act, the Interoperability and Patient Access Rule, and the Transparency in Coverage rules—and they face potentially hefty penalties for non-compliance.
But it is not just about regulations. Payers have known for decades that when they publish inaccurate data on their provider networks, their members complain, which is why they formed CAQH. This not-for-profit alliance came together to maintain more accurate provider information.
Given this history, it’s surprising that only nine health plans responded to the RFI. Their feedback, along with CAQH, was consistent. We found five key themes:
There was near-universal agreement that maintaining provider directories is a huge challenge and a significant financial burden for payers. So it was no surprise that they argued that healthcare would become more efficient (and less expensive) with a reliable, centralized provider data repository.
While there was sympathy for the burden providers face in maintaining directory information, almost all plans recommended imposing penalties on providers that do not do a good job. And while there was interest in a provider directory collating a broad array of data (such as whether providers are accepting new patients), there was broad support for initially focusing on basic demographic and contact information.
Payers expressed a strong desire to see regulations homogenized. Not only did they see this as necessary at the federal level (where there are different regulations for Medicare Advantage, Medicaid, QHP, and commercial plans), but also at the state level, which often impose additional requirements on plans for their provider directories.
Almost all payers argued that if CMS builds a central resource, they should be given a “safe harbor” from fines and penalties if they relied on that information when publishing their directories. And some went further, wanting to be relieved of any burden in sourcing accurate location and contact information.
Most payers raised concerns about CMS publishing information on the health plans with which an individual provider is contracted. This, they argued, was for them to maintain—with the silent inference that this was competitive intelligence and may impact consumer behavior when selecting a health plan.
Digging into the details, there were some differences in opinion about how CMS should go about building a directory. UnitedHealth Group, for example, made a case for CMS starting with the CAQH database rather than NPPES, the NPI database. And CAQH advocated for CMS to leverage existing industry efforts to collect and update data vs. build a new centralized approach.
Payers agree this is a problem worth solving but cautioned that it is more complex than it may appear. They argued forcefully for a “partnership approach” between payers, providers, health IT companies, and CMS and encouraged CMS to listen to the industry before formulating a strategy and an action plan.
Who can argue with “ready, aim, fire!”?
So, what do you think of the RFI responses from Health Plans? We’d love your feedback —send us an email anytime.
Justin